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LOAN AGREEMENT BETWEEM RE $98000 LOAN ON VOGEL PROPERTY It 3 2, 'I - '. ,! ~ ...., ..I- - .,"'; EXHIB[T B -, I', This Loan Agreement cokstitutes an lnterlocal Agreement Under Chapter 163.01, Florida Statutes 01 iU:C09'lr 0 R F( / 2 ' fb ].., . HI" 1\i, i- f' I Rt~'~ T~jTA~V LOAN AGREEMENT between SUN BANK, NATIONAL ASSOCIATION as Trustee OR ~ 9 I 2 PG : 4 9 7 1i It J./C-LC'a. 'f--u-- 1/, 1 / (,l. UL4 t '- JACKSON C. TU'M'LE, City Mana~r acting as Administrator ' 1'1.,)4Q20,)5 \lEl'I 'ri1-\l4-6'J 12 ,''; THE CITY OF CLEARWATER, FLORIDA ;l1 "i:.~':C?!) II'K~ I':;~::,'")' +'!rfT TOTAL: "::;-.;r,fR~j) : :-H~r~E : a municipal corporation of the State of Florida City of Gulf Breeze, Florida Local Government Loan Program Series 1985C . $980,000 Loan for Vogel Property Dated as of December 1, 1988 v C ,,'1,~ ,-/-0 Q (t) ':"? ,~ c- :-::- :z: I en -0 - -- o Prepared h1 & ~~ -It,: \.. Daniel U. Livermore, Jr. '" Livermore Klein & Lott, P. A. 1750 Gulf Life Tower Jack.oaville, Florida 32201 Phone: (904) 399-0500 t -;; 1 ~.~ c, '~-:: ~. .' ':& : :' ,; , . . " ':-:x :~~;; '--, =" :- ;::0::;' >-T1= V:~~ .:; 33 :.- ==~;;; :;:=~ ~~r :<<.".\,') > =:S~ ,00-/5'/ -D 0 & J TABLE OF CONTENTS CITY OF GULF BREEZE, FLORIDA LOCAL GOVERNMENT LOAN PROGRAM LOAN AGREEMENT Parties and Recitals ......................................................... 1 Section 1.1 Section 1.2 Section 1.3 Section 1.4 Section 1.5 Section 2.1 Section 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5 Section 3.6 Section 3.7 Section 3.8 Section 3.9 Section 3.10 Section 3.11 Section 3.12 ARTICLE I BACKGROUND AND REPRESENTATIONS Background .................................................. 1 Representations of Governmental Unit . . . . . . . . . . . . . . . . . . . . . . . . . 2 Sponsor Representations ....................................... 3 Administrator Representations ................................. 3 Trustee Representations ....................................... 3 ARTICLE n DEFINITIONS Definitions .................................................. 4 ARTICLE ill FINANCING THE PROJECT Making of Loan; Application of Loan Proceeds .................... Disbursement of Loan; Security Int'erest in Undisbursed Proceeds ......................................... Repayment of Loan ........................................... Prepayment of Loan .........'................................. 6 6 6 8 8 9 Administrative Expenses ............ . . . . . . . . . . . . . . . . . . . . . . . . . . Special Obligation of Governmental Units ........................ Benefit of Bondholders and Enhancement Provider; Compliance with Trust Indenture . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11 Bonds Not to Become Arbitrage Bonds ........................... 11 Assignment of Sponsor's Rights ................................. 11 Covenant Regarding Pledged Revenues; Revenue Fund ................................................ 11 Alternate Security for Governmental Unit Note .................. 12 Inter local Agree m ent ......................................... 13 -i- Section 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6 Section 5.1 Section 5.2 Section 5.3 Section 5.4 Section 5.5 Section 5.6 Section 5.7 Section 6.1 Section 6.2 Section 6.3 Section 6.4 Section 6.5 Section 6.6 Section 6.7 Section 6.8 Section 6.9 Section 6.10 Exhibit "A" Exhibit "B" Exhibit "C" Exhibit "D" I ARTICLE IV I COVENANTS OF THE GOVERNMENTAL UNIT Reports and Opinions; Inspections ............................... 14 Immunity of Sponsor .......................................... 14 Compliance with Laws ........................................ 15 Issuance of Other Obligations Payable from Pledged Revenues ................................ 15 Issuance of Additional Parity Bonds ............................. 16 Additional Covenants ......................................... 17 ARTICLE V EVENTS OF DEFAULT AND REMEDIES Events of Default ............................................ 18 Acceleration' . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19 Payment of Loan on Default; Suit Therefor ...................... 19 Other Remedies .............................................. 20 Cumulative Rights............................... .......... ... 21 Discontinuance of Proceedings ................................. 21 Notice of Default ............................................ 21 ARTICLE VI MISCELLANEOUS Limitation of Liability ........................................ 22 No Personal Recourse ......................................... 22 22 23 23 23 23 23 23 23 Notices .....................................'................ Illegal or Invalid Provisions Disregarded ......................... Applicable Law .............................................. Assignments .................................................. Amendments ................................................. Term of Agreement ........................................... Headings .................................................... Superseding Clause . ............ ...... ...... .... ...... ...... Project Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 27 Promissory Note . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 General Certificate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33 Opinion of Governmental Unit Counsel . . . . . . . . . . . . . . . . . . . . . . . .. 39 -ii- j I TIllS LOAN AGREEMENT, dated December 1, 1988, between SUN BANK, NATIONAL ASSOCIATION, Orlando, Florida, as Trustee for the holders of the Bonds (as defined herein), JACKSON C. TUTILE, City Manager, acting on behalf of City of Gulf Breeze, Florida (the "Administrator") and THE CITY OF CLEARWATER, FLORIDA, a municipal corporation organized and duly existing under the laws of the State of Florida (the "Governmental Unit"), witnesseth as follows: ARTICLE I BACKGROUND AND REPRESENTATIONS SECTION 1.1 BACKGROUND. (a) The City of Gulf Breeze, a municipal corporation of the State of Florida, as issuer of the Bonds hereinafter referred to as the "Sponsor", is authorized to exercise those powers conferred by Chapters 166 and 163, Florida Statutes, as amended. (b) The Sponsor has issued $100,000,000 aggregate principal amount of its Local Government Loan Program Floating Rate Demand Revenue Bonds, Series 1985 C (the "Bonds") the proceeds of which are to be used for the purpose of financing and refinancing the cost of the acquisition and installation by "Governmental Units", as hereinafter defined, of qualified Projects as described herein (the "Program"). The Bonds are issued under and are secured by the Trust Indenture dated as of December 1, 1985, as amended and restated as of July 1, 1986, as further amended and supplemented (the "Indenture") between the Sponsor and Sun Bank, National Association, Orlando, Florida, as Trustee (the "Trustee"). Except as otherwise provided herein, all capitalized terms used herein which are defined in the Indenture shall have the meanings set forth in the Indenture. (c) Pursuant to the Indenture, the Sponsor has caused the net proceeds of the Bonds to be deposited with the Trustee, to be used to make loans to Governmental Units for the financing or refinancing of the Projects. (d) Under the Indenture, the Sponsor has pledged, for the security and repayment of the Bonds, inter alia, the amounts to be received in repayment of the Loans, in the manner set forth in the Indenture. (e) For the additional security for the payment of the principal of the Bonds, the Sponsor has caused to be delivered to the Trustee a Bond Insurance Policy (the "Credit Facility") initially issued by Financial Guaranty Insurance Company (which, together with any issuer of a substitute Credit Facility, is referred to as the "Credit Facility Issuer") pursuant to which it has agreed to make available funds for the timely payment of the principal and interest on the Bonds (the Credit Facility and any substitute Credit Facility as defined in the Indenture hereinafter referred to as the "Credit Facility"). (f) For the purpose of prDviding the Bond Registrar and Paying Agent (as defined in the Indenture) with funds for the purchase at the principal amount thereof plus accrued interest on Bonds tendered to it for payment pursuant to the Indenture, and not remarketed in accordance with the provisions thereof, the Sponsor has entered into a LKL-1I/16/88-267 AA-2821 Rev.1I/30/88 Rev.I2/07/88 -1- Standby Bond Purchase aid Revolving Credit Agreement datel as of April 1, 1988 (the "Liquidity Facility") with COGB Liquidity Corporation and The Bank of Tokyo, Ltd., New York Agency (collectively, the "Liquidity Facility Issuer") and the Trustee, pursuant to which the Liquidity Facility Issuer will agree to purchase Bonds at the principal amount thereof (up to the aggregate principal amount of Bonds outstanding), together with accrued interest, to the extent that moneys are not otherwise available therefor under the terms of the Indenture. (g) The Administrator has approved the Loan and has approved a commit- ment (the "Commitment") to make a loan in the amount of $980,000 (the "Loan") for the purpose of financing the original cost of acquisition of the project identified on Exhibit A attached hereto, which shall hereinafter collectively be referred to as the "Project". (h) As evidence of the Loan made pursuant to this Agreement, the Govern- mental Unit will execute and deliver a note in the principal amount of the Loan in the form attached hereto as Exhibit B (the "Governmental Unit Note"). As security for the Bonds, the Sponsor is assigning to the Trustee all its right, title and interest in the Governmental Unit Note and this Agreement (except for the rights reserved by the Sponsor as described in Section 3.9 hereof). Pursuant to the Indenture, the Governmental Unit Note and this Agreement may be assigned by the Trustee to the Credit Facility Issuer under the circumstances set forth therein. SECTION 1.2 REPRESENTATIONS OF GOVERNMENTAL UNIT. (a) The Governmental Unit is a municipal corporation of the State of Florida, with full power and legal right to enter into this Agreement and perform its obligations hereunder, and to finance the Project in the manner contemplated herein. The Governmental Unit's actions in making and performing this Agreement have been duly authorized by all necessary official action and will not violate or conflict with any applicable provision of the Constitution, or law of the State of Florida or with any ordinance, governmental rule or regulation, or with any agreement, instrument or other document by which the Governmental Unit or its funds or properties are bound. (b) The amount of the Loan, less anticipated investment earnings, does not exceed the "Cost" of the Project (as defined in the Indenture). (c) No portion of the proceeds of the Loan will be used to finance any Project which is used in the trade or business of a person who is not an "exempt person" as defined in Section 103(b)(3) of the Code. (d) Immediately after the execution hereof, no Event of Default shall exist hereunder nor shall there exist any condition which with lapse of time, the giving of notice, or both, would constitute an Event of Default hereunder. (e) The Governmental Unit is duly authorized and empowered under the laws of the State of Florida, particularly Chapter 166, Part II, Florida Statutes, to enter into this Agreement, to issue the Governmental Unit Note and to pledge the sources hereinafter mentioned to the repayment thereof, and to apply the proceeds thereof to the payment of the Costs of the Project. LKL-ll/16/88-267 AA-2821 -2- j I (f) On December 15. 