Subject: File No. S7-2024-05
From: St. Lucie Clerk and Comptroller St. Lucie County

Stakeholder FDTA Implementation Comments.
Vanessa Countryman
Secretary, Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
 
Re: Financial Data Transparency Act, File No. S7-2024-05
Via electronic submission: SEC.gov | Financial Data Transparency Act Joint Data Standards

October 21, 2024

On behalf of St. Lucie Clerk and Comptroller, we write today to provide comments on S7-2024-05, the Proposed Rule to establish data standards and impose other mandates in order to implement the Financial Data Transparency Act. As a government/entity with outstanding bonds and looking to access the bond market in the future – we are very interested in how the federal government will develop this and additional rulemaking. We are concerned about how this will impact how our government prepares financial and disclosure information. 

We concur with comments made by issuer organizations, especially the Government Finance Officers Association and urge regulators to carefully review these comments.  GFOA’s more in-depth analysis and discussion of the concerns of the issuer community strongly reflect what we are likely to experience here in St. Lucie Clerk and Comptroller. 
At the St. Lucie Clerk and Comptroller's office, we prioritize financial transparency by leveraging both advanced reporting practices and innovative technologies to ensure that the public can easily access detailed financial information. One example of this commitment is our updated website and our financial dashboard that allows citizens to explore financial data in a user-friendly format. Our Annual Comprehensive Financial Report (ACFR), which includes hundreds of pages of detailed financial information, is available in an organized and searchable format online. This tool provides access to budget summaries, revenue breakdowns, expenditure tracking, and more. 
In terms of technology, we are implementing automated financial reconciliation software, which significantly improves the accuracy and efficiency of financial reporting. This technology reduces manual errors and ensures that financial statements are reconciled in real-time, providing p-to-date financial positions that are available to the public much faster than traditional methods.
By combining transparency initiatives with cutting-edge technology, we aim to make financial information accessible, accurate, and understandable for our citizens while maintaining the highest standards of excellence in financial reporting

While we stand by our robust reporting standards, we are aware that the SEC and other regulators may continue with efforts to impose mandates on how our financial information is submitted to regulators. Regulators must avoid any actions that would conflict with the Tower Amendment, and provisions in the FDTA prohibiting any new disclosure requirements. Additionally, the SEC should strongly consider utilizing the provision in the FDTA to scale implementation and mandates of the law in our sector and avoid burdening small governments and entities. The SEC should focus on minimizing “market disruption” and we can focus on what is practical and feasible. This will help to minimize costs for our taxpayers and limit the possibility of disruption in the municipal securities market.

Changes to the way we develop our financial information into a structured data format could take considerable staff time and resources to find consultants and programs to comply with these mandates.  Specifically, we estimate implementation may cost hundreds of thousands of dollars to implement and complete this information yearly. The questions and costs associated with this are listed below. 

•	Costs of software, technology, consultants to implement and maintain it.
•	Staff for training and onboarding.
•	Costs for compliance with new rules and regulations.
•	Bond market access if you cannot comply with new rules and regulations.

We understand that there are other elements of the rulemaking that could also be imposed on issuers and others in the municipal securities market.   As regulators consider these items going forward, they need to be aware that the elements that apply to corporate entities and the federal government face greater hurdles for local governments, including St. Lucie Clerk and Comptroller's office.  

The best way for the SEC and other regulators to understand how governments like ours currently prepare financial and disclosure information, and to understand how any new mandates would affect us and work in our sector is to have conversations with us.  The law calls on regulators to consult with issuers and other market participants, and that should be the first step of many, as this proposed rule is finalized, and additional rulemaking is developed.  

This law is an unfunded federal mandate on St. Lucie Clerk and Comptroller's office and tens of thousands of others across the country. We hope that the examples and information we provided, as well as ongoing conversations, will assist in thoughtful and workable rules that, if needed, our government can easily implement without extensive burden.









Thank you for the opportunity to submit these comments.  We welcome the opportunity to discuss any of these issues in greater detail with regulators as the process moves forward.

Sincerely, 

St. Lucie Clerk and Comptroller's office