Who Submits Political Contribution Information to the MSRB?
MSRB-regulated entities, including municipal securities dealers and municipal advisors, must submit information to the MSRB on their municipal securities and advisory business and related political contributions to municipal entity officials, state and local political parties, and bond ballot campaigns. Political contribution information is to be provided on Form G-37 for:
- Municipal finance professionals and non-MFP executive officers of a dealer
- Political action committees controlled by dealers or their municipal finance professionals
- Municipal advisors
- Municipal advisor professionals and non-MAP executive officers of a municipal advisor
- Political action committees controlled by municipal advisors or their municipal advisor professionals
Some regulated entities may not be required to submit political contribution information to the MSRB if they meet certain conditions set forth in MSRB Rule G-37. For example, if a regulated entity has not engaged in municipal securities business or municipal advisory business for the previous eight calendar quarters and has a valid Form G-37x on file with the MSRB, no reporting of political contribution information is required. Additionally, a regulated entity is not required to submit Form G-37 for any quarter in which it has no information to report.
What Information Must Regulated Entities Submit to the MSRB?
With certain exceptions, regulated entities must submit to the MSRB on Form G-37:
- Information on contributions made to municipal entity officials,
- Payments made to state or local political parties, and payments made to bond ballot campaign initiatives
- Information about municipal entities with which the regulated entity has engaged in municipal securities business or municipal advisory business
How Do Regulated Entities Submit Political Contribution Disclosures to the MSRB?
Regulated entities may file political contribution disclosures via electronic Forms G-37 or G-37x through a password-protected account in MSRB Gateway.
How Often Must Political Contribution Disclosures Be Submitted?
Regulated entities must submit political contribution disclosures to the MSRB on a quarterly basis with certain exceptions.
How Can Political Contribution Disclosures Be Accessed?
Since the 1990s, the MSRB has made political contribution disclosure documents available to the public. As of February 2013, these documents are made available on the MSRB's Electronic Municipal Market Access (EMMA®) website.
What MSRB Rules Govern Political Contribution Reporting Requirements?
- MSRB Rule G-37 prohibits dealers from engaging in municipal securities business and municipal advisors from engaging in municipal advisory business with municipal entities if certain political contributions have been made to officials of such municipal entities. 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.
Read additional information about Rule G-37 and political contributions.
- MSRB Rule G-37 Interpretive Questions and Answers
- Instructions for Forms G-37, G-37x and G-38t
- MSRB Rule G-37 Interpretive Notices and Letters
- Other federally filed information on political contributions
For assistance, contact MSRB Support at 202-838-1330 or MSRBsupport@msrb.org.
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