Pay-To-Play

News & Analysis as of

"Maryland Making Additional Changes to Pay-to-Play Law"

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

Financial Services Weekly News Roundup - April 2015 #3

DOL Fiduciary Standard Proposal. The Department of Labor issued a notice of proposed rulemaking including a definition of the term “fiduciary,” a conflict of interest rule for retirement investments, new exemptions and...more

Contribution Caution: Mitigating Risks From Pay-To-Play

With the record-breaking campaign expenditures of the 2014 midterm elections behind us, and the 2016 campaign cycle already heating up, this is an ideal moment for investment advisers (including advisers to venture capital...more

"Maryland Considering Pay-to-Play Cleanup Bill"

As detailed in our previous mailing, the changes to Maryland's pay-to-play reporting law that took effect in January have caused confusion and created significant challenges for companies doing business with Maryland state...more

Upcoming New Jersey Pay-to-Play Filing: Due March 30, 2015

Any business entity holding contracts in 2014 that, in the aggregate, totaled more than $50,000 with state agencies, the legislature, counties, municipalities, school boards and fire districts in New Jersey must...more

Calling All New Jersey Government Contractors: The Clock is Ticking . . . Are you Ready for the March 30th Pay-to-Play Filing...

As we have previously discussed here, the New Jersey Pay-to-Play Annual Disclosure filing deadline is right around the corner. Any entity that received payments of $50,000 or more as a result of payments from a New...more

"Reminder: New Jersey Pay-to-Play Form BE Due on March 30, 2015"

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, 2015. In particular, as we have described in previous client alerts,...more

The Pay-to-Play Effect in New Jersey’s 2015 Statewide Elections

2015 is a unique year in New Jersey politics, as the New Jersey Assembly races are the only set of elections scheduled for this year that extend beyond county and municipal lines. Even the Assembly Members’ colleagues in the...more

Pay-to-Play Lessons from New Jersey’s State Investment Council Rules

New Jersey is often thought of as the “pay-to-play” state – primarily because we have five separate statewide pay-to-play prohibition laws in effect (covering state procurement, county procurement, local procurement, state...more

Atlantic County Freeholders Vote to Repeal Pay-to-Play Ordinance

Earlier this week, the Atlantic County Freeholders approved a measure that rolls back the County’s pay-to-play ordinance. New Jersey is home to an overlapping series of pay-to-play laws. Although there is a statewide law in...more

"Changes Likely in Campaign Finance, Pay-to-Play"

In recent months, aggregate political contribution limits have been the subject of dramatic change due to the McCutcheon decision as well as significant legislative modifications in the federal budget bill. Meanwhile,...more

Financial Services Weekly News Roundup - January 2015 #4

The CFTC Exercises Expanded Jurisdiction Over Retail Transactions in Physical Commodities. Title VII of the Dodd-Frank Act of 2010 amended the Commodity Exchange Act (CEA) to add new authority over certain leveraged,...more

Investment Management Update

SEC’s Focus in 2015 - On December 11, 2014, Mary Jo White, Chair of the U.S. Securities and Exchange Commission (SEC), gave a speech at The New York Times DealBook Opportunities for Tomorrow Conference that...more

"Disclosure of Political Contributions in Maryland, New Jersey, Pennsylvania and Rhode Island"

The following describes the reporting requirements under Maryland, New Jersey, Pennsylvania and Rhode Island laws, which require certain corporate entities to file reports regarding their business relationships with state...more

Will 2015 be The Year for Pay-to-Play Reform in New Jersey?

New Jersey’s pay-to-play laws have been described as a “dizzyingly complex array of statutes, ordinances and executive orders.” New Jersey currently has different laws in effect that apply to State government contracts, State...more

Bribery Is Not a Free Speech Right, Judge Says

In late 2012, a California district attorney’s office obtained an indictment charging 18 defendants, including school board members, administrators and contractors, with conspiracy, bribery, perjury, filing false gift reports...more

Investment Management Update

In This Issue: - SEC Announces First-of-Its-Kind Whistleblower Award To an Audit and Compliance Professional - SEC Issues No-Action Letter To Allow for Amendment of a Sub-Advisory Agreement without Shareholder...more

Pay-to-Play Ruling on Atlantic County Ordinance Turns on the Use of the Word “Any”

Atlantic County is one of three counties in the State of New Jersey with a stringent county pay-to-play ordinance in effect. Like many local pay-to-play ordinances, the Atlantic County ordinance covers contributions to...more

2014 SEC and FINRA Enforcement Actions Against Broker-Dealers and Investment Advisers

The sheer number of enforcement actions brought against broker-dealers and investment advisers makes it challenging to keep up. In this alert, we divide this year’s most important cases against broker-dealers and investment...more

"Increased Scrutiny for Government Contracts Under New Maryland Pay-to-Play Law"

Amendments to Maryland's pay-to-play law taking effect January 1, 2015, will impose burdensome contract reporting requirements for many companies. Although Maryland has had a pay-to-play law on the books for years, these...more

FINRA Solicitor Pay-to-Play Rules Complete IA & MSRB Suite

Last Friday, FINRA proposed pay-to-play prohibitions that parallel and implement similar Investment Adviser Act provisions in Rule 206(4)-5. That IA Rule prohibits investment advisers from paying third-parties to solicit...more

Financial Services Weekly News Roundup - November 2014 #3

FINRA Requests Comment on Proposed “Pay-to-Play” Rule - FINRA issued Regulatory Notice 14-50 requesting comment on proposed “pay-to-play” and related rules that would regulate in a manner similar to Rule 206(4)-5 under...more

Status Updates - November 2014 #8

..Pay to play. Attention, marketing professionals: The free ride that Facebook has been giving to advertisers is coming to end. We’ve recently discussed Facebook’s recently ban on “like” gating. Now, inspired by its users’...more

SEC Obtains Over $4 Billion for Securities Violations in 2014

Following the end of its fiscal year on September 30, the Securities and Exchange Commission (SEC) reported that FY 2014 was notable not only for the record number of enforcement actions filed, but for the wide range of...more

"Post-Election Issues (Inaugurations, Transitions and Special Elections)"

Now that the 2014 mid-term elections are over, we must contend with special legal issues that arise from contributions to federal, state, or local inaugural or transition committees, paying for inaugural events and...more

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