Post-Issuance Compliance Policy

April 17, 2023

The Post-Issuance Compliance Policy establishes guidelines to facilitate compliance with the federal tax law applicable to Baylor’s outstanding tax-exempt debt issues, including documentation and filing requirements, use of proceeds, and limitations on the use of property financed by tax-exempt debt.

Overview of Policy

• Establishes responsibility for compliance as being jointly held by all University departments which use tax-exempt debt proceeds or property financed by tax-exempt debt proceeds; including Financial Services, Business Services, Facilities Management, Office of Advancement, Office of General Counsel, Office of the Vice Provost for Research, and Real Estate Operations.

• Defines monitoring requirements for these same offices.

• Establishes tax compliance procedures that must be followed for the issuance of tax-exempt debt, the use of debt proceeds and debt-financed property, arbitrage rebate monitoring, and accounting for debt proceeds.