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HomeMy WebLinkAbout94-025BOARD OF SUPERVISORS, COUNTY OF BUTTE, STATE OF CALIFORNIA RESOLUTION NO. 94-25 RESOLUTION OF THE BOARD OF SUPERVISORS OF THE COUNTY OF BUTTE PROVIDING FOR THE ISSUANCE OF BUTTE COUNTY OFFICE OF EDUCATION, COUNTY OF BUTTE, STATE OF CALIFORNIA, 1994 TAX AND REVENUE ANTICIPATION NOTES WHEREAS, pursuant to Sections 53850 et sue. of the Government Code of the State of California (the "Act"? contained in Article 7.6 thereof, entitled "Temporary Borrowing", on or after the first day of any fiscal year (being July 1}, a school district or county office of education may borrow money by issuing notes for any purpose for which the school district or caunty office of education is authorized to expend moneys, including but not limited to current expenses, capital expenditures, and the discharge of any obligation or indebtedness of the school district or county office of education; and WHEREAS, Section 53853 of the Act provides that such notes must be issued in the name of the county office of education by the board of supervisors of the county, the county superintendent of which has jurisdiction over the caunty office of education, as soon as possible following the receipt of a resolution of the governing board of the county office of education requesting the borrowing; and WHEREAS, the County Superintendent of the County of Butte (the "County") has jurisdiction over Butte County Office of Education (the "Office"}, and this Board of Supervisors of the County (the "County Board"} has received a resolution of the Board of Education of the Office (the "Office Board"), being the governing board of the Office, dated February 22, 1994, entitled "RESOLUTION OF THE BOARD OF EDUCATION OF BUTTE COUNTY OFFICE OF EDUCATION AUTHORIZING THE ISSUANCE OF 1994 TAX AND REVENUE ANTICIPATION NOTES FOR SAID OFFICE AND REQUESTING THE BOARD OF SUPERVISORS OF THE COUNTY OF BUTTE TO ISSUE SAID NOTES" (the "Office Resolution"}, attached hereto as Exhibit A, which Office Resolution requests the borrowing of not exceeding Ten Million Dollars ($10,000,000} at an interest rate not exceeding five percent ( 5 a ) per annum through the issuance by the County Board of 1994 Tax and Revenue Anticipation Notes (the "Notes"} in the name of the Office; and WHEREAS, such Notes are payable twelve months after their date of delivery which is during the fiscal year succeeding the fiscal year 1993-1994 in which such Notes were issued, but as required by Section 53854 of the Act, such date is not later than fifteen 88580\00001\7956.3 months after the date of issue, and such Notes shall be payable only from revenue received or accrued during the fiscal year 1993-1994 in which issued; and WHEREAS, pursuant to Section 53856 of the Act, the Office may pledge any taxes, income, revenue, cash receipts or other moneys deposited in inactive or term deposits (but excepting certain moneys encumbered for a special purpose); and the Office Resolution specifies that certain unrestricted revenues that will be received by the Office for the General Fund of the Office during or allocable to fiscal year 1993-1994 are pledged for the payment of the Notes; and WHEREAS, the Notes shall be a general obligation of the Office , and to the extent not paid from the taxes , income , revenue , cash receipts and other moneys of the Office pledged for the payment thereof shall be paid with interest thereon from any other moneys of the Office lawfully available therefor, as required by Section 53857 of the Act; and WHEREAS, the Notes shall be in denominations of $1,000 or integral multiples thereof, as permitted by Section 53854 of the Act; shall be issued on a date to be designated and shall be in the form and executed in the manner prescribed in this Resolution, all as permitted and required by Section 53853 of the Act; and WHEREAS, the County Board, in reliance on a determination by the Office, has found and determined that said $10,000,000 maximum principal amount of Notes to be issued by the County Board in fiscal year 1993-1994, when added to the interest payable thereon, does not exceed eighty-five percent (850} of the estimated amount of the uncollected taxes, income, revenue (including but not limited to revenue from state and federal governments), cash receipts and other moneys of the Office which will be available for the payment of the Notes and interest thereon, as required by Section 53858 of the Act; and WHEREAS, the Notes will not be outstanding after a period ending twelve months after the date on which such Notes are issued and will not be issued in an amount greater than the maximum anticipated cumulative cash flaw deficit to be financed by the anticipated tax or other revenue sources for the period for which such taxes or other revenues are anticipated and during which such Notes are outstanding, all as provided in Section 1.103-14 (c) of the Income Tax Regulations of the United States Treasury; and WHEREAS, pursuant to Section 265 (b} (3) of the Internal Revenue Code of 1986, as amended (the "Code"), under certain circumstances, certain obligations the interest on which is exempt from federal income tax under Section 103 of the Code may be designated by the issuer thereof as "qualified tax-exempt obligations," thereby allowing certain financial institutions that are holders of such qualified tax-exempt obligations to deduct for federal income tax 88580~t1t1(7(71V`7956.3 purposes a portion of such institution's interest expense that is allocable to such qualified tax-exempt obligations, all as determined in accordance with Sections 265 and 291 of the Code; and WHEREAS, the Office Board has represented in the Office Resolution that: (1) the Notes authorized by this resolution are not private activity bands within the meaning of Section 141 of the Code; (2) the Office, together with all of its subordinate entities, has not heretofore issued any obligations (other than those obligations described in Paragraph {4) below) in calendar year 1994 the interest on which is exempt from federal income tax under Section 103 of the Code; {3) the Office reasonably anticipates that it, together with its subordinate entities will issue during the remainder of calendar year 1994 obligations {other than those obligations described in paragraph 4 below} the interest on which is exempt from federal income tax under Section 103 of the Code which, when aggregated with all obligations described in paragraph 2 above, will not exceed an aggregate principal amount of $10,000,000; and (4) notwithstanding paragraphs 2 and 3 above, the Office and its subordinate entities may have issued in calendar year 1994 and may continue to issue during the remainder of calendar year 1994 private activity bonds other than qualified 501(c){3) bonds as defined in Section 145 of the Cade; and WHEREAS, the Office Board wishes to designate the Notes as "qualified tax-exempt obligations" within the meaning of Section 265{b)(3) of the Code; NOW, THEREFORE, the Board of Supervisors of the County of Butte hereby resolves as follows: Section 1. Authorization of Issuance of Notes• Terms Thereof. The County Board hereby determines to, and shall issue in the name of the Office, an amount not to exceed $10,000,000 principal amount of notes under Sections 53850 et sew. of the Act, designated "Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes"; to be numbered 1 {and consecutively upward in order of issuance if more than one Note is registered}; to be in the denominations of $1,000, or integral multiples thereof; to be dated the date of delivery thereof; to mature (without option of prior redemption} within 360 days computed on a 30-day monthJ360-day year basis or, if such date is not a day on which banks in New York or California are open for business, on the last day prior to such date; and to bear interest, payable at maturity and computed on a 30-day monthJ360-day year basis, at the rate or rates determined at the time of sale thereof, but not in excess of five percent (5%) per annum. Both the sesao\ooooi\~~s6.3 3 purposes a portion of such institution's interest expense that is allocable to such qualified tax-exempt obligations, all as determined in accordance with Sections 265 and 291 of the Code; and WHEREAS, the Office Board has represented in the Office Resolution that: (1} the Notes authorized by this resolution are not private activity bands within the meaning of Section 141 of the Code; (2) the Office, together with all of its