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Resolution No. GPFFA 1994-03 | Refunding Bonds and Issuance of Authority Revenue Bonds - 1994 Authority Revenue Bonds | Adopted 03/21/1994RESOLUTION NO. 94 - 3 RESOLUTION AUTHORIZING PURCHASE OF CITY REFUNDING BONDS AND ISSUANCE OF AUTHORITY REVENUE BONDS 1994 AUTHORITY REVENUE BONDS The Board of Directors of the Gilroy Public Facilities Financing Authority resolves: Section 1. Recitals. The City Council of the City of Gilroy has heretofore levied reassessments and authorized the issuance of refunding bonds (the "Refunding Bonds") in Consolidated Refunding District No. 1994-1. The City Council has further ordered the sale of the Refunding Bonds to this Authority pursuant to a trust agreement (the "Trust Agreement") among the City of Gilroy, this Authority and Union Bank, as Trustee (the "Trustee"). Section 2. Approval of Trust Agreement. The form of Trust Agreement attached hereto as Exhibit A is hereby approved in substance. Any Authorized Officer of the Authority (i.e., the Chair, Vice Chair or Treasurer), upon the recommendation of Bond Counsel, is authorized to approve changes and completions in the Trust Agreement before closing of the transaction for the sale of 1994 Authority Revenue Bonds as herein provided, and to execute the Trust Agreement on behalf of the Authority. Section 3. Purchase of Refunding Bonds. The Board of Directors hereby orders the purchase by the Authority of the Refunding Bonds and the assignment of the Refunding Bonds to the Trustee in accordance with the provisions of the Trust Agreement. In consideration of the purchase of the Refunding Bonds, the Authority will issue the 1994 Authority Revenue Bonds as herein provided and will disburse the proceeds thereof as provided in the Trust Agreement. Section 4. Issuance of Revenue Bonds. The Board of Directors hereby authorizes the issuance of its 1994 Authority Revenue Bonds in the amount of $8,615,000.00. The Revenue Bonds shall be in the form specified in the Trust Agreement and shall be issued by the Authority and authenticated, delivered and subsequently administered by the Trustee. Payment of principal of, and interest on, the Revenue Bonds shall be made from payments to be made to the RESOLUTION NO. 94 - 3 Trustee of principal and interest for the Refunding Bonds, all as set forth in the Trust Agreement. The Refunding Bonds are hereby pledged as security for the payment of the Revenue Bonds and shall be held in safekeeping and in trust by the Trustee until the Revenue Bonds are paid in full. Section 5. Sale of Revenue Bonds. The Treasurer of the Authority or other Authorized Officer is hereby authorized to sell the 1994 Authority Revenue Bonds in accordance with the Purchase Contract attached hereto as Exhibit B and by reference incorporated herein. The Treasurer of the Authority is hereby authorized to receive proposals for the purchase of the 1994 Authority Revenue Bonds, to approve the maturity schedule and interest rates thereof and to execute a purchase contract with a bond underwriter on behalf of the Authority. I hereby certify that the foregoing resolution was duly and regularly adopted and passed by the Board of Directors of the Giiroy Public Facilities Financing Authority, City of Gilroy, California, at a regular meeting thereof held on the 21st day of March, 1994, by the following vote of the members thereof: AYES, and in favor, thereof, Boardmembers:GILROY, KLOECKER, ~RALES, ROGERS, ROWLISON, VALDEZ and GAGE. NOES, Boardmembers: None ABSENT, Boardmembers: None APPR~D ~ President 465 California Street Suite 600 San Francisco, CA 94104 MARK PRESSMAN ASSOCIATES Investment Banking EXHIBIT B Tel: (415) 421-7300 (800) 273-6630 Fax: (415) 421-0755 March 25, 1994 The Honorable City Council Gilroy Public Facilities Financing Authority City of Gilroy Gilroy, California Re: Bond Purchase Contract for 1994 Authority Revenue Bonds to be Issued by Gilroy Public Facilities Financing Authority (the "AuthOrity"), City of Gilroy, California Dear Members of the Authority: MARK PRESSMAN ASSOCIATES (MPA), as managing underwriter (the "Underwriter") of the above referenced issue, hereby offers to purchase all, but not less than all, bonds to be offered by the Gilroy Public Facilities Financing Authority (the "Authority") City of Gilroy, California designated (the "Bonds"), being issued by the Authority pursuant to the laws of the State of California (the "State") and particularly the Marks-Roos Local Bond Pooling Act of 1985, as amended, constituting Article 4 (commencing with Section 6584), of Chapter 5, Division 7, Title 1 of the Government Code of the State (the "Bond Law"), for the purpose of acquiring the bonds of the 1994-1 Consolidated Refunding District which will refund certain previously issued bonds of the City which financed public improvements in the following districts: Country Estates - Phase 1 Assessment District, Series 91-1; Las Animas Technology Park Refunding District No. 2, Series No. 88-1; East Ninth Street et al Assessment District, Series No. 87-1; Ronan-Liman Avenues Assessment District, Series 82-2; Amount of Bonds: $8,615,000 Form of Bonds: First Interest Payment and Maturity Schedule: Registered bonds to be issued serially. Bond denominations in multiples of $5,000 or any integral thereof. The first interest payment on the Bonds shall be September 2, 1994, with principal payments commencing September 2, 1994, and annually thereafter as specified below: 1994 $35,000 2003 $585,000 1995 490,000 2004 630,000 1996 500,000 2005 665,000 1997 540,000 2006 695,000 1998 530,000 2007 335,000 1999 ~ 470,000 2008 360,000 2000 500,000 2009 380,000 2001 520,000 2010 405,000 2002 555,000 2011 420,000 Mailing Address: P.O. Box 26690, San Francisco, CA 94126 Board of Directors Gilroy Public Facilities Financing Authority March 25, 1994 Page Two Price: Term: Net Interest Cost: True Interest Cost: Interest Rates: $8,399,625 The last maturity shall be 2011. 6.6154051% 6.2876497% 1994 3.00% 2003 6.20% 1995 4.25 2004 6.30 1996 4.75 2005 6.40 1997 5.25 2006 6.50 1998 5.50 2007 6.60 1999 5.75 2008 6.70 2000 5.90 2009 6.75 2001 6.00 2010 6.80 2002 6.10 2011 6.80 Date of Bonds and Closing Date: Foreclosure Clause: Reserve Fund: Redemption Premium: Trustee: No Litigation: Legal Opinion: April 7, 1994. As described in the Trust Agreement and the Official Statement. The Authority shall establish a Reserve Fund in the amount of Eight percent (8%) of the bond par value. In our view, it is reasonably required for this issue, and vital to the marketing of the Bonds, that proceeds from the investment of moneys in said reserve fund be credited to the Payment Account to be applied to debt service. As described in the Official Statement. Union Bank, Los Angeles, California. A no litigation certificate of the Authority shall accompany the Bonds at closing. The opinion of Sturgis, Ness, Brunsell & Assaf, Emeryville, California, without qualification and without expense to the Underwriter as to the legality of the proceedings leading to the issuance of the Bonds and as to the federal and state tax status of the Bonds. Such opinion, dated as of the Closing Date, to be printed on the Bonds when issued. Board of Directors Gilroy Public Facilities' Financing Authority March 25, 1994 Page Three Conditions Precedent: The obligation of the Underwriter to accept delivery of and pay for the Bonds on the Closing Date shall be subject, at the option of the Underwriter, to the following additional conditions: (a) The Authority shall have delivered or caused to have been delivered to the Underwriter prior to the execution of this Purchase Contract or the first sale of the Bonds, whichever first occurs, copies of the Draft Official Statement dated March 21, 1994, relating to the Bonds (the "Draft Official Statement") deemed final by the Authority for purposes of Rule 15c2-12 under the Securities Exchange Act of 1934 (the "Rule") and to satisfy Municipal Securities Rulemaking Board (the "MSRB") Rule G-32 or any other rules adopted by the MSRB, and approved for distribution by resolution of the Authority. Within seven business days from the date hereof, the Authority shall deliver to the Underwriter a final Official Statement, executed on behalf of the Authority by an authorized representative of the Authority and dated the date of Closing thereof to the Underwriter, which shall include information permitted to be omitted by paragraph (b)(1) of the Rule and with such other amendments or supplements as shall have been approved by the Authority and the Underwriter (the "Official Statement"). The Draft Official Statement and the Official Statement, including the cover pages, the appendices thereto and all information incorporated therein by reference are hereinafter referred collectively to as the "Official Statement." The Underwriter agrees that it will not confirm the sale of any Bonds unless the confirmation of sale is accompanied or preceded by the delivery of a copy of the Official Statement. (b) The Resolution shall be in full force and effect, and shall not have been amended, modified or supplemented except as may have been agreed in writing by the Underwriter, and there shall have been taken in connection therewith, with the issuance of the Bonds and with the transactions contemplated thereby and by this Purchase Contract, all such actions as, in the opinion of Sturgis, Ness, Brunsell & Assaf, Emeryville, California, Bond Counsel for the Authority, shall be necessary and appropriate; (c) Between the date hereof and the Closing date, the market price or marketability of the Bonds at the initial offering prices set forth in the Official Statement shall not have been adversely affected in a material way, in the judgment of the Underwriter (evidenced by a written notice to the Authority terminating the obligation of the Underwriter to accept delivery of and pay for the Bonds) by reason of any of the following: Board of Directors Gilroy Public Facilities Financing Authority March 25, 1994 Page Four (1) (2) (3) (4) (5) Legislation enacted (or resolution passed) by the Congress of the United States of America or a decision rendered by a court established under Article III of the Constitution of the United States of America or by the Tax Court of the United States of America, or an order, ruling, regulation (final, temporary or proposed), press release or other form of notice issued or made by or on behalf of the Treasury Department or the Internal Revenue Service of the United States of America, with the purpose or effect, directly or indirectly, of imposing federal income taxation upon the interest as would be received by the owners of the Bonds; Legislation enacted (or resolution passed) by the Congress of the United States of America, or an order, decree or injunction issued by any court of competent jurisdiction or an order, ruling, regulation (final, temporary or proposed), press release or other form of notice issued or made by or on behalf of the Securities and Exchange Commission, or any other govemmental agency having jurisdiction of the subject matter, to the effect that obligations of the general character of the Bonds, or the Bonds, including any or all underlying arrangements, are