October 24 2017 NYS Lobbying Disclosure Report PDF

New York State Lobbying Disclosure:
Landmark Reforms Diminished by Antiquated Technology
October 24, 2017
I. Executive Summary
New York State has undergone significant changes to its lobbying laws under the Cuomo
Administration, requiring more reporting of lobbying activity and the funding and
relationships related to lobbying activity.
The changes to New York States lobbying laws under the Cuomo Administration began
with the 2011 Public Integrity Reform Act (PIRA), which was followed by subsequent
legislation and rulemaking.1
The significant statutory changes to the states Lobbying Laws include the following
reforms, which are detailed in the Appendix of this report:
an expansion of the definition of lobbying
application of the lobbying laws to municipalities (including school districts) of
5,000 or more residents
greater transparency of sources of funding for lobbying activity
disclosure of relationships between lobbyists and state officials and employees
they do business with
disclosure of political consulting activity by lobbyists
While these changes have positioned New York as a national leader in disclosure and
transparency of lobbying activity in law, the changes in statute have not been as fully
realized in practice.
Transparency achieved in statute has been diminished by a lack of uniformity and

standardization in reporting by lobbyists and clients, and antiquated lobbying disclosure
databases which do not facilitate either. When lobbyists and clients report their activity,
www.reinventalbany.org
OPEN, ACCOUNTABLE, EFFECTIVE GOVERNMENT
148 Lafayette, 12th Floor, New York, NY 10013
1
they are generally required to report who they lobbied; what subjects they lobbied on;
any corresponding numbers associated with bills, procurement, executive orders, or
rules or ratemaking; and the funds spent on lobbying activity. They may also have to
disclose any political consulting activity, sources of funding for lobbying activity, and
business relationships with state or elected officials. Lobbyists and clients report this
information in irregular and nonstandard ways, making it challenging for good
government groups, journalists or other third parties to do analyses across lobbyists,
lobbying subjects, or lobbying targets. It is very challenging to determine, for example,
which clients lobbied on a particular bill, how much money different clients spent
lobbying on the same bill, and which entities or individuals clients met with regarding a
bill. The current disclosures databases are better at revealing the lobbying activity of
individual clients or small groups of clients. However, in some instances, lobbying
activity reported by individual clients can be very general and unrevealing, lacking a
clear connection between who was lobbied and, on what matter, for particular
government determinations.
Reinvent Albany makes the following recommendation to JCOPE for the reporting and
displaying of lobbying activity so it is more transparent to the public:
1. Use technology to ensure data is entered in a standardized form by lobbyists and

clients. By offering restricted online web forms, drop down menus, or other tools
lobbyists and clients will enter persons lobbied, subjects lobbied, and bill
numbers using the same syntax.
2. Use technology to require lobbyists and clients to enter data so for each specific
governmental determination lobbied on, there is a clear connection between the
persons lobbied, the subject matter, and any bill or other numbers affiliated with
the subject.
3. Encourage reporting by lobbyists and clients of specific lawmakers, executive

agencies and specific entities lobbied, and require disclosure of individual
persons lobbied if permissible under current law.
4. Provide examples of best practices in reporting to compliance officers and

include it as part of training programs.
5. Examine data reported to ensure its integrity and conformance with the law, and
check in with lobbyists and clients to ensure reporting accurately reflects current
2
lobbying activity. Reinvent Albany observed filings which revealed the following:
a. Thousands of filings for which there was no reported lobbying activity for
lobbying subjects, bill details, and/or lobbying targets. JCOPE should
require No Activity or Not Applicable designations be actively reported
to discern between periods of no activity or inapplicable reporting
requirements and data fields left blank.
b. Some semi-annual filings were identical year after year for the same client,
even for large sets of reported bill numbers.
c. Bill numbers sometimes reflected a portfolio of issues which were
extremely broad for the reported client raising questions about the
accuracy of the reporting.
d. Subjects reported did not match subjects covered by bill numbers.
e. Subjects reported appeared to have corresponding bill numbers, but bill
numbers were not reported.
6. Make reportable business relationships and sources of income disclosures

available in a downloadable, machine-readable format ideally integrated with
current open data documents already provided by JCOPE for client and lobbyist
registration and periodic filings rather than the static PDFs they are currently
viewable in. This should also be done for financial disclosure forms submitted by
elected officials.
7. Place all datasets in the states Open Data portal and allow for instantaneous
updates through automation of datasets.
II. Challenges with Reporting and Transparency of Lobbying Activity
A. Burdensome Reporting Requirements
With the many new reporting requirements for filers at the state level because of
changes to the law, the process needs to be made simpler and more efficient. Lobbyists
reporting lobbying activity to the New York State Joint Commission on Public Ethics
(JCOPE) who also lobby New York City must also report again their New York City
lobbying activity to the New York City Clerks Office through its online database. The
State and City databases do not communicate with each other and so the same
information has to be manually entered in both databases. The 2011 New York City
Lobbying Commission explored dual reporting to make the filing process more efficient
for filers, and held a hearing on the matter with JCOPE testifying. No resolution was
3
achieved in part due to insurmountable technological challenges along with somewhat
differing reporting requirements between the city and state.
B. Shortcomings of NYC and NYS Lobbying Databases
Although lobbyists and clients enter information about their lobbying activity in city and
state databases for reporting, it is not collected or presented to the public in a manner
that provides for broad, in-depth analysis across the lobbying industry. Current filings
can be revealing for individual lobbyists or clients but it is very challenging to do an
analysis across many lobbyists or clients, or by lobbying subjects, bills, procurement or
persons or entities targeted.
The city requires filers enter very specific information about their lobbying activity
including the subject matter; numbers associated with the bill, executive order,
procurement, rulemaking or ratemaking; and the names of individual people lobbied.
While the city collects those data points for each lobbying activity, its database only
discloses information on the statement of registration rather than the very detailed
periodically reported information (the City Clerks Office was charged with creating a
new database within two years of December 2013 when Local Law 29 was passed, but it
has long missed the statutory deadline). The states database discloses more of the
reported information about lobbying activity. The state, however, makes little to no
effort to ensure filers enter data which is uniform or standardized to promote
categorization of data entered. This makes analyses across subjects, bills and persons
lobbied nearly impossible. Furthermore, the state does not require a connection
between individual bills, subjects and persons lobbied. All subjects, targets, and bill or
procurement numbers are grouped together in reporting so it is not clear, for example,
that a client met with a particular lobbying target on a specific bill or subject.
C. General and Unstandardized Reporting of Lobbying Subjects
The chart on the next page shows the 30 most frequently reported lobbying subjects of
52,703 filings by clients to JCOPE between 2007 and October 17, 2016. The reported
subjects show a lack of uniformity and specificity in reporting.2
4
30 MOST FREQUENTLY REPORTED LOBBYING SUBJECTS
Rank General Subject Lobbied Number of
as Reported by Clients Semi-Annual Filings
1 NULL 5,867
2 BUDGET 336
3 FUNDING 234
4 NYC BUDGET 173
5 HEALTHCARE ISSUES 170
6 ECONOMIC DEVELOPMENT 169
7 REAL ESTATE ISSUES 154
8 EDUCATION 141
9 (blank) 131
10 HEALTH CARE ISSUES 95
11 PROCUREMENT ISSUES 84
12 TRANSPORTATION ISSUES 83
13 HARDWARE, SOFTWARE AND SERVICES 82
14 GENERAL CONTRACTING ISSUES 81
15 LABOR 81
16 APPLICATION FOR AMENDMENT OF THE 80

