704 REVENUE

704 REVENUE Jen@iowaschool… Thu, 07/11/2019 - 17:52

704.02 DEBT MANAGEMENT POLICY

DEBT LIMITS

Credit Ratings

The school district seeks to maintain the highest possible credit ratings for all categories of short- and long-term debt that can be achieved without compromising the delivery of services and the achievement of adopted objectives. The school district recognizes that external economic, natural, or other events may from time to time affect the creditworthiness of its debt. Nevertheless, the school district is committed to ensuring that actions within their control are prudent.

Debt Limits

For general obligation debt, the school district’s outstanding debt limit shall be no more than five percent (5%) of the actual value of property within the school district’s boundaries, as prescribed by the Iowa constitution and statutory restrictions.

For revenue debt, the school district’s goal is to provide adequate debt service coverage of at least 1.20 times the annual debt service costs.

In accordance with Iowa law, the school district may not act as a conduit issuer or issue
municipal securities to raise capital for revenue-generating projects where the funds generated are used by a third party (“conduit borrower”) to make payments to investors.

PURPOSES AND USES OF DEBT

Capital Planning

To enhance creditworthiness and prudent financial management, the school district is
committed to systematic capital planning, intergovernmental cooperation and coordination and long-term financial planning.

Capital Financing

The school district may issue long-term debt for capital projects as authorized by Iowa law, which include, but are not limited to, the costs of planning, design, land acquisition, buildings, permanent structures, attached fixtures or equipment, and movable pieces of equipment. Capitalized interest may be included in sizing any capital project debt issue. The types of debt instruments to be used by the school district include:

General Obligation Bonds
General Obligation Capital Loan Notes
Bond Anticipation Notes
Revenue Anticipation Notes
School Infrastructure Sales, Services and Use Tax Revenue Bonds
Lease Purchase Agreements, including Certificates of Participation

Working Capital Financing

The school district may issue debt for working capital for operations after cash flow analysis has determined that there is a mismatch between available cash and cash outflows. The school district shall repay working capital debt within thirteen (13) months of issuance. A Working Capital Reserve may be included in sizing any working capital debt issue.

Refundings

Periodic reviews of all outstanding debt will be undertaken to determine if refunding opportunities exist. Refunding will be considered (within federal tax law restraints) if and when there is a net economic benefit of the refunding or if the refunding is otherwise in the best interests of the school district, such as to release restrictive bond covenants which affect the operations and management of the school district.

In general, advance refundings (within federal tax law constraints) for economic savings will be undertaken when a net present value savings exceeds three percent of the refunded debt can be achieved. Current refundings, which produce a new present value savings of less than three percent will be considered on a case by case basis taking into consideration bond covenants and general conditions. Refundings with negative savings will not be considered unless it is in the best interest of the school district.

DEBT STANDARDS AND STRUCTURE

Length of Debt

Debt will be structured for the shortest period consistent with a fair allocation of costs to current and future beneficiaries or users. Long-term debt will not be issued for periods exceeding 120% the useful life or average useful lives of the project or projects to be financed. All debt issued will adhere to state and federal law regarding the length of time the debt may be outstanding.

Debt Structure

Debt will be structured to achieve the lowest possible net cost to the school district given market conditions, the urgency of the capital project, the type of debt being issued, and the nature and type of repayment source. To the extent possible, the school district will design the repayment of its overall debt to rapidly recapture its credit capacity for future use.

Generally, the school district will only issue fixed-rate debt. In very limited circumstances, the school district may issue variable rate debt, consistent with the limitations of Iowa law and upon a finding of the board that the use of fixed rate debt is not in the best interest of the school district and a statement of the reasons for the use of variable rate debt.

All debt may be structured using discount, par or premium coupons, and as serial or term bonds or notes, or any combination thereof, consistent with Iowa law. The school district should utilize the coupon structure that produces the lowest True Interest Cost (TIC) taking into consideration the call option value of any callable maturities.

The school district will strive to structure their debt in sinking fund installments for each debt issue that achieves, as nearly as practicable, level debt service within an issue or overall debt service within a particular classification of debt.

Derivatives (including, but not limited to, interest rate swaps, caps, collars, corridors, ceiling and floor agreements, forward agreements, float agreements, or other similar financing arrangements), zero-coupon or capital appreciation bonds are not allowed to be issued consistent with State law.

