Pay-to-Play

IA penalized $60K for running afoul of the Commission's pay-to-play rule

A staffer at the adviser "made a campaign contribution to a candidate for elected office in Minnesota, which office had influence over selecting investment advisers ...

"This case is yet another illustration of the overbreadth of the pay-to-play rule and another reminder of the way the rule hampers legitimate political participation"

'Draconian' rules handicap DeSantis, Burgum

Check out a peer's matrix for finding potential political contributions by staff

It’s been more than a decade since the SEC adopted its pay-to-play rule, yet violations by advisers continue to imbue compliance lessons

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 ...