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Doug Cornelius on compliance for private equity real estate

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Category: Pay to Play

Another Terrible Pay-to-Play Case

Doug Cornelius August 22, 2024August 21, 2024 Pay to Play   [+]

Just in time for a governor to be selected to the presidential ticket, the Securities and Exchange Commission levied a big fine for violating the Pay-to-Play Rule for Investment Advisers. Obra Capital Management was the sponsor and adviser to a closed-end, private fund. The Michigan Public Employees’ Retirement Fund made a $100 million commitment to … Read more »

Yard Signs and Pay to Play

Doug Cornelius June 14, 2017June 15, 2017 Pay to Play   [+]

I was fortunate to be able to attend the Securities and Exchange Commission’s CCO Outreach in Boston yesterday. I’ll post more later, but today I wanted focus on one topic that one panel discussed: the pay to play rule. The CCO Outreach stated that they were not trying to play “gotcha” as part of the … Read more »

Vice Presidents and the Pay to Play Rule

Doug Cornelius July 21, 2016July 20, 2016 Pay to Play   [+]

The Securities and Exchange Commission limits the ability of investment advisers and fund managers from contributing to certain politicians that can influence investment decisions for state pension funds. Under Rule 206(4)-5, you can contribute up to $150 to any candidate or up to $350 if you can vote for the candidate. Mike Pence is the … Read more »

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