Bond lawyers should report an issuer’s failure to comply with its continuing disclosure agreement, no matter how late, because doing so no longer carries a stigma and does not hurt the issuer’s ability to sell the bonds,” panel members said at the National Association of Bond Lawyers Tax and Securities Law Institute here.

Under the Securities and Exchange Commission’s Rule 15c2-12 on disclosure, a dealer cannot underwrite bonds unless it is reasonably assured that the issuer has contractually agreed to disclose financial and operating information annually as well as material event notices when such events occur.

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