subordinate entities, has not heretofore issued any obligations (other than those obligations described in Paragraph {4) below) in calendar year 1994 the interest on which is exempt fram federal .income tax under Section 103 of the Code; (3) the Office reasonably anticipates that it, together with its subordinate entities will issue during the remainder of calendar year 1994 obligations (other than those obligations described in paragraph 4 below} the interest on which is exempt from federal income tax under Section 103 of the Cade which, when aggregated with all obligations described in paragraph 2 above, will not exceed an aggregate principal amount of $10,000,000; and (4} notwithstanding paragraphs 2 and 3 above, the Office and its subardinate entities may have issued in calendar year 1994 and may continue to issue during the remainder of calendar year 1994 private activity bonds other than qualified 501 (c}(3) bonds as defined in Section 145 of the Code; and WHEREAS, the Office Board wishes to designate the Notes as "qualified tax-exempt obligations" within the meaning of Section 265(b}(3) of the Code; NOW, THEREFORE, the Board of Supervisors of the County, of Butte hereby resolves as follows: Section 1. Authorization of Issuance of Notes• Terms Thereof. The County Board hereby determines to, and shall issue in the name of the Office, an amount not to exceed $10,000,000 principal amount of notes under Sections 53850 et seg. of the Act, designated "Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes"; to be numbered 1 (and consecutively upward in order of issuance if more than one Note is registered); to be in the denominations of $1,000, ar integral multiples thereof; to be dated the date of delivery thereof; to mature (without option of prior redemption) within 360 days computed on a 30-day monthJ360-day year basis or, if such date is not a day on which banks in New York or California are open for business, an the last day prior to such date; and to bear interest, payable at maturity and computed on a 30-day month/360-day year basis, at the rate or rates determined at the time of sale thereof, but not in excess of f.~ve percent (50} per annum. Both the Sasso\ao~ci\;~sh.s 3 principal of and interest on the Notes shall be payable, only upon surrender thereof, in lawful money and of the United States of America at the office of the Treasurer and Tax Collector (the "Treasurer"} of the County which is hereby designated to be the paying agent on the Notes {in such capacity, the "Paying Agent"}. Section 2. Form of Notes. The Notes shall be issued in registered form and shall be substantially in the form and substance set farth in Exhibit B attached hereto and by reference incorporated herein, the blanks in said form to be filled in with appropriate words and figures. The Notes shall be initially registered in the name of "Cede & Co." as nominee of The Depositary Trust Company, and shall be evidenced by one note in the full principal amount of the Notes. The Depository Trust Company, New York, New York is hereby appointed depository for the Notes. Registered ownership may not thereafter be transferred except as set forth in Section 4 hereof. There shall be simultaneously delivered with each Note, the legal opinion of Brown & Wood respecting the validity of said Notes and, immediately preceding such legal opinion, a certificate executed with the facsimile signature of the Chair of the County Board {the "County Chair"}, said certificate to be in substantially the fallowing form: I HEREBY CERTIFY that the following is a true and correct copy of the legal opinion regarding the Notes therein described that was manually signed by Brown & Wood, and was dated as of the date of delivery of and payment for said Notes. [Facsimile Signature] _ Chair, Board of Supervisors Section 3. Transfer and Exchange of Notes. Subject to the provisions of Section 4 hereof, the registration of any Nate may, in accordance with its terms, be transferred, upon the registration books kept by the Paying Agent for such purpose, by the person in whose name it is registered, in person or by his or her duly authorized attorney, upon surrender of such Note for cancellation, accompanied by delivery of a written instrument of transfer, duly executed in a form approved by the Paying Agent. Whenever any Note or Notes shall be surrendered for registration or transfer, the Paying Agent shall execute and deliver a new Nate or Notes, for a like aggregate principal amount . The Paying Agent shall require the Note owner requesting such registration of transfer to pay any tax or other governmental charge required to be paid with respect to such transfer. The County may require the owner requesting such registration of transfer to pay such additional reasonable charge as may be necessary to cover customary expenses incurred and fees charged by the Paying Agent with respect to such registration of transfer. The Paying Agent may treat the registered owner of any Note as the Sfl58G\00001\7956.3 4 absolute owner thereof for all purposes whatsoever in accordance with this resolution, and the Paying Agent shall not be affected by any notice to the contrary. Subject to the provisions of Section 4 hereof, Notes may be exchanged at the office of the Paying Agent in Oroville, California for a like aggregate principal amount of Notes in other authorized denominations. The Paying Agent shall require the payment by the Note owner requesting such exchange of any tax or other governmental charge required to be paid with respect to such exchange. The Office may require the owner requesting such exchange to pay such additional reasonable charge as may be necessary to cover customary expenses incurred and fees charged by the Paying Agent or the Office with respect to such exchange. Section 4. Use of Depository. (1} The Notes shall be initially registered as provided in Section 2 hereof. Registered ownership of the Notes, or any portion thereof, may not thereafter be transferred except: (i ) To any successor of Cede & Co . , as nominee of The Depository Trust Company, or its nominee, or to any substitute depositary designated pursuant to clause (ii) of this Section 4 (a "substitute depository"); provided, that any successor of Cede & Co., as nominee of The Depository Trust Company or a substitute depository, shall be qualified under any applicable laws to provide the services proposed to be provided by it; (ii) To any substitute depository not objected to by the Paying Agent, upon {1) the resignation of The Depository Trust Company or its successor (or any substitute depository or its successor) from its functions as depository, or {2) a determination by the Office to substitute another depository for The Depository Trust Company {or its successor) because The Depository Trust Company or its successor {or any substitute depository or its successor) is no longer able to carry out its functions as depository; provided, that any such substitute depository shall be qualified under any applicable laws to provide the services proposed to be provided by it; or {iii) To any person as provided below, upon (l} the resignation of The Depository Trust Company or its successor (or substitute depository or its successor) from its functions as depository, or {2) a determination by the Office to remove The Depository Trust Company or its successor (or any substitute depository or its successor) from its functions as depository. 