Pay-to-play: proposed MSRB guidance regarding PACs under Rule g-37

The Municipal Securities Rulemaking Board (“MSRB”) recently filed with the Securities and Exchange Commission (“SEC”) proposed guidance regarding affiliated Political Action Committees (“PACs”) for purposes of the pay-to-play limitations imposed on municipal securities dealers under MSRB rule G-37. Much of the Proposed Guidance consolidates MSRB policy statements regarding PACs that were previously approved by the SEC. While the Proposed Guidance is aimed at municipal securities dealers, if approved by the SEC it will likely serve as precedent for similar limitations imposed on investment advisers by Rule 206(4)-5 under the Investment Advisers Act of 1940.

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Pay-to-play: proposed MSRB guidance regarding PACs under Rule g-37

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