Despite the July 31, 2015 compliance date, the SEC will not enforce the third-party solicitation ban until corresponding FINRA/MSRB Rules take effect.

On June 25, 2015, the Securities and Exchange Commission (SEC) announced a compliance date of July 31, 2015 for the provision of its Pay-to-Play Rule under the Investment Advisers Act of 1940 that requires third-party solicitors be subject to a similar pay-to-play regime. Some had thought that the SEC would require compliance with the third-party solicitation ban as early as April 1, 2015. While the SEC has now established the compliance date at the end of this month, it also provided guidance that will allow time for the Financial Industry Regulatory Authority (FINRA) and the Municipal Securities Rulemaking Board (MSRB) to finalize their own pay-to-play rules.