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92-54RESOLUTION NO. 92 -54 A RESOLUTION AUTHORIZING THE ISSUANCE OF $3,425,000 AGGREGATE PRINCIPAL AMOUNT OF CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992 (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) ; PROVIDING FOR THE FORMS OF TRUST INDENTURE AND LOAN WORK- OUT AGREEMENT; AUTHORIZING EXECUTION OF TRUST INDENTURE AND LOAN WORK -OUT AGREEMENT; APPROVING BOND PURCHASE AGREEMENT RELATING TO THE NEGOTIATED SALE OF THE BONDS TO THE UNDERWRITERS; APPOINTING A TRUSTEE, REGISTRAR AND PAYING AGENT WITH RESPECT TO THE BONDS; AUTHORIZING THE DISTRIBUTION OF AN OFFICIAL STATEMENT IN CONNECTION WITH THE ISSUANCE AND DELIVERY OF SUCH BONDS; AUTHORIZING REDEMPTION OF CERTAIN PRIOR BONDS; AND PROVIDING AN EFFECTIVE DATE. WHEREAS, the City Commission of the City of Clearwater, Florida (the "Issuer ") by this Resolution (the "Resolution ") and as authorized by Ordinance No. 5256 -92 (the "Ordinance ") , expresses its agreement as to the issuance of the Issuer's Mortgage Revenue Refunding Bonds, Series 1992 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) (the "Bonds "), in the aggregate principal amount of $3,425,000, for the purpose stated in the ordinance and providing for other matters consistent therewith; and WHEREAS, the Issuer desires to approve the forms of Trust Indenture and Loan Work -Out Agreement to be executed in connection with the issuance of the Bonds; and WHEREAS, the Issuer wishes to approve the form of the Official Statement and to authorize distribution thereof in connection with the issuance and delivery of its Bonds; and WHEREAS, the Issuer intends to negotiate the sale of the Bonds as hereinafter provided with Banc One Capital Corporation and Newman & Associates, Inc. (collectively, the "Underwriters ") pursuant to a Bond Purchase Agreement; and WHEREAS, the Issuer now desires to provide for the form of the foregoing documents to facilitate the issuance and delivery of the Bonds. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF CLEARWATER, FLORIDA, as follows: SECTION 1. In accordance with the Ordinance, there is hereby authorized and directed to be issued the Issuer's Mortgage Revenue Refunding Bonds, Series 1992 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) (the "Bonds "), in the aggregate principal amount of $3,425,000. The Bonds shall be issued under and secured by the Indenture referred to below which by reference is hereby incorporated in this Resolution as if set forth in full herein. The Bonds shall mature in the amounts and at the times, shall bear interest at the rates, be redeemable at the redemption prices and upon the terms as shall be set forth in the Indenture (as hereinafter defined) and in the Bond Purchase Agreement (as hereinafter approved) . The Bonds shall be executed, authenticated and delivered by the officers of the Issuer authorized below in substantially the form set forth in the Indenture in fully regis- tered form. SECTION 2. The Trust Indenture (the "Indenture ") , in sub- stantially the form attached hereto as Exhibit "A ", is hereby approved, and the Mayor and Clerk of the Issuer are hereby authorized and directed to execute and deliver the Indenture on 2 behalf of and in the name of the Issuer with such additional changes, insertions and omissions therein including, but not limited to, the insertion of rates, maturities and other details of the Bonds determined as herein provided and as may be made prior to the delivery of the Bonds, and as may be otherwise made and approved by the said officers of the Issuer executing the same, such execution to be conclusive evidence of such approval. SECTION 3. The Loan Work -Out Agreement in substantially the form attached hereto as Exhibit "B" (the "Agreement "), is hereby approved, confirmed and ratified and the Mayor and Clerk are hereby authorized and directed to execute and deliver the Agreement on behalf of and in the name of the Issuer with such additional changes, insertions and omissions therein as implement the provisions of the Bond Purchase Agreement (hereinafter mentioned), and as may be otherwise made and approved by the said officers of the Issuer executing the same, such execution to be conclusive evidence of such approval. SECTION 4. It is hereby found and determined that due to the complexity of the financinq�.and the need to coordinate matters among the Rating Agency, the Issuer, Drew Gardens Associates, Ltd. (the "Owner "), and Bond purchasers, it is in the best interest of the Issuer to negotiate the sale of the Bonds. The disclosure required by Section 218.385, Florida Statutes, as amended, shall be provided to the Issuer, as evidenced by a schedule attached to the Bond Purchase Agreement hereinafter described, wherein the Underwriters agrees to provide disclosure to the Issuer prior to 3 execution by the Issuer of the Bond Purchase Agreement. The negotiated sale of $3,425,000 City of Clearwater, Florida Mortgage Revenue Refunding Bonds, Series 1992 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) is hereby approved to the Underwriters upon the terms and conditions set forth in the Bond Purchase Agreement, which is hereby approved in substantially the form attached hereto as Exhibit "C ". The Bond Purchase Agreement, with such changes, alterations and corrections as may be approved by the Mayor of the Issuer, such approval to be presumed by her execution thereof, is hereby approved by the Issuer, and the Issuer hereby authorizes said Mayor of the Issuer to execute and deliver (attested by the Clerk of the issuer) , said Bond Purchase Agreement in the name of and on behalf of the Issuer, all of the provisions of which, when executed and delivered by the Issuer as authorized herein shall be deemed to be a part of this instrument as fully and to the same extent as if incorporated verbatim herein. The Bonds are hereby sold to the Underwriters in the amount, at the price and upon the final terms set forth in the Bond Purchase Agreement. SECTION 5. The Issuer hereby approves the Preliminary Official Statement, relating to the Bonds in substantially the form attached hereto as Exhibit "D" and authorizes the use and distribution by the Underwriters of said Preliminary Official Statement and a Final Official Statement relating to the Bonds with such revisions as shall hereafter be approved by the Mayor of the Issuer and, with such approval and authorization, the distribution of such Final Official Statement by said Underwriters in connection 4 l�'S� with the sale and issuance of the Bonds. The Preliminary Official statement in the form attached hereto as Exhibit "D" is hereby deemed "nearly final" on behalf of the Issuer, as required by Rule 15c2 -12 of the Securities Exchange Commission. SECTION 6. With respect to the Bonds, Bank One, Columbus, NA, Columbus, Ohio, is hereby appointed as Trustee, Registrar and Paying Agent pursuant to the Indenture. SECTION 7. All prior resolutions and motions of the Issuer inconsistent with the provisions of this Resolution are hereby modified, supplemented and amended to conform with the provisions herein contained and except as otherwise modified, supplemented and amended hereby shall remain in full force and effect. SECTION 8. To the extent that the Mayor or the Clerk of the Issuer are unable for any reason to execute or deliver the documents referred to above, such documents may be executed, a attested and /or delivered by any Commission Member of the Issuer or by an Assistant Clerk, with the same effect as if executed and/ or delivered by the Mayor or Clerk. SECTION 9. The Mayor and the Clerk and all other Commission members of the Issuer and the staff of the Issuer are hereby authorized and directed to execute any and all certifications or other instruments, agreement or documents required by the Indenture, the Agreement, the Bond Purchase Agreement, Bond Counsel or any other document referred to above as a prerequisite or precondition to the issuance of the Bonds and any representation made therein shall be deemed to be made on behalf of the Issuer. 5 tc 5V All action taken to date by the members of the Issuer and the staff of the Issuer in furtherance of the issuance of the Bonds is hereby i approved, confirmed and ratified. SECTION 10. The Issuer recognizes that Bank One, Columbus, NA, Columbus, Ohio, as trustee (the "Prior Trustee ") for the Issuer's Mortgage Revenue Bonds, Series 1983, (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) (the "Prior Bonds ") , has issued notice of.redemption of the Prior Bonds for redemption on September 1, 1992, in accordance with directions from the United States Department of Housing and Urban Development ( "HUD ") and pursuant to an assignment of the insured mortgage to HUD. To the extent as may be required in order to refund a portion of the Prior Bonds with proceeds of the Bonds, such redemption and the giving of notice is hereby ratified and approved. SECTION 11. This Resolution shall become effective immediately upon its adoption. PASSED AND ADOPTED by the City Commission of the City of Clearwater, Florida, this 13th day of August, 1992. (SEAL) CITY C014MISSION OF THE CITY OF CLEARW ER, FLO DA ATTEST: By: Mayor Ci C1eYk APPROVED AS TO FOP AND CORRECTN S: City A torn _y 6 EXHIBIT "A" TRUST INDENTURE CITY OF CLEARWATER, FLORIDA to BANK ONE, COLUMBUS, NA, Columbus, Ohio, As Trustee Securing the Issuance of $3,425,000 Principal Amount of Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan - Drew Gardens Project) Dated as of August 1, 1992 This Instrument Prepared by: Robert C. Reid, Esquire BRY.ANT, MILLER AND OLIVE, P.A, 201 South Monroe Street Suite 500 Tallahassee, Florida 32301 5 I TABLE OF CONTENTS (This Table of Contents is not a part of the Trust Indenture but is only for convenience of reference.) Page PARTIES . . . . . . . . . . . . . . . . . . . . 1 RECITALS . . . . . . . . . . . . . . . . . . . . 1 FORM OF BOND . . . . . . . . . . . . . . . . . 3 GRANTING CLAUSES . . . . . . . . . . . . . . . . . . . . . 12 TRUST CLAUSES . . . . . . . . . . . . . . . . . . . . . . . . 13 ARTICLE I DEFINITIONS Section 1.01 Definitions . . . . . . . . . . . . . . . . . . 14 Section 1.02 Interpretation . . . . . . . . . . . . . . . . 20 ARTICLE II ARTICLE III REDEMPTION OR TENDER OF BONDS PRIOR TO MATURITY Section 3.01 THE BONDS . . 27 Section 2.01a The Bonds . . . . . . . . . . . . . . . 21 Section 2.01b Payments of Principal, Redemption Price . . 30 Section 3.04 and Interest . . . . . . . . . . . . . . 22 Section 2.02 Restriction on Issuance of Bonds . . . . . . . 22 Section 2.03 Limited Obligations . . . . . . . . . . . . . . 22 Section 2.04 Indenture Constitutes Contract . . . . . . . . 23 Section 2.05 Execution . . . . . . . . . . . . . . . . . 23 Section 2.06 Authentication . . . . . . . . . . . 23 Section 2.07 Mutilated, Lost, Stolen or Destroyed Bonds 23 Section 2.08 Transfer and Exchange of Bonds; Persons Treated as Owners . . . . . . . . . . . 24 Section 2.09 Temporary Bonds . . . . . . . . . . . . . . . 25 Section 2.10 Delivery of the Bonds . . . . . . . . . . . . . 25 ARTICLE III REDEMPTION OR TENDER OF BONDS PRIOR TO MATURITY Section 3.01 Redemption of Bonds Prior to Maturity . . . . . 27 Section 3.02 Selection of Bonds for Redemption . . . . . . . 29 Section 3.03 Notice of Redemption . . . . . . . . . . . . . 30 Section 3.04 Cancellation . . . . . • . . . . 32 Section 3.05 Effect of Notice of Redemption . . . . . . . . 32 i Page ARTICLE IV FUNDS; INVESTMENTS Section 4.01 Establishment of Bond Funds . . . . . . . . . . 33 Section 4.02 Application of Bond Proceeds and Other Amounts . . . . . . . . . . . . . . . 33 Section 4.03 Costs of Issuance Fund . . . . . . . . . . . . 33 Section 4.04 Program Fund . . . . . . . . . . . . . . . . . 33 Section 4.05 [Reserved] . . . . . . . . . . . . . . . . . . 33 Section 4.06 Bond Fund . . . . . . . . . . . . . . . . . . 33 Section 4.07 Debt Service Reserve Fund . . . . . . . . . . . 34 Section 4.08 Final Balances . . . . . * . . . . . 35 Section 4.09 Custody of Funds; Money to be Held in Trust 35 Section 4.10 Cancellation of Obligations . . . . . . . . . 35 Section 4.11 Investment of Funds . . . . . . . . . . . . 36 Section 4.12 Non - Presentment of Bonds . . . . . . . . . 36 Section 4.13 Calculations of Annual Debt Service; Yield . . 37 Section 4.14 Maintenance of Rebate Fund . . . . . . . . . . 38 Section 4.15 Prevention of Bonds Becoming Arbitrage Bonds 39 Section 4.16 Prohibited Payments . . . . . . . . . . . . . . 39 Section 4.17 Change in Regulations . . . . . . . . . . . . . 39 ARTICLE V GENERAL COVENANTS Section 5.01 Payment of Principal and Interest . . . . . . . 41 Section 5.02 Performance of Covenants; Authority of Issuer . . . . . . . . . . . . . . 41 Section 5.03 Instruments of Further Assurance . . . . . . . 41 Section 5.04 Inspection of Project Books . . . . . . . 42 Section 5.05 No Modification of Security; Additional Indebtedness . . . . . . . . . . . . . 42 Section 5.06 Damage, Destruction or Condemnation . . . . . . 42 Section 5.07 Ownership of FHA Note; Instruments of Further Assurance . . . . . . . 43 Section 5.08 Required Insurance . . . . . . 43 Section 5.09 Representations, Warranties and Additional Covenants of the Issuer . . . . . . . . . . . . 43 Section 5.10 Tax Covenants . . . . . . . . . . . . . . . . . 44 ii 4% Paae ARTICLE VI DEFAULT PROVISIONS AND REMEDIES OF TRUSTEE AND BONDHOLDERS Section 6.01 Events of Default . . . . . . . . . . . . . 45 Section 6.02 Acceleration; Other Remedies Upon Default . . . 45 Section 6.03 Rights of Bondholders . . . . . . . . . . . . . 47 Section 6.04 Waiver by Issuer . . . . . . . . . . . . . . . 47 Section 6.05 Application of Money . . . . . . . . . . . . . 47 Section 6.06 FHA Mortgage Insurance . . . . . . . . . . . . 48 Section 6.07 Opportunity to Cure Default Under . . 60 Section 7.08 Mortgage Note . . . . . . . . . . . . . . . 49 Section 6.08 Prepayment Penalty Lockout Period Claim . . 60 Section 7.10 Processing Procedures . . . . . . . . . . . . . 51 Section 6.09 Partial Assignment Option . . . . . . . . . . . 53 Section 6.10 Remedies Vested in Trustee . . . . . . . . . . 53 Section 6.11 Remedies of Bondholders . . . . . . . . . . . . 53 Section 6.12 Termination of Proceedings . . . . . . . . . . 54 Section 6.13 Waivers of Events of Default . . . . . . . . . 54 Section 6.14 Notice to Bondholders if Default Occurs . . . . 55 ARTICLE VII CONCERNING THE TRUSTEE Section 7.01 Standard of Care . . . . . . . . . . . . . . . 56 Section 7.02 Reliance Upon Documents . . . . . . . . . . . 57 Section 7.03 Use of proceeds . . . . . . . . . . . . . . 59 Section 7.04 Trustee May Hold Bonds . . . . . . . . . . . . 59 Section 7.05 Trust Imposed . . . . . . . . . . . . . . . . . 59 Section 7.06 Compensation of Trustee . . . . . . . . . . . . 59 Section 7.07 Maintenance of Office . . . . . . . . . . . . . 60 Section 7.08 Successor Trustee . . . . . . . . . . . . . . . 60 Section 7.09 Resignation by the Trustee . . . . . . . . . . 60 Section 7.10 Removal of the Trustee . . . . . .by 60 Section 7.11 Appointment of. Successor Trustee the Bondholders; Temporary Trustee . . . . . . . . 61 Section 7.12 Concerning Any Successor Trustee . . . . . . . 61 Section 7.13 Successor Trustee as Trustee, Paying Agent and Bond Registrar . . . . . . . . 62 Section 7.14 Servicing the Mortgage Loan; Mortgage Servicing Agreement . . . . . . . . . 62 Section 7.15 Co- Trustee or Separate Trustee . . . . . . . . 63 Section 7.16 Additional Security . . . . . . . . . . . . . . 65 Section 7.17 Representation by Trustee . . . . . . . . . . . 65 Section 7.18 Appointment, Resignation or Removal of Paying Agent; Successors . . . . . . . . . . 66 Section 7.19 Reports . . . . . . . . . . . . . . . . . . . . 67 ill Paae Section 7.20 Audit and Records . . . . . . . . . . . . . 67 Section 7.21 Special Procedures for Bonds Registered to DTC . . . . . . . . . . . . . . . . . . . . 67 ARTICLE VIII SUPPLEMENTAL INDENTURES AND AMENDMENTS OF CERTAIN DOCUMENTS Section 8.01 Supplemental Indentures Not Requiring Consent of Bondholders . . . . . . . . . . . . 68 Section 8.02 Supplemental Indentures Requiring Consent of Bondholders . . . . . . . . . . . . 68 Section 8.03 Amendment of Unanimous Consent . . . . . . . . 70 Section 8.04 Amendment of Certain Documents . . . . . . . . 70 iv ARTICLE IX SATISFACTION AND DISCHARGE OF INDENTURE Section 9.01 Discharge of Lien . . . . . . . . . . . . . . 72 ARTICLE X MISCELLANEOUS Section 10.01 Consents and Other Instruments of Bondholders . . . . . . . . . . . . . . . . 73 Section 10.02 Limitation of Rights . . . . 74 Section 10.03 Construction of Conflicts; Severabl:lity . . . . 74 Section 10.04 Notices . . . . . . . . . . . . . . . . . . . 74 Section 10.05 Trustee as Paying Agent and Bond Registrar 74 Section 10.06 Payments Due on Saturdays, Sundays and Holidays . . . . . . . . . . . . . 74 ' Section 10.07 Counterparts . . . . . . . . . . . . . . . 75 Section 10.08 Laws Governing Indenture and Situs and Administration of Trust . . . . . . . . . . . . 75 Section 10.09 No Recourse . . . . . . . . . . . . . . . . . . 75 Section 10.10 Role of Issuer . . . . . . . . . . . . . . 75 Section 10.11 Successors and Assigns . . . . . . . . . . . . 76 Section 10.12 HUD and FHA Requirements to Control . . . . . . 76 iv Pace TESTIMONIUM . . . . . . . • • • ' ' ' ' ' ' . . . 76 SIGNATURES AND SEALS . . . . . . . . . . . . . . . . EXHIBIT A -- LEGAL DESCRIPTION EXHIBIT B -- SCHEDULE OF MINIMUM CARRY - FORWARD BALANCES IN BOND FUND EXHIBIT C -- HUD LETTER OF JUNE 23, 1987 V 4"N TRUST INDENTURE THIS TRUST INDENTURE, made and entered into as of August 1, 1992, from the City of Clearwater, Florida (the "Issuer "), a muni- cipal corporation, organized and existing under the laws of the State of Florida, to Bank One, Columbus, NA, Columbus, Ohio, a national banking association duly organized and existing under the laws of the United States of America and authorized to accept and execute trusts of the character herein set out, with its principal office in the City of Columbus, Ohio, as Trustee (such trustee or any of its successors in trust being the "Trustee "); WHEREAS, the Issuer is authorized under the laws of the State of Florida, particularly Chapter 166, Part II, and Chapter 159, Part IV, Florida Statutes, and other applicable provisions of law (the "Act ") , to provide funds for the acquisition, construction, rehabilitation, remodeling and improvement of privately owned pro- jects comprising residential rental property for dwelling units; and WHEREAS, the Issuer is authorized and empowered pursuant to the Act to issue its revenue bonds and take other actions to finance, refinance, and provide other incentives for development of certain facilities; and WHEREAS, on October 12, 1983, the Issuer issued $6,450,000 aggregate principal amount of its Mortgage Revenue Bonds, Series 1983 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) (the "Refunded Bonds "), for the purpose of making a loan (the "Mortgage Loan ") to Drew Gardens Associates, Ltd., a Florida limited partnership, (the "Owner ") for the acquisition, construc- tion and equipping of a multifamily residential rental project located in Clearwater, Florida (the "Project "); and WHEREAS, pursuant to a Financing Agreement, dated as of September 1, 1983 (the "Prior Agreement ") , among the Issuer, the Prior Trustee (as defined below), Sun Bank, National Association, as co- trustee and the Owner, the Issuer provided funds to Bank One, Columbus NA, Columbus, Ohio, as trustee (the "Prior Trustee ") under the indenture (the "Prior Indenture ") securing the Refunded Bonds (i) to finance the Mortgage Loan insured by the Federal Housing Administration ( "FHA "), an organizational unit within the United States Department of Housing and Urban Development ( "HUD ") , in the principal amount of $6,094,900 evidenced by a Mortgage Note (the "Note ") from the Owner to the Prior Trustee secured by a first mortgage on the Project (the "Mortgage ") , the proceeds of which were advanced pursuant to a Building Loan Agreement between the Prior Trustee, as mortgagee of record, and the Owner, and (ii) to fund a Debt Service Reserve Fund under the Prior Indenture; and WHEREAS, the Owner is in default of its obligation to make payments to the Prior Trustee under the Note, and the Prior Trustee has, therefore, assigned the Note and the Mortgage to HUD pursuant to the provisions of the Prior Indenture; WHEREAS, HUD has confirmed that the FHA mortgage insurance benefits are payable to the Prior Trustee as a result of the default with respect to the Mortgage Loan and has paid mortgage insurance benefits to the Prior Trustee in connection with such Mortgage Loan default; and WHEREAS, under the terms of the Prior Indenture, the Refunded Bonds are subject to mandatory redemption at a redemption price equal to the principal amount thereof, plus accrued interest to the redemption date, to the extent money is available in the Bond Fund thereunder from whatever source on any date at the earliest prac- ticable date, as a whole or in part if FHA mortgage insurance pro- ceeds are payable to the Prior Trustee; and WHEREAS, the Owner and HUD have agreed to amend the Note to provide for, among other things, a reduction in the rate of Interest on the Note; and WHEREAS, in order to fulfill the public purpose of providing residential rental property for dwelling units within its juris- diction, the Issuer has determined to issue its Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan - Drew Gardens Project), in the aggregate principal amount of $3,425,000 (the "Bonds ") to provide for the current refunding of the Refunded Bonds; and WHEREAS, the proceeds of the Bonds transferred to the Prior Trustee will be sufficient, together with other amounts available for such purpose, to redeem the Refunded Bonds pursuant to the pro - visions described above; and WHEREAS, upon the receipt of amounts released from the Prior Indenture, the Trustee is to remit a portion of such. amounts to HUD (together with certain other amounts available to the Trustee for such purpose) in exchange for HUD's delivery to the Trustee of the Note, as amended, pursuant to a Loan Work -Out Agreement, dated as of the date hereof (the "Loan Work -Out Agreement "), by and among the Issuer, the Owner and the Trustee; and WHEREAS, all things necessary to make the Bonds when issued as provided in this Indenture, valid, binding and legal obligations of the Issuer according to the import thereof, and to constitute this Indenture a valid lien on the properties, interests, revenues and payments herein pledged to the payment of the Bonds, have been done and performed, and the creation, execution and delivery of this Indenture, and the execution and issuance of the Bonds, subject to the terms hereof, have in all respects been duly authorized; and WHEREAS, the Bonds and the Trustee's Certificate of Authenti- cation to be endorsed on such Bonds are all to be in substantially the following form with necessary and appropriate variations, omis- sions and insertions as permitted or required by this Indenture: No. R Interest R_-- 6.5% Registered owner:. (Form of Bond) CITY OF CLEARWATER, FLORIDA Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan - Drew Gardens PrOject) Maturity Dat October 1, 2025 Dated Dam August 1, 1992 CUSIP_ 185267AA9 Principal Amount: anized a municipal core °ration11issuer ")I FLORIDA, Florida (the from the CITY OF CLEARWATER, of the State of ut solely under the laws promises to pay 0: owner identified and existing hereby P to the registered above, for value received, maturity date set forth set hereinafter described) rincipal sum as istered assigns, on the the p sources reg set forth above, called for redemption, the rate next pre- forth with interest thereon at below) unless prev Date (as defined this Bond is forth abd °e, unless of the Interest ion of this B° the sixteenth day above fthe date of reg the period to to such Interest ceding during meT7t Da. such any Interest Pay bear interest from registered x 0' ceding it shall istered before the month next preceding which event this Bond is reg 1, Payment Date, or unless bear interest from August aid, Payment Date event it shall and Interest 1993 in which shall have been 1 April 1, principal amount hereof Pa 1993 the ,Interest 1992) until the P forth above per annum, P1, 1993 rate set commencing April da year cons' on the each year, 36o-day if any, on October 1 of �� calculated on the bass of a premium, States ° f and p of Payment Dates") months. Principal of the united Bank One, of twelve 30 -day in lawful money office of ing Bond are payable corporate trust in trust (the this the principal or its successors check mailed to America at the Columbus, Ohio, shall be made by shall Pd thereto as such address Columbus, Payment of interest o� by wire transfer nTrustee ). of the person entitle the Bonds designated in the address istration books for: domestic account g ate principal appear on the registration to a 250,000 of immediately owner at least $ writing by any owner Owner's expense. amount of the Bonds at such This Bond shall not be entitled to any benefit under the Indenture (as hereinafter defined) or become valid or obligatory for any purpose until such Bond shall have been authenticated by the certificate of the Trustee endorsed hereon. This Bond and the issue of Bonds of which it is a part and the premium, if any, and interest thereon are limited obligations of the Issuer, payable solely from the revenues or other moneys to be received in connection with the refinancing of the Project or other moneys to be made available to the Issuer for such purpose. Neither the Bonds nor any premium or the interest thereon shall ever constitute an indebtedness or a charge against the general credit or taxing powers of the State of Florida, the Issuer or any other public body within the meaning of any constitutional or char- ter provision or statutory limitation and neither shall ever con- stitute or give rise to any pecuniary liability of the State of Florida, the Issuer or any other public body. The Bonds do not constitute an indebtedness to which the faith or credit of the State of Florida, the Issuer or any other public body is pledged. Notwithstanding anything to the contrary contained in the Bonds, Indenture or Loan Work -Out Agreement, or in any other instrument or document executed by or on behalf of the Issuer in connection herewith, no stipulation, covenant, agreement or obligation contained herein or therein shall be deemed or construed to be a stipulation, covenant, agreement or obligation of any present or future member, commissioner, director, trustee, officer, employee or agent of the Issuer or of any successor to the Issuer, or of any incorporator, member, commissioner, director, trustee, officer, employee or agent of the Issuer or of any successor to the Issuer, in any such person's individual capacity, and no such person, in his individual capacity, shall be liable personally for any breach or non - observance of or for any failure to perform, fulfill or comply with any such stipulations, covenants, agreements or the principal of, premium, if any, or interest on any of the Bonds or for any claim based thereon or on any such stipulation, covenant, agreement or obligation, against any such person, in his individual capacity, either directly or through the Issuer, under any rule of law or equity, statute or constitution or by the enforcement of any assessment or penalty or otherwise, and all such liability of any such person, in his individual capacity, is hereby expressly waived and released. No recourse under or upon any obligation, covenant or agree- ment contained in the Indenture or in any Bond, or under any judg- ment obtained against the Issuer, or by the enforcement of any assessment or by any legal or equitable proceeding by virtue of any constitution or statute or otherwise or under any circumstances, under or independent of the Indenture, shall be had against any member, officer or employee, as such, past, present or future, of the Issuer, either directly or through the Issuer, or otherwise, for the payment for or to the Issuer or any receiver thereof, or for or to the holder of any Bond issued thereunder or otherwise of any sum that may be due and unpaid by the Issuer upon any such Bond. Any and all personal liability of every nature, whether at common law or in equity, or by statute or by constitution or other- wise, of any such member, officer or employee, as such, to respond by reason of any act or omission on his or her part or otherwise, for the payment for or to the Issuer or any receiver thereof, or for or to the holder of any Bond issued thereunder or otherwise, of any sum that may remain due and unpaid upon the .Bonds thereby secured or any of them, is hereby expressly waived and released as a condition of and consideration for the execution of the Indenture and the issuance of the Bonds. It is hereby certified, recited and declared that all acts, conditions and things required to exist, happen and be performed precedent to and in the execution and delivery of the Indenture and the issuance of this Bond, do exist, have happened and have been performed in the time, form and manner as required by law; that payment in full for the Bonds has been received; and that the Bonds do not exceed or violate any constitutional or statutory limitation. IN WITNESS WHEREOF, the City Commission of the City of Clearwater, Florida has caused this Bond to be duly executed by its Mayor with her manual or facsimile signature, and its official seal to be impressed or printed hereon, attested by the manual or fac- simile signature of its Clerk, all as of the date of registration hereof. [SEAL] CITY OF CLEARWATER, FLORIDA By :_ (facsimile) e Mayor - Commissioner Attest: (facsimile) City Clerk ti DATE OF REGISTRATION: t `f `f 5 CERTIFICATE OF AUTHENTICATION This Bond is one of the Bonds issued under the provisions of and described in the within- mentioned Indenture. BANK ONE, COLUMBUS, NA, Columbus, Ohio, as Trustee By: 6 7 Authorized Signer �a tT (Back of Bond) This Bond is one of a duly authorized issue of Bonds of the Issuer known as its Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan - Drew Gardens Project) issued in the aggregate principal amount of $3,425,000, (the "Bonds") pursuant to the laws of the State of Florida, particularly Chapter 266, Part II, and Ch-pter 159, Part IV, Florida Statutes, and other applic- able provisions of law (the "Act "), and under and pursuant to a resolution of the Issuer. The Bonds are issued under a Trust Indenture dated as of August 1, 1992, from the Issuer to the Trustee (the "Indenture "), to which Indenture and all indentures supplemental thereto reference is hereby made for a description of the trust estate under the Indenture, the nature and extent of the security, the terms and conditions upon which the Bonds are issued and secured and the rights of the holders thereof. All of the Bonds are equally and ratably secured under the Indenture. The Bonds are limited obli practicable date as a whole or in part upon the occurrence of any of the following events: (i) if FHA mortgage insurance proceeds are payable to the Trustee, (ii) to the extent the proceeds of any con - demnation award or casualty insurance recovery are applied to the prepayment of the Note, (iii) without notice in the event that the Owner becomes subject to any bankruptcy proceedings and the trustee in bankruptcy causes the Note to be prepaid without notice and without premium, or (iv) to the extent of any prepayment of the Note made upon the determination of HUD in order to avoid an FHA insurance claim. The Bonds are also subject to redemption on any date on and after October 1, 2002, as a whole or in part to the extent of any optional prepayment of the Note by the Owner (and from any reduc- tion of the Debt Service Reserve Fund under the terms of the Inden- ture), or from the proceeds of refunding bonds or otherwise from any moneys provided by the Issuer, at the redemption prices expressed as percentages of the principal amount to be redeemed, plus accrued interest to the date of redemption, as set forth in the following table: Redemption Dates Redemption Prices October 1, 2002, through September 30, 2003 102% October 1, 2003, through September 30, 2004 101 October 1, 2004 and thereafter 100 The Bonds are also required to be retired by mandatory sinking fund payments from money in the Bond Fund, as set forth in the Indenture. In the event of a redemption of less than all of the Bonds other than by scheduled mandatory sinking fund redemption (i) the Trustee shall redeem an amount of Bonds, and the scheduled manda- tory sinking fund payments shall be reduced, so that the resulting decrease in debt service on the Bonds during each six -month period ending on an Interest Payment Date is proportional, as nearly as practicable, to the decrease in payments on the Note in each period, and the Bonds shall be selected by lot, and (ii) the Trustee shall transfer from the Debt Service Reserve Fund to the Bond Fund an amount that bears the same proportion to the amount then on deposit in the Debt Service Reserve Fund as such reduction in the principal balance of the Mortgage Loan bears to the out- standing balance of the Mortgage Loan immediately prior to such reduction, and use such amounts to redeem Bonds; provided that the Bonds shall only be redeemed in a principal amount of $5,000 or an integral multiple thereof. The particular Bonds to be redeemed shall be selected by lot. Unless notice of redemption is not required under this Bond and the terms of the Indenture, notice of intended redemption of this Bond shall be given by first class mail, postage prepaid, to the registered owner hereof at the address of such owner shown on the Trustee's Bond Register. All such redemption notices shall be given not less than thirty (30) days or more than sixty (60) days prior to the date fixed for redemption by first class mail, postage prepaid to the holders of each Bond to be redeemed at the address l of each holder shown on the Bond Register and by registered mail, overnight delivery service or other secure means to holders of $250,000 or more in aggregate principal amount of Bonds and to each registered securities depositary known to the Trustee to be holding Bonds on behalf of a registered holder and to certain information services as described in the Indenture. Failure to give notice by mailing to the registered owner of any Bond designated for redemp- tion shall not affect the validity of the proceedings for the redemption of any other Bond if notice of such redemption shall have been mailed as herein provided. Notwithstanding the foregoing or any other provision hereof, in the event of a redemption by reason of the Trustee receiving prepayments on the Mortgage Loan representing prepayments on the Mortgage Loan made by the Owner without notice or prepayment penalty while under the supervision of a trustee in bankruptcy, notice of redemption of Bonds shall not be required if the circum- stances do not permit the Trustee to give such notice in accordance with the provisions provided herein. In addition to providing notice of redemption as set forth above, the Trustee shall send a second notice of redemption, by registered mail, overnight delivery service, or other secure means, postage prepaid -to the registered owners of any Bonds called for redemption, at their addresses appearing on the Bond Register maintained by the Trustee, who have not surrendered their Bonds for redemption within 30 days following the redemption date. The owner of this Bond shall have no right to enforce the pro- visions of the Indenture or to institute action to enforce the covenants therein, or to take any action with respect to any event of default under the Indenture, or to institute, appear in or defend any suit or other proceeding with respect thereto, except as provided in the Indenture. Modifications or alterations of the Indenture or of any inden- ture supplemental thereto may be made only to the extent and in the circumstances permitted by the Indenture. This Bond is transferable by the registered owner hereof in person or by his attorney duly authorized in writing at the princi- pal corporate trust office of the Trustee, but only in the manner, subject to the limitations and upon payment of the charges provided in the Indenture, and upon surrender and cancellation of this Bond. Upon such transfer, a new registered Bond or Bonds of the same series, maturity and interest rate and of authorized denomination or denominations for the same aggregate principal amount will be 9 issued to the transferee in exchange therefore. The Bonds are issuable only as fully registered Bonds without coupons. The Issuer and the Trustee may deem and treat the registered holder hereof as the absolute owner hereof for the purpose of receiving payment of or on account of principal hereof and interest due hereon and for all other purposes and neither the Issuer nor the Trustee shall be affected by any notice to the contrary. This Bond shall not be entitled to any benefit under the Indenture or become valid or obligatory for any purpose until such Bond shall have been authenticated by the certificate of the Trustee endorsed hereon. a 4 i 10 ASSIGNMENT FOR TRANSFER FOR VALUE RECEIVED, the undersigned, hereby sells, assigns and transfers unto (PLEASE INSERT SOCIAL SECURITY OR OTHER IDENTIFYING NUMBER OF ASSIGNEE) (Please print or Typewrite Name and Address of Assignee) the within Bond and all rights thereunder, and hereby irrevocably constitutes and appoints attorney to transfer the within Bond on the books kept for registration thereof, with full power of substitution in the premises. Dated: Signature Guaranteed NOTICE: Signature(s) must be guaranteed by a member firm of the New York Stock Exchange or a commercial bank or trust company. 11 Signature NOTICE: The signature to this assignment must correspond with the name as it appears upon the face of the within Bond in every particular, without alteration or enlargement or any change whatever. AOL NOW, THEREFORE, the Issuer, in consideration of the premises and the acceptance by the Trustee of the trusts hereby created and of the purchase and acceptance of the Bonds by the holders and owners thereof, and of the sum of one dollar, lawful money of the United States of America, to it duly paid by the Trustee at or before the execution and delivery of these presents, and for other good and valuable consideration, the receipt of which is hereby acknowledged, in order to secure the payment of the principal of, premium, if any, and interest on the Bonds according to their tenor and effect and the performance and observance by the Issuer of all the covenants expressed or implied herein and in the Bonds, does hereby grant, bargain, sell, convey, pledge and assign a security interest, unto the Trustee, and its successors in trust and its and their assigns in and to the following (said property being herein referred to as the "Trust Estate "), to wit: GRANTING CLAUSES I. Except for the Rebate Fund, all right, title and interest of the Issuer in and to any money or letters of credit held under this Indenture by the Trustee, including the proceeds of the Bonds, the payments made under the Note and the interest, profits, and other income derived from the investment thereof. II. All right, title and interest of the Issuer in and to the Mortgage Loan and the security therefor, including the Note, the Mortgage, all FHA or casualty insurance benefits or condemnation awards payable with respect thereto and any interest, profits and other income derived from the investment thereof. III. All right, title and interest of the Issuer in and to the Loan Work -Out Agreement. IV. Except for the Rebate Fund, all funds, money and securities and any and all other rights and interests in property whether tangible or intangible from time to time hereafter by delivery or by writing of any kind, conveyed, mortgaged, pledged, assigned or transferred as and for additional security hereunder for the Bonds by the,Issuer or by anyone on its behalf or with its written con- sent to the Trustee, which is hereby authorized to receive any and all such property at any and all times and to hold and apply the same subject to the terms hereof. PROVIDED, HOWEVER AND NOTWITHSTANDING THE FOREGOING, THE TRUST ESTATE SHALL NOT INCLUDE THE REBATE FUND OR ANY MONEYS OR INVEST- MENTS REQUIRED TO BE DEPOSITED IN THE REBATE FUND AND ANY OTHER 12 AMOUNT RE4UIR BENEFIT PAID TO THE UNITED UNITED MERICA AND SNOT LFOR HELD FOR THE THE BENEFIT OF THE HOLDERS OF THE BONDS. PROVIDED, HOWEVER, that the pledge and assignment of the Issuer's right, title and interest in and to the Loan Work -Out Ac3'reement pursuant to this Indenture is intended solely for fpthe the Bonds, the enforcement of the payment when poses of securing remium and interest thereon, principal thereof and any p payable, according to the erformancetofn and meaning compliance owithdthe and the p and such pledge this Indenture, diminish or impair the covenants, terms and conditions wa taffectden Indenture, and assignment shall not in any Y reement or impose Issuer's obligations under the Loan Work-out or be deemed to constitute a any such obligations on or affect the collection by or receipt by e or assignment of, avments) which, pursuant to pledge other than Note p to the Issuer. the Issuer, of money ( are to be paid directly the Loan Work -Out Agreement, TO HAVE AND TO HOLD, all the same with all privileges and or agreed or intended appurtenances hereby conveyed and assigned, the parties so to be, to the Trustee and its tsbeingsundersto d by the and to ore of FHA do not permit a gross revenues them and their assigns forever hereto that the requirements hold certain other funds in connec- pledge and that thTrustee may tion with the Project Pursuant to documents ofj this nIndenture);� which funds shall not be subject IN TRUST NEVERTHELESS, upon the terms and trusts herein set forth for the equal and proportionate benefit, security and p tion of all Holders tore without privilege,n prioritvdo under d'ofithe secured by t1lis Inden of. the Bonds over any tion as to lien Or otherwise of any other Bonds, except as set forth in ths Indenture: that if the Issuer shall pay or cause to be PROVIDED, HOWEVER, principal, interest and pre- paid to the Holders of the Bonds the p perform mium, if any, to become due thereon at the times and ke the manner Performed and observed all Of its provided in Article IX hereof and if the Issuer shall keep, and observe, or cause to be kept, p at the warranties and agreements contained herein, covenants, A ranted shall, determine and be void, and thereupon presents and the estate and rights he g option of the Issuer, cease, a the lien of this Indenture the Trustee shall cancel and di,scharg and, subject to and execute and deliver si eeto satisfystheylienhhIx hereof, reconvey�to instruments in as shall be requislt the p conveyed; and assign and deliver to provisions of Section 4.07 and Article IX hereof, the Issuer the estate r the e the time I ect to the lien of this then be in its possession, except for the the Issuer any p p of Indenture which may the Trustee for the payment Rebate Fund and cash held by otherwise this Indenture interest on and retirement of the Bonds; Upon the trusts and to be and remain in full force and effect and up subject to the covenants and conditions hereinafter set forth. 13 ARTICLE I DEFINITIONS Section 1.01. Definitions. The terms defined in this Section 1.01 and in the Recitals hereto (except as herein otherwise expressly provided or unless the context otherwise requires) for all purposes of this Indenture and of any indenture supplemental hereto shall have the respective meanings specified in this Section 1.01 and said Recitals. "Accrued Interest" means all interest due to date. "Act" means Chapter 166, Part II, and Chapter 159, Part IV, Florida Statutes, and other applicable provisions of law. "Authorized Denomination" means $5,000 principal amount or any integral multiple thereof. "Bond Fund" means the Bond Fund established by the Trustee pursuant to Section 4.01 hereof. "Bondholder" or "Holder" or "owner of [or "the "] Bond[s]" means the person in whose name such Bond is registered, from time to time. "Bond Obligation" means, as of any date of calculation, the principal amount of all Outstanding Bonds plus accrued interest to the date of calculation (if other than an Interest Payment Date). "Bond Purchase Agreement" means the Bond Purchase Agreement among the Bond Purchaser, the issuer, and the Owner relating to the Bonds. "Bond Purchaser" means collectively, Banc One Capital Corporation and Newman & Associates, Inc. "Bonds" means the Bonds issued under this Indenture. "Bond Year" means each twelve -month period ending on the first day of March of each year, with the initial Bond Year beginning on the day of issuance of the Bonds. "Certificate of the Issuer," "Statement of the Issuer," "Request of the Issuer" and "Requisition of the Issuer" mean, respectively, a written certificate, statement, request or requisi- tion signed in the name of the Issuer by the Mayor of the Issuer or such other person as may be designated and authorized to sign for the Issuer. Any such instrument and supporting opinions or representations, if any, may, but need not, be combined in a single instrument with any other instrument, opinion or representation, 14 and the two or more so combined shall be read and construed as a single instrum e Date means the date of in delivery of the Bonds tiClosing �� against payment therefor. to the Bond Purchaser as amended and 11Code" means the Internal e Revenue Code of 1986, contemporaneously as "1954 Code" means the internal oe C to the end n actme t of the amended and in effect immediately pri Code. 11Contract of Mortgage Insurance" means the comae° insurance and FHA with respect to mortgage created the Trustee as mortgagee of the National Housing terms of the pursuant to Section 221(d)(4) provisions. and regulatory p by FHA endorsement of the Note and incorporating FHA Commitment and certain statutory the Bonds 11costs of Issuance" means all costs of issuing the underwriter's fee, to be paid by the Trustee as including regiment. identified in the Bond purchase Agreement. the Costs of Issuance Fund 11Costs of Issuance Fund" established by the Trustee pursuant to Section 4.01 hereof. "Debt Service Reserve Fund" meaner the Debt Service Reserve Fund established by the Trustee pursuant to Section 4.01 hereof. Requirement" means the sum of (i) the mandatory sinking fund payments) and "Debt Service Reserve maximum principal (including the last in respect of the Bonds in any consecutive e eight- in payable on an Interest Payment Date, principal month period ending equal to one payment of p such period, and (ii) an amount and interest on the Mortgage Loan. n "event of default" means any of those "Event of Default or the applicable provisions of events specified in and defined by Article vi hereof to constitute an event of default. Trustee's Fees and Expense means all those "Extraordinary the Trustee fees, an Bond Year in excess of expenses and disbursements earned or incurred Y as described under Feesland7Expensesng Y ordinary d Expenses" means all "Extraordinary Mortgage Servicing gees an expenses of the Servicer under the Mortgage fees and exp Mortgage any Bond Year in excess of ordinary Servicing Agreement during Mortgage Servicing Fees and Expenses. 15 "FHA" means the Federal Housing Administration and may refer to the Commissioner thereof, any authorized representative thereof or the successor thereof. "FHA Regulations" means the regulations promulgated by FHA regarding insurance under Section 221(d) (4) of the National Housing Act. "Final Calculation Date" means October 1, 2025, or any earlier date on which the last Bond is discharged. "Indenture" means this Indenture together with any other indentures supplemental hereto. "Initial Payment" means the payment on the Note which is due on September 1, 1992, in accordance with the modification of the Note and Mortgage. "Installment Calculation Date" means April 1 of 1997, 2002, 2007, 2012, 2017, and 2025, unless the Final Calculation Date has been reached. "Interest Payment Date" means each April 1 and October 1, commencing April 1, 1993. "Investment Agreement" means the investment agreement by and between the Trustee and Bayerische Landesbank, or any successor provider, which provider shall have a rating on its unsecured long term debt equal to or higher than -the rating on the Bonds, with respect to money held in the Bond Fund, the Debt Service Reserve Fund created by this Indenture. Any successor Investment Agreement shall have the same terms and conditions as the original Investment Agreement. The Rating Agency shall be notified of any substituted Investment Agreement provider. "Issuer" means the City of Clearwater, Florida. "Loan Work -Out Agreement" means the Loan Work -Out Agreement, dated as of August 1, 1992, among the Issuer, the Trustee and the Owner. "Modification Agreement" means the Modification of Mortgage Note and Mortgage, dated as of August 18, 1992, among the Owner and the Trustee, as approved by HUD. "Mortgage" means that certain mortgage, including any supplements thereto, from the Owner to the Trustee, as mortgagee, with respect to the Project, securing payment of the Mortgage Loan. "Mortgage Insurance" means the insurance provided for by the Contract of Mortgage Insurance. 16 "Mortgage Loan" means the loan made to the Owner pursuant to the Note, Mortgage and the Mortgage Loan Documents. "Mortgage Loan Documents" means Loan Work -out Agreement, the Note, the Mortgage and the Supplemental Regulatory Agreement. "Mortgage Servicer" means Continental Securities corporation, Syracuse, New York 13202, or its successor as servicer under the Mortgage Servicing Agreement referred to in Section 7.14 hereof. "Net Proceeds" when used with respect to any insurance or condemnation award, means the gross proceeds from the insurance or condemnation award with respect to which that term is used remaining after payment of all reasonable expenses incurred in the collection of such gross proceeds. "Note" means the nonrecourse deed of trust note of the Owner evidencing the Mortgage Loan, including any allonge thereto, delivered to the Trustee in substantially the form attached as Exhibit A to the Loan Work -out Agreement. "Ordinary Mortgage Servicing Fees and Expenses" shall mean the fees and expenses of the Mortgage Servicer under the Mortgage Ser- vicing Agreement equal to 1 /8th of 1.00% of the outstanding principal balance of the Note computed monthly, deducted by the Mortgage Servicer from the monthly payments on the Mortgage Loan. "Ordinary Trustee's Fees and Expenses" means those fees, expenses and disbursements payable to the Trustee pursuant to Section 4.05 hereof and as described under Section 7.06, equal to 1 /8th of 1.00% of the outstanding principal balance of the Bonds computed and payable semiannually in arrears. "Outstanding" when used with respect to the Bonds or "Bonds Outstanding" means, as of any date, all Bonds that have been duly authenticated and delivered by the Trustee under this Indenture, except: (a) Bonds surrendered and replaced upon exchange or transfer, or canceled because of payment or redemption, at or prior to such date; (b) Bonds for the payment, redemption or purchase for cancellation of which sufficient money has been deposited prior to such date with the Trustee (whether upon or prior to the maturity, amortization or redemption date of any such Bonds), or which are deemed to have been paid and discharged pursuant to the provisions of Section 9.01 hereof; provided that if such Bonds are to be redeemed prior to the maturity thereof, other than by scheduled amortization, notice of such redemption shall have been given or arrangements satisfactory to the Trustee shall have been made therefor, or waiver of 17 7 such notice satisfactory in form to the Trustee shall have been filed with the Trustee; and (c) Bonds in lieu of which others have been authenticated (or payment, when due, of which is made without replacement) under Section 2.07 hereof; and also except that (d) For the purpose of determining whether the holders of the requisite principal amount of Bonds plus accrued but unpaid interest thereon have made or concurred in any notice, request, demand, direction, consent, approval, order, waiver, acceptance, appointment or other instrument or communication under or pursuant to the Indenture, Bonds owned by or for the account of the Owner or any person owned, controlled by, under common control with or controlling the Owner shall be disre- garded and deemed to be not Outstanding. The :erm "control" (including the terms "controlling ", "controlled by" and "under common control with ") means the possession, directly or indi- rectly, of the power to direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities, by contract, or otherwise. Beneficial ownership of 5% or more of a class of securities having general voting power to elect a majority of the board of directors of a corporation shall be conclusive evidence of control of such corporation. "Owner" means Drew Gardens Associates, Ltd., a Florida limited partnership, or any of its FHA - approved successors as owner of the Project. "Owner Deposit" means the cash in the amount of $ to be deposited in immediately available funds by the Owner with the Trustee on the Closing Date in the Costs of Issuance Fund as provided in Section 4.02 hereof. "Paying Agent" means the Trustee acting as such, and any other paying agent appointed pursuant to this Indenture. "Pledged Revenues" means the revenues, receipts and other money received or to be received from the Owner under the Note, the Mortgage and the Project, or other charges, interest and income derived or to be derived on any money held by the Trustee hereunder, and all money paid pursuant to the Contract of Mortgage Insurance and other benefits thereunder. "Prior Indenture" means the Trust Indenture dated as of September 1, 1983, between the Issuer and the Prior Trustee with respect to the Refunded Bonds. "Prior Trustee" means collectively, Bank One, Columbus, NA, Columbus, Ohio, in its capacity as trustee and Sun Bank, National Association, as co- trustee under the Prior Indenture. 