News & Analysis as of

Pay-To-Play

Lowenstein Sandler LLP

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

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

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for August 2024

More Flack on WhatsApp, Hypothetical Performance SmackDown, A Timely Warning on the Pay-to-Play Rule, and Updates to Qualifying Venture Capital Fund Exemption - This month's big news from the SEC was more piggy-bank breaking...more

Nossaman LLP

Compliance Notes - Vol. 5, Issue 29

Nossaman LLP on

Campaign Finance & Lobbying Compliance The Securities and Exchange Commission (SEC) has censured and fined a large, registered investment advisor, Obra Capital Management (Obra), $95,000 after learning an associate of the...more

Holtzman Vogel Baran Torchinsky & Josefiak

In Compliance: Holtzman Vogel's August 2024 Round-Up

Eighth Circuit Invalidates Missouri's Two-Year Lobbying Ban for Former Legislators and Staffers - The Eighth Circuit Court of Appeals invalidated a Missouri state constitutional amendment that imposed a two-year lobbying...more

Katten Muchin Rosenman LLP

Selection of Gov. Walz as VP Harris's Running Mate Triggers Federal Pay-to-Play Restrictions on Investment Advisers and Other...

Vice President Kamala Harris's selection of Minnesota Gov. Tim Walz as her running mate imposes restrictions on campaign contributions to the Harris-Walz campaign by federally registered investment advisers (RIAs), exempt...more

BakerHostetler

When Is a Pay-to-Play Game Gambling?

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As of relatively recently, gambling was generally prohibited in the United States. You could visit a casino in places like Las Vegas, participate in some state lotteries, and buy tickets for charitable raffles, but options...more

K&L Gates LLP

Selection of Gov. Walz as VP Candidate Implicates SEC Pay-To-Play Rule

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Kamala Harris’ selection of Tim Walz as running mate for her presidential campaign has implications under the Securities and Exchange Commission’s (SEC) Rule 206(4)-5 under the Investment Advisers Act (SEC Pay-to-Play Rule)....more

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

Goodwin

Minnesota Governor Tim Walz’s National Candidacy Raises Significant Pay-to-Play Rule Considerations for Certain Investment...

Goodwin on

On August 6, 2024, the Democratic nominee for President, Kamala Harris, chose Tim Walz, Governor of Minnesota, as her running mate. This selection presents important considerations vis à vis the “Pay-to-Play Rule” (Rule...more

Cooley LLP

Remember Pay-to-Play Rule Before Making US Election Campaign Contributions

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On August 6, 2024, US Vice President Kamala Harris announced Minnesota Gov. Tim Walz as her running mate for the 2024 presidential election. This selection triggers the political contributions rule under the Investment...more

Skadden, Arps, Slate, Meagher & Flom LLP

2024 Presidential Election Alert: Harris-Walz Campaign Now in General Election Period

On August 6, 2024, Vice President Kamala Harris accepted the Democratic nomination for president and announced Governor Tim Walz as her running mate. This marked the end of the primary election period for the Harris/Walz...more

WilmerHale

Pay-to-Play Alert: Implications of a Governor Joining a Presidential Ticket

WilmerHale on

Vice President Kamala Harris’ selection of Minnesota Governor Tim Walz as her running mate highlights a wrinkle in Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule” or “Rule”) to which investment advisers should...more

Akin Gump Strauss Hauer & Feld LLP

Walz’s Addition to Democratic Ticket Raises Pay-to-Play Issues for Donors in the Financial Industry

Employees of investment advisers must consider whether their employer is managing or seeking to manage public funds in Minnesota before donating to the Harris-Walz campaign this election season. Vice President Harris’...more

Proskauer - The Capital Commitment

Harris's Running Mate Announcement: Pay-to-Play Rule Implications for Investment Advisers

As reported today, Vice President Harris has announced Tim Walz, the sitting governor of Minnesota, as her running mate. This announcement is particularly significant for investment advisers due to the Advisers Act Political...more

Dechert LLP

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

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Contributions to Harris/Walz Campaign Are Subject to Pay-to-Play Rules

Vice President Kamala Harris announced today that she has selected Minnesota Gov. Tim Walz as her vice presidential running mate in her bid for president. Contributions to the Harris/Walz campaign are now subject to the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Reminder: Illinois Pay-to-Play Registration Updates Due Quarterly

The next quarterly update required under the Illinois pay-to-play law is due August 14, 2024. As described in an earlier mailing, Illinois law requires many companies with aggregate state bids, proposals and contracts...more

Wiley Rein LLP

Pay-to-Play Rules Enter the 2024 Presidential Campaign

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On August 6, Vice President Kamala Harris selected Governor Tim Walz of Minnesota as her Vice-Presidential running mate for the 2024 general election. Since Governor Walz is a state official, his selection for the ticket...more

Royer Cooper Cohen Braunfeld LLC

Pay-to-Play: One Size Might Not Fit All?

The recent case involving Wayzata Investment Partners and the SEC highlights the potential consequences of pay-to-play violations in the investment advisory industry. It also highlights the effects of slow-moving policy...more

Skadden, Arps, Slate, Meagher & Flom LLP

Presidential Election Alert: Campaign Finance Implications for Harris for President

On July 21, 2024, President Joseph Biden announced that he was ending his bid for reelection and instead endorsing Vice President Kamala Harris for president. A presumptive nominee withdrawing so close to the party convention...more

Littler

Pay to Play? Third Circuit Holds NCAA Athletes Can Be Considered Employees

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The National Collegiate Athletic Association (NCAA) has long argued that college athletes are amateurs exempt from minimum wage and overtime under the Fair Labor Standards Act (FLSA). Until last week, courts around the United...more

Wiley Rein LLP

Mind Your Ps (and Qs): Pay-to-Play and Procurement Lobbying for the Government Contractor

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If there are two political law compliance issues that perennially bedog federal, state, and local government contractors, it is the myriad of state and local pay-to-play laws and procurement lobbying laws. In the FAQs below,...more

Proskauer - The Capital Commitment

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

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

Venable LLP

Political Giving: A Primer for High-Net-Worth Individuals and Family Offices

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For many years, supporters of a candidate or a cause simply wrote a check and asked friends and colleagues to do the same. But the opportunities to influence elections and public policy have evolved significantly, allowing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Maryland Amends Pay-to-Play Law To Require Companies To Disclose Certain Beneficial Owners

As a result of recent statutory amendments that will go into effect on July 1, 2024, companies registered and filing pay-to-play reports in Maryland will be required to list on their registration certain beneficial owners,...more

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