by Christopher B. Langhart on June 11, 2014
The recent Municipalities Continuing Disclosure Cooperation Initiative is the latest action taken by the SEC to enforce the continuing disclosure obligations of municipal issuers.
Since an SEC 2012 report on the municipal securities market, in which the SEC highlighted both inadequate disclosure and shortcomings in current disclosure practices, the SEC has increased its regulatory focus on continuing disclosure by municipal issuers. The SEC has subsequently brought a series of enforcement actions, as summarized below, that set precedents in SEC enforcement and illustrate that agency’s resolve to address the issue of municipal disclosure.
An administrative proceeding by the SEC against the City of Harrisburg, Pennsylvania was the first time where the SEC charged a municipality for making misleading statements outside of its securities disclosure documents. The SEC charged Harrisburg with securities fraud for making misleading public statements in a state of the City address, the City’s budget report, and in certain annual and mid-year financial statements. Furthermore, all these statements were made while the financial condition of the City was deteriorating and the publicly available financial information was either stale or incomplete.
The first instance where the SEC assessed a financial penalty against a municipal issuer was when the Greater Wenatchee Regional Events Center Public Facilities District in the state of Washington, paid a $20,000 penalty after the District defaulted on approximately $41,000,000 of bond anticipation notes it had issued to finance a multi-use arena and ice hockey rink. The SEC found that the official statement for the notes was false and misleading because it stated that no independent review of the financial projections in the official statement had been made when in fact such reviews had been made, that the official statement failed to state that the projections had been questioned and revised, and that municipal support for the project was constrained by limitations on debt capacity. Additionally, the underwriter Piper Jaffray and Co. and its lead banker were required to pay penalties of $300,000 and $25,000, respectively, for violating the securities laws.
In a West Clark Community Schools proceeding in the state of Indiana, the SEC charged the School District with securities violations for claiming in a 2007 official statement for a bond offering, that “in the previous five years, the school district has never failed to comply, in all material aspects, with any previous undertakings…” In fact, the School District had prepared an official statement in 2005 for a bond issue and subsequently entered into an undertaking to provide annual information for such bonds. However, the School District had never provided any annual information from 2005 to 2010. Additionally, as in the Greater Wenatchee proceeding above, a separate administrative proceeding was brought against the underwriter City Securities and its lead banker, wherein City Securities agreed to pay nearly $580,000 to settle the SEC charges, and the lead banker of City Securities agreed to an industry bar for one year and a permanent supervisory bar for violating the securities laws.
Finally, in 2013, the SEC charged the City of Miami and its budget director with securities fraud in connection with several bond offerings and other disclosures made to the investing public. The SEC also charged the City with violating a 2003 cease and desist order entered against the City for similar conduct. This was the first time the SEC sought injunctive action against a municipality under an existing SEC cease and desist order.
The proceedings above are instances where, for the first time, the SEC (i) charged a municipal issuer with making materially misleading statements outside of disclosure documents, (ii) imposed financial penalties against a municipal issuer, (iii) charged a municipal issuer with making false statements about continuing disclosure to bond investors in an official statement, and (iv) charged a municipal issuer with violating an existing cease and desist order.
These are just a sample of recent SEC enforcement actions. Taken as a whole, they illustrate the agency’s emphasis on ensuring that municipal issuers comply with their disclosure and continuing disclosure requirements when issuing municipal obligations. This underscores the need for municipal issuers to analyze their past continuing disclosure undertakings and determine whether they are in compliance with such undertakings. If non-compliance issues arise, then further thought must be given to participating in the SEC’s Municipalities Continuing Disclosure Cooperation Initiative in order to avoid becoming the subject of an SEC enforcement action like the ones listed above.
by Christopher B. Langhart on April 10, 2014
Recently the Securities and Exchange Commission (SEC) announced the implementation of the Municipalities Continuing Disclosure Cooperation Initiative (MCDCI), a program enacted to “address potentially widespread violations of the federal securities laws by municipal issuers and underwriters”—specifically, the continuing disclosure requirements required of them by SEC Rule 15c2-12.
The MCDCI allows both municipal issuers and underwriters to self-report possible violations involving materially inaccurate statements in an Official Statement that had addressed prior compliance with an issuer’s continuing disclosure requirements. Issuers and underwriters who wish to participate must self-report by September 10 of this year. Self-reporting is done by completing the SEC questionnaire and emailing it to MCDCsubmissions@sec.gov, or by faxing or mailing the questionnaire to the SEC.
