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ORD 95-53 GENERAL OBLIGATION REFUNDING BONDSORDINANCE NO. 95-53 AN ORDINANCE of the City of Bainbridge Island, Washington, relating to contracting indebtedness; providing for the issuance of $2,450,000 par value of Limited Tax General Obligation Refunding Bonds, 1995, of the City to provide part of the funds with which to pay the cost of advance refunding the City's outstanding $2,400,000 Water and Sewer Revenue Bonds, 1989, and paying the administrative costs of such refunding and the costs of issuance and sale of such bonds; fixing the date, form, maturities, interest rates, terms and covenants of the bonds; establishing a bond redemption fund; providing for and authorizing the purchase of certain obligations out of the proceeds of the sale of the bonds herein authorized and for the use and application of the money derived from those investments; authorizing the execution of an agreement with First Interstate Bank of Washington, N.A. of Seatfie,Washington, as refunding trustee; providing for the call, payment and redemption of the outstanding bonds to be refunded; and approving the sale and providing for the delivery of the bonds to Pacific Crest Securities of Seattle, Washington. WHEREAS, pursuant to Ordinance No. 89-50, the City of Winslow, Washington (now the City of Balnbridge Island, Washington) heretofore issued its $2,400,000 par value Water and Sewer Revenue Bonds, 1989 (the "1989 Bonds"), for the putpose of paying the cost of carrying out a system or plan of additions to and betterments and extensions of the waterworks utility of the City and capitalizing a reserve for those bonds, and by that ordinance reserved the right to redeem the 1989 Bonds prior to their maturity on November 1, 1999, at a price of par plus accrued interest to the date fixed for redemption; and WHEREAS, there are presently outstanding $2,400,000 par value of 1989 Bonds maturing on November 1 of each of the years 1998 through 2003, inclusive, and in 2009, and bearing various interest rates from 7.10% to 7.60% (the "Refunded Bonds"); and WHEREAS, after due consideration, it appears to the City Council that the Refunded Bonds may be refunded by the issuance and sale of the limited tax general obligation refunding bonds authorized herein (the "Bonds") so that a substantial savings will be effected by the difference between the principal and interest cost over the life of the Bonds and the principal and interest cost over the life of the Refunded Bonds but for such refunding, which refunding will be effected by: (a) The issuance of the Bonds and the payment of the costs of the issuance of the Bonds and the costs of the refunding; (b) The payment of principal of and interest on the Refunded Bonds when due up to and including November 1, 1999, and the call, payment and redemption on November 1, 1999, of all of the then-outstanding Refunded Bonds at a price of par; 0211114.02 ']' and WHEREAS, to effect that refunding in the manner that will be most advantageous to the City it is found necessary and advisable that certain Acquired Obligations (hereinafter defined) bearing interest and maturing at such time or times as necessary to accomplish the refunding as aforesaid be purchased out of the proceeds of the Bonds and other money of the City; and WHEREAS, the City deems it to be in the best interests of the City to issue and sell the Bonds to pay pan of the cost of advance refunding the Refunded Bonds and to pay the administrative costs of such refunding and the costs of issuance and sale of the Bonds; NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF BAINBRIDGE ISLAND, WASHINGTON, DO ORDAIN as follows: Section 1. Debt Capacity. The assessed valuation of the taxable property within the City as ascertained by the last preceding assessment for City purposes for the calendar year 1994 is $1,858,795,349, and the City has outstanding general indebtedness evidenced by limited tax general obligation bonds (excluding the amount of Refunded Bonds) in the principal amount of $1,915,000 incurred within the limit of up to 1-1/2% of the value of the taxable property within the City permitted for general municipal purposes without a vote of the qualified voters therein, and the amount of indebtedness for which bonds are authorized herein to be issued is $2,450,000. Section 2. Authorization of Bonds. The City shall borrow money on the credit of the City and issue negotiable limited tax general obligation refunding bonds evidencing that indebtedness in the amount of $2,450,000 to provide the funds to pay the cost of accomplishing the following (the "Refunding Plan"): (a) the placement of sufficient proceeds of the Bonds which, with other money of the City, if necessary, will acquire those United States Treasury Certificates of Indebtedness, Notes and Bonds -- State and Local Government Series and other direct, noncallable obligations of the United States of America (the "Acquired Obligations") to be deposited, with cash, if necessary, with the Refunding Trustee; Co) the payment of the principal of and interest on the Refunded Bonds when due up to and including November 1, 1999, and the call, payment and redemption on November 1, 1999, of all of the then-outstanding Refunded Bonds at a price of par; (c) the payment of the costs of issuing the Bonds and the costs of carrying out the foregoing elements of the Refunding Plan. The general indebtedness to be incurred shall be within the limit of up to 1-1/2% of the value of the taxable property within the City permitted for general municipal purposes without a vote of the qualified voters therein. 0211114.02 $~ction 3. Description of Bonds. The bonds shall be called Limited Tax General Obligation Refunding Bonds, 1995, of the City (the "Bonds"); shall be in the aggregate principal amount of $2,450,000; shall be dated December 1, 1995; shall be in the denomination of $5,000 or any integral multiple thereof within a single maturity; shall be numbered separately in the manner and with any additional designation as the Bond Registrar (collectively, the fiscal agencies of the State of Washington located in Seattle, Washington, and New York, New York) deems necessary for purposes of identification; shall bear interest (computed on the basis of a 360-day year of twelve 30-day months) payable semiannually on each May 1 and November 1, commencing May 1, 1996, to the maturity or earlier redemption of the Bonds; and shall mature on November 1 in years and amounts and bear interest at the rates per annum as follows: Maturity Interest Years Amounts Rates 1996 $ 40,000 3.80% 1997 20,000 4.00 1998 35,000 4.10 1999 145,000 4.15 2000 180,000 4.25 2001 180,000 4.35 2002 190,000 4.45 2003 205,000 4.55 2004 210,000 4.65 2005 225,000 4.75 2006 235,000 4.85 2007 250,000 4.95 2008 260,000 5.05 2009 275,000 5.15 Section 4. Registration and Transfer of Bonds. The Bonds shall be issued only in registered form as to both principal and interest and shall be recorded on books or records maintained by the Bond Registrar (the "Bond Register"). The Bond Register shall contain the name and mailing address of the owner of each Bond and the principal amount and number of each of the Bonds held by each owner. Bonds surrendered to the Bond Registrar may be exchanged for Bonds in any authorized denomination of an equal aggregate principal mount and of the same interest rate and maturity. Bonds may be transferred only if endorsed in the manner provided thereon and surrendered to the Bond Registrar. Any exchange or transfer shall be without cost to the owner or transferee. The Bond Registrar shall not be obligated to exchange or transfer any Bond during the 15 days preceding any principal payment or redemption date. Section 5. Payment of Bonds. Both principal of and interest on the Bonds shall be payable in lawful money of the United States of America. Interest on the Bonds shall be paid by checks or drafts of the Bond Registrar mailed on the interest payment date to the registered owners at the addresses appearing on the Bond Register on the 15th day of the month preceding the interest ff211114.02 '3- payment date. Principal of the Bonds shall be payable upon presentation and surrender of the Bonds by the registered owners at either of the principal offices of the Bond Registrar at the option of the owners. Section 6. Optional Redemption and Open Market Purchase of Bonds. Bonds maturing in the years 1996 through 2005, inclusive, shall be issued without the right or option of the City to redeem those Bonds prior to their stated maturity dates. The City reserves the right and option to redeem Bonds maturing on or after November 1, 2006, prior to their stated maturity dates on or alter November 1, 2005, as a whole at any time or in part on any interest payment date within one or more maturities selected by the City (and by lot within a maturity in such manner as the Bond Registrar shall determine), at par plus accrued interest to the date fixed for redemption. Portions of the principal amount of any Bond, in installments of $5,000 or any integral multiple thereof, may be redeemed. If less than all of the principal amount of any Bond is redeemed, upon surrender of that Bond at either of the principal offices of the Bond Registrar, there shall be issued to the registered owner, without charge therefor, a new Bond (or Bonds, at the option of the registered owner) of the same maturity and interest rate in any of the denominations authorized by this ordinance in the aggregate principal amount remaining unredeemed. The City further reserves the right and option to purchase any or all of the Bonds in the open market at any time at any price acceptable to the City plus accrued interest to the date of purchase. All Bonds purchased or redeemed under this section shall be caneeled. Section 7. Notice of Redemption. The City shall cause notice of any intended redemption of Bonds to be given not less than 30 nor more than 60 days prior to the date fixed for redemption by first-class mall, postage prepaid, to the registered owner of any Bond to be redeemed at the address appearing on the Bond Register at the time the Bond Registrar prepares the notice, and the requirements of this sentence shall be deemed to have been ful~lled when notice has been mailed as so provided, whether or not it is actually received by the owner of any Bond. Interest on Bonds called for redemption shall cease to accrue on the date fixed for redemption unless the Bond or Bonds called are not redeemed when presented pursuant to the call. In addition, the redemption notice shall be mailed within the same period, postage prepaid, to Moody's Investors Service, Inc., and Standard & Poor's at their offices in New York, New York, or their successors, to Pacific Crest Securities, at its principal office in Seattle, Washington, or its successor, and to such other persons and with such additional information as the City Director of Finance and Administrative Services shall determine, but these additional mailings shall not be a condition precedent to the redemption of Bonds. Section 8. Failure to Redeem Bonds. If any Bond is not redeemed when properly presented at its maturity or call date, the City shall be obligated to pay interest on that Bond at the same rate provided in the Bond from and after its maturity or call date until that Bond, both principal and interest, is paid in full or until sufficient money for its payment in full is on deposit in the bond redemption fund bereinafter created and the Bond has been called for payment by giving notice of that call to the registered owner of each of those unpaid Bonds. 0211114.02 -dr- Section 9. Hedge of Taxes. For as long as any of the Bonds are outstanding, the City irrevocably pledges to include in its budget and levy taxes annually within the constitutional and statutory tax limitations provided by law without a vote of the electors of the City on all of the taxable property within the City in an amount sufficient, together with other money legally available and to be used therefor, including gross revenue of the Waterworks Utility of the City, after the payment of maintenance and operation expenses and any obligations the payment of which is pledged to be made from such gross revenue, to pay when due the principal of and interest on the Bonds, and the full faith, credit and resources of the City are pledged irrevocably for the annual levy and collection of those taxes and the prompt payment of that principal and interest. Section 10. Foan and Execution of Bonds. The Bonds shall be printed or lithographed on good bond paper in a form consistent with the provisions of this ordinance and state law and shall be signed by the Mayor and City Clerk, either or both of whose signatures may be manual or in facsimile, and the seal of the City or a facsimile reproduction thereof shall be impressed or printed thereon. Only Bonds bearing a Certificate of Authentication in the following form, manually signed by the Bond Registrar, shall be valid or obligatory for any purpose or entitled to the benefits of this ordinance: CERTIFICATE OF AUTHENTICATION This Bond is one of the fully registered City of Balnbridge Island, Washington, Limited Tax General Obligation Refunding Bonds, 1995, described in the Bond Ordinance. WASHINGTON STATE HSCAL AGENCY Bond Registrar By Authorized Signer The authorized signing of a Certificate of Authentication shall be conclusive evidence that the Bonds so authenticated have been duly executed, authenticated and delivered and are entitled to the benefits of this ordinance. If any officer whose facsimile signature appears on the Bonds ceases to be an officer of the City authorized to sign bonds before the Bonds bearing his or her facsimile signature are authenticated or delivered by the Bond Registrar or issued by the City, those Bonds nevertheless may be authenticated, issued and delivered and, when authenticated, issued and delivered, shall be as binding on the City as though that person had continued to be an officer of the City authorized to sign bonds. Any Bond also may be signed on behalf of the City by any person who, on the actual date of signing of the Bond, is an officer of the City authorized to sign bonds, although he or she did not hold the required office on the date of issuance of the Bonds. Section 11. Bond Fund and Deposit of Bond Proceeds. All of the proceeds of the Bonds, together with other money of the City referred to in Section 12 below, and exclusive of the accrued 0211114.1}2 '5- interest, shall be deposited with the Refunding Trustee in accordance with provisions of Section 12 herein. There is created and established in the office of the Director of Finance and Administrative Services a special fund designated as the Limited Tax General Obligation Refunding Bond Fund, 1995 (the 'Bond Fund'). Accrued interest on the Bonds, if any, received from the sale and delivery of the Bonds shall be paid into the Bond Fund. Until needed to pay the cost of issuance, the City may invest those remaining principal proceeds of the Bonds temporarily in any legal investment, and the investment earnings may be retained in the Bond Fund and spent for the purposes of that fund. All taxes collected for and allocated to the payment of the principal of and interest on the Bonds shall be deposited in the Bond Fund. Section 12. Authorization of Transfer of Funds. The Director of Finance and Administrative Services of the City is authorized and directed to transfer a sufficient amount of proceeds of the Reserve Account allocable to the Refunded Bonds to the Refunding Trustee appointed below for the purposes as described in Section 13 below. Section 13. Refunding of the Refunded Bonds. (a) Appointment of Refunding Trustee. First Interstate Bank of Washington, N.A. of Seattle, Washington, is appointed Refunding Trustee. Co) use of Bond Proceeds: Acquisition and Substitution of Acquired Obligations. All of the proceeds of the sale of the Bonds, wgether with a portion of the City's Reserve Account allocable to the Refunded Bonds, shall be deposited immediately upon the receipt thereof with the Refunding Trustee and used to discharge the obligations of the City relating to the Refunded Bonds under Ordinance No. 89-50 by providing for the payment of the amounts required to be paid by the Refunding Plan. To the extent practicable, such obligations shall be discharged fully by the Refunding Trustee's simultaneous purchase of the Acquired Obligations, bearing such interest and maturing as to principal and interest in such mounts and at such times so as to provide, together with a beginning cash balance, if necessary, for the payment of the amount required to be paid by the Refunding Plan. The Acquired Obligations are listed and more particularly described in Schedule A attached to the Refunding Trust Agreement between the City and the Refunding Trustee, but are subject to substitution as set forth below. Any Bond proceeds deposited with the Refunding Trustee that are not needed to purchase the Acquired Obligations and provide a beginning cash balance, if any, and pay the costs of issuance of the Bonds shall be returned to the City at the time of delivery of the Bonds for deposit in the Bond Fund. Prior to the purchase of any such Acquired Obligations, the City reserves the right to substitute other Government Obligations for any of the Acquired Obligations and to use any savings created thereby for any lawful City purpose if, (a) in the opinion of Foster Pepper & Shefelman, the City's bond counsel, the interest on the Bonds and the Refunded Bonds will remain excluded from gross income for federal income tax purposes under Sections 103, 148 and 149(d) of the Code, and Co) such substitution shall not impair the timely payment of the amounts required to be paid by the Refunding Plan, as verified by a nationally recognized firm of independent certified public accountants. After the purchase of the Acquired Obligations by the Refunding Trustee, the City reserves the right to substitute therefor cash or Government Obligations subject to the conditions that such 0211114.02 money or securities held by the Refunding Trustee shall be sufficient to carry out the Refunding Plan, that such substitution will not cause the Bonds and the Refunded Bonds to be arbitrage bonds within the meaning of Section 148 of the Code and regulations thereunder in effect on the date of such substitution and applicable to obligations issued on the issue date of the Bonds, and that it obtain, at its expense: (1) verification by a nationally recognized independent certified public accounting firm acceptable to the Refunding Trustee confirming that the payments of principal of and interest on the Government Obligations, if paid when due, and any other money held by the Refunding Trustee will be sufficient to carry out the Refunding Plan; and (2) an opinion from Foster Pepper & Shefelman, bond counsel to the City, its successor, or other nationally recognized bond counsel to the City, to the effect that the disposition and substitution or purchase of such securities, under the statutes, rules and regulations then in force and applicable to the Bonds, will not cause the interest on the Bonds or the Refunded Bonds to be included in gross income for federal income tax purposes and that such disposition and substitution or purchase is in compliance with the statutes and regulations applicable to the Bonds. Any surplus money resulting from the sale, transfer, other disposition or redemption of the Acquired Obligations and the substitutions therefor shall be released from the trust estate and transferred to the City to be used for any lawful City purpose. (c) Administration of Refunding Plan. The Refunding Trustee is authorized and directed to purchase the Acquired Obligations (or substitute obligations) and to make the payments required to be made by the Refunding Plan from the Acquired Obligations (or substitute obligations) and money deposited with the Refunding Trustee pursuant to this ordinance. All Acquired Obligations (or substitute obligations) and the money deposited with the Refunding Trustee and any income therefrom shall be held irrevocably, invested and applied in accordance with the provisions of Ordinance No. 89-50, this ordinance, chapter 39.53 RCW and other applicable statutes of the State of Washington and the Refunding Trust Agreement. All necessary and propor fees, compensation and expenses of the Refunding Trustee for the Bonds and all other costs incidental to the setting up of the escrow to accomplish the refunding of the Refunded Bonds and costs related to the issuance and delivery of the Bonds, including bond printing, verification fees, bond counsel's fees and other related expenses, shall be paid out of the proceeds of the Bonds. (d) Authorization for Refunding Trust Agreement. To carry out the Refunding Plan provided for by this ordinance, the Mayor or Director of Finance and Administrative Services of the City is authorized and directed to execute and deliver to the Refunding Trustee a Refunding Trust Agreement substantially in the form on file with the City Clerk and by this reference made a part hereof setting forth the duties, obligations and responsibilities of the Refunding Trustee in connection with the payment, redemption and retirement of the Refunded Bonds as provided herein and stating that the provisions for payment of the fees, compensation and expenses of such Refunding Trustee set forth therein are satisfactory to it. Prior to executing the Refunding Trust Agreement, the Mayor or City Clerk of the City is authorized to make such changes therein which do not change the substance and purpose thereof or which assure that the escrow provided therein and the Bonds are in compliance with the requirements of federal law governing the exclusion of interest on the Bonds from gross income for federal income tax purposes. Section 14. Call for Redemption of the Refunded Bonds. The City calls for redemption on November 1, 1999, all then-outstanding Refunded Bonds at a price of par plus accrued interest. Such call for redemption shall be irrevocable after the delivery of the Bonds to the initial purchaser 0211114.02 -7- thereof. The date on which the Refunded Bonds are called for redemption is the earliest date on which the those bonds may be called for redemption. The proper officials of the City are authorized and directed to give or cause to be given such notices as required, at the times and in the manner required pursuant to Ordinance No. 89-50 in order to effect the redemption prior to their maturity of the Refunded Bonds. Section 15. City Findings with Respect to Refunding. The City Council finds and deteunines that the issuance and sale of the Bonds at this time will effect a savings to the City and is in the best interest of the City and in the public interest. In making such finding and deteunination, the City Council has given consideration to the fixed maturities of the Bonds and the Refunded Bonds, the costs of issuance of the Bonds and the known earned income from the investment of the proceeds of the issuance and sale of the Bonds and other money of the City used in the Refunding Plan pending payment and redemption of the Refunded Bonds. The City Council further Finds and determines that the money to be deposited with the Refunding Trustee for the Refunded Bonds in accordance with Section 13 of this ordinance will discharge and satisfy the obligations of the City under Ordinance No. 89-50 with respect to the Refunded Bonds, and the pledges, charges, trusts, covenants and agreements of the City therein made or provided for as to the Refunded Bonds, and that the Refunded Bonds shall no longer be deemed to be outstanding under such ordinance immediately upon the deposit of such money with the Refunding Trustee. Section 16. Bond Registrar. The Bond Registrar shall keep, or cause to be kept, at its principal corporate trust office, sufficient books for the registration and transfer of the Bonds, which shall be open to inspection by the City at all times. The Bond Registrar is authorized, on behalf of the City, to authenticate and deliver Bonds transferred or exchanged in accordance with the provisions of the Bonds and this ordinance, to serve as the City's paying agent for the Bonds and to carry out all of the Bond Registrar's powers and duties under this ordinance and City Ordinance No. 83-10 establishing a system of registration for the City's bonds and obligations. The Bond Registrar shall be responsible for ks representations contained in the Bond Registrar's Certificate of Authentication on the Bonds. The Bond Registrar may become the owner of Bonds with the same rights it would have if it were not the Bond Registrar and, to the extent permitted by law, may act as depository for and permit any of its officers or directors to act as members of, or in any other capacity with respect to, any committee formed to protect the rights of Bond owners. Section 17. Preservation of Tax Exemption for Interest on Bonds. The City covenants that it will take all actions necessary to prevent interest on the Bonds from being included in gross income for federal income tax purposes, and it will neither take any action nor make or permit any use of proceeds of the Bonds or other funds of the City treated as proceeds of the Bonds at any time during the term of the Bonds which will cause interest on the Bonds to be included in gross income for federal income tax purposes. The City certifies that it has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that it is a bond issuer whose arbitrage certifications may not be relied upon. 0211114.02 -8- Section 18. Small Governmental Issuer Arbitrage Rebate Exception and Designation of Bonds as "Oualified Tax-Exempt Obligations." The City finds and declares that (a) it is a duly organized and existing governmental unit of the State of Washington and has general taxing power; (b) no Bond which is part of this issue of Bonds is a "private activity bond" within the meaning of Section 141 of the United States Internal Revenue Code of 1986, as amended (the "Code"); (c) at least 95 % of the net proceeds of the Bonds will be used for local governmental activities of the City (or of a governmental unit the jurisdiction of which is entirely within the jurisdiction of the City); (d) the aggregate face amount of all tax-exempt obligations (other than private activity bonds and other obligations not required to be included in such calculation) issued by the City and all entities subordinate to the City (including any entity which the City controls, which derives its authority to issue tax-exempt obligations from the City or which issues tax-exempt obligations on behalf of the City) during the calendar year in which the Bonds are issued is not reasonably expected to exceed $5,000,000; and (e) the amount of tax-exempt obligations, including the Bonds, designated by the City as "qualified tax-exempt obligations" for the purposes of Section 265(0)(3) of the Code during the calendar year in which the Bonds are issued does not exceed $10,000,000. The City therefore certifies that the Bonds are eligible for the arbitrage rebate exception under Section 148(0(4)(D) of the Code and designates the Bonds as "qualified tax-exempt obligations" for the purposes of Section 265(0)(3) of the Code. Section 19. Bonds Negotiable. The Bonds shall be negotiable instruments to the extent provided by RCW 62A.8-102 and 62A.8-105. Section 20. Refunding or Defeasance of the Bonds. The City may issue refunding bonds pursuant to the laws of the State of Washington or use money available from any other lawful source to pay when due the principal of and interest on the Bonds, or any portion thereof included in a refunding or defeasance plan, and to redeem and retire, refund or defease all such then-outstanding Bonds (hereinafter collectively called the "defeased Bonds") and to pay the costs of the refunding or defeasance. If money and/or direct obligations of the United States of America maturing at a time or times and bearing interest in amounts (together with money, if necessary) sufficient to redeem and retire, refund or defease the defeased Bonds in accordance with their terms are set aside in a special trust fund or escrow account irrevocably pledged to that redemption, retirement or defeasance of defeased Bonds (hereinafter called the "trust account"), then all right and interest of the owners of the defeased Bonds in the covenants of this ordinance and in the funds and accounts obligated to the payment of the defeased Bonds shall cease and become void. The owners of defeased Bonds shall have the right to receive payment of the principal of and interest on the defeased Bonds from the trust account. The City shall include in the refunding or defeasance plan such provisions as the City deems necessary for the random selection of any defeased Bonds that constitute less than all of a particular maturity of the Bonds, for notice of the defeasance to be given to the owners of the clefeased Bonds and to such other persons as the City shall determine, and for any required replacement of Bond certificates for defeased Bonds. The defeased Bonds shall be deemed no longer outstanding, and the City may apply any money in any other fund or account established for the payment or redemption of the defeased Bonds to any lawful purposes as it shall determine. Section 21. Approval of Bond Purchase Contract. Pacific Crest Securities of Seattle, Washington, has presented a purchase contract (the "Bond Purchase Contract") to the City offering to purchase the Bonds under the terms and conditions provided in the Bond Purchase Contract, which 0211114.02 -9- written Bond Purchase Contract is on file with the City Clerk and is