COIB testimony - Carolyn on annual disclosure expansion concerns

So the second piece of the legislation talks about a major change to the annual disclosure law where it requires the reporting of all transactions.

Of $50 or more related to event contracts on prediction markets.

There's nothing, absolutely nothing even comparable in the current annual disclosure law.

For example, the closest thing would be the reporting of securities.

And a current public servant can buy and sell securities over the course of the reporting year.

There's no reporting.

Of the purchase or sale of any security, of who you bought it from, who you sold it to, when you made that transaction.

The only reporting requirement currently is the assets that you hold on the final day of the reporting period.

Similarly, there's no requirement of reporting of any other kinds of gambling.

You don't have to report

When you placed a bet, what casino you placed it at, what the bet was for, what you earned.

There's nothing comparable in the annual disclosure law.

You just have to report your winning.

on the final day of the reporting period.

And there's no reporting anywhere in the annual disclosure law of losses.

And this would be the first time that there would be any reporting of losses.

So this would be a dramatic expansion of any kind of comparable reporting in the annual disclosure law.

I'd also note that the...

The regulatory regime, the conduct, is directed at substantial policymakers.

And substantial policymakers may be comprised about a third, if not less, of people who report under the annual disclosure law.

For example, there's

every candidate for elective office in the city has to file an annual disclosure law, this provision would apply to those people.

Those people, many of whom are not public servants at the time they run for office, so they're having to report conduct which is totally fine, not prohibited, maybe thus deterring them from

seeking public office because they'd have to report conduct which is in no way prohibited, would it reflect a conflict of interest, or anything like that.

This, so there's, I think, a lot of ways in which this is maybe more than what is necessary given the current state.

It is a brand new field.

Prediction markets, why this particular robust reporting regime where there isn't anything similar seems to be disproportionate to the concern.

And we're happy to take any questions on either of these.

Councilmember, do you want to go ahead with questions?