There has been plenty of coverage of the SEC’s $294,894 penalty and disgorgement for a pay-to-play violation by a Philadelphia-area private equity firm that advised Philadelphia city and Pennsylvania state pension funds. The penalty appears draconian in comparison to the $4,500 in campaign contributions that generated it. But there is some data behind the story that could make the penalty seems less disproportionate and that makes the firm’s failure to implement adequate P2P compliance measures especially puzzling. The New York Times, Philadelphia Inquirer and other media disclosed that the donor was Robert E. Keith, Jr., a co-founder of the penalized firm, TL Ventures. Both pension funds had been investing in TL ventures funds for over a decade before the 2011 contributions at issue.
Source: Worse than it Looks? The Donor Data Behind the SEC's Big Pay-to-Play Penalty | Aristotle
