Exemptive relief is granted based on: the representation that at the time of the contribution the individual had no connection to the firm’s municipal securities business, and it was not contemplated that, at the time of the contribution, he would be promoted and, thus, become a municipal finance professional (as defined); the firm has significant and long standing business relationships with the government entity of which the contribution recipient was an issuer official; the firm has established additional compliance processes about political contributions; the individual will not be involved in any way in municipal securities business with the state or any other governmental issuer business for which the contribution recipient is an issuer official.