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Agenda 10/28/2014 Item #10A10/28/2014 10.A. EXECUTIVE SUMMARY Recommendation to accept information on the record contrary to information presented under Agenda Item 10.13 to present factual information available by public record regarding the Clerk of Courts contract for banking services with First Florida Integrity Bank as adopted under Agenda Item D.A. at the September 23, 2014 Board meeting. OBJECTIVE: To present factual information as obtained by public record to clarify all issues regarding the new banking services contract adopted by the Board on September 23, 2014 and to advise the Board it has no authority to take action on Agenda Item 10.B. CONSIDERATIONS: On September 23, 2014 at a regular Board meeting, the Board of County Commissioners approved with a 3 to 2 vote the Clerk of Court Banking Services Agreement with Florida First Integrity Bank (FFIB) under Agenda Item 13.A. The voting majority for this agenda item is Commissioner Henning, Commissioner Nance and Commissioner Fiala. See Exhibit A. Since approving the Clerk of Courts' FFIB Banking Services Contract, Commissioner Hiller has raised questions regarding the legality of the contract and the process by which a contract/agreement was negotiated. It shall be placed on the record that no such Sunshine Violations occurred related to the final Selection Committee created by the Clerk. The initial Selection Committee failed to advertise its vendor presentation meetings and prior to this committee making any recommendation to the Clerk it was dissolved. A new Selection Committee with different members was formed with all meetings properly advertised. The Selection Committee advertised its vendor presentation meeting with FFIB which can be found online at http:/ /www .collierclerk.com /clerksoffice /functions /purchasin /public-notices- and- invitations -to- bid /rfp -2014- 001 - banking- services/banking- services- recordinas /. From the Clerk's minutes of the FFIB vendor presentation, FFIB clarified that although the vendor "requested" a $25 million minimum account balance it was not required and therefore was not included in the agreement. See Exhibits A and B. Commissioner Hiller's Agenda Item 10.13. on this agenda would require the Board to reconsider its approval of Agenda Item 13.A. from September 23, 2014. The Board must adhere to its Reconsideration Ordinance (codified as Section 2 -41 in Municode) in order to reconsider an item, which requires a motion "made by a member who voted with the majority" following delivery to the County Manager of "a written memorandum stating that the member intends to introduce a motion to reconsider." The memorandum must be submitted to the County Manager at least six days prior to "the second regular Commission meeting following the meeting at which the motion for reconsideration was adopted." Agenda l O.B. does not meet this requirement. See Exhibit C. Packet Page -269- 10/28/2014 10.A. Furthermore, the County Attorney emailed Commissioner Hiller his opinion that the Board does have a valid contract with FFIB and the Board has regularly waived its purchasing policy specifically with urgent circumstances regarding the immediate need for banking services. See Exhibit D. Additional concerns have been raised concerning the Clerk utilizing a third -party, not the County's depository-bank as the investment and securities holder is recommended by the Government Finance Officers Association (GFAO). As part of GFAO's recommended Best Practices its Executive Board in October 2010 adopted the following recommendation: "GFOA recommends that state and local governments utilize independent third -party custodians to safeguard their investments and protect against safekeeping /custodial risks." The Government Finance Officers Association additionally stated in its recommendation report that, "In a third -party safekeeping agreement, the government arranges for a finn other than the party that sold the investment to provide for the transfer and safekeeping of the securities. Financial firms should not serve both as government broker - dealer and custodian... Custody normally does not take place in the governmental entities depository bank." See Exhibit E. FISCAL IMPACT: None. LEGAL CONSIDERATIONS: This item is approved as to form and legality, and should be heard concurrently with Item I O.B. -JAK RECOMMENDATION: Recommendation the Board has no authority to take action on Agenda Item IO.B. because Commissioner Hiller was not in the voting majority for the September 23, 2014 Agenda Item 13.A, and therefore a reconsideration would be in violation of the Board's Reconsideration Ordinance. Prepared by: Commissioner Tom Henning Exhibits: A) FFIB Banking Services Agreement; B) Excerpt Minutes July 30 Vendor Presentation FFIB; C) Reconsideration Ordinance Section 2 -41; D) Email CAO to Commissioners and Email Attachment; E) GFAO Safekeeping and Third Party Best Practices Packet Page -270- COLLIER COUNTY Board of County Commissioners Item Number: 10.10.A. 10/28/2014 10.A. Item Summary: Recommendation to accept information on the record contrary to information presented under Agenda Item 10.13 to present factual information available by public record regarding the Clerk of Courts contract for banking services with First Florida Integrity Bank as adopted under Agenda Item 13.A. at the September 23, 2014 Board meeting. (Commissioner Henning) Meeting Date: 10/28/2014 Prepared By Name: SmithCamden Title: Executive Coordinator to Commissioner, 10/14/2014 10:47:59 AM Approved By Name: DurhamTim Title: Executive Manager of Corp Business Ops, Date: 10/22/2014 12:50:35 PM Name: OchsLeo Title: County Manager, County Managers Office Date: 10/22/2014 3:06:46 PM Packet Page -271- 10/28/2014 1O.A. Contract Number 2014 -001 MASTER BANKING SERVICES AGREEMENT The Master Banking Services Agreement ( "Agreement ") is entered into as of the 1' day of November, 2014 among the Clerk of the Circuit Court and Comptroller of Collier County, Florida ( "Clerk "), the Collier County Board of County Commissioners ( "Board ") and First Florida Integrity Bank ( "Bank "), collectively the "Parties." Recitals WHEREAS, the Clerk has requested that the Bank provide certain banking and treasury management services (collectively, the "Banking Services ") to the Clerk; and WHEREAS, the Board has requested Banking Services through the Clerk, as the custodian of the Board's funds, for the Bank to provide certain banking and treasury management services; and WHEREAS, the Bank has agreed to provide the Banking Services to the Clerk and the Board; the Clerk and the Board have agreed to accept the Banking Services, upon the terms and conditions set forth in this Agreement. NOW, THEREFORE, in consideration of the foregoing premises and other good and valuable consideration, the receipt and adequacy of which are hereby acknowledged, the Parties hereby covenant and agree as follows: Section 1. Purpose and Effect of this Agreement: Delineation of Banking Services The banking services to be provided to the Clerk and the Board by the Bank shall consist of: (a) Each of the specific requirements, terms and conditions set forth in the Request for Proposal (RFP) 2014 -001 Banking Services (Exhibit A) dated May 12, 2014 which RFP is hereby incorporated by reference in its entirety; and (b) Each of the services, terms and conditions set forth in the Bank Proposal (Exhibit B) dated June 13, 2014, which Bank Proposal is hereby incorporated herein by reference in its entirety; and (c) Each of the terms, conditions and provisions of the specific banking service agreements provided for in the Exhibits detailed in Section 14 of this Agreement, hereinafter collectively referred to as the "Exhibits," which are attached hereto and made a part hereof. Unless the context requires otherwise, all references to this "Agreement," and use of the terms "herein," "hereby," "hereof," "hereto," "hereunder" and the like shall be deemed to include the RFP, the Bank Proposal, all other Exhibits attached hereto, and this Agreement. Section 2. Controlling Provisions Contract No. 2014 -001 Page 1 of 8 Packet Page -272- 10/28/2014 10.A. Except as otherwise specifically provided in Section 6 hereof, in the event of any conflict between the specific provisions of this Agreement or any of the Exhibits hereto, on the one hand, and the requirements or provisions of the RFP and /or Proposal, on the other hand, the requirements or provisions of the written Agreement shall control. Wherever possible, the provisions of all documents shall be construed in such a manner as to avoid conflicts between provisions of the various documents. It is the intention of the Parties that the Exhibits hereto set forth the day -to -day operational procedures to be complied with in connection with the Clerk's ordering of and the Bank's provision of specific banking services covered by the Proposal. In that connection, the Parties hereby acknowledge and agree that, in the event that the Clerk or the Board elects to utilize any banking services not specifically set forth in the Proposal, or in the event that the Bank, in the normal course of its business, develops specific service agreements in the future for banking services requested by the Clerk or the Board in addition to those covered by the Exhibits hereto, the Parties will execute specific service agreements with respect thereto. Such agreements shall be consistent with the terms and provisions of the RFP, the Proposal and this Agreement, and in form and substance reasonably acceptable to the Parties, and such agreements shall be deemed to be a part of and subject to this Master Banking Services Agreement, whether or not so stated in such service agreement. Section 3. Services to be Rendered The Clerk may establish a reasonable number of additional demand deposit accounts or time deposit accounts with the Bank at no extra cost. All banking services and online services, specified in Exhibit B of this Agreement, shall be available at commencement of this Agreement. The Clerk and the Board reserve the right to segregate merchant services, retail and wholesale lockbox (Lockbox) and other associated electronic services related to merchant services and Lockbox initially, or with sixty (60) days written notice to the Bank at any time during the term of this Agreement. Any segregation of services shall be reflected in a corresponding decrease in the monthly fee as specified in Exhibit C of this agreement. The Board shall have the right to independently enter into separate service agreements at any time during the term of this Agreement. Section 4. Payment for Services Subsequent to the first year of service, which is without charge, general banking and custodial fees shall be billed on a monthly basis pursuant to Exhibit C and shall be paid in accordance with Florida's Prompt Payment Act, Florida Statute 218.74. Payment for merchant services, or any additional services agreed upon, shall be billed on a monthly basis with sufficient detail to allow the Clerk to assess services used and paid in accordance with Florida's Prompt Payment Act, Florida Statute 218.74. In no event shall the fee for general banking services and custodial services exceed $7,500 per month, excluding merchant services, for the initial term of the contract. Contract No. 2014 -001 Page 2 of 8 Packet Page -273- 10/28/2014 10.A. Section S. Interest Rate Paid on Collected Balances All balances available for overnight investment shall earn interest as indicated by the formula in Section III, Scope of Banking Services of the RFP at 95% of Daily Effective Federal Funds. The interest rate on available balances shall never fall below 25 basis points. The Bank reserves the right to offer a more favorable interest earnings rate, provided that the interest rate on available balances shall never fall below 95% of Daily Effective Federal Funds or 25 basis points, whichever is greater. All balances in excess of the $250,000 Federal Deposit Insurance Corporation (FDIC) insurance shall be collateralized by the Bank in accordance with all applicable Florida laws. Account statements shall be provided on a monthly basis. Section 6. Representations, Warranties and Covenants (a) The Bank hereby represents and warrants to the Clerk and the Board that it has full power and authority to enter into this Agreement and fully perform its obligations hereunder without the need for any further corporate or