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HomeMy WebLinkAboutRES 85-054 RESOLUTION RELATING TO $2,125,000 GENERAL OBLIGATION TAX INCREMENT BONDS, SERIES 1985B; AWARDING THE SALE, FIXING THE FORM AND DETAILS, PROVIDING FOR THE EXECUTION THEREOF AND THE SECURITY THEREFOR AND LEVYING AD VALOREM TAXES FOR THE PAYMENT T Meeting Sheet IIIIII VIII VIII VIII VIII VIII IIII IIII 102403 Box: 23 Folder: RES 1985 Document: RES 85-054 RESOLUTION RELATING TO $2,125,000 GENERAL OBLIGATION TAX INCREMENT BONDS, SERIES 198513; AWARDING THE SALE, FIXING THE FORM AND DETAILS, PROVIDING FOR THE EXECUTION THEREOF AND THE SECURITY THEREFOR AND LEVYING AD VALOREM TAXES FOR THE PAYMENT T Ranallo introduced the following q resolution and moved its adoption: RESOLUTION NO. 85-054 RESOLUTION RELATING TO $2, 125 , 00-0 GENERAL OBLIGATION TAX INCREMENT BONDS, SERIES 1985B; AWARDING THE SALE, FIXING THE FORM AND DETAILS, PROVIDING FOR THE EXECUTION THEREOF AND THE SECURITY THEREFOR AND LEVYING AD VALOREM TAXES FOR THE PAYMENT THEREOF BE IT RESOLVED by the City Council of the City of St . Anthony, Minnesota, as follows : Section 1 . Recitals ; Authorization and Sale of Bonds . 1 . 01 . The Housing and Redevelopment Authority of St . Anthony, Minnesota (the HRA) , has approved a redevelopment plan, as defined in Minnesota Statutes , Section 462 . 421 , • subdivision 15 , designated as the Kenzie Terrace -Redevelopment Plan (the Redevelopment Plan) , and a redevelopment project , as defined in Minnesota Statutes , Section 462 . 421 , subdivision 13 , designated as the Kenzie Terrace Redevelopment Project (the Project) to be undertaken by the HRA pursuant to the Plan . To finance the costs to be incurred by the HRA in connection with the Plan and the Project , the HRA has approved a tax increment financing plan, pursuant to the provisions of Minnesota Statutes , Section 273 . 74 (the Financing Plan) , which established a tax increment financing district , as defined in Minnesota Statutes , Section 273 . 73 , subdivision 9 (the District) . After appropriate proceedings conducted pursuant to Minnesota Statutes , Section 273 . 74 , 462 . 515 and 462 . 521 , this Council approved the Redevelopment Plan, the Project and the Financing Plan._ 1 . 02 . The District is located in Hennepin County and the HRA has requested the Director of Property Taxation of Hennepin County to certify to it the assessed value of all taxable property in the District as defined in Minnesota Statutes , Section 273 . 73 , Subdivision 7 (the Original Assessed Value) , and to certify to the City in each year the -captured assessed value of the District , as defined in Minnesota Statutes , Section 273 . 73 , Subdivision 4 (the Captured Assessed Value) . The ad valorem taxes derived from the property in the • District in each year , by application of the aggregate mill -4- • rate levied by all governmental entities having authority to levy taxes on such property to the Captured. Assessed Value, is the Tax Increment to be derived from the District (the Tax Increment) . 1 . 03 . The HRA has determined to pay certain public redevelopment costs in connection with the Project in accordance with the Plan as follows : Land Acquisition $1 , 650 , 000 Relocation 400 , 000 Demolition 90 , 000 Capitalized Interest 420 , 573 Administrative and Legal 34 , 000 Issuance Costs 30 , 000 Allowance for Discount Bidding 41 , 500 Subtotal $2 , 666, 073 Less : Land Sales (442, 400) Interest Earnings (98 , 673) Total $2 , 125 , 000 1 . 04 . The City has previously issued its General Obligation Tax Increment Bonds, Series 1985A (the "Series 1985A Bonds) , in the principal amount of $545 , 000 , pursuant to Resolution 85-025 duly adopted on May 7 , 1985 (the Series 1985A Bond Resolution) . $165 , 000 of the proceeds of the Series 1985A Bonds were used to finance costs and expenses of the Project and such portion of the Series 1985A Bonds are payable from tax increment to be derieved from the District . Such portion of the Series 1985A Bonds payable from the tax increment to be derived from the District are herein referred to as the "Kenzie Bonds" . 1 . 05 . This Council , under the authority of Minnesota Statutes , Chapers 273 and 475 , and pursuant to a resolution adopted on November 12 , 1985, has determined to issue and sell $2, 125 , 000 General Obligation Tax Increment Bonds , Series 1985B (the Bonds) , $41 , 500 of said issue representing interest as provided in Minnesota Statutes , Section 475 . 56 , for the purpose of providing funds for the payment of the public redevelopment costs in connection with the Project . The Tax Increment generated from the District will be segregated and pledged for the payment of principal and interest on the Bonds under an agreement between the HRA and the City pursuant to. Minnesota Statutes, Section 273 . 