HomeMy WebLinkAbout08-127 - Seattle Northwest Securities - 1999 Bonds Refund SEATTLE- NORTTFWEST
SECURITIES CORPORATION 08 -127
Council Approval 12/01/08
December 1, 2008
City of Tukwila
6200 Southcenter Boulevard
Tukwila, Washington 98188
Re: City of Tukwila, Washington
$6,180,000 Limited Tax General Obligation Refunding Bonds, 2008
Honorable Mayor and City Council:
Seattle- Northwest Securities Corporation (the "Underwriter offers to enter into this purchase agreement
(the "Purchase Agreement with the City of Tukwila, Washington (the "Issuer Each of the
Underwriter and the Issuer may be referred to herein as a "Party" or collectively as the "Parties."
This offer is contingent upon acceptance by the Issuer by execution and delivery of this Purchase
Agreement to the Underwriter at or prior to 11:59 p.m. Pacific Time on the date hereof, by means of hand
delivery, facsimile or other secure electronic transmission, such as a PDF file. Upon execution of this
Purchase Agreement by the Parties, this Purchase Agreement will constitute a binding agreement
between the Issuer and the Underwriter.
Capitalized terms in this Purchase Agreement that are not otherwise defined herein shall have the
meanings given to such terms in the Ordinance as defined below:
1. Authorization and Documents
The issuance, sale and delivery of the Bonds (as defined below) shall be authorized by Ordinance
No. 2216 (the "Ordinance adopted by the Mayor and City Council of the Issuer on December 1,
2008. The transaction at which the Bonds are delivered by the Issuer to the Underwriter and paid
for by the Underwriter is referred to herein as the "Closing" and the date of such transaction, the
"Closing Date."
The Ordinance includes an undertaking to provide certain information to DisclosureUSA (so long
as such method of disclosure continues to be approved by the Securities and Exchange
Commission (the "SEC') for such purposes) or to nationally recognized municipal securities
information repositories and regulatory bodies or their designees. The Ordinance and this
Purchase Agreement are collectively referred to herein as the "Documents."
2. Purchase and Sale
Subject to the terms and conditions of this Purchase Agreement, the Underwriter hereby agrees
to purchase from the Issuer for offering to the public and the Issuer hereby agrees to sell to the
Underwriter all, but not less than all of the $6,180,000 aggregate principal amount of Limited Tax
General Obligation Refunding Bonds, 2008 (the 'Bonds The Bonds shall be dated, shall
1420 Fifth Avenue, Suite 4300 Seattle, WA 98101 (206) 628 -2882 1 www.seattlenorthwestcom
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Honorable Mayor and City CCoffilal
City of Tukwila, Washington
December 1, 2008
Page 2
mature, shall bear interest, shall be payable, and shall have redemption provisions, all as set forth
in Exhibit C attached hereto. The Underwriter's purchase price for the Bonds also is set forth in
Exhibit C.
3. Fiscal Agent; Insurance
a) The fiscal agent of the state of Washington shall be the fiscal agent for the Bonds, serving
as registrar, authenticating agent and paying agent (the "Bond Registrar The Bonds
shall be payable and shall be secured as provided in the Ordinance and as described in
the document entitled Preliminary Official Statement, which is dated November 24, 2008
and which describes the Issuer and the Bonds (the "POS
b) Payment when due of the regularly scheduled principal of and interest on the Bonds
shall be insured by a municipal bond insurance policy (the "Policy issued by Assured
Guaranty Corporation (the "Insurer
4. Offering
The Underwriter agrees to make a bona fide public offering of all the Bonds, at prices not in excess
of the initial public offering prices or at yields not lower than the initial yields as set forth in
Exhibit C attached hereto.
5. Official Statement
a) In the Ordinance, the Issuer has ratified and "deemed final" the POS for purposes of Rule
15c2 -12 of the Securities Exchange Act of 1934, as amended (the "Rule The Issuer
approves and ratifies the use and distribution by the Underwriter of the POS in
connection with the public offering for sale of the Bonds by the Underwriter.
b) The final official statement shall be substantially in the form of the POS with only such
changes permitted by the Rule as shall have been reviewed by the Underwriter (such
final official statement, incorporating such changes, if any, shall be referred to herein as
the "Final Official Statement The Issuer shall cooperate with the Underwriter in the
preparation of the Final Official Statement for delivery within seven (7) business days
after the date hereof and, in any event, for delivery in sufficient time to accompany any
order confirmation from the Underwriter to its customer, and in sufficient time to permit
the Underwriter to comply with the provisions of the Rule and with all applicable rules
of the Municipal Securities Rulemaking Board.
C) The Issuer will not amend or supplement the Final Official Statement without the consent
of the Underwriter. The Issuer agrees to notify the Underwriter promptly if, on or prior
to the 25th day after the End of the Underwriting Period (as defined below), any event
shall occur, or information come to the attention of the Issuer, that would cause the Final
Official Statement (whether or not previously supplemented or amended), as of its date,
to contain any untrue statement of a material fact or to omit to state a material fact
necessary to make the statements therein, in light of the circumstances under which they
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Honorable Mayor and City Council
City of Tukwila, Washington
December 1, 2008
Page 3
were made, not misleading. If, in the opinion of the Issuer, such event requires the
preparation and distribution of a supplement or amendment to the Final Official
Statement, the Issuer at its expense and with Underwriter's assistance, shall amend or
supplement the Final Official Statement in a form and manner approved by the
Underwriter and will provide such number of copies of the supplement or amendment to
the Final Official Statement, as the Underwriter may reasonably request. For purposes of
this Purchase Agreement, the "End of the Underwriting Period" shall occur on the
Closing Date.
6. Representations, Warranties and Covenants
The Issuer represents, warrants and covenants to the Underwriter that as of the date hereof and
as of the Closing Date:
a) The Issuer is a municipal corporation duly organized and validly existing under the laws
and Constitution of the State of Washington;
b) The Issuer has duly adopted the Ordinance and it is a valid, legal and binding ordinance
of the Issuer;
C) The Issuer is duly authorized and has full legal right, power, and authority to issue, sell
and deliver the Bonds and perform its obligations under the Documents;
d) The Ordinance is in full force and effect and has not been superseded, rescinded or
amended;
e) The Issuer has full legal right, power and authority to and will apply or cause to be
applied the proceeds of the Bonds as described in the Ordinance;
f) The execution of and performance by the Issuer of its obligations under the Documents
will not cause the Issuer to be (i) in violation of any constitutional provision, law, court
decree, administrative regulation or judgment or (ii) in material default under any loan
agreement, indenture, bond, note, resolution or other material agreement or instrument
to which the Issuer is a party or to which the Issuer or any of its properties or assets is
otherwise subject;
g) All governmental approvals or authorizations required to be obtained by the Issuer prior
to the Closing in connection with the issuance and delivery of the Bonds or the
performance by the Issuer of its obligations under the Documents have been or will be
obtained prior to Closing;
h) No filing or registration of the Ordinance or other instrument or financing statement is
required to be made to create, protect or preserve the pledge of taxing power under the
Ordinance or is required for the validity and enforceability of the Ordinance;
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Honorable Mayor and City CoiWl
City of Tukwila, Washington
December 1, 2008
Page 4
i) As of the Closing, the Bonds will be legal, valid and binding obligations of the Issuer,
and, subject only to the laws of bankruptcy and insolvency, will be enforceable in
accordance with their terms and will be in full force and effect;
j) Except as described in the Final Official Statement there is no action, suit, proceeding,
inquiry or investigation before or by any court, governmental agency, public board or
body pending or, to the knowledge of the Issuer, threatened against the Issuer, (i) in any
way questioning the legal existence of the Issuer or the titles of the officers of the Issuer
to their respective offices; (ii) in any way affecting or contesting or seeking to prohibit,
restrain or enjoin the issuance or delivery of the Bonds; (iii) wherein an unfavorable
decision, ruling, or finding would have a material adverse effect on the collection and
application of taxes that may be levied for the benefit of the Issuer for the payment of the
Bonds, the financial condition of the Issuer, or would have an adverse effect on the
validity or enforceability of the Bonds or the Ordinance, or which would in any way
adversely affect the exclusion of interest on the Bonds from gross income for federal
income tax purposes; (iv) contesting the completeness or accuracy of the POS or the Final
Official Statement; or (v) to the actual knowledge of the Issuer, there is no reasonable
basis for any action, proceeding, inquiry or investigation of the nature described in the
foregoing clauses (i) through (iv);
k) The financial statements of the Issuer contained in the Final Official Statement fairly
present the financial position of the Issuer as of the dates and for the periods therein set
forth in accordance with the accounting standards applicable to the Issuer, and since the
date thereof, there has been no material adverse change in the financial position of the
Issuer;
1) In connection with the financing process, the Underwriter may have provided the format
for and certain of the content for inclusion in the POS and may have assumed principal
drafting responsibility for the preparation of the POS and may coordinate the
preparation and dissemination of the Final Official Statement. The Issuer understands
and acknowledges, however, that the ultimate responsibility for the POS and the Final
Official Statement with respect to content, accuracy and completeness is the
responsibility of the Issuer as an issuer of municipal securities. The Issuer hereby
represents and warrants to the Underwriter that the POS did not, as of its date, and the
Final Official Statement will not, as of its date and at the Closing Date, contain any
untrue statement of material fact nor omit any statement or information which is
necessary to make the statements therein, in light of the circumstances under which they
were made, not misleading; provided, however, that no representation or warranty is
made with respect to information within the POS or the Final Official Statement relating
to DTC, the book entry system, the Insurer or the Underwriter; and
M) As described in the Final Official Statement, the Issuer failed to comply with its filing
deadline of September 30 in the years 2004 through 2007 for its existing undertakings.
Subsequently the Issuer complied on or about November 19, 2008 and implemented the
procedures to ensure compliance thereafter.
