HomeMy WebLinkAboutResolution 041-2010 RESOLUTION NO. 41-10
Resolution Authorizing the Execution, Terms, Issuance, Sale and Payment of Sales
Tax Revenue Bonds in the Aggregate Principal Amount of not to exceed Seven
Million Dollars ($7,000,000), of the City of Brookings of Brookings County, SD.
Whereas, the City of Brookings (the "City") and Brookings County (the "County") are
intending to construct an Intergovernmental Administration Building to facilitate the efficient
use of governmental services; and
Whereas, the City and County intent to enter into an agreement for the joint use and
operation of the Intergovernmental Building; and
Whereas, each governmental entity must provide funds for the construction thereof; and
Whereas, the City of Brookings is authorized by the provisions of SDCL §§I 0-52-2.10 to issue
Sales Tax Revenue Bonds to fund capital improvements and land acquisition pursuant to the
provisions of Chapter 16 of the Revised Ordinances of Brookings, South Dakota; and
Whereas, the City Council has determined and does hereby declare that is necessary and in the
best interest of the City to issue Sales Tax Revenue Bonds for the purpose of providing funds
by appropriation to (i) acquire real property; (ii) construction of new Intergovernmental
Administration Building; and (iii) pay the Costs of Issuance of the Bonds described herein.
Now Therefore, Be It Resolved by the City Council of the City of Brookings of
Brookings County, as follows:
ARTICLE I
DEFINITIONS
Section 1.1. Definition of Terms.
In addition to the words and terms elsewhere defined in this Bond Resolution, the following
words and terms as used herein, whether or not the words have initial capitals, shall have the
following meanings, unless the context or use indicates another or different meaning or intent,
and such definitions shall be equally applicable to both the singular and plural forms of any of
the words and terms herein defined:
"Act" means collectively SDCL Chapter 6-8B and Chapter 10-52, as amended.
"Authorized Officer of the City" means the Mayor and the Finance Officer, or, in the case of
any act to be performed or duty to be discharged, any other member, officer, or employee of
the City then authorized to perform such act or discharge such duty.
"Bond Counsel" means Meierhenry Sargent LLP, a firm of attorneys recognized as having
experience in matters relating to the issuance of state or local governmental obligations.
"Book-Entry Form" or "Book-Entry System" means a form or system, as applicable, under which
physical certificates in fully registered form are issued to a Depository or to its nominee as
Registered Owner, with the certificated certificates being held by and "immobilized" in the
custody of such Depository, and under which records maintained by persons, other than the
City or the Registration Agent, constitute the written record that identifies, and records the
transfer of the beneficial "book-entry" interests in those Bonds.
"Bond Insurer" means a municipal bond insurance company which has the highest rating for the
rating agencies.
"Bond Payment Date" means each June I and December I in the years 2011 through 2030.
"Bond Purchase Agreement" means the agreement between the City and the Underwriter for
the purchase of the Bonds.
"Bond Resolution" means the within Resolution, duly adopted by the City Council on the date
hereof, as it may be amended from time to time.
"Bondholder", "Holder" and "Registered Owner" means the registered owner of a Bond,
including any nominee of a Depository.
"Bonds" mean not to exceed $7,000,000 of Sales Tax Revenue Bonds, Series 2010A, dated the
Closing Date, or such other designation or date as shall be determined by the City Council
pursuant to Section 8.1 hereof, authorized and issued under the Bond Resolution.
"City" means the City of Brookings, Brookings County, South Dakota, a home rule form of
municipality organized under the State of South Dakota.
"City Council" means the City Council of the City elected pursuant to the provisions of the
SDCL Title 9.
"City Finance Officer" means the City Finance Officer of the City appointed pursuant to the
provisions of South Dakota Codified Laws Title 9 or, in the absence of such appointment or in
the event the person so appointed is unable or incapable of acting in such capacity, the person
appointed by the City Council to perform the duties otherwise performed by the City Finance
Officer, or his/her designee.
"Closing Date" means the date the Bonds are exchanged for value.
"Code" means the Internal Revenue Code of 1986, as amended, and the applicable regulations
of the United States Department of Treasury promulgated thereunder as in effect on the date
of issuance of the Bonds.
"Costs of Issuance" means all costs, fees, charges and expenses incurred in connection with the
issuance of the Bonds, including costs for bond insurance and rating agency fees.
1
"Debt" means (I) indebtedness of the City for borrowed money or for the deferred purchase
price of property or services, and expressly including the obligation to pay principal and interest
on or with respect to revenue bonds, (2) the obligation of the City as lessee under leases which
should be recorded as capital leases under generally accepted accounting principles, and (3)
obligations of the City under direct or indirect guarantees in respect of, and obligations,
contingent or otherwise, to purchase or otherwise acquire, or otherwise to assure a creditor
against loss in respect of, indebtedness or obligations of others of the kinds referred to in
subdivisions (I) and (2) above.
"Depository" means any securities depository that is a clearing agency under federal laws
operating and maintaining, with its participants or otherwise, a Book-Entry System, including,
but not limited to DTC.
"DTC Participant(s)" means securities brokers and dealers, banks, trust companies and clearing
corporations that have access to the DTC system.
"DTC" means the Depository Trust Company, a limited purpose company organized under the
laws of the State of New York, and its successors and assigns.
"Improvements" means the acquisition of real property and construction of Intergovernmental
Administration Building.
"Interest Payment Dates" means each June I and December I, commencing June I, 2011.
"Intergovernmental Administration Building" means the joint County and City Building built
"Letter of Representation" means the Issuer Letter of Representations or Blanket Issuer Letter
of Representations to DTC of the City.
"Mayor" means the Mayor elected pursuant to the provisions of SDCL § 9-8-1 or his or her
designee acting on his or her behalf pursuant to the Charter.
"Minimum Reserve" means the lesser of (i) 10% of the original principal amount of, (ii) the
maximum annual debt service on or, (iii) 125% of the average annual debt service on, all
Outstanding Bonds having a parity lien on the Pledged Revenues.
"Official Statement" and "Preliminary Official Statement" means that Official Statement and
Preliminary Official Statement described in Section 8.2 hereof pertaining to the sale of the
Bonds.
"Original Issue Discount or O.I.D." means the difference between the issue price and the stated
redemption price at maturity. The stated redemption price is determined without regard to
optional call dates.
"Original Issue Premium or O.I.P." means the difference between the issue price and the stated
redemption price at maturity. The stated redemption price is determined without regard to
optional call dates.
