2024-073 - Approving Revisions to the Municipal Securities

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Not less than 30 days before the submission date, the Disclosure Coordinator, in coordination with the Subject Matter Reviewers, shall prepare a draft submission of financial and operating information required to be included in the Annual Information Filing, highlighting any information still unavailable. Additionally, the draft of the Annual Information Filing and Audited Financial Statements shall be submitted to CAO for review. ANNUAL REPORT FILING PROCESS The Disclosure Coordinator along with the Subject Matter Reviewers shall review the drafts of the Annual Reports. The Disclosure Coordinator shall make any changes recommended by the Committee and resubmit the Annual Information Filings. The Disclosure Coordinator shall maintain and update the compliance files for each Continuing Disclosure Undertaking. On or before the submission date established under each Continuing Disclosure Undertaking, the Disclosure Coordinator or the dissemination agent, if applicable, shall file the Annual Report with the MSRB using EMMA the Annual Information Filing that includes any changes recommended by the Committee. If the Audited Financial Statements are not available, unaudited financial information shall be filed with the MSRB using EMMA and the Audited Financial Statements shall be filed within 10 business days of their receipt and acceptance. LISTED EVENTS The Rule also requires filing of a Rule 15c2-12 Event Notice upon the occurrence of certain listed events described in the Continuing Disclosure Undertakings including rating changes. The Disclosure Coordinator shall coordinate the preparation and filing of any Rule 15c2-12 Event Notice to the MSRB using EMMA within 10 business days of occurrence of any such listed event. The listed events most likely to occur on a regular basis relate to bond redemptions or defeasances of outstanding issues and rating changes. REPORTING REQUIREMENTS The Committee shall identify any incidents of non-compliance and prepare a report for the City Manager, Executive Director of Finance and the CAO. Such report shall include recommendations to resolve any non-compliance with the respective Continuing Disclosure Undertaking. AUDITED FINANCIAL STATEMENTS (COMPREHENSIVE ANNUAL FINANCIAL REPORT) The Committee shall review and provide feedback in the preparation of the Management Discussion & Analysis (MD&A) and the debt -related footnotes to the Audited Financial Statements. Additionally, the Committee along with the disclosure counsel shall compare the MD&A and related footnote sections to the Annual Information Filing and any Preliminary Official Statement being prepared at the time to ensure consistency. RECORDS RETENTION The Disclosure Coordinator shall maintain records with respect to the filings with the MSRB using EMMA, including, but not limited to, EMMA posting receipts showing dates and nature of contents of all filings for each issue of Obligations outstanding. Resolution No. 2024-073