incorporated herein by this reference. The City Council finds that entering into the Bond Purchase Contract is in the City's best interest and therefore accepts the offer contained therein and authorizes its execution by City officials. The Bonds will be printed at City expense and will be delivered to the purchaser in accordance with the Bond Purchase Contract, with the approving legal opinion of Foster Pepper & Shefelman, municipal bond counsel of Seattle, Washington, regarding the Bonds printed on each Bond. Bond counsel shall not be required to review and shall express no opinion concerning the completeness or accuracy of any official statement, offering circular or other sales material issued or used in connection with the Bonds, and bond counsel's opinion shall so state. The proper City officials are authorized and directed to do everything necessary for the prompt delivery of the Bonds to the purchaser and for the proper application and use of the proceeds of the sale thereof. Section 22. Preliminary Official Statement Deemed Final. The City Council has been provided with copies of a preliminary official statement dated November 24, 1995, as amended as of the date of passage of this ordinance, (the "Preliminary Official Statement"), prepared in connection with the sale of the Bonds. For the sole purpose of the Bond purchaser's compliance with Securities and Exchange Commission Rule 15c2-12(b)(1), the City "deems final" that Preliminary Official Statement as of its date, except for the omission of information as to offering prices, interest rates, selling compensation, aggregate principal amount, principal amount per maturity, maturity dates, options of redemption, delivery dates, ratings and other terms of the Bonds dependent on such matters. Section 23. Undertaking to Provide Continuing Disclosure. To meet the requirements of United States Securities and Exchange Commission CSEC') Rule 15c2-12(b)(5) (the "Rule"), as applicable to a participating underwriter for the Bonds, the City makes the following written undertaking (the "Undertaking ") for the benefit of holders of the Bonds: (a) Undertaking to Provide Annual Financial Information and Notice of Material Events. The City undertakes to provide or cause to be provided, either directly or through a designated agent: (i) To each nationally recognized municipal securities information repository designated by the SEC in accordance with the Rule CNRMSIR") and to a state information depository, if any, established in the state of Washington (the "SID") annual financial information and operating data of the type included in the final official statement for the Bonds and described in Section 23(b) ("annual financial information"); (ii) To each NRMSIR or the Municipal Securities Rulemaking Board CMSRB'), and to the SID, timely notice of the occurrence of any of the following events with respect to the Bonds, if material: (1) principal and interest payment delinquencies; (2) non-payment related defaults; (3) unscheduled draws on debt service reserves reflecting financial difficulties; o2nn4.o2 -10- (4) unscheduled draws on credit enhancements reflecting financial difficulties; (5) substitution of credit or liquidity providers, or their failure to perform; (6) adverse tax opinions or events affecting the m-exempt status of the Bonds; (7) modifications to rights of holders of the Bonds; (8) Bond calls (other than scheduled mandatory redemptions of Term Bonds); (9) defeasances; (10) release, substitution, or sale of property securing repayment of the Bonds; and (11) rating changes; and (iii) To each NRMSIR or to the MSRB, and to the SID, timely notice of a failure by the City to provide required annual financial information on or before the dam specified in Section 23Co). (b) Type of Annual Financial Information Undertaken to be Provided. The annual financial information that the City undertakes to provide in Section 23(a): (i) Shall consist of (1) authorized, issued and outstanding balance of limited tax general obligation bonds; (2) authorized issued and outstanding balance of waterworks utility bonds; (3) debt service coverage for waterworks utility debt; (4) assessed valuation for the fiscal year; (5) regular property tax levy rate and regular property tax levy rate limit for the fiscal year; and (6) Annual Financial Statements for the City; (ii) Shall be prepared in accordance with applicable generally accepted accounting principles promulgated by the Government Accounting Standards Board CGASB"), as such principles may be changed from time to time by GASB or its successor; (iii) Shall not be audited, except, however, that if and when audited financial statements are otherwise prepared and available to the City they will be provided from the Director of Finance and Administrative Services of the City; (iv) Shall be provided to each NRMSIR and the SID, not later than the last day of the ninth month after the end of each fiscal year of the City (currently, a fiscal year ending December 31, as such fiscal year may be changed as required or permitted by State law, commencing with the City's fiscal year ending December 31, 1996; and (v) May be provided in a single or multiple documents, and may be incorporated by reference to other documents that have been filed with each NRMSIR and the SID, or, if the document incorporated by reference is a "final official statement" with respect to other obligations of the City, that has been filed with the MSRB. (c) Amendment of Undertaking. The Undertaking is subject to amendment after the primary offering of the Bonds without the consent of any holder of any Bond, or of any broker, dealer, municipal securities dealer, participating - 11- underwriter, rating agency, NRMSIR, the SID or the MSRB, under the circumstances and in the manner permitted by the Rule. The City will give notice to each NRMSIR or the MSRB, and the SID, of the substance (or provide a copy) of any amendment to the Undertaking and a brief statement of the reasons for the amendment. If the amendment changes the type of annual financial inforiFtation to be provided, the notice also will include a narrative explanation of the effect of that change on the type of information to be provided. (d) Beneficiaries. The Undertaking evidenced by this Section 23 shall inure to the benefit of the City and any holder of Bonds, and shall not inure to the benefit of or create any rights in any other person. (e) Termination of Undertaking. The City's obligations under this Undertaking shall terminate upon the legal defeasance of all of the Bonds. In addition, the City's obligations under this Undertaking shall terminate if those provisions of the Rule which require the City to comply with this Undertaking become legally inapplicable in respect of the Bonds for any reason, as confirmed by an opinion of nationally recognized bond counsel or other counsel familiar with federal securities laws delivered to the City, and the City provides timely notice of such termination to each NRMSIR or the MSRB and the SID. (0 Remedy for Failure to Comply with Undertaking. As soon as practicable after the City learns of any failure to comply with the Undertaking, the City will proceed with due diligence to cause such noncompliance to be corrected. No failure by the City or other obligat~l person to comply with the Undertaking shall constitute a default in respect of the Bonds. The sole remedy of any holder of a Bond shall be to take such actions as that holder deems necessary, including seeking an order of specific performance from an appropriate court, to compel the City or other obligated person to comply with the Undertaking. (g) Designation of Official Responsible to Administer Undertaking. The Director of Finance and Administrative Services the City or his or her designee (or such other officer of the City who may in the future perform the duties of the Director of Finance and Administrative Services) is authorized and directed in his or her discretion to take such further actions as may be necessary, appropriate or convenient to carry out the Undertaking of the City in respect of the Bonds set forth in this Section 23 and in accordance with the Rule, including, without limitation, the following actions: (i) Preparing and filing the annual financial information undertaken to be provided; (ii) Determining whether any event specified in Section 23(a) has occurred, assessing its materiality with respect to the Bonds, and, if material, preparing and disseminating notice of its occurrence; o2nn4.o2 -12- (iii)'Determining whether any person other than the City is an "obligated person" within the meaning of the Rule with respect to the Bonds, and obtaining from such person an undertaking to provide any annual f'mancial information and notice of material events for that person in accordance with the Rule; (iv) Selecting, engaging and compensating designated agents and consultants, including but not limited to financial advisors and legal counsel, to assist and advise the City in canying out the Undertaking; and (v) Effecting any necessary amendment of the Undertaking. Section 24. Temporary Bond. Pending the printing, execution and delivery to the purchaser of definitive Bonds, the City may cause to be executed and delivered to the purchaser a single temporary Bond in the total principal amount of the Bonds. The temporary Bond shall bear the same date of issuance, interest rates, principal payment dates and terms and covenants as the definitive Bonds, shall be issued as a fully registered Bond in the name of the purchaser, and otherwise shall be in a forlit acceptable to the purchaser. The temporary Bond shall be exchanged for definitive Bonds as soon as they are printed, executed and available for delivery. Section 25. Effective Date of Ordinance. This ordinance shall take effect and be in force five days from and after its passage, approval and publication as required by law. PASSED by the City Council this 7th day of December, 1995. APPROVED by the Mayor this 8thday of December, 1995. ATTES T/AUTHENTICATED City Clerk ~ ~' Mayor APPROVED AS TO FORM: City Attorney FILED WITH CITY CLERK: PASSED BY THE CITY COUNCIL: PUBLISHED: EFFECTIVE DATE: ORDINANCE NO.: November 13, 1995 December 7, 1995 December 13, 1995 December 18, 1995 95-53 o2nn4.o2 -13- I, SUSAN P. KASPER, City Clerk of the City of Bainbridge Island, Washington, certify that the attached copy of Ordinance No. 95-53 is a true and correct copy of the original ordinance passed on the 7th day of December, 1995, as that ordinance appears on the Minute Book of the City. DATED this 8thday of December, 1995. REFUNDING TRUST AGREEMENT THIS AGREEMENT is made and entered into as of the 21st day of December, 1995, by and between the CITY OF BAINBRIDGE ISLAND, WASHINGTON (the "City"), a municipal corporation, and FIRST INTERSTATE BANK OF WASHINGTON, N. A. of Seattle, Washington (the "Refunding Trustee"). WHEREAS, the City now has outstanding $2,400,000 par value of its Water and Sewer Revenue Bonds, 1989, maturing on November i of each of the years 1998 through 2003, inclusive, and in 2009, and bearing interest at various rates ranging from 7.10% to 7.60% (the "Refunded Bonds"); and WHEREAS, pursuant to Ordinance No. 95-53 of the City (the "Bond Ordinance"), the City has determined that the Refunded Bonds be refunded out of the proceeds of the sale of its Limited Tax General Obligation Refunding Bonds, 1995 (the "Bonds"), for the purpose of realizing a debt service savings for the City, which refunding will be effected by: (a) The issuance of the Bonds and the payment of the costs of the issuance of the Bonds and the costs of the refunding; and (b) The payment of the principal of and interest on the Refunded Bonds when due up to and including November 1, 1999, and on November 1, 1999, the call, payment and redemption of all of the then- outstanding Refunded Bonds at a price of par; and WHEREAS, the payment, through advance refunding of the Refunded Bonds will be accomplished pursuant to this Refunding Trust Agreement (including Schedule A attached hereto) and the Bond Ordinance, which doc~,ments provide for and, for the purpose of Sections 103, 148 and 149(d) of the Internal Revenue Code of 1986, as amended (the "Code"), are to be considered as the Refunding Plan, by: (a) The delivery by the City. to the Refunding Trustee of the proceeds of the Bonds, together with a portion of the Reserve Account allocable to the Refunded Bonds; (b) The purchase by the Refunding Trustee of the noncallable direct obligations of the United States of America listed on Schedule A attached hereto and made a part hereof by this reference or substituted obligations purchased pursuant to Section 2 of this Agreement (the "Acquired Obligations") at or prior to the date the Bonds are delivered to the original purchaser thereof and the 021~,~09.01 City receives full payment therefor (the "Date of Closing"), which Acquired Obligations satisfy the requirements of the Verification described in paragraph (c); (c) The delivery to the City and the Refunding Trustee of a verification (the "Verification") by a nationally recognized independent certified public accounting firm verifying the mathematical accuracy of the computations (which computations shall be attached to that report) showing that the Acquired Obligations to be purchased by the Refunding Trustee pursuant to the Bond Ordinance and this Refunding Trust Agreement, together with the specified beginning cash balance, if any, and the maturing principal of and interest on such Acquired Obligations, will provide sufficient money (assuming that all principal of and interest on the Acquired Obligations are paid on the due dates thereof and assuming no reinvestment of such maturing principal and interest) to pay principal of and interest on the Refunded Bonds when due up to and including November 1, 1999, and on November 1, 1999, call, pay and redeem all of the outstanding Refunded Bonds at a price of par; and (d) The receipt by the Refunding Trustee of the maturing installments of principal of and interest on the Acquired Obligations; and (e) The Refunding Trustee's payment to the fiscal agencies of the State of Washington of money sufficient to make the payments on the Refunded Bonds set forth herein; and WHEREAS, upon the issuance of the Bonds to carry out the Refunding Plan under the authority of chapter 39.53 RCW and other laws of the State of Washington (collectively, the "Refunding Bond Act"), the principal amount of the Refunded Bonds no longer shall be considered outstanding pursuant to the defeasance provisions of the ordinance that authorized the issuance of the Refunded Bonds; and WHEREAS, the City Council of the City has found that the refunding of the Refunded Bonds, through the issuance of the Bonds, is beneficial and will realize a debt service savings to the City and its tax and rate payers; and WHEREAS, the City Council of the City, pursuant to the Bond Ordinance, has duly and validly authorized the execution and delivery of this Refunding Trust Agreement, the delivery of the proceeds of the Bonds to the Refunding Trustee, the purchase bythe Refunding Trustee of the Acquired Obligations and the carrying out of the Refunding Plan; 021i~09.01 -2- NOW, THEREFORE, in consideration of the mutual covenants hereinafter contained and for the benefit of the City, the parties hereto agree as follows: Section 1. Delivery of Money to Refunding Trustee. On the Date of Closing, the City shall cause to be delivered to the Refunding Trustee all of the proceeds of the Bonds and $269,440.00 of money of the City on deposit in the Reserve Account of the Water and Sewer Revenue Refunding Bond Fund, 1987. Section 2. Investment and Expenditure of Money. On the Date of Closing, the Refunding Trustee shall apply $2,508,220.65 to pay on behalf of the City the purchase and/or subscription prices of the Acquired Obligations, from the sources, in the principal amounts, with the dates of maturity and bearing the interest rates or yields set forth in Schedule A, and to establish a beginning cash balance. Upon receipt thereof, the Refunding Trustee shall deliver tothe City copies of the doc~,ments evidencing the purchase of and payment for the Acquired Obligations. Investments in mutual funds and unit investment trusts are prohibited. The City reserves the right at or prior to the Date of Closing to substitute other noncallable, nonprepayable direct obligations of the United States of America and/or obligations unconditionally guaranteed by the United States of America as to full and timely payment of principal and interest authorized to be acquired with the proceeds of Bonds under the Refunding Bond Act ("Government Obligations"), or cash, for any of the Acquired Obligations and to use any savings created thereby for any lawful City purpose if (a) in the opinion of Foster Pepper & Shefelman, bond counsel to the City, the interest on the Bonds will remain excluded from gross income for federal income tax purposes under Sections 103, 148 and 149(d) of the Code, and (b) a verification by a nationally recognized independent certified public accounting firm acceptable to the Refunding Trustee is obtained by the City verifying that such substitution shall not impair the timely payment of the amounts required to be paid under the Refunding Plan. On the Date of Closing, the Refunding Trustee shall pay the costs of issuance and sale of the Bonds from the Bond proceeds deposited with the Refunding Trustee and not needed to refund the Refunded Bonds, and shall transfer all remaining proceeds to the City for application in accordance with the Bond Ordinance. Section 3. Sufficiency of Acquired Obliaations. Based upon the Verification, the City represents that the Acquired Obligations and the maturing principal thereof' and the interest thereon, if paid when due, together with the beginning cash balance, shall be sufficient to make when due the payments required by the Refunding Plan. Such amounts coming due are sometimes referred to hereinafter as the "payments described in Section 3." The schedules oft he sources, amounts, maturities and interest rates or yields of the Acquired Obligations and of the Refunded Bonds which 0215509.01 -3- will fulfill the foregoing requirements are set forth in the Verification. Section 4. Collection of Proceeds of Acquired Obligations and Application of Such Proceeds and Money. The Refunding Trustee shall present for payment and shall collect and receive on the due dates thereof the maturing installments of the principal of and the interest on the Acquired Obligations and any Substitute Obligations (defined hereinafter). The Refunding Trustee shall make payments, but only in the amounts received pursuant to this section, in a timely manner to the Fiscal Agency of the State of Washington (the "Fiscal Agency") of the amounts to be paid on the Refunded Bonds as shown in the Verification. Those payments shall be made by check, wire transfer or such other method of transfer of funds as shall be agreed upon by the Refunding Trustee and the Fiscal Agency. The Refunding Trustee [shall notify the City not more than 80 nor less than 60 days prior to the call date of the Refunded Bonds to give the required notice of the call for redemption of the Refunded Bonds, and the City] shall cause timely notice of call for redemption of the Refunded Bonds to be given to the owners of those bonds. The cost of giving the notice shall be paid by the City. Section 5. All Obligations and Money and Proceeds Thereof Held in Trust. The Refunding Trustee irrevocably agrees to hold the Acquired Obligations, the Substitute Obligations, if any, the principal thereof and interest thereon and any other money which it may receive pursuant to this Refunding Trust Agreement and any reinvestments thereof made pursuant to Sections 7 and 8 hereof, in trust and separate at all times from all other funds and investments held by the Refunding Trustee, solely for the purpose of making the payments described in Section 3. The City irrevocably conveys, transfers and assigns to the Refunding Trustee the Acquired Obligations, any Substitute Obligations, the principal thereof and the interest thereon and any other money and investments deposited with the Refunding Trustee pursuant to this Refunding Trust Agreement, for the purpose of making such pa.yments. The Refunding Trustee shall not sell, transfer, assign or hypothecate any Acquired Obligations, reinvestments, or Substitute Obligations except pursuant to Sections 7, 8, 12 and 14 hereof. Section 6. Reports and Notice of Insufficiency. The Refunding Trustee shall submit a report to the City, at least semiannually, which report shall set forth the cash, Acquired Obligations and any Substitute Obligations held hereunder by the Refunding Trustee, the obligations which have matured and amounts received by the Refunding Trustee by reason of such maturity, the interest earned on such obligations, a list of any investments or reinvestments made by the Refunding Trustee in other obligations and the interest and/or principal derived therefrom, the amounts paid to the Fiscal Agency and any other transaction of the Refunding Trustee pertaining to its duties and obligations as set forth herein. 0215509.01 -4- If the maturing principal of and interest on the Acquired Obligations, any Substitute Obligations and other money held bythe Refunding Trustee pursuant to this Refunding Trust Agreement shall be insufficient or shall be projected to become insufficient at any time in the future to make the payments described in Section 3, the Refunding Trustee shall give the City prompt notice of such insufficiency or projected insufficiency. Section 7. Substitution of Different Government Obliaations or Other Investments. The City reserves the right to substitute from time to time for Acquired Obligations initially purchased in accordance with Section 2 hereof, or for obligations purchased under this section, other Government Obligations (the "Substitute Obligations"). Prior to effecting any such substitution, the City shall have obtained at its expense and delivered to the Refunding Trustee: (a) A verification by a nationally recognized independent certified public accounting firm acceptable to the Refunding Trustee confirming that the maturing principal of and interest on the Substitute Obligations and any remaining Acquired Obligations to be held by the Refunding Trustee in the refunding escrow, if paid when due and assuming no reinvestment thereof, together with any other cash then held by the Refunding Trustee, will be sufficient to carry out the Refunding Plan and make all remaining payments described in Section 3; and (b) An opinion from Foster Pepper & Shefelman, bond counsel to the City, its successor or other nationally recognized bond counsel to the City, that the disposition and substitution or purchase of such securities, under the statutes, rules and regulations then in force and applicable to the Bonds, will not cause the interest on the Bonds or the Refunded Bonds to be included in gross income for federal income tax purposes and that such disposition and substitution or purchase is in compliance with the statutes and regulations applicable to the Bonds. If the verification delivered to the Refunding Trustee pursuant to Section 7(a) shows that surplus money not needed to make the payments described in Section 3 will result from the sale, transfer or other disposition of Acquired Obligations and the substitution of Substitute Obligations therefor, that surplus money at the request of the City shall be released from the trust estate and shall be transferred to the City to be used for any lawful City purpose, subject to any restrictions stated in the opinion of bond counsel required by Section 7(b). Section 8. Reinvestment of Proceeds of Acquired and/or Substitute Obligations. The proceeds (principal and interest) and reinvestment proceeds of any Acquired Obligations and/or Substitute Obligations held by the Refunding Trustee in accordance with this 0215509.01 -5- Refunding Trust Agreement which are not needed within five business days of the receipt thereof to make the payments described in Section 3 may be reinvested by the Refunding Trustee on such date of receipt, subject to the following conditions: (a) Except as provided in subsection (c) below, the proceeds of such Acquired Obligations and/or Substitute Obligations shall be reinvested in Government Obligations at a yield which will not cause the composite yield on the refunding escrow to exceed 4.78305% during its term or such higher yield as may be directed by letter of instructions from the City to the Refunding Trustee, but if the composite yield on the directed investments made pursuant to this Refunding Trust Agreement would exceed 4.78305%, such letter of instructions shall contain a verification of such composite yield and shall be based upon and accompanied by the opinion of Foster Pepper & Shefelman, bond counsel to the City, its successor, or other nationally recognized bond counsel to the City, approving reinvestment of such proceeds at such higher yield. (b) The obligations in which such proceeds are reinvested shall mature in an amount at least equal to their purchase price on the date or dates directed bythe City, but not later than the date (as shown by the then most recent certified public accountant verification) the principal thereof is needed to make the payments described in Section 3; (c) If such proceeds, together with other funds remaining in trust, are insufficient to reinvest in the smallest denomination of such obligations or are required to be used to make payments described in Section 3 sooner than the shortest maturity available for such obligations, then those proceeds and funds either shall be converted to United States currency and retained or shall remain uninvested in the refunding escrow and carried on the books of the Refunding Trustee until required to make the payments described in Section 3, or until sufficient money is accumulated to permit the investment thereof; and (d) "Yield," as used in paragraph (a) of this section with respect to the Acquired Obligations and Substitute Obligations, means that yield computed in accordance with and permitted by the Code applicable to the Bonds and the trust under this Refunding Trust Agreement so as to preserve the exclusion from gross income for federal income tax purposes of the interest on the Bonds. 