This Policy is intended to help ensure that the Issuer complies with Rule 15c2-12 ("Rule 15c2-12") promulgated by the U.S. Securities and Exchange Commission under the Securities Exchange Act of 1934. Rule 15c2-12 requires an underwriter in an offering of municipal securities to determine that the issuer of bonds or notes has undertaken, pursuant to a written Continuing Disclosure Agreement, to provide financial information – including the issuer’s financial statements, certain financial and operating data, and notice of the occurrence of certain events – on a continuing basis while the bonds or notes are outstanding. Rule 15c2-121 further requires that Official Statements used to offer bonds or notes to investors must describe any instances in the previous five years (from the date of the Official Statement) in which the issuer failed to comply, in all material respects, with it prior Continuing Disclosure Agreements.

The Issuer recognizes that compliance with Rule 15c-2-12 is required during the entire term the related bonds or notes are outstanding, and takes on additional importance when an Official Statement of Issuer is prepared in connection with a new offering of bonds or notes subject to Rule 15c2-12. Accordingly, the administration and implementation of the Policy and the accompanying Procedures will require ongoing monitoring and ongoing consultation with the Issuer’s dissemination agent, counsel, and other agents, as applicable.

Adopted 12/17/14