1988, the Governmental Unit duly enacted Ordinance No. 4728-88 (the "Authorizing Ordinance") authorizing the borrowing contemplated hereby, and the terms and provisions of the Authorizing Ordinance are hereby incorporated by reference. (g) Neither the Governmental Unit nor any related person to such Govern- mental Unit will, pursuant to any arrangement, formal or informal, purchase any Bonds in an amount related to the Loan from the Program to the Governmental Unit. (h) The Governmental Unit. is in compliance with all covenants and under- takings in connection with all debt obligations payable from the Pledged Revenues herein defined, or any part th~reof. SECTION 1.3 SPONSOR REPRESENTATIONS. The Sponsor represents that it is a municipal corporation of the State of Florida duly existing, and with full power and authority to issue the Bonds and to enter into this Agreement. By proper action the Sponsor has duly authorized the issuance and sale of the Bonds and the execution and delivery of this Agreement. In accordance with the Indenture, the Sponsor has appointed the Administrator t<> execute, undertake and perform the Sponsor's duties hereunder; and all actions taken by the Administrator on behalf of the Sponsor pursuant to such appointment shall be deemed to be the action of the Sponsor. SECTION 1.4 ADMINISTRATOR REPRESENTATIONS. The Administrator represents that he has duly authorized the execution and delivery of this Agreement. In accordance with the Indenture, the Sponsor has appointed the Adminstrator to execute, undertake and perform the Sponsor's duties hereunder either personally or through the Independent Contractor; and all actions taken by the Administrator or the Independent Contractor on behalf of the Sponsor pursuant to such appointment shall be deemed to be the action of the Sponsor. SECTION 1.5 TRUSTEE REPRESENTATIONS. The Trustee represents that it is a national banking association duly existing, and with full power and authority to enter into this Agreement and perform its obligations hereunder on behalf of the holders of the Bonds. By proper action the Trustee has duly authorized the execution and delivery of this Agree ment and the Indenture. LKL-12/07 /88-267 AA-2821 -3- J I ARTICLE IT DEFINITIONS SECTION 2.1 DEFINITIONS. The capitalized terms used herein which are defined in the Indenture and in the Authorizing Ordinance shaH have the meanings assigned thereto in the Indenture and in the Authorizing Ordinance, unless the context hereof expressly requires otherwise. In addition, the following terms shall have the meanings defined as follows: "Additional Parity Bonds" shall mean Additional Parity Bonds issued under the terms, conditions and provisions hereof. Loan. "Commitment" means the commitment of the Administrator to make the "Costs and Expenses of the Program" shall mean the fees and expenses of the Trustee, the Liquidity Facility Issuer, the Credit Facility Issuer, the Remarketing Agent, the Administrator, the Independent Contractor, the Registrar and Paying Agent, and the Issuer, including the fees and expenses of general or special counsel to any of the foregoing, and shall include, without limitation of the foregoing, all amounts provided in Section 3.5 hereof. "Cost" or "Costs" in connection with the acquisition and/or construction of any Project, means any cost incurred or estimated to be incurred by the Governmental Unit which is reasonable and necessary for carrying out all works and undertakings in providing and constructing or acquiring such Project for the Governmental Unit, including the construction of the Project, the cost of necessary studies, surveys, plans and specifica- tions, architectural, engineering, legal or other special services, including the fees and expenses of bond counsel, development, construction and reconstruction necessary or useful in connection with the construction of the Project, the reasonable cost of financing incurred by the Governmental Unit or the Sponsor in connection with the execution of the Loan Agreement, or in the course of the acquisition and/or construction of the Project, including reimbursement to the Administrator for its out-of-pocket expenses and including capitalized interest on any Loan disbursed in stages, and the cost of such other items as may be reasonable and necessary for the acquisition and/or construction of the Project. "Local Credit Enhancement" or "Local Letter of Credit" means a credit enhancement device acceptable in form and substance to the Credit Facility Issuer securing timely payment of principal of and interest and premium, if any, on the Governmental Unit Note. "Maximum Annual Debt Service" shall mean as of any date, the maximum amount of principal, interest and other amounts provided for hereunder coming due in any year on the Loan and on any Additional Parity Bonds. Such amount shall be computed at the higher of (i) 1096 per annum or (ii)(A) the highest floating rate of interest borne by any Variable Rate Loan during the preceeding 24 months or (B) if no such Variable Rate Loan is then outstanding, the component of the Loan interest rate payable in respect of the Governmental Unit's Pro-Rata Share of interest on the Bonds shall be computed assuming the highest rate borne by the Bonds during the preceding 24 months. In the case of LKL-ll/30/88-267 AA-2821 -4- - I Additional Parity Bonds 'bearing interest at a variable rate such amount shall be computed at the higher of (i) 1096 per annum or (ij) the highest variable rate borne by such Bonds during the preceding 24 months, provided that if no such Bonds are then outstanding, the highest rate borne by variable rate obligations the interest rate on which is computed according to the same or a similar index as that to be used for the Additional Parity Bonds to be issued shall be assumed. For the purpose of this definition, "interest" on the Loan shall include that .amount payable in respect of the Governmental Unit's Pro-Rata Share of interest on the Bonds, Non-Asset Bonds amount, and Costs and Expenses of the Program. "Pledged Revenues" shall mean the proceeds of the local government half-cent sales tax, as defined and described in, and distributed to, the Governmental Unit under, Part VI, Chapter 218, Florida Statutes, securing repayment of the Loan and the Governmental Unit Note, pursuant to Section 3.6(b) hereof. "Pro-Rata Share" shall mean the percentage derived by dividing the principal amount of the Governmental Unit's Loan by the sum of (1) the principal amount of all loans outstanding plus (2) the amounts on deposit in the Project Loan Fund. "Recycled Bond Proceeds" shall mean proceeds used to make Loans from the Loan Repayment Account under the Indenture. LKL-11/30/88-267 AA -2821 -5- " I I ARTICLE m FINANCING THE PROJECT SECTION 3.1 MAKING OF LOAN; APPLICATION OF LOAN PROCEEDS. From the amounts, on deposit in the Project Loan Fund created under the Indenture, the Governmental Unit hereby agrees to borrow and repay the sum of $980,000. The Loan made hereby shall be repaid in accordance with the Governmental Unit Note and Section 3.3 hereof. The Governmental Unit covenants that it shall use the proceeds of the Loan solely for the purposes described in Section 1.l(g) hereof and that it shall not use the proceeds of the Loan in a manner inconsistent with the representations and covenants set forth in Sections 1.2(c), 1.2(e) and 1.2(f) hereof. ' SECTION 3.2 DISBURSEMENT OF LOAN; SECURITY INTEREST IN UN- DISBURSED PROCEEDS. (a) Following the execution and delivery of this Agree ment and the Govern- mental Unit Note (the "Closing"), the Trustee shall disburse the fees and expenses of bond counsel and the amount of expenses of the Administrator to be reimbursed from the proceeds of the Loan to the Expense Account created under the Indenture. The Trustee shall disburse the balance of the Loan, with the written approval of the Credit Facility Issuer, to the Governmental Unit in reimbursement for the cost of acquisition of the Project previously incurred by the Governmental Unit. (b) The Governmental Unit agrees that, upon request of the Trustee or the Administrator, it shall supply such documentation as the Trustee, the Administrator or the Credit Facility Issuer may require to determine that the proceeds of the Loan have been applied solely to payment of the Costs of the Project. SECTION 3.3 REPAYMENT OF LOAN. The Loan to be made to the Governmental Unit for the Project shall be repaid in installments which shall correspond in time and amount to the payments of principal and interest on the Governmental Unit " Note and shall bear interest at the rates, and shall be payable at the times payable on the Governmental Unit Note, as follows: (a) The principal of the Loan shall be paid in 120 installments on the dates and in the amounts shown on "Schedule I" attached to the form of the Governmental Unit Note, which is attached hereto as Exhibit "B", with all remaining principal, together with any other amounts payable in connection therewith, due on January 1, 1999, or such later date as the Credit Facility Issuer shall have approved in writing. (b) The interest on and other amounts due in respect of the Loan shall be paid commencing on the first day of February, 1989, and on the first day of each month thereafter. The repayment amounts due in respect of all Loans to Governmental Units shall be an amount determined by the Financial Advisor on behalf of the Sponsor, sufficient to retire, over the life of the Loan, the Pro-Rata Share of Non-Asset Bonds, and an amount sufficient to provide funds, which, as described in the immediately following paragraph, together with the Governmental Units' Pro-Rata Share of amounts in the Surplus Fund constituting income from the investment of certain funds established under LKL-ll/16/88-267 AA-2821 -6- the Indenture will be slfficient, to pay when due among Jher things, the Costs and' Expenses of the Program, the estimated interest (including Additional Interest, if any) becoming due on the Bonds, taking into consideration the fact that such interest on all or a portion of the Bonds will vary on a weekly basis pursuant to the Indenture; provided, however, that if an acceleration of the Loan is declared pursuant to Section 5.2 hereof following the occurrence of an Event of Default hereunder, the interest rate on the Loan shall be increased ,to a rate per annum equal to the Prime Rate plus 296. Said interest rate shall be based upon a year equal to 365/366 days for actual days elapsed and shall change when said Prime Rate shall change. Notwithstanding anything otherwise contained in this Agreement, the interest rate on the Loan shall not exceed twenty-five percent (2596) per annum (exclusive of amounts charged for Costs and Expenses of the Program which are not charges for the use or forbearance of money), or such higher rate as may from time to time be permitted under applicable law and approved by the Credit Facility Issuer (the "Maximum Rate"); provided, that, in the event the imposition of such Maximum Rate shall ever cause the amount payable on the Governmental Unit Note to be less than the amount of interest which would otherwise Qe computed pursuant to this Section 3.3, the Governmental Unit Note shall thereafter bear interest at the Maximum Rate until the earlier of (1) the final maturity of the Governmental Unit Note or (2) such time as the total amount of interest paid on the Governmental Unit Note shall at such rate equal the amount of interest which would have been payable on the Governmental Unit Note pursuant to this Section 3.3 without regard to any Maximum Rate. The Financial Advisor, on behalf of the Sponsor, shall determine not less often than each January 1 and July 1 the rate of interest on the Loan and the Pro-Rata Share of the Costs and Expenses of the Program and the Non-Asset Bonds and shall notify the Trustee and the Administrator of such determination. The Administrator shall compute the amount of each Governmental Unit's monthly payment and shall notify the Trustee and the Governmental Unit, at least ten days prior to the first day of the month in which the new payment amount is to become effective, of the period (not exceeding six months) for which such payment amount is to be in effect and the amount of each interest payment which the Governmental Unit is required to make during such period. However, if at any time the Trustee determines that such payment amount, together with other funds available therefor, does not provide sufficient funds to pay interest on all Bonds and to pay the Non-Asset Bonds, the interest becoming due on the Bonds (including Additional Interest, if any, together with the annual fees and other amounts, if any, charged for or due under the Credit Facility and Liquidity Facility, together with other fees and expenses relating to the Sponsor's multi-governmental loan program, the Trustee shall so notify the Administrator and the Financial Advisor. The Financial Advisor, on behalf of the Sponsor shall increase the payment amount on the Loan then in effect by an amount sufficient to cure such deficiency by giving notice thereof to the Administrator. The Administrator shall recompute the amount of the Governmental Unit's monthly payments and shall give the Governmental Unit notice of a revised interest rate at least ten days prior to the date such revised interest rate is to become effective, stating the period (not exceeding six months) for which such revised interest rate is or additional payments are to be in effect, and the amount of each interest payment which the Governmental Unit is required to make during such period. The Administrator shall send to the Trustee and the Credit Facility Issuer duplicate copies of each statement to the Governmental Unit specifying the total payment due from the Governmental Unit for principal and interest on the Loan, the respective amounts of principal and interest included in such total payment, and the amount of any fees and expenses billed to the Governmental Unit on a LKL-l1/30/88-267 AA-2821 -7- monthly basis pursuant tl Section 3.5 hereof. The Governm4,tal Unit agrees that the Sponsor has reserved the right to determine the extent to which invest ment income on the funds established under the Indenture (including any income from the Project Loan Fund prior to full disbursement of the Loan) may be applied in determining the amount payable hereunder. (c) As provided in the Governmental Unit Note, in addition to the above payments of principal and interest on the Loan and the additional payments provided for herein, any payment of principal and interest on the Loan which is received later than its due date shall bear interest at a rate equal to the Prime Rate plus 296 per annum. SECTION 3.4 PREP A YMENT OF LOAN. The Governmental Unit may upon any Interest Payment Date on which the Bonds may be redeemed or converted to another Mode at the option of the Sponsor and, upon not less than 129 days prior written notice to the Sponsor, the Adm inistrator and the Trustee, prepay the outstanding principal of the Loan or any portion thereof in accordance with the requirements of Section 4.04(b) of