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HomeMy WebLinkAbout52-85 RESOLUTION454. RESOLUTION NO. 52-85 SCANNED -I' A RESOLUTION AUTHORIZING THE MAYOR AND CITY CTPRK TO EXECUTE A CONTRACT WITH A.G. EEWARDS & SONS, INC. TO PROVIDE MANAGING UNDERWRITERS SERVICES ON THE CITY'S $19,000,000 SALES AND USE TAX CAPITAL IMPROVEMENT BONDS FOR WASTEWATER TREATMENT SYSTEM IMPROVEMENTS. BE IT RESOLVED BY ME BOARD OF DIRECTOFS OF THE CITY OF FAYETTEVILLE, ARKANSAS: That the Mayor and City Clerk are hereby authorized and directed to execute a contract with A.G. Edwards & Sons, Inc. to provide managing underwriters services on the City's $19,000,000 Sales and Use Tax Capital Improvement Bonds for Wastewater Treatment System improvements. A copy of the contract authorized for execution hereby is attached hereto marked Exhibit "PL" and made a part hereof. PASSED AND APPROVED this 4th day of June APPR7Eti: BYL.Yd--Z61 Mayor , 1985. • McIlroy Bank & Trust (the "Trustee"). The Bonds are to be $21,725,000 City of Fayetteville, Arkansas Sales and Use Tax Capital Improvement Bonds $10,000,000 1985 Series A Subordinated Sales and Use Tax Capital Improvement Bonds $11,725,000 1985 Series B July 18, 1985 4 - BOND PURCHASE AGREEMENT On the basis of the representations, warranties and agreements and upon the terms and conditions contained herein, the undersigned, A. G. Edwards & Sons, Inc. (the "Underwriter"), hereby offers to purchase $21,680,000 aggre- gate principal amount of $10,000,000 Sales and Use Tax .:Capital Improvement Bonds, 1985 Series A (the "Series A Bonds") and $11,725,000 Subordinated Sales and Use Tax Capital Improvement Bonds, 1985 Series B (the "Series B Bonds") (collectively, the Series A Bonds and the Series B ,Bonds shall be referred to as the "Bonds") to be issued by the City of Fayetteville, Arkansas (the "City"), a political Subdivision organized and existing under the laws of the State of Arkansas, under and pursuant to Ordinances adopted by the City on February 5, 1985 and July 18, 1985 (collec- tively, the "Ordinance") and a Trust Indenture, dated as of August 15, 1985 (the "Trust Indenture"), between the City and r ;1 issued by the City pursuant to and in accordance with the provisions of Amendment No. 62 to the Constitution of the state of Arkansas, as implemented by Act No. 871 of the General Assembly of Arkansas for the year 1985 (the "Act"). The Bonds will constitute special obligations of the City, payable as to principal and interest from the amounts received by the City from its one percent (1%) sales and use tax (the "Pledged Revenues"). The Ordinance irrevocably pledges such Pledged Revenues to the payment of the principal of and interest on the Bonds. The Bonds do not constitute an indebtedness of the City within the meaning of any constitu- tional or statutory limitation. The proceeds from the sale of the Bonds are to be used to provide funds to pay a portion of the cost of acquiring, constructing and equipping addi- tions and improvements to the City's wastewater collection and treatment facilities. SECTION 1. REPRESENTATIONS, WARRANTIES, COVENANTS AND AGREEMENTS. By execution hereof, the City hereby represents to, and agrees with, the Underwriter that: (a) The City is a political subdivision, duly organized and existing under the Constitution and laws of the State of Arkansas. The City is authorized by the provisions of the Act and the Ordinance to issue, sell and deliver the Bonds for the purposes specified above, -2- adopt and perform its obligations under the Ordi- ance, the Trust Indenture and this Bond Purchase greement (this "Agreement") and to irrevocably pledge he Pledged Revenues to the payment of the principal of nd interest on the Bonds. (b) The City has full power and authority to =summate all transactions contemplated by this Agree- ent, the Bonds, the Ordinance, the Trust Indenture and ny and all other agreements relating thereto to which he City is a party. (c) The City has duly authorized all action neces- ary under the Act or otherwise to be taken by it or on ts behalf for: (i) the issuance and delivery of the onds upon the terms set forth in the Act, the Ordi- ance, the Trust Indenture, this Agreement and the fficial Statement (as hereinafter defined); (ii) the lcecution and delivery by it of the Trust Indenture and his Agreement; (iii) the pledge 'of the Pledged Reve- mes; and (iv) the adoption of the Ordinance and the lerformance of its duties thereunder. (d) There is no action, suit, proceeding, inquiry )r investigation at law or in equity or before or by any :ourt, public board or body pending or, to the knowledge )f the City, threatened against or affecting it (or, to -3- its knowledge, any basis therefor) wherein an unfavor- able decision, ruling or finding would adversely affect the transactions contemplated by this Agreement or would adversely affect the validity of the Bonds, the Ordi- nance, the Trust Indenture, this Agreement or any agreement or instrument to which the City is a party and which is used or contemplated for use in the consumma- tion of the transactions contemplated hereby. (e) The financial statements of the City referred to and contained in Appendix A to the Preliminary Official Statement dated July 9, 1985, and the final Official Statement, dated July 18, 1985 (the Preliminary Official Statement, the final Official Statement, the Appendices thereto and any and all supplements and amendments thereto are hereinafter referred to collec- tively as the "Official Statement"), present fairly the financial position of the City as of the dates indicated therein and the results of operations for the periods specified therein, and the financial statements therein have been prepared in conformity with generally accepted accounting principles consistently applied, except as may be noted in said Official Statement, in all material respects with respect to the periods involved. -4- (f) The descriptions and information contained in the Official Statement relating to the City, its organ- ization, properties, operations and financial condition and the descriptions of the Bonds, the Ordinance, the Trust Indenture and the Pledged Revenues are, and at the Closing Date (as defined in this Agreement and used hereinafter) will be true and do not contain, and at the Closing Date will not contain, any untrue statement of a material fact or omit to state