18 "Program Fund" means the Program Fund established by the Trustee pursuant to Section 4.01 hereof. "Prohibited Payment" means a payment, or an agreement to pay, to a person other than the United States of America, an amount that is required to be paid to the United States of America by the Code, by entering into a transaction that reduces or eliminates any excess nonpurpose obligations earnings (as discussed in Section 4.14 hereof) because such transaction results in a lower yield, smaller profit or larger loss than would have resulted if the transaction had been at arm's length and had the Yield on the Bonds not been relevant to either party, as more specifically provided in Section 1.148 -0 -9 of the United States Income Tax Regulations. "Project" means the multifamily residential rental project in Clearwater, Florida, owned by Owner, including the real estate described in Exhibit A hereof and identified as FHA Project No. 067 - 35276 -PM. "Qualified Investments" means any of the following if and to the extent permitted by law: (i) direct obligations of or obligations the principal of and interest on which are fully guaranteed by the full faith and credit of the United States Government, or (ii) obli- gations of any agency or instrumentality of the United States Government backed by the full faith and credit of the United States, or (iii) certificates of deposit issued by the Trustee or any of its affiliates or by any state or national bank that has a short term rating from Standard & Poor's Corporation of A -1+ or higher, or which deposits are fully insured by FDIC (excluding a bank where the Issuer is a settlor of a trust account evidenced by deposits therewith), or (iv) investment agreements, in substantially the same form as the Investment Agreement, which will not adversely affect the rating on the Bonds, with a financial institution whose unsecured long term debt is rated by Standard & Poor's Corporation at least as high as the rating on the Bonds or (v) interests in any money market funds rated either "AAAm" or "AAAm -G" by Standard k,, Poor's Corporation that invest exclusively in obligations issued and guaranteed by the United States Government or its agencies._or instrumentalities. Qualified Investments under (i) -(iii) or (v) hereof shall have a maturity date not to exceed the lesser of 180 days from the date of purchase of such Qualified Investments or as needed under this Indenture. "Rating Agency" means Standard & Poor's Corporation, or any successor thereto. "Rebate Analyst" means Peck, Shaffer & Williams, Cincinnati, Ohio. 19 "Rebate Analyst Fee" means a fee of $2,500 payable on the first rebate calculation date together with a $250 set up fee, and thereafter, $2,500 on each rebate calculation date. "Rebate Fund" means the Rebate Fund established by the Trustee pursuant to Section 4.01 hereof. "Record Date" or "Regular Record Date" means the close of business on the 15th day of the month next preceding each Interest Payment Date.. "Refunded Bonds" means the Issuer's Mortgage Revenue Bonds, Series 1983 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) in the initial aggregate principal amount of $6,450,000. "Regulatory Agreement" means that certain Regulatory Agreement dated October 12, 1983 between the Owner and FHA with respect to the Project. "Second Mortgage" means the second lien mortgage encumbering the Project in favor of HUD which arose out of the Loan Work -Out Agreement and the Modification Agreement. "State" means the State of Florida. "supplemental Regulatory Agreement" means the Supplemental Regulatory Agreement as to Tax Exemption dated as of August 1, 1992 between the Owner, the Issuer and the Trustee, to be recorded in the Official Records of Pinellas County, Florida. "Trustee" means Bank One, Columbus, NA, Columbus, Ohio, and its successors in trust hereunder. r Section 1.02. Interpretation. The words "hereof," "herein," "hereunder," and other words of similar import refer to this Inden- ture as a whole. Words of the masculine gender shall be deemed and construed to include correlative words of the feminine and neuter genders. Words importing the singular number shall include the plural number and vice versa unless the context shall otherwise indicate. References to Articles, Sections, and other subdivisions of this Indenture are to the designated Articles, Sections and other subdivisions of this Indenture as originally executed. The headings of this Indenture are for convenience only and shall not define or limit the provisions hereof. 20 ARTICLE II THE BONDS Section 2.01(a). The Bonds. Bonds may not be issued under this Indenture except in accordance with this Article. The Bonds in the aggregate principal amount of $3,425,000 shall be designated "City of Clearwater, Florida Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan - Drew Gardens Apartments Project)." The Bonds shall be issued only as fully registered secured. All of the numberedofromaRelyupward and ratably , Each Bond shall be dated and bear interest until paid from the Interest Payment Date next preceding the date of registration thereof unless it is registered as of a day during the period from the sixteenth day of the month next preceding any Interest Payment Date to such Interest Payment Date, inclusive, in which event it shall be dated and bear interest from such Interest Payment Date, or unless it is registered before April 1, 1993, in which event it shall be dated and bear interest from August 1, 1992; provided, however, that if, at the time of registrationsucha B ndn shall is in default on any Outstanding Bonds, interest from the Interest payment Date to which interest has pre- viously been paid or made available for payment on the Outstanding Bonds. The Bonds shall be issued in the Authorized Denominations, shall bear interest payable on each Interest Payment Date, and shall mature on the dates and in the amounts, and bear interest at the rates per annum, all as set forth below: Maturity Date Principal Amount Interest Rate October 1, 2025 $3,425,000 6.50% The person in whose name any Bond is register e e Dateh on shall Regular Record Date with respect to an interest Paym be entitled to receive the interest payable on such Interest Payment Date (unless such Bond has been called for redemption on a redemp- tion date which is prior to such Interest Payment Date) notwith- standing the cancellation of such Bond upon any registration of transfer or exchange thereof subsequent to such Regular Record if and prior to such Interest Payment Date; provided, however, and to the extent the Issuer shall default in the payment of the interest due on any Interest Payment Date, such defaulted interest shall be paid as provided in the next paragraph. Any interest on any Bond that is payable, but is not punctu- ally paid or duly provided for, on any Interest Payment Date payable tolthe Bondholder ontthes cease by payable 21 virtue of having been such Bondholder. The Trustee may elect to make payment of any Defaulted Interest to the Persons in whose names the Bonds (or their respective predecessor Bonds) are registered at the close of business on a special record date for the payment of such Defaulted Interest (a "Special Record Date "), which shall be fixed in the following manner. The Trustee shall determine the amount of Defaulted Interest proposed to be paid on each Bond and the date of the proposed payment, shall fix a Special Record Date for the payment of such Defaulted Interest which shall be not more than 15 nor less than 10 days prior to the date of the proposed payment and shall cause notice of the proposed payment of such Defaulted Interest and the Special Record Date therefor to be mailed, first class, postage prepaid, to each Bondholder at his address as it appears in the Bond Register not less than 10 days prior to such Special Record Date. notice of the proposed payment of such Defaulted Interest and the Special Record Date therefor having been mailed as aforesaid, such Defaulted Interest shall be paid to the persons in whose names the Bonds (or their respective predecessor Bonds) are registered on such Special Record Date. The Bonds shall be subject to redemption as provided in Article III hereof. Section 2.01(b). Payments of Principal Redemption Price and Interest. (i) Payment of principal, premium, and interest on the Bonds shall be paid by check or draft mailed to the registered owner thereof at his address as it appears on the registration books of the Issuer on the Record Date. Upon request of and at the expense of a registered owner of at least $250,000 in principal amount of Bonds Outstanding, all payments of principal, premium, and interest on the Bonds shall be paid by wire transfer in immediately available funds to an account designated by such registered owner. (ii) Before the date fixed for redemption, funds shall be deposited with the Trustee to pay, and the Trustee is hereby authorized and directed to apply such funds to the payment of, the Bonds or portions thereof called, together with accrued interest thereon to the redemption date. CUSIP number identification with appropriate dollar amounts for each CUSIP number must accompany all payments of principal, premium, and interest, whether by check or by wire transfer. Section 2.02. Restriction on Issuance of Bonds. No Bonds may be issued under the provisions of this Indenture except in accor- dance with this Article. The total principal amount of Bonds that may be issued hereunder, or in substitution for other Bonds pursuant to Section 2.07, is expressly limited to $68,500. Section 2.03. Limited Obligations. The Bonds, together with premium, if any, and interest thereon, are limited obligations of the Issuer payable solely from the revenues, receipts and security pledged therefor in the Granting Clauses hereof. The Bonds do not constitute a debt or pledge of the faith and credit of the State, the Issuer or any other public body, and the holders or owners 22 thereof have no right to have taxes levied by any public body for the payment of the principal thereof or premium, if any, or interest thereon. Money raised by taxation shall not be obligated or pledged for the payment of principal of or premium, if any, or interest on the Bonds, and the Bonds shall be payable solely from the revenues and security interests pledged for their payment as authorized by this Indenture. Section 2.04. Indenture Constitutes Contract. In considera- tion of the purchase and acceptance of the Bonds issued hereunder by those who shall hold them from time to time, the provisions of this Indenture shall be part of the contract of the Issuer with the Holders of the Bonds and shall be deemed to be a contract between the Issuer and the Holders of the Bonds from time to time. Section 2.05. Execution. The Bonds shall be executed on behalf of the Issuer by the manual or facsimile signature of its Mayor, and a facsimile of its seal shall be imprinted or otherwise reproduced thereon, and attested by the manual or facsimile signa- ture of its Clerk. Any facsimile signatures shall have the same force and effect as if said officers had manually signed said Bonds. Any reproduction of the official seal of the Issuer on the Bonds shall have the same force and effect as if the official seal of the Issuer had been impressed on the Bonds. In case any officer whose manual or facsimile signature shall appear on any Bonds shall cease to be such officer before the delivery of such Bonds, such signature or such facsimile shall nevertheless be valid and sufficient for all purposes, the same as if he had remained in office until delivery, and also any Bond may bear the facsimile signatures of, or may be signed by, such persons as at the actual time of the execution of such Bond shall be the proper officers to sign such Bond although at the date of such Bond such persons may not have been such officers. Section 2.06. Authentication. Only such Bonds as shall have endorsed thereon a certificate of authentication substantially in the form hereinabove set forth duly executed by the Trustee shall be entitled to any right or benefit under this Indenture. No Bond shall be valid or obligatory for any purpose unless and until such certificate of authentication shall have been duly executed by the Trustee; and such executed certificate upon any such Bond shall be conclusive evidence that such Bond has been authenticated and delivered under this Indenture. The Trustee's certificate of authentication on any Bond shall be deemed to have been executed by it if signed by an authorized signer of the Trustee, but it shall not be necessary that the same person sign the certificate of authentication on all of the Bonds. Section 2.07. Mutilated, Lost Stolen or Destroyed Bonds. In the event any Bond is mutilated, lost, stolen or destroyed, the Issuer shall execute and the Trustee shall authenticate a new Bond of like date, series, maturity and denomination as that mutilated, 23 lost, stolen or destroyed. Any mutilated Bond shall first be surrendered to the Trustee; and in the case of any lost, stolen or destroyed Bond, there shall first be furnished to the Trustee and the Issuer evidence of such loss, theft or destruction reasonably satisfactory to them together with indemnity reasonably satisfac- tory to them. In the event any such Bond shall have matured, instead of issuing a duplicate Bond or Bonds the Issuer may pay the same without surrender thereof. The Issuer and the Trustee may charge the holder or owner of any lost, mutilated, stolen or destroyed Bond with their reasonable fees and expenses of replacing such Bond. Section 2.08. Transfer and Exchange of Bonds, Persons Treated as Owners. The Trustee as Bond Registrar shall cause a bond register to be kept for the registration of transfers of Bonds. Any Bond may be transferred only upon an assignment duly executed by the registered owner or his duly authorized representative in such form as shall be satisfactory to the Bond Registrar and upon surrender of such Bond to the Trustee for cancellation. Whenever any Bond or Bonds shall be surrendered for transfer, the Issuer shall execute and the Trustee shall authenticate and deliver to the transferee a replacement fully registered Bond or Bonds, of Authorized Denomination or Denominations and for the amount of such Bond or Bonds so surrendered. Any Bond may, in accordance with its terms, be exchanged, at the office of the Trustee, for a new fully registered Bond or Bonds, of the same maturity, of any Authorized Denomination or Denominations and for the aggregate amount of such Bond then remaining outstanding. In all cases in which Bonds shall be transferred or exchanged hereunder, the Trustee may make a charge sufficient to reimburse it for any tax, fee or other governmental charge required to be paid with respect to such transfer or exchange. The Trustee shall not be required to transfer any Bond after the mailing of notice calling such Bond for redemption, or during the period of fifteen days next preceding the mailing of a notice of redemption of any Bonds. The person in whose name any Bond shall be registered shall be deemed and regarded as the absolute owner thereof for all purposes and payment of or on account of the principal of and premium and interest on any such Bond shall be made only to or upon the order of the registered owner thereof, or his legal representative, and neither the Issuer nor the Trustee shall be affected by any notice to the contrary. All such payments shall be valid and effectual to satisfy and discharge the liability upon such Bond to the extent of the sum or sums to be paid. Neither the Issuer nor the Trustee shall be required to make any such exchange, registration or transfer of Bands during the 15 days immediately preceding an Interest Payment Date, or, in the 24 case of any proposed redemption of Bonds, during the 15 days imme- diately preceding the selection of Bonds for such redemption and after the giving of notice of redemption, the Trustee is not required to transfer or exchange any Bond or portion thereof which has been called for redemption. Section 2.09. Temporary Bonds. Until definitive Bonds are ready for delivery, there may be executed, and upon the request of the Issuer the Trustee shall authenticate and deliver, in lieu of definitive Bonds, temporary printed, typewritten, engraved or lit:ographed Bonds, in such denomination or denominations as shall be determined by the Issuer, in fully registered form, in substan- tially the tenor hereinabove set forth and with such appropriate omissions, insertions and variations as may be required. If temporary Bonds shall be issued, the Issuer shall cause the definitive Bonds to be prepared and to be executed and delivered to the Trustee, and the Trustee, upon presentation to it at its prin- cipal trust office of any temporary Bond shall cancel the same and authenticate and deliver in exchange therefor, without charge to the owner thereof, a definitive Bond or Bonds, as the case may be, of an equal aggregate principal amount, of the same maturities and bearing interest at the same rates as the temporary Bond sur- rendered. Until so exchanged the temporary Bonds shall in all respects be entitled to the same benefit and security of this Indenture as the definitive Bonds to be issued and authenticated hereunder. Interest on temporary Bonds, when due and payable, if the definitive Bonds shall not be ready for exchange, shall be paid on presentation of such temporary Bonds and notation of such pay- ment shall be endorsed thereon by the Trustee. Section 2.10. Deliverer of the Bonds. Upon the execution and delivery of this Indenture, the Issuer shall execute and deliver to the Trustee, and the Trustee shall authenticate the Bonds and deliver them to or upon the order of the Issuer upon receipt by the Trustee of the following: (a) An executed counterpart of this Indenture and of the Loan Work -Out Agreement; (b) an opinion of nationally recognized bond counsel to the effect that the -ssuer is duly organized and existing under the laws of the State and has duly authorized, executed and delivered the Indenture, other loan documents, and the Bonds and that the Bonds are entitled to the benefits of this Indenture and are valid and binding limited obligations of the Issuer, which opinion, to the extent described in this para- graph (b), may rely upon a written opinion of counsel to the Issuer delivered in connection with the issuance of the Bonds; (c) a resolution of the Issuer certified by the clerk of the Issuer, authorizing the execution and delivery of this 25 Indenture and other necessary documents and the issuance, sale and delivery of the Bonds; (d) the Bond Purchase Agreement; duly executed by each party thereto; (e) the executed Modification Agreement; (f) the Owner Deposit; (g) conformed copies of all other Loan Documents; (h) a policy of title insurance in the face amount of the Mortgage insuring the Trustee in its capacity hereunder as the holder of the Mortgage that the Mortgage constitutes a valid first lien upon the Project; (i) an opinion of counsel to the owner to the effect that the owner is duly organized and validly existing and in good standing under the laws of the State and has full power and authority to enter into the agreements described herein to which it is a party, that its execution and delivery of and performance of its covenants in such agreements do not contra- vene law or any provision of any other agreement to which it is a party or by which it or such property is bound or affected, that all such agreements described herein are legal, valid and .binding agreements of the owner enforceable against the owner in accordance with their respective terms, and addressing in a manner satisfactory to the 'Trustee such other matters as the Trustee may reasonably require, and that the Trustee's interest in the Project is a valid, perfected first security interest under the laws of the State; (j) an opinion of nationally recognized bond counsel to the effect that the Bonds have been validly issued and consti- tute legal, valid and binding limited obligations of the Issuer, and that the interest on the Bonds, under law in effect on the date of such opinion, is excluded from gross income for federal income purposes and that the lien of the Prior Indenture upon the Note and the amount transferred from the Prior Indenture to the Indenture has been validly released; (k) a letter of instructions from the Issuer directing the Trustee to authenticate the Bonds; and (1) such other documents as the Trustee may reasonably request. 26 ARTICLE III REDEMPTION OR TENDER OF BONDS PRIOR TO MATURITY Section 3.01. Redemption of Bonds Prior to Maturity. (a) Casualty and Condemnation Redemption. The Bonds are sub- ject to redemption on any date, on the earliest practicable date, as a whole or in part, at a redemption price equal to the principal amount thereof plus accrued interest to the date fixed for redemp- tion to the extent the Net Proceeds of any condemnation award or insurance recovery (and, in the case of the Bonds, as a result of a reduction in the Debt Service Reserve Fund pursuant to Section 3.02) are applied to the prepayment of the Note as further provided in Section 5.06 hereof. (b) Optional Redemption. The Bonds are subject to redemption as a whole or in part on October 1, 2002, or any date thereafter on the earliest practicable date to the extent of, any optional prepayment of the Note by the Owner (and as a result of a reduction in the Debt Service Reserve Fund pursuant to Section 3.02), or from the proceeds of any refunding bonds or otherwise from any monies provided by the Issuer, at the redemption prices, expressed as percentages of the principal amount to be redeemed, plus accrued interest to the date of redemption set forth in the table below: Redemption Dates Redemption Prices October 1, 2002, through September 30, 2003 102% October 1, 2003, through September 30, 2004 101 October 1, 2004, and thereafter 100 (c) Special Redemption Upon a Default Under the Mortctacge Loan. If insurance benefits under the Contract of Mortgage Insurance are paid by FHA to the Trustee, or if such benefits are payable by FHA and the proceeds of refunding bonds of the Issuer or other moneys are deposited with the Trustee for such purposes, the Trustee shall call the Bonds for redemption on the earliest practicable date as a whole or in part to the extent of available money, at a redemp- tion price equal to 100% of the principal amount thereof plus accrued interest to the date fixed for redemption. (d) Mandatory Sinking Fund Redemption. The Bonds described below are required to be retired by mandatory sinking fund payments from money in the Bond Fund: 27 Maturity Date In the event of a redemption of less than all of the Out- standing Bonds other than by mandatory sinking fund payments of the Bonds, as appropriate, scheduled redemptions above shall be reduced so that the resulting decrease in debt service on the Bonds during each six -month period ending on an Interest Payment Date is proportional, as nearly as practical, to the decrease in payments on the Note in each period. (e) Special Bankruptcy Redemption. In the event that the Owner becomes subject to any bankruptcy proceedings and the trustee 28 BONDS MATURING OCTOBER 1, 2025 Principal Amount Principal Amount D_ a _te To Be Redeemed Date To Be Redeemed April 1 p , 1993 $15,000 October 1, 2009 $45,000 45 000 October It 1993 15,000 April 1, 2010 October 1, 2010 , 45,000 April 1, 1994 15,000 15,000 April 1, 2011 50,000 October 1, 1994 20,000 October 1, 2011 50,000 April 1 1995 A p October 1, 1995 15 000 , April 1, 2012 50,000 50 000 April 1 , 1996 20,000 October 1, 2012 April 1, 2013 , 55,000 October 1, 1996 20,000 20,000 October 1, 2013 55,000 April 1, 1997 October 1, 1997 20,000 Ap ril 1 2014 60,000 60 000 April 1 1998 20,000 October 1, 2014 April 1, 2015 , 60,000 October 1, 1998 20,000 20 000 October 1 2015 ' 65,000 April October 1191999 25,000 1, 65 000 , 65,000 April 1, 2000 25,000 , 20 October 1, 2016 October April 1, 2017 70,000 October 1, 2000 25,000 25 000 October 1, 2017 75 000 , April 1, p October 2001 1, 2001 + 25;000 April 1, 75,000 75 000 April 1, p 202002 25,000 , 20 October 1, 2018 April 1, 2019 , 75,000 October 1, 25,000 30,000 October 1, 2019 85 000 , April 1 ` October 2003 1, 2003 30,000 April 1, 2020 85,000 85,000 April 1, p 20004 30,000 October 1 2020 ' April 1, 2021 90 000 , October 1, 30,000 30,OG0 October 1, 2021 95,000 April 1, 2005 2005 35,000 April 1, 2022 95 000 , October April 1 p 1, 2006 35,000 October 1, 2022 100,000 100,000 October 1, 2006 35,000 35,000 April 1 2023 Ap October 1, 2023 105 000 , April 1, October 2007 1, 2007 40,000 April 1, 2024 110,000 115 000 April 1 ' 2008 40,000 October 1, 2024 April 1, 2025 , 115,000 October 1, 2008 40 000 40, October 1, 2025* 195,000 April 1, 2009 ,000 Maturity Date In the event of a redemption of less than all of the Out- standing Bonds other than by mandatory sinking fund payments of the Bonds, as appropriate, scheduled redemptions above shall be reduced so that the resulting decrease in debt service on the Bonds during each six -month period ending on an Interest Payment Date is proportional, as nearly as practical, to the decrease in payments on the Note in each period. (e) Special Bankruptcy Redemption. In the event that the Owner becomes subject to any bankruptcy proceedings and the trustee 28 0 in bankruptcy causes there to be a prepayment of the Note without notice and without premium, Bonds in the amount of such prepayment (and as a result of a reduction in the Debt Service Reserve Fund pursuant to Section 3.02) , shall be redeemed, as a whole or in part, without any otherwise required notice of redemption on the earliest practicable date at a redemption price equal to the principal amount thereof plus accrued interest to the date of redemption. (f) Redemption Upon Determination of HUD. On any date, as a whole or in part, Bonds shall be redeemed to the extent of any pre- payments of the Note made upon the determination of HUD in order to avoid an insurance claim under the Contract of Mortgage Insurance (and as a result of a reduction in the Debt Service Reserve Fund pursuant to Section 3.02). In the event of an optional redemption of Bonds on a date on which the redemption price includes a redemption premium, the Trustee shall not give notice of such redemption unless (i) the Trustee shall have had in its possession, for a period of at least 91 days prior to the giving of such notice, an amount paid by the Owner as a prepayment premium on the Mortgage Loan equal to such redemption premium; (ii) there shall not have occurred at any time during or after such 91 -day period any filing by or against the Owner under any bankruptcy act or any similar law for the relief of debtors and the Owner has filed with the Trustee a certificate to that effect; and (iii) the Trustee shall have received the pre- payment of the Mortgage Loan. Section 3.02. Selection of Bonds for Redemption. (a) In the event of a redemption of less than all the Out- standing Bonds pursuant to the scheduled mandatory redemption provisions provided for in Section 3.01(d) above and in the form of the Bonds, the particular Bonds to be redeemed are to be selected by the Trustee by lot. (b) If less than all the Bonds then outstanding shall be called for redemption other than from mandatory sinking fund pay- ments pursuant to Section 3.01(d) hereof, (i) the Trustee shall redeem an amount of Bonds of each series so that the resulting decrease in debt service on the Bonds of each series in each semi- annual period ending in an interest Payment Date is proportional, as nearly as practicable, to the decrease in the payments on the Note in each such semiannual period, and the Bonds shall be selected by lot within each maturity, and (ii) the Trustee shall transfer from the Debt Service Reserve Fund to the Bond Fund an amount that bears the same proportion to the amount then on deposit in the Debt Service Reserve Fund as the reduction in the principal balance of the Mortgage Loan bears to the outstanding balance of the Mortgage Loan immediately prior to such reduction. 29 (c) Bonds shall be redeemed pursuant to this Article III, only in the principal amount of $5,000 or any integral multiple thereof. Section 3.03. Notice of Redemption. Except that Bonds redeemed under Section 3.01(e) hereof shall be redeemed without notice, notice of the intended redemption of each Bond shall be given by the Trustee by first class mail, postage prepaid, to the registered owner at the address of such owner shown on the Registrar's bond register. All such redemption notices shall be given not less than thirty (30) days nor more than sixty (60) days prior to the date fixed for redemption. Each notice shall state that payment of the applicable redemption price plus accrued interest to the date fixed for redemption will be made upon presen- tation and surrender of the Bonds. The Trustee shall not give notice of any redemption of Bonds (other than pursuant to section 3.01 (d) hereof), unless the Trustee shall have, at the time such notice is given, sufficient funds on hand to make such redemption. Notices shall state the redemption date and the redemption price and, if less than all of the then Outstanding Bonds are called for redemption, shall state (i) the numbers of the bonds to be redeemed by giving the individual certificate number of each Bond to be redeemed or shall state that all Bonds between two stated certificate numbers, both inclusive, are to be redeemed or that all of the Bonds of one or more maturities have been called for redemption; (ii) the cusIP numbers of all Bonds being redeemed if available, (iii) the amount of each Bond being redeemed (in the case of a partial redemption) ; (iv) the date of issue of the Bonds as originally issued; (v) the rate of interest borne by each Bond redeemed; (vi) the maturity date of each Bond being redeemed, (vii) any other descriptive information needed to identify accurately the Bonds being redeemed, (vii.i) the place or places when amounts due upon redemption will be payable, and (ix) the name, address and contact person at the office of the Trustee with respect to such redemption. The notice shall require that such Bonds be sur- rendered at the principal corporate trust office of the Trustee and shall state that further interest on such Bonds will not accrue from and after the redemption date. cusIP number identification with appropriate dollar amos for each cusIP number shall also accompany each redemption payment. Notice of such redemption shall also be sent by registered mail, overnight delivery service or other secure means, postage prepaid, to the original purchaser of the Bonds, to any holders of $250,000 or more in principal amount of Bonds to be redeemed, to all municipal registered securities Depositories (described below) and to at least two of the national Information Services (described below) that disseminate securities redemption notices, when pos- sible, at least five (5) days prior to the provided, mailing hof either required by the first paragraph above; failure to receive such notice nor any defect in any notice so 30 mailed shall affect the sufficiency of the proceedings for the redemption of such Bonds. Securities Depositories include The Depository Trust Company, 711 Stewart Avenue, Garden City, New York 11530, Fax -(516) 227 -4039 or 4190; Midwest Securities Trust Company, Capital Structures - Call Notification, 440 South LaSalle Street, Chicago, Illinois 60605, Fax (312) 663 -2343; Philadelphia Depository Trust Company, Reorganization Division, 1900 Market Street, Philadelphia, Pennsylvania 19103, Attention: Bond Department, Fax (215) 496 -5058; or, in accordance with the then current guidelines of the Securities and Exchange Commission to such other addresses and /or such other securities depositories or to any such depositories as the Issuer may designate in writing to the Trustee. Information Services include Financial Information, Inc.'s "Daily Called Bond Service," 30 Montgomery Street, 10th Floor, Jersey City, New Jersey 07302, Attention: Editor; Kenny Information Services' "Called Bond Service," 55 Broad Street, 28th Floor, New York, New York 10004; Moody's Investors Service "Municipal and Government," 99 Church Street, 8th Floor, New York, New York, 10007, Attention: Municipal News Reports; and Standard & Poor's Corporation "Called Bond Record," 25 Broadway, New York, New York 10004; or, in accordance with then current guidelines of the Securities and Exchange Commission to such other addresses and /or such other services providing information with respect to called bonds, or to such services as the Agency may designate in writing to the Trustee. In addition to providing notice of redemption as set forth above, the Trustee shall send a second notice of redemption within 60 days of the redemption date, by registered mail, overnight delivery service, or other secure means, postage prepaid to the registered owners of any Bonds called for redemption, at their addresses appearing on the Bond Registration books maintained by the Trustee, who have not surrendered their Bonds for redemption within 30 days fa)-?.owing the redemption date. Notice of redemption under Section 3.01(b) shall be given only if the Trustee has received (i) money sufficient to pay the redemp- tion premium, if any, together with an amount equal to all costs of redeeming the Bonds, including any loss of investment earnings and including accrued interest to the redemption date, at least 91 days prior to the giving of notice of redemption 'T'rustee receives a cer- tificate from the Owner to the effect that during such period no petition in bankruptcy has been filed with respect to the Owner and (ii) the amount of such prepayment, prior to the giving of a notice of redemption. Failure to give notice by mailing to the registered owner of any Bond designated for redemption or to any depository or informa- tion service shall not affect the validity of the proceedings for 31 the redemption of any other Bond if notice of such redemption shall have been mailed as herein provided. Section 3.04. Cancellation. All Bonds that the have Trustee, redeemed shall be canceled and thereupon destroyed by and shall not be reissued. destruction rshallt certificate up n request, be destruction evidencing furnished by the Trustee to the Issuer. Section 3.05. Effect of Notice of rov dedli in this Notice of Article redemption having been given in the manner p III (or in the event no such notice is held by the Trustee or 3.03), and money for the redempthereueongthe Bonds so called for Paying Agent for that purpose, P redemption shall become due and payable on the redemption date, and interest thereon shall cease to accrue on such dsecur security or such benefit shall under thiseIndenture except to nreceive tpaym payment of the redemption price thereof. 32 ARTICLE IV FUNDS, INVESTMENTS Section 4.01. Establishment of Bond Funds. The following funds shall be established and maintained by the Trustee under this Indenture: (a) Costs of Issuance Fund; (b) Program Fund; (c) Bond Fund. (d) Debt Service Reserve Fund; and (e) Rebate Fund. Section 4.02. Application of Bond Proceeds and Other Amounts. From the proceeds of the Bonds ($ )' the Trustee shall to the deposit the accrued interest in the amount of $ to the Bond Fund; $ to the Program Fund; $ to the Debt Service Reserve Cost of Issuance Fund; and $ o£ the Owner Deposit Fund. The Trustee shall deposit $ to the Program into the Costs of Issuance Fund and $ Fund. After making the required deposits referred to above, any excess moneys shall be deposited in the Costs of Issuance Fund. Section 4.03. Costs of Issuance Fund. The Owner Deposit shall be deposited into the Costs of Issuance Fund. The Trustee shall use moneys in the Costs of Issuance Fund to pay Costs of Issuance in accordance with Schedule II of the Bond Purchase Agree- ment upon presentation to it of invoices not in excess of the amounts set forth therein. On the date which is 180 days following shall distribute any funds remaining the Closing Date, the Trustee in the Costs of Issuance Fund to the Owner. Section 4.04. Program Fund. There shall be deposited in the Program Fund the amount set forth-in Section 4.02. The Trustee shall remit amounts held in the Program Fund constituting Bond proceeds to the Prior Trustee for the purpose of refunding the Refunded Bonds and the funds constituting Owner contribution to the Prior Trustee for repayment to HUD of certain reserves, mortgage escrows and related fees. Section 4.05. (Reserved) Section 4.06. Bond Fund. There shall be deposited in the Bond Fund the amounts indicated in Section 4.02 and the amounts 33 disbursed thereto from the Debt Service Reserve Fund. There shall be deposited in the Bond Fund all payments on the Note and all interest,, profits or other income derived from the investment of all funds held hereunder as provided herein. FHA Insurance Mortgage benefits, if any, are to be deposited in the Bond Fund and used, together with other amounts on deposit in the Bond Fund, to the extent necessary for the redemption of Bonds in accordance with Section 3.01 at the earliest practicable date. On each Interest Payment Date, and on any other date when the Bonds are to be redeemed or otherwise paid pursuant to this inden- ture, the Trustee shall apply moneys in the Bond Fund in the following order of priority: (i) to pay all principal and /or interest due on the Bonds (including mandatory sinking fund payments, if any), (ii) to pay the Trustee its ordinary Trustee's Fees and Expenses, (iii) to pay or provide for payment on October 1 of each year commencing October 1, 1943, of the ongoing surveillance °ee of Standard « Poor's Corporation of $500 per year; (iv) to pay the Mortgage Servicer any amounts due and payable on such date; (v) to transfer any amounts required to be deposited in the Debt Service Reserve Fund in order to restore the amount of money or deposit therein to the amount required pursuant to the terms of this Indenture; (vi) to pay on each Installment Calculation Date the Rebate Analyst the Rebate Analyst Fee; and (vii) to maintain in the Bond Fund a carry- forward balance of at least equal to that set forth as Exhibit B hereto. Section 4.07. Debt Service Reserve Fund. The Trustee shall deposit in the Debt Service Reserve Fund the amounts set forth in Section 4.02. If on any interest Payment Date the amount in the Bond Fund after making all required deposits therein shall be insufficient to pay the interest on, principal of, and premium, if any, then due on the Bonds, the Trustee shall, subject to the limitations in the paragraph below, transfer cash from the Debt Service Reserve Fund to the Bond Fund in an amount equal to such deficiency; provided, however, that any such transfer by the Trustee shall not relieve the Owner of any of its obligations under the Note or under the Mortgage and that the Trustee shall notify the Rating Agency of such withdrawal. The Trustee shall on each Interest Payment Date transfer to the Bond Fund from the Debt 34 Service Reserve Fund interest earnings on the Debt Service Reserve Fund. The Trustee shall value the Debt Service Reserve Fund on each Interest Payment Date at the lowest of cost, market, or amortized value. Notwithstanding the foregoing, except when all Outstanding Bonds are to be redeemed, or unless the Trustee has filed with FHA notice of Default and intent and election to assign pursuant to Section 6.03 hereof, no money in the Debt Service Reserve Fund shall be used for payments of principal of or interest on the Bonds, other than an amount not to exceed one payment on the Note on each Interest Payment Date and the transfer of earnings on the Debt Service Reserve Fund to the Bond Fund as provided herein, if such use would result in the amount in the Debt Service Reserve Fund being reduced to less than the Debt Service Reserve Requirement. Section 4.08. Final Balances. When provision has been made for payment of all Bonds Outstanding in full, either at maturity or upon redemption, and for the payment of the Trustee's, Mortgage Servicer's, Rating Agency's and Rebate Analyst's fees and expenses and all other costs due under this Indenture after such payment in full, money remaining under the Indenture shall be transferred to the Owner. Section 4.09. Custody of Funds; Money to be Held in Trust. All moneys required to be deposited with or paid to the Trustee for the account of any fund referred to in any provision of this Inden- ture or the Loan Work -Out Agreement, except moneys required to be deposited in the Rebate Fund, shall be held by the Trustee in trust, and except for moneys deposited with or paid to the Trustee for the redemption of Bonds, notice of the redemption of which has been duly given, shall, while held by the Trustee, constitute part of the Trust Estate and be subject to the lien or security interest created hereby. Notwithstanding that moneys deposited in the Rebate Fund are not part of the Trust Estate, such moneys are to be held by the Trustee in trust and rebated to the United States Treasury as provided in this Indenture. Section 4.10. Cancellation of Obligations. Upon the redemp- tion or payment of all the outstanding Bonds in accordance with the terms of this Indenture, the Issuer and the Trustee shall take whatever steps may be necessary to cancel. the Note and release the lien of the Mortgage to the extent then held by the Trustee. In the event of the redemption or payment of the Bonds in accordance with the terms of this Indenture and the satisfaction and discharge of this Indenture, any amounts .remaining in the funds and accounts established under this Indenture (other than the Rebate Fund) shall be remitted to the Owner after payment or provision for payment of any amounts due the Issuer, the Trustee or the Mortgage Servicer as provided in Section 4,08. 35 Section 4.11. Investment of Funds. Any money held as part of any fund created in this Article, other than the Rebate Fund, shall be invested or reinvested by the Trustee under the Investment Agreement to the maximum extent possible and otherwise in Qualified Investments. Moneys in the Rebate Fund shall only be invested in obligations described in clauses (i) and (ii) of the definition of Qualified Investments. The investments so made shall be held by the Trustee and shall be deemed at all times to be a part of the fund in which such money was held; provided that for purpose of investment money held in any of the funds established hereunder may be commingled. The Trustee may act as principal or agent in the making or disposing of any investment. The Trustee is directed to sell and reduce to cash a sufficient amount of such investments whenever the cash balance in any fund shall be insufficient to cover a proper disbursement from any fund. Subject to the neces- sary withdrawals and deposits of interest earnings from various Funds to the Rebate Fund according to the instructions of Section 4.10 hereof, all interest, profits or other income derived from the investment of any Fund created by this Article shall be deposited in the Bond Fund. The Trustee shall not be liable for any losses resulting from any such investments consistent with this Section. Money held in the funds created by this Indenture shall be invested in securities and obligations maturing not later than the dates on which such money will be needed to pay principal of or interest on the Bonds. Any subsequent investment made by the Trustee shall be in Qualified Investments. For the purpose of determining the amount on deposit to the credit of any Fund, obligations purchased as an investment of money therein shall be valued semiannually at the lowest of cost, market or amortized value thereof, inclusive of accrued interest. Section 4.12. Non - Presentment of Bonds. If any Bond shall not be presented for payment when the principal thereof becomes due, either at maturity or otherwise or at the date fixed for redemption thereof, if moneys sufficient to pay such Bond shall have been deposited with the Trustee, it shall be the duty of the Trustee to hold such moneys, without liability to the Issuer, any Bondholder or any other person for interest thereon, for the Bene- fit of the owner of such Bond. Any moneys so deposited with and held by the Trustee due to nonpresentment of Bonds on any redemp- tion date must be retained by the Trustee for a period of at least one year after the final maturity date of the Bonds or advance refunding date, if applicable, thereafter, such amounts shall be paid "y the Trustee to the Owner, free from the trusts created by this indenture. Thereafter, Bondholders shall be entitled to look only to the Owner for payment, and then only to the extent of the amount to repaid by the Trustee. 36 Notwithstanding any provision of this Indenture any money deposited with the Trustee: or any other paying agent in trust for the payment of the principal of or interest or premium on any Bonds, and remaining unclaimed for four (4) years after such pay- due due and payable (whether at maturity or upon ment shall have becom e call for redemption) shall then be repaid to the owner upon its written request, and the Holders of such Bondsgthereofedandrall entitled to look only to the Owner for repayment agent with respect to other liability of the Trustee or cease. In the e en t of the repayment of such money shall thereupon s in such money to the Owner as aforesaid, the Holders of the Bond respect of which such money was deposited shall thereafter be deemed to be unsecured creditors o u o ited for the payment of such lent to the respective amounts dep Bonds and so repaid to the Owner (without interest thereon). Section 4.13. Calculations of Annual Debt Service- Yield. as The annual debt service on the Bonds shaltheeBandsuscheduledtand amount of principal of, and interest on, expected to be due and payable to Holders of the Bonds during the Bond Year, taking into account any redemptions gi Bonds previously on made. Such calculation shall be made at the beginning Year and at the dale six of investments the Bond debt Year, and shall apply p service over the twelve -month period then next following. The yield on the Bonds shall be calculated as that discount rate (determined on the basis of semi -ant al interest compounding) that, when used in computing the p principal and interest to be paid thereon, produces an amount equal to the purchase price thereof, all according to the requ e of ther.a Bonds of Income Tax Regulations 51.148 -0 -9. The purchase pr f thetBondso is an amount equal to the original offering price the public, including accrued interest, as of the date of issuance, and without allowance for discount al or any fees in to insure the nectioifwith not such issuance. However, premiums p in excess of the present value of the interest saved as a result ld on such insurance, shall be treated as interest paid. The variable the Bonds, if the Bonds should constitute, or include, under its rate obligation, being an obligation the yield on escribed formula terms, is adjusted periodically according to a p so that yield over its term cannot be determined on s the date nitial issue, shall be calculated, for the first Bond Year, and, interest rate borne by the oblig weighted averagelinterest rate for subsequent Bond Years, receding Bond Year. borne by the obligation during -the p hall be calculated according to the Yield on investments s above- stated definition, provided additionally that (1) the administrative costs of acquiring investments shall not be included; (2) investments must be acquy ad adjusts their yield; (3) and not in a manner which artificially 37 investments previously owned and subsequently attributed to the Bonds shall be valued at their fair market value at the time of such attribution; (4) notwithstanding any other provisions of this Indenture as to valuations of investments for security purposes, investments once acquired shall not be revalued for purposes of Sections 4.10 and 4.12; and (5) the yield on a variable rate investment shall not be its initial rate once acquired by the Owner if it had been previously issued, but shall be its prior year's weighted average. Section 4.14. Maintenance of Rebate Fund. The Owner covenants to take all actions necessary to comply with the rebate requirements applicable to investments of proceeds of the Bonds contained in Section 148 the Code and the Treasury Regulations thereunder. The Owner further agrees and covenants that it will cooperate with the Trustee in keeping accurate accounts of the investment earnings on all investments of gross proceeds, within the meaning of the Code and the Treasury Regulations, and the Owner and Trustee will cause a timely rebate to the United States Treasury of all the Net Rebate Liability. In the event that the Gross Proceeds of the Bonds (not including, for this purpose, Gross Proceeds periodically deposited and withdrawn for current debt service into and from the Bond Fund and Gross Proceeds held in the Debt Service Reserve Fund and Gross Proceeds which arise after six months from the date hereof which are not reasonably anticipated as of the date hereof) are not completely expended by the date six (6) months from the date of issuance of the Bonds, then the Trustee and the Owner shall under- take and perform the following requirements: (1) On each Installment or Final Calculation Date, the Owner shall retain the Rebate Analyst and shall cause such Rebate Analyst to calculate any net rebate liability. The Rebate Analyst shall be paid in accordance with clause (vi) of Section 4.06 hereof. (2) On written direction of the Owner, the Trustee shall withdraw from available funds or accounts held under the Indenture (unless the Owner shall pay) the amount of any net rebate liability set forth in the report of said Rebate Analyst and deposit the same into the Rebate Fund hereby cre- ated, and the Trustee shall, solely from amounts then con- tained in the Rebate Fund, then remit to the United States Treasury, not later than sixty (60) days after each Install- ment Calculation Date the amount then constituting 90% of such net rebate liability. Within sixty (60) days after the Final Calculation Date, the Owner shall cause said Rebate Analyst to compute, and shall direct, in writing, the Trustee to remit to the United States Treasury the net rebate liability set forth in the report of said Rebate Analyst. Said payments shall be made to the Internal Revenue service Center, Philadelphia, 38 AMK Adk Pennsylvania, or such other location determined under the Code, and filed together with a copy of the Form 8038T (which Form 803ST shall be supplied to the Trustee) with respect to the Bonds, and the Trustee shall retain records of all such calculations and rebate payments required by this Section for a period ending six (6) years after final payment of the Bonds. Section 4.15. Prevention of Bonds Becoming Arbitrage Bonds. If at any time and from time to time the Issuer determines (upon the advice of Bond Counsel) that it is necessary to restrict the yield or limit the investment of money held by the Trustee here- under in order to prevent the Bonds from becoming "arbitrage bonds" within the meaning of Section 148(d) and Section 148(f) of the Code, the Issuer shall (upon the advice of Bond Counsel) so instruct the Trustee in writing, and the Trustee shall and hereby agrees to take such action or actions as may be necessary to so restrict or limit on such investments as set forth in, and in accordance with, such instructions. Notwithstanding the foregoing, the Trustee shall not be required to take any action that in its judgment diminishes the security of the Bondholders if the Trustee obtains an opinion of nationally recognized bond counsel to the effect that failing to take such action would not jeopardize the exclusion of interest on the Bonds from gross income for federal income tax purposes. Section 4.16. Prohibited Payments. To the extent necessary to preserve the exclusion from gross income of the interest on the Bonds for federal tax purposes, neither the Trustee nor the Issuer shall make, or enter into any agreement to make, a Prohibited Pay- ment. In determining whether any amount is a Prohibited Payment, the Trustee and the Issuer may rely on an opinion of Bond Counsel. Section 4.17. Change in Regulations. The covenants and agreements contained in Sections 4. 14, 4.15 and 4.16 of this Inden- ture are intended to assure compliance with the Code, and with Section 1.148 -0 -9 of the Regulations (the "Regulations ") to the extent made applicable by the Code. In the event the Regulations are hereafter modified, or final regulations are promulgated in substitution for such regulations, and such modifications or such final Regulations modify or delete any elements of the covenants contained in such Sections in the opinion of Bond Counsel delivered to the Trustee, the Trustee and the Issuer shall be relieved of their obligations to comply with such covenants to the extent of such modification or deletion. In the event such modifications or final regulations impose additional requirements which are applicable to the Bonds in the opinion of Bond Counsel delivered to the Trustee and the Issuer, the Trustee and the Issuer hereby agree to comply with the provisions of the Regulations, as so modified, or with such final regulations. Further, in the event that in the opinion of Bond Counsel delivered to the Trustee and the Issuer, 39 failure to comply with all or a specified portion of such covenants will not adversely affect the tax - exempt status of interest on the Bonds, the Trustee and the Issuer shall be relieved of their obligations to comply with such covenants to the extent set out in such opinion of Bond Counsel. y ,4 :r i 40 ARTICLE V GENERAL COVENANTS Section 5.01. Payment of Principal and Interest. The Issuer covenants that it shall promptly pay, but only from the sources provided herein, the principal of, including any applicable redemp- tion premiums, and interest on every Bond issued under this Inden- ture at the place, on the dates and in the manner provided herein and in the Bonds, according to the true intent and meaning thereof. Section 5.02. Performance of Covenants; Authority of Issuer. The Issuer covenants that it shall faithfully perform at all times any and all covenants, undertakings, stipulations and provisions contained in this Indenture, in any and every Bond executed, authenticated and delivered hereunder and in all proceedings per- taining thereto. The Issuer covenants and represents that it is duly authorized under the constitution and laws of the State to issue the Bonds authorized hereby and to execute this Indenture, to convey the interests described in and conveyed hereby and to pledge the revenues, receipts and other amounts hereby pledged in the manner and to the extent herein set forth; that all action on its part for the issuance of the Bonds and the execution and delivery of this Indenture has been duly and effectively taken; and that the Bonds are and will be valid and enforceable obligations of the interest of the Bondholders in the Trust Estate or the revenues or receipts therefrom. Section 5.03. Instruments of Further Assurance. The Issuer covenants that it will do, execute, acknowledge and deliver or cause to be done, executed, acknowledged and delivered, such inden- tures supplemental hereto, and such further acts, instruments and transfers as may be reasonably required for the better assuring, transferring, conveying, pledging, assigning and confirming unto the Trustee all and singular its interest in the property herein described and the revenues, receipts and other amounts pledged hereby to the payment of the principal of, premium, if any, and interest on the Bonds. Any and all interest in property hereafter acquired which is of any kind or nature herein provided to be and become subject to the lien hereof shall and without any further conveyance, assignment or act on the part of the Issuer or the Trustee, become and be subject to the lien of this Indenture as fully and completely as though specifically described herein, but nothing in this sentence contained shall be deemed to modify or change the obligations of the Issuer under this Section of this Indenture. The Issuer covenants and agrees that, except as herein otherwise expressly provided, it has not and will not sell, convey, mortgage, encumber or otherwise dispose of any part of its interest in the Trust Estate or the revenues or receipts therefrom. 