Loading...
July1989 Bonds SUTHERLANP, ASBILL & BRENNAN 3100 FIRST ATLANTA TOWER ATLA"i"lTA, GEORGIA 30383-3001 (404) sse 8700 1275 PENNSYLVANIA AVENUE. N.W. WASHINGTON, D. C. 20004 2404 (2021 383-0100 lO,l989 Max Bacon 3008l Mayor Bacon: ion in the minute book of the City as filed with the IRS, together with Very truly yours, H ES <5< MILLER UNSELLORS AT LAVV FOU RTH ..FLOOR !156 FIFTEENTH N.W. VVASHINGTON. C. 20005-1704 TELEPHONE (202l 955-9500 AUTOMATIC TELECOP1ER {2QZl 955-9594 ..J. MARVIN HAYNES 1949-!976 ARTHUR H. ADAMS 1958-1966 WRITER'S DIRECT (202) June 28, 1989 955-95l8 and Council , Georgia , Asbill & Brennan Georgia Inc. Water $3,510,000 Smyrna (Georgia) age Revenue Refunding Bonds al Tax Counsel with respect to the of Smyrna, Georgia (the "Issuer") of (the "Bonds"). We have given of the Bonds, and to the expected including proceeds of the Bonds) to prior bonds (the "Prior Bonds") of ance with the restrictions imposed by (d)(4) of the Internal Revenue Code ), and applicable regulations, court tions of the Internal Revenue Service have examined originals, or copies to our satisfaction, of (i) a Issuer, of even date, setting forth ions with respect to the Bonds; (ii) rland, Asbill & Brennan, Bond rized and valid obligations of the and local laws; (iii) an ordinance -2- "Ord.inance"), authorizing a covenant of the Issuer ions of Section 148 of the Code; as of June 28, 1989 which refinanced on July 1, 1995; and icates as we have deemed inion rendered herein. our attention that would make representations or expectations made ate. , and assuming continued compliance ained in the Ordinance, we are of the not "arbitrage bonds" within the Code and (2) the Bonds are not (4) of Section l49(d) of the Code. the limited puxpose of rendering 148, 149(d)(3) a.nd 149(d)(4) of limited solely such matters. We any other legal questions with Bonds or of the ab~lity of the Issuer service thereon. No opinion is other provisions of law that might of the interest on the Bonds from tax purposes. Very truly yours, HAYNES & MILLER MILLER RS AT LAW FLOOR STREET, N.W. GTON, D. C. 005-1704 TELEPHONE (202) 955--9500 AUTOMATIC TELECOP1ER (202j 955-9594- J. MARVIN HAYNES 1949-1976 ARTHUR H. ADAMS 1958-1966 JR. WRiTER'S DIRECT (202) OF Ge::Cl"IQiAB,AR ONL.Y June 28, 1989 955-9518 Mayor and Council Smyrna, Georgia Water $3,510,000 Smyrna (Georgia) Revenue Refunding Bonds letter is to explain the general legal the Internal Revenue Code of 1986, as to give you guidance in complying ained in the ordinance (the na, Georgia (the "Issuer") with financing. Capitalized terms not the meanings set forth in the which must be satisfied in order water and Sewerage Revenue Refunding ") to continueta enjoy their ing the rebate requirement and the of the Water and Sewerage Revenue Bonds") being refinanced. e to the Internal Revenue Service of the tota~ amount earned from over the amount that would have such "groS$proceeds" if their "Bond Yield") plus any investment excess (collectively referred to "Gross Proceeds" is a fairly udes original investments of bond proceeds, amounts pledged to the service funds. However, for a number ignore the investmen't of certain of s simplify your rebate calculations. -2- The specific funds of the Issuer which may include "gross proceeds" are discussed below: 1. The Escrow Fund is funded in part from proceeds of the Bonds and is technically sUbject to inclusion in the rebate calculation. However, since computations have already been made confirming that the Escrow Fund does not yield more than 6.977191%, you should be able to ignore the Escrow Fund in the rebate calculation. 2. The Debt Service Account within the Sinking Fund is a debt service fund for the payment of current debt service on the Bonds and is generally designed to be cleared of all funds once each year. Since the Bonds are fixed rate bonds with an average maturity of more than five years and your bond counsel has determined that they are not "private activity bonds", the Code requires you to ignore this fund for rebate purposes. 3. The Debt Service Reserve Account within the Sinking Fund is funded with Issuer revenues and is entirely "gross proceeds" subject to rebate. 4. The Other Issuer Funds (including the Renewal and Extension Fund) should be excluded from the rebate calculation since they are generally not expected to be used to pay debt service on the Bonds. However, the IRS has not yet enacted regulations under Section 148 of the Code and there is no clear guidance on this point. Thus, subsequent regulations may force some Issuer funds into the category of "gross proceeds". The bonds may qualify for the $5 million dollar small issue exemption to the Rebate requirement. If the Issuer (and all of its subordinate entities) has issued less than $5 million of tax-exempt bonds (other than private activity bonds) including the Bonds, during the calendar year 1989, it may not be necessary to comply with any of the Rebate requirements of Section 148 of the Code, for the entire term of the Bonds. Technical corrections to the 1986 Code enacted by Congress impose certain additional limits to this exception in the context of Refunding Bonds. Generally, these additional restrictions to the general $5 million exception prohibit use of this exception if a refunding extends the average maturity of bonds or the prior issue itself exceeded the $5 million limit. We have determined that the average maturity of the Bonds used to refund the 1984 Bonds does not exceed the remaining average maturity of the 1984 Bonds. You should consult your counsel to determine if the Issuer qualifies with regard to the other requirements of the $5 million exception. Unless the Issuer qualifies for the general exception described above, the following steps should be undertaken to assure compliance with the rebate requirements. -3- Detailed records should be maintained of the investment activity for all funds and accounts, in order to be able to trace the investment of all funds until spent. These records should include full descriptions of all investments purchased and identify the purchase prices and sale prices for such investment, and receipts therefrom. Documentation with respect to the calculation of the rebate should be retained by the Issuer until six years after the retirement of the last obligation of the Bonds and copies of each such determination of the Rebate Amount with respect to the Bonds should be made available to the Issuer, the Trustee and Bond Counsel upon reasonable request. You are required to calculate the amount of rebate due every five years. The first installment computation date is the last day of the fifth bond year. You have a certain amount of flexibility in choosing the exact calender day of the year which is the end of a "bond year". If January 1, 1990 is selected as the end of the