2
"Outstanding", "Bonds Outstanding", or "Outstanding Bonds" means, as of a particular date all
Bonds issued and delivered under this Bond Resolution except: (I) any Bonds paid or
redeemed or otherwise canceled by the City at or before such date; (2) any Bond for the
payment of which cash, equal to the principal amount thereof with interest to date of maturity,
shall have theretofore been deposited prior to maturity by the City for the benefit of the
Owner thereof; (3) any Bond for the redemption of which cash, equal to the redemption price
thereof with interest to the redemption date, shall have theretofore been deposited with the
Registration Agent and for which notice of redemption shall have been mailed in accordance
with this Bond Resolution; (4) any Bond in lieu of or in substitution for which another Bond
shall have been delivered pursuant to this Resolution, unless proof satisfactory to the City is
presented that any Bond, for which a Bond in lieu of or in substitution therefor shall have been
delivered, is held by a bona fide Underwriter, as that term is defined in Article 8 of the Uniform
Commercial Code of the State, as amended, in which case both the Bond in lieu of or in
substitution for which a new Bond has been delivered and such new Bond so delivered therefor
shall be deemed Outstanding; and, (5) any Bond deemed paid under the provisions of Article VII
of this Resolution, except that any such Bond shall be considered Outstanding until the maturity
or redemption date thereof only for the purposes of being exchanged, transferred, or
registered.
"Person" means an individual, partnership, corporation, trust, or unincorporated organization,
or a governmental entity or agency or political subdivision thereof.
"Pledged Revenues" means the Sales Tax.
"President" means the President of the City Council who may act for the Mayor in the absence
of the Mayor.
"Purchase Agreement" means the Bond Purchase Agreement authorized pursuant to and
described in Section 8.1 hereof by and between the City and the Underwriter.
"Rating Agency" means one or more of the following rating agencies: Standard & Poor's Credit
Market Services, Moody's Investors Service Inc. and Fitch IBCA, Inc.
"Record Date" means such dates set forth in the Bond Purchase Agreement.
"Registration Agent" means Wells Fargo Bank, NA, Minneapolis, Minnesota, its successor or
successors hereafter appointed in the manner provided in Article VI hereof.
"Resolution" means this Bond Resolution.
"Reasonably Require Reserve" means an amount, if required, which will comply with the
Internal Revenue Regulations specifying the maximum amount in a reserve fund permitted to be
invested without regard to investment yield.
"Sales Tax" means the City two percent tax on the gross receipts of all persons engaged in
business within the jurisdiction of the City who are subject to the South Dakota Retail
3
Occupational Sales and Service Tax, SDCL ch. 10-45 and the two percent upon all transactions
or use, storage and consumption which are subject to the South Dakota Use Tax Act, SDCL
ch. 10-46 imposed by Chapter 78 of the City of Brookings Code.
"Schedule" means the principal and interest payment schedule for the Bonds.
"Surety" means a company licensed to do surety business in the State of South Dakota.
"Underwriter" means Northland Securities, Inc. acting for and on behalf of itself and such
securities dealers as it may designate.
Section 1.2. References to Resolution.
The words "hereof", "herein", "hereunder", and other words of similar import refer to this
Bond Resolution as a whole.
Section 1.3. References to Articles, Sections, Etc.
References to Articles, Sections, and other subdivisions of this Bond Resolution are to the
designated Articles, Sections, and other subdivisions of this Bond Resolution as originally
adopted.
Section 1.4. Headings.
The headings of this Bond Resolution are for convenience only and shall not define or limit the
provisions hereof.
ARTICLE II
FINDINGS
Section 2.1
It is hereby found, declared a necessity and determined by the City Council that all limitations
upon the issuance of Bonds have been met and the Bonds are being authorized, issued and sold
in accordance with the provisions of the Act.
ARTICLE III
AUTHORITY, PLEDGE, LEVY AND ACCOUNTS
Section 3.1 Authority.
In order to fund the acquisition and construction of the Improvements there shall be issued
pursuant to, and in accordance with, the provisions of the Act, the Bond Resolution, and other
applicable provisions of law, Sales Tax Revenue Bonds of the City in the aggregate principal
amount as finalized by the Bond Purchase Agreement.
4
Section 3.2 Pledge of Sales Tax.
The Sales Tax shall be and is hereby irrevocably pledged to the prompt and full payment of the
principal, premium and interest on each and all of said Bonds as such principal, premium and
interest respectively become due.
Section 3.3. Collection of Taxes.
Pursuant to SDCL § 10-52-2.10, the City does hereby pledge, provide and agree that it will
continue to impose and collect the non-ad valorem tax so long as the Bonds are outstanding.
The governing body shall also pledge so much of the collections of the taxes as may be
necessary to pay the principal, premium and interest on the bonds and to maintain any debt
service reserve established for the Bonds.
Section 3.4. Accounts.
(a) Special Revenue Fund. The Finance Officer has established and will maintain the Special
Revenue Fund as a separate and special account in the financial records of the City until all
Bonds issued and made payable therefrom, and interest due thereon, have been duly paid or
discharged. All collections of the Sales Tax shall be credited, as received, to the Special Revenue
Fund. Within the Special Revenue Fund are various separate accounts to be maintained by the
City.
(b) Construction Account. There is hereby created and established as an account of the Special
Revenue Fund, a "Construction Account" There shall be credited to the Construction Account
the proceeds from the sale of the Bonds remaining after (a) the deposit to the Reserve Account
required by Section 3.05, and (b) payment of the (i) underwriter's discount, (ii) original issue
discount and (iii) any other expenses of issuing the Bonds. All moneys credited to the
Construction Account shall be applied solely to the payment of the costs of the Improvements.
For the purposes of this Resolution, "costs of the Improvements" shall include costs of
acquiring, constructing, and installing the Improvements including costs of labor, services,
materials and supplies, financial, architectural, engineering, legal, accounting and other
professional expenses relating to the Improvements, the costs of acquisition or properties,
rights, easements, or other interest in properties, insurance premiums, and the costs of
publishing, posting or mailing notices in connection with the Improvements. All sums derived
from the investment of moneys in the Construction Account shall remain in and become part
of such fund. Upon completion of the Improvements and when all costs of the Improvements
have been paid, any balance remaining in the Construction Account shall be credited to the
Principal and Interest Account hereinafter established.
(c) Principal and Interest Account. There is hereby created and established as an account of the
Special Revenue Fund, a "Principal and Interest Account." Immediately upon delivery of the
Bonds, there shall be credited to the Principal and Interest Account the amount of accrued
interest received from the Underwriter. Commencing on the date specified in the Bond
5
Purchase Agreement, there shall be withdrawn from the Special Revenue Fund at least monthly
and credited to the Principal and Interest Account an amount which will equal at least one-sixth
(1/6th) of the interest becoming due on the next succeeding payment date and one-twelfth
(I/12th) of the principal becoming due on the next succeeding payment dates with respect to
the Outstanding Bonds. In all events there shall be credited to the Principal and Interest
Account amounts sufficient to pay the principal of and interest on the Outstanding Bonds as the
same become due.
