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

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

SEC Finalizes Changes to Dealer Definition – Does Not Exempt Private Funds or Proprietary Trading Firms

At a contentious open meeting on February 6, 2024, the Securities and Exchange Commission (Commission) voted three to two to adopt rule amendments (Final Rules) under the Securities Exchange Act of 1934, as amended (Exchange...more

Just Off-Target: FINRA Proposal on Projections and Targeted Returns

The Proposed Amendments would permit FINRA members to include targeted returns or projected performance solely if the communication is either: (i) an “institutional communication” as defined in FINRA Rule 22102.; or (ii)...more

The SEC’s Private Fund Adviser Rules: Exploring The Critical Questions

The Securities and Exchange Commission adopted new and amended rules under the Investment Advisers Act of 1940 (“Final Rules”) in August 2023 that will impose a broad set of new reporting, disclosure and other obligations on...more

Preparing for the 2024 Elections: Pay-to-Play and Other Considerations for Managers of Public Pension Plan Assets

With the 2024 elections fast approaching, investment advisers must continue to be mindful of political contributions by their personnel if they manage or intend to manage public pension plan assets, among other compliance...more

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