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Oppose Inclusion of Costly State, Local Government Bond Reporting Mandate in National Defense Bill

The National Special Districts Coalition encourages Member associations and districts to contact their U.S. Senators and urge them to oppose an amendment to the Fiscal Year 2023 National Defense Authorization Act (NDAA) that would require a standardized federal reporting requirement and could create a $1.5 billion unfunded mandate for bond-issuing state and local government.


Primary supporters of S. 4295 (Warner), the Financial Data Transparency Act, are seeking to add the legislation as an amendment to the must-pass NDAA. The Senate is expected to consider the defense bill between Election Day and the end of the year.

Specifically of concern is Section 203 of the amendment, which would require major federal financial agencies to standardize regulatory/disclosure reports. All public data reporting would be required to be inter-operable for consistency, and would be required to be searchable, using the same requirements across the agencies.

Currently, municipalities abide by various public records and financial laws with federal requirements and a myriad of state public records laws. All affected federal agencies would be required to finalize rulemaking for standardized financial data reporting, then would have two years to finalize implementation of data reporting requirements.

This means special districts and other local agencies subject to financial data reporting guidelines, such as those issuing bonds and holding investments, would be required to comply with a new federal standardized system to be implemented by 2027.


Call your Senator and urge them to oppose including the Financial Data Transparency Act in the NDAA. Click here to look up your Senator’s contact information.

 Talking Points & Discussion Guide

  • Introduce your district / organization, your position with the district, what types of district services are offered, and share how many residents receive district services.
  • We are concerned with efforts to include Section 203 of the Financial Data Transparency Act in the National Defense Authorization Act.
  • Doing so would put in motion swift development and implementation of an unnecessary and costly financial reporting mandate on state and local governments.
  • The bill would require standardization of reports across multiple federal agencies based on common municipal securities reporting metrics of all state and local governments. This could actually lead to the loss of important reported information.
  • These requirements would differ from wildly accepted and used financial accountability standards currently used to follow state and federal reporting laws.
  • The bill calls for a reporting format that could require state and local agencies to install new software for compliance. This unfunded mandate could total $1.5 billion.
  • If your district issues bonds and must report to federal agencies governed by the Municipal Securities Rulemaking Board, share how this could impact your district.
  • We value and promote the necessity of public agencies’ transparency and accountability and comply with all state and federal financial reporting requirements, but we are concerned about the costs associated with the Financial Data Transparency Act.
  • Please oppose including the Financial Data Transparency Act in the National Defense Authorization Act.


For questions, contact Cole Arreola-Karr, NSDC Federal Advocacy Director, at


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