Covington annually publishes a detailed survey of state campaign finance, lobbying, and gift rules. Now, for the first time, Covington is releasing an updated survey that details federal campaign finance, lobbying, and gift rules, in addition to those of the 50 states and the District of Columbia. Corporations, trade associations, non-profits, other organizations, and individuals face

Zachary G. Parks
Zachary Park advises a wide range of corporate and political clients on federal and state campaign finance, lobbying disclosure, pay to play, and government ethics laws. Mr. Parks regularly advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended clients in investigations by the Federal Election Commission, the U.S. Department of Justice, and the House Oversight & Government Reform Committee.
Tips for Responding To Corporate Political Disclosure Shareholder Proposals
The contentious 2020 election cycle, debate over hot-button issues, including the Supreme Court’s 2022 decision in Dobbs v. Jackson Women’s Health Organization, and increased investor focus on ESG matters (as well as criticism of such focus) have led to an increased focus on shareholder proposals requesting disclosure of corporate political expenditures. This Covington Alert…
Updated and Expanded: Covington Announces 2023 Edition of Pay-to-Play Rule Survey
For over a decade, Covington has published a detailed survey of the “pay-to-play” laws of all 50 states. Now, for the first time, Covington is updating the survey with a new section covering federal pay-to-play rules, in addition to those of the 50 states and many cities and counties. This new section details the federal…
Inflation Hits the FEC: Contribution Limits for 2023-2024 Raised in the Largest Periodic Increase Ever
The Federal Election Commission has announced contribution limits for 2023-2024. The new “per election” limits are effective for the 2023-2024 election cycle (November 9, 2022 – November 5, 2024), and the calendar year limits are effective January 1, 2023. The new limits represent the largest election cycle increase since the limits started being indexed for…
Covington Releases Updated Version of “FARA: A Guide for the Perplexed”
In 2018, Covington published the original version of its widely read primer on the Foreign Agents Registration Act, “FARA: A Guide for the Perplexed.” We have updated this primer periodically. Today, the firm released the latest edition of the primer, featuring new analysis of recent Department of Justice guidance regarding the scope of agency…
Ranking of Companies on PoliticalDisclosure Now Expanded to Russell 1000
The CPA-Zicklin Index, which ranks companies’ political disclosure practices, has issued a new
report ranking companies in the Russell 1000 Index. This is a significant expansion of the Index,
which previously only covered companies from the S&P 500. The expansion will impact many
public companies that have not previously been subject to scrutiny by political…
SEC Commissioner Says It’s “Past Time” To Reform Overly “Blunt” Pay-to-Play Rule
The U.S. Securities and Exchange Commission (“SEC”) last week announced settlements with four investment advisory firms regarding alleged violations of the SEC’s pay-to-play rule, illustrating that federal regulators continue to aggressively pursue such cases. The rule at issue, Rule 206(4)-5 (“the Rule”), prohibits investment advisers from, among other things, receiving compensation from certain government entities…
Picking Battles: The FEC and the Constitution
Perhaps no citation has been more favored in Federal Election Commission (“FEC”) decisions over the past decade than Heckler v. Chaney, 470 U.S. 821 (1985), a Supreme Court decision that gives an agency broad discretion over which enforcement cases to pursue. But there is a category of cases where the FEC is not employing…
FEC Commissioners Issue New Guidance on Donor Disclosure for Groups Paying for Political Advertisements
Trade associations, 501(c)(4) social welfare organizations, other outside groups that pay for political advertisements, and their donors now have more answers to long-running questions regarding when donations to these groups are publicly reportable. After postponing consideration of the issue during its previous meeting, the Federal Election Commission (“FEC”) approved Wednesday an interim final rule on…
Covington Publishes Comprehensive Advisory Comparing Biden and Trump Executive Orders on Ethics
The ethics rules that apply to Presidential appointees shifted Wednesday, in some ways significantly, as President Biden, just hours after being sworn in, signed an “Executive Order on Ethics Commitments by Executive Branch Personnel” and President Trump, just hours before his term expired, revoked his Executive Order on Ethics.
While the Biden…