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HomeMy WebLinkAboutItem #18 Capital Improvement Refunding Revenue Note Series 2011 center of Good L AGENDA ITEM COVER SHEET Meeting Date: December 6, 2011 Item # Reviewed By: Contact Name: Wanda Horton Department Director: Wanda Horton Contact Number: X1520 City Manager: Subject: Capital Improvement Refunding Revenue Note, Series 2011 Background Summary: The 1999 Capital Improvement Refunding Revenue Bonds were issued to finance the acquisition of the Beech Center, the City Hall Complex, a Public Works Facility and fire stations. The principle amount currently outstanding on the bonds is $8,185,000 with interest rates of 4.5% to 4.75 %. The bonds mature October 2028. The City issued a Request for Proposal (RFP) to obtain bank qualified financing to refund the 1999 Capital Improvement Refunding Revenue Bonds (not to exceed $8,400,000). The RFP was issued to take advantage of lower interest rates. Responses were received on October 31 from three financial institutions- Branch Banking and Trust Company (BB &T), JP Morgan Chase, and SunTrust Bank. Low interest rates coupled with bank qualified financing resulted in proposed savings from $72,293 to $120,380 annually or $1,228,983 to $2,046,466 over the remaining life of the bonds. Interest rates range from 2.23% to 3.21 %. Finance and the City's Financial Advisor reviewed and compared the proposals to determine the best opportunity for the City. Issue: In addition to the proposed savings, the terms and conditions of the proposals were analyzed and compared to select the best option for the city. SunTrust Bank offered the best interest rates and flexibility by proposing two options of financing for the bonds. Option 1 offers a pre - payment clause without a penalty. The interest rate for this option is 2.53 %. Option 2 offers a pre - payment clause with a "Make Whole" provision or penalty. The interest rate for this option is 2.23 %. The interest rates are indexed and are subject to change until two days prior to closing. Interest rates have tracked lower since October providing for an increased benefit for the City. JP Morgan Chase and SunTrust Bank both included "Capital Adequacy" covenants or provisions in their proposals. In addition to the traditional taxable gross up language included in most tax - exempt bank loans (a provision that allows the bank to increase or "gross up" the interest rate if tax rates change), this covenant permits the bank to increase the interest rate due to changes in law that negatively impact the bank's after -tax yield. However locking in rates, at the current lower interest rates, should provide some protection if interest rates do increase due to this provision. Recommendations Staff recommends the commission approve 1) The resolution authorizing the refunding of the Capital Improvement Refunding Revenue Bonds, Series 1999 (not to exceed $8,400,000) utilizing Option 1 proposed by SunTrust, and 2) authorize the Mayor and Staff to execute all documents necessary to complete the transaction. Attachments: Resolution , Bank Commitment Letter, Proposal Analysis Sheet Financial Impact: Annual debt service savings from $72,293 to $120,380. Type of Item: (please mark with an "x") Public Hearing For Clerk's Dept Use: Ordinance First Reading Consent Agenda Ordinance Second Reading Public Hearing Resolution Regular Agenda Commission Approval Discussion & Direction Original Document/Contract Attached for Execution by City Clerk Original Document/Contract Held by Department for Execution Reviewed by City Attorney N/A Reviewed by Finance Dept. i7 N/A Reviewed by 0 N/A 2 C no y F3 E a c E m N in 17 m N C O p 1. N a) N N d N d o. 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A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF OCOEE, FLORIDA; AUTHORIZING THE ISSUANCE OF CITY OF OCOEE, FLORIDA CAPITAL IMPROVEMENT REFUNDING REVENUE NOTE, SERIES 2011 IN THE PRINCIPAL AMOUNT OF NOT TO EXCEED $8,400,000 TO REFUND THE CITY'S CAPITAL IMROVEMENT REFUNDING REVENUE BONDS, SERIES 1999; PROVIDING THAT SUCH NOTE SHALL BE A LIMITED OBLIGATION OF THE CITY PAYABLE FROM SALES TAX REVENUES AS THE PLEDGED REVENUES AS PROVIDED HEREIN; PROVIDING FOR THE RIGHTS, SECURITIES AND REMEDIES FOR THE OWNER OF SUCH NOTE; MAKING CERTAIN COVENANTS AND AGREEMENTS IN CONNECTION THEREWITH; APPROVING THE FORM OF AN ESCROW DEPOSIT AGREEMENT; DESIGNATING THE NOTE FOR THE EXCEPTION FOR CERTAIN TAX - EXEMPT OBLIGATIONS CONTAINED IN SECTION 265 OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED; AND PROVIDING FOR AN EFFECTIVE DATE. BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF OCOEE, FLORIDA: Section 1. Authority for this Resolution. This Resolution is adopted pursuant to the provisions of the Constitution of the State of Florida, Chapter 166, Part II, Florida Statutes, the Charter of the City of Ocoee, Florida (the "Issuer "), and other applicable provisions of law. Section 2. Definitions. The following words and phrases shall have the following meanings when used herein including the exhibits attached hereto: "Act" means the Constitution of the State of Florida, Chapter 166, Part II, Florida Statutes, the Charter of the Issuer, the Issuer's home rule powers and other applicable provisions of law. "Additional Debt" is as defined in Section 16(b) hereof. "Business Day" means any day except any Saturday or Sunday or day on which the Principal Office of the Original Purchaser is closed. "City Clerk" means the City Clerk of the Issuer or any Deputy City Clerk. "City Manager" means the duly appointed and acting City Manager of the Issuer, or any duly authorized deputy thereof. "Change in Law" means with respect to the Original Purchaser, so long as it is the holder of the Note, the occurrence, after the date of this Resolution, of any of the following: (a) the adoption or taking effect of any law, rule, regulation or treaty applicable to the Original Purchaser, (b) any change in any law, rule, regulation or treaty or in the administration, interpretation, implementation or application thereof