Political Contributions by Certain Investment Advisers: Ban on Third-Party Solicitation; Order With Respect to MSRB Rule G-37

The Securities and Exchange Commission ("Commission' or "SEC') is issuing an order finding that Municipal Securities Rulemaking Board ("MSRB') rule G-37 (the "MSRB Pay to Play Rule') imposes substantially equivalent or more stringent restrictions on municipal advisors than rule 206(4)-5 (the "SEC Pay to Play Rule) under the Investment Advisers Act of 1940 (the "Advisers Act') imposes on investment advisers and is consistent with the objectives of the SEC Pay to Play Rule.