News & Analysis as of

Investment Management Pay-To-Play

Skadden, Arps, Slate, Meagher & Flom LLP

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

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

Morrison & Foerster LLP

Investment Adviser Compliance Index - March 2024

The Investment Advisers Act of 1940 (the “Advisers Act”) is a relatively compact statute, and for many years the Securities and Exchange Commission (SEC) adopted relatively few regulations specifically targeting Advisers Act...more

Ballard Spahr LLP

Fidelity's "Infrastructure" Fee Draws Unwanted Attention From Regulators And Several Lawsuits

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On February 21, 2019, a participant in T-Mobile’s 401(k) plan sued the parent company of Fidelity Investments in federal District Court, accusing Fidelity of receiving indirect compensation through the use of a “hidden” fee...more

Akin Gump Strauss Hauer & Feld LLP

Investment Management Special Report - 2017-18 Compliance Developments & Calendar for Private Fund Advisers

Introduction - Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals. ...more

Ballard Spahr LLP

Recent Investment Management Developments - June 2015

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In This Issue: - SEC Proposes Changes to Reporting and Disclosure Obligations for Investment Companies and Advisers - SEC Charges Hedge Fund Executives and External Auditor for Improper Disclosure of Expense...more

Genova Burns LLC

New Jersey’s Investment Pay-to-Play Law Remains Unchanged in the Wake of Governor Christie’s Conditional Veto

Genova Burns LLC on

On Monday, Governor Chris Christie conditionally vetoed Senate Bill No. 2430, which sought to expand New Jersey’s pay-to-play laws governing State investments. The current law requires external investment managers of State...more

Genova Burns LLC

Pay-to-Play Lessons from New Jersey’s State Investment Council Rules

Genova Burns LLC on

New Jersey is often thought of as the “pay-to-play” state – primarily because we have five separate statewide pay-to-play prohibition laws in effect (covering state procurement, county procurement, local procurement, state...more

Ballard Spahr LLP

Investment Management Update

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In This Issue: - SEC Announces First-of-Its-Kind Whistleblower Award To an Audit and Compliance Professional - SEC Issues No-Action Letter To Allow for Amendment of a Sub-Advisory Agreement without Shareholder...more

K&L Gates LLP

Questions & Answers on State and Local Variations on SEC Pay-to-Play Rule

K&L Gates LLP on

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

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