Resolution 2014-093 RESOLUTION NO. 9 3
A RESOLUTION OF THE BOARD OF COUNTY
COMMISSIONERS OF COLLIER COUNTY, FLORIDA
SUPPLEMENTING RESOLUTION NO. 2003-89 WHICH,
AMONG OTHER THINGS, AUTHORIZES THE
ISSUANCE OF GAS TAX REVENUE BONDS FROM
TIME TO TIME; AUTHORIZING THE REFUNDING OF A
PORTION OF THE COUNTY'S OUTSTANDING GAS
TAX REVENUE BONDS, SERIES 2005; AUTHORIZING
THE ISSUANCE OF A NOT EXCEEDING $90,000,000
PRINCIPAL AMOUNT OF COLLIER COUNTY,
FLORIDA GAS TAX REFUNDING REVENUE BOND,
SERIES 2014 IN ORDER TO EFFECT SUCH
REFUNDING; AUTHORIZING A NEGOTIATED SALE
OF SAID BOND PURSUANT TO THE PROPOSAL OF STI
INSTITUTIONAL & GOVERNMENT, INC.;
DELEGATING CERTAIN AUTHORITY TO THE
CHAIRMAN IN CONNECTION WITH THE APPROVAL
OF THE TERMS AND DETAILS OF SAID BOND;
APPOINTING THE CLERK AS PAYING AGENT AND
REGISTRAR FOR SAID BOND; AUTHORIZING THE
EXECUTION AND DELIVERY OF AN ESCROW
DEPOSIT AGREEMENT AND APPOINTMENT OF AN
ESCROW AGENT THERETO; AND PROVIDING AN
EFFECTIVE DATE.
BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF
COLLIER COUNTY, FLORIDA:
SECTION 1. FINDINGS. It is hereby found and determined that:
(A) On February 25, 2003, the Board of County Commissioners (the "Board")
of Collier County, Florida (the "Issuer") duly adopted Resolution No. 2003-89, as
amended and supplemented (as supplemented hereby, the "Resolution"), authorizing,
among other things, the issuance of the Collier County, Florida Gas Tax Revenue Bonds,
Series 2003 (the "Series 2003 Bonds"), which Series 2003 Bonds were issued for the
principal purpose of financing a portion of the costs of certain transportation-related
capital improvements and to current refund the Issuer's Collier County, Florida Road
Improvement Refunding Revenue Bonds, Series 1995.
(B) On June 29, 2005, the Issuer issued its Collier County, Florida Gas Tax
Revenue Bonds, Series 2005 (the "Series 2005 Bonds") pursuant to the Resolution for the
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principal purpose of financing a portion of the costs of certain transportation-related
capital improvements.
(C) On June 5, 2012, the Issuer issued its Collier County, Florida Gas Tax
Refunding Revenue Bonds, Series 2012 (the "Series 2012 Bonds"), which Series 2012
Bonds refunded a portion of the then outstanding Series 2003 Bonds.
(D) The Resolution provides for the issuance of Additional Bonds upon
meeting the requirements set forth herein and in the Resolution.
(E) The Issuer deems it to be in its best interest to refund a portion of the
outstanding Series 2005 Bonds (the "Refunded Bonds"), the specific maturities and
portions thereof to be refunded to be determined by the Chairman upon the advice of the
Issuer's financial advisor, Public Financial Management, Inc. (the "Financial Advisor"),
in order to achieve debt service savings.
(F) In order to refund the Refunded Bonds, the Issuer hereby determines to
issue its Collier County, Florida Gas Tax Refunding Revenue Bond, Series 2014 (the
"Series 2014 Bond") pursuant to the Resolution, which Series 2014 Bond shall be issued
on parity with any portion of the Series 2005 Bonds that are not refunded in connection
with the issuance of the Series 2014 Bond (the "Unrefunded Series 2005 Bonds" and,
together with the outstanding Series 2012 Bonds, the "Outstanding Parity Obligations"),
except as otherwise provided herein or in the Resolution, in accordance with the terms of
the Resolution.
(G) For the refunding of the Refunded Bonds, the Issuer shall, as provided
herein, deposit part of the proceeds derived from the sale of the Series 2014 Bond,
together with other legally available moneys of the Issuer, in a special escrow deposit
trust fund (the "Escrow Fund"), which shall be sufficient to pay the Refunded Bonds as
the same mature or are redeemed prior to maturity, all as provided herein and in the
hereinafter described Escrow Deposit Agreement. Subsequent to the defeasance of the
Refunded Bonds, the Refunded Bonds shall no longer be payable from or be secured by
any portion of the Pledged Funds (as defined in the Resolution).
(H) On April 22, 2014, the Board accepted the proposal of STI Institutional &
Government, Inc. (including any successors thereof, the "Purchaser") for the purchase of
the Series 2014 Bond (the "Proposal").
(I) Due to the potential volatility of the market for tax-exempt obligations such
as the Series 2014 Bond and the complexity of the transactions relating to such Series
2014 Bond, it is in the best interest of the Issuer to sell the Series 2014 Bond by a
negotiated sale to the Purchaser pursuant to the Proposal and the provisions hereof and of
the Resolution, rather than at a specified advertised date, thereby permitting the Issuer to
obtain the best possible price, terms and interest rate for the Series 2014 Bond.
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(J) The Issuer hereby certifies that it is current in all deposits into the various
funds and accounts established by the Resolution and all payments theretofore required to
have been deposited or made by the Issuer under the provisions of the Resolution have
been deposited or made and the Issuer has complied with the covenants and agreements
of the Resolution and is not currently in default under the Resolution.
(K) The Resolution provides that the Series 2014 Bond shall mature on such
dates and in such amounts, shall bear such rates of interest, shall be payable in such
places and shall be subject to such redemption provisions as shall be determined by
Supplemental Resolution adopted by the Issuer; and it is now appropriate that the Issuer
determine certain of such provisions, terms and details and establish the mechanisms for
determining the remaining provisions, terms and details.
