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
In a 3-2 vote on August 23, 2023, the Securities and Exchange Commission (“SEC” or “Commission”) adopted five new rules under the Investment Advisers Act of 1940 (the “Advisers Act”), collectively called the “Private Fund...more
8/29/2023
/ Compliance ,
Disclosure Requirements ,
Final Rules ,
Fund Managers ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
Private Funds ,
Proposed Rules ,
Registered Investment Advisors ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On July 26, 2023, the Securities and Exchange Commission (SEC or Commission) narrowly approved (3-2) a proposed rulemaking under the Securities Exchange Act of 1934 (Exchange Act) and the Investment Advisers Act of 1940...more
8/18/2023
/ Analytics ,
Broker-Dealer ,
Conflicts of Interest ,
Electronic Communications ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
Predictive Analytics ,
Proposed Regulation ,
Retail Investors ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
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
On June 5, 2019, the Securities and Exchange Commission (“SEC” or “Commission”) in a divided 3-1 vote, approved a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’...more
6/18/2019
/ Best Interest Standard ,
Broker-Dealer ,
Conflicts of Interest ,
Dodd-Frank ,
Fiduciary Duty ,
Final Rules ,
Financial Services Industry ,
Form ADV ,
Form CRS ,
Investment Adviser ,
Securities and Exchange Commission (SEC)
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