Government Command Center 15 items
Municipal Bond Continuing Disclosure (SEC Rule 15c2-12) Checklist
Helps a municipal issuer or obligated person meet continuing disclosure undertakings by filing annual financial information and material event notices to the MSRB's EMMA system.
SEC Rule 15c2-12MSRB EMMASEC Rule 10b-5
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Continuing Disclosure Undertaking (CDU)
- Has each series of outstanding bonds subject to Rule 15c2-12 been inventoried with its CUSIPs? *
- Is a copy of each Continuing Disclosure Undertaking/Agreement on file? *
- Does the CDU specify the annual filing deadline and the required financial/operating data? *
- Has a designated compliance officer / dissemination agent been assigned? *
Annual Financial Information Filing
- Was the annual financial information filed to EMMA by the deadline in the undertaking? *
- Were audited financial statements filed when available (or unaudited then audited)? *
- Do the annual operating data / tables match the categories promised in the CDU? *
- Were filings correctly linked to all affected CUSIP-9 numbers on EMMA? *
Material Event Notices
- Are procedures in place to file listed material event notices within 10 business days of occurrence? *
- Are the two 2018-added events (financial obligations incurrence; default/acceleration on such obligations) monitored? *
- Were any rating changes, defeasances, or principal/interest payment delinquencies filed? *
- Were failure-to-file notices posted when an annual filing was late? *
Anti-Fraud & Recordkeeping
- Have disclosures been reviewed to ensure no material misstatements or omissions? *
- Are dated confirmations/receipts from EMMA retained for each filing? *
- Has staff been trained and are policies periodically reviewed for accuracy? *
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