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Chicago Nonprofit Update: Implementation of New Lobbying Ordinance Delayed Until January 1, 2021

Tax-Exempt Organizations Alert Jodi P. Patt, Norah L. Jones, Jacob L. Zerkle

Many Chicago nonprofits were relieved that implementation of the City’s new Governmental Ethics Ordinance (the “Amended Ordinance”) was delayed from its original effective date of January 1, 2020, to April 20, 2020, and then to July 1, 2020. In a June 18, 2020, press release (available here), the Board of Ethics cited the COVID-19 crisis and again delayed implementation of the Amended Ordinance, this time until January 1, 2021:

As the City and many non-profit organizations in Chicago and environs continue to work together to respond to the COVID-19 crisis, delaying implementation of the City’s non-profit lobbying laws until January 1, 2021 is appropriate. The Board and Mayor’s Office continue to be committed to working diligently with non-profit organizations and stakeholders to understand and respond to their concerns about this law, and on working toward amendments that increase transparency in Chicago.

You may recall that the Amended Ordinance imposes new registration and reporting requirements on individuals who interact with the City of Chicago on behalf of nonprofit organizations and the communities they serve (click here for QB’s initial analysis). In response to certain concerns raised by Chicago’s nonprofit community, the Board of Ethics has issued four binding advisory opinions (each, an “Advisory Opinion”), three on January 13, 2020 (click here for a complete copy) and a fourth on February 10, 2020 (click here for a complete copy). Each Advisory Opinion addresses certain common interactions between nonprofit organizations and the City of Chicago and then indicates whether each set of facts constitutes lobbying under the Amended Ordinance. Although not every question is addressed by these Opinions, they are extremely helpful in clarifying the application of the Amended Ordinance to specific situations.

We will continue to monitor these issues as the new implementation date approaches. If your organization intends to interact with the City of Chicago in a manner that does not clearly fall within the scenarios described in the four Advisory Opinions, please consult with an attorney in the Tax-Exempt Organizations Group at Quarles & Brady about how the Amended Ordinance may apply in your organization. For more information, please contact: