Financial Policies

City of El Mirage — Regular Meeting (2021-06-01)

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Financial Management Policies 
 
 
Financial Management Policies 
Revised June 1, 2021                                               
Revised June 18, 2019                                   
Revised June 7, 2016                                   
Revised May 21, 2013                                
Adopted June 19, 2012 
Sound financial policies provide guidance and assurance to the community that the City is 
following best practices.  The Government Finance Officers Association recommends that 
financial policies be developed and formally adopted by the jurisdiction’s governing board.  
These policies are subject to review and refresh at any time.

Financial Management Policies 
 
 
Table of Contents 
 
Policy 
Title 
Page 
 
 
 
1 
Financial Management Goals 
1 
 
 
 
2 
Policy Review 
2 
 
 
 
3 
Budget 
3 
 
 
 
4 
Cash Management and Investment 
8 
 
 
 
5 
Capital Improvement Plan 
9 
 
 
 
6 
Debt Management 
10 
 
 
 
7 
Accounting, Auditing, and Financial Reporting 
13 
 
 
 
8 
Written Policies and Procedures for Tax-Advantaged Bonds  
14 
 
 
 
9 
Fund Balance Policy 
    25

Financial Management Policies 
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Policy 1 
Financial Management Goals 
 
Purpose: Define overall financial management goals. 
 
1.1 
Maintain a financially viable city government that provides an adequate level of 
services. 
 
 
1.2 
Maintain financial flexibility to adapt to local, regional, and national economic 
changes. 
 
 
1.3 
Maintain programs and activities that add value and contribute to the City’s mission.

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Policy 2 
Policy Review 
 
Purpose: Require periodic review and revision to financial management policies.  
 
2.1 
The Council will annually or more frequently as required, review and, if changes 
are recommended, adopt the financial management policies. 
 
 
2.2 
These policies are meant to serve as a guideline to ensure that best practices are 
utilized.  AccordinglyAccordingly, the term “shall” as utilized in this document is 
considered to be synonymous with the term “should”. 
 
2.3 
City Manager means the Chief Executive Officer of the organization who reports 
directly to the Mayor and Council or designated representative 
 
2.4 
Finance Director means the individual in charge of tracking revenues and 
expenditures and preparation of the Annual Budgetthe day-to-day operations of the 
Finance Department or designated representative.

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Policy 3 
Budget Policies 
 
Purpose: Require the City to systematically plan, adopt, and manage annual operating budgets.  
 
Section 3.1: Introduction   
 
 
3.1.1 
The Council shall annually review, re-affirm, amend as necessary, and adopt budget 
policies (guidelines) as part of the process to develop, consider, and adopt tentative 
and final budgets.   The budget policies will address revenues, expenditure controls, 
grants, transfers, reserves/contingencies, balances, and reporting. These policies are 
intended to ensure that the long-term desires of the Council will be met within the 
financial constraints of the City. 
 
 
Section 3.2: General 
 
3.2.1 
The Council shall use the budget process to weigh all competing requests for City 
resources, within expected fiscal constraints.  The Council shall discourage requests 
for new, ongoing activities outside the budget process. 
 
 
3.2.2 
The City shall rely upon ongoing revenues to fund ongoing expenditures and avoid 
one-time sources of revenues to fund ongoing activities. 
 
 
3.2.3 
The Finance DirectorCity shall annually prepare 5-year revenue and expenditure 
forecasts to examine the City’s ability to absorb operating costs due to changes in 
the economy, service demands, service levels, and capital improvements. 
 
 
3.2.4 
The Finance DirectorCity shall prepare a balanced budget, where fund balance plus 
revenues plus other financing sources equal or exceed expenditures plus other 
financing uses for each fund. and tThe Council shall adopt a fund/department-level 
operating budget, as presented in schedule E of state budget forms. 
 
 
3.2.5 
The Council shall compare service delivery alternatives to ensure that quality 
services are provided at the most competitive and economical cost.  Finance 
Department Directors shall direct departments to identify all activities that can be 
provided by another source and review options/alternatives to current service 
delivery.  The City shall review service delivery alternatives continually. 
 
 
3.2.6 
The City shall fund current year capital projects with: 
1. bonds,  
2. grants/donations, or  
3. funds accumulated (fund balances) prior to budgeting for capital expenditures.

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3.2.7 
The City shall practice conservatism in budgeting for both revenues and expenditures 
to ensure the City can meet its ongoing obligations.   The City shall not budget excess 
funds collected (fund balance) for ongoing expenditures.  
 
 
Section 3.3: Revenues 
 
3.3.1 
The City shall develop diversified and stable revenue sources to protect activities 
from short-term fluctuations in any single revenue source. 
 
 
3.3.2 
The City shall not dedicate revenues for specific purposes unless required by law, 
Council Policy, or Generally Accepted Accounting Principles (GAAP).  The Finance 
Director shall deposit all non-restricted revenues in the general fund for 
appropriation through the budget process. 
 
 
3.3.3 
The Council shall review and adopt user fees and charges annually to ensure recovery 
of all direct and indirect costs of service, unless full cost recovery would be 
excessively burdensome on citizens receiving service.  
 
 
3.3.4 
The Council shall adjust rates for enterprise operations (water, sewer, and sanitation) 
based on ten-year fund plans. 
 
3.3.5 
The Council shall annually consider the impacts to the General Fund of providing 
public safety services, as well as the financial impact on the residents and property 
owners, before setting the primary property tax levy. By statute the primary property 
levy with adjustments shall not exceed 102% of the prior fiscal year’s maximum 
allowable levy plus new construction and reimbursement for the prior calendar year’s 
tort liability payments. 
 
Section 3.4: Grants 
 
3.4.1 
The City may rely on grants to leverage City funds.   The City shall avoid 
inconsistent and/or fluctuating grants to fund ongoing activities.  In the event of 
reduced grant funding, the City may substitute City resources only after all other 
priorities and alternatives are considered. Therefore, employees shall apply for 
grants that are consistent with the mission and priorities of the City. 
 
When employees apply for, accept, and/or administer a grant, the City assumes 
responsibility for complying with the grant obligations. The City Manager shall 
establish policies for grant related projects. 
 
 
3.4.2 
Whenever possible, the City shall consider grant funded projects which require City 
matching or operating funds as part of the budget process. Any grant funded 
expenditure should include a five yearfive-year analysis of the amount of City funds 
required to subsidize its operation.

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Section 3.5: Transfers and Interfund Loans 
 
3.5.1 
All requests for transfer require written justification explaining the rationale and 
fiscal impact. 
 
 
3.5.2 
Any transfers between funds, projects, or contingencies, or from department to 
department within the General Fund require City Council approval. Transfers from 
department to department within a fund or from line item account to line item account 
within a department, or from division to division within a department shall require 
City Manager approval.   
 
 
3.5.3 
The council must review and approve interfund loans. 
 
 
Section 3.6: Reserve/Council Contingency 
 
3.6.1 
“Council” Contingency Funds.  The City may use contingency funds when additional 
funds are needed to offset unexpected expenditure increases or when unanticipated 
events threaten the public health or safety.  The City Manager shall review and may 
approve use of contingency funds in accordance with the City’s procurement policy. 
 