41 M Aft Section 5.04. Inspection of Project Books. The Issuer covenants and agrees that all books and documents in its possession relating to the Project shall at all times during regular business hours be open to inspection and copying by such accountants or other agents as the Trustee may from time to time reasonably designate. Section 5.05. No Modification of Security; Additional Indeb tedness. The Issuer covenants that it will not, without the writ- ten consent of the Trustee and notification to the Rating Agency, alter, modify or cancel, or agree to consent to alter, modify or cancel any agreement to which the Issuer is a party, or which has been assigned to the Issuer, and which relates to or affects the security for the Bonds. The Issuer further covenants not to incur any additional indebtedness prior to or on a parity with the lien of this Indenture. Section 5.06. Damac(e Destruction or Condemnation. If, as a result of fire or other casualty, the Project, or any material part thereof, is damaged or destroyed, or the Project, or any material part thereof, shall be condemned or acquired for public use, the Trustee as mortgagee shall within thirty (30) days after receiving actual notice of such damage, destruction or condemnation, and after written notice to the Owner, FHA and the Issuer, shall take the course of action set forth below: (a) Repair and Restoration. If the Project can be repaired or restored to substantially the same condition as it existed prior to the event causing such damage or destruction, or the effect of the condemnation can be relieved so that the status of the Project will be restored to substantially the same status as it existed prior to the event causing such condemnation, without, in either case, jeopardizing repayment of the principal of and interest on the Bonds, all in accordance with the opinion of an expert or experts selected as referred to below, then, upon receipt by the Trustee of the written consent of the Issuer and FHA, the Owner may so repair and restore the Project and the Owner may and /or the Trustee shall apply the net proceeds of any insurance relating to such damage, destruction or condemnation or any condemnation award to the payment or the reimbursement of the costs of such repair or restoration. Such reimbursement of the costs of repair or restoration shall be paid to the Owner by the Trustee periodically as construction progresses. The Trustee may rely on the advice of architects, engineers, accountants, financial consultants, attorneys and other experts reasonably selected by it in the foregoing matters. (b) Prep 1ption of Bonds. If the above is not followed, the Trustee shall apply the Net Pro- ceeds of any insurance relating to such damage, destruction or condemnation to the reduction of indebtedness under the Note. 42 In sc:':h event the Trustee shall deposit such net proceeds in the Bond Fund and apply such money to the redemption of Bonds in accordance with Section 3.01 of this Indenture. Section 5.07. Ownership of Note; Instruments of Further Notice. The Trustee will defend its title to the Note for the benefit of the Holders of the Bonds against the claims and demands of all persons whomsoever and the Issuer and Trustee will do, exe- cute, acknowledge, and deliver or cause to be done, executed, acknowledged and delivered, such indentures supplemental hereto, and such further acts, instruments and transfers as the Trustee may reasonably require for the better assuring, transferring, con - veying, pledging, assigning and confirming unto the Trustee all and singular its interest in the property herein described and the revenues, receipts and other amounts pledged hereby to the payment of the principal of, and premium, if any, and interest on the Bonds. Any and all interest in property hereafter acquired which is of any kind or nature herein provided to be and become subject to the lien hereof shall and without any further conveyance, assignment or act on the part of the Issuer or the Trustee, become and be subject to the lien of this Indenture as fully and com- pletely as though specifically described herein, but nothing con- tained in this sentence shall be deemed to modify or change the obligations of the Issuer under this Section. Section 5.08. Required Insurance. The Trustee shall require that the Owner maintain all insurance policies required to be main- tained pursuant to the Mortgage and by FHA. All such policies shall include standard loss payable provisions naming the Trustee and the commissioner of Housing and Urban Development as loss payees as their interests appear and all proceeds of such insurance shall be applied in accordance with the provisions of Section 5.06 hereof. Section 5.09. Representations Warranties and Additional Covenants of the Issuer. The Issuer hereby represents, warrants and covenants as follows: (a) The Issuer has been duly organized and is now validly existing and in good standing as a body politic and corporate and a political subdivision of the State under the laws of the State, and the Issuer has all necessary power and authority to execute and deliver this Indenture, to execute, deliver and issue the Bonds and perform its duties and discharge its obli- gations hereunder and thereunder. The revenues and assets pledged for the repayment of the Bonds are and will be free and clear of any pledge, lien or encumbrance prior to, or equal with, the pledge created by this Indenture, and all action on the part of the Issuer to that end has been duly and validly taken. The Issuer shall at all times, to the extent permitted by law, defend and protect the pledge created here- under against any and all claims whatsoever. 43 ry. 1 , (b) The Issuer shall at all times do and perform all acts and things permitted by law and necessary or desirable in order to assure that the interest paid on the Bonds shall be excluded from gross income for federal income tax purposes. Section 5.10. Tax Covenants. The Issuer covenants to the Holders of the Bonds that notwithstanding any other provisions hereof or of any other instrument, it will neither make nor cause to be made any investment or other use of the proceeds of the Bonds that would cause the Bonds to be arbitrage be---.Is under Section 103(c) of the 1954 Code or Section 148 of the Coca and the Regula- tions thereunder or otherwise cause the interest on the Bonds to become included in gross income for federal income tax purposes. This covenant shall extend throughout the term of the Bonds, to all funds created hereunder and all money on deposit to the credit of any such fund. 44 ARTICLE VI DEFAULT PROVISIONS AND REMEDIES OF TRUSTEE AND BONDHOLDERS Section 6.01. Events of Default. Each of the following shall be an "event of default" with respect to the Bonds (a "Default ") under this Indenture: (a) default in the due and punctual payment of any interest on any Bond; or (b) default in the due and punctual payment of the prin- cipal of or premium, if any, on any Bond whether at the stated maturity t..ereof, or on proceedings for redemption thereof, or on the maturity thereof by declaration; or (c) default, and the continuation thereof for a period of 30 days following notice to the Trustee, in the performance or observance of any other of the covenants, agreements or con- ditions on the part of the Issuer in this Indenture or in the Bonds after written notice to the Issuer from the Trustee or the registered owners of at least 25% of the Bond Obligation at such time specifying such default and requiring the same to be remedied. The Trustee and the Issuer agree that, notwithstanding the provisions hereof, no default under the terms of this Indenture shall be construed as resulting in a default under the Mortgage Note, the Mortgage or related Mortgage Loan Documents, unless such event also constitutes a default thereunder. Section 6.02. Acceleration, Other. Remedies Upon Default. Upon the occurrence of a Default as provided in Section 6.01(x) and (b) , (i) the Trustee may, and (ii) upon the written request of the holders of not less than 25% of the Bond Obligation then outstand- ing, the Trustee shall, or (iii) in the case of a Default under Section 6.01(c) and one upon the written request of the holders of 100% of the Bond Obligation then Outstanding the Trustee shall, by notice in writing delivered to the Issuer, declare the principal of all Bonds then outstanding and the interest accrued thereon immediately due and payable, and such principal and interest shall thereupon become and be immediately due and payable. If at any time after the Bonds shall have been so declared due and payable, and before any judgment or decree for the payment of the money due shall have been obtained or entered, the Issuer or the owner shall pay to or deposit with the Trustee a sum sufficient to pay all principal of the Bonds then due (other than solely by reason of such declaration) and all unpaid installments of interest (if any) upon all the Bonds then due, with interest at the rate 45 borne by the Bonds on such overdue principal and (to the extent legally enforceable) on such overdue installments of interest, and the reasonable expenses of the Trustee shall have been made good or cured or adequate provisions shall have been made therefor, and all other defaults hereunder either (i) have been made good or cured or (ii) waived in writing by 100% of the owners of the Bond Obligation then Outstanding, then and in every case, the Trustee on behalf of the holders of all the Bonds shall rescind and annul such declaration and its consequences; but no such rescission and annulment shall extend to or shall affect any subsequent default, nor shall it impair or exhaust any right or power consequent thereon. Upon the happening and continuance of a Default, the Trustee in its own name and as trustee of an express trust, on behalf and for the benefit and protection of the holders of all Bonds with respect to which such a Default has occurred, may also proceed to protect and enforce any rights of the Trustee and, to the full extent that the holders of such Bonds themselves might do, the rights of such Bondholders under the laws of the State or under this Indenture by such of the following remedies as the Trustee shall deem most effectual to protect and enforce such rights: (1) by mandamus or other suit, action or proceeding at law or inequity, to enforce the payment of the principal of, premium, if any, or interest on the Bonds then Outstanding, or for the specific performance of any covenant or agreement contained herein or in the Mortgage Note or the Mortgage, or to require the Issuer to carry out any other covenant or agreement with Bondholders and to perform its duties under the Act; (2) by pursuing any available remedies under the Mortgage Note or the Mortgage; (3) in connection with a Default under Section 6.01 by realizing or causing to be realized through sale or otherwise upon the security pledged hereunder; and (4) by action or suit in equity, to enjoin any acts or things that may be unlawful or in violation of the rights of the holders of the Bonds. No remedy by the terms of this Indenture conferred upon or reserved to the Trustee or to the Bondholders is intended to be exclusive of any other remedy, but each and every such remedy shall be cumulative and shall be in addition to any other remedy given to the Trustee or to the Bondholders hereunder or under the Mortgage Note or the Mortgage, or now or hereafter existing at law or in equity or by statute. No delay or omission to exercise any right or power accruing upon any Default shall impair any such right or power or shall be construed to be a waiver of any such Default or 46 acquiescence therein, and every such right and power may be exercised from time to time and as often as may be deemed expedi- ent. No waiver of any Default hereunder, whether by the Trustee or by the Bondholders, shall extend to or shall affect any subsequent default or event of default or shall impair any rights or remedies consequent thereto. Section 6.03. Rights of Bondholders. If any event of default shall have occurred and if requested in writing so to do by the owners of not less than 25% of the Bond Obligation with respect to which there is a default, and if indemnified as provided herein, the Trustee shall be obliged to exercise one or more of the rights and powers conferred by this Article as the Trustee, being advised by counsel, shall deem most expedient in the interest of the affected Bondholders. Subject to the provisions of Section 6.07, the holders of a majority of the Bond Obligation with respect to which an event of default has occurred shall have the right at any time, by an instrument in writing executed and delivered to the Trustee, to direct the time, method and place of conducting all proceedings to be taken in connection with the enforcement of the terms and conditions of this Indenture, or for the appointment of a receiver or any other proceedings hereunder, in accordance with the provisions of law and of this Indenture. Section 6.04. Waiver by Issuer. Upon the occurrence of an event of default, to the extent that such right may then lawfully be waived, neither the Issuer nor anyone claiming through or under it shall set up, claim or seek to take advantage of any appraisal, valuation, stay, extension or redemption laws now or hereinafter in force, in order to prevent or hinder the enforcement of the Inden- ture; and the Issuer, for itself and all who may claim through or under it, hereby waives, to the extent that it lawfully may do so, the benefit of all such laws and all right of appraisement and redemption to which it may be entitled under the laws of the State and the United States. Section 6.05. Application of Money. Any money received by the Trustee in the event of a default pursuant to this Article shall be applied in the following order, at the date or dates fixed by the Trustee and, in the case of the distribution of such money on account of principal, or premium, if any, or interest, upon presentation of Bonds, and notation thereon of the payment if only partially paid and upon surrender thereof if fully paid: (a) first, to the payment of all amounts then due on the Bonds for principal, premium, if any, and interest, in respect of which or for the benefit of which, money has been collected (other than Bonds which have matured or otherwise become pay- able prior to such event of default and money for the payment of which is held in the Bond Fund), ratably without preference or priority of any kind, according to the amounts due and 47 payable on such Bonds, for principal, premium, if any, and interest respectively; (b) next, to the payment of all amounts due the Trustee under Section 7.06, any Extraordinary Mortgage Servicing Fees and Expenses and any amounts owed to the Issuer; (c) next, to the reimbursement of HUD or FHA for any claims it may have for reimbursement for any payment made by either HUD or FHA under the mortgage insurance; and (d) next, any money remaining in any fund or account held by the Trustee after payment of all amounts due pursuant to (a), (b) and (c) above shall be paid to the Owner by the Trustee. Section 6.06. FHA Mortgage Insurance. (a) The Trustee shall, at all times so long as the Mortgage Loan is held by it hereunder, take all steps necessary to maintain the Mortgage Insurance with respect to the Mortgage Loan. In the event of a failure by the Owner to make the entire amount of any payment due under the Mortgage Note or to perform any other covenant under the provisions of the Mortgage, the Trustee shall take all steps necessary not to impair the interests of the Bond- holders and to obtain the Mortgage Insurance benefits in cash. (b) Subject to the foregoing, upon such payment default or performance default, the Trustee shall: (i) immediately upon becoming entitled to do so, and not later than the 30th day following the due date of the payment under the Mortgage Note after a failure by the Owner to make such payment: (A) Subject to subsection (ii) below, give written notice of Default and Intention and Election to Assign in writing to HUD Central (with a copy to the applicable HUD area office and the Rating Agency) which notice shall: 1. state that the Mortgage Loan was funded with the proceeds of tax - exempt bonds rated by the Rating Agency entitled to priority processing and expedited processing procedures by FHA; and 2. provide a schedule of payments of Debt Service with respect to the Bonds indicating funds available to make such payments; and 3. request forms and instructions relating to assignment of the Mortgage and shall attach to such request a copy of the letter from HUD to the Rating 48 Agency, dated June 23, 1987, a copy of which is attached hereto as Exhibit C; and 4. request payment in cash; and (B) give notice, in writing, to the HUD area office of the occurrence of the default entitling the Trustee to claim Mortgage Insurance benefits. (ii) within five days of receiving the forms and instruc- tions described in (i)(A)(3) above, the Trustee shall submit the required legal documentation to HUD's Office of 3eneral Counsel; (iii) as soon as possible, but in no event later than 30 days after recordation and assignment of the Mortgage, submit fiscal documentation to HUD's Office of Finance and Accounting and complete and submit any outstanding legal documents; (iv) as soon as practicable after filing its election to assign with FHA, but not later than 30 days thereafter (or any shorter period required by FHA), the Trustee shall: (A) assign the Mortgage, the Mortgage Note, and such other necessary documents as shall be required by FHA directly to FHA, giving all required notices, (B) record the Assignment of the Mortgage Note to FHA in accordance with instruction from HUD, and (C) submit to HUD the Application for Mortgage Insurance benefits and request payment of the mortgage insurance benefits in cash. (c) Subject to Subsection (a) above, the Trustee shall not consent to any adjustments or revisions of the terms of the Mort- gage Loan or the contract of FHA Mortgage Insurance, or take, or fail to take, any action in the event of a default, which would cause there to be insufficient money available for the scheduled payment of principal and interest on the Bonds, or for the payment of the Ordinary Trustee's Fees and Expenses and Ordinary Mortgage Servicing Fees and Expenses, subject to Section 6.08. The Trustee may not foreclose upon the Mortgage. (d) Request confirmation from the Rating Agency of the rating prior to pursuing a partial payment under Section 207.258(b) of the FHA Regulations. Section 6.07. Opportunity to Cure Default Under Mortgage Note. Prior to the date the Mortgage Note and the Mortgage are assigned to FHA pursuant to Section 6.06 hereof and prior to the date of notice of redemption of the Bonds pursuant to Section 3.03 49 hereof, the Trustee may allow the Owner to cure any default under the Mortgage Note and the Mortgage but only subject to the following conditions and provided that during the period the Trustee is allowing the Owner to cure, it shall continue to pursue benefits under the FHA Mortgage Insurance: (1) The Owner must pay to the Trustee any overdue pay- ments of principal and interest on the Mortgage Note. (2) The Owner must cure any non - monetary defaults under the Mortgage, this Indenture and any related documents to the satisfaction of the Trustee. (3) If any money has been withdrawn from the Trust Estate to be used in connection with the default, the Owner must: (a) Redeposit under the Trust Estate an amount at least equal to the amount withdrawn, or (b) Provide the Trustee with cash or a letter of credit in such form acceptable to the Trustee (and which would not adversely affect the Rating Agency's rating on the Bonds) that (i) provides a source for the payment of the principal and interest on the Bonds and (ii) is in an amount at least equal to the amount withdrawn from the Trust Estate plus an amount equal to the interest that would have been earned on the withdrawn amount had it been invested at the rate of 8.1% per annum, and (c) Provide to the Trustee an unqualified opinion of nationally recognized bankruptcy counsel, satisfactory to the Trustee (and approved by the Trustee's counsel) with respect to the deposit specified in (a) or (b) above and which opinion (i) if the deposit is in the form of a letter of credit (which letter of credit must be issued or confirmed by a bank whose unsecured long -term debt is rated by the Rating Agency at least as high as the rating then in effect on the Bonds) states that the letter of credit is a valid and binding obligation of the bank issuing the letter of credit and is enforceable against the bank or (ii) if the deposit is in any other form states that such amounts are exempt from claims of creditors of the provider of such funds pursuant to 11 t, U.S.C. Sections 362(a) and 547(b). (4) The Owner, must deposit with the Trustee an amount equal to any loss of investment income resulting from the failure to make any Mortgage Note payments when due and pro- vide to the Trustee an opinion of counsel of the type des- cribed in paragraph (3)(c) above with respect thereto. 50 (5) The Trustee must receive written confirmation from FHA that the cure of any such default and the withdrawal of any notice of assignment of the Mortgage Note and Mortgage that had been given under Section 6.06 will not adversely affect the FHA Mortgage Insurance on the Mortgage Note or be construed as a waiver or reduction thereof. (6) Cash flows, prepared by a qualified independent third party, must be delivered to the Trustee which show that after the action taken under (3) above, the timely payment of the principal and interest on the Bonds and the Ordinary Trustee's Fees and Expenses, and the Ordinary Mortgage Servicing Fees and Expenses, as set forth in the original cash flows, will not be adversely affected. (7) The Trustee shall not allow the cure of the default if it would adversely affect the Bondholders. (8) The Owner shall pay all fees and expenses of the Trustee, the Issuer and the Mortgage Servicer, extraordinary or otherwise (and including, without limitation, any reason- able legal fees and expenses) incurred in connection with such default and shall fully fund all FHA project reserves and reserves under this Indenture to their required levels (including restoration of any interest income loss due to a withdrawal from such reserve) and provide to the Trustee an opinion of counsel of the type described in paragraph 3(c) above with respect thereto. (9) If the FHA project reserves are called upon to effect a Mortgage cure, notify the Rating Agency. The allowance by the Trustee of any cure upon a default under the Mortgage Note will not affect any subsequent default pro - ceedings with respect to the FHA Mortgage Insurance or any claims thereunder. Section 6.08. Prepayment Penalty Lockout Period Claim Pro - cessing Procedures. The Issuer and the Trustee on behalf of the Issuer certifies that, in the event of a default on the Mortgage Loan during the term of a prepayment lock -out and /or penalty (i.e., prior to the date an which prepayments may be made with a premium of one percent or less), the Trustee on behalf of the Issuer will immediately after the Owner has been in default on the Mortgage Note for 30 days: (1) file a request in writing with HUD Central (with a copy to the Rating Agency) for a three month extension of the time to notify HUD of the Intention and Election to Assign simultaneously with the filing of the notice of default with the HUD area office. The Trustee shall include with the notice of default to the HUD area office and with the 51 communication to HUD Central (i) a statement that the Project is financed with rated bonds subject to priority processing and expedited processing procedures as described in HUD's letter to Standard & Poor's Corporation dated June 23, 1987, which is an Exhibit hereto (attaching a copy of such letter), (ii) a schedule of debt service payments on the Bonds, indicating the funds available to make debt service payments on the Bonds and (iii) a request for priority processing and the forms and instructions necessary to assign the Mortgage Loan to FHA; (2) if HUD grants the requested (or a shorter) extension of the notice filing deadline, cooperate with the Owner in connection with a refinancing to cure the default and avert an insurance claim, but simultaneously pursue full assignment of the Mortgage Note pursuant to Section 6.06 hereof; (3) report to HUD at least monthly on any progress in arranging a refinancing; (4) otherwise cooperate with HUD in taking reasonable steps in accordance with prudent business practices to avoid an insurance claim; (5) submit legal documents to HUD Office of General Coun- sel within five days of receipt of forms and instructions from FHA; (6) require any successors or assigns to certify in writing that they agree to be bound by these conditions for the remainder of the term of the prepayment lock -out and /or premium; (7) submit fiscal documents required by HUD office of Finance and Accounting and any additional legal documents as soon as possible but in no event later than 30 days after recordation; (8) notify HUD 30 days prior to any Payment Date on the Bonds that insufficient moneys are available to make such payment and request immediate payment of Mortgage Insurance benefits in cash as specified in Subsection (a) above; (9) if at any time during the extension period the Trustee determines that a workout is infeasible, immediately request HUD to make such a determination and submit Notice of Intention and Election to Assign to HUD Central; (10) obtain prior written confirmation of the rating from the Rating Agency prior to consent to any workout agreement or any adjustment or revision of the contract of Mortgage Insurance; 52 (11) obtain written confirmation of the rating from the Rating Agency prior to requesting an extension of initial three month extension period; (12) if request for further extension is not met, imme- diately submit Notice of Intention and Election to Assign to HUD Central; and (13) as soon as possible after submitting Notice of with Intention and Election to Assign, o in accordance Insurance instructions from FHA, submit Application Benefits and record assignment of Mortgage Note to FHA. Section 6.09. Partial Assignment Option. In the event HUD requests that the Trustee on behalf of the Trissuermayree to such partial assign the Mortgage Loan to confirmation in writing of the partial assignment only up rating on the Bonds from the Rating Agency. The Trustee may request or accept an extension of time to file a Notice of Inten- tion and Election to Assign, other than pursuant to this Section on the 6.09, only after a confirmation in writing e ent shallating Trustee Bonds from the Rating Agency. request an extension of time for filing the Notice of such Intention and Election to Assign in excess of three months period required by HUD) from the date of the notice of default. Section 6.10. Remedies Vested in Trustee. All rights of action, including the right to file proof of claims, under this Indenture or under any of the Bonds may be B of ror d the the Trustee without the possession of any of the thereof in any trial or other proceedings relating thereto and any such suit or proceeding instituted by the Trustee joining be brought in its name as Trustee without the necessity of j g tiffs or defendants any holders of the Bonds, and any recovery of judgment shall be for the benefit as provided herein of the holders of the Outstanding Bonds. Section 6.11. Remedies of Bondholders. No holder of any Bond shall have any wgfo then enforcement fith his Indentureooreforgthe equity or at la ointment of a execution of any trust hereunder or for the app receiver or any other remedy hereunder, unless (a) a default shall have occurred of which h the Tr default shall have been become notified eevent pro- have default; herein; default; (c) the holders of at least 25% of the Bond Obligation with respect to which there is an event of default shall have made written request to the 'Trustee and shall have offered reasonable opportunity to the Trustee either to proceed to exercise t o r pros hereinbefore granted or. to such holders shall have offered to the ceeding in its own name; (d) the Trustee shall Trustee indemnity as provided herein; and ( e ) powers within 60 days thereafter fail or refuse to exercise the 53 hereinbefore granted, or to institute such action, suit or pro- ceeding; it being understood and intended that no one or more holders of the Bonds shall have any right in any manner whatsoever to affect, disturb or prejudice the lien of this Indenture or the rights of any other holders of Bonds or to obtain priority or pre- ference over any other holders or to enforce any right under this Indenture, and for the equal and ratable benefit of all holders of Bonds with respect to which there is a default. Nothing contained in this Indenture shall, however, affect or impair the right of any Bondholder to enforce the payment of the principal of, the premium, if any, and interest on any Bond at the maturity thereof or the obligation of the Issuer to pay the principal of, premium, if any, and interest on the Bonds issued hereunder to the respective holders thereof, at the time, in the place, from the sources and in the manner expressed in said Bonds. Section 6.12. Termination of Proceedincfs. In case the Trustee shall have proceeded to enforce any right under this Inden- ture by the appointment of a receiver, by entry or otherwise, and such proceedings shall have been discontinued or abandoned for any reason, or shall have been determined adversely, then and in every such case the Issuer and the Trustee shall be restored to their former positions and rights hereunder with respect to the Trust Estate herein conveyed, and all rights, remedies and powers of the Trustee shall continue as if no such proceedings had been taken. i Section 6.13. Waivers of Events of Default. The Trustee shall waive any event of default hereunder and its consequences and rescind any declaration of maturity of principal of and interest on the Bonds upon the written request of the holders of 100% of the Bond Obligation with respect to which there is a default; provided, however, that there shall not be waived (a) any event of default in principal of any Bonds at the date of maturity the payment of the specified therein, or upon proceedings for mandatory redemption, (b) any default in the payment when due of the interest or premium on any such Bonds, unless prior to such waiver or rescission all arrears of interest, with interest (to the extent permitted by law) at the rate borne by the Bonds in respect of which such default shall have occurred on overdue installments of interest or all arrears of payments of principal or premium, if any, when due (whether at the stated maturity thereof or upon proceedings for mandatory redemption) as the case may be, and all expenses of the Trustee (including attorney's fees), in connection with such default shall have been paid or provided for, and in case of any such waiver or rescission, or in case any proceeding taken by the Trustee on account of any such default shall have been discontinued or abandoned or determined adversely, then and in every such case the Issuer, the Trustee and the Bondholders shall be restored to their former positions and rights hereunder, respectively, but no such waiver or rescission shall extend to any subsequent or other default, or impair any right consequent thereto. 54 M i Section 6.14, Notice to Bondholders if Default Occurs. Upon the occurrence of an event of default, or if an event occurs which could lead to a default with the passage of time and of which the Trustee is required to take notice, the Trustee shall, within 30 days, give written notice thereof by first -class mail to the owners of all Bonds then Outstanding, shown by the list of Bondholders required to be kept at the office of the Trustee. t, J x hi 55 ARTICLE VII CONCERNING THE TRUSTEE Section 7.01. Standard of Care. The Trustee shall, prior to an event of default as defined in Section 6.01, and after the curing of all such events which may have occurred, perform such duties and only such duties as are specifically set forth in this Indenture. The Trustee shall, during the existence of any such event of default (which shall not have been cured) exercise such rights and powers vested in it by this Indenture and use the same degree of care and skill in their exercise as a prudent man would exercise or use under the circumstances in the conduct of his own affairs. No implied covenants or obligations shall be read into this Indenture against the Trustee. No provision of this Indenture shall be construed to relieve the Trustee from liability for its own neglect or willful miscon- duct, except that: (a) prior to such an event of default hereunder, and after the curing of all such events of default which may have occurred: (i) the duties and obligations of the Trustee shall be determined solely by the express provisions of this Indenture, and the Trustee shall not be liable except for the performance of such duties and obligations as are specifically set forth in this Indenture; and (ii) in the absence of bad faith on the part of the Trustee, the Trustee may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed therein, upon any certificate or opinion furnished to the Trustee by the person or persons authorized to furnish the same; (b) at all times, regardless of whether or not any such event of default shall exist: (i) the Trustee shall not be liable for any error of judgment made in good faith by an officer or employee of the Trustee; and (ii) the Trustee shall not be liable with respect to any action taken or omitted to be taken by it in good faith in accordance with the direction of the Holders of not less than a majority (or such lesser or greater per- centage as is specifically required or permitted by this Indenture) in aggregate principal plus accrued but unpaid interest on the outstanding Bonds relating to the time, 56 method and place of conducting any proceeding for any remedy available to the Trustee, or exercising any trust or power conferred upon the Trustee under this Indenture. Section 7.02. Reliance Upon Documents. Except as otherwise provided in Section 7.01: (a) the Trustee may rely upon the authenticity or truth of the statements and the correctness of the opinions expressed in, and shall be protected in acting upon any reso- lution, certificate, statement, instrument, opinion, report, notice, notarial seal, stamp, acknowledgment, verification, request, consent, order, bond, or other paper or document of the proper party or parties; (b) any notice, request, direction, election, order or demand of the Issuer mentioned herein shall be sufficiently evidenced by an instrument signed in the name of the Issuer by any officer of the Issuer (unless other evidence in respect thereof be herein specifically prescribed), and any resolution of the Issuer may be evidenced 'to the Trustee by a copy of such resolution duly certified by the Clerk of the Issuer; (c) any notice, request, direction, election, order or demand of the Owner mentioned herein shall be sufficiently evidenced by an instrument purporting to be signed in the name of the Owner by any officer of the Owner (unless other evi- dence in respect thereof be herein specifically prescribed), and any resolution or certification of the Owner may be evidenced to the Trustee by a copy of such resolution duly certified by an officer of the Owner; (d) in the administration of the trusts of this Inden- ture, the Trustee may execute any of the trusts or powers hereby granted directly or through its agents or attorneys, and the Trustee may consult with counsel (who may be counsel for the Issuer) and the opinion or advice of such counsel shall be full and complete authorization and protection in respect of any action taken or permitted by it hereunder in good faith and in accordance with the opinion of such counsel; (e) whenever in the administration of the trusts of this Indenture, the Trustee shall deem it necessary or desirable that a matter be proved or established prior to taking or permitting any action hereunder, such matters (unless other evidence in respect thereof be herein specifically pre- scribed), may in the absence of negligence or willful miscon- duct on the part of the Trustee, be deemed to be conclusively proved and established by a certificate of an officer or authorized agent of the Issuer or the Owner and such certif- icate shall in the absence of bad faith on the part of the Trustee be full warrant to the Trustee for any action taken or 57 permitted by it under the provisions of this Indenture, but in its discretion the Trustee may in lieu thereof accept other evidence of such matter or may require such further or addi- tional evidence as it may deem reasonable; (f) the recitals herein and in the Bonds (except the Trustee's Certificate of Authentication thereon) shall be taken as the statements of the Issuer and the Owner and shall not be considered as made by or imposing any obligation or liability upon the Trustee. The Trustee makes no representa- tions as to the value or condition of the Trust Estate or any part thereof, or as to the title of the Issuer or the Owner to the Trust Estate, or as to the security of this Indenture, or of the Bonds issued hereunder, and the Trustee shall incur no liability or responsibility in respect of any of such matters; (g) the Trustee shall not be personally liable for debts contracted or liability for damages incurred in the management or operation of the Trust Estate; and every provision of this Indenture relating to the conduct or affecting the liability of or affording protection to the Trustee shall be subject to the provisions of this subsection (g); (h) the Trustee shall not be required to ascertain or inquire as to the performance or observance of any of the covenants or agreements herein or in any contracts or securi- ties assigned or conveyed to or pledged with the Trustee hereunder, except for monetary defaults that are evident from the funds and accounts held hereunder, the Trustee shall not be required to take notice or be deemed to have notice or actual knowledge of any default or event of default specified in Section 6.01 hereof unless the Trustee shall receive from the Issuer, or the Holder of any Bond written notice stating that a default or event of default has occurred and specifying the same, and in the absence of such notice the Trustee may conclusively assume that there is not such default. Every provision contained in this Indenture or related instruments or in any such contract or security wherein the duty of the Trustee depends on the occurrence and continuance of such default shall be subject to the provisions of this subsection (h); and (i) the Trustee shall be under no duty to confirm or verify any financial or other statements or reports or certif- icates furnished pursuant to any provisions hereof, and shall be under no other duty in respect of the same except to retain the same in its files and permit the inspection of the same at reasonable times by the Holder of any Bond. None of the provisions contained in this Indenture shall require the Trustee to expend or risk its own funds or otherwise incur personal financial liability in the performance of any of its 58 duties or in the exercise of any of its rights or powers. Nothing in this Section 7.02 shall in any way reduce the duties and obliga- tions of the Trustee with respect to the Note and Mortgage. Section 7.03. Use of Proceeds. The Trustee shall not be accountable for the use or application by the Issuer of any of the Bonds authenticated or delivered hereunder, or of the proceeds of the Bonds, except as provided in Articles IV and V hereof. Section 7.04. Trustee May Hold Bonds. The Trustee and its officers and directors may acquire and hold, or become the pledgee of Bonds and otherwise deal with the Issuer and the Owner in the manner and to the same extent and like effect as though it were not Trustee hereunder. Section 7.05. Trust Imposed. All money received by the Trustee shall, until used or applied as herein provided, be held in trust for the purposes for which they were received, but need not be segregated from other funds except to the extent required by law. Section 7.06. Compensation of Trustee. The Trustee shall be entitled to compensation for all services rendered by it, including but not limited to its obligations under Section 4.14 hereof in the execution of the trusts hereby created and in the exercise and performance of any of the powers and duties hereunder of the Trustee to the extent funds are available therefor, in accordance with Section 4.02 or 4.06 hereof. If any property, other than cash, shall at any time by held by the Trustee subject to,this Indenture, or any supplemental indenture, as. security for the Bonds, the Trustee, if and to the extent authorized by a receiver- ship, bankruptcy, or other court of competent jurisdiction or by the instrument subjecting such property to the provisions of this Indenture as such security for the Bonds, shall be entitled to make advances for the purpose of preserving such property or of dis- charging tax liens or other liens or encumbrances thereon. The Trustee shall also be indemnified by the Owner for, and held harm- less against, any loss, liability, expense or advance incurred or made without gross negligence or willful misconduct on the part of the Trustee, arising out of or in connection with the acceptance of this trust, including the costs and expenses of defending itself against any claim or liability in connection with the Project. Payment to the Trustee for its services and reimbursement to the Trustee for its expenses, disbursements, liabilities and advances, shall be limited to the sources described in Section 4.05 hereof and in the Loan Work -Out Agreement. The Issuer shall have no liability for Trustee's fees, costs or expenses. Subject to the provision of Section 7.09 hereof, the Trustee agrees that it shall continue to perform its duties hereunder even in the event that funds designated for payment of its fees or the fees of the Mort- gage Servicer shall be insufficient for such purposes or in the 59 event that the owner fails to pay the ordinary Trustee's Fees and Expenses, as required by the Loan work -Out Agreement.; Section 7.07. Maintenance of Office. There shall at all times be a Trustee hereunder which shall be a corporation organized: and doing business under the laws of the United States of America or any State thereof authorized under such laws to exercise corpor- ate trust powers, having its principal office and place of business in any state, having a combined capital and surplus of at least Fifty Million Dollars ($50,000,000), and subject to supervision or examination by Federal or state authority. The Trustee shall be an If mortgagee and maintain that status. If such cor- poration or association publishes reports of condition at least annually, pursuant to law or to the requirements of any supervising or examining authority above referred to, then for the purposes of this Section the combined capital and surplus of such corporation or association shall be deemed to be its combined capital and sur- plus as set forth in its most recent report of conditions so pub- lished. In case at any time the Trustee shall cease to be eligible in accordance with the provisions of this Section, the Trustee shall resign immediately in the manner and with the effect spe- cified in section 7.09 hereof. Section 7.08. Successor Trustee. Any corporation or associa- tion into which the Trustee may be converted or merged, or with which it may be consolidated, or to which it may sell or transfer its trust business and assets as a whole or substantially as a whole, or any corporation or association resulting from any such conversion, sale, merger, consolidation or transfer to which it is a party shall, Aso facto, be and become successor Trustee here- under and vested with all the title to the whole property or Trust Estate and all the trusts, powers, discretions, immunities, privi- leges and all other matters as was its predecessor, without the execution or filing o � nyofi instruments rear further t,annything conveyance on the p Y herein to the contrary notwithstanding. Section 7.09. Resignation by the Trustee. The Trustee and any successor Trustee may at any time resign from the trusts hereby created by giving written notice to the Issuer and to the owner, and by giving notice by registered or certified mail to each registered owner of the Bonds then Outstanding. Such notice to the Issuer and to the Owner may be served personally or sent by registered mail. The Trustee shall not resign until a successor Trustee has been appointed. If no successor Trustee shall have been appointed and have accepted appointment within thirty (30) days following delivery of all required notices of resignation, the resigning Trustee may petition any court of competent jurisdiction for the appointment of a successor Trustee. Section 7.10. Removal of the Trustee. The Trustee may be removed at any time, by an instrument or concurrent instruments in 60 writing delivered to the Trustee, the Issuer and the Owner, and signed by the owners of a majority in aggregate principal plus accrued but unpaid interest on the Outstanding Bonds. Section 7.11. Appointment of Successor Trustee by the Bond- holders; Temporary Trustee. In case the Trustee hereunder shall resign or be removed, or be dissolved, or shall be in course of dissolution or liquidation, or otherwise become incapable of acting hereunder, or in case it shall be taken under the control of any public officer or officers, or of a receiver appointed by a court, a successor may be appointed by the owners of a majority in aggre- gate principal plus accrued but unpaid interest on the outstanding Bonds, by an instrument or concurrent instruments in writing signed by such Holders, or by their duly authorized attorneys; provided, nevertheless, that in case of vacancy the Issuer may appoint a temporary Trustee to fill such vacancy until a successor Trustee shall be appointed by such Bondholders in the manner above pro- vided; and any such temporary Trustee so appointed by the Issuer shall immediately and without further act be superseded by the Trustee so appointed by such Bondholders. Every such Trustee appointed pursuant to the provisions of this Section shall be a trust company or bank organized under the laws of the United States of America or any state thereof and which is in good standing, within or outside the State, having a reported capital and surplus of not less than $50,000,000 and at least $50,000,000 in trust assets under management if there be such an institution willing, qualified and able to accept the trust upon reasonable or customary terms and qualified to act as a HUD approved FHA mortgagee. The Rating Agency shall be notified if a successor Trustee is appointed. Section 1.12. Concerning Any Successor Trustee. Every suc- cessor Trustee appointed hereunder shall execute, acknowledge and deliver to its predecessor and also to the Issuer an instrument in writing accepting such appointment hereunder and accepting assign- ment of the Mortgage to it as mortgagee, and thereupon such succes- sor, without any further act, deed or conveyance, shall become fully vested with all the estates, properties, rights, powers, trusts, duties and obligations of its predecessor; but such prede- cessor shall, nevertheless, on the written request of the Issuer or the owner, or of its successor, and upon payment of all amounts due such predecessor, execute and deliver such instruments as may be appropriate to transfer to such successor Trustee all the estates, properties, rights, powers and trusts of such predecessor hereunder; and every predecessor Trustee shall deliver all securi- ties and money held by it as Trustee hereunder to its successor. Should any instrument in writing from the Issuer be required by a successor Trustee for more fully and certainly vesting in such successor the estate, rights, powers and duties hereby vested or intended to be vested in the predecessor, any and all such instru- ments in writing shall, on request, be executed, acknowledged and delivered by the Issuer. The resignation of any Trustee and the 61 instrument or instruments removing any Trustee and appointing a successor hereunder, together with all other instruments provided for in this Article, shall be filed and /or recorded by the succes- sor Trustee in each recording office where the Indenture shall have been filed and /or recorded. Section 7.13. Successor Trustee as Trustee Paying Agent and Bond Registrar. In the event of a change in the office of Trustee, the predecessor Trustee which shall have resigned or shall have been removed shall cease to be trustee and Paying Agent on the Bonds and Bond Registrar, and the successor Trustee shall become such Trustee, Paying Agent and Registrar upon giving notice to and obtaining consent of the Rating Agency. Section 7.14. Servicing the Mortgage Loan, Servicing Agreement. There shall be engaged an FHA - approved mortgage banking company or financial institution to service the Mortgage Loan. The Trustee is authorized to execute a Mortgage Servicing Agreement in substantially the form heretofore furnished to the Trustee providing for the servicing of the Mortgage by the Mortgage Servicer. Such Mortgage Servicing Agreement shall require the Mortgage Servicer to transfer money received by it in respect of the Note to the Trustee within three (3) business days provided that payments under the Mortgage Servicing Agreement shall be pay- able as provided herein. The Mortgage Servicing Agreement shall require that Note payments shall be deposited in fully insured FDIC accounts prior to such transfer. In the event such Mortgage Ser- vicing Agreement is terminated, the Trustee shall service the Mort- gage Loan itself until it can engage a qualified successor Mortgage Servicer to service the Mortgage Loan in accordance with the provi- sions of this Section and shall give the Rating Agency immediate notice of such fact. The Trustee covenants and agrees that the Mortgage Loan will be serviced in accordance with all applicable provisions of the National Housing Act of 1934, as amended, and all applicable rules and regulations thereunder. The Trustee further covenants and agrees that it- shall at all times do and perform all acts permitted by law and necessary in order to assure that the Mortgage Insurance shall remain in full force and effect for as long as the Bonds are Outstanding. Such acts include without limitation assuring the timely payment of the Mortgage Insurance premium and of the casu- alty insurance premium, that the annual inspection required by FHA is accomplished and that FHA is given timely notice of any default under the Mortgage. The Trustee also covenants and agrees that it shall at all times perform all acts required herein in a timely manner to protect the Bondholders. If requested, the Trustee shall annually provide the Owner a statement of account indicating all interest and principal payments credited to the owner on the Note. The Trustee shall not release any funds or letter of credit held by it as FHA mortgagee without written approval from HUD. 62 The Trustee and any successor trustees appointed hereunder represent and warrant that they are FHA approved mortgagees and will continue to maintain that status at all times, and that they are experienced in administering trusts similar to those of the Trust Estate. Section 7.15. Co- Trustee or Separate Trustee. It is the pur- pose of this Indenture that there shall be no violation of any law of any jurisdiction (including particularly the laws of the State) denying or restricting the right of barking corporations or associ- ations to transact business as Trustee in such jurisdiction. It is recognized that in case of litigation under this Indenture or the Loan Work -Out Agreement, and in particular in case of the enforcement thereof on Default, or in case the Trustee deems that by reason of any present or future law of any jurisdiction it may not exercise any of the powers, rights or remedies herein or therein granted to the Trustee or hold title to the properties, in trust, as herein granted, or take any other action which may be desirable or necessary in connection therewith, the Issuer and the Trustee shall have power to appoint an institution or individual as a co- trustee or separate