87-179RESOLUTION NO. 87R- t79
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANAHEIM
PROVIDING FOR THE BORROWING OF FUNDS FOR FISCAL YEAR
1987/1988 AND THE ISSUANCE AND SALE OF 1987 TAX AND REVENUE
ANTICIPATION NOTES THEREFOR AND APPOINTING BOND COUNSEL
WHEREAS, pursuant to Sections 53850 et seq. of the Government Code of the
State of California, this City Council (the "Council") has found and determined that moneys
are needed for the requirements of the City of Anaheim (the "City"), a municipal
corporation and charter city duly organized and existing under the laws of the State of
California, to satisfy obligations payable from the General Fund of the City (the "General
Fund"), and that it is necessary that said sum be borrowed for such purpose at this time
by the issuance of temporary notes therefor in anticipation of the receipt of taxes, revenue
and other moneys to be received by the City for the General Fund during or allocable to
the fiscal year of the City beginning July 1, 1987 and ending June 30, 1988 ("Fiscal Year
1987/1988");
NOW, THEREFORE, the City Council of the City of Anaheim hereby finds,
determines, declares and resolves as follows:
Section 1. Definitions. All capitalized terms used, but not otherwise defined herein,
shall have the following meanings:
(;;ode. The term "Code" means the Internal Revenue Code of 1986, as amended.
Debt Service. The term "Debt Service" means the scheduled amount of interest
and principal payable on the Notes during the period of computation.
Earnings Account. The term "Earnings Account" means the account by that name
created by, and held by the City pursuant to, Section 13 hereof.
Excess Investment Earnings. The term "Excess Investment Earnings" means an
amount equal to the sum of:
(i) the excess of
(A) the aggregate amount earned from the date of delivery of the
Notes on all Nonpurpose Obligations in which Gross Proceeds of the Notes
are invested (other than amounts attributable to an excess described in this
paragraph (i)), over
(B) the amount that would have been earned if the Yield on such
Nonpurpose Obligations (other than amounts attributable to an excess
described in this paragraph (i)) had been equal to the Yield on the Notes,
plus
(ii) any income attributable to the excess described in paragraph (i).
Gr ss Pro eeds. The term "Gross Proceeds" means the sum of the following
amounts:
(i) original proceeds, namely, net amounts (after payment of all expenses of
issuing the Notes) received by or for the City as a result of the sale of the Notes, excluding
original proceeds which become transferred proceeds (determined in accordance with
applicable Regulations) of obligations issued to refund in whole or in part the Notes;
(ii) investment proceeds, namely, amounts received at any time by or for the City,
such as interest and dividends, resulting from the investment of any original proceeds (as
referenced in clause (i) above) or investment proceeds (as referenced in this clause (ii)) in
Nonpurpose Obligations, increased by any profits and decreased (if necessary, below
zero) by any losses on such investments;
(iii) sinking fund proceeds, namely, amounts, other than original proceeds,
investment proceeds, which are held in the Repayment Fund and any other fund to the
extent that the City reasonably expects to use such other fund to pay Debt Service on the
Notes;
(iv) Investment Property pledged as security for payment of Debt Service on the
Notes by an ultimate obligor or a related person or by the City;
(vi) amounts, other than as specified in this definition, used to pay Debt Service on
the Notes; and
(vii) amounts received as a result of investing amounts described in this definition.
Investment Property. The term "investment property" means any security (as said
term is defined in section 165(g)(2)(A) or (B) of the Code), obligation, annuity or
investment-type property, excluding, however, obligations the interest on which is exempt
from income tax under section 103 of the Code.
N n ur o e Obli a ion. The term "Nonpurpose Obligation" means any Investment
Property which is acquired with the Gross Proceeds of the Notes and is not acquired in
order to carry out the governmental purpose of the Notes.
Note Year. The term "Note Year" means the twelve month period beginning on
July 1, 1987 and ending on June 30, 1988.
