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Office of the New York State Comptroller’s Seal

NYS Comptroller

Thomas P. DiNapoli

Reporting Elected and Appointed Officials

Reporting Requirements Changes (2015)

Title 2 of New York Codes, Rules and Regulations (NYCRR), Part 315 was originally adopted in 1975. Since its adoption there have been a few amendments which govern the reporting requirements for elected and appointed officials. Section 315.4 requires elected and appointed officials to record and submit a Record of Activities (ROA) to their employers if:

  • They are members of the New York State and Local Retirement System (NYSLRS); and
  • Do not use a time-keeping system that shows hours worked. (This includes systems that keep track of accruals used and attest that, other than time charged to accruals, hours were worked.)

The revisions to the regulation help ensure that elected and appointed officials receive appropriate service credit.

The chart below summarizes the most recent revisions:

Comparison of Previous to Current Requirements for Regulation 315.4

Previous Regulation Amended Regulation
Elected and Appointed Officials
Official did not need to attest to the accuracy of their ROA. Official must sign their ROA to attest to its accuracy.
Regulation did not clearly address how frequently an official must/can submit an ROA.
  1. Official must submit an ROA following a new or subsequent appointment.
  2. Official may attest that a previous ROA is still valid for up to 8 years.
  3. Official may submit a new ROA if the previous ROA is not representative.
Governing Body
Regulation did not address whether the governing body had the authority to determine whether activities are official duties of the position. Regulation now states that the employer determines whether activities listed on the ROA are official duties of the position, and if they are not, excludes the activity and time from the calculation of average number of days worked per month.
Clerk or Secretary
Employer had to include officials who participate in the employer’s time-keeping system on the Standard Workday and Reporting Resolution (Resolution) and indicate their participation by checking the box that says “Participates in the Employer’s Time-Keeping System.” Employer is no longer required to include officials who participate in the employer’s time-keeping system on the Resolution.
Employer may omit NYSLRS registration numbers and social security numbers from the publicly posted Resolutions. Employer must omit NYSLRS registration numbers and Social Security numbers from the publicly posted Resolutions.
Employer had to submit the Resolution to the State Comptroller within 45 days of the adoption of the resolution. Employer must submit the Resolution to the State Comptroller within 15 days after the 30-day public posting period ends.
Employer had to keep copies of the officials’ ROA for 10 years. Employer must keep copies of the officials’ ROA for 30 years.
Regulation did not address whether the Secretary or Clerk had to provide the average number of days worked per month listed on the Resolution to the individual(s) responsible for reporting days worked to the Retirement System on the employer’s behalf. Once a standard work day and reporting resolution is passed, the Secretary or Clerk must provide the average number of days worked per month listed on the Resolution to the individual(s) responsible for reporting days worked to the Retirement System on the employer’s behalf.

Rev. 9/18