On July 31, the Securities Exchange Commission (SEC) announced
modifications to its Enforcement Division's Municipalities
Continuing Disclosure Cooperation Initiative (Initiative). In an
effort to encourage as much participation as possible in the
Initiative, the SEC has extended the self-reporting deadline for
issuers and obligated parties, established tiered caps on civil
penalties, and offered to consider "reasonable, good faith and
documented efforts" to identify potential violations, even if
those violations are not discovered until after the expiration of
the Initiative.
For issuers and obligated persons, the SEC has extended the
self-reporting deadline from September 10, 2014, to December 1,
2014. The extension will provide issuers and obligors with more
time to complete their reporting requirements and allows issuers
time to consult with their underwriters and make determinations
regarding appropriate next steps. The self-reporting
deadline remains unchanged