Post-issuance Compliance for Tax Exempt Bonds and Tax Credit Bonds

BP 8-180

EFFECTIVE: December 10, 2014
APPROVED: December 10, 2014

REFERENCES: Internal Revenue Code and Regulations and Securities and Exchange Commission’s Rule 15c2-12

/Richard E. Martinez Jr./
Richard E. Martinez Jr., Chair

Policy Statement

In compliance with the Internal Revenue Service recommendation that issuers of municipal bonds assist with the efforts to administer the income tax laws by adopting written policies and procedures that are intended to assure that appropriate compliance measures are implemented by such issuers after their bonds have been issued, the Board adopted Resolution 01-2014 to constitute and memorialize formally its postissuance compliance policies and procedures (the “PICPP”) that the Board had previously adopted or followed in connection with the issuance of the Issuer’s TaxAdvantaged Bonds.

The PICPP also contains undertakings to insure compliance with the Securities and Exchange Commission’s Rule 15c2-12 (the “Rule”). The Post Issuance Compliance Officer (the “PICO”) will also be responsible for taking the necessary actions so that the System is in compliance with the Rule.

The Board will annually review implementation of its PICPP as initially adopted by the Board through Resolution 01-2014 and as subsequently revised by resolution of the Board.

The System President may promulgate such procedures as deemed necessary to implement this policy.