Rule 206(4)‑5 of the Investment Advisers Act of 1940 - known as the Pay to Play Rule – comes into focus in major election years. With political activity gaining momentum heading into the upcoming midterm elections, the Private Equity Law Report interviewed Skadden partner Ki P. Hong to help fund managers identify and avoid pay to play compliance risks and other potential legal pitfalls. The article outlines relevant federal, state and local pay to play rules; examines key differences between those regimes; summarizes SEC enforcement activity targeting political contributions; and prescribes steps fund managers can take to ensure compliance. For additional commentary from Hong, see our two-part series: “Federal Pay to Play Rules” (Feb. 14, 2019); and “State and Local Pay to Play Rules; Traps for the Unwary; and Compliance” (Feb. 21, 2019).