not exempt from registration under or other requirements of the Securities Act of 1933, as amended, or that the Resolution is not exempt from qualification under or other requirements of the Trust Indenture Act of 1939, as amended, or that the issuance, offering or sale of obligations of the general character of the Bonds, or of the Bonds, including any or all underwriting arrangements, as contemplated hereby or by the Official Statement or otherwise is, or would be, in violation of the federal securities laws as amended and then in effect; Any amendment to the Federal or California Constitution or action by any Federal or California court, legislative body, or other authority materially adversely affecting the tax status of the Authority or the City, its property, income, securities (or interest thereon), validity or enforceability of the assessment or the ability of the Authority to acquire the Refunding Bonds as contemplated by the Trust Agreement and the Official Statement; Any event occurring, or information becoming known which, in the judgment of the Underwriter makes untrue or misleading in any material respect any statement or information contained in the Official Statement concerning the Authority or the City, the improvement projects, the landowners, or the property assessed; or Any calamitous act of God such as flooding, land movement, or other which directly or indirectly affects the value of the property assessed and/or the security of the Bonds; or Board of Directors Gilroy Public Facilities Financing Authority March 25, 1994 Page Five (6) The declaration of war or engagement in major military hostilities by the United States or the occurrence of any other national emergency or calamity relating to the effective operation of the government or the financial community of the United States. Closing Conditions: (a) At or prior to the Closing, the Underwriter shall have received copies of each of the following documents: (1) The Official Statement and each supplement or amendment, if any, thereto; (2) The Resolutions and the Trust Agreement, certified on the date of the Closing by an authorized officer of the Authority as having been duly adopted and as being in full force and effect; (3) An unqualified opinion in substantially the form included as EXHIBIT B to the Official Statement, dated the Closing Date and addressed to the Authority, of Sturgis, Ness, Brunsell & Assaf, Emeryville, California, together with a reliance letter of Sturgis, Ness, Brunsell & Assaf, dated the Closing Date and addressed to the Underwriter, to the effect that such opinion addressed to the Authority may be relied upon by the Underwriter to the same extent as if such opinion were addressed to it; (4) A certificate signed by an appropriate .Authority official to the effect that (i) such official has reviewed the Official Statement and on such basis certifies that the Official Statement does not contain any untrue statement of a material fact or omit to state any material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading; and (ii) that the representations and warranties of the Authority contained herein are true and correct in all material respects on and as of the Closing Date with the same effect as if made on the Closing Date; and (iii) the Authority and the City have complied with all the agreements and satisfied all the conditions on its part to be performed or satisfied under this Purchase Contract, the Resolutions, the Trust Agreement and the Official Statement at or prior to the Closing Date; If the Authority shall be unable to satisfy the conditions to the obligations of the Underwriter to purchase, to accept delivery of and to pay for the Bonds contained in this Purchase Contract, or if the obligations of the Underwriter to purchase, to accept delivery of and to pay for the Bonds shall be terminated for any reason permitted by this Purchase Contract, this Purchase Contract shall terminate and neither the Underwriter nor the City shall be under any further obligation hereunder. In the event that the Underwriter fails (other than for a reason permitted by this Purchase Contract) to accept and pay for the Bonds at the closing, the amount of one-quarter of one percent (1/4%) of the principal amount~ of the Bonds shall be full liquidated damages for such failure and for any and all defaults hereunder on the part of the Underwriter, and the acceptance of such amount shall constitute a full release and discharge of all claims and rights of the City against the Underwriter. Board of Directors Gilroy Public Facilities Financing Authority March 25, 1994 Page Six Authority and City Covenant: Place of Closing: Time of Closing: Expiration: The Authority and-the City shall covenant in the Resolution and the Trust Agreement to take any action within its powers to maintain the tax-exempt status of the Bonds. To be arranged. Not later than 48 hours after the Authority notifies the undersigned that the Bonds are ready for delivery. If the subject Bonds are not available for delivery by 5:00 p.m. on the aforementioned Closing date, the Underwriter reserves the right to renegotiate the price and/or the rate of interest. This offer expires at 5:00 p.m. on March 25, 1994. Very truly yours, MARK PRESSMAN ASSOCIATES Mark Pressman Managing Principal Accepted by: Authority Treasurer TRUST AGREEMENT by and among CITY OF GILROY and GILROY PUBLIC FACILITIES FINANCING AUTHORITY and UNION BANK as Trustee Dated as of March 21, 1994 TABLE OF CONTENTS TRUST AGREEMENT 1994 AUTHORITY REVENUE BONDS RECITALS ARTICLE I ARTICLE II ARTICLE III ARTICLE IV ARTICLE V EXHIBIT A EXHIBIT B EXHIBIT C EXHIBIT D 1 GENERAL PROVISIONS ................ 2 THE TRUSTEE ................... 3 FUNDS AND ACCOUNTS ................ 6 9 THE BONDS .................... COVENANTS; EVENT OF DEFAULT .......... 16 22 DEFINITIONS .................. DEBT SERVICE SCHEDULE FOR CONSOLIDATED REFUNDING DISTRICT NO. 1994-1 . . 28 DEBT SERVICE SCHEDULE FOR 1994 REVENUE BONDS . . 29 FORM OF REVENUE BOND ............. 30 TRUST AGREEMENT THIS IS A TRUST AGREEMENT (the "Trust Agreement") among the CITY OF GILROY, a municipal corporation of the State of California (the "City"), the GILROY PUBLIC FACILITIES FINANCING AUTHORITY, a joint powers authority organized and existing pursuant to Government Code Section 6500 et seq. (the "Authority") and Union Bank as Trustee (the "Trustee"), entered into as of March 21, 1994. RECITALS The City has heretofore issued improvement bonds (the "Prior Bonds") pursuant to the Improvement Bond Act of 1915 (Streets and Highways Code Section 8500 et seq.) to represent unpaid special assessments in four special assessment districts established pursuant to the Municipal Improvement Act of 1913 (Streets and Highways Code Section 10000 et seq.), to wit: (a) (b) (c) (d) Country Estates Phase I Assessment District; Las Animas Technology Park Refunding District No. 2; East Ninth Street et al Refunding Assessment District; and Ronan-Liman Avenues Assessment District No. 82-2. Pursuant to the Refunding Act of 1984 for 1915 Improvement Act Bonds (Streets and Highways Code Section 9500 et seq., the "Refunding Act"), the City has created a reassessment district (the "Reassessment District") to be named Consolidated Refunding District No. 1994-1. The City has issued refunding bonds (the "Refunding Bonds") for the Reassessment District pursuant to the Refunding Act and has sold the Refunding Bonds to the Authority. To provide funds for the purchase of the Refunding Bonds, the Authority has issued and sold bonds (the "Revenue Bonds") pursuant to the Marks-Roos Local Bond Pooling Act of 1985 (Government Code Section 6584 et seq.). The City and the Authority wish to assign to the Trustee certain of their rights with reference to this transaction, and the Trustee is willing to accept the assignment and to perform the duties set forth herein in consideration of the payment of monetary compensation. ARTICLE I GENERAL PROVISIONS Section 101. Definitions. Terms capitalized herein shall have the definitions given herein or in Exhibit A hereof, unless the context otherwise requires. Section 102. Captions and Titles. The captions of sections and the titles of articles in this Agreement are not a part of this Agreement but are for reference only and shall not affect the meaning of this Agreement. Section 103. Exhibits. Each exhibit to this Agreement is incorporated herein by reference and shall be deemed a part of the Agreement. Section 104. Rules of Construction. Gender-specific words shall be deemed to apply to any gender appropriate to the context. Unless the context otherwise requires, the word "person" means a natural person, corporation, association or public agency. Where the context permits, the singular may include the plural and the plural, the singular. Terms of inclusion such as "herein", "hereof", "hereunder" and the like refer to this Agreement as a whole. Section 105. Applicable Law. This Agreement has been entered into and shall be construed in accordance with the laws of the State of California. Any reference to an agreement, statute, regulation or ordinance shall be deemed to include amendments now or hereafter adopted. Section 106. Severability. If any provision of this Agreement is ruled contrary to law by a court of competent jurisdiction, that provision shall be deemed severable from all other provisions of this Agreement and the validity of those other provisions shall not be affected by the ruling. Section 107. Acts of Aqents. Any act required or permitted of a party to this Agreement may be performed by an Authorized Officer of that party, or, if not otherwise limited in this Agreement, by any duly authorized agent of that party. Actions required of or permitted to the City pursuant to this Trust Agreement may be as principal or as agent of the Authority, as the context requires. Section 108. Date of Performance or Condition. Any act required to be performed or condition required to exist on a day that is not a Business Day shall be deemed to have been performed or to have existed on that day if the act is performed or the condition exists on the next Business Day. 2 Section 109. Counterparts. This Agreement may be executed in counterparts, and each counterpart shall be deemed to be the same instrument. Section 110. Notices. Unless otherwise specifically provided in this Agreement, any notice required or permitted to be given to any party hereof may be given by depositing the notice in the United States mail, first-class, postage prepaid, addressed as follows: TO THE CITY: City Clerk City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 TO THE AUTHORITY: Gilroy Public Facilities Financing Authority c/o Director of Finance City of Gilroy 7351 Rosanna Street Gilroy, CA 95020 TO THE TRUSTEE: Union Bank 350 California Street San Francisco, CA 94104 Attn: Corporate Trust Division ARTICLE II THE.TRUSTEE Section 201. Appointment of Trustee. The Authority hereby appoints the Trustee, and the Trustee hereby accepts the appointment, to receive, hold and invest moneys in the Redemption Fund and all accounts held thereunder and in the Prepayment Fund in trust for the benefit of the Owners of the Revenue Bonds; to authenticate and deliver