In light of recent news reports on stock trades made by certain senators after they received intelligence briefings on the COVID-19 crisis, we want to remind you of the provisions of the Stop Trading on Congressional...more
On June 18, 2019, the U.S. Court of Appeals for the District of Columbia Circuit (the court) dismissed a challenge to Financial Industry Regulatory Authority (FINRA) pay-to-play Rule 2030 (the rule) brought by the New York...more
6/28/2019
/ Administrative Authority ,
Arbitrary and Capricious ,
Campaign Contributions ,
Corruption ,
Dismissals ,
Federal Contractors ,
Federal Election Campaign Act ,
Financial Industry Regulatory Authority (FINRA) ,
First Amendment ,
Government Entities ,
Important Governmental Objectives ,
Investment Adviser ,
Pay-To-Play ,
Political Contributions ,
Political Parties ,
Preemption ,
Securities and Exchange Commission (SEC) ,
Solicitation ,
Standing
Financial institutions and their employees may be subject to the following federal pay-to-play rules: SEC Rule 206(4)-5 for investment advisers; CFTC Rule 23.451 for commodities-backed swap dealers; FINRA Rule 2030 for...more
5/2/2019
/ Broker-Dealer ,
CFTC ,
Commodities-Backed Swap ,
De Minimus Doctrine ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Investment Adviser ,
MSRB ,
Municipal Advisers ,
Pay-To-Play ,
Political Contributions ,
Securities and Exchange Commission (SEC) ,
Swap Dealers
Now that the 2018 midterm elections are over, we must contend with legal issues that arise from activities related to federal, state and local inaugural and transition committees, as well as recounts and runoff elections. As...more
11/14/2018
/ 501(c)(3) ,
501(c)(4) ,
Broker-Dealer ,
Campaign Finance Reform ,
CFTC ,
Conflicts of Interest ,
Consultants ,
Corporate Executives ,
Corporate Gifts ,
General Elections ,
Inauguration Committees ,
Lobbying ,
MSRB ,
Municipalities ,
PACs ,
Pay-To-Play ,
Political Contributions ,
Political Parties ,
Recount Committees ,
Securities and Exchange Commission (SEC) ,
Special Election ,
State and Local Government ,
State Elections ,
State Procurement Contracts ,
Transition Team
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
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
11/14/2016
/ CFTC ,
Corporate Executives ,
Disclosure Requirements ,
Financial Institutions ,
Inauguration Committees ,
Lobbying ,
MSRB ,
PACs ,
Pay-To-Play ,
Political Contributions ,
Public Employees ,
Recount Committees ,
Securities and Exchange Commission (SEC) ,
Special Election ,
State and Local Government
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
This week, on Thursday, August 25, 2016, the SEC approved FINRA Proposed Rules 2030 and 4580 (the Proposed Rules) as they had been proposed by FINRA. The Proposed Rules would impose pay-to-play restrictions and recordkeeping...more
On June 21, 2016, the Financial Industry Regulatory Authority extended the time for the Securities and Exchange Commission (SEC) to act on Proposed Rules 2030 and 4580 (the Proposed Rules) to August 26, 2016. The Proposed...more
On March 29, 2016, the Securities and Exchange Commission (SEC) filed an order instituting proceedings (the Order) intended to determine whether to approve or disapprove Financial Industry Regulatory Authority (FINRA)...more
On February 17, 2016, the Municipal Securities Rulemaking Board (MSRB) announced in Regulatory Notice 2016-06 that its draft amendments to Rule G-37 on political contributions, and related amendments to Rules G-8 and G-9 on...more
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
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
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
This is to update you about recent Municipal Securities Rulemaking Board (MSRB) actions.
SEC Approves MSRB's Proposed Amendments to MSRB Rule G-20 and Related Recordkeeping -
On November 6, 2015, the Securities and...more
SEC Municipal Advisor Examination Initiative -
The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) recently updated the National Association of Municipal Advisors on...more
Proposed Amendments to MSRB Rule G-20 -
On September 2, 2015, the MSRB filed with the Securities and Exchange Commission (SEC) proposed amendments to Rule G-20, with conforming changes to related recordkeeping Rules G-8...more
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
On August 6, 2015, the Securities and Exchange Commission (“SEC”) filed an Order instituting proceedings intended to determine whether to approve or disapprove Proposed Municipal Securities Rulemaking Board (“MSRB”) Rule G-42...more
On June 25, 2015, the Securities and Exchange Commission (SEC) issued Release No. IA-4129 setting July 31, 2015, as the compliance date for SEC Rule 206(4)-5's placement agent restrictions on using third-party and affiliated...more
On May 11, 2015, the Municipal Securities Rulemaking Board (MSRB) announced that Proposed Rule G-42 (standards of conduct for nonsolicitor municipal advisors), with conforming changes to Rule G-8 (books and records), was...more
The Municipal Securities Rulemaking Board (MSRB) recently filed the content outline for the Municipal Advisor Representative Qualification Examination (Series 50) with the Securities and Exchange Commission (SEC). Our March...more
This alert is to inform you that the Municipal Securities Rulemaking Board (MSRB) recently submitted Proposed Rule G-42 (standards of conduct for nonsolicitor municipal advisors) to the Securities and Exchange Commission...more
Municipal Advisor Professional Qualification Requirements and Exam -
On March 2, 2015, the Municipal Securities Rulemaking Board (MSRB) announced that the Securities and Exchange Commission (SEC) approved the MSRB’s...more
Earlier this week, the Municipal Securities Rulemaking Board (MSRB) released an update on the status of Draft Rule G-42, which outlines the duties of non-solicitor municipal advisors. The MSRB indicated that it has further...more