Pay-to-Play

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 ...

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) ...