Compliance Checks: Tax-Exempt Bond Compliance Monitoring

1. Before requesting Bond funding reimbursement for expenditures, the capital project accounts are approved and reviewed by the Treasurer for eligibility to be covered for bond use.
2. The approved expenditures are charged to the respective capital project accounts during the year. The Business Office maintains a requisition spreadsheet which contains each “Treasurer approved for bond use capital project account” with the current expenditures for each request.
3. These requisition requests for funding from the bond are made periodically during the year by the Controller and Associate Treasurer based on the capital project account charges. Each requisition is available electronically in the Finance Division electronic files.
4. After bond issuance certain benchmarks dates and amounts need to be met to avoid Arbitrage Rebate. The Treasurer is informed of the arbitrage benchmark rebate for spending exceptions by the Virginia State Non-Arbitrage Program (SNAP). Capital project cumulative spending is monitored by the Business Office on the requisition spreadsheet to compare to the calculated benchmarks. Also, a third-party rebate servicer (Bingham Arbitrage Rebate Services, Inc.) is contracted to report annually on arbitrage
   compliance. The Treasurer reviews each of these reports to ensure compliance.

Last Updated: May 2023