How to Maintain Pay-to-Play Compliance

Addressing political contribution risk during a midterm election year

Across party lines, we are seeing both the monetary value and physical number of
contributions continue to increase, even in “off years,” which have historically seen significant drop-offs.

Simply put, this level of activity has created increased risk to firms who rely on government contracted work.

To continue to comply with federal, state and local regulations, firms must take a proactive approach to their pay-to-play compliance program. During this session, experts will share their insight regarding:

  • The complex array of federal, state and local regulations at play.
  • The heightened political contribution risk firms face, specifically during a midterm election year.
  • The potential “hidden risks” that could result in serious enforcement action.
  • How firms can address and mitigate risk.
  • The role of technology plays in proactively preventing purposeful or accidental pay-to-play compliance violations.

Please fill out the form below to access the recording & the “Ultimate Pay-to-Play” guide!


Tori Patton

Tori Patton


Senior Customer Success Manager

Tori Patton is a Customer Success Manager at ComplySci with years of experience working with customers in the financial services industry around pay to play compliance solutions. Tori came to ComplySci from illumis, where she was responsible for many different pieces of business—from operations and finance, to building out research reports around pay-to-play risk, to assisting and supporting all illumis customers. Tori specializes in Customer Success and is passionate about educating customers on ComplySci’s platforms (including illumis!) and ensuring that they are getting the most possible value out of the technology. She loves the trickiness of political contribution compliance, and enjoys helping solves customers problems. She currently leads the Customer Success at Scale team at ComplySci.

Heather L. Traeger

Heather L. Traeger

Teacher Retirement System of Texas

Chief Compliance Officer and General Counsel

Heather L. Traeger serves as the Chief Compliance Officer and Compliance Counsel for the Teacher Retirement System of Texas -- one of the largest public pension plans in the country with 1.7 million members and retirees and $200 billion in trust assets.
Prior to joining TRS, she was a partner in the Financial Services Practice at O’Melveny & Myers LLP; served as Associate Counsel at the Investment Company Institute; and worked for the U.S. Securities and Exchange Commission as Counsel to two Commissioners and Senior Counsel in the Division of Market Regulation.

Tyler Rosen

Tyler Rosen



Tyler Rosen advises clients on government affairs compliance matters at the federal, state and local levels, including in the areas of pay-to-play, campaign finance, lobbying, gifts and entertainment, and conflicts of interest. He also advises on the placement agent rules and policies of state and local public pension systems. Mr. Rosen has assisted many clients from a range of industries, with a particular focus in the financial services and real estate sectors, in developing comprehensive policies for complying with these laws and rules. He advises clients on the implementation and application of these policies and on the many issues that arise in these areas, including under SEC Rule 206(4)-5, MSRB Rule G-37, CFTC Rule 23.451 and FINRA Rule 2030. He has represented several clients in successfully obtaining exemptive orders from the SEC under Rule 206(4)-5 and from FINRA under Rule G-37. At the state level, he has represented clients in successfully obtaining exemptions from the New Jersey State Investment Council’s policy on political contributions as well as from Conn. Gen. Stat. § 9-612 (the Connecticut pay-to-play law) involving the Connecticut State Elections Enforcement Commission.

Lisa Tolar

Lisa Tolar

RIA in a Box

Enterprise Chief Compliance Officer

Prior to joining RIA in a Box, Lisa was a State of Alabama regulator. She spent 26 years with the Alabama Securities Commission, the last 17 years of which she served as Securities Registration Manager overseeing the licensing and registration of investment advisers, broker dealers, securities registrations and exemptions, and money transmitters. Prior to managing, as a Securities Analyst, she conducted desk reviews for registration/exemption and licensing and conducted routine and for cause field audits, including sweeps coordinated with other state regulators, FINRA and SEC. She served on various NASAA project groups during her tenure with the Commission. Lisa graduated from Auburn University at Montgomery with a BSBA (Finance emphasis) and MBA. She currently holds a Certified Fraud Examiner (CFE) designation.