SEC Risk Alert on Pay-to-Play and MSRB

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On August 31, the SEC issued an alert on compliance with MSRB Rule G-37, which limits political contributions by municipal securities professionals to campaigns of public officials of issuers with whom they are doing or seek to do business. The SEC’s concerns include: (i) compliance with the rule’s ban on doing business with a municipal issuer within two years of a political contribution to officials of the issuer by any of the firm’s municipal finance professionals; (ii) possible recordkeeping violations; (iii) failure to file accurate and complete forms with regulators; and (iv) inadequate supervision. SEC Release. SEC Risk Alert.

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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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