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C - 25 City of Pleasanton Operating Budget • FY 2023/24 - FY 2024/25 <br />APPENDIX C <br />13. ON-GOING DEBT ADMINISTRATION <br />The Director of Finance will regularly review the City’s outstanding obligations, particularly in declining <br />interest rate environments. When rates begin to approach levels at which refunding is cost-effective, <br />the City shall select a financing team to begin preparations for a refunding issue. <br />A. Continuing Disclosure <br />The Finance staff will ensure that the City’s annual financial statements and associated reports <br />are posted on the City’s web site. The City will also contract with Consultant(s) to comply with the <br />Securities and Exchange Commission Rule 15c2 by filing its annual financial statements and other <br />financial and operating data for the benefit of its bondholders on the Electronic Municipal Market <br />Access (EMMA) website of the Municipal Securities Rulemaking Board (MSRB). <br />B. Arbitrage Rebate Compliance and Reporting <br />The use and investment of bond proceeds must be monitored to ensure compliance with arbitrage <br />restrictions. Existing regulations require that issuers calculate rebate liabilities related to any bond <br />issues, with rebates paid to the Federal Government every five years and as otherwise required by <br />applicable provisions of the Internal Revenue Code and regulations. <br />The Director of Finance shall contract with a specialist to ensure that proceeds and investments are <br />tracked in a manner that facilitates accurate, complete calculations, and if necessary, timely rebate <br />payments. <br />C. Use of Bond Proceeds <br />The Director of Finance shall report to the City Council annually at the same time as the City’s annual <br />audited financial statements the actual use of bond proceeds to ensure the use is consistent with <br />intended use and that the proceeds are spent in accordance with tax requirements. <br />14. DEBT MANAGEMENT POLICY REVIEW <br />The Director of Finance will be involved in the annual review of this Policy to confirm compliance. The <br />annual review will occur in conjunction with the budget adoption. <br />The Director of Finance shall review this Policy at a minimum of every five (5) years and recommend <br />any changes to the City Manager and City Council.