traps for the unwary

In December, the Securities and Exchange Commission (“SEC”) fined an investment adviser $100,000 for violating the SEC’s pay-to-play rule.  The SEC’s rule effectively prohibits investment adviser executives and other “covered associates” of an investment adviser from making political contributions in excess of de minimis amounts ($350 per election if the…
Continue Reading Investment Adviser Hit With $100K SEC Fine, a Reminder that Public Universities are Covered by Pay-to-Play Rule

Two public relations firms have filed documents with the Department of Justice revealing that they provided public relations and media services in the United States for the government of Ecuador without being registered under the Foreign Agents Registration Act (FARA), as that law requires.  These firms are the latest in…
Continue Reading Two More Public Relations Firms Trip Over the Foreign Agents Registration Act

Celebrities often use their star power to shine a light on otherwise overlooked issues.  Soccer star David Beckham has inadvertently used his celebrity status to highlight a trap for the famous and non-famous alike — local lobbying regulations.  Last Wednesday, The Miami-Dade County Commission on Ethics and Public Trust cleared…
Continue Reading Attend It Like Beckham: Celebrity Cleared of Lobbying Violations from Miami “Meet-and-Greets”

It is about to become a little more challenging for companies to pay travel costs for House Members and staff.  Starting for trips on or after April 1, 2013, Members and employees of the House must submit pre-approval request forms to the House Ethics Committee at least 30 days prior…
Continue Reading Privately-Sponsored Travel For House Members and Staffers About To Get More Difficult

The Federal Election Commission increased the limits on the amount an individual can contribute to a candidate or national political party, as well as the overall limit on the amount an individual can give to all federal candidates and federal political committees in a two-year election cycle.

An individual can…
Continue Reading FEC Increases Individual Contribution Limits for 2013-2014

Most businesses are careful not to post confidential proprietary information on the public face of their website.  But is there any reason to avoid posting video clips of speeches by public figures at an annual conference that contain no proprietary information?  It turns out there is, if the public figures…
Continue Reading Posting Videos of Candidates Speaking to Your Organization Could Violate Federal Law

Lesson one for any student of state and local pay-to-play laws: just when you think you have a handle on them, they change.  Recent developments in a small New Jersey township provide a case-in-point.

Last month, Upper Township, New Jersey, adopted an ordinance that forbids the township from entering into…
Continue Reading New Jersey Township Move Highlights Dynamic Nature of Pay-to-Play Laws

The final fundraising push of 2012 is on and politically active individuals with substantial net worth need to be particularly careful to comply with the overall aggregate contribution limits, as well as with the sub-limits on giving to federal candidates, party committees and PACs.  On Friday, Reuters had a …
Continue Reading The Press Begins to Scrutinize Donor Compliance with Federal Contribution Limits

On July 13, the FEC announced a settlement with Americans for Common Sense Solutions.  The group agreed to pay a penalty of $9,000 for failing to report $121,000 in electioneering commutations attacking Reps. Capps (D – Calif.) and Cicilline (D-R.I.) within 60 days of the November 2010 general election. FEC…
Continue Reading Ouch! Traps for the Unwary In FEC Electioneering Communications Reports