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ILLINOIS SCHOOL DISTRICT BOND MARKET — UNDERWRITERS, BROKERS & ACCOUNTABILITY

Who profits from $43.8B in Illinois school district debt | MSRB EMMA Data | Forensic Audit 2026
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STATEWIDE BOND DEBT OVERVIEW

Total Bond Par On Record
$43.8B
Cumulative across all series
Districts with Active Bonds
451
of 864 Illinois school districts
Avg Debt Per District
$97M
Among districts with bonds
What This Money Funds: Illinois school districts issue General Obligation (GO) bonds to fund capital construction, building renovations, technology infrastructure, and debt refinancing. These bonds are backed by local property taxes — meaning taxpayers are the ultimate guarantors. Underwriters earn fees of 0.5%–2% of par value on each issuance. On $43.8B in total par, that represents $219M–$876M in underwriter fees paid by Illinois taxpayers.

MAJOR UNDERWRITERS & BROKERS — ILLINOIS SCHOOL DISTRICT BONDS

These firms structure, underwrite, and distribute Illinois school district municipal bonds. They earn underwriting spreads, financial advisory fees, and ongoing secondary market trading profits on taxpayer-backed debt.

Bernardi Securities

Primary Underwriter — Illinois Specialist

Chicago-based boutique public finance broker-dealer specializing entirely in Illinois municipal and school district bonds. One of the most active firms in the state for small-to-mid-size district GO bond issuances. As a dedicated Illinois specialist, Bernardi participates in the underwriting and distribution of bonds across dozens of Illinois school districts annually.

bernardisecurities.com

Raymond James Public Finance

Primary Underwriter — K-12 Education Specialist

Operates a dedicated Chicago fixed-income office focused on K-12 education financing. Raymond James is a primary underwriter nationwide for school bonds, with specific focus on Illinois referendum bonds and school project bonds. Their Illinois education finance team structures bond issuances for districts seeking voter-approved debt authorization.

raymondjames.com — Illinois Education Finance

Baird Public Finance

Financial Advisor & Underwriter — Middle Market Illinois

Major middle-market financial advisor and underwriting broker for school districts throughout Illinois. Baird regularly facilitates district debt issuances as both underwriter and financial advisor. Their Illinois school financing practice page specifically targets districts evaluating bond referendums.

rwbaird.com — Illinois School Financing

Stifel Institutional

National Underwriter — K-14 Education

Dominant national and regional broker-dealer that actively structures and distributes capital bonds for K-14 public education entities across Illinois. Stifel's public education practice handles large-scale bond issuances for major Illinois districts and maintains secondary market positions in Illinois school district paper.

stifelinstitutional.com

Secondary Market — Where Bonds Trade After Issuance

Fidelity Fixed Income

Retail & Institutional Secondary Market

Retail and commercial secondary market access to national municipal bond inventory. Clients can filter specifically by Illinois school district issuers to purchase already-issued bonds in the secondary market.

Charles Schwab BondDesk

Retail Secondary Market

Allows commercial and private clients to browse active secondary marketplace offerings for tax-exempt municipal bonds, filterable by state and purpose code — including Illinois school district bonds.

SURETY BONDS — SCHOOL TREASURER PROTECTION

Distinct from capital bonds: these are insurance products protecting districts against losses from treasurer misconduct or error. Illinois law requires school treasurers to be bonded.

One80 Intermediaries (Brokers' Risk)

IASB-Endorsed Surety Provider

Endorsed by the Illinois Association of School Boards (IASB) to underwrite Special Purpose and School Treasurer Bonds for Illinois public school districts.

one80.com

WCSIT (Workers' Comp Self-Insurance Trust)

Discounted Treasurer Surety Bonds

Offers discounted commercial surety bonds up to $15 million for Illinois public school district treasurers. Administered through the Illinois School District Activity Association framework.

wcsit-isda.com

TOP 20 ILLINOIS SCHOOL DISTRICTS BY TOTAL BOND DEBT

Total par value of all bond series on record in MSRB EMMA. Includes all series — some maturities may have been paid, refunded, or defeased. Figures represent cumulative taxpayer obligation.

#DistrictTotal ParSeries CountMSRB EMMA
1Elmhurst SD 205$1,209,054,16022EMMA →
2Salt Fork Community Unit District 512$1,008,980,0004EMMA →
3CCSD 204$978,295,0009EMMA →
4Belleville Twp HSD 201$790,805,00017EMMA →
5Ball Chatham CUSD 5$696,145,00026EMMA →
6Champaign CUSD 4$660,631,3684EMMA →
7CUSD 308$652,552,5369EMMA →
8CUSD 300$609,145,00012EMMA →
9Hall HSD 502$607,950,0006EMMA →
10Lake Forest CHSD 115$567,425,0003EMMA →
11Morris SD 54$563,780,00013EMMA →
12Park Ridge CCSD 64$551,300,0005EMMA →
13Bensenville SD 2$532,299,00019EMMA →
14Lemont Twp HSD 210$505,362,8038EMMA →
15Cahokia CUSD 187$503,603,5846EMMA →
16Woodland CCSD 50$497,225,0004EMMA →
17Belvidere CUSD 100$496,225,00013EMMA →
18Grayslake CCSD 46$495,360,00010EMMA →
19Barrington CUSD 220$485,885,0005EMMA →
20Antioch CCSD 34$482,700,00015EMMA →

Source: MSRB EMMA raw data, Illinois school districts only. Data as of audit date May 2026.

