The Financial Data Transparency Act of 2022 (Act) will change the way issuers and obligors of municipal securities report required disclosure information on the Municipal Securities Rulemaking Board’s Electronic Municipal...more
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
The municipal securities market carried its momentum from the first half of 2021 into a strong finish for the year against the backdrop of continued regulatory and enforcement actions. Despite new variants of COVID-19...more
Given the far-reaching consequences of the COVID-19 pandemic, including unprecedented financial and operational impacts, volatile municipal market conditions and the potential for a significant economic contraction...more
As state and local governments confront the financial and operating strains imposed by the COVID-19 coronavirus pandemic, investors in the debt obligations of such governmental entities (referred to as municipal issuers) are...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
Is information posted on EMMA subject to greater scrutiny under the antifraud provisions of the federal securities laws than when posted only on an issuer’s website?...more
A new federal regulation taking effect soon will increase the burden of compliance with federal securities law on issuers of tax-exempt securities. ...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
As reported in our October 10, 2018 alert, the Securities and Exchange Commission has amended Rule 15c2-12 (the "Rule"), which governs continuing disclosure by state and local governmental borrowers to add two new material...more
Beginning February 27, 2019, municipal market issuers and obligated persons must add the following two new events—relating to their indebtedness and financial health—to the list of reportable events in their continuing...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
The impact of tax reform is on the minds of many. While there are currently many unknowns, municipal issuers and conduit borrowers (collectively, “obligated persons”) should consider whether changes in tax law could impact...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
Disclosure in the municipal securities markets has been a focus of the Securities and Exchange Commission for some time, but it has recently returned to center view with the SEC’s proposals for additions to the event-driven...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 15, 2017, the Securities and Exchange Commission (“Commission” or “SEC”) published in the Federal Register for comment proposed amendments to Rule 15c2-12 (the “Rule”) under the Securities Exchange Act of 1934...more
On March 1, 2017, the Securities and Exchange Commission (“SEC”) issued Release No. 34-80130 (the “Release”) proposing several amendments to its Rule 15c2-12 (the “Rule”) that would add two new events to the list of events...more
In responding to the Securities and Exchange Commission’s recent Municipalities Continuing Disclosure Cooperation (MCDC) initiative, the unanswered question for many municipalities and broker-dealers was determining whether...more
The Securities and Exchange Commission (SEC) this week announced enforcement actions under its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative, targeting 22 municipal bond underwriting firms for alleged due...more
The U.S. Securities and Exchange Commission (SEC) continues to increase its enforcement efforts in the municipal bond market by focusing on the sufficiency and timeliness of disclosure in initial municipal securities...more
As highlighted in the SEC’s 2012 Municipal Market Report, the SEC has expressed significant concern that many issuers have not been complying with their obligation to file continuing disclosure documents and that federal...more
The Securities and Exchange Commission released a statement on July 31, 2014, modifying certain aspects of its Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”). The MCDC Initiative provides...more
On March 10, 2014, the Enforcement Division of the Securities and Exchange Commission (SEC) announced the Municipalities Continuing Disclosure Cooperation Initiative (MCDC) – an offer for municipal issuers and their...more