a material fact necessary in order to make the statements made therein, in light of the circumstances under which they were made, not misleading. (g) Since December 31, 1984, there has not been any material adverse change in the properties, financial position or results of operations of the City, whether or not arising from transactions arising in the ordinary course of business, other than any such changes which are disclosed in the Official Statement and since such date the City has not entered into any transaction or incurred any liability material as to the City, except as disclosed in the Official Statement. (h) The City will not take, or omit to take, any action which will in any way result in the proceeds from the sale of the Bonds being applied in a manner incon- sistent with the provisions of the Ordinance. -5- (i) The Bonds, when executed and delivered by the City, will constitute special obligations of the City enforceable in accordance with their respective terms, except to the extent that enforcement thereof may be limited by bankruptcy, insolvency or other similar laws affecting creditors' rights generally. (3) The Ordinance, the Trust Indenture Agreement, when executed and delivered by the be the legal, valid and binding obligation of and this City, will the City enforceable in accordance with their respective terms, except to the extent that enforcement thereof may be limited by bankruptcy, insolvency or other similar laws affecting creditors' rights generally. (k) The execution and delivery of the Bonds, the Trust Indenture and this Agreement, and the adoption of [the Ordinance, and the performance by the City of its obligations under the aforementioned, do not and will :.not violate the Act or any court'order by which the City is bound, and such actions do not and will not consti- tute a default under any existing resoluion, agreement, indenture, mortgage, lease, note or other obligation or instrument to which the City is a party, and no approval or other action by any governmental authority or agency is required in connection therewith. -6- 11 12 13 1 1 (1) The City has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that it is a bond issuer whose arbitrage certifications may not be relied upon. PURCHASE, SALE AND DELIVERY OF THE BONDS. On the basis of, and in reliance upon, the warranties, representations and agreements of the City contained herein in the other documents and agreements referred to herein the terms and conditions herein set and and subject to the Closing Time, the Underwriter agrees to purchase from the 1 City and the City agrees to sell to the Underwriter the Bonds At Sat4aa8/6/2.75 (qS.01% of the principal amount thereof), plus of the Bonds to the date of forth, at (=rued interest from the payment and delivery thereof. The Bonds shall be issued date in the Ordinance and bave the maturities and interest rates and be subject to todemption as set forth in the Trust indenture. Payment for the Bonds shall be made by official bank check or draft, wire transfer or otherwise in funds immediately available payable to the City on the same dal'. at the offices of Rose Law Firm, in Little Rock, the Trust under and secured as provided Indenture and the Bonds shall certified or Arkansas, at 9:00 a.m., on August 22, 1985, or at such place and/or date and hour as shall be mutually agreed between the City and the Underwriter. The date of such other upon 1 ry and payment is herein called the "Closing Date," and ur and date of such delivery and payment is herein the "Closing Time." g 3. CONDITIONS TO THE UNDERWRITER'S OBLIGATIONS. ae Underwriter's obligations hereunder shall be subject due performance by the City of its obligations and flats to be performed hereunder at or prior to the 1 Time and to the accuracy of and compliance with the !ntations and warranties of the City contained herein, :he date hereof and as of the Closing Time, and the 7iter's obligations hereunder are also subject to the .ng conditions: (a) A policy of insurance issued by AMBAC idemnity Corporation, dated the date of Closing, shall me been delivered, which policy shall guarantee tyment when due of principal of and interest on the !ries B Bonds and shall be in substantially the same !rm and substance as that attached as Exhibit A. (b) The City shall have received from Moody's vvestors Service a rating of "A" on the Series A Bonds Id from Standard & Poor's Corporation the rating of AA" on the Series B Bonds and letters evidencing such ttings shall have been delivered to the Underwriter. -8- (c) The Bonds shall have been duly authorized, executed and delivered in the form heretofore approved by the Underwriter with only such changes therein as the Underwriter and the City shall mutually agree upon. (d) At the Closing Time, the Underwriter shall receive: (1) The opinions dated as of the Closing Date of (A) General Counsel to AMBAC Indemnity Corpora- tion, in substantially the form and substance as that attached hereto as Exhibit B; (B) James N. McCord, City Attorney, in substantially the form • and substance as that attached hereto as Exhibit C; (C) Rose Law Firm, a Professional Association, Bond Counsel, in substantially the form and substance as that attached hereto as Exhibit D, a supplemental opinion of Bond Counsel in form and substance as that attached hereto as Exhibit E and a no arbi- trage opinion of Bond Counsel in form and substance as that attached hereto as Exhibit F; and (D) Kutak Rock & Campbell, Counsel to the Underwriter, in substantially the form and substance as attached hereto as Exhibit G; (2) A certificate, in form and substance satisfactory to the Underwriter and its counsel, of the Mayor of the City or any duly authorized -9- officer or official of the City satisfactory to the Underwriter and its counsel, dated as of the Clos- ing Date, to the effect that: (i) each of the City's representations contained herein are true and correct as of the Closing Time; (ii) the City has authorized, by all action necessary under the Act, the adoption of the Ordinance and the execu- tion, delivery and due performance of the Boncth, the Trust Indenture, the Agreement and the pledging of the Pledged Revenues; (iii) no litigation is pending, or to his knowledge threatened, to restrain or enjoin the issuance or sale of the Bonds or in any way affecting any authority for or the validity of the