The deadline for municipal issuers and obligated persons to self-report to the Securities and Exchange Commission (SEC) under its Municipal Continuing Disclosure Compliance (MCDC) Initiative any recent misstatements in primary offering documents concerning secondary market disclosure compliance is December 1, 2014. Underwriters have already submitted their reports, and their action may affect the issuer’s decision. Given the need to launch a factual audit of the recent disclosures and past compliance, and then undertake a careful analysis and consultation with counsel on issues of materiality, the December 1 deadline will be here before we know it.