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Political Contributions

Alston & Bird

Look Ahead to the Week of September 16: Will Congress Avoid a Shutdown?

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Both the House and Senate are in session this week to continue working on an agreement to fund the government beyond September 30. A stopgap measure proposed by Speaker Mike Johnson (R-LA) was pulled from consideration last...more

Nossaman LLP

Compliance Notes - Vol. 5, Issue 30

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Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more

Hogan Lovells

Election season brings political contribution rule to forefront for investment advisers

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It’s election season in America – and for investment advisers (registered or exempt), that means a renewed focus on Rule 206(4)-5, the political contributions rule, commonly known as the “pay-to-play rule.”...more

Wiley Rein LLP

Federal Electioneering Communication Rules Apply Starting September 6; May Impact Your Grassroots Lobbying

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The federal rules for electioneering communications kick in on September 6, 2024, and run through Election Day. These rules could affect your grassroots lobbying during this 60-day period if your ads are on radio or...more

Lowenstein Sandler LLP

SEC’s Pay-to-Play Crackdown: Settlement Sends Strong Message on Political Contributions

On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more

Skadden, Arps, Slate, Meagher & Flom LLP

Federal District Court Blocks Part of Ohio’s Foreign National Ban

As noted in our prior updates, on June 2, 2024, Ohio Gov. Mike DeWine signed into law H.B. 1, which prohibits foreign nationals from making or being solicited for political contributions in connection with Ohio state and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Reminder: Ohio’s Foreign National Ban Takes Effect September 1, 2024

As noted in our prior update, Ohio Gov. Mike DeWine signed H.B. 1 into law on June 2, 2024. H.B. 1 enacted a ban on foreign nationals making or being solicited for political contributions, defining foreign nationals to...more

Holtzman Vogel Baran Torchinsky & Josefiak

FEC Advisory Opinion Approves Federal Candidate Request to Add Super PAC to Joint Fundraising Committee

In Advisory Opinion 2024-07, the FEC approved a request made by Team Graham, the principal campaign committee of Senator Lindsey Graham, to add a Super PAC to an existing joint fundraising committee named Graham Majority...more

Nossaman LLP

Compliance Notes - Vol. 5, Issue 29

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Campaign Finance & Lobbying Compliance The Securities and Exchange Commission (SEC) has censured and fined a large, registered investment advisor, Obra Capital Management (Obra), $95,000 after learning an associate of the...more

Faegre Drinker Biddle & Reath LLP

Five Things to Know About Election Participation as November 5 Approaches

As general Election Day approaches, businesses, corporate executives and employees may take opportunities to become involved in the administrative and political processes central to determining the outcomes of local, state...more

Cooley LLP

What’s the impact of political spending from corporate treasuries?

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This new report, Corporate Underwriters: Where the Rubber Hits the Road, from the nonpartisan Center for Political Accountability, examines “the scope of corporate political spending and its impact on state and national...more

Katten Muchin Rosenman LLP

Selection of Gov. Walz as VP Harris's Running Mate Triggers Federal Pay-to-Play Restrictions on Investment Advisers and Other...

Vice President Kamala Harris's selection of Minnesota Gov. Tim Walz as her running mate imposes restrictions on campaign contributions to the Harris-Walz campaign by federally registered investment advisers (RIAs), exempt...more

McCarter & English, LLP

NJ ELEC Proposes New Reporting Requirements for IEs and SuperPACs

The Election Law Enforcement Commission (ELEC) proposed new rules this week (56 N.J.R. 1684(a) and 56 N.J.R. 1699(a)), finally implementing the legislature’s creation of reporting requirements for independent expenditure (IE)...more

K&L Gates LLP

Selection of Gov. Walz as VP Candidate Implicates SEC Pay-To-Play Rule

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Kamala Harris’ selection of Tim Walz as running mate for her presidential campaign has implications under the Securities and Exchange Commission’s (SEC) Rule 206(4)-5 under the Investment Advisers Act (SEC Pay-to-Play Rule)....more

Nossaman LLP

Compliance Notes - Vol. 5, Issue 28 - August 2024

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Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more

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

Goodwin

Minnesota Governor Tim Walz’s National Candidacy Raises Significant Pay-to-Play Rule Considerations for Certain Investment...

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On August 6, 2024, the Democratic nominee for President, Kamala Harris, chose Tim Walz, Governor of Minnesota, as her running mate. This selection presents important considerations vis à vis the “Pay-to-Play Rule” (Rule...more

Cooley LLP

Remember Pay-to-Play Rule Before Making US Election Campaign Contributions

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On August 6, 2024, US Vice President Kamala Harris announced Minnesota Gov. Tim Walz as her running mate for the 2024 presidential election. This selection triggers the political contributions rule under the Investment...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

WilmerHale

Pay-to-Play Alert: Implications of a Governor Joining a Presidential Ticket

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Vice President Kamala Harris’ selection of Minnesota Governor Tim Walz as her running mate highlights a wrinkle in Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule” or “Rule”) to which investment advisers should...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

Proskauer - The Capital Commitment

Harris's Running Mate Announcement: Pay-to-Play Rule Implications for Investment Advisers

As reported today, Vice President Harris has announced Tim Walz, the sitting governor of Minnesota, as her running mate. This announcement is particularly significant for investment advisers due to the Advisers Act Political...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

Venable LLP

FEC to Reconsider Regulation of Free Online Political Advocacy

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Since the early days of the internet, the Federal Election Commission (FEC) has kept its hands off of unpaid online political expression. Though federal campaign finance law generally treats paid online communications as...more

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