Ordinance, the Trust Indenture, this Agreement or the pledge of the Pledged Reve- nues; (iv) the Bonds, as executed by the City, are in the form or in substantially the form approved for such execution by appropriate proceedings of the City; (v) since December 31, 1984 there has not been any material adverse change in the properties, financial position or results of operations of the City, whether or not arising from transactions in the ordinary course of business, other than such changes which are disclosed in the Official State- ment and since such date the City has not entered -10- 11 • ty into any material Official transaction or incurred any liability as to the City except as disclosed in the Statement; (vi) there are not pending or, to his knowledge, threatened legal proceedings which are not disclosed in the Official Statement, and which are material as to the City, or to which the City is a party, or of which property of the City is the subject, or which will adversely affect the transactions contemplated hereby or by the Official Statement; (vii) the information contained in the Official Statement relating to the City, its organization, condition and Ordinance and properties, operations and financial the descriptions of the Bonds, the the Pledged Revenues are true and correct in all material respects and do not contain any untrue or incorrect statement of a material fact and do not omit to state a material fact necessary in order to make the statements made therein, in light of the circumstances under which they were made, not misleading; and (viii) the City has duly authorized by all necessary action the signing of the Official Statement by its Mayor; (3) An arbitrage certificate of the City, in form satisfactory to Bond Counsel, signed by the Mayor and Director of Finance of the City; -11- 11 12 13 14 16 (4) A certificate of AMBAC Indemnity Corporation in substantially the form and substance as that attached hereto as Exhibit.H; (5) A letter dated July 9, 1985 addressed to the City (with copy to the Underwriter) from Arthur Young & Company, independent certified public accountants to the City, consenting to the use of the City's audited financial statements prepared by them and reference to such firm in the Official Statement; and (6) Such additional certificates and other documents as the Underwriter may reasonably request to evidence performance of or compliance with the provisions of this Agreement and the transactions contemplated hereby and by the Official Statement, all such certificates and other documents to be satisfactory in form and substance to the Under- writer and its counsel. • N.4. THE UNDERWRITER'S RIGHT TO CANCEL. he Underwriter shall have the right to cancel its tion to purchase the Bonds hereunder by'notifying the n writing or by telegram of its election to do so n the date hereof and the Closing Time, if at any time ter and prior to the Closing Time: -12- 1! (a) A decision with respect to legislation shall be reached by a committee of the House of Representa- tives or the Senate of the Congress of the United States or legislation shall be favorably reported by such a committee or be introduced, by amendment or otherwise, or be enacted by, the House of Representatives or the Senate, or be recommended to the Congress of the United States for passage by the President of the United States, or a decision by a court established under Article III of the Constitution of the United States, or a decision by the Tax Court of the United States, shall be rendered or a ruling, regulation or order of the Treasury Department of the United States or the Internal Revenue Service shall be made purpose or effect of imposing or any other event shall have or proposed having the federal income taxation, occurred which results in the imposition of federal income taxation, upon revenues or other income of the general character to be derived by the City or upon interest received on obligations of the general character of the Bonds, or the Bonds, which, in the Underwriter's opinion, materially adversely affects the market price of the Bonds; (b) Any legislation, ordinance, rule or regulation shall be introduced in, or be enacted by, any govern- mental body, department or agency in the State of -13- 11 .•f • Arkansas, or a decision by any court of competent jurisdiction within the State of Arkansas shall be rendered which, in the Underwriter's opinion, materially adversely affects the market price of the Bonds; (c) Legislation shall be introduced, by amendment or otherwise, in, or be enacted by the House of Repre- sentatives or the Senate of the Congress of the United States, or a decision by a court of the United States shall be rendered, or a stop order, ruling, regulation or official statement by, or on behalf of, the Securi- ties and Exchange Commission or other governmental agency having jurisdiction of the subject matter shall be made or proposed, to the effect that the issuance, offering or sale of obligations of the general character of the Bonds, or the Bonds as contemplated hereby or by the Official Statement, is or would be in violation of any provision of the Securities Act of 1933, as amended and as then in effect, or the Securities Exchange Act of 1934, as amended and as then in effect, or the Trust Indenture Act of 1939, as amended and as then in effect, or with the purpose or effect of otherwise prohibiting the issuance, offering or sale of obligations of the general character of the Bonds, or the Bonds as contem- plated hereby or by the Official Statement; -14- Col _ • (d) Any event shall have occurred, or information become known, which, in the Underwriter's opinion, makes untrue, incorrect or misleading in any material respect any statement or information contained in the Official Statement (or any Appendices thereto) as originally circulated, or has the effect that the Official State- ment (or any Appendices thereto) as originally circu- lated, contains an untrue, incorrect or misleading statement of a material fact or omits to state a mate- rial fact necessary to be stated therein in order to make the statements made therein, in light of the cir- cumstances under which they were made, not misleading; (e) Additional material restrictions not in force as of the date hereof shall have been imposed upon trading in securities generally by any governmental authority or by any national