Amended and Restated Policies and Procedures Regarding Municipal Securities DisclosureCity of Dubuque
City Council
CONSENT ITEMS # 6.
Copyrighted
March 3, 2025
ITEM TITLE: Amended and Restated Policies and Procedures Regarding
Municipal Securities Disclosure
SUMMARY: City Manager recommends City Council approval of the
suggested proceedings to adopt the Amended and Restated
Policies and Procedures Regarding Municipal Securities
Disclosure.
RESOLUTION Authorizing Adoption of Amended and
Restated Policies and Procedures Regarding Municipal
Securities Disclosure
SUGGUESTED Receive and File; Adopt Resolution(s)
DISPOSITION:
ATTACHMENTS:
1. MVM Memo Disclosure Policies and Procedures_MVM Memo_2025_02_25
2. Disclosure Policies and Procedures Staff Memo 2025 02 25
3. Disclosure Policies and Procedures (AR) (Dubuque 2025)-v2
4. Proc Auth AR Disclosure Policies (Dubuque 2025)-v2
5. Dorsey_Securities_Law_Summary-v2
Page 89 of 629
THE C
DUUB-.'*-TE
Masterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
Dubuque
2007-2012.2013
2017*2019
SUBJECT: Amended and Restated Policies and Procedures Regarding Municipal
Securities Disclosure
DATE: February 25, 2025
Chief Financial Officer Jennifer Larson recommends City Council approval of the
suggested proceedings to adopt the Amended and Restated Policies and Procedures
Regarding Municipal Securities Disclosure.
In January 2015, the City Council adopted certain policies and procedures regarding
municipal securities disclosure to be followed in connection with the issuance and on-
going administration of publicly offered bonds. As a result of certain changes in Federal
law, the City deems it necessary to amend and restate the 2015 Ongoing Disclosure
Policy.
The amended and restated Disclosure Policy is designed to assist issuers with fulfilling
both primary and secondary disclosure responsibilities. It sets forth procedures that
govern the preparation of official statements for new bond offerings, compliance with
continuing disclosure requirements under a continuing disclosure certificate, and
systematic training of key staff members and elected officials.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Michael C. Van Milligen
MCVM/jml
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Jennifer Larson, Chief Financial Officer
Brian DeMoss, Finance Manager
Page 90 of 629
THE CITY OF
Dubuque
D UB E
All-AmerioaCily
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" IIF
Masterpiece on the Mississippi
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TO: Michael C. Van Milligen, City Manager
FROM: Jennifer Larson, Chief Financial Officer
SUBJECT: Amended and Restated Policies and Procedures Regarding Municipal
Securities Disclosure
DATE: February 26, 2025
INTRODUCTION
The purpose of this memorandum is to request approval of the amended and restated
policies and procedures regarding municipal securities disclosure.
BACKGROUND
In January 2015, the City Council adopted certain policies and procedures regarding
municipal securities disclosure to be followed in connection with the issuance and on -going
administration of publicly offered bonds. As a result of certain changes in Federal law, the
City deems it necessary to amend and restate the 2015 Ongoing Disclosure Policy.
DISCUSSION
Issuers of municipal securities are regulated by the Securities Act of 1933 and the Securities
Exchange Act of 1934 and various rules promulgated under those acts by the U.S. Securities
and Exchange Commission ("SEC"). Of particular importance are Rule 10b-5 (which prohibits
fraud) and Rule 15c2-12 (which generates an issuer's ongoing disclosure obligations). Taken
together, these rules impose primary disclosure duties (i.e. accuracy and forthrightness in the
preparation of an official statement for new bond issues) and secondary disclosure duties (i.e.
timely filing financial and other data under a continuing disclosure certificate ("CDC") for
outstanding bond issues).
Various provisions of federal securities law including SEC Rule 10b-5 prohibit fraud in the
issuance, purchase, or sale of municipal securities. These provisions generally prohibit
"material" misstatements or omissions to investors, potential investors, or the general public.
Violation of these provisions can result in civil or criminal liability.
When bonds are issued and publicly offered, an official statement will be prepared on behalf
of the Issuer. The official statement is the disclosure document that sets forth the terms
associated with the bond issue and is used to market and sell the Issuer's bonds. Issuers
(including elected officials and staff) are primarily responsible for the accuracy of an official
statement. Hiring a professional to assist with the preparation of an OS does not discharge
an Issuer's responsibility. The elected officials and relevant employees of an issuer have an
Page 91 of 629
affirmative obligation to ensure the accuracy of the contents of the financial and other
information in an OS— delivery of an OS without first reading it to gauge its accuracy may be
reckless and the basis for an SEC enforcement action.
SEC Rule 15c2-12 ensures that Issuers contractually agree to provide certain financial and
operating information to investors and the public on an ongoing basis. The type of information
that must be reported is generally (i) annual financial reports and (ii) material event notices.
Issuers must file updated financial information and operating data on an annual or other
regular basis, as specified in their CDC. Generally, the information that must be reported
includes audited financial statements, annual financial or operating data, of the type included
in the OS for the related bonds.
Issuers must notify investors (via a specific filing on the "EMMA" website, at
https://emma.msrb.org/) within 10 business days if certain events occur while a bond is
outstanding. Generally, those events are items that impact an Issuer's ability to pay, or timely
pay amounts owed on outstanding debt, rating changes, defaults, and the incurrence of
material financial obligations (debt obligations of the Issuer). At present, there are 16 events
that can trigger reporting obligations. The Issuer's Disclosure Policy will detail the events, and
the procedures intended to enable timely identification and disclosure.
The amended and restated Disclosure Policy is designed to assist issuers with fulfilling both
primary and secondary disclosure responsibilities. It sets forth procedures that govern the
preparation of official statements for new bond offerings, compliance with continuing
disclosure requirements under a CDC, and systematic training of key staff members and
elected officials.
