The staff of the Securities and Exchange Commission's ("SEC") Division of Investment Management ("Staff") recently posted to the SEC's website responses to a series of questions (the "FAQs") raised by a new rule 206(4)-5 ("Rule") under the Investment Advisers Act of 1940 ("Advisers Act"). The Rule, which had a compliance date of March 14, 2011, for most advisers, is designed to limit pay-to-play practices involving public pension plans and other government entities. The Staff's FAQs offer clarity concerning some issues that have been raised by advisers, but may also create confusion on certain other issues.
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