NEW YORK CITY ZONING RESOLUTION
17 ENERGY ISSUES 77
18 REAL ESTATE DEVELOPMENT 72
19 EDUCATION ISSUES 71
5
20 INSURANCE ISSUES 69
21 PROCUREMENT 67
22 FUNDING ISSUES 65
23 CIVIL SERVICE & PENSIONS 61
24 BUDGET ISSUES 59
25 TECHNOLOGY 59
26 REAL ESTATE 58
27 LABOR ISSUES 56
28 NEW YORK CITY BUDGET 55
29 BUDGET FUNDING 52
30 BUDGET, REGULATORY AND 52

LEGISLATIVE ISSUES PERTAINING TO
HEALTHCARE AND HOSPITALS
Looking at the chart above, the most commonly reported lobbying activity was Null or
no activity. Null, in addition to blank may reflect no lobbying activity during the
reporting period (many lobbyists monitor government matters for clients) or may
indicate a failure to report lobbying activity, a matter JCOPE should review more
closely.
Clients reported advocating on the budget in 336 filings, the most commonly reported
lobbying subject. However, the third, fourth, twenty second, twenty fourth, twenty
eighth, twenty ninth and thirtieth most frequently reported subjects lobbied also appear
to be related to the budget, (Funding (234 times reported); NYC Budget (173 times
reported); Funding Issues (65 times reported); Budget Issues (59 times reported);
New York City Budget (55 times reported); Budget Funding (52 times reported); and
Budget, Regulatory and Legislative Issues Pertaining to Healthcare and Hospitals (52
times reported). Similar redundancies occur in the reporting of other subjects
(healthcare issues and health care issues; real estate issues, real estate
development and real estate).
6
Looking beyond the 30 most frequently reported lobbying subjects, Reinvent Albany
tallied a stunning 5,132 different varieties of syntax and terms in reported lobbying
subjects using the word budget, and 3,115 unique reporting variations of lobbying
subjects using the word funding. This makes it virtually impossible to do a simple
tabulation of which lobbyists and clients lobbied on the state budget. The table below
shows the top 20 reported terms related to lobbying on the budget.
20 MOST FREQUENTLY REPORTED BUDGET LOBBYING SUBJECTS

Rank General Subject Lobbied Number of Semi-
as Reported by Clients Including the Annual Filings
Word Budget
1 BUDGET 336
2 NYC BUDGET 173
3 BUDGET ISSUES 59
4 NEW YORK CITY BUDGET 55
5 BUDGET FUNDING 52
6 BUDGET, REGULATORY AND

HEALTHCARE AND HOSPITALS 52
7 BUDGET, LEGISLATIVE, AND

REGULATORY ISSUES PERTAINING TO
HEALTH CARE, HOSPITALS, NURSING
HOMES, HOME CARE, AND OTHER
HEALTH CARE PROVIDERS. 43

ADULT CARE 42
9 BUDGET, REGULATORY & EGISLATIVE

ISSUES PERTAINING TO HEALTHCARE &
HOSPITALS* 31
7
10 CAPITAL BUDGET 29
11 HEALTH AND BUDGET ISSUES 28
12 BUDGET, REGUL. & LEGIS. ISSUES

IMPACTING INSTITUTIONS OF HIGHER
EDUC., INCLUDING FIRE SAFETY,
NURSING INITITIATIVES, ZONING AND
LAND USE* 27
13 BUDGET, REGULATORY & LEGISLATIVE

ISSUES PERTAINING TO HOTELS & THE
TOURISM INDUSTRY 26
14 STATE BUDGET 26
15 BUDGET & HEALTH CARE ISSUES 22

THE HEALTHCARE INDUSTRY &
HOSPITALS 22
17 BUDGET BILLS AND OTHER BILLS TO

PROMOTE THE EXPANSION OF
NYSERNET, INC. 19
18 BUDGET, EMPLOYEE BENEFITS AND,

CIVIL SERVICE, PENSIONS, STATE,
CONDITIONS 19

UNIVERSITY BOOKSTORES 19
20 CERTIFIED CAPITAL COMPANY LEGIS.,

NYS BUDGET 19
*= lobbying subjects are as reported by clients, including misspellings and abbreviations
8
D. Irregular Reporting of Bill Details & Numbers
It is important to note that in addition to reporting lobbying subjects, clients are also
required to report numbers identifying bills, executive orders, rules, regulations,
ratemaking or municipal resolutions or ordinances, along with identifying numbers and
titles for procurement contracts.3 Identifying numbers shed further light on the general
subjects reported even when general subjects are general or vague and can be very
helpful in determining the lobbying activity of one or a few clients. However, when bill
and other numbers are reported, it requires they be looked up in separate databases.
This requires time consuming research and is only helpful in evaluating the filings of
one or a few clients rather than doing a broader analysis.
While bill and other identifying numbers can complement reported lobbying subjects to
illuminate lobbying activity, many lobbying activities do not have numbers associated
with them. As shown on the chart on the next page, at least 48 percent of client
semi-annual reports - 25,414 of 52,703 filings - do not include any bill details (null,
N/A, None, or (blank)) which, when coupled with a generally reported lobbying
subject, is not very revealing. Unreported bill numbers may simply reflect a
governmental determination being lobbied on is not a legislative matter or it may also
reflect underreporting. Confusingly, the most common information reported in the bill
details #1 category of client filings intended for receipt of bill numbers are all words
rather than numbers. Five of the top 10 reported bill numbers are budget-related for
which there ought to be bill numbers reported albeit some lobbying on the budget may
take place before bill numbers are assigned. It is also not uncommon for clients to
report lobbying subjects in the bill details category for reporting or report bill details in
the lobbying subject category in their filings, further adding to the confusion and
making broad analyses challenging.
10 MOST FREQUENTLY REPORTED BILL DETAILS