first bond year, the first installment computation date would be January 1, 1994. The Issuer must make installment payments to the United States in an amount equal to 90% of the Rebate Amount with respect to the Bonds within 60 days of a rebate computation date. The last installment payment shall be made no later than 60 days after the date on which the last Obligation of the Bonds is paid and should be in an amount sufficient to pay the remaining balance of the Rebate Amount with respect to the Bonds. Each payment of the Rebate Amount should be (a) filed with the Internal Revenue Service Center, Philadelphia, Pennsylvania 19255, (unless subsequent regulations designate a different location), (b) accompanied by a copy of the IRS Form 8038-G filed with the Internal Revenue Service at the time of the issuance of the Bonds, and (c) accompanied by a statement summarizing the determination by the Issuer of the Rebate Amount being paid. With respect to the requirement concerning the redemption of the bonds being refinanced, those bonds which were originally issued prior to January 1, 1986, must be called on the earliest redemption date in which the premium is 3% or less. In this instance, the bonds being refinanced must be redeemed on July 1, 1995 with respect to the 1984 Bonds maturing July 1, 1996 and thereafter. The Escrow Deposit Agreement directs the Escrow Agent to effect this call. Failure to comply with the above described arbitrage limitations of Section 148 and Section 149(d)(3) of the Code may result in the Bonds becoming taxable or, you may be able to correct a violation of the rebate requirement by late payment of the rebate due, plus a penalty of 50 percent of the rebate, plus interest thereon. -4- interpretations of Sections an the Code and the limited this time~ The IRS has ngthecomputation method to However, these regulations revisions. The IRS has not ng the rebate provisions regu ions are not expected to rstand the IRS is currently interpretive rules dealing with the such as identification of "gross as edged proceeds and transferred calculation of the Rebate your first rebate calculation, you should consult your counsel to more current interpretation of Section Very truly yours, HAYNES & MILLER By This Escrow 'Agreement") by a times referred k, At ta, Geo e "Escr Agent"). it Agreement (hereinafter referred to as een City of Smyrna (hereinafter "City") and the Trust Company inafter sometimes referred to as WIT N E SSE T H: WHEREAS, the City of Smyrna has issued and delivered $4,375,000 pri amount of City of Smyrna Water and en , Series 1984, dated October 1, 1984, some s referred to as the "Series 1984 Bonds"), lly registered form without coupons, in the denomination or any integral multiple thereof, bearing interest rate per annum set forth below opposite each y, all interest payable January 1, 1985 and reafter on the 1st days of January and July in the principal maturing on the 1st day of July, in amounts, as follows: Year Rate Year Amount Rate 1985 7.00% 1994 $ 180,000 9.20% 1986 $ 7.25% 1995 $ 195,000 9.40% 1987 7.50% 1996 $ 215,000 9.60% 1 $ 7.75% 1997 $ 235,000 9.75% 1 $ 8.00% 1998 $ 255,000 9.90% 1990 $ 8.25% 1999 $ 285,000 10.00% 1991 $140,000 8.50% 2000 $ 310,000 10.10% 1992 $150,000 8.75% 2004 $1,600,000 10.375% 1993 $165,000 9.00% hereof, being bo~ds maturing in t6e'y~ars ive, and in the year 2004; and rincipal amount 9 to 2000, inc WHEREAS, it has been determined that the City should fund that portion of said Series 1984 Bonds maturing on and ter , 1996 a ow outstanding in the principal amount $2, 0 (herei er referred co as "Refunded Bonds") on rliest practicable call date it is necessary that proper ion for the refunding of said Refunded Bonds be made with gent Bank for said Series 1984 Bonds; and the City pursuant to an ordinance adopted by the ncil of the City of Smyrna on May 25, 1989 has n all necessary and proper steps to provide for the deposit with the Trust y Bank, Atlanta, Georgia, the Paying Agent said Series ds, as Escrow Agent, moneys derived sale 0 ter and Sewerage Revenue Refunding ies ich are to be held, supervised, ~ned and a tered by the Escrow Agent under che cerms conditions of is Agreement; and WHEREA the City will deposit with the Escrow Agent, Itaneous with the issuance and delivery of the Series the sum of 47,303.75 derived from moneys t account designated as "Debt Service i hin the special fund designated as Wat Sewerage System Sinking Fund" now Bank of Cobb County, N.A., Smyrna, ustodian, which moneys are to be by the Escrow Agent under the terms and Agreement; and WHEREAS, enter into th the use and a Escrow Agent. it is now necessary and desirable for the City to eement with the Escrow Agent to provide for tion of the moneys so deposited with said NOW, undertaki the City rgia, e icers: in consideration of the premises and the fter set forth, it is agreed by and between and the Trust Company Bank, Atlanta, g by and through its duly authorized SECTION 1. The Escrow Agent acknowledges receipt of: (a) rand reinaf things, p Bonds mat the aggre rtified copy of the ordinance adopted by the 1 of the City of Smyrna on May 25, 1989 rred to as the "Ordinance"), among other for the refunding of all of said Series 1984 n and after July 1, 1996 and now outstanding in principal amount of $2,900,000; and ( b ) The the sale of t $147,303.75 from received, ,386,000 from the proceeds derived from Series 1989 Bonds and the sum of City. Of said aggregate funds so ( i ) simultaneou $3,383,000 a Treasury ObI (hereinafter interest fro e ea 1, 1990 January maturing in the of $3,383,000 was applied the receipt thereof to acquire principal amount of United States -State and Local Government Series d to as "Direct Obligations"), bearing the rate per annum set forth below al maturity, all interest payable semi-annually thereafter on the 1st and July in each year, and the principal amounts and on the dates, as follows: 1/ 0 7/1/90 1/1/91 7/1/91 1/1/92 7/1/92 Rate 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% Date 1/1/93 7/1/93 1/1/94 7/1/94 1/1/95 7/1/95 Amount $ 35,600 $ 35,600 $ 35,500 $ 35,600 $ 35,600 $2,993,500 Rate 0.00% 0.00% 0.00% 0.00% 0.00% 7.465% $35,600 $35,500 -2- All of said Direct Obligations are now on deposit with and are g held by the United States Federal Reserve Bank excl ely for the purposes of this Agreement. (ii) The sum of $147,303.75 shall be held as an initial cash balance. (iii) The sum of $3,000 has been paid to the Trust Company Bank, anta, Georgia, as full and complete payment of al ees, charges and expenses incurred or to be incurred as Escrow Agent for said Refunded Bonds. Section 2. The parties hereto acknowledge the creation and the establishment by the Escrow Agent of a special and irrevocable trust fund designated as the "City of Smyrna Water and Sewerage Re e Bond