Spotlight on Public Finance: Fall 2019
Fall 2019 Newsletter
Featured Articles Attorney Spotlight Attorneys in Action
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FEATURED ARTICLES Cybersecurity and Climate Change: Considerations for Municipal Issuers By Barron F. Wallace, Ed Fierro and Sarah Tahir Cybersecurity
Municipal entities have increasingly fallen victim to cyberattacks in their varied forms. Over the course of the last 10 months, 140 local governments, law enforcement units and hospitals across the US have been victims of ransomware attacks. In Texas, coordinated ransomware assaults have targeted 22 small towns. Ransomware onslaughts generally start with an email containing a link or an attachment that permits hackers to take over the entity’s network and data. Once locked from its own system, the governmental entity finds itself between a rock and a hard place, where it can either remain without access to its data, or succumb to the hackers and pay a ransom. Additionally, data breaches, where hackers or other unauthorized users may seize vast amounts of sensitive information, also present risks for municipal issuers. The City of Bakersfield, California, has, for example, experienced 2 successive data breach incidents in the last 11 months, whereby hackers targeted the online payment system used by the city to process online payments for building permits, utility bills and business license renewals. Another form of cyberattack includes business email compromise schemes. Such scams involve emails from purported executives or third-party consultants requesting funds to be remitted by unsuspecting employees. In sum, criminals are steadily becoming more creative and methodical in their attempts to launch cyberattacks against municipal issuers, and municipal issuers are at risk of being targeted in such schemes. To date, the Securities and Exchange Commission (SEC) has not published guidance for municipal issuers on cybersecurity disclosure or pursued any enforcement actions involving municipal issuers and cybersecurity. If the SEC updates its 1994 Interpretive Guidance Regarding Disclosure Obligations of Municipal Issuers, some predict that such guidance will include cybersecurity disclosure. For now, we can analyze what the SEC has said about public company cybersecurity disclosure. In 2011, SEC staff issued guidance stating that although no existing disclosure requirement explicitly refers to cybersecurity risks and cyber incidents, public companies nonetheless may be obligated to disclose such risks and incidents. The SEC staff advised that public companies should consider the adequacy of cybersecurity disclosure in registration statements in the context of Rule 10b-5 of the
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Exchange Act, among other regulations. After the issuance of this guidance, many public companies began including cybersecurity disclosure in registration statements, typically in the form of a risk factor. In 2018, due to the increasing significance of cybersecurity incidents, the SEC reaffirmed the staff’s 2011 guidance and expanded upon it by focusing on, among other things, the importance of maintaining comprehensive policies and procedures related to cybersecurity. Given the limited regulatory authority of the SEC over municipal issuers, the SEC cannot require municipal issuers to include cybersecurity disclosure in offering documents or adopt policies and procedures. That said, the SEC assesses the adequacy of disclosure based on determining materiality and, with the recent uptick, severity and costs of cyberattacks on municipal issuers, municipal issuers should consider whether it is advisable to include cybersecurity disclosure in offering documents. Furthermore, municipal issuers should consider whether it is worthwhile to adopt policies related to cybersecurity or to engage third parties to assess risk and offer solutions to mitigate such risk. To start the analysis, municipal issuers should consider asking questions, such as: • What is the risk of a cyberattack? • What impact would a cyberattack have on the municipal issuer’s operations, financial condition, reputation, susceptibility to litigation and security for the bonds? • Has the municipal issuer ever been attacked? • Does the municipal issuer have any cybersecurity policies and procedures? • Has the municipal issuer appointed an officer to oversee its cybersecurity measures, including in the event of a cyberattack? • Is the municipal issuer’s technology, such as its servers, secure? • Does the municipal issuer use any third-party services to store data? • Does the municipal issuer have adequate insurance policies to cover any losses? Importantly, any cybersecurity disclosure and policies and procedures that are publically available should be carefully drafted to ensure that the information does not provide a roadmap for a potential hacker to attack the municipal issuer’s systems. The SEC, for example, discourages detailed disclosure of a public company’s cybersecurity measures and does not expect companies to publicly disclose specific technical information about their cybersecurity systems. Striking a balance between disclosure and overexposure of information is thus critical when drafting any information that may be publically available. Climate Change The earth’s climate has evolved throughout history and continues to change. According to the National Aeronautics and Space Administration, evidence of rapid climate change includes global temperature rise, warming oceans, shrinking ice sheets, decreased snow cover, sea level rise, and extreme weather-related events. Regardless of the cause, there is no doubt that extreme weather events have impacted many public entities. Hurricane Harvey, for instance, devastated the coast of Texas, leaving behind approximately $125 billion