the Revenue Bonds; to disburse the Redemption Payments to the Owners of the Revenue Bonds; and to perform certain other functions, all as hereinafter provided. Section 202. Assiqnment of Refundinq Bonds. The Authority hereby assigns in trust to the Trustee, and the Trustee hereby accepts the assignment of, all of the Authority's right, title and interest in and to the Refunding Bonds. The Trustee shall place the Refunding Bonds in safekeeping when received and shall exercise the rights of an owner of the Refunding Bonds for the benefit of the Owners of the Revenue Bonds as provided hereinafter. The duties of the Trustee with regard to the Refunding Bonds shall be limited as provided hereinafter. The Trustee shall cancel any Refunding Bond that has been paid in full and shall deliver it to the City or its order. Section 203. Trustee: Duties, Removal and Resiqnation. a) Before an Event of Default and after every Event of Default has been cured, the Trustee shall perform only the duties specifically set out in this Trust Agreement, and no implied duties or obligations shall be read into this Agreement against the Trustee. After an Event of Default and before its cure, the Trustee shall use such of the rights and powers vested in it by this Trust Agreement, and with the same degree of care and skill, as a prudent person would use under the circumstances in the conduct of his own affairs. b) So long as no Event of Default has occurred and is continuing, by written notice to the Trustee the City may remove the initial Trustee and any successor thereto and may appoint a successor Trustee, but any successor shall be a bank or trust company subject to supervision or examination by state or federal authority. The Trustee's rights to indemnity and to payment of its fees and expenses shall survive Trustee's resignation or removal and final payment or defeasance of the Revenue Bonds. c) The Trustee may resign at any time by written notice mailed by first-class mail to the City and to the Owners at their addresses shown on the Bond Register. On receiving the notice of resignation, the city shall promptly appoint a successor Trustee in writing; if the City fails to do so within ninety (90) days after receiving the notice, the resigning Trustee at the expense of the city may petition the court having jurisdiction to appoint a successor Trustee. Any resignation or removal of the Trustee and appointment of a successor Trustee shall become effective upon acceptance of appointment by the successor Trustee. The City shall require a successor Trustee to provide a written notice of appointment to each Owner. d) Any company into which the Trustee is merged or converted or with which it is consolidated; or any company resulting from any merger, conversion or consolidation to which the Trustee shall be a party; or any company to which the Trustee sells or transfers all or part of its corporate trust business, shall be the successor to the Trustee without executing or filing any paper or taking any further action. Section 204. Compensation of the Trustee. From time to time on demand the City shall pay to the Trustee, within thirty (30) days after receipt of periodic billing, reasonable compensation and the fees and expenses of independent appraisers, accountants, consultants, legal counsel, and others employed by it in the performance of its duties hereunder. To secure payment the Trustee shall have a lien, superior to that of the Owners, on funds held by it under this Trust Agreement. Section 205. Indemnification. The City shall indemnify the Trustee, its officers, directors, employees and agents against all cost, expense and liability resulting from the employment of the Trustee as Trustee and assignee of the Authority, except liability arising from the negligence or willful misconduct of the Trustee, its officers, employees or agents. This indemnification shall include all expenses arising from the Trustee's alleged liability, including legal fees and costs of defending against any claim. If the City is required to pay indemnity to the Trustee, the city shall be subrogated to the rights of the Trustee to recover its losses from any other person (excluding any insurer under any policy maintained by the Trustee in its individual capacity). Indemnification and the Trustee's right to fees and expenses shall survive the Trustee's resignation or removal and the final payment or defeasance of the Revenue Bonds. Section 206. Protection to the Trustee. The Trustee shall incur no liability in acting in good faith on any document or instrument that in good faith it believes to be genuine and to have been duly given. The Trustee shall have no duty to investigate or question the statements contained in any document or instrument, but may rely conclusively on them as true and accurate. Unless otherwise specifically provided herein, the Trustee is entitled to rely conclusively on the certificate of an Authorized Officer of the City or the Authority, but in its discretion the Trustee may require other or further evidence before acting or withholding action. The Trustee may buy, sell, own, hold and deal in any of the Revenue Bonds and as an Owner may join in any action which any Owner may be entitled to take with the same effect as if it were not the Trustee. The TrUstee, either as principal or agent, may have an interest in any other transaction with the City and may act as depository, trustee or agent for any committee or body of Owners of Revenue Bonds or other obligations of the City or the Authority as freely as if it were not the Trustee. The Trustee may act hereunder through attorneys, agents, or receivers and shall be entitled to advice of counsel concerning its duties. The Trustee may rely upon an opinion of counsel as complete protection for any action taken or not taken by it. The Trustee shall not be answerable for the default or misconduct of any attorney, agent, or receiver selected by it with reasonable care. The Trustee shall not be answerable for the exercise of any discretion or power under this Agreement or for the administration of the Accounts, except only for its own negligence or willful misconduct. The Trustee shall not be liable for any action taken or omitted in good faith, at the direction of the Owners of not less 5 than twenty-five percent (25%) in aggregate principal amount of the Outstanding Revenue Bonds, as to the time, method and place of conducting a proceeding for any remedy available to the Trustee. The Trustee makes no representations about the validity or sufficiency of this Agreement or the Refunding Bonds or the Revenue Bonds or the sufficiency of security for the Refunding Bonds or the Revenue Bonds and shall not incur any responsibility therefor, except as expressly provided herein. The Trustee shall have no liability for the failure of performance by any other party to this Agreement, but shall be responsible solely for the performance of its own duties. The Trustee undertakes to perform only the duties specified in this Agreement, and no implied covenants or obligations, fiduciary or otherwise, shall be read into this Agreement against the Trustee. In accepting the trust hereby created the Trustee acts solely as Trustee for the Owners and not in its individual capacity. All persons, including without limitation the Owners and the City, having any claim against the Trustee arising from this Agreement shall look only to the Accounts for payment except as otherwise provided herein. The Trustee shall not be liable in its individual capacity for the obligations evidenced by the Revenue Bonds. Section 207. No Obliqation of Trustee to Expend its Funds. The Trustee is not required to expend or risk its own funds or incur any financial liability in performing its duties or exercising its rights or powers, if repayment of funds or adequate indemnity against risk or liability is not assured to it. The Trustee shall be entitled to interest on any funds advanced by it in the performance of its duties at the maximum rate permitted by law. ARTICLE III FUNDS AND ACCOUNTS Section 301. Establishment of Funds and Accounts. There are hereby established with the Trustee three special trust funds: (1) The Redemption Fund, and within it the Payment Account and the Reserve Account; (2) The Prepayment Fund; and (3) The Delivery Cost Fund. The Trustee shall keep the funds and each of these accounts separate from all other funds and accounts held by it, and shall 6 not withdraw, transfer or pay from any fund or account except as provided herein. Section 302. Initial Deposit. On the Closing Date the Trustee shall receive and place in safekeeping the Refunding Bonds, and shall receive, from the proceeds of the sale of the Revenue Bonds, the amount of $8,399,625.00 (the par amount of the bonds of $8,615,000.00 less a 2.5% discount of $215,375.00), to be deposited or otherwise disbursed as follows: (1) The amount of $7,501,000.00 shall be transferred to the Escrow Agent to be applied as provided in the Defeasance Escrow Agreement, for the purpose of retiring the Prior Bonds on July 2 and September 2, 1994. (2) The amount of $689,200.00 (the "Required Reserve") shall be deposited in the Reserve Account and shall be administered in accordance with Section 304 hereof. (3) The amount of $209,425.00 shall be deposited in the Delivery Cost Fund and disbursed by the Trustee upon order of the City as agent of the Authority for the payment of Delivery Costs of the Revenue Bonds and the Refunding Bonds. The Trustee shall administer the Delivery Cost Fund. All funds in the Delivery Cost Fund will be expended within thirty (30) days after the issuance of Revenue Bonds. At the end of thirty days, the Fund is to be closed and any moneys in the fund after payment of all Delivery Costs shall be deposited in the Payment Fund. The Trustee shall deposit the amount of $18,702.93 in the Payment Account upon receipt of that amount from the City of Gilroy on or about April 7, 1994. This amount represents capitalized interest on the Refunding Bonds and shall be disbursed in accordance with Section 303. The Trustee in its discretion may establish a temporary account on its records to facilitate the foregoing transfers. Section 303. Payment Account. (a) The Trustee shall deposit in the Payment Account all payments of principal of and interest on the Refunding Bonds, to be received from the City in accordance with the schedules of payments set forth in Exhibit B hereof. The Trustee shall maintain the Payment Account until all payments on the Revenue Bonds are made in full. (b) On each Interest Payment Date the Trustee shall withdraw from the Payment Account the amount due as principal of, and interest on, the Revenue Bonds and shall disburse it to the Owners of the Revenue Bonds. 