SIFMA White Paper: Considerations Regarding Voluntary Disclosure about Bank Loans (and Whether Certain Bank Loans are Securities)

SIFMA, as part of the Bank Loan Disclosure Task Force, released the attached white paper regarding voluntary secondary market disclosure by state and local government issuers and conduit borrowers about bank loans. The study notes that disclosure about bank loans is not currently required by Exchange Rule 15c2-12, and indicates that the unavailability of such information may be significant.In addition to the principal topic of the study, which is interesting in itself, the study also raises questions (footnote 3) as to whether certain bank loans may be "securities," and, if they are securities, whether the parties involved in the transactions are violating MSRB Rules.

Click here to view white paper in full (links externally to SIFMA website).