Purchase Price. The term "Purchase Price," for the purpose of computation of the
Yield of the Notes, has the same meaning as the term "issue price" in sections 1273(b)
and 1274 of the Code, and, in general, means the initial offering price to the public (not
including bond houses and brokers, or similar persons or organizations acting in the
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capacity of underwriters or wholesalers) at which price a substantial amount of the Notes
are sold or, if the Notes are privately placed, the price paid by the first buyer of the Notes
or the acquisition cost of the first buyer. The term "Purchase Price," for the purpose of
computation of the Yield of Nonpurpose Obligations, means the fair market value of the
Nonpurpose Obligations on the date of use of Gross Proceeds of the Notes for acquisition
thereot, or if later, on the date that Investment Property constituting a Nonpurpose
Obligation becomes a Nonpurpose Obligation of the Notes.
Reb~. The term "Rebate Account Account" means the account by that
name created by, and held by the City pursuant to, Section 13 hereot.
Reclulations. The term "Regulations" means temporary and permanent regulations
promulgated under section 148 of the Code.
~. The term "Safe Harbor Rules" means the rules set forth in
Section 148(f)(4)(B)(iii) of the Code.
Yield. The term "Yield" means that yield which, when used in computing the
present worth of all payments of principal and interest (or other payments in the case of
Nonpurpose Obligations which require payments in a form not characterized as principal
and interest) on a Nonpurpose Obligation or on the Notes produces an amount equal to
the Purchase Price of such Nonpurpose Obligation or the Notes, all computed as
prescribed in applicable Regulations.
ctS. Limitation on Maximum Amount. The principal amount of notes issued
pursuant hereto, when added to the interest payable thereon, shall not exceed eighty-five
percent (85%) of the estimated amount of the uncollected taxes, revenue and other
moneys of the City for the General Fund attributable to Fiscal Year 1987-1988, and
available for the payment of said notes and the interest thereon (as hereinafter provided).
Section $. Issuance and Terms of Notes Solely for the purpose of anticipating
taxes, revenue and other moneys to be received by the City for the General Fund during or
allocable to Fiscal Year 1987/1988, and not pursuant to any common plan of financing, the
City hereby determines to and shall borrow the principal amount of thirteen million dollars
($13,000,000) by the issuance of temporary notes under Sections 53850 et seq. of the
Government Code of the State of California, designated "City of Anaheim (Orange County,
California) 1987 Tax and Revenue Anticipation Notes" (the "Notes"). The Notes shall be
numbered from 1 consecutively upward in order of issuance, shall be in the denomination
of $25,000 each or any integral multiple thereot, shall be dated July 1, 1987, shall mature
(without option of prior redemption) on June 30, 1988, and shall bear interest, payable at
maturity and computed on a 30-day month/360-day year basis, at the rate determined in
accordance with the bid of the successful bidder or bidders for the Notes approved by the
resolution of the Council. Both the principal of and interest on the Notes shall be payable,
only upon surrender thereof, in law/ul money of the United States of America, at the office
of the City Treasurer, 200 South Anaheim Boulevard, Anaheim, California.
Section 4. Form of Notes. The Notes shall be issued in bearer form, without
coupons, and shall be substantially in the form and substance set forth in Exhibit A
attached hereto and by reference incorporated herein, the blanks in said form to be filled
in with appropriate words and figures.
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Section 5. ~. The moneys so borrowed shall be deposited in the
General Fund and used and expended by the City for any purpose for which it is
authorized to expend funds from the General Fund.