by any Governmental Authority applicable to the Original Purchaser or (c) the making or issuance of any request, rule, guideline or directive (whether or not having the force of law) by any Governmental Authority; provided that notwithstanding anything herein to the contrary, (x) the Dodd -Frank Wall Street Reform and Consumer Protection Act and all requests, rules, guidelines or directive thereunder or issued in connection therewith and (y) all requests, rules, guidelines or directives promulgated by the Bank for International Settlements, the Basel Committee on Banking Supervision (or any successor or similar authority) or, pursuant to the accord commonly referred to as "Basel III" or the United States or foreign regulatory authorities, shall in each case be deemed to be a "Change in Law," if subsequent to the date of the Resolution, regardless of the date enacted, adopted or issued. "Closing" means December 8, 2011, the date of issuance of the Note, or such other date as determined by the Issuer and the Original Purchaser. "Code" means the Internal Revenue Code of 1986, as amended, and any Treasury Regulations, whether temporary, proposed or final, promulgated thereunder or applicable thereto. "Debt Service Requirement" for any Bond Year shall mean the sum of: (1) the amount required to pay the interest becoming due on the Note and any Additional Debt during such Bond Year and (2) the amount required to pay the principal of such Note and Additional Debt maturing in such Bond Year. "Escrow Deposit Agreement" shall mean the agreement described in Section 10 hereof securing the Refunded Bonds. "Escrow Holder" shall mean U.S. Bank National Association. "Fiscal Year" means the period commencing on October 1 of each year and ending on the succeeding September 30. "Interest Rate" shall be as set forth in the Note. "Issuer" means the City of Ocoee, Florida, a municipal corporation of the State of Florida. 2 "Mayor" means the Mayor of the Issuer or in his or her absence or inability to act, the Vice Mayor of the Issuer or such other person as may be duly authorized by the City Commission to act on its behalf. "Maximum Debt Service Requirement" means, as of a particular date of calculation, the greatest amount of Debt Service Requirement for the then current or any future Bond Year. "Note" or "Notes" means the Issuer's Notes of the Issuer authorized by Section 4 hereof. "Note Year" shall mean the period beginning with October 1 and extending for a period of twelve (12) months thereafter. "Original Purchaser" means SunTrust Bank, a Georgia corporation. "Owner" or "Owners" means the Person or Persons in whose name or names the Notes shall be registered on the books of the Issuer kept for that purpose in accordance with provisions of this Resolution, including, initially, the Original Purchaser. "Person" means natural persons, firms, trusts, estates, associations, corporations, partnerships and public bodies. "Pledged Revenues" means the local government half -cent sales tax and other moneys received by the Issuer from the local government half -cent sales tax clearing trust fund pursuant to Chapter 218, Part VI, Florida Statutes. "Principal Office" means, with respect to the Original Purchaser, the office located at 200 S. Orange Avenue, SOAB 6th Floor, Orlando, Florida 32801 Attention: Institutional and Governmental Banking, or such other office as the Original Purchaser may designate to the Issuer in writing. "Refunded Bonds" means the Issuer's original aggregate principal amount $11,405,000 Capital Improvement Refunding Revenue Bonds, Series 1999, dated February 10, 1999. "Resolution" means this Resolution, pursuant to which the Notes are authorized to be issued. "State" means the State of Florida. Section 3. Findings. (A) For the benefit of its inhabitants, the Issuer finds, determines and declares that it is necessary for the continued preservation of the health, welfare, convenience and safety of the Issuer and its inhabitants to refund the Refunded Bonds. Issuance of the Note to refund the 3 Refunded Bonds, the proceeds of which originally refinanced certain indebtedness of the Issuer and financed various capital improvements of the Issuer satisfies a paramount public purpose. (B) Debt service on the Note will be payable from Pledged Revenues. The Pledged Revenues will be sufficient to pay the principal and interest on the Note herein authorized, as the same become due, and to make all deposits required by this Resolution. (C) The Issuer has received an offer from the Original Purchaser to purchase the Note. (D) In consideration of the purchase and acceptance of the Note authorized to be issued hereunder by those who shall be the Owners thereof from time to time, this Resolution shall constitute a contract between the Issuer and the Owners. (E) The Issuer desires to qualify the Note for the exception contained in Section 265(b)(3) of the Code to the provisions contained in Section 265(b) of the Code which deny financial institutions any deduction for interest expense allocable to tax - exempt obligations acquired after August 7, 1986, and to designate the Note for the purpose of qualifying for such exception. (F) That the Issuer adopted this Resolution after a public hearing preceded by at least seven (7) days notice of the hearing and the proposed action by publication in a newspaper of general circulation in the Issuer in accordance with the requirements of the Charter of the Issuer. Section 4. Authorization of Note. Subject and pursuant to the provisions of this Resolution, an obligations of the Issuer to be known as City of Ocoee, Florida, Capital Improvement Refunding Revenue Note, Series 2011 is hereby authorized to be issued under and secured by this Resolution, in the aggregate principal amount of not to exceed $8,400,000, for the purpose of providing funds to refund the Refunded Bonds and paying the costs of issuing the Note. Because of the characteristics of the Note, prevailing market conditions, and additional savings to be realized from an expeditious sale of the Note, it is