SIFMA and Other Associations Submit Comments to SEC on Structure of MCDC

SIFMA, the Government Finance Officers Association, the National Association of Bond Lawyers and the Bond Dealers of America (the "Associations") submitted comments to the SEC regarding concerns with the current structure of the Division of Enforcement's Municipal Continuing Disclosure Cooperation Initiative ("MCDC").

The Associations provided the SEC with suggestions for modifications to the program in order to "maximize MCDC's potential to improve disclosure compliance, to increase participation in the initiative, and to provide the most accurate set of responses to the SEC," including:

• adjusting MCDC's five to ten year look-back period to transactions where official statements were published after March 2012, and limiting MCDC to annual filings after 2009, to determine whether or not issuers have made materially inaccurate statements in offering documents regarding prior continuing disclosure compliance; and
• extending the end date of MCDC from September 9, 2014 to March 10, 2015. According to the Associations, the current deadline does not provide sufficient time for issuers and underwriters to communicate, coordinate, and compare findings from their separate compliance investigations prior to the September 10, 2014 deadline.

See: Associations' Comment Letter.