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Honorable Mayor and City Cu,,-<,il
City of Tukwila, Washington
December 1, 2008
Page 5
7. Termination
The Underwriter may terminate its obligation under this Purchase Agreement, without liability
therefor, by notifying the Issuer of its election to do so in writing if, after the execution of this
Purchase Agreement and prior to the Closing, any one or more of the following events shall have
occurred and such event, in the reasonable opinion of the Underwriter (i) would materially and
adversely affect the marketability of the Bonds or the prices or yields of the Bonds as set forth in
Exhibit C, or (ii) would materially and adversely affect the Underwriter's ability to enforce
contracts for the sale of the Bonds:
a) A material disruption in commercial banking or securities settlement or clearance
services; or
b) The United States shall have become engaged in hostilities or existing hostilities shall
have escalated or a national emergency or other national or international calamity,
including but not limited to terrorist attack(s) or other event; or
C) A general suspension of trading or other material restrictions not in force as of the date of
this Purchase Agreement on the New York Stock Exchange or other national securities
exchange; or
d) Declaration of a general banking moratorium by the United States, New York State or
Washington State authorities; or
e) Legislation with respect to eliminating or reducing the exemption from federal or state
taxation for interest income received on obligations of the general character of the Bonds
shall be introduced or enacted by the legislature of the State of Washington or by
Congress of the United States or adopted by either the United States House of
Representatives or the United States Senate or shall have been recommended to the
Congress or otherwise endorsed for passage by the Treasury Department of the United
States, the Internal Revenue Service or by the chairman of the Senate Finance Committee
or a decision or an order or ruling with respect to eliminating or reducing such
exemption, shall have been issued by a court of the United States, including the United
States Tax Court, or by or on behalf of the Treasury Department of the United States or
the Internal Revenue Service; or
f) Legislation shall hereafter be enacted, or actively considered for enactment, or a decision
by a court of the United States shall hereafter be rendered, or a ruling, stop order or
regulation by the Securities and Exchange Commission or other governmental agency
having jurisdiction of the subject matter shall hereafter be made, the effect of which is or
would be that the offering and sale of the Bonds would be illegal or that:
i) The Bonds are not exempt from the registration, qualification or similar
requirements of the Securities Act of 1933, as amended and as then in effect (the
"33 Act or distribution of the Bonds, as contemplated herein or in the Final
Official Statement, is in violation of or not exempt from the registration,
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Honorable Mayor and City C=icil
City of Tukwila, Washington
December 1, 2008
Page 6
qualification or other requirements of the 33 Act, as amended and as then in
effect, or the Securities Exchange Act of 1934, as amended and then in effect or
the Investment Company Act of 1940, as amended and then in effect (the
"Investment Company Act or, in each case, the rules or regulations
promulgated thereunder as then in effect; or
ii) The Ordinance is not exempt from the registration, qualification or other
requirements of the Trust Indenture Act of 1939, as amended and as then in
effect; or
iii) This Purchase Agreement is subject to the Investment Company Act or requires
any registration under the Investment Company Act; or
g) Any litigation, except as described in the Final Official Statement, shall be instituted or
pending at Closing to restrain or enjoin the authorization, issuance, execution, sale or
delivery of the Bonds or the execution and delivery of any of the Documents, or in any
way contesting or affecting any authority for or the validity or enforceability of the
Bonds, the Ordinance or any of the other Documents, any moneys or securities provided
for the payment of the Bonds or the existence or powers of the Issuer; or
h) Any legislation, ordinance, rule or regulation shall be introduced in or enacted by any
governmental body, board, department or agency of Washington State or of the United
States, or a decision by any court of competent jurisdiction within Washington State or
any court of the United States shall be rendered materially affecting the Issuer or the
Bonds; or
i) There shall have been established any new restrictions on transactions in securities
materially affecting the free market for securities or the extension of credit by, or the
charge to the net capital requirements of the Underwriter, including without limitation,
the fixing of minimum or maximum prices for trading or maximum ranges of prices, by
any exchange, the Securities and Exchange Commission, any other federal or state
agency or the Congress of the United States, or by Executive Order; or
j) Except for such changes to the Final Official Statement as provided in Section 5(c) of this
Purchase Agreement, there shall have been a material adverse change in the affairs of the
Issuer or there shall exist any event or fact or set of facts that either (a) makes untrue or
incorrect in any material respect any statement or information contained in the Final
Official Statement or (b) is not reflected in the Final Official Statement but should be
reflected therein to make the statements and information contained therein under the
circumstances in which made not misleading in any material respect; or
k) The withdrawal or downgrading of any rating of the Bonds by a national rating agency
from those shown in (c)(i) of Exhibit B.
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Honorable Mayor and City COMTcil
City of Tukwila, Washington
December 1, 2008
Page 7
8. Closing; Conditions of Closing
The Closing shall occur on such date and at such time and place as is set forth in Exhibit C or
otherwise agreed between the Issuer and the Underwriter, and subject to the satisfaction of the
terms and conditions of this Purchase Agreement. At Closing, the following shall occur: the
Issuer will deliver the duly executed Bonds or cause to be delivered to the fiscal agent for re-
delivery through Fast Automated Transfer System to DTC and will deliver or cause to be
delivered to the Underwriter the Ordinance; the Underwriter will accept such delivery and pay
the purchase price of the Bonds as set forth in Exhibit C hereof in same day funds. The Issuer
shall cause the applicable CUSIP identification numbers to be printed on the Bonds of each
maturity, but neither the failure to print such number on any such Bond nor any error with
respect thereto shall constitute cause for a failure or refusal by the Underwriter to accept delivery
of and to pay for the Bonds. The Bonds shall be prepared and delivered to the Bond Registrar at
or prior to the Closing Date.
In addition to the other requirements of this Purchase Agreement, Underwriter's obligations
hereunder are subject to and conditioned upon Issuer, at or prior to the Closing Date, delivering
or making available to Underwriter copies of the Documents and such items as are listed in
Exhibit B attached hereto and incorporated herein.
9. Fees and Expenses
The Issuer will pay the cost of preparing, printing and executing the Bonds; the fees and
disbursements of Bond Counsel; bond registration and rating fees and expenses; the bond
insurance premium; the refunding trustee fee; escrow verification fee; the cost of printing and
distributing the POS and Final Official Statement; travel and lodging expenses of the Issuer's
employees and representatives; and other expenses of the Issuer.
The Underwriter will pay fees and disbursements of its counsel, if any, the cost of preparation
and filing of blue sky and legal investment surveys where necessary, the Underwriter's travel
expenses, and other expenses of the Underwriter. As a convenience to the Issuer, the
Underwriter may from time to time, but only upon the prior written direction from the Issuer,
make arrangements for certain items for which Issuer is responsible hereunder, such as printing
of the POS and the Final Official Statement and travel or lodging arrangements for the Issuer's
representatives.
The Underwriter also may advance for the Issuer's account when appropriate and when directed
in advance in writing by the Issuer, the cost of the items for which the Issuer is responsible by
making payments to third -party vendors. In such cases, the Issuer shall pay such costs or
expenses directly, upon submission of appropriate invoices by the Underwriter, or promptly
reimburse the Underwriter in the event the Underwriter has advanced such costs or expenses for
the Issuer's account. It is understood that the Issuer shall be primarily responsible for payment of
all such items and that the Underwriter may agree to advance the cost of such items from time to
time solely as an accommodation to the Issuer and on the condition that it shall be reimbursed in
full by the Issuer.
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Honorable Mayor and City Lo'vpmil
City of Tukwila, Washington
December 1, 2008
Page 8
10. Miscellaneous
a) All matters relating to the Purchase Agreement shall be governed by the laws of the state
of Washington.
b) This Purchase Agreement is intended to benefit only the parties hereto. Unless it can be
shown that the untruth of any representation or warranty of the Issuer or the violation of
any agreement of the Issuer hereunder actually was or should have been discovered by
the Underwriter through its review of the information in the Final Official Statement in
accordance with and as a part of its responsibilities under federal securities laws as
applied to the facts and circumstances of this transaction, all representations and
warranties and agreements of the Issuer in this Purchase Agreement shall remain
operative and in full force and effect, regardless of (i) any investigation made by or on
behalf of the Underwriter, (ii) delivery of and payment for the Bonds hereunder, or (iii)
any termination of this Purchase Agreement. If the Issuer fails to satisfy any of the
foregoing conditions or covenants, or if the Underwriter's obligations are terminated for
any reason permitted under this Purchase Agreement, then neither the Underwriter nor
the Issuer shall have any further obligations under this Purchase Agreement, except that
any expenses incurred shall be borne in accordance with the Fees and Expenses Section
hereof.
C) Any notice or other communication to be given to the Issuer by the Underwriter under
this Purchase Agreement may be given by delivering the same in writing to the Finance
Director or other authorized official of the Issuer at 6200 Southcenter Boulevard,
Tukwila, Washington 98188; and any notice or other communication to be given to the
Underwriter by the Issuer under this Purchase Agreement may be given by delivering
the same in writing to the attention of the officer of the Underwriter executing this
Purchase Agreement at Seattle- Northwest Securities Corporation, 1420 Fifth Avenue,
Suite 4300, Seattle, Washington, 98101. Written communications may be delivered by
electronic means.
d) This Purchase Agreement may be executed in any number of counterparts, all of which
shall be one and the same instrument, and either Party hereto may execute this Purchase
Agreement by signing any such counterpart.
e) This Purchase Agreement, including all documents incorporated herein by reference,
constitutes the entire agreement between and among the Parties, supersedes any other
representations, understandings or communications between the Parties or their
representatives, and may be amended only in a writing signed by both Parties. This
Purchase Agreement is intended solely for the benefit of the Parties (including any
successors and assigns thereof but not any holder of any Bonds). No other person shall
acquire or have any rights hereunder or by virtue hereof.
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Honorable Mayor and City C7nncil
City of Tukwila, Washington
December 1, 2008
Page 9
Respectfully submitted,
SEATTLE NORTHWEST SECURITIES CORPORATION
By: wo Am V�vv�
Lindsay A. Sovde, Senior Vice President
Accepted December 1, 2008
CITY OF TUKWILA, WASHINGTON
Y:
Shawn Hunstock, Finance Director Time Signed
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EXHIBIT A
FINAL PRICING NUMBERS
BOND DEBT SERVICE
City of Tukwila, Washington
Limited Tax General Obligation Refunding Bonds, 2 _008 (Ref. 99)
FINAL NUMBERS
Dated Date 12!16 /2008
Delivery Date 12/16i2008
Annual
Period Debt Debt
Ending Principal Coupon Interest Service Service
06, 138,600 138,600
12/01/2009 35,000 4.000% 151,200 186,200 324,800
06/01 150,500 150,500
1210112010 515,000 4.000% 150,500 665,500 816,000
06/01/2011 140,200 140.200
12,01/2011 535,000 4.000% 140,200 675,200 815,400
06/01'2012 129,500 129,500
12/01/2012 550,000 4.000% 129,500 679,500 809,000
06/01 119,500 118,500
12!012013 500,000 4.000% 118.500 618,500 737,000
06/01/2014 108,500 108,500
12012014 595,000 6.000% 108,500 703,500 812,000
06/012015 90,650 90,650
12 %01/2015 630,000 4.000% 90,650 720,650 811,300
06/01/2016 78,050 78,050
12 655,000 4.000% 78.050 733,050 811,100
06/01/2017 64,950 64,950
12!01;2017 680,000 6.000% 64,950 744.950 809,900
0601/2018 44.550 44,550
12,01 720,000 6.000% 44.550 764,550 809,100
06/01/2019 22,950 22.950
12i0l/2019 765,000 6.000% 22,950 787,950 810,900
6,180,000 2.186,500 8,366.500 8.366,500
Dec 1, 2008 12.41 pm Prepared by Seattle Northwest Securities Corp JM W (k:\.. fukwila:TUKWIt.A- R99LT,R991,T) Page 3
BOND PRICING
City of rukwila, Washington
Limited Tax General Obligation Refunding Bonds, 2008 (Ref. 99)
FINAL NUMBERS
Maturity Premium
Bond Component Date Amount Rate Yield Price Discount)
Serial Bonds:
12 35,000 4.000% 1.300% 102.562 896.70
1201 2010 515.000 4.000% 2.390% 103.061 15.764.15
12.01 2011 535.000 4.000% 2.630% 103.873 20.720.55
12x01 2012 550,000 4.000% 2.980% 103.780 20,790.00
12 01'2013 500,000 4.000% 3.200% 103.639 18,195.00
12'01'2014 595,000 6.000% 3.390% 113.972 83,133.40
12'01'2015 630,000 4.000% 3.630% 102.255 14.206.50
12101 %2016 655,000 4.000% 3.880% 100.813 5,325.15
12 01'2017 680,000 6.000% 4.090% 114.203 96,580.40
12 +01 2018 720,000 6.000% 4.290% 113.738 98,913.60
12012019 765.000 6.000% 4.350% 114.258 109.073.70
6.180,000 483,599.15
Dated Date 12162008
Delivery Date 12;162008
First Coupon 06/01
Par Amount 6,180.000.00
Premium 483,599.15
Production 6,661599.15 107.825229%
Underwriter's Discount 54,075.00 0.875000%
Purchase Price 6,609,524.15 106.950229%
Accrued Interest
Net Proceeds 6.609,524.15
Dec 1, 2008 12.41 pin Prepared by Seattle- Northwest Securities Corp 1MW (k:... Tukwila:TIJKWILA- R99L1'.R99LT) Page 2
SOURCES AND USES OF FUNDS
City of Tukwila, Washington
Limited Tax General Obligation Refunding Bonds, 2008 (Ref. 99)
FINAL NUMBERS
Dated Date 12 16 2008
Delivery Date 12 162008
Sources:
Bond Proceeds:
Par Amount 6,180,000.00
Premium 483,599.15
6,663,599.15
Uses:
Refunding Escrow Deposits:
Cash Deposit 1.90
SLGS Purchases 6 ,553.897.0 0
6,553,898.90
Delivery Date Expenses:
Cost of Issuance 35,845.00
Underwriter's Discount 54,075.00
Bond Insurance (Assured Guaranty (nd 22 bps) 18,406.30
108,326.30
Other Uses of Funds:
Additional Proceeds 1,373.95
6,663,599.15
Dec 1. 2008 12:41 pin Prepared by Seattle- Northwest Securities Corp JMW (k:... rukwila.TtJKWILA- R99LT.R99L'T) Page 1
EXHIBIT B
CLOSING DOCUMENTS
Issuer's Closine Documents
At Closing, Issuer shall provide the following:
a) Copies of the Ordinance and the Blanket Issuer Letter of Representation;
b) The approving opinion of Bond Counsel dated as of the Closing Date and addressed to the
Issuer, substantially in the form set forth in Appendix A to the Final Official Statement and a
letter addressed to the Insurer and the Underwriter to the effect that the Insurer and the
Underwriter may rely upon such opinion as if it were addressed to the Insurer and the
Underwriter;
C) Evidence of each of the following:
i) That Moody's Investors Service "Moody's has assigned its (i) underlying rating of
"A1" to the Bonds and that such rating is in full force and effect on and as of the date of
Closing and (ii) insured rating of "Aa2 based upon the Issuer's purchase of the Policy
issued by the Insurer;
ii) Issuer's purchase of the Policy, including a copy of the Policy and an opinion of counsel
to the Insurer in form and substance satisfactory to the Underwriter; and
iii) Designation of the Bonds as "qualified tax exempt obligations" for banks, thrift
institutions and other financial institutions, as defined in Section 265(b)(3) of the Internal
Revenue Code of 1986, as amended.
