The rule prohibits investment advisers from providing investment advisory services for compensation to a government entity within two years after a contribution to an official of that government entity is made, either by the investment adviser or by any covered associate of the investment adviser.  This prohibition does not apply to contributions made by a covered associate to officials for whom the covered associate was entitled to vote at the time of the contributions if the contributions did not exceed $350 in the aggregate to any one official, per election.  The prohibitions also do not apply to contributions made by a covered associate to officials for whom the covered associate was not entitled to vote at the time of the contributions if the contributions did not exceed $150 in the aggregate to any one official, per election.

An additional prohibition prevents an investment adviser from providing or agreeing to provide, directly or indirectly, payment to any person to solicit a government entity for investment advisory services unless that person is a regulated person or is an executive officer, general partner, managing member, or employee of the investment adviser.  Nor may such advisers coordinate or solicit any person or political action committee to make a contribution to an official of a government entity to which the adviser is providing or seeking to provide investment advisory services or payment to a political party of a state or locality where the investment adviser is providing or seeking to provide investment advisory services to a government entity.

The rule has two important compliance dates.  The March 14, 2011 date applied to investment advisers subject to the rule.  The other compliance date, September 13, 2011, is when investment advisers will no longer be able to use third parties to solicit government business except in compliance with this rule.  Additionally, advisers to registered investment pools have until the September 13 date to comply with this rule.

Cole County Circuit Court Judge Daniel Green ruled that Senate Bill 844, which became effective August 28, 2010, is unconstitutional because it covers multiple subjects.   The Missouri constitution requires that bills contain only one subject.

The bill sharply restricted transfers between campaign committees, boosted the enforcement powers of the Missouri Ethics Commission, and created measures aimed at reducing situations in which candidates channeled money through several committees to obscure their source.   The court found that the procurement measures in the bill were the “original controlling purpose,” and thus should be upheld while all other measures relating to campaign finance are void.

The Missouri Attorney General’s office and the Missouri Ethics Commission are currently reviewing the decision to examine both enforcement procedures and further legal action.

UTAH: Governor Gary Herbert has called a special session of the legislature to convene at noon on March 25. The governor stated the purpose of the special session will be to repeal HB477, an open records law which the governor had previously signed earlier this month. The legislature had adjourned on March 10.

LOUISIANA: The legislature convened on March 20 for an ‘extraordinary session’ to establish redistricting boundaries for all congressional, state and local entities’ elections. The session is scheduled for no later than April 13. The regular session of the legislature convenes on April 25.

Commissioners in Mecklenburg County, North Carolina have agreed to a change in the county’s ethics code preventing themselves and other county employees from soliciting or receiving tickets to cultural or sporting events supported by the county.

If the county has included money, either directly or indirectly, or if an employee knows or has reason to know county money may be requested for an event, employees will no longer be able to receive complimentary tickets. County employees are still free to purchase their own tickets to sporting and cultural events without violating the new policy.

Photo of the Charlotte, North Carolina skyline by Riction on Wikipedia.

Last Friday when I was writing my Highlighted Site of the Week post about the Sunshine Week website, I added some links to places for further study. In my haste I showed the last link for the “Best Practices for State Campaign Finance Disclosure, 2010” as being a project of SunshineWeek.0rg. Well, this isn’t the case, and I knew better. It belongs to the site FollowTheMoney.org, a project of the National Institute on Money in State Politics.

I send a big thank you to the National Institute on Money in State Politics for emailing me, showing appreciation for our blog, and very kindly setting the record straight.

If you dig into FollowTheMoney.org, you will see what an important resource it is for government transparency. In addition to the Best Practices data, you will find the Legislative Committee Analysis Tool, Point of Interest interactive maps, and many other features and mashups. You can filter your search results to your own congressional district and even use an API to stream their data onto your own website. Their motto: Jump Into the Data!

The National Institute on Money in State Politics offers the public information on a scale we absolutely could not get for ourselves. Their site describes the feat better than I can:

“Every two years, Institute data acquisition specialists collect, input and upload more than 90,000 contribution reports filed by 15,500 statewide, legislative and judicial candidates, 250 political party committees and 500 ballot measure committees in the 50 states. Researchers standardize donor names and code over $2 billion in contributions to 400 business categories and other interests. Programmers create open access to the records and attract thousands of users to the information. Staff also introduce users to the tools and resources and work with dozens of reporters to answer questions and provide custom data sets for their investigation.”

Thanks again to everyone at the National Institute on Money in State Politics. I hope our readers take the opportunity to view their powerful website.

This week is Sunshine Week, when people across the country celebrate the importance of government transparency and warn against the dangers of government secrecy. The organization behind the celebration has a website, SunshineWeek.org, and this is our Highlighted Site of the Week.

According to the site, Sunshine Week is “a national effort spearheaded by the American Society of News Editors. The key funder has been the John S. and James L. Knight Foundation, with significant support from ASNE Foundation. In 2011, The Gridiron Club and Foundation contributed $10,000.” The week-long celebrations include groups across the country finding creative ways to raise awareness for freedom of information – through songwriting, hosting public forums, having classroom discussions, writing editorials to newspapers, and much more. This week also marks the 12th National Freedom of Information Day on the 16th.

The White House honored the week. Steve Croley, Special Assistant to the President for Justice and Regulatory Policy, offered this blog post on the White House blog in honor of Sunshine Week. They have provided their analysis of how transparency improvements have been made on their Open Government Initiative web page.

For more information about Sunshine Week, you can follow their blog. You can also find many resources on the United States Department of Justice’s Freedom of Information Act website (foia.gov). Another item of interest to our readers is the “Best Practices for State Campaign Finance Disclosure, 2010” from the National Institute on Money in State Politics found on followthemoney.org.

