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Bond Accountability Commission 2 Recommendations Page 37

emerging market for direct subsidy QSCBs—with new types of investors—highlights both the importance and feasibility of investor meetings for such Bond offerings. The meetings would signify that CMSD values investor perspectives, would allow CMSD to inform investors about CMSD 37 and to respond to investor questions, and would afford CMSD an opportunity to identify investor concerns to which CMSD could respond.

MSRB Financial Disclosure Incentives The Municipal Securities Rulemaking Board (“MSRB”) recently proposed to offer to municipal securities issuers, such as CMSD, a number of voluntary financial disclosure incentives. If accepted by CMSD, those financial disclosure incentives would lead to special recognition by the MSRB on its new EMMA website 38 of those issuers, such as CMSD, accepting one or more of the incentives. The EMMA website clearly is well on its way to becoming the central information vehicle in the municipal securities market. While one of the incentives is controversial—commitments to deliver audited financial statements within 120 days following the end of fiscal years (with an option for 150 days on a temporary basis to December 31, 2013)—the others have not drawn widespread issuer objections. Especially when attempting to attract new investors, as would be the case with taxable bonds, CMSD should be aware that many investors in taxable securities                                                             37

Any “material” information, however, should be made available to all investors and the market simultaneously. The MSRB’s new EMMA disclosure platform will accept supplemental filings, and provides an important vehicle for communications with investors. This is another area within which CMSD would benefit from continuing advice of its Bond Counsel and Financial Advisors.


The EMMA website is located at

BAC2 Recomendations Final 04062010