d) A report from Grant Thornton LLP (the "Verification Agent verifying the accuracy of (a) the
mathematical computations concerning the adequacy of the maturing principal amounts of and
interest earned on the Government Obligations, together with other escrowed moneys, to be
placed in the escrow account to pay when due, pursuant to stated maturity or call for
redemption, as the case may be, the principal of, premium, if any, and interest on the Refunded
Bonds and (b) the mathematical computations of the yield on the Bonds and the yield on the
Government Obligations purchased with a portion of the proceeds of the sale of the Bonds,
together with a letter from the Verification Agent consenting to the inclusion in the POS and in
the Final Official Statement under the heading "Verification" of references to the Verification
Agent and to its report.
e) A copy of completed Form 8038 -G;
f) The following certifications, which may be combined, executed by an authorized officer of the
Issuer and dated as of the Closing Date, to the effect that:
i) The representations, warranties and covenants of the Issuer contained herein and in the
Ordinance are true and correct in all material respects on and as of the Closing Date with
the same effect as if made on the Closing Date;
ii) No litigation or other proceedings are pending or, to the knowledge of the Issuer,
threatened in any court in any way (a) affecting the position or title of the authorized
officers of the Issuer, or (b) seeking to restrain or to enjoin the authorization, issuance,
sale or delivery of, or security for, any of the Bonds, or (c) contesting or affecting the
validity or enforceability of the Bonds, the Ordinance, this Purchase Agreement, or (d)
contesting the completeness or accuracy of the POS or the Final Official Statement, or (e)
contesting the powers of the Issuer or its authority with respect to the Bonds, the
Ordinance or this Purchase Agreement, or (f) materially affecting the finances of the
Issuer. For the purpose of this subparagraph, the Issuer may rely upon a certificate of the
Issuer's legal counsel with respect to the legal matters set forth therein; and
iii) No event affecting the Issuer has occurred since the date of the Final Official Statement
which should be disclosed in the Final Official Statement for the purpose for which it is
to be used or which is necessary to disclose therein in order to make the statements
therein not misleading, and the Final Official Statement does not contain any untrue
statement of a material fact or omit to state a material fact necessary to make the
statements therein, in light of the circumstances under which they were made, not
misleading; provided, however, that no representation or warranty is made with respect
to information within the Final Official Statement relating to DTC, the book entry system,
the Insurer, the State Guarantee or the Underwriter.
g) Such additional certificates, instruments or opinions or other evidence as the Underwriter or
Bond Counsel may deem reasonably necessary or desirable to evidence the due authorization,
issuance, execution, authentication and delivery of the Bonds, the truth and accuracy as of the
time of the Closing of the representations and warranties contained in this Purchase Agreement,
and the conformity of the Bonds and Ordinance with the terms thereof as summarized in the POS
and the Final Official Statement, and to cover such other matters as the Underwriter or Bond
Counsel reasonably requests.
Underwriter's Closing Documents
At Closing, Underwriter shall deliver or cause to be delivered to the Issuer or Bond Counsel a receipt for
the Bonds including therein a representation that all closing conditions set forth in this Purchase
Agreement have been provided to the satisfaction of the Underwriter or waived by it.
EXHIBIT C
DESCRIPTION OF THE BONDS
(a) Principal Amount: $6,180,000
(b) Purchase Price: $6,609,524.15 ($106.950229 per $100), representing an original
issue premium of $483,599.15 and an underwriter's discount of
$54,075.00.
(c) Denominations: $5,000, or integral multiples thereof.
(d) Form: Registered; Book -entry only.
(e) Interest Payment Dates: June 1 and December 1, commencing June 1, 2009.
(f) Maturity and Interest Rates: The Bonds shall mature on December 1 of each year and bear
interest as follows:
Due Interest CU5IP Due Interest CUSIP
Dec. 1, Amounts Rates Yields 899052, Dec. 1 Amounts Rates Yields 899052
2009 35,000 4.00% 1.30% ERl 2015 630,000 4.00% 3.63% EX8
2010 515,000 4.00 2.39 ES9 2016 655,000 4.00 3.88 EY6
2011 535,000 4.00 2.63 ET7 2017 680,000 6.00 4.09 EZ3
2012 550,000 4.00 2.98 EU4 2018 720,000 6.00 4.29 FA7
2013 500,000 4.00 3.20 EV2 2019 765,000 6.00 4.35 FB5
2014 595,000 6.00 3.39 EWO
(g) Optional Redemption: The Bonds are not subject to optional redemption prior to
maturity.
(h) Dated Date: Date of Delivery, expected to be December 16, 2008.
(i) Offer Expires: 11:59 p.m. Pacific Time, December 1, 2008.
(j) Bond Counsel: Foster Pepper PLLC.
(k) Closing: Via conference call initiated by Bond Counsel on December 16,
2008, at 9:00 a.m. Pacific Time.
(l) Delivery: To the Bond Registrar on behalf of DTC by Fast Automated
Securities Transfer.
(m) Bond Insurance: Payment of the principal of and interest on the Bonds, when due,
will be insured by the Policy to be issued by the Insurer
(Assured Guaranty Corporation) simultaneously with the
delivery of the Bonds.
(n) Ratings: Moody's will assign its rating of "Aa2" to the Bonds based on
the Issuer's purchase of the Policy described above. Further,
Moody's has assigned its underlying rating of "Al" to the
Bonds.
DRAFT DATED 11/21/08
REFUNDING TRUST AGREEMENT
THIS AGREEMENT is made and entered into as of the 16th day of December, 2008, by
and between the CITY OF TUKWILA, WASHINGTON (the "City a Municipal corporation,
and U.S. BANK NATIONAL ASSOCIATION of Seattle, Washington (the "Refunding
TPUStee
WHEREAS, the City now has outstanding $6,260,000 par value of its Limited Tax
General Obligation Bonds, 1999, maturing on December 1 of each of the years 2010 through
2016, inclusive, and in 2019, and bearing interest at various rates ranging from 5.20% to 5.70%
(the "Refunded Bonds and]
WHEREAS, pursuant to Ordinance No. of the City (the `Bond Ordinance
the City has determined that the Refunded Bonds be refunded out of the proceeds of the sale of
its Limited Tax General Obligation Refunding Bonds, 2008 (the "Bonds for the purpose of
realizing a debt service savings for the City; and
WHEREAS, the payment, through advance refunding of the Refunded Bonds will be
accomplished pursuant to this Refunding Trust Agreement (including Exhibit A attached hereto)
and the Bond Ordinance, which documents provide for and, for the purpose of Sections 103, 148,
and 149(d) of the Internal Revenue Code of 1986, as amended (the "Code are to be considered
as the Refunding Plan, by:
(a) The delivery by the City to the Refunding Trustee of the proceeds
of the Bonds;
(b) The purchase by the Refunding Trustee of the noncallable direct
obligations of the United States of America listed on Exhibit A attached hereto
and made a part hereof by this reference or substituted obligations purchased
pursuant to Section 2 of this Agreement (the "Acquired Obligations at or prior
to the date the Bonds are delivered to the original purchaser thereof and the City
receives full payment therefor (the "Date of Closing which Acquired
Obligations satisfy the requirements of the Verification described in paragraph
(c);
(c) The delivery to the City and the Refunding Trustee of a
verification (the "Verification by a nationally recognized independent certified
public accounting firm verifying the mathematical accuracy of the computations
(which computations shall be attached to that report) showing that the Acquired
Obligations to be purchased by the Refunding Trustee pursuant to the Bond
Ordinance and this Refunding Trust Agreement, together with the specified
beginning cash balance, if any, and the maturing principal of and interest on such
Acquired Obligations, will provide sufficient money (assuming that all principal
of and interest on the Acquired Obligations are paid on the due dates thereof and
assuming no reinvestment of such maturing principal and interest) to pay interest
on the Refunded Bonds when due up to and including December 1, 2009, and on
December 1, 2009, call, pay, and redeem all of the outstanding Refunded Bonds
at a price of par; and
(d) The receipt by the Refunding Trustee of the maturing installments
of principal of and interest on the Acquired Obligations; and
(e) The Refunding Trustee's payment to the fiscal agent of the State of
Washington of money sufficient to make the payments on the Refunded Bonds set
forth herein;
and
WHEREAS, upon the issuance of the Bonds to carry out the Refunding Plan under the
authority of chapter 39.53 RCW and other laws of the State of Washington (collectively, the
"Refunding Bond Act the principal amount of the Refunded Bonds no longer shall be
considered outstanding pursuant to the defeasance provisions of Ordinance No. 1884 that
authorized the issuance of the Refunded Bonds (the "Refunded Bond Ordinance and
WHEREAS, the City Council of the City has found that the refunding of the Refunded
Bonds, through the issuance of the Bonds, is beneficial and will realize a debt service savings to
the City and its taxpayers; and
WHEREAS, the City Council of the City, pursuant to the Bond Ordinance, has duly and
validly authorized the execution and delivery of this Refunding Trust Agreement, the delivery of
the proceeds of the Bonds to the Refunding Trustee, the purchase by the Refunding Trustee of
the Acquired Obligations and the carrying out of the Refunding Plan;
NOW, THEREFORE, in consideration of the mutual covenants hereinafter contained and
[or the benefit of the City, the parties hereto agree as follows:
Section 1. Delivery of Monev to Refunding Trustee. On the Date of Closing, the
City shall cause to be delivered to the Refunding Trustee all of the proceeds of the Bonds.
Section 2. Investment and Expenditure of Monev. On the Date of Closing, the
Refunding Trustee shall apply S to pay on behalf of the City the purchase
and /or subscription prices of the Acquired Obligations, from the sources, in the principal
amounts. Nvith the dates of maturity and bearing the interest rates or yields set forth in Exhibit A,
and S to establish a beginning cash balance. Upon receipt thereof, the Refunding Trustee
shall deliver to the City copies of the documents evidencing the purchase of and payment for the
Acquired Obligations. Investments in mutual funds and unit investment trusts are prohibited.
