Muni Commentary

It started with the SEC’s MCDC initiative and Cease and Desist Orders, then it was the resulting enhanced scrutiny of underwriters and now it’s amendments to Rule 15c2-12.  Each has further emphasized the importance of ensuring a complete understanding and management of disclosure obligations and having comprehensive polices and procedures. 

The amendments to Rule 15c2-12 have refocused the spotlight on issuers and their policies, procedures and controls as well as their filing history and ongoing disclosure management.  Our full article (link below) highlights what the market has learned since the MCDC initiative, discusses the Rule 15c2-12 amendments and identifies several resources for your consideration.

With the cold winter air hanging around, the early months of the year can often be a time of winter blues. For some municipal debt issuers, it may also be a time of continuing disclosure filing blues. We often hear that there are many pieces of information to track when preparing a filing and, even after filings are made, there is still the worry that something was missed. For example, we have seen situations where a filing was made but was not filed to all the necessary CUSIPs. Or, a financial filing did not contain all of the information that the issuer committed to provide in the Continuing Disclosure Agreement. According to the GFOA Information on Best Practices for Disclosure, even when another firm is hired to prepare and/or submit filings on behalf of the municipal issuer, "Disclosure is the responsibility of the issuer. Others may assist in preparation but the issuer is ultimately responsible for completeness and accuracy."

Before getting started, we here at Lumesis send our thoughts and prayers to those impacted by Harvey. This week we bring you the August 2017 DIVER Geo Scores and a look at the SEC’s Beaumont Order.

DIVER Geo Scores are designed to quickly communicate the overall economic health of a selected geographic area on a scale of 0 to 10. The Geo Score reflects the relative economic well-being of the location and is available for all States, counties, and approximately 350 of the largest cities. Calculations are released monthly and are based on multiple, meaningful economic and demographic data from the employment, income and housing categories.

This week we take a look at the importance of continuing disclosure for Issuers of municipal debt and suggest some best practices.

 This week we bring you the February 2017 DIVER Geo Scores and, in case you missed it, some interesting news and a quote around the Labor Department’s Fiduciary Rule. Last month, a reader requested that we provide, in addition to the locations with the greatest moves, the top and bottom States, counties and cities. Given our limited space, we refer you to our website for that data.

 This week we look at the recently released MSRB report regarding disclosure filings and offer some facts and observations.  We also look at those obligors that might be impacted should the Oroville Dam fail.

 This week we start with a review of the SEC’s announcement ending the MCDC initiative, a possible SEC focal point for 2017, and bring you the December 2016 DIVER Geo Scores.  DIVER Geo Scores are designed to quickly communicate the overall economic health of a selected geographic area on a scale of 0 to 10 and reflect the relative economic well-being of all States, counties, and approximately 350 of the largest cities.  Calculations are released monthly and are based on multiple, meaningful economic and demographic data from the employment, income and housing categories.