In a recent mailing we noted that the following Democratic presidential candidates are covered under federal pay-to-play rules (i.e., SEC 206(4)-5, MSRB G-37, CFTC 23.451 and FINRA 2030) because they are currently elected...more
Financial institutions and their employees may be subject to the following federal pay-to-play rules: SEC Rule 206(4)-5 for investment advisers; CFTC Rule 23.451 for commodities-backed swap dealers; FINRA Rule 2030 for...more
5/2/2019
/ Broker-Dealer ,
CFTC ,
Commodities-Backed Swap ,
De Minimus Doctrine ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Investment Adviser ,
MSRB ,
Municipal Advisers ,
Pay-To-Play ,
Political Contributions ,
Securities and Exchange Commission (SEC) ,
Swap Dealers
The Office of the Clerk of the House and the Senate Office of Public Records recently amended the online federal Lobby Disclosure Act (LDA) filing system to provide fields for the new disclosures required by the Justice...more
The annual filing for state and local contractors required under New Jersey Chapter 271, known as Form BE, is due April 1, 2019....more
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
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
2/11/2019
/ CEOs ,
Corporate Entities ,
Directors ,
Disclosure Requirements ,
Filing Deadlines ,
PACs ,
Pay-To-Play ,
Political Contributions ,
Reporting Requirements ,
State and Local Government ,
State Contractors
On January 14, 2019, the New York state legislature passed A. 776 (the bill), which is designed to close the “LLC loophole” in state campaign contribution laws that treats LLCs as individuals, rather than corporations. New...more
With heightened attention to investment and depository rules as well as increased enforcement of federal and state pay-to-play rules, registered investment advisers (RIAs) and broker-dealers should address the unique legal...more
1/23/2019
/ Broker-Dealer ,
CFTC ,
Commodities ,
Compliance ,
Conflicts of Interest ,
Contingency Fees ,
Custody Rule ,
Federal Contractors ,
Financial Industry Regulatory Authority (FINRA) ,
Gifts ,
Investment Adviser ,
Investment Funds ,
Lobbying ,
MSRB ,
Municipal Securities Issuers ,
Pay-To-Play ,
Personal Liability ,
Political Contributions ,
Public Officials ,
Registered Investment Advisors ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
State and Local Government ,
State Contractors ,
Work Restrictions
On January 3, 2019, President Trump signed Senate Bill 2896, the Justice Against Corruption on K Street Act of 2018. Effective immediately, the act amends the Lobbying Disclosure Act of 1995 to require filers of LD-1...more
On Election Day in 2018, voters in three states approved amendments to rules involving a variety of ethics reforms involving lobbying, contributions and gifts....more
12/21/2018
/ Amended Legislation ,
Ballot Measures ,
Campaign Finance Reform ,
Charter Amendments ,
City Councils ,
Constitutional Amendment ,
Contribution Limits ,
Cooling-Off Rule ,
Ethics ,
General Assembly ,
Gifts ,
Lobbying ,
Local Ordinance ,
PACs ,
Political Contributions ,
Public Officials ,
State and Local Government ,
State Legislatures
The Federal Election Commission (FEC) has begun sending email communications to PACs and other committees to update their electronic filing passwords to comply with the FEC’s modernized electronic Password Assignment System....more
The Maryland State Board of Elections recently sent out a notice to pay-to-play law filers for whom it is missing an Initial Report....more
Below please find a discussion of recent lobbying developments in the District of Columbia and Boston, Massachusetts....more
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
11/14/2018
/ 501(c)(3) ,
501(c)(4) ,
Broker-Dealer ,
Campaign Finance Reform ,
CFTC ,
Conflicts of Interest ,
Consultants ,
Corporate Executives ,
Corporate Gifts ,
General Elections ,
Inauguration Committees ,
Lobbying ,
MSRB ,
Municipalities ,
PACs ,
Pay-To-Play ,
Political Contributions ,
Political Parties ,
Recount Committees ,
Securities and Exchange Commission (SEC) ,
Special Election ,
State and Local Government ,
State Elections ,
State Procurement Contracts ,
Transition Team
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
10/31/2018
/ Campaign Finance Reform ,
Corporate Contributions ,
Governor Cuomo ,
Lobbying ,
Lobbyists ,
New Legislation ,
PACs ,
Political Contributions ,
Popular ,
Public Employee Retirement Funds ,
Registration Requirement ,
Solicitation ,
State and Local Government ,
State Attorneys General
This mailing summarizes Missouri's new requirements for certain federal PACs and Maine's new requirement that lobbyists attend in-person anti-harassment training....more
Recently, the Municipal Securities Rulemaking Board (MSRB) noted in its quarterly compliance newsletter dated June 8, 2018 that it has “compliance concerns” regarding issuer-solicited charitable donations. The MSRB’s...more
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
Below, we have summarized recent developments regarding New York and Kansas lobbying requirements.
New York Lobbying Regulations -
On April 24, 2018, the New York Joint Commission on Public Ethics (JCOPE) voted to...more
5/16/2018
/ Disclosure Requirements ,
Equity Compensation ,
Ethics ,
Exemptions ,
Lobbying ,
Meals-Gifts-and Entertainment Rules ,
Reporting Requirements ,
Salespersons ,
Source of Payments ,
State and Local Government ,
State Procurement Contracts
The annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due March 30, 2018...more
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
On June 1, 2017, the state of New York’s Department of Economic Development (the department) issued draft forms and guidance to capture employee salary information from New York state contractors and subcontractors pursuant...more
6/13/2017
/ Bureau of Labor Statistics ,
Data Collection ,
Department of Economic Development ,
Disclosure Requirements ,
Draft Guidance ,
Executive Orders ,
Governor Cuomo ,
Public Comment ,
Public Works ,
State Contractors ,
Wage Statements
In January 2017, New York Gov. Andrew Cuomo issued Executive Order 162 (the order) requiring state contractors to disclose the salary paid to employees who work on the contract. The order attempts to address disparity in pay...more
On February 2, 2017, the Federal Election Commission (FEC) announced the new federal campaign contribution limits...more
On January 28, 2017, President Donald Trump signed an executive order titled “Ethics Commitments by Executive Branch Appointees” (the Order). This Order requires every full-time political appointee to sign an Ethics Pledge...more
2/7/2017
/ Barack Obama ,
Conflicts of Interest ,
Ethics ,
Executive Appointments ,
Executive Branch ,
Executive Orders ,
Former Employee ,
Gifts ,
Lobbying ,
Presidential Nominations ,
Trump Administration