The training of key staff members and elected officials will be done at a scheduled City
Council work session every two years by the Chief Financial Officer with assistance from
bond counsel.
RECOMMENDATION
I respectfully recommend the adoption of the enclosed resolution to adopt the Amended and
Restated Policies and Procedures Regarding Municipal Securities Disclosure.
JML
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Brian DeMoss, Finance Manager
2
Page 92 of 629
City of Dubuque / Disclosure Policies and Procedures
City of Dubuque, Iowa
POLICIES AND PROCEDURES RE: MUNICIPAL SECURITIES DISCLOSURE
As an issuer of municipal securities (bonds and/or notes, referred to herein as "Bonds"), the City of Dubuque,
Iowa (the "Issuer") has adopted the policies and procedures set forth herein (collectively, the "Disclosure Policy")
to guide the Issuer's actions with respect to complying with (1) the disclosure document (often referred to as the
"official statement") for publicly -offered bond transactions and (2) ongoing continuing disclosures associated
with outstanding contractual obligations resulting from bond issues (also known as "continuing disclosure"). This
Disclosure Policy is designed to provide the necessary policy framework and accompanying procedures for
compliance by the Issuer with its disclosure responsibilities. It should be noted, however, issuers of municipal
securities are primarily responsible for the content of their disclosure documents including on -going compliance
with respect to continuing disclosure.
This Disclosure Policy includes the following elements: (1) disclosure training for officials responsible for
producing, reviewing and approving disclosure; (2) establishment of procedures for review of relevant disclosure,
and (3) ensuring that any procedures established are followed.
Background
The anti -fraud provisions of federal securities laws apply to municipal securities such as the Issuer's Bonds. The
U.S. Securities and Exchange Commission (the "SEC") can bring enforcement actions against the Issuer,
members of its governing body, government employees and elected officials, and professionals working on the
bond transaction. Government employees and elected officials can be, and have been, held personally liable
with respect to securities laws violations related to the issuance of Bonds. Issuers and members of the governing
body can mitigate risks related to SEC enforcement by relying on professionals such as disclosure counsel.
Issuers may also seek affirmative assurances of compliance with the receipt of a legal opinion from disclosure
counsel.
When bonds are issued and publicly offered, an official statement will be prepared on behalf of the Issuer. The
official statement is the disclosure document that sets forth the terms associated with the bond issue. The official
statement will be used to market and sell the Issuer's bonds.' In addition, for transactions larger than $1 million
in size that include an official statement, the Issuer enters into a continuing disclosure certificate, agreement or
undertaking (the "CDC"). The CDC is a contractual obligation of the Issuer, pursuant to which the Issuer agrees
to provide certain financial information filings (at least annually) and material event notices to the public. The
CDC is necessary to allow the bond underwriters to comply with SEC Rule 15c2-12, as amended (the "Rule").
As noted below, filings under the CDC must be made electronically at the Electronic Municipal Market Access
(EMMA) portal (www.emma.msrb.org).
Accordingly, this Disclosure Policy addresses the following three aspects of disclosure: (1) preparation and
approval of official statements in connection with new ("primary") bond issues; (2) on -going continuing
disclosure requirements under a CDC; and (3) education of staff and elected officials with respect to disclosure
matters.
' Under federal law issuers of municipal securities are primarily responsible for the content of their disclosure documents (the
official statement), regardless of who prepared the document. An issuer does not discharge its disclosure obligations by
hiring professionals to prepare the official statement. An issuer has "an affirmative obligation" to know the contents of its
official statement, including the financial statements. Finally, executing an official statement without first reading the
document to ascertain whether it is accurate may be reckless (the basis for certain anti -fraud causes of action by the SEC).
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DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 93 of 629
City of Dubuque / Disclosure Policies and Procedures
1. CD Compliance Officer
The Chief Financial Officer and the City Attorney are appointed as the compliance officers for purposes of this
Disclosure Policy (each a "CD Compliance Officer").
2. Primary (New) Offerings of Bonds — Official Statements of the Issuer
In connection with the issuance of its publicly -offered Bonds (Bonds sold via the public market, through a broker -
dealer known as an "underwriter"), the Issuer will cause its hired professionals to prepare a disclosure document
commonly known as an "official statement." The official statement is the document that describes the issuance of
the Bonds to the marketplace and as such, under federal law, the official statement cannot contain any untrue
statement of a material fact or omit to state a material fact necessary to make the statements therein, in the
light of the circumstances under which they were made, not misleading.
To ensure the Issuer's official statements are properly prepared and reviewed, the Issuer adopts the procedures set
forth in Appendix I hereto.
3. Continuing Disclosure Compliance (CDC Compliance)
The Issuer has entered into, or may in the future enter into, CDCs in connection with its bond issues. Under these
contractual agreements, the Issuer has agreed to provide to the marketplace certain financial information and
notices of material events. The Issuer will file, or cause to be filed, necessary items under the CDCs in a
searchable electronic format at the Electronic Municipal Market Access (EMMA) portal (www.emma.msrb.org).
The determination of whether a material event has occurred will be made pursuant to the Rule and SEC Release
No. 34-83885, in conjunction with disclosure counsel and other members of the Issuer's external bond finance
working group.
To ensure compliance with its contractual continuing disclosure obligations, the Issuer adopts the procedures set
forth in Appendix II hereto.