Decision Analysis to Issue Debt

Whenever the school district is contemplating the issuance of debt, information will be developed concerning the following four categories commonly used by rating agencies
assessing the school district’s credit worthiness, listed below.

Debt Analysis – Debt capacity analysis; purpose for which debt is proposed to be issued; debt structure; debt burden; debt history and trends; and adequacy of debt and capital planning.

Financial Analysis – Stability, diversity, and growth rates of tax or other revenue sources; trend in assessed valuation and collections; current budget trends; appraisal of past revenue and expenditure trends; history and long-term trends of revenues and expenditures; evidences of financial planning; adherence to GAAP; audit results; fund balance status and trends in operating and debt funds; financial monitoring systems and capabilities; and cash flow projections.

Governmental and Administrative Analysis – Government organization structure; location of financial responsibilities and degree of control; adequacy of basic service provision; intergovernmental cooperation/conflict and extent of duplication; and overall planning efforts.

Economic Analysis – Geographic and location advantages; population and demographic
characteristics; wealth indicators; types of employment, industry and occupation; housing characteristics; new construction; evidence of industrial decline; and trend of the economy.

DEBT ISSUANCE

Credit Enhancement

Credit enhancements (.i.e., bond insurance, etc.) may be used but only when the net debt service on the debt is reduced by more than the costs of the credit enhancement.

Costs and Fees

All costs and fees related to issuing the debt will be paid out of debt proceeds and allocated across all projects receiving proceeds of the debt issue.

Method of Sale

Generally, all school district debt will be sold through a competitive bidding process. Bids will be awarded on a TIC basis providing other bidding requirements are satisfied.The school district may sell debt using a negotiated process if it is in the best interest of the school district when the complexity of the issue requires specialized expertise, when the negotiated sale would result in substantial savings in time or money, or when market conditions of school district credit are unusually volatile or uncertain.

Professional Service Providers

The school district will retain external bond counsel for all debt issues. All debt issued by the school district will include a written opinion by bond counsel affirming that the school district is authorized to issue the debt, stating that the school district has met all Iowa constitutional and statutory requirements necessary for issuance and determining the debt’s federal income tax status. The bond counsel retained must have comprehensive municipal debt experience and a thorough understanding of Iowa law as it relates to the issuance of the particular debt.

The school district will retain a municipal advisor. The municipal advisor will be responsible for structuring and preparing all offering documents for each debt issue. The financial advisor retained will have comprehensive municipal debt experience, experience with diverse financial structuring and pricing of municipal securities.

The treasurer shall have the authority to periodically select other service providers (e.g., escrow agents, verification agents, trustees, arbitrage consultants, rebate specialist, etc.) as necessary to meet legal requirements and minimize net debt costs. These services can include debt restructuring services and security or escrow purchases.

Compensation for bond counsel, municipal advisor and other service providers will be as economical as possible and consistent with industry standards for the desired qualification
levels.

DEBT MANAGEMENT

Investment of Debt Proceeds

The school district shall invest all proceeds received from the issuance of debt separate from the school district’s consolidated cash pool unless otherwise specified by the authorizing bond resolution or trust indenture. Investments will be consistent with those authorized by Iowa law and the school district’s Investment Policy to maintain safety of principal and liquidity of the funds.

Arbitrage and Record Keeping Compliance

The Treasurer shall maintain a system of record-keeping, reporting and compliance procedures with respect to all federal tax requirements which are currently, or may become applicable through the lifetime of all tax-exempt or tax credit bonds.

Federal tax compliance, record-keeping, reporting and compliance procedures shall include not
be limited to:

post-issuance compliance procedures (including proper use of proceeds, timely expenditure of proceeds, proper use of bond financed property, yield restriction and rebate, and timely return filing);
proper maintenance of records to support federal tax compliance;
investments and arbitrage compliance;
expenditures and assets;
private business use; and
designation of primary responsibilities for federal tax compliance of all bond financings.

Financial Disclosure

The school district is committed to full and complete financial disclosure, and to cooperating fully with rating agencies, institutional and individual investors, other levels of government, and the general public to share comprehensible and accurate financial information. The school district is dedicated to meeting secondary disclosure requirements on a timely and comprehensive basis, as promulgated by the Securities and Exchange Commission.

The Official Statements Accompanying debt issues, Annual Audits, and Continuing Disclosure statements will meet the standards articulated by the Municipal Securities Rulemaking Board (MSRB), the Government Accounting Standards Board (GASB), the Securities and Exchange Commission (SEC), Generally Accepted Accounting Principles (GAAP) and the Internal Revenue Service (IRS). The treasurer shall be responsible for ongoing debt disclosure as required by any Continuing Disclosure Certificate for any debt issue and for maintain compliance with disclosure standards promulgated by state and federal regulatory bodies.

