D-700 Post Issuance Compliance for Tax-Exempt Obligations

The College recognizes that compliance with pertinent law is an ongoing process necessary during the entire term of the tax-exempt obligations. It is an integral component of the College’s debt management. Accordingly, analyzing those facts and implementing the policy will require ongoing monitoring and consultation with bond counsel and the College’s accountants and advisors.

A Post-Issuance Compliance Policy sets forth specific policies of the College designed to monitor post-issuance compliance:

• With applicable provisions of the Internal Revenue Code of 1986, as amended, and regulations promulgated thereunder for obligations issued by the College on a tax-exempt or tax-advantaged basis ("Obligations").

• With applicable requirements set forth in certificates and agreement(s) ("Continuing Disclosure Agreements") providing for ongoing disclosure in connection with the offering of obligations to investors, for obligations (whether or not tax-exempt / tax-advantaged) subject to the continuing disclosure requirements of Rule 15c2-12(b)(5) (the "Rule") promulgated by the Securities and Exchange Commission under the Securities Exchange Act of 1934.

The College procedure documents practices and describes various procedures and systems designed to identify on a timely basis fact relevant to demonstrating compliance with the requirements that must be satisfied after the issuance of Obligations so that the interest on such Obligations continues to be eligible to be excluded from gross income for federal income tax purposes or that the Obligations continue to receive tax-advantage treatment. The federal tax law requirements applicable to each issue to Obligations will be detailed in the arbitrage or tax certification prepared by bond counsel and signed by officials of the College.

This Policy establishes a permanent, ongoing structure of practices and procedures that will facilitate compliance with the requirements for individual borrowings.

This Policy similarly documents practices and describes various procedures and systems designed to ensure compliance with Continuing Disclosure Agreements by preparing and disseminating related reports and information and reporting "material events" to benefit the holders of the College's obligations and to assist the Participating Underwriters (within the meaning of the Rule) in complying with the Rule.

DEVELOPMENT OF WRITTEN PROCEDURES AND/OR ADMINISTRATIVE RULE

The Vice President of Finance and College Operations/CFO shall develop, maintain, and follow written procedures and/or an Administrative Rule for monitoring post-issuance compliance.