in the best interest of the Issuer to accept the offer of the Original Purchaser to purchase the Note at a private negotiated sale. Prior to the issuance of the Note, the Issuer shall receive from the Original Purchaser a disclosure letter containing the information required by Section 218.385, Florida Statutes. Section 5. Description of Note. The Note shall be issued as one fully registered Note in the principal amount not to exceed $8,400,000, shall be dated as of the date of its delivery to the Original Purchaser thereof and shall mature on October 1, 2028. The Note shall be payable to the Original Purchaser, and shall bear interest equal to the Interest Rate and calculated on the basis of a 30/360 day count basis, subject to adjustment as provided in the form of the Note included herein. The initial Interest Rate shall be determined on or prior to the 4 date of issuance of the Note and shall not exceed 4.00% per annum. The rate of interest on the Note shall be fixed as set forth on the executed Note. Principal shall be payable annually on October 1, commencing October 1, 2012 based upon level annual debt service payments. Interest shall be payable semi - annually on April 1 and October 1 of each year, commencing April 1, 2012 or such other date as agreed upon by the Issuer and the Original Purchaser prior to the issuance of the Note. Said principal and any unpaid interest shall be payable upon maturity or prepayment. The Note shall be payable in any coin or currency of the United States of America which on the respective dates of payment thereof is legal tender for the payment of public and private debts. The principal and interest on the Note, shall be payable by the Finance Director, as the paying agent (the "Paying Agent "), to the person appearing on the registration books of the Issuer in its capacity as registrar (the "Registrar ") hereinafter provided for as the registered Owner thereof. The principal of the Note shall be payable only to the registered Owner or his legal representative at the office of the Issuer who shall also keep a registration book registering the ownership of the Note (the "Registrar "). The Note is to be in substantially the form set forth on Exhibit A, attached hereto, together with such changes as shall be approved by the Mayor, following review by the City Manager, Finance Director and City Attorney, such approval to be conclusively evidenced by the execution thereof by the Mayor. The Note shall be executed on behalf of the Issuer with the manual signature of the Mayor and shall have impressed thereon the official seal of the Issuer, and be attested with the manual signature of the City Clerk and approved as to form by the City Attorney, and the Mayor, City Clerk and City Attorney are hereby authorized to execute, attest and approve to the Note on behalf of the Issuer. Section 6. Registration and Exchange of Note; Persons Treated as Owners. The Note is initially registered to the Original Purchaser. So long as the Note shall remain unpaid, the Issuer will keep books for the registration and transfer of the Note. The Note shall be transferable only upon such registration books. The Person in whose name the Note shall be registered shall be deemed and regarded as the absolute owner thereof for all purposes, and payment of principal and interest on such Note shall be made only to or upon the written order of the Owner. All such payments shall be valid and effectual to satisfy and discharge the liability upon such Note to the extent of the sum or sums so paid. Section 7. Note Mutilated, Destroyed, Stolen or Lost. In case a Note shall become mutilated, or be destroyed, stolen or lost, the Issuer shall issue and deliver a new Note of like tenor as the Note so mutilated, destroyed, stolen or lost, in exchange and in substitution for such mutilated Note, or in lieu of and in substitution for the Note destroyed, stolen or lost and upon the Owner furnishing the Issuer proof of ownership thereof and indemnity reasonably satisfactory to the Issuer and complying with such other reasonable regulations and conditions as the Issuer may prescribe and paying such expenses as the Issuer may incur. The Note so surrendered shall be canceled. 5 Section 8. Payment of Principal and Interest; Limited Obligation. The Issuer promises that it will promptly pay the principal of and interest on the Note at the place, on the dates and in the manner provided therein according to the true intent and meaning hereof and thereof. The Note shall not be or constitute general obligations or indebtedness of the Issuer as "bonds" within the meaning of Article VII, Section 12 of the Constitution of Florida, but shall be payable solely from the Pledged Revenues in accordance with the terms hereof. No holder of any Note issued hereunder shall ever have the right to compel the exercise of any ad valorem taxing power to pay such Note, or be entitled to payment of such Note from any funds of the Issuer except from the Pledged Revenues as described herein. Section 9. Prepayment. The Note shall be subject to prepayment at the option of the Issuer in whole or in part at any time without penalty, upon two (2) Business Days' prior written notice to the Original Purchaser. Such prepayment notice shall specify the amount of the prepayment which is to be made. Section 10. Disbursement of and Application of Proceeds of Note; Escrow Deposit Agreement. At the time of delivery of the Note herein authorized, the proceeds from the sale of the Note shall be used to deposit funds to secure the Refunded Bonds and pay costs of issuance associated with the Note. There is hereby authorized the execution of the Escrow Deposit Agreement in order to refund the Refunded Bonds in the manner provided herein. Simultaneously with the delivery of the Note to the Original Purchaser thereof, the Issuer will enter into the Escrow Deposit Agreement in substantially the form attached hereto as Exhibit B with the Escrow Holder. At the time the Escrow Deposit Agreement is executed, the Issuer will furnish to the Escrow Holder