On the Date of Closing, the Refunding Trustee shall pay the costs of issuance and sale of
the Bonds as set forth on the attached Exhibit B from the Bond proceeds deposited with the
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Refunding T7 Ustec and not needed to refund the Refunded Bonds, and shall transfer all
remaining proceeds to the City for application in accordance with the Bond Ordinance.
Section 3. Sufficiencv of Acauired Obligations. Based upon the Verification, the City
represents that the Acquired Obligations and the maturing principal thereof and the interest
thereon, if paid when due, together with the beginning cash balance, shall be sufficient to make
wlhen due the payments required by the Refunding Plan. Such amounts coming due are
sometimes referred to hereinafter as the "payments described in Section 3." The schedules of the
sources, amounts, maturities, and interest rates or yields of the Acquired Obligations and of the
Refunded Bonds that will fulfill the foregoing requirements are set forth in the Verification.
Section 4. Collection of Proceeds of Acquired Obli.v-ations and Application of Such
Proceeds and Monev. The Refunding Trustee shall present for payment and shall collect and
receive on the due dates thereof the maturing installments of the principal of and the interest on
the Acquired Obligations and any Substitute Obligations (defined hereinafter). The Refunding
Trustee shall make payments, but only in the amounts received pursuant to this section, in a
timely manner to the Fiscal Agent of the State of Washington (the "Fiscal Agent of the
amounts to be paid on the Refunded Bonds as shown in the Verification. Those payments shall
be made by check, wire transfer, or such other method of transfer of fields as shall be agreed
upon by the Refunding Trustee and the Fiscal Agent.
Section 5. Notice of Defeasance /Notice of Redemption. The Refunding Trustee agrees
to give a notice of defeasance and a notice of redemption of the Refunded Bonds pursuant to the
terms of the Refunded Bonds, and in substantially the forms attached hereto as and as described
in Exhibits C and D, to the Fiscal Agent for distribution as described therein. The notice of
defeasance shall be given immediately following the execution of this Refunding Trust
Agreement, and the notice of redemption shall be given in accordance with the Refunded Bond
Ordinance. The cost of giving the notice shall be paid by the City.
Section 6. All Obligations and Monev and Proceeds Thereof Held in Trust. The
Refunding Trustee irrevocably agrees to hold the Acquired Obligations, the Substitute
Obligations, if any, the principal thereof and interest thereon, and any other money it may
receive pursuant to this Refunding Trust Agreement and any reinvestments thereof made
pursuant to Sections 8 and 9 hereof, in trust and separate at all times from all other funds and
investments held by the Refunding Trustee, solely for the purpose of making the payments
described in Section 3. The City irrevocably conveys, transfers, and assigns to the Refunding
Trustee the Acquired Obligations, any Substitute Obligations, the principal thereof and the
interest thereon, and any other money and investments deposited with the Refunding Trustee
pursuant to this Refunding, Trust Agreement, for the purpose of making such payments. The
Refunding Trustee shall not sell, transfer, assign, or hypothecate any Acquired Obligations,
reinvestments, or Substitute Obligations except pursuant to Sections 8, 9, 13 and 14 hereof.
Section 7. Reports. The Refunding Trustee shall submit a report to the City, at least
semiannually, which report shall set forth the cash, Acquired Obligations, and any Substitute
Obligations held hereunder by the Refunding Trustee, the obligations which have matured and
amounts received by the Refunding Trustee by reason of such maturity, the interest earned on
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such obligations, a list of any investments or reinvestments made by the Refunding Trustee in
other obligations and the interest and /or principal derived therefrom, the amounts paid to the
Fiscal Agent, and any other transaction of the Refunding Trustee pertaining to its duties and
obligations as set forth herein.
Section 8. Substitution of Different Oblivations or Other Investments. The City reserves
the right to substitute from time to time for Acquired Obligations initially purchased in
accordance with Section 2 hereof, or for obligations purchased under this section, other
noncallable, nonprepayable direct obligations of the United States of America and /or obligations
unconditionally guaranteed by the United States of America as to full and timely payment of
principal and interest authorized to be acquired with the proceeds of Bonds under the Refunding
Bond Act (the "Substitute Obligations Prior to effecting any such substitution, the City shall
have obtained at its expense and delivered to the Refunding Trustee:
(a) A verification by a nationally recognized independent certified
public accounting firm acceptable to the Refunding Trustee confirming that the
maturing principal of and interest on the Substitute Obligations and any remaining
Acquired Obligations to be held by the Refunding Trustee in the refunding
escrow, if paid when due and assuming no reinvestment thereof, together with any
other cash then held by the Refunding Trustee, will be sufficient to carry out the
Refunding Plan and make all remaining payments described in Section 3; and
(b) An opinion from Foster Pepper PLLC, bond counsel to the City, its
successor or other nationally recognized bond counsel to the City, that the
disposition and substitution or purchase of such securities, under the statutes,
rules, and regulations then in force and applicable to the Bonds, will not cause the
interest on the Bonds or the Refunded Bonds to be included in gross income for
federal income tax Purposes and that such disposition and substitution or purchase
is in compliance with the statutes and regulations applicable to the Bonds.
If the verification delivered to the Refunding Trustee pursuant to Section 8(a) shows that surplus
money not needed to make the payments described in Section 3 will result from the sale, transfer,
or other disposition of Acquired Obligations and the substitution of Substitute Obligations
therefor, that surplus money at the written request of the City shall be released from the trust
estate and shall be transferred to the City to be used for any lawful City purpose, subject to any
restrictions stated in the opinion of bond counsel required by Section 8(b).
Section 9. Reinvestment of Proceeds of ACQlrlred and /or Substitute Obligations. The
proceeds (principal and interest) and reinvestment proceeds of any Acquired Obligations and /or
Substitute Obligations held by the Refunding Trustee in accordance with this Refunding Trust
Agreement, which are not needed within five business days of the receipt thereof to make the
payments described in Section 3, shall be reinvested by the Refunding Trustee, but only upon
receipt of written request of the City, on such date of receipt or the next business day. The City
shall direct such reinvestment subject to the following conditions:
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(a) Except as provided in subsection (c) below, the proceeds of such
Acquired Obligations and /or Substitute Obligations shall be reinvested in
Substitute Obligations at a yield that will not cause the composite yield on the
refunding escrow to exceed during its tern or such higher yield as
may be directed by letter of instructions from the City to the Refunding Trustee,
but if the composite yield on the directed investments made pursuant to this
Refunding Trust Agreement would exceed such letter of
instructions shall contain a verification of such composite yield and shall be based
upon and accompanied by the opinion of Foster Pepper PLLC, bond counsel to
the City, its successor, or other nationally recognized bond counsel to the City,
approving reinvestment of such proceeds at such higher yield.
(b) The obligations in which such proceeds are reinvested shall mature
in an amount at least equal to their purchase price on the date or dates directed by
the City, but not later than the date (as shown by the then most recent certified
public accountant verification) the principal thereof is needed to make the
payments described in Section 3;
(c) if such proceeds, together with other funds remaining in trust, are
insufficient to reinvest in the smallest denomination of such obligations or are
required to be used to make payments described in Section 3 sooner than the
Shortest maturity available for such obligations, then those proceeds and funds
either shall be converted to United States currency and retained or shall remain
uninvested in the refunding escrow and carried on the books of the Refunding
Trustee until required to make the payments described in Section 3, or until
sufficient money is accumulated to permit the investment thereof, and
(d) "Yield," as used in paragraph (a) of this section with respect to the
Acquired Obligations and Substitute Obligations, means that yield computed in
accordance with and permitted by the Code applicable to the Bonds and the trust
under this Refunding Trust Agreement so as to preserve the exclusion from gross
income for federal income tax purposes of the interest on the Bonds.
The Refunding Trustee may make any and all investments permitted by the provisions of this
Section through its own investment department or the investment departments of any of its
affiliates.
Section 10. Amendments to Refunding Trust Agreement. The Refunding Trustee and
the City recognize that the owners of the Refunded Bonds and the Bonds from time to time have
a beneficial interest in the Acquired Obligations, the Substitute Obligations, and money to be
held by the Refunding Trustee as herein provided. Therefore, this Refunding Trust Agreement is
irrevocable and shall not be subject to amendment except for the purpose of clarifying any
ambiguity herein, increasing the protection of the rights of the owners of the Refunded Bonds or
the Bonds, or preserving the exclusion of the interest on the Refunded Bonds and the Bonds from
gross income for federal income tax purposes, and only if such amendment is accompanied by an
opinion addressed to the City and the Refunding Trustee from Foster Pepper PLLC, its successor
-5-
or other nationally recognized bond counsel to the City, to the effect that such change is
necessary for one of the above reasons and does not detrimentally affect the owners of the
outstanding Refunded Bonds and the Bonds or that it strengthens the protection of the owners of
the Refunded Bonds and the Bonds and does not detrimentally affect the owners of the Refunded
Bonds and the Bonds. If such amendment affects the amount of money and investments in the
escrow account or the application thereof, prior to the amendment's taking effect there also shall
be a verification by a nationally recognized independent certified public accounting firn
satisfactory to the Refunding Trustee to the effect that after such amendment the Acquired
Obligations, Substitute Obligations, and other money in the escrow account will be sufficient to
make the payments described in Section 3. A copy of such verification shall be delivered to the
Refunding Trustee.
Section H. Limitation of Liability of Refimdlmz Trustee. None of the provisions
contained in this Refunding Trust Agreement shall require the Refunding Trustee to use or
advance its own funds in the performance of any of its duties or the exercise of any of its rights
or pow'ei hereunder. The Refunding Trustee shall be under no liability for the payment of
interest on any funds or other property received by it hereunder except to the extent the
Refunding Trustee is required by the express terms of this Refunding Trust Agreement to invest
such funds.
The Refunding Trustee's liabilities and obligations in connection with this Refunding
Trust Agreement are confined to those specifically described herein. The Refunding Trustee is
authorized and directed to comply with the provisions of this Refunding Trust Agreement and is
relie� from all liability for so doing notwithstanding any demand or notice to the contrary by
any party lhcreto. The Refunding Trustee shall not be responsible or liable for the sufficiency,
correctness, genuineness, or validity of the Acquired Obligations or the Substitute Obligations
deposited with it; the performance or compliance by any party other than the Refunding Trustee
\N ith the terms or conditions of any such instruments; or any loss which may occur by reason of
forgeries, false representations, or the exercise of the Refunding Trustee's discretion in any
particular manner unless such exercise is negligent or constitutes willful misconduct.
If any controversy arises between the City and any third person, the Refunding Trustee
shall not be required to determine the same or to take any action in the premises, but it may
institute, in its discretion, an interpleader or other proceedings in connection therewith as it may
deem proper, and in following either course, it shall not be liable.
Section 12. Remittance of Funds When Refunded Bonds Paid in Full. At such time as
the Refunding Trustee has received the representation of the City that all of the payments
described in Section 3 have been made and the confirmation of such representation by the Fiscal
Agent, toucther with such other evidence of such payments as shall be satisfactory to the City
and the Refunding Trustee, the Refunding Trustee shall deliver forthwith or remit to the City any
remaining Acquired Obligations, Substitute Obligations, and money held pursuant to this
Refunding Trust Agreement.
