Reporting and Recordkeeping Requirements
To monitor compliance with the pay to play rule, the MSRB requires broker-dealers to submit quarterly statements, reporting all of their political contributions for the previous quarter. They must also list all the issuers with whom they engaged in municipal securities business activities for the quarter. Reports must be filed on Form G-37 and sent to the MSRB by the last day of the month following the end of each calendar quarter.
De minimis contributions to officials of issuers do not need to be reported, however, as long as the municipal finance professionals or non-MFP executives are eligible to vote in that election. Similarly, contributions of $250 or less to political parties in elections in which the MFP or non-MFP executive is entitled to vote need not be reported.
Reported information on the Form G-37 quarterly reports must include the following:
- • Name and title of each official and political party receiving contributions, listed by state
- • Identity of each contributor controlled by the broker-dealer or MFP and the amount paid
- • For contributions to bond ballot campaigns, the following information must be declared:
- » The official name of each bond ballot campaign receiving contributions and the jurisdiction where the municipal securities would be issued
- » The contribution amount, date of contribution, and type of contributor (broker-dealer, MFP, non-MFP executive officer, PAC)
- » Full description of the issue resulting from the bond ballot campaign
- » The payments received from any third party related to the dealer’s bond ballot contribution, including the name of the third party and the amount paid
A bond ballot campaign is a fund or organization that solicits contributions for a ballot initiative. The ballot initiative seeks authorization by popular vote for the issuance of municipal securities.
A firm that has not made reportable contributions to muni