(d) Reserve Account. There is hereby created and established as an account of the Special
Revenue Fund, a "Reserve Account." There shall be credited to the Reserve Account from the
proceeds of the Bonds, an amount equal to the Minimum Reserve. Thereafter, in the event that
the amount on deposit in the Reserve Account shall thereafter fall below the Minimum Reserve,
additional deposits shall be made from the Pledged Revenues to the Reserve Account until the
Minimum Reserve is again reached. Upon the issuance of any parity lien bonds, the Minimum
Reserve established in this section shall be increased to an amount equal to the combined
maximum annual debt service on the Outstanding Bonds. The balance required shall be funded
on the delivery date of the parity lien bonds. Moneys credited to the Reserve Account may be
used only for the payment of principal of and interest on the Outstanding Bonds and shall be
used only in the event that there are insufficient moneys in the Principal and Interest Account
to meet such principal and interest payments promptly when due. The interest from any
investment of the Reserve Account may be transferred from time to time to the Construction
Account, provided that after completion of the Improvements such interest shall be transferred
to the Principal and Interest Account. No transfer of investment income shall be made from the
Reserve Account at any time when the balance therein is less than the Minimum Reserve. Such
investments shall be subject to the limitations of South Dakota law.
(e) Subordinate Lien Bonds. After making the above required payments, any remaining Pledged
Revenues may be used for the payment of the principal of and interest on any additional sales
tax revenue bonds having a lien which is subordinate to the lien of the Outstanding Bonds, and
for a reserve fund as additional security for the payment of such subordinate lien bonds.
(f) Other Expenditures. The remaining Pledged Revenues may be used for any legally
authorized purpose.
ARTICLE IV
FORM, TERMS, EXECUTION, AND TRANSFER OF BONDS
Section 4.1. Authorized Bonds.
The aggregate principal amount of Bonds that may be issued under the Bond Resolution shall
not exceed Seven Million and No/100 Dollars ($7,000,000).
6
Section 4.2. Form of Bonds; Execution.
(a) The Bonds are issuable only as fully registered Bonds, without coupons, in any
denomination. All Bonds issued under the Resolution shall be substantially in the form set forth
in Exhibit A attached hereto, and by this reference incorporated herein as fully as though
copied.
(b) The Bonds shall be executed in such manner as may be prescribed by applicable law in the
name and on behalf of the City with the manual or facsimile signature of the Mayor, attested by
the manual or facsimile signature of the City Finance Officer, and approved as to form and
countersigned by a Resident Attorney by his manual or facsimile signature.
(c) In the event any officer whose manual or facsimile signature shall appear on any Bonds shall
cease to be such officer before the delivery of such Bonds, such manual or such facsimile
signature shall nevertheless be valid and sufficient for all purposes as if he or she had remained
in office until such delivery. Any Bonds may bear the facsimile signature of, or may be manually
signed by, such individuals who, at the actual time of the execution of such Bonds, were the
proper officers of the City to sign such Bonds, although on the date of the adoption by the City
of this Resolution, such individuals may not have been such officers.
(d) In the event that the Bonds are issued as Build America Bonds under Section 54AA of the
Code or Recovery Zone Economic Development Bonds under Section 1400U of the Code,
then the form of the Bonds shall comply with the requirements thereof.
Section 4.3 Maturities, Interest Rates, and Certain Other Provisions of Bonds.
(a) The Bonds shall become due and payable and be subject to the terms and conditions as are
set forth in the Bond Purchase Agreement.
(b) The Bonds shall be designated "Sales Tax Revenue Bonds, Series 20I0A," or such other
designation as shall be determined by the City Council pursuant to Section 8.1 hereof. The
Bonds shall bear interest from their date or from the most recent interest payment date to
which interest has been paid or duly provided for, until the principal amount of the Bonds is
paid, such interest (computed upon the basis of a 360-day year of twelve 30-day months) being
payable on Interest Payment Dates. Interest on each Bond shall be paid by wire transfer, check
or draft of the Paying Agent, payable in lawful money of the United States of America, to the
person in whose name such Bond is registered at the close of business on the Record Date.
The principal of the Bond shall be payable in lawful money of the United States of America at
the principal office of the Paying Agent on the Bond Payment Date. Each Bond shall state that it
is issued pursuant to the Act.
(c) The Registration Agent shall make all interest payments with respect to the Bonds on
each interest payment date directly to the registered owners as shown on the bond registration
records maintained by the Registration Agent as of the close of business on the Record Date by
wire transfer, check or draft mailed to such owners at their addresses shown on said bond
registration records, without, except for final payment, the presentation or surrender of such
7
registered Bonds, and all such payments shall discharge the obligations of the City in respect of
such Bonds to the extent of the payments so made. Payment of principal and premium, if any,
on the Bonds shall be made upon presentation and surrender of such Bonds to the Registration
Agent as the same shall become due and payable.
Section 4.4 Negotiability of Bonds.
All Bonds issued under this Resolution shall be negotiable, subject to the provisions for
registration and transfer contained in this Resolution and in the Bonds.
Section 4.5 Registration, Transfer and Exchange of Bonds.
(a) The Bonds are transferable only by presentation to the Registration Agent by the registered
owner, or his legal representative duly authorized in writing, of the registered bond(s) to be
transferred with the form of assignment on the reverse side thereof completed in full and
signed with the name of the registered owner as it appears upon the face of the bond(s)
accompanied by appropriate documentation necessary to prove the legal capacity of any legal
representative of the registered owner. Upon receipt of the bond(s) in such form and with such
documentation, if any, the Registration Agent shall issue a new bond or bonds to the assignee(s)
in $5,000 denominations, or integral multiples thereof, as requested by the registered owner
requesting transfer. The Registration Agent shall not be required to transfer or exchange any
bond during the period commencing on a Record Date and ending on the corresponding
interest payment date of such bond, nor to transfer or exchange any bond after the publication
of notice calling such bond for redemption has been made, nor to transfer or exchange any
bond during the period following the receipt of instructions from the City to call such bond for
redemption; provided, the Registration Agent, at its option, may make transfers after any of said
dates. No charge shall be made to any registered owner for the privilege of transferring any
Bonds, provided that any transfer tax relating to such transaction shall be paid by the registered
owner requesting transfer. The person in whose name any bond shall be registered shall be
deemed and regarded as the absolute owner thereof for all purposes and neither the City nor
the Registration Agent shall be affected by any notice to the contrary whether or not any
payments due on the Bonds shall be overdue. Bonds, upon surrender to the Registration Agent,
may, at the option of the registered owner, be exchanged for an equal aggregate principal
amount of Bonds of the same maturity in any authorized denomination or denominations.
(b) Except as otherwise provided in this subsection or in the Bond Purchase Agreement, the
Bonds shall be registered in the name of Cede & Co., as nominee of DTC, which will act as
securities depository for the bond. References in this Section to a Bond or the Bonds shall be
construed to mean the Bond or the Bonds that are held under the Book-Entry System. One
Bond for each maturity shall be issued to DTC and immobilized in its custody. Unless otherwise
provided herein, a Book-Entry System shall be employed, evidencing ownership of the Bonds in
authorized denominations, with transfers of beneficial ownership affected on the records of
DTC and the DTC Participants pursuant to rules and procedures established by DTC.
