Other Example Questions
Example Question 1
You are working as a non-MFP executive officer and you make a contribution to an official of an issuer in a region where you are not entitled to vote. Is your dealer prohibited from engaging in municipal securities business with the issuer?
Answer: No. The ban only applies to contributions made by dealers, MFPs, and PACs controlled by the dealer or MFP. However, your contributions will be subject to reporting provisions. Also, you may not make contributions for your dealer.
Example Question 2
You are working as an MFP and you live in an area that allows you to vote for an official of an issuer. You go door-to-door and solicit contributions from others for $200. You bundle these contributions together and send them in to the official. Will this trigger the ban?
Answer: Yes. Solicitations of contributions are prohibited by the rule. Therefore, there is no de minimis exception, and your firm would be subject to the ban.
Example Question 3
You are an MFP and made a contribution two months ago to an official candidate of an issuer. The contribution was not subject to the de minimis exception. The candidate subsequently did not win the election. Will this contribution trigger the ban?
Answer: Yes. Rule G-37 defines the term “official of an issuer” as “any person (including any election committee for such person) who was, at the time of the contribution, an incumbent, candidate, or successful candidate.”
Example Question 4
You are an MFP and your spouse makes a contribution of $500 to an official candidate of an issuer. Will this contribution trigger the ban?
Answer: No. Spouses and household members are not covered by the rule unless the contribution was directed by the MFP.
Example Question 5
A municipal securities dealer makes a contribution to a charitable organization at the request of the issuer. Would the contribution trigger the ban?
Answer: No. Do