Now that the 2024 election has passed, individuals and organizations must be mindful of special legal issues that arise from contributions made to, and expenses incurred for, federal, state or local inaugural or transition...more
12/2/2024
/ Biden Administration ,
Broker-Dealer ,
Corporate Executives ,
Corporate Governance ,
Employees ,
Employer Liability Issues ,
Federal Contractors ,
Financial Institutions ,
General Services Administration (GSA) ,
Inaugrations ,
Inauguration Committees ,
Investment Adviser ,
Lobbying Disclosure Act ,
Lobbyists ,
PACs ,
Pay-To-Play ,
Political Campaigns ,
Political Contributions ,
Presidential Elections ,
Public-Private Entities ,
Securities and Exchange Commission (SEC) ,
State and Local Government ,
Transition Team ,
Transitional Arrangements ,
Trump Administration
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
8/9/2024
/ Campaign Finance Reform ,
CFTC ,
Financial Industry Regulatory Authority (FINRA) ,
Kamala Harris ,
MSRB ,
Pay-To-Play ,
Political Campaigns ,
Political Candidates ,
Political Contributions ,
Presidential Elections ,
Securities and Exchange Commission (SEC)
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
8/7/2024
/ Campaign Finance Reform ,
CFTC ,
Financial Industry Regulatory Authority (FINRA) ,
Kamala Harris ,
MSRB ,
Pay-To-Play ,
Political Campaigns ,
Political Candidates ,
Political Contributions ,
Presidential Elections ,
Securities and Exchange Commission (SEC)
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
7/29/2024
/ Biden Administration ,
Campaign Funds ,
CFTC ,
Financial Industry Regulatory Authority (FINRA) ,
Kamala Harris ,
Legislative Agendas ,
MSRB ,
Pay-To-Play ,
Political Campaigns ,
Presidential Elections ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
On April 15, 2024, the U.S. Securities and Exchange Commission (SEC) censured and imposed a $60,000 civil penalty on Wayzata Investment Partners LLC (Wayzata) for violating SEC Rule 206(4)-5 (the Pay-to-Play Rule). Under the...more
4/29/2024
/ Campaign Contributions ,
Civil Monetary Penalty ,
Compensation ,
Fund Managers ,
Government Entities ,
Investment Adviser ,
Investment Management ,
New Rules ,
PACs ,
Pay-To-Play ,
Political Campaigns ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
State and Local Government
With the election season in full swing, there is increased interest in political contributions. It is important for financial institutions subject to SEC Rule 206(4)-5 for investment advisers, CFTC Rule 23.451 for swap...more
Florida Gov. Ron DeSantis filed paperwork on May 24, 2023, to run for president in the 2024 election. In light of his announcement, it is important to keep in mind that contributions made to or solicited on behalf of Gov....more
Nonprofits organized under Section 501(c)(4) of the Internal Revenue Code (IRC) play an ever-growing role in politics and public policy advocacy. These 501(c)(4) organizations may accept unlimited corporate and personal...more
In light of recent news reports on stock trades made by certain senators after they received intelligence briefings on the COVID-19 crisis, we want to remind you of the provisions of the Stop Trading on Congressional...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
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
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
On June 21, 2016, the Financial Industry Regulatory Authority extended the time for the Securities and Exchange Commission (SEC) to act on Proposed Rules 2030 and 4580 (the Proposed Rules) to August 26, 2016. The Proposed...more
On February 17, 2016, the Municipal Securities Rulemaking Board (MSRB) announced in Regulatory Notice 2016-06 that its draft amendments to Rule G-37 on political contributions, and related amendments to Rules G-8 and G-9 on...more
On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) submitted Rules 2030 and 4580 (the Draft Rules) to the Securities and Exchange Commission (SEC) for approval. The Draft Rules set forth pay-to-play...more
On December 16, 2015, the Municipal Securities Rulemaking Board (MSRB) filed its draft amendments to Rule G-37 on political contributions (the Draft Rule) with the Securities and Exchange Commission (SEC). The Draft Rule...more
On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) and Municipal Securities Rulemaking Board (MSRB) submitted their respective pay-to-play rules to the Securities and Exchange Commission (SEC) for...more
This is to update you about recent Municipal Securities Rulemaking Board (MSRB) actions.
SEC Approves MSRB's Proposed Amendments to MSRB Rule G-20 and Related Recordkeeping -
On November 6, 2015, the Securities and...more
SEC Municipal Advisor Examination Initiative -
The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) recently updated the National Association of Municipal Advisors on...more
Proposed Amendments to MSRB Rule G-20 -
On September 2, 2015, the MSRB filed with the Securities and Exchange Commission (SEC) proposed amendments to Rule G-20, with conforming changes to related recordkeeping Rules G-8...more
On August 25, 2015, the U.S. Court of Appeals for the District of Columbia Circuit upheld the D.C. District Court’s dismissal of a challenge to Securities and Exchange Commission (SEC) pay-to-play Rule 206(4)-5 (the Rule) and...more
On August 6, 2015, the Securities and Exchange Commission (“SEC”) filed an Order instituting proceedings intended to determine whether to approve or disapprove Proposed Municipal Securities Rulemaking Board (“MSRB”) Rule G-42...more
On June 25, 2015, the Securities and Exchange Commission (SEC) issued Release No. IA-4129 setting July 31, 2015, as the compliance date for SEC Rule 206(4)-5's placement agent restrictions on using third-party and affiliated...more