Method · privacy · nationwide · worldwide holders
Disclose the conflict file at the speed of the vote.
The county borrowed in public and pays from the General Fund in public. Current lenders sit behind a book-entry market built in the 1980s and 1990s. Beneficial owners of that paper may live in any country. Sunlight that matches the speed of county government is the vote, the yearly payment, the advisor file, and a targeted conflict rule — not a claim that nothing is known until every bond fund on earth is named.
What this page will do
- Decision file. Publish the vote, the yearly General Fund hit, transaction parties, and conflict excerpts already on the public record (county minutes, EMMA, G-17).
- Fund-level sunlight. Show CUSIPs, the Cede & Co. / DTC fact, EMMA trade summaries, and any public 13F / N-PORT hit that already names the CUSIP or issuer.
- Threshold self-disclosure. Require covered officials, vendors, and their families to file yes/no plus an amount band when interest exceeds $5,000 in a fiscal year, or 5% of an entity that holds the bonds.
What this page will refuse
No public list of natural-person beneficial owners. Not for U.S. residents. Not for anyone else on earth. The market was never built to produce one, and privacy law will not permit it as a general public register.
- DTC book-entry is accepted. This page does not pierce participant files.
- Broker KYC / BSA-AML stays with institutions and regulators — not a county website feed.
- Foreign custodians (including Euroclear / Clearstream chains) are not a feed either. Their existence is why “holders may live anywhere” is a method fact, not a database.
- Over-collection is refused. The threshold filing is yes/no plus an amount band only.
Nationwide scale
Every U.S. county-equivalent can open this file. Cities, school districts, and authorities use the same four sections; the county (or equivalent) is the default unit because that is where a General Fund vote usually lives. Geography is on the record. Bond dollars are not invented to fill the map.
The Tower Amendment bars the SEC and MSRB from forcing issuer filings. It does not bar a county from an ethics rule for its own officials and vendors. There is no federal mandate in this product.
Honesty labels
- we-have-a-record
- A primary public record is attached — minutes, ordinance, official statement, audit, budget page, EMMA, or a sworn filing.
- not-proven
- Missing, unbound, outline only, or not yet retrieved. Blank is allowed.
- people-disagree
- The record exists and parties contest what it means.
Basis sits next to the label: Evidence / Inference / Assumption. Forecasts stay labeled Forecast, never Record. Software never auto-truths. Incomplete beats fake-complete. Human final call.
Cites
- CJEU, joined cases C-37/20 and C-601/20, 22 November 2022.
- Tower Amendment, 15 U.S.C. §78o-4(d).
- MSRB Rule G-17; SEC Rule 15c2-12; MSRB EMMA.
- Financial Data Transparency Act of 2022 (machine-readable filings, not owner identity).
- If a covered person fails to disclose and is later shown to hold the bonds, that is an ethics violation, not a missing owner registry.