Navigating Pay-to-Play Rule Compliance in the 2024 Election Season

USA

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A contentious 2024 U.S. election season is well underway, with candidates and related PACs reaping political donations in record numbers. Overall fundraising for campaigns in this cycle – federal, state, and local – has handily outstripped all prior periods. As the November election draws closer, so too will the size of campaign coffers. It is clear that the public is actively supporting their political picks, and those supporters most certainly include employees of fund managers whose donations can trigger issues for their firms.

The SEC’s “Pay-to-Play Rule” that has a strict liability standard may be well known, but it is not the only contribution-focused rule. Many states, counties and cities have additional requirements and restrictions. In addition, pensions and endowments can have their own sets of restrictions applicable to anyone doing business with them. All these rules put the burden on the fund manager to ensure it, and its employees, are in compliance at all times. Whatever the approach taken, it must be effective, as missteps can cost dearly.

On July 24, please join AIMA and Schulte Roth & Zabel for a webinar to discuss the requirements and risks fund managers face from pay-to-play rules. During this session, we will review real-life scenarios of how pay-to-play rules can impact fund managers – some are obvious, some less so. We also will discuss various approaches fund managers have taken to ensure and document compliance. Attendee questions are welcome and encouraged.

Panelists:

Allison Scher Bernbach, Partner, Schulte Roth & Zabel LLP

Michael Didiuk, Partner, Schulte Roth & Zabel LLP

Suzan Rose, Senior Advisor, Government & Regulatory Affairs, AIMA

 

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