7 (c) The balance, if any, in the Payment Account immediately following the disbursement pursuant to subsection (b) shall be transferred first to the Reserve Account to the extent that the amount in the Reserve Account is less than the Required Reserve, and any remaining balance shall be transferred to the Prepayment Fund. Section 304. Reserve Account. (a) The Trustee shall maintain the Reserve Account until the Revenue Bonds are paid in full. (b) On any Interest Payment Date, if the amount in the Payment Account is less than the amount due the Owners of the Revenue Bonds on that date as principal and interest on the Revenue Bonds, the Trustee shall transfer from the Reserve Account to the Payment ~ Account an amount sufficient to cover the deficiency, and within five (5) Business Days thereafter shall notify the City in writing of the amount and the date of transfer, the amount of the remaining balance in the Reserve Account and the amount of the Required Reserve. (c) On payment in full of the Revenue Bonds, the Trustee shall remit the amount in the Reserve Account to the City and shall close the account. (d) On any Interest Payment Date, if the amount due and payable on the Revenue Bonds exceeds the amount in the Payment Account after transfer from the Reserve Account pursuant to subsection (b), the Trustee shall apply the amount in the Payment Account in the following order of priority, prorating as necessary within the last category to which moneys can be applied: (1) To the payment of interest on all Outstanding Revenue Bonds; (2) To the payment of the principal of unpaid Revenue Bonds that matured on an earlier Bond Payment Date, in order of maturity date; and (3) To the payment of the principal of Revenue Bonds maturing on the current Bond Payment Date. (e) On receiving a delinquent payment from the city for which an advance has been made from the Reserve Account, the Trustee shall deposit the payment: (1) First, to the Payment Account to the extent of the full amount remaining payable to Owners of the Revenue Bonds; and (2) Second, to the Reserve Account. 8 Section 305. Prepayment Fund. The Trustee shall administer the Prepayment Fund in accordance with Section 417 hereof. Section 306. Investment of Fund and Account Balances. (a) The Trustee shall invest all moneys held in the funds and accounts hereunder in Permitted Investments designated by the City in writing and received by the Trustee at least two (2) Business Days before the investment date. In the absence of instructions the Trustee shall invest in money market funds as defined in Exhibit A, ,,Permitted Investments", paragraph F. (b) The Trustee shall deposit investment earnings on all funds and accounts to the Reserve Account, to the extent that the amount in the Reserve Account is less than the Required Reserve, and then to the Payment Account. (c) In its investment activities the Trustee acts only as agent of the City. The Trustee shall not be liable for investment losses, which shall be charged to the account for which the investment was made. (d) The Trustee shall give the City a monthly statement of account for each fund and account, including the balance thereof and the earnings, transfers and other transactions since the date of the previous statement. Section 307. Rebate of Arbitraqe. Within ten (10) Business Days after receiving written instructions from the City, the Trustee shall disburse to the United States, from the funds and accounts specified by the City, any amounts required to be rebated as arbitrage to the United States pursuant to Section 148 of the Internal Revenue Code. The Trustee may rely conclusively on the instructiOns and shall have no responsibility for compliance with those provisions of the Internal Revenue Code or regulations adopted thereunder. ARTICLE IV 'THE BONDS Section 401. Authentication of Revenue Bonds. On the written request of the City and the Authority the Trustee shall authenticate and deliver to the original purchaser thereof Revenue Bonds in an aggregate principal amount of $8,665,000.00, secured by the pledge of revenues to be received by the city pursuant to the Refunding Bonds. The City and the Authority hereby certify that all conditions required by the Constitution and statutes of the State of California and this Trust Agreement precedent to the delivery of the Revenue Bonds have occurred or been duly performed. Section 402. Form: Denomination; Medium of Payment. The Revenue Bonds shall be delivered as fully registered bonds in the denomination of $5,000 or integral multiples thereof. The form of the Revenue Bonds shall be substantially as set forth in Exhibit D. The Revenue Bonds shall be payable in lawful money of the United States of America which at the time of payment is legal tender for the payment of public and private debts. Section 403. Date of Revenue Bonds. Each Revenue Bond shall be dated as of the date of its authentication, except that each Revenue Bond delivered to the original purchaser shall be dated as of the Closing Date. Interest on each Revenue Bond shall be payable from the Interest Payment Date next preceding the date of its authentication, except that: (1) If the Revenue Bond is authenticated as of an Interest Payment Date, or after the fifteenth (15th) day of a month preceding an Interest Payment Date and before that Interest Payment Date, interest shall be payable from that Interest Payment Date; or (2) If the Revenue Bond is authenticated on or before September 2, 1994, interest shall be payable from the Closing Date. In any event, if interest is in default on any Outstanding Revenue Bond as of the authentication date of a Revenue Bond, interest on that Revenue Bond shall be payable from the Interest Payment Date to which interest has previously been paid or made available for payment on the Outstanding Revenue Bonds. Section 404. Payment of Principal and Interest. The Revenue Bonds shall be in serial form, and their principal shall be payable from the principal payments on the Refunding Bonds on September 2 in each of the years and in the amounts set forth in Exhibit C. Interest on the Revenue Bonds shall be payable on September 2, 1994, and semiannually thereafter on September 2 and March 2 of each year to and including the date of principal payment or prepayment, whichever is earlier. Interest on the Revenue Bonds shall be payable from the interest paid on the Refunding Bonds and shall be computed at the rates set forth in Exhibit C on the basis of a 360-day year of twelve 30-day months. Section 405. Place of Payment. The principal (together with a prepayment premium, if any) of the Revenue Bonds shall be payable at the Principal Office of the Trustee. Interest on the Revenue Bonds shall be payable by check of the Trustee mailed by first- class mail to the Owners on the Interest Payment Date; but the Owners shown on the Bond Register on the 15th day of the month preceding the Interest Payment Date shall be deemed to be Owners on the Interest Payment Date for the purpose of paying interest (except as otherwise described herein for interest paid to an account in the Continental United States of America by wire 10 transfer as requested in writing no later than the applicable Record Date by certain owners of $1,000,000 or more in aggregate principal amount of Bonds). Section 406. Numbers; Legends. The Revenue Bonds may be numbered by a method selected by the Trustee. The Revenue Bonds may contain or have endorsed thereon provisions, specifications and descriptive words consistent with this Agreement, as determined by the City before delivery of the Revenue Bonds. Section 407. Authentication. The Revenue Bonds shall be authenticated by the Trustee, as trustee under this Trust Agreement, by the manual signature of an Authorized Officer or signatory of the Trustee. Section 408. Transfer and Exchanqe of Revenue Bond. (a) Each Revenue Bond shall be transferable only on the Bond Register, which shall be kept at the Principal Office of the Trustee, on surrender of the Revenue Bond together with a written instrument of transfer satisfactory to the Trustee and duly executed by the Owner or his authorized attorney. On the surrender of the Revenue Bond and the registration of its transfer, the Trustee shall authenticate and deliver, in the name of the transferee, one or more new Revenue Bonds of the same aggregate principal amount of Authorized Denominations, Bond Payment Date and interest rate as the surrendered Revenue Bond. (b) One or more Revenue Bonds having the same Bond Payment Date may be exchanged at the Principal Office of the Trustee for the same aggregate principal amount of Revenue Bonds of other Authorized Denominations. On the surrender of any Revenue Bond together with a written request for exchange executed by the Owner or his authorized attorney, the Trustee shall authenticate and deliver in the name of the Owner and shall register one or more new Revenue Bonds of the same aggregate principal amount of Authorized Denominations, Bond Payment Date, and interest rate as the Revenue Bond being exchanged. (c) The Trustee shall not be required to register a transfer or exchange during the period established by the Trustee for selection of Revenue Bonds for prepayment or redemption or for any Revenue Bond or portion thereof selected for prepayment or redemption pursuant to Section 415 of this Trust Agreement. Section 409. Requlation with Respect to Exchange and Transfers. On the transfer or exchange of Revenue Bonds, the Trustee shall authenticate and deliver Revenue Bonds in accordance with this Article. The Trustee shall cancel Revenue Bonds surrendered in any transfer or exchange and shall destroy them. The City shall pay the cost of preparing new Revenue Bonds and any other expenses of the City or the Tr6stee in a transfer or exchange 11 of Revenue Bonds, except for any tax, fee or other governmental charge not imposed by the City. Section 410. Bond Reqister. (a) The Trustee shall keep at its Principal office a Bond Register, which shall be open to inspection by the City or the Owners on reasonable notice and at reasonable times during normal business hours on any Business Day. (b) The Trustee shall deem the person in whose name any Outstanding Revenue Bond appears on the Bond Register as the absolute owner of the Revenue Bond. Payment made to an Owner or on his order shall satisfy and discharge the liability on the Revenue Bond to the extent of the amount paid, and neither the City nor the Trustee shall be affected by any notice to the contrary. Section 411. Mutilated, Lost, Destroyed or Stolen Revenue Bonds. If any Revenue Bond is mutilated, the Trustee, at the expense of the Owner, shall authenticate and deliver a new Revenue Bond in the same principal amount of Authorized Denominations, Bond Payment Date, and interest rate, on surrender of the mutilated Revenue Bond. The Trustee shall cancel the mutilated Revenue Bond and destroy it. On submittal of evidence satisfactory to the Trustee that any Revenue Bond has been lost, destroyed or stolen, together with an indemnity satisfactory to the Trustee, the Trustee, at the expense of the Owner, shall authenticate and deliver a new Revenue Bond of the same principal amount of Authorized Denominations, Bond Payment Date, and interest rate, and numbered as the Trustee shall determine, in substitution for the lost, destroyed or stolen Revenue Bond. The Trustee may require payment of a fee for its expenses under this section. Any Revenue Bond delivered in lieu of a Revenue Bond alleged to be lost, destroyed or stolen shall be as much entitled to the benefits of this Trust Agreement as all other Outstanding Revenue Bonds. The Trustee shall not be