Pay to Play Updates - August 2024 - Pay to Play Law Blog

An excerpt of Dentons’ Political Law Playbook.

Harris-Walz Campaign Contributions Covered by Federal Pay-to-Play Rules – Banks and other financial institutions are restricted from donating to Vice President Harris and Minnesota Governor Tim Walz’s presidential campaign ticket due to federal pay-to-play laws. One such law is the Securities and Exchange Commission’s (“SEC”) pay-to-play Rule 206(4)-5, which prohibits investment advisers from receiving compensation for providing advisory services to a government entity for two years after the investment adviser, or certain covered personnel, make a contribution to an “official” of the government entity. Governor Walz is considered an “official” under this scheme as he serves as Chair of the Minnesota State Board of Investment. Similar rules exist across other financial regulatory bodies, including the Commodity Futures Trading Commission and the Municipal Securities Rulemaking Board. These pay-to-play rules will likely have a dampening effect on the financial industry’s support for the Harris-Walz campaign.

About the Political Law Playbook

Dentons’ Political Law Playbook is a monthly update on the most important developments in the areas of political law, government ethics, campaign finance, lobbying and election law. Each edition of Political Law Playbook will cast a spotlight on the unique issues at the intersection of law, policy and politics and give you a window into how the Dentons Political Law, Ethics and Disclosure team can help you navigate the compliance challenges you face.

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About Benjamin Keane

Ben Keane is a Partner in the Washington, DC and Atlanta, GA offices of Dentons and co-head of the firm’s Political Law, Ethics and Disclosure Team. Mr. Keane focuses his practice on the representation of elected officials, political candidates, PACs, SuperPACs, political parties, corporations, non-profit organizations and other entities with regard to federal, state and local election law, campaign finance, lobbying, pay-to-play, and ethics matters. He regularly counsels businesses, trade associations and other non-profits on the establishment and maintenance of successful political law compliance frameworks. Additionally, Mr. Keane assists clients across the country with political law investigation and audit matters involving federal, state and local government authorities, and frequently counsels presidential nominees, appointees and other federal officials on confirmation and ethics matters.

About Michael Zolandz

Mike Zolandz is the chair of Dentons' Federal Regulatory and Compliance practice, and serves as the Managing Partner for Dentons’ Washington, DC office. Mike focuses his practice on advising clients on their most critical and complex trade compliance and foreign investment projects, specializing in cross-border transactions and regulations related to international commerce.

About C. Randall Nuckolls

Randy Nuckolls is a partner Dentons’ Washington, D.C. office and is a member of the Public Policy practice. He has more than thirty years of experience working on federal policy issues.

About Michael Pfeifer

Michael Pfeifer is member of Dentons' Political Law, Ethics and Disclosure team. The focus of his practice is providing lobbying, campaign finance, and government ethics compliance counsel and representation to trade associations, political action committees (PACs), corporations and other business entities, non-profit organizations and elected officials at the federal, state and local levels.

About Madeline Conover

Maddie Conover is an associate in Dentons’ Washington D.C. office and a member of the Political Law, Ethics and Disclosure team. Her practice focuses on providing counsel on state, federal, and local lobbying, campaign finance, and government ethics compliance issues to clients including trade associations, political action committees (PACs), corporations and other business entities, and non-profit organizations.