[WEBINAR] Annual Labor & Employment Update
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
On September 19, 2016, the Municipal Securities Rulemaking Board ("MSRB") advised Congress that it had "just concluded development of a core regulatory framework for municipal advisors." This by no means signals a significant...more
The Sixth Circuit this week declined the SEC’s request to dismiss a Constitutional challenge to the new MSRB pay-to-play rules. Instead, the Court ordered the case to a merits panel for consideration. The Republican parties...more
The SEC announced August 25 that it approved FINRA’s pay-to-play rules governing placement-agent or solicitor broker-dealers and was “prepared” to approve the extension of MSRB Rule G-37 to municipal advisors as well....more
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
This SRO gamesmanship is making a mockery of governing. The latest is the SEC’s position that it didn’t take any action on the new MSRB Rules extending pay-to-play prohibitions to municipal advisors, so it can’t be sued...more
On April 12, the Tennessee Republican Party filed a petition in the US Sixth Circuit Court of Appeals, seeking to invalidate the SEC’s approval of new rules extending the MSRB’s long-standing “pay-to-play” prohibitions to new...more
The MSRB’s Rule G-37 amendments applying pay-to-play prohibitions to Municipal Advisors and their third-party solicitors will become effective August 17, 2016....more
The Securities and Exchange Commission (“SEC”) recently published for comments rules proposed by the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Municipal Securities Rulemaking Board (“MSRB”) to regulate...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, the Municipal Securities Rulemaking Board (“MSRB”) filed with the SEC a proposed rule that would extend to municipal advisers the MSRB’s existing rule prohibiting “pay-to-play” practices and restricting...more
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
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
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
SEC’s Focus in 2015 - On December 11, 2014, Mary Jo White, Chair of the U.S. Securities and Exchange Commission (SEC), gave a speech at The New York Times DealBook Opportunities for Tomorrow Conference that...more
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
Spotlight on the MSRB: In the Industry Developments section we report that the SEC, FINRA and the MSRB will be conducting a compliance outreach program for municipal advisors. The Municipal Securities Rulemaking Board was...more
In This Issue: - Regulation: Long-Awaited Money Market Fund Rules Adopted - SEC Staff Offers Guidance Regarding Investment Advisers and Proxy Advisory Firms - SEC Staff Closes Loophole on BDC Asset...more
Following its quarterly meeting, the Municipal Securities Rulemaking Board, or MSRB, stated its Board agreed to extend its pay-to-play rules to municipal advisors....more
With increased attention to transparency in corporate political spending, disclosure of so-called “dark money” and a new rule for municipal advisors, corporations and other organizations active in government affairs or...more