COELIG Ensures Accuracy in Data Reporting Through Compliance and ...

The Commission on Ethics and Lobbying in Government’s focus on increasing compliance and transparency, and ensuring full and accurate data reporting resulted in resolving 99.5%, or $17.97 million, out of $18.1 million in lobbying filing discrepancies, in 2024, Executive Director Sanford Berland announced today. Final data on lobbying activity shows that for the third consecutive year, spending to influence government decision making in New York rose to a record high, totaling more than $382.1 million in 2024, a 5.97% increase over last year, 15.26% over 2022 spending, and 30.48% - nearly $90 million - over the 2021 figure of $292.9 million.
 

The Commission’s 2024 Annual Report also reports that the Investigations and Enforcement Unit processed 169 complaints and referrals, opened 24 formal investigations, and closed 139 open or pending matters in 2024, and, between January 1, 2024 and April 30 of this year, secured a total of $347,500 in settlement payments and penalties in nine enforcement matters. In addition, more than 209,500 state officers and employees completed ethics training last year.
 

“The Commission prioritizes data integrity and strives to ensure that statewide ethics and lobbying activity is fully and accurately reported,” Executive Director Berland said. “Working with lobbyists and clients, nearly $18 million in reporting discrepancies were resolved, providing the public with more transparent and accurate lobbying data.”
 

“In another record year for lobbying spending, an increasingly higher volume of lobbying filings and inquiries, the busiest year yet for ethics training, and nearly 170 matters processed by investigations and enforcement, 2024 was an active year for the Commission,” Chair Seymour W. James, Jr. said. “The Annual Report puts into black and white the vital work being done each day by Commission staff.”
 

Lobbying Compliance Efforts

The record-breaking $382.1 million reported for 2024 follows Commission staff’s reconciliation of discrepancies, initially totaling over $18.1 million, between the compensation reported in 2024 by lobbyists and the amounts reported by their clients. By working with lobbyists and clients, Commission staff succeeded in resolving 99.5%, or $17.97 million, in filing disparities and errors that were impeding full and accurate disclosure of lobbying expenditure data.  In addition, staff identified eight unregistered lobbyists for a total of $3.8 million in compensation and expenses that would otherwise have gone unreported. These parties are also subject to late filing fee assessments.

Table: Top 10 Largest Discrepancies in 2024 Lobbyist and Client Reported Compensation

The Commission conducts a Random Audit Program that provides an independently selected and objective audit of reports and registration statements filed by lobbyists and their clients. The random selection of audits is made by an outside consulting firm, and a second outside consulting firm certifies that the Commission’s Random Audit Program complies with the requirements of the Lobbying Act.
 

In 2024, audit staff conducted 862 audits of lobbying registrations, disclosures, and reports covering a three-year period, generating 959 findings and recommendations affecting 326 lobbying filings, or 37.8% of audited filings. Findings and recommendations were issued to improve filing and recordkeeping procedures or to require the filing of amended reports correcting discrepancies discovered in the audit process, or both.
 

Examples of corrected filings in 2024 include:

• $140,138 in lobbying expense discrepancies found at a large university. In a January-June 2022 Client Semi-Annual Report, a reporting discrepancy of $137,446 was found between the amount of employee lobbyist compensation reported ($171,705) and the amount supported by audit documentation ($34,259). In a July-December 2022 Client Semi-Annual Report: a reporting discrepancy of $2,692 was found between the amount of employee lobbyist compensation reported ($33,000) and the amount supported by source documentation ($30,371).
• $45,000 in unreported lobbying compensation found at cannabis company. The client did not submit a January-June 2024 Client Semi-Annual Report.  The lobbyist reported compensation of $15,000 per bi-monthly period on their January-February 2024 through May-June 2024 Bi-monthly Reports. Audit documentation obtained for this audit supported $45,000 in reportable compensation for the January-June 2024 period.
• $30,000 in unreported lobbying compensation found at a real estate development firm. In a January-June 2021 Client Semi-Annual Report, a reporting discrepancy of $15,000 was found between the amount of retained lobbyist compensation reported ($15,000) and the amount supported by audit documentation ($30,000). In a July-December 2021 Client Semi-Annual Report: a reporting discrepancy of $15,000 was found between the amount of retained lobbyist compensation reported ($15,000) and the amount supported by source documentation ($30,000).
   

Investigations and Enforcement Activities

Investigations staff processed 169 tips, complaints, referrals, and reports in 2024. The Commission closed 139 matters, of which 26 were continued matters carried over from the Joint Commission on Public Ethics (JCOPE). The Commission resolved six matters by settlement in 2024 and three additional matters so far in 2025, for total payments and penalties of $347,500 in nine settlements.
 

In general, allegations covered a broad range of potential violations of the Public Officers Law, including conflicts of interest, misuse of state resources and authority, improper gifts, nepotism, post-employment restrictions, and other issues. In addition, some matters involved alleged violations of the Lobbying Act, including failure to register as a lobbyist and failure to submit required or accurate and complete filings, and the so-called “Little Hatch Act,” Section 107 of the Civil Service Law.
 

