News & Analysis as of

Commodities Futures Trading Commission Pay-To-Play

The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from... more +
The United States Commodities Futures Trading Commission was created in 1974 to regulate commodity futures and option markets. The Commission’s mission is to protect market participants and the public from fraud, abuse, and systemic risk associated with derivatives subject to the Commodities Exchange Act. In 2010, as a result of the Frank-Dodd Wall Street Reform and Consumer Protection, the Commission’s role was expanded to include drafting rules for regulating the swaps marketplace. less -
Katten Muchin Rosenman LLP

Selection of Gov. Walz as VP Harris's Running Mate Triggers Federal Pay-to-Play Restrictions on Investment Advisers and Other...

Vice President Kamala Harris's selection of Minnesota Gov. Tim Walz as her running mate imposes restrictions on campaign contributions to the Harris-Walz campaign by federally registered investment advisers (RIAs), exempt...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Presidential Election Campaign Donations May Trigger Investment Adviser “Pay to Play” Rule

Overview: Investment advisers that seek to manage public money need to consider the SEC’s “pay to play” rule, which restricts election-related contributions by the firms or their “covered associates” to elected state...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Presidential Election Alert: Harris-Walz Campaign Now in General Election Period

On August 6, 2024, Vice President Kamala Harris accepted the Democratic nomination for president and announced Governor Tim Walz as her running mate. This marked the end of the primary election period for the Harris/Walz...more

Akin Gump Strauss Hauer & Feld LLP

Walz’s Addition to Democratic Ticket Raises Pay-to-Play Issues for Donors in the Financial Industry

Employees of investment advisers must consider whether their employer is managing or seeking to manage public funds in Minnesota before donating to the Harris-Walz campaign this election season. Vice President Harris’...more

Dechert LLP

Contributions to the Harris Presidential Campaign Subject to Federal "Pay-to-Play" Rules

Dechert LLP on

Vice President Kamala Harris announced Minnesota Governor Tim Walz as her running mate for the upcoming Presidential election. Because Governor Walz is an “official” for purposes of the SEC’s pay-to-play rule under the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Harris/Walz Campaign Are Subject to Pay-to-Play Rules

Vice President Kamala Harris announced today that she has selected Minnesota Gov. Tim Walz as her vice presidential running mate in her bid for president. Contributions to the Harris/Walz campaign are now subject to the...more

Wiley Rein LLP

Pay-to-Play Rules Enter the 2024 Presidential Campaign

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On August 6, Vice President Kamala Harris selected Governor Tim Walz of Minnesota as her Vice-Presidential running mate for the 2024 general election. Since Governor Walz is a state official, his selection for the ticket...more

Skadden, Arps, Slate, Meagher & Flom LLP

Presidential Election Alert: Campaign Finance Implications for Harris for President

On July 21, 2024, President Joseph Biden announced that he was ending his bid for reelection and instead endorsing Vice President Kamala Harris for president. A presumptive nominee withdrawing so close to the party convention...more

Wiley Rein LLP

Mind Your Ps (and Qs): Pay-to-Play and Procurement Lobbying for the Government Contractor

Wiley Rein LLP on

If there are two political law compliance issues that perennially bedog federal, state, and local government contractors, it is the myriad of state and local pay-to-play laws and procurement lobbying laws. In the FAQs below,...more

Wiley Rein LLP

Pay-to-Play Compliance Down the Stretch in the 2023 Elections

Wiley Rein LLP on

The 2023 elections are a little over a month away, and hopefully, if your corporation holds or seeks state and local government business, you have been regularly reminding your directors, officers, and other employees about...more

Akin Gump Strauss Hauer & Feld LLP

North Dakota Governor Seeks GOP Presidential Nomination: Pay-to-Play Considerations

North Dakota Governor Doug Burgum announced his candidacy for the 2024 GOP Presidential nomination on June 7, 2023.  His announcement, on the heels of Florida Governor DeSantis’ May 24 announcement, highlights the urgent need...more

