On February 2, 2016, the SEC announced "enforcement actions against 14 municipal underwriting firms for violations in municipal bond offerings. The actions conclude charges against underwriters under the Municipalities Continuing Disclosure Cooperation (MCDC) Initiative. In all, 72 underwriters have been charged under the voluntary self-reporting program targeting material misstatements and omissions in municipal bond offering documents"

According to the SEC: "The Commission has issued separate orders ('MCDC Orders') instituting administrative and cease-and-desist proceedings against certain municipal underwriters who participated in the MCDC Initiative (the 'MCDC Underwriters').... The MCDC Orders trigger a number of disqualifications from exemptions under the Securities Act for the MCDC Underwriters, and for certain issuers which have MCDC Underwriters as subsidiaries ('MCDC Issuers').... [T]he Commission has determined that pursuant to Rules 262(b)(2), 505(b)(2)(iii)(C), 506(d)(2)(ii), and 602(e) of the Securities Act and Paragraph (2) of the definition of ineligible issuer in Rule 405 of the Securities Act, the requisite showings of good cause have been made." Accordingly, the SEC granted waivers from the application of the disqualification provisions of Rules 262(a)(4)(ii), 505(b)(2)(iii), 506(d)(1)(iv)(B), and 602(c)(3) of the Securities Act and waivers from being ineligible issuers resulting from entry of the MCDC Orders against the MCDC Underwriters.

On February 2, 2016 the SEC instituted settled administrative and cease-and-desist proceedings against TD Securities (USA) LLC. According to the SEC: "This matter involves violations of an antifraud provision of the federal securities laws in connection with Respondent's underwriting of certain municipal securities offerings. Respondent, a registered broker-dealer, conducted inadequate due diligence in certain offerings and as a result, failed to form a reasonable basis for believing the truthfulness of certain material representations in official statements issued in connection with those offerings. This resulted in Respondent offering and selling municipal securities on the basis of materially misleading disclosure documents. As a result of the conduct described herein, Respondent willfully violated Section 17(a)(2) of the Securities Act. The violations discussed in this Order were self-reported by Respondent to the Commission pursuant to the Division of Enforcement's (the 'Division') Municipalities Continuing Disclosure Cooperation Initiative. Accordingly, this Order and Respondent's Offer are based on the information self-reported by Respondent."