HomeMy WebLinkAbout22-080 - ADMIN Resolution - City Council - 2022/05/16Resolution No. 22-080
Resolution authorizing the issuance of multifamily housing revenue
notes for the benefit of St. Louis Park AH I, LLLP; approving a housing
program; and authorizing the execution of related documents
Be it resolved by the City Council (the “City Council”) of the City of St. Louis Park,
Hennepin County, Minnesota (the “City”) as follows:
Section 1. Recitals.
1.01. Pursuant to Minnesota Statutes, Chapter 462C, as amended (the “Housing Act”),
the City is authorized to carry out the public purposes described in the Housing Act by providing
for the issuance of revenue obligations to provide funds to finance multifamily housing
developments located within the City.
1.02. St. Louis Park AH I, LLLP, a Minnesota limited liability limited partnership (the
“Borrower”), has proposed that the City issue one or more series of taxable or tax-exempt
revenue obligations (the “Notes”) in an estimated aggregate principal amount not to exceed
$27,990,550 for the benefit of the Borrower for the purposes of (i) financing the acquisition,
construction, and equipping of an approximately 114-unit multifamily housing development for
occupancy by persons of low and moderate income and facilities functionally related and
subordinate thereto to be located at 3801 Wooddale Avenue South in the City (the “Project”),
which will be owned and operated by the Borrower; (ii) funding any required reserve funds;
(iii) financing capitalized interest during the construction of the Project, if necessary; and
(iv) paying the costs of issuing the Notes.
1.03. On December 6, 2021, the City Council adopted a resolution authorizing the
submission of an application to the office of Minnesota Management and Budget for an
allocation of bonding authority with respect to the Notes to finance the Project in accordance
with the requirements of Minnesota Statutes, Chapter 474A, as amended (the “Allocation Act”),
and providing preliminary approval for the sale and issuance of the Notes for the Project.
1.04. On January 11, 2022, the City received Certificate of Allocation No. 425 from the
Minnesota Department of Management and Budget allocating bonding authority to the City in
the amount of $17,490,550 from the State of Minnesota (the “State”), pursuant to the
Allocation Act.
1.05. Section 146(i)(6) of the Internal Revenue Code of 1986, as amended (the
“Code”), permits the reuse of bonding authority for affordable housing projects and treats the
reuse as a refunding for tax purposes if: (i) the “refunding” occurs within four (4) years after the
original bonds were issued, (ii) the “refunding” bonds are issued within six (6) months after the
principal payment of the original bonds, and (iii) the “refunding” bonds mature within thirty-
four (34) years of the original issue date.
1.06. Minnesota Statutes, Section 471.656, as amended, authorizes a municipality to
issue obligations to finance the acquisition or improvement of property located outside of the
corporate boundaries of such municipality if the obligations are issued under a joi nt powers
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Resolution No. 22-080 2
agreement between the municipality issuing the obligations and the municipality in which the
property to be acquired or improved is located. Pursuant to Minnesota Statutes,
Section 471.59, as amended, by the terms of a joint powers agreement entered into through
action of their governing bodies, two municipalities may jointly or cooperatively exercise any
power common to the contracting parties or any similar powers, including those which are the
same except for the territorial limits within which they may be exercised and the joint powers
agreement may provide for the exercise of such powers by one or more of the participating
governmental units on behalf of the other participating units.
1.07. The Borrower has represented to the City that the Notes will meet the
requirements of Section 146(i)(6) of the Code with respect to the reuse of a portion of the
bonding authority from the Multifamily Housing Revenue Bonds (Lincoln Place/Vadnais
Highlands Projects), Series 2021 (the “Participant City Bonds”), issued by the City of
Mahtomedi, Minnesota (the “Participant City”) on June 30, 2021, in the original aggregate
principal amount of $10,500,000. In order to better leverage public funding by recycling
bonding authority as permitted by Section 146(i)(6) of the Code, the Borrower has proposed
that the City and the Participant City enter into a cooperative agreement pursuant to the Act
and Minnesota Statutes, Sections 471.59 and 471.656, as amended (the “Joint Powers Act”), in
order to provide for issuance of the Notes to finance the Project using, in part, recycled bonding
authority from the Participant City Bonds.
