“The two-year timeout is intended to discourage pay-to-play practices in the investment of public money, including public pension funds,” said LeeAnn Ghazil Gaunt, Chief of the SEC Enforcement Division’s Public Finance Abuse Unit.  “Advisory firms must be mindful of the restrictions that can arise from campaign contributions made by their associates.” 

Without admitting or denying the findings, the 10 firms consented to the SEC’s orders finding they violated Section 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-5.  The firms are censured and must pay the following monetary penalties:

• * Adams Capital Management – $45,000
• * Aisling Capital – $70,456
• * Alta Communications – $35,000
• * Commonwealth Venture Management Corporation – $75,000
• * Cypress Advisors – $35,000
• * FFL Partners – $75,000
• * Lime Rock Management – $75,000
• * NGN Capital – $100,000
• * Pershing Square Capital Management – $75,000
• * The Banc Funds Company – $75,000