trustee, and upon the request of the Trustee or of the Holders of at least ten percent (100) of the aggregate principal amount of the Bonds at the time Outstanding the Issuer shall for such purpose join with the Trustee in the execution, delivery and performance of all instruments and agreements necessary or proper to appoint such institution or individual to act as co- trustee jointly with the Trustee or as a separate trustee of all or any part of the Trust Estate, and to vest in such person or institution, in such capacity, such title to the Trust Estate, or any part thereof, and such rights, powers, duties, trusts or obligations as the Issuer and the Trustee may consider necessary or desirable, subject to the remaining provisions of this Section. If the Issuer shall not have made such appointment within thirty (30) days after the receipt by it of a request so to do, or in case an event of default shall have occurred and be continuing, the Trustee alone shall have the power to make such appointment. The Trustee, the Issuer and the owner shall execute, acknow- ledge and deliver all such instruments as may be required by any such co- trustee or separate trustee for more fully confirming such title, rights, powers, trusts, duties and obligations to such co- trustee or separate trustee. Every co- trustee or separate trustee shall, to the extent per- mitted by law, but to such extent only, be appointed subject to the following terms, namely: (a) The Bonds shall be authenticated and delivered, and all rights, powers, trusts, duties and obligations by this Indenture conferred upon the Trustee in respect of the 63 custody, control or management of money, papers, securities and other personal property shall be exercised solely by the Trustee; (b) all rights, powers, trusts, duties and obligations conferred or imposed upon the Trustee shall be conferred or imposed upon or exercised or performed by the Trustee, or by the Trustee and such co- trustee, or separate trustee jointly, as shall be provided in the instrument appointing such co- trustee or separate trustee, except to the extent that under the law of any jurisdiction in which any particular act or acts are to be performed the Trustee shall be incompetent or unqualified to perform such act or acts, in which event such act or acts shall be performed by such co- trustee or separate trustee; (c) any request in writing by the Trustee to any co- trustee or separate trustee to take or to refrain from taking any action hereunder shall be sufficient warrant for the taking or the refraining from taking of such action by such co- trustee or separate trustee; (d) any co- trustee or separate trustee to the extent permitted by law shall delegate to the Trustee the exercise of any right, power, trust, duty or obligation, discretionary or otherwise; (e) the Trustee at any time by an instrument in writing with the concurrence of the Issuer evidenced by a certified resolution may accept the resignation of or remove any co- trustee or separate trustee appointed under this Section and in case an event of default shall have occurred and be continuing, the Trustee shall have power to accept the resig- nation of or remove any such co- trustee or separate trustee without the concurrence of the Issuer, and upon the request of the Trustee, the Issuer shall join with the Trustee in the execution, delivery and performance of all instruments and agreements necessary or proper to effectuate such resignation or removal. A successor to any co- trustee or separate trustee so resigned or removed may be appointed in the manner provided in this Section; (f) no trustee hereunder shall be personally liable by reason of any act or omission of any other trustee hereunder; (g) any demand, request, direction, appointment, removal, notice, consent, waiver or other action in writing executed by the Bond Holders and delivered to the Trustee shall be deemed to have been delivered to each such co- trustee or separate trustee; and 64 (h) any money, papers, securities or other items of per- sonal property received by any such co- trustee or separate trustee hereunder shall forthwith, so far as may be permitted by law, be turned over to the Trustee. Upon the acceptance in writing of such appointment, any such co- trustee or separate trustee shall be vested with such title to the Trust Estate or any part thereof, and with such rights, powers, duties, trusts or obligations as shall be specified in the instru- ment of appointment jointly with the Trustee (except insofar as local law makes it necessary for any such co- trustee or separate trustee to act alone) subject to all the terms of this Indenture. Every such acceptance shall be filed with the Trustee and the Issuer. In case any co- trustee or separate trustee shall die, become incapable of acting, resign or be removed, the title to the Trust Estate and all rights, powers, trusts, duties and obligations of said co- trustee or separate trustee shall, so far as permitted by law, vest in and be exercised by the Trustee unless and until a successor co- trustee or separate trustee shall be appointed in the manner herein provided. The total compensation of the Trustee and co- trustee or separ- ate trustee shall be as provided in (and may not exceed the amount provided in) Sections 7.06 and 4.06(a) hereof. Section 7.16. Additional Security. It is hereby expressly provided that the Trustee shall have a set -off against any -oney in its custody from any funds created by this instrument, except money in the Rebate Fund to pay interest on or principal of any Bonds secured hereby, if for any reason, the Pledged Revenues and other income pledged hereunder are insufficient at any time to service the Bonds. Section 7.17. Representations by Trustee. The Trustee hereby represents and warrants that as of the date of execution of this Indenture: (a) It is duly organized and validly existing in good standing under the laws of the jurisdiction of its organiza- tion and has the power and authority to enter into and perform its obligations under this Indenture; (b) it was an FHA approved mortgagee at the time of ini- tial endorsement of the Mortgage for FHA mortgage insurance and is currently an FHA approved mortgagee; and (c) this Indenture has been duly authorized, executed and delivered by it. 65 a Section 7.18. Appointment Resignation or Removal of Pavina Anent Successors. The Trustee is hereby designated and, by executing this Indenture, agrees to act as paying agent for and in respect to the Bonds. The Issuer from time to time may appoint one or more addi- tional Paying Agents and, in the event of the resignation or removal of any Paying Agent, successor Paying Agents by an instru- ment signed by an officer of the Issuer and delivered to such Paying Agent and the Trustee. Any such additional Paying Agent or successor Paying Agent shall be a national banking association, trust company or bank which is authorized by law to perform all the duties imposed upon a Paying Agent by this Indenture and has a com- bined capital and surplus of at least $25,000,000. Any such addi- tional Paying Agent or successor Paying Agent shall signify its acceptance of the duties and obligations imposed upon it by this Indenture by executing and delivering to the Issuer and the Trustee a written acceptance thereof. The Paying Agents shall enjoy the same protective provisions in the performance of their duties hereunder as are specified in Section 7.01 hereof with respect to the Trustee, insofar as such provisions may be applicable. Any bank or trust company with or into which any Paying Agent other than the Trustee may be merged or consolidated, or to which the assets and business of such Paying Agent may be sold, shall be deemed the successor of such paying Agent for the purposes of this Indenture. The principal office of each Paying Agent is hereby designated as the respective office or agency of the Issuer for the payment of the principal of, premium, if any, and the interest on the Bonds. Any additional Paying Agent shall hold all money received by it for the payment of the principal of, premium, if any, and interest on the Bonds in trust for the Holders of such Bonds. Any additional Paying Agent, and its directors, officers, employees or agents, may in good faith buy, sell, own, hold and deal in any of the Bonds, and may join in any action which any Bondholder may be entitled to take with like effect as if such association, bank or trust company were not such Paying Agent. A Paying Agent may at any time resign and be discharged of the duties and obligations created by this Indenture by giving at least thirty (30) days written notice to the Issuer and the Trustee. A Paying Agent may be removed at any time on at least thirty (30) days prior written notice by an instrument signed by the Issuer and delivered to such Paying Agent and the Trustee. In the event of the resignation or removal of a Paying Agent such Paying Agent shall pay over, assign and deliver any money held 66 by it as paying Agent to its successor, or if there be no succes- sor, to the Trustee. Section 7.19. Rep_ orts• The Trustee shall provide to the Rating Agency notice of a default on the Note that necessitates a filing of a . claim r FHA serving ns trustee hereunder notice and such ninformae in the institution uest from time to time to maintain the tion as it may reasonably req rating on the Bonds. The Trustee shall provide the Rating Agency with: 1. all information the Rating Agency reasonably requests, 2. notification of a partial Mortgage payment, 3. notification of the use of any FHA project reserves to make a principal or interest payment on the Bonds. at all Section 7.20. Audit and Records. The Trustee will er books times maintain an accurate system of accounts and keep p p of records and account relating to this Indenture. The audit shall by the f the deposits include a schedule oro a e isionsof this Indenture. Funds signed Trustee pursuant to the p copy of the audit with financial statements shall be lenivereear. the Trustee within 120 the days after the shalld furnish copies calendar ysuch Upon written request, audit to any Registered Holder, r ting agenciespresentative of such Holder, and to the applicable Section 7.21. Special Procedures for Bonds Re istered to DTC. t of DTC or its In the case of any Bonds register o the m e maximum extent possible nominee, the Trustee shall comply, a Letter of Representation uto, be with executed gbyrandn among DTC, the a Lett Trustee and the Issuer. 67 � ARTICLE VIII SUPPLEMENTAL INDENTURES AND AMENDMENTS OF CERTAIN DOCUMENTS Section 8.01. Supplemental Indentures Not Requiring Consent of Bondholders, The Issuer and the Trustee may without the consent of, or notice to, any of the Bond Holders enter into an indenture or indentures supplemental to this Indenture as shall not be incon- sistent with the terms and provisions hereof or materially adverse to the Holders of the Bonds for any one or more of the following purposes: (a) to cure any ambiguity or formal defect or omission herein; (b) to change or modify any provision hereof so as to harmonize to the maximum extent practicable the provisions hereof with existing rules, regulations and procedures of FHA; (c) to grant to or confer upon the Trustee for the bene- fit of the Bond Holders any additional rights, remedies, powers or authority that may lawfully be granted to or con- ferred upon the Bond Holders or the Trustee or either of them; (d) to subject to the lien and pledge of this Indenture additional revenues, properties or collateral; (e) to modify, amend or supplement this Indenture or any indenture supplemental hereto or the Loan Work -Out Agreement, the Note or the Mortgage in such manner as to permit the qual- ification hereof and thereof under the Trust Indenture Act of 1939 or any similar Federal statute hereafter in effect or under any state Blue Sky Law; (f) in connection with any other change in this Indenture which, in the judgment of the Trustee, is not to the prejudice of the Trustee or the Bondholders; or (g) to modify or amend the Indenture as necessary to secure a rating on the Bonds acceptable to the Issuer, except no change may be made to the maturity, interest rate or amount of the Bonds. Section 8.02. Supplemental Indentures Requiring Consent of Bondholders. The Holders of not less than two - thirds of the Bond Obligation then Outstanding shall have the right, from time to time, anything contained in this Indenture to the contrary notwith- standing, to consent to and approve the execution by the Issuer and the l shallr be e deemed uCnecessary indenture and desirable sby supplemental hereto as the Issuer for the 68 purpose of modifying, altering, amending, adding to or rescinding, in any particular, any of the terms or provisions contained in this Indenture; provided, however, that nothing in this Section con- tained shall permit, or be construed as permitting without the consent of the Holders of all of the Bonds then Outstanding, (a) an extension of the stated maturity or reduction in the principal amount or reduction in the rate of interest on or extension of the time of payment, of interest on, or reduction of any premium payable on the redemption of, any Bonds, or a reduction in the Owner's obligation on the Note, or (b) the creation of any lien prior to or on a parity with the lien of this Indenture, or (c) a reduction in the aforesaid aggregate principal amount of Bonds the Holders of which are required to consent to any such supplemental indenture, or (d) the modification of the rights, duties or immuni- ties of the Trustee, without the written consent of the Trustee, or (e) a privilege or priority of any Bond over any other Bonds or (f) any action that results in the interest on the Bonds becoming included in gross income for federal income tax purposes. If at any time the issuer shall request the Trustee to enter into any such supplemental indenture for any of the purposes of this Section, the Trustee shall, upon being satisfactorily indemni- fied with respect to expenses, cause notice of the proposed execu- tion of such supplemental Indenture to be published or mailed, postage prepaid, to all registered Bond holders. Such notice shall briefly set forth the nature of the proposed supplemental indenture and shall state that copies thereof are on file at the corporate trust office of the Trustee for inspection by all Bondholders. If, within 60 days or such longer period as shall be prescribed by the Issuer following the mailing of such notice, the Holders of not less than two- thirds in or in the case of certain amendments, all of the aggregate principal plus accrued but unpaid interest on the Bonds Outstanding at the time of the execution of any such supplemental indenture shall have consented to and approved the execution thereof as herein provided, no Holder of any Bond shall a have any right to object to any of the terms and provisions contained therein, or the operation thereof, or in any manner to question the propriety of the execution thereof, or to enjoin or restrain the Trustee or the Issuer from executing the same or from taking any action pursuant to the provisions thereof. Upon the execution of any such supplemental indenture as in this Section permitted and provided, this Indenture shall, be and be deemed to be modified and amended in accordance therewith. The Trustee may rely upon an opinion of counsel as conclusive evidence that execution and delivery of a supplemental indenture has been effected in compliance with the provisions of this Article. Anything herein to the contrary notwithstanding, a supplemen- tal indenture under this Article which affects any rights of the Owner shall not become effective unless and until the Owner shall have expressly consented in writing to the execution and delivery of such supplemental indenture. In this regard, the Trustee shall 69 cause notice of the proposed execution and delivery of any such supplemental indenture to be mailed by certified or registered mail to the Owner or the Owner's attorney at least 15 days prior to the proposed date of execution and delivery of any supplemental indenture. Section 8.03. Amendment by Unanimous Consent. Notwith- standing any other provision of this Indenture, the Issuer and the Trustee may consent to any supplemental indenture or to any amend- ment, change or modification of the Loan Work -Out Agreement, the Note, or the Mortgage upon receipt of the consent of the holders of all Bonds then Outstanding or as permitted in Section 8.04. Except for redemption of the mortgage amount at final endorsement, 100% bondholder approval is required to reduce the mortgage obligations on the Note. Section 8.04. Amendment of Certain Documents. The Issuer and the Trustee may, with the approval of FHA, make or consent to any amendment, change or modification of the Note, the Mortgage, and the Loan Work -Out Agreement, except to extend the Initial Payment or maturity date thereof, for the purpose of curing any ambiguity, or of curing, correcting or supplementing any defective or incon- sistent provision ccntained therein, or in regard to matters or questions arising under said documents, as the Issuer and the Trustee may deem necessary or desirable and not inconsistent with said documents or this Indenture and which shall not adversely affect the interests of the Holders of the Bonds. The Trustee agrees to cooperate with the Owner in obtaining FHA's consent to a transfer of physical assets and to execute any documents required by FHA to effect any such transfer. The Issuer and the Trustee also agree to consent to encumbrance(s) of all or any portion(s) of the Project by mortgage, security agreement or otherwise, where such encumbrance is junior to the lien of the Mortgage, subject only to the consent of FHA to any such encum- brance. In addition, the Trustee shall cooperate with the owner in its attempts to increase the principal amount of the Note, and the granting of any easements, partial release of the Mortgage, the transfer of any other property rights or the making of any cove- nants or dedications which FHA approves. With the approval of FHA and the Rating Agency, the Owner may request and the Trustee shall consent to an amendment to the Note and Mortgage to reduce the debt service payable thereunder to an amount sufficient to pay the scheduled debt service on the Bonds only in the event that the Project fails to produce sufficient revenues to make the regular debt service payment on the Note. This amendment shall be made only upon the Owner demonstrating to the satisfaction of FHA, the Rating Agency and. the Trustee that the Project will generate sufficient revenues to support the scheduled debt service on the Bonds. 70 W on Except as provided herein, neither the Issuer nor the Trustee amendment, change or modification of the Note shall consent to any or the Mortgage without the written adverse effect on the Bo of not less n than one hundred nds), approval or consent of the Holders igation outstanding- percent ercent in aggregate amount of the Bond obl 71 ARTICLE IX SATISFACTION AND DISCHARGE OF INDENTURE Section 9.01. Discharge of Lien. If the Issuer shall pay or cause to be paid to the Holders of the Bonds the principal, interest and premium, if any, to become due thereon at the times and in the manner stipulated therein and herein, and shall have paid or caused to be paid all fees and expenses of the Trustee, the Mortgage Servicer and each paying agent, and if the Issuer shall keep, perform and observe all and singular the covenants and promises in the Bonds and in this Indenture expressed as to be kept, performed and observed by it or on its part, then these pre- sents and the estates and rights hereby granted shall cease, deter- mine and be void, and thereupon the Trustee shall cancel and dis- charge the Note, the Mortgage and the lien of this Indenture and execute and deliver to the Issuer such instruments in writing as shall be requisite to satisfy the lien thereof, and reconvey to the Issuer the estate hereby conveyed, and assign and deliver to the Issuer any interest in property at the time subject to the lien of this Indenture which may then be in its possession, except amounts held by the Trustee for the payment of principal of, interest and premium, if any, on the Bonds. All Outstanding Bonds of any series shall prior to the maturity or redemption date thereof be deemed to have been paid within the meaning and with the effect expressed in the first para- graph of this section if, under circumstances which do not render interest on the Bonds subject to federal income taxation, the following conditions shall have been fulfilled: (a) in ca.:•a any of the Bonds are to be redeemed on any date prior to their maturity, the Issuer shall have given to the Bondholders and the Trustee in form satisfactory to it irrevocable notice of redemption of the Bonds on said date; and (b) there shall be on deposit with the Trustee either money or direct obligations of the United States of America in an amount, together with anticipated earnings thereon as provided in the related investment agreement which will be suffi- cient to pay, when due, the principal or redemption price, if applicable, and interest due and to become due on the Bonds on the redemption date or maturity date thereof, as the case may be. 72 .A, ARTICLE X MISCELLANEOUS Section 10.01. Consents and Other Instruments of Bondholders. Any consent, request, direction, approval, waiver, objection, appointment or other instrument required by this Indenture to be signed and executed by the Bond Holders may be signed and executed in any number of concurrent writings of similar tenor and may be signed or executed by such Bond Holders in person or by agent appointed in writing. Proof of the execution of any such instru- ment, if made in the following manner, shall be sufficient for any of the purposes of this Indenture, and shall be conclusive in favor of the Trustee with regard to any action taken under such instru- ment, namely: (a) The fact and date of the execution by any person of any such instrument may be proved by the affidavit of a wit- ness of such execution or by the certificate of any notary public or other officer of any jurisdiction, authorized by the laws thereof to take acknowledgments of deeds, certifying that the person signing such instrument acknowledged to him the execution thereof. Where such execution is by an officer of a corporation or association or a member of a partnership on behalf of such corporation, association or partnership such affidavit or certificate shall also constitute sufficient proof of his authority; (b) the ownership of registered Bonds shall be proved by the bond register; (c) any request, consent or vote of the Holder of any Bond shall bind every future holder of the same Bond and the holder of every Bond issued in exchange thereof or in lieu thereof, in respect of anything done or permitted to be done by the Trustee or the Issuer in pursuance of such request, consent or vote; and (d) in determining whether the Holders of the requisite aggregate principal plus accrued but unpaid interest on the Bonds have concurred in any demand, request, direction, con- sent or waiver under this Indenture, Bonds which are owned by the Issuer or the Owner or by any person directly or indi- rectly controlling or controlled by or under direct or indirect common control with the Issuer or the Owner shall be disregarded and deemed not to be Outstanding for the purpose of determining whether the Trustee shall be protected in relying on any such demand, request, direction, consent or waiver. Only Bonds which the Trustee knows to be so owned shall be disregarded. Bonds so owned which have been pledged in good faith may be regarded as Outstanding for the purposes 73 of this Section if the pledgee shall establish to the satis- faction of the Trustee the pledgee's right to vote such Bonds. In case of a dispute as to such right, any decision by the Trustee taken upon the advice of counsel shall be full protec- tion to the Trustee. Section 10.02. Limitation of Rights. With the exception of rights herein expressly conferred, nothing expressed or to be implied from this Indenture or the Bonds is intended or shall be construed to give to any person other than the Parties hereto, the Owner and the Holders of the Bonds, any legal or equitable right, remedy or claim under or in respect to this Indenture or any covenants, conditions and provisions hereof. Section 10.03. Construction of Conflicts, . Not- withstanding anything provided herein, or in any of the documents referred to herein, in the event that any contracts or other docu- ments executed by the Owner or any other arrangements agreed to by the Owner in order to finance the Mortgage with bonds the interest on which is excluded from gross income for federal income tax pur- poses under Section 103 of the 1954 Code and Section 103(a) of the Code are inconsistent with the Loan Documents then the Loan Docu- ments shall be controlling in all respects. If any provision of this Indenture shall be held or deemed to be, or shall in fact be inoperative or unenforceable as applied in any particular case in any jurisdiction or jurisdictions or in all jurisdictions, or in all cases because it conflicts with any other provision or provi- sions hereof or any constitution, statute, rule of law or public policy, or for any other reason, such circumstances shall not have the effect of rendering the provision in question inoperative or unenforceable in any other case or circumstance, or of rendering any other provision or provisions herein contained invalid, inoperative, or unenforceable to any extent whatever. The invalidity of any one or more phrases, sentences, clauses or sections in this Indenture contained, shall not affect the remaining portions of this Indenture, or any part thereof. Section 10.04. Notices. All notices, certificates or other communications hereunder shall be sufficiently given and shall be deemed given when mailed by certified or registered mail, postage prepaid, or dispatched by telegram, addressed, unless notice of a different address is given, as provided in the Loan Work -Out Agreement. Section 10.05. Trustee as_Pavina Agent and Bond Registrar. The Trustee is hereby designated and agrees to act as paying agent and Registrar for and in respect to the Bonds. Section 10.06. Payments Due on Saturdays, Sundays and Holi- days. In any case where the date of maturity of interest on or principal of the Bonds, or the date fixed for redemption of any 14 Bonds, shall be a Saturday, Sunday, legal holiday or a day on which the Trustee is authorized by law to close and is closed, then pay- ment of interest or principal need not be made on such date but may be made on the next succeeding business day with the same force and effect as if made on the date of maturity or the date fixed for redemption, and no interest shall accrue for the period after such date providing that payment is made on such next succeeding business day. Section 10.07. Counterparts. This Indenture may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. Section 10.08. Laws Governing Indenture and Situs and Admini- stration of Trust. The effect and meanings of this Indenture and the rights of all parties hereunder shall be governed by, and con- strued according to, the laws of the State. Section 10.09. No Recourse. No recourse under or upon any obligation, covenant or agreement contained in the Indenture or in any Bond, or under any judgment obtained against the Issuer, or the enforcement of any assessment, or any legal or equitable pro- ceedings by virtue of any constitution or statute or otherwise, or under any circumstances under or independent of the Indenture, shall be had against any member, commissioner, officer or employee, as such, past, present or future of the Issuer, either directly or through the Issuer or otherwise, for the payment for or to the Issuer or any receiver thereof, or for or of the Holder of any Bond issued thereunder, or otherwise, of any sum that may be due and unpaid by the Issuer upon any such Bond. Any and all personal liability of every nature whether at common law or in equity or by statute or by constitution or otherwise of any such member, com- missioner, officer or employee, as such, to respond by reason of any act of omission on his /her part or otherwise, for the payment for or to the Holder of any Bond issued thereunder or otherwise of any sum that may remain due and unpaid upon the Bond thereby secured or any of them is, by the acceptance hereof, expressly waived and released as a condition of and in consideration for the execution of the Indenture and the issuance of the Bonds. Section 10.10. Role of Issuer. The Issuer shall not be required to take any action or perform any specific act unless spe- cifically requested to do so by the Trustee or other appropriate party. In addition, the Issuer shall have no obligation to review, control, or oversee the activities of the Trustee in (a) collecting any amounts payable pursuant to the Mortgage or (b) making any pay- ments on the Bond. Furthermore, the Issuer shall not be obligated to take any action which might in its reasonable judgment involve it in any expense or liability unless it shall have been furnished with assurance of payment or reimbursement for any expense and with reasonable indemnity for liability of the issuer, its officers and employees. 75 Section 10.11. Successors and Ass icrns . All the covenants and representations contained in this Indenture, by or on behalf of the Issuer, shall bind and inure to the benefit of its successors and assigns, whether so expressed or not. Section 10.12. HUD and 'FHA Reguirements to control. Notwith- standing anything in this Indenture to the contrary, the provisions of this Indenture and the Loan Work -Out Agreement are subject and subordinate to the National Housing Act, all applicable HUD coin- surance (and Section 8, if applicable) regulations and related administrative requirements and the Mortgage Loan Documents, and all applicable FHA regulations and related administrative require- ments in effect as of the date hereof; and in the event of any con- flict between the provisions of this Indenture or the Loan Work -out Agreement and the provisions of the National Housing Act, any applicable HUD regulations, related administrative requirements and the Mortgage Loan Documents, and any applicable FHA regulations and related administrative requirements, the said National Housing Act, HUD regulations, related administrative requirements and Mortgage Loan Documents, and the said FHA regulations and related admini- strative requirements in effect as of the date hereof shall be controlling in all respects. IN WITNESS WHEREOF', the Issuer and the Trustee have executed the Indenture as of the day and year first hereinabove written. ATTEST: Clerk CITY OF CLEARWATER, FLORIDA By: Mayor- Commissioner BANK ONE, COLUMBUS, NA, Columbus, Ohio, as Trustee By: Authorized Officer 76 EXHIBIT A LEGAL DESCRIPTION EXHIBIT B SCHEDULE OF MINIMUM CARRY- FORWARD BALANCES IN BOND FUND EXHIBIT "B" CLEARWATER, FLORIDA BOND FUND SUMMARY STATEMENT PERIOD BEGINNING ENDING ENDING BALANCE DEPOSITS WITHDRAWALS BALANCE 8 -18 -1992 0.00 34512.85 0.00 34512.85 4- 1 -1993 34512.85 141008.25 - 165547.92 9973.18 10- 1 -1993 9973.18 129120.89 - 129446.88 9647.20 4- 1 -1994 9647.20 129123.95 - 127450.00 11321.14 10- 1 -1994 11321.14 129163.58 - 128453.13 12031.59 4- 1 -1995 12031.59 129186.06 - 131453.13 9764.53 10- 1 -1995 9764.53 129154.92 - 127293.75 11625.70 4- 1 -1996 11625.70 129198.95 - 130293.75 10530.90 10- 1 -1996 10530.90 129189.76 - 131131.25 8589.41 4- 1 -1997 8589.41 129165.60 - 128968.75 8786.26 10- 1 -1997 8786.26 129180.58 - 132556.25 5410.59 4- 1 -1998 5410.59 129131.21 - 127643.75 6898.05 10- 1 -1998 6898.05 129170.40 - 128481.25 7587.19 4- 1 -1999 7587.19 129195.54 - 126318.75 10463.99 10- 1 -1999 10463.99 129260.78 - 132153.13 7571.65 4-- 1 -2000 7571.65 129221.92 - 129825.00 6968.56 10- 1 -2000 6968.56 129225.02 - 130496.88 5696.70 4- 1 -2001 5696.70 129216.49 - 128168.75 6744.44 10- 1 -2001 6744.44 129250.51 - 128840.63 7154.32 4- 1 -2002 7154.32 129273.49 - 126512.50 9915.31 10- 1 -2002 9915.31 129339.64 - 129684.38 9570.58 4- 1 -2003 9570.58 129350.05 - 129853.13 9067.50 10- 1 -2003 9067.50 129358.18 - 130359.38 8066.31 4- 1 -2004 8066.31 129357.89 - 127865.63 9558.57 i 10- 1 -2004 9558.57 129403.41 - 128371.88 10590.11 4- 1 -2005 10590.11 129441.23 - 125878.13 14153.21 10- 1 -2005 14153.21 129525.60 - 131381.25 12297.56 4- 1 -2006 12297.56 129512.45 - 128721.88 13088.14 10- 1 -2006 13088.14 129547.98 °129062.50 13573.63 4- 1 -2007 13573.63 129578.73 - 126403.13 16749.23 10- 1 -2007 16749.23 129659.00 - 134240.63 12167.60 4- 1 -2008 12167.60 129599.46 - 128915.63 12851.44 10- 1 -2008 12851.44 129636.19 - 129090.63 13397.00 4- 1 -2009 13397.00 129671.26 - 126265.63 16802.63 3.0 -1 -2009 16802.63 129759.04 - 131437.50 15124.17 4- 1 -2010 15124.17 129755.60 - 128446.88 16432.90 10- 1 -2010 16432.90 129807.24 - 3.28456.25 17783.88 4- 1 -2011 17783.88 129860.62 - 130462.50 17182.00 10- 1 -2011 17182.00 129879.62 - 130306.25 16755.37 4- 1 -2012 16755.37 129902.84 - 127150.00 19508.21 10- 1 -2012 19508.21 129984.77 - 129493.75 19999.23 4- 1- 2013 19999.23 130026.83 - 128834.38 21191.68 10- 1 -2013 21191.68 130082.76 -128512.50 22761.94 4- 1 -2014 22761.94 130146.74 - 130187.50 22721.18 10- 1 -2014 22721.18 130182.77 - 129700.00 23203.95 i PERIOD BEGINNING ENDING ENDING BALANCE DEPOSITS WITHDRAWALS BALANCE 4- 1 -2015 23203.95 130229.57 - 126212.50 27221.02 10- 1 -2015 27221.02 130341.76 - 130721.88 26840.90 4- 1 -2016 26840.90 130375.63 - 127068.75 30147.78 10- 1 -2016 30147.78 130477.75 - 126415.63 34209.91 4- 1 -2017 34209.91 130595.04 - 127759.38 37045.57 10- 1 -2017 37045.57 130691.63 - 134437.50 33299.70 4- 1 -2018 33299.70 130670.51 - 127953.13 36017.09 10- 1 -2018 36017.09 130768.17 - 126968.75 39816.51 4- 1 -2019 39816.51 130887.14 - 122984.38 47719.28 10- 1 -2019 47719.28 131082.24 - 131993.75 46807.76 4- 1 -2020 46807.76 131119.39 - 127678.13 50249.03 10- 1 -2020 50249.03 131237.31 - 126362.50 55123.84 4- 1 -2021 55123.84 131383.17 - 127043.75 59463.26 10- 1 -2021 59463.26 131521.33 - 130559.38 60425.21 4- 1 -2022 60425.21 131600.35 - 125912.50 66113.07 10- 1 -2022 66113.07 .131767.19 - 131762.50 66117.76 4- 1 -2023 66117.76 131833.26 - 124450.00 73501.02 10- 1 -2023 73501.02 132035.37 - 127634.38 77902.01 4- 1 -2024 77902.01 132185.81 - 127653.13 82434.69 10- 1 -2024 82434.69 132341.12 - 130506.25 84269.56 4- 1 -2025 84269.56 132450.08 - 125196.88 91522.77 10- 1 -2025 91522.77 201533.85 - 205337.50 87719.12 4- 1 -2026 8771.9.12 264.98 - 87984.10 0.00 Total 0.00 8700713.27 - 8700713.27 0.00 EXHIBIT C HUD LETTER OF JUNE 23, 1987 M � %..m F3 EXHIBT,T "B" LOAN WORK -OUT AGREEMENT among CITY OF CLEARWATER, FLORIDA BANK ONE, COLUMBUS, NA, Columbus, Ohio, As Trustee and DREW GARDENS ASSOCIATES, LTD. A Florida Limited partnership $3,425,000 Principal Amount of Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan -- Drew Gardens Project) Dated as of August 1, 1992 I ,x -, V TABLE OF CONTENTS (This Table no) a part of the Agreement but is only for convenience of referen Paae 1 Preambles • • • ' ' . ' . . . . . . . ARTICLE I DEFINITIONS 4 Section 1.1 General . • • • ' • . . . . . . • . . . . 4 Section 1.2 Definitions . • • . . . . . . . . • . . 6 Section 1.3 Construction . ARTICLE II THE MORTGAGE LOAN MODIFICATION, LOAN PAYMENTS AND ADDITIONAL PAYMENTS Section 2.1 Amount and Terms of the Mortgage Loan 7 Modification; the Note . . . . . 7 Section 2.2 Additional Payments . . . . . . . . . 7 Section 2.3 Redemption of Bonds ARTICLE III ISSUANCE OF BONDS; APPLICATION OF PROCEEDS Section 3.1 Issuance of Bonds; Deposit and Disbursement 9 of Bond Proceeds . • 9 Section 3.2 Investment of Fund Money i ARTICLE IV INSURANCE; DAMAGE; DESTRUCTION AND EMINENT DOMAIN _. MAINTENANCE; . 10 Section 4.1 Maintenance . • • • • ' ' • . . . . • Removal of Portions of the Project 10 10 Section 4.2 10 Section Section 4.3 4.4 Insurance e , ensation coverage • • • ' ' . Worker's Comp Eminent Domain 10 Section 4.^ Damage; Destruction and i ARTICLE VII TERMINATION, PREPAYMENT AND AMENDMENT OF NOTE Section 7.1 Option to Terminate . . . . . . . . . . . 20 Section 7.2 Option to Prepay Loan . . . . ... . . . 20 Section 7.3 Amendment of Note . . . . . . . . . . . . 20 ARTICLE VIII EVENTS OF DEFAULT AND REMEDIES Section 8.1 ARTICLE V . 21 21 Section 8.2 WARRANTIES, REPRESENTATIONS AND SPECIAL COVENANTS Section Section 5.1 Representations and Warranties of Issuer 11 Section 5.2 Representations of the Owner . . . . . . . 12 Section 5.3 Owner's Approval of Indenture . • • • • . Section 5.4 Indemnification . • • . . • • • • • • 16 Section 5.5 Owner Not to Adversely Affect Tax Exempt Status of Interest on Bonds . . . . . . 17 Section 5.6 Notice of Certain Events . . . . . . . . 17 Section 5.7 Taxes, Other Governmental Charges and Utility Charges . . . . . . . . . . . . . 18 ARTICLE VI ASSIGNMENT Section 6.1 Assignment by Owner . . . . . . . . . . . 19 Section 6.2 Issuer Pledge of Certain Rights Under Loan Work -Out Program . . . . . • • • • 19 Section 6.3 Assignment by the Issuer . . . . . . . . . 19 ARTICLE VII TERMINATION, PREPAYMENT AND AMENDMENT OF NOTE Section 7.1 Option to Terminate . . . . . . . . . . . 20 Section 7.2 Option to Prepay Loan . . . . ... . . . 20 Section 7.3 Amendment of Note . . . . . . . . . . . . 20 ARTICLE VIII EVENTS OF DEFAULT AND REMEDIES Section 8.1 Events of Default . . . . . . . . . . . . 21 21 Section 8.2 Remedies on Default . . . . . . . . . . . 22 Section 8.3 No Remedy Exclusive . . . . . . . . . . . Section 8.4 Agreement to pay Attorneys' 22 Fees and Expenses . . . . . . . . . . . Section 8.5 No Additional Waiver Implied by One Waiver . . . . . . . . . . . . . . . . . . 23 ii ARTICLE IX MISCELLANEOUS Section 9.1 Term of Agreement • • • • • • • ' ' . . _ 24 24 Section 9.2 Notices . . . . . . . . . . . ' . • 24 Section 9.3 9.4 Binding Effect . . . . . . . . . • ' ' . . Amendments, Changes and Modifications 24 Section Section 9.5 Executive Counterparts . . . 24 24 Section 9.6 Severability . • • • • • • • 25 Section 9.7 Captions . . • • • • • • • • ' • ' 25 Section Section 9.6 9.9 Governing Law . • • • • • • . ' ' . • , HUD and FHA Requirements to Control . 25 Section 9.10 Limited Liability of Owner; No Recourse 26 Against Project Assets . . . . . . . . . . 27 Section 9.11 No Liability of Issuer Officers . • . • 27 SIGNATURES • • • • • • • • ' ' ' . • • EXHIBIT A - Form of Modification of Mortgage Note and Mortgage iii LOAN WORK -OUT AGREEMENT , Among CITY OF CLEARWATER, FLORIDA, BANK ONE, COLUMBUS, NA, and DREW GARDENS ASSOCIATES, LTD. THIS LOAN WORK -OUT AGREEMENT (this "Loan Work -Out Agreement ") made and entered into as of the first day of August, 1992, among the CITY OF CLEARWATER, FLORIDA (the "Issuer ") , a municipal corpor- ation, organized and existing under the laws of the State of Florida, BANK ONE, COLUMBUS, NA, Columbus, Ohio, as Trustee under the Indenture referred to herein (the "Trustee ") and DREW GARDENS ASSOCIATES, LTD. (the "Owner "), a Florida limited partnership, W I T N E S S E T H• WHEREAS, the Issuer is authorized under the laws of the State of Florida, particularly Chapter 166, Part II, and Chapter 159, Part Iv, Florida Statutes, and other applicable provisions of law (the "Act ") , to provide funds for the acquisition, construction, rehabilitation, remodeling and improvement of privately owned facilities including a rental housing facility and to issue its bonds, and refund bonds issued for such purposes, for the purposes set forth in the Act; and WHEREAS, the Issuer is authorized and empowered pursuant to the Act to issue its revenue bonds and take other actions to finance, refinance and provide other incentives for development of certain facilities; and WHEREAS, on October 12, 1983, the Issuer issued $6,450,000 aggregate principal amount of its Mortgage Revenue Bonds, Series 1983 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project) (the "Refunded Bonds "), for the purpose of making a loan (the "Mortgage Loan ") to the Owner, the acquisition, construction and equipping of a multifamily residential rental project located in Clearwater, Florida and identified as FHA Project No. 067 - 35276 -PM (the "Project "); and WHEREAS, pursuant to a Financing Agreement, dated as of September 1, 1983 (the "Prior Agreement "), among the Issuer, the Prior Trustee (as defined below), Sun Bank, National Association, as co- trustee, and the Owner, the Issuer provided funds to Bank One, Columbus NA, Columbus, Ohio, as trustee (the "Prior Trustee ") under the indenture (the "Prior Indenture ") securing the Refunded Bonds (i) to finance the Mortgage Loan insured by the Federal Housing Administration ( "FHA"), an organizational unit within the United States Department of Housing and Urban Development ( "HUD "), in the principal amount of $6,094,900 evidenced by a Mortgage Note by a first (the "Note ") from the Owner to the prior Trus tee proceeds of which mortgage on the Project (the "Mortgage") , were advanced pursuant to a Loan Agreement between the Prior Trustee, as mortgagee of record, and the Owner, and (ii) to fund a Debt Service Reserve Fund under the Prior Indenture; and WHEREAS, the Owner is in default of its obligation to make Trustee payments to the Prior ned the Note a d the Mortgage htoP HUD rpursuant has, therefore, g to the provisions of the Prior Indenture; and WHEREAS, the Owner is entering into this Loan Work -Out Agreement in order to provide for a modification o of the Mortgage Loan because the Owner defaulted in its payment the Mortgage Loan and continued to be in such default from August the Prior 1, 1991, to immediately prior to the date hereof and of mortgage Trustee assigned the Mortgage Loan to FHA for pay insurance benefits because of such default; and WHEREAS, HUD has confirmed that the FHA mortgage insurance benefits are payable to the Prior Trustee as a result Of the default with respect to the Mortgage Loan and has paid mortgage insurance benefits to the Prior Trustee in connection with such Mortgage Loan default; and WHEREAS, under the terms of the Prior Indenture, tphe Refunded Bonds are subject to mandatory redemption ptlus accrued interest o the equal to the principal amount thereof ,,s available in the Bond Fund redemption date, to the extent money thereunder from whatever if u F'HA mortgage earliest insurance proceeds date, are as a whole or in p payable to the Prior Trustee; and WHEREAS, the Owner and HUD have agreed to amend the Note to provide for, among other things, a reduction in the rate of interest an the Note; and WHEREAS, in order to fulfill the public purpose of providing rental housing facilities within its jurisdic- facilities such as tion, the Issuer has determined to issue its Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan $3,425,000 Drew Gardens Project), in the aggregate principal amount of de (the "Bonds ") to provide for the refunding of the Refunded Bonds; and WHEREAS, the proceeds of the Bonds will be sufficient, to redeem the Refunded hBonds pursuant to the provisions e descrpibed� the above; and 2 WHEREAS, the Owner, the Trustee and the Issuer each have full right and authority to enter into this Loan Work -Out Agreement and to perform and observe the provisions hereof on their respective parts to be performed and observed; NOW, THEREFORE, in consideration of the premises and the mutual covenants hereinafter contained, the parties hereto covenant, agree and bind themselves as follows, provided, that any obligation of the Issuer created by or arising out of this Loan Work -Out Agreement shall never constitute a debt or a pledge of the faith and credit of the Issuer but shall be payable solely out of Pledged Revenues as herein defined, anything herein contained to the contrary by implication or otherwise notwithstanding: Alk ARTICLE I DEFINITIONS Section 1.1. General. In addition to the words and terms elsewhere defined in this Loan Work -out Agreement, certain words and terms as used in this Loan Work -Out Agreement shall have the meanings given to them by the definitions and descriptions in this Article unless the context or use indicates another or different meaning or intent and such definitions shall be equally applicable to both the singular and plural forms of any of the words and terms herein defined. Those words and terms not specifically defined herein and used in this Loan Work -Out Agreement and Article, as defined words or terms shall have the meanings set forth in the Indenture, as defined herein. Section 1.2. Definitions. The following words and terms are defined under this Loan Work -Out Agreement: "Act" means Chapter 166, Part II, and Chapter 159, Part IV, Florida Statutes, and other applicable provisions of law. "Bond Purchaser" means Banc One Capital Corporation. "Code" means the Internal Revenue Code of 1986, as amended and contemporaneously in effect. 111954 Code" means the Internal Revenue Code of 1954, as amended and in effect prior to the enactment of the Code. "Indenture" means the Indenture of Trust between the Issuer and the Trustee, of even date herewith, as the same may be duly amended, modified or supplemented in accordance with the provisions i thereof. "Loan" means the Mortgage Loan as defined in the Indenture. "Modification Agreement" means the Modification of Mortgage Note and Mortgage, dated as of August 18, 1992, among the Owner, the Prior Trustee and as approved by HUD. "Mortgage Loan Documents" means the Loan Work -out Agreement, the Note, the Mortgage and the Supplemental Regulatory Agreement. "Mortgage Servicer" means Continental Securities Corporation, Syracuse, New York, or its successor or assigns, which will service the Loan on behalf of the Trustee pursuant to the provisions of the Servicing Agreement. `1 4 "Notice Address" means: (a) As to the Issuer: City of Clearwater City Hall Finance Department, 3rd Floor 112 South Osceola Avenue Clearwater, Florida 34616 Attention: (b) As to the Owner: Drew Gardens Associates, Ltd. c/o Reynolds Metals Development Company General Partner 4501 N.W. 31st Avenue Ft. Lauderdale, Florida 33309 Attention: with a copy to: Drew Gardens Associates, Ltd. 6601 West Broad Street Richmond, Virginia 23260 Attention: Corporate Secretary (c) As to the Trustee: Bank One, Ohio Trust Company, NA 100 East Broad Street Columbus, Ohio 43215 Attention: or such different address notice of which is given under Section 9.2 hereof, but no such notice shall thereby be required to be sent to more than two addresses. "Owner" means Drew Gardens Associates, Ltd., a Florida limited partnership. "Owner Deposit" means the deposit made by the Owner in immediately available funds to the Cost of Issuance Fund. "Partnership Mortgage" means the existing second mortgage on the Project in favor of Presidential Development Corporation, which mortga ,qe is subordinated to the Mortgage and the Second Mortgage. "Prior Indenture" means the Trust Indenture dated as of September 1., 1983, between the Issuer and the Prior Trustee with respect to the Refunded Bonds. "Prior Trustee" means collectively, Bank One, Columbus, NA, Columbus, Ohio, in its capacity as trustee and Sun Bank, National Association, as co- trustee under the Prior Indenture. "Refunded Bonds" means $6,450,000 initial aggregate principal amount of the Issuer's Mortgage Revenue Bonds, Series 1983 (FHA Insured Mortgage Loan - Drew Gardens Apartments Project). 5 "Regulatory Agreement" means that certain Regulatory Agreement dated October 12, 1983 between the Owner and FHA with respect to the Project. "Second Mortgage" means the second lien mortgage encumbering the Project in favor of HUD which arose out of the Loan Work -Out Agreement and the Modification Agreement. "Servicing n Agreemen� +- means the Agreement between the Mortgage Servicer and the Trustee, of even date herewith, pursuant to which the Mortgage Servicer will service the Loan. "Supplemental Regulatory Agreement" means the Supplemental Regulatory Agreement as to Tax Exemption dated as of September 1, 1983 among the Issuer, the Owner and the Prior Trustee. "Termination Date" means October 1, 2025, subject to earlier termination as herein provided. "Trustee" means, collectively, the banks or trust companies at the time serving as Trustee under the Indenture, one of which shall at all times be an FHA approved Mortgagee, initially Bank One, Columbus, NA, Columbus, Ohio. Section 1.3. Construction. Any reference herein to the Issuer shall include any entity which succeeds to its functions, duties or responsibilities pursuant to or by operation of law. Unless the context shall otherwise indicate, words of the masculine gender shall be deemed and construed to include correla- tive words of the feminine and neuter genders, words, importing the singular number shall include the plural number, and vice versa, and the terms "hereof," "hereby," "hereto," "hereunder," and similar terms mean this Loan Work -Out Agreement. All accounting terms not otherwise defined herein shall have the meanings assigned to them in accordance with generally accepted accounting principles. The title to any section in this Loan Work -Out Agreement shall not be controlling with respect to the subject matter contained therein but is for convenience of reference only. Ank ARTICLE II THE MORTGAGE LOAN MODIFICATION, LAN PAYMENTS AND Section 2. 1. Amount and Terms subject the t °o the terms and ifica= tion• the Note. The Issuer agrees, tie mortgage to e Loan throughtther issuance oand cause salethe of the Bonds nand the M g g the the redemption of the Refunded Bonds in accordance deposited wwlt the Indenture. The proceeds of the Bonds shall be Trustee and used as provided in Section 4.02 of the Indenture to pay accrued interest to the Bond Fund plus additional moneys required to be deposited to such Fund to provide for payment lags, to fund the Program Fund and to fund a portion of the Costs of Issuance Funds and conditions ionstof Section 4. shall, 02 of the Indenture, be with the term remitted eand Prior the Trelease of the li n of the Prior Indenture. Ref unded Bonds ts transferred by the Prior Trustee to the Trustee shall The amoun including the be used to fund the Debt Service Reserve Fund Mortgage Reserve Account therein) . The Owner Deposit shall be used to pay a portion of the costs of issuing the Bonds and to fully funadsthe of bt Servfrom the Prior I dent re extent not funded by a tr The Owner agrees to amend the d Mortgage in substanti- ally the Modification of Mortgag e Note a ally the form attached as r hbi to he veto and to make loan payments under the Note as pvided Section 2.2• Additional Payments. In addition to payments ture and the ' required of the Owner under rht he the reasonable Loan the owner agrees to pustee as trustee, paying agent, and of any and expenses of the are not other paying agent on the Bonds under the Indenture includin t the cost g payable from the funds held under the Indenture, the Issuer the expenses of of the Rebate Calculation and to pay without granting the Issuer, if any; provided that the Owner may, a default hereunder, contest in good faith the reasonableness of any such extraordinary fees, charges or expenses. 2.3. RedeM t'1�Bonds. The Issuer, at the written Section rovision first made for upon request at any time of the Owner, hall forthwith take all steps that the Issuer's expenses, if any, e all of the may be necessary under the applicable redemption provisions the then out- s Indenture to effect the redemption of all the Owner, on the earliest standing Bonds, as may h specified by be made under such redemption date on which such redemption may 1 to any applicable provisions. This provision shall not apply ARTICLE III ISSUANCE OF BONDS; APPLICATION OF PROCEEDS Section 3.1. Issuance of Bonds;-Deposit and Disbursement of Bond Proceeds. In order to provide funds to refund the Refunded Bonds, the Issuer will issue, sell and deliver the Bonds and will deposit the proceeds of the Bonds with the Trustee as provided in the Indenture and will direct the Trustee to disburse funds for the purposes and on the terms and conditions provided in Section 2.1 hereof and Section 4.02 of the Indenture. Section 3.2. Investment of Fund Money. Any money held as part of the Bond Fund, the Rebate Fund, the Costs of Issuance Fund, the Collateral Fund, the Program Fund, the Debt Service Reserve Fund, or the Mortgage Reserve Account shall be invested and reinvested by the Trustee as specified in the Indenture. The Issuer and the Owner jointly and severally covenant that the use of the proceeds of the Bonds, including any money held as part of any fund and any other amounts received by the Issuer in respect to property directly or indirectly financed with the proceeds of the Bonds, and proceeds from interest earned on the investment and reinvestment of such fund and proceeds, shall be invested or otherwise used and shall be restricted in such manner and to such extent, if any, as may be necessary, after taking into account reasonable expectations at the time of issuance of the Bonds, so that the Bonds will not constitute "arbitrage bonds" within the meaning of Section 148 of the Code. Any officer of the Issuer having responsibility with respect to the issuance of the Bonds is authorized and directed, alone or in conjunction with any other officer, employee or consultant of the Issuer or the owner, and upon receipt of satisfactory indemnities, to give an appropriate certificate on behalf of the Issuer, for inclusion in the transcript of proceedings for the Bonds, setting forth the facts, estimates and circumstances and reasonable expectations pertaining to Section 148 of the Code. ARTICLE IV MAINTENANCE, INSURANCE, DAMAGE, DESTRUCTION AND EMINENT DOMAIN Section 4.1. 