Last week the Commodity Futures Trading Commission (“CFTC”) issued a No-Action Letter that helps harmonize the CFTC’s pay-to-play rules for swap dealers (Regulation 23.451) with both the SEC and Municipal Securities Rulemaking Board (“MSRB”) pay-to-play regulations. The Letter also provided guidance regarding the two-year “look back” period, during which time swap dealers may be prohibited
SEC
Major Wall Street Firm Pays Nearly $12 Million to Settle Pay-to-Play Violations
By Ronald M. Jacobs & Lawrence H. Norton on
Prominent Wall Street firm Goldman Sachs will pay almost $12 million to settle charges that one of its investment bankers made undisclosed campaign contributions to a state official responsible for awarding government contracts.
The case is the first SEC action for pay-to-play violations based on “in-kind” – meaning, non-cash – contributions to a political campaign.…
SEC Issues National Examination Risk Alert on MSRB “Pay-to-Play” Rules
By Scott Gluck on
Last week the SEC’s Office of Compliance Inspections and Examinations issued a National Examination Risk Alert for brokers, dealers and municipal securities dealers regarding compliance with Municipal Securities Rulemaking Board (MSRB) Rule G-37. The Risk Alert noted that recent SEC examiners have observed practices that raise concerns whether firms are adequately complying with all of…
SEC Extends Compliance Date for Ban on Use of Third Party Marketers
By Scott Gluck on
Posted in Pay-to-Play, SEC
Last week the Securities and Exchange Commission issued a Final Rule extending the date by which investment advisers are required to comply with the ban on the use of third-party marketers under Rule 206(4)-5 (the Federal Pay-to-Play Rule”). This ban had been set to go into effect this Wednesday, June 13.
The ban will now…