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Enforcement › Pay-To-Play

Proskauer - The Capital Commitment

Mid-Year Enforcement Update: SEC’s Continued Focus on Private Funds in 2024

Proskauer - The Capital Commitment on

As we reach the midpoint of 2024, the SEC has maintained its rigorous enforcement stance on the private funds industry, proposing new rules and oversight tools to better identify and investigate market practices. As 2024...more

Proskauer - The Capital Commitment

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

Proskauer - The Capital Commitment on

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

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

Foley & Lardner LLP

Pay-to-Play in the CFPB’s Cross-Hairs: Digital Mortgage Comparison-Shopping Platforms under RESPA Scrutiny

Foley & Lardner LLP on

The Consumer Financial Protection Bureau (CFPB) ended a more than decade-long hiatus since the last formal guidance regarding Section 8 of the Real Estate Settlement Procedures Act (RESPA) on February 7, 2023, by issuing its...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

Morrison & Foerster LLP

Paying for Playing: SEC Brings First Pay-to-Play Action against an Investment Adviser

Morrison & Foerster LLP on

The SEC has brought the first action under the “pay-to-play” rule adopted under the Investment Advisers Act. Andrew Ceresney, director of the SEC Enforcement Division, served notice that the SEC “will hold investment advisers...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

Dorsey & Whitney LLP

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

Dorsey & Whitney LLP on

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Stinson - Corporate & Securities Law Blog

Integrated Private Equity Firms Charged With Failure to Register and Pay-to-Play Violations

Stinson - Corporate & Securities Law Blog on

The SEC charged two firms with failing to register as investment advisers because their operations were integrated and charged one of the entities with violating pay-to-play rules....more

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