Proposed Rules to Change to Political Contributions by Certain Investment Advisers

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed rules which are intended to eliminate pay-to-play practices from the selection of investment advisors by the government entities,  Proposed Rule 206(4)-5. SIFMA supports efforts to preserve a well functioning market, however, we are concerned that the proposed rule sweeps too broadly and fails focus on key issues relating to compliance.  Four principle areas of concern are addressed. SIFMA believes a collaborative approach between the SEC and regulated parties will be capable of producing effective methods to prevent distortions caused by pay-to-play.