Sarasota County Debt Management Policy - Resolution 2021-184

Sarasota County Debt Management Policy C. ARBITRAGE COMPLIANCE The Clerk and Comptroller maintains a system of record keeping and reporting to meet the arbitrage rebate compliance requirements of the federal tax code. All arbitrage rebate calculations are completed by an outside arbitrage consultant. Arbitrage rebate liabilities are calculated annually and the liability reported in the County's annual financial statements. D. TAX-EXEMPT DEBT POST ISSUANCE COMPLIANCE There are certain post-issuance federal tax requirements that must be met pursuant to Sections 103 and 141 through 150 of the Internal Revenue Code of 1986, as amended. In order to monitor such post issuance requirements, the Clerk and Comptroller have adopted policies and procedures with respect to Form 8038, Information Return for Tax-Exempt Private Annuity Bond Issues, compliance. A copy of the guidelines can be found in the proceeding Section VII; Tax-Exempt Debt Post- Issuance Compliance Guidelines section of this Debt Management Policy. E. FINANCING PROPOSALS Any capital financing proposal to a County operating department, agency, or utility involving a pledge or other extension of the County's credit through sale of securities, execution of loans or leases, marketing guarantees, or otherwise involving directly or indirectly the lending or pledging of the County's credit, will be referred to and reviewed by the Clerk and Comptroller Director of Finance (Director of Finance) and the Director of the OFM, or their respective designees. Any decision to act on such proposal will require final approval by the Board. F. CONDUIT BOND FINANCING Periodically the County is approached with a request to provide conduit financing for qualified projects using Sarasota County Health Facilities Authority Bonds or Sarasota County Industrial Development Revenue Bonds. Applications for such issues are processed pursuant to guidelines approved by the Board, including credit rating requirements, private placement requirements and the purpose of the borrowing issue. The Debt Management Team will assist the Health Facilities Authority and Industrial Development Revenue Bond Citizens Advisory Committee to conduct the required public hearing and provide a final funding recommendation to the Board. The County requires complete indemnification from third parties seeking conduit bond financing and does not accept any liability associated with conduit bond financings. Therefore, the County will not recognize a conduit bond financing as a liability. 12