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Environmental Loans Interim financing

Sections NR 162.01 and NR 162.10 and NR 166.04 of the Wisconsin Administrative Code provide that the department may purchase or refinance an eligible municipal applicant's interim financing for an eligible project, subject to applicable requirements and limits established in related statutes and codes.

What is the difference between "reimbursement" and "refinancing"?

Reimbursement - using EIF loan proceeds to pay back a municipal account that advanced internal funds to temporarily pay project costs.

  • Reimbursement applies when the municipality is paying project costs with ordinary municipal funds (such as property tax revenue, user charge revenue, state shared revenue, general investment earnings) and then wants to be reimbursed from the EIF loan proceeds, which are subject to the IRS reimbursement regulations and therefore likely need a "Reimbursement Resolution" (a.k.a. a Declaration of Official Intent to Reimburse or a Comfort Resolution).

Refinancing - using EIF funding to pay off all or part of a debt that was taken out by the municipality to temporarily finance project costs.

  • Refinancing applies when the municipality takes out a debt (bank loan, Land Trust loan, Bond Anticipation Note (BAN), Rural Water Pool) to pay project costs and then wants the EIF loan to be used to pay off that debt, which is subject to the IRS refinancing (a.k.a. refunding) regulations and State limitations on interim financing. This would be a "refinancing" transaction rather than a "reimbursement" transaction.

Limitation on eligibility of interim financing costs

The IRS reimbursement regulations and Wisconsin administrative codes limit the eligibility of interest and issuance costs incurred on interim financing taken out by an applicant for project costs requested in a financial assistance application for the Clean Water Fund Program (CWFP) or the Safe Drinking Water Loan Program (SDWLP).

The IRS reimbursement regulations and Wisconsin administrative codes limit the eligibility of interest and issuance costs incurred on interim financing taken out by an Environmental Improvement Fund (EIF) loan applicant.

See the following sections of Wisconsin Administrative Code for more information:

Note: The Environmental Improvement Fund (EIF) CANNOT reimburse principal or interest payments made on interim debts.

The IRS reimbursement regulations do not allow for the reimbursement of principal or interest payments made by the municipality out of its ordinary municipal revenues or funds.

Interest payments on an interim project debt that are made from the proceeds of that particular debt (capitalized interest) may be refinanced. This is not a "reimbursement" transaction. Rather, such a transaction is treated as "refunding," which is subject to other IRS regulations.

Net interest expense

The interest expenses will be offset with any interest earned on the investment of the proceeds from the interim financing.

Limits on issuance costs

For issuance expenses, the amount eligible is limited to $15,000 plus 1/2 percent (0.5%) of the total eligible face amount of the interim financing. If the interim financing is rolled over or renewed, the face amount may not be counted multiple times in calculating the eligible face amount of interim financing for purposes of this limit. Issuance costs may include legal fees, financial advisor fees, an underwriter's discount, and/or printing costs.

Eligible term for interest costs

The period of time for which interest on interim financing is eligible for funding shall run from no earlier than 12 months prior to the start of construction through the earliest of either of the following:

  • the closing date of the CWFP/SDWLP loan; or
  • one year following substantial completion of the project.

Cost proration

If the term of the interim financing exceeds the above limit, a proration factor will be applied to the interest cost using the length of the eligible term divided by the total time the interim financing is outstanding.

Interim financing as a component of a multi-purpose issue

If the interim financing is a part of a larger multi-purpose debt, the eligible amount of interest and issuance costs will be prorated according to the proportion of eligible interim debt to the total interim debt.

Supporting documentation and invoices

Eligible project, interest, and/or issuance costs incurred on interim financing must be supported by appropriate source documentation and invoices totaling at least the amount to be refinanced. In addition to invoices for eligible project costs, the following documentation is needed:

  • A copy of the interim financing agreement, i.e., Bond Anticipation Note (BAN), NAN, promissory note, etc.
  • A statement of interest charged on the interim financing.
  • A statement of interest earned on investment of the proceeds of the interim financing.
  • A statement of fees charged for issuance costs, e.g., legal fees, financial advisor fees, an underwriter's discount, and/or printing costs.
Contact information
Direct questions to:
Greg Farmer

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Last revised: Friday September 06 2019