appropriate documentation to demonstrate that the sum being deposited with the Escrow Holder pursuant to this Resolution, together with other funds deposited into the escrow account pursuant to the provisions of the Escrow Deposit Agreement, shall be equal to the Escrow Requirement (as defined therein) and that such moneys and the investments to be made pursuant to the Escrow Deposit Agreement will be sufficient to produce the moneys required to make all payments described in the Escrow Deposit Agreement for the full and complete refunding and defeasance of the Refunded Bonds. Section 11. Tax Covenant. The Issuer covenants to the purchasers of the tax - exempt Note provided for in this Resolution that the Issuer will not make any use of the proceeds of the tax - exempt Note at any time during the term of the tax - exempt Note which, if such use had been reasonably expected on the date the tax - exempt Note was issued, would have caused such tax - exempt Note to be "arbitrage bonds" within the meaning of the Internal Revenue Code of 1986, as amended (the "Code "). The Issuer will comply with the requirements of the Code and any valid and applicable rules and regulations promulgated thereunder necessary to ensure the exclusion of interest on the tax - exempt Note from the gross income of the holders thereof for purposes of federal income taxation. 6 Section 12. Bank Qualified. The Issuer hereby designates the Note as "qualified tax - exempt obligation" within the meaning of Section 265(b)(3) of the Code. The Issuer and any subordinate entities of the Issuer and any issuer of "tax- exempt" debt that issues "on behalf of" the Issuer do not reasonably expect during the calendar year 2011 to issue more than $10,000,000 of "tax- exempt" obligations including the tax - exempt Note, exclusive of any private activity bonds as defined in Section 141(a) of the Code (other than qualified 501(c)(3) bonds as defined in Section 145 of the Code). Section 13. Sale of Note; Authorization Regarding Debit for Interest Payments. The Note is hereby sold and awarded to SunTrust Bank at the price of par and the Mayor and the City Clerk are hereby authorized to execute and deliver the Note in the form set forth herein, receive the purchase price therefor and apply the proceeds thereof as hereinafter provided, without further authority from this body. The Mayor and the City Clerk are authorized to make any and all changes on the form of the Note which shall be necessary to conform the same to the commitment of SunTrust Bank. Execution of the Note by the Mayor and the City Clerk shall be conclusive evidence of their approval of the form of the Note. The Finance Director of the Issuer shall provide for the collection of the interest payments on the Note through an auto debit from the Issuer's account with the Original Purchaser. Section 14. Impairment of Contract. The Issuer covenants with the Owner of the Note that it will not, without the written consent of the Owner of the Note, enact any ordinance or adopt any resolution which repeals, impairs or amends in any manner adverse to the Owner the rights granted to the Owner of the Note hereunder. The pledging of the Pledge Revenues in the manner provided herein shall not be subject to repeal, modification or impairment by any subsequent ordinance, resolution or other proceedings of the City Commission. The Issuer covenants that it will not impair or adversely affect the power and right of the Issuer to receive the Pledged Revenues. The Issuer will proceed diligently to perform legally and effectively all steps required on its part in the levy and collection of the Pledged Revenues and shall exercise all legally available remedies to enforce such collections now or hereafter available under State law. Section 15. Budget and Financial Information. The Issuer shall provide the Owner of the Note with a copy of its annual budget and such other financial information regarding the Issuer as the Owner of the Note may reasonably request. The Issuer hereby covenants that it shall promptly give written notice to the Owner of the Note of any litigation or proceeding which if determined adversely to the Issuer would adversely affect the security for the payment of the Note. The Issuer shall provide the Owner of the Note with annual financial statements 7 not later than two hundred forty (240) days after the close of such fiscal year and a copy of the final budget for each fiscal year of the Issuer not later than thirty (30) days after adoption. The financial statements shall be prepared in accordance with applicable law and generally accepted accounting principles and audited by an independent certified public accountant. All accounting terms not specifically defined or specified herein shall have the meanings attributed to such terms under generally accepted accounting principles ( "GAAP ") as in effect from time to time, consistently applied. Section 16. Additional Debt. (a) The Issuer shall issue no bonds, notes or obligations of any kind or nature payable from or enjoying a lien on the Pledged Revenues if such obligations have priority over the Note with respect to payment or lien, nor shall the Issuer create or cause or permit to be created any debt, lien, pledge, assignment, encumbrance or other charge having priority to or being on a parity with the lien of the Note upon said Pledged Revenues. However, the Issuer may issue additional debt under the conditions and in the manner provided below. Any obligations issued by the Issuer other than the Note and Additional Debt (as described in subparagraph (b)), which are payable from the Pledged Revenues shall contain an express statement that such obligations are junior and subordinate in all respects to the Note as to lien on and source and security for payment from such Pledged Revenues. (b) No additional debt, notes, bonds, payable on a parity from the Pledged Revenues ( "Additional Debt "), shall be issued after the issuance of the Note herein authorized, except upon the conditions and in the manner hereinafter provided: (1) The