HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 05/04/2010 - ITEMS RELATING TO SALES, USE AND LODGING TAX DATE: May 4, 2010
STAFF: Chuck Seest • - • •
Items Relating to Sales, Use and Lodging Tax.
A. First Reading of Ordinance No.054,2010,Amending Chapter25,Article III of the City Code Concerning Sales
and Use Tax.
B. First Reading of Ordinance No.055,2010,Amending Section 25-252 of the City Code Relating to the Vendor
Fee for Collecting and Remitting Lodging Tax.
EXECUTIVE SUMMARY
Ordinance No.054,2010,modifies City Code to allow for use of a certified electronic address database for determining
whether or not a customer is in the City, and it simplifies tax collection regarding definitions, waivers, and notice.
Ordinance No. 055, 2010, will eliminate the City's current vendor fee for lodging tax licensees. The proposed
modification will result in approximately $25,000 of ongoing additional revenue available for the promotion of
convention and visitor activities and for cultural development and programming services. This change will not increase
taxes or fees charged, but rather eliminate the amount of City lodging taxes that vendors are allowed to retain in
exchange for the service they provide in collecting City taxes. Currently, vendors are allowed to retain 3% of the
lodging tax collected.
BACKGROUND / DISCUSSION
A. Ordinance No.054,2010 Amending Chapter 25,Article III of the City Code Concerning Sales and Use
Tax.
The amendment to Section 25-123 allows the businesses (taxpayers)that rely on the certified database to be"held
harmless"in a future audit if they did not collect the City of Fort Collins sales tax due to an error in the address locator
database. The Ordinance encourages the use of the database, which provides retailers with great accuracy as to
which municipality they are making deliveries. Presently,some retailers are often unaware of where a delivery address
is located,and City of Fort Collins tax is often not collected. For example,ABC sells a couch to a customer with a Fort
Collins address. ABC enters the address into one of the two databases and it indicates what tax rate should be
collected. The rate is determined by whether or not the address is located in the city limits of Fort Collins.
The City of Fort Collins Management Information Services department is currently working with the two database
companies to confirm the accuracy of their data. The two companies are First American Spatial Solutions and Group
1 Software (part of Pitney Bowes).
In addition to the State of Colorado,the home rule cities that have adopted similar provisions in their tax codes include
Arvada,Aurora,Boulder,Brighton,Denver,Longmont,Loveland,Northglenn,Silverthorne,Westminster,Wheat Ridge,
and Woodland Park. The Colorado Municipal League is a proponent of the databases and has urged municipalities
to adopt a sales and use tax locator/hold-harmless ordinance (Attachment 1).
The remaining portion of the Ordinance addresses areas of confusion in the Code regarding definitions,waivers,and
notice.
• The definition of drugs dispensed in accordance with a prescription has been clarified.
• Section 25-186 has been clarified to indicate notices of assessment should be sent via first class mail or
certified mail.
• Section 25-225 has clarified the statute of limitations ruling with regard to audits.
May 4, 2010 -2- ITEM 15
B. Ordinance No. 055, 2010, Amending Section 25-252 of the City Code Relating to the Vendor Fee for
Collecting and Remitting Lodging Tax
The vendor fee is a service fee that is retained by sales tax licensees in recognition of their work in collecting the City's
sales and use taxes. The fee was originally established to acknowledge that merchants incurred a cost for collecting
lodging taxes, including accounting work and the completion of paper forms for remitting the lodging tax collection.
With increasingly automated accounting processes,the cost incurred by vendors has greatly diminished as their"point
of sale" software makes these calculations for the vendor. On November 3, 2009, Council adopted an ordinance to
eliminate the vendor fee for sales and use tax licensees.
The current vendor fee for lodging tax licensees allows licensees to keep 3%of the lodging tax collected during each
reporting period as a service fee for collecting the tax.The fee may be taken only if the return is filed and paid on time.
There are 23 active lodging tax licenses. This Ordinance eliminates the vendor fee for lodging tax licensees.
This change has been discussed with Jim Clark, Executive Director of the Fort,Collins' Convention and Visitors'
Bureau. Mr. Clark agreed the change was consistent with elimination of the broader vendor fee that applied to sales
and use tax collections.