Section 6. Security. The principal amount of the Notes, together with the interest
thereon, shall be payable from taxes, revenue and other moneys which are received by
the City for the General Fund for Fiscal Year 1987/1988. As security for the payment of
the principal of and interest on the Notes the City hereby pledges the first "unrestricted
moneys" (as hereinafter defined) to be received by the City in the amount of $4,500,000 in
the months of December, 1987, and March, 1988, and the first "unrestricted moneys" to
be received by the City in the amount of $4,000,000 in the month of June, 1988, plus an
amount sufficient to pay interest on the Notes at their maturity (such pledged amounts
being hereinafter called the "Pledged Revenues"). The principal of the Notes and the
interest thereon shall constitute a first lien and charge thereon and shall be payable from
the Pledged Revenues. To the extent not so paid from the Pledged Revenues, the Notes
shall be paid from any other moneys of the City lawfully available therefor. In the event
that there are insufficient "unrestricted moneys" received by the City to permit the deposit
into the Repayment Account (as hereinafter defined) of the full amount of the Pledged
Revenues to be deposited in any month by the last business day of such month, then the
amount of any deficiency shall be satisfied and made up from any other moneys of the
City lawfully available for the repayment of the Notes and interest thereon. The term
"unrestricted moneys" shall mean taxes, income, revenue, cash receipts, and other
moneys intended as receipts for the General Fund for Fiscal Year 1987/1988 and which
are generally available for the payment of current expenses and other obligations of the
City.
Section 7. Payina Agent. The City Treasurer is hereby appointed to act as the
Paying Agent and depository of the City for the purpose of receiving the payments of
principal and interest made by the City on the Notes at maturity, to hold, allocate, use and
apply said payments and to perform such other duties and powers of the Paying Agent as
are prescribed in this Resolution.
Section IL Re a m n Ac unt. There is hereby created, within the General Fund,
a special account to be designated the "1987 Tax and Revenue Anticipation Note
Repayment Account" (the "Repayment Account") and applied as directed in this
Resolution. Any money placed in the Repayment Account shall be for the benefit of the
holders of the Notes and, until the Notes and all interest thereon are paid or until provision
has been made for the payment of the Notes at maturity with interest to maturity, the
moneys in the Repayment Account shall be applied solely for the purposes for which the
Repayment Account is created; provided, however, that, subject to the provisions of
Section 13, any interest earned on amounts deposited in the Repayment Account shall
periodically be transferred to the General Fund.
During the months of December, 1987, March, 1988, and June, 1988, the City shall
deposit all Pledged Revenues in the Repayment Account. On June 30, 1988, the City shall
transfer to the Paying Agent the moneys in the Repayment Account necessary to pay the
principal and interest on the Notes at maturity and to the extent said moneys are
insufficient therefor an amount of moneys from the General Fund which will enable
payment of the full principal and interest on the Notes at maturity. Any moneys remaining
in the Repayment Account after the Notes and the interest thereon have been paid, or
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provision for such payment has been made, shall be transferred to the City for deposit in
the General Fund.
Section 9. Deposit and Investment Qf Repayment Account. All moneys held by the
City in the Repayment Account, if not invested, shall be held in time or demand deposits
as public funds and shall be secured at all times by bonds or other obligations which are
authorized by law as security for public deposits, of a market value at least equal to the
amount required by law.
Moneys in the Repayment Account shall, to the greatest extent possible, be
invested by the City Treasurer directly, or through an investment agreement, in
investments as permitted by the laws of the State of California as now in effect and as
hereafter amended, and the proceeds of any such investments shall be deposited in the
Repayment Account.
Section 10. Execution of Notes. The Mayor of the City is hereby authorized to
execute the Notes by manual or facsimile signature, and the City Clerk of the City is
hereby authorized to countersign the same by manual or facsimile signature (provided that
at least one of such signatures shall be manual) and to affix the seal of the City thereto by
facsimile impression thereof, and said officers are hereby authorized to cause the blank
spaces thereof to be filled in as may be appropriate.
Section 11. Covenants and Warranties It is hereby covenanted and warranted by
the City that all representations and recitals contained in this Resolution are true and
correct, and that the City and its appropriate officials have duly taken all proceedings
necessary to be taken by them, and will take any additional proceedings necessary to be
taken by them, for the prompt collection and enforcement of the taxes, revenue, cash
receipts and other moneys pledged hereunder in accordance with law and for carrying out
the provisions of this Resolution.
