A Checklist for Advisers to Comply With New York’s Anti‑Sexual Harassment Training Requirements

Both New York State (NYS) and New York City (NYC) have enacted new laws imposing anti-sexual harassment requirements on private employers based in New York. The NYS and NYC laws have several common requirements, including that employers train their employees on preventing sexual harassment. NYS previously released final versions of model sexual harassment prevention materials that employers may adapt and use to comply with the new training requirements. See “New York State Releases Final Anti-Sexual Harassment Model Policy and Training Materials” (Nov. 15, 2018). More recently, on the date the NYC anti-sexual harassment training requirements took effect, the NYC Commission on Human Rights issued updated frequently asked questions and an online training video. This article reviews the basic requirements of both the NYS and NYC sexual harassment laws; explains the training requirements under each law; and provides a checklist that investment advisers based in New York can use to ensure that their anti-sexual harassment training complies with both NYS and NYC requirements. For more information on the NYS and NYC sexual harassment requirements, see “What Fund Managers Need to Know About Recent Developments to the New Anti-Sexual Harassment Policy and Training Requirements in New York City and New York State” (Sep. 13, 2018); and our two-part series: “Key Elements of New York’s New Anti-Sexual Harassment Policy and Training Requirements” (Jun. 14, 2018); and “Ways Fund Managers Can Comply With New York’s New Anti-Sexual Harassment Policy and Training Requirements” (Jun. 21, 2018).

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