the Indenture. There shall also be paid as a prepayment premium an amount equal to any premium payable to the holders of the Bonds in connection with such prepayment. SECTION 3.5 ADMINISTRATIVE EXPENSES. (a) In determining the payments in respect of the Loans which all Govern- mental Units with non-accelerated Loans shall pay in each month, there shall be included an amount determined by the Administrator on behalf of the Sponsor to be sufficient to pay when due the items referred to in Section 3.3, including without limitations: (1) the annual fees and other amounts, if any, charged for or due (i) in the case of Variable Rate Loans, under the Credit Facility (including additional surety bond premiums, if any); (ii) under the Liquidity Facility, and (iii) if this Loan is funded from Recycled Bond Proceeds the bond insurance premiums and additional surety bond premiums, if any, related to Recycled Bond Proceeds for the Loan (which shall be paid in full at Closing); (2) the annual administrative fees of (i) the Sponsor, the Administra- tor, and the Independent Contractor, if applicable, and (ii) the Trustee, the Bond Registrar and Paying Agent and any other Paying Agent or Agents; (3) the annual fee of the Remarketing Agent; (4) cost of issuance of the Bonds allocable to the Loan as Non-Asset Bonds; (5) the deferred Increased Cost Payments accrued to the date of Closing of the Loan (which shall be recovered over a 12 month period); and (6) the Governmental Unit's Pro-Rata Share of any amounts payable pursuant to the Indenture as Increased Costs or Deferred Increased Costs. LKL-ll/16/88-267 AA-2821 -8- The Administrator, on Jdalf of the Sponsor, shall determineLuch amount (concurrently, with the determination of the interest payments on the Loan pursuant to Section 3.3(b) hereoO and shall notify the Governmental Unit at least ten days prior to the first day of the period for which the new payment schedule is to become effective, of the period (not exceeding six months) for which such payment schedule is to be in effect and the amount of each payment which the Governmental Unit is required to make during such period. However, if at any time the Administrator determines that such payments made by all Governmental Units with non-accelerated Loans will not provide sufficient funds to pay the amounts described in clauses (1) through (6) above, the Administrator, on behalf of the Sponsor, shall revise the schedule of payments then in effect by giving the Governmental Unit notice of revised schedule of payments, at least ten days prior to the date such revised payment schedule is to become effective, stating the period (not exceeding six months) for which such payment schedule is to be in effect and the amount of each payment which the Governmental Unit is required to make during such period. " (b) The Governmental Unit shall pay the amounts described in paragraph (a) above to the Trustee, as the Sponsor's assignee of this Agreement; except as otherwise provided in Section 3.9 hereof. (c) Any other amounts due from the Governmental Unit hereunder, including closing costs related to the Loan and not paid at closing. SECTION 3.6 SPECIAL OBLIGATION OF GOVERNMENTAL UNITS. (a) Each. Credit Issuer may share with any other Credit Issuer any informa- tion given to any of them by the Governmental Unit, including without limitation financial statements, and may also share such information with any participant of such Credit Issuer, and any financial institution which is being solicited to become a participant of any Credit Issuer. To the extent necessary to permit the foregoing, the Governmental Unit hereby waives any privilege or right to confidentiality, whether arising under statute or otherwise, it may have which would otherwise prohibit the foregoing sharing of informa- tion. (b) The Governmental Unit Note shall be secured by a lien upon and pledge of the Pledged Revenues, and the Pledged Revenues are hereby pledged to secure repayment of the Governmental Unit Note, as, set forth in the Authorizing Ordinance. The Governmental Unit hereby represents and warrants that the pledge of the Pledged Revenues to secure the Governmental Unit Note is valid, binding and enforceable and that the Pledged Revenues are not otherwise subject to any pledge, lien or encumbrance, other than as has been heretofore disclosed to and expressly approved by the Credit Facility Issuer in writing, such disclosure consisting of a first pledge and lien securing the repayment of the Governmental Unit's Capital Improvement Revenue Bonds, Series 1984 (the "1984 Bonds") and a second pledge and lien securing repayment of the Governmental Unit's Loan from the Program in the amount of $415,000 (the "Parity Loan"). The Governmental Unit covenants that it will not cause or permit to exist any pledge of or lien or encumbrance upon the Pledged Revenues which is prior in right of payment to that securing the Governmental Unit Note except as expressly approved by the Credit Facility Issuer including, specifically, any further debt secured on a parity with the 1984 Bonds. The Governmental Unit covenants that it will not cause or permit to exist any pledge of or lien or encumbrance upon the Pledged Revenues, other than the pledge benefitting the LKL-ll/16/88-267 AA-2821 -9- Governmental Unit Note, lcePt for any Additional Parity BondJor obligations secured by a lien subordinate to the lien of the Governmental Unit Note which may be issued in the manner permitted hereunder. (c) Prior to each of its fiscal years, the Governmental Unit shall establish a budget for such fiscal year which allocates a sufficient sum of Pledged Revenues to pay all amounts reasonably anticipated by the Governmental Unit to be payable hereunder and all amounts reasonably anticipated to be payable with respect to any Additional Parity Bonds. In the event that the budgeted amounts prove insufficient to make said payments the Governmental Unit shall as soon as practicable (but in any event prior to the expiration of sixty days from such event) amend its budget so as to assure that sufficient Pledged Revenues are available to at all times make said payments. (d) The Loan and the Governmental Unit Note, and all payments due with respect thereto, shall be a special obligation of the Governmental Unit, payable solely from the Pledged Revenues as herein provided. The Loan and the Governmental Unit Note do not constitute a general indebtedness of the Governmental Unit, or a pledge of its faith, credit or taxing power within the meaning of any constitutional or statutory provision or limitation. Neither the State of Florida nor any political subdivision thereof nor the Governmental Unit shall be obligated (1) to exercise its ad valorem taxing power or any other taxing power in any form on any real or personal property in the Governmental Unit to pay the principal of the Loan and the Governmental Unit Note, the interest thereon or other payments or costs incident thereto, or (2) to pay the same from any other funds of the Governmental Unit except from the Pledged Revenues, all in the manner provided herein. The acceptance of the Governmental Unit Note by the holder from time to time thereof shall be deemed an agreement between the Governmental Unit and such holder that the Governmental Unit Note and the indebtedness evidenced thereby shall not constitute a lien upon any property of the Governmental Unit, but shall constitute a lien only on the Pledged Revenues, in the manner herein provided. (e) Subject to the provisions of the Florida Constitution, nothing herein contained shall preclude the Governmental Unit from using any legally available funds, in addition to the Pledged Revenues herein provided, which may come into its possession, including but not limited to the proceeds of the Loan, contributions or grants, for the purpose of payment of principal of and interest on the Loan. SECTION 3.7 BENEFIT OF BONDHOLDERS AND ENHANCEMENT PROVIDER; COMPLIANCE WITH TRUST INDENTURE. This Agreement is executed in part to induce the purchase by others of the Bonds, the issuance by the Credit Facility Issuer of the Credit Facility, the issuance of Local Credit Enhancement, if any, and the execution and delivery by the Liquidity Facility Issuer of the Liquidity Facility and, accordingly, all covenants, agreements and representations on the part of the Govern- mental Unit and the Sponsor, as set forth in this Agreement, are hereby declared to be for the benefit of the holders from time to time of the Bonds, and for the benefit of each Credit Issuer. The Governmental Unit covenants and agrees to do all things within its power in order to comply with and to enable the Sponsor to comply with all requirements and to fulfill and to enable the Sponsor to fulfill all covenants of the Indenture. LKL-ll/16/88-267 AA-2821 -10- SECTION 3.1 BONDS NOT TO BECOME ARBITt AGE BONDS. The Governmental Unit hereby covenants to the Sponsor and the holders of the Bonds that, notwithstanding any other provision of this Agreement or any other instru- ment, it will neither make nor cause to be made any investment or other use of the proceeds of the Loan which would cause the Bonds to be "arbitrage bonds" under Section 103 of the Internal Revenue Code of 1954, as amended, and the regulations issued thereunder, and that it will comply with the requirements of such Section and regulations throughout the term of the Bonds. Section 3.9 ASSIGNMENT OF SPONSOR'S RIGHTS. (a) As the source of payment for the Bonds, the Sponsor will assign to the Trustee all the Sponsor's rights under the Governmental Unit Note and this Agreement (except for the rights of the Sponsor, the Trustee, the Administrator and the Independent Contractor, if applicable, to receive payment of administrative expenses, reports and indemnity against claims, and the Sponsor's, Trustee's and Administrator's rights to enforce remedies pursuant to Section 3.5, 4.1, 4.2 and 5.4 hereof). The Governmental Unit will make all payments required under Sections 3.3, 3.4, 3.5 and 5.3 hereof directly to the Trustee without defense or setoff by reason of any dispute between the Governmental Unit and the Sponsor. (b) The Indenture requires that the Credit Facility provide for payment of the principal of and interest on the Bonds when due if other moneys available under the Trust Indenture are insufficient therefor, and that rights to the payment of any principal and/or interest paid by the Credit Facility Issuer shall be assigned to the Credit Facility Issuer. Under certain circumstances provided in the Indenture, this Agreement and the Governmental Unit Note may be assigned to a Credit Issuer or the issuer of a Local Letter of Credit. (c) Notwithstanding anything in this Agreement to the contrary, if amounts due under the Governmental Unit Note and this Agreement are accelerated as described in the Indenture, and the full amount of the Loan has not been disbursed pursuant to the Commitment, the Trustee shall have no obligation to make any further disbursements of the Loan and shall apply the same to pay the Governmental Unit Note. SECTION 3.10. COVENANT REGARDING PLEDGED REVENUES; REVENUE FUND. (a) The Governmental Unit hereby covenants to take all lawful action necessary or required to collect and receive the Pledged Revenues. The Governmental Unit further covenants that it has full power to pledge the Pledged Revenues to the payment of the principal and interest and other amounts becoming due on the Governmental Unit Note. (b) There is hereby created and established the City of Clearwater Gulf Breeze Loan Program Revenue Fund (the "Revenue Fund"). After application for the benefit of the 1984 Bonds as required under the ordinance authorizing issuance of the 1984 Bonds, all Pledged Revenues received by the Governmental Unit shall be deposited into the Revenue Fund and held solely for the benefit of the holder of the Governmental Unit Note and Additional Parity Bonds as provided in this Section 3.10(b). The Revenue Fund shall constitute a trust fund for the purposes herein provided and shall be kept separate and distinct from all other funds of the Governmental Unit and used only for the purposes and in the manner herein provided. Moneys on deposit in the Revenue Fund shall be invested in obligations in which the Project Loan Fund may be invested under the LKL-11/16/88-267 AA-2821 -11- Indenture or as otherw~e may be permitted by the Credl Facility Issuer, and all investment earnings shall be retained therein and used for the purposes thereof. Revenues shall be applied and allocated on the fifteenth day of each month (i) first, to a separate fund, which is hereby created and designated the City of Clearwater Gulf Breeze Loan Program Sinking Fund (hereinafter called "Sinking Fund") commencing January 1~, 1989, in such amounts sufficient to pay the principal of and interest and other amounts becoming due on the Governmental Unit Note on the first day of the following month, (ii) next, on a parity with the payments to be made pursuant to clause (i), to the payment of amounts due in connection with any Additional Parity Bonds issued pursuant to the provisions hereof, (iii) next, to the payment of any junior lien obligations issued pursuant to the provisions hereof, and (iv) thereafter, to the Governmental Unit for any lawful purpose of the Governmental Unit. The designation and establishment