New Jersey, already home to some of the most complex and restrictive pay-to-play laws in the nation, is considering an aggressive new expansion of those laws.  A bill under consideration that recently passed through a senate committee would prohibit certain individuals and entities involved in managing state employee retirement funds from making contributions to national, federal, or other out-of-state political parties and committees to the same extent it currently prohibits them for in-state committees.  If adopted into law, this could restrict politically active individuals and entities concerned about New Jersey’s pay-to-play law from making contributions to the DNC, RNC, the national congressional committees, and the Democratic and Republican Governors’ Associations.  It is even possible, depending on the final language and how it is implemented, that this new law could affect contributions to other federal and non-New Jersey political committees.

This legislation appears to stem from two sources.  First, New Jersey Governor Chris Christie is the current chairman of the RGA, and both the RGA and RNC supported his re-election campaign.  State labor officials have cried foul on contributions from investment managers to those committees, saying their contributions benefitted Christie’s election and political influence.  Second, the State Investment Council amended its regulations in March 2014 to explicitly exclude national party committees from the contribution ban.  This bill seeks to repeal those exclusions and affirmatively include the federal, national, and out-of-state entities in the ban.

An identical bill, A3772, is in committee in the General Assembly.  We will be closely monitoring the progress of these bills.

Photo of Andrew Garrahan Andrew Garrahan

Andrew Garrahan represents and counsels clients at the intersection of law and politics. He guides them through both regulatory compliance issues and government investigations on matters including state and federal campaign finance, ethics, lobbying, and corruption, as well as in congressional investigations.

Andrew’s…

Andrew Garrahan represents and counsels clients at the intersection of law and politics. He guides them through both regulatory compliance issues and government investigations on matters including state and federal campaign finance, ethics, lobbying, and corruption, as well as in congressional investigations.

Andrew’s prior career in political fundraising gives him a unique perspective on the challenges faced by his clients, which include corporations, candidates, government officials, political and nonprofit organizations, and private individuals.

Andrew’s counseling and advisory practice includes:

  • guiding clients on structuring of and compliance for their state and federal lobbying and grassroots advocacy campaigns;
  • representing campaigns, Super PACs, corporations, trade associations, and individuals on the applicability of the Federal Election Campaign Act (FECA) and state campaign finance law;
  • counseling on Foreign Agents Registration Act (FARA) registration and disclosure, and its interaction with the Lobbying Disclosure Act (LDA);
  • helping companies comply with state and federal ethics laws, particularly on gifts and conflicts of interests, and domestic anticorruption; and
  • auditing corporate political law compliance practices.

Andrew’s investigations and defense work includes:

  • representing clients in Congressional investigations, including responding to letter requests and subpoenas;
  • preparing company officers and other individuals for testimony in Congressional investigative hearings;
  • defending clients in Department of Justice matters related to campaign finance, lobbying, ethics, and public corruption; and
  • representing clients before the FEC and state campaign finance, lobbying, and ethics regulators.