SEC Adopts Pay-To-Play Rule for Investment Advisers


After almost a year of deliberations, on June 30 the SEC approved a “pay-to-play” rule that restricts political contributions by investment advisers that seek business from public pension funds and similar government investment accounts. These pension plans control over $2.6 trillion in assets and account for one-third of all U.S. pension assets.

This client alert summarizes key provisions and compliance considerations, as well as record-keeping obligations.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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