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Update: The SEC’s New Rules on “Pay to Play” Restrictions for Investment Advisers
The SEC’s new rule prohibiting "pay to play" (Rule 206(4)-5 under the Investment Advisers Act of 1940) imposes significant new obligations - and new prohibitions - on investment advisers. The rule seeks to protect public pension plan beneficiaries by limiting the ability of investment advisers to influence investment management decisions by state and local government officials through the use of political contributions.
The rule became effective on September 13, 2010, though it has several tiered compliance dates. The SEC recently provided guidance with respect to many frequently asked questions regarding implementation of the new requirements, as described in this FS Regulatory Brief.
The rule became effective on September 13, 2010, though it has several tiered compliance dates. The SEC recently provided guidance with respect to many frequently asked questions regarding implementation of the new requirements, as described in this FS Regulatory Brief.
