Campaign Donation Clouds Oklahoma Investment Advisory Award, Firm Withdraws from Bid
Why It Matters
Oklahoma’s Invest in Oklahoma program — designed to direct a portion of the state’s $45 billion in pension, trust, and endowment assets into Oklahoma-based private equity and venture capital funds — has been thrown into further uncertainty after the firm selected to manage those investments withdrew from the process. The development raises questions about the integrity of state contract awards and the application of federal securities regulations to Oklahoma officials.
What Happened
311 Capital Management LLC notified the five-member Invest in Oklahoma board in a letter that it could no longer pursue the investment advisory contract it had been awarded. The firm’s withdrawal followed scrutiny of a $2,500 campaign contribution made in February 2025 by Bond Payne — owner of Citizen Capital LLC, the parent company of 311 Capital — to Oklahoma Treasurer Todd Russ.
Federal securities regulations, commonly known as the “pay-to-play” rule, bar investment firms from receiving compensation under state pension advisory contracts when an employee or affiliated individual has donated to an elected official who holds influence over the awarding process. The rule carries a two-year lockout period on compensation.
The Invest in Oklahoma board had voted on February 17 to award the advisory contract to 311 Capital, passing over two competing bidders. Russ, whose office administered the bidding process, had recommended 311 Capital for the award. The campaign contribution became a focal point just days before the firm’s withdrawal letter was submitted.
By the Numbers
- $45 billion — Total value of Oklahoma pension, trust, and endowment assets the program involves
- $2,500 — Amount of the campaign donation from Bond Payne to Treasurer Russ in February 2025
- 2 years — Federal lockout period on compensation under pay-to-play rules
- 3 — Number of firms that submitted bids, including MEMCO and GCM Grosvenor
- May 6 — Date Attorney General Drummond threatened legal action over the contract award
Zoom Out
The pay-to-play rule was adopted by the Securities and Exchange Commission in 2010 following a series of public pension fund scandals in multiple states involving improper campaign contributions to officials with contracting authority. Oklahoma is among several states where enforcement of the rule has come into question in recent years, particularly as state pension funds have expanded their use of private equity managers. A related case involving alleged financial misconduct in Oklahoma’s Epic Charter Schools system is also moving through the courts, underscoring recurring concerns about oversight of public funds in the state.
What’s Next
Oklahoma Attorney General Gentner Drummond, a Republican currently running for governor, has stated publicly that he views the bidding process as tainted by collusion and undisclosed conflicts of interest. He has indicated he would pursue legal action if any contract based on the February award is executed. The Invest in Oklahoma board has not publicly announced a timeline for restarting or restructuring the bidding process. Russ’ office has not indicated whether it plans to recuse itself from future proceedings related to the program.