SEC 206(4)-5 pay to plah

[Guest Southern FA]

I am reading through the new SEC final rule on pay to play for governmental retirement systems. I am unsure whether their definition of elected official includes people who are solely elected by the membership of the retirement systems. For example, if someone on a City retirement system board is elected by the active employees, are they covered by 206(4)-5? Are there the same restrictions on investment advisors (it would certainly seem consistent with the SEC's intent). The retirement system certainly looks like the SEC is treating it as a governmental entity.