 
3.6.2 
Reserve Funds.  The Council will not budget reserve funds – reserve funds are 
“savings” intended to offset revenue shortfalls during a fiscal year. If there is a 
shortfall in revenue, the City shall use reserve funds in accordance with the City’s 
fund balance policy.   The City may establish reserves for all operating funds – an 
operating fund is a fund that has salary expenses or collects user fees for services 
performed (excludes grant and capital funds). 
 
 
3.6.3 
Debt Service Funds.  The City may accumulate secondary property tax revenues in 
an amount equal to ten percent (10%) of debt service to ensure that the General Fund 
is not subsidizing debt service payments.   The City shall not collect and reserve 
secondary property taxes in an amount exceeding state law.  Additional funds not 
levied by secondary property tax may be transferred into the Debt Service Fund 
through the budget process to provide additional reserves. 
 
 
3.6.4 
Debt Service and Replacement Reserves.  The City shall fund debt service and 
replacement reserves to meet required bond covenants including repair and 
replacement funds in the water and sewer funds. 
 
 
 
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Section 3.7: Budget Process 
 
3.7.1 
The City shall monitor and follow the budget process throughout the year.  The 
Finance Director, in consultation with the City Manager, shall initiate the formal 
budget process by distributing to providingDdepartments witha budget packet 
information that includes an outline of the budget schedule, year-to-date 
expenditures and revenues, and all applicable budget forms.  
 
 
3.7.2 
The City Manager and Finance Director shall schedule and host a budget 
introduction session with all Department hHeads.  
 
 
3.7.3 
Departments shall prepare and submit their requests to the Finance Directorin the 
form and manor provided by the City. 
 
 
3.7.4 
The Finance DirectorCity shall prepare summary reports, along with detailed budget 
requests, and submit the reports and detail to the City Manager. 
 
 
3.7.5 
Department hHeads shall individually present capital and operating requests to the 
City Manager.  
 
 
3.7.6 
The City Manager shall review budget requests and provide further guidance to 
Ddepartments. 
 
 
3.7.7 
The City Manager and the Finance Director shall present the a balanced 
recommended draft budget to Council for review and discussion at a Council 
workshop.   As required, Department hHeads may be present and participate at the 
Council workshop. 
 
 
3.7.8 
After the Council workshop, the Finance DirectorCity shall revise the draft budget 
and prepare a recommended tentative budget.   The City Manager and Finance 
Director shall present the recommended tentative budget for Council consideration 
and adoption at a Council meeting.  Capital projects and acquisitions that have not 
been completed in the current fiscal year are included in the tentative budget as carry 
forward projects and the beginning fund balance is adjusted accordingly. 
 
 
3.7.9 
After Council action, the City Clerk shall publish the tentative budget for two 
consecutive weeks as required by law. 
 
 
3.7.10 
The Council shall schedule and host a public hearing on the budget, after which the 
Council shall consider and may adopt the final budget.  The Finance DirectorCity 
shall ensure that budget adoption adheres to all statutory hearings, publications, and 
requirements. 
 
 
3.7.11 
The Council shall set the final property tax levy in accordance with State law.

Financial Management Policies 
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3.7.12 
After the Council adopts the tentative budget and sets the expenditure limitation, the 
City shall not expend more than the total appropriated for all funds. 
 
Section 3.8: Budget Basis 
 
3.8.1 
The City prepares budgets primarily on a cash basis.  This is different than the 
accounting process which utilizes a modified accrual basis.    Cash basis means that 
revenues are recognized when they are collected, and expenses are recognized when 
they are paid.  Modified accrual basis recognizes revenues when they become 
available and measurable and, generally, recognizes expenditures when the City 
agrees/commits to buy something. 
 
 
3.8.2 
Independent Auditors shall annually provide a reconciliation of actual expenditures 
compared to the adopted budget in accordance with State law. 
 
 
3.8.3 
The City shall use the Annual Audited Financial Statements (Audit) to detail the final 
status of the City’s finances compared to budget on the basis of Generally Accepted 
Accounting Principles (GAAP). In most cases, this conforms to the way the City 
prepares its budget. Exceptions are as follows: 
 
1. Compensated absences are accrued as earned by employees (GAAP) as opposed 
to being expended when paid (Budget). 
2. Capital Outlay within the enterprise funds are shown as assets (GAAP) and are 
shown as expenses in the budget. 
3. Bond and loan principal payments within the enterprise funds are shown as 
reductions of liabilities (GAAP) and are shown as expenses in the budget. 
 
 
3.8.4 
Due to expenditure limitation statutes, the City must identify all possible 
expenditures and corresponding revenues within the budget.  The Finance Director 
and Department heads shall closely monitor expenditures to ensure that they are 
being spent for the purpose identified in the budget and that the corresponding 
revenue is adequate.   The Finance Director shall establish and maintain a detailed 
accounting structure to record revenues and expenditures at the level of detail shown 
in the budget. 
 
Section 3.9: Funds 
 
3.9.1 
State law only requires the existence of two funds, the General Fund and the 
Highway Users Revenue Fund (HURF). 
 
 
3.9.2 
The City may create and maintain other funds by statute, agreement, ordinance, 
contract, or to provide balance sheet accounts for tracking purposes. To the extent 
feasible, the City may limit the number of funds to comply with GAAP.

Financial Management Policies 
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Policy 4 
Cash Management and Investment 
 
Purpose: Ensure investment, liquidity, and yield.  
 
4.1 
The Finance Director, in consultation with the City Manager, will invest all funds of 
the City according to six criteria in order of importance: 
 
a. Legality 
b. Safety 
c. Liquidity 
d. Yield 
e. Duration 
f. Accounting Complexity 
 
 
4.2 
The City will collect, deposit, and disburse all funds to maximize invested cash. 
 
 
4.3 
To maximize investment yields, the City will consolidate cash balances from various 
funds to maximize the size and duration of investments.   The Finance Director will 
allocate investment earnings to participating funds. 
 
 
4.4 
The City will conduct its investment activities with financial institutions in 
accordance with written contracts. 
 
 
4.5 
The City will protect its investment securities through third party custodial 
safekeeping.

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Policy 5 
Capital Improvement Plan 
 
Purpose: Require the City to plan, schedule, and finance capital projects and acquisitions. 
 
5.1 
The Finance DirectorCity Manager will annually coordinate with the City’s 
Engineer, and Public Works Director, and other Department Heads to submit a 
Capital Improvement Plan for review by the City Manager, then Council.  
 
 
5.2 
The Capital Improvement Plan shall include: 
 
a. A statement of the objectives of the Capital Improvement Plan. 
b. An estimate of each project’s/acquisition’s useful life. 
c.a. An estimate of each project’s/acquisition’s capital costs broken down by fiscal 
year. 
d.b.An estimate of each project’s/acquisition’s annual operating costs. 
e.c. An evaluation of potential funding sources for each project/acquisition.  
f.d. Recommended funding sources for each project/acquisition. 
g.e. A development schedule for each project/acquisition. 
h.f. A scope of work to be performeddescription forof each project/acquisition. 
i.g. If a project/acquisition will be completed in phases, each phase should be 
identified as a separate project/acquisition. 
 