1.08. The Project is expected to be financed with tax-exempt obligations issued using
housing allocation received from the State in the amou nt of $17,490,550 and recycled
allocation from the Participant City in the amount of up to $10,500,000.
1.09. In accordance with the Housing Act, the City has prepared a housing program
(the “Housing Program”) to authorize the issuance by the City of the Notes to finance the
Project, and the Housing Program was prepared and submitted to Metropolitan Council for its
review and comment.
1.10. A notice of public hearing (the “Public Notice”) was published in the Sun Sailor,
the official newspaper of and a newspaper of general circulation in the City, with respect to the
required public hearing under Section 147(f) of the Code and Section 462C.04, subdivision 2 of
the Housing Act.
1.11. The Public Notice was published at least fifteen (15) days before the regularly
scheduled meeting of the City Council, and on the date hereof, the City Council conducted a
public hearing on the Housing Program and the issuance of the Note s at which a reasonable
opportunity was provided for interested individuals to express their views, both orally and in
writing.
1.12. Cedar Rapids Bank and Trust Company, an Iowa banking corporation, or another
financial institution selected by the Borrower (the “Lender”), intends to purchase the Notes.
Section 2. The Housing Program. The Housing Program, in the form substantially on
file with the City, is hereby approved.
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Section 3. The Notes. The Borrower has requested that the City issue, sell, and
deliver one or more series of the Notes in the estimated aggregate principal amount of
$27,990,550. The City expects to issue two separate series of the Notes (the “Series 2022A
Note” and the “Series 2022B Note,” respectively).
Section 4. The Series 2022A Note.
4.01. The proceeds derived from the sale of the Series 2022A Note will be loaned by
the City to the Borrower (the “Series 2022A Loan”) pursuant to the terms of a Loan Agreement
(the “Series 2022A Loan Agreement”) between the City and the Borrower.
4.02. The Series 2022A Loan Agreement requires the Borrower to make loan
repayments to produce revenue sufficient to pay the principal of, premium, if any, and interest
on the Series 2022A Note when due. The City will assign its rights to the loan repayments, basic
payments, and certain other rights under the Series 2022A Loan Agreement to the Lender
pursuant to the terms of an Assignment of Loan Agreement (the “Series 2022A Assignment of
Loan Agreement”) between the City and the Lender.
4.03. As security for the repayment of principal of and interest on the Series 2022A
Loan, the Borrower will execute and deliver to the City a mortgage agreement (the
“Series 2022A Mortgage”) to be assigned by the City to the Lender pursuant to an assignment
of mortgage (the “Series 2022A Mortgage Assignment”).
4.04. The Series 2022A Note will be issued pursuant to this resolution, the Housing
Act, and the Joint Powers Act, and the Series 2022A Note and the interest thereon (i) shall be
payable solely from the revenues pledged therefor under the Series 2022A Loan Agreement
and additional sources of revenues provided by or on behalf of the Borrower, which will be
assigned to the Lender pursuant to the Series 2022A Assignment of Loan Agreement; (ii) shall
not constitute a debt of the City within the meaning of any constitutional or statutory
limitation; (iii) shall not constitute nor give rise to a pecuniary liability of the City or a charge
against its general credit or taxing powers; (iv) shall not constitute a charge, lien, or
encumbrance, legal or equitable, upon any property of the City other than the City’s interest in
the Series 2022A Loan Agreement and the revenues and assets thereunder, which will be
pledged to the Lender; and (v) shall not constitute a general or moral obligation of the City.
4.05. The City acknowledges, finds, determines, and declares that the issuance of the
Series 2022A Note is authorized by the Housing Act and the Joint Powers Act and is consistent
with the purposes of the Housing Act and the Joint Powers Act and that the issuance of the
Series 2022A Note, and the other actions of the City under the Series 2022A Loan Agreement,
the Series 2022A Assignment of Loan Agreement, and this resolution constitute a public
purpose and are in the interests of the City. In authorizing the issuance of the Series 2022A
Note to finance a portion of the Project and the related costs, the City’s purpose is and the
effect thereof will be to promote the public welfare of the City and its residents by providing
multifamily housing developments for individuals and families of low or moderate income and
otherwise furthering the purposes and policies of the Housing Act.
