Rule 206(4)‑5 under the Investment Advisers Act of 1940, known as the Pay to Play Rule, establishes what amounts to a strict liability regime. An adviser whose covered associate makes a political contribution to someone with the ability to influence a government entity’s choice of adviser is barred for two years from receiving advisory fees from that entity – regardless of intent and whether a quid pro quo was involved. The SEC settled four enforcement actions for alleged violations in which a covered associate made a political contribution to an official of either a state university or a public pension plan that already invested with the applicable respondent. In each case, the respondent continued to provide advisory services for compensation to the university or pension plan during the two-year period after the contribution. The settlements prompted a strong dissent from Commissioner Hester M. Peirce, who saw little benefit from the settlements and urged the SEC to revisit the fundamentals of the Pay to Play Rule. The article details the facts giving rise to the enforcement actions, the terms of the settlements and Peirce’s dissent. See “SEC’s Latest Enforcement Results and Budget Request Affirm Focus on Fraud” (Jun. 11, 2026); and “2026 Securities Enforcement Forum Panel Discusses Current Enforcement Climate” (May 14, 2026).