NOW, THEREFORE BE IT RESOLVED, that the National Association of State Treasurers hereby reiterates and clarifies its positions regarding the following critical issues related to the municipal securities market:
1. NAST opposes preemption of state and local finance authority and state oversight of the debt issuance process through revision or repeal of the Tower Amendment.
2. NAST opposes legislation to subject state and local government issuers to federal disclosure laws and registration of municipal securities with the SEC.
3. NAST opposes legislative and regulatory measures to repeal the exemption of municipal bond interest from Federal and applicable state income taxation, to curtail the use and attractiveness of tax-exempt bonds, and to discourage investment in tax-exempt bonds and opposes any federal legislation that diminishes the value or impairs the use of taxexempt bonds.
4. NAST supported the creation of EMMA and supports expanding the usefulness of EMMA as a central repository
5. NAST encourages and promotes the frequent and timely disclosure of information to the municipal securities market. To this end, NAST is prepared to work with other organizations and associations to better define what financial, operating and other information is relevant and useful to the market recognizing the significant differences of issuers by size, sector and frequency of issuance.
6. NAST opposes any requirements to provide audited financial statements in less than 180 days of the fiscal year-end.
7. NAST supports traditional tax-exempt financing, which should never be reduced or eliminated. To the extent tax credit debt financing programs are extended or created, credits and subsidies should not be reduced or eliminated.
8. NAST supports the regulation of all financial intermediaries in the municipal securities market.
9. NAST supports an independent and equitably funded Governmental Accounting Standards Board (“GASB”). NAST maintains that funding for GASB should come primarily from state and local governments. NAST opposes federal government funding or oversight of the Governmental Accounting Standards Board as well as any direct federal mandates on issuers of municipal securities to comply with GASB accounting standards.
10. NAST supports rating agencies that carry out their commitment to utilize a single rating scale for all debt instruments such that a rating applied to a municipal bond indicates the same credit risk as that same rating applied to corporate bonds, while also recognizing the need for relative ratings amongst municipal issuers. Ratings should measure the ability of an issuer to meet its obligation to investors as promised in the bond documents, such obligation primarily being to pay debt service on time and in full.
NOW, THEREFORE BE IT RESOLVED, that the National Association of State Treasurers opposes preemption of state and local finance authority and oversight of the debt issuance process through revision or repeal of the Tower Amendment or enactment of legislation to subject state and local government issuers to federal disclosure laws.
BE IT FURTHER RESOLVED, that the National Association of State Treasurers supports the self-regulatory structure of the municipal market, and the commitment of all issuers of municipal securities to provide annual financial, operating, and other information in timely manner consistent with federal and state laws and Securities and Exchange Commission rules.
Urging the Internal Revenue Service (IRS): to exempt competitive sales of municipal debt from
any issue price rule; to provide specific guidance on acceptable documentation to be used in
determining market changes and acceptable variances in the offering price under the proposed
alternative method of determining issue price; to establish an efficient process that can quickly
and definitively be executed so as not to hinder the proper sizing of an escrow account on the bond
sale date; and to eliminate enforcement responsibilities for the municipal bond issuer.
With respect to the exclusion of municipal bonds from the High Quality Liquid Asset (“HQLA”) definition, we believe that the proposed rule would impair a long history of U.S. legislative motivation for banks to serve and support the municipal securities market.