8717-14 Adopting post-issuance compliance procedures

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o. All compliance reports prepared in accordance with these procedures. 7. Calendar System. The Compliance Officer shall maintain a calendar system to assure any deadlines for rebate calculations or payments, yield restriction, IRS filings and other dates relevant to the Obligations are monitored and actions can be taken sufficiently in advance of any such deadlines to assure compliance with the required tasks. The Compliance Officer shall confirm that these procedures have been reviewed on an annual basis. Date of amoral review in each calendar year: July 31 (i.e., by January 31st of each calendar year). The Compliance Officer shall complete a memo or report stating when annual review was completed and file such memo or report with the transcript or other records relating to the Obligations. 8. Continuing Disclosure. Pursuant to Rule 15c2 -12, the City has agreed to make certain periodic filings (i.e., certain annual operating data, annual financial statements and event notices as set forth in either the authorizing legislation or the continuing disclosure agreement) with the Municipal Securities Rulemaking Board's Electronic Municipal Market Access system. The Compliance Officer shall determine the requirements of the City's continuing disclosure undertakings, filing deadlines, the preparation of the annual information statement, the procedure for filing of specified event notices and the determination of whether any information must be filed with a bond insurer. 9. Compliance Questionnaires. Upon receipt of a compliance questionnaire sent by the IRS, the Compliance Officer shall contact Bond Counsel and /or complete the questionnaire in a timely manner and return it to the IRS prior to its due date. 10. IRS Audit Requests. Upon receipt of an audit request sent by the IRS, the Compliance Officer shall contact Bond Counsel to prepare and respond to the audit request. 11. Private Letter Rulings. The Compliance Officer shall contact Bond Counsel for discussion and explanation of the private letter ruling process. 12. Advice of Counsel. The Compliance Officer may obtain advice and counsel from Bond Counsel or other legal counsel.