3.2.5.12. Submitting Forms G-37 and G-37x
Quarterly Submission Requirements for Form G-37
Form G-37 must be submitted to the MSRB for a calendar quarter if any of the following occurred:
• Reportable political contributions,
• Payments to political parties, or
• Contributions to bond ballot campaigns were made during the reporting period
(Unless the regulated entity has previously submitted Form G-37x and the submission remains effective)
or
• During the reporting period, the regulated entity, if a municipal advisor, engaged in municipal advisory business with a municipal entity, or if a dealer, engaged in municipal securities business with a municipal entity.
Exemptions from Form G-37 Submission Requirement
A regulated entity is not required to submit a Form G-37 for a calendar quarter if both of the following are true:
• The regulated entity had no reportable contributions to municipal entity officials, payments to political parties or contributions to bond ballot campaigns for that calendar quarter;
and
• During that calendar quarter, the regulated entity, if a municipal advisor, did not engage in municipal advisory business with a municipal entity, or if a dealer, did not engage in municipal securities business with a municipal entity, and the regulated entity had not engaged in municipal securities business or municipal advisory business during the seven consecutive calendar quarters immediately preceding such calendar quarter. In addition, the entity must also file form G-37x, which is a certification that the entity did not engage in any municipal securities business or municipal advisory business during the last eight quarters. More information about Form G-37x is below.
Due to the breadth of the definition of municipal advisory business in Rule G-37, it is less likely that a municipal advisor would be able to use the exemption than a municipal dealer. The definition of municipal advi