 
5.3 
The current year of the Capital Improvement Plan will provide the basis for the 
capital budget. 
 
 
5.4 
When current revenues or resources are available for projects/acquisitions, the City 
will first consider those projects/acquisitions with the shortest useful life and/or those 
projects/ acquisitions which are difficult to finance with debt.    
 
 
5.5 
The City may not proceed with construction or acquisition until the funding sources 
have been identified to finance the project. 
 
 
5.6 
At the end of the Fiscal Year in which the project is completed or acquired, any 
remaining budgeted funds will revert to the fund balance of the funding source.

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Policy 6 
Debt Management 
 
Purpose: Evaluate the purpose, necessity, and condition under which the City will issue debt. 
 
Section 6.1: Overall Debt Management Policies  
 
 
6.1.1 
The City will utilize long-term debt to finance capital projects in accordance with the 
Capital Improvement Plan. 
 
 
6.1.2 
The City will prohibit the City’s financial advisor from underwriting any debt 
directly issued by the City or special districts sponsored by the City within a 
negotiated underwriting of debt offered through public sale.   This underwriting 
prohibition does not include: 
 
a. competitive bond sales when the City authorizes the financial advisor to submit 
a competitive bid,  
b. bond issues by the Greater Arizona Development Authority, the Water 
Infrastructure Finance Authority, or other independent financing authority on 
behalf of the City, and  
c. limited offerings, private placements, or other underwritings not offered through 
public sale. 
 
 
6.1.3 
The City will consider refunding debt when the net present value of the debt service 
savings exceeds 3% and $100,000 Net Present Value (NPV).   The City will also 
consider refunding debt to modify restrictive covenants or to modify debt structures. 
 
 
6.1.4 
The City will adopt, review, and update as necessary written policies and procedures 
for tax-advantaged bonds within these financial management policies. 
 
 
Section 6.2: General Obligation Bonds 
 
 
6.2.1 
The City may finance capital projects with general obligation bonds authorized by 
voters through a citywide bond election. 
 
 
6.2.2 
The City will repay general obligation bonds from secondary property taxes 
authorized by voters or from any lawfully available source of revenue. 
 
 
6.2.3 
The target maturity for general obligation bonds will typically range between twenty 
(20) and thirty (30) years.   The final maturity will not exceed the useful life of the 
capital project.    
 
 
6.2.4 
Where possible, the City will structure general obligation bond issues to create 
annual level debt service payments.

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6.2.5 
In accordance with the State of Arizona Constitution, total general obligation debt 
cannot be issued in excess of 26% of the total Full Cash assessed valuation of taxable 
property within the City. 
 
 
6.2.6 
The City will use investment earnings on general obligation bond balances to pay 
debt service unless otherwise committed towards a capital project or as otherwise 
directed by bond restrictions and covenants. 
 
 
Section 6.3: Revenue Bonds  
 
 
6.3.1 
The City may finance capital projects with revenue bonds authorized by voters 
through a citywide bond election. 
 
 
6.3.2 
The City may repay revenue bonds from any lawfully available source of revenue 
including revenue generated from the operation of the capital project being financed 
or from other designated revenues such as highway user revenues, excise taxes, or 
special fees/taxes. 
 
 
6.3.3 
The target maturity for revenue bonds will typically range between twenty (20) and 
thirty (30) years.  The final maturity will not exceed the useful life of the capital 
project.    
 
 
6.3.4 
Where possible, the City will structure revenue bond issues to create annual level 
debt service payments. 
 
 
6.3.5 
The City will fund a debt service reserve when required by rating agencies, bond 
insurers, or existing bond covenants. 
 
 
6.3.6 
The City will use investment earnings on revenue bond balances to pay debt service 
unless otherwise committed towards a capital project or as otherwise directed by 
bond restrictions and covenants. 
 
 
Section 6.4: Debt Subject to Annually Appropriated Debt Service  
 
 
6.4.1 
The City may finance capital projects with debt authorized by the Council with debt 
service subject to annual appropriations (henceforth, “Annual Appropriation Debt” 
or “AAD.”)    
 
 
6.4.2 
The City may repay AAD from any lawfully available source of revenue including 
revenue generated from the operation of the capital project being financed or from 
other designated revenues such as excise taxes, or special fees/taxes. 
 
 
6.4.3 
The target maturity for AAD will typically range between twenty (20) and thirty (30) 
years.  The final maturity will not exceed the useful life of the capital project.

Financial Management Policies 
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6.4.4 
Where possible, the City will structure AAD issues to create annual level debt service 
payments. 
 
 
6.4.5 
The City will fund a debt service reserve when required by rating agencies, bond 
insurers, or existing bond covenants. 
 
 
6.4.6 
The City will use investment earnings on AAD balances to pay debt service unless 
otherwise committed towards a capital project or as otherwise directed by bond 
restrictions and covenants. 
 
 
Section 6.5: Municipal Improvement District/Special Assessment Bonds  
 
 
6.5.1 
The City may finance capital projects with special assessment bonds after the 
Council forms a Municipal Improvement District (MID) in accordance with State 
statutes. 
 
 
6.5.2 
The City may form a MID when there is a clear and significant purpose for the City 
and when commercial or residential developments or redevelopments desire 
improvements to property such as roads, water lines, sewer lines, street lights, and 
drainage. 
 
 
Section 6.6: Community Facilities District Bonds  
 
 
6.6.1 
 
 
 
The City may form a Community Facility District (CFD) when there is a clear and 
significant purpose of the City and when commercial or residential developments or 
redevelopments desire improvement to property such as roads, water lines, sewer 
lines, street lights, and drainage. 
 
6.6.2 
CFD’s for commercial development may be formed for any size district and for any 
amount deemed appropriate by the Council. 
 
6.6.3 
CFD’s for residential development of less than 160 acres are discouraged and should 
only be considered if the improvements achieve published Council goals. 
 
6.6.4 
Should the City desire to form a CFD, the Council may adopt and the City will 
maintain an expanded policy on CFDs.

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Section 6.7: Financial Disclosure Compliance 
6.7.1 
 
 
 
A “Material Financial Obligation” shall be defined as any indebtedness secured by 
a security interest in or a lien, deed of trust, or mortgage on assets owned, leased, 
operated, or maintained by the City with a term in excess of one year and with a par 
amount in excess of $100,000 when originally issued or executed.  Material 
Financial Obligations include but are not limited to bank loans; bonds; capital 
leases; certificates of participation; loans from local, state, and federal agencies and 
governments; guarantees, lines of credit, and placements.  
6.7.2 
In accordance with Security Exchange Commission’s (SEC) Rule 15c2-12 and 
continuing disclosure agreements affiliated with public offerings of debt, the 
Finance Director shall comply with primary and secondary disclosure requirements 
in a timely and comprehensive manner.    
6.7.3 
In addition to the disclosing on publicly offered debt as per 6.7.2, the Finance 
Director shall annually disclose any other material financial obligations issued after 
February 27, 2019 in accordance with the amended SEC Rule 15c2-12.  
6.7.4 
The Finance Director shall post ongoing disclosure data to the Municipal Security 
Rulemaking Board’s (MSRB) Electronic Municipal Market Access (EMMA) 
system, the central repository designed by the SEC.

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Policy 7 
Accounting, Auditing and Financial Reporting 
 
Purpose: Provide financial data to the Council, City management, citizens, investors, and 
creditors. 
 