FINANCIAL IMPACT
Ordinance No. 054, 2010 does not have any immediate financial impacts. As updates need to be made to the
database to reflect future annexations to the City boundary, the Finance Department will coordinate with the City's
Management Information Systems Department to validate the accuracy of the database. This will ensure that vendors
relying upon these databases are calculating the appropriate taxes and collecting the appropriate amount on the behalf
of the City.
Ordinance No.055,2010 amends the City Code to eliminate the vendor fee paid to merchants who collect City lodging
tax. Elimination of the fee will result in approximately $25,000 of ongoing additional revenue available for the
promotion of convention and visitor activities and for cultural development and programming services.
SUSTAINABILITY: ECONOMIC, ENVIRONMENTAL AND SOCIAL IMPACTS
The economic impact of Ordinance No. 054, 2010 would be that vendors would be able to collect the appropriate tax
at the time of sale rather than when an audit is performed. The City would be receiving the monies in a more timely
manner.
The economic impact of Ordinance No. 055, 2010 would be additional funds would be available for use in promoting
convention and visitor activities which ultimately could increase tourism and spending in the City.
STAFF RECOMMENDATION
Staff recommends adoption of these Ordinances on First Reading.
ATTACHMENTS
1. Memo from the Colorado Municipal League
ATTACHMENT
GML
1144 Sherman Street•Denver,Colorado 80203-2207 0 Phone(303)831-6411,Fax(303)860-8175 •cmlQcml.ore
MEMORANDUM
TO: Sales Tax Committee Representatives for home rule municipalities that locally collect
their sales tax
FROM: Geoff Wilson,General Counsel
SUBJECT: Request for Adoption of Model Address Locator/"Hold-harmless" Ordinance
DATE: February 9,2007
By this memorandum, we respectfully urge your municipality to adopt a sales and use tax address
locator/"hold-harmless"ordinance similar to the enclosed ordinance, which was adopted by Denver
earlier this year.
Introduction
Adoption of these ordinances by home Wile municipalities that locally collect their sales tax will be the
culmination of a multi-year tax simplification effort involving CML,the business community and the
CML Sales Tax Committee(which includes a member representing each locally collecting home rule
municipality).The"Address Locator Project"is described below. The project has been unanimously
endorsed by CML's Executive Board and the CML Sales Tax Simplification Committee.
In a nutshell,these ordinances will hold retailers harmless if they fail to remit tax to the correct
municipality,based solely on an error in a state-certified address locator database. The ordinances thus
encourage use of these databases,which tell retailers with great accuracy in which municipality they
are making a sale or,more often,a delivery. Presently,retailers are often unaware of where,exactly,a
delivery address is located,and tax is often remitted to the wrong municipality.
Municipal tax officials have viewed use of address locator databases as a"win-win"proposition for
municipalities and business owners alike. Business owners remit properly in the first place and avoid
unpleasant news at audit time. Municipalities receive the convect tax right away,and are able to avoid
forcing an unwitting retailer to remit a second time,or squabbling with another municipality over who
is entitled to the money. Plus,this is important tax simplification that doesn't hurt municipalities and
can be adopted without a TABOR election.
Colorado's Home Rule Municipal Tax System: Critical,but Complicated
As you are no doubt aware,Colorado municipalities,compared to municipalities in other states,are
quite dependant upon the sales tax. On average,Colorado municipalities derive nearly 73 percent of
their general purpose tax revenues from the sales tax. By comparison,municipalities in other
states derive over 51 percent of their general purpose tax revenues from the property tax,and only 28'
percent from sales and use taxes. Colorado has a fairly unusual sales tax system,in that home rule
municipalities are permitted to locally collect their sales taxes,as well as locally control their tax base
and tax rate(statutory municipalities in Colorado are permitted to set their own tax rate,and have
limited discretion with respect to certain tax base elements). This tax structure reflects Colorado's
traditional philosophy of"local control,"in which local governments provide a far greater share of
services than do municipalities in many states,and our revenue raising authority corresponds with this
responsibility.
