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

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

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?

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

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

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

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

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

The Right Political And Election Law Compliance Policy

These days, it is not enough for companies with dealings with government officials to adopt election and political law compliance policies.  They need to adopt the right policies. A $200,000 settlement the Financial Industry Regulatory Authority recently obtained against L.J. Hart & Co. (“Hart”), a Missouri municipal-bond underwriter, is a case in point.  The case … Continue Reading

Lessons From the Reversal of Tom DeLay’s Conviction

For Tom DeLay, yesterday’s Texas Court of Appeals ruling reversing his conviction on money laundering charges (with its accompanying three year prison sentence) probably makes up for the former House Majority Leader’s Dancing with the Stars loss.  The acquittal marks another high-profile defeat for government prosecutors bringing criminal charges predicated on alleged election law violations. … Continue Reading

Major Criminal Penalties Assessed In New Jersey Pay-to-Play Case

Last spring, we reported that the New Jersey Attorney General charged seven executives and shareholders of Birdsall Services Group, an engineering firm, with participating in a massive pay-to-play scheme.  The scheme allegedly involved a multi-year attempt by company executives and major shareholders to evade state level pay-to-play restrictions by making and then reimbursing political contributions … Continue Reading

FBI Sting Results In Prison Sentence for Candidate’s Finance Director

This spring, a jury convicted Robert Braddock, the Finance Director to former Congressional candidate—and former Speaker of the Connecticut House of Representatives—Christopher Donovan, with conspiring to hide the source of $27,500 in campaign contributions.  According to the indictment, Braddock accepted contributions to the campaign knowing that they had been reimbursed by individuals associated with Connecticut … Continue Reading

How Pay-to-Play Laws Are Changing Elections

Obscure pay-to-play rules are having a big impact on U.S. elections.  In an article in today’s The Hill, we examine how these little understood rules provide institutional fundraising advantages for certain candidates at the expense of others.  We also point out how these laws are changing the operational rules of the road, forcing candidates to … Continue Reading

Two New FEC Commissioners To Be Nominated

The White House today announced its intent to nominate two lawyers to serve as commissioners on the six-member Federal Election Commission: Lee Goodman, an election lawyer at LeClairRyan and Ann Ravel, the chair of the California Fair Political Practices Commission. According to the Center for Public Integrity, Goodwin has been selected to fill the seat … Continue Reading

Chevron Shareholder Resolution Attempting to Bar Corporate Political Activity Resoundingly Defeated

Earlier this week, activist investors attempted to push through a shareholder resolution barring Chevron from using corporate funds for political activities.  The resolution called for the board of directors to “adopt a policy to refrain from using corporate funds to influence any political election.”  If passed, it would have prohibited not only direct contributions, but … Continue Reading

Fine Levied Against California Super PAC a Possible Signal of Things to Come

Earlier this year we predicted that battles over the definition of “coordination” and Super PAC “independence” would play a significant role in the development of campaign finance law in the coming years.   In keeping with that forecast, last week, the California Fair Political Practices Commission for the first time fined a Super PAC for allegedly … Continue Reading

Skeptical GAO Report Considers Potential “Political Intelligence” Disclosure Requirements

A Wall Street Journal article says that a report published today by the Government Accountability Office “urges” the creation of a new disclosure regime for political intelligence firms.  That’s not how we read the report. As background, when the Senate passed the Stop Trading on Congressional Knowledge Act (the “STOCK Act”) 96-3 last year, the … Continue Reading

GAO Report Signals Slow But Steady Increase In Lobbying Disclosure Act Enforcement

The Government Accountability Office this week issued its sixth annual report summarizing the results of its audit of approximately one hundred federal Lobbying Disclosure Act registrants.  As we previously explained when the audits began, federal law requires the GAO to select LDA registrants on a “random” basis for an audit to assess their compliance with … Continue Reading

Tough Pay-To-Play Bill Under Consideration in Rhode Island

Rhode Island — currently a “disclosure only” pay-to-play state — is considering adding a political contributions ban to its pay-to-play repertoire.  In February, Rhode Island Attorney General Peter Kilmartin proposed legislation to prohibit state vendors, their ten-percent owners, their executive officers, and the spouses and minor children of those officers and owners from making political … Continue Reading

Congressionally Commissioned Report Recommends Shelving Key STOCK Act Provision

With near-unanimous bipartisan majorities, Congress last year passed the Stop Trading on Congressional Knowledge (“STOCK”) Act in an effort to confront alleged insider trading by federal officials.  A major part of that legislation required that financial information of high-level government employees be disclosed in a searchable, sortable, and downloadable internet database.  Although the officials’ underlying … Continue Reading

Vermont Working On Major Changes To Campaign Finance Law

The Vermont Senate might soon scrap the Green Mountain State’s campaign finance law in its entirety in favor of new legislation.  The pending bill would change contribution limits, increase reporting frequency, and require groups paying for electioneering communications to disclose their major donors.  The ambitious bill, which is making its way through the state senate, … Continue Reading

New House Travel Forms Highlight Restrictions on Underwriting Events

Thinking about subsidizing a think-tank’s policy conference in Aspen?  If House Members or employees are expected to attend, corporations and trade associations should think twice before cutting the check. Last month, we highlighted revisions to the House of Representatives travel regulations which kick in for trips on or after April 1, 2013.  New travel sponsor … Continue Reading

Courts Begin To Grapple With Challenges To Super PAC “Independence”

When is an independent expenditure-only committee, or Super PAC, truly independent of the candidate the Super PAC supports?  Surprisingly few courts in the post-Citizens United world have decided this question.  A recent Vermont Superior Court decision, however, provides a rare example of a court grappling with this issue. The case involved allegations of coordination between … Continue Reading

What To Watch Out For During Presidential Inauguration Festivities

With Inauguration Day just under three weeks away, many corporations and individuals are being asked to participate in the festivities that will accompany the presidential swearing-in ceremony.  While less regulated than pre-election political activities, presidential inaugurations are nonetheless subject to a number of easily-overlooked rules.  Yesterday’s Covington E-Alert identifies three common situations where individuals and … Continue Reading
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