My understanding is that the Board needs to submit a conflict of interest report that covers the entire Board's activities. At least that's how we've done it.

I have never heard that our shareholders are supposed to receive a copy of this report. It's supposed to be on file with the proper authorities.

I don't know why you'd say that there is no auditing/enforcement of this requirement. Just because you haven't received the report doesn't mean it hasn't been done. None of our shareholders has ever received this report.

The filing of this report is now the law, so any responsible Board should be in compliance.

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Interesting - I had understood that the requirement was to provide the report to shareholders themselves:

"submit an annual report to the shareholders, which shall be signed by each such director"

https://www.nysenate.gov/legislation/laws/BSC/727

When you say "on file with the proper authorities", can you be more specific? Would that be the NY Attorney General, or some other body?

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There is a podcast on this site by Braverman Greenspun titled
"What does the new disclosure law mean for my board?" also: https://www.habitatmag.com/Publication-Content/Legal-Financial/2018/2018-January/Conflict-of-Interest

I was also curious about this since i have never received this report either

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I don't know which agency gets the report. Our managing agent takes care of it by filing the report after the Board signs it.

I guess we've been lucky in that none of our Board members has anything resembling a conflict of interest based on how we conduct business.

Sounds like the podcast suggested by NYC might be worth a listen. Please update all of us if you receive additional information. Thanks.

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Hi philc,
Did you receive BCL727or find out any further information regarding this report?

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Hi,

No - I am still yet to (ever) receive one of these reports from my co-op.

As best I can tell, there is absolutely no enforcement of this requirement, although I'd love to be wrong about that.

Thanks, hope that helps!

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Because " The law is completely silent on enforcement and oversight, and does not contain any penalties for violations", boards are not adhering to this law, also shareholders are either unaware of the disclosure report
or do not want to be considered trouble makers by requesting the report.

Like other BCL's legal intervention would probably be required. What is the point of having a law that is moot?

You might want to contact Diana Nickel 212-416-8131  at the Attorney Generals office or anyone on lthe below list.

https://ag.ny.gov/sites/default/files/ref-public-directory.pdf

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