Legal Reference Iowa Code §§ 74-76; 278.1; 298; 298A (2013).

Cross Reference: 701 Financial Accounting System

704 Revenue

Approved Reviewed: 4/23/2018 Revised: 7/15/26

Jen@iowaschool… Thu, 07/11/2019 - 18:09

Regulation 704.02-R(1): Debt Management-Post Insurance Compliance

Regulation for Tax-Exempt Obligations

1. Role of Compliance Coordinator/Board Treasurer

The board treasurer shall:

a. Be responsible for monitoring post-issuance compliance;

b. Maintain a copy of the transcript of proceedings or minutes in connection with
the issuance of any tax-exempt obligations and obtain records that are
necessary to meet the requirements of this regulation;

c. Consult with bond counsel, a rebate consultant, financial advisor, IRS
publications and such other resources as are necessary to understand and
meet the requirements of this regulation;

d. Seek out training and education to be implemented upon the occurrence of
new developments in the area and upon the hiring of new personnel to
implement this regulation.

2. Financing Transcripts’ Filing and Retention

The board treasurer shall confirm the proper filing of an IRS 8038 Series return and
maintain a transcript of proceedings and minutes for all tax-exempt obligations
issued by the school district including, but not limited to, all tax-exempt bonds, notes
and lease-purchase contracts. Each transcript shall be maintained until 11 years
after the tax-exempt obligation documents have been retired. The transcript shall
include, at a minimum:

a. Form 8038;

b. Minutes, resolutions and certificates;

c. Certifications of issue price from the underwriter;

d. Formal elections required by the IRS;

e. Trustee statements;

f. Records of refunded bonds, if applicable;

g. Correspondence relating to bond financings; and

h. Reports of any IRS examinations for bond financings.

3. Proper Use of Proceeds

The board treasurer shall review the resolution authorizing issuance for each tax-
exempt obligation issued by the school district and the school district shall:

a. Obtain a computation of the yield on such issue from the school district's
financial advisor;

b. Create a separate Project Fund (with as many sub-funds as shall be
necessary to allocate proceeds among the projects being funded by the
issue) into which the proceeds of issue shall be deposited;

c. Review all requisitions, draw schedules, draw requests, invoices and bills
requesting payment from the Project Fund;

d. Determine whether payment from the Project Fund is appropriate and, if so,
make payment from the Project Fund (and appropriate sub-fund, if
applicable);

e. Maintain records of the payment requests and corresponding records
showing payment;

f. Maintain records showing the earnings on, and investment of, the Project
Fund;

g. Ensure that all investments acquired with proceeds are purchased at fair
market value;

h. Identify bond proceeds or applicable debt service allocations that must be
invested with a yield-restriction and monitor the investments of any yield-
restricted funds to ensure that the yield on such investments do not exceed
the yield to which such investments are restricted;

i. Maintain records related to any investment contracts, credit enhancement
transactions and the bidding of financial products related to the proceeds.

4. Timely Expenditure and Arbitrage/Rebate Compliance

The board treasurer shall review the Tax-Exemption Certificate (or equivalent) for
each tax-exempt obligation issued by the school district and the expenditure records
provided in Section 2 of this regulation, above and shall:

a. Monitor and ensure that proceeds of each such issue are spent within the
temporary period set forth in such certificate;

b. Monitor and ensure that the proceeds are spent in accordance with one or
more of the applicable exceptions to rebate as set forth in such certificate if
the school district does not meet the "small issuer" exception for said
obligation;

c. Not less than 60 days prior to a required expenditure date, confer with bond
counsel and a rebate consultant, if the school district will fail to meet the
applicable temporary period or rebate exception expenditure requirements of
the Tax-Exemption Certificate. In the event the school district fails to meet a
temporary period or rebate exception:

1. Procure a timely computation of any rebate liability and, if rebate is
due, file a Form 8038-T and arrange for payment of such rebate
liability;

2. Arrange for timely computation and payment of yield reduction
payments (as such term is defined in the Code and Treasury
Regulations), if applicable.