8
Each DTC Participant shall be credited in the records of DTC with the amount of such DTC
Participant's interest in the Bonds. Beneficial ownership interests in the Bonds may be
purchased by or through DTC Participants. The holders of these beneficial ownership interests
are herein referred to as the "Beneficial Owners." The Beneficial Owners shall not receive the
Bonds representing their beneficial ownership interests. The ownership interests of each
Beneficial Owner shall be recorded through the records of the DTC Participant from which
such Beneficial Owner purchased its Bonds. Transfers of ownership interests in the Bonds shall
be accomplished by book entries made by DTC and, in turn, by DTC Participants acting on
behalf of Beneficial Owners. SO LONG AS CEDE & CO., AS NOMINEE FOR DTC, IS THE
REGISTERED OWNER OF THE BONDS THE REGISTRATION AGENT SHALL TREAT CEDE
& CO., AS THE ONLY HOLDER OF THE BONDS FOR ALL PURPOSES UNDER THIS
RESOLUTION, INCLUDING RECEIPT OF ALL PRINCIPAL OF, PREMIUM, IF ANY, AND
INTEREST ON THE BONDS, RECEIPT OF NOTICES, VOTING AND REQUESTING OR
DIRECTING THE REGISTRATION AGENT TO TAKE OR NOT TO TAKE, OR
CONSENTING TO, CERTAIN ACTIONS UNDER THIS BOND RESOLUTION.
Payments of principal, interest, and redemption premium, if any, with respect to the Bonds, so
long as DTC is the only owner of the Bonds, shall be paid by the Registration Agent directly to
DTC or its nominee, Cede & Co., as provided in the Letter of Representation. DTC shall remit
such payments to DTC Participants, and such payments thereafter shall be paid by DTC
Participants to the Beneficial Owners. Neither the City nor the Registration Agent shall be
responsible or liable for payment by DTC or DTC Participants, for sending transaction
statements or for maintaining, supervising or reviewing records maintained by DTC or DTC
Participants.
In the event that (I) DTC determines not to continue to act as securities depository for the
Bonds or (2) the City determines that the continuation of the Book-Entry System of evidence
and transfer of ownership of the Bonds would adversely affect their interests or the interests of
the Beneficial Owners of the Bonds, the City may discontinue the Book-Entry System with
DTC. If the City fails to identify another qualified securities depository to replace DTC, the
City shall cause the Registration Agent to authenticate and deliver replacement Bonds in the
form of fully registered Bonds to each Beneficial Owner.
NEITHER THE CITY NOR THE REGISTRATION AGENT SHALL HAVE ANY
RESPONSIBILITY OR OBLIGATIONS TO ANY DTC PARTICIPANT OR ANY BENEFICIAL
OWNER WITH RESPECT TO (i) THE BONDS; (ii) THE ACCURACY OF ANY RECORDS
MAINTAINED BY DTC OR ANY DTC PARTICIPANT; (iii) THE PAYMENT BY DTC OR
ANY DTC PARTICIPANT OF ANY AMOUNT DUE TO ANY BENEFICIAL OWNER IN
RESPECT OF THE PRINCIPAL OF AND INTEREST ON THE BONDS; (iv) THE DELIVERY
OR TIMELINESS OF DELIVERY BY DTC OR ANY DTC PARTICIPANT OF ANY NOTICE
DUE TO ANY BENEFICIAL OWNER THAT IS REQUIRED OR PERMITTED UNDER THE
TERMS OF THIS BOND RESOLUTION TO BE GIVEN TO BENEFICIAL OWNERS, (v) THE
SELECTION OF BENEFICIAL OWNERS TO RECEIVE PAYMENTS IN THE EVENT OF ANY
PARTIAL REDEMPTION OF THE BONDS; OR (vi) ANY CONSENT GIVEN OR OTHER
ACTION TAKEN BY DTC, OR ITS NOMINEE, CEDE & CO., AS OWNER.
9
SO LONG AS A BOOK-ENTRY SYSTEM OF EVIDENCE OF TRANSFER OF OWNERSHIP
OF ALL THE BONDS IS MAINTAINED IN ACCORDANCE HEREWITH, THE PROVISIONS
OF THIS RESOLUTION RELATING TO THE DELIVERY OF PHYSICAL BONDS SHALL BE
DEEMED INAPPLICABLE OR BE OTHERWISE SO CONSTRUED AS TO GIVE FULL EFFECT
TO SUCH BOOK-ENTRY SYSTEM. IF THE PROVISIONS OF THE LETTER OF
REPRESENTATION SHALL BE IN CONFLICT WITH THE PROVISIONS OF THIS
RESOLUTION AS SAID PROVISIONS RELATE TO DTC, THE PROVISIONS OF THE LETTER
OF REPRESENTATION SHALL CONTROL.
Section 4.6 Mutilated, Lost, Stolen, or Destroyed Bonds.
(a) In the event any bond is mutilated, lost, stolen, or destroyed, the City may execute, and
upon the request of an Authorized Officer of the City the Registration Agent shall authenticate
and deliver, a new bond of like maturity, interest rate, and principal amount, and bearing the
same number (but with appropriate designation indicating that such new bond is a replacement
bond) as the mutilated, destroyed, lost, or stolen bond, in exchange for the mutilated bond or
in substitution for the bond so destroyed, lost, or stolen. In every case of exchange or
substitution, the bondholder shall furnish to the City and the Registration Agent: (I) such
security or indemnity as may be required by them to save each of them harmless from all risks,
however remote; and, (2) evidence to their satisfaction of the mutilation, destruction, loss, or
theft of the subject bond and the ownership thereof. Upon the issuance of any bond upon such
exchange or substitution, the City and the Registration Agent may require the Owner thereof
to pay a sum sufficient to defray any tax or other governmental charge that may be imposed in
relation thereto and any other expenses, including printing costs and counsel fees, of the City
and the Registration Agent. In the event any bond which has matured or is about to mature
shall become mutilated or be destroyed, lost, or stolen, the City may, instead of issuing a bond
in exchange or substitution therefor, pay or authorize the payment of the same (without
surrender thereof except in the case of a mutilated bond) if the Owner thereof shall pay all
costs and expenses, including attorneys fees, incurred by the City and the Registration Agent in
connection herewith, as well as a sum sufficient to defray any tax or other governmental charge
that may be imposed in relation thereto and shall furnish to the City and the Registration Agent
such security or indemnity as they may require to save them harmless and evidence to the
satisfaction of the City and the Registration Agent the mutilation, destruction, loss, or theft of
such bond and of the ownership thereof.
(b) Every bond issued pursuant to the provisions of this section shall constitute an additional
contractual obligation of the City (whether or not the destroyed, lost, or stolen bond shall be
found at any time to be enforceable) and shall be entitled to all the benefits of this Bond
Resolution equally and proportionately with any and all other Bonds duly issued under this
Bond Resolution.
