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October 19, 2020

illumis Webinar: Pay-to-Play Compliance & the 2020 Election

We’re excited to host a webinar regarding pay-to-play compliance around the 2020 election! Please join our team on October 28th at 4 p.m. ET for a conversation with two experts on the subject. We will focus on some of the complexities of pay-to-play law and political contribution compliance and hear from the experts on best practices as well as emerging areas of risk. You can find more details about our guests below and to register, please click here.

We’re including more details about our guests below. We hope you can join us!

Ki P. Hong is the head of Skadden’s Political Law Group. He advises major corporations on the unique political law issues they face when engaging in government affairs or government procurement activity. These include federal and state campaign finance, lobbying, gift, ethics and conflict-of-interest laws. Mr. Hong also advises clients on pay-to-play laws that impose special restrictions on the political activity of companies that have or seek government contracts, as well as their covered employees. He advises clients on establishing and maintaining comprehensive systems to ensure compliance with those laws. In addition, he represents clients at the enforcement stage.

Heather L. Traeger serves as the Chief Compliance Officer and General Counsel for the Teacher Retirement System of Texas. TRS is one of the largest public pension plans in the country at approximately $154 billion AUM. Heather has significant experience advising a variety of financial institutions. Prior to joining TRS, Ms. Traeger was a partner at O’Melveny & Myers LLP in the Financial Services Practice. She has also previously served as an Associate Counsel at the Investment Company Institute (ICI) and in several positions at the U.S. Securities and Exchange Commission.
Why real-time data is essential to helping your investment firm avoid violating pay-to-play regulations, SEC rule 206(4)-5

Political contributions made by firm employees pose a significant threat to investment advisory firms. And even firms with the best compliance teams can be at risk of violating pay-to-play regulations, like the Securities and Exchange Commission’s (SEC) rule 206(4)-5, given the complexity of the rules and the myriad of regulations to which firms must comply.

Because of this, investment firms must arm themselves with the access to and support of real-time data, which can help identify potential violations and anomalies in the political donation process.

By leveraging real-time data, investment firms can quickly detect suspicious or unauthorized activities and take prompt action to prevent pay-to-play violations.

Beyond SEC Rule 206(4)-5: A look at state and local political contributions compliance regulations

SEC Rule 206(4)-5 is arguably the most well known regulation regarding political contributions compliance or pay-to-play compliance. However, it certainly isn’t the only regulation to which firms must comply.

In fact, beyond federal regulations, firms which take part in government contracted work must contend with numerous and varied state and local regulations as well. Such regulations present unique challenges because of the various requirements within each, which should they be neglected, can cause significant financial and reputational damage.

Aligning pay-to-play rule 206(4)-5 compliance practices with your investment firm’s regulatory compliance program

While it would be almost too easy to treat the Securities and Exchange Commissions’ (SEC) pay-to-play rule 206(4)-5 as a special requirement implemented only during election years, that mistake can cause serious, firm-wide damages. In fact, for investment firms, establishing a compliance program which actively and regularly incorporates compliance with the SEC pay-to-play rule is essential to avoiding fines, sanctions, lockout periods, loss of revenue and a damaged reputation.