Loading...
HomeMy WebLinkAbout05-065 - ADMIN Resolution - City Council - 2005/05/02RESOLUTION NO. 05-065 A RESOLUTION AWARDING THE SALE OF $2,370,000 GENERAL OBLIGATION TAX INCREMENT REFUNDING BONDS, SERIES 2005B; FIXING THEIR FORM AND SPECIFICATIONS; DIRECTING THEIR EXECUTION AND DELIVERY; PROVIDING FOR THEIR PAYMENT; PROVIDING FOR THE ESCROWING AND INVESTMENT OF THE PROCEEDS THEREOF; AND PROVIDING FOR THE REDEMPTION OF BONDS REFUNDED THEREBY BE IT RESOLVED By the City Council of the City of St. Louis Park, Hennepin County, Minnesota (the "City") as follows. Section 1 Sale of Bonds. 1.01. It is hereby determined that: (a) the City has duly established the following project areas and tax increment districts: (i) Excelsior Boulevard Redevelopment Project, (ii) Oak Park Village Redevelopment Project; and (iii) the Highway 7 Development Distnct (collectively referred to herein as the "Distncts") pursuant to Minnesota Statutes, Sections 469.001 through 469 047, Chapter 472A, and Sections 469.174 to 469.179 and predecessor statutes (Act); (b) the control, authonty and operation of the Distncts were transferred to the St. Louis Park Economic Development Authonty (Authority) by Resolution No. 88-134 of the City, pursuant to Minnesota Statutes, Section 469.094; and (c) by Resolution No. 90-4 of the Authority and Resolution No 90-29 of the City, the geographical areas of the project areas associated with the Districts were expanded and joined (such expanded coterminous area is referred to herein as the "Project Area"); and (d) the City is authorized by Section 469.178 of the TIF Act to issue and sell its general obligations to pay all or a portion of the public development and redevelopment costs (Costs) related to the Project Area as identified in the redevelopment plan and program and tax increment financing plan (Plans) for the Districts; (e) the City is authorized by the provisions of Minnesota Statutes, Chapter 475 (the "Act") and Section 475.67, Subdivision 13 of the Act and its home rule charter to issue and sell its general obligation bonds to refund outstanding bonds when determined by the City Council to be necessary and desirable; (f) it is necessary and desirable that the City issue approximately $2,470,000 General Obligation Tax Increment Refunding Bonds, Senes 2005B (the "Bonds") to refund in advance of maturity and at their redemption date, certain outstanding general obligations of the City; the proceeds of which have been (g) the outstanding bonds to be refunded (the "Refunded Bonds") consist of the $7,000,000 General Obligation Tax Increment Bonds, Senes 1997A, dated May 1, 1997, of which $2,435,000 in pnncipal amount is callable on February 1, 2006. Resolution No. 05-065 -2- (h) the Mayor and City Manager are authonzed and directed to execute a Tax Increment Pledge Agreement between the City and the Authonty (Pledge Agreement) in substantially the form on file in City Hall, pursuant to which the Authonty pledges certain Available Tax Increment (as defined in the Pledge Agreement) to pay principal of and interest on the Bonds. 1.02. The proposal of Legg Mason Wood Walker, Inc. (the "Purchaser") to purchase $2,370,000 General Obligation Tax Increment Refunding Bonds, Senes 2005B (the "Bonds") of the City described in the Official Terms of Proposal thereof is determined to be a reasonable offer and is accepted, the proposal being to purchase the Bonds at a pnce of $2,493,914.54 plus accrued interest to date of delivery, for Bonds beanng interest as follows: Year 2007 2008 True interest cost: 2.9692% Interest Rate 5.00% 5.00% Year 2009 Interest Rate 5.00% 1.03. The sum of $14,220 being the amount proposed by the Purchaser in excess of $2,355,780 is credited to the Escrow Account hereinafter created, or designated to pay costs of issuance of the Bonds, as may be recommended by the financial advisors to the City. The City Finance Director is directed to retain the good faith check of the Purchaser, pending completion of the sale of the Bonds, and to return the good faith checks of the unsuccessful proposers forthwith The Mayor and City Manager are directed to execute a contract with the Purchaser on behalf of the City. 1.04. The City will forthwith issue and sell the Bonds pursuant to Minnesota Statutes, Chapter 475 (the "Act") in the total pnncipal amount of $2,370,000, onginally dated May 25, 2005, in the denomination of $5,000 each or any integral multiple thereof, numbered No. R-1, upward, bearing interest as above set forth, and matunng senally on February 1 without option of pnor payment in the years and amounts as follows: Year Amount Year Amount 2007 $755,000 2009 $825,000 2008 790,000 Section 2. Registration and Payment. 2.01. Registered Form. The Bonds will be issued only in fully registered form. The interest thereon and, upon surrender of each Bond, the pnncipal amount thereof, is payable by check or draft issued by the Registrar descnbed herein. 