What Are Political Contribution Disclosures?
Under its pay-to-play rules, the MSRB requires municipal securities dealers and municipal advisors to disclose information in connection with certain
political contributions they (or certain of their associated persons) make to officials of municipal entities, state and local political parties, and
bond ballot referendum committees. In addition, dealers and municipal advisors also must disclose certain information about the municipal securities business
and/or municipal advisory business in which they engage.
What Information Does a Political Contribution Disclosure Provide?
Quarterly, dealers and municipal advisors are required to report to the MSRB information required on Form G-37. Form G-37 requires disclosure of certain
contributions to officials of municipal entities, payments made to political parties of states or political subdivisions, and contributions made to bond
ballot campaigns made by:
- The dealer firm
- Municipal finance professionals and non-MFP executive officers of the dealer firm
- Political action committees controlled by the dealer firm or its municipal finance professionals
- The municipal advisor firm
- Municipal advisor professionals and non-MAP executive officers of the municipal advisor firm
- Political action committees controlled by the municipal advisor firm or its municipal advisor professionals
Dealers and municipal advisors also must report on Form G-37 municipal entities with which they have engaged in municipal securities business or municipal
Dealers and municipal advisors are not required to file Form G-37 if they have no information to report (e.g., they have not made any political contributions
and have not engaged in municipal securities business or municipal advisory business) for the reporting period. Additionally, dealers and municipal advisors
that have not engaged in municipal securities business or municipal advisory business for an extended period of time may be eligible to file a much more
limited disclosure document, Form G-37x, in lieu of a quarterly Form G-37. As long as the dealer or municipal advisor’s Form G-37x on file with the MSRB
remains valid, the dealer is not required to file quarterly Form G-37 disclosures.
A limited number of dealers also submit quarterly reports on Form G-38t that include information about transitional payments solely for past services
provided by consultants, including compensation arrangements, municipal securities business obtained, payments pending, and reportable political contributions
and political party payments.
Accessing Political Contribution Disclosures