Rule 15c2-12 and Potential Updates to the Rule
SIFMA submitted a whitepaper to the Securities and Exchange Commission (SEC) on SEC Rule 15c2-12 Whitepaper to offer a current perspective on the existing framework for provision of disclosure in the municipal securities market, the relative burdens placed upon municipal market participants by that framework, and opportunities for improvement in framework structure and guidance interpreting application and compliance.
OVERVIEW
This Rule 15c2-12 Whitepaper has been prepared by the Securities Industry and Financial Markets Association (“SIFMA”) to offer a current perspective on the existing framework for provision of disclosure in the municipal securities market, the relative burdens placed upon municipal market participants by that framework, and opportunities for improvement in framework structure and guidance interpreting application and compliance. The Whitepaper begins with a review of the history of Rule 15c2-12 up to and including the ongoing MCDC initiative. Potential revisions to the Rule and topics for new or revised guidance as to compliance with the Rule are then discussed. The Whitepaper concludes with an invitation to the Commission for dialogue and a request for action.