On September 3, 2026, the Securities and Exchange Commission (“SEC”) voted to propose rescinding in its entirety Rule 206(4)-5 under the Investment Advisers Act of 1940, the agency’s longstanding “pay-to-play rule” applicable to investment advisers. If finalized, the proposal would eliminate the most significant federal political law compliance regime for
Continue Reading SEC Proposes to Repeal Longstanding Pay-to-Play Restrictions on Investment Advisers
Zachary G. Parks
Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.
Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside attorney for election law, campaign finance, pay-to-play and PAC issues.” Zachary is also a leading lawyer in the emerging corporate political disclosure field, regularly advising corporations on these issues.
Zachary's expertise includes the Federal Election Campaign Act, the Lobbying Disclosure Act, the Ethics in Government Act, the Foreign Agents Registration Act, and the Securities and Exchange Commission’s pay-to-play rules. He has also helped clients comply with the election and political laws of all 50 states. Zachary also frequently leads political law due diligence for investment firms and corporations during mergers and acquisitions.
He routinely advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended his political law clients in investigations by the Federal Election Commission, the U.S. Department of Justice, Congressional committees, and in litigation.
Zachary is also the founder and chair of the J. Reuben Clark Law Society’s Political and Election Law Section.
Zachary also has extensive complex litigation experience, having litigated major environmental claims, class actions, and multi-district proceedings for financial institutions, corporations, and public entities.
From 2005 to 2006, Zachary was a law clerk for Judge Thomas B. Griffith on the United States Court of Appeals for the District of Columbia.
DOJ Signals it will Move Forward with Significant Revisions to FARA Regulations
In an August 2026 Unified Agenda entry, the Department of Justice (“DOJ”) stated that it intends to complete its long-running effort to revise the regulations implementing the Foreign Agents Registration Act (“FARA”). The National Security Division (“NSD”) stated that it is considering a final rule that would adopt “many…
Continue Reading DOJ Signals it will Move Forward with Significant Revisions to FARA RegulationsDefense Department Publishes Guidance Page Concerning Restrictions on Defense Contractors Retaining Outside Consultants
Over the last month, we have issued multiple client alerts outlining developments related to the Chinese military company covered lobbyist prohibition enacted by Section 851 of the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025, codified at 10 U.S.C. § 4663. This is a follow-up to…
Continue Reading Defense Department Publishes Guidance Page Concerning Restrictions on Defense Contractors Retaining Outside ConsultantsElection Year Reminder: Pay-to-Play Risks Are Easy to Miss and Costly to Fix
It’s a common scenario: An employee receives a text from a friend asking them to contribute to the campaign of a candidate the friend supports. Without thinking much about it, the employee makes a $500 contribution. Though the employee has been trained on their company’s political contributions policy, it doesn’t…
Continue Reading Election Year Reminder: Pay-to-Play Risks Are Easy to Miss and Costly to FixSupreme Court Decision in National Republican Senatorial Committee v. Federal Election Commission Empowers Political Parties, Calls Other Restrictions into Question
In a major decision today, the Supreme Court in NRSC v. FEC struck down longstanding limits on “coordinated party expenditures” that restricted the amounts political parties could spend in coordination with federal candidates. With this decision, national party committees and the federal accounts of state parties can now spend unlimited…
Continue Reading Supreme Court Decision in National Republican Senatorial Committee v. Federal Election Commission Empowers Political Parties, Calls Other Restrictions into QuestionCovington Launches Election Year Toolkit
As the election season intensifies, companies face a rapidly evolving landscape of regulatory, compliance, and reputational considerations. With heightened scrutiny on political engagement, lobbying, campaign finance, and communications, organizations must be prepared to navigate complex and fast-moving legal requirements.
Drawing on our deep experience in election and political law, public…
Continue Reading Covington Launches Election Year ToolkitCovington Announces Political Law Survey (2026 Edition)
Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of political laws for 2026.
Corporations, trade associations, non-profits, other organizations, and individuals face significant penalties and reputational harm if they violate federal or state laws governing corporate and personal political activities, the registration of…
Continue Reading Covington Announces Political Law Survey (2026 Edition)Covington Announces Pay-to-Play Survey (2026 Edition)
Covington is pleased to announce that it has revised and updated its comprehensive 50-state survey of pay-to-play laws for 2026.
Companies doing business with the federal government or state and local governments and companies operating in regulated industries are subject to a dizzying array of “pay-to-play” rules. These rules effectively…
Continue Reading Covington Announces Pay-to-Play Survey (2026 Edition)Covington Releases Updated Version of “FARA: A Guide for the Perplexed”
In 2018, Covington published the original version of its widely read primer on the Foreign Agents Registration Act, “FARA: A Guide for the Perplexed.” We have updated this primer periodically. This week, the firm released the latest edition of the primer, featuring new analysis of recent Department of Justice…
Continue Reading Covington Releases Updated Version of “FARA: A Guide for the Perplexed”A Potentially Overlooked Risk Area: Incorporating Congressional Investigations into Transactional Due Diligence
Congressional investigations are now a common reality across corporate America, and companies large and small are therefore more focused than ever on the potential effects of congressional inquiries into business activities, goals, and strategies. In this new reality, the most sophisticated companies, private equity firms, and other corporate players are…
Continue Reading A Potentially Overlooked Risk Area: Incorporating Congressional Investigations into Transactional Due Diligence