The SEC’s Pay-to-Play Rule: Ensure This Election Season Doesn’t End with a Compliance Violation at Your Firm

IAWatch Webinar

10/20/2015 02:00 p.m. - 03:00 p.m. EDT

Investment Management

Kelley A. Howes


With the presidential election season heating up exceptionally early this time around, the benefits of absorbing a refresher on the SEC’s pay-to-play rule are not up for debate. Many worry how the SEC’s pay-to-play rule’s punishing two-year time-out on payments would harm their firm’s paycheck. However, a violation would cause even longer lasting damage as the adviser’s tarnished reputation could potentially drive away clients.

Of Counsel Kelley A. Howes will speak on a panel focused on SEC Rule 206(4)-5, also known as the SEC’s pay-to-play rule.

Topics Will Include:

  • The rule's strict “do's and don'ts” - and how your compliance peers convey these to staff;
  • Takeaways from a recent SEC pay-to-play enforcement action;
  • Compliance tips to avoid trouble at your firm;
  • How to maneuver within the SEC's exemptive relief process;
  • What your peers are doing by way of pay-to-play staff training;
  • Why the SEC's newly implemented third-party solicitation ban promises to confuse firms; and,
  • The latest on coming pay-to-play rules from FINRA & the MSRB.


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