(L) The Series 2014 Bond shall not constitute a general obligation or pledge of
the faith, credit or taxing power of the Issuer, the State of Florida, or any political
subdivision thereof, or indebtedness as a "bond," within the meaning of any constitutional
or statutory provision, but shall be a special obligation of the Issuer, payable solely from
and secured by a lien upon and a pledge of the Pledged Funds in accordance with the
terms of the Resolution. Neither the Issuer, the State of Florida, nor any political
subdivision thereof shall be obligated (i) to exercise its ad valorem taxing power in any
form on any real or personal property of or in the Issuer to pay the principal of the Series
2014 Bond, the interest thereon, or other costs incidental thereto, or (ii) to pay the same
from any other funds of the Issuer except from the Pledged Funds, in the manner
provided in the Resolution.
(M) The covenants, pledges and conditions in the Resolution shall be applicable
to the Series 2014 Bond herein authorized and said Series 2014 Bond shall be on a parity
with and rank equally as to the lien on and source and security for payment from the
Pledged Funds and in all other respects with the Outstanding Parity Obligations and any
Additional Bonds (as defined in the Resolution) hereafter issued, except that any Bond
(as defined in the Resolution) may be separately secured by a subaccount within the
Reserve Account (as defined in the Resolution), and shall constitute a "Bond" within the
meaning of the Resolution.
SECTION 2. DEFINITIONS. When used in this Supplemental
Resolution, the terms defined in the Resolution shall have the meanings therein stated,
except as such definitions shall be hereinafter amended and defined.
SECTION 3. AUTHORITY FOR THIS SUPPLEMENTAL
RESOLUTION. This Supplemental Resolution is adopted pursuant to the provisions of
the Act.
SECTION 4. AUTHORIZATION OF THE ADVANCE REFUNDING
OF THE REFUNDED BONDS. The Issuer hereby authorizes the advance refunding of
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the Refunded Bonds for the purpose of achieving debt service savings. The Chairman,
upon the advice of the Financial Advisor, shall determine which maturities and portions
of the Series 2005 Bonds shall be refunded.
SECTION 5. AUTHORIZATION AND DESCRIPTION OF THE
SERIES 2014 BOND. The Issuer hereby authorizes the issuance of a Series of Bonds in
the principal amount of not exceeding $90,000,000 to be known as the "Collier County,
Florida Gas Tax Refunding Revenue Bond, Series 2014" (or such other designation as the
Chairman may determine), for the principal purpose of refunding, on an advance basis,
the Refunded Bonds. The principal amount of the Series 2014 Bond to be issued
pursuant to the Resolution shall be determined by the Chairman, upon the advice of the
Issuer's Financial Advisor, provided such principal amount does not exceed the amount
provided above. The Series 2014 Bond shall be on parity in all respects and shall rank
equally as to lien on and source and security for payment from the Pledged Funds with
the Outstanding Parity Obligations and any Additional Bonds hereafter issued, except
that any Bond may be separately secured by a subaccount within the Reserve Account.
The Series 2014 Bond shall be dated as of its date of issuance, or such other date
as the Chairman may determine, shall be issued in the form of one fully registered Bond
in the denomination of its outstanding principal amount and shall be numbered "R-1."
The Series 2014 Bond shall bear interest from its dated date at a fixed interest rate of
2.33% per annum (the "Interest Rate"). The Interest Rate shall be calculated on the basis
of a 360-day year consisting of twelve 30-day months. The Interest Rate is subject to
adjustment in accordance with Sections 11 and 12 hereof Interest on the Series 2014
Bond shall be payable semi-annually, on December 1 and June 1 of each year (the
"Interest Payment Dates"), commencing on December 1, 2014. The Series 2014 Bond
shall be issued as a single Term Bond with a final maturity of June 1, 2025 and shall be
subject to mandatory sinking fund redemption in such Amortization Installments
commencing on June 1, 2015 and on each June 1 thereafter through the maturity date of
the Series 2014 Bond, determined by the Chairman, upon the advice of the Issuer's
Financial Advisor, and approved by the Purchaser prior to the issuance of the Series 2014
Bond. Such Amortization Installments shall be set forth in the Series 2014 Bond. The
Series 2014 Bond shall be sold on a negotiated basis to the Purchaser at a purchase price
equal to 100% of the aggregate principal amount thereof. The Purchaser shall provide
the Issuer with an executed Disclosure Letter and Truth-in-Bonding Statement as
required by Section 218.385, Florida Statutes, prior to the issuance of the Series 2014
Bond. The Interest Rate on the Series 2014 Bond shall comply in all respects with
Section 215.84, Florida Statutes. For purposes of the Resolution, "Bond Year" shall
mean the period commencing on June 2 of each year and continuing through the next
succeeding June 1.
The Series 2014 Bond shall be payable as to principal and interest by ACH direct
debit or bank wire transfer or in such other manner as is agreed to between the Issuer and
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the holder of the Series 2014 Bond in whose name the Series 2014 Bond shall be
registered on the registration books maintained by the Issuer as of the close of business
on the fifteenth day (whether or not a business day) of the calendar month next preceding
an Interest Payment Date; provided, that the registered owner of the Series 2014 Bond
shall only be required to present and surrender the Series 2014 Bond to the Issuer for the
final payment of the principal of the Series 2014 Bond or shall otherwise provide
evidence that such Series 2014 Bond has been cancelled. Principal of and interest on the
Series 2014 Bond shall be payable in any coin or currency of the United States of
America, which at the time of payment, are legal tender for the payment of public and
private debts.
SECTION 6. REDEMPTION PROVISIONS FOR SERIES 2014
BOND. The Series 2014 Bond may be redeemed in whole, or in part, on any Business
Day with two (2) Business Days' prior written notice to the Purchaser by payment of an
amount equal to the principal amount to be redeemed plus accrued interest thereon to the
date of redemption plus the Redemption Premium, as defined below.
