Resources for Developing Disclosure Documents

The following municipal market organizations provide educational reference material for municipal securities issuers preparing initial and ongoing disclosure documents about their municipal securities. The resources listed below are not intended to represent an exhaustive list of disclosure guidance produced by municipal market organizations, nor does the provision of links to these resources constitute an endorsement of any of the material contained therein or a rejection of resources produced by other organizations.

The MSRB takes no responsibility for the content contained on any site to which it provides links and exercises no control over any changes that may occur to the content on those sites. The MSRB does not make any guarantee with regard to these resources’ accuracy, completeness or suitability. These resources should not be construed as legal or financial advice and users should seek appropriate legal or other professional advice to address specific facts and circumstances. Compliance with the guidance suggested in these disclosure resources does not guarantee compliance with the federal securities laws. 

Government Finance Officers Association (GFOA)
The purpose of the GFOA is to enhance and promote the professional management of governments for the public benefit by identifying and developing financial policies and best practices and promoting their use through education, training, facilitation of member networking, and leadership. 

GFOA recommended best practices identify specific policies and procedures as contributing to improved management, including disclosing pension-related obligations in official statements, using a website for disclosure and understanding continuing disclosure responsibilities. View best practices related to:

• Debt Management
• Primary Market Disclosure
• Post-Issuance Policies and Procedures
• Understanding Bank Loans

National Association of State Auditors, Comptrollers & Treasurers (NASACT) 
NASACT is an organization for state officials who deal with the financial management of state government. NASACT’s membership is comprised of officials who have been elected or appointed to the office of state auditor, state comptroller or state treasurer in the 50 states, the District of Columbia, and U.S. territories.

NASACT's “Voluntary Interim Financial Reporting: Best Practices for State Governments” outlines ten best practices to be implemented by states on a voluntary basis to augment their existing disclosure programs.

National Federation of Municipal Analysts (NFMA) 
The NFMA is a not-for-profit association with over 1,200 members throughout the U.S. with a professional focus on the creditworthiness of municipal bonds.

NFMA issued best practices on disclosure of agreements related to direct purchase bonds, bank loans and other bank-borrower agreements. Download Recommended Best Practices in Disclosure for Direct Purchase Bonds, Bank Loans and Other Bank-Borrower Agreements (pdf).

NFMA best practices in disclosure are tailored to particular sectors of the market, including tax-supported debt, housing revenue bonds, water and sewer transactions, toll road financings, and variable rate debt, among others. View NFMA disclosure guidelines here.

National Association of Bond Lawyers (NABL) 
NABL exists to promote the integrity of the municipal market by advancing the understanding of and compliance with the law affecting public finance.

NABL's white paper on crafting written disclosure policies provides practical considerations for drafting policies and highlights the benefits, as well as risks, of written disclosure policies. Download Crafting Disclosure Policies (pdf).

NABL created a Pension Disclosure Task force that produced guidance regarding the application of the federal securities laws to the preparation of official statement disclosure addressing the pension funding obligations of state and local gov\u00adernments to their public defined benefit pension plans. Download Considerations in Preparing Disclosure in Official Statements Regarding an Issuer’s Pension Funding Obligations (pdf).

A Bank Loan Disclosure Task Force, comprised of NABL, NFMA, GFOA, the American Bankers Association, Bond Dealers of America, the Investment Company Institute, the National Association of Health and Educational Facilities Finance Authorities, the National Association of Independent Public Finance Advisors and the Securities Industry and Financial Markets Association, produced an analysis of considerations in making voluntary secondary market disclosure about bank loans. Download Considerations Regarding Voluntary Secondary Market Disclosure about Bank Loans (pdf).

Securities and Exchange Commission (SEC)’s Office of Municipal Securities  
The SEC’s Office of Municipal Securities coordinates the SEC’s municipal securities activities and works closely with the municipal securities industry to educate state and local officials and conduit borrowers about risk management issues and foster a thorough understanding of the SEC’s policies. The office provides continuing disclosure resources.