of the Revenue Fund and Sinking Fund pursuant to this Section 3.10 shall not be construed to require the establishment of any completely independent, self-balancing funds as such term is commonly defined and used in governmental accounting, but rather is intended solely to constitute an earmarking of certain revenues of the Governmental Unit for certain purposes and to establish certain priorities for application of such revenues as herein provided. SECTION 3.11 ALTERNATE SECURITY FOR GOVERNMENTAL UNIT NOTE. The Governmental Unit reserves the right to secure the Governmental Unit Note with a Local Credit Enhancement acceptable in form and substance to the Credit Facility Issuer and the Administrator, and upon furnishing such Local Credit Enhancement or other security, the pledge of and lien upon the Pledged Revenues in favor of the Governmental Unit Note shall be released and discharged, in the manner and to the extent specified by the Credit Facility Issuer in writing. In addition, the Governmental Unit may provide for the defeasance of the lien of this Loan Agreement upon the Pledged Revenues at any time provided it first provides the following to the Trustee and to the Credit Facility Issuer: (a) Evidence that the Governmental Unit shall have paid, or shall have made provision for payment of, all amounts payable under this Loan Agreement. For purposes of the preceding sentence, deposit of direct obligations of the United States of America which are not subject to redemption prior to maturity at the option of the obligor (or, with the written approval of the Credit Facility Issuer, deposit of any other securities or investments which may be authorized by law from time to time and sufficent under such law to effect such a defeasance) in irrevocable trust with a banking institution or trust company, for the sole benefit of the Sponsor, the principal of and interest on which will be sufficient to pay when due all payments under this Loan Agreement, shall be considered "provision for payment". (b) An opinion of nationally recognized bond counsel acceptable to the Sponsor and to the Credit Facility Issuer to the effect that (i) the lien of the Loan Agreement upon the Pledged Revenues has been defeased and (ii) the transaction resulting in such defeasance does not adversely affect the exemption from taxation of the interest on the Bonds. (c) Verification by an independent certified public accountant of sufficiency of amounts deposited in escrow pursuant to paragraph (a). LKL-ll/16/88-267 AA-2821 -12- I I SECTION 3.12 INTERLOCAL AGREEMENT. This Loan Agreement, together with the Governmental Unit Note incorporated by reference herein, shall be deemed to be an interlocal agreement with the Sponsor within the meaning of Chapter 163, Part I, Florida Statutes, and shall be filed of record in accordance with the provisions of the Florida Intergovernmental Cooperation Law. LKL-ll/16/88-267 AA-2821 -13- I I " ARTICLE IV COVENANTS OF THE GOVERNMENTAL UNIT SECTION (.1 REPORTS AND OPINIONS; INSPECTIONS. (a) Until all amounts due under this Agreement have been paid in full, the Governmental Unit shall deliver to the Sponsor, the Trustee and the Credit Issuers, within ten days of the Governmental Unit's receipt thereof, an annual report prepared in accordance with generally accepted accounting principles applicable to the Governmental Unit, and certified by an independent certified public accountant (or accounting firm) satisfactory to the Sponsor which shall include a balance sheet and income statement for the prior fiscal year in reasonable detail. In addition, the Governmental Unit shall deliver to the Sponsor, the Trustee and the Credit Issuers, if requested by them, within 50 days after the end of each fiscal quarter: (i) a reasonable number of copies of the Governmental Unit's unaudited financial statements for the prior fiscal quarter including a balance sheet and income statement; and (ij) a certificate stating that no Event of Default hereunder has occurred and is continuing. (b) The Governmental Unit shall deliver to the Sponsor, the Credit Facility Issuer and the Trustee, not later than the 135th but not earlier than the 128th day following (i) in the case of a Loan secured by a Local Letter of Credit, the date of each Loan Payment pursuant to the terms of this Agreement (whether by prepayment or regularly scheduled payment) or (ii) as to Loans not so secured, upon the final payment upon the Loan, a certificate of the Governmental Unit, or other evidence in form and substance satisfactory to the Trustee, to the effect that, during the period ending 128 days following such payment, no bankruptcy, insolvency or similar proceeding has been commenced by or against the Governmental Unit and that no other event has occurred which would have constituted an ev.ent of default under Section 5.1(f) of this Agreement (except such as has been vacated, dismissed or discharged by an order which is not subject to further appeal). Notwithstanding the payment in full of the Loan, the Governmental Unit shall pay any charges incurred by the Sponsor or the Trustee in connection with any payment under the Credit Facility by reason of the Governmental Unit's failure to deliver such certificate or evidence on a timely basis. In addition, notwithstanding the payment in full of the Loan, the Governmental Unit shall pay to any Substitute Credit Facility Issuer an amount, if any, equal to the Credit Issuer Rate per annum on the amount which was disbursed under the Credit Facility by reason of any payment to the holders of the Bonds being deemed a Preference P~yment (as defined in the Indenture). (c) The Governmental Unit agrees to permit the Sponsor, the Trustee and the Credit Issuers to examine, visit and inspect, at any reasonable time, the Project, and the Governmental Unit's facilities, and any accounts, books and records, including its receipts, disbursements, contracts, investments and any other matters relating thereto and to its financial standing, and to supply such reports and' information as the Sponsor, the Trustee or the Credit Issuers may reasonably require. SECTION (.2 IMMUNITY OF SPONSOR. In the exercise of the powers of the Sponsor and its members, officers, employees and agents under the Indenture or this Agreement including (without limiting the foregoing) the application of moneys and the LKL-12/07 /88-267 AA-2821 -14- I I investment of funds, the Sponsor shall not be accountable to the Governmental Unit for any action taken or omitted with respect to the Project or this Agreement by it or its members, officers, employees and agents in good faith and believed by it or them to be authorized or within the discretion or rights or powers conferred under this Agreement. The Sponsor and its members, officers, employees and agents shall be protected in its or their acting upon any paper or documents believed by it or them to be genuine, and it or they may conclusively rely upon the advice of counsel and may (but need not) require further evidence of any fact or matter before taking any action. No recourse shall be had by the Governmental Unit for any claims based on the Indenture or this Agreement against any member, officer, employee or agent of the Sponsor alleging personal liability on the part of such person unless such claims are based upon the bad faith, fraud or deceit of such person. The Governmental Unit shall indemnify the Sponsor and any of its members, officers, employees or agents and save them harmless against any liability intended to be precluded by this Section resulting from acts or omissions of the Governmental Unit or from acts or omissions of the Sponsor or any of its members, officers, employees or agents in connection with any necessary or reasonable acts taken pursuant to this Agreement, except for fraud, deceit, or acts taken in bad faith or which are negligent. SECTION 4.3 COMPLIANCE WITH LAWS. With respect to the Project and any additions, alterations, or improvements thereto, the Governmental Unit will at all times comply with all applicable requirements of Federal and state laws and with all applicable lawful requirements of any agency, board, or commission created under the laws of the State of Florida or of any other duly constituted public authority; provided, however, that the governmental unit shall be deemed in compliance with this Section 4.3 so long as it is contesting in goocl faith any such requirement by appropriate legal proceedings. SECTION 4.4 ISSUANCE OF OTHER OBLIGATIONS PAYABLE FROM PLEDGED REVENUES. So long as the Governmental Unit Note remains Outstanding and unpaid, the Governmental Unit will not issue or consent to the issuance' of any other Obligations, except under the conditions and in the manner provided herein, payable from the Pledged Revenues or any portion thereof, nor voluntarily create or cause to be created any debt, lien, pledge, assignment, encumbrance or other charge, having priority to or being on a parity with the lien of the Governmental Unit Note and the interest thereon, upon the Pledged Revenues. Any other obligations issued by the Governmental Unit in addition to the Governmental Unit Note or Additional Parity Bonds provided for in Section 4.5 hereof, payable from the Pledged Revenues, shall contain an express statement that such obligations are junior and subordinate in all respects to the Governmental Unit Note, as to lien on and source and security for payment from the Pledged Revenues; provided, however, that the Governmental Unit may also grant to the provider of a Local Credit Enhancement for the Governmental Unit Note or any provider of Local Credit Enhancement with respect to any Additional Parity Bonds, a lien upon the Pledged Revenues commensurate with the lien granted in respect of such Additional Parity Bonds, provided that the scheduled Maximum Annual Debt Service on the reimbursement obligation under any such Local Credit Enhancement would meet the requirements hereof, as appropriate, without regard to the Maximum Annual Debt Service on such Additional Parity Bonds. LKL-ll/30/88-267 AA-2821 -15- " I I SECTION 4.5 ISSUANCE OF ADDmONAL PARITY BONDS. No Additional Parity Bonds, payable on a parity from the Pledged Revenues with the Governmental Unit Note shall be issued after the issuance of the Governmental Unit Note, except for the construction and acquisition of capital projects of the Governmental Unit or for refunding purposes and except upon the conditions and in the manner herein provided: (1) There shall have been obtained and filed with the Governmental Unit a certificate of an independent certified public accountant of suitable experience and responsibility; (a) stating that the books and records of the Governmental Unit relating to the collection and receipt of Pledged Revenues have been audited by him; (b) setting forth the amount of Pledged Revenues, as defined herein, received by the Governmental Unit for any twelve consecutive months within the eighteen mon"ths immediately preceding the date of delivery of such Additional Parity Bonds with respect to which the certificate is made; (c) stating that the Pledged Revenues, received by the Governmental Unit for such twelve month period equals at least 1.50 times the Maximum Annual Debt Service on (i) the Governmental Unit Note and all Additional Parity Bonds, if any, then outstanding and (ii) the Additional Parity Bonds with respect to which the certificate is made. Prior to retirement or defeasance of the 1984 Bonds, such certificate shall state the amount of Pledged Revenues received during the immediately preceding fiscal year and shall state that the amount of such Pledged Revenues received for such fiscal year, less an amount equal to Maximum Annual Debt Service coming due in any future year on the 1984 Bonds, shall equal at least 1.50 times the Maximum Annual Debt Service on (i) the Governmental Unit Note and all Additional Parity Bonds, if any, then outstanding, and (ii) the Additional Parity Bonds with respect to which the certificate is made. (2) There shall have been prepared and filed with the Governmental Unit a certificate of such independent certified public accountant stating that the estimated revenues budgeted in the annual budget of the Governmental Unit for the current Fiscal Year in which the Additional Parity Bonds will be issued, adjusted in accordance with generally accepted accounting principles, will be sufficient to pay all expenses to be incurred in the operation of the Governmental Unit and to pay the Maximum Annual Debt Service becoming due on (i) the 1984 Bonds, the Governmental Unit Note and all .. Additional Parity Bonds, if any, then outstanding and (ii) the Additional Parity Bonds with respect to which the certificate is made. (3) The Governmental Unit shall not be in default in performing any of the covenants and obligations assumed hereunder, and all payments herein required to have been made into the accounts and funds, as provided hereunder, shall have been made to the full extent required. (4) No Additional Parity Bonds bearing interest at a variable rate shall be issued while any portion of the Governmental Unit Note shall remain outstanding without the prior written consent of the Credit Facility Issuer. (5) Notwithstanding the foregoing, the Parity Loan, being made contempor- aneously with the Loan made hereunder, shall for all purposes be deemed