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City of New Brighton, Minnesota <br /> Post-Issuance Debt Compliance Procedures <br /> The City Council (the "Council") of the City of New Brighton, Minnesota (the "City") has <br /> adopted the attached Post-Issuance Debt Compliance Policy dated . The Post-Issuance Debt <br /> Compliance Policy applies to qualifying debt obligations issued by the City. As directed by the <br /> adoption of the Post-Issuance Debt Compliance Policy, the Finance Director of the City will <br /> perform the following Post-Issuance Debt Compliance Procedures for all of the City's <br /> outstanding debt. <br /> 1. General Post-Issuance Compliance <br /> a. Ensure written procedures and/or guidelines have been put in place for individuals <br /> to follow when more than one person is responsible for ensuring compliance with <br /> Post-Issuance Debt Compliance Procedures. <br /> b. Ensure training and/or educational resources for post-issuance compliance have <br /> been approved and obtained. <br /> c. The Finance Director understands that there are options for voluntarily correcting <br /> failures to comply with post-issuance compliance requirements (such as remedial <br /> actions under Section 1.141-12 of the Treasury Regulations and the ability to <br /> enter into a closing agreement under the Tax-Exempt Bonds Voluntary Closing <br /> Agreement Program described in Notice 2008-31(the "VCAP Program")). <br /> 2. General Recordkeeping <br /> a. Retain records and documents for the obligation and all obligations issued to <br /> refund the obligation for a period of at least seven years following the final <br /> payment of the obligation (or if such obligation is refunded, the final payment of <br /> the refunding bond) unless otherwise directed by the City's bond counsel. <br /> b. Retain both paper and electronic versions of records and documents for the <br /> obligation. <br /> c. General records and documentation to be assembled and retained <br /> i. Description of the purpose of the obligation (referred to as the project) and <br /> the state statute authorizing the project. <br /> ii. Record of tax-exempt status or revocation of tax-exempt status, if <br /> applicable. <br /> iii. Any correspondence between the City and the IRS. <br /> iv. Audited financial statements. <br /> v. Bond transcripts, official statements and other offering documents of the <br /> obligation. <br /> vi. Minutes and resolutions authorizing the issuance of the obligation. <br /> vii. Certifications of the issue price of the obligation. <br /> viii. Any formal elections for the obligation (i.e. election to employ an <br /> accounting methodology other than the specific tracing method). <br />