021~9.01 -6- The Refunding Trustee may make any and all investments permitted by the provisions of this Section 8 through its own investment department or the investment departments of any of its affiliates. Section 9. Amendments to Refunding Trust Agreement. The Refunding Trustee and the City recognize that the owners of the Refunded Bonds and the Bonds from time to time have a beneficial interest in the Acquired Obligations, the Substitute Obligations and money to be held by the Refunding Trustee as herein provided. Therefore, this Refunding Trust Agreement is irrevocable and shall not be subject to amendment except for the purpose of clarifying any ambiguity herein, increasing the protection of the rights of the owners of the Refunded Bonds or the Bonds, or preserving the exclusion of the interest on the Refunded Bonds and the Bonds from gross income for federal income tax purposes, and only if such amendment is accompanied by an opinion addressed to the City and the Refunding Trustee from Foster Pepper & Shefelman, its successor or other nationally recognized bond counsel to the City, to the effect that such change is necessary for one of the above reasons and does not detrimentally affect the owners of the outstanding Refunded Bonds and the Bonds or that it strengthens the protection of the owners of the Refunded Bonds and the Bonds and does not detrimentally affect the owners of the Refunded Bonds and the Bonds. If such amendment affects the amount of money and investments in the escrow account or the application thereof, prior to the amendment's taking effect there also shall be a verification by a nationally recognized independent certified public accounting firm satisfactory to the Refunding Trustee to the effect that after such amendment the Acquired Obligations, Substitute Obligations and other money in the escrow account will be sufficient to make the payments described in Section 3. Section 10. Limitation of LiabilitV of Refundin~ Trustee. None of the provisions contained in this Refunding Trust Agreement shall require the Refunding Trustee to use or advance its own funds in the performance of any of its duties or the exercise of any of its rights or powers hereunder. The Refunding Trustee shall be under no liability for the payment of interest on any funds or other property received by it hereunder except to the extent the Refunding Trustee is required by the express terms of this Refunding Trust Agreement to invest such funds. The Refunding Trustee's liabilities and obligations in connection with this Refunding Trust Agreement are confined to those specifically described herein. The Refunding Trustee is authorized and directed to comply with the provisions of this Refunding Trust Agreement and is relieved from all liability for so doing notwithstanding any demand or notice to the contrary by any party hereto. The Refunding Trustee shall not be responsible or liable for the sufficiency, correctness, genuineness or validity of the Acquired Obligations or the Substitute Obligations deposited with it; the performance or compliance by any party other than the Refunding Trustee with the terms or conditions of any such instruments; or any loss which may occur by reason of forgeries, 0~1~509.01 -7- false representations or the exercise of the Refunding Trustee's discretion in any particular manner unless such exercise is negligent or constitutes willful misconduct. If any controversy arises between the City and any third person, the Refunding Trustee shall not be required to determine the same or to take any action in the premises, but it may institute, in its discretion, an interpleader or other proceedings in connection therewith as it may deem proper, and in following either course, it shall not be liable. ~ection 11. City Deposit of Additional Money. The City agrees that it will deposit promptly with the Refunding Trustee the additional money specified in the Refunding Trustee's notice of insufficiency given pursuant to Section 6 hereof. Section 12. Remittance of Funds When Refunded Bonds Paid in Full. At such time as the Refunding Trustee has received the representation of the City that all of the payments described in Section 3 have been made and the confirmation of such representation by the Fiscal Agency, together with such other evidence of such payments as shall be satisfactory to the City and the Refunding Trustee, the Refunding Trustee shall deliver forthwith or remit to the City any remaining Acquired Obligations, Substitute Obligations and money held pursuant to this Refunding Trust Agreement. Section 13. Compensation of Refundin~ Trustee. The payment arrangement heretofore made between the Refunding Trustee and the City on compensation and expenses of the Refunding Trustee for services rendered by it pursuant to the provisions of this Refunding Trust Agreement is satisfactory to it and to the City, and no further payment to the Refunding Trustee shall be required for such purpose. Such arrangement for compensation and expenses is intended as compensation for the ordinary services as contemplated by this Refunding Trust Agreement, and if the Refunding Trustee renders any service hereunder not provided for in this Refunding Trust Agreement, or the Refunding Trustee is made a party to or intervenes in any litigation pertaining to this Refunding Trust Agreement or institutes interpleader proceedings relative hereto, the Refunding Trustee shall be compensated reasonably by the City for such extraordinary services and reimbursed for all fees, costs, liability and expenses (including reasonable attorneys' fees) occasioned thereby. The Refunding Trustee shall not have a lien against or otherwise be compensated for its services and expenses from the money, Acquired Obligations and Substitute Obligations held pursuant to this Refunding Trust Agreement to make the payments described in Section 3. Section 14. Successor Refundinu Trustee. The obligations ass~,med by the Refunding Trustee pursuant to this Refunding Trust Agreement may be transferred by the Refunding Trustee to a successor if (a) the Refunding Trustee has presented evidence satisfactory to the City and to Foster Pepper & Shefelman, its -~- successor or other nationally recognized bond counsel to the City that the successor trustee meets the requirements of RCW39.53.070, as now in effect or hereafter amended; (b) the City approves the appointment of the successor trustee; (c) the successor trustee has assumed all of the obligations of the Refunding Trustee under this Refunding Trust Agreement and has been compensated; and (d) all of the Acquired Obligations, reinvestments, Substitute Obligations and money then held by the Refunding Trustee pursuant to this Refunding Trust Agreement have been duly transferred to such successor trustee. Notwithstanding anything to the contrary contained in this Agreement, any company into which the Refunding Trustee may be merged or converted or with which it may be consolidated or any company resulting from any merger, conversion or consolidation to which the Refunding Trustee is a party, or any company to which the Refunding Trustee may sell or transfer all or substantially all of its corporate trust business shall be the successor to the Refunding Trustee without execution or filing of any paper or further act, if such company is eligible to serve as Refunding Trustee under RCW 39.53.070. Section 15. Miscellaneous. This Refunding Trust Agreement is governed by Washington law and may not be modified except by a writing signed by the parties and subject to the limitations of Section 9. If any one or more of the provisions contained in this Refunding Trust Agreement shall for any reason be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provisions of this Refunding Trust Agreement, but this Refunding Trust Agreement shall be construed as if such invalid or illegal or unenforceable provision had never been contained herein. Section 16. Notice to Ratin~ A~encies. The Refunding Trustee shall notify Moody's Investors Service, Inc., and any other national rating agency maintaining (at the request of the City) a rating on the Refunded Bonds or the Bonds, in writing upon timely receipt of notice or evidence of either of the following circumstances: (a) Prior to the taking effect of any amendments to this Refunding Trust Agreement under Section 9, enclosing the proposed amendatory documents; and (b) The holding (referred to in Section 15) that one or more provisions of this Refunding Trust Agreement is invalid, illegal or unenforceable in any respect, enclosing a copy of that holding. Such notices shall be sent to Moody's Investors Service, Inc. by first class mail to: 021~09.01 -9- Moody's Investors Service, Inc. Attn: Public Finance Rating Desk/Refunded Bonds 99 Church Street New York, New York 10007 Such notices shall be sent to the other applicable rating agencies by first class mail to the addresses advised by those rating agencies. IN WITNESS WHEREOF, the parties have executed and delivered this Refunding Trust Agreement pursuant to due and proper authorization, all as of the date and year first above written. CITY OF BAINBRIDGE ISLAND, WASHINGTON FIRST INTERSTATE BANK OF WASHINGTON, N. A., Refunding Trustee By Title:~~Mayor 0215509.01 SCHEDULE A ACQUIRED OBLIGATIONS MATURITY PAR INTEREST PURCHASE TYPE* DATE AMOUNT RATE PRICE TNote 10/31/96 $ 2,000 6,875% 101.5000% TNote 04/30/97 6,000 6.500 101.6562 TNote 04/30/98 3,000 5,125 99.6406 TNote 10/31/98 17,000 4,750 98.5312 TNote 04/15/99 2,477,000 7,000 104.8906 *TNote - U. S. Treasury Note NOTE: Upon the maturity of the TNote maturing on April 15, 1999, all available proceeds in the escrow to the nearest $100 shall he reinvested 4mmediately in United States Treasury Certificates of Indebtedness--State and Local Government Series ("SLGS") with a 0% yield and maturing on November 1, 1999. In the event SLGS securities are not available when needed, such proceeds shall be converted to United states currency as described in Section 8(c) of the Refunding Trust Agreement. ~Y21~).O1 FOSTER PEPPER & SHEFELMAN A LAW PARTNERSHIP INCLUDING pROFESSLONAL SERVICE CORPORATIONS DIRECT DIAL 206-447-8961 December 7, 1995 VIA HAND DELIVERY Mr. Ralph W. EelIs Director of Finance and Administrative Services City of Bainbridge Island 625 Winslow Way East Bainbridge Island, WA 98110 Re: Limited Tax General Obligation Refunding Bonds, 1995 Dear Ralph: Enclosed in final form is Ordinance No. 95-53 authorizing the issuance and sale of the above- referenced bonds, together with a form of Refunding Trust Agreemere and approving legal opinion. Enclosed for convenience are fifteen blacklined copies of Ordinance No. 95-53 for distribution to the Council and the original and five clean copies. The Refunding Trust Agreement should be retained in the records of the City Clerk as referenced in Section 13(d) of the ordinance. I invite comments on the Refunding Trust Agreement by you or any of the parties to this financing listed below. If the ordinance is passed, please return five certified copies, together with certified excerpts of the minutes of the Council meeting showing its passage and affidavit of publication of the ordinance, with the usual language a copy in its entirety may be obtained upon request. We would also appreciate receiving five certified copies of the Bond Purchase Contract prepared by Pacific Crest Securities. We will proceed with ordering the printing of the bonds and will be contacting you shortly concerning information necessary to complete the closing documents. Sincerely, FOSTER PEPPER & SHEFELMAN George M. Mack Enclosures 1111 THIRD AVENUE, SUITE 3400 SEATTLE, WASHINGTON 98101-3299 TEL. 206 447-4400 FACSIMILE 206 447-9700 ANCHORAGE, ALASKA BELLEVUE, WASHINGTON PORTLAND. OREGON SEATTLE, WASHINGTON Mr. Ralph W. EelIs December 6, 1995 Page 2 cc (w/encl.): Rod P. Kaseguma Susan P. Kasper Steve Galdos Michael Jones Perry Tobe Alice Garrett 0215539.WP ORDINANCE NO. 95-53 AN ORDINANCE of the City of Bainbridge Island, Washington, relating to contracting indebtedness; providing for the issuance of $2,505,000 $2.450.000 par value of Limited Tax General Obligation Refunding Bonds, 1995, of the City to provide part of the funds with which to pay the cost of advance refunding the callable portion of the City 's outstanding $2,400,000 Water and Sewer Revenue Bonds, 1989, and paying the administrative costs of such refunding and the costs of issuance and sale of such bonds; f'txing the date, form, maturities, interest rates, terms and covenants of the bonds; establishing a bond redemption fund; providing for and authorizing the purchase of certain obligations out of the proceeds of the sale of the bonds herein authorized and for the use and application of the money derived from those investments; authorizing the execution of an agreement with of, First Interstate Bank of Washington. N.A. of Seattle.Washington, as refunding trustee; providing for the call, payment and redemption of the outstanding bonds to be refunded; and approving the sale and providing for the delivery of the bonds to Pacific Crest Securities of Seattle, Washington. WHEREAS, pursuant to Ordinance No. 89-50, the City of Winslow, Washington (now the City of Bainbridge Island, Washington) heretofore issued its $2,400,00 $2.400.000 par value Water and Sewer Revenue Bonds, 1989 (the "1989 Bonds"), for the purpose of paying the cost of carrying out a system or plan of additions to and betterments and extensions of the waterworks utility of the City and capitalizing a reserve for those bonds, and by that ordinance reserved the right to redeem the 1989 Bonds prior to their maturity on November 1, 1999, at a price of par plus accrued interest to the date fixed for redemption; and WHEREAS, there are presently outstanding $2,260,000 $2,400,000 par value of 1989 Bonds maturing on November 1 of each of the years 2~Q~2~ 1998 through 2003, inclusive, and in 2009, and bearing various interest rates from 7.25,% 7.10% to 7.60% (the "Refunded Bonds"); and WHEREAS, after due consideration, it appears to the City Council that the Refunded Bonds may be refunded by the issuance and sale of the limited tax general obligation refunding bonds authorized herein (the "Bonds") so that a substantial savings will be effected by the difference between the principal and interest cost over the life of the Bonds and the principal and interest cost over the life of the Refunded Bonds but for such refunding, which refunding will be effected by: (a) The issuance of the Bonds and the payment of the costs of the issuance of the Bonds and the costs of the refunding; (b) The payment of ~e, I!rincival of and interest on the Refunded Bonds when due up to and including November 1, 2~nee~ 199=_=29, and the call, payment and redemption on November 1, 2~nee~ 199--9, of all of the then-outstanding Refunded Bonds at a price of par; 0211114.02 -1- and WHEREAS, to effect that refunding in the manner that will be most advantageous to the City it is found necessary and advisable that certain Acquired Obligations (hereinafter defined) bearing interest and maturing at such time or times as necessary to accomplish the refunding as aforesaid be purchased out of the proceeds of the Bonds and other money of the City; and WHEREAS, the City decms it to be in the best interests of the City to issue and sell the Bonds to pay part of the cost of advance refunding the Refunded Bonds and to pay the administrative costs of such refunding and the costs of issuance and sale of the Bonds; NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF BAINBRIDGE ISLAND, WASHINGTON, DO ORDAIN as follows: Section 1. Debt Capacity. The assessed valuation of the taxable property within the City as ascertained by the last preceding assessment for City purposes for the calendar year 1994 is $1,858,795,349, and the City has outstanding general indebtedness evidenced by limited tax general obligation bonds (excluding the amount of Refunded Bonds) in the principal amount ors $1.915.000 incurred within the limit of up to 1-1/2% of the value of the taxable property within the City permitted for general municipal purposes without a vote of the qualified voters therein, and the amount of indebtedness for which bonds are authorized herein to be issued is $2,505,000 $2.450.000. Section 2. Authorization of Bonds. The City shall borrow money on the credit of the City and issue negotiable limited tax general obligation refunding bonds evidencing that indebtedness in the amount of $2,505,000 $2.450.000 to provide the funds to pay the cost of accomplishing the following (the "Refunding Plan'): (a) the placement of sufficient proceeds of the Bonds which, with other money of the City, if necessary, will acquire those United States Treasury Certificates of Indebtedness, Notes and Bonds -- State and Local Government Series and other direct, noncallable obligations of the United States of America (the "Acquired Obligations") to be deposited, with cash, if necessary, with the Refunding Trustee; (b) the payment of the Drincioai of and interest on the Refunded Bonds when due up to and including November 1, 1999, and the call, payment and redemption on November 1, 1999, of all of the then-outstanding Refunded Bonds at a price of par; (c) the payment of the costs of issuing the Bonds and the costs of carrying out the foregoing elements of the Refunding Plan. The general indebtedness to be incurred shall be within the limit of up to 1-1/2% of the value of the taxable property within the City permitted for general municipal purposes without a vote of the qualified voters therein. 0211114.02 Section 3. Description of Bonds. The bonds shall be called Limited Tax General Obligation Refunding Bonds, 1995, of the City (the "Bonds"); shall be in the aggregate principal mount of $2,505,000 $2.450.000; shall be dated December 1, 1995; shall be in the denomination of $5,000 or any integral multiple thereof within a single maturity; shall be numbered separately in the manner and with any additional designation as the Bond Registrar (collectively, the fiscal agencies of the State of Washington located in Seattle, Washington, and New York, New York) deems necessary for purposes of identification; shall bear interest (computed on the basis of a 360-day year of twelve 30-day months) payable semiannually on each ;::re May 1 and Docombor November 1, commencing J--,,r;, May 1, 1996, to the maturity or earlier redemption of the Bonds; and shall mature on Docombor November 1 in years and amounts and bear interest at the rates per annum as follows: Maturity Interest Years Amounts Rates 199725,000 199825,000 199930,000 2000190,000 2001190,000 2002205,000 2003220,000 2004230,000 2005245,000 2006255,000 2007275,000 2008290,000 2009300,000 1996 3,80% 1997 20,000 4.00 1998 35.000 4.10 1999 145,000 4.15 2000 180.000 4.25 2001 180,000 4.35 2002 190,000 4.45 2003 205.000 4.55 2004 210,000 4.65 2005 225,000 4,75 2006 235,000 4,85 2007 250,000 4,95 2008 260,000 5.05 2009 275,000 5.15 Section 4. Registration and Transfer of Bonds. The Bonds shall be issued only in registered form as to both principal and interest and shall be recorded on books or records maintained by the Bond Registrar (the "Bond Register"). The Bond Register shall contain the name and mailing 0211114.02 -3- address of the owner of each Bond and the principal amount and number of each of the Bonds held by each owner. Bonds surrendered to the Bond Registrar may be exchanged for Bonds in any authorized denomination of an equal aggregate principal amount and of the same interest rate and maturity. Bonds may be transferred only if endorsed in the manner provided thereon and surrendered to the Bond Registrar. Any exchange or transfer shall be without cost to the owner or transferee. The Bond Registrar shall not be obligated to exchange or transfer any Bond during the 15 days preceding any principal payment or redemption date. Section 5. Payment of Bonds. Both principal of and interest on the Bonds shall be payable in lawful money of the United States of America. Interest on the Bonds shall be paid by checks or drafts of the Bond Registrar mailed on the interest payment date to the registered owners at the addresses appearing on the Bond Register on the 15th day of the month preceding the interest payment date. Principal of the Bonds shall be payable upon presentation and surrender of the Bonds by the registered owners at either of the principal offices of the BOnd Registrar at the option of the owners. Section 6. Optional Redemption [. Mandatory Redemption] and Open Market Purchase of BondS. Bonds maturing in the years 1996 through 2005, inclusive, shall be issued without the right or option of the City to redeem those Bonds prior to their stated maturity dates. The City reserves the right and option to redeem Bonds maturing on or after December November 1, 2006, prior to their stated maturity dates on or after D~ombcr November 1, 2005, as a whole at any time or in part at any time on any interest payment date within one or more maturities selected by the City (and by lot within a maturity in such manner as the Bond Registrar shall determine), at par plus accrued interest to the date fixed for redemption. [ADD FOR TERM BONDS] [Bonds maturing in are Term Bonds and, if not rcd~.xmcd under the optional redemption provisions sot forth above or purchased in the open market under the provisions set forth below, shall be called for redemption by lot (in such manner aa the Bond Registrar shall determine) at par plus accrued interest on Dcu~xmber 1 in years and amounts as follo~vs: Mandatory Mandatory Redemption Redemption Years Amounts [Insert redemption schedule] [If tho City shall redoom Term Bondn under the optional redemption provisions sot forth above or purchaso Torm Bonds in thc opon markot as sot forth below, thc par amount of tho Tcrm Bonds so redccrnod or purchased (irrcspc-ctivc of thcir actual redcmption or purchasc priccs) shall b~ creditod against onc or morc scheduled mandatory redcmption amount~ for thooc Tcrm Bonds (as allocatod o211114.02 ..4- by the City) beginning not earlier than 60 days after the dat~ of the optional redemption or purehag, and the City shall promptly notify the Bond Registrar in ~vriting of the manner in which the credit for the Team Bonds so redeemed or purchased has boon allocated.] Portions of the principal amount of any Bond, in installments of $5,000 or any integral multiple thereof, may be redeemed. If less than all of the principal amount of any Bond is redeemed, upon surrender of that Bond at either of the principal offices of the Bond Registrar, there shall be issued to the registered owner, without charge therefor, a new Bond (or Bonds, at the option of the registered owner) of the same maturity and interest rate in any of the denominations authorized by this ordinance in the aggregate principal amount remaining unredeemed. The City further reserves the right and option to purchase any or all of the Bonds in the open market at any time at any price acceptable to the City plus accrued interest to the date of purchase. All Bonds purchased or redeemed under this section shall be canceled. Section 7. Notice of Redemption. The City shall cause notice of any intended redemption of Bonds to be given not less than 30 nor more than 60 days prior to the date fixed for redemption by first-class mail, postage prepaid, to the registered owner of any Bond to be redeemed at the address appearing on the Bond Register at the time the Bond Registrar prepares the notice, and the requirements of this sentence shall be deemed to have been fulfilled when notice has been mailed as so provided, whether or not it is aaually received by the owner of any Bond. Interest on Bonds called for redemption shall cease to accrue on the date fixed for redemption unless the Bond or Bonds called are not redeemed when presented pursuant to the call. In addition, the redemption notice shall be mailed within the same period, postage prepaid, to Moody's Investors Service, Inc., and Standard & Poor's at their offices in New York, New York, or their successors, to Pacific Crest Securities, at its principal office in Seattle, Washington, or its successor, and to such other persons and with such additional information as the City gnan~ DirecWr of Finance and Administrative ~ervices shall determine, but these additional mailings shall not be a condition precedent to the redemption of Bonds. Section 8. Failure to Redeem Bonds. If any Bond is not redeemed when properly presented at its maturity or call date, the City shall be obligated to pay interest on that Bond at the same rate provided in the Bond from and after its maturity or call date until that Bond, both principal and interest, is paid in full or until sufficient money for its payment in full is on deposit in the bond redemption fund hereinafter created and the Bond has been called for payment by giving notice of that call to the registered owner of each of those unpaid Bonds. Section 9. Pledge of Taxes. For as long as any of the Bonds are outstanding, the City irrevocably pledges to include in its budget and levy taxes annually within the constitutional and statutory tax limitations provided by law without a vote of the electors of the City on all of the taxable property within the City in an amount sufficient, together with other money legally available and to be used therefor, including gross revenue of the Waterworks Utility of the City, after the payment of maintenance and operation expenses and any obligations the payment of which is pledged to be made from such gross revenue, to pay when due the principal of and interest on the Bonds, and the full faith, credit and resources of the City are pledged irrevocably for the annual levy and collection of those taxes and the prompt payment of that principal and interest. 0211114.0'2 '5- Section 10. Form and Execution of Bonds. The Bonds shall be printed or lithegraphed on good bond paper in a form consistent with the provisions of this ordinance and state law and shall be signed by the Mayor and City Clerk, either or both of whose signatures may be manual or in facsimile, and the seal of the City or a facsimile reproduction thereof shall be impressed or printed thereon. Only Bonds bearing a Certificate of Authentication in the following form, manually signed by the Bond Registrar, shall be valid or obligatory for any purpose or entitled to the benefits of this ordinance: CERTIFICATE OF AUTHENTICATION This Bond is one of the fully registered City of Balnbridge Island, Washington, Limited Tax General Obligation Refunding Bonds, 1995, described in the Bond Ordinance. WASHINGTON STATE FISCAL AGENCY Bond Registrar Authorized Signer The authorized signing of a Certificate of Authentication shall be conclusive evidence that the Bonds so authenticated have been duly executed, authenticated and delivered and are entitled to the benefits of this ordinance. If any officer whose facsimile signature appears on the Bonds ceases to be an officer of the City authorized to sign bonds before the Bonds bearing his or her facsimile signature are authenticated or delivered by the Bond Registrar or issued by the City, those Bonds nevertheless may be authemicated, issued and delivered and, when authenticated, issued and delivered, shall be as binding on the City as though that person had continued to be an officer of the City authorized to sign bonds. Any Bond also may be signed on behalf of the City by any person who, on the actual date of signing of the Bond, is an officer of the City authorized to sign bonds, although he or she did not hold the required office on the date of issuance of the Bonds. Section 11. Bond Fund and Deposit of Bond Proceeds. All of the proceeds of the Bonds, together with other money of the City referred to in Section 12 below, and exclusive of the accrued interest, shall be deposited with the Refunding Trustee in accordance with provisions of Section 12 herein. There is created and established in the office of the F-i~mee Director of Finance and Administrative Services a special fund designated as the Limited Tax General Obligation Refunding Bond Fund, 1995 (the "Bond Fund"). Accrued interest on the Bonds, if any, received from the sale and delivery of the Bonds shall be paid into the Bond Fund. Until needed to pay the cost of issuance, the City may invest those remaining principal proceeds of the Bonds temporarily in any legal investment, and the investment earnings may be retained in the Bond Fund and spent for the purposes of that fund. All taxes collected for and allocated to the payment of the principal of and interest on the Bonds shall be deposited in the Bond Fund. (Y211114.02 -6' Section 12. Authorization of Transfer of Funds. The ~ Director of Finance and Administrative Services of the City is authorized and directed to transfer a sufficient amount of proceeds of the Reserve Account allotable to the Refunded Bonds to the Refunding Trustee appointed below for the purposes as described in Section 13 below. Section 13. Refunding of the Refunded Bonds. (a) Appointment of Refunding Trustee. of, First Interstate Bank of Washin~on. N.A. of Seattle. Washington, is appointed Refunding Trustee. Co) use of Bond Proceeds: Acquisition and Substitution of Acquired Obligations. All of the proceeds of the sale of the BoMs, together with a portion of the City' s Reserve Account allocable to the Refunded Bonds, shall be deposited immediately upon the receipt thereof with the Refunding Trustee and used to discharge the obligations of the City relating to the Refunded Bonds under Ordinance No. 89-50 by providing for the payment of the amounts required to be paid by the Refunding Plan. To the extent practicable, such obligations shall be discharged fully by the Refunding Trustee's simultaneous purchase of the Acquired Obligations, bearing such interest and maturing as to principal and interest in such amounts and at such times so as to provide, together with a beginning cash balance, if necessary, for the payment of the amount required to be paid by the Refunding Plan. The Acquired Obligations are listed and more particularly described in Schedule A attached to the Refunding Trust Agreement between the City and the Refunding Trustee, but are subject to substitution as set forth below. Any Bond proceeds deposited with the Refunding Trustee that are not needed to purchase the Acquired Obligations and provide a beginning cash balance, if any, and pay the costs of issuance of the Bonds shall be returned to the City at the time of delivery of the Bonds for deposit in the Bond Fund. Prior to the purchase of any such Acquired Obligations, the City reserves the right to substitute other Government Obligations for any of the Acquired Obligations and to use any savings created thereby for any lawful City purpose if, (a) in the opinion of Foster Pepper & Shefelman, the City's bond counsel, the interest on the Bonds and the Refunded Bonds will remain excluded from gross income for federal income tax purposes under Sections 103, 148 and 149(d) of the Code, and (b) such substitution shall not impair the timely payment of the amounts required to be paid by the Refunding Plan, as verified by a nationally recognized fi~m of independent certified public accountants. After the purchase of the Acquired Obligations by the Refunding Trustee, the City reserves the right to substitute therefor cash or Government Obligations subject to the conditions that such money or securities held by the Refunding Trustee shall be sufficient to carry out the Refunding Plan, that such substitution will not cause the Bonds and the Refunded Bonds to be arbitrage bonds within the meaning of Section 148 of the Code and regulations thereunder in effect on the date of such substitution and applicable to obligations issued on the issue date of the Bonds, and that it obtain, at its expense: (1) verification by a nationally recognized independent certified public accounting firm acceptable to the Refunding Trustee confirming that the payments of principal of and interest on the Government Obligations, if paid when due, and any other money held by the Refunding Trustee will be sufficient to carry out the Refunding Plan; and (2) an opinion from Foster Pepper & Sbefelman, bend counsel to the City, its successor, or other nationally recognized bond counsel to the City, to the effect that the disposition and substitution or purchase of such securities, 0211114,02 -7- under the statutes, rules and regulations then in force and applicable to the Bonds, will not cause the interest on the Bonds or the Refunded Bonds to be included in gross income for federal income tax purposes and that such disposition and substitution or purchase is in compliance with the statutes and regulations applicable to the Bonds. Any surplus money resulting from the sale, transfer, other disposition or redemption of the Acquired Obligations and the substitutions therefor shall be released from the trust estate and transferred to the City to be used for any lawful City purpose. (c) Administration of Refunding Plan. The Refunding Trustee is authorized and directed to purchase the Acquired Obligations (or substitute obligations) and to make the payments required to be made by the Refunding Plan from the Acquired Obligations (or substitute obligations) and money deposited with the Refunding Trustee pursuant to this ordinance. All Acquired Obligations (or substitute obligations) and the money deposited with the Refunding Trustee and any income therefrom shall be held irrevocably, invested and applied in accordance with the provisions of Ordinance No. 89-50, this ordinance, chapter 39.53 RCW and other applicable statutes of the State of Washington and the Refunding Trust Agreement. All necessary and proper fees, compensation and expenses of the Refunding Trustee for the Bonds and all other costs incidental to the setting up of the escrow to accomplish the refunding of the Refunded Bonds and costs related to the issuance and delivery of the Bonds, including bond printing, verification fees, bond counsel's fees and other related expenses, shall be paid out of the proceeds of the Bonds. (d) Authorization for Refunding Trust Agreement. To carry out the Refunding Plan provided for by this ordinance, the Mayor or City Clerk Director of Finance and Administrative Services of the City is authorized and directed to execute and deliver to the Refunding Trustee a Refunding Trust Agreement substantially in the form on file with the City Clerk and by this reference made a part hereof setting forth the duties, obligations and responsibilities of the Refunding Trustee in connection with the payment, redemption and retirement of the Refunded Bonds as provided herein and stating that the provisions for payment of the fees, compensation and expenses of such Refunding Trustee set forth therein are satisfactory to it. Prior to executing the Refunding Trust Agreement, the Mayor or City Clerk of the City is authorized to make such changes therein which do not change the substance and purpose thereof or which assure that the escrow provided therein and the Bonds are in compliance with the requirements of federal law governing the exclusion of interest on the Bonds from gross income for federal income tax purposes. Section 14. Call for Redemption of the Refunded Bonds. The City calls for redemption on November 1, 1999, all then-outstanding Refunded Bonds at a price of par plus accrued interest. Such call for redemption shall be irrevocable after the delivery of the Bonds to the initial purchaser thereof. The date on which the Refunded Bonds are called for redemption is the earliest date on which the those bonds may be called for redemption. The proper officials of the City are authorized and directed to give or cause to be given such notices as required, at the times and in the manner required pursuant to Ordinance No. 89-50 in order to effect the redemption prior to their maturity of the Refunded Bonds. Section 15. City Findings with ReSpect to Refunding. The City Council finds and determines that the issuance and sale of the Bonds at this time will effect a savings to the City and is in the best interest of the City and in the public interest. In making such finding and determination, the City Council has given consideration to the fixed maturities of the Bonds and the 0211114.02 -8- Refunded Bonds, the costs of issuance of the Bonds and the known earned income from the investment of the proce.