New Jersey issuers, as part of their continuing disclosure requirements, typically contract to provide annual financial information consisting of audits, adopted budgets, and certain economic, demographic, and statistical information within 180 to 270 days after the end of an issuer’s fiscal year. Underwriters are under an obligation to reasonably determine that an issuer has been in compliance with its prior continuing disclosure requirements for the past five years. The advent of the Electronic Municipal Marketplace Access website (EMMA) has made it easier for investors, issuers, underwriters, and regulators to review and verify the materials submitted by an issuer as part of its continuing disclosure requirements—and has made it easier to identify omissions and misstatements relating to an issuer’s continuing disclosure requirements.
So, if an issuer has stated in a final Official Statement that it has been in compliance with all required disclosure undertakings for the past five years, when in fact the issuer is not in compliance, the issuer must now seriously weigh self-reporting this non-compliance to the SEC against known, standardized settlement terms for such violation. The issuer must also consider that if it does not self-report such violation, the underwriter might. Therefore, communication between issuers and underwriters would be desirable to avoid one party’s self-reporting a violation and the other party’s not doing so. In such an instance, the non-reporting party runs a significant risk of incurring more severe penalties for failing to report the disclosure violation, which is now presumably known to the SEC.
Issuers who participate are subject to non-monetary penalties and will be obligated to implement policies and procedures to ensure compliance with current and future continuing disclosure requirements. Underwriters are subject to financial penalties and implementation of similar policies and procedures, as set forth in the SEC press release. However, self-reporting continuing disclosure violations through the MCDCI is intended to provide more favorable settlement terms to issuers and underwriters than if such violations were to be discovered independently by the SEC. The SEC has also indicated that it will seek increased penalties and sanctions against issuers and underwriters who do not participate in the MCDCI and are found to be non-compliant with continuing disclosure requirements.
The MCDCI is the latest in an ever increasing list of actions taken by the SEC to more stringently enforce the continuing disclosure requirements of municipal issuers and underwriters. Such actions include assessing penalties against municipal issuers, imposing fines against underwriters, and requiring the implementation of policies and procedures by issuers to ensure compliance with current and future continuing disclosure requirements.
The municipal community is still analyzing the import of the MCDCI and its implications. However, it is clear that municipal issuers and underwriters need to closely examine their own municipal issuances to determine what, if any, action needs to be taken to comply with both past statements and current practices relating to their individual continuing disclose requirements, and to determine whether any violations of continuing disclosure requirements exist and should be reported to the SEC.
In upcoming posts, we’ll look at the cases that have led the SEC to implement the MCDCI and the practices that an issuer can implement to ensure continuing disclosure compliance.
by Matthew D. Jessup on July 24, 2013
Editor’s Note: The following was written by Edward J. McManimon, a partner and founder of McManimon, Scotland & Baumann, LLC. Ed wrote the following after repeated requests for his views from various State organizations and media outlets.
On July 18, 2013, the City of Detroit, Michigan filed for bankruptcy under Chapter 9 of the U.S. Bankruptcy Code. This is, by far, the largest municipal bankruptcy in U.S. history.
After years of blindly spending itself into insolvency while the State of Michigan stood by with little or no oversight and after trying to cram down settlements with bondholders and other “unsecured” creditors, Detroit determined that it was a “responsible act” to file for bankruptcy, rather than work out, with the help of the State, a way to recast the City’s obligations so that City creditors and retirees would be paid.
Some have characterized the bankruptcy filing as the best of all worlds. Michigan’s Governor seemed to think that filing for bankruptcy was a well thought out strategy, after he installed an aggressive interim administrator at the City to basically set the stage for bankruptcy rather than explore other more responsible actions with the State’s resources and the State’s energy to reorganize the obligations of the City.
It is very hard to accept the actions of the City and the State of Michigan, when so many more responsible options were available to the State over the past several years. For the State to pat itself on the back for pushing bankruptcy is foolish and certainly irresponsible.
This action should significantly and adversely affect not only the credit of the City, but also the State of Michigan, as the State failed miserably to guard the financial condition of the municipal governments like the City that provide the services to the residents of the State. The City certainly seemed willing and the State seemed comfortable with the City borrowing and spending money for projects and services that it obviously couldn’t afford; only now to have the costs of those projects and services borne by creditors rather than the City or State themselves.
