On Wednesday, the Municipal Securities Rulemaking Board (MSRB) announced that its expanded pay-to-play rules will cover municipal advisors, including third-party solicitors, as of August 17, 2016.
As we noted previously and discussed during Covington’s Corporate Political Activity & Government Affairs Compliance Conference earlier this month, the MSRB has been drafting an expansion to its pay-to-play rule, Rule G-37.
Now that the MSRB’s rule is set to go into effect this summer, we will be watching the progress of the FINRA rule. At this point, the SEC is expected to act on the FINRA rule before April. Expect the SEC’s temporary reprieve on enforcement to end this year once both MSRB and FINRA rules are in effect, which is on track to happen this fall.