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
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Draft Guidance ,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 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
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
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
On November 16, 2016, a spokesman for President-elect Donald Trump announced on a conference call that Trump’s transition team is imposing certain restrictions on lobbyists who are appointed to the team. (The spokesman said...more
We wish to remind you that companies with one or more Maryland state or local government contracts worth at least $200,000 are required to file semiannual pay-to-play reports with the Maryland State Board of Elections by May...more
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
11/14/2016
/ CFTC ,
Corporate Executives ,
Disclosure Requirements ,
Financial Institutions ,
Inauguration Committees ,
Lobbying ,
MSRB ,
PACs ,
Pay-To-Play ,
Political Contributions ,
Public Employees ,
Recount Committees ,
Securities and Exchange Commission (SEC) ,
Special Election ,
State and Local Government
On October 24, 2016, the Financial Industry Regulatory Authority (FINRA) announced in Regulatory Notice 16-40 that its pay-to-play and related recordkeeping rules, FINRA Rules 2030 and 4580, will take effect on August 20,...more
On Wednesday, August 24, 2016, New York Gov. Andrew Cuomo signed into law an ethics package (the Bill) including campaign finance, lobbying and disclosure amendments. Below, we briefly summarize key provisions that (i) expand...more
The Financial Industry Regulatory Authority (FINRA) has filed a regulatory notice seeking comment on proposed changes to its gift, business entertainment and noncash compensation rules for broker-dealers. Comments must be...more
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 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
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
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
According to news reports, the watchdog group Public Citizen will reprise its “bird-dogging” campaign to shed light on whether events held during the 2016 presidential nominating conventions violate applicable laws. As it has...more
On June 21, 2016, the Financial Industry Regulatory Authority extended the time for the Securities and Exchange Commission (SEC) to act on Proposed Rules 2030 and 4580 (the Proposed Rules) to August 26, 2016. The Proposed...more
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
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
On March 29, 2016, the Securities and Exchange Commission (SEC) filed an order instituting proceedings (the Order) intended to determine whether to approve or disapprove Financial Industry Regulatory Authority (FINRA)...more
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
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