Notice to Members 96-54
NASD Regulation Reminds Members of Reporting Obligations of MSRB Rules G-37 and G-38, and Announces Sanction Guidelines for Failure to Report Form G-37/G-38
NASD Regulation, Inc. (NASD RegulationSM) again reminds members of their reporting obligations under Municipal Securities Rulemaking Board (MSRB) Rules G-37 and G-38. Members are required to submit Form G-37/G-38 to the MSRB within 30 calendar days after the end of each calendar quarter if any one of the following occurred during the reporting period: reportable political contributions to issuer officials or payments to political parties were made; the dealer engaged in municipal securities business; or the dealer used consultants to obtain or retain municipal securities business (i.e., new or continuing relationships with consultants). Failure to timely report information required by Rules G-37 and G-38 and patterns of filing deficiencies could result in a monetary sanction, suspension, and/or bar. On July 18, 1996, the NASD Regulation National Business Conduct Committee (NBCC) approved Sanction Guidelines for G-37/G-38 reporting violations. These guidelines are effective immediately and are provided at the end of this Notice.
Questions regarding this Notice may be directed to Thomas R. Cassella, Vice President, NASD Regulation Compliance Department, at (202) 728-8237, or Samuel Luque, Jr., Associate Director, NASD Regulation Compliance, at (202) 728-8472.