The deadline for municipal issuers and obligated persons to self-report to the Securities and Exchange Commission (SEC) under its Municipal Continuing Disclosure Compliance (MCDC) Initiative any recent misstatements in primary offering documents concerning secondary market disclosure compliance is December 1, 2014. Underwriters have already submitted their reports, and their action may affect the issuer’s decision. Given the need to launch a factual audit of the recent disclosures and past compliance, and then undertake a careful analysis and consultation with counsel on issues of materiality, the December 1 deadline will be here before we know it.

Now is the time to reach out to a member of Ballard Spahr’s Municipal Securities Regulation and Enforcement Group to determine how you can take advantage of applicable settlement terms of the MCDC program. Whether you have been questioning what you should disclose, or even if you haven't thought about it, we are here to help. Issuers and obligated persons who have not yet undertaken this analysis are urged to do so now.

The Group helps municipal market participants navigate a rapidly evolving regulatory, investigative, and enforcement environment, enabling them to anticipate and address compliance issues and respond effectively to investigations when necessary. For more information, please contact M. Norman Goldberger at 215.864.8850 or, John C. Grugan at 215.864.8226 or, William C. Rhodes at 215.864.8534 or, or Tesia N. Stanley at 801.517.6825 or

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This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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Municipal Securities Regulation and Enforcement
Public Finance
Securities Enforcement and Litigation