The City of Harrisburg, the Hershey Trust Co., and the Milton S. Hershey School have implemented reforms in two separate cases that placed all three entities under the scrutiny of government regulators and law enforcement.

The City has agreed to settle charges of securities fraud, in which the U.S. Securities and Exchange Commission alleged that the City misled bond investors about its financial health in various financial statements and a mayoral address. Two days later, state Attorney General Kathleen Kane said her office was ending a multiyear investigation into allegations of financial improprieties at the Hershey Trust Co. and the school.

In an analysis of the Harrisburg case, Ballard Spahr attorneys William C. Rhodes and Tesia N. Stanley noted that a “significant number” of municipal bond issuers fall short of total disclosure compliance. They said municipalities “struggling to remain solvent” should be especially careful about timely and complete disclosures.

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Public Finance