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CASS COUNTY <br /> COMMISSION POLICY MANUAL 21.52 <br /> SUBJECT: POST ISSUANCE DEBT COMPLIANCE POLICY <br /> ADOPTED DATE: AUGUST 4, 2014 PAGE 4 OF 9 <br /> i. Such allocation will be done not later than the earlier of: <br /> eighteen (18) months after the later of the date the expenditure is paid, <br /> or the date the project, if any, that is financed by the tax-exempt bond <br /> issue is placed in service; or the date sixty (60) days after the earlier of <br /> the fifth anniversary of the issue date of the tax-exempt bond issue, or <br /> the date sixty (60) days after the retirement of the tax-exempt bond <br /> issue. <br /> b. Documentation of allocations of obligation proceeds to issuance costs. <br /> c. Copies of requisitions, draw schedules, draw requests, invoices, bills and <br /> cancelled checks related to obligation proceed expenditures during the <br /> construction period. <br /> d. Copies of all contracts entered into for the construction, renovation or <br /> purchase of facilities financed with obligation proceeds. <br /> e. Records of expenditure reimbursements incurred prior to issuing bonds for <br /> facilities financed with obligation proceeds (Declaration of Official <br /> Intent/Reimbursement Resolutions including all modifications). <br /> f. List of all facilities and equipment financed with obligation proceeds. <br /> g. Depreciation schedules for depreciable property financed with obligation <br /> proceeds. <br /> h. Documentation that tracks the purchase and sale of assets financed with <br /> obligation proceeds. <br /> i. Documentation of timely payment of principal and interest payments on <br /> the obligation. <br /> j. Tracking of all issue proceeds and the transfer of proceeds into the debt <br /> service fund as appropriate. <br /> k. Documentation that excess earnings from a Reserve Fund is transferred to <br /> the Debt Service Fund on an annual basis. Excess earnings are balances <br /> in a Reserve Fund that exceed the Reserve Fund requirement. <br /> 5. Miscellaneous Documentation to be Assembled and Retained <br /> a. Ensure that the project, while the obligation is outstanding, will avoid IRS <br /> private activity concerns. <br /> i. The County Auditor shall monitor the use of all obligation-financed <br /> facilities in order to: <br /> determine whether private business uses of obligation-financed <br /> facilities have exceeded the de minimus limits set forth in <br /> Section 141(b) of the Code as a result of sale of the facilities <br />