Pay-To-Play

News & Analysis as of

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement - FINRA’s Proposed Pay-to-Play Rule Will Impact Investment Advisers - Late last year (December 24, 2015), the Financial Industry Regulatory Authority (FINRA) submitted a proposed rule to the U.S....more

Trends in Legal Terms in Venture Financings in Israel - First Half 2015

Background —We have analyzed the terms of venture financings for Israeli and Israeli-related technology companies that reported raising money during H1 2015. Our survey does not include financing rounds of less than US...more

SEC Announces Settlement with State Street – and a Suit Against a Big Law Partner – for Pay-to-Play Scheme

On January 14, 2016, the SEC entered into two no-admit, no deny settlements regarding an alleged pay-to-play scheme to obtain contracts from the Treasury Office for the State of Ohio. The first was with State Street Bank and...more

"Political Contribution Disclosure Rules in Maryland, New Jersey, Pennsylvania and Rhode Island"

The following describes the reporting requirements under Maryland, New Jersey, Pennsylvania and Rhode Island laws for certain corporate entities to file reports regarding their business relationships with these states, as...more

Decision 2016: Is Your Company Ready?

The 2016 election season is fast approaching. As companies begin to plan their political participation for the coming year, government affairs staff and compliance counsel should closely consider whether there are any...more

Pay-to-Play: FINRA Requests SEC Approval of Proposal to Regulate Political Contributions

The Securities and Exchange Commission (“SEC”) recently published for comments rules proposed by the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Municipal Securities Rulemaking Board (“MSRB”) to regulate...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...more

OCIE Publishes Exam Priorities for 2016

The National Exam Program of the SEC’s Office of Compliance Inspections and Examinations (OCIE) published its examination priorities for 2016 this week. Much like last year’s letter, this year’s letter is organized around...more

New procurement lobbying, ethics and pay-to-play provisions

The political headlines from last year's battle over lobbying and ethics reform legislation in the Commonwealth of Virginia may have long faded from public memory, but the legal realities of the enacted law—Senate Bill No....more

Revised Pay-to-Play Rules

The Securities and Exchange Commission is seeking comments on a revised proposal recently filed by the Financial Industry Regulatory Authority to establish “pay-to-play” and related rules regulating the activities of FINRA...more

Corporate and Financial Weekly Digest - Volume XI, Issue 1

SEC/CORPORATE - PCAOB Adopts New Rules Requiring Disclosure of Participants in an Audit - On December 15, 2015, the Public Company Accounting Oversight Board (PCAOB) adopted new rules and related amendments to...more

Pay-to-Play Resolutions

As we approach the end of the first work week of 2016, companies should be thinking about their “pay-to-play resolutions” in the upcoming year. New Jersey is home to numerous and varied pay-to-play restrictions. One misstep...more

"FINRA Submits Pay-to-Play Rule 2030 to SEC for Approval"

On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) submitted Rules 2030 and 4580 (the Draft Rules) to the Securities and Exchange Commission (SEC) for approval. The Draft Rules set forth pay-to-play...more

"MSRB Submits Pay-to-Play Rule G-37 Amendments to SEC for Approval"

On December 16, 2015, the Municipal Securities Rulemaking Board (MSRB) filed its draft amendments to Rule G-37 on political contributions (the Draft Rule) with the Securities and Exchange Commission (SEC). The Draft Rule...more

"FINRA and MSRB Submit Pay-to-Play Rules to SEC for Approval"

On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) and Municipal Securities Rulemaking Board (MSRB) submitted their respective pay-to-play rules to the Securities and Exchange Commission (SEC) for...more

MSRB Files New MA Pay-to-Play Rule with SEC

On December 16, the Municipal Securities Rulemaking Board (“MSRB”) filed with the SEC a proposed rule that would extend to municipal advisers the MSRB’s existing rule prohibiting “pay-to-play” practices and restricting...more

Broker-Dealer “Pay-to-Play” Rule Proposed to SEC

Last week FINRA proposed for SEC adoption a “pay-to-play” rule for broker-dealers engaged in distribution or solicitation activities with government entities.  The Proposed Rule is modeled after investment-adviser pay-to-play...more

Public-Private Partnerships and Pay-to-Play in New Jersey: “P3s and P2P in the Garden State”

Public-Private Partnerships (commonly known as “P3s”) are very popular across the country, including the recently announced renovations at LaGuardia Airport as one example. P3s are also gaining significant attention here in...more

"Reminder: Maryland Pay-to-Play Report Due November 30, 2015"

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 each...more

Conducting a pay-to-play fantasy sports league may be gambling with the law

Participation in fantasy sports has exploded in the United States in the past few years. Anyone listening to sports radio or watching ESPN will be overwhelmed by advertisements from fantasy football organizations soliciting...more

"Maryland Proposes Regulations Regarding Its Pay-to-Play Reporting Law"

The Maryland Board of Elections recently proposed regulations regarding its pay-to-play reporting law, which was amended earlier this year and now requires companies that have one or more Maryland state or local government...more

Allen & Overy Partner Co-Authors Chapter on Swap Dealer Pay-to-Play Rule in 2015 Edition of Book on Regulation under Dodd-Frank

The 2016 elections pose potentially significant set of compliance challenges for swap dealers subject to CFTC Rule 23.451, the pay-to-play rule established by the U.S...more

Pay to Play: Appellate Division Upholds Ruling that Payment is Required to Qualify for Champerty Safe Harbor Provision

In Justinian Capital SPC v. WestLB AG, etc. et al., 2015 N.Y. Slip Op. 04381 (1st Dep’t May 21, 2015), the Appellate Division affirmed the February 25, 2014 decision of the New York County Supreme Court, Commercial Division...more

"DC Circuit Dismisses Challenge to SEC Rule 206(4)-5"

On August 25, 2015, the U.S. Court of Appeals for the District of Columbia Circuit upheld the D.C. District Court’s dismissal of a challenge to Securities and Exchange Commission (SEC) pay-to-play Rule 206(4)-5 (the Rule) and...more

Financial Services Weekly News - August 2015 #4

Regulatory Developments - CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps: On Aug. 19 the CFTC announced that it had voted to propose amendments to existing...more

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