Rank Bill Details Lobbied Number of Semi-
as Reported by Clients Annual Filings
1 NULL 24,943
2 BUDGET 328
3 (blank) 236
4 N/A 159
9
5 NYC ZONING RESOLUTION 78
6 NONE 76
7 BUDGET BILLS 68
8 NYS BUDGET 31
9 NYC BUDGET 30
10 BUDGET BILL 26
For the top bill numbers reported in the bill details #1 category of lobbying filings,
there is no standardization of formatting in how bills are reported, as shown on the
chart below. Bills are reported in large groups for individual clients separated by spaces,
slashes, or semicolons or other configurations making it nearly impossible to determine
different clients who lobbied on the same bill or which persons individual clients lobbied
on a specific bill. Furthermore, some of the filings seem completely implausible with
countless bills lobbied on by the same client year after year even while the bill numbers
change when bills are reintroduced each new legislative session.
10 MOST FREQUENTLY REPORTED BILL NUMBERS

(OR SETS OF BILL NUMBERS) REPORTED IN BILL DETAILS
Rank Bill Details Lobbied on Number of
as Reported by Clients Semi-Annual Filings
(Groups of bills represent
one client filing)
1 A6000/A6003/A6004/A6007/S4200/S420 21
3/S4204/S4207
2 S50 S51 S52 S53 S54 S55 S56 S57 S58 S59 20
S60 S182 S249 S250 S1802 A150 A151 A152
A153 A154 A155 A156 A157 A158 A159 A160
A161 A162 A163 A4919
3 A5218/S2862 18
4 A21 A28 A29 A40 A42 A43 A50 A53 A54 A60 16
A63 A68 A71 A72A A85 A99 A104 A112 A115
A116 A144 A186 A195 A201 A208 A214 A223
10
A241 A243 A244 A246 A268 A271 A304
A310 A314 A315 A321 A325 A353 A363A
A364 A372 A376 A410 A411 A416 A464 A466
A470 A498 A516 A521 A534 A536 A550 A574
A575 A579 A590 A594 A640 A644 A646
A647 A654 A655 A670 A679 A696 A708
A719 A725 A732 A784 A804 A838 A853
A877 A888 A901 A921 A931 A935 A937 A955
A980 A1043 A1045 A1070 A1082 A1087
A1088 A1089 A1098 A1107 A1108 A1109
A1113 A1123 A1178 A1186 A1228 A1244
A1267 A1268 A1271 A1272 A1274 A1280
A1284 A1293 A1320 A1321 A1328 A1329
A1332 A1334 A1339 A1370A A1376 A1378
A1391 A1393 A1395 A1414 A1416 A1422
A1430A A1434 A1439 A1443 A1444 A1452
A1472 A1481 A1503 A1519 A1527 A1537
A1543 A1545 A1549 A1550 A1568 A1569
A1584 A1600 A1601 A1611 A1635 A1651
A1652 A1653 A1667 A1718 A1723 A1733
A1734 A1735 A1745 A1747 A1750 A1753
A1755 A1762 A1779 A1780 A1790 A1817
A1818 A1834 A1837 A1855 A1869 A1880
A1883 A1890 A1891 A1900 A1916 A1929
A1930 A1933 A1939 A1952 A1955 A1962
A1965 A1973A A1998 A1999 A2000 A2007
A2012 A2013 A2024 A2051 A2055 A2061
A2075 A2113 A2115 A2121 A2129 A2130
A2132 A2133 A2137 A2138 A2139 A2140
A2154A A2155 A2157 A2170 A2179 A2199
A2201 A2203 A2210 A2221 A2222 A2227
A2248 A2251 A2270 A2279 A2280 A2282
A2283 A2284 A2292 A2293 A2295 A2308
A2314 A2319 A2328 A2330 A2335 A2338
A2340 A2352 A2353 A2354 A2358 A2384A
A2387 A2389 A2400 A2417 A2418 A2419
A2427 A2429 A2431 A2432 A2433 A2436
A2445 A2455 A2457 A2466 A2468 A2471
A2495 A2496 A2498 A2527 A2532 A2536
A2538 A2554 A2567 A2586 A2588 A2629
A2654 A2664 A2668 A2681 A2683 A2691
A2693 A2716 A2717 A2718 A2721 A2725
A2728 A2729 A2743 A2746 A2757 A2764
11
A2769 A2771 A2792 A2798 A2800 A2805
A2806 A2807 A2812 A2816 A2820 A2831
A2834 A2835 A2837 A2838 A2843 A2848
A2859 A2861 A2865 A2868 A2875 A2878
A2891 A2896 A2909 A2917 A2929 A2945
A2947 A2954 A2957 A2969 A2973 A2983
A2985 A2988 A2989 A2990 A2996 A3001
A3003 A3006 A3007 A3015 A3017 A3023
A3025 A3040 A3041 A3046 A3047 A3049
A3056 A3061 A3071 A3073 A3075 A3078
A3084 A3094 A3102 A3106 A3112 A3114
A3115 A3120 A3121 A3122 A3123 A3124
A3127 A3130 A3133 A3137 A3145 A3147
A3149 A3162 A3163 A3164 A3169 A3176
A3177 A3182 A3191 A3199 A3201 A3206
A3213 A3217 A3248 A3251 A3252 A3258
A3259 A3262 A3263 A3271 A3287 A3325
A3333 A3345 A3351 A3364 A3367 A3377
A3402 A3406 A3407 A3429 A3437 A3447
A3460 A3461 A3469 A3483 A3485 A3492
A3497 A3498 A3499 A3501 A3510 A3518
A3521 A3524 A3540 A3560 A3566 A3569
A3575 A3578 A3582 A3585 A3589 A3592
A3624 A3640 A3641 A3642 A3643 A3644
A3654 A3662 A3665 A3675 A3680 A3682
A3683 A3684 A3687 A3688 A3689 A3690
A3694 A3695 A3698 A3700 A3710 A3711
A3713 A3715 A3717 A3718 A3719 A3720
A3734 A3736 A3741 A3746 A3757 A3763
A3764 A3770 A3771 A3772 A3773 A3778
A3793 A3797 A3801 A3805 A3806 A3813
A3819 A3829 A3849 A3850 A3854 A3855
A3856 A3874 A3875 A3880 A3888 A3897A
A3902 A3904 A3906 A3914 A3917 A3931
A3934 A3939 A3943 A3944 A3956 A3965
A3966 A3977 A3979 A3980A A3982 A4000B
A4001 A4002 A4003B A4004A A4005
A4006 A4007A A4008A A4009B A4010A
A4011A A4012A A4013 A4022 A4023 A4024
A4044 A4049 A4051 A4064 A4080 A4081
A4084 A4090 A4110 A4144 A4145 A4148
A4158 A4163 A4185 A4186 A4204 A4241
A4254 A4257 A4259 A4274 A4278 A4281
12
A4282 A4283 A4291 A4293 A4296 A4322
A4326 A4356 A4359 A4383 A4389 A4394
A4395 A4396 A4399 A4410 A4415 A4428
A4430 A4441 A4443 A4445 A4447 A4448
A4449 A4451 A4462 A4466 A4469 A4472
A4476 A4479 A4500 A4517 A4519 A4532
A4534 A4535 A4536 A4537 A4565 A4567
A4568 A4569 A4572 A4577 A4579 A4580
A4583 A4586 A4591 A4616 A4624 A4628
A4634 A4635 A4661 A4666 A4675 A4684
A4685 A4691 A4702 A4713 A4726 A4728
A4745 A4752 A4760 A4765 A4766 A4770
A4778 A4780 A4782 A4832 A4908 A4917
A4919 A4920 A4955 A4956 A4957 A4969
A4975 A4997 A5039 A5053 A5057 A5081
A5086 A5087 A5088 A5090 A5093 A5123
A5141 A5214 A5222 A5283 A5296 A5368
A5369 A5401 A5463 A5507 A5528 A5529
A5581 A5596 A5612 A5650 A5680 A5709
A5711 S44 S53 S54 S59 S66 S71 S78 S88 S89
S95 S97 S101 S105 S111 S118 S119 S122 S137
S140
5 A23 A24 A30 A40 A67 A70 A92 A93 A94 16