governmental consents or approvals, and that the persons executing this Agreement are authorized to execute and deliver it. Assuming the due authorization, execution, delivery, legality and enforceability hereof by or against the Clerk and the Board when executed and delivered by the Parties, this Agreement will constitute a valid and binding agreement of the Bank, enforceable against it in accordance with its terms, subject only to the application of general principles of equity and limitations arising from bankruptcy, insolvency, moratorium and other similar laws affecting the rights of creditors generally. (b) The Bank has not employed or retained any person employed by the Clerk to solicit or secure this Agreement and it has not offered to pay, paid, or agreed to pay any person employed by the Clerk any fee, commission percentage, brokerage fee, or gift of any kind contingent upon or resulting from the award of this Agreement. (c) The Bank is aware of the conflict of interest, and ethics laws, of the ordinances of Collier County and rules and regulations of the Clerk and the Board, and of the State of Florida, and covenants that the Bank will fully comply in all material respects with the terms of said laws, ordinances, rules and regulations. (d) This Agreement constitutes a valid and binding agreement, enforceable against it in accordance with its terms, subject only to the application of general principles of equity and law and limitations arising from bankruptcy, insolvency, moratorium and other similar laws affecting the rights of creditors generally. The Clerk further represents and warrants to the Bank that it has authorized the Clerk's Director of Finance and Accounting, or persons designated by them in writing, to execute and deliver documents to the Bank as necessary hereunder or reasonably deemed appropriate by such officers to effect the transactions contemplated hereby. The Clerk acknowledges and agrees that the Bank is fully authorized and directed to accept orders, requests and authorizations from such officers on the Clerk's behalf in connection with the implementation or provision of any of the banking services covered by the Proposal. Such authorization and direction shall not be deemed to prohibit or preclude the Bank from relying upon actions or requests of Deputy Clerk's so long as the Bank reasonably Contract No. 2014 -001 Page 3 of 8 Packet Page -274- 10/28/2014 10.A. believes, in good faith, that such persons have been authorized to act on behalf of the Clerk or the Board. (e) At the request of the Bank, the Clerk and the Board agree to cause its designated officials or their designees to execute such signature cards as the Bank deems reasonably necessary for purposes of establishing appropriate security measures in connection with the banking services to be provided hereunder. The Clerk and the Board agree to provide any and all documentation the Bank requires to execute and appoint such designated officials or their designees. (f) The Bank covenants to provide the Clerk, and when requested by the Board, with quarterly updates to the Bank's Qualified Public Depository status and current pledge level (25%, 50 %, 110% or 150%) commencing quarter ended December 31, 2014. Section 7. Indemnification The Bank shall indemnify and hold harmless the Clerk, the Board and their authorized agents and employees from or on account of any losses, costs, claims and damages resulting from any breach of fiduciary duty committed during or on account of any operations connected with this Agreement and by any act of negligence in connection with the same; and by or on account of any negligent act or omission or willful misconduct of the Bank or its subcontractors, agents, servants and employees and from any breach of this Agreement. The Bank further agrees to indemnify and hold harmless the Clerk, the Board and their authorized agents and employees against any claims or liability arising from or based upon the violation of any applicable federal, state, county or city laws, by -laws, ordinances or regulations by the Bank, its subcontractors, agents, servants or employees and from any breach of this Agreement. Section 8. Limitation of Liability Notwithstanding any other term or provision of this Agreement, the Clerk and the Board shall not be liable to the Bank for any amount in excess of the actual loss sustained by the injured party, and in no event shall the Clerk and the Board ever be liable hereunder or in any action in tort arising out of the services or relationship to be provided or established hereunder for any indirect, special, incidental, punitive or consequential loss or damage of any kind, including lost profits or opportunities or damage to reputation (whether or not advised of the possibility thereof) arising or allegedly arising therefrom. Section 9. Term and Termination (a) This Agreement shall have an initial term of (5) five years, beginning on November 1, 2014 and expiring on October 31, 2019, with an option to renew upon mutual agreement of the "Parties" for an additional (3) three, (1) one year periods. Banking service charges for the optional renewal period(s) must be mutually agreed upon and will be based on charges proposed. Proposed charges shall not exceed the average of the monthly Consumer Price Index- All Urban Consumers (12 -Month Percent Change — Not Seasonally Adjusted) and measured October 2014 through September 2019. Contract No. 2014 -001 Page 4 of 8 Packet Page -275- 10/28/2014 10.A. (b) The contract may be terminated with cause by the Bank upon providing written notice to the Clerk of the Circuit Court and the Board no less than (180) one hundred and eighty days prior to the effective date of such termination. The Clerk and the Board may terminate the agreement with or without cause with the financial institution upon (30) thirty days written notice prior to the effective date of the termination. Under no circumstances will any damages be paid by the Clerk or the Board as a result of the termination of this contract. (c) If the Bank does not comply with terms of this Agreement, the Bank shall be given notice to the specific default in writing. The default(s) shall be corrected within ten (10) days. (d) The Clerk and /or the Board, from time to time, during Bank business hours and with at least two (2) business days prior notice to the Bank, shall have the right to audit the Bank's books and records with regard to the accounts and services provided to the Clerk and /or the Board hereunder to ensure that all aspects of the Agreement are being met. Such audit will be performed at the expense of the Clerk and /or the Board. (e) In the event the Clerk and the Board are not allotted funds for any fiscal period or funds previously allotted are subsequently recalled, the Clerk and the Board may terminate the agreement. Upon the occurrence of such non - appropriation, the Clerk and the Board shall not be obligated for payment of any future deliverables for which funds have not been so appropriated. Section 10. Changes The Clerk may, from time to time, request changes in the scope of services of the Bank for accounts specific to the Clerk of Courts to be performed hereunder. Such changes in services, which are mutually agreed upon by and between the Clerk and the Bank, shall be incorporated in written amendments to this Agreement. The Board may, from time to time, request changes in the scope of services of the Bank for accounts specific to the Board to be performed hereunder. Such changes in services, which are mutually agreed upon by and between the Clerk and the Bank, shall be incorporated in written amendments to this Agreement. Section 11. Waiver No waiver of a breach of any provision of this Agreement shall constitute a waiver of any subsequent breach of the same or any other provision hereof, and no waiver shall be effective unless made in writing. Section 12. Severability Should any provisions, paragraphs, sentences, words or phrases contained in this Agreement be determined by a court of competent jurisdiction to be invalid, illegal or otherwise unenforceable under the laws of the State of Florida or the Clerk and /or the Board, such provisions, Contract No. 2014 -001 Page 5 of 8 Packet Page -276- 10/28/2014 10.A. paragraphs, sentences, words or phrases shall be deemed modified to the extent necessary in order to conform with such laws, and to the extent they cannot be so modified, then same shall be deemed severable, and in either event, the remaining terms and provisions in this Agreement shall remain unmodified and in full force and effect. Section 13. Governing Law This Agreement shall be construed and enforced according to the Laws of the State of Florida. Any litigation arising out of this Agreement shall be in the appropriate state court having jurisdiction in Collier County, Florida. Section 14. Exhibits The following documents are attached hereto and incorporated by reference herein: Exhibit A — RFP 2014 -001 Banking Services Exhibit B — First Florida Integrity Bank Proposal in response to RFP 2014 -001 RFP Banking Services Exhibit C — First Florida Integrity Bank Pricing Proposal in response to RFP 2014 -001 Banking Services Exhibit D — First Florida Integrity Bank letter waiving $25M minimum balance requirement Exhibit E — Custodial Agreement with Infinex Financial Group Exhibit F — Wholesale Lockbox Agreement with First Florida Integrity Bank Additional service agreements may be added from time to time as mutually agreed upon by the Parties, and any service agreement may be terminated separately and severally without affecting the continued enforceability of all other provisions of this Agreement as to non - terminated services. Section 15. Notices All written notices, demands and other communications required or provided for hereunder or under any of the Exhibits hereto, except service issues, which may be addressed by telephonic communication or other method provided hereunder, shall be sent by certified mail, return receipt requested, postage prepaid, in the case of mailing, or by overnight or same day courier, or by electronic transmission producing a written record, or hand delivered to the following address and person bearing the following title for each party hereto or such other addressee or person as shall be designated by a party in a written notice given in the manner required hereby: Clerk: Dwight E. Brock Collier County Clerk of the Circuit Court 3315 Tamiami Trail East Suite 102 Naples, Florida 34112 -5324 Phone: (239) 252 -2745 Email: Dwight.Brock @collierclerk.com Bank: First Florida Integrity Bank Nancy Ortega, Senior Vice President 3560 Kraft Road Naples, Florida 34105 Phone: (239) 325 -3748 Email: nancyortega@ffibank.com Contract No. 2014 -001 Page 6 of 8 Packet Page -277- Attest: Attest: 10/28/2014 10.A. Board: Leo Ochs, Jr. Collier County Manager 3299 Tamiami Trail East Suite 202 Naples, Florida 34112 -5746 Phone: (239) 252 -8383 Email: Ieoochs@colliereov.net All notices shall be deemed delivered when received. Section 16. Service Issues All service issues related to the everyday operations of the Clerk and the Board shall be responded to on the same business day. Section 17. Force Maieure Clerk and Board agree that the Bank shall not be responsible or liable for any delay in its performance under this Agreement or any losses arising out of delays and /or interruptions of business due to acts of God, acts of public enemy or war, riots, civil disturbances, power failure beyond the Bank's reasonable control, telecommunications failure beyond the Bank's reasonable control, severe adverse weather conditions or other causes beyond the Bank's reasonable control. This time, if any, required for such performance under this Agreement shall be automatically extended during the period of such delay or interruption. Section 18. Assignment The Parties shall not assign this Agreement or any interest herein, or delegate any of its duties hereunder, without the other party's prior written consent, except that it is agreed by the Clerk and the Board that the Bank may delegate certain services to be provided through independent contractors as described in any Exhibits attached hereto. In addition, the contract shall not be transferred by merger, sale or acquisition, in whole or in part without providing 60 days' notice to the Clerk and the Board. All costs to the Clerk and the Board associated with the merger, sale or acquisition shall be borne by the Bank. IN