'Maintenance. So long as any of the Bonds are outstanding within the meaning of the Indenture, the Owner shall, as required under the Loan Documents, keep and maintain the Project, including all appurtenances thereto and any personal property therein or thereon, in good repair and good operating condition. Section 4.2. Removal of Portions of the Project. The Owner shall have the right from time to time to substitute personal property or fixtures for any portions of the Project, provided such actions are permitted under the Loan Documents. Removal of any portion of the Project pursuant to this Section shall be made only with the prior written concurrence of FHA. Section 4.3. Insurance. The Owner agrees to insure the project as required by FHA and by Section 5.08 of the Indenture. Section 4.4. Worker's Compensation Coverage. Throughout the term of this Loan Work -Out Agreement, the Owner shall comply, or cause compliance, with applicable worker's compensation laws of the State of Florida. Section 4.5. Damage Destruction and Eminent Domain. If, prior to full payment of all Bonds outstanding (or provision for payment thereof having been made in accordance with the provisions of the Indenture) ; the Project or any portion thereof is destroyed or damaged as a whole or in part by fire or other casualty, or title to, or the temporary use of, the project or any portion thereof shall have been taken by the exercise of the power of eminent domain, and the Issuer, the Owner or Trustee receives Net Proceeds from insurance or any condemnation award in connection therewith, such proceeds shall be applied as provided in the Loan Documents and the Indenture. 10 ARTICLE V WARRANTIES, REPRESENTATIONS AND SPECIAL COVENANTS Section 5.1. Representations and Warranties of the Issuer. The Issuer represents, warrants and covenants as follows: (a) The Issuer is a municipal corporation, organized and existing under the laws of the State of Florida. The Issuer agrees that it will do or cause to be done all things necessary, so far as lawful, to preserve and keep in full force and effect its existence. The Issuer has duly accomplished all conditions neces- sary to be accomplished by it prior to issuance and delivery of the Bonds and execution and delivery of this Loan Work -Out Agreement, it is not in default under any of the provisions contained in the laws of the State in any manner that would impair its ability to carry out its obligations hereunder, it has power under the Act to enter into the transactions contemplated by this Loan Work -Out Agreement, and it has been duly authorized to execute and deliver this Loan Work -Out Agreement. (b) The Issuer will, solely from Pledged Revenues, pay or cause to be paid the principal of and interest on the Bonds on the dates, at the places and in the manner provided therein. (c) The Issuer will at all times faithfully_ observe and perform all agreements, covenants, undertakings, stipulations and provisions contained in this Loan Work -Out Agreement, the Indenture and in any and every Bond executed, authenticated and delivered under the Indenture, and in all proceedings of the Issuer pertain- ing to the Bonds, the Indenture or this Loan Work -Out Agreement. The Issuer warrants and covenants that it is, and upon delivery of the Bonds will be, duly authorized by the laws of the State of Florida, including particularly and without limitation, the Act, to issue the Bonds and to execute the Indenture and this Loan Work -Out Agreement, to provide the security for payment of the Bonds and interest thereon in the manner and to the extent herein and in the Indenture set forth; that all actions on its part for the issuance of the Bonds and execution and delivery of the Indenture and the Loan Work -Out Agreement have been or will be duly and effectively taken; and that the Bonds will be valid and enforceable limited obligations of the Issuer according to the terms thereof and are payable solely from revenues pledged to the payment thereof under the Indenture, and do not constitute a debt of the Issuer within the meaning of any constitutional or statutory provision. The Bonds are not secured by any obligation or pledge of any money received, or to be received, from taxation or from the State of Florida or any political subdivision, taxing district or public body thereof and do not now and never shall constitute a charge against the general credit or taxing powers of the State of Florida, the Issuer or any other public body, pursuant to the laws 11 of the State of Florida. Each provision of the Indenture, Loan Work -Out Agreement and Bonds is binding upon each such officer of the Issuer as may from time to time have the authority under law to take such actions as may be necessary to perform all or any part of the duties required by such provision; and each duty of the Issuer and of its officers undertaken pursuant to such proceedings for the Bonds is established as a duty of the Issuer and of each such officer having authority to perform such duty. (d) Except as otherwise provided in the Indenture and Loan Work -Out Agreement, the Issuer will not create or suffer to be created any debt, lien or charge thereon, or make any pledge or assignment of or create any debt, lien or charge on the Project, or make any pledge or assignment of or create any lien or encumbrance upon the Pledged Revenues, including the money in the Bond Funds, other than the pledge and assignment thereof under the Indenture and this Loan Work -Out Agreement. (e) The Trustee, in its name or in the name of the Issuer, may, for and on behalf of the Bondholders, enforce all rights of the Issuer and all obligations of the Owner under and pursuant to this Loan Work -Out Agreement, the Note and the Loan Documents, whether or not the Issuer has pursued or attempted to enforce any of such rights and obligations. Section 5.2. Representations of the Owner. As a condition to the Issuer's entering into this Loan Work -Out Agreement, the Owner represents, warrants and covenants to the Issuer as follows; (a) The Owner is a limited partnership duly organized and existing under and by virtue of the laws of the State and is not in violation of any provision of its partnership agreement or any laws of the State relevant to the transactions contemplated by this Loan Work -Out Agreement, the Note, the Indenture or the Loan Documents. ` (b) The Owner has full power and authority to execute and deliver this Loan Work -Out Agreement and the Modification Agreement, and t >p carry out the transactions provided for therein. This Loan Work -Out Agreement and the Modification Agreement have by proper action been duly authorized, executed and delivered by the Owner and all actions necessary have been taken to constitute this Loan Work -Out Agreement and the Modification Agreement, when executed and delivered by the respective parties thereto, valid and binding obligations of the Owner. (c) The execution, delivery and performance by the Owner of this loan Work -out Agreement and the Modification Agreement and the consummation of the transactions contemplated hereby and thereby will not violate any provision of law or regulation applicable to the Owner, or of any writ or decree of any count or governmental instrumentality, or of the partnership agreement of the owner, or of any mortgage, indenture, contract, agreement or other 12 undertaking to which the Owner is a party or that purports to be binding upon the Owner or upon any of its assets. (d) The use of the Project will be in accordance with the Act, and the Project will be utilized and maintained in such manner as to conform with all applicable zoning, planning, building and other similar regulations of all governmental authorities having jurisdiction of the Project, and all necessary permits, licenses, consents and permissions have been obtained as of the date of execution of this Loan Work -Out Agreement to the extent that the same are obtainable as of such date and the Project conforms to all environmental regulations known to the Owner. (e) There are no actions, suits or proceedings pending, or to the knowledge of the Owner, threatened against or affecting it or the Project or involving the validity or enforceability of the Mortgage or the priority of the lien thereof, at law or in equity or before or by any governmental authority, except actions, suits and proceedings fully covered by insurance or that, if adversely determined, would not substantially impair the ability of the Owner to pay when due any amounts which may become payable in respect of the Note; and to the Owner's knowledge it is not in default with respect to any order, writ, injunction, decree or demand of any court or any governmental authority that will not be cured by the transactions contemplated herein. (f) The consummation of the transactions hereby contemplated and performance of this Loan Work -Out Agreement and the Modification Agreement will not result in any breach of, or constitute a default under any mortgage, deed of trust, lease, bank loan, credit agreement, or other instrument to which the owner is a party or by which it,may be bound or affected. (g) No assessments of any nature with respect to the Project remain unpaid, including but not limited to assessments relating to streets, roads, entrances, waterlines, sanitary and storm sewers, gas lines and all other utilities including acreage fees and trunk sewers. (h) The Owner shall do or cause to be done all things necessary to preserve, maintain and keep in full force and effect its legal existence and comply with all laws applicable to it. (i) The owner agrees to promptly give notice in writing to the Trustee and the Issuer of the occurrence or existence of any material litigation, labor dispute or governmental proceeding or investigation affecting the Owner that could reasonably be expected to interfere substantially with its normal operations or materially and adversely affect, its financial condition. (j) The owner lawfully owns and is possessed of the real property and interests therein described in the Mortgage and has 13 good and marketable title and fee simple estate therein subject only to such encumbrances as are described in the Trustee's policy of title insurance and approved by FHA, and it will defend the title thereto and every part thereof against the claims and demands of all persons whomsoever. (k) No counterclaim, offset, defense or right o: exists that can be asserted and maintained by the Owner Issuer. (1) The statements made in the final Official Statement relating to the Bonds (the "Official statement ") that are descrip- tive of the Owner, the Project, this Loan Work -Out Agreement or the Loan Documents have been prepared or reviewed by the Owner and did not on the date of the Official Statement, do not on the date of this Loan Work -Out Agreement and will not on the date of delivery of the Bonds contain any untrue statement of a material fact or omit to state any material fact necessary in order to make such statements, in light of the circumstances under which they were made, not misleading. (m) The Owner will prepare or cause to be expense all audits of the Owner or of the Project in accordance with HUD regulations. If the Owner receives notice from the Trustee that any required to be paid by the Owner into the Rebate Fund, shall promptly make such payment. (o) The Owner agrees to pay all of the fees and expenses of Bond Counsel, a certified public accountant and any other necessary consultant employed by the Owner, the Trustee or the Issuer in connection with any of the requirements imposed by Sections 4.14, 4.15 or 4.16 of the Indenture. The Owner shall provide or cause to be provided all information and moneys (including moneys necessary to make deposits to the Rebate Fund required by the Indenture) to the Trustee to enable the Trustee to perform the duties imposed on the Trustee by the Indenture with respect to any excess nonpurpose obligation earnings and investment of amounts held under the Indenture. (p) The Owner covenants and agrees that from the date hereof until payment in full of all of the obligations hereunder, unless the Trustee shall otherwise consent in writing, the Owner will not: (i) incur, create, assume or suffer to exist any mort- gage, pledge, security interest, lien, charge or other encumbrance of any nature on any of the owner's assets, now or hereafter owned other than (1) any liens, taxes or other governmental charges which are not yet due and payable, (2) any pledge relating to syndication of the Project, (3) any lien, including, but without limiting the generality of the foregoing, mechanics' liens, or other liens resulting from a good -faith dispute on the part of the Owner, which dispute the Owner agrees to resolve diligently, or which liens are insured over by a title insurance company acceptable to FHA, (4) the Second Mortgage and the Partnership Mortgage, (5) other liens or encumbrances approved by FHA, (6) purchase money liens on personal property arising in the ordinary course of business, and (7) such other pledges as may be approved in writing by the Trustee; (ii) To the extent required by FHA, make changes with respect to the general partner(s) now acting as the duly authorized general partner(s) of the Owner without approval of FHA; (iii) No general partner shall be permitted to sell, assign, give, transfer or otherwise dispose of his entire share ownership interest in the Owner without first presenting to the Trustee a certificate with respect to compliance with the Tax Regulatory Agreement; or (iv) Create, incur, assume or suffer to exist any indebtedness for borrowed money or any other obligation whatsoever, regardless of how evidenced or secured except indebtedness of the Owner to the Issuer or the Trustee or provided in the Note, Mortgage, Indenture and the documents referred to therein or in the normal course of business. (q) The Project constitutes land or property of a character subject to the allowance for depreciation for purposes of Section 103(b) of the Code, and substantially all of the net proceeds received from the sale of the Bonds (net proceeds being those proceeds remaining after paying all of the expenses incurred in connection with the issuance of the Bonds) will be used to finance the acquisition, construction and equipping of the Project. Not more than 25% of the proceeds of the Bonds shall be used to provide a facility described in Section 144(a) (8) of the Code, and no portion of the proceeds of the Bonds shall be used to provide any property or facility described in Sections 144(a)(8) or 147(e) of the Code. (r) The average weighted maturity of the Bonds does not exceed the average weighted estimated economic life of the compo- nents comprising the Project by more than 20 %, determined pursuant to Section 147(b) of the Code. (s) (1) No portion of the proceeds of the Refunded Bonds was applied directly or indirectly, to the acquisition of land, or an interest therein, to be used for farming purposes, except and only to the extent that the Owner is a first -time farmer, as defined in and pursuant to the conditions of section 144(a)(11) and Section 147(c) of the Code; and 15 4F, (2) No portion equal to 25% or more of the proceeds of the Refunded Bonds was applied, directly or indirectly, to the acquisition of land, or an interest therein, except and only to the extent that the Project is an industrial park, in which case no portion equal to 5o; or more the proceeds shall be so applied, or that the Project is an airport, mass transit or port development project consisting of facilities described in Sections 141(a)(1), 141(a)(2) or 141(a)(3) of the Code, in which case land may be acquired for noise abatement, wetland preservation, further use or other public purposes. (t) To its knowledge, the Owner is now, an' at all times since the issuance of the Refunded Bonds has been, in compliance with all of the material obligations imposed upon it by (i) the Supplemental Regulatory Agreement (except to the extent that its default under the Mortgage Loan may constitute a default under such agreement) and (ii) the other agreements and instruments executed and delivered or otherwise binding upon it in connection with the issuance of the Refunded Bonds. Section 5.3. Owner's Approval of Indenture. The Indenture has been submitted to the Owner for examination, and the Owner acknowledges, by execution of this Loan Work -Out Agreement, that it has approved the Indenture. Section 5.4. Indemnification. Except for any liability arising out of or in connection with the gross negligence or willful misconduct of the Issuer or the Trustee or their respective members, commissioners, officers, agents, employees, attorneys and consultants, the Owner hereby releases the Issuer and the Trustee, and their respective members, commissioners, officers, agents, employees, attorneys and consultants from, agrees that the Issuer and the Trustee, and their respective members, commissioners, officers, agents, employees, attorneys and consultants, shall not be liable for, and agrees to reimburse and indemnify and hold the Issuer and the Trustee, and their respective members, commissioners, agents, employees, attorneys and consultants harmless from and against, any and all: (1) liability for loss or damage to property or any injury to or death of any and all persons that may be occasioned by any cause whatsoever pertaining to the project or arising by reason of or in connection with the acquisition, construction, equipping, occupation, or use of said Project; (2) liability arising from, or expense incurred by reason of, the Issuer's financing of the acquisition, construction and equipping of the Project, and all causes of action and attorneys' fees and any other expense incurred in defending any suits or actions which may arise as a result of any of the foregoing; and (3) all costs and expenses of the Issuer and the Trustee and their respective commissioners, officers, directors, employees, agents and attorneys incurred as a result of carrying out their respective obligations under this Loan Work -Out Agreement, the Indenture or any other document herein contemplated. 16 Notwithstanding that it is the intention of the parties that the issuer and the Trustee shall not incur any pecuniary liability by reason of this Loan Work -out Agreement, the Indenture or the issuance of the Bonds, or by reason of any actions, documents, statutes, ordinances, or regulations pertaining to the foregoing, the Owner hereby agrees to promptly pay any and all costs and expenses, including reasonable attorney fees, as such costs and expenses accrue, which may be incurred by, or judgments which may be rendered against, the Issuer or the Trustee or any of their respective officers, directors, employees, commissioners, agents or attorneys, at any time or times during, or subsequent to, the term of this Loan Work -Out Agreement, including any costs and expenses incurred as part of any bankruptcy proceedings: (1) in enforcing any of the terms, covenants, conditions or provisions of this Loan Work -Out Agreement, the Indenture or any other document herein contemplated; (2) in taking any action as a result of the occurrence of any Default; or (3) in defending any action, suit, or proceeding brought against the Issuer or the Trustee, or any of their respective officers, directors, employees, agents or attor- neys, as a result of the violation by or on behalf of the Owner of, or failure by or on behalf of the Owner to comply with, any present or future federal, state or municipal law, ordinance, regulation or order, or as a result of any alleged failure, neglect, misfeasance or default on the part of the Owner, or any of the Owner's officers, directors, employees, servants, agents or independent contractors, as applicable, or the Owner in connection with, arising from, or growing out of, this Loan Work -Out Agreement, the Indenture or in connection with the issuance of the Bonds, or the Project, or the acquisition, construction or equipping thereof, or any operations conducted in, or any use or occupancy of, said Project, or any action pertaining to, or connected with, any of the foregoing. The provisions of this Section 5.4 shall survive the termination of this Loan Work -Out Agreement. Section 5.5. Owner Not to Adversely Affect Tax - Exempt Status of Interest on Bonds. The Owner, for the benefit of the Issuer and each Holder, hereby represents it has not taken, or permitted to be taken on its behalf, and agrees that it will not take, or permit to be taken on its behalf, any action which would adversely affect the exclusion of the interest paid on the Bonds from gross income for federal income tart purposes, and that it will make and take, or require to be made and taken, such acts and filings as may from time to time be required under the Code to maintain such exclusion. Section 5.6. Notice of Certain Events. If the Owner becomes aware of any situation, event or condition that would result in the interest on the Bonds becoming included in gross income for federal income tax purposes, the owner shall promptly give written notice thereof to the Issuer, Mortgage Servicer, the Trustee and the Bond Purchaser. 17 section 5.7. Tares, Other Governmental Charges and Utility Chartres. The Owner may, at its own expense and in its own name and behalf, in good faith contest any property taxes, governmental charges, assessments and other charges and, in the event of any such contest, may permit the taxes, assessments or other charges so contested to remain unpaid during the period of such contest, and any appeal therefrom unless by such action the title of the Issuer to any part of the Project shall be materially endangered or the Project or any part thereof shall become subject to loss or forfeiture, in which event such taxes, assessments or charges shall be paid prior to their becoming delinquent. a + 18 i ARTICLE VI ASSIGNMENT Section 6.1. Assignment by Owner. This art o Work -Out Agreement may not be assigned as a whole or in p ownership of the 'th a transfer of the except in accordance wi to HUD regulations and procedures Project pursuant Section 6.2. Issuer Pled e of Certain eRthe project Lo and Out A reement. The Owner shall mortgage money eceivable Issuer shall assign its interest in to phedTrustee as security for under this Loan Work -Out Agreement, payment of the principal of and interest on the Bonds. Assi nment b the Issuer. The Issuer shall Section 6.3. and pledge the Pledged assign its rights under and her t hngs,l loan payments hereunder to Revenues including, among for payment of the Trustee pursuant to the Indenture as premium security n the Bonds and the principal of and interest and any P ledg e except as may shall not make any further such assignment or p of principal be necessary or required to enforce or secure payment of and interest and any premium on the Bonds. 19 ARTICLE VII TERMINATION, PREPAYMENT AND AMENDMENT OF NOTE Section 7.1. Option to Terminate. The Owner shall have the option to terminate this Loan Work -Out Agreement at any time when (i) the Indenture shall have been released pursuant to its provi- sions and (ii) sufficient money is on deposit with the Trustee, the Mortgage Servicer or the Issuer, or all of them combined, to meet all additional payments due or to become due through the date on which the last of the Bonds is then scheduled to be retired or redeemed, or, with respect to additional payments to become due, provisions satisfactory to the Trustee, the Mortgage Servicer and the Issuer are made for paying such amounts as they come due. Such option shall be exercised by the Owner giving the Issuer, the Mortgage Servicer and the Trustee notice of such termination and such termination shall thereupon become effective. Section 7.2. Option to Prepay Loan. The Owner shall have, and is hereby granted, the option to prepay the Loan in full or in part prior to the payment and discharge of all the outstanding Bonds only in accordance with the provisions of the Note and the Indenture. The mutual agreements contained in this Section are indepen- dent of, and constitute an agreement separate and distinct from, any and all provisions of this Loan Work -Out Agreement and shall be unaffected by any fact or circumstances that might impair or be alleged to impair the validity of any other provision. Section 7.3. Amendment of Note. The Owner may request an amendment of the Note and the Mortgage in accordance with Section 8.04 of the indenture in the event the Project fails to produce sufficient revenues to make the debt service payment required under the Note. This amendment will be permitted only if the Owner can demonstrate to the satisfaction of FHA, Standard & Poor's Corporation and the Trustee that the Project will produce suffi- cient revenues to meet the scheduled debt service on the Bonds. 20 ARTICLE 'VIII EVENTS OF DEFAULT AND REMEDIES Section 8.1. Events of Default. The following shall be "events of default" under this Loan Work -Out Agreement and the terms "event of default" or "default" shall mean, whenever they are used in this Loan Work -Out Agreement, any one or more of the following events: (a) The occurrence of an event of default as defined in Section 6.01 (a) or (b) of the Indenture, or a default in payment under the Note. (b) The occurrence of an event of default pursuant to the terms of any of the Loan Documents, or pursuant to the regulations promulgated by FHA relating to projects to be insured pursuant to Section 221(d) (4) of the National Housing Act of 1934, as amended. The provisions of paragraph (b) of this Section are subject to any notice or grace provisions permitted or required by the Loan Documents. Section 8.2. Remedies on Default. Whenever any event of default under Section 8.1 of this Loan Work -Out Agreement shall have happened and be subsisting, any one or more of the following remedial steps may be taken, provided that in no event shall the Issuer be obligated to take any step which in its opinion will or might cause it to expend time or money or otherwise incur liability unless and until a satisfactory indemnity bond has been furnished to it: (a) The Issuer shall cooperate with the Trustee as the Trustee acts pursuant to Section 6.02 of the Indenture. (b) In the event any of the Bonds shall at the time be outstanding and not paid and discharged in accordance with the provisions of the Indenture, the Issuer or the Trustee may have access to and inspect, examine and make copies of the books and records and any and all accounts, data and income tax and other tax returns of the Owner. (c) The Issuer may, without being required to give any notice (other than to the Trustee), except as provided herein, pursue all remedies of a creditor under the laws of the State, as supplemented and amended, or any other applicable laws, (d) The Issuer or Trustee may take whatever action at law or in equity may appear necessary or desirable to collect the payments due under Article II hereof then due and thereafter to become due, 21 or to enforce performance and observance of any obligation, agree- ment or covenant of the Owner under this Loan Work -Out Agreement. (e) The Trustee shall, upon the occurrence of an event of default under any of the Loan Documents, pursuant to applicable FHA regulations immediately give notice and assign the Note and the Mortgage to FHA in exchange for cash payment of insurance benefits pursuant to the terms of the Loan Documents and Section 221(d)(4) of the National Housing Act of 1934, as amended. Any amounts collected pursuant to Article II hereof and any other amounts that would be applicable to payment of principal of and interest and any premium on the Bonds collected pursuant to action taken under this Section shall be applied in accordance with the provisions of the Indenture. The provisions of this Section are subject to the further limitation that the rescission or annulment of a declaration that all the Bonds outstanding under the Indenture are immediately due and payable shall also constitute rescission or annulment of any corresponding declaration made pursuant to paragraph (a) of this Section and a waiver and rescission of the consequences of such declaration and of the event of default with respect to which such declaration had been made, provided that no such waiver or rescission shall extend to or affect any subsequent or other event of default or impair any right consequent thereon. Notwithstanding anything herein or in the Indenture to the contrary, the Issuer shall not be required to take any affirmative action to enforce any remedies in the event of default hereunder. Section 8.3. No Remedy Exclusive. No remedy conferred upon or reserved to the Issuer or the Trustee by this Loan Work -Out 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 Loan Work -Out Agreement or now or hereafter existing at law or in equity or by statute. No delay or omission to exercise any right or power accruing upon any default 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 from time to time and as often as may be deemed expedient. In order to entitle the Issuer or the Trustee to exercise any remedy reserved to it in this Article, it shall not be necessary to give any notice, other than such notice as may be expressly required herein. Section 8.4. Agreement to Pay Attorneys' Fees and Expenses. In the event the Owner should default under any of the provisions of this Loan Work -Out Agreement and the Issuer, the Trustee or the Mortgage Servicer should employ attorneys or incur other expenses for the collection of Loan Payments or the enforcement of perfor- mance or observance of any obligation or agreement on the part of 22 the owner contained in this Loan Work -Out Agreement or represented by the Note, the owner shall on demand therefor reimburse the reasonable fee of such attorneys and such other expenses so incurred. Section 8.5. No Additional Waiver Implied by One Waiver. In the event any agreement contained in this Loan Work -Out Agreement should be breached by any party and thereafter waived by the other parties, such waiver shall be limited to the particular breach so waived and shall not be deemed to waive any other breach hereunder. 23 R ARTICLE IX MISCELLANEOUS Section 9.1. Term of Agreement. This Loan Work -Out Agreement shall remain in full force and effect from the date hereof to and including October 1, 2025, or until such time as all of the Bonds shall have been fully paid (or provision made for such payment pursuant to the Indenture), whichever shall be earlier. Section 9.2. Notices. All notices, certificates, requests or other communications hereunder shall be sufficiently given and shall be deemed given when mailed by registered or certified mail, postage prepaid, addressed to the appropriate Notice Address. A duplicate copy of each notice, certificate, request or other communication given hereunder to the Issuer, the Mortgage Servicer or the Owner shall also be given to the Trustee. The Owner, the Issuer and the Trustee may, by notice given hereunder, designate a different Notice Address for it than the one specified in Section 1.2 hereof. Section 9.3. Binding Effect. This Loan Work -Out Agreement shall inure to the benefit of and shall be binding upon the Issuer, the Owner, the Trustee and their respective successors and assigns, subject, however, to the specific provisions hereof, and subject to the further limitation that any obligation of the Issuer created by or arising out of this Loar Work -Out Agreement shall not constitute an indebtedness or a charge against the general taxing power of the Issuer or the State or any political subdivision, taxing district or public body thereof, but shall be payable solely out of the Pledged Revenues, as provided herein, nor is any such obligation secured by any obligation or pledge of any money received, or to be received, from taxation or from the Issuer, the State or any political subdivision, taxing district or public body thereof. Section 9.4. Amendments Changes and Modifications. Except as otherwise provided in this Loan Work -Out Agreement or in the Indenture, subsequent to the issuance of the Bonds and prior to all conditions provided for in the Indenture for release of the Indenture having been met, this Loan Work -Out Agreement may not be effectively amended, changed, modified, altered or terminated without the prior written consent of the Trustee. Section 9.5. Execution Counterparts. This Loan Work -Out Agreement may be executed in several counterparts, each of which shall be regarded as an original and all of which shall constitute but one and the same Loan Work -Out Agreement. Section 9.6. Severability. In case any clause, provision or section of this Loan Work -out Agreement, or any covenant, stipulation, agreement, act or action, or part thereof, made, 24 assumed, entered into, or taken under this Loan above- captioned, or any application thereof, is for any reason held to be illegal, invalid or inoperable, such illegality, invalidity, or inoperabil- ity shall not affect the remainder thereof or make any other clause, provision or section or any other covenant, stipulation, obligation, agreement, act or action or part thereof, made, assumed, entered into, or taken thereunder, illegal or invalid or inoperable as if such illegal, invalid or inoperable portion were not contained therein, nor shall such illegality or invalidity or inoperability of any application thereof affect any legal and valid and operable application thereof, from time to time, and each such clause, provision or section, covenant, stipulation, obligation, agreement, act, or action, or part thereof shall be deemed to be effective, operative, made, entered into or taken in the manner and to the full extent from time to time, and each such clause, provision or section, covenant, stipulation, obligation, agreement, act, or action, or part thereof shall be deemed to be effective, operative, made, entered into or taken in the manner and to the full extent from time to time permitted by law. Section 9.7. Cautions. The captions or headings in this Loan Work -Out Agreement are for convenience only. Section 9.8. Governing Law. This Loan Work -Out Agreement shall be deemed to be a contract made under the laws of the State of Florida and for all purposes shall be governed by and construed in accordance with the laws of the State of Florida. Section 9.9. HUD and FHA Requirements to Control. (a) Notwithstanding anything in the Indenture or this Loan Work -Out Agreement to the contrary, the provisions hereof are subject and subordinate to the National Housing Act, all applicable HUD insurance (and Section 8, if applicable) regulations and related administrative requirements and the Mortgage Loan Docu- ments, and all applicable FHA regulations and related administra- tive requirements; and in the event of any conflict between the provisions of said Indenture or this Loan Work -out Agreement and the provisions of the National Housing Act, any applicable HUD regulations, related HUD administrative requirements, or the Mortgage Loan Documents, or the FHA regulation and related administrative requirements, the said National Housing Act regulations, related administrative requirements or Mortgage Loan Documents shall be controlling in all respects. (b) This Loan Work -Out Agreement shall not be construed to restrict or adversely affect the duties and obligations of the Trustee under the Contract of Insurance between the Trustee and HUD with respect to the Mortgage Loan. (c) Any project funds held by the Mortgage Servicer for or on behalf of the Owner shall be maintained separate and apart from the 25 funds established and held by the Trustee for the holders of the Bonds and the various escrows and funds, if any, under the Indenture. (d) Neither the Issuer, the Trustee, nor any of the Bond- holders has or shall be entitled to assert any claim against the Project, the Mortgage proceeds, any reserve or deposit required by HUD in connection with the Mortgage Loan, or the rents or income of the property other than "surplus cash" as defined in the Regulatory Agreement, or as otherwise permitted by HUD; provided, however, the foregoing shall not restrict any rights of the Issuer, the Trustee, the Mortgage Servicer or any of the Bondholders against any guarantor of the obligations of the owner, if any, with respect to this Loan Work -Out Agreement. Section 9.10. Limited Liability of Owner, Recourse Against Project Assets. (a) The monetary obligations of the Owner contained in this Loan Work -Out Agreement (except for indemnification under Section 5.4 hereof and payments required to be made pursuant to Sections 2.2, 5.2 (p), 5.4 and 8.4 hereof) shall be limited obligations payable solely from the income and assets of the Project and neither the Owner or any successor or assignee thereof nor any officer, director or employee of the Owner or any successor or assignee thereof shall have personal liability for the satisfaction of any obligation of the Owner or claim arising out of this Loan Work -Out Agreement against the Owner other than from revenues of the Project. Notwithstanding anything contained in this Loan Work- out Agreement to the contrary, neither the Issuer, nor the Trustee may assert any claim arising hereunder against the Owner's interest in the Project, the proceeds of the Mortgage on the Project, any reserve or deposit made with the Mortgage Servicer or with any other entity that is required by HUD in connection with the giving of the Mortgage Loan, or in the rents or other income of the Project for the payment of any charge due hereunder except to the extent available from "surplus cash" as that term is defined in the Regulatory Agreement, (b) Notwithstanding any provisions in this Loan Work -Out Agreement to the contrary, enforcement of the provisions of this Loan Work. -Out Agreement shall not result in any claim against the Project, Mortgage Loan proceeds, any reserve or deposit required by HUD or the Mortgage Servicer in connection with the Mortgage Loan, or the rents or other income from the Project (other than available Excess Surplus Cash as defined in the FHA Regulatory Agreement or distributions thereof). By execution hereof, each of the undersigned affirms that no pledge has been made and that it has no claim, and will not later assert any claim, against the Project, the Mortgage Loan proceeds, any reserve or deposit made with the Mortgage Servicer or any other amounts required by HUD in connection with the Mortgage Loan, or against the income from the 26 Project for payment of any obligation contained herein (other than available surplus cash as defined in the FHA Regulatory Agreement or distributions thereof); provided, however, that this provision shall not alter, affect or diminish the rights of the Trustee or the Mortgage Servicer under the Mortgage Loan Documents. Section 9.11. No Liability of Issuer Officers. Notwithstand- ing anything to the contrary contained in the Bonds, Indenture or this Loan Work -Out Agreement, or in any other instrument or docu- ment executed by or on behalf of the Issuer in connection herewith, no stipulation, covenant, agreement or obligation contained herein or therein shall be deemed or construed to be a stipulation, covenant, agreement or obligation of any present or future member, commissioner, director, trustee, officer, employee or agent of the Issuer, or of any incorporator, member, commissioner, director, trustee, officer, employee or agent of any successor to the Issuer, and no such other person in any such person's individual capacity shall be liable personally for any breach or non- observance of or for any failure to perform, fulfill or comply with any such stipu- lations, covenants, agreements or the principal of, premium, if any, or interest on any of the Bonds or for any claim based thereon or on any such stipulation, covenant, agreement or obligation, against any such person, in his or her individual capacity, either directly or through the Issuer or any successor to the Issuer, under any rule of law or equity, statute or constitution or by the enforcement of any assessment or penalty or otherwise, and all such liability of any such person, in his or her individual capacity, is hereby expressly waived and released. CITY OF CLEARWATER, FLORIDA By: Mayor BANK ONE, COLUMBUS, NA, Columbus, Ohio, as Trustee By: Its: DREW GARDENS ASSOCIATES, LTD., a Florida Limited Partnership By: Reynolds Metals Development Company, as General Partner By: 27 Title: 12041.18 JHH W:RWN :rst 08/12/41 Y $3,425,000 CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992A (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) BOND PURCHASE AGREEMENT City of Clearwater City Hall Mayor and City Commission 112 South Osceola Avenue Clearwater, Florida 34616 Drew Gardens Associates, Ltd., a Florida limited partnership c/o Reynolds Metals Development Company 4501 N.W. 31st Avenue Foist Lauderdale, Florida 33309 August 13, 1992 Ladies and Gentlemen: Banc One Capital Corporation and Newman and Associates, Inc. (collectively, the "Underwriters "), understand that the City of Clearwater, Florida (the "Issuer "), proposes to issue and sell to a purchaser or purchasers to be designated by the Underwriters $3,425,000 aggregate principal amount of the City of Clearwater, Florida Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan - Drew Gardena Apartments Project) (the "Bonds "), to be issued pursuant to a Trust Indenture dated as of August 1, 1992 (the "Indenture "), between the Issuer and Bank One, Columbus, NA, as Trustee (the "Trustee "), as set forth in the Official Statement of the Issuer prepared for use by the Underwriters in making an offering of the Bonds (the "Official Statement "). The proceeds from the sale of the Bonds will be used to provide funds to refund, in part, a prior issue of bonds (the "Prior Bonds ") of the Issuer that were issued to pay the cost of acquiring, constructing, improving and equipping a 180 -unit multifamily residential rental housing facility project located in Clearwater, Florida (the "Project'), owned by Drew Gardens Associates, Ltd., a Florida limited partnership (the "Owner "). Section 1. Purchase, Sale and Delivery of Bonds. On the basis of the representations and agreements contained herein, but subject to the terms and conditions herein set forth, the Underwriters agree to place on behalf of the Issuer, and the Issuer agrees to sell to the purchaser designated by the Underwriters, all, but not less than all of the $3,425,000 aggregate principal amount of the Bonds at a purchase price equal to the principal amount thereof, plus accrued interest from August 1, 1992, to the Closing Date specified below. The Issuer will deliver the Bonds to the purchaser designated by the Underwriters in good deliverable form (including the printing of CUSIP numbers thereon) against payment of the purchase price therefor by immediately available funds at 10:00 a.m., pastern time, on August 18, 1992, or at such other time thereafter as may be mutually agreed upon by the parties, such time being hereinafter referred to as the "Closing Date." The maturities, principal amounts, interest rates and other terms and conditions of the Bonds shall be as set forth in Schedule I hereto. For our services hereunder, we shall be paid fees and expenses as set forth in Section 10 and Schedule II hereof, Section 2. Offering, Security and Authorization. The Underwriters propose to offer and sell the Bonds on behalf of the Issuer as set forth in the Official Statement. The Issuer and the Owner acknowledge that they have been advised that the Underwriters may offer the Bonds at prices above or below their principal amounts. Section 3. Delivery of Official Statement. At the time of the acceptance of this Bond Purchase Agreement by the Issuer (or such later date as the Underwriters may consent to), the Issuer shall deliver to the Underwriters for review copies of the Official Statement relating to the Bonds (which, including all appendices thereto, and with such changes therein and supplements thereto as are consented to by the Underwriters, are referred to as the ":Preliminary Official Statement "). The Issuer hereby ratifies the use of the Preliminary Official Statement by the Underwriters in the marketing of the Bonds. The Preliminary Official Statement shall be final as of its date of review, except for final information as to the offering prices, interest rates, selling compensation, amount of proceeds, delivery dates, other terms depending on such factors, and other information permitted to be omitted under Rule 15c2- 12(b)(1) under the Securities Exchange Act of 1934, as amended. The Issuer shall provide to the Underwriters, within seven business days following the date hereof (or earlier, if reasonably requested by the Underwriters), a quantity of final Official Statements, including such final information listed in the previous sentence (the "Official Statement ") adequate to enable the Underwriters to meet the continuing obligations imposed on it by Rule 15c2 -12 under the Securities Exchange Act of 1934; provided that the Underwriters shall have advised the Issuer of such quantity within two business days following the date hereof. Section d. Financing Documents. On or prior to the Closing Date, the Underwriters shall have received the following: (a) The Indenture, duly executed by the Issuer and the Trustee; (b) The Official Statement, duly executed by the Issuer and the Owner; (c) The Investment Agreement dated August 18, 1992, between the Trustee and Bayerische Landesbank Oirozentrale (the "Investment Agreement "), with respect to amounts held in the Bond Fund, the Debt Service Reserve Fund and the Mortgage Reserve Account of the Debt Service Reserve Fund under the Indenture; (d) The Loan Work -Out Agreement dated as of August 1, 1992, duly executed by the Issuer, the Owner and the Trustee (the "Loan Work -Out Agreement "); (e) The Supplemental Regulatory Agreement as to Tax Exemption (the "Supplemental Regulatory Agreement ") dated September 1, 1992, duly executed by the Issuer, the Owner and the Prior Trustee; and (f) A copy of the Mortgage Note (the "Note ") duly executed by the Owner, endorsed for insurance by FHA and amended by the Modification of Mortgage Note and Mortgage (the "Modification Agreement ") executed by FHA in the form attached as Exhibit A to the Loan Work -Out Agreement. i- r Section 5. Representations and Warranties by the Issuer. (a) The Issuer is a municipal corporation organized and existing under the laws of the State of Florida (the "State ") and has full legal right, power and authority (i) to enter into this Bond Purchase Agreement, (ii) to issue, sell and deliver the Bonds as provided herein, (iii) to use the proceeds of the Bonds to refund the Issuer's Mortgage Revenue Bonds, Series 1983 (FHA Insured Mortgage Loan -- Drew Gardens Apartments Project ) (the "Prior Bonds ") and (iv) to carry out the transactions contemplated by this Bond Purchase Agreement, the Indenture, the Official Statement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement. (b) The information in the Official Statement relating to the Issuer does not on the date hereof contain any untrue statement of a material fact or omit to state a material fact necessary in order to make the statements relating to the Issuer contained therein, in light of the circumstances under which they were made, not misleading. (c) By official action of the Issuer prior to or concurrently with the acceptance hereof, the Issuer has duly authorized and approved the Official Statement, has duly authorized and approved the execution and delivery of, and the performance by the Issuer of the obligations on its part contained in, the Indenture, the Bonds, this Bond Purchase Agreement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement and has duly authorized and approved the consummation of all other transactions contemplated by this Bond Purchase Agreement. (d) The Issuer is not in breach of or default under any applicable law or administrative regulation of the State or the United States that would impair materially the performance of its obligations under the Indenture, the Loan Work -Out Agreement, the Supplemental Regulatory Agreement or, this Bond Purchase Agreement or any applicable judgment or decree or any loan agreement, note, resolution, agreement or other instrument to which the Issuer is a party or is otherwise subject; and the execution and delivery of the Bonds, the Indenture, this Bond Purchase Agreement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement, and compliance with the provisions of each thereof, will not conflict with or constitute a material breach of or default under any law, administrative regulation, judgment, decree, loan agreement, note, resolution, agreement or other instrument to which the Issuer is a party or is otherwise subject. (e) All approvals, consents and orders of any governmental authority, board, agency or commission having jurisdiction which would constitute a condition precedent to the performance by the Issuer of its obligations hereunder and under the Indenture, the Bonds, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement have been obtained. (r') Except as disclosed in the Official Statement, the Issuer has received no notice of any action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, public board or body, pending, and to its knowledge, no such action or suit is threatened, against the Issuer affecting the existence of the Issuer or the titles of its officials to their respective offices or seeking to prohibit, restrain or enjoin the financing or the sale, issuance or delivery of the Bonds or the pledge of revenues or assets of the Issuer pledged or to be pledged to pay the principal of and interest on the Bonds, or in any way contesting or affecting the validity or enforceability of the Bonds, the Indenture, this Bond Purchase Agreement, the Loan Work -Out Agreement, or the Supplemental Regulatory Agreement or contesting in any way the completeness or accuracy of the Official Statement, or contesting the powers of the Issuer or any authority -3- f Aft i for the issuance of the Bonds, the execution and delivery of this Bond Purchase Agreement, the Indenture, the Loan Work -Out Agreement or the Supplemental Regulatory Agreement, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Bonds, the Indenture, the Loan Work -Out Agreement, the Supplemental Regulatory Agreement or this Bond Purchase Agreement. (g) The issuance and sale of the Bonds are not subject to any transfer or other documentary stamp taxes of the State or any political subdivision thereof. (h) The Bonds, when issued, authenticated and delivered in accordance with the Indenture and sold to the Underwriters as provided herein, will be validly issued and outstanding limited obligations of the Issuer enforceable in accordance with their terms and entitled to the benefits of the Indenture as provided therein; provided, however, that the remedies available are subject to certain limitations as more fully described in the Official Statement. (i) The Issuer has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that the Issuer is a bond issuer whose arbitrage certifications may not be relied upon. Section 6. Representations and Warranties of the Owner. (a) The Owner is a duly organized and existing limited partnership under the laws of the State and has full legal right, power and authority (i) to enter into this Bond Purchase Agreement, (ii) to fulfill its obligations under the FHA Note and the Mortgage, and (iii) to carry out the transactions contemplated by this Bond Purchase Agreement, the Indenture, the Official Statement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement. (b) The information in the Official Statement under the captions "THE PRIVATE PARTICIPANTS -- The Owner," "THE PROJECT," and "ABSENCE OF LITIGATION," does not on the date hereof containn any untrue statement of a material fact or omit to state a material fact necessary to make the statements relating to the Owner contained therein in light of the circumstances under which they were made not misleading. (c) The Owner has duly authorized and approved the Official Statement and has duly authorized and approved the execution, delivery of and the performance by the Owner of the obligations on its part contained in the Bond Purchase Agreement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement and has duly authorized. and approved the consummation of all the transactions contemplated by this Bond Purchase Agreement. (d) The Owner is not in breach of or default under any applicable law or administrative regulation of the State or of the United States that would, subsequent to the issuance of the Bonds, impair materially the performance of its obligations under the Loan Work -Out Agreement, this Bond Purchase Agreement, the Supplemental Regulatory Agreement, the FHA Note, the Mortgage or any applicable judgment or decree or any loan agreement, note, resolution, agreement or other instrument to which the Owner is a party or otherwise subject; and the execution and delivery of this Bond Purchase Agreement, the Loan Work-Out Agreement and the Supplemental Regulatory Agreement: and compliance with the provisions of each thereof will not conflict with or constitute a material breach of or default under any law, administrative regulation, -4- judgment, decree, loan agreement, note, resolution, agreement or other instrument- to which the Owner is a party or otherwise subject. (e) All approvals, consents and orders of any governmental authority, board or commission having jurisdiction over the Owner or the Project that would constitute a condition precedent to the performance by the Owner of its obligations hereunder and under the Loan Work -Out Agreement, the Supplemental Regulatory Agreement, the FHA Note or the Mortgage have been obtained. (f) The Owner has received no notice of any pending or threatened action, suit, proceeding, inquiry or investigation, at law or in equity, before any court, other board or body affecting the existence of the Owner or seeking to prohibit, restrain or enjoin the financing or the sale, issuance or delivery of the .Bonds, the refunding of the Prior Bonds or in any way contesting or affecting the validity or enforceability of this Bond Purchase Agreement, the Loan Work -Out Agreement, the FHA Note, the Mortgage or the Supplemental Regulatory Agreement, or contesting the execution and delivery of this Bond Purchase Agreement, the Loan Work -Out Agreement or the Supplemental Regulatory Agreement, wherein an unfavorable decision relating or finding would adversely affect the validity or enforceability of any of such documents. (g) The Indenture has been sabmitted to the Owner for examination, and the Owner acknowledges, by the execution of this Bond Purchase Agreement, that it has reviewed and approved the Indenture. (h) Neither the Issuer, nor the Underwriters nor any party on behalf of the foregoing, prior to the date of the default on the FHA Note relating to the Project encouraged the Owner to participate in the issuance of the Bonds and the redemption of the Prior Bonds as a 'means to facilitate the refinancing of the FHA Note. (4) The date on which the first missed payment on the FHA Note was due was August 1, 1991, and prior to July 31, 1991, the FHA Note was not in default. 