HOW TAXPAYERS CAN AUDIT SCHOOL DISTRICT BONDS

Step 1 — Search MSRB EMMA: Go to emma.msrb.org and search your district by name. View all bond issuances, official statements, and continuing disclosure filings.
Step 2 — Read the Official Statement: Each bond issuance has an Official Statement (OS) — a legal document disclosing the underwriter, financial advisor, bond counsel, and all fees paid. These are public record on EMMA.
Step 3 — Check Continuing Disclosure: Under SEC Rule 15c2-12, districts must file annual financial reports and material event notices on EMMA. Missing filings = federal securities violation. Search your district and check for gaps.
Step 4 — SEC Complaint (Bond Fraud): If your district has outstanding bonds and has failed to file required continuing disclosure reports, file a complaint at sec.gov/tcr. Cite SEC Rule 15c2-12 and MSRB Rule G-17. No attorney required.
Step 5 Request all bond resolutions, financial advisor contracts, underwriting agreements, and bond counsel invoices for the past 10 years The district must respond within 5 business days.

WHO IS BOND COUNSEL?

Bond counsel is the law firm that issues a legal opinion that the bonds are valid, tax-exempt obligations. In Illinois, the dominant bond counsel firms for school districts include:

Why Bond Counsel Matters for This Audit: Bond counsel firms are often the same firms that serve as general school district legal counsel — creating potential conflicts of interest. A firm advising a district on governance while also issuing bond opinions on that district's debt should be scrutinized under ARDC Rules 1.7 and 1.8 (conflicts of interest).

⚠ HEALTH/LIFE SAFETY (HLS) BONDS — NO VOTER APPROVAL REQUIRED

Critical Audit Finding: Illinois school districts can issue School Fire Prevention and Safety (SFPS) bonds for "health and life safety" violations without a voter referendum and exempt from PTELL tax-cap limitations. This is the primary mechanism districts use to bypass taxpayer oversight. Every district with outstanding HLS bonds must be audited for compliance.

50-Year History — From Tragedy to Taxpayer Vulnerability

YearEventAudit Significance
1958 Our Lady of the Angels School Fire, Chicago — 92 students and 3 teachers killed. The deadliest school fire in Illinois history fundamentally changed how the state regulated school facilities. Origin of modern HLS code — legitimate safety imperative that has since been exploited
1970s Illinois General Assembly amends 105 ILCS 5/17-2.11 — grants school boards explicit authority to issue non-referendum bonds for fire prevention, safety, and energy conservation. The SFPS bond program is born. The legal foundation: no voter approval required — established 50+ years ago and never repealed
1990s PTELL Enacted — HLS Bonds Exempted — When the Property Tax Extension Limitation Law (PTELL) went into effect capping property tax levy increases, Life Safety bonds were specifically carved out and remain exempt from PTELL caps. Districts in PTELL counties (collar counties, Chicago suburbs) can levy additional taxes for HLS bonds above the cap — invisible to most taxpayers
2000s–2010s Scope Expanded — Legislature adds ADA accessibility compliance, school security upgrades, and energy efficiency improvements to the approved list of HLS bond uses. Mandatory Regional Superintendent plan reviews added. Expanding approved uses = expanding potential for reclassification of capital projects as "life safety"
July 2024 New Legislation Effective — Illinois General Assembly passes additional reforms further loosening school district non-referendum bond structuring and borrowing powers. Most recent expansion of no-referendum bonding authority — districts have MORE power to bypass voters than ever before
Statutory Authority: 105 ILCS 5/17-2.11 (School Code Section 17-2.11) is the controlling statute. The Regional Superintendent approves HLS surveys and plan submissions. ISBE provides the regulatory handbook. No voter referendum is required at any stage — only a school board vote.

How the System Works — and How It Gets Abused

✓ Legitimate Use
  • Asbestos removal mandated by EPA
  • Fire alarm/sprinkler system upgrades per NFPA 101
  • Structural hazards identified in 10-year engineer survey
  • ADA accessibility repairs required by federal law
  • Boiler/HVAC replacements posing documented safety hazard
⚠ Common Abuse Patterns
  • Cosmetic renovations reclassified as "life safety" to avoid referendum
  • New construction bundled with minor safety items
  • Inflated engineer survey findings to justify larger bond amounts
  • Same contractor receiving no-bid HLS contracts repeatedly
  • ROE inspector approving surveys from connected architects

The Oversight Chain — and Its Weaknesses

StepWho Is ResponsibleAudit Weakness
10-Year Facility SurveyLicensed architect or engineer hired by the districtNo independent verification — district pays the surveyor
Violation SubmissionDistrict submits HLS survey amendments to Regional Superintendent (ROE)ROE has no enforcement mandate; rubber-stamp risk
Bond AuthorizationSchool board votes to issue SFPS bonds (no voter referendum)Bypasses PTELL; taxpayers have no direct say
Building Permit ReviewRegional Superintendent reviews sealed plansROE staff may lack engineering expertise
Construction InspectionsCalled-inspections by ROE or OSFM during constructionInspection records not centrally tracked — must
ISBE OversightStatewide guidelines and handbook; no active enforcement databaseNo single public dashboard — records siloed at each ROE

Where to Find HLS Data

Illinois State Board of Education (ISBE): Provides HLS handbook and regulatory framework.
Website: isbe.net/Pages/Health-and-Life-Safety.aspx
Regional Offices of Education (ROE): Primary custodians of HLS survey amendments, called-inspection records, and construction documents.
ROE Locator: isbe.net — Find Your ROE
Illinois Office of the State Fire Marshal (OSFM): Handles state-licensed facility inspections and enforces NFPA 101 Life Safety Code.
Website: sfm.illinois.gov

FOIA Template — HLS Bond Records Request

SEC Angle on HLS Bonds: SFPS bonds are sold to investors via the same MSRB EMMA system as GO bonds. If a district misrepresents the life safety basis for bond issuance in the Official Statement, that may constitute securities fraud under SEC Rule 10b-5 and MSRB Rule G-17. File SEC complaint at sec.gov/tcr.