Rule 206(4)‑5 under the Investment Advisers Act of 1940, known as the pay to play rule (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 recently settled enforcement actions against four advisers for alleged violations of the Rule. 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 Rule’s fundamentals. This article details the facts giving rise to the enforcement actions, the terms of the settlements and Peirce’s dissent. See “Use a Preclearance Checklist to Avoid Violating the Pay to Play Rule” (Nov. 1, 2022); and “With Midterm Elections Looming, Fund Managers Must Review the Pay to Play Rule” (Sep. 20, 2018).