8.2.3 Recordkeeping and Reporting

8.2.3 Recordkeeping and Reporting

As noted by GFOA, records necessary to document compliance should be maintained for the required time periods.127 In addition, state or local record retention requirements need to be considered. In some cases, an issuer may need to amend its record retention policy in order to keep tax or other records for periods longer than otherwise required by state law for non bond related documents. See Section 8.3.6, Recordkeeping and Retention.

In general, an issuer of municipal debt must also meet disclosure requirements that help enable the underwriters of the issuer’s securities to comply with federal securities laws, including SEC Rule 15c2-12 (See Section 8.4, Continuing Disclosure). The GFOA noted that incorporating robust disclosure practices and demonstrating a solid disclosure track record will benefit an issuer by encouraging regulatory compliance and by enhancing credibility among investors, credit rating agencies, and the public.128