The proposed rescission of Rule 206(4)-5 (the Pay-to-Play Rule) under the Investment Advisers Act of 1940 (the Advisers Act) by the Securities and Exchange Commission (the SEC) has generally been celebrated by industry participants and observers. However, the relief may not be as momentous as many are expecting and it’s possible that very little will change for certain types of investment advisers, particularly advisers with multiple U.S. state or local government clients or investors in their private funds or other pooled investment vehicles.