Client Alert
The Commission’s recent Cease-and-Desist Order against the City of Harrisburg found that post-issuance financial information made available by the City and public statements made by City officials contained material misstatements and omissions, and violated the antifraud provisions of the federal securities laws. The Order raises a number of continuing disclosure concerns for issuers and obligated persons in municipal bond transactions, including potential antifraud liability for issuers, obligated persons and their officers and employees. In its companion Report of Investigation, the Commission calls upon all issuers to adopt comprehensive policies and procedures to promote timely, accurate and complete disclosures.