Section 13. Compensation of Refundinu Trustee. The payment arrangement heretofore
made bem,cen the Refunding Trustee and the City (attached hereto as Exhibit E and by this
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reference made a part hereof) on compensation and expenses of the Refunding Trustee for
services rendered by it pursuant to the provisions of this Refunding Trust Agreement is
satisfactory to it and to the City, and no further payment to the Refunding Trustee shall be
required for such purpose. Such arrangement for compensation and expenses is intended as
compensation for the ordinary services as contemplated by this Refunding Trust Agreement, and
if the Refunding Trustee renders any service hereunder not provided for in this Refunding Trust
Agreement, or the Refunding Trustee is made a party to or intervenes in any litigation pertaining
to this Refunding Trust Agreement or institutes interpleader proceedings relative hereto, the
Refunding Trustee shall be compensated reasonably by the City for such extraordinary services
and reimbursed for all fees, costs, liability, and expenses (including reasonable attorneys' fees)
occasioned thereby. The Refimding Trustee shall not have a lien against or otherwise be
compensated for its services and expenses from the money, Acquired Obligations, and Substitute
Obligations held pursuant to this Refunding Trust Agreement to make the payments described in
Section 3.
Section 14. Successor Refunding Trustee. The obligations assumed by the Refunding
Trustee pursuant to this Refunding Trust Agreement may be transferred by the Refunding
Trustee to a successor if (a) the Refunding Trustee has presented evidence satisfactory to the
City and to Foster Pepper PLLC, its successor or other nationally recognized bond counsel to the
City that the successor trustee meets the requirements of RCW 39.53.070, as now in effect or
hereafter amended; (b) the City approves the appointment of the successor trustee; (c) the
successor trustee has assumed all of the obligations of the Refunding Trustee under this
Refundin- Trust Agreement and has been compensated; and (d) all of the Acquired Obligations,
reinvestments, Substitute Obligations, and money then held by the Refunding Trustee pursuant to
this Refunding Trust Agreement have been duly transferred to such successor trustee.
Notwithstanding anything to the contrary contained in this Agreement, any company into
v the Refunding Trustee may be merged or converted or with which it may be consolidated
or any company resulting from any merger, conversion, or consolidation to which the Refunding
Trustee is a party, or any company to which the Refunding Trustee may sell or transfer all or
substantially all of its corporate trust business shall be the successor to the Refunding Trustee
without execution or filing of any paper or further act, if such company is eligible to serve as
Refunding Trustee under RCW 39.53.070.
Section 15. Miscellaneous. This Refunding Trust Agreement is governed by
Washington law without regard to the conflict of laws provisions thereof and may not be
modified except by a writing signed by the parties and subject to the limitations of Section 10. If
any one or more of the provisions contained in this Refunding Trust Agreement shall for any
reason be held to be invalid, illegal, or unenforceable in any respect, such invalidity, illegality, or
unenforceability shall not affect any other provisions of this Refunding Trust Agreement, but this
Refunding Trust Agreement shall be construed as if such invalid, illegal, or unenforceable
provision had never been contained herein.
Section 16. Notice to Rating A,encies. The Refunding Trustee shall notify all national
rating agencies maintaining (at the request of the City) a rating on the Refunded Bonds or the
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Bonds, in writing" upon timely receipt of notice or evidence of either of the following
circumstances:
(a) Prior to their taking effect, any amendments to this Refunding
Trust Agreement under Section 10, enclosing the proposed amendatory
documents; and
(b) The holding (referred to in Section 15) that one or more provisions
of this Refunding Trust Agreement are invalid, illegal, or unenforceable in any
respect, enclosing a copy of that holding.
Such notices shall be sent to the applicable rating agencies by first class mail to the addresses
advised by those rating agencies.
Section 17. COLlntemarts. This Agreement may be executed in counterparts.
IN WITNESS WHEREOF, the parties have executed and delivered this Refunding Trust
Agreement pursuant to due and proper authorization, all as of the date and year first above
�tiritten.
CITY OF TUILWILA, WASHINGTON U.S. BANK NATIONAL ASSOCIATION,
as Refunding Trustee
By By
Title:
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EXHIBIT A
CITY OF TUKWILA, WASHINGTON
I.INIITED TAX GENERAL OBLIGATION REFUNDING BONDS, 2008
ACOUIRED OBLIGATIONS
MATURITY PAR INTEREST
TYPE' DATE AMOUNT RATE
�`CLK7 United States Treasury Certificate of Indebtedness -State and Local Government Series
\(CIF. United States Treasury Notc- -State and Local Government Series
EXHIBIT B
CITY OF TUKWILA, WASHINGTON
LI VIITED TAX GENERAL OBLIGATION REFUNDING BONDS, 2008
COSTS OF ISSUANCE
EXHIBIT C
Notice of Defeasance
City of Tukwila, Washington
Limited Tax General Obligation Bonds, 1999
NOTICE 1S HEREBY GIVEN to the owners of the above captioned bonds with respect to which,
pursuant to the Refunding Trust Agreement dated as of December 16, 2008, by and between the City of
Tuk\Vila, Washington (the "City and U.S. Bank National Association (the "Refunding Trustee there
has been deposited into an escrow account, held by the Refunding Trustee, cash and non- callable direct
obligations of the Unitcd States of America, the principal of and interest on which, when due, will provide
money to pay each year, to and including the respective maturity or redemption dates of such bonds so
provided for. the principal thereof and interest thereon (the "Refunded Bonds Such Refunded Bonds
are therefore deemed to be no longer outstanding pursuant to Section 14 of Ordinance No. 1884 of the
City relating to the Refunded Bonds, but will be paid by application of the assets in such escrow account.
The Refunded Bonds are described as follows:
City of Tukwila, Washington
Limited Tax General Obligation Bonds, 1999
(Dated October 15, 1999)
Maturity Date Par Amount Interest Call Date CUSIP
(December 1) Defeased Rate (at 100 Nos.
2010 S 490,000 5.200% 12/1/2009 899052DFS
2011 515,000 5.250 12/1/2009 899052DG6
2012 540,000 5.300 12/1/2009 899052DH4
2013 570,000 5.375 12/1/2009 899052DJO
2014 600,000 5.450 12/1 /2009 899052DK7
2015 635,000 5.550 12/1/2009 899052DM3
2016 670,000 5.600 12/1/2009 899052DNI
2019 2 ,240.000 5.700 12/1/2009 899052DL5
tT.S. Bank National Association, as Refunding Trustee
Dated:
This notice shall be given immediately by first class mail to each registered owner of the Refunded Bonds, to
Ambac Assurance Corporation and to each Nationally Recognized Municipal Securities Information Repository.
EXHIBIT D
Notice of Redemption
City of Tukwila, Washington
Limited Tax General Obligation Bonds, 1999
NOTICE E IS HEREBY GIVEN that the City of Tukwila, Washington, has called for redemption
on December 1. 2009, all of its then- outstanding Limited Tax General Obligation Bonds, 1999 (the
"Bonds
The Bonds will be redeemed at a price of one hundred percent (100%) of their principal amount,
plus accrued interest to December 1, 2009. The redemption price of the Bonds is payable on presentation
and surrender of the Bonds at the office of:
IBy Mail or in Person] -or- [In Person Only]
The Bank of New York Any branch of Wells Fargo
Worldwide Securities Processing Bank, National Association in the
2001 Bryan Street, 9" Floor State of Washington
Dallas, TX 75201
Interest on all Bonds or portions thereof which are redeemed shall cease to accrue on
December 1. 2009.
The lollovrin, Bonds are being redeemed:
Maturity Date Par Amount Interest CUSIP
(December 1) Defcased Rate Nos.
2010 490,000 5.200% 899052DF8
2011 515,000 5.250 899052DG6
2012 540,000 5.300 899052DH4
2013 570,000 5.375 899052DJO
2014 600,000 5.450 899052DK7
2015 635,000 5.550 899052DM3
2016 670,000 5.600 899052DNI
2019 2.240.000 5.700 899052DL5
By Order of the City of Tukwila, Countyname
County, 'Washington
The Bank of New York, as Paying Agent
Dated:
I his notice shall be given not less than 30 nor more than 60 days prior to December I, 2009, by first class mail, postage
prepaid, to each registered owner of the redeemed bonds. In addition, notice shall be mailed within the same period, postage
prepaid. to Moody's Incstors Service, Inc., and Standard Poor's at their offices in New York, New York; Ambac Assurance
Corporation at its principal office in Nc%\ York, New York, to Lehman Brothers, or its successor, at its principal office in Seattle,
\ashington: and The Depository Trust Company of New York, New York, and each NRMSIR.
t;ndcr Section 3406(a)(1) of the Internal Revenue Code the Registrar may be obligated to withhold a percentage of
the principal of a holder who has failed to furnish the Registrar with a valid taxpayer identification number and a
certification that the owner is not subject to backup withholding. Owners who wish to avoid the application of these
provisions should submit a completed IRS Form W -9 when presenting their certificates for payment.
EXHIBIT E
U.S. BANK NATIONAL ASSOCIATION FEE SCHEDULE
[INSERT SCHEDULE FROM BANK]
N
ysos
C i ty of u la
Washington
Ordinance No. 1,!
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF TUKWILA,
WASHINGTON, RELATING TO CONTRACTING INDEBTEDNESS;
PROVIDING FOR THE ISSUANCE OF $6,180,000 PAR VALUE OF LIMITED
TAX GENERAL OBLIGATION REFUNDING BONDS, 2008, OF THE CITY
FOR GENERAL CITY PURPOSES TO PROVIDE FUNDS WITH WHICH TO
PAY THE COST OF ADVANCE REFUNDING A PORTION OF THE CITY'S
OUTSTANDING LIMITED TAX GENERAL OBLIGATION BONDS, 1999,
AND PAYING THE ADMINISTRATIVE COSTS OF SUCH REFUNDING
AND THE COSTS OF ISSUANCE AND SALE OF SUCH BONDS; FIXING
THE DATE, FORM, MATURITIES, INTEREST RATES, TERMS AND
COVENANTS OF THE BONDS; ESTABLISHING A BOND FUND;
PROVIDING FOR AND AUTHORIZING THE PURCHASE OF CERTAIN
OBLIGATIONS OUT OF THE PROCEEDS OF THE SALE OF THE BONDS
HEREIN AUTHORIZED AND FOR THE USE AND APPLICATION OF THE
MONEY DERIVED FROM THOSE INVESTMENTS; AUTHORIZING THE
EXECUTION OF AN AGREEMENT WITH U.S. BANK NATIONAL
ASSOCIATION OF SEATTLE, WASHINGTON, AS REFUNDING TRUSTEE;
PROVIDING FOR THE CALL, PAYMENT AND REDEMPTION OF THE
OUTSTANDING BONDS TO BE REFUNDED; PROVIDING FOR THE
PURCHASE OF BOND INSURANCE; AND APPROVING THE SALE AND
PROVIDING FOR THE DELIVERY OF THE BONDS TO SEATTLE
NORTHWEST SECURITIES CORPORATION OF SEATTLE,
WASHINGTON; PROVIDING FOR SEVERABILITY; AND
ESTABLISHING AN EFFECTIVE DATE.