Akin Gump Strauss Hauer & Feld LLP

Pay-to-Play Laws May Hinder Governor DeSantis’ Presidential Fundraising

After recently signing legislation allowing state officeholders to run for president without resigning from office, Florida Gov. Ron DeSantis has officially entered the 2024 presidential race. As a sitting governor, DeSantis...more

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Florida Gov. Ron DeSantis’ Presidential Campaign Are Subject to Federal Pay-to-Play Rules

Florida Gov. Ron DeSantis filed paperwork on May 24, 2023, to run for president in the 2024 election. In light of his announcement, it is important to keep in mind that contributions made to or solicited on behalf of Gov....more

Goodwin

Dismissal of Putative Securities Class Action for Bellus Health, Inc.

Goodwin on

On September 21, 2022, U.S. District Judge George B. Daniels of the Southern District of New York dismissed with prejudice a putative securities class action against BELLUS Health, Inc. and certain of its officers....more

Pillsbury Winthrop Shaw Pittman LLP

Text, Alexa, Bitcoin—Technology Makes Political Contributions Easier

Is your political compliance program ready for the 2020 election season? With the 2020 election season underway, now is a good time to make certain your internal policies and procedures address applicable campaign...more

Skadden, Arps, Slate, Meagher & Flom LLP

An Update for Financial Institutions on Presidential Candidates Covered Under Federal Pay-to-Play Rules

Financial institutions and their employees may be subject to the following federal pay-to-play rules: SEC Rule 206(4)-5 for investment advisers; CFTC Rule 23.451 for commodities-backed swap dealers; FINRA Rule 2030 for...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Political Law: What to Consider When Providing Investment Fund Services to US State and Local Government...

With heightened attention to investment and depository rules as well as increased enforcement of federal and state pay-to-play rules, registered investment advisers (RIAs) and broker-dealers should address the unique legal...more

Skadden, Arps, Slate, Meagher & Flom LLP

Post-Election Issues (Inaugurations, Transitions, and Special Elections)

Now that the 2018 midterm elections are over, we must contend with legal issues that arise from activities related to federal, state and local inaugural and transition committees, as well as recounts and runoff elections. As...more

Akin Gump Strauss Hauer & Feld LLP

Investment Management Special Report - 2017-18 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals. ...more

Foley Hoag LLP

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

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Investment Advisers - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or The Commonwealth of Massachusetts are required to review their compliance...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues Interpretation on Federal Transition and Inaugural Contributions

On December 23, 2016, the Commodity Futures Trading Commission’s Division of Swap Dealer and Intermediary Oversight (DSIO) issued a staff interpretation saying that, in its view, contributions by swap dealers and their...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Developments: Applying Federal Pay-to-Play Rules to Trump/Pence Inaugural and Transition Committees"

For financial institutions subject to federal pay-to-play rules (SEC Rule 206(4)-5 for investment advisers, MSRB Rule G-37 for municipal bond underwriters and municipal advisors, and CFTC Rule 23.451 for swap dealers),...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Post-Election Issues"

Now that the 2016 elections are over, we must contend with special legal issues that arise from contributions made to, and expenses incurred for, federal, state or local inaugural or transition committees, as well as recounts...more

Clark Hill PLC

The Federal Securities Pay-to-Play Regulatory Framework is Complete - A Primer for Financial Services Firms

Clark Hill PLC on

On September 20, 2016, the Securities and Exchange Commission ("SEC") issued two orders effectively completing the federal pay-to-play regulatory framework for investment advisers, municipal advisors, underwriters of...more

K&L Gates LLP

Impact of Pay-to-Play Rules in the 2016 Election Cycle

K&L Gates LLP on

The federal Pay-to-Play Rules may impact campaign contributions in the 2016 election and, in particular, campaign contributions to a major party’s presidential campaign. Financial institutions that do business with, or seek...more

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