SEC enforcement

The updated FAQs offer "important insights about recordkeeping requirements related to new issue pricing," NAMA Executive Director Susan Gaffney said.

"Nothing motivates enforcement staff more than protecting those who invest their savings in our markets," said David Woodcock, director of the SEC's Division of Enforcement.

Prepay energy borrowings may not generate promised savings.

"It's hard to know whether a decrease in enforcement is a statistical blip or early evidence of [a] meeker, milder FINRA in the current era," said Benjamin Edwards, an associate dean at UNLV law school.

"I find this a very encouraging appointment," Peter Chan, a partner at law firm Baker McKenzie, said of Woodcock's appointment.

Jeffrey Puzzullo is the fourth person to plead guilty in the now-notorious Legacy Cares case.

"This split enforcement action is unconstitutional and unlawful," their opening brief said.

It could signal the issuer did not get the best price during a negotiated deal, officials said.

"I don't think this topic is necessarily gaining traction as an enforcement matter," said Andrew Kintzinger, counsel at Hunton Andrews Kurth LLP.

It's the first time the regulator has named VRDO rate-resetting process as an area of review.

The final judgment in the case was filed Dec. 10 in the U.S. District Court for the Southern District of New York.

Fippinger teamed up with co-authors Peg Henry and Ernesto Lanza for "The Securities Law of Public Finance (Fourth Edition)."

The decline in muni enforcement actions is part of a broader trend at the SEC.

"It shows the chairman's understanding of the practical realities of firms...," Peter Chan, a partner at Baker McKenzie said.

"Going forward, the staff will provide the other side with at least four weeks to make Wells submissions," SEC Chairman Paul Atkins said in a recent speech.

"It is a big problem across the board with all types of deal participants perhaps venturing into unregistered MA activity," said Susan Gaffney.

Stradling clients "were fortunate to receive proactive contact from SEC staff to reschedule imminent matters leading up to the shutdown," said Kathleen Marcus, a partner at Stradling.

"If the open jacket policy is actually implemented—which we in the defense bar hope is the case—it would be a welcome reform," one attorney said.

An SEC investigation "is not a litigation," said Kathleen Marcus, a partner at Stradling Yocca Carlson & Rauth.

Sanchez cited affordable housing and "project-based" types of transactions as areas "where we are seeing … lawyers more openly engaging in structuring that might be problematic."