September 25, 2009
i represent an investment advisory firm that does not use third party marketing agents. nevertheless, they provide a valuable service to the investment management industry and outlawing their services is 'throwing the baby out with the bath water'
why not simply create a new regualtion that any investment manager who makes a donation to an official afilliated with a public pension fund or related entity is prohibited from doing business with that fund for a period of ___ years (say 3 years??). this policy would in no way restrict an individual's right to make a donation, but it certainly will carry consequences for those who do.