February 3, 2015
Calling All Government Contractors: Upcoming Pennsylvania Political Contribution Disclosure Form
For government contractors, the start of a new year brings with it a host of filing requirements in many states along the Northeast Corridor. Although some states (such as New York and Connecticut) do not impose annual or semi-annual filing requirements on government contractors, other states such as New Jersey, Pennsylvania, and Maryland require government contractors to file reports. This is the second in a series of blog posts that focuses on the upcoming filing deadlines in Maryland, Pennsylvania, and New Jersey. These reports generally require government contractors to disclose certain information about their political contributions, but no two filing requirements are the same. As your company prepares to put its best foot forward in 2015, this series will share what you need to know about these disclosure requirements and some compliance tips to make sure that your company is accurately capturing all relevant information. Pennsylvania (Filling Deadline – February 15, 2015) Business entities that have been awarded any no-bid contract by the Commonwealth of Pennsylvania or any of its political subdivisions must file Form DSEB-504 with the Pennsylvania’s Department of State by February 15, 2015. Because February 15 falls on a Sunday this year, make sure that your form is postmarked or received before that date. The form requires disclosure of all political contributions made during the preceding calendar year by any covered individual whose contributions exceed $1,000 in the aggregate for the year. There is an alternative form (Form DSEB-504B) that must be filed when the contributions made in the previous year do not exceed the $1,000 aggregate limit. Electronic filing is not available in Pennsylvania, so the appropriate form must be submitted either by mail or by bringing a copy to the Department of State’s offices. Compliance Tip – Although Pennsylvania law prohibits corporate contributions, the definition of “covered individuals” is broad and includes a company’s officers, directors, associates, partners, owners and employees. The definition also includes the immediate family members of any covered individual. Whether a company is required to file Form DSEB-504 or Form DSEB-504B depends on whether any of these covered individuals made a contribution in excess of the $1,000 aggregate limit.