In addition to laying out the changes to Form ADV, in Release No. IA-3110 the SEC also took a slightly different course on regulating placement agents. Rule 206(4)-5, released in July 2010, required placement agents to either be registered with the SEC as an investment adviser and subject to the limitation on campaign contributions, or [...]
Tag Archives: MSRB Rule G-37
SEC Warns Firms on Muni Pay-to-Play Rules
on March 22, 2010 in Compliance Programs
While sources are wallowing in the exposure of a political figure in a “pay to play” scandal, I thought there might be some lessons for other investment managers as states and perhaps the SEC roll out limitations on political contributions. The original story seemed mildly interesting. The SEC warned firms that municipal securities rules prohibiting [...]
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