an Additional Parity Bond, without compliance with any of the terms of this Section 4.5. LKL-ll/30/88-267 AA-2821 -16- I I " SECTION 4.6 ADDITIONAL COVENANTS. (A) NO PRrV A TE USE. The Governmental Unit will take no action, or permit or suffer any action or event, which will cause the Governmental Unit Note or the Bonds to be an "Industrial Development Bond" or a "Consumer Loan Bond" within the meaning of the Internal Revenue Code of 1954, as amended. No portion of the Project will be used in the trade or business of any Person (including any governmental body or public instrumentality) except the Governmental Unit, by lease, license or management contract or otherwise. In this regard the Governmental Unit further certifies that (i) not in excess of ten percent (1096) of the net proceeds of the Governmental Unit Note will be used for Private Business Use if, in addition, the payment of more than ten percent (1096) of the principal or ten percent (1096) of the interest due on such Governmental Unit Note during the term thereof is, under the terms of such Governmental Unit Note or any underlying arrangement, directly or indirectly, secured by any interest in property used or to be used for a Private Business Use or in payments in respect of property used or to be used for a Private Business Use or is to be derived from payments, whether or not to the Governmental Unit, in respect of property or borrowed money used or to be used for a Private Business Use; and (ii) that, in the event that both (A) in excess of five percent (596) of the Net Proceeds of such Governmental Unit Note are used or have been used for a Private Business Use, and (B) an amount in excess of five percent (596) of the principal or five percent (596) of the interest due on such Governmental Unit Note during the term thereof is, under the terms of such Governmental Unit Note or any underlying arrange- ment, directly or indirectly, secured by any interest in property used or to be used for said Private Business Use or in payments in respect of property used or to be used for said Private Business Use or is to be derived from payments, whether or not to the Governmental Unit, in respect of property or borrowed money used or to be used for said Private Business Use, then said excess over said five percent (596) of Net Proceeds of the Governmental Unit Note used for a Private Business Use has been or shall be used for a Private Business Use related to the governmental use of the System. The term "Private Business Use" means use directly or indirectly in a trade or business' carried on by a natural person or in any activity carried on by a person other than a natural person, excluding, however, use by a state or local governmental unit and use as a member of the general public. LKL-ll/16/88-267 AA-2821 -17- 1 ARTICLE V 1 '. EVENTS OF DEFAULT AND REMEDIES SECTION 5.1 EVENTS OF DEFAULT. Each of the following events is hereby defined as, s.nd declared to be and shall constitute, an "Event of Default": (a) failure by the Governmental Unit to make any payment required to be made pursuant to Section 3.3 or 3.5(a) or (b) hereof on or before the date the same is due; or (b) failure by the Governmental Unit to make any payment required to be made pursuant to Section 3.5(c) hereof within 30 days after the same is due; or (c) with the exceptions of those covenants set forth in Sections 3.3 and 3.5 hereof, failure by the Governmental Unit to observe and perform any other covenant, condition or agreement on its part to be observed or performed under this Agreement for a period of 30 days after written notice specifying such failure and requesting that it be remedied is given to the Governmental Unit by the Sponsor, the Credit Facility Issuer or the Trustee; or (d) if any of the representations, warranties or certifications of the Governmental Unit under Section 1.2 hereof or otherwise made or delivered in connection herewith or pursuant to the Indenture shall prove to be false or misleading in any material respect; or (e) (1) the Governmental Unit shall make an assignment for the benefit of creditors, (2) the Governmental Unit shall apply for or seek, the appointment of a receiver, custodian, trustee, examiner, liquidator or similar official for it or any substantial part of its property, (3) the Governmental Unit shall fail to file an answer or other pleading denying the material allegations of any proceeding filed against it described under Section 5.1(f)(2), (4) the Governmental Unit shall take any action to authorize or effect any of the actions set forth in Sections 5.1(e) or 5.1(f) or (5) fail to contest in good faith any appointment or proceeding described in Sections 5.1(e) or 5.1(f), (6) without the application, or approval or consent of the Governmental Unit, a receiver, trustee, examiner, liquidator, or similar official shall be appointed for any substantial part of the Governmental Unit's property and such appointment shall continue undischarged or such proceedings shall continue undismissed or unstayed for a period of 30 consecutive days, or (7) the Governmental Unit shall be in a state of financial emergency as defined in Section 218.503, Florida Statutes, as amended, or any successor statute thereto; or (f) (1) the Governmental Unit shall be adjudicated a bankrupt or become subject to an order for relief under federal bankruptcy law, (2) the Governmental Unit shall institute any proceedings seeking an order for relief under federal bankruptcy law or seeking to be adjudicated a bankrupt or insolvent, or seeking dissolution, winding up, liquidation, reorganization, arrangement, adjustment or composition of it or its debts under any law relating to bankruptcy or insolvency, (3) there shall be appointed a receiver, liquidator or similar official for the Governmental Unit under any law relating to bankruptcy or insolvency, or (4) without the application, approval or consent of the LKL-ll/16/88-267 AA-2821 -18- Governmental Unit, a re1ceiver, trustee, examiner, liquidator lor similar official shall be' appointed for the Governmental Unit, or a proceeding described in Section 5.1(f)(2) shall be instituted against the Governmental Unit and such appointment continues undischarged or such proceeding continues undismissed or unstayed for a period of 30 consecutive days; the mere declaration of a state of financial emergency under Section 218.503, Florida Statutes, as amended, shall not, in and of itself, constitute a default under this Section S.l(f); or " (g) the failure of the Governmental Unit to provide a replacement for any Local Letter of Credit required with respect to the Loan, which replacement has been approved in writing by the Credit Facility Issuer, by the 15th day prior to the expiration or non-renewal of the existing Local Letter of Credit. SECTION 5.2 ACCELERATION. If an Event of Default as defined in Section 5.1(a), (b), (e) or (f) hereof shall have occurred, or upon the 10th day prior to the expiration, termination, or non-renewal of a Local Letter pursuant to Section 5.1(g) hereof, the Loan and all other sums which the Governmental Unit is obligated to pay under this Agreement shall, upon direction of the Credit Facility Issuer, become due and payable immediately, and the Commitment shall terminate, without further notice to the Governmental Unit. If any other Event of Default shall have occurred, the Trustee (as the Sponsor's assignee, or any assignee of the Trustee or Co-Trustee, as may be the case) shall, but only upon direction of the Credit Facility Issuer, by notice in writing to the Governmental Unit, declare the Loan and all other sums which the Governmental Unit is obligated to pay hereunder to be due and payable immediately, and terminate the Commitment. Upon any such acceleration whether automatically or by declaration, anything in this Agreement contained to the contrary notwithstanding, there shall become immediately due and payable, in addition to any other amounts then due from the Governmental Unit hereunder, the sum of: (i) the outstanding principal of the Loan or pro rata portion thereof, as the case may be; (ii) accrued and unpaid interest on the Loan or pro rata portion thereof, as the case may be; and (iii) all amounts which would be payable in excess of the sum of: (x) the unpaid principal balance of the Governmental Unit Note or pro rata portion thereof, as the case may be plus (y) accrued and unpaid interest thereon, in the event the Governmental Unit Note had been prepaid in accordance with Section 3.4(b) hereof on the date of acceleration pursuant to this Section 5.2. SECTION 5.3 PAYMENT OF LOAN ON DEFAULT; SUIT THEREFOR. (a) The Governmental Unit covenants that, in case default shall occur in the payment of any sum payable by the Governmental Unit under Section 3.3 of this Agreement as and when the same shall become due and payable, whether at maturity or by acceleration or otherwise, then, upon demand of the Sponsor, the Credit Facility Issuer or the Trustee, but only upon direction of the Credit Facility Issuer, the Governmental Unit will pay to the Trustee (or its assignee) an amount equal to the sum of: (1) the amount described in Section 5.2 hereof; (ii) all accrued interest on the Loan to the date such payment is made; (Hi) all other amounts which the Governmental Unit is obligated to pay under this Agreement; and (iv) such further amount as shall be sufficient to cover the costs and expenses of collection, including a reasonable compensation to the Sponsor, the Trustee, their agents, attorneys and counsel, and any expenses or liabilities incurred by the Sponsor or the Trustee other than through gross negligence or bad faith. LKL-ll/16/88-267 AA-2821 -19- ........ '. I I (b) In case the Governmental Unit shall fall forthwith to pay such amounts upon such demand, the Sponsor or the Trustee (or its assignee) shall be entitled and empowered but only upon direction of the Credit Facility Issuer, to institute any actions or proceedings at law or in equity for the collection of the sums so due and unpaid, and may prosecute any such action or proceeding to judgment or final decree, and may enforce any such judgment or final decree against the Governmental Unit and collect in the manner provided by law. (c) In case any proceedings shall be pending for the bankruptcy or for the reorganization of the Governmental Unit under the Federal bankruptcy laws or any other applicable law, or in case a receiver or trustee shall have been appointed for the property of the Governmental Unit, or in case any other similar judicial proceedings shall be pending relating to the Governmental Unit or to the creditors or property of the Governmental Unit, the Trustee (or its assignee) shall be entitled and empowered, by intervention in such proceedings or otherwise, to file and prove a claim or claims for the whole amount of the Loan made to the Governmental Unit pursuant to this Agreement and for interest owing and unpaid in respect thereof and to file such proofs of claim and other papers or documents as may be necessary or advisable in order to prosecute the claims of the Trustee (or its assignee) in any such judicial proceedings relating to the Governmental Unit, its creditors, or its property, and to collect and receive any moneys or other property payable or deliverable on any such claims, and to distribute the same after the deduction of its charges and expenses. Any receiver, assignee or trustee in bankruptcy or reorganization is hereby authorized to make such payments to the Trustee (or its assignee), and to pay to the Trustee (or its assignee) any amount it requires for compensation and expenses, including counsel fees it has incurred up to the date of such distribution. SECTION 5.4 OTHER REMEDIES. (a) Whenever any Event of Default hereunder shall have occurred and be continuing, whether or not all sums which the Governmental Unit is obligated to pay under this Agreement shall have been declared to be immediately due and payable pursuant to this Agreement, the Sponsor or the Trustee (or its assignee) shall, but only if directed by the Credit Facility Issuer, take whatever action at law or in equity as may appear necessary or desirable to collect the amounts payable by the Governmental Unit hereunder, then due and thereafter to become due, or to enforce performance and observance of any obligation, agreement or covenant of the Governmental Unit under this Agreement, including the application of any undisbursed Loan proceeds to the reduction of the outstanding balance of such Loan. (b) Whenever any Event of Default hereunder shall have occurred and be continuing, before or after declaring an acceleration pursuant to Seeton 5.2 hereof, the Sponsor or the Trustee (or its assignee) may, but shall not be obligated to, perform for the account of the Governmental Unit any covenant or obligation in the performance of which the Governmental Unit is in default, in which event the Governmental Unit shall immediately reimburse the Sponsor or the Trustee (or its assignee), as the case may be, upon demand for all expenses incurred by the Sponsor or the Trustee (or its assignee), as the case may be, in the course of such performance, including reasonable counsel fees, with interest from the date of such expenditure at the Prime Rate of the Liquidity Facility Issuer then in effect. LKL-ll/16/88-267 AA-2821 -20- I I (c) No action taken