April 28, 2014 Board of Directors Municipal Securities Rulemaking Board 1900 Duke Street, Suite 600 Alexandria,

VA 22314 Updating MSRB information collection and sharing: taking steps toward transparency Dear Board of Directors, The Sunlight Foundation is a nonpartisan nonprofit that advocates for open government globally and uses technology to make government more accountable to all. We are committed to improving access to government information by making it available online and encourage policies that facilitate public access through making data searchable, sortable and machine-readable. We urge the Board to consider updating policies and practices that will facilitate the gathering and sharing of municipal financial information online in easily accessible and reusable formats. Sharing information in this way will empower greater transparency and oversight, upholding a key part of the Boards vision and strategic goals. MSRB plays an important role in collecting and sharing municipal information related to the bond market. Specifically, the Comprehensive Annual Financial Reports (CAFRs) and basic audited financial statements included in the continuing disclosures of municipal bond-issuers provide important insights into local finances. Audited financial statements are generally more accurate, complete and standardized than budgets. However, while budget information is often easy to access and review, CAFR information is generally difficult to access directly. The MSRBs collection of local governmental CAFRs therefore represents a substantial public good. Unfortunately, the audited financial data held within the MSRBs continuing disclosure database is also difficult to extract and analyze. The MSRB currently shares most reports as PDFs, a format that makes it challenging for computers to search for and extract data. If the information about local finances contained in CAFRs were easier to access, there would be a wide range of benefits. It would be easier for the Board and other stakeholders to analyze the financial health of local governments. It would be easier for the public to access data about finances in their communities. It would be easier for journalists to use this information to hold local governments accountable. We applaud the Board for the steps it has already taken toward sharing this valuable information proactively online for the public to access. Finding all of the relevant information from a typical CAFR, however, could involve sifting through hundreds of pages

of a PDF. Instead, all numerical information from continuing disclosures should be shared as structured, machine-processable data, empowering easier searching, sorting and analysis of the numbers. These kinds of improvements are in line with the goals of the Board in upgrading EMMA. In the Long-Range Plan for Market Transparency Products, the Board writes about providing primary or continuing disclosure documents posted in interactive data formats. Sharing information as structured, machine-processable data would allow for more interactive data access and presentation formats. The Long-Range Plan also suggests simplifying the process of submitting continuing disclosures. Improvements in how information is submitted in the first place could help lead to easier sharing of what is submitted, especially if the MSRB encourages or mandates electronic filing. Electronic filing can ensure information submitted digitally is structured from the start, making it easier to share as structured, machine-processable data online. Until these improvements can be made, there are other steps that could be taken to improve EMMA and access to important municipal financial information in general. First, EMMA should allow for bulk download of continuing disclosures from each state. This would enable users to quickly access relevant information for assessments and comparisons rather than downloading files individually. (In California, for example, users would need to click through more than 8,300 links to see where CAFRs exist.) Search functions should also be improved on EMMA, in line with another goal stated in the Long-Range Plan. Though there are several different ways to search for and browse information, the advanced search function which provides a number of good ways to filter and narrow a query often times out without returning results. The advanced search function works under an unacceptably small number of parameters. Searching should be as easy as possible to facilitate access to the crucial data stored in EMMA. We are pleased that the Board has prioritized working toward improved transparency. We hope due consideration will be given to further advances by examining and taking action on opening up municipal financial information by adopting best practices for sharing data. This information is already collected and disclosed online its time for improving the ease of access and reuse to help bolster transparency and accountability. Sincerely, Ellen S. Miller Co-founder and Executive Director Sunlight Foundation

Marc Joffe Principal Consultant Public Sector Credit Solutions Yaw M. Mensah, Ph.D., CMA Professor of Accounting and Information Systems & Academic and Research Director Center for Governmental Accounting Education and Research Rutgers Business School Newark & New Brunswick Dr. Shannon Sohl NIU Center for Governmental Studies DFR Project Co-Director Miklos a Vasarhelyi KPMG Distinguished Professor of AIS Rutgers University Anna Lukasiak Co-founder Open JC Hussein Issa, Ph.D. Assistant Professor Department of Accounting and Information Systems Rutgers Business School Rutgers University Dalton Laluces Founder Gasbie.com Bart Mosley Co-President Trident Municipal Research, LLC Data Transparency Coalition Cathy ONeil Program Director, the Lede Program: An Introduction to Data Practices Columbia Graduate School of Journalism