News & Analysis as of

Effective Date of Investment Adviser Pay-to-Play Rule Ban on Third-Party Solicitation

The Securities and Exchange Commission’s Rule 206(4)-5 (Pay-to-Play Rule) under the Investment Advisers Act of 1940, as amended, prohibits, among other restrictions, an investment adviser subject to the rule, and its covered...more

SEC Announces Compliance Date for Pay-to-Play Rule

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

FINRA Solicitor Pay-to-Play Rules Complete IA & MSRB Suite

Last Friday, FINRA proposed pay-to-play prohibitions that parallel and implement similar Investment Adviser Act provisions in Rule 206(4)-5. That IA Rule prohibits investment advisers from paying third-parties to solicit...more

Financial Services Weekly News Roundup - November 2014 #3

FINRA Requests Comment on Proposed “Pay-to-Play” Rule - FINRA issued Regulatory Notice 14-50 requesting comment on proposed “pay-to-play” and related rules that would regulate in a manner similar to Rule 206(4)-5 under...more

"Disclosure and Collateral Consequences of Enforcement Actions for Regulated Financial Services Firms"

Financial services firms facing enforcement proceedings at the hands of the U.S. Securities and Exchange Commission (SEC) or any other financial industry regulator must consider disclosure obligations in the context of the...more

New Freedoms & Heightened Scrutiny Complicate the US Private Fund Marketing Environment

Originally published in CorporateLiveWire on February 21, 2013. The last few years have witnessed tectonic shifts in U.S. laws and regulations that effect the management and operations of hedge funds, private equity...more

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