SEC Rule 206(4)-5 outlines the requirements to prevent registered investment advisers from making or soliciting political contributions to influence government officials’ awards of advisory contracts (“pay-to-play” practices.) The purpose of the rule is to ensure that the high standards and integrity of the municipal industry are maintained, to prevent fraudulent and manipulative acts and practices.
The firm does not encourage its supervised persons to contribute to political campaigns and does not officially endorse any elected officials or candidates. However, supervised persons are permitted to make contributions to an elected official(s) or candidate(s) of their own choosing. Prior to making a political contribution to an elected official or candidate, all supervised persons must obtain the firm’s approval by submitting this form to the Chief Compliance Officer.
A contribution is defined as “any gift, subscription, loan, advance, deposit of money, or anything of value made for the purpose of influencing an election for a federal, state or local office, including any payments for debts incurred in such an election.” Supervised persons of the firm may not make political contributions without first obtaining prior approval.