WITNE,�S WHEREOF, the Parties have executed this Agreement hereto: Depp�y Clerk Clerk of the Circuit Court By: Dwigh Bro Clerk of the rcuit Court a Comptrolle of jollier Coo Tom Henning Chairman, Board of County Contract No. 2014 -001 Page 7 of 8 Packet Page -278- missioners 10/28/2014 10.A. Attest By: Garrett S. Richter President, first glorha Integrity Bank App,revVgs 0 Aof rrj and legality: By: _— I Jeffrey A. K County AM Contract No. 2014 -001 Page 8 of 8 Packet Page -279- 10/28/2014 10.A. July 30, 2014 RFP 2014 -001 Excerpt: Vendor Presentation 1 Time 50:09 to 51:25 Derek Johnssen — Assistant Finance Director, Clerk of Courts - Finance and Accounting Department:... requested minimum balance of $25 million dollars and the requested was another semantics issue that we needed to go over. is requested required, and if so what happens if it dipped below that balance? What would the ramifications be? Garrett Richter — President — First Florida Integrity Bank: I would tell you there would be no ramifications. In fact, as was discussed in the public meeting the balances as our research has told us have never really gone below that. I know you prefer to have the opportunity if market scenarios change to move funds into other alternative investments that is an advantage to the Clerk. We can remove the $25 million dollar minimum balance with the confidence, we can do that because we're confident that we can provide the best services and at a very competitive market driven rate environment. So it would be no negative consequences. Derek Johnssen: So, in short, for my simple, now caffeine addled mind, it is a request not a requirement. Garrett Richter — President — First Florida Integrity Bank: We can, we can. Yes Packet Page -280- 10/28/2014 10.A. Sec. 2 -41. - Reconsideration of matters generally. (a) Any matter which has been voted upon by the Board of County Commissioners may be reconsidered as follows: (1) By a motion to reconsider made by a member who voted with the majority if such motion is made prior to the adjournment of the meeting at which the matter was voted upon. If there were no public speakers on the item, or if all of the public speakers for the item are still present in the boardroom following a successful motion to reconsider, the Board may elect to rehear the matter during that meeting, or direct the County Manager to place the item on the agenda for a future meeting as set forth in subsection (2). If there were public speakers for the item, and not all of the public speakers are still present in the boardroom following a successful motion to reconsider, the County Manager will place the item on the agenda for a future meeting as set forth in subsection (2)• (2) By a motion to reconsider made by a member who voted with the majority if such motion is made at a regular meeting following the meeting at which the matter was voted upon, but only in accordance with the following: a. Where a member who voted with the majority wishes the Board to reconsider a matter after the adjournment of the meeting at which it was voted on, the member shall deliver to the County Manager a written memorandum stating that the member intends to introduce a motion to reconsider. The memorandum shall state the date of the regular meeting at which the member intends to introduce such motion, and shall be delivered to the County Manager at least six days prior to such meeting. The purpose of this requirement is to allow the staff to advise the Board of the legal or other ramifications of reconsideration. b. No motion to reconsider shall be made any later than the second regular Board meeting following the Board's vote on the matter sought to be reconsidered. c. Upon adoption of a motion to reconsider, the County Manager shall place the item on an agenda not later than the second regular Commission meeting following the meeting at which the motion for reconsideration was adopted. d. All parties who participated by speaking, submitting registration forms or written materials at the first hearing, shall be notified by the County Manager of the date of reconsideration. (b) This section shall apply to any matters which may lawfully be reconsidered except those matters which are covered by Paragraph 7 below. (Ord 1 1. �'l ?4, 1`' ?: Ord ;1o. 07 50, ` ?; Or 'Vo. 009 -52. i 1 ) • Sec. 2 -42. - Reconsideration of land use matters. (a) Applicability;. Any matter in which the Board of County Commissioners or Board of Zoning Appeals, as the case may be, has denied a request to change the land use designation of a parcel of land, a request for site specific rezone initiated by a petitioner or his or her agent, variance, conditional use, license, permit or other land use - related request. (b) Request, for Reconsideration bY Petitioner. A request for reconsideration may be made only by the petitioner. The petitioner may request reconsideration of a petition in writing to the County Manager no later than 15 days from the date of the Board's action denying the original petition. Except as provided below, this request shall be jurisdictional, and no motion for reconsideration may be made by any member of the Board where such a request was untimely. If State or Federal submission and /or approval schedules pertaining to the petition are extended within 6 months following the denial of the original petition, upon Public Petition initiated by the petitioner, the Board may extend petitioner's Packet Page -281- 10/28/2014 10.A. request for reconsideration by majority vote, and on a second motion made by any Commissioner, place the issue of reconsideration for a date certain on which the action or petition will be reconsidered, but in no event shall such reconsideration take place less than 14 days nor more than 45 days from the date the motion to reconsider is adopted. (c) Motion for reconsideration by a Board member who voted in the majority. Any member of the Board who voted with the majority (or in the case of a rezoning or change in land use designation, voted against) on the original action or petition may move for a reconsideration of the action or petition at any regular meeting of the Board within 15 days of the date of the request for reconsideration. If no regular meeting of the Board occurs within 15 days of the request for reconsideration, the Board member may move for a reconsideration of the action or petition no later than the first meeting of the Board that follows the County Manager's receipt of the request for consideration. This motion shall be made during that portion of the Board's agenda entitled "Board of County Commissioners." If no motion for reconsideration is made during this time period, the request shall be deemed denied. The motion may specify a date certain on which the action or petition will be reconsidered, but in no event shall such reconsideration take place less than 14 days nor more than 45 days from the date the motion to reconsider is adopted. (d) Action on motion for reconsideration. The Board shall either act on the motion for reconsideration at the meeting at which such motion is made or may table the motion for no longer than the next regular meeting of the Board. If the motion is not finally acted upon by the adjournment of-the next regular meeting of the Board after the motion has been made, it shall be deemed to have been denied. (e) Scheduling ofpetition for reconsideration. If the motion for reconsideration is granted, the County Manager shall schedule the petition on the agenda for the regular Board meeting which was specified in the motion for reconsideration, or if no date is specified then on the second regular Board meeting following the meeting at which the motion is granted. (f) No hearing or debate on motion for reconsideration. A motion for reconsideration shall not require public hearing, and neither the petitioner nor any other person shall have the right to address the Board considering the merits of such a motion. However, the Board may request information of the petitioner, the staff or any other person in order to better inform itself prior to acting upon the motion. The purpose of this provision is to prevent either the petitioner or any other person from debating the merits of the petition prior to its full consideration at a regularly scheduled Board meeting where the petition is reconsidered. (g) [Procedures outlined.] The procedures outlined herein shall not constitute an administrative remedy, and the defense of failure to exhaust administrative remedies shall not be raised if a petitioner declines to utilize these procedures and instead elects to pursue judicial remedies following the denial of the petition. The time period for seeking judicial relief following denial of those matters contemplated by subsection (a)(2) of this section shall run from the time the Board votes on such matter, and a motion hereunder shall not alter such time period. (h) [Initial vote.] Where the initial vote was made after an advertised public hearing, any reconsideration of such vote shall comply with all advertisement and notice provisions that were legally required for the initial public hearing. tJf't:. No, "O'-d No- 88-41. q i_ f111 -a' 6,. Packet Page -282- 10/28/2014 10.A. SmithCamden From: KlatzkowJeff Sent: Tuesday, October 14, 2014 9:14 AM To: CoyleFred; FialaDonna; HenningTom; HillerGeorgia; NanceTim Cc: OchsLeo Subject: FW: Purchasing Ordinance - Bank Services Contract Motion Attachments: Frankenmuth.doc Commissioners: Please consider this a one -way communication. -Jeff From: Klatzkow3eff Sent: Friday, October 03, 2014 11:16 AM To: HillerGeorgia; GEORGIA HILLER Cc: HayesKaren Subject: Purchasing Ordinance - Bank Services Contract Motion Commissioner: With respect to Item 13A of September 23`d,s Board meeting, in which the Clerk "Recommended the Board of County Commissioners (Board) approve the attached newly proposed three -party agreement for Banking Services between the Clerk, the Board and First Integrity Bank and acknowledge any waivers of the Board's Purchasing Policy as the solicitation was made in accordance with the Clerk's purchasing policy," my thought process was as follows: 1. The Florida Supreme Court in Frankenmuth determined that a governing body has the ability to ratify an unauthorized :ontract provided that (1) the Board initially has the power to enter into such an agreement; (2) that the ratification be conducted in the lame manner as if the agreement had initially come to the Board; and (3) that the Board has full knowledge of the material facts related to the agreement. 2. The Purchasing Ordinance, which was derived from the County's long - standing Purchasing Policy, provides in relevant part as follows: Sec. 2 -195. - Competitive Bid Process. E. Waiver of Irregularities: The Board of County Commissioners shall have the authority to waive any and all irregularities in any and all formal bids within lawful guidelines. (Ord. No. 2013 -69, § 10) Sec. 2 -215. - Waiver of Ordinance. The Board of County Commissioners shall have the authority to waive any and all Purchasing Ordinance provisions within lawful guidelines and upon formal Board action. (Ord. No. 2013 -69, § 30) Lawful guidelines as forth in Florida Statutes include (by analogy): Florida Statute Sec. 255.20 Local bids and contracts for public construction works; specification of state- produced lumber. (c) The provisions of this subsection do not apply: 1. If the project is undertaken to replace, reconstruct, or repair an existing public building, structure, or other public construction works damaged or destroyed by a sudden unexpected turn of events such as an act of God, riot, fire, flood, accident, or other urgent circumstances, and such damage or destruction creates: a. An immediate danger to the public health or safety; b. Other loss to public or private property which requires emergency government action; or c. An interruption of an essential eovemmental service. Packet Page -283- 10/28/2014 10.A. Moreover, the Purchasing Ordinance grants the County Manager great discretion to enter into agreements if exigent circumstances or an emergency exists. Since the County Manager has only that power delegated to him by the Board, the Board also has like power to act. Sec. 2 -21C. - Exigent Circu�m�stances, Emergency and Board Absence Purchases. In case of an exigent circumstance, which is defined as any circumstance requiring immediate action or attention, a valid public emergency, or during the Board's extended recess