pursuant to this Section 5.4 shall relieve the Governmental Unit from its obligations pursuant to Sections 3.3, 3.5 and 5.3 hereof, all of which shall survive any such action. The Sponsor or the Trustee (or its assignee) may, and upon direction of the Credit Facility Issuer, shall take whatever action at law or in equity as may appear necessary and desirable to collect the amounts then due and thereafter to become due, or to enforce the performance and observance of any obligation, agreement or covenant of the ,Governmental Unit hereunder. " (d) Except as to the Sponsor's rights to indemnity and reports from the Governmental Unit hereunder, the Sponsor shall not be deemed to have an exclusive right to enforce the remedies described in this Section 5.4. SECTION 5.5 CUMULATIVE RIGHTS. No remedy conferred upon or reserved to the Sponsor, the Credit Facility Issuer or the Trustee (or its assignee) by this Agreement is intended to be exclusive of any other available remedy or remedies, but each and every such remedy shall be cumulative and shall be in addition to every other remedy given under this Agreement or now or hereafter existing at law or in equity or by statute. No waiver by the Sponsor, the Credit Facility Issuer or the Trustee (or its assignee) of any breach by the Governmental Unit of any of its obligations, agreements or covenants hereunder shall be deemed a waiver of any subsequent breach, or a waiver of any other obligation, agreement or covenant, and no delay or failure by the Sponsor, the Credit Facility Issuer or the Trustee (or its assignee) to exercise any right or power shall impair any such right or power or shall be construed to be a waiver thereof, but any such right and power may be exercised by the Sponsor, the Credit Facility Issuer or the Trustee (or its assignee) from time to time and as often as may be deemed expedient. SECTION 5.6 DISCONTINUANCE OF PROCEEDINGS. In case the Sponsor, the Credit Facility Issuer or the Trustee (or its assignee) shall have proceeded to enforce any right under this Agreement and such proceedings shall have been discontinued or abandoned for any reason or shall have been determined adversely to the Sponsor, the Credit Facility Issuer or the Trustee (or its assignee), then and in every such case the Governmental Unit, the Sponsor, the Credit Facility Issuer and the Trustee (or its assignee) shall be restored respectively to their several positions and rights hereunder, and all rights, remedies and powers of the Govermental Unit, the Sponsor, the Credit Facility Issuer and the Trustee (or its assignee) shall continue as though no such proceeding had been taken. SECTION 5.7 NOTICE OF DEFAULT. The Governmental Unit shall give the Trustee, the Credit Facility Issuer, the Liquidity Facility Issuer, each Local Credit Enhancement Issuer or provider of any Local Letter of Credit and the Sponsor, a prompt written notice of any condition or occurrence which constitutes an Event of Default under Section 5.1 hereof immediately upon becoming aware of the existence thereof. LKL-ll/16/88-267 AA-2821 -21- I I ARTICLE VI MISCELLANEOUS SECTION 6.1 LIMITATION OF LIABILITY. In the event of any default by the Sponsor hereunder, the liability of the Sponsor or the Credit Facility Issuer to the Governmental Unit shall be enforceable only out of its interest under this Agreement and there shall be no other recourse for damages by the Governmental Unit against the Sponsor, the Credit Facility Issuer, its officers, members, agents and employees, or against any of the property now or hereafter owned by it or them. In the event of any default by the Governmental Unit hereunder, the liability of the Governmental Unit shall be enforceable only out of the Pledged Revenues, and there shall be no other recourse for damages by the Sponsor or the Credit Facility Issuer against the Governmental Unit, its officers, members, agents and employees. SECTION 6.2 NO PERSONAL RECOURSE. Neither any member nor any officer, employee or agent of the Governmental Unit nor any person executing the Loan Agreement or Governmental Unit Note shall be personally liable on the Loan or the Bonds by reason of the issuance thereof. SECTION 6.3 NOTICES. Notice hereunder shall be effective upon receipt and shall be given by certified mail, return receipt reques~ed, to: As to the Sponsor: City Manager City of Gulf Breeze P.O. Box 640 Gulf Breeze, Florida 32561 As to the Trustee: Sun Bank, National Association 225 E. Robinson Street, Suite 350 Orlando, Florida 32801 Attn: Corporate Trust As to the Governmental Unit: City of Clearwater 112 S. Osceola Avenue Clearwater, Florida 33518 A ttn: City Manager LKL-11/16/88-267 AA-2821 -22- J I As to the Credit Facility Issuer: Financial Guaranty Insurance Company 175 Water Street, 15th Floor New York, New York 10038 A ttn: President As to the Liquidity Facility Issuer: COGB Liquidity Facility and Blount Building 3 West Garden Street Pensacola, Florida 32501 The Bank of Tokyo, Ltd., New York Agency 100 Broadway New York, New York 10005 SECTION 6.4 ILLEGAL OR INY ALID PROVISIONS DISREGARDED. In case any provision of this Agreement shall for any reason be held invalid, illegal or unenforceable in any respect, this Agreement shall be construed as if such provision had never been contained herein. SECTION 6.5 APPLICABLE LAW. This Agreement shall be deemed to be a contract made in Florida and governed by Florida law. SECTION 6.6 ASSIGNMENTS. The Governmental Unit shall not assign this Agreement or any interest of the Governmental Unit herein, either in whole or in part. The Administrator on behalf of the Sponsor hereby assigns this Agreement and the Governmental Unit Note attached hereto to the Trustee as provided in Section 3.9 hereof. Except as provided in Section 3.9 hereof this Agreement shall be binding upon and shall inure to the benefit of the successors and assigns of the parties hereto. SECTION 6.7 AMENDMENTS. This Agreement may not be amended except by an instrument in writing signed by the parties and with the consent of each provider of a Local Letter of Credit, if any, and the Credit Facility Issuer, and, if such amendment occurs after the issuance of the Bonds, with consent of the Trustee if required by Section 8.03 of the Indenture. SECTION 6.8 TERM OF AGREEMENT. This Agreement and the respect- ive obligations of the parties hereto shall be in full force and effect from the date hereof until the principal of and all interest on the Loan shall have been paid in full and the Governmental Unit shall have complied with Section 4.1(b) hereof. SECTION 6.9 HEADINGS. The captions or headings in this Agreement are for convenience of reference only and shall not control or affect the meaning or construction of any provision hereof. SECTION 6.10 SUPERSEDING CLAUSE. This Agreement is the entire final agreement between the respective parties and supersedes all other agreements, whether written or oral, except that this Agreement is not intended to supersede or displace any interlocal agreement previously recorded in the public records of the Sponsor and the Governmental Unit except to the extent this Agreement is inconsistent therewith. LKL-ll/30/88-267 AA-2821 -23- I I '. IN WlTNK88 WHERBOF. the parti.. hereto, intending to be leplly bound, have caused this Agreement to be executed and deUvered u of the date tint written above. JACKSON C. Tu'l-n.aX, City Manager Admlniltrator O~/$~ / WITNESSa //tdZ/L_;--<,7 R ~~ ~~ ~(?~ LKL.1l/16/88-267 AA-2821 .24- I (SEAL) Attest: ') c' U BY:.~Yv~ <,',' ..-J:...k-~ City fierk Approved as to Form and Correctness: ~~ City Attorney . LKL-ll/16/88-267 AA-2821 -25- I CITY OF CLEARWATER, FLORIDA Governmental Unit Br- jJ}k By: 4 ?L -62.L City Manager - Attest: By:' Vice President I /"" / \ ~. .. I'j \. ~ V '\__j \ .. LKL-l1/16/88-Z6SAA-2822 . SUN BANK, HAboNAL ASSOClA'nON Trustee Byz ~ L C( , j l-('>Jlz- Corporate Trust O~f1eer -28- I I EXHIBIT A $980,000 Loan Project park land. The acquisition of 15.61 acres of land known as the "Vogel Property" for use as LKL-ll/16/88-267 AA-2821 -27- I I EXHIBIT B PROMISSORY NOTE For value received, the City of Clearwater, Florida, a municipal corporation organized and existing under the laws of the State of Florida (the "Governmental Unit") hereby promises to pay to the holder hereof or to its order, solely from the Pledged Revenues hereafter mentioned the principal sum of Nine Hundred Eighty Thousand Dollars ($980,000) and to pay, solely from such sources, interest thereon from the date hereof, as follows: (a) The principal hereof shaU be paid in monthly instaUments on the dates and in the amounts shown on "Schedule I" attached hereto; and the entire unpaid principal balance hereof, together with accrued interest thereon as provided below, shall be due and payable in full as set forth on said "Schedule I"; and (b) Interest on the unpaid principal balance hereof shall be paid on the first day of February, 1989, and on the first day of each month thereafter, at a rate determined from time to time by the Financial Advisor as defined in, and as described in the Loan Agreement of even date herewith between the City of Gulf Breeze, Florida (the "Sponsor") and the Governmental Unit (the "Loan Agreement"); provided, however, that (i) if an acceleration of the Loan made pursuant to the Loan Agreement is declared following the occurrence of an event of default under the Loan Agreement, the interest rate hereon shall be increased to a rate per annum equal to the Prime Rate (as defined in the Loan Agreement) plus 296. Said rate shall be based upon a 365/366 day year for the actual days elapsed and shall change when and as said Prime Rate shall change. Notwithstanding anything otherwise contained in this Note, the interest rate on this Note (excluding any amounts which do not represent charges for the use or forebearance of money) shall not exceed twenty-five percent (2596) per annum or such higher rate as may from time to time be permitted under applicable law; provided, that, in the event the imposition of such Maximum Rate shaU ever cause the amount payable on this Note to be less than the amount of interest which would otherwise be computed pursuant to the Loan Agreement, this Note shall thereafter bear interest at the Maximum Rate until the earlier of (1) the final maturity of this Note or (2) such time as the total amount of interest paid on this Note shall at such rate equal the amount of interest which would have been payable on this Note pursuant to Section 3.3 of the Loan Agreement without regard to any Maximum Rate. The interest rate on this Note may be converted to a fixed rate under certain circumstances described in the Loan Agreement. In addition to the above payments of principal and interest, late payments of any amount due under this Note will bear interest at a rate per annum equal to the Prime Rate plus 296. The payments described in paragraph (b), above, will include an amount determined by the Administrator to be sufficient to pay certain fees described in Section 3.5(a) of the Loan Agreement. All payments made hereunder shall be applied first to payment of accrued interest on the unpaid principal balance hereof at the aforesaid rate, and then to LKL-l1/30/88-267 AA-2821 -28- I I reduction of principal. In the event the full amount of this Note is not disbursed, the payments of principal due hereunder shall be reduced ratably to reflect such reduction in the principal amount due hereunder. The principal hereof and interest hereon shall be paid at such place as the holders hereof may designate in writing. This Note evidences a loan made to the Governmental Unit pursuant to the Loan Agreement dated as of December 1, 1988, to finance or refinance the Governmental Unit's cost of acquisition and installation of the Project described in the Loan Agreement (the "Project") and the Governmental Unit has executed this Note to secure all payments due under said Loan Agreement. Such loan is being made by the City of Gulf Breeze, Florida (the "Sponsor"), from the proceeds of its Local Government Loan Program Floating Rate Demand Revenue Bonds, Series 1985A (the "Bonds"). The Bonds are issued under a Trust Indenture dated as of December 1, 1985, as amended and restated as of July 1, 1986, as further amended and supplemented (the "Indenture") between the Sponsor and Sun Bank, National Association, as Trustee. The Governmental Unit's obligations hereunder are limited, special obligations payable solely from the Pledged Revenues in the manner set fortn in the Loan Agreement. This Note may be paid prior to maturity in the manner and with the penalties specified in Section 3.4 of the Loan Agreement. This Note, and all payments due in this Note does not constitute a general indebtedness of the Governmental Unit, or a pledge of its faith, credit or taxing power within the meaning of any constitutional or statutory provision or limitation. Neither the State of Florida nor any political subdivision thereof nor the Governmental Unit shall be obligated (1) to exercise its ad valorem taxing power or any other taxing power in any form on any real or personal property in the Governmental Unit to pay the principal of this Note, the interest thereon or other payments or costs incident thereto, or (2) to pay the same from any other funds of the Governmental Unit except from the Pledged Revenues. This Note and the indebtedness evidenced