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<br /> 4 <br />present value debt service savings equal to or greater than 100% of any escrow fund negative <br />arbitrage. <br /> <br />E. Internal Control Procedures <br /> <br />When issuing debt, in addition to complying with the terms of this Debt Policy, the City <br />shall comply with any other applicable policies regarding initial bond disclosure, continuing <br />disclosure, post-issuance compliance, and investment of bond proceeds. <br /> <br />Without limiting the foregoing, the City will periodically review the requirements of and will <br />remain in compliance with the following: <br /> <br />• Any continuing disclosure undertakings entered into by the City in accordance <br />with SEC Rule 15c2-12. <br /> <br />• Any federal tax compliance requirements, including, without limitation, arbitrage <br />and rebate compliance. <br /> <br />• The City’s investment policies as they relate to the use and investment of bond <br />proceeds. <br /> <br />Proceeds of debt will be held either (a) by a third-party trustee or fiscal agent, which will <br />disburse such proceeds to or upon the order of the City upon the submission of one or more <br />written requisitions by the Finance Director (or his or her written designee), or (b) by the City, to <br />be held and accounted for in a separate fund or account, the expenditure of which will be carefully <br />documented by the City. <br /> <br />F. Adoption by Related Local Agency <br /> <br />This Debt Policy may be adopted, and shall be applicable to, any other local agency for <br />which the City Council acts as the governing board thereof (each, a “Local Agency”). The <br />adoption of this Debt Policy by the Local Agency shall be evidenced by a resolution adopted by <br />the City Council, in its capacity as the governing board of such Local Agency, or other governing <br />board of such Local Agency, adopting this Debt Policy and specifying the officer(s) thereof, or of <br />the City, authorized to submit the requisitions, and required to retain the records, described in <br />Section E above on behalf of such Local Agency. <br />98