Client Alert
The Securities and Exchange Commission recently set the compliance date for the ban on certain payments to third-party solicitors under Rule 206(4)-5 of the Investment Advisers Act of 1940 (the “Pay-to-Play Rule”) as July 31, 2015.
The SEC separately clarified in its “Staff Responses to Questions About the Pay to Play Rule” that it would not recommend enforcement actions against investment advisers for payments to third-party solicitors under the Pay-to-Play Rule until equivalent or more stringent pay-to-play rules are adopted by the Financial Industry Regulatory Authority and the Municipal Securities Rulemaking Board and are effective.