securities exchange; (f) The New York Stock Exchange or other national securities exchange, or any govefnmental authority, shall impose, as to the Bonds, or obligations of the general character of the Bonds, any material restric- tions not now in force, or increase materially those now in force, with respect to the extension of credit by, or the charge to the net capital requirements of, the Underwriter; -15- • • (g) A general banking moratorium shall have been established by federal or Arkansas authorities; (h) A default shall have occurred with respect to the obligations of, or proceedings have been instituted under, the federal bankruptcy laws or any similar state laws by or against any state of the United States or any city located in the United States having a population in excess of one million persons or any entity issuing obligations on behalf of such a city or state which, in the Underwriter's opinion, materially adversely affects the market price of the Bonds; • (i) Any rating of the Bonds shall have been down- graded or withdrawn by a national rating service; or (3) A war involving the United States shall have been declared, or any conflict involving the armed forces of the United States shall have escalated, or any other national emergency relating to the effective operation of government or the financial community shall have occurred, which, in the Underwriter's opinion, materially adversely affects the market price of the Bonds. ECTION 5. CONDITIONS OF OBLIGATIONS OF THE CITY. The obligations of the City hereunder are subject to the aderwriter's performance of its obligations hereunder, and -16- • 11 •.• 1 12 13 Jim further condition that at the Closing Time the Under- witer shall receive the opinions described in Section 3(d) atreof. SECTION 6. INDEMNIFICATION. To the extent permitted by law, the City agrees to indemnify and hold harmless the Underwriter, any member, )fficer, official or employee of the Underwriter, and each Arson, if any, who controls the Underwriter within the soaning of Section 15 of the Securities Act of 1933, as mended (collectively the "Indemnified Parties"), against any Ind all losses, claims, damages, liabilities or expenses thatsoever caused.by any untrue statement or misleading statement or allegedly misleading statement of a material tact contained in the Official Statement or caused by any Smission or alleged omission from the Official Statement of Any material fact necessary in order to make the statements aade therein, in light of the circumstances under which they were made, not misleading, except insofar as such losses, Claims, damages, liabilities or expenses are caused by any ouch untrue or misleading statement or omission or allegedly untrue or misleading statement or omission in the information contained under the caption "LEGAL MATTERS --Tax Exemption." In case any action shall be brought against one or more Of the Indemnified Parties based upon the Official Statement and n respect of which indemnity may be sought against the -17- • ty, the Indemnified Parties shall promptly notify the City writing, and, to the extent permitted by law, the City all.promptlY assume the defense thereof, including the ployment of counsel, the payment of all expenses and the ght to negotiate and consent to settlement. Any one or re of the Indemnified Parties shall have the right to ploy separate counsel in any such action and to participate the defense thereof, but the fees and expenses of such unsel shall be at the expense of such Indemnfied Party or demnified Parties unless employment of such counsel has en specifically authorized by the City. The City shall not liable for any settlement of any such action effected thout its consent by any of the Indemnified Parties, but if ttled with the consent of the City or if there be a final tgment for the plaintiff in any such action against the ty or any of the Indemnified Parties, with or without the 'arment of the City, the City agrees to indemnify and hold umless the Indemnified Parties to the extent provided in tie Agreement and to the extent permitted =ION 7. REPRESENTATIONS AND AGREEMENTS DELIVERY. ' All representations and agreements of the City shall main operative and in full force and effect, regardless of lY investigations made by or on the Underwriter's behalf, Id shall survive delivery of the Bonds to the Underwriter. by law. TO :SURVIVE -18- • • I 11 1 a i 12 c 13 14 SECTION 8. PAYMENT OF EXPENSES. If the Underwriter accepts delivery of and pays for the lands as set forth herein, all expenses and costs to effect the authorization, preparation, issuance, delivery and sale of the Bonds (including, without limitation, the fees and disbursements of Rose Law Firm, rating agency fees and expenses incurred in connection therewith and the expenses and costs for the preparation, printing, photocopying, exe- eUtion and delivery of the Bonds, the Official Statement, the Ordinance and all other agreements and documents contemplated the proceeds of the Bonds. not accept delivery of and pays hereby) shall be paid out of If the Underwriter does FAS for the Bonds as set forth herein, all effect the authorization, preparation, expenses and costs to issuance, delivery and gale of the Bonds (including, without limitation, the dis- -bursements of Rose Law Firm, rating agency fees and the ',,,)11xpenses and costs for the preparation, printing, photocopy- ing, execution and delivery of the Bodds, the Official State - Plant, the Ordinance and all other agreements and documents contemplated Whether pays for the thereby) shall be paid by the City. or not the Underwriter accepts delivery of and Bonds as set forth herein, the Underwriter shall pay all costs and disbursements incurred by it in connection With the transaction including, without limitation, fees and expenses of counsel for the Underwriter. • :i X11 it SECTION 9• NOTICE. Any notice or other communication to be given to the t. City under this Agreement may be given by mailing or deliv- eying the same in writing to the Director of Finance, City of Fayetteville, City Hall, Fayetteville, Arkansas 72702, Attention: Mr. Scott Linebaugh; and any notice or other communication to be given to the Underwriter under this Agreement may be given by delivering the same in writing to A. G. Edwards & Sons, Inc., Public Finance Department, One North Jefferson, St. Louis, Missouri 63103, Attention: Mr. Charles H. Devers. SECTION 10. APPLICABLE LAW; NONASSIGNABILITY. This Agreement shall be governed by the laws of the State of Arkansas and shall not be assigned by the City. SECTION 11. EXECUTION OF COUNTERPARTS. This Agreement may be executed in several counterparts, Iach of which shall be regarded as an original and all of which shall constitute one and the sathe document. 