Pay-To-Play

News & Analysis as of

SEC Registered Investment Advisers—A Review of 2016 and a Look at What’s Ahead for 2017

As we near the seventh anniversary of the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), private equity and hedge fund advisers are subject to an ever-increasing degree of supervision...more

Is the Time Ripe for New Jersey Pay-to-Play Reform?

For more than a decade, New Jersey has had in place a series of pay-to-play laws that impose reduced contribution limits and heightened disclosure requirements for government contractors. The goal of these laws is to ensure...more

Questions & Answers on State and Local Variations on the SEC Pay-to-Play Rule

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

Deadline for New Jersey's Annual Pay-to-Play Disclosure is Approaching: Is Your Company Ready to File?

The New Jersey Election Law Enforcement Commission (“ELEC”) requires each business entity that received payments of $50,000 or more (in the aggregate) as a result of government contracts during the 2016 calendar year to...more

Plainfield Repeals Local Pay-to-Play Ordinance

New Jersey is home to a multitude of overlapping pay-to play laws. The State has a default statute covering pay-to-play restrictions at the municipal level. In 2006, however, the State Legislature allowed municipalities to...more

UPDATE: Continued Regulatory Focus on US Political Contributions

Recent actions by financial industry regulators, including the Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority, Inc. (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”),...more

When it Comes to Pay-to-Play, Not All Political Recipients are Created Equal

If any New Jersey State contractor or potential State contractor out there ever thought that it didn’t need to put political-activity and pay-to-play compliance at the top of its “To Do” list, we have a cautionary tale for...more

The Top Ten Regulatory and Litigation Risks for Private Funds in 2017

Private investment funds and advisers are likely to face new regulatory challenges and increased litigation risks in 2017, not only because of a change in the administration, but also because many advisers have not corrected...more

Ten Investment Advisory Firms Violate SEC's Pay-to-Play Rule

The Securities and Exchange Commission recently announced that ten investment advisory firms agreed to pay penalties in the tens of thousands of dollars to settle SEC charges that they violated the SEC’s pay-to-play rule,...more

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

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

Investment Management Legal + Regulatory Update – February 2017

REGULATION - DOL Issues Additional Guidance on Fiduciary Rule - On January 13, 2017, the U.S. Department of Labor (“DOL”) issued a second set of guidance on its new fiduciary rules, which are scheduled to become...more

Pay-to-Play Enforcement Sweep Snares Private Equity and Venture Capital

On January 17, 2017, the SEC announced nine settled enforcement actions for violations of the pay-to-pay rule against private equity, venture capital and hedge fund sponsors. The firms involved agreed to pay monetary...more

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

Former New York Pension Official and Two Broker-Dealers Charged In Pay-To-Play Scheme

On December 21, 2016, the SEC charged the former Director of Fixed Income for the New York State Common Retirement Fund (the “NYSCRF”) with allegedly steering billions of dollars of NYSCRF assets to two broker-dealers in...more

This Week In Securities Litigation

As the Christmas and holiday season approaches, the SEC brought a series of actions. Those included two settled FCPA actions filed in tandem with the DOJ, one of which also involved foreign regulators and the payment of about...more

"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

6th Circuit Orders Pay-to-Play Challenge to Merits Panel

The Sixth Circuit this week declined the SEC’s request to dismiss a Constitutional challenge to the new MSRB pay-to-play rules. Instead, the Court ordered the case to a merits panel for consideration. The Republican parties...more

Hedge Fund Seeks Absolution from the SEC Claiming the Potential Pay-to-Play Penalty Doesn’t Fit the Violation

Pershing Square Capital Management has found itself in the unenviable position of having to seek absolution from the Securities and Exchange Commission for the consequences of an unintended $500 pay-to-play error by one of...more

"Reminder: Maryland Pay-to-Play Report Due November 30"

We wish to remind you that companies with one or more Maryland state or local government contracts worth at least $200,000 are required to file semiannual pay-to-play reports with the Maryland State Board of Elections by May...more

"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

"FINRA Pay-to-Play Rule Effective August 20, 2017"

On October 24, 2016, the Financial Industry Regulatory Authority (FINRA) announced in Regulatory Notice 16-40 that its pay-to-play and related recordkeeping rules, FINRA Rules 2030 and 4580, will take effect on August 20,...more

SEC Approves FINRA Rules Addressing “Pay-to-Play” Practices

The Securities and Exchange Commission (the “SEC”) recently approved the Financial Industry Regulatory Authority, Inc. (“FINRA”) proposal to adopt FINRA Rules 2030 and 4580, which set forth pay-to-play restrictions, and...more

The Municipal Advisor Regulatory Framework - Where We Are and Where to Next

On September 19, 2016, the Municipal Securities Rulemaking Board ("MSRB") advised Congress that it had "just concluded development of a core regulatory framework for municipal advisors." This by no means signals a significant...more

6th Circuit Orders Pay-to-Play Challenge to Merits Panel

The Sixth Circuit this week declined the SEC’s request to dismiss a Constitutional challenge to the new MSRB pay-to-play rules.  Instead, the Court ordered the case to a merits panel for consideration.  The Republican parties...more

Local Campaign Finance Reform: Can Local Agencies Wean the Baby From “Mother’s Milk?” (Part 1)

It is an issue that has been with us since the earliest days of politics: The wealthy tend to have disproportionate influence over our political leaders in contrast to the poor and middle class. In the immortal words of the...more

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