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Continuing Disclosure Undertaking <br />Publicly issued LiD financings fall under the requirements of the SEG 15c2-12 regulations. if the <br />issue meets the size thresholds of the regulation, reporting to the Nationally Recognized <br />Municipal Securities Information Repository (NRMSIR) is required. Of particular importance for <br />reporting is the annual call of LID bonds. LID bonds are relatively unique in that they have annual <br />unscheduled calls of bonds. The calls are unscheduled in that the number of bonds called is <br />dependent on the receipt of assessment payments and cannot be scheduled at the time of <br />issuance, only estimated. Prior to the issuance of the bonds and the passage of the financing <br />ordinance or resolution, reviewthe reporting requirements under 15c2-12 with bond counsel and <br />set up the mechanism for annual reporting under the regulation. <br />Arbitrage Tracking <br />LID financings are subject to the Arbitrage Regulations in the same manner that all other b are <br />subject to the regulations. If arbitrage is earned, rebates must be paid. <br />A rebate requirement will most likely be incurred as a result of the balance and interest earnings <br />of the reserve or guaranty fund for the LID bonds. Arbitrage tracking is necessary to insure <br />compliance with the regulations and may be accomplished by qualified people and software <br />programs within your municipality or by independent professionals who specialize in providing <br />the service. Given the potential penalties for failure to comply, the cost of the professional <br />service is relatively low at the current time. Ask your financial advisor and/or bond counsel for <br />a list of firms who provide the service. In addition, keep accurate records of the interest earned <br />in the reserve or guaranty fund as well as the debt service fund and do not commingle the funds <br />with other funds and accounts. <br />Contributor: Steve Gaidos <br />Local and Road Improvement Districts Manual for Washington State Sixth Edition 51 <br />