Political Contributions – Managing the Pay to Play Rule

If you live in the United States, it is impossible to avoid the constant chatter about the upcoming Presidential elections. And as the weather warms, the local and state elections are starting to heat up too. It is also a good time for advisors to remind employees of their obligations under MSRB Rule G-37 and the SEC’s Rule 206(4)-5.”

These rules are founded on the idea that providing political contributions could create the perception or reality that the company is seeking a quid pro quo. They also present a dilemma for employees and firms as to whether to fund candidates that support their political views, or serve the needs of municipalities and public pensions. The choice is yours, but now might be a good time for you to make sure employees (and recruits) are aware of your firm’s policies and procedures.

What You Should Do:

• Remind employees of their obligations and policies under the rule to disclose political contributions
• Review your clients against the political contributions log
• Have employees attest that they have complied with your policies and procedures
• Search candidate contribution disclosures to see if employees have undisclosed contributions

How Oyster Can Help:

Oyster Consulting can review your firm’s compliance program, including your Code of Ethics and supervisory practices. Oyster will not only help you understand potential problem areas, but will also identify best practices and provide training to your team to ensure they are aware of their responsibilities.

Oyster Solutions software is a powerful tool to implement and enhance your compliance program.  Among its many other features, Oyster Solutions software includes workflows to disclose and manage political contributions. Oyster can also help you protect your firm through support staffing or outsourcing.