Placement agents to private funds who seek investments by state and local pension plans must comply with restrictions on political contributions and related activities.

On August 25, 2016, the Securities Exchange Commission (SEC) approved Pay-to-Play Rules 2030 and 4580 (the Rules) submitted by the Financial Industry Regulatory Authority (FINRA).1 The impact of the approved Rules will be felt primarily by placement agents for investments by government instrumentalities, such as public pension funds, in private funds.