7.1 
The City will maintain accounting and financial reporting systems in conformance 
with Generally Accepted Accounting Principles (GAAP) and standards promulgated 
by the Governmental Accounting Standards Board (GASB). 
 
 
7.2 
The City will develop and manage its accounting system to provide reasonable 
assurance regarding the: 
 
a. safeguarding of assets against loss from unauthorized use or disposition,  
b. proper recording of financial transactions, 
c. reliability of financial records for preparing financial statements, and  
d. accountability for capital assets. 
 
 
7.3 
The Finance Director shall catalog all significant financial events and related matters 
and prepare the City’s annual disclosures, as required by the SEC Regulation 15-C-
2-12. 
 
 
7.4 
The City will engage an independent public accounting firm to annually audit the 
City’s financial statements in accordance with Generally Accepted Government 
Auditing Standards (GAGAS).  The City will prepare its financial statements in 
accordance with applicable standards and will account for its operations in a manner 
consistent with the goal of obtaining an unqualified opinion from its auditors. 
 
 
7.5 
Following the annual financial statement audit, the Finance Director will issue an 
official Annual Financial Report (AFR) The AFR will include the bond related on-
going disclosure requirements and will fully disclose all significant financial events 
and related matters.   The Finance Director will provide the AFR to the rating 
agencies, municipal bond insurers, and national bond disclosure repositories. 
 
 
7.6 
The Finance Director will post the AFR and Annual Adopted Budget on the City’s 
website and make them available to the public. 
 
 
7.7 
The Finance Director will generate monthly revenue and expenditure reports for 
review by the Council and City management.

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Policy 8 
Written Policies and Procedures for Tax-Advantaged Bonds  
 
Purpose: Comply with federal requirements to issue bonds or other obligations of the City. 
 
Section 8.1: Introduction and Overview 
 
 
8.1.1 
The City has issued and may in the future issue tax-exempt obligations (including, 
without limitation, bonds, notes, loans, leases and certificates), tax credit obligations 
and “direct-pay” tax credit obligations (together, “tax-advantaged bonds”) that are 
subject to certain requirements under the Internal Revenue Code of 1986, as amended 
(the “Code”).   
 
 
8.1.2 
The City has established the policies and procedures contained herein (the 
“Procedures”) as of June 19, 2012 in order to ensure that the City complies with the 
requirements of the Code that are applicable to its tax-advantaged bonds.  These 
Procedures, coupled with requirements contained in the Arbitrage and Tax 
Certificate (the “Tax Certificate”) or other operative documents executed at the time 
of issuance of the tax-advantaged bonds, are intended to constitute written 
procedures for ongoing compliance with the Federal tax requirements applicable to 
the bonds and for timely identification and remediation of violations of such 
requirements. 
 
 
8.1.3 
The tax-advantaged bonds that are covered by these Procedures include, but are not 
limited to, “Build America Bonds”, “Recovery Zone Economic Development 
Bonds”, and “Specified Tax Credit Bonds” that constitute “qualified bonds” under 
Section 6431 of the Code and are therefore eligible for interest subsidy payments 
(the “Subsidy”) from the U.S. Treasury (such Build America Bonds, Recovery Zone 
Economic Development Bonds and Specified Tax Credit Bonds are collectively 
referred to as “Direct-Pay Bonds”).  Specified Tax Credit Bonds include new clean 
renewable energy bonds, qualified energy conservation bonds, qualified zone 
academy bonds and qualified school construction bonds. 
 
 
Section 8.2: General Matters 
 
 
8.2.1 
Responsible Officer. The Finance Director will have overall responsibility for 
ensuring that the ongoing requirements described in these Procedures are met with 
respect to tax-advantaged bonds (the “Responsible Officer”). 
 
 
8.2.2 
Establishment of Procedures. The Procedures established herein will be set forth 
within the City’s Financial Management Policies which includes the City’s Debt 
Management Policies.

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8.2.3 
Additional Responsible Employees.  The Responsible Officer shall identify any 
additional persons who will be responsible for each section of the Procedures, notify 
the current holder of that office of the responsibilities, and provide that person a copy 
of the Procedures.  Upon employee or officer transitions, new personnel should be 
advised of responsibilities under the Procedures and ensure they understand the 
importance of the Procedures.   If employee or officer positions are restructured or 
eliminated, responsibilities should be reassigned as necessary. 
 
 
8.2.4 
Training Required.  The Responsible Officer and other responsible persons shall 
receive appropriate training that includes the review of and familiarity with the 
contents of these Procedures, review of the requirements contained in the Code 
applicable to each tax-advantaged bond, identification of all tax-advantaged bonds 
that must be monitored, identification of all facilities (or portions thereof) financed 
with proceeds of tax-advantaged bonds, familiarity with the requirements contained 
in the Tax Certificate or other operative documents contained in the transcript, and 
familiarity with the procedures that must be taken in order to correct noncompliance 
with the requirements of the Code in a timely manner.   
 
 
8.2.5 
Periodic Review.  The Responsible Officer or other responsible person shall 
periodically review compliance with the Procedures and with the terms of the Tax 
Certificate to determine whether any violations have occurred so that such violations 
can be timely remedied through the “remedial action” regulations (Treasury 
Regulation §1.141-12, §1.142-2, §1.144-2, §1.145-2 or §1.147-2, as applicable) or 
the Voluntary Closing Agreement Program described in Internal Revenue Service 
(“IRS”) Notice 2008-31 (or successor guidance) and related sections of the Internal 
Revenue Manual.  Such periodic review shall occur at least annually or more 
frequently prior to the issuance of new or refunding obligations. 
 
 
8.2.6 
Change in Bond Terms. If any changes to the terms of the bonds are contemplated, 
bond counsel should be consulted.  Such modifications could result in a reissuance, 
i.e., a deemed refunding, of the bonds which could jeopardize the status of tax-
advantaged bonds, including Direct-Pay Bonds (and thereby affect the continued 
receipt of the Subsidy for Direct-Pay Bonds). 
 
 
8.2.7 
Change in Bond Terms. If any changes to the terms of the bonds are contemplated, 
bond counsel should be consulted.  Such modifications could result in a reissuance, 
i.e., a deemed refunding, of the bonds which could jeopardize the status of tax-
advantaged bonds, including Direct-Pay Bonds (and thereby affect the continued 
receipt of the Subsidy for Direct-Pay Bonds).

Financial Management Policies 
Page 18 
 
 
 
Section 8.3: Issue Price for Tax-Advantaged Bonds; Premium Limit for Direct-Pay Bonds 
 
 
8.3.1 
Issue Price.  In order to document the issue price of tax-advantaged bonds, the 
Responsible Officer shall consult with bond counsel and obtain a written certification 
from the underwriter, placement agent or other purchaser of the bonds as to the 
offering price of the bonds that is in form and substance acceptable to the City and 
bond counsel. 
 
