First Southwest Company is one of the only financial advisory firms in the
nation to offer a separate, full-time staff dedicated to helping municipal
clients meet the industry’s increasingly important continuing disclosure
requirements.
With one of the most experienced continuing disclosure staffs in the industry,
First Southwest Disclosure Services professionals are well versed in all
aspects of the municipal bond industry. First Southwest files nearly 600
reports for more than 500 clients annually.
First Southwest is one of the few practices in the industry to actively help
clients meet the requirements set forth in U.S. Securities and Exchange
Commission Rule 15c2-12. First Southwest works closely with clients to prepare
and file the appropriate reports, while most other services only disseminate
the required information.
First Southwest Disclosure Service’s timely and accurate filings help ensure
issuers continued access to capital markets, and more importantly, a low cost
of financing.
| Q |
What are the requirements of U.S. Securities and Exchange and Commission Rule
15c2-12(the "Rule")?
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Q |
What is the Central Post Office (CPO)?
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| A |
The Rule requires non-exempt municipal debt issuers to provide
certain financial information, including audited financials as well as prompt
notice of specified material events to each Nationally Recognized Municipal
Securities Information Respository ("NRMSIR") and State Information Repository
("SID"), when required.
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A |
The CPO, located at www.disclosureusa.org, serves as a free, internet-based,
single filing location that distributes filings to each NRMSIR and SID, if any.
The Muni Council requested the creation of the CPO to improve the annual
disclosure filing process.
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| Q |
Which municipal debt issuers must comply with the annual reporting aspect of
the Rule?
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Q |
How often is the issuer required to submit financial information to each
NRMSIR?
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| A |
Any municipal issuer who has more than $10 million in oustanding
debt and has issued a least one debt offering in the par amount of $1 million
or more after July 3, 1995, or any municipal issuer that has undertaken to
disclose certain information in its offering document. |
A |
Issuers must file financial information annually. Issuers generally update the
required information within 6 to 9 months of their fiscal year end.
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| Q |
Which municipal debt issuers must comply with the material event notification
aspect of the Rule?
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Q |
When is the issuer required to file notice of a specified material event?
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| A |
Any municipal issuers that have issued debt offerings after July
3, 1995.
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A |
The issuer must give notice in a timely manner.
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| Q |
Are there any exceptions or exemptions to the Rule?
|
Q |
Who are the current NRMSIRs?
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| A |
Yes, there are several. For a copy of the Rules, please go to
www.sec.gov, or contact Beth Bankhead at 214.953.4003.
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A |
Bloomberg Muncipal Repository
DPC Data, Inc.
FT Interactive Data
Standard & Poor's J.J. Kenny Repository
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| Q |
What happens if the issuer doesn't file?
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| A |
The underwriter is prohibited from buying the issuer's bonds until
the issuer is in full compliance with the Rule. Repeat offenders of continuing
disclosure requirements risk not being able to access the capital markets.
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