Regulatory Compliance Association Reviews

Political Contributions and “PAY-TO-PLAY”

DechertDate: September 19, 2018
General Session: 12:00 PM ET to 1:30 PM ET
Location: Webcast (Free)

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This session will provide training on compliance with regulatory requirements under the rules of the Financial Industry Regulatory Authority (“FINRA”), Municipal Securities Rulemaking Board (“MSRB”) and Securities and Exchange Commission (“SEC”) related to political contributions and other “pay-to-play” issues.  These issues are particularly timely this election year but are always of issue for financial professionals. Faculty will focus on issues relevant to firms regulated by FINRA and the MSRB and broker-dealers that are dually-registered with the SEC as investment advisers. In addition to providing an overview of legal and regulatory requirements under FINRA and MSRB rules as well as Rule 206(4)-5 under the investment Advisors Act of 1940, faculty will discuss practical issues related to compliance with these requirements and provide suggestions for addressing thorny compliance challenges. The session will also discuss the lessons provided by relevant SEC and FINRA enforcement actions.

Learning Objectives:

  • Identify the requirements applicable to political contributions and pay-to-play requirements under (i) MSRB’s Pay-to-Play Rule – MSRB Rule G-37;(ii) FINRA’s Pay-to-Play Rule – FINRA Rule 2030; and (iii) the SEC’s Pay-to-Play Rule – SEC Rule 206(4)-5
  • Define exemptions from these rules
  • Recognize the consequences of violating these rules
  • Discover lessons learned from relevant enforcement actions
  • List reporting and recordkeeping obligations
  • Distinguish key elements for building an effective compliance program
  • Apply answers to common compliance questions

Session Chairman:

Walter Zebrowski, JD, CPA, Principal, Hedgemony Partners
Chairman, Regulatory Compliance Association

Senior Fellow from Practice:

K. Susan Grafton, JD, Partner, Dechert

Guest Lecturers

Brenden Carroll, JD, Partner, Dechert
Erik Strom, Director, Government & Community Relations, Russell Investments