thereby shall not constitute a lien upon any property of the Governmental Unit, but shall constitute a lien only on the Pledged Revenues, in the manner provided in the Loan Agreement. The Governmental Unit shall be in default hereunder upon: (i) the nonpayment on or before the date the same is due of any payment described in paragraph (a) or (b) of this Note, or (ii) upon the occurrence of any other Event of Default described in the Loan Agreement which is not corrected within the applicable period therein specified, if any, and after the giving of any required notice. In the event of such default hereunder, the holder hereof shall have the following rights or remedies: (i) the entire unpaid amount of the principal of this Note and all other amounts which the Governmental Unit is obligated to pay under the Loan Agreement, .including but not limited to, those sums payable under Section 5.2 of the Loan Agreement, shall become immediately due and payable in full without notice to or demand on the Governmental Unit of any kind and without presentation, demand or protest, all of which are hereby waived; and (ii) the holder may at its option exercise from time to time any and all rights and remedies available to it under the Loan Agreement. No failure of the holder hereof to exercise any right hereunder shall be construed as a waiver of the right to exercise the same or any other right at any other time. LKL-12107 /88-267 AA-2821 -29- I I In addition to all other rights it may have, the holder hereof shall have the following rights, each of which may be exercised at any time: (i) to pledge, transfer or assign this Note in the manner prescribed therein and any renewals, extensions and modifications hereof, assigning therewith its rights in the Loan Agreement in accordance with the terms thereof and any such pledgee, transferee or assignee shall have all the rights of the holder hereof with respect to this Note and any renewals, extensions and modifications hereof and of the Loan Agreement so assigned therewith, and the holder hereof making such pledge, transfer or assignment shall be thereafter relieved from any and all liability with respect to the Loan Agreement so assigned; (ii) to notify the Governmental Unit or any other persons obligated under the Loan Agreement to make payment to the holder of this Note any amounts due or to become due thereon; and (iii) to apply any amounts received under or pursuant to the Loan Agreement against the principal of and interest on and other amounts payable under this Note. Upon the request of the holder hereof, this Note may be converted to a registered obligation and the Governmental Unit shall maintain books for the registration of the transfer and exchange of this Note in compliance with the Florida Registered Public Obligations Act. The terms and conditions of the Loan Agreement are made a part of this Note as fully as if set forth in full herein. Except as otherwise provided herein, all capitalized terms used herein which are defined in the Loan Agreement shall have the meanings set forth in the Indenture. LKL-1l/16/88-267 AA-2821 -30- I I IN WITNESS WHEREOF, the City of Clearwater, Florida has caused this Note to be executed in its name, and its corporate seal to be affixed hereto and attested, by its duly authorized officers, this _ day of , 198_ CITY OF CLEARWATER, FLORIDA By: Mayor-Co m miss ioner (SEAL) Attest: By: City Manager By: City Clerk Approved as to Form and Correctness: City Attorney LKL-ll/16/88-267 AA-2821 -31- J "Schedule 1" I The principal amount of $8,166.67 shall be due on February 1, 1989 and on the first day of each month thereafter through and including December 1, 1998, and all unpaid principal shall be due on January 1, 1999. LKL-1l/16/88-267 AA-2821 -32- I I EXHIBIT C GENERAL CERTIFICATE This certificate is made by the City of Clearwater, Florida (the "Governmental Unit") to City of Gulf Breeze, Florida (the "Sponsor"), Sun Bank, National Association, as Trustee and to Financial Guaranty Insurance Company (the "Credit Facility Issuer"), and to their respective c0unsel and bond counsel to the Sponsor, in connection with a loan from the Sponsor to the Governmental Unit in the amount of $980,000 (the "Loan") from the proceeds of the Sponsor's $100,000,000 aggregate principal amount Local Government Loan Program Floating Rate Demand Revenue Bonds, Series 1985C (the "Bonds"). The Loan is evidenced by the Governmental Unit's promissory note of even date herewith (the "Governmental Unit Note"). The Sponsor is making the Loan to the Governmental Unit for the purpose of financing or refinancing the Governmental Unit's cost of the acquisition and installation of certain qualified projects (the "Project"), as more particularly described in Exhibit "A" attached to the Loan Agreement of even date herewith (the "Loan Agreement") between the Sponsor and the Governmental Unit. The Governmental Unit, by the undersigned officers, hereby certifies that: 1. The Governmental Unit is a municipal corporation duly organized and validly existing under the laws of the State of Florida. The Governmental Unit has full power and legal right to enter into, and perform its obligations under, the Loan Agreement and the Governmental Unit Note of even date herewith between the Sponsor and the Governmental Unit. 2. Attached hereto as Exhibit "A-I" is a true, correct and complete certified copy of Ordinance No. 4728-88 of the City Commission of the Governmental Unit, approving and authorizing the execution and delivery of the Governmental Unit Note and the Loan Agreement (the "Ordinance"). Such Ordinance was duly enacted in accordance with all procedural rules as specified in Chapter 166, Florida Statutes and, if applicable, the Charter of the Governmental Unit. Said Ordinance has not been amended, modified or repealed and is in full force and effect on the date hereof. 3. The names of the members of the governing body of the Governmental Unit, their respective offices and the dates of expiration of their respective terms of office are as follows: Name Title Term Begins Term Ends Rita Garvey Mayor-Commissioner April, 1987 April, 1990 James L. Berfield Co m missioner April, 1986 April, 1989 Lee Regulski Co m missioner April, 1987 April, 1990 Don Winner Commissioner April, 1987 April, 1990 William Nunamaker Commissioner April, 1987 April , 1989 4. Such of the above persons as are required by law to file oaths of office and bonds or undertakings have duly filed such oaths and filed such bonds or undertakings in the amount and manner required by law. LKL-12/07/88-267 AA-2821 -33- I I 5. Each of the below named individuals which have executed the Loan Agreement and the Governmental Unit Note, and which will execute requisitions for disbursement of the Loan, has been duly elected as a member of the governing body of the Governmental Unit, in the case of the Mayor, or has been duly appointed as City Manager by the governing body of the Governmental Unit, in the case of the City Manager, and is authorized to act for and on behalf of the Governmental Unit in connection with the execution of such documents, and the signature set opposite the name of such officer is a genuine specimen of such officer's signature: Name Specimen Silnlature Office Rita Garvey Mayor Ron H. Rabun City Manager 6. We further certify that on , 1988, the Governmental Unit Note was executed by the manual signatures of the undersigned Mayor and City Manager, and attested by the City Clerk, of the Governmental Unit. 7. We further certify that at the date of the Governmental Unit Note, and on this date, such officers were and are the duly chosen, qualified and acting officers authorized to execute the Governmental Unit Note. 8. The undersigned did, on , 1988, duly execute and attest, respectively, on behalf of the Governmental Unit and deliver to the other parties thereto, the Loan Agreement. 9. The Pledged Revenues described in the Loan Agreement have not been pledged in whole or in part, directly or indirectly, for the benefit of any obligations previously issued by the Governmental Unit and are not subject to any other encumbrance, other than as has been disclosed to and approved by the Credit Facility Issuer pursuant to the Loan Agreement. 10. (a) The portion of the Loan financing the original cost of the Governmental Unit's acquisition of the Project listed in Exhibit "A" attached to the Loan Agreement, together with the estimated interest earnings on the undisbursed portion of the Loan, does not exceed the actual cost of such acquisition. (b) The Project identified in Exhibit "A" attached to the Loan Agree- ment was acquired by the Governmental Unit prior to the date hereof, but the funds used for such acquisition were loaned from other temporarily available surplus funds of the Governmental Unit, and at the time such acquisition was authorized, the governing body of the Governmental Unit expressly contemplated and intended that such temporary funds be replenished from the proceeds of a longer-term permanent loan such as the Loan. (c) No portion of the Loan will be used to finance any Project which is used in the trade or business of a person who is not an "exempt person" as defined in Section 103(b)(3) of the Internal Revenue Code of 1954, as amended (as in effect on LKL-12/07 /88-267 AA-2821 -34- I I December 31, 1985). In this regard the Governmental Unit further certifies that (i) not in excess of ten percent (1096) of the net proceeds of the Governmental Unit Note will be used for Private Business Use if, in addition, the payment of more than ten percent (1096) of the principal or ten percent (1096) of the interest due on such Governmental Unit Note during the term thereof is, under the terms of such Governmental Unit Note or any underlying arrangement, directly or indirectly, secured by any interest in property used or to be used for a Private Business Use or in payments in respect of property used or to be used for a Private Business Use or is to be derived from payments, whether or not to the Governmental Unit, in respect of property or borrowed money used or to be used for a Private Business Use; and (ii) that, in the event that both (A) in excess of five percent (596) of the Net Proceeds of such Governmental Unit Note are used or have been used for a Private Business Use, and (B) an amount in excess of five percent (596) of the principal or five percent (596) of the interest due on such Governmental Unit Note during the term thereof is, under the terms of such Governmental Unit Note or any underlying arrange- ment, directly or indirectly, secured by any interest in property used or to be used for said Private Business Use or in payments in respect of property used or to be used for said Private Business Use or is to be derived from payments, whether or not to the Governmental Unit, in respect of property or borrowed money used or to be used for said Private Business Use, then said excess over said five percent (596) of Net Proceeds of the Governmental Unit Note used for a Private Business Use has been or shall be used for a Private Business Use related to the governmental use of the Project. The term "Private Business Use" means use directly or indirectly in a trade or business carried on by a natural person or in any activity carried on by a person other than a natural person, excluding, however, use by a state or local governmental unit and use as a member of the general public. 11. The Governmental Unit is not in breach of or in default under any existing law, court or administrative regulation, decree, order, agreement, indenture, mortgage, lease, sublease or other instrument to which it is a party or by which it is bound, and no event has occurred or is continuing which, with the passage of time or the giving of notice, or both, would constitute a default or an event of default thereunder, except for such minor breaches, defaults or potential defaults or events of default, if any, " which individually and in the aggregate would have no material adverse effect on the Governmental Unit's financial condition, operations or properties. 12. The execution and delivery, receipt and due performance by the Govern- mental Unit of the Loan Agreement, the Governmental Unit Note, and the Loan Documents hereafter described and compliance with the provisions thereof, do not and will not conflict with or result in the breach of any of the terms, conditions or provisions of, or constitute a default under the Charter, any existing resolution or ordinance of the Governmental Unit, any existing law, court or administrative regulation, decree, order or any agreement, indenture, lease or other instrument to which the Governmental Unit is a party or by which it or any of its properties is bound. 13. There is no action, suit, proceeding, inquiry or investigation at law or in equity before or by any court, public board or body pending or, to the knowledge of the Governmental Unit after due inquiry, threatened against or affecting the Governmental Unit, which has not been disclosed in writing to the Credit Facility Issuer, contesting the due organization of the Governmental Unit, or wherein an unfavorable decision, ruling or LKL-12/07/88-267 AA-2821 -35- I I finding (i) would have a material adverse effect on the financial condition of the Governmental Unit, the operation by the Governmental Unit of the Project, its facilities and its other properties, or an adverse effect on the functioning of the Governmental Unit or payment by the Governmental Unit of the amounts due under the Loan Agreement in the manner and time required thereby, or the tax-exempt status of the Governmental Unit or the Governmental Unit Note, or (ii) would have an adverse effect on the validity or enforceability of the Governmental Unit Note, the Loan Agreement, or the Ordinance of the Governmental Unit authorizing the Governmental Unit Note and the execution of other documents in connection therewith (the "Loan Documents"). 