Proposed Amendments Relating to Municipal Securities Disclosure

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed amendments to Rule 15c2-12 under the Securities Exchange Act of 1934 relating to municipal securities disclosure, Release No. 34-60332; File No. S7-15-09. The proposed amendments would: 1) delete the current exemption from the continuing disclosure obligations of the Rule that exists for demand securities; 2) require that notice of certain events be filed with the Municipal Securities Rulemaking Board (MSRB) within ten business days after the occurrence of the event; 3) remove a materiality standard for certain events that must be reported to the MSRB; 4) require the disclosure to the MSRB of certain adverse tax events under a continuing disclosure agreement (CDA); and 5) require disclosure to the MSRB of tender offers for municipal securities; the occurrence of bankruptcy, insolvency, receivership or similar events regarding an issuer or obligated person; the merger, acquisition or consolidation of an obligated person or the sale of all or substantially all of the assets of the obligated person; and the appointment of successor or additional trustee or a name change of a trustee, if material.