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Compliance
Arbitrage Rebate Services
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As the premier provider of arbitrage rebate, yield restriction and related post issuance compliance services, we pride ourselves on delivering unmatched technical and regulatory expertise. Our qualifications include:

Technical and Financial Proficiency

BLX numbers more than 45 finance professionals with a per professional average of over six years experience in arbitrage compliance and public finance. In strong contrast to those who view arbitrage compliance as an after-the-fact data entry or accounting function, BLX professionals thoroughly understand the legal, economic, and technical aspects of debt offerings and investment instruments. This expertise allows us to accommodate even the most unusual and complex circumstances and to apply beneficial analytical alternatives when available.

Relevant Experience

BLX has provided arbitrage compliance services for over 12,000 municipal issues since its origination in 1989, including preparing over 32,000 comprehensive analyses since inception.

Tax Regulatory Expertise

Accurately interpreting and applying federal tax laws, rules, and regulations to arbitrage rebate and most other aspects of municipal borrowings is essential both for avoiding outright errors and for maximizing "retainable" earnings in what is essentially an after tax investment environment. With our Orrick, Herrington & Sutcliffe LLP relationship, we are able to deliver an Orrick legal opinion with each completed BLX arbitrage report and escrow verification report which attests that the analysis was prepared in accordance with applicable federal tax laws, rules, and regulations. Orrick has been providing quality legal services to municipal issuers, underwriters, and trustees for over 100 years and has been ranked first nationally as bond counsel for 11 of the past 14 years.*

Comprehensive Reporting

BLX's arbitrage rebate analyses serve as invaluable review tools to ensure that an issue is functioning optimally from both economic and overall covenant compliance perspectives. Our standard services include the following:
  • Verifying that the issue is subject to the Rebate Requirement
  • Calculating and/or recalculating the bond yield as appropriate
  • Identifying and separately accounting for all "Gross Proceeds" (as that term is defined in the Internal Revenue Code) of the bond issue, including those requiring allocation analyses due to "transferred proceeds" and/or "commingled funds" circumstances
  • Determining what general and/or elective exceptions to the bond issue are applicable
  • Calculating the bond issue's excess investment earnings (cumulative rebate liability), if any
  • Providing an executive summary identifying the methodology employed, major assumptions, conclusions, and any recommendations for changes in record keeping and investment policies
  • Providing all IRS filing documentation and instructions, in the event a rebate payment is required

Not Just a Matter of Compliance

In our experience as the nation's leading provider of arbitrage rebate services, we have learned that efforts to minimize negative arbitrage are at least as important as those to minimize positive arbitrage when it comes to improving the economics of our clients' transactions. That's because we understand that bond proceeds investments do not occur in a vacuum, rather they are an integral component of minimizing overall net financing costs. Throughout our history, we have worked with many of the nation's largest and most demanding issuers on developing, implementing, and managing fully-integrated investment and arbitrage compliance strategies for a wide variety of bond-related projects.

For general inquiries, please contact:

Sandee Stallings,
Managing Director
Phone: 214.989.2701
Email: sstallings@blxgroup.com