IRMA Exemption Letter For Developers

January 1, 2024

Independent Registered Municipal Advisor Representation Letter

The Escambia County Housing Finance Authority (the “Authority”) is hereby disclosing and notifying all potential underwriters and placement agents that it has retained an independent registered municipal advisor (“Municipal Advisor”). By publicly posting the following written disclosure, the Authority intends that market participants receive and use it for purposes of the Independent Registered Municipal Advisor Exemption (the “IRMA Exemption”) as provided in the Securities and Exchange Commission’s final rules adopted for municipal advisor registration (the “Final MA Rules”).

The Authority is represented by and will rely on its Municipal Advisor, CSG Advisors Incorporated (“CSG”), and more specifically, David Jones, for General Municipal Advisory Services and to provide advice on proposals from financial services firms concerning the issuance of municipal securities and municipal financial products (including investment of bond proceeds, escrow investments, the sale of mortgage backed securities and other securities in connection with the Authority’s single or multi-family programs (“Transaction Advisory Services”). The individuals listed herein are on our retained team at our Municipal Advisor and have been employed by our Municipal Advisor for two years (or more) prior to the date of this disclosure and, thus, are not “associated” (as defined in the Final MA Rules) at either an entity level or an individual level with persons seeking to rely on the IRMA Exemption. Any changes to the Authority’s team going forward will be promptly posted to the Authority’s website. The written notice required under the IRMA Exemption of the Final MA Rules stating that an underwriter or placement agent is not a municipal advisor and is, therefore, not subject to a fiduciary duty to the Authority should be provided to the Authority at the address noted below, with a copy to CSG at 41 Perimeter Center East, Suite 615, Atlanta, GA 30346.

Notices and proposals should be addressed to Lisa Bernau, Executive Director, at 700 South Palafox Street, Suite 310, Pensacola, FL 32502. To encourage the continued sharing of ideas and propriety information by market participants, the Authority intends to keep original materials provided by and concepts it discusses with market participants from time to time confidential (to the extent provided by law) but hereby reserves the right, in its sole discretion, to share any information which will be seriously considered by the Authority with its Municipal Advisor. Please note, that aside from regulatory mandated correspondence between an underwriter and municipal advisor, an underwriter or placement agent should not speak directly with or send documents directly to the Authority’s Municipal Advisor unless specifically directed to do so by the Authority’s Executive Director.

This Representation Letter may be relied upon until December 31, 2024, unless amended or otherwise replaced by a new Representation Letter posted to the Authority’s website.

- Lisa Bernau, Executive Director

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