What the SEC’s Proposed Rescission of its Pay-to-Play Rule Means for Compliance

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What the SEC’s Proposed Rescission of its Pay-to-Play Rule Means for Compliance

October 14, 2026

United States
United States
United States
Dow Jones Risk Journal

The SEC’s proposed rescission of its longstanding “pay-to-play” rule could fundamentally change how investment advisers approach compliance around political contributions, shifting from bright-line requirements toward a principles-based framework that puts greater weight on compliance judgment.

Partner Michael Koffler and Senior Counsel William Nelson examine what that change could mean in practice and the steps advisers should consider as they review their policies governing political contributions, government relationships and third-party solicitors.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. Eversheds Sutherland is a provider of legal and other services operating through various separate and distinct legal entities. For further information about these entities and Eversheds Sutherlands' structure please see the Legal Notice page of this website.

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Key contacts

michaelkoffler@eversheds-sutherland.com

Michael B. Koffler

Partner

New York, United States

williamnelson@eversheds-sutherland.com

William Nelson

Senior Counsel

Washington, DC, United States

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