(c) All Bonds shall be held and owned upon the express condition that the provisions of this
Section are exclusive, with respect to the replacement or payment of mutilated, destroyed, lost,
or stolen Bonds, and, to the maximum extent legally permissible, shall preclude all other rights
10
or remedies, notwithstanding any law or statute now existing or hereafter enacted to the
contrary.
Section 4.7 Authentication.
The Registration Agent is hereby authorized to authenticate and deliver the Bonds to the
Underwriter or as it may designate upon receipt by the City of the proceeds of the sale
thereof, to authenticate and deliver Bonds in exchange for Bonds of the same principal amount
delivered for transfer upon receipt of the bond(s) to be transferred in proper form with proper
documentation as hereinabove described. The Bonds shall not be valid for any purpose unless
authenticated by the Registration Agent by the manual signature of an officer thereof on the
certificate set forth herein on the bond form.
Section 4.8 Qualification for DTC.
The Registration Agent is hereby authorized to take such actions as may be necessary from
time to time to qualify and maintain the Bonds for deposit with DTC, including but not limited
to, wire transfers of interest and principal payments with respect to the Bonds, utilization of
electronic book entry data received from DTC in place of actual delivery of Bonds and
provision of notices with respect to Bonds registered by the DTC (or any of its designees
identified to the Registration Agent) by overnight delivery, courier service, telegram, telecopy
or other similar means of communication. No such arrangements with DTC may adversely
affect the interest of any of the Owners of the Bonds, provided, however, that the Registration
Agent shall not be liable with respect to any such arrangements it may make pursuant to this
section.
Section 4.9 Bond Insurer or Surety. The Mayor and Finance Officer are authorized to
enter into an agreement with a Bond Insurer or Surety as may be required under the Purchase
Agreement. Any terms or conditions of the Bond Insurer or Surety shall be attached to this
resolution and incorporated herein as if stated in full.
Section 4.10. Rating Agency. The Mayor and Finance Officer are authorized to enter into
an agreement with a Rating Agency as may be required under the Purchase Agreement. Any
terms or conditions of the Rating Agency shall be attached to this resolution and incorporated
herein as if stated in full.
Section 4.1 1. Taxable Bonds.
All or any portion of the Bonds may, subject to the parameters set forth above, be issued as
Build America Bonds or Recovery Zone Economic Development Bonds and in connection
therewith, each of Authorized Officer of the City is authorized to make, for and on behalf of
and as the act of the City, any and all designations or irrevocable elections, to execute and
deliver any agreements, Bonds or other instruments to or with the federal government or any
agency thereof or the State of South Dakota or any agency thereof, and to take any other
11
actions necessary for the Bonds, the holders of the Bonds and the City to receive any benefits,
funds or federal subsidies available under Code.
ARTICLE V
REDEMPTION OF BONDS PRIOR TO MATURITY
Section 5.1 Redemption.
(a) Redemption. The Bonds shall be redeemable as set forth in the Bond Purchase
Agreement.
ARTICLE VI
REGISTRATION AGENT
Section 6.1. Appointment and Acceptance of Duties.
(a) The City hereby authorizes the City Finance Officer to appoint the Registration Agent
with respect to the Bonds and authorizes and directs the Registration Agent to maintain bond
registration records with respect to the Bonds, to authenticate and deliver the Bonds as
provided herein, either at original issuance, upon transfer, or as otherwise directed by the City,
to effect transfers of the Bonds, to give all notices of redemption as required herein, to make all
payments of principal and interest with respect to the Bonds as provided herein, to cancel and
destroy Bonds which have been paid at maturity or upon earlier redemption or submitted for
exchange or transfer, to furnish the City at least annually a certificate of destruction with
respect to Bonds canceled and destroyed, and to furnish the City at least annually an audit
confirmation of Bonds paid, Bonds Outstanding and payments made with respect to interest on
the Bonds. The Mayor and the City Finance Officer, or either of them is hereby authorized to
execute and the City Finance Officer is hereby authorized to attest such written agreement
between the City and the Registration Agent as they shall deem necessary or proper with
respect to the obligations, duties and rights of the Registration Agent. The payment of all
reasonable fees and expenses of the Registration Agent for the discharge of its duties and
obligations hereunder or under any such agreement is hereby authorized and directed.
Section 6.2. Permitted Acts and Functions.
The Registration Agent may become the Owner of any Bonds, with the same rights as it would
have if it were not a Registration Agent. The Registration Agent may act as an Underwriter or
fiscal agent in connection with the sale of the Bonds or of any other securities offered or issued
by the City.
Section 6.3. Resignation or Removal of the Registration Agent and Appointment of
Successors.
(a) The Registration Agent may at any time resign and be discharged of the duties and
obligations created by the Bond Resolution by giving at least sixty (60) calendar days' written
12
notice to the City Finance Officer. The Registration Agent may be removed at any time by the
City Finance Officer, provided that such removal does not constitute a breach of any
contractual agreement with any such Registration Agent, by filing written notice of such
removal with such Registration Agent. Any successor Registration Agent shall be appointed by
the City Finance Officer and shall be a trust company or a bank having the powers of a trust
company, having a combined capital, surplus, and undivided profits aggregating at least Forty
Million Dollars ($40,000,000), willing to accept the office of Registration Agent on reasonable
and customary terms and authorized by law to perform all the duties imposed upon it by the
Bond Resolution.
(b) In the event of the resignation or removal of the Registration Agent, such Registration
Agent shall pay over, assign and deliver any monies and securities held by it as Registration
Agent, and all books and records and other properties held by it as Registration Agent, to its
successor, or if there be no successor then appointed, to the City Finance Officer until such
successor be appointed.
Section 6.4. Merger or Consolidation of Registration Agent.
Any corporation or association into which the Registration Agent may be converted or
merged, or with which it may be consolidated, or to which it may sell or transfer its trust
business and assets as a whole, or substantially as a whole, or any corporation or association
resulting from any such conversion, sale, merger, consolidation, or transfer to which it is a
party shall be and become successor Registration Agent hereunder and shall be vested with all
the trusts, powers, discretion, immunities, privileges, and other matters as was its predecessor,
without the execution or filing of any instrument or any further act, deed, or conveyance on
the part of any of the parties hereto, anything herein contained to the contrary
notwithstanding. Upon any such conversion, merger, consolidation, sale or transfer, the City
Finance Officer shall have the right and option, upon notice to such converted, merged,
consolidated or acquiring entity, to remove such entity and appoint a successor thereto
pursuant to the procedures and requirements set forth in Section 6.3 hereof.
ARTICLE VII
ADDITIONAL BONDS
The City may issue additional bonds (the "Parity Bonds") payable from the Pledged Revenues
and having a lien upon such revenues on a parity with the Bonds and the Outstanding Parity
Bonds providing that:
I. the City is current in the payment of principal and interest on the Outstanding
Bonds and is current in the collections required for the Principal and Interest Account and the
Reserve Account.
