What financial interests have to be reported and how?


What has to be reported

Where the aggregate value received exceeds $200 in a given Fiscal Year, the Greenwich Code of Ethics requires that Town Officers report both the nature of their interest(s) in Town transactions and the total value received as a result. Reportable interests include indirect interests, such as the interests of: 1) joint owners, general or limited partners or shareholders, 2) subcontractors and employees, or 3) spouses, children, parents or others who the reporting individual might reasonably be expected to provide financial support for. Where the financial compensation isn't a fixed amount, the individual filing a report may rely on a reasonable estimate and should file an amended report in the event that the estimate becomes materially inaccurate. Where an individual is reporting an indirect interest, reasonable reliance on the amount reported or estimated by the person with the direct interest is permitted.The Code requires the Board of Ethics to prescribe the forms on which interests are to be disclosed. In general, the Board seeks to obtain information sufficient to identify the transaction in question and the value of the reporting person's direct or indirect interest. Where the interest is indirect, such as that of a subcontractor, employee or family member, the Board seeks to obtain sufficient information to describe the relationship and the amount of value actually expected to be received by the reporting person. Estimates of dates and values may be used, subject to the filing of an amended statement if the estimate proves to be significantly different from the actual result. Where the value is uncertain, an explanation may be provided. The form provided by the Board is intended to provide for substantial compliance with the requirements of the Code. Filers who have difficulty providing the specific information requested are encouraged to file with the best information available and then contact the Board to obtain an advisory opinion with respect to the sufficiency of that information.


What does not have to be reported

Interests in transactions aggregating less than $200 a year do not need to be reported. In addition, Town Officers are not required to report on the employment agreement or other service transaction that makes them a Town Officer, such as a Town employee's employment contract or a consultant's consulting agreement. Moreover, regardless of the size of a transaction, interests in the transaction that are not financial in nature or are nominal or common to the interests of other citizens of the Town, need not be reported. Thus, the payment of taxes or assessments or a use or license fee for Town services or facilities is not required to be reported as long as, at the time it is paid, the tax, assessment or fee is generally applicable and the service generally available, to all Town citizens on equivalent terms and conditions.


For additional information concerning financial reporting requirements Click here.

Show All Answers

1. How do I get a copy of the Town ethics code?
2. Who does the Greenwich Code of Ethics apply to?
3. Am I required to file an ethics disclosure statement?
4. How can get more information about disclosure filings?
5. What is considered a Town "transaction" for purposes of the Code of Ethics?
6. What financial interests have to be reported and how?
7. What if I have other questions about the Code of Ethics?