In January 2026, the SEC granted two exemptive requests made under Rule 206(4)-5 of the Investment Advisers Act (the "Pay-to-Play Rule") with respect to contributions that were made to the Harris / Walz campaign. The two advisers requested exemption from the two-year prohibition under the rule from receiving compensation following a contribution to a covered official for a government entity client. Contributions were made by the Managing Partner for one firm in the amount of $1,000 and by the Global Head of Investment Research for the other firm in the amount of $2,000, while their respective firms managed money on behalf of Minnesota government entity clients for which the MN Governor was a covered official. Neither contributor realized or was attentive to the fact that their contribution exceeded the $350 de minimis limit in the Pay-to-Play Rule, until they were reminded of these provisions in subsequent compliance training. In each instance upon discovery and at the request of the Compliance Team, the contributor requested and received a refund, and the adviser took steps to minimize contact with the government entity client and return and/or escrow fees until exemptive relief was obtained. The SEC concluded in each case that the proposed exemption was appropriate in the public interest and consistent with the investor protection and other purposes of the Investment Advisers Act when establishing the Pay-to-Play rule. Accordingly, each adviser was exempted from the two-year prohibition on compensation under the rule. See True Venture Management, L.L.C. and Parametric Portfolio Associates LLC