2.02. Dates; Interest Payment Dates. Each Bond will be dated as of the last interest payment date preceding the date of authentication to which interest on the Bond has been paid or made available for payment, unless (i) the date of authentication is an interest payment date to which interest has been paid or made available for payment, in which case the Bond will be dated as of the date of authentication, or (ii) the date of authentication is prior to the first interest payment date, in which case the Bond will be dated as of the date of onginal issue. The interest on the Bonds • o Resolution No. 05-065 -3- is payable on February 1 and August 1 of each year, commencing February 1, 2006, to the registered owners of record as of the close of business on the fifteenth day of the immediately preceding month, whether or not that day is a business day 2.03. Registration. The City appoints the City Finance Director as Bond Registrar, transfer agent and paying agent (the "Registrar"). The effect of registration and the nghts and duties of the City and the Registrar with respect thereto are as follows: (a) Register. The Registrar will keep a bond register in which the Registrar provides for the registration of ownership of Bonds and the registration of transfers and exchanges of Bonds entitled to be registered, transferred or exchanged. (b) Transfer of Bonds. Upon surrender for transfer of a Bond duly endorsed by the registered owner thereof or accompanied by a written instrument of transfer, in form satisfactory to the Registrar, duly executed by the registered owner thereof or by an attorney duly authonzed by the registered owner in wnting, the Registrar will deliver, in the name of the designated transferee or transferees, one or more new Bonds of a like aggregate pnncipal amount and matunty, as requested by the transferor. The Registrar may, however, close the books for registration of any transfer after the fifteenth day of the month preceding each interest payment date and until that interest payment date. (c) Exchange of Bonds. When Bonds are surrendered by the registered owner for exchange the Registrar will deliver one or more new Bonds of a like aggregate principal amount and maturity as requested by the registered owner or the owner's attorney in writing. (d) Cancellation. Bonds surrendered upon transfer or exchange will be promptly cancelled by the Registrar and thereafter disposed of as directed by the City. (e) Improper or Unauthorized Transfer. When a Bond is presented to the Registrar for transfer, the Registrar may refuse to transfer the Bond until the Registrar is satisfied that the endorsement on the Bond or separate instrument of transfer is valid and genuine and that the requested transfer is legally authonzed. The Registrar will incur no liability for the refusal, in good faith, to make transfers which it, in its judgment, deems improper or unauthonzed. (f) Persons Deemed Owners. The City and the Registrar may treat the person in whose name a Bond is registered in the bond register as the absolute owner of the Bond, whether the Bond is overdue or not, for the purpose of receiving payment of, or on account of, the pnncipal of and interest on the Bond and for all other purposes, and payments so made to a registered owner or upon the owner's order will be valid and effectual to satisfy and discharge the liability upon the Bond to the extent of the sum or sums so paid. (g) Taxes, Fees and Charges. The Registrar may impose a charge upon the owner thereof for a transfer or exchange of Bonds sufficient to reimburse the Registrar for any tax, fee or other governmental charge required to be paid with respect to the transfer or exchange. Resolution No. 05-065 -4- (h) Mutilated, Lost, Stolen or Destroyed Bonds. If a Bond becomes mutilated or is destroyed, stolen or lost, the Registrar will deliver a new Bond of like amount, number, maturity date and tenor in exchange and substitution for and upon cancellation of the mutilated Bond or in lieu of and in substitution for any Bond destroyed, stolen or lost, upon the payment of the reasonable expenses and charges of the Registrar in connection therewith; and, in the case of a Bond destroyed, stolen or lost, upon filing with the Registrar of evidence satisfactory to it that the Bond was destroyed, stolen or lost, and of the ownership thereof, and upon furnishing to the Registrar an appropnate bond or indemnity in form, substance and amount satisfactory to it and as provided by law, in which both the City and the Registrar must be named as obligees. Bonds so surrendered to the Registrar will be cancelled by the Registrar and evidence of such cancellation must be given to the City. If the mutilated, destroyed, stolen or lost Bond has already matured or been called for redemption in accordance with its terms it is not necessary to issue a new Bond pnor to payment. 