The SEC continues its aggressive pursuit of pay to play violations. It recently issued settlement orders against three investment advisers for violations of Rule 206(4)‑5 under the Investment Advisers Act of 1940 – the so-called “pay to play rule” (Rule). The Rule makes it unlawful for an adviser to provide investment advice for compensation to a government entity – including a pension fund – for two years after a covered associate of the adviser makes a contribution to an official of the government entity. This article details the relevant provisions of the Rule, the terms of the settlements and the SEC waiver granted to the parent of one of the affected advisers – a public issuer that could have been rendered ineligible for “well-known seasoned issuer” status under Rule 405 of the Securities Act of 1933. See “Pay to Play, Revenue Sharing and Wrap Fees Remain on the SEC’s Radar” (Apr. 20, 2017).