HomeMy WebLinkAboutR-91-0696J-91-757
9/17/91
RESOLUTION NO P 6 (9 6
WITH ATTACHMENT(S�
A RESOLUTION,OF THE CITY CO&ISSION OF THE CITY OF MIAMI,
FLORIDA, WITH ATTACHMENTS, AUTHORIZING THE ISSUANCE OF AN
AMOUNT NOT TO EXCEED $25,000,000 IN AGGREGATE PRINCIPAL
AMOUNT OF THE CITY OF MIAMI, FLORIDA, TAX ANTICIPATION
NOTES, SERIES 1991 FOR THE PURPOSE OF MEETING CERTAIN OF THE
CITY'S CASH FLOW REQUIREMENTS FOR THE FISCAL YEAR ENDING
SEPTEMBER 30, 1992; APPROVING THE FORM OF THE NOTES;
PROVIDING FOR THE RIGHTS AND SECURITY OF ALL NOTE HOLDERS
PURSUANT TO THIS RESOLUTION; APPOINTING A PAYING AGENT
FOR THE NOTES; AUTHORIZING THE CITY MANAGER OR ASSISTANT
CITY MANAGER TO TAKE ANY ACTION NECESSARY TO QUALIFY THE
NOTES FOR DEPOSIT WITH THE DEPOSITORY TRUST COMPANY;
AUTHORIZING THE NEGOTIATED SALE OF THE NOTES; APPROVING
THE FORM, EXECUTION AND DELIVERY OF A NOTE PURCHASE
AGREEMENT TO EFFECT THE NEGOTIATED SALE OF THE NOTES;
APPROVING THE FORM AND DISTRIBUTION OF A PRELIMINARY
OFFICIAL STATEMENT; APPROVING THE FORM AND EXECUTION OF
AN OFFICIAL STATEMENT; AUTHORIZING THE CITY MANAGER OR
ASSISTANT CITY MANAGER ON BEHALF OF THE CITY TO DETERMINE
THE FINAL DETAILS OF THE NOTES WITHIN THE PARAMETERS
ESTABLISHED BY THIS RESOLUTION; AUTHORIZING THE MAYOR OR
VICE MAYOR, CITY MANAGER OR ASSISTANT CITY MANAGER, AND
THE CITY ATTORNEY AS TO THE FORM TO EXECUTE THE NOTE
PURCHASE AGREEMENT CONSISTENT WITH SUCH FINAL DETAILS;
AUTHORIZING OTHER OFFICERS OF THE CITY TO TAKE ALL OTHER
ACTIONS NECESSARY IN CONNECTION WITH THE ISSUANCE OF THE
NOTES; AND PROVIDING FOR AN EFFECTIVE DATE.
WHEREAS, The City of Miami, Florida (the "City"), anticipates certain temporary cash
shortages during the fiscal year of the City ending September 30, 1992 (the "Fiscal Year")
because cash disbursements have been scheduled to be made in the Fiscal Year before sufficient
moneys therefor are expected to be available to the City; and
WHEREAS, pursuant to the Constitution and the laws of the State of Florida (the
"State"), in particular Chapter 166, Florida Statutes, as amended, and pursuant to the Charter
of the City, as amended (collectively, the "Act"), the City desires to issue its Tax Anticipation
Notes, Series 1991, in an aggregate principal amount not to exceed $25,000,000 (the "Notes")
for the purpose of meeting certain of the City's cash flow requirements for the Fiscal Year and
for the purpose of paying certain of the costs of issuance of the Notes; and
WHEREAS, for reasons more fully set forth herein, the City Commission of the City
(the "Commission") finds and determines it to be in the best interest of the City to authorize the
sale of the Notes on the basis of a negotiated sale to PaineWebber Incorporated, Grigsby
Brandford Powell, Inc., AIBC Investment Services Corp., and Guzman & Company.
(collectively, the "Underwriter"), rather than a public sale by competitive bid; and
WHEREAS, in order to take advantage of currently existing interest rates, due to
uncertainties of the financial markets which have resulted from current economic conditions in
the United States of America and from recent events in foreign countries, particularly in the
Middle East and the Union of Soviet Socialist Republics, and the necessity of immediate response
to market conditions by the City, and because of the characteristics of the Notes, it is necessary
for the Commission to authorize the City Manager or any Assistant City Manager to determine
on behalf of the City the final details of the Notes within the parameters set forth in this
Resolution and to authorize the Mayor or the Vice Mayor, the City Manager or Assistant City
Manager, and the City Attorney as to form, to execute a final Note Purchase Agreement on
behalf of the City evidencing such final details;
',TTACHMENTS
CONTAINED
CITY COMMISSIONT
ME ING OF
S E P 26 1991
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NOW,THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE CITY OF
MIAMI, FLORIDA:
SECTION 1. RECITALS. The recitals set forth above are hereby incorporated by
reference into the body of this Resolution, as if fully set forth herein.
SECTION 2. AUTHORITY FOR THIS RESOLUTION. This Resolution is adopted
pursuant to the provisions of the Act.
SECTION 3. FINDINGS. It is hereby ascertained, determined and declared:
(a) Under the Act, the City is entitled to levy and receive ad valorem taxes on
real and tangible personal property within the City.
(b) The principal of and interest on the Notes and all required sinking fund and
other payments shall be payable solely from the City's ad valorem taxes collected during the
Fiscal Year other than ad valorem taxes approved by referendum and levied specifically to pay
debt service on bonds or other obligations issued by the City (the "Pledged Funds"). Neither
the full faith and credit nor the taxing power of the City, Dade County, Florida (the "County")
or the State or any political subdivision thereof or governmental authority or body there in are
pledged to the payment of the principal of or interest on the Notes, except for the Pledged
Funds.
(c) The Pledged Funds are expected to be sufficient to pay all principal of and
interest on the Notes as the same become due and to make all sinking fund or other payments
required by this Resolution.
SECTION 4. RESOLUTION CONSTITUTES CONTRACT. In consideration of the
acceptance of the Notes authorized to be issued hereunder by those who shall own the same from
time to time (the "Noteholders"), this Resolution shall be deemed to be and shall constitute a
contract between the City and such Noteholders, and the covenants and agreements herein set
forth to be performed by the City shall be for the equal benefit, protection and security of the
owners of any and all of such Notes, all of which shall be of equal rank and without preference,
priority or distinction of any of the Notes over any other thereof except as expressly provided
therein and herein.
SECTION 5. AUTHORIZATION, DESIGNATION AND DETAILS OF THE
NOTES. Subject and pursuant to the provisions of this Resolution, Notes of the City to be
known as "Tax Anticipation Notes, Series 1991" are hereby authorized to be issued in an
aggregate principal amount not to exceed Twenty Five Million Dollars ($25,000,000) for the
purpose of providing funds to pay the appropriations made for the Fiscal Year in anticipation of
the receipt of the Pledged Funds and to pay the costs of issuance of the Notes. The Notes shall
be issued in such aggregate principal amount not to exceed $25,000,000 as shall be approved by
the City Manager or any Assistant City Manager. The Notes shall be sold at an underwriting
discount or fee (not taking into account any original issue discount) not to exceed ninety six
percent (96%) of the total of the aggregate principal amount of the Notes and may be sold at
such premium or at such original issue discount as shall be approved by the City Manager or
Assistant City Manager, the execution of the Note Purchase Agreement (as defined herein) by
the City, as provided in Section 17 of this Resolution, to be conclusive evidence of such approval
by the City Manager or Assistant City Manager. The Notes shall be issuable without coupons
in denominations of $5,000 each or any integral multiple thereof, shall be numbered from NR
1 upwards, shall be dated on or as of such date as shall be determined by the City Manager or
Assistant City Manager and shall not be subject to redemption prior to maturity. The Notes shall
mature no later than one year from the date of the Notes, as such date shall be approved by the
City Manager or Assistant City Manager, and shall bear interest from their date at a true interest
cost rate not to exceed 5.20%, such rate to be determined by the City Manager or Assistant City
Manager at the time of execution of the Note Purchase Agreement and shall be, in the judgment
of such officer and subject to the maximum rate limitation set forth above, the lowest rate
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available to the City under then current financial conditions taking into consideration the maturity
established for the Notes. Interest shall be payable on the maturity date of the Notes and shall
be calculated on the basis of a 360 day year of twelve (12) thirty (30) day months.
All of the particulars of this Section 5, and such other characteristics as may be necessary
or advisable to be included in the Notes or in relation to the issuance of the Notes, as approved
by the City Manager or Assistant City Manager, shall be contained in the Note Purchase
Agreement.
SECTION 6. PAYMENT OF NOTES. The principal of and interest on each Note are
payable at the principal corporate trust office of NCNB National Bank of Florida, Tampa,
Florida, as paying agent (the "Paying Agent") upon the presentation and surrender of such Note
at maturity, in any coin or currency of the United States of America which, at the date of
payment thereof, is legal tender for the payment of public and private debts.
SECTION 7. EXECUTION OF NOTES. The Notes shall be executed in the name of
the City by the Mayor and shall be approved as to form and correctness by the signature of the
City Attorney, and the seal of the City or a facsimile thereof shall be affixed thereto or imprinted
or reproduced thereon and attested by the City Clerk, either manually or with their facsimile
signatures. In case any one or more of the officers who shall have signed or sealed any of the
Notes shall cease to be such officer before the Notes so signed and sealed shall have been
actually sold and delivered, such Notes may nevertheless be sold and delivered as herein
provided and may be issued as if the person who signed and sealed such Notes had not ceased
to hold such office. Any Note may be signed and sealed on behalf of the City by such person
as at the actual time of the execution of such Note shall hold the proper office, although at the
date of such Note such person may not have held such office or may not have been so
authorized.
The Notes shall bear thereon a certificate of authentication, in the form set forth in
Exhibit "A" hereto, executed manually by the Paying Agent. Only such Notes as shall bear
thereon such certificate of authentication shall be entitled to any right or benefit under this
Resolution, and no Note shall be valid or obligatory for any purpose until such certificate of
authentication shall have been duly executed by the Paying Agent. Such certificate of the Paying
Agent upon any Note executed on behalf of the City shall be conclusive evidence that the Note
so authenticated has been duly authenticated and delivered under this Resolution and that the
owner thereof is entitled to the benefits of this Resolution.
SECTION 8. NEGOTIABILITY, REGISTRATION AND CANCELLATION. At
the option of a registered owner of a Note and upon surrender of a Note at the principal
corporate trust office of the Paying Agent with a written instrument of transfer and with guaranty
- of signature satisfactory to the Paying Agent duly executed by the Noteholder or his duly
authorized attorney and upon payment by such Noteholder of any charges which the Paying
Agent or the City may make as provided in this Section, the Note may be exchanged for a Note
of the same aggregate principal amount and maturity of any other authorized denominations.
The Paying Agent shall keep books for the registration of Notes and for the registration
of transfers of Notes. The Notes shall be transferable by the owner thereof in person or by his
attorney duly authorized in writing only upon the books of the City kept by the Paying Agent
and only upon surrender thereof together with a written instrument of transfer satisfactory to the
Paying Agent duly executed by the Noteholder or his duly authorized attorney. Upon the
transfer of any such Note, the City shall cause to be issued in the name of the transferee a new
Note or Notes.
The City and the Paying Agent may deem and treat the person in whose name any Note
shall be registered upon the books kept by the Paying Agent as the absolute owner of such Note,
whether such Note shall be overdue or not, for the purpose of receiving payment of, or on
account of, the principal of and interest on such Note as the same becomes due and for all other
purposes. All such payments so made to any such Noteholder or upon his order shall be valid
and effectual to satisfy and discharge the liability upon such Note to the extent of the sum or
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sums so paid, and neither the City nor the Paying Agent shall be affected by any notice to the
contrary.
In all cases in which the privilege of exchanging Notes or transferring Notes is exercised,
the City shall execute and the Paying Agent shall authenticate and deliver Notes in accordance
with the provisions of this Resolution. All Notes surrendered in any such exchanges or transfers
shall forthwith be delivered to the Paying Agent and canceled by the Paying Agent in the manner
provided in this Section. There shall be no charge for any such exchange or transfer of Notes,
but the City or the Paying Agent may require the payment of a sum sufficient to pay any tax,
fee or other governmental charge required to be paid with respect to such exchange or transfer.
All Notes paid, at maturity or otherwise, shall be delivered to the Paying Agent when
such payment is made, and such Notes, together with any Notes purchased by the City for
cancellation, shall thereupon be promptly canceled. Notes so canceled may at any time be
destroyed by the Paying Agent, who shall execute a certification of destruction in duplicate by
the signature of one of its authorized officers describing the Notes so destroyed, and one
executed certificate shall be filed with the City and the other executed certificate shall be retained
by the Paying Agent.
SECTION 9. NOTES MUTILATED, DESTROYED, STOLEN OR LOST. In case
any Note shall become mutilated, destroyed, stolen or lost, the City may execute and the Paying
Agent shall authenticate and deliver a new Note of like date, maturity, denomination and interest
rate as the Note so mutilated, destroyed, stolen or lost, provided that, in the case of any
mutilated Note, such mutilated Note shall first be surrendered to the City and, in the case of any
lost, stolen or destroyed Note, there shall first be furnished to the City and the Paying Agent
proof of ownership, evidence of such loss, theft, or destruction satisfactory to the City and the
Paying Agent, together with indemnity satisfactory to them. In the event any such Note shall
be about to mature or have matured, instead of issuing a duplicate Note, the City may direct the
Paying Agent to pay the same without surrender thereof. The City and Paying Agent may
charge the owner of such Notes their reasonable fees and expenses in connection with this
transaction. Any Note surrendered for replacement shall be canceled in the same manner as
provided in Section 9 hereof.
Any such duplicate Notes issued pursuant to this Section shall constitute additional
contractual obligations on the part of the City, whether or not the lost, stolen or destroyed Notes
be at any time found by anyone, and such duplicate Notes shall be entitled to equal and
proportionate benefits and rights as to lien on and source and security for payment from the
Pledged Funds with all other Notes issued hereunder.
SECTION 10. FORM OF NOTES. The text of the Notes shall be of the tenor set
forth in Exhibit A to this Resolution, with such omissions, insertions and variations as may be
necessary and desirable and authorized or permitted by this Resolution.
SECTION 11. PAYING AGENT.
(a) NCNB National Bank of Florida, Tampa, Florida, is hereby appointed to
act as Paying Agent under this Resolution and undertakes to perform such duties as are set forth
in this Resolution.
(b) The Paying Agent may at any time resign and be discharged of the duties
and obligations created by this Resolution by giving at least 60 days' written notice to the City.
The Paying Agent may be removed at any time by an instrument filed with such Paying Agent
and signed by the Mayor or the City Manager. Any successor Paying Agent shall be appointed
by the City and shall be, if other than the City or its successor entity, a bank or trust company
organized under the laws of any state of the United States or a national banking association,
willing and able to accept the office on reasonable and customary terms and authorized by law
to perform all the duties imposed upon it by this Resolution. In the event of the resignation or
removal of the Paying Agent, such Paying Agent shall pay over, assign and deliver any moneys
held by it as Paying Agent to its successor.
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SECTION 12. NO PLEDGE OF FULL FAITH AND CREDIT. Neither the full faith
and credit nor the taxing power of the City, the County or the State or any political subdivision
thereof or governmental authority or body therein are pledged to the payment of the principal
of or interest on the Notes, except for the Pledged Funds. No Noteholder shall ever have the
right to compel the exercise of the ad valorem taxing power of the City, the County or the State
or any political subdivision thereof or governmental authority or body therein or taxation in any
form of any real or personal property therein to pay such Notes or the interest thereon except
for those ad valorem taxes of the City collected during the Fiscal Year which constitute Pledged
Funds.
SECTION 13. COVENANTS AND REPRESENTATIONS AND PLEDGE OF
PLEDGED FUNDS. The City represents to and covenants with and for the benefit of the
owners of the Notes:
(a) That it has adopted an operating budget for the Fiscal Year and that it will
levy the City's ad valorem taxes during such Fiscal Year as required by law.
(b) That to the extent necessary to pay when due the principal of and the
interest on the Notes, the Pledged Funds for the Fiscal Year and all moneys held in the Note
Fund hereinafter established are irrevocably pledged to the payment of the Notes superior to all
other liens and encumbrances on such funds, except for bonds and other debt obligations as to
which the City has or may in the future pledge its full faith, credit and taxing power.
(c) That, commencing on December 1, 1991, the Director of Finance of the
City (the "Director of Finance") shall withdraw from the General Fund of the City (the "General
Fund") all Pledged Funds as received and deposit the amount so withdrawn to the credit of a
special fund which is hereby created called The City of Miami Tax Anticipation Notes, Series
1991 Note Fund (the "Note Fund"), until the amount then on deposit to the credit of the Note
Fund on the first day of each indicated month in the Fiscal Year equals the following percentages
of the sum of the principal of and interest on the Notes issued hereunder to be paid at maturity
thereof (such sum being herein called the "Note Fund Requirement"):
Percentage of
Month Note Fund Requirement
December
25 %
January
15 %
February
10 %
March
10 %
April
10%
May
10 %
June
7 %
July
5 %
August
5 %
September
37o
TOTAL
100 %
Amounts in the Note Fund shall be invested in accordance with the City of Miami, Florida, Code
Section 18-2(b) (1986), as amended, and all investment earning on funds in the Note Fund shall
be retained therein and applied as herein provided. If the amount so deposited in any month to
the credit of the Note Fund shall be less than the required amount for such month, the
requirement therefor shall nevertheless be added to the amount otherwise required to be deposited
in each month thereafter until such time as such deficiency shall have been made up. Pledged
Funds deposited to the credit of the Note Fund in excess of the monthly deposit requirement set
forth above shall be credited against future Note Fund deposit requirements. Payments into the
Note Fund shall be adjusted to give credit for investment earnings then on deposit in the Note
Fund and to make up any deficit in the required cumulative balance attributable to investment
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losses. Moneys in the Note Fund shall be trust funds and shall be at all times secured as are
other deposits of public funds.
