Jason Abel and his colleagues at Steptoe flag that selecting a sitting Governor as a running mate implicates critical pay-to-pay rules. In this helpful brief, the authors lay out three sources of pay-to-play rules that now constrain the Harris campaign’s fundraising efforts, especially from the financial services sector:

• Securities and Exchange Commission Rule 206(4)-5 for investment advisers
• Municipal Securities Rulemaking Board Rule G-37 for municipal securities dealers and municipal advisors
• Commodity Futures Trading Commission Rule 23.451 for swap dealers