Donations and Gifts to the City – extension of public comment period

Online comments: 2

• Rachael Fauss

  Thank you for the opportunity to provide testimony for this hearing. My name is Rachael Fauss, and I am a Senior Policy Advisor for Reinvent Albany. Reinvent Albany advocates for transparent and accountable government in New York.

  We appreciate that the Conflicts of Interest Board (COIB) reopened public comment on its proposed rules for travel payments in response to our September 2025 testimony and the comments of others.

  We continue to believe that New York City needs to be bolder in its response to the scandals that occurred during the Eric Adams administration – many of which included travel payments. Given the large number of press accounts, we think it is obvious that the public is concerned that special interests are attempting to influence city officials by paying for their travel.

  While we support the modest changes that COIB suggested – aligning the reporting threshold to $1,000 for all reports by agencies and individuals, and ensuring that travel be “government-class” – we again ask the COIB to think big and ban third-party travel payments altogether. COIB excludes travel payments from the gift ban under certain conditions – not NYC law – and it is up to COIB to undo this allowance.

  Lastly, we ask COIB to revisit its decision to not post on its website the financial disclosures of elected officials who have left office. Section 12-110 of the Administrative Code simply states that disclosures from “each elected officer described in sections four, twenty-four, twenty-five, eight-one, ninety-one and eleven hundred twenty-five of the New York city charter shall be made available for public inspection on the board’s website without written request.” We see no reason that this should not apply to disclosures filed by former officials that cover the years they were in public office.

  For example, the 2021 financial disclosures published on COIB’s website do not include former Mayor Bill de Blasio. Similarly, in 2025, a disclosure filed by Zohran Mamdani is posted, showing travel payments paid by his transition committee, but Eric Adams’s 2025 disclosure is not currently on COIB’s website. The 2025 disclosure for Eric Adams is of particular public interest, and likely has information about travel payments that could be topical for today’s hearing.

  New data on disclosures shows hundreds of thousands in travel gifts

  Our testimony provides new data about the scope of travel payments that shows they are significant, and are increasing as public officials are resuming travelling after the COVID-19 pandemic. We found $77,025 in travel payments reported by elected officials on their financial disclosures in 2024, and $28,000 reported for 2025 – however, as noted previously, incumbents from 2025 who left office are not included, as their forms are not currently on COIB’s website, like Eric Adams.

  In 2025, city agencies reported gifts of $186,788 listed explicitly for travel expenses, and we believe even more gifts are likely related to travel ($24,350 in in-kind donations from transportation companies, and $247,520 in payments for conference attendance). More details are provided below.

  Research finds that buying influence works

  Behavioral science confirms what we already know from experience: gifts are used to influence individuals and their decisions. In Reinvent Albany’s 2023 report, Buying Influence Works, we reviewed literature in various fields: political science regarding campaign contributions, medical journals examining pharmaceutical companies’ influence over doctors, and lastly, studies (on studies) that find that industry-funded research is skewed. We have no reason to believe that behavior is any different regarding gifts of travel payments to public officials or city agencies.

  COIB exempts travel payments from gift rules through rule and opinion

  COIB is responsible for interpreting Chapter 68 of the City Charter, which contains the city’s Code of Ethics and standards for conflicts of interest. Nowhere in Chapter 68 are travel payments specifically discussed. Section 2604 defines prohibited interests and conduct, and Section 2607 provides that COIB has jurisdiction over complaints regarding lobbyist gifts, which are prohibited under Section 3-255 of the Administrative Code.

  Section 2604(b)(5) of the City Charter specifically provides that gifts may not be accepted from those whom the public servant “knows is or intends to become engaged in business dealings with the city.”
  Section 3-255 of the Administrative Code states that “No person required to be listed on a statement of registration pursuant to section 3- 213(c)(1) of subchapter 2 of this chapter shall offer or give a gift to any public servant.”

  Interestingly, the only mention of travel in city law we could find regarding ethics is in Section 12-110 of the Administrative Code, the Annual Disclosure Law, which relates only to reporting.

