The SEC has proposed to rescind Rule 206(4)-5, the Investment Advisers Act's Pay-to-Play Rule, after concluding that its strict liability framework created disproportionate consequences relative to the rule's anti-corruption goals. This is a significant development for investment advisers and private fund managers. If adopted, the rescission would eliminate the two-year compensation ban and related recordkeeping requirements, leaving existing antifraud, fiduciary duty, and compliance obligations in place. The proposal is open for public comment for at least 60 days. We will continue to monitor this proposal and will update you on further developments. Please see the attached summary for more detail.