Director of Compliance

The Shakman case prohibits the consideration of Political Reasons or Factors in all aspects of employment with the Assessor's Office. This means that politics cannot be considered in the hiring, termination, promotion, transfer or in any other action pertaining to employees or to individuals applying for positions with the Assessor's Office. There are a few exceptions. These positions are called Exempt Positions. Political Reasons or Factors can be considered in the hiring or termination of employees holding Exempt Positions.

There are three documents which specifically address these prohibitions:

  • the Agreed Order found here,
  • the Employment Plan found here
  • and the Assessor's Executive Orders found here and here

In furtherance of the Assessor's Office's commitment to engage in fair, transparent and non-political hiring and employment practices as required by the Shakman case, the Cook County Assessor hired a Director of Compliance (DOC). The Director of Compliance functions as the Employment Plan compliance officer for the Office and has responsibilities which include the following: (a) overseeing compliance with the Employment Plan and policies referenced in the Employment Plan, including the monitoring and auditing of employment actions (b) maintaining and reviewing the Exempt List (c) accepting, investigating, and reporting on complaints related to alleged technical violations of the Employment Plan (d) accepting, investigating, and reporting on complaints related to Unlawful Political Discrimination in Employment Actions and Political Contacts (e) investigating alleged violations of policies in the Employee Handbook referenced in the Employment Plan and (f) working with Human Resources to implement training programs to educate employees on the Employment Plan and the prohibition of Unlawful Political Discrimination.

