Many Public Authorities Must Comply with “Project Sunlight” in Public Integrity Reform Act of 2011

Late today, Governor Cuomo signed the Public Integrity Reform Act of 2011.  Among other things, the new ethics law creates a disclosure program named “Project Sunlight” which requires public agencies, including public benefit corporations and public  authorities that have at least  one  of their members  appointed by the governor, to provide the Office of General Services (OGS) with a list of all individuals, firms, or other entities (other than state or local governmental agencies) who have appeared before the corporation or authority in a representative capacity on behalf of a client or customer for purposes of: “(a) procuring a state contract  for  real  property,  goods  or  services for such client; representing such client or customer in a proceeding  relating  to  rate making; (c) representing such client in a regulatory matter; (d) representing  such client or customer in a judicial or quasi-judicial proceeding; or (e) representing such client or  customer  in  the  adoption  or repeal  of  a  rule or regulation.”  OGS is to collect the information and post it a readily searchable and available on-line database. This section of the new law takes effect January 1, 2013. The Governor’s press release describing the various provisions of the new law is available here.

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