UK:
Two Additional Presidential Candidates Subject To Federal Pay-To-Play Rules
07 June 2019
Skadden, Arps, Slate, Meagher & Flom (UK) LLP
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In a recent mailing we noted that the following Democratic
presidential candidates are covered under federal pay-to-play rules
(i.e., SEC 206(4)-5, MSRB G-37, CFTC 23.451 and FINRA
2030) because they are currently elected state or local officials
running for federal office:
- Mayor Pete Buttigieg, South Bend,
Indiana;
- Mayor Wayne Messam, Miramar, Florida;
and
- Gov. Jay Inslee, state of
Washington.
Since then, two additional Democratic candidates who are covered
under the rules have announced their candidacy. They are:
- Gov. Steve Bullock, Montana; and
- Mayor Bill de Blasio, New York
City.
Please note that Montana and New York City also have pay-to-play
laws covering certain elected officials in each jurisdiction.
However, there are questions as to whether those laws are preempted
by the federal election law, which expressly preempts state laws
when it comes to contributions made to federal candidates, but does
not preempt other federal agency rules, such as the federal
pay-to-play rules mentioned earlier.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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