1. 115 For a good summary of the details of the new Rule, see Summary of the SEC's Pay-To-Play Rule;Curtis C Verschoor;We Need to Stop Pay-to-Play Corruption, STRATEGIC FIN,2009
2. Lobbying, Rent-Seeking, and the Constitution, 64 STAN;Richard L Hasen;L. REV,2012
3. Following the SEC's lead, the Commodity Futures Trading Commission (CFTC) issued its own pay-to-play rules in 2012 imposing business conduct standards (BCS) on swap dealers (SDs) and major swap participants (MSPs). See Business Conduct Standards for Swap Dealers and Major Swap Participants With Counterparties;Fed. Reg,2012