2. the City is in compliance with all covenants of outstanding sales tax revenue bonds
and
13
3. the Pledged Revenues collected by the City in the last preceding fiscal year are
sufficient to cover 1.25 times the combined average annual principal and interest requirements
on the Outstanding Bonds and the proposed Parity Bonds.
ARTICLE VIII
SALE OF BONDS AND DEPOSIT OF PROCEEDS
Section 8.1. Sale of Bonds.
The Bonds shall be sold to the Underwriter at a price of not less than 98% of par less any
Original Issue Discount on the Bonds plus accrued interest. The Mayor and the Finance Officer,
or either of them, in consultation with the Underwriter, is authorized to make such changes in
the structuring of the terms and sale of the Bonds as they shall deem necessary. In this regard,
they, or either of them, in consultation with the Underwriter, are authorized to cause to be
sold an aggregate principal amount of the Bonds less than that authorized herein, to sell any or
all of the Bonds as term Bonds with annual mandatory redemption requirements which will
produce substantially the same annual principal reductions as authorized herein, to change the
dated date of the Bonds, and to adjust principal and interest payment dates and redemption
dates of the Bonds. The form of the bond set forth in Exhibit A attached hereto shall be
conformed to reflect any changes, if any, as hereinbefore mentioned. The Mayor and the City
Finance Officer, or either of them, are hereby authorized to execute and the City Finance
Officer is authorized to attest the Bond Purchase Agreement with the Underwriter providing
for the purchase and sale of the Bonds. The Bond Purchase Agreement shall be in form and
content acceptable to the Mayor and City Finance Officer, the execution thereof by either of
them to constitute conclusive evidence thereof, and approved as to form and legality by the
City's attorney; provided the Bond Purchase Agreement effects the sale of the Bonds in
accordance with the provisions of this Resolution, and is not inconsistent with the terms
hereof. The Mayor and the City Finance Officer are authorized to cause the Bonds to be
authenticated and delivered by the Registration Agent to the Underwriter and to execute,
publish, and deliver all Bonds and documents, including the Official Statement, and closing
Bonds and documents, as they shall deem necessary in connection with the sale and delivery of
the Bonds.
Section 8.2. Official Statement.
The Mayor, Finance Officer, and the Underwriter are hereby authorized and directed to
provide for the preparation and distribution of a Preliminary Official Statement describing the
Bonds in the form of the Preliminary Official Statement. After the Bonds have been sold, the
Mayor and Finance Officer shall make such completions, omissions, insertions and changes in
the Preliminary Official Statement not inconsistent with this resolution as are necessary or
desirable to complete it as a final Official Statement for purposes of Rule I 5c2-I 2(e)(3) of the
Securities and Exchange Commission. The Mayor and Finance Officer shall arrange for the
delivery to the Underwriter the Official Statement within seven business days after the Bonds
have been sold in an electronic format as prescribed by the MSRB.
14
The Mayor and Finance Officer are authorized, on behalf of the City, to deem the Preliminary
Official Statement and the Official Statement in final form, each to be final as of its date within
the meaning of Rule 15c2-12(b)(I), except for the omission in the Preliminary Official
Statement of certain pricing and other information allowed to be omitted pursuant to such Rule
I 5c2-12(b)(I). The distribution of the Preliminary Official Statement and the Official Statement
in final form shall be conclusive evidence that each has been deemed in final form as of its date
by the City except for the omission in the Preliminary Official Statement of such pricing and
other information.
Section 8.3. Disposition of Bond Proceeds.
The proceeds of the sale of the Bonds shall be deposited in the Sales Tax Fund. The cost shall
include costs incident to the issuance and sale of the Bonds pursuant to SDCL 6-8B-20 and
capitalized interest, if any.
Section 8.4. Tax Matters.
(a) Notwithstanding Sections 8.4(b) through 8.4(f), any series of Bonds which are
designated Build America Bonds or Recovery Zone Economic Development Bonds shall
be issued in accordance with the rules and regulation provided therefore. Prior to
closing of the Bonds, the officers of the City shall review the issue price of the Bonds as
reported on http://emma.msrb.org to make sure that the bonds are being sold in
accordance with the Code.
(b) The City covenants and agrees with the registered owners 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 includable in
gross income for federal income tax purposes under the Code and applicable Treasury
Regulations (the "Regulations"), and covenants to take any and all actions within its
powers to ensure that the basic interest on the Bonds will not become includable in
gross income for federal income tax purposes under the Code and the Regulations.
(c) The Mayor and the City Finance Officer, being the officers of the City charged with the
responsibility for issuing the Bonds pursuant to this Resolution are hereby authorized
and directed to execute and deliver to the Underwriter thereof a certificate in
accordance with the provisions of Section 148 of the Code, and Section 1.148-2(b) of
the Regulations, stating that on the basis of facts, estimates and circumstances in
existence on the date of issue and delivery of the Bonds, it is reasonably expected that
the proceeds of the Bonds will be used in a manner that would not cause the Bonds to
be "arbitrage bonds" within the meaning of Section 148 of the Code and the
Regulations.
(d) The City shall file with the Secretary of the Treasury a statement concerning the Bonds
containing the information required by Section 149(e) of the Code.
15
ARTICLE IX
MISCELLANEOUS
Section 9.1. Failure to Present Bonds.
(a) Subject to the provisions of Section 4.7 hereof, in the event any Bond shall not be
presented for payment when the principal or redemption price hereof becomes due, either at
maturity or at the date fixed for prior redemption thereof or otherwise, and in the event
monies sufficient to pay such Bond shall be held by the Registration Agent for the benefit of the
Owner thereof, all liability of the City to such Owner for the payment of such Bond shall
forthwith cease, determine, and be completely discharged. Whereupon, the Registration Agent
shall hold such monies, without liability for interest thereon, for the benefit of the Owner of
such Bond who shall thereafter be restricted exclusively to such monies for any claim under the
Resolution or on, or with respect to, said Bonds.
(b) If any Bond shall not be presented for payment within a period of five years following the
date when such Bond becomes due, whether by maturity or otherwise, the Registration Agent
shall, subject to the provisions of any applicable escheat or other similar law, pay to the City
any monies then held by the Registration Agent for the payment of such Bond and such Bond
shall (subject to the defense of any applicable statute of limitation) thereafter constitute an
unsecured obligation of the City.
Section 9.2. Payments Due on Saturdays, Sundays, and Holidays.
In any case where the date of maturity or interest on or principal of any Bonds, or the date
fixed for redemption of any Bonds, shall be a Saturday or Sunday or shall be, at the place
designated for payment, a legal holiday or a day on which banking institutions similar to the
Registration Agent are authorized by law to close, then the payment of the interest on, or the
principal, or the redemption price of, such Bond need not be made on such date but must be
made on the next succeeding day not a Saturday, Sunday, or a legal holiday or a day upon which
banking institutions similar to the Registration Agent are authorized by law to close, with the
same force and effect as if made on the date of maturity or the date fixed for redemption, and
no interest shall accrue for the period after such date.