2.04. Execution and Delivery. The Bonds will be prepared under the direction of the City Manager and executed on behalf of the City by the signatures of the Mayor and the City Manager, provided that those signatures may be pnnted, engraved or lithographed facsimiles of the originals. If an officer whose signature or a facsimile of whose signature appears on the Bonds ceases to be such officer before the delivery of a Bond, that signature or facsimile will nevertheless be valid and sufficient for all purposes, the same as if the officer had remained in office until delivery. When the Bonds have been so prepared and executed, the City Manager will deliver the same to the Purchaser upon payment of the purchase pnce in accordance with the contract of sale heretofore made and executed, and the Purchaser is not obligated to see to the application of the purchase pnce. 2.06. Temporary Bonds. The City may elect to deliver in lieu of pnnted definitive Bonds one or more typewntten temporary Bonds in substantially the form set forth in Section 3 with such changes as may be necessary to reflect more than one maturity in a single temporary bond. Upon the execution and delivery of definitive Bonds the temporary Bonds will be exchanged therefor and cancelled. Section 3. Form of Bond. 3.01. The Bonds will be pnnted or typewritten in substantially the following form: No. R- UNITED STATES OF AMERICA $ STATE OF MINNESOTA COUNTY OF HENNEPIN CITY OF ST. LOUIS PARK GENERAL OBLIGATION TAX INCREMENT REFUNDING BOND, SERIES 2005B Rate Matunty Date of Original Issue , 20_ May 25, 2005 Registered Owner: Cede & Co. CUSIP 0 0 Resolution No. 05-065 ' -5- The City of St. Louis Park, Minnesota, a duly organized and existing municipal corporation in Hennepin County, Minnesota (the "City"), acknowledges itself to be indebted and for value received promises to pay to the Registered Owner specified above or registered assigns, the principal sum of $2,370,000 on the matunty date specified above without option of pnor payment, with interest thereon from the date hereof at the annual rate specified above, payable February 1 and August 1 in each year, commencing February 1, 2006, to the person in whose name this Bond is registered at the close of business on the fifteenth day (whether or not a business day) of the immediately preceding month. The interest hereon and, upbn presentation and surrender hereof, the pnncipal hereof are payable in lawful money of the United States of Amenca by check or draft by the Finance Director of the City of St. Louis Park, Minnesota, as Bond Registrar, Paying Agent and Transfer Agent, or its designated successor under the Resolution described herein. For the prompt and full payment of such pnncipal and interest as the same respectively become due, the full faith and credit and taxing powers of the City have been and are hereby irrevocably pledged. The City Council has designated the issue of Bonds of which this Bond forms a part as "qualified tax exempt obligations" within the meaning of Section 265(b)(3) of the Internal Revenue Code of 1986, as amended (the "Code") relating to disallowance of interest expense for financial institutions and within the $10 million limit allowed by the Code for the calendar year of issue. This Bond is one of an issue in the aggregate principal amount of $2,370,000 all of like onginal issue date and tenor, except as to number, matunty date, and interest rate, all issued .: pursuant to a resolution adopted by the City Council on May 2, 2005 (the "Resolution"), for the purpose of providing money to refund in advance of matunty and on the Redemption Date, as defined in the Resolution, a portion of certain general obligation bonds of the City, pursuant to and in full conformity with the home rule charter of the City and the Constitution and laws of the State of Minnesota, including Minnesota Statutes, Sections 475.67, Subdivision 13. The interest hereon is payable until the Redemption Date, pnmanly out of the Escrow Account and Debt Service Account in the City's Tax Increment Refunding Bonds, Senes 2005B Debt Service Fund and after the Redemption Date from tax increments resulting from increases in the taxable value of real property in certain tax increment financing distncts in the City as set forth in the Resolution to which reference is made for a full statement of rights and powers thereby conferred. The full faith and credit of the City are irrevocably pledged for payment of this Bond and the City Council has obligated itself to levy ad valorem taxes on all taxable property in the City in the event of any deficiency in tax increments pledged, which taxes may be levied without limitation as to rate or amount. The Bonds of this series are issued only as fully registered Bonds in denominations of $5,000 or any integral multiple thereof of single matunties. As provided in the Resolution and subject to certain limitations set forth therein, this Bond is transferable upon the books of the City at the pnncipal office of the Bond Registrar, by the registered owner hereof in person or by the owner's attorney duly authorized in wnting, upon surrender hereof together with a wntten instrument of transfer satisfactory to the Bond Registrar, duly executed by the registered owner or the owner's attorney; and may also be surrendered in exchange for Bonds of other authonzed denominations. Upon such transfer or exchange the City will cause a new Bond or Bonds to be issued in the name of the transferee or registered owner, of the same aggregate principal amount, bearing interest at the same rate and