required to treat both the original Revenue Bond and any replacement Revenue Bond as Outstanding, but both the original and replacement Revenue Bond shall be treated as one and the same. In lieu of delivering a new Revenue Bond for which principal has become due or has been called for prepayment or redemption, the Trustee may pay the Revenue Bond upon receipt of indemnity satisfactory to it. Section 412. Evidence of Siqnatures of Owners and Ownership of Revenue Bonds. Any request, consent, revocation of consent, or other instrument in writing required or permitted by this Trust Agreement to be signed or executed by Owners may be in any number of concurrent instruments of similar tenor, and may be signed or 12 executed by the Owners or by their attorneys or agents appointed for that purpose by an instrument in writing. Any request or consent of an Owner shall bind every subsequent Owner of the same Revenue Bond or its replacement. The fact and date of the execution of any such instrument may be proved by a certificate, which need not be acknowledged or verified, of an officer of any bank or trust company within the United States of America, or of any notary public or other officer authorized to take acknowledgments of deeds to be recorded in United States jurisdictions that the persons signing the instrument acknowledged before him the execution thereof. Where any such instrument is executed by an officer of a corporation or association or a member of a partnership on behalf of the corporation, association or partnership, the certificate shall also constitute sufficient proof of his authority. The fact of ownership of Revenue Bonds and the amount, Bond Payment Date, interest rate, numbering and date of ownership shall be proved by the Bond Register. The Trustee is not limited to the method of proof set forth in this Article, but may accept any other evidence deemed sufficient. Section 413. Advance Retirement of Refundinq Bonds. (a) The City may provide to the Trustee from time to time a Notice of Advance Retirement of Refunding Bonds in accordance with the Improvement Bond Act of 1915. The Trustee shall thereupon select Revenue Bonds for prepayment on the Interest Payment Date for which the Notice of Advance Retirement is given. Revenue Bonds shall be selected for prepayment in the same principal amounts and of the same maturities as stated in the Notice of Advance Retirement for the Refunding Bonds. (b) On or before the March 2 or September 2 for which the Notice of Advance Retirement is given, the City shall transmit to the Trustee the amount of the principal of Refunding Bonds to be retired pursuant to the notice, together with the redemption premium, if any, thereon and interest thereon to the date of retirement specified in the notice. At the same time the City shall provide to the Trustee a revised maturity schedule (Exhibit B) for the affected Refunding Bonds and a revised maturity schedule (Exhibit C) for the Revenue Bonds. (c) Amounts received by the Trustee pursuant to a Notice of Advance Retirement of Refunding Bonds shall be deposited in the Prepayment Fund and shall be disbursed for the optional prepayment of Revenue Bonds in accordance with Section 417. The Trustee shall endorse on the appropriate Refunding Bonds the date and amount of principal retired in advance of maturity. 13 Section 414. optional Prepayment of Revenue Bonds. (a) Ail or any portion of any Revenue Bond may be prepaid on any Interest Payment Date by paying to the Owner thereof the principal amount thereof, interest to the Interest Payment Date of prepayment and a prepayment premium of a percentage of the principal being prepaid as follows: Prepayment Date Premium September 2, 1994 to September 2, 2003 2.00 March 2, 2004 to September 2, 2004 1.50 March 2, 2005 to September 2, 2005 1.00 March 2, 2006 to September 2, 2006 0.50 March 2, 2007 and thereafter 0.00 (b) Revenue Bonds to be prepaid shall be selected by lot within each maturity in the manner determined by the Trustee. In making the selection the Trustee shall treat each Revenue Bond as representing a number of bonds obtained by dividing the Bond principal amount by $5,000. Prepayment of a portion of any Revenue Bond shall be in the amount of $5,000 or any integral multiple thereof. Section 415. Notice of Prepayment. At the expense of the city the Trustee shall give notice to the affected Owners of the prepayment or redemption of their Revenue Bonds. The notice shall state: * That the whole or a specified portion of the Revenue Bonds is to be prepaid or redeemed; * The date of prepayment or redemption; * The place or places where the prepayment or redemption will be made; * The prepayment or redemption price; * The CUSIP numbers; * The numbers of the Revenue Bonds to be prepaid or redeemed, if fewer than all of the Outstanding Revenue Bonds; * The interest component and maturity date of each Revenue Bond to be prepaid or redeemed in whole or in part; and *.That on the date of prepayment or redemption the principal of and accrued interest on each Revenue Bond or portion thereof to be prepaid or redeemed, together with a prepayment premium, if any, shall become due and payable, and that from and after the date of prepayment or redemption interest on 14 each such Revenue Bond or portion thereof shall cease to accrue. The notice shall be mailed, first-class, postage prepaid, not less than thirty (30) nor more than sixty (60) days before the date of prepayment or redemption. The notice shall be mailed to the Owners of all Revenue Bonds to be prepaid or redeemed as the Owners' names and addresses appear on the Bond Register; to one or more of the Information Services; and by first-class mail, overnight courier or by facsimile transmission to the Securities Depositories. Failure to mail the notice, or any defect in the notice as mailed, shall not affect the validity of the proceedings for prepayment or redemption of the Revenue Bonds. Section 416. Payment on Date of Prepayment. If the Prepayment Fund contains an amount sufficient for the prepayment of the Revenue Bonds selected for prepayment, the Revenue Bonds to be prepaid shall become due and payable on the date of prepayment, and on their presentation and surrender at the Principal Office, the Revenue Bonds shall be paid at their principal amount, together with accrued and unpaid interest to the date of prepayment and any applicable prepayment premium. If moneys in the Prepayment Fund on the Interest Payment Date of prepayment are sufficient to prepay the Revenue Bonds selected for prepayment, interest on the Revenue Bonds selected for prepayment shall cease to accrue as of that date. If sufficient moneys are not available on the Interest Payment Date, interest on the Revenue Bonds shall continue to accrue, until paid, at the rates at which the Revenue Bonds were authenticated and delivered. Moneys held by the Trustee for the prepayment of particular Revenue Bonds shall be held in trust for the account of the Owners of those Revenue Bonds. Section 417. Partial Prepayment of Revenue Bond. On surrender of any Revenue Bond prepaid or redeemed in part only, the Trustee shall authenticate and deliver to the Owner, at the expense of the City, one or more new Revenue Bonds of Authorized Denomination equal in aggregate principal amount to the unprepaid portion of the Revenue Bond surrendered and of the same interest rate and the same Bond Payment Date. The City, the Authority and the Trustee shall be released and discharged from liability to the extent of the payment. Section 418. Non-Presentment of Revenue Bonds. If any Revenue Bond is not presented for payment when its principal becomes due, either at maturity or at the date fixed for prepayment or redemption, and money sufficient to pay the Revenue Bond has been deposited in the Payment Account or the Prepayment Fund, all liability of the City to the Owner for payment of the Revenue Bond shall be discharged, and it shall then be the duty of the Trustee to hold the money in a separate account, without liability for interest thereon to any person, for the benefit of the Owner. The 15 Owner shall thereafter be restricted exclusively to that money for any claim under this Trust Agreement or on the Revenue Bond. Subject to applicable escheat laws, two (2) years after the money was due the Owners or after the City pays the money to the Trustee, whichever is later, the money shall be paid by the Trustee to the City free from the trusts created by this Trust Agreement, and thereafter Owners shall be entitled to look only to the City for payment and then only to the extent of the amount repaid by the Trustee. The City shall not be liable for any interest on money paid to it pursuant to this section and shall not be regarded as a trustee of the money. ARTICLE V COVENANTS; EVENT OF DEFAULT Section 501. Compliance with Foreclosure Covenants. During any period in which the amount in the Reserve Account is less than ninety-five percent (95%) of the Required Reserve, the City shall provide reports in writing (the "Compliance Reports") to the Trustee of compliance with the Foreclosure Covenants. The reports shall be furnished semiannually not later than each Interest Payment Date and not earlier than thirty (30) days before each Interest Payment Date. Each Compliance Report shall state: (1) The date of filing each complaint in foreclosure, and the action number thereof; (2) A description, by special assessment and diagram number and by county assessor's parcel number, of the property addressed in the complaint; and (3) A brief description of the status of the action, including, if applicable, the existence of any injunction or stay order preventing prosecution of the action by the City. Section 502. Event of Default Defined. Either of the following shall constitute an Event of Default by the City under this Agreement: (1) A reduction of the Reserve Account to an amount less than the lesser of (i) eighty percent (80%) of the Required Reserve, or (ii) eight percent (8%) of the principal amount of Revenue Bonds then Outstanding; or (2) At any time that the amount in the Reserve Fund is less than ninety-five percent (95%) of the Required Reserve, the failure or refusal of the City to file Compliance Reports pursuant to Section 501 hereof or to institute and diligently prosecute the judicial foreclosure of property delinquent in 16 the payment of reassessments securing the Refunding Bonds, pursuant to the Foreclosure Covenants. Section 503. Action on Default. The Trustee shall notify the City and the Owners in writing of the occurrence of an Event of Default within five (5) Business Days after the Trustee receives actual knowledge of its occurrence. The Trustee shall not be required to take any further action or seek any remedy pursuant to Section 504 hereof unless requested to do so by the Owners of at least twenty-five percent (25%) in aggregate principal amount of the Outstanding Revenue Bonds and unless indemnified to its satisfaction from any liability or expense. Section 504. Remedies on Default. (a) On the occurrence of an Event of Default, if the default is not cured within thirty (30) days after notice given by the Trustee to the City pursuant to Section 503, the Trustee may ~apply to a court of competent jurisdiction for one or more of the following remedies: (1) A writ of mandate or other judicial order compelling the City to comply with the Foreclosure Covenants; (2) An accounting of amounts posted to the City tax roll and amounts received on account of reassessments securing the Refunding Bonds; (3) Intervention in any foreclosure action instituted pursuant to the Foreclosure Covenants, or in any action challenging the validity of the Refunding Bonds or the reassessments securing them; the City hereby consents to any such intervention; (4) Application for dissolution of any injunction or stay order preventing the City's compliance with the Foreclosure Covenants; and (5) Any other remedy at law or in equity reasonably expected to assist in the protection of the rights and seCurity of the Owners of the Revenue Bonds. (b) On an Event of Default, if the Trustee has taken any judicial or other action at its own discretion or on the request of Owners, the Trustee shall have full power, in the exercise of its discretion for the best interests of the Owners, to continue, discontinue, withdraw, compromise, settle or otherwise dispose of the action. (c) Ail reasonable fees and all costs of the Trustee, its employees, agents and counsel in the pursuit of these remedies shall be paid to the Trustee by the City within thirty (30) days after billing. 