FINANCIAL POLICIES
Arbitrage Rebate Due to the complexity of arbitrage rebate regulations and the severity of non- compliance penalties, the City shall contract with an independent expert for preparation of the arbitrage rebate calculation in accordance with the IRS code and regulations.
The City shall maintain an internal system for tracking expenditure of bond proceeds and investment earnings by each issue with the assistance from its fiscal agent(s).
Continuing Disclosure The City established its Continuing Disclosure Compliance Procedures outlining its responsibilities as the issuer to make all reasonable efforts to assist underwriters in their efforts to comply with Security Exchange Commission or SEC Rule 15c2-12 and MSRB Rule G-36. The City will file Continuing Disclosure reports and/or certificates with the Electronic Municipal Market Access (EMMA) system, the official repository for information on all municipal bonds. The City will also provide a copy of its Annual Comprehensive Financial Reports (ACFR) upon request and will disseminate other information that it deems pertinent to the market as required. While initial bond disclosure requirements pertain to bond offering statements, the City will provide financial information and notices of material events on an ongoing basis throughout the life of the issue in accordance with agreements to do so on a transaction- by-transaction basis. With respect to conduit debt, continuing disclosure requirements will be provided by the City only if the City is contractually obligated to do so. The City is to be reimbursed by the borrower for the cost of providing continuing disclosure services. Post-Issuance Compliance Tax-exempt bonds issued by the City retain their tax-exempt status throughout the life of the issue if all applicable federal tax laws are satisfied while the bonds are outstanding. Various requirements apply under the Internal Revenue Code and Income Tax Regulations including information filing and other requirements related to issuance, the proper and timely use of bond-financed property, and arbitrage yield restriction and rebate requirements. Internal Control Procedures The City shall periodically review the requirements of and will remain in compliance with the following: I. Federal securities law, including any continuing disclosure undertakings under SEC Rule 15c2- 12 II. Any federal tax compliance requirements including without limitation arbitrage and rebate compliance III. The City's investment policies as they relate to the investment of bond proceeds IV. Government Code section 8855(k) and the annual reporting requirements therein
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FY 2023-25 Adopted Budget
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