Annual financial information
The annual filing must include audited financial statements (when available) and the specific operating-data tables named in the undertaking — all present, or the package does not release.
The most rigorous continuing-disclosure filing engine a municipal issuer can use.
DisclosureKeeper assembles a documentation-complete annual filing package — every required operating-data table, every material-event notice, every EMMA submission — checked against the exact language of each continuing-disclosure undertaking before a public-finance specialist releases it.
Every undertaking parsed against SEC Rule 15c2-12Sixteen listed material events, including Events 15 & 16ACFR table extraction · CDU checklist · EMMA filingPublic-finance reviewer release on every package5-business-day SLA
Why filings fail
A single missed filing can jeopardize your next bond offering.
Every municipal bond carries a permanent obligation: under SEC Rule 15c2-12, issuers must file annual financial information, specific operating-data tables, and timely material-event notices to MSRB EMMA for the life of the bonds. Miss a filing, and the next official statement must disclose the failure — a red flag that can delay or derail a new issuance.
Most mid-market issuers — school districts, water authorities, small cities — have one or two finance staff, no securities specialist, and a continuing-disclosure undertaking written in dense legal language. The ACFR lands months after year-end, and nobody has translated the undertaking into a checklist. Filings slip not because the data doesn't exist, but because the process is manual and unforgiving.
DisclosureKeeper exists to close that gap with a single, exhaustive standard applied identically to every file.
188 days
median time to post annual financials in 2018 — far beyond the deadline
The benchmark
Measured against the letter of each undertaking — and SEC Rule 15c2-12.
We do not summarize the law and hope. Every filing is scored against a versioned rule pack tied to the exact text of the issuer's continuing-disclosure undertaking and the SEC rule. These are the provisions each package is held to.
Operating-data tables
Each table required by the undertaking is extracted from the ACFR, reconciled to prior-year figures, and verified against the undertaking's description.
Material-event notices (16 events)
All sixteen listed events, including the 2019 additions (Events 15 & 16 — financial obligation and default events), are monitored and filed within 10 business days.
Event 15 & 16 monitoring
New financing documents are scanned for triggers of material financial obligations or default events, with a 10-business-day clock started upon occurrence.
Five-year compliance representation
The package includes a verified record of all filings over the prior five years, supporting the issuer's representation in the next official statement.
EMMA submission & audit trail
Every filing is submitted to MSRB EMMA with a complete audit trail, including the undertaking checklist, source documents, and reviewer sign-off.
How a package is built
Intake to specialist release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human public-finance specialist signs every release. That order is never reversed.
01
EMMA Compliance & Five-Year Look-Back Scan
Upload the issuer's existing EMMA history and CDUs. We return a free gap report: which filings are missing, which undertakings are not being met, and what is needed for the next official statement.
02
CDU parsing & checklist build
As your authorized clerical agent, we parse the continuing-disclosure undertaking and build a filing checklist tied to each specific requirement — no assumptions, no summaries.
03
ACFR table extraction & reconciliation
The required operating-data tables are extracted from the new audited ACFR, reconciled to prior-year figures, and cross-checked against the undertaking.
04
Deterministic completeness gates
Every table is present; every material-event trigger is checked; the 10-business-day clock is verified; the five-year compliance record is complete. Any failure blocks release.
05
Public-finance specialist release
A public-finance analyst reviews the exception queue and signs the release. High-value or complex undertakings route to attorney review first.
06
Delivery
You receive the filing package: draft annual filing, material-event notices, evidence log, EMMA submission checklist, and audit trail — ready for the issuer's authorized officer to certify and submit.
The bar we hold
Rigor you can measure.
100%
Specialist-released
No package ships without a human signature.
5 days
Standard SLA
From complete intake to released package.
<1%
Critical-defect target
Tracked against a gold-standard package library.
16
Material events monitored
All SEC Rule 15c2-12 listed events, including Events 15 & 16.
Why DisclosureKeeper
Built to be the most thorough option an issuer has.
Documentation-complete, by design
The deliverable is completeness itself — every undertaking element and filing accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.
In its lane, on purpose
We prepare documentation and run searches as your clerical agent. We never give legal advice, certify filings, or make compliance representations on your behalf.
Engagement
Flat fee, per annual package, per event notice, per monitoring subscription. No hourly billing, ever.
Simple, predictable, and aligned with a documentation standard — not a cut of any bond proceeds.
- A free EMMA Compliance & Five-Year Look-Back Scan before you commit — see exactly what is missing.
- One flat fee per annual filing package; per material-event notice; per-issuer annual monitoring subscription.
- Optional fixed-fee attorney review for complex undertakings or high-value issuances.
- Optional Sale Continuity Add-on for the advertisement and sale-day exhibits, pre-dated to your 60-day window.
FAQ
Questions, answered precisely.
Is DisclosureKeeper a law firm?
No. DisclosureKeeper, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex undertakings or high-value issuances.
Do you certify the filing or make compliance representations?
Never. DisclosureKeeper prepares the filing package and submits it to EMMA as your clerical agent. The issuer's authorized officer must certify and submit the filing. We do not make compliance representations on your behalf.
What makes a package 'complete'?
Completeness is defined by the undertaking and SEC Rule 15c2-12: every required operating-data table present, every material-event notice filed within 10 business days, the five-year compliance record verified, and all source documents reconciled. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released package. The free EMMA Compliance Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
Flat fees per annual filing package, per material-event notice, and per-issuer annual monitoring subscription. No hourly billing and no contingency.
See what's missing before it costs you a bond offering.
Start with a free EMMA Compliance & Five-Year Look-Back Scan. Send your issuer details and we'll return a gap report against every undertaking and SEC Rule 15c2-12.
Documentation-completeness service · not legal advice · the issuer certifies every filing.