Director of Compliance Semi-Annual Reports

Information about the Employment Plan

  • Employment Plan Compliance
    • What is the Employment Plan?
      • The Employment Plan is a document entered by the Court that implements proactive and transparent policies, procedures and practices for the Assessor's Office that address the prohibition and influence of Political Reasons or Factors in Employment Actions. A copy of the Employment Plan can be found here. The Director of Compliance is available to answer any questions about the Employment Plan and will treat all inquiries objectively and confidentially.
    • What is an Employment Action?
      • An Employment Action is any action (positive or negative) related to any aspect of employment, including, but not limited to, hiring, training, change in job assignment, temporary assignment, cross-training, promotion, demotion, transfer, reclassification, layoff, assignment of overtime (and other benefits of employment), discipline, and termination.
    • Complaints alleging violations of the Employment Plan
      • Who may file a complaint?
        • Any person who has knowledge of non-compliance with the Employment Plan or policies in the Employee Handbook referenced in the Employment Plan is required to file a complaint with the Director of Compliance.
      • How to file a complaint?
        • A complaint may be made by using the form found here, by e-mail, or by telephone and a complaint may be made anonymously; Director of Compliance, Matthew R. Serio, (312) 603-0745, MSerio@cookcountyassessor.com. Employees are required to cooperate fully in any investigation conducted by the Director of Compliance. Employees cannot be retaliated against for reporting Unlawful Political Discrimination or for participating in an investigation. This means that a negative Employment Action cannot be taken against an employee for reporting Unlawful Political Discrimination or for cooperating with an investigation.
      • Will a report be issued after an investigation?
        • The DOC will issue a report at the conclusion of an investigation. The report will include a description of the allegations, a description of the findings, other relevant information, if any, and recommendations for remedial action. If the DOC finds that Unlawful Political Discrimination occurred, the Assessor, after reviewing the DOC report, may conduct a follow-up investigation of the alleged Unlawful Political Discrimination. The Assessor then issues an Assessor's Report and the Assessor may either accept, reject, or offer alternative proposals to the DOC?s recommendations.
  • Hiring
    • General Hiring Process
      • What is the General Hiring Process?
        • The General Hiring Process is designed to be fair, transparent, and free from political influence. It is a process to ensure that employment decisions are based only on valid and relevant criteria. Most positions in the Assessor's Office, including all positions that are subject to the collective bargaining agreement, are filled through the General Hiring Process. In order to be considered for a position filled through the General Hiring Process, applicants must carefully follow all application instructions and meet the Minimum Qualifications for the position. Minimum Qualifications for a position are based on the job description and are qualifications that an applicant must possess in order to be considered for the position. Frequently asked questions about the General Hiring Process can be found here.
    • Exempt Positions
      • What is an Exempt Position?
        • An Exempt Position is a job that involves policy making or is confidential such that political party affiliation is an appropriate requirement for the effective performance of the job. Individuals in Exempt Positions may be hired or terminated for political reasons.
      • How are Exempt Positions filled?
        • Exempt Positions are not filled in accordance with the General Hiring process. There is no set process for the filling of Exempt Positions. However, individuals must meet the Minimum Qualifications for the position as set forth in position description in order to be hired into an Exempt Position. Prior to an individual being selected for an Exempt Position, the Director of Compliance reviews the application materials to ensure that the individual meets the Minimum Qualifications for the Exempt Position. Only individuals who meet the Minimum Qualifications for the position may be placed in an Exempt Position.
      • What is the Exempt List?
        • The Exempt List is the list of all Exempt Positions within the Assessor's Office. This list may only be amended pursuant to the process set forth in the Employment Plan and with the approval of the Court. The Exempt List is maintained and reviewed by the Director of Compliance. The Exempt Position list can be found here.
    • Executive Assistants
      • What is an Executive Assistant?
        • An Executive Assistant is a position that reports directly to an Exempt Deputy or Director and who perform executive-level administrative services for the Deputy or Director. Executive Assistant positions are non-Exempt, at-will, and are not covered by a collective bargaining agreement. The Executive Assistant list can be found here.
      • How are Executive Assistant Positions filled?
        • The hiring of an Executive Assistant cannot be based on Political Reasons or Factors. Positions are not filled through the General Hiring process but are filled through a separate process as set forth in the Employment Plan. In filling an Executive Assistant position, the Deputy or Director submits a Request to Hire containing the identification of the individual selected for the position, the personal knowledge upon which the selection was made, a copy of required certifications or licensure, and a No Political Considerations Certification. The Director of Compliance reviews the application materials to ensure that the individual meets the Minimum Qualifications for the Executive Assistant position.
    • Ineligible for Rehire List
      • What is the Ineligible for Rehire List?
        • The Ineligible for Rehire list is a list of former Assessor's Office employees who have been determined to be ineligible for rehire by the Assessor's Office. Individuals are ineligible for rehire if (1) there is a finding by the DOC that the individual engaged in Unlawful Political Discrimination or Prohibited Political Activity, or (2) there is a finding by the DOC that the individual intentionally provided materially false information during an investigation by the DOC or refuse to cooperate with an investigation, or (3) there is a finding by the DOC that the individual intentionally provided materially false information to the Assessor Compliance Administrator or to the DOC, or (4) there is a finding by the DOC that the individual falsified an Assessor's Office document concerning any Employment Action. Individuals on the Ineligible for Rehire list are ineligible for employment with the Assessor's Office for a period of five years.
      • How is the Ineligible for Rehire List maintained?
        • The Ineligible for Rehire list is maintained by the Human Resources Department and a copy of the list is maintained by the DOC. The DOC must be notified five days in advance of the removal of an individual from the Ineligible for Rehire list in order for a determination to be made that the appropriate time frame for ineligibility has been instituted and expired.

Director of Compliance (DOC) Contact Information

The Director of Compliance (DOC) is a non-Exempt position in the Assessor's Office. The Director of Compliance operates with the requisite independence necessary to fulfill the duties of the position as set forth in the Agreed Order and the Employment Plan.

Susan G. Feibus
Assessor Compliance Administrator/Interim DOC
69 West Washington St., Suite 818B
Chicago, IL. 60602
Email: susan@feibuslaw.com
Phone: 312-343-0221

Note: Ms. Feibus currently holds both the titles of ACA and Interim DOC. Per a court order, Ms. Feibus will remain as DOC until the Assessor's Office hires a new permanent DOC. The previous DOC left the office in June 2021.