WHEREAS, pursuant to Ordinance No. 1884 (the "Refunded Bond Ordinance the
City of Tukwila, Washington (the "City issued and sold its $10,000,000 par value
Limited Tax General Obligation Bonds, 1999 (the "1999 Bonds for the purpose of
providing funds with which to pay and redeem the City's outstanding Limited Tax
General Obligation Bond Anticipation Note, 1998 (City Hall), and to pay a part of the cost
of acquiring property for and constructing a City office and resource facility, parking area
and other developments in connection with the Tukwila Village Program, and by that
ordinance reserved the right to redeem the 1999 Bonds maturing on or after December
1, 2010, prior to their maturity at any time on or after December 1, 2009, at a price of par
plus accrued interest to the date fixed for redemption; and
WHEREAS, there are presently outstanding $6,260,000 par value of 1999 Bonds
maturing on December 1 of each of the years 2010 through 2016 (inclusive), and 2019,
and bearing various interest rates from 5.20% to 5.70% (the "Refunded Bonds and
WHEREAS, after due consideration, it appears to the City Council that the
Refunded Bonds may be refunded by the issuance and sale of the limited tax general
obligation refunding bonds authorized herein (the "Bonds so that a substantial
savings will be effected by the difference between the principal and interest cost over
the life of the Bonds and the principal and interest cost over the life of the Refunded
Bonds but for such refunding, which refunding will be effected by carrying out the
Refunding Plan, as defined below; and
WHEREAS, to effect that refunding in the manner that will be most advantageous
to the City, it is found necessary and advisable that certain Acquired Obligations
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(defined below) bearing interest and maturing at such time or times as necessary to
accomplish the refunding as aforesaid be purchased out of a portion of the proceeds of
the Bonds; and
WHEREAS, the City Council deems it to be in the best interests of the City to issue
and sell the Bonds to pay part of the cost of advance refunding the Refunded Bonds and
to pay the administrative costs of such refunding and the costs of issuance and sale of
the Bonds; and
WHEREAS, Seattle Northwest Securities Corporation has offered to purchase the
Bonds authorized herein under the terms and conditions set forth in this ordinance in the
form of a bond purchase contract; and
WHEREAS, Assured Guaranty Corp. has made a commitment to issue an insurance
policy (the "Financial Guaranty Insurance Policy insuring the payment when due of
the principal of and interest on the Bonds as provided therein, and the City Council
deems the purchase of the Financial Guaranty Insurance Policy is in the best interest of
the City;
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUKWILA,
WASHINGTON, HEREBY ORDAINS AS FOLLOWS:
Section 1. Definitions. For the purposes of this ordinance the words or phrases
defined in this section shall have the following meanings:
1. "Acquired Obligations" means those United States Treasury Certificates of
Indebtedness, Notes, and Bonds -State and Local Government Series and other direct,
non callable obligations of the United States of America purchased to accomplish the
refunding of the Refunded Bonds as authorized by this ordinance.
2. "Bond Fund" means the Limited Tax General Obligation Refunding Bond
Fund, 2008, created by this ordinance for the payment of the Bonds.
3. "Bond Insure" means Assured Guaranty Corp.
4. "Bond Register" means the books or records maintained by the Bond
Registrar containing the name and mailing address of the owner of each Bond and the
principal amount and number of Bonds held by each owner.
5. "Bond Registrar" means the Fiscal Agent.
6. "Bonds" means the $6,180,000 par value Limited Tax General Obligation
Refunding Bonds, 2008, of the City issued pursuant to and for the purposes provided in
this ordinance.
7. "City" means the City of Tukwila, Washington, a municipal corporation
duly organized and existing under and by virtue of the laws of the State of Washington.
8. "Code" means the United States Internal Revenue Code of 1986, as
amended, and applicable rules and regulations promulgated thereunder.
9. "DTC" means The Depository Trust Company, New York, New York.
10. "Financial Guaranty Insurance Policy" means the financial guaranty
insurance policy issued by the Bond Insurer insuring the payment when due of the
principal of and interest on the Bonds as provided therein.
11. "Fiscal Agent" means the fiscal agent of the State of Washington, as the
same may be designated by the State from time to time.
12. "Letter of Representations" means the Blanket Issuer Letter of
Representations dated October 18, 1999, between the City and DTC, as it may be
amended from time to time.
13. "Refunded Bonds" means all of the outstanding Limited Tax General
Obligation Bonds, 1999, of the City maturing in the years 2010 through 2016, inclusive,
and in 2019, issued pursuant to Ordinance No. 1884, the refunding of which has been
provided for by this ordinance.
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I
14. "Refunding Plan" means:
a. the deposit of a sufficient amount of the proceeds of the Bonds with
the Refunding Trustee for the purchase of the Acquired Obligations;
b. the payment of the interest on the Refunded Bonds when due up to
and including December 1, 2009, and the call, payment, and redemption on December 1,
2009, of all of the outstanding Refunded Bonds at a price of par; and
c. the payment of the costs of issuing the Bonds and the costs of carrying
out the foregoing elements of the Refunding Plan.
15. "Refunding Trust Agreement" means a Refunding Trust Agreement between
the City and the Refunding Trustee substantially in the form of that which is on file with
the City Clerk and by this reference incorporated herein.
16. "Refunding Trustee" means U.S. Bank National Association of Seattle,
Washington, serving as trustee or escrow agent or any successor trustee or escrow agent.
Section 2. Debt Capacity. The assessed valuation of the taxable property within
the City as ascertained by the last preceding assessment for City purposes for the
calendar year 2008 is $4,437,340,786, and the City has outstanding general indebtedness
evidenced by limited tax general obligation bonds in the principal amount of
$20,843,000 incurred within the limit of up to 1 /2% of the value of the taxable property
within the City permitted for general municipal purposes without a vote of the
qualified voters therein, no outstanding unlimited tax general obligation bonds issued
pursuant to a vote of the qualified voters of the City, and the amount of indebtedness
for which bonds are authorized herein to be issued is $6,180,000.
Section 3. Authorization of Bonds. The City shall borrow money on the credit of
the City and issue negotiable limited tax general obligation bonds evidencing that
indebtedness in the amount of $6,180,000 for general City purposes to provide the funds
to advance refund the Refunded Bonds by carrying out the Refunding Plan. The
general indebtedness to be incurred shall be within the limit of up to 1 1 /2% of the value
of the taxable property within the City permitted for general municipal purposes
without a vote of the qualified voters therein.
Section 4. Description of Bonds. The Bonds shall be called Limited Tax General
Obligation Refunding Bonds, 2008. The Bonds shall be dated the date of their initial
delivery; shall be in the denomination of $5,000 or any integral multiple thereof within a
single maturity; shall be numbered separately in the manner and with any additional
designation as the Bond Registrar deems necessary for purposes of identification; shall
bear interest (computed on the basis of a 360 -day year of twelve 30 -day months)
payable semiannually on each June 1 and December 1, commencing June 1, 2009 to the
maturity or earlier redemption of the Bonds; and shall mature on December 1 in years
and amounts and bear interest at the rates per annum as follows:
Maturity Interest Maturity Interest
Years Amounts Rates Years Amounts Rates
2009 35,000 4.00% 2015 $630,000 4.00%
2010 515,000 4.00 2016 655,000 4.00
2011 535,000 4.00 2017 680,000 6.00
2012 550,000 4.00 2018 720,000 6.00
2013 500,000 4.00 2019 765,000 6.00
2014 595,000 6.00
Section 5. Registration and Transfer of Bonds.
A. The Bonds shall be issued only in registered form as to both principal and
interest and shall be recorded on books or records maintained by the Bond Registrar
(the "Bond Register The Bond Register shall contain the name and mailing address
of the owner of each Bond and the principal amount and number of each of the Bonds
held by each owner.
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B. Bonds surrendered to the Bond Registrar may be exchanged for Bonds in any
authorized denomination of an equal aggregate principal amount and of the same
interest rate and maturity. Bonds may be transferred only if endorsed in the manner
provided thereon and surrendered to the Bond Registrar. Any exchange or transfer
shall be without cost to the owner or transferee. The Bond Registrar shall not be
obligated to exchange or transfer any Bond during the 15 days preceding any principal
payment or redemption date.
C. The Bonds initially shall be registered in the name of Cede Co., as the
nominee of DTC. The Bonds so registered shall be held in fully immobilized form by
DTC as depository in accordance with the provisions of the Letter of Representations.
Neither the City nor the Bond Registrar shall have any responsibility or obligation to
DTC participants or the persons for whom they act as nominees with respect to the
Bonds regarding accuracy of any records maintained by DTC or DTC participants of
any amount in respect of principal of or interest on the Bonds, or any notice which is
permitted or required to be given to registered owners hereunder (except such notice as
is required to be given by the Bond Registrar to DTC).
D. For as long as any Bonds are held in fully immobilized form, DTC, its nominee
or its successor depository shall be deemed to be the registered owner for all purposes
hereunder and all references to registered owners, bondowners, bondholders or the like
shall mean DTC or its nominee and shall not mean the owners of any beneficial
interests in the Bonds. Registered ownership of such Bonds, or any portions thereof,
may not thereafter be transferred except:
1. to any successor of DTC or its nominee, if that successor shall be qualified
under any applicable laws to provide the services proposed to be provided by it;
2. to any substitute depository appointed by the City or such substitute
depository's successor; or
3. to any person if the Bonds are no longer held in immobilized form.
E. Upon the resignation of DTC or its successor (or any substitute depository or
its successor) from its functions as depository, or a determination by the City that it no
longer wishes to continue the system of book entry transfers through DTC or its
successor (or any substitute depository or its successor), the City may appoint a
substitute depository. Any such substitute depository shall be qualified under any
applicable laws to provide the services proposed to be provided by it.
F. If, 1) DTC or its successor (or substitute depository or its successor) resigns
from its functions as depository, and no substitute depository can be obtained, or 2) the
City determines that the Bonds are to be in certificated form, the ownership of Bonds
may be transferred to any person as provided herein and the Bonds no longer shall be
held in fully immobilized form.
Section 6. Payment of Bonds. Both principal of and interest on the Bonds shall be
payable in lawful money of the United States of America. Interest on the Bonds shall be
paid by checks or drafts of the Bond Registrar mailed on the interest payment date to
the registered owners at the addresses appearing on the Bond Register on the 15th day
of the month preceding the interest payment date or, if requested in writing by a
registered owner of $1,000,000 or more in principal amount of Bonds prior to the
applicable record date, by wire transfer on the interest payment date. Principal of the
Bonds shall be payable upon presentation and surrender of the Bonds by the registered
owners to the Bond Registrar. Notwithstanding the foregoing, for as long as the Bonds
are registered in the name of DTC or its nominee, payment of principal of and interest
on the Bonds shall be made in the manner set forth in the Letter of Representations.
Section 7. Redemption Provisions and Open Market Purchase of Bonds.
A. The Bonds shall be issued without the right or option of the City to redeem the
Bonds prior to their stated maturity dates.
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B. The City reserves the right and option to purchase any or all of the Bonds in the
open market at any time at any price plus accrued interest to the date of purchase. All
Bonds purchased under this section shall be cancelled.
Section 8. Failure to Redeem Bonds. If any Bond is not redeemed when properly
presented at its maturity, the City shall be obligated to pay interest on that Bond at the
same rate provided in the Bond from and after its maturity until that Bond, both
principal and interest, is paid in full or until sufficient money for its payment in full is
on deposit in the Bond Fund and the Bond has been called for payment by giving notice
of that call to the Registered Owner of each of those unpaid Bonds.
Section 9. Pledge of Taxes. For as long as any of the Bonds are outstanding, the
City irrevocably pledges to include in its budget and levy taxes annually within the
constitutional and statutory tax limitations provided by law without a vote of the
electors of the City on all of the taxable property within the City in an amount sufficient,
together with other money legally available and to be used therefore, to pay when due
the principal of and interest on the Bonds, and the full faith, credit and resources of the
City are pledged irrevocably for the annual levy and collection of those taxes and the
prompt payment of that principal and interest.
Section 10. Form and Execution of Bonds.
A. The Bonds shall be printed on good bond paper in a form consistent with the
provisions of this ordinance and state law and shall be signed by the Mayor and City
Clerk, either or both of whose signatures may be manual or in facsimile, and the seal of
the City or a facsimile reproduction thereof shall be impressed or printed thereon.
B. Only Bonds bearing a Certificate of Authentication in the following form,
manually signed by the Bond Registrar, shall be valid or obligatory for any purpose or
entitled to the benefits of this ordinance:
CERTIFICATE OF AUTHENTICATION
This Bond is one of the fully registered City of Tukwila, Washington, Limited Tax
General Obligation Refunding Bonds, 2008, described in the Bond Ordinance.