(d) That the principal of and interest on the Notes when due shall be paid from
the moneys on deposit in the Note Fund.
(e) That the City will not create or suffer to be created any lien or charge upon
the Pledged Funds ranking equally with or prior to the Notes, except for direct obligations of
the City for which the full faith, credit and taxing power of the City have been or shall be
pledged.
(f) That it is the intention of the City and all parties under its control that the
interest on the Notes issued hereunder be and remain excluded from gross income for federal
income tax purposes and to this end the City hereby represents to and covenants with each of the
holders of the Notes issued hereunder that it will comply with the requirements applicable to it
contained in Section 103 and Part IV of Subchapter B of Chapter 1 of the Internal Revenue Code
of 1986, as amended (the "Code") to the extent necessary to preserve the exclusion of interest
on the Notes issued hereunder from gross income for federal income tax purposes. Specifically,
without intending to limit in any way the generality of the foregoing, the City covenants and
agrees:
(1) To make or cause to be made all necessary determinations and calculations
of the Rebate Amount (as hereinafter defined) and required payments of the Rebate Amount;
(2) to set aside sufficient moneys from the Pledged Funds or other legally
available funds of the Issuer, to timely pay the Rebate Amount to the United States of America;
(3) to pay the Rebate Amount to the United States of America from the Pledged
Funds or from any other legally available funds, at the times and to the extent required pursuant
to Section 148(f) of the Code;
(4) to maintain and retain all records pertaining to the Rebate Amount with
respect to the Notes issued hereunder and required payments of the Rebate Amount with respect
to the Notes for at least six years after the final maturity of the Notes or such other period as
shall be necessary to comply with the Code;
(5) to refrain from using proceeds from the Notes issued hereunder in a manner
that might cause the Notes to be classified as private activity bonds under Section 141(a) of the
Code; and
(6) to refrain from taking any action that would cause the Notes issued hereunder
to become arbitrage bonds under Section 148 of the Code.
The City understands that the foregoing covenants impose continuing obligations
of the City that will exist as long as the requirements of Section 103 and Part IV of Subchapter
B of Chapter 1 of the Code are applicable to the Notes.
Notwithstanding, any other provision of this Resolution, including, in particular
Section 20 hereof, the obligation of the Issuer to pay the Rebate Amount to the United States of
America and to comply with the other requirements of this provision shall survive the defeasance
or payment in full of the Notes.
As used herein, the term "Rebate Amount" means the excess of the amount earned
on all non -purpose investments (as defined in Section 148(f)(6) of the Code) over the amount
which would have been earned if such non -purpose investments were invested at the rate equal
to the yield on the Notes, plus any income attributable to such excess.
SECTION 14. COST OF ISSUANCE. An amount of proceeds of the Notes equal to
the cost of issuance shall be deposited with the Paying Agent in a separate fund designated the
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City of Miami Tax Anticipation Notes, Series 1991 Cost of Issuance Fund (the "Cost of Issuance
Fund") and disbursed according to the instructions of the City for the payment of expenses
incurred in issuing the Notes (including payment of the expenses of the City). Any balance
remaining after payment or provision for payment of such costs and expenses has been made
shall be used solely to pay the principal and interest on the Notes.
SECTION 15. AMENDMENTS. Without the consent of any Noteholders, the City
may, from time to time and at any time, adopt such resolutions supplemental hereto that do not
materially adversely affect the interests of the Noteholders (which supplemental resolutions shall
thereafter form a part hereof):
(a) to cure any ambiguity, to correct or supplement any provision herein which
may be inconsistent with any other provision herein or to make any other amendment with
respect to matters or questions arising under this Resolution which may not be inconsistent with
the provisions of this Resolution, or
(b) to modify, amend or supplement this Resolution or any supplement or
amendment hereto in such manner as to permit the Notes to be rated by any nationally
roz:ognized securities rating services.
Any other amendment hereof may be made with the prior written consent of the holders of a
majority in aggregate principal amount of the Notes then outstanding hereunder, provided that
no .amendment shall permit a change: (a) in the maturity of the Notes, (b) in the amount of the
principal obligation of any Notes, (c) that would adversely affect the pledge of the Pledge Funds
hereunder, or (d) that would reduce the percentage of Noteholders required above for the
modification of this Resolution, without the consent of all Noteholders. For the purposes of
Noteholders' consents, the Notes owned by or held for the account of the City, directly, or
indirectly, shall not be counted.
SECTION 16. QUALIFICATION FOR THE DEPOSITORY TRUST COMPANY.
If determined by the Director of Finance or the City Manager or any Assistant City Manager to
be necessary or desirable, the Director of Finance, the City Manager, and the Assistant City
Manager is hereby authorized to take such actions as may be necessary from time to time to
qualify the Notes for deposit with The Depository Trust Company of New York ("DTC"),
including but not limited to, wire transfers of interest and principal payments with respect to the
Notes, utilization of electronic book entry data received from DTC in place of actual delivery
of Notes and provisions of any notices with respect to Notes registered by DTC by overnight
delivery, courier service, telegram, telecopy or other similar means of communication. No such
arrangements with DTC may adversely affect the interests of any of the beneficial holders of the
Notes.
SECTION 17. NEGOTIATED SALE REQUIRED. The Commission hereby finds,
ascertains, determines and declares that a negotiated sale of the Notes to the Underwriters is in
the best interest of the City and is necessary in order to take advantage of currently existing
interest rates, because of uncertainties in the financial markets which have resulted from current
recessive economic conditions in the United States of America and from recent events in foreign
countries, particularly in the Middle East and the Union of Soviet Socialist Republics, and
because of the characteristics of the Notes. Prevailing market conditions have resulted in rapidly
changing and broadly varying interest rates, the negative effects of which on the issuance of the
Notes will be minimized by a negotiated sale. The Underwriter will provide the City with a
disclosure statement containing the information requested by Section 218.385, Florida Statutes
prior to the execution of by the City of the Note Purchase Agreement described below.
SECTION 18. NOTE PURCHASE AGREEMENT APPROVED. The proposal
submitted by the Underwriter at this meeting in the form of the Note Purchase Agreement to be
entered into by and between the City and the Underwriter, a form of which is attached hereto
as Exhibit "B" (the "Note Purchase Agreement"), is hereby approved, subject to such changes,
insertions, and omissions and such filling of blanks then as may be approved and made by the
officers of the City executing the same, in a manner consistent with this Resolution, such
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execution to be conclusive evidence of such approval. The Note Purchase Agreement shall be
accepted and the Notes shall be awarded to the Underwriter at the price and upon the terms and
conditions stated in the Note Purchase Agreement, provided such price, terms and conditions are
in compliance in all respects with the terms of Section 5 of this Resolution. Subject to the
foregoing, the Mayor or Vice Mayor, the City Manager or any assistant City Manager, and the
City Attorney as to the form of the Note Purchase Agreement, are hereby authorized, empowered
and directed, in the name and on behalf of the City, to execute and deliver the Note Purchase
Agreement.
SECTION 19. PRELIMINARY AND FINAL OFFICIAL STATEMENT
APPROVED. The distribution by the Underwriter of a Preliminary Official Statement in
connection with the offering and sale of the Notes in substantially the form attached hereto as
E:.hibit "C" (the "Preliminary Official Statement") is hereby approved; provided that, prior to
such distribution the Mayor, the Vice Mayor, the City Manager or any Assistant City Manager
is hereby authorized, empowered and directed to execute a certificate to "deem final" the
Preliminary Official Statement for the purposes of Rule 15c2-12 of the Securities and Exchange
Commission.
The Commission hereby authorizes the preparation of the Official Statement to be used
in the actual offer and sale of the Notes to the public (the "Official Statement") and the delivery
of such offering Memorandum to the Underwriter no later than two (2) business days (days on
which the City is open for business) from the day on which the Note Purchase Agreement is
executed by the City and hereby approves the Official Statement, which shall be substantially in
the form of the Preliminary Official Statement, with such changes, additions or deletions as shall
be necessary and appropriate to reflect the terms of the sale of the Notes by the City to the
Underwriter and the terms of the resale of the Notes by the Underwriter to the public. The
Commission hereby approves future use by the Underwriter of the Official Statement in
connection with the offering of the Notes to the public and hereby authorizes the preparation and
use by the Underwriter of any supplement or amendment to the Official Statement which is
necessary so that the Official Statement does not include any untrue statement of a material fact
and does not omit to state a material fact necessary to make the statements contained therein, in
light of the circumstances under which they were made, not misleading. The Official Statement
and any supplement or amendment thereto shall be approved by the Mayor, the Vice Mayor, the
City Manager, or any Assistant City Manager such approval to be evidenced by the execution
of a certificate by the Mayor, the Vice Mayor, the City Manager, or any Assistant City Manager
and by the execution of an acknowledgment on such certificate by the City Attorney that the City
Attorney has approved the Official Statement as to form.
The Mayor, the Vice Mayor, the City Manager or any Assistant City Manager is hereby
authorized, empowered and directed to execute the Official Statement and any supplement or
amendment thereto, after the Official Statement or such supplement or amendment thereto has
been approved as provided in this Section 18.
SECTION 20. FURTHER OFFICIAL ACTION. The Mayor, Vice Mayor, City
Manager, Assistant City Manager, Director of Finance, City Attorney, City Clerk and other
officials and officers of the City are hereby authorized, empowered and directed to execute and
deliver such other documents and take such other actions (including, but not limited to, the
procurement of credit enhancement to secure the Notes and obtaining ratings for the Note) as
shall be necessary and appropriate to accomplish the performance of the obligations of the City
in respect thereof. The Mayor, Vice Mayor or City Manager is hereby authorized to agree to
such requirements as may be imposed by the issuer of any credit enhancement or by any rating
agency with respect to the Notes as a condition of such credit enhancement or rating.
SECTION 21. DEFEASANCE. If (1) the City shall pay or cause to be paid to the
Noteholders the principal of and interest to become due thereon at the time and in the manner
stipulated therein and herein, (2) all fees and expenses of the Paying Agent shall have been paid,
and (3) the City shall have kept, performed and observed all of its covenants and promises in the
Notes and in this Resolution, then the Notes shall no longer be deemed to be outstanding under
the provisions of this Resolution. For the purposes of the preceding sentence, Notes for the
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91- 696
payment of which when due sufficient moneys or sufficient noncallable direct obligations of, or
obligations the principal of and the interest on which are unconditionally guaranteed by, the
United States of America shall have been deposited in trust for the owners thereof (whether upon
or prior to the maturity of such Notes) shall be deemed to have been paid and no longer
outstanding under the provisions of this Resolution. Such direct obligations of, or obligations
the principal of and interest on which are unconditionally guaranteed by the United States will
be considered sufficient if said obligations, with interest, mature and bear interest in such
amounts and at such times as will assure sufficient cash to pay interest and principal when due
on the Notes.
SECTION 22. REMEDIES. Any Noteholder or any trustee acting for such Noteholder
in the manner hereinafter provided may by suit, action, mandamus or other proceeding in any
court of competent jurisdiction protect and enforce any and all rights under the laws of the State
or granted and contained in this Resolution and may enforce and compel the performance of all
duties required by this Resolution or by any applicable statutes to be performed by the City or
by any officer thereof. The Noteholders of a majority in aggregate principal amount of Notes
then outstanding may, by a duly executed certificate, appoint a trustee for the Noteholders with
authority to represent such Noteholders in any legal proceedings for the enforcement and
protection of the rights of such Noteholders.
SECTION 23. SEVERABILITY OF INVALID PROVISIONS. If any section,
paragraph, clause or provision of this Resolution shall for any reason be held to be invalid or
unenforceable, the invalidity or unenforceability of such section, paragraph, clause or provision
shall not affect any remaining provisions of this Resolution, but this Resolution shall be
construed and enforced as if such illegal or invalid provision or provisions had not been
contained herein.
SECTION 24. GOVERNING LAW. The provisions of this Resolution shall be
construed and enforced in accordance with the laws of the State of Florida.
SECTION 25. REPEALING CLAUSE. All resolutions or parts thereof in conflict with
the provisions of this Resolution are, to the extent of such conflict, hereby superseded and
repealed.
SECTION 26. TIME OF TAKING EFFECT. This Resolution shall become effective
immediately upon its adoption.
PASSED AND ADOPTED this 26rhday of September,A1991.
(SEAL
ATTF,
MATTY HIRAI, City Clerk
APPROVED AS TO FORM AND
CORRECTNESS:
Ra
XAVIER L. SUA)tEZ, Mayor
91-- 696
0
0
Interest Rate:
Principal Amount:
Registered Owner:
EXHIBIT A
[Form of Note]
UNITED STATES OF AMERICA
STATE OF FLORIDA
THE CITY OF MIAMI, FLORIDA
TAX ANTICIPATION NOTE,
SERIES 1991
Maturity Date:
September _, 1992
Issue Date:
October 1991
C SIP:
The City of Miami, Florida (the "City"), is justly indebted and for value received
hereby promises to pay to the Registered Owner set forth above or registered assigns or legal
representatives, on the Maturity Date specified above, but solely from the sources hereinafter
identified upon the presentation and surrender hereof, at the principal corporate trust office of
NCNB National Bank of Florida, Tampa, Florida (the "Paying Agent"), the Principal Amount
specified above together with interest thereon from the Issue Date specified above, at the Interest
Rate per annum specified above (calculated on the basis of a 360-day year consisting of twelve
thirty -day months) until payment of such Principal Amount. Both the principal of and interest
on this note are payable in any coin or currency of the United States of America which, at the
date of payment thereof, is legal tender for the payment of public and private debts.
This note is one of a duly authorized issue of notes of the City known as "Tax
Anticipation Notes, Series 1991", (the "Notes") issued under the authority of and in full
compliance with the Constitution and the laws of the State of Florida, the Charter of the City and
Resolution No. adopted by the City Commission of the City on September _, 1991
(the "Resolution"), for the purpose of paying the appropriations made for the fiscal year of the
City ending September 30, 1992 (the "Fiscal Year") in anticipation of the receipt of ad valorem
taxes of the City and estimated in the budget of the City to be realized in cash during such Fiscal
Year and to pay the costs of the sale and issuance of the Notes. By the acceptance of this Note,
the owner hereof assents to all the provisions of the Resolution.
Neither the full faith and credit nor the taxing power of the City, County or the
State of Florida or any political subdivision thereof or governmental authority or body therein
are pledged to the payment of the Notes, but the Notes shall be payable in accordance with the
provisions of the Resolution solely from the City's ad valorem taxes collected during the Fiscal
Year, except ad valorem taxes approved by referendum and levied specifically to pay debt
services on bonds or other obligations issued by the City (the "Pledge Funds") moneys deposited
to the credit of the special fund known as the "Note Fund" created by the Resolution. The
Registered Owner of this note shall not have the right to compel the exercise of the ad valorem
taxing power of the City, County or the State of Florida or any political subdivision thereof or
governmental authority or body therein or taxation in any form of any real or personal property
therein to pay such note except for the Pledged Funds. The pledge of the Pledged Funds to the
payment of the Notes is superior to all other liens and encumbrances on such funds, except for
bonds and other debt obligations as to which the City has or may in the future pledge its full
faith, credit and taxing power.
The Notes are issuable as registered notes without coupons in denominations of
$5,000 each or any integral multiple thereof. At the principal corporate trust office of the
Paying Agent, in the manner and subject to the limitations and conditions provided in the
91-" 696
0
Resolution and without cost except for any tax or other governmental charge, Notes may be
exchanged for an equal aggregate principal amount of registered Notes of other authorized
denominations.
The transfer of this Note is registrable by the Registered Owner hereof in person
or by his attorney or legal representative at the principal corporate trust office of the Paying
Agent, but only in the manner and subject to the limitations and conditions provided in the
Resolution and upon surrender and cancellation of this note. Upon any such registration of
transfer the City shall execute and the Paying Agent shall authenticate and deliver in exchange
for this note a new note or notes registered in the name of the transferee or transferees, of any
authorized denominations and in principal amount equal to the principal amount of this Note.
The Notes are not subject to redemption prior to maturity.
This Note shall not be valid or become obligatory for any purpose or be entitled
to any benefit under the Resolution until this Note shall have been authenticated by the execution
by the Paying Agent of the certificate of authentication endorsed hereon.
This Note shall be governed and construed in accordance with the laws of the State
of Florida.
It is hereby certified and recited that all acts, conditions and things required to
happen, exist and be performed precedent to and in the issuance of this Note have happened,
exist and have been performed in due time, form and manner as required by the Constitution and
laws of the State of Florida.
This Note is and has all the qualities and incidents of an investment security under
the Uniform Commercial Code - Investment Securities law of the State of Florida.
