The Securities and Exchange Commission extended the date by which registered investment advisers must comply with the ban on third-party solicitation in Rule 206(4)-5 under the Investment Advisers Act. The SEC is extending the compliance date in order to ensure an orderly transition. Since solicitors will need to registered as an investment adviser or a … Read more »
Tag: MSRB
Placement Agent Limitations on Gifts
The Municipal Securities Rulemaking Board is continuing to tighten the limits on what placement agents can do as part of their fundraising activities for private funds. Dodd-Frank created a new category of “municipal advisors” and placed them under the regulatory oversight of the MSRB. If your fund uses a placement agent and has government-sponsored investors … Read more »
Pay to Play Rules for Placement Agents
The SEC imposed strict limitations on the ability of investment advisers to make political contributions when their clients include government bodies when it issued Rule 206(4)-5. They don’t want government investment decisions decided campaign contributions. This limitation also applies to private investment funds under the language of the rule and the changes to the Investment … Read more »
Placement Agents and the MSRB
In addition to laying out the changes to Form ADV, in Release No. IA-3110 the SEC also took a slightly different course on regulating placement agents. Rule 206(4)-5, released in July 2010, required placement agents to either be registered with the SEC as an investment adviser and subject to the limitation on campaign contributions, or … Read more »