other · I-1
I-1 - Finance Plan Tiffin 2021A Refunding
Page 9 of 10
Text from the PDF text layer; check the PDF for anything that matters. Attachment 4 – Related Considerations
Bank Qualification
We understand the City (in combination with any subordinate taxing jurisdictions or debt
issued in the City’s name by 501(c)3 corporations) anticipates issuing $10,000,000 or less in tax-
exempt debt during this calendar year. Therefore, the Bonds will be designated as “bank
qualified” obligations pursuant to Federal Tax Law.
Arbitrage Compliance
All tax-exempt bond issues are subject to federal rebate requirements which require all arbitrage
earned in relation to the investment of bond proceeds to be rebated to the U.S. Treasury. A
rebate exemption the City expects to qualify for is the “small issuer” exemption because the
City expects to issue less than $5,000,000 of tax-exempt bonds, including any 501(c)3 conduit
financings, in calendar year 2021.
The City must also maintain a bona fide debt service fund for the Bonds or be subject to yield
restriction in the debt service fund. A bona fide debt service fund involves an equal matching of
revenues to debt service expense with a balance forward permitted equal to the greater of the
investment earnings in the fund during that year or 1/12 of the debt service of that year.
The City should become familiar with the various Arbitrage Compliance requirements for this
bond issue. The Resolution for the Bonds prepared by Bond Counsel explains the requirements
in greater detail.
Continuing Disclosure
Type: Full
Dissemination Agent: Northland Securities
The requirements for continuing disclosure are governed by SEC Rule 15c2-12. The primary
requirements of Rule 15c2-12 actually fall on underwriters. The Rule sets forth due diligence
needed prior to the underwriter’s purchase of municipal securities. Part of this requirement is
obtaining commitment from the issuer to provide continuing disclosure. The document
describing the continuing disclosure commitments (the “Undertaking”) is contained in the
Official Statement that will be prepared to offer the Bonds to investors.
The City has more than $10,000,000 of outstanding debt and is required to undertake “full”
continuing disclosure. Full disclosure requires annual posting of the audit and a separate
continuing disclosure report, as well as the reporting of certain “material events.” Material
events set forth in the Rule, including, but not limited to, bond rating changes, call notices, and
issuance of “financial obligations” (such as SRF Loans, TIF Rebate Agreements, leases, or bank
placements) must be reported within ten business days of occurrence. The report contains
annual financial information and operating data that “mirrors” material information presented
in the Official Statement. The specific contents of the annual report will be described in the
Undertaking that appears in the appendix of the Official Statement. Northland currently serves
as dissemination agent for the City, assisting with the annual reporting. The information for the
Bonds will be incorporated into our reporting.
Premiums
In the current market environment, it is likely that the proposed pricing will include premiums.
A premium price occurs when the underwriter pays the City an amount in excess of the par
amount of a maturity in exchange for a higher coupon (interest rate). The use of premiums
reflects the underwriter’s view on future market conditions, tax considerations for investors and
Northland Securities, Inc. Page 7
Sources
- sharepoint (I-1 - Finance Plan Tiffin 2021A Refunding.pdf) — where it was found ↗ first seen Oct 12, 2026
Data last updated October 15, 2026. Built from the archive's documents; see how the data is built.