Pay-to-Play

More than one in five cases involved fees, expenses or valuations

In August 2018, a covered associate of Respondent made a campaign contribution to a candidate for elected office in California, which office had influence over ...

Between December 2020 and April 2021, two covered associates of Respondent made campaign contributions to a candidate for elected office in New York, New York, ...

In July 2018, an officer of the Bank of Hawaii made a campaign contribution to an incumbent for elected office in Hawaii, which office had ...

In May 2021, a covered associate of Respondent made a campaign contribution to a candidate for elected office in Massachusetts, which office had influence over ...

"The Pay-to-Play Rule, although well-intentioned, imposes unique, unquantifiable costs on individuals by impeding their ability to participate in the political process"

Use this form to help you comply with the SEC's pay-to-play rule

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 ...