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developments. Baa BBB BBB Adequate capacity to secure debt. Adverse developments may affect ability to meet debt service requirements. Note: Moody's uses the designation "1" to indicate greater strength within the "Baa", "A", "Aa" categories. Standard & Poor's and Fitch use "=" and "-" to indicate relative strength or weakness in the "BBB", "A", and "AA" categories. 12. MARKET RELATIONSHIPS The Director of Finance will be responsible for maintaining relationships with investors, credit analysts, and rating agencies. 13. ON-GOING DEBT ADMINISTRATION The Director of Finance will regularly review the City's outstanding obligations, particularly in declining interest rate environments. When rates begin to approach levels at which refunding is cost-effective, the City shall select a financing team to begin preparations for a refunding issue. A. Continuing Disclosure: The Finance staff will ensure that the City's annual financial statements and associated reports are posted on the City's web site. The City will also contract with Consultant(s) to comply with the Securities and Exchange Commission Rule 15c2 by filing its annual financial statements and other financial and operating data for the benefit of its bondholders on the Electronic Municipal Market Access (EMMA) website of the Municipal Securities Rulemaking Board (MSRB). B. Arbitrage Rebate Compliance and Reporting: The use and investment of bond proceeds must be monitored to ensure compliance with arbitrage restrictions. Existing regulations require that issuers calculate rebate liabilities related to any bond issues, with rebates paid to the Federal Government every five years and as otherwise required by applicable provisions of the Internal Revenue Code and regulations. The Director of Finance shall contract with a specialist to ensure that proceeds and investments are tracked in a manner that facilitates accurate, complete calculations, and if necessary, timely rebate payments. C. Use of Bond Proceeds: The Director of Finance shall report to the City Council annually at the same time as the City's annual audited financial statements the actual use of bond proceeds to ensure the use is consistent with intended use and that the proceeds are spent in accordance with tax requirements City of Pleasanton Debt Management Policy (February 2022) Page 12