worth of costs. Municipal issuers are forced to reckon with the ramifications of extreme weather-related events. Similar to cybersecurity disclosure, the SEC has not published guidance for municipal issuers on climate change or pursued any enforcement actions involving municipal issuers and climate change. In 2010, the SEC provided guidance for public companies on climate change disclosure. The guidance summarized a number of SEC rules and regulations that may be the source of a disclosure obligation under the federal securities laws, including disclosure in a public company’s registration statement. The guidance also provided examples of climate-change-related issues that a public company may need to consider, including the impact of legislation and regulation addressing climate change, indirect consequences of regulation or business trends, as well as the physical impact that such extreme weather events can have on a public company’s operations and financial condition. Again, given the limited regulatory authority of the SEC over municipal issuers, the SEC cannot require municipal issuers to include climate change disclosure in offering documents. Similar to cybersecurity disclosure, the adequacy of disclosure is assessed based on determining materiality, and with the occurrence of more frequent and extreme weather related events, municipal issuers should consider whether it is appropriate to include climate change or weather-related event disclosure in offering documents. To start the analysis, municipal issuers should consider asking questions, such as: • What is the risk of climate change or a weather-related event? • What impact does climate change and/or weather-related events have on the municipal issuer’s property, operations, financial condition and security for its obligations? • In the past, what has been the financial impact of weather-related events? • How frequent are weather-related events? • Has any material environmental litigation occurred involving the municipal issuer because of weather-related events?
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• Does the municipal issuer have any procedures in place to mitigate damages? • Does the municipal issuer have sufficient insurance coverage for any losses?
Unlike cybersecurity disclosure, a municipal issuer does not necessarily risk overexposure of information by providing disclosure about climate change; however, municipal issuers should be mindful of providing generic disclosures and instead focus on disclosure that is of particular relevance to the municipal issuer, taking into account its history and geographic location. Conclusion Cybersecurity and climate change are increasingly on the radar of not only investors, rating agencies, underwriters and but also the SEC. Further, certain rating agencies and underwriters have begun asking questions about cybersecurity and climate change during diligence reviews in connection with the issuance of municipal securities. The considerations presented in this article are a starting point for municipal issuers in approaching these issues. Bracewell’s team of experienced lawyers regularly provides guidance on disclosure and policies and procedures for municipal issuers. Should you desire additional information, please contact any member of our public finance team.
FEATURED ARTICLES Public Improvement Districts: An Economic Development Tool By Julie Melton Partain and Robert R. Collins III
Public Improvement Districts ( “PIDs”), which are created pursuant to Chapter 372, Texas Local Government Code (the “Act”), are a popular economic development tool in Texas. A PID allows a city or county to finance public improvements and provide services that benefit the property owners in a designated area within its boundaries or, in the case of a city in its extraterritorial jurisdiction, by levying assessments on property owners within such area. Most PIDs have been formed to facilitate residential housing development; however, in recent years, many PIDs have contained commercial development as a component of the residential development and, in some cases, cities have designated “commercial only” PIDs. PIDs are especially prevalent in the North Texas area, but their use is rapidly expanding across the State. Why a PID? Developer: For a developer, PID financing (especially bond financing) for all or a portion of the costs of public improvements reduces the amount of private capital needed for a development. Even a few million dollars of cash up front for the developer can make a very big difference in the financing and rate of return. Issuer: For a city or county issuer, there are several reasons why a PID financing is attractive. First, it can allow the issuer to achieve a higher standard of development than zoning alone would allow, which in turn can lead to higher home values. With a PID financing, the issuer has leverage to entice the developer to agree to a higher quality development in exchange for the upfront PID bond financing. Second, for certain troubled properties within a city or county, a PID bond financing may be a useful incentive to attract development that would not otherwise occur. Third, a PID financing places the payment obligation for an improvement only on the property owners benefitting directly from the improvement, as opposed to all citizens having to bear the cost of the improvements even if they don’t benefit directly. Finally, a PID is often more attractive to a city or county issuer than a municipal utility district or other water district within the issuer or its extraterritorial jurisdiction because a PID is merely a financing vehicle used by the issuer and the land within the PID remains under the issuer’s control. Formation In order to form a PID, the issuer must receive a petition from (i) the owners of taxable real property representing more