IN WITNESS WHEREOF, The City of Miami, Florida has caused this note to
be signed by the Mayor, either manually or with his facsimile signature, and the seal of The City
of Miami, Florida or a facsimile thereof to be affixed hereto or imprinted or reproduced hereon,
and attested by the City Clerk, either manually or with her facsimile signature.
(SEAL)
ATTEST:
City Clerk
THE CITY OF MIAMI, FLORIDA
By:
Mayor
APPROVED AS TO FORM AND
CORRECTNESS
By:
City Attorney
91- 61!16
CERTIFICATE OF AUTHENTICATION
This is one of the Notes of the issue designated there in and issued under the
provisions of the Resolution mentioned therein.
Date of Authentication:
as Paying Agent
By:
Authorized Officer
91 - 696
[Form of Abbreviations for Note]
The following abbreviations, when used in the inscription the within note shall be
constnied as though they were written out in full according to applicable laws or regulations.
TEN COM - as tenants in common
TEN ENT - as tenants by the entireties
JT TEN - as joint tenants with the right of
survivorship and not as tenants
in common
UNIFORM GIFT MIN ACT - Custodian
(Cust)
Gifts to Minors Act
(State)
(Minor)
Additional abbreviations may also be
used though not in the above list
[Form of Assignment for Note]
under Uniform
For value received, the undersigned hereby sells, assigns and transfers unto
the within Note, and
all rights thereunder, and hereby irrevocably constitutes and appoints,
attorney to transfer the said Note on the
registration books, with full power of substitution in the premises.
Dated
Please insert Social Security
or other identifying number
of transferee:
Signature guaranteed:
NOTICE: The transferor's signature to this Assignment must correspond with the name as
it appears on the face of the within note in every particular without alteration or
any change whatever.
91- 696
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5/19/91 PRELYMINARY DRAFT, SUBJECT TO REVISIONS
NOTE PURCHASE AGREEMENT
[DATE]
Honorable Mayor and Members
of the City Commission of
The City of Miami, Florida
3500 Pan American Drive
Miami, Florida 33133
Re: The City of Miami, Florida
Tax Anticipation Notes, Series 1991
Ladies and Gentlemen:
+o 6
The undersigned, PaineWebber Incorporated (the
"Representative") , acting for and on behalf of itself and on behalf
of the other underwriters named in Exhibit A hereto, as such list
may from time to time be changed by us at or prior to the
hereinafter defined Closing (the undersigned and such other
underwriters are collectively referred to herein as the
Of Underwriters"), offers to enter into this Note Purchase Agreement
(this "Purchase Agreement") with The City of Miami, Florida (the
"City"), which, upon the acceptance of this offer and the execution
of this Purchase Agreement by the City, shall be in full force and
effect in accordance with its terms, and shall be binding upon the
City and the Underwriters. The Underwriters have designated the
Representative to act as their representative and the
Representative hereby represents that it has been duly authorized
to execute this Purchase Agreement for and on behalf of the
Underwriters. The Representative shall not be obligated to advise
you of any changes made to the list of underwriters in Exhibit A.
Terms not otherwise defined herein shall have the same meanings as
set forth in the Resolution described below.
This offer is made subject to your acceptance of this Purchase
Agreement on or before Eastern Time, on the . day of
1991, and, if not so accepted, this offer will be
subject to Withdrawal by the Underwriters upon oral 'or written
notice delivered by the Representative to the City at any time
prior to the acceptance hereof by the city.
I. Purche§e o! N.-,cam. Upon the terms and conditions and in
reliance upon the respective representations►, warranties and
covenants herein, the Underwriters, jointly and severally, hereby
9112101.19478.ode -�,-
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agree to purchass from the City for offerinunderwriters ail (but publicsto the d
the
not loss
City hereby agrees to sell to the
than a11) of the Tax Anticipation Notes, S payableies 9to( the 11Citygin
at a purchase price of $
immediately available funds (equal to the face value of the Notes
less Underwriter's discount and original issue discount; plus
accrued interest).
The Notes shall be as described in, and shall be issued
pursuant to the constitution and laws of the state of Florida,
particularly Chapter 166► Florida Issuer S a uamendod Resolutioas n Nond
pursuant to the Charter of t
of The City of Miami duly adopted on September _,, 1991 (the
"Resolution") and other applicable provisions of law (collant'velyl
the "Act"). The Notes shall mature on ,
shal
bear interest at % per annum and shall not be subject to
redemption prior to their maturity date. In connection with the
public offering of the Notes, the Underwriters have delivered to
the City a letter containing the information required by Chapter
218.385 of the Florida Statutes; which letter is in the form
attached hereto as Exhibit B. It shall be a condition of the
obligation of the City to Bell and eliver the Underwritersotosto the
purchase
Underwriters, and the obligation of thethat the entire aggregate
and accept delivery of the Notes,
principal amount of the
una Underwriters at the Closing.
shall be sold and ivered by the
City and paid for by the
Public of grins
2. the Notes. The Underwriters agree to
at the
make a bona fide public h on the offering
cover page of the Finalall of the NotesOf icial
offering prices set fort
Statement described below.
Delivery of Official Statement. The City shall deliver
3• after the
or cause to be delivered to the Underwriters, promptly
City's acceptance hereof:
(a) two copies of the City's Official Statement, dated
the date hereof, substantially in the form of the Preliminary
official Statementdated , 1991 (the "Preliminary
official Statement"), with only such changes therein as shall have
been accepted by the Underwriters (such official statement with
such changes, if any, and including the cover page and all exhibits
included therein or attached thereto being herein called the
"official Statement"), signed on behalf of the City by the Mayor;
and
/ (b) two certified copies of the Resolution of the City
authorizing the issuance and sale of the Notes.
By acceptance of this Purchase Agreement, the, City hereby
approves the Official Statement
distribution,
to the1n accordance
distribution
with applicable law, and ratifies their consent
9112101.19470.eds -2 -
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ind use of the Preliminary official statement by the underwriters,
in accordance with applicable law, in connection with the public
offering and sale of the Notes.
As soon as practicable after the date hereof, but in any
event within seven (7) business days, the City shall deliver to the
Representative a reasonable number of copies of the Official
Statement of the City, dated , 1991, relating to the
Notes. The City hereby represents and warrants that such Official
Statement is deemed final and complete as of its date for purposes
of compliance with paragraph (H)(1) of Rule 1502-12 under the
Securities Exchange Act of 19341 as amended.
4. Good with Denoa=. The Representative herewith delivers
to the City a corporate check payable to the City in the amount of
$ , representing „_% of the Purchase Price of the Notes,
as security for the performance by the Underwriters of their
obligations to accept and pay for the Notes at the Closing
(described below) in accordance with the provisions of this
Purchase Agreement. Said check shall be held by the City uneashed
until the Closing and at the Closing shall be returned to the
Representative upon receipt by or on behalf of the City of the
Purchase Price for the Notes. In the event the City does not
accept this offer, or upon its failure to deliver the Notes at the
closing, or if it shall be unable to satisfy the conditions to the
obligations of the Underwriters contained in this Purchase
Agreement, or if such obligations shall be terminated for any
reason permitted by this purchase Agreement, such check shall be
immediately returned to the Representative. In the event that the
Underwriters fail (other than for a reason permitted under this
Purchase Agreement) to accept and pay for the Notes at the Closing,
such check shall be retained and may be cashed by the City as and
for full liquidated damages for such failure and for any and all
defaults hereunder on the part of the Underwriters, and the cashing
of such check and retention of such. proceeds shall constitute a
full release and discharge of all claims and rights hereunder
against the Underwriters.
5. Re=es8AtAJ;12ns and WA 'rantias of theCity. The City
represents and warrants to the Underwriters that:
(a) The City is duly organized and existing as a
municipal corporation under the constitution and
laws of the State of Florida (the "State"). The
City is authorized by the provisions of the Act and
Resolution, among other things, (i) to issue tax
anticipation notes,such as the Notes, for the
purpose of providing funds to pay the
appropriations made by the City for the fiscal year
ended September 30, 1992, and (ii) to secure the
Notes in the manner contemplated by the Resolution.
9112101.19478.ede
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20
91-r 696
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(b) The City has the full legal right, power and
authority (i) to adopt Resolution No.
adopted by the Commissioner authorizing the
issuance of and awarding the sale of the Notes (the
"Resolution"), (ii) to enter into this Purchase
Agreement, and (iii) to issue, sell and deliver the
Notes to the Underwriters as provided herein, and
(iv) to carry out and consummate all other
transactions contemplated by each of the aforesaid
documents, and the City has complied with all
provisions of applicable law, including the Act, in
all matters relating to such transactions.
(c) The City hag duly authorized (i) the execution and
delivery of the Notes and the execution, delivery
and due performance of this Purchase Agreament and
the Financing Documents, (ii) the distribution and
use of the Preliminary Official Statement and
execution, deliverY and distribution of the Final
official Statement and (iii) the taking of any and
all such action as may be required on the part of
the City to carry out, give effect to and
consummate the transactions contemplated by such
instruments. All consents or approvals necessary
to be obtained by the city in connection with the
foregoing have been received, and the consents or
approvals so received are still in full force and
effect.
(d) The Resolution has been duly adopted by the City,
is in full force and effect and constitutes the
legal, valid and binding act of the City; and this
Purchase Agreement, when executed and delivered,
will constitute legal, valid and binding
obligations of the City. The Resolution and this
Purchase Agreement are enforceable against the City
in accordance with their respective terms except as
enforceability thereof may be limited by
bankruptcy, insolvency or other laws affecting
creditors$ rights generally.
(a) when delivered to the Underwriters, the Notes will
.have been duly authorized, executed, authenticated
issued and delivered and will constitute legal,
valid and binding obligations of the City in
conformity with the laws of the State of Florida,
including the Act, and will be entitled to the
benefit and security of the Indenture.
(f) Both at the time of acceptance hereof by the City
and at the date of Closing, the statements and
information contained in the official Statement are
9112101.19478.sda —4 — o1
91- 696
-------------
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and will be true, correct and complete in all
material respects and the Official Statement does
not and will not contain any untrue or misleading
statement of a material fact or omit to state a
material fact required to be stated therein or
necessary to make the statements and information
therein, in light of the circumstances under which
they were made, not misleading;
(g) At the time of the CitysI acceptance hereof and
(unless an event occurs of the nature described in
Section 8(h) hereof requiring the preparation of an
amendment or supplement to the Official Statement)
at all times subsequent thereto during the period
up to and including twenty-five (25) [or ninety
(90)] days subsequent to the "end of the
underwriting period", as defined in Rule l5c2-12
promulgated under the Securities Exchange Act of
1934, as amended ("Rule 15e2-1211), the official
Statement does not and will not contain any untrue
statement of a material fact or omit 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 were made,
not misleading;
(h) If the Official Statement is supplemented or
amended pursuant to Section 8(d), at the time of
each supplement or amendment thereto and (unless
subsequently again supplemented or amended) at all
times subsequent thereto during the period up to
and including twenty-five (25) [or ninety (90)]
days subsequent to the "end of the underwriting
period" (as defined in Mule 15e2-12) the Official
Statement as so ,supplemented or amended will not
contain any untrue statement of a material fact or
omit 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 were made, not misleading;
(i) As of the date thereof, the Preliminary Official
Statement delivered to the Underwriters was deemed
final by the City for purposes of Rule 15c2-12,
except for the omission of such information as was
permitted to be excluded by Rule 15c2-12; and
(j) Unless otherwise notified in writing by the
Underwriters, the City can assume that the "end of
the underwriting period" for purposes of Rule 15c2-
12 and this Agreement shall be the date of Closing;
and
9122101.19476.ads �5-
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91-- 696
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(k) Neither the adoption of the Resolution the
execution and delivery of this Purchase Agreement
or the Notes nor the consummation of the
transactions contemplated herein or therein or the
compliance with the provisions hereof or thereof
will conflict with, or constitute on the part of
the City a violation of, or a breach of or default
under, (i) any statute, indenture, mortgage,
commitment, note or other agreement or instrument
to which the City is a party or by which it is
bound, (ii) any provision of the State constitution
or (iii) any existing law, rule regulation,
ordinance, judgment, order or decree to which the
City or any of its officers in their respective
capacities as such, is subject.
(1) The City has never been in default at any time as
to principal of or interest on any obligation which
it has issued, including those which it has issued
as a conduit for another entity, except as
specifically disclosed in the Official Statement.
(m) Except as is specifically disclosed in the official
Statement, there is no action, suit, proceeding,
inquiry or investigation, at law or. in equity,
before or by any court, public board or body,
pending or, to the best knowledge of the city
threatened, which in any way guest ions the powers
of the City referred to in paragraph (b) above, or
the validity of any proceeding taken by the City in
connection with the issuance of the Notes, or
wherein an unfavorable decision, ruling or finding
could materially adversely affect the transactions
contemplated by this Purchase Agreement, or of any
other document or instrument required or
contemplated by this financing, or which, in any
way, could adversely affect the validity or
enforceability of the Resolution the Notes, or this
Purchase Agreement.
(n) Any certificate signed by any official of the City
and delivered to the underwriters shall be deemed a
representation and warranty by the City to the
Underwriters as to the truth of the statements
therein contained.
(o) The City has not been notified of any listing or
proposed listing by the Internal Revenue Service to
the effect that it is a bond issuer whose arbitrage
certifications may not be relied upon.
9112101.19470.sds - 6—
91 696
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(p) The City will not knowingly take or remit to take
any action, which action or omission will in any
way cause the proceeds from the sale of the Notes
to be applied in a manner other than as provided in
the Resolution or which would cause the interest on
the Notes to be included in gross income for
federal income tax purposes.
6. covenants of the . ity. The City covenants with the
Underwriters as follows:
(a) The City will cooperate with the Underwriters in
qualifying the Notes for offer and sale under the
securities or Blue Sky laws of such jurisdictions
of the United States as the Underwriters may
request; provided, however, that the city shall not
be required to consent to suit or to service of
process in any jurisdiction. The City consents to
the use by the Underwriters in the course of their
compliance with the securities or Blue Sky laws of
the various jurisdictions of the documents relating
to the Notes, subject to the right of the City to
withdraw such consent for cause by written notice
to the Underwriters.
(b) during the offering period or for a period not
exceeding twenty --five (25) [or ninety (90)] days
subsequent to the "end of the underwriting period"
(as defined in Rule 1502-12), the City will not
adopt any amendment of or supplement to the
Official Statement which, after having been
furnished with a copy, the Underwriters shall
reasonably object in writing.
(c) The city will cause to be made available to the
Underwriters such reasonable quantities of the
Official Statement (and related documents) as the
Underwriters may request, from time to time, for
use in connection with the offering and sale of the
Notes and to cause reasonable quantities of the
official Statement not be delivered to the
Underwriters, without charge, within seven (7)
.business days of the date hereof and, in the event
the date of Closing is legs than seven (7) business
days after the date hereof, upon request of the
Underwriters, in sufficient time to accompany any
confirmation requesting payment from any customers
of Underwriters;
(d) The City will apply the proceeds from the sale of
the Notes as provided in the Official Statement and
agree not to take or omit to take any action within
9112101,19478.ads -7- ay
91-- 696
n i I V.40a AVIIQI VVI 001 1 v IV-0I I IV1OV 1 6 9 n & 0 1 V411 i%Ib at VIQy" 1M a
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10
their control which action or omission would
adversely affect the exclusion from gross income
for federal income tax purposes of the interest on
the Notes;
(e) If, after the date of this Agreement and until
twenty-five (25) Car ninety (90)] days after the
'lend of the underwriting period" (as defined in
Rule 15c2-12) any event shall occur as*a result of
which it is necessary to amend or supplement the
official Statement in order to make the statements
therein, in light of the circumstances existing at
the time the official Statement is delivered to a
Note purchaser, not misleading, or if it is
necessary to amend or supplement the official
Statement to comply with applicable law, the City
agrees to promptly notify the Underwriters (and for
the purposes of this clause (iii) to provide the
Underwriters with such information as they may form
time to time request), and to forthwith prepare and
furnish, at the City's own expense (in a form and
manner approved by the Underwriters), a reasonable
number of copies of either amendments or
supplements to the Official Statement so that the
statements in the official Statement as so amended
and supplemented will not, in light of the
circumstances existing at the time of the official
Statement is delivered to a purchaser, be
misleading, or so that the official Statement will
comply with applicable law;
7. C osina. At, o'clock A.M., New York City time, on
or at such other time or on such earlier or
later date as the City and the Underwriters may mutually agree upon
(the "Closing"), the City will deliver or cause to be delivered to
the Underwriters, at the New York office of the Depository Trust
Company ("DTC"), or at such other place as the parties may mutually
agree upon, the Notes in definitive form, duly executed on behalf
of the City, authenticated by the Series Trustee and registered in
_ the name of Cede & Co., as nominee of DTC, in denominations equal
to the amount of each maturity thereof, and at the office of
, or at such other place as
may be mutually agreed upon, the other documents hereinafter and
hereinbefore mentioned. It is anticipated that CUSIP
identification number will be printed on the Notes, but neither the
failure to print such number on any Note nor any error with respect
thereto shall constitute cause for a failure or refusal by the
Underwrites to accept delivery of an pay for the Notes in
accordance with the terms of this Agreement. All expanses in
relation to the printing of CUSIP number on said Notes and the
CUSIP Service Bureau charge for the assignment of said numbers
shall be paid for by the City. the Underwriters will accept
9112101.19478.@d• _e
91-- 696
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delivery of the Notes and pay the purchase price thereof at the
Closing by certified or official bank check to the order of the
City, payable in New York Clearing House funds at such bank located
in the City of New York as the City shall herein designate. The
Notes will be made available for checking and packing on the day
prior to the Closing at the office of DTC, or at such other place
as may be agreed upon by the City and the Underwriters.
