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<br /> <br /> <br /> <br />PURPOSE <br />The purpose of this Municipal Securities Disclosure Policy (“Policy”) is to memorialize and communicate <br />the policies and procedures in connection with both the initial and annual continuing disclosure <br />undertakings for municipal securities issued by the City of Santa Ana, California (the "City"), the Santa Ana <br />Public Financing Authority, the Successor Agency to the Santa Ana Redevelopment Agency and certain <br />community facility districts and assessment districts (collectively, the "Santa Ana Issuers"). Adherence to <br />the Policy will ensure compliance with federal securities laws, promote best practices, and enhance the <br />City’s internal controls and control environment. In addition, the Policy will also establish a Continuing <br />Disclosure Committee which will have general oversight of the disclosure process. <br /> <br />This Policy is subject to recommendations for improvements during the annual disclosure process. As <br />such, the Executive Director of Finance & Management Services Agency (“Finance”) is authorized and has <br />the responsibility to update, modify, and/or make recommended changes when appropriate. <br /> <br />BACKGROUND <br />The Santa Ana Issuers have issued and expect that they will in the future issue bonds, certificates of <br />participation, notes or other obligations (collectively, “Obligations”) which are offered to the investing <br />public. Issuers of publicly offered municipal securities are required under most circumstances to provide <br />certain financial and operating information on an annual basis to the Municipal Securities Rulemaking <br />Board (MSRB) utilizing the database Electronic Municipal Market Access system (EMMA) to assist the <br />underwriter of such municipal securities in complying with Rule 15c2 -12(b)(5) promulgated under the <br />Securities and Exchange Act of 1934 (the “Rule”). The Santa Ana Issuers have covenanted or will covenant <br />to assist such underwriters in complying with the Rule through the execution and delivery of continuing <br />disclosure agreements or certificates (each, a "Continuing Disclosure Undertaking") applicable to each <br />issue of Obligations. The Santa Ana Issuers must comply with any required filings in a timely manner in <br />accordance with its respective offering documents for the Obligations. This Policy and the associated <br />procedures are intended to ensure that all filings required under the Rule are made timely and all <br />requirements set forth in the Continuing Disclosure Undertakings are met. <br /> <br />The Rule requires that an underwriter, prior to purchasing or selling an issue of municipal securities in <br />connection with a covered offering, determine that the issuer, and any other “Obligated Person” (as <br />defined in the Rule) for whom financial or operating data is presented in the official statement, has <br />undertaken in writing to provide the following information to the MSRB using EMMA: <br /> <br />• By a specified date, annual financial and operating information for each Obligated Person for whom <br />financial information or operating data is presented in the official statement (an "Annual Information <br />Filing"); <br /> <br /> <br />City of Santa Ana <br />Administrative <br />Policies and Procedures <br /> <br /> <br />City Manager’s Authorization <br /> <br />Subject <br />Municipal Securities Disclosure Policy & Procedures <br /> <br /> <br />Date <br />November 19, 2024