EXCEPTIONS There are several exceptions to the rebate requirements which are reviewed for each issue. Some of these are listed and described very briefly below. • Small Issuer – the issuer must reasonably expect to issue $5 million or less in tax‑exempt debt in one calendar year. Sarasota County has not used this exception. • Six‑Month – the proceeds plus interest earnings are expended for the governmental purpose within six months of receipt. This exception has been used on various County debt issues. • Eighteen‑Month – the proceeds plus interest earnings are expended for the governmental purpose at the following intervals: 15% within 6 months, 60% within 12 months, and 100% within 18 months. This exception is available for debt issued after June 30, 1993. This exception has been used on various County debt issues. • Twenty‑Four‑Month – for construction issues only, this exception is available only for issues delivered after December 19, 1989. The proceeds plus investment earnings must be expended for their governmental purpose according to the following schedule: 10% at 6 months, 45% at 12 months, 75% at 18 months, and 100% at 24 months. This exception has been used on various debt issues. As long as the County meets one of these exceptions, the issue is monitored internally. If one of the period calculations fails, the issue is then turned over to the Consultant. The Consultant then prepares the rebatable arbitrage calculations for the life of the issue. MONITORING DEBT In accordance with the federal tax code, Sarasota County maintains arbitrage data on every issue of tax‑exempt debt. As debt is issued each year, the list of issues requiring arbitrage compliance increases. The arbitrage rebate rules were enacted for tax‑exempt debt issued after August 31, 1986. Historically, the County has had 70 bond issues affected by these regulations, two of which were issued under the penalty election. Currently, the County has 25 bond issues, 18 commercial paper draws and 11 bank term loans that are tracked for rebate by the County’s Consultant. It is vital that each Business Center monitor their projects to minimize arbitrage costs. The amount to be borrowed should be carefully estimated in the planning stages so that the spend‑down requirements can be met. Project expenditures should be monitored to ensure compliance with the spend‑down requirements. If the spend‑down requirements are met, the County does not incur any arbitrage costs and the interest earnings may be retained. A detailed history of all bonds, commercial paper and bank term loans issued under the arbitrage rebate regulations accompanies this report. For each issue, the column titled “Arbitrage Calculation” indicates the penalty election if it was chosen. The “Payment” column displays the total amount of rebate or penalty actually paid for each issue, while the “Liability” column represents the amount that was reported in the September 30, 2023 audited financial statements. SarasotaClerk.com 47 2023 INDEBTEDNESS
RkJQdWJsaXNoZXIy MzM3Mjg=