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HomeMy WebLinkAboutCC RES 92-039 RESOLUTION AUTHORIZING ISSUANCE, AWARDING SALE OF $405,000 LIQUOR STORE REVENUE REFUNDING BONDS Meeting Sheet IIIIIIVIIIVIIIVIIIVIIIVIIIIIIIIIII 103575 Box: 26 Folder: RES 1992 Document: CC RES 92-039 RESOLUTION AUTHORIZING ISSUANCE, AWARDING SALE OF $405,000 LIQUOR STORE REVENUE REFUNDING BONDS CERTIFICATION OF MINUTES RELATING TO $405,000 LIQUOR STORE REVENUE REFUNDING BONDS, SERIES 1992 • Issuer: City of St. Anthony, Minnesota Governing Body: City Council Kind, date, time and place of meeting: A meeting held on Tuesday, August 25, 1992 at 7:30 o'clock P.M., at the City Hall. Members present: Ranallo, Marks, Enrooth, Fleming, Wagner Members absent: None Documents Attached: Minutes of said meeting (pages): 1 through RESOLUTION NO. 92- 0 3 9 RESOLUTION RELATING TO $405,000 LIQUOR STORE REVENUE REFUNDING BONDS, SERIES 1992; AWARDING THE SALE, FIXING THE FORM AND DETAILS, PROVIDING • FOR THE EXECUTION AND DELIVERY THEREOF AND THE SECURITY THEREFOR I, the undersigned, being the duly qualified and acting recording officer of the City of St. Anthony, Minnesota, certify that the documents attached hereto, as described above, have been carefully compared with the original records of the City in my legal custody, from which they have been transcribed; that said documents are a correct and complete transcript of the minutes of a meeting of the City Council of the City, and correct and complete copies of all resolutions and other actions taken and of all documents approved by said City Council at said meeting, so far as they relate to said bonds; and that said meeting was duly held by said City Council at the time and place and was attended throughout by the members indicated above, pursuant to call and notice of such meeting given as required by law. WITNESS my hand officially as such recording officer this day of August , 1992. Signature Connie Kroeplin, City Clerk Name and Title It was reported that 3 bids had been received by Springsted • Incorporated prior to 11:00 A.M. Central Time for the purchase of $405,000 Liquor Store Revenue Refunding bonds, Series 1992A of the City (the Bonds) in accordance with the Terms of Proposal relating to the Bonds approved by the Council on July 28, 1992. The bids received were as follows: (See attached sheet) • -2- Member Marks introduced the following resolution and • moved its adoption: RESOLUTION NO. 92- 0 3 9 RESOLUTION RELATING TO $405,000 LIQUOR STORE REVENUE REFUNDING BONDS, SERIES 1992; AWARDING THE SALE, FIXING THE FORM AND DETAILS, PROVIDING FOR THE EXECUTION AND DELIVERY THEREOF AND THE SECURITY THEREFOR BE IT RESOLVED by the City Council of the City of St. Anthony, (the City), as follows: Section 1. Authorization and Sale. 1.01. Municil2al Liquor Store. The City owns and operates one or more municipal liquor stores (collectively the Store) for the on-sale and off-sale of intoxicating liquor and other merchandise in accordance with the provisions of Minnesota Statutes, Chapter 340A. 1.02. Existing; Indebtedness and Liens. There is presently outstanding the Liquor Store Revenue Bonds, Series 1987 of the City originally dated as of July 1, 1987 (the 1987 Bonds), which are payable from the net revenues of the Store, and constituting a first lien and charge on the net revenues derived and to be derived from the operation of the Store. The 1987 Bonds were issued pursuant to a Resolution No. 87-021 adopted by this Council on May 26, 1987 (the Authorizing Resolution). Except for the 1987 Bonds, there are no other bonds, certificates or other obligations of the City which constitute a lien or charge upon the net revenues of the Store. Capitalized terms used herein and not otherwise defined herein shall have the meaning given to them in the Authorizing Resolution. 1.03. Refunding Bonds; Pari , Lien. It is in the best interest of the City, its residents and the customers of the Store for the City to issue at this time its Liquor Store Revenue Refunding Bonds, Series 1992 in the principal amount of $405,000 (the Bonds), upon the terms and conditions hereinafter set forth, to refund in advance of their maturity the 1987 Bonds maturing in the years 1994 through 1998 (the Refunded Bonds). It is in the best interest of the City that the Bonds be payable primarily from the Net Revenues of the Store and that the lien and charge on such Net Revenues of the Store for the payment of both principal and interest on the Bonds be on a parity with the lien upon such Net Revenues of the Store as to payment as to both principal and interest with the 1987 Bonds. Section 3.06 of the Authorizing Resolution provides that additional obligations