ACA Program Reviews State and Local Pay to Play Rules; Traps for the Unwary; and Compliance (Part Two of Two)

A recent ACA Compliance Group (ACA) program provided a comprehensive overview of the panoply of federal, state and local pay to play rules with which fund managers must contend. The program featured Ki P. Hong, partner at Skadden, and Elaine Vincent, consultant at ACA. This second article in our two-part series discusses state and local pay to play rules; traps for the unwary; and compliance policies and procedures. The first article summarized the four federal pay to play rules. For additional commentary from ACA, see “ACA Panel Reviews Effects of Impending MiFID II on U.S. Advisers” (Dec. 7, 2017); and “How Private Fund Managers Can Avoid Common Pitfalls When Calculating and Advertising Internal Rates of Return” (Sep. 7, 2017).

To read the full article

Continue reading your article with a HFLR subscription.