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