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Compliance Considerations for Political Contributions in an Election Year

October 27, 2020
10:45 AM - 12:00 PM CDT
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Course Description:

With what promises to be a chaotic election season ahead, firms need to be certain that their political contributions policies, procedures, and records are buttoned up and thoroughly tested. This session will explain the many moving parts of the political contributions rule and provide real-world guidance on the steps you need to take to be sure your firm is in compliance.

Learning Objectives

After attending this session, attendees should be able to:

  • Analyze your firm’s client base and marketing plans to determine whether you are subject to the pay-to-play rules
  • Develop a comprehensive set of policies, procedures and attestations
  • Explore internal and external sources to use in testing your political contributions program

This virtual course is being taught as part of the Fall 2020 Compliance Conference. To learn more, visit our main conference webpage.

Karen Aavik
Karen Aavik
Chief Compliance Officer, Stratos Wealth Partners


Karen Aavik is the Chief Compliance Officer of Stratos Wealth Partners; she is also a member of Stratos’ Executive Committee. As CCO, Karen oversees all brokerage and advisory compliance matters for Stratos, focusing on ensuring that its advisers, partners, and staff operate in accordance with SEC and FINRA rules and requirements.

Prior to that she served as an Enterprise Risk Officer at Wells Fargo and Compliance Executive with KeyBank, N.A., where she led a compliance team that provided support for, and oversight of, numerous bank- and investment-side lines of business, functions and disciplines across the organization.

She was the Wealth Management Compliance Officer, the Ethics Officer and the Privacy Officer for First Niagara Financial Group, and an Assistant General Counsel in the First Niagara Legal Department. .

Ms. Aavik holds a J.D., LL.M. with Honors and M.B.A. from the State University of New York at Buffalo and is a member of the New York State Bar. She has the CCEP, CFE, CAMS, and NRS IACCP designations; earned the CIPP/US, CIPP/E, CIPT, and CIPM privacy credentials; and is FINRA Series 4, 7, 24, 53, and 63 licensed.

Ms. Aavik has contributed to articles regarding cybersecurity requirements within the investment industry and authored the “Compliance in a Bank Investment Program Environment” chapter for Modern Compliance: Best Practices for Securities & Finance (Vol. 2). She was featured in the January 2018 edition of Compliance & Ethics Professional Magazine, and currently serves as an Editorial Board Member for the Journal of Financial Compliance.


Sean Kreiger
Sean Kreiger
Chief Compliance OfficerJackson Square Partners, LLC


Sean Kreiger joined Jackson Square in August 2015 as Chief Compliance Officer. Sean started his professional career as an attorney with the Division of Enforcement of the U.S. Securities and Exchange Commission (SEC) followed by several years in private practice in the New York office of the law firm of K&L Gates.

He then used this background to transition his career into a variety of legal and compliance roles in the asset management industry. This experience included roles at a multi-strategy hedge fund manager and AIG Investments in New York followed by Babson Capital Management in Boston.

Prior to joining Jackson Square, Sean spent the prior three years as General Counsel and Chief Compliance Officer of DCI, LLC in San Francisco.


Kelley A. Howes
Kelley Howes
Of Counsel / Vice Chair of Investment Management PracticeMorrison & Foerster LLP


Kelley Howes serves as vice chair of Morrison & Foerster’s Investment Management Group.

Ms. Howes has experience with a wide range of legal, regulatory, compliance, corporate governance, insurance, and other matters relating primarily to the representation of U.S. registered and unregistered investment companies, offshore funds, registered investment advisers, transfer agents, and broker-dealers.
Ms. Howes has counseled independent fund directors on governance issues, and has advised mutual funds on mergers, reorganizations, compliance, and regulatory matters, including examinations and enforcement matters. She has also advised public companies with regard to corporate governance and various corporate transactional matters, including mergers and acquisitions, subsidiary ownership issues, and equity and debt issuances.

Ms. Howes has more than 20 years’ experience in investment management- related matters. Prior to joining Morrison & Foerster, she served as Executive Vice President and General Counsel of Janus Capital Group Inc., a NYSE-listed global asset management holding company. She also previously served as Senior Vice President and General Counsel of Janus Capital Management LLC, a U.S. registered investment advisory subsidiary of Janus Capital Group, and as President of the Janus funds and President of Janus Distributors LLC.

Ms. Howes has served on the boards of directors of Young Americans Bank/Young Americans Center for Financial Education; ICI Mutual Insurance Company; and the Denver Metro Chamber of Commerce.

During her time at Suffolk University School of Law, Ms. Howes was a member of the Suffolk Transnational Law Review.

Ms. Howes is a member of the Colorado and New York bars.


For Whom: Designed to increase the professional competence of Investment Advisers.

Suggested Skill Level: Intermediate

Maximum Recommended Credit Hours for this session will include CLE, IACCP® and CPE.

CA MCLE = 75 minutes
IACCP® = 75 minutes
CPE = 75 minutes

For more information, check out the NRS Continuing Education Guide.