SIE: Ban On Business

Ban on Business

A contribution will trigger a ban on municipal securities business with a municipal entity if the contribution was made by any of the following:

• • Municipal securities broker-dealers
• • A municipal finance professional (MFP)—definition to follow
• • Political action committee (PAC) that is controlled by either the municipal securities dealer or an MFP of the municipal securities dealer

Municipal securities business in this context is defined as:

• • Purchase of securities in a primary offering from an issuer (a negotiated underwriting, not a competitive underwriting)
• • Offer or sale of securities in a private placement
• • Provision of financial advisory services or remarketing agent services for a primary offering (where the services were not chosen on a competitive bid basis)

These activities are subject to the two-year prohibition. Note that selling municipal securities to customers in the secondary market is not considered municipal securities business for this rule. Moreover, the two-year ban