News & Analysis as of

Investment Advisers Act of 1940 Compliance Pay-To-Play

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's August 2024 Round-Up

Eighth Circuit Invalidates Missouri's Two-Year Lobbying Ban for Former Legislators and Staffers - The Eighth Circuit Court of Appeals invalidated a Missouri state constitutional amendment that imposed a two-year lobbying...more

Proskauer - The Capital Commitment

Key Steps for Fund Managers to Avoid Scrutiny Under the SEC’s Pay-to-Play Rule

The SEC’s recent settlement involving a “pay-to-play” rule violation by a private equity firm is a timely reminder for fund managers, especially with the November elections approaching. As a refresher, Rule 206(4)-5 of...more

WilmerHale

Recent Pay-to-Play Settlement: Notwithstanding a Strong Dissent Over 206(4)-5 Overbreadth, the Need for Strong Compliance Policies...

WilmerHale on

With political campaign activity ramping up as the fall elections approach, the Securities and Exchange Commission (SEC) has indicated it will continue stringent enforcement of Investment Advisers Act Rule 206(4)-5 (the...more

WilmerHale

Recent Exemptions from Rule 206(4)-5 Demonstrate the Importance of Strong Compliance Policies and Quick Corrective Action

WilmerHale on

Recently, the Securities and Exchange Commission (SEC) has demonstrated its willingness to largely forgo the strict consequences of Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule”) in circumstances where...more

K&L Gates LLP

Compliance Reminder: Pay-to-Play and the 2020 Election Cycle

K&L Gates LLP on

INTRODUCTION - As the November 2020 elections approach, investment advisers and other financial institutions who do business with, or seek to do business with, public pension plans and other government entities should...more

Morrison & Foerster LLP

Investment Adviser Compliance Index - 2019

The Investment Advisers Act of 1940 (the “Advisers Act”) is the shortest of the federal securities laws enacted after the Great Depression, and the SEC has adopted relatively few regulations under the Advisers Act. As any...more

Womble Bond Dickinson

DC Circuit Court Rejects Challenge to SEC Pay-to-Play Rule

Womble Bond Dickinson on

The DC Circuit Court has rejected an effort by the New York and Tennessee Republican Parties to set aside Securities and Exchange Commission Rule 206(4)-5. The 2010 SEC rule prohibits investment advisers from providing...more

Burr & Forman

DC Circuit Tosses Republican’s Challenge to Adviser Pay-to-Play Rule

Burr & Forman on

The District of Columbia Circuit Court of Appeals Tuesday rejected a challenge to the SEC’s investment-adviser pay-to-play rule, holding that two state Republican Party organizations filed it almost four years too late....more

Latham & Watkins LLP

SEC Announces Compliance Date for Pay-to-Play Rule

Latham & Watkins LLP on

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)...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Issues Fine in Pay-to-Play Rule and Registration Requirement Violation Case"

On June 20, 2014, the Securities and Exchange Commission ("SEC") censured and fined investment adviser TL Ventures Inc. for violating the SEC's pay-to-play rule, Rule 206(4)-5 (the "Rule"), and failing to properly register...more

10 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide