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Pay-to-Play

A peer shares a portion of the firm's code of ethics. These are sample policies and procedures for gifts and entertainment as well as pay-to-play.
DB Fitzpatrick “terminated the chief compliance officer at the time of the Contributions and hired a new chief compliance officer
Early debates among Democratic Presidential candidates attest to the vigorous election season that awaits – a perfect time to ponder the reach of the SEC’s ...
Commissioner approval of rules and interpretations tied to fiduciary duty represented a “culmination of decades of work,” noted Barbara Gunn, assistant regional director in the ...
You may wish to consider live or videotaped training around the SEC’s pay-to-play rule.   Generation Investment Management ($8.4B in AUM) in San Francisco adopted ...
The Mayfield Heights, Ohio-based advisory firm Ancora Advisors ($4.6B in AUM) knew it had violated the SEC’s pay-to-play rule, which meant a “two-year ‘time-out’” on ...
These proceedings involve violations of the Commission’s “pay-to-play” rule for investment advisers by Respondent Ancora Advisors, an investment adviser. Rule 206(4)-5, promulgated under Section 206(4) ...
We’ve told you before about Stephanie Drescher’s $1,000 contribution to the presidential campaign of Ohio Governor John Kasich (IA Watch, March 29, 2018). Now an ...
Paulsen and Kelley planned a ski trip for the purpose of entertaining Kang and his girlfriend. The complaint alleges that Kang told Paulsen and Kelley ...
The Advisers Act’s pay-to-play rule clearly states that a violation of the rule prohibits an adviser from receiving compensation from a public pension plan for ...
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