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Pershing Square & 9 Others Violated Pay-to-Play Rule – SEC
Ten investment advisory firms have agreed to pay penalties ranging from $35K to $100K to settle charges that they violated the SEC’s investment adviser pay-to-play rule by receiving compensation from public pension funds within 2 years after campaign contributions had been made by the firms’ associates.
Investment advisers are subject to a 2-year timeout from providing compensatory advisory services either directly to a government client or through a pooled investment vehicle after political contributions were made to a candidate who could influence the investment adviser selection process for a public pension fund or appoint someone with such influence.
The following firms consented to the SEC’s orders finding they violated Section 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-5.
- Adams Capital Mgmt - $45,000
- Aisling Capital - $70,456
- Alta Communications - $35,000
- Commonwealth Venture Mgmt - $75,000
- Cypress Advisors - $35,000
- FFL Partners - $75,000
- Lime Rock Mgmt - $75,000
- NGN Capital - $100,000
- Pershing Square Cap. Mgmt - $75,000
- The Banc Funds Company - $75,000
