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Client Update July 9, 20151Client Update SEC Autoplay Placement Agent Restriction Delayed, and a Reminder for Campaign Season NEW YORK Michael P. Harrell mpharrell@debevoise.com Jordan C. Murray jcmurray@debevoise.com Jennifer

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How to fill out sec pay-to-play placement

How to fill out sec pay-to-play placement:

01

Obtain the necessary forms: Start by accessing the SEC's website or contacting your broker-dealer to obtain the required forms for the pay-to-play placement. These forms typically include a disclosure document and a questionnaire.

02

Understand the requirements: Familiarize yourself with the SEC's regulations regarding pay-to-play placement. These regulations are designed to prevent individuals or firms from making political contributions in order to influence the awarding of investment advisory contracts with government entities.

03

Gather the requested information: Fill out the forms by providing the requested information accurately and completely. This may include details about your firm's political contributions and affiliations, as well as any potential conflicts of interest.

04

Review and double-check: Before submitting the forms, carefully review all the provided information for accuracy and completeness. Ensure that you have answered all the required questions and attached any necessary supporting documentation.

05

Submit the forms: Once you are confident that all the information is accurate, submit the forms to the appropriate authority. This might be the SEC, a specific state regulatory agency, or your broker-dealer, depending on the specific requirements.

Who needs sec pay-to-play placement:

01

Investment advisers: Investment advisers who participate in the placement of advisory contracts with government entities are typically required to comply with the SEC's pay-to-play rules. This includes both registered investment advisers and exempt reporting advisers.

02

Firms seeking government contracts: If your firm provides investment advisory services and intends to compete for government contracts, it is crucial to familiarize yourself with the SEC's pay-to-play rules and ensure compliance. Failure to comply may result in penalties and restrictions.

03

Government entities: Pay-to-play placement regulations are in place to protect government entities from being unduly influenced by political contributions. By requiring firms to disclose their contributions and affiliations, government entities can make more informed decisions when awarding advisory contracts.

Note: It is essential to consult with legal professionals or compliance experts to ensure accurate and up-to-date information regarding the SEC's pay-to-play placement requirements.

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What is sec pay-to-play placement?

SEC pay-to-play placement is a rule that regulates political contributions made by investment advisors to government officials in order to secure business opportunities.

Who is required to file sec pay-to-play placement?

Investment advisors who manage assets for government entities are required to file SEC pay-to-play placement.

How to fill out sec pay-to-play placement?

SEC pay-to-play placement is typically filled out electronically through the SEC's reporting system.

What is the purpose of sec pay-to-play placement?

The purpose of SEC pay-to-play placement is to prevent investment advisors from using political contributions to gain unfair advantages in securing government business or contracts.

What information must be reported on sec pay-to-play placement?

Information such as the amount of political contributions made by the investment advisor, the recipient of the contributions, and the timing of the contributions must be reported on SEC pay-to-play placement.

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