Information on Political Engagement, Public Policy and Lobbying, Trade Associations and Political Contributions at BNY Mellon.
The financial industry globally is subject to extensive laws and regulations that continually evolve and affect the way we do business in the United States and internationally. Our engagement in policy development and political process can take many forms, including discussions with policymakers and providing thought leadership.
Corporate Contribution Reports
PAC Contribution Reports
Federal Lobbying Disclosure Reports
Reports can be found here. Total spend is also reported in our annual CSR reports.
Our Global Regulatory Policy and Government Affairs teams monitor legislative and regulatory activities in the United States, Europe, and Asia. We analyze the potential impacts of proposed laws and regulations on BNY Mellon and financial markets. We contribute to industry policy discussions to benefit our stakeholders and strengthen our reputation for responsible political engagement. Our Regulatory Policy and Government Affairs group sets priorities, partners with our senior management and businesses in lobbying activity and reports outcomes. We implement all changes required by regulatory reforms around the world.
We educate legislators, regulators and policymakers globally about BNY Mellon so they understand our unique business model and how we differ from other large financial institutions. This understanding helps them as they consider new reforms and regulatory proposals.
Through memberships in industry and trade associations, or together with peer banks, we submit comment letters, respond to financial industry surveys and meet with legislators and regulatory agencies to exchange ideas on the financial industry and regulatory and tax reform. Because our business model differs significantly from other large financial institutions, we are often impacted differently by industry regulations and need to explain potential unintended consequences to policymakers
In addition to lobbying efforts by members of our Government Affairs group, we have retained lobbying firms to advocate for our legislative interests at the federal and state level. These activities and applicable disclosure reports are regulated pursuant to federal and state laws. Our total annual federal lobbying spend can be found in our annual Corporate Social Responsibility Reports, and our federal lobbying disclosure reports can be found at http://lobbyingdisclosure.house.gov/index.html. Our state and local legislative lobbying efforts are concentrated in New York and Pennsylvania, where the company’s main business operations are located. Expenses are of a de minimis nature and are disclosed where required by applicable law.
BNY Mellon is a member of numerous trade associations that represent the interests of the financial industry and general business interests. These groups produce issues analyses or white papers and advocate on public policy important to their members. We regularly review our memberships for alignment with our priorities and may not always agree with an association’s or its members’ positions or priorities.
Our principal trade association memberships include the American Bankers Association, Investment Company Institute, The Clearing House and SIFMA (Securities Industry and Financial Markets Association). We also belong to the Financial Services Forum, GFMA (Global Financial Markets Association), AFME (Association for Financial Markets in Europe), EFAMA (European Fund and Asset Management Association), The Investment Association, The CityUK, ASIFMA (Asia Securities Industry and Financial Markets Association), New York Bankers Association, Pennsylvania Bankers Association, Insured Retirement Institute and Institute of International Finance.
We ask trade associations to not use our membership fees to fund federal, state or local level election-related activity, including contributions and expenditures (including independent expenditures) to support or oppose any candidate for any office, political party committee or political committee.
We also engage in the political process through political contributions. BNY Mellon has two political action committees (PACs) funded entirely by voluntary contributions from our employees. Employees are not reimbursed or compensated in any way for political activities or contributions. In accordance with applicable federal, state and local regulations, the PACs have the ability to make contributions to U.S. federal candidates, and/or state and local candidates, political party committees and other political action committees.
Our PACs are regulated by the Federal Election Commission (FEC) and file reports, as required, with the FEC and relevant state election commissions. Reports filed with the FEC are available to the public at www.fec.gov. Our most recent report of our PAC contributions is available here.
It has been our practice to disclose any corporate contributions** that we make. When we do make such contributions, we will disclose that information semi-annually. Our most recent report of corporate contributions is available here.
In addition, BNY Mellon does not use corporate funds for independent political expenditures in support of, or opposition to, any candidate for office.
** A corporate contribution is defined to include a state candidate committee, a 501(c)4, 527 or ballot initiatives.
Our Government Affairs team is under the supervision of the company’s General Counsel. The Government Affairs leadership is responsible for all political activity by or on behalf of BNY Mellon, including administration of our PACs. When making specific contribution decisions, the PAC officers, in consultation with the Government Affairs staff, consider a number of factors, including the candidates’ views on issues related to our business, their leadership positions and legislative committee memberships, and the communities they represent.
The Corporate Governance, Nominating and Social Responsibility Committee of our Board of Directors, which consists entirely of independent directors, provides oversight of our public policy advocacy, lobbying focus and political contributions.
We encourage our employees to stay informed of political issues and candidates and to take an active interest in political affairs. Employees may participate in the political process by making voluntary contributions on their own behalf to candidates and related political entities, in accordance with applicable federal and state laws and regulations and company policies. In addition, employees must comply with the company’s Code of Conduct and company policy with respect to engaging in personal political activities.
Employees are not reimbursed or compensated in any way for attending political events, engaging in political activities or making political contributions. Employees engaging in political activities must do so on their own time and with their own resources. Our Compliance and Ethics Department reviews all individual employee contributions that may be affected by federal, state or local “pay-to-play” laws. These laws limit the ability of corporations to compete for business if certain employees have made contributions to officials who have the authority to award business.