Exam alert: SEC issues risk alert on “Pay-to-Play” practices

On August 31, 2012, the SEC issued a risk alert regarding compliance with MSRB rules. Specifically, the alert looks at failures to comply with Rule G-37, which prohibits a firm from doing business with a municipal issuer if a municipal finance professional of the firm donated money to an official of that issuer within the past two years. Continue reading

On August 31, 2012, the SEC issued a risk alert regarding compliance with MSRB rules.  Specifically, the alert looks at failures to comply with Rule G-37, which prohibits a firm from doing business with a municipal issuer if a municipal finance professional of the firm donated money to an official of that issuer within the past two years.  The alert expresses concerns about violations of the ban, as well as inadequate supervision, failure to file forms, and recordkeeping violations.

The alert identifies good practices implemented by brokers to ensure compliance with the rule.  These practices include training programs for municipal finance professionals, self-certification of compliance with the rule, surveillance of unreported political contributions, and restriction on political contributions (when permitted by state or local law).

Source: SEC Issues Risk Alert on “Pay-to-Play” Prohibitions Under MSRB Rules (SEC Release 2012-173)

This alert applies to the Series 24, Series 7, and Series 99.

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