Of General Market Interest

A good source for general business news - U.S. Based

The EMMA website is funded and operated by the Municipal Securities Rulemaking Board (MSRB), the self-regulatory organization charged by Congress with promoting a fair and efficient municipal securities market. EMMA is designated by the U. S. Securities and Exchange Commission as the official source for municipal securities data and disclosure documents. The website provides free public access to objective municipal market information and interactive tools for investors, municipal entities and others. EMMA supports municipal market transparency but is not a platform for buying or selling bonds.  At this site you can do municipal bond price (interest rate) discovery and a whole lot more. (Please note the MSRB does not recommend nor endorse Roberts Consulting, LLC - this link is for convenience only).

Municipal Securities Rulemaking Board Education Center. Learn about municipal securities as in issuer and/or an investor. (Please note the MSRB does not recommend nor endorse Roberts Consulting, LLC in any way - this link is for convenience only) 

 

From novice to expert. Roberts Consulting, LLC will help you understand your tax-exempt (and taxable) bond debt structure.

Bar none - this is our number one "go to" location for tax credit and Opportunity Zone information.

This is a link to The Securities and Financial Markets Association's (SIFMA's) muni swap index - an index of high quality weekly reset municipal bonds. The rest of SIFMA's website provides a variety of other market information plus the organization's reaction to certain ongoing regulatory activities in the capital markets.

This is a link to a section of The U.S. Department of Housing and Urban Development's (HUD's) website where it lists multifamily financing programs available through Federal Housing Administration's (FHA's) mortgage insurance origination. Along with other descriptions, this link includes descriptions of popular HUD FHA programs like 221(d)4, 223(f), 207, and for the elderly the 231 and 202 programs. 

Do you want to do a tax-exempt housing bond deal? Notwithstanding if the deal is to be rated or not, most deals that get executed do employ rating agency criteria in their structure. Here is a June 19, 2014 release by Standard and Poor's Rating Service respecting the Rating Methodology And Assumptions For Affordable Multifamily Housing Bonds.

USGG10YR:IND

US Generic Govt 10 Year Yield

Many debt financing vehicles use the 10-year U.S. Treasury to determine the "spread" that will be charged to borrows over this "risk free" benchmark. 

Selected Interest Rates (Daily) - H.15 from the Federal Reserve.

This is a good site for current USD Libor Rates (Please make sure you are looking at the USD LIBOR and correct tenor).

 

Please Note, due to widely publicized bank scandals over the manipulation of the Libor index, there is an effort to have Libor completely phased out by the end of 2021. With the support of other U.S. financial regulators the Federal Reserve Bank convened a committee of private-sector financial market participants to establish a replacement index for Libor. This committee chose the Secured Overnight Financing Rate (SOFR) as that index.

 

Libor and SOFR differ from one another in many ways and are not comparable without first gaining an appreciation for the methodological differences as to how each of these rate indices are compiled.

 

As of May 2019, this transition away from Libor is still in its infancy and to date SOFR market executions represent a relatively small sliver of the entire market. Only with much greater additional market activity will we begin to see a standardization of certain "conventions" that will be commonly and consistently used. To understand what we mean by “convention” we will discuss but one among several of these possible conventions. Please understand that SOFR is an overnight lending rate. The interest cost is set one day before the interest is due. Not many want to pay interest daily. For this reason, over the years the Libor markets developed what is commonly called a term rate structure (e.g. know your interest rate before borrowing and pay it one month later, or know the rate and pay it three months later, or six months later. LIBOR can establish rates out as far as 30-years with conventions as to when interest will be paid during the entire term structure). SOFR, being in its early stage development, is just now commencing efforts to establish a term rate structure.

 

As it stands today, if one were to borrow for a 30-day period, in the Libor world you would know the rate at least 30 days in advance. But since SOFR is a daily rate, one would not know the actual final days' rate (on day 30) with interest due the next day. But its even worse, it takes time to compile the SOFR index rate and it is not published until the morning of that day that interest is due. The lender will then have to obtain this rate, calculate the intertest due on the loan and invoice the borrower. Just how much time is the borrower going to have to prepare themselves for this payment? Suffice it to say, there are numerous methods to deal with this issue. To date the executions that have been made have varied and no dominant convention has established itself. We are sure one or more will become increasingly more common and this will make the documentation of these deals much easier. But today it is impossible to know which conventions will become “more standard”.

 

However, if you are desiring to execute a transaction today - then right now is the time you must consider your documentation and how to prepare for possible unknown future conventions (and if applicable, their ability to integrate with hedges/derivatives should also be considered). If you need to transition a loan from LIBOR based documentation, then in the opinion of Roberts Consulting, LLC, your efforts should commence between now and not later than by the 2nd half 2020 – for if everyone tries to transition at the end of 2021 – will you be able to find available attorneys and advisors that are not already overwhelmingly engaged?

 

Past conventions have not dealt well with a Libor index demise. Most documents never considered Libor’s unavailability to be more than just a temporary problem. As such, many documents provide that the last rate available will prevail (and thus the loan becomes fixed rate – this could be bad for either of the parties depending on the direction of interest rate changes). Others convert to a bank "prime rate" based loan. This provision could wind up costing a borrower several hundred basis points more. Yet other documents remain silent on the matter and leave borrowers and lenders in a complete state of limbo. Some just let the lender to unilaterally choose a new index. Do you know what your current documents provide for? It could be any of the forgoing, or something completely different.

 

A couple of sections down you will find links for SOFR rates too.

This may be a tricky site for a capital markets novice. But here is a site to see the latest LIBOR rate swap yield curve (note that the use of LIBOR is set to "expire" at the end of 2021 in favor of better "indices" - which in the US, we anticipate the SOFR index to prevail). Please make sure you adjust the drop-down box for USD LIBOR.

