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CITY OF RAMSEY, MINNESOTA <br />GOVERNMENTAL BONDS <br />POST -ISSUANCE COMPLIANCE <br />POLICIES AND PROCEDURES <br />The following policies and procedures were adopted by the City Council of the City of <br />Ramsey, Minnesota (the "City") as of the date indicated below with respect to the governmental <br />bonds of the City, to require, and further ensure, the ongoing compliance of governmental bonds <br />issued by the City with the Internal Revenue Code of 1986, as amended (the "Code"), and the <br />Treasury Regulations promulgated thereunder (the "Regulations"), including the record retention <br />requirements of Code Section 6001 and Section 1.6001(a) of the Treasury Regulations. Such <br />policy and procedures were adopted after consultation with Taft Stettinius and Hollister, LLP <br />(formerly Briggs and Morgan, P.A.), the bond counsel ("Bond Counsel"), and Northland <br />Securities, Inc., the financial advisors, to the City and are internal operating procedures to be used <br />by the City's management in connection with the issuance and sale of all issues of governmental <br />bonds. <br />The City Council of the City has the overall, final responsibility for monitoring whether <br />the City is in compliance with post -issuance federal tax requirements for the City's governmental <br />bonds. However, the City Council assigns to the Finance Director of the City the primary operating <br />responsibility to monitor the City's compliance with post -issuance federal tax requirements for the <br />City's governmental bonds. The Finance Director may further assign post -issuance compliance <br />responsibilities to other staff of the City, Bond Counsel, the paying agent for the bonds, and a <br />rebate analyst. The Finance Director shall provide training and educational resources to City staff <br />who are responsible for ensuring compliance with any portion of these policies and procedures. <br />4553512v1 <br />