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.