News & Analysis as of

Rule 15c2-12 MSRB

Ballard Spahr LLP

White Paper: Structured Data is Coming to the Municipal Securities Market–Now What?

Ballard Spahr LLP on

The Financial Data Transparency Act of 2022 (FDTA), enacted by Congress as Title LVIII of the National Defense Authorization Act for Fiscal Year 2023, was signed into law by President Biden on December 23, 2022. The FDTA is...more

Orrick, Herrington & Sutcliffe LLP

A Teachable Moment: Latest SEC Enforcement Actions Remind Underwriters of Limited Offering Exemption’s “Reasonable Belief”...

In an unprecedented move, the Securities and Exchange Commission (the “SEC”) recently filed litigation against one underwriter of municipal securities and announced settlements with three others. The litigation and...more

Dorsey & Whitney LLP

SEC Charges Underwriters with Violations of Rule 15c2-12

Dorsey & Whitney LLP on

​​​​​​​Last week, the SEC entered orders against three underwriters for failing to comply with Securities Exchange Act of 1934 (“Exchange Act”) Rule 15c2-12. These actions serve as a good reminder for compliance checks and...more

K&L Gates LLP

Securities and Exchange Commission Amends and Updates Rule 15c2-12

K&L Gates LLP on

Since 1995, states and local governments have been subject to Rule 15c2-12 (the “Rule”), promulgated by the U.S. Securities and Exchange Commission (the “SEC”). Under the Rule, governmental entities that issued securities...more

Foley & Lardner LLP

SEC Adds Two New Events to Rule 15c2-12: Could Have Far-Reaching Impact on Issuers and Obligors of Municipal Securities

Foley & Lardner LLP on

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

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

Kramer Levin Naftalis & Frankel LLP

Debt Dialogue: June 2017 - SEC Proposes Modifications to Rule 15c2-12 to Increase Event-Driven Disclosures by Municipal Issuers

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

Kramer Levin Naftalis & Frankel LLP

Debt Dialogue: April 2017 - SEC Action Against Underwriter Illustrates Enforcement of Disclosure Violations in the Muni World

On April 5, as one of several enforcement actions relating to an alleged Ponzi scheme, the Securities and Exchange Commission settled an administrative enforcement action against a municipal bond underwriter accused of...more

Hinshaw & Culbertson LLP

SEC Proposes to Add New Reporting Events to the Municipal Disclosure Rule

On March 15, 2017, the U.S. Securities and Exchange Commission (SEC) published for public comment proposed amendments to the Municipal Disclosure Rule, Rule 15c2-12 under the Securities Exchange Act of 1934. The proposed...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

Burr & Forman

SEC to Propose "Requiring" Municipal-Issuers to Disclose Bank Loans

Burr & Forman on

The two remaining SEC Commissioners agreed March 1 to propose amendments “requiring” municipal securities issuers to disclose non-security financial obligations and material events occurring in other outstanding obligations....more

McNees Wallace & Nurick LLC

SEC Proposes Amendments to Rule 15c2-12 to Address Bank Loan Disclosure Concerns

At its meeting on March 1, 2017, the United States Securities and Exchange Commission (SEC) voted to formally propose and publish for comment amendments to Rule 15c2-12 to add two additional disclosure events to written...more

Holland & Knight LLP

Will President Trump's Regulation Cuts Reduce Ongoing Disclosure for Bond-Financed Projects?

Holland & Knight LLP on

President Donald Trump on Feb. 3, 2017, signed an executive order entitled "Core Principles for Regulating the United States Financial System," which directed the Treasury Secretary to consult with financial regulators,...more

Dechert LLP

SEC Announces Further Enforcement Actions in the Municipalities Continuing Disclosure Cooperation Initiative

Dechert LLP on

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

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