Issuer's Finance Director shall certify at the time of the issuance of the Additional Debt that the Issuer is not in default of any of the provisions, covenants and agreements hereof. (2) The Issuer's Finance Director shall also certify at the time of the issuance of the Additional Debt that the Pledged Revenues received by the Issuer during the two most recent Fiscal Years immediately preceding the date of issuance of such Additional Debt for which audited statements are available shall equal at least 1.35 times the Maximum Debt Service Requirement on the outstanding Note and the proposed Additional Debt. Section 17. Events of Default; Remedies of Noteholder. The following shall constitute Events of Default: (i) if the Issuer fails to pay any payment of principal of or interest on any Note as the same becomes due and payable; (ii) if the Issuer defaults in the performance or observance of any covenant or agreement contained in this Resolution or the Note (other than set forth in (i) above) and fails to cure the same within thirty (30) days; or (iii) filing of a petition by or against the Issuer relating to bankruptcy, reorganization, arrangement or readjustment of debt of the Issuer or for any other relief relating to the Issuer under the United States Bankruptcy Code, as amended, or any other insolvency act or law now or hereafter 8 existing, or the involuntary appointment of a receiver or trustee for the Issuer, and the continuance of any such event for ninety (90) days undismissed or undischarged. Upon the occurrence and during the continuation of any Event of Default, the Owner of the Note may, in addition to any other remedies set forth in this Resolution or Note, either at law or in equity, by suit, action, mandamus or other proceeding in any court of competent jurisdiction, protect and enforce any and all rights under the laws of the State of Florida, or granted or contained in this Resolution, and may enforce and compel the performance of all duties required by this Resolution, or by any applicable statutes to be performed by the Issuer or by any officer thereof. Section 18. Limitation of Rights. With the exception of any rights herein expressly conferred, nothing expressed or mentioned in or to be implied from this Resolution or the Note is intended or shall be construed to give to any Person other than the Issuer and the Owner any legal or equitable right, remedy or claim under or with respect to this Resolution or any covenants, conditions and provisions herein contained; this Resolution and all of the covenants, conditions and provisions hereof being intended to be and being for the sole and exclusive benefit of the Issuer and the Owner. Section 19. Amendment. This Resolution shall not be modified or amended in any respect subsequent to the issuance of the Note except with the written consent of the Owner of the Note. Section 20. City Commission Members of the Issuer Exempt from Personal Liability. No recourse under or upon any obligation, covenant or agreement of this Resolution or the Note or for any claim based thereon or otherwise in respect thereof, shall be had against any City Commission members, as such, of the Issuer, past, present or future, either directly or through the Issuer it being expressly understood (a) that no personal liability whatsoever shall attach to, or is or shall be incurred by, the City Commission members of the Issuer, as such, under or by reason of the obligations, covenants or agreements contained in this Resolution or implied therefrom, and (b) that any and all such personal liability, either at common law or in equity or by constitution or statute, of, and any and all such rights and claims against, every such City Commission member of the Issuer, as such, are waived and released as a condition of, and as a consideration for, the execution of this Resolution and the issuance of the Note, on the part of the Issuer. Section 21. Authorizations. The Mayor and any member of the City Commission, the City Manager, the City Attorney, the City Clerk and such other officials and employees of the Issuer as may be designated by the Issuer are each designated as agents of the Issuer in connection with the issuance and delivery of the Note and are authorized and empowered, collectively or individually, to take all action and steps and to execute all instruments, documents, and contracts on behalf of the Issuer that are necessary or desirable in connection 9 with the execution and delivery of the Note, and which are specifically authorized or are not inconsistent with the terms and provisions of this Resolution. Section 22. Business Days. In any case where the due date of interest on or principal of the Note is not a Business Day, then payment of such principal or interest need not be made on such date but may be made on the next succeeding Business Day, provided that credit for payments made shall not be given until the payment is actually received by the Owner. Section 23. Applicable Provisions of Law. This Resolution shall be governed by and construed in accordance with the laws of the State. Section 24. Rules of Interpretation. Unless expressly indicated otherwise, references to sections or articles are to be construed as references to sections or articles of this instrument as originally executed. Use of the words "herein," "hereby," "hereunder," "hereof," "hereinbefore," "hereinafter" and other equivalent words refer to this Resolution and not solely to the particular portion in which any such word is used. Section 25. Captions. The captions and headings in this Resolution are for convenience only and in no way define, limit or describe the scope or intent of any provisions or sections of this Resolution. Section 26. Severability. If any provision of this Resolution shall be held or deemed to be or shall, in fact, be illegal, inoperative or unenforceable in any context, the same shall not affect any other provision herein or render any other provision (or such provision in any other context) invalid, inoperative or unenforceable to any extent