With the contenders for President nearly locked up for the conventions, I’m stuck worrying about political contributions. At least one fund manager continues to look for an exemption after a small oversight.
The firm hired a new senior investment professional in September 2014. A year earlier, the employee had made a contribution to Bruce Rauner who was running for Governor of Illinois.
The problem is that the Governor appoints trustees to the board of trustees for the Illinois state pension funds. Some of those funds were investors in one of the firm’s funds.
The contribution was paying the cost of a small meet-and-greet reception for the candidate. The total value was $892.17. That small amount is greater than the $350 limit and triggers the two-year ban on fees.
The firm is not alone. On page 14 of the request, it lists several other requests for exemption.
- Davidson Kempner Capital Management LLC, Investment Advisers Act Release Nos. 1A-3693 (October
17, 2013) (notice) and IA-3715 (November 13, 2013) (order) - Ares Real Estate Management Holdings, LLC, Investment Advisers Act Release Nos. IA-3957 (October 22, 2014) (notice) and IA-3969 (November 18, 2014) (order)
- Crestview Advisers, LLC, Investment Advisers Act Release Nos. IA-3987 (December 19, 2014) (notice) and IA-3997
(January 14, 2015) (order) - T. Rowe Price, Investment Advisers Act Release Nos. IA-4046 (March 12, 2015) (notice) and IA-4058 (April 8, 2015) (order)
- Crescent Capital Group, LP, Investment Advisers Release Nos. IA-4140 (July 14, 2015) (notice) and IA-4172 (August 14,
2015) (order) - Starwood Capital Group Management, LLC, Investment Advisers Act Release Nos. IA-4182 (August 26, 2015) (notice) and IA-4203 (September 22, 2015) (order)
- Fidelity Management & Research Company and FMR Co., Inc., Investment Advisers Release Nos. IA-4220 (October 8,
2015)(notice) and IA-4254 (November 3, 2015)(order) - Brookfield Asset Management Private Institutional Capital Adviser US, LLC et. al., Investment Advisers Act Release Nos. IA-4337 (February 22, 2016)(notice) and IA-4355 (March 21, 2016)
That is a list of some A-list fund managers with a long track record of good compliance. Clearly the rule must be overly broad and tripping up advisers and fund managers if so many are seeking exemptions.
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