Pursuant to Municipal Securities Rulemaking Board Rule G-42, on Duties of Non-Solicitor Municipal Advisors, Municipal Advisors are required to make certain written disclosures to clients which include, amongst other things, "Conflicts of Interest" and any "Legal or Disciplinary events" of the Firm and its associated persons.
Compass Municipal Advisors ("Compass") represents, in general, that it has no known material conflicts of interest with any municipal entity. If Compass becomes aware of any material conflict of interest with a particular municipal entity, Compass will disclose all detailed information in writing to the Issuer in a timely manner.
From time to time, Compass does provide municipal advisory services that are in connection with the issuance of a Bond, and Compass may receive compensation for the services provided, which compensation is contingent upon the successful closing of a transaction or is based on the size of a transaction. Consistent with certain regulatory authorities, Compass hereby discloses that such contingent and/or transactional compensation present a conflict of interest, because it may cause Compass to recommend a transaction that is unnecessary or in a size that be larger than is necessary. This conflict of interest will not impair Compass' ability to render unbiased and competent advice or to fulfill its fiduciary duty.
Compass does not have any legal events or disciplinary history on Compass’ Form MA and Form MA-I's, which includes information about any criminal actions, regulatory actions, investigations, terminations, judgments, liens, civil judicial actions, customer complaints, arbitrations and civil litigation. An Issuer may electronically access Compass’ most recent Form MA and each most recent Form MA-I filed with the U.S. Securities and Exchange Commission ("SEC") at the following website: www.sec.gov/edgar/searchedgar/companysearch.html.
There have been no material changes to a legal or disciplinary event disclosure on any Form MA or Form MA-I filed with the SEC. If any material legal or regulatory action is brought against Compass, Compass will provide complete disclosure to the Issuer in detail allowing the Issuer to evaluate Compass, its management and personnel.