Credit unions are reminded that the New York City Council’s amendments to the Salary Transparency Law, which requires employers to post minimum and maximum salary information, becomes effective on Nov. 1, 2022.

The amendments, originally set to go into effect May 15, 2022, aim to clarify three 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.

The state Legislature passed a similar bill that would impact all New York state employers with four or more employees, however, that bill has not yet been sent to the governor for signature/veto. The city of Ithaca also imposed a similar law effective Sept. 1, 2022 and Westchester County employers will be subject to similar requirements effective Nov. 6, 2022.