3.2.5.12. Other Pay to Play Example Questions
Example Question 1
You are working as a non-MAP 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 advisor prohibited from engaging in municipal securities business with the issuer?
Answer: No. The ban only applies to contributions made by advisors, MAPs, and PACs controlled by the advisor or MAP. However, your contributions will be subject to reporting provisions. Also, you may not make contributions for your advisor.
Example Question 2
You are an MAP 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 3
You are an MAP 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 MAP.
Example Question 4
A municipal advisor makes a contribution to a charitable organization at the request of the issuer. Would the contribution trigger the ban?
Answer: No. Donations to charitable organizations are not considered political contributions for purposes of Rule G-37.
Example Question 5
You are an MAP who lives in a district that allows you to vote for a candidate. You solicit a political action committee