14. No final judgment for the payment of money has been rendered against the Governmental Unit, unless within 60 days from the entry thereof, (i) such judgment has been discharged or (ii) the Governmental Unit has taken and is diligently prosecuting an appeal therefrom, or from the order, decree or process, upon which or pursuant to which such judgment was granted or entered, and has caused the execution or levy under such judgment, order, decree or process or the enforcement thereof to be stayed pending the determination of such appeal, or (iii) the Governmental Unit has provided for the payment or securing of such judgment in a manner satisfactory to the Credit Facility Issuer. 15. The Governmental Unit has duly performed and complied with all the obligations, agreements and conditions on its part to be performed or complied with at or prior to the closing. Each of the representations, warranties and other information contained in the the Governmental Unit's loan application is true and correct and does not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements in such documents, in light of the circumstances under which they were made, not misleading and has not changed since the date of the Governmental Unit's loan application. The Governmental Unit has authorized, by all necessary action, the execution, delivery, receipt and due performance of the Governmental Unit Note, the Loan Documents and any and all such other agreements and documents as may be required to be executed, delivered and received by the Governmental Unit to carry out, give effect to and consummate the transactions contemplated by the Loan Agreement relating to the Governmental Unit Note, and such authorization has not been modified, amended or repealed. 16. The Governmental Unit Note has been duly authorized pursuant to the Loan Agreement and the Ordinance in the forms delivered by the Governmental Unit in connection with the issuance of the Governmental Unit Note on the date hereof. The Ordinance was duly enacted in accordance with all procedural rules applicable to the Governmental Unit, and has not been the subject of repeal or modification since the date of its enactment and is in full force and effect as of the date hereof. 17. To the best of our knowledge, no event affecting the Governmental Unit has occurred since the date of the Governmental Unit's loan application which either makes untrue or incorrect in any material respect as of the date of Closing any statement or information contained in the Governmental Unit's loan application, and all of such information contained in the Governmental Unit's loan application, including all financial information contained therein, is true and correct as of the date hereof. LKL-12/07/88-267 AA-2821 -36- 18. We furler certify that the seal impressed !pon this certificate is the legally adopted, proper and only official seal of the Governmental Unit; and that the seal has been impressed or imprinted upon the Governmental Unit Note. 19. The representations and warranties pertaining to the Governmental Unit as contained in the Loan Documents and any other documents incident to the transaction described therein are true and correct as of the date hereof; no default has occurred with regard to any of the obligations of the Governmental Unit, and no event has occurred as of the date hereof which would bring about or constitute any such default. 20. We have no knowledge of any legislation adopted by the 1988 Session of the Florida Legislature that restricts or otherwise adversely affects the Governmental Unit's power to issue the Governmental Unit Note or its ability to provide for the payment of the principal thereof and interest thereon in the manner provided in the Loan Agreement or the Indenture. LKL-12/07/88-267 AA-2821 -37- I I IN WITNESS WHEREOF, the below-named officers of the Governmental Unit have hereunto set their respective signatures as such officers and have affixed the corporate seal of the Governmental Unit this _ day of December, 1988. (SEAL) CITY OF CLEARWATER, FLORIDA Governmental Unit ATTEST: By: City Clerk By: Mayor By: City Manager Approved as to form and correctness: City Attorney LKL-12/07l88-267 AA-2821 -38- I I EXlllBIT D (Letterhead of Governmental Unit Counsel) December _' 1988 City of Gulf Breeze Gulf Breeze, Florida Livermore Klein &. Lott, P.A~ Jacksonville, Florida Sun Bank, National Association Orlando, Florida Financial Guaranty Insurance Company New York, New York Re: $980,000 Loan from City of Gulf Breeze, Florida, Local Government Loan Program to City of Clearwater, Florida Ladies and Gentlemen: As counsel for the City of Clearwater, Florida (the "Governmental Unit"), I am delivering this opinion to you in connection with the consummation of a loan by City of Gulf Breeze, Florida (the "Sponsor") to the Governmental Unit in the amount of $980,000 (the "Loan") from the proceeds of the Sponsor's $100,000,000 Local Government Loan Program Floating Rate Demand Revenue Bonds, Series 1985C (the "Bonds"). The Loan is being made pursuant to a Loan Agreement of even date herewith (the "Loan Agreement") between the Sponsor, the Governmental Unit, Sun Bank, National Association (the "Trustee"), and Jackson C. Tuttle, City Manager (the "Administrator") to finance the Governmental Unit's cost of the acquisition of certain qualified projects of the Governmental Unit (the "Project"). The Loan is evidenced by the Governmental Unit's promissory note in the principal amount of $980,000 (the "Governmental Unit Note"). As provided in the Loan Agreement, the Loan Agreement and the Governmental Unit Note may be assigned to a credit facility issuer for the Bonds (the "Credit Facility Issuer") under certain circumstances. It has been represented to me that: (i) the Bonds were issued pursuant to Chapter 125, Florida Statutes as amended, Chapter 166, Florida Statutes, as amended, Chapter 163, Florida Statutes, as amended, Chapter 159, Part I, as amended, and other applicable provisions of law for the purpose of financing and refinancing the cost of the acquisition and installation of qualified projects in the State of Florida; (ii) the Sponsor intends to lend the proceeds of the Bonds to eligible governmental units by entering into a loan agreement with each participating governmental unit; (iii) it is intended that such agreements, in the aggregate, will provide for the payment by the governmental units of amounts sufficient to pay the principal of and interest on the Bonds and other costs incurred in connection with the Sponsor's loan pool program; and (iv) the Bonds are secured by an assignment and pledge to Sun Bank, National Association, Orlando, Florida, as trustee under a Trust Indenture dated as of December 1, 1985, as amended and restated as of July 1, 1986, as further amended and supplemented (the "Indenture") of certain of the Sponsor's rights under such loan agreements, including the Loan Agreement, and by a pledge of the notes given by the governmental units evidencing such loans, including the Governmental Unit Note. LKL-12107/88-267 AA-2821 -39- ... At a closing i~eld tod.ay, the Governmental Unit. hall executed and delivered to the Sponsor, the Loan A~eement and the Governmental UnIt ~ute. As counsel for the Governmental Unit, I have examined the originals or certified copies of each of the agreements and instruments referred to above and Ordinance No. 4728-88 duly enacted by the City Commission of the Governmental Unit on December 15, 1988 (collectively, the "Ordinance"). I have also examined such other documents and certificates, made such inquiries of officers and employees of the Governmental Unit and others and considered such other matters of fact and questions of law as I deemed necessary for the purpose of giving this opinion. Based on the foregoing, I am of the opinion that: 1. The Governmental Unit is validly existing as a municipal corporation of the State of Florida and has full power and authority to conduct its operations, to enact the Ordinance, to enter into, execute and deliver the Loan Agreement and the Governmental Unit Note, and to perform all acts necessary to effectuate and consummate the transactions contemplated thereby. 2. The Ordinance has been duly enacted, and the Loan Agreement and the Governmental Unit Note have been duly authorized, executed and delivered by the Governmental Unit and constitute binding and enforceable agreements of the Governmen- tal Unit in accordance with their respective terms (SUbject as to enforcement of remedies to any applicable bankruptcy, reorganization, insolvency, moratorium or other laws or equitable principles affecting the enforcement Ot" of creditors' rights generally from time to time in effect.) 3. The Governmental Unit is not in breach of or in default under any existing law, court or administrative regulation, decree, order, agreement, indenture, mortgage, lease, sublease or other instrument to which it is a party or by which it is bound, and no event has occurred or is continuing which, with the passage of time or the giving of notice, or both, would constitute a default or an event of default thereunder, except for such minor breaches, defaults or potential defaults or events of default, if any, which individually and in the aggregate would have no material adverse effect on the Governmental Unit's financial condition, operations or properties. 4. The execution and delivery of the Loan Agreement and the Governmen- tal Unit Note and compliance with the provisions thereof, do not and will not conflict with or result in the breach of any of the terms, conditions or provisions of, or constitute a default under, the enabling legislation and Charter of the Governmental Unit, any existing ordinance or resolution of the governing body of the Governmental Unit, any existing law, court or administrative regulation, decree, order or any agreement, indenture, lease or other instrument to which the Governmental Unit is a party or by which it or any of its properties is bound. 5. All requirements imposed by Section 163.01, Florida Statutes, as amended, as preconditions to the effectiveness of the Loan Agreement as an interlocal agreement under such section have been met and the Loan Agreement constitutes a valid, binding and enforceable interlocal agreement under the provisions of such Section. LKL-12/07/88-267 AA-2821 -40- I tl 6. There is no action, suit, proceeding, inquiry or investigation at law or in equity before or by any court, public board or body pending or, to our knowledge, threatened against or affecting the Governmental Unit which has not been disclosed in writing to the Credit Facility Issuer, nor, in our opinion is there any meritorious basis therefor, contesting the due organization of the Governmental Unit, or wherein an unfavorable decision, ruling or finding (i) would have a material adverse effect on the financial condition of the Governmental Unit, the operation by the Govern(T\i:~ntal Unit of the Project, its facilities and its other properties, or an adverse effect on tilt functioning of the Governmental Unit or payment by the Governmental Unit of the amounts due under the Loan Agreement in the manner and time required thereby, or (ii) would have an adverse effect on the validity or enforceability of the Governmental Unit Note or the Loan Agreement. " , ~ 7. No final judgment for the payment of money has been rendered against the Governmental Unit, unless within 60 days from the entry thereof, (i) such judgment has been discharged or (ii) the Governmental Unit has taken and is diligently prosecuting an appeal therefrom, or from the order, decree or process, upon which or pursuant to which such judgment was granted or entered, and has caused the execution or levy under such judgment, order, decre~ or process or the enforcement thereof to be stayed pending the determination of such appeal, or (Hi) the Governmental Unit has provided for the payment or securing of such judgment in a manner satisfactory to the Credit Facility Issuer. 8. The Pledged Revenues described in the Loan Agreement have not been pledged in whole or in part, directly or indirectly, for the benefit of any obligations previously issued by the Governmental Unit, except as specifically described in the Loan Agreement, and are not subject to any other encumbrance, except as specifically described in the Loan Agreement. 9. We have no knowledge of any legislation adopted by the 1988 Session of the Florida Legislature that restricts or otherwise adversely affects the Governmental Unit's power to issue the Governmental Unit Note or its ability to provide for the payment of the principal thereof and interest thereon in the manner provided in the Loan Agreement and the Indenture. Very truly yours, M. A. Galbraith, Jr. LKL-12/07/88-267 AA-2821 -41- tI4