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Pay-to-Play Spotlight: End of 2009 Brings Pay-to-Play Changes in Illinois, Pennsylvania and Dallas

January 2010

Several jurisdictions took action in the last months of 2009 with respect to their pay-to-play laws and rules. The changes involved both new rules and amendments to pre-existing rules. The changes are summarized briefly below.

Most recently, Illinois Governor Quinn signed amendments to the state's pay-to-play laws on December 23, 2009. These changes, effective January 1, 2010, affected, among other things, the types of business entities considered to be "affiliated entities" and, thus, subject to the state's pay-to-play solicitation and contribution ban as well as to disclosure through the state's pay-to-play registration system. The legislative changes also affected the timing of amendments to the registration statements and eliminated the disclosure of minor children on such statements.

Effective December 17, 2009, Pennsylvania enacted a series of pay-to-play statutes with respect to municipal pension systems. The new rules, which vary in their details, regulate the solicitation and making of contributions as well as the disclosure of contributions.

Finally, in November, the city of Dallas enacted a pay-to-play ordinance that became effective on December 1, 2009.