CBS News political analyst Frank Luntz had a major undisclosed conflict of interest while appearing on the network. While Luntz used his pre-election platform on CBS to praise Rep. Paul Ryan, his consulting firm, Luntz Global LLC, received $40,000 in consulting and polling fees from Rep. Paul Ryan's congressional campaign.

On CBS, Luntz called Ryan a “very popular” congressman who could help Romney win Wisconsin. Luntz also used his CBS appearances to attack his client's vice presidential opponent. He claimed that Biden's debate performance was a turnoff to voters and suggested it showed that the Obama administration can't work with Congress. Luntz made eleven CBS appearances to discuss the presidential campaign from September 24 -- when Luntz's firm first received a payment from Ryan -- through November.

According to reports filed with the Federal Election Commission, Ryan's successful 2012 congressional campaign paid Luntz Global LLC $20,000 on September 24 for “Polling: Dial Session” and $20,000 on October 9 for “Advertising: Ad Consulting.” UPDATE (12/7): Following the publication of this post, Ryan's campaign filed its post-general FEC report showing an additional $5,063.39 disbursement to Luntz Global on November 6 for “Advertising: Ad consulting expenses.”

Luntz is a Republican operative (despite some apparent confusion from CBS) who is perhaps best known for helping write and market Newt Gingrich's Contract with America. New York Times Magazine contributor Robert Draper reported that Luntz orchestrated a 2009 meeting where prominent Republicans, including Paul Ryan, formulated a plan to gain control of Congress and The White House.

Luntz's lack of disclosure may violate CBS Corporation's standards of conduct. The CBS Corporation Business Conduct Statement on conflicts of interest informs CBS employees, “including those employed on a temporary, freelance, intern, or per diem basis,” that “in all cases” they “must disclose all potential conflicts of interest” to CBS:

Disclosing and Addressing Potential Conflicts of Interest CBS requires that you disclose, in writing, any personal, business, or other relationship that could potentially affect your business judgment on behalf of your Company and CBS. The existence of a potential conflict of interest, such as one or more of the situations discussed below, does not necessarily constitute a violation of CBS's conflict of interest policy. Our policy is one of disclosure and review of potential conflicts and prohibition of actual conflicts of interest. In some cases, disclosure may be all that is required. In others, the situation may require additional action to avoid a conflict of interest or to remedy one. But remember, in all cases, you must disclose all potential conflicts of interest.

The document adds: “Even the appearance of a conflict of interest can undermine our integrity in the minds of our co-workers, our customers, our suppliers, or the public.”

Luntz also didn't disclose his financial relationship with Ryan during appearances on Fox News. On the October 29 edition of Fox News' Hannity (via Nexis), Luntz said: “I would tell people to be watching Wisconsin even more than Ohio. Paul Ryan is very popular there. He's known state wide. His numbers are fantastic, and that's a state that has already survived a recall. There's a good Republican organization on the ground because of the Scott Walker vote. The man did even better in the recall.” Luntz also conducted a live focus group on Fox following the October 11 vice presidential debate. Luntz Global states that Luntz is a Fox News contributor.

Luntz's failure to disclose his financial connection to Rep. Ryan was not his only undisclosed conflict of interest during recent media appearances. The day before the election, Fox & Friends hosted Luntz to praise a “powerful” ad from Karl Rove's super PAC, American Crossroads. Neither Luntz nor Fox disclosed that Crossroads had paid Luntz's firm more than $46,000 earlier in the year.

Requests for comment to CBS, Fox News and Luntz Global LLC were not returned.

Luntz Praised Ryan, Criticized Biden Debate Performance

Luntz appeared on CBS eleven times to discuss the presidential campaign following his firm's first payment from Ryan's campaign. Luntz primarily appeared on CBS This Morning, and also guested on Face The Nation and CBS' election results coverage. Luntz's appearances included praise of Ryan and criticism of Vice President Joe Biden's debate performance against Ryan.

CBS introduced Luntz in a variety of ways, including “CBS News political analyst,” “Republican strategist,” Republican pollster, and “former” Republican pollster.

