Sarasota County Debt Management Policy - Resolution 2021-184

Sarasota County Debt Management Policy 6. Care should be taken that any information produced and maintained for public consumption, and which may be relied upon by an investor in making an investment decision in the primary or secondary market, is accurate as of its date of publication. 7. If you are not sure if it is material or not, err on the side of concluding that it is material. 8. Prior to undertaking any voluntary continuing disclosure filings, the County should first have a discussion with its Disclosure Counsel. If it is determined to be beneficial to undertake a voluntary continuing disclosure filing, the County should take care to be consistent in its filings when implementing a voluntary continuing disclosure program. Such voluntary filings can also be subject to federal securities law liability. Any voluntary continuing disclosure filings should contain no material omissions or misstatements. 9. Consideration should be made, based on consultation with Disclosure Counsel as to whether a public statement by a County official or the response by the County to an investor inquiry (e.g., a question from one of the County's bondholders) may be material enough to merit a voluntary Electronic Municipal Market Access (EMMA) filing in order to ensure that the County's bonds are trading based on equal access to material information. D. POLICIES 1. Preparation of Annual Continuing Disclosure Filing By February 28th of each year, the Director of Finance shall review the County's annual filing requirements in each active continuing disclosure undertaking to determine what financial information and operating data must be updated and filed on an annual basis, and when such filings should be submitted. The Director of Finance shall involve the Accounting Manager and Debt Analyst, as appropriate, in the preparation of the requisite updates. The Director of Finance shall comply with the annual filing requirements of all such undertakings. Process of preparation shall be the same as the preparation of Official Statements. The Director of Finance may employ the services of an outside dissemination agent to assist with the foregoing responsibilities. 28