News & Analysis as of

PACs Pay-To-Play Investment Adviser

Skadden, Arps, Slate, Meagher & Flom LLP

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

K&L Gates LLP

Compliance Reminder: Pay-to-Play and the 2020 Election Cycle

K&L Gates LLP on

INTRODUCTION - As the November 2020 elections approach, investment advisers and other financial institutions who do business with, or seek to do business with, public pension plans and other government entities should...more

Pillsbury Winthrop Shaw Pittman LLP

Text, Alexa, Bitcoin—Technology Makes Political Contributions Easier

Is your political compliance program ready for the 2020 election season? With the 2020 election season underway, now is a good time to make certain your internal policies and procedures address applicable campaign...more

Clark Hill PLC

The Federal Securities Pay-to-Play Regulatory Framework is Complete - A Primer for Financial Services Firms

Clark Hill PLC on

On September 20, 2016, the Securities and Exchange Commission ("SEC") issued two orders effectively completing the federal pay-to-play regulatory framework for investment advisers, municipal advisors, underwriters of...more

Proskauer - The Capital Commitment

Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide

As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more

Proskauer Rose LLP

Private Fund Advisers Must Pay Close Attention to Nuances under Pay-to-Play Restrictions in Light of Upcoming Elections Nationwide

Proskauer Rose LLP on

As the elections approach nationwide, advisers to private investment funds with current or prospective state or local government entity investors should be mindful of political activities by their personnel which could raise...more

Ballard Spahr LLP

SEC Announces First Investment Adviser ‘Pay-to-Play’ Enforcement Action

Ballard Spahr LLP on

The U.S. Securities and Exchange Commission (SEC) announced its first enforcement action under "pay-to-play" rules for investment advisers since those rules were adopted nearly four years ago. TL Ventures Inc., a...more

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