Code No. 702.1

RECEIPT OF INCOME

The Board Secretary, Director of Business Services or Superintendent Designee shall receive funds of the District.  Other persons receiving revenues on behalf of the District shall immediately turn the revenues over to the Board Secretary or Director of Business Services. 

All income received by the District shall be classified under the official accounting system.  The Board Secretary or the Director of Business Services shall timely deposit all District funds into the official school district depository or depositories set by the Board in accordance with the laws of the State of Iowa.

Date of Review:  April 9, 2018

886087

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code 702.10

Online Fundraising Campaigns - Crowdfunding

The Decorah Community School District Board of Education believes online fundraising campaigns, including crowdfunding campaigns, may further the interests of the District.  Any person or entity acting on behalf of the District and wishing to conduct an online fundraising campaign for the benefit of the district shall begin the process by seeking prior approval from the Superintendent.  Money or items raised by an online fundraising campaign will be the property of the District only upon acceptance by the Board, and will be used only in accordance with the terms for which they were given, as agreed to by the Board.

Approval of requests shall depend on factors including, but not limited to:

• Compatibility with the District’s educational program, mission, vision, core values, and beliefs:
• Congruence with the District and school goals that positively impact student performance;
• The District’s instructional priorities;
• The manner in which donations are collected and distributed by the crowdfunding platform;
• Equity in funding; and
• Other factors deemed relevant or appropriate by the District.

If approved, the requestor shall be responsible for preparing all materials and information related to the online fundraising campaign and keeping district administration apprised of the status of the campaign.

The requestor is responsible for compliance with all state and federal laws and other relevant District policies and procedures.  All items and money generated are subject to the same controls and regulations as other District property and shall be deposited or inventoried accordingly.  No money raised or items purchased shall be distributed to individual employees.

Date of Review:  April 9, 2018

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.2

DISTRICT SALE OF GOODS AND SERVICES

The Board of Directors claims exemption from the application of Iowa law prohibiting competition with private enterprise for the following activities:

1.         Goods and services that are directly and reasonably related to the educational mission of the District.

2.         Goods and services offered only to students, employees or guests of the District which cannot be provided by private enterprise at the same or lower cost.

3.         Use of vehicles owned by or contracted for by the District for trips offered to the public or to students.

4.         Goods or services which are not otherwise available in the quantity or quality required by the District.

5.         Telecommunications (including radio and television stations if in the District).

6.         Providing facilities for cultural events, fitness and recreation.

7.         Food sales and services.

8.         Sale of books, records, tapes, software, educational equipment and supplies.

9.         Items displaying the emblem, mascot or logo of the District or that otherwise promote the identity of the District and its program if sold in the District.

10.       Souvenirs and programs relating to events sponsored by or at the District.

1. Goods, products, or professional services which are produced, created or sold incidental to the District's teaching, research and extension missions.

Date of Review:  April 9, 2018

543365

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.3

EDUCATIONAL MATERIAL FEES

The Board may charge students fees for the use, purchase, damage or destruction of certain educational materials or supplies as authorized by law. Fees received by the District for educational materials shall be deposited in the general fund.  It shall be the responsibility of the Superintendent to recommend to the Board of Directors each year a schedule of fees for designated educational materials or supplies to students.

Date of Review:  April 9, 2018

886088

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.4

STUDENT ACTIVITY FUNDS

Funds from student activities and from fundraising for activities raised by students shall be classified as District funds and shall be properly held and accounted for by the Director of Business Services.  An audit of these accounts shall be made at the same time as the annual audit.

Expenditures from student activity funds shall be approved by the Director of Business Services.  Sponsors of student activities shall also maintain a record of student activities and expenditures.

Funds remaining in the senior class activity account after graduation or other unencumbered funds from activities that are discontinued shall be transferred to such accounts as designated by the Superintendent.

Gate and concession receipts from student activities shall be deposited whenever possible on the same day of the event.  When this is not possible, receipts shall be kept in a locked vault and deposited in a timely manner.  The Superintendent shall be responsible for designating the individual(s) who shall be in charge of collecting, counting and depositing receipts.

