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CTOWT14.pptx
Compliance Tip of the Week
Pre-clearance for Political Contributions
With midterm Elections coming up I think it’s a great idea to remind everyone the proper procedure if you are going to make a political contribution.
5.13.6 PRE-CLEARANCE OF POLITICAL CONTRIBUTIONS If any Supervised Person wishes to make a political contribution to any state or local government entity, official, candidate, political party, or political action committee, the Supervised Person may seek pre-clearance from the Firm’s CCO, or his designee whenever the total contribution to be made exceeds $150. Total contribution is the sum of the proposed contribution and any prior contributions made directly or indirectly to the same entity or person. For example, a Supervised Person who previously contributed $100 and would like to contribute another $100 has a total contribution of $200. Since $200 exceeds the $150 contribution limit by $50, the Supervised Person should obtain pre- clearance on the second contribution of $100 or reduce the size of the second contribution to $50 to avoid the restriction on eligible advisory fees. Page 31 V1.1 The $150 contribution limit is increased to $350 for Supervised Persons who are eligible to vote in the election of the candidate or official. Both the $150 and $350 contribution limits apply to each election, so political contributions made to a candidate in a prior election will not count toward subsequent elections for the same candidate or official. Note: Any Supervised Persons involved in soliciting the business of municipalities must be mindful of MSRB Rule G-37 and should keep political contributions at or below $250 to avoid triggering restrictions on their business. Supervised Persons who are governed by MSRB Rule G-37 may make political contributions only to officials for whom they are entitled to vote.
Can’t say Compliance without Clients
Has your residence recently changed?
Email [email protected] within 30 days of moving to avoid the possibility of fines
CC: [email protected]
Don't forget to check state licensing and carrier appointments
Every day offers opportunities to shine!
only to officials for whom they are entitled to vote.
political contributions only to officials for whom they are entitled to vote.
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