One of our affiliates is considering hiring a state lobbyist. Are there any compliance issues involved in hiring a lobbyist?

We do not see any problems with the company hiring a lobbyist, given that the lobbyist is in compliance with Illinois and federal election ethics laws; such activities are political speech and are protected by the First Amendment. However, there are three areas of law to keep in mind, particularly municipal securities’ lobbyist rules. Having extensively researched the municipal securities board rules, we do not feel comfortable giving any specific guidance, as this area of law is complex.

Also, note that lobbyists are prohibiting from communicating with executive departments or agency officials as to the disposition of Recovery Act funds and Emergency Economic Stability Act funds.