Over the last several years, there has been a trend toward the enactment of general pay-to-play laws and tighter lobbying, campaign finance and ethics laws by many states and localities. More recently, this trend has included the very specific application of lobbying laws and pay-to-play laws to investment managers. These laws regulate the government interactions and political contributions of investment advisors, placement agents and other participants in the pension fund management business.
This bulletin focuses attention on the development of the state and local laws. These laws impact certain pension fund management business participants as lobbyists, who are subject to specific registration, reporting and other requirements, and/or prohibit or limit campaign contributions from these participants through pay-to-play laws. The growing implementation of these types of laws at the state and municipal level require participants in the pension fund management business to carefully track, understand and comply with these new requirements. This bulletin discusses, as a sampling, such laws in New York City, California, the City of Los Angeles and Pennsylvania.