i.5.1.2 Disclosure Policies

Disclosure policies should provide specific guidance on who, how, and when the issuer will provide ongoing disclosures as required by SEC Rule 15c2-12.30 These disclosures fall into two groups: (1) updates, additions, and amendments to information originally presented in the OS and subject to the issuer’s continuing disclosure agreement and (2) material event notices.

Disclosure policies are designed to ensure the accuracy of the issuer’s disclosures and its compliance with all applicable federal and state securities laws, and to promote best practices regarding disclosures. Disclosure policies and procedures should address who, what, when, and how information is to be released to the market with the intent to:

Identify the information that must be disclosed on a continuing basis.

Create a schedule for disclosures.

Establish a full list of events that must be reported.

Create procedures to gather the information, validate the information, and approve its release.

Designate roles and responsibilities that control the release of information.

The policies may also address the development and review of the policies, a timeline for the review of the policies, a training program to inform key staff of the procedures and their responsibilities under the policy, and measures to retain and track documents.31