5. Proper Use of Bond Financed Assets

The board treasurer shall:

a. Maintain appropriate records and a list of all bond financed assets. Such
records shall include the actual amount of proceeds (including investment
earnings) spent on each of the bond financed assets;

b. Monitor and confer with bond counsel with respect to all proposed bond
financed assets;

1. management contracts;

2. service agreements;

3. research contracts;

4. naming rights contracts;

5. leases or sub-leases;

6. joint venture, limited liability or partnership arrangements;

7. sale of property; or

8. any other change in use of such assets.

c. Maintain a copy of the proposed agreement, contract, lease or arrangement,
together with the response by bond counsel with respect to said proposal for
at least three years after retirement of all tax-exempt obligations issued to
fund all or any portion of bond financed assets; and

d. Contact bond counsel and ensure timely remedial action under IRS
Regulation Sections 1.141-12 in the event the school district takes an action
with respect to a bond financed asset, which causes the private business
tests or private loan financing test to be met.

6. General Project Records

For each project financed with tax-exempt obligations, the board treasurer shall
maintain, until three years after retirement of the tax-exempt obligations or
obligations issued to refund those obligations, the following:

a. Appraisals, demand surveys or feasibility studies;

b. Applications, approvals and other documentation of grants;

c. Depreciation schedules;

d. Contracts respecting the project.

7. Advance Refundings

The board treasurer shall be responsible for the following current, post issuance and
record retention procedures with respect to advance refunding bonds. The board
treasurer shall:

a. Identify and select bonds to be advance refunded with advice from internal
financial personnel and a financial advisor;

b. Identify, with advice from the financial advisor and bond counsel, any possible
federal tax compliance issues prior to structuring any advance refunding;

c. Review the structure with the input of the financial advisor and bond counsel,
of advance refunding issues prior to the issuance to ensure;

1. that the proposed refunding is permitted pursuant to applicable federal
tax requirements if there has been a prior refunding of the original
bond issue;

2. that the proposed issuance complies with federal income tax
requirements which might impose restrictions on the redemption date
of the refunded bonds;

3. that the proposed issuance complies with federal income tax
requirements which allow for the proceeds and replacement proceeds
of an issue to be invested temporarily in higher yielding investments
without causing the advance refunding bonds to become "arbitrage
bonds"; and

4. that the proposed issuance will not result in the issuer's exploitation of
the difference between tax exempt and taxable interest rates to obtain
an financial advantage nor overburden the tax exempt market in a way
that might be considered an abusive transaction for federal tax
purposes;

d. Collect and review data related to arbitrage yield restriction and rebate
requirements for advance refunding bonds. To ensure such compliance, the
board treasurer shall engage a rebate consultant to prepare a verification
report in connection with the advance refunding issuance. Said report shall
ensure said requirements are satisfied;

e. Whenever possible, purchase State and Local Government Series (SLGS) to
size each advance refunding escrow. The financial advisor shall be included
in the process of subscribing to SLGS. To the extent SLGS are not available
for purchase, the Board treasurer shall, in consultation with bond counsel and
the financial advisor, comply with IRS regulations;

f. Ensure, after input from bond counsel, compliance with any bidding
requirements set forth by the IRS regulations to the extent as issuer elects to
the purchase of a guaranteed investment contract;

g. In determining the issue price for any advance refunding issuance, obtain and
retain issue price certification by the purchasing underwriter at closing;

h. After the issuance of an advance refunding issue, ensure timely identification
of violations of any federal tax requirements and engage bond counsel in an
attempt to remediate the same in accordance with IRS regulations.

8. Continuing Disclosure

The board treasurer shall assure compliance with each continuing disclosure
certificate and annually, per continuing disclosure agreements, file audited annual
financial statements and other information required by each continuing disclosure agreement.

The board treasurer will monitor material events as described in each
continuing disclosure agreement and assure compliance with material event
disclosure. Events to be reported shall be reported promptly, but in no event not later
than 10 business days after the day of the occurrence of the event. Currently, such
notice shall be given in the event of:

a. Principal and interest payment delinquencies;

b. Non-payment related defaults, if material;

c. Unscheduled draws on debt service reserves reflecting financial difficulties;

d. Unscheduled draws on credit enhancements relating to the bonds reflecting
financial difficulties;

e. Substitution of credit or liquidity providers, or their failure to perform;

f. Adverse tax opinions, the issuance by the Internal Revenue Service of
proposed or final determinations of taxability, Notices of Proposed Issue (IRS
Form 5701-TEB), or other material notices, or determinations with respect to
the tax-exempt status of the bonds, or material events affecting the tax-
exempt status of the bonds;

