SEC Delays Compliance Date for Pay-to-Play Rule - State and Federal Communications

June 18, 2012  •  

SEC Delays Compliance Date for Pay-to-Play Rule

SECThe Securities and Exchange Commission has extended the date advisers and third-party solicitors must comply with new pay-to-play rules until April 2013.

The Commission is extending the compliance date for the ban on third-party solicitation under rule 206(4)-5 of the Investment Advisers Act of 1940 in order to ensure an orderly transition for third-party solicitors and advisers and as well as to provide additional time to adjust compliance policies and procedures after the transition.

Rule 206(4)-5, the “Pay to Play Rule,” prohibits an investment adviser from providing advisory services for compensation to a government client for two years after the adviser or certain of its executives or covered associates make a contribution to elected officials or candidates.

The rule also prohibits an adviser and its covered associates from providing or agreeing to provide, directly or indirectly, payment to any third-party for a solicitation of advisory business from any government entity on behalf of such adviser, unless such third-party was an SEC-registered investment adviser or a registered broker or dealer subject to pay to play restrictions adopted by a registered national securities association.

More information can be found here.

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