4. Systematic Training of Staff and Governing Body Members
In addition to the specific procedures adopted under this Disclosure Policy, the Issuer understands that on -going
training of both staff and members of the governing body is essential to successful compliance with the Issuer's
disclosure obligations. The training noted below may be accomplished by various methods, including in -person,
webinars or other electronic means, or through review of written materials. Accordingly, the Issuer has
implemented the following training procedures, which may be implemented with the assistance of disclosure
counsel to the Issuer:
A. Annual Training. The CD Compliance Officer is responsible for scheduling annual training of Issuer
employees regarding disclosure and financial reporting requirements of the federal securities laws. Such training
shall include a complete review of this Disclosure Policy, Rule 15c2-12 and the material events required to be
reported pursuant to such Rule, and a complete overview of the Issuer's obligations under the federal securities
laws.
B. Specific Training. When appropriate, the CD Compliance Officer shall conduct (or cause to be conducted)
training with individuals on those persons' specific roles and responsibilities in the disclosure and financial
reporting process.
C. Governing Body Training. Not less than once every two years, the CD Compliance Officer shall schedule a
training session for the Issuer's governing body on this Disclosure Policy and the disclosure and financial
reporting requirements of the federal securities laws.
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DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 94 of 629
City of Dubuque / Disclosure Policies and Procedures
Appendix I
Written Procedures for Preparing Official Statements
1. At the commencement of a financing, the CD Compliance Officer shall develop or cause the Issuer's
Finance Team to develop a plan for preparation of the official statement and a schedule that allows sufficient time
for all required work, including appropriate review and participation by members of the Finance Team.
2. The CD Compliance Officer shall be responsible for managing the preparation process for the official
statement, and shall obtain the assistance of other participants within the Issuer and engage legal and financial
professionals, as necessary and appropriate.
3. The CD Compliance Officer shall be responsible for developing a program for coordinating staff
review of the disclosure information, as necessary, and obtaining formal sign -off from staff on the disclosure
documents.
4. The CD Compliance Officer shall ensure that any previous failure to fully comply with continuing
disclosure obligations during the prior five-year period is disclosed in the official statement by reviewing
compliance with all outstanding continuing disclosure agreements, reviewing continuing disclosure review
documentation prepared by independent parties and contacting disclosure counsel to discuss any questions or
concerns.
5. The Issuer's governing body shall be given not less than 7 days to review an official statement prior to
being asked to vote on its approval, absent extenuating circumstances. Elected representatives on the governing
body shall be directed to contact the CD Compliance Officer during the review period to discuss potential issues,
concerns or comments on the official statement.
I-1
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 95 of 629
City of Dubuque / Disclosure Policies and Procedures
Appendix II
Written Procedures Re: Continuing Disclosure
1. The CD Compliance Officer shall be responsible for compliance with the Issuer's obligations
under continuing disclosure agreements, undertakings or certificates (the "CDC"), including without limitation
annual filings, material event notice filings, voluntary filings and other filings required by the CDC.
2. Prior to execution of a CDC in connection with a bond issue, the CDC shall be discussed with
disclosure counsel, the underwriter and municipal advisor, if any, to ensure a full understanding of issuer
obligations.
3. The CD Compliance Officer shall have the primary responsibility to confer with the finance team
and Issuer staff bi-weekly to monitor compliance with respect to "material events" as defined in the Rule.
The CD Compliance Officer shall be responsible for (i) determining whether any of the following "material
events" has taken place (questions regarding their interpretation shall be directed to disclosure counsel), (ii)
gathering information material to making that determination from other departments, and (iii) if a material event
has occurred, discussing the same with disclosure counsel to determine the form of notice of material event and
causing the filing of notice to be made on EMMA within ten (10,) business days of the occurrence of the event:
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, including rating upgrades and downgrades;
12. Bankruptcy, insolvency, receivership or similar event 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 trustee or the change of name of a trustee, if
material;
15. Incurrence of a financial obligation of the obligated person, if material, 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
2 "Financial obligation" is to mean a (i) debt obligation; (ii) derivative instrument entered into in connection with, or
pledged as security or a source of payment for, an existing or planned debt obligation; or (iii) a guarantee of (i) or (ii).
II-1
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 96 of 629
City of Dubuque / Disclosure Policies and Procedures
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.
The determination of whether a material event has occurred will be made pursuant to the Rule and SEC Release
No. 34-83885, in conjunction with disclosure counsel.
4. The CD Compliance Officer shall have primary responsibility for ensuring that statements or
releases of information relating to the Issuer's finances to the public that are reasonably expected to reach
investors and the financial markets, including website updates, press releases and market notices, are accurate and
not misleading in any material respect. The CD Compliance Officer shall work together to ensure that all public
statements and information released by the Issuer are accurate and not misleading in all material respects.
5. The CD Compliance Officer shall be responsible for compiling and maintaining a list of all
outstanding bond issues subject to continuing disclosure, noting the applicable filing dates (see attached table
format, Part I, for an example to be used by staff in tracking this information (the "Disclosure Table")).
6. The CD Compliance Officer shall be responsible for assembling and maintaining copies of the
final CDC and final Official Statements for each applicable bond issue, together with any third -party
Dissemination Agent Agreements, if applicable.
7. The CD Compliance Officer shall document and track the required information to be filed,
including dates such information is filed (see attached Disclosure Table, Part II for a form of table to be used by
staff).
8. The CD Compliance Officer shall be responsible for registering for continuing disclosure filing
email reminders from the "EMMA" website, or for ensuring the Issuer's dissemination agent will remind the
Issuer of applicable deadlines (http://emma.msrb.org).
9. At least 60 days prior to the earliest filing deadline listed on the Disclosure Table, the CD
Compliance Officer shall begin the process of compiling necessary information required by the CDCs (and
coordinate with outside professionals hired to compile this information, if applicable).
10. At least 30 days prior to each filing deadline, the CD Compliance Officer shall determine whether
all necessary items have been compiled for filing pursuant to the CDC requirements, (including review with
disclosure counsel or the Issuer's dissemination agent).