 
8.3.2 
Premium Limit for Direct Pay-Bonds.  Prior to issuing Direct-Pay Bonds, the 
Responsible Officer shall consult with bond counsel and the City’s financial advisors 
to assure that the premium on each maturity of the Direct-Pay Bonds (stated as a 
percentage of principal amount) does not exceed one-quarter of one-percent (0.25%) 
multiplied by the number of complete years to the earlier of the final maturity of the 
bonds or, generally, the earliest call date of the bonds, and that the excess of the issue 
price of the bonds over the price at which the bonds are sold to the underwriter or 
placement agent, when combined with other issuance costs paid from proceeds of 
the bonds, does not exceed 2% of the sale proceeds of the bonds. 
 
 
Section 8.4: IRS Information Return Filing 
 
 
8.4.1 
Filing of Applicable Form 8038.  The Responsible Officer will confirm that bond 
counsel has filed the applicable information reports (such as Forms 8038, 8038-G, 
8038-B or 8038-TC) for such bond issue with the IRS on a timely basis, and maintain 
copies of such form including evidence of timely filing as part of the transcript of the 
bond issue.  
 
 
8.4.2 
Filing of Form 8038-CP.  For Direct-Pay Bonds, the Responsible Officer shall 
review the IRS Form 8038-CP in order to ensure that the proper amount of interest 
is being reported and the proper amount of Subsidy is being requested with respect 
to each interest payment date.  The Responsible Officer shall ensure that the IRS 
Form 8038-CP is filed on a timely basis with respect to each interest payment date 
in order to receive timely payment of the Subsidy.  If the Subsidy is to be paid to a 
person other than the City (i.e., the bond trustee), the Responsible Officer shall obtain 
and record the contact information of that person, and ensure that it is properly shown 
on Form 8038-CP so that the direct payment will be made to the proper person. 
 
 
8.4.3 
Filing of Forms 8038-T or 8038-R.  The Responsible Officer shall file the IRS Form 
8038-T relating to the payment of rebate or yield reduction payments in a timely 
manner as discussed in Section 8.10.   The Responsible Officer shall also monitor 
the extent to which the City is eligible to receive a refund of prior rebate payments 
and provide for the timely filing for such refunds using an IRS Form 8038-R.

Financial Management Policies 
Page 19 
 
 
 
Section 8.5: Use of Proceeds 
 
 
8.5.1 
The Responsible Officer or other responsible shall be responsible for ensuring and 
monitoring the appropriate use of proceeds as detailed in this section. 
 
 
8.5.2 
Consistent Accounting Procedures.  Maintain clear and consistent accounting 
procedures for tracking the investment and expenditures of bond proceeds, including 
investment earnings on bond proceeds.   
 
 
8.5.3 
Reimbursement Allocations at Closing.  At or shortly after closing of a bond issue, 
ensure that any allocations for reimbursement expenditures comply with the Tax 
Certificate.   
 
 
8.5.4 
Timely Expenditure of Bond Proceeds.  Monitor that sale proceeds and investment 
earnings on sale proceeds of tax-advantaged bonds are spent in a timely fashion 
consistent with the requirements of the Tax Certificate. 
 
 
8.5.5 
Costs of Issuance.  With respect to Direct-Pay Bonds and qualified private activity 
bonds, monitor that no more than 2% of the sale proceeds are used to pay costs of 
issuance.   
 
 
8.5.6 
Qualified Use of Proceeds of Direct-Pay Build America Bonds.  With respect to 
Build America Bonds, determine the correct amount of available project proceeds 
and monitor that 100% of all sale proceeds and investment earnings on sale proceeds 
(other than proceeds used to pay costs of issuance or deposited in a reasonably 
required reserve fund) are allocated to capital expenditures in a timely fashion 
consistent with the requirements of the Tax Certificate.  
 
 
8.5.7 
Qualified Use of Proceeds of Recovery Zone Economic Development Bonds.  With 
respect to Recovery Zone Economic Development Bonds, determine the correct 
amount of available project proceeds and monitor that 100% of all sale proceeds and 
investment earnings on sale proceeds (other than proceeds used to pay costs of 
issuance or deposited in a reasonably required reserve fund) are allocated to 
expenditures for qualified economic development purposes within the recovery zone 
in a timely fashion consistent with the requirements of the Tax Certificate.  Ensure 
compliance with the “Davis Bacon” requirements described in Section 8.9.

Financial Management Policies 
Page 20 
 
 
 
8.5.8 
Qualified Use of Proceeds of Specified Tax Credit Bonds.  With respect to Specified 
Tax Credit Bonds, determine the correct amount of available project proceeds and 
monitor that 100% of all sale proceeds and investment earnings on sale proceeds 
(other than proceeds used to pay costs of issuance) are allocated to qualifying 
expenditures that are permitted for each type of Specified Tax Credit Bond in a 
timely fashion consistent with the requirements of the Tax Certificate.  If proceeds 
are not spent by the end of the “expenditure period” as defined in Section 8.9, redeem 
bonds in accordance with the requirements of the Code as further described in 
Section 8.9.  
 
 
8.5.9 
Qualified Use of Proceeds of Qualified Private Activity Bonds.  With respect to 
qualified bonds, including exempt facility bonds, monitor that sale proceeds and 
investment earnings on sale proceeds are allocated to qualifying expenditures 
permitted for each type of qualified bond in a timely fashion consistent with the 
requirements of the Tax Certificate.  If an exempt facility or other applicable facility 
will not be completed, or the facility has been placed in service, and there are 
remaining unspent bond proceeds, immediately consult with bond counsel to 
determine whether bonds are required to be redeemed under Treasury Regulation 
§1.142-2.  If exempt facility bonds are required to be redeemed or defeased in order 
to comply with the remedial action rules under Treasury Regulation §1.142-2, such 
redemption or defeasance must occur within 90 days of the date an action is taken 
that causes the bonds to not be used for the qualifying purpose for which the bonds 
were issued. 
 
 
8.5.10 
Requisitions.  Utilize requisitions to draw down bond proceeds, and ensure that each 
requisition contains (or has attached to it) detailed information in order to establish 
when and how bond proceeds were spent; review requisitions carefully before 
submission to ensure proper use of bond proceeds to minimize the need for 
reallocations. 
 
 
8.5.11 
Final Allocation.  Ensure that a final allocation of bond proceeds (including 
investment earnings) to qualifying expenditures is made if bond proceeds are to be 
allocated to project expenditures on a basis other than “direct tracing” (direct tracing 
means treating the bond proceeds as spent as shown in the accounting records for 
bond draws and project expenditures).  An allocation other than on the basis of 
“direct tracing” is often made to reduce the private business use of bond proceeds 
that would otherwise result from “direct tracing” of proceeds to project expenditures.  
This allocation must be made within 18 months after the later of the date the 
expenditure was made or the date the project was placed in service, but not later than 
five years and 60 days after the date the bonds are issued (or 60 days after the bond 
issue is retired, if earlier).  Bond counsel can assist with the final allocation of bond 
proceeds to project costs.  Maintain a copy of the final allocation in the records for 
the tax-advantaged bond.

Financial Management Policies 
Page 21 
 
 
 
8.5.12 
Maintenance and Retention of Records Relating to Proceeds.  Maintain careful 
records of all project and other costs (e.g., costs of issuance, credit enhancement and 
capitalized interest) and uses (e.g., deposits to a reserve fund) for which bond 
proceeds were spent or used.  These records should be maintained separately for each 
issue of bonds for the period indicated under Section 8.11. 
 
