i.5.1.3 Investor Relations Policies
In addition to making required disclosure in compliance with SEC Rule 15c2-12, an issuer is likely to have intermittent communications with investors, the market, and the community about its debt. Policies that guide these communications can help to ensure that valid and consistent information is shared. The policies should identify the roles responsible for communicating, the procedures for the review and approval of communications, and a system to track such communications. Staff responsible for these communications should be trained annually, if not more often, on securities laws as they relate to public communications.
The MSRB Electronic Municipal Marketplace Access (EMMA) System offers issuers the opportunity to set up an investor website. The GFOA maintains that an investor website can make “disclosure information more accessible” and help to “improve the efficiency of the municipal market” and “possibly lower borrowing costs by improving access to information relevant to determining the credit quality of an issuer’s bonds.”32
An investor website has several advantages, including offering:
- An efficient and low-cost means of distribution
- The simultaneous, controlled release of information
- Lower costs and broader reach as compared to traditional investor relations programs used by most issuers to respond to investor inquiries.
The use of an investor website poses risks to issuers who fail to develop it properly or keep it current. Disclosures that are incomplete, late, stale, or incorrect may constitute violations of securities laws or commitments made to bondholders. The GFOA has published its Best Practice recommendations to help issuers avoid these pitfalls.33