Kelley A. Howes, an editor of the BD/IA Regulator, recently published Pay-to-Play Rule─Practical Considerations for Investment Advisers in the May/June 2015 issue of the Journal of Taxation and Regulation of Financial Institutions.
In addition to discussing the SEC's first case against an investment adviser for violations of Rule 206(4)-5 (the "Pay-to-Play Rule") under the Investment Advisers Act, the article offers practical guidance that investment advisers may want to consider in developing and implementing compliance programs and policies.
The abstract of the article is available here. For additional background, see our blog post and related Client Alert.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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