17 Section 505. Riqhts of Owners of Revenue Bonds. No Owner shall have the right to institute any judicial action for any remedy under this Agreement, unless: * The Owner has first given the Trustee written notice of the occurrence of an Event of Default; and * The Owners of at least twenty-five percent (25%) in aggregate principal amount of Outstanding Revenue Bonds have requested the Trustee in writing to exercise the powers hereinbefore granted or to institute the action in its own name; and * The Owners have tendered indemnity satisfactory to the Trustee against the Trustee's expenses and liabilities to be incurred in complying with their request; and * The Trustee has refused or omitted to comply with the request for a period of sixty (60) days after the written request has been received by, and the tender of indemnity made to, the Trustee. Such notification, request, tender of indemnity and refusal or omission are conditions precedent to the exercise by an Owner of any remedy hereunder. No one or more Owners shall have the power to enforce any right under this Agreement, except in the manner herein provided. Judicial proceedings resulting from an Event of Default shall be for the equal benefit of all Owners of the Outstanding Revenue Bonds. Section 506. Non-Waiver. A delay or omission by the Trustee to exercise a right or power arising on an Event of Default shall not impair that right or power or be construed as a waiver of, or acquiescence in, the Event of Default. Every power and remedy possessed by the Trustee may be exercised from time to time and as often as deemed expedient by the Trustee. Section 507. Remedies Not Exclusive. Ail remedies afforded to the Trustee by law or by this Agreement are cumulative: the exercise of a remedy shall not impair the right of the Trustee to exercise any other remedy, at the same time or from time to time. Section 508. No Obligation by City to Owners. Except for the payment of amounts due under the Refunding Bonds and the performance of other City covenants contained in the proceedings for issuance of the Refunding Bonds and in this Agreement, the City shall have no obligation or liability to any other party or to the Owners arising from this Trust Agreement, the performance of the Trustee, the terms, execution, delivery or transfer of the Revenue Bonds, or the distribution of payments to the Owners by the Trustee. 18 Section 509. No Liability to Owners for Payment. Except as provided herein the Trustee shall have no obligation nor liability to the Owners for the City's payments under the Refunding Bonds or the city's performance of any other covenant of this Agreement. Section 510. Tax Covenants. (a) Neither the City nor the Authority shall take or permit any action that would cause interest on the Revenue Bonds or the Refunding Bonds to be included in the gross income of recipients thereof for purposes of federal income taxation. (b) Neither the City nor the Authority shall take or permit any action that would cause any of the Revenue Bonds or the Refunding Bonds to be an "arbitrage bond" within the meaning of Section 148 of the Internal Revenue Code of 1986, as amended. ARTICLE VI AMENDMENT; DEFEASANCE; ADMINISTRATIVE PROVISIONS Section 601. Amendment. This Trust Agreement may be amended in writing by a supplemental agreement among all of the parties: * Without the consent of the Owners, to add to the rights and privileges of the Trustee, or to cure a defective provision or settle a question arising from an uncertainty, ambiguity, or omission in this Trust Agreement without adversely affecting the interests of the Owners; or * With the written consent of the Owners of a majority in aggregate principal amount of Outstanding Revenue Bonds, to make any other amendment. This section does not authorize an amendment that causes the interest on the Revenue Bonds to become subject to California personal income tax or to be included in the gross income of the Owners for federal income tax purposes. The parties may rely on the opinion of Bond Counsel in the application of this section. Section 602. No Impairment of Security. The City shall not reduce any reassessment securing the Refunding Bonds or enter into any settlement of a claim or dispute respecting the Refunding Bonds or the reassessments securing them, 'except upon the written consent of the Trustee. Such consent may be based on an opinion of counsel or certificate of the city or the Authority and the Trustee shall be completely protected in relying thereon. This section shall not be construed to prevent the City from dividing reassessments to 19 conform with the division of assessed parcels as provided by the Improvement Bond Act of 1915. Section 603. Defeasance. Upon defeasance of the Revenue Bonds, even though all Revenue Bonds have not been presented for payment, all obligations of the Authority, the Trustee and the City hereunder shall end, except only the obligation of the City to compensate and indemnify the Trustee and the obligation of the Trustee to pay all amounts due to the Owners. Defeasance will have occurred when all Outstanding Revenue Bonds are paid and discharged: (a) By paying the principal of and interest on all Outstanding Revenue Bonds as they become due and payable; or (b) By prepayment of all Outstanding Revenue Bonds; or (c) By irrevocably depositing with the Trustee cash which, together with amounts then on deposit in the Payment Account, Prepayment Fund, and Reserve Account are sufficient to pay the principal of and interest on all Outstanding Revenue Bonds; or (d) By irrevocably depositing with the Trustee Federal Securities which, together with moneys then on deposit in the Payment Account, Prepayment Fund, and Reserve Account, together with interest to be received thereon, will be sufficient to pay the principal or and interest on all Outstanding Revenue Bonds at or before their respective Interest Payment Dates, in the written opinion of an independent certified public accountant given to the Trustee. Section 604. Recordinq and Filinq. The Trustee shall not be responsible for recording or filing this Agreement or supplemental instruments or documents. Section 605. Trustee to Keep Records. The Trustee shall keep books and records of all money received and disbursed by it under this Trust Agreement. They shall be available for inspection upon reasonable advance notice and at reasonable times during normal business hours on Business Days, by the City, the Authority or Owners representing five percent (5%) in aggregate principal amount of Outstanding Revenue Bonds, or their respective designees. 20 IN WITNESS WHEREOF, the parties hereto have executed this Trust Agreement the day and year first above written. CITY OF GILROY, a municipal corporation of the State of California Noble Shaw, Director of Finance GILROY PUBLIC FACILITIES FINANC~By ~/j~AUTHORITY Chairman UNION BANK, as Trustee By Authorized Officer 21 EXHIBIT A DEFINITIONS Accounts. The term "Accounts" means the funds and accounts established by Section 301 of this Trust Agreement. Authority. The term "Authority" means the Gilroy Public Facilities Financing Authority, a joint powers authority of the City of Gilroy and the Community Redevelopment Agency of the City of Gilroy, formed pursuant to Article 1 (Section 6500 et seq.) of Chapter 5 of Division 7 of Title 1 of the California Government Code. Authorized Denominations. The term "Authorized Denominations" means the authorized denominations of the Bonds, which shall be $5,000 or any integral multiple thereof. Authorized Officer. The term "Authorized Officer", when used with reference to the Authority, means its Chair, its Vice Chair or its Treasurer; when used with reference to the City, means the Mayor of the City Council, city Manager, City Treasurer, City Director of Finance or their respective deputies or assistants or any other City officer or employee designated by the City Manager as an Authorized Officer for purposes of this agreement; when used with reference to the Trustee means any officer within the Corporate Trust Department (or any vice president, assistant vice president, assistant secretary or any other officer or assistant officer of the Trustee customarily performing functions similar to those performed by the persons who at the time shall be such officers, respectively), and also means, with respect to a particular corporate trust matter, any other officer of the Trustee to whom the matter is referred by the Trustee because of that officer's knowledge of and familiarity with the particular subject. Bond Counsel. The term "Bond Counsel" means an attorney or a firm of attorneys, acceptable to the City, of nationally recognized standing in matters pertaining to the tax-exempt nature of interest on bonds issued by states and their political subdivisions, duly admitted to the practice of law before the highest court of any state of the United States of America. Bond Payment Date. The term "Bond Payment Date" means September 2 of each year during the term of the Bonds commencing September 2, 1994. Bond Reqister. The term "Bond Register" means the books for registration of the Bonds maintained by the Trustee pursuant to Section 410 of this Trust Agreement. 