"New MSRB guidance, which took effect December 12, 2010, outlines factors that may result in the PAC of an affiliated company, such as a bank, being viewed as controlled by the dealer itself or one of its municipal finance professional employees (MFPs). In a nutshell, the guidance requires a thorough examination of all facts and circumstances related to the creation, management, funding and operational control of the PAC to ascertain if it is controlled by the dealer. The guidance is clear that control can exist in the absence of “majority control” of a PAC board. For example, a PAC may be viewed as dealer controlled if the dealer has just one vote on a multi-member PAC governing board or if a majority of the PACs funds come from the dealer’s MFPs."
Corporate PACs -- When Is The Last Time You Had A Compliance Audit?
Political GPS: Womble Carlyle Political Law:
