Sarasota County Debt Management Policy - Resolution 2021-184

Sarasota County Debt Management Policy b. When reviewing for financial obligations, consider: debt obligations or a source of payment for, an existing or planned debt obligation; and guarantees thereof. The term "debt obligation" includes leases "that operate as vehicles to borrow money". The term 'financial obligation" does not include "ordinary financial and operating liabilities incurred in the normal course of the County's business", or municipal securities as to which a final official statement has been provided to the MSRB consistent with The Rule. 7. Determine if a Financial Obligation is Material Consider materiality when reviewing financial obligations for reportable events: a. Determine materiality by asking whether the information would be important to a reasonable investor making a decision of buy or sell the County's bonds (consider what is pledged, what is the priority, what is the size of the borrowing relative to the issuer's budget, what events of defaults were granted, what remedies were granted, etc.) When in doubt, err on the side of assuming it is material. b. Determine materiality based on whether the information would be important to the total mix of information made available to the reasonable investor. c. Review agreements associated with the financial obligation, such as covenants, events of default, remedies, and priority rights, to determine if they are material. 8. Ensure Reportable Event Filings are Timely and Complete When filing for a reportable event: a. File event notices within ten business days of the occurrence of the reportable event. b. Ensure any cover sheet for a filing is correct and appropriate. c. Determine if a summary or copy of an underlying document needs to be included in the filing of an event notice. d. Determine if a description, date, and other information, about the additional event disclosures, needs to be submitted. e. Determine which terms and conditions of the financial obligation require disclosure. These could include covenants, events of default, remedies, and priority rights. f. Decide to disclose the material terms either in a summary form or by posting the entire contract or agreement to EMMA. 34