If a non-MFP executive officer makes a contribution to an official of an issuer, is the dealer prohibited from engaging in municipal securities business with that issuer?
No. The prohibition section applies only to contributions made by the dealer, its municipal finance professionals, or any PAC controlled by the dealer or any of its municipal finance professionals. The definition of non-MFP executive officer does not include any municipal finance professional. However, contributions by non-MFP executive officers are subject to the reporting/disclosure provisions of the rule. In addition, pursuant to section (d), dealers are prohibited from using non-MFP executive officers (as well as any other person or entity) as a conduit for making contributions to officials of issuers.
Related Questions
- What actions would cause a dealer to be prohibited from engaging in municipal securities business with an issuer?
- In a bank with a separately identifiable dealer department, who would be considered a non-MFP executive officer?
- Is a municipal finance professional prohibited from performing volunteer work on an issuer officials behalf?