11. Prior to each filing deadline, the CD Compliance Officer shall file (or cause any Dissemination
Agent to file) the necessary items on the EMMA website in a word -searchable PDF configured to be saved,
printed, and retransmitted by electronic means. After filing, the CD Compliance Officer shall confirm that all
items have, in fact, been filed on EMMA as required, and shall note the filing date on the Disclosure Table.
12. The CD Compliance Officer shall be responsible for coordinating and filing any voluntary
information with EMMA, after consultation with the Issuer's legal and financial professionals.
13. The CD Compliance Officer may contact the Issuer's disclosure counsel with any disclosure -
related questions or concerns.
II-2
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 97 of 629
City of Dubuque / Disclosure Policies and Procedures
Form of Disclosure Tables
Part I — Master Tracking Table (list of deadlines for all bond issues subject to continuing disclosure)
[Note this is only a form; Issuer staff will update and maintain the Tables separate from this Policy; the
current Table can be obtained from the CD Compliance Officer]
Name of Bond Issue
Date of Issue
Final Maturity
Dissemination
CUSIP for Final
Deadline for
Date
Agent
Maturity
Annual Report
$23,025,000 Urban
10/16/2007
06/01/2037
Independent
263844 BF8
only required to
Renewal Tax Increment
Public Advisors,
file for Material
Revenue Bonds
LLC
Events
(Taxable), Series 2007
$7,190,000 Sales Tax
06/16/2014
06/01/2029
Independent
264037 AG7
Not later than
Revenue Bonds
Public Advisors,
210 days after
(Unlimited Property
LLC
end of fiscal year
Tax Supported), Second
Lien Series 2014
$20,800,000 Sales Tax
06/15/2015
06/01/2031
Independent
264037 AR3
Not later than
Increment Revenue
Public Advisors,
210 days after
Bonds (Annual
LLC
end of fiscal year
Appropriation Property
Tax Supported), Senior
Bond Series 2015A
$2,830,000 General
04/04/2016
06/01/2035
Independent
263868 AU5
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2016A
LLC
end of fiscal year
$10,920,000 General
04/04/2016
06/01/2028
Independent
263868 BH3
Not later than
Obligation Refunding
Public Advisors,
210 days after
Bonds, Series 2016B
LLC
end of fiscal year
$4,145,000 General
04/04/2016
06/01/2035
Independent
263868 CC3
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2016C
LLC
end of fiscal year
$8,495,000 General
04/17/2017
06/01/2030
Independent
263868 CRO
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2017A
LLC
end of fiscal year
$9,745,000 General
04/17/2017
06/01/2030
Independent
263868 DE8
Not later than
Obligation Urban
Public Advisors,
210 days after
Renewal Refunding
LLC
end of fiscal year
Bonds, Series 2017B
$2,120,000 Taxable
04/17/2017
06/01/2030
Independent
263868 DT5
Not later than
General Obligation
Public Advisors,
210 days after
Urban Renewal
LLC
end of fiscal year
Refunding Bonds,
Series 2017C
$4,950,000 General
04/25/2018
06/01/2031
Independent
263868 EG2
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2018A
LLC
end of fiscal year
$1,005,000 Taxable
04/25/2018
06/01/2026
Independent
263868 ER8
Not later than
General Obligation
Public Advisors,
210 days after
Refunding Bonds,
LLC
end of fiscal year
Series 2018B
$2,240,000 General
06/20/2019
06/01 /2039
Independent
263868 FK2
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2019A
LLC
end of fiscal year
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 98 of 629
City of Dubuque / Disclosure Policies and Procedures
Name of Bond Issue
Date of Issue
Final Maturity
Dissemination
CUSIP for Final
Deadline for
Date
Agent
Maturity
Annual Report
$860,000 Taxable
06/20/2019
06/01/2027
Independent
263868 FT3
Not later than
General Obligation
Public Advisors,
210 days after
Bonds, Series 2019B
LLC
end of fiscal year
$4,240,000 General
07/03/2019
06/01/2032
Independent
263868 GGO
Not later than
Obligation Refunding
Public Advisors,
210 days after
Bonds, Series 2019C
LLC
end of fiscal year
$27,995,000 General
06/02/2021
06/01/2041
Independent
263868 HC8
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2021A
LLC
end of fiscal year
$12,535,000 Taxable
06/02/2021
06/01/2036
Independent
263868 HT1
Not later than
General Obligation
Public Advisors,
210 days after
Bonds, Series 2021B
LLC
end of fiscal year
$3,505,000 Water
08/18/2021
06/01/2030
Independent
264057 DK3
Not later than
Revenue Refunding
Public Advisors,
365 days after
Bonds, Series 2021C
LLC
end of fiscal year
$2,345,000 General
06/29/2022
06/01/2042
Independent
263868 KF7
Not later than
Obligation Bonds,
Public Advisors,
210 days after
Series 2022A
LLC
end of fiscal year
$7,220,000 Taxable
06/29/2022
06/01/2042
Independent
263868 JL6
Not later than
General Obligation
Public Advisors,
210 days after
Bonds, Series 2022B
LLC
end of fiscal year
$6,090,000 Taxable
08/01/2023
06/01/2043
Independent
263868 LA7
No later than
General Obligation
Public Advisors,
June 30 after end
Corporate Purpose
LLC
of fiscal year
Bonds, Series 2023A
$6,420,000 General
03/04/2025
06/01/2044
Independent
263868 LV1
No later than
Obligation Corporate
Public Advisors,
June 30 after end
Purpose Bonds, Series
LLC
of fiscal year
2025A
$8,370,000 Taxable
03/04/2025
06/01/2044
Independent
263868 MQ1
No later than
General Obligation
Public Advisors,
June 30 after end
Corporate Purpose
LLC
of fiscal year
Bonds, Series 2025B
