OFA requires borrowers, as a condition of financing, to adopt and follow appropriate “post-issuance compliance procedures.” The goal of these procedures is to make sure that the borrower takes appropriate steps, after issuance of the bond, to meet tax and securities laws requirements.
OFA has worked with its Bond Counsel to develop suggested Post-Issuance Compliance Procedures, provides these Procedures to borrowers for their adoption. Borrowers are not required to adopt OFA’s suggested procedures. Some OFA borrowers may already have post-issuance compliance procedures in place, or may wish to develop their own procedures. In that case, OFA suggests that the borrower work closely with its bond counsel and other advisors to make sure that these procedures comply with legal requirements.
Post-Issuance Compliance Documents