Frequently Asked Questions

Please review the following information about conflict of interest and financial disclosure for UB investigators if you have questions about when and how to file.

On this page:

Who is considered an investigator?

UB follows federal policies, asking investigators to file financial disclosure statements annually. Investigators are those persons who, regardless of title or position, who is responsible for the design, conduct, or reporting of research. They have the authority to make independent decisions about the direction of the research and subsequent conclusions drawn from the results.

You don't need to file if you are a non-investigator staff member. These persons are directed by the investigator(s) and have  well-defined roles and responsibilities for implementing research projects.

To whom should I disclose my financial interests?

You submit your financial disclosure statement online through Click COI.

When should I disclose my financial interests?

UB's annual filing deadline is Nov. 1.

All investigators must have a current financial disclosure on file prior to applying for extramural funding:

  • Annually, UB's filing deadline is November 1 of each year. Click COI will email notifications mid-September alerting individuals that they must complete their financial disclosure. A current annual financial disclosure must be completed prior to applying for extramural funding.
  • Within 30 days of discovering or acquiring a significant financial interest (e.g., through purchase, marriage or inheritance). Updating your financial disclosure is accomplished via Click COI.

What happens if I acquire significant financial interests during the award?

You must update your financial disclosure within 30 days of discovering or acquiring a significant financial interest (e.g., through purchase, marriage or inheritance) via Click COI. Once a financial disclosure is updated it will be reviewed against current awards and/or IRB protocols to determine if there is a potential conflict of interest or not. If it is determined that there is a conflict of interest, a management plan must be developed and submitted to UB's Conflict of Interest Research Committee (CIRC) for approval.

Learn more about the PHS financial conflict of interest policy.