77( a) . A public sale of the Bonds was held on December 4 , 1985 , and this Council by resolution adopted on that date, accepted the bid of Norwest Investment Services • ( and associates] , of Minneapolis, MN to purchase the Bonds _5_ on the terms and conditions set forth in the Terms and Conditions of Sale. 1 . 06 . All acts , conditions and things which are required by the Constitution and laws of the State of Minnesota to be done, to exist, to happen and to be performed precedent to and in the valid issuance of the Bonds having been done, existing, having happened and having been performed, it is now necessary for this Council to establish the form and terms of the Bonds , to provide security therefor and to issue the Bonds forthwith. 1 . 07 . For the purpose of complying with the provisions of Minnesota Statutes , Section 475. 54 , subdivision 7, by Resolution No . 85-047 the maturities of the Bonds have been combined with the maturities of the Series 1985A. Bonds , and such combination of maturities is hereby ratified, confirmed and affirmed by this Council . Section 2 . Form of Bonds . 2 . 01 . Bond Form. The Bonds shall be prepared in substantially the following form: -6- w [Face of the Bonds] UNITED STATES OF AMERICA STATE OF MINNESOTA COUNTIES OF RAMSEY AND HENNEPIN CITY OF ST. ANTHONY GENERAL OBLIGATION TAX INCREMENT BOND SERIES 1985B No . $ Date of Rate Maturity Original Issue CUSIP REGISTERED December 1 , 1985 SEE REVERSE OWNER FOR CERTAIN DEFINITIONS PRINCIPAL DOLLARS AMOUNT THE CITY OF ST . ANTHONY, Ramsey and Hennepin Counties , Minnesota (the City) , acknowledges itself to be indebted and, for value received, hereby promises to pay to the registered owner named above, or registered assigns , the principal sum specified above, on the maturity date specified above, with interest thereon from the date hereof at the annual rate specified above, payable on February 1 and August 1 in each year , commencing August 1 , 1986 , to the person in whose name this Bond is registered at the close of business on the 15th day (whether or not a business day) of the immediately preceding month, all subject to the provisions referred to herein with respect to the redemption of the principal of this Bond before maturity. The interest hereon and, upon presentation and surrender hereof , the principal hereof and premium, if any, hereon are payable in lawful money of the United States of America by check or draft of , in as Bond Registrar , Transfer Agent and Paying Agent (the Bond Registrar) , or its successor designated under the Resolution described herein. Additional provisions of this Bond are contained on the reverse hereof and such provisions shall for all purposes have the same effect as though fully set forth hereon. • This Bond shall not be valid or become obligatory for any purpose or be entitled to any security or benefit under the Resolution until the Certificate of Authentication hereon shall -7- have been executed by the Bond Registrar by manual signature of one of its authorized representatives . IN WITNESS WHEREOF, the City of St . Anthony, Ramsey and Hennepin Counties, State of Minnesota, by its City Council , has caused this Bond to be executed by the facsimile signatures of the Mayor and the City Manager and by a printed facsimile of the official seal of the City and has caused this Bond to be dated as of the date set forth below. Dated: (Facsimile Signature) (Facsimile Signature) City Manager Mayor (Facsimile Seal ) CERTIFICATE OF AUTHENTICATION This is one of the Bonds delivered pursuant to the Resolution mentioned within . By Authorized Representative (Reverse of the Bonds] This Bond is one of an issue in the aggregate principal amount of $2 , 125 , 000 ( the Bonds) , issued pursuant to a resolution adopted by the City Council on December 4 , 1985 (the Resolution) to finance the public redevelopment costs incurred by the City in aid of a redevelopment project undertaken in a tax increment financing district in the City, and is issued pursuant to and in full conformity with the provisions of the Constitution and laws. of the State of Minnesota thereunto enabling, including Minnesota Statutes , Chapter 475 and Sections 462 . 585 and 273 . 