than 50% of the appraised value of taxable real property liable for assessment in the proposed PID or (ii) the record owners of real property liable for assessment in the PID who constitute more than 50% of all record owners of property that is liable for assessment in the PID or own taxable real property that constitutes more than 50% of the area of all taxable real property that is liable for assessment in the PID. In reality, the majority of PIDs are formed when all the property within the proposed PID is owned by a single developer or landowner, but there some instances where a developer owns less than 50% of the property and can convince the owners of the remaining property to sign the petition prior to the developer’s purchase of the land. The issuer’s governing body must meet to “accept” the petition and call a public hearing on the creation of the PID. Notice of the public hearing must be published in
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newspaper of general circulation in the area of the proposed PID and mailed to property owners in the PID no later than 16 days prior to the public hearing date. PID creation is fairly straightforward but there are a few of areas in which an issuer should exercise caution: (i) Boundaries: Once the PID is created and assessments levied, it is difficult to correct a boundary issue. If PID bonds have been issued, the difficulty of changing the PID boundary increases significantly. The responsibility for the correctness of the boundary is the responsibility of the developer, but the issuer’s staff should review the survey and if there is a question, commission their own survey to ensure the boundaries are correct. (ii) Early Creation: Developers tend to push cities or counties to create a PID before the development agreement is completed. They view creation as evidencing the issuer’s commitment to the deal. While it can certainly be done, creating the PID before an issuer has its development deal worked out with the developer could leave the issuer in the position of having a busted business deal, but an already created PID. The Act does not provide a mechanism for the issuer, on its own initiative, to dissolve the PID. This would mean that if a later developer came along, the city or county would have to dissolve the existing PID (by petition of the property owner) and then create another over the same property. (iii) Land Ownership: Sometimes, when the PID petition is submitted, the developer does not own the land but plans to purchase it at a later date. At a minimum, an issuer should not levy assessments until the property in the PID is owned by the developer who can consent in writing to the levy of assessments; ideally the issuer would not create the PID until all land is owned by the developer. If a city or county creates a PID before the developer owns the property, then it is advisable to obtain a consent from the The development agreement between the issuer and the developer is the memorialization of the business deal. The development agreement is the document whereby the issuer receives the benefit of its bargain in return for creating the PID, levying assessments and providing bond financing or a cash flow reimbursement stream to the developer. It is the document that dictates what each party will do to facilitate the proposed development. In negotiating the development agreement, an issuer should carefully consider what it wants in return for accommodating the developer with PID financing. This is the issuer’s opportunity to achieve a desired outcome. Often cities require additional development standards or amenities above and beyond basic zoning to help ensure the development is more attractive or of higher quality than the developer would otherwise be required to achieve with zoning alone. This could include additional parks and/or green space, different setbacks or building facades, or more enhanced landscaping. Even though many of these developments are zoned as a planned development or “PD”, the city can include items in the development agreement that it cannot include in the PD pursuant to State law. For example, with the passage of HB 2439 in 2019, the city can no longer regulate the use of certain building materials. The city, however, could include the desired material restrictions as a covenant in the development agreement and bypass the limitation imposed by the new law. The development agreement also will lay out the timing of development and the construction of the public improvements to be funded from assessments or from bond proceeds as well as any additional requirements of the issuer. If an issuer is concerned about the pace of development, the development agreement can require the developer to reach certain milestones before the issuer will issue bonds secured with a pledge of the PID assessments (“PID Bonds”) or the issuer and developer may agree that the issuer will withhold building permits until certain milestones are completed. Finally, the development agreement contains all of the issuer’s conditions to issuing any PID Bonds or levying assessments. These could include items such as (i) annexation of the PID if it is within the extraterritorial jurisdiction of a city, (ii) a lien to value ratio minimum such that the value of the land on which the assessments are levied is high enough that in a foreclosure proceeding the proceeds of the land sale would pay the delinquent assessment (e.g., 3:1 lien-to-value ratio); and (iii) a “tax stack” maximum that caps the ad valorem tax and assessment total the residents of the PID would be required to pay. Levy of Assessments A service and assessment plan (the “SAP”) is the document that identifies the assessment amounts, the projects for which the assessments are being levied and their estimated costs, apportions the assessments among the properties within the PID and sets forth the benefit analysis for how the assessment amounts are determined for each parcel or lot in the PID. This document current property owner of the property at the time of creation. The Business Deal: The Development Agreement
