Earlier this year, the SEC adopted anti-fraud rule 206(4)-5 (the “Pay to Play Rule”) which serves to limit political contributions and “pay to play” activities. Prior to the effective date of this rule, all investment advisers should ensure that they build out comprehensive political contribution reporting and pre-clearance policies.
On November 11th HedgeOp CEO Bill Mulligan to a look at the “Pay to Play Rule” with a focus on the following areas:
- What are the basics of the Rule and who does it apply to?
- What types of policies should advisers build out?
- How should political contribution reporting and pre-clearance work?
- When does the Rule become effective?
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