$8,945,000 Taxable
03/04/2025
06/01/2044
Independent
263868 NG2
No later than
General Obligation
Public Advisors,
June 30 after end
Urban Renewal Bonds,
LLC
of fiscal year
Series 2025C
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 99 of 629
City of Dubuque / Disclosure Policies and Procedures
Part 11— Separate Table for Each Bond Issue Subject to Continuing Disclosure (tracks details of filings for
each issue)
[Note this is only a form; Issuer staff will update and maintain the Tables separate from this Policy; the
current Table can be obtained from the CD Compliance Officer]
$7,190,000 Sales Tax Revenue Bonds (Unlimited
Property Tax Supported), Second Lien Series 2014
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
US Census Data
AF
AF
AF
01/25/2024
01/24/2025
Unemployment Rates(City only)
AF
AF
AF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
AF
01/25/2024
01/24/2025
Tax Rates
AF
AF
AF
01/25/2024
01/24/2025
Levies and Tax Collections
AF
AF
AF
01/25/2024
01/24/2025
Larger Taxpayers
AF
I AF
AF
1 01/25/2024
1 01/24/2025
Direct Debt
AF
AF
AF
01/25/2024
01/24/2025
Other Debt
AF
AF
AF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
AF
01/25/2024
01/24/2025
$20,800,000 Sales Tax Increment Revenue Bonds
(Annual Appropriation Property Tax
Supported), Senior Bond Series 2015A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
02crating Data
US Census Data
AF
AF
AF
01/25/2024
01/24/2025
Unemployment Rates(City only)
AF
AF
AF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
AF
01/25/2024
01/24/2025
Tax Rates
AF
AF
AF
01/25/2024
01/24/2025
Levies and Tax Collections
AF
AF
AF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
AF
01/25/2024
01/24/2025
Direct Debt
AF
AF
AF
01/25/2024
01/24/2025
Other Debt
AF
AF
AF
1 01/25/2024
1 01/24/2025
Indirect Debt
AF
AF
AF
1 01/25/2024
1 01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 100 of 629
City of Dubuque / Disclosure Policies and Procedures
$2,830,000 General Obligation Bonds, Series
2016A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2015 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$10,920,000 General Obligation Refunding
Bonds, Series 2016B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/l/2015 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$4,145,000 General Obligation Bonds, Series
2016C
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/l/2015 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 101 of 629
City of Dubuque / Disclosure Policies and Procedures
$8,495,000 General Obligation Bonds, Series
2017A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2016 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$9,745,000 General Obligation Urban Renewal
Refunding Bonds, Series 2017B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2016 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$2,120,000 Taxable General Obligation Urban
Renewal Refunding Bonds, Series 2017C
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2016 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 102 of 629
City of Dubuque / Disclosure Policies and Procedures
$4,950,000 General Obligation Bonds, Series
2018A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2017 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$1,005,000 Taxable General Obligation
Refunding Bonds, Series 2018B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2017 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$2,240,000 General Obligation Bonds, Series
2019A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2018 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 103 of 629
City of Dubuque / Disclosure Policies and Procedures
$860,000 Taxable General Obligation Bonds,
Series 2019B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2018 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$4,240,000 General Obligation Refunding Bonds,
Series 2019C
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
Audited Financials
01/26/2021
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
N/A
1/1/2018 Valuations
AF
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
AF
OF
01/25/2024
01/24/2025
Levies and Collections
AF
AF
OF
01/25/2024
01/24/2025
$27,995,000 General Obligation Bonds, Series
2021A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2021
FY2022
FY2023
FY2024
FY2025
FY2026
Audited Financials
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Ogerating Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
1/1/2020 Valuations
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
OF
01/25/2024
01/24/2025
Annual Fiscal Year Debt Service Payments
AF
OF
1 01/25/2024
1 01/24/2025
Levies and Collections
AF
OF
1 01/25/2024
1 01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 104 of 629
City of Dubuque / Disclosure Policies and Procedures
$12,535,000 Taxable General Obligation Bonds,
Series 2021B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2021
FY2022
FY2023
FY2024
FY2025
FY2026
Audited Financials
01/26/2022
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
Iowa Property Valuations
N/A
N/A
N/A
N/A
l/l/2020 Valuations
AF
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
AF
OF
01/25/2024
01/24/2025
Trend of Valuations
AF
OF
01/25/2024
01/24/2025
Larger Taxpayers
AF
OF
01/25/2024
01/24/2025
Debt Limit
AF
OF
01/25/2024
01/24/2025
Direct Debt
AF
OF