On the other hand, although it acts as an extremely effective revenue raising mechanism for Colorado
municipalities,for retailers, Colorado's municipal tax system is widely regarded as one of the most
complex in the country. This complexity is particularly apparent for vendors that operate in multiple
jurisdictions,either because they have multiple fixed retail locations,or because they make deliveries
into multiple jurisdictions. These vendors are generally required to obtain a license from and
periodically remit tax directly to each jurisdiction in which they do business. Each of these
jurisdictions may have its own tax rate and vendors may be affected by variations between
jurisdictions in tax base(often due to varying tax exemptions or varying administrative interpretations
of ordinance language). Multi jurisdictional vendors must also be careful to correctly determine in
which jurisdiction they are making a delivery;if they fail to remit to the correct jurisdiction,they may
be subject to later assessment(this is where the address locator databases can help—more on that
later). Additionally,vendors are subject to audit by each of the Colorado home rule,locally collecting
municipalities in which they do business.
This makes the Colorado system different from the municipal sales tax systems of most other states. In
most states,(as is the case with statutory jurisdictions here in Colorado)the municipal sales tax is
i state-collected,using the state tax base,and"shared back"with the municipalities. Like Colorado,
many of these states permit local tax rate variation among state-collected jurisdictions. Colorado
retailers often complain about all of the various local requirements with which they must contend,
particularly in comparison with the tax systems in other states.
+ Being Proactive on Reasonable Tax Simplification
All of this puts Colorado municipalities in a delicate position. On the one hand,the sales tax is our
main revenue stream and we will fight,and have fought vigorously over the years,to protect the
critical aspects of our home rule authority associated with it. On the other hand,retailers are our
principal partner in collecting this tax,as it is levied on the customer,not the retailer.
Most thoughtful municipal officials acknowledge that we have a complicated tax system here in
Colorado,and agree that there's no reason that this system should be any more complicated than it
needs to be. We can defend essential complexity in the tax system;what we cannot defend is
unnecessary complexity, or an unwillingness to discuss potential solutions.Failure to address
reasonable tax simplification proposals is what coalitions in favor of eviscerating our tax authority are
formed around The League's philosophy over the years has thus been to actively support sales tax
simplification,so long as this can be done without jeopardizing the viability of the sales tax as our
principal revenue raising device.
The CML Sales Tax Simplification Committee is the principal forum in which home rule locally
collecting municipalities discuss sales tax simplification initiatives among themselves. We have to
agree among ourselves on any tax simplification measures that we decide to pursue. Fortunately,
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the General Assembly is constitutionally precluded from telling us how to run our tax systems;over
the years, we have had many occasions to be thankful for this fact. As described below,the address
locator project is the product of several years of work involving the Sales Tax Simplification
Committee,CCI,The Colorado Department of Revenue(DOR)and the business community.
Background on the Address Locator Project
Under Colorado's"point of use"tax system,multi jurisdictional vendors are required to collect tax on
behalf of the jurisdictions in which they do business,either at fixed locations or where they make
deliveries. A long-standing complaint of the business community,particularly in areas where
jurisdictional boundaries are changing or where taxing jurisdictions abut one another,is that vendors
find it exceedingly difficult to determine precisely in which taxing jurisdiction their delivery is made.
All sorts of problems result. Vendors remit to the wrong jurisdiction. The vendor is later assessed
following an audit and then finds that she is unable to secure a refund,the refund period having
elapsed. So(in the hard case)a vendor who in good faith tried to do the right thing ends up"paying
twice." Meanwhile,the municipalities involved bicker over who should get the money.
Informal discussions with municipal tax professionals and other interested parties(public and private)
beginning in 2003 revealed a broad consensus that this was a significant complexity for the business
community that we could do something about. Furthermore,unlike many other tax simplification
proposals,a solution to this problem could be implemented without a TABOR election and without
municipalities sacrificing tax revenue. Indeed,municipalities would benefit from receiving proper
remittance in the first instance,thereby being able to avoid forcing vendors to"pay twice"or having to
attempt to recover the money from the municipality that wrongfully received it.
Since 2003,several members of the CML Sales Tax Committee,Colorado Counties,Inc.,DOR and
representatives of the business community(including the Colorado Association of Commerce and
Industry,the Colorado Retail Council, Qwest,Xcel Energy and American Furniture Warehouse),have
been working to encourage use of "address locator"databases by multi jurisdictional vendors. These
databases would be certified by DOR as achieving a high degree of accuracy. Vendors relying on a
certified database would then be"held harmless"in an audit,if they remitted to the wrong jurisdiction
solely due to an error in the address locator database. The address locator project has been
unanimously endorsed by the CML Sales Tax Committee and CML's Executive Board.
