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Political Contributions Investment Advisers Act of 1940 Investment Adviser

Hogan Lovells

Election season brings political contribution rule to forefront for investment advisers

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It’s election season in America – and for investment advisers (registered or exempt), that means a renewed focus on Rule 206(4)-5, the political contributions rule, commonly known as the “pay-to-play rule.”...more

K&L Gates LLP

Selection of Gov. Walz as VP Candidate Implicates SEC Pay-To-Play Rule

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Kamala Harris’ selection of Tim Walz as running mate for her presidential campaign has implications under the Securities and Exchange Commission’s (SEC) Rule 206(4)-5 under the Investment Advisers Act (SEC Pay-to-Play Rule)....more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: Presidential Election Campaign Donations May Trigger Investment Adviser “Pay to Play” Rule

Overview: Investment advisers that seek to manage public money need to consider the SEC’s “pay to play” rule, which restricts election-related contributions by the firms or their “covered associates” to elected state...more

Goodwin

Minnesota Governor Tim Walz’s National Candidacy Raises Significant Pay-to-Play Rule Considerations for Certain Investment...

Goodwin on

On August 6, 2024, the Democratic nominee for President, Kamala Harris, chose Tim Walz, Governor of Minnesota, as her running mate. This selection presents important considerations vis à vis the “Pay-to-Play Rule” (Rule...more

Proskauer - The Capital Commitment

Key Steps for Fund Managers to Avoid Scrutiny Under the SEC’s Pay-to-Play Rule

The SEC’s recent settlement involving a “pay-to-play” rule violation by a private equity firm is a timely reminder for fund managers, especially with the November elections approaching. As a refresher, Rule 206(4)-5 of...more

WilmerHale

Recent Pay-to-Play Settlement: Notwithstanding a Strong Dissent Over 206(4)-5 Overbreadth, the Need for Strong Compliance Policies...

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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

Dechert LLP

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

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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

K&L Gates LLP

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

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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

Proskauer - The Capital Commitment

U.S. Supreme Court Denies Bid to Review Dismissal of Challenge to Pay-To-Play Rule

On January 13, 2020, the United States Supreme Court denied certiorari to an appeal of a June 2019 order from the United States Court of Appeals for the D.C. Circuit that dismissed an action seeking to invalidate certain...more

Fox Rothschild LLP

Political Contributions Result in RIA Fines

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We are regularly approached by both our RIA (and BD too) clients, who inquire, usually around election time, how they should make political contributions. Our advice is usually do not make the political contribution and you...more

K&L Gates LLP

Questions & Answers on State and Local Variations on the SEC Pay-to-Play Rule

K&L Gates LLP on

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

BakerHostetler

Ten Investment Advisory Firms Violate SEC's Pay-to-Play Rule

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The Securities and Exchange Commission recently announced that ten investment advisory firms agreed to pay penalties in the tens of thousands of dollars to settle SEC charges that they violated the SEC’s pay-to-play rule,...more

Ballard Spahr LLP

Investment Management Update

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The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...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

Womble Bond Dickinson

DC Circuit Court Rejects Challenge to SEC Pay-to-Play Rule

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The DC Circuit Court has rejected an effort by the New York and Tennessee Republican Parties to set aside Securities and Exchange Commission Rule 206(4)-5. The 2010 SEC rule prohibits investment advisers from providing...more

Goodwin

Private Fund Adviser Receives Exemptive Relief from Two-Year Compensation Ban under Pay-to-Play Rule Triggered by Contribution to...

Goodwin on

An SEC-registered adviser (the “Adviser”) was granted exemptive relief pursuant to Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) from the Rule’s two-year prohibition on receiving...more

K&L Gates LLP

Questions & Answers on State and Local Variations on SEC Pay-to-Play Rule

K&L Gates LLP on

Many states and municipalities have adopted laws and regulations that affect how investment managers may solicit investment advisory business, including investment in sponsored public and private funds, from the state...more

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