WASHINGTON STATE FISCAL AGENT
Bond Registrar
By
Authorized Signer
C. The authorized signing of a Certificate of Authentication shall be conclusive
evidence that the Bonds so authenticated have been duly executed, authenticated and
delivered and are entitled to the benefits of this ordinance.
D. If any officer whose facsimile signature appears on the Bonds ceases to be an
officer of the City authorized to sign bonds before the Bonds bearing his or her facsimile
signature are authenticated or delivered by the Bond Registrar or issued by the City,
those Bonds nevertheless may be authenticated, issued and delivered and, when
authenticated, issued and delivered, shall be as binding on the City as though that
person had continued to be an officer of the City authorized to sign bonds. Any Bond
also may be signed on behalf of the City by any person who, on the actual date of
signing of the Bond, is an officer of the City authorized to sign bonds, although he or
she did not hold the required office on the date of issuance of the Bonds.
Section 11. Bond Registrar.
A. The Bond Registrar shall keep, or cause to be kept, at its principal corporate
trust office, sufficient books for the registration and transfer of the Bonds, which shall
be open to inspection by the City at all times. The Bond Registrar is authorized, on
behalf of the City, to authenticate and deliver Bonds transferred or exchanged in
accordance with the provisions of the Bonds and this ordinance, to serve as the City's
paying agent for the Bonds and to carry out all of the Bond Registrar's powers and
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duties under this ordinance and City Ordinance No. 1338 establishing a system of
registration for the City's bonds and obligations.
B. The Bond Registrar shall be responsible for its representations contained in the
Bond Registrar's Certificate of Authentication on the Bonds. The Bond Registrar may
become the owner of Bonds with the same rights it would have if it were not the Bond
Registrar and, to the extent permitted by law, may act as depository for and permit any
of its officers or directors to act as members of, or in any other capacity with respect to,
any committee formed to protect the rights of Bond owners.
Section 12. Preservation of Tax Exemption for Interest on Bonds. The City
covenants that it will take all actions necessary to prevent interest on the Bonds from
being included in gross income for federal income tax purposes, and it will neither take
any action nor make or permit any use of proceeds of the Bonds or other funds of the
City treated as proceeds of the Bonds at any time during the term of the Bonds which
will cause interest on the Bonds to be included in gross income for federal income tax
purposes. The City also covenants that it will, to the extent the arbitrage rebate
requirement of Section 148 of the Code is applicable to the Bonds, take all actions
necessary to comply (or to be treated as having complied) with that requirement in
connection with the Bonds, including the calculation and payment of any penalties that
the City has elected to pay as an alternative to calculating rebatable arbitrage, and the
payment of any other penalties if required under Section 148 of the Code to prevent
interest on the Bonds from being included in gross income for federal income tax
purposes.
Section 13. Designation of Bonds as "Qualified Tax Exempt Obligations." The
City has determined and certifies that:
1. the Bonds are not "private activity bonds" within the meaning of Section
141 of the Code;
2. the reasonably anticipated amount of tax exempt obligations (other than
private activity bonds and other obligations not required to be included in such
calculation) which the City and any entity subordinate to the City (including any entity
that the City controls, that derives its authority to issue tax exempt obligations from the
City, or that issues tax exempt obligations on behalf of the City) will issue during the
calendar year in which the Bonds are issued will not exceed $10,000,000; and
3. the amount of tax exempt obligations, including the Bonds, designated by
the City as "qualified tax exempt obligations" for the purposes of Section 265(b)(3) of
the Code during the calendar year in which the Bonds are issued does not exceed
$10,000,000. The City designates the Bonds as "qualified tax exempt obligations" for
the purposes of Section 265(b)(3) of the Code.
Section 14. Refunding or Defeasance of the Bonds.
A. The City may issue refunding bonds pursuant to the laws of the State of
Washington or use money available from any other lawful source to pay when due the
principal of and interest on the Bonds, or any portion thereof included in a refunding or
defeasance plan, and to redeem and retire, refund or defease all such then outstanding
Bonds (hereinafter collectively called the "defeased Bonds and to pay the costs of the
refunding or defeasance. If money and/or direct obligations of the United States of
America maturing at a time or times and bearing interest in amounts (together with
money, if necessary) sufficient to redeem and retire, refund or defease the defeased
Bonds in accordance with their terms are set aside in a special trust fund or escrow
account irrevocably pledged to that redemption, retirement or defeasance of defeased
Bonds (hereinafter called the "trust account then all right and interest of the owners
of the defeased Bonds in the covenants of this ordinance and in the funds and accounts
obligated to the payment of the defeased Bonds shall cease and become void. The
owners of defeased Bonds shall have the right to receive payment of the principal of
and interest on the defeased Bonds from the trust account. The City shall include in the
refunding or defeasance plan such provisions as the City deems necessary for the
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random selection of any defeased Bonds that constitute less than all of a particular
maturity of the Bonds, for notice of the defeasance to be given to the owners of the
defeased Bonds and to such other persons as the City shall determine, and for any
required replacement of Bond certificates for defeased Bonds. The defeased Bonds shall
be deemed no longer outstanding, and the City may apply any money in any other
fund or account established for the payment or redemption of the defeased Bonds to
any lawful purposes as it shall determine.
B. If the Bonds are registered in the name of DTC or its nominee, notice of any
defeasance of Bonds shall be given to DTC in the manner prescribed in the Letter of
Representations for notices of redemption of Bonds.
C. Notwithstanding anything in this section to the contrary, if the principal of
and /or interest due on the Bonds is paid by the Bond Insurer pursuant to the Financial
Guaranty Insurance Policy, the Bonds shall remain outstanding for all purposes, not be
defeased or otherwise satisfied and not be considered paid by the City, and all
covenants, agreements and other obligations of the City to the registered owners of the
Bonds shall continue to exist and run to the benefit of the bond Insurer, and the Bond
Insurer shall be subrogated to the rights of the registered owners.
Section 15. Bond Fund. The Bond Fund is created and established in the office of
the City Finance Director as a special fund designated the Limited Tax General
Obligation Bond Fund, 2008 (the "Bond Fund for the purpose of paying principal of
and interest on the Bonds. Accrued interest on the Bonds, if any, received from the sale
and delivery of those Bonds shall be paid into the Fund. All taxes collected for and
allocated to the payment of the principal of and interest on the Bonds shall be deposited
in the Bond Fund.
Section 16. Refunding of Refunded Bonds.
A. Appointnzent of Refunding Trustee. U.S. Bank National Association of Seattle,
Washington, is appointed Refunding Trustee.
B. Use of Bond Proceeds; Acquisition of Acquired Obligations. All of the proceeds of
the sale of the Bonds, exclusive of the accrued interest thereon (if any) which shall be
paid into the Bond Fund, shall be deposited immediately upon the receipt thereof with
the Refunding Trustee and used to discharge the obligations of the City relating to the
Refunded Bonds under Ordinance No. 1884 by providing for the payment of the
amounts required to be paid by the Refunding Plan. To the extent practicable, such
obligations shall be discharged fully by the Refunding Trustee's simultaneous purchase
of the Acquired Obligations, bearing such interest and maturing as to principal and
interest in such amounts and at such times so as to provide, together with a beginning
cash balance, if necessary, for the payment of the amount required to be paid by the
Refunding Plan. The Acquired Obligations are listed and more particularly described
in Exhibit A attached to the Refunding Trust Agreement between the City and the
Refunding Trustee, but are subject to substitution as set forth below. Any Bond
proceeds or other money deposited with the Refunding Trustee not needed to purchase
the Acquired Obligations and provide a beginning cash balance, if any, and pay the
costs of issuance of the Bonds shall be returned to the City at the time of delivery of the
Bonds to the initial purchaser thereof and deposited in the Bond Fund to pay interest on
the Bonds on the first interest payment date.
C. Substitution of Acquired Obligations. Prior to the purchase of any Acquired
Obligations by the Refunding Trustee, the City reserves the right to substitute other
direct, non callable obligations of the United States of America "Substitute
Obligations for any of the Acquired Obligations and to use any savings created
thereby for any lawful City purpose if,
1. in the opinion of Foster Pepper PLLC, the City's bond counsel, the interest
on the Bonds and the Refunded Bonds will remain excluded from gross income for
federal income tax purposes under Sections 103,148, and 149(d) of the Code; and
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2. such substitution shall not impair the timely payment of the amounts
required to be paid by the Refunding Plan, as verified by a nationally- recognized
independent certified public accounting firm.
D. After the purchase of the Acquired Obligations by the Refunding Trustee, the
City reserves the right to substitute therefor cash or Substitute Obligations subject to the
conditions that such money or securities held by the Refunding Trustee shall be
sufficient to carry out the Refunding Plan, that such substitution will not cause the
Bonds and the Refunded Bonds to be arbitrage bonds within the meaning of Section 148
of the Code and regulations thereunder in effect on the date of such substitution and
applicable to obligations issued on the issue date of the Bonds, and that the City obtain,
at its expense:
1. a verification by a nationally- recognized independent certified public
accounting firm acceptable to the Refunding Trustee confirming that the payments of
principal of and interest on the substitute securities, if paid when due, and any other
money held by the Refunding Trustee will be sufficient to carry out the Refunding Plan;
and
2. an opinion from Foster Pepper PLLC, bond counsel to the City, its
successor, or other nationally recognized bond counsel to the City, to the effect that the
disposition and substitution or purchase of such securities, under the statutes, rules,
and regulations then in force and applicable to the Bonds, will not cause the interest on
the Bonds or the Refunded Bonds to be included in gross income for federal income tax
purposes and that such disposition and substitution or purchase is in compliance with
the statutes and regulations applicable to the Bonds. Any surplus money resulting from
the sale, transfer, other disposition, or redemption of the Acquired Obligations and the
substitutions therefor shall be released from the trust estate and transferred to the City
to be used for any lawful City purpose.
E. Administration of Refunding Plan. The Refunding Trustee is authorized and
directed to purchase the Acquired Obligations (or substitute obligations) and to make
the payments required to be made by the Refunding Plan from the Acquired
Obligations (or substitute obligations) and money deposited with the Refunding
Trustee pursuant to this ordinance. All Acquired Obligations (or substitute obligations)
and the money deposited with the Refunding Trustee and any income therefrom shall
be held irrevocably, invested and applied in accordance with the provisions of
Ordinance No. 1884, this ordinance, chapter 39.53 RCW and other applicable statutes of
the State of Washington and the Refunding Trust Agreement. All necessary and proper
fees, compensation, and expenses of the Refunding Trustee for the Bonds and all other
costs incidental to the setting up of the escrow to accomplish the refunding of the
Refunded Bonds and costs related to the issuance and delivery of the Bonds, including
bond printing, verification fees, bond insurance premium, bond counsel's fees, and
other related expenses, shall be paid out of the proceeds of the Bonds.
F. Autliorization for Refunding Trust Agreement. To carry out the Refunding Plan
provided for by this ordinance, the Mayor or the Finance Director of the City is
authorized and directed to execute and deliver to the Refunding Trustee a Refunding
Trust Agreement substantially in the form on file with the City Clerk and by this
reference made a part hereof setting forth the duties, obligations and responsibilities of
the Refunding Trustee in connection with the payment, redemption, and retirement of
the Refunded Bonds as provided herein and stating that the provisions for payment of
the fees, compensation, and expenses of such Refunding Trustee set forth therein are
satisfactory to it. Prior to executing the Refunding Trust Agreement, the Mayor or
Finance Director of the City is authorized to make such changes therein that do not
change the substance and purpose thereof or that assure that the escrow provided
therein and the Bonds are in compliance with the requirements of federal law
governing the exclusion of interest on the Bonds from gross income for federal income
tax purposes.
