Pay-to-Play: SEC Staff Provides New Guidance on Advisers Act Rule 206(4)-5

May 09, 2011
The staff of the Securities and Exchange Commission recently issued a series of questions and answers (“FAQs”) intended to assist advisers in complying with its new pay-to-play rule: Rule 206(4)-5 under the Investment Advisers Act of 1940. This update examines the guidance provided in the FAQs and how it will affect advisers as they implement their compliance programs.