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ARTICLE · 04 AUGUST 2014

SEC Modifies MCDC Initiative To Encourage Participation

On July 31, the Securities Exchange Commission announced modifications to its Enforcement Division's Municipalities Continuing Disclosure Cooperation Initiative.

United StatesGovernment, Public Sector

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

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