Political Activities and
Policy Engagement

As a leading global financial institution, BNY has a unique voice and perspective to bring to the policy and political process. Laws and regulations have significant impacts on our business, the markets where we operate, as well as our clients, employees, shareholders and communities. We are committed to working constructively with policymakers and market participants to move the financial services industry forward in compliance with applicable legal requirements.

Public Policy Engagements

Working both bilaterally and through trade associations, BNY’s Public Policy and Government Affairs (PPGA) team represents BNY’s interests in the United States, Europe and Asia. This activity includes the submission of comment letters in response to regulatory and legislative proposals, engagement with elected officials, regulators and administration officials, as well as engagement with trade associations. In addition, qualified employees engage in our Political Action Committee (PAC) program. BNY does not engage in grassroots lobbying.

Oversight

The BNY Public Policy and Government Affairs team is responsible for overseeing political activity by or on behalf of BNY, including administration of the Political Action Committees (PACs). All political activity is done in furtherance of BNY business strategies and in the best interests of the company. The PPGA team reports to the General Counsel and is overseen by the Board of Directors Corporate Governance, Nominating and Social Responsibility (CGNSR) Committee. The group provides regular updates (at least semi-annually) to the CGNSR Committee to set engagement strategy, receive feedback and maintain alignment with business priorities.

Lobbying

Lobbying and other political activity is subject to various rules and regulations based on jurisdiction and BNY is committed to complying with the applicable requirements. The BNY PPGA team discloses political activity as legally required in each jurisdiction. In the U.S., BNY files reports at the federal and state levels and recent reports are available below. In Europe, BNY reports political activities annually through the EU Transparency Register. All activities are designed to be conducted in accordance with BNY’s Code of Conduct, internal policies and procedures, applicable laws and regulations, and in consultation with the compliance and legal Departments, as well as external counsel. 

Employee-Funded Political Action Committees

BNY’s Political Action Committees (PACs) are funded entirely by voluntary contributions from eligible employees.  Because both PACs are separate segregated funds, federal campaign finance law permits BNY to pay for the PACs’ administrative expenses without making a contribution to either.  

The BNY PACs make contributions to candidates for federal offices, national party committees, certain state/local offices and may make contributions to certain other PACs. PAC contributions are made on a bipartisan basis and in accordance with PAC bylaws, contribution guidelines and campaign finance restrictions.  The PACs do not make contributions to candidates running for President.

Contribution guidelines include the elected member’s participation in committees of jurisdiction, representation of communities where BNY has a presence, leadership positions and civility and respect for democratic processes. Contribution decisions are made by the bipartisan group of employees who make up the PAC Boards and are made without regard to the private political preferences of the PAC Board members or any BNY executives. The PAC Boards adhere to applicable campaign finance laws and regulations.

PACs are regulated by the Federal Election Commission (FEC) and relevant state election commissions. BNY files periodic reports accordingly as required by law.  Reports filed with the FEC are available to the public at www.fec.gov and with state election commissions available here.

Trade Associations

BNY is a member of numerous trade associations. These trade associations help build consensus, facilitate information sharing, and produce industry analysis and best practices. They may also advocate on policy issues of interest to the financial industry and general business community. We ask trade associations not to use our membership fees to fund federal, state, or local level election-related activity, including contributions and expenditures to support or oppose any candidate for any office, political party committee, or political committee.

Our principal trade association memberships, defined as organizations to which we pay $25,000 or more annually in dues, include:

• American Bankers Association
• Association of Global Custodians
• Bank Policy Institute
• Belgium Febelfin
• Business Roundtable
• Financial Services Forum
• Global Financial Markets Association, including its regional trade association members AFME, ASIFMA, GFXD and SIFMA
• Institute of International Finance
• International Swaps and Derivatives Association
• Investment Company Institute
• Loan Syndication and Trading Association
• Managed Funds Association
• New York Bankers Association
• Partnership for New York City
• Pennsylvania Bankers Association
• Risk Management Association
• Structured Finance Association
• The Clearing House
• TheCityUK
• UK Finance

We regularly review our memberships for alignment with our priorities. Our membership in specific trade associations does not mean we endorse or support every position, priority, or issue that those organizations support. We may voice differing viewpoints directly to those organizations where we disagree. This list of memberships is subject to change and will be updated accordingly.

Employee Engagement

We encourage our employees to stay informed about political issues and candidates and to take an active interest in policy and political affairs.  Employees may participate in the political process by making voluntary contributions on their own behalf or engaging in personal political activities in accordance with applicable federal and state laws and regulations, the Code of Conduct and internal policies and procedures.

Compliance

Employees are not reimbursed or compensated in any way for attending political events, engaging in political activities, or making political contributions (either personally or to the BNY Employee Funded PACs.)  Employees engaging in political activities, except for official BNY responsibilities, must do so on their own time and use their own resources.  Our Compliance Department reviews all individual employee contributions that may be affected by federal, state, or local “pay-to-play” laws including SEC Rule 206(4)-5, MSRB Rule G-37 and CFTC Rule 23.451. Employees covered by such restrictions have been identified by BNY and are subject to pre-clearance requirements.

Employees who wish to accept an appointment to public office or file as a candidate for election must first obtain approval consistent with BNY policy to avoid any conflict of interest.

¹ A gift, subscription, loan, advance, or deposit of money or anything of value given to influence a federal election; or the payment by any person of compensation for the personal services of another person if those services are rendered without charge to a political committee for any purpose. 11 CFR 100.52(a) and 100.54

Corporations and labor organizations may not use their general treasury funds to make contributions to their separate segregated funds or candidates and they are generally prohibited from using their treasury funds to make contributions to other types of political committees. 11 CFR 114.2(b).