9. rirmingtign. The Underwriters shall have the right to
cancel their obligations to purchase the Notes if between the date
hereof and the date of Closings
(a) a tentative decision with respect to legislation
shall be reached by a committee of the House of
Representatives or the Senate of the Congress of
the United States, or legislation shall be
favorably reported or rereported by such a
committee or be introduced, by amendment or
otherwise, in or be passed by the House of
Representatives or the Senate, or recommended to
the Congress of the United States for passage by
the President of the United States, or be enacted
or a decision by a federal court of the United
States or the United States Tax Court shall have
been rendered, or a ruling, release, order,
regulation or official statement by or on behalf of
the United States Treasury Department, the Internal
Revenue Service or other governmental agency shall
have been made or proposed to be made having the
purpose or effect, or any other action or event
shall have occurred which has the purpose or
effect, directly or indirectly, of adversely
affecting the federal income tax consequences of
owning the Notes or of any of the transactions
contemplated in connection herewith, including
causing interest on the Notes to be included in
gross income for purposes of federal income
taxation, or imposing federal income taxation upon
revenues or other income of the general character
to be derived by the City or by any similar body
upon interest received on obligations of, the
general character of the Notes, or the Notes which,
in the opinion of the Representative, materially
adversely affects the market price of or market for
the Notes; or
(b) legislation shall have been enacted, or actively
considered for enactment with an effective date
prior to the Closing, or a decision by a court of
the United States shall have been rendered, the
effect of which is that the Notes, including any
underlying obligations, or the Resolution, as the
9112101.19478.ada -9 - 26
91.w- 696
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04►►
case may be, is not exempt from the registration,
qualification or other requirements of the
securities Act of 1933, as amended and as then in
effect, the Securities. Exchange Act of 1934, as
amended and as then in effect, or the Trust
indenture Act of 1939, as amended and as then in
effect; or
(c) a stop order, ruling, regulation or official
statement by the Securities and Exchange Commission
or any other governmental agency having
jurisdiction of the subject matter shall have been
issued or made or any other event occurs, the
effect of which is that the issuance, offering or
gale of the Notes, including any underlying
obligations,is or would be in violation of any
provision of the federal securities laws, including
the Securities Act of 1933, as amended and as then
in effect, the Securities Exchange Act of 1934, as
amended and as then in effect, or the Trust
Indenture Act of 1939, as amended and as then in
effect; or
(d) any event shall have occurred or any information
shall have becomes known to the Underwriters which
causes the Representative to reasonably believe
that the Official Statement as then amended or
supplemented includes an untrue statement of a
material fact, or omits to state any material fact
necessary to make the statements therein, in light
of the circumstances under which they were made,
not zeisleading; or
(a) there shall have occurred any outbreak of
hostilities or any national or international
calamity or crisis, including a financial crisis,
the effect of which on the financial markets of the
United states is such as, in the reasonable
judgment of the Underwriters, would materially
adversely affect the market for or market price of
the Noted; or
(f)- there shall be in force a general suspension of
trading on the New York Stock Exchange, the affect
of which on the financial markets of the United
States is such as, in the reasonable judgment of
the Underwriters, would materially adversaly affect
the market for or market price of the Notes; or
(g) a general banking moratorium shall have been
declared by federal, New York or State authorities;
or
9112101.19478.9de
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91- 696
Ociri ur;H Nrotessions, uorp, ; to;4u
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+aft
(h) any proceeding shall be pending or threatened by
the Securities and Exchange Commission against the
City; or
(i) additional material restrictions not in force as of
the date hereof shall have been imposed upon
trading in securities generally by any governmental
authority or by any national securities exchange;
or
(j) the New York Stock Exchange or other national
securities exchange, or any governmental authority,
shall impose, as to the Notes or obligations of the
general character of the Notes, any material
restrictions not now in force, or increase
materially those now in force, with respect to the
extension of credit by, or the charge to the net
capital requirements or, underwriters.
9. Conditions to cigaing. The obligations of the
Underwriters to purchase the Notes shall be subject (a) to the
performance by the City of their obligations to be performed
hereunder at and prior to the Closing, (b) to the accuracy of the
representations and warranties of the City as of the date hereof
and as of the time of the Closing, and (c) to the following
conditions, including the delivery by the City of such documents as
are enumerated herein in form and substance satisfactory to Lewis,
White & Clay, A Professional Corporation, counsel to the
Underwriters:
(a) At the time of Closing, (i) the Official Statement
and this Purchase Agreement shall be in full force
and effect and shall not have been amended,
modified or supplemented from the date hereof
except as may have been agreed to in writing by the
Underwriters, (ii) the proceeds of the sale of the
Notes shall be deposited and applied as described
in the Resolution, and (iii) the City shall have
duly adopted and there shall be in full force and
effect such resolutions as, in the opinion of [BOND
COUNSEL] , as bond counsel ( "Bond Counsel") , shall
be necessary in connection with the transactions
contemplated hereby.
(b) Receipt of the Notes at or prior to the Closing.
The terms of the Notes, as delivered, shall in all
instances be as described in the Final official
Statement.
(c) At or prior to the Closing, the Underwriters shall
receive the following documents in such number of
9112101.19478.sds
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0
91- (;96
I V'41 1 b-V,awl It l la Vl; 4 V14,
i" IV
9112101.19478.eds
counterparts as shall be mutually agreeable to the
Underwriters:
(1) A final approving opinion of Bond Counsel
dated the date of Closing, in customary form,
substantially in the form attached to the
official Statement as Appendix D.
(2) A Letter of Bond Counsel addressed to the
underwriters and dated the date of Closing, to
the effect that Bond Counsel's final approving
opinion may be relied upon by the Underwriters
to the same extent as if such opinion were
addressed to the Underwriters.
(3) A supplemental opinion of Bond Counsel
addressed to the Underwriters and dated the
date of Closing, in substantially the form set
forth in Exhibit C hereto.
(4) An opinion of Counsel for the City dated the
date of Closing, addressed to the
Underwriters, in substantially the form set
forth in Exhibit D hereto.
(5) Memoranda from Counsel to the Underwriters
addressed to the Underwriters indicating the
Jurisdictions in which the Notes have been
qualified or exempted under the securities or
"Blue Sky" laws and a legal investment survey.
(6) An opinion of Counsel to the Underwriters in
substantially the form set forth in Exhibit E
hereto.
(7) The Final official
behalf of the City
officer of each.
Statement executed on
by a duly authorized
(s) Certified copies of all resolutions of the
City relating to the Notes,.
(9) Specimen Notes.
(10) A letter from [RATING AGENCIES] to the effect
that the Notes have been assigned a rating of
no less than 11 " which rating shall
be in effect as of the date of Closing.
(11) A Non -Arbitrage and Tax Compliance certificate
signed by the City's Finance Director (the
"Director") setting forth, among other things,
-12-
�'7
91- 696
OCIVI ai.M rroressional Corp, 1u;41
i 4ew18, Whit$ & C I ay.4
W4
facts, estimates and circumstances (including
covenants of and by the City) in existence on
the date of Closing, which facts, estimates
and circumstances shall be set forth therein,
sufficient to support the conclusion that (i)
it is not expected that the proceeds of the
Notes will be used in a manner that would
cause the Notes to be "arbitrage bonds" within
the meaning of Section 148 of the Internal
Revenue Code of 1986, as amended, and the
regulations, temporary regulations and
proposed regulations promulgated with respect
thereto and stating that (ii) to the best of
the knowledge and belief of such officer there
are no other facts, estimates or circumstances
that would materially affect such
expectations;
(12) A certificate, in form and substance
satisfactory to the Underwriters and their
counsel, of the City or any duly authorized
officer or official of the City satisfactory
to the Underwriters and their counsel, dated
an -of the Closing Date, to the effect that:
(i) each of the City's representations,
warranties and covenants contained herein are
true and correct as of the Closing; (i i) the
City has authorized, by all action necessary
under the Act and the laws and Constitution of
the State, the adoption of the Resolution and
the execution, delivery and due performance of
the Notes; (iii) no litigation is pending, or
to the knowledge of the officer or official of
the City signing the certificate after due
investigation and inquiry threatened, to
restrain or enjoin the issuance or sale of the
Notes or in any way affecting any authority
for or the validity of the Resolution, the
Noted or this Purchase Agreement; and (iv) the
Notes as executed by the City, are in the form
or in substantially the form approved for such
execution by appropriate proceedings of the
City.
(13 ) A certificate of the City 18 Finance Director
to the effect that to the best of his
knowledge the Official Statement does not
contain any untrue statement of a material
fact and does not omit to state any material
fact required to be stated therein, or
necessary to make the statements therein in
the light of the circumstances under which
9112101.19478. *ds -13 - 30
91 - 696
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they were made, not misleading. Such
certificate of the Cityrs Finance director
shall also certify that to the beet of their
knowledge from the date of the Official
statement to the date of Closing there has
been no material adverse change in the
information set forth therein;
(14) A letter signed by the Finance Director of the
City stating that the financial information
included in the Official statement presents
fairly the financial position and results of
operations of the city as at and for the
periods therein set forth and the general
purpose financial statements of the City
appended to the official Statement, were
prepared in conformity with generally accepted
accounting principles and that for the period
September 30, 1990 to a subsequent date not
more than five (5) business days prior to the
closing, there have been no material adverse
changes in the financial position of the City;
(15) Evidence that Federal Form 8038 has been
executed by the City and filed with the
Internal Revenue Service.
(16) such additional legal opinions, certificates,
proceedings, instruments and other documents
as Counsel to the Underwriters, Bond counsel
or Counsel to the City may reasonably request
to evidence compliance by the City with legal
requirements, the truth and accuracy, as of
the time of Closing, of the respective
representations of the City herein contained
and the due performance or satisfaction by
each of them at or prior to such time of all
agreements then to be performed and all
conditions then to be satisfied by each of
them.
If the city shall be unable to satisfy the conditions to
the obligations of the Underwriters contained in this Purchase
Agreement, or if the obligations of the Underwriters to purchase
and accept delivery of the Notes shall be terminated for any reason
permitted by this Purchase Agreement, the good -faith check
referenced in section 4 shall be returned to the Representative and
this Purchase Agreement shall terminate and neither the
Underwriters nor the City shall be under any further obligations
hereunder; except that their respective obligations to pay
expenses, as provided in Section 13 hereof, shall continue in full
force and affect.
9112101.19478.sde
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31
9f-- 696
OMIri 01 rroressionai Corp, a-in-ai i �u�4o i Lewls,wnite & clay-
i4lo
lp. city Uligatigng. The obligations of the City hereunder
are subject to the performance by the Underwriters of its
obligations hereunder.
li. BsryV&I - of Rsngresentatt gnp. All representations,
warranties and agreements of the City shall remain operative and in
full force and effect, regardless of any investigations made by or
on behalf of the Underwriters and shall survive the Closing.
12. go ice. Any notice or other communication to be given to
the City under this Purchase Agreement may be given by delivering
the same in writing at their addresses set forth above, and any
notice or other communication to be given to the Underwriters under
this Purchase Agreement may be given by delivering the same in
writing to the Underwriters
Attention:
13. Exee s s. Expenses concerning the offer and sale of the
Notes and performance of this Purchase Agreement shall be paid as
follows!
(a) The Underwriters shall be under no obligation to
pay, and the City shall pay, all expenses incident
to the performance of the City's obligations under
this Agreement, including, without limitation, (i)
the cost of preparation, printing and distribution
of the official statement (including any
Preliminary Official Statements, or amendments or
supplements thereto), (ii) the cost of the
preparation, printing and execution of the Notes,
(iii) the fees and disbursements or Bond Counsel
and Counsel to the City, (iv) the fees and
disbursements of the Paying Agent, the City's
Financial Advisors, the City's independent public
accountants, and of any other experts, advisors or
consultants retained to assist the City, (v) fees
for bond ratings, (vi) the cost of reproducing all
necessary copies'of any of the Bond Documents, and
(vii) all travel and other out-of-pocket expenses
of the City's staff and officials as incurred in
connection with the Closing; all such expenses to
be paid by the City as issuance costs, as permitted
under the Resolution.
(b) The Underwriters shall pay (i) all underwriting and
advertising expenses in connection with the public
offering and distribution of the Notes, (ii) the
fees and disbursements of Counsel to the
Underwriters, (iii) the cost of preparation and
printing of the blue sky memorandum, (iv) the cost
of the preparation and printing of any agreement
among underwriters or selling group agreements and
9112101.19478.8do -is- 3C?--
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OY'A Protesslon al Corp, ;
8-19�81 10s43 i
Lewis white & C18y-+
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this Note Purchase Agreement, and (v) all travel
and out-of-pocket expenses of the Underwriters.
14. Den. This Purchase Agreement is made solely for the
benefit of the City, and the Underwriters (including the successors
or assigns of the Underwriters) and no other person, including any
purchaser of the Notes, shall acquire or have any right hereunder
or by virtue hereof.
15. Centro ling Last. This Purchase Agreement shall be
governed by and construed in accordance with the laws of the State
of Florida
16. Effectivene s. This Purchase Agreement shall become
effective upon your mutual acceptance hereof.
Accepted and agreed to as of
the date first above written:
The City of Miami, Florida
By
9112101.19478.ade
Very truly yours,
PaineWebber Incorporated,
Representative, acting for
itself and on behalf of the other
Underwriters
By:
Richard Wells, Vice President
—16-
91-- 696
SENT BY:A.Protessione► Corp, 18-18-91 1044
05
i LeW18oWhite & Clay-4
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We
4111101.19476.ods
]CXHIBIT A
LIST OF UNDERWRITERS
311
---------------
r.,i�r w�•n v��r�.vn/+i vv�Y, v Iv vi t AV t Llifli0ItriliYFJ O VIG
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EXHIBIT B
Form of Letter Pursuant to Section 210.305, Florida Statutes
(Letterhead of PaineWebber Incorporated)
October _1 1991
Honorable Mayor and Members
of the City Commission of the
City of Miami, Florida
3500 Pan American Drive
Miami, Florida 33133
Re: $25,000,000 The City of Miami, Florida
Tax hnticiRatio Nmt&IU Series 19923
Dear Commissioners:
In connection with the proposed issuance by The City of Miami,
Florida (the "City"), of $25,000,000 in aggregate principal amount
of the Tax Anticipation Notes, Series 1991, referred to above (the
"Notes"), PaineWebber Incorporated, Grigsby Branddford Powell,
Inc., AIBC Investment Services Corp. and Guzman & Company (the
"Underwriters") are preparing to underwrite a public offering of
the Notes. Arrangements for underwriting the Notes will include,
among other things, a Note purchase Agreement between the City and
the Underwriters that will embody the negotiations in respect
thereof.
The purpose of this letter
provisions of Section 215.385(4)
certain information in respect of
the underwriting of the Notes as
is to furnish, pursuant to the
Florida Statutes, as amended,
the arrangements contemplated for
followsI
(a) The nature and estimated amounts of expenses to be
incurred by the Underwriters in connection with the
purchase and reoffering of the Notes are set forth
in schedule I attached hereto.
(b,) There are no "finders", as defined in Section
218.386, Florida Statutes, as amended, connected
with the issuance of the Notes.
(c) Subject to the outcome of negotiations of -the terms
of the Note Purchase Agreement and to the
successful sale by the Underwriters of all the
9112101.19478.@do
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35
t if 1 0
SEN7 SY:A Profeesional Corp. 9-18-91 ', 10,45 Lewie, 01te & Ciey-4
#20
Notes at the initial public offering price, it is
our expectation that based on current market
conditions, the underwriting spread (i.e., the
difference between the price at which the Notes
will be initially offered to the public by the
Underwriters and the price to be paid to the Issuer
for the Notes) , will be ___-,_ % of the principal
amount of the Notes.
(d) Based on and as part of the estimated underwriting
spread not forth in paragraph (c) above, the
Underwriters will not charges a management fee in
respect of the Notes.
(a) There is no other fee, bonus or other compensation
to be paid by the Underwriters in connection with
the issuance of the Notes to any parson not
regularly employed or retained by the Underwriters,
except as specifically enumerated as expenses
referred to in paragraph (a) above to be incurred
by the Underwriters as set forth in Schedule I
attached hereto.
(f) The name and address of each of the Underwriters
are set forth in Schedule II attached hereto.
We understand that you do not require any further disclosure
from the Underwriters pursuant to Section 218.385(4), Florida
Statutes, as amended.
9112101.19478.eds
Very truly yours,
PAINEWEBBER INCORPORATED
GRIGSBY BRANDDFORD POWELL? INC.
AIBC INVESTMENT SERVICES CORP.
