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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

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

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

SEC Penalizes Adviser in New Rule 206(4)-5 Proceeding

On April 15, 2024, the U.S. Securities and Exchange Commission (SEC) censured and imposed a $60,000 civil penalty on Wayzata Investment Partners LLC (Wayzata) for violating SEC Rule 206(4)-5 (the Pay-to-Play Rule). Under the...more

For Financial Institutions: Reminder That Federal Political Activity Can Implicate Certain Pay-to-Play Rules

With the election season in full swing, there is increased interest in political contributions. It is important for financial institutions subject to SEC Rule 206(4)-5 for investment advisers, CFTC Rule 23.451 for swap...more

2024 Insights: Other Regulatory Developments

AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more

Contributions to Florida Gov. Ron DeSantis’ Presidential Campaign Are Subject to Federal Pay-to-Play Rules

Florida Gov. Ron DeSantis filed paperwork on May 24, 2023, to run for president in the 2024 election. In light of his announcement, it is important to keep in mind that contributions made to or solicited on behalf of Gov....more

Complying With the Rules Governing 501(c)(4) Organizations: Key Issues

Nonprofits organized under Section 501(c)(4) of the Internal Revenue Code (IRC) play an ever-growing role in politics and public policy advocacy. These 501(c)(4) organizations may accept unlimited corporate and personal...more

Reminder of STOCK Act Implications When Gathering Political Intelligence

In light of recent news reports on stock trades made by certain senators after they received intelligence briefings on the COVID-19 crisis, we want to remind you of the provisions of the Stop Trading on Congressional...more

Post-Election Issues (Inaugurations, Transitions, and Special Elections)

Now that the 2018 midterm elections are over, we must contend with legal issues that arise from activities related to federal, state and local inaugural and transition committees, as well as recounts and runoff elections. As...more

"Developments: Applying Federal Pay-to-Play Rules to Trump/Pence Inaugural and Transition Committees"

For financial institutions subject to federal pay-to-play rules (SEC Rule 206(4)-5 for investment advisers, MSRB Rule G-37 for municipal bond underwriters and municipal advisors, and CFTC Rule 23.451 for swap dealers),...more

"Post-Election Issues"

Now that the 2016 elections are over, we must contend with special legal issues that arise from contributions made to, and expenses incurred for, federal, state or local inaugural or transition committees, as well as recounts...more

"FINRA Pay-to-Play Rule Effective August 20, 2017"

On October 24, 2016, the Financial Industry Regulatory Authority (FINRA) announced in Regulatory Notice 16-40 that its pay-to-play and related recordkeeping rules, FINRA Rules 2030 and 4580, will take effect on August 20,...more

SEC Approves FINRA Pay-to-Play Rule

This week, on Thursday, August 25, 2016, the SEC approved FINRA Proposed Rules 2030 and 4580 (the Proposed Rules) as they had been proposed by FINRA. The Proposed Rules would impose pay-to-play restrictions and recordkeeping...more

"FINRA Extends Deadline for SEC to Act on Proposed FINRA Pay-to-Play Rule"

On June 21, 2016, the Financial Industry Regulatory Authority extended the time for the Securities and Exchange Commission (SEC) to act on Proposed Rules 2030 and 4580 (the Proposed Rules) to August 26, 2016. The Proposed...more

"SEC Extends Comment Period on Proposed FINRA Pay-to-Play Rule "

On March 29, 2016, the Securities and Exchange Commission (SEC) filed an order instituting proceedings (the Order) intended to determine whether to approve or disapprove Financial Industry Regulatory Authority (FINRA)...more

"MSRB Amendments to Pay-to-Play Rule Will Take Effect in August 2016"

On February 17, 2016, the Municipal Securities Rulemaking Board (MSRB) announced in Regulatory Notice 2016-06 that its draft amendments to Rule G-37 on political contributions, and related amendments to Rules G-8 and G-9 on...more

"FINRA Submits Pay-to-Play Rule 2030 to SEC for Approval"

On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) submitted Rules 2030 and 4580 (the Draft Rules) to the Securities and Exchange Commission (SEC) for approval. The Draft Rules set forth pay-to-play...more

"MSRB Submits Pay-to-Play Rule G-37 Amendments to SEC for Approval"

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

"FINRA and MSRB Submit Pay-to-Play Rules to SEC for Approval"

On December 16, 2015, the Financial Industry Regulatory Authority (FINRA) and Municipal Securities Rulemaking Board (MSRB) submitted their respective pay-to-play rules to the Securities and Exchange Commission (SEC) for...more

"MSRB Rulemaking Update: SEC Approves MSRB's Proposed Amendments to Gift Rule G-20, MSRB Files Second Amendment to Proposed Rule...

This is to update you about recent Municipal Securities Rulemaking Board (MSRB) actions. SEC Approves MSRB's Proposed Amendments to MSRB Rule G-20 and Related Recordkeeping - On November 6, 2015, the Securities and...more

"Municipal Advisor Update: SEC Examination Initiative, Series 50 Pilot Exam, Continuing Education Requirements"

SEC Municipal Advisor Examination Initiative - The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) recently updated the National Association of Municipal Advisors on...more

"Recent MSRB Developments: Board Proposes Amendments to Gift Rule G-20, Schedules Municipal Advisor Pilot Exam"

Proposed Amendments to MSRB Rule G-20 - On September 2, 2015, the MSRB filed with the Securities and Exchange Commission (SEC) proposed amendments to Rule G-20, with conforming changes to related recordkeeping Rules G-8...more

"DC Circuit Dismisses Challenge to SEC Rule 206(4)-5"

On August 25, 2015, the U.S. Court of Appeals for the District of Columbia Circuit upheld the D.C. District Court’s dismissal of a challenge to Securities and Exchange Commission (SEC) pay-to-play Rule 206(4)-5 (the Rule) and...more

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