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Your Advocacy Committee has determined that we should file comments on the pending SEC Rule 15c2-12 proposed revision and the MSRB proposal on CUSIP numbers. Below are brief descriptions of the notices, a blog by one of my NY partners and a BB article. If you have any thoughts about the content of the comments, particularly the effects on conduit financings, please provide them to me, Chuck Samuels, directly.
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The Congressional Municipal Finance Caucus sent this letter to House Ways & Means Chairman Kevin Brady (R-TX) and Ranking Member Richard Neal (D-MA) on March 8, 2017, urging that any reform of the tax code protect the current treatment of tax-exempt municipal bonds. The letter was signed by 156 members of congress, many of them obtained from our efforts with authorities individually. This bipartisan letter was signed by 95 Democrats and 61 Republicans. The letter notes that:
“Nearly two-thirds of core infrastructure investments in the United States are financed with municipal bonds. In 2015 alone, more than $400 billion in municipal bonds were issued to finance the projects that touch the daily lives of every American citizen and business. They are the roads we drive on, schools for our children, affordable family housing, water systems that supply safe drinking water, courthouses, hospitals and clinics to treat the sick, airports and ports that help move products domestically and overseas, and, in some cases, the utility plants that power our homes, businesses, and factories. These are the pro-growth investments which spur job creation, help our economies grow, and strengthen our communities.” The letter states that any changes to the tax code should recognize the vital role of tax-exempt municipal bonds and that any changes to the tax exempt status should be provided very careful consideration. If your representative did not sign the letter, this would serve as a good leave behind for any Capitol Hill meetings you plan during Spring Conference in April; and of course, if your representative did sign the letter we’ll want to thank them during our Hill visits in April. Not affected by the Presidential executive orders freezing regulatory action(as an independent agency),on March 1, the Securities and Exchange Commission voted to propose amendments to Rule 15c2-12, with the goals of improving investor protection and enhancing transparency in the municipal securities market.
The proposed amendments to Rule 15c2-12 add two event notices to Continuing Disclosure Agreements. First, issuers and obligated persons must disclose information on the incurrence of alternative financings, including bank loans, direct placements, and similar obligations, and terms of such financings. Second, issuers and obligated persons must disclose any default or termination events with regard to those alternative financings. Acting Chairman Piwowar said the changes would “empower investors by improving their access to current information about the financial obligations incurred by municipal issuers.” The public comment period will remain open for 60 days following publication of the proposing release in the Federal Register. |
AuthorCharles A. Samuels Archives
December 2019
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