Section 9.3. Miscellaneous Acts.
The appropriate officers of the City are hereby authorized, empowered, and directed to do any
and all such acts and things, and to execute, acknowledge, deliver, and, if applicable file or
record, or cause to be filed or recorded, in any appropriate public offices, all such documents,
instruments, and certifications, in addition to those acts, things, documents, instruments, and
certifications hereinbefore authorized and approved, as may, in their discretion, be necessary or
desirable to implement or comply with the intent of the Bond Resolution, or any of the
documents herein authorized and approved, or for the authorization, issuance, and delivery by
the City of the Bonds.
16
Section 9.4. Amendment.
The City Council is hereby authorized to make such amendments to the Bond Resolution as
will not impair the rights of the Bondholders.
Section 9.5. No Recourse Under Bond Resolution or on Bonds.
All stipulations, promises, agreements, and obligations of the City contained in the Resolution
or any supplemental resolutions shall be deemed to be the stipulations, promises, agreements,
and obligations of the City and not of any officer, director, or employee of the City in his or
her individual capacity, and no recourse shall be had for the payment of the principal of or
interest on the Bonds or for any claim based thereon or on the Resolution against any officer,
director, or employee of the City or against any official or individual executing the Bonds.
Section 9.6. Partial Invalidity.
If any one or more of the provisions of the Bond Resolution, or of any exhibit or attachment
thereto, shall be held invalid, illegal, or unenforceable in any respect, by final decree of any
court of lawful jurisdiction, such invalidity, illegality, or unenforceability shall not affect any other
provision hereof, or of any exhibit or attachment thereto, but the Bond Resolution, and the
exhibits and attachments thereto, shall be construed the same as if such invalid, illegal, or
unenforceable provision had never been contained herein, or therein, as the case may be.
Section 9.7. Continuing Disclosure.
The City hereby covenants and agrees that it will provide financial information and material
event notices as required by Rule 15c2-12 of the Securities Exchange Commission for the
Bonds. The Mayor is authorized to execute at the Closing of the sale of the Bonds, an
agreement for the benefit of and enforceable by the owners of the Bonds specifying the details
of the financial information and material event notices to be provided and its obligations relating
thereto. Failure of the City to comply with the undertaking herein described and to be detailed
in said closing agreement, shall not be a default hereunder, but any such failure shall entitle the
owner or owners of any of the Bonds to take such actions and to initiate such proceedings as
shall be necessary and appropriate to cause the City to comply with its undertaking as set forth
herein and in said agreement, including the remedies of mandamus and specific performance.
Section 9.8. Post Issuance Compliance.
The City does hereby adopt Meierhenry Sargent LLP Post Issuance Compliance Manual
procedures with regard to the Bonds. The City directs the Finance Officer and City Clerk to
formalize the written procedures.
17
Section 9.9. Conflicting Resolutions Repealed.
All resolutions or parts thereof in conflict herewith are, to the extent of such conflict, hereby
repealed.
Said motion was made by Council Member Bartley, seconded by Council Member
Whaley. Upon vote being taken the following voted AYE: Bartley, Bezdichek, Kubal, Reed,
Thorpe, and Whaley, and the following voted NAY: None. Council Member McClemans was
absent.
CITY OF BROOKINGS
&et
Tim Reed, Mayor
i n oq:a,
I ,
er,p_, nes, City Clerk
18
EXHIBIT A-(FORM OF BOND)
UNITED STATES OF AMERICA
STATE OF SOUTH DAKOTA
CITY OF BROOKINGS
BROOKINGS COUNTY, SOUTH DAKOTA
SALES TAX REVENUE BONDS SERIES 2010A
REGISTERED REGISTERED
No. «No» $«AMOUNT» .00
Interest Rate Maturity Date Bond Date CUSIP No.
«INTEREST_RATE» «maturity» «cusip»
Registered Owner: Cede & Co.
55 Water Street, 1st Floor
New York, New York 10041
Tax ID #13-25551I9
Principal Amount: «Dollarlong» AND NO\I00 DOLLARS
REFERENCE IS HEREBY MADE TO THE FURTHER PROVISIONS OF
THE CERTIFICATE SET FORTH ON THE FOLLOWING PAGES, WHICH
FURTHER PROVISIONS SHALL FOR ALL PURPOSES HAVE THE SAME
EFFECT AS IF SET FORTH AT THIS PLACE.
It is hereby certified and recited that all conditions, acts and things required by law
to exist or to be done precedent to and in the issuance of this Bond did exist, have happened,
been done and performed in regular and due form and time as required by law.
(BOND INSURANCE LANGUAGE INSERTED HERE)
This Bond shall not be valid or become obligatory for any purpose or be entitled to
any benefit or security under the Resolution until it shall have been authenticated by the
execution by the Registrar of the certificate of authentication endorsed hereon.
IN WITNESS WHEREOF, the City has caused this Bond to be signed by the manual or
facsimile signature of its Mayor of the City and to be countersigned by the manual or facsimile
r oo. gi�": e of its City Finance Officer all as of the Bond Date specified above.
'2-P\` %
CITY OF OKINGS, SD
w.ltift •
Spa Thornes, City Clerk Tim Reed, Mayor
COUNTERSIGNED:
./ —#'446Y=4"
City Attorney
19
CERTIFICATE OF AUTHENTICATION
This bond is a bond of the series designated therein and has been issued under the
provisions of the within-mentioned Resolution and the date of its authentication is
, 2010.
Wells Fargo Bank, NA
Minneapolis, Minnesota
Bond Registrar and Paying Agent
By:
Authorized Officer
KNOW ALL MEN BY THESE PRESENTS: That the City of Brookings, South Dakota
(the "City"), in Brookings County, South Dakota, hereby acknowledges itself to owe and for
value received promises to pay, to the Registered Owner mentioned above in lawful money of
the United States of America, together with interest thereon from the Bond Date mentioned
above at the Interest Rate mentioned above. The interest hereon is payable June I, 2011 and
semiannually thereafter on June I and December I in each year to maturity or earlier
redemption by wire transfer, check or draft mailed to the Registered Owner at its address as it
appears on the Bond registration books of the City maintained by Wells Fargo Bank, NA,
Minneapolis, Minnesota, as Bond registrar and paying agent (the "Registrar"), on the close of
business on May 15 and November 15 immediately preceding the interest payment date (the
"Record Date"). The principal hereof due at maturity or upon redemption prior to maturity is
payable at the office of Registrar upon presentation and surrender of this Bond at maturity or
upon earlier redemption. The principal of, premium (if any) and interest on this Bond is payable
in any coin or currency of the United States of America which, at the time of payment, is legal
tender for the payment of public and private debts.
