Political Contributions

News & Analysis as of

Court Dismisses Challenge to New York Donor Disclosure Requirement

On August 29, 2016, the United States District Court for the Southern District of New York dismissed in its entirety a complaint against the New York Attorney General filed by Citizens United and Citizens United Foundation,...more

Investment Management Update

The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...more

California Ballot 2016: Pros and Cons of Props 57-61

This is the second post in our California Ballot 2016 series – providing the “nutshell” versions of each of the 17 state-wide measures voters must decide in November. Please refer to our first post in the series: Props 51-56,...more

SEC Approves FINRA Pay-to-Play Rule

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

Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide

As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more

Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide

As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more

The Ethics Advisor: 13 Things You Need to Know About Campaign Restrictions

Ya no aguanto. (I can’t take it anymore.) Can we POSSIBLY get away from campaigning and politics for a little while? Sorry folks, pero, no. Puntada. (but, no. Period.) With the 2016 Presidential election campaign in...more

Impact of Pay-to-Play Rules in the 2016 Election Cycle

The federal Pay-to-Play Rules may impact campaign contributions in the 2016 election and, in particular, campaign contributions to a major party’s presidential campaign. Financial institutions that do business with, or seek...more

Election Year Reminders: Cautionary Guidance for Employers That Sponsor PAC/Charity Matching Programs

As we head into the final stretch of the presidential election cycle, employers — both for-profit and nonprofit — may wish to offer employee programs to encourage civic participation, including facilitating political...more

"California Treasurer Announces New Pay-to-Play Policy for Municipal Bond Underwriters"

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

2016 Presidential Conventions: What Congress Members and Attendees Need to Know

With the 2016 presidential conventions underway and as the November presidential election draws near, this post is part of a series on what different entities and groups need to know about their political activity as the 2016...more

2016 Presidential Conventions: What Delegates and Attendees Need to Know

With the 2016 presidential conventions underway and as the November presidential election draws near, this post is part of a series on what different entities and groups need to know about their political activity as the 2016...more

Political Contributions to the Donald J. Trump Presidential Campaign Might Adversely Affect Advisers That Have or Are Seeking...

Last week, Donald J. Trump, the Republican nominee for U.S. president, selected Governor Mike R. Pence of Indiana as his running mate for vice president. The selection of Governor Pence might have implications under the SEC’s...more

"Contributions to Trump/Pence Campaign Are Subject to Pay-to-Play Rules"

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

"Supreme Court Vacates Corruption Conviction of Former Virginia Governor"

On June 27, 2016, the United States Supreme Court unanimously vacated the conviction of former Virginia Gov. Bob McDonnell on corruption charges and remanded the case for retrial. As discussed below, the impact of the...more

Investment Management Update

SEC Enforcement Action against Private Equity Fund Adviser - On June 1, 2016, the SEC announced that a private equity fund adviser and its principal owner agreed to pay more than $3.1 million to settle SEC charges that,...more

Independence, Coordination & Super PACs in the 2016 Presidential Election

On July 4th we celebrated Independence Day. In the next three weeks, the Nation will focus on the Republican and Democratic National Conventions. We cannot turn on the television without catching a political ad....more

Raise Your Hand if You Are Contributing—FEC Dismissal of Charges Offers Insight about Coercing Contributions to Your PAC

As we approach the November elections, it may be time to replenish your corporate PAC, also known as your Separately Segregated Fund (SSF). In early June, the Chairman and two commissioners of the Federal Election Commission...more

New York State Announces Broad Set of Ethics and Campaign-Finance Reforms

Late last week, New York Governor Andrew Cuomo and State legislative leaders announced agreement on a broad set of ethics and campaign-finance reforms focused on increased disclosure, transparency, and public trust....more

Corporate Political Activity, Reputational Risk Management and the 2016 Federal Election

As the 2016 presidential primary season concludes, we are quickly approaching the summer conventions and the November presidential election. With the political contests becoming more heated, this post is part of a new series...more

Connecticut Stands Firm to Enforce Pay-to-Play Against State Party Committee

In announcing a $325,000 settlement with the Connecticut Democratic State Central Committee, the State Elections Enforcement Commission (“SEEC”) has made clear that it will not tolerate efforts to circumvent the state’s...more

New Jersey’s 2016 Primary: Potential Pitfalls of Per Election & Pay-to-Play Limits

New Jersey held its 2016 primary election on Tuesday, June 7, 2016. While most of the focus has been on the presidential primary, individuals and entities that contribute in connection with New Jersey state and local...more

501(c)(3)s and the 2016 Federal Election: Do You Know What Your Employees Are Doing?

As the 2016 presidential primary season proceeds, we are quickly approaching the summer conventions and the November presidential election. With the political contests becoming more heated, this post is part of a new series...more

Corporations and the 2016 Federal Election: Do You Know What Your Employees Are Doing?

As the 2016 presidential primary season proceeds, we are quickly approaching the summer conventions and the November presidential election. With the political contests becoming more heated, this post is part of a new series...more

Maryland Just Can’t Help Itself When It Comes to Pay-to-Play Revisions

Avid followers of the Pay to Play Law Blog know how active the State of Maryland has been over the past few years with regard to the amendment and revision of its pay-to-play framework for those contracting with or otherwise...more

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