Alert December 04, 2012

CFTC Amends No-Action Letter on “Pay-to-Play” Rules

The CFTC amended its no-action letter on “pay-to-play” rules (the original release of which was reported in the November ­­27, 2012 Financial Services Alert).  The amendment inserts a clause to clarify that the scope of relief provided in the letter extends only to dealings with governmental plans that are not otherwise covered by the pay-to-play rules of the SEC and/or Municipal Securities Rulemaking Board.