WHY CONTINUING DISCLOSURE IS IMPORTANT

A complete timely record of compliance with disclosure obligations is essential to preserve a competitive market for issuer securities.

Since the implementation of SEC Rule 15c2-12 (the “Rule”), dealers are prohibited from underwriting certain municipal securities unless the issuer has obligated to comply with a Continuing Disclosure Agreement (CDA). The Rule codifies the information to be filed annually, as well as the sixteen (16) events which must be recorded (disclosed) on Electronic Municipal Market Access (EMMA) within ten (10) business days of occurrence.

Issuers often turn to third party disclosure services for help.

First Security Disclosure streamlines the aspects of maintaining compliance with the Rule. Required documents, operating data and event notice filings are posted, and a clear, concise presentation of adherence to disclosure obligations is provided.

Assist clients with maintaining compliance to make their municipal offerings attractive to investors.

Unlike other service providers, First Security Disclosure will provide timely reminders to clients and follow up with obtaining required documents and data to maintain compliance. All necessary documents are filed in a timely manner to allow the client to remain in compliance with its CDA obligations.

CONTINUING DISCLOSURE SERVICES

Review

Assess the status of disclosure filings within the statutory 5-year window for all relevant issues along with all postings on EMMA and provide a report of findings.

Record

Post on EMMA relevant audited financials, required documents, operating data and event notice filings.

Report

Provide electronic confirmation of filings made on EMMA for issuer files. Reports can be shared at the issuer’s discretion and included when preparing language for representations of compliance in future offering documents.