Governmental entities have increasingly experienced cybersecurity incidents impacting their operations and finances over the last few years, with some breaches costing upwards of $40 million. Many issuers and borrowers of...more
On April 9, the Municipal Securities Rulemaking Board (“MSRB”) filed with the SEC a temporary rule change that waived certain late fees and delayed some key compliance deadlines....more
Our thoughts are with you, your loved ones and organizations as we all navigate this public health crisis together. We are providing this alert to our public finance clients and other professionals regarding COVID-19 and its...more
The Situation: The Municipal Securities Rulemaking Board ("MSRB") amended its rules regarding primary offering practices and disclosures in connection with primary offerings to enhance regulatory transparency, ensure equal...more
Introduction - Over the past several years, local government issuers have increasingly been privately placing bonds and other municipal debt obligations directly with banks or other purchasers rather than utilizing an...more
Now that the 2018 midterm elections are over, we must contend with legal issues that arise from activities related to federal, state and local inaugural and transition committees, as well as recounts and runoff elections. As...more
On August 20, 2018, the Securities and Exchange Commission (“SEC”) issued Release No. 34-83885 (the “Release”) adding two new events (the “New Events”) to the list of events that must be included in the continuing disclosure...more
On August 20, 2018 the Securities and Exchange Commission (“SEC”) adopted amendments to 17 CFR 240.15c2-12, commonly referred to as “Rule 15c2-12”, which deals with continuing disclosure obligations. According to the SEC’s...more
Regulation FD prohibits public companies from disclosing material nonpublic information to designated classes of persons such as securities professionals and holders of the issuer’s securities without, in most cases,...more
On March 1, 2017, the Securities and Exchange Commission (SEC) published for comment proposed amendments to Rule 15c2-12 under the Securities Exchange Act of 1934 (Exchange Act) that would expand the list of events triggering...more
On March 1, 2017, the Securities Exchange Commission voted in open meeting to propose amendments to Rule 15c2-12 under the Securities Exchange Act of 1934 adding two event notices to the current fourteen required in...more
The U.S. Securities and Exchange Commission (SEC or Commission) announced enforcement actions against 22 municipal underwriters on September 30, 2015, as part of its Municipalities Continuing Disclosure Cooperation Initiative...more
Although the MSRB’s new best execution rule is generally consistent with FINRA’s, differences exist and questions remain regarding FINRA’s examination and enforcement of the requirements....more
The MSRB last week proposed an extension of its gift-limitations Rule G-20 to encompass municipal advisors. The Proposed Rule generally limits gifts in relation to municipal securities or advisory services to $100 per year. ...more
The SEC last week approved new MSRB Rule G-44 implementing supervision and compliance requirements for municipal advisors. The MSRB touted the Rule as “its first dedicated rule for municipal advisors” under the Dodd-Frank...more
Today, the Municipal Securities Rulemaking Board (MSRB) announced that it will distribute a confidential electronic survey to registered municipal advisors to assess the business activities of municipal advisory...more
On Thursday, January 9, the MSRB re-proposed new Rule G-42 promulgating standards of conduct for Municipal Advisors (“MA’s”) subject to the almost-newly-effective SEC MA Rule, 17 CFR § §240.15Ba1-1 to 15Ba1-8 (now delayed...more
The SEC’s new Municipal-Advisor Rules, 17 CFR § § 240.15Ba1-1 to 15Ba1-8 were to become effective Monday, January 13, 2014 but that morning were delayed until July 1. SEC Rel. 34-71288. Adopted last September, SEC Rel....more
The Municipal Securities Rulemaking Board, or MSRB, is seeking comment on proposed rule changes that would set forth in a single rule the requirements to and process by which brokers, dealers and municipal securities dealers...more
Brokers, dealers, and municipal securities dealers are now required to disclose additional information about their bond ballot contributions under amendments to the Municipal Securities Rulemaking Board’s (MSRB) “pay-to-play”...more
In the spring of 2012, the Securities and Exchange Commission approved the release of MSRB Notice 2012-25, which provided interpretive guidance on how SEC Rule G-17 applied to underwriters of municipal securities...more
On September 27, 2012, Goldman Sachs agreed to pay $12 million to settle claims with the Securities and Exchange Commission (“SEC”) alleging that one of its employees engaged in a pay-to-play scheme. The scheme, as described...more
As market regulators press for stricter reporting guidelines for state and local governments concerning pension disclosure in public offerings, the Government Finance Officers Association (GFOA) is advocating that funding...more