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<br /> <br /> <br />Northland Securities, Inc. Page 7 <br />Attachment 3 – Related Considerations <br />Bank Qualification <br />We understand the City (in combination with any subordinate taxing jurisdictions or debt <br />issued in the City’s name by 501(c)3 corporations) anticipates issuing $10,000,000 or less in tax- <br />exempt debt during this calendar year. Therefore, the Bonds will be designated as “bank <br />qualified” obligations pursuant to Federal Tax Law. <br />Arbitrage Compliance <br />Project/Construction Fund. All tax-exempt bond issues are subject to federal rebate <br />requirements which require all arbitrage earned to be rebated to the U.S. Treasury. A rebate <br />exemption the City expects to qualify for is the “small issuer” exemption because the City <br />expects to issue less than $5,000,000 of tax-exempt bonds, including any 501(c)3 conduit <br />financings, in calendar year 2025. <br />Debt Service Fund. The City must maintain a bona fide debt service fund for the Bonds or be <br />subject to yield restriction in the debt service fund. A bona fide debt service fund involves an <br />equal matching of revenues to debt service expense with a balance forward permitted equal to <br />the greater of the investment earnings in the fund during that year or 1/12 of the debt service of <br />that year. <br />The City should become familiar with the various Arbitrage Compliance requirements for this <br />bond issue. The Resolution for the Bonds prepared by Bond Counsel explains the requirements <br />in greater detail. <br />Continuing Disclosure <br />Type: Full <br />Dissemination Agent: Northland Securities, Inc. <br />The requirements for continuing disclosure are governed by SEC Rule 15c2-12. The primary <br />requirements of Rule 15c2-12 actually fall on underwriters. The Rule sets forth due diligence <br />needed prior to the underwriter’s purchase of municipal securities. Part of this requirement is <br />obtaining commitment from the issuer to provide continuing disclosure. The document <br />describing the continuing disclosure commitments (the “Undertaking”) is contained in the <br />Official Statement that will be prepared to offer the Bonds to investors. <br />The City has more than $10,000,000 of outstanding debt and is required to undertake “full” <br />continuing disclosure. Full disclosure requires annual posting of the audit and a separate <br />continuing disclosure report, as well as the reporting of certain “material events.” Material <br />events set forth in the Rule, including, but not limited to, bond rating changes, call notices and <br />issuance of “financial obligations” (such as USDA loans, Public Finance Authority loans, and <br />lease agreements), must be reported within ten days of occurrence. The report contains annual <br />financial information and operating data that “mirrors” material information presented in the <br />Official Statement. The specific contents of the annual report will be described in the <br />Undertaking that appears in the appendix of the Official Statement. Northland currently serves <br />as dissemination agent for the City, assisting with the annual reporting. The information for the <br />Bonds will be incorporated into our reporting. <br />