Update: What to know about NYC’s updated salary transparency requirements

New York City Mayor Eric Adams has signed into law the NYC Council’s amendments to the Salary Transparency Law, which now becomes effective on Nov. 1, 2022.

In addition to postponing the law’s effective date (originally May 15, 2022), the amendments also clarify three other aspects of the law:

  • There will be no civil penalty for the first violation if the employer cures the violation within 30 days of receipt of a complaint.
  • In line with updated the New York City Commission on Human Rights guidance, the law applies to job listings for both salaried and hourly positions, and does not apply to any position “that cannot or will not be performed, at least in part, in the city of New York.”
  • While an individual may only file a lawsuit based on a violation arising from an advertisement by a current employer, any aggrieved person may file a complaint with the Commission, regardless of whether the alleged violator is the grievant’s current employer.

Credit unions located in New York City are encouraged to ensure their current pay practices are up to date and to consider conducting pay equity audits to assess current issues related to equity in pay. It is also recommended that credit unions work with legal counsel on how to address possible discrepancies in any current pay practices in an effort to further promote internal equity. In addition, credit unions should consider developing and implementing onboarding practices that comply with the new law and are informed by the findings of the pay equity audit.

Several states have already adopted similar laws, and the New York State legislature recently introduced pay transparency legislation. Albany County is also considering similar legislation.

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