Welcome to your daily briefing on government developments in Maryland. Today we're covering 5 key stories including updates on maryland government headlines, background & context. Let's dive in.
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Before incurring any cost on a federal grant, the question is whether 2 CFR 200 (Uniform Guidance) treats the cost as allowable, allocable, and reasonable. "Reasonable" is the most-litigated of the three; auditors will second-guess it after the fact using a prudent-person standard.
Disallowed costs must be repaid, with interest, and in serious cases trigger pass-through audits of other grants. The standard does not distinguish between intent and oversight.
Most agencies have records-retention schedules that prescribe minimum and maximum hold periods for each record series. Discarding too early (below minimum) violates state records law; holding too long (above maximum) creates discovery exposure and storage cost. Both errors are routine.
Records litigation typically lands between the minimum and maximum boundaries — the gray zone where the schedule could go either way. A consistently followed schedule is the best defense against claims of selective retention.
MSRB Rule 15c2-12 requires issuers to file notice of certain events within 10 business days. The list runs to 16 categories now, including some (insolvency of obligated person, modifications to rights of bondholders, financial obligations material to investors) that are easily missed without a tracking process.
A pattern of late or missed event filings can trigger SEC enforcement and impair the issuer's future market access. The reputational cost outlasts the immediate penalty.
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