Sarasota County Debt Management Policy - Resolution 2021-184

Sarasota County Debt Management Policy g. If a summary form was posted to EMMA, ensure the summary was accurate and complete. h. Consult with legal counsel regarding which terms and conditions to disclose. i. Determine if there are agreements in existing continuing disclosure undertakings to comply with The Rule as it may be amended. If there are, review the existing undertakings to determine if amendments are required, to include The Rule amendments, or if the amendments are automatically included by the terms of the existing undertakings. j. If the County failed to materially comply with previous commitments within the last five years, ensure the disclosure states that. 9. Document Compliance For any event filings: a. Maintain a document file. b. Maintain evidence that all procedures were followed. c. Maintain evidence that all proper reviews were conducted. 10. Staffing the Disclosure Process Consider the following staffing and communications issues: a. Identify personnel, including an obligated person, who can determine the occurrence of a reportable event and file notice on EMMA. b. Select an employee who will determine whether the government is experiencing financial difficulties. c. Have procedures in place to require proper communication between departments so that internal information silos are avoided. d. Know who is filing what, when, and where. e. Have a disclosure committee, which meets regularly, to consider new disclosures. 35