Department Policy and Lobbying Guidelines
The University’s Office of Government and Community Relations coordinates all University contacts with public officials, including University lobbying activities. This memo is intended as a brief introduction to the rules that apply to University political and lobbying activities, with the aim of helping to ensure that the University complies with Federal, New York State and New York City tax and lobbying laws.
The Office of Government and Community Relations, under the direction of Vanessa J. Herman, is the University’s primary contact for all elected officials and political candidates. Pace employees who plan to contact elected officials or political candidates on behalf of the University or to invite elected officials and/or political candidates to participate in University events must obtain advance permission from the Office of Government and Community Relations. Furthermore, all requests from public officials or political candidates to use University facilities must be referred to the Office of Government and Community Relations for review and response. Pace employees must also obtain advance permission from the Office of Government and Community Relations if they plan to use University letterhead or email to invite elected officials and/or political candidates to participate in University events; to support a political candidate, political party PAC or the like; or to engage in lobbying activities as defined below. These requirements apply only to contacts on behalf of the University and not to contacts with government officials by individuals or groups of individuals on their own behalf. Compliance with these requirements is necessary to maintain the University’s tax-exempt status under Section 501(c)(3) of the Internal Revenue Code.
Vanessa J. Herman is the University’s Principal Lobbyist. She is responsible for coordinating the University’s lobbying efforts. Both New York State and New York City laws require that employees who lobby on behalf of the University must register as lobbyists and file reports detailing their lobbying activities. We have included a brief description below, of the kinds of activities considered to be “lobbying” under New York State and New York City laws.
Please be advised that unless the Office of Government and Community Relations has designated you to do so, you are currently NOT authorized to lobby on behalf of Pace University. There are severe civil and criminal penalties associated with lobbying without being registered and/or violating provisions of the lobbying act. If you believe that you might engage in the below activities in the future, we can arrange for you to attend a training seminar. The seminar will outline permissible lobbying activity and how such activity must be reported to both New York State & the City of New York. In addition, we urge you to reach out to the Office of Government and Community Relations so that we can determine whether you should be registered as a lobbyist.
Pace University is currently registered to Lobby in New York State. Pursuant to the New York State Lobbying Statute, lobbying is defined as any attempt to influence:
- The introduction of State legislation or resolutions;
- the passage or defeat of State legislation or resolutions;
- the adoption, issuance, rescission, modification or terms of an executive order issued by the Governor, or the chief executive officer of a municipality;
- the adoption or rejection of any state or local rules and regulations;
- the outcome of a ratemaking proceeding of the State or any municipality or subdivision thereof;
- any determination by a public official or a person or entity working with a government official related to a governmental procurement;
- the approval, disapproval, implementation of tribal- state compacts or other tribal agreements;
Please note that the New York State Lobbying regulations apply to attempts on behalf of the University to influence the listed matters both directly (by contacts with public officials) and indirectly (through contacts with the press).
The University is also registered to lobby with the City of New York. Pursuant to the New York City Lobbying Act, lobbying is defined as any attempts to influence:
- any determination made by the city council or member thereof with respect to the introduction, passage, defeat or substance of any local legislation or resolution;
- any determination made by the mayor to support, oppose, approve or disapprove any local legislation or resolution, whether or not such local legislation or resolution has been introduced by the city council;
- any determination made by an elected city official or an officer or employee of the city with respect to the procurement of goods, services or construction, including the preparation of contract specifications or the solicitation, award or administration of a grant, loan, or agreement involving the disbursement of public monies;
- any determination made by the mayor, the city council, the city planning commission, a borough president, a borough board or a community board with respect to zoning or the use, development or improvement of real property subject to city regulation;
- any determination made by an elected city official or an officer or employee of the city with respect to the terms of the acquisition or disposition by the city of any interest in real property, with respect to a license or permit for the use of real property of or by the city, or with respect to a franchise, concession or revocable consent;
- the proposal, adoption, amendment or rejection by an agency of any rule or regulation;
- the decision to hold, timing or outcome of any ratemaking proceeding before an agency;
- the agenda or any determination of a board or commission;
- any determination regarding the calendaring or scope of any city council over-sight hearing;
- the issuance, repeal, modification or substance of a mayor executive order;
- any determination made by an elected city official or an officer or employee of the city to support or oppose any state or federal legislation, rule or regulation, including any determination made to support or oppose that is contingent on any amendment of such legislation, rule or regulation, whether or not such legislation has been formally introduced and whether or not such rule or regulation has been formally proposed.
- the passage or defeat of any local law, ordinance, resolution, or regulation by any municipality or subdivision.
As an employee of a University that is registered to lobby, you are prohibited from giving “gifts” to government officials. A gift is defined as anything of more than nominal value given to a public official in any form including but not limited to money, service, loan, travel, lodging, meals, refreshments, entertainment and discounts.
Please address any questions that you have about lobbying activities to Vanessa J. Herman at (212) 346-1025 or via e-mail at email@example.com.