Category Archives: Pensions

SEC Proposes Ban of Political Contributions by Registered Investment Advisers Seeking to Manage Public Pensions

July 24, 2009

Earlier this week, the U.S. Securities and Exchange Commission (“SEC”) proposed a new rule prohibiting “pay to play” practices by SEC registered investment advisers seeking to manage money for state and local governments. The SEC explained that “[t]he measures are designed to prevent an [investment] adviser from making political contributions or hidden payments to influence their selection by government officials.” The proposed SEC rule prohibit three primary activities by a federally registered investment adviser seeking to manage public funds: (1) political contributions (2) solicitation of political contributions and (3) use of a third-party to solicit the government.

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Investment Advisers Should Review Insider Trading Policies & Procedures

March 08, 2008

Although the recent report concerning possible insider trading by a public pension plan administrator conducted by the Division of Enforcement of the U.S. Securities and Exchange Commission (“SEC”) involves an essentially unregulated money manager which is not subject to the Investment Advisers Act of 1940, it still offers an excellent opportunity for each registered investment adviser to review its policies and procedures regarding trading activity based upon material, non-public (“insider”) information.

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Pension Consulting – Follow the Money!

May 20, 2005

With the SEC’s recent focus upon pension consulting, it’s incumbent upon the chief compliance officers of investment advisors to review again whether their firms are properly disclosing the conflicts of interest that may exist with their pension consulting services and then supervising, mitigating and/or eliminating such conflicts.

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