Other Pay to Play 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
Explanation: 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 sign a check from a joint account along with a document that states the contribution is being made solely by the other holder of the joint account. The amount was for $400. Would any portion of this contribution be attributable to you as an MFP?
Answer: Yes
Explanation: If a municipal finance professional signs a check, whether the check was drawn on a joint account or not, and submits it as a contribution to an issuer official, then the municipal finance professional is deemed to have made the full contribution, regardless of any writing accompanying the check that provides or directs otherwise. Moreover, if this amount exceeds, or does not qualify for, the de minimis exception, then by making such a contribution the municipal finance professional will trigger the rule’s ban on business, thereby prohibiting his dealer/employer from engaging in municipal securities business with that particular issuer for two years.
Example Question 3
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
Explanation: Solicitations of contributions are prohibited by the rule. Therefore, there is no de minimis exception, a