matunng on the same date, subject to reimbursement for any tax, fee or governmental charge required to be paid with respect to such transfer or exchange. ,,+r r 1;11J ,r+i Resolution No. 05-065 - -6- .4, , The City and the Bond Registrar may deem and treat the person in whose name this Bond is registered as the absolute owner hereof, whether this Bond is overdue or not, for the purpose of receiving payment and for all other purposes, and neither the City nor the Bond Registrar will be affected by any notice to the contrary. IT IS HEREBY CERTIFIED, RECITED, COVENANTED AND AGREED that all acts, conditions and things required by the home rule charter of the City and the Constitution and laws of the State of Minnesota to be done, to exist, to happen and to be performed preliminary to and in the issuance of this Bond in order to make it a valid and binding general obligation of the City in accordance with its terms, have been done, do exist, have happened and have been performed as so required, and that the issuance of this Bond does not cause the indebtedness of the City to exceed any constitutional, statutory or charter limitation of indebtedness. This Bond is not valid or obligatory for any purpose or entitled to any security or benefit under the Resolution until the Certificate of Authentication hereon has been executed by the Bond Registrar by manual signature of one of its authonzed representatives. IN WITNESS WHEREOF, the City of St. Louis Park, Hennepin County, Minnesota, by its City Council, has caused this Bond to be executed on its behalf by the facsimile or manual signatures of the Mayor and City Manager and has caused this Bond to be dated as of the date set forth below. Dated: CITY OF ST. LOUIS PARK, MINNESOTA (Facsimile) (Facsimile) City Manager Mayor The following abbreviations, when used in the inscnption on the face of this Bond, will be construed as though they were written out in full according to applicable laws or regulations: TEN COM -- as tenants in common UNIF GIFT MIN ACT Custodian (Cust) (Minor) TEN ENT -- as tenants under Uniform Gifts or by entireties Transfers to Minors JT TEN -- as Joint tenants with nght of survivorship and not as tenants in common Act... ..... (State) Additional abbreviations may also be used though not in the above list. 0 0 Resolution No. 05-065 -7- ASSIGNMENT For value received, the undersigned hereby sells, assigns and transfers unto the within Bond and all nghts thereunder, and does hereby irrevocably constitute and appoint attorney to transfer the said Bond on the books kept for registration of the within Bond, with full power of substitution in the premises Dated: Notice: The assignor's signature to this assignment must correspond with the name as it appears upon the face of the within Bond in every particular, without alteration or any change whatever. Signature Guaranteed: NOTICE: Signature(s) must be guaranteed by a financial institution that is a member of the Secunties Transfer Agent Medallion Program ("STAMP"), the Stock Exchange Medallion Program ("SEMP"), the New York Stock Exchange, Inc. Medallion Signatures Program ("MSP") or other such "signature guarantee program" as may be determined by the Registrar in addition to, or in substitution for, STAMP, SEMP or MSP, all in accordance with the Securities Exchange Act of 1934, as amended. The Bond Registrar will not effect transfer of this Bond unless the information concerning the assignee requested below is provided. Name and Address: (Include information for all point owners if this Bond is held by joint account.) Please insert social secunty or other identifying number of assignee PROVISIONS AS TO REGISTRATION ®The ownership of the pnncipal of and interest on the within Bond has been registered on the books of the Registrar in the name of the person last noted below. ,, a,, ty ,'; o. Resolution No. 05-065 -8- Date of Registration Signature of Registered Owner City Finance Director Cede & Co. Federal ID #13-2555119 fvk 3.02. The City Manager is authorized and directed to obtain a copy of the proposed approving legal opinion of Kennedy & Graven, Chartered, Minneapolis, Minnesota, which is to be complete except as to dating thereof and cause the opinion to be panted on or accompany each Bond. Section 4. Bonds; Security; Escrow. 4.01. Funds and Accounts. For the convenience and proper administration of the moneys to be borrowed and repaid on the Bonds and the Refunded Bonds (as defined in the resolution providing for the issuance and sale of the Bonds), and to provide adequate and specific secunty for the Purchaser and holders from time to time of the Bonds and Refunded Bonds, there is hereby created a special fund to be designated the Tax Increment Refunding Bonds, Senes 2005B Debt Service Fund (the "Fund") to be administered and maintained by the Finance Director as a bookkeeping account separate and apart from all other funds maintained in the official financial records of the City. The Fund will be maintained in the manner herein specified until all of the Refunded Bonds have been paid and until all of the Bonds and the interest thereon will have been