77 . This Bond is payable primarily from the "Series 1985B Tax Increment Bond Account'' (the Bond Account) in the General Obligation Sinking Fund of the City, but the City is required by law to pay maturing principal hereof premium, if any, and interest hereon from any available funds of the City if moneys on hand in the • Bond Account are insufficient therefor . The Bonds are issuable -8- • only as fully registered bonds , in denominations of $5, 000 or any multiple thereof , of single maturities . The Bonds are each subject to redemption and prepayment, at the option of the City and in inverse order of maturities and by lot, assigned in proportion to their principal amount, within any maturity, on August 1, 1987 and on any interest payment date thereafter, at the redemption price expressed as percentages of the principal amount thereof to be redeemed as set forth in the table below, plus interest accrued to the date. of redemption: Redemption Date Redemption Price August 1 , 1987 through August 1 , 1992 102% February 1 , .1993 and thereafter 100% .. At least thirty days prior to the date set for redemption of any Bond, notice of the call for redemption will be published in a daily or weekly periodical , published in a Minnesota city of the first class or its metropolitan area, which circulates throughout the state and furnishes financial news as a part of its service, and will be mailed to the Bond Registrar and to • the registered owner of each Bond to be redeemed at his address appearing in the Bond Register , but no defect in or failure to give such mailed notice of redemption shall affect the validity of proceedings for the redemption of any Bond. Upon partial redemption of any Bond, a new Bond or Bonds will be delivered to the registered owner without charge, representing the remaining principal amount outstanding . As provided in the Resolution and subject to certain limitations set forth therein, this Bond is transferable upon the books of the City at the principal office of the Bond Registrar , by the registered owner hereof in person or by his attorney duly authorized in writing upon surrender hereof together with a written instrument of transfer satisfactory to the Bond Registrar, duly executed by the registered owner or his attorney; and may also be surrendered in exchange for Bonds of other authorized denominations . Upon such transfer or exchange, the City will cause a new Bond or Bonds to be issued in the name of the transferee or registered owner , of the same aggregate principal amount , bearing interest at the same rate and maturing on. the same date, subject to reimbursement for any tax, fee or governmental charge required to be paid with respect to such transfer or exchange. The City and the Bond Registrar may deem and treat the person in whose name this Bond is registered as the absolute owner hereof , whether this Bond is overdue or not, for the -9- • purpose of receiving payment and for all other purposes , and neither the City nor the Bond Registrar shall be affected by any notice to the contrary. IT IS HEREBY CERTIFIED, RECITED, COVENANTED AND AGREED that all acts, conditions and things required by the Constitution and laws of the State of Minnesota to 'be done, to exist , to happen and to be performed precedent to and in the issuance of this Bond in order to make it a valid and binding general obligation of the City according to its terms have been done, do exist, have happened and have been performed in regular and due form as so required; that prior to the issuance hereof , the City has pledged and appropriated tax increments to be derived by the City from a tax increment financing district in which the redevelopment project to be financed by the proceeds of the Bonds are located to the Bond .Account ; that all taxable property within the City is subject to the levy of a direct, annual , ad valorem tax, which has been levied and is required to be extended, assessed and collected for the years and in such amounts as may be required to pay the principal , premium, if any, and interest on the Bonds when due, which levy is not limited as to rate or amount ; and that the issuance of this Bond does not cause the indebtedness of the City to exceed any constitutional or statutory limitation. The following abbreviations , when used in the inscription on the face of this Bond, shall be construed as though they were written out in full according to the applicable laws or regulations : TEN COM -- as tenants UNIF GIFT MIN ACT . . . . .Custodian. . . . . in common (Cust) (Minor) TEN ENT -- as tenants by the entireties under Uniform Gifts to JT TEN -- as joint tenants Minors with right of . survivorship and Act . . . . . . . . . . . . . . . . . . . . . . not as tenants in (State) common Additional abbreviations may also be used. -10- ASSIGNMENT FOR VALUE RECEIVED, the undersigned hereby sells , assigns and transfers unto , the within Bond and all rights thereunder , and hereby irrevocably constitutes and appoints attorney to transfer .the within Bond on the books kept for registration thereof, with full power of substitution in the premises . Dated: PLEASE INSERT SOCIAL SECURITY OR OTHER IDENTIFYING NUMBER NOTICE: The signature to this OF ASSIGNEE: assignment must correspond with the name as it appears upon the face of the within 'Bond in every particular , without alteration or any change whatsoever . Signature( s) must be guaranteed by a commercial bank or trust company or by a brokerage firm having a membership in one of the major stock exchanges . • 2 . 