For purposes of the foregoing, the term "Redemption Premium" shall mean the
present value of the difference between (i) the amount that would have been realized by
the Purchaser on the redeemed amount for the remaining term of the Series 2014 Bond at
the Federal Reserve H.15 Statistical Release rate for fixed-rate payers in interest rate
swaps for a term corresponding to the term of the Series 2014 Bond, interpolated to the
nearest month, if necessary, that was in effect three Business Days prior to the issuance
date of the Series 2014 Bond, and (ii) the amount that would be realized by the Purchaser
by reinvesting such redeemed funds for the remaining term of the Series 2014 Bond at
the Federal Reserve H.15 Statistical Release rate for fixed-rate payers in interest rate
swaps, interpolated to the nearest month, that was in effect three Business Days prior to
the redemption date; both discounted at the same interest rate utilized in determining the
applicable amount in (ii). Should such present value have no value or a negative value,
the Issuer may redeem the Series 2014 Bond with no additional fee or Redemption
Premium. Should the Federal Reserve no longer release rates for fixed-rate payers in
interest rate swaps, the Purchaser may substitute the Federal Reserve H.15 Statistical
Release with another similar index. The Purchaser shall provide the Issuer with a written
statement explaining the calculation of the premium due, which statement shall, in
absence of manifest error, be conclusive and binding. The application of such
Redemption Premium is not intended to, and shall not be deemed to be, an increase in the
Interest Rate on the Series 2014 Bond.
Principal redemptions shall be applied to the Series 2014 Bond in inverse order of
the remaining Amortization Installments.
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SECTION 7. APPLICATION OF SERIES 2014 BOND PROCEEDS.
The proceeds derived from the sale of the Series 2014 Bond shall be applied by the Issuer
simultaneously with the delivery thereof as follows:
(A) A sufficient amount of Series 2014 Bond proceeds, together with other
legally available moneys of the Issuer, shall be deposited irrevocably in trust in the
Escrow Fund established under the terms and provisions of the hereinafter defined
Escrow Deposit Agreement to pay the principal of, Redemption Price, if applicable, and
interest on the Refunded Bonds as the same mature and become due and payable or are
redeemed prior to maturity.
(B) A sufficient amount of the Series 2014 Bond proceeds shall be applied to
the payment of costs and expenses relating to the issuance of the Series 2014 Bond.
SECTION 8. TRANSFER OF CERTAIN MONEYS. The Refunded
Bonds will be refunded from proceeds of the Series 2014 Bond and from other legally
available funds of the Issuer. Any excess moneys on deposit in the Debt Service Fund
established for the benefit of the Refunded Bonds pursuant to the Resolution and not
required to remain on deposit therein shall be transferred to the Escrow Fund established
pursuant to the Escrow Deposit Agreement.
SECTION 9. APPOINTMENT OF PAYING AGENT AND
REGISTRAR. The Clerk is hereby designated Registrar and Paying Agent for the
Series 2014 Bond.
SECTION 10. AUTHORIZATION TO EXECUTE ESCROW DEPOSIT
AGREEMENT. The Issuer hereby authorizes and directs the Chairman to execute and
the Clerk to attest an escrow deposit agreement (the "Escrow Deposit Agreement") and to
deliver the Escrow Deposit Agreement to The Bank of New York Mellon Trust
Company, Jacksonville, Florida, which is hereby appointed as Escrow Agent. The
Escrow Deposit Agreement shall be in substantially the form of the Escrow Deposit
Agreement attached hereto as Exhibit A with such changes, amendments, modifications,
omissions and additions, including the date of such Escrow Deposit Agreement, as may
be approved by said Chairman. Execution by the Chairman of the Escrow Deposit
Agreement shall be deemed to be conclusive evidence of approval of such changes.
SECTION 11. ADJUSTMENT TO INTEREST RATE. (A) Upon the
occurrence of a Determination of Taxability (as defined below) and for as long as the
Series 2014 Bond remains Outstanding, the Interest Rate on the Series 2014 Bond shall
be converted to the Taxable Rate (as defined below) and this adjustment shall survive
payment on the Series 2014 Bond until such time as the federal statute of limitations
under which the interest on the Series 2014 Bond could be declared taxable under the
Code shall have expired. In addition, upon a Determination of Taxability, the Issuer
shall, immediately upon demand, pay to the Purchaser (i) an additional amount equal to
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the difference between (a) the amount of interest actually paid on the Series 2014 Bond
during the Taxable Period (as defined below) and (b) the amount of interest that would
have been paid during the Taxable Period had the Series 2014 Bond borne interest at the
Taxable Rate, and (ii) an amount equal to any interest, penalties on overdue interest and
additions to tax (as referred to in Subchapter A of Chapter 68 of the Code) owed by the
Purchaser as a result of the Determination of Taxability.
(B) If the Maximum Federal Corporate Tax Rate (as defined below) as
applicable to the Purchaser decreases from 35%, the Purchaser shall have the option to
increase the Interest Rate otherwise borne by the Series 2014 Bond to a rate equal to the
product obtained by multiplying the Interest Rate otherwise borne by the Series 2014
Bond by a fraction, the numerator of which is equal to one (1) minus the Maximum
Federal Corporate Tax Rate on the date of calculation and the denominator of which is
0.65; provided, however, the Interest Rate for the Series 2014 Bond shall never be
adjusted to a rate greater than 2.69% per annum as a result of a change in the Maximum
Federal Corporate Tax Rate; provided, however, the Interest Rate may increase multiple
times as a result of multiple decreases in the Maximum Federal Corporate Tax Rate as of
the effective date of each such decrease in the Maximum Federal Corporate Tax Rate.
(C) For purposes of this Section 11, the following terms shall have the
definitions ascribed thereto:
"Determination of Taxability" means a final decree or judgment of any Federal
court or a final action of the Internal Revenue Service determining that interest paid or
payable on all or a portion of the Series 2014 Bond is or was includable in the gross
income of the Purchaser for Federal income tax purposes; provided, that no such decree,
judgment, or action will be considered final for this purpose, however, unless the Issuer
has been given written notice and, if it is so desired and is legally allowed, has been
afforded the opportunity to contest the same, either directly or in the name of the
Purchaser, and until the conclusion of any appellate review, if sought. A Determination
of Taxability shall not include and is not triggered by a change in law by Congress that
causes the interest to be includable in the Purchaser's gross income.
"Taxable Period" shall mean the period of time between (i) the date that interest on
the Series 2014 Bond is deemed to be includable in the gross income of the Purchaser for
federal income tax purposes as a result of a Determination of Taxability, and (ii) the date
of the Determination of Taxability and after which the Series 2014 Bond bears interest at
the Taxable Rate.
