Zachary G. Parks

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.

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SEC Issues Fines for Pay-to-Play Violations That Predate Its Pay-to-Play Rule

By Zachary G. Parks on Posted in Enforcement, Pay-to-Play, SEC Pay-to-Play
A $12 million settlement announced last week by the Securities & Exchange Commission suggests that the SEC will aggressively pursue alleged schemes connecting political contributions to government contracts even if the political contributions do not violate its 2010 pay-to-play rule.  According to the settlement order, in 2010, the head of Public Funds at State Street … Continue Reading

Congressional Spending Bill Shuts Down Key Goals of Campaign Finance Reform Community

By Zachary G. Parks on Posted in Campaign Finance, Corporate Political Spending Disclosure
A major spending bill posted late last night by Congressional leaders contains provisions shooting down two key initiatives of the campaign finance reform community.  Stymied by a Federal Election Commission that has increasingly struggled to find consensus, campaign finance activists in recent years have turned their attention to other federal regulators, pressing those regulators to … Continue Reading

SEC Fines Should Prompt Firms Engaged in Political Intelligence To Revisit Insider Trading Policies

By Zachary G. Parks on Posted in Enforcement
In a rare move, the Securities & Exchange Commission has assessed penalties against a political intelligence firm for failing to adopt adequate policies to prevent the flow of inside governmental information to the firm’s clients.  The enforcement action is particularly noteworthy because all the factual allegations took place in 2010, before Congress passed the STOCK … Continue Reading

Will President Obama’s New Overtime Regulations Shrink Corporate Restricted Classes?

By Zachary G. Parks on Posted in Campaign Finance
Corporate PAC managers may soon find that the universe of employees who receive corporate PAC solicitations has unexpectedly shrunk.  In July 2015, the Department of Labor proposed new regulations that would dramatically increase the number of workers entitled to overtime wages.  The Department of Labor estimates that, under the new regulations, approximately 5 million new … Continue Reading

New Report Adds Pressure For Public Companies to Voluntarily Disclose Political Spending

By Zachary G. Parks on Posted in Corporate Political Spending Disclosure
A report published today by the Center for Political Accountability will result in more pressure on public companies to voluntarily disclose information about their political spending. Each year, CPA in collaboration with the Zicklin Center at the University of Pennsylvania issues a detailed report “scoring” companies on their corporate political disclosure practices according to a … Continue Reading

What’s Next for the SEC Pay-to-Play Rule Challenge?

By Zachary G. Parks on Posted in Litigation, Pay-to-Play, SEC Pay-to-Play
Yesterday’s D.C. Circuit opinion upholding the SEC’s burdensome “pay-to-play” rule on procedural grounds is bad news for those questioning the rule’s constitutionality.  Nevertheless, the rule is still far from invincible. The SEC pay-to-play rule, among other things, effectively prohibits investment firm executives from making certain political contributions to state and local officeholders and candidates.  Last … Continue Reading

New Insights on FARA Enforcement Emerge from DOJ Letter to Sen. Grassley

By Zachary G. Parks and Brian D. Smith on Posted in Foreign Agents Registration Act
In a recent letter to Sen. Chuck Grassley (R-Iowa), the Department of Justice offered a rare public glimpse into the enforcement activities of the small unit in the Department that enforces the Foreign Agents Registration Act.  Some of the details highlighted in the letter are consistent with observations that we have shared in this blog; … Continue Reading

Pay-to-Play Law on Gov. Christie’s Desk Poses Potential Threat to National Parties

By Zachary G. Parks on Posted in Pay-to-Play, State Pay-to-Play
A little-noticed sentence in a bill sitting on New Jersey Governor Chris Christie’s desk could, if it becomes law, threaten to curtail the ability of national party committees to raise money from Wall Street and financial industry executives.  The Republican and Democratic Governors Associations, the Republican National Committee, the Democratic National Committee, and the federal … Continue Reading

Covington Issues Client Advisory on Bank Loans and Transactions with Candidates and Political Groups

By Robert Kelner and Zachary G. Parks on Posted in Campaign Finance
Covington recently issued an advisory to its bank and financial institution clients explaining the rules governing their business dealings with candidates and political groups. The advisory, which is available here, deals with loans and other transactions that sometimes cause banks to run afoul of Federal Election Commission regulations or government ethics rules. While banks are … Continue Reading

FEC Increases Contribution Limits, Permitting Individuals to Contribute over $800K to National Party Committees

By Zachary G. Parks on Posted in Campaign Finance
The Federal Election Commission has increased the limits on the amount an individual can contribute to a candidate or national political party for the 2015-2016 election cycle.  An individual can now give up to $2,700 per election to a candidate for federal office, up from $2,600.  Because the primary and general count as separate elections, individuals may now give $5,400 per candidate … Continue Reading

CPA-Zicklin Index for 2015 Expected To Rank Entire S&P 500

By Zachary G. Parks on Posted in Corporate Political Spending Disclosure
Covington has recently learned that, for the first time ever, the CPA-Zicklin Index, which ranks companies’ political disclosure practices, plans to issue rankings for all 500 companies in the S&P 500 Index.  This is a significant expansion of the Index, which will impact many public companies that have not previously been subject to intense scrutiny … Continue Reading

Covington Releases How-To Guide For Responding To Corporate Political Disclosure Initiatives

By Zachary G. Parks on Posted in Corporate Political Spending Disclosure
Covington today released a client advisory providing best practices to assist in-house counsel of publicly-traded companies in responding to corporate political disclosure initiatives.  These initiatives aim to force companies to post to their websites more information regarding corporate political activities, such as details regarding corporate contributions to trade associations and 501(c)(4) social welfare organizations.  Despite … Continue Reading

