Issuers undertake to provide ongoing information to the market, and enforcement for failures has been active.
Annual reports. Financial information and operating data of the type included in the official statement, filed with the central repository within a stated period after the fiscal year end, together with audited financial statements when available.
Event notices within ten business days, covering payment delinquencies, defaults, unscheduled draws on reserves, rating changes, defeasances, tender offers, bankruptcy, mergers, and — added by amendment — the incurrence of financial obligations and agreements to covenants or events of default that materially affect security holders.
Financial obligations include direct purchases, bank loans and leases, which many issuers did not previously disclose and which are now a common source of late filings.
Failure to file. Must be disclosed in future official statements, and a pattern of late filings affects market access and pricing.
Antifraud exposure. Official statements and continuing disclosures are subject to the antifraud provisions, and enforcement has addressed misleading statements about pension liabilities, budget balance and prior compliance.
Practical compliance. A disclosure calendar, a designated officer, a written policy and procedures, and training — which are themselves the subject of enforcement expectations.