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Maryland Irons Out Its Pay-to-Play Contribution Disclosure Regime

July 2015

By Carol A. Laham and D. Mark Renaud

In 2013, Maryland overhauled its campaign finance laws, including the reporting requirements for government contractors. Earlier this year, the state clarified some provisions of the new law, altered the reporting dates, and modified certain reporting requirements.

Under the Maryland reporting regime, a contractor that enters into a government contract worth at least $200,000 is required to disclose certain political contributions to the State Board of Elections. The disclosure law became effective on January 1, 2015, but it was unclear whether entities that had entered into covered contracts before that date were required to file semiannual disclosure statements. The recent legislation clarifies that these reporting requirements apply to entities that currently hold covered contracts that were entered into before January 1, 2015. 

The legislation also amended the reporting periods and due dates for the semiannual disclosure statements. Semiannual reports are now due by May 31 for the period covering November 1 through April 30 and by November 30 for the period covering May 1 through October 31. However, because the legislation did not become effective until this summer, the reports for this year are due by August 31, 2015 for the period covering February 1 through July 31 and by November 30, 2015 for the period covering August 1 through October 31.

The legislation made several other changes. First, contractors that did not make applicable contributions in a cumulative amount of $500 or more to a candidate can avoid most reporting requirements. Second, the legislation permits contractors that have obtained waivers from the State Board of Elections (which are allowed if supplying information about certain contracts is “unduly burdensome”) to avoid filing initial statements with the Board and file abbreviated semiannual reports.