GUZMAN be COMPANY
By: PAINEWEBBER INCORPORATED,
Representative
By: --
Richard Wells, Vice President
3(,=
91--- 696
001 WiA rrote681ona i Leorp, i V-10-VI ; W 40 ; - 4eWi8o wnite & G18yy
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SCHEDULE I
ESTIMATED EXPENSES
(based on $25,000,000 issue size)
cUBIP Registration S
Municipal Securities Rulemaking Board
Assessment Fee ($0.01 per $1,000)
Public Securities Association Assessment Fea
($0.02 per $1,000)
Cost of Federal Funds
DTC Fees
Underwriters' Counsel
Blue Sky lees and expanses
Out -of -Pocket Expenses
Miscellaneous
TOTAL
9112101.19478.ads
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9CHECULE 11
9112101.19478.sds 3 9'
Oeni nr.n rroressionsi uorp. ► U-10-Ul ; 1046
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i 23
EXHIBIT C
(Letterhead of Co -Bond Counsel)
October _„_, 1991
PaineWebber Incorporated
701 Brickell Avenue
Suite 2400
Miami, Florida 33131-2801
Grigsby Branddford Powell, Inc.
230 California Street, Suite 601
San Francisco, California 94111
AIBC Investment Services Corp.
8o S.W. Sth Street, Suite 1970
Miami, Florida 33130
Guzman & Company
701 Brickell Avenue, iith Floor
Miami, Florida 33130
$25,000,000 The City of Miami
Try_Anticigation Notes. Se ies 1991
Ladies and Gentlemens
This opinion supplements our bond opinion, dated the date
hereof, relating to the above -referenced notes (the "Notes") .
Except as otherwise defined herein, the terms used herein shall
have the meanih9s prescribed for them in that opinion. In addition
to the documents specifically mentioned in that opinion, we have
examined the portions of the Official Statement, dated September
1991, respecting the Notes ("Official Statement"), captioned
eecription of the Notes" (other than the portion thereof
captioned "Book -Entry Only System") and "Security for the Notes" to
the extent such portions purport to summarize certain provisions of
the Resolution (as defined in the Official Statement) and "Tax
Matters", insofar as they relate to this opinion.
w41w4/ 4 46A"n wd•
39
91.- 696
SENT SY:A Professional Corp, ; 8-18-91 ; 10:48 LBWi$fWhite & Clay-4 ;4L4
LI
Based on our examination, we are of the opinion, as of the
date hereof and under existing law, as follows:
1. The statements contained in the official statement under
the captions "Description of the Notes" (other than the
portion thereof captioned "Book -Entry only System") and
"security for the Notes" to the extent such portions
purport to summarize certain provisions of the Resolution
(as defined in the Official statement) and "Tax Matters",
insofar as such statements purport to summarize certain
provisions of the Notes or conclusions of law and legal
opinions, are true, accurate and correct summaries
thereof in all material respects and do not omit to estate
a material tact necessary in order to make the statements
therein, in light of the circumstances under which they
were made, not misleading. In addition, based solely
upon such Counsel's examination of the proceedings of the
city in connection with their opinion as to the validity
of the Notes and solely upon their participation in
certain meetings and conference calls at which
representatives of the City, Underwriters and counsel to
the Underwriters were present for the preparation of the
Preliminary official Statement and the official
Statement, and, except as to the information contained
under the headings set forth above, without having
undertaken to determine independently the accuracy or
completeness of the statements contained in the
Preliminary official Statement and the Official
statement, as of the date of the Purchase Agreement and
as of the date of the Closing respectively (except for
the information contained the financial statements and
information set forth in Appendices _._ and ,._,_, the
information contained in Appendix ,, and other financial
and statistical data included therein, as to which no
opinion is expressed) nothing has come to their attention
which would cause them to believe that the Preliminary
official Statement and the official Statement contain any
untrue statement of a material fact or omit to state any
material fact necessary to make the statements therein,
in the light of the circumstances under which they were
made, not misleading.
2. The'Notoo.are exempted securities within the meaning of
the Securities Act of 1933, as amended, and the offer and
sale thereof does not require registration pursuant to
the Securities Act of 1933, as amended, and the
Resolution and any other related instrument are not
required to be qualified under the Trust Indenture Act of
1939, as amended, in connection with the offer and sale
of the Notes.
9112101.19478.sda
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3. The Purchase Agreement has been duly authorized, executed
and delivered by the City and (assuming due
authorization, execution and delivery by the
Underwriters) constitutes a valid and binding agreement
of the City enforceable according to its term®, subject
to any applicable bankruptcy, reorganization, insolvency,
moratorium or other law affecting the enforcement of
creditors' rights generally.
This opinion is being rendered to you solely for your benefit.
Very truly yours,
9112101.1947 8.sdo
7
(
SENT 9Y:A Professionsi Corp, 8-1b-91 ; 10:47 LOWIStwn:te a WAY" 141.0
a 0
EXHIBIT D
[Letterhead of Counsel to the City)
September , 1991
PaineWebber Incorporated
701 Brickell Avenue
Suite 2400
Miami, Florida 33131-2801
Grigsby Branddford Powell, Inc.
230 California Street, Suite 601
San Francisco, California 94111
AIBC Investment services Corp.
8o S.W. 8th Street, Suite 1970
Miami, Florida 33130
Guzman & Company
701 Brickell Avenue, 11th Floor
Miami, Florida 33130
$25,000,000 The City of Miami Tax
AnticipAligh o ��,,Se ies 1991
Ladies and Gentlemen:
We have acted as counsel for The City of Miami (the "City")
and have acted as such in connection with the sale of the above -
referenced Notes, which are being delivered and sold pursuant to a
Note Purchase Agreement dated September i, 1991 (the "Purchase
Agreement") among PaineWebber Incorporated, Grigsby Branddford
Powell, Ina., AIBC Investment Services Corp., and Guzman & Company
(the "Underwriters") and the City. Any capitalized term used
herein and not defined shall have the meaning assigned to it in the
Purchase Agreement.
In this connection, we have reviewed and examined certain
proceedings -and documents with respect to the Notes, and such
records, certificates and other documents as we have considered
necessary or appropriate for the purposes of this opinion.
including the Act, the Resolution, the Purchase Agreement, the
Preliminary Official Statement dated , and the Final
Official Statement dated ,with respect to the
9112101.19476.sds
91- 696
y'2
SENT BY:A Professional Corp, ; 9-18-91 ; 10:48 I LewMWhite & CISY"I
of 0
#27
issuance and offering of the Notes (collectively, the "Official
Statement") and a closing certificate of the City.
Based on such review and such other considerations of law and fact
as we believe to be relevant, we are of the opinion that:
1. The City is a municipal corporation duly organized under
the laws and Constitution of Florida. The City is
authorized by the laws of Florida, including particularly
the Act, to issue, sell and deliver the Notes for, among
other purposes, the purposes expressed in the official
Statement and to enter into and perform its obligations
under the Purchase Agreement.
2. The City has full power and authority to consummate all
transactions contemplated by the Notes, the Purchase
Agreement and any and all other agreements relating
thereto, to which the City is a party.
3. The City has duly authorized all action necessary to be
taken by it or on its behalf for (i) the issuance and
delivery of the Notes; (ii) the execution and delivery of
the Purchase Agreement; (iii) the approval of the
distribution of the Official Statement; and (iv) the
carrying out, giving effect to, and consummation of the
transactions contemplated thereby.
4. The Purchase Agreement has been duly and validly
authorized, executed and delivered by the City, and the
same is in full force and effect as of the date hereof
and is a valid and legally binding obligation of the
City, enforceable against the City in accordance with its
terms, except to the extent the enforceability thereof
may be limited by bankruptcy, insolvency, reorganization,
moratorium or similar laws relating to or affecting
creditors' rights generally.
5. The Resolution was duly adopted at a meeting of the
Commissioners of the City which was called and held
pursuant to law and in accordance with all applicable
open meeting laws and at which a quorum was present and
acting at the time of the adoption of the Resolution and
the -Resolution was adopted by a majority vote of all
members of the Commissioner.
6. The execution and delivery by the City of the Purchase
Agreement, and the performance of its obligations
thereunder do not and will not result in a violation of
any provision of, or in default under, Florida statutes
organizing and governing the City or, to the best of our
knowledge after diligent inquiry and review of the CityyIs
records, any agreement or other instrument to which the
9112101.19478.sde
q3
91-' 696
ociri nr-M rrotessionoi toorp, a-in-ai lu.40 + • Lewlsi wnice at 4i&Y", 94c0
City is a party or by which it or its properties are
bound.
7. All actions necessary to be taken by the Commissioner of
the City have been taken, and no additional approval,
authorization, consent or other order of the City or any
public board or body is legally required to allow the
City to enter into and perform its obligations under the
Purchase Agreement, as described in the Official
Statement.
Be The City is not in violation of any provision of. or in
default under, Florida statutes organizing and governing
the City.
9. There are no legal or governmental actions, proceedings,
inquiries or investigations pending or threatened by
governmental authorities or to which the city is a party
or of which any property of the City is sub3ect, except
as described in the Official Statement, which, if
determined adversely to the City, would individually or
in the aggregate (i) materially and adversely affect the
validity or the enforceability of the Purchase Agreement,
(ii) otherwise materially or adversely affect the ability
of the city to comply with its obligations under the
Purchase Agreement, or materially and adversely affect
the transactions contemplated by the Official Statement
to be engaged in by the City.
10. Based upon our experience as counsel for the city and on
our review of and participation in the drafting of the
Official Statement, and after diligent inquiry, we have
no reason to believe that the information regarding the
City in the Official Statement contains any untrue
statement of a material fact or omits to state any
material fact necessary in order to make the statements
made therein, in light of the circumstances under which
they were made, not misleading.
11. The City has not been notified of any listing or proposed
listing by the Internal Revenue Service to the effect
that it is a bond issuer whose arbitrage certifications
may -not be relied upon.
We hereby consent to the references made to us in the official
statement.
Very truly yours
9112101.19478.sds
qy
91- 696
SENT 9Y:A Professional Corp. 9-18-91 ; 10:49 Lew,�'
is'White & 01AYof OP
EXHIBIT E
(Letterhead of Counsel to the Underwriters)
September r„_, 1991
PaineWebber Incorporated
701 Brickell Avenue
Suite 3400
Miami, Florida 33131-7801
Grigsby Branddford Powell, Inc.
330 California Street, Suite 601
San Francisco, California 94111
AIBC Investment Services Corp.
80 S.W. 8th Street, Suite 1970
Miami, Florida 33130
Guzman 8 Company
701 Brickell Avenue, lath Floor
Miami, Florida 33130
$25,0001000 The City of Miami
TAIg ,Ala i s��on Hotee�ee"g
Ladies and Gentlemen:
This letter is being delivered to you pursuant to the Note
Purchase agreement dated , (the "Purchase Agreement") among
The City Of Miami. (the "City"), and PaineWebber Incorporated (the
"Representative") relating to the sale of the above -referenced
Notes. The terms defined in the purchase Agreement are used in
this latter with the meanings assigned to them in the Purchase
Agreement.
We have acted as your Counsel in connection with the issuance
and sale of the Notes to you, and in that capacity have examined an
executed counterpart of the Purchase Agreement. we have also
examined the originals or copies, certif isd or otherwise identified
to our satisfaction, of such other documents, corporate records and
9112101.19478.sd■
16
91 - 696
other instrument gas we have deemed necessaryor advisable for
purposes of this letter.
In connection with the preparation of the Preliminary
Official Statement dated and the Final Official
Statement dated (collectively, the "Official
Statement") , we have generally reviewed information furnished to us
by, and have participated in conferences with, representatives of
the City, its respective counsel, independent certified public
accountants of the Corporation, your representatives and [BOND
COUNSEL], Bond Counsel. We have also reviewed other records
relating to the authorization, issuance and sale of the Notes and
have relied upon certificates of officials of the City and upon
written opinions and letters received from the City and its
attorneys and independent certified public accountants.
We have considered the information contained in the Official
Statement and, based upon our review and discussions and in
reliance upon the accuracy of the information contained in the
aforementioned certificates, written opinions and letters, and
further, based upon our participation in the preparation of the
Preliminary Official Statement and the Official Statement as
Counsel to the Underwriters which involved participation in
conferences with representatives of the City at which the contents
of the Preliminary Official Statement and the Official Statement
and the ordinances and related matters were discussed and revised,
and without having undertaken to determine independently the
accuracy or completeness of the statements contained in the
Preliminary official Statement and the Official Statement, nothing
has come to our attention which has caused us to believe that the
Preliminary Official Statement and the Official Statement as of
their respective dates, and, as supplemented or amended as rewired
at all times subsequent thereto up to and including the date of
Closing, at the date of the closing (except for the statistical and
financial information contained in Appendices and _ and the
financial statements included in Appendices and , and other
financial and statistical data included therein, as to which no
opinion is necessary), contain any untrue statement of a material
fact or omit to state any material fact required to be stated
therein or necessary to make the statements therein, in the light
Of CirCunstances under which they were made, not misleading. We
express no opinion as to the financial statements included in the
Official Statement, and we express no opinion as to any other
financial or statistical data included in the official Statement or
the Exhibits thereto.
very truly yours,
9112101.19479.ede
qb
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110
FXFIPIT"C" D R AFY
pRELIMINARY CSICIAL STATEKENT DATED 8Ep 1BER —, 1991
in the opinion of Co -Bond Counsel, assuming continuing
compliance with certain arbitrage rebate and other tax requirements
referred to herein, under existing law, facts and circumstances,
interest on the Notes is excluded from gross income for federal
income tax purposes and will not be treated as an item of tax
preference in computing the alternative minimum tax for individuals
and corporations. Interest on such Notes will, however, be taken
into account in computing an adjustment made in determining a
corporate Noteholder's alternative minimum tax, and holders of
9**eht1 Note could be subject to the consequences of other
provIs.ons of the Internal Revenue Code of 1986, as amended, as
further described herein. In the opinion of Co -Bond Counsel, under
existing law, the Notes are exempt from present intangible personal
property taxes imposed by the State of Florida. See "TAX MATTERS"
herein.
NEW ISSUE
BOOK -ENTRY ONLY
Dated Date:
Rate: %
RATINGS:
$25,000,000*
THE CITY OF NIAKI,
Taz Anticipation Notes,
Date of Delivery
Moodys:
S&P:
See "Ratings" herein.
FLORIDA
Series 1991
Due: October _, 1992
Price %
The Tax Anticipation Notes, Series 1991 (the "Notes"), are being
issued by The City of Miami, Florida (the "City") for the purpose
of providing funds to pay the appropriations made by the City for
the fiscal year ending September 30, 1992 (the "Fiscal Year") in
anticipation of the receipt of ad valorem taxes collected by the
City during the Fiscal Year other than revenues from ad valorem
taxes approved by referendum and levied specifically to pay debt
service on bonds or other obligations issued by the City (the
"Pledged Funds") and to pay a portion of the costs of issuance of
the Notes. The Notes, when issued, will be registered in the name
of Cede & Co., as nominee of The Depository Trust Company, New
York, New York ("DTC"), acting as securities depository for the
Notes. Individual purchases of the Notes will be made in book -entry
form only in denominations of $5,000 or any integral multiple
thereof. Purchasers of the Notes will not receive physical
delivery of note certificates. Transfers of the Notes will be
effected through a book -entry system as described herein. As long
as DTC or its nominee is the registered owner of the Notes,
payments of interest on and principal of the Notes are to be made
to Cede & Co., as nominee for DTC as registered owner of the Notes,
by NCNB National Bank of Florida, Tampa, Florida, as paying agent
("the "Paying Agent") Cede & Co is responsible for remitting such
interest and principal payments to DTC Participants (as defined
10
91-- 696
1 1% [Continued - Cover Page]
2
3 herein) for subsequent disbursement to the Beneficial owners of the
4 Notes.
5
6 The principal of and interest on the Notes shall be paid at
maturity. The Notes are not subject to redemption prior to
maturity.
The principal of and the interest on the Notes are payable solely
from and secured solely by a prior lien on and pledge of the Cityls
ad valorem taxes collected during the Fiscal Year, except such ad
valorem taxes approved by referendum and levied specifically to pay
debt service on bonds or other obligations issued by the City which
constitute the Fledged Funds. The Notes do not constitute a
general obligation of the City and neither the full faith and
credit nor the taxing power of the City, Dade County, Florida or
the State of Florida or any political subdivision thereof or
governmental authority or body therein are pledged to the payment
of the principal of or interest on the Notes, except for the
Pledged Funds.
The Notes are offered when, as and if issued and received by the
Underwriters, subject to the unqualified opinion as to legality by
Kubicki, Draper, Gallagher & McGrane, P.A., Miami, Florida and
Holland & Knight, Miami, Florida, Co -Bond Counsel. Certain matters
will be pass: d on for the City by A', Qu3� c beEsq. , l , r.
City Attornr, and for the Underwriters ... by' Lewis, 'White & Clay, A
Professional Corporation, Detroit, Michigan and Armando J. Bucelo,
Jr., Miami, Florida. Howard Gary & Company, Miami, Florida, and
Raymond James & Associates, Inc., St. Petersburg, Florida, are
serving as financial advisors to the City. It is expected that the
Notes in book -entry form will be available for delivery in New
York, New York on or about October 10, 1991.
PAINEWEBBER INCORPORATED
GRIGSBY BRANDFORD POWELL, INC.