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4.06. For the purposes set forth above, there is hereby authorized the issuance, sale,
and delivery of the Series 2022A Note.
4.07. The Series 2022A Note shall bear interest at the rates, shall be designated, shall
be numbered, shall be dated, shall mature, shall be in the aggregate principal amount, shall be
subject to redemption prior to maturity, shall be in such form, and shall have such other terms,
details, and provisions as are prescribed in the form of the Series 2022A Note now on file with
the City, with the amendments referenced herein. The City hereby authorizes the Series 2022A
Note to be issued, in whole or in part, as a “tax-exempt obligation,” the interest on which is not
includable in gross income for federal and State of Minnesota income tax purposes.
4.08. All of the provisions of the Series 2022A Note, when executed as authorized
herein, shall be deemed to be a part of this resolution as fully and to the same extent as if
incorporated verbatim herein and shall be in full force and effect from the date of execution
and delivery thereof. The Series 2022A Note shall be substantially in the form on file with the
City, which form is hereby approved, with such necessary and appropriate variations,
omissions, and insertions (including changes to the aggregate principal amount of the
Series 2022A Note, the stated maturities of the Series 2022A Note, the interest rates on the
Series 2022A Note and the terms of redemption of the Series 2022A Note) as the Mayor and
the City Manager, in their discretion, shall determine. The execution of the Series 2022A Note
with the manual or facsimile signatures of the Mayor and the City Manager and the delivery of
the Series 2022A Note by the City shall be conclusive evidence of such determination.
4.09. The Series 2022A Note shall be a special, limited obligation of the City payable
solely from the revenues provided by the Borrower pursuant to the Series 2022A Loan
Agreement, including revenues derived from the Project. Th e City Council hereby authorizes
and directs the Mayor and the City Manager to execute the Series 2022A Note in accordance
with the terms thereof.
4.10. The Mayor and the City Manager are hereby authorized and directed to execute
and deliver the Series 2022A Loan Agreement and the Series 2022A Assignment of Loan
Agreement. All of the provisions of the Series 2022A Loan Agreement and the Series 2022A
Assignment of Loan Agreement, when executed and delivered as authorized herein, shall be
deemed to be a part of this resolution as fully and to the same extent as if incorporated
verbatim herein and shall be in full force and effect from the date of execution and delivery
thereof. The Series 2022A Loan Agreement and the Series 2022A Assignment of Loan
Agreement shall be substantially in the forms on file with the City which are hereby approved,
with such omissions and insertions as do not materially change the substance thereof, and as
the Mayor and the City Manager, in their discretion, shall determine, and the execution thereof
by the Mayor and the City Manager shall be conclusive evidence of such determinations.
Section 5. The Series 2022B Note.
5.01. The proceeds derived from the sale of the Series 2022B Note will be loaned by
the City to the Borrower (the “Series 2022B Loan”) pursuant to the terms of a Loan Agreement
(the “Series 2022B Loan Agreement”) between the City and the Borrower.
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5.02. The Series 2022B Loan Agreement requires the Borrower to make loan
repayments to produce revenue sufficient to pay the principal of, premium, if any, and interest
on the Series 2022B Note when due. The City will assign its rights to the loan repayments, basic
payments, and certain other rights under the Series 2022B Loan Agreement to the Lender
pursuant to the terms of an Assignment of Loan Agreement (the “Series 2022B Assignment of
Loan Agreement”) between the City and the Lender.
5.03. As security for the repayment of principal of and interest on the Series 2022B
Loan, the Borrower will pledge to the Lender a portion of equity installments attributable to
low-income housing tax credits for the Project. Additionally, the Borrower may cause one or
more guaranties to be delivered to secure the Borrower’s obligations under the Series 2022B
Loan Agreement.
