State and Local Pay-to-Play and Public Records Laws


Many investment managers routinely seek business from public pension plans and other government instrumentalities.  But how many of them are aware of all of the local laws and regulations that affect the solicitation of business from such governmental entities or the fact that certain information submitted to them, either in connection with the procurement process or on an ongoing basis, may be publicly disclosed?

This program will discuss these relevant laws and regulations, including:

•           Potential lobbyist registration requirements

•           State and local pay-to-play rules (and will compare and contrast them with the SEC pay-to-play rule, Advisers Act Rule 206(4)-5)

•           Restrictions on use of placement agents and/or payment of contingent compensation

•           Restrictions on gifts and entertainment and political contributions

•           Public records law considerations


Diane E. Ambler and Cary J. Meer are partners in, and Ruth E. Delaney is an associate in, the investment management practice group of K&L Gates LLP. Diane, who is located in the Washington, DC office, represents diversified financial institutions sponsoring mutual funds and other retail and institutional investment products on regulatory compliance and related matters. Cary, who is located in the Washington, DC and New York offices, and Ruth, who is located in the Los Angeles office, represent advisers to private funds in all of their structuring, formation and compliance matters. All three lawyers also were instrumental in creating the K&L Gates’ database that tracks laws relating to the solicitation of business for private funds and routinely advise clients on these laws and regulations.

Eric J. Smith is the Managing Director andDeputy General Counsel of PineBridge Investments. He heads a five-person legal team responsible for the firm’s private equity and alternative investments businesses that are managed from the Americas (approximately $10.7 billion in AUM). He also works closely with legal colleagues in Europe, the Middle East and Asia on cross-border strategies and to provide support for regional alternative investment initiatives.

Please note this is a manager only event.

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