fully paid. There will be maintained in the Fund two separate accounts, to be designated the Escrow Account and Debt Service Account. (a) Escrow Account. The Escrow Account will be maintained as an Escrow Account (the "Escrow Account") with U.S. Bank National Association, in St. Paul, Minnesota, which is a suitable financial institution within the State, whose deposits are insured by the Federal Deposit Insurance Corporation, whose combined capital and surplus is not less than $500,000 and said financial institution is hereby designated escrow agent (the "Escrow Agent") for the Escrow Account. All proceeds of the sale of the Bonds will be received by the Escrow Agent and applied to fund the Escrow Account or to pay costs of issuing the Bonds. Proceeds of the Bonds not used to pay costs of issuance are hereby irrevocably pledged and appropnated to the Escrow Account, together with all investment earnings thereon. The Escrow Account will be invested in secunties matunng or callable at the option of the holder on such dates and bearing interest at such rates as will be required to provide sufficient funds, together with any cash or other funds retained in the Escrow Account, to pay when due the interest to accrue on each Bond to and including February 1, 2006 (the "Redemption Date"), and to pay when due on the Redemption Date the pnncipal amount of each of the Refunded Bonds then outstanding. From the Escrow Account there will be paid (i) all interest paid on, or to be paid on, or to accrue on, the Bonds to and including the Redemption Date, and (rr) the principal of the Refunded Bonds due by reason of redemption on the Redemption Date. The Escrow Account will be irrevocably appropnated to the payment of the pnncipal of and interest on the Bonds until the proceeds of the Bonds therein are applied to prepayment of the Refunded Bonds. The moneys in the Escrow Account will be used solely for the purposes herein set forth and for no other purpose, except that any surplus in the Escrow Account may be remitted to the City, all in accordance with the Escrow Agreement (hereafter defined) by and between the City and the Escrow Agent. Any moneys remitted to the City upon termination of the Escrow Agreement will be deposited in the Debt Service Account. C Resolution No. 05-065 -9- (b) Debt Service Account. To the Debt Service Account there is hereby pledged and irrevocably appropnated and there will be credited. (i) any balance remitted to the City upon the termination of the Escrow Agreement; (ii) any balance remaining on February 2, 2006, in the Debt Service Fund created by the City Council resolution authonzing the issuance and sale of the Refunded Bonds (the "Pnor Resolution"), (iii) any collections of all taxes hereafter levied for the payment of the Bonds and interest thereon; (iv) all investment earnings on funds in the Debt Service Account; (v)tafter the Redemption Date, all Available Tax Increment (as defined in the Pledge Agreement) received by the City from the Authority pursuant to the Pledge Agreement; (vi) accrued interest (if any) received upon delivery of the Bonds, to the extent not required to fund the Escrow Account; and (vii) any and all other moneys which are properly available and are appropnated by the City Council to the Debt Service Account. The amount of any surplus remaining in the Debt Service Account when the Bonds and interest thereon are paid will be used as provided in Section 475.61, Subdivision 4 of the Act. 4.02. Findings. It is hereby found and determined that based upon information presently available from the City's financial advisers, the issuance of the Bonds will result in a reduction of debt service cost to the City on the Refunded Bonds, such that the present value of such debt service or interest cost savings (the "Reduction") is 3 254% of the debt service on the Refunded Bonds. The Reduction, after the inclusion of all authonzed expenses of refunding in the computation of the effective interest rate on the Bonds, is adequate to authorize the issuance of the Bonds as provided by Minnesota Statutes, Section 475 67, Subdivisions 12 and 13. 4.03. The moneys in the Debt Service Account will be used solely to pay the pnncipal of and interest on the Bonds or any other bonds hereafter issued and made payable from the Fund. No portion of the proceeds of the Bonds will be used directly or indirectly to acquire higher yielding investments or to replace funds which were used directly or indirectly to acquire higher yielding investments, except (i) for a reasonable temporary penod until such proceeds are needed for the purpose for which the Bonds were issued, and (ii) in addition to the above, in an amount not greater than the lesser of five percent of the proceeds of the Bonds or $100,000. To this effect, any proceeds of the Bonds and any sums from time to time held in the Fund (or any other City account which will be used to pay pnncipal and interest to become due on the Bonds) in excess of amounts which under the applicable federal arbitrage regulations may be invested without regard as to yield will not be invested at a yield in excess of the applicable yield restrictions imposed by the arbitrage regulations on such investments after taking into account any applicable temporary penods or minor portion made available under the federal arbitrage regulations. In addition, the proceeds of the Bonds and money in the Fund will not be invested in obligations or deposits issued by, guaranteed by or insured by the United States or any agency or instrumentality thereof if and to the extent that such investment would cause the Bonds to be federally guaranteed within the meaning of Section 149(b) of the Internal Revenue Code of 1986, as amended (the "Code"). 