88580\00001\7956.3 (2) In the case of any transfer pursuant to clause (i} or clause (ii} of subsection {1} of this Section 4, upon receipt of the outstanding Notes by the Paying Agent, together with a request of the Office to the Paying Agent, a new Note shall be executed and delivered in the aggregate principal amount of the Notes registered in the name of such successor or such substitute depository, or their nominees, as the case may be, all as specified in such request of the Office. In the case of any transfer pursuant to clause {iii} of subsection (1) of this subparagraph (d), upon receipt of the outstanding Notes by the Paying Agent together with a request of the Office to the Paying Agent, new Notes shall be executed and delivered in such denominations numbered in the manner determined by the Paying Agent and registered in the names of such persons as are requested in such a request of the Office; provided that the Paying Agent shall not be required to deliver such new Notes within a period less than sixty (60} days Pram the date of receipt of such a request of the Office. Thereafter, Notes shall be transferred pursuant to Section 3 hereof . (3} The Office and the Paying Agent shall be entitled to treat the person in whose name any Note is registered as the owner thereof for all purposes of this resolution and any applicable laws, notwithstanding any notice to the contrary received by the Paying Agent or the Office; and the Office and the Paying Agent shall have no responsibility far transmitting payments to, communication with, notifying, or otherwise dealing with any beneficial owners of the Notes and neither the Office nor the Paying Agent will have any responsibility or obligations, legal or otherwise, to the beneficial owners or to any other party, including The Depository Trust Company or its successor (or substitute depository or its successor}, except far the Owner of any Notes. (4} So long as the outstanding Notes are registered in the name of Cede & Co. or its registered assigns, the Office and the Paying Agent shall cooperate with Cede & Co., as sole registered Owner, or its registered assigns in effecting payment of the principal of and interest on the Notes by arranging for payment in such manner that funds for such payments are properly identified and are made immediately available on the date they are due. Section 5. Deposit of Note Proceeds; No Arbitrage. The moneys so borrowed initially shall be deposited in the General Fund of the Office and subsequently credited, in the amounts of the respective loans requested from the Office by certain school districts within the County, first, in the amounts which such school districts and the Office shall direct the Treasurer to deposit, to the respective accounts in the Repayment Fund (as hereinafter defined} , as sufficient for the payment of interest due at maturity on the notes of the school districts evidencing such ss~ao\ooooi\~9s~.s 5 Iodns (the "District Notes"), which are hereby autharized to be issued by trLi s Hoard in the Warne of such school districts, and, second, in t:Ze remaining amount, to the respective general funds of such school districts. The Office has covenanted that it will mare ro use of the proceeds of the Notes that would cause the Notes to be "arbitrage bonds" under Section 148 of t~-,e Code; and, to that end, so long as an.y of the Notes are outstanding, the Office, and all of its officers having custody or control of suc:~ praceeds, have agreed to comply with all rEquirements of said section, including restrictions on the use and investment of proceeds of the Notes and the rebate of a portion of investment earnings on certain amounts, including proceeds of the Notes, if required, to the Federal government, and of `he I.~come Tax Regulations of the tirited ,States Treasury promulgated thereunder or under any predecessor provisions, to the extent teat suc;~ regulatians are, at t~.e tl~lte, applicable and in effect, SC that the Hates wild. not be "arbitrage bonds . '~ Section b. Payment of Notes. (A) Sources of Pavi'.er.t The principal amount o= the ivotes, together with the interest there~:,n, s:rzall be payable from taxes, income, revenue, cash receipts and other moneys (including the deposits to the Repa <<,ent Fund described in Sec; ion 5 hereof } which are recaived by the Of `ice ~ur~.ng fiscal year 1993-1994 and W17iC are available therefor. Thp Hates shall be a genera. obligation cf the Office, and to the extent the Notes are nest paid from the Pledged Revenues defined below, the Notes shall be paid with interest thereon. from any other moneys of the Office lawfully available therefor, as provided in the Office Resolution and by law. (8) Pledoed Revenues. As security for t e pay`i.ent of the nr?.-:C~pal C.. anQ J.n~ereSt on tr:? NateS the OffyCe o.~edces a:i at~..ai.lnt equal t0 5e'Senty-fivve percen`_ { 1~3) Of t~:e principal amCt:^t Cf the Notes from tie unreSt?"wC~eG reVer:UeS reCelL-ed by t?:e ~ f:_Ce in Cr attributable tc thA month e,~di,.g ~'tay 31, 1994, plus an ar^cur.t equal to twenty-five percent (2>>} of the principal amount of the Fetes from. the unrestricted revenues received by the Office in cr attributable to the month ending June 3C, 1994., plus an amaunt sufficient to pay at maturity interest on the Notes and deposited in the Re,Uayment Fund (as hereinaftew defined) pursuant to Scotian 5 hereof (such pledged amounts being hereinafter called the "Pledged Revenues" } hiay 31, 1994 ar_d June 3C, 1994 s'r.all GCnStJ.tute t}'1~' "depCS~t dates" referred tC in ~eCtiCn 4l~'/ Of the rZSOlLltlaii8 of the U1,Str.tCtS c"iut:7ar1Z1n~ the iSSuanr'~e Cf the District Notes . T'he terra "unre5trlCted ~:everiUPS" Sia1.1 mean taxp5, income, revenue, cash receipts, a: d other money of the Office as provided in Section 53855 of the Act, which are intended as receipts for the General Fund of the Office and which are generally available for t:.e payment of current e:cpenses and other ob~.igations Of the Office, all as further defined In the Of~J.Ce ReSalutlCn. The principal of the Notes and the interest thereon shall be a first lien and charge against a:zd shall be payable from the first -~ 8°530~,00~01V7?35.3 moneys received by the Office from such. Pledged Revenues as provided by law. In the event that there are insufficient unrestricted revenues received by the Office to permit the deposit into the County investment pool and credited to the Repayment Fund, as hereinafter defined, of the full amount of Pledged Revenues to be deposited from unrestricted revenues in any month, then the amount of such deficiency shall be satisfied and made up from any other moneys of the Office lawfully available for the repayment of the Notes and the interest thereon. (C) Covenant Reaarding Additional Short-Term Borrowing. The Office has covenanted and warranted that it will not request the Treasurer to make temporary transfers of funds in the custody of the Treasurer to meet any obligations of the Office during the 1993-1994 fiscal year pursuant to the authority of Article XVI, Section 6 of the Constitution of the State of California or any other legal authority. (D} Deposit of Pledged Revenues in Repayment Fund. As the Pledged Revenues are received by the County on behalf of the Office, they shall be deposited directly with and held by the Treasurer in the appropriate accounts in a special fund designated as the "Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes Repayment Fund" (herein called the "Repayment Fund"} and shall not be available to the Office. Separate accounts shall be established within the Repayment Fund for the deposit of (i) unrestricted revenues received by the Office as payments with respect to each loan made from the proceeds of the Notes to a school district and (ii) unrestricted revenues from other sources. Any moneys placed in the Repayment Fund shall be far 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 Fund shall be applied only for the purposes for which the Repayment Fund is created. (E) Disbursement and Investment of Moneys in Repayment Fund. After such date as the amount of Pledged Revenues deposited in the Repayment Fund shall be sufficient to pay in full the principal of and interest on the Notes, when due, any moneys in excess of such amount remaining in or accruing to the Repayment Fund shall be transferred to the General Fund of the Office upon the request of the Office. On the maturity date of the Notes, the moneys in the Repayment Fund shall be used, to the extent necessary, to pay the principal of and interest on the Notes. Moneys in the Repayment Fund, to the greatest extent possible, shall be invested at the request of the Office in investment securities by the Treasurer, as permitted by applicable California law, as it is now in effect and as it may be amended, modified or assae\coooi\~~s6.3 ~ supplemented from time to time; to the extent that moneys invested or held by the County are subject to arbitrage rebate, neither the County nor any officer or employee of the County shall assume hereunder or under the provisions of any rebate certificate any duty or obligation to make the actual calculations of arbitrage rebate liability of the Office, or to pay any such rebate or any penalties in regard thereto if the Office miscalculates or fails to pay ar cause such rebate or such penalties to be paid. Section 7. Execution of Notes; Registration. The County Chair, or a designated deputy thereof, is hereby authorized to sign the Notes manually or by facsimile signature, and the Treasurer is hereby authorized to sign the Notes