Continuing Disclosure Deadline for Bonds

If your school has outstanding bonds, it likely entered into a “continuing disclosure agreement” when the bonds were issued. That agreement requires the school to submit certain “continuing disclosure” documents and information annually to the Municipal Securities Rulemaking Board’s Electronic Municipal Market Access System (EMMA), including the school’s audit and updates to 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.