Section 12. Arbitrage Covenant. The City shall not take, or permit or suffer to be
taken by the Paying Agent or otherwise, any action with respect to the proceeds of the
Notes which, if such action had been reasonably expected to have been taken, or had
been deliberately and intentionally taken, on the date of delivery of the Notes, would have
caused the Notes to be "arbitrage bonds" within the meaning of section 148(a) of the
Internal Revenue Code of 1986, as amended (the "Code"), and the the regulations
promulgated thereunder.
Section 13. Rebate of Excess Investment Earninas to United States; InaDplicabilib¢¢
of Rebate Under Cedain Circumstances
(a) Cr ation f Acc unts. There are hereby created, to be held by the City as
separate accounts distinct from the Repayment Account held by the City under this
Resolution, the Earnings Account and the Rebate Account. All interest earnings and
profits on amounts in all funds and accounts established under this Resolution, other than
interest earnings on the Repayment Fund if such earnings in the Note Year are less than
$100,000, shall, upon receipt by the City, be deposited in the Earnings Account. In
addition, all interest earning.s and profits on Gross Proceeds in funds held by the City
shall, upon receipt, be deposited in the Earnings Account. If the City has not complied
with the Safe Harbor Rules, the City shall, on June 30, 1988, transfer from the Earnings
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Account to the Rebate Account for purposes of ultimate rebate to the United States an
amount equal to Excess Investment Earnings, all as more particularly described in this
Section 13. Following the transfer referenced in the preceding sentence, the City shall
transfer all amounts remaining in the Earnings Account to the Repayment Fund to be used
for the payment of Debt Service on the Notes at maturity and, for such purpose, Debt
Service due from the City on such date shall be credited by an amount equal to the
amount so transferred.
(b) Duties of the City in General. The City shall calculate Excess Investment
Earnings in accordance with subsection (c) and shall assure payment of an amount equal
to Excess Investment Earnings to the United States in accordance with subsections (d)
and (e).
(c) Calculation of Excess Investment Earnings. Prior to the last day of the Note
Year, the City shall calculate the Excess Investment Earnings referenced in paragraph (i)
of definition thereof. Thereafter, prior to the last day of each Note Year and on the date of
the retiremeht of the Notes, the City shall calculate Excess Investment Earnings. Said
calculations shall be made or caused to be made by the City in accordance with the
following:
(1) Except as provided in (2), in determining the amount described in
paragraph (i)(A) of subsection (b), the aggregate amount earned on
Nonpurpose Obligations shall include (i) all income realized under federal
income tax accounting principles (whether or not the person earning such
income is subject to federal income tax) with respect to such Nonpurpose
Obligations and with respect to the reinvestment of investment receipts from
such Nonpurpose Obligations (without regard to the transaction costs
incurred in acquiring, carrying, selling or redeeming such Nonpurpose
Obligations), including, but not limited to, gain or loss realized on the
disposition of such Nonpurpose Obligations (without regard to when such
gains are taken into account under Section 453 of the Code relating to
taxable year of inclusion of gross income), and income under Section 1272
of the Code (relating to original issue discount) and (ii) any unrealized gain
or loss as of the date of retirement of the Notes in the event that any
Nonpurpose Obligation is retained after such date.
(2) In determining the amount described in paragraph (i) of the
definition of Excess Investment Earnings, Investment Property shall be
treated as acquired for its fair market value at the time it becomes a
Nonpurpose Obligation, so that gain or loss on the disposition of such
Investment Property shall be computed with reference to such fair market
value as its adjusted basis.
(3) In determining the amount described in paragraph (i)(B) of the
definition of Excess Investment Earnings, the Yield on the Notes shall be
determined based on the actual Yield of the Notes during the period
between the date of issuance of the Notes and the date the computation is
made (with adjustments for discount or premium).
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(4) In determining the amount described in paragraph (ii)of the
definition of Excess Investment Earnings, all income attributable to the
excess described in paragraph (i) of said definition must be taken into
account, whether or not that income exceeds the Yield on the Notes, and no
amount may be treated as "negative arbitrage".
