Full Disclosure? Traps For the Unwary in Corporate Political Activity Disclosure Policies

Increasingly, corporations are being pressured by a variety of stakeholders to provide transparency regarding political spending. Public companies must ensure that voluntary disclosures relating to their political contributions are accurate and that sufficient internal disclosure controls are in place, as failure to do so risks the SEC taking enforcement action. Partners Anita Bandy and Charles Ricciardelli and associate Olivia Marshall discuss this issue and highlight potential sources of SEC enforcement risk in the political activity context.