COMPREHENSIVE BASE SERVICES
The base subscription to MuniVault® includes services allowing issuers and borrowers of tax-advantaged bonds to comport with the six key areas of IRS guidance related to post-issuance compliance, as well as unique requirements imposed by some states. Our base services are described below:
The vault is our secure, cloud-based repository for your post-issuance compliance information, housing nearly any file type in its native format. Once in the vault, files are maintained as read-only, ensuring the integrity of the data filed. Recordkeeping deadlines exceed the life of the bonds—the vault ensures their preservation.
Some states require annual filings of debt issued during the year, bonds outstanding, tax increment financing activities and related filings and reporting. MuniVault® has the flexibility to accommodate these additional regulatory filings to help you stay in full compliance across your reporting regime.
IRS regulations have become more restrictive regarding the ability of issuers and borrowers to identify the disposition of each dollar of bond proceeds. Preliminary and final allocations are important steps in this process. We can help you through this process.
While the Municipal Securities Rulemaking Board's EMMA system has become much more user-friendly in recent years, the Dataport interface can still be a bit opaque, especially if you use it once a year. We use it all the time and will take care of this important step for you.
Post-issuance compliance policies impose requirements for routine review of outstanding transactions to ensure there have been no changes that might impair their eligibility for continued exemption. We use a simple checklist process to help you complete this work annually.
As we saw in early 2019 an SEC amendment to Rule 15c2-12, post-issuance compliance policies are living documents. We will help you work thorugh this and future changes to ensure your policy is effective and matches your internal compliance practices.
The bond compliance officer (BCO) needs to be the organization's internal compliance expert, often working across departments to ensure effective compliance. We will help the BCO build confidence and expertise through period training and topical updates when important through they year.
Coming in 2019 is an enhancement to the MuniVault® system that will permit automated email notifications to you of upcoming compliance deadlines and activities. This is just another way our service helps you to maintain an effective and well-implmented compliance regime.
Some post-issuance compliance policies require reporting to the governing body from time-to-time to bring public confidence to the organization's compliance activities. The MuniVault® service includes providing additional assurance that your policies are being implemented.
While most post-issuance policies are geared around annual activities—training, reporting, EMMA filings—we are available anytime to assist with bringing a new BCO up to speed, reviewing policies for changes, answering a question or assisting with drafting and filing a material event notice.
VALUABLE ON-DEMAND SERVICES
Issuers and borrowers can extend the value of their MuniVault® subscriptions through our additional, optional service offerings. We take a best-of-breed approach to certain services, passing-through at our cost the expertise of partners that we know and trust.
We work closely with third-party experts to assist with your arbitrage rebate calculation needs. Particulary with the recent rise in short-term investment yields, rebate calculations may show positive arbitrage for highly-rated issuers.
Need help designing internal templates and forms to be used among your team and throughout your organization to implement your post-issuance compliance policy? Our team can create and update those forms for you.
Sometimes even the best compliance policies cannot prevent an unintentional failure in compliance, leading to a reportable event. Although a bond lawyer should guide the process, we can assist in supporting your voluntary reporting process with the IRS.
MuniVault® is a great way to store information required to be archived under your post-issuance compliance policy, but it is equally convenient to maintain records for other financings like bank direct purchases, state revolving loans, taxable bond transactions and other financings.
Most bond transcripts and other important records these days are available as PDFs. But, post-issuance compliance policies require, for instance, records of refunded bonds to be kept with their refunding bonds. Need scanning? We can help. Send us the physical records and we will take care of the rest.
Does your policy work a little differently than others? Do you have unique state recordkeeping requirements? Do you have an organizational change pending that might require some more in-depth, ad hoc training? No worries. We are here to help. MuniVault® is flexibile enough to meet the needs of each organization.
We created MuniVault® in response to clients who told us that they did not have the staff, the time or the expertise to manage the responsibilities of new post-issuance compliance policies they had been asked to adopt. We understand, for many issuers and borrowers, debt issuance and debt management is simply one more burden heaped upon already stretched finance staff. We approach MuniVault® in the same way we do our financial and investment advisory services: by understanding the unique needs of each of our clients and tailoring our services to meet those needs.
Columbia Capital Management, LLC has been providing financial and investment advisory services to state, regional, local governments and non-profits for more than two decades. As a registered municipal advisor and SEC-registered investment adviser, we provide indendent, expert advice to our municipal bond issuer and borrower clients as their fiduciaries. You can learn more about us here.