Interested in training for your team? Click here to learn more

Pay-to-Play Compliance in Municipal Contracts

Avoiding Violations of MSRB Amended Rule G-37, SEC Rule 206 (4)-5, FINRA Rule 2030, CFTC Reg 23.451

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, May 8, 2018

Recorded event now available

or call 1-800-926-7926

This CLE course will examine the bevy of “pay-to-play” rules and their impact on contracts with state and local government entities. The panel will also discuss current trends in enforcement, and compliance best practices.


The U.S. Municipal Securities Rulemaking Board (MSRB), Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), and Commodity Futures Trading Commission (CFTC) have all promulgated rules restricting political contributions by certain financial or advisory services government contractors to state and local government entities. These rules apply to covered business with state and local governments nationwide. Moreover, many states and localities have their own "pay-to-play" rules as well, which typically apply more broadly to government contractors (not just financial services or advisory firms) in the jurisdiction.

For firms pursuing or performing work with state and local governments, counsel must understand these rules, particularly their breadth and impact on company strategy (during the pursuit phase) and the daily administration of public contracts post-award. Counsel for local governments must also understand the requirements and prohibitions of these rules.

Listen as our experienced panel discusses navigating this sometimes complicated regulatory landscape and provides tools to help avoid costly missteps.



  1. Regulatory overview
    1. MSRB amended Rule G-37
    2. SEC Rule 206(4)-5
    3. FINRA Rule 2030
    4. CFTC Regulation 23.451
  2. Municipal application
    1. Local governments
    2. Government contractors
  3. Outlook and expectations
    1. Judicial challenges
    2. Legislative developments


The panel will review these and other critical issues:

  • To which business activities do pay-to-play laws apply?
  • Which affiliated individuals and entities are subject to the law?
  • What are the consequences for covered individuals and entities (prohibitions, reduced contributions limits, reporting)?
  • What are the penalties for violating applicable pay-to-play laws?


Holzrichter, Mitchell
Mitchell D. Holzrichter

Mayer Brown

Mr. Holzrichter practices in the firm’s Government and Global Infrastructure Groups. He focuses on...  |  Read More

Zweibel, Patricia
Patricia M. Zweibel

Skadden Arps Slate Meagher & Flom

Ms. Zweibel advises clients on government affairs matters at the federal, state and local levels, including ethics,...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video