Former U.S. Sen. Chris Dodd (D-Conn.) left his perch on the powerful Senate Banking Committee with the conclusion of the 111th Congress, and today was named chairman and CEO of the Motion Picture Association of America. For some, this is an eyebrow raiser; does Dodd’s new position with MPAA pit him in conflict with the Senate’s revolving door rules?
Though the chairman/CEO does not actually lobby the government, there is no question that Dodd will have some influence over the association’s lobbying activities, which makes this case a little tricky to hold up to the rules light. The rule says that a Senator may not lobby any Member, officer, or employee in either chamber for two years , and may not assist with any official actions by U.S. government officials on behalf of foreign governments. It also says a senator is prohibited from engaging in any discussions to accept such a position until after his successor has been named (which, in Dodd’s case, has happened), including positions that could involve a former senator in “indirect lobbying” — activities in support of other people’s lobbying, but which do not involve actions that would trigger registration.
Sen. Dodd’s acceptance of the position, which was made public today, is not in direct violation of the rules, assuming Dodd does not lobby Congress on any issues until the 113th Congress. The Senate does not have the specific guidelines on “advocacy contacts” that the House details. So, as long as Dodd does not directly contact a Member of Congress with the intent to influence action, he is not in violation of any Senate revolving door guidelines, but he should probably tread lightly.