may be issued by the • City payable from the Net Revenues of the Store on a parity with the 1987 Bonds if the Net Revenues of the Store in the last complete fiscal year immediately preceding the issuance of the additional obligations shall have been at least equal to 125% of the maximum amount of principal and interest to come due in any future fiscal year during the remaining term of the 1987 Bonds and on the additional obligations then proposed to be issued. The Council hereby finds that the Net Revenues of the Store for the fiscal year ended December 31, 1991 (which is the last complete fiscal year of the Store) were at least equal to 125% of the maximum amount of principal and interest to come due in any future fiscal year during the remaining term of the 1987 Bonds following the redemption of the Refunded Bonds on Janaury 1, 1993 and the Bonds, and therefore the Bonds may be issued payable from the Net Revenues on a parity with the 1987 Bonds. 1.04. Sale of Bonds. The City has received an offer from Moore Juran & Company I of Minneapolis , Minnesota, (the Purchaser), to purchase the Bonds at a price of $400,545.00 , plus accrued interest from the date of the Bonds to the date of delivery thereof, the Bonds to bear interest at the rates set forth in Section 3.01 and have such other terms as are set forth in this Resolution. The proposal is deemed reasonable and in the best interests of the City and is hereby accepted. 1.05. Performance of Requirements. 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 to establish the form and terms of the Bonds, to provide security therefor and to issue the Bonds forthwith. Section 2. Form of Bonds. 2.01. Bond Form. The Bonds shall be prepared in substantially the following form: • -2- (Face of the Bonds] UNITED STATES OF AMERICA STATE OF MINNESOTA COUNTIES OF HENNEPIN AND RAMSEY CITY OF ST. ANTHONY LIQUOR STORE REVENUE REFUNDING BOND, SERIES 1992 No. $ Date of Rate Maturity Original Issue CUSIP October 1, 1992 REGISTERED SEE REVERSE OWNER FOR CERTAIN DEFINITIONS PRINCIPAL AMOUNT DOLLARS THE CITY OF ST. ANTHONY, Hennepin and Ramsey 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, solely from the Revenue Bond Account in its Liquor Store Fund, as a first lien and charge upon the net revenues from time to time received from the operation of its municipal liquor store, the principal amount specified above, on the maturity date specified above, without option of prior payment, with interest thereon from the date of original issue specified above, or the most recent interest payment date to which interest has been paid or duly provided for, at the annual rate specified above, payable on January 1 and July 1 in each year, commencing July 1, 1993, 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. The interest hereon and, upon presentation and surrender hereof at the office of , in , as Registrar, Transfer Agent and Paying Agent (the "Bond Registrar"), or its successor designated under the Resolution described herein, the principal hereof, are payable in lawful money of the United States of America by check or draft of the Bond Registrar. • -3- 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 herein. 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 have been executed by the Bond Registrar by manual signature of one of its authorized representatives. IN WITNESS WHEREOF, the City of St. Anthony, Hennepin and Ramsey Counties, State of Minnesota, by its City Council, has caused this Bond to be executed by the signatures of the Mayor and the City Manager of the City and has caused this Bond to be dated as of the date set forth below. Date of Authentication: (Facsimile Signature) (Facsimile Signature) City Manager Mayor • CERTIFICATE OF AUTHENTICATION This is one of the Bonds delivered pursuant to the Resolution mentioned within. as Bond Registrar By Authorized Representative -4- [Reverse of the Bonds] This Bond is one of a series in the total principal amount of $405,000, all of like date and tenor except as to serial number, denomination and maturity dat, which Bonds have been issued for the purpose of providing money to refund a portion of the outstanding principal amount of the City's Liquor Store Revenue Refunding Bonds, Series 1987 (the 1987 Bonds). Said Bonds and the interest thereon are payable solely and exclusively from the net revenues of the-municipal liquor store pledged to the payment thereof and do not constitute a debt of the City within the meaning of any constitutional or statutory limitation of indebtedness, and the full faith and credit and taxing power of the City are not pledged to the payment of the principal of or interest on the Bonds. The lien and charge upon