"Taxable Rate" shall mean the interest rate per annum that shall provide the
Purchaser with the same after tax yield that the Purchaser would have otherwise received
had the Determination of Taxability not occurred, taking into account the increased
taxable income of the Purchaser as a result of such Determination of Taxability. The
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Purchaser shall provide the Issuer with a written statement explaining the calculation of
the Taxable Rate, which statement shall, in the absence of manifest error, be conclusive
and binding on the Issuer.
"Maximum Federal Corporate Tax Rate" shall mean the maximum rate of income
taxation imposed on corporations pursuant to Section 11(b) of the Code, determined
without regard to tax rate or tax benefit make-up provisions such as the last two sentences
of Section 11(b)(1) of the Code, as in effect from time to time (or, if as a result of a
change in the Code the rate of income taxation imposed on corporations shall not be
applicable to the Purchaser, the maximum statutory rate of federal income taxation which
could apply to the Purchaser). The Maximum Federal Corporate Tax Rate on the date of
execution of this Supplemental Resolution is 35%.
SECTION 12. DEFAULT RATE. After the occurrence of an Event of
Default under Section 6.01 of the Resolution or a material breach or default of any
covenant, warranty or agreement herein, notwithstanding any other terms hereof or of the
Resolution, the Series 2014 Bond shall bear interest at the Default Rate (as defined
below) until such Event of Default is cured. Noncompliance with the provisions of
Section 14 hereof shall be considered a material breach for purposes of this Section 12.
Within 5 days of its actual knowledge, the Issuer shall notify the Purchaser of the
occurrence of any Event of Default or a material breach or default of any covenant,
warranty or agreement herein.
For purposes of this Section 12, "Default Rate" means the lesser of (i) 18% per
annum and (ii) the maximum lawful rate.
SECTION 13. RESERVE ACCOUNT. Pursuant to the provisions of
Section 4.05(A)(4) of the Resolution, the Issuer hereby establishes a separate subaccount
in the Reserve Account for the Series 2014 Bond which shall be designated as the "Series
2014 Subaccount" of the Reserve Account. The Reserve Account Requirement with
respect to the Series 2014 Subaccount and the Series 2014 Bond shall be zero dollars and
zero cents ($0.00). The Series 2014 Subaccount shall solely secure the Series 2014 Bond
and the Series 2014 Bond shall not be secured by any other portion of the Reserve
Account or any other subaccount therein.
SECTION 14. REPORTING FINANCIAL INFORMATION. A copy of
the audited financial statements for each Fiscal Year shall be made available to the
Purchaser within 270 days after the end of each Fiscal Year. A copy of the annual budget
for each Fiscal Year will be provided to the Purchaser within 30 days of final approval.
The Issuer shall also provide the Purchaser with any other items reasonably requested by
the Purchaser.
SECTION 15. GENERAL AUTHORITY. The Issuer, the Chairman, the
County Manager, the Clerk and the officers, attorneys and other agents or employees of
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the Issuer are hereby authorized to do all acts and things required of them by this
Supplemental Resolution, the Resolution or the Escrow Deposit Agreement, or desirable
or consistent with the requirements hereof or the Resolution or the Escrow Deposit
Agreement for the full punctual and complete performance of all the terms, covenants
and agreements contained herein or in the Series 2014 Bond, the Resolution and the
Escrow Deposit Agreement and each member, employee, attorney and officer of the
Issuer and the Clerk is hereby authorized and directed to execute and deliver any and all
papers and instruments and to be and cause to be done any and all acts and things
necessary or proper for carrying out the transactions contemplated hereunder. In the
event the Chairman is absent or unavailable to perform any function or duty hereunder
the Vice-Chairman is hereby authorized to perform any and all of such functions or
duties. Bond Counsel and the Issuer's Financial Advisor are hereby authorized and
directed to take all action necessary and desirable to carryout the intent and purposes of
this Supplemental Resolution.
SECTION 16. MODIFICATION OR AMENDMENT OF THIS
SUPPLEMENTAL RESOLUTION. No modification or amendment of this
Supplemental Resolution or of any resolution amendatory thereof or supplemental
thereto, may be made without the consent in writing of the Purchaser. No modification
or amendment to Article IV or Section 5.02 of the Resolution that adversely affects the
Purchaser may be made without the written consent of the Purchaser.
SECTION 17. WAIVER OF JURY TRIAL. To the extent permitted by
applicable law, the Issuer knowingly, voluntarily and intentionally waives any right it
may have to a trial by jury in respect of any litigation or legal proceeding based on, or
arising out of, the Resolution, this Supplemental Resolution, the Series 2014 Bond,
including any course of conduct, course of dealing, verbal or written statements or
actions or omissions of the Issuer or the Purchaser which in any way relates to the Series
2014 Bond, the Resolution or this Supplemental Resolution.
SECTION 18. APPLICABLE LAW AND VENUE. The Series 2014 Bond
shall be governed by applicable federal law and the internal laws of the State of Florida.
The Issuer agrees that certain material events and occurrences relating to the Series 2014
Bond bear a reasonable relationship to the Laws of Florida and the validity, terms,
performance and enforcement of the Series 2014 Bond shall be governed by the internal
Laws of Florida which are applicable to agreements which are negotiated, executed,
delivered and performed solely in Florida. Unless applicable law provides otherwise, in
the event of any legal proceeding arising out of or related to the Series 2014 Bond, the
Issuer consents to the jurisdiction and venue of any court located in the State of Florida.
SECTION 19. SEVERABILITY AND INVALID PROVISIONS. If any
one or more of the covenants, agreements or provisions herein contained shall be held
contrary to any express provision of law or contrary to the policy of express law, though
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not expressly prohibited or against public policy, or shall for any reason whatsoever be
held invalid, then such covenants, agreements or provisions shall be null and void and
shall be deemed separable from the remaining covenants, agreements or provisions and
shall in no way affect the validity of any of the other provisions hereof or of the Series
2014 Bond.
SECTION 20. RESOLUTION TO CONTINUE IN FORCE. Except as
herein expressly provided, the Resolution and all the terms and provisions thereof are and
shall remain in full force and effect.
SECTION 21. DATE. This Supplemental Resolution shall become effective
immediately upon its adoption.
DULY ADOPTED this 13th day of May, 2014.