5.04. The Series 2022B Note will be issued pursuant to this resolution, the Housing
Act, and the Joint Powers Act, and the Series 2022B Note and the interest thereon (i) shall be
payable solely from the revenues pledged therefor under the Series 2022B Loan Agreement and
additional sources of revenues provided by or on behalf of the Borrower, which will be assigned
to the Lender pursuant to the Series 2022B Assignment of Loan Agreement; (ii) shall not
constitute a debt of the City within the meaning of any con stitutional or statutory limitation;
(iii) shall not constitute nor give rise to a pecuniary liability of the City or a charge against its
general credit or taxing powers; (iv) shall not constitute a charge, lien, or encumbrance, legal or
equitable, upon any property of the City other than the City’s interest in the Series 2022B Loan
Agreement and the revenues and assets thereunder, which will be pledged to the Lender; and
(v) shall not constitute a general or moral obligation of the City.
5.05. The City acknowledges, finds, determines, and declares that the issuance of the
Series 2022B Note is authorized by the Housing Act and the Joint Powers Act and is consistent
with the purposes of the Housing Act and the Joint Powers Act and that the issuance of the
Series 2022B Note, and the other actions of the City under the Series 2022B Loan Agreement,
the Series 2022B Assignment of Loan Agreement, and this resolution constitute a public
purpose and are in the interests of the City. In authorizing the issuance of the Series 2022B
Note to finance a portion of the Project and the related costs, the City’s purpose is and the
effect thereof will be to promote the public welfare of the City and its residents by providing
multifamily housing developments for individuals and families of low or moderate income and
otherwise furthering the purposes and policies of the Housing Act.
5.06. For the purposes set forth above, there is hereby authorized the issuance, sale,
and delivery of the Series 2022B Note.
5.07. The Series 2022B Note shall bear interest at the rates, shall be designated, shall
be numbered, shall be dated, shall mature, shall be in the aggregate principal amount, shall be
subject to redemption prior to maturity, shall be in such form, and shall have such other terms,
details, and provisions as are prescribed in the form of the Series 2022B Note now on file with
the City, with the amendments referenced herein. The City hereby authorizes the Series 2022B
Note to be issued, in whole or in part, as a “tax-exempt obligation,” the interest on which is not
includable in gross income for federal and State of Minnesota income tax purposes.
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5.08. All of the provisions of the Series 2022B Note, when executed as authorized
herein, shall be deemed to be a part of this resolution as fully and to the same extent as if
incorporated verbatim herein and shall be in full force and effect from the date of execution
and delivery thereof. The Series 2022B Note shall be substantially in the form on file with the
City, which form is hereby approved, with such necessary and appropriate variations,
omissions, and insertions (including changes to the aggregate principal amount of the
Series 2022B Note, the stated maturities of the Series 2022B Note, the interest rates on the
Series 2022B Note and the terms of redemption of the Series 2022B Note) as the Mayor and
the City Manager, in their discretion, shall determine. The execution of the Series 2022B Note
with the manual or facsimile signatures of the Mayor and the City Manager and the delivery of
the Series 2022B Note by the City shall be conclusive evidence of such determination.
5.09. The Series 2022B Note shall be a special, limited obligation of the City payable
solely from the revenues provided by the Borrower pursuant to the Series 2022B Loan
Agreement, including revenues derived from the Project and the equity installments
attributable to low-income housing tax credits for the Project. The City Council hereby
authorizes and directs the Mayor and the City Manager to execute the Series 2022B Note in
accordance with the terms thereof.
5.10. The Mayor and the City Manager are hereby authorized and directed to execute
and deliver the Series 2022B Loan Agreement and the Series 2022B Assignment of Loan
Agreement. All of the provisions of the Series 2022B Loan Agreement and the Series 2022B
Assignment of Loan Agreement, when executed and delivered as authorized herein, shall be
deemed to be a part of this resolution as fully and to the same extent as if incorporated
verbatim herein and shall be in full force and effect from the date of execution and delivery
thereof. The Series 2022B Loan Agreement and the Series 2022B Assignment of Loan
Agreement shall be substantially in the forms on file with the City which are hereby app roved,
with such omissions and insertions as do not materially change the substance thereof, and as
the Mayor and the City Manager, in their discretion, shall determine, and the execution thereof
by the Mayor and the City Manager shall be conclusive eviden ce of such determinations.