A103 A108 A117 A121 A126 A130 A135
A137 A161 A182 A198 A202 A207 A209
A266 A268 A297 A330 A395 A397 A402
A416 A426 A515 A518 A631 A635 A656
A657 A661A A663 A666 A723 A757 A759
A766 A767 A771 A782 A790 A792 A800
A812 A831 A872 A878 A935 A963 A968
A1009 A1015 A1019 A1035 A1036 A1049
A1050 A1057 A1070 A1078 A1115 A1151
A1154 A1163 A1178 A1191 A1220 A1240
A1272 A1274 A1279 A1281 A1286 A1296
A1321 A1351 A1353 A1384 A1401 A1428
A1480 A1504 A1505 A1515 A1527 A1561
A1591 A1625 A1640 A1666 A1670 A1679
A1700 A1721 A1726 A1747 A1773 A1815
A1824 A1837 A1841 A1842 A1846 A1883
A1885 A1910 A1929 A1946 A1967 A1974
A1975 A1982 A2005 A2006 A2032 A2038
A2081 A2085 A2098 A2121 A2128 A2138
13
A2150 A2159 A2168 A2216 A2239 A2247
A2266 A2280 A2289 A2293 A2313
A2336A A2359 A2397 A2402 A2417A
A2471 A2479 A2508 A2553 A2558 A2591
A2611 A2648 A2653 A2675 A2687 A2705
A2714 A2728 A2744 A2746 A2765 A2771
A2783 A2812 A2822 A2824 A2836 A2845
A2849 A2853 A2866 A2914 A2926 A2930
A2937 A2946 A2967 A2976 A2999
A3000C A3001 A3002 A3003C A3004C
A3005C A3006C A3007C A3008C
A3009C A3011 A3015 A3024 A3035
A3063 A3070 A3079 A3088 A3100 A3110
A3111 A3126 A3129 A3132 A3138 A3147
A3150 A3167 A3178 A3214 A3218 A3221
A3227 A3242 A3243 A3246 A3255 A3263
A3265 A3267 A3284 A3287 A3291 A3295
A3302 A3304B A3321 A3322 A3334
A3359 A3360 A3386 A3447 A3459 A3505
A3516 A3524 A3531 A3532 A3533 A3563
A3584 A3585 A3604 A3638 A3641 A3652
A3655 A3660 A3662 A3671 A3714 A3730
A3733 A3739 A3742 A3748 A3750 A3757
A3771 A3788 A3789 A3796 A3834 A3838
A3842 A3845 A3895 A3908 A3923 A3934
A3941 A3996 A4027 A4029 A4035
A4049A A4053 A4054 A4071 A4101
A4109 A4134 A4142 A4161 A4164 A4170
A4177 A4178 A4185 A4206 A4239 A4242
A4276 A4277 A4294 A4311 A4316 A4326
A4351 A4362 A4372 A4375 A4377 A4379
A4381 A4382 A4383 A4389 A4400 A4419
A4429 A4440 A4453 A4455 A4456 A4473
A4491 A4493 A4578 A4580 A4609 A4625
A4627 A4631 A4639 A4662 A4666 A4675
A4685 A4686 A4695 A4719 A4733 A4740
A4756 A4757 A4763 A4772A A4775 A4802
A4808 A4811 A4812 A4845 A4852 A4853
A4854 A4893 A4906 A4925 A4929 A4931
A4972 A5011 A5065 A5078 A5081 A5096
S20 S50 S80 S102 S104 S108 S122 S133
S175 S201 S209 S229 S237 S251 S256
S286 S419 S423 S433 S443 S446 S481
14
S488 S531 S539 S573 S578 S615 S657
S661 S671 S672 S697 S766 S781 S789
S793 S846 S859 S923 S925 S927 S944
S992 S993 S994 S1023 S1034 S1041
S1048 S1065 S1140 S1157 S1202 S1212
S1241 S1293 S1331 S1358 S1380 S1388
S1396 S1400 S1403 S1406 S1408 S1429
S1446 S1466 S1517 S1518 S1522 S1523
S1560 S1566 S1575 S1587 S1635 S1640
S1641 S1654 S1680 S1689 S1703 S1706
S1715 S1726 S1730 S1737 S1751 S1754
S1757 S1764 S1788 S1792 S1795 S1804
S1826 S1864 S1869 S1934 S1944 S1946
S1972 S1987 S1989 S1999 S2021 S2028
S2038 S2071 S2077 S2096 S2123 S2127
S2180 S2183 S2201 S2213 S2220 S2233
S2308 S2309 S2319 S2324 S2327 S2352
S2361 S2363 S2367 S2376 S2385 S2390
S2397 S2398 S2408 S2417 S2474 S2481
S2504 S2531 S2533 S2551 S2562 S2596
S2600C S2601 S2602 S2603C S2604C
S2605C S2606C S2607C S2608C S2609C
S2629 S2630 S2637 S2668 S2671 S2672
S2687 S2707 S2721 S2750 S2764 S2781
S2786 S2789 S2815 S2834 S2855 S2858
S2861 S2864 S2874 S2880 S2897 S2899
S2900 S2973 S2992 S2999 S3025 S3040
S3042 S3069A S3071 S3086 S3127 S3139
S3148 S3154 S3174 S3197 S3209 S3216
S3219 S3221 S3225 S3251 S3264 S3271
S3272 S3274 S3285 S3296 S3301 S3304
S3328 S3343 S3350 S3374 S3380 S3399
S3403 S3411 S3435A S3454 S3477 S3485
S3496 S3503 S3525 S355
6 A1266 A1568 A4971 A1570 A1824 A3069 15