g. Modifications to rights of Holders of the Bonds, if material;

h. Bond calls (excluding sinking fund mandatory redemptions), if material and
tender offers;

i. Defeasances of the bonds;

j. Release, substitution, or sale of property securing repayment of the bonds, if
material;

k. Rating changes on the bonds;

l. Bankruptcy, insolvency, receivership or similar event of the Issuer;

m. The consummation of a merger, consolidation, or acquisition involving the
Issuer or the sale of all or substantially all of the assets of the Issuer, other
than in the ordinary course of business, the entry into a definitive agreement
to undertake such an action or the termination of a definitive agreement
relating to any such actions, other than pursuant to its terms, if material; and

n. Appointment of a successor or additional trustee or the change of name of a
trustee, if material.

I.C. Iowa Code Description

Iowa Code § 278.1 Power of Electors
Iowa Code § 298 School Taxes and Bonds
Iowa Code § 298A School District Fund Structure
Iowa Code § 74 Public Obligation Warrants
Iowa Code § 75 Sale of Public Bonds
Iowa Code § 76 Public Bonds and Debt Obligations
Cross References
Code Description
701.02 Transfer of Funds

Approved: 08/17/2022 Reviewed Revised

ahaack@e-hawks.org Tue, 08/23/2022 - 10:42

704.1 LOCAL - STATE - FEDERAL - MISCELLANEOUS REVENUE

The board treasurer shall receive revenues of the school district. Other persons receiving
revenues on behalf of the school district shall promptly turn them over to the board treasurer.

Revenue, from whatever source, shall be accounted for and classified under the official
accounting system of the school district. It shall be the responsibility of the board treasurer to
deposit the revenues received by the school district in a timely manner. School district funds
from all sources shall not be used for private gain or political purposes.

Tuition fees received by the school district shall be deposited in the general fund. The tuition
fees for kindergarten through twelfth grade during the regular academic school year shall be set
by the board based upon the superintendent's recommendation in compliance with current law.
Tuition fees for summer school, driver's education and adult education shall be set by the board
prior to the offering of the programs.

The board may charge materials fees for the use or purchase of educational materials.
Materials fees received by the school district shall be deposited in the general fund. It shall be
the responsibility of the superintendent to recommend to the board when materials fees will be
charged and the amount of the materials fees.

Rental fees received by the school district for the rental of school district equipment or facilities
shall be deposited in the general fund. It is the responsibility of the superintendent to
recommend to the board a fee schedule for renting school district property.

Proceeds from the sale of real property shall be placed in the physical plant and equipment levy
(PPEL) fund. However, following a properly noticed public hearing, the board of directors may
elect to deposit proceeds from the sale of real property or buildings into any fund under the
control of the school corporation. Notice for the public hearing must be published in a
newspaper of general circulation within the district not less than 10 and no more than 20 days
prior to the proposed public hearing. Notice of the public hearing must include the date, time,
and location of the public hearing, and a description of the proposed action. The proceeds from
the sale of other school district property shall be placed in the general fund.

The board may claim exemption from the law prohibiting competition with private enterprise for
the following activities:

Goods and services directly and reasonably related to the educational mission;

Goods and services offered only to students, employees or guests which cannot be provided by
private enterprise at the same or lower cost;

Use of vehicles for charter trips offered to the public, full- or part-time, or temporary students;

Goods and services which are not otherwise available in the quantity or quality required by the
school district;

Telecommunications other than radio or television stations;

Sponsoring or providing facilities for fitness and recreation;

Food service and sales; and,

Sale of books, records, tapes, software, educational equipment, and supplies.

It shall be the responsibility of the superintendent to bring to the board's attention additional
sources of revenue for the school district.

Legal Reference: Iowa Code §§ 12C; 23A; 257.2; 279.8; 282.2, .6, .24; 291.12, 297.9-.12,
.22; 301.1 (2013).

Cross Reference: 701.1 Depository of Funds

703 Budget

803 Selling and Leasing

905 Use of School District Facilities & Equipment

Approved 1/10/72 Reviewed 8/17/2022 Revised 4/09/01

Jen@iowaschool… Thu, 07/11/2019 - 18:03

704.2 SALE OF BONDS

The board may conduct an election for the authority to issue bonded indebtedness. Revenues generated from an approved bond issue shall be used only for the purpose stated on the ballot. Use of excess funds in the account for another purpose requires approval of the voters in the school district community.

