Municipal Advisor Pay-to-Play Rules “Deemed Approved”

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The MSRB’s Rule G-37 amendments applying pay-to-play prohibitions to Municipal Advisors and their third-party solicitors will become effective August 17, 2016.

The proposed amendments extend Rule G-37 to municipal advisers and third-party solicitors:

  • Imposing a two-year ban on business with municipal entities after any contribution to an issuer official who can influence municipal-advisory business, subject to $250 de minimis exclusion to officials for whom a contributor can vote;
  • Prohibiting soliciting, coordinating (“bundling”), and contributions to state/local political parties or bond ballot initiatives – as well as indirect violations;
  • Imposing related disclosure and books-and-records requirements.

The proposed Rules were “deemed approved” February 13 by the SEC’s inaction on the last amendments to the proposal filed December 23, 2015 as Release No. 34-76763; File No. SR-MSRB-2015-14.

MSRB Reg. Notice 2016-06 (Feb. 17, 2016) is here.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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