SEC Publishes FAQs on Pay-to-Play Rule

 

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March 23, 2011

TO: 529 PLAN MEMBERS No. 2-11
BANK, TRUST AND RECORDKEEPER ADVISORY COMMITTEE No. 18-11
BROKER/DEALER ADVISORY COMMITTEE No. 18-11
CLOSED-END INVESTMENT COMPANY MEMBERS No. 29-11
COMPLIANCE MEMBERS No. 21-11
INVESTMENT ADVISER MEMBERS No. 10-11
MUNICIPAL SECURITIES ADVISORY COMMITTEE No. 16-11
PENSION MEMBERS No. 18-11
SEC RULES MEMBERS No. 44-11
SMALL FUNDS MEMBERS No. 28-11
TRANSFER AGENT ADVISORY COMMITTEE No. 22-11 RE: SEC PUBLISHES FAQS ON PAY-TO-PLAY RULE

 

The Securities and Exchange Commission has published staff responses to frequently asked questions (“FAQs”) about Rule 206(4)-5 under the Investment Company Act of 1940, the pay-to-play rule.  The FAQs address questions regarding compliance dates, third-party solicitors, and the definitions of “covered associate,” “government entity,” and “official.”  They do not yet address many of the questions members are struggling with.  The FAQs are available at  http://www.sec.gov/divisions/investment/pay-to-play-faq.htm.

 

Tamara K. Salmon
Senior Associate Counsel
Heather L. Traeger
Associate Counsel