On Friday, July 17, 2009, the Securities and Exchange Commission (the SEC) published proposed changes to Exchange Act Rule 15c2-12 (the Rule) relating to continuing disclosure requirements for municipal securities. The Rule requires that underwriters in a primary offering of municipal securities reasonably determine that an issuer of municipal securities or an obligated person has undertaken, in a written agreement or contract for the benefit of bondholders, to provide certain continuing disclosure information to the Municipal Securities Rulemaking Board (MSRB). The proposed Rule modification will....

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