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Grant County Personnel Policy
1503 — Procedure
Issue Date
03/09/20
ive Date
3/0 20
Revision Date
03/09/20
Chair
Cindy Carter
Vice Chair
Tom Taylor
VU
J
Commissioner
Richard Stevens
-
1503 — Procedure
1503.1 General Policies
1503.1.1 The Board of County Commissioners (BOCC) may adopt
resolutions or ordinances to set financial policies to assure
the financial strength and accountability of the County.
1503.1.2 The BOCC and/or its designee shall develop administrative
directives and general procedures for implementing the
County's financial policies.
1503.1.3 All County offices and departments will share in the
responsibility of meeting policy goals and ensuring long-term
financial health. Future service plans and programs will be
developed to reflect current policy directives, projected
resources, and future service requirements.
1503.1.4 To attract and retain employees necessary for providing high
quality services, the County shall establish and maintain a
competitive compensation and benefit package with public
and private sectors.
1503.1.5 Efforts will be coordinated with other governmental agencies
to achieve common policy objectives, share the cost of
providing governmental services on an equitable basis, and
support favorable legislation at the state and federal level.
1503.1.6 Grant County will initiate, encourage, and participate in
economic development efforts to create job opportunities and
strengthen the local economy.
1503.1.7 The County will strive to maintain fair and equitable
relationships with its contractors and suppliers.
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1503.2 Revenue Policies — These are designed, maintained, and administered to
ensure a reliable, equitable, diversified, and sufficient revenue stream to
support desired and necessary County services.
1503.2.1 General Revenues
(a) Current expenditures will be funded by current
revenues. The County will try to maintain a diversified
and stable revenue system to protect programs from
short-term fluctuations in any single source.
(b) Budgeted revenues will be estimated conservatively
using accepted standards and estimates provided by the
state, other governmental agencies, or reliable economic
forecasters when available.
(c) General Fund and other unrestricted revenues will not
be earmarked for specific purposes, activities or services
unless otherwise authorized by the BOCC or as required
by law, or through Generally Accepted Accounting
Principles (GAAP). All non -restricted revenues will be
deposited into the General Fund and appropriated by
the budget process.
(d) If revenues from "one-time" or limited duration
sources are used to balance the County's annual
operating budget, it is to be fully disclosed and
explained at the time the budget is presented. It is the
County's goal to not rely on these types of revenues to
balance the operating budget.
(e) The County will not use deficit financing and borrowing
to support on-going operations in the case of long-term
(greater than one year) revenue downturns. Revenue
forecasts will be revised and expenses will be reduced to
conform to the revised long-term revenue forecast or
revenue increases will be considered.
(f) The County will follow an aggressive and professional
policy of collecting revenues. When necessary,
discontinuing service, small claims court, collection
agencies, foreclosure, liens and other methods of
collection — such as imposing penalties, collection and
late charges — maybe used.
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1503.2.2 Fees and Charges
(a) All Enterprise operations will be self-supporting.
(b) The County retains the right to maximize the use of
service users' charges in lieu of ad valorem (property)
taxes and subsidies from other County funds, for
services that can be identified and where costs are
directly related to the level of service provided.
(1) Charges for providing services shall be sufficient to
finance all operating, capital outlay, and debt
service expenses of the County's enterprise funds,
including operating contingency, planned capital
improvements, and reserve requirements.
(2) Other reimbursable work performed by the
County (labor, meals, contracted services,
equipment and other indirect expenses) shall be
billed at actual or estimated actual cost.
(3) Charges for services shall accurately reflect the
actual or estimated cost of providing a specific
service. The cost of providing specific services shall
be recalculated periodically, and the fee adjusted
accordingly. The County shall maintain a current
schedule of fees and charges, showing when the fees
were last reviewed and/or recalculated. Fees and
charges will be reviewed every three years at a
minimum.
(4) The County will consider market rates and charges
levied by other municipalities for like services in
establishing rates, fees, and charges.
(5) Certain fees, such as rental fees, will be based upon
market conditions and are not subject to the
limitations of cost recovery.
1503.2.3 Grants and Gifts
(a) Grant funding for programs or items which address the
County's current priorities and policy objectives should
be considered to leverage County funds. Inconsistent
and/or fluctuating grants should not be used to fully
fund on-going programs.
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(b) Before accepting any grant the County shall thoroughly
consider the implications in terms of ongoing obligations
that will be required in connection with acceptance of
said grant.
(c) All grants and other federal and state funds shall be
managed to comply with the laws, regulations, and
guidance of the grantor.
1503.3 Expenditure Policies - These are designed, maintained, and administered
to identify priority services, establish appropriate service levels, and
administer the expenditure of available resources to assure fiscal
stability and the effective and efficient delivery of services.
1503.3.1 The County will strive to adopt an annual General Fund
budget in which current expenditures do not exceed current
projected revenues. Capital expenditures may be funded
from one-time revenues.
1503.3.2 Elected Officials and Department Heads are responsible
for managing their budgets within the total appropriation
for their department.
1503.3.3 The County will take immediate corrective actions if, at any
time during the fiscal year, expenditure and revenue re -
estimates are such that an operating deficit is projected at
year-end. Corrective actions can include a hiring freeze,
expenditure reductions, fee increases, or use of
contingencies. The Board of County Commissioners may
approve a short-term interf ind loan or use of one-time
revenue sources to address temporary gaps in cash flow,
although this will be avoided if possible.