~s of the issuance and sale of the Bonds and other money of the City used in the Refunding Plan pending payment and redemption of the Refunded Bonds. The City Council further finds and determines that the money to be deposited with the Refunding Trustee for the Refunded Bonds in accordance with Section 13 of this ordinance will discharge and satisfy the obligations of the City under Ordinance No. 89-50 with respect to the Refunded Bonds, and the pledges, charges, trusts, covenants and agreements of the City therein made or provided for as to the Refunded Bonds, and that the Refunded Bonds shall no longer be deemed to be outstanding under such ordinance immediately upon the deposit of such money with the Refunding Trustee. Section 16. Bond Registrar. The Bond Registrar shall keep, or cause to be kept, at its principal corporate trust office, sufficient books for the registration and transfer of the Bonds, which shall be open to inspection by the City at all times. The Bond Registrar is authorized, on behalf of the City, to authenticate and deliver Bonds transferred or exchanged in accordance with the provisions of the Bonds and this ordinance, to serve as the City's paying agent for the Bonds and to carry out all of the Bond Registrar's powers and duties under this ordinance and City Ordinance No. 83-10 establishing a system of registration for the City's bonds and obligations. The Bond Registrar shall be responsible for its representations contained in the Bond Registrar's Certificate of Authentication on the Bonds. The Bond Registrar may become the owner of Bonds with the same rights it would have if it were not the Bond Registrar and, to the extent permitted by law, may act as depository for and permit any of its officers or directors to act as members of, or in any other capacity with respect to, any committee formed to protect the rights of Bond owners. Section 17. Preservation of Tax Exemption for Interest on Bonds. The City cov6nants that it will take all actions necessary to prevent interest on the Bonds from being included in gross income for federal income tax purposes, and it will neither take any action nor make or permit any use of proceeds of the Bonds or other funds of the City treated as proceeds of the Bonds at any time during the term of the Bonds which will cause interest on the Bonds to be included in gross income for federal income tax purposes. The City certifies that it has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that it is a bond issuer whose arbitrage certifications may not be relied upon. Section 18. Small Governmental Issuer Arbitrage Rebate Exception and Designation of Bonds as "Oualified Tax-Exempt Obligations." The City finds and declares that (a) it is a duly organized and existing governmental unit of the State of Washington and has general taxing power; (b) no Bond which is part of this issue of Bonds is a "private activity bond" within the meaning of Section 141 of the United States Internal Revenue Code of 1986, as amended (the "Code"); (c) at least 95 % of the net proceeds of the Bonds will be used for local governmental activities of the City (or of a governmental unit the jurisdiction of which is entirely within the jurisdiction of the City); (d) the aggregate face amount of all tax-exempt obligations (other than private activity bonds and other obligations not required to be included in such calculation) issued by the City and all entities subordinate to the City (including any entity which the City controls, which derives its authority to issue tax-exempt obligations from the City or which issues tax-exempt obligations on behalf of the 0211114.02 -9- City) during the calendar year in which the Bonds are issued is not reasonably expected to exceed $5,000,000; and (e) the amount of m-exempt obligations, including the Bonds, designated by the City as "qualified m-exempt obligations" for the purposes of Section 265(b)(3) of the Code during the calendar year in which the Bonds are issued does not exceed $10,000,000. The City therefore certifies that the Bonds are eligible for the arbitrage rebate exception under Section 148(0(4)(13) of the Code and designates the Bonds as "qualified tax-exempt obligations" for the purposes of Section 265(b)(3) of the Code. Section 19. Bonds Negotiable. The Bonds shall be negotiable instruments to the extent provided by RCW 62A. 8-102 and 62A.8-105. Section 20. Refunding or Defeasance of the Bonds. The City may issue refunding bonds pursuant to the laws of the State of Washington or use money available from any other lawful source to pay when due the principal of and interest on the Bonds, or any portion thereof included in a refunding or defeasance plan, and to redeem and retire, refund or clefease all such then-outstanding Bonds (hereinafter collectively called the "clefeased Bonds") and to pay the costs of the refunding or defeasance. If money and/or direct obligations of the United States of America maturing at a time or times and bearing interest in amounts (together with money, if necessary) sufficient to redeem and retire, refund or defease the defeased Bonds in accordance with their terms are set aside in a special trust fund or escrow account irrevocably pledged to that redemption, retirement or defeasance of clefeased Bonds (hereinafter called the "trust account"), then all right and interest of the owners of the clefeased Bonds in the covenants of this ordinance and in the funds and accounts obligated to the payment of the clefeased Bonds shall cease and become void. The owners of defeased Bonds shall have the right to receive payment of the principal of and interest on the defeased Bonds from the trust account. The City shall include in the refunding or defeasance plan such provisions as the City deems necessary for the random selection of any clefeased Bonds that constitute less than all of a particular maturity of the Bonds, for notice of the defeasance to be given to the owners of the defeased Bonds and to such other persons as the City shall determine, and for any required replacement of Bond certificates for clefeased Bonds. The defeased Bonds shall be deemed no longer outstanding, and the City may apply any money in any other fund or account established for the payment or redemption of the clefeased Bonds to any lawful purposes as it shall determine. Section 21. Approval of Bond Purchase Contract. Pacific Crest Securities of Seattle, Washington, has presented a purchase contract (the 'Bond Purchase Contract") to the City offering to purchase the Bonds under the terms and conditions provided in the Bond Purchase Contract, which written Bond Purchase Contract is on file with the City Clerk and is incorporated herein by this reference. The City Council finds that entering into the Bond Purchase Contract is in the City's best interest and therefore accepts the offer contained therein and authorizes its execution by City officials. The Bonds will be printed at City expense and will be delivered to the purchaser in accordance with the Bond Purchase Contract, with the approving legal opinion of Foster Pepper & Shefelman, municipal bond counsel of Seattle, Washington, regarding the Bonds printed on each Bond. Bond counsel shall not be required to review and shall express no opinion concerning the completeness or accuracy of any official statement, offering circular or other sales material issued or used in connection with the Bonds, and bond counsel's opinion shall so state. -10- The proper City officials are authorized and directed to do everything necessary for the prompt delivery of the Bonds to the purchaser and for the proper application and use of the proceeds of the sale thereof. Section 22. Preliminary Official Statement Deemed Final. The City Council has been provided with copies of a preliminary official statement dated November 24, 1995. as mended as of the date of Passage of this ordinance. (the "Preliminary Official Statement"), prepared in connection with the sale of the Bonds. For the sole purpose of the Bond purchaser's compliance with Securities and Exchange Commission Rule 15c2-12Co)(1), the City "deems final" that Preliminary Official Statement as of its date, except for the omission of information as to offering prices, interest rates, selling compensation, aggregate principal mount, principal mount per maturity, maturity dates, options of redemption, delivery dates, ratings and other teims of the Bonds dependent on such matters. Section 23. Undertaking to Provide Continuing Disclosure. To meet the requirements of United States Securities and Exchange Commission ("SEC") Rule 15c2-12(b)(5) (the "Rule"), as applicable to a participating underwriter for the Bonds, the City makes the following written undertaking (the "Undertaking") for the benefit of holders of the Bonds: (a) Undertaking to Provide Annual Financial Information and Notice of Material Events. The City undertakes to provide or cause to be provided, either directly or through a designated agent: (i) To each nationally recognized municipal securities information repository designated by the SEC in accordance with the Rule CNILMSIR") and to a state information depository, if any, established in the state of Washington (the "SID") annual financial information and operating data of the type included in the final official statement for the Bonds and described in Section 23(b) ("annual financial information"); (ii) To each NRMSIR or the Municipal Securities Rulemaking Board CMSRB"), and to the S1D, timely notice of the occurrence of any of the following events with respect to the Bonds, if material: (1) principal and interest payment delinquencies; (2) non-payment related defaults; (3) unscheduled draws on debt service reserves reflecting financial difficulties; (4) nnscheduled draws on credit enhancements reflecting financial difficulties; (5) substitution of credit or liquidity providers, or their failure to perform; (6) adverse tax opinions or events affecting the m-exempt status of the Bonds; (7) modifications to rights of holders of the Bonds; (8) Bond calls (other than scheduled mandatory redemptions of Term Bonds); (9) defeasances; (10) release, substitution, or sale of property securing repayment of the Bonds; and (11) rating changes; and (iii) To each NRMSIR or to the MSRB, and to the SID, timely notice of a failure by the City to provide required annual financial information on or before the date specified in Section 23(b). -11- (13) Typ~ of Annual Financial Information Undertaken to be Provided. The annual financial information that the City undertakes to provide in Section 23(a): (i) Shall consist of (1) authorized, issued and outstanding balance of limited tax general obligation bonds; (2) authorized issued and outstanding balance of waterworks utility .~,'a~m bonds; (3) debt service coverage for Wator~vork~ Utility waterworks utility debt; (4) assessed valuation for the fiscal year; (5) General Fund regular DrODert'v tax levy rate and re~,ular DroDertv tax levy rate limit for the fiscal year; and (6) Annual Financial Statements for the City; (ii) Shall be prepared in accordance with applicable generally accepted accounting principles promulgated by the Government Accounting Standards Board ("GASB'), as such principles may be changed from time to time by GASB or its successor; (iii) Shall not be audited, except, however, that if and when audited financial statements are otherwise prepared and available to the City they will be provided from the Director of Finance and Administrative Services of the City; (iv) Shall be provided to each NRMSIR and the SID, not later than the last day of the six',-~- ninth month after the end of each fiscal year of the City (currently, a fiscal year ending December 31, as such fiscal year may be changed as required or permitted by State law, commencing with the City's fiscal year ending December 31, 1996; and (v) May be provided in a single or multiple documents, and may be incorporated by reference to other documents that have been filed with each NRMS1R and the SID, or, if the document incorporated by reference is a "final official sta~ment" with respect to other obligations of the City, that has been filed with the MSRB. (c) Amendment of Undertaking. The Undertaking is subject to amendment after the primary offering of the Bonds without the consent of any holder of any Bond, or of any broker, dealer, municipal securities dealer, participating underwriter, rating agency, NRMSIR, the SID or the MSRB, under the circumstances and in the manner permitted by the Rule. The City will give notice to each NRMSIR or the MSRB, and the SID, of the substance (or provide a copy) of any amendment to the Undertaking and a brief staremerit of the reasons for the amendment. If the amendment changes the type of annual f'mancial information to be provided, the notice also will include a narrative explanation of the effect of that change on the type of information to be provided. -12- (d) Beneficiaries. The Undertaking evidenced by this Section 23 shall inure to the benefit of the City and any holder of Bonds, and shall not inure to the benefit of or cream any rights in any other person. (e) Termination of Undertaking. The City's obligations under this Undertaking shall terminate upon the legal defeasance of all of the Bonds. In addition, the City's obligations under this Undertaking shall terminate if those provisions of the Rule which require the City to comply with this Undertaking be.c, ome legally inapplicable in respect of the Bonds for any reason, as confumed by an opinion of nationally recognized bond counsel or other counsel familiar with federal securities laws delivered to the City, and the City provides timely notice of such te, t,dnation to each NRMSIR or the MSRB and the SID. (t) Remedy for Failure to Comply with Undertaking. As soon as practicable after the City learns of any failure to comply with the Undertaking, the City will proceed with due diligence to cause such noncompliance to be corrected. No failure by the City or other obligated person to comply with the Undertaking shall constitute a default in respect of the Bonds. The sole remedy of any holder of a Bond shall be to take such actions as that holder deems necessary, including seeking an order of specific performance from an appropriate court, to compel the City or other obligated person to comply with the Undertaking. (g) Designation of Official Responsible to Administer Undertaking. The Finance Director of Finance and Administrative Services the City or his or her designee (or such other officer of the City who may in the future perform the duties of the Director of Finance D'~c, etzr) and Administrative Services) is authorized and directed in his or her discretion to take such further actions as may be necessary, appropriate or convenient to carry out the Undertaking of the City in respect of the Bonds set forth in this Section 23 and in accordance with the Rule, including, without lirm'tation, the following actions: (i) Preparing and filing the annual financial information undertaken to be provided; (ii) Determining whether any event specified in Section 23(a) has occurred, assessing its materiality with respect to the Bonds, and, if material, preparing and disseminating notice of its occurrence; (iii) Determining whether any person other than the City is an "obligated person" within the meaning of the Rule with respect to the Bonds, and obtaining from such person an undertaking to provide any annual financial information and notice of material events for that person in accordance with the Rule; (iv) Selecting, engaging and compensating designated agents and consultants, including but not limited to financial advisors and legal counsel, to assist and advise the City in carrying out the Undertaking; and 0mm. o~ -13- (v) Effecting any necessary amendment of the Undertaking. Section 24. Temporary Bond. Pending the printing, execution and delivery to the purchaser of definitive Bonds, the City may cause to be executed and delivered to the purchaser a single temporary Bond in the total principal amount of the Bonds. The temporary Bond shall bear the same date of issuance, interest rates, principal payment dates and terms and covenants as the definitive Bonds, shall be issued as a fully registered Bond in the name of the purchaser, and otherwise shall be in a form acceptable to the purchaser. The temporary Bond shall be exchanged for definitive Bonds as soon as they are printed, executed and available for delivery. Section 25. Effective Date of Ordinance. This ordinance shall take effect and be in force five days from and after its passage, approval and publication as required by law. PASSED by the City Council this 7th day of December, 1995. APPROVED by the Mayor this __ day of December, 1995. ATTEST/AUTHENTICATED: Mayor City Clerk APPROVED AS TO FORM: City Attorney FILED WITH CITY CLERK: PASSED BY THE CITY COUNCIL: PUBLISHED: EFFECTIVE DATE: ORDINANCE NO.: 02nn4.0~ -14- I, SUSAN P. KASPER, City Clerk of the City of Bainbridge Island, Washington, certify that the attached copy of Ordinance No. 95-53 is a true and correct copy of the original ordinance passed on the 7th day of December, 1995, as that ordinance appears on the Minute Book of the City. DATED this day of December, 1995. SUSAN P. KASPER, City Clerk FOSTER PEPPER & SHEFELMAN A LAW PARTNERSHIP INCLUDING [FORM OF APPROVING ! .~,GAL OPINION] City of Bahabridge Island, Washington Re'. City of Bainbridge Island, Washington, $2,450,000 Limited Tax General Obligation Refunding Bonds, 1995 We have examined a certified transcript of proceedings had by the City of Bainbridge Island, Washington (the "City"), relating to its issuance of the above-referenced bonds (the "Bonds") and also have examined an executed and authenticated Bond or a facsimile thereof. The Bonds are issued pursuant to law for the purpose of providing the funds required to advance refund the City's outstanding Water and Sewer Revenue Bonds, 1989, and to pay the costs of issuance and sale of the Bonds, all as set forth in the Ordinance No. 95-53 {the 'Bond Ordinance") and under and in accordance with the Constitution and laws of the State of Washington and ordinances of the City. The Bonds are fully registered; are in the denomination of $5,000 or any integral multiple thereof within a single maturity; are numbered separately; are dated December 1, 1995; and bear interest at the rates set forth below, payable semiannually on each May 1 and November 1, commencing May I, 1996, to the maturity or earlier redemption of the Bonds. The Bonds are payable at the principal office of either of the fiscal agencies of the State of Washington in Seattle, Washington, or New York, New York (collectively, the 'Bond Registrar*). The Bonds mature on November I in years and mounts and bear interest at the rates per annum as follows: Maturity Interest years Amounts Rates 1996 $ 40,000 3.80% 1997 20,000 4.00 1998 35,000 4.10 1999 145,000 4.15 2000 180,000 4.25 SEATTLE, WASHINGTON 98101-3299 TEL. 206-447-4400 FacsiMile 206-447-9700 ANCHORAGE, ALASKA BELLEVUE, WASHINGTON PORTLAND, OREGON SEATTLE, WASHINGTON City of Bainbridge Island, Washington Page 2 Maturity Interest Years Amounts Rates 2001 $180,000 4.35% 2002 190,000 4.45 2003 205,000 4.55 2004 210,000 4.65 2005 225,000 4.75 2006 235,000 4.85 2007 250,000 4.95 2008 260,000 5.05 2009 275,000 5.15 Bonds maturing in the years 1996 through 2005, inclusive, are issued without the right or option of the City to redeem those Bonds prior to their statexi maturity dates. The City has reserved the right and option to redeem Bonds maturing on or after November 1, 2006, prior to their stated maturity dates on or after November 1, 2005, as a whole at any time or in pan on any interest payment date within one or more maturities selected by the City (and by lot within a maturity in such manner as the Bond Registrar shall determine), at par plus accrued interest to the date fixed for redemption and in the manner set forth in the Bonds. For as long as any of the Bonds are outstanding, the City irrevocably has pledged to include in its budget and to levy taxes annually within the constitutional and statutory tax limitations provided by law without a vote of the electors of the City on all of the taxable property within the City in an mount sufficient, together with other money legally available and to be used therefor, to pay when due the principal of and interest on the Bonds, and the full faith, credit and resources of the City have been pledged irrevocably for the annual levy and collection of those taxes and the prompt payment of that principal and interest. The City has also pledged the Gross Revenue of the Waterworks Uffiity subject to Maintenance and Operation Expenses and any Future Parity Bonds, all as defined in Ordinance No. 89-50 of the City. We have not reviewed and thus express no opinion concerning the completeness or accuracy of any official statement, offering circular or other sales material rel_n_tlng to the issuance of the Bonds or otherwise used in connection with the Bonds. Under the Internal Revenue Code of 1986, as amended (the "Code"), issuers of m-exempt obligations arc required to calculate and rebate to the United States certain investment earnings on gross proceeds of those obligations in the event that all gross proceeds have not been spent within 02119~4.01 City of Bainbridge Island, Washington Page 3 Under the Internal Revenue Code of 1986, as amended (the *Code*), issuers of tax-exempt obligations are required to calculate and rebate to the United States certain investment earnings on gross proceeds of those obligations in the event that all gross proceeds have not been spent within certain periods prescribed by the Code. There is an exception to this rebate requirement available to a governmental unit with general taxing powers in connection with the issuance of obligations other than "private activity bonds" as def'med in the Code, if the governmental unit, together with all subordinate governmental units, does not reasonably anticipate issuing more than $5,000,000 of tax-exempt obligations (other than private activity bonds and other obligations not required to be included in such calculation) during the calendar year in which the obligations are issued. The City has certified in the Bond Ordinance that it is an issuer which qualifies for this arbitrage rebate exception in connection with the issuance of the Bonds. As of the date of initial delivery of the Bonds to the purchaser thereof and full payment therefor, it is our opininnthat (1) the City is a duly organized and legally existing non-chartered code city under the laws of the State of Washington; (2) the Bonds are issued in full compliance with the provisions of the Constitution and laws of the State of Washington and the ordinances of the City relating thereto; (3) the Bonds constitute valid general obligations of the City payable from annual ad valorem taxes to be levied within the constitutional and statutory tax linfit_a_tions provided by law without a vote of the electors of the City on all of the taxable property within the City, together with Gross Revenue of the Waterworks Utility, except only to the extent that enforcement of payment may be limited by bankruptcy, insolvency or other laws affecting creditors' rights and principles of equity if equitable remedies are sought; and (4) assuming compliance by the City after the date of issuance of the Bonds with applicable requirements of the Code, including arbitrage requirements, under existing federal law the interest on the Bonds is excluded from gross income of the registered owners for federal income tax purposes and is not an item of tax preference for purposes of the alternative minimum tax applicable to individuals; however, while interest on the Bonds also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations, interest on the Bonds received by corporations is to be taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations, interest on the Bonds received by certain corporations may be subject to an environmental tax, interest on the Bonds received by certain S corporations may be subject to tax, and interest on the Bonds received by foreign corporations with United States branches may be subject to a foreign branch profits tax. We express no opinion regarding any other federal tax consequences of receipt of interest on the Bonds. Respectfully submitted, 0211934.01 01-Dec-95 12:55 pm Prepared by Pac,,ic Crest Securities TABLE OF CONTENTS City of Bainbridge Island LTGO Refunding Bonds, 1995 (Fi,,,nce 2.300 BAINBRDG:SCENA,REVENUE'A) Page Report 1 Sources and Uses of Funds ................................. 2 Sun~nary of Refunding Results ................................ 3 Sugary of Bonds Refunded ................................. 4 Savings .......................................... 5 Prior Bond Debt Service .................................. 6 Escrow Requirements .................................... 7 Form 8038 Statistics Report ................................ 9 Bond Summary Statistics .................................. 10 Bond Pricing ........................................ 11 Detailed Bond Debt Service ................................. 12 Proof of Arbitrage Yield .................................. 13 Escrow Descriptions Detail ................................. 14 Escrow Cost Detail ..................................... 15 Escrow Cash Flow ...................................... 17 Escrow Sufficiency ..................................... 18 Escrow Statistics ..................................... 19 Proof of Composite Escrow Yield .............................. 20 Average Takedown ...................................... 21 Cost of Issuance ...................................... 01-Dec-95 12:55 pm prepared by Pacl,ic Crest Securities (Finance 2.3Uu BAINBRDG:SCENA,REVENUE-A) SOURCES AND USES OF FUNDS City of Bainbridge Island LTGO Refunding Sonds, 1995 Page 1 Sources of Funds Bond Proceeds: 1996 to 2009 Other Sources of Funds: Reserve Fund Par Plus: Less: Amount Accrued Discount 2,450,000.00 6,364.02 269,440.00 2,719,440.00 6,364.02 Total 2,456,364.02 269,440.00 2,725,804.02 Uses of Funds Refunding Escrow Deposits: Cash Deposit Open Market Purchases Other Fund Deposits: General Fund Delivery Date Expenses: Cost of Issuance Underwriter's Discount Other Uses of Funds: Additional Proceeds Par Plus: Less: Amount Accrued Discount Total 3,220.65 3,220.65 2,505,000.00 31,949.38 -121,009.69 2,657,959.07 2,508,220.65 31,949.38 -121,009.69 2,661,179.72 6,364.02 20,320.00 36,750.00 57,070.00 6,364.02 1,190.28 2,572,844.95 20,320.00 36,750.00 57,070.00 1,190.28 31,949.38 '121,009.69 2,725,804.02 Note: General Fund includes deposit of 6,364.02 of bond accrued interest. 