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Aug 18, 2017 · A: A contribution to a political party, PAC or other committee or organization would not trigger a two-year time out under rule 206(4)-5(a)(1), unless it is a means to do indirectly what the rule prohibits if done directly (for example, the contribution is earmarked or known to be provided for the benefit of a particular political official ...
Sep 13, 2010 · Advisers Act Rule 206(4)-5 (Political Contributions by Certain Investment Advisers) A Small Entity Compliance Guide 1 Introduction. The Securities and Exchange Commission ("SEC" or "Commission") approved a new rule on June 30, 2010 to address so-called "pay to play" practices in which investment advisers make campaign contributions to elected officials in order to influence the award of ...
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(1) For any investment adviser registered (or required to be registered) with the Commission, or unregistered in reliance on the exemption available under section 203(b)(3) of the Advisers Act (15 U.S.C. 80b–3(b)(3)), or that is an exempt reporting adviser, as defined in section 275.204–4(a), to provide investment advisory services for ...
Political Contributions by Certain Investment Advisers AGENCY: Securities and Exchange Commission. ACTION: Final rule. SUMMARY: The Securities and Exchange Commission is adopting a new rule under the Investment Advisers Act of 1940 that prohibits an investment adviser from providing
Mar 1, 2023 · March 1, 2023 - As we approach, on March 14, its 12-year anniversary, now is as good a time as any to reflect on Securities and Exchange Commission ("SEC") Rule 206 (4)-5 (the "Pay-to-Play Rule ...
Jun 25, 2020 · For example, the SEC staff has indicated that while a covered associate’s contribution to a PAC generally would not trigger the two-year time-out, if the contribution is earmarked or known to be provided for the benefit of a particular political official, it would implicate the catchall provision because the covered associate would be doing ...
Jul 9, 2010 · The Rule requires investment advisers registered with the SEC that provide advisory services to government entities or Covered Investment Pools to maintain detailed records of contributions made by the adviser and its covered associates to government officials (including candidates) and payments to state and local political parties and PACs ...
