2016-051 - Adoption of Municipal Securities Disclosure Policy and Procedures

Home Browse Search

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 Committee shall provide a 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. The Disclosure Coordinator shall, on a periodic basis, monitor all of the Santa Ana Issuers transactions which are rated or insured. 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. TRAINING To ensure adequate resources to comply with the Continuing Disclosure Undertakings, the Disclosure Coordinator shall develop a training process aimed at providing additional assistance in preparing required information. The training process shall be conducted at least every other calendar year and shall encompass a review of the EMMA submission process and an understanding of the timing requirements necessary for full compliance with the Continuing Disclosure Undertakings. Resolution No. 2016-051 Page 7 of 7