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July 20, 2021

illumis Welcomes New Client: Pillar Compliance Group

David Lombardy recently launched his own regulatory and compliance consulting firm, Pillar Compliance Group, to assist investment managers with the development, implementation, and ongoing monitoring of their compliance programs. In reviewing the regulatory environment around pay-to-play compliance, he saw the value in using illumis’ political contribution monitoring platform to provide the best risk coverage available for his clients.

According to David, “A pay-to-play violation is a risk for all my clients. A client may have policies and procedures in this area, but I strongly encourage them to enhance their compliance program by testing those policies and procedures. illumis has the solution to help my clients test their compliance policies in this area and therefore mitigate this risk to their business.”

We are excited to welcome David and Pillar Compliance Group to the illumis compliance platform and look forward to supporting their compliance efforts, and helping them better serve their clients and help manage risks.

Looking to learn more about how to manage pay-to-play risks effectively? Sign up here or contact us at solutions@illumis.com.
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.