whatever. Section 27. Repealer. All resolutions or parts thereof in conflict herewith are hereby repealed. Section 28. No Third Party Beneficiaries. Except such other persons as may be expressly described in this Resolution or in the Note, nothing in this Resolution or in the Note, expressed or implied, is intended or shall be construed to confer upon any person, other than the Issuer and the holders, any right, remedy or claim, legal or equitable, under and by reason of this Resolution, or any provision thereof, or of the Note, all provisions thereof being intended to be and being for the sole and exclusive benefit of the Issuer and the persons who shall from time to time be the holders. Section 29. Capital Adequacy. If, after the date of issuance of the Note, the Original Purchaser shall have reasonably determined that a Change in Law shall have occurred that has or would have the effect of reducing the rate of return on the Original Purchaser's capital on the Note as a consequence of its ownership of the Note or otherwise, to a level below that which the Original Purchaser could have achieved but for such adoption, change or compliance (taking into consideration the legal requirements with respect to capital adequacy) by an amount 10 deemed by the Original Purchaser to be material, then from time to time, promptly upon demand by the Original Purchaser, the Issuer hereby agrees to pay the Original Purchaser such additional amount or amounts as will compensate the Original Purchaser for such reduction; provided however, no such demand for reimbursement shall be effective until the Original Purchaser delivers to the Issuer a certificate (each a "Certificate "), no less than sixty (60) calendar days preceding the effective date of such demand setting forth in reasonable detail the basis therefor and the manner of calculation thereof which Certificate shall be conclusive (absent manifest error) as to the amount set forth therein and such calculation shall also take into account any changes which decrease the cost to the Original Purchaser. In determining any such amount, the Original Purchaser may use any reasonable averaging and attribution methods. Concurrently with the presentation of each Certificate, the Issuer shall also be provided written certification from the Original Purchaser that all of the Original Purchaser's outstanding loans of like type to the Note are also being required to compensate the Original Purchaser due to the change in capital adequacy requirements. Upon receipt of the Certificate, the Issuer may request the Original Purchaser (provided, the Original Purchaser is under no obligation to grant such request) to delay all or a portion of the reimbursement payment attributable the Change in Law until the first payment date occurring in the fiscal year following the Change in Law (the "Transition Date "), then in such case, on the Transition Date the Issuer shall pay the Original Purchaser the reimbursement amounts attributable to a Change in Law that remain due hereunder and are unpaid. In addition, if, on or prior to sixty (60) calendar days after receipt of the Certificate, the Issuer prepays the Note pursuant Section 9 hereof, no amounts shall be due from the Issuer to the Original Purchaser with respect to a Change in Law. Notwithstanding the foregoing, no reimbursing amounts due and owing to the Original Purchaser pursuant to this paragraph shall have the effect of causing the Interest Rate on the Note to exceed the maximum amounts allowed pursuant to Section 215.84, Florida Statues or any other applicable provision of law. Section 30. Effective Date. This Resolution shall be in full force and take effect immediately upon its passage and adoption. [Remainder of page intentionally left blank] 11 PASSED AND ADOPTED by the City Commission of the City of Ocoee, Florida, on this 6th day of December, 2011. ATTEST: APPROVED: CITY OF OCOEE, FLORIDA By: By: Name: Beth Eikenberry Name: S. Scott Vandergrift Title: City Clerk Title: Mayor Approved as to form and legality for the use and reliance of the City of Ocoee, Florida, only. Name: Paul Rosenthal Title: City Attorney j: \ wdox \ docs \ clients \ 25136 \ 006 \ ordres \ 00594071.doc 12 EXHIBIT A FORM OF NOTE ANY HOLDER SHALL, PRIOR TO BECOMING A HOLDER, EXECUTE A PURCHASERS CERTIFICATE CERTIFYING, AMONG OTHER THINGS, THAT SUCH HOLDER IS AN "ACCREDITED INVESTOR" AS SUCH TERM IS DEFINED IN THE SECURITIES ACT OF 1933, AS AMENDED, AND REGULATION D THEREUNDER. R -1 $ STATE OF FLORIDA COUNTY OF ORANGE CITY OF OCOEE, FLORIDA CAPITAL IMPROVEMENT REFUNDING REVENUE NOTE, SERIES 2011 Dated Date Maturity Date Interest Rate , 2011 October 1, 2028 The City of Ocoee, Florida (the "Issuer "), a municipal corporation created and existing pursuant to the Constitution and the laws of the State of Florida, for value received, promises to pay from the sources hereinafter provided, to the order of SunTrust Bank or registered assigns (hereinafter, the "Owner "), the principal sum of $ together with interest on the principal balance at the Interest Rate (as the same may be adjusted) based upon a 30/360 day count basis. Principal payments shall begin on October 1, 2012 and the final installment of the entire unpaid principal balance, together with all accrued and unpaid interest hereon, is due and payable on October 1, 202, and shall be in the amounts attached hereto as Schedule A. This Note is issued pursuant to the Constitution of the State of Florida, Chapter 166, Part II, Florida Statutes, the Charter of the Issuer and a Resolution duly adopted by the Issuer on December 6, 2011, as from time to time amended and supplemented (herein referred to as the "Resolution "), and is subject to all the terms and conditions of the Resolution. All terms, conditions and provisions of the Resolution including without limitation remedies in the Event of Default are by this reference thereto incorporated herein as a part of this Note. Payment of this Note is secured by the Pledged Revenues of the Issuer. Terms used herein in capitalized form and not otherwise defined