Recent SEC Order Finds Employee's Use of Company Resources Violates Pay to Play Rules

October 10, 2012

A recent Securities and Exchange Commission action finding violations of municipal securities pay to play rules brings into focus the broad scope of new political contribution regulations under the Investment Advisers Act of 1940 and new business conduct standards applicable to swap dealers dealing with governmental entities, including state, municipal and county pension funds, and underscores the potential risks posed to dealers by the political activities of their employees.