March 22, 2016


06.06.17 – NAST & SDMN Submits Formal Comments to the SEC

The Securities and Exchange Commission (“Commission” or “SEC”) has published proposed amendments to the Municipal Securities Disclosure Rule (Rule 15c2-12) under the Securities Exchange Act of 1934 (“Exchange Act”) that would amend the list of event notices that a broker, dealer, or municipal securities dealer (collectively, “dealers”) acting as an underwriter in a primary offering of municipal securities must reasonably determine that an issuer or an obligated person has undertaken, in a written agreement or contract for the benefit of holders of the municipal securities, to provide to the Municipal Securities Rulemaking Board (“MSRB”).


03.09.17 – Hultgren, Ruppersberger Joined by More Than 150 in Bipartisan Effort to Protect Municipal Bonds

As Congress prepares to take on the issue of comprehensive tax reform, Congressmen Randy Hultgren (IL-14) and C.A. Dutch Ruppersberger (MD-02), Co-Chairmen of the Congressional Municipal Finance Caucus, have again sent a bipartisan letter to leaders of the House Ways and Means Committee in support of a critical tool that helps local and state governments finance new roads, schools, hospitals, fire stations and more. Also signed by 154 of their colleagues (95 Democrats, 61 Republicans total), the letter asks leadership to reject any proposal to cap or eliminate the deduction on tax-exempt municipal bonds used to finance the vast majority of infrastructure projects in America’s communities.


11.16.16 – MSRB Strategic Priorities Comment Letter

NAST continues to support the development of Electronic Municipal Market Access (EMMA). Transparency and timely disclosure of relevant information in the municipal securities market is in the best interest of all participants. NAST is constantly working 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. We understand that the Government Finance Officers Association (GFOA) has submitted its own comments regarding the MSRB’s Strategic Priorities document. In working with GFOA, we have decided to make some similar suggestions for EMMA improvement.


10.21.16 – LGIP Guidelines Cover Letter

Please find enclosed your requested copy of Voluntary Guidelines for the Management of Stable Net Asset Value (NAV) Local Government Investment Pools (LGIPs). These guidelines were prepared as a joint effort between the National Association of State Treasurers (NAST) and the National Association of State Auditors, Comptrollers and Treasurers (NASACT). NAST and NASACT represent both elected and appointed government officials who have the responsibility of overall management of state finances, including investment of state and local government funds.


09.20.16 – Senate Banking Letter

For more than 100 years, tax-exempt bonds have been the primary financing mechanism for state and local infrastructure projects. These critical infrastructure tools have provided essential funding for states, counties, and localities across the nation. In face, three-quarters of all public infrastructure projects in the U.S. are built by state and local governments utilizing the public-private partnership embodied in these bonds.


06.02.16 – IRS Comment on Political Subdivisions

The IRS has proposed new Treasury Regulations to redefine the qualifications to be a “political subdivision” for tax-exempt bond purposes. To be a political subdivision, an entity must meet each of three requirements of (i) having one or more sovereign powers, (ii) being constituted and operated for a governmental purpose, and (iii) being subject to governmental control.  The proposed regulations call into question the status of special districts, authorities, commissions and other entities that have been created by state and local governments. If adopted in its current form, the proposed regulations will have an adverse impact on the ability of many governmental issuers to issue tax-exempt obligations. We are in accord with the continued application of the sovereign powers requirement, but we have serious concerns with the governmental purpose test and have a number of questions about the governmental control test.


06.02.16 – MSRB Comment Letter

The National Association of State Treasurers (NAST) and its affiliate State Debt Management Network (SDMN) has reviewed the MSRB’s Request for Comment on a Concept Proposal to Improve Disclosure of Direct Purchases and Bank Loans as published on March 28, 2016. We continue to fully support timely disclosure of information that would be material to investors. However, after careful consideration and dialogue within the membership, we strongly oppose this proposal and believe that its implementation would misrepresent the responsibilities of issuers and serve only to magnify the problem of incomplete disclosure.


03.02.16 – Municipal Bond Letter to Congress

As leaders in state and municipal government, we are writing to stress the importance of maintaining the current tax exemption for municipal bonds. It has been estimated that at the combined state and local levels, we must spend $3.6 trillion by the year 2020 to meet our infrastructure needs, and the importance of building and maintaining our public infrastructure has never been more apparent.1 Tax exemption of interest on municipal bonds was implemented more than 100 years ago at the dawn of the U.S. income tax system, and we strenuously oppose any reduction or elimination of this tax exemption. Any such change will inhibit our ability to make critical infrastructure investments. Proposals to change this commitment to tax-free municipal bonds would not only be costly for state and local taxpayers, but also result in fewer projects, fewer jobs and further deterioration of our infrastructure.


10. 20. 15 – Regarding The 2015 Re-Proposed Regulations Related To The Determination Of “Issue Price” In The Arbitrage Rules Under Section 148 Of The Internal Revenue Code

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.


09. 28. 14 – Preserving and Enhancing the Tax Exempt Status of Mutual Bonds

NOW THEREFORE BE IT RESOLVED, that the National Association of State Treasurers hereby 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 tax-exempt bonds.


01. 31. 14 – Comment Letter On Liquidity Coverage Ratio

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.


10. 15 .13 – Critical Issues Related To The Municipal Securities Market

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:


10. 14. 13 – Resolution Opposing Repeal Of The Tower Amendment

Repeal or amendment of the Tower Amendment could lead to substantial increases in the issuance costs for state and local governments.


10. 07. 13 – State Treasurers On The MSRB

NOW, THEREFORE BE IT RESOLVED, that the National Association of State Treasurers urges the Municipal Securities Rulemaking Board to continue to include state treasurers on the Board in order to make sure the governmental community is appropriately represented on the Board.




Wall Street Journal –  Washington Battles Over Munis: Safe or Hard to Sell?

Wall Street Journal –  Hundreds of Local Officials Defend Municipal-Bond Tax Exemption

Bond Buyer – Muni Finance Caucus Launched in House

The Hill – Bipartisan House Pair Launches Municipal Finance Caucus

Politico – State, local officials urge lawmakers to keep tax exemption for muni bonds