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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 ...
Three covered associates of Respondent made campaign contributions to candidates for elected office in California and Rhode Island, which offices had influence over selecting investment ...
A covered associate of Respondent made a contribution to the federal election campaign of an elected state official in Wisconsin and that state office had ...
In April 2014, a covered associate of Respondent made a campaign contribution to a candidate for elected office in Illinois, which office had influence over ...
With another election nearing, this may be a good time to remind staff of your pay-to-play policies – especially after two more advisers have applied ...
Two new amended applications for exemptive relief under the SEC’s pay-to-play rule suggest the agency wants to see more evidence of a robust response by ...
Bradford Eichler had grown up with Capi Peck’s ex-husband. Their friendship dated back decades. So when Peck ran for the job of director of the ...
It’s taken years for the SEC’s ban on third-party solicitation under its pay-to-play rule to take effect – largely because the Commission waited until FINRA ...
Few executives blunder as big as Mark Wiedman did when the Blackrock Advisors’ ($544B in AUM) senior managing director contributed $2,700 to last year’s Presidential ...
Another shoe has dropped in the ongoing investigation of a “pay-to-play” bribery scheme involving the New York State Common Retirement Fund. A second senior executive ...
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.
Only days after OCIE’s 2017 exam priorities recorded examiners’ interest in public pension advisers and compliance with the pay-to-play rule (IA Watch, Jan. 12, 2017), ...
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