On May 15, 2017, GFOA filed comments in response to the U.S. Securities and Exchange Commission’s proposed amendments to Rule 15c2-12. The letter reiterates that while GFOA promotes transparency in the market and actively supports activities to ensure that investors have appropriate information about municipal securities, GFOA has significant concerns with the SEC’s proposal.
The letter reminds the SEC that GFOA has a long history of encouraging transparency in the municipal marketplace and urging our members to disclose material events to investors. Accordingly, GFOA supports efforts to ensure that municipal securities information is available to investors. However, the SEC should be aware of the considerable problems associated with adopting multiple changes to Rule 15c2-12 as proposed. The letter articulates why the proposed amendments would be burdensome to issuers, add complication for investors and the general public, and ultimately increase costs to taxpayers and investors. The proposed amendments would create significant administrative and costly burdens to state and local governments. The Federal Liaison center will continue to monitor the proposed amendment’s development and update members accordingly.