the net revenues of the municipal liquor store of the City to pay the principal and interest of the Bonds of this issue is on a parity with the lien upon such net revenues to pay the 1987 Bonds. Additional revenue obligations may be issued on a parity of lien upon the net revenues of the municipal liquor store with the Bonds of this issue and the 1987 Bonds as provided in Resolution No. 87-021, adopted May 26, 1987 by the City Council, as amended and supplemented by Resolution No. 92- adopted August 25, 1992 by the City Council (collectively the "Resolution"). The Bonds are issuable only as fully registered bonds, in denominations of $5,000 or any multiple thereof, of single maturities. Bonds of this series are designated by the City as "Qualified Tax Exempt Obligations" pursuant to Section 265(b) of the Internal Revenue Code of 1986, as amended. 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 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. is -5- 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 in order to make this Bond a valid and binding special obligation of the City according to its terms have been done, do exist, have happened and have been performed as so required; and that the issuance of this Bond does not cause the indebtedness of the City to exceed any constitutional or statutory limitation of indebtedness; that the City has established and will maintain in its Liquor Store Fund a Revenue Bond Account and Reserve Account and has irrevocably appropriated and pledged thereto, out of the Net Revenues, as defined in the Resolution, to be received from its ownership and operation of the municipal liquor store, including any additions thereto and improvements thereof, periodic payments to be made at times and in amounts sufficient to pay from the principal and interest on all bonds payable therefrom, including the Bonds of this series and the 1987 Bonds, as such payments become due, and to establish and maintain the required reserve balance therein, and will use the moneys in said Accounts solely for said purposes; that the City and its officers and employees will establish and maintain operating policies governing purchase and sale of merchandise and will do all other things necessary and feasible to assure that the gross receipts of the municipal liquor store will at all times be adequate to pay all costs of operation and maintenance thereof and to produce Net Revenues in the amounts so appropriated and pledged; and that in and by the Resolution other covenants, agreements and stipulations are prescribed for the security and enforcement of the bonds of this series, each and all of which will be faithfully and promptly performed by the City and its officers and agents. (Form of certificate to be printed on the reverse side of each Bonds, following a full copy of the legal opinion) 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, Minnesota, 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 -6- 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 TRANS MIN ACT...........Custodian.......... in common (Cust) (Minor) TEN ENT -- as tenants by the entireties under Uniform Transfers to JT TEN -- as joint tenants Minors with right of survivorshipand Act.............................................................................. not as tenants in (State) common Additional abbreviations may also be used. 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: NOTICE: The signature to this PLEASE INSERT SOCIAL SECURITY assignment must correspond with OR OTHER IDENTIFYING NUMBER the name as it appears upon the OF ASSIGNEE: 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. -7- Section 3. Bond Terms, Execution and Delivery. 3.01. Maturities, Interest Rates, Denominations, Payment, and Dating of Bonds. The City shall forthwith issue and deliver the Bonds, which shall be denominated "Liquor Store Revenue Refunding Bonds, Series 1992." The Bonds shall be issuable in the denomination of $5,000 each or any integral multiple thereof, shall bear a date of original issue of October 1, 1992, shall mature on January 1 in the years and amounts set forth below, without option of prior payment, and Bonds maturing in such years and amounts shall bear interest from date of original issue until paid at the rates per annum shown opposite such years and amounts as follows: Year Amount Rate 1994 $70,000 4.00% 1995 80,000 4.50 1996 80,000 4.75 1997 85,000 5.00 1998 90,000 5.25 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. Each Bond shall be dated by the Registrar as of its date of its authentication. 