 
Section 8.6: Monitoring Private Business Use 
 
 
8.6.1 
With respect to tax-advantaged bonds that are subject to the private activity bond 
limitations provided in the Code (e.g., governmental bonds and qualified 501(c)(3) 
bonds), the Responsible Officer or other responsible person shall ensure and monitor 
the appropriate use of proceeds as detailed within this section. 
 
 
8.6.2 
Identify Bond-Financed Facilities.  Identify or “map” which outstanding bond issues 
financed which facilities and in what amounts.   
 
 
8.6.3 
Review of Contracts with Private Persons.  Review all of the following contracts or 
arrangements with non-governmental persons or organizations or the federal 
government (collectively referred to as “private persons”) with respect to the bond-
financed facilities which could result in private business use of the facilities: 
 
a. Sales of bond-financed facilities; 
b. Leases of bond-financed facilities; 
c. Management or service contracts relating to bond-financed facilities; 
d. Research contracts under which a private person sponsors research in bond-
financed facilities; and 
e. Any other contracts involving “special legal entitlements” (such as naming rights 
or exclusive provider arrangements) granted to a private person with respect to 
bond-financed facilities. 
 
 
8.6.4 
Counsel Review of New Contracts or Amendments.  Before amending an existing 
agreement with a private person or entering into any new lease, management, service, 
or research agreement with a private person, consult counsel to review such 
amendment or agreement to determine whether it results in private business use.   
 
 
8.6.5 
Establish Procedures to Ensure Proper Use and Ownership.  Establish procedures to 
ensure that bond-financed facilities are not used for private use without written 
approval of the Responsible Officer or other responsible person.  For qualified 
501(c)(3) bonds, establish procedures to ensure that the bond-financed facilities 
continue to be owned by a qualified 501(c)(3) organization or a governmental unit.

Financial Management Policies 
Page 22 
 
 
 
8.6.6 
Analyze Use.  Analyze any private business use of bond-financed facilities and, for 
each issue of bonds, determine whether the 10% limit on private business use (5% in 
the case of qualified 501(c)(3) bonds or “unrelated or disproportionate” private 
business use) is exceeded, and contact bond counsel or other tax advisors if either of 
these limits appears to be exceeded.   
 
 
8.6.7 
Remediation if Limits Exceeded.  If it appears that private business use limits are 
exceeded, immediately consult with bond counsel to determine if a remedial action 
is required with respect to nonqualified bonds of the issue under Treasury Regulation 
§1.141-12, or if the IRS should be contacted under its Voluntary Closing Agreement 
Program.  If tax-advantaged bonds are required to be redeemed or defeased in order 
to comply with the remedial action rules under Treasury Regulation §1.141-12, such 
redemption or defeasance must occur within 90 days of the date a deliberate action 
is taken that results in a violation of the private business use limits.   
 
 
8.6.8 
Maintenance and Retention of Records Relating to Private Use.  Retain copies of all 
of the above contracts or arrangements (or, if no written contract exists, detailed 
records of the contracts or arrangements) with private persons for the period 
indicated under Section 8.11.  
 
 
Section 8.7: Monitoring Use of Facilities Financed with Qualified Private Activity Bonds 
 
 
8.7.1 
With respect to tax-advantaged bonds that are not subject to the private activity bond 
limitations, but are subject to the limitations provided in the Code as to the qualifying 
use of proceeds and qualifying use of bond-financed facilities (e.g., exempt facility 
bonds, qualified small issue bonds and qualified redevelopment bonds), the 
Responsible Officer or other responsible person shall ensure and monitor the 
appropriate use of proceeds as detailed within this section.   
 
 
8.7.2 
Identify Bond-Financed Facilities.  Identify or “map” facilities that have been bond-
financed and assure that use is for an appropriate purpose (e.g., airport facilities are 
being used for airport purposes).   
 
 
8.7.3 
Review of Contracts with Private Persons.  If the bond-financed facilities are 
required to be governmentally owned, examine all leases, management contracts or 
other contracts with private persons to assure compliance with applicable safe-
harbors for governmental ownership provided in the Code.  Before amending an 
existing agreement or entering into any new lease, management or other contract, 
consult bond counsel to review such amendment or agreement to determine whether 
it complies with applicable safe harbors.  
 
8.7.4 
Establish Procedures to Monitor Use.  Establish procedures to monitor that bond-
financed facilities are not used for nonqualifying purposes.  Require users of facilities 
to immediately notify the Responsible Officer or other responsible person if a change 
in use of the facilities is contemplated or occurs.

Financial Management Policies 
Page 23 
 
 
 
8.7.5 
Remediation if Limitations Exceeded.  If qualified use of facilities financed with tax-
advantaged bonds changes to a non-qualified use (e.g., use of airport facilities that is 
not for airport purposes), immediately consult with bond counsel to determine if a 
remedial action is required with respect to nonqualified bonds of the issue under 
Treasury Regulation §1.142-2, or if the IRS should be contacted under its Voluntary 
Closing Agreement Program.  If tax-advantaged bonds are required to be redeemed 
or defeased in order to comply with the remedial action rules under Treasury 
Regulation §1.142-2, such redemption or defeasance must occur within 90 days of 
the date an action is taken that causes the bonds to not be used for the qualifying 
purpose for which the bonds were issued.  
 
 
8.7.6 
Maintenance and Retention of Records Relating to Qualifying Use.  Retain copies of 
all of the above contracts or arrangements (or, if no written contract exists, detailed 
records of the contracts or arrangements) with private persons for the period 
indicated under Section 11 below.      
 
 
Section 8.8: Loan of Bond Proceeds 
 
 
8.8.1 
The Responsible Office or other responsible person shall consult bond counsel if a 
loan of proceeds of tax-advantaged bonds is contemplated.  If proceeds of tax-
advantaged bonds are permitted under the Code to be loaned to other entities and are 
in fact so loaned, require that the entities receiving a loan of bond proceeds institute 
policies and procedures similar to the Procedures to ensure that the proceeds of the 
loan and the facilities financed with proceeds of the loan comply with the limitations 
provided in the Code.  Require the recipients of such loans to annually report to the 
City ongoing compliance with the Procedures and the requirements of the Code. 
 
 
 
 
 
Section 8.9: Special Requirements Applicable to Specified Tax Credit Bonds 
 
 
8.9.1 
The Code imposes certain additional special requirements that apply to the issuance 
of Specified Tax Credit Bonds.  For Specified Tax Credit Bonds, the Responsible 
Officer or other responsible person shall ensure and monitor that the requirements of 
this section are met. 
 
 
8.9.2 
Davis-Bacon.  Pursuant to the terms of Section 1701 of the American Recovery and 
Reinvestment Tax Act of 2009, projects financed with Specified Tax Credit Bonds 
are subject to the prevailing wage requirements of Subchapter IV of Chapter 31 of 
Title 40, United States Code.  Note that these requirements also apply to the issuance 
of Recovery Zone Economic Development Bonds.