22 Bonds. herein. The term "Bonds" means the Revenue Bonds as defined Business Day. The term "Business Day" means any day on which banks in San Francisco and Los Angeles, California, are open for business, except Saturday, Sunday or a legal holiday. city. The term "city" means the City of Gilroy, a municipal corporation of the State of California. Closinq Date. The term "Closing Date" means the date on which the Bonds are authenticated by the Trustee and delivered to the first purchaser thereof. Compliance Report. The term "Compliance Report" means the report described in Section 501 of this Trust Agreement, by which the City reports to the Trustee the institution and progress of judicial foreclosure proceedings against property delinquent in the payment of reassessments securing the Refunding Bonds. Defeasance Escrow Aqreement. The term "Defeasance Escrow Agreement" means the Defeasance Escrow Agreement dated as of March 21, 1994, between the City and Union Bank. Delivery Costs. The term "Delivery Costs" means all costs of payment or reimbursement for execution, sale and delivery of the Refunding Bonds and the Revenue Bonds, including without limitation costs paid or incurred by the city, the Authority or the Trustee for filing, preparation, printing, distribution, reproduction and binding of disclosure documents, initial fees and charges of the Trustee and its counsel, financing discounts, computer analysis, legal and regulatory fees, charges and reimbursements, financial and other professional ratings, insurance and fees for authentication, registration, transportation and safekeeping of bonds. Event of Default. The term "Event of Default" means an event of default as defined in Section 502 of this Trust Agreement. Federal Securities. The term "Federal Securities" means United States Treasury notes, bonds, bills or certificates of indebtedness or obligations for which the full faith and credit of the United States are pledged for the timely payment of principal and interest. Fiscal Year. The term "Fiscal Year" means the one-year period beginning on July 1 and ending on June 30. Foreclosure Covenant. The term "Foreclosure Covenant" means a covenant made by the City for the benefit of the owners of the Refunding Bonds, by which the City agrees to institute and diligently prosecute judicial foreclosure proceedings against 23 property delinquent in the payment of reassessment installments securing the Refunding Bonds. Information Services. The term "Information Services" means Financial Information, Inc.'s "Daily Called Bond Service", 30 Montgomery Street, Floor 10, Jersey City, New Jersey 07302, Attention: Editor; Kenny Information Services' "Called Bond Service", 55 Broad Street, Floor 28, New York, New York 10004; Moody's Investors Service "Municipal and Government", 99 Church Street, Floor 8, New York, New York 10007, Attention: Municipal News Reports; Standard and Poor's Corporation "Called Bond Record", 25 Broadway, Floor 3, New York, New York 10004; and, in accordance with then current guidelines of the Securities and Exchange Commission, such other addresses and/or such other services providing information with respect to called bonds as the City may designate in a written request of the City delivered to the Trustee. Interest Payment Dates. The term "Interest Payment Dates" means March 2 and September 2 of each year during the term of the Bonds commencing with September 2, 1994. # Notice of Advance Retirement. The term "Notice of Advance Retirement" means the notice required by Section 8751 of the California Streets and Highways Code (being a part of the Improvement Bond Act of 1915) by which the City may advance the maturity of any Refunding Bond. Outstandinq. The term "Outstanding" when used with reference to the Revenue Bonds as of a particular date means all Bonds theretofore delivered except: (a) all Bonds cancelled by the Trustee on or before that date; (b) all Bonds in substitution for which other Bonds have been delivered pursuant to this Trust Agreement, and (c) Bonds defeased under Section 603 of this Trust Agreement. Owner. The term "Owner", when used with reference to the Revenue Bonds, means the owner of any Outstanding Bond as shown on the Bond Register. Payment Account. The term "Payment Account" means the account by that name, within the Redemption Fund, established by Section 301 of this Trust Agreement Permitted Investments. means: The term "Permitted Investments" A. Federal Securities. B. Obligations of any of the following federal agencies which obligations represent full faith and credit of the United States of America, including: 24 Export - Import Bank Farmers Home Administration General Services Administration U.S. Maritime Administration Small Business Administration Government National Mortgage Association (GNMA) U.S. Department of Housing & Urban Development (PHA's) Federal Housing Administration; Tennessee Valley Authority C. Bonds, notes or other evidences of indebtedness rated "AAA" by Standard & Poor's Corporation and "Aaa" by Moody's Investors Service issued by the Federal National Mortgage Association or the Federal Home Loan Mortgage Corporation with remaining maturities not exceeding three years; D. U.S. dollar denominated deposit accounts, federal funds and banker's acceptances with domestic commercial banks (including the Trustee) which have a rating on their short term certificates of deposit on the date of purchase of "A-i" or "A-l+" by Standard & Poor's and "P-i" by Moody's and maturing no more than 360 days after the date of purchase. (Ratings on holding companies are not considered as the rating of the bank); E. Commercial paper which is rated at the time of purchase in the single highest classification, "A-l+" by Standard & Poor's and "P-i" by Moody's Investors Service and which matures not more than 270 days after the date of purchase; F. Investments in a money market fund rated "AAAm" or "AAAm-G" or better by Standard & Poor's Corporation, including such funds for which the Trustee or an affiliate acts as investment advisor or provides other services; G. Pre-refunded Municipal Obligations defined as follows: Any bonds or other obligations of any state of the United States of America or of any agency, instrumentality or local governmental unit of any such state which are not callable at the option of the obligor prior to maturity or as to which irrevocable instructions have been given by the obligor to call on the date specified in the notice; and which are rated, based on the escrow, in the highest rating category of Standard & Poor's Corporation and Moody's Investors Service, Inc. or any successors thereto; H. Investment agreements, guaranteed investment contracts, funding agreements, or any other form of corporate note representing the unconditional obligations of entities: (a) the unsecured long-term debt obligations or claims-paying ability ratings of which are rated in the top two rating categories of Moody's Investors Service, Inc. or Standard & Poor's Corporation, or (b) the short-term debt obligation 25 rated in the two highest categories of either of such rating agencies; and I. Repurchase agreements with financial institutions insured by the FDIC or FSLIC, or any broker-dealer with "retail customers" which falls under the jurisdiction of the Securities Investors Protection Corporation (SIPC), provided that (a) the over-collateralization is at one hundred two percent (102%), computed weekly, consisting of such securities as described in A through E above; (b) a third party custodian, the Trustee or the Federal Reserve Bank shall have possession of such obligations; (c) the Trustee shall have perfected a first priority security interest in such obligations; and (d) failure to maintain the requisite collateral percentage will require the Trustee to liquidate the collateral. Person. The term "Person" means a natural person, corporation, association or public agency. Prepayment Fund. The term "Prepayment Fund" means the fund by that name established by Section 301 of this Trust Agreement. Principal Office. The term "Principal office" means the corporate trust office of the Trustee at which it conducts its corporate trust business in Los Angeles, California or any other office of the Trustee designated by the Trustee for the purpose from time to time, including for registration, transfer, exchange and payment of Revenue Bonds. Record Date. The term "Record Date" means the close of business on the fifteenth day of the month preceding each Interest Payment Date, whether or not the fifteenth day is a Business Day. Redemption Fund. The term "Redemption Fund" means the fund of that name established by Section 301 of this Trust Agreement, containing within it the Payment Account and the Reserve Account. Redemption Payments. The term "Redemption Payments" means payments of principal of and interest on the Refunding Bonds, made by the City to the Trustee as assignee of the Authority. Refundinq Bonds. The term "Refunding Bonds" means bonds issued by the City pursuant to the Refunding Act of 1984 for 1915 Improvement Act Bonds and secured by reassessments in Consolidated Refunding District No. 1994-1. Required Reserve. The term "Required Reserve" means the amount stated and defined as such in Section 302 of this Trust Agreement. 26 Reserve Account. The term "Reserve Account" means the account by that name, within the Redemption Fund, established by Section 301 of this Trust Agreement. Revenue Bonds. The term "Revenue Bonds" means bonds of the Authority'authorized on March 21, 1994 to be issued pursuant to the Marks-Roos Local Bond Pooling Act of 1985 (Section 6584 et seq., California Government Code) for the purpose of purchasing the Refunding Bonds. Securities Depositories. The term "Securities Depositories" means: The Depository Trust Company, 711 Stewart Avenue, Garden City, New York 11530, Fax (516) 227-4039 or -4190; Midwest Securities Trust Company, Capital Structures-Call Notification, 440 South LaSalle Street, Chicago,' Illinois 60605, Fax (312) 663-2343; Philadelphia Depository Trust Company, Reorganization Division, 1900 Market Street, Philadelphia, Pennsylvania 19203, Attention: Bond Department, Fax (215) 496-5058; and, in accordance with then current guidelines of the Securities and Exchange Commission, other addresses that these depositories may specify and/or other securities depositories designated in a written request of the City delivered to the Trustee. Trust Aqreement. The term "Trust Agreement" means this Trust Agreement dated as of March 21, 1994, among the Trustee, the City and the Authority. Trustee. The term "Trustee" means Union Bank acting as Trustee under this Trust Agreement. 27 EXHIBIT B YR DEBT SERVICE SCHEDULE GILROY Consolidated Refunding District No. 1994-1 03/23/94 PRINCIPAL RATE* INTEREST DEBT SERVICE OUTSTANDING EFF%* 95 396,000.00 7.030 791,903.55 1,187,903.55 7,501,000.00 7.526 96 417,000.00 7.030 536,686.50 953,686.50 7,105,000.00 7.554 97 458,000.00 7.030 507,371.40 965,371.40 6,688,000.00 7.586 98 453,000.00 7.030 475,174.00 928,174.00 6,230,000.00 7.627 99 397,000.00 7.530 443,328.10 840,328.10 5,777,000.00 7.674 00 430,000.00 7.530 413,434.00 843,434.00 5,380,000.00 7.685 01 451,000.00 7.530 381,055.00 832,055.00 4,950,000.00 7.698 02 491,000.00 7.530 347,094.70 838,094.70 4,499,000.00 7.715 03 521,000.00 7.530 310,122.40 831,122.40 4,008,000.00 7.738 04 570,000.00 7.530 270,891.10 840,891.10 3,487,000.00 7.769 05 608,000.00 7.530 227,970.10 835,970.10 2,917,000.00 7.815 06 645,000.00 7.530 182,187.70 827,187.70 2,309,000.00 7.890 07 287,000.00 8.030 133,619.20 420,619.20 1,664,000.00 8.030 08 310,000.00 8.030 110,573.10 420,573.10 1,377,000.00 8.030 09 332,000.00 8.030 85,680.10 417,680.10 1,067,000.00 8.030 10 359,000.00 8.030 59,020.50 418,020.50 735,000.00 8.030 11 376,000.00 8.030 30,192.80 406,192.80 376,000.00 8.030 7,501,000.00 5,306,304.25 12,807,304.25 * "Rate" Is on Bonds Maturing Each Year. "Eff%" Is on Ail Outstanding Bonds. Bond Date: 04/07/94 Yield-to-Maturity:7.646140% Denomination: $1,000 or Multiples Net Rate(with Discount) :7.680141% Bonds Mature on September 2 Average Interest Rate:7.680141% Weighted Average Maturity:9.211 Years Advance Redemption Premium: Varies First Interest Payment on 09/02/94 Is $227,378.25,Representing 145 Days or 0.40278 Years of Accrued Interest. Interest of $18,702.93 Has Been Capitalized or Otherwise Funded. 