The MSRB provided additional support to help market participants comply with SEC amendments to Exchange Act Rule 15c2-12 that require municipal securities issuers and obligated persons to disclose material financial obligations to investors. The compliance date of the amendments is February 27, 2019.
The MSRB emphasized the importance of fulfilling these obligations through the MSRB Electronic Municipal Market Access ("EMMA") platform.
The MSRB explained that:
- the amendments to Rule 15c2-12 add two additional events for continuing disclosure agreements entered into after February 27, 2019;
- the adopted amendments define the term "financial obligation" to mean (i) a debt obligation, (ii) a derivative instrument entered into in connection with a debt obligation, or (iii) a guarantee of a debt obligation or derivative instrument entered into in connection with a debt obligation;
- disclosure must be made no more than 10 business days after the occurrence of the event;
- the process for submitting additional event disclosures to EMMA is the same as submitting disclosures for the current event types;
- market participants will be asked to provide a description, date and other information with respect to the additional event disclosures;
- market participants will be required to "associate securities to the additional event disclosures";
- documents uploaded to EMMA must satisfy all MSRB standards for submission; and
- voluntary disclosures of bank loans can be submitted to EMMA.
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