The next quarterly update required under the Illinois pay-to-play law is due August 14, 2021. As described in earlier mailings, the Illinois pay-to-play law requires many companies with aggregate annual state bids, proposals...more
The annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due March 30, 2021. As we have described in previous mailings, this report must be filed if a business entity received...more
The following summarizes the periodic reporting requirements under Illinois, Maryland, New Jersey, Pennsylvania, Philadelphia and Rhode Island laws for certain corporate entities to file reports regarding their business...more
The next quarterly update required under the Illinois pay-to-play law is due August 14, 2020. As described in earlier mailings, this law requires many companies with aggregate annual state bids, proposals and contracts...more
Below, please find a summary of notable political law developments in New York, Texas and the city of Los Angeles.
New York State Reduces Contribution Limits Beginning in November 2022 -
Late last year, the New York...more
2/27/2020
/ Campaign Contributions ,
Campaign Finance Reform ,
City of Los Angeles ,
City Planning Departments ,
Contribution Limits ,
Ethics Commission ,
General Elections ,
Land Developers ,
Lobbying ,
Local Ordinance ,
Pay-To-Play ,
Political Contributions ,
Primary Elections ,
Public Officials ,
State and Local Government ,
State Elections ,
State Legislatures
The following describes periodic pay-to-play reporting requirements under Illinois, Maryland, New Jersey, Pennsylvania and Rhode Island laws. Certain corporate entities must file reports regarding their business relationships...more
2/12/2020
/ Affiliates ,
Campaign Finance Reform ,
Corporate Entities ,
Disclosure Requirements ,
Filing Requirements ,
PACs ,
Pay-To-Play ,
Political Campaigns ,
Political Contributions ,
Regulatory Requirements ,
Reporting Requirements
The next quarterly update for state contractors that is required under the Illinois pay-to-play law is due August 14, 2019. As described in earlier mailings, the state’s pay-to-play law requires a company with aggregate...more
On June 18, 2019, the U.S. Court of Appeals for the District of Columbia Circuit (the court) dismissed a challenge to Financial Industry Regulatory Authority (FINRA) pay-to-play Rule 2030 (the rule) brought by the New York...more
6/28/2019
/ Administrative Authority ,
Arbitrary and Capricious ,
Campaign Contributions ,
Corruption ,
Dismissals ,
Federal Contractors ,
Federal Election Campaign Act ,
Financial Industry Regulatory Authority (FINRA) ,
First Amendment ,
Government Entities ,
Important Governmental Objectives ,
Investment Adviser ,
Pay-To-Play ,
Political Contributions ,
Political Parties ,
Preemption ,
Securities and Exchange Commission (SEC) ,
Solicitation ,
Standing
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 annual filing for state and local contractors required under New Jersey Chapter 271, known as Form BE, is due April 1, 2019....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
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
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
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
The annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due March 30, 2018...more
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
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