NYC’s Frontline Ethics Agencies Must be Funded

Thank you for the opportunity to provide written testimony about the budgets of the Conflicts of Interest Board (COIB) and Department of Investigation (DOI). Reinvent Albany advocates for transparent and accountable government in New York. 

First, we thank the City Council for holding budget hearings on the FY 2027 Executive Budget for both DOI and COIB, responding to a joint letter from Reinvent Albany and other watchdogs urging the City Council to restore funding to both agencies. Both DOI and COIB are operating at historically low funding and staffing levels despite their increasing responsibilities. The Council’s hearing was very illuminating about the effect this has had on their ability to fulfill their missions.

While Reinvent Albany fully supports the funding requests from both agencies, we caution that these requests only stabilize the agencies and meet their needs for FY2027.  This is not a “once and done” budget need. The Council must ensure that the FY2028 budget continues the progress in restoring them to past staffing levels, as well as meeting other technology and contracting needs of the agencies.

1. DOI – total of $10 million for staffing
   • $4 million for mandated 9/11 investigation
   • $6 million to stabilize the budget
     • $4.53 million for Other Than Personal Services (OTPS) costs
     • $1.14 million to reverse 50 percent vacancy reduction plan
     • $290,520 for five new, entry-level investigators
2. COIB – total of $395,000 for staffing
   • $95,000 for legal advice attorney
   • $300,000 for pay equity, so COIB staff salaries are more competitive
     • $230,000 for senior staff
     • $70,000 for junior staff
3. Additional COIB needs 
   • $1.5 million in capital for new financial disclosure system – COIB stated at its hearing that it is seeking a new financial disclosure filing system, and a budget line should be provided for OTI for $1.5 million in capital expenditures. The current system does not allow COIB to search the data – it only produces PDF reports, and they are unable to edit the questions. Additionally, COIB is unable to provide elected officials’ responses in an open data format. The current system is both antiquated for COIB and does not provide the public easy access to disclosure statements of the elected officials that represent them.
   • Auditor needed for legal defense trusts – COIB also stated that it does not have funding or current staff expertise to perform the audit requirements of the Legal Defense Trusts Law. Under the law, biennial audits using Generally Accepted Accounting Principles (GAAP) are required. These audits have not taken place for any of the reported trusts.
   • Case management system upgrade – Lastly, COIB noted that it has to annually seek approval for upgrading its outdated, 2013-era case management system from OMB. Because COIB is a small agency, it has been at the back of the line for this upgrade, and as a result, it has had to annually reapply.

Department of Investigation down more than 100 staff since FY17
DOI has been decimated by repeated Program to Eliminate the Gap (PEG) initiatives from the Adams administration. DOI has also been tasked with new responsibilities, in particular a mandated 9/11 investigation pursuant to Resolution 560-A of 2025 that must be funded. The next page shows a chart and table of DOI’s full-time staffing and budget levels from FY17 to FY27, compared to adjustments to reflect the growth in the overall NYC budget and inflation. More than 100 positions have been lost in this time period. 

It is clear that despite the growth in the NYC budget and complaints made to DOI, the agency has not been given adequate resources to oversee City agencies. According to the Mayor’s Management Report for DOI:

• Complaints increased from 12,128 in FY17 to 14,435 in FY25.
• It took 152 days to complete an investigation in FY17, compared to 251 days in FY25.
• 1,346 investigations were closed in FY17 vs 806 in FY25.
• 765 arrests resulted from DOI investigations in FY17 vs 220 in FY25.
• 498 policy and procedure recommendations were issued to agencies in FY17, compared to 158 in FY25.

COIB’s staff has not increased, despite much larger responsibilities
While COIB does not report to the MMR, it is clear that they also have experienced challenges meeting their goals. At the hearing, COIB noted that they had 21 staff in 1991 when they were first created, and were responsible for overseeing 240,000 NYC employees. Today, they have 22 staff members and oversee more than 300,000 employees, in addition to former NYC staff who must abide by revolving door limitations.

While COIB has done remarkably well in handling a large volume of inquiries and filings, their enforcement efforts have been strained. For example, in 2019, COIB issued 86 findings of violations. In 2024, this dropped to 46, according to their 2024 annual report (2025 report not yet available). 

Independent budgeting needed for DOI and COIB
We strongly urge the City Council to not only meet COIB and DOI’s funding requests, but also ensure that they are permanently protected from budget cuts. We ask that you support a charter amendment to provide independent budgeting to both agencies via a fixed formula, as proposed by the 2025 NYC Council Charter Revision Commission. 

Click here to view the testimony as a PDF.