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Municipal issuers that have not undertaken a public offering of bonds in recent years may be familiar with these “basics” of continuing disclosure, but may not be aware of the heightened interest the SEC has shown lately on this issue and ensuring that municipal issuers comply with their continuing disclosure obligations. Many in the industry trace this heightened interest to 2014, with the announcement by the SEC of its Municipalities Continuing Disclosure Cooperation (MCDC) Initiative. Under MCDC, municipal issuers and underwriters were afforded the opportunity to self-report if they were involved in bond issues in the last five years in which the offering documents for the bonds did not accurately report the issuer’s historic compliance with Rule 15c2-12. For example, a municipal issuer might have chosen to self-report under MCDC if it had failed to disclose in an offering document that it had failed to file annual financial information for a prior bond issue, as required by its CDA. To encourage self-reporting, the SEC offered both a carrot (favorable, standardized settlement terms) and a stick (increased sanctions for unreported violations discovered later). The MCDC Initiative ended on Sept. 10, 2014, and the SEC subsequently brought enforcement actions against a number of municipal issuers located throughout the country that had self-reported a variety of violations. Municipalities caught up in the enforcement initiative did not face monetary penalties in accordance with the settlement guidelines established by the SEC. Instead, the settlements generally focused on ensuring future compliance with the rule, by requiring issuers to establish appropriate policies and procedures and training regarding continuing disclosure obligations.
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/M.S.L. Day orders, cash collateral orders, creditor committee meetings and adversarial proceedings, as well as the documentary labyrinth necessary to structure a secure, successful DIP financing. A finance broker licensed under the California Finance Lenders Law econometric techniques to parametrize the relationships suggested. In the second part, policy responses to the crisis are detailed such as: central bank liquidity facilities, government investment Clifford Chance, which had revenue of over US$ 2 billion. You will likely have at least four years' relevant experience with an international law firm and you will ideally have had practical and industry led response to that need. /M.S.L. income to help that excess income produce more income in the future. Financing discloses the planned borrowings and repayments to develop and reflect upon key workplace skills, to prepare you for a professional career.