To suggest, as Michigan’s Governor seems to be doing, that bondholders bought the credit of the City and not the credit of the State of Michigan ignores the very basic responsibility that the State has to ensure that local governments that the State creates to provide services to its residents do so in a responsible manner. Unless this action has a consequence to Detroit and to Michigan, it could spiral down and affect the credits of all general obligations bonds, including the State of New Jersey and its municipal issuers.
This result would be entirely unjust considering the very strong and continued oversight at the State level in New Jersey and the equally strong statements made by our Governor and the Director of the Local Finance Board that there would be no bankruptcies of any local governments of New Jersey under their watch. The actions and oversight of New Jersey’s Governor, the Director and the State back that up.
I can’t image the State of New Jersey doing what Michigan did or allowing it to be done. The State certainly would have stepped in a long time ago to analyze the problem and craft a solution that would completely avoid a filing for bankruptcy and respect the obligations any New Jersey municipality incurred.
So, while it may be viewed in some circles as a well thought out strategy by Detroit and the State of Michigan, that does not make it right or a financially responsible move.
by Matthew D. Jessup on March 6, 2013
The talk-of-the-town the past two weeks in Washington DC and around the country has been about sequestration. You can’t turn on the television or “open” a newspaper on your iPad without hearing about it. The federal budget cuts that took effect March 1, 2013 affect defense spending, air traffic controllers, and now even tours at the White House.
One impact not widely publicized is that on the governmental issuer of municipal bonds and, more specifically, Build America Bonds, or BABs. Sequestration has cut by 8.7%, the direct pay subsidy expected by local government issuers of BABs. That means any local government issuer of BABs should expect an 8.7% reduction in the “BAB revenue” it is likely anticipating in its 2013 budget.
BABs were created by the federal government in 2009 as part of the American Recovery and Reinvestment Act. Though many types of BABs were created, most New Jersey local governments (and governments country-wide) issued “direct pay” BABs – taxable bonds to fund tax-exempt projects at taxable interest rates, with a 35% interest rate subsidy paid back to the local government issuer by the federal government. The 35% subsidy was meant to lower the taxable debt service to comparable debt service on a tax-exempt issue. In total, $3.351 billion of direct pay BABs are affected by the sequestration cuts.
In New Jersey, issuers of BABs are required by the Division of Local Government Services to budget the full taxable debt service payment on BABs in the budget, as if the local government would not receive any subsidy. However, the local government issuer is then permitted to anticipate the 35% subsidy payments as a revenue in the same year’s budget. As a result, New Jersey local governments will feel the effect of sequestration on the revenue side of the budget and not on the “outside-the-cap” debt service side.
Many BABs were issued with special redemption features that allow the issuer to refund its BABs in the event of an adverse tax action, such as a reduction in the subsidy. As interest rates generally are lower today than they were in 2009 and 2010, issuers of BABs should consult with their professionals to determine the viability of issuing traditional tax-exempt refunding bonds to refund BABs for a debt service savings. Perhaps the State Local Finance Board might even consider approving refundings of BABs that produce less than the standard 3% present value savings, particularly if the sequestration cuts to the subsidy end up being the first in a series.
Issuers of BABs will still be required to submit to the IRS their form 8038-CP 45 days prior to the interest payment date. The IRS will, temporarily, process the reduced subsidy payments by hand, but anticipates no delay in sending them out. Perhaps an indication of whether the sequestration cuts to BABs are here to stay, the IRS expects that it will have an automated system for processing the reduced payments by mid-April.
by Christopher B. Langhart on August 3, 2012
Municipal Securities Rulemaking Board (“MSRB”) Notice 2012-25 (the “Notice”) was approved by the SEC on May 4, 2012 and took effect on August 2, 2012. The Notice sets forth the responsibility of underwriters of municipal securities to make certain disclosures to an issuer, to ensure that they have dealt fairly with that issuer.
