After a surprisingly active 2017, the Federal Election Commission’s enforcement efforts have slowed noticeably in the early months of 2018. In February, former Commission Lee Goodman’s departure from the agency left the Commission with only four members. While the remaining Commissioners can still form a quorum, unanimity is required for
Continue Reading Covington Publishes Update on Recent FEC Enforcement Activity

Robert Lenhard
Robert Lenhard has helped guide decision makers in corporations, trade associations, and advocacy groups on complying with the laws regulating political activity for over 20 years. As a senior member of the firm’s Election and Political Law Practice Group, he provides compliance advice relating to federal and state campaign finance, lobbying, pay-to-play, and government ethics laws. As an advocate, counselor, and regulator, Mr. Lenhard brings a depth of experience on matters that involve legal as well as political risk.
Bob led Covington’s representation of the Biden for President campaign, the Super PAC supporting President Obama’s re-election, as well as several prominent professional sports leagues, pharmaceutical manufacturers, technology companies, advocacy groups, and trade associations.
Prior to joining the firm in 2008, Mr. Lenhard served as Chairman of the Federal Election Commission (FEC) in 2007 and Vice Chairman of the agency in 2006, during which time the agency handled over 10 major rulemakings, had among its most productive years in enforcement and audit, and adopted several reforms to the enforcement process. Mr. Lenhard also led the Presidential Transition Team that reviewed the FEC for the incoming Obama administration in 2008-2009.
Mr. Lenhard is frequently quoted in the press, has lectured at major law schools, and Before his service to the FEC, Mr. Lenhard provided legal advice to labor organizations active in the political process at the federal, state, and local levels. Mr. Lenhard also was involved in litigation in the Florida trial and appellate courts over the counting of absentee ballots in Seminole County, Florida in 2000.
Robert Lenhard is a member of the firm’s Election and Political Law Practice Group and advises corporations, trade associations, not-for-profit organizations, and high-net-worth individuals on compliance with federal and state campaign finance, lobbying, and government ethics laws.
Mr. Lenhard routinely assists clients in establishing and operating federal and state PACs, compliance programs associated with campaign finance and pay-to-play laws; advises advocacy groups and their donors; conducts compliance trainings and audits of federal and state lobbying and political programs; and counsels clients on compliance with congressional gift and travel rules. According to Chambers, sources report: "He is strategic and always sees the big picture. He is a great person who provides excellent non-legal counsel as well."
Bank Loans to Federal Candidates
FEC audit reports often address obscure topics, but today one touched on an important issue for banks. At an open meeting, a majority of FEC Commissioners would not support a staff recommendation that a bank violated the campaign finance laws when it made a loan based on collateral that was…
Continue Reading Bank Loans to Federal Candidates
FEC Announces Internet Rulemaking
The Federal Election Commission (FEC) unanimously approved a Notice of Proposed Rulemaking, beginning the formal process of amending the agency’s regulations on internet political disclaimers. The proposal and the Commissioners’ comments at the hearing reflect a fair amount of consensus on how to refashion rules that have been the…
Continue Reading FEC Announces Internet Rulemaking
Revisions to the Department of Defense “Revolving Door” Rules
Buried in the 2018 National Defense Authorization Act (NDAA) is an obscure, and quite significant, change to the post-employment restriction on U.S. Department of Defense (DoD) civilian and uniformed personnel. This new provision could have a substantial impact on defense contractors and others who recruit DoD personnel to work on…
Continue Reading Revisions to the Department of Defense “Revolving Door” Rules
House Tax Bill Opens Door to Expanded Political Activity By Charities
UPDATE: The provision in the House bill, discussed below, was not included in the final Conference Agreement that became law.
There is one very important political law provision to watch as the tax bill moves to a final vote in the Senate, and potentially a conference committee reconciles the House…
Continue Reading House Tax Bill Opens Door to Expanded Political Activity By Charities
Will the FEC Declare War on Russia?
Noting that we are at an “all hands on deck” moment for our democracy, FEC Commissioner Ellen Weintraub circulated to the Commission yesterday a document citing former Vice President Dick Cheney for the proposition that the United States is now at war with Russia, and that “[e]very part of our…
Continue Reading Will the FEC Declare War on Russia?
The FEC Revisits the Ban on Foreign Nationals’ Financing of American Elections
On Thursday, the FEC will return to the question of foreign nationals’ involvement in United States elections. This is an important question that deserves appropriate attention from our government. Be it the role of Chinese government-linked funds in the 1996 presidential campaign or the Russian government-linked cyber intrusion in the…
Continue Reading The FEC Revisits the Ban on Foreign Nationals’ Financing of American Elections
What’s Next for the FEC?
Commissioner Ann Ravel’s decision to resign from the Federal Election Commission will have short term and long term effects on an agency empowered to interpret and enforce the federal campaign finance laws and disclose the money raised and spent in federal elections. Its short term effects should be minimal. The…
Continue Reading What’s Next for the FEC?
Covington Publishes Comprehensive Advisory Comparing Trump and Obama Executive Orders on Ethics
President Donald Trump this weekend signed his promised “drain the swamp” Executive Order, which imposes ethics restrictions on incoming and outgoing Trump Administration appointees. Incoming appointees would, of course, do well to carefully review the provisions of the Executive Order. But companies that deal with the Administration—whether by lobbying…
Continue Reading Covington Publishes Comprehensive Advisory Comparing Trump and Obama Executive Orders on Ethics
Presidential Appointees Can Take Advantage of 2014 OGE Guidance on Hedge Funds
As the President-elect begins to nominate individuals for Senate-confirmed positions in his administration, one of the major hurdles these individuals face is the statutory requirement that the Director of the Office of Government Ethics (“OGE”) review and certify a public disclosure of each source of income exceeding $200 and each…
Continue Reading Presidential Appointees Can Take Advantage of 2014 OGE Guidance on Hedge Funds