1503.3.4 Long-term debt or bond financing shall not be used to
finance current operating expenditures.
1503.3.5 The County will assess funds for services provided internally
by other funds. Interfund service fees charged to recover
these costs will be recognized as revenue to the providing
fund.
1503.3.6 Emphasis will be placed on improving individual and work
group productivity rather than adding to the work force.
The County will invest in technology and other efficiency
tools to maximize productivity. The County will hire
additional staff only after the need for such positions has
been demonstrated and documented.
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1503.3.7 All compensation planning and collective bargaining will
focus on the Total Cost of Compensation (TCC) which
includes direct salary, health care benefits, pension
contributions, and other benefits which are a cost to the
County, to the extent that the data is available. The rate of
increase of TCC of negotiated labor contracts will be based,
more or less, on salary/compensation comparables as
determined by the Director of Human Resources. Contracts
presented for approval by the Director of Human Resources
that do not meet these requirements will have specific
operational, legal or other compulsory items identified and
discussed before ratification by the Board of County
Commissioners will be considered.
1503.3.8 Periodic comparisons of service delivery will be made to
ensure that quality services are provided to our citizens at
the most competitive and economical cost. Privatization and
contracting with other governmental agencies will be
evaluated as alternatives to service delivery where
appropriate. Programs that are determined to be inefficient
and/or ineffective shall be reduced in scope or eliminated.
1503.3.9 Whenever feasible, government activities will be considered
enterprises if so doing will increase efficiency of service
delivery or recover the cost of providing the service from the
benefiting entity by user fees.
1503.3.10 The County will make every effort to maximize any
discounts offered by creditors/vendors.
1503.4 Operating Budget Policies
1503.4.1 The County will adopt and maintain a balanced annual
operating budget.
1503.4.2 The County will strive to adopt a budget where current
annual operating revenues will be equal to or greater than
current operating expenditures.
1503.4.3 Balanced revenue and expenditure forecasts will be
prepared to examine the County's ability to absorb
operating costs due to changes in the economy, service
demands, contractual obligations, and capital
improvements. The forecast will encompass five years and
will be updated annually.
1503.4.4 In the event a balanced budget is not attainable, and the
cause of the imbalance is expected to last for no more than
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one year, the planned use of reserves to balance the budget
is permitted. In the event that a budget shortfall is expected
to continue beyond one year, the planned use of reserves
must be developed as part of a corresponding strategic
financial plan to close the gap through revenue increases or
expenditure decreases.
1503.4.5 Any year-end operating surpluses will revert to
unappropriated balances for use in maintaining reserve
levels set by policy and will be available for capital
expenditures and/or "one-time" only General Fund
expenditures.
1503.4.6 The County will provide for adequate maintenance and the
orderly replacement of capital assets and equipment. Fleet
and equipment replacement will be accomplished through
the use of a "rental" rate structure. The rates will be revised
annually to ensure that charges to operating departments
are sufficient for the replacement of the vehicles and
equipment.
1503.4.7 The operating budget shall serve as the annual financial
plan for the County. It will serve as the policy document of
the Board of County Commissioners for implementing its
goals and objectives. The budget will provide County
officials and staff the resources necessary to accomplish
Board of County Commissioner determined service levels.
1503.4.8 As mandated by RCW 36.40.010, the Auditor shall annually
present a proposed operating budget to the County
Commissioners on or before the first Monday in December.
The County Commissioners must adopt by resolution a final
balanced budget no later than December 31 of each year.
1503.4.9 Funds may not be expended or encumbered for the
following fiscal year until the budget has been adopted by
the Board of County Commissioners.
1503.4.10 Budget control and accountability is maintained at the
departmental level.
1503.4.11 In no case may total expenditures of a particular fund
exceed that which is appropriated by the Board of County
Commissioners without a budget amendment. Amendments
to the budget are approved by the Board of County
Commissioners.
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1503.5 Accounting Policies — Comply with prevailing federal, state, and local
statutes and regulations. Confirm to a comprehensive basis of
accounting in compliance with Washington State statutes and with
Generally Accepted Accounting Principles (GAAP) as promulgated by the
Governmental Accounting Standards Board (GASB) and the Government
Finance Officers Association (GFOA), where applicable.
1503.5.1 The County uses the cash basis of accounting which is a
departure from Generally Accepted Accounting Principles
(GAAP).
1503.5.2 The County will maintain expenditure categories according to
state statute and administrative regulation. The County will
use the "Budgeting, Accounting & Reporting System" (BARS)
prescribed by the State Auditor for its revenue and
expenditure classification.
1503.5.3 Monthly budget reports showing the current status of
revenues and expenditures will be prepared and distributed
to appropriate legislative, staff and management personnel
in a timely manner and made available for public
inspection.
1503.5.4 Monthly financial updates will be presented to the Board of
County Commissioners.
1503.5.5 Electronic financial systems will be maintained to monitor
revenues, expenditures, and program performance on an
ongoing basis.
