Contract Filers
Rule status: Adopted
Agency: COIB
Effective date: October 9, 2025
Proposed Rule Full Text
COIB-Proposed-Amendment-of-Financial-Disclosure-Rules-Preliminarily-Certified-6.10.25.pdf
Adopted Rule Full Text
Notice-of-Adoption-08-20-2025.pdf
Adopted rule summary:
The Conflicts of Interest Board has amended Section 4-04 of Chapter 4 of Title 53 of the Rules of the City of New York to update its rule defining the category of public servants required to file an annual disclosure report because their duties involve the negotiation, authorization, or approval of contracts, leases, franchises, revocable consents, concessions and applications for zoning changes, variances and special permits.
Comments are now closed.
Online comments: 3
-
Tahir Asar Khan
Comment added June 25, 2025 10:52amGood day All,
Please take special attention and care to this matter, for all New Yorkers.
Thank you
– Tahir -
Loophole Contravenes The Goal!
Comment added July 21, 2025 11:37amOpposing Proposed Rule Amendments to Section 4-04 (Contract Filers)
Submitted: 7/21/25
The proposed amendment to Section 4-04 of Title 53 of the Rules of the City of New York, specifically subdivision (c)(1) creates a significant loophole in the financial disclosure framework.
Key Concern: Subdivision (c)(1) Loophole
The proposed exemption for public servants who “develop general policies, rules, or regulations” would exclude senior policy architects from financial disclosure, despite their central role in shaping zoning, land use, and procurement policy. For instance, a senior staffer at the Department of City Planning who authored a major rezoning plan like the “City of Yes” would be exempt, even though their decisions have substantial financial and land use impacts. These roles are not merely advisory—they shape policy outcomes with material consequences and should not be excluded from disclosure requirements.
Additional Issues:
1. Contradicts Stated Intent: While aiming to improve clarity and precision, the rule weakens oversight by exempting those who design the very policies that drive public contracts and land decisions.
2. Relies on Agency Discretion: Continued reliance on internal agency judgment risks inconsistent and insufficient disclosure.
3. Ignores Real-World Influence: High-level staff often influence outcomes as strongly as those with formal approval authority.
4. Undermines Transparency: The proposal appears to reform the system but instead codifies exemptions for influential figures.
Recommendation:
I urge the Board to revise or remove the exemption in subdivision (c)(1). At minimum, senior officials who shape zoning or procurement policy should remain subject to financial disclosure. Transparency must include both decision-makers and those who create the frameworks for those decisions.
This rule change, as written, weakens accountability and opens the door to hidden conflicts of interest. Please reconsider this aspect of the proposed amendment. -
Suwen Cheong
Comment added July 22, 2025 1:53pmOpposing Proposed Rule Amendment to Section 4-04 (Contract Filers)
Subdivision (c)(1) Loophole
The proposed exemption for public servants who “develop general policies, rules, or regulations” would exclude senior policy architects from financial disclosure, despite their central role in shaping zoning, land use, and procurement policy. For instance, a senior staffer at the Department of City Planning who authored a major rezoning plan like the “City of Yes” would be exempt, even though their decisions have substantial financial and land use impacts. These roles are not merely advisory—they shape policy outcomes with material consequences and should not be excluded from disclosure requirements.Please remove this exemption for all paid staff or consultants in senior or supervisory positions at the department of City Planning, Landmarks Preservation Commission, Department of Buildings, Board of Standards and Appeals, DCAS, or Housing Preservation and Development who “develop general policies, rules, or regulations” related to zoning, land use, variances, franchises, or leases.