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The purpose of this paper is to explain two recent actions by the US Securities and Exchange Commission (SEC), a “Settlement Order” and a National Examination Risk Alert, that highlight the importance of compliance controls with respect to political contributions and other political activities.

The paper explains Municipal Securities Rulemaking Board Rule G‐37, one of the earliest pay‐to‐play rules; the Settlement Order and how it addresses in‐kind campaign contributions, solicitation activities, and a municipal dealer's compliance failures; and the Risk Alert, including SEC staff observations and concerns based on examinations of the compliance programs of brokers and dealers engaged in the municipal securities business, practices the SEC staff has found problematic and in violation of Municipal Securities Rulemaking Board Rule G‐37, and certain practices firms have incorporated into their pay‐to‐play compliance programs.

The Settlement Order and Risk Alert provide an important reminder for investment advisers and municipal underwriters that are subject to pay‐to‐play restrictions, particularly highlighting issues relating to “in‐kind” contributions and solicitation activities, but also, beyond the municipal financing arena, may be of interest to investment advisers who have less guidance from the SEC on the application of Advisers Act Rule 206(4)‐5.

Because of the harsh consequences for not complying with the law, firms and their employees should be keenly aware of political activity that may cause violations of applicable pay‐to‐play restrictions.

The paper provides practical guidance from experienced financial services lawyers.

To explain and analyze the SEC’s January 17, 2017 announcement of settlements with ten investment advisory firms related to charges that those firms violated Rule 206(4)-5, known as the “Pay-to-Play Rule,” of the Investment Advisers Act of 1940.

Explains the Pay-to-Play Rule, its applicability to investment advisers, the de minimis and returned contribution exceptions, and the Rule violations cited by the SEC, and draws conclusions for the benefit of registered investment advisers and exempt reporting advisers.

The settlement included censures, civil money penalties, and recovery of compensation earned for firms’ failure to abide by the Rule, most often involving relatively small contributions by single covered individuals.

In light of these settlements, registered investment advisers and exempt reporting advisers may wish to review the adequacy of their policies and procedures with respect to the Pay-to-Play Rule and the effectiveness of their implementation.

Practical analysis and guidance from an experienced lawyer with a specialty in investment management.

To explain the first enforcement action the USA Securities and Exchange Commission (SEC) has brought under “pay to play” rules for investment advisers since those rules were adopted nearly four years ago.

First, the article provides a summary of the SEC enforcement action against TL Ventures Inc., a Philadelphia-area private equity firm. Next, the article provides a historical context and some key provisions of the rules. Finally, the article provides political contribution policy and procedure recommendations.

Political corruption in the municipal market has been a focus of the SEC for several years and is likely to continue to be a top priority. Investment advisers should ensure they have sufficient policies and procedures in place to avoid a two-year ban on business with a state or local government as the result of a political contribution.

The article provides the facts underlying the SEC’s enforcement action, the historical context of municipal market pay-to-play rules, a summary of the pay-to-play prohibitions, and recommendations for avoiding rule violations. The article would be of interest to investment advisers, public pension plans, municipal securities underwriters, brokers, and dealers as well as state and local governments.

The purpose of this study is a formal experimental economics test of results found in a study designed and executed by a 12-year-old who was concerned about what she perceived to be bias in gaming applications (apps) that provided male avatar characters for no cost but required in-app purchases to access female characters. The present study was designed to test empirically whether children have a revealed preference for same-gendered characters and whether such preferences are dependent on the cost of the characters.

Children from 6 to 16 years of age were recruited to participate in a framed field economics experiment in which they would earn actual money and be given opportunities to spend it on in-game avatars they could then use to continue to play. Additionally, a survey gathered data on participants’ stated preferences and experiences playing game apps on mobile phones.

Children do prefer to play a character of the same gender; however, they are more likely to remain the default character if choosing a different character costs money. When asked to say why they picked their character, children report most often that it is based on either the characters’ appearance or gender, followed by perceived character abilities, liking the character and the cost of a character. A vast majority (90 per cent) of children felt both male and female characters should be free.

