Appeal body upholds decision to deny exemptive relief under Municipal Securities Rulemaking Board (MSRB) Rule G-37 because the political contribution at issue resulted from a failure of the firm to develop and institute procedures reasonably designed to ensure compliance with Rule G-37.


February 28, 1997

 

A
Firm X
Address

 

RE: MSRB Rule G-37 Exemption Request

 

Dear A:

 

The Fixed Income Committee of NASD Regulation, Inc. has reviewed your appeal for exemptive relief and has determined to deny your request. The Committee found that the contribution at issue resulted from a failure of the firm to develop and institute procedures reasonably designed to ensure compliance with Rule G-37. The Committee noted that the text of Rule G-37 requires NASDR to consider whether the firm, prior to the time of the contribution, had developed and instituted procedures reasonably designed to ensure compliance with Rule G-37.

 

Very Truly Yours,

 

 

Alden S. Adkins
General Counsel

 

cc: Christopher A. Taylor, MSRB