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Recent Pay-to-Play Settlement: Notwithstanding a Strong Dissent Over 206(4)-5 Overbreadth, the Need for Strong Compliance Policies...

With political campaign activity ramping up as the fall elections approach, the Securities and Exchange Commission (SEC) has indicated it will continue stringent enforcement of Investment Advisers Act Rule 206(4)-5 (the...more

Pay-to-Play Update: A Quartet of Recent Settlements Underscores the Breadth of Risk Posed by Rule 206(4)-5

With the midterm elections less than a month away and political campaign activity in full swing, the Securities and Exchange Commission (SEC) has demonstrated a renewed interest in “pay-to-play” enforcement after a long...more

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