GFOA MCDC Survey

On March 10, 2014, the Securities and Exchange Commission’s Enforcement Division (the SEC) announced the Municipalities Continuing Disclosure Cooperation (MCDC) Initiative to provide issuers and underwriters the opportunity to self-report instances of material misstatements in bond offering documents regarding the issuer’s prior compliance with its continuing disclosure obligations. The initiative incentivized underwriters to self-report, which in turn caused many issuers to be questioned about their prior continuing disclosure compliance. This survey is designed to gather information so that we can estimate the time and costs incurred by issuers responding to the MCDC initiative. To assist in this endeavor, please respond to the following questions by April 3, 2015.

Question Title

* 1. What is the nature of your entity?

State

County

City

Special District

Other, please specify

Question Title

* 2. If you are a state, county or city, what is the population of your jurisdiction?

1,000 or less

1,000 – 5,000

5,000 – 10,000

10,000 – 20,000

20,000 – 50,000

50,000 – 100,000

100,000 – 200,000

200,000 – 400,000

400,000 – 800,000

800,000 – 1,500,000

1,500,000 +

Question Title

* 3. If you are a special district or other type of entity, how many employees do you maintain?

50 or less

50 – 100

100 – 200

200 – 300

300 – 400

400 – 500

500 +

Question Title

* 4. How frequently do you typically issue debt?

One or more times per year

Once per year

Once every few years

Less than once every five years

Question Title

* 5. How much time did your government spend in responding to questions regarding prior continuing disclosure compliance or exploring whether to self-report under the MCDC initiative? Please provide an estimate of hours spent. (For example: 100)

Question Title

* 6. Please provide an estimate of the cost to your government of responding to questions regarding prior continuing disclosure compliance or exploring whether to self-report under the MCDC initiative. In other words, what was the total cost of employee time dedicated to these tasks estimated to the nearest dollar? (For example: 1500)

Question Title

* 7. Did your entity self-report to the SEC under the MCDC Initiative?

Yes

Question Title

* 8. If your entity self-reported under the MCDC Initiative, how much time did your entity dedicate to actually participating in the MCDC initiative? Please estimate to the nearest hour. (For example: 100)

Question Title

* 9. If your entity self-reported under the MCDC Initiative, please provide an estimate of the cost to your government. In other words, what was the total cost of employee time dedicated to these self-reporting under the MCDC Initiative estimated to the nearest dollar? (For example: 1500)

Question Title

* 10. Were you contacted by an underwriter regarding your continuing disclosure compliance?

Yes

Question Title

* 11. Did your underwriters indicate you had failed to comply with continuing disclosure obligations?

Yes