Charles E. Borden, Samuel C. Brown, and Claire N. Rajan write for The Investment Lawyer. It begins:

Although Election Day is more than a year away, the 2016 election cycle has begun in earnest, with Presidential aspirants and elected officials jockeying for position and dominating media coverage. Candidates and potential candidates already are raising historic sums for an increasingly varied set of fundraising vehicles and non-profi t entities, and many individuals in the fi nancial services sector are regularly being solicited to make political contributions.1 Th ese developments have the potential to create heightened pay-to-play risk for investment advisers. More than any other election cycle since the Securities and Exchange Commission (SEC) pay-to-play rule for investment advisers (Rule 206(4)-5 or the Rule) became effective in 2011, the 2016 elections are likely to pose significant compliance challenges for investment advisers subject to the Rule.