Examples of Covered Associate in a sentence
Contributions by a Covered Associate made to any elected official who, within two years of the contribution, is in a position to influence the retention or has legal authority to retain WCM, will result in the firm’s prohibition in receiving any adviser fees from that government entity for a period of two years.
If and only if a contribution does not present a conflict of interest or harm WCM’s ability to obtain clients will the Covered Associate be allowed to make such a contribution.
The Advisers must look-back in time to determine whether a Covered Associate has made a triggering prohibited contribution within the previous two years for new Covered Associates who solicit clients, and six months for new Covered Associates who do not solicit clients.
The SEC pay-to-play contribution restrictions specifically apply to employees of an investment adviser that are deemed to be a Covered Associate.
No Covered Associate shall, directly or indirectly, make any contribution (which includes any gift, payment, loan, advance or anything of value) to, or for the benefit of or at the request of, any “public official” (which term also includes any candidate for public office), or political party, or coordinate, or solicit any person (including any family member or political party) to make any payment to a public official, or political party without the prior review and written approval of the CCO.