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Section 17. Call for Redemption of the Refunded Bonds. The City calls for
redemption on December 1, 2009, all of the outstanding Refunded Bonds at a price of
par plus accrued interest. Such call for redemption shall be irrevocable after the
delivery of the Bonds to the initial purchaser thereof. The date on which the Refunded
Bonds are herein called for redemption is the first date on which those bonds may be
called. The proper City officials are authorized and directed to give or cause to be given
such notices as required, at the times and in the manner required, pursuant to
Ordinance No. 1884 in order to effect the redemption prior to their maturity of the
Refunded Bonds.
Section 18. City Findings with Respect to Refunding.
A. The City Council of the City finds and determines that the issuance and sale of
the Bonds at this time will effect a savings to the City and is in the best interest of the
City and its taxpayers and in the public interest. In making such finding and
determination, the City Council has given consideration to the fixed maturities of the
Bonds and the Refunded Bonds, the costs of issuance of the Bonds and the known
earned income from the investment of the proceeds of the issuance and sale of the
Bonds and other money of the City, if any, used in the Refunding Plan pending
payment and redemption of the Refunded Bonds.
B. The City Council further finds and determines that the money to be deposited
with the Refunding Trustee for the Refunded Bonds in accordance with Section 16 of
this ordinance will discharge and satisfy the obligations of the City under Ordinance
No. 1884 with respect to the Refunded Bonds, and the pledges, charges, trusts,
covenants, and agreements of the City therein made or provided for as to the Refunded
Bonds, and that the Refunded Bonds shall no longer be deemed to be outstanding
under such ordinance immediately upon the deposit of such money with the Refunding
Trustee.
Section 19. Approval of Bond Purchase Contract.
A. Seattle Northwest Securities Corporation of Seattle, Washington, has presented
a purchase contract (the "Bond Purchase Contract to the City offering to purchase the
Bonds under the terms and conditions provided in the Bond Purchase Contract, which
written Bond Purchase Contract is on file with the City Clerk and is incorporated herein
by this reference. The City Council finds that the purchase price offered is acceptable to
the City and that entering into the Bond Purchase Contract is in the City's best interest.
The City therefore approves the Bond Purchase Contract, accepts the offer contained
therein, and authorizes its execution by City officials.
B. The Bonds will be printed at City expense and will be delivered to the
purchaser in accordance with the Bond Purchase Contract, with the approving legal
opinion of Foster Pepper PLLC, municipal bond counsel of Seattle, Washington,
regarding the Bonds.
C. The proper City officials are authorized and directed to do everything
necessary for the prompt delivery of the Bonds to the purchaser and for the proper
application and use of the proceeds of the sale thereof. All prior actions taken by the
City consistent with the provisions of this ordinance are ratified, confirmed and
approved.
Section 20. Preliminary Official Statement Deemed Final. The City Council has
been provided with copies of a preliminary official statement dated November 24, 2008
(the "Preliminary Official Statement prepared in connection with the sale of the
Bonds and hereby ratifies and approves the distribution of that preliminary official
statement and the final official statement by the Bond purchaser. For the sole purpose
of the Bond purchaser's compliance with United States Securities and Exchange
Commission "SEC Rule 15c2- 12(b)(1), the City "deems final" that Preliminary Official
Statement as of its date, except for the omission of information as to offering prices,
interest rates, selling compensation, aggregate principal amount, principal amount per
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maturity, maturity dates, options of redemption, delivery dates, ratings and other terms
of the Bonds dependent on such matters.
Section 21. Undertaking to Provide Continuing Disclosure. To meet the
requirements of SEC Rule 15c2- 12(b)(5) (the "Rule as applicable to a participating
underwriter for the Bonds, the City makes the following written undertaking (the
"Undertaking for the benefit of holders of the Bonds:
A. Undertaking to Provide Annual Financial Information and Notice of Material
Events. The City undertakes to provide or cause to be provided, either directly or
through a designated agent:
1. To each nationally recognized municipal securities information
repository "NRMSIR designated by the SEC in accordance with the Rule and to a
state information depository, if any, established in the State of Washington (the "SID
annual financial information and operating data of the type included in the final official
statement for the Bonds and described in subsection (B) of this section "annual
financial information
2. To each NRMSIR or the Municipal Securities Rulemaking Board
"MSRB and to the SID, timely notice of the occurrence of any of the following events
with respect to the Bonds, if material:
a) principal and interest payment delinquencies;
b) non payment related defaults;
c) unscheduled draws on debt service reserves reflecting financial
difficulties;
d) unscheduled draws on credit enhancements reflecting financial
difficulties;
e) substitution of credit or liquidity providers, or their failure to
perform;
f) adverse tax opinions or events affecting the tax exempt status of
the Bonds;
g) modifications to rights of holders of the Bonds;
h) Bond calls (other than scheduled mandatory redemptions of Term
Bonds);
i) defeasances;
j) release, substitution, or sale of property securing repayment of the
Bonds; and
k) rating changes.
3. To each NRMSIR or to the MSRB, and to the SID, timely notice of a
failure by the City to provide required annual financial information on or before the
date specified in subsection (B) of this section.
B. Type of Annual Financial Information Undertaken to be Provided. The annual
financial information that the City undertakes to provide in subsection (A) of this
section:
1. Shall consist of:
a) annual financial statements prepared (except as noted in the
financial statements) in accordance with applicable generally accepted accounting
principles applicable to governmental units in Washington State, as such principles may
be changed from time to time and in conformity with state law and regulations
pertaining to cities, which statements shall not be audited, except, however, that if and
when audited financial statements are otherwise prepared and available to the City they
will be provided;
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b) authorized, issued and outstanding balance of general obligation
debt of the City;
c) the assessed value of the property within the City subject to ad
valorem taxation; and
d) ad valorem tax levy rates and amounts and percentage of taxes
collected.
2. Shall be provided to each NRMSIR and the SID, not later than the last
day of the ninth month after the end of each fiscal year of the City (currently, a fiscal
year ending December 31), as such fiscal year may be changed as required or permitted
by State law, commencing with the City's fiscal year ending December 31, 2008.
3. May be provided in a single or multiple documents, and may be
incorporated by reference to other documents that have been filed with each NRMSIR
and the SID, or, if the document incorporated by reference is a "final official statement"
with respect to other obligations of the City, that has been filed with the MSRB.
C. Amendment of Undertaking.
1) The Undertaking is subject to amendment after the primary offering of the
Bonds without the consent of any holder of any Bond, or of any broker, dealer,
municipal securities dealer, participating underwriter, rating agency, NRMSIR, the SID
or the MSRB, under the circumstances and in the manner permitted by the Rule.
2) The City will give notice to each NRMSIR or the MSRB, and the SID, of the
substance (or provide a copy) of any amendment to the Undertaking and a brief
statement of the reasons for the amendment. If the amendment changes the type of
annual financial information to be provided, the annual financial information
containing the amended financial information will include a narrative explanation of
the effect of that change on the type of information to be provided.
D. Beneficiaries. The Undertaking evidenced by this section shall inure to the
benefit of the City and any holder of Bonds, and shall not inure to the benefit of or
create any rights in any other person.
E. Termination of Undertaking. The City's obligations under this Undertaking shall
terminate upon the legal defeasance of all of the Bonds. In addition, the City's
obligations under this Undertaking shall terminate if those provisions of the Rule which
require the City to comply with this Undertaking become legally inapplicable in respect
of the Bonds for any reason, as confirmed by an opinion of nationally- recognized bond
counsel or other counsel familiar with federal securities laws delivered to the City, and
the City provides timely notice of such termination to each NRMSIR or the MSRB and
the SID.
F. Remedy for Failure to Comply with Undertaking. As soon as practicable after the
City learns of any failure to comply with the Undertaking, the City will proceed with
due diligence to cause such noncompliance to be corrected. No failure by the City or
other obligated person to comply with the Undertaking shall constitute a default in
respect of the Bonds. The sole remedy of any holder of a Bond shall be to take such
actions as that holder deems necessary, including seeking an order of specific
performance from an appropriate court, to compel the City or other obligated person to
comply with the Undertaking.
G. Designation of Official Responsible to Administer Undertaking. The Finance
Director of the City (or such other officer of the City who may in the future perform the
duties of that office) or his or her designee is authorized and directed in his or her
discretion to take such further actions as may be necessary, appropriate or convenient
to carry out the Undertaking of the City in respect of the Bonds set forth in this section
and in accordance with the Rule, including, without limitation, the following actions:
1. Preparing and filing the annual financial information undertaken to be
provided;
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2. Determining whether any event specified in subsection (A) has occurred,
assessing its materiality with respect to the Bonds, and, if material, preparing and
disseminating notice of its occurrence;
3. Determining whether any person other than the City is an "obligated
person" within the meaning of the Rule with respect to the Bonds, and obtaining from
such person an undertaking to provide any annual financial information and notice of
material events for that person in accordance with the Rule;
4. Selecting, engaging and compensating designated agents and consultants,
including but not limited to financial advisors and legal counsel, to assist and advise the
City in carrying out the Undertaking; and
5. Effecting any necessary amendment of the Undertaking.
H. Centralized Dissemination Agent. To the extent authorized by the SEC, the City
may satisfy the Undertaking by transmitting the required filings using
http: /www.disclosureusa.org (or such other centralized dissemination agent as may
be approved by the SEC).
22. Bond Insurance. The City Council finds that it is in the City's best interest to
purchase, and that a savings will result from purchasing, the Financial Guaranty
Insurance Policy for the Bonds. The City shall purchase from the Bond Insurer the
Financial Guaranty Insurance Policy insuring the prompt payment of the principal of
and interest on the Bonds and agrees to the conditions for obtaining that policy,
including the payment of the premium therefor. The Mayor is authorized to execute on
behalf of the City a commitment for the purchase of the Financial Guaranty Insurance
Policy, including such terms as he deems appropriate and consistent with the purposes
of this ordinance, and any and all other documents required or requested in connection
with the Financial Guaranty Insurance Policy.
23. Severability. If any section, subsection, paragraph, sentence, clause or phrase
of this ordinance or its application to any person or situation should be held to be
invalid or unconstitutional for any reason by a court to competent jurisdiction, such
invalidity or unconstitutionality shall not affect the validity or constitutionality of the
remaining portions of this ordinance or its application to any other person or situation.
24. Effective Date. This ordinance or a summary thereof shall be published in the
official newspaper of the City, and shall take effect and be in full force five days after
passage and publication as provided by law.
PASSED BY THE CITY COUNCIL OF THE CIT,OF TUKWILA, WASHINGTON,
at a Regular Meeting thereof this day of 1 l -0 b-0 2008.
ATTEST/ AUTHENTICATED: n
v
r ,�or
Christy O'Flaherty, CMC, City Clerk v
Filed with the City Clerk:
APPROV AST ORM BY: Passed by the City Council:
Published: 1 t,/ ZAP
Effective Date: 1 r rl
Offi of th�ttorney Ordinance Number: 1
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CERTIFICATION
I, the undersigned, City Clerk of the City of Tukwila, Washington (the "City
hereby certify as follows:
1. The attached copy of Ordinance No. (e (the "Ordinance is a full,
true and correct copy of an ordinance duly passed at a regular meeting thereof on
D 0- 0, M hrr I 20_f") V as that ordinance appears
on the minute book of the City; and the Ordinance will be in full force and effect five
days after publication in the City's official newspaper as provided by law; and
2. A quorum of the members of the City Council was present throughout the
meeting and a majority of those members present voted in the proper manner for the
passage of the Ordinance.
IN WITNESS WHEREOF, I have hereunto set my hand this day
of r c.., b or 20--OW
CITY OF TUKWILA, WASHINGTON
1
Christy O'Flaherty, CMC, City Clerk a
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