02 . Form of Certificate . A certificate in substantially the following form shall appear on the reverse side of each Bond, following a copy of the text of the legal opinion of Bond Counsel : We certify that the above is a full , true and correct . copy of the legal opinion rendered by Bond Counsel on the issue of Bonds of the City of St . Anthony which includes the within Bond, dated as of the date of delivery of and payment for the Bonds . (Facsimile signature) (Facsimile signature) City Manager Mayor Section 3 . Bond Terms , Execution and Delivery. 3 . 01 . Maturities , Interest Rates , Denominations , Payment . The City shall forthwith issue and deliver the Bonds , which shall be denominated "General Obligation Tax Increment Bonds , Series 1985B" and shall be payable primarily from, the Series 1985B Tax Increment Bond Account created in Section 4 . 02 hereof . The Bonds shall be issuable in the denomination of $5 , 000 each or any integral multiple thereof , shall mature on February 1 in the years and amounts set forth below., and Bonds maturing in such years and amounts shall bear interest from -11- date of issue until paid or duly called for redemption at the rates per annum shown opposite such years and amounts as follows : Year Amount Rate Year Amount Rate 1989 $ 75 , 000 6 . 20% 1994 $300 , 000 7 . 20% 1990 -0- ---- 1995 325 , 000 7 . 40% 1991 75 , 000 6 . 60% 1996 3.50 , 000 7 . 60% 1992 150 , 000 6 . 80% 1997 375 , 000 7 , 80% 1993 275 , 000 7 . 00% 1998 200 , 000 8 . 00% The Bonds shall be issuable only in fully registered form. The interest thereon and, upon surrender of each Bond, the principal amount thereof, shall be payable by check or draft issued by the Registrar described herein. 3 . 02 . Dates ; Interest -Payment Dates . Each Bond shall be dated as of the last interest payment date preceding the . date of authentication to which interest on the Bond has been paid or made available for payment , unless ( i) the date of authentication is an interest payment date to which interest has been paid or made available for payment , in which case such . Bond shall be dated as of the date of authentication, or ( ii) the date of authentication is prior to August 1 , 1986 in which case such Bond shall be dated as of December 1 , 1985 . The interest on the Bonds shall be payable on February 1 and August 1 in each year , commencing August 1 , 1986 , to the owner of record thereof as of the close of business on the fifteenth day of the immediately preceding month, whether or not such day is a business day. 3 . 03 . Registration. The City shall appoint , and shall maintain, a bond registrar , transfer agent and paying agent (the Registrar) . The effect of registration and the rights and duties of the City and the Registrar with respect thereto shall be as follows : (a) Register . The Registrar shall keep at its principal corporate trust office a bond register in which the Registrar shall provide for the registration of ownership of Bonds and the registration of transfers and exchanges of Bonds entitled to be registered, transferred or exchanged. (b) Transfer of Bonds . ' Upon surrender for transfer of any Bond duly endorsed by the registered owner thereof or accompanied by a written instrument of transfer , in form satisfactory to the Registrar , duly executed by the -12- • registered owner thereof or by an attorney duly authorized by the registered owner in writing, the Registrar shall authenticate and deliver, in the name of the designated transferee or transferees , one or more new Bonds of a like aggregate principal amount and maturity, as requested by the transferor . The Registrar may, however , close the books for registration of any transfer after the fifteenth day of the month preceding each interest payment date and until such interest payment date. (c) Exchange of Bonds . Whenever any Bond is surrendered by the registered owner for exchange, the Registrar shall authenticate and deliver one or more new Bonds of a like aggregate principal amount and maturity, as requested by the registered owner or the owner ' s attorney duly authorized in writing. (d) Cancellation. All Bonds surrendered upon any transfer or exchange shall be promptly cancelled by the