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SEC Pay-to-Play Placement Agent Restriction Delayed, and a Reminder for Campaign Season
9 July 2015
View Client Update
The SEC staff has again delayed the compliance date of the SEC Pay-to-Play Rule that will prohibit investment advisers from retaining placement agents and client solicitors that are not themselves subject to “pay-to-play” rules until such time as both FINRA and the MSRB have adopted such rules. It is currently not clear when FINRA and the MSRB will adopt their proposed rules.
With the kick-off of presidential campaign season, we recommend that investment advisers remind their covered associates of their restrictions under the Pay-to-Play Rule and applicable state and local laws, including with respect to state or local government officials running for federal office (
, governors running for president).
Kenneth J. Berman
Michael P. Harrell
Jennifer R. Cowan
Pro Bono Counsel & Litigation Counsel
UK Modern Slavery Act Transparency Statement
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