Res 2010- 63 Sale of Rev Funding Note St Thomas Academy Series 2010Resolution No. 10 -63
A RESOLUTION PROVIDING FOR THE ISSUANCE AND SALE OF
EDUCATIONAL FACILITIES REVENUE REFUNDING NOTE
(ST. THOMAS ACADEMY PROJECT), SERIES 2010
WHEREAS,
(a) Minnesota Statutes, Sections 469.152 through 469.1651, as amended (the
"Act "), confers upon cities the power to issue revenue bonds for the purpose of the
encouragement and development of economically sound industry and commerce to prevent so far
as possible the emergence of blighted and marginal lands and areas of chronic unemployment;
and
(b) The City Council of the City of Mendota Heights, Minnesota (the "City ")
has received from St. Thomas Academy, a Minnesota nonprofit corporation organized under the
laws of the State of Minnesota and a 501(c)(3) organization (the "Borrower "), a proposal that the
City assist in refinancing a project hereinafter described through the issuance of a revenue note,
pursuant to the Act; and
(c) In authorizing refinancing of the Project (as hereinafter defined), and the
issuance of the Note (as hereinafter defined), the City's purpose is, and in its judgment the effect
thereof will be, to promote the public welfare by providing educational facilities within the
meaning of the Act, such purpose to be accomplished in the manner and upon the terms and
conditions set forth in the Act and in this Resolution; and
(d) The project to be financed by the revenue note is the refunding of the
City's outstanding Variable Rate Demand Purchase Revenue Bonds (St. Thomas Academy
Project) Series 1999 (the "Refunded Bonds "), which were issued to finance the acquisition,
construction, and equipping of a middle school addition and the renovation and remodeling of
the Borrower's existing educational facilities, including the acquisition of unimproved land
adjacent thereto and the expansion of a parking lot (the "Project "). The Project will be owned
and operated by the Borrower; and
(e) The City has been advised by representatives of the Borrower that without
the aid of municipal financing, and its resulting low borrowing cost, the Project and the provision
of the services offered in connection therewith is not economically feasible; and
(f) No public official of the City has either a direct or indirect financial
interest in the Project nor will any public official either directly or indirectly benefit financially
from the Project.
BE IT RESOLVED by the City Council of the City of Mendota Heights (the "City "), as
follows:
SECTION 1 LEGAL AUTHORIZATION AND FINDINGS.
2590986v2
1.1 Findings. The City hereby finds, determines and declares as follows:
(a) The City is a municipal corporation and a political subdivision of the State
of Minnesota and is authorized under the Act to assist the project herein referred to, and
to issue and sell the Note for the purpose, in the manner and upon the terms and
conditions set forth in the Act and in this Resolution.
(b) As required by the Act and Section 147(f) of the Internal Revenue Code of
1986, as amended (the "Code "), the City on the date hereof, held a public hearing on the
issuance of one or more series of revenue bonds or other obligations to finance the
Proj ect.
(c) The issuance and sale of the Educational Facilities Revenue Refunding
Note (St. Thomas Academy Project) Series 2010 (the "Note ") in an amount not to exceed
$6,500,000 by the City, pursuant to the Act, is in the best interest of the City, and the City
hereby determines to issue the Note and sell the Note to U.S. Bank National Association
(the "Lender "), as provided herein. The City will loan the proceeds of the Note (the
"Loan") to the Borrower in order to finance the Project.
(d) Pursuant to a Loan Agreement (the "Loan Agreement ") to be entered into
between the City and the Borrower, the Borrower has agreed to repay the Note in
specified amounts and at specified times sufficient to pay in full when due the principal
of, premium, if any, and interest on the Note. In addition, the Loan Agreement contains
provisions relating to the maintenance and operation of the Project, indemnification,
insurance, and other agreements and covenants which are required or permitted by the
Act and which the City and the Borrower deem necessary or desirable for the financing
of the Project. A draft of the Loan Agreement has been submitted to the City Council.
(e) Pursuant to the Loan Agreement the proceeds of the Note will be
disbursed to the Borrower for the Project.
(f) Pursuant to a Pledge Agreement to be entered into between the City and
the Lender, the City has pledged and granted a security interest in all of its rights, title,
and interest in the Loan Agreement to the Lender (except for certain rights of
indemnification and to reimbursement for certain costs and expenses). A draft of the
Pledge Agreement has been submitted to the City Council.
