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 8 OF 9 Post-Issuance Debt Compliance Policy The County Auditor is designated as the County's agent who is responsible for post- issuance compliance of these obligations. The County Auditor shall assemble all relevant documentation, records and activities required to ensure post-issuance debt compliance as further detailed in corresponding procedures (the "Post-Issuance Debt Compliance Procedures"). At a minimum, the Post-Issuance Debt Compliance Procedures for each qualifying obligation will address the following: 1. General post-issuance compliance; 2. Proper and timely use of obligation proceeds and obligation-financed property; 3. Arbitrage yield restriction and rebate; 4. Timely filings and other general requirements; 5. Additional undertakings or activities that support points 1 through 4 above; 6. Maintenance of proper records related to the obligations and the investment of proceeds of obligations; 7. Other requirements that become necessary in the future. The County Auditor shall apply the Post-Issuance Debt Compliance Procedures to each qualifying obligation and maintain a record of the results. Further, the County Auditor will ensure that the Post-Issuance Debt Compliance Policy and Procedures are updated on a regular and as needed basis. The County Auditor or any other individuals responsible for assisting the County Auditor in maintaining records needed to ensure post-issuance debt compliance, are authorized to expend funds as needed to attend training or secure use of other educational resources for ensuring compliance such as consulting, publications, and compliance assistance. Most of the provisions of this Post-Issuance Debt Compliance Policy are not applicable to taxable governmental obligations unless there is a reasonable possibility that the County may refund their taxable governmental obligation, in whole or in part, with the proceeds of a tax-exempt governmental obligation. If this refunding possibility exists, then the County Auditor shall treat the taxable governmental obligation as if such issue were an issue of tax-exempt governmental obligations and comply with the requirements of this Post-Issuance Debt Compliance Policy.