October 19, 2011
Practice Groups:
Investment
Management, Hedge
Funds and
Alternative
Investments
Broker-Dealer
Public Policy and
Law
Previously Proposed Amendments to
California Lobbyist Registration for
Placement Agents Adopted
By Cary J. Meer, David Mishel, Sonia R. Gioseffi
The proposed amendments to the California Political Reform Act and other sections of the California
Government Code in SB 398, which were discussed in our May 18, 2011 Client Alert, were signed
into law by Governor Brown on October 9, 2011. The amendments are effective immediately.
In summary, the amendments do the following:
 Revise the definitions of “external manager” and of “placement agent” and add a definition of
“investment fund” to clarify that routine trading transactions between broker-dealers and state
retirement systems are not subject to the provisions of the California Political Reform Act;
 Clarify that the competitive bidding exception to the definition of “placement agent” applies
during the competitive bidding process to all those competing, and not only to those selected; and
 Make the competitive bidding exception applicable to the requirements of local governments with
respect to local retirement plans.
Please click here to see our May 18, 2011 alert, “Update on Proposed Amendments to California
Lobbyist Registration Requirements for Placement Agents,” for a more detailed discussion of the
amendments.
Please contact any of the authors listed below if you have questions or need additional information
about the SB 398 amendments or the laws concerning lobbyists or other registration requirements for
placement agents and external managers.
Authors:
Cary J. Meer
cary.meer@klgates.com
+1.202.778.9107
David Mishel
david.mishel@klgates.com
+1.415.249.1015
Sonia R. Gioseffi
sonia.gioseffi@klgates.com
+1.415.882.8006
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