(g) The Note will be a special limited obligation of the City. The Note shall
not be payable from or charged upon any funds other than the revenues pledged to the
payment thereof, nor shall the City be subject to any liability thereon. No holder of the
Note shall ever have the right to compel any exercise of the taxing power of the City to
pay the Note or the interest thereon, nor to enforce payment thereof against any property
of the City. The Note shall not constitute a debt of the City within the meaning of any
constitutional or statutory limitation.
(h) It is desirable, feasible and consistent with the objects and purposes of the
Act to issue the Note, for the purpose of financing the costs of the Project.
2
2590986v2
1.2 Authorization and Ratification of Project. The City has heretofore and does
hereby authorize the Borrower, in accordance with the provisions of the Act and subject to the
terms and conditions imposed by the Lender, to provide for the financing of the Project by such
means as shall be available to the Borrower and in the manner determined by the Borrower and
without advertisement for bids as may be required for the construction and acquisition of other
municipal facilities; the City hereby ratifies, affirms, and approves all actions heretofore taken by
the Borrower consistent with and in anticipation of such authority; and the Borrower is hereby
authorized to make such expenditures and advances toward redemption of the Refunded Bonds
to be financed from the proceeds of the Note as the Borrower considers necessary, if and when
delivered, but otherwise without liability on the part of the City.
SECTION 2 THE NOTE.
2.1 Authorized Amount and Form of Note. The Note issued pursuant to this
Resolution shall be in substantially the form submitted to the City Council with such appropriate
variations, omissions and insertions as are necessary and appropriate and are permitted or
required by this Resolution, and in accordance with the further provisions hereof; and the total
aggregate principal amount of the Note that may be outstanding hereunder is expressly limited to
$6,500,000, unless a duplicate Note is issued pursuant to Section 2.7. The Note shall bear
interest at a variable rate as set forth therein.
2.2 The Note. The Note shall be dated as of the date of delivery to the Lender, shall
be payable at the times and in the manner, shall bear interest at the rate, and shall be subject to
such other terms and conditions as are set forth therein.
2.3 Execution. The Note shall be executed on behalf of the City by the signatures of
its Mayor and City Administrator and shall be sealed with the seal of the City; provided that the
seal may be intentionally omitted as provided by law. In case any officer whose signature shall
appear on the Note shall cease to be such officer before the delivery of the Note, such signature
shall nevertheless be valid and sufficient for all purposes, the same as if had remained in office
until delivery. In the event of the absence or disability of the Mayor or City Administrator, such
officers of the City as, in the opinion of the city attorney, may act on his or her behalf, shall
without further act or authorization of the City Council execute and deliver the Note.
2.4 Delivery of Initial Note. Before delivery of the Note there shall be filed with the
Lender (except to the extent waived by the Lender) the following items:
(1) an executed copy of each of the following documents:
(a) the Loan Agreement; and
(b) the Pledge Agreement;
(2) an opinion of Counsel for the Borrower as prescribed by the Lender and
Bond Counsel;
(3) the opinion of Bond Counsel as to the validity and tax exempt status of the
Note;
2590986v2
3
(4) a 501(c)(3) determination letter or comparable evidence from the Internal
Revenue Service evidencing that the Borrower is exempt from income taxation under
Section 501(c)(3) of the Code; and
(5) such other documents and opinions as Bond Counsel may reasonably
require for purposes of rendering its opinion required in subsection (3) above or that the
Lender may reasonably require for the closing.
2.5 Disposition of Proceeds of the Note. Upon delivery of the Note to Lender, the
Lender shall, on behalf of the City, disburse the proceeds of the Note for payment of Project
Costs in accordance with the terms of the Loan Agreement.
2.6 Registration of Transfer. The City will cause to be kept at the office of the City
Clerk a Note Register for the Note in which, subject to such reasonable regulations as it may
prescribe, the City shall provide for the registration of transfers of ownership of the Note. The
Note shall be initially registered in the naive of the Lender and shall be transferable upon the
Note Register by the Lender in person or by its agent duly authorized in writing, upon suurender
of the Note together with a written instrument of transfer satisfactory to the City Clerk, duly
executed by the Lender or its duly authorized agent. The following form of assignment shall be
sufficient for said purpose.
For value received hereby sells, assigns and transfers unto
the within Note of the City of Mendota Heights, Minnesota, and does hereby
irrevocably constitute and appoint attorney to transfer said Note on the
books of said City with full power of substitution in the premises. The undersigned certifies that
the transfer is made in accordance with the provisions of Section 2.9 of the Resolution
authorizing the issuance of the Note.