Escrow Fund" (hereinafter referred to as the "Escrow ) and the Escrow Agent acknowledges, agrees and certifies that all of the Direct Obligations and cash in the amount of $147,303.75 for which it acknowledged receipt in Section 1 above are fully credited to the Escrow Fund. The cipal of and income derived from the Direct Obligations and cash are irrevocably pledged to the payment of the efunded Bonds a owners of the Refunded Bonds are hereby granted and shal an express lien on the cash and the p 1 of and derived from all the Direct Obligations c ted to the Escrow Fund until used and applied in accordance with the terms of this Agreement. Section 3. The parties hereto each acknowledge, agree and certify that the principal of and income derived from the Direct ObI tions referred to in Section 1 as and when due and ble received the Escrow Agent will provide moneys, , toegther with id initial cash balance, in the aggregate will be sufficient to acquire all of the Refunded nds by making the following payments, on the dates and in the amounts, as follows: Principal Interest Premium Total 19 9 -0- $147,303.75 -0- $ 147,303.75 1, 1990 -0- $147,303.75 -0- $ 147,303.75 1990 -0- $147,303.75 -0- $ 147,303.75 1, 1991 -0- $147,303.75 -0- $ 147,303.75 1991 -0- $147,303.75 -0- $ 147,303.75 l, 1992 -0- $l47,303.75 -0- $ 147,303.75 1992 -0- $147,303.75 -0- $ 147,303.75 1, 1993 -0- $147,303.75 -0- $ 147,303.75 1993 -0- $147,303.75 -0- $ l47,303.75 1, 1994 -0- $l47,303.75 -0- $ l47,303.75 1994 -0- $147,303.75 -0- $ 147,303.75 l, 1995 -0- $l47,303.75 -0- $ 147,303.75 July 1995 $2,900,000 $147,303.75 $58,000 $3,105,303.75 -3- Section 4. The Escrow Agent agrees to apply the initial ash balance and Direct Obligations so deposited in or credited to the Escrow Fund and the income derived from the Direct Obligations in accordance with the provisions hereof. The Escrow Agent sha ect the principal of and interest on said Direct Obli ons as same become due and payable and it shall have no power to make substitution of the Direct Obligations cr d to the Escrow Fund. All moneys and the Direct obligat the income derived from the Direct Obligations he uant to the terms and conditions of this eement sha subject to the lien herein granted in favor the owners of the Refunded Bonds and shall be held for the security of such owners until disbursed in accordance with this Agreement and the Ordinance. Section 5. The Escrow Agent agrees that it shall on July 1, 1989 and on h January 1 and July 1 thereafter, withdraw from th w Fund and transfer in immediately available funds t t Company Bank, Atlanta, Georgia, as payi nt for funded Bonds if such date is July 1, a sum cient to pay the principal, prem , if any, and the inte d payable on the Refunded s on July 1, and if such date uary 1, a sum sufficient to pay the interest due and the Refunded Bonds on January 1; and such tr f tinue and recontinue until provision shall ha b for the payment in full of all of the Refunde set forth in Section 3 hereof. The ica essary portions of the Ordinance pertaining h the Refunded Bonds are by this reference ere ed herein and made a part hereof. Any moneys remaining Fund after making payments as required under this after paying any incidental expenses shall be rem~ the City. ties hereto agree that the liability of e yment of moneys pursuant to this t to the application of the cash and e income derived from the Direct for such purpose as provided hereunder. have no lien whatsoever on any of the ed to or on deposit in the Escrow Fund for the es and expenses for services rendered by the or otherwise. the Escrow Aoent's failure to account for ations or moneys received by it, said 1 be and remain the property of the City of the Refunded Bonds as herein y reason such Direct Obligations or as herein provided, the assets of the impressed with a trust for the amount not provided until the required application shall -4- Section 7. The parties hereto agree that the moneys received by the Escrow Agent under Section 1, Paragraph (b){iii) of this Ag ent represent payment of fees, charges s incurr r to be incurred hereunder as Escrow nd do not in any respect constitute payment of the fees, and ex incurred or to be incurred by the Trust Bank, as ing Agent and Bond Registrar for said Bonds. Section is Agreement is made for the benefit of the City and the from time to time of the Refunded Bonds and it shall not b ed, revoked, altered or amended without the written consent of all such owners and the written consent of the Escrow Agent and the Municipal Bond Investors Assurance Cor ation; , however, that the City and the Escrow may, wi e consent of, or notice to, such owners, into such reements supplemental to this Agreement as not adver ffect the rights of such owners and as shall not be inconsistent with the terms and provisions of this Agreement, for anyone or more of the following purposes: (a) to cure any ambiguity or formal defect or omission in this Agreement; (b) to grant to , or confer upon, the Escrow Agent for benefit of the owners of the Refunded Bonds any addi rights, remedies, powers or authority that may lawfully be granted to, or conferred upon, such owners or the Escrow Agent; and (c) to subject to this Agreement additional funds, securities or properties. The Escrow Agent shall be entitled to rely exclusively upon an unqualified 0 ion of attorneys nationally recognized on the of mun~ pal bonds with respect to compliance with t tion, including the extent, if any, to which any nge, ficati addition or limitation affect the rights the owners of t funded Bonds or that any instrument executed hereunder complies with the conditions and provisions of this Section. The Escrow Agent at the time acting hereunder ime resign and be discharged from the trusts hereby ess than sixty (60) days written notice ing notice thereof, specifying the date such resi ion will take effect in a financial newspaper 1 circulation in the City of New York, at least once a three onsecutive calendar weeks prior to the date the resig is to take effect. Such resignation shall effect immediately upon the acceptance by the City of the -5- resignation, the appointment by the City of a successor Escrow Agent and acceptance by such successor Escrow Agent of the terms, covenants and conditions of this Agreement. The Escr rument or Escrow Ag rity in t outstanding. may be removed at any time by an ent instruments in writing, delivered to to the City and signed by the owners of a ipal amount of the Refunded Bonds then In the event the Escrow Agent hereunder shall resign or be removed, or be dissolved, or shall be in the course of lution or liquidation, or otherwise become incapable of ng hereunder, or in case the Escrow Agent shall be taken der the cont f any public officer or officers, or of a ceiver a y a court, the City shall appoint a successor