Jim Matteo, University of Virginia

TAX EXEMPT BOND COMPLIANCE

• Part 1 – Policy DevelopmentA. Compliance Environment

Assessment

B. Compliance Team Formation

C. Policy Development

Agenda

• Part 2 – Development of TEDC Dashboard

A. Defining Scope and Objectives

B. Compliance Dashboard Development

C. Activation and Future Enhancements

Agenda

• Identification of Need–2007 Audit of Series 2003 Bonds–IRS TE Bond Compliance Check Questionnaire Issued –Need for formal policy–Discussion with advisors and counsel on need–Better way to manage, report, and research TEBC data

1.A. Compliance Environment

• FY 2011 IRS Tax-Exempt Bonds Work Plan • IRS Committed to the following operating

priorities:

“Expand TEB’s compliance presence in the tax-exempt bond and tax credit bond market through increased use of compliance check initiatives and correspondence examinations”

(http://www.irs.gov/pub/irs-tege/fy_2011_teb_workplan.pdf)

• IRS Direct Pay Bond Compliance Questionnaire

1.A. Compliance Environment

1.B. Compliance Team Formation

• Team Formation–Internal members• Treasury, Accounting, Tax

–External members• FA, Bond Counsel, Arb. Calc. Agent

–Other Departments–Facilities Management

1.C. Policy Development

• Data Gathering–Conversations with FA and counsel–Review presentations, best practices and policies of other Universities–IRS Forms 13907 and 14002–Publications of National Assoc. of Bond Lawyers (NABL) and Government Financial Officers Assoc. (GFOA)

1.C. Policy Development

• Setting Objectives and Scope–Objectives• Formal policy to define compliance

practices• Create information dashboard to

consolidate TEBC data and support policy–Scope• University issued debt and certain State-

issued debt benefiting the University

1.C. Policy Development

• Policy Sections–Debt Issuance Process–Proceeds Tracking–Maintaining Records–Private Business Use–Disclosures and Filings–Data Management–Continuity–Responsibilities

2.A. Dashboard Scope and Objectives

• Dashboard Specifications–Single interface for TEDC reporting–Consolidate data from multiple sources–Relational database for compliance items–Scalable for future uses–Keep focus on project objectives

2.B. Compliance Dashboard Development

2.C. Activation and Future Enhancements

• Current Status–Phase 1 live in Q1 2010–Data cleanup and validation underway

Future Enhancements

2.C. Activation and Future Enhancements

• Calendar to anticipate and track compliance events

• Tracking actual to budget expenditures• Tracking amortization schedules• Including internal loan program info• Imaging debt documents