Investment Management Regulatory Update
A Summary of Current Investment Management Regulatory Developments

Created date


Pay-to-play arrangements involving payments to intermediaries to influence public pension fund investment decisions have recently come to the fore on a number of fronts: 

  • New York State Attorney General Andrew M. Cuomo's Office has recently announced an expansion of a two-year investigation in the pay-to-play schemes involving New York State and City pension funds as well as a settlement agreement with The Carlyle Group ("Carlyle") pursuant to which Carlyle agreed to pay $20 million to the State of New York and adopt Cuomo's Public Pension Fund Reform Code of Conduct (the "Code of Conduct"). 
  • SEC Chairman Mary L. Schapiro has asked the SEC staff to revisit a rule first proposed in 1999, but never finalized, that would curtail political contributions by investment advisers. 
  • The SEC recently charged a Los Angeles placement agent in connection with a New York State pension fund corruption investigation. 
  • In response to these developments, the California Public Employees' Retirement System ("CalPERS"), the nation's largest public pension fund, recently instituted a new placement agent policy mandating the disclosure and registration of intermediaries hired by external managers of CalPERS' funds. 
Related Professionals
Related Practices