Compliance, Recordkeeping, and Regulatory Reporting
Books, records, and reporting
Rule G-8 lists the records a municipal securities dealer must make and keep; SEC Rules 17a-3 and 17a-4 govern content and retention - generally six years, with the most recent two readily accessible. Covered records include order tickets, confirmations, customer account information, correspondence, complaint files, supervisory review logs, and syndicate records. Rule G-27 supplies the supervisory system that produces them; examiners look for contemporaneous evidence, not reconstructions.
Political contributions fall under Rule G-37: a dealer may not engage in municipal securities business with an issuer for two years if a municipal finance professional makes a covered contribution to an official of that issuer, subject to the de minimis exception ($250 per election per candidate where the contributor is not entitled to vote for that candidate; $150 where entitled). Soliciting contributions and payments to political parties are prohibited, and Forms G-37/G-37x must be filed quarterly. Qualification and training live in Rule G-3, with a Regulatory Element and an annual Firm Element.
Traps
- Calling a contribution de minimis because it is small - the test is per election, per candidate, and voter status matters.
- Forgetting the two-year ban runs from the date of the contribution and covers negotiated business.
- Omitting the annual CEO certification and the annual OSJ inspection from the compliance calendar.
- Retaining records only three years because "that is the correspondence rule."
Rule of thumb
Build the calendar on four rhythms: annual (OSJ inspections, CEO certification, Firm Element, WSP review), quarterly (G-37 filings, EMMA submissions), per transaction (principal review and endorsement), and event-driven (complaints, contributions, new hires, continuing-disclosure failures).