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NYS Comptroller


The Academy for New York State's Local Officials

Protecting the Public’s Interest: A Tutorial on Local Government Ethics and Transparency in New York State

Module 1 - Conflict of Interest of Municipal Officers and Employees

Step 1:

Is the municipal officer or employee who has the interest in the bank or trust company the chief fiscal officer (CFO), treasurer, or a deputy or employee of either the CFO or treasurer?

If not, then the exception applies and it is permissible to designate the bank or trust company as a depository, paying agent, registration agent, or for the investment of municipal funds. In this situation, it does not matter whether there are any other banks or trust companies located in the municipality. For example, if a village mayor has an interest in a bank, the exception would apply whether there is a single bank or a dozen within the village's borders because the mayor is not the village CFO, treasurer, or a member of their staff.

  Next: Step 2