Political Contribution Disclosures
Who Submits Political Contribution Information to the MSRB?
Municipal securities dealers that underwrite municipal bonds must submit information to the MSRB on their municipal business and related political contributions to issuer officials, state and local political parties, and bond ballot campaigns. Political contribution information is to be provided for the dealer, the dealer's municipal finance professionals and non-municipal finance professional executive officers, as well as political action committees controlled by dealers or their municipal finance professionals.
What Information Must Dealers Submit to the MSRB?
With certain exceptions, dealers must submit to the MSRB on Form G-37:
- Information on contributions made to issuer officials,
- Payments made to state or local political parties, and payments made to bond ballot campaign initiatives
- Information about issuers with which the dealer has engaged in municipal securities business
How Do Dealers Submit Political Contribution Disclosures to the MSRB?
Dealers may file political contribution disclosures via paper or electronically using Form G-37 and Form G-37x. Any person submitting disclosure documents electronically must establish a password-protected account with the MSRB Gateway.
Form G-38t must be submitted in paper format. To make a paper submission, download and complete the instructions as shown on the form.
Read more about submission forms here.
How Often Must Political Contribution Disclosures Be Submitted?
Dealers and related parties must submit political contribution disclosures to the MSRB on a quarterly basis with certain exceptions.
Dealers need not submit Form G-37 for any quarter in which there is no information to report. In addition, if a dealer has not engaged in municipal securities business for at least two years and has submitted Form G-37x, such dealer need not submit Form G-37 unless it thereafter engages in municipal securities business.
What MSRB Rules Govern Political Contribution Reporting Requirements?
- MSRB Rule G-37 prohibits municipal securities dealers from engaging in municipal securities business with issuers if certain political contributions have been made to officials of such issuers. It also requires them to disclose certain political contributions to the MSRB to allow for regulatory and public scrutiny.
- MSRB Rule G-38 prohibits municipal securities dealers from making payments for the solicitation of municipal business to any persons not affiliated with their firm. Rule G-38 contains provisions for transitional payments to unaffiliated persons of dealers if the payments are related solely to solicitation activities by consultants or others on or prior to the effective date of Rule G-38, and if certain other conditions are strictly adhered to, including, but not limited to, quarterly filing of Form G-38t.
Additional Information
Read additional information about Rule G-37 and Political Contributions.
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