'SECTION 12. SEVERABILITY. In the event any provision of this Agreement shall be held invalid or unenforceable by any court of competent F -20- a�jurisdiction, such holding shall not invalidate or render ,'unenforceable any other provision hereof. g -J SEAL] : CITY OF FAYETTEVILLE, ARKANSAS ., ;Attest: By tii�!S nn_.n ___' d24I_?4CA, _/ Assistant ayor/ y lerk j, A. G. EDWARDS & SONS, INC. ;4 n 6 [,R By en. r -21- • ._- fl. wisconsln SJ2D1 — Municipal Bond Insurance New York. New York 10004 Policy Number. Premium: AMDAC INDEMNITY CORPORATION (AMBAC) - A Stock Insurance Company tlr payment of the premium and subject to the terms of this Policy hereby agrees to pay to the United Sttes Trust ark, as tutee. or Its successor(th ' "Insurance Trustee" L for the benefit of Bondholders, that portion of the principal r abovedescribed debt obligatians (thy' Scnda'D which shall become Due for Payment but shall be unpaid by reason tM Issuer. a 1 itch payments to the Insurance Trustee within S days following n, Son and surrender to the Insurance Trustee of such unpaid Bonds tiny advent claim. the Insurance Trustee will disburse to the a fat Payment but is unpaid Upon such disbursement, AMBAC I be fully subrogated to all of the Bondholder, rights to n ViA, .:iJ:icLI\L1 of Nonpayment Upon a Boric. Otis, uncanceled and in bearer count of principal and interest of the surrendered Bonds and LWdtknor their assigns. the In. othe Insurance Trustee of rm satisfactory to the In- s to permit ownership.of a form whereby interest Bondholder as aforesaid onh upon ment of interest on the Bond and Insurance Tnntee. duly executed by the AMBAC all rights under such Bond to receive subrogated to all of the Bondholders' rights to hssn I ns pe n o er t t>I,4r who, at the time of Non Ntsinn a '• o C w n Y9r a to the principal of Bonds. rs whrrn the stated maturity date or a Ann d e p 'iCbI a ed si in ad installment has been reached and does not refer to any earlier siam d a for n other than by a lication of dvanc a - tu Bo rettestad sulking fund installments)of int. ac. d, txh. et a to interest on the Bonds, is when the stated date for payment interest M npi ire' me th lure of saver to have provided wffirient funds to the paving agent for pavn+ent it A we Due for Payment Mtc'etabk. o s Policy i not refundable fm any reason. includin does not rn re I t coca of any redemption R payment of the Bonds prior to Oct Of art nor gowp, Prepayment or acceleration premium which at any time may ainst-risk other than Nonpayment. AMBAC has caused than Policy to he affixed with a facsimile of it% ?orporare seal and to be signed by its duty a facsimile to become effective as its original seat and signatures and binding upon AMBAC by virtue of the counter- �n'onzed representative. 0��0 o i a'sEALfl President Ui g0s�'- • fa Secretary Authorized Representative COMPANY OF NEW YORK acknowledges that it has agreed to perform the duties of Insurance Tnastee urt: y .rn EXHIBIT B [AMBAC Letterhead] t .:. ht..: August 22, 1985 i] 'c I s City of Fayetteville • City Hall• AR 72702 Fayetteville, L... nose Law Firm ;z'?120 East Fourth Street 4..: , ";Little Rock, AR 72201 Kutak Rock & Campbell 1650 Farnam Street Omaha, NE 68102 A. G. Edwards & Sons, One North Jefferson St. Louis, MO 63103 $11,725,000 City of Fayetteville, Arkansas Subordinated Sales andBUse Capital Imp onds 1985 series B Inc. „� oentiemen: a requested of the undersigned, This opinion has been g Vice President and AssistWisconsinal stocknsel of insuran eBcompany : Indemnity Corporation, a 41. AMBAC Indemnity"), in connection with the issuanceand th w::delivery by the City of Fayetteville (e "Issuer") '1 $11,725,000 in aggregate principal amount of its Subordinated rovement Bonds, 1985 Series B, Sales and Use Tax Capital Imp „ and the issuance by dated August 15, 1985 (the Bonds"), Ad1SAC Indemnity of a certain Municipal Bond Insurance Policy, effective as of the date hereof (the "Policy"), providing for the payment of that portion of the principal of and interest payment but shall be on the Bonds which shall become due for p Ym Unpaid by reason of nonpayment by the Issuer. In connection with the issuance o£ the Policy, I have examined such statutes, documents and proceedings as I have • Considered necessary or appropriate in the circumstances to tender the following opinion, including, without limiting the generality of the foregoing, certain statements contained in the Official Statement of relating to the Bonds (the dix C, entitled "INSURANCE the Issuer, dated July 18, 1985, "Official Statement") under Appen- ON THE 1985 SERIES B BONDS." In reliance upon the foregoing, I am of the opinion that: 1. AMBAC Indemnity is a stock insurance company duly organized and validly existing under the laws of the State of Wisconsin and is duly qualified to do business in the State of Texas. 2. AMBAC Indemnity has full corporate power and authority to execute and deliver the Policy, and the Policy has been duly authorized, executed and delivered by AMBAC Indemnity and constitutes a legal, valid and binding obligation of AMBAC Indemnity enforceable in accordance with its terms. The execution and delivery by AMBAC Indemnity of the Policy will not, and the consummation of the transactions contemplated thereby and the satisfaction of the terms thereof will not, conflict with or result in a breach of any of the terms, conditions or provisions of the Charter or Bylaws of AMBAC Indemnity, any decree, order, statute, rule or governmental regulation applicable to AMBAC Indemnity or any restriction contained in any contract, agreement or instrument to which AMBAC Indemnity is a party or by which it is bound or constitute a default under any of the foregoing. 