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is prepared by an assessment consultant who specializes in this type of work. It is important that the issuer hire an experienced assessment consultant who works for the issuer directly and is an advocate for the issuer. As part of its continuing role, the assessment consultant updates the SAP each year and prepares the assessment roll, which is the document that identifies the assessment amount by lot or parcel for each year the assessment is levied. The assessment consultant will interface with the developer, the county tax assessor collector, the appraisal district, bond counsel and bond trustee (if PID Bonds are issued), and the property owners within the PID. The assessment consultant is paid from a portion of the assessments levied on the property as an administrative cost of the PID. The importance of an experienced and responsive assessment consultant cannot be overstated. The assessment consultant and their attention to detail can help to ensure that the collection and enforcement of the assessments is smooth process that requires as little time from the issuer’s staff as possible. The PID will exist for thirty years or more and the issuer will have to manage each PID and update the SAP each year. Trying to handle this process in- house can be very time consuming for the issuer’s existing staff. PID Financings A PID financing can be a bond financing or it can be an annual cash flow reimbursement to the developer. Typically, if possible, a developer will want the issuer to issue PID Bonds for the costs of at least a portion of the public improvements within the PID. Again, this “up front” cash is very valuable to a developer and reduces the cost of private borrowing. However, there are circumstances in which a PID bond financing is not possible because of political and/or market reasons. In those instances the issuer can levy assessments and enter into a reimbursement agreement with the developer and each year as assessments are collected, the developer could be reimbursed for the costs of the public improvements from the assessment revenues collected that year. The developer then often monetizes that reimbursement stream by selling it to a bank or other lender as security for a private loan. An issuer may want to ensure the development agreement and reimbursement agreement address this circumstance and that the assignment provisions are acceptable and do not bind the issuer to perform reporting or other onerous obligations in the event of such an assignment or otherwise make the administration of the PID and the reimbursement difficult. A PID financing that results in the issuance of PID Bonds often looks quite different than an issuer’s normal general obligation or revenue debt process. Typically, the PID bonds are issued pursuant to an indenture of trust with a trustee bank and the financing documents are more numerous than a typical debt offering of the issuer. These financings are also more expensive than those the issuer would typically incur for traditional debt issuances because more professional time and additional reserve and administrative funds are required to be funded at delivery of the PID Bonds. All costs are typically paid from the proceeds of the PID Bonds, but if the proceeds generated from the PID Bonds are not sufficient to fully construct the public improvements, then the developer should deposit the difference in cash at closing of the PID Bonds. The issuer will want to ensure that upon issuance of the PID Bonds they that the issuer will at least have completed public improvements and will not be short of funds to complete those projects. Collection and Foreclosure The PID assessments are a first and prior lien except for ad valorem taxes of the issuer or other political subdivisions. Best practices dictate that the developer file notice in the property records of the existence of the assessments so that they will appear on a title report, although this is not required by law in order for the assessment to be valid. The ultimate security for any PID bond financing or any reimbursement obligation to a developer is foreclosure on the property if the property owner does not pay their assessment. Unlike with property taxes, the issuer would not have the option to delay foreclosure on the property. The issuer will be required to covenant in the bond documents, or in a reimbursement agreement, to foreclose for nonpayment of the assessments. These foreclosure costs would be an administrative expense of the PID. Because foreclosure takes some time, in a PID bond financing, there are reserves that can be drawn upon to make bond debt service payments until foreclosure can be completed. In addition, foreclosure in one year does not extinguish the assessment for future years. If a property owner fails to pay again in a subsequent year, the issuer would have to foreclose again on that property. Risks of a PID Bond Financing The PID Bonds are payable solely from assessments levied within the PID, and an issuer is never required to pay those PID Bonds from any other sources of revenue. In other words, the issuer’s general fund is not at risk. The time period of the most risk with respect to a bond default is the time period when the developer owns the property and is responsible for payment of all or a majority of the assessments. Typically, the PID bonds will have a capitalized interest period where no assessments will be due and during this period the developer will construct the public improvements and complete lot development in order to sell to home builders.
