SEC Proposes to Rescind Pay to Play Rule
On September 3, 2026, the SEC proposed to rescind Rule 206(4)-5 under the Investment Advisers Act, its pay to play rule governing political contributions by investment advisers and their employees.
September 03, 2026
Harris/Walz Ticket Raises Advisers Act Pay-to-Play Rule Considerations
A brief review of the Pay to Play Rule, and some of the common compliance foot faults seen in the industry.
October 23, 2024
Certain Political Contributions to Harris Campaign Subject to “Pay to Play” Rule
Political contributions to, or fundraising for, the presidential campaign of Kamala Harris by an adviser or its “covered associates” are now potentially subject to the SEC pay to play rule because of the selection of Minnesota Governor Tim Walz as her running mate.
August 07, 2024
Pay-to-Play Tips and Reminders
This article discusses tips for advisers to comply with the pay-to-play rule.
June 29, 2023
SEC Brings Four Pay-to-Play Cases, Commissioner Peirce Highlights Need to Revisit the Rule
The SEC charges four investment advisers with violations of the Pay-to-Play rule, as Commissioner Peirce calls on the SEC to revisit the “exceedingly blunt instrument.”
September 22, 2022
Compliance and Operational Risks Associated with Public Pension Plan Investors
Requirements for public pension plan investments have expanded. Managers must consider compliance challenges before a plan invests and before the first interaction with a plan.
October 20, 2021
AMAC Discusses Private Funds, ESG, and Diversity and Inclusion
The AMAC’s Private Investments and ESG subcommittees provided updates on their progress and the AMAC’s Diversity and Inclusion subcommittee held a panel discussion.
December 09, 2020
Supreme Court Leaves SEC’s Pay-to-Play Rule Intact
The state parties’ petition claimed that the rule exceeds the SEC’s statutory authority and violates the Administrative Procedure Act and the First Amendment.
January 21, 2020
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