cr nt to fill such vacancy. The City shall publish notice of any such appointment at least once a week for three (3) consecutive calendar weeks in a financial newspaper of general circulation in the City of New York, New York. In the event that no appointment of a successor Escrow ent shall have been made by the City pursuant to the regoing ovisions of this Section 9 within sixty (60) days after writ en notice of resignation of the Escrow Agent has been given to the City, the owner of any of the Refunded Bonds or the retir. Escrow Agent may apply to any court of competent ju sdiction for the appointment of a successor Escrow Agent, and such court may thereupon, after such notice, if any, as it shall deem proper, appoint a successor Escrow Agent. No successor Escrow Agent shall be appointed unless such successor Escrow nt shall be a corporation with trust powers organized under th banking laws of the United States or any State, and shall have at the time of appointment capital and surplus of not less than $50,000,000. In that the Escrow Agent has been paid in full for all of its fees, charges and expenses incurred in or to be incurred as Escrow Agent hereunder, the Escrow Agent agrees to pay and all pay 0 rata in advance all fees, charges and expenses to by the next succeeding Escrow Agent, if any, up to t received by the Escrow Agent as payment of its own Charges and expenses. Each succeeding Escrow Agent, if any, shall have the same obligation to its successor as Escrow Agent. or Escrow Agent appointed hereunder shall and deliver to its predecessor and to the in writing accepting such appointment upon such successor Escrow Agent without any or conveyance, shall become fully vested with -6- ties, power, trusts, duties and cessor; but such predecessor shall, tten request of such successor Escrow e and deliver an instrument cessor Escrow Agent all the estates, s and trusts of such predecessor decessor Escrow Agent shall deliver all Id by it to its successor. Should any instrument in writing from the City be Escrow Agent to more fully and successor Escrow Agent the estates, ies hereby vested or intended to be or Escrow Agent, any such transfer, nts in writing shall, on request, be and delivered by a duly authorized oration into which the Escrow Agent, or any it in the trusts created by this Agreement, may be rted or with which it or any successor to it may , or corporation resulting from any merger, consoli on or tax-free reorganization to which Agent or successor to it shall be a party shall, tory to City be the successor Escrow Agent under this Agreement without the execution or filing of any paper or other act on the part of any of the parties thereto, nything herein to the contrary notwithstanding. Secti O. This Agreement shall terminate when all transfers r red to be made by the Escrow Agent under the provisions hereof shall have been made. notice, authorization, request or demand to be given pursuant to the terms and of this Agreement shall be in writing and sent by ified or registered mail to: Municipal Bond Investors nce Corporation, 445 Hamilton Avenue, White Plains, New York 10601. Section 12. If anyone or more of the covenants or agreements provided in this Agreement on the part of the City or the Escrow Agent be performed should be determined by a ourt of nt sdiction to be contrary to law, such ovenant erne hall be deemed and construed to be rable rom the ining covenants and agreements herein ontained and shall in no way affect the validity of the remaining provisions of this Agreement. This Agreement shall be governed by the applicable laws of the State of Georgia. s Agreement may be executed in several any of which shall be regarded for all es as one 0 nal and shall constitute and be but one the same instrument. -7- Section 14. All the covenants and agreements in this Agreement contained by or on behalf of the City or the Escrow Agent shall bind and inure to the benefit of their respective successors and assigns, whether or not so expressed. IN WITNESS WHEREOF, the parties hereto have each caused this Agreement be executed by their duly authorized officers and their offic seals to be hereunto affixed and attested, this 28th day of June, 1989. Attest: By: (S E A L) Attest: Officer By: -8- HIGGINS PC June 28, 1989 Mayor and Councl I of ~he CITY of Smyrna, Georgia Smyrna, Georg I a TrusT Company Bank ATlanTa, Georgia Haynes & M I I I er Wa sh In gTon, D. C. SUTherland, Asbill & Brennan ATlanTa, Georgia RE: Defeasance of 12,900,000 CITy of Smyrna, WaTer and Sewerage Revenue Bonds, Series (Georgia) 1984 Gen~lemen: We unders~and ~ha~ The CITy of Smyrna, Georgia (The "Issuer") has deTermined To defease a por~lon of ~he CI~y ot Smyrna, (Georgia) Wa~er and Sewerage Revenue Bonds, Series 1984, now oUTs~andlng (~he "Series 1984 Bonds"), on June 28, 1989. The defeasance of Is TO be accomplished pursuanT ~o an Escrow DeposiT AgreemenT be~ween Ty and Trus~ Company Bank, A~lan~a, daTed as of The daTe hereof, a copy of has been delivered TO us by ~he CITy (The "Escrow DeposiT AgreemenT"). We undersTand ThaT The cash inl~lal cash deposiT (1147,3 used Ta detease ThaT parTlan 1, 1996, naw ou~s~andlng In "Refunded Bonds"). Specific The Refunded 1,1995; (II) ~he re July 1, 1995, of The Refunded flow from ~he DireCT ObligaTions Toge~her wiTh The on deposiT wiThin The Escrow AccaunT shal I be se Series 1984 Bonds maTuring on and afTer July gregaTe principal amoun~ of 12,900,000 (The The cash flaw shal I be used To pay (I) The same becomes due and payable ~hrough and Including n price (102% of The principal amounT ~hereof) on Bonds called for redempTlan. We have reviewed The aw Deposl~ Agreemen~ and The aT~ached schedules furnished TO us by The Issuer. been asked TO verify The maThemaTical accuracy of The ariThmeTical comp of The cash fl p by ~he DireCT ObligaTions (as defined and des In ~he Escrow Cep ~ enT) and The fn ITla I depas IT and express an opl TO The sufficiency of The projeCTed income and principal TO be derived from The DireCT Obllga pay The defeasance requiremenTs of The Refunded Bonds in accordance wl~h ~he posl~ AgreemenT. We have verified The acc cy of The ariThmeTical compuTaTion of The cash flow from The DirecT ObligaTions The IniTial deposiT~ The debT service requiremenTs on The Refunded Bonds, and The sufficiency of The cash flow from The DirecT ObligaTions and The iniTial deposiT TO pay The defeasance requiremenTs on The Refunded Bonds. Based upon The foregoing, IT is our opinion ThaT The principal of The DirecT ObligaTions plus The Income To be derived Therefrom~ TogeTher WiTh The iniTial depOSiT, are scheduled TO maTure In amounTS and aT Times TO provide funds which are sufficienT TO pay (I} The inTereST on The oUTsTanding principal amounT of Refunded Bonds as The same become due and payable Through and Including July 1, 1995; (Ii) The redempTion price (102% of The principal amounT Thereof} on July 1~ 1995 of Refunded Bonds called for redempTion on July 1~ 1995~ In accordance wiTh The Escrow DeposiT AgreemenT. DEEMER DAVIDSON CARTER HIGGINS PC J 77..l- Dw;e/ SCHEDUl..E 1 CITY OF SMYRNA W&S (QA); Summar~ OT R~~~ipt$ and REFUNDING BONDS Di -sb uT's-ements R~ceipts: Princip l~ss plus a~c oT bonds . ::),510.000.00 -42. 