Ethics and Conflicts of Interest - FEDERAL RESERVE BANK of NEW YORK
Ethics and Conflicts of Interest

The New York Fed expects its employees to perform their duties with honesty, integrity and impartiality, and without improper preferential treatment of any person.

Code of Conduct

The New York Fed’s Code of Conduct outlines its principles and standards for employee conduct, including rules for avoiding actual and apparent conflicts of interest.

Conflicts of Interest Rules

New York Fed employees are subject to the same conflict of interest statute that applies to federal government employees (18 U.S.C. Section 208). Under Section 208 and the New York Fed’s code of conduct, a Bank employee is prohibited from participating personally and substantially in an official capacity in any particular matter in which, to the employee's knowledge, the employee has a financial interest if the particular matter will have a direct and predictable effect on that interest. Participation in a particular matter may include making a decision or recommendation, providing advice, or taking part in an investigation.

New York Fed employees are also not permitted to own or control investments in depository institutions or affiliates of depository institutions. Employees are also prohibited from investing in certain thrift holding companies and funds that have a state policy of concentrating their investments in the financial services sector. Additionally, staff members in the Markets Group and those with regular and ongoing access to Class I Federal Open Market Committee information may not own or control investments in a primary dealer or an entity that directly or indirectly controls a primary dealer.

In order to avoid the appearance of conflicts of interest, New York Fed employees are generally not permitted to accept anything of value from a supervised institution or anyone that does business or seeks to do business with the New York Fed. This prohibition applies to gifts, meals, favors and entertainment.

Preemployment Reviews
Post-Employment Rules
Heightened Rules for Examiners
Ethics Training
PUBLIC SPEAKING
Financial Disclosure Reports

The New York Fed requires that a large number of staff members file a confidential financial disclosure report.

These forms require the employee to disclose information about assets, liabilities, outside activities, gifts received, and other circumstances that might constitute an actual or potential conflict of interest or a violation of applicable law or Bank policy. An employee’s position and access to sensitive information determine the particular report that must be filed.

Among those required to file some form of report are the president and first vice president, Markets Group personnel, the Director of Research, staff members with access to Federal Open Market Committee (FOMC) information, Supervision Group personnel, all Reserve Bank officers and senior staff, any member of the management group in a valuables handling area, and employees:

  • Whose duties and responsibilities require that he or she participate personally and substantially through decisionmaking or the exercise of significant judgment in taking action regarding contracting or procurement;
  • Whose duties and responsibilities require that he or she participate personally and substantially in any supervisory matter, examination, application, investigation, etc., concerning a depository institution (DI) or any affiliate or subsidiary of a DI.

The financial disclosure process ensures staff compliance with the conflicts of interest rules and personal investment guidelines outlined in the Code of Conduct. The Ethics Office performs a comprehensive disclosure report review.

Personal Trading Compliance Program
Waivers

New York Fed employees are subject to a number of ethics rules and policies. Any proposed waiver to those rules and policies is subject to careful review and consideration before it is granted.

Bank Stock and Financial Interest Waivers
Section 208 Waiver
Pension Waivers
Relative Waiver
Related New York Fed Content
Related External Content
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