session(s) (all efforts should be made to obtain Board approval prior to anticipated recesses) whereby a purchase is necessary, the County Manager shall authorize the Purchasing Director to secure by open market procedure as herein set forth, any commodities or services. The County Manager shall have the authority to take actions including, but not limited to the issuance of contracts, change orders, and/or supplemental agreements. Any action shall be reported at the first available meeting of the Board of County Commissioners. The County Manager under the same consultations noted above shall further be authorized to approve payment(s) to vendors at the time of or shortly after purchase should the circumstances warrant. These payments shall be reported at the first available meeting of the Board. (Ord. No. 2013 -69, § 25) It is my opinion that a bank depository is an essential governmental service, and that facing the expiration of an existing depository agreement without a replacement depository bank in place constitutes an exigent circumstance. I had several discussions with the County Manager prior to this September 23rd meeting. I asked Leo several times whether he could secure an extension of the current agreement with Fifth - Third. At the time of the September 23rd meeting, my understanding was that the best Mr. Ochs could then do was to get the Board at the September 23" meeting to sign a letter requesting Fifth -Third grant an extension, which Fifth -Third would consider with no assurance that they would positively act on it. There was no Executive Summary on the published September 23rd agenda seeking such a letter, nor was such a request made on the Change Sheet When the Clerk initially came forward with an agreement between the Clerk and First Integrity, asking in essence that the Board ratify his agreement, I stated that I would not sign off for legality. In that agreement the Board was not a party, and there was no protection for the Board should it take the requested action. When the Clerk amended the agreement to include the Board as a party, the agreement then fell within the confines of both the Frankenmuth decision and the Board's Purchasing Ordinance. The alleged irregularities of the process were discussed in detail during two public meetings. The Board, with full knowledge of the irregularities, had the lawful ability to waive any and all requirements and irregularities under the Purchasing Ordinance. The Board's decision was further bolstered by the fact that there was no substitute depository bank in place (which constituted an exigent circumstance as well as the loss of an essential government service), nor was there any requested action on the Agenda that the Board send a letter request to Fifth Third seeking an extension, which requested action would have given the Board the opportunity to continue this item one meeting. With this background, I prepared a proposed motion that the Chair could use provided the public hearing be consistent with the above. The purpose of the motion was to capture the considerations set forth above, in order to give the Board maximum protection against any claim should the Clerk's request be approved by majority vote. With respect to your question regarding the meeting, at Commissioner Fiala's request Leo and I met with Crystal and Derek Johnssen on September 15`h. The primary issue was what could be done to get an acceptable Bank depository agreement to the Board. The three party agreement, as modified with staffs' input, resulted from this meeting. Jeffrey A. Klatzkow County Attorney (239) 252 -2614 - - - -- Original Message---- - From: HillerGeorgia Sent: Friday, October 03, 2014 7:55 AM To: KlatzkowJeff Cc: HayesKaren Subject: Purchasing Ordinance - Bank Services Contract Motion Jeff, Please email the specific section of the purchasing ordinance that you relied on for allowing the board to waive the purchasing ordinance by motion due to exigent circumstances. Did you verify that exigent circumstances existed? If so, how? Packet Page -284- 10/28/2014 10.A. Please provide the specific law that you relied on to allow the board to waive procurement irregularities with respect to the bank services solicitation and contract. Please provide a memo detailing your conversation in the meeting with you, Leo and the Clerk's staff ahead of the last board meeting where you determined how to craft the motion you then advised Commissioner Henning to make. When and where was that meeting held? Who was in attendance? With thanks, Commissioner Georgia Hiller Sent from my iPad Under Florida Law, e -mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by telephone or in writing. Packet Page -285- LexisNexis 0 FOCUS - 20 of 24 DOCUMENTS FRANKENMUTH MUTUAL INSURANCE COMPANY, etc., Appellant, vs. ERNIE LEE MAGAHA, etc., et al., Appellees. No. SC96384 SUPREME COURT OF FLORIDA 769 So. 2d 1012; 2000 Fla. LEXIS 1889; 25 Fla. L. Weekly S 697 September 21, 2000, Decided PRIOR HISTORY: [ * *1] Certified Question of Law from the United States Court of Appeals for the Eleventh Circuit - Case No. 98 -2962. COUNSEL: J. Lofton Westmoreland and William R. Mitchell of Moore, Hill, Westmoreland, Hook & Bolton, P.A. for Appellant. Paula G. Drummond, Pensacola, Florida, on behalf of Appellee Ernie Lee Magaha; and David G. Tucker, Ja- net Lander, and James M. Messer, Pensacola, Florida, on behalf of Appellee Escambia County, Florida, for Ap- pellees. Carole Sanzeri, Senior Assistant County Attorney, Pi- nellas County Attorney's Office, Clearwater, Florida, for the Florida Association of County Attorneys, Inc., Ami- cus Curiae. JUDGES: LEWIS, J., WELLS, C.J., and SHAW, HARDING, ANSTEAD, PARIENTE and QUINCE, JJ., concur. OPINION BY: LEWIS OPINION [ *1014] LEWIS, J. We have for review two questions of Florida law certified by the United States Court of Appeals for the Eleventh Circuit as determinative of a cause pending before that court and for which there is no controlling precedent. Specifically, the Eleventh Circuit has certified the following questions to this Court: 10/28/2014 10.A. Page 1 (1) UNDER FLA. STAT. § 125.031, WHICH REQUIRES AP- PROVAL OF THE BOARD OF COUNTY COMMISSIONERS FOR CERTAIN LEASE - PURCHASE [ * *2] AGREEMENTS, CAN A COUNTY BE HELD TO HAVE APPROVED A CONTRACT ABSENT FORMAL RES- OLUTION AND BASED SOLELY ON ACTS AND OMISSIONS OF THE COUNTY COMMISSION? IF SO, WHAT STANDARD GUIDES THE CONSIDERATION OF WHETHER A COUNTY COMMISSION HAS "AP- PROVED" A CONTRACT OR AGREEMENT? (2) IF THE LEASE - PURCHASE AGREEMENT HAS BEEN APPROVED, DOES THE NON - SUBSTITUTION CLAUSE IN THE LEASE - PURCHASE AGREE- MENT THAT PROVIDES FOR A PENALTY UPON NON - APPROPRIATION AND EX- PLICITLY DISCLAIMS USE OF REV- ENUES FROM AD VALOREM TAXA- TION VIOLATE . ARTICLE VII, § 12, OF THE FLORIDA CONSTITUTION? Frankenmuth Mutual Insurance Co. v. Magaha, slip op., No. 98 -2962, slip op. at 10 (11th Cir. Aug. 25, 1999). We have jurisdiction. See art. V, § 3(b)(6), Fla. Packet Page -286- 10/28/2014 10.A. Page 2 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 Const. As more fully explained below, we answer the Note 2: One payment first certified question in the affirmative and determine of $ 200,000, two pay - that a board of county commissioners may approve a ments of $ 120,000, three lease - purchase agreement under section 125.031, Florida payments of $ 134,964, Statutes (1999), even absent formal resolution, if such and a final payment of $ board is not required by local ordinance or charter to take 319,743. action by formal resolution, as is the status of the local Note 3: One payment charter here. Further, we outline a three -prong test to of $ 200,000, six payments [ * *3] guide courts in determining whether an approval of $ 419,008 and a final without formal resolution has occurred. Finally, we also payment of $ 827,860. answer the second certified question in the affirmative, as rephrased below, and determine that the nonsubstitution clause implicates article VII, section 12 of the Florida Constitution, notwithstanding the attempt- Flowers signed each of these agree - ed disclaimer. ments as "Escambia County Comptroller." Although he warranted in paragraph 20 of I. FACTS AND PROCEDURAL HISTORY the master lease that he had obtained a resolution of the "governing body" of the On September 6, 1995, Frankenmuth Mutual In- jurisdiction authorizing him to execute the surance Company (Frankenmuth) filed a two -count lease, in fact, Flowers neither requested complaint in the [ *1015] United States District Court Es- nor obtained the permission of the Es- for the Northern District of Florida, Pensacola Division, cambi a County Board of County Com- cambia Iam against both Escambia County, Florida, and Ernie Lee ners ("the Board" or "the County Magaha (Magaha), the Clerk of the Circuit Court for Commission ") _before signing the agree - Escambia County. Frankenmuth sought declaratory ment. relief in Count I of the complaint and injunctive relief in Count II. All three parties moved for summary judgment The master lease contains a number after participating in discovery, and the federal district of provisions relevant [ * *5] to this dis- court set forth the following facts in considering the par- pute. Paragraph 21 includes a ties' motions: "non- appropriation clause," which pro- vides the lease will terminate in any given year if the "legislative body or funding authority" fails to appropriate funds to In May 1992 Escambia County make the lease payments. The same para- Comptroller Joe Flowers signed a master graph also contains a "non- substitution lease agreement with Unisys Leasing clause," providing that, in the event of Corporation ( "Unisys "), under schedule non- appropriation, Flowers agrees not to 01 of which, Flowers agreed to purchase or rent any substitute computer lease - purchase a Unisys Model A -11 equipment for the balance of the appro- mainframe computer. [ * *4] ' The priation period and the one following it. schedule called for seven annual pay- Finally, an addendum clarifies that noth - ments totaling $ 2,353,814.1 In July 1993, ing in the lease shall be construed to con - the parties signed a second schedule stitute a pledge of ad valorem taxes and agreeing to add a Unisys imaging system that, in the event of default, the Lessor has for eight annual payments totaling $ no right to compel the County Commis - 1,164,635.2 In May 1994, the parties sion to appropriate funds to make the signed a third schedule adding further lease payments. equipment and restructuring the finance The agreement continued without in- arrangement for schedule 01. This third cident for several years after it was exe- aped schedule called for eight annual payments cuted. Flowers used the equipment for a totaling $ 908.3 variety of municipal functions, including Note 1: Six payments of county payroll and central data processing services for the County Commission as $ 304,112 and one pay- well as the Road, Mass Transit and Solid ment of $ 529,142. Waste Departments. (Ken Gardner Depo. Packet Page -287- 10/28/2014 10.A. Page 3 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 23 -24). In 1992 Unisys sold and assigned the lease to Chicorp Financial Services, Inc. Chicorp, in turn, sold it to Franken- muth Mutual Insurance [ * *6] Company ( "Frankenmuth ") - -the [ *1016] current owner of the lease and the plaintiff in this case. Although the County Commission and Flowers both regarded the Comptrol- ler to be a fee officer 4 rather than a budget officer, the evidence shows Flow- ers submitted his budget to the County Commission each year setting forth the fees he anticipated collecting, the expens- es he anticipated incurring and any antic- ipated shortfall between the two. Each year Flowers requested [that] the County Commission appropriate funds to cover the shortfall, which for fiscal years ending 1992, 1993 and 1994, amounted to roughly half the Comptroller's total budg- et. In each of those years, Flowers listed, respectively, $ 301,563, $ 304,561 Z and $ 304,113 as a budget expense titled "Debt Service -- Computer." Each year, the Board appropriated Flowers' requested funds without question. 