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Proposed Bill Would Expand Political Communications Ban for Foreign Nationals

On June 25, the Preventing Adversaries Internationally from Disbursing Advertising Dollars Act (the bill) was introduced in the U.S. Senate. The bill proposes expansions of existing prohibitions on political activities of...more

FEC Announces New Federal Campaign Contribution Limits

On February 7, 2019, the Federal Election Commission (FEC) announced new federal campaign contribution limits. The Bipartisan Campaign Reform Act of 2002 requires the FEC to adjust certain federal contribution limits every...more

Political Contribution Disclosure Rules in Illinois, Maryland, New Jersey, Pennsylvania and Rhode Island

The following describes the periodic reporting requirements under five state laws for certain corporate entities to file reports regarding their business relationships with these states, as well as their political...more

Post-Election Issues (Inaugurations, Transitions, and Special Elections)

Now that the 2018 midterm elections are over, we must contend with legal issues that arise from activities related to federal, state and local inaugural and transition committees, as well as recounts and runoff elections. As...more

New Hampshire Moves to Require Corporations to Register as PACs; New York Codifies Placement Agent Ban

Below, please find a discussion of recent developments in New Hampshire and New York. New Hampshire The New Hampshire Office of the Attorney General recently has indicated that, going forward, it will interpret state...more

Montana Enacts New Pay-to-Play Disclosure Requirements

On June 8, 2018, Montana Gov. Steve Bullock signed Executive Order No. 15-2018 (the order), enacting new pay-to-play disclosure requirements. The order is notable in that it not only requires disclosure of certain contractor...more

RGA and RSLC Register Main Accounts as Virginia Political Committees

On April 6, 2017, we sent a mailing alerting you to the fact that the Republican Attorneys General Association had registered its main account — the general operating account — as a political committee with the Commonwealth...more

CFTC Issues Interpretation on Federal Transition and Inaugural Contributions

On December 23, 2016, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a staff interpretation saying that, in its view, contributions by swap dealers and their...more

"Developments: Applying Federal Pay-to-Play Rules to Trump/Pence Inaugural and Transition Committees"

For financial institutions subject to federal pay-to-play rules (SEC Rule 206(4)-5 for investment advisers, MSRB Rule G-37 for municipal bond underwriters and municipal advisors, and CFTC Rule 23.451 for swap dealers),...more

"Post-Election Issues"

Now that the 2016 elections are over, we must contend with special legal issues that arise from contributions made to, and expenses incurred for, federal, state or local inaugural or transition committees, as well as recounts...more

SEC Approves FINRA Pay-to-Play Rule

This week, on Thursday, August 25, 2016, the SEC approved FINRA Proposed Rules 2030 and 4580 (the Proposed Rules) as they had been proposed by FINRA. The Proposed Rules would impose pay-to-play restrictions and recordkeeping...more

"California Treasurer Announces New Pay-to-Play Policy for Municipal Bond Underwriters"

California State Treasurer John Chiang has adopted a new pay-to-play policy for firms participating in the state’s underwriter pool. By August 31, 2016, firms will need to certify that they will abide by the policy, or risk...more

"Contributions to Trump/Pence Campaign Are Subject to Pay-to-Play Rules"

On July 15, 2016, Donald Trump announced that he selected Indiana Gov. Mike Pence as his vice presidential running mate. Contributions to the Trump/Pence campaign are now subject to prohibitions and restrictions under the...more

"Supreme Court Vacates Corruption Conviction of Former Virginia Governor"

On June 27, 2016, the United States Supreme Court unanimously vacated the conviction of former Virginia Gov. Bob McDonnell on corruption charges and remanded the case for retrial. As discussed below, the impact of the...more

"Maryland Again Proposes Regulations Regarding Its Pay-to-Play"

The Maryland State Board of Elections recently proposed new regulations regarding its pay-to-play reporting law. The public comment period closes on May 30, 2016. Below is a summary of the key provisions contained in the...more

"Maryland Amends Pay-to-Play Disclosure Law"

On April 26, 2016, Maryland Gov. Larry Hogan signed a bill amending the state’s pay-to-play disclosure law. The law currently requires that a filer include on its reports contributions made by or attributed to the filer...more

"Reminder: New Jersey Pay-to-Play Form BE Due on March 30, 2016"

This memorandum is to remind you that the annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due March 30, 2016. In particular, as we have described in previous mailings, this...more

"MSRB Amendments to Pay-to-Play Rule Will Take Effect in August 2016"

On February 17, 2016, the Municipal Securities Rulemaking Board (MSRB) announced in Regulatory Notice 2016-06 that its draft amendments to Rule G-37 on political contributions, and related amendments to Rules G-8 and G-9 on...more

"New York JCOPE Issues Lobbying and Political Contributions Opinions"

On January 26, 2016, the New York Joint Commission on Public Ethics (JCOPE) approved two controversial advisory opinions. The first opinion clarified the scope of the state’s lobby law. Although most of the media coverage on...more

"Wisconsin Raises Contribution Limits, Eases Federal PAC Requirements"

On December 16, 2015, Wisconsin Gov. Scott Walker signed 2015 Wisconsin Act 117, which became effective January 1, 2016 (the Act). Among other changes, the Act eases the registration requirements for federal political action...more

"FEC Dismisses Wal-Mart PAC Match Case"

The Federal Election Commission (FEC) recently dismissed a complaint filed against Wal-Mart Stores, Inc. and its political action committee (PAC), finding that Wal-Mart's 2-for-1 PAC match program did not violate federal...more

"Political Contribution Disclosure Rules in Maryland, New Jersey, Pennsylvania and Rhode Island"

The following describes the reporting requirements under Maryland, New Jersey, Pennsylvania and Rhode Island laws for certain corporate entities to file reports regarding their business relationships with these states, as...more

"FINRA Submits Pay-to-Play Rule 2030 to SEC for Approval"

On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) submitted Rules 2030 and 4580 (the Draft Rules) to the Securities and Exchange Commission (SEC) for approval. The Draft Rules set forth pay-to-play...more

"MSRB Submits Pay-to-Play Rule G-37 Amendments to SEC for Approval"

On December 16, 2015, the Municipal Securities Rulemaking Board (MSRB) filed its draft amendments to Rule G-37 on political contributions (the Draft Rule) with the Securities and Exchange Commission (SEC). The Draft Rule...more

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