Registrar and thereafter disposed of as directed by the City. (e) Improper or Unauthorized Transfer . When any Bond is presented to the Registrar for transfer , the Registrar may refuse to transfer the same until it is satisfied that the endorsement on such Bond or separate instrument of transfer is legally authorized. The Registrar shall incur no liability for its refusal , in good faith, to make transfers which it , in its judgment , deems improper or unauthorized. ( f) Persons Deemed Owners . The City and the Registrar may treat the person in whose name any Bond is at any time registered in the bond register as the absolute owner of such Bond, whether such Bond shall be overdue or not , for the purpose of receiving payment of , or on account of , the principal of and interest on such Bond and for all other purposes , and all such payments so made to any such registered owner or upon the owner ' s order shall be valid and effectual to satisfy and discharge the liability of the City upon such Bond to the extent of the sum or sums so paid. (g) Taxes , Fees and Charges . For every transfer or exchange of Bonds , the Registrar may impose a .charge upon the owner thereof sufficient to reimburse the Registrar for any tax, fee or other governmental charge required to be paid with respect to such transfer or exchange . -13- • (h) Mutilated, Lost , Stolen or Destroyed Bonds . In case any Bond shall become mutilated or be lost , stolen or destroyed, the Registrar shall deliver a new Bond of like amount , number , maturity date and tenor in exchange and substitution for and upon cancellation of any such mutilated Bond or in lieu of and in substitution for any such Bond lost , stolen or destroyed, upon the payment of the reasonable expenses and charges of the Registrar in connection therewith; and, in the case of a Bond lost , stolen or destroyed, upon filing with the Registrar of evidence satisfactory to it that such Bond was lost , stolen or destroyed, and of the ownership thereof , and upon furnishing to the Registrar of an appropriate bond or . indemnity in form, substance and amount satisfactory to it , in which. both the City and the Registrar shall be named as obligees.. All Bonds so surrendered to the Registrar shall be cande.11ed by it and evidence of such cancellation shall be given to the City. If the mutilated, lost , stolen or destroyed Bond has already matured or been called for redemption in accordance with its terms , it shall not be necessary to issue a new Bond prior to payment. 3 . 04 . Appointment of Initial Registrar . The City • hereby appoints Norwest Bank Minneapolis N A , as the initial Registrar . The Mayor and the City Manager are authorized to execute and deliver , on behalf of the City, a contract with Norwest Bank Minneapolis , N.A. , as Registrar . Upon merger or consolidation of the Registrar with another corporation, if the resulting corporation is a bank or trust company authorized by law to conduct such business , such corporation shall be authorized to act as successor Registrar . The City agrees to pay the reasonable and customary charges of the Registrar for the services performed. The City reserves the right to remove any Registrar upon thirty (30 ) days ' notice and upon the appointment of a successor Registrar , in which event the predecessor Registrar shall deliver all cash and Bonds in its possession to the successor Registrar and shall deliver the bond register to the successor Registrar . On or before each principal or interest due date, without further order of this Council , the City Manager shall transmit to the Registrar from the Series 1985B Tax Increment Bond Account described in Section 4 . 02 hereof , moneys sufficient for the payment of all principal and interest then due. 3 . 05 . Redemption. The Bonds shall each be subject to redemption and prepayment at the option of the City, in inverse order of maturities and, ' within any maturity, in $5 , 000 principal amounts selected by the Registrar by lot, on August 1 , 1987 and on any interest payment date thereafter at a • redemption price expressed as percentages of principal amount -14- thereof to be redeemed set forth below, plus interest accrued to the date of redemption: Redemption Date Redemption Price August 1 , 1987 through August 1 , 1992 102% February 1 , 1993 and thereafter 1000 At least thirty days prior to the date set for redemption of any Bond, the City Manager shall cause notice of the call for redemption to be published in a daily or weekly periodical published in a Minnesota city of the first class or its metropolitan area, which circulates throughout the state and furnishes financial news as a part of its service, and to be mailed to the Registrar and to the registered owner of each Bond to be redeemed, but no _defect in or failure to give such mailed notice of 'redemption shall affect the validity of proceedings for the redemption of any Bond not affected by such defect or failure. 