Specifically, the Notice states that an underwriter must disclose to the issuer that:
(i) Rule G-17 requires an underwriter to deal fairly at all times with both municipal issuers and investors;
(ii) the underwriter’s primary role is to purchase securities with a view to distribution in an arm’s-length commercial transaction with the issuer and it has financial and other interests that differ from those of the issuer;
(iii) the underwriter does not have a fiduciary duty to the issuer under the federal securities laws and is therefore not required by federal law to act in the best interests of the issuer without regard to its own financial or other interests;
(iv) the underwriter has a duty to purchase securities from the issuer at a fair and reasonable price, but the underwriter must balance that duty with its duty to sell municipal securities to investors at prices that also are fair and reasonable; and
(v) the underwriter will review the official statement for the issuer’s securities in accordance with, and as part of, its responsibilities to investors under the federal securities laws, as applied to the facts and circumstances of the transaction.
The Notice also makes clear that the underwriter must not recommend that an issuer not retain a municipal advisor.
Compensation is addressed in that an underwriter must disclose to the issuer whether underwriting compensation will be contingent on the closing of a transaction. If so, the underwriter must disclose that such compensation presents a conflict of interest, because an underwriter could conceivably recommend a transaction that is unnecessary or larger than necessary. Typically an underwriter does not get paid unless a transaction is completed, so it is likely this disclosure will be necessary in almost every transaction.
The basic intent of the Notice appears to be to emphasize that the underwriter is a party to a business deal and is not always the issuer’s ally. However, the underwriter is acting no differently than in past deals, and this flurry of disclosure requirements has come about solely due to the changes in Rule G-17.
An issuer can expect to receive initial disclosure representations at the beginning of a transaction, but certain additional disclosures may be required at later times within a transaction, especially for more complex transactions. Since the Notice requires that an issuer acknowledge receipt of such disclosures, an issuer can expect to be requested to sign an acknowledgment of receipt of the disclosure representations of an underwriter. However, by acknowledging or signing for such receipt, the issuer is acknowledging only that it has received and read the representations and is not making a contract with the underwriter or in any way binding the issuer to continue the transaction.
The Notice states that all written and oral representations made by an underwriter to an issuer must be truthful and accurate and not misrepresent or omit material facts—which conduct might be expected anyway—and that an underwriter must have a reasonable basis for its statements and any prepared materials. For example, an underwriter cannot represent that it has the requisite knowledge or expertise with respect to a transaction, if the personnel who will work on the transaction don’t have such knowledge or expertise. This is important to think about during the RFP and RFQ processes.
The requirements detailed in the Notice raise potential issues that need to be thought about in every transaction going forward, especially because the Notice appears to be a harbinger of the stricter regulation of municipal securities transactions that seems all but inevitable.
by Matthew D. Jessup on July 18, 2012
The Local Finance Board (Board) has released a questionnaire for all municipal and county applicants seeking approval of the Board to:
1. Long-term finance tax appeals;
2. Long-term finance certain emergencies; and
3. Issue bonds pursuant to a non-conforming maturity schedule.
The four-page questionnaire is being used by the Board to help assess whether the applicant has made prior efforts to “prepare for a reasonably forseeable financial challenge” and whether the applicant has “made substantial efforts to control spending.” The questionnaire asks project-specific questions (“When did the applicant become aware of the underlying issue?” “What appropriation and other steps has the applicant taken to provide for the financial exposure?”) and more general operational questions (“Do elected officials receive compensation?” “Are there any shared service agreements in place?”).
The message being sent by the Board to potential applicants is clear from the questionnaire – don’t look for us, the Board, to provide financial relief unless you, the Applicant, have already made substantial efforts on your own.
This message can best be applied to an applicant seeking long-term financing of tax appeals. A municipality or county seeking to finance prior years’ tax appeals, that has not been providing funds via a reserve for tax appeals in the budgets of prior years or the current year, is not likely to be favorably reviewed by the Board.
The questionnaire should be reviewed by all municipalities and counties and used as a guidebook in managing potential financial exposures. Municipalities and counties seeking any of the approvals referenced above should be prepared to complete and file the questionnaire simultaneous with filing their application with the Board.
A complete copy of the questionnaire can be found here.
by Matthew D. Jessup on January 19, 2012
It’s no secret that municipalities have been hit hard by the ongoing recession. One source of significant financial stress is the amount of money that municipalities are required to pay to residents as a result of tax appeals. As real estate values continue to decline, successful tax appeals continue to rise, forcing municipalities to pay significant judgment amounts out of an ever-declining surplus. Municipalities currently have a few tools to finance these tax appeal judgments, including by refunding bond ordinance or by a series of emergency appropriations that are later taken out by refunding bond ordinance.
