Considerations for California School Districts: Audit Delays and Continuing Disclosure Compliance

In response to the Coronavirus 2019 (“COVID-19”) pandemic and the challenges it presents for school district operations, Senate Bill 98 (Chapter 24, enacted on June 29, 2020, as an urgency bill) provides, among other things, that a school district’s audited financial statements for fiscal year 2019-20 (the “2020 Audit”) are not due to the State until March 31, 2021. This extension to complete and file the 2020 Audit with the State definitely provides operational relief. However, it also creates a dilemma for California school district bond issuers with existing continuing disclosure undertakings having annual report deadlines prior to March 31, 2021. Moreover, the problem created has complexities which, without a deeper understanding of the issues raised, could result in a violation of federal securities disclosure laws.

For a discussion of the complexities and various options available to California school district bond issuers with existing continuing disclosure undertakings having annual report deadlines prior to March 31, 2021, please click here.

Nothing contained in the article in the above link should be construed or relied upon as legal advice.  Instead, the article is intended to provide an overview of considerations associated with Senate Bill 98’s 2020 Audit filing deadline extension and potential impacts on California school district bond issuers with existing continuing disclosure undertakings having annual report deadlines prior to March 31, 2021.