4.04. General Obligation Pledge. For the prompt and full payment of the pnncipal and interest on the Bonds, as the same respectively become due, the full faith, credit and taxing powers of the City will be and are hereby irrevocably pledged. If the balance in the Escrow Account or Debt Service Account is ever insufficient to pay all pnncipal and interest then due on the Bonds and any other bonds payable therefrom, the deficiency will be promptly paid out of monies in the general fund of the City which are available for such purpose, and such general fund may be reimbursed with or without interest from the Escrow Account or Debt Service Account when a sufficient balance is available therein. Resolution No. 05-065 -10- °r. 4.05. It is determined that estimated collection of tax increments for the payment of principal and interest on the Bonds after the Redemption Date will produce at least five percent in excess of the amount needed to meet when due, the pnncipal and interest payments on the Bonds matunng after the Redemption Date, and that no tax levy is needed at this time. 4.06. Filing. The City Manager is authorized and directed to file a certified copy of this resolution with the Taxpayer Services Division Manager of Hennepin County and to obtain the certificate required by Section 475.63 of the Act. Section 5. Refunding; Findings; Redemption of Refunded Bonds. 5.01. As of the date of delivery of and payment for the Bonds proceeds of the Bonds in the amount of $2,467,323.00 including amounts used to pay costs of issuance) (the "Proceeds"), are hereby pledged and appropnated and will be deposited in the Escrow Account. 5.02. It is hereby found and determined that the Proceeds available and appropnated to the Escrow Account will be sufficient, together with the permitted earnings on the investment of the Escrow Account, to pay pnncipal of and interest on the Bonds through the Redemption Date, and to pay at maturity or redemption all of the pnncipal of and redemption premium (if any) on the Refunded Bonds. 5.03. Secunties purchased from the monies in the Escrow Account will be limited to secunties specified in Section 475.67, Subdivision 8 of the Act. Ehlers & Associates, Inc., as agent for the City of St. Louis Park is hereby authorized and directed to purchase for and on behalf of the City of St. Louis Park and in its name, appropnate secunties to fund the Escrow Account. Upon the issuance and delivery of the Bonds, the secunties so purchased will be deposited with the Escrow Agent and held pursuant to the terms of the Escrow Agreement and the Resolution. 5.04. The Refunded Bonds matunng on February 1, 2006 and thereafter will be redeemed and prepaid on the Redemption Date. The Refunded Bonds will be redeemed and prepaid in accordance with their terms and in accordance with the terms and conditions set forth in the form of Notice of Call for Redemption attached hereto as Attachment A which terms and conditions are hereby approved and incorporated herein by reference. The Registrar for the Refunded Bonds is authonzed and directed to send a copy of the Notice of Redemption to each registered holder of the Refunded Bonds. 5.05. Escrow Agreement. On or prior to the delivery of the Refunding Bonds, the Mayor and the City Manager are hereby authorized and directed to execute on behalf of the City an escrow agreement (the "Escrow Agreement") with the Escrow Agent in substantially the form now on file with the City Manager. All essential terms and conditions of the Escrow Agreement including payment by the City of reasonable charges for the services of the Escrow Agent, are hereby approved and adopted and made a part of this resolution, and the City covenants that it will promptly enforce all provisions thereof in the event of default thereunder by the Escrow Agent. Section 6. Authentication of Transcript 6.01. The officers of the City are authorized and directed to prepare and furnish to the Purchaser and to the attorneys approving the Bonds, certified copies of proceedings and records of the City relating to the Bonds and to the financial condition and affairs of the City, and such other • Resolution No. 05-065 -11- certificates, affidavits and transcnpts as may be required to show the facts within their knowledge or as shown by the books and records in their custody and under their control, relating to the validity and marketability of the Bonds, and such instruments, including any heretofore furnished, will be deemed representations of the City as to the facts stated therein. qi 6.02. The Mayor, City Manager and Finance Director are hereby authorized and directed to certify that they have examined the Official Statement prepared and circulated in connection with the issuance and sale of the Bonds and that to the best of their knowledge and belief the Official Statement is a complete and accurate representation of the facts and representations made therein as of the date of the Official Statement. Section 7. Tax Covenant. 