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:
1. General Obligation Bonds
2. General Obligation Capital Loan Notes
3. Bond Anticipation Notes
4. Revenue Anticipation Notes
5. School Infrastructure Sales, Services, and Use Tax Revenue Bonds
6. 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 repay working capital debt within thirteen (13) months of issuance. 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 (within federal tax law constraints) 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 it is in the best interest of the school district.
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.
The Investments policy of the Wapello Community School District shall apply to all public funds of the school district, which includes operating funds, bond proceeds, and all other funds, and all investment transactions involving public funds accounted for in the financial statements of the school district. Eave investment made pursuant to this policy must be authorized by applicable law and this written Investments Policy
The investment of debt service or sinking funds shall comply not only with this Investments policy, but also be consistent with any applicable bond resolution.
This policy is intended to comply with Iowa Code 12B.
Upon passage and upon future amendment, if any, copies of this policy shall be delivered to all the following:
The governing body or officer of the school district to which the Investments policy applies
All depository institutions or fiduciaries for public funds of the school district.
The auditor engaged to audit any funds of the school district
In addition, a copy of this policy shall be delivered to every fiduciary or third party assisting with or facilitating investment of school district funds.
Delegation of Authority
In accordance with Iowa Code 12B.10(1), the responsibility for conducting investment transactions resides with the Treasurer. Only the Treasurer and those authorized by resolution may invest public funds and a copy of any empowering resolution shall be attached to this policy.
All contracts or agreements with outside persons investing public funds, advising on the investment of public funds, directing the deposit or investment of public funds, or acting in a fiduciary capacity for the school district shall require the outside person to notify the school district in writing, within thirty (30) days of receipt of all communication from the Auditor of the outside person or any regulatory authority, of the existence of a material weakness in internal control structure of the outside person or regulatory orders or sanctions regarding the type of services being provided to the school district by the outside person.
The records of investment transactions made by or on behalf of the school and district are public records and are the property of whether in the custody of the school district or in the custody of a fiduciary or other third party. If a fiduciary or other third party with custody of school district public investment transaction records fails to produce requested records when requested by the school district within a reasonable time, the school district shall make no new investment with or through the fiduciary or third party and shall not renew maturing investments with or through the fiduciary or third party.
The Treasurer shall establish a written system of internal controls and investment practices. The controls shall be designed to prevent losses of public funds, to document those officers and employees of the school district responsible for elements of the investment process, and to address the capability of investment management. The controls shall provide for receipt and review of the audited financial statement and related reports on internal control structure of all outside persons performing any of the following for the school district:
Investing public funds
Advising on the investment of public funds
Directing the deposit or investment of public funds
Acting in a fiduciary capacity for the school district.
A bank, savings and loan association, or credit union providing only depository services shall not be required to provide an audited financial statement and related report on internal control structure.
The Treasurer and all employees authorized to place investments shall be bonded at an appropriate level.
Objectives
The primary objectives, in order of priority,, of all investment activities involving the financial assets of the school district shall be the following:
Safety: Safety and preservation of principal in the overall portfolio is the foremost investment objective.
Liquidity: Maintaining the necessary liquidity to match expected liabilities is the second investment objective.
Return: Obtaining a reasonable return is the third investment objective.
Prudence
The Treasurer, when investing or depositing public funds, shall exercise care, prudence, and diligence under the circumstances then prevailing that a person acting in a like capacity and familiar with such matters would use to attain the investment “Objectives”. This standard requires that when making investment decisions, the Treasurer shall consider the role that hte investment or deposit plays within the portfolio assets of the school district and the investment objectives stated in “Objectives.”
When investing school district assets for a period longer than two (23) years, the Treasurer shall request competitive investment proposals for comparable credit and term investments from a minimum of three (3) investment providers.
Instruments Eligible for Investment
School district assets may be invested in the following:
Obligations of the United States government, its agencies and instrumentalities.
Certificates of deposit and other evidences of deposit (i.e., savings accounts, interest-bearing checking accounts, money market accounts, etc.) at federally insured Iowa depository institutions approved and secured pursuant to Iowa Code 12C
An open-end management investment company registered with the Securities & Exchange Commission under the federal Investment Company Act of 1940, 15 U.S.C. Section 80(a) and operated in accordance with 17 C.F.R. Section 270.2a-7, whose portfolio investments are limited to those instruments individually authorized in this "Instruments Eligible for Investment” of this Investment Policy.
