On Jan. 17, 2017, 10 investment advisory firms were sanctioned by the Securities and Exchange Commission (SEC) for violations of the so-called “pay-to-play” prohibition of the Investment Advisers Act Rule 206(4)-5 (the Rule).
SEC Takes Aim at Political Contributions By Investment Advisers
While it remains unclear both when the regulators will invoke their authority to enforce the nearly limitless strict liability provision of the "pay-to-play" rules and how they will determine the appropriate remedy, the recent settlements and the SEC's handling of exemptive relief petitions may provide some clues.
By
Joseph F. Savage, Jr. and Stephanie M. Aronzon
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