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Continuing Disclosure


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.

Scope of Services

First Southwest Disclosure Services:
• Reviews past continuing disclosure filings and obligations
• Advises on issuer disclosure undertakings
• Monitors certain material events
• Prepares and files material event notices
• Prepares and files annual reports
• Stays abreast of industry regulations

First Southwest uses superior proprietary software to track:
• Compliance status of each issuer
• Annual filing requirements and due dates
• Material events such as rating changes and refunded bonds
• Issuances through conduit issuers

Frequently Asked Questions

Q What are the requirements of U.S. Securities and Exchange and Commission Rule 15c2-12(the "Rule")? Q What is the Central Post Office (CPO)?
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. 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.
 
Q Which municipal debt issuers must comply with the annual reporting aspect of the Rule? Q How often is the issuer required to submit financial information to each NRMSIR?
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.
 
Q Which municipal debt issuers must comply with the material event notification aspect of the Rule? Q When is the issuer required to file notice of a specified material event?
A Any municipal issuers that have issued debt offerings after July 3, 1995. A The issuer must give notice in a timely manner.
 
Q Are there any exceptions or exemptions to the Rule? Q Who are the current NRMSIRs?
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. A Bloomberg Muncipal Repository
DPC Data, Inc.
FT Interactive Data
Standard & Poor's J.J. Kenny Repository
 
Q What happens if the issuer doesn't file?  
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.


Contact Information:
Nora Wittstruck
Vice President
First Southwest Disclosure Services
325 N. St. Paul, Suite 800
Dallas, Texas 75201
214.953.4000
nwittstruck@firstsw.com



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