Dated:
Registered Owner
Upon such transfer the City Clerk shall note the date of registration and the name and address of
the new holder in the applicable Note Register and in the registration blank appearing on the
Note.
2.7 Mutilated, Lost or Destroyed Note. In case any Note issued hereunder shall
become mutilated or be destroyed or lost, the City shall, if not then prohibited by law, cause to
be executed and delivered, a new Note of like outstanding principal amount, number and tenor in
exchange and substitution for and upon cancellation of such mutilated Note, or in lieu of and in
substitution for such Note destroyed or lost, upon the Lender's paying the reasonable expenses
and charges of the City in connection therewith, and in the case of a Note destroyed or lost, the
filing with the City of evidence satisfactory to the City with indemnity satisfactory to it. If the
mutilated, destroyed or lost Note has already matured or been called for redemption in
accordance with its terms it shall not be necessary to issue a new Note prior to payment.
2.8 Ownership of Note. The City may deem and treat the person in whose name the
Note is last registered in the applicable Note Register and by notation on the applicable Note
4
2590986v2
whether or not such Note shall be overdue, as the absolute owner of such Note for the purpose of
receiving payment of or on account of the Principal Balance, redemption price or interest and for
all other purposes whatsoever, and the City shall not be affected by any notice to the contrary.
2.9 Limitation on Note Transfers. The Note will be issued to an "accredited investor"
and without registration under state or other securities laws, pursuant to an exemption for such
issuance; and accordingly the Note may not be assigned or transferred in whole or part, nor may
a participation interest in the Note be given pursuant to any participation agreement, except to
another "accredited investor" or "financial institution" in accordance with an applicable
exemption from such registration requirements and with full and accurate disclosure of all
material facts to the prospective purchaser(s) or transferee(s).
2.10 Issuance of New Notes. Subject to the provisions of Section 2.9, the City shall, at
the request and expense of the Lender, issue new notes, in aggregate outstanding principal
amount equal to that of the Note surrendered, and of like tenor except as to number, principal
amount, and the amount of the monthly installments payable thereunder, and registered in the
name of the Lender or such transferee as may be designated by the Lender.
SECTION 3 GENERAL COVENANTS
3.1 Payment of Principal and Interest. The City covenants that it will promptly pay or
cause to be paid the principal of and interest on the Note at the place, on the dates, solely from
the source and in the manner provided herein and in the Note. The principal and interest are
payable solely from and secured by revenues and proceeds derived from the Loan Agreement
and the Pledge Agreement, which revenues and proceeds are hereby specifically pledged to the
payment thereof in the manner and to the extent specified in the Note, the Loan Agreement, and
the Pledge Agreement; and nothing in the Note or in this Resolution shall be considered as
assigning, pledging or otherwise encumbering any other funds or assets of the City.
3.2 Performance of and Authority for Covenants. The City covenants that it will
faithfully perform at all times any and all covenants, undertakings, stipulations and provisions
contained in this Resolution, in the Note executed, authenticated and delivered hereunder and in
all proceedings of the City Council pertaining thereto; that it is duly authorized under the
Constitution and laws of the State of Minnesota including particularly and without limitation the
Act, to issue the Note authorized hereby, pledge the revenues and assign the Loan Agreement in
the manner and to the extent set forth in this Resolution, the Note, the Loan Agreement, and the
Pledge Agreement, that all action on its part for the issuance of the Note and for the execution
and delivery thereof has been duly and effectively taken; and that the Note in the hands of the
Purchaser is and will be a valid and enforceable special limited obligation of the City according
to the terms thereof.
3.3 Enforcement and Performance of Covenants. The City agrees to enforce all
covenants and obligations of the Borrower under the Loan Agreement upon request of the
Lender and being indemnified to the satisfaction of the City for all expenses and claims arising
therefrom, and to perform all covenants and other provisions pertaining to the City contained in
the Note and the Loan Agreement and subject to Section 3.4.