On the November 2 edition of CBS This Morning, Luntz praised Ryan as a “very popular” congressman with “a very good favorability rating there [in Wisconsin]” and claimed the congressman could help swing the election for Romney. Despite Luntz's professed optimism for Romney's chances in Wisconsin, Obama consistently led in polls of the state. Nate Silver's November 6 forecast gave Obama a 96.7% chance of winning the state, which Obama won 53-46.

During a discussion of Ohio, Luntz said: “I want to throw something out to you. I think that Wisconsin -- we don`t talk about it that much -- that Wisconsin may be the balance to Ohio. It`s very popular for Paul-- Paul Ryan is known, and has a very good favorability rating there. They`ve got a Republican governor. They`ve got a key Senate race. And so you`re going to see a lot of Republicans going over just in the same general vicinity. Ohio is still in play but there are other states in the region that are equally important.”

Luntz later predicted that “if the vote is at this moment, I believe Mitt Romney wins the popular vote by the tiniest of margins. And I believe Barack Obama wins the Electoral College by the tiniest of margins.”

On October 20, Luntz called Biden's line that GM is alive and Osama bin Laden is dead the “best line of the campaign so far.” But Luntz then added: “Joe Biden actually said something intelligent for a change.”

On the October 14 edition of Face The Nation, host Bob Schieffer introduced Luntz as having “some very interesting research on the vice-presidential debate.” Luntz criticized Biden for his debate performance, stating that his focus group research showed that Biden “did well on the substance, but they were so angry with his style” :

BOB SCHIEFFER: And joining us now on my right Romney campaign adviser Bay Buchanan. Bay, good to have you. Republican pollster, Frank Luntz, plus, CBS political director John Dickerson, and over on the left, where they're very comfortable, David Corn, who writes for Mother Jones, he's the author of a new e-book out this week called 47 Percent, uncovering the Romney video that rocked the 2012 election. David, of course, is the one who broke that story. And also with us today, Katrina vanden Heuvel of The Nation magazine. I want to talk about this Libya thing and see what you all think is the political impact of that in a minute. But Frank Luntz is here, and you did some very interesting research on the vice-presidential debate. Bring us up to speed on what that was. FRANK LUNTZ (Republican Pollster): We've now done three sessions and they all concluded the same thing, that Joe Biden did well on the substance, but they were so angry with his style and the more that you split screen the two of them where they could see Biden's interruptions and the smiling and the laughing, it's funny because I actually wrote down on my note here, don't interrupt and don't smile. They didn't want that from the vice president. And he could have gained points, but not a single person in any session switched. In the previous debate we had about a third of our group switched.

However, a CBS News poll found that Biden overwhelmingly won the debate among uncommitted voters (50-31), and Ryan “faced a loss among voters' opinions of which candidate would be an effective president, if necessary.”

During his Face The Nation appearance, Luntz later added: “If you can't cooperate in a debate setting with your opponent, how can you cooperate with Congress? How can you work with the other side? And that's what they pointed out. It wasn't his performance that bothered them. They feel that Barack Obama can't work with Congress, and so if you vote for him again, you're going to get four more years of the same thing.”

At the end of the segment, Luntz said “my person is not Romney or the Democrats. I come here as a CBS News analyst.”

METHODOLOGY: Media Matters reviewed the following sit down CBS appearances by Luntz through Nexis and CBSNews.com: September 26 (CBS This Morning); October 4 (CBS This Morning); October 14 (Face The Nation); October 15 (CBS This Morning); October 20 (CBS This Morning: Saturday); October 22 (CBS This Morning); November 2 (CBS This Morning); November 6 (CBS This Morning); November 6 (CBS election results coverage); November 7 (CBS This Morning); November 14 (CBS This Morning). Media Matters also searched Nexis for Fox News transcripts containing “Luntz” and “Paul Ryan.” Appearances prior to the first Luntz-Ryan disbursement, and when the presidential election was not discussed, were not reviewed.