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ARTICLE · 07 APRIL 2015

Contribution Caution: Mitigating Risks From Pay-To-Play

WilmerHale
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With the record-breaking campaign expenditures of the 2014 midterm elections behind us, and the 2016 campaign cycle already heating up, this is an ideal moment for investment advisers (including advisers to venture capital funds and certain private equity and hedge funds) to ensure that they have mechanisms in place to verify compliance with the U.S. Securities and Exchange Commission’s pay-to-play rule.

United StatesFinance and Banking
Matthew Chambers
Matthew Chambers
Benjamin Neaderland
Benjamin Neaderland
April M. Elliott
April M. Elliott
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With the record-breaking campaign expenditures[1] of the 2014 midterm elections behind us, and the 2016 campaign cycle already heating up, this is an ideal moment for investment advisers (including advisers to venture capital funds and certain private equity and hedge funds) to ensure that they have mechanisms in place to verify compliance with the U.S. Securities and Exchange Commission's pay-to-play rule.[2] The SEC has ramped up enforcement of the rule: the first case charged under the rule settled last year,[3] and the director of the SEC's Division of Enforcement has declared it to be a current priority.[4]

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