120. 00 IS. 103. 31 Net r~c~ived Tor bonds plUS contribution From issu~r 3.485.983.31\ 147.303.75 Total available . 3.633.287.06 ~~=======i~====== 1)i sb urs~ment s: bond Fund CASH FOR 7/1 PMT s W/PROCEEDS IUM & RATING FEE . 18,103.31 147.303.75 3. 3e3. 000. 00 "\ 23,500.00 47.477.50 13.902.50 Total disbursements . 3,633.287.06 ================= f A~tuarial Yield is 6.977191 X Assumptions of Calculations: issue cro.... -ting ",ield pro~eeds 1.200000 % . 1.025000 % . . . 11,:)00.00 23.500.00 19,000.00 147.303.75 CITY OF SMYRNA W&S (GAl: REFUNDING BONDS Debt Service Comparison i'JOf'l-"""'l... := AJ'r"";;::a,,;;: S ~ ************ The Maturity Principal In1:eres1: Date Amount Rate ***-+******** To1:al Debt Servic.e- ;2 h 'ftJ. uo ~_;t_~ yo. ,,'" ~q?,Q :tIf) -:J3uii. flu 7-93 '?, 4 ad. "V 7-94 .___ ::J ~ ~ <1.. <I'; 7-9~ .,,~lJC!2;;.;:-vJ _ 7-96 19 5/~W 7-97 ,~2.-~:;;. '-'<t. ----,7-98 __d2-.:L:t''fi ~a _ 7-99 _;<,'11<:'U.<I'; 7-00 7-01 7-02 430000 460000 ;2 <fl, :;, 77 50 6. 6000 6.6000 6.6000 6.6000 6.6000 6.6000 6.7000 6.7:500 6.8000 6.8500 6.9000 6.9500 7. 0000 7.0000 7.0000 Sands Interest: Pallanle 243368. 98~ 238737. :50 '" 236097. 50", 233127. 50", 229827. :50 '" 226:527.50", 222897. 50 "I 204472.50", 184897. :50"1 164157.50.." 141210. OO'A 117060.00", 906:50. 00", 62300. 00 '" 32200. 00 '" 283388.98 278737. 50 281097. SO 283127. 50 279827. 50 281527. 50 497897. 50 494472. 50 469897. :50 499157. 50 491210.00 497060.00 495650.00 492300.00 492200.00 Totals 3510000 0.0000 r::: All bonds pall semi-annual comput:ed ~rom 6- 1-1969. 2627551.46 6137551.48 ~ )~ current int:erest: beginning SCHEDULE 2 Available Revenues 294607. 50 294607.50 294607.50 294607.50 294607.50 294607.50 509607.50 :508967.50 :5060:55.00 510610.00 :507310.00 511000.00 510206.25 505781. 25 507725.00 634:5107. 50 r:: 1- 1-1990 Oi......re...ce 11218. 52 "1 15870.00 ... 13510.00", 11480.00", 14780. 00 '" 13080.00", 11710.00", 14495.00 '" 16157.50",- 11652.50" 16100. 00",- 13940. 00", 14556.25..., 13481- 25 '" 15525. 00 VI 207556. 02 ~I- Assumes settlement: on 6-28-1989 wit:h accrued interest o~ '" 18.103.31. Interest: Pallable and Tot:al Dent: Service Do Not Include Accrued Int:erest. Mondall' 4:04 pm, ~une 5. 1969 REPRESENT AMOUNTS COMMITTED TO DEBT SERVICE 6.97719% is '" 132.620.68 I .1/79'- Present value o~ di~~eren"e a~ 7/1"10 ~ "3' g cf ~'7.,) :1-43 I '1 J f.."'I? c1 ((" '1 I, :3 7' 7. ,,--0 y 3fof _::: 36:) /) ,,,",,<....... ~- ;;1.1:; ,3(,,1-'-13 fD};':;:O ? 7 ~<' \.;:1 4S L. ~""I.-- ______,:J "--\ \ ,3'/ ::.- - ., SCHEDULE 3A CITY OF SMYRNA W&S, GA: OUTSTANDING SERIES 1984 SONDS ESCROW ACCOUNT Summary or Inves~ments Inves~ment Coupon Invest Normal 1st: Period Total Date Principal Rat:e Type Int:erest Interest: In~erest 7- 1-89 0.00 0.00 0.00 o. 00 1- 1-90- 00. .0.000 SLG CeTt 0.00 0.00 113:584.68 7- 1-90 00 0.000 SLG Note 0.00 0.00 1117:32.76 1- 1-91 00 0.000 SLG Note O. 00 0.00 1117:32.76 7- 1-91 .00 0.000 SLG No;;e 0.00 O. 00 1117:32.76 1- 1-92 .00 0.000 SLG No;;e 0.00 0.00 111732.76 7- 1-92 .00 0.000 SLG Note 0.00 0.00 111732.76 1- 1-93 30000.00 0.000 SLG Note 0.00 0.00 111732.76 7- 1-9:3 30bOO.00 0.000 SLG Note O. 00 0.00 111732.76 1- 1-94 :30500. 00 0.000 SLG Note 0.00 0.00 111732.76 7- 1-94 .00 0.000 SLG Note O. 00 0.00 111732.76 1- 1-9::; .00 0.000 SLG Note 0.00 0.00 111732.76 7- 1-95 2 .00 J. 7.465 SLG Note 1117:32.76 1851. 92 '7 111732.76 To~al :3383000.00 111732.76 1851.92 1342645 04 re: p: '"' f'" Settlemen~ is 6-28-1989. 3/18!~.2nd CIH'i; 187~3~ SLG 1st per. tlo: bonds 3< notes 1st: ",e1"iOO int:e1"est on SLGS paid In 2fii:1 p e".'" ad --- 1S"E'~ 1 ad less than 30 day Coupon rOT' 7- 1-1995 15 7.4b50250 Yo. '- Monday. 4:04 pm, June 5. 1989 --z ....- ~ SCHEDULE 3B CITY OF SMYRNA W3<S. GA: OUTSTANDING SERIES 1984 BONDS ESCROW ACCOUNT Escrow Cash Flow Sta..~lng Principal In~erest Total Payout Closing Date aalance Received Received Available _ R..<tuired r Balance ------,,;;;;;, \ '1"1, ~, 0j"' , "".3">-:l,"t.~. I '-\-L ;"": ,~ 7- 1-89 ~ 0.00 0.00 .0.....00 o.....bG 0.00... 1- 1-90 0.00 33800.00 113584.68 147384.b8 147303.75 80. 93 A 7- 1-90 80.<;>3 35500.00 111732.76 147313.b9 147303.75 9.94", 1- 1-<;>1 <;>.<;>4 35600.00 111732.76 147342.70 147303.75 38.95... 7- 1-91 38.<;>5 35600.00 111732.76 147371. 71 147303.75 67. <;>b~ 1- 1-<;>2 b7.9b 3:1000.00 111732.70 147400.72 147303.75 9b.97"1 7- 1-<;>2 96.97 35500.00 111732.7b 147329.73 147303.75 25. 98.. 1- 1-93 25.<;>8 35bOO.00 111732.76 147358.74 147303.75 54.99.. 7- 1-93 54.99 35600.00 111732.76 147387.75 147303.75 84.00" 1- 1-94 84.00 35500.00 111732.70 147316.7b 147303.75 13.01 ... 7- 1-94 13.01 35600.00 111732.76 147345.77 147303.75 42. 02 ~ 1- 1-95 42.02 35bOO.00 111732.76 147374.78 147303.75 71. 03.... 7- 1-95 71. 03 2993500.00 111732.7b 310:5303.79 310:5303.75 0.04 y Total 0.00 33830?-0.OO 1342645.04 4725b45.04 4725b45.00 0.04 1'1'7303 X' - ~ '/J7;1.. 7'<ff. 7'J tii'--J:J.../q'{,f'75 Monday. 4:04 pm. June 5, 1989 .,;;:: CITY OF SMYRNA W&S, GA; OUTSTANDING SERIES 1984 SaNDS SCHEDULE 4 7-89 Pr1nc1pal tnt.rest Amount Rat. Debt Service Schedule Matur1ty Oat.. 00 00 00 00 00 00 00 00 00 .00 00 310,000.00 34!h 000. 00 380,000.00 415,000.00 460,000.00 7-95 7-96 7-97 7-98 7-99 7-00 7-01 7-02 7-03 7-04 8.0000 '1..'1.... 8.2500 8.5000 8.7500 9.0000 9.2000 9.4000 9. 6000 9.7500 9.9000 10.0000 10. 1000 10.3750 10.3750 10.3750 10.3750 Intere..t Payable 194,848.75 "I 380,097.50 >1 369,372.50 ... 357.472.50 " 344.347.50.., 329.497.50,.., 312.937.50 "'" 294.607.50", 273,967. 50,.., 251.055.00 "" 225.810. 00 VI 197.310. 00 VI 166, 000. oo~ 130. 206. 25 V\ 90,781.25 ..... 47,725.00.., Total.. 3.980.000.00 0.0000 3.966.036.25 ~ P All bonds pall ..e!"i---<l1"T~cu........nt inte....st b"9in.,:,inll-. computed i'...om _ 1- 1-19.~.>/ ~____..~: _ A/" n"__""-- As.s.umes ..ettlem..nt on 6- 1-1989 with accru.d int.....est Thu.....day, 11;31 am, May II. 1989 Total D..bt ""In!..""'<- Service :r:N"T<:r!.<~'" 314. 848. 75 '7 {. <1<1 .t/d 510,097. 50 I07~S.t/~ 509,372.50 119au.co 507,472. 50 13/~~.<lJ 509.347.50 /Yf~~ljd 509,497. 50 16.".0."'; 507, 937. 50-" 18;;:3 tJ. <IV' 509,607.50 20 "yo.ad ~8, 967.50 ;). L 'j;;l.4'J 506,055.00.~.~.~y~t/J 510.810.00 ]..5' <;'''').oJ 507.310. 00 3 I :J / v-:7iiT' 511,000. 00 :1<; 793.7'- 5:1.0,206.25' 39 '/.z., "" 505.781. 25 i.(:;,a <;'1,. ~<; 507.725.00 '-177:J.