0) The Owner represents that it has operated and managed the Project in a professional and appropriate manner and has taken all reasonable steps and used all available funds to continue to make all mortgage payments due under the Mortgage Loan, but due to economic conditions within the Clearwater, Florida area, beyond the control of the Owner, the market rents for the Project have produced insufficient revenues to cover the costs of operating and maintaining that Project and to pay the debt service required under the original terms of the Mortgage Loan, which resulted on August 1, 1991 in a default under the Mortgage Loan, subsequent to which the trustee for the Prior Bonds (the "Prior Trustee ") assigned the Mortgage Loan to HUD, and it is expected that HUD will pay mortgage insurance benefits to the Prior Trustee. Based on the Owner's projection for the rental apartment market place in the Clearwater, Florida area and the Project, the Project could not have reached a bre kk -even level of operations in the foreseeable future under the original terms of the Mortgage Loan. Section 7. Termination. The Underwriters may terminate their obligations hereunder by written notice to the Issuer and the Owner if at or prior to the Closing Date: (a) (i) Legislation shall have been enacted by the Congress, or recommended to the Congress for passage by the President of the United States or the U.S. Department of the Treasury or the Internal Revenue Service or any member of the United States Congress or favorably reported for passage to either House of the Congress by any Committee of such House to which such legislation has been referred for consideration, -5- or (ii) a decision shall have been rendered by a court established under Article III of the Constitution of the United States, or the United States Tax Court, or (iii) an order, ruling, regulation or communication (including a press release) shall have been issued by the Treasury Department of the United States or the Internal Revenue Service, in each case referred to in clauses (i), (ii) and (iii), with the purpose or effect, directly or indirectly, of including in gross income for federal income tax purposes interest to be received by any owners of the Bonds; (b) Legislation shall have been enacted, or action taken by the Securities and Exchange Commission, that, in the opinion of counsel to the Underwriters, has the effect of requiring the contemplated offering of the Bonds to be registered under the Securities Act of 1933, as amended, or the Indenture to be qualified under the Trust Indenture Act of 1939, as amended; (c) There shall have occurred any material adverse change in the business or affairs of the Owner or any material adverse change in the Project that, in the Underwriters' reasonable judgment, has any material adverse effect on the security for the Bonds; or (d) There shall have occurred after the date hereof a general suspension of trading in securities, or the declaration of a general banking moratorium by the United States of America, State of New York or State of Florida authorities, or any war involving the United States or other national calamity, the effect of which, in the Underwriters' . reasonable judgment, will adversely affect the marketability of the Bonds. Section 8. Conditions to Underwriters' Obligation. The Underwriters' obligation hereunder to place the Bonds shall be subject to the accuracy of the representations and warranties of the Issuer and the Owner herein, to the accuracy of statements to be made on behalf of the issuer and the Owner, to the performance by the Issuer and the Owner of their respective obligations hereunder, and to the following additional conditions: (a) All official or corporate action of the Issuer and the Owner (as, and if, applicable) relating to the Indenture, this Bond Purchase Agreement, the Supplemental Regulatory Agreement, the Loan Work -Out Agreement and the Bonds shall be in full force and effect and shall not have been amended, modified or supplemented, except as may have been agreed to by the Underwriters. (b) The Underwriters shall have received the unqualified approving legal opinion of Bryant, Miller and Olive, P.A., Tallahassee, Florida, Bond Counsel, dated the Closing Date with respect to the Bonds, or a reliance letter with respect thereto, together with a supplementary letter in substantially the form attached hereto as Exhibit A. (c) The Underwriters shall have received an opinion of counsel for the Owner dated the Closing Date in substantially the form attached as Exhibit B. (d) The Underwriters shall have received an opinion of the City Attorney of the Issuer, in substantially the form attached as Exhibit C hereto. (e) The Underwriters shall have received a certificate from the Owner in substantially the form attached as Exhibit D hereto. (f) The Underwriters shall have received an opinion of its counsel, Jones Hull Hill & White, A Professional Law Corporation, San Francisco, California, dated the Closing Date, as to such matters as the Underwriters may reasonably request. In rendering such opinion, such counsel may rely upon the opinions of Bond Counsel with respect to matters of State law. The Issuer and the Owner shall furnish to such counsel such documents as they may reasonably request for the purpose of enabling them to pass on such matters. (g) The Underwriters shall have received a certificate, dated the Closing Date and signed by an authorized officer of the Trustee, to the effect that (i) he or she is an authorized officer of the Trustee; (ii) the Indenture has been duly executed and delivered by the Trustee; (iii) the Trustee has all necessary corporate and trust powers required to carry out the trust created by the Indenture; and (iv) to the best of his or her knowledge, the acceptance by the Trustee of the duties and obligations of the Trustee under the Indenture and compliance with the provisions thereof will not conflict with or constitute a breach of or default under any law, administrative regulation, consent decree or any agreement or other instrument to which the Trustee is subject. (h) The Underwriters shall have received an opinion of counsel to the Trustee in substantially the form attached as Exhibit E hereto. (i) The Underwriters shall have received a certificate, dated the Closing Date and signed on behalf of the Issuer, to the effect that: (A) except as disclosed in the Official Statement under the caption "ABSENCE OF LITIGATION," no litigation or other proceedings are pending or, to the knowledge of the person or persons signing the certificate, threatened in any court or other tribunal of competent jurisdiction, state or federal, in any way (A) restraining or enjoining the issuance, sale or delivery of the Bonds, (B) questioning or affecting the validity of this Bond Purchase Agreement, the Bonds, the Indenture, the pledge to the Bondholders of any money or other security provided under the Indenture, the Loan Work -Out Agreement, the Supplemental Regulatory Agreement, or any other transaction referred to in the Official Statement, (C) questioning or affecting the validity of any of the proceedings for the authorization, sale, execution, issuance or delivery of the Bonds, (D) questioning or affecting the organization or existence of the Issuer or the title to any office of the executive officers thereof or (E) questioning or affecting the power and authority of the Issuer to issue the Bonds, or to execute this Bond Purchase Agreement, the Indenture, the Supplemental Regulatory Agreement, the Loan Work -Out Agreement or the Official Statement; (B) the information in the Official Statement and the Placement Memorandum regarding the Issuer under the captions "THE ISSUER" and "ABSENCE OF LITIGATION" does not contain any untrue statement of a material fact or omit to state any material fact necessary in order to make the statements contained therein, in light of the circumstances under which they were made, not misleading; and (C) the Issuer has complied with and satisfied all the conditions on its part to be performed or satisfied hereunder at or prior to the Closing Date and the representations and warranties of the Issuer contained herein are true, complete and correct as of the Closing Date. 0) The Underwriters shall have received arbitrage certifications by the Issuer and the Owner in form and substance satisfactory to Bond Counsel. .7. fi W The Underwriters shall have received a certificate dated the Closing Date and signed by an authorized officer of the Trustee, with respect to the sources and uses of funds deposited under the Indenture. (1) The Underwriters shall have received an opinion 'of Bond Counsel to the effect that the Prior Bonds have been refunded or defeased and are no longer entitled to any lien on the assets of the Issuer or the Owner. (m) Standard & Poor's Corporation shall have issued a rating of "AAA" on the Bonds and no action shall have been taken, discussed or proposed with a view to the suspension or withdrawal of such rating as of the Closing Date. (n) At the Closing Date, the Underwriters shall receive an opinion from counsel to each institution providing an Investment Agreement, and counsel to any guarantor thereof, to the effect that the Investment Agreement, or the guaranty, as the case may be, constitutes a legal, valid and binding obligation of said institution, enforceable in accordance with its terms, except as may be limited by applicable reorganization, insolvency, liquidation, readjustment of debt or similar laws affecting the enforcement of creditors' rights generally and by general principles of equity. (o) At the Closing Date, the Purchaser shall receive satisfactory evidence that the Trustee has received the Owner Deposit and the Collateral Deposit (each as defined in the Indenture) in an amount and in such form that is satisfactory to the Underwriters and to satisfy the rating requirement of Standard & Poor's Corporation, with respect to the Bonds. Section 9. Covenants. The Issuer and the Owner covenant and agree with the Underwriters as follows: (a) If between the date of this Bond Purchase Agreement and the date 90 days following the Closing Date an event occurs that is known to the Issuer or the Owner that would cause the Official Statement to contain an untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements therein in light of the circumstances under which they were made, not misleading, the Issuer or the Owner, as the case may be, shall notify the Underwriters, and if in the opinion of the Issuer or the Underwriters, such event requires an amendment or supplement to the Official Statement, the Issuer will amend or supplement the Official Statement in a form and in a manner approved by the Issuer and the Underwriters; provided however, that if such event shall occur on or prior to the Closing Date, the Underwriters in their sole discretion shall have the right to terminate the Underwriters' obligations hereunder by written notice to the Issuer and the Owner, and the Underwriters shall be under no obligation to purchase and pay for the Bonds. (b) To the extent required by the Indenture, the Supplemental Regulatory Agreement or the Loan Work -Out Agreement, the Owner and the Issuer each shall take all necessary actions to cause the Bonds to comply with the provisions of the laws and regulations of the State pursuant to which the Bonds are issued and of the Code, as that terns is defined in the Indenture, and will not take any action, or permit any action within its control to be taken, in violation of such provisions or that would cause interest on the Bonds to be included in gross income for federal income tax purposes. Section 10, Payment to Underwriters and Payment of Expenses. The Underwriters shall pay their own expenses; the fees and expenses of their counsel; the initial rating agency fees; the cost of printing the Bonds, the Preliminary Official Statement and the -K. Official Statement; takedown and concession for selling the Bonds (portions of which,-to the extent the Bonds are placed by the Underwriters, will be retained by the Underwriters as part of their compensation) and certain additional expenditures, estimates of which are all more particularly set forth in Schedule II hereof. The Owner shall pay or cause to be paid from the Costs of Issuance Fund (established under the Indenture), a payment to the Underwriters of $146,817, the fees and expenses of Bond Counsel; the fees and expenses of Financial Advisor to the Issuer; the initial Trustee fees and expenses; and the fees and expenses of counsel to the Trustee; estimates of which are set forth in Schedule II hereof. Section 11. Survival of Covenants and Representations. The respective agreements, covenants, representations, warranties and other statements of the Issuer, the Underwriters, and the Owner and of their respective officers set forth in or made pursuant to this Bond Purchase Agreement will remain in full force and effect, notwithstanding any investigation made by or on behalf of any party hereto, and shall survive the delivery of and payment for the Bonds. Section 12. Notices. Any notice or other communication to be given to the Issuer under this Bond Purchase Agreement may be given by delivering the same in writing to the Issuer at its address set forth above, and any notice or other communication to the Owner may be given by delivering the same in writing to the Owner at its address set forth above with a copy to: Drew Gardens Associates, Ltd., 6601 West Broad Street, Richmond, Virginia 23230, Attention: Corporal,.; Secretary. Any notice or other communication to be given to the Underwriters under this Bond Purchase Agreement may be given by delivering the same in writing to Banc One Capital Corporation, 90 North High Street, Columbus, Ohio 43215, Attention: James F. Croft, 'Mice President. Section 13. Governing Lave. This Bond Purchase Agreement shall be governed by the laws of the State. Section 14. Indemnification and Contribution. (a) To the fullest extent permitted by applicable law, the Owner and the undersigned General Partner of the Owner (jointly and severally) (each, an "Indemnifying Party" and collectively, the "Indemnifying Parties ") agree to indemnify and hold harmless the Issuer, the Trustee and the Underwriters and the additional persons described in subsection (b) hereof (each, an "Indemnified Party" and collectively, the "Indemnified Parties ") against any and all losses, damages, expenses (including legal and other fees and expenses), liabilities or claims (or actions in respect thereof), joint or several, to which the Indemnified Parties, or any of them, may become subject under the federal or state securities laws or any other statutory law or at common law or otherwise, arising out of or based upon or in any way relating to: (i) the redemption of the Prior Bonds and/or the issuance, sale or delivery of the Bonds to the extent involving the redemption of the Prior Bonds, including, without limitation, any claim against any Indemnified Party by MBIA or any other person relating to the application of the residual funds held by the Prior Trustee under the Prior Indenture; (ii) any untrue statement or misleading statement or alleged untrue statement or alleged misleading statement of a material fact contained in the Preliminary Official Statement or the Official Statement for the Prior Bonds or in the Preliminary Official Statement or the Official Statement for the Bonds relating to the matters described in paragraph (i) above, the Owner, the Project or the defaulted Mortgage Loan or any omission or alleged omission from the -9- Preliminary Official Statement or the Official Statement for the Prior Bonds'or from the Preliminary Official Statement or the Official Statement for the Bonds of any material fact relating in any way to the matters described in paragraph (i) above, the Owner, the Project or the defaulted Mortgage Loan, necessary to be stated therein in order to make the statements made therein, in light of the circumstances under which they were made, not misleading; or (iii) claims against any Indemnified Party by the United States Department of Housing and Urban Development ( "HUD ") or any authorized agent or employee thereof asserting a right to indemnification (other than pursuant to a contractual arrangement) and/or defense against any loss or expense allegedly incurred by HUD as a result of any claim against HUD or such agent or employee relating to the redemption of the Prior Bonds and/or the issuance, sale or delivery of the Bonds for the purpose of redeeming the Prior Bonds or the defaulted Mortgage Loan. It is the intention of the parties that such indemnification shall cover liabilities, losses, damages, costs, expenses and fees (including reasonable legal and other fees and expenses) and claims (or actions in respect thereof) arising out of the negligence of any Indemnified Party and, to the fullest extent permitted by applicable law, that such indemnification shall also cover liabilities, losses, damages, costs, expenses and fees (including reasonable legal and other fees and expenses) and claims (or actions in respect thereof) arising out of conduct by the Indemnifying Parties which is deemed to involve "scienter" within the meaning of Rule 10b -5 under the Securities Exchange Act of 1934, as amended (the "1934 Act "), but shall not otherwise cover conduct deemed to involve the gross negligence or willful misconduct of any Indemnified Party. This indemnification is in addition to any liability which each Indemnifying Party may otherwise have. (b) The indemnity provided under this Section 14 shall extend upon the same terms and conditions to each officer, commissioner, employee, agent and attorney of the Issuer, the Trustee and the Underwriters, Bond Counsel, and each person, if any, who controls the Issuer, the Trustee or the Underwriters within the meaning of Section 15 of the Securities Act of 1933, as amended (the "1933 Act ") or Section 20 of the 1934 Act. Such indemnity shall also extend, without limitation, to any and all expenses (subject to paragraph. (c) below) whatsoever reasonably incurred by any Indemnified Party in connection with investigating, preparing for or defending against, or providing evidence, producing documents or taking any other reasonable action in respect of, any such loss, damage, expense, liability or claim (or action in respect thereof), whether or not resulting in any liability, and shall include any loss to the extent of the aggregate amount paid in settlement of any litigation, commenced or threatened, or of any claim whatsoever as set forth herein if such settlement is effected with the written consent of each Indemnifying Party. (c) Within a reasonable time after an Indemnified Party under paragraphs (a) and (b) of this Section 14 shall have been served with the summons or other first legal process or shall have received written notice of the threat of a claim in respect of which an indemnity may be claimed hereunder, such Indemnified Party shall, if a claim for indemnity in respect thereof is to be made against any Indemnifying Party under this Section 14, notify each Indemnifying Party from whom indemnity is sought in writing of the commencement thereof; but the omission so to notify an Indemnifying Party shall not relieve that Indemnifying Party from any liability that it may have to any Indemnified Party other than pursuant to paragraphs (a) and (b) of this Section 14 and the omission so to notify an Indemnifying Party by the Issuer shall have no effect on the W. indemnification of the Issuer. The Indemnifying Party from which indemnity is sought shall be entitled to participate at its own expense in the defense, and if the Indemnifying Party so elects within a reasonable time after receipt of such notice, or all Indemnified Parties seeking indemnification in such notice so direct, the Indemnifying Party shall assume the defense of any suit brought to enforce any such claim, and in either such case, such defense shall be conducted by counsel chosen promptly by the Indemnifying Party and reasonably satisfactory to the Indemnified Party ( "Litigation Counsel "); provided, however, that if the defendants in any such action include such an Indemnified Party and one or more Indemnifying Parties or include more than one Indemnified Party, and any such Indemnified Party shall have been advised by Litigation Counsel that there may be legal defenses available to such Indemnified Party which are different from or additional to those available to one or more of the Indemnifying Parties or another defendant Indemnified Party, and which in the reasonable opinion of Litigation Counsel are sufficient to make it undesirable for the same counsel to represent such Indemnified Party and one or more of the Indemnifying Parties and/or another defendant Indemnified Party, such Indemnified Party shall have the right to employ separate counsel in such action (and the Indemnifying Party or Indemnifying Parties shall not be entitled to assume the defense thereof on behalf of such Indemnified Party), and in such event the reasonable fees and expenses of such counsel shall be borne by the Indemnifying Parties. Nothing contained in this paragraph (c) shall preclude any Indemnified Party, at its own expense, from retaining additional counsel to represent such party in any action with respect to which indemnity may be sought from the one or more of the Indemnifying Parties hereunder. (d) In order to provide for just and equitable contribution in circumstances in which the indemnity provided for in paragraphs (a), (b) and (c) of this Section 14 is for any reason held to be unavailable from one or more of the Indemnifying Parties, or is inadequate, or the Issuer, the Trustee, the Underwriters or the Owner or undersigned General Partner of the Owner, or any person described in subsection 14(b) hereof, has incurred any loss, damage, expense (including legal and other fees and expenses), liability or claim (or any action in respect thereof) of the nature described in subsection (a) above, then the Owner and the undersigned General Partner (jointly and severally) agree to contribute to any such loss, damage, expense (including legal and other fees and expenses), liability or claim (or action in respect thereof) in proportion to the net present value of the savings resulting from the refunding (computed at a discount rate equal to the yield on the Bonds) and the Underwriters agree to contribute in proportion to its fee as set forth in Schedule II of this Bond Purchase Agreement; provided, however, that the total contribution of the Underwriters hereunder shall not exceed the fee of the Underwriters set forth in Schedule II of this Bond Purchase Agreement. Neither the Issuer, the Trustee, nor any other persons described in paragraph 14(b) above shall have any obligation to contribute. The contribution provided by this paragraph (d) shall also extend, without limitation, to any and all expenses whatsoever reasonably incurred in connection with investigating, preparing for or defending against, or providing evidence, producing documents or taking any other reasonable action in respect of, any such loss, damage, expense, liability or claim (or action in respect thereof), whether or not resulting in any liability, and shall include any loss to the extent of the aggregate amount paid in settlement of any litigation, commenced or threatened, or of any claim whatsoever as set forth herein if such settlement is effected with the written consent of the party from whom contribution is sought hereunder. For purposes of this paragraph (d) each officer, commissioner, employee, agent or attorney of the Issuer, the Trustee, the Underwriters or the Owner or any of the undersigned General Partner and each person, if any, who controls any of the foregoing within the meaning of Section 15 of the 1933 Act or Section 20 of the 1934 Act shall, under the same circumstances, have the same rights to contribution as do the Issuer, the Trustee, the Underwriters and the Owner and each of the undersigned General Partner hereunder. Within a reasonable time after a person entitled to contribution under this paragraph (d) of Section 14 shall have been served with the summons or other first legal process or shall have received written notice of the threat of a claim in respect of which contribution may be sought hereunder, such person shall, if a claim for contribution is to be made against the foregoing contributing parties under this paragraph (d), notify the contributing parties in writing of the commencement thereof; but the omission so to notify the contributing parties shall not relieve the contributing parties from any liability that they or any of them may have other than pursuant to this paragraph (d); provided, however, that any notice given by any Indemnified Party for purposes of, and as provided in, paragraph (c) of this Section 14 shall constitute notice for purposes of this paragraph (d). (e) The indemnity provided by Sections 14(a) through 14(c) hereof shall be in addition to any other liability that each Indemnifying Party may have, and the contribution provided in Section 14(d) hereof shall be in addition to any other liability which the Owner and each of the undersigned General Partner and the Underwriters may otherwise have hereunder, at common law or otherwise, and is provided solely for the benefit of the persons specified above, as applicable, and each commissioner, officer, employee, agent, attorney and controlling person referred to therein, and their respective successors, assigns and legal representatives, and no other person shall acquire or have any right under or by virtue of such provisions of this agreement. Section 15. Effectiveness. This Bond Purchase Agreement shall become effective upon the execution of the acceptance hereof by the Issuer and the Owner. Section 16. HUD and FHA Requirements to Control. Notwithstanding anything in this Bond Purchase Agreement to the contrary, the provisions of this Bond Purchase Agreement are subject and subordinate to the National Housing Act, all applicable HUD insurance (and Section 8, if applicable) regulations and related administrative requirements and the Mortgage Loan Documents, and all applicable FHA regulations and related administrative requirements in effect as of the date hereof, and in the event of any conflict between the provisions of this Bond Purchase Agreement and the provisions of the National Housing Act, any applicable HUD regulations, related administrative requirements and the Mortgage Loan Documents, and any applicable FHA regulations and related administrative requirements, the said National Housing Act, HUD regulations, related administrative requirements and Mortgage Loan Documents, and the said FHA regulations and related administrative requirements shall be controlling in all respects. Section 17. Counterparts. This Bond Purchase Agreement may be executed in two or more counterparts, each of which shall be deemed the same document. -12- If the foregoing is in accordance with your understanding of our agreement, please sign and return to us the enclosed copy of this Bond Purchase Agreement, whereupon it will become a binding agreement among the Underwriters, the Issuer and the Owner in accordance with its terms. Very truly yours, BANC ONE CAPITAL CORPORATION N]EWMAN AND ASSOCIATES, INC. By: BANC ONE CAPITAL CORPORATION By: Title: The foregoing is confirmed and accepted as of the date first above written. CITY OF CLEARWATER, FLORIDA By: Title: DREW GARDENS ASSOCIATES, LTD., z A FLORIDA LIMITED PARTNERSHIP By: Reynolds Metals Development Company By: Title: _ 13 SCHEDULEI MATURITIES, PRINCIPAL AMOUNTS AND INTEREST RATES Maturity Principal Interest I2� �� $3,425,000 6.50% October 1, 2025 -14- mm- 100% t J. ,.r r a SCHEDULE II DISCLOSURE STATEMENT The undersigned, as Underwriters, propose to negotiate with City of Clearwater, Florida, (the City) for the sale of $3,425,000 principal amount of its Mortgage Revenue Refunding Bonds, Series 1992A (FHA Insured Mortgage Loan -- Drew Gardens Apartments Project) (the "Bonds "), to be completed on this date. Prior to the award of the Bonds, the following information is hereby furnished to the City: 1. Set forth is an itemized list of the nature and estimated amounts of expenses to be incurred by the Underwriters and the Owner in connection with the issuance of the Bonds: ESTIMATED COST OF ISSUANCE Payment to Underwriters* $146,817 Bond Counsel Fees and Expenses 38,000 Issuer's Fees and Expenses 10,)00 Issuer's Financial Advisor Fees and Expenses 12,600 Initial Trustee Fees and Expenses including Trustee Counsel 5.000 TOTAL $210,417 'From such amount (which includes the Underwriters' Management Fee and Underwriting Fee), the Underwriters will pay the following additional costs of issuing and selling the Bonds (to the extent that such additional costs vary from the estimates thereof, the Underwriters will be responsible to cover such variance from their - Management and Underwriting Fees): E)(PENSES TO BE PAID BY UNDERWRITERS Underwriters' Counsel Fees and Expenses $25,000 30,000 Owner's Counsel Fees and Expenses Initial Rating Agency Fees and Expenses (Estimate) 12,500 Preliminary Official Statement and Official Statement 5,000 Printing Costs (Estimate) 3 000 Printing of Bonds (Estimate) 2,854 Federal Funds Charge (Estimate) 3,000 Miscellaneous Expenses (Estimate) 750 CUSIP, MSRB, PSA Expenses (Estimate) 1,713 Bond Clearance (Estimate) 3,000 Title Policy Fees (Estimate) $86,817 1WAL 2. Set forth below are the names, addresses and estimated amounts of compensation of all "finders" as defined in Section 218.386, Florida Statutes: NONE 15- 3. The amount of the underwriting spread expected to be realized by the Underwriters is $146,817 ($42.87 per Bond) which includes the following: PerBond Management Fee $60,000 $17.50 Expenses 86,817 25.35 4. The management fee to be charged by the Underwriters is $60,000 ($17.50 per Bond). 5. Set forth below are all other fees, bonuses and other compensation estimated to be paid by the Underwriters on behalf of the City from Bond proceeds in connection with the Bond issue to all persons not regularly employed or retained by them. All amounts listed as expenses to be paid by Underwriters under paragraph 1. 6. The names and addresses of the Underwriters connected with the Bonds are set forth below: Banc One Capital Corporation 90 North High Street Columbus, Ohio 43215 Newman and Associates, Inc. 9428 Baymeadows Road, Suite 240 Jacksonville, FL 32256 7. The City is proposing to issue $3,425,000 of debt or obligations for the purpose of refunding certain revenue bonds currently outstanding and to pay costs of issuance of the Bonds. This debt or obligation is expected to be repaid over a period of thirty -two and one half years (32.5) years. At a forecasted interest rate of 6.50 %, total interest paid over the life of the debt or obligation will be $5,026,667. 8. The source of repayment or security for this proposal is the payments on the Mortgage Loan for the Project, which Mortgage Loan is insured by the Federal Housing Administration, an agency of the federal government. Authorizing this debt will result in no funds of the Issuer being available to meet debt service on the Bonds nor will it result in any money otherwise available not to be available to meet any operating expenses of the Issuer. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK.] «1h- EXHIBIT A [LETTERHEAD OF BOND COUNSEL] [Closing Date] Banc One Capital Corporation Columbus, Ohio Newman and Associates, Inc. Jacksonville, Florida City of Clearwater Clearwater, Florida $3,425,000 CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992A (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) Ladies and Gentlemen: We have acted as Bond Counsel in connection with the authorization and issuance of the above - captioned Bonds (the "Bonds ") by the City of Clearwater, Florida (the "Issuer "). In our capacity as Bond Counsel, we have reviewed the statements set forth in the Official Statement of the Issuer relating to the Bonds (the "Official Statement ") under the captions "INTRODUCTION," "THE BONDS," "THE INDENTURE," "TI'!E SUPPLEMENTAL REGULATORY AGREEMENT," "THE LOAN 'WORK -OUT AGREEMENT," "TAX EXEMPTION" and "LEGAL MATTERS ". Insofar as such statements constitute summaries of certain provisions of the documents, instruments and matters referred to therein, we are of the opinion that the information called for with respect to such documents, instruments and matters is fairly presented. The limitations inherent in our review are such, however, that we assume no responsibility for the accuracy, completeness or fairness of the statements contained in the Official Statement except for those made under the captions set forth above. The proceedings to redeem the Issuer's $6,450,000 aggregate original principal amount of the Issuer's Mortgage Revenue Bonds, Series 1933 (FHA Insured Mortgage Loan -- Drew Gardens Apartments Project ) (the "Prior Bonds ") without premium on September 1, 1992, are permitted under the trust indenture securing the Prior Bonds (the "Prior Indenture "), and the lien of the Prior Indenture upon the trust estate established thereunder has been released. You may rely upon our opinion of even date herewith addressed to the Issuer with respect to the Bonds as if such opinion had been addressed to you. Very truly yours, A -1 n EXH BrF B [FORM OF OWNER'S COUNSEL OPINION] [Closing Date] k Banc One Capital Corporation Columbus, Ohio f' City of Clearwater Clearwater, Florida Jones Hall Hill & White, A Professional Law Corporation'. San Francisco, California Bank One, Columbus, NA, { as Trustee Columbus, Ohio $3,425,000 CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992A (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) Ladies and Gentlemen: We have acted as counsel to Drew Gardens Associates, Ltd., a Florida limited partnership (the "Owner "), in connection with its acquiring, constructing, improving and equipping a 180 -unit multifamily residential rental housing facility project located in Clearwater, Florida (the "Project "). In connection with the issuance on this date by the City of Clearwater, Florida (the "Issuer "), of the above - referenced Bonds (the "Bonds "), we have examined the following: the Owner's Partnership Agreement, dated the Trust Indenture (the "Indenture "), dated as of August 1, "Trustee the Issuer and Bank One, Columbus, NA, as Trustee (the t the Loan Work -Out Agreement (the "Loan Work -Out Agreement "), dated as of August 1, 1992, between the Issuer, the Owner and the Trustee; the Supplemental Regulatory Agreement dated as of August 1, 1992, among the Issuer, the Owner and the Trustee (the "Supplemental Regulatory Agreement "); the Mortgage Note (the "Note "), dated October s amended on amended on August , 1992, and the Mortgage dated October 12, August _, 1992 (the "Mortgage "); the Bond Purchase Agreement (the "Bond Purchase Agreement) dated August 18, 1992, by and among the Issuer, the Owner and Banc One Capital Corporation and Newman and Associates, Inc. (collectively, the "Underwriters "); and the Official Statement relating to the Bonds (the "Official Statement "). The Note and the Mortgage are hereinafter referred to for convenience as the Security Documents. We have investigated such matters of law and the aforesaid documents necessary F' 1 to render the opinions set forth below. In rendering such opinion we have relied upon the foregoing documents with respect to the accuracy and completeness of the factual matters contained herein. In our examination of such documents we have assumed the genuineness of signatures on original documents (except as otherwise opined as to execution) and the conformity to original documents of all copies submitted to us as B -1 certified, conformed, or photographic copies and as to certificates of public officials, we have assumed the same to have been properly given and to be accurate. The opinions given herein are limited to the laws of the United States and the State of Florida and no opinion is expressed with respect to the laws of any other jurisdiction or state with respect to the effect of any such laws or the matters dealt with herein. On the basis of the foregoing, we are of the opinion that: (1) The Owner is a limited partnership duly formed and validly existing under the laws of the State of Florida, and all requirements for its legal formation in accordance with the provisions of the laws of the State of Florida, have been complied with, and the Owner has full power and authority to conduct its business as presently conducted, to own its properties in its name, and to consummate the transactions contemplated by the Bond Purchase Agreement, the Indenture, the Loan Work -Out Agreement, the Supplemental Regulatory Agreement and the Security Documents; (2) The execution, delivery and due performance of the Security Documents, the Supplemental Regulatory Agreement, the Loan Work -Out Agreement and the Bond Purchase Agreement have been duly authorized by all necessary action on the part of the Owner and have been duly executed and delivered by the Owner and the Security Documents constitute legal, valid and binding agreements or obligations of the Owner enforceable against the Owner in accordance with their respective terms except as enforcement may be limited by bankruptcy, insolvency, or similar laws affecting the enforcement of creditors' rights generally; (3) The Note has been finally endorsed by FHA for Mortgage Insurance; (4) The Owner has a fee simple interest in the real property upon which the Project is 'located, subject to the Security Documents. [Except as described in the policy of title insurance issued by to on the date hereof (and to which we render no opinion)], there is no contract or other obligation providing for or requiring the Owner to convey the Owner's interest in the Project or any estate or interest therein to any party other than as provided in the Security Documents, and no party other than the Issuer and the Trustee under the Security Documents has any beneficial or equitable right, title or interest in the Project; (5) The execution, delivery and due performance of the Security Documents by the Owner and compliance by the Owner with all the provisions thereof, (a) is not and will not be in contravention of any law, ordinance or governmental rule or regulation currently applicable to the Owner, (b) is not and will not conflict with, or constitute, on the part of the Owner, a breach or default under the provisions of its partnership agreement and certificate of limited partnership or of any indenture, mortgage, deed of trust, note, or other instrument or agreement to which the Owner is a party or by which it is bound, or of any statute or license or judgment, decree or order of any court, agency or body having jurisdiction over the Owner or any of its activities or properties, and (c) is not and will not result in the creation of any lien or encumbrance upon any property of the Owner (other than the lien contemplated by the Indenture and the Security Documents); (6) The information contained in the Official Statement and the Placement Memorandum under the captions "PRIVATE PARTICIPANTS- -The Owner" and "THE PROJECT" presents a true and accurate statement with respect to the information purported to be summarized therein; B -2 S (7) All consents, approvals, authorizations and orders of, or filing, registration j or qualification with, any governmental or regulatory authority which are required to be obtained by the Owner for the consummation of the transactions contemplated by the Supplemental Regulatory Agreement, the Loan Work -Out Agreement and the Security Documents have been duly and validly obtained or performed and are in full force and effect; (S) There is no action, suit, proceeding or investigation at law or in equity before or by any court, arbitration board or tribunal, public board or body pending or In- eatened against or affecting the Owner, 'or, to the best of our knowledge, any basis therefor, wherein an unfavorable decision, ruling or finding (i) would restrain or enjoin or question the execution or delivery of the Supplemental Regulatory Agreement, the Indenture, the Loan Work -Out Agreement, the Security Documents or the Bond Purchase Agreement or (ii) could adversely affect the transactions contemplated by the Supplemental Regulatory Agreement, the Bond Purchase Agreement, the Indenture, the Loan Work -Out Agreement and the Security Documents or any other agreement or instrument to which the Owner is a party and which is used or contemplated for use in consummation of the transactions contemplated by the Supplemental Regulatory Agreement, the Bond Purchase Agreement, the Indenture, the Loan Work -Out Agreement or the Security Documents; and On the basis of information developed in the course of our representation of the Owner, no facts have come to our attention that would lead us to believe that the Official Statement contains an untrue statement of a material fact or omits to state a material fact necessary to be stated therein in order to make the statements made therein, in the light of the circumstances under which they were made, not misleading. Very truly yours, B•; EXHIBIT C [LETTERHEAD OF COUNSEL TO THE ISSUER] [Closing Date] City of Clearwater Clearwater, Florida Bank One, Columbus, NA, as Trustee Columbus, Ohio Bryant, Miller and Olive, P.A. Tallahassee, Florida $3,425,000 CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992A (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) Ladies and Gentlemen: I have acted as counsel to the City of Clearwater, Florida, (the "Issuer ") in connection with the issuance of its $3,425,000 Mortgage Revenue Refunding Bonds, Series 1992A (FICA Insured Mortgage Loan -- Drew Gardens Apartments Project) (the "Bonds "). In so acting, I have examined: (i) Ordinance No. 5256 -92 (the "Ordinance') adopted by the City Commission of City of Clearwater, Florida on August 13, 1992, authorizing the issuance and sale of the Bonds; (ii) Trust Indenture between the Issuer and Bank One, Columbus, NA, Columbus, Ohio (the "Trustee') dated as of August 1, 1992 (the "Indenture"); (iii) Loan Work -Out Agreement among the Issuer, the Trustee, and Drew Gardens Associates, Ltd., a Florida limited partnership (the "Owner "), dated as of August 1, 1992 (the "Loan Work -Out Agreement "); (iv) Supplemental Regulatory Agreement as to Tax Exemption dated September 1, 1983, among the Issuer, the Owner and the Prior Trustee named therein, (the "Supplemental Regulatory Agreement "); (v) executed financing statements; (vi) an executed and authenticated Bond; (vii) an Official Statement dated August 13, 1992, relating to the Bonds (the "Official Statement "); (viii) a Bond Purchase Agreement dated August 13 1992 (the "Bond Purchase Agreement"), by and among Banc One Capital Corporation and Newman and Associates, Inc. (collectively, the "Underwriters "), the City and the Owner; C -1 (ix) relevant provisions of the Constitution and laws of the State of Florida; and (x) other proofs submitted to us relative to the issuance and sale of the Bonds. Unless the context clearly indicates otherwise, each capitalized term used in this opinion letter shall have the same meaning as set forth in the Indenture. As to questions of fact material to my opinion I have relied upon representations of the City and the Owner contained in the Indenture and the Loan Work -Out Agreement, the certified proceedings and other certifications of public officials furnished to me, without undertaking to verify the same by independent investigation. I am qualified to practice law in the State of Florida, and I do not purport to be experts on, or to express any opinion herein concerning, any law other than the law of the State of Florida and the Federal law of the United States of America. I have not examined, and express no opinion as to, the existence of or title to real or personal property and I express no opinion as to the creation, validity or priority of any lien upon, assignment of, pledge of, or security interest in, real or personal property. I have assumed the authenticity of all documents submitted to me as originals, the genuineness of all signatures, the conformity to original documents of all documents submitted to me as certified or photostatic copies and the authenticity of the originals of such latter documents. Reference is made to the opinion of even date herewith of Byrne, Costello & Pickard, P.C., counsel to the Owner, with respect to certain matters pertaining to the Owner and to the documents executed and delivered by the Owner. I express no opinion as to any of the matters set forth in such opinion. Based on my examination and subject to the foregoing, and having regard to legal questions which I deem relevant, I am of the opinion, as of the date hereof and under existing law, as follows: 1. The Issuer is a duly organized body politic and corporate and a municipal corporation of the State of Florida, validly existing under the Constitution and statutes of the State of Florida. The Issuer has all necessary power and authority (i) to enter into, perform and consummate all transactions contemplated by the Indenture, the Loan Work -Out Agreement, the Official Statement, the Supplemental Regulatory Agreement and the Bond Purchase Agreement; and (ii) to execute and deliver the documents and instruments to be executed and delivered by it in connection with the issuance and sale of the Bonds. 2, The Issuer has complied with all of the requirements of Florida law with respect to the authorization, execution and delivery of the documents and instruments referred to above. 3. The Loan Work -Out Agreement, the Indenture, the Supplemental Regulator Agreement and the Bond Purchase Agreement have been duly executed and delivered by the Issuer, and assuming the validly authorized execution and delivery thereof by each party thereto in addition to the Issuer, and are valid and binding limited obligations of the Issuer in accordance with their respective terms. (' 4. No additional or further approval, consent or authorization of any governmental or public agency or authority not already obtained is required by the Issuer in connection with the refinancing of the Project or entering into and performing its obligations under the Loan Work -Out Agreement, the Indenture, the Supplemental Regulatory Agreement and the Bond Purchase Agreement. 5. The execution, delivery and performance by the Issuer of the Loan Work - Out Agreement, the Indenture, the Supplemental Regulatory Agreement and the Bond Purchase Agreement will not violate any provision of Federal or Florida law or any applicable order or regulation of any court or of any public or governmental agency or authority of the State of Florida, and will not conflict with, or result in the breach of any of the provisions of, or constitute a default under the provisions of any law applicable to the powers and functions of the Issuer, or, to the best of my knowledge, any indenture, mortgage, deed of trust or other agreement or instrument to which the Issuer is a party or by which it or its properties are bound. 6. To the best of my knowledge after diligent inquiry of representatives of the Issuer but without having made any further investigation, there is no action, suit, proceeding, inquiry or investigation at law or in equity, before or by any judicial or administrative court or agency, pending or, threatened against or affecting the Issuer or its property wherein an unfavorable decision, ruling or finding would adversely affect the validity or enforceability of the Loan Work -Out Agreement, the Indenture, the Supplemental Regulatory Agreement or the Bond Purchase Agreement in accordance with their respective terms, or in any way relating to, affecting the issuance, sale, execution or delivery of the Bonds or of any of the proceedings had or actions taken leading up to the execution and delivery of the same or the Loan Work -Out Agreement, the Indenture, the Supplemental Regulatory Agreement , the Official Statement or Bond Purchase Agreement or the acquisition and rehabilitation or operation of the Project for which the Bonds are being issued, or the payment of interest on or principal of the Bonds, or otherwise affecting or questioning the validity of the Bonds. 7. All resolutions, ordinances and actions of the Issuer relating to the above - mentioned documents and all related proceedings comply with all applicable statutes governing the Issuer and all rules and regulations of the Issuer. 8. None of the proceedings had or actions taken with regard to any of the documents mentioned herein, including without implied limitation the proceedings relating to the execution, issuance, sale and delivery of the Bonds, has or have been repealed, rescinded or revoked, and all such proceedings and actions remain in full force and effect on the date hereof. 