3 . 06 . Preparation and Delivery. The Bonds shall be prepared under the direction of the City Manager and shall be executed on behalf of the City by the signatures of the Mayor and the City Manager , and shall be sealed with the official • corporate seal of the City; provided that said signatures and the corporate seal may be printed, engraved, or lithographed facsimiles thereof . In case any officer whose signature, or a facsimile of whose signature, shall appear on the Bonds shall cease to be such officer before the delivery of any Bond, such signature or facsimile shall nevertheless be valid and sufficient for all purposes , the same as if such officer had remained in office until delivery. Notwithstanding such execution, no Bond shall be valid or obligatory for any purpose or entitled to any security or benefit under this resolution unless and until a certificate of authentication on such Bond has been duly executed by the manual signature of an authorized representative of the Registrar . Certificates of authentication on different Bonds need not be signed by the same representative. The executed certificate of authenti- cation on each Bond shall be conclusive evidence that it has been authenticated and delivered under this resolution. When the Bonds have been so executed and authenticated, they shall be delivered by the City Manager to the purchaser thereof upon payment of the purchase price in accordance with the contract of sale heretofore made and executed, and the purchaser shall not be obligated to see to the application of the purchase price. 3 . 07 . Application of Proceeds . The proceeds of the • Bonds shall be applied as follows : -15- ( a) $420 , 573 of the proceeds of the Bonds , together with the amount in excess of $2, 083 , 500 paid by the purchaser of the Bonds shall be deposited in the Series 1985B Tax Increment Bond Account referred to in Section 4 . 02 hereof; and (b) $1 , 662 , 927 of the proceeds of the Bonds shall be deposited in the Series 1985B Tax Increment Bonds Capital Expenditures Fund referred to in Section 4 . 01 hereof-. Section 4 . Security Provisions . 4 . 01 . Capital Expenditures Fund. There is hereby established on the official books and records of the City a ''Series 1985B Tax Increment Bonds Capital Expenditures Fund" (the Capital Expenditures Fund) and the City Treasurer shall maintain the Capital Expenditures Fund until all costs and expenses to be financed by the proceeds of the Bonds deposited therein have been paid. There is appropriated to the Capital Expenditures Fund, and to said Fund there shall be credited the amounts specified in Section 3 . 07 hereof . From the Capital Expenditures Fund there shall be paid all costs and expenses incurred and to be incurred by the City and the HRA in aid of the Project . After payment of all costs and expenses of the • Project to be paid from. the Capital Expenditures Fund, said Fund shall be discontinued and any amounts remaining therein shall be transferred to the Series 1985B Tax Increment Bond Account referred to in Section 4 . 02 hereof . 4 . 02 . Bond Sinking Fund. The Bonds shall be payable from a "Series 1985B Tax Increment Bond Account" (the Bond Account) , which Account the City agrees to establish and maintain until all bonds payable therefrom have been paid in full . The moneys on hand in the Bond Account from time to time shall be used only to pay when due the principal of and interest on the Bonds and any additional bonds issued pursuant to Section 4 . 04 which are payable therefrom. If the moneys on hand in the Bond Account should at any time be insufficient to pay principal and interest due on the bonds payable therefrom, such amounts shall be paid from the General Fund of the City, which shall be reimbursed therefor when sufficient money becomes available in the Account . There is appropriated to the Bond Account, and to the Bond Account there shall be credited or transferred as the case may be, the amounts specified in Section 3 . 07( a) hereof , all amounts transferred therein pursuant to Section 4 . 01 or 4 . 03 hereof , all taxes levied pursuant to Section 4 . 05 hereof , and all other moneys appropriated thereto . -16- 4 . 