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3077 Continuing Disclosure Administrative Procedures

Pursuant to SEC Rule 15c2-12 (the “Rule”), issuers of municipal obligations are required under most circumstances to provide financial and operating information on an annual basis with the Municipal Securities Rulemaking

Board (MSRB) using the Electronic Municipal Market Access system (EMMA) for the benefit of Bondholders. Independent School District 9, Tulsa County, Oklahoma (Union Public Schools) (the “district”) has issued obligations which are covered by the Rule and must comply with any required filings in a timely manner. This Board Policy is intended to assure such filings are completed to provide a competitive market for the district’s bonds or notes and meet all obligations related to the Rule. The district has covenanted to comply with the Rule through the execution and delivery of Continuing Disclosure Certificate(s) applicable to each series of bonds issued.

The Responsible Party for the district shall be the Chief Financial Officer and/or the Director of Accounting (“Responsible Party”). The Responsible Party shall maintain a current list for each fiscal year identifying each issue of Obligation of the district outstanding during such fiscal year setting forth the name, original principal amount, date of issuance and CUSIP numbers for each such issue and the dates by which the Annual Report Filings and the Audited Financial Statements are required to be submitted to the MSRB using EMMA, such list to be accompanied by copies of the related Continuing Disclosure Certificate. He/she shall be knowledgeable and familiar with the type of financial information and other data necessary to meet any requirements as set forth in the Continuing Disclosure Certificate(s). The district may engage the services of a bond consultant to fulfill the Continuing Disclosure filing requirement(s).

The Responsible Party shall be knowledgeable and familiar with the provisions of each Continuing Disclosure Certificate as to the type, format, and content of the financial information and operating data to be included in each Annual Report Filing to be made thereunder and the timing requirements for the filing thereof. Generally such Continuing Disclosure Certificate provides or is expected to provide submission dates of no later than 180 days following the close of the district’s fiscal year which is currently June 30, generally by December 27, or another date specified in the Continuing Disclosure Certificate.

The Responsible Party shall be knowledgeable and familiar with the specific requirements for the filing of a Notice of Failure to provide the Annual Report and/or to file Audited Financial Statements by the date(s) required under the terms of each Continuing Disclosure Certificate. The Responsible Party shall send a notice of such failure to the MSRB by a date not in excess of ten (10) business days after the occurrence of such failure.

On or before the submission date indicated above, the Responsible Party shall electronically file the required information (i.e., the Annual Report and the Audited Financial Statements) with EMMA. If the Audited Financial Statements are not available by December 27 the Responsible Party shall instead file the Annual Report and unaudited financial information with EMMA. Thereafter, said Audited Financial Statements shall be filed with EMMA as soon as possible, but not later than 45 days following receipt and acceptance of the Audited Financial Statements by the Board of Education. The district will implement calendar reminders in district recordkeeping systems.

The Responsible Party shall coordinate the preparation and submission of the required information with the district’s Financial Advisor or Paying Agent to ensure full compliance with the Rule.

The Responsible Party shall maintain records with respect to the filings with EMMA, including, but not limited to, EMMA posting receipts showing the dates and nature or contents of all filings during each fiscal year for each outstanding bond issue.

Currently, there is no State Information Depository (SID) in the State of Oklahoma. If the State of Oklahoma should establish a SID, the district will file all required information with such SID.


Adopted 12/8/14

Revised 12/9/19