October 29, 2018

Rule 15c2-12 Amendments: Next Steps to Be Ready for the February 27, 2019 Compliance Date

Rule Amendments

Beginning February 27, 2019 (the “Compliance Date”), issuers of state and municipal bonds (and other obligated persons) will be required to include two additional notice events in new undertakings to provide continuing disclosure pursuant to Securities and Exchange Commission (the “SEC” or “Commission”) Rule 15c2-12 under the Exchange Act of 1934 (the “Rule”).[1] The Rule currently requires an underwriter to determine, prior to purchasing bonds, that an issuer and/or other obligated person has undertaken to provide continuing disclosure to bondholders in the form of annual financial information and notice of certain listed events via emma.msrb.org.

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[1] For more information, our prior alert announcing the amendments is available here.