5.11. If the City obtains recycled allocation from the Participant City, the Borrower
may determine that only one series of Notes is necessary. If such a determination is made, the
Series 2022B Note will not be issued by the City.
Section 6. Agreements Applicable to the Notes.
6.01. If the Borrower is able to obtain recycled allocation from the Participant City, or
another municipality or authority, the Mayor and the City Manager are authorized and directed
to execute a Cooperative Agreement in substantially the form now on file with the City which is
hereby approved, with such omissions and insertions as do not materially change the substance
thereof, or as the Mayor and the City Manager, in their discretion, shall determine, and the
execution thereof by the Mayor and the City Manager shall be conclusive evidence of such
determination.
6.02. To ensure compliance with certain rental and occupancy restrictions imposed by
the Housing Act and Section 142(d) of the Code, and to ensure compliance with certain
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restrictions imposed by the City, the Mayor and City Manager are also hereby authorized and
directed to execute and deliver a Regulatory Agreement (the “Regulatory Agreement”)
between the City, the Borrower, and the Lender. All of the provisions of the Regulatory
Agreement, when executed and delivered as authorized herein, shall be deemed to be a part of
this resolution as fully and to the same extent as if incorporated verbatim herein and shall be in
full force and effect from the date of execution and delivery thereof. The Regulatory
Agreement shall be substantially in the form on file with the City which is hereby approved,
with such omissions and insertions as do not materially change the substance thereof, or as the
Mayor and the City Manager, in their discretion, shall determine, and the execution thereof by
the Mayor and the City Manager shall be conclusive evidence of such determination.
6.03. To provide a portion of the financing for the Project, the City will consid er
making a loan to the Borrower in the estimated principal amount of $850,000 (the
“Subordinate Loan”) from its Affordable Housing Trust Fund. Provided that the City Council
approves the Subordinate Loan at a future City Council meeting, t he Mayor and the City
Manager are hereby authorized to execute and deliver, on behalf of the City, a Master
Subordination Agreement (the “Master Subordination Agreement”) between the Lender, the
City, as the issuer of the Notes, the City, as the lender of the Subordinate Loan, any additional
subordinate lenders, and the Borrower. All of the provisions of the Master Subordination
Agreement, when executed and delivered as authorized herein, shall be deemed to be a part of
this resolution as fully and to the same extent as if incorporated verbatim herein and shall be in
full force and effect from the date of execution and delivery thereof. The Master Subordination
Agreement shall be substantially in the form on file with the City which is hereby approved,
with such omissions and insertions as do not materially change the substance thereof, or as the
Mayor and the City Manager, in their discretion, shall determine, and the execution thereof by
the Mayor and the City Manager shall be conclusive evidence of such determination.
6.04. The Mayor, the City Manager, and the Finance Director of the City are hereby
authorized to execute and deliver, on behalf of the City, such other documents and certificates
as are necessary or appropriate in connection with the issuance, sale, and d elivery of the Notes,
including the Series 2022A Mortgage Assignment, various certificates of the City, an
Information Return for Tax-Exempt Private Activity Bond Issues, Form 8038, an endorsement of
the City to the tax certificate of the Borrower, and similar documents, additional subordination
agreements, and all other documents and certificates as shall be necessary and appropriate in
connection with the issuance, sale, and delivery of the Notes. The City hereby authorizes
Kennedy & Graven, Chartered, as bond counsel (“Bond Counsel”), to prepare, execute, and
deliver its approving legal opinions with respect to the Notes.
6.05. The City hereby authorizes the Borrower to provide such security for payment of
its obligations under the Loan Agreement and for payment of the Notes, including the
Mortgage, one or more guaranties, or any other security agreed upon by the Borrower and the
Lender, and the City hereby approves the execution and delivery of such security.
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Section 7. Additional Findings and Certifications.