Have a terrific weekend everyone!

Ms. Ravel is the commission’s first chairwoman and has an established career in public service. She has served as counsel for Santa Clara County and most recently with the U.S. Justice Department.

Ravel has indicated she may reverse the recently enacted policy of publishing allegations on the FPPC’s website before investigations are concluded out of consideration for politicians and others who may be wrongfully accused of an infraction and later cleared.

Ms. Ravel replaces Dan Schnur, a Schwarzenegger appointee, atop the commission.

Photo of Ann Ravel courtesy of the Santa Clara County website.

Directors of the California Public Employees’ Retirement System (CalPERS) adopted several new ethics proposals. Among the proposals are rules to regulate fee payments to placement agents, who help funds gain access to CalPERS decision makers, and rules to ensure the same staff members who negotiate investment deals do not monitor their success.

Additionally, the directors approved a requirement for investment partners to hold meetings in modest office settings instead of vacation resorts. The directors postponed decisions on proposals to reduce or eliminate travel, gifts, and other accommodations outside investment firms provide board members, and to impose a two-year “revolving door” ban on certain CalPERS employees.

These regulations being put in place are in line with legislation taking effect earlier this year requiring placement agents to register as lobbyists and regulating how the agents are paid.

Photo of CalPERS headquarters by Coolcaesar on Wikipedia.

Jim Sedor, the editor of State and Federal Communications’ News You Can Use, offers this breaking news item. Jeff Cox, a deputy attorney general in Indiana, has been fired for commenting on his Twitter account that police in Wisconsin should use live ammunition to disperse protesters.

For the full story, here is the article by Chris Sikich and Mary Beth Schneider in the Indianapolis Star: “Indiana official fired for remarks on Twitter” from February 24.

Here is a statement from the Attorney General’s Office on Jeff Cox’s online postings and his being fired.

Governor Dannel P. Malloy has proposed reducing the number of budgeted state agencies from 87 to 57 in a move intended to increase efficiency and save the state money. Included in the reduction plan is a proposal to combine the Office of State Ethics, Elections Enforcement Commission, Contracting Standards Board, Freedom of Information Commission, and Judicial Review Council into a new agency to be named the Office of Governmental Accountability.

While not detailing how these agencies would be capable of functioning as one, or where any cost savings would be seen, Malloy did question in a press release why all these agencies are presently separate, stating “…why are all of the government accountability functions…separate entities when so many of their issue areas and jurisdiction overlap? It just didn’t make sense.”

Quickly voicing their concern against this proposal was the non-profit group Common Cause, noting how each of these “watchdog” agencies presently must keep watch over the other. A statement released by Common Cause noted “If a citizen files a complaint that the Elections Enforcement Commission or the Office of State Ethics has violated the FOI Act, the watchdog agency would be both the respondent and judge. It is unlikely that the new commission would bring ethics charges against itself, and this watchdog agency would undermine the public’s confidence and become a national joke.”

Photo of the state capitol by Ragesoss on Wikipedia.

The Alaska Public Offices Commission (APOC) has chosen Paul Dauphinais as its new executive director. Mr. Dauphinais has served as the president of Garrett College in Maryland, the director for the University of Alaska in Palmer and the executive director for the Homer Chamber of Commerce. He also has a PhD in History and an MS in Information Systems and is a retired commander of the U.S. Navy.

Mr. Dauphinais starts February 22, replacing Holly Hill who held the position since 2008.

You can read the full press release here.

Map of Alaska by Skew-t on Wikipedia.

Transparency International (TI) has this motto: Corruption hurts everyone. Based in Berlin, Germany, TI is a  non-governmental and non-partisan organization with a coalition of more than 90 local chapters throughout the world.

Founded in 1993, Transparency International monitors and reports on international political and corporate corruption. They look at how corruption affects political parties and the election process, lobbying, international trade, defense issues, and government procurement. TI’s work has directed the world’s attention to the problem of corruption and how it affects people, especially the poor. Among its accomplishments, the organization has played a big role in establishing the United Nations Convention against Corruption and the OECD Anti-Bribery Convention.

From TI’s website you can learn many things about the organization and global corruption. My favorite feature is the 2010 Corruption Perception Index. It has an interactive map reporting the perception of government and corporate corruption for people in most nations of the world. Looking at their scale from zero (highly corrupt) to 10 (very clean), I held my breath before I saw the score for the United States. I was happy to find out we earned a 7.1 – pretty clean. I was disturbed to see how many places all over the world fell into the corrupt categories.

In addition to giving us a terrific web design, the people at Transparency International are savvy with social media. TI has put a great deal of engaging information on Twitter, Facebook, Youtube, and their blog. You can even find a podcast and a free iPhone app.

For anyone who cares about the worldwide issues of good government, Transparency International deserves your close attention.

As reported in today’s pressofatlanticcity.com, the Atlantic City City Council unanimously passed a pay-to-play ordinance mandated by an agreement with the state’s Department of Community Affairs. The law would prohibit granting contracts to individuals and businesses who contributed to a campaign or political action committee for the election of a council member.

The Department of Community Affairs gives financial assistance to local municipalities in exchange for measures such as instituting pay-to-play laws and giving the Department power to review and approve other city business, such as hiring and promoting. The only discussion about the ordinance was from Councilman Moisse Delgado, who asked, “Y’all ready for this?”

The state Ethics Commission has released its final promulgated amendments to the state’s ethics rules for 2011.

These amendments, available on the commission’s website, become law on July 1 if no action is taken by the state legislature.

One of the rules set forth this year will allow corporations to make independent expenditures and another will allow PACs to contribute to ballot measure committees.

Image of the Oklahoma flag by Denelson83 on Wikipedia.