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SEC Announces First Investment Adviser 'Pay-To-Play' Enforcement Action
Ballard Spahr LLP Link to more items from this source
June 24, 2014
"The rules are applied formulaically: they do not require that an advisor intend to influence the government official to award the advisor business or any evidence that the contribution generated business from the recipient.... [T]he chief of the SEC's Municipal Securities and Public Pensions Unit warned: 'Public pension funds are increasingly investing in alternative investment vehicles such as hedge funds and private equity funds. When dealing with public pension fund clients, advisers to those kinds of investment vehicles should be mindful of the restrictions that can arise from political contributions.'"

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