Bailey Quoted on SEC Rule 15c2-12

Foley Partner Michael Bailey was quoted in an article titled “Worries Over Changes to 15c2-12” in the July 20, 2009 issue of The Bond Buyer. Bailey speaks on the Securities and Exchange Commission’s proposal to require issuers to disclose when they have received an Internal Revenue Service form that asks an issuer or borrower to help it resolve tax issues related to their bond. He adds that disclosing the receipt of a form could be premature, as the IRS may be merely trying to identify issues and questions that require explanation rather than make a proposed adverse determination that the bonds are taxable.