News & Analysis as of

Political Contributions Pay-To-Play

Lowenstein Sandler LLP

SEC’s Pay-to-Play Crackdown: Settlement Sends Strong Message on Political Contributions

On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for...more

Nossaman LLP

Compliance Notes - Vol. 5, Issue 29

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Campaign Finance & Lobbying Compliance The Securities and Exchange Commission (SEC) has censured and fined a large, registered investment advisor, Obra Capital Management (Obra), $95,000 after learning an associate of the...more

Katten Muchin Rosenman LLP

Selection of Gov. Walz as VP Harris's Running Mate Triggers Federal Pay-to-Play Restrictions on Investment Advisers and Other...

Vice President Kamala Harris's selection of Minnesota Gov. Tim Walz as her running mate imposes restrictions on campaign contributions to the Harris-Walz campaign by federally registered investment advisers (RIAs), exempt...more

K&L Gates LLP

Selection of Gov. Walz as VP Candidate Implicates SEC Pay-To-Play Rule

K&L Gates LLP on

Kamala Harris’ selection of Tim Walz as running mate for her presidential campaign has implications under the Securities and Exchange Commission’s (SEC) Rule 206(4)-5 under the Investment Advisers Act (SEC Pay-to-Play Rule)....more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Presidential Election Campaign Donations May Trigger Investment Adviser “Pay to Play” Rule

Overview: Investment advisers that seek to manage public money need to consider the SEC’s “pay to play” rule, which restricts election-related contributions by the firms or their “covered associates” to elected state...more

Goodwin

Minnesota Governor Tim Walz’s National Candidacy Raises Significant Pay-to-Play Rule Considerations for Certain Investment...

Goodwin on

On August 6, 2024, the Democratic nominee for President, Kamala Harris, chose Tim Walz, Governor of Minnesota, as her running mate. This selection presents important considerations vis à vis the “Pay-to-Play Rule” (Rule...more

Cooley LLP

Remember Pay-to-Play Rule Before Making US Election Campaign Contributions

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On August 6, 2024, US Vice President Kamala Harris announced Minnesota Gov. Tim Walz as her running mate for the 2024 presidential election. This selection triggers the political contributions rule under the Investment...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Presidential Election Alert: Harris-Walz Campaign Now in General Election Period

On August 6, 2024, Vice President Kamala Harris accepted the Democratic nomination for president and announced Governor Tim Walz as her running mate. This marked the end of the primary election period for the Harris/Walz...more

WilmerHale

Pay-to-Play Alert: Implications of a Governor Joining a Presidential Ticket

WilmerHale on

Vice President Kamala Harris’ selection of Minnesota Governor Tim Walz as her running mate highlights a wrinkle in Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule” or “Rule”) to which investment advisers should...more

Akin Gump Strauss Hauer & Feld LLP

Walz’s Addition to Democratic Ticket Raises Pay-to-Play Issues for Donors in the Financial Industry

Employees of investment advisers must consider whether their employer is managing or seeking to manage public funds in Minnesota before donating to the Harris-Walz campaign this election season. Vice President Harris’...more

Proskauer - The Capital Commitment

Harris's Running Mate Announcement: Pay-to-Play Rule Implications for Investment Advisers

As reported today, Vice President Harris has announced Tim Walz, the sitting governor of Minnesota, as her running mate. This announcement is particularly significant for investment advisers due to the Advisers Act Political...more

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Harris/Walz Campaign Are Subject to Pay-to-Play Rules

Vice President Kamala Harris announced today that she has selected Minnesota Gov. Tim Walz as her vice presidential running mate in her bid for president. Contributions to the Harris/Walz campaign are now subject to the...more

Wiley Rein LLP

Pay-to-Play Rules Enter the 2024 Presidential Campaign

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On August 6, Vice President Kamala Harris selected Governor Tim Walz of Minnesota as her Vice-Presidential running mate for the 2024 general election. Since Governor Walz is a state official, his selection for the ticket...more

Royer Cooper Cohen Braunfeld LLC

Pay-to-Play: One Size Might Not Fit All?

The recent case involving Wayzata Investment Partners and the SEC highlights the potential consequences of pay-to-play violations in the investment advisory industry. It also highlights the effects of slow-moving policy...more

Wiley Rein LLP

Mind Your Ps (and Qs): Pay-to-Play and Procurement Lobbying for the Government Contractor

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If there are two political law compliance issues that perennially bedog federal, state, and local government contractors, it is the myriad of state and local pay-to-play laws and procurement lobbying laws. In the FAQs below,...more

Venable LLP

Political Giving: A Primer for High-Net-Worth Individuals and Family Offices

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For many years, supporters of a candidate or a cause simply wrote a check and asked friends and colleagues to do the same. But the opportunities to influence elections and public policy have evolved significantly, allowing...more

Proskauer - The Capital Commitment

Key Steps for Fund Managers to Avoid Scrutiny Under the SEC’s Pay-to-Play Rule

The SEC’s recent settlement involving a “pay-to-play” rule violation by a private equity firm is a timely reminder for fund managers, especially with the November elections approaching. As a refresher, Rule 206(4)-5 of...more

Wiley Rein LLP

How to Reduce Your Political-law Risk in Five Easy Steps

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Political-law risk is always present, but it becomes particularly acute in even-numbered election years such as 2024. Below, however, we outline five easy steps you and your organization - whether it is a corporation,...more

Venable LLP

Changes to Maryland Pay-to-Play Law Will Expand Reporting Obligations, Boost Public Scrutiny of State Public Contractors

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Starting this July, Maryland’s “pay-to-play” law, which requires public contractors to file campaign contribution disclosure reports with the State Board of Elections, will require for the first time that local government...more

Seward & Kissel LLP

SEC Charges Investment Adviser with Pay-to-Play Violation, Bringing Political Contributions into Focus During Election Year

Seward & Kissel LLP on

The SEC recently charged an investment adviser for violating Rule 206(4)-5 under the Advisers Act, known as the “Pay-to-Play Rule” (Rule). In settling the charges, the adviser agreed to pay a $60,000 penalty and was censured...more

Vedder Price

SEC Settles Enforcement Proceedings Against Adviser Regarding Alleged “Pay-to-Play” Political Contribution

Vedder Price on

On April 15, 2024, the SEC announced the settlement of administrative proceedings brought against a registered investment adviser for alleged violations of Section 206(4) of the Investment Advisers Act of 1940 and Rule...more

WilmerHale

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

WilmerHale on

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

Genova Burns LLC

Important Changes to the New Jersey ELEC Pay-to-Play Annual Disclosure

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New Jersey has long had a requirement for business entities that hold government contracts to file a Business Entity Annual Statement (“Form BE”). The Form BE, normally due on March 30 of each year, will be due on April 1,...more

Wiley Rein LLP

New Jersey Annual Pay-to-Play Report due April 1

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Despite major “reforms” to New Jersey’s pay-to-play laws in 2023, certain state and local government contractors doing business in New Jersey still must file the Business Entity Annual Disclosure Statement by April 1, 2024....more

Skadden, Arps, Slate, Meagher & Flom LLP

Reminder: New Jersey Pay-to-Play Form BE Due April 1, 2024

The annual filing for state and local contractors required under New Jersey Chapter 271 (Form BE) is due April 1, 2024. As we have described in previous mailings, this report must be filed by a business entity if it received...more

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