Pay-To-Play Lessons From This Week's SEC Settlements

Law360, New York (January 18, 2017, 4:05 PM EST) -- Charles Borden

William E. White

Claire Rajan On Jan. 17, 2017, the U.S. Securities and Exchange Commission announced 10 separate settlements with investment advisory firms relating to violations of SEC Rule 206(4)-5, the SEC’s pay-to-play rule for investment advisers and exempt reporting advisers. Although none of the 10 cases involved a major penalty (the largest fine was $100,000), they collectively demonstrate the SEC’s continued focus on pay-to-play enforcement cases and the extent to which pay-to-play enforcement represents an important priority of the Enforcement Division’s new Public Finance Abuse Unit.  As Andrew Ceresney, the then-head of the SEC’s Enforcement Division, noted in...

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