01 -Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.30U BAINBRDG:SCENA,REVENUE-A) SUMMARY OF REFUNDING RESULTS City of Bainbridge Island LTGO Refunding Bonds, 1995 Page 2 Dated Date Delivery Date Arbitrage yield Escrow yield Bond Par Amount True Interest Cost Net Interest Cost Average Coupon Average Life Par amount of refunded bonds Average coupon of refunded bonds Average life of refunded bonds PV of prior debt to 12/21/1995 8 4.783056% Net PV Savings Percentage savings of refunded bonds Percentage savings of refunding bonds 12/01/1995 12/21/1995 4.783056% 4.690329% 2,450,000.00 4.994534% 4.964567% 4.800986% 9.114 2,400,000.00 7.539383% 9.624 2,919,419.27 201,169.55 8.382065% 8.211002% 01 -Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) SUMMARY OF BONDS REFUNDED City of Bainbridge Island LTGO Refunding Bonds, 1995 1989 - 1989 Bonds Bond Maturity Interest Date Rate Par An~unt Call Date Call Price $2,400,000 WS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS SERIALS Revenue Bonds, 1989: 11/01/1998 7.100% 11/01/1999 7.200% 11/01/2000 7.250% 11/01/2001 7.300% 11/01/2002 7.350% 11/01/2003 7.400% 11/01/2004 7.600% 11/01/2005 7.500% 11/01/2006 7.600% 11/01/2007 7.600% 11/01/2008 7.600% 11/01/2009 7.600% 15,000.00 125000.00 160 O00.O0 165 000.00 180 000.00 200 000.00 210 000.00 230 000.00 245 000.00 270000.00 290 OOO.O0 310,000.00 11/01/1999 11/01/1999 11/01/1999 11/01/1999 11/01/1999 11/01/1999 11/01/1999 11/01/1999 11/01/1999 11/01/1999 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 Page 3 2,400,000.00 01-Dec-95 12:55 pin Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) PRIOR BOND DEBT SERVICE City of Bainbridge Island LTGD Refunding Bonds, 1995 S2,400,000 ~/S Revenue Bonds (1989) Period Annual Ending Principal Coupon Interest Debt Service Debt Service Dec 21, 1995 May 1, 1996 Nov 1, 1996 May 1, 1997 Nov 1, 1997 May lr 1998 NOV 1, 1998 May 1, 1999 Nov 1, 1999 May 1, 2000 Nov 1, 2000 May 1, 2001 Nov 1, 2001 May 1, 2002 Nov 1w 2002 May 1, 2003 Nov 1, 2003 May 1, 2004 Nov 1, 2004 May 1, 2005 Nov lr 2005 May 1, 2006 Nov 1m 2006 May 1, 2007 Nov 1, 2007 May 1, 2008 Nov 1, 2008 May 1, 2009 Nov 1, 2009 15,000.00 125,000.00 160,000.00 165,000.00 180,000.00 200,000.00 210,000.00 230,000.00 245w000.00 270,000.00 290,000.00 310,000.00 7.100% 7.200% 7.250% 7.300% 7.350% 7.400% 7.600% 7.600% 7.600% 7.600% 7.600% 7.600% 89,960.00 89,960.00 89,960.00 89,960.00 179,920.00 89,960.00 89,960.00 89,960.00 89,960.00 179,920.00 89,960.00 89,960.00 89,960.00 104,960.00 194,920.00 89~427.50 89,427.50 89,427.50 214,427.50 303,855.00 84,927.50 84,927.50 84,927.50 244,927.50 329,855.00 79,127.50 79,127.50 79,127.50 244,127.50 323,255.00 73,105.00 73,105.00 73r105.00 253,105.00 326,210.00 66r490.00 66,490.00 66,490.00 266,490.00 332,980.00 59,090.00 59,090.00 59,090.00 269,090.00 328,180.00 51,110.00 51,110.00 51,110.00 281,110.00 332,220.00 42,370.00 42,370.00 42f370.00 287,370.00 329,740.00 33,060.00 33,060.00 33,060.00 303,060.00 336,120.00 22,800.00 22,800.00 22,800.00 312,800.00 335,600.00 11,780.00 11,780.00 11,780.00 321,780.00 333,560.00 1,766,335.00 4,166,335.00 4,166,335.00 2,400,000.00 Page 5 01-Dec-95 12:55 pm Prepared by PaC~TiC Crest Securities (Finance 2.3bu BAINBRDG:SCENA,REVENUE-A) Page 6 ESCROW REQUIREMENTS City of Sainbridge Island LTGO Refunding Bonds, 1995 $2,400,000 W/S Revenue Bonds (1989) Period Ending Principal Principal Interest Redeemed Totat May 1, 1996 Nov 1, 1996 May 1, 1997 Nov 1, 1997 May 1, 1998 Nov 1, 1998 May 1, 1999 NOV 1, 1999 15,000.00 125,000.00 89,960.00 89,960.00 89,960.00 89,960.00 89,960.00 89,960.00 89,427.50 89,960.00 89,960.00 89,960.00 89,960.00 89,960.00 104,960.00 89,427.50 89,427.50 2,260,000.00 2,474,427.50 140,000.00 718,615.00 2,260,000.00 3,118,615.00 01 ~Dec-95 12:55 ~n prepared by PaClTiC Crest Securities (Finance 2.30u SAINBRDG:SCENA,REVENUE-A) FORM 8038 STATISTICS REPORT City of Bainbridge Island LTGO Refunding Bonds, 1995 Page 7 Dated Date 12/01/1995 Delivery Date 12/21/1995 Bond Component 1996 to 2009: Date Principal Coupon Price 11/01/1996 40,000.00 3.800% 11/01/1997 20,000.00 4,000% 11/01/1998 35,000.00 4.100% 11/01/1999 145,000.00 4.150% 11/01/2000 180,000.00 4.250% 11/01/2001 180,000.00 4.350% 11/01/2002 190,000.00 4.450% 11/01/2003 205,000.00 4.550% 11/01/2004 210,000.00 4.650% 11/01/2005 225,000.00 4.750% 11/01/2006 235,000.00 4.850% 11/01/2007 250,000.00 4.950% 11/01/2008 260,000.00 5.050% 11/01/2009 275,000.00 5.150% 2,450,000.00 Redemption Issue Price at Maturity 100.000 40,000.00 40,000.00 100.000 20,000.00 20,000.00 100.000 35,000.00 35,000.00 100.000 145,000.00 145,000.00 100.000 180,000.00 180,000.00 100.000 180,000.00 180,000.00 100.000 190r000.00 190,000.00 100.000 205,000.00 205,000.00 100.000 210,000.00 210,000.00 100.000 225,000.00 225,000.00 100.000 235,000.00 235,000.00 100.000 250,000.00 250,000.00 100.000 260,000.00 260,000.00 100.000 275,000.00 275,000.00 2,450r000.00 2,450,000.00 Final Maturity Entire Issue Maturity Date 11/01/2009 Interest Rate 5.150% Issue Price 275,000.00 2,450,000.00 Stated Weighted Net Redemption Average Interest at Maturity Maturity Yield Cost 275,000.00 2,450,000.00 9.114 4.783% 4.802% 01-Dec-95 12:55 pm Prepared by Pacltic Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) Page 8 FORM 8038 STATISTICS REPORT City of Bainbridge Island LTGO Refunding Bonds, 1995 Refunded Bonds Bond Component Date Principal Coupon Price Issue Price $2,400,000 W/B Revenue Bonds: SERIALS 11/01/1998 SERIALS 11/01/1999 SERIALS 11/01/2000 SERIALS 11/01/2001 SERIALS 11/01/2002 SERIALS 11/01/2003 SERIALS 11/01/2004 SERIALS 11/01/2005 SERIALS 11/01/2006 SERIALS 11/01/2007 SERIALS 11/01/2008 SERIALS 11/01/2009 15,000.00 125 000.00 160 000.00 165 000.00 180 000.00 200 000.00 210 000.00 230 000.00 245 000.00 270,000.00 290,000.00 310,000.00 7.100% 7.200% 7.250% 7.300% 7.350% 7.400% 7.600% 7.600% 7,600% 7.600% 7.600% 7,600% 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 100.000 15,000~00 125,000.00 160,000.00 165,000.00 180,000.00 200,000,00 210,000.00 230,000.00 245,000.00 270,000.00 290,000.00 310,000.00 2,400,000.00 2,400,000,00 $2,400,000 W/S Revenue Bonds AlL Refunded Issues Last Call Date 11/01/1999 11/01/1999 Issue Date 11/01/1995 Remaining Weighted Average Maturity 9.624 9.624 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) BOND SUMMARY STATISTICS City of Bainbridge Island LTGO Refunding Bonds, 1995 Page 9 Dated Date Delivery Date First Coupon Last Maturity Arbitrage Yield True Interest Cost (TIC) Net Interest Cost (NIC) All-In TIC Average Coupon Average Life (years) Duration of Issue (years) Par Amount Bond Proceeds Total Interest Net Interest Total Debt Service Maximum Annual Debt Service Average Annual Debt Service Underwriter's Fees (per $1000) Average Takedown Other Fee Total Underwriter's Discount Bid Price 12/01/1995 12/21/1995 5/01/1996 11/01/2009 4.783056% 4.994534% 4.964567% 5.113328% 4.800986% 9.114 7.287 2,450,000.00 2,456,364.02 1,078,581.45 1,115,331.45 3,528,581.45 289,667.50 . 254,107.87 15.000000 15.000000 98.500000 Bond Component 1996 to 2009 Par Value 2,450,000.00 2,450,000.00 Price 100.000 Average Coupon 4.B01% Average Life 9.114 9.114 Par Value + Accrued Interest + Premium (Discount) - Underwriter's Discount - Cost of Issuance Expense - Other Amounts Target Value Target Date Yield TIC 2,450,000.00 6,364.02 -36,750.00 2,419,614.02 12/21/1995 4.994534% All-in TIC 2,450,000.00 6,564.02 '56,750.00 'Z0,320.00 2,399,294.02 12/21/1995 5.113328% Arbitrage Yield 2,450,000.00 6,364.02 2,456,364.02 12/21/1995 4.783086% 01-Dec-95 12:55 pm Page 10 Prepared by Pacific Crest Securities (Finance 2.30b BAINBRDG:SCENA,REVENUE-A) BOND PRICING City of Bainbridge Island LTGO Refunding Bonds, 1995 Bond Component 1996 to 2009: Maturity Date Amount Rate Yield Price 11/01/1996 11/01/1997 11/01/1998 11/01/1999 11/01/2000 11/01/2001 11/01/2002 11/01/2003 11/01/2004 11/01/2005 11/01/2006 11/01/2007 11/01/2008 11/01/2009 40,000 20,000 35,000 145,000 180,000 180,000 190 000 205 000 210 000 225 000 235 000 250 000 260 000 275 000 2,450,000 3.800% 3.800% 100.000 4.000% 4.000% 100.000 4.100% 4.100% 100.000 4.150% 4.150% 100.000 4.250% 4.250% 100.000 4.350% 4.350% 100.000 4.450% 4.450% 100.000 4.550% 4.550% 100.000 4.650% 4.650% 100.000 4.750% 4.750% 100.000 4.850% 4.850% 100.000 4.950% 4.950% 100.000 5.050% 5.050% 100.000 5.150% 5.150% 100.000 Dated Date De(ivery Date First Coupon Par Amount Discount Production Underwriter's Discount Purchase Price Accrued Interest 12/01/1995 12/21/1995 5/01/1996 2,450,000.00 2,450,000.00 -36,750.00 2,413,250.00 6,364.02 100.000000% -1.500000% 98.500000% Net Proceeds 2,419,614.02 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) DETAILED BOND DEBT SERVICE City of Bainbridge [stand LTGO Refunding Bonds, 1995 Period Ending Principal Dec 21, 1995 May 1, 1996 Nov 1, 1996 40,000.00 May 1, 1997 NOv 1, 1997 20,000.00 May 1, 1998 Nov 1, 1998 35,000.00 May 1, 1999 NOV 1, 1999 145,000.00 May 1, 2000 NOV 1, 2000 180,000.00 May 1, 2001 NOV 1, 2001 180,000.00 May 1, 2002 Nov 1, 2002 190,000.00 May 1, 2003 Nov 1, 2003 205,000.00 May 1, 2004 Nov 1, 2004 210,000.00 May 1, 2005 Nov 1, 2005 225,000.00 May 1, 2006 Nov 1, 2006 235,000.00 May 1, 2007 Nov 1, 2007 250,000.00 May 1, 2008 Nov 1, 2008 260,000.00 May 1, 2009 Nov 1, 2009 275,000.00 2,450,000.00 1996 to 2009 (SERIALS} Coupon Interest Debt Service 47,730.20 3.800% 57,276.25 56,516.25 4.000% 56,516.25 56,116.25 4.100% 56,116.25 55,398.75 4.150% 55,398.75 52,390.00 4.250% 52,390.00 48,565.00 4.350% 48,565.00 44,650.00 4.450% 44,650.00 40,422.50 4.550% 40,422.50 35,758.75 4.650% 35,758.75 30,876.25 4.750% 30,876.25 25,532.50 4.850% 25,532.50 19,833.75 4.950% 19,833.75 13,646.25 5.050% 13,646.25 7,081.25 5.150% 7,081.25 1,078,581.45 Annual Debt Service 47,730.20 97,276.25 145,006.45 56,516.25 76,516.25 133,032.50 56,116.25 91,116.25 147,232.50 55,398.75 200,398.75 255,797.50 52,390.00 232,390.00 284,780.00 48,565.00 228,565.00 277,130.00 44,650.00 234,650.00 279,300.00 40,422.50 245,422.50 285,845.00 35,758.75 245,758.75 281,517.50 30,876.25 255,876.25 286,752.50 25,532.50 260,532.50 286,065.00 19,833.75 269,833.75 289,667.50 13,646.25 273,646.25 287,292.50 7,081.25 282,081.25 289,162.50 3,528,581.45 3,528,581.45 Page 11 01-Dec-95 Page 12 12:55 pin Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) PROOF OF ARBITRAGE YIELD City of Bainbridge island LTGO Refunding Bonds, 1995 Date Debt Service Present Value to 12/21/1995 a 4.783055P~ May 1, 1996 47,730.20 46,922.41 Nov 1, 1996 97,276.25 93,396.35 May 1, 1997 56,516.25 52,994.69 Nov 1~ 1997 76,516.25 70,072.68 May 1# 1998 56#116.25 50,190.28 Nov 1# 1998 91,116.25 79,590.79 May 1, 1999 55,398.75 47,261.00 Nov 1, 1999 200,398.75 166,968.27 May 1, 2000 52,390.00 42,630,78 Nov 1, 2000 232,390.00 184,683.59 May 1, 2001 48~565.00 37,693.83 Nov 1# 2001 228,565.00 173,257.71 May 1, 2002 44#650.00 33,055.24 Nov 1, 2002 234,650.00 169,658.39 May 1, 2003 40,422.50 28,543.94 Nov 1, 2003 245,422.50 169,254.85 May 1, 2004 35,758.75 24,084.91 Nov 1, 2004 245,758.75 161,661.90 May 1, 2005 30,876.25 19,836.23 Nov 1, 2005 255,876.25 160,546.42 May 1, 2006 25~532.50 15,645.88 Nov 1, 2006 260,532.50 155,920.96 May 1, 2007 19,833.75 11,592.67 Nov 1, 2007 269~833.75 154,031.95 May 1, 2008 13,646.25 7,607.88 Nov 1~ 2008 273,646.25 148,996.48 May 1, 2009 7,081.25 3,765.58 Nov 1, 2009 282,081.25 146~498.33 3~528,581.45 2,456,364.02 Proceeds Summary Delivery date Par Value Accrued interest Target for yield calculation 12/21/1995 2,450,000.00 6,364.02 2,456,364.02 00000 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) ESCROW4 COST DETAIL City of BainOridge Island LTGO Refunding Bonds, 1995 Page 14 Type of Maturity Par Accrued Total Security Date Amount Rate Yield Price Cost Interest Cost Global Proceeds Escrow: TNote 10/31/1996 2,000 6.875% 5.060% 101.500000 2,030.00 19.27 2,049.27 TNote 4/30/1997 6,000 6.500% 5.216% 101.656250 6,099.38 54.64 6,154.02 TNote 4/30/1998 3,000 5.125% 5.286% 99.640625 2,989.22 21.54 3,010.76 TNote 10/31/1998 17,000 4.750% 5.308% 98.531250 16,750.31 113.14 t6,863.45 TNote 4/15/1999 2m477,000 7.000% 5.367~. 104.890625 2,598,140.78 31,740.79 2,529,881.57 2,505,000 2,626~009.69 3t,949.38 2,657,959.07 Purchase Cost of Cash Date Securities Deposit Global Proceeds Escrow: 12/21/1995 2,657,959.07 3,220.65 2,657,959.07 3,220.65 Total Escrow Cost 2,661,179.72 2,661,179.72 Yield 4.690329% 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) Page 15 ESCROW4 CASH FLO~ City of Bainbridge Island LTGO Refunding Bonds, 1995 1989 Bonds (1989) - Allocation of Global Date Present Value Other Net Escrow to 12/21/1995 Cash Flows Receipts @ 4.6903286% Dec Apr Apt Oct Oct Apr Apt Oct Oct Apt Apt Oct Oct Apr Nov 21, 1995 3,220.65 3,220,65 3,220.65 15, 1996 86,695.00 86f695.00 85,431.51 30, 1996 744.38 744.38 732.11 15, 1996 86,695.00 86,695.00 83,473.91 31, 1996 2,744.38 2,744.38 2,636.97 15, 1997 86,695.00 86,695.00 81,561.17 30, 1997 6,675.63 6f675.63 6,268.19 15, 1997 86,695.00 86,695.00 79,692.25 31, 1~97 480.63 480.63 440.89 15, 1998 86,695.00 86,695.00 77,866.16 30, 1998 3,480.63 3,480.63 3,120.13 15, 1998 86,695.00 86,695.00 76,081.92 31, 1998 17,403.75 17,403.75 15,241.77 15, 1999 89,295.00 89,295.00 76,567.98 1, 1999 2,474~400.00 2,474,400.00 2,068,844.11 3,118,615.03 3,118,615.03 2,661,179.72 Escrow Cost Sunmary Purchase date Purchase cost of securities Target for yield calculation 12/21/1995 2,661,179.72 2,661,179.72 01-Dec-95 Date Apr 15, Apr Oct 15, Oct 31, Apr 15, Apr 30, Oct 15, Oct 31, Apr 15, Apt 30, Oct 15, Oct 31, Apr 15, Nov 10 12:55 pm Prepared by Pacific Crest Securities (Finance 2,300 BAINBRDG:SCENA,REVENUE-A) Page 16 ESCROW CASH FLOW City of Bainbridge Island LTGO Refunding Bonds, 1995 Global Proceeds Escrow Principal Interest RotLovers 19~6 86,695. O0 1996 744.38 1996 86,695. O0 1996 2, OOO. O0 744.38 1997 ~,695.00 1997 6,000. O0 675.63 1997 86,695.00 1997 480.63 1998 86,695.00 1998 3,000. O0 480 · 63 1998 86,695. O0 1998 17, DO0. O0 403.75 1999 2,47'/,000.00 86,695.00 1999 2,505,000.00 610,394.38 -2,474,400.00 2,474,400.00 Present Value Net Escrow to 12/21/1995 Receipts ~ 4.6903286% 86,695.00 85,431.51 744.38 732.11 86,695.00 83,473.91 21744.38 2,636.97 86,695.00 81#561.17 6#675.63 6,268.19 86,695.00 79,692.25 480.63 440.89 86#695.00 77,866.16 3,480.63 3t120.13 86t695.00 76,081.92 17,403.75 15f241.77 89,295.00 76#567.98 2,474#400.00 2,068,844.11 3,115,394.38 2,657,959.07 Escrow Cost Summary Purchase date Purchase cost of securities Target for yield calculation 12/21/1995 21657,959.07 2,657,959.07 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) Page 17 ESCROW SUFFICIENCY Date Dec 21, 1995 Apr 15, 1996 Apr 30, 1996 May 1, 1996 Oct 15, 1996 Oct 31, 1996 Nov 1, 1996 Apr 15, 1997 Apr 30, 1997 May 1, 1997 Oct 15, 1997 Oct 31, 1997 Nov 1, 1997 Apr 15, 1998 Apr 30, 1998 May 1, 1998 Oct 15, 1998 Oct 31, 1998 Nov 1, 1998 Apt 15, 1999 May 1, 1999 NOV 1, 1999 City of Rainbridge Island LTGO Refunding Bonds, 1995 1989 Bonds (1989) Escrow Net Escrow Excess Excess Requirement Receipts Receipts Balance 89,960.00 89,960.00 89,960.00 89,960.00 89,960.00 104,960.00 89,427.50 2,474,427.50 3,220.65 86,695.00 744.38 86,695.00 2,744.38 86,695.00 6,675.63 86,695.00 480.63 86,695.00 3,480.63 86,695.00 17,403.75 89,295.00 2,474,400.00 3,220.65 3,220.65 86,695.00 89,915.65 744.38 90,660.03 -89,960.00 700.03 86,695.00 87,395.03 2,744.38 90,139.40 -89,960.00 179.40 86,695.00 86,874.40 6,675.63 93,550.03 -89,960.00 3,590.03 86,695.00 90,285.03 480.63 90,765.65 '89,960.00 805.65 86,695.00 87,500.65 3,480.63 90,981.28 -89,960.00 1,021.28 86,695.00 87,716.28 17,403.75 105,120.03 -104,960.00 160.03 89,295.00 89,455.03 -89,427.50 27.53 -27.50 0.03 3,118,615.00 3,118,615.03 0.03 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) ESCROW STATISTICS City of Bainbridge Island LTGO Refunding Bonds, 1995 Page 18 Modified Yield to Yield to Perfect Value of Total Duration Receipt Disbursement Escrow Negative Cost of Escrow Cost (years) Date Date Cost Arbitrage Dead Time Global Proceeds Escrow: 2,661,179.72 3.326 2,661,179.72 4.690329% 4.6757'35% 2,651,626.85 8,181.18 1,371.69 2,651,626.85 8,181.18 1,371.69 Delivery date 12/21/1995 Arbitrage yield 4.783056% 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 8AINBRDG:SCENA,REVENUE-A) PROOF OF COMPOSITE ESCROU YIELD City of Bainbridge [stand LTGO Refunding Bonds, 1995 ALl restricted escrows funded by bond proceeds Date Security Net Escrow Receipts Rol(overs Receipts Present Value to 12/21/1995 ~ 4.6903286% Apr Apr Oct Oct Apr Apr Oct Oct Apr Apr Oct Oct Apr Nov 15, 1996 30, 1996 15, 1996 31, 1996 15, 1997 30, 1997 15, 1997 31, 1997 15, 1998 30, 1998 15, 1998 31, 1998 15, 1999 1, 1999 86,695.00 744.38 86,695.00 2,744.38 86,695.00 6,675.63 86,695.00 480.63 86,695.00 3,480.63 86,695.00 17,403.75 2,563,695.00 '2,474,400.00 2,474,400.00 86,695.00 85,431.51 744.38 732.11 86,695.00 83,473.91 2,744.38 2,636.97 86,695.00 81,561.17 6,675.63 6,268.19 86,695.00 79,692.25 480.63 440.89 86,695.00 77,866.16 3,480.63 3,120.13 86,695.00 76,081.92 17,403.75 15,241.77 89,295.00 76,567.98 2,474,400.00 2,068,844.11 3,115,394.38 3,115,394.38 2,657,959.07 Page 19 Escrow Cost SLm~nary Purchase date Purchase cost of securities Target for yield calculation 12/21/1995 2,657,959.07 2,657,959.07 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) AVERAGE TAKEDOWN City of Bainbridge IsLand LTGO Refunding Bonds, 1995 Page 20 Dated Date 12/01/1995 Oetivery Date 12/21/1995 Bond Component 1996 to 2009: Maturity Par Takedown Takedown Date Amount S/Bond Amount 11/01/1996 40,000 5.00000 200.00 11/01/1997 20,000 5.00000 100.00 11/01/1998 35,000 5.00000 175.00 11/01/1999 145,000 3.75000 543.75 11/01/2000 180,000 3.75000 675.00 11/01/2001 180,000 5.00000 900.00 11/01/2002 190,000 5.00000 950.00 11/01/2003 205,000 5.00000 1,025.00 11/01/2004 210,000 5.00000 1,050.00 11/01/2005 225,000 5.00000 1,125.00 11/01/2006 235,000 6.25000 1,468.7~ 11/01/2007 250,000 6.25000 1,562.50 11/01/2008 260,000 6.25000 1,625.00 11/01/2009 275,000 6.25000 1,718.75 2,450,000 5.35459 13,118.75 Rounded Takedown S/Bond 5.35 Total amount 13,107.50 01-Dec-95 12:55 pm Prepared by Pacific Crest Securities (Finance 2.300 BAINBRDG:SCENA,REVENUE-A) COST OF ISSUANCE City of Bainbridge Island LTGO Refunding Bonds, 1995 Page 21 Cost of Issuance Bond Counsel Bond Printing Trustee Escrow Verification Hoody's $/1000 3.67347 0,70204 0.57143 1.22449 2.12245 Amount 9,000.00 1,720.00 1,400.00 3,000.00 5,200.00 8.29388 20,320.00 REPRESENTATIONS Neither the City nor the Underwriters has authorized any dealer, broker, salesperson or other persons to given any information or make any representations other than those made in this Official Statement, and, if given or made, such other information or representations must not be relied upon as having been authorized by the City or the Underwriter. This Official Statement does not constitute an offer to sell, or the solicitation of an offer to buy, nor shall there be any sale of the Bonds by any person in any jurisdiction in which it is unlawful for such person to make such offer, solicitation or sale. The information contained in this Official Statement has been obtained from City Officials and other sources believed to be reliable. Neither a representation, warranty nor guarantee is made by the Underwriter as to the accuracy or completeness of any information in this Official Statement and nothing contained in this Official Statement is or shall be relief upon as a promise or representation by the Underwriter. The delivery of this Official Statement does not imply that the information contained herein is correct as of any time subsequent to the date of the Official Statement as shown on the cover page. Disclosure Statement The City will deliver to the Underwriter at the time of delivery of the Bonds a signed statement substantially to the effect that this Official Statement, as of its date and as of the date of the Bonds, neither contains any untrue statement of a material fact nor omits to state any material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading in any material respect and that there has not been any material adverse change in the normal operations or financial condition of the City nor, to the best of the City 's knowledge, in the general economy of the City since the date of the Official Statement. Securities Act of 1933 The Bonds have not been registered under the Securities Act of 1933, as amended, in reliance upon specific exemptions contained in such act. The registration or qualification of the Bonds in accordance with applicable provisions of securities laws of the state in which the Bonds have been registered or qualified and the exemption from registration or qualification in other states cannot be regarded as a recommendation thereof. Neither these states nor any of their agencies have passed upon the merits of the Bonds nor the accuracy or completeness of this Official Statement. Any representation to the contrary may be a criminal offense. Secondary Market It has been the practice of the Underwriter to maintain a secondary market in municipal bonds which it sells. The Underwriter intends to engage in secondary market trading of the Bonds, subject to applicable securities laws. The Underwriter, however, is neither obligated to engage in secondary trading nor to repurchase any of the Bonds at the request of the registered owners thereof and no assurance can be given that a secondary market for the Bonds will be available. In connection with the offering of the Bonds, the Underwriter may over-allot or effect transactions that stabilize or maintain the market price of the Bonds at a level above that which might otherwise prevail in the open market. Such stabilizing, if commenced, may be discontinued at anytime. ii City of Bainbridge Island, Washington Page 3 certain periods prescribed by the Code. There is an exception to this rebate requirement available to a governmental unit with general taxing powers in connection with the issuance of obligations other than "private activity bonds" as defined in the Code, if the governmental unit, together with all subordinate governmental units, does not reasonably anticipate issuing more than $5,000,000 of tax-exempt obligations (other than private activity bonds and other obligations not required to be included in such calculation) during the calendar year in which the obligations are issued. The City has certified in the Bond Ordinance that it is an issuer which qualifies for this arbitrage rebate exception in connection with the issuance of the Bonds. As of the date of initial delivery of the Bonds to the purchaser thereof and full payment therefor, it is our opinion that (1) the City is a duly organized and legally existing non-chartered code city under the laws of the State of Washington; (2) the Bonds are issued in full compliance with the provisions of the Constitution and laws of the State of Washington and the ordinances of the City relating thereto; (3) the Bonds constitute valid general obligations of the City payable from annual ad valorera taxes to be levied within the constitutional and statutory tax limitations provided by law without a vote of the electors of the City on all of the taxable property within the City, together with Gross Revenue of the Waterworks Utility, except only to the extent that enforcement of payment may be limited by bankruptcy, insolvency or other laws affecting creditors' rights and principles of equity if equitable remedies are sought; and (4) assuming compliance by the City after the date of issuance of the Bonds with applicable requirements of the Code, including arbitrage requirements, under existing federal law the interest on the Bonds is excluded from gross income of the registered owners for federal income tax purposes and is not an item of tax preference for purposes of the alternative minimum tax applicable to individuals; however, while interest on the Bonds also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations, interest on the Bonds received by corporations is to be taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations, interest on the Bonds received by certain corporations may be subject to an environmental tax, interest on the Bonds received by certain S corporations may be subject to tax, and interest on the Bonds received by foreign corporations with United States branches may be subject to a foreign branch profits tax. We express no opinion regarding any other federal tax consequences of receipt of interest on the Bonds. Respectfully submitted, 0211934.01 TABLE OF CONTENTS Page Introduction .................................................................................................. 1 Description of the Bonds ........................................................................................ The Advance Refunding Plan .............................................. .3 Verification of Mathematical Calculations ...................................................................4 Administration of Refunding Plan ................................................... 4 .5 Purpose ............................................................................................................. ...................... 5 Sources and Uses of Funds ................................................................ Debt Payment Record ......................................................................................5 5 Future Financing .................................................................................................. ..5 Security ..................................................... 5 Litigation ..................................................... . ..................... 6 Assessed Valuation Determination .................................... 6 Tax Collection Procedure ....................................................................................... 6 Initiative 601 ............................................................................ .7 Authorization of Debt ........................................................................................... · .7 General Obligation Indebtedness ................................................... Limits on Amount of General Obligation Indebtedness ........................ 7 Computation of Statutory Debt Limitations ..................................................................9 Net Direct and Overlapping General Obligation Debt .....................................................9 Bonded Debt Ratios ............................................................... .10 Major Taxpayers Within the City ........................................................ l0 Taxing Powers and Limitations ................................................22222222222......................lo .11 Tax Collection Record of the City ...........................................................~7" ... 12 Levy Amounts and Rates of the City ............................................ Representative City Property Tax Rates ......................................................................12o Comparative Statement of Combined Tax Supported Fund Revenues and Expenditures ............ 1 ~ Combined Tax Supported Fund Revenues and Expenditures, 1995 Budget ........................... 13 Schedule of General Obligation Bonded Indebtedness of the City .......................................14 Historical Combined Waterworks Utility Operations ......................... .15 .16 The City ........................................................... .17 General and Economic .......................................................................................... Preservation of Tax Exemption ..................................................................18 ......... 26 Tax Exemption ............................................................................. .26 Certain Other Federal Tax Consequences .................................................................. Approval of Bond Counsel ......................................................................................277 co.mcts of Interest .........................................................................................222222:2a Rating .......................................... ............................................................... 28 Underwriting ..................................................... . ......... 