Speer Financial Services

Continuing Disclosure Requirements

The Rule
Rule 15c2-12 of the Securities Exchange Act of 1934 requires that issues of certain municipal securities issued after July 3, 1995, and not otherwise exempt from the Rule, to agree in writing when those securities are issued, to provide certain information to the market place for the life of the issue. The information that is agreed to be provided on a continual basis is commonly referred to a continuing disclosure. Under the Rule, it is unlawful for a municipal securities broker/dealer to act as an underwriter of an issue of municipal securities unless the broker/dealer has reasonably determined that the issuer, or its designated agent, has undertaken in a written agreement to provide such continuing disclosure. Information relating to continuing disclosure is to be provided to the marketplace through nationally recognized municipal securities information repositories (NRMSIRs).

What Information Must Be Disclosed?

Audited financial statements;
Annual financial information, which includes updated information from any offering or disclosure document prepared in connection with and used for the securities that have been issued; and
Material events, including:
1. Principal and interest payment delinquencies;
2. Non-payment related defaults;
3. Unscheduled draws on debt service reserves reflecting financial difficulties;
4. Unscheduled draws on credit enhancements reflecting financial difficulties;
5. Substitution of credit or liquidity providers, or their failure to perform;
6. Adverse tax opinions or events affecting the tax-exempt status of the security;
7. Modifications to the rights of security holders;
8. Bond calls;
9. Defeasances;
10. Release, substitution or sale of property securing repayment of the securities; and
11. Rating changes.

Who Must Comply?
For purposes of the Rule, issuers include almost all governmental units that can issue tax exempt bonds and any “obligation persons” as defined by the Continuing Disclosure Rule. Issuers with less than $10,000,000 in outstanding bonded indebtedness have less stringent continuing disclosure requirements.

What Type of Municipal Securities are Exempt?
Certain small issues, short-term issues, private placements with a limited number of sophisticated investors, and issues with certain tender optims may all be exempt from the Rule

Continuing Disclosure Services Provided by Speer Financial
Speer Financial, Inc. provides continuing disclosure services, as dissemination agent, to approximately 125 clients of varied types under a separate hourly contract for this service.

Disclosing material events are the responsibility of issuers.

Speer Financial, Inc. electronically submits the clients disclosure document to the municipal securities information repositories (NRMSIRs) or the central Post Office (Disclosure USA) prior to the due date, 180-210 days after the close of the client’s fiscal year.

Disclosure requirements vary by security.

Security	Typical Tables
General Obligation Bonds	- Retailers Occupation Tax, if applicable - Property Assessment and Tax Information - Debt Information - Financial Information
Revenue Bonds	- System Data - System Debt - System Financial Information
Special Service Areas/ Special Assessments	- Area Debt Information - Area Tax Information
Installment Contracts/ Debt Certificates	- Same as General Obligation Bonds