Annual Disclosure Reports: Unlike some disclosure/dissemination agent services, Accu-Disclose, LLC does not provide issuers with templates to complete on their own. Accu-Disclose has the ability and resources to create, compile and file all analytical tables and reports on the issuer’s behalf. In addition, should certain information not be available at the time filing, Accu-Disclose will submit a Failure to File Notice on behalf of the issuer.
5-Year Look Back & Disclosure Summary: As a Dissemination Agent/Disclosure Specialist, Accu-Disclose acts as a liaison between the Municipal Securities Rulemaking Board (“MSRB”) and the issuer. Services include the timely dissemination and filing of documents to MSRB’s Electronic Municipal Market Access (“EMMA”) system for the life of the bonds including the Annual Disclosure Report, Audit, Draft Audits (if necessary) and Event Notices. Accu-Disclose provides the issuer with a Comprehensive 5-Year Look-Back & Disclosure Summary of all disclosure filings for the past five years including EMMA confirmations and a link to the publications on EMMA. This comprehensive summary can be provided to potential investors as proof of compliance.
Event Filing Notices: In addition to the Annual Disclosure Reports mentioned above, other continuing disclosures provide notification of specific events that may have an effect on repayment of a bond such as principal and interest payment delinquencies, bond calls and defeasances, to name a few. There are 16 mandatory Rule 15c2-12 disclosures that require Event Filing Notices should they occur and 10 additional/voluntary disclosure events.
Monitoring of Ratings: Also pursuant to Rule 15c2-12, it is mandatory that the issuer monitor all of its bond and insurer ratings. In the event of a rating change, the issuer is responsible for posting a notice to EMMA within 10 business days of the rating change. Accu-Disclose tracks ratings, and in cooperation with the issuer and/or its municipal advisor, posts such notice to EMMA on the issuer’s behalf.
Review of Offering Documents: Accu-Disclose, in cooperation with the issuer’s municipal advisor and/or bond counsel, will review the offering documents (Preliminary & Final Official Statement and Continuing Disclosure Undertaking Agreement) to ensure the issuer’s obligations are correctly reflected in each of the documents.
Continuing Disclosure Policy/Procedures: Should the issuer decide to implement and adopt policies and procedures regarding Continuing Disclosure Requirements, Accu-Disclose will develop a comprehensive guide for such procedures.
Additional Services: Accu-Disclose can show issuers how to access the EMMA website for all current and prior financial information by issuer name or CUSIP number. This website provides access to a database of documents available to anyone at no charge. In addition, Accu-Disclose will send the issuer e-mail ticklers which support compliance through the issuance of reminders of due dates. Upon request by the issuer or its municipal advisor, Accu-Disclose will forward the Comprehensive Disclosure Summary to the Trustee, Bond Counsel or other individuals.