Speaking of the new SOFR index - Learn about rates and the transition from LIBOR to SOFR (Secured Overnight Financing Rate) here.

This is a link to the historic interest rates of U.S. Treasury Securities. It allows you to graph and see numerical historical data for any maturity of U.S. Treasury (for example 2 or 10-year constant yield treasuries over selected adjustable periods of time). Notable is that it also allows you to compare say, the 2-year to the 10-year Treasury and see what historical spreads (differences) have existed between them.  Please note that you may have to enable Adobe Flash Player (in Chrome in particular) to see the graphic information.

This web page has indications for taxable 221(d)4 and 223(f) HUD program mortgage loan pricing. So, thanks to you CREFCOA! You will need to scroll down while looking at the left-hand side of the page. Please note that different deals have different structures and these published rates are indicative at best. We have found that the current funding "(f)" loans will be at the lower end of the scale indicated while the "(d)4" loans will be toward the upper end.

This site gives indications of interest rates for non-profit senior housing providers. Note that the various levels of service and the structure of the financing can deviate widely, so use these rates with a large dose of caution and seek better advice (Preferably from Roberts Consulting, LLC) for what may be applicable to your specific situation.

An interesting Real Estate Investment Resource

Q&A on Davis Bacon Published by AFL-CIO
DavisBacon QA.pdf
Adobe Acrobat document [1.3 MB]
Did you know there is a Taxpayer Bill of Rights?
Taxpayer Bill of Rights.pdf
Adobe Acrobat document [13.0 KB]

Why You Need A Financial Advisor

If you are a borrower eligible to take advantage of lower costing tax-exempt debt, did you know there are now laws that may affect the depth of the advice your broker dealer/investment banker may give to you?
 
In the past, many borrowers have depended on ideas, suggestions and related "advice services" from public finance bankers outside of an underwriting engagement. New rules (effective July 1, 2014) limit the ability of investment bankers to provide such assistance outside an underwriting engagement - and it may even limit some of the advice they can give you even while engaged.
 
You should further note that the law requires an engaged underwriter to disclose to a municipal borrower that they may have interests adverse to yours. This conflict of interest was the basis for why in year 2000, Jon Roberts formed Roberts Consulting, LLC. It took a 2008 world economic financial meltdown for the lawmakers to review and acknowledge this conflict, and then it took nearly 6 years more to implement rules to address it.   
 
Please Remember This:
Roberts Consulting, LLC is a registered Municipal Advisor.
 

In July 2010 the Dodd-Frank Act included a provision that the Securities and Exchange Commission (SEC) and Municipal Securities Rulemaking Board (MSRB) regulate non-dealer "municipal advisors" (MA).

 

If you have someone soliciting and providing ideas as to how to structure a tax-exempt bond issue for your particular needs and circumstances - then they are likely undertaking a municipal advisory activity. If they are not registered with the SEC and MSRB as an MA, they may be violating the law.

 

If your broker dealer renders advice particular to your needs outside an underwriting engagement, provided the transaction you execute utilizes that advice, it would preclude that investment bank from acting as your underwriter. However, provided they are registered as an MA they can continue to work as your advisor.

 

The SEC's general definition of "advice" under the MA rules is: "advice includes, without limitation a recommendation that is particularized to the specific needs, objectives, or circumstances of a municipal entity or obligated person with respect to municipal financial products or the issuance of municipal securities, including with respect to the structure, timing, terms and other similar matters concerning such financial products or issues, based on all the facts and circumstances."

 

For the typical Roberts Consulting, LLC client (all of whom are not  “municipal entities”) read the above SEC definition of "advice" using the following understandings:

 

"obligated persons" means a borrower  responsible for the repayment of municipal security indebtedness (could be a 501(c)3, a for-profit developer entity, an owner of a manufacturing facility, etc.); and

 

"municipal financial products" means products or services such as the reinvestment of bond proceeds, the use of interest rate derivatives (swaps and caps), plus other products that are often tied or linked to the needs of issuing/using municipal security indebtedness.

 

The SEC's rules provide broker dealers with three narrowly-defined exemptions where "advice" may be given without being considered a Municipal Advisor:

  • If the broker dealer is contractually engaged to serve as the borrower's underwriter 
  • If the borrower already has an "independent registered municipal advisor" and
  • If the broker dealer is responding to a request for proposal (RFP) 

The law does not provide a way for a borrower to agree with an underwriter to "opt out" from the applicability of these rules.

 

How do you know if you want to hire a broker dealer without knowing if they intend to (or even can) offer the financing solution best suited to your needs? The devil is in the details - and they are not (without engagement) allowed to provide those details.

 

If you opt for the RFP exception, how do you know all the right questions or providers to ask if you don't fully understand the array of products and services that might be available to you? The markets are forever changing, and the products and services keep developing to address those changes.

 

The problem is that what you don't know - and what you may not ask - can result in a higher costing and/or less than an optimally structured financing. Today you are subject to increasingly more complicated products and structural choices. Meanwhile new regulations are serving to stymie traditional resources to learning which product or service could or would be of particular interest to you. The result is that the use of a financial advisor (registered Municipal Advisor) is even more essential than it has ever been.

 

You should ask your advisor if they are a registered MA. We were -  long before the laws existed - a financial advisor because we know borrowers (of tax-exempt finance) need a fair, impartial voice they can trust. A voice that comes in the absence of material conflicts of interest. A voice of experience, and one possessing the expertise they will learn to know they can rely on. 

The theme colors of Roberts Consulting are varying shades of grey. This is because, except for our logo, rarely are things financial, simply black and white

Progress always involves risks. You can't steal second base and keep your foot on first.

Please Note: We want to remind our prospective clients that past successful performance is no guarantee as to our ability to achieve future successful performance. 

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