The SEC continues to focus on political contributions by investment advisers seeking to secure government pension investments. It recently charged 10 advisers with violating Rule 206(4)-5 under the Investment Advisers Act of 1940 (Advisers Act) – the so-called “pay to play rule” (Rule). This Rule makes it unlawful for an investment adviser to provide for compensation investment advice to public pension funds for two years after covered employees of that investment adviser contribute to the campaign of officials that can influence the selection of investment advisers by those funds. See “The SEC’s Pay to Play Rule Is Here to Stay: Tips for Hedge Fund Managers to Avoid Liability” (Oct. 8, 2015). This article summarizes the key terms of the settlements and their lessons for private fund advisers. All fund managers should pay heed to these settlements, as they illustrate the SEC’s aggressive pursuit of pay to play violations, including the regulator’s enforcement of minor violations of – and broad interpretation of definitions under – the Rule. See “BakerHostetler Panel Analyzes Shifts in Enforcement Policies and Tactics As Industry Anticipates New Administration and SEC Chair (Part One of Two)” (Jan. 5, 2017); “SEC Starts Year With Pay to Play Penalties” (Jan. 28, 2016); and “Four Pay to Play Traps for Hedge Fund Managers, and How to Avoid Them” (Feb. 5, 2015).