De Minimis Exception
The pay to play rule carves out an exception for small contributions in elections by MFPs and MAPs who are entitled to vote for an elected official. MFPs and MAPs are allowed to contribute up to $250 per election in which they are entitled to vote. For instance, a resident of Minnesota could make a small contribution to the governor of Minnesota for his reelection campaign. This is often referred to as the de minimis exception. Under this exception, a MFP or MAP could give up to $250 in the primary election and up to $250 in the general election because these are two separate elections. Note that this exception only applies to associated persons and not to the firms themselves.
Example Question 1
John is a municipal advisor professional and lives in a district that votes for an official that could direct business to his advisory firm. John makes a contribution of $200. Would this trigger the ban on advisory business with the municipal entity under the official’s control?
Answer: No
Explanation: John’s contribution falls under the de minimis exception of $250.
Examp