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, […]
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 […]
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.
Theyre taking the nations top securities cop to court.
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.
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 […]
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 […]
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 […]
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 […]
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 […]