3. The Policy guarantees the full and complete payment of the principal of and all interest on the Bonds as such payments shall become due. 4. All proceedings Legally required for the issuance of the Policy have been taken by AMBAC Indem- nity and all licenses, orders, consents or other author- izations or approvals of any governmental boards or bodies legally required for the validity of the Policy have been obtained. S. The statements contained in the Official Statement under Appendix C, entitled "INSURANCE ON THE 1985 SERIES B BONDS," insofar as such statements con- stitute summaries of the matters referred to therein, accurately reflect and fairly present the information purported to be shown and, insofar as such statements purport to describe AMBAC Indemnity, fairly and accurately describe AMBAC Indemnity. B-2 In rendering the opinion hereinabove set forth in para- rraph 2 I wish to advise you that the enforceability (but pt the validity) of the Policy may be limited by any appli- :able bankruptcy, insolvency or other similar law or enact - lent now or hereafter enacted affecting the enforcement of Creditors' rights. Fr, Very truly yours, #E• 13 4 -It I s B-3 f w - 4 EXHIBIT C [Letterhead of Counsel to the City] August 22, 1985 SI .;City of Fayetteville City Hall `.;,.fayetteville, AR 72702 ',A. G. Edwards & Sons, Inc. '`:Otto North Jefferson .Sftt. Louis, MO 63103 $21,725,000 City of Fayetteville, Arkansas Sales and Use Tax Capital Improvement Bonds $10,000,000 1985 Series A Subordinated Sales and Use Tax Capital Improvement Bonds $11,725,000 1985 Series B I am counsel to the City of Fayetteville, Arkansas (the •City") and have acted in that capacity, in connection with tic issuance and sale by the City of its $10,000,000 Sales and Use Tax Capital Improvement Bonds, 1985 Series A and $11,725,000 Subordinated Sales and Use Tax Capital Improve- Slnt Bonds, 1985 Series B (the "Bonds") by the` City, which Bonds are being sold pursuant to a Bond Purchase Agreement fitted July 18, 1985 (the "Bond Purchase Agreement") between A. C. Edwards .& Sons, Inc. (the "Underwriter") and the City. The terms defined in this Bond Purchase Agreement are used in thi$ letter with the meaning assigned to them in the Bond ltttchase Agreement. In this connection, I have reviewed certain documents respect to the Bonds, and such records, certificates and 11 - J her documents as I have considered necessary or appropriate r the purposes of this opinion, including the Ordinances opted by the City on February 5, 1985 and on July 20, 1985 ollectively, the "Ordinance") and the Trust Indenture tween the District and Mcllroy Bank & Trust; and the final 'facial Statement dated July 18, 1985 with respect to the ids and a closing certificate of the District. Based on ,ch review and such other considerations of law and fact as believe to be relevant, I am of the opinion that: 1. The City has been properly formed and is _ K�rf5 "?s ,"° validly existing as a political subdivision of the State of Arkansas with full power and authority to adopt the Ordinance, to execute and deliver the Bonds, the Trust Indenture, the Official Statement and the Bond Purchase Y " Agreement. ke 2. The adoption by the City of the Ordinance, the issuance of the Bonds, the execution and delivery of the Trust Indenture and the Bond Purchase Agreement and the �...,� performance of the City's obligations thereunder do not ,. .� and will not result in a violation of any provision of, y tz or in default under, any other resolution, any agreement . .•o or any other instrument to which the City is a party or y*;w, by which it or its properties are bound. to 3. Except as may be described in the Official Statement, the City is not in violation of any provision of any agreement or other instrument the violation of or default under which would materially and adversely affect the business, properties, assets, liabilities or conditions (financial or other) of the City. 4. Except as may be described in the Official • Statement, there are no legal or' governmental actions, proceedings, inquiries or investigations pending or threatened by governmental authorities or to which the City is a party or of which any property of the City is subject, except as described in the Official Statement, which, if determined adversely, would individually or in the aggregate (i) have a material adverse effect on the financial position or results of operations of the City, (ii) materially and adversely affect the validity or the enforceability of the Bonds, the Trust Indenture or the Bond Purchase Agreement, (iii) otherwise materially or adversely affect the ability of the City to comply with its obligations on the Bonds or under the Ordinance, the Trust Indenture or the Bond Purchase Agreement, or C-2 j materially and adversely affect the transactions con- templated by the Official Statement to be engaged in by the City. 4 5. The aggregate amount which may reasonably be expected to be recovered in litigation pending or .1 threatened against the City, taking into account s: •insurance coverage, is not material. We hereby consent to the references made to us in the ,,Official Statement. Respectfully yours, ill C-3 EXHIBIT D (Letterhead of Rose Law Firm] August 22, 1985 Ncl1roy Bank & Trust, as Trustee Eayetteville, AR G. Edwards & Sons, Inc. One North Jefferson Ct. Louis, MO 63103 k Ladies and Gentlemen: We have examined a certified copy of proceedings City of Fayetteville, Arkansas (the "City") and other cents pertaining to the issuance by the City of its $10.000,000 Sales and Use Tax Capital Improvement Bonds, 1985 Series A (the "Series A Bonds") and its $11,725,000 Subordi- 6ated Sales and Use Tax Capital Improvement Bonds, 1985 Caries B (the "Series B Bonds") (collectively, the "Bonds"). The Bonds are being issued for the purpose of financing the Acquisition, construction and equipping of improvements to the City's wastewater collection and treatment facilities (the "Project"), funding certain reserves, paying the premium for a policy of municipal bond insurance issued by AMBAC Indemnity Corporation (the "Insurance. Policy") and paying 'Costs of issuance. The Bonds are issued under the authority of Amendment 62 to the Constitution of the State of Arkansas, as implemented by Act 871 of the General Assembly of the State of Arkansas for the year 1985 (the "Act"), pursuant to Ordinance Of the City adopted July 18, 1985 and a Trust Indenture dated ASof August 15, 1985 (the "Indenture") between the City and McIlroy Bank & Trust, of Fayetteville, Arkansas, as Trustee .