News & Analysis as of

Pay-To-Play

BCLP

Missouri House of Representatives Passes HB 575, Imposing Residency Requirements and Banning Per-Signature Payments for Initiative...

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Today, the Missouri House of Representatives passed House Bill 575, which contains two new provisions applicable to statewide initiative petition circulators....more

Skadden, Arps, Slate, Meagher & Flom LLP

Reminder: New Jersey Pay-to-Play Form BE Due March 31, 2025

The annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due March 31, 2025. As we have described in previous client alerts, this report must be filed by a business entity if it...more

McCarter & English, LLP

Compliance Note No. 11: NJ Annual Business Entity Disclosure Reports

Businesses that received at least $50,000 in revenue during the 2024 calendar year through New Jersey government contracts must file an Annual Business Entity Disclosure report with the New Jersey Election Law Enforcement...more

Brownstein Hyatt Farber Schreck

California Refines Political Giving Rules to Limit “Pay to Play” Concerns

Under SB 1243, attorneys, architects, engineers, planners, political consultants, and other “agents” are absolutely barred from making political contributions to elected and appointed officials while a decision is pending and...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

The following summarizes periodic pay-to-play reporting requirements under laws in Illinois, Maryland, New Jersey, Pennsylvania, Philadelphia and Rhode Island. Certain companies must file reports regarding their business...more

Wiley Rein LLP

FEC Raises Individual Federal Contribution Limits for 2025-2026 Election Cycle

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As published in the Federal Register on January 30, 2025, the Federal Election Commission (FEC) has followed the statutory dictates and raised the federal individual contribution limits to account for inflation. The new...more

Morrison & Foerster LLP

Open Banking Update: CFPB Recognizes First Open Banking Standard-Setting Body

On January 8, 2025, the Consumer Financial Protection Bureau (CFPB) issued a decision and order approving the application of Financial Data Exchange, Inc. (FDX) for recognition as a standard-setting body (SSB) under the...more

Morrison & Foerster LLP

When Your Life Sciences Are on the Line: FCPA Enforcement

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Morrison Foerster partners Kate Driscoll and Nate Mendell, both former federal prosecutors and members of the firm’s Investigations + White Collar Defense Group, hosted the seventh episode of When Your Life Sciences Are on...more

Nossaman LLP

Important Updates to California’s “Pay to Play” Contribution Bans Go into Effect in 2025

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More Action By the FPPC Expected - Introduction to the Levine Act - In 2022, California lawmakers expanded the Levine Act (Government Code Section 84308) to apply to local elected officials....more

White & Case LLP

SEC Enforcement Year-End Overview

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2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more

Proskauer Rose LLP

Eight Enforcement Trends That Likely Will End Under a Trump SEC

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The Voting Record and Public Statements of the Commissioners Provide a Roadmap - There has been much speculation on what SEC enforcement will look like under a new administration, especially now that President-elect Donald...more

Katten Muchin Rosenman LLP

Not-So-New News Flash? Change in Administration Ushers Back a Deregulatory Agenda – Implications for Investment Advisers

While most industry observers agree that the transition to the new presidential administration will bring with it a deregulatory agenda, members of Katten’s asset management regulatory team compiled their Top-5 Holiday Wish...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Post-Election Considerations for Inaugurations, Transitions, Special Elections and Personnel Entering or Leaving Government

Now that the 2024 election has passed, individuals and organizations must be mindful of special legal issues that arise from contributions made to, and expenses incurred for, federal, state or local inaugural or transition...more

Wiley Rein LLP

Contributing to Inaugurals, Transitions, or Candidate Debt Retirement This Year? Here’s How to Reduce Your Legal Risk.

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While this November’s election is over, many organizations remain politically active in between the general election and the time that newly elected and re-elected officials take office. In fact, many individuals and...more

Proskauer Rose LLP

Funds in Focus: Top SEC Exam and Enforcement Trends

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The Securities and Exchange Commission’s (“SEC”) National Examination Program is designed to improve compliance, prevent fraud, monitor risk and inform policy. It is also a consistent source of referrals to the SEC’s Division...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Oct. 1 Quarterly Review

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

McCarter & English, LLP

Compliance Note - October 11 2024

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Does your company have a government contract or plan to seek business with a government entity in New Jersey? If so, it is essential to understand the rules that could result in the breach of an existing contract and the...more

Akin Gump Strauss Hauer & Feld LLP

California to Increase State Pay-to-Play Limit in 2025

Last week, California Governor Gavin Newsom signed a new law that amends key provisions of the state’s pay-to-play statute which limits political contributions by state and local contractors and their agents....more

Best Best & Krieger LLP

California Updates Levine Act “Pay to Play” Campaign Contribution Restrictions for 2025

Governor Newsom signed a bill on September 30 that will update the State’s “pay to play” campaign contribution law commonly known as the “Levine Act” starting on January 1, 2025. The Levine Act currently prohibits agency...more

Seward & Kissel LLP

A Refresher on the SEC’s Pay to Play Rule

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In the midst of a national election cycle, now is a good time for investment advisers to refresh their understanding on the SEC’s Pay to Play Rule (the “Rule”) and related SEC staff guidance As demonstrated by a number of...more

WilmerHale

Pay-to-Play Alert: The Importance of Vetting the Specifics of a Political Contribution

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As explained in our prior client alert, the presence of a sitting state-level elected official—Minnesota Governor Tim Walz—on a presidential ticket should increase vigilance among investment advisers regarding the potential...more

Lowenstein Sandler LLP

SEC’s Pay-to-Play Crackdown: Settlement Sends Strong Message on Political Contributions

On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for August 2024

More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more

Nossaman LLP

Compliance Notes - Vol. 5, Issue 29

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Campaign Finance & Lobbying Compliance The Securities and Exchange Commission (SEC) has censured and fined a large, registered investment advisor, Obra Capital Management (Obra), $95,000 after learning an associate of the...more

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's August 2024 Round-Up

Eighth Circuit Invalidates Missouri's Two-Year Lobbying Ban for Former Legislators and Staffers - The Eighth Circuit Court of Appeals invalidated a Missouri state constitutional amendment that imposed a two-year lobbying...more

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