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
On January 14, 2019, the New York state legislature passed A. 776 (the bill), which is designed to close the “LLC loophole” in state campaign contribution laws that treats LLCs as individuals, rather than corporations. New...more
On Election Day in 2018, voters in three states approved amendments to rules involving a variety of ethics reforms involving lobbying, contributions and gifts....more
12/21/2018
/ Amended Legislation ,
Ballot Measures ,
Campaign Finance Reform ,
Charter Amendments ,
City Councils ,
Constitutional Amendment ,
Contribution Limits ,
Cooling-Off Rule ,
Ethics ,
General Assembly ,
Gifts ,
Lobbying ,
Local Ordinance ,
PACs ,
Political Contributions ,
Public Officials ,
State and Local Government ,
State Legislatures
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
Below please find a discussion of recent lobbying developments in the District of Columbia and Boston, Massachusetts....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
Below, please find a discussion of recent developments in New Hampshire
and New York.
New Hampshire
The New Hampshire Office of the Attorney General recently has indicated that, going forward, it will interpret state...more
10/31/2018
/ Campaign Finance Reform ,
Corporate Contributions ,
Governor Cuomo ,
Lobbying ,
Lobbyists ,
New Legislation ,
PACs ,
Political Contributions ,
Popular ,
Public Employee Retirement Funds ,
Registration Requirement ,
Solicitation ,
State and Local Government ,
State Attorneys General
This mailing summarizes Missouri's new requirements for certain federal PACs and Maine's new requirement that lobbyists attend in-person anti-harassment training....more
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
Below, we have summarized recent developments regarding New York and Kansas lobbying requirements.
New York Lobbying Regulations -
On April 24, 2018, the New York Joint Commission on Public Ethics (JCOPE) voted to...more
5/16/2018
/ Disclosure Requirements ,
Equity Compensation ,
Ethics ,
Exemptions ,
Lobbying ,
Meals-Gifts-and Entertainment Rules ,
Reporting Requirements ,
Salespersons ,
Source of Payments ,
State and Local Government ,
State Procurement Contracts
On April 6, 2017, we sent a mailing alerting you to the fact that the Republican Attorneys General Association had registered its main account — the general operating account — as a political committee with the Commonwealth...more
On June 1, 2017, the state of New York’s Department of Economic Development (the department) issued draft forms and guidance to capture employee salary information from New York state contractors and subcontractors pursuant...more
6/13/2017
/ Bureau of Labor Statistics ,
Data Collection ,
Department of Economic Development ,
Disclosure Requirements ,
Draft Guidance ,
Executive Orders ,
Governor Cuomo ,
Public Comment ,
Public Works ,
State Contractors ,
Wage Statements
In January 2017, New York Gov. Andrew Cuomo issued Executive Order 162 (the order) requiring state contractors to disclose the salary paid to employees who work on the contract. The order attempts to address disparity in pay...more
On January 28, 2017, President Donald Trump signed an executive order titled “Ethics Commitments by Executive Branch Appointees” (the Order). This Order requires every full-time political appointee to sign an Ethics Pledge...more
2/7/2017
/ Barack Obama ,
Conflicts of Interest ,
Ethics ,
Executive Appointments ,
Executive Branch ,
Executive Orders ,
Former Employee ,
Gifts ,
Lobbying ,
Presidential Nominations ,
Trump Administration
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
On November 16, 2016, a spokesman for President-elect Donald Trump announced on a conference call that Trump’s transition team is imposing certain restrictions on lobbyists who are appointed to the team. (The spokesman said...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
On Wednesday, August 24, 2016, New York Gov. Andrew Cuomo signed into law an ethics package (the Bill) including campaign finance, lobbying and disclosure amendments. Below, we briefly summarize key provisions that (i) expand...more
The Financial Industry Regulatory Authority (FINRA) has filed a regulatory notice seeking comment on proposed changes to its gift, business entertainment and noncash compensation rules for broker-dealers. Comments must be...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