Linda F. Beckmann
August 22, 2016
Therefore, contributions to the Trump/Pence campaign, the Republican Party, or to a PAC supporting the Trump presidential campaign may trigger a “time-out” from receiving compensation for providing advisory services to a government entity client for two years after the adviser or a “Covered Associate” has made a contribution to an “official” of the government entity. Don’t forget the “look-back” provision of the rule either when hiring new employees.
Covered Associates may make aggregate contributions up to the de minimis amounts without triggering the “time-out.” In an election where a Covered Associate may not vote for the candidate, the limit is $150, and in an election where a Covered Associate may vote for the candidate, the limit is $350.
Be sure to review your pay to play policies and procedures with your firm’s Covered Associates, particularly if you have Indiana government entities as clients now, or hope to have them within the next two years! The SEC will be looking at this area very closely!