Staff Contact: Ken Pokalsky
JCOPE client/lobby and source of funding rules –
The Business Council has submitted comments on, and provided testimony to, the Joint Commission on Public Ethics in response to, their proposed “comprehensive lobbying” regulations and its updated “source of funding” regulations. Of major concern is JCOPE’s proposed restrictions of the Lobby Act exemption for “commission salespersons.” The Council also highlighted other provisions of JCOPE’s proposal that are inconsistent with underlying statute and/or impose unworkable compliance obligations, and made recommendations to address these concerns. Our submissions, as well as the proposed rules and public comments received by JCOPE, are available below.
JCOPE Proposed Part 943 “Comprehensive Lobbying Regulations” and Part 938 “Source of Funding” regulations, and Public Comments
Comments on JCOPE draft advisory opinion on contributions (12/4/15)
JCOPE Request for Comments on Definition of “Lobbying”
Proposed IRS rules on 501(c)(4) organizations
IRS notice of proposed rulemaking
Proposed Part 934 Regulation on Gift Restrictions
Business Council comments/overview of JCOPE changes
TBC Letter of Concern regarding “Reportable business relationship” and “source of fund” implementation
Campaign / Election Reform Legislative Proposals
JCOPE Proposed "Source of Income" Regulation
JCOPE Emergency "Source of Income" Rule Adopted 11/20/12
JCOPE Proposed Guidance on "Reportable Business Relationships"
Joint Commission on Public Ethics Invitation for Public Comment on Lobbyist/Client Disclosure Rules