University Resources, Operations and Policies


Post-Issuance Compliance Tax Exempt Bond Financings

Policy Statement

The University engages outside bond counsel to assist in timely reviewing compliance with all regulations for its tax-exempt bond issues. In addition, the University follows a number of procedures to comply with all post-issuance regulations. IRS Publication 4077, Tax Exempt Bonds for 501(c)(3) Charitable Organizations, provides an overview of general rules under federal tax law that apply to qualified 501(c)(3) bond financing arrangements. The federal tax rules discussed in Publication 4077 include, but are not limited to information filing and other requirements related to issuance, the proper and timely use of bond-financed property and arbitrage yield restriction and rebate requirements. The University has adopted policies to comply with the regulations set forth in Publication 4077.

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Reason for Policy                                                                    

The University finances certain capital projects through the issuance of qualified 501(c)(3) tax-exempt bonds. The Internal Revenue Service Code and Treasury Regulations as well as the Bond Documents set forth rules which must be satisfied both at the time the bonds are issued and during the entire term of the bonds in order for the bonds to maintain a tax-exempt status.

It is the University’s policy to comply with all applicable laws, regulations and contracts applicable to its tax-exempt bonds.

Who Is Governed by this Policy                                         

Finance Office

Policy Owner

Robert Decarlo

Secondary Contact

Susan Okrent

Document History                                                      

  • Last Reviewed Date: October 12, 2017
  • Last Revised Date: October 12, 2017
  • Policy Origination Date: Not known            

Who Approved This Policy                                                  

Robert DeCarlo, Chief Financial Officer & Associate Vice President

Michael J. McLeod, Director of Financial Operations and Associate Vice President

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