Statement on the State of New Jersey Policy Concerning Political Contributions and Prohibitions on Investment Management Business May 15, 2014 Recent press coverage has raised unfounded concerns about an investment by a New Jersey pension fund in General Catalyst Fund VI due to a political contribution made by Charlie Baker. These concerns and questions are without merit. To be clear, General Catalyst did not “pay to play” or violate the law. Concerns have also been raised about the extent to which Mr. Baker’s political contribution to the New Jersey Republican State Committee is addressed by New Jersey rules regarding political contributions and prohibitions on investment management business, including the rules applicable to the State Investment Council, as codified in the New Jersey Administrative Code, Title 17, Section 16. The investment by the New Jersey pension fund in General Catalyst Fund VI was not prohibited by the New Jersey Administrative Code. Among other things, and as it relates to Mr. Baker’s political contribution, Title 17, Section 16-4.3(a) of the New Jersey Administrative Code restricts an investment if, within the past two years prior to such engagement, any political contribution has been made by the following: 1.
The investment management firm, its parent company, or any other person or entity that controls the investment management firm; 2.
Any investment management professional associated with such investment management firm; 3.
Any third party solicitor associated with such investment management firm; or 4.
Any political action committee controlled by the investment management firm, its parent company, or any other entity that controls the investment management firm, or by an investment management professional of such investment management firm or controlling entity. Mr. Baker, in his capacity as XIR at General Catalyst, does not fall into any of these four criteria. Importantly, Mr. Baker was not an “investment management professional” under these rules. Title 17, Section 16-4.2 of the New Jersey Administrative Code defines "Investment management professional" as the following: 1.
Any person associated with an investment management firm who is primarily engaged in the provision of investment management services; 2.
Any person associated with an investment management firm involved in client development or the solicitation of business from pension fund clients, including pension fund clients that are not State Pension and Annuity Fund clients; 3.
Any person associated with an investment management firm who is a supervisor of any person described in 1 or 2 above, up through and including the Chief Executive Officer or similarly situated official; or