All instruments eligible for investment are further governed by all other provisions of this Investments policy, including “Investment Maturity Limitations” and “Diversification Requirements.”
Prohibited Investments and Investment Practices
School district assets shall not be invested in the following:
Reverse repurchase agreements
Futures and options contracts
School district assets shall not be invested pursuant to the following investment practices:
Trading of securities for speculation or the realization of short-term trading gains.
Pursuant to a contract providing for the compensation of an agent or fiduciary based upon the performance of the invested assets.
Investment Maturity Limitations
Operating Funds must be identified and distinguished from all other funds available for investment. Operating Funds are defined as those funds which are reasonably expected to be expended during a current budget year or within fifteen months of receipt.
All investments authorized in “Instruments Eligible for Investment” are further subject to the following investment maturity limitations: Operating Funds may only be invested in instruments authorized in “Instruments Eligible for Investment” of this Investments policy that mature within three hundred ninety-seven (397) days. However, if the school district has or expects to accrue in the current budget year an amount of public funds that exceeds Operating Funds by at least thirty-three perfect, the school district may invest amounts exceeding thirty-=three percent of Operating Funds in certificates of deposit at federally insured depository institutions approved pursuant to ioa Code 12C which mature within sixty-three months or less provided that the school district invests an amount reasonably expected to be expended during the current budget year or within fifteen months of receipt in investments authorized in “Instruments Eligible for Investment” of this Investment Policy that mature within three hundred ninety-seven (397) days.
The Treasurer may invest funds that are not identified as Operating Funds in investments with maturities longer than three hundred ninety-seven days (397) days. However, all investments of the school district shall have maturities that are consistent with the school district’s needs and use of funds.
Diversification
School district investments are subject to the following diversification requirements:
Prime bankers’ acceptances:
At the time of purchase, no more than ten percent (10%) of the investment portfolio of the school district shall be invested in prime bankers’ acceptances; and
At the time of purchase, no more than five percent (5%) of the investment portfolio of the school district shall be invested in the securities of a single issuer.
Where possible, it is the policy of the school district to diversify its investment portfolio. Assets shall be diversified to eliminate the risk of loss resulting from over concentration of assets in a specific maturity, a specific issuer, or a specific class of securities. In establishing specific diversification strategies, the following general policies and constraints shall apply:
Portfolio maturities shall be staggered in a way that avoids undue concentration of assets in a specific maturity sector. Maturities shall be selected which provide stability of income and reasonable liquidity.
Liquidity practices to ensure that the next disbursement date and payroll date are covered through maturing investments, marketable U.S. Treasury bills, or cash on hand shall be used at all times.
Risks of market price volatility shall be controlled through maturity diversification so that aggregate price losses on instruments with maturities approaching one year shall not be greater than coupon interest and investment income received from the balance of the portfolio.
Safekeeping and Custody
All school district invested assets involving the use of a public funds custodial agreement, as defined in Iowa Code 12B.10C, shall comply with all rules adopted pursuant to Iowa Code 12B.10C. All custodial agreements shall be in writing and shall contain a provision that all custodial services be provided in accordance with the laws of the state of Iowa.
All school district invested assets eligible for physical delivery shall be secured by having them held at a third-party custodian. All purchased investments shall be held pursuant to a written third-aprty custodial agreement requiring delivery versus payment and compliance with all rules set out in this Sedtion, “Safekeeping Custody.”
Reporting
The Treasurer shall monthly, submit to the Board of Directors an investment report that summarizes recent market conditions and investment strategies employed since the last investment report. The investment report shall set out the current portfolio in terms of maturity, rates of return , and other features and summarize all investment transactions that have occurred during the reporting period and compare the investment results to the budgetary expectations.
Investment Policy Review and Amendment
This investment policy shall be reviewed every three (e) years or more frequently as appropriate. Notice of amendments to the Investments policy shall be promptly given to all parties noted in the “Scope of Investments” section.
Legal References: Iowa Code 11.2, .6; 12.62; 12B.10; 10A; 12C; 22.1, .14; 28E.2; 257.29; 283A;
285; 502.701; 633.123
Cross References: 206.03 Secretary
206.04 Treasurer
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;