Revenues received from the issuing of bonded indebtedness shall be deposited in to the physical plant and equipment levy (PPEL) fund.

Legal Reference: Iowa Code §§ 74-76; 278.1; 298; 298A (1999).

Cross Reference: 701 Financial Accounting System

704 Revenue

Approved: 1/10/1972 Reviewed:3/21/2018 Revised:4/09/2001

Jen@iowaschool… Thu, 07/11/2019 - 18:04

704.3 INVESTMENTS

Scope of Investment

The Investments policy of the [Insert name of school district] shall apply to all public funds of the school district, which includes operating funds, bond proceeds, and all other funds, and all investment transactions involving public funds accounted for in the financial statements of the school district. Each investment made pursuant to this policy must be authorized by applicable law and this written Investments Policy.

The investment of debt service or sinking funds shall comply not only with this Investments policy, but also be consistent with any applicable bond resolution.

This policy is intended to comply with Iowa Code 12B.

Upon passage and upon future amendment, if any, copies of this policy shall be delivered to all the following:

The governing body or officer of the school district to which the Investments policy applies.
All depository institutions or fiduciaries for public funds of the school district.
The auditor engaged to audit any funds of the school district.

In addition, a copy of this policy shall be delivered to every fiduciary or third party assisting with or facilitating investment of school district funds.

Delegation of Authority

In accordance with Iowa Code 12B.10(1), the responsibility for conducting investment transactions resides with the Treasurer. Only the Treasurer and those authorized by resolution may invest public funds and a copy of any empowering resolution shall be attached to this policy.

All contracts or agreements with outside persons investing public funds, advising on the investment of public funds, directing the deposit or investment of public funds or acting in a fiduciary capacity for the school district shall require the outside person to notify the school district in writing, within thirty (30) days of receipt of all communication from the Auditor of the outside person or any regulatory authority, of the existence of a material weakness in internal control structure of the outside person or regulatory orders or sanctions regarding the type of services being provided to the school district by the outside person.

The records of investment transactions made by or on behalf of the school district are public records and are the property of whether in the custody of the school district or in the custody of a fiduciary or other third party. If a fiduciary or other third party with custody of school district public investment transaction records fails to produce requested records when requested by the school district within a reasonable time, the school district shall make no new investment with or through the fiduciary or third party and shall not renew maturing investments with or through the fiduciary or third party.

The Treasurer shall establish a written system of internal controls and investment practices. The controls shall be designed to prevent losses of public funds, to document those officers and employees of the school district responsible for elements of the investment process and to address the capability of investment management. The controls shall provide for receipt and review of the audited financial statement and related reports on internal control structure of all outside persons performing any of the following for the school district:

Investing public funds.
Advising on the investment of public funds.
Directing the deposit or investment of public funds.
Acting in a fiduciary capacity for the school district.

A bank, savings and loan association or credit union providing only depository services shall not be required to provide an audited financial statement and related report on internal control structure.

The Treasurer and all employees authorized to place investments shall be bonded in the amount of [insert $ amount].

Objectives

The primary objectives, in order of priority, of all investment activities involving the financial assets of the school district shall be the following:

1. Safety: Safety and preservation of principal in the overall portfolio is the foremost investment objective.

2. Liquidity: Maintaining the necessary liquidity to match expected liabilities is the second investment objective.

3. Return: Obtaining a reasonable return is the third investment objective.

Prudence

The Treasurer, when investing or depositing public funds, shall exercise care, prudence and diligence under the circumstances then prevailing that a person acting in a like capacity and familiar with such matters would use to attain the investment "Objectives". This standard requires that when making investment decisions, the Treasurer shall consider the role that the investment or deposit plays within the portfolio assets of the school district and the investment objectives stated in "Objectives".

When investing school district assets for a period longer than two (2) years, the Treasurer shall request competitive investment proposals for comparable credit and term investments from a minimum of three (3) investment providers.

Instruments Eligible for Investment

School district assets may be invested in the following:

- Obligations of the United States government, its agencies and instrumentalities.

- Certificates of deposit and other evidences of deposit (i.e., savings accounts, interest-bearing checking accounts, money market accounts, etc.) at federally insured Iowa depository institutions approved and secured pursuant to Iowa Code 12C.

Iowa Schools Joint Investment Trust (“ISJIT”).

All instruments eligible for investment are further governed by all other provisions of this Investments policy, including "Investment Maturity Limitations" and "Diversification Requirements".

