The U.S. Securities and Exchange Commission has proposed rescinding its investment adviser pay-to-play rule in full, including the two-year ban on receiving compensation from a government client after certain political contributions. The proposal would also remove associated restrictions on solicitation and coordination and eliminate corresponding recordkeeping requirements for registered investment advisers. The SEC concluded that the rule is overly prescriptive, operationally difficult and prone to disproportionate consequences for small donations, hiring decisions and political activity. Advisers would instead address pay-to-play risks through existing antifraud and fiduciary obligations and, where applicable, tailored compliance policies, procedures and codes of ethics. Federal, state and local anti-corruption and political contribution requirements would remain unaffected. The SEC estimates annual monetized benefits of about USD 416.3 million, primarily from lower compliance costs, against initial costs of about USD 51 million for modifying policies and procedures. The proposal is open for public comment.
2026-09-04U.S. Securities & Exchange Commission
U.S. Securities and Exchange Commission proposes rescinding investment adviser pay-to-play rule and related recordkeeping requirements
The U.S. Securities and Exchange Commission has proposed fully rescinding its investment adviser pay-to-play rule and related recordkeeping requirements. Advisers would instead manage pay-to-play risks under existing antifraud, fiduciary, compliance and ethics obligations. The SEC estimates annual monetized benefits of about USD 416.3 million.