Illinois Secretary of State Issues Guidance on State Lobby Law Changes, Cook County Passes Ethics Reform Package

Skadden Publication / Political Law Update

Ki P. Hong Charles M. Ricciardelli Matthew Bobys Melissa L. Miles Tyler Rosen Karina Bakhshi-Azar Theodore R. Grodek Sam Rothbloom

Guidance on Illinois Lobby Law Changes

On December 28, 2021, the Illinois Secretary of State’s office issued guidance on changes to the state’s lobby law made by S.B. 539, a recently enacted state ethics reform package that we discussed in our November 3, 2021, mailing. Effective January 1, 2022, the state lobby law requires state registration for lobbying at the county, municipal and township levels. The guidance clarifies, however, that individuals or entities only lobbying Chicago will not be required to register with the state. S.B. 539 included a provision preempting all inconsistent local lobby laws but exempted Chicago’s lobby law.

Cook County Ethics Reform Package

At its December meeting, the Cook County Board of Commissioners passed an ethics reform package that, among other things, repealed the county’s lobby ordinance, amended its pay-to-play limits and gift ban to cover state registered lobbyists lobbying the county, and doubled the pay-to-play limits in nonelection years.

The repeal of the county’s lobby ordinance comes in response to changes to the state’s lobby law made in S.B. 539. Beginning January 2022, lobbyists attempting to influence the decisions of Cook County officials may have to register and report with the state. However, lobbyists no longer have to register with the county, and current registrants do not have to file lobbying reports for the second half of 2021 (which were previously due January 20, 2022).

Both the county’s pay-to-play limits and gift ban (which previously covered lobbyists registered with the county) have been amended to cover lobbyists registered with the state as lobbying the county.

The county ethics reform package also amends the county’s pay-to-play limits. Previously, covered donors were permitted to contribute up to $1,500 per election year (up to $750 per primary election and up to $750 per general election) to a county candidate and any local, state or federal political committee established in support of such candidate and up to $750 per nonelection year to a county elected official and any local, state or federal political committee established in support of such official. Now, covered donors may contribute up to $1,500 per calendar year to any local, state or federal political committee established in support of a county candidate or elected official. Thus, the new limits double the amount that a covered donor may give in a nonelection year.

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.