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02-004 EDA . . . ~ '. RESOLUTION NO. 02-004 A RESOLUTION AWARDING THE SALE OF PUBLIC SAFETY FIRE FACILITY LEASE REVENUE BONDS, SERIES 2002A (CITY OF SHOREWOOD, MINNESOTA LEASE OBLIGATION) BE IT RESOLVED By the Shorewood Economic Development Authority (the "Authority"), as follows: Section 1. Recitals. 1.01. The City of Shore wood, Minnesota (the "City") is authorized by Minnesota Statutes, Section 465.71, as amended, to acquire real and personal property under lease-purchase agreements. 1.02. The Authority has agreed with the City that pursuant to a Ground Lease dated as of September 1, 2002 (the "Ground Lease"), the Authority will acquire certain property from the City, and the Authority will lease such property, together with the buildings, structures or improvements now or hereafter located thereon, to the City pursuant to a Lease-Purchase Agreement dated as of September 1, 2002 (the "Lease"). 1.03. Pursuant to a Trust Indenture dated as of September 1, 2002 (the "Indenture"), between the Authority and U.S. Bank National Association, as trustee (the "Trustee"), the Authority will issue its Public Safety Fire Facility Lease Revenue Bonds, Series 2002A (City of Shorewood, Minnesota Lease Obligation) (the "Bonds") in an aggregate principal amount of $3,865,000. 1.04. Under the Indenture, proceeds of the Bonds will be used to pay costs of acquisition, construction and equipping of the Facilities described in the Lease. 1.05. Pursuant to an Assignment and Security Agreement dated as of September 1, 2002 (the "Assignment"), the Authority will assign to the Trustee all of the Authority's right, title and interest in and to the Ground Lease, the Lease, and the Lease Payments to be made by the City thereunder (other than certain rights to indemnification and payment of expenses) as security for the Bonds. 1.06. Forms of the Ground Lease, the Lease, the Indenture, the Assignment, the Official Statement for the Bonds and a Continuing Disclosure Agreement of the City dated as of September 1, 2002, have been prepared and submitted to the Authority and are on file with the Authority. DJG-194423v2 CH285-17 .. . .. . Section 2. Sale of Bonds. 2.01. The proposal of Miller Johnson Steichen Kinnard (the "Purchaser") to purchase the Bonds is hereby found and determined to be a reasonable offer and is hereby accepted, the proposal being to purchase the Bonds at a price of $3,865,000 plus accrued interest to date of delivery, for Bonds bearing interest as follows: Year of Maturity 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year of Maturity 2015 2016 2017 2018 2019 2020 2021 2022 2023 Interest Rate 5.05% 5.10 5.15 5.20 5.25 5.30 5.50 5.50 5.50 Interest Rate 3.00% 3.50 4.00 4.20 4.40 4.50 4.60 4.75 4.90 5.00 Net interest cost: 5.315% 2.02. The Authority will forthwith issue and sell the Bonds in the total principal amount of $3,865,000 originally dated September 1, 2002, in the denomination of $5,000 each or any integral multiple thereof, numbered No. R-l, upward, bearing interest as above set forth, and which mature serially on February 1, in the years and amounts as follows (subject to redemption and prior payment as set forth in the Indenture): . Year Amount Year Amount 2005 $135,000 2015 $205,000 2006 140,000 2016 215,000 2007 140,000 2017 225,000 2008 150,000 2018 235,000 2009 155,000 2019 250,000 2010 160,000 2020 260,000 2011 170,000 2021 275,000 2012 175,000 2022 290,000 2013 185,000 2023 305,000 2014 195,000 2.03. Execution, Authentication and Delivery. The Bonds, substantially in the form provided in the Indenture, will be prepared under the direction of the Authority staff and executed on behalf of the Authority by the signatures of the President and one other officer of the Authority, provided that all signatures may be printed, engraved or lithographed facsimiles of the originals. Notwithstanding such execution, a Bond will not be valid or obligatory for any purpose or entitled to any security or benefit under this Resolution or the Indenture unless and until a certificate of authentication on the Bond has been duly executed by the manual signature of an authorized representative of the Trustee. When the Bonds have been so prepared, executed and authenticated, DJG-194423v2 CH285-17 . . . . the Authority will deliver the same to The Depository Trust Company, New York, New York, on behalf of the Purchaser, upon payment of the purchase price, and the Purchaser is not obligated to see to the application of the purchase price. Section 3. Approval and Execution of Documents. The Ground Lease, the Lease, the Indenture, the Assignment and the Continuing Disclosure Agreement described in Section 1 have previously been approved. The President and one other officer of the Authority are authorized and directed to execute and deliver the Ground Lease, the Lease and the Indenture on behalf of the Authority, substantially in the forms on file, but with all such changes therein as shall be approved by the officers executing the same, which approval shall be conclusively evidenced by the execution thereof. Copies of all of the transaction documents shall be delivered, filed and recorded as provided therein. The President and other officers of the Authority are also authorized and directed to execute such other instruments as may be required to give effect to the transactions herein contemplated. Section 4. Payment: Security; Pledges and Covenants. The Bonds are payable solely from the Lease Payments to be made by the City under the Lease and from other moneys realized by the Trustee after default or termination of the Lease by the City as provided therein. No property or funds of the Authority, other than the property pledged pursuant to the Indenture and assigned to the Trustee pursuant to the Assignment, is pledged to the payment of the Bonds. Section 5. Authentication of Transcript; Issuance Costs. 5.01. The officers of the Authority 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 Authority relating to the Bonds and such other certificates, affidavits and transcripts 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, may be deemed representations of the Authority as to the facts stated therein. 5.02. The preparation and distribution of the Official Statement prepared and circulated in connection with the issuance and sale of the Bonds is hereby approved. 5.03. The Authority authorizes the Purchaser to forward the amount of proceeds of the Bonds allocable to the payment of issuance expenses (other than amounts payable to Kennedy & Graven, Chartered) to U.S. Bank National Association on the closing date for further distribution as directed by the Authority's financial advisor, Juran and Moody, a division of Miller Johnson Steichen Kinnard. Section 6. Tax Covenants. 6.01. The Authority 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 DJG-194423v2 CH285-17 .. . . . 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. 6.02. In order to qualify the Bonds as "qualified tax-exempt obligations" within the meaning of Section 265(b )(3) of the Code, the Authority makes the following factual statements and representations: (a) the Bonds are not "private activity bonds" as defined in Section 141 of the Code; (b) the Authority 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 any private activity bonds that are not qualified 501(c)(3) bonds) which will be issued by the Authority (and all subordinate entities of the City) during calendar year 1998 will not exceed $10,000,000; and (d) not more than $10,000,000 of obligations issued by the Authority during calendar year 2002 have been designated for purposes of Section 265(b )(3) of the Code. 6.03. The Authority will use its best efforts to comply requirements which may apply in order to effectuate the deS'il;?ns Dated: September 12, 2002 ~ President ATTEST: DJG-194423v2 CH285-17