[Cobo] FW: SEC notice

[Mauck, Sheri]

Please see the information attached as it may pertain to certain bond issuances at your campus.  Please take the time to review and take action if required.

From: James Joseph [mailto:jjoseph at oksba.org]
Sent: Friday, August 01, 2014 9:05 AM
To: Mauck, Sheri
Subject: SEC notice

Sheri -

Attached is an announcement from the SEC that extends the deadline for filing of missed disclosure notices.  Please circulate to the campus business officers or others, as you deem appropriate.

Jim


James C. Joseph
Oklahoma State Bond Advisor
405-602-3100
jjoseph at oksba.org<mailto:jjoseph at oksba.org>

Sheri -

Attached is some information on the SEC's Municipalities Continuing Disclosure Cooperation Initiative (MCDC).  This is an enforcement program related to issuer's failure to fully comply with the notice requirements contained in their Continuing Disclosure Agreements (CDAs).  The question is whether, under Rule 15-c2-12, issuers have accurately disclosed whether they are in compliance with all of the filing/notice requirements under past CDAs.

The most common violation that has been identified is the failure by issuers of insured bonds to post the required notice of a rating downgrade of the bond insurance company (there were multiple downgrades of these companies, as you know).  This is just an example and the initiative is much broader in its scope, encompassing any failure to post a require notice.

For those issuers who self-report prior non-compliance, a settlement option does exist that will protect the entity from charges or fines.  As noted in the attachment, that option is available until September 10, 2014.

I don't know how much the State's colleges and universities know about this program, but it might be helpful if you could share this attachment with all of the business officers.  For most, there is probably little exposure.  However, some may need to do substantial research to ensure that their bond issues are not subject to this enforcement action.

Please let me know if you have any questions.  Thanks.

Jim


James C. Joseph
Oklahoma State Bond Advisor
405-602-3100
jjoseph at oksba.org<mailto:jjoseph at oksba.org>

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