3 Note 4: Under Florida law, "fee of- ficers" are ones "assigned specialized functions within county government and whose budgets are established inde- pendently of the local governing body, even though said budgets may be reported to the local governing body or may be composed of funds either generally or specifically [ * *7] available to a local governing authority involved." § 218.31(8), Fla. Stat. (1993). The County Commission had no di- rect knowledge of the Unisys computer equipment, however, until it began dis- cussing implementing its own computer network system in 1993. By letter dated August 3, 1993 Flowers wrote to the Board's chairperson explaining his office already had a central data processing sys- tem and that the Board should adjust its plans to integrate that system. At a June 28, 1994 meeting the County Commission voted to amend its technology plan to make use of the Comptrollers computer equipment. In late 1994, Flowers became the subject of considerable controversy when Escambia County lost millions of dollars in bad derivative investments made by Flowers' office. The political uproar led to a grand jury investigation and, eventually, a four -count indictment charging Flowers with malfeasance. Count Four specifically charged Flowers with malfeasance for entering into the Unisys lease in violation of Florida law. Flowers pled no contest and resigned from office. Thereafter, on August 1, 1995, the Florida Legislature abolished the Office of Escambia County Comptroller [ * *8] by repealing the Special Act that had cre- ated it. See Ch. 95 -529, Laws of Fla. As a result, Escambia County's elected Clerk of the Circuit Court, Ernie Lee Magaha, became responsible for the constitutional duties formerly held by the Office of Comptroller. 5 In the aftermath of these events, Magaha and the County Commis- sion obtained and reviewed, for the first time, the Unisys master lease and sched- ules signed by Flowers. After investiga- tion and discussion, the County Commis- sion determined the Unisys equipment was too old, too big, too expensive and too ineffective to serve the County's needs. The County Commission therefore advised Frankenmuth it [ *1017] would not make the 1995 schedule 02 and schedule 03 payments of, respectively, $ 120,000 and $ 419,000. The Commission further advised Frankenmuth it consid- ered the lease void and unenforceable due to Flowers' failure to obtain approval be- fore signing it Note 5: In most Florida counties, the Clerk of the Circuit Court serves a dual function: he or she manag- es the circuit and county court system and serves as "ex officio clerk of the board of county commis- sioners, auditor, recorder and custodian of all county funds." [ * *9] See Fla. Const. art. VIII, § 1(d). The Florida Constitution also provides, however, that individual counties may choose to divide the Packet Page -288- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 Clerk's duties between two county officers, one man- aging the courts and the other serving as custodian of county funds. Fla. Const. art. V, § 16. In 1972, Escambia County chose to divide the duties between two elected offic- ers: a Clerk of the Circuit Court and a Comptroller. See Ch. 73 -455, Laws of Fla. When the Legislature abolished that Act, the du- ties of the Comptroller re- verted to the Clerk of Court. Consequently, in September 1995, Frankenmuth filed this suit asking the court to declare the lease agreement valid and enforceable and to enjoin the County Commission and the Clerk of Court (as constitutional successor to the Comptrol- ler) from breaching the agreement. While the case proceeded through discovery, the County Commission purchased, in April 1996, a replacement computer system. As a result, Frankenmuth now seeks declar- atory relief only. These motions for sum- mary judgment followed. Frankenmuth Mut. Ins. Co. v. Magaha, 1996 U.S. Dist. LEXIS 15930, 10 Fla. L. Weekly Fed. D 340, D 340 (N.D. Fla. Aug. 30, 1996). 1 According to the master lease agreement, ti- tle to the computer equipment vested in Flowers, the lessee, with Unisys retaining a security inter- est in the equipment and the right to repossess the equipment. Also under the master lease agree- ment, Flowers generally accepted responsibility for all risks related to the equipment. An adden- dum executed by the parties in September 1992 abolished Unisys' security interest in the equip- ment and its right to repossess the equipment, in- stead substituting other available remedies in the event of default, including seeking compensatory damages from the lessee should the lessee refuse to (1) sell the equipment; or (2) voluntarily return 10/28/2014 10.A. Page 4 the equipment (with legal and beneficial title) to the lessor. [ * *10] 2 The actual amount listed in Flowers' letter to the Board of County Commissioners dated May 8, 1992, for "Debt Service - Computer" actually was $ 301,561, not $ 304,561. 3 Flowers' budget request for the fiscal year ending September 30, 1992, was made by letter dated June 6, 1991, almost one year before the agreement with Unisys was executed. Further, the amount listed in the 1991 budget request for "Debt Service - Computer" was $ 301,563, simi- lar to the annual payments called for under the Unisys lease agreement. Finally, Flowers' budget request for the fiscal year ending September 30, 1993, was made by letter dated May 8, 1992, also before the agreement with Unisys was executed. As noted in footnote 2, supra, the amount listed in the 1992 budget request for "Debt Service - Computer" was $ 301,561, similar to the annual payments called for under the yet- to -be- executed Unisys lease agreement. After considering the above - listed facts, the federal district court made several determinations. See 1996 U.S. Dist. LEXIS 15930, *19 -24, 10 Fla. L. Weekly Fed. at D 341 -43. First, [ * *11] the court determined that even though the County Commission had not approved the lease - purchase agreement prior to its execution as re- quired by section 125.031, Florida Statutes (1993), the Commission had subsequently approved the agreement by (1) appropriating funds to pay for computer equip- ment; (2) voting to change its own technology plan to integrate the computer equipment; and (3) taking no ac- tion after learning that an elected official in Escambia County had entered into a lease - purchase agreement in possible violation of section 125.031. ° See Franken- muth, 1996 U.S. Dist. LEXIS 15930, *20, 10 Fla. L. Weekly Fed. at D 341. Second, the court determined that the agreement's nonsubstitution clause rendered illusory both the nonappropriation clause and the express dis- claimer regarding ad valorem taxation, thus causing the agreement to be void as violative of article VII, section 12 of the Florida Constitution. See Frankenmuth, 1996 U.S. Dist. LEXIS 15930, *20 -22, 10 Fla. L. Weekly Fed. at D 341 -42. Third, the court determined that the nonsubstitution clause was void as against public policy because the clause "effectively contracted [ * *12] away the taxpayers' right to a central data processing [ *1018] system for up to two years." See 1996 U.S. Dist. LEXIS 15930, *22, 10 Fla. L. Weekly Fed. at D 342. However, the court further determined that the nonsubstitution clause was properly severable from the remainder of the agreement. See id. Finally, the court determined that Magaha had no contractual obligations to Franken- Packet Page -289- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 muth. See 1996 U.S. Dist. LEXIS 15930, *23 -24, 10 Fla. L. Weekly Fed. at D 343. In accordance with theses determinations, the district court declared: Escambia County's Board of County Commissioners ratified the lease and all schedules between Unisys and Joe Flowers, the Comptroller of Escambia County. As the County Commission has failed to appropriate funds to make the lease payments, Frankenmuth may exer- cise its rights under the non - appropriation clause in paragraph 21 [of the lease- purchase agreement]. Franken- muth may not enforce the non - substitution clause, however, because it is void for violation of Article VII, § 12 of the Florida Constitution and for viola- tion of public policy. Frankenmuth has no contractual rights against Ernie Lee Magaha, Escambia County's [ * *13] Clerk of the Circuit Court. 1996 U.S. Dist. LEXIS 15930, *23 -24, 10 Fla. L. Weekly Fed. at D 343. Frankenmuth appealed to the Eleventh Circuit, and Escambia County cross - appealed. See Frankenmuth, No. 98 -2962, slip op. at 2 4 To support this third finding, the federal dis- trict court stated: "The evidence shows the ac- counting firm of Saltmarsh, Cleveland & Gund advised the County Commission through a 1994 independent audit that an elected official of the county had entered into a long -term lease agree- ment in possible violation of section 125.031." Frankenmuth Mut. Ins. Co. v. Magaha, 1996 U.S. Dist. LEXIS 15930, 10 Fla. L. Weekly Fed. D 340, D 341 (N.D. Fla. Aug. 30, 1996). The record shows that the independent auditing report stated, "Elected officials of the County have en- tered into lease purchase arrangements to obtain need property and equipment ... [that] appear to fall within the category of transactions 'which must be approved by the governing body of the County." This language is almost identical to that contained in the same auditing firm's 1991 report, which also did not specify what officials had en- tered into lease- purchase agreements in possible violation of section 125.031. 10/28/2014 10.A. Page 5 [ * *14] On appeal, the Eleventh Circuit discussed the issues regarding the execution of the lease - purchase agreement and the validity of the nonsubstitution clause. See id. at 5 -9. After discussing these issues, that court certified for this Court's consideration the two questions of law set forth above. Id. at 10. We now address those questions in turn. H. ISSUES AND ANALYSIS A. THE FIRST CERTIFIED QUESTION In the first certified question, the Eleventh Circuit has asked us to determine whether, consistent with the requirements of section 125.031, Florida Statutes, a board of county commissioners may approve a lease - purchase agreement absent formal resolution, and, if so, what standards guide consideration of whether such an approval has occurred. As explained below, we de- termine that a board of county commissioners may ap- prove a lease - purchase agreement under section 125.031, even absent formal resolution, if a governing charter or ordinance does not require the board to take action by formal resolution, as is the situation here. 5 Further, we provide a three -prong [ * *15] test to guide the determi- nation process as to whether an approval without formal resolution has occurred. Before we reach the first certi- fied question, however, we must first address Franken- muth's argument that Flowers, as the Comptroller of Escambia County, had the independent authority to enter into the agreement with Unisys even absent any approval whatsoever by the Escambia County Board of County Commissioners (the Board). If Frankenmuth's argu- ment on this point is correct, then we need not reach the first question certified by Eleventh Circuit. 5 The parties have not referred us to any provi- sion in the Escambia County Code requiring the Board to take action in some specified manner. After careful consideration, we find Frankenmuth's argument regarding Flowers' independent authority to bind the governmental entity to be without merit. It is clear that Flowers, as Comptroller of Escambia County, was a constitutional officer under the Florida Constitu- tion. See art. V, § 16, Fla. Const.; art. VIII, § [ * *16] 1(d), Fla. Const.; see also Alachua County v. Powers, 351 So. 2d 32, 35 -43 (Fla. 1977). It does not follow, however, that Flowers had the independent authority to enter into the agreement at issue here. As we noted in Powers, the clerk of the circuit court-or the comptroller if duties are divided between two offices- derives author- ity and responsibility from both "constitutional and stat- utory provisions." Powers. 351 So. 2d at 35: see also Escambia County v. Flowers, [ *1019] 390 So. 2d 386, 387 (Fla. 1st DCA 1980) (stating that Flowers' duties as Packet Page -290- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 comptroller were enumerated by legislative prerogative); cf. State v. Walton County, 93 Fla. 796, 800, 112 So. 630, 632 (1927) (noting that "[T]he board of county commissioners of each county are constitutional officers, and under the terms of the Constitution their powers and duties shall be fixed and prescribed the Legislature. "); Weaver v. Heidtman, 245 So. 2d 295, 296 (Fla. lst DCA 1971) (observing that counties are "subject to legislative prerogatives in [ * *17] the conduct of their affairs "). By enacting section 125.031, the Legislature clearly estab- lished that agreements such as the one at issue here may not be entered into without approval by a board of coun- ty commissioners. This is not an instance where the clerk of the circuit court is acting as an arm of the judi- cial branch and thus under judicial control and not the control of the Legislature. See Times Publishing Co. v. Ake, 660 So. 2d 255, 257 (Fla. 1995). Therefore, the Legislature's pronouncement in section 125.031 is con- trolling here, and Flowers did not have the independent authority to enter into the agreement with Unisys without the approval of the Board. 