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The issuer holds PID Bond proceeds and cash from the developer and will oversee the construction of those public improvements and their payment. If, however, the developer cannot complete the lots and sell them to builders, then he could be left paying the bulk of the assessments, and depending on cash flow and assets, the developer could default in its payment. In that scenario either (i) the developer’s lender with a mortgage on the property would step in and pay the assessments in order to preserve their lien (a PID lien trumps a mortgage lien), (ii) the issuer would foreclose on the property and use the proceeds to pay off PID Bonds, or (iii) if the foreclosure proceeds are insufficient or not timely, the PID Bonds default. Most financial advisors advise issuers that a default of assessment PID Bonds is not a default that affects an issuer’s general obligation debt capacity or rating. In these scenarios, while the issuer’s credit rating wouldn’t be affected, the issuer would not get the development it bargained for but it should at least have infrastructure in the ground that would hopefully work for a new property owner and developer. An Effective Tool PIDs are a useful financing tool in an issuer’s economic development toolkit. Like all tools, they are not without risks, but with careful thought and consideration and the involvement of experienced professionals, a city or county can effectively utilize a PID to obtain a development that it would otherwise not be able to achieve with zoning. Issuers may want to create thorough policies and procedures for using public improvement districts as an economic development tool. Once a PID is utilized, the issuer may be inundated with developer requests for this financing vehicle. Identifying what types of development the issuer wants to incentivize and in what instances the issuer will consider a PID will help focus the issuer’s economic development program and hone in on those developments that bring something “extra” or “special” to the issuer or its residents. Should you have questions concerning PIDs or other public financing tools, please contact Julie Partain, Rob Collins, Andy Prihoda or any one of our Bracewell public finance lawyers.
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Julie Melton Partain | Counsel, Dallas Julie Partain focuses on public debt offerings and business transactions involving cities, counties, school districts, universities, economic development corporations and water districts. She serves as bond counsel, underwriter’s counsel and disclosure counsel in financing transactions for all types of public entities. Julie also works on financings and debt issuances for special districts, including special legislatively created districts. In addition, she advises clients on their economic development initiatives and incentives for public/private projects. What are your areas of focus within public finance? Besides helping my clients with ad valorem tax and revenue debt, my practice focus is on public improvement district financings and the issuance of assessment revenue bonds. I have been working on public improvement districts since 2007 and besides helping my clients issue assessment revenue bonds, I also assist them with the ongoing administration of public improvements districts. In addition, a large part of my practice concentrates on economic development and assisting my clients in negotiating and drafting economic development agreements and master development agreements for economic development projects.
How did you get started in the public finance practice? I have a Master of Public Administration degree from the University of North Texas and had originally planned to be a City Manager. I was always interested in local government. After attending law school, public finance was a perfect fit for me. My clients are predominately local governments and I am privileged to help them develop and finance public improvement projects that support and enhance their communities. What do you like best about your practice? It is tie between my clients and my colleagues. My clients and their operations touch people’s lives on an everyday basis and being a part of helping them deliver services that matter to the public is very meaningful to me. Most people don’t know how their streets or schools or water and sewer improvements are built and financed, but I do, and being a part of making those things happen is very fulfilling for me personally. And I work with the best and the brightest people who share my vision of the importance of local government. It is a privilege to work with and for the people I do. What would people be most surprised to learn about you? I was diagnosed with Celiac disease about twelve years ago. So please don’t serve sandwiches and pasta when I come to your office for a meeting! Or chocolate chip cookies – those are my favorite and not being able to eat them is no fun.
