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 contributor is eligible to vote
traps for the unwary
Two More Public Relations Firms Trip Over the Foreign Agents Registration Act
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 a long string of law…
Attend It Like Beckham: Celebrity Cleared of Lobbying Violations from Miami “Meet-and-Greets”
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 “Becks” of violating the county’s…
Privately-Sponsored Travel For House Members and Staffers About To Get More Difficult
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 to the trip. Previously, they…
FEC Increases Individual Contribution Limits for 2013-2014
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 now give up to $2,600…
Posting Videos of Candidates Speaking to Your Organization Could Violate Federal Law
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 are candidates for federal office.…
Another Trap for the Unwary in New Jersey
Upper Township, New Jersey, just added another mine to the minefield that is New Jersey pay-to-play law. We noted in October that Upper Township (1) had adopted a new pay-to-play law and (2) was poised to do so again. According to the Upper Township Gazette, on Monday the Upper Township Committee voted to adopt…
New Jersey Township Move Highlights Dynamic Nature of Pay-to-Play Laws
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 certain kinds of contracts if,…
The Press Begins to Scrutinize Donor Compliance with Federal Contribution Limits
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 story on a prominent donor…
Ouch! Traps for the Unwary In FEC Electioneering Communications Reports
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 MUR 6443. The group’s defense:…