News & Analysis as of

Pay-To-Play MSRB

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Presidential Election Campaign Donations May Trigger Investment Adviser “Pay to Play” Rule

Overview: Investment advisers that seek to manage public money need to consider the SEC’s “pay to play” rule, which restricts election-related contributions by the firms or their “covered associates” to elected state...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Presidential Election Alert: Harris-Walz Campaign Now in General Election Period

On August 6, 2024, Vice President Kamala Harris accepted the Democratic nomination for president and announced Governor Tim Walz as her running mate. This marked the end of the primary election period for the Harris/Walz...more

Akin Gump Strauss Hauer & Feld LLP

Walz’s Addition to Democratic Ticket Raises Pay-to-Play Issues for Donors in the Financial Industry

Employees of investment advisers must consider whether their employer is managing or seeking to manage public funds in Minnesota before donating to the Harris-Walz campaign this election season. Vice President Harris’...more

Dechert LLP

Contributions to the Harris Presidential Campaign Subject to Federal "Pay-to-Play" Rules

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Vice President Kamala Harris announced Minnesota Governor Tim Walz as her running mate for the upcoming Presidential election. Because Governor Walz is an “official” for purposes of the SEC’s pay-to-play rule under the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Harris/Walz Campaign Are Subject to Pay-to-Play Rules

Vice President Kamala Harris announced today that she has selected Minnesota Gov. Tim Walz as her vice presidential running mate in her bid for president. Contributions to the Harris/Walz campaign are now subject to the...more

Wiley Rein LLP

Pay-to-Play Rules Enter the 2024 Presidential Campaign

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On August 6, Vice President Kamala Harris selected Governor Tim Walz of Minnesota as her Vice-Presidential running mate for the 2024 general election. Since Governor Walz is a state official, his selection for the ticket...more

Skadden, Arps, Slate, Meagher & Flom LLP

Presidential Election Alert: Campaign Finance Implications for Harris for President

On July 21, 2024, President Joseph Biden announced that he was ending his bid for reelection and instead endorsing Vice President Kamala Harris for president. A presumptive nominee withdrawing so close to the party convention...more

Wiley Rein LLP

Mind Your Ps (and Qs): Pay-to-Play and Procurement Lobbying for the Government Contractor

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If there are two political law compliance issues that perennially bedog federal, state, and local government contractors, it is the myriad of state and local pay-to-play laws and procurement lobbying laws. In the FAQs below,...more

Wiley Rein LLP

Pay-to-Play Compliance Down the Stretch in the 2023 Elections

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The 2023 elections are a little over a month away, and hopefully, if your corporation holds or seeks state and local government business, you have been regularly reminding your directors, officers, and other employees about...more

Akin Gump Strauss Hauer & Feld LLP

North Dakota Governor Seeks GOP Presidential Nomination: Pay-to-Play Considerations

North Dakota Governor Doug Burgum announced his candidacy for the 2024 GOP Presidential nomination on June 7, 2023.  His announcement, on the heels of Florida Governor DeSantis’ May 24 announcement, highlights the urgent need...more

Akin Gump Strauss Hauer & Feld LLP

Pay-to-Play Laws May Hinder Governor DeSantis’ Presidential Fundraising

After recently signing legislation allowing state officeholders to run for president without resigning from office, Florida Gov. Ron DeSantis has officially entered the 2024 presidential race. As a sitting governor, DeSantis...more

Proskauer - The Capital Commitment

U.S. Supreme Court Denies Bid to Review Dismissal of Challenge to Pay-To-Play Rule

On January 13, 2020, the United States Supreme Court denied certiorari to an appeal of a June 2019 order from the United States Court of Appeals for the D.C. Circuit that dismissed an action seeking to invalidate certain...more

Pillsbury Winthrop Shaw Pittman LLP

Text, Alexa, Bitcoin—Technology Makes Political Contributions Easier

Is your political compliance program ready for the 2020 election season? With the 2020 election season underway, now is a good time to make certain your internal policies and procedures address applicable campaign...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Update for Financial Institutions on Presidential Candidates Covered Under Federal Pay-to-Play Rules

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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Political Law: What to Consider When Providing Investment Fund Services to US State and Local Government...

With heightened attention to investment and depository rules as well as increased enforcement of federal and state pay-to-play rules, registered investment advisers (RIAs) and broker-dealers should address the unique legal...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

MSRB Notes Compliance Risks of Issuer-Solicited Charitable Donations

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

Burr & Forman

6th Circuit Rejects GOP Suit Against MA Pay-to-Play Rule

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The Sixth Circuit Court of Appeals dismissed a suit by the Tennessee, Georgia and New York Republican parties challenging the constitutionality of an MSRB extending pay-to-play prohibition to municipal advisors. The Court...more

Dechert LLP

UPDATE: Continued Regulatory Focus on US Political Contributions

Dechert LLP on

Recent actions by financial industry regulators, including the Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority, Inc. (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”),...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Developments: Applying Federal Pay-to-Play Rules to Trump/Pence Inaugural and Transition Committees"

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

Burr & Forman

6th Circuit Orders Pay-to-Play Challenge to Merits Panel

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The Sixth Circuit this week declined the SEC’s request to dismiss a Constitutional challenge to the new MSRB pay-to-play rules. Instead, the Court ordered the case to a merits panel for consideration. The Republican parties...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Post-Election Issues"

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

Skadden, Arps, Slate, Meagher & Flom LLP

"FINRA Pay-to-Play Rule Effective August 20, 2017"

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

Clark Hill PLC

The Municipal Advisor Regulatory Framework - Where We Are and Where to Next

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On September 19, 2016, the Municipal Securities Rulemaking Board ("MSRB") advised Congress that it had "just concluded development of a core regulatory framework for municipal advisors." This by no means signals a significant...more

Burr & Forman

6th Circuit Orders Pay-to-Play Challenge to Merits Panel

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The Sixth Circuit this week declined the SEC’s request to dismiss a Constitutional challenge to the new MSRB pay-to-play rules.  Instead, the Court ordered the case to a merits panel for consideration.  The Republican parties...more

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