This Bond is one of an authorized issue of Bonds limited in aggregate principal amount
to a maximum of $7,000,000 (the "Bonds") all of like date and tenor except as to maturity,
interest rates and privileges of redemption, the proceeds of this issue (Series 2010A) will be
used for the purpose of the acquisition of real property and construction of new city/county
offices., pursuant to a resolution duly and regularly adopted by the City (the "Bond
Resolution"), and are subject to all the provisions and limitations of the Resolution and
Chapters 10-52 and 6-8B, South Dakota Codified Laws, as amended. The City has pledged and
agreed to collect, so long as the Bonds are outstanding, non-ad valorem tax (the "Sales Tax")
in an amount sufficient to pay principal, premium and interest when due on the Bonds.
20
[Redemption Provisions]
This Bond is transferable by the registered holder hereof in person or by his attorney
duly authorized in writing at the office of the Bond Registrar in Minneapolis, Minnesota, but
only in the manner, subject to the limitations and upon payment of the charges provided in the
Bond Resolution, and upon surrender and cancellation of this Bond. Upon such transfer a new
Bond or Bonds of authorized denomination of the same maturity and for the same aggregate
principal amount will be issued to the transferee in exchange therefore.
The City and the Bond Registrar may deem and treat the registered holder hereof as
the absolute owner hereof and neither the City nor the Bond Registrar shall be affected by any
notice to the contrary.
BOND OPINION
$7,000,000
City of Brookings
Brookings County, South Dakota
Sales Tax Revenue Bonds Series 2010A
Ladies and Gentlemen:
We have acted as bond counsel in connection with the issuance by the City of
Brookings (the "Issuer") of $7,000,000 Sales Tax Revenue Bonds Series 2010A, dated
, 2010, (the "Bonds"). We have examined such certified proceedings and
other papers as we deem necessary to render this opinion.
We have not been engaged or undertaken to review the accuracy, completeness or
sufficiency of the Official Statement or other offering material relating to the Bonds and we
express no opinion relating thereto.
As to questions of fact material to our opinion, we have relied upon the certified
proceedings and other certifications of public officials furnished to us, without undertaking to
verify such facts by independent investigation.
Based upon the foregoing, we are of the opinion that, under existing law:
I. The Issuer is duly created and validly existing as a body corporate and politic and
public instrumentality of the State of South Dakota with the corporate power to adopt and
perform the Resolution and issue the Bonds.
2. Resolution No. has been duly adopted by the Issuer on
, 2010 and constitutes a valid and binding obligation of the Issuer enforceable upon the
Issuer.
21
3. The Resolution pledges the City's non-ad valorem tax (the "Sales Tax) in an amount
sufficient to pay principal, premium and interest when due on the Bonds.
4. The Bonds have been duly authorized, executed and delivered by the Issuer and are
valid and binding special obligations of the Issuer, payable solely from City's Sales Tax.
5. The interest on the Bonds is excluded from gross income for federal income tax
purposes and is not an item of tax preference for purposes of the federal alternative minimum
tax imposed on individuals and corporations. The opinions set forth in the preceding sentence
are subject to the condition that the Issuer comply with all requirements of the Internal
Revenue Code of 1986 as amended, that must be satisfied subsequent to the issuance of the
Bonds in order that interest thereon be, or continue to be, excluded from gross income for
federal income tax purposes. The Issuer has covenanted to comply with each such
requirement. Failure to comply with certain of such requirements may cause the inclusion of
interest on the Bonds in gross income for federal income tax purposes to be retroactive to the
date of issuance of the Bonds. We express no opinion regarding other federal tax
consequences arising with respect to the Bonds.
6. The Bonds are exempt from all taxation as property by the State of South Dakota, its
subdivisions and municipalities and bear interest not includible in the gross income of the
recipient for purposes of computing any tax imposed by the provisions of South Dakota law.
We express no further opinions regarding other South Dakota tax consequences arising with
regard to the Bonds.
It is to be understood that the rights of the holders of the Bonds and the enforceability
thereof may be subject to bankruptcy, insolvency, reorganization, moratorium and other similar
laws affecting creditors' rights heretofore or hereafter enacted to the extent constitutionally
applicable and that their enforcement may be subject to the exercise of judicial discretion in
accordance with general principles of equity and subject to regulatory requirements under the
laws of the United States and of the State of South Dakota.
Meierhenry Sargent LLP
AS PROVIDED IN THE RESOLUTION REFERRED TO HEREIN, UNTIL
THE TERMINATION OF THE SYSTEM OF BOOK-ENTRY-ONLY TRANSFERS
THROUGH DEPOSITORY TRUST COMPANY, NEW YORK, NEW YORK
(TOGETHER WITH ANY SUCCESSOR SECURITIES DEPOSITORY
APPOINTED PURSUANT TO THE RESOLUTION, "DTC"), AND
NOTWITHSTANDING ANY OTHER PROVISIONS OF THE RESOLUTION TO
THE CONTRARY, A PORTION OF THE PRINCIPAL AMOUNT OF THIS
CERTIFICATE MAY BE PAID OR REDEEMED WITHOUT SURRENDER HEREOF
TO THE REGISTRAR. DTC OR A NOMINEE, TRANSFEREE OR ASSIGNEE OF
DTC OF THIS CERTIFICATE MAY NOT RELY UPON THE PRINCIPAL
22
AMOUNT INDICATED HEREON AS THE PRINCIPAL AMOUNT HEREOF
OUTSTANDING AND UNPAID. THE PRINCIPAL AMOUNT HEREOF
OUTSTANDING AND UNPAID SHALL FOR ALL PURPOSES BE THE AMOUNT
DETERMINED IN THE MANNER PROVIDED IN THE RESOLUTION.
UNLESS THIS CERTIFICATE IS PRESENTED BY AN AUTHORIZED
OFFICER OF DTC (A) TO THE REGISTRAR FOR REGISTRATION OF
TRANSFER OR EXCHANGE OR (B) TO THE REGISTRAR FOR PAYMENT OF
PRINCIPAL, AND ANY CERTIFICATE ISSUED IN REPLACEMENT HEREOF OR
SUBSTITUTION HEREFOR IS REGISTERED IN THE NAME OF DTC AND ANY
PAYMENT IS MADE TO DTC OR ITS NOMINEE, ANY TRANSFER, PLEDGE OR
OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON
IS WRONGFUL BECAUSE ONLY THE REGISTERED OWNER HEREOF, DTC
OR ITS NOMINEE, HAS AN INTEREST HEREIN.
(Form of Assignment)
FOR VALUE RECEIVED the undersigned hereby sells, assigns and transfers unto
the within Certificate and all rights thereunder, and hereby irrevocably constitutes and appoints
attorney to transfer the within Certificate on the books kept for registration thereof, with full
power of substitution in the premises.
Dated:
NOTICE: The signature to this Assignment
must correspond with the name as it appears
upon the face of the within Certificate in every
particular, without alteration or enlargement or
any change whatever.
23