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Pay-to-Play Rule—Practical Considerations for Investment Advisers  


Author:  Kelley A. Howes.


Source: Volume 28, Number 05, May/June 2015 , pp.43-47(5)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

In a decision of first impression, the SEC’s Division of Enforcement gave investment advisers a clear indication of how it will enforce the “Pay-to-Play” rule under the Investment Advisers Act of 1940. Advisers should be on notice that they will be held strictly liable for violations of Rule 206(4)-5 and ensure that their policies and procedures are appropriately documented and tested.

Keywords: Rule 206(4)-5; covered associate; political contributions; public pension funds; MSRB Rule G-37; MSRB Rule G-38; In the Matter of TL Ventures, Inc.

Affiliations:  1: Morrison & Foerster.

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