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25 <br />City of St. Anthony, Minnesota <br />Post -Issuance Debt Compliance Procedures <br />The City Council (the "Council") of the City of St. Anthony, Minnesota (the "City") has <br />adopted the attached Post -Issuance Debt Compliance Policy dated May 8, 2012. The Post - <br />Issuance Debt Compliance Policy applies to qualifying debt obligations issued by the City. <br />As directed by the adoption of the Post -Issuance Debt Compliance Policy, the Finance <br />Director of the City will perform the following Post -Issuance Debt Compliance Procedures <br />for all of the City's outstanding debt. <br />1. General Post -Issuance Compliance <br />a. Ensure written procedures and/or guidelines have been put in place for <br />individuals to follow when more than one person is responsible for ensuring <br />compliance with Post -Issuance Debt Compliance Procedures. <br />b. Ensure training and/or educational resources for post -issuance compliance <br />have been approved and obtained. <br />c. The Finance Director understands that there are options for voluntarily <br />correcting failures to comply with post -issuance compliance requirements <br />(such as remedial actions under Section 1.141-12 of the Treasury <br />Regulations and the ability to enter into a closing agreement under the Tax - <br />Exempt Bonds Voluntary Closing Agreement Program described in Notice <br />2008-31(the "VCAP Program")). <br />2. General Recordkeeping <br />a. Retain records and documents for the obligation and all obligations issued to <br />refund the obligation for a period of at least seven years following the final <br />payment of the obligation (or if such obligation is refunded, the final <br />payment of the refunding bond) unless otherwise directed by the City's <br />bond counsel. <br />b. Retain both paper and electronic versions of records and documents for the <br />obligation. <br />c. General records and documentation to be assembled and retained <br />i. Description of the purpose of the obligation (referred to as the project) <br />and the state statute authorizing the project. <br />ii. Record of tax-exempt status or revocation of tax-exempt status, if <br />applicable. <br />iii. Any correspondence between the City and the IRS. <br />iv. Audited financial statements. <br />v. Bond transcripts, official statements and other offering documents of <br />the obligation. <br />vi. Minutes and resolutions authorizing the issuance of the obligation. <br />vii. Certifications of the issue price of the obligation. <br />