Reminder: Illinois Pay-To-Play Registration Updates Due Quarterly

Skadden, Arps, Slate, Meagher & Flom LLP

Kenneth A. Gross Ki P. Hong Matthew Bobys Melissa L. Miles Charles M. Ricciardelli Tyler Rosen Karina Bakhshi-Azar Theodore R. Grodek Shayla K. Parker Sam Rothbloom

The next quarterly update required under the Illinois pay-to-play law is due August 14, 2021. As described in earlier mailings, the Illinois pay-to-play law requires many companies with aggregate annual state bids, proposals and contracts totaling more than $50,000 to register with the State Board of Elections and list their covered donors.

If a company has existing contracts and no pending bids, updates to the registration are due each February 14, May 14, August 14 and November 14. If a company has pending bids, updates to the registration are due within five business days or seven calendar days of the change, or the day before the contract is awarded, whichever is first.

We suggest confirming that all state contractors are properly registered and are verifying the accuracy of their registrations at least quarterly. We often find the following problems with registrants’ covered donor lists:

  • Capturing too many employees, as listing an employee who does not need to be can be problematic under the pay-to-play ban;
  • Failing to include spouses of covered individuals;
  • Listing affiliate companies that do not need to be reported, such as non-U.S. affiliates, and nonoperating sister companies and subsidiaries;
  • Failing to include the contractor’s political action committee; and
  • Allowing years to pass since the last update.

Within ten days of adding a new covered donor, a contractor must provide a copy of the registration certificate to the covered donor.

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.

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