The SEC charged Obra Capital Management, LLC for violating the SEC's Pay-to-Play Rule 206(4)-5 under the Investment Advisers Act. The firm consented to a $95,000 penalty. The SEC found that the firm violated the rule by continuing to provide investment advisory services for compensation from a government entity following a campaign contribution made to an elected official with influence over selecting investment advisers for the government entity. The contribution was made by an individual who was not employed by the adviser at the time of the contribution but later hired and deemed to be a covered associate. The case is a clear example of the SEC bringing an enforcement action based on a technical violation of the Pay-to-Play Rule without any indication that the contribution in question did or could have unduly influenced the decision of a government entity investor to invest in the fund.