5.2.4.4.1. Disclosure Requirements
To monitor compliance with the pay to play rule, the MSRB requires broker-dealers to submit quarterly statements reporting all of their political contributions for the previous quarter, whether made by MFPs or otherwise. They must also list all the issuers with whom they engaged in municipal securities business activities for the quarter. Reports must be filed on Form G-37 and sent to the MSRB by the last day of the month following the end of each calendar quarter.
De minimis contributions to officials of issuers do not need to be reported, however, as long as the municipal finance professionals or non-MFP executives are eligible to vote in that election. Similarly, contributions of $250 or less to political parties in elections in which the MFP or non-MFP executive is entitled to vote need not be reported.
Information reported on Form G-37 includes:
