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January 19, 2011

ARE YOUR MARKETING OR SALES PROFESSIONALS LOBBYISTS?

In light of several high-profile scandals related to the use of placement agents, state and local jurisdictions have been focusing their attention on the activities of persons who influence investment decisions. These persons are often referred to as “placement agents,” but may even include internal employees, such as marketing and sales professionals who are involved in influencing the decisions of pension board officials and employees on behalf of their employer. As the new year begins, companies with employees who interact with public officials at state and local retirement systems and pension funds on investment matters are encouraged to review state and local lobbying laws to determine if their employees’ activities trigger lobbying registration and reporting obligations.

While certain jurisdictions such as New York City and California have issued new guidance or rules that require placement agents and internal employees to register as lobbyists, lobbying laws in other jurisdictions may be interpreted to include similar activities, thus requiring registration as a lobbyist. This alert provides specific information on New York City’s recent notice to persons involved with investment decisions and California’s new placement agent rules (We also refer the reader to our November 30, 2010 client alert
http://info.akingump.com/rs/ct.aspx?ct=24F76C1EDFE60AEDC1D180ADDA2E941DDDBE5995EEF16CE43
and December 20, 2010 client alert
http://info.akingump.com/rs/ct.aspx?ct=24F76C1EDFE60AEDC1D180ADDA2E941DDDBE5995EEF16FE42
on the topic of California placement agents).

Click here
http://info.akingump.com/rs/ct.aspx?ct=24F76C1EDFE60AEDC1D180ADDA2E941DDDBE5995EEF16EE46
to read the full alert.


http://info.akingump.com/rs/ct.aspx?ct=24F76C1EDFE60AEDC1D180ADDA2E941DDDBE5D97E5A529FD69CE7
Contact Information

If you have any questions concerning this alert, please contact—

Melissa L. Laurenza
http://info.akingump.com/rs/ct.aspx?ct=24F76C1EDFE60AEDC1D180ADDA2E941DDDBE4B89E3AD7

mlaurenza@akingump.com
mailto:mlaurenza@akingump.com?subject=Alert%20Query

202.887.4251
Washington, D.C.


Carrie Hoback Hill
choback@akingump.com
mailto:choback@akingump.com?subject=Alert%20Query

202.416.5153
Washington, D.C.

Julie B. Hodgson
jhodgson@akingump.com
mailto:jhodgson@akingump.com?subject=Alert%20Query

202.416.5152
Washington, D.C.


© 2011 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party.

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