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---ARPEN HILLS <br />Post -Issuance Debt Compliance Procedures <br />The City Council of the City of Arden Hills has adopted the attached Post -Issuance Debt Compliance <br />Policy dated September 14, 2009. The Post -Issuance Debt Compliance Policy applies to all tax-exempt <br />debt obligations issued by the City of Arden Hills. As directed by the adoption of the Policy, the <br />Finance Director will perform the following Post -Issuance Debt Compliance Procedures for the <br />following tax-exempt debt obligation: <br />(Title of tax-exempt debt obligation) <br />1. General Post -Issuance Compliance <br />a. Ensure written procedures and/or guidelines have been put in place for individuals to follow <br />when more than one person is responsible for ensuring compliance with Post -Issuance <br />Procedures. <br />b. Ensure training and/or educational resources for post -issuance compliance have been <br />approved and obtained. <br />c. The Finance Director of the City of Arden Hills understands that there are options for <br />voluntarily correcting failures to comply with post -issuance compliance requirements (i.e. <br />Treasury Regulations 1.141-12 remedial actions, Tax -Exempt Bonds Voluntary Closing <br />Agreement Program and the ability to enter into a closing agreement under the Tax -Exempt <br />Bonds Voluntary Closing Agreement Program describer in Notice 2001-60). <br />2. General Recordkeeping <br />a. Retain records and documents for this tax-exempt debt obligation for a period of at least <br />three years following the final payment of the obligation of the final payment of any tax- <br />exempt refunding debt obligation unless otherwise directed by Bond Counsel. <br />b. Retain both paper and electron versions of records and documents for this tax-exempt debt <br />obligation. <br />c. General Records and Documentation to be Assembled and Retained <br />i. Description of the purpose of the tax-exempt debt obligation (referred to as the <br />project) and the state statute authorizing the project. <br />ii. Record of tax-exempt status or revocation of tax-exempt status <br />iii. Any correspondence between the City of Arden Hills and the IRS. <br />iv. Audited financial statements. <br />v. Bond transcripts, official statements and other offering documents of tax-exempt <br />debt obligations. <br />vi. Minutes and resolutions authorizing the issuance of tax-exempt debt obligations. <br />vii. Certifications of the issue price of tax-exempt debt obligations. <br />viii. Any formal elections for tax-exempt debt obligations (i.e. election to employ an <br />accounting methodology other than the specific tracing method). <br />ix. Appraisals, demand surveys, or feasibility studies for property financed by tax- <br />exempt debt obligations. <br />x. Documents related to governmental grants, associated with construction, renovations <br />or purchase of property financed with tax-exempt debt obligations. <br />xi. Reports of any prior IRS examinations of the City of Arden Hills or City's tax- <br />exempt debt obligations. <br />