manually or by facsimile signature and the Clerk of the County Board (the "Clerk") is hereby authorized to countersign the Notes manually or by facsimile signature, provided that at least one of the foregoing shall sign manually, and said Clerk is hereby authorized to affix the seal of the County Board 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. This Board does hereby appoint the Paying Agent to act as bond registrar and transfer agent far the Notes. So long as any of the Notes remain outstanding, the Paying Agent will maintain and keep all books and records necessary for the registration, exchange and transfer of the Notes. Section 8. Sale of the Notes. The Notes will be sold by competitive sale. Such sale shall be at the time and place and upon the terms provided in the Official Notice of Sale of the Notes (the "Official Notice"), which Official Notice is substantially in the form attached hereto as Exhibit C. Sealed or facsimile bids for the purchase of the Notes shall be received by the Treasurer at the time and place set forth in the Official Notice. The Treasurer, or his authorized designee, is authorized to distribute copies of the Official Notice and to publish a Notice of Intention to Sell substantially in the farm of Exhibit D hereto in The Bond Buyer once at least fifteen (15) days prior to the date set to receive bids. The Treasurer, or his authorized designee, is authorized to accept the bid with the lowest true interest cost so long as the aggregate principal of Notes does not exceed Ten Million Dollars ($10,000,000) and the interest rate thereon does not exceed five percent (50) per annum. Section 9. Appointment of Bond Counsel; Authorization of Preliminary Official Statement and Official Statement. Brown & Wood is hereby designated as the bond counsel in connection with the issuance of the Notes. Government Financial Strategies, Inc., the financial advisor to the Office, is hereby authorized to prepare a Preliminary Official Statement and an Official Statement relating to the Notes, to be used in connection with the offering and sale of the Notes. The Superintendent, or any Assistant aeseo\odaoi\~~s6.3 9 Superintendent, of the Office is hereby authorized and requested to execute and deliver the Official Statement. Section 10. Delivery of Notes. The proper officers of the County Board and the Treasurer are hereby authorized and directed to deliver the Notes to the successful bidder therefor. All actions heretofore taken by the officers and agents of the County Board with respect to the sale and issuance of the Notes are hereby approved, confirmed and ratified, and the officers of the County Board are hereby authorized and directed, far and in the name and on behalf of the County Board, to do any and all things and take any and all actions and execute and deliver any and all certificates, agreements and other documents, which they, or any of them, may deem necessary or advisable in order to consummate the lawful issuance and delivery of the Notes in accordance with this Resolution and the resolution heretofore adopted by the Office Board. Section 11. Further Actions Authorized. It is hereby covenanted that the County, 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 levy, collection and enforcement of the secured property taxes pledged under the Office Resolution in accordance with the law and for carrying out the provisions of the Office Resolution and of this Resolution. Section 12. Recitals. above are determines true and correct and represents. All the recitals in this Resolution and this County Board so finds, Section 13. Designation as Qualified Tax-Exempt Obligation. As provided in the Office Resolution, the Notes have been designated as "qualified tax-exempt obligations" within the meaning of Section 265{b){3) of the Code. Section 14. Action Re Qualified Tax-Exempt Obligation. Appropriate officials of the County Board and the Treasurer are hereby authorized and directed to take such other actions as may be necessary to assist the Office in designating such Notes as "qualified tax-exempt obligations," including, if either deemed necessary or appropriate, placing a legend to such effect on the farm of Note in such form as either deemed necessary or appropriate. 8858C\00001V"7956.3 1 9.03 RESOLUTION NO. 94-13 RESOLUTION OF THE BOARD OF EDUCATION OF BUTTE COUNTY OFFICE OF EDUCATION AUTHORIZING THE ISSUANCE OF 1994 TAX AND REVENUE ANTICIPATION NOTES FOR SAID OFFICE AND REQUESTING THE BOARD OF SUPERVISORS OF THE COUNTY OF BUTTE TO ISSUE SAID NOTES WHEREAS, pursuant to Sections 53850 at et sue. of the Government Code of the State of California (the "Act") contained in Article 7.6 thereof, entitled "Temporary Borrowing", on or after the first day of any fiscal year (being July l}, the Butte County Office of Education (the "Office") may borrow money by issuing notes for any purpose for which the Office is authorized to expend moneys, including but not limited to current expenses, capital expenditures, and the discharge of any obligation ar indebtedness of the Office; and WHEREAS, Section 53853 of the Act provides that such notes must be issued in the name of the Office by the Board of Supervisors of the county (the "County Board"), the County Superintendent of which has jurisdiction over the Office, as soon as possible following the receipt of a resolution of the governing baard of the Office requesting the borrowing; and WHEREAS, the County Superintendent of the County of Butte (the "County") has jurisdiction over the Office, and this Board of Education (the "Office Board"), being the governing board of the Office, hereby requests the borrowing of not to exceed Ten Million Dollars ($10,000,000) at an interest rate not to exceed five percent (50) per annum through the issue by the County Board of 1994 Tax and Revenue Anticipation Notes (the "Notes") in the name of the Office; and WHEREAS, such Notes are payable twelve months after their date of delivery which is during the fiscal year succeeding the fiscal year 1993-1994 in which such Notes were issued, but as required by Section 53854 of the Act, such date is not later than fifteen months after the date of issue, and such Notes shall be payable only from revenue received or accrued during the fiscal year 1993- 1994 in which issued; and WHEREAS, pursuant to Section 53856 of the Act, the Office may pledge any taxes, income, revenue, cash receipts or other moneys deposited in inactive or term deposits (but excepting certain moneys encumbered for a special purpose); and this Resolution specifies that certain unrestricted revenues which will be received by the Office for the General Fund of the Office during or allocable to fiscal year 1993-1994 are pledged for the payment of the Notes; and 88580'V000Oi\7967,? 9.Q3a WHEREAS, the Notes shall be a general obligation of the Office, and to the extent not paid from the taxes, income, revenue, cash receipts and other moneys of the Office pledged for the payment thereof shall be paid with interest thereon from any other moneys of the Office lawfully available therefor, as required by Section 53857 of the Act; and WHEREAS, the Notes shall be in denominations of $1,000 or integral multiples thereof, as permitted by Section 53854 of the Act; shall be issued on a date to be designated and shall be in the form and executed in the manner prescribed in this Resolution, all as permitted and required by Section 53853 of the Act; and WHEREAS, the Office Board has found and determined that said $10,000,000 maximum principal amount of Notes to be issued by the Caunty Baard in fiscal year 1993-1994, when added to the interest payable thereon, does not exceed eighty-five percent (850) of the estimated amount of the uncollected taxes, income, revenue (including but not limited to revenue from state and federal governments}, cash receipts and other moneys of the Office which will be available for the payment of the Nates and interest thereon, as required by Section 53858 of the Act; and WHEREAS, the Notes will not be outstanding after a period ending twelve months after the date on which such Notes are issued and will not be issued in an amount greater than the maximum anticipated cumulative cash flow deficit to be financed by the anticipated tax or other revenue sources for the period for which such taxes or other revenues are anticipated and during which such notes are outstanding, all as provided in Section 1.103-14 (c) of the Income Tax Regulations of the United States Treasury; and WHEREAS, pursuant