(5) In determining the amount of Excess Investment Earnings, there
shall be excluded any amount earned on any fund or account which is used
primarily to achieve a proper matching of revenues and Debt Service within
each Note Year and which is depleted at least once a year except for a
reasonable carryover amount not in excess of the greater of one year's
earnings on such fund or account or one-twelfth of annual Debt Service as
well as amounts earned on said earnings if the gross earnings on all such
funds and accounts for the Note Year is less than $100,000.
(d) Payment to United States. Not later than sixty (60) days after the retirement of
the Notes, the City shall pay from the Rebate Account to the United States 100 percent of
the Excess Investment Earnings. In the event that there are any amounts remaining in the
Rebate Account following the payment required by the preceding sentence, said amounts
may be used for any lawful purpose of the City. The City shall remit payments to the
United States at the address prescribed by the Regulations as the same may be in time to
time in eftect with such reports and statements as may be prescribed by such
Regulations. In the event that, for any reason, amounts in the Rebate Account are
insufficient to make the payments to the United States which are required by this
subsection (d), the City shall assure that such payments are made to the United States, on
a timely basis, from any funds lawfully available therefor.
(e) Further Obli(~ation of City. The City shall assure that Excess Investment
Earnings are not paid or disbursed except as required in this Section 13. To that end, the
City shall assure that investment transactions are on an arm's length basis and that
Nonpurpose Obligations are acquired at their fair market value. In the event that
Nonpurpose Obligations consist of certificates of deposit or investment contracts,
investment in such Nonpurpose Obligations shall be made in accordance with the
procedures described in applicable Regulations as from time to time in effect.
(f) Maintenance of Records. The City shall keep, and retain for a period of six (6)
years following the retirement of the Notes, records of the determinations made pursuant
to this Section 13.
(g) Independent Consultants. In order to provide for the administration of this
Section 13, the City may provide for the employment of independent attorneys,
accountants and consultants compensated on such reasonable basis as the City may
deem appropriate.
(h) Inapolicabili_ty of Rebate Under Certain Circumstances. Anything herein to the
contrary notwithstanding, the City shall not be obligated to rebate Excess Investment
Earnings to the United States if the City shall comply with the Safe Harbor Rules, and the
City may, upon compliance with the Safe Harbor Rules, transfer all amounts then on hand
in the Earnings Account to the General Fund and the Earnings Account and Rebate
Account may thereupon be closed.
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Section 14. Sale of Notes The Notes are hereby ordered to be sold to the
successful bidder or bidders therefor approved by the Council by resolution.
Section 15. Preparation of Notes: Official Action. Jones Hall Hill & White, A
Professional Law Corporation, as Bond Counsel, is d~rected to cause suitable Notes' to be
prepared showing on their face that the same bear interest at the rate specified in the offer
submitted by the successful bidder or bidders, and to cause the blank Spaces therein to
be filled in to comply with the provisions of this Resolution, and to procure their execution
by the proper officers, and to cause the Notes to be delivered when so executed to the
purchaser or purchasers thereof.
The Mayor, Director of Finance, Assistant Director of Finance, City Treasurer and
City Clerk, or any of them, are further authorized and directed to make, execute and
deliver such certificates, agreements and other closing documents as are necessary to
consummate the transactions contemplated by this Resolution.
PASSED AND ADOPTED by the City Council of the City of Anaheim, California, this
12th day of May. 1987.
IS E A L]
Attest:
City Clerk
Mayor
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CLEP. K
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.
CITY OF ANAHEIM )
I, LEONORA N. SOHL, City Clerk of the City of Anaheim, do hereby certify that
the foregoing Resolution No. 87R-t79 was introduced and adopted at a regular
meeting provided by law, of the City Council of the City of Anaheim held on
the 12th day of May, 1987, by the following vote of the members thereof:
AYES: COUNCIL MEMBERS: Pickler, Hunter, Kaywood and Bay
NOES: COUNCIL MEMBERS: None
ABSENT: COUNCIL MEMBERS: None
VACANCY: COUNCIL MEMBERS: One
AND I FURTHER certify that the Mayor of the City of Anaheim signed said
Resolution No. 87R-179 on the 12th day of May, 1987.
