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
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
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
4/22/2024
/ Broker-Dealer ,
Compliance ,
Enforcement ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Pay-To-Play ,
Political Contributions ,
Quid Pro Quo ,
Securities and Exchange Commission (SEC) ,
Securities Violations
Recently, the Securities and Exchange Commission (SEC) has demonstrated its willingness to largely forgo the strict consequences of Investment Advisers Act Rule 206(4)-5 (the “Pay-to-Play Rule”) in circumstances where...more
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
Midterm congressional elections are expected to see a historic number of candidates competing. The record number of candidates comes as individual races become increasingly expensive and trends portend record spending. All of...more
With the record-breaking campaign expenditures of the 2014 midterm elections behind us, and the 2016 campaign cycle already heating up, this is an ideal moment for investment advisers (including advisers to venture capital...more