A4837 A694A A7949A S1551 S1653 S1669
S1670 S3496A S4602A
7 A9804/S6804; A9807/S6807; NY SFY 15

2008-09 EXECUTIVE BUDGET
(S.2108/A.4308); 10 NYCRR; EMERGENCY
AND DISASTER PREPARDENSS SNF PPS;
15
NH P4P; ADULT DAY HEALTH CARE;
ENVIRONMENT OF CARE; COLOR CODED
WRISTBANDS; HC FACILITY
EVACUATION PLAN; S.3126/A.7076;
S.2108/A.4308; MANDATORY OVERTIME;
LONG TERM HOME HEALTH CARE
REFORM; 10 NYCRR-SECTION 702.7; 10
NYCRR - SECTION 400.21; SECTION 4432A
- BALANCED BUDGET ACT FO 97; CMS
1545-P; SNF RULE FOR 2008;
A10827/S8645 (CASE MIX INDEX),
A8390/S5230 (HOME HEALTH A&G CAP),
A11416/S8702 (LTHHCP), A10873/S7683
(MOLST), A3791 (STANDARDS OF CARE),
A4436 (PUBLICLY TRADED CORPS),
A11711/S8637 (MANDATORY OVERTIME);
LTHHCP; SFY 2009-10 BUDGET
PROPOSAL *
8 07-M-0548 14
9 A00240 A00410 A00445 A00563 A00587 14

A00701 A00708 A00842 A00847 A01071
A01977 A01990 A01997 A02089 A02297
A03603 A03604 A03605 A03840 A03967
A03985 A04246 A04249 A04257 A04807
A05604 A05955 A06363 A06722 A06725
A07017 A07301 A07359 A07424 A07572
A07742 A07839 S00300 S00358 S00612
S00666 S00690 S00839 S00848 S00851
S00961 S01110 S02418 S02421 S02474
S02488 S02764 S02894 S02945 S03136
S03375 S03666 S03783 S04279 S04330
S04787 S04789 S05375 S05427
10 A2565/S2664: 30% RENT CAP ON AIDS 14

HOUSING; A5710/S2406: GENDER
EXPRESSION NON-DISCRIMINATION
ACT (GENDA); S1570: ESTABLISHING A
DIVISION OF AIDS SERVICES FOR NYS;
S03293: HIV TESTING; S5620/A8396:
SYRINGE DECRIMINALIZATION ACT;
NEW YORK CITY BUDGET
MODIFICATION FOR HEALTH & HUMAN
16
SERVICES; NEW YORK STATE EXECUTIVE
BUDGET FOR HEALTH & HUMAN
SERVICES
*= bill numbers are as reported by clients, including misspellings and abbreviations
E. Vague Reporting of Persons Lobbied
Reporting of which clients lobbied can also be opaque even while technically in
compliance with state law which only requires the the name of the person,
organization, or legislative body before which the lobbyist has lobbied.4 The list of top
30 persons or governmental entities lobbied as reported in the primary person category
of the periodic reports reveals very little, with few clients even providing the state
agency lobbied let alone the names of individuals within government they lobbied and
for whom they work, as is required in filings submitted in New York City. 5 Most
lobbyists simply report they lobbied the legislative and executive branches with
countless variations in syntax. 6,200 filings did not report a lobbying target which may
reflect a period of No Activity, monitoring of issues, or underreporting. The endless
variations of syntax in reporting the houses of the legislature or the executive branch
make meaningful analyses of lobbying activity very challenging. It is difficult to broadly
review which elected officials, staff, or government agencies were lobbied on particular
issues by groups of lobbyists or clients.
30 MOST FREQUENTLY REPORTED LOBBYING TARGETS

Rank Persons or Organizations Lobbied Number of Semi-
as Reported by Clients Annual Filings
1 NULL 6,200
2 ADMINISTRATIVE, EXECUTIVE AND 1,226

LEGISLATIVE BRANCHES OF
GOVERNMENT
3 NEW YORK STATE EXECUTIVE AND 727

LEGISLATIVE BRANCHES
4 NYC COUNCIL 405
17
5 SENATE, ASSEMBLY, EXECUTIVE BRANCH 287
6 NYS ASSEMBLY, SENATE, EXECUTIVE 283

CHAMBER, EXECUTIVE BRANCH
7 ADMINISTRATIVE, EXECUTIVE & 275

GOVERNMENT
8 ASSEMBLY, SENATE, EXECUTIVE 274
9 SENATE, ASSEMBLY 262
10 SENATE, ASSEMBLY, EXECUTIVE 241

CHAMBER
11 NYS LEGISLATIVE AND EXECUTIVE 230

BRANCHES OF GOVERNMENT
12 SENATE, ASSEMBLY, GOVERNOR 221
13 SENATE, ASSEMBLY, GOVERNOR'S OFFICE 186
14 NYS ASSEMBLY, SENATE, EXECUTIVE & 168