  Given these prohibitions, travel payments fitting certain criteria have been excluded from these gift bans by COIB through Sections 1-01 and 1-16 of its rules:

  Section 1-01 excludes travel payments from the prohibitions of Sections 2604(b)(3) and (b)(5) of the City Charter, if:
  -the trip is for a City purpose and could properly be paid for by the City;
  -the travel arrangements are appropriate to that purpose;
  -the trip is no longer than reasonable to achieve the City purposes;
  -the public servant received agency head approval in advance; and
  -solicitation of the payment and reporting abides by Board Rules § 1-14.

  Section 1-16 provides an exclusion to the lobbyist gift ban, provided that the travel expenses are paid as a gift to the City, rather than the public servant, so long as it meets the same first three conditions of Section 1-01 above.

  COIB must reverse course and ban third-party travel payments – in particular from lobbyists and those who do business with NYC

  Because COIB has created the exclusion to the gift ban for travel payments by rule, we therefore believe you can undo it, and ban third-party travel payments. In particular, we see no reason that travel payments are allowed under any circumstance from those who do business with the City or are registered lobbyists, given the specific restrictions in Section 2604(b)(5) of the City Charter and Section 3-255 of the Administrative Code.

  Electeds’ financial disclosures show wide range of travel payments

  The total value of travel payments reported by officials has increased since 2020 and 2021, when travel was limited due to the COVID-19 pandemic (data from before 2020 is not published on the COIB website, so it is not included in our analysis). In 2024, there were at least $77,025 worth of travel payments, and $28,000 were reported in 2025. Donations totalled $214,625 from 2020 to 2025 for the disclosures published on COIB’s website.

  Minimum Value of Travel Payments Gifted to NYC Elected Official Financial, 2020-2025

  Includes either minimum value of range or exact amount, when provided.

  Table with 2 columns and 6 rows. Sorted ascending by column “Year” (column headers with buttons are sortable)
  Year Total Reported
  2020 $3,000
  2021 $1,000
  2022 $66,000
  2023 $39,600
  2024 $77,025
  2025 $28,000
  Table: Reinvent Albany Source: Summary of COIB Financial Disclosure Statements

  The list of the organizations providing travel payments below shows a wide range of interests. Reinvent Albany takes no position on the particular policy or political issues discussed or raised by these outside organizations during these trips. We do, however, question whether it is good public policy for city travel to be funded by outside groups. If the trip is truly related to the official duties of elected officials, we see no reason why they should not be paid for by taxpayers – and subject to the same transparency and public scrutiny as they are now.

  Minimum Value of Travel Payments Gifted by Organization, 2020-2025
  Includes either minimum value of range or exact amount, when provided.

  Table with 2 columns and 32 rows. Sorted ascending by column “Organization Name” (column headers with buttons are sortable)
  Organization Name Total Reported
  America-Israel Friendship League (AIFL) $1,000
  Assembly of the World Diasporas $15,000
  Association of Prosecuting Attorneys $1,000
  Attorneys General Alliance $5,000
  Climate Jobs Institute at Cornell University ILR School $20,000
  Combat Antisemitism Movement $1,000
  Community Leaders of America $4,000
  Concordia $1,000
  Consulate General of the Dominican Republic $1,000
  Council For American Ireland Relations $7,000
  Delta Air Lines $1,000
  European Janusz Korczak Academy $7,000
  Fair and Just Prosecution Organization $5,325
  Fondazione Fratelli Tutti $1,000
  Government of Colombia $1,000
  Jewish Community Relations Council $98,600
  Korean Prosecutor’s Bar Association $1,000
  LGBT Victory Institute Conference $1,000
  Local Progress (a project of the Center for Popular Democracy) $22,000
  Mobius Conference $1,000
  Municipality of Bat Yam, Israel $1,000
  New Deal Leaders $3,000
  North Capital Forum $1,000
  Northwestern University $2,000
  Queens Economic Development Corporation $1,700
  Regional Planning Association $2,000
  RFK Human Rights $3,000
  SEAP–Tides $1,000
  The Blue Card $1,000
  UJA-Federation of New York $1,000
  Uzbekistan Mission at the U.N. $1,000
  Zohran Mamdani Transition 2025 $2,000
  Table: Reinvent Albany Source: Summary of Conflicts of Interest Board Financial Disclosure Statements

  Disclosures of gifts to the City show even more travel payments

  As COIB noted in the proposed rules change, city agencies must report annually by February 28th, “the name of any individual or firm that made one or more donations totaling $5,000 or more to the agency during the previous calendar year, the total amount of these donations, and whether the donation was cash or an in-kind donation,” (Board Rules § 1-14(c)(1)). COIB makes these reports available on its website in XLS format, and also publishes these reports as open data.

