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Continuing Disclosure Deadline for Bonds


December 14th, 2020

If your school has outstanding bonds, it may have entered into a “continuing disclosure agreement” that requires the school to submit certain “continuing disclosure” documents annually to the Municipal Securities Rulemaking Board’s Electronic Municipal Market Access System (EMMA), including the school’s audit and updated key financial and operating information.

If your school entered into a continuing disclosure agreement as part of a bond transaction and the bonds are still outstanding, school officials should file their an­nual continuing disclosure documents soon. The annual filing deadline depends on the terms of the particular continuing disclosure agreement, but typically falls be­tween December 27 and December 31. We recommend that clients confirm the filing has been completed be­fore recessing for winter break. If a school retains a dis­closure agent, such as a financial advisor, to prepare and submit the annual disclosure filings, school officials should coordinate with that agent well before the deadline to ensure timely filing.