Pay-To-Play Compliance Deadline Around the Corner for Investment Advisers
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This client memo provides a reminder of an upcoming compliance deadline on March 14, 2011 for the new Rule 206(4)-5 under the Investment Advisers Act of 1940, which is designed to address “pay-to-play” practices in the investment advisory industry. The Rule applies to registered and certain unregistered investment advisers and has implications for private fund sponsors.