NVCA Represented by Proskauer Rose? Now that is Scary..

Proskauer Rose LLP has their Hands in just about everything .. well the things that are Worth Billions of Dollars that is.. see connections ot Venture Capital Billiosn puts Proskauer Rose Law Firm and Corrupt Proskauer Rose Patent Attorneys in Position to Steal Intellectual Property such as the Iviewit Technologies long before you ever even know about it...

"Guidance on New SEC Rules on Campaign Contributions, Placement Agents

NVCA issued two documents concerning recently adopted SEC rules on the use of placement agents, campaign contributions, and payments to public officials. There are a number of new and changed provisions which all venture capital firms should be aware of and factor into operations and hiring procedures.

These new provisions are far reaching and can affect activities such as firm hiring and staff promotion practices, encouraging others to make donations to political parties, using placement agents to raise future funds, family member contributions, and campaign contributions to candidates for federal office who are currently state officials.


The two documents, prepared for NVCA by Proskauer Rose, are:

SEC Rule 206(4)-5 and Amendments to Rules 204-2 and 206(4)-3 under the Investment Advisers Act of 1940 - There are a number of new provisions here regarding both placement agents and political contributions.

Placement Agents -- An outright ban on the use of placement agents, specified in an early draft of these rules, was dropped at the urging of NVCA and other interested parties. The final rules allow the use of placement agents subject to a number of specific conditions outlined in the rule.

Political Contributions - Generally, these restrictions focus on non-federal elections and candidates (as opposed to Federal elections for members of the US House and the US Senate).

As the guidance points out, contributions to NVCA's VenturePAC are permitted because its practices, current and past, comply with these new rules. The NVCA is advising all firms to review the rules carefully as there are many instances that could trigger a "two-year time out" from accepting public pension fund money.

Such instances include the promotion of employees to positions that are covered under the new ruling or inducing or encouraging others to make political contributions.

Model Campaign Contributions Policy to Comply with Revised Rules - We have provided a model policy template for venture firms to use as a starting point in creating and adopting a firm policy as well as creating documents for partner, staff, and new hire review and acceptance.

Please note that this model policy suggests reviewing practices from new staff screening to a firm or employee hosting a fundraising event, whether or not a cash contribution is made by that employee. Please note that state, local, and individual pension plan rules could add restrictions and sanctions on permitted activities. ..."

Source and Full Article
http://nvcaccess.nvca.org/index.php/topics/public-policy/129-guidance-on-new-sec-rules-on-campaign-contributions-placement-agents-.html


www.ProskauerSucks.com