On September 14, 2026, the staff of the US Securities and Exchange Commission’s (“SEC” or “Commission”) Division of Examinations (the “Division”) issued a Risk Alert (the “Risk Alert”) setting out their examination observations of SEC-registered investment advisers’ (“RIAs”) annual compliance reviews, as required by Rule 206(4)-7 (the “Compliance Rule”) under the Investment Advisers Act of
Robert Kim
SEC Proposes Rescission of Investment Adviser “Pay-to-Play” Rule
By Leslie S. Cruz, Jodi Erlandsen, Adam D. Kanter, Robert Kim, Mickey Leibner, Peter M. McCamman & Joseph Seliga on
Posted in Investment Advisers Act, SEC News
On September 3, 2026, the US Securities and Exchange Commission (“SEC” or the “Commission”) proposed the rescission of Rule 206(4)-5 under the Investment Advisers Act of 1940 (the “Advisers Act”), widely known as the “pay-to-play” rule. The SEC will solicit comments on the proposal for 60 days following publication in the Federal Register.
Rule…