<""u< 7.946,036.25 .... C r: 1 - i 98"9"" oi' '$ 162,373.96. SCHEDULE 4-REF CITY OF SMYRNA W&S, GA: OUTSTANDING SERIES 1984 BONDS TO BE REFUNDED Maturity Date Principal Amount Inte,.est Rate Debt Service Schedule 7-89 7-90 7-91 7-92 7-93 7-94 7-95 7-96 7-97 7-98 7-99 7-00 7-01 7-02 7-03 7-04 215,000.00 235,000.00 .00 .00 .00 345,000.00 380,000.00 415,000.00 460,000.00 9.6000 9.7500 9.9000 10.0000 10. 1000 10.3750 10.3750 10.3750 10.3750 Totals 2,900,000.00 i";' All bonds pay semi-annual computed Tram 1- 1-1989. 0.0000 cu,.rent Inte,.",st Payable '1,...,..- 147,303.75.. 2'94,607.50" 294,607.50., 2'94,607.50, 2'94,607. SO., 2'94,6>07. SO" 2'94,6>07.50_ 2'94,6>07. 50- 273.967. 50 ~ 251, 055. OO'~ 225,810. 00..., 1'97,310.00,., 16>0,000.00- 130,206.25~ '90,781.25,.., 47.725. 00 ~ 3,592,411.25 P interest beginning Total Debt NO~~i~ Se-rvi c e --:I:~..,.~A:~r 147,30:3.75 294,607.50 2'94,607.50 294,607.50 294,607.50 294,007. SO 2'94.607.50 50'9'007.50 ;1.0(,.'10.00 508,'967. 50 -~ij[~J~ 506,055. 00 :- <;' .2.""."" 510. 810. oo-~-i.T~ 507~ 310. 00 .:3: / :;!<..I_~uJ.J 511, 000. 00---- "1,'''i--;;- .. -1- 'i,- 510.206. 2~~~~~r~w- 505.781. 2;? '-,1,,, 5"& 2 <' 507,725.00 1'1 7;..1' ~J 2"7' '7""0 7~5U ,':;: 6.492,411.25 C /c 7- 1-1989 Assumes settlement On 6-28-1989 with accrued inter..st oT S 144,848.69. Monday, 4:28 pm, June 5, 1989 CITY OF SMYRNA W&S. GA: OUTSTANDING SERIES 1984 BONDS TO BE REFUNDED SCHEDULE 5 DEFEASANCE REGUIREMENTS Call 2.900.000.00 outst<ilnding bonds maturing 7- 1-1996 and i::he...eai'ter on 7- 1-1995 at 102.00007. oi' pa... total premium is 58.000.00 . 7- 1-1989 1 1- 1-1990 2 7- 1-1990 3 1- 1-1 4 7- 1-1 5 1- 1-1 6 7- 1- 7 1- 1-1'993 8 7- 1-19'93 9 1- 1 10 7- 1 11 1- 1 12 7- 1 13 1- 1 14 7- 1-1996 15 To1;al Column A 147,303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 147.303.75 3.105.303.75(jj) 00 'l/ 00 Monday. 4:28 pm. June 5, 1989 15 4.872.948.75 I:::: 0.0;': 2, iJJ,1j IJ.I)':'1+ 5;3,000-00+ 1 47 '.3 1] 3 . 7 :5 + 003 If- 3. 1,,)5' 3,J3'"7 :5*(jj> SCHEDULE 6 COL 1 CITY OF SMYRNA W~S (GA): REFUNDING BONDS PROOF OF YIELD COL :2 COL 3 DATE AMOUNT VALUED TOTALS 140603. 54 160066.75 119306.75 159368.75 116048.75 163048. 75 116563.75 166563. 75 114913.75 164913.75 113263.75 168203.75 111448.75 380446.75 25 25 92446.75 397446.75 82076.75 417076.75 70605.00 420605.00 56530.00 436530.00 45325.00 450325.00 31150.00 461150.00 16100.00 476100.00 61556::;4.79 1- 1-1990 7- 1-1990 1- 1-1991 7- 1-1991 1- 1-1992 7- 1-1992 1- 1-1993 7- 1-1993 1- 1-1'994 7- 1-1994 1- 1-1995 7- 1-1995 1- 1-1996 7- 1- 1- 1- 7- I- I- 1- 7- 1- 7- 1- 7- 1- 7- 1- TO 6-28-1969 2 6.97719 Yo P.V. FACTOR PRESENT VALUE (COL 1 X COL 2) 0.9657379568 0.'933162'9619 0.'9017254335 0.8713283174 O. 641'955886::; 0.8135735'966 0.7861460761 0.75'96470665 0.7340394045 0.70'92949755 0.68538467'98 0.6622603989 0.6399549621 0.6163621146 O. 5975364666 O. 5773935636 O. 557'92'96575 O. 6766 O. 1089 O. 9760 0.4664176280 0.4700207090 0.4541763361 0.4366660761 0.4240719242 0.4097764623 0.395962'9390 0.3626150495 0.36'97171167 0.357253'9724 135979.32 14'9952.01 107637. 84 138862. 50 '9'9391.84 132652. 16 91636. 37 12652'9. 66 64351. 22 116972.49 77629.24 111437.76 71322. 18 236973.00 61089.89 226474. 69 51579.90 214273.32 42758.77 209952.01 34343. 53 197693.06 26582.94 192455.94 19221.06 16453..1. 59 12334.25 176442.93 5952. 45 170068. 62 3509103. 55 Monday, 4:23 pm, June 5, 198'9 Tac~o~s based on 2 compounding in~e~vals pe~ vea~. COST AD.JVSTMENT ... A. 1. - PRICE FOR YIEJ..D PROOF '9000 ... 18103.31 - 3509103.31 DOES NOT EXCEED CALCULATED VALUE (TOTAL OF COL. 3) THE YIELD U6ED IN THE CALCULATION (YIELD USED IN OF COLUMN 2) SCHEDULE 7 CITY OF SMYRNA W&S. GA: OUTSTANDING SERIES 1984 BONDS ESCROW ACCOUNT PROOF OF YIEl..D COl.. 1 eol.. 2 0_97719 % P.V. FACTOR COL :3 D....TE 1-1989 1-1990 1-1990 AMOUNT VALUED PRESENT VALUE (COl.. 1 X COL 2) 1 1 1-199l' 1-1995 TOTALS 0.00 147384.08 147232.70 147332.70 147332.70 147332.70 147232.76 147332.76 147:3:32.76 147232.76 14733..1. 76 147332.76 3105232.70 4725045.04 0.9994286429 O. 9657379568 0.9331829819 O. 90172:::>4335 O. 4 O. 5 0.91 0.7 1 0_7596470665 0.7340394045 0.70<12949755 0.6953946798 0.6622803989 0.00 142334.98 1:37395.11 132853. 70 129375.21 124047.68 11<1784.69 115925.37 111920.90 109074. 65 104502. 39 100979. 62 2056534.79 :3392629.07 ALL P....YMENTS VALUED TO 6-29-1969 AMOUNT VALUED FROM SCHEDULE 3B PTesen~ value ractoTs based on 2 compounding in~ervals per ~ear. Monday. 4:23 pm. June 5. 19&9 PRICE FOR YIEl..D PROOF - PAR AMT PAID FOR SLGS - 3.383,000.00 IS GRE YIEl..O OF eOL N CAL.CULATED YAL.UE (TOTAL OF COL. 3) THE CAL.CUl..ATION (YIELD USED IN rNCOMBENCY CERTIFICATE OF TROST COMPANY BANK, AS ESCROW AGENT DO HEREBY CERTIFY that I am Vice company Bank, Atlanta, Georgia (the ized to execute and deliver this of the Bank, and that I have personal set forth herein. I below elected the offices ify that the officers of the Bank shown res opposite thereto were duly of Directors of the Bank and now hold under their respective names: M.R. Assis , President P.H. Assi icers of the Bank, by virtue of the them by the Board of Directors of the zed to execute for and on behalf of the f trust and acceptances of fiduciary virtue of the aforementioned authority are authorized to execute and deliver +-h.o 1=i'C!.I"""'.,....r"\C.7 l\.t::liY"\.-,"",.O; +- n.......,,...~.o.rt'\..c::::..,....,..... ..-...F "::::"T"T~T"'1 r documents as may be necessary, to the acceptance or performance of responsibility set forth in the and to apply the seal of the Bank IN WITNESS WHEREOF, I have hereunto set my hand affixedt.heseal of the Trust Company Bank, Atlanta, this 28th day of June, 1989. and Georgia, Vice President CE:R'I:':I::E":I:(;j.\'!"E RELA'!"IVE TO THE CITY OF SMYRNA GEORGIA WATER AND SEWERAGE REVENUE BONDS, SERIES 1984 HEREBY CERTIFY that I am Assistant t Company Sank, Atlanta, Georgia (the zed to execute and deliver this the Bank, and that I have personal set forth herein. that the Bank is the Paying Agent for amount of City of Smyrna, Water and Series 1984 (the "Series 1984 Bonds"), of said Series 1984 Bonds and all 1984 Bonds which have heretofore matured or moneys are otherwise on deposit in the payment tb.ereof, exclusive of the Bank pursuant to the Escrow Deposit of Smyrna of even date herewith. that the Bank has received full and and charges incurred to date as istrar for said Series 1984 Bonds. the day have hereunto set my hand and affixed Bank, Atlanta, Georgia, this 28th TRUST COMPANY BANK Atlanta, Georg'a e President By: (S E June 28, 1989 Company Corporate Trus Atlanta, Georgia Re: o~ Smyrna, Water and Sewerage ries 1984 Gentlemen: to refund the above-captioned in accordance with the terms and ed by the Mayor and Council of 9 and to the extent and in the Deposit Agreement and even date between the City of Smyrna and the and directed to mail, not more than thirty (30) days prior to Notice ofC;:a.ll for Redemption in ted by the Mayor and Clerk of the of the $2,900,000 aggregate 1984 Bonds maturing July 1, 1996 on July 1, ~OO4:, which are to be ir addresses appearing on the the Bank as Bond Registrar. ng that the payment of the incurred or to be incurred as on.ed bonds have been paid in Deposit Agreement. Very truly yours, By Mayor COCHRAN. CAMP 8c SNIPES ~!:~ .