SIFMA Comment Letter to MSRB on Bond Ballot Campaign Committee Contributions

SIFMA has released this comment letter to the MSRB on draft amendments to Rule G-37 ("Political Contributions and Prohibitions on Municipal Securities Business").

The draft amendments require an increase in the type of information publicly disclosed regarding contributions to bond-ballot campaigns. (This requirement would affect broker-dealers and municipal securities dealers.) This letter notes that while SIMFA was supportive of the MSRB’s initial disclosure regime for bond-ballot campaign contributions, it has concerns regarding the following aspects of the proposed amendments:

• Revision of the definition of "Contribution";
• Requiring name of issuer;
• Requiring complete date of engagement;
• Requiring dealers to disclose specific date a contribution was made;
• Requiring dealers to disclose reimbursements; and
• (Non)-Application to municipal advisors.

View comment letter here(links externally to SIFMA website).See also MSRB Regulatory Notice 2012-43; Other Comment Letters.