Series 54: 3.3.4. Pay-to-Play Recordkeeping Requirements

Taken from our Series 54 Online Guide

3.3.4. Pay-to-Play Recordkeeping Requirements

In addition to submitting reports to the MSRB about political contributions, dealers and advisors must also maintain records of political contributions. These records must include a list of:

• Names, titles, city, county and state of residence of the dealer’s MFPs or the advisor’s MAPs

• Names, titles, city, county and state of residence of the advisor’s or dealer’s non-executive officers

• States in which the dealer or advisor is engaging or seeks to engage in municipal advisory or municipal securities business

Records for the current calendar year and each of the two previous years must also include a list of:

• All the municipal entities with which the dealer or advisor has dealt in municipal securities business or municipal advisory business

• All direct or indirect contributions made to officials of a municipal entity or political party by the dealer, advisor, or PAC controlled by a dealer or advisor

• All direct or indirect contributions or payments made by an MFP, MAP, non-MFP executive officer, non-MAP ex

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