In 2014, the Securities and Exchange Commission (the “SEC”) implemented the Municipalities Continuing Disclosure Cooperation Initiative (the “MCDC Initiative”) in order to address alleged widespread violations of the federal securities laws by municipal issuers and underwriters in connection with representations regarding municipal issuers continuing disclosures in their bond offering documents. The MCDC Initiative goal was to correct past failures to comply with the municipal issuers continuing disclosure undertakings pursuant to SEC Rule 15c2-12 in a timely manner.
Although the MCDC Initiative has come to an end, disclosure compliance remains an ongoing responsibility that requires the municipal entity to monitor its outstanding debt and subsequent reporting requirements, and to post the needed documentation in a timely manner on the SEC’s EMMA website.
Our expertise in municipal finance makes us particularly qualified to provide continuing disclosure services so that our client’s municipal debt obligations are maintained in good disclosure standing which enables our client’s to readily access to the primary and secondary municipal markets.
NW Financial reviews continuing disclosure agreements for hundreds of clients providing the following services:
- Review the requirements of prior secondary market disclosure undertakings
- Provide on-going alerts and updates to the client
- Complete and post all required documents by the filing deadlines
- Monitor and post any rating agency upgrades or downgrades to issuances and rating changes for any insured deals for the client
- File any material events specific to any outstanding bond transactions
- Monitor and file material event notices for any new debt obligation or financial occurrences