8717-14 Adopting post-issuance compliance procedures

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POST - ISSUANCE COMPLIANCE PROCEDURES The federal tax laws impose a number of requirements for bonds and notes (collectively, "Obligations ") to constitute Tax - Exempt Obligations. Many of those requirement are addressed at the time of issuance; others require the City (as defined below) to monitor various attributes of the Obligations, the Proceeds of the Obligations and the use and disposal of facilities financed by those Obligations ( "Financed Facilities ") throughout the life of the Obligations. All of these requirements are set forth in the tax certificate executed at the time of issuance of each series of Obligations (the "tax certificate "), which should be consulted in addition to these procedures. The procedures set forth in this document are designed to ensure consistent compliance with the tax laws by the City over the term of each issuance of Tax - Exempt Obligations that are outstanding at the time of adoption of these procedures and Tax - Exempt Obligations that are issued after the adoption of these procedures. Throughout the term of each series of Obligations, the federal tax law requirements on which these procedures are based may change and may necessitate revisions to these procedures. The City of Lakewood, Ohio (the "City ") has adopted these procedures to help it comply with the tax law requirements that apply to the Obligations. Capitalized terms not defined in this checklist have the meanings in Attachment A. GENERAL MATTERS 1. Compliance Officer. Identify the officer(s) who will be responsible for each of the procedures listed below, advise the current holder(s) of that office of the responsibilities under these procedures, and provide that/those person(s) a copy of these procedures. If multiple individuals will monitor compliance, elaborate on the line below who those individuals are, what areas of compliance he /she is monitoring and how monitoring will be coordinated among individuals. In general, compliance officer will monitor the City's post- issuance responsibilities (including, but not limited to, rebate spending exceptions, calculation and payment; investment yield restrictions; tracking of expenditures of the Proceeds of Obligations; monitoring of the use of Financed Facilities for Private Business Use; together with any related filings due to the Internal Revenue Service ( "IRS "); compliance with financial covenants in the documents for each series of Obligations; monitoring of any Hedges or other derivative financial instruments entered into in connection with the Obligations; and general monitoring of any investments with Proceeds of Obligations). The Director of Finance is hereby designated as the compliance officer for the City (the "Compliance Officer"), The Assistant Director of Finance is hereby designated as the deputy or backup compliance officer and such individuals shall have access to all documents and records relating to these procedures, and any necessary usernames and passwords, and shall carry out the duties of the Compliance Officer in Compliance Officer's absence. a. Upon transition of the employee or officeholder designated as Compliance Officer, designation of new Compliance Officer as set forth above. Outgoing compliance officer or deputy backup Compliance Officer shall train the new Compliance Officer. b. Upon restructuring or elimination of position, identify the new Compliance Officer and train the individual pursuant to Section 1 a above.