to Section 265 (b) (3) of the Internal Revenue Code of 1986, as amended (the "Code"), under certain circumstances, certain obligations the interest on which is exempt from federal income tax under Section 103 of the Code may be designated by the issuer thereof as "qualified tax-exempt obligations," thereby allowing certain financial institutions that are holders of such qualified tax-exempt obligations to deduct for federal income tax purposes a portion of such institution`s interest expense that is allocable to such qualified tax-exempt obligations, all as determined in accordance with Sections 265 and 291 of the Code; and WHEREAS, the Office Board hereby represents that: (1) the Notes authorized by this Resolution are not private activity bonds within the meaning of Section 141 of the Code; (2) the Office, together with all of its subordinate entities, has not heretofore issued any obligations (other than those obligations described in Paragraph (4} below} in calendar year 1994 the interest on which is exempt from federal income tax under Section 103 of the Code; 88580\00001\7967.3 2 9.03b {3) the Office reasonably anticipates that it, together with its subordinate entities, will issue during the remainder of calendar year 1994 obligations (other than those obligations described in Paragraph (4) below) the interest on which is exempt from federal income tax under Section 103 of the Code which, when aggregated with all obligations described in Paragraph (2) above, will not exceed an aggregate principal amount of $10,000,000; and {4) notwithstanding Paragraphs {2) and (3} above, the Office and its subordinate entities may have issued in calendar year 1994 and may continue to issue during the remainder of calendar year 1994 private activity bonds other than qualified 501 (c) {3) bonds as defined in Section 145 of the Code; and WHEREAS, the Office Board wishes to designate the Notes as "qualified tax-exempt obligations" within the meaning of Section 265 (b) (3) of the Code; and WHEREAS, certain school districts within the County (the "Districts") have requested loans from the Office through the issue by the County Board of the Notes and the Office desires to make such loans to the Districts so long as the loans are evidenced by the delivery of notes of each District (the "District Notes"), each in an amount equal to the amount of the respective loan; NOW, THEREFORE, the Board of Education of Butte County Office of Education hereby resolves as follows: Section 1. Authorization of Issuance of Notes and of Loans; Terms Thereof; Payinq Agent. The Office Board hereby requests the County Board to issue in the name of the Office, an amount nat to exceed Ten Million Dollars ($10,000,000} principal amount of Notes under Section 53850 et sew. of the Act, designated Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes" {the "Notes"); to be numbered from 1 (and consecutively upward in order of issuance if more than one Note is registered); to be in the denominations of $1,000, or integral multiples thereof, as determined by the purchaser thereof; to be dated the date of delivery thereof; to mature {without option of prior redemption) 360 days computed on a 30-day monthj360-day year basis, or if such date is not a day on which banks in New York or California are open for business, on the last day prior to such date; and to bear interest, payable at maturity and computed on a 30-day monthJ360-day year basis, at the rate or rates determined at the time of sale thereof, but not in excess of five percent (5%) per annum. Both the principal of and interest on the Notes shall be payable, only upon surrender thereof, in lawful money of the United States of America at the principal office of the Treasurer and Tax Collector of the County, which is hereby designated to be the paying agent on the Notes (in such capacity, the "Paying Agent") or such other paying agent as the County may designate. This Board hereby approves the payment of the reasonable fees and expenses of the Paying Agent as they shall became due and payable. easao\oooci\~~E,~..3 3 9.03c The Office Board hereby authorizes loans to be made to the Districts from the proceeds of the Notes, provided that such loan shall be repayable at a rate of interest, computed on a 30-day month/360-day year basis, at the rate to be borne by the Notes, and as otherwise provided in the resolutions of the Districts authorizing such loans (the "District Resolutions"). Section 2. Form of Notes. The Notes shall be issued in registered form 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. The Notes shall be initially registered in the name of "Cede & Co." as nominee of The Depository Trust Company, and shall be evidenced by one note in the full principal amount of the Notes. The Depositary Trust Company, New York, New York is hereby appointed depositary for the Notes. Registered ownership may not thereafter be transferred except as set forth in Section 4 hereof. There shall be printed on the reverse of each Note, the legal opinion of Brown & Wood respecting the validity of said Notes and, immediately following such legal opinion, a certificate executed with the facsimile signature of the Chair of the County Board (the "County Chair"), said certificate to be in substantially the following form: I HEREBY CERTIFY that the foregoing is a true and correct copy of the legal opinion regarding the Notes therein described that was manually signed by Brown & Wood, and was dated as of the date of delivery of and payment for said Notes. Facsimile Signature Chair of the Board of Supervisors Section 3. Deposit of Nate Proceeds; No Arbitrage. The moneys so borrowed initially shall be deposited in the General Fund of the Office and subsequently credited in the amount of the respective loans concurrently with the delivery of the District Notes, first, in the amounts which the Districts and the Office shall direct the Treasurer to deposit, to the respective accounts in the Repayment Fund (as hereinafter defined}, as sufficient for the payment of interest due on the District Notes at maturity, and, second, in the remaining amount, to the respective general funds of the Districts. The Office hereby covenants that it will make no use of the proceeds of the Notes that would cause the Notes to be "arbitrage bonds" under Section 148 of the Code; and, to that end, so long as any of the Notes are outstanding, the Office, and all of its officers having custody or control of such proceeds, shall comply with all requirements of said section, including restrictions an the use and investment of proceeds of the Notes .and the rebate of a portion of investment earnings on certain amounts, including proceeds of the Notes, if required, to the Federal 88580\OOCO1\7967.3 4 9.03d government, and of the Income Tax Regulations of the United States Treasury promulgated thereunder or under any predecessor provisions, to the extent that such regulations are, at the time, applicable and in effect, so that the Notes will not be "arbitrage bonds." Section 4. Payment of Notes. (A) Source of Payment. The principal amount of the Notes, together with the interest thereon, shall be payable from taxes, income, revenue, cash receipts and other moneys (including the deposits to the Repayment Fund described in Section 3 hereof) which are received by the Office during fiscal year 1993-1994 and which are available therefor. The Nates shall be a general obligation of the Office, and to the extent the Notes are not paid from the Pledged Revenues defined below, the Notes shall be paid with interest thereon from any other moneys of the Office lawfully available therefor, as provided herein and by law. (B} Pledged Revenues. As security for the payment of the principal of and interest on the Notes, the Office hereby pledges an amount equal to seventy-five percent (750) of the principal amount of the Notes from the unrestricted revenues received by the Office in or attributable to the month ending May 31, 19 94 , plus an amount equal to twenty-five percent (250) of the principal amount of the Notes from the unrestricted revenues received by the Office in or attributable to the month ending June 30, 1994, plus an amount sufficient to pay at maturity interest an the Notes from deposits in the Repayment Fund (as hereinafter defined) pursuant to Section 3 hereof (such pledged amounts being hereinafter called the "Pledged Revenues"), unless otherwise provided in the resolution of the County authorizing the issuance of the Notes (the "County