7.01. The City covenants and agrees with the holders from time to time of the Bonds that it will not take or permit to be taken by any of its officers, employees or agents any action which would cause the interest on the Bonds to become subject to taxation under the Internal Revenue Code of 1986, as amended (the "Code"), and the Treasury Regulations promulgated thereunder, in effect at the time of such actions, and that it will take or cause its officers, employees or agents to take, all affirmative action within its power that may be necessary to ensure that such interest will not become subject to taxation under the Code and applicable Treasury Regulations, as presently existing or as hereafter amended and made applicable to the Bonds. 7 02 The City will comply with requirements necessary under the Code to establish and maintain the exclusion from gross income of the interest on the Bonds under Section 103 of the Code, including without limitation requirements relating to temporary penods for investments, limitations on amounts invested at a yield greater than the yield on the Bonds, and the rebate of excess investment earnings to the United States 7.03. The City further covenants not to use the proceeds of the Bonds or to cause or permit them or any of them to be used, in such a manner as to cause the Bonds to be "private activity bonds" within the meaning of Sections 103 and 141 through 150 of the Code. 7.04. In order to qualify the Bonds as "qualified tax-exempt obligations" within the meaning of Section 265(b)(3) of the Code, the City makes the following factual statements and representations: (a) the Bonds are not "pnvate activity bonds" as defined in Section 141 of the Code; (b) the City hereby designates the Bonds as "qualified tax-exempt obligations" for purposes of Section 265(b)(3) of the Code; (c) the reasonably anticipated amount of tax-exempt obligations (other than pnvate activity bonds, that are not qualified 501(c)(3) bonds) which will be issued by the City (and all subordinate entities of the City) during calendar year 2005 will not exceed $10,000,000; and (d) not more than $10,000,000 of obligations issued by the City dunng calendar year 2005 have been designated for purposes of Section 265(b)(3) of the Code. Resolution No. 05-065 r -12- 7.05. The City will use its best efforts to comply with any federal procedural requirements which may apply in order to effectuate the designations made by this section. Section 8. Book -Entry System; Limited Obligation of City. 8.01. The Bonds will be initially issued in the form of a separate single typewntten or printed fully registered Bond for each of the matunties set forth in Section 1.03 hereof. Upon initial issuance, the ownership of each such Bond will be registered in the registration books kept by the Bond Registrar in the name of Cede & Co., as nominee for The Depository Trust Company, New York, New York, and its successors and assigns ("DTC"). Except as provided in this section, all of the outstanding Bonds will be registered in the registration books kept by the Bond Registrar in the name of Cede & Co., as nominee of DTC. 8.02. With respect to Bonds registered in the registration books kept by the Bond Registrar in the name of Cede & Co., as nominee of DTC, the City, the Bond Registrar and the Paying Agent will have no responsibility or obligation to any broker dealers, banks and other financial institutions from time to time for which DTC holds Bonds as secunties depository (the "Participants") or to any other person on behalf of which a Participant holds an interest in the Bonds, including but not limited to any responsibility or obligation with respect to (i) the accuracy of the records of DTC, Cede & Co. or any Participant with respect to any ownership interest in the Bonds, (n) the delivery to any Participant or any other person (other than a registered owner of Bonds, as shown by the registration books kept by the Bond Registrar), of any notice with respect to the Bonds, including any notice of redemption, or (iii) the payment to any Participant or any other person, other than a registered owner of Bonds, of any amount with respect to pnncipal of, premium, if any, or interest on the Bonds. The City, the Bond Registrar and the Paying Agent may treat and consider the person in whose name each Bond is registered in the registration books kept by the Bond Registrar as the holder and absolute owner of such Bond for the purpose of payment of principal, premium and interest with respect to such Bond, for the purpose of registenng transfers with respect to such Bonds, and for all other purposes. The Paying Agent will pay all