5
2590986v2
3.4 Nature of Security. Notwithstanding anything contained in the Note, the Loan
Agreement, the Pledge Agreement or any other document referred to in Section 2.4 to the
contrary, under the provisions of the Act, the Note may not be payable from or be a charge upon
any funds of the City other than the revenues and proceeds pledged to the payment thereof, nor
shall the City be subject to any liability thereon, nor shall the Note otherwise contribute or give
rise to a pecuniary liability of the City or, to the extent permitted by law, any of the City's
officers, employees and agents. No holder of the Note shall ever have the right to compel any
exercise of the taxing power of the City to pay the Note or the interest thereon, or to enforce
payment thereof against any property of the City other than the revenues pledged under the
Pledge Agreement; and the Note shall not constitute a charge, lien or encumbrance, legal or
equitable, upon any property of the City; and the Note shall not constitute a debt of the City
within the meaning of any constitutional or statutory limitation; but nothing in the Act impairs
the rights of the Lender to enforce the covenants made for the security thereof as provided in this
Resolution, the Loan Agreement, and the Pledge Agreement, and in the Act, and by authority of
the Act the City has made the covenants and agreements herein for the benefit of the Lender;
provided that in any event, the agreement of the City to perform or enforce the covenants and
other provisions contained in the Note, the Loan Agreement, and the Pledge Agreement shall be
subject at all times to the availability of revenues under the Loan Agreement sufficient to pay all
costs of such performance or the enforcement thereof, and the City shall not be subject to any
personal or pecuniary liability thereon.
SECTION 4 MISCELLANEOUS.
4.1 Severability. If any provision of this Resolution shall be held or deemed to be or
shall, in fact, be inoperative or unenforceable as applied in any particular case in any jurisdiction
or jurisdictions or in all jurisdictions or in all cases because it conflicts with any provisions of
any constitution or statute or rule or public policy, or for any other reason, such circumstances
shall not have the effect of rendering the provision in question inoperative or unenforceable in
any other case or circumstance, or of rendering any other provision or provisions herein
contained invalid, inoperative, or unenforceable to any extent whatever. The invalidity of any
one or more phrases, sentences, clauses or paragraphs in this Resolution contained shall not
affect the remaining portions of this Resolution or any part thereof.
4.2 Authentication of Transcript. The officers of the City are directed to furnish to
Bond Counsel certified copies of this Resolution and all documents referred to herein, and
affidavits or certificates as to all other matters which are reasonably necessary to evidence the
validity of the Note. All such certified copies, certificates and affidavits, including any
heretofore furnished, shall constitute recitals of the City as to the correctness of all statements
contained therein.
4.3 Authorization to Execute Agreements. The forms of the proposed Loan
Agreement, the Pledge Agreement, and the Note are hereby approved in substantially the form
heretofore presented to the City Council, together with such additional details therein as may be
necessary and appropriate and such modifications thereof, deletions therefrom and additions
thereto as may be necessary and appropriate and approved by Bond Counsel prior to the
execution of the documents, and the Mayor and City Administrator are authorized to execute the
Loan Agreement and the Pledge Agreement in the name of and on behalf of the City and such
6
2590986v2
other documents as Bond Counsel consider appropriate in connection with the issuance of the
Note. In the event of the absence or disability of the Mayor or City Administrator, such officers
of the City as, in the opinion of the City Attorney, may act on his or her behalf, shall without
further act or authorization of the City do all things and execute all instruments and documents
required to be done or executed by such absent or disabled officers. The execution of any
instrument by the appropriate officer or officers of the City herein authorized shall be conclusive
evidence of the approval of such documents in accordance with the terms hereof.
7
2590986v2
Adopted by the City Council of the City of Mendota Heights, this 17th day of August,
2010.
ATTEST:
BY
Nam,
2590986v2
Acting City Clerk
CITY COUNCIL
CITY OF MENDOTA HEIGHTS
8
STATE OF MINNESOTA )
) ss.
COUNTY OF DAKOTA )
I, the undersigned, being the duly qualified and acting City Clerk of the City of Mendota
Heights (the "City "), do hereby certify that attached hereto is a compared, true and correct copy
of a resolution giving final approval to an issuance of a revenue Note by the City on behalf of St.
Thomas Academy, duly adopted by the City Council of the City on August 17, 2010, at a regular
meeting thereof duly called and held, as on file and of record in my office, which resolution has
not been amended, modified or rescinded since the date thereof, and is in full force and effect as
of the date hereof, and that the attached Extract of Minutes as to the adoption of such resolution
is a true and accurate account of the proceedings taken in passage thereof.
WITNESS My hand this l� —day of August, 2010.
Acting Ci \Clerk
9
2590986v2