Resolution"} May 31, 1994 and June 30, 1994 shall constitute the "deposit dates" referred to in Section 4(B} of each of the District Resolutions. The term "unrestricted revenues" shall mean taxes, income, revenue, cash receipts, and other money of the Office as provided in Section 53856 of the Act, which are intended as receipts for the General Fund of the Office and which are generally available for the payment of current expenses and other obligations of the Office. The term "unrestricted revenues" shall include (but shall not be limited to) those amounts paid by the Districts under the District Notes. The principal of the Notes and the interest thereon shall be a first lien and charge against and shall be payable from the first moneys received by the Office from such Pledged Revenues, as provided by law. In the event that there are insufficient unrestricted revenues received by the Office to permit the deposit into the Repayment Fund, as hereinafter defined, of the full amount of Pledged Revenues to be deposited from unrestricted revenues in a month, then the amount of any deficiency shall be satisfied and made up 88580\000017967.3 5 9.03e from any other moneys of the office lawfully available for the repayment of the Notes and the interest thereon. (C) Covenant Regarding Additional Short-Term Borrowing. The Office hereby covenants and warrants that it will not request the County Treasurer and Tax Collector (the "Treasurer") to make temporary transfers of funds in the custody of the Treasurer to meet any obligations of the Office during the 1993-1994 fiscal year pursuant to the authority of Article XVI, Section 6 of the Constitution of the State of California or any other legal authority. (D) Deposit of Pledged Revenues in Repayment Fund. The Office acknowledges that, as the Pledged Revenues are received by the County on behalf of the Office, they shall be deposited directly with and held by the Treasurer in the appropriate accounts in a special fund designated as the Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes Repayment Fund" (the "Repayment Fund") and shall not be available to the Office. Any moneys placed in the Repayment Fund 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 Fund shall be applied only for the purposes for which the Repayment Fund is created. (E) Disbursement and Investment of Moneys in Repayment Fund. After such date as the amount of Pledged Revenues deposited in the Repayment Fund shall be sufficient to pay in full the principal of and interest on the Notes, when due, any moneys in excess of such amount remaining in or accruing to the Repayment Fund shall be transferred to the General Fund of the Office upon the request of the Office. The Office hereby covenants to return to the respective District any amount received by the Office which represents any portion of a deposit made by the District described in Section 3 hereof or the investment earnings thereon. On the maturity date of the Notes, the moneys in the Repayment Fund shall be used, to the extent necessary, to pay the principal of and interest on the Notes. Moneys in the Repayment Fund, to the greatest extent possible, shall be invested at the request of the Office in investment securities by the Treasurer, as permitted by applicable California law, as it is naw in effect and as it may be amended, modified or supplemented from time to time; provided that no such investments shall have a maturity date later than the maturity date of the Notes. Section 5. Execution of Notes. The Office hereby requests the County Chair, or a designated deputy thereof, to sign the Notes manually or by facsimile signature, the Treasurer to sign the Notes manually or by facsimile signature, and the Clerk of the County 88580\00001\7967,3 6 9.03f Board {the "Clerk") to countersign the Notes manually or by facsimile signature {provided that at least one of the foregoing shall sign manually); the Clerk to affix the seal of the County thereto by facsimile impression thereof; and said officers to cause the blank spaces thereof to be filled in as may be appropriate. Section 6. Sale of the Notes. The Notes will be sold on a negotiated basis or at a public sale, as provided in the County Resolution; provided that the aggregate principal amount of the Notes does not exceed Ten Million Dollars ($10,000,000) and the interest rate does not exceed five percent (50} per annum. In the event the Notes shall be sold on a negotiated basis, the Office shall request the Treasurer to execute a Contract of Purchase substantially in the form approved by the County Board in the County Resolution with an underwriter to be designated by either the Superintendent or a designee of the Office. In the event the Notes are sold at a public sale, the Notes shall be sold at the time and place and upon the terms provided in the County Resolution. Section 7. Appointment of Bond Counsel; Authorization of Preliminary Official Statement and Official Statement. Brown & Wood is hereby designated as the bond counsel to the Office in connection with the issuance of the Notes. Government Financial Strategies, Inc., the financial advisor to the Office, is hereby authorized to prepare a Preliminary Official Statement and an Official Statement relating to the Notes, to be used in connection with the offering and sale of the Notes. The Superintendent and any Assistant Superintendent of the Office are each hereby authorized and requested to execute and deliver the Official Statement. Section 8. Delivery of Notes. The proper officers of the Caunty Board are hereby requested to deliver the Notes to the successful bidder or purchaser thereof. All actions heretofore taken by the officers and agents of the Office Board with respect to the Notes are hereby approved, confirmed and ratified, and the officers of the Office Board are hereby authorized and directed to do any and all things and take any and all actions which they, or any of them, may deem necessary or advisable in order to consummate the lawful issuance and delivery of the Notes in accordance with this Resolution and resolution hereafter adopted by the County Board. Section 9. Further Actions Authorized. It is hereby covenanted that the Office Board, 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 levy, collection and enforcement of the secured property taxes pledged under this Resolution in accordance with the law and for carrying out the provisions of this Resolution. 88580\6G001\7967.3 9.038 Section 10. Recitals. All the recitals in above are determines true and correct and this Office and represents. this Resolution Board so finds, Section 11. Designation as Qualified Tax-Exempt Obligation. The Office Board hereby designates the Notes as "qualified tax- exempt obligations" within the meaning of Section 265(b)(3) of the Code. Section 12. Action Re Qualified Tax-Exempt Obligation. Appropriate officials of the Office are hereby authorized and directed to take such other actions as may be necessary to designate such Notes as "qualified tax-exempt obligations," including, if either deemed necessary or appropriate, placing a legend to such effect on the form of Note in such form as either deemed necessary or appropriate. Section 13. Transmittal of Resolution. The Clerk of this Board is hereby directed t Resolution to the County Board and the County Superintendent o send a certified copy of this of Supervisors, the County Treasurer of Schools. 88580\00001\7967.3 g 9.03h PASSED AND ADOPTED by the Board of Education of Butte County Office of Education this 22nd day of February, 1994, by the following vote: AYES : G ~+4 -U ~ n~ ~ v x~-s s ~ +~ , N-o w ~e `r-7-~ 3 2~ ~ ~ ~} ~ ~ , ~ ~ 2 v u r ~ u S, L.. ~ ~ ~ s e y NOES : 1~10N~ Attest: r ~` ~ ; ;. C:I e rk ~'B cn'a r`d' ~o~'~ E clu c a~`i~exi Butt, County Office of Education president, Board of Education Butte County Office of Education 88580100~fl1\7U5'7.3 9 9.03i EXHIBIT A BUTTE COUNTY OFFICE OF EDUCATION COUNTY OF BUTTE STATE OF CALIFORNIA 1994 TAX AND REVENUE ANTICIPATION NOTE Registered No. Registered Owner: CEDE & CO. FOR VALUE RECEIVED, Butte County Office of Education (the "Office"}, County of Butte, State of California, acknowledges itself indebted to and promises to pay the Registered Owner hereof, at the office of the Treasurer of the County of Butte the principal sum of DOLLARS ($ in lawful money of the United States of America, on March 1995, together with interest thereon at the rate of PERCENT ( o } per annum in like lawful money of the United States of America 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 to properly 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 Dollars ($ }, all of like date, tenor and effect, made, executed and given pursuant to and by authority of a resolution of the Board of Supervisors of the County of Butte duly passed and adopted on March 8, 1994 and a Resolution of the Board of Education of the Office duly passed and adopted on February 22, 1994 under and by authority of Article 7.6 (commencing with Section 53850} of Chapter 4, Part 1, Division 2, Title 5 of the California Government Code, and that all acts, conditions and things required to exist, happen and be performed precedent to and in the issuance of this Note have existed, 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 Office, does not exceed any limit prescribed by the Constitution or statutes of the State of California. 