During its 2004 session,the General Assembly approved HB 04-1237,which put this structure in place
at the state level. The legislation directed the Department of Revenue to develop regulations for
review and certification of address locator databases and provides that vendors utilizing a state
certified database would be held harmless as to state collected sales and use taxes(including those
levied by statutory municipalities).
During the interim between the 2004 and 2005 sessions of the General Assembly,League staff and
members of the Sales Tax Committee worked closely with DOR on the database certification
regulations. The working group agreed that it was not practical for the state certification process to
conduct individual field trials of each address locator database in each sales taxing jurisdiction in
Colorado. Consequently,our focus was to develop a certification process that tested database accuracy
on a sample of addresses that would provide an overall level of confidence to tax administrators and
their elected officials.
A priority of municipal representatives in the state rulemaking was assuring that,in addition to the
state's certification process,affected local governments could directly check addresses within their
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jurisdiction against a database. The rules make it a condition of certification that local governments be
afforded this opportunity,and further require that the database provider promptly make corrections to
its database as to any errors discovered. Indeed,the final regulations provide that addresses may be
tested against the database either individually or in batches.
The Next Phase:Municipal Ordinance Adoption
HB 04-1237 was the fast phase of a two-step process. In the second phase,similar"hold harmless"
protection will be provided by home rule municipalities that locally collect their sales taxes,for
vendors that utilize state certified address locator databases. It has been well understood that,for this
to occur,each home rule,locally collecting municipality will need to adopt an ordinance enacting the
"hold harmless"provision.
Denver is the state's largest locally collecting home Wile municipality,and like most other Colorado
home rule municipalities,it is heavily dependant upon sales tax revenues. Not surprisingly,therefore,
Denver has developed a reputation over the years of having its legal staff and its revenue managers
very highly focused on sales tax matters. For these reasons,we decided to work with Denver's
attorneys and tax professionals on a hold-harmless ordinance for Denver that could then serve as a
model for other home rule municipalities. The Denver City Council adopted the enclosed ordinance on
March 20,2006,and it was signed by the Mayor on March 21,2006.
The next step in the address locator project will be to secure adoption of ordinances functionally
I`
identical to the Denver ordinance in home rule,locally collecting municipalities.
i We would prefer that municipalities adopt an ordinance as close to the Denver model as possible;
however,I do want to highlight one aspect of the Denver ordinance that you may,or may not,wish to
include. Denver chose to include an automatic repealer in its ordinance,which requires the council to
revisit the address locator issue in 2008 and readopt the ordinance. This is fine;however,another
approach would be to simply leave the automatic repealer out of your ordinance. We have every
confidence that this program will work out just fine,and be a"win-win"for all concerned If,for
whatever reason,your municipality ever wishes to stop participating in this program,your municipality
can simply repeal its ordinance.
Your municipality's representative on the Sales Tax Committee will be the principal point of contact
within your municipality for information concerning this project. Of course,please feel free to call me
at the League or one of the following individuals for information concerning the operation of this
ordinance.
■ Laura Fisher,Revenue Officer,City of Boulder and Chair,CML Sales Tax
Simplification Committee:303.441.4017
■ Robin Peterson,Manager,Tax and Licensing,Aurora,303.739.7341.
i
a Lori Burns,Revenue Manager,City of Lakewood,303.987.7631.
How the Address Locator/Hold-harmless Ordinance will Affect your Municipality
' While incentivizing retailers to use address-locator databases and thus dramatically increasing the
likelihood that tax will be properly remitted to your municipality,the revenue loss possibility,due to
the hold-harmless provision,is small.
4
To illustrate, in order for a retailer to be held harmless for tax owed to your municipality under this
ordinance, all of the following must occur:
(a) Vendor makes a delivery into your municipality.
(b) Vendor uses a state certified database to locate the delivery address.
(c) There is an error in the database.
(d) Vendor fails to remit tax to your municipality solely because of the error in the
database.
(e) Your municipality selects this vendor for an audit.