Prohibited Investments and Investment Practices

School district assets shall not be invested in the following:

Reverse repurchase agreements.
Futures and options contracts.

School district assets shall not be invested pursuant to the following investment practices:

Trading of securities for speculation or the realization of short-term trading gains.
Pursuant to a contract providing for the compensation of an agent or fiduciary based upon the performance of the invested assets

Investment Maturity Limitations

Operating Funds must be identified and distinguished from all other funds available for investment. Operating Funds are defined as those funds which are reasonably expected to be expended during a current budget year or within fifteen months of receipt.

All investments authorized in "Instruments Eligible for Investment" are further subject to the following investment maturity limitations: Operating Funds may only be invested in instruments authorized in "Instruments Eligible for Investment" of this Investments policy that mature within three hundred ninety-seven (397) days. However, if the school district has or expects to accrue in the current budget year an amount of public funds that exceeds Operating Funds by at least thirty-three percent, the school district may invest amounts exceeding thirty-three percent of Operating Funds in certificates of deposit at federally insured depository institutions approved pursuant to Iowa Code 12C which mature within sixty-three months or less provided that the school district invests an amount reasonably expected to be expended during the current budget year or within fifteen months of receipt in investments authorized in "Instruments Eligible for Investment" of this Investment Policy that mature within three hundred ninety-seven (397) days.
The Treasurer may invest funds that are not identified as Operating Funds in investments with maturities longer than three hundred ninety-seven days (397) days. However, all investments of the school district shall have maturities that are consistent with the school district’s needs and use of funds.

Legal Reference: Iowa Code §§ 11.2, .6; 12.62; 12B.10; 10A; 12C; 22.1, .14; 28E.2; 257;

Diversification

School district investments are subject to the following diversification requirements:

Prime bankers' acceptances:

At the time of purchase, no more than ten percent (10%) of the investment portfolio of the school district shall be invested in prime bankers’ acceptances; and
At the time of purchase, no more than five percent (5%) of the investment portfolio of the school district shall be invested in the securities of a single issuer.]

Commercial paper or other short-term corporate debt:

At the time of purchase, no more than ten percent (10%) of the investment portfolio of the school district shall be in commercial paper or other short-term corporate debt;
At the time of purchase, no more than five percent (5%) of the investment portfolio of the school district shall be invested in the securities of a single issuer; and
At the time of purchase, no more than five percent (5%) of all amounts invested in commercial paper and other short-term corporate debt shall be invested in paper and debt rated in the second-highest classification.]

Where possible, it is the policy of the school district to diversify its investment portfolio. Assets shall be diversified to eliminate the risk of loss resulting from over concentration of assets in a specific maturity, a specific issuer, or a specific class of securities. In establishing specific diversification strategies, the following general policies and constraints shall apply:

Portfolio maturities shall be staggered in a way that avoids undue concentration of assets in a specific maturity sector. Maturities shall be selected which provide stability of income and reasonable liquidity.
Liquidity practices to ensure that the next disbursement date and payroll date are covered through maturing investments, marketable U.S. Treasury bills or cash on hand shall be used at all times.
Risks of market price volatility shall be controlled through maturity diversification so that aggregate price losses on instruments with maturities approaching one year shall not be greater than coupon interest and Investment Income received from the balance of the portfolio.

Safekeeping and Custody

All school district invested assets involving the use of a public funds custodial agreement, as defined in Iowa Code 12B.10C, shall comply with all rules adopted pursuant to Iowa Code 12B.10C. All custodial agreements shall be in writing and shall contain a provision that all custodial services be provided in accordance with the laws of the state of Iowa.

All school district invested assets eligible for physical delivery shall be secured by having them held at a third-party custodian. All purchased investments shall be held pursuant to a written third-party custodial agreement requiring delivery versus payment and compliance with all rules set out in this Section, "Safekeeping Custody."

Reporting

The Treasurer shall monthly, submit to the Board of Directors an investment report that summarizes recent market conditions and investment strategies employed since the last investment report. The investment report shall set out the current portfolio in terms of maturity, rates of return and other features and summarize all investment transactions that have occurred during the reporting period and compare the investment results with the budgetary expectations.

Investment Policy Review and Amendment

This Investments policy shall be reviewed every three (3) years or more frequently as appropriate. Notice of amendments to the Investments policy shall be promptly given to all parties noted in the "Scope of Investment" section.

