Pay-To-Play

News & Analysis as of

New Jersey Government Contractors: Don’t Let the Upcoming Pay-to-Play Filing Deadline Catch You Off Guard!

New Jersey’s Pay-to-Play Annual Disclosure filing deadline is imminent. By March 31, 2014, all for-profit businesses that have received aggregate payments of $50,000 or more during the 2013 calendar year as a result of New...more

"Government Affairs and Government Procurement: Pressure to Comply Continues to Grow in 2014"

With increased attention to transparency in corporate political spending, disclosure of so-called “dark money” and a new rule for municipal advisors, corporations and other organizations active in government affairs or...more

Spotlight on Mississippi: Opportunity for Legislature to Level Playing Field

New proposed legislation has been introduced in the Mississippi State Senate to reform several laws that directly affect Mississippi taxpayers. The new bill, S.B. 2487, was introduced on January 21, 2014 by the chairman of...more

Private Fund Adviser Receives Exemptive Relief from Two-Year Compensation Ban under Pay-to-Play Rule Triggered by Contribution to...

An SEC-registered adviser (the “Adviser”) was granted exemptive relief pursuant to Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) from the Rule’s two-year prohibition on receiving...more

First Pay-To-Play Exemption Becomes Effective For Hedge Fund

Rule 206(4)-5(a)(1) under the Investment Advisers Act prohibits a registered investment adviser from providing investment advisory services for compensation to a government entity within two years after a contribution to an...more

SEC Grants Rare Exemptive Relief from Pay-to-Play “Time-Out” Provision

In what may be a case of first impression, the SEC recently granted exemptive relief from Rule 206(4)-5(a)(1) of the Investment Advisers Act of 1940, the “time-out” provision of the pay-to-play rule. In general, Rule...more

Silicon Valley Venture Survey - Third Quarter 2013

We analyzed the terms of venture financings for 128 companies headquartered in Silicon Valley that reported raising money in the third quarter of 2013. Overview of Fenwick & West Results - Valuation results in...more

Questions & Answers on State and Local Variations on 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

First Formal Pay-To-Play Exemption Request

In 2011, so-called “pay-to-play” prohibitions under the Investment Advisers Act Rule 206(4)-5 (the Rule) went into effect. A recent U.S. Securities and Exchange Commission (SEC) exemptive order application addresses one...more

McCutcheon v. FEC: the Potential Impact on Aggregate Contribution Limits Under Local Pay-to-Play Ordinances

Last week the United States Supreme Court heard arguments in McCutcheon v. FEC, a challenge to the constitutionality of aggregate contribution limits under federal campaign finance law....more

In Proposed Amendments to Pay-to-Play Rules, the New Jersey State Investment Council Explains Indirect Violations

Comments are due today on proposed amendments to the New Jersey State Investment Council (“SIC”) Pay-to-Play Rules. ...more

What does the phrase “pay to play” mean?

The term “pay to play” is actually a negative phrase in the direct selling and MLM industry. It is used to reference a program which encourages independent distributors to make purchases to qualify for commissions and rank...more

Potential Pitfalls of Volunteer Employee Political Activity

As the New Jersey 2013 gubernatorial and legislative general election season kicks into high gear and as the State is preparing for a special primary and general federal election, New Jersey employees may get caught up in the...more

Additional Pay-to-Play Disclosure Required of Municipal Securities Dealers

Brokers, dealers, and municipal securities dealers are now required to disclose additional information about their bond ballot contributions under amendments to the Municipal Securities Rulemaking Board’s (MSRB) “pay-to-play”...more

New Bergen County Pay-to-Play Ordinance Requires County Vendors to File “REVUE 2” Form Today

Bergen County has now issued updated Political Contribution Disclosure Forms with which County vendors must comply. ...more

Trends in Legal Terms in Venture Financings in Israel 2012

Background — We have analyzed the terms of venture financings for Israeli and Israeli-related technology companies that reported raising money during 2012. Our survey does not include financing rounds of less than US...more

New Jersey Statewide Pay to Play Reform to be Introduced in the Senate Today

This afternoon, Senate Democrats plan to introduce legislation aimed to overhaul “loopholes” in New Jersey’s current pay-to-play laws. ...more

Better Business Bureau Shuts Down Southern California Chapter

The Better Business Bureau has announced that it has expelled its Southern California chapter following years of allegations that the local unit fostered a "pay for play" environment, requiring businesses to pay membership...more

SEC Releases 2013 Examination Priorities

On February 21, 2013, the US Securities and Exchange Commission (the “SEC”) released its examination priorities for 2013. The priorities were published by National Examination Program (“NEP”), a program administered through...more

SEC Announces 2013 Examination Priorities for the Investment Management Industry

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has published its list and discussion of examination priorities for the investment management industry in 2013, which includes both market-wide initiatives...more

Select Broker-Dealer, Investment Adviser, and Investment Company Enforcement Cases and Developments: 2012 Year in Review

This Outline highlights key U.S. Securities and Exchange Commission (the "SEC" or the "Commission") and Financial Industry Regulatory Authority ("FINRA") enforcement developments and cases regarding broker-dealers during...more

Goldman Sachs Pays First-Of-Its-Kind Settlement to Close Pay to Play Action with the SEC by Grant Nichols

On September 27, 2012, Goldman Sachs agreed to pay $12 million to settle claims with the Securities and Exchange Commission (“SEC”) alleging that one of its employees engaged in a pay-to-play scheme. The scheme, as described...more

Washington Insight: Corporate Lobbyist's Toolkit - January 2013

In This Issue: - Making Decisions on Corporate Campaign Expenditures - What’s in Store in Congresson Campaign Finance Reform? - DC Circuit Reversed Van Hollen. Players Changed Tactics to Avoid Disclosure. ...more

Skadden's 2013 Insights: Regulatory

Communications Law: The Relentless Pursuit of Broadband Competition - As the Obama administration enters its second term, the Federal Communications Commission (FCC or Commission) is one of many federal agencies likely...more

Orrick's Financial Industry Week in Review - December 3, 2012

In This Issue: - Financial Industry Developments · CFTC Final Rule on Clearing of Credit Default Swaps and Interest Rate Swaps · Fed, Treasury Proposed Amendments to Bank Secrecy Act Definitions...more

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