Impact of Rule 15c2-12 Amendments

Nov 12, 2018 | Disclosure Notes

On August 20, 2018, the SEC adopted amendments to Rule 15c2-12 to expand the list of events requiring an event notice filing on EMMA. Our initial post describing the amendments is available here. This follow-up post provides additional detail about the amendments and...

SEC Adopts Continuing Disclosure Amendments

Aug 21, 2018 | Disclosure Notes

On August 20, 2018, the SEC adopted amendments to Rule 15c2-12 to expand the list of events that require a special notice filing on EMMA within 10 business days after their occurrence. incurrence of a financial obligation, if material, or agreement to covenants,...

Seven Things Everyone Asks About Continuing Disclosure

Jul 5, 2018 | Disclosure Notes

In a vain attempt to be like the trendy media outlets that use odd-numbered lists and slightly misleading headlines as clickbait, we present answers to seven commonly asked questions about the continuing disclosure requirements of SEC Rule 15c2-12. As anyone who would...

Everyone Gets a CUSIP! (Unless an Exception Applies.)

Jun 1, 2018 | Disclosure Notes

In an act of generosity a little bit like the famous 2004 episode of the Oprah Winfrey Show (“You get a car! You get a car! You get a car!”), the MSRB recently amended its Rule G-34 to clarify the requirement that placement agents and municipal advisors obtain CUSIPs*...

Welcome to Disclosure Notes!

May 30, 2018 | Disclosure Notes

Disclosure Notes will provide commentary by Gilmore & Bell’s securities group on issues in public finance impacted by securities laws. Gilmore & Bell’s securities group assists the firm’s clients with matters relating to federal and state securities laws...