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.

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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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