STATE AGENCIES
15 SENATE, ASSEMBLY, EXECUTIVE 162
16 NYS SENATE/ASSEMBLY/EXECUTIVE 160

BRANCH
17 EXECUTIVE CHAMBER, NYS 142

SENATE/ASSEMBLY, VARIOUS STATE
AGENCIES/COMMITTEES
18 NEW YORK STATE EXECUTIVE & 140

LEGISLATIVE BRANCHES
18
19 SENATE, ASSEMBLY, EXECUTIVE. 140
20 NEW YORK STATE AND NEW YORK CITY 132

EXECUTIVE AND LEGISLATIVE
BRANCHES
21 SENATE, ASSEMBLY, EXECUTIVE. 140
22 NEW YORK STATE AND NEW YORK CITY 132

EXECUTIVE AND LEGISLATIVE
BRANCHES
23 (blank) 132
24 ADMINISTRATIVE, EXECUTIVE AND 118

LEGISLATIVE BRANCHES OF STATE AND
MUNICIPAL GOVERNMENT
25 EXECUTIVE CHAMBER, NYS 118

SENATE/ASSEMBLY, VARIOUS
COMMITTEES
26 NEW YORK STATE EXECUTIVE AND 114

GOVERNMENT
27 NYS SENATE, ASSEMBLY & EXECUTIVE 106

BRANCH
28 NEW YORK CITY COUNCIL 96
29 NYS ASSEMBLY, NYS SENATE 86
30 NYS SENATE/ASSEMBLY 85
III. Recommendations for Improved Transparency of Lobbying

Activity
The recent reforms to New York State Lobbying Laws could be made much more
meaningful in informing the public of how government decisions are made if the
19
databases used to collect and disclose lobbying activity were modernized utilizing the
latest technology. Reinvent Albany recommends JCOPE take the following actions to
enhance transparency of lobbying activity:
1. Use technology to ensure data is entered in a standardized form by lobbyists and

clients. By offering restricted online web forms, drop down menus, or other tools
lobbyists and clients will enter persons lobbied, subjects lobbied, and bill
numbers using the same syntax.
2. Use technology to require lobbyists and clients to enter data so for each
governmental determination lobbied on, there is a clear connection between the
persons lobbied, the subject matter, and any bill or other numbers affiliated with
the subject.
3. Encourage reporting by lobbyists and clients of specific lawmakers, executive

agencies and specific entities lobbied, and require disclosure of individual
persons lobbied if permissible under current law.
4. Provide examples of best practices in reporting to compliance officers and

include it as part of training programs.
5. Examine data reported to ensure its integrity and conformance with the law, and
check in with lobbyists and clients to ensure reporting accurately reflects
lobbying activity. Reinvent Albany observed filings which revealed the following:
a. Thousands of filings for which there was no reported lobbying activity for
lobbying subjects, bill details, and/or lobbying targets. JCOPE should
require No Activity or Not Applicable designations be reported to
discern between periods of no activity or inapplicable reporting
requirements and data fields left blank.
b. Some semi-annual filings were identical year after year for the same client,
even for large sets of reported bill numbers.
c. Bill numbers sometimes reflected a portfolio of issues which were
extremely broad for the reported client raising questions about the
accuracy of the reporting.
d. Subjects reported did not match subjects covered by bill numbers.
e. Subjects reported appeared to have corresponding bill numbers, but bill
numbers were not reported.
20
6. Make reportable business relationships and sources of income disclosures
available in a downloadable, machine-readable format ideally integrated with
current open data documents already provided by JCOPE for client and lobbyist
registration and periodic filings rather than the static PDFs they are currently
viewable in. This should also be done for financial disclosure forms submitted by
elected officials.
7. Place all datasets in the states Open Data portal and allow for instantaneous
updates through automation of datasets.
21
V. Appendix: Major Changes to the Lobbying Law During the Cuomo
Administration
A. Changes to the Definition of Lobbying and Reported Lobbying

Activity
Lobbying is generally defined as any attempt to influence governmental

decision-making and state law enumerates specific acts that constitute lobbying as well
as actions that do not constitute lobbying.6 Lobbying activities include attempts to
influence determinations related to legislation, resolutions, rules, regulations,
rate-making (establishing rates of payment), procurement contracts and tribal-state
agreements. Notable exempted activities are reporting by the media, professional
advice to clients evaluating government proposals, public hearings when invited,
adjudicatory proceedings, and certain circumscribed communications and aspects of the
procurement process.7
The state expanded its definitions of lobbying in PIRA to include advocacy before a bill
is introduced and defined advocacy on resolutions, both before and after introduction,
as lobbying activity. JCOPE in February 2016 issued Advisory Opinion 16-01 clarifying
what constitutes grassroots advocacy and when consultants doing grassroots advocacy
are lobbying.8 The Advisory Opinion clarified that grassroots advocacy constitutes
lobbying when a specific ask is made in reference to a government action covered by
the Lobbying Law, and the ask is made indirectly through the public or another third
party to a public official. The Opinion also clarified that consultants are lobbying when
they both shape the content of a communication making a request of government and
controls its delivery.9 The Opinion included as part of controlling the delivery of a
message communicating to Editorial Boards and the press a position on how
government should act on an issue. Chapter 286 of the Law of 2016 later exempted
communications with the press including editorial boards or writers.10
B. Sources of Funding for Lobbying Activity
The state has also established very robust disclosure requirements making known the
sources of funding for lobbying activity.
As a result of the passage of the PIRA11 and Chapter 286 of the Laws of 201612, the state
requires lobbyists who advocate on their own behalf and clients to report annually or for
22
the previous twelve months, all of the reportable contributions by their donors
contributing $2,500 or more to the lobbying entity if:
1. the lobbying entity spends a combined $15,000 during the period on combined
lobbying compensation or expenses; and
2. three percent of its overall expenditures are on lobbying in New York.13
Governmental entities are exempted from the disclosure of donors as are organizations
who can demonstrate to the Joint Commission on Public Ethics (JCOPE) that disclosure
would result in a substantial likelihood of harm, threats, harassment, or reprisals to a
donor or their property.
501(c)(3) organizations were exempted from disclosure under PIRA but Chapter 286 of
the Laws of 2016 requires 501(c)(3)s disclose their donors if making in-kind
contributions over $2,500 to 501(c)(4) organizations.14 This is currently the subject of a
lawsuit filed by Citizens Union and the American Civil Liberties Union (ACLU).
JCOPE promulgated rules related to sources of funding disclosure to lobbyists and
clients in relation to PIRA and amended those in September 2016 following the
enactment of Chapter 286 of the Laws of 2016.15 The rules lay out the exact information
that must be reported for Sources of Income and specify factors the Joint Commission
on Public Ethics (JCOPE) uses to determine if there is a substantial likelihood of harm,
threats, harassment or reprisals to unveiled donors. Four organizations to date have
had their donors exempted from disclosure under this provision.16
C. Reportable Business Relationships
In addition to disclosure of donors to lobbyists, PIRA also requires additional disclosure