This research was limited because the experiment simulated in-app purchases but could not offer the permanence of real-world in-app purchases. Players in the experiment could not “keep” the character if they chose to pay for it. The authors adjusted for this by making the cost to change character gender much lower than it would be in the game (25 cents in the study vs approximately $10 in the app). Future research could explore ways to make in-app purchases during the study permanent for players to test if the permanence of the purchase results in greater willingness to pay to switch character gender.

This research has practical implications for video game designers. As both male and female players prefer to play with characters of the same gender, and having a cost to play a character reduces switching behavior, it is possible that having a cost for female characters reduces the popularity of the game with female players. This is especially relevant for endless running games as these games are preferred more by women than men. By making female characters free, default character and developers may increase the popularity of these games with female players.

This study adds to the body of literature about gender and video game preferences because prior studies relied solely on stated preferences about characters (using surveys and self-reported behaviors) and not on revealed preferences (observed behaviors). Additionally, this study examines character gender preferences in a casual game, while most prior studies have examine preferences in massively multiplayer online role-playing games.

A rarely discussed type of indulgence good is “virtual” goods featured in freemium games, one of the most important platforms for online retailing. The freemium business model becomes popular amid the growth of mobile games and smartphones. The purpose of this research is to look into the factors that influence the intention to play freemium games and purchase in-game virtual goods, as well as to compare male and female millennial gamers in Indonesia, Southeast Asia's largest mobile gaming market. This research discusses the phenomenon in the context of compensatory consumption.

This quantitative research used an online questionnaire for data collections. A total of 275 millennial mobile gamers were selected via purposive sampling. In total, there are six factors incorporated in this research: utility, self-indulgence, social interaction, competition, the intention to play freemium games and the intention to pay for virtual goods. This research used structural equation modelling (SEM) via AMOS software to test the hypotheses.

This research reveals that (1) utility is a negative predictor of the intention to pay for virtual goods, (2) self-indulgence is a positive predictor of the intention to play freemium games, (3) there is a mediation effect of the intention to play freemium games on the relationship between self-indulgence and the intention to pay for virtual goods, (4) social interaction is a positive predictor of the intention to pay for virtual goods, (5) competition is a positive predictor of the intention to play freemium games, (6) there is a mediation effect of the intention to play freemium games on the relationship between competition and the intention to pay for virtual goods and (7) the intention to play freemium games is a positive predictor of the intention to pay for virtual goods.

This research has several limitations: first, half of the study’s millennial respondents were students whose gaming expenditures might depend on their parents or guardians' willingness to accommodate their gaming activities. Therefore, there might be some biases in the intention to pay for virtual goods. Second, the numbers of female respondents outweigh male respondents (44.4% males), hence the sample representativeness issue in a slightly male-dominated gaming industry in Indonesia. Third, the game genres the millennial respondents mostly played were the battle royale and the shooter games. Other game genres (e.g. puzzles) might involve a different mechanism. Lastly, the authors measured the compensatory consumption concept indirectly, such as by measuring variables associated with lack of time (utility), the need for virtual achievements or online recognitions (competition), mood-related issues (self-indulgence) and lack of belongingness (social interaction).

Game developers and online retailers (e.g. Google Play Store, Android App Store and Microsoft Store) should incorporate competition, indulgence and social interaction elements when designing and promoting freemium games. Based on the results of this research, a combination of these three elements improves the likelihood of purchasing virtual goods via online retail platforms

This is the first research to demonstrate a link between online retailing and compensatory consumption, particularly in the context of freemium games. This research extends the literature on online retailing in the context of freemium games, which has received little attention. In addition to theoretical support, this research provides new empirical evidence for previously unexplored and unsupported relationships.

The purpose of this paper is to explain the SEC staff's web site responses to a series of frequently asked questions concerning SEC Advisers Act Rule 206(4)‐5.

The paper explains the SEC staff responses to FAQs on the ability to rely on prior Municipal Securities Rulemaking Board interpretations regarding MSRB Rules G‐37 and G‐38, determining who is an “official of a government entity,” determining who is a “covered associate,” payments of commissions or other compensation to brokers or others, the Rules' application to political action committees (PACs), and “effective dates” and “compliance dates” under the related recordkeeping rule.