01/25/2024
01/24/2025
Other Debt
AF
OF
01/25/2024
01/24/2025
Indirect Debt
AF
OF
01/25/2024
01/24/2025
Tax Rates
AF
OF
01/25/2024
01/24/2025
Annual Fiscal Year Debt Service Payments
AF
OF
1 01/25/2024
1 01/24/2025
Levies and Collections
AF
OF
1 01/25/2024
1 01/24/2025
$3,505,000 Water Revenue Refunding Bonds,
Series 2021C
Reporting Periods
[inset date info was filed on EMMA
Description of Financial Information / Operating
Data to file on EMMA
FY2021
FY2022
FY2023
FY2024
FY2025
FY2026
Audited Financials
06/29/2022
06/28/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
06/26/2024
Operating Data
Rates and Charges
06/29/2022
06/28/2023
06/26/2024
Number of Water Customers
06/29/2022
06/28/2023
06/26/2024
Larger Water Customers
06/29/2022
06/28/2023
06/26/2024
Water Sales
06/29/2022
06/28/2023
06/26/2024
Water Revenue Debt
06/29/2022
06/28/2023
06/26/2024
$2,345,000 General Obligation Bonds, Series
2022A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2022
FY2023
FY2024
FY2025
FY2026
FY2027
Audited Financials
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
Operating Data
Iowa Property Valuations
N/A
N/A
N/A
l/l/2021 Valuations
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
OF
01/25/2024
01/24/2025
Trend of Valuations
OF
01/25/2024
01/24/2025
Larger Taxpayers
OF
01/25/2024
01/24/2025
Debt Limit
OF
01/25/2024
01/24/2025
Direct Debt
OF
01/25/2024
01/24/2025
Other Debt
OF
01/25/2024
01/24/2025
Indirect Debt
OF
01/25/2024
01/24/2025
Tax Rates
OF
01/25/2024
01/24/2025
Annual Fiscal Year Debt Service Payments
OF
1 01/25/2024
01/24/2025
Levies and Collections
OF
1 01/25/2024
1 61/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 105 of 629
City of Dubuque / Disclosure Policies and Procedures
$7,220,000 Taxable General Obligation Bonds,
Series 2022B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2022
FY2023
FY2024
FY2025
FY2026
FY2027
Audited Financials
06/12/2023
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2023
01/25/2024
01/24/2025
O eratin Data
Iowa Property Valuations
N/A
N/A
N/A
1/1/2021 Valuations
OF
01/25/2024
01/24/2025
Gross Taxable Valuation by Class of Property
OF
01/25/2024
01/24/2025
Trend of Valuations
OF
01/25/2024
01/24/2025
Larger Taxpayers
OF
01/25/2024
01/24/2025
Debt Limit
OF
01/25/2024
01/24/2025
Direct Debt
OF
01/25/2024
01/24/2025
Other Debt
OF
01/25/2024
01/24/2025
Indirect Debt
OF
01/25/2024
01/24/2025
Tax Rates
OF
01/25/2024
01/24/2025
Annual Fiscal Year Debt Service Payments
OF
1 01/25/2024
1 01/24/2025
Levies and Collections
OF
1 01/25/2024
1 01/24/2025
$6,090,000 Taxable General Obligation
Corporate Purpose Bonds, Series 2023A
Reporting Periods
inset date info was filed on EMMA
Description of Financial Information / Operating
Data to file on EMMA
FY2023
FY2024
FY2025
FY2026
FY2027
FY2028
Audited Financials
10/11/2024
Unaudited financials, if audit not available by
deadline
01/25/2024
01/24/2025
Ogerating Data
PROPERTY VALUES
Trend of Valuations
01/25/2024
01/24/2025
Larger Taxpayers
01/25/2024
01/24/2025
INDEBTEDNESS
Debt Limit
01/25/2024
01/24/2025
Direct Debt
01/25/2024
01/24/2025
First Lien General Obligation Debt
01/25/2024
01/24/2025
Second Lien Sales Tax Increment General
Obligation Debt
01/25/2024
01/24/2025
Total General Obligation Debt Subject to
Debt Limit
01/25/2024
01/24/2025
Annual Fiscal Year Debt Service Payments
01/25/2024
01/24/2025
First Lien General Obligation Debt
01/25/2024
01/24/2025
Second Lien General Obligation Debt
01/25/2024
01/24/2025
Urban Renewal Revenue Debt
01/25/2024
01/24/2025
Other Debt
01/25/2024
01/24/2025
Water Revenue Debt
01/25/2024
01/24/2025
Sewer Revenue Debt
01/25/2024
01/24/2025
Stormwater Revenue Debt
01/25/2024
01/24/2025
Other Obligations
01/25/2024
01/24/2025
Debt Ratios
01/25/2024
01/24/2025
Direct General Obligation Debt
01/25/2024
01/24/2025
Levies and Collections
01/25/2024
01/24/2025
Tax Rates
01/25/2024
01/24/2025
City ofDubuque
01/25/2024
01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 106 of 629
City of Dubuque / Disclosure Policies and Procedures
$6,420,000 General Obligation Corporate
Purpose Bonds, Series 2025A
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2024
FY2025
FY2026
FY2027
FY2028
FY2029
Audited Financials
Unaudited financials, if audit not available by
deadline
01/24/2025
O eratin Data
PROPERTY VALUES
Trend of Valuations
01/24/2025
Larger Taxpayers
01/24/2025
INDEBTEDNESS
Debt Limit
01/24/2025
Direct Debt
01/24/2025
First Lien General Obligation Debt
01/24/2025
Second Lien Sales Tax Increment General
Obligation Debt
01/24/2025
Total General Obligation Debt Subject to
Debt Limit
01/24/2025
Annual Fiscal Year Debt Service Payments
01/24/2025
First Lien General Obligation Debt
01/24/2025
Second Lien General Obligation Debt
01/24/2025
Urban Renewal Revenue Debt
01/24/2025
Other Debt
01/24/2025
Water Revenue Debt
01/24/2025
Sewer Revenue Debt
01/24/2025
Stormwater Revenue Debt
01/24/2025
Other Obligations
01/24/2025
Debt Ratios
01/24/2025
Direct General Obligation Debt
01/24/2025
Levies and Collections
01/24/2025
Tax Rates
01/24/2025
City ofDubuque
01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 107 of 629
City of Dubuque / Disclosure Policies and Procedures
$8,370,000 Taxable General Obligation
Corporate Purpose Bonds, Series 2025B
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2024
FY2025
FY2026
FY2027
FY2028
FY2029
Audited Financials
Unaudited financials, if audit not available by
deadline
01/24/2025
O eratin Data
PROPERTY VALUES
Trend of Valuations
01/24/2025
Larger Taxpayers
01/24/2025
INDEBTEDNESS
Debt Limit
01/24/2025
Direct Debt
01/24/2025
First Lien General Obligation Debt
01/24/2025
Second Lien Sales Tax Increment General
Obligation Debt
01/24/2025
Total General Obligation Debt Subject to
Debt Limit
01/24/2025
Annual Fiscal Year Debt Service Payments
01/24/2025
First Lien General Obligation Debt
01/24/2025
Second Lien General Obligation Debt
01/24/2025
Urban Renewal Revenue Debt
01/24/2025
Other Debt
01/24/2025
Water Revenue Debt
01/24/2025
Sewer Revenue Debt
01/24/2025
Stormwater Revenue Debt
01/24/2025
Other Obligations
01/24/2025
Debt Ratios
01/24/2025
Direct General Obligation Debt
01/24/2025
Levies and Collections
01/24/2025
Tax Rates
01/24/2025
City ofDubuque
01/24/2025
(Tables continue on the following page)
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 108 of 629
City of Dubuque / Disclosure Policies and Procedures
$8,945,000 Taxable General Obligation Urban
Renewal Bonds, Series 2025C
Reporting Periods
[inset date info was filed on EMMA]
Description of Financial Information / Operating
Data to file on EMMA
FY2024
FY2025
FY2026
FY2027
FY2028
FY2029
Audited Financials
Unaudited financials, if audit not available by
deadline
01/24/2025
O eratin Data
PROPERTY VALUES
Trend of Valuations
01/24/2025
Larger Taxpayers
01/24/2025
INDEBTEDNESS
Debt Limit
01/24/2025
Direct Debt
01/24/2025
First Lien General Obligation Debt
01/24/2025
Second Lien Sales Tax Increment General
Obligation Debt
01/24/2025
Total General Obligation Debt Subject to
Debt Limit
01/24/2025
Annual Fiscal Year Debt Service Payments
01/24/2025
First Lien General Obligation Debt
01/24/2025
Second Lien General Obligation Debt
01/24/2025
Urban Renewal Revenue Debt
01/24/2025
Other Debt
01/24/2025
Water Revenue Debt
01/24/2025
Sewer Revenue Debt
01/24/2025
Stormwater Revenue Debt
01/24/2025
Other Obligations
01/24/2025
Debt Ratios
01/24/2025
Direct General Obligation Debt
01/24/2025
Levies and Collections
01/24/2025
Tax Rates
01/24/2025
City ofDubuque
01/24/2025
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 109 of 629
Dubuque / Auth Disclosure Policies & Procedures
MINUTES AUTHORIZING ADOPTION OF
AMENDED AND RESTATED POLICIES AND
PROCEDURES REGARDING MUNICIPAL
SECURITIES DISCLOSURE
430411
Dubuque, Iowa
March 3, 2025
The City Council of the City of Dubuque, Iowa, met on March 3, 2025, at 6',.30 o'clock P.m.
at the kslor: F r j a;jl Dubuque, Iowa.
3.9c w, 6 +h 5 .
The meeting was called to order by the Mayor, and the roll was called showing the following
Council Members present and absent:
Present: ML\Yor CAvonoxjk, 6ounu*I Mem6r.5' Fc r l� Soy1°s� -rl _k RouSShc4
SprcnNt (,A[7 o l
Absent:
After due consideration and discussion, Council Member Re SV1i C K
introduced the following resolution and moved its adoption, seconded by Council Member
F-Cxr6 e r . The Mayor put the question upon the adoption of said resolution, and
the roll being called, the following Council Members voted:
Ayes: Spmnl/ For6rr, CaVoxoagk, Rf9r;Cj RoV5Sj, �)c$L\) SolCS
Nays:
Whereupon, the Mayor declared the resolution duly adopted as hereinafter set out.
At the conclusion of the meeting, and upon motion and vote, the City Council adjourned.
mm,
Attest:
&L-)A-Ir� &J�L
City Clerk
-1-
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Dubuque/ Auth Disclosure Policies & Procedures
RESOLUTION NO. 73-25
Resolution Authorizing Adoption of Amended and Restated Policies and Procedures
Regarding Municipal Securities Disclosure
WHEREAS, pursuant to the laws of the State of Iowa, the City of Dubuque, Iowa (the "City")
has publicly offered, and likely will issue and publicly offer in the future, its notes, bonds or other
obligations (the "Bonds"); and
WHEREAS, in January of 2015, the City adopted certain Policies and Procedures Regarding
Municipal Securities Disclosure (the "Original Disclosure Policy") to be followed in connection with
the issuance and on -going administration of publicly offered Bonds; and
WHEREAS, as a result of certain changes in federal law, the City deems it necessary and
desirable to amend and restate the Original Disclosure Policy; and
WHEREAS, the proposed Amended and Restated Policies and Procedures Regarding Municipal
Securities Disclosure are attached hereto as Exhibit A (the "Disclosure Policies and Procedures");
NOW, THEREFORE, Be It Resolved by the City Council of the City of Dubuque, Iowa, as
follows:
Section 1. The Disclosure Policies and Procedures attached hereto as Exhibit A are hereby
adopted and shall be dated as of the date hereof.
Section 2. All resolutions or parts of resolutions in conflict herewith are hereby repealed to
the extent of such conflict.
Passed and approved March 3, 2025.
Mayor
Attest:
ad �- � A 4, *A,.
City Clerk
-2-
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Dubuque / Auth Disclosure Policies & Procedures
ATTESTATION CERTIFICATE:
STATE OF IOWA
COUNTY OF DUBUQUE SS:
CITY OF DUBUQUE
I, the undersigned, City Clerk of the City of Dubuque, Iowa, do hereby certify that attached hereto
is a true and correct copy of the proceedings of the City Council relating to the City's adoption of the
Policies and Procedures Regarding Municipal Securities Disclosure.