0 3 . Kenzie District Bond Subaccount . B the Series 3 Y 1985A Bond Resolution there was established on the official books of the City a "Kenzie District Bond Subaccount" into which shall be paid the Tax Increments from the District appropriated and pledged by the HRA to the City to pay the principal of and interest on the Kenzie Bonds there shall also be paid from the Kenzie District Bond Subaccount the principal of , premium, if any, and interest on the Bonds . On or before each interest payment date with respect to the Bonds the City Treasurer shall transfer to the Bond Account the amount necessary to pay the principal of and interest on the Bonds coming due on such interest payment date. 4 . 04 . Additional Bonds . The City reserves the right to issue additional bonds payable from the Bond Account and/or- the Kenzie District Bond Subaccount as may be required to finance costs to be paid or incurred by the City in accordance with the Plan not financed hereby; provided that the City Council shall , prior to the delivery of such additional bonds , levy or agree to levy by resolution sufficient additional ad valorem taxes and special assessments which, together with other moneys or revenues pledged for the payment of said additional obligations , will produce revenues at least five percent in excess of the amount needed to pay when due the principal and interest on all bonds payable from the Bond Account . The additional ad valorem taxes , special assessments and moneys or revenues so pledged, levied or agreed to be levied shall. be irrevocably appropriated to the Bond Account in the manner provided by Minnesota Statutes , Section 475 . 61 . 4 . 05 . Pledge of Taxing Powers . The full faith and credit and taxing powers of the City are hereby irrevocably pledged to the payment of the principal of , premium, if any, and the interest on the Bonds when due. In order to provide moneys for the payment of such principal and interest which, together with the Tax Increments , Bond proceeds and other moneys appropriated for the payment and security of the Bonds in Section 4 , will meet the requirements of Minnesota Statutes , Section 475 . 61 , there is hereby levied upon all of the taxable property in the City a direct , annual , ad valorem tax which shall be spread upon the tax rolls for collection in the years and amounts set forth below, as a part of other general taxes of the City, as follows : -17- • Levy Collection Levy Collection Year Year Amount Year Year Amount 1986 1987 -0- 1992 1993 -0- 1987 1988 -0- 1993 1994 -0- 1988 1989 -0- 1994 1995 -0- 1989 1990 -0- 1995 1996 -0- 1990 1991 -0- 1996 1997 -0- 1991 1992 -0- Said tax shall be irrepealable as long as any of the Bonds are outstanding and unpaid; provided that the City reserves the right and power to reduce the levies in the manner and to the extent permitted by Minnesota Statutes , Section 475 . 61 . 4 . 07 . Execution of Documents . The Mayor and City Manager are hereby authorized to execute and deliver on behalf of the City such documents as may be appropriate to evidence the pledge and appropriation of the Tax Increments by the HRA to the City to pay the Bonds . Section 5 . Defeasance. When any Bond has been discharged as provided in this section, all pledges , covenants and other rights granted by this resolution to the holders of such Bonds shall cease, and such Bonds shall no longer be deemed to be outstanding under this Resolution. The City may discharge its obligations with respect to any Bond thereto which are due on any date by depositing with the paying agent on or before that date a sum sufficient for the payment thereof in full ; or , if any Bond should not be paid when due, it may nevertheless be discharged by depositing with the paying agent a sum sufficient for the payment thereof in full with interest accrued to the date of such deposit . The City may also discharge its obligations with respect to any prepayable Bond according to its terms , by depositing with the paying agent on or before that date an amount equal to the principal , interest and redemption premium, if any, which are _then due, provided that notice of such redemption has been duly given as provided herein. The City may also at any time discharge its obligations with respect to any Bonds , subject to the provisions of law now or hereafter authorizing and regulating such action, by depositing irrevocably in escrow, with a bank qualified by law as an escrow agent for this purpose, . cash or securities which are authorized by law to be so deposited, bearing interest payable at such times and at such rates and maturing on such dates as shall be required to pay all principal , interest and redemption premiums to become due thereon to maturity or said redemption date. -18- • Section 6 . County Auditor Registration, Certification of Proceedings, Investment of Moneys and Arbitrage. 6 . 