28 EXHIBIT C DEBT SERVICE SCHEDULE GILROY PUB.FAC.FIN.AUTHORITY 1994 Authority Revenue Bonds YR PRINCIPAL RATE* INTEREST DEBT SERVICE 03/24/94 OUTSTANDING EFF%* 94 35,000.00 3.000 207,986.39 242,986.39 8,615,000.00 5.994 95 490,000.00 4.250 515,330.00 1,005,330.00 8,580,000.00 6.006 96 500,000.00 4.750 494,505.00 994,505.00 8,090,000.00 6.113 97 540,000.00 5.250 470,755.00 1,010,755.00 7,590,000.00 6.202 98 530,000.00 5.500 442,405.00 972,405.00 7,050,000.00 6.275 99 470,000.00 5.750 413,255.00 883,255.00 6,520,000.00 6.338 00 500,000.00 5.900 386,230.00 886,230.00 6,050,000.00 6.384 01 520,000.00 6.000 356,730.00 876,730.00 5,550,000.00 6.428 02 555,000.00 6.100 325,530.00 880,530.00 5,030,000.00 6.472 03 585,000.00 6.200 291,675.00 876,675.00 4,475,000.00 6.518 04 630,000.00 6.300 255,405.00 885,405.00 3,890,000.00 6.566 05 665,000.00 6.400 215,715.00 880,715.00 3,260,000.00 6.617 06 695,000.00 6.500 173,155.00 868,155.00 2,595,000.00 6.673 07 335,000.00 6.600 127,980.00 462,980.00 1,900,000.00 6.736 08 360,000.00 6.700 105,870.00 465,870.00 1,565,000.00 6.765 09 380,000.00 6.750 81,750.00 461,750.00 1,205,000.00 6.784 10 405,000.00 6.800 56,100.00 461,100.00 825,000.00 6.800 11 420,000.00 6.800 28,560.00 448,560.00 420,000.00 6.800 8,615,000.00 4,948,936.39 13,563,936.39 * "Rate" Is on Bonds Maturing Each Year. "Eff%" Is on Ail Outstanding Bonds. Bond Date: 04/07/94 Yield-to-Maturity:6.287650% Denomination: $5,000 or Multiples Net Rate(with Discount):6.615405% Bonds Mature on September 2 Average Interest Rate:6.339513% Weighted Average Maturity:9.062 Years Advance Redemption Premium: Varies First Interest Payment on 09/02/94 Is $207,986.39,Representing 145 Days or 0.40278 Years of Accrued Interest. No Capitalized Interest Has Been Budgeted. 29 EXHIBIT D FORM OF REVENUE BOND REGISTERED REGISTERED 1994 AUTHORITY REVENUE BOND GILROY PUBLIC FACILITIES FINANCING AUTHORITY CITY OF GILROY, SANTA CLARA COUNTY, CALIFORNIA SERIES NO. 1994 Rate of Interest: Maturity Date: % September 2, Bond Date April 7, 1994 REGISTERED OWNER: Cusip: PRINCIPAL AMOUNT: DOLLARS THIS IS TO CERTIFY that, subject to the provisions hereof for prepayment, the registered owner stated above or registered assigns (the "Owner") is entitled to receive on the maturity date stated above (the "Bond Payment Date"), the principal amount stated above. This Bond has been authorized for issuance by resolution (the "Resolution") of the Gilroy Public Facilities Financing Authority (the "Authority") pursuant to the provisions of the Marks-Roos Local Bond Pooling Act of 1985 of the State of California. This Bond (the "Bond") evidences a direct interest in amounts received by the Authority as payments of the principal of, and interest on, certain refunding bonds (the "Refunding Bonds") issued by the City of Gilroy, Santa Clara County, California (the "City") and held by the Authority. The payments on the Refunding Bonds have been assigned to Union Bank, as Trustee (the "Trustee") having a corporate trust office (the "Principal office") at Los Angeles, California, pursuant to a trust agreement dated as of March 21, 1994 (the "Trust Agreement") among the Authority, the City and the Trustee. The aforesaid principal amount is payable subject to the terms of the Trust Agreement and represents a portion of the payments on the Refunding Bonds coming due on and before the Bond Payment Date. The Owner is also entitled to receive, subject to the terms of the Trust Agreement, on September 2, 1994, and semiannually thereafter on September 2 and March 2 of each year (the "Interest Payment Dates") to and including the Bond Payment Date or the date of prepayment, whichever is earlier, semiannual interest on the principal of this Bond at the per annum rate of interest stated above. The principal and redemption premiums, if any, are payable at the Principal Office of Trustee, or its successor, as Trustee. 30 Said amounts are payable in lawful money of the United States of America. Amounts representing principal are payable at the Principal office; amounts representing interest are payable by check of the Trustee mailed by first-class mail on each Interest Payment Date to the Owner of record on the fifteenth day of the month preceding the Interest Payment Date (except as otherwise described herein for interest paid to an account in the Continental United States of America by wire transfer as requested in writing no later than the applicable Record Date by certain owners of $1,000,000 or more in aggregate principal amount of Bonds). REFERENCE IS HEREBY MADE TO THE FURTHER PROVISIONS OF THE BOND SET FORTH ON THE REVERSE HEREOF WHICH FURTHER PROVISIONS SHALL FOR ALL PURPOSES HAVE THE SAME EFFECT AS IF SET FORTH IN THIS PLACE. The Trustee has no obligation or liability to the Owners to make payments of principal or interest with respect to the Bonds. The Trustee's sole obligations are to administer, for the benefit of the Owners, the various funds and accounts established under the Trust Agreement. The Trustee does not warrant the recitals of fact herein. The City and the Authority have covenanted that all conditions precedent to the delivery of the Bonds, whether required by law or by the Trust Agreement, have occurred or been performed, and that the Bonds are within every limit prescribed by law. This Bond shall not be entitled to any benefit under the Trust Agreement or become valid or obligatory for any purpose until the certificate of authentication and registration hereon endorsed shall have been dated and signed by the Trustee. IN WITNESS WHEREOF, the Authority has caused this Bond to be signed by its Chair and its Secretary and has caused its corporate seal to be affixed, all as of the 7th day of April, 1994. (SEAL) GILROY~J.~LIC FAC L TIES FINANCING AUTHORITY Chair of the aut~it~ .l Secretary of the Authority ~j' CERTIFICATE OF AUTHENTICATION AND REGISTRATION This is one of the Bonds described in the within-mentioned Trust Agreement, which has been authenticated and registered on UNION BANK as Trustee (Authorized signatory) 31 (REVERSE OF BOND) 1994 AUTHORITY REVENUE BOND GILROY PUBLIC FACILITIES FINANCING AUTHORITY CITY OF GILROY, SANTA CLARA COUNTY, CALIFORNIA SERIES NO. 1994 This Bond has been authenticated by the Trustee pursuant to the terms of the Trust Agreement. Copies of the Trust Agreement are on file in the offices of the Authority and the city and at the Principal office; reference is made to the Trust Agreement and any amendments thereto for a description of the covenants of the Authority securing the payments on this Bond, the nature, extent and manner of enforcement of the covenants, the rights and remedies of the Owners and the terms and conditions on which the Bonds are delivered thereunder. To the extent and in the manner permitted by the terms thereof, the provisions of the Trust Agreement may be amended by the parties thereto with the written consent of the Owners of at least a majority in principal amount of the Bonds then outstanding, or without that consent for an amendment not adversely affecting the interests of the Owners. The registration of this Bond shall be transferable only on the Bond Register, which shall be kept at the Principal Office, on surrender hereof together with a written instrument of transfer satisfactory to the Trustee executed by the Owner or his duly authorized attorney. Thereupon the Trustee shall provide one or more new registered Bonds of the same aggregate principal amount, Bond Payment Date and interest rate as the surrendered Bond, registered in the name. of the transferee. The Bonds are delivered in the form of registered Bonds in denominations of $5,000 each or any integral multiple thereof, and on surrender thereof at the Principal office with a written request for exchange executed by the Owner or his attorney duly authorized in writing, may be exchanged for an equal aggregate principal amount of Bonds of any other authorized denominations, of the same Bond Payment Date, and with the same interest rate as the surrendered Bond. Ail or a portion of any Bond is subject to prepayment on any Interest Payment Date by paying to the Owner thereof the principal amount thereof, interest to the Interest Payment Date of prepayment and a prepayment premium of a percentage of the principal being prepaid as follows: 32 Prepayment Date Premium September 2, 1994 to September 2, 2003 2.00 March 2, 2004 to September 2, 2004 1.50 March 2, 2005 to September 2, 2005 1.00 March 2, 2006 to September 2, 2006 0.50 March 2, 2007 and thereafter 0.00 The Trustee shall determine the manner of prepayment by lot.; but the portion of any Bond to be prepaid shall be in the principal amount of $5,000 or an integral multiple thereof, and in selecting portions of Bonds for prepayment, the Trustee shall treat each Bond as representing the number of Bonds obtained by dividing its principal amount by $5,000. Notice of prepayment shall be mailed by first-class mail to the affected Owners, postage prepaid, not less than thirty (30) nor more than sixty (60) days before the date of prepayment. Failure to mail the notice, or any defect in the notice as mailed, shall not affect the validity of the proceedings for prepayment of the Bonds. The obligation of the City to make payments on the Refunding Bonds is a limited obligation, subject to the receipt of installment payments of reassessments securing the Refunding Bonds. The obligation of the Authority to make payments on the Bonds is limited to amounts deposited with the Trustee in the Payment Account and the Reserve Account, all as specified in the Trust Agreement. The obligations of the Authority and the City under the Trust Agreement constitute neither a debt nor a pledge of the faith and credit of the City, the Authority, the Trustee, the State of California or any other political subdivision of the State. I hereby certify that the following is a correct copy of the signed legal opinion of STURGIS, NESS, BRUNSELL & ASSAF, a professional corporation, Emeryville, California, on file in my office. Secretary of the Authority 33 (Form of Assignment) ASSIGNMENT For value received the undersigned do(es) hereby sell, assign and transfer unto the within registered Bond and hereby irrevocably constitute(s) and appoint(s) to transfer the same on the Bond register of the Trustee with full power of substitution in the premises. Dated: Signature: Note: The signature(s) on this Assignment must correspond with the name(s) as written on the face of the within registered Bond in every particular without alteration or enlargement or any change whatsoever. Signature Guaranteed: Note: This signature must be guaranteed by an eligible gurantor. 34