28 Continuing Disclosure Undertaking ............................................. . .30 CUSIP Numbers ................................................................................................. · .30 Miscellaneous .................................................................................................... Form of Counsel Opinion ..........................................................................Appendix A iv FOSTER PEPPER & SHEFELMAN [FORM OF APPROVING LEGAL OPINION] City of Bainbridge Island, Washington City of Bainbridge Island, Washington, $2,455,000 Limited Tax General Obligation Refunding Bonds, 1995 We have examined a certified transcript of proceedings had by the City of Bainbridge Island, Washington (the "City"), relating to its issuance of the above-referenced bonds (the "Bonds") and also have examined an executed and authenticated Bond or a facsimile thereof. The Bonds are issued pursuant to law for the purpose of providing the funds required to refund the City's outstanding Water and Sewer Revenue Bonds, 1989, and to pay the costs of issuance and sale of the Bonds, all as set forth in the Ordinance No. (the "Bond Ordinance") and under and in accordance with the Constitution and laws of the State of Washington and ordinances of the City. The Bonds are fully registered; are in the denomination of $5,000 or any integral multiple thereof within a single maturity; are numbered separately; are dated December 1, 1995; and bear interest at the rates set forth below, payable semiannually on each May 1 and November 1, commencing May 1, 1996, to the maturity or earlier redemption of the Bonds. The Bonds are payable at the principal office of either of the fiscal agencies of the State of Washington in Seattle, Washington, or New York, New York (collectively, the "Bond Registrar"). The Bonds mature on November 1 in years and amounts and bear interest at the rates per annum as follows: Maturity Interest Years Amounts Rates 1996 $ 35,000 1997 20,000 1998 35,000 1999 145,000 2000 180,000 Notice of Redemption Notice of any such early redemption of the Bonds will be given not less than 30 nor more than 60 days prior to the date fixed for redemption, by first-class mail, postage prepaid, to the Owners of each Bond to be redeemed at the address appearing on the Bond Register at the time the Bond Registrar prepares the notice. The requirements of notification will be deemed to be complied with when notice is mailed as provided by the Bond Ordinance, whether or not it is actually received by the Owner of any Bond. In addition, such redemption notice shall be mailed within the same period, postage prepaid, to such other persons, including registered securities depositories, and with such additional information as the City Director of Finance and Administrative Services shall deem appropriate, but such mailings shall not be a condition precedent to the redemption of such Bonds. If such notice shall have been given and the City shall have set aside, on the date fixed for redemption, sufficient money for the payment of all Bonds called for redemption, the Bonds so called shall cease to accrue interest after such redemption date, and all such Bonds shall be deemed not to be outstanding hereunder for any purposes, except that the Owners thereof shall be entitled to receive payment of the redemption price and accrued interest to the redemption date from the money set aside for such purpose. If any Bond is not paid upon proper presentment at its maturity or earlier redemption. the City shall be obligated to pay interest at the same rate for such Bond until such Bond, both principal and interest, is paid in full. Purchase of the Bonds by the City The City further reserves the right and option to purchase any or all of the Bonds in the open market at any time at any price acceptable to the City plus accrued interest to the date of purchase when the Bonds are available for purchase. All Bonds so purchased or redeemed shall be canceled. Registrar, Paying Agent and Transfer Agent Both principal of and interest on the Bonds are payable in lawful money of the United States of America. Principal of the Bonds will be paid by the Fiscal Agency of the State of Washington (the "Registrar," the "Paying Agent" and the "Transfer Agent") upon presentation and surrender of the Bonds, at maturity or earlier redemption, at either of the principal corporate trust offices of the Registrar in Seattle, Washington or New York, New York. Interest on the Bonds will be paid by check or draft of the Paying Agent mailed on the interest payment date to the registered owners at the addresses appearing on the Bond Register on the fifteenth day of the month preceding the interest payment date. Currently, the Fiscal Agency of the State of Washington is First Interstate Bank of Washington, N.A., Seattle, Washington, and The Bank of New York, New York, New York. Transferability The Bonds may be transferred only on the Bond Register maintained by the Registrar for that purpose and only if endorsed in writing in the manner provided thereon and surrendered by the Registered Owner or Registered Owner's nominee to the Registrar for re-registration upon the Bond Register and on the Registration Certificate on the Bonds. Such transfer shall be without cost to the Registered Owner or transferee. The City and the Registrar may deem the person in whose name each Bond is registered to be the absolute owner thereof for the purposes of securing payment of the principal of and interest on such Bond and for any and all other purposes whatsoever. Upon surrender thereof to the Registrar, the Bonds are interchangeable for Bonds in any authorized denomination of an equal aggregate principal amount and of the same interest rate and maturity. The Registrar shall not be obligated to exchange or transfer any Bond during the fifteen days preceding any principal payment or redemption date. CUSIP NUNIBERS It is anticipated that CUSIP identification numbers will be printed on the Bonds l but neither the failure to print such numbers on any Bonds or any error with respect thereto shall constitute cause for a failure or refusal by the purchaser hereof to accept delivery of and pay for said Bonds in accordance with the terms of the purchase contract. All expenses in relation to the printing of CUSIP numbers on said Bonds shall be paid by the City; provided, however, that the CUSIP Service Bureau charge for the assignment of said numbers shall be the responsibility of and shall be paid for by said purchaser. MISCELLANEOUS The descriptions of the Ordinance and other documents are brief summaries of certain provisions thereof. Such summaries do not purport to be complete, and reference is made to such documents and contracts, copies of which are on file with the City, for full and complete statements of their provisions. All estimates and projections included in this Preliminary Official Statement, whether or not so stated, are not to be construed as representations that the same will be realized. Section headings, tables headings and captions are included for convenience only and should not be construed as modifying the text of this Preliminary Official Statement. The City's financial statements for fiscal years 1990 and 1991 have been audited by the Washington State Auditor's Office. Information concerning the City contained in this Preliminary Official Statement has been furnished by the City. All projections and other statements in this Preliminary Official Statement involving matters of opinion, whether or not expressly so stated, are intended as such and not as representations of fact. This Preliminary Official Statement is not to be construed as a contract or agreement between the City and the purchasers or holders of any of the Bonds. The execution and delivery of this Preliminary Official Statement has been duly authorized by the City. Dated: , 1995 THE CITY OF BAINBRIDGE ISLAND, WASHINGTON By: \s\ Director of Finance and Administrative Services 3O VERIFICATION OF MATHEMATICAL COMPUTATIONS Ernst & Young LLP, a firm of independent public accountants, will deliver to the City its attestation report indicating that it has examined, in accordance with standards established by the American Institute of Certified Public Accountants, the information and assertions provided by the City and its representative. Included in the scope of its examination will be a verification of the mathematical accuracy of (a) the mathematical computation of the adequacy of the cash and the maturing principal of and interest on the Acquired Obligations deposited in the Escrow Fund to pay when due, maturing principal of, principal redemption of and interest on the Refunded Bonds; and (b) the mathematical computations supporting the conclusions of Bond Counsel that the Bonds are not "arbitrage bonds" under the Code and the regulations promulgated thereunder. ADMINISTRATION OF THE REFUNDING PLAN The Escrow Agent is authorized and directed to purchase the Acquired Obligations (or substitute obligations) and to make the payments required to be made by the Refunding Plan from the Acquired Obligations (or substitute obligations) and money deposited with the Escrow Agent pursuant to the Ordinance. All Acquired Obligations (or substitute obligations) and the money deposited with the Escrow Agent and any income therefrom shall be held irrevocably, invested and applied in accordance with the provisions of the Ordinance, Chapter 39.53 RCW and other applicable statutes of the State of Washington, and the Escrow Agreement. All necessary and proper fees, compensation and expenses of the Escrow Agent for the Bonds and all other costs incidental to establishing the escrow to accomplish the refunding of the outstanding Refunded Bonds and costs related to the issuance and delivery of the Bonds, including bond printing, rating service fees, verification fees, bond counsel's fees and other related expenses, shall be paid out of the proceeds of the Bonds. Authorization for Escrow Agreement In order to carry out the Refunding Plan provided for by the Ordinance, the Mayor or the Director of Finance and Administrative Services is authorized and directed to execute and deliver to the Escrow Agent, an Escrow Agreement setting forth the duties, obligations and responsibilities of the Escrow Agent in connection with the payment, redemption and retirement of the Refunded Bonds, as provided in the Ordinance and stating that the provisions for payment of the fees, compensation and expenses of such Escrow Agent set forth therein are satisfactory to the Escrow Agent. Prior to executing the Escrow Agreement, the Director of Finance and Administrative Services is authorized to make sure such changes therein which do not change the substance and purpose thereof or which assure that the escrow provided therein and the Bonds are in compliance with the requirements of federal law governing the exclusion of interest on the Bonds from gross income for federal income tax purposes. All money and the Acquired Obligations on deposit with the Escrow Agent, including interest to be earned thereon, are pledged solely and irrevocably for the benefit of the holders of the Refunded Bonds and are not available for payment of the Bonds. The advance refunding will defease the Refunded Bonds, and they will no longer be considered outstanding obligations of the City. The Escrow Agent First Interstate Bank of Washington, N.A., is serving as the Escrow Agent for the purpose of managing the cash and investments which comprise the Acquired Obligations for the Refunded Bonds, which will pay the principal of, interest on and redemption premium, if any, on the Refunded Bonds, as the same become due and payable. CONFLICTS OF INTEREST Some or all of the fees of the Underwriter and Bond Counsel are contingent upon the issuance and sale of the Bonds. Furthermore, Bond Counsel from time to time serves as counsel to the Underwriter with respect to issuers other than the City and transactions other than the issuance of the Bonds. None of the Councilmembers or other officials of the City have an interest in the issuance of the Bonds that are prohibited by applicable law. RATING The Bonds have been rated "A" by Moody's Investors Service.. The rating reflects only the view of the rating agency and an explanation of the significance of the rating may be obtained from Moody's Investors Service. There is no assurance that the rating will be retained for any given period of time or that the rating will not be revised downward, suspended or withdrawn entirely by the rating agency if, in their judgment, circumstances so warrant. Any such downward revision, suspension or withdrawal of the rating will be likely to have an adverse effect on the market price of the Bonds. UNDERWRITING The Bonds are being purchased by the Underwriter, Pacific Crest Securities, Inc. The Underwriter has agreed to purchase the Bonds at an underwriting discount of $ from the initial offering prices reflected on the cover page. The Purchase Contract for the Bonds provides that the Underwriter will purchase all the Bonds, if any are purchased. The public offering prices for the Bonds set forth on the cover page hereof may be changed after the initial offering by the Underwriter. The City has agreed to indemnify the Underwriter against certain liabilities. CONTINUING DISCLOSURE UNDERTAKING Basic Undertaking to Provide Annual Financial Information and Notice of Material Events. Because it will have outstanding less than $10,000,000 of obligations after the issuance of the Bonds, the City is currently exempt from the requirements of United States Securities and Exchange Commission (SEC) Rule 15c2-12(b)(5) (the "Rule"), as applicable to a participating underwriter for the Bonds, however, the City will undertake (the "Undertaking") for the benefit of holders of the Bonds to provide or cause to be provided, either directly or through a designated agent, to each nationally recognized municipal securities information repository designated by the SEC in accordance with the Rule CNRMSIR") and to a state information depository, if any, established in the state of Washington (the "SID") annual financial information and operating data of the type included in this Official Statement as generally described below Cannual financial information"); and to each NRMSIR or the Municipal Securities Rulemaking Board CMSRB"), and to the SID, timely notice of the occurrence of any of the following events with respect to the Bonds, if material: (i) principal and interest payment delinquencies; (ii) non-payment related defaults: (iii) unscheduled draws on debt service reserves reflecting financial difficulties; (iv) unscheduled draws on credit enhancements reflecting financial difficulties: (v) substitution of credit or liquidity providers, or their failure to perform; (vi) adverse tax opinions or events affecting the tax-exempt status of the Bonds; (vii) modifications to rights of holders of the Bonds; (viii) Bond calls (other than scheduled mandatory redemptions of Term Bonds); (xi) defeasances; (x) release, substitution, or sale of property securing repayment of the Bonds; and (xi) rating changes. The City also will provide to each NRMSIR or to the MSRB, and to the SID, timely notice of a failure by the City to provide required annual financial information on or before the date specified below. 28 ASSESSED VALUATION DETERMINATION In the State of Washington, the County Assessor (the "Assessor") determines the value of all real and personal property throughout the County (including the City), which is subject to ad vaIorem taxation. The Assessor' s duties and methods of determining value are prescribed and controlled by statute and by detailed regulations promulgated by the Department of Revenue of the State of Washington. For tax purposes the assessed value of property is set at 100% of its actual value. By state statute all property is subject to re-evaluation at least every four years. The property is listed by the Assessor on a tax roll at its current assessed value and the tax roll is filed in the Assessor' s office. The Assessor's determinations are subject to revision by the County Board of Equalization and, for certain property, subject to further revision by the State Board of Equalization. After all administrative procedures are completed, the taxing unit receives the Assessor's final certificate of assessed value of property within the taxing unit. TAX COLLECTION PROCEDURE Property taxes are levied in specific amounts, and the rate for all taxes levied for all taxing districts in the County (including the City) are determined, calculated and fixed by the Assessor based upon the assessed valuation of the property within the various taxing districts. The Assessor extends the taxes to be levied within each taxing district upon a tax roll which contains the total amount of taxes to be so levied and collected and assigns a tax account number to each tax lot. The tax roll is delivered to the Kitsap County Treasurer by December 15 of each year, and an abstract of the tax roll, showing the total amount of taxes collectible in each of the taxing districts for the year, is delivered to the Board of County Commissioners at the same time. All taxes are due and payable on the 30th of April of each year, but if the amount due from a taxpayer exceeds thirty dollars ($30.00), one-half may be paid then and the balance no later than October 31 of each year. The method of giving notice of pay. ment of taxes due, accounting for the money collected, the division of the taxes among the various taxing districts, giving notice of delinquency, and collection procedure are all covered by detailed statutes. The lien for ad valorem property taxes which have been levied prior to the filing of federal tax liens is prior to such federal tax liens. In other respects, and subject to the possible "Homestead Exemption," the lien for delinquent property taxes is prior to all other liens or encumbrances of any kind on real or personal property subject to taxation. By law (Chapter 6.13 RCW) the taxing district may commence foreclosure of a tax lien on real property after three (3) years have passed since the first delinquency. Washington State's courts have not decided whether the Homestead Exemption gives the occupying homeowner a right to retain the first $30,000 proceeds of a forced sale of a family residence for delinquent general property taxes. INITIATIVE 601 Initiative 601 was approved by the voters of the state on November 2, 1993. On July 1, 1995, Initiative 601 began limiting spending from the State's general fund by a "fiscal growth factor" based on the rate of inflation and the rate of population growth in the State. Increases in State taxes up to the spending limit must now be approved by a 2/3 vote in each house of the legislature. Increases in tax revenues above the spending limit must be approved by a 2/3 vote of the legislature and by a majority of voters at the next election. State fees may not be increased at a rate greater than the "fiscal growth factor" without prior legislative approval. Additionally, the legislature may not mandate new programs or increased levels of service in existing programs by local governments without appropriating enough money to reimburse such costs fully. Initiative 601 does not, by its terms, effect the authority of the City or other cities to authorize or issue general obligation bonds or to levy and collect taxes for the payment of general obligation bonds. The City does not believe that Initiative 601 will have any material effect on the finances of the City nor the ability of the City to pay debt service on the Bonds. PRESERVATION OF TAX EXEMPTION The City covenants that it will take all actions necessary to prevent interest on the Bonds from being included in gross income for federal income tax purposes, and it will neither take any action nor make or permit any use of proceeds of the Bonds or other funds of the City treated as proceeds of the Bonds at any time during the term of the Bonds which will cause interest on the Bonds to be included in gross income for federal income tax purposes. The City certifies that it has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that it is a bond issuer whose arbitrage certifications may not be relied upon. TAX EXEMPTION Exclusion from Gross Income In the opinion of Bond Counsel, assuming compliance by the City with applicable requirements of the Code, including arbitrage requirements under Section 148 of the Code, interest on the Bonds is excluded from gross income of registered owners for federal income tax purposes under existing federal law and is not an item of tax preference for purposes of the alternative mininmm tax applicable to individuals. Corporate Alternative Minimum Tax While interest on the Bonds also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations, under Section 55 of the Code, tax-exempt interest, including interest on the Bonds, received by corporations is taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations (as defined for federal income tax purposes). Under the Code, alternative minimum taxable income of a corporation will be increased by 75 percent of the excess of the corporation's adjusted current earnings (including any tax-exempt interest) over the corporation' s alternative minimum taxable income determined without regard to such increase. A corporation's alternative minimum taxable income, so computed, that is in excess of an exemption of $40,000, which exemption will be reduced (but not below zero) by 25 percent of the amount by which the corporation's alternative minimum taxable income exceeds $150,000, is then subject to a 20 percent minimum tax. Corporate Environmental Tax Section 59A of the Code imposes for taxable years beginning on or before January 1, 1996, an environmental tax of 0.12 percent ($1.20 per $1,000) on the amount of a corporation's alternative minimum taxable income (increased for certain book income and adjusted current earnings, including any tax-exempt interest) that exceeds $2,000,000. Tax on Certain Passive Investment Income of S Corporations Under Section 1375 of the Code, certain excess net passive investment income, including interest on the Bonds, received by an S corporation (a corporation treated as a partnership for most federal tax purposes) that has Subchapter C earnings and profits at the close of the taxable year may be subject to federal income taxation at the highest rate applicable to corporations if more than 25 percent of the gross receipts of such S corporation is passive investment income. Foreign Branch Profits Tax Interest on the Bonds may be subject to the foreign branch profits tax imposed by Section 884 of the Code when the Bonds are owned by, and effectively connected with a trade or business of, a United States branch of a foreign corporation. 26 and park facilities - 2-1/2%. The combination of unlimited tax and limited tax general obligation debt for all purposes cannot exceed 7.5 % of the City's assessed valuation. The State statutory limks on City general obligation indebtedness described in this section are more restrictive than those contained in the State Constitution. Both the Constitutional and statutory debt limits may be exceeded if necessary to meet obligations made mandatory by State law or, if necessary, to maintain the corporate existence of the City. In computing total general obligation indebtedness, the following "assets" may be deducted against the principal amount of indebtedness outstanding: (a) money and invesUnents on deposit in general obligation bond retirement funds; (b)taxes (both current and delinquent) levied for the payment of general obligation indebtedness; and (c) delinquent (but not current) taxes due the general fund. In addition to limits on the total principal amount of general obligation indebtedness described in this section, the Constitution and statutes of the State impose other limitations on the City's levy of taxes upon real and personal property. (See section herein entitled "TAXING POWERS AND LIMITATIONS" .) BREMERTON PMSA (KITSAP COUNTY) AVERAGE ANNUAL RESIDENT CIVILIAN LABOR FORCE DATAIs 1994 1993 1992 1991 1990 1989 1988 1987 Civilian Labor Force Total Employment Unemployment Unemployment as a percent of labor force 89,500 90,100 88,900 85,600 84,300 79,900 76,400 72,900 84,100 84,100 83,500 81,400 80,900 75,600 72,300 68,500 5,400 6,000 5,400 4,200 3,400 4,300 4,100 4,400 6.0% 6.7% 6.1% 4.9% 4.0% 5.4% 5.4% 6.0% BREMERTON PMSA (KITSAP COUNTY) NON-AGRICULTURAL WAGE AND SALARY WORK. ERS19 1994 1993 1992 TOTAL WAGE AND SALARY WORKERS 67,300 67,900 67,800 TOTAL MANUFACTURING 1,900 1,800 1,800 MINING &MISCELLANEOUS 600 700 500 CONSTRUCTION 3,100 3,300 3,300 TRANSPORTATION, COMMUNICATIONS &PUBLIC UTILITIES 1,800 1,800 1,800 WHOLESALE AND RETAIL TRADE 14,800 14,900 14,700 FINANCE, INSURANCE AND REAL ESTATE 2,700 2,700 2,500 SERVICE S 15,000 14,900 13,500 GOVERNMENT 27,300 27,800 29,400 WORKERS IN LABOR-MANAGEMENT DISPUTES 45 0 0 1991 1990 66,800 65,000 1,700 1,900 500 500 3,100 3,200 1,700 1,700 14,300 13,700 2,400 2,300 14,400 13,400 28,700 28,400 0 0 Source: Washington State Employment Security Department Source: Washington State Employment Security Department 24 CITY OF BAINBRIDGE ISLAND BONDED DEBT RATIOS 1995 Assessed Valuation City Population Ratio of: Net Direct Debt to Assessed Value Net Direct and Estimated Overlapping Debt to Assessed Value Per Capita: Net Direct Debt Net Direct and Estimated Overlapping Debt Assessed Valuation $1,858,795,349 17,910 0.23% 3.19% $238 $3,309.72 $103,785 MAJOR TAXPAYERS WITHIN THE CITY Name of TaxDaver Port Blakely Tree Farms Puget Sound Power & Light U.S. West Communications Country Club of Seattle Alexander & Baldwin, Inc. Crystal Springs Property Devel. North Washington Associates Harding Fletcher Company Grahame & Barbara Watson Madison Ave Retirement Center Winslow Cohousing Totem Storage Curtis F. Kingsbury Edgewood Villa Associates Totals Timber land Electric utility Telephone utility Country club Property management Property management Property management Manufacturer Retirement center Apartments Storage facility Marina condominiums Apartments Assessed~ Valuation~ 536,689,890 12,761,549 7,594,441 6,003,861 5,893,000 3,599,660 3,551,080 3,000,000 2,857,070 2,631,000 2,420,880 2,384,000 2,001,000 2.000,000 $93,387,431 Percent of Citv AV 1.97% 0.69% 0.41% 0.32% 0.32% 0.19% 0.19% 0.16% 0.15% 0.14% 0.13% 0.13% 0.11% 0.11% 5.02 % 2 1994 Assessed Valuation for 1995 taxes. 10 The following contain economic indicators for the City of Bainbridge Island Kitsap County and King County. pOpULATION~2 CRy of Kitsap King Bainbridge Island County County 1995 17,910 220,600 1,613,600 1994 17,510 213,210 1,599,500 1993 17,200 210,000 1,587,700 1992 16,850 205,600 1,564,486 1991 16,390 196,500 1,542,286 1990 census 15,846 189,731 1,507,305 1989 14,495 183,150 1,463,301 1988 14,253 179,365 1,428,605 1987 14,010 172,008 1,400,194 1986 13,768 167,429 1,376,073 1985 13,526 168,709 1,356,552 City of Bainbridge Island CITY OF BAINBRIDGE ISLAND NUMBER OF HOUSING UNITS BY STRUCTURE TYPE~3 Mobile Homes, Total One-Unit Two or More Trailers, & Housing Units Structures Unit Structures Special Units 1990 1995 1990 1995 1990 1995 1990 1995 1,596 7,805 665 6,049 776 1,300 155 456 ASSESSED VALUATION~4 Year CRy of Bainbridge Island Kitsap County King County 1995 $1,858,795,349 $10,670,426,158 $120,828,946,549 1994 1,812,935,103 10,190,219,955 118,222,725,598 1993 1,757,272,419 9,236,571,898 117,625,404,009 1992 1,686,414,209 8,251,019,186 104,292,255,110 1991 204,993,587 6,661,235,888 102,212,020,082 1990 153,396,054 5,947,069,239 73,097,889,390 ~2 Source: City of Bainbridge Island Population for Bainbridge Island from 1987-1991 is Winslow and formerly unincorporated area of Bainbridge Island. ~3 Source: Washington State Office of Financial Managemere. Effective February 28, 1991 the entire land area of Bainbridge Island was incorporated as the City of Winslow. On November 5, 1991, the name of the City was changed to Bainbridge Island. 14 Source: Kitsap County Assessor's Office (1991 and 1990 are Assessed Valuations prior to annexation) 22 TAX COLLECTION RECORD OF THE CITY3 (As of October 31, 1995) Collected Year 1995 1994 1993 1992 1991 1990 Taxable Collected Collected as of Assessed Tax Year of Levy October 31, 1995 Valuation Levy Amount Percent Amount Percent $1,858,795,349 $2,468,560 $1,633,842 66.19% $1,633.842 66.19% 1,812,935,103 2,408,772 1,643,088 68.21% 2,376,342 98.65% 1,757,272,419 2,334,446 2,228,650 95.47% 2,317,514 99.27% 1,686,414,209 2,240,642 2,142,470 95.62% 2,237,146 99.84% 204,993,587 478.053 455,439 95.27% 477,726 99.93% 153,396,054 414,054 396,584 95.75% 413,344 99.83% NOTE: Taxes are due and payable on April 30, of each year. At least one half of the tax amount due must be paid on or before April 30, or else the total amount becomes delinquent on May 1. The second half of the tax due is payable on or before October 31, becoming delinquent November 1. LEVY AMOUNTS AND RATES OF THE CITY4 LEVY AMOUNT LEVY RATE Year Regular EMS Bond Total Regular EMS Bond Total 1995 $2,468,560 0 0 $2,468,560 $1.328 0 0 $1.328 1994 2,407,659 0 0 2,407,659 1.328 0 0 1.328 1993 2,333,700 0 0 2,333,700 1.328 0 0 1.328 1992 2,239,633 0 0 2,239.633 1.328 0 0 1.328 1991 477,786 0 0 477,786 2.331 0 0 2.331 1990 413,873 0 16,050 429,973 2.698 0 .106 2.804 REPRESENTATIVE OVERLAPPING PROPERTY TAX RATES5 For City Residents (Rates in Dollars per $1,000 of Assessed Valuation for 1995 Collection) State Schools $3.5508 Kitsap County 1.2249 City of Bainbridge Island 1.3280 Bainbridge Island School District 4.6214 Kitsap County Rural Library 0.4595 Fire Protection District No. 2 1.0822 Bainbridge Island Park & Rec District 1.4012 Public Utility District 0.0940 Total $13.7620 Source: Kitsap County Treasurer's Office. Source: Kitsap County Assessor's Office. Source: Kitsap County Assessor's Office. 