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05/23/2016 feedback from the Annual Disclosure Compliance Group, to enable the Annual Disclosure Compliance Group to conclude that this Disclosure Policy was followed and that the Annual Filing is accurate and complete in all material respects. The Annual Disclosure Compliance Group shall approve the final draft of the Annual Filing. The Disclosure Coordinator shall file the Annual Filing with the MSRB through EMMA by the deadline established by each continuing disclosure undertaking of the City. The Disclosure Coordinator shall exercise reasonable care to file the Annual Filing in the format and with the required identifying information, including applicable CUSIP numbers for the City's bonds. Listed Event Notices The list of Listed Events applicable to continuing disclosure undertakings executed on or after December 1, 2010 is attached hereto as Exhibit A. Listed Events are required to be filed with EMMA within 10 business days following their occurrence. The Disclosure Coordinator shall request in writing that the City Manager, City Attorney and Finance Director notify the Disclosure Coordinator immediately after learning of any Listed Event, regardless of materiality, and repeat such request in a quarterly reminder. The Disclosure Coordinator shall consult with disclosure counsel and the City Attorney to determine if a Listed Event is material, if materiality is a requirement. The Finance Director and City Attorney shall promptly review and approve or comment on the Listed Event notice. The Disclosure Coordinator shall incorporate such comments into the Listed Event notice to be filed with EMMA. The Disclosure Coordinator shall not file the Listed Event notice until it is approved by the City Attorney, unless the Listed Event notice (a) gives notice of a rating change, bond call, or defeasance or (b) such approval has not been received by the applicable filing deadline (10 business days). The Disclosure Coordinator shall file the Listed Event notice with the MSRB through EMMA within 10 business days or, if the facts cannot be correctly and fairly described by the deadline, then as soon thereafter as possible. The Disclosure Coordinator shall exercise reasonable care to file the Listed Event notice in the format and with the identifying information required by the Disclosure Agreements, including CUSIP numbers for the applicable bonds of the City. ATTY/RES0.0044/CC RESO DEBT DISCLOSURE POLICIES AND PROCEDURES REV:05-12-16 JS Page 11 of 13