Month: July 2010

SEC’s new pay to play rules and notions of “solicit” and “bundling”

Still going through the Securities and Exchange Commission’s new pay to play rules?  A few random points.  On the rules’ notion of what constitutes a “solicitation,” the rules adopt a broad facts and circumstances test.   Footnote 328 discusses the definition and cites a Caplin & Drysdale comment letter.  On bundling, the rules don’t define the […]