Municipalities have now been given yet another tool to assist with this ongoing struggle with tax appeal refunds. Yesterday, Governor Christie signed into law A-3971/S-3110, which states, among other things, the following:
Any municipality that has ended the previous budget year with a deficit in operations caused, whether in whole or in part, by obligations created from tax appeals, may issue notes with the approval of the Local Finance Board on such conditions as the Local Finance Board deems appropriate. The amount of notes authorized pursuant to this provision shall not exceed the cash payments or tax credits due to tax appeals and shall be authorized by a bond ordinance approved by the Local Finance Board.
I’m calling this one the “Do Over Bill”, as in “Those municipalities that didn’t finance tax appeals last year by refunding bond ordinance or pay tax appeal amounts through emergency appropriations, now get a do over.” This opportunity at a “do over” could not have come at a better time. In this economic environment, rating agencies are concerned more than ever before with the level of surplus held by municipalities. This new law gives municipalities a chance to restore surplus and stave off the probable ratings downgrade that would have otherwise followed.
Similar to the Local Finance Board’s recently announced criteria for financing tax appeal credits, to me it’s a shame that this new law allows a municipality to issue these new Tax Appeal Notes only if the municipality’s previous budget year ended with a deficit in operations. If Town A spends $3 million on tax appeals in a given year and ends up with $10,000 in surplus in operations, Town A does not qualify under the new law and cannot issue new Tax Appeal Notes to help restore surplus. But if Town B spends the same $3 million on tax appeals and ends up with a $5,000 deficit, Town B gets to recapture and rebuild all $3 million in surplus through the issuance of these new Tax Appeal Notes.
Perhaps over time, the Local Finance Board can find a way to ease the “deficit” requirement. In the meantime, if your municipality finds itself starting 2012 with a deficit created in part by tax appeals, there is now a mechanism to help right the ship.
by Matthew D. Jessup on December 15, 2011
Yesterday, the Local Finance Board (Board) took the first step in establishing a new rule that would allow municipalities and counties to issue refunding bonds and capture debt service savings on an expedited basis. This is a significant development, as timing is everything when it comes to refundings, particularly in this volatile economic market.
The Board has adopted a resolution approving a proposed rule that would allow municipal and county issuers to issue refunding bonds to refund outstanding long-term bonds without the prior approval of the Board, as long as certain conditions are met. Currently, municipalities and counties must appear before the Board for approval after introduction and before final adoption of a refunding bond ordinance. Because the Board accepts applications and meets only once per month, the current procedure can result in a 30 to 45 day delay – plenty of time for interest rates to rise and opportunities to decrease debt service to vanish.
The proposed conditions are as follows:
Upon closing on a refunding bond issue, an issuer will need to file a certification with the Board that details that the above conditions were met, with appropriate back-up and an itemized accounting of the costs of issuance of the refunding bonds.
An overwhelming majority of the refunding transactions completed by municipalities and counties meet the above conditions. Accordingly, most issuers will receive the significant benefit of being able to enter the bond market quickly without any additional burdens. Any issuer that was going through the process of authorizing a refunding bond issue at the end of 2010 knows how quickly interest rates can rise and certainly can appreciate the benefit this proposed rule provides.
The Board’s proposed rule is subject to a 60-day comment period and additional action prior to becoming final. During that time period, issuers will still need to make application to the Board for approval to issue refunding bonds.
by Matthew D. Jessup on September 30, 2011
The Division of Local Government Services indicated today that municipalities may, for the first time, finance with refunding bonds or notes the amount owed to a taxpayer as a result of a successful tax appeal and applied as a credit against future taxes to be paid by such taxpayer (taxpayer credits). Previously, municipalities were able to finance only the amount actually paid by the municipality by check back to the taxpayer.
Specifically, the Division will allow municipalities to finance 3/4 of the amount of taxpayer credits. The logic is that, even though the entire taxpayer credit is being given to the successful taxpayer in the 4th Quarter, that taxpayer credit is a product of the overpayment made by the taxpayer in Quarters 1, 2 and 3.
This, of course, presumes that the tax appeal is settled after the 3rd Quarter tax payment is made by the taxpayer. It is unclear whether a tax appeal settled after the 2nd Quarter but prior to the 3rd Quarter would result in only 2/4 of the credit being eligible for financing.