herein shall have the meanings ascribed thereto in the Resolution. Principal of and interest on this Note is payable in lawful money of the United States of America at such place as the Owner may designate to the Issuer in writing. If any date for the payment of principal and interest hereon shall fall on a day which is not a Business Day (as A -1 defined in the Resolution the payment due on such date shall be due on the next succeeding day which is a Business Day, but the Issuer shall not receive credit for the payment until it is actually received by the Owner. All payments by the Issuer pursuant to this Note shall apply first to accrued interest, then to other charges due the Owner, and the balance thereof shall apply to principal. The Issuer has designated this Note as a "qualified tax - exempt obligation" within the meaning of Section 265(b)(3) of the Code in the Resolution. Should subsequent but currently unforeseen actions by the Issuer cause this Note to not be classified as a "qualified tax - exempt obligation" pursuant to Section 265(b)(3) of the Internal Revenue Code of 1986, as amended, the interest rate on this Note shall be adjusted to that level necessary to ensure that the anticipated after tax yield contemplated by the Owner at the time of issuance of this Note is received. In addition, in the event that the interest on this Note is ever determined to be taxable for purposes of state income taxation, or in the event that any or all of the interest on this Note is deemed to be included in the gross income of the Owner for state income taxation, or in the event the Owner is unable to deduct any other amounts as a result of purchasing or carrying this Note, or in the event of a change in the alternative minimum tax or in the method of calculating the alternative maximum tax to which the Owner may be subject, or in the event of any action which would otherwise decrease the after tax yield to the Owner, the interest on this Note shall be adjusted to that level necessary to ensure that the anticipated after tax yield contemplated by the Owner at the time of issuance of this Note is received. In no event, however, shall the interest rate on this Note exceed the maximum rate permitted by law. If, after the date of issuance of this Note, the Original Purchaser shall have reasonably determined that a Change in Law shall have occurred that has or would have the effect of reducing the rate of return on the Original Purchaser's capital on this Note as a consequence of its ownership of this Note or otherwise, to a level below that which the Original Purchaser could have achieved but for such adoption, change or compliance (taking into consideration the legal requirements with respect to capital adequacy) by an amount deemed by the Original Purchaser to be material, then from time to time, promptly upon demand by the Original Purchaser, the Issuer hereby agrees to pay the Original Purchaser such additional amount or amounts as will compensate the Original Purchaser for such reduction; provided however, no such demand for reimbursement shall be effective until the Original Purchaser delivers to the Issuer a certificate (each a "Certificate "), no less than sixty (60) calendar days preceding the effective date of such demand setting forth in reasonable detail the basis therefor and the manner of calculation thereof which Certificate shall be conclusive (absent manifest error) as to the amount set forth therein and such calculation shall also take into account any changes which decrease the cost to the Original Purchaser. In determining any such amount, the Original Purchaser may use any reasonable averaging and attribution methods. Concurrently with the presentation of each Certificate, the Issuer shall also be provided written certification from the Original Purchaser that all of the Original Purchaser's outstanding loans of like type to this A -2 Note are also being required to compensate the Original Purchaser due to the change in capital adequacy requirements. Upon receipt of the Certificate, the Issuer may request the Original Purchaser (provided, the Original Purchaser is under no obligation to grant such request) to delay all or a portion of the reimbursement payment attributable the Change in Law until the first payment date occurring in the fiscal year following the Change in Law (the "Transition Date "), then in such case, on the Transition Date the Issuer shall pay the Original Purchaser the reimbursement amounts attributable to a Change in Law that remain due hereunder and are unpaid. In addition, if, on or prior to sixty (60) calendar days after receipt of the Certificate, the Issuer prepays this Note pursuant Section 9 of the Resolution, no amounts shall be due from the Issuer to the Original Purchaser with respect to a Change in Law. Notwithstanding the foregoing, no reimbursing amounts due and owing to the Original Purchaser pursuant to this paragraph shall have the effect of causing the Interest Rate on this Note to exceed the maximum amounts allowed pursuant to Section 215.84, Florida Statues or any other applicable provision of law. This Note shall be subject to prepayment at the option of the Issuer in whole or in part at any time without penalty, upon two (2) Business Days' prior written notice to the Original Purchaser. Such prepayment notice shall specify the amount of the prepayment which is to be made. In the event the prepayment of this Note under Section 9 of the Resolution, the Issuer may be required to pay the Original Purchaser an additional fee (a prepayment charge or premium) determined in the manner provided below, to compensate the Original Purchaser for all losses, costs and expenses incurred in connection with such prepayment. In case of an Event of Default (as defined in the hereinafter defined Resolution), the Owner may declare the entire debt then remaining unpaid hereunder immediately due and payable; and in any such default and acceleration, the Issuer shall also be obligated to pay as part of the indebtedness evidenced by this Note, all costs