704.02 DEBT MANAGEMENT POLICY
704.02 DEBT MANAGEMENT POLICYDEBT 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 strive to repay working capital debt by the end of the fiscal year in which the debt
was incurred. 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 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 there is a compelling public
policy objective for doing so.
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 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.
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 in extraordinary circumstances
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 an independent financial advisor. The financial 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, financial 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:
1) 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);
2) proper maintenance of records to support federal tax compliance;
3) investments and arbitrage compliance;
4) expenditures and assets;
5) private business use; and
6) 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: 8/17/2022
Regulation 704.02-R(1): Debt Management-Post Insurance Compliance
Regulation 704.02-R(1): Debt Management-Post Insurance ComplianceRegulation 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