News & Events

Partners Anne Choe and Meaghan Kelly were quoted in an article titled, “SEC Continues Deregulatory Agenda With Proposed Pay to Play Rule Rescission,” which was published by Private Equity Law Report. In discussing the SEC’s proposal to rescind its so-called pay to play rule and what provisions would remain to protect investors after the rule is rescinded, Anne explained that “the SEC recognizes that its enforcement toolkit already has everything needed to enforce against true pay to play activity – namely, the anti-fraud provisions of the Advisers Act – and also the ability to enforce the standard of conduct that all advisers are already subject to.” In advance of the rule being officially rescinded, Meaghan noted, “Although advisers must continue adhering to their existing 206(4) 5 policies, they can start planning for what changes might look like and even technically change their policies now to have other controls built in…Advisers must think holistically about what policies, attestations and disclosures will need to be modified.”

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