Form 14429 - Tax Exempt Bonds Voluntary Closing Agreement Program Request Page 4
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39. Has the issuer included a statement as to whether the bonds are under review in any court (other than a federal court),
administrative agency, commission, or other proceeding (and identified the proceeding)
Yes
Page number
N/A
40. Has the issuer included a statement as to whether the issuer knew or reasonably expected on the issue date that the violation might
occur
Yes
N/A
Page number
41. Has the issuer included a description of the policies or procedures which have been or will be implemented to prevent this type of
violation from recurring with this or any other bond issues
Yes
N/A
Page number
42. Has the issuer included a statement that the request for a closing agreement was promptly undertaken upon the discovery of the
identified violation, including the date(s) of the violation, the date and circumstances surrounding the discovery of the violation, and
the date and nature of any actions taken in response to the discovery of violation (e.g., redemption, defeasance)
Yes
Page number
N/A
Identification of Previous TEB VCAP or Private Letter Ruling Requests
See IRM 7.2.3.2.1(2)(F)&(G) for more information
43. Has the issuer identified any previous and contemporaneous TEB VCAP requests (including anonymous requests) submitted either:
(1) with respect to the bond issue that is the subject of the request; or (2) pertaining to a violation that is of the same type as the
subject of the request provided that such request was submitted within the past five years, including the name(s) of the related bond
issue(s), brief summaries of the violation(s) identified and resolution thereof; or, if no previous or contemporary request has been
submitted, has the issuer included a statement to that effect
Yes
Page number
N/A
44. Has the issuer identified all previous or contemporaneous private letter ruling requests submitted by the issuer with respect to the
bonds and relating to the violation which is the subject of the TEB VCAP request, including a brief summary of the matters
addressed therein; or, if no previous or contemporaneous private letter ruling request has been submitted, has the issuer included a
statement to that effect
Yes
N/A
Page number
Conflicts, Disclosure, 3rd Party Fault, Other
See IRM 7.2.3.2.1(2)(H) through (K) for more information
45. Has the issuer described any explanation the representative(s) or other professionals have made to the issuer regarding conflicts of
interests relating to the bonds that might exist under Circular 230
Yes
Page number
N/A
46. Has the issuer identified a violation that has been disclosed on the Municipal Securities Rulemaking Board’s Electronic Municipal
Market Access System (EMMA) or to any state or local taxing jurisdiction that grants tax-advantaged treatment to the issuer’s
bonds, including a statement describing the disclosure and how it was made; or, if no disclosure has been made, a statement to that
effect
Yes
Page number
N/A
47. If the issuer wishes to assert that the violation was caused by another party and requests TEB to consider this as a factor in
determining an appropriate resolution, has the issuer included a statement that the violation was due to the acts or omissions of a
person or persons other than the issuer, together with a description of the circumstances surrounding the violation thereof, and any
information that the issuer has regarding such acts or omissions (including an identification of the person or persons whose acts or
omissions caused the violation)
Yes
Page number
N/A
48. Has the issuer attached an explanation of any other information relevant to the matters contained in or resolution of the TEB VCAP
request
Yes
N/A
Page number
Written Post-Issuance Compliance Monitoring Procedures
49. Has the issuer included an affirmative or negative statement as to whether the issuer has adopted comprehensive written
procedures intended to promote post-issuance compliance with, and to prevent violations of, the federal tax requirements for tax-
advantaged bonds? IRM 7.2.3.2.1(3)
Yes
N/A
Page number
14429
Catalog Number 60719A
Form
(3-2013)
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