(the "Trustee"). In accordance with the Act, and pursuant to Ordinance No. 3065 adopted February 5, 1985, the City has levied a one percent (1%) local sales and use tax (the "Sales _1") to provide funds for the repayment of the Bonds. of the docu- 2• 4. The Bonds are being issued in fully registered form, in Ldenominations of $5,000 each or any integral multiple thereof. The Bonds are initially dated August 15, 1985 and mature serially on August 15 in each of the years 1986 to 1997, inclusive. Interest is payable on the Bonds from their iodate semiannually on each February 15 and August 15, commenc- ing February 15, 1986, by check or draft mailed by the Trus- tee to the registered owners thereof. The Bonds are subject to redemption prior to maturity as poet forth in the Indenture and the Bonds. The City is authorized to issue additional series of @ales and use tax capital improvement bonds in aggregate principal amount, including the Bonds, not to exceed $28,000,000 upon the terms and conditions set forth in the Indenture. Such additional series of bonds, when and if issued, will be subordinate to the Series A Bonds but will issued on parity with the Series B Bonds and shall be enti- tled to the equal benefit, protection and security of the provisions, covenants and agreements of the Indenture. �,. The Series B Bonds are entitled to the benefits Insurance Policy. As to matters pertaining thereto, 'once is made to such policy, the original of which is at the principal corporate office of the Trustee. Based on the } above, we are of the opinion that: M of the refer - on file 1. The Bonds have been duly authorized and issued by the City and are the valid, binding special obliga- tions of the City in accordance with their terms. 2. The Series A Bonds are, secured by an irrevo- cable pledge of and first lien oft the proceeds of the Sales Tax as provided in the Indenture. The Series B Bonds are secured by an irrevocable pledge of and lien on the proceeds of the Sales Tax, subordinate only to the lien securing the Series A -Bonds, as provided by the Indenture. The Bonds are not secured by a lien on or security interest in the Project or the revenues thereof. 3. The Indenture has been duly executed and delivered by the City to the Trustee and is legally binding and enforceable in accordance with its terms. D-2 4. 4. Interest on the Bonds is not includable in federal gross income and is therefore exempt from federal income taxation under existing laws, regula- tions, judicial decisions and rulings. No opinion is expressed as to the effect of any pending or future federal legislation. 5. The Bonds and interest thereon are exempt from all Arkansas state, county and municipal taxation under existing laws. With regard to matters expressed in this opinion, please advised that the enforceability of rights and remedies h respect to the Bonds may be limited by bankruptcy, atorium, insolvency or other laws affecting creditors' its or remedies heretofore or hereafter enacted and their orcement may also be subject to the exercise of judicial eretion in appropriate cases. Very truly yours, 11 D-3 EXHIBIT E [Letterhead of Rose Law Firm] August 22, 1985 A.O. Edwards & Sons, Inc. One North Jefferson It. Louis, MO 63103 s- �- $21,725,000 City of Fayetteville, Arkansas • Sales and.Use Tax Capital Improvement Bonds $10,000,000 1985 Series A fix4*1; Subordinated Sales and Use Tax Capital Improvement Bonds $11,725,000 1985 Series B . and Gentlemen: I:1a I On the date hereof, we rendered to the City of 11 .60tteville (the "City") an opinion approving the validity 4-) t ty's $10,000,000 Sales and Use Tax Capital Improvement hIn do, 1985 Series A and its $11,725,000 Subordinated Sales 1'AAd Use Tax Capital Improvement Bonds,. 1985 Series B 'ft011ectively, the "Bonds") . You are authorized to rely upon 6ild opinion as if the same were addressed to you. In connection with the issuance of the Bonds, we have dined (a) the Ordinances adopted by the City on • Mary 5, 1985 and July 18, 1985 authorizing the issuance Adtnthe Bonds (collectively, the "Ordinance"), (b) the Trust o dated as of August 15, 1985 (the "Indenture") ten the City and Mcllroy Bank & Trust (the "Trustee"), -_�? executed Bond No. R-1 of said issue of Bonds and (d) such 'lest opinions, documents, certificates and letters as we relevant and necessary in -rendering this opinion. '� prom such examination, we are of the opinion that: Ai (1) the Bonds uirements of the the Indenture is st Indenture Act are not subject to the registration Securities Act of 1933, as amended, exempt from qualification under the of 1939, as amended; and (2) the descriptions contained in the Official tement dated July 18, 1985 relating to the Bonds (the ficial Statement") under the captions "THE BONDS" and CURITY FOR THE BONDS" and in "APPENDIX B" have been pared or reviewed by such counsel and such present a r and accurate summary of such provisions; and the tements of law made in the Official Statement under caption "LEGAL MATTERS --Tax Exemption" have been pared or reviewed by such counsel and are fair and urate descriptions thereof. Very truly yours, E-2 EXHIBIT F [Letterhead of Rose Law Firm] August 22, 1985 NCllroy Bank & Trust, as Trustee Fayetteville, AR A. C. Edwards & Sons, Inc. One North Jefferson St. Louis, MO 63103 $21,725,000 City of Fayetteville, Arkansas } = Sales and Use Tax Capital Improvement Bonds .�4 $10,000,000 1985 Series A Subordinated Sales and Use Tax Capital Improvement Bonds $11,725,000 1985 Series B •.Ldies and Gentlemen: i�yhS:m r�{i.a,zY" '`?.. We have served as Bond Counsel to the City of Fayetteville, Arkansas (the "City") in connection with the hhouance of the referenced bonds (the "Bonds"). In this Connection, we have examined the Arbitrage Certificate OEOcuted by the Mayor and the Director of Finance of the City Of even date (the "Arbitrage Certificate"). r1a (ta Based on our examination of law and overall familiarity !With the transaction, we are of the opinion that the facts, .Sttimates, circumstances and expectations set forth in the Atbitrage Certificate are sufficient to satisfy the criteria :ceder Section 103(c) of the Internal Revenue Code of 1954, as oflded 'tt10 (the CSections land n income tax regulations pursuant thereto, as amended, to apport the conclusion that the Bonds will not be arbitrage within the meaning of Section 103(c) of the Code. No Otters have come to our attention which make unreasonable or ;Aeerrect the representations made in the