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Carol Huller

Managing Director

Ms. Carol Huller began her career in arbitrage rebate as a Financial Analyst at Public Financial Management, LLC, before the formation of ACS. Ms. Huller manages the accounting department at ACS; she oversees all client rebate calculations, provides technical training for ACS personnel and coordinates calculation work flow, quality control and professional development.  During her tenure, Ms. Huller has completed more than 12,500 complex arbitrage calculations with par values above $157 billion; reviewed over 7,500 calculations and has a 100% success rate in responding to IRS audit inquiries in favor of the client.  

When ACS takes over the calculation process from another arbitrage firm, Ms. Huller analyzes prior calculations and provides the client with recommendations regarding corrections and alternative methods that can be employed to optimize the prior provider’s calculation and reduce our client’s liability amount.  Ms. Huller has discovered material errors in prior calculations which has led to millions of dollars in reduced client arbitrage payments. 

Ms. Huller is known amongst her clients as being readily available to their inquiries and requests for assistance. For example, an existing water authority client undergoing an Internal Revenue Service audit attested to her attentiveness:

We would never have anyone else do our rebate calculations for us … we think very highly of [Ms. Huller] and [she is] always there for us; like now, we are undergoing this IRS audit… I have some questions, I call [Ms. Huller] and [she] immediately picks up the phone and addresses my questions, it doesn’t take a day or even hours for [Ms. Huller] to get back to me.

Due to Ms. Huller’s extensive knowledge and experience, she has served as an instructor on the topic of arbitrage rebate compliance at Government Finance Officers Association, Association of School Business Officials and Association of Public Treasurers conferences throughout the country.  Ms. Huller is also a member of the National Bond Lawyers Association.


Bachelor of Science Degree

Areas of Expertise:

Bond Year Slicing   |   Commingled Funds   |   Hedges   |   Rebate Minimization                 Cascading Transferred Proceeds   |   Common Reserve Allocations   |   IRS Audit Defense SWAP Transactions   |   Cash Flow Modeling   |   Derivatives   |   Pooled Financing       Universal Cap   |   Large Debt Portfolios   |   State Authorities