TNINVESTCO

Do not see a change and satisfied with current retention status.

RDA 3088 satisfactory as written.

We have reviewed RDA 3088 from an audit standpoint. We would like it to be clear and change the Cut Off to state that it is "When ALL securities are sold at the end of the Program, then maintain in agency 5 years and destroy."

Approve with the change to Cut Off: "When all securities are sold at end of program, then maintian in agency 5 years and destroy." Response from Agency on PRC request for more information on "Securities" definition. "Program ends 12/31/2019. Maintaining docs 5 years after the securities are sold allows the dept. to monitor post programmatic activities, perform analysis on the use of the funds, and document long term benefits of the program to the state." The term securities refers to the portfolio company investments that are sold or liquidated by the TNInvestco entities. The term does not refer to the insurance premium tax credits that funded the program. Please note, the selling (monetization) of the tax credits by the TNInvestco entities to the insurance companies was a one-time event performed at the beginning of the program and is not an ongoing process. However, according to statute (see below), the claiming of the tax credits by the insurance companies began January 1, 2012 and will continue until 2019. The tracking of the tax credits is performed by the department of Commerce & Insurance. According 4-28-103(a)(1) states the following below: (a) A participating investor shall earn an investment tax credit against its state premium tax liability equal to one hundred percent (100%) of the investment tax credit allocated to the participating investor under 4-28-105. The participating investor's investment tax credit shall be earned and vested upon making its investment in the qualified TNInvestco. Beginning January 1, 2012, a participating investor may claim the investment tax credit as follows: (1) In tax years 2012, 2013, 2014, and 2015, an amount equal to fifteen percent (15%) of the investment tax credit allocated to the participating investor; and (2) In tax years 2016, 2017, 2018 and 2019, an amount equal to ten percent (10%) of the investment tax credit allocated to the participating investor.