Reminder: File Your Qualifying Statement by December 31st

Obtaining “qualified status” each year from the Michigan Department of Treasury is critical if your school wants to borrow money. To issue most types of debt, a school must either have: (1) prior approval or (2) qualified status. The latter saves schools both time and resources.

Prior Approval

Acquiring Treasury’s prior approval is the more costly and time-consuming option. If a school has not obtained qualified status, then school officials must submit a prior approval application to Treasury each time the school wants to borrow. Once the application is deemed “received,” Treasury has up to 30 business days (i.e., six calendar weeks) to evaluate it.

While Treasury may process applications more quickly than 30 business days, prior approval can still cause significant delays, leading to additional stress for unexpected or urgent borrowings. If your school has been denied qualified status and must submit a prior approval application, you should plan ahead and allow sufficient time to accommodate this often lengthy process.

Qualified Status

To obtain qualified status, school officials must complete and electronically file a Municipal Finance Qualifying Statement with Treasury by December 31 of each year. Once a school has been granted qualified status, it can generally borrow during the following year without any further approval from Treasury.

New users must request a username and password from Treasury to file online. Further instructions for filing a Qualifying Statement can be found on the Michigan Department of Treasury website.

Before filing the Qualifying Statement, school officials must have already filed their school’s annual audit. Schools may satisfy their audit filing obligation with both Treasury and the Michigan Department of Education (MDE) through a single electronic filing with MDE. A school’s June 30, 2023 audit must be filed with MDE by November 1, 2023. Specific instructions for audit submissions can be found on the Michigan Department of Education website, Guidance on Electronic Filing of Financial Statement Audits.

Some questions on the Qualifying Statement form (such as those related to taxes levied and delinquent taxes) may be confusing. Please read and complete the form carefully. Upon request and free of charge, Thrun finance attorneys will review a retainer client’s Qualifying Statement before it is filed. Because of Treasury’s online filing interface, to receive a review, you must send a screenshot of the completed form to your finance attorney. Please provide the screenshot by early December to allow adequate time for review before the December 31 filing deadline.