Category: Rule G-37

Rule G-37 and PACs: new rules coming?

Post author By Eric Brown
Post date September 13, 2010
Categories In Rule G-37

Pay to Play Blog notes recent MSRB activity on Rule G-37 and dealer-controlled political action committees.

SEC’s new pay to play rules and notions of “solicit” and “bundling”

Post author By Eric Brown
Post date July 11, 2010
Categories In Rule G-37

Still going through the Securities and Exchange Commission’s new pay to play rules? A few random points. On the rules’ notion of what constitutes a “solicitation,” the rules adopt a broad facts and circumstances test. Footnote 328 discusses the definition and cites a Caplin & Drysdale comment letter. On bundling, the rules don’t define the […]

Wading through SEC’s new pay to play rules?

Post author By Eric Brown
Post date July 7, 2010
Categories In Rule G-37

The Federal Election Commission has a new “tip for treasurers” on the SEC’s new rules. The tip? Don’t call the FEC, call the SEC. Covington’s got an overview of the new rules here. The rules are available here. Not sure they made the Federal Register, yet. Footnote 154 speaks to inaugural and transition expenses. The […]