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 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. 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 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 passage or defeat of legislation by the State Legislature;
- the approval or disapproval of legislation by the Governor;
- the outcome of a rule, regulation, or rate-making proceeding by a State agency;
- the passage or defeat of any local law or ordinance;
- the passage of defeat of a rule, regulation or rate-making proceeding by any municipality or subdivision thereof ;
- Procurement Lobbying --any determination by a public official, or by a person or entity working with a government official related to a procurement (any time you are competing for a governmental entity to award a product, service or public monies to the university you could be involved in a procurement contract.
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 attempt to influence…
- The passage or defeat of a local law or resolution by the city council or mayor;
- zoning determinations;
- determinations 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 or concession;
- any rule having the force and effect of law;
- the outcome of a rule making proceeding before a state agency;
- any determination by a board or commission;
- Procurement Lobbying--any determination made by an elected official or an officer or employee of the city regarding the procurement of goods or services including the specifications of a contract, the solicitation, award or administration of a contract, the award or administration of a grant, loan or any agreement involving the disbursement of public monies.
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.