Date of Review:  April 9, 2018

01435181

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.5

SCHOOL BONDS AND INDEBTEDNESS

The Board of Directors may, upon receipt of a legal petition, or upon its own motion if legally authorized, conduct an election for authorization to issue school bonds.  The election, the sale and the issuance of the bonds, the payment of the bonds, and the use of the proceeds of the bonds shall be in accordance with the laws of the State of Iowa and shall comply with federal tax laws in order to qualify them as tax-exempt bonds.  Revenues generated from an approved bond issue shall be used only for the purpose(s) stated on the ballot and shall be deposited into the capital projects fund.  However, once the purpose(s) is fulfilled, any balance remaining in a capital projects fund may be retained for future capital projects in accordance with the purpose stated on the ballot or any remaining balance may be transferred by a Board resolution to the debt service fund or to the physical plant and equipment levy fund.  Voter approval is required to transfer monies to the general fund from the capital projects fund.  Records of identity of owners of public bonds are confidential records and are not open to public inspection.

The Board of Directors may authorize the incurrence of indebtedness on behalf of the District when the Board determines that the acquisition of equipment and of other services are necessary for the District, and it is determined by the Board to be in the District’s best interests to acquire the equipment or services immediately.  The total indebtedness shall not exceed Constitutional or statutory limitations and shall be issued in accordance with the laws of the State of Iowa.

Date of Review:  April 9, 2018

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.6

INVESTMENTS

District funds in excess of current needs shall be invested in compliance with this policy and in compliance with the law.  The goals of the District’s investment portfolio in order of priority are:

                        1.         To provide safety of the principal.

                        2.         To maintain the necessary liquidity to match expected liabilities.

                        3.         To obtain a reasonable rate of return.

The responsibility for conducting investment transactions resides with the Director of Business Services/Treasurer.  Only the Director of Business Services/Treasurer and those authorized by resolution may invest public funds.  When making investments or depositing public funds, the Director of Business Services/Treasurer shall exercise the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use to meet the goals of the investment program.

District funds are monies of the District, including operating funds.  “Operating funds” of the District are funds which are reasonably expected to be used during a current budget year or within fifteen months of receipt.  When investing operating funds, the investments must mature within three hundred and ninety-seven days or less.  When investing funds other than operating funds, the investments must mature according to the needs for the funds.

The Board authorizes the Director of Business Services/Treasurer to invest funds in excess of current needs in the following investments:

• Interest bearing savings, money market, and checking accounts at the District’s authorized depositories.
• Iowa Schools Joint Investment Trust Program (ISJIT).
• Obligations of the United States government, its agencies and instrumentalities.
• Certificates of deposit and other evidences of deposit at federally insured Iowa depository institutions.
• Repurchase agreements in which underlying collateral consists of investments in government securities.  The District must take delivery of the collateral either directly or through an authorized custodian.  Reverse repurchase agreements are not authorized investments. 
• Prime bankers' acceptances that mature within two hundred seventy days and that are eligible for purchase by a federal reserve bank.  At the time of purchase no more than ten percent of the investment portfolio can be in these investments and no more than five percent of the investment portfolio can be invested in the securities of a single issuer.​
• Commercial paper or other short-term corporate debt that matures within two hundred seventy days and that is rated within the two highest classifications, as established by at least one of the standard rating services, with no more than five percent at the time of purchase placed in the second highest classification.  At the time of purchase no more than ten percent of the investment portfolio can be in these investments and no more than five percent of the investment portfolio can be invested in the securities of a single issuer.
• An open-end management investment company registered with the federal securities exchange commission and commonly referred to as a money market mutual fund.  The money market mutual fund shall use only the investments individually authorized by law for school districts.

It shall be the responsibility of the Director of Business Services/Treasurer to oversee the investment portfolio in compliance with this policy and the law.  The Director of Business Services/Treasurer and all officers and employees of the District shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions.

The records of investment transactions made by or on behalf of the District are public records and are the property of the District whether in the custody of the District or in the custody of a fiduciary or other third party.