September , • 1991
Subject to change
t---E-mpeeted
AIBC INVESTMENT SERVICES CORPORATED
GUZMAN & COMPANY
Uri
91-- 696
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TEX CITY OF MIAKIP FLORIDA
MEM88RS OF THE BOARD OF CITY COMMISSION$RS
THE HONORABLE XAVIER L. SUAREZ, MAYOR
THE HONORABLE J. L. PLUMMER# JR., VICE -MAYOR
THE HONORABLE MILLER J. DAWKINS, COMMISSIONER
THE HONORABLE DR. MIRIAM ALONSO, COMMISSIONER
THE HONORABLE VICTOR H. DeYURRE, COMMISSIONER
CITY OFFICIALS
City Manager
79-
ty Attorney
D.Lrector of Finance
City Clerk
Co -Hoed Counsel
CESAR H. ODIO
�4tt.�
CAMEOS . S . GARCIA'r
MATTY HIRAI
KUBICKI, DRAPER, GALLAGHER & MCGRANE, P.A.
Miami, Florida
HOLLAND & KNIGHT
Miami, Florida
Financial Advisors
HOWARD GARY & COMPANY
Miami, Florida
RAYMOND JAMES & ASSOCIATES, INC.
St. Petersburg, Florida
qy
91--" 696
i
1 No dealer, broker, salesperson or other person has been
2 authorized by The City of Miami, Florida to give any information or
3 to make any representations other than those contained herein and,
A if given or made, such other information or representation must not
be relied upon as having been authorized by the City. This
Official Statement does not constitute an offer to sell or a
7 solicitation of an offer to buy any Notes nor shall there be any
8 sale of the Notes to any person in any jurisdiction in which it is
9 unlawful to make such an offer, solicitation or sale.
10
11 This Official Statement is not to be construed as a contract
12 with the purchasers of the Notes. Statements contained in this
13 Official Statement which involve estimates, forecasts or matters of
14 opinion, whether or not expressly so described herein, are intended
15 solely as such and are not to be construed as a representation of
16 fact.
17
18 The information set forth herein has been obtained from The
19 City of Miami and other official sources which are believed to be
20 reliable but is not guaranteed as to accuracy or completeness by,
21 and is not to be construed as a representation by, the
22 Underwriters. The information and expressions of opinions herein
23 are subject to change without notice and neither delivery of this
24 Official Statement nor any sale made hereunder shall, under any
25 circumstanceo, create any implication that there has been no change
2 in the affa.zs of the City since the date hereof.
2,
28 This Official Statement is submitted in connection with the
29 offer and sale of the Notes and may not be reproduced or used, in
30 whole or in part, for any other purpose.
31
32 IN CONNECTION WITH THIS OFFERING, THE UNDERWRITERS MAY OVER-
33 ALLOT OR EFFECT TRANSACTIONS WHICH STABILISE OR MAINTAIN THE MARKET
34 PRICE OF THE NOTES AT A LEVEL ABOVE THAT WHICH FIGHT OTHERWISE
35 PREVAIL IN THE OPEN MARKET. SUCH STABILISING, IF COMMENCED, MAY BE
36 DISCONTINUED AT ANY TIME.
37
38 THE NOTES HAVE NOT BEEN REGISTERED WITH THE SECURITIES AND
39 EXCHANGE COMMISSION UNDER THE SECURITIES ACT OF 1933f AS AMENDED,
40 NOR HAS THE RESOLUTION BEEN QUALIFIED UNDER THE TRUST INDENTURE ACT
41 OF 1939, AS AMENDED, IN RELIANCE UPON EXEMPTIONS CONTAINED IN SUCH
42 ACTS. THE REGISTRATION OR QUALIFICATION OF THE NOTES IN ACCORDANCE
43 WITH APPLICABLE PROVISIONS OF THE SECURITIES LAWS OF THE STATES, IF
44 ANY, IN WHICH THE NOTES HAVE BEEN REGISTERED OR QUALIFIED AND THE
45 EXEMPTION FROM REGISTRATION OR QUALIFICATION IN CERTAIN OTHER
46 STATES CANNOT BE REGARDED AS A RECOMMENDATION THEREOF. NEITHER
4 THESE STATES NOR ANY OF THEIR AGENCIES HAVE PASSED UPON THE MERITS
4b OF THE NOTES OR THE ACCURACY OR COMPLETENESS OF THIS OFFICIAL
49 STATEMENT. ANY REPRESENTATION TO THE CONTRARY MAY BE A CRIMINAL
50 OFFENSE.
51
'G
91-- 696
I TAM Or CONT NT8
2 Pace
3
INTRODUCTION...........................................
AUTHORITYFOR THE ISSUE ................................
PURPOSEOF THE NOTES ...................................
r1M OF Tr!\'laTClN TITTTi�TT"
DESCRIPTIONOF THE NOTES ...............................
DEBTSUNIlKARY...........................................
TAXMATTERS ............................................
LITIGATION...* ..........................................
RATINGS................................................
UNDERWRITING...........................................
FINANCIALADVISORS .....................................
FINANCIALSTATEMENTS ...................................
LEGALITY...............................................
DISCLOSURES REQUIRED BY FLORIDA BLUE SKY REGULATIONS...
CERTAINCLOSING CERTIFICATES ...........................
MISCELLANEOUS..........................................
APPENDIX A - DESCRIPTION OF THE CITY OF MIAMI..........
APPENDIX B - GENERAL PURPOSE FINANCIAL STATEMENTS......
APPENDIXC - THE RESOLUTION ............................
APPENDIX D - FORM OF LEGAL OPINION .....................
:51
91- 696
1 Off iciai statement
2 $25,000000*
3 THE CITY OF MIAMIt FLORIDA
Tax Anticipation Notes, series 1991
INTRODUCTION
The purpose of this Official Statement, including the cover
page and all appendices hereto, is to set forth certain information
in connection with the sale by The City of Miami Florida (the
"City'), of its $25,000,000* aggregate principal amount of Tax
Anticipation Notes, Series 1991 (the "Notes").
AUTHORITY FOR THE ISSUE
The Notes are being issued pursuant to the Constitution and
laws of the State of Florida, particularly Chapter 166, Florida
Statutes, as amended, and pursuant to the Charter of the City, as
amended (collectively, the "Act"), and a resolution duly adopted by
the City on September , 1991 (the "Resolution"). A copy of the
Resolution is included as APPENDIX C hereto. Capitalized terms
used herein and not defined shall have the meaning ascribed to them
in the Resolution. For a complete description of the terms and
conditions of the Notes, reference is made to the Resolution. The
description of the Notes and the documents authorizing and securing
the Notes and the information from reports contained herein do not
purport to be comprehensive or definitive. All references herein
to the Notes and such documents and reports are qualified in their
entirety by reference thereto.
PURPOSE OF THE NOTES
The Notes are being issued
to pay the appropriations made
for the fiscal year of the Ci-
"Fiscal Year") in anticipation
valorem taxes for such Fiscal
costs of issuance of the Notes.
for the purpose of providing funds
)y the City Commission of the City
.y ending September 30, 1992 (the
of the receipt of the City 's ad
Year and to pay a portion of the
DESCRIPTION OF THE NOTES
4F The Notes will be issued in the aggregate principal amount,
4 will bear interest at the rate, and will mature on the date, all as
48 set forth on the cover page of this Official Statement. The Notes
49 * Subject to change
18604 -1-
91- 696
...
,t or%
_,
1 will be dated the date of their original issuance and delivery and
2 shall be issued in fully registered form in the denominations of
3 $5,000 or any integral multiple thereof and, when issued, will be
registered in the name of Cede & Co., as nominee of The Depository
Trust Company, New York, New York ("DTC"). Purchases of beneficial
o interests in the Notes will be made in book -entry -only form
7 (without certificates) in the denomination of $50000 or any
8 integral multiple thereof.
9
10 Hook -Entry only System
11
12 DTC will act as securities depository for the Notes. The
13 Notes shall initially be issued exclusively in "book -entry" form
14 and ownership of one fully registered Note in the aggregate
15 principal amount of $25,0000000 will be initially registered in
16 the name of "Cede & Co." as nominee of DTC.
17
18 DTC is a limited -purpose trust company organized under the
19 laws of the State of New York, a member of the Federal Reserve
20 System, a "clearing corporation" within the meaning of the New. York
21 Uniform Commercial Code, and a "clearing agency" registered
22 pursuant to the provisions of Section 17A of the Securities
23 Exchange Act of 1934, as amended. DTC was created to hold
24 securities of its participants (the "DTC Participants") and to
2' facilitate the clearance and settlement of securities transactions
among DTC Participants through electronic book -entry changes in
27 accounts of the DTC Participants, thereby eliminating the need for
28 physical movement of certificates. DTC Participants include
29 securities brokers and dealers, banks, trust companies, clearing
30 corporations and certain other organizations, some of which (and/or
31 their representatives) own DTC. Access to the DTC system is also
32 available to others such as banks, brokers, dealers and trust
33 companies that clear through or maintain a custodial relationship
34 with a DTC Participant, either directly or indirectly.
35
36 For the purposes of this Official Statement, the term
37 "Beneficial Owner" shall mean the person for whom the DTC
38 Participant acquires an interest in the Notes. Ownership interests
39 in the Notes may be purchased by or through DTC Participants.
40 Neither the DTC Participants nor the Beneficial Owners will receive
41 Notes, but each DTC Participant is to instead receive a credit
42 balance in the records of DTC in the amount of such Participant's
43 interest in the Notes, which will be confirmed in accordance with
44 DTC's standard procedures. Each Beneficial Owner may desire to
45 make arrangements with the DTC Participant from whom it has
4e purchased an ownership interest in the Notes, to receive a credit
4 balance in the records of such DTC Participant, and to have all
4b notices of redemption or other communications of the City to DTC,
49 Subject to change
18604
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91 - 696
�o •
1 which may affect such Beneficial Owner, forwarded in writing by
2 such DTC Participant and to receive notification of all payments.
3
As long as Cede & Co. or its registered assignee is the
registered owner of the Notes, the City shall be entitled to treat
the person in whose name any Note is registered as the absolute
7 owner thereof for all purposes of the Resolution and any applicable
8 laws, notwithstanding any notice to the contrary received by the
9 City, and the City shall have no responsibility for transmitting
0 payments to, communicating with, notifying, or otherwise dealing
1 with any Beneficial Owners of the Notes.
51
DTC is to receive payments on the Notes from NCNB National
Bank of Florida, Tampa, Florida, as paying agent (the "Paying
Agent") to be remitted to the DTC Participants for the subsequent
disbursement to the Beneficial Owners. The ownership interest of
each Beneficial Owner in the Notes is to be recorded on the records
of the DTC Participants, whose ownership interest is to be recorded
on a computerized book -entry system operated by DTC. For as long
as any purchaser is the Beneficial Owner of a Note, he must
maintain an account with a broker or dealer who is, or acts
through, a DTC Participant, in order to receive payments on such
Note. The City cannot and does not give any assurances that DTC,
DTC Participants or others will distribute payments on the Notes
paid to DTC cr its nominee, as the registered owner, or any notices
to the Beneiicial Owners or that they will do so on a timely basis
or will serve and act in a manner described in this Off icial
Statement. The City is not responsible or liable for the failure
of DTC, DTC Participants or others to make any payment or give any
notice to a Beneficial Owner in respect of the Notes or any error
or delay relating thereto.
When reference is made to any action which is required or
permitted to be taken by the Beneficial Owners, such reference
shall only relate to those permitted to act (by statute, regulation
or otherwise) on behalf of such Beneficial Owners for such purposes
when notices are given, they shall be sent by the City to DTC. DTC
shall forward (or cause to be forwarded) the notice to the DTC
Participants so that such Participants may forward (or cause to be
forwarded) the Notices to the Beneficial Owners.
Beneficial Owners are to receive a written confirmation of
their purchase detailing the terms of the Notes acquired.
Transfers of ownership interest in the Notes are to be accomplished
by book entries made by DTC and the DTC Participants who act on
behalf of the Beneficial Owners of the Notes. Beneficial Owners
will not receive certificates representing their ownership
interest. Paymbnts on the Notes are to be paid by the Paying Agent
to DTC, then paid by DTC to the DTC Participants and thereafter
paid by the DTC Participants to the Beneficial Owners when due.
18604 -3-
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yi-_. 696
I For every transfer and exchange of the Notes, the Beneficial
2 Owner may be charged a sum sufficient to cover any tax, fee or
3 other governmental charge that may be imposed in relation thereto.
/ DTC may determine to discontinue providing its services with
c, respect to the Notes at any time by giving notice to the City and
7 discharging its responsibilities with respect thereto under
8 applicable law. In addition, the City may determine to no longer
9 utilize the services of DTC. If either of such determinations is
0 made, and the City identifies another qualified securities
1 depository to replace DTC, the City will make arrangements with DTC
2 and such other depository to effect such replacement and deliver
3 replacement Notes registered in the name of such other depository
4 and its nominee in exchange for the outstanding Notes. If the City
5 fails to identify another qualified securities depository to
6 replace DTC, the City is obligated to deliver Notes as described in
7 the Resolution.
In the event of an insolvency of DTC, if DTC has insufficient
securities in the fungible bulk of securities in its custody (e.g.,
due to theft or loss) to satisfy the claims of its DTC Participants
with respect to deposited securities and is unable by
(1) application of cash deposits and securities pledged to DTC to
protect DTC against losses and liabilities; (2) the proceeds of
insurance m::intained by DTC and/or its DTC Participants; or
(3) other resources, to obtain securities necessary to eliminate
the insufficiency, DTC Participants may not be able to obtain all
of their deposited securities.
SECURITY FOR THE NOTES
The principal of and interest on the Notes and all required
sinking fund and other payments shall be payable solely from the
City's ad valorem taxes collected during the Fiscal Year other than
ad valorem taxes approved by referendum and levied specifically to
pay debt service on bonds or other obligations issued by the City
(the "Pledged Funds"). Neither the full faith and credit nor the
taxing power of the City, Dade County, Florida or the State of
Florida or any political subdivision thereof or governmental
authority or body therein are pledged to the payment of the
principal of or interest on the Notes.
44 Commencing on December 1, 1991, the Director of Finance shall
45 withdraw from the General Fund of the City all Pledged Funds as
46 received and deposit the amount so withdrawn to the credit of a
4 special fund called the Note Fund created under the terms of the
48 Resolution (the "Note Fund"), until the amount then on deposit to
49 the credit of the Note Fund on the first day of the indicated month
50 equals the following percentages of the sum of the principal of and
18604 -4-
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3
b
7
8
9
10
it
12
13
14
15
16
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18
19
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21
22
23
24
7'
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
48
interest on the Notes to be paid at maturity (the "Note Fund
Requirement"):
Percentage of I
December
25%
January
15
February
10
March
10
April
10
May
10
June
7
July
5
August
5
September
3
Total 100%
If the amount so deposited in any month to the credit of the
Note Fund shell be less than the required amount for such month,
the requirerent therefor shall nevertheless be added to the amount
otherwise required to be deposited in each month thereafter until
such time as such deficiency shall have been made up. Pledged
Funds deposited to the credit of the Note Fund in excess of the
monthly deposit requirement set forth above shall be credited
against future Note Fund deposit requirements. Payments into the
Note Fund shall be adjusted to give credit for investment earnings
then on deposit in the Note Fund and to make up any deficit in the
required cumulative balance attributable to investment losses.
Moneys in the Note Fund shall be trust funds and shall be at all
times secured as are other deposits of public funds. Amounts in
the Note Fund shall be invested
The City will not create or suffer to be created any lien or
charge upon the Pledged Funds ranking equally with or prior to the
Notes, except for direct obligations of the City for which the full
faith, credit and taxing power of the City have been or shall be
pledged.
1 SOURCES AND USES OF FVWD8
2
3
The following table sets forth the overall anticipated sources
and uses of funds associated with the issuance of the Notes:
Sources of Funds:
Principal Amount of the Notes $a5,000.000*
Total Sources $ OEM
Uses of Funds:
Deposit to the General Fund $
Cost of Issuance
Underwriters Discount
Total Uses $
* Subject to change
REGISTRATION, EXCHANGE AND TRANSFER
As long' as a book -entry system is used for determining
beneficial ownership of Notes, registration, transfer and exchange
of Notes will occur as described under "Book -Entry -Only System".
LEGAL DEBT LIMITATIONS
The Florida Constitution
The Florida Constitution does not provide a limit on the
amount of ad valorem taxes the City may levy for voted bonds.
However, pursuant to Article VII, Section 9 of the Florida
Constitution, the City is limited to an annual maximum tax levy of
10 mills per $1.00 ($10 per $1,000) of the assessed value of real
estate and tangible personal property for municipal purposes, other
than for the payment of voted bonds. Ad valorem taxes levied for
periods not exceeding two years and authorized by a vote of the
electorate are excluded from 10 mill limitations.
Article VII, Section 12 of the Florida Constitution requires
the approval of electors prior to the issuance of bonds payable
from ad valorem taxes and maturing more than twelve months after
issuance. The provision in Article VII, Section 12, which limits
such vote to electors who are owners of freeholds not wholly exempt
from taxation has been held by the courts to be void. Accordingly,
all qualified electors in the City are eligible to vote in bond
18604 -6-
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91_- 696
MR
1 elections. The remainder of the relevant section of the Florida
2 Constitution providing for ad valorem taxation has been held valid
3 and remains operative.
' The City Charter
36
37
38
39
40
41
42
43
44
45
4F
48
49
50
51
The City Charter limits general obligation debt of the City to
15% of the assessed valuation of all real and personal property
within the City limits as shown by the last preceding assessment
roll of the City and provides that bonds for street, sewer,
sidewalk and other public improvements which are paid from special
assessments shall not be subject to such limitation of amount nor
be considered when computing the amount of general obligation bonds
that may be issued.