12 Kitsap County Kitsap County is located in western Washington on the western side of Puget Sound and covers 398 square miles of land, including the northern portion of Kitsap Peninsula and Bainbridge Island. The County has 211 miles of salt water shoreline: Hood Canal to the west, Admiralty Inlet to the north and Puget Sound to the east. The topography is mostly low, fiat-topped rolling hills separated by valleys and bays, with altitudes from sea level to 600 feet above, except for Green and Gold mountains, which rise to 1,761 feet above sea level. The climate is moderate, with mild, wet winters and cool, dry summers. Mean annual precipitation ranges from 26 inches in the north to nearly 80 inches in the mountains. Kitsap County is divided into two distinct sections: the Kitsap Peninsula and Bainbridge Island. The Kitsap Peninsula is home to several naval installations. Much of this area is rural and includes the Hood Canal area. Hood Canal is a major recreation area and has attracted many seasonal residents who own homes on the shore. The region's natural resources include extensive shoreline, fish, shellfish, and timber. The economy of the County is based primarily on the U.S. Naval installations, which employ over 16,000 civilians and 15,700 military personnel. Population Kitsap County has been one of the fastest growing counties in the Puget Sound Region since 1970. The population of the County has increased 86.5% since 1970, nearly 90,000 new residents. The State population only grew 42.6% during the same time. Between 1980 and 1990, Kitsap County had an annual growth rate of 2.89% while the State was 1.77%. By the year 2012, the population is projected to be 269,700. The largest city in the County is Bremerton, with 39,610 residents. The other incorporated areas are Bainbridge Island (17,910), Port Orchard (6,240), and Poulsbo (5,756). Employment Kitsap County is defined as the Bremerton Metropolitan Statistical Area (MSA) for employment and unemployment statistics. In 1994, the labor force in the MSA numbered 89,500. The rate of unemployment was 6.0 %, compared with 6.4 % for Washington State. Non-manufacturing employment in the MSA for 1994 accounted for 97.2% of wage and salary jobs, while manufacturing accounted for 2.8% of employment. Government (federal, state and local) continues to be the largest employer in Kitsap County accounting for 40.6 % of employment. Transportation The peninsula is accessible by land from highways located at the southern end of Puget Sound. Interstate 5 and Highway 101 are connected by a six-mile leg near Olympia, and State Highway 3 branches off Highway 101 and heads north to Bremerton. A bridge across Puget Sound at south Tacoma carries State Highway 16 to Kitsap County. Washington State Ferries connect with Kitsap County at four points. Regular ferry service carries vehicles, foot passengers and cargo between Edmonds and Kingston, Seattle and Bainbridge Island, between Seattle and Bremenon, and between Fauntleroy, in west Seattle and Southworth on the Kitsap Peninsula. The Kitsap County Public Transportation Benefit Area Authority was established by the voters in I982 to provide public transportation in the most heavily populated portions of the County. The system, called Kitsap Transit, provides four types of services: regular public transit, commuter bus transit, transportation of the elderly or handicapped, and carpool and vanpool services. Bremerton National Airport is the largest airport in the County. The airport can handle all general aviation aircraft and most transport and military planes. Charter passenger and air freight services are available at SeaTac Airport in the Seattle-Tacoma area, the major international airport serving the Puget Sound area. 2O COMBINED TAX-SUPPORTED FUND REVENUES AND EXPENDITURESa 1995 BUDGET (Fiscal Year Ending December 31) Estimated Beginning Fund Balance Revenues: Taxes Fees & Service Charges Intergovernmental Fines & Forfeits Miscellaneous Investment Interest Total Revenues Operating Transfers In & Other Sources Sale of Bonds LID 13 Interfund Loan Repayment From Other Funds Total Non-Revenues Total Resources Expenditures: Salaries Benefits Supplies Professional Services Other Services and Charges Intergovernment Capital Debt Service Other Expenditures Total Expenditures Operating Transfers Out To Other Funds Total Non-Expenditures Budgeted Ending Fund Balance Total Uses $1,600,000 255,000 2.460.862 $2,838.933 $ 3,924,158 $ 4,621,093 598,100 2,088,567 109,500 327,858 121.432 $ 7,866,550 $ 4.315,862 $I6,106.570 $ 3,088,152 927,212 254, I47 1,284,032 1,035,020 539,489 3,542,760 46,689 466.031 $ i1,183.532 $ 2.838.933 $ 2,084,105 $16.106,570 Source: City of Bainbridge Island 14 The City Director of Finance and Administrative Services maintains general supervision over financial transactions of all City funds and supervises all accounting. The accounts of the City are organized by fund and account group, each of which is considered a separate accounting entity. Each fund has a separate set of self-balancing accounts that comprise its assets, liabilities, fund equity, revenues and expenditures or expenses, as appropriate. The City's resources are allocated to, and accounted for in, individual funds according to the purposes for which they are spent and the means b.y which spending activities are controlled. The full annual basis of accounting is employed for all proprietary funds. Labor Relations The City currently employs 108 full-time, part-time and temporary employees and approximately 85 % of the employees are represented by two bargaining units, both represented by District Lodge 160 of the International Association of Machinists and Aerospace Workers. Contracts are in place through 1996 for police and 1997 for all other represented employees. The City strives to be fair with all employees, consistent with all applicable state law, to ensure equity, and promote labor relation policies mutually beneficial to management and employees. Pension System Pensions for the City employees are provided through the Washington State Department of Retirement Systems by other the Public Employees Retirement System (PERS I and PERS II) or the Law Enforcement Officers and Fire Fighters (LiEOFF I & II). The City's contributions to all retirement systems are current. Insurance The City is a member of the Washington Cities Insurance Authority which pools insurance risk among 82 Washington cities. Liability coverage is self-funded and limits are layered with $1 million per loss in the primary layer, and an additional $4 million per lnss in the excess layer (subject to a $16 million aggregate limit). GENERAL AND ECONOMIC City of Bainbridge Island The City of Bainbridge Island is approximately eight miles west of the City of Seattle across Elliott Bay and Puget Sound on Bainbridge Island. Bainbridge Island is primarily a residential community, which has a mix of suburban and rural neighborhoods. There are a few industrial concerns and some commercial areas as well. The extensive waterfront and view property on Bainbridge Island and its close proximity to Seattle have made it particularly appealing. Bainbridge Island, which is twelve miles long and four miles wide, is connected to the county mainland and the Olympia Peninsula by the Agate Pass Bridge. Seattle can be accessed via a State-operated ferry. The City of Winslow was the only incorporated area on Bainbridge Island until November 6, 1990, when the voters approved annexation of the unincorporated area of the Island. Effective February 28, 1991 the entire land area of Bainbridge Island became incorporated as the City of Winslow. On November 5, 1991, the voters of the incorporated City of Winslow agreed to change the name of the City to Bainbridge Island. Extensive waterfronts, view property and close proximity to Seattle has contributed to making Bainbridge Island a predominantly residential community with high property values. As a result of the short commute to downtown Seattle, a disproportionately large percentage of the population are financial and legal professionals who work in Seattle. Based on the 1990 Census data, half of the work-force commutes to jobs outside the community. Roughly one4hird commute by ferry to Seattle. 18 The City has pledged to pay the debt service of the Bonds from available revenues of the Waterworks Utility of the City (see "SECURITY" herein). CITY OF BAINBRIDGE ISLAND HISTORICAL COMBINED WATERWORKS U~JLITY OPERATIONS (Year Ending December 3 1)9t UNAUDITED UNAUDITED UNAUDITED AUDITED 1994 1993 1992 1991 Operating Revenues Water Sales and Services Sewer Services Storm Drain Services Other Fees/Charges Total Operating Revenues Operating Expenses Cost of Sales and Services Administration Total Operating Expenses Non-Operating Revenues & Expenses Imerest Revenue Special Assessment Principal Interest & Penalties on ULID's Other Revenue Amortization Expense Total Non-Operating Revenues & & Expenses Required Capital Contributions Net Revenue Available for Debt Service Annual Debt Service Annual Debt Service Coverage Junior Lien Debt Balance $578,257 $386,568 $349,964 $377,680 618,196 623,684 547,944 552,362 364,367 356,386 230,536 115,125 0 0 2.505 0 $1,560,820 $1,366,638 $1,130,959 $1,045,167 $905,070 $687,176 $497,273 $414,173 306,286 422,766 519,167 405,956 $1,211,356 $1,109,942 $1,016,440 $820,129 $201,461 $227,807 $165,723 $281,733 20,166 50,382 38,901 56,981 10,622 21,983 15,350 29,577 311 -- 9,286 10,427 (7,814) (6,631) (533) (8,460) $224,746 $293,541 $228.727 $370,258 386,380 351,000 269,388 266,599 960,590 901,237 612,624 861,895 329,657 353,088 415,860 432,015 2.91 2.55 1.47 2.00 0 0 0 0 $630,933 $548,149 $196,764 $429,880 Source: City of Bainbridge Island Annual Financial Reports. On January 1, 1994, Water rates were increased 42% and Sewer rates were increased by 3.0%. At the same time, required system participation fees for water and sewer (accounted for as capital contributions) were increased from $2,808 for a single family residence or equivalent to $5,000 (a 78% increase). 16 The City has pledged to pay the debt service of the Bonds from available revenues of the Waterworks Utility of the City (see "SECURITY" herein). CITY OF BAINBRIDGE ISLAND HISTORICAL COMBINED WATERWORKS .U,~JLITY OPERATIONS (Year Ending December 3 1) UNAUDITED UNAUDITED tINAUDITED AUDITED 1994 1993 1992 1991 Operating Revenues Water Sales and Services $578,257 $386,568 Sewer Services 618,196 623,684 Storm Drain Services 364,367 356,386 Other Fees/Charges 0 0 Total Operating Revenues $1,560,820 $1,366,638 Operating Expenses Cost of Sales and Services $905,070 $687,176 Administration 306,286 422,766 Total Operating Expenses $1,211,356 $1,109,942 Non-Operating Revenues & Expenses Interest Revenue $201,461 $227,807 Special Assessment Principal 20,166 50,382 Interest &Penalties on ULID's 10,622 21,983 Other Revenue 311 Amortization Expense (7,814) ( 6,631 Total Non-Operating Revenues & $224,746 $293,541 & Expenses Required Capital Contributions Net Revenue Available for Debt Service Annual Debt Service Annual Debt Service Coverage Junior Lien Debt Balance $349,964 $377,680 547,944 552,362 230,536 115,125 2,505 0 $1,130,959 $1,045,167 $497,273 $414,173 519,167 405,956 $1,016,440 $820,129 $165,723 $281,733 38,901 56,981 15,350 29,577 9,286 10,427 (533) (8,460) $228,727 $370,258 386,380 351,000 269,388 266,599 960,590 901,237 612,624 861,895 329,657 353,088 415,860 432,015 2.91 2.55 1.47 2.00 0 0 0 0 $630,933 $548,149 $196,764 $429,880 10 Source: City of Bainbridge Island Annum Financial Reports. On January 1, 1994, Water rates were increased 42% and Sewer rates were increased by 3.0%. At the same time, required system participation fees for water and sewer (accounted for as capital contributions) were increased from $2,808 for a single family residence or equivalent to $5,000 (a 78% increase). 16 The City. Director of Finance and Administrative Services maintains general supervision over financial transacnons of all City funds and supervises all accounting. The accounts of the City are organized by fund and account group, each of which is considered a separate accounting entity. Each fund has a separate set of self-balancing accounts that comprise its assets, liabilities, fund equity, revenues and expenditures or expenses, as appropriate. The City's resources are allocated to, and accounted for in, individual funds according to the purposes for which they are spent and the means by which spending activities are controlled. The full annual basis of accounting is employed for all proprietary funds. Labor Relations The City currently employs 108 full-time, part-time and temporary employees and approximately 85 % of the employees are represented by two bargaining units, both represented by District Lodge 160 of the International Association of Machinists and Aerospace Workers. Contracts are in place through 1996 for police and 1997 for all other represented employees. The City strives to be fair with all employees, consistent with all applicable state law, to ensure equity, and promote labor relation policies mutually beneficial to management and employees. Pension System Pensions for the City employees are provided through the Washington State Departmere of Retirement Systems by other the Public Employees Retirement System (PERS I and PERS II) or the Law Enforcement Officers and Fire Fighters (LiEOFF I & II). The City's contributions to all retirement systems are current. Insurance The City is a member of the Washington Cities Insurance Authority which pools insurance risk among 82 Washington cities. Liability coverage is self-funded and limits are layered with $1 million per loss in the primary layer, and an additional $4 million per loss in the excess layer (subject to a $16 million aggregate limit). GENERAL AND ECONOMIC City of Bainbridge Island The City of Bainbridge Island is approximately eight miles west of the City of Seattle across Elliott Bay and Puget Sound on Bainbridge Island. Bainbridge Island is primarily a residential community, which has a mix of suburban and rural neighborhoods. There are a few industrial concerns and some commercial areas as well. The extensive waterfront and view property on Bainbridge Island and its close proximity to Seattle have made it particularly appealing. Bainbridge Island, which is twelve miles long and four miles wide, is connected to the county mainland and the Olympia Peninsula by the Agate Pass Bridge. Seattle can be accessed via a State-operated ferry. The City of Winslow was the only incorporated area on Bainbridge Island until November 6, 1990, when the voters approved annexation of the unincorporated area of the Island. Effective February 28, 1991 the entire land area of Bainbridge Island became incorporated as the City of Winslow. On November 5, 1991, the voters of the incorporated City of Winslow agreed to change the name of the City to Bainbridge Island. Extensive waterfronts, view property and close proximity to Seattle has contributed to making Bainbridge Island a predominantly residential community with high property values. As a result of the short commute to downtown Seattle, a disproportionately large percentage of the population are financial and legal professionals who work in Seattle. Based on the 1990 Census data, half of the work-force commutes to jobs outside the community. Roughly one-third conm~ute by ferry to Seattle. 18 COMBINED TAX-SUPPORTED FUND REVENUES AND EXPENDITURES8 1995 BUDGET (Fiscal Year Ending December 31) Estimated Beginning Fund Balance Revenues: Taxes Fees & Service Charges Intergovernmental Fines & Forfeits Miscellaneous Investment Interest Total Revenues Operating Transfers In & Other Sources Sale of Bonds LID 13 Interfund Loan Repayment From Other Funds Total Non-Revenues Total Resources Expenditures: Salaries Benefits Supplies Professional Services Other Services and Charges Intergovernment Capital Debt Service Other Expenditures Total Expenditures Operating Transfers Out To Other Funds Total Non-Expenditures Budgeted Ending Fund Balance Total Uses $1,600,000 255,000 2.460.862 $2.838.933 $ 3,924,158 $ 4,621,093 598,100 2,088,567 109,500 327,858 121.432 $ 7,866,550 $ 4,315.862 $16.106.570 $ 3,088,152 927,212 254,147 1,284,032 1,035,020 539,489 3,542,760 46,689 466.03I $11,183,532 $ 2,838.933 $ 2,084,105 $16.106.570 s Source: City of Bainbridge Island 14 Kitsap County Kitsap County is located in western Washington on the western side of Puget Sound and covers 398 square miles of land, including the northern portion of Kitsap Peninsula and Bainbridge Island. The County has 211 miles of salt water shoreline: Hood Canal to the west, Admiralty Inlet to the north and Puget Sound to the east. The topography is mostly low, flat-topped rolling hills separated by valleys and bays, with altitudes from sea level to 600 feet above, except for Green and Gold mountains, which rise to 1,761 feet above sea level. The climate is moderate, with mild, wet winters and cool, dry summers. Mean annual precipitation ranges from 26 inches in the north to nearly 80 inches in the mountains. Kitsap County is divided into two distinct sections: the Kitsap Peninsula and Bainbridge Island. The Kitsap Peninsula is home to several naval installations. Much of this area is rural and includes the Hood Canal area. Hood Canal is a major recreation area and has attracted many seasonal residents who own homes on the shore. The region's natural resources include extensive shoreline, fish, shellfish, and timber. The economy of the County is based primarily on the U.S. Naval installations, which employ over 16,000 civilians and 15,700 military personnel. Popul~ion Kitsap County has been one of the fastest growing counties in the Puget Sound Region since 1970. The population of the County has increased 86.5% since 1970, nearly 90,000 new residents. The State population only grew 42.6% during the same time. Between 1980 and 1990, Kitsap County had an annual growth rate of 2.89% while the State was 1.77%. By the year 2012, the population is projected to be 269,700. The largest city in the County is Bremerton, with 39,610 residents. The other incorporated areas are Bainbridge Island (17,910), Port Orchard (6,240), and Poulsbo (5,756). Employment Kitsap County is defined as the Bremerton Metropolitan Statistical Area (MSA) for employment and unemployment statistics. In 1994, the labor force in the MSA numbered 89,500. The rate of unemployment was 6.0%, compared with 6.4% for Washington State. Non-manufacturing employment in the MSA for 1994 accounted for 97.2 % of wage and salary jobs, while manufacturing accounted for 2.8% of employment. Government (federal, state and local) continues to be the largest employer in Kitsap County accounting for 40.6% of employment. Transportation The peninsula is accessible by land from highways located at the southern end of Puget Sound. Interstate 5 and Highway 101 are connected by a six-mile leg near Olympia, and State Highway 3 branches off Highway 101 and heads north to Bremerton. A bridge across Puget Sound at south Tacoma carries State Highway 16 to Kitsap County. Washington State Ferries connect with Kitsap County at four points. Regular ferry service carries vehicles, foot passengers and cargo between Edmonds and Kingston, Seattle and Bainbridge Island, between Seattle and Bremenon, and between Fauntleroy, in west Seattle and Southworth on the Kitsap Peninsula. The Kitsap County Public Transportation Benefit Area Authority was established by the voters in 1982 to provide public transportation in the most heavily populated portions of the County. The system, called Kitsap Transit, provides four types of services: regular public transit, commuter bus transit, transportation of the elderly or handicapped, and carpool and vanpool services. Bremerton National Airport is the largest airport in the County. The airport can handle all general aviation aircraft and most transport and military planes. Charter passenger and air freight services are available at SeaTac Airport in the Seattle-Tacoma area, the ' international airport serving the major Puget Sound area. 2O TAX COLLECTION RECORD OF THE CITY3 (As of October 31, 1995) Collected Year 1995 1994 1993 1992 1991 1990 Taxable CoHe~ed Collected as of Assessed Tax Year of Levy October 31, 1995 Valuation Levy Amount Percent Amount Percent $1,858,795,349 $2,468,560 $1,633,842 66.19% $1,633,842 66.19% 1,812,935,103 2,408,772 1,643,088 68.21% 2,376.342 98.65% 1,757,272,419 2,334,446 2,228,650 95.47% 2,317,514 99.27% 1,686,414,209 2,240,642 2,142,470 95.62% 2,237,146 99.84% 204,993,587 478,053 455,439 95.27% 477,726 99.93% 153,396,054 414,054 396,584 95.75% 413.344 99.83% NOTE: Taxes are due and payable on April 30, of each year. At least one half of the tax amount due must be paid on or before April 30, or else the total amount becomes delinquent on May 1. The second half of the tax due is payable on or before October 31, becoming delinquent November 1. LEVY AMOUNTS AND RATES OF THE CITY4 LEVYAMOUNT LEVYRATE Year Regular EMS Bond Total Regular EMS Bond Total 1995 $2,468,560 0 0 $2,468,560 $1.328 0 0 $1.328 1994 2,407,659 0 0 2,407,659 1.328 0 0 1.328 1993 2,333,700 0 0 2,333,700 1.328 0 0 1,328 1992 2,239,633 0 0 2,239,633 1.328 0 0 1,328 1991 477,786 0 0 477,786 2.331 0 0 2.331 1990 413,873 0 16,050 429,973 2.698 0 .106 2.804 REPRESENTATIVE OVERLAPPING PROPERTY TAX RATES5 For City Residents (Rates in Dollars per $1,000 of Assessed Valuation for 1995 Collection) State Schools $3.5508 Kitsap County 1.2249 City of Bainbridge Island 1.3280 Bainbridge Island School District 4.6214 Kitsap County Rural Library 0.4595 Fire Protection District No. 2 1.0822 Bainbridge Island Park & Rec District 1.4012 Public Utility District 0,0940 Total $13.7620 Source: Kitsap County Treasurer's Office. Source: Kitsap County Assessor's Office. Source: Kitsap County Assessor'S Office. 12 The following contain economic indicators for the City of Bainbridge Island Kitsap County and King pOpULATION12 County. City of Kitsap King Bainbridge Island County County 1995 17,910 220,600 1,613,600 1994 17,510 213,210 1,599,500 1993 17,200 210,000 1,587,700 1992 16,850 205,600 1.564,486 1991 16,390 196,500 1,542,286 1990 census 15,846 189,731 1,507,305 1989 14,495 183,150 1,463,301 1988 14,253 179,365 1,428,605 1987 14,010 172,008 1,400,194 1986 13,768 167,429 1,376,073 1985 13,526 168,709 1,356,552 City of Bainbridge Island CITY OF BAINBRIDGE ISLAND NUMBER OF HOUSING UNITS BY STRUCTURE TyPEx3 Mobile Homes, Total One-Unit Two or More Trailers, & Housing Units Structures Unit Structures Special Units 1990 1995 1990 1995 1990 1995 1990 1995 1,596 7,805 665 6,049 776 1300 155 456 ASSESSED VALUATION~4 Year City of Bainbridge Island Kitsap County King County 1995 $1,858,795,349 $10,670,426,158 $120,828,946,549 1994 1,812,935,103 10,190,219,955 118,222,725,598 1993 1,757,272,419 9,236,571,898 117,625,404,009 1992 1,686,414,209 8,251,019,186 104,292,255,110 1991 204,993,587 6,661,235,888 102,212,020,082 1990 153,396,054 5,947,069,239 73,097,889,390 ~2 Source: City of Bainbridge Island population for Bainbridge Island from 1987-1991 is Winslow and formerly unincorporated area of Bainbridge Island. ~3 Source: Washington State Office of Financial Management. Effective February 28, 1991 the entire land area of Bainbridge Island was incorporated as the City of Winslow. On November 5, 1991, the name of the City was changed to Bainbridge Island. 14 Source: Kitsap County Assessor's Office (1991 and 1990 are Assessed Valuations prior to annexation) 22 CITY OF BAINBRIDGE ISLAND BONDED DEBT RATIOS 1995 Assessed Valuation City Population Ratio of: Net Direct Debt to Assessed Value Net Direct and Estimated Overlapping Debt to Assessed Value Per Capita: Net Direct Debt Net Direct and Estimated Overlapping Debt Assessed Valuation $1,858,795,349 17,910 0.23% 3.19% $238 $3,309.72 $103,785 MAJOR TAXPAYERS WITHIN THE CITY Name of Taxpayer Port Blakely Tree Farms Puget Sound Power & Light U.S. West Communications Country Club of Seattle Alexander & Baldwin, Inc. Crystal Springs Property Devel. North Washington Associates Harding Fletcher Company Grahame & Barbara Watson Madison Ave Retirement Center Winslow Cohousing Totem Storage Curtis F. Kingsbury Edgewood Villa Associates Totals Timber land Electric utility Telephone utility Country club Property management Property management Property management Manufacturer Retirement center Apartments Storage facility Marina condominiums Apartments Assessed Valuation2 $36,689,890 12,761,549 7,594,441 6,003,86I 5,893,000 3,599,660 3,551,080 3,000,000 2,857,070 2,631,000 2,420,880 2,384,000 2,001,000 2.000,000 $93,387,431 Percent of Citv AV 1.97% 0.69% 0.41% 0.32% 0.32% 0.19% 0.19% 0.16% 0.15% 0.14% 0.13% 0.13% 0.11% 0.11% 5.02 % 2 1994 Assessed Valuation for 1995 taxes. 10 BREMERTON PMSA (KITSAP COUNTY) AVERAGE ANNUAL RESIDENT CIVILIAN LABOR FORCE DATAis 1994 1993 1992 1991 1990 1989 1988 1987 Civilian Labor Force Total Employment Unemployment Unemployment as a percent of labor force 89,500 90,100 88,900 85,600 84,300 79,900 76.400 72.900 84,100 84,100 83,500 81,400 80,900 75,600 72.300 68,500 5,400 6,000 5,400 4,200 3,400 4,300 4,100 4,400 6.0% 6.7% 6.1% 4.9% 4.0% 5.4% 5.4% 6.0% BREMERTON PMSA (KITSAP COUNTY) NON-AGRICULTURAL WAGE AND SALARY WORKERSt9 1994 1993 1992 TOTAL WAGE AND SALARY WORKERS 67,300 67,900 67,800 TOTAL MANUFACTURING 1,900 1.800 l. 800 MINING &MISCELLANEOUS 600 700 500 CONSTRUCTION 3,100 3,300 3,300 TRANSPORTATION, COMMUNICATIONS &PUBLIC UTILITIES 1,800 1,800 1,800 WHOLESALE AND RETAIL TRADE 14,800 14,900 14,700 FINANCE. INSURANCE AND REAL ESTATE 2,700 2.700 2.500 SERVICES 15,000 14.900 13,500 GOVERNMENT 27,300 27,800 29.400 WORKERS IN LABOR-MANAGEMENT DISPUTES 45 0 0 1991 1990 66,800 65,000 1,700 1,900 500 500 3,100 3.200 1,700 1,700 14,300 13,700 2,400 2,300 14,400 13,400 28,700 28,400 0 0 Source: Washington State Employment Security Department Source: Washington State Employment Security Department 24 and park facilities - 2-1/2%. The combination of unlimited tax and limited tax general obligation debt for all purposes cannot exceed 7.5 % of the City's assessed valuation. The State statutory limits on City general obligation indebtedness described in this section are more restrictive than those contained in the State Constitution. Both the Constitutional and statutory debt limits may be exceeded if necessary to meet obligations made mandatory by State law or, if necessary, to maintain the corporate existence of the City. In computing total general obligation indebtedness, the following "assets" may be deducted .against the principal amount of indebtedness outstanding: (a) money and investments on deposit ~n general obligation bond retirement funds; (b) taxes (both current and delinquent) levied for the payment of general obligation indebtedness; and (c) delinquent (but not current) taxes due the general fund. In addition to limits on the total principal amount of general obligation indebtedness described in this section, the Constitution and statutes of the State impose other limitations on the City's levy of taxes upon real and personal property. (See section herein entitled "TAXING POWERS AND LIMITATIONS" .) PRESERVATION OF TAX EXEMPTION The City covenants that it will take all actions necessary to prevent interest on the Bonds from being included in gross income for federal income tax purposes, and it will neither take any action nor make or permit any use of proceeds of the Bonds or other funds of the City treated as proceeds of the Bonds at any time during the term of the Bonds which will cause interest on the Bonds to be included in gross income for federal income tax purposes. The City certifies that it has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that it is a bond issuer whose arbitrage certifications may not be relied upon. TAX EXEMPTION Exclusion from Gross Income In the opinion of Bond Counsel, assuming compliance by the City with applicable requirements of the Code, including arbitrage requirements under Section 148 of the Code, interest on the Bonds is excluded from gross income of registered owners for federal income tax purposes under existing federal law and is not an item of tax preference for purposes of the alternative minimum tax applicable to individuals. Corporate Alternative Minimum Tax While interest on the Bonds also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations, under Section 55 of the Code, tax-exempt interest, including interest on the Bonds, received by corporations is taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations (as defined for federal income tax purposes). Under the Code, alternative minimum taxable income of a corporation will be increased by 75 percent of the excess of the corporation's adjusted current earnings (including any tax-exempt interest) over the corporation's alternative minimum taxable income determined without regard to such increase. A corporation's alternative minimum taxable income, so computed, that is in excess of an exemption of $40,000, which exemption will be reduced (but not below zero) by 25 percent of the amount by which the corporation's alternative minimum taxable income exceeds $150,000, is then subject to a 20 percent minimum tax. Corporate Enviromnental Tax Section 59A of the Code imposes for taxable years beginning on or before January 1, 1996, an environmental tax of 0.12 percent ($1.20 per $1,000) on the amount of a corporation's alternative minimum taxable income (increased for certain book income and adjusted current earnings, including any tax-exempt interest) that exceeds $2,000,000. Tax on Certain Passive Investment Income of S Corporations Under Section 1375 of the Code, certain excess net passive investment income, including interest on the Bonds, received by an S corporation (a corporation treated as a partnership for most federal tax purposes) that has Subchapter C earnings and profits at the close of the taxable year may be subject to federal income taxation at the highest rate applicable to corporations if more than 25 percent of the gross receipts of such S corporation is passive investment income. Foreign Branch Profits Tax Interest on the Bonds may be subject to the foreign branch profits tax imposed by Section 884 of the Code when the Bonds are owned by, and effectively connected with a trade or business of, a United States branch of a foreign corporation. 