-...{ ~~ a& 5:&- 2950 ATLANTA STREET. S.E. SMYRNA. GEORGIA 30080-3692 TE...E.....O.... 43l5-21 31 AREA CODE 404 June 28. 1989 Lex Jolley & Co.. Inc. 34 Peachtree St. Suite 2500 Atlanta. Georgia 30303 Sutherland. Asbill & 3100 First Atlanta Atlanta. Georgia 30 Brennan r Gentlemen: This opinion is being rendered to you in connection with the issuance by the City of Smyrna. Georgia (the "City") of its Water and Sewerage Revenue Refunding Bonds. Series 1989 (the "Bonds") in the aggregate principal amount of $ 510,000. ds have been issued and delivered pursuant to and in ace ce with ions of a Bond Ordinance adopted by the City on May 25. 1989 (the "Bond Ordinance"). -- As counsel to the City and in connection with the issuance of the Bonds. we have examined such records and documents as are necessary in order to render this opinion. Based on our examination. it is our opinion that: L The Ci the Co s a duly organized and existing political subdivision under tution and laws of the State of Georgia. 2. The Bond Ordinance was duly adopted by the City on May 25, in accordance with O.C.G.A. 36-82- and is in full force and effect in the form in which it was adop 3. The adopti by the City of the Bond Ordinance and the performance by the Cit f its obligations thereunder. do not and will not violate any prov of the Constitution. laws or regulations of the State of d are not and will not be in conflict with any provisions of rter. by-laws. Ordinance or Resolution of the City and do not and will not cause any default by the City under any other agreement to which the City is a party. CEC/kpl ey & Co., Inc. d, Asbill & Brennan 4. No lit threat or del charges or fees or 1.n any manner of the Bonds 0 or affects the charges 1.ssuance and 1.s now pend1.ng. or to our knowledge. or does restra1.n or enjo1.n the 1.ssuance r the levy or collect1.on of any ut1.l1.ty to p 1.nterest on or princ1.pal of the Bonds. quest~ons the authority or proceedings for the 1.ssuance collection of said ut1.l1.ty charges or fees. of the Bonds or the collect1.on of sa1.d utility ffects the transact1.ons contemplated by the of the Bonds. " CERTIFICATE AS TO MUNICIPAL BOND GUARANTY INSURANCE POLICY I, Michael F. Kemp, Assistant Vice President of the Bank South, N.A., Atlanta, Georgia, DO HEREBY CERTIFY that attached hereto is a true and correct copy of the Municipal Bond Guaranty Insurance Policy No. 65l2, dated June 28, 1989, issued by Municipal Bond Investors Assurance Corporation, which insures the payment of the principal of and interest on the $3,5l0,000 principal amount of City of Smyrna Water and Sewerage Revenue Refunding Bonds, Series 1989, the original of which being on file in the corporate trust office of the Bank South, N.A., Atlanta, Georgia. WITNESS my hand and the official seal of the Bank South, N.A., Atlanta, Georgia, this 28th day of June, 1989. Bank South, N.A., Atlanta, Georgia By: ent (SEAL) BIA Corporation MUNICIPAL BOND GUARANTY INSURANCE POLICY Municipal Bond Investors Assurance Corporation White Plains, New York 10601 Policy No. 6512 Mun ~ipaI Bond Investors Assurance Corporation (the '.lnsurer"). in consideration of the paYfllcnt of the premium and subject tG the tenns of this polk ,hereby unconditionally and irrevocably guarantees to any owner. as hereinafter defined, of the following described obligations. the full and c e payment required to be nlude by or on ltehalfpf th~< Issuer to f f . f the pr~nc~pai corporate trust 0 ~ce 0 Bank South. N .A... Atlanta. Georgia '" or its successor (the hPaying AgenC') of an aUlount equal to (i) the principal of (either at th~ stated rnaturity or by any advancement of nl.utunty pursuant 10 a mandatory sinking fund payment) und interest on, the Obligations (as {hat {cnn is defined below) such payments ~hall become due but shall not be so paid (except that in the event of any accdenition of the due date of such principal by reason mandatory or opti~-mal redernpt!on or acceleration resulting froin default or otherwise. other than any advanCt:rne,l1t of ruaturity pursuant to a mandatory sinking fund paymenl, the payments guaranteed hereby: shan be made in such aluollnts and at such linles as such payments of principal would have been due had there not been any such acceleration): and (ii) the reimbursernent of any such paYlucnr which is subsequently recovered fronl any owner pursuant to a final judgrnent by a court of conlpe-tent jurisdiction that 1'luch payn1ent constitutes an avoidable preference to such owner within the n1eaning of any applicable bankruptcy law. The amounts referred to in clauses (i) and (ii) of the preceding sentence shall be referred to herein collectively as the --Insured i\mounts. n ~~Obligationsn shall rnean: $3>510.000 City of Smyrna, Georgia Water and Sewerage Revenue Refunding Bonds Series 1989 Upon receipt of telephonic or telegraphic notice, such notice subsequently confirmed in writing by registered or certified mail. or upon receipt of written notice by registered or certified mail, by the Insurer from the Paying Agent or any owner of an Obligation the payment of an Insured Amount for which is then due, that such required payment has not been made, the rns~rer on the due' date of such payment or within one business day after receipt of notice of such later, will rnake a deposit of funds, in an account with Citibank, N .A., in New Y ark, ~ew Yark. or its successor, $ufficie yment of any such Insured Amount.s which are then due. Upon presentment and surrender of such OblIgations or presentment of such 0 wnership of the Obligations, together with any appropriate instruments of assignment to evidence the assignment of the Insured Amount Obligations as are paid by the Insurer, and .appropriate instruments to effect the appointment of the lnsurer as agent for such owners of the Obligations in any legal proceeding related to payment of Insured Amounts on the Obligations, such instruments being in a form satisfactory to Citibank, N.A., Citib~nk. N.A. shall disburse to such owners. or the Paying Agent payment of the Insured Arnount.s due on such Obligations, less any amount held by the Paying Agent for the payment of such Insured Amounts and legally available therefor. ThIS polley does not insure against loss of any prepayment premium which may at any time be payable with respect to any Obligation. As used herein, the term "owneru shall mean the registered owner of any Obligation as indicated in the books 111aintained by the Paying Agent, the Issuer, or any de-signee of the Issuer for such purpose. The term owner