COLLIER OUNTY, % ORIDA
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EXHIBIT A
FORM OF ESCROW DEPOSIT AGREEMENT
ESCROW DEPOSIT AGREEMENT
ESCROW DEPOSIT AGREEMENT, dated as of , 2014, by and
between COLLIER COUNTY, FLORIDA (the "County"), and THE BANK OF NEW
YORK MELLON TRUST COMPANY, N.A. (the "Escrow Agent"), a national banking
association organized and existing under the laws of the United States, having its
designated corporate trust office in Jacksonville, Florida, as escrow agent hereunder.
WHEREAS, the County has heretofore issued its Collier County, Florida Gas Tax
Revenue Bonds, Series 2005 (the "Series 2005 Bonds") pursuant to Resolution No.
2003-89, adopted on February 25, 2003, as amended and supplemented, particularly as
supplemented by Resolution No. adopted on May 13, 2014 (collectively, the
"Resolution"); and
WHEREAS, the County has determined it is in its best interests to refund that
portion of the Series 2005 Bonds described on Schedule A hereto (the "Refunded Bonds");
and
WHEREAS, the County has determined to issue its Collier County, Florida Gas
Tax Refunding Revenue Bond, Series 2014 (the "Series 2014 Bond") pursuant to the
Resolution, a portion of the proceeds of which Series 2014 Bond, together with other
legally available moneys of the County,will be used, other than a cash deposit,to purchase
certain United States Treasury obligations in order to provide payment for the Refunded
Bonds and discharge and satisfy the pledge of and lien on the Pledged Funds (as defined in
the Resolution) under the Resolution in regard to such Refunded Bonds; and
WHEREAS, the issuance of the Series 2014 Bond, the purchase by the Escrow
Agent of the hereinafter defined Escrow Securities, the deposit of such Escrow Securities
into an escrow deposit trust fund to be held by the Escrow Agent and the discharge and
satisfaction of the pledge of and lien on the Pledged Funds under the Resolution in regard
to the Refunded Bonds shall occur as a simultaneous transaction; and
WHEREAS, this Agreement is intended to effectuate such simultaneous
transaction;
NOW, THEREFORE, in consideration of the foregoing and of the mutual
covenants hereinafter set forth, the parties hereto agree as follows:
SECTION 1. PREAMBLES. The County represents that the recitals
stated above are true and correct, and the same are incorporated herein.
SECTION 2. RECEIPT OF RESOLUTION AND VERIFICATION
REPORT. Receipt of a true and correct copy of the above-mentioned Resolution and this
Agreement is hereby acknowledged by the Escrow Agent. The applicable and necessary
provisions of the Resolution, including, without limitation, Article III and Section 8.01
thereof, are incorporated herein by reference. The Escrow Agent also acknowledges
receipt of the verification report of dated May , 2014 (the
"Verification Report"). Reference herein to or citation herein of any provisions of the
Resolution or the Verification Report shall be deemed to incorporate the same as a part
hereof in the same manner and with the same effect as if the same were fully set forth
herein.
SECTION 3. DISCHARGE OF PLEDGE OF HOLDERS OF
REFUNDED BONDS. In accordance with Section 8.01 of the Resolution,the County by
this writing exercises its option to cause the pledge of the Pledged Funds, and all
covenants, agreements and other obligations of the County to the holders of the Refunded
Bonds to cease, terminate and become void and be discharged and satisfied.
SECTION 4. ESTABLISHMENT OF ESCROW FUND. There is
hereby created and established with the Escrow Agent a special, segregated and
irrevocable escrow deposit trust fund designated the "Collier County, Florida Gas Tax
Revenue Bonds, Series 2005 Escrow Deposit Trust Fund" (the "Escrow Fund"). The
Escrow Fund shall be held in the custody of the Escrow Agent as a trust fund for the benefit
of the holders of the Refunded Bonds, separate and apart from other funds and accounts of
the County and the Escrow Agent. The Escrow Agent hereby accepts the Escrow Fund
and acknowledges the receipt of and deposit to the credit of the Escrow Fund the sum of
$ from the County from proceeds of the Series 2014 Bonds (the "Bond
Proceeds"), and the sum of $ received from the County from certain
moneys on deposit in the funds and accounts established pursuant to the Resolution for the
benefit of the holders of the Refunded Bonds (the "County Moneys").
SECTION 5. DEPOSIT OF MONEYS AND SECURITIES IN
ESCROW FUND. The County hereby directs the use of the Bond Proceeds and County
Moneys as provided in this Section 5. The Escrow Agent represents and acknowledges
that, concurrently with the deposit of the Bond Proceeds and County Moneys under
Section 4 above, it has used $ of the Bond Proceeds and
$ of the County Moneys to purchase on behalf of and for the account of
the County certain United States Treasury obligations -- State and Local Government
Series (collectively, together with any other securities which may be on deposit, from time
to time, in the Escrow Fund, the "Escrow Securities"), which are described in Schedule B
hereto, and the Escrow Agent will deposit such Escrow Securities and $ of the Bond
Proceeds and $ of the County Moneys in cash (collectively, the "Cash Deposit") in
the Escrow Fund. All Escrow Securities shall be noncallable, direct obligations of the
United States of America.
In the event any of the Escrow Securities described in Schedule B hereto are not
available for delivery on May , 2014, the Escrow Agent may, at the written direction
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of the County and with the approval of Bond Counsel, substitute other United States
Treasury obligations and shall credit such other obligations to the Escrow Fund and hold
such obligations until the aforementioned Escrow Securities have been delivered. Bond
Counsel shall, as a condition precedent to giving its approval, require the County to
provide it with a revised Verification Report in regard to the adequacy of the Escrow
Securities, taking into account the substituted obligations to pay the Refunded Bonds in
accordance with the terms hereof The Escrow Agent shall in no manner be responsible or
liable for failure or delay of Bond Counsel or the County to promptly approve the
substitutions of other United States Treasury obligations for the Escrow Fund.