9. The execution and delivery of the Official Statement by the Issuer and its distribution have been authorized by the Issuer. After reasonable investigation, I have no reason to believe that the information contained in the Official Statement under the captions "THE ISSUER" and "ABSENCE OF LITIGATION" is not complete and accurate or contains any untrue statement of a material fact or omits to state any material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they are made, not misleading. It is to be understood that the rights of any holder of the Bonds and the enforceability of the Indenture, the Loan Work -Out Agreement, the Supplemental Regulatory Agreement and the Bond Purchase Agreement may be subject to (a) bankruptcy, insolvency, reorganization, moratorium and other similar laws heretofore or hereafter in effect affecting creditors' rights, to the extent constitutionally applicable, C" -4 (b) the valid exercise of the constitutional powers of the United Sates of America and- of the sovereign police and taxing powers of state or other governmental units having jurisdiction, and (c) the exercise of judicial discretion in accordance with general principles of equity (whether applied in a court of law or a court of equity). In addition, enforceability of the provisions of the Bond Purchase Agreement and the Loan Work -Out Agreement pertaining to indemnification may also be limited by applicable securities laws and public policy. I hereby consent to the reference to me on the front cover and under the caption "LEGAL MATTERS" in the Official Statement. This opinion may be relied upon by Bond Counsel in connection with an opinion of such counsel relating to the Bonds. Very truly yours, C-4 • f EXHIBIT D CLOSING CERTIFICATE OF OWNER $3,425,000 CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992A (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) Drew Gardens Associates, Ltd., a Florida limited partnership (the "Owner "), hereby certifies, represents and warrants to the Underwriters named in the Bond Purchase Agreement described below, as follows: (1) The representations and warranties of the Owner contained in the Bond Purchase Agreement executed by the Owner, the City of Clearwater, Florida (the "Issuer "), and the Underwriters named therein (the "Bond Purchase Agreement ") are true and correct as of the date hereof. (2) The Owner has complied with all agreements and satisfied all conditions contained in the Bond Purchase Agreement on its part to be performed or satisfied prior to or on the date hereof. (3) There has not been any material adverse change in the financial position or results of operations of the Owner or its general partner in their businesses or any material adverse change affecting the Owner's project in Clearwater, Florida (the "Project "), that would impair the ability of the Owner to carry out the Project as contemplated by the Official Statement (the "Official Statement ") relating to the issuance of the above - captioned Bonds (the "Bonds "), the proceeds from the sale of which will be used to provide refinancing for the Project. (4) To the best of the knowledge of the undersigned, the statements and information contained in the Official Statement with respect to the Owner and the Project do not contain an untrue statement of a material fact or fail to state a material fact necessary in order to make the statements made therein not misleading as of the date hereof (the "Closing Date'). (5) Except as described in the Official Statement there is no action, suit, proceeding, inquiry or investigation, at law or in equity, or before or by any court, public board or body, pending or, to the best knowledge of the Owner after due inquiry, threatened against or affecting the Owner nor, to the best knowledge of the Owner, is there any basis therefor, wherein an unfavorable decision, ruling or finding would, in any way, adversely affect the transactions contemplated by the Official Statement, or that, in any way, would adversely affect the operation of the Project or that might result in any material adverse change in the business, operations, properties, assets, liabilities or condition (financial or other) of the Owner and its related companies or that affects the information contained in the Official Statement. (6) The expenses associated with the Project and the Owner, as outlined in the audited and unaudited financial statements presented to the Underwriters, are reasonable in light of the circumstances governing the Project. FOM f� Y ' (7) The date of the first missed payment on the FHA Note relating to the Project was August 1, 1991, and from such date to the date immediately prior to the date hereof, the FHA Note has been in default. IN WITNESS WHEREOF, the undersigned has signed this certificate as of August 1992. DREW GARDENS ASSOCIATES, LTD., A FLORIDA LIMITED PARTNERSHIP By: Reynolds Metals Development Company General Partner By: Title: v t D•2 EXHIBIT E (LETTERHEAD OF COUNSEL TO THE TRUSTEE) [Closing Date] City of Clearwater Clearwater, Florida Bryant, Miller and Olive, P.A. Tallahassee, Florida Banc One Capital Corporation Columbus, Ohio Jones Hall Hill & White, A Professional Law Corporation San Francisco, California $3,425,000 CITY OF CLEARWATER, FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 1992A (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) Ladies and Gentlemen: We have acted as counsel for Bank One, Columbus, NA (the "Bank "), in connection with the Bank's serving as Trustee under a Trust Indenture dated as of August 1, 1992 (the "Indenture "), between the City of Clearwater, Florida (the "Issuer "), and the Bank relating to the issuance of the Issuer's above - mentioned bonds (the "Bonds "). Certain capitalized terms not defined herein have the same meaning as in the Indenture. In such capacity we have examined originals or copies certified or otherwise identified to our satisfaction of: W the Indenture, (ii) the Articles of Incorporation and By -Laws of the Bank, (iii) the Loan Work -Out Agreement (the "Loan Work -Out Agreement ") dated as of August 1, 1992, among the Issuer, the Bank and the Owner named therein (the "Owner "), (iv) the Supplemental Regulatory Agreement dated as of August 1, 1992, among the Issuer, the Bank and the Owner (the "Supplemental Regulatory Agreement "), and (v) the Investment Agreement (the "Investment Agreement ") dated as of August 18, 1992, between Bayerische Landesbank Girozentrale and the Trustee. Based on the foregoing we are of the opinion that: (i) The Bank is a duly created and lawfully existing national banking association created and existing under the laws of the United States of America. (ii) The Bank has taken all corporate action necessary to assume the duties and obligations of the Trustee under the Indenture, the Investment Agreement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement. (iii) The Bank has duly authorized the execution and delivery of the Indenture, the Investment Agreement, the Loan Work -Out Agreement and the Supplemental E -1 3 Regulatory Agreement and the Indenture, when executed, will be the valid, legal and binding obligation of the Bank in its capacity as Trustee enforceable in accordance with i its terms. (iv) The Bank has all necessary trust powers required to carry out the trust intended under the Indenture. (v) All approvals, consents and orders of any governmental authority or agency having jurisdiction in the matter that would constitute a condition precedent to the performance by the Bank of its duties and obligation, under the Indenture, the Investment Agreement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement have been obtained and are in full force and effect. (v) No litigation is pending or, to the best of our knowledge, threatened in any way contesting or affecting the existence of powers (including trust powers) or the Bank's ability to fulfill its duties and obligations under the Indenture, the Investment Agreement, the Loan Work -Out Agreement and the Supplemental Regulatory Agreement. Very truly yours, E•2 4 c PRELIMINARY OFFICIAL STATEMENT DATED AUGUST 6, 19Y2 Standard & Poor's: Refunding Issue (See "RATING" herein.) c.6 = re ula- ri $ In the opinion of Bond Counsel, assuming continuing compliance with the certain covenants, under existing statutes, 8 person who is a Lions, rulings and judicial decisions, (i) interest on the Bonds is excluded from gross income for federal income tax purposes except $ g 13 o the 1954 Code, as amended, that such exclusion shalt not apply ry interest on any Bond jot any period during which such Bond is held y any p 634- "substantial user' ` of the Project or a "related person" within the meaning of Section 103(6)( ) f and (ii) the Bonds are exempt from all present intangible personal property fazes imposed pursuant to Chapter, 199, Florida Statures. Agreement z 0 See, ax treatment " AX TR A the Bonds. The CiryJ hesTrustee and the have entered nto arSupplemental egular ry q8 affect the nimurn and e A and the ability gas to rite Tax Exemption (tththe Code. The covenants to Comply +with ' the requirements of Section 103(b)(4)( the requirements M2% of Section 103(b)( 4)(A) f V; subjec�to compliance ce wirhr certain FHAsrequ rcovenants enrs and subject otherr !'mutations as+described under the rcapt caption The Suppl met tions. The m $ ? Regulatory Agreement'. Am ong regulations thereunder and the MorrgageeLoan documents, even though such acsoe may adversely affect m c National Housing Act, the Agreement, enforcement the tax exemption i Regulatory be inadequate to w iron on the Bonds. !n addition, if the Ownerjails to comply with the St Re ulato Ag (nag a remedies available o to the City, the Trustee and registered owners of the Bonds are severely limited and may 9 M o prevent the loss of tax exemption of interest on the Bonds retroactive to the dated date of the Bonds. See "THE SUPPLEMENTAL E *a o REGULATORY AGREEMENT"' and 'TAX TREATMENT' herein. d $3,400,000* CITY OF CLEARWATER, FLORIDA c m MORTGAGE- REVENUE REFUNDING BONDS, SERIES 1992A a (FHA Insured Mortgage Loan —Drew Gardens Apartments Project) e m Due: October 1, 2025 �$ " q e Dated: August 1, 1992 C b m o w c Price of All Bonds: % c o $ (Accrued interest to be added.) Eat E u principal amount or any multiple � � o Interest on the Bonds is payable on April 1, 1993, and thereafter on October l and April 1 of each year (each an "Interest —,°, v °' Payment Date "). The Bonds are issuable on tfhuIlIIo wtl�be bonds ayable at the principal oorporatetr s office of Bank One, Columbus, -50 ® thereof. Principal of and premium, if any, aw a NA, f Trustee, in Columbus, Ohio. Interest on the Bonds will be payable by check or draft mailed to the person in whose name c such Bond (or any predecessor Bond) is registered at the close of business on the 15th day of the month preceding each Interest Payment Date (provided that, principal, premium, if any, and interest may be paid by wire transfer as described herein). a The Bonds are issued by the City of Clearwater, Florida (the "Issuer"), to provide a portion in the money required to refund ide ca prior issue of bonds of the Issuer that were issued to pro the National Housing Act o mortgage 1934, as amend d to pay he cost r of �r Administration ( "FHA ") pursuant to Section 221(d)(4) e 0 acquiring, constructing, improvingDredµegCruaPdengAssoci Associates Ltdmultifamily orida limited partnershipt(the facility ) acrd in ro pay certain Florida (the "Project "), owned by costs of the refunding. O� T Any person who purchased or holds a Bond at a price in excess of its principal amount should consider the fact that the Bonds rued c ?e a are subject to redemption prior to ma n without u premium,cir the times and to the to the principal herein. See a THE BONDS — 3 6 5 interest to the redemption date, but c m Redemption" herein. HE ISSUER, THE 4 THE INTEREST g THE BONDS, TOGETHER ANY, AND INTEREST ON WHIOCH ARE PAYABLDE SOLELY FROM THE REVENUES OR 5 m 2 PRINCIPAL OF, PREMIUM, u o OTHER MONEYS TO BE RECEIVED N CONNECTION WITH THE REFINANCING OR THE PROJECT OR OTHER REST o= L EYS TO BE MADE AVAILABLE TO THE ISSUER FOR SUCH OR CHARGE AGAINST BTHE GENERAL CREDIT OR o r THEREON SHALL EVER CONSTITUTE AN R PUBLIC BO o TAXIN L POWERS TER PROVISION OR STATUTORY LIMITAT ON AND NEITHER HALL EVER CONSTITUTE OR GIVE E�, TIO r RISE TO ANY PECUNIARY LIABILITY OF THE ISSUER. ant, " Tire Bonds are offered when, as and if issued and received by the Underwriters subject to the approval of legality by Dry o bfiiler and Olive, PA., Tallahassee, Florida. Certain legal matters will be passed upon for the Underwriters by their counsel, Jones s y °�� /!all Hill & White, A Professional Law Corporation, San Francisco, California, and for the Owner by its counsel, Byrne, Costello p C Picka on It is ezneded that he Boorul n delfit& lie j Altman, 1 benavaflable jot ddivcry n New Yo k! New York, n +o Owner bout August fro Coq q � dr.. -. transact! ®e2 ,1992. p8a= BANC ONE CAPITAL CORPORATION NEWMAN 8c ASSOCIATES, INC. C aAa Dated- August , 1992 e a ------ i�bleet to change L/� r�i No dealer, broker, salesman or other person has been authorized by the Own Underwriters or the Issuer to respect to the Bonds other thangthosencontaaiinein this o� is s� Statement, an err, the made, such information or representations Y representations with authorized by any of the foregoing. must not be relied upon � d' even or sell nor the solicitation of an offer to buy nor shall there be an p having been g g• This Official Statement does not constitute an offer to person in any jurisdiction in which such offer, solicitation or sale is not authorized or ' y which the person m y sale of the Bonds by an Ong such offer, solicitation or sale is not qualified to do so or to any Person to whom it is unlawful to make such offer, solicitation or sale The information in forth herein has been obtained from sources that are believed le be re ' information herein has not been independently verified and is not gu ble b set accuracy and is not to be construed as a representation of such by the haute t he O t the or the Underwriters and is subject to revision and teed as to the Statement. The information and expressions of opinion stated herein are caner chap a amendment in a final Official g without notice. The delivery of this Official Statement shall not circumstances, create any implication that there has been no change subject to or opinions set forth herein since the date hereof. under any ange in the information IN CONNECTION WITH THE OFFERING OF THE UNDERWRITERS MAY OVERALLOT OR E STABILIZE OR r EFFECT TRANSACIBIONSDS�TT ABOVE THAT H MAINTAIN THE MARKET PRICE OF SUCH BONDS AT A LEVEL WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ARTY TI1dI:E, TABLE OF CON'S'ENTS THEINDENTURE ................................................................... .............................12 Definitions.............. ............................... .................... .............................13 Security........................................................................ .............................13 Establishment of Funds ................................................. .............................14 Application of Bond Proceeds and Other Amounts ....... .............................14 Costs of Issuance Fund ................................................. .............................14 ProgramFund .............................................................. .............................14 BondFund .............................................................:..... .............................15 Debt Service Reserve Fund ............................................ .............................15 FinalBalances ............................................................... .............................16 RebateFund ................................................................. .............................16 Investmentof Funds ..................................................... .............................16 Eventsof Default .......................................................... .............................16 Remedies of Bondholders ............................................. .............................18 Servicing the Mortgage Loan... .............................................................. I ... 18 Mortgage Insurance Benefits ........................................ .............................18 Supplemental Indentures .............................................. .............................19 TheTrustee ...................... ......................................... .............................20 THE FHA NOTE AND MORT GAGE ....................................... .............................20 THE FHA REGULATORY AGREEMENT ............................... .............................21 THE SUPPLEMENTAL REGULATORY AGREEMENT .......... .............................22 THE LOAN WORK -OUT AGREEMENT ................................. .............................25 Representations and Warranties of the Owner ................ .............................25 TaxCovenant. .............................................. .............................26 Non - Recourse Obligation ........................................... .............................26 TAXTREATMENT ................................................................. .............................26 ABSENCE OF LITIGATION .................................................... .............................28 LEGALMATTERS ................................................................. .............................29 ENFORCEABILITY OF REMEDIES ........................................ .............................29 MARKETING......................................................................... .............................29 RATING................................................................................ ..............................2 9 OTHERMATTERS .................................................................. .............................30 -i - PAM. INTRODU CTION.................................................................... ..............................1 THEBONDS .... ................................................................ ..............................2 General Description .................................................. ..............................2 LimitedObligations .... ........................................... ..............................3 Registration and Transfer ............................................. ..............................3 Redemption............................................................... ..............................3 FHAiNSURANCE..... ............................................................. ..............................7 THEISSUER ........................................................................... ..............................7 THEPROJECT ........................................................................ ..............................8 Location and Description of the Project ....................... ..............................8 Prior Operating History ............................................... ..............................8 Secondary Project Financing ....................................... ..............................9 THE PRIVATE PARTICIPANTS .............................................. .............................10 TheOwner ..... ........................................................ .............................10 TheManaging Agent .................................................... .............................11 TheMortgage Servicer ................................................ ..............................1 l TheTrustee ................................................................. ..............................I I RISKS TO THE BONDHOLDERS ............................................ .............................11 THEINDENTURE ................................................................... .............................12 Definitions.............. ............................... .................... .............................13 Security........................................................................ .............................13 Establishment of Funds ................................................. .............................14 Application of Bond Proceeds and Other Amounts ....... .............................14 Costs of Issuance Fund ................................................. .............................14 ProgramFund .............................................................. .............................14 BondFund .............................................................:..... .............................15 Debt Service Reserve Fund ............................................ .............................15 FinalBalances ............................................................... .............................16 RebateFund ................................................................. .............................16 Investmentof Funds ..................................................... .............................16 Eventsof Default .......................................................... .............................16 Remedies of Bondholders ............................................. .............................18 Servicing the Mortgage Loan... .............................................................. I ... 18 Mortgage Insurance Benefits ........................................ .............................18 Supplemental Indentures .............................................. .............................19 TheTrustee ...................... ......................................... .............................20 THE FHA NOTE AND MORT GAGE ....................................... .............................20 THE FHA REGULATORY AGREEMENT ............................... .............................21 THE SUPPLEMENTAL REGULATORY AGREEMENT .......... .............................22 THE LOAN WORK -OUT AGREEMENT ................................. .............................25 Representations and Warranties of the Owner ................ .............................25 TaxCovenant. .............................................. .............................26 Non - Recourse Obligation ........................................... .............................26 TAXTREATMENT ................................................................. .............................26 ABSENCE OF LITIGATION .................................................... .............................28 LEGALMATTERS ................................................................. .............................29 ENFORCEABILITY OF REMEDIES ........................................ .............................29 MARKETING......................................................................... .............................29 RATING................................................................................ ..............................2 9 OTHERMATTERS .................................................................. .............................30 -i - OFFICIAL STATEMENT $3,400,000 MY OF CLEAI{WATER,FLORIDA MORTGAGE REVENUE REFUNDING BONDS, SERIES 19! (FHA INSURED MORTGAGE LOAN - DREW GARDENS APARTMENTS PROJECT) INTRODUCTION provided to furnish information in conn of 101earwater, This Official Statement isp principal amount of CiInsured Mortgage issuance and sale of $3,400,000 aggregate onds, Series 19920E the City of Clearwater, Florida, Mortgage Revenue Refunding Drew Gardens Apartments Project) (the "Bonds') pursuant to the laws of the Loan - The Bonds will be issued under and Florida, (the "Issuer ). Chapter 166, Florida Statutes, Or o an ons of 5256(the State of Florida, particularly applicable P Indenture dated the Issuer on August 13, 1992 ands 13,1992, and a Trust One, Columbus, enacted by adopted Augu Act "), a resolution of the Issuer sure as of August 1, 1992 (the "Indenture "), between the Issuer and B NA, Columbus, Ohio, as Trustee (the "Trustee "). the Issuer to provide a Portion of the funds to refund The Bonds are being issued by a e Revenue Bonds, original principal amount of the Issuer 'S Mo g Project) (the $6,450,000 aggregate Insured Mortgage Loan -- Drew Gardens Apartments Series 1983 (FHA provide funds to make a mortgage partnership "prior Bonds "). The Prior Bonds were issued top d equipping a 180 - Ltd. a Florida limited p a e Loan') to Drew Gardens Associates, .proving an Florida (the (the 'M °rtg g the cost of acquiring, constructing, (the "Owner' ), to pay facility located in Clearwaeenote (the "F unit elderly residential rental housing a nonrecourse mortgag Note is insured "Project°). The Mortgage Loan is evidenced by on the Project. The FHA Note') secured by a Mortgage (the ,Mortgage ) an organizational unito the Administration ("FHA"), ("I-IUD' pursuant ended by the Federal Housing Act D' 1934, as am United States Department of Housing and Urban Development mortgage insurance Act ,,). Under applicable regulations, provisions of Section 221(d)(4) of Title II of the 1a e Housing (the "National Housing benefits are payable in cash. See "FHA INSURAN e trustee with respect to the prior Bondq (the e Since August 11 1991, the Owanner s been in default in its obligation to make e Loan, payment PP under the Mortgage went, FHA has paid a portion of the Prior Trustee ") has as the Mortgage Loan to FHA or P y and the Prior insurance benefits. As result to such assign with the issuance of the Bonds, the respect to the Mortgage Loan, insurance claim to the Prior Trustee with Bement dated as Bonds are subject to redemption. Concurrently Work -Out Work -Out Agreement "). Pursuant to the Loan Issuer, the Owner and tLo stee will enter into a Loan d d t Work-out the interest ,the of August 1, 1992 (the e Loan will be am %per annum, which ,Agreement, the terms of the Mortgage annum to a rate of anti and projected al rate of 10.625% p support' the Project's p Loan, from the origin History herein.) The Mortgage Owner believes is HE PROJFCT - which Operating operations. (See "THE and to ed will be transferred from the retire of the Prior Bonds Outstandin delivery to as so amend , the prior Trustee of sufficient moneys to "preliminary, subject to change. 1- pay any trustee's and mortgage servicing fees and expenses, and the prior HUD mortgage insurance payment (together with interest thereon) will be returned by the Prior Trustee to HUD. The Bonds will be secured by a pledge of W payments on the FHA Note, (ii) money held by the Trustee under the Indenture (other than amounts subject to rebate to the United States Government), (iii) FHA insurance proceeds payable in the event of a default on the Mortgage Loan, and (iv) all right, title and interest of the Issuer in the Loan Work - Out Agreement. Any person who purchases or holds a Bond at a price in excess of its principal amount should consider the fact that the Bonds are subject to redemption under certain circumstances at a price equal to the principal amount thereof, plus accrued interest to the redemption date, but without premium, at the times and to the extent described herein. See "THE BONDS -- Redemption." The exclusion of interest on the Bonds from gross income for federal income tax pur-poses is dependent upon, among other things, continuing compliance with certain provisions of the Internal Revenue Code of 1986, as amended (the "Code ") and of the Internal Revenue code of 1954, as amended prior to the enactment of the Code, and applicable Treasury regulations. There is no provision for acceleration of the indebtedness evidenced by the Bonds or for payment of additional interest if interest on the Bonds becomes included in gross income for federal income tax purposes due to noncompliance by the Owner with the provisions of the Loan Work -Out Agreement or the Supplemental Regulatory Agreement as to Tax Exemption among the Issuer, the Owner and the Trustee (the "Supplemental Regulatory Agreement ") under which the enforcement remedies of the Trustee and the Issuer are substantially limited by the requirements of FHA. See'THE SUPPLEMENTAL REGUIXrORY AGR.EEIIIENT' and 'TAX TREAT1%1ENT." Brief descriptions of the Bonds, the security for the Bonds, FHA insurance, the Indenture, the Loan Work -out Agreement, the Supplemental Regulatory Agreement and other documents are included in this Official Statement. All references to such documents and agreements are qualified in their entirety by reference thereto, copies of which are available for inspection at the office of the Trustee. THE BONDS General Description The Bonds will bear interest at the rates and mature on the dates set forth on the cover page. Interest on the Bonds will be payable on April 1, 1993, and thereafter semiannually on October 1 and April 1 of each year (each an "Interest Payment Date "). The Bonds are issuable in denominations of $5,000 principal amount or any multiple thereof. Principal of and premium, if any, on the Bonds will be payable at the principal corporate trust office of the Trustee. Interest on the Bonds will be payable by check or draft mailed to the person in whose name such Bond (or any predecessor Bond) is registered at the close of business on the 15th day of the month preceding each Interest Payment Date; except that the owner of at least $250,000 aggregate principal amount of Bonds may be paid principal, premium, if any, and interest, at the bond owner's option and at the bond owner's expense, by wire transfer in immediately available funds to an account designated by such owner. .2- Limited Obligations The Bonds, together with the interest thereon, are limited obligations of the Issuer, the principal of, premium, if any, and interest on which are payable solely from the revenues or other moneys to be received in connection with the refinancing of the Project or other moneys to be made available to the Issuer, for such purpose. Neither the Bonds nor the interest thereon shall ever constitute an indebtedness or a charge against the general credit or taxing powers of the Issuer, or any other public body within the meaning of any constitutional or charter provision or statutory limitation and neither shall ever constitute or give rise to any pecuniary liability of the Issuer. Registration and Transfer Bonds may be exchanged, and the transfer of Bonds must be registered, at the corporate trust office of Bank One, Columbus, NA, as Trustee in Columbus, Ohio. If any Bond is mutilated, lost, stolen or destroyed, the Issuer may execute and the Trustee is to authenticate a new Bond. In the case of a lost, stolen or destroyed Bond, the Issuer and the Trustee may require satisfactory indemnification prior to authenticating a new Bond. The Issuer and the Trustee may charge reasonable fees and expenses in connection with replacing Bonds mutilated, lost, stolen or destroyed. Redemption Optional Redemption. The Bonds are subject to redemption on any date on and after October 1, 2002, as a whole or in part, to the extent of any optional prepayment of the FIIA Note by the Owner (and from any reduction of the Debt Service Reserve Fund under the terms of the Indenture), or from the proceeds of refunding bonds or otherwise from any monies provided by the Issuer, at the redemption prices set forth in the table below, expressed as percentages of the principal amount to be redeemed (together with accrued interest to the redemption date), as follows: Redemption Redemption Dates Prices October 1, 2002, through September 30, 2003 102% October 1, 2003, through September 30, 2004 101 October 1, 2004, and thereafter 100 In the event of an optional redemption of Bonds on a date on which the redemption price includes a redemption premium, the Trustee shall not give notice of such redemption unless W the Trustee shall have had in its possession, for a period of at least 91 days prior to the giving of such notice, an amount paid by the Owner as a prepayment premium on the Mortgage Loan equal to such redemption premium; (ii) there shall not have occurred at any time during or after such 91 -day period any filing by or against the Owner under any bankruptcy act or any similar law for the relief of debtors and the Owner has filed with the Trustee a certificate to that effect; and (iii) the Trustee shall have received the prepayment of the Mortgage Loan. 1 ggfla.tory Sinking Fund Redemption. The Bonds are subject to mandatory sinking fund redemption in the amounts and on the dates set forth below (subject to adjustment as described below to the extent that the Bonds are redeemed prior to maturity other than pursuant to scheduled mandatory redemption) at a redemption price .3. I equal to the principal amount thereof, together with accrued interest to the redemption date: Principal Principal Amount Amount to be to be Date Redeemed Ito Redeemed In the event of a redemption of less than all of the outstanding Bonds other than by mandatory sinking fund redemption, the mandatory sinking fund payments scheduled above are to be reduced so that the resulting decrease in debt service on the Bonds during each six -month period ending on an Interest Payment Date is proportional, as nearly as practicable, to the decrease in payments on the FHA Note in each period. C mqua tv and Condemnation Redemption. The Bonds are subject to redemption on any date, on the earliest practicable date, as a whole or in part, at a redemption price equal to the principal amount thereof plus accrued interest to the date fixed for redemption to the extent the Net Proceeds of any condemnation award or insurance recovery (and, in the case of the Bonds, as a result of a reduction in the Debt Service Reserve Fund pursuant to the Indenture) are applied to the prepayment of the Note. -4- S pecial Redpmnti�» ZTnon (�Defaujt TTnr�or th Mortgage Loan. If insurance benefits under the Contract of Mortgage Insurance are paid by FHA to the Trustee, or if such benefits are payable by FHA and the proceeds of refunding bonds of the Issuer or other moneys are deposited with the Trustee for such purposes, the Trustee shall call the Bonds for redemption, on the earliest practicable date as a whole or in part to the extent of available money, at a redemption price equal to 100% of the principal amount thereof plus accrued interest to the date fixed for redemption. Special Bankruptcy Redemption. In the event that the Owner becomes subject to any bankruptcy proceedings and the trustee in bankruptcy causes there to be a prepayment of the Note without notice and without premium, Bonds in the amount of such prepayment (and as a result of a reduction in the Debt Service Reserve Fund pursuant to the Indenture), shall be redeemed, as a whole or in part, without any otherwise required notice of redemption on the earliest practicable date at a redemption price equal to the principal amount thereof plus accrued interest to the date of redemption. Redemption aon Determination of HUD. On any date, as a whole or in part, Bonds shall be redeemed to the extent of any prepayments of the Note made upon the determination of HUD in order to avoid an insurance claim under the Contract of Mortgage Insurance (and as a result of a reduction in the Debt Service Reserve Fund pursuant to the Indenture). Selection of Bonds for Redem tion. In the event of a redemption of less than all the Outstanding Bonds pursuant to the scheduled mandatory redemption provisions described above, the particular Bonds to be redeemed are to be selected by the Trustee by lot. If less than all the Bonds then Outstanding shall be called for redemption other than from mandatory sinking fund payments pursuant to the Mandatory Sinking Fund provisions, (i) the Trustee shall redeem an amount of Bonds of each series so that the resulting decrease in debt service on the Bonds of each series in each semi - annual period ending in an Interest Payment Date is proportional, as nearly as practicable, to the decrease in the payments on the Note in each such semiannual period, and the Bonds shall be selected by lot within each maturity, and (ii) the Trustee shall transfer from the Debt Service Reserve Fund to the Bond Fund an amount that bears the same proportion to the amount then on deposit in the Debt Service Reserve Fund as the reduction in the principal balance of the Mortgage Loan bears to the outstanding balance of the Mortgage Loan immediately prior to such reduction. Bonds shall be redeemed pursuant to the Indenture, only in the principal amount of $5,000 or any integral multiple thereof. .Notice of Redemption. Except that Bonds redeemed under the Special Bankruptcy Redemption provisions described above shall be redeemed without notice, notice of the intended redemption of each Bond shall be given by the Trustee by first class mail, postage prepaid, to the registered owner at the address of such owner shown on the Registrar's bond register. All such redemption notices shall be given not less than thirty (30) days nor more than sixty (60) days prior to the date fixed for redemption. Each notice shall state that payment of the applicable redemption price plus accrued interest to the date fixed for redemption will be made upon presentation and surrender of the Bonds. The Trustee shall not give notice of any redemption of Bonds (other than pursuant to the Mandatory Sinking Fund provisions), unless the Trustee shall have, at the time such notice is given, sufficient funds on hand to make such redemption. A second notice of redemption shall be sent within 30 days of the redemption date, by registered mail, overnight delivery service or other secure means, postage prepaid to the registered owners of any Bonds called for redemption, at their addresses appearing on the Bond registration books maintained by the Trustee. Each notice of redemption shall state the redemption date and the redemption price and, if less than all of the outstanding Bonds are called for redemption, (i) the numbers of the Bonds to be redeemed by giving the individual certificate number of each Bond to be redeemed (or equivalent information); (ii) the CUSIP numbers of all Bonds being redeemed; (iii) in the case of a partial redemption, the principal amount of each Bond being redeemed; (iv) the date of issue of the Bonds as originally issued; (v) the rate or rates of interest borne by each Bond being redeemed; (vi) the maturity date of each Bond being redeemed; (vii) any other descriptive information needed to identify accurately the Bonds being redeemed; (viii) the place or places where amounts due upon such redemption will be payable: and (ix) the name, address, telephone number and contact person at the office of the Trustee with respect to such redemption. The notice shall require that such Bonds be surrendered at the principal corporate trust office of the Trustee for redemption at the redemption price and shall state that further interest on such Bonds will not accrue from and after the redemption date. CUSIP number identification with appropriate dollar amounts for each CUSIP number also shall accompany all redemption payments. Notice of such redemption also shall be sent by registered mail, overnight delivery service or other secure means, postage prepaid, to the original purchaser of the Bonds and to any holder of $250,000 or more in aggregate principal amount of Bonds to be redeemed, to certain municipal registered securities depositories (described in the Indenture) which are known to the Trustee to be holding Bonds on behalf of a registered Bondholder and to at least two of the national information services (described in the Indenture) that disseminate securities redemption notices, when possible, at least five (5) days prior to the mailing of notices required described in the first paragraph above, provided that neither failure to receive such notice nor any defect in any notice so mailed shall affect the sufficiency of the proceedings for the redemption of such Bonds. Notwithstanding the foregoing or any other provision of the Indenture, in the event of a redemption by reason of the Trustee receiving prepayments on the Mortgage Loan representing prepayments on the Mortgage Loan made by the Owner without notice or prepayment penalty while under the supervision of a trustee in bankruptcy, notice of redemption of Bonds shall not be required if the circumstances do not permit the ^trustee to give such notice in accordance with the provisions described above. The Indenture provides that failure to give notice by mailing to the holder of any Bond designated for redemption or to any depository or information service will not affect the 'validity of the proceedings for the redemption of any other Bond if notice of such redemption shall have been mailed as provided herein. Lass of Premium. fr . Early Redern tion, Any person who purchases or holds a Bond at a price in excess of its principal amount should consider the fact that the Bonds are subject to redemption under certain circumstances at a price equal to the principal amount thereof, plus accrued interest to the redemption date, but without premium, at the times and to the extent described herein. FHA INSURANCE The Federal Housing Administration has insured the FHA Note pursuant to Section 221(d)(4) of the National Housing Act. Applicable FHA regulations are contained in 24 CFR 221 which, with certain exceptions (requiring payment of insurance benefits in cash rather than FHA debentures), incorporates by reference the provisions of 24 CFR. 207 (covering mortgages insured under Section 207 of the National Housing Act). The National Housing Act defines an event of default under an FHA- insured mortgage as failure to make any payment due under the mortgage or to perform any other mortgage covenant if the mortgagee, because of such failure, has accelerated the debt. In the event of a payment default continuing for a period of 30 days (as such period may be extended up to 90 days upon request to HUD), the Trustee may give notice to the Federal Housing Commissioner (the "Commissioner ") of the default and of its intention to file an insurance claim. Promptly thereafter, the Trustee may take the necessary steps to file a claim for insurance. Under FHA regulations, the Trustee may either assign the FHA Note (and the Mortgage) to the Commissioner or acquire title to the Project by foreclosure and convey it to the Commissioner. If the Trustee were to acquire title to the Project and convey it to the Commissioner, the expenses of foreclosure proceedings would be payable out of the proceeds received on account of the insurance claim. The Trustee has been directed by the Indenture to make an assignment rather than acquire and convey title to the Project. In connection with a claim for insurance benefits, FHA may require delivery to it of certain cash items. Cash items include any balance of the Mortgage Loan and any undrawn balance due under the letters of credit required to be obtained in connection with the endorsement of the FHA Note by FHA. In the event of a default on the FHA Note, its assignment to FHA and the filing of a claim for FHA insurance, FHA will pay in cash (unless FHA were requested by the Trustee to pay in FHA debentures, which is not permitted under the Indenture) insurance benefits equal to the sum of (a) the unpaid principal amount of the FHA Note computed as of the date of default, (b) certain eligible payments (such as taxes, insurance, special assessments and water rates) made by the Trustee and (c) interest on the insurance proceeds from the date of default at the applicable FHA debenture rate 10.375% (which interest may be limited if certain notices are not given to FHA within the prescribed time periods), less 1% of the principal amount of the FHA Note and certain amounts realized by the Trustee from the Owner on the mortgaged property, including cash items. In addition, insurance benefits do not include up to one month's interest which may have accrued on the Mortgage Loan prior to the date of a default. In the past, it has been FHA's policy, during the construction period, to pay 70% of the insurance claim within 15 days of recordation and the balance, after audit, within three to twelve months. After final endorsement, it has been. FHA's policy to pay 90% of the insurance claim within 15 days of recordation and the balance, after audit, within three to twelve months. THE ISSUER The Issuer is a municipality duly organized and existing under the laws of the State of Florida. The Issuer is authorized by the State of Florida, particularly Chapter 166, Florida Statutes, Ordinance No. 5256 -92, enacted by the Issuer on August 13, 1992 -7- provisions of law (the "Act "), to issue he a Bonds ta facility- proceeds the and other applicable p purpose of refinancing proceeds thereof to the Owner for the pure an elected Mayor - Commissioner and four Commission The Issuer is governed by resent administered by the appointed City Manager. The p ether comprise the City Commission. The 1tY Commissioners of Policy which is establishes p Commission and other Officials are as follows: members of the City Eg ion Rita J. Garvey Sue Berfield Arthur X. Deegan Richard Fitzgerald Lee Regulski Michael J. Wright M.A. Galbraith, Jr. Cyndie Goudeau Mayor -City Commissioner City Commissioner City Commissioner City Commissioner City Commissioner The offices of the Issuer are located at 112 Florida 34616. City Manager City Attorney City Clerk South Osceola Avenue, Clearwater, THE PROJECT Location and Description of the Project The Project, known as Drew Gardens Apartments, consists of one four -story building containing of ow housing units and is located on Drew Street 1 3 and was Pinellas County, Florida. construction A its arehfurnrosh d cwitth window hades, ele The completed in December, 1984. orts in range and refrigerator, kitchen exhaust fans and board court and to carp Project also tootin 74 es a g parking o, a storage building, SP aces. The characteristics of the units are as follows: addition Number N, of Unit °f Tnits. Studio 72 One Bedroom 90 Two Bedroom 18 Prior Operating History the closing of 1883, following Construction of the Project commenced in October, of the acquisition, construction e Loan on October 12, 1983 and the issuance °f the Prior $°nom ° substantially tr Construction the Mortgage 1983 to provide construction and and equipping 1984 and the Mortgage Loan was finally of the Project. Construction of the Project was determYn completed by �D/FHA on December August 27, 1955. endorsed for insurance by FHA .8- ik Since that time, due to the depressed conditions in the rental apartment market in Clearwater, Florida and the surrounding area for projects of this type and other factors, the Project has experienced occupancy levels and rent levels per unit which have been lower than those projected at the time the Mortgage 'Loan was underwritten, as well as higher than anticipated operating expenses. The Project has therefore been unable to generate sufficient levels of revenues after payment of operating expenses to pay the required debt service on the Mortgage Loan and to cover mortgage insurance premiums, escrow requirements and similar items, as shown in the following table, derived from the audited financial statements of the Owner prepared by Coopers & Lybrand, Certified Public Accountants, Richmond, Virginia, for the years ended December 31, 1989, 1990 and 1991: Due to the foregoing factors, the Owner ceased making regularly scheduled payments on the Mortgage Loan in August, 1991. The Mortgage Loan has been in default since that time. As a result of the default, the Prior Trustee assigned the Mortgage Loan to HUD on July 15, 1992, and on July 17, 1992, the Prior Trustee received a payment of FHA mortgage insurance benefits from HUD with respect to the defaulted Mortgage Loan. Secondary Project Financing A second mortgage of $1,770,530 on the Project closed in December 1985 when operating deficit advances in excess of the $500,000 maximum provided for in the Operating Deficit Guarantee Agreement were converted to a second mortgage payable to Presidential Development Corporation, an affiliate of the Owner. The loan is due on demand and bears interest at the rate of prime plus 1 %; the interest rate is determined on December 31 each year. The mortgage is collateralized by a second mortgage on the Project's real estate. The mortgage is to be repaid only from surplus cash of the Project as defined in the regulatory agreement. Upon the closing of the refunding, this obligation will become a third lien on the Project subordinate to both the Mortgage and the new second deed of trust described below. In connection with the work -out of the defaulted Mortgage Loan, the Owner has agreed to an arrangement under which the loan will be partially assigned to HUD, in an amount equal to $2,766,672 principal plus accrued interest, leaving an outstanding -9- I& Total Income $1,574,679 $1,353,891 $1,861,081 Cost of Operations before Depreciation aj2i7641 a2i6.9591 M536343) Operating Profit (Loss) Before Depreciation ($617,085) ($863,068) ($675,662) Depreciation (2 t2� (239.362) Operating.Profit (Loss) ($854,753) ($1,100,737) ($915,024) Due to the foregoing factors, the Owner ceased making regularly scheduled payments on the Mortgage Loan in August, 1991. The Mortgage Loan has been in default since that time. As a result of the default, the Prior Trustee assigned the Mortgage Loan to HUD on July 15, 1992, and on July 17, 1992, the Prior Trustee received a payment of FHA mortgage insurance benefits from HUD with respect to the defaulted Mortgage Loan. Secondary Project Financing A second mortgage of $1,770,530 on the Project closed in December 1985 when operating deficit advances in excess of the $500,000 maximum provided for in the Operating Deficit Guarantee Agreement were converted to a second mortgage payable to Presidential Development Corporation, an affiliate of the Owner. The loan is due on demand and bears interest at the rate of prime plus 1 %; the interest rate is determined on December 31 each year. The mortgage is collateralized by a second mortgage on the Project's real estate. The mortgage is to be repaid only from surplus cash of the Project as defined in the regulatory agreement. Upon the closing of the refunding, this obligation will become a third lien on the Project subordinate to both the Mortgage and the new second deed of trust described below. In connection with the work -out of the defaulted Mortgage Loan, the Owner has agreed to an arrangement under which the loan will be partially assigned to HUD, in an amount equal to $2,766,672 principal plus accrued interest, leaving an outstanding -9- I& balance of $3,242,452 (the `Partial Assignment "). As a result of the Partial Assignment, HUD will take back a second mortgage, evidencing the Owner's indebtedness to HUD for the amount paid by HUD under the Partial Assignment. The HUD second mortgage will have a final maturity which is the same as that on the first mortgage. The interest rate on the second mortgage will be equal to the mortgage note rate following the refunding. Interest on the second mortgage will be partially accrued but unpaid for the first seven years. At the end of seven years the unpaid principal and 'interest will be reamortized and will be repayable in level monthly payments of principal and interest over the remaining term of the note. The second mortgage will have a ten year "lock out" provision for prepayment by the Owner. In connection with the issuance of the Bonds to provide work -out refinancing for the defaulted Mortgage Loan, the Owner will enter into the Loan Work -Out Agreement (see "THE LOAN WORK -OUT AGREEMENT" herein) and the Modification of Mortgage Note and Mortgage (see THE FHA NOTE AND MORTGAGE "), pursuant to which the Owner will cure all arrearages on the Mortgage Loan, the FHA insurance will be reinstated and the interest rate on the Mortgage Loan will be lowered from 10.625% to per annum and the Owner will enter into the arrangements described under "Secondary Project Financing" above. The Owner believes that this reduction in the interest rate on the Mortgage Loan will bring the cash flow requirements for the Project in line with present and projected project revenues; however, due to the uncertainties of the apartment rental marketplace in Clearwater, Florida, and other factors, there can be no assurance that the Project will produce sufficient income, even after these modifications of the Mortgage Loan, to cover operating expenses and to pay debt service on the Mortgage Loan, to cover the Owner's obligations under the secondary project financing and to pay related items. The Mortgage Loan, as modified, and the secondary project financing will continue to be non - recourse obligations of the Owner. See "THE FHA NOTE AND MORTGAGE" and "THE LOAN WORK -OUT AGREEMENT" herein for a description of the terms of the modified Mortgage Loan. If the Owner were to default under the terms of the modified Mortgage Loan or the Loan Work -Out Agreement, it is likely that the Bonds would be called at par prior to their scheduled maturities. See "THE BONDS -- Redemption' and "RISKS TO THE BONDHOLDERS " herein. "FHE PRIVATE PARTICIPANTS The Owner The Owner of the Project is Drew Gardens Associates, Ltd., a Florida limited partnership formed for the principal purpose of owning the Project. The General Partner of the Owner is Reynolds Metals Development Company, who will have general responsibility and sole authority for supervising the operations of the Owner, and is responsible for the management and operation of the Project subject to regulation, supervision and inspection by HUD. An affiliate of the General Partner, Presidential Development Corporation, is a Limited Partner of the Owner. The General Partner has had previous experience with the development, ownership and/or management of HUD subsidized housing projects in 8 states. The General Partner has previously managed or owned 35 multifamily housing projects comprising over approximately 3,500 units. III- Aak substantial assets or engage the The Owner has not and does not intend to acquire any continue to ed in and may es of .n an substantial business activities he Ownerm Y be engaged ton of similar types 1 Y partners o and management Project. However, the p development, ownership engage in the acquisition, housing projects. liable for payments on the Neither the Owner nor its partners will be personally lied to pay the principal °f and lnresentation s m de that e Owner FHA Note to be applied ressly set forth herein, no rep neither the Owner's except to the extent exp artners are included in this Official Statement. will have substantial funds available for the Project. Accor ing Y+ financial statements nor those of its p The Managing Agent presently employs 140 Judge By Results, Inc. began its operations in 1988 and g' persons 11. The firm The Principal of the Managing Agent is Michael r projects locat d in Florida manages approximately 260 units of multifamily housing in p J The Mortgage Servicer Syracuse, oration located in Syr Continental Securities Corporation, a New York Corp roved FHA New York, has agreed to service the mortgage Securities Corporate n is an Pp a Mortgage approximately 100 multifamily Servicing Agreement. Continental r0 nately $400 Mortgagee and GNMA issuer. It is currently servial balances of app and nursing home loans with aggregate princip million. O£ these, app roximately 80 loans are FHA insured under Sections 221 or 232 0 the National Housing Act. The Trustee under the ink One, Columbus, NA, Columbus, Ohio, will serve zed under the laws of B n association organized fiduciary Indenture. The Trustee is a national banking powers of a bank, oration and the Federal the United States of America, having of record and as trustee for powers and is a member of the Federal aeFsRA mortgagee Corp Reserve System. The Trustee will e loans totaling over $250 The Trustee currently serves as trustee or escrowee for over 80 other ax- the Bonds• FHA- insured multifamily mortgage exempt financings backed by mount. The Trustee currently serves as trustee ate million in aggregate principal 525 other tax-exempt financings in excess of $1.5 billion in aggregate approximately principal RISKS TO THE BONDHOLDERS Limited BONDS -- and payable only from payments to be The Bonds are The Bonds will be secured under the indenture for the benefit of the Obligations" herein. held under made on the FHA Note and from money s thereon. owners of the Bonds and investment earning should consider carefully all Prospective purchasers of the Bonds, therefore, prior t e maturity or factors that may affect both the operations be redeemed p f the Project y and possible possibility that the Bonds may consequently create the that the Bonds might bear taxable interest retroactively from their date of issuance. e 11- following list of possible factors, while not setting forth all the factors which must be considered, contains some of the factors that should be considered prior to purchasing Bonds: (1) V c L c E PM-as In ome. E Z I r being substantially The at rents per uniithwhich willdcpends in large F upon its r service and other cash requirements. There can be no assurance that the Owner will be able to rent units at rentals that will enable it to make timel over operating expenses, debt See "Prior Unsuccessful Operating History of the Project" below. The on the FHA Note. The exclusion of interest on the Bonds from federal gross continuing compliance by the Owner with certain requirements referred to below; income is dependent upon however, the enforcement remedies available to the Issuer and the Trustee are severely limited. See "THE SUPPLEMENTAL REGULATORY AGREEMENT" and "TAX TREATMENT." There is no provision for an acceleration of the indebtedness evidenced by the Bonds or payment of additional interest if interest on the Bonds becomes included in gross income for federal income tax purposes. (2) Pri r c s ul erati . Hi .!2!!!,:1:! encountered substantial difficulties in operations in its Prior oPeratin. history T Project has PROJECT - Prior Operating History" above). on assurance can ra g (See "THE per od following the issuance of the Bonds, the cash flow from the Project that operating the expenses, taxes, insurance, mortgage insurance premium, and other expenses) b„ sufficient to cover the stated debt service on the Mortgage Loan and other fees and xP . expenses. In such an event, the Owner could default once again on the FHA Note, which default, if not cured within the time permitted under the terms of the Mortgage Loan, could result in the assignment of the FHA Note to HUD for a and would result in a redemption of the Bonds prior to maturity, as described herein. See "THE BONDS __ payment of FHA insurance Redemption -- Extraordinary, Mandatory Redemption." (a) �aonslary Mark t and Prices. The Underwriters will not be obligated to repurchase any of the Bonds, and no representation is made concerning the existence of market secondary market following Bonds completion o assurance can of erin given that any secondary assurance can be given that the initial offering prices for the Bonds will continue for any of the Bonds, and no period of time. (4) Cq t* Facilities. The Issuer and the Owner and persons who may be affiliated with each have and may additionally finance, develop, construct, and operate other facilities that could compete with the Project for tenants. Any com if so constructed, could adversely affect occupancy and revenues of the Pro t ec eting facilities, THE INDENTURE The following is a brief summary of the Indenture. The summary does not purport to be complete or definitive and is qualified in its entirety by reference to the Indenture, copies of which are on file with the Trustee. 