pnncipal of, premium, if any, and interest on the Bonds only to or on the order of the respective registered owners, as shown in the registration books kept by the Bond Registrar, and all such payments will be valid and effectual to fully satisfy and discharge the City's obligations with respect to payment of principal of, premium, if any, or interest on the Bonds to the extent of the sum or sums so paid. No person other than a registered owner of Bonds, as shown in the registration books kept by the Bond Registrar, will receive a certificated Bond evidencing the obligation of this resolution. Upon delivery by DTC to the City Manager of a wntten notice to the effect that DTC has determined to substitute a new nominee in place of Cede & Co., the words "Cede & Co.," will refer to such new nominee of DTC; and upon receipt of such a notice, the City Manager will promptly deliver a copy of the same to the Bond Registrar and Paying Agent. 8.03. Representation Letter. The City has heretofore executed and delivered to DTC a Blanket Issuer Letter of Representations (the "Representation Letter") which will govern payment of pnncipal of, premium, if any, and interest on the Bonds and notices with respect to the Bonds. Any Paying Agent or Bond Registrar subsequently appointed by the City with respect to the Bonds will agree to take all action necessary for all representations of the City in the Representation letter with respect to the Bond Registrar and Paying Agent, respectively, to be complied with at all times. Resolution No 05-065 -13- 8.04. Transfers Outside Book -Entry System. In the event the City, by resolution of the City Council, determines that it is in the best interests of the persons having beneficial interest, in the Bonds that they be able to obtain Bond certificates, the City will notify DTC, whereupon DTC will notify the Participants, of the availability through DTC of Bond certificates. In such event the City will issue, transfer and exchange Bond certificates as requested by DTC and any other registered owners in accordance with the provisions of this Resolution. DTC may determine to discontinue providing its services with respect to the Bonds at any time by giving notice to the City and discharging its responsibilities with respect thereto under applicable law. In such event, if no successor securities depository is appointed, the City will issue and the Bond Registrar will authenticate Bond certificates in accordance with this resolution and the provisions hereof will apply to the transfer, exchange and method of payment thereof. 8.05. Payments to Cede & Co. Notwithstanding any other provision of this Resolution to the contrary, so long as a Bond is registered in the name of Cede & Co., as nominee of DTC, payments with respect to principal of, premium, if any, and interest on the Bond and notices with respect to the Bond will be made and given, respectively in the manner provided in DTC's Operational Arrangements, as set forth in the Representation Letter. Section 9. Continuing Disclosure. 9.01 The City hereby covenants and agrees that it will comply with and carry out all of the provisions of the Continuing Disclosure Certificate Notwithstanding any other provision of this Resolution, failure of the City to comply with the Continuing Disclosure Certificate will not be considered an event of default with respect to the Bonds, however, any Bondholder may take such actions as may be necessary and appropnate, including seeking mandate or specific performance by court order, to cause the City to comply with its obligations under this section. 9 02 "Continuing Disclosure Certificate" means that certain Continuing Disclosure Certificate executed by the Mayor and City Manager and dated the date of issuance and delivery of the Bonds, as onginally executed and as it may be amended from time to time in accordance with the terms thereof. Section 10. Defeasance. When all Bonds and all interest thereon, have been discharged as provided in this section, all pledges, covenants and other nghts granted by this resolution to the holders of the Bonds will cease, except that the pledge of the full faith and credit of the City for the prompt and full payment of the principal of and interest on the Bonds will remain in full force and effect. The City may discharge all Bonds which are due on any date by depositing with the Registrar on or before that date a sum sufficient for the payment thereof in full. If any Bond should not be paid when due, it may nevertheless be discharged by depositing with the Registrar a sum sufficient for the payment thereof in full with interest accrued to the date of such deposit. The motion for the adoption of the foregoing resolution was duly seconded by Member Sanger, and upon vote being taken thereon, the following voted in favor thereof: Jacobs, Basill, Finkelstein, Omodt, Sanger, Santa, Velick and the following voted against the same: None whereupon said resolution was declared duly passed and adopted. Resolution Reviewed fo City Manager Attest: rze_....2,,J--____6— Ci Clerk 261760V1 (SJB) 1, 1 -14- Ilied by the CI Council May 2, 2005 May