SECTION 6. SUFFICIENCY OF ESCROW SECURITIES AND THE
CASH DEPOSIT. In reliance upon the Verification Report, the County represents that
the Cash Deposit and the interest on and the principal amounts successively maturing on
the Escrow Securities in accordance with their terms (without consideration of any
reinvestment of such maturing principal and interest) are sufficient such that moneys will
be available to the Escrow Agent in amounts sufficient and at the times required to pay the
amounts of principal of, redemption premium, if any, and interest due and to become due
on the Refunded Bonds as described in Schedule C attached hereto. If the Escrow
Securities and the Cash Deposit shall be insufficient to make such payments, the County
shall timely deposit to the Escrow Fund, solely from legally available funds of the County,
such additional amounts as may be required to pay the Refunded Bonds as described in
Schedule C hereto. Notice of any insufficiency shall be given by the Escrow Agent to the
County as promptly as possible, but the Escrow Agent shall in no manner be responsible
for the County's failure to make such deposits.
SECTION 7. ESCROW SECURITIES AND THE CASH DEPOSIT IN
TRUST FOR HOLDERS OF REFUNDED BONDS. The deposit of the Escrow
Securities and the Cash Deposit in the Escrow Fund shall constitute an irrevocable deposit
of Refunding Securities (as defined in the Resolution) and cash in trust solely for the
payment of the principal of, redemption premium, if any, and interest on the Refunded
Bonds at such times and in such amounts as set forth in Schedule C hereto, and the
principal of and interest earnings on such Escrow Securities and the Cash Deposit shall be
used solely for such purpose.
SECTION 8. ESCROW AGENT TO PAY REFUNDED BONDS FROM
ESCROW FUND. The County hereby directs, and the Escrow Agent hereby agrees,that
it will take all actions required to be taken by it under the provisions of the Resolution
referenced in this Agreement, including the timely transfer of money to the Paying Agent
for the Refunded Bonds(U.S. Bank National Association)as provided in the Resolution, in
order to effectuate this Agreement and to pay the Refunded Bonds in the amounts and at
the times provided in Schedule C hereto. The Escrow Securities and the Cash Deposit
shall be used to pay the principal of, redemption premium, if any, and interest on the
Refunded Bonds as the same may mature or be redeemed. If any payment date shall be a
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day on which either the Paying Agent for the Refunded Bonds or the Escrow Agent is not
open for the acceptance or delivery of funds,then the Escrow Agent may make payment on
the next business day. The liability of the Escrow Agent for the payment of the principal
of, redemption premium, if any, and interest on the Refunded Bonds pursuant to this
Agreement shall be limited to the application of the Escrow Securities and the Cash
Deposit and the interest earnings thereon available for such purposes in the Escrow Fund.
SECTION 9. REINVESTMENT OF MONEYS AND SECURITIES IN
ESCROW FUND. Moneys deposited in the Escrow Fund shall be invested only in the
Escrow Securities listed in Schedule B hereto and the Cash Deposit and, except as provided
in Section 5 hereof and this Section 9, neither the County nor the Escrow Agent shall
otherwise invest or reinvest any moneys in the Escrow Fund.
Except as provided in Section 5 hereof and in this Section 9, the Escrow Agent may
not sell or otherwise dispose of any or all of the Escrow Securities or the Cash Deposit in
the Escrow Fund and reinvest the proceeds thereof in other securities nor may it substitute
securities for any of the Escrow Securities, except upon written direction of the County and
where, prior to any such reinvestment or substitution, the Escrow Agent has received from
the County the following:
(a) a written verification report by a firm of independent certified public
accountants, of recognized standing,appointed by the County and acceptable
to the Escrow Agent, to the effect that after such reinvestment or substitution
the principal amount of Escrow Securities, together with the interest therein,
will be sufficient to pay the Refunded Bonds as described in Schedule C
hereto; and
(b) a written opinion of nationally recognized Bond Counsel to the effect that (i)
such investment will not cause the Series 2014 Bond or the Refunded Bonds
to be "arbitrage bonds" within the meaning of Section 148 of the Internal
Revenue Code, as amended, and the regulations promulgated thereunder or
otherwise cause the interest on the Refunded Bonds or the Series 2014 Bond
to be included as gross income for purposes of federal income taxation, and
(ii) such investment does not violate any provision of Florida law or of the
Resolution.
The above-described verification report need not be provided in the event the County
purchases Escrow Securities with the proceeds of maturing Escrow Securities and such
purchased Escrow Securities mature on or before the next interest payment date for the
Refunded Bonds and have a face amount which is at least equal to the cash amount
invested in such Escrow Securities.
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In the event the above-referenced verification concludes that there are surplus
moneys in the Escrow Fund, such surplus moneys shall be released to the County upon its
written direction. The Escrow Fund shall continue in effect until the date upon which the
Escrow Agent makes the final payment to the Paying Agent for the Refunded Bonds in an
amount sufficient to pay the Refunded Bonds as described in Schedule C hereto,
whereupon the Escrow Agent shall sell or redeem any Escrow Securities remaining in the
Escrow Fund, and shall remit to the County the proceeds thereof, together with all other
money, if any, then remaining in the Escrow Fund.
SECTION 10. REDEMPTION OF CERTAIN REFUNDED BONDS.
The County hereby irrevocably instructs the Escrow Agent to direct, on behalf of the
County, that the Registrar for the Refunded Bonds (U.S. Bank National Association) give
at the appropriate times the notice or notices, if any, required by the Resolution in
connection with the redemption of the Refunded Bonds. Such notice of redemption shall
be given by the Registrar for such Refunded Bonds in accordance with the Resolution.
The Refunded Bonds shall be redeemed on June 1, 2015 at a redemption price equal to
100% of the principal amount thereof plus interest accrued to the redemption date.
SECTION 11. DEFEASANCE NOTICE TO HOLDERS OF
REFUNDED BONDS. Concurrently with the deposit of the Escrow Securities set forth
in Section 5 hereof, the Refunded Bonds shall be deemed to have been paid within the
meaning and with the effect expressed in Section 8.01 of the Resolution. Within 30 days
of the deposit of moneys into the Escrow Fund,the Escrow Agent, on behalf of the County,
shall, or shall cause the Registrar for the Refunded Bonds (U.S. Bank National
Association), to mail to the holders of the Refunded Bonds the appropriate notices in the
form provided in Schedule D attached hereto.