It shall be the responsibility of the Director of Business Services/Treasurer to bring to the Board of Directors for review and approval any contract with any outside person to invest District funds, to advise on investments, to direct investments, to act in a fiduciary capacity or to perform other services.  The Director of Business Services/Treasurer shall also provide the Board with information about and verification of the outside person’s fiduciary bond.  Contracts with outside persons shall include a clause requiring the outside person to notify the District within thirty days of any material weakness in internal structure or regulatory orders or sanctions against the outside person regarding the services being provided to the District and to provide the documents necessary for the performance of the investment portion of the District audit.  The compensation of the outside persons shall not be based on the performance of the investment portfolio.

The Director of Business Services/Treasurer shall be responsible for reporting to and reviewing with the Board at its regular meetings the investment portfolio’s performance, transaction activity and current investments including the percent of the investment portfolio by type of investment and by issuer and maturities.  The report shall also include trend lines by month over the last year and year-to-year trend lines regarding the performance of the investment portfolio.  It shall also be the responsibility of the Director of Business Services/Treasurer to obtain the information necessary to ensure that the investments and the outside persons doing business with the District meet the requirements outlined in this policy.

It shall be the responsibility of the Superintendent to deliver a copy of this policy to the District’s depositories, auditor and outside parties assisting with or facilitating investments of the funds of the District.

It shall also be the responsibility of the Superintendent, in conjunction with the Director of Business Services/Treasurer, to develop a system of investment practices and internal controls over the investment practices.  The investment practices shall be designed to prevent losses, to document the officers’ and employees’ responsibility for elements of the investment process and address the capability of the management.

Date of Review:  April 9, 2018

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS 

Code No. 702.7

GIFTS, GRANTS, AND BEQUESTS

Gifts, grants, and bequests to the District shall be either accepted or rejected by the Board of Directors.  All gifts, grants, and bequests shall be deposited into a trust fund, agency fund or permanent fund, shall be used or administered in accordance with the terms of the gift or bequest, and shall become the property of the District under the control of the Board of Directors.  The District shall not accept gifts, grants, or bequests that improperly discriminate on the basis of race, color, sex, sexual orientation, gender identity, national origin, ethnic background, religion, creed, political belief, physical attribute, generic information, socio-economic status or any other protected class under state or federal law.

The District shall judge and accept or reject all media gift materials based on the same criteria applied to materials selected and purchased by the District.  The District, because of function and space of the media centers, cannot promise in all cases to maintain a collection or group of educational materials as a single entity segregated from the circulating and reference collections.  The District reserves the right to make the decision as to the most appropriate use and housing of a gift collection.  Educational materials may be identified by appropriate name plates indicating donor information.

Date of Review:  April 9, 2018

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.8

DEPOSITORIES OF FUNDS

At the annual meeting of the Board of Directors, the Board of Directors shall designate by resolution, which shall be entered in the official minutes of the Board, the names and locations of the banks, savings and loan associations, savings banks, or credit unions selected as the official District depository or depositories.  The Board shall also designate the maximum amount that may be kept on deposit in each institution.

Date of Review:  April 9, 2018

DECORAH COMMUNITY SCHOOL BOARD OF DIRECTORS

Code No. 702.9

POST-ISSUANCE COMPLIANCE POLICY FOR

TAX-EXEMPT OBLIGATIONS

1.         Compliance Coordinator:

a)         The Treasurer ("Coordinator") shall be responsible for monitoring post-issuance compliance.

b)         The Coordinator will maintain a copy of the transcript of proceedings in connection with the issuance of any tax-exempt obligations.  Coordinator will obtain such records as are necessary to meet the requirements of this policy.

c)         The Coordinator shall consult with bond counsel, IRS publications and such other resources as are necessary to understand and meet the requirements of this policy.

d)         Training and education of Coordinator will be sought and implemented upon the occurrence of new developments and upon the hiring of new personnel to implement this policy.

2.         Financing Transcripts.  The Coordinator shall confirm the proper filing of an 8038 Series return, and maintain a transcript of proceedings for all tax-exempt obligations issued by the School District, including but not limited to all tax-exempt bonds, notes and lease-purchase contracts.  Each transcript shall be maintained until eleven (11) years after the tax-exempt obligation it documents has been retired.