26 ASSESSED VALUATION DETERMINATION In the State of Washington, the County Assessor (the "Assessor") determines the value of all real and personal property throughout the County (including the City), which is subject to ad valorem taxation. The Assessor' s duties and methods of determining value are prescribed and controlled by statute and by detailed regulations promulgated by the Department of Revenue of the State of Washington. For tax purposes the assessed value of property is set at 100% of its actual value. By state statute all property is subject to re-evaluation at least every four years. The property is listed by the Assessor on a tax roll at its current assessed value and the tax roll is filed in the Assessor' s office. The Assessor's determinations are subject to revision by the County Board of Equalization and, for certain property, subject to further revision by the State Board of Equalization. After all administrative procedures are completed, the taxing unit receives the Assessor's final certificate of assessed value of property within the taxing unit. TAX COLLECTION PROCEDURE Property taxes are levied in specific amounts, and the rate for all taxes levied for all taxing districts in the County (including the City) are determined, calculated and fixed by the Assessor based upon the assessed valuation of the property within the various taxing districts. The Assessor extends the taxes to be levied within each taxing district upon a tax roll which contains the total amount of taxes to be so levied and collected and assigns a tax account number to each tax lot. The tax roll is delivered to the Kitsap County Treasurer by December 15 of each year, and an abstract of the tax roll, showing the total amount of taxes collectible in each of the taxing districts for the year, is delivered to the Board of County Commissioners at the same time. All taxes are due and payable on the 30th of April of each year, but if the amount due from a taxpayer exceeds thirty dollars ($30.00), one-half may be paid then and the balance no later than October 31 of each year. The method of giving notice of payment of taxes due, accounting for the money collected, the division of the taxes among the various taxing districts, giving notice of delinquency, and collection procedure are all covered by detailed statutes. The lien for ad valorem property taxes which have been levied prior to the filing of federal tax liens is prior to such federal tax liens. In other respects, and subject to the possible "Homestead Exemption," the lien for delinquent property taxes is prior to all other liens or encumbrances of any kind on real or personal property subject to taxation. By law (Chapter 6.13 RCW) the taxing district may commence foreclosure of a tax lien on real property after three (3) years have passed since the first delinquency. Washington State's courts have not decided whether the Homestead Exemption gives the occupying homeowner a right to retain the first $30,000 proceeds of a forced sale of a family residence for delinquent general property taxes. INITIATIVE601 Initiative 601 was approved by the voters of the state on November 2, 1993. On July 1, 1995, Initiative 601 began limiting spending from the State's general fund by a "fiscal growth factor" based on the rate of inflation and the rate of population growth in the State. Increases in State taxes up to the spending limit must now be approved by a 2/3 vote in each house of the legislature. Increases in tax revenues above the spending limit must be approved by a 2/3 vote of the legislature and by a majority of voters at the next election. State fees may not be increased at a rate greater than the "fiscal growth factor" without prior legislative approval. Additionally, the legislature may not mandate new programs or increased levels of service in existing programs by local governments without appropriating enough money to reimburse such costs fully. Initiative 601 does not, by its terms, effect the authority of the City or other cities to authorize or issue general obligation bonds or to levy and collect taxes for the payment of general obligation bonds. The City does not believe that Initiative 601 will have any material effect on the finances of the City nor the ability of the City to pay debt service on the Bonds. CONFLICTS OF INTEREST Some or all of the fees of the Underwriter and Bond Counsel are contingent upon the issuance and sale of the Bonds. Furthermore, Bond Counsel from time to time serves as counsel to the Underwriter with respect to issuers other than the City and transactions other than the issuance of the Bonds. None of the Councilmembers or other officials of the City have an interest in the issuance of the Bonds that are prohibited by applicable law. RATING The Bonds have been rated "A" by Moody's Investors Service.. The rating reflects only the view of the rating agency and an explanation of the significance of the rating may be obtained from Moody's Investors Service. There is no assurance that the rating will be retained for any given period of time or that the rating will not be revised downward, suspended or withdrawn entirely by the rating agency if, in their judgment, circumstances so warrant. Any such downward revision, suspension or withdrawal of the rating will be likely to have an adverse effect on the market price of the Bonds. UNDERWRITING The Bonds are being purchased by the Underwriter, Pacific Crest Securities, Inc. The Underwriter has agreed to purchase the Bonds at an underwriting discount of $ from the initial offering prices reflected on the cover page. The Purchase Contract for the Bonds provides that the Underwriter will purchase all the Bonds, if any are purchased. The public offering prices for the Bonds set forth on the cover page hereof may be changed after the initial offering by the Underwriter. The City has agreed to indemnify the Underwriter against certain liabilities. CONTINUING DISCLOSURE UNDERTAKING Basic Undertaking to Provide Annual Financial Information and Notice of Material Events. Because it will have outstanding less than $10,000,000 of obligations after the issuance of the Bonds, the City is currently exempt from the requirements of United States Securities and Exchange Commission (SEC) Rule 15c2-12(b)(5) (the "Rule"), as applicable to a participating underwriter for the Bonds, however, the City will undertake (the "Undertaking") for the benefit of holders of the Bonds to provide or cause to be provided, either directly or through a designated agent, to each nationally recognized municipal securities information repository designated by the SEC in accordance with the Rule CNRMSIR") and to a state information depository, if any, established in the state of Washington (the "SID") annual financial information and operating data of the type included in this Official Statement as generally described below ("annual financial information"): and to each NRMSIR or the Municipal Securities Rulemaking Board CMSRB"), and to the SID, timely notice of the occurrence of any of the following events with respect to the Bonds, if material: (i) principal and interest payment delinquencies; (ii) non-payment related defaults: (iii) unscheduled draws on debt service reserves reflecting financial difficulties; (iv) unscheduled draws on credit enhancements reflecting financial difficulties: (v) substitution of credit or liquidity providers, or their failure to perform; (vi) adverse tax opinions or events affecting the tax-exempt status of the Bonds; (vii) modifications to rights of holders of the Bonds; (viii) Bond calls (other than scheduled mandatory redemptions of Term Bonds); (xi) defeasances; (x) release, substitution, or sale of property securing repayment of the Bonds; and (xi) rating changes. The City also will provide to each NRMSIR or to the MSRB, and to the SID, timely notice of a failure by the City to provide required annual financial information on or before the date specified below. 28 VERIFICATION OF MATHEMATICAL COMPUTATIONS Ernst & Young LLP, a firm of independe. nt public accountants, will deliver to the City its attestation report indicating that it has examined, ~n accordance with standards established by the American Institute of Certified Public Accountants, the information and assertions provided by the City and its representative. Included in the scope of its examination will be a verification of the mathematical accuracy of (a) the mathematical computation of the adequacy of the cash and the maturing principal of and interest on the Acquired Obligations deposited in the Escrow Fund to pay when due, maturing principal of, principal redemption of and interest on the Refunded Bonds; and (b) the mathematical computations supporting the conclusions of Bond Counsel that the Bonds are not "arbitrage bonds" under the Code and the regulations promulgated thereunder. ADMINISTRATION OF THE REFUNDING PLAN The Escrow Agent is authorized and directed to purchase the Acquired Obligations (or substitute obligations) and to make the payments required to be made by the Refunding Plan from the Acquired Obligations (or substitute obligations) and money deposited with the Escrow Agent pursuant to the Ordinance. All Acquired Obligations (or substitute obligations) and the money deposited with the Escrow Agent and any income therefrom shall be held irrevocably, invested and applied in accordance with the provisions of the Ordinance, Chapter 39.53 RCW and other applicable statutes of the State of Washington, and the Escrow Agreement. All necessary and proper fees, compensation and expenses of the Escrow Agent for the Bonds and all other costs incidental to establishing the escrow to accomplish the refunding of the outstanding Refunded Bonds and costs related to the issuance and delivery of the Bonds, including bond printing, rating service fees, verification fees, bond counsel's fees and other related expenses, shall be paid out of the proceeds of the Bonds. Authorization for Escrow Agreement In order to carry out the Refunding Plan provided for by the Ordinance, the Mayor or the Director of Finance and Administrative Services is authorized and directed to execute and deliver to the Escrow Agent, an Escrow Agreement setting forth the duties, obligations and responsibilities of the Escrow Agent in connection with the payment, redemption and retirement of the Refunded Bonds, as provided in the Ordinance and stating that the provisions for payment of the fees, compensation and expenses of such Escrow Agent set forth therein are satisfactory to the Escrow Agent. Prior to executing the Escrow Agreement, the Director of Finance and Administrative Services is authorized to make sure such changes therein which do not change the substance and purpose thereof or which assure that the escrow provided therein and the Bonds are in compliance with the requirements of federal law governing the exclusion of interest on the Bonds from gross income for federal income tax purposes. All money and the Acquired Obligations on deposit with the Escrow Agent, including interest to be earned thereon, are pledged solely and irrevocably for the benefit of the holders of the Refunded Bonds and are not available for payment of the Bonds. The advance refunding will defease the Refunded Bonds, and they will no longer be considered outstanding obligations of the City. The Escrow Agent First Interstate Bank of Washington, N.A., is serving as the Escrow Agent for the purpose of managing the cash and investments which comprise the Acquired Obligations for the Refunded Bonds, which will pay the principal of, interest on and redemption premium, if any, on the Refunded Bonds, as the same become due and payable. CUSIP NUMBERS It is anticipated that CUSIP identification numbers will be printed on the Bonds, but neither the failure to print such numbers on any Bonds or any error with respect thereto shall constitute cause for a failure or refusal by the purchaser hereof to accept delivery of and pay for said Bonds in accordance with the terms of the purchase contract. All expenses in relation to the printing of CUSIP numbers on said Bonds shall be paid by the City; provided, however, that the CUSIP Service Bureau charge for the assignment of said numbers shall be the responsibility of and shall be paid for by said purchaser. MISCELLANEOUS The descriptions of the Ordinance and other documents are brief summaries of certain provisions thereof. Such summaries do not purport to be complete, and reference is made to such documents and contracts, copies of which are on file with the City, for full and complete statements of their provisions. All estimates and projections included in this Preliminary Official Statement, whether or not so stated, are not to be construed as representations that the same will be realized. Section headings, tables headings and captions are included for convenience only and should not be construed as modifying the text of this Preliminary Official Statement. The City's financial statements for fiscal years 1990 and 1991 have been audited by the Washington State Auditor's Office. Information concerning the City contained in this Preliminary Official Statement has been furnished by the City. All projections and other statements in this Preliminary Official Statement involving matters of opinion, whether or not expressly so stated, are intended as such and not as representations of fact. This Preliminary Official Statement is not to be construed as a contract or agreement between the City and the purchasers or holders of any of the Bonds. The execution and delivery of this Preliminary Official Statement has been duly authorized by the City. Dated: , 1995 THE CITY OF BAINBRIDGE ISLAND, WASHINGTON By: \s\ Director of Finance and Administrative Services 30 Notice of Redemption Notice of any such early redemption of the Bonds will be given not less than 30 nor more than 60 days prior to the date fixed for redemption, by first-class mail, postage prepaid, to the Owners of each Bond to be redeemed at the address appearing on the Bond Register at the time the Bond Regist. rar .prepares the notice. The requirements of notification will be deemed to be complied with when notme ts mailed as provided by the Bond Ordinance, whether or not it is actually received by the Owner of any Bond. In addition, such redemption notice shall be mailed within the same period, postage prepaid, to such other persons, including registered securities depositories, and with such additional information as the City Director of Finance and Administrative Services shall deem appropriate, but such mailings shall not be a condition precedent to the redemption of such Bonds. If such notice shall have been given and the City shall have set aside, on the date fixed for redemption, sufficient money for the payment of all Bonds called for redemption, the Bonds so called shall cease to accrue interest after such redemption date, and all such Bonds shall be deemed not to be outstanding hereunder for any purposes, except that the Owners thereof shall be entitled to receive payment of the redemption price and accrued interest to the redemption date from the money set aside for such purpose. If any Bond is not paid upon proper presentment at its maturity or earlier redemption, the City shall be obligated to pay interest at the same rate for such Bond until such Bond, both principal and interest, is paid in full. Purchase of the Bonds by the City The City further reserves the right and option to purchase any or all of the Bonds in the open market at any time at any price acceptable to the City plus accrued interest to the date of purchase when the Bonds are available for purchase. All Bonds so purchased or redeemed shall be canceled. Registrar, Paying Agent and Transfer Agent Both principal of and interest on the Bonds are payable in lawful money of the United States of America. Principal of the Bonds will be paid by the Fiscal Agency of the State of Washington (the "Registrar," the "Paying Agent" and the "Transfer Agent") upon presentation and surrender of the Bonds, at maturity or earlier redemption, at either of the principal corporate trust offices of the Registrar in Seattle, Washington or New York, New York. Interest on the Bonds will be paid by check or draft of the Paying Agent mailed on the interest payment date to the registered owners at the addresses appearing on the Bond Register on the fifteenth day of the month preceding the interest payment date. Currently, the Fiscal Agency of the State of Washington is First Interstate Bank of Washington, N.A., Seattle, Washington, and The Bank of New York, New York, New York. Transferability The Bonds may be transferred only on the Bond Register maintained by the Registrar for that purpose and only if endorsed in writing in the manner provided thereon and surrendered by the Registered Owner or Registered Owner's nominee to the Registrar for re-registration upon the Bond Register and on the Registration Certificate on the Bonds. Such transfer shall be without cost to the Registered Owner or transferee. The City and the Registrar may deem the person in whose name each Bond is registered to be the absolute owner thereof for the purposes of securing payment of the principal of and interest on such Bond and for any and all other purposes whatsoever. Upon surrender thereof to the Registrar, the Bonds are interchangeable for Bonds in any authorized denomination of an equal aggregate principal amount and of the same interest rate and maturity. The Registrar shall not be obligated to exchange or transfer any Bond during the fifteen days preceding any principal payment or redemption date. FOSTER PEPPER & SHEFELMAN [FORM OF APPROVING LEGAL OPINION] City of Bainbridge Island, Washington Re: City of Bainbridge Island, Washington, $2,455,000 Limited Tax General Obligation Refunding Bonds, 1995 We have examined a certified transcript of proceedings had by the City of Balnbridge Island, Washington (the "City"), relating to its issuance of the above-referenced bonds (the "Bonds") and also have examined an executed and authenticated Bond or a facsimile thereof. The Bonds are issued pursuant to law for the purpose of providing the funds required to refund the City's outstanding Water and Sewer Revenue Bonds, 1989, and to pay the costs of issuance and sale of the Bonds, all as set forth in the Ordinance No. (the "Bond Ordinance") and under and in accordance with the Constitution and laws of the State of Washington and ordinances of the City. The Bonds are fully registered; are in the denomination of $5,000 or any integral multiple thereof within a single maturity; are numbered separately; are dated December 1, 1995; and bear interest at the rates set forth below, payable semiannually on each May 1 and November 1, commencing May 1, 1996, to the maturity or earlier redemption of the Bonds. The Bonds are payable at the principal office of either of the fiscal agencies of the State of Washington in Seattle, Washington, or New York, New York (collectively, the "Bond Registrar"). The Bonds mature on November 1 in years and amounts and bear interest at the rates per annum as follows: Maturity Interest Years Amounts Rates 1996 $ 35,000 1997 20,000 1998 35,000 1999 145,000 2000 180,000 ANCHORAGE, ALASKA BELLEVUE, WASHINGTON PORTLAND, OREGON SEATTLE, WASHINGTON TABLE OF CONTENTS Page Introduction ........................................................................................................1 Description of the Bonds ........................................................................................1 The Advance Refunding Plan ...................................................................................3 Verification of Mathematical Calculations ...................................................................4 Administration of Refunding Plan .............................................................................4 Purpose ..............................................................................................................5 Sources and Uses of Funds ......................................................................................5 Debt Payment Record ............................................................................................5 Future Financing ..................................................................................................5 Security .............................................................................................................5 Litigation ...........................................................................................................5 Assessed Valuation Determination .............................................................................6 Tax Collection Procedure .......................................................................................6 Initiative 601 .......................................................................................................6 Authorization of Debt ............................................................................................7 General Obligation Indebtedness ...............................................................................7 Limits on Amount of General Obligation Indebtedness ....................................................7 Computation of Statutory Debt Limitations ..................................................................9 Net Direct and Overlapping General Obligation Debt .....................................................9 Bonded Debt Ratios ...............................................................................................10 Major Taxpayers Within the City ..............................................................................10 Taxing Powers and Limitations .................................................................................10 Tax Collection Record of the City .............................................................................11 Levy Amounts and Rates of the City ..........................................................................12 Representative City Property Tax Rates ......................................................................12 Comparative Statement of Combined Tax Supported Fund Revenues and Expenditures ............ 12 Combined Tax Supported Fund Revenues and Expenditures, 1995 Budget ...........................13 Schedule of General Obligation Bonded Indebtedness of the City .......................................14 Historical Combined Waterworks Utility Operations ......................................................15 The City .............................................................................................................16 General and Economic ...........................................................................................17 Preservation of Tax Exemption .................................................................................18 Tax Exemption ....................................................................................................26 Certain Other Federal Tax Consequences ....................................................................26 Approval of Bond Counsel ......................................................................................27 Conflicts of Interest ...............................................................................................27 Rating ...............................................................................................................28 Underwriting .......................................................................................................28 Continuing Disclosure Undertaking ...........................................................................28 CUSIP Numbers ...................................................................................................30 .30 Miscellaneous ..................................................................................................... Form of Counsel Opinion ..........................................................................Appendix A iv City of Bainbridge Island, Washington Page 3 certain periods prescribed by the Code. There is an exception to this rebate requirement available to a governmental unit with general taxing powers in connection with the issuance of obligations other than "private activity bonds" as defined in the Code, if the governmental unit, together with all subordinate governmental units, does not reasonably anticipate issuing more than $5,000,000 of tax-exempt obligations (other than private activity bonds and other obligations not required to be included in such calculation) during the calendar year in which the obligations are issued. The City has certified in the Bond Ordinance that it is an issuer which qualifies for this arbitrage rebate exception in connection with the issuance of the Bonds. As of the date of initial delivery of the Bonds to the purchaser thereof and full payment therefor, it is our opinion that (1) the City is a duly organized and legally existing non-chartered code city under the laws of the State of Washington; (2) the Bonds are issued in full compliance with the provisions of the Constitution and laws of the State of Washington and the ordinances of the City relating thereto; (3) the Bonds constitute valid general obligations of the City payable from annual ad valorem taxes to be levied within the constitutional and statutory tax limitations provided by law without a vote of the electors of the City on all of the taxable property within the City, together with Gross Revenue of the Waterworks Utility, except only to the extent that enforcement of payment may be limited by bankruptcy, insolvency or other laws affecting creditors' rights and principles of equity if equitable remedies are sought; and (4) assuming compliance by the City after the date of issuance of the Bonds with applicable requirements of the Code, including arbitrage requirements, under existing federal law the interest on the Bonds is excluded from gross income of the registered owners for federal income tax purposes and is not an item of tax preference for purposes of the alternative minimum tax applicable to individuals; however, while interest on the Bonds also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations, interest on the Bonds received by corporations is to be taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations, interest on the Bonds received by certain corporations may be subject to an environmental tax, interest on the Bonds received by certain S corporations may be subject to tax, and interest on the Bonds received by foreign corporations with United States branches may be subject to a foreign branch profits tax. We express no opinion regarding any other federal tax consequences of receipt of interest on the Bonds. Respectfully submitted, 0211934.01 REPRESENTATIONS Neither the City nor the Underwriters has authorized any dealer, broker, salesperson or other persons to given any information or make any representations other than those made in this Official Statement, and, if given or made, such other information or representations must not be relied upon as having been authorized by the City or the Underwriter. This Official Statement does not constitute an offer to sell, or the solicitation of an offer to buy, nor shall there be any sale of the Bonds by any person in any jurisdiction in which it is unlawful for such person to make such offer, solicitation or sale. The information contained in this Official Statement has been obtained from City Officials and other sources believed to be reliable. Neither a representation, warranty nor guarantee is made by the Underwriter as to the accuracy or completeness of any information in this Official Statement and nothing contained in this Official Statement is or shall be relief upon as a promise or representation by the Underwriter. The delivery of this Official Statement does not imply that the information contained herein is correct as of any time subsequent to the date of the Official Statement as shown on the cover page. Disclosure Statement The City will deliver to the Underwriter at the time of delivery of the Bonds a signed statement substantially to the effect that this Official Statement, as of its date and as of the date of the Bonds, neither contains any untrue statement of a material fact nor omits to state any material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading in any material respect and that there has not been any material adverse change in the normal operations or financial condition of the City nor, to the best of the City's knowledge, in the general economy of the City since the date of the Official Statement. Securities Act of 1933 The Bonds have not been registered under the Securities Act of 1933, as amended, in reliance upon specific exemptions contained in such act. The registration or qualification of the Bonds in accordance with applicable provisions of securities laws of the state in which the Bonds have been registered or qualified and the exemption from registration or qualification in other states cannot be regarded as a recommendation thereof. Neither these states nor any of their agencies have passed upon the merits of the Bonds nor the accuracy or completeness of this Official Statement. Any representation to the contrary may be a criminal offense. Secondary Market It has been the practice of the Underwriter to maintain a secondary market in municipal bonds which it sells. The Underwriter intends to engage in secondary market trading of the Bonds, subject to applicable securities laws. The Underwriter, however, is neither obligated to engage in secondary trading nor to repurchase any of the Bonds at the request of the registered owners thereof and no assurance can be given that a secondary market for the Bonds will be available. bz connection with the offering of the Bonds, the Underwriter may over-allot or effect transactions that stabilize or maintain the market price of the Bonds at a level above that which might otherwise prevail in the open market. Such stabilizing, if commenced, may be discontitzued at anytime.