2024-073 - Approving Revisions to the Municipal Securities

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City of Santa Ana Administrative Policies and Procedures City Manager's Authorization Subject Date Municipal Securities Disclosure Policy & Procedures November 19, 2024 PURPOSE The purpose of this Municipal Securities Disclosure Policy ("Policy") is to memorialize and communicate the policies and procedures in connection with both the initial and annual continuing disclosure undertakingsfor municipal securities issued by the City of Santa Ana, California (the "City"), the Santa Ana Public Financing Authority, the Successor Agency to the Santa Ana Redevelopment Agency and certain community facility districts and assessment districts (collectively, the "Santa Ana Issuers"). Adherence to the Policy will ensure compliance with federal securities laws, promote best practices, and enhance the City's internal controls and control environment. In addition, the Policy will also establish a Continuing Disclosure Committee which will have general oversight of the disclosure process. This Policy is subject to recommendations for improvements during the annual disclosure process. As such, the Executive Director of Finance & Management Services Agency ("Finance") is authorized and has the responsibility to update, modify, and/or make recommended changes when appropriate. BACKGROUND The Santa Ana Issuers have issued and expect that they will in the future issue bonds, certificates of participation, notes or other obligations (collectively, "Obligations") which are offered to the investing public. Issuers of publicly offered municipal securities are required under most circumstances to provide certain financial and operating information on an annual basis to the Municipal Securities Rulemaking Board (MSRB) utilizing the database Electronic Municipal Market Access system (EMMA) to assist the underwriter of such municipal securities in complying with Rule 15c2-12(b)(5) promulgated under the Securities and Exchange Act of 1934 (the "Rule"). The Santa Ana Issuers have covenanted or will covenant to assist such underwriters in complying with the Rule through the execution and delivery of continuing disclosure agreements or certificates (each, a "Continuing Disclosure Undertaking") applicable to each issue of Obligations. The Santa Ana Issuers must comply with any required filings in a timely manner in accordance with its respective offering documents for the Obligations. This Policy and the associated procedures are intended to ensure that all filings required under the Rule are made timely and all requirements set forth in the Continuing Disclosure Undertakings are met. The Rule requires that an underwriter, prior to purchasing or selling an issue of municipal securities in connection with a covered offering, determine that the issuer, and any other "Obligated Person" (as defined in the Rule) for whom financial or operating data is presented in the official statement, has undertaken in writing to provide the following information to the MSRB using EMMA: • By a specified date, annual financial and operating information for each Obligated Person for whom financial information or operating data is presented in the official statement (an "Annual Information Filing"); Resolution No. 2024-073