Resources / Disclosure Notes
Gilmore Bell’s insight and commentary on securities law and disclosure issues in public finance. Please subscribe in the sidebar to receive future posts by email.
Following an August 2018 rule change by the Securities and Exchange Commission, municipal issuers, conduit borrowers and other “obligated persons” will be required to file an event notice with EMMA for the incurrence of certain material “financial obligations” and for...read more
The recent amendments to SEC Rule 15c2-12 (the “Rule”), which must be incorporated into continuing disclosure undertakings effective on or after February 27, 2019, have caused municipal underwriting firms to review existing due diligence processes and procedures. In...read more
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...read more
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.read more
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…read more
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*...read more