12- w, 1' I Definitions "Debt Service Reserve Requirement" andsum interest 1payablei nnrespect of the (including mandatory sinking fund payments) Bonds in any eight -month period ending on an Interest Payment incipal and interest e the such period, and (ii) an amount equal to one payment P Mortgage Loan. "Owner Deposit" means cash in the amount of $ to be deposited by the Owner with the Trustee provided e ine is Indenture. funds on the Closing Date in the Costs of Issuance "Pledged Revenues" means the revenues, receipts and other money received or to be received from the Owner come denied orHto be derived on any money held by the oTrustee Note, the Mortgage and the Project charges, interest and ursuant to the Contract of Mortgage under the Indenture, and all money p aid P Insurance between the Trustee and FHA, and other benefits thereunder. "Qualified Investments" means any of the following if and to the extent permitted bylaw: (i) Direct obligations of or obligations the principal of and interest on which are fully guaranteed by the full faith credit of the instrumentality State Uniternme e, or (ii) obligations of any Governor s of deposit ssued by full hfaith rustee orcanyof its taffil affiliates by any state or certificates P national 1+ ohig bank ortwhich deposit from insured by FDIC (excludiCorporation g a lbank A where the Issuer is a settler of a trust account evidenced by deposits therewith), or (iv) investment agreements, in substantially the same form the Investment Agreement (as defined in the Indenture), which will not adversely affect the rating on the Bonds, with a financial institution whose unsecured long term debt is rated by Standard & Poor's Corporation at least as high as the rating on the BGndpy Sta lord &s poor s Corporation ationt that invest ltexclusiivvelyy in "AAAm es obligains issued and guaranteed alified Inve the stments tmentseundere (G (e) oren(v)r above shall or instrumentalities. da from the of have a su h Qualified date not to Investments cor as needed under he Indenture. date of purchase Security Under the Indenture, as security: payment of the principal of, premium, if any, and interest on eand assigns to, and advanced ecuritye interest to he Trustee in, the the Issuer pledges following property: A. Lxcepters of credit held uunderlthright, ndenture by the interest Trustee, including the to any money or le pro its and proceeds of the Bonds, the payments under the FHA Note and the interest, p other income derived from the investment thereof. B. All right, therefor, including interest issuer in the Mortgage the alMortgage FHA gor casualty the security theref , -13- insurance benefits or condemnation awards payable with respect thereto and any interest, profits and other income derived from the investment thereof. C. All right, title and interest of the Issuer in and to the Loan Work-Out Agreement. D. Except for the Rebate Fund, all funds, money and securities and any and all other rights and interests in property whether tangible or intangible from time to time by delivery or by writing of any kind, conveyed, mortgaged, pledged, assigned or transferred as and for additional security under for the Bonds by the Issuer or by anyone on its behalf or with its written consent to the Trustee, by which it is authorized to receive any and all such property at any and all times and to hold and apply the same subject to the terms l the Indenture. of Establishment of Funds The following funds are established under the Indenture: Costs of Issuance Fund; Program Fund; Bond Fund; Debt Service Reserve Fund (including the Mortgage Reserve Account therein); and Rebate Fund. Application of ]Bond Proceeds and Other Amounts From the proceeds of the Bonds ($) the Trustee shall deposit the accrued interest in the amount of $ __ ,plus $ to the Bond Fund, and $ to ustee s the Program Fund. The Tr hall deposit the Owner Deposit in the Costs of Issuance Fund. From the moneys released from the Prior Indenture, the Trustee shall deposit $ to the Debt Service Reserve Fund (of which Mortgage Reserve Account therein). $ shall be deposited to the Costs of Issuance Fund The Trustee is to use moneys in the Costs of Issuance Fund to pay costs of issuance in accordance with a Bond Purchase Agreement among the Issuer, the Owner and the Underwriters upon presentation to it of invoices not in excess of the amounts set forth therein. On the date which is 180 days following the date of the issuance of the Bonds, the Trustee is to distribute any funds remaining in the Costs of Issuance Fund to the Owner. Program Fund The Trustee is to remit amounts held in the Program Fund to the Prior Trustees for the purpose of refunding the Prior Bonds. -14- Bond Fund All payments on the FHA Note and all interest, profits or other income derived from the investment of all funds held under the Indenture are to be deposited in the Bond Fund. Subject to the limitations contained in the Indenture, in the event that on or before any Interest Payment Date the Trustee does not receive the full amount of a payment then due on the FHA Note, the Trustee is to on such Interest Payment Date, withdraw from the Mortgage Reserve Account of the Debt Service Reserve Fund and deposit to the Bond Fund the amount that when added to the amount therein, is sufficient to pay principal and interest on the Bonds then due, provided, however, that any such transfer by the Trustee shall not relieve the Owner of its obligations under the FHA Note or Mortgage. Upon receipt of such payment the Trustee is to immediately deposit in the Mortgage Reserve Account of the Debt Service Reserve Fund the amount previously withdrawn therefrom, FRA mortgage insurance benefits, if any, are to be deposited in the Bond Fund, and used, together with other amounts ou deposit in the Bond Fund, to the extent necessary to redeem Bonds in accordance with the Indenture at the earliest practicable date. On each Interest Payment Date and on any other date when Bonds are to be redeemed or otherwise paid pursuant to the Indenture, the Trustee is to apply the amounts in the Bond Fund in the following priority: (a) to the payment of all principal and/or interest due on the Bonds (including any mandatory sinking fund payments) then due; (b) to. the payment of the fees and expenses of the Trustee, as provided in the Indenture; (c) to the payment of the ongoing surveillance fee of Standard & Poor's Corporation, in the amount of $500 per year; (d) to the payment of any fees and expenses of the Mortgage Servicer, as provided in the Indenture; (e) to the transfer of any amounts required to be deposited in the Debt Service Reserve Fund (and the Mortgage Reserve Account therein), in order to restore the amount of money therein to the amounts required pursuant to the terms of the Indenture; :L (f) payment to the Rebate Analyst; and (g) to the maintenance in the Bond Fund of a carry - forward balance as required in the Indenture. Debt Service Reserve Fund If on any Interest Payment Date the amount in the Bond Fund after making all required deposits therein is insufficient to pay the interest on, principal of, and premium, if any, then due on the Bonds, the Trustee is, subject to the limitations described in the paragraph below, to transfer cash in an amount equal to such deficiency to the Bond Fund from the Debt Service Reserve Fund; provided, however, that any such transfer by the Trustee is not to relieve the Owner of any of its obligations under the FHA Note or under the Mortgage. The Trustee is, on each Interest Payment Date, to transfer to the Bond Fund from the Debt Service Reserve Fund and the Mortgage Reserve Account •15- interest arnin sy luehtheDDeb SSe eC Service Reserve Fund and the Mortggage Restirve Account The Trustee f cost, market, or amortized value• on each Interest Payment Date at the lowest o Notwithstanding the foregoing, except when all outstanding Bonds are to be un redeemed, insurance be efits Trustee nd of is intention and f ele dionuto assign the Mortgage mortgage Loan to HUD Pursuant to the Indenture, no money in the Debt Service Reserve Fu is o not to be used for payments of principal of or interest In the Bonds, other Dat and the transfer of exceed one payment on the FHA Note on each Interest Bon earaungse iftsuch use would result in the amount in the Debt Service Reserve Fund Indenture, being reduced to less than the Debt Service Reserve Requirement. Final Balances either When provision has been made for payment of all �nof the Trustees, Mortgage at maturity or upon redemption, and for the payment' Service 's, Rating Indenture, after such paymyent in full,dmoneysremaining under the due under Indenture shall be transferred to the Owner. Rebate Fund The Trustee is to establish and maintain a fund separate from any other fund established and deposited in the Rebate nFuud is t be h ld by the TrustRee in trusFund. o he money at any payment to the federal government of the United States of America. extent required for the All amounts nd by -aeLetter of Instructions. The Trustee will be deemed conclusively by to Indenture l et have complied with such Owner with the terms of the no liability eweP o to enforce compliance by the Letter of Instructions. Investment of Funds The money held in the Bond Fund, the Debt Service Reserve Fund (including the Mortgage Reserve Account) is to be invested pursuant to an investment agreement (the "Investment Agreement ") between the Trustee and The Investment Agreement provides on the Debt Service Reserve Fund (including the Sz Bond Fund an Mortgage Reserve Account thereon). In addition, the Trustee is authorized to invest other amounts held under the Indenture in Qualified Investments, as hereinbefore defined. Events of Default Each of the following is an "event of default" with respect to the Bonds (each a Default) under the Indenture: (a) default in the due and punctual payment of any interest on any Bond; =1G- (b) default in the due and punctual payment of the principal or premium, if any, on any Bond whether at the stated maturity thereof, or on proceedings for redemption thereof, or on the maturity thereof by declaration; or (c) default, and the continuation thereof for a period of 30 days following notice to the Trustee, in the performance or observance of any other of the covenants, agreements or conditions on the part of the Issuer in the Indenture or in the Bonds after written notice to the Issuer from the Trustee or the registered owners of at least 25 % of the Bond Obligation as defined below) at such time specifying such default and requiring the same to be remedied. Upon the occurrence of a Default described in paragraph (a) or (b) above, the Trustee may, and upon the written request of the holders of not less than 25% of the aggregate principal amount of the Bonds then outstanding (the "Bond Obligation ") must, by notice in writing delivered to the Issuer, declare the principal of all Bonds then outstanding and the interest accrued thereon immediately due and payable, and such principal and interest will thereupon become and be immediately due and payable. If at any time after the Bonds have been so declared due and payable, and before any judgment or decree for the payment of the money due has been obtained or entered, the Issuer or the Owner, pays to or deposits with the Trustee a sum sufficient to pay all principal of the Bonds then due (other than solely by reason of such declaration) and all unpaid installments of interest (if any) upon all the Bonds then due, with interest at the rate borne by the Bonds on such overdue principal and (to the extent legally enforceable) on such overdue installments of interest, and the reasonable expenses of the Trustee have been made good or cured or adequate provisions will have been made therefor, and all other defaults under the Indenture have been made good or cured or waived in writing by 100% of the owners of the Bond Obligation, then and in every case, the Trustee on behalf of the holders of all the Bonds is to rescind and annul such declaration and its consequences. Upon the happening and continuance of a Default, the Trustee in its own name and as trustee of an express trust, on behalf and for the benefit and protection of the holders of all Bonds with respect to which such Default has occurred, may also proceed to protect and enforce any rights of the Trustee and, to the full extent that the holders of such Bonds themselves might do, the rights of such Bondholders under the laws of the State of Florida or under the Indenture by such of the following remedies as the Trustee deems most effectual to protect and enforce such rights: (1) by mandamus or other suit, action or proceeding at law or in equity, to enforce the payment of the principal of, premium, if any, or interest on the Bonds then outstanding, or for the specific performance of any covenant or agreement contained in the Indenture or in the FHA Note or the Mortgage, or to require the Issuer to carry out any other covenant or agreement with Bondholders and to perform its duties under the Act; (2) by pursuing any available remedies under the FHA Note and the Mortgage; realizing or causing tocbereali realized through sale or otherwise auponhthe security pledged under the Indenture; and (4) by action or suit in equity, to enjoin any acts or things that may be unlawful or in violation of the rights of the holders of Bonds. WVA If any Default has occurred and if requested in writing to do so by the holders of not less than 25% of the Bond Obligation with respect to which there is a Default, and if indemnified as provided in the Indenture, the Trustee is obligated to exercise such one or more of the rights and powers conferred by the Indenture as the Trustee, being advised by counsel, deems most expedient in the interest of the Bondholders. Subject to the provisions of the Indenture, the holders of a majority of the Bond Obligation with respect to which a Default has occurred have the right at any time, by an instrument in writing executed and delivered to the Trustee, to direct the time, method and place of conducting all proceedings to be taken in connection with the enforcement of the terms and conditions of the Indenture, or for the appointment of a receiver or any other proceedings under the Indenture, in accordance with the provisions of law and of the Indenture. Remedies of Bondholders No holder of any Bond has any right to institute any suit, action or proceeding in equity or at law for the enforcement of the Indenture or for the execution of any trust under the Indenture or for the appointment of a receiver or any other remedy under the Indenture, unless (a) a default occurred of which the Trustee has been notified as provided in the Indenture; (b) such default has become a Default; (c) the holders of at least 25% of the Bond Obligation have made written request to the Trustee and have offered reasonable opportunity to the Trustee either to proceed to exercise the powers granted in the Indenture or to institute such action, suit or proceeding in its own name; (d) such holders have offered to the Trustee indemnity as provided in the Indenture; and (e) the Trustee within 60 days thereafter fails or refuses to exercise the powers granted in the Indenture, or to institute such action, suit or proceeding; no holders of the ?•fonds, however, will have any right to affect, disturb or prejudice the lien of the Indenture or the rights of any other holders of Bonds or to obtain priority or preference over any other holders or to enforce any right under the Indenture. Nothing contained in the Indenture, however, affects or impairs the right of any Bondholder to enforce the payment of the principal of, the premium, if any, and interest on any Bond at the maturity thereof or the obligation of the Issuer to pay the principal of, premium, if any, and interest on the Bonds issued under the Indenture to the owners thereof, at the time, in the place, from the sources and in the manner set forth in the Bonds. Servicing the Mortgage Loan; Mortgage Servicing Agreement The Trustee is entering into a Mortgage Servicing Agreement dated as of August 1, 1992, by and between the Trustee and Continental Securities Corporation (the "Mortgage Servicer "). The Trustee will have the right to replace the Mortgage Servicer, upon a default by the Mortgage Servicer as provided for in the Mortgage Servicing Agreement. Mortgage Insurance Benefits Upon a default by the Owner in the due and punctual payment of the principal of (including, without limitation, a principal payment below what is required by the FHA Note) and interest on the FHA Note, the Trustee is to immediately notify the Issuer, the Owner, and any holder of 25% or more in aggregate principal amount of the Bonds then outstanding who has filed a written request with the Trustee for such notification. The Trustee is required to take all steps necessary to obtain mortgage insurance benefits in cash, including giving FHA appropriate and timely notice of default, assigning the FHA Note to FHA following the expiration of applicable grace periods on .1€. the FHA Note and specifically stating that a claim for mortgage insurance benefits relates to a financing with tax - exempt bonds for which the Trustee will assert its right to priority processing by FHA. The Trustee is to apply any FHA mortgage insurance benefits received to the redemption of Bonds. Supplemental Indentures Without the consent of the Bondholders, the Issuer and the Trustee may enter into supplemental indentures (not inconsistent with the terms of the Indenture or materially adverse to the holders of the Bonds) .for any one or more of the following purposes: (a) to cure any ambiguity or formal defect or omission in the Indenture; (b) to change or modify any provision of the Indenture so as to harmonize to the maximum extent practicable the provisions of the Indenture with existing rules, regulations and procedures of FHA; (c) to grant to or confer upon the Trustee for the benefit of the Bondholders any additional rights, remedies, powers or authority that may lawfully be granted to or conferred upon the Bondholders or the Trustee or either of them; (d) to subject to the lien and pledge of the Indenture additional revenues, properties or collateral; (e) to modify, amend or supplement the Indenture or any indenture supplemental thereto in such manner as to permit the qualification thereof under the Trust Indenture Act of 1939, as amended, or any similar federal statute hereafter in effect or under any state securities laws; (f) in connection with any other change in the Indenture which, in the judgment of the Trustee, is not to the prejudice of the Trustee or the Bondholders; or (g) to modify or amend the Indenture as necessary to secure a rating on the Bonds acceptable to the Issuer, except no change may be made to the maturity, interest rate or amount of the Bonds. With the consent of the holders of not less than two - thirds of the principal amount of the Bonds to be affected by the execution of the supplemental indenture, the Issuer and the Trustee may from time to time enter into supplemental indentures for the purpose of modifying, altering, amending, adding to or rescinding any of the terms or provisions contained in the Indenture or in any supplemental indenture; provided, however, that nothing in the Indenture or in any supplemental indenture permits, or can be construed as permitting (a) an extension of the stated maturity or reduction in the principal amount or reduction in the rate of interest on or extension of the time of payment, of interest on, or reduction of any premium payable on the redemption of, any Bonds, or a reduction in the Owner's obligation on the FHA Note, without the consent of the Holders of all of the Bonds then outstanding, or (b) the creation of any lien prior to or on a parity with the lien of the Indenture, or (c) a reduction in the aforesaid aggregate principal amount of Bonds the holders of which are required to consent to any such supplemental indenture, without the consent of the holders of all the Bonds at the time outstanding, or (d) the modification of the rights, duties or immunities of the Trustee, without the written consent of the Trustee, or (e) a privilege or priority of any Bond over any other Bonds, or (f) any action that results in the interest on the Bonds becoming included in gross income for federal income tax purposes. -19- 0 The Trustee During any event of default, the Trustee is to exercise rights and powers vested in it by the Indenture with the degree of care and skill a prudent person would exercise in the conduct of his or her own affairs. Otherwise, the Trustee is to perform only such duties as are specifically set forth in the Indenture. In the absence of bad faith on the part of the Trustee, the Trustee may conclusively rely upon any certificate or opinion furnished it. The Trustee is not liable in the absence act of bad faith for any error of judgment, able any aion of the Bonds. en in accordance with the direction of the holders of any app prop The Trustee may acquire and hold Bonds and otherwise deal with the Issuer and the Owner as though it were not the Trustee. THE FHA NOTE AND MORTGAGE The following is a brief summary of the FHA Note and Mortgage. The summary does not purport complete s f fi entirety by reference to he FHA N and Mortgagecop e of are on e with the Trustee. The FHA Note is a nonrecourse obligation (which means that the Owner is not liable for the payment thereof beyond the amount realized upon the security therefor) providing for level monthly payments of principal and interest. In the event of a failure to make a payment when due and the failure to correct such failure by the next due date, the entire amount of the FHA Note may be declared due and payable by the Trustee. In the event of a late payment of more than fifteen days, the Trustee may charge and collect Note is ercent of the late from prepayable he O only n accordance p to two e provisions thereof including the p y payment of premiums. Pursuant to the Modification of Mortgage Note and Mortgage executed by the Owner in accordance with the terms of the Loan Work -Out Agreement, the interest rate on the FHA Note and Mortgage has been reduced from 10.625% to % per annum, the level monthly payments of principal and interest have been reduced and the optional prepayment provisions have been altered to conform to the optional redemption provisions of the Bonds (see "TI-IF. BONDS -- Optional Redemption" herein). Notwithstanding any prepayment prohibition or penalty otherwise required by the ull without prepayment penalty if HUD FHA Note, the indebtedness may be prepaid in full. determines that prepayment to avoid an insurance claim is in the best interest of the Federal Government. HUD has indicated that it would make its determination to exercise this provision only if: (a) the Owner has defaulted and HUD has received required notice of default; (b) HUD determines that the Project has been experiencing a project income deficiency that has not been caused solely by management inadequacy or lack of owner interest and that is of such maanitaulderoje t ape Ot g expo seseand fund ball required required debt service payments, p Y P HUD reserves; -20- W HT`1D finds there is a reasonable likelihood that the Owner can arrange to refinance the defaulted loan at a lower interest rate, or otherwise reduce the debt service payments through partial prepayment; and (d) HUD determines that refinancing the defaulted loans at a lower rate or partial prepayment is necessary to restore the Project to a financially viable condition and to avoid an insurance claim. The Mortgage conveys the Owner's interest in the Project to secure the payment of the FHA Note. The Mortgage (including the FHA Regulatory Agreement incorporated therein) requires that: (1) fire and casualty insurance be maintained on the Project payable to the Trustee in an amount not less than necessary to comply with the applicable co- insurance percentage but in no event less than 100% of the insurable values or the unpaid balance of the FHA Note plus the Mortgage Loan whichever is lower: (2) the mortgage insurance premiums, taxes and utility assessments, fire and casualty insurance premiums, and deposit to the replacement fund be paid monthly to the Mortgage Servicer together with the monthly payment on the FHA Note; (3) the Owner not place any liens on the Project inferior (without FHA consent) or superior to the Mortgage; and (4) the Owner maintain the Project in good repair and condition. THE FRA REGULATORY AGREEMENT The following is a brief summary of the FHA Regulatory Agreement. The summary does not purport to be complete or definitive and is qualified in its entirety by reference to the FHA Regulatory Agreement, copies of which are on file with the Trustee. Pursuant to the FHA firm commitment to insure the FHA Note (see "FHA INSURANCE "), the Owner and HUD have entered into the FHA Form of Regulatory Agreement (the "FHA Regulatory Agreement "). The FHA Regulatory Agreement provides, among other things, that the Owner must rent the units in the Project to eligible tenants, determined in accordance with FHA regulations. The FHA Regulatory Agreement incorporates the provisions of the FLOP Contract by reference. The Owner is required to give priority to persons and families designated in the National Housing Act an absolute preference or priority and to maintain the Project in good condition. Dwelling units are not to be rented for a period of less than 30 days nor more than three years. The FHA Regulatory Agreement also prohibits the conveyance, transference or encumbrance of the Project or any right to manage the Project without the prior written approval of FHA. The Owner may not make, receive, or retain any distribution of assets or income from the Project except from "surplus cash" and only as permitted under applicable laws. The Owner is prohibited, without the prior written approval of FHA, from remodeling, adding to or demolishing any part of the Project or engaging in any other business or activity or incurring any obligation or liability not in connection with the -21- Project or requiring as a condition of occupancy of any unit a deposit greater than the prepayment of the first month's rent plus a security deposit of one month's rent or permitting the use of the Project for any other use. The Project and all books, records, and documents relating thereto are required to be subject to examination and inspection at any reasonable time by FHA. Books and accounts of the Project are to be kept in accordance with FHA requirements and complete annual financial reports are to be furnished to FHA within 60 days of the end of each fiscal year. In the event of a default in the performance of the Owner's obligations under the FHA Regulatory Agreement, even in the absence of a default under the FHA Note or the Mortgage, FHA may (a) notify the Mortgagee of such default and request the Mortgagee to declare a default under the FHA Note and the Mortgage and the Mortgagee may, at its option, declare the whole indebtedness due and proceed with assignment of the FHA Note and the Mortgage to FHA, (b) collect all rents and charges in connection with the operation of the Project and use such collections to pay the Owner's obligations under the FHA Regulatory Agreement and under the FHA Note and the Mortgage and the expenses of maintaining the Project, (c) take possession of and operate the Project, and (d) apply for an injunction, appointment of a receiver or such other relief as may be appropriate. THE SUPPLEMENTAL REGULATOR' AGREEMENT The following is a summary of the Supplemental Regulatory Agreement. The summary does not purport to be complete or definitive and is qualified in its entirety by reference to the Supplemental Regulatory Agreement, copies of which are on file with the Trustee. The Issuer, as a condition of issuing the Prior Bonds, required the Owner to enter into a Supplemental Regulatory Agreement as to Tax Exemption (the "Supplemental Regulatory Agreement ") in which the Owner covenants, subject to certain limitations described below, to comply with the requirements of Section 103(b)(4)(A) of the Internal Revenue Code of 1954, as amended (the "1954 Code "), as made applicable by Section 1313(a) of the 1986 Code, and further represents that it has complied with such requirements on a continuous basis since the date of issue of the Prior Bonds. Those requirements must be continuously met subsequent to the date of issue of the Prior Bonds in order that interest on the Bonds commencing from the dated date of the Bonds be excludable from gross income for federal income tax purposes. In the Supplemental Regulatory Agreement, the Issuer and the Owner each covenant that they will not knowingly take or permit to be taken any action, and represent that they have not knowingly taken or permitted to be taken any action, which would adversely affect the exclusion of interest on the Bonds from gross income for federal income tag purposes, except that the Owner may take any action required to be taken by it under Section 221(d)(4) of the National Housing Act or the regulations thereunder, or the Mortgage Loan Documents, even if the excludability of interest on the Bonds from gross income for federal income tax purposes were thereby adversely affected. The Owner and the Issuer have also agreed to take any lawful action (other than an action prohibited by HUD), subject to prior approval by HUD (including amendment of the Supplemental Regulatory Agreement as is necessary, in the opinion of Bond Counsel) to comply fully with all applicable requirements affecting the exclusion of interest on the Bonds from gross income for federal income tax purposes under Section 103(b)(4)(A) of the 1954 Code. Under the Supplemental Regulatory Agreement, the Owner and its successors are obligated, subject to the foregoing, to operate, and the Owner has represented that it has operated at all times since the issuance of the Prior Bonds, the Project as a residential rental project, as defined in Section 103(b)(4)(A) of the 1954 Code and the Treasury Regulations thereunder. Furthermore, the Owner and its successors are obligated to cause at least 20% of the units in the Project to be, and the Owner has represented, that in fact, at least 20% of the units in the Project have been, occupied (or treated as occupied) by low or moderate income persons (as defined in the Supplemental Regulatory Agreement) continuously during a period commencing the date of issue of the Prior Bonds, and ending on the later of (a) the date which is ten years after the date on which at least 50% of the units were first occupied or (b) the date which is 50% of the total number of days which comprise the stated term of the Prior Bonds which were outstanding and the longest maturity of the Bonds or (c) the date on which any assistance under Section 8 of the United States Housing Act of 1937 terminates (the "Occupancy Restrictions Period "). In order to determine whether prospective tenants are of low or moderate income, the Owner has agreed to require, and has represented that it did require at all times since the issuance of the Prior Bonds, submission of income certifications in which prospective low or moderate income tenants certify that the individuals or families to occupy such units qualify under HUD's Section 8 guidelines (without adjustment for family size) as being of low or moderate income (the "Income Certification "). A material misrepresentation by such prospective tenant in the Income Certification will be and has been at all times since the issuance of the Prior Bonds, under such tenant's lease, grounds for default and eviction; the enforcement of that provision may, however, be subject to limitations imposed now or in the future by laws designed to protect tenants' rights. The Supplemental Regulatory Agreement also requires that (a) the Project has been acquired, constructed and equipped for the purpose of providing multi - family residential rental. property and constitutes multi- family residential rental property (as defined in the Supplemental Regulatory Agreement); (b) the Project consists of similarly constructed dwelling units, together with functionally related and subordinated facilities and has comprised and will comprise a building or structure or several proximate buildings or structures which (i) are located on a single tract of land or two or more parcels of land that are contiguous; (ii) are owned by the same person for federal income tax purposes; and (iii) are financed pursuant to a common plan; (c) the Owner has not occupied and will not occupy any dwelling unit in any building or structure containing fewer than five dwelling units; (d) all the dwelling units in the Project have contained at all times since the issuance of the Prior Bonds and will contain complete facilities for living, sleeping, eating, cooking, and sanitation; (e) none of the units in the Project have been at any time since the issuance of the Prior Bonds or will be at any time utilized on a transient basis by being leased for a period of less than 30 days or by being used as a hotel, motel, dormitory, fraternity house, sorority house, rooming house, hospital, nursing home, sanitarium, rest home or trailer park or court; and (f) all the units in the Project (other than a unit for a resident manager or maintenance personnel) have been at all times since the issuance of the Prior Bonds and will be leased, rented, or available for lease or rental on a continuous basis to members of the general public for the longer of the Occupancy Restrictions Period or the remaining term of the Bonds (the "Rental Restrictions Period "). .23. The Supplemental Regulatory Agreement transfer of deed in lieu of foreclosure or similar event the Supplemental Regulatory provides that upon foreclosure or Agreement and its restrictions will terminate. In such event, the Owner or a related person is prohibited from reacquiring an ownership interest in the Project during the Occupancy Restrictions Period. In addition the Supplemental Regulatory Agreement Provides for termination upon involuntary 3' e lt o f unforeseen events such as fire, seizure, requisition or condemnation of the Project, arY oss or substantial destruction as a result of Provided that, within a reasonable time period, either the Bonds are retired in full or the amounts received as a consequence of such event are used to provide a project which satisfies the requirements of Section 103(b)(4)(A) of the 1954 Code. The Supplemental Regulatory representative of the Issuer to inspect Agreement permits any duly Project with respect to the incomes of tenants a.nd require sthe LOwneOwner o submit to Issuer other information, documents or certifications requested by the Issuer hick the Issuer deems reasonably necessary to substantiate the Owner's with the provisions of the Supplemental Regulato A en continuing compliance determine whether the Owner is in compliance with theSu and the 1954 Code to Agreement and requires that the Owner submit all Income Certifications to the Issuer upon request and, each month after the Project is available for occupancy submit Issuer Issuer and the Trustee a certificate stating he occupied d treated as occupied, g percentage of the units whichtwere' the preceding month by low or moderate income persons. In addition, the Owner is required upon discoverin �' Regulations, at all times during Provide immediate written notice f such violation tSupplemental he Issuer anRegulatory the Agreement to t Trustee. The Owner has covenanted and agreed in the Supplemental Regulatory Agreement to cause or require, as a condition precedent to an assignment or any other disposition. of the Project termination Y conveyance transfer, Occupancy Restrictions and the Rental Restrictions, thatt the transferee of' assume b thne writing in a form acceptable to the Issuer, the Trustee and HUD, all duties and obligations of the Owner under the Supplemental Regulatory Agreement executed counterpart of such instrument of assumption be delivere to the Issuer that nd the Trustee prior to any conveyance, transfer, assignment or other disposition. The Trustee is entitled for any breach of the provisions of the Supplemental Regulatory Agreement to all remedies both at law or in equity. The availability of equitable remedies such as specific performAce or an subject to ' the discretion of the court and no assurances can be e able given that the Trustee would b injunction is generally subto obtain such relief after proving a breach by the Owner of any of the covenants contained in the Supplemental Regulatory Agreement. Agreement is made expressly su ordinte to theeMort Furthermore, Supplemental enforcement Regulatory Supplemental Regulatory Agreement will not result in an enforcement of the Loan., or claim against the Project, the Mortgage Loan proceeds, y claim under the Mortgage made with the Trustee, as Mortgagee, or another person or entity requireserve U deposit or the Trustee, as Mortgagee, in connection with the Mortgage or other income from the Project, except that the Owner has agreed to pay to th Dssuer g ge transaction, or against the rents but only to the extent of any available "surplus cash" as defined in the FHA Regulat Agreement, an amount equal to any rents or other amounts received by the Owner for any units in the Project which were in violation of the Supplemental Re Ory Agreement during the period such violation continued. the Consequently, the rightory ts la la Issuer or the Trustee to enforce a claim for money damages are severely restricted. Among other things, it would not be possible to accelerate the debt evidenced by the Mortgage Note or to seek mortgage insurance benefits as a result of the violation by the -z4- Owner of the covenants contained in the Supplemental Regulatory Agreement. IS NO PROVISION FOR AN ACCELERATION OF THE INDEBTEDNESS EVIDENCED THERE BY THE BONDS OR PAYMENT OI' INDEBTEDNESS EVIDENCED SUCH INTEREST BECOMES INCLUDABLEOINAGROSS INTEREST INCOME FOR FEDERAL INCOME TAX PURPOSES. the Supplemental Regulatory 'g anything in the Indenture, the Loan Work -Out t Agreement (collectively,'the'Bond Docu ment �7 to the contrary, the provisions of the Bond Documents are subordinate to all applicable HUD Mortgage Insurance Regulations and related administrative of any con$ict between the provisions of the Bond ccents and the provisions of any 9luirements. In the event applicable HUD Regulations, related HUD administrative requirements or Mortgage Loan Documents, the HUD re gulations, related administrative requirements or ortg� Loan shall control THE LOAN WORKOUT AGREEMENT The following is a brief summary of certain provisions of the Loan Work -Out Agreement. This summary does not purport to be complete or definitive and is qualified in its entirety by reference to the Loan Work -Out Agreement, copies of which are on file with the Trustee. Pursuant to the Loan Work -Out Agreement, the Issuer agrees to issue the Bonds for the purpose of refunding the Prior Bonds, which are to be redeemed as a result of the Owner's default under the FHA Note. See "THE PROJECT -Prior Operating History. Pursuant to the Loan Work -Out Agreement, the Owner agrees to deposit $ the Trustee on or prior to the date of the delivery of the Bonds. Such amount is to be used as provided in the Indenture. with As described above under "THE INDENTURE," the Trustee is to apply available to it to reimburse HUD for its payment of FHA mortgage insuranc amounts thereby to acquire the FHA Note from HUD. The Owner agrees to amend the F reduce the interest rate from 10.625% per annum to HA Note to %per annum. Representations and Warranties of the Owner The Owner represents in the Loan Work -out Agreement that it is not as of the date of the delivery of the Bonds in breach of or in default under any of the provisions of the Supplemental Regulatory Agreement and that it has cont 103(bx4)(A) of the 1954 Code. inuously operated the Project as a qualified multifamily residential rental housing facility within the meaning of Section The Owner also represents that it has been in continuous default under its obligations with respect to the FHA Note since August 1, 1991, and that the operating income of the Project has been insufficient since such time to make full and timely Payments with respect to the FHA Note. -25- Tax Covenant resents that it has not taken or permitted to be taken action that would ould. The Owner rep gross income for federal and covenants thaateitt will exclusion f o interest e or td onethe{BoT a from b inane and taken such adversely affect t income tax Purposes, and that it will make and take q acts of feting as may from time to time be required under the 1954 Code or to the 1986 Code to maintain such exclusion. r Limitations on Enforceability Non - Recourse Obligation; Othe Agreement and under the bl recourse to the Project. The Owner and its general Partners will The Ownertseabhgations under the Loan Work -Out FHA Note are lime no personal liability with respect to a breach of or default under the Loan Work-Out have P Agreement or the FHA documents. IJ in the Loan In the event of a breach by the Owner of the a covenants pec fic performance of the Loan Out Agreement, ction against any `isolation or violations of equitable eement, the Issuer or the Trustee may sue for specific Work -Out Agreement or for an fij� uit The availability other remedy available at law or in eq Y generally subject to the pursue any dy erformance or an injunction i e will remedies such as specific given that the Issuer or f e Treovenants discretion of the court, and no assurances can be g� the Owner of any eement. Furthermore, as a condition of FHA be able to obtain such relief after proving a breach by reement is made expressly contained in the Loan Work -Out Agr and enforcement of the Loan insuring the Mortgage Loan, the Loan Work -Out Ag atio is under the Mortgage Loa' to the oblig ressly limited so that enforcement lLoan result ceeds, any Work -Out Agreement i exp or against the Project, the mortgage re aired by Loan, a gee or any other person or entity q claim under the Mortgage reserve or deposit, made with the Mge g ent under the Loan UD in connection with the Mortgage Loan transaction, or against he rents or Other H surplus cash) for paym income from the Project (other than available Burp other things, it would not Agreement. Consequently, the rights of the Issuer and the 'Trustee toe enforce Work -Out Agr damages are severely restricted. Among or claim for monetary the FHA Note or to seek FHA mortgage the be possible to accelerate the debt evidenced by the Owner of a covenant ro main form h e insurance benefits ase menttwithout FHAbapproval. There is a° pent of additional Loan Work -Out Agr the Bonds or for p Ym accelerationmt f neon the Bonds becomes included in gross income for federal income tax interest. purposes. TAX. TREATMENT all as ects of federal taxation that may ' be The following is a discussion of certain federal income tax matters under existing u ort to deal with particularly those statutes. It does not p rP the federal relevant to particular Bond owners. Prospective investors, p tax subject to special nd disposing of the Bonds, �u isdiction. any ecial rules, are advised to consult their own tax advisor regarding income tax consequences of owning the Tax Reform Act of 1986, consequences arising under the laws of any state or other t g excepted from certain ofuiremenchanges. or he though subssanions such as the Bonds, certain were excepCode y compliance req certain trap the 1954 Code in the comp the result, rules established by Project remain in effect for the Project subsequent to the issuance of the Bonds. -26- !p Section 1.103 -8(b) of the Income Tax Regulations (the "Regulations ") sets forth one requirements for compliance with Section 1093(bro4e(As located in Code. Tha Regulations the require, in part, that at least 20% (15% or projects complete rental units in the Project must a Regulations ons equirelthat, once navailablelfor the Qualified Project Period. In addition, occupancy, each rental unit in the Project must be rented or available for rental on a continuous basis during the longer a (a) the remainder of the Regulations pr vi e that Bonds are Outstanding or (b) the Qualified Project Period. The Regal the failure to satisfy the foregoing requirements on a continuous basis, unless corrected within a reasonable cure peha a od of not less been discovered by the0exerese of reasonableodiligence, is first discovered or would will cause the loss of tag exclusion from gross income for federal income tax purposes of the interest on the Bonds as of the date of the issuance of the Bonds. In order to comply with these requirements, the City has required, among other things, that the Owner execute the Supplemental Regulatory Agreement as to Tax Exemption with respect to the Project, providing, among other things, that the Project has been and will escribed continue the foregoing maintained and available for rental for the periods and in the manner d See "THE SUPPLEMENTAL REGULATORY of causing the Project rto be operated d in the covenants made by the Owner for the pure compliance with the requirements of Section 103(b)(4)(A) aft he 1954 with such Code an description of the representations of the Owner regarding p compliance requirements.. As described therein, the Owner's covenants axe, however, subject to compliance with certain FHA requirements or if the representations sett forth therein with the Supplemental Regulatory Agreement are inaccuraeo enforcement e erely limi ed and m y ble inadequate to prevent the loss of Bondholders excludability of interest onthere�is n grovis-non o�acceleratio vortredemptio of the the Bonds. In such event, d to hold the Bonds, which then bear Bonds and the owners of the Bonds may be require tameable interest, anti? maturity. onal The Code of contains the Bonds order t requirements he into est on t e Bonds betandsremain to the issuance purposes. Failure to comply with excluded from gross income for federal income tax pure such requirements date of issueeofthe Bonds. The Authority has o enantedl n the retroactive to Indenture antions required by the Codetoemainthaine exclusion nt from gross in income of taking, the interest on the Bonds. In the opinion of Bryant, Miller and Olive, P.A. Bond Counsel, assuming continuing compliance bur the Authority and �n s and judicial with the Cisions, interest on the above, under existing statutes, regulations, u oses except that such Bonds is excluded from gross income for federal income tax od during which such Bond exclusion shall not apply to interest on any Bond for any p is held by any person who is a "substantial user" of the Project or a "related person" within the meaning of Section 1 purposes Federal alternatrvr e alternative Bonds is imposed d on item of tax preference for pure individuals or nimumr tax when any Bondeis held by eaBcorporation. eThe alt to rnative alternative mi -27- E2 75% of the excess of such mix mum taxable income of a corporation must be increased by "Adjusted usted current earnings over its alternative loss deduction) taxable income corporation's adj The Bonds are exempt from all (before this adjustment and the alternative tax net Bonds. e Bt to Chapter pt Florida Current Earning" will include interest taon thmP imposed p present intangible personal property Statutes. Except as described above, Bond Counsel will express n ooPiniO. receipt or accrual of osition of Bonds. Prospective purchasers of Bonds should be aware Federal income. tax consequences resulting from ral I'edeTa�ncome tax consequences, interest on, or d1SP of Bonds may result in collate that the ownership property reduction of the loss reserve deductlone for p on the including (i) the denial of a deductioneor interest on indebtedness din ed or continue lnc g Bonds, (ii) the to purchase or carry antes by 15% of certain items, Including rn u g and casualty it comp modified alternative minimum taxable imposed on corporations, (iv) the inclusion Bonds, (iii) the inclusion of interest on Bonds In corporations doing business in the income" for purposes of the environ o f certain foreign rP of interest on the Bonds in of earning arch Profits tax, (v) the inclusion of interest corporations United States for piuP and (vi) the and Profits at the close of the taxable Yep reci Tents of passive income subject to Federal income taxation of certain Subchapter with Subchapter C earnings oss income" by P and Railroad Retirement benefits for purposes of determining inclusion of interest on the Bonds in "modified adjusted purposes certain Social Security gross income for Federal income tax purr whether such benefits are included in gr ADVERSE CHASE, OyRSHIP, SALE OR DISPOSITION OF THE BONDS AND THE PURCHASE, FOR CERTAIN INDIVII CONSULT WITH THEIR RECEIPT OR ACCRUAL OF THE INTEREST THEREON MAY FEDERAL TAX CONSEQUENCES BONDHOLDERS. PROSPECTIVE BONDHOLDERT SHOULD TION IN THAT TAX SPECIALISTS FOR INFORMATION and ears legislative proposals have been introduced in Congress) the During recent y consequences resulting proposals in some cases enacted, that altered c filar se he Bo ds es on retroactive basis. Such ownership of obligations that alte ed then the Bonds. In some evalue of obligations have contained provisions that have affected them ending which could are p of Bonds alteration of Federal tax Consequences. may from ownership similar to the Bonds. From time to tme, legislative proposals ' g f rO e proposals will not be have an effect on both the Federal tax consequences resulting the enacted that would or might apply to, or have an adverse effect upon, and their market value• a assurance can be given that legl introduced or � Bonds. ABSENCE OF LITIGATION e date of delivery of the Bonds, tthere is no controversy or litigation of any On the of the effect that, to its best restrain nleoTg enjnd belief, of the Bonds, the proceedings of oin the issuance, sale, execution or delivery nature pending or affecting the validity pledge or application of Bonds, or in any waY contesting of the Bonds and the existence ositions•or the Issuer taken with respect to the issuance d for the payment oeelof the to their respective p any money or secure officers of th powers of the Issuer or the title of any -28- LEGAL MATTERS All legal matters incident to the authorization, issuance, sale and delivery of the Bonds by the Issuer to the Underwriters are subject to the approval of legality by Bryant, Miller and Olive, P.A., Tallahassee, Florida, Bond Counsel. Certain legal matters will be passed upon for the Underwriters by Jones Hall Hill & White, A Professional Law Corporation, San Francisco, California, Counsel to the Underwriters, and for the Owner by Byrne, Costello & Pickard, P.C., Syracuse, New York. Krooth & Altman, Washington, I.C. has served as Special Counsel to the Owner in this transaction. The compensation of Bond Counsel and counsel to the Underwriters is contingent upon the issuance and delivery of the Bonds. ENFORCEABILITY OF REMEDIES The remedies available to the Trustee and the owners of the Bonds upon an event of default under the Loan Work -Out Agreement, the Supplemental Regulatory Agreement, the Indenture or any other document described herein are in many respects dependent upon regulatory and judicial actions which are often subject to discretion and delay. Under existing law and judicial decisions, the remedies provided for under such documents may not be readily available or may be limited. The various legal opinions to be delivered concurrently with the delivery of the Bonds will be qualified to the extent that the enforceability of certain legal rights related to the Bonds is subject to limitations imposed by bankruptcy, reorganization, insolvency or other similar laws affecting the rights of creditors generally and by equitable remedies and proceedings generally. MARKETING Banc One Capital Corporation and Newman & Associates, Inc. (collectively, the "Underwriters ") are offering the Bonds at the prices set forth on the inside cover page hereof. The initial offering prices may be changed from time to time and concessions from the offering prices may be allowed to dealers, banks and others. The Underwriters have received an underwriting fee in an amount equal to approximately _% of the original principal amount of the Bonds in connection with their services as underwriters for the Bonds. Out of this fee the Underwriters are obligated to pay certain costs of issuance of the Bonds in an amount equal to approximately % of the original principal amount of the Bonds. RATING Standard & Poor's Corporation has given the Bonds the rating set forth on the cover page of this Official Statement. The rating agency may have obtained and considered information and material that have not been included in this Official Statement. Generally, the rating agency bases its ratings on information and material furnished and on investigations, studies and assumptions made by it, The rating is not a recommendation to buy, sell or hold the Bonds. The rating reflects only the views of the rating agency and an explanation of the significance of such ratings may be obtained from it. No assurance can be given that the rating will be maintained for any given period of time or that the rating may not be revised downward or withdrawn entirely by the rating agency. if in its judgment, circumstances warrant. Any such downward .2g. change in or withdrawal of the rating may have an adverse effect on the market price of the Bonds. The Underwriters and the Issuer have undertaken no responsibility after the offering of the Bonds to assure the maintenance of the rating or to oppose any such revision or withdrawal. OTHER MATTERS The foregoing summaries and explanations do not purport to be comprehensive, and are expressly made subject to the exact provisions of documents referred to herein. Copies of the Indenture, the Supplemental Regulatory Agreement, the Loan Work -Out Agreement and the other documents referred to herein may be obtained from the Trustee. Any statements in this Official Statement involving matters of opinion or forecast, whether or not expressly so stated, are intended as such and not as representations of fact. This Official Statement is not to be construed as a contract or agreement between the Issuer or the Underwriters and the purchasers or holders of any Bonds. -30- The execution and delivery of this Official Statement have been duly authorized by the Issuer and the Owner. CITY OF CLEARWATER, FLORIDA By: _ Title: DREW GARDENS ASSOCIATES, LTD., a Florida Iimited partnership By: General Partner -31- /'IN (THIS PAGE INTENTIONALLY LEFT BLANK)