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--> The 2026 Election Season Is a Minefield of Pay-to-Play Risks for Investment Advisers | WilmerHale - JDSupra Menu News & Insights Popular Labor & Employment Finance & Banking Intellectual Property Health & Healthcare Environmental Issues more… Business Insurance Commercial Real Estate Corporate Taxes Immigration Securities more… Personal Residential Real Estate Estate Planning Civil Rights Personal Taxes Bankruptcy more… Jump to: Latest Updates » Trending [ 7 ] [Survey] What do GC want from law firm guidance? Your input matters... [Hot Topic] Artificial Intelligence [Hot Topic] Employer Liability Issues Latest IMMIGRATION News & Updates Stay Informed: Popular Reads on JD Supra Meet JD Supra's Top Authors! Build a Morning News Digest: Easy, Custom Content, Free! Browse All Law News Topics » Find Author By Business Matters Labor & Employment Finance & Banking Intellectual Property Insurance Taxes See All Subjects » --> By Personal Issues Civil Rights Family Matters Personal Injury Wills, Trusts, & Estate Planning Worker’s Compensation See All Subjects » --> By Location California New York Texas Canada United Kingdom See All Locations » --> Subscribe Custom Email Digests Build a custom email digest by following topics, people, and firms published on JD Supra. X (formerly Twitter) RSS Feeds for Publishers For Reporters My Account Log In May 20, 2026 The 2026 Election Season Is a Minefield of Pay-to-Play Risks for Investment Advisers Thomas Bredar , Molly Collett , Io Jones , Benjamin Neaderland WilmerHale + Follow x Following x Following - Unfollow Contact LinkedIn Facebook X Send Embed To embed, copy and paste the code into your website or blog: US Securities and Exchange Commission (SEC) Chairman Paul Atkins made news in March when he told an audience of securities industry professionals that change was on the way for Investment Advisers Act Rule 206(4)-5 (the Pay-to-Play Rule or the Rule). Atkins labeled the Rule “a trap for the unwary” and said that the SEC would address rule changes in 2026. 1 While the nature and extent of regulatory changes the SEC may make to the Rule this year remain unclear, the existing Rule—together with myriad state- and local-level regulations—can impose draconian penalties on investment advisers based on particular types of political contributions. This presents a heightened risk for investment advisers and their personnel in 2026 as dozens of current elected officials at the federal, state and local levels are running for a new office in the November election. As many advisers are well aware, contributions to federal officials and candidates are typically not covered by the Pay-to-Play Rule. However, the Rule can apply to contributions to campaigns for federal office by current state or local officials, as well as contributions to campaigns for state or local office by current federal officials. Moreover, numerous state and local juris

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