But, there’s no such thing as a free lunch.
Approval by the Local Finance Board to finance taxpayer credits comes with four conditions:
1. The municipality must show that, absent financing the taxpayer credits, the municipality would end the fiscal year with a deficit in operations (this would be a projected deficit, since the Local Finance Board’s approval of these financings must occur no later than the November Local Finance Board meeting).
This condition is unfortunate. Those municipalities that have large amounts of taxpayer credits but do not meet this condition will be forced to spend their surplus funds instead of financing the taxpayer credits over several years. In this economic environment, with rating agencies already downgrading municipal credits at alarming levels, this unnecessary use of surplus will be a “credit negative” (to use a rating agency phrase) and lead to increased costs of borrowing for municipalities.
2. The municipality may finance tax appeal credits only one time. Choose your year wisely.
3. The municipality will be required to undertake a revaluation or reassessment, as appropriate.
4. The municipal governing body must adopt a resolution acknowledging that all new hires through the end of the next succeeding fiscal year be approved by the Division.
Municipalities will be required to complete a Division-issued form asking a series of questions regarding each new hire, including who is being hired, at what compensation, whether the hire will be civil service, why the hire is taking place (someone’s retiring, new position, etc.). The Division will scrutinize each new hire thoroughly.
This is not a perfect solution, as noted above. In addition, it is troubling that each municipality may finance taxpayer credits only once. Even if a municipality immediately undertakes a revaluation or reassessment, those procedures take time, and the intended effect of eliminating or drastically reducing the number of tax appeals won’t be felt the next year. The municipality will likely have the same taxpayer credit problem in the next year, with no real, viable solution.
That said, the inability of municipalities to finance taxpayer credits over a multi-year period was putting enormous financial pressure on many municipal budgets. The Division’s solution will go a long way towards eliminating one of many financial pressures faced by municipalities.
by Matthew D. Jessup on August 8, 2011
In today’s municipal bond market, your credit rating is more important than ever. Underwriters and financial advisors say that the difference between an “A” rating and a “AA” rating can mean the difference of 30 basis points or more. Such a difference can result in interest rate savings of $315,000 on a $10,000,000 20-year general improvement bond issue. In refunding transactions, 30 basis points can mean the difference between achieving the State-required 3.00% present value savings (and capturing debt service savings) and falling short (and letting bondholders keep your money).
That said, not every municipality is blessed with a healthy general fund balance, a wealthy tax base and a full “cap bank” under the 2% Property Tax Cap Act. After recently meeting with one rating agency and participating in ratings calls with both ratings agencies week after week, it occurred to me that there are three easy ways every municipality can immediately improve its standing with the rating agencies.
First, establish written policies regarding (1) use and regeneration of General Fund balance, (2) long-term capital improvements and (3) issuance of short- and long-term debt. Your municipality likely already has “informal” or “understood” policies regarding these topics, but they’re not written down. Simply putting them to paper (and, even better, having them adopted by the governing body by resolution) shows the rating agencies that all members of the administration are in agreement and that the policies will survive departing finance officers and administrators and provide continuity.
Second, complete and update revenue and expenditure forecasting on a monthly or quarterly basis. Continuous updates to a 12- or 18-month projection will better prepare a municipality to anticipate and react to future revenue decreases or expenditure increases. Revisit prior forecasts and identify and use historic trends to help prepare future forecasts. Preparing and updating these forecasts, being prepared to discuss each item and meeting the projections consistently are all indications to the rating agencies of a strong management team.
Third, provide monthly or quarterly financial reports to the Mayor and governing body. Use the revenue and expenditure forecast discussed above to prepare a “projected versus actual.” Many municipalities already prepare similar reports but fail to share them with the Mayor and governing body. Keeping everyone informed is another characteristic of a strong management team.
Your municipality likely implements one or more of these three suggestions in an informal way. It is a short step-up to make them formal in a way that satisfies the rating agencies. The effort will be minimal and the result could be significant.
Both Moody’s Investors Service and Standard & Poor’s publish their rating methodologies. I encourage everyone to read through them for more details on what the rating agencies are looking for when assigning a rating to your municipality.
Moody’s – General Obligation Bonds Methodology
Standard & Poor’s – General Obligation Bonds Methodology