6 6 It is interesting to note that Flowers entered a nolo contendere plea to the charge of violating section 125.031, Florida Statutes; if Franken- muth's argument were correct, then Flowers' plea would have responded to a charge having abso- lutely no basis in law. Further, Frankenmuth's argument on this point is inconsistent with lan- guage contained in the underlying agreement, which stated in paragraph 20(b): "Lessee [Flow- ers] has been duly authorized by the Constitution and laws of the applicable jurisdiction and by resolution of its governing body (which resolu- tion, if requested by Lessor, is attached hereto), to execute and deliver this Lease and to carry out its obligations hereunder." If Frankenmuth's argu- ment regarding Flowers' authority were correct, the language in the agreement regarding a resolu- tion by the governing body of the jurisdiction would be superfluous and meaningless. [ * *18] Turning now to the first question certified by the Eleventh Circuit, we must consider the text of section 125.031, Florida Statutes (1999):' Counties may enter into leases or lease- purchase arrangements relating to properties needed for public purposes for periods not to exceed 30 years at a stipu- lated rental to be paid from current or other legally available funds and may make all other contracts or agreements necessary or convenient to carry out such 10/28/2014 10.A. Page 6 objective. The county shall have the right to enter into such leases or lease - purchase arrangements with private individuals, other governmental agencies, or corpora- tions. When the term of such lease is for longer than 60 months, the rental shall be payable only from funds arising from sources other than ad valorem taxation. Such leases or lease - purchase arrange- ments shall be subject to approval by the board of county commissioners, and no such lease or lease - purchase contract shall be entered into without said approval. It is undisputed in this case that Flowers failed to obtain the express or formal "approval" [ * *19] of the Es- cambia County Board of County Commissioners (the Board) before entering into the agreement with Unisys. Therefore, the initial question we must answer is whether the Board had the power to approve the agreement after it was executed. We determine that Florida law clearly establishes that the Board had the power to approve, or, stated another way, ratify, that which was initially an unauthorized agreement after it had been executed. See, e.g., Ramsey v. City of Kissimmee, 139 Fla. 107, 111 -13, 190 So. 474, 476 -77 (1939); Brown v. City of St. Peters- burg, 111 Fla. 718, 720, 153 So. 140, 140 (1933); cf. City of Panama City v. T & A Util. Contractors, 606 So. 2d 744, 747 (Fla. [ *1020] 1st DCA 1992) (holding that city ratified city manager's unauthorized termination of contract between city and third party); Tolar v. School Board of Liberty County, 398 So. 2d 427, 428 -29 (Fla. 1981) (finding that municipality's action taken in.viola- tion of Sunshine Law could be later ratified if taken in accordance with such law); see generally l0A Eugene McQuillin, The Law of Municipal Co7porations, § 29.104 at 63 [ * *20] (3d ed. 1999) ( "It is a general rule that whatever acts public officials may do or authorize to be done in the first instance may subsequently be adopt- ed or ratified by them with the same effect as though properly done under previous authority. "). The disposi- tive question thus becomes, what constitutes "approval" by the Board within the meaning of section 125.031? 7 We quote the current version of the statute because the Legislature has not amended the stat- ute since 1989. See ch. 89 -103, § 1, at 279, Laws of Fla. Thus, the current version of the statute is the same as the version in effect at the time the events in the present case transpired. Section 125.031 does not define the term "approval" as used in the statute, nor does the legislative history underlying the statute shed any light on the matter. N Un- der such circumstances, we must give the statutory ]an- Packet Page -291- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 guage its plain and ordinary meaning. See, e.g., [ * *21] Green v. State, 604 So. 2d 471, 473 (Fla. 1992) ( "One of the most fundamental tenets of statutory construction requires that we give statutory language its plain and ordinary meaning, unless words are defined in the statute or by the clear intent of the legislature. "). In ascertaining the plain and ordinary meaning of a term, reference may be made to a dictionary. See id. ( "If necessary, the plain and ordinary meaning of the word can be ascertained by reference to a dictionary. "). 8 The Legislature created section 125.031, Florida Statutes, in 1971, see chapter 71 -240, section 1, at 1318 -19, Laws of Florida, and, as stated in footnote 6, supra, has amended the stat- ute only once since that time. See Ch. 89 -103, § 1, at 279, Laws of Fla. (increasing time period implicating statute from 24 to 60 months). How- ever, no legislative history surrounding these amendments sheds light on the meaning of the term "approval" as used in the statute. [ * *22] In its opinion, the federal district court de- fined "approve" as "to have or express a favorable opin- ion of or "to accept as satisfactory." Frankenmuth, 10 Fla. L. Weekly Fed. at D341 (quoting Webster's Ninth New Collegiate Dictionary at 98 (Merriam- Webster Inc. 1991)). In addition to the definition adopted by the fed- eral district court, the dictionary definition of "approve" also includes "to give formal or official sanction to." Webster's Tenth Collegiate Dictionary at 57 (Merri- am- Webster Inc. 1996). Thus, the dictionary shows that the term "approve" may consist of either an informal or formal expression of assent. Florida case law ' also establishes that an approval or ratification can occur without formal resolution. For example, in Deutsche Credit Corp. v. Peninger, 603 So. 2d 57, 58 (Fla. 5th DCA 1992), the court stated, "Ratifi- cation of an agreement occurs where a person expressly or impliedly adopts an act or contract entered into in his or her behalf by another [ * *23] without authority." Similarly, in City of Panama City, the First District de- termined that the city commission had ratified the city manager's unauthorized termination of a contract be- tween the city and a third party -even though the city commission did not pass a formal resolution terminating the contract -where the city commission knew the reasons for the termination and then voted to award the contract to a third party. See 606 So. 2d at 747; see generally l0A McQuillin, § 29.106 at 82 (stating that ratification of a municipal contract may occur "by the affirmative action of the proper officials, or by any action or non - action which in the circumstances amounts to approval of the contract "): cf. hillearn Properties, Inc. v. Citv of Tal- lahassee, 366 So. 2d 172 (Fla. 1st DCA 1979) (employ- 10/28/2014 10.A. Page 7 ing doctrine of estoppel to bar city from challenging va- lidity of agreements on grounds of lack of proper formal- ities in the passage [ *1021] of such agreements). As a result, we determine that the term "approval" as used in section 125.031 does not require a board [ * *24] of county commissioners to pass a formal resolution, unless passage of such a resolution is required by the governing law of the county. 10 We do note, however, that several principles must be satisfied before a board of county commissioners may be deemed to have approved an agreement absent formal resolution. 9 See, e.g., State v. Mitro, 700 So. 2d 643, 645 (Fla. 1997) ( "In the absence of a statutory defini- tion, resort may be had to case law or related statutory provisions which define the term .... "). 10 We recognize that in reaching its decision in City of Panama City, the First District distin- guished the process of ratifying entry into an agreement from the process of ratifying the ter- mination of an agreement. See 606 So. 2d at 747. However, the different policy concerns implicat- ed in those distinguishable processes does not al- ter the conclusion that an approval or ratification of an agreement may occur absent formal resolu- tion where the governing law of the county does not require action by formal resolution. [ * *25] First, we determine that an approval absent formal resolution must be made in compliance with Florida's Sunshine Law, which is of both constitutional and statutory dimension. See art. I, § 24(b), Fla Const.; § 286.011(1), Fla. Stat. (1999). Under the Sunshine Law, any meeting at which official acts are to be taken must be open to the public, and no "resolution, rule or formal action shall be considered binding except as taken or made at such meeting." § 286.011(1), Fla. Stat. (1999); see also, e.g., Zorc v. City of Vero Beach, 722 So. 2d 891, 896 (Fla. 4th DCA 1998) (interpreting Sunshine Law). As we previously have stated, "The intent of [the Sunshine Law] is to cover any gathering of the members of the Board where the members deal with some matter on which foreseeable action will be taken by the Board." Tolar, 398 So. 2d at 428. Thus, for a board of county commissioners to approve a lease or lease - purchase agreement in accordance with section 125.031, we find it necessary that such approval [ * *26] be made "in the sunshine." If an "approval" by a board of county commissioners of a lease or lease purchase agreement under section 125.031 must be made in accordance with the Sunshine Law, it necessarily follows that any subsequent ratifica- tion of such an agreement must also be made in compli- ance with the Sunshine Law. This is so because we have Packet Page -292- 10/28/2014 10.A. Page 8 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 recognized that for a local government to properly ratify a previously executed, unauthorized agreement, the agreement must be ratified "in the same manner ... in which it might have been originally adopted." Ramsey, 139 Fla. at 113, 190 So. at 477; see also Broward County v. Conner, 660 So. 2d 288, 290 (Fla. 4th DCA 1995) (interpreting Sunshine Law) ( "If the county could not have entered into this contract without action taken at a meeting, it necessarily follows that the actions of the county's attorneys could not bind the county to specific performance of a contract in the absence of proper com- mission approval. "). As stated by the First District in City of Panama City, the apparent policy justification [ * *27] for the requirement set forth in Ramsey is that "taxpayers should not be held accountable on a contract unless the contract has been entered into according to the strict letter of the law. Otherwise, corrupt (or merely inept) public officials could subject the public to untold financial liability." 