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05/23/2016 v. Establishing a procedure for ensuring that other information that is reasonably expected to reach investors and the marketplace for the City's securities, such as certain information posted on the City's website, is reviewed so that such information meets the Rule 10b-5 standard. The current procedures for public statements of the City are set forth below under "Public Statements Regarding Information Material to City Bond Issues." vi. Monitoring compliance by the City with these Disclosure Policies and updating these Disclosure Policies, as necessary or appropriate. vii. The Disclosure Coordinator shall compile and retain a file of the actions taken to prepare, check, and approve offering documents or continuing disclosure filings, including the sources of the information included, the comments and actions of the Financing Group, the description of the process followed by the Financing Group including any items discussed with outside counsel that were not included in the offering document based on advice of counsel, and any necessary internal approvals. Financing Group The Disclosure Coordinator shall identify a Financing Group for each financing (the composition of which may differ for each financing), which shall include other City department director(s) as appropriate, City Finance Department staff, the City Attorney or a designated staff attorney and staff from other City departments as needed. Outside experts, such as the municipal advisor and disclosure counsel, will advise the Financing Group in accordance with their contractual obligations. Review and Approva/ of Officia/ Statements Resaonsibilities of Financinq Group. The Financing Group shall provide the required information for and review drafts of an Official Statement prior to it being finalized. More specifically: (i) The Financing Group will (a) determine (with input from the City's municipal advisor and disclosure counsel and, in the case of a negotiated offering, the City's underwriters) what information should be disclosed in the Official Statement to present fairly a description of the source of repayment and security for the securities being offered, (b) assign responsibilities for assembling and verifying the information, and (c) establish a schedule for producing the information and the Official Statement that will afford sufficient time for final review by the Financing Group and the Disclosure Coordinator. While the information included in the last offering document may be used as a starting point, the Financing Group should be encouraged to provide suggestions for improvement and not assume the last offering document represents a complete list of what is currently required. ATTY/RE50.0044/CC RE50 DEBT DISCLOSURE POLICIES AND PROCEDURES RESO.#15493 REV:05-12-16 JS MUFF#205 Page 4 of 13