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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

"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

"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

"Maryland Again Proposes Regulations Regarding Its Pay-to-Play"

The Maryland State Board of Elections recently proposed new regulations regarding its pay-to-play reporting law. The public comment period closes on May 30, 2016. Below is a summary of the key provisions contained in the...more

"Maryland Amends Pay-to-Play Disclosure Law"

On April 26, 2016, Maryland Gov. Larry Hogan signed a bill amending the state’s pay-to-play disclosure law. The law currently requires that a filer include on its reports contributions made by or attributed to the filer...more

"Reminder: New Jersey Pay-to-Play Form BE Due on March 30, 2016"

This memorandum is to remind you that the annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due March 30, 2016. In particular, as we have described in previous mailings, this...more

"MSRB Amendments to Pay-to-Play Rule Will Take Effect in August 2016"

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

"New York JCOPE Issues Lobbying and Political Contributions Opinions"

On January 26, 2016, the New York Joint Commission on Public Ethics (JCOPE) approved two controversial advisory opinions. The first opinion clarified the scope of the state’s lobby law. Although most of the media coverage on...more

"Wisconsin Raises Contribution Limits, Eases Federal PAC Requirements"

On December 16, 2015, Wisconsin Gov. Scott Walker signed 2015 Wisconsin Act 117, which became effective January 1, 2016 (the Act). Among other changes, the Act eases the registration requirements for federal political action...more

"FEC Dismisses Wal-Mart PAC Match Case"

The Federal Election Commission (FEC) recently dismissed a complaint filed against Wal-Mart Stores, Inc. and its political action committee (PAC), finding that Wal-Mart's 2-for-1 PAC match program did not violate federal...more

"FINRA Submits Pay-to-Play Rule 2030 to SEC for Approval"

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

"MSRB Submits Pay-to-Play Rule G-37 Amendments to SEC for Approval"

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

"Reminder: Maryland Pay-to-Play Report Due November 30, 2015"

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 each...more

"Maryland Proposes Regulations Regarding Its Pay-to-Play Reporting Law"

The Maryland Board of Elections recently proposed regulations regarding its pay-to-play reporting law, which was amended earlier this year and now requires companies that have one or more Maryland state or local government...more

"Recent MSRB Developments: Board Proposes Amendments to Gift Rule G-20, Schedules Municipal Advisor Pilot Exam"

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

"First Semiannual Report Under New Maryland Pay-to-Play Law Due August 31, 2015"

This month, many companies that had not previously been required to file Maryland pay-to-play reports will be required to file with the Maryland State Board of Elections for the first time. Maryland’s pay-to-play reporting...more

"DC Circuit Unanimously Upholds Federal Contractor Contribution Ban"

On July 7, 2015, the federal circuit court for the District of Columbia sitting en banc issued a unanimous opinion upholding the federal contractor contribution ban against a constitutional challenge in the long-running case...more

"Department of Justice Secures Sentence in First Super PAC Coordination Case"

The Department of Justice recently concluded its first criminal prosecution of coordination between an independent-expenditure-only committee (super PAC) and a campaign committee. On June 12, 2015, the U.S. District Court for...more

"Maryland Making Additional Changes to Pay-to-Play Law"

Maryland's pay-to-play reporting law is set to undergo another round of changes later this year. The legislature has passed and the governor is expected to sign a bill that makes further changes to the regime that took effect...more

"Maryland Considering Pay-to-Play Cleanup Bill"

As detailed in our previous mailing, the changes to Maryland's pay-to-play reporting law that took effect in January have caused confusion and created significant challenges for companies doing business with Maryland state...more

"Disclosure of Political Contributions in Maryland, New Jersey, Pennsylvania and Rhode Island"

The following describes the reporting requirements under Maryland, New Jersey, Pennsylvania and Rhode Island laws, which require certain corporate entities to file reports regarding their business relationships with state...more

"Arkansas Bans Corporate Contributions to Candidates and Prohibits Gifts From Lobbyists"

On November 4, 2014, Arkansas voters passed a constitutional amendment extending term limits for state legislators and tightening ethics laws. The amendment prohibits candidates from accepting corporate contributions,...more

"State Parties File Legal Challenge Against SEC Rule 206(4)-5"

On August 7, 2014, the New York and Tennessee state Republican parties brought suit against the Securities and Exchange Commission (the SEC), challenging Rule 206(4)-5 (the rule). Specifically, the complaint seeks an...more

"Developments Regarding Aggregate Contribution Limits"

In the aftermath of the U.S. Supreme Court's decision in McCutcheon v. FEC, striking down the aggregate limits imposed on individual contributions under federal law, several jurisdictions also have taken steps to address...more

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