3.02. Interest Payment Dates. Interest on the Bonds shall be payable on January 1 and July 1 in each year, commencing July 1, 1993, 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 to the Registrar 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 -8- executed by the 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 endorse::;ent 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 (except for an exchange upon a partial redemption of a Bond), 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. (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 -9- 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 cancelled 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. A1212ointment of Initial Registrar. Norwest Bank Minnesota, National Association , of Minneapolis Minnesota , is hereby appointed as the initial Registrar. The Chairman and Secretary are hereby authorized to execute and deliver, on behalf of the City, a contract with Norwest Bank Minnesota, National Association , 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. 3.05. 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 facsimile signatures of the Mayor and the City Manager. On the reverse side of each Bond shall be a printed a copy of the legal opinion to be rendered by bond counsel, certified by the facsimile signatures of the Mayor and City Manager. In case any officer whose signature shall appear on the Bonds shall cease to be such officer before the delivery of any Bond, such signature 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 authentication 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 upon payment of the purchase price in accordance with • -10- the contract of sale heretofore made and executed, and the Purchaser shall not be obligated to see to the application of the purchase price. Section 4. Security Provisions; Bond Proceeds. 4.01. Authorizing Resolution. The Bonds shall be additional obligations payable from the Net Revenues of the Store on a parity with the 1987 Bonds in accordance with Section 3.06 of the Authorizing Resolution. The Bonds shall be payable from the Revenue Bond Account established within the Liquor Store Fund of the City by Section 3.03 of the Authorizing Resolution on a parity with the 1987 Bonds and any other additional obligations permitted by the Authorizing Resolution to be payable on a parity with the 1987 Bonds and the Bonds. The provisions of Sections 3, 4 and 5 of the Authorizing Resolution are incorporated herein by reference and shall apply to the Bonds and the amendment of this resolution, and the Bonds shall be secured by each and all of the covenants and provisions contained in Sections 3, 4 and 5 of the Authorizing Resolution. 4.02. 1987 Bonds Escrow Account. There is hereby established in the Liquor Store Fund a "1987 Bonds Escrow Account" to which shall be credited $343,670 of the purchase price received from the Purchaser for the bonds and $69,000 from amounts on hand in the Reserve Account established within the Liquor Store Fund by Section 3.04 of the Authorizing Resolution. Funds in the 1987 Bonds Escrow Account shall be invested in securities authorized by law maturing or callable at the • option of the holder thereof on such dates and bearing interest at such rates as shall be required to provide sufficient funds together with any cash or other funds retained in such account to pay the principal of the Refunded Bonds on January 1, 1993. The funds in said account shall be used solely for the purposes herein set forth and for no other purpose, and said account and all securities therein and all payments of principal and interest on said securities are hereby irrevocably pledged to the payment of the principal of the Refunded Bonds; except that if any balance shall remain in said account after all principal has been paid on the Refunded Bonds then such balance shall be transferred to the Revenue Bond Account. 4.03. Costs of Issuance Account. There is hereby established within the Liquor Store Fund a "Costs of Issuance Account", into which shall be paid $16,375 of the proceeds of the Bonds. There shall be chargi_ to and paid from the Costs of Issuance Account costs incurred by the City in connection with the issuance of the Bonds and refunding of the Refunded Bonds, provided that any money remaining in said Costs of Issuance Account shall be transferred to the Revenue Bond Account. 4.04. Reserve Account. $40,500 of the purchase price received from the Purchaser for the Bonds shall be deposited in the Reserve Account. The money in the Reserve Account shall be used to pay the principal and interest on the 1987 • -11- Bonds and the Bonds and any other additional obligations issued pursuant to • Section 3.06 of the Authorizing Resolution payable from Net Revenues of the Store on a parity with the 1987 Bonds and the Bonds. 