Exemptive Relief Granted Under the Political Contributions Rule After Clearing Significant Procedural Hurdles

In a positive sign for investment advisers, the Securities and Exchange Commission (“SEC”) recently approved an application for exemptive relief pursuant to rule 206(4)-5 (“Political Contributions Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) allowing an investment adviser to retain the full $37 million of fees at issue following a Political Contribution Rule violation by a covered employee, indicating the SEC’s willingness to consider exemptive relief even in cases involving potentially large disgorgements.