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Investment Adviser › Government Entities

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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

Nutter McClennen & Fish LLP

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

Nutter McClennen & Fish LLP on

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

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Penalizes Adviser in New Rule 206(4)-5 Proceeding

Skadden, Arps, Slate, Meagher & Flom LLP on

On April 15, 2024, the U.S. Securities and Exchange Commission (SEC) censured and imposed a $60,000 civil penalty on Wayzata Investment Partners LLC (Wayzata) for violating SEC Rule 206(4)-5 (the Pay-to-Play Rule). Under the...more

The Rodman Law Group, LLC

The Corporate Transparency Act Reporting Exemptions

The Rodman Law Group, LLC on

The Corporate Transparency Act mandates certain reporting requirements for beneficial ownership information for certain companies, with the goal of preventing the illicit use of anonymous shell companies for financial crimes....more

Skadden, Arps, Slate, Meagher & Flom LLP

D.C. Circuit Upholds Federal Pay-to-Play Rule

Skadden, Arps, Slate, Meagher & Flom LLP on

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

Latham & Watkins LLP

SEC Approves FINRA Pay-to-Play Rules

Latham & Watkins LLP on

Placement agents to private funds who seek investments by state and local pension plans must comply with restrictions on political contributions and related activities. On August 25, 2016, the Securities Exchange...more

Proskauer Rose LLP

SEC Sets Compliance Date for Pay-to-Play Rule's Ban on Third-Party Solicitation of Government Entities

Proskauer Rose LLP on

On June 25, 2015, the Securities and Exchange Commission (SEC) set a compliance date of July 31, 2015 for the ban on payments to third parties for the solicitation of advisory business from any government entity under Rule...more

Allen Matkins

Is A “Rule” An “Order” And Why Would Anyone Care?

Allen Matkins on

Pay-to-Play Rule Challenged - Doug Cornelius recently wrote about the dismissal of a lawsuit challenging the Securities and Exchange Commission’s anti “pay-to-play” rule under the Investment Advisers Act of 1940. New...more

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