The SEC Pay-to-Play Rule Year in Review

By Zachary G. Parks on Posted in Pay-to-Play, SEC Pay-to-Play
When the history of the Securities & Exchange Commission’s pay-to-play rule is written, 2014 could be the inflection point.  Developments this year suggest two dramatically different paths for the rule in the years to come: either the rule will unravel from court challenges or it will become an increasingly prominent enforcement weapon in the SEC’s … Continue Reading

MSRB Advances Expanded Pay-to-Play Rule Covering Municipal Advisors

By Zachary G. Parks on Posted in Pay-to-Play
For two decades, municipal securities dealers have been subject to Municipal Securities Rulemaking Board (“MSRB”) rule G-37 which bars them from receiving state and local business for two years after certain political contributions are made by the dealers and individuals affiliated with them.  Earlier this week, the MSRB advanced amendments to rule G-37 that would … Continue Reading

Lobbyists Can Now Sit on Some Federal Advisory Committees: Here’s How to Find Out Where

By Zachary G. Parks and Brian D. Smith on Posted in Government Ethics, Lobbying Compliance
In a significant reversal by the Obama administration, lobbyists will now be permitted to serve on federal advisory committees, boards, and commissions after more than four years of sitting on the advisory committee sidelines.  In guidance published in the Federal Register today, the Office of Management and Budget (“OMB”) quietly revised, in large part, the … Continue Reading

SEC Announces Major Fines In First Pay-to-Play Enforcement Case

By Zachary G. Parks on Posted in Enforcement, SEC Pay-to-Play
The Securities & Exchange Commission hit a Philadelphia-area private equity firm today with a major penalty, in the SEC’s first case involving alleged violations of its 2010 “pay-to-play” rules.  More enforcement actions may be coming. The SEC pay-to-play rules were adopted to prevent, among other things, executives of investment firms from making political contributions in … Continue Reading

2013 GAO Lobbying Disclosure Report Shows Challenges in Compliance, Recordkeeping

By Brian D. Smith, Zachary G. Parks and Andrew Garrahan on Posted in Enforcement, Lobbying Compliance
Last week, the Government Accountability Office (GAO) released its 2013 report on compliance with the Lobbying Disclosure Act of 1995 (LDA), summarizing the audits of 104 lobbyist reports and information from the U.S. Attorney’s Office for the District of Columbia. We see several trends in this year’s report.  First, registrants are reporting more difficulties complying … Continue Reading

Federal Judge Finally Tosses Aside Limits on Contributions to New York Super PACs

By Zachary G. Parks on Posted in Campaign Finance, Enforcement, Litigation, State Law
Super PACs in the Empire State and in the Big Apple are about to become more “super.”  Today, a New York federal court finally (albeit begrudgingly) struck down a state law that effectively capped contributions to state Super PACs at no more than $150,000.  Prior to today’s ruling, New York had been one of a … Continue Reading

Both Sides of the Political Disclosure Divide Likely to Latch onto McCutcheon Decision

By Zachary G. Parks on Posted in Campaign Finance, Corporate Political Spending Disclosure
Despite the heated rhetoric surrounding today’s McCutcheon decision, it should be remembered that the aggregate contribution limits the Court struck down today have played only a minor role in recent controversies surrounding campaign finance regulation.  In recent years, debates surrounding the disclosure of political spending have instead taken center stage.  Groups like the Center for … Continue Reading

Will States Ignore the Supreme Court’s Coming McCutcheon Decision?

By Zachary G. Parks on Posted in Campaign Finance, Enforcement, State Law
The Supreme Court is expected to rule soon, in McCutcheon v. FEC, on whether the Federal Election Campaign Act’s biennial aggregate limits on individual political contributions are constitutionality permissible.  Many have argued that, if the Supreme Court strikes down the federal limits, aggregate limits imposed by state law will likewise be tossed aside.  That may … Continue Reading

Activist Investors Announce Submission of Political Spending Shareholder Proposals to 48 Companies

By Zachary G. Parks on Posted in Corporate Political Spending Disclosure
A coalition of 60 investors, led by the AFSCME Employees Pension Plan and Walden Asset Management, recently announced that they have submitted shareholder proposals seeking additional disclosures regarding political spending and lobbying activities. This announcement reflects a continuing desire among these groups to obtain additional disclosures from public companies regarding lobbying and political spending, and … Continue Reading

Shareholders Try New Tactic in Corporate Political Disclosure Fight

By Zachary G. Parks on Posted in Corporate Political Spending Disclosure, Litigation
This year has not been a great one for activists seeking to force corporations to increase disclosure of their political activities.  According to the Manhattan Institute’s Center for Legal Policy, average shareholder support for proposals related to political spending or lobbying declined again this year, from 22 percent to 20 percent for lobbying proposals and … Continue Reading

SEC Takes a Pass on Corporate Political Disclosure, But Other Fronts Remain

By Zachary G. Parks on Posted in Corporate Political Spending Disclosure, Litigation
If there was an award for “political law issue of the year,” corporate political disclosure would be a front-runner.  About a year ago, the Securities & Exchange Commission (“SEC”) asked the Office of Information and Regulatory Affairs (“OIRA”)—housed within the Office of Management and Budget as part of the Executive Office of the President—to add … Continue Reading

A New Twist to GAO Lobbying Disclosure Audit Procedures

By Zachary G. Parks on Posted in Lobbying Compliance
The Government Accountability Office (“GAO”) has begun a new wave of audits of corporations, associations, and firms that are registered under the federal Lobbying Disclosure Act (“LDA”).  These periodic audits are required under legislation enacted in 2007, the Honest Leadership and Open Government Act (“HLOGA”).  HLOGA requires that registrants be selected for audit on a … Continue Reading
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