8717-14 Adopting post-issuance compliance procedures

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C. The Compliance Officer is encouraged to attend seminars and other educational events, to acquire reference materials and to setup internal educational sessions with the assistance of legal counsel, financial advisors, and other professionals knowledgeable with respect to post - issuance compliance so as to assure adequate knowledge and understanding to carry out responsibilities under these procedures. 2. Obligations Spreadsheet. The Compliance Officer shall keep a ledger or spreadsheet of all of the City's outstanding Obligations. The spreadsheet shall include information relevant to each series of Obligations, including but not limited to principal amounts, maturity dates, interest rates, Yield rates, details of projects financed, completion dates of projects, if and when an allocation of Proceeds of Obligations has been made, whether Obligations are subject to rebate and if rebate calculations have been generated, due date of continuing disclosure filings, and any other relevant information. 3. Amendments /Changes to Obligations. If any changes to the Obligations are contemplated (i.e., change in maturity, interest rate or redemption terms), the Compliance Officer shall consult with Bond Counsel. If action has already been taken without consultation of Bond Counsel, consult with Bond Counsel to determine if remedial action must be taken. See USE OF PROCEEDS CHECKLIST AND REMEDIAL ACTION INSTRUCTIONS FOR NONQUALIFIED OBLIGATIONS — Part II REMEDIAL ACTION. 4. Transcripts. The Compliance Officer shall obtain a copy of the transcript for the Obligations from Bond Counsel. The Compliance Officer shall retain this a part of the records of the Obligations in compliance with "Record Retention" procedure set forth in Section 6. 5. IRS 8038 Filings. The Compliance Officer shall verify that 8038 has been completed and filed by Bond Counsel. If amended or late returns need to be filed, the Compliance Officer shall consult with Bond Counsel for preparation of the return and confirm mailing of the return. The Compliance Officer shall request, or have Bond Counsel request, a time - stamped copy of the filed return and maintain such copy with the transcript or other records relating to the Obligations. 6. Record Retention. The Compliance Officer shall maintain all records (including, but not limited to those fisted below) relating to a series of Obligations in written or electronic form until at least three (3) years after the last maturity of those Obligations has been paid off. In the case of Refunding Bonds, records relating to the Refunded Bonds and all records relating to the Refunding Bonds (including records of the original Obligations) must be retained until at least three (3) years after the final redemption date of both the original Obligations and the Refunding Bonds. All electronic records must be backed -up on a hard drive or other means typically used by the City. All written documents must be retained in the office of the Compliance Officer or a location designated by such Compliance Officer listed in Section 1 above. The following documents must be retained as set forth above: a. All documents relating to the Obligations including, but not limited to, the transcript, the form of the Obligations, and related certificates and opinions; 11