1503.5.6 The Annual Financial Report will be prepared and
submitted to the State Auditor's Office no later than 150
days from the end of the preceding fiscal year.
1503.5.7 The Annual Financial Report will be prepared on the basis
of accounting that demonstrates compliance with
Washington State statutes and the BARS manual prescribed
by the State Auditor, which is a comprehensive basis of
accounting other than Generally Accepted Accounting
Principles. The report will provide full disclosure of all
financial activities and related matters.
1503.5.8 An annual financial audit shall be performed by the
Washington State Auditor's Office, which will issue an
official opinion on the annual financial statements. The
accountability audit (i.e., accountability for public resources
and compliance with state laws and regulations and its own
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policies and procedures) shall be performed every two years
by the Washington State Auditor's Office.
1503.5.9 The County's budget should satisfy criteria as a financial and
programmatic policy document, as a comprehensive
financial plan, as an operations guide for all organizational
units, and as a communications device for all significant
budgetary issues, trends and resources. It should be a goal
of the Accounting Department to submit the budget
document to the Washington Finance Officers Association
(WFOA) or Government Finance Officers Association
(GFOA) Distinguished Budget Presentation program.
1503.6 Capital Management Policies — These are established to review and
monitor the state of the County's capital equipment and infrastructure,
setting priorities for its replacement and renovation based on needs,
funding alternatives, and availability of resources.
1503.6.1 Capital Facilities Plan
(a) The County will continue to follow, update, and revise as
necessary the goals and policies adopted in the Grant
County Comprehensive Plan.
1503.6.2 Capital Asset Plan
(a) The County will maintain its capital assets at a level
adequate to protect the County's capital investment and
to minimize future maintenance and replacement costs.
The budget will provide for adequate maintenance and
orderly replacement of capital assets from current
revenues where possible.
(b) The capitalization threshold used in determining if a
given asset qualifies for capitalization is $5,000 per item
with a useful life of over one year. All capital assets
shall have a County property tag affixed to it when
placed into service.
(c) Minor equipment that falls below the $550 threshold
but is subject to shrinkage shall have a County property
tag affixed to it when placed into County service and
will be accounted for on the "Small and Attractive"
inventory list.
(d) The Accounting Department will oversee an annual
physical count/inspection of all capital assets.
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(e) Adequate insurance will be maintained on all capital
assets consistent with the results of the annual physical
count/inspection.
1503.7 Capital Outlay Budgeting
1503.7.1 Current Expense (General Fund): All budgeted capital must
be listed on the "Computer Capital Outlay" tab or "Capital
Outlay" tab in the Excel worksheet provided by the
Accounting Department for County office/ department budget
submittal. Totals for capital outlay are not to be included in
an office/department's standard budget request/ spreadsheet.
1503.7.2 Special Revenue Funds, Internal Service Funds, and
Pronrietary Funds (those Countv offices/ departments outside
of Current Expense): Totals for Capital Outlay will be
included in an office/ department's standard budget
request/spreadsheet. It is still advisable to list these outlays
on the "Computer Capital Outlay" tab or "Capital Outlay" tab
in the Excel worksheet provided by the Accounting
Department for budget submittal.
1503.8 Purchasing Approval Thresholds
1503.8.1 Current Expense/General Fund Purchases: Any item that has
been previously approved in a Capital Budget that is over
$5,000.00 must have secondary Board of County
Commissioner authorization at the time of purchase.
1503.8.2 Special Revenue Funds, Internal Service Funds, and
Proprietary Funds Purchases: Any item that has been
previously approved in an office/ department budget that is
over $5,000.00 must have secondary Board of County
Commissioner authorization at the time of purchase.
1503.9 Debt Policies — These are intended to establish guidelines for debt
financing that will provide needed capital equipment and infrastructure
improvements while minimizing the impact of debt payments on
current revenues.
1503.9.1 Purpose and Overview: The Debt Policy for the County is
established to help ensure that all debt is issued both
prudently and cost effectively. The Debt Policy sets forth
comprehensive guidelines for the issuance and management
of all financings of the Board of County Commissioners.
Adherence to the policy is essential to ensure that the County
maintains a sound debt position and protects the credit
quality of its obligations.
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1503.9.2 Capital Planning: The County shall integrate its debt issuance
with its Capital Improvement Program (CIP) spending to
ensure that planned financing conforms to policy targets
regarding the level and composition of outstanding debt. This
planning considers the long-term horizon, paying particular
attention to financing priorities, capital outlays and
competing projects. Long term borrowing shall be confined
to the acquisition and/or construction of capital
improvements and shall not be used to fund operating or
maintenance costs. For all capital projects under
consideration, the County shall set aside sufficient revenue
from operations to fund ongoing normal maintenance needs
and to provide reserves for periodic replacement and renewal.
The issuance of debt to fund operating deficits is not
permitted.
1503.9.3 Legal Governing Principles: In the issuance and management
of debt, the County shall comply with the state constitution
and with all other legal requirements imposed by federal,
state, and local rules and regulations, as applicable.
(a) State Statutes — The County may contract indebtedness as
provided for by State law, subject to the statutory and
constitutional limitations on indebtedness.
