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Municipal Securities Disclosure Policy & Procedures <br />Page 4 <br />June 21. 2016 <br />Not less than 30 days before the submission date, the Disclosure Coordinator, in coordination with the <br />Subject Matter Reviewers, shall prepare a draft submission of financial and operating information <br />required to be included in the Annual Information Filing, highlighting any information still unavailable. <br />Additionally, the draft of the Annual Information Filing and Audited Financial Statements shall be <br />submitted to CAO for review. <br />ANNUAL REPORT FILING PROCESS <br />The Disclosure Coordinator along with the Subject Matter Reviewers shall evaluate all the components <br />of the Annual Reports and make the appropriate updates. Following the updating of the Annual Reports, <br />the Committee shall review the drafts of the Annual Reports. The Disclosure Coordinator shall make any <br />changes recommended by the Committee and resubmit the Annual Reports to the Committee. <br />Subsequent to the final approval by the Committee, the Disclosure Coordinator along with the Santa Ana <br />Issuers' Dissemination Agent shall finalize the Annual Reports. The Disclosure Coordinator shall maintain <br />and update the compliance files for each Continuing Disclosure Undertaking. <br />On or before the submission date established under each Continuing Disclosure Undertaking, the <br />Disclosure Coordinator or the dissemination agent, if applicable, shall file the Annual Report. If the <br />Audited Financial Statements are not available, unaudited financial information shall be filed with the <br />MSRB using EMMA and the Audited Financial Statements shall be filed within 10 business days of their <br />receipt and acceptance. <br />LISTED EVENTS <br />The Rule also requires filing of a Rule 15c2 -12 Event Notice upon the occurrence of certain listed events <br />described in the Continuing Disclosure Undertakings including rating changes. The Committee shall <br />provide a Rule 15c2 -12 Event Notice to the MSRB using EMMA within 10 business days of occurrence of <br />any such listed event. <br />The listed events most likely to occur on a regular basis relate to bond redemptions or defeasances of <br />outstanding issues and rating changes. The Disclosure Coordinator shall, on a periodic basis, monitor all <br />of the Santa Ana Issuers transactions which are rated or insured. <br />REPORTING REQUIREMENTS <br />The Committee shall identify any incidents of non - compliance and prepare a report for the City <br />Manager, Executive Director of Finance and the CAO. Such report shall include recommendations to <br />resolve any non - compliance with the respective Continuing Disclosure Undertaking. <br />AUDITED FINANCIAL STATEMENTS (COMPREHENSIVE ANNUAL FINANCIAL REPORT) <br />The Committee shall review and provide feedback in the preparation of the Management Discussion & <br />Analysis (MD &A) and the debt - related footnotes to the Audited Financial Statements. Additionally, the <br />Committee along with the disclosure counsel shall compare the MD &A and related footnote sections to <br />the Annual Information Filing and any Preliminary Official Statement being prepared at the time to <br />ensure consistency. <br />55C -46 <br />