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ATTORNEYS IN ACTION Welcome Bill Mahomes, Steve Bolden and Sarah Tahir
Bracewell LLP is honored to add Bill Mahomes , E. Steve Bolden II and Sarah Tahir to its team of public finance lawyers in Dallas. Bracewell partners Bill and Steve have worked together for over 10 years and bring with them a wealth of knowledge of public finance transactions, public projects, public private partnerships (P3s) and real estate, and are proud supporters and advocates of the Dallas community. Please take a moment to send a note to welcome Bill, Steve and Sarah to the firm. Bill has over 30 years of experience in public finance, real estate and other transactional disciplines. He has been involved in various public infrastructure projects, providing practical advice on public projects and P3s based on his service on the board of directors of the Dallas/Fort Worth International Airport and the Texas Turnpike Authority. Bill received his B.A. from Texas A&M University and his J.D. from The University of Texas at Austin School of Law. He currently serves as a regent for the Texas A&M University System. Steve concentrates on public finance matters, including bond counsel, disclosure counsel and underwriters’ counsel matters. In addition to public finance, Bolden practices in the corporate and securities area, including the merger and acquisition of publicly traded and privately held companies. He currently serves as trustee for the Dallas Bar Foundation and is a Past Chair of the Business Law Section of the State Bar of Texas. He earned his A.B. in government from Dartmouth College and his J.D., magna cum laude, from Thurgood Marshall School of Law, Texas Southern University, where he was a member of the board of advocates. Bracewell associate Sarah Tahir represents Texas counties, cities, independent school districts, housing and tollway authorities, investment banks and related entities on public finance matters, including as bond counsel, disclosure counsel, issuer’s counsel and underwriters’ counsel. She earned her B.A. from Oslo Metropolitan University and her J.D. from Arizona State University. Sarah is fluent in Norwegian and Swahili.
Ozimek Selected to Serve on NABL’s Board of Directors Congratulations to Bracewell partner Victoria Ozimek for being named to a three-year term on the Board of Directors of National Association of Bond Lawyers (NABL).
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UPCOMING EVENTS Entrepreneurship and Community Development Clinic
Brian Teaff will be a guest lecturer on November 12, 2019, at the University of Houston Law Center, where he will present to students in their Entrepreneurship and Community Development Clinic on tax incentives and tax-exempt finance.
PAST EVENTS Connect Opportunity Zones Brian Teaff served as moderator for the “Alternative Investments Through Opportunity Zones” panel at the Connect Opportunity Zones conference on October 23, 2019, in New York. National Society of Compliance Professionals Ed Fierro participated in the National Society of Compliance Professionals Annual Conference on October 21, 2019, and presented on the MSRB’s advertising rules for municipal advisors. The Workshop (formerly known as the Bond Attorneys Workshop or BAW) presented by NABL Victoria Ozimek presented on the “Tax Diligence and Documentation” panel, Barron Wallace participated on the “Hot Topics in Securities Law” panel and Ed Fierro presented on the “Understanding the Role of Municipal Advisors” panel at The Workshop in Chicago, Illinois on September 11-13, 2019. International Municipal Lawyers Association (IMLA) Paul Maco presented a webinar for IMLA on July 9, 2019 which discussed the coverage of municipal bonds, specifically a municipal attorney’s responsibilities related to municipal bonds/allegations of securities fraud.
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UPDATES Since our last newsletter, our public finance team has distributed a number of federal securities and tax law updates as well as announcements and attorney commentaries. If you missed them the first time or would like to refresh your memory, we have compiled the most recent of our team’s updates here. Proposed Rules Addressing LIBOR Phase-out Help Ease Reissuance Concerns October 18, 2019 By Victoria N. Ozimek and Brian P. Teaff Webinar: 86th Legislative Session Recap August 14, 2019 By Jonathan K. Frels SLGS Window Reopening; Sequestration Extended Through FY 2029 August 2, 2019 By R. Todd Greenwalt , Victoria N. Ozimek and Brian P. Teaff FY 2020 Sequestration Reduction Rate Set at 5.9% July 15, 2019 By R. Todd Greenwalt , Victoria N. Ozimek and Brian P. Teaff Appellate Court Affirms Decision to Block Medical Merger June 20, 2019 By Daniel E. Hemli and Jacqueline R. Java Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations April 30, 2019 By Brian P. Teaff and Lance W. Behnke
DID YOU KNOW?
• Rating agencies are factoring cyber and climate risks into credit analysis for certain issuers. • Nearly two-thirds of all publicly known ransomware attacks in 2019 have targeted state or local governments. • The impact of climate-related risks varies widely, with coastal and southern states hit hardest.
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