Sarasota County Debt Management Policy - Resolution 2021-184
Sarasota County Debt Management Policy 11.Determining Enhancements to the Disclosure Process Consider the following when assessing potential enhancements to the disclosure process: a. Ensure all employees and officials, who possess relevant material information, are sufficiently involved in the disclosure process. b. Ensure officials with the appropriate authority, and knowledge of issuer-wide trends and risks, have reviewed disclosures. c. Ensure the various employees and officials who are involved in the disclosure process are working together and interacting with each other. d. Maintain key points in the disclosure process where the appropriate employees and officials are thinking about the big picture of the disclosure and considering whether as a whole it is complete and accurate. 12. Work with Disclosure Counsel Consider the following when working with Disclosure Counsel: a. Retain qualified Disclosure Counsel. b. Discuss any proposed voluntary disclosures with Disclosure Counsel prior to their issuance. The general rule is not to undertake any voluntary disclosures, unless there is a good reason to do so (obtaining pricing benefits with rating agencies and the investor community). c. Discuss with Disclosure Counsel any questions on materiality. d. Have Disclosure Counsel review these principles, policies and procedures for accuracy and completeness. e. Disclosure Counsel may not be included on a distribution list for certain financing transactions, such as bank loans. Consider adding Disclosure Counsel to the distribution list for such transactions so Disclosure Counsel can assist in any filings necessary as a result of such transaction. 13. Train Employees on the Continuing Disclosure Process Consider the following when training employees: a. Periodically train appropriate management and staff on The Rule filing requirements and procedures. 36
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