IN WITNESS W]{EREOF, I have hereunto set my hand and affixed the seal of the
City of Anaheim this 12th day of May, 1987.
CITY CLERK OF T~HE' CITY OF ANAHEIM
(SEAL)
I, LEONORA N. SOHL, City Clerk of the City of Anaheim, do hereby certify that
the foregoing is the original of Resolution No. 87R-179 duly passed and
adopted by the Anaheim City Council on May 12, 1987.
CITY CLERK OF THE CITY OF ANAHEIM
[Form of Note]
CITY OF ANAHEIM
(ORANGE COUNTY, CALIFORNIA)
1987 TAX AND REVENUE ANTICIPATION NOTE
NO.
Date: July 1, 1987
FOR VALUE RECEIVED, the City of Anaheim (the "City"), State of California,
acknowledges itself indebted to and promises to pay to the bearer hereof, at the office of
the City Treasurer, 200 South Anaheim Boulevard, Anaheim, California, the principal sum
of
DOLLARS ($_ )
lawful money of the United States of America, on June 30, 1988, together with interest
thereon at the rate of percent ( %) per annum in like lawful
money from the date hereof until payment in full of said principal sum. Both the principal
of and interest on this Note shall be payable only upon surrender of this Note as the same
shall fall due; provided, however, no interest shall be payable for any period after maturity
during which the holder hereof fails properly to present this Note for payment.
It is hereby certified, recited and declared that this Note is one of an authorized
issue of Notes in the aggregate principal amount of thirteen million dollars ($13,000,000),
all of like tenor, issued pursuant to the provisions of Resolution No. 87R~ of the City
Council of the City duly passed and adopted on May 12, 1987, and pursuant to Article 7.6
(commencing with Section 53850) of Chapter 4, Part 1, Division 2, Title 5, of the California
Government Code, and that all things, conditions and acts required to exist, happened and
been performed in regular and due time, form and manner as required by law, and that
this Note, together with all other indebtedness and obligations of the City, does not exceed
any limit prescribed by the Constitution or statutes of the State of California.
The principal amount of the Notes, together with the interest thereon, shall be
payable from taxes, revenue and other moneys which are received by the City for the
General Fund for Fiscal Year 1987/1988. As security for the payment of the principal of
and interest on the Notes the City has pledged the first "unrestricted moneys" (as
hereinafter defined) to be received by the City in the amount of $4,500,000 in the months of
December, 1987, and March, 1988, and the first "unrestricted moneys" to be received by
the City in the amount of $4,000,000 in June, 1988, plus an amount sufficient to pay
interest on the Notes at their maturity (such pledged amounts being hereinafter called the
"Pledged Revenues"). The principal of the Notes and the interest thereon shall constitute
a first lien and charge thereon and shall be payable from the Pledged Revenues. To the
extent not so paid from the Pledged Revenues, the Notes shall be paid from any other
moneys of the City lawfully available therefor. In the event that there are insufficient
Exhibit A
Page 1
"unrestricted moneys" received by the City to permit the deposit into the Repayment
Account (as hereinafter defined) of the full amount of the Pledged Revenues to be
deposited in any month by the last business day of such month, then the amount of any
deficiency shall be satisfied and made up from any other moneys of the City lawfully
available for the repayment of the Notes and interest thereon. The term "unrestricted
moneys" shall mean taxes, income, revenue, cash receipts, and other moneys intended
as receipts for the General Fund for Fiscal Year 1987/1988 and which are generally
available for the payment of current expenses and other obligations of the City.
IN WITNESS WHEREOF, the City of Anaheim has caused this Note to be executed
by the Mayor of the City and countersigned by the City Clerk of the City, and caused its
official seal to be affixed hereto all as of this 1st day of July, 1987.
CITY OF ANAHEIM
[S E A L]
Countersigned:
By_
Mayor
City Clerk
Exhibit A
Page 2