A Renewed Focus — On Pfizer’s Lobbying Disclosure Compliance Efforts — Part I of II

It’s suddenly a warm, quiet and sun-dappled Sunday morning here (after a truly ghoulish Irish ginger’s eighth-inning error in the Apple last night) — so I thought we’d begin to follow Pfizer again, a little more closely. Why? Well. . . there is talk of (i) another $100 billion plus inversion with Allergan (nominally in Ireland), and more immediately, because (ii) it seems Ian C. Read is now about ten days overdue in disclosing the Pfizer-led lobbying efforts and expenditures, during the third quarter of 2015. [Is he lobbying for. . . renewed inversion loopholes? We ought to be informed. In fact that’s why the timely disclosure laws exist.]

I’ll take the second one first, here today — because it’s easy. And I like easy, on Sundays. Here is the only remotely likely saving rule (which would allow Pfizer to avoid filing an LD-2 on or before October 20, 2015):

. . . .An organization employing in-house lobbyists whose total expenses in connection with lobbying activities do not exceed and are not expected to exceed $12,500 in the quarterly period during which the registration would be made is not required to be registered. . . .

Now, I suppose it is possible that — despite spending $2.1 million in the third quarter of 2014 — and between $1.2 million and $3.8 million dollars per quarter, every quarter since 1999 — Mr. Read simply turned off the faucet in Q3 2015. Possible. But unlikely. No, I think he’s overdue. What did he spend the shareholders’ money on, last quarter? The applicable federal law requires that he say, and say — in detail. All the other multi-national majors in our pharma space have already complied (Kenilworth plainly included here) — why hasn’t he? We will track this — and his renewed inversion efforts, now pretty closely, in the coming weeks — as time from our myriad other responsibilities permits. Onward!

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