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
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
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
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
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
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
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
On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) and Municipal Securities Rulemaking Board (MSRB) submitted their respective pay-to-play rules to the Securities and Exchange Commission (SEC) for...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 each...more
The Maryland Board of Elections recently proposed regulations regarding its pay-to-play reporting law, which was amended earlier this year and now requires companies that have one or more Maryland state or local government...more
On August 25, 2015, the U.S. Court of Appeals for the District of Columbia Circuit upheld the D.C. District Court’s dismissal of a challenge to Securities and Exchange Commission (SEC) pay-to-play Rule 206(4)-5 (the Rule) and...more
This month, many companies that had not previously been required to file Maryland pay-to-play reports will be required to file with the Maryland State Board of Elections for the first time. Maryland’s pay-to-play reporting...more
On July 7, 2015, the federal circuit court for the District of Columbia sitting en banc issued a unanimous opinion upholding the federal contractor contribution ban against a constitutional challenge in the long-running case...more
7/15/2015
/ Affiliates ,
Anti-Corruption ,
Equal Protection ,
Federal Contractors ,
Federal Election Commission (FEC) ,
Fifth Amendment ,
First Amendment ,
Free Speech ,
Parent Corporation ,
Pay-To-Play ,
Political Contributions ,
SuperPACs
On May 1, 2015, Virginia Gov. Terry McAuliffe signed Senate Bill No. 1424 (the Bill). The Bill tightens restrictions on gifts, expands Virginia’s lobby law to cover attempts to obtain public contracts and adds a new...more
Maryland's pay-to-play reporting law is set to undergo another round of changes later this year. The legislature has passed and the governor is expected to sign a bill that makes further changes to the regime that took effect...more