88580~'J0001\7967.3 A - I 4.a3~ The principal amount of the Notes, together with the interest thereon, shall be payable from taxes, income, revenue, cash receipts and other moneys that are received by the Office during fiscal year 1993-1994. As security for the payment of the principal of and interest on the Notes the Office has pledged an amount equal to seventy-five percent t75o) of the principal amount of the Notes from the unrestricted revenues received by the Office in ar attributable to the month ending May 31, 1994; and an amount equal to twenty-five percent (25%) of the principal amount of the Notes from the unrestricted revenues received by the Office in or attributable to the month ending June 30, 1994; plus an amount which will be sufficient to pay interest on the Notes at maturity from certain deposits made from proceeds of the Notes, as further described in the above-described resolutions (such pledged amounts being hereinafter called the "Pledged Revenues"); and 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, and to the extent not so paid shall be paid from any other moneys of the Office lawfully available therefor. IN WITNESS WHEREOF, the County of Butte has caused this Nate to be executed by the Chair of its Board of Supervisars by facsimile signature and by the Treasurer and Tax Collector by manual signature and countersigned by the Clerk of the Board of Supervisors by facsimile signature and has caused a facsimile of its official seal to be printed hereon this day of 1994. COUNTY OF BUTTE By Chair, Board of Supervisors By (SEAL) Countersigned By Clerk, Board of Supervisors Treasurer and Tax Collector aasao~ooooi~~9~7.i A - 2 9.03k QUALIFIED TAX-EXEMPT OBLIGATION This Note has been determined to be a "qualified tax-exempt obligation" within the meaning of Section 265(b){3) of the Internal Revenue Cade of 1986, as amended, by resolution of the Office. ri85H0\OO~C 1\7967.3 A-? EXHIBIT C OFFICIAL NOTICE OF SALE BUTTE COUNTY OFFICE OF EDUCATION COUNTY OF BUTTE, STATE OF CALIFORNIA 1994 TAX AND REVENUE ANTICIPATION NOTES (Bank Qualified) NOTICE IS HEREBY GIVEN that separate sealed proposals as well as telecommunicated proposals will be received by the Treasurer and Tax Collector (the "Treasurer") of the County of Butte {the "County"}, at the office of Government Financial Strategies, Inc., 1228 N Street, Suite 13, Sacramento, California 95814, telephone number (916) 444-5100; and facsimile number (916) 444-5109, on Wednesday, March 9, 1994 at the hour of 9:30 A.M., California time {unless prior notice to the contrary is given by the Treasurer, in which case proposals will be received the following Wednesday at the same time and place and each Wednesday thereafter until such time as a bid is awarded or notice to the contrary is given), for the purchase of the 1994 Tax and Revenue Anticipation Notes (individually and collectively, the "Notes"), more particularly described below. ISSUE AND DENOMINATION: The Notes are a separate and distinct issue in the principal follows: amount of $ designated as "Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes". FULL BOOK ENTRY: The Notes, when delivered, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York. The Depository Trust Company ("DTC") will act as securities depository of the Notes. Individual purchases will be made in book-entry form only, in the principal amount of $1,000 and integral multiples thereof. Purchasers will not receive certificates representing their interest in the Notes purchased. DATE AND MATURITIES: The Notes will be dated the date of delivery, and will mature on March 1995. INTEREST RATE: The maximum interest rate bid may not exceed five percent {50) per annum, payable upon maturity of the Notes. Bidders must specify the rate of interest which the Notes bid upon will bear, provided that (i) the Notes bid upon will bear the same eesao\ooooi\~9s~.s C - 1 interest rate; (ii) no Note will bear more than one rate of interest; (iii) the Notes bid upon will bear interest from its date to its stated maturity at the interest rate specified in the bid; and (iv} the interest rate specified must be in a multiple of 1j1000 of one percent {10) Interest will be computed on a 360-day year basis. REDEMPTION: The Notes are not subject to call and redemption prior to maturity. PAYMENT: Both principal and interest are payable in lawful money of the United States of America at the office of the Treasurer and Tax Collector of the County of Butte in Oroville, California, as Paying Agent, to DTC, which will in turn remit such principal and interest to the beneficial owners of the Notes through DTC`s Participants, as described in the Preliminary Official Statement. PURPOSE OF ISSUES: The Notes are a separate and distinct issue to be issued by the Board of Supervisors (the "Board" ) of the County of Butte, in the name and on behalf of the Butte County Office of Education (the "Office"), and the Notes are authorized pursuant to the provisions of Sections 53850-53858 of the Government Code of the State of California and the provisions of a resolution of said Board, for any purpose for which the Office is authorized to expend moneys. SECURITY: The Notes are obligations of the Office on whose behalf such Notes are issued and as security for the payment of the principal of and interest on the Notes, such Office has pledged an amount equal to seventy-five percent (750) of the principal amount of such Office's issue of Notes from the unrestricted revenues received by such Office in the month ending May 31, 1994, and an amount equal to twenty-five percent (254) of the principal amount of such Office's issue of Notes from the unrestricted revenues received by such Office in the month ending June 30, 1994, plus an amount sufficient to pay interest on the Notes at maturity from certain deposits made from proceeds of the Notes. By statute, the Notes of each issue are declared to be a general obligation of the Office an whose behalf such Notes are issued and to the extent not paid from such pledged moneys will be paid with the interest thereon from any other moneys of such Office lawfully available therefor. Under provisions of the California Constitution, each office of education is generally prohibited from incurring any indebtedness or liability exceeding in any year the income and revenue provided for such year, without the assent of two-thirds of its qualified electors voting at an election called for such purpose. aasso\ooooi\~9s6.s C - 2 TERMS OF SALE HIGHEST BID: The Notes will be awarded on the basis of the lowest true interest cost ("True Interest Cast"} including premium offered in the proposals for such issue of Notes. No bid for less than par and accrued interest, if any (which interest will be computed on a 360-day year basis}, will be accepted. In the event two or more bids setting forth identical interest rates and premium per dollar principal amount are received, the County reserves the right to exercise its own discretion and judgment in making the award and may award the Notes an a pro rata basis in such denominations as the Treasurer shall determine. RIGHT OF REJECTION: The County reserves the right, in its discretion, to reject any and all bids and to waive any irregularity or informality in any bid. PROMPT AWARD: The Treasurer, or his authorized designee, will take action awarding the Notes or rejecting all bids for the Notes not later than 26 hours after the expiration of the time herein prescribed for the receipt of proposals unless such time of award is waived by the successful bidder. DELIVERY AND PAYMENT: It is estimated that delivery of the Notes