7.01. Except as otherwise provided in this resolution, all rights, powers, and privileges
conferred and duties and liabilities imposed upon the City or the City Council by the provisions
of this resolution or of the aforementioned documents shall be exercised or performed by the
City or by such members of the City Council, or such officers, board, body or agency thereof as
may be required or authorized by law to exercise such powers and to perform such duties.
No covenant, stipulation, obligation or agreement herein contained or contained in the
aforementioned documents shall be deemed to be a covenant, stipulation, obligation or
agreement of any member of the City Council, or any officer, agent or employee of the City in
that person’s individual capacity, and neither the City Council nor any officer or employee
executing the Notes shall be personally liable on the Notes or be subject to any personal
liability or accountability by reason of the issuance thereof.
No provision, covenant or agreement contained in the aforementioned documents, the
Notes, or in any other document relating to the Notes, and no obligation therein or herein
imposed upon the City or the breach thereof, shall constitute or give rise to a general or moral
obligation of the City or any pecuniary liability of the City or any charge upon its general credit
or taxing powers. In making the agreements, provisions, covenants, and representations set
forth in such documents, the City has not obligated itself to pay or remit any funds or revenues,
other than funds and revenues derived from the Series 2022A Loan Agreement and the
Series 2022B Loan Agreement which are to be applied to the payment of the Notes, as provided
therein.
7.02. Except as herein otherwise expressly provided, nothing in this resolution or in
the aforementioned documents expressed or implied is intended or shall be construed to
confer upon any person or firm or corporation, other than the City, any holder of the Notes
issued under the provisions of this resolution, any right, remedy or claim, legal or equitable,
under and by reason of this resolution or any provisions hereof, this resolution, the
aforementioned documents, and all of their provisions being intended to be and being for the
sole and exclusive benefit of the City, and any holder from time to time of the Note s issued
under the provisions of this resolution.
7.03. In case any one or more of the provisions of this resolution, other than the
provisions contained in the first sentence of Sections 4.09 and 5.09 hereof, or of the
aforementioned documents, or of the Notes issued hereunder shall for any reason be held to
be illegal or invalid, such illegality or invalidity shall not aff ect any other provision of this
resolution, or of the aforementioned documents, or of the Notes, but this resolution, the
aforementioned documents, and the Notes shall be construed and endorsed as if such illegal or
invalid provisions had not been contained therein.
7.04. The Notes, when executed and delivered, shall contain a recital that they are
issued pursuant to the Housing Act and the Joint Powers Act, and such recital shall be
conclusive evidence of the validity of the Notes and the regularity of the issuance thereof, and
that all acts, conditions, and things required by the laws of the State of Minnesota relating to
the adoption of this resolution, to the issuance of the Notes, and to the execution of the
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aforementioned documents to happen, exist, and be performed precedent to the execution of
the aforementioned documents have happened, exist, and have been performed as so required
by law.
7.05. The officers of the City, Bond Counsel, other attorneys, engineers, and other
agents or employees of the City are hereby authorized to do all acts and things required of
them by or in connection with this resolution, the aforementioned documents, and the Note s,
for the full, punctual, and complete performance of all the terms, covenants, and agreements
contained in the Notes, the aforementioned documents, and this resolution. If for any reason
the Mayor or the City Manager is unable to execute and deliver the documents referred to in
this resolution, such documents may be executed by any member of the City Council or any
officer of the City delegated the duties of the Mayor or the City Manager with the same force
and effect as if such documents were executed and delivered by the Mayor or the City
Manager.
7.06. The Borrower shall pay the administrative fee of the City for the issuance of
conduit debt. The Borrower will also pay, or, upon demand, reimburse the City for payment of,
any and all costs incurred by the City in connection with the Project and the issuance of the
Notes, whether or not the Notes are issued, including any costs for reasonable attorneys’ fees.
Section 8. Effective Date. This resolution shall be in full force and effect from and
after its approval. The approvals contained in the resolution are effective for one year after the
date hereof.
Reviewed for Administration: Adopted by the City Council May 16, 2022
Kim Keller, city manager Jake Spano, mayor
Attest:
Melissa Kennedy, city clerk
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