4.05. Accrued Interest. Accrued interest on the Bonds paid by the Purchaser shall be paid into the Reserve Bond Account. 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 is 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. Section 6. County Auditor Registration, Certification of Proceeding-s, Investment of Moneys, Arbitrage, Designation of Bonds as Qualified Tax Exempt Obligations and Official Statement. 6.01. County Auditor Registration. The City Clerk is hereby authorized and directed to file a certified copy of this resolution with the County Auditors of Hennepin and Ramsey Counties, together with such other information as the County Auditors shall require, and to obtain from said County Auditors certificates that the Bonds have been entered on his bond register as required by law. 6.02. Certification of Proceedings. The officers of the City and the County Auditors of Hennepin and Ramsey Counties 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 -12- 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. Tax Covenant. The City covenants and agrees with the holders from time to time of the Bonds that they will not take or permit to be taken by any of their officers, employees or agents any action which would cause the interest on the Bonds to become subject to taxation under the Internal Revenue Code of 1986, as amended (the Code), and the Treasury Regulations promulgated thereunder (the Regulations), and covenants to take any and all actions within their powers to ensure that the interest on the Bonds will not become subject to taxation under the Code and the Regulations. The City will cause to be filed with the Secretary of Treasury an information reporting statement in the form and at the time prescribed by the Code. The City represents and covenants that the City is and will be the owner of all facilities financed by the 1987 Bonds and will use such facilities to conduct its municipal liquor business. so long as any Bonds are outstanding, the City will not enter into any lease, or any operating, use, management or other agreement respecting said faiclities which would cause the Bonds to be considered "private activity Bonds" or "private loan bonds" pursuant to Section 141 of the Code. 6.04. 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 148 of the Code, and the applicable 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. 6.05. Exemption from Rebate Requirement. For purposes of complying with the requirements of Section 148(f)(4)(C) of the Code relating to the exemption of certain small governmental units from the rebate requirements of the Code, the City represents that: (i) the City is a governmental unit with general taxing powers; (ii) the 1987 Bonds and the Bonds are not "private activity bonds" as defined in Section 141 of the Code (Private Activity Bonds); (iii) ninety-five percent of the net proceeds of the 1987 Bonds were used for the local governmental purposes of the City; -13- • (iv) the aggregate face amount of all tax-exempt bonds (other than Private Activity Bonds) issued by the City in calendar year 1987 did not exceed $5,000,000; and (v) the average maturity of the Bonds does not exceed the average maturity of the Refunded Bonds. 6.06. Interest Disallowance. The City hereby designates the Bonds as "qualified tax-exempt obligations" for purpose of Section 265(b) of the Code relating to the disallowance of interest expenses for financial institutions. The City represents that in calendar year 1992 it does not reasonably expect to issue tax-exempt obligations which are not private activity bonds (not treating qualified 501(c)(3) bonds under Section 145 of the Code as private activity bonds for purposes of this representation) in an amount in excess of $10,000,000. 6.07 Official Statement. The Official Statement, dated August 11, 1992, relating to the Bonds is hereby approved. The officers of the City are hereby authorized and directed to execute such certificates as may be appropriate concerning the accuracy, completeness and sufficiency of the Official Statement. 6.08. Redemption of Refunded Bonds. The Refunded Bonds shall be called for redemption on January 1, 1993, and the City Manager is authorized and directed to take all steps necessary to provide for such redemption. Dated: August 25, 1992. Mayor Attest: ty Clerk The motion for the adoption of the foregoing resolution was duly seconded by Councilmember Fleming and upon vote being taken thereon, the following Councilmembers voted in favor thereof: Marks , Fleming, Enrooth, Ranallo, and Wagner -14- • and the following voted against the same: None whereupon said resolution was declared duly passed and adopted. • • -15-