Financial Management Policies 
Page 24 
 
 
 
8.9.3 
Spending Requirements.  Although these may seem similar to “temporary period 
requirements,” the “spending requirements” applicable to Specified Tax Credit 
Bonds are hard and fast rules that if not met may cause payments of the Subsidy  on 
some or all of the Specified Tax Credit Bonds to be lost or revoked and will require 
redemption of such bonds.  The spending requirements are as follows: 
a. 100% of the sale proceeds and investment proceeds must be spent within the 3 
year period beginning on the date of issuance (unless such period is extended as 
described below) (the “expenditure period”);  
b. a binding commitment with a third party to spend at least 10 percent of the sale 
proceeds and investment proceeds (other than the amount spent on costs of 
issuance) (“available project proceeds”) will be incurred within the six month 
period beginning on the date of issuance;  
c. to the extent less than 100% of available project proceeds are not spent by the 
end of the expenditure period for qualified purposes, the City must redeem all of 
the “nonqualified bonds”) within 90 days after the end of the expenditure period 
(this should be done with the assistance of bond counsel); 
d. the expenditure period may be extended beyond the initial three year period only 
by the U.S. Treasury upon the request of the City, which request must establish 
that the failure to spend the available project proceeds within three years was due 
to a reasonable cause and that spending will continue with due diligence. 
 
 
8.9.4 
Sinking Funds.  Special rules permit Specified Tax Credit Bonds to be structured 
with sinking funds that will not be subject to rebate.  These sinking funds must be 
structured as follows: 
a. the sinking fund may not be funded more rapidly than in equal monthly 
installments; 
b. the sinking fund may only be funded in a manner reasonably expected to result 
in an amount not greater than the amount necessary to repay the bond issue; and  
c. the yield on the investments in the sinking fund may not exceed the published 
permitted sinking fund yield for the sale date (which is set forth in the Tax 
Certificate). 
 
 
8.9.5 
Prohibition on Financial Conflicts of Interest.  Upon the issuance of Specified Tax 
Credit Bonds, the City certified that applicable State and local laws governing 
conflicts of interest were followed with respect to the bonds.  If the U.S. Treasury 
prescribes additional conflicts of interest rules with respect to the Specified Tax 
Credit Bonds, such rules must also be satisfied. 
 
 
8.9.6 
Additional Rules Applicable to Specified Tax Credit Bonds.  New clean renewable 
energy bonds, energy conservation bonds, qualified school construction bonds and 
qualified zone academy bonds each have their own set of specific and unique 
requirements that are applicable to the use of proceeds or eligibility as a Specified 
Tax Credit Bond.  The Responsible Officer should consult the Tax Certificate and 
establish procedures for monitoring compliance with such specific requirements that 
are applicable to the Specified Tax Credit Bonds of the City.

Financial Management Policies 
Page 25 
 
 
 
Section 8.10: Arbitrage and Rebate Compliance 
 
 
8.10.1 
The Responsible Officer or other responsible person shall ensure and monitor 
compliance with the requirements detailed in this section. 
 
 
8.10.2 
Review Tax Certificate.  Review each Tax Certificate to understand the specific 
requirements that are applicable to each tax-advantaged bond issue.  
 
 
8.10.3 
Arbitrage Yield.  Record the arbitrage yield of the bond issue, as shown on IRS Form 
8038-G, 8038-B, 8038-TC or other applicable form.  If the bonds are variable rate 
bonds, yield must be determined on an ongoing basis over the life of the bonds as 
described in the Tax Certificate.    
 
 
8.10.4 
Temporary Periods.  Review the Tax Certificate to determine the “temporary 
periods” for each bond issue, which are the periods during which proceeds of bonds 
may be invested without yield restriction. 
 
 
8.10.5 
Post-Temporary Period Investments.  Ensure that any investment of bond proceeds 
after applicable temporary periods is at a yield that does not exceed the applicable 
bond yield, unless yield reduction payments can be made pursuant to the Tax 
Certificate. 
 
 
8.10.6 
Monitor Temporary Period Compliance.   Monitor that bond proceeds (including 
investment earnings) are expended promptly after the bonds are issued in accordance 
with the expectations for satisfaction of three-year or five-year temporary periods for 
investment of bond proceeds and to avoid “hedge bond” status. 
 
 
8.10.7 
Monitor Yield Restriction Limitations.  Identify situations in which compliance with 
applicable yield restrictions depends upon later investments (e.g., the purchase of 0% 
State and Local Government Securities from the U.S. Treasury for an advance 
refunding escrow).  Monitor and verify that these purchases are made as 
contemplated. 
 
 
8.10.8 
Establish Fair Market Value of Investments.  Ensure that investments acquired with 
bond proceeds satisfy IRS regulatory safe harbors for establishing fair market value 
(e.g., through the use of bidding procedures), and maintaining records to demonstrate 
satisfaction of such safe harbors.  Consult the Tax Certificate for a description of 
applicable rules. 
 
 
8.10.9 
Credit Enhancement, Hedging and Sinking Funds.  Consult with bond counsel before 
engaging in credit enhancement or hedging transactions relating to a bond issue, and 
before creating separate funds that are reasonably expected to be used to pay debt 
service on bonds.  Maintain copies of all contracts and certificates relating to credit 
enhancement and hedging transactions that are entered into relating to a bond issue.

Financial Management Policies 
Page 26 
 
 
 
8.10.10 
Grants/Donations to Governmental Entities.  Before beginning a capital campaign or 
grant application that may result in gifts that are restricted to bond-financed projects 
(or, in the absence of such a campaign, upon the receipt of such restricted gifts), 
consult bond counsel to determine whether replacement proceeds may result that are 
required to be yield restricted. 
 
 
8.10.11 
Bona Fide Debt Service Fund.  Even after all proceeds of a given bond issue have 
been spent, ensure that the debt service fund meets the requirements of a “bona fide 
debt service fund,” i.e., one used primarily to achieve a proper matching of revenues 
with debt service that is depleted at least once each bond year, except for a reasonable 
carryover amount not to exceed the greater of: (i) the earnings on the fund for the 
immediately preceding bond year; or (ii) one-twelfth of the debt service on the issue 
for the immediately preceding bond year.  To the extent that a debt service fund 
qualifies as a bona fide debt service fund for a given bond year, the investment of 
amounts held in that fund is not subject to yield restriction for that year. 
 
 
8.10.12 
Debt Service Reserve Funds.  Ensure that amounts invested in any reasonably 
required debt service reserve fund do not exceed the least of: (i) 10% of the stated 
principal amount of the bonds (or the sale proceeds of the bond issue if the bond 
issue has original issue discount or original issue premium that exceeds 2% of the 
stated principal amount of the bond issue plus, in the case of premium, reasonable 
underwriter’s compensation); (ii) maximum annual debt service on the bond issue; 
or (iii) 125% of average annual debt service on the bond issue.

