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Pay-To-Play Enforcement Actions

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for August 2024

More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more

WilmerHale

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

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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

Goodwin

Exempt Reporting Advisers Faced Significantly More SEC Enforcements in 2022

Goodwin on

The Securities and Exchange Commission (SEC) brought an unusually high number of enforcement actions against exempt reporting advisers in 2022 — that appears to be more than the prior three years combined and a record number...more

WilmerHale

Pay-to-Play Update: A Quartet of Recent Settlements Underscores the Breadth of Risk Posed by Rule 206(4)-5

WilmerHale on

With the midterm elections less than a month away and political campaign activity in full swing, the Securities and Exchange Commission (SEC) has demonstrated a renewed interest in “pay-to-play” enforcement after a long...more

Goodwin

Dismissal of Putative Securities Class Action for Bellus Health, Inc.

Goodwin on

On September 21, 2022, U.S. District Judge George B. Daniels of the Southern District of New York dismissed with prejudice a putative securities class action against BELLUS Health, Inc. and certain of its officers....more

Lowenstein Sandler LLP

Strengthened SEC Enforcement Activity is a Reminder that Investment Advisers Must Ensure their Practices and Procedures are...

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As evidenced by an influx of recent activity over the past month, it’s becoming more and more apparent that the U.S. Securities and Exchange Commission (SEC) is strengthening its regulatory framework and pushing forward with...more

K&L Gates LLP

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

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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

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - February & March 2020

IN THIS ISSUE - • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

McDermott Will & Emery

Massachusetts’ Highest Court Upholds Record Fine Against Beer Distributor for Pay-To-Play Scheme But Overturns Fine for Bar that...

Last week, the Massachusetts Supreme Judicial Court upheld a $2.6 million fine against beer wholesaler Craft Brewers Guild (a Sheehan family-owned company) for violating anti-price discrimination statutes and commercial...more

Pillsbury Winthrop Shaw Pittman LLP

Private Funds Litigation/Regulatory Year in Review and 2019 Outlook

Although the SEC did not bring as many headline enforcement actions against private funds as in years past, it continues to devote substantial resources and attention on investment advisers. The SEC will maintain its...more

Skadden, Arps, Slate, Meagher & Flom LLP

Enforcement Sweep Under Maryland Pay-to-Play Reporting Law and Reminder of November Filing

The Maryland State Board of Elections recently sent out a notice to pay-to-play law filers for whom it is missing an Initial Report....more

Blank Rome LLP

Regulatory Update and Recent SEC Enforcement Actions

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REGULATORY UPDATE - Ten Investment Advisory Firms Subject to Steep Penalties after Violating Pay-to-Play Rules - In January 2017, 10 investment advisory firms agreed to settle with the U.S. Securities and Exchange...more

Dechert LLP

UPDATE: Continued Regulatory Focus on US Political Contributions

Dechert LLP on

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

Stinson - Corporate & Securities Law Blog

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

Ballard Spahr LLP

Investment Management Update

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SEC Enforcement Action against Private Equity Fund Adviser - On June 1, 2016, the SEC announced that a private equity fund adviser and its principal owner agreed to pay more than $3.1 million to settle SEC charges that,...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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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

Ballard Spahr LLP

Recent Investment Management Developments - June 2015

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In This Issue: - SEC Proposes Changes to Reporting and Disclosure Obligations for Investment Companies and Advisers - SEC Charges Hedge Fund Executives and External Auditor for Improper Disclosure of Expense...more

Goodwin

Financial Services Weekly News Roundup - January 2015 #4

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The CFTC Exercises Expanded Jurisdiction Over Retail Transactions in Physical Commodities. Title VII of the Dodd-Frank Act of 2010 amended the Commodity Exchange Act (CEA) to add new authority over certain leveraged,...more

K&L Gates LLP

2014 SEC and FINRA Enforcement Actions Against Broker-Dealers and Investment Advisers

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The sheer number of enforcement actions brought against broker-dealers and investment advisers makes it challenging to keep up. In this alert, we divide this year’s most important cases against broker-dealers and investment...more

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update -- September 2014

In This Issue: - Regulation: Long-Awaited Money Market Fund Rules Adopted - SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms - SEC Staff Closes Loophole on BDC Asset...more

Goodwin

SEC Settles with Exempt Reporting Adviser over Pay-to-Play Violations

Goodwin on

The SEC settled public administrative proceedings against TL Ventures Inc., a venture capital fund adviser (the “Adviser”), over violations of Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the...more

Goodwin

SEC Integrates Two Exempt Reporting Advisers to Determine Advisers Act Registration Status

Goodwin on

The SEC settled public administrative proceedings against TL Ventures Inc., a venture capital fund adviser (the “VC Fund Adviser”) and Penn Mezzanine Partners Management, L.P. (the “Private Fund Adviser” and with the VC Fund...more

Dorsey & Whitney LLP

This Week In Securities Litigation (Week ending June 27, 2014)

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The Supreme Court handed down its much anticipated decision in Halliburton. While the Court declined to overrule Basic and its presumption of reliance based on the fraud-on-the-market theory, it did alter existing practice....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

Ballard Spahr LLP

SEC Announces First Investment Adviser ‘Pay-to-Play’ Enforcement Action

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The U.S. Securities and Exchange Commission (SEC) announced its first enforcement action under "pay-to-play" rules for investment advisers since those rules were adopted nearly four years ago. TL Ventures Inc., a...more

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