3.         Proper Use of Proceeds.  The Coordinator shall review the resolution authorizing issuance for each tax-exempt obligation issued by the School District, and shall:

a)         obtain a computation of the yield on such issue from the School District’s financial advisor; 

b)         create a separate Project Fund (with as many sub-funds as shall be necessary to allocate proceeds among the projects being funded by the issue) into which the proceeds of issue shall be deposited;

c)         review all requisitions, draw schedules, draw requests, invoices and bills requesting payment from the Project Fund;

d)         determine whether payment from the Project Fund is appropriate, and if so, make payment from the Project Fund (and appropriate sub-fund if applicable);

e)         maintain records of the payment requests and corresponding cancelled checks showing payment;

f)          maintain records showing the earnings on, and investment of, the Project Fund;

g)         ensure that investments acquired with proceeds are purchased at fair market value;

h)         identify bond proceeds or applicable debt service allocations that must be invested with a yield-restriction and monitor the investments of any yield-restricted funds to ensure that the yield on such investments does not exceed the yield to which such investments are restricted.

            4.  Timely Expenditure and Arbitrage/Rebate Compliance.  The Coordinator shall review the Tax-Exemption Certificate (or equivalent) for each tax-exempt obligation issued by the School District and the expenditure records provided in Section 2 of this policy, above, and shall:

a)         monitor and ensure that proceeds of each such issue are spent within the temporary period set forth in such certificate;

b)         if the School District does not meet the "small issuer" exception for said obligation, monitor and ensure that the proceeds are spent in accordance with one or more of the applicable exceptions to rebate as set forth in such certificate;

c)         not less than sixty (60) days prior to a required expenditure date confer with bond counsel if the School District will fail to meet the applicable temporary period or rebate exception expenditure requirements of the Tax-Exemption Certificate; and

d)         in the event the School District fails to meet a temporary period or rebate exception:

i.          procure a timely computation of any rebate liability and, if rebate is due, file a Form 8038-T and arrange for payment of such rebate liability;

ii.         arrange for timely computation and payment of "yield reduction payments" (as such term is defined in the Code and Treasury Regulations), if applicable.

5.         Proper Use of Bond Financed Assets.  The Coordinator shall: 

a)         maintain appropriate records and a list of all bond financed assets.  Such records shall include the actual amount of proceeds (including investment earnings) spent on each of the bond financed assets;

b)         with respect to each bond financed asset, the Coordinator will monitor and confer with bond counsel with respect to all proposed:

             i.         management contracts,

             ii.        service agreements,

            iii.        research contracts,

            iv.        naming rights contracts,

             v.        leases or sub-leases,

            vi.        joint venture, limited liability or partnership arrangements,

            vii.       sale of property; or

            viii.      any other change in use of such asset;

c)         maintain a copy of the proposed agreement, contract, lease or arrangement, together with the response by bond counsel with respect to the proposal for at least three (3) years after retirement of all tax-exempt obligations issued to fund all or any portion of bond financed assets; and

d)         In the event the School District takes an action with respect to a bond financed asset, which causes the private business tests or private loan financing test to be met, the Coordinator shall contact bond counsel and ensure timely remedial action under IRS Regulation Sections 1.141-12.

6.         General Project Records.  For each project financed with tax-exempt obligations, the Coordinator shall maintain, until three (3) years after retirement of the tax-exempt obligations or obligations issued to refund those obligations, the following:

            a)         appraisals, demand surveys or feasibility studies,

            b)         applications, approvals and other documentation of grants,

            c)         depreciation schedules,

            d)         contracts respecting the project.

7.         Continuing Disclosure.  The Coordinator shall assure compliance with each continuing disclosure certificate and annually, per continuing disclosure agreements, file audited annual financial statements and other information required by each continuing disclosure agreement.  The Coordinator will monitor material events as described in each continuing disclosure agreement and assure compliance with material event disclosure.  Events to be reported shall be reported promptly, but in no event not later than ten (10) Business Days after the day of the occurrence of the event, and shall include, but not be limited to:

            a)         Principal and interest payment delinquencies;

            b)         Non-payment related defaults, if material;

            c)         Unscheduled draws on debt service reserves reflecting financial difficulties;

            d)         Unscheduled draws on credit enhancements relating to the bonds reflecting financial difficulties;

            e)         Substitution of credit or liquidity providers, or their failure to perform;

            f)          Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax-exempt status of the bonds, or material events affecting the tax-exempt status of the bonds;

            g)         Modifications to rights of Holders of the Bonds, if material;

            h)         Bond calls (excluding sinking fund mandatory redemptions), if material, and tender offers;

            i)          Defeasances of the bonds;

            j)          Release, substitution, or sale of property securing repayment of the bonds, if material;

            k)         Rating changes on the bonds;

            l)          Bankruptcy, insolvency, receivership or similar event of the Issuer;

            m)        The consummation of a merger, consolidation, or acquisition involving the Issuer or the sale of all or substantially all of the assets of the Issuer, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material; and

            n)         Appointment of a successor or additional trustee or the change of name of a trustee, if material.