Financial Management Policies 
Page 27 
 
 
 
8.10.13 
Rebate and Yield Reduction Payment Compliance.  Review the Arbitrage Rebate 
covenants contained in the Tax Certificate.  Subject to certain rebate exceptions 
described below, investment earnings on bond proceeds at a yield in excess of the 
bond yield (i.e., positive arbitrage) generally must be rebated to the U.S. Treasury, 
even if a temporary period exception from yield restriction allowed the earning of 
positive arbitrage. 
 
a. Ensure that rebate and yield reduction payment calculations will be timely 
performed and payment of such amounts, if any, will be timely made.  Such 
payments are generally due 60 days after the fifth anniversary of the date of issue 
of the bonds, then in succeeding installments every five years.  The final rebate 
payment for a bond issue is due 60 days after retirement of the last bond of the 
issue.  The City should hire a rebate consultant if necessary. 
b. Review the rebate section of the Tax Certificate to determine whether the “small 
issuer” rebate exception applies to the bond issue. 
c. If the 6-month, 18-month, or 24-month spending exceptions from the rebate 
requirement (as described in the Tax Certificate) may apply to the bonds, ensure 
that the spending of proceeds is monitored prior to semi-annual spending dates 
for the applicable exception. 
d. Make rebate and yield reduction payments and file Form 8038-T in a timely 
manner.  
e. Even after all other proceeds of a given bond issue have been spent, ensure 
compliance with rebate requirements for any debt service reserve fund and any 
debt service fund that is not exempt from the rebate requirement (see the 
Arbitrage Rebate covenants contained in the Tax Certificate). 
 
 
8.10.14 
Maintenance and Retention of Arbitrage and Rebate Records.  Maintain records of 
investments and expenditures of proceeds, rebate exception analyses, rebate 
calculations, Forms 8038-T, and rebate and yield reduction payments, and any other 
records relevant to compliance with the arbitrage restrictions for the period indicated 
in Section 11 below. 
 
 
Section 8.11: Record Retention 
 
 
8.11.1 
For each issue of bonds or other obligations of the City, the Responsible Officer or 
other responsible person shall ensure and monitor the transcript and all records and 
documents described in these Procedures will be maintained while any of the bonds 
are outstanding and during the three-year period following the final maturity or 
redemption of that bond issue, or if the bonds are refunded (or re-refunded), while 
any of the refunding bonds are outstanding and during the three-year period 
following the final maturity or redemption of the refunding bonds.

Financial Management Policies 
Page 28 
 
 
Policy 9 
Fund Balance 
 
Purpose:  Identify and classify fund balances in accordance with Governmental Accounting 
Standards Board (GASB) Statement No. 54, Fund Balance Reporting and Governmental Fund 
Type Definitions and establish minimum fund balance targets as recommended by the Government 
Finance Officers Association Best Practices and Advisories guidelines, Replenishing Fund 
Balance in the General Fund. 
 
Section 9.1: Fund Balance Classifications 
 
 
9.1.1 
In accordance with GASB 54, the City shall categorize fund balance within five 
classifications for governmental accounting and tracking purposes as more fully 
defined within this policy: 
  
1. Nonspendable, 
2. Restricted, 
3. Committed 
4. Assigned, and 
5. Unassigned.   
 
 
9.1.2 
The City shall maintain a prudent level of financial resources to protect against 
reducing service levels, incurring debt, or raising taxes and fees because of 
unexpected revenue shortfalls, unanticipated expenditures, and similar 
circumstances.   The City shall use this Fund Balance Policy as guide to prepare 
and execute the annual budget to ensure the City: 
 
1. maintains sufficient reserves for cash flow needs, economic and legislative 
uncertainties, unanticipated expenditures or revenue shortfalls, and 
contingencies 
2. preserves flexibility throughout the fiscal year to make adjustments in funding 
for programs approved in connection with the annual budget. 
 
Section 9.2: Nonspendable Fund Balances 
 
 
9.2.1 
Consists of funds that are not in a spendable form (e.g., inventories and prepaid 
items) or funds that legally or contractually must be maintained intact (e.g., corpus 
of a permanent fund). 
 
Section 9.3: Restricted Fund Balances 
 
 
9.3.1 
Consists of funds that are externally imposed by creditors (e.g., debt covenants), 
grantors, contributors, laws and regulations of other governments, or by law 
through constitutional provisions or enabling legislation.

Financial Management Policies 
Page 29 
 
 
Section 9.4: Committed Fund Balances 
 
 
9.4.1 
The Council may set aside funds (“Committed Fund Balances”) for specific 
purposes by adopting a resolution prior to the end of the fiscal year.   The City 
may not use Committed Fund Balances for any other purpose unless the Council 
removes or changes the specified uses by resolution.  
 
 
9.4.2 
As a Committed Fund Balance, the Council may establish Fiscal Stabilization 
reserves within the General Fund.  The City may use fiscal stabilization reserves 
when the following conditions are met: 
  
a. The City has exhausted all efforts to fund the response to a natural disaster, 
urgent event, revenue shortfall or budget deficit, and there are no budget 
adjustments available to continue to provide the essential services to the 
public. 
b. The City Manager, or designee, analyzes and documents the impacts of the 
natural disaster, urgent event, revenue shortfall, or budget deficit. 
c. Sudden and unexpected declines in ongoing revenues, including taxes, 
intergovernmental revenues, and charges for services, when such declines 
exceed 10 percent (10%) of General Fund operating revenues. 
d. Sudden or unexpected drop in state-shared revenues, such as income taxes and 
state sales taxes, when such declines exceed 10 percent (10%) of the budgeted 
General Fund operating revenues of the prior fiscal year. 
e. Reduction in secondary assessed valuations or secondary property tax 
collections, resulting in secondary property tax revenue below the City’s 
general obligation debt service requirements. 
f. Sudden or unexpected risk management loss that exceeds available reserves 
in the Risk Management Fund. 
g. The Council approves the spending of stabilization reserves by a simple 
majority vote. 
 
The City shall not spend fiscal stabilization reserves in excess of the amount 
required to offset the revenue shortfall or unexpected budget deficit.    
 
9.4.3 
If the reserves are spent down below the minimum required reserve levels, the 
City shall replenish the reserves within five (5) fiscal years following the fiscal 
year in which the reserves were spent. If the depletion of the reserves occurs 
during an ongoing economic downturn, the City shall restore the funds within five 
(5) years of revenue stabilization, as applicable. The Finance Director shall report 
the progress of reserve replenishment in the City’s Annual Budget & Financial 
Plan. 
 
9.4.4 
The City shall maintain fiscal stabilization reserves equal to twenty-five percent 
(25%) of the highest annual General Fund plus Special Revenue Funds 
operating expenditures identified in the Capital Improvements Plan (CIP) for

Financial Management Policies 
Page 30 
 
any year, rounded up to the nearest $1,000,000.  For example if the General 
Fund plus Special Revenue Funds operating expense in year five of the CIP is 
$31 million the reserve would be $8.0 million ($31,000,000 * 25% = $7,750,000 
rounded to $8,000,000). 
 
Section 9.5: Assigned Fund Balances 
 
 
9.5.1 
The City Manager may set aside funds (Assigned Fund Balances) for specific 
purposes and shall report the set asides to the Council at their next meeting.  The 
Council may remove or change the assignment with a majority vote.    
 
Section 9.6: Unassigned Fund Balances 
 
 
9.6.1 
Includes funds not otherwise classified above as the residual classification within 
the General Fund.  The City may use unassigned funds for any lawful purpose as 
identified and recommended by the City Manager and approved by the Council. 
 
Section 9.7: Order and Use of Fund Balances 
 
 
9.7.1 
When the City has the discretion to expend funds from more than one or all of the 
Fund Balances, the City shall expend according to the following order: 
 
a. Restricted Fund Balances 
b. Committed Fund Balances 
c. Assigned Fund Balances 
d. Unassigned Fund Balances