Pay to Play and Other Political Law Issues for Investment Advisers


Webinar – Pay to Play and Other Political Law Issues for Investment Advisers

Thursday, June 18, 2015
2:00 - 3:15 pm ET

Topics Covered

With the 2016 election cycle heating up, this webinar provides investment advisers with an overview of pay to play regulation, with an emphasis on recent developments and compliance strategies. The webinar will also address other political law regimes that apply to interactions with public sector investors. Key topics include:

  • Pay to play Rule 206(4)-5 and the SEC’s treatment of recent exemptive relief applications under the Rule and the implications for investment adviser’s compliance programs
  • The application of the Rule to the increasingly varied set of fundraising vehicles and non-profit entities active in the current election cycle
  • Recent developments in state and local pay to play laws
  • Other political law regimes that apply when soliciting investment from government entities, including procurement lobbying laws, placement agent regulations, gift and entertainment laws


  • Charles Borden, Partner, Head of Political Law Group, Allen & Overy LLP
  • Sam Brown, Associate, Political Law Group, Allen & Overy LLP
  • Sanjay Lamba, Assistant General Counsel, Investment Adviser Association (Moderator)


Registration for the live event has closed, but the recording can still be purchased by clicking the "Register" button on this page.

Live Recording Both
Members and Associate Members $125* $125 $200
Non-Members $250* $250 $475

*Per computer login
Registration closes on Tuesday, June 16 at 5:00 p.m.


For questions regarding this webinar, call (202) 293-4222 or email

About the Presenters

Charles Bordon is a Partner and Head of the Political Law Group at Allen & Overy LLP. His practice focuses on the intersection of law and political activity, and he regularly counsels multinational corporations and financial institutions on the regulatory and compliance obligations, as well as the political and reputational consequences, of political activity relating to campaign finance law; the Lobbying Disclosure Act (LDA); the Foreign Agents Registration Act (FARA); the SEC’s regulation of municipal advisors; the federal pay-to-play rules for municipal dealers (Municipal Securities Rulemaking Board (MSRB) Rule G-37), investment advisers (SEC Rule 206(4)-5), and swap dealers (CFTC Rule 23.451); the Stop Trading on Congressional Knowledge Act (STOCK Act); and state and local pay-to-play laws.

Sam Brown is an Associate in the Political Law Group at Allen & Overy LLP. His practice focuses on political law issues, particularly as such issues relate to commercial interactions with public sector entities. Among other topics, he counsels multinational corporations on pay-to-play issues, placement agent regulations, lobbying regulations, gifts and entertainment, revolving door restrictions, campaign finance laws, and issues relating to the federal Freedom of Information Act and state Public Records Acts. Sam has experience with the regulation of municipal securities and municipal advisors, as well as other securities regulation and enforcement matters. Sam also counsels financial services clients on anti-money laundering and anti-corruption issues.

Sanjay Lamba is is Assistant Counsel at the Investment Adviser Association. Prior to joining the IAA in 2013, Sanjay worked at the SEC for 10 years, beginning his service in the rulemaking office of the Division of Investment Management before transferring to the Office of Chief Counsel (Legal Branch) in the Office of Compliance Inspections and Examinations. He received his B.S. degree in Finance from George Mason University and his law degree from Boston University.

Registration Cancellation or Substitution

For the live webinar, cancellations and substitutions must be received in writing no later than 5:00 p.m. (ET) Tuesday, June 16, 2015. There are no refunds for cancellations received after this date. Email your requests to