Proposed Rescission of the SEC Pay-to-Play Rule: Analysis and Commenting Opportunities Registration
On September 10, 2026, the SEC published in the Federal Register a proposed rescission of Rule 206(4)-5 — the “pay-to-play” rule — along with related record-keeping requirements, officially opening a public comment period that runs through November 9. If adopted, the rescission would mark a sweeping change for investment advisers and the broader financial services industry.
We will examine the key implications of the proposal and the path ahead.
Topics will include:
– Critical issues raised by the SEC's Notice of Proposed Rulemaking.
– Areas in which the SEC is specifically seeking public comment.
– The future of other federal pay-to-play rules and the evolving regulatory landscape.
This webinar will be of particular interest to investment advisers, broker-dealers, municipal advisors, swap dealers and security-based swap dealers.
- October 26, 2026
- 1:00 PM
- 2:30 PM
- 1.5
- 1.5
- Virtual Participation
- Ki P. Hong, Esq., Speaker, Skadden Arps Slate Meagher & Flom, LLP
- Charles Ricciardelli, Esq., Speaker, Skadden Arps Slate Meagher & Flom, LLP
- Tyler Rosen, Esq., Speaker, Skadden, Arps, Slate, Meagher & Flom LLP
- Sam Rothbloom, Esq., Speaker, Skadden, Arps, Slate, Meagher & Flom LLP
- Webinar
- 0RF71
- Business Law Section
- Private Investment Funds Committee
- Securities Regulation Committee
- Committee on Continuing Legal Education