SECTION 12. ESCROW FUND IRREVOCABLE. The Escrow Fund
hereby created shall be irrevocable and the holders of the Refunded Bonds shall have an
express lien on all Escrow Securities and the Cash Deposit deposited in the Escrow Fund
pursuant to the terms hereof and the interest earnings thereon until paid out, used and
applied in accordance with this Agreement and the Resolution. Neither the County nor
the Escrow Agent shall cause nor permit any other lien or interest whatsoever to be
imposed upon the Escrow Fund.
SECTION 13. AMENDMENTS TO AGREEMENT. This Agreement is
made for the benefit of the County and the holders from time to time of the Refunded
Bonds and it shall not be repealed,revoked,altered or amended without the written consent
of all such holders and the written consent of the Escrow Agent; provided, however, that
the County and the Escrow Agent may, without the consent of, or notice to, such holders,
enter into such agreements supplemental to this Agreement as shall not adversely affect the
rights of such holders and as shall not be inconsistent with the terms and provisions of this
Agreement, for any one or more of the following purposes:
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(a) to cure any ambiguity or formal defect or omission in this Agreement;
(b) to grant, or confer upon, the Escrow Agent for the benefit of the holders of
the Refunded Bonds, any additional rights, remedies, powers or authority
that may lawfully be granted to, or conferred upon, such holders or the
Escrow Agent; and
(c) to subject to this Agreement additional funds, securities or properties.
The Escrow Agent shall be entitled to rely exclusively upon an opinion of nationally
recognized Bond Counsel with respect to compliance with this Section 13, including the
extent, if any, to which any change, modification or addition affects the rights of the
holders of the Refunded Bonds, or that any instrument executed hereunder complies with
the conditions and provisions of this Section 13.
SECTION 14. FEES AND EXPENSES OF ESCROW AGENT;
INDEMNIFICATION. In consideration of the services rendered by the Escrow Agent
under this Agreement, the County agrees to and shall pay to the Escrow Agent the fees and
expenses as shall be agreed to in writing by the parties hereto. The Escrow Agent shall
have no lien whatsoever upon any of the Escrow Securities in said Escrow Fund for the
payment of such proper fees and expenses. The County further agrees to indemnify and
save the Escrow Agent harmless,to the extent allowed by law, against any liabilities which
it may incur in the exercise and performance of its powers and duties hereunder, and which
are not due to its negligence or misconduct. Indemnification provided under this Section
14 shall survive the termination of this Agreement.
Whenever the Escrow Agent shall deem it necessary or desirable that a matter be
proved or established prior to taking, suffering or omitting any action under this
Agreement, such matter may be deemed to be conclusively established by a certificate
signed by an authorized officer of the County. The Escrow Agent may conclusively rely,
as to the correctness of statements, conclusions and opinions therein, upon any certificate,
report, opinion or other document furnished to the Escrow Agent pursuant to any provision
of this Agreement; the Escrow Agent shall be protected and shall not be liable for acting or
proceeding, in good faith,upon such reliance; and the Escrow Agent shall be under no duty
to make any investigation or inquiry as to any statements contained or matters referred to in
any such instrument. The Escrow Agent may consult with counsel, who may be counsel
to the County or independent counsel, with regard to legal questions, and the opinion of
such counsel shall be full and complete authorization and protection in respect of any
action taken or suffered by it hereunder in good faith in accordance herewith. Prior to
retaining such independent counsel, the Escrow Agent shall notify the County of its
intention.
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The Escrow Agent and its successors, agents and servants shall not be held to any
personal liability whatsoever, in tort, contract or otherwise, by reason of the execution and
delivery of this Agreement, the establishment of the Escrow Fund, the acceptance and
disposition of the various moneys and funds described herein, the purchase, retention or
payment, transfer or other application of funds or securities by the Escrow Agent in
accordance with the provisions of this Agreement or any non-negligent act, omission or
error of the Escrow Agent made in good faith in the conduct of its duties. The Escrow
Agent shall, however, be liable to the County and to holders of the Refunded Bonds to the
extent of their respective damages for negligent or willful acts, omissions or errors of the
Escrow Agent which violate or fail to comply with the terms of this Agreement. The
duties and obligations of the Escrow Agent shall be determined by the express provisions
of this Agreement.
SECTION 15. REPORTING REQUIREMENTS OF ESCROW AGENT.
As soon as practicable after each June 1 and December 1, commencing June 1, 2014, the
Escrow Agent shall forward in writing to the County a statement in detail of the activity of
the Escrow Fund.
SECTION 16. RESIGNATION OR REMOVAL OF ESCROW
AGENT. The Escrow Agent, at the time acting hereunder, may at any time resign and be
discharged from the duties and obligations hereby created by giving not less than 60 days'
written notice to the County and mailing notice thereof, specifying the date when such
resignation will take effect to the holders of all Refunded Bonds then outstanding, but no
such resignation shall take effect unless a successor Escrow Agent shall have been
appointed by the holders of a majority in aggregate principal amount of the Refunded
Bonds then outstanding or by the County as hereinafter provided and such successor
Escrow Agent shall have accepted such appointment, in which event such resignation shall
take effect immediately upon the appointment and acceptance of a successor Escrow
Agent.
The Escrow Agent may be replaced at any time by an instrument or concurrent
instruments in writing, delivered to the Escrow Agent and signed by either the County or
the holders of a majority in aggregate principal amount of the Refunded Bonds then
outstanding. Such instrument shall provide for the appointment of a successor Escrow
Agent, which appointment shall occur simultaneously with the removal of the Escrow
Agent.
In the event the Escrow Agent hereunder shall resign or be removed, or be
dissolved, or shall be in the course of dissolution or liquidation, or otherwise become
incapable of acting hereunder, or in case the Escrow Agent shall be taken under the control
of any public officer or officers, or of a receiver appointed by a court, a successor may be
appointed by the County or by the holders of a majority in aggregate principal amount of
the Refunded Bonds then outstanding by an instrument or concurrent instruments in
writing, signed by such holders, or by their attorneys in fact, duly authorized in writing. In
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the event the holders of the Refunded Bonds shall appoint a successor Escrow Agent, the
County may appoint a temporary Escrow Agent to fill such vacancy until a successor
Escrow Agent shall be appointed by the holders of a majority in aggregate principal
amount of the Refunded Bonds then outstanding in the manner above provided, and any
such temporary Escrow Agent so appointed by the County shall immediately and without
further act be superseded by the Escrow Agent so appointed by such holders. The County
shall mail notice of any such appointment made by it at the times and in the manner
described in the first paragraph of this Section 16.