Date of Review:  March 8, 2021

01841884

EXHIBIT A

LISTED EVENTS

The following events automatically trigger a requirement to file on EMMA within ten (10) business days of their occurrence (listed events are subject to change by the SEC):

(1) Principal and interest payment delinquencies;

(2) Non-payment related defaults, if material;

(3) Unscheduled draws on debt service reserves reflecting financial difficulties;

(4) Unscheduled draws on credit enhancements reflecting financial difficulties;

(5) Substitution of credit or liquidity providers, or their failure to perform;

(6) Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax status of the security, or other material events affecting the tax status of the security;

(7) Modifications to rights of security holders, if material;

(8) Bond calls, if material, and tender offers;

(9) Defeasances;

(10) Release, substitution, or sale of property securing repayment of the securities, if material;

(11) Rating changes;

(12) Bankruptcy, insolvency, receivership or similar event of the obligated person[1];

Note to paragraph (b)(5)(i)(C)(12):

For the purposes of the event identified in paragraph (b)(5)(i)(C)(12) of this section, the event is considered to occur when any of the following occur: The appointment of a receiver, fiscal agent or similar officer for an obligated person in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the obligated person, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the obligated person.

(13) The consummation of a merger, consolidation, or acquisition involving an obligated person or the sale of all or substantially all of the assets of the obligated person, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material;

(14) Appointment of a successor or additional Director or the change of name of a Director, if material;

Additionally, the following events apply to Disclosure Agreements entered by the District on or after October 22, 2020:

(15) Incurrence of a Financial Obligation of the obligated person, if material[2], or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of the obligated person, any of which affect security holders, if material*; and

(16) Default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a Financial Obligation of the obligated person, any of which reflect financial difficulties.

Suggested Practices in Submitting Annual Financial Information to EMMA*

Annual Financial Information is to be submitted to EMMA as follows:

• through the EMMA Dataport;

• in one or more electronic word-searchable portable document format files configured to permit documents to be saved, viewed, printed and retransmitted by electronic means (“properly formatted pdf file”); and

• indexed by the submitter as “Annual Financial Information and Operating Data” – this EMMA indexing category should be used for all submissions consisting of one or both parts of an annual financial information submission. A submission should be indexed in EMMA by the submitter as “Annual Financial Information and Operating Data” if it consists of complete annual financial information (including audited financial statements and/or the CAFR).

If the audited financial statements have not been prepared in time to meet the deadline:

• file unaudited financial statements with a notice to the effect that the unaudited financial statements are being provided pending completion of audited financial statements and that the audited financial statements will be submitted to EMMA when they have been prepared.

If annual financial information is provided by reference to other submitted documents file:

• a notice that includes specific reference to a document available on the EMMA website or the SEC (such as, but not limited to, an official statement), to the extent that such document in fact includes the information required to be include in the annual financial information; and

• the submitter should confirm that such document in fact is available from the EMMA website or the SEC and should include in such notice (A) a textual description of the document that includes the required information, with sufficient detail for a reasonable person to determine the precise document being referenced, and (B) an active hyperlink to the pdf file of such document as then posted on the EMMA website or to the SEC’s EDGAR system; further, if such document includes audited financial statements, the submitter should also index such submission as “Audited Financial Statements or CAFR” in addition to (but not instead of) “Annual Financial Information and Operating Data” unless the submitter submits such audited financial statements separately to EMMA.

Failure to file notices are to be submitted to EMMA as follows:

• through the EMMA Dataport;

• as an electronic word-searchable and properly formatted pdf file; and

• indexed by the submitter as “Failure to Provide Annual Financial Information.”

* Procedures subject to change.

01841892