On August 3, 2009, the Securities and Exchange Commission (SEC) published the full text of its proposed rule regarding “Political Contributions by Investment Advisers,” Investment Advisers Act Rule 206(4)-5.  Its intended purpose is to curtail so-called “pay to play” practices involving investment advisers.  The phrase “pay to play” refers to arrangements whereby investment advisers make political contributions or related payments to governmental officials in order to be rewarded with, or afforded the opportunity to compete for, contracts to manage the assets of public pension plans and other government accounts.  On July 22, 2009, the SEC unanimously voted to approve the proposed rule, which remains subject to a 60-day public comment period after its publication in the Federal Register.  We provide a detailed description of the proposed rule.