(b) Federal Rules and Regulations — The County shall issue
and manage debt in accordance with the limitations and
constraints imposed by federal rules and regulations
including the Internal Revenue Code of 1986, as
amended; the Treasury Department regulations
thereunder; and the Securities Acts of 1933 and 1934.
(c) Local Rules and Regulations — The County shall issue
and manage debt in accordance with the limitations and
constraints imposed by local rules, policies, and
regulations.
1503.9.4 Roles & Responsibilities
The Board of County Commissioners shall:
(a) Approve indebtedness;
(b) Approve appointment of the bond underwriter and bond
counsel;
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(c) Approve the General Financial Policies, which
incorporate Section 1503.6, Debt Policy;
(d) Approve budgets sufficient to provide for the timely
payment of principal and interest on all debt; and
The Treasurer, or his/her designee, in consultation with the
Finance Committee, Chief Accountant, and Board of County
Commissioners shall:
(a) Assume primary responsibility for debt management;
(b) Provide for the issuance of debt at the lowest possible cost
and risk;
(c) Determine the available debt capacity;
(d) Provide for the issuance of debt at appropriate intervals
and in reasonable amounts as required to fund approved
capital expenditures;
(e) Recommend to the Board of County Commissioners the
manner of sale of debt;
(f) Opportunities to refund debt and recommend such
refunding, as appropriate, will be sought;
(g) Comply with all Internal Revenue Service IRS
Securities and Exchange (SEC), and Municipal Securities
Rulemaking Board (MSRB) rules and regulations
governing the issuance of debt;
(h) Provide for the timely payment of principal and interest
on all debt and ensure that the fiscal agent receives funds
for payment of debt service on or before the payment
date;
(i) Provide for and participate in the preparation and review
of offering documents;
(j) Comply with all terms, conditions and disclosure required
by the legal documents governing the debt issued;
(k) Submit to the Board of County Commissioners all
recommendations to issue debt;
(1) Comply with undertakings for ongoing disclosure,
pursuant to SEC Rule 15c2-12; and
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(m) Apply and promote prudent fiscal practices.
The Budget Director shall:
(a) Provide for the distribution of pertinent information to
rating agencies.
1503.9.5 Ethical Standards Governing Conduct: All County staff and
the Board of County Commissioners will adhere to the
standards of conduct as stipulated by the Public Disclosure
Act, RCW 42.12 and Ethics in Public Service, RCW 42.52.
1503.9.6 Types of Debt Instruments: The County may utilize several
types of municipal debt obligations to finance long-term
capital projects. Subject to the approval of the Board of
County Commissioners, the County is authorized to sell:
(a) Unlimited Tax General Obligation Bonds — The
County shall use Unlimited Tax General Obligation
Bonds (UTGO), also known as "Voted General Obligation
Bonds" for the purpose of general purpose, open space
and parks, and utility infrastructure. Voted issues are
limited to capital purposes only.
Every project proposed for financing through general
obligation debt should be accompanied by a full analysis
of the future operating and maintenance costs associated
with the project. UTGO Bonds are payable from excess tax
levies and are subject to the assent of 6o% of the voters at
an election to be held for that purpose, plus validation
requirements.
(b) Limited Tax General Obligation Bonds — A Limited -
Tax General Obligation debt (LTGO), also known as
"Non -Voted General Obligation Debt", requires the
County to levy a property tax sufficient to meet its debt
service obligations but only up to a statutory limit. The
County shall use LTGO Bonds as permitted under State
law for lawful purposes only. General Obligation debt is
backed by the full faith and credit of the County and is
payable from non-voter approved property taxes and
other money lawfully available. LTGO Bonds will only
be issued if:
(1) A project requires funding not available from
alternative sources;
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(2) Matching fund monies are available which may be
lost if not applied for in a timely manner; or
(3) Emergency conditions exist
(c) Revenue Bonds — The County shall use Revenue Bonds
as permitted under State law for the purpose of financing
construction or improvements to facilities of enterprise
(i.e., utility) systems operated by the County in
accordance with the Capital Improvement Plan.
(d) Special Assessment/Local Improvement District
Road Improvement District Bonds — The County
shall use Special Assessment Bonds as permitted under
State law for the purpose of assuring the greatest degree
of public equity in place of general obligation bond where
possible. Local Improvement District (LID) and Road
Improvement District (RID) Bonds represent debt that is
repaid by the property owners who specifically benefit
from the capital improvements through annual
assessments paid to the County. LIDS and RIDs are
formed by the Board of County Commissioners after a
majority of property owners agree to the assessment. No
taxing power or general fund pledge is provided as
security, and LID or RID Bonds are not subject to
statutory debt limitations. The debt is backed by the
value of the property within the district and an LID/RID
Guaranty Fund, as required by State Law.
(e) Short Term Debt — The County shall use short term
debt as permitted by State law for the purpose of meeting
any lawful purpose of the municipal corporation,
including the immediate financing needs of a project for
which long term funding has been secured but not yet
received. The County may use interf ind loans rather
than outside debt instruments to meet short-term cash
flow needs for the project. Interfund loans will be
permitted only if an analysis of the affected fund indicates
excess funds are available and the use of the funds will
not impact the fund's current operations. All interfund
loans will be subject to Council approval and will bear
interest at prevailing rates.
(f) Leases — The County is authorized to enter into capital
leases under State law, subject to the approval of the
Board of County Commissioners.
