Pay to Play

Association Wants Pay-to-Play Rule Tailored for Small Advisers, Less Complex

The SEC is considering revising Rule 206(4)-5, the Pay-to-Play Rule, in the near future – and the Investment Adviser Association is ready with suggestions. In a recent comment letter to the agency, the IAA urged the Commission to consider a number of steps, including changing the definition of what constitutes a small business or organization, […]

As Election Season Heats Up, Pay Attention to Pay-to-Play

Presidential candidates and talk about the 2020 elections is in the news – and likely to increase as the months progress. Too far away to pay attention? Not for advisory firm chief compliance officers. Now, in fact, is a good time to start ensuring advisory firm compliance with Rule 206(4)-5, the Pay-to-Play Rule. “It definitely […]

10 Advisory Firms Learn the Meaning of Pay-to-Play

If only they had monitored the political contributions their employees made. Then, they wouldnt be getting all this bad publicity, SEC attention, and having to pay fines ranging from $35,000 to $100,000.

Pay-to-Play Rule: State Republican Parties Take SEC to Court

Theyre taking the nations top securities cop to court.

SEC for First Time Charges an Adviser with Pay-to-Play Rule Violations

Firms with covered associates who make political contributions to entities they do business with may wind up getting a lot more than they paid for - in the way of SEC attention.

SEC Adds to Pay to Play FAQs

The SECs June extension of the compliance date for the ban on third-party solicitation in the pay to play rule has made its way into the Division of Investment Managements FAQs on the rule.As a result of the announcement that compliance with the third-party solicitation ban would be extended to nine months after the compliance date of […]

Classic Pay to Play Fall For MayfieldGentry

Some towns just cant shake their reputations for political corruption.Chicago.Any town in New Jersey (sorry New Jersey).Detroit.Detroit politicians are making headlines again, this time for turning the screws on an asset manager that feared losing lucrative pension fund clients.It was a classic stick-up operation, and the adviser who wanted the business emptied his pockets.Last month […]

Compliance Date Extended for Ban on Third Party Solicitation

Effective June 11, the SEC has once again extended the compliance date for the third-party solicitation ban in the pay to play rule.This time, the staff has crafted the extension in such a way so they will not need to provide further extensions, while still allowing for other necessary rulemaking events to take place at […]

SEC Corrects Error in Pay to Play Rules Definition of Covered Associate

One little six-letter word ended up somewhere it shouldnt have, and now the SEC is setting the record straight.Back in November 2010, the SEC proposed several amendments to the pay to play rule, Rule 206(4)-5, to implement provisions of the Dodd-Frank Act. One of the proposals would have replaced the word “individual” with the word […]

Advisers Get Some Relief on Pay to Play Recordkeeping

When the pay to play rule was adopted back in July 2010, certain ancillary rules were adopted along with it.One of them was Rule 204-2(a)(18)(i)(B), the “Government Plan Recordkeeping Rule.” Under this rule, an adviser must keep certain records that identify pension funds and other government entities that are clients, or are investors in certain […]

Audio Interviews

How to Read an SEC Enforcement Action

Stern Tannenbaum law firm partner Aegis Frumento on how to get the most from reading an SEC administrative order or court complaint.

Most Important Supreme Court Decisions for Advisers and Funds

Find out the high court decisions from recent years that are likely to affect how advisers and investment companies work from Debevoise partner Robert Kaplan. 

Top 10 Cybersecurity Steps to Take Now

Sutherland law firm partner Brian Rubin shares the most urgent cybersecurity steps for investment advisers.

Top Marketing Problems … and Solutions

Get solutions for the top marketing challenges that advisers face from ACA Compliance Group managing director Kimberly Daly

Watch Out for 5 Cybersecurity Myths

ACA Aponix Director Pascal Busnel on the most common cybersecurity myths that may cause firms to spend resources where they may not be needed.

The Hidden Costs of Non-Compliance

Proskauer law firm partner and former SEC Division of Investment Management deputy director Robert Plaze on why the costs of non-compliance go way beyond an SEC penalty.

CCO Liability: How to Protect Yourself

Find out from Blue Edge Capital CCO Margaret Fretz what chief compliance officers may be liable for and best practices to make sure you are protected.

Ethics or Compliance: Making the Choice

Find out the difference an ethics, rather than a compliance, perspective makes at an advisory firm from former Ethics and Compliance Officer Association COO Timothy Mazur.