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___________________________________________________________________________________________ April 25, 2013 New York State Joint Commission on Public Ethics 540 Broadway Albany, NY 12207 Re: Guide for Filing A NYS Financial Disclosure Statement and Advisory Opinion 13-02 Dear Sir or Madam: New Yorkers for Constitutional Freedoms (NYCF) is a nonprofit advocacy organization under Section 501(c)(4) of the Internal Revenue Code. Founded in 1982, NYCF lobbies the New York State government regarding matters of concern to the evangelical Christian community. We are writing in regard to the Joint Commission on Public Ethics Guide (JCOPE) for Filing a NYS Financial Disclosure Statement, which states that financial and other data regarding spouses of elected officialsbut not unmarried domestic partners of elected officials must be provided in connection with an elected officials annual financial filing. On the other hand, we note that JCOPE recently released Advisory Opinion 13-02, in which JCOPE found that the domestic partner of the Governor of New York may fly on state aircraft for free when traveling with the Governor to and from official events, may stay in the Governor's Mansion, and may receive state police protection when with the Governor. NYCF is not unique in pointing out the apparent inconsistency between the Guide for Filing a NYS Financial Disclosure Statement and Advisory Opinion 13-02. If the Governors domestic partner is to be entitled to the state-provided perks and benefits that a Governors spouse would receive, it logically follows that the Governors domestic partner should be required to disclose the same financial information that a Governors spouse would be required to disclose. Also, the publics interest in government accountability and transparency militates in favor of such a requirement. Therefore, we request that the Joint Commission on Public Ethics reviews its Guide for Filing a NYS Financial Disclosure Statement with respect to the question of the appropriate financial and other disclosures to be made by elected officials with domestic partners. NYCF urges that the current Guide be brought into conformity with both the letter and the spirit of Advisory Opinion 13-02. Thank you for your consideration. Respectfully submitted,

Rev. Jason J. McGuire Executive Director

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