ACA Program Reviews Federal Pay to Play Rules (Part One of Two)

A recent ACA Compliance Group (ACA) program provided a comprehensive overview of the panoply of federal, state and local pay to play rules with which fund managers must contend. The program featured Ki P. Hong, partner at Skadden, and Elaine Vincent, consultant at ACA. This first article in our two-part series summarizes the four federal pay to play rules. The second article will review state and local pay to play rules; traps for the unwary; and compliance policies and procedures. For additional commentary from ACA, see “ACA Panel Examines Compliance Issues Faced by Credit Managers” (Nov. 15, 2018); and “Developing a 2018 Compliance Budget: How Investment Advisers Can Make the Most of Limited Resources” (Dec. 21, 2017).

To read the full article

Continue reading your article with a PELR subscription.