May 5, 2017
We applaud the Commission's efforts to increase transparency in the municipal marketplace, and support the voluntary disclosure of bank loans, private placements and debt instruments. However, the term "materiality" should be more specifically defined so as to allow local government management to make a determination without the unnecessary cost of consulting bond counsel or financial advisors. We recommend defining "leases" as used in 11(ii) as limited to long-term capital leases, thus excluding any requirement to report operating leases. Likewise, we recommend striking the proposed paragraph 11(v) "monetary obligation resulting from a judicial, administrative, or arbitration proceeding," as there will often be a monetary obligation even if there is no debt issued to satisfy the obligation. Lastly, we ask that a definition as to what "financial difficulties" are be provided.