MIAMI BEACH - It is unreasonable to expect state and local governments to file material event notices when the ratings on their bonds are downgraded because the ratings of the insurers that backed their bonds are lowered, Frank Hoadley, chairman of the Government Finance Officers Association's debt management committee, said here yesterday.

Speaking at the annual conference of the National Federation of Municipal Analysts, Hoadley, Wisconsin's capital finance director, argued that the requirements of the Securities and Exchange Commission's Rule 15c2-12 on disclosure places an impossible burden on issuers in such circumstances.

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