of collection and enforcement hereof, including such reasonable legal fees and expenses as may be incurred, including on appeal or incurred in any proceeding under bankruptcy laws as they now or hereafter exist. Upon the occurrence of and during the continuation of an Event of Default, the interest rate on this Note shall be increased to the lesser of 25% per annum or the maximum rate permitted by law. The Issuer to the extent permitted by law hereby waives presentment, demand, protest and notice of dishonor. THIS NOTE DOES NOT CONSTITUTE A GENERAL INDEBTEDNESS OF THE ISSUER WITHIN THE MEANING OF ANY CONSTITUTIONAL, STATUTORY OR CHARTER PROVISION OR LIMITATION, AND IT IS EXPRESSLY AGREED BY THE HOLDER OF THIS NOTE THAT SUCH NOTEHOLDER SHALL NEVER HAVE THE RIGHT TO REQUIRE OR COMPEL THE EXERCISE OF THE AD VALOREM TAXING POWER OF THE ISSUER OR TAXATION OF ANY REAL OR PERSONAL PROPERTY THEREIN FOR THE PAYMENT OF THE PRINCIPAL OF AND INTEREST ON THIS NOTE OR THE MAKING OF ANY OTHER PAYMENTS PROVIDED FOR IN THE RESOLUTION, OR BE ENTITLED TO PAYMENT OF A -3 SUCH NOTE FROM ANY FUNDS OF THE ISSUER EXCEPT FROM THE PLEDGED REVENUES. This Note may be exchanged or transferred by the Owner hereof but only upon the registration books maintained by the Issuer and in the manner provided in the Resolution. It is hereby certified, recited and declared that all acts, conditions and prerequisites required to exist, happen and be performed precedent to and in the execution, delivery and the issuance of this Note do exist, have happened and have been performed in due time, form and manner as required by law, and that the issuance of this Note is in full compliance with and does not exceed or violate any constitutional or statutory limitation. THE ISSUER, AND THE OWNER, BY ACCEPTANCE OF THIS NOTE, AGREE TO WAIVE TRAIL BY JURY IN ANY CONTROVERSY OR CLAIM BETWEEN THE PARTIES HERETO INCLUDING BUT NOT LIMITED TO THOSE ARISING OUT OF OR RELATING TO THIS AGREEMENT OR ANY RELATED INSTRUMENTS, AGREEMENTS OR DOCUMENTS. A -4 IN WITNESS WHEREOF, the City of Ocoee, Florida has caused this Note to be executed in its name by the manual signature of its Mayor and attested by the manual signature of its City Clerk, and its seal to be impressed hereon, all this day of , 2011. CITY OF OCOEE, FLORIDA [SEAL] By: Mayor Attest: City Clerk APPROVED AS TO FORM: City Attorney A -5 CERTIFICATE OF AUTHENTICATION This Note is one of this Notes issued under the provisions of the within mentioned Resolution. SUNTRUST BANK, Registrar, as Authenticating Agent Date of Authentication: By Authorized Officer ASSIGNMENT AND TRANSFER For value received the undersigned hereby sells, assigns and transfers unto (Please insert Social Security or other identifying number of transferee) the attached Note of the City of Ocoee, Florida, and does hereby constitute and appoint , attorney, to transfer the said Note on the books kept for registration thereof, with full power of substitution in the premises. Date: By: (manual signature) NOTICE: No transfer will be registered and no Title: new Note will be issued in the name of the Transferee, unless the signature to this assignment corresponds with the name as it appears upon the face of the within Note every particular, without alteration or enlargement or any change whatever and the Social Security or Federal Employer Identification Number of the Transferee is supplied. Signature Guaranteed by [member firm of the New York Stock Exchange or a commercial bank or a trust company.] A -6 SCHEDULE A Principal and Interest Repayment Schedule A -7 EXHIBIT B FORM OF ESCROW DEPOSIT AGREEMENT A -1 of Advertisement (that ran in the print rn Date Published end Medici Name oc\gin =; ne_t KakieMber acA Advertisement or Article NOTICE OF PUBLIC BEARING CITY OF OCOEE Notice is hereby given pursuant to the Charter of the City of Ocoee Florida (the "City ") that the Board of City Commissioners at a session to be held on December 6, 2011 at 7:15 p.m. or as soon thereafter as practical, will hold a Public Hearing at Ocoee City Hall, 150 N. Lakeshore Drive, Ocoee, Flori- da in order to consider the issuance of not to exceed 98,400,000 Capital Im- provement Refunding Revenue Note, Series 2011 for the purpose of refunding the remaining portion of the City's out- standing Capital Improvement Reve- • nue Bonds, Series 1999 (the "1999 i Bonds "). The 1999 Bonds were ssued to: (1) finance certain capital Im- provements within the City, including but not limited to, the construction of an Olympic -sized swimming pool and o bath house, the acquisition of adjoin- ing land and the construction of a ve- hicle fueling facility, a vehicle mainte- nance facility and an administration facility, the acquisition and construc- tion of the Police Department includ- ing land acquisition and building de- sign costs and the acquisition of park land, (ii) advance refund the City's outstanding Capitol Improvement Rev- , enue Bonds, Series 1991 (the "1991 Bonds ") and (111) currently refund the City's outstanding Capital improve- ment Revenue Promissory Note, Se- ries 1996 (the "1996 Nate "). Both the 1991 Bonds and the 1996 Note were is- sued to finance the cost of certain cap- itol improvements within the City. In- terested parties may appear at the meeting and be heard with respect to the proposed action. A copy of the pro- posed action may be examine at Ocoee City Hall, 150 N. Lakeshore Drive, Ocoee, Florida between the hours of 8:00 a.m. and 5:00 P.m., Mon- day through Friday. You are advised that if a person decides to appeal any decision made with respect to any matter considered at such hearing, he or she will need a record of proceed- ings and for such purpose may need to insure that a verbatim record of the proceeding is made, which record in- cludes the testimony and evidence up- on which the appeal is based. Persons with disabilities needing assistance to participate in any of these proceedings should contact the City Clerk's office 48 hours in advance of the meeting at (407) 656.2322. Beth-Eiyrnberry, CMC, City Clerk COij1)4833 11/23/2011 •