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(g) Public Works Trust Fund Loans — The County shall
use Public Works Trust Fund Loans as provided under
State law for the purpose of repairing, replacing or
creating domestic water systems, sanitary sewer systems,
storm sewer systems, roads, streets, solid waste/recycling
facilities and bridges.
1503.9.7 General Requirements
(a) The County will not use long-term debt to pay for
current operations. The use of bonds or certificates of
participation will only be considered for significant
capital and infrastructure improvements.
(b) The term of the debt shall never extend beyond the
useful life of the improvements to be financed.
(c) General obligation debt will not be used for self-
supporting enterprise activity. The general policy of the
County is to fund general-purpose public improvements
and capital projects that cannot be financed from
current revenues with voter -approved general obligation
debt. Non-voter approved debt may be utilized when a
dedicated revenue source other than general revenue
can be identified to pay debt service expenses.
(d) The general policy of the County is to establish debt
repayment schedules that use level annual principal and
interest payments.
(e) Interest earnings on bond proceeds will be limited to:
(1) funding the improvements specified in the
authorizing bond ordinance; or (2) payment of debt
service on the bonds. Proceeds from debt will be used
in accordance with the purpose of the debt issue. Funds
remaining after the project is completed will be used in
accordance with the provisions stated in the bond
ordinance that authorized the issuance of the debt.
(f) The County will use the most prudent methods of
acquiring capital outlay items, including the use of
lease -purchase agreements. In no case will the County
lease -purchase equipment whose useful life is less than
the term of the lease.
(g) The County will maintain its bond rating at the highest
level fiscally prudent, so that future borrowing costs are
minimized and access to the credit market is preserved.
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The County will encourage and maintain good relations
with financial bond rating agencies and will follow a
policy of full and open disclosure.
(h) The County shall use refunding bonds in accordance with
the Refunding Bond Act, RCW 39.53. Unless otherwise
justified, the County will refinance debt to achieve true
savings as market opportunities arise. Refunding debt
shall never be used for the purpose of avoiding debt
service obligations. A target 4% cost savings (discounted
to its present value) over the remainder of the debt must
be demonstrated for any "advance refunding", unless
otherwise justified.
(i) With Board of County Commissioner approval, interim
financing of capital projects may be secured from the debt
financing marketplace or from other funds through an
interfund loan as appropriate in the circumstances.
(j) When issuing debt, the County shall strive to use special
assessment, revenue or other self-supporting bonds in
lieu of general obligation bonds.
1503.9.8 Limitations on General Obligation Debt Issuance: The
County shall remain in compliance with all debt limitations.
As part of the annual budgeting process, a current summary
of outstanding debt and compliance targets is prepared. The
County shall observe the following limitations on debt
issuance:
• General Obligation — 2.5% of Assessed Value,
from such amount 1.5% may be non -voted general
obligation debt.
Debt payments shall not extend beyond the estimated useful
life of the project being financed. The County shall keep the
average maturity of general obligations bonds at or below 20
years, unless special circumstances arise warranting the need
to extend the debt schedule.
1503.10 Financial Communication Policy
1503.10.1 It is the policy of the County to remain as financially
transparent as possible.
1503.10.2 The County shall manage relationships with the rating
analysts assigned to the County's credit, using both informal
and formal methods to disseminate information.
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1503.10.3 The County's Basic Financial Statements and Notes shall be
a vehicle for compliance with continuing disclosure
requirements. The Notes to the Financial Statements may
be supplemented with additional documentation as
required. Each year included in the Notes to the Financial
Statements, the County will report its compliance with debt
targets and the goals of the Debt Policies.
1503.10.4 The County shall seek to maintain and improve its current
bond rating.
1503.11 Governmental Bonds Post Issuance Compliance
1503.11.1 Specifics: To guide Grant County in meeting its obligations
under applicable statutes, regulations and documentation
associated with publicly offered and privately placed
securities of the County. This policy addresses obligations
of the County that arise and will continue following the
issuance of securities. These obligations may arise as a
result of federal tax law (with respect to tax-exempt
securities) and securities laws (with respect to ongoing
disclosure) or as a result of contractual commitments made
by the County. This policy outlines obligations that may be
applicable to each issue of securities and identifies the party
to be responsible for monitoring compliance. In the County,
the County Treasurer will be responsible for ensuring that
the policy is followed and checklists and records are
maintained.
1503.11.2 Procedure
(a) Treasurer's Ability to Delegate. The County Treasurer
may delegate responsibility to employees and outside
agents for developing records, maintaining records and
checklists. The County will provide educational
opportunities (opportunities to attend educational
programs/seminars on the topic) for the parties
identified in this policy with responsibilities for post -
issuance compliance in order to facilitate their
performance of these obligations.
(b) Transcripts
(1) The County's bond counsel shall provide the County
with two copies of a full transcript related to the
issuance of securities (for each issue). The
transcript shall be delivered in the following form:
one bound paper copy and one electronic file and
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transcripts shall be delivered to the County within
six months following the date of issuance of
securities. It is expected that the transcript will
include a full record of the proceedings related to
the issuance of securities, including proof of filing an
IRS Form 8038-G or 8038 -GC, if applicable.