Arbitrage rificate. Very truly yours, fr Th 121 Jp •e EXHIBIT G (Letterhead of Kutak Rock & Campbell] August 22, 1985 )fP f4V • i 4 A. G. Edwards & Sons, Inc. One North Jefferson Avenue .St. Louis, MO 63103 • $21,725,000 City of Fayetteville, Arkansas • Sales and Use Tax Capital Improvement Bonds $10,000,000 1985 Series A Subordinated Sales and Use Tax Capital ry ` Improvement Bonds ��- $11,725,000 1985 Series B This letter is being delivered to you pursuant to the :"Bond Purchase Agreement dated July 18, 1985 (the. "Bond purchase Agreement") between A. G. Edwards & Sons, Inc. and tha City of Fayetteville (the "City") relating to the leauance and sale by the City of its $10,000,000 Sales and Use Tax Capital Improvement Bonds, 1985 Series A and its *11,725,000 Subordinated Sales and Use Tax Capital Improve - bent Bonds (collectively, the "Bonds"). The terms defined in the Bond Purchase Agreement are used in this letter with the beaning assigned to them in the Bond Purchase Agreement. We have acted as your special.counsel in connection with the issuance and sale of the Bonds to you, and in that Capacity have examined an executed counterpart of the Bond purchase Agreement, the Trust Indenture and the Ordinance. We have also examined the originals or copies, certified or Otherwise identified to our satisfaction, of such other documents, records and other instruments as we have deemed pecessary or advisable for purposes of this letter. In connection with the preparation of the Preliminary Official Statement dated July 9, 1985 and the final Offi- cial Statement dated July 18, 1985 (collectively, the "Official Statement"), we have generally reviewed information furnished to us by, and have participated in conferences with, representatives of the City, its counsel, independent certified public accountants, representatives of Arthur Young & Company, your representatives and Rose Law Firm, Bond Counsel. We have also reviewed other records relating to the authorization, issuance and sale of the Bonds and have relied upon certificates of officials of the City and of public. officials and upon written opinions and letters received from the City, its attorneys and independent certified public accountants. We have considered the information contained in the Official Statement and, based upon our review and discussions and in reliance upon the accuracy of the information con- tained in the aforementioned certificates, written opinions and letters, nothing has come to our attention which leads us to believe that the Official Statement contains any untrue statement of a material fact or omits to state a material fact necessary in order to make the statements made therein, in light of the circumstances under which they were made, not misleading. We express no opinion as to the statements con- tained in. the Official Statement in Appendix B and Appen- dix C, nor do we express an opinion as to the financial statements included as Appendix A to the Official Statement, and we express no opinion as to any other financial or statistical data included in the Official Statement or the Appendices thereto. Further, we are of the opinion that the offer, sale and delivery of the Bonds under the circumstances contemplated do not require registration of the Bonds under the Securities Act of 1933, as amended, and do not require qualification of the Indenture under the Trust Indenture Act of 1939, as amended. Very truly yours, G-2 EXHIBIT H [Letterhead of AMBACI August 22, 1985 City of Fayetteville City Hall Fayetteville, AR 72702 Rose Law Firm, a Professional Association 120 East Fourth Street Little Rock, AR 72201 tt21, 725, 000 City of Fayetteville, Arkansas Sales and Use Tax Capital Improvement Bonds $10,000,000 1985 Series A Subordinated Sales and Use Tax Capital Improvement Bonds $11,725,000 1985 Series B Ladies and Gentlemen: We provide this letter in connection with the issuance by the City of Fayetteville, Arkansas .(the "City") of the above referenced bonds (the "Bonds"). 'As you know, we have issued a policy of municipal bond insurance (the "Bond Insurance") which guarantees the payment of principal of and interest on the 1985 Series B Bonds. We note that the City has levied a one percent (1%) local sales and use tax (the "Sales Tax") to provide funds for the repayment of the Bonds and that the Bonds are subject to redemption on or after August 15, 1990 (the "Call Date") from accumulated surplus Sales Tax receipts. We hereby certify that: (1) We are generally familiar with the facts and circumstances surrounding the issuance of the Bonds. (2) The amount to be maintained in the Series B Account in the Debt Service Reserve Fund created in connection with the issuance of the Bonds is, before August 15, 1994, an amount equal to the annual principal and interest requirements on the Series B Bonds for the succeeding bond year and is, on or after August 15, 1994, an amount equal to the lesser of (i) one million seven hundred fifty-two thousand dollars ($1,752,000) or (ii) average annual principal and interest require- ments on the Series B Bonds for all succeeding bond years (the "Required Level"). (3) The debt service on the Series B Bonds has been scheduled so that expected Sales Tax receipts, assuming no growth in collections, will generally equal 120% of debt service on the Bonds during each year. (4) We have required funding of the Series A Account in the Debt Service Reserve Fund to the Required Level. In addition, we have required that expected Sales Tax receipts, assuming no growth in collections, be equal to at least 1.2 times debt service on the Bonds. These requirements are based upon similar special tax bond issues that have been sold within the last year, past tax collection experience by the City, and our internal requirements for acceptable coverage and reserve requirements. (5) Based upon these considerations, it is our opinion that the amount to be maintained in the Series A Account in the Debt Service Reserve Fund is reasonably required. It is our further opinion that the City has scheduled as much debt service on the Bonds as is practicable prior to the Call Date. (6) Defined terms used herein have the meanings ascribed in the Indenture or Official Statement prepared for use in connection with the issuance of the Bonds, as applicable. Very truly yours., AMBAC INDEMNITY CORPORATION By Authorized Signature H-2