Alpha Covenant Holdings · Duty Sheet · generated 2026-10-26 21:03 UTC · free · all sheets

Municipal bond and P3 financings — underwriter and bond counsel diligence record on project participants (SEC Rule 15c2-12 context; Exchange Act antifraud provisions)

Applies to: Underwriters, municipal advisors and bond counsel assembling the Official Statement and the closing transcript for a financing whose proceeds pay a concessionaire, design-builder, operator or major vendor · Rule text: https://www.ecfr.gov/current/title-17/chapter-II/part-240/section-240.15c2-12

The question the rule asks

Rule 15c2-12 governs the issuer's disclosure undertaking; the underwriter's own reasonable-basis diligence on the Official Statement rests on the antifraud provisions. Where a project participant's standing is material to the offering, what did SAM.gov Exclusions, EPA ECHO, OSHA, the OIG LEIE, OFAC and the participant's state registry print under its exact name and keys on pricing day — and which files did not answer? Materiality and what the Official Statement must say are counsel's judgments.

The party this sheet is about

Colonial Pipeline Company · keys supplied: none — exact printed name only · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_1c6a6a752bbe4a1e · read 2026-10-26 21:03:47 UTC · SHA-256 a776efa390f825aa8d1755daffe635e410ed6817df81b34114dc839df4f00a38 · verify: https://alphacovenantholdings.com/r/r_1c6a6a752bbe4a1e

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
SAM.gov Exclusions — Public Extract V2 (GSA, daily)answers the questionanswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-26 (SAM_Exclusions_Public_Extract_V2_26299.ZIP).
EPA ECHO (Enforcement and Compliance History Online) — facility recordssupportinganswered0ECHO returned 235 facility record(s) for a name search on 'Colonial Pipeline Company'; 0 carry this exact printed name. Each row links to EPA's own Detailed Facility Report.
OSHA inspection records (DOL Enforcement API — inspections opened in the last five years, by establishment name as OSHA prints it)supportinganswered00 OSHA inspection(s) opened since 2021-10-27 under this exact printed establishment name
HHS Office of Inspector General — LEIE (monthly downloadable file)supportinganswered0No entry under this exact name in the OIG file fetched 2026-10-25.
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)supportinganswered0No entry under this exact name or listed alias on the SDN list fetched 2026-10-25.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directlysupportinganswered00 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
Federal Audit Clearinghouse (GSA) — single audit filings under 2 CFR 200 Subpart FsupportingansweredNo single-audit filing is on file for this exact name. Entities below the federal-spending threshold do not file; this is not a finding.
SEC EDGAR (registrant submissions index, data.sec.gov)supportinganswered0EDGAR's entity index lists no registrant under this exact printed name (a registrant may file under a different printed name — see the EDGAR company search).
USAspending.gov (recipient name equals this name)supportingansweredNo registered recipient equals this exact name.
SAM.gov entity registrationcross-sourcedid not answer — nothing stands in for it
State checkbooks & UCC (VT, DE, CT)cross-sourceanswered0no payments under the exact printed name in the states read

What to record in the file

One dated receipt per named participant on pricing day (a roster receipt for the whole participant list), each with its sources' file dates and SHA-256; the diligence lead's decision record bound to the receipt with the deal name as the reference. Filed in the transcript as what the public record printed on that date — not as a conclusion about any participant.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections