Revenues of the Wapello Community School District shall be received by the board treasurer or their designee. Other persons receiving revenues on behalf of the school district shall promptly turn them over to the board treasurer or their designee.
Revenue, from whatever source, shall be accounted for and classified under the official accounting system of the school district. It shall be the responsibility of the board treasurer to deposit the revenues received by the school district in a timely manner. School district funds from all sources shall not be used for private gain or political purposes.
Tuition fees received by the school district shall be deposited in the general fund. The tuition fees for kindergarten through twelfth grade during the regular academic school year shall be set by the board based upon the superintendent's recommendation in compliance with current law. Tuition fees for summer school, driver's education and adult education shall be set by the board prior to the offering of the programs.
The board may charge materials fees for the use or purchase of educational materials. Educational materials fees received by the school district shall be deposited in the general fund. It shall be the responsibility of the superintendent to recommend to the board when materials fees will be charged and the amount of the materials fees.
Rental fees received by the school district for the rental of school district equipment or facilities shall be deposited in the general fund. It shall be the responsibility of the superintendent to recommend to the board a fee schedule for renting school district property.
Proceeds from the sale of real property shall be placed in the Physical Plant and Equipment Levy (PPEL) fund. However, following a properly noticed public hearing, the board of directors may elect to deposit proceeds from the sale of real property or buildings into any fund under the control of the school corporation. Notice for the public hearing must be published in a newspaper of general circulation within the district not less than ten and no more than twenty days prior to the proposed public hearing. Notice of the public hearing must include the date, time, and location of the public hearing and a description of the proposed action. . The proceeds from the sale of other school district property shall be placed in the general fund.
The board may claim exemption from the law prohibiting competition with private enterprise for the following activities:
It shall be the responsibility of the superintendent to bring to the board's attention additional sources of revenue for the school district.
Legal Reference: Iowa Code 12C; 23A; 24.9; 257.2; 279.8, .41; 282.2, .6, .24; 291.12,
279.9-.12, .22; 301.1
Cross Reference: 701.1 Depository of Funds
703 Budget
805 Selling and Leasing
905 Use of School District Facilities and Equipment
Approved: 7/18/95
Reviewed: 12/13/01; 12/12/07; 12/14/11; 4/10/19; 1/10/24
Revised: 12/13/01; 4/17/24
Credit Ratings
The school district seeks to maintain the highest possible credit ratings for all categories of short-and long-term debt that can be achieved without compromising the delivery of services and the achievement of adopted objectives. The school district recognizes that external economic, natural, or other events may from time to time affect the creditworthiness of its debt. Nevertheless, the school district is committed to ensuring that actions within their control are
prudent.
Debt Limits For general obligation debt, the school district's outstanding debt limit shall be no more than five percent (5%) of the actual value of property within the school district's boundaries, as prescribed by the Iowa constitution and statutory restrictions.
For revenue debt, the school district's goal is to provide adequate debt service coverage of at least 1.20 times the annual debt service costs. In accordance with Iowa law, the school district may not act as a conduit issuer or issue municipal security to raise capital for revenue-generating projects where the funds generated are used by a third party ("conduit borrower") to make payments to investors.
PURPOSES AND USES OF DEBT
Capital Planning To enhance creditworthiness and prudent financial management, the school district is committed to systematic capital planning, intergovernmental cooperation and coordination and long-term financial planning.
Capital Financing The school district may issue long-term debt for capital projects as authorized by Iowa law, which include, but are not limited to, the costs of planning, design, land acquisition, buildings, permanent structures, attached fixtures or equipment, and movable pieces of equipment.
Capitalized interest may be included in sizing any capital project debt issue. The types of debt instruments to be used by the school district include: General Obligation Bonds, General Obligation Capital Loan Notes, Bond Anticipation Notes, Revenue Anticipation Notes School Infrastructure Sales, Services, and Use Tax Revenue Bonds, and Lease Purchase Agreements, including Certificates of Participation Working Capital Financing The school district may issue debt for working capital for operations after cash flow analysis has determined that there is a mismatch between available cash and cash outflows. The school district shall strive to repay working capital debt by the end of the fiscal year in which the debt was incurred. A Working Capital Reserve may be included in sizing any working capital debt issue.
Refundings Periodic reviews of all outstanding debt will be undertaken to determine if refunding opportunities exist. Refunding will be considered (within federal tax law restraints) if and when there is a net economic benefit of the refunding or if the refunding is otherwise in the best interests of the school district, such as to release restrictive bond covenants which affect the operations and management of the school district. In general, advance refundings for economic savings will be undertaken when a net present value savings exceeds three percent of the refunded debt can be achieved. Current refundings, which produce a new present value savings of less than three percent will be considered on a case by case basis taking into consideration bond covenants and general conditions. Refundings with negative savings will not be considered unless there is a compelling public policy objective for doing so.
DEBT STANDARDS AND STRUCTURE
Length of Debt
Debt Structure
Decision Analysis to Issue Debt
DEBT ISSUANCE
Credit Enhancement
Method of Sale
Professional Service Providers
DEBT MANAGEMENT
Investment of Debt Proceeds
Arbitrage and Record Keeping Compliance
Financial Disclosure
Legal Reference: Iowa Code §§ 74-76; 278.1; 298; 298A (2013).
Cross Reference: 701 Financial Accounting System
704 Revenue
Approved: 10/16/97
Reviewed: 12/13/01; 12/12/07; 12/14/11; 4/10/19; 1/10/24
Revised: 12/13/01; 5/9/16
1. Compliance Coordinator:
a: The School Business Official/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, a rebate consultant, financial advisor, 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 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. Said transcript shall include, at a minimum:
a: Form 8038s
b: minutes, resolutions, and certificates
c: certifications of issue price form the underwriter
d: formal elections required by the IRS
e: trustee statements
f: records of refunded bonds, if applicable
g: correspondence relating to bond financings
h: reports of any IRS examinations for bond financings
3. Proper Use of Proceeds: The Coordinator shall review the resolution authorizing issuance of reach tax-exempt obligation issued by the District, and that the District shall:
a: obtain a computation of the yield on such issue from the 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 records showing payment
f: maintain records showing the earnings on, and investment of, the Project Fund
g: ensure that all 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
i: maintain records related to any investment contracts, credit enhancement transactions, and the bidding of financial products related to the proceeds.
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 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 for in such certificate
b: if the 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 for in such certificate
c: not less than 60 days prior to a required expenditure date confer with bond counsel and a rebate consultant if the District will fail to meet the applicable temporary period or rebate exception expenditure requirements of the Tax-Exemption Certificate
d: in the event the District fails to meet a temporary period or rebate exception:
1: 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.
2: 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:
1. management contracts
2. service agreements
3. research contracts
4. naming rights contracts
5. leases or sub-leases
6. joint venture, limited liability or partnership arrangements
7. sale of property
8. 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 said 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
d. In the event the 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 Regulations Sections 1.141-12.
6. General Project Records
For each project financed with tax-exempt obligations,t he 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. Advance Refundings
The Coordinator shall be responsible for the following current, post issuance and record retention procedures with respect to advance refunding bonds:
a. Identify and select bonds to be advance refunded with advice from internal financial personnel and a financial advisor
b. The Coordinator shall identify with advice from the financial advisor and bond counsel, any possible federal tax compliance issues prior to structuring any advance refunding.
c. The Coordinator shall review the structure with the input of the financial advisor and bond counsel, or advance refunding issues prior to the issuance to ensure (1) that the proposed refunding is permitted pursuant to applicable federal tax requirements if there has been a prior refunding of the original bond issue; (2) that the proposed issuance complies with federal income tax requirements which might impose restrictions on the redemption date of the refunded bonds; (3) that the proposed issuance complies with federal income tax requirements which allow for the proceeds and replacement proceeds of an issue to be invested temporarily in higher yielding investments without causing the advance refunding bonds to become "arbitrage bonds"; and (4) that the proposed issuance will not result in the issuer's exploitation of the difference between tax exempt and taxable interest rates to obtain a financial advantage nor overburden the tax exempt market in a way that might be considered an abusive transaction for federal tax purposes.
d. The Coordinator shall collect and review data related to arbitrage yield restriction and rebate requirements for advance refunding bonds. To ensure such compliance, the Coordinator shall engage a rebate consultant to prepare a verification report in connection with the advance refunding issuance. Said report shall ensure said requirements are satisfied.
e. The Coordinator shall, whenever possible, purchase SLGS to size each advance refunding escrow. The financial advisor shall be included in the process of subscribing SLGS. To the extent SLGS are not available for purchase, the Coordinator shall, in consultation with bond counsel and the financial advisor, comply with IRS regulations.
f. To the extent an issuer elects to the purchase a guaranteed investment contract, the Coordinator shall ensure, after input from bond counsel, compliance with any bidding requirements set forth by the IRS regulations.
g. In determining the issue price for any advance refunding issuance, the Coordinator shall obtain and retain issue price certification by the purchasing underwriter at closing.
h. After the issuance of an advance refunding issue, the Coordinator shall ensure timely identification of violations of any federal tax requirements and engage bond counsel in attempt to remediate same in accordance with IRS regulations.
Wapello Community School District funds in excess of current needs shall be invested in compliance with this policy. The goals of the school district's investment portfolio in order of priority are:
In making investments, the school district 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.
School district funds are monies of the school district, including operating funds. "Operating funds" of the school 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. If, during the current budget year an amount of public funds will exceed operating funds by at least thirty-three percent, the amount of public funds that exceed operating funds by greater than thirty-three percent may be invested in certificates of deposit at federally insured depository institutions which mature within sixty-three months or less, in accordance with state and federal laws. When investing funds other than operating funds, the investments mature according to the need for the funds.
The board authorizes the treasurer to invest funds in excess of current needs in the following investments:
It shall be the responsibility of the treasurer to oversee the investment portfolio in compliance with this policy and the law.
It shall be the responsibility of- the treasurer to bring a contract with an outside person to invest school district funds, to advise on investments, to direct investments, to act in a fiduciary capacity or to perform other services to the board for review and approval. The 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 school 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 school district and to provide the documents necessary for the performance of the investment portion of the school district audit. The compensation of the outside persons shall not be based on the performance of the investment portfolio.
The 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 treasurer to obtain the information necessary to ensure that the investments and the outside persons doing business with the school 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 school district's depositories, auditor and outside persons doing investment business with the school district.
It shall also be the responsibility of the superintendent, in conjunction with the 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.
Legal Reference: Iowa Code 11.2, .6; 12.62; 12B.10; 10A' 12C' 22/1. /14' 28#2; 257; 279.29;
283A; 285; 502.701; 633.123
Cross References: 206.4 Treasurer
704 Revenue
Approved: 4/18/95
Reviewed: 152/13/01; 12/12/07; 12/14/11; 4/10/19; 1/10/24
Revised: 12/13/01
The Wapello Board of Directors believes gifts, grants, and bequests to the school district may be accepted when they will further the interests of the school district. The board shall have sole authority to determine whether the gift furthers the interests of the school district.
Gifts, grants, and bequests shall be approved by the board. Once it has been approved by the board, a board member or the superintendent may accept the gift on behalf of the school district.
Gifts, grants, and bequests once accepted on behalf of the school district shall become the property of the school district. Gifts, grants, and bequests shall be administered in accordance with terms, if any, agreed to by the board.
Legal Reference: Iowa Code §§ 279.42; 565.6 (1993).
Cross Reference: 217 Gifts to Board of Directors
402.4 Gifts to Employees
508.1 Class or Student Group Gifts
Approved: 7/18/95
Reviewed: 12/13/01; 12/12/07; 12/14/11; 4/10/19; 1/10/24
Revised: 12/13/01
Revenue raised by students or from student activities shall be deposited and accounted for in the student activities fund. This revenue is the property of and shall be under the financial control of the board. Students may use this revenue for purposes approved by the superintendent or superintendent's designee.
Whether such revenue is collected from student contributions, club dues, and special activities or result from admissions to special events or from other fund-raising activities, all funds will be under the jurisdiction of the board and under the specific control of the superintendent or superintendent's designee. They will be deposited in a designated depository and will be disbursed and accounted for in accordance with instructions issued by the superintendent.
It shall be the responsibility of the superintendent’s secretary to keep student activity accounts up-to-date and complete.
Any unencumbered class or activity account balances will automatically revert to the activity fund when a class graduates or an activity is discontinued.
Legal Reference: Iowa Code 279.8
Cross Reference: 504 Student Activities
701 Financial Accounting System
Approved: 7/18/95
Reviewed: 12/13/01; 12/12/07; 12/14/11; 4/10/19; 1/10/24
Revised: 12/13/01
Fundraising can foster a sense of community and pride in the school district through group efforts to accomplish a common goal. The school board believes fundraising campaigns can further the interests of the district. Care must be taken to help ensure fundraising efforts are done properly and safely to benefit the school community. The school board is responsible for approving all district affiliated and student fundraising. Any person or entity acting on behalf of the district and wishing to conduct a fundraising campaign for the benefit of the district shall begin the process by seeking prior approval from t6he board or its designee. Any fundraising efforts conducted using the district’s resources, any, logos, symbols, or imagery will be conducted in accordance with all policies, regulations, and rules for fundraising within the district.
District Affiliated Fundraising
There are times when the school board may decide to engage in district-affiliated fundraising efforts to benefit the school district. All district affiliated fundraising efforts will fulfill a public purpose and will not benefit only one single individual or family, except in unique circumstances pre-approved by the school board. The use of district owned resources to conduct fundraising efforts will be in accordance with all applicable laws and regulations and other relevant district policies and procedures.
Money or items raised by any district affiliated 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,
Student Fundraising
Students may raise funds for school-sponsored events with the permission of the school board. The school board delegates to the Superintendent the authority to approve routine student fundraising as deemed appropriate. Collection boxes for school fundraising must have prior approval from the school board or its designee before being placed on school property. All funds generated from district-sponsored student fundraising will be placed in the district’s student activity fund. The Superintendent will develop necessary regulations to ensure the safety and equity of student fundraising efforts.
Online Fundraising
The use of the district’s name, logos, symbols, or imagery for online fundraising will be subject to the approval of the Superintendent. All online fundraising efforts will fulfill a public purpose, and will not benefit only one single individual or family except in unique circumstances pre-approved by the school board. 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.
All items and money generated from online fundraising 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 districted to individual employees.
Legal Reference: Senior Class of Pekin High School v. Tharp, 154 N.W. 2d 874 (Iowa 1967).
Iowa Code 279.8; 279.42; 565.6
Cross Reference: 508.1 Class or Student Group Gifts
504.5 Student Fundraising
704.4 Gifts—Grants—Bequests
904.2 Advertising and Promotion
Approved: 5/8/24
Reviewed:
Revised:
All district affiliated fundraising will be approved by the school board. Once approved, funds collected related to district affiliated fundraising will be placed in the appropriate fund in accordance with applicable laws and board policies. Prior to approval of district affiliated fundraising efforts, the board will consider
Student Fundraising
Student fundraising can enhance a student’s educational experience, but it must not be at the expense of the safety and education of the district’s students. The following are additional regulations to assist the administration in developing procedures necessary for successful fundraising efforts;