In the event that no appointment of a successor Escrow Agent or a temporary
successor Escrow Agent shall have been made by such holders or the County pursuant to
the foregoing provisions of this Section 16 within 60 days after written notice of
resignation of the Escrow Agent has been given to the County, the holder of any of the
Refunded Bonds or any retiring Escrow Agent may apply to any court of competent
jurisdiction for the appointment of a successor Escrow Agent, and such court may
thereupon, after such notice, if any, as it shall deem proper, appoint a successor Escrow
Agent.
In the event of replacement or resignation of the Escrow Agent, the Escrow Agent
shall have no further liability hereunder and the County shall indemnify and hold harmless
Escrow Agent from any such liability, including costs or expenses incurred by Escrow
Agent or its counsel.
No successor Escrow Agent shall be appointed unless such successor Escrow Agent
shall be a corporation with trust powers organized under the banking laws of the United
States or any State, and shall have at the time of appointment capital and surplus of not less
than $30,000,000.
Every successor Escrow Agent appointed hereunder shall execute, acknowledge
and deliver to its predecessor and to the County an instrument in writing accepting such
appointment hereunder and thereupon such successor Escrow Agent, without any further
act, deed or conveyance, shall become fully vested with all the rights, immunities, powers,
trusts, duties and obligations of its predecessor; but such predecessor shall nevertheless, on
the written request of such successor Escrow Agent or the County execute and deliver an
instrument transferring to such successor Escrow Agent all the estates, properties, rights,
powers and trust of such predecessor hereunder; and every predecessor Escrow Agent shall
deliver all securities and moneys held by it to its successor; provided, however, that before
any such delivery is required to be made, all fees, advances and expenses of the retiring or
removed Escrow Agent shall be paid in full. Should any transfer, assignment or
instrument in writing from the County be required by any successor Escrow Agent for
more fully and certainly vesting in such successor Escrow Agent the estates,rights,powers
and duties hereby vested or intended to be vested in the predecessor Escrow Agent, any
such transfer, assignment and instruments in writing shall, on request, be executed,
acknowledged and delivered by the County.
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Any corporation into which the Escrow Agent, or any successor to it in the trusts
created by this Agreement, may be merged or converted or with which it or any successor
to it may be consolidated, or any corporation resulting from any merger, conversion,
consolidation or tax-free reorganization to which the Escrow Agent or any successor to it
shall be a party shall be the successor Escrow Agent under this Agreement without the
execution or filing of any paper or any other act on the part of any of the parties hereto,
anything herein to the contrary notwithstanding.
SECTION 17. TERMINATION OF AGREEMENT. This Agreement
shall terminate when all transfers and payments required to be made by the Escrow Agent
under the provisions hereof shall have been made. Upon such termination, all moneys
remaining in the Escrow Fund shall be released to the County.
SECTION 18. GOVERNING LAW. This Agreement shall be governed by
the applicable laws of the State of Florida.
SECTION 19. SEVERABILITY. If any one or more of the covenants or
agreements provided in this Agreement on the part of the County or the Escrow Agent to be
performed should be determined by a court of competent jurisdiction to be contrary to law,
such covenant or agreement shall be deemed and construed to be severable from the
remaining covenants and agreements herein contained and shall in no way affect the
validity of the remaining provisions of this Agreement.
SECTION 20. COUNTERPARTS. This Agreement may be executed in
several counterparts, all or any of which shall be regarded for all purposes as one original
and shall constitute and be but one and the same instrument.
[Remainder of page intentionally left blank]
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SECTION 21. NOTICES. Any notice, authorization, request or demand
required or permitted to be given in accordance with the terms of this Agreement shall be in
writing and sent either by facsimile, overnight express mail with fees prepaid, first class
mail with postage prepaid; or hand delivered to the Issuer or the Bank, respectively, at the
addresses or facsimile numbers shown below:
Collier County, Florida
Collier County Government Complex
3299 Tamiami Trail East, #202
Naples, FL 34112
Attention: County Manager
Facsimile: (239) 252-8588
Bank of New York Mellon Trust Company, N.A.
10161 Centurion Parkway
Jacksonville, Florida 32256
Attention: Corporate Trust Department
Facsimile: (904) 645-1921
[Remainder of page intentionally left blank]
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IN WITNESS WHEREOF, the parties hereto have each caused this Escrow
Deposit Agreement to be executed by their duly authorized officers and appointed
officials, and the seal of the County to be hereunder affixed and attested, as of the date first
written herein.
COLLIER COUNTY, FLORIDA
(SEAL)
Chairman, Board of County Commissioners
ATTEST:
Deputy Clerk
Approved as to Form and Legal Sufficiency:
County Attorney
THE BANK OF NEW YORK MELLON
TRUST COMPANY, N.A.,
Escrow Agent
By:
Authorized Signatory
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SCHEDULE A
REFUNDED BONDS
[TO COME]
SCHEDULE B
ESCROW SECURITIES
[TO COME]
SCHEDULE C
DEBT SERVICE REQUIREMENTS FOR REFUNDED BONDS
[TO COME]
SCHEDULE D
FORM OF NOTICE OF DEFEASANCE
Notice is hereby given pursuant to Resolution No. 2003-89 adopted by the Board of
County Commissioners of Collier County, Florida on February 25, 2003, as amended and
supplemented (the "Resolution"), that the outstanding Collier County, Florida Gas Tax
Revenue Bonds, Series 2005 described below (the "Refunded Bonds") are deemed to be
paid within the meaning of the Resolution and shall no longer be secured from the Pledged
Funds (as defined in the Resolution) and shall be secured solely from the irrevocable
deposit of U.S. Treasury obligations and cash made by the County with The Bank of New
York Mellon Trust Company,N.A., Jacksonville, Florida, as Escrow Agent, in accordance
with Section 8.01 of the Resolution. The Refunded Bonds shall be redeemed on June 1,
2015 at the offices of the paying agent for the Refunded Bonds at a redemption price equal
to 100% of the principal amount thereof plus interest accrued to the redemption date.
[insert Refunded Bonds information]