(2) Bond transcripts will be retained by the following
parties and in the following location within the
County: County Treasurer's office.
(c) Federal Tax Law Requirements (Applicable only if the
securities are issued as "tax-exempt" securities).
(1) Use of Proceeds
(1a) If the project(s) to be financed with the
proceeds of the securities will be funded with
multiple sources of funds, the County will
adopt an accounting methodology that:
(i) Maintains each source of funding
separately and monitors the actual
expenditure of proceeds of the securities;
(ii) Commingles the proceeds and monitors
the expenditures on a first in, first out
basis; or
(iii) Provides for the expenditure of funds
received from multiple sources on a
proportionate basis.
(ib) Records of expenditures (timing of expenditure
and object code) of the proceeds of securities
will be maintained by the County Treasurer.
(1c) Records of investments and interest earnings
on the proceeds of securities will be maintained
by the County Treasurer. Such records should
include the amount of each investment, the
date each investment is made, the date each
investment matures and, if sold prior to
maturity, its sale date and its interest rate
and/or yield. Interest earnings on proceeds
will be deposited in the fund in which the
proceeds of the securities were deposited (if
not, then the plan for use of interest earnings
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will be discussed with the County's bond
counsel).
(1d) Records of interest earnings on reserve funds
maintained for the securities.
(2) Arbitrage Rebate. The County Treasurer or his/her
designee ("Rebate Monitor") will monitor
compliance with the arbitrage rebate obligations of
the County for each issue ("issue") of securities
which are described in further detail in the tax
certificate if any, executed by the County for each
issue and included in the transcript for the issue. If
the County did not execute a tax certificate in
connection with an issue, the Rebate Monitor should
consult with the County's bond counsel regarding
arbitrage rebate requirements. The County will
provide educational opportunities (opportunities to
attend educational programs/ seminars on the topic)
for the County Treasurer in order to facilitate
his/her performance of these obligations.
(2a) If the Rebate Monitor determines that the total
principal amount of tax-exempt governmental
obligations (including all tax-exempt leases,
etc.) of the County issued by or on behalf of the
County and subordinate entities during the
calendar year, including the issue, will not be
greater than $5,000,000, the Rebate Monitor
will not be required to monitor arbitrage rebate
compliance for the issue, exce t to monitor
expenditures and the use of proceeds after
completion of the project (see Sect.
1503.11.2(c)(3) below). For purposes of this
paragraph, tax-exempt governmental
obligations issued to currently refund a prior
tax-exempt governmental obligation will only
be taken into account to the extent they exceed
the outstanding amount of the refunded bonds.
(2b) If the Rebate Monitor determines that the total
principal amount of tax-exempt governmental
obligations (including all tax-exempt leases,
etc.) of the County issued or incurred any
calendar year is greater than $5,000,000, the
Rebate Monitor will monitor rebate compliance
for each issue of tax-exempt governmental
obligations issued during that calendar year.
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(i) Rebate Exceptions. The Rebate Monitor
will review the tax certificate, if any, in the
transcript in order to determine whether
the County is expected to comply with a
spending exception that would permit the
County to avoid having to pay arbitrage
rebate. If the tax certificate identifies this
spending exception (referred to as the six-
month exception, the 18 month exception
or the 2 -year exception), then the Rebate
Monitor will monitor the records of
expenditures (see paragraph
1503.11.2(c)(1) above) to determine
whether the County met the spending
exception (and thereby avoid having to
pay any arbitrage rebate to the federal
government). If the County did not
execute a tax certificate in connection with
an issue, the Rebate Monitor should
consult with bond counsel regarding the
potential applicability of spending
exceptions.
(ii) Rebate Compliance. If the County does
not meet or does not expect to meet any of
the spending exceptions described in (i)
above, the County will:
Review the investment earnings
records retained as described in
paragraph 1503.11.2(c)(1) above. If
the investment earnings records
clearly and definitively demonstrate
that the rate of return on investments
of all proceeds of the issue were lower
than the yield on the issue (see the tax
certificate in the transcript), then the
County may opt not to follow the
steps described in the following
paragraph.
Retain the services of an arbitrage
rebate consultant in order to calculate
any potential arbitrage rebate
liability. The rebate consultant shall
be selected no later than the
completion of the project to be
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financed with the proceeds of the
issue. A rebate consultant may be
selected on an issue by issue basis or
for all securities issues of the County.
The Rebate Monitor will obtain the
names of at least three qualified
consultants and request that the
consultants submit proposals for
consideration prior to being selected
as the County's rebate consultant.
The selected rebate consultant shall
provide a written report to the County
with respect to the issue and with
respect to any arbitrage rebate owed,
if any.
Based on the report of the rebate
consultant, file reports with and make
any required payments to the Internal
Revenue Service, no later than the
fifth anniversary of the date of each
issue (plus 6o days), and every five
years thereafter, with the final
installment due no later than 6o days
following the retirement of the last
obligation of the issue.
(2c) Yield Reduction Pats. If the County fails
to expend all amounts required to be spent as
of the close of any temporary period specified
in the tax certificate (generally 3 years for
proceeds of a new money issue and 13 months
for amounts held in a debt service fund), the
County will follow the procedures described in
paragraph 1503.11.2(c)(2)(2a)(ii) above to
determine and pay any required yield reduction
payment.