(f) Vendor is able to prove reliance on the version of the database current at the time of
delivery.
(g) Result: Vendor is held harmless only for the tax owed on the particular transaction
affected by the error. For example,on a$2500.00 couch,a 3 percent local tax would
mean$75.00 in lost tax revenue to your municipality.
This combination of circumstances is unlikely to occur with any regularity. In the first place,the
databases certified by the State Department of Revenue are quite accurate. The Department of
Revenue's database certification rules require that the databases achieve a 95 percent accuracy
rate against the test sample;the accuracy of these databases is further borne out in tests run by
Denver and other municipalities. Furthermore,municipal tax professionals have the opportunity
check addresses within their jurisdiction against the databases for accuracy. This enables
municipalities to assure that particularly important"high tax"addresses(e.g.,construction sites or
newly annexed areas)are properly coded in the databases,to guard against potential loss of revenue.
Both the database providers and municipalities have a mutual interest in the accuracy of these
databases; it is expected that,over time,cooperation between database providers and municipal
officials will only enhance the already high degree of accuracy in these databases.
Attachments
In this packet you will find the following materials:
• A copy of the recently adopted City and County of Denver address locatorP'hold-harmless"
ordinance, to serve as a model for your jurisdiction.
• A list of the members of the CML Sales Tax Simplification Committee.
5�
ORDINANCE NO. 0541 2010
OF THE COUNCIL OF THE CITY OF FORT COLLINS
AMENDING CHAPTER 25 , ARTICLE III OF THE CODE OF THE
CITY OF FORT COLLINS CONCERNING SALES AND USE TAX
WHEREAS , under Article V, Section 22 of the City Charter, the Financial Officer is
responsible for collecting, receiving and disbursing all money belonging to the City; and
WHEREAS , in the past three years initiatives have been undertaken at the state level to
simplify tax collection in the State ; and
WHEREAS , in the past several years City staff has identified several areas of confusion in
the Code regarding definitions, waivers, and notice ; and
WHEREAS , the Financial Officer and the City Manager recommend that the City Code be
amended to allow for more simplified tax collection; and
WHEREAS, the City Council wishes to accept the recommendations of the Financial Officer
and the City Manager and adopt an ordinance to that effect.
NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF FORT
COLLINS, as follows
Section 1 . That the definition "Drugs dispensed in accordance with a prescription"
contained in Section 25 -71 of the Code of the City of Fort Collins is hereby amended to read as
follows :
Sec. 25-71 . Definitions.
Drugs dispensed in accordance with a prescription shall mean drugs dispensed
in accordance with any order in writing, dated and signed by a licensed practitioner
of the healing medicine, dentistry, optometry, or podiatry, or given orally by
such practitioner, and immediately reduced to writing, specifying the name and
address of the person for whom the medicine, drug or poison is offered and
directions, if any, to be placed on the label .
Section 2 . That Section 25 - 123 of the Code of the City of Fort Collins is hereby amended
by the addition of new subparagraphs (f) and (g) which read in their entirety as follows :
Sec. 25-123 . Remittance of sales tax collected by retailer.
(f) Any retailer that collects and remits sales tax to the Financial Officer as
provided in this Article may use an electronic database of state addresses that is
certified by the State Department of Revenue pursuant to § 39-26- 105 . 3 , C .R. S . , to
determine the jurisdictions to which tax is owed.
(g) Any retailer that uses the data contained in an electronic database certified
by the State Department of Revenue pursuant to § 39-26- 105 . 3 , C .R. S . , to determine
the jurisdictions to which tax is owed shall be held harmless for any tax, penalty, or
interest owed the City that otherwise would be due solely as a result of an error in
the electronic database, provided that the retailer demonstrates that it used the most
current information available in such electronic database on the date that the sale
occurred. Each retailer shall keep and preserve such records as prescribed by the
Financial Officer to demonstrate that it used the most current information available
in the electronic database on the date that the sale occurred. Notwithstanding the
above, if the error in collecting and remitting is a result of a deceptive or false
representation or fraud, the provisions of this Section shall not apply.
Section 3 . That Section 25 - 186 (b) of the Code of the City of Fort Collins is hereby amended
to read as follows :
Sec. 25-186. Failure to make return , estimate of taxes ; notices ; appeal; audit.
