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c. Special assessment or revenue debt will not be refunded unless the Finance <br /> Director determines that special assessments or other sufficient revenues will not <br /> be collected soon enough to pay off the debt fully at that call date. <br /> 4. Professional Services. The city shall use an outside bond attorney and an independent <br /> financial advisor to structure the sale. <br /> E. Debt Management Practices <br /> 1. Investment of bond proceeds. The city shall invest bond proceeds in a capital project <br /> fund. <br /> 2. Disclosure: The city shall comply with SEC rule 15(c)2(12) on primary and continuing <br /> disclosure. Continuing disclosure reports shall be filed no later than 180 days after <br /> receipt of the city's annual financial report. <br /> 3. Arbitrage Rebate: The city shall complete an arbitrage rebate report for each issue no <br /> less than every five years after its date of issuance. <br /> 34.Communication: The city will maintain frequent and regular communications with <br /> bond rating agencies about its financial condition and will follow a policy of full <br /> disclosure in every financial report and bond prospectus. The city will comply <br /> Securities Exchange Commission (SEC) reporting requirements. <br /> 4. The city has also adopted post issuance debt compliatice policy as a separate policy. <br /> F. Post issuance debt compliance policy <br /> The City Council (the "Council") of the City of Elk River,Minnesota (the "Ci ,") has <br /> chosen,by policy, to take steps to help ensure that all obligations will be in compliance <br /> with all applicable state and federal regulations. This policy may be amended, as necessary, <br /> in the future. <br /> Background <br /> The Internal Revenue Service (IRS) is responsible for enforcing compliance with the <br /> Internal Revenue Code (the "Code") and related regulations governing certain obligations <br /> (for example: tax-exempt obligations,Build America Bonds, Recovery Zone Development <br /> Bonds and various "Tax Credit"Bonds). The IRS expects issuers and beneficiaries of <br /> these obligations to adopt and implement a post-issuance debt compliance policy and <br /> procedures to safeguard against post-issuance violations. <br /> Post-Issuance Debt Compliance Policy Objective <br /> The City desires to monitor these obligations to ensure compliance with the IRS Code and <br /> related regulations governing such obligations. To help ensure compliance, the City has <br /> developed the following policy(the "Post-Issuance Debt Compliance Polices). The Post- <br /> Issuance Debt Compliance Policy shall apply to the obligations mentioned above, <br /> including bonds,notes,loans,lease purchase contracts, lines of credit, commercial paper <br /> or any other form of debt that is subject to compliance. <br /> The Finance Director of the City is designated as the City's gent who is responsible for <br /> post-issuance compliance of these obligations. However, to the extent obligations are <br /> Financial Management Policies Page 12 <br />