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Agency Testimony

CFB testimony - Ryan on amended bill and disclosure model

New York City Council · Jun 22, 2026 · starts 0:38:53 · 1 min

Ryan appreciates that the amended bill shifts from a prohibition to a disclosure model and names CFB as the implementing agency, eliminating First Amendment vulnerabilities and clarifying enforcement responsibilities. He says CFB is well qualified as a disclosure administrator.

Paul Seamus Ryan

To that end, we appreciate that the amended version of this legislation meaningfully addresses our most significant legal and implementation concerns shared at the hearing in December 2024.

Paul Seamus Ryan

By shifting from a prohibition to a disclosure model and naming the CFB as the agency in receipt of these disclosures, as well as naming the CFB as the agency responsible for implementing the new disclosure regime,

Paul Seamus Ryan

the Council eliminated the greatest vulnerabilities to First Amendment legal challenge and clarified administrative and enforcement responsibilities.

Paul Seamus Ryan

The CFB has a unique perspective on this topic rooted in our dual mandate to serve candidates and voters.

Paul Seamus Ryan

CFB is well qualified to administer and enforce the requirements of Intro 12A.

Paul Seamus Ryan

We receive disclosure reports from all campaigns running for city office and all independent spenders active in city elections.

Paul Seamus Ryan

We sympathize with the perspective of both.

Paul Seamus Ryan

And we impose fines and penalties for violations of our campaign finance rules and laws.

Paul Seamus Ryan

We wholeheartedly share your concerns about the ways that AI technology could be used to spread false information to intentionally mislead or deceive voters about council members and other city candidates and officeholders.

Paul Seamus Ryan

Importantly, this bill casts the CFB in a role we have already played as a disclosure administrator, receiving, processing, and making public the information reported to us, not as a content regulator.

Paul Seamus Ryan

At the Campaign Finance Board, we have placed a priority on learning about artificial intelligence.

Paul Seamus Ryan

Ms.

Paul Seamus Ryan

Melillo and I recently completed the Harvard Kennedy School AI in Action certificate course.