(b) The Financial Officer shall serve upon the delinquent taxpayer personally or
by first class mail, or certified mail, directed to the last address of the taxpayer on file
with the City written notice of such estimated taxes, penalty and interest. Such notice
shall constitute a notice of determination, assessment and demand for payment and
shall be due and payable within twenty (20) days from the date the notice is mailed.
Section 4 . That Section 25 -225 (d) of the Code of the City of Fort Collins is hereby
amended to read as follows :
Sec. 25-225. Limitations on actions to collect.
(d)
Financial Officer may a�;I %.T III Withlig to an extCmsion thereof, and the period so
agreed oii may be exteiided by subseqnctit agi-cenien1b) in maiiig made before the
-2 -
exrirafion of the previously agreed upon fitne . The ability to complete an audit will
not lapse , once the taxpayer has been notified of the audit period, until thirty (30)
days after the date of the notice of determination, assessment and demand for
payment issued as a result of such audit.
Introduced, considered favorably on first reading, and ordered published this 4th day of May,
A.D . 2010, and to be presented for final passage on the 18th day of May, A.D. 2010,
Mayor
ATTEST :
City Clerk
Passed and adopted on final reading on the 18th day of May, A.D . 2010 .
Mayor
ATTEST :
City Clerk
-3 -
ORDINANCE NO . 055 , 2010
OF THE COUNCIL OF THE CITY OF FORT COLLINS
AMENDING SECTION 25 -252 OF THE CODE OF THE CITY OF FORT COLLINS
RELATING TO THE VENDOR FEE FOR COLLECTING AND
REMITTING LODGING TAX
WHEREAS , Sections 25 -252(a), (e), and (f) of the City Code authorize lodging providers
to retain three percent of the amount of lodging tax they collect for the City (the "Vendor' s
Fee") ; and
WHEREAS , the Vendor' s Fee was originally adopted in recognition of the time and
effort expended by lodging providers to collect the City ' s lodging tax from their customers ; and
WHEREAS , current business practices include automated accounting processes that have
significantly reduced the time lodging providers need to invest in collecting the City ' s lodging
tax; and
WHEREAS , the total amount currently retained by lodging providers is approximately
$25 ,000 per year; and
WHEREAS , the loss of this amount of lodging tax revenues has a negative effect on the
City and its citizens given the recent budget constraints ; and
WHEREAS , the City incurs an administrative expense of approximately $5 ,000 per year
associated with monitoring the Vendor' s Fee and eliminating the Vendor' s Fee would eliminate
that expense; and
WHEREAS , the City Council believes it to be in the best interests of the City to
eliminate the Vendor' s Fee and to utilize the resulting savings to help defray City expenses.
NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF
FORT COLLINS as follows :
Section 1 . That Sections 25 -252(a), (e), and (f) of the City Code are hereby amended
to read as follows :
Sec . 25-252 . Payment of tax.
(a) Every lodging provider shall be liable and responsible for the payment of
an amount equal to three (3) percent of all proceeds derived from the providing of
lodging accommodations as established pursuant to § 25 -242 and any such
lodging provider shall file a return each month with the Financial Officer on or
before the twentieth day of each month for the preceding month and remit any
amount equivalent to the lodging tax collected to the Financial Officer.
by stich lodging piovidei -ander this Article to cover the expense Of Collection and
remittance of the tax.
(e) The lodging provider shall be entitled, as collecting agent of the eity, to
apply and credit thTee (3 ) percent of the amount of tax collected purstrant to (a)
abovc, rcmitting cxcess of collections over that aniount, together with the taxes
due� to tile Financial Officer in the lodging provider's next monthly lodging ta
rctmn,
(f) No person other than the City may take enrichment from the collection or
payment of such tax or from liability for payment of the full amount of the tax as
levied by § 25 -242 .
Section 2 . That this Ordinance shall become effective on July 1 , 2010 .
Introduced, considered favorably on first reading, and ordered published this 4th day of
May, A.D . 2010, and to be presented for final passage on the 18th day of May, A. D . 2010 .
Mayor
ATTEST :
City Clerk
Passed and adopted on final reading on the 18th day of May, A.D . 2010 .
Mayor
ATTEST :
City Clerk