3. Comm policy-Post Issuance Debt Compliance

CASS COUNTY COMMISSION POLICY MANUAL 21.52 SUBJECT: POST ISSUANCE DEBT COMPLIANCE POLICY ADOPTED DATE: AUGUST 4, 2014 PAGE 3 OF 9 b. Computations of the arbitrage yield. c. Computations of yield restriction and rebate amounts including but not limited to: i. Compliance in meeting the "Temporary Period from Yield Restriction Exception" and limiting the investment of funds after the temporary period expires. ii. Compliance in meeting the "Rebate Exception". 1. Qualifying for the "Small Issuer Exception" 2. Qualifying for a "Spending Exception" • 6 Month Spending Exception • 18 Month Spending Exception • 24 Month Spending Exception 3. Qualifying for the "Bona Fide Debt Service Fund Exception" 4. Quantifying arbitrage on all funds established in connection with the obligation in lieu of satisfying arbitrage exceptions (including Reserve Funds and Debt Service Funds) d. Computations of yield restriction and rebate payments. e. Timely Tax Form 8038-T filing, if applicable. i. Remit any arbitrage liability associated with the obligation to the IRS at each five year anniversary date of the obligation, and the date in which the obligation is no longer outstanding (redemption or maturity date), whichever comes sooner, within 60 days of said date. f. Timely Tax Form 8038-R filing, if applicable. g. Procedures or guidelines for monitoring instances where compliance with applicable yield restriction requirements depends on subsequent reinvestment of obligation proceeds in lower yielding investments (for example: reinvestment in zero coupon SLGS). 4. Expenditure and Asset Documentation to be Assembled and Retained a. Documentation of allocations of obligation proceeds to expenditures (i.e. allocation of proceeds to expenditures for the construction, renovation or purchase of facilities owned and used in the performance of exempt purposes).