News & Analysis as of

Municipal Securities Market EMMA

Orrick, Herrington & Sutcliffe LLP

The Financial Data Transparency Act

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

Adler Pollock & Sheehan P.C.

Navigating the Disclosure Labyrinth in Municipal Finance: A Practical Approach

One of the primary purposes of the Securities and Exchange Commission (the “SEC”) is to ensure that the investing public obtains accurate, timely and comprehensive information with respect to publicly-traded securities. The...more

Ballard Spahr LLP

Municipal Securities Regulation and Enforcement: The Year in Review and a Look Ahead

Ballard Spahr LLP on

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

McCarter & English, LLP

Voluntary Disclosures And The SEC’s Public Statement Regarding The Importance Of Disclosure For Our Municipal Markets

On May 4, 2020, the U.S. Securities and Exchange Commission (the “SEC”) released a public statement from Chairman Jay Clayton and Rebecca Olsen, Director of the SEC’s Office of Municipal Securities (“OMS”), titled, “The...more

Bracewell LLP

SEC Leaders Ask Municipal Issuers for Voluntary COVID-19 Disclosure

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On May 4, Securities and Exchange Commission Chairman Jay Clayton and Rebecca Olsen, Director of the SEC’s Office of Municipal Securities, issued a statement entitled “The Importance of Disclosure for our Municipal Markets”1...more

Bricker Graydon LLP

FAQs regarding voluntary disclosure

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In response to the COVID-19 pandemic, state and local government issuers of securities, and others generally obligated to support the payment of such securities, who entered into continuing disclosure undertakings or...more

Ballard Spahr LLP

Disclosing COVID-19 Risks and Impacts in Connection with Municipal Securities

Ballard Spahr LLP on

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

Ballard Spahr LLP

SEC Requires Addition of Two New Events to Continuing Disclosure Undertakings Beginning February 27, 2019

Ballard Spahr LLP on

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

Obermayer Rebmann Maxwell & Hippel LLP

Securities and Exchange Commission Adopts Amendments to Rule 15c2-12

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

Bracewell LLP

Disclosure Considerations and Tax Reform

Bracewell LLP on

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

Orrick, Herrington & Sutcliffe LLP

Call for Comments on Proposed SEC Amendment to Rule 15c2-12

Recently, the SEC proposed amendments to Rule 15c2-12 (the "Rule"), which was published in the Federal Register on or about March 16. Since 1995 governmental issuers and other obligors (like nonprofit health care...more

McGuireWoods LLP

Proposed Securities Rule Changes Focus on Bank Loans, Other Private Placements

McGuireWoods LLP on

SEC Proposed Amendments to Rule 15c2-12 - On March 1, 2017, the Securities and Exchange Commission (SEC) proposed amendments to Rule 15c2-12 under the Securities Exchange Act of 1934 that would add two new events that...more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposes Amendments to Rule 15c2-12 to Expand Municipal Securities Disclosures

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

Clark Hill PLC

SEC Settles Fraud Cases Against Municipal Issuers Under MCDC Initiative

Clark Hill PLC on

On August 24, 2016, the Securities and Exchange Commission ("SEC") announced settlements with 71 state and local government issuers of municipal bonds and private sector borrowers of bond proceeds (collectively, "issuers")...more

Foley & Lardner LLP

Recent MCDC Settlements Provide Guidance Concerning Scope of Materiality in Continuing Disclosure Obligations

Foley & Lardner LLP on

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

Ballard Spahr LLP

SEC Announces Second Wave of MCDC Enforcement Actions

Ballard Spahr LLP on

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

Cozen O'Connor

One Size Does Not Fit All: Written Disclosure Policies in a Time of Increased SEC Enforcement

Cozen O'Connor on

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

Mintz - Public Finance Viewpoints

MSRB Proposes Rule G-47 on Time of Trade Disclosure Obligations

MSRB Rule G-17 has been interpreted by the MSRB as requiring a broker or dealer (“broker”) to disclose to its customer, at or prior to the time of trade of a municipal security, all material information about the transaction...more

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