606 So. 2d at 747. Second, in addition to the requirement that a subse- quent approval in the form of ratification be made "in the sunshine" in the same manner that a formal approval would have required, there are several other general principles undergirding the concept of ratification war- ranting our attention. In the vintage opinion of Ball v. Yates, 158 Fla. 521, 527, 29 So. 2d 729, 732 (1946), this Court stated, "Before ratification will be implied of an act of an unauthorized agent it must be made to appear that the principle has been fully informed and that he has approved." In Peninger, 603 So. 2d at 58, the Fifth Dis- trict Court of Appeal expounded upon the general pro- nouncement made by this Court in Ball: [ * *28] [ *1022] An agreement is deemed ratified where the principal has full knowledge of all material facts and circumstances relating to the unauthorized act or transaction at the time of the ratifi- cation. G & M[v. Tropical Music Serv.], 161 So. 2d [5561 at 558. See also Ball v. Yates, 158 Fla. 521, 29 So. 2d 729 (1946), cert. den., 332 U.S. 774, 68 S. Ct. 66, 92 L. Ed. 359 (1947); Pedro Realty Inc. v. Silva, 399 So. 2d 367 (Fla. 3d DCA 1981); Bach v. Florida State Bd. of Den- tistry, 378 So. 2d 34 (Fla. 1st DCA 1979). An affirmative showing of the principal's intent to ratify the act in question is re- quired. [Carolina - Georgia Carpet & Textiles, Inc. v. ] Pelloni, 370 So. 2d 450 at 452. Moreover, the issue of whether an agent's act has been ratified by the princi- pal is a question of fact. One Hour Valet of America, Inc. v. Keck, 157 So. 2d 83 (Fla. 2d DCA 1963). Regarding the "full knowledge" requirement discussed in Peninger, the First District stated the following in Bach v. Florida State Board of Dentistry, 378 So. 2d 34, 36 -37 (Fla. 1 st DCA 1979): [ * *29] Before one may infer that a principal ratified an unauthorized act of his agent, the evidence must demonstrate that the principal was fully informed and that he approved of the act. Ball v. Yates, 158 Fla. 521, 29 So. 2d 729, 732 (1946). It is generally the rule that the doctrine of constructive knowledge does not apply to bring about ratification. The principal is charged only upon a showing of full knowledge, and not because he had notice which should have caused him to make inquiry, which in turn would have brought to his attention the knowledge of the un- authorized act of the employee. 2 Fla. Jur. 2d, Agency and Employment, § 52 at page 204 (1977).... There is no duty imposed upon the principal to make inquiries as to whether his agent has carried out his re- sponsibilities. The principal "has a right to presume that his agent has followed in- structions, and has not exceeded his au- thority." Oxford Lakeline v. First Nat. Bank, 40 Fla. 349, 24 So. 480, 483 (1898). And, [ * *30] Packet Page -293- [w]henever he is sought to be held liable on the ground of ratification, ei- ther express or implied, it must be shown that he rati- fied upon full knowledge of all material facts, or that he was willfully ignorant, or purposely refrained from seeking information, or that he intended to adopt the unauthorized act at all events, under whatever circumstances. Id. 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 Based on the above principles well established in Florida jurisprudence, we determine that a three -prong test is appropriate for determining whether an af- ter- the -fact "approval," or ratification, has occurred in satisfaction of section 125.031, Florida Statutes. First, a board of county commissioners must have the power to approve the agreement. " See, e.g., P.C.B. Partnership v. City of Largo, 549 So. 2d 738, 740 (Fla. 2d DCA 1989) (determining that city did not have authority to enter into an agreement that effectively contracted away the city's police powers). Second, a board of county commission- ers must ratify an agreement in the same manner in which the agreement would have been [ * *31] initially approved. For example, as we stated above, the approval must be made in accordance with the "Sunshine Law." Additionally, where a charter or ordinance requires a board of county commissioners to take action in a speci- fied manner, such as by passing a formal resolution (un- like the circumstances here), [ *1023] then an af- ter- the -fact approval must satisfy the specified manner to be valid. See Ramsey, 190 So. at 476 -77, 139 Fla. at 111 -13 (involving city charter requiring the city com- mission to take action on certain contracts by ordinance or resolution). Finally, in ratifying the agreement in the same manner in which it initially could have been ap- proved, a board of county commissioners must have full knowledge of the material facts relative to the agreement. As we have not been asked to determine whether a prop- er ratification occurred in this case, we leave that ques- tion open for determination by the Eleventh Circuit based on the principles set forth above. 11 As will be addressed in our discussion con- cerning the second certified question, Escambia County argues that the first prong of this test has not been met here because the Escambia County Board of County Commissioners allegedly did not have the power to initially approve the agreement. Specifically, Escambia County argues that (1) the agreement, based on its nonsubstitution clause, required approval by vot- er referendum due to its alleged practical long -term impact on ad valorem taxes; and (2) the nonsubstitution clause is not severable from the agreement. [ * *32] B. THE SECOND CERTIFIED QUESTION The .second certified question presented by the Eleventh Circuit has asked us to determine whether the nonsubstitution clause contained in the underlying 10/28/2014 10.A. Page 9 agreement violates article VII, section 12 of the Florida Constitution, which provides: Counties, school districts, munic- ipalities, special districts and local gov- ernmental bodies with taxing powers may issue bonds, certificates of indebtedness or any form of tax anticipation certifi- cates, payable from ad valorem taxation and maturing more than twelve months after issuance only: (a) to finance or refinance capital projects authorized by law and only when approved by vote of the electors who are owners of freeholds therein not wholly exempt from taxation .... To more accurately reflect the procedural posture and underlying facts of this case, we rephrase the second certified question to read: DOES THE NONSUBSTITUTION CLAUSE IN THE LEASE- PURCHASE AGREEMENT, WHICH REQUIRES UP TO A TWO -YEAR LAPSE IN COMPUTER SERVICES UPON NONAPPROPRIATION, VIOLATE ARTICLE VII, SECTION 12, OF THE FLORIDA CONSTITUTION, [ * *33] EVEN THOUGH THE AGREEMENT ALSO EXPRESSLY DISCLAIMS USE OF REVENUES FROM AD VALOREM TAXATION? After careful consideration, we answer the second certi- fied question, as rephrased, in the affirmative. The 1968 revision to the Florida Constitution, which produced article VII, section 12 of the Florida Constitu- tion, became effective on January 7, 1969. 12 See State v. County of Dade, 234 So. 2d 651, 652 (Fla. 1970). Since that time, we have addressed the constitutional provision on several occasions. Escambia County asserts that our decisions in County of Volusia v. State, 417 So. 2d 968 (Fla. 1982), and Nohrr v. Brevard Countv Educational Facilities [ *1024] Authority, 247 So. 2d 304 (Fla. 1971), " support a finding that the nonsubstitution clause implicates article VII, section 12, while Frankenmuth Packet Page -294- 10/28/2014 10.A. Page 10 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 attempts to distinguish JN6hrr and County of Volusia, compelling the lessee to continue to ap- primarily relying on our decisions in Murphy v. City of propriate funds throughout the full lease Port St. Lucie, 666 So. 2d 879 (Fla. 1995); State v. term, thereby rendering the optional fea- School Board of Sarasota County, 561 So. 2d 549, 553 tures of the nonappropriation and nonre- (Fla. 1990); State v. Brevard County, 539 So. 2d 461 newal clauses illusory." Id. [ * *36] This (Fla. 1989); [ * *34] City of Palatka v. State, 440 So. 2d court agrees a non - substitution clause may 1271 (Fla. 1983); and State v. Alachua County, 335 So. render a non - appropriation clause illusory, 2d 554 (Fla. 1976). In federal district court, the parties thereby requiring a lease to undergo Arti- presented arguments similar to those presented here, and cle VII, § 12 voter referendum. While the court there determined that the nonsubstitution clause Florida's courts have not addressed the contained in Paragraph 21 of the agreement implicates precise issue, several decisions lead to article VII, section 12 of the Florida Constitution, and that conclusion. In Nohrr v. Brevard thus the agreement could not have been approved absent County Educational Facilities Authority, a voter referendum. See Frankenmuth, 10 Fla. L. 247 So. 2d 304 (Fla. 1971), [ * *37] the Weekly Fed. at D342. In essence, the court determined court validated non - referendum revenue that the inclusion of the nonsubstitution clause trans- bonds that had been authorized to raise formed the agreement into a long -term certificate of in- money to build educational facilities. The debtedness pledging ad valorem taxes. See id. at D341. court deleted from the bonds, however, In making this determination, the district court engaged certain provisions that created a mortgage in the following analysis: on the property, allowing the bondholders to foreclose in the event of default. The Like many long -term municipal lease court reasoned the mortgage would "mor- agreements, the Unisys master lease con- ally compel" the governing body to levy tains a non - appropriation clause, provid- taxes to avoid foreclosure in the event ing that, if in any given year the govern- bond payments could not be made from ing body fails to appropriate funds to non -ad [ *1025] valorem revenue. Id. make the lease payments, the lease will at 311. In effect, the mortgage provision terminate. (Master Lease P 21). Such amounted to a pledge of ad valorem taxes, non - appropriation or non - renewal clauses which is invalid absent approval by the are essential to prevent long -term munic- electorate. ipal financing arrangements from being Similarly in State v. Brevard County, classified as debt under state law, thus 539 So. 2d 461 (Fla. 1989), the court ap- triggering state -law requirements such as proved a long -term lease - purchase ar- voter referendum. See M. David Gelfand, rangement which included an annual "re- State & Local Government Debt Financ- newal option" similar to the annual ing, § 3:17 at 32 (Clark Boardman & Cal- non- appropriation clause in the Unisys laghan 1993). lease. The court rejected an argument that The Unisys lease [ * *35] also con- the financing arrangement violated Nohrr, tains a non - substitution clause, providing but specifically noted the deal allowed the that, in the event of non - appropriation, the county to "terminate the lease without Lessee agrees not to procure substitute further obligation" in any given year. Id. computer equipment [or equivalent ser- at 463. Thus, the court reasoned, "with its vices] for the remainder of the appropria- 'annual renewal option' under the lease, tion period and the one following it. [ * *38] the county maintains full budget - (Master Lease P 21). Such clauses are a ary flexibility." common method by which the lessor cre- In contrast, a non- substitution clause ates an economic disincentive for the mu- denies the county "full budgetary flexibil- nicipality to exercise its non- appropriation ity" because it renders the rights. Gelfand § 3:17 at 32. As one non- appropriation clause illusory by commentator has noted, however, "there compelling the municipality to make the is considerable doubt about the enforcea- lease payments or suffer a penalty. The bility of the non - substitution clause and Attorney General of at least one State has its effect on the validity of the lease." Id. opined a non - substitution clause compels at 33. "The inclusion of the lease payments and creates debt. See La. nonsubstitution clause may be viewed as Packet Page -295- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, ** 25 Fla. L. Weekly S 697 Atty Gen. Op. No. 86 -517, 1986 WL 236994; Accordingly, the court must address two issues to determine the validity of the non - substitution clause in this case: (1) whether the risk of non - substitution would morally compel the County Commission to appropriate funds for the lease pay- ments; and (2) whether those funds would come from ad valorem tax dollars. A. Moral Compulsion Had funds not been appropriated to make the Unisys lease payments, the evi- dence is undisputed the consequences of non - substitution would have been disas- trous. The Unisys equipment provided the primary means for county payroll and central data processing for the County Commission and numerous other county offices. At deposition, Flowers made the following comments regarding non - substitution: Q: [ * *39] What would happen? A: If they took the equipment out, then we would be shut down. We would- n't be able to operate. Q: Why is that? A: Because everything was on that computer. (Flowers Depo. at 65). Given these facts, the court wastes little time finding the County Commission would feel mor- ally compelled to appropriate funds to make the lease payments to avoid the risk of running county government without a central data processing ability for up to two years. In this regard, the non- appropriation clause is rendered illu- sory and the lease creates a multi -year debt. B. Ad Valorem Taxes A municipal debt does not trigger Ar- ticle VII, § 12, however, unless it pledges ad valorem tax dollars as its source of payment. E.g. State v. School Bd. of Sarasota Count-, 561 So. 2d 549, 552 (Fla. 1990). In this case, the addendum to the master lease specifies no ad valorem taxes are pledged: Nothing herein shall constitute a pledge by the Lessee of the full faith and credit of the Lessee, nor does the Lessee pledge any ad valorem taxes or other moneys other than moneys lawfully appropriated by the County Commission of Escambia County from time to time. . . . Lessor shall [ * *40] not have the right to require or compel the exercise of the ad val- orem taxing power of, or the appropriation of any funds by the County Commission to obtain the payment or performance of any of the Lessee's obliga- tions created by this agreement. (Addendum P 1). 