SEC PAY-TO-PAY RULE IS PROPOSED

On August 4, 1999, the SEC proposed Rule 206(4)-5, which would prohibit an investment adviser from providing advisory services to a government client for two years after the adviser or any of its personnel or solicitors made a contribution to any state treasurer, state comptroller or other elected official who control or otherwise influence the selection of investment advisers. Certain de minimis contributions would be permitted. Advisers would also have to keep specific types of records of political contributions and solicitation activities.


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