Keating Muething & Klekamp PLL is a nationally recognized law firm of approximately 130 lawyers in Cincinnati, Ohio. We deliver sophisticated legal solutions to individuals and businesses of all sizes — from start-up companies to Fortune 50 corporations. While the firm has primarily built its reputation in the tri-state area, including Ohio, Kentucky, and Indiana, our unwavering client-first approach has helped us establish a national and international presence.
Since 1954, KMK Law has been a pillar of the Cincinnati community. The attorneys and staff at KMK Law have dedicated themselves to serving as trusted advisors for private and public companies, nonprofits, charity-focused organizations, and individuals from every walk of life. Whether our counsel is to a multi-billion dollar company, or an individual working to make sure their life’s work is protected for their family and the organizations they support, we are proud and honored to help those clients achieve their aspirations, every time.
On September 13, 2022 the Securities and Exchange Commission filed litigation against four separate municipal securities underwriters for failing to comply with municipal bond offering disclosure requirements.
On September 13, 2022 the Securities and Exchange Commission
filed litigation against four separate municipal securities
underwriters for failing to comply with municipal bond offering
disclosure requirements. The four firms at issue (three of which
have settled with the Commission) sold new issue bonds without
first obtaining required disclosures for investors. Each firm
attempted to rely on an exemption to Rule 15c2-12 known as a
limited offering. In each case, however, the participating
underwriter failed to satisfy the requirements of the limited
offering exemption for continuing disclosure. Among other things,
the underwriters failed to establish a reasonable belief that the
broker-dealers who were purchasing the securities were doing so for
investment purposes, as opposed to resale. The SEC has begun
further investigations of firms relying on limited offering
exemptions and has opened a communication line for self-reporting
and additional information. These recent enforcement actions
highlight the need for underwriters to fully understand their
obligations relating to continuing disclosure, including Rule
15c2-12 and its relevant exemptions.
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