In 2024, COELIG opened 24 investigations and issued notices of allegation, referred to as “15-day letters,” to the affected subjects. To date in 2025, the Commission has opened seven additional investigations. As of April 30, 2025, COELIG had 207 open and 52 pending investigations.
 

To the extent permitted by law, information concerning the Commission’s enforcement actions is published on the Commission’s enforcement website as well as on its pressroom website.
 

Unprecedented Demand for Lobbying and Ethics Guidance

The Commission regularly provides advice, guidance, and assistance to state officers, employees, lobbyists, and clients concerning New York’s ethics and lobbying laws. Commission staff generated or responded to almost 40,000 lobbying-related inquiries and processed nearly 78,000 lobbying filings in 2024. 

Table: Lobbying Inquiries and Filings

In addition, staff provided ethics advice and guidance in response to more than 1,300 requests, a 60% increase over 2023. The most frequent inquiry topics included engaging in outside activities at 35.3%. Others included post-employment restrictions at 21.8%, conflicts of interest at 12.9%, and gifts at 8.1%, 

Financial Disclosure Statement Compliance

The Commission pursues compliance with the financial disclosure statement (FDS) requirement in accordance with the Executive Law and the Public Officers Law. COELIG issued approximately 7,300 confidential failure-to-file notices in 2024 to individuals who did not timely file their FDS. Through significant outreach efforts by Commission staff and cooperation by individual agencies, the Commission secured nearly 97% compliance among these late filers by the end of 2024 and over 99.8% compliance to date. 

If an individual does not resolve a failure to file, the Commission publicly issues a notice of delinquency, which is published on the Commission’s website and sent to the individual’s appointing authority. If the filer still does not comply, the Commission may then pursue an enforcement action against the individual with civil penalties of up to $40,000.
 

Education and Training
In 2024, the Commission continued to build on the foundation it established to support the 30-fold increase in the number of employees required to undergo ethics training every year under the Ethics Commission Reform Act of 2022 (ECRA), enhancing the suite of education and training resources available to state employees, agency ethics officers, and trainers, and monitoring training completions at both the agency and the individual level.
 

From January 1, 2024, through May 1, 2025, more than 209,500 employees completed on-demand or live ethics training. Among the nearly 18,000 employees who attended a COELIG-led live Comprehensive Ethics Training Course (CETC) to date, 87% of those who completed a course evaluation said they are satisfied or highly satisfied with the training program. Also in 2024, 28 SUNY and CUNY agencies participated in specialized COELIG-led live CETC sessions, resulting in the training of more than 6,000 employees.
 

Final Data Confirms Another Record Year for Lobbying Spending

Final data for total lobbying spending in 2024 once again eclipsed all previous records at more than $382.1 million, representing a 5.97% increase over the $360.6 million reported in 2023.  The Commission released preliminary lobbying data in April.

1199SEIU Labor Management Initiatives, Inc. Healthcare Education Project once again was the year’s top spender, reporting $11.48 million in lobbying compensation and expenses in 2024. A newcomer to the Top 10 client spender’s category, the Alliance to Protect Home Care, Inc. placed second this year, with $10.6 million in lobbying spending. The gaming industry moved into this year’s top 10, with Genting New York LLC ranking third on the list.

To focus a timely spotlight on efforts to influence government decision making, the Commission now releases clear and concise compilations of bi-monthly lobbying report data every two months. The first installment, released on April 22, 2025, showed that more than $65 million was spent on lobbying in January and February 2025. The frequent release of this data will help the public gain a better understanding of how lobbying activity correlates with the work of state government and how it fluctuates over the course of the legislative session and the year, fluctuations that the yearly aggregate numbers in the annual report do not reflect.

About the New York State Commission on Ethics and Lobbying in Government 

Established by the 2022 Ethics Commission Reform Act (ECRA) and made effective in July 2022, the Commission’s charge is to foster public trust in government by ensuring compliance with the state’s ethics and lobbying laws and regulations. It has jurisdiction over more than 330,000 officers and employees at state agencies and departments, including commissions, boards, state public benefit corporations, public authorities, SUNY, CUNY, and the statutory closely affiliated corporations; the four statewide elected officials and candidates for those offices; employees and members of the state Legislature and legislative candidates; and state and local lobbyists and their clients.     
 

The Commission administers, enforces, and interprets New York’s ethics and lobbying laws by providing information, education, and guidance regarding ethics and lobbying laws; promoting compliance through audits, investigations, and enforcement proceedings; issuing formal and informal advisory opinions; and promulgating regulations implementing the laws under its jurisdiction.    
 

The Commission promotes transparency by conducting its proceedings publicly to the fullest extent permitted by law and by making the financial and other disclosures filed by those subject to the Commission’s authority publicly available. These disclosures include, but are not limited to, annual financial disclosure statements filed by over 30,000 individuals, and millions of records contained in registrations and activity and expense reports filed by lobbyists and their clients.