10/28/2014 10.A. Page 11 Regardless of the above provision, the court finds the lease, and in particular the non- substitution clause, would inevi- tably require the County Commission to appropriate ad valorem tax dollars to make the lease payments. The case is [ *1026] similar to County of Volusia v. State, 417 So. 2d 968 (Fla. 1982), in which the municipality sought to secure bonds by pledging "All legally available sources of unencumbered county revenue other than ad valorem taxes." The su- preme court reasoned this pledge, along with Volusia County's promise to do all things necessary to continue to receive the non -ad valorem revenue, would inevitably lead to higher ad valorem taxes during the life of the bonds. The court denied valida- tion, reasoning, "that which may not be done directly may not be done indirectly." Id. at 972.; cf. Brevard County, 539 So. 2d at 463 (refusing to apply County [ * *41] of Volusia to a case in which the municipality, unlike Escambia County in this case, "reserved the right to terminate the lease without further obliga- tion. ")County of Volusia applies squarely to these facts. The size of the lease pay- ments together with the consequences of Packet Page -296- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 non - substitution indicate the County Commission would inevitably be forced to spend ad valorem taxes dollars to fund this lease. The addendum clause pledging otherwise is illusory. For these reasons, the court finds the non - substitution clause violates Article VII, § 12 of the Florida Constitution and is therefore unenforcea- ble. Frankenmuth, 10 Fla. L. Weekly Fed. at D341 -42 (footnote omitted). 12 The predecessor constitutional provision to article VII, section 12, was article IX, section 6 of the Constitution of 1885, which was effective from 1930 until January 7, 1969. See State v. County of Dade, 234 So. 2d 651, 654 (Fla. 1970). That section provided: The Legislature shall have power to provide for issuing State bonds only for the purpose of re- pelling invasion or suppressing insurrection, and the Counties, Districts, or Municipalities of the State of Florida shall have power to issue bonds only after the same shall have been approved by a majority of the votes cast in an election in which a majority of the freeholders who are qualified electors residing in such Counties, Districts, or Municipalities shall participate, to be in the man- ner to be prescribed by law; but the provisions of this act shall not apply to the refunding of bonds issued exclusively for the purpose of refunding of the bonds or the interest thereon of such Counties, Districts, or Municipalities. Art. IX, § 6, Fla. Const. (1885). In numerous decisions, this Court held that various kinds of debts were not "bonds" for the purposes of the referendum requirement. See, e.g., State v. Miami Beach Redevelopment Agency, 392 So. 2d 875, 895 -98 (Fla. 1980) (discussing this Court's cases construing the predecessor constitutional provi- sion); see generally Patricia M. Lee, Note, Bond 10/28/2014 10.A. Page 12 Financing and the Referendum Requirement: Harmless Creative Financing or Assault on the Constitution ?, 20 Stet. L. Rev. 989, 992 -98 (199 1) (same). 13 In State v. School Board of Sarasota Coun- ty, 561 So. 2d 549, 553 (Fla. 1990), this Court in- dicated that our prior decision in Nohrr construed the predecessor to article VII, section 12 of the Florida Constitution. However, after reviewing the opinion in Nohrr, it is clear that (1) the facts in that case took place after the 1968 constitu- tional revision became effective; and (2) this Court was construing the new constitutional pro- vision in that case. We agree with the federal district court's thorough analysis regarding the nonsubstitution clause in the pre- sent agreement. While the addendum to the master lease agreement states that there is to be no pledge of ad val- orem taxes to fund the payments due under the agree- ment, and further disclaims any right to compel the pro- curement of ad valorem taxes, this is not a case where there is a pledge of a specifically demarcated source of revenue to satisfy the underlying obligation. See Murphy, 666 So. 2d at 881 [ * *42] (upholding bond validation where non- ad valorem taxes were pledged as a supple- ment to specifically demarcated source of revenue); City of Palatka, 440 So. 2d at 1273 (validating bond where two specific non -ad valorem sources of revenue were pledged); Alachua County, 335 So. 2d at 556 -58 (vali- dating bonds funded by pledge of revenue sharing funds and race track proceeds). More importantly, this is not a case where the county has retained "full budgetary flexi- bility." See School Board of Sarasota County, 561 So. 2d at 552 -53 (noting that school board could maintain "full budgetary flexibility" under terms of agreement); " Bre- vard County, 539 So. 2d at 464 (noting that "annual re- newal option" under lease - purchase agreement would allow county to maintain "full budgetary flexibility"). Instead, due to the expense and functionality of the computer equipment covered by the agreement here, the nonsubstitution clause interrelates with other lease provi- sions, see County of Volusia, 417 So. 2d at 972, to "mor- ally compel the county to pledge ad valorem taxes to fulfill the obligations of the lease. See [ * *43] Nohrr, 247 So. 2d at 311. Accordingly, we answer the second certified question, as rephrased, in the affirmative. " 14 In School Board of Sarasota County, we noted that the school board's failure to appropri- ate funds would result in "lease penalties," but that even with such penalties, the board main- tained its "full budgetary flexibility." See 561 So. 2d at 552 -53. As set forth in our opinion in that case, the lease penalties included either purchas- ing the constructed facilities or surrendering pos- Packet Page -297- 10/28/2014 10.A. Page 13 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 session of the facilities and the land upon which those facilities stood for the remainder of the lease term. See id. at 551. We emphasized, how- ever, that the school board was "free to substitute other facilities for those surrendered." See id. Clearly, the presence of a nonsubstitution clause here distinguishes this case from our decision in School Board of Sarasota County, insofar as "full budgetary flexibility" is concerned. 15 The federal district court determined that the nonsubstitution clause is severable from the remainder of the agreement, seeFrankenmuth, 10 Fla. L. Weekly Fed. at D342, but the Eleventh Circuit has not asked us to make a determination regarding severability. We decline to address the severability issue here, given that the issue is not novel and has not been fully briefed in this Court. We do note, however, that if the nonsubstitution clause is not severable from the remainder of the agreement, then the entire agreement must be in- validated as violative of article VII, section 12 of the Florida Constitution. [ * *44] I1I. CONCLUSION As we have analyzed, the first certified question is answered in the affirmative [ *1027] upon our deter- mination that a board of county commissioners may ap- prove in the form of ratification a lease - purchase agree- ment under section 125.031, Florida Statutes, even ab- sent formal resolution, where the board is not required by local ordinance or charter to take action by formal reso- lution. Further, we have established a three -prong test to guide the determination of whether an approval without formal resolution has occurred. Finally, we have re- sponded to the second certified question as rephrased in the affirmative upon the determination that, based on the particular facts in this case, the nonsubstitution clause implicates article VII, section 12 of the Florida Constitu- tion. Accordingly, we return the record in this case to the United States Court of Appeals for the Eleventh Circuit. It is so ordered. WELLS, C.J., and SHAW, HARDING, ANSTEAD, PARIENTE and QUINCE, JJ., concur. Packet Page -298- GFOA Best Practice Using Safekeeping and Third -Party Custodian Services Background. The safety of public funds should be the primary objective of all governments. One of the most important protections and a control against fraud is the separation of the safekeeping and custody function from the investment function Investment policies should include a section regarding independent third- party safekeeping or custody of securities. By arranging to have securities held by a third party, governments can effectively minimize safekeeping or custodial risk in an investment transaction. In a third -party safekeeping agreement, the government arranges for a firm other than the party that sold the investment to provide for the transfer and safekeeping of the securities. Financial firms should not serve as both government broker - dealer and custodian. Safekeeping represe.tri:s a. C.in:incial in obligation to act on behalf of the owner under the owner's control. Custody is a more clearly defined control position by the agent responding to the owner's requirements. Custody noranally does not take place in the governmental entities depository bank. Investments should be settled in a delivery- versus - payment (DNT) basis. In this procedure, the buyer's payment for securities is due at the time of delivery. Security delivery and payment occur simultaneously. This practice ensures that no funds are at risk in an investment transaction as funds are not released until securities are delivered. ensuring the governmental entity has either money or securities at all times during tlx: transaction. Recommendation. GFOA recommends that state and local governments utilize independent third -party custodians to safeguard their investments and protect against sat keeping /custochal risks. To accomplish this goal. GFOA recommends that goveriltnental entities: 1. compc°titiVeJN' Select third -party custodians and safe. - .keeping agents 2. have safe.kcepill.g/ctastoclia.l agrcemcnts revievl-cd by government legal counsel prior to execution 3. evidence their safekcepiaag or custodial relationship void: a signed. written Sc c.ttrtt4' -1" n- erntnt tnat is reviewcL`_ by counsel an(d establishes the tarn: as its agc:tl f 4. exccutt all inveslun nt transactions on u hasis '. designate a sl >ecifsc DD-A demand dc-posit account) clearing account in Conju31Ctio Vviy1h th`t safekeet)i.m or cusiod al t-c=; un", Packet Page -299- Gove,i,r en' F;noTice C 10/28/2014 10.A. 6. require that the independent third -party safekeeping agent or custodian mark the portfolio to market at least monthly. Ideally, marking should take place daily with independent pricing. 7. require reports and monthly statements to be received directly by the governmental entity from the agent. 8. ideally, have electronic access to the safekeeping or custody account for monitoring and reporting purposes, if cost effective. 9. require safekeeping or custodial agents to be insured for error and omissions. 10. require review of internal safekeeping and custodial procedures annually with the independent auditor. References. Int esting Public .Funds, Second Edition., Girard Miller with M. Corinne Larson and W. Paul Zorn, GFOA, 1998. GFOA Sample Custodial Trust Agreement, 2006, www.gfoa.org. 4n.1 ntrocluction to C'oll7tctnli7it7, Public Deposits for Statc and Local Governments, Second Edition, i't'I. Corinne Larson, GFOA, 2006. GFOA Best. Practice Collateralizing Public Deposits (1984, 1987, 1993, 2000, and 2007) GFOA Sample Security Agreement (long and short version) 2010. vovw.gfoa.org. Approved by the GIOA's E,eecutive Board, October, 2010. Packet Page -300-