The U.S. Securities and Exchange Commission (“SEC”) last week announced settlements with four investment advisory firms regarding alleged violations of the SEC’s pay-to-play rule, illustrating that federal regulators continue to aggressively pursue such cases. The rule at issue, Rule 206(4)-5 (“the Rule”), prohibits investment advisers from, among other things, receiving
Continue Reading SEC Commissioner Says It’s “Past Time” To Reform Overly “Blunt” Pay-to-Play Rulesettlement
SEC Issues Fines for Pay-to-Play Violations That Predate Its Pay-to-Play Rule
A $12 million settlement announced last week by the Securities & Exchange Commission suggests that the SEC will aggressively pursue alleged schemes connecting political contributions to government contracts even if the political contributions do not violate its 2010 pay-to-play rule. According to the settlement order, in 2010, the head of…
Continue Reading SEC Issues Fines for Pay-to-Play Violations That Predate Its Pay-to-Play Rule
FEC Issues Zero Tolerance Decision on Foreign National Contributions
In a little noticed decision earlier this month, the FEC announced the settlement of an enforcement case that sets a compliance standard that few companies may currently meet. FEC ADR Case 708 (Marsh & McLennan Companies, Inc. PAC). The outcome is even more surprising because the case involved a single…
Continue Reading FEC Issues Zero Tolerance Decision on Foreign National Contributions