The debt limitation for general obligation bonds as of
September 30, 1990 was $1,580,007,572 based on the net assessed
valuation of $10,533,383,819. Outstanding general obligation debt
applicable to the City's debt limitation as of September 30, 1990
totaled $185,840,000, which is approximately 1.7b$ of the net
assessed valuation.
DEBT SUMMARY
The information under this heading is subject in all respects
to the more aetailed financial information in the audited financial
statements of the City. See the General Purpose Financial
Statements of the City for the fiscal year ended September 30, 1990
attached hereto as Appendix B.
Short -Term Borrowing History
198:9
14, 96t�, D;Qt
-a- . _ .. .
-0-
198�5
�p
1985
-0-
* Based on the City's fiscal year ended 6epteW)ii:30
18604
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cro ing
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C
1
2
3
10
Selected Debt Data
The following tables provide details of the City's principal
and interest requirements on general obligations bonds and
overlapping debt of the County.
18604
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91- 696
1 General Obligation Bonded Indebtedness
2 Principal and Interest Requirements
3
as of
September 30, 1990
Fiscal
Year
Ending
9/30 Prinaigal
interest
MAI
7
8
1991
$ 8,655,000
$ 11,317,525
$ 19,972,525(f)
9
10
1992
11,915,000
12,251,774
24,166,774
11
12
1993
11,270,000
11,423,490
22,693,490
13
14
1994
11,205,000
10,578,279
21,783,279
15
16
1995
11,530,000
9,828,419
21,358,419
17
18
1996
11,425,000
9,065,429
20,490,429
19
20
1997
11,525,000
8,310,893
19,835,893
21
22
1998
10,745,000
7,568,964
18,313,964
23
24
1999
9,965,000
6,845,202
16,810,202
25
26
2000
9,300,000
6,079,556
15,379,556
27
28
2001
9,875,000
5,327,630
15,202,630
7
2002
9,970,000
4,742,100
14,712,100
3i
32
2003
10,490,000
3,996,946
14,486,946
33
34
2004
8,750,000
3,215,336
11,965,336
35
36
2005
8,300,000
2,579,221
10,879,221
37
38
2006
6,565,000
1,961,511
8,526,511
39
40
2007
5,160,000
1,488,913
6,648,913
41
42
2008
4,190,000
1,138,467
5,328,467
43
44
2009
4,225,000
876,615
5,101,615
45
46
2010
3,070,000
655,184
3,725,184
47
48
2011
2,395,000
461,404
2,856,404
49
50
2012
1,735,000
324,169
2,059,169
51
52
2013
1,795,000
212,681
2,007,681
53
5
2014
1,785,000
97,006
1,862.006
5
56
TOTAL
S 185,840,000
S 120.346,714
S306.186,714
57
58
(1) Excludes October 1, 1990 installment in the amount
of $3,997,133 recorded
59
in
the general obligation debt service fund.
18604 -9-
m
91- 696
1
Not Direct and ovarlappinq Debt as of September 30, 1990
2
(Amounts rounded to nearest thousands)
3
General Special
d
obligation obligation Combined
7
Debt Debt (Net)(1) Debt
8
9
City
of Miami $184, 302, 000 $217, 378, 000�2) $401,680,000
10
Dade
County(3) 98,834,000 59,928,000 158,762,000
11
12
TOTAL $283 . 36, 000 $277, 306, 000 1560,442,
13
14
15
16
(1)
Special obligation debt is payable from revenue sources other than ad
17
valorem taxes and includes special obligation bonds and revenue bonds.
18
19
Amount shown does not include accretion of the portion of the City's
20
Special Revenue Refunding Bonds, Series 1987 issued as capital
21
appreciation bonds, which accretion amounted to approximately $4,674,000
22
as of September 30, 1990.
23
24
(3)
Excludes $80,873,000 Waterworks System Bonds which are outstanding and are
25
secured by revenues of the Miami Dade Water and Sewer Authority as well as
29
a pledge of the County to make payments from ad valorem taxes, if
necessar-�. As of September 30, 1990, Dade County's total General
i
Obligation Debt was $520,182,000, its total Special Obligation Debt was
29
$315,411,000, and its total Combined Debt was $835,593,000. The e0ity's
30
share of Dade County's debt based on assessed valuation is 19% of the
31
County total. The issuance of $980,000,000 of general obligation bonds by
32
the School Board of Dade County was approved by referendum on March 8,
33
1988. As of the date hereof, the Board has issued $200,000,000 of such
34
bonds. Such bonds are not included as part of the general obligation debt
35
of the County.
18604
-10-
91- 696
1
2
3
4
5
6
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
0
3
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
5
5
60
61
62
63
64
65
66
67
68
Debt statistics al %various Debt Ratios '
The following tables detail the City's debt statistics and significant
comparative ration of debt to population and to the city's tax base.
Debt Ratio of the Citp of Kiami
september 30, 1990
Factors:
Net Assessed Valuation (1)(2).................... $11,515,111,000
Net Taxable Assessel V# uation for
operating Purpose ( )( �........0................ $10,533,383,000
City of Miami Debt g (2)(5). ..........
Net General obligation $184,302,000
Net Special Obligation(2)(4)(�').........,S217.378t000
Combined Net Direct Debt (2)..................... $401,680,000
overlapping Debt
General Obligation 2 ................$98,834,000
Special Obligation................ S59,928.000
Combined Net overlapping Debt (2)................ S158.762.000
Total Combined Net Direct at5)................. S560.762.000
Net overlapping Debt
Population of Miami (8).......................... 383,000
Assessed Valuation Per Capita...... .................... $30,066
Net Taxable Assessed Valuation Per Capita $27,502
Debt Ratios:
Net Direct General Obligation Debt as a Percent of
Net Taxable Assessed Valuation............ 1.75e
Combined Net Direct and Overlapping General
Obligation Debt as Percent of Net Taxable
Assessed Valuation ......... ....... 2.68%
Net Direct General Obligation Debt Per Capita $ 481.20
Combined Net Direct General and special Obligation
Debt Per Capita ............ ....0.. ..... $1,048.77
Combined Net Direct and Overlapping General Obligation
Debt Per Capita... ....... ....... .... $ 739.26
Combined Net Direct and Overlapping General and Special
Obligation Debt Per Capita ................ $1,463.30
(1) Assessed valuation as of the final tax roll, using 100• of assessed values
as mandated by the laws of the State of Florida, excluding exempt
governmental properties.
(2) Amount rounded to nearest thousands.
(3) Net of homestead exemptions established by law. Homestead exemptions are
applicable to taxable property for owner -occupies housing and certain
persons who are aged, disabled or otherwise qualified therefor, as
required by the laws of the State of Florida.
(4) Net of reserve funds.
(5) Net of existing funds on hand.
(6) Special obligation debt which includes special obligation bonds as well as
revenue bonds, is payable from revenue sources other than ad valorem
taxes. Amount shown does not include accretion of the portion of the
City's Special Revenue Refunding Bonds, Series 1987, issued as capital
appreciation bonds, which accretions amounted to approximately $4,674,000
as of September 30, 1990.
(7) Based on the City's share of Dade County's real and personal property,
which is 19% of the County total.
(8) Based on the City's estimate. The 1990 U.S. Bureau of Census preliminary
population count of 358,458 is being challenged by the City and is
expected to be adjusted.
18604
-11-
(O�
91-- 696
1
2
3
14
to
7
8
9
10
11
12
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
3
3
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
Ratio of Net General obligation Bonded Debt
to Net Assessed Value and Not General obligation
Bonded Debt Per Capita
($ in thousands)
Net General
Assessed Nomstead Net Assessed Obligation
Fiscal Year Powtation Value Exemption XAM Bonded Debt Ratio Per Capita
1990
t383,000(4)
$11,515,111
$981,728
S10,533,383
$184,302
1.75%
"81.20
1989
371,4440)
11,210,985
969,335
10,241,650
1",$60
1.91
S27.29
19W
369,0070)
10,761,797
954,978
9,806,819
166,041
1.90
504.11
1987
368,210(l)
10,420,911
933,300
9,487,611
195,578
2.06
531.15
1986
371,9750)
10,194,933
953,516
9,231,417
190,697
2.07
512.66
1985
380,4460)
9,696,610
952,430
8,744,180
170,087
1.95
447.07
1984
383,0270)
9,346,033
954,979
8,391,054
146,102
1.74
381.74
1983
382,726(2)
8,659,281
920,895
7,738,386
124,955
1.61
326.49
1982
382,726(2)
7,962,129
750,665
7,2il,464
109,398
1.52
285.84
1981
399,995(3)
6,622,365
564,238
6,058,127
118,038
1.95
295.09
(1) Based on annual populating estimates provided by the State of Florida,.Division of
Population Studies, Bureau of Business and Economics Research, University of
Florida.
(2) Based on the July 1, 1982 populating estimate used by the Office of Revenue Sharing
of the Federal Government.
(3) The City was involved in litigation with the Federal Census Bureau challenging the
346,995 for Federal Revenue Sharing purposes. A result during 1981 the population
count was majusted upward to 399,995 for Federal Revenue Sharing purposes.
t4) Estimated by the City on the basis of added electric and water connections and new
dwelling units constructed. The 1990 U.S. Bureau of Census preliminary population
count of 358,458 is being challenged by the City and is expected to be adjusted.
General obligation Bonds Authorized But Not Issued
The following table outlines the date, type and amounts of general
obligation bonds authorized but unissued as of September 30, 1990.
Date of Previously
Vote Approval Tyne of Debt Authorized Issued
10/1/80 Sanitary Sewer $45,000,000 $22,500,000
3/13/84 Storm Sewer 30,000,000 20,000,000
S75.000.000 $42.500.000
18604 -12-
Balance Unissued
$22,500,000
10,000,000
$32,500,000
t0 3
A
696
�Y
=i
a L
W
1 Procedure For Tax Levy and Tax Collection
2
3 Real and personal property valuations are determined each year
as of January 1 by the Dade County Assessor of Property at 100% of
market value. A notice is mailed to each property owner indicating
b the property valuation. The property owner has the right to file
7 an appeal with the Dade County Clerk of the Board of Tax Adjustment
8 if such property valuation as determined by the property appraiser
9 is inconsistent with that as determined by the property owner. All
10 appeals of such valuation determinations are heard by the Dade
11 County Board of Equalization. The Board certifies the assessment
12 roll upon completion of the hearing of all appeals so filed.
13
14 All taxes are due and payable on November 1 of each year or as
15 soon thereafter as the assessment roll is certified and delivered
16 to the Dade County Tax Collector. The Dade County Tax Collector
17 mails to each taxpayer on the assessment roll a notice of the taxes
18 levied. Taxes may be paid upon receipt of such notice, with
19 discounts at the rate of four percent if paid in the month of
20 November, three percent if paid in the month of December, two
21 percent if paid in the month of January and one percent if paid in
22 the month of February. Taxes paid during the month of March are
23 without discount. Taxpayers also have the option of paying their
24 taxes in equal quarterly payments based on the prior years' tax
2" assessment with a six percent discount with the June 30th payment,
four percent discount with the September 30th payment, two percent
2't discount plus one-half of any adjustments required to bring tax
28 payments to current year's tax assessments, discounted at three
29 percent with the December 31 payment and no discount plus one-half
30 of any such adjustments with the March 31st payment. All unpaid
31 taxes on real and personal property become delinquent on April 1 of
32 the calendar year following the year in which the taxes were
33 levied. All tax collections for the City are delivered to the City
34 by Dade County. The delinquent real property taxes bear interest
35 at the rate of eighteen percent per year from April 1 until a tax
36 sale certificate is sold at auction from which time the interest
37 rate shall be as bid by the buyer of the certificate.
18604 -13 -
(�y
91 -- 696
I
Tax
Schedules and Tables
2
3
The following tables present detailed information
pertaining
to
the City's assessed property valuations, tax
levels and
collections and the City's ten largest tax assessments.
b
7
The assessed value of taxable property in the City
together
8
with real property value assessed, personal property assessed
9
values, and homestead exemptions in the current and
each of the
10
last ten completed fiscal years is detailed below.
11
12
Assessed value of All Tazable Property
13
Fiscal Year Ended September 30
14
(in thousands)
15
16
NET
17
FISCAL REAL PERSONAL HOMESTEAD
ASSESSED
18
YEAR
PROPERTY PROPERTY TOTAL EXEMPTIONS
VALUE
19
20
1990
$10,243,901 $1,271,210 $11,515,111 $981,728
$10,553,383
21
1989
9,997,519 1,213,466 11,210,985 969,335
10,241,650
22
1988
9,519,481 1,242,316 10,761,797 954,978
9,806,819
23
1987
9,210,476 1,210,435 10,420,911 933,300
9,487,611
24
1986
8,979,226 1,205,707 10,184,933 953,516
9,231,417
25
1985
8,538,398 1,158,212 9,696,933 952,430
8,744,180
26
1984
8.230,309 1,115,724 9,346,033 954,979
8,391,054
1983
7.616,829 1,042,452 8,659,281 920,895
7,738,386
1982
b,976,847 985,282 7,962,129 750,665
6,058,127
a.
1981
5,748,550 873,815 6,622,365 564,238
6,058,127
30
31
32
SOURCE: Metropolitan Dade County Property Appraiser's Office
33
34
35
The following table lists the ten largest tax assessments in
36
the
City of Miami.
37
38
Ten Largest Property Taz Assessments in the City
of Miami
39
1990 Assessed Values
40
41
42
Name of Taxpayer Name of Activity Assessed
Value (0001
43
44
1.
City National Bank Bank/Trustee
$253,837
45
2.
Southern Bell Telephone Utility
230,061
46
3.
Southeast Bank Bank/Office Building
202,832
47
4.
Equitable Life Assurance Real Estate Investments
179,025
48
5.
Florida Power & Light Co. Utility
144,025
49
6.
Brickell Associates Office Building
91,300
7.
Mayfair Hotel/Shopping Center
88,650
8.
C.P. Tower Office Building
75,000
9.
One Biscayne Tower Office Building
63,800
53
10.
Miami Center Joint Venture Developer
62,716
54
55
56 Source: Metropolitan Dade County Property Appraiser's Office
18604
-14-
��
91- 696
0
1
2
3
4
5
6
7
8
9
10
11
12
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
The City has levied certified millages of 11.9376 mills for fiscal year 1990-1991 beginning October 1,
1990, consisting of 9,5995 mills for general governmental and 2.3381 mills for debt service. The following
table shows the tax levies and collections of the City for each of the last ten completed fiscal years.
Tax Levies and Collections
Fiscal Years Ended September 30
(in thousands)
outstanding
Dolinquent
Collections
Collections
Taxes
Total
of Current
Percent
Collection
as Percent
Outstanding
As Percent
Fiscal
Tax
Year's
of levy
of Delinquent
Total Tax
of Current
Delinquent
of Current
Year
Le 1
Taxes
Collected
Taxes
Collections
Levy
Taxes(2)
LM
City Millaaeol
1990...
$125,743
t119,363
94.93%
$4,592
$123,955
98.58X
$5.162
4.11X
11.9376
1989...
122,260
114,535
93.68
3,710
118,245
96.72
5,742
4.70
11.9376
1988...
115,935
107,908
93.08
2.356
110,264
95.11
4.621
3.99
11.8219
1987...
116,612
111.740
95.82
1,606
113,346
97.20
2,8%
2.48
12.2910
1988...
109.938
105,457
95.92
944
113,346
96.83
3.318
3.01
11.9091
1987...
104,135
100,976
96.97
722(3)
101.698
97.66
3.970
3.61
11.9091
1986...
93,340
88,982
95.33
3,036
92,018
98.58
3,367
3.61
10.1238
1985...
83,025
75,815
94.93
1.209
80.024
96.38
2.925
3.52
10.7290
1984...
76.903
74,040
96.28
1,067
75,107
97.66
2,489
3.24
10.6640
1983...
72,619
70,288
96.79
437
70.725
97.39
2,027
2.79
11.9870
(1) Includes levies for general operations and debt service.
(2) Net of reserve for early payment discowits and uncollectabte tax of approximately 5% of total tax levy.
(3) Starting in fiscal year 1985. current year's delinquent tax collections are included with collection of current year's taxes. For years prior
to 1985, collection of delinquent taxes included both current year and prior year's delinquent tax cottections.
18604
-15-
E
AN
1
2 TAX MATTUR
3
In the opinion of Co -Bond Counsel, under existing law, the
Notes are exempt from present Florida intangible personal property
L taxes. Also, in the opinion of Co -Bond Counsel under existing law,
7 facts and circumstances, interest on the Notes is excluded from
8 gross income for federal income tax purposes. The opinion of Co-
g Bond Counsel is conditioned upon compliance by the City with
10 covenants contained in the Resolution to comply with certain
11 arbitrage rebate and other tax requirements contained in the
12 Internal Revenue Code of 1986, as amended (the "Code"), to the
13 extent necessary to preserve the exclusion of interest on the Notes
14 from gross income for federal income tax purposes. If the City
15 fails to comply with such covenants, interest on the Notes could
16 become includable in the gross income of the owners thereof for
17 federal income tax purposes retroactive to the date of issuance.