Legal Reference: Iowa Code §§ 11.2, .6; 12.62; 12B.10; 10A; 12C; 22.1, .14; 28E.2; 257;

279.29; 283A; 285; 502.701; 633.123.

I.C. Iowa Code	Description
Iowa Code § 11.2	Annual Settlements
Iowa Code § 11.6	Audits of Governmental Subdivisions
Iowa Code § 12.62	Treasurer of State - Investments
Iowa Code § 12B.10	Public Funds Investment Standards
Iowa Code § 12C	Deposit of Public Funds

Approved 1/10/72 Reviewed 8/17/22 Revised 7/15/26

Jen@iowaschool… Thu, 07/11/2019 - 18:05

704.4 GIFTS - GRANTS - BEQUESTS

The board believes gifts, grants, and bequests to the school district may be accepted when they
will further the interests of the school district. The board shall have sole authority to determine
whether the gift furthers the interests of the school district.

Gifts, grants, and bequests shall be approved by the board. Once it has been approved by the
board, a board member or the superintendent may accept the gift on behalf of the school
district.

Gifts, grants, and bequests once accepted on behalf of the school district shall become the
property of the school district. Gifts, grants, and bequests shall be administered in accordance
with terms, if any, agreed to by the board.

Legal Reference: Iowa Code §§ 279.42; 565.6 (2013).
Cross Reference: 217 Gifts to Board of Directors
402.4 Gifts to Employees
508.1 Class or Student Group Gifts

Approved 1/10/72 Reviewed 08/17/2022 Revised 6/18/2014

Jen@iowaschool… Thu, 07/11/2019 - 18:07

704.5 STUDENT ACTIVITIES FUND

Revenue raised by students or from student activities shall be deposited and accounted for in
the student activities fund. This revenue is the property of and shall be under the financial
control of the board. Students may use this revenue for purposes approved by the building
principal.

Whether such revenue is collected from student contributions, club dues, and special activities or result from admissions to special events or from other fund-raising activities, all funds will be under the jurisdiction of the board and under the specific control of the building principal. They
will be deposited in a designated depository and will be disbursed and accounted for in accordance with instructions issued by the superintendent.
It shall be the responsibility of the board secretary to keep student activity accounts up-to-date
and complete.

Any unencumbered class or activity account balances will automatically revert to the activity
fund when a class graduates or an activity is discontinued.

Legal Reference: Iowa Code §§ 11.23; 279.8 (2013).
Cross Reference: 504 Student Activities

701 Financial Accounting System

Approved 4/09/01 Reviewed 8/17/2022 Revised

Jen@iowaschool… Thu, 07/11/2019 - 18:08

704.6 ONLINE FUNDRAISING CAMPAIGNS – CROWDFUNDING

The Emmetsburg Community School Board of Education believes online fundraising
campaigns, including crowdfunding campaigns, may further the interests of the district. Any
person or entity acting on behalf of the district and wishing to conduct an online fundraising
campaign for the benefit of the district shall begin the process by seeking prior approval from
the Superintendent. Any fundraising efforts conducted using the district’s name, symbols, or
imagery will be conducted in accordance with all policies, regulations and rules for fundraising
within the district. Money or items raised by an online fundraising campaign will be the property
of the district only upon acceptance by the board, and will be used only in accordance with the
terms for which they were given, as agreed to by the board.

Approval of requests shall depend on factors including, but not limited to:

● Compatibility with the district’s educational program, mission, vision, core values, and
beliefs;

● Congruence with the district and school goals that positively impact student
performance;

● The district’s instructional priorities;

● The manner in which donations are collected and distributed by the crowdfunding
platform;

● Equity in funding; and

● Other factors deemed relevant or appropriate by the district.

If approved, the requester shall be responsible for preparing all materials and information
related to the online fundraising campaign and keeping district administration apprised of the
status of the campaign.

The requestor is responsible for compliance with all state and federal laws and other relevant district policies and procedures. All items and money generated are subject to the same controls and regulations as other district property and shall be deposited or inventoried accordingly. No
money raised or items purchased shall be distributed to individual employees.

Legal Reference: Iowa Code §§ 279.8; 279.42; 565.6.
Cross Reference: 508.1 Class or Student Group Gifts
504.5 Student Fundraising
704.4 Gifts – Grants – Bequests
904.2 Advertising and Promotion

Approved 3/21/2010 Reviewed: 8/17/2022 Revised

Jen@iowaschool… Thu, 07/11/2019 - 18:08