(3) Unused Proceeds Following_ Completion of the
Pro-ect. Following completion of the project(s)
financed with the issue proceeds, the County
Treasurer will:
(3a) Review the expenditure records to determine
whether the proceeds have been allocated to
the project(s) intended (and if any questions
arise, consult with bond counsel in order to
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determine the method of re -allocation of
proceeds); and
(3b) Direct the use of remaining unspent proceeds
(in accordance with the limitations set forth in
the authorizing proceedings, i.e., bond
ordinance, and if no provision is otherwise
made for the use of unspent proceeds, to the
redemption or defeasance of outstanding
securities of the issue.
(4) Use of the Facilities Financed with Proceeds. In
order to maintain tax -exemption of securities issued
on a tax-exempt basis, the financed facilities
(projects) are required to be used for governmental
purposes during the life of the issue. The County
Treasurer or his/her designee will monitor and
maintain records regarding any private use of the
projects financed with tax-exempt proceeds. The
IRS Treasury Regulations prohibit private business
use (use by private parties, including nonprofit
organizations and the federal government) of tax-
exempt financed facilities beyond permitted de
minimus amounts unless cured by a prescribed
remedial action. Private use may arise as a result of:
(4a) Sale of the facilities;
(4b) Lease of the facilities (including leases,
easements or use arrangements for areas
outside the four walls; e.g., hosting of cell
phone towers);
(40 Management contracts (in which the County
authorizes a third parry to operate a facility;
e.g., cafeteria; and/or
(4d) Preference arrangements (in which the County
grants a third party preference of the facilities;
e.g., preference parking in a public parking
lot).
If the County Treasurer or his/her designee identifies
private use of tax-exempt debt financed facilities, the
County Treasurer will consult with the County's bond
counsel to determine whether private use will
adversely affect the tax-exempt status of the issue and,
if so, what remedial action is appropriate.
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(5) Records Retention
(5a) Records with respect to matters described in
paragraph (e)(2) below will be retained by the
County for the life of the securities issue (and
any issue that refunds the securities issue) and
for a period of three years thereafter.
(5b) Records to be retained:
(i) The transcript;
(ii) Arbitrage rebate reports prepared by
outside consultants;
(iii) Work papers that were provided to the
rebate consultants;
(iv) Records of expenditures and investment
receipts (showing timing of expenditure
and the object code of the expenditure and,
in the case of investment, timing of receipt
of interest earnings). Maintenance of
underlying invoices should not be required
provided the records include the date of
the expenditure, payee name, payment
amount and object code; however, if those
documents are maintained as a matter of
policy in electronic form, then the County
should continue to maintain those records
in accordance with this policy;
(v) Copies of all certificates and returns filed
with the IRS (e.g., for payment of arbitrage
rebate); and
(vi) Copies of all leases and/or user agreements
for use of the financed property
(agreements that provide for use of the
property for periods longer than 3o days),
whether or not the use was within the four
walls (e.g., use of the roof of the facility for
a cell phone tower).
(d) Ongoing Disclosure. Under the provisions of SEC
Rule 15c2-12 (the "Rule"), underwriters are required to
obtain an agreement for ongoing disclosure in connection
with the public offering of securities. Unless the County
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is exempt from compliance with the Rule as a result of
certain permitted exemptions, the transcript for each
issue will include an undertaking by the County to
comply with the Rule. The County Treasurer or his/her
designee will monitor compliance by the County with its
undertakings. These undertakings may include the
requirement for an annual filing of operating and
financial information and will include a requirement to
file notices of listed "material events." (For some types of
material events (early bond calls), the State's fiscal agent
has undertaken the responsibility of filing notice of the
applicable material event).
(1) On an annual basis, the County Finance Committee
(comprised of the County Treasurer, County Auditor,
and the Chair of the Board of County
Commissioners) and Chief Accountant will begin
compiling information for the continuing disclosure
requirement at the regular County Finance
Committee meeting in May, and continue compiling
and updating that information, and reporting on the
status of the information at the June and July
meetings, with all the information completed by the
August meeting. The information will be uploaded
by the Chief Accountant on the EMMA website by or
before September 1st of each year.
(e) Other Notice Requirements. In some instances, the
proceedings authorizing the issuance of securities will
require the County to file information periodically with
other parties; e.g., bond insurers, banks, rating agencies.
The types of information required to be filed may include:
(1) budgets; (2) annual financial reports; (3) issuance of
additional debt obligations; and (4) amendments to
financing documents. The County Treasurer or his/her
designee will maintain a listing of those requirements and
monitor compliance by the County.
1503.12 Investment and Cash Management Policies: Manage and invest the
County's operating cash to ensure its legality, safety, provide for
necessary liquidity, avoid imprudent risk, and optimize yield.
1503.12.1 The County will develop and adopt an investment policy.
The County Investment Policy is reviewed and approved the
beginning of each year by the Board of County
Commissioners. In 1995, the County Treasurer created a
County Investment Pool to the benefit of the County and all
taxing districts the Treasurer is the ex -officio treasurer for.
