InstructorTerri Hays
TypeOnline Course
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Tuition Options


PracticeEdge Elite™

Standard Tuition $400

Senior Fellow Ki Hong, JD, Partner, Skadden, Arps, Slate, Meagher & Flom

The “Pay to Play” Regulation and Compliance landscape continues to become more complex and treacherous:

This session will provide a comprehensive overview of the Federal and State “Pay to Play” regulatory framework.

The Speaking Faculty is comprised of seminal experts within the field, who will deliver a complete discussion and analysis regarding the intricate legal mechanics, latest developments and best practices; as well as a detailed examination of the two forms of “Pay to Play” regulation:

  1. Strict-liability whereby a political contribution automatically disqualifies a firm from contracting with the effected public entity (i.e. SEC Rule 206(4)-5, MSRB Rule G-37, CFTC Rule 23.451, and similar state laws).
  2. Fraud provisions (e.g. Federal Honest Service Fraud) which may trigger a criminal prosecution against the person or firm for proffering the contribution.

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Students shall learn the following within this Course:

  • Define the types of laws and rules that regulate pay-to-play
  • Fraud/conflict of interests based pay-to-play laws
    • Define the relevant federal and state fraud/conflict of interest laws and rules
    • Recognize the areas of conduct and types of arrangements that create heightened risk under fraud/conflict of interests based pay-to-play laws
    • Identify compliance strategies, systems and best practices to ensure compliance with these laws
  • Define strict-liability pay-to-play laws
    • Define the SEC’s objectives in adopting and enforcing the pay-to-play rule;
    • Learn key components of SEC Rule 206(4)-5 for investment advisers
    • Identify other federal pay-to-play rules (MSRB Rule G-37 for broker-dealers that underwrite municipal bonds and municipal advisors, and CFTC Rule 23.451 for swap dealers)
    • Identify state and local pay-to-play laws and their intersection with above federal pay-to-play rules
    • Identify methods for compliance, monitoring and testing of political contributions and activity to comply with the patchwork of strict-liability pay-to-play laws

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Senior Fellow:

Ki Hong, JD, Partner, Skadden, Arps, Slate, Meagher & Flom, LLP

Guest Lecturers:

Kenneth Gross, JD, Partner, Skadden, Arps, Slate, Meagher & Flom, LLP
Ken Berman, JD, Partner, Debevoise
Lou Randazzo, JD, Municipal Securities and Public Pensions, SEC
Kevin Kelcourse, JD, Assistant Regional Director, SEC
Heather Traeger, JD Partner, O’Melveny & Myers

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Accreditation Information

CLE Information

Credit Hours: 2
Subject Area: Professional Practice
States: Contact Curriculum Advisor For More Information

CPE Information

Credit Hours: 3.5
Subject Area: Accounting
States: Contact Curriculum Advisor For More Information

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Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.

Arizona: Does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. RCA programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.

Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.

New Hamphsire: The approval is for three years from recorded date.

New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.

New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web Programs or live Webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.

North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.

Ohio: To confirm that the web program has been approved, please refer to the list of Ohio’s Approved Self Study Activities at Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.

Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.

Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.

Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.

Tennessee: The approval is for the calendar year in which the live program was presented.

Virginia: All distance learning courses are to be done in an educational setting, free from distractions.

Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.

Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

If applicable, the RCA will apply for credit in your state upon request.