(a) Arbitrage Rebate Reporting. The Commission will comply with all arbitrage rebate requirements as established by the Internal Revenue Service and all disclosure requirements established by the Securities and Exchange Commission. This effort includes tracking investment earnings on bond proceeds, calculating rebate payments in compliance with the tax law and rebating positive arbitrage earnings to the federal government in a timely manner in order to preserve the tax exempt status of the Commission’s outstanding debt issues.

(b) Disbursements and Management of Accounts. The CFO or designee will be the Commission’s representative controlling disbursements from bond accounts held by trustees or managed by the Commission. Bond accounts include, among others, the debt service fund, project fund, and applicable escrow accounts. At the appropriate time, the Finance Office will proactively close the trust accounts related to a particular bond issue. This practice will ameliorate the possibility of unauthorized use of the bond proceeds and will further comply with IRS regulations relative to spend-down requirements and arbitrage rebate calculations.

(c) Investment of Bond Proceeds. Commission funds held for capital purposes are invested by the Finance Office designee in accordance with the Commission’s investment policy, which conforms to State of Maryland law on the investment of public funds. The Commission invests primarily in obligations of the United States government, its agencies or instrumentalities, repurchase agreements, and bankers’ acceptances.

(d) Investor Relations and Continuing Disclosure. The Commission will maintain compliance with disclosure standards promulgated by Maryland State and federal regulatory agencies and provide ongoing disclosure information to current and potential investors on its website at www.wsscwater.com. Hard copies of certain documents may also be made available upon request. The financial documents to be made available to the public include the WSSC Bond and Note Information Book and WSSC’s Official Statement. The Bond and Note Information Book is prepared on an annual basis with data as of the Commission’s fiscal year-end. The Official Statement is prepared subsequent to each bond sale or refunding. The Commission will provide the most recent copy of each of these documents as well as a number of historical submissions as deemed appropriate. Also available are the Commission’s audited annual financial reports, fiscal year budget information and capital improvements program (CIP) submissions. The CFO will maintain policy and procedures for the compliance with the Commission’s continuing disclosure agreements, preparation of official statements and the filing of reportable events. Such procedures will include appropriate training for staff responsible for compliance.

(e) Refunding. The Commission, in coordination with its financial advisor, will monitor outstanding Commission debt relative to existing market conditions and, subject to approval of a bond refunding plan by Prince George’s County and Montgomery County Councils and Executives in accordance with the PUA, will refund any outstanding debt when sufficient cost savings can be realized. The general guideline for determining if a refunding is economically desirable is when the Commission can save, on a net present value basis, at least two percent of the amount of bonds being refunded. In cases of advance refunding, the Commission may purchase state and local government securities (the “SLGs”) to fund the escrow. If SLGs are not available or are less cost effective than open market securities, upon permission from the CFO and with guidance from bond counsel, the Commission may fund the escrow with competitively bid United States Treasury securities. (REG-FIN-FI-2015-002 § VII)