WITNESS MY HAND this
11
day of Tlorc k , 2025.
A�/ ),.�tix-"r1.e. L4UL
City Clerk
-3-
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Dubuque / Auth Disclosure Policies & Procedures
Exhibit A
AMENDED AND RESTATED
POLICIES AND PROCEDURES RE: MUNICIPAL SECURITIES DISCLOSURE
[see attached]
A-1
DORSEY & WHITNEY LLP, ATTORNEYS, DES MOINES, IOWA
Page 113 of 629
A
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Overview of Municipal Securities Disclosure
Governmental issuers ("Issuers") of municipal bonds are subject to several important legal provisions under federal
securities laws. This overview serves as a starting point for understanding the federal securities law framework surrounding
issuance of municipal bonds. In recent years, the U.S. Securities and Exchange Commission ("SEC") has expanded its
regulation of the municipal securities market, bringing civil and criminal enforcement actions against issuers, elected
officials, and employees for violations of the anti -fraud or continuing disclosure provisions described below.
This overview should be reviewed in connection with the Issuer's policies and procedures (the "Disclosure Policy"),
which relate to (1) the disclosure document (often referred to as the "official statement" or "OS") for publicly -offered
bond transactions and (2) ongoing continuing disclosure associated with outstanding bond issues (also known as
"continuing disclosure").
Overview of Legal Duties Under Federal Securities Law
Issuers of municipal securities are regulated by the Securities Act of 1933 and the Securities Exchange Act of 1934 and
various rules promulgated under those acts by the U.S. Securities and Exchange Commission ("SEC"). Of particular
importance are Rule 10b-5 (which prohibits fraud) and Rule 15c2-12 (which generates an issuer's ongoing disclosure
obligations). Taken together, these rules impose primary disclosure duties (i.e. accuracy and forthrightness in the
preparation of an official statement for new bond issues) and secondary disclosure duties (i.e. timely filing financial and
other data under a continuing disclosure certificate ("CDC") for outstanding bond issues).
How Do the Anti -Fraud Provisions of SEC Rule 10b-5 Affect Issuers?
Various provisions of federal securities law including SEC Rule 10b-5 prohibit fraud in the issuance, purchase, or sale of
municipal securities. These provisions generally prohibit "material" misstatements or omissions to investors, potential
investors, or the general public. Violation of these provisions can result in civil or criminal liability.
Who Is Responsible for the Content of an OS?
When bonds are issued and publicly offered, an official statement will be prepared on behalf of the Issuer. The official
statement is the disclosure document that sets forth the terms associated with the bond issue and is used to market and
sell the Issuer's bonds. Issuers (including elected officials and staff) are primarily responsible for the accuracy of an official
statement. Hiring a professional to assist with the preparation of an OS does not discharge an Issuer's responsibility. The
elected officials and relevant employees of an issuer have an affirmative obligation to ensure the accuracy of the contents
of the financial and other information in an OS— delivery of an OS without first reading it to gauge its accuracy may be
reckless and the basis for an SEC enforcement action.
What Ongoing Requirements Are Imposed by SEC Rule 15c2-12?
SEC Rule 15c2-12 ensures that Issuers contractually agree to provide certain financial and operating information to
investors and the public on an ongoing basis. The type of information that must be reported is generally (i) annual financial
reports and (ii) material event notices.
OORSEYr"'
www.dorsey.com always ahead
This handout is not legal advice, but contains general information not applicable to specific matters.
We are not acting as your legal counsel unless separately retained in a written agreemenRaA&%1J 9sof 629
What Are the Annual Filing Requirements?
Issuers must file updated financial information and operating data on an annual or other regular basis, as specified in their
CDC. Generally, the information that must be reported includes audited financial statements, annual financial or operating
data, of the type included in the OS for the related bonds.
What Material Event Notices Must Be Filed and When?
Issuers must notify investors (via a specific filing on the "EMMA" website, at https:gemma.msrb.org/) within 10 business
days if certain events occur while a bond is outstanding. Generally, those events are items that impact an Issuer's ability
to pay or timely pay amounts owed on outstanding debt, rating changes, defaults, and the incurrence of material financial
obligations (debt obligations of the Issuer). At present, there are 16 events that can trigger reporting obligations. The
Issuer's Disclosure Policy will detail the events and the procedures intended to enable timely identification and disclosure.
What Is Addressed by the Disclosure Policy?
The Disclosure Policy is designed to assist Issuers with fulfilling both primary and secondary disclosure responsibilities. It
sets forth procedures that govern preparation of official statements for new bond offerings (see Appendix I of the policy),
compliance with continuing disclosure requirements under a CDC (see Appendix 11 of the policy), and systematic training of
key staff members and elected officials.
Where Can I Find Additional Information?
As always, you and your staff can contact us with any questions about your responsibilities under federal securities law, to
address specific items, and for annual training seminars (Dorsey & Whitney LLP provides an annual securities law training
for issuers during the first quarter of each year, to satisfy one of the requirements of the Disclosure Policy).
Contacts
John P. Danos
(515) 699-3275
danos.john@dorsey.com
Cristina Kuhn
(515) 699-3272
kuhn.cristina@dorsey.com
www.dorsey.com
David D. Grossklaus
(515) 699-3287
grossklaus.david@dorsey.com
.i
James H. Smith
(515) 699-3276
smith.james@dorsey.com
OORSEYr"'
always ahead
This handout is not legal advice, but contains general information not applicable to specific matters.
We are not acting as your legal counsel unless separately retained in a written agreemenRaA&%1j 5sof 629