  COIB also stated that “agencies’ reports are not required to include details about underlying travel paid for by third parties, and it is not apparent from the text of the rule that it applies to unsolicited gifts of travel related expenses.” Despite the lack of clarity, agencies have provided some details to COIB in these disclosures that explain the purpose of gifts, and in some cases explicitly say they are for travel expenses.

  Reinvent Albany reviewed agencies’ disclosures from 2019-2025 and tallied possible travel payments in three separate categories: in-kind donations from transportation companies ($104k); gifts explicitly labeled as payments for travel expenses ($232k); and payments made for conferences where travel may be a part of the donation ($248k). All payments in these categories totalled $585k from 2019-2025.

  Not included in this analysis are donations made to the city from other government agencies. We also note that while our categories may capture gifts that are not travel payments – for example if a transportation company’s in-kind donation was for something other than travel – overall this analysis is likely an undercount given the lack of clarity in the current rules.

  Below is a listing of the total amount of donations to city agencies in these categories by year. Following that is a list of all donors providing these gifts. Thank you again for the opportunity to provide testimony.

  See attached PDF for all tables.

  Comment attachment
  Reinvent-Albany-Testimony-on-Proposed-COIB-Rules-on-Travel-Payments-June-23-2026.pdf

  Comment added June 23, 2026 10:42am

• Zack Viera

  Good morning, and members of the Board. My name is Zack Viera. I’ve lived in New York City for seven years, and I plan to spend the rest of my life here. This city has given me a great deal — professionally, intellectually, and personally. The people I’ve met here are people I intend to keep in my life, and the relationships I value most are ones where we hold each other to a high standard — where honesty isn’t optional and accountability runs both ways. I hold the institutions of this city to the same standard.
  That’s why I’m here today in support of the Board’s proposed amendments to its rules regarding the reporting of donations and gifts to the City, including travel-related expenses.
  At its core, this proposal is about transparency — and I believe the case for it is straightforward. The current reporting threshold of $5,000 is too high. There is a meaningful amount of third-party-funded travel happening between $1,000 and $5,000 that the public currently has no visibility into. Lowering the threshold to $1,000 — consistent, as the Board notes, with the existing Annual Disclosure Law — is a common-sense correction. I don’t see a compelling reason to maintain the gap, and I think the public interest clearly favors closing it.
  But I want to spend a moment on what I find most exciting about this proposal, which is the detail level of the new disclosure requirements. Under proposed Section 1-19, agencies would be required to report not just the donor and the dollar amount, but who traveled, where, when, and for what purpose. That shift matters enormously. We are living in a moment where the tools available to analyze and summarize large amounts of public data are more powerful than they have ever been. More granular disclosure creates a living public record that journalists, researchers, advocates, and ordinary New Yorkers can actually use. The Board itself acknowledges it currently lacks basic information about how frequently third-party travel is accepted and for what purposes. Detailed disclosure is how we fix that — for both the public and the Board’s own capacity to govern this area well in the future.
  I also want to name the structural risk that this proposal addresses. The current system places approval authority entirely at the agency level, with no reporting back to the Board or the public. That is precisely the kind of opacity that creates conditions for abuse. In my own life, I’ve found that the people and institutions I trust most are the ones willing to be seen clearly — not just when it’s convenient. Transparency is not a guarantee against misconduct, but it is the minimum necessary condition for accountability. The days of officials quietly jetting off on someone else’s dime, with no public record, should be behind us. The people of this city deserve to know, in specific terms, who is paying for their public servants to travel, and why.
  The best relationships I have — personal and civic — are the ones where nothing is hidden. I’m here today because I want that same standard for my city. I am grateful to the Board for taking this up, and I commend the staff for the thoroughness of this rulemaking process. Members of the Board, thank you for your time and for your continued commitment to the integrity of New York City government.

  Comment attachment
  6_22-COIB-Testimony.pdf

  Comment added June 23, 2026 11:47am