News & Analysis as of

Investment Advisers Act of 1940 Financial Industry Regulatory Authority (FINRA) Pay-To-Play

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

Dechert LLP

Contributions to the Harris Presidential Campaign Subject to Federal "Pay-to-Play" Rules

Dechert LLP on

Vice President Kamala Harris announced Minnesota Governor Tim Walz as her running mate for the upcoming Presidential election. Because Governor Walz is an “official” for purposes of the SEC’s pay-to-play rule under the...more

Proskauer - The Capital Commitment

U.S. Supreme Court Denies Bid to Review Dismissal of Challenge to Pay-To-Play Rule

On January 13, 2020, the United States Supreme Court denied certiorari to an appeal of a June 2019 order from the United States Court of Appeals for the D.C. Circuit that dismissed an action seeking to invalidate certain...more

Proskauer - The Capital Commitment

Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide

As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more

Proskauer Rose LLP

Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide

Proskauer Rose LLP on

As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more

Goodwin

Financial Services Weekly News - August 2015 #4

Goodwin on

Regulatory Developments - CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps: On Aug. 19 the CFTC announced that it had voted to propose amendments to existing...more

Katten Muchin Rosenman LLP

Effective Date of Investment Adviser Pay-to-Play Rule Ban on Third-Party Solicitation

The Securities and Exchange Commission’s Rule 206(4)-5 (Pay-to-Play Rule) under the Investment Advisers Act of 1940, as amended, prohibits, among other restrictions, an investment adviser subject to the rule, and its covered...more

Latham & Watkins LLP

SEC Announces Compliance Date for Pay-to-Play Rule

Latham & Watkins LLP on

Despite the July 31, 2015 compliance date, the SEC will not enforce the third-party solicitation ban until corresponding FINRA/MSRB Rules take effect. On June 25, 2015, the Securities and Exchange Commission (SEC)...more

Burr & Forman

FINRA Solicitor Pay-to-Play Rules Complete IA & MSRB Suite

Burr & Forman on

Last Friday, FINRA proposed pay-to-play prohibitions that parallel and implement similar Investment Adviser Act provisions in Rule 206(4)-5. That IA Rule prohibits investment advisers from paying third-parties to solicit...more

Goodwin

Financial Services Weekly News Roundup - November 2014 #3

Goodwin on

FINRA Requests Comment on Proposed “Pay-to-Play” Rule - FINRA issued Regulatory Notice 14-50 requesting comment on proposed “pay-to-play” and related rules that would regulate in a manner similar to Rule 206(4)-5 under...more

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