Back in 2010, the SEC adopted Rule 206(4)-5 (the “Pay to Play Rule”) under the Investment Advisers Act of 1940 to prohibit registered investment advisers from providing advisory services for compensation to a government client for two years after the RIA or certain of its executives or employees (“covered associates”) made a contribution to certain elected officials or candidates. The Rule also prohibits the RIA and its covered associates from, directly or indirectly, providing a payment to a third party for a solicitation of advisory business from any governmental entity on behalf of the adviser, unless that third party is a “regulated person.” The term “regulated persons” includes a registered investment adviser, broker-dealer or municipal adviser. The compliance date for the ban on paying a non-registered third party for soliciting a governmental entity had been postponed by the SEC on several occasions while final rules on municipal adviser registrations were complete. Those final rules have now been completed by the SEC.