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The County Investment Pool was also made available to
cities and other governmental entities in Grant County. As
part of a diversified portfolio, the County puts monies in the
Washington State Investment Pool (LGIP). The remaining
portion of investment portfolio consists of Federal Agency
securities but can be expanded to other investment vehicles
allowed by state, if needed. The County Treasurer is the
investment manager where the pool is handled on only a
passive mode, with no intent of active selling and replacing
securities prior to their call or maturity.
1503.12.2 The County will develop and adopt an investment policy.
Currently the Local Government Investment Pool (LGIP),
which is an investment vehicle maintained by the State
Treasurer's Office to help local governmental entities
achieve higher rates of return by pooling local funds for
economies of scale, is the only authorized investment
vehicle available to the County.
1503.12.3 The County will maintain written guidelines on cash
handling, accounting, segregation of duties, and other
financial matters.
1503.12.4 Monthly reports will be prepared and distributed to all
departments and the Board of County Commissioners
showing cash position, and year-to-date budgeted and
actual expenditures.
1503.12.5 Any County department that receipts cash will be
responsible to conduct annual reviews of its internal
controls and cash handling procedures.
1503.13 Reserve Fund Policies: Adequate financial reserves are an essential
element of Grant County's financial management strategy. They
insulate the County from unanticipated economic shortfalls and
demonstrate responsible budget practices to outside interests assessing
the County's credit -worthiness.
1503.13.1 At each fiscal year end the remaining dollars left in each
fund that are undesignated and unencumbered constitute
available reserves of the County.
1503.13.2 The County will include all fund balances in the annual
budget.
1503.13.3 Reserve Fund Determination
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(a) The Board of County Commissioners (BOCC) shall
determine the level of reserve funds necessary to affect
fiscally sound management practices, comply with legal
and contractual covenants, ensure service levels to
citizens, maintain reliable cash -flows, and protect
against economic downturns and fiscal emergencies.
(b) Prudent management of reserve funds enables the
County to address hidden or unanticipated costs, take
advantage of matching grant fund opportunities, and
exercise flexible financial planning for future needs.
(c) Just as maintaining adequate financial reserves indicates
sound fiscal stewardship, so does avoiding excess reserve
funds. An excess of accumulated reserve funds over
several years indicates excess taxation of County
residents.
(d) Therefore, it shall be the policy of the Grant County
BOCC to ensure adequate funding for legitimate needs
while rejecting unnecessary spending in the interest of
delivering effective, affordable County governance.
(e) Unless otherwise approved by action of the BOCC, an
aggregate total of no less than twenty percent (20%) of
the current year's operating budget shall be held in fund
balance within Current Expense accounts at all times.
1503.13.4 Fund Balance Distributions
(a) County fund balances shall be distributed as may be
directed by law, and in accordance with County fiscal
needs, into the following four (4) categories:
(1) Restricted Fund Balance consists of funds mandated
for a specific purpose by external parties,
constitutional provisions or enabling legislation.
These limitations are imposed by creditors (e.g.,
bond proceeds used for construction), grantors (e.g.,
state and federal assistance), or laws and regulations
of other governments (e.g., Distressed County Sales
Tax used only for economic development). The
County's restricted funds are held in Special
Revenue, Debt Service, and Capital Projects Funds.
(2) Committed Fund Balance consists of funds set aside
for a specific purpose by the County's highest level
of decision-making authority (BOCC). Formal
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action must be taken prior to the end of the fiscal
year to set limitations on the use of these funds. The
same formal action must be taken to remove or
change the limitations placed on the funds.
(3) Assigned Fund Balance consists of funds set aside
for a specific purpose by the BOCC. Assigned funds
cannot cause a deficit in an unassigned fund
balance. The Current Expense reserved fund
balance falls into this category.
(4) Unrestricted Fund Balance in the Current Expense
fund represents the total fund balance in excess of
any assigned fund balance (reserves).
1503.13.5 Surplus or Replenishment of Reserves
(a) Reserve Surplus. In the event the annual total reserve
level as determined by the BOCC is exceeded, these
additional funds will be deemed as surplus reserves and
may be designated for any County General Fund one-
time expense use as deemed appropriate by the BOCC.
(b) Replenishment. Replenishment of the County's reserves
following planned or unanticipated expenditures shall be
a primary fiscal priority for the County. The BOCC shall
direct appropriate budgetary actions to keep the total
level of reserve funds at prudent levels consistent with
this policy. If the level of total reserves is at any time
projected to drop below adopted reserve fund levels, the
BOCC will institute budgetary actions necessary to bring
those total reserves up to established levels as soon as
practical and no later than two subsequent annual
budget cycles.
1503.14 Enterprise Funds
1503.14.1 The County's Enterprise Funds will maintain reserves equal
to at least 10 percent of their adopted operating
expenditures.
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1503.15 Equipment Rental & Replacement Fund
1503.15.1 Sufficient reserves will be maintained to provide for the
scheduled replacement of County vehicles and capital
equipment at the end of their useful lives.
1503.15.2 Contributions will be made through assessments to the
operating departments and maintained on a per asset basis.
1503.16 Additional Reserves
1503.16.1 Additional reserve accounts may be created by the Board of
County Commissioners to be set aside for specific purposes
or special projects, for known significant future
expenditures, or as general operational reserves.
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