CONTRIBUTES TO ANY CAMPAIGN FUND OF ANY POLITICAL PARTY OR TO ANY PERSON FOR THE BENEFIT OF SUCH PARTY OR ITS CANDIDATES DOES SO ON BEHALF OF THE CORPORATION. WHETHER ANY PARTICULAR ATTORNEY IS ACTING ON BEHALF OF A CORPORATION WOULD HINGE UPON THE FACTS OF EACH CASE. THE COUNCIL ON CAMPAIGN COMPLIANCE AND ETHICAL STANDARDS IS AUTHORIZED TO ISSUE ADVISORY OPINIONS TO PERSONS WISHING TO KNOW WHETHER A PARTICULAR CONTRIBUTION WOULD VIOLATE THE ETHICS ACT. FURTHER REQUESTS FOR INFORMATION SHOULD BE DIRECTED TO THE COUNCIL.
HOPEFULLY, IT IS APPARENT THAT A DEFINITIVE ANSWER TO YOUR QUESTION ABOUT THE PROPRIETY, AS A MATTER OF LAW, OF ATTORNEY CONTRIBUTIONS OUTSIDE 17 O.S. 177 120-DAY WINDOW PERIOD IS NOT POSSIBLE. IT IS POSSIBLE, HOWEVER, THAT IN A GIVEN FACTUAL SETTING, THE ETHICS COUNCIL OR AN OKLAHOMA COURT MIGHT WELL FIND THAT A GIVEN ATTORNEY, OR ANY ATTORNEY WITH AN ACTIVE BUSINESS RELATIONSHIP WITH A COMMISSION-REGULATED CLIENT, IS WITHIN THE PROHIBITORY SCOPE OF 74 O.S. 4219 AND 17 O.S. 77. THUS, THERE IS IN MY VIEW, A SUBSTANTIAL RISK IN SOLICITING OR ACCEPTING SUCH CONTRIBUTIONS.
(NED BASTOW)