regarding the relationships of lobbyists, namely with so-called State Persons. The
purpose of this new requirement is to ensure that any conflicts of interest are made
known.
PIRA specifically requires that lobbyists in their statement of registration and clients in
their semi-annual reports disclose reportable business relationships. A reportable
business relationship is defined in the Lobbying Law as:
a relationship in which compensation is paid by a lobbyist or by a client

of a lobbyist, in exchange for any goods, services or anything of value, the
total value of which is in excess of one thousand dollars annually, to be
23
performed or provided by or intended to be performed or provided by (i)
any statewide elected official, state officer, state employee, member of the
legislature or legislative employee, or (ii) any entity in which the lobbyist
or the client of a lobbyist knows or has reason to know the statewide elected
official, state officer, state employee, member of the legislature or legislative
employee is a proprietor, partner, director, officer or manager, or owns or
controls ten percent or more of the stock of such entity (or one percent in
the case of a corporation whose stock is regularly traded on an established
securities exchange).17
Lobbyists and clients are required to disclose for each reportable business relationship
the public office address of any statewide elected official, state officer, state employee,
member of the legislature or legislative employee (referred to in the guidelines as a
State Person) and entity in which any State Person has a substantial ownership stake
or is in a senior management position (referred to in the guidelines as the Requisite
Involvement). They are additionally required to disclose the general subjects of the
business transaction and the costs and compensation involved and the amount of each
that has been paid to date or is scheduled to be paid.
JCOPE issued guidelines to clarify the Reportable Business Relationships reporting

requirement in August of 2012.18 The guidelines are notable for exempting from the
definition of a Reportable Business Relationship transactions related to medical, mental
health or dental services in addition to legal services involving domestic relations or
bankruptcy matters. The guidelines also exempt from State Persons those who serve on
boards or commissions without compensation or who only earn per diems and public
benefit corporations and commissions that do not have any appointments from the
governor. The guidelines also exclude from the definition of compensation certain
goods and services consumer and business loans and lines of credit that are offered
at market rates to the general public. The guidelines also allow clients to fulfill the
reason to know standard of a reportable business relationship by, for example, issuing
a questionnaire to members of a board of a lobbying entity as to whether a relationship
exists.
Complementing the disclosure by lobbyists and clients of business relationships with

State Persons is the disclosure of relationships by public officers and state employees,
which is also required by the PIRA as part of the financial disclosure forms the policy
makers submit in May every year. PIRA required that public officers and state
employees report new customers and clients or new matters for existing customers and
24
clients in instances in which they refer the customer or client to the firm or corporation
of which they are part or personally provide services valued over $10,000 annually
connected with bills, resolutions, large contracts, grants and cases, proceedings, or
applications before a state agency that are not a ministerial matter.
D. Disclosure of Clients of Political Consultants and Public Relations

Firms Who Lobby
Chapter 286 of the Laws of 2016 requires political consultants to register with the
secretary of state, and disclose twice annually the elected officials or candidates they
provided political consulting services for, the clients they represent, and the nature of
the work for those clients. The Secretary of State posts the information within 30 days
of the end of the reporting period on its website. To date, the Secretary of State
promulgated rules, issued a FAQ, received the first six-month filing, and disclosed the
reported information in the states Open Data portal.19
E. Disclosure of Lobbying of Small Municipalities
In the 2015-2016 budget, changes were made to the Lobbying Law requiring the
disclosure of lobbying activity in relation to small municipalities with populations of
5,000 or more residents, from the previous threshold of 50,000 or more residents.
School districts were also included in an expansion of the covered localities.20 The
change in the threshold will result in more light being shed on local lobbying for
hundreds of political subdivisions and the application of the lobbyist gift ban to many
more lobbyists who now register as a result.
Body
1. See chapter 399 of the Laws of 2011. Available at:
http://open.nysenate.gov/legislation/bill/S5679-2011
2. As reported in the Lobbyist Subjects 1 category of periodic filings. A Lobbyist Subject 2 category also
exists but is utilized infrequently.
3. See 1-j(3) of Article 1-A of the Legislative Law
4. See 1-e(6), 1-h(4), 1-j(4) of Article 1-A of the Legislative Law
5. Only 78 periodic reports of 52,704 submitted by clients contained any information in the person 2
category indicating additional persons or organizations lobbied. Reinvent Albany therefore limited its
analysis to the person 1 category.
Appendix
6. For NYS Lobbying Laws, see Article 1-A of NYS Legislative Law at
http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=@SLLEG0A1-A
25
+&LIST=LAW+&BROWSER=BROWSER+&TOKEN=08818352+&TARGET=VIEW.
7. The definition of lobbying and exemptions from it for NYS are in section 1-c of Article 1-A of the NYS
Legislative Law. See:
http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=$$LEG1-C$$@
TXLEG01-C+&LIST=LAW+&BROWSER=BROWSER+&TOKEN=08818352+&TARGET=VIEW. The
definition of lobbying and exemptions from it for NYC are in section 3-211 of subchapter 2 of Chapter 2 of
Title 3 of the NYC Administrative Code. See
http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=$$ADC3-211$$
@TXADC03-211+&LIST=LAW+&BROWSER=BROWSER+&TOKEN=25967841+&TARGET=VIEW.
8. Advisory Opinion 16-01. See:
http://www.jcope.ny.gov/advice/jcope/2016/NYS%20Joint%20Commission%20on%20Public%20Ethics
%20Advisory%20Opinion%2016-01.pdf
9. This activity constitutes reportable lobbying when the threshold for expenditures and compensation is
additionally met.
10. See Part I, Chapter 286 of the Laws of 2016.
11. See section 1 of Part B of chapter 399 of the Laws of 2011. Available at:
12. See:
http://nyassembly.gov/leg/?default_fld=&leg_video=&bn=S08160&term=2015&Summary=Y&Actions=
Y&Committee%26nbspVotes=Y&Floor%26nbspVotes=Y&Memo=Y&Text=Y
13. The dollar value of membership dues, fees or assessments are not included as part of the reported
contributions (they are reported as $0 contributions) and only a fraction of the value of contributions are
reported for those contributions not specifically tagged for lobbying purposes. The fraction is equivalent
to the proportion of spending and compensation the organization spends on lobbying.
14. See Section 172-e of the NYS Executive Law and Paragraph 4 of subdivision (c) of section 1-h and 1-j of
the Legislative Law.
15. See Title 19 NYCRR Part 938 at http://www.jcope.ny.gov/about/ethc/19%20NYCRR%20938.pdf. An
FAQ is available here: http://www.jcope.ny.gov/source_funding/SOURCE%20FUNDING%20FAQ.pdf.
Reported funding sources for lobbyists and clients to date is available here:
http://www.jcope.ny.gov/source_funding/chart.html.
16. See Disclosures and Exemptions 2014-Present, JCOPE Website.
http://www.jcope.ny.gov/source_funding/chart.html
17. See section 8 of Part A chapter 399 of the Laws of 2011. Available at:
18. See JCOPE Reportable Business Relationship Guidelines,
http://www.jcope.ny.gov/about/lob/2013-03-21%20Revised%20RBR%20Guidelines%20--%20FINAL.p
df. An FAQ on Reportable Business Relationships is available here:
http://www.jcope.ny.gov/rbr/RBR%20FAQ.pdf
19. See: https://www.dos.ny.gov/licensing/pdfs/PoliticalConsultant.pdf;
https://data.ny.gov/Transparency/Political-Consultant-Filings-Beginning-2016/tekz-xrvb;
https://www.dos.ny.gov/licensing/politicalconsultant.html
20. See Expansion of New York States lobbying law enacted, Greenberg Traurig LLP. Available at:
http://www.lexology.com/library/detail.aspx?g=f9994833-de27-4aaa-b730-e1342a379cc0
26

October 24 2017 NYS Lobbying Disclosure Report PDF

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

October 24 2017 NYS Lobbying Disclosure Report PDF

Uploaded by

Copyright:

Available Formats

New York State Lobbying Disclosure:

Landmark Reforms Diminished by Antiquated Technology

October 24, 2017

Transparency achieved in statute has been diminished by a lack of uniformity and

1. Use technology to ensure data is entered in a standardized form by lobbyists and

3. Encourage reporting by lobbyists and clients of specific lawmakers, executive

4. Provide examples of best practices in reporting to compliance officers and

6. Make reportable business relationships and sources of income disclosures

II. Challenges with Reporting and Transparency of Lobbying Activity

A. Burdensome Reporting Requirements

B. Shortcomings of NYC and NYS Lobbying Databases

C. General and Unstandardized Reporting of Lobbying Subjects

4 NYC BUDGET 173

5 HEALTHCARE ISSUES 170

6 ECONOMIC DEVELOPMENT 169

7 REAL ESTATE ISSUES 154

10 HEALTH CARE ISSUES 95

13 HARDWARE, SOFTWARE AND SERVICES 82

14 GENERAL CONTRACTING ISSUES 81

16 APPLICATION FOR AMENDMENT OF THE 80

18 REAL ESTATE DEVELOPMENT 72

23 CIVIL SERVICE & PENSIONS 61

28 NEW YORK CITY BUDGET 55

30 BUDGET, REGULATORY AND 52

20 MOST FREQUENTLY REPORTED BUDGET LOBBYING SUBJECTS

2 NYC BUDGET 173

4 NEW YORK CITY BUDGET 55

6 BUDGET, REGULATORY AND

7 BUDGET, LEGISLATIVE, AND

8 BUDGET, REGULATORY AND

9 BUDGET, REGULATORY & EGISLATIVE

11 HEALTH AND BUDGET ISSUES 28

12 BUDGET, REGUL. & LEGIS. ISSUES

13 BUDGET, REGULATORY & LEGISLATIVE

15 BUDGET & HEALTH CARE ISSUES 22

16 BUDGET, REGULATORY AND

17 BUDGET BILLS AND OTHER BILLS TO

18 BUDGET, EMPLOYEE BENEFITS AND,

19 BUDGET, REGULATORY AND

20 CERTIFIED CAPITAL COMPANY LEGIS.,

10 MOST FREQUENTLY REPORTED BILL DETAILS

10 MOST FREQUENTLY REPORTED BILL NUMBERS

5 A23 A24 A30 A40 A67 A70 A92 A93 A94 16

6 A1266 A1568 A4971 A1570 A1824 A3069 15

7 A9804/S6804; A9807/S6807; NY SFY 15

9 A00240 A00410 A00445 A00563 A00587 14

10 A2565/S2664: 30% RENT CAP ON AIDS 14

E. Vague Reporting of Persons Lobbied

30 MOST FREQUENTLY REPORTED LOBBYING TARGETS

2 ADMINISTRATIVE, EXECUTIVE AND 1,226

3 NEW YORK STATE EXECUTIVE AND 727

4 NYC COUNCIL 405

6 NYS ASSEMBLY, SENATE, EXECUTIVE 283

7 ADMINISTRATIVE, EXECUTIVE & 275

8 ASSEMBLY, SENATE, EXECUTIVE 274

9 SENATE, ASSEMBLY 262

10 SENATE, ASSEMBLY, EXECUTIVE 241

11 NYS LEGISLATIVE AND EXECUTIVE 230

12 SENATE, ASSEMBLY, GOVERNOR 221

13 SENATE, ASSEMBLY, GOVERNOR'S OFFICE 186

14 NYS ASSEMBLY, SENATE, EXECUTIVE & 168

15 SENATE, ASSEMBLY, EXECUTIVE 162

16 NYS SENATE/ASSEMBLY/EXECUTIVE 160