01 . County Auditor Registration. The City Clerk is hereby authorized and directed to file a certified copy of this resolution with the County Auditor of Ramsey County and the County Auditor of Hennepin County, together with such other information as the respective County Auditors shall require, and to obtain from said County Auditors a certificate that the Bonds have been entered on his bond register and the taxes described in Section 4 . 07 hereof have been levied as required by law. 6 . 02 . Certification of Proceedings . The officers of the City, the County Auditor of Ramsey County and the County Auditor of Hennepin County are hereby"authorized and directed to prepare and furnish to the purchaser of the Bonds and to Dorsey & Whitney, Bond Counsel , certified copies of all proceedings and records of the City, and such other affidavits , certificates and information as may be required to show the facts relating to the legality and marketability of the Bonds as the same appear from the books and records under their custody and control or as otherwise known to them, and all such certified copies , certificates and affidavits , including any heretofore furnished, shall be deemed representations of the City as to the facts recited therein. 6 . 03 . Covenant . The City covenants and agrees with the holders from time to time of the Bonds that it will not take or permit to be taken by any of its officers, employees or agents any action which would cause the interest. on the Bonds to become subject to taxation under the Internal Revenue Code of 1954 , as amended (the Code) , and the Treasury Regulations promulgated thereunder (the Regulations) , and covenants to take any and all actions within its powers to ensure that the interest on the Bonds will not become subject to taxation under the Code and the Regulations . In particular , the City covenants that it shall not take any action or exercise any remedies pursuant to any development agreement relating to the District if the effect thereof would be, in the opinion of the City' s bond counsel , to cause the Bonds to be considered " industrial development bonds" or ''consumer loan bonds" pursuant to the Code . 6 . 04 . Investment of Moneys on Deposit in Bond Account . The City Treasurer shall ascertain monthly the amount on deposit in the Bond Account . If the amount on deposit therein ever exceeds by more than $318 , 750 (so long as any Bonds are outstanding; when no Bonds are outstanding this • amount shall be zero unless additional bonds have been issued and made payable -19- • from the Bond Account, as hereinafter provided) the aggregate o g amount of principal and interest due and payable from the Bond Account within the next succeeding 12 months , such excess shall be used to prepay and redeem Bonds or be invested at a yield less than or equal to the yield on the Bonds , based upon their amounts , maturities and interest rates on their date of issue, computed by the actuarial method. If any additional bonds are ever issued and made payable from the Bond Account pursuant to Section 4 . 05 hereof , the dollar amount in the preceding sentence shall be changed to equal 15 percent of the aggregate original principal amount of all bonds , including the Bonds , which are then outstanding and payable therefrom. The City reserves the right to amend the provisions of this Section 6 . 04 at any time, whether prior to or after the delivery of the Bonds , if and to the extent that this Council determines that the provisions of this Section 6 . 04 are not necessary in order to ensure that the Bonds are not "arbitrage bonds" within the meaning of Section 103(c) of the Code and Regulations . 6 . 05 . Arbitrage Certification. The Mayor and City Manager , being the officers of the City charged with the responsibility for issuing the Bonds pursuant to this resolution, are authorized and directed to execute and deliver to the purchaser thereof a certificate in accordance with the • provisions of Section 103(c) of the . Code, and Sections 1 . 103-13 , 1 . 103-14 and 1 . 103-15 of the Regulations , stating the facts , estimates and circumstances in existence on the date of issue and delivery of the Bonds which make it reasonable to expect that the proceeds of the Bonds will not be used in a manner that would cause the Bonds to be arbitrage bonds within the meaning of the Code and Regulations . Mayor Attest : City Clerk -20- The motion for the adoption of the foregoing resolution was duly seconded by Member Marks and upon vote being -taken thereon, the following voted in favor thereof : All members and the following voted against the same: None whereupon said resolution was declared duly passed and adopted, and was signed by the Mayor, whose signature was attested by the City Clerk. • -21-