Sarasota County Debt Management Policy - Resolution 2021-184

Sarasota County Debt Management Policy 8. RESPONSIBILITY OF COUNTY OFFICIALS Generally, publicly offered bonds issued by state and local governments are subject to ongoing monitoring and reporting with respect to federal disclosure requirements pursuant to their CDAs, as well as compliance with federal tax requirements specifically related to tax-exempt bonds. In addition to federal securities and tax requirements, issuers may face a variety of other compliance obligations, such as bond indenture requirements, state and local law and policy requirements. Comprehensive post-issuance compliance consists of policies and procedures designed to assist an issuer of bonds in complying with all of the relevant requirements that apply to each series of bonds from the date they are issued until the bonds are no longer "outstanding". Market disclosure in general is subject to the anti-fraud rules under the federal securities laws. Disclosures by issuers are generally made in three contexts: (1) primary market disclosure through offering documents prepared for primary offerings of securities; (2) secondary market disclosures prepared in compliance with undertakings under The Rule; and (3) releases and/or statements by the issuer and its officials that are reasonably expected to reach investors and the trading markets, such as communications through investor websites, press releases or other public responses. The County has engaged Disclosure Counsel to advise the County with respect to disclosure obligations and requirements under the federal securities laws. C. PRINCIPLES 1. Everyone involved in the County disclosure process should be encouraged to raise potential disclosure items at all times in the process. 2. Everyone should be encouraged to err on the side of raising issues to the next level of the review chain. 3. It should be made clear that all participants in the disclosure process should feel free to raise any issue with the Director of Finance at any time. 4. While care should be taken not to shortcut or eliminate any steps outlined in these guidelines on an ad hoc basis, they are a continuing process and recommendations for improvement should be solicited and regularly considered. 5. The process of primary disclosure should not be viewed as a mechanical insertion of current information and data. Everyone involved in the preparation of official statements should consider the need for revisions in the form and content of the sections for which they are responsible at the time of each update. 27