will be made to the successful bidder at The Depository Trust Company, on March 17, 1994 in New York City. Payment of the purchase price must be made in the funds immediately available to the Treasurer. The cost of registering the Notes in the name of Cede & Co., as nominee of DTC, will be borne by the successful bidder. All other costs or fees associated with the sale and delivery of the Notes, including fees charged by CUSIP Service Bureau, CDAC, MSRB and PSA, will be the responsibility of the winning bidder. CALIFORNIA DEBT ADVISORY COMMISSION FEE: Attention of all bidders is directed to California Government Code Section 8856, which provides that the purchaser of the Notes may be charged the California Debt Advisory Commission fee. RIGHT OF CANCELLATION: The successful bidder will have the right at its option to terminate its obligation to purchase Notes if the County fails to execute such Notes on behalf of the Office and tender the same for delivery within 30 days from the date of sale thereof. THE BIDS: Bids for the Notes must be for all of the Notes of such issue, and must be for not less than the par value thereof. Each bid must be either (i) telecommunicated to the financial advisor by the times specified for the receipt of proposals in substantially the form attached hereto, or (ii} enclosed in a sealed envelope addressed to the Treasurer and Tax Collector of the County of Butte at the office of Government Financial Strategies, Inc., 1228 N Street, Suite 13, Sacramento, California 95814, aesac~ooooz~~9s~.a C - 3 telephone number (916) 444-5100; and FAX number (916} 444-5109, not later than 9:30 A.M. California time on said date of sale, and endorsed "Proposal for Butte County Office of Education 1994 Tax and Revenue Anticipation Notes." Each bid must be in accordance with the terms and conditions set forth herein, and must be submitted on, or in substantial accordance with, proposal forms provided by the County. ESTIMATE OF TRUE INTEREST COST: Bidders are requested (but not required} to supply an estimate of the True Interest Cost to the Office on the basis of their respective bids, which shall be considered as informative only and not binding on either the bidder or the Board. BID CHECK: No bid check will be required to bid for the purchase of the Notes. CHANGE IN TAX-EXEMPT STATUS: At any time before the Notes are tendered for delivery, any successful bidder may disaffirm and withdraw its proposal if the interest received by private holders form notes of the same type and character shall be determined to be includable in gross income under present federal income tax laws, either by a ruling of the Internal Revenue Service or by a decision of any federal court, or shall be determined to be includable in gross income by the terms of any federal income tax law enacted subsequent to the date of this notice. CERTIFICATION OF REOFFERING PRICE: The successful bidder shall be required, as a condition to the delivery of the Notes, to certify to the County and the Office in writing, as of the date of award, (i} that the Notes were certified to be reoffered in a bona fide public offering, and (ii} the price at which the Notes were expected to be sold to the public, in form and substance satisfactory to the County, the Office and Bond Counsel. CLOSING PAPERS• LEGAL OPINION: Each proposal will be conditioned upon the Office furnishing to each successful bidder, without charge, concurrently with payment for delivery of the Notes, the following closing papers, each dated the date of such delivery: (a} The opinion of Brown & Wood, San Francisco, California, Bond Counsel, approving the validity of the Notes and stating that under existing statutes, regulations and court decisions, interest on the Notes is exempt from all present State of California personal income taxes and, assuming compliance with certain covenants and requirements, is excludable from gross income for federal income tax purposes (although such interest may be subject to the corporate, alternative minimum and environmental taxes), a copy of which opinion (certified by the official in whose office the original is filed) will be attached to each Note without cost to the purchaser; 8859 C1,00001~7956.3 C - 4 (b} A certificate of the Office that on the basis of the facts, estimates and circumstances in existence an the date of issue, it is not expected that the proceeds of the Notes will be used in a manner that would cause the Notes to be arbitrage bonds; (c} A certificate or opinion of County Counsel that there is no litigation threatened or pending affecting the validity of the Notes; (d} A certificate of an appropriate Office official, acting on behalf of the Office solely in his official, and not in his personal capacity, that at the time of the sale of the Notes and at all times subsequent thereto up to and including the time of the delivery of the Notes to the initial purchasers thereof the Official Statement of the Office pertaining to said Notes did not, and does not, contain any untrue statement of a material fact or omit to state a material fact necessary to make the statement therein, in light of the circumstances under which they were made, not misleading; (e) The signature certificate of the officials of the County, showing that they have signed the Notes and impressed the seal of the Board thereon, and that they were respectively duly authorized to execute the same; and { f ) The receipt of the Treasurer that the purchase price of the Notes, including interest accrued to the date of delivery thereof has been received by him. INFORMATION AVAILABLE: Requests for information concerning the Office should be addressed to: Dick Puel Treasurer County of 25 County Oroville, (916) 538 icher and Tax Collector Butte Center Drive California 95965-3384 -7443 Paul Raineri Government Financial Strategies, Inc. 1228 N Street, Suite 13 Sacramento, California 95814-5609 (916) 444-5100 FAX: (916} 444-5109 The Office will provide the successful bidder such number of printed copies of the Official Statement for this issue as such bidder may request. Up to l0 copies for each $1 million of Notes purchased of the Official Statement will be furnished without cost, 88580\00001\795F.3 C - 5 and any additional copies will be furnished at the expense of the bidder. Dated: 1994 TREASURER AND TAX COZLECTOR OF THE COUNTY OF BUTTE aasao~ooooi\~9s6.3 C - ~ EXHIBIT D NOTICE OF INTENTION TO SELL NOT-TO-EXCEED $10,000,000 BUTTE COUNTY OFFICE OF EDUCATION COUNTY OF BUTTE, STATE OF CALIFORNIA 1994 TAX AND REVENUE ANTICIPATION NOTES {Bank Qualified} NOTICE IS HEREBY GIVEN that the Butte County Office of Education, in Butte County, California (the "County") intends to offer for public sale on Wednesday, March 9, 1994, not to exceed $10,000,000 principal amount of tax and revenue anticipation notes designated "Butte County Office of Education, County of Butte, State of California, 1994 Tax and Revenue Anticipation Notes" {the "Notes"), at 9:30 A.M. Pacific Time at the offices of Government Financial Strategies, Inc., 1228 N Street, Suite 13, Sacramento, California 95814, {916} 444-5100. The Butte County Treasurer and Tax Collector {the "Treasurer") will take action awarding the Notes or rejecting all bids for the Notes not later than 26 hours after the expiration of the time herein prescribed for the receipt of proposals unless such time of award is waived by the successful bidder. If notice to the contrary is given by the Treasurer by such designated time, proposals will be received the following Wednesday at the same time and place and each Wednesday thereafter until such time as a bid is awarded or notice to the contrary is given. NOTICE IS HEREBY FURTHER GIVEN that the Nates, dated March 17, 1994, are offered for public sale, subject to the terms and conditions of the Official Notice of Sale for the Notes. An Official Statement relating to the Notes will be furnished upon request directed to Government Financial Strategies, Inc., the financial advisor to the Butte County Office of Education for the Notes, at the above address. Dated: 1994 By: Treasurer of and Tax Collector Butte County 88580\00001\7956.3 D - 1 PASSED AND ADOPTED by the Board of Supervisors of the County of Butte this 8th day of March, 1994, by the following vote: AYES: NOES: ABSENT Supervisors Dolan, Houx, Thomas and Chair McLauKhlin None SupervisUr Meyer By 4 ~ -~~~.;-c, ~, Y, Chair, Board of pervisors ~i};~i ~ ~~ 1~~~ Attest: (, f~ !` ,,. . .Clerk, Board of Supervisors 88580~00001~7956.3 ~ 1