18
19
20 9191seeunt Netes") have haws" go
21 disesont from their value at maturity. The eviginal issue disee-ant
22 is the -e -e€- the -stated redemption prise at maturity of soeh
23
he p
24 emeludinej underwriters and ether intermediaries, at Whieh priee
2 substantial ameunt of sus i $isesunt Notes were —said-. Under
21 diseeuntT-depend-ing inparton the peried--a-B=Qeounfe Nete is held
d
28 by the purehaser thereof, will be treated fee federal ineeme t-a*
29 purposes as interest --which- is exeludable=from grass ineeme-rather
30 than as tamable gains Under Seetion !288 ef
" -ble-gains—Hnder-6eetien288--ef the -cede evigal
31 eleeeunt en: —tam —exempt -notes aeerues—on a eempeundbasis.
32
33 a 919sount Nete doping any aeorual period generally equals (I the
34
36 the ykeld te maturity ef- sireh 91seeentete—(ie-mined en he
37
38 properly adjusted fee the length of the aserua! peried) , less (3)
39
40 a eds The amount f evigina! iesue--diseount rip-a--par-je%;:ar
r
41
42
43 emehange, redemption or payment e= a-91se eent Note in emeese of the
44 `�
45 disseunt whleh has aeerued and Is treated as feam exempt
4' i ntOwest in his hands) ' ; will tee- treated -ate--g fees the ,
� —saavr
emehange of su *1 andnotas interest. The feral
4b tam eensequenees of the-pureharse, ownership and redemption,
49
50 in the Initial offering at the initial efferinej prieL- may j9,e
51 determined aeserding to rules whieh differ from these deseribed
18604
-16-
L ?
94._ 696
1
291seelant Metes,
ownership
1= ddin,g _ th.�_wC_L'.'we w�.'-.♦a ...1� _ Pander
��...1 ieab a state
and
3 Y� 7 -as ra rr
An alternative minimal tax is imposed by the Code on
7 corporations and taxpayers other than corporations. Interest on
8 the Notes will not be treated as an item of tax preference for
9 purposes of the alternative minimum tax. Interest on the Notes
10 will therefore not be included in u.'non-corporate Nth' holder Ia
11 alternative minimum taxable income: The alternative minimum tax on
12 corporations is imposed at a 20$ rate. Interest on the Notes
13 received by a corporate Noteholder will be included in such
14 Noteholder's adjusted current earnings. A corporation's
15 alternative minimum taxable income will be increased by 75% of the
16 corporation's adjusted current earnings not otherwise included in
17 its alternative minimum taxable income.
18
19 Reference is made to a proposed form of the Co -Bond Counsel
20 opinion attached hereto as Appendix D for the complete text
21 thereof. Co -Bond Counsel have expressed no opinion regarding other
22 federal income tax consequences which may arise with respect to the
23 Notes. For a description of some.of the other potential income tax
24 consequences•• with respect to the Notes, see the following
2r' paragraphs.
2, 1. Environmental Sygerfund Tax. Section 59A of the Code
28 imposes for taxable years beginning before January 1, 1996, an
29 additional tax on corporations at a rate of .12 percent on the
30 excess over $2,000,000 of a corporation's "modified alternative
31 minimum taxable income". Interest on the Notes received by a
32 corporate Noteholder will be included in the determination of such
33 Noteholder's "modified alternative minimum taxable income".
34
35 2. Financial Institutions and Property and Casualty
36 Insurance Companies. Section 265 of the Code provides that a
37 financial institution holding Notes will be denied any deduction
38 for its interest expense allocable to such Notes. Under Section
39 832 (b) (5) (B) of the Code, property and casualty insurance companies
40 will be required to reduce the amount of their deductible
41 underwriting losses by 15% of the amount of tax-exempt interest
42 received from installments made after August 7, 1986, including
43 investments in the Notes.
44
45 3. Social Security and Railroad Retirement Benefits. Under
4r Section 86 of the Code, recipients of certain social security
4 benefits and railroad retirement benefits may be required to
4o include a portion of such benefits within gross income by reason of
49 receipt of interest on the Notes.
50
18604
-17-
91-- 696
.O%N
1
2
3
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
2
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
4
4
48
49
4. S Corporations. Section 1375 of the etode imposes a tax
on the income of an S corporation having Subchapter C earnings and
profits at the close of a taxable year, if greater than 25% of the
gross receipts of such S corporation is passive investment income.
Interest on the Notes will be included in an S corporation's
passive investment income.
5. Eoreign Corporation -Branch Offices Tax. Section 884 of
the Code imposes a branch profits tax on foreign corporations equal
to 30% of the "dividend equivalent amount" for the taxable year.
Interest on the Notes would be taken into account in determining a
foreign corporate Noteholder's "dividend equivalent amount" to the
extent such interest is effectively connected (or treated as
effectively connected) with the foreign corporate Noteholder's
conduct of atrade or business within the United States.
These and other provisions of the Code may give rise to
adverse federal income tax consequences to particular Noteholders.
Owners of the Notes should consult their own tax advisors with
respect to the tax consequences to them of owning Notes.
LITIGATION
There is not now pending any litigation restraining or
enjoining the issuance or delivery of the Notes or the levy or
collection of ad valorem taxes to pay the principal of or the
interest on the Notes, or questioning the proceedings or
authorization under which the Notes are to be issued, or affecting
the validity of the Notes.
RATINGS
The Notes have received ratings of from Moody's
Investors Service, Inc., and from Standard & Poor's
Corporation. Generally, rating agencies base their ratings on the
information and materials so furnished and on investigations,
studies and assumptions by the rating agencies. Such ratings
reflect only the views of such rating agencies, and an explanation
of the significance of such ratings may be obtained from the rating
agencies. There is no assurance that the ratings will continue for
any given period of time or that they will not be revised or
withdrawn entirely by the rating agencies, if in their judgment
circumstances so warrant. A revision or withdrawal of any such
rating may have a adverse effect on the market price of the Notes.
18604 -is-
91- 696
1
2
3
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
2°
2
2 "1
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
4F
48
49
50
51
52
53
54
UNDnWRITING
The Underwriters, PaineWebber Incorporated, Grigsby Brandford
Powell, Inc., AIBC Investment Services Corp. and Guzman & Company,
have agreed under certain conditions to purchase the Notes from the
City at a price of $ . The Notes may be offered and
sold to certain dealers, banks, and others at prices lower than the
initial offering prices, and such initial public offering prices
may be changed from time to time by the Underwriters.
FINANCIAL ADVISORS
The City has retained Howard Gary & Company, Miami, Florida,
and Raymond James & Associates, Inc., St. Petersburg, Florida, as
Financial Advisors (the "Financial Advisors") in connection with
the preparation of the CityyIs plan of financing and with respect to
the authorization and issuance of the Notes. The Financial
Advisors are not obligated to undertake and have not undertaken to
make, an independent verification or to assume responsibility for
the accuracy, completeness, or fairness of the information
contained in the Official Statement. Howard Gary & Company and
Raymond James & Associates, Inc., are full service investment
banking firms which provide financial advisory and underwriting
services to .governmental entities throughout the nation.
FINANCIAL STATEXENTS
The general purpose financial statements of the City appearing
as Appendix B to this Official Statement have been examined by
Deloitte & Touche, independent certified public accountants, for
the fiscal year ended September 30, 1990, as stated in their report
to the Honorable Mayor and City Commissioners dated March 25, 1991,
and are an integral part of this Official Statement. See Appendix
B, "General Purpose Financial Statements".
LEGALITY
Certain legal matters incident to the validity of the Notes,
including their authorization, issuance and sale by the City are
subject to the approval of Kubicki, Draper, Gallagher & McGrane,
P.A., Miami, Florida, and Holland & Knight, Miami, Florida, Co -Bond
Counsel. Certain legal matters will be passed upon for the City by
A. Quint the Acting City Attorney, and for the
Underwriters by Lewis, White & Clay, A Professional Corporation,
Detroit, Michigan, and Armando J. Bucelo, Jr., Miami, Florida.
Holland & Knight and Kubicki, Draper, Gallagher & McGrane,
P.A., Co -Bond Counsel, have not undertaken independently to verify
and therefore express no opinion as to the accuracy, completeness,
fairness or sufficiency of the information or statements contained
herein or in the appendices attached hereto except as to the
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91-M 696
S
1 accuracy of the portions hereof captioned "Description of the
2 Notes" (other than the portion thereof captioned "Book -Entry Only
3 System") and "Security for the Notes" to the extent such portionis
purport to summarize certain provisions of the Resolution and
except as to the accuracy of the information under the caption "Tax
Matters".
7
8 DISCLOSURES REQUIRED BY FLORIDA BLUE SKY REGULATIONS
9
10 Rule 3E-400.0030 Florida Administrative Code,requires the City
11 to disclose each and every default as to payment of principal and
12 interest after December 31, 1975 with respect to obligations issued
13 or guaranteed by the City. Rule 3E-400.003 further provides,
14 however, that if the City in good faith believes that such
15 disclosure would not be considered material by reasonable
16 investors, such disclosure may be omitted. Certain obligations
17 issued by the City in which the City has acted merely as a conduit
18 for payment do not constitute an actual debt, liability or
19 obligation of the City, but are instead secured by payments to be
20 made from certain users of bond -financed property. Because such
21 other obligations are not dependent upon the City for repayment,
22 they do not affect or reflect the financial strength of the City.
23 Accordingly, any prior default with respect to such obligations
24 issued by the City would not in the City's judgment be considered
2material by .seasonable investors in the Notes. Accordingly, the
City has not taken affirmative steps to contact the various
2*1 trustees of conduit bond issues of the City to determine the
28 existence of prior defaults.
29
30 Notwithstanding the foregoing, to the best knowledge of the
31 Director of Finance of the City, the City has not received actual
32 notice of any default in the payment of principal or interest after
33 December 31, 1975 on any obligation issued or guaranteed by the
34 City. Nevertheless, given the number of bond issues of the City
35 and the turnover in administrative personnel since December 31,
36 1975, there is no assurance that obligations issued by the City
37 have never been in default with respect to the payment of principal
38 and/or interest.
39
40 CERTAIN CLOSING CERTIFICATES
41
42 Concurrently with the delivery of the Notes, the City Manager
43 and the Director of Finance will furnish their certificate to the
44 effect that, to the best of their knowledge, this Official
45 Statement, as of its date and as of the date of the delivery of the
4r Notes, did not and does not contain any untrue statement of a
4 material fact or omit to state a material fact necessary to make
46 the statements contained herein, in the light of the circumstances
49 under which they were made, not misleading.
50
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I In addition, at the time of delivery of the Notes to the
2 Underwriters, the City will provide to the Underwriters a
3 certificate (which may be included in a consolidated closing
certificate of the City described in this section immediately
above), signed by the City official who signed the Official
o Statement, relating to the accuracy and completeness of t:is
7 Official Statement and to it being deemed a "final official
8 statement" in the judgment of the City for the'purposes of Rule
9 15C2-12 of the Securities and Exchange Commission.
MISCELLANEOUS
The references, excerpts and summaries of all documents
referred to herein do not purport to be complete statements of the
provisions of such documents and reference is directed to all such
documents for full and complete statements of all matters of fact
relating to the Notes, the security for the payment of the Notes
and the rights and obligations of the holders thereof. The City
has prepared a projected cash flow statement, including a statement
of assumptions used therein, for a period equal to the term of the
Notes and histerleal eash f=ew--ezateeents fer the previous twe
years. Copies of such eash fiew statements _ the ethet documents
referenced above may be obtained from the City's Director of
Finance at 3306 Aviation Avenue, Miami, Florida 33133, telephone
number (305) 579-6350, or from its Financial Advisors, Howard Gary
& Company, 3050 Biscayne Boulevard, Suite 603, Miami, Florida
33137-4163, telephone number (305) 571-1380, and Raymond James &
Associates, Inc., 880 Carillon Parkway, St. Petersburg, Florida
33716, telephone number (813) 573-8189.
The information contained in this Official Statement has been
compiled from official and other sources deemed to be reliable,
and is believed to be correct as of this date, but is not
guaranteed as to accuracy or completeness by, and is not to be
construed as a representation by, the Underwriters or the Financial
Advisors.
Any statement made in this Official Statement involving
matters of opinion or of estimates, whether or not so expressly
stated, are set forth as such and not as representations of fact,
and no representation is made that any of the estimates will be
realized. The information and expressions of opinion herein are
subject to change without notice and neither the delivery of this
Official Statement nor any sale made hereunder shall, under any
circumstances, create any implication that there has been no change
in the affairs,of the City since the date hereof.
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I The execution and delivery of this Official Statement has been
2 duly authorized by the Commission of the City of Miami.
3
THE CITY OF MIAMI, FLORIDA
7
9 By•
10 THE HONORABLE XAVIER L. SUAREZ, MAYOR
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?3
AP?ZUDIZ A - DSBCRIPTION of THE CITY OF KIANI
4
5
6
a
1 APPENDIZ A
2
3 DEBCRIPTION OP T$E CITY OP MIAMtI
o Geography
7
8 The City, situated at the mouth of the Miami River on the
9 western shore of Biscayne Bay, is a main port of entry in Florida
10 and the county seat of Metropolitan Dade County (the "County")
11 which encompasses over 2,000 square miles of Florida's southeastern
12 region. The City comprises 34.3 square miles of land and 19.5
13 square miles of water.
14
15 Miami is the southern -most major city and seaport in the
16 continental United States and the center of Pan-American trade and
17 air transportation. The nearest foreign territory is the Bahamian
18 island of Bimini, situated approximately fifty miles off the coast
19 of Florida. The County is often referred to herein as Greater
20 Miami.
21
22
23 Climate
24
Due to its location near the upper boundary of the tropical
zone, Miami•s climate is strongly influenced by the Gulf Stream,
27 trade winds and other local climatic factors. Its average yearly
28 temperature is 75.5. degrees Fahrenheit. Summer temperatures
29 average 81.4 degrees Fahrenheit and winter temperatures average
30 69.1 degrees Fahrenheit. Rainfall comes most frequently between
31 the months of May and September, with June the heaviest, averaging
32 nine inches.
33
34
35 Population
36
37 The U.S. Bureau of Census estimated the population of the City
38 at 358,458 as of April 1, 1990. The estimate is being challenged
39 by the City. The City estimates that its population as of April
40 11, 1990 was 383,000. According to estimates of the City, the
41 population is expected to increase to 400,000 by the year 2000.
42
43
44 Government of the city
45
The City has operated under the Commission -City Manager form
of government. since 1921. The Commission consists of five elected
48 citizens, who are qualified voters in the City, one of whom serves
49 as Mayor. The Commission acts as the governing body of the City
50 with powers to enact ordinances, adopt resolutions and appoint a
51 chief administrative officer known as the City Manager. The City
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..�
CITY OF MIAMI, .FLORIDA llp� 7
INTER -OFFICE MEMORANDUM
TO Honorable Mayor and Members DATE 181991
FILE
SEPof City Commission `J
SUBJECT
Agenda Item
FROM Cesar H. OREFERENCES:
d
City Manager ENCLOSURES
It is respectfully recommended that the City Commission adopt a.
resolution authorizing the issuance of an amount not to exceed
$25,000,000 in aggregate principal amount of the City of Miami,
Florida, Tax Anticipation Notes, Series 1991 for the purpose of
meeting certain of the City's cash flow requirements for the
fiscal year ending September 30, 1992; approving the form of the
Notes; providing for the rights and security of all Note Holders
pursuant to this resolution; appointing a paying agent for the
Notes; authorizing the City Manager or Assistant City Manager to
take any action necessary to qualify the Notes for deposit with
the Depository Trust Company; authorizing the negotiated sale o;
the Notes; approving the form, execution and delivery of a Note
Purchase Agreement to effect the negotiated sale of the Notes;
approving the form and distribution of a Preliminary Official
Statement; approving the form and execution of an Official
Statement; authorizing the City Manager or Assistant City Manager
on behalf of the City to determine the final details of the Notes
within the parameters established by this resolution; authorizing
the Mayor or Vice Mayor, City Manager or Assistant City Manager ,
and the City Attorney as to the form to execute the Note Purchase
Agreement consistent with such final details; authorizing other
officers of the City to take all other actions necessary in
connection with the issuance of the Notes; and providing for an
effective date.
The City will begin collection of property taxes for fiscal year
92 at the end of November 91. A cash flow gap approximating $25
million is expected to occur in October and November, of whicl
approximately $15 million are attributable to normal operating
expenditures. An additional amount of up to $10 million may be
issued to cover the one-time costs attributable to the recently
approved program to induce retirement and related payment of
accumulated vacation, and other leave balances.'
17->
91.- 696
Agenda Item
Page -2-
These Tax Anticipation Notes will be paid with fiscal year 1992
general fund property taxes. The proposed budget estimates these
taxes at $101,134,459, net of a five percent (5%) reserve for
early payment discounts and uncollectables. Although these
budgeted revenues are based on the preliminary taxroll, the vast
majority of these taxes are expected to be collected. For
instance, the general fund tax levy for fiscal year 90-91 was
$98,442,454 of which approximately $2.4 million are expected to
remain uncollected by the closing of the fiscal year 91 records.
The Department of Finance hereby recommends
Anticipation Notes in October, 1991 in an
$25 million to bridge the cash flow gap
fiscal year 1991-92.
the issuance of Tax
amount not to exceed
at the beginning of
2
9 1 _..