Rule 206(4)‑5 of the Investment Advisers Act of 1940 - known as the pay to play rule – comes into focus in major election years. That is particularly true in the current election cycle in light of Kamala Harris’ selection of Minnesota Governor Tim Walz as her running mate, as contributions to her campaign by employees of investment advisers could be limited by the pay to play rule. With political activity gaining momentum heading into the upcoming election, the Private Equity Law Report interviewed Skadden partner Ki P. Hong to help fund managers identify and avoid pay to play compliance risks and other potential legal pitfalls. This article outlines relevant federal, state and local pay to play rules; examines key differences between those regimes; summarizes SEC enforcement activity targeting political contributions; and prescribes steps fund managers can take to ensure compliance. For additional commentary from Hong, see our two-part series: “Federal Pay to Play Rules” (Feb. 14, 2019); and “State and Local Pay to Play Rules; Traps for the Unwary; and Compliance” (Feb. 21, 2019).