News & Analysis as of

Pay-To-Play

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Oct. 1 Quarterly Review

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

McCarter & English, LLP

Compliance Note - October 11 2024

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Does your company have a government contract or plan to seek business with a government entity in New Jersey? If so, it is essential to understand the rules that could result in the breach of an existing contract and the...more

Akin Gump Strauss Hauer & Feld LLP

California to Increase State Pay-to-Play Limit in 2025

Last week, California Governor Gavin Newsom signed a new law that amends key provisions of the state’s pay-to-play statute which limits political contributions by state and local contractors and their agents....more

Best Best & Krieger LLP

California Updates Levine Act “Pay to Play” Campaign Contribution Restrictions for 2025

Governor Newsom signed a bill on September 30 that will update the State’s “pay to play” campaign contribution law commonly known as the “Levine Act” starting on January 1, 2025. The Levine Act currently prohibits agency...more

Seward & Kissel LLP

A Refresher on the SEC’s Pay to Play Rule

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In the midst of a national election cycle, now is a good time for investment advisers to refresh their understanding on the SEC’s Pay to Play Rule (the “Rule”) and related SEC staff guidance As demonstrated by a number of...more

WilmerHale

Pay-to-Play Alert: The Importance of Vetting the Specifics of a Political Contribution

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As explained in our prior client alert, the presence of a sitting state-level elected official—Minnesota Governor Tim Walz—on a presidential ticket should increase vigilance among investment advisers regarding the potential...more

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

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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...

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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

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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

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