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ARTICLE · 13 JULY 2010

Compilation of Non-Enforcement Actions - July 2010

On June 30, 2010, the SEC approved a new rule that significantly curtails the pay-to-play practices by investment advisers who seek to provide investment advisory services to public pension and other government plans.

United StatesFinance and Banking

Non-Enforcement Matters

SEC Adopts Regulations to Restrict Pay-to-Play Activities by Investment Advisers

On June 30, 2010, the SEC approved a new rule that significantly curtails the pay-to-play practices by investment advisers who seek to provide investment advisory services to public pension and other government plans.

Pay-to-play practices involve the making of campaign contributions and related payments by an investment management firm or its executives or employees to elected officials for the purposes of influencing such officials to award investment management contracts to the contributor-investment management firm.

The new rule provides that an investment adviser who makes a political contribution to an elected official (or to a candidate who is running for such office) in a position to influence the selection of the adviser, will be barred for two years from providing advisory services for compensation, either directly or through a fund. The

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