Pay‐to‐play is the practice of making campaign contributions and related payments to elected officials in order to influence the awarding of lucrative contracts for the management of public pension plan assets and similar government investment accounts. The staff's answers to the FAQs announce cautious positions, do not address some of the more difficult issues advisers may face on a day‐to‐day basis, and are subject to change.

The paper provides practical guidance from experienced financial services lawyers.

The purpose of this paper is to explain the SEC's proposed new rules under the Advisers Act that would prohibit making or receiving various types of payments and political contributions that could be construed as direct or indirect efforts to win investment advisory business from government entities.

The paper outlines the proposed rules, provides interpretive comments, and explains the background and motivation for the rules.

The proposed rules are aimed at over $2.2 trillion of assets in public pension plans. The SEC's action comes after a number of widely publicized pay‐to‐play scandals. However, some state systems have affirmatively decided not to ban placement agents, one of them affirming that placement agents can provide a useful service.

The paper provides practical interpretation and guidance from experienced employee benefits and executive compensation practice lawyers.

This paper aims to offer a comprehensive perspective into Free-to-Play gamers’ attitudes, feelings toward and perceived value of in-app purchases (IAPs).

The study is based on a twofold qualitative methodology using an inductive approach: user-generated YouTube videos and gamers’ online reviews posted on Play stores.

Eight topics have emerged out from the qualitative data related to the characteristics of a good/bad IAP, the IAPs as downsides, the ambiguity with traditional Pay-to-Play games, the financial-risk issues, the resistance behaviors, the worries about over-spending and addiction and the frustration mechanism.

By focusing on IAPs, this research contributes to build an integrative overview to better understand how players deal with IAPs and how this interaction should be analyzed in the light of multiple frameworks. Emphasis is placed on a continuum of player responses from tolerant metacognition to high degree of subversion.

A twofold netnographic approach offers a novel contribution to the field of mobile games by bringing together two materials increasingly connected to the video game universe. It also brought to the fore an experiential context by providing insight into the underlying dynamics of Player/IAP interactions.

The aim of this paper is to provide hedge fund and other private fund managers with a brief recap of regulatory changes in 2010 and a reminder of certain “best practices” they should consider as they prepare for 2011.

The paper provides 2010 regulatory highlights, including relevant provisions of the Dodd‐Frank Wall Street Reform and Consumer Protection Act, the Pay‐to‐Play Rule, and amendments to Form ADV. It outlines issues for consideration in 2011, including preparation for SEC registration (if applicable), review of compliance policies and procedures, updating Form ADV, Form D and Blue Sky Filings, “custody rule” (Rule 206(4)‐2 under the Advisers Act) compliance, other regulatory filings that may be required (including Form 13F, Schedule 13D/13G, and Forms 3, 4, and 5), CFTC regulatory requirements for investment managers who trade or advise others on trading commodity futures contracts, certain tax considerations (including foreign bank, brokerage and other financial account (FBAR) reporting requirements), the Foreign Tax Compliance Act of 2009 (FACTA)), ERISA and Department of Labor considerations, fee deferral arrangements, and offering document updates.

This summary is not intended to provide a complete list of an investment manager's obligations relating to its compliance with applicable rules and regulations or to serve as legal advice. It does not address any non‐US or state law requirements and has not been tailored to the specific needs of a particular investment manager's business.

This paper provides useful summary practical guidance from experienced financial institutions lawyers.

One of the most visible discussion points around international level, professional women's football in recent years has been that of gender equitable payment of players. This chapter presents some of the cornerstones of the equal pay debates at play in women's football. First, the emergence of international women's football as a major force in the global sport nexus is highlighted, which has enabled women to be paid to play football as a profession. Second, the historical roots of equal pay debates are presented, before turning to the most public and high-profile remuneration dispute in the sport of football, that of the USWNT versus the United States Soccer Federation (USSF). In this chapter, we outline how the drawn-out legal process has undoubtedly contributed to greater pay parity on the international stage for many professional women footballers and conclude the chapter by offering our thoughts as to the significance, and future, of gendered pay debates in football.