shall not include the Issuer or any party whose agreernent with the Issuer constitutes the undertying security for the Obligations_ Any service of process on the Insurer may be made to the Insurer at its offices located at 445 Hamilton Avenue. White Plains. New York 10601 and such service of process shall be valid and binding. This policy is non~canceHable for any reason. The premium on this policy is not refundable for any reason including the payment prior to maturity of the Obligations. IN WITNESS WHEREOF. the Insurer has caused this po.licy ro be executed and attested on its behalf by its President and its Assistant Secretary, this 28th day of 19 89 CDUNTERSIGNED: MUNICIPAL BOND INVESTORS ASSURANCE CORPORATION I:f'~ -H. c~ p"","" ";:JiJ / /,/~ /./^1. . /~'-~..: j. r '- _'"' i Assistirrf( Secretary ./--J J~/I /) // Attest: ,19 STD-R.2 *Inserr Name of Trustee or Paying Agent. Municipal Bond Investors Assurance Corporation 445 Hamilton Avenue Box 788 White Plains. NY 10602 914681.1300 28, of $3,510,000 Smyrna, Georgia Revenue Refunding Bonds Series 1989 obligations (the "Obligations") of (the "Paying Agent"), please be advised of and interest on the Obligations has municipal bond gu,ar<:lnty insurance (the Bond Investors Assurance Corporation (the York, New York, (the "Fiscal Agent") is Insurer. guarantees to any owner or holder coupons apPertaining thereto (the be m<:lde by or on behalf of the Paying Agent or its the principal of (either at the stated maturity pU:r-suant to a mandatory sinking Obligations as such payments shall become that in the event of any acceleration of of mandatory or optional redemption default or otherwise, other than any to a mandatory sinking fund payment. t.he shall be made in such amounts and at. such would have been due had there not. been any reimbursement of <;lny such payment which is pursuant to a final judgment. by a court such payment constit.utes an avoidable Owner wit.hin t.he meaning of any applicable red t.o in clauses (il and (iil of t.he coII.ect.ively in t.his lett.er as t.he "Insured -2- The Po~icy does not insure against ~oss of any prepayment premium which may at any time be payab~e with respect to any Ob~igations. The Po~icy does not, under any circumstance, insure against ~oss re~ating to: (i) optional or mandatory redemptions (other than mandatory sinking fund redemptions); (ii) any payments to be made on an accelerated basis; (iii) payments of the purchase price of Obligations upon tender by an Owner thereof; or (iv) any Preference re~ating to (i) through (iii) above. In the event that the Issuer does not make fu~~ and comp~ete payment when due of the principal of and interest on the Obligations, please immediately notify, by telephone or telegraph, the Insurer, 445 Hamilton Avenue, White P~ains, New York, (914) 681-1300. On the due date or within one business day after receipt of such notice, whichever is later, the Insurer will deposit funds with the Fiscal Agent sufficient to pay the Obligations (or, if applicable, coupons appertaining thereto) then due. Upon presentment and surrender of such obligations (or, if applicable, coupons) or presentment of such other proof of ownership of Obligations together with any appropriate instruments of assignment to evidence the assignment of the Insured Amounts due on the Obligations as are paid by the Insurer, and appropriate instruments to effect the appointment of the Insurer as agent for the Owners in any legal proceeding related to payment of Insured Amounts on the Obligations (or. if applicable, coupons), such instruments being in a form satisfactory to the Fiscal Agent, shall disburse to you payment of the Insured Amounts due on such Obligations (and, if applicable, coupons), less any amount held by you for the payment of such Insured Amounts and legally available therefor. Forms of such instruments of assignment and instruments to effect the appointment of the Insurer as such agent for the Owners (collectively, the "Claim Documents"), which are currently acceptable to the Fiscal Agent and the Insurer, are on file with the Fiscal Agent. The Insurer may, from time to time, file revised forms of Claim Documents with the Fiscal Agent in substitution for the forms previously filed with the Fiscal Agent, and upon such filing, the revised forms shall supersede all forms of Claim Documents previously filed with the Fiscal Agent, except as otherwise directed by the Insurer in writing. In the event that you shall have prior knowledge of an impending failure by the Issuer to make payment on the Obligations (or, if applicable, coupons) when due. please immediately notify the Insurer so that it will be possible to have funds available for you on the due date to make payments against surrendered Obligations (and, if applicable, coupons). Your cooperation in this matter will possible for the Owners of Obligations of all payments when due. be most appreciated and guaranteed by the Insurer will to be make it assured Very truly yours, 1:f~ -1f. C~ David H. Elliott, President Municipal Bond Investors Assurance Corporation KUTAK ROCK & CAMPBELL A PARTNERSHIP INCLUDING PROFESSiONAL CORPORATIONS THE OMAHA BUILDING j 650 FARNAM STREET OMAHA, NEBRASKA 68102 (402) 346-6000 June 28, 1989 City of Smyrna 1306 Bank Street Smyrna, GA 30080 Les Jolley & Co. Inc. Suite 2500 34 Peachtree Street, N.W. Atlanta, GA 30303-2316 Sutherland, Asbill & Brennan 3100 Firt Atlanta Tower Atlanta, GA 30383-3001 $3,510,000 City of Smyrna, Georgia Water and Sewerage Revenue Refunding Bonds Series 1989 Dear Sirs: We have acted as special counsel to the Municipal Bond Investors Assurance Corporation (the "Corporation") in con- nection with the issuance of municipal bond guaranty insur- ance POlicy No. 6512 (the "Policy") relating to $3,510,000 City of Smyrna, Georgia Water and Sewerage Revenue Refunding Bonds, Series 1989. We are familiar with and have examined a certified copy of the Policy and such other relevant documents as we have deemed necessary. Based upon the foregoing, we are of the following opin- ion: 1. The Corporation is a stock insurance corpora- tion, duly incorporated and validly existing under the laws of the State of New York and is licensed and authorized to issue the Policy under the laws of the State of New York. ATLANTA DENVER NEW YORK WASHINGTON KUTAK ROCK & CAMPBELL June 28, 1989 Page 2 2. The Policy has been duly executed and is a valid and b~nding obligation of the Corporation enforce- able in accordance with its terms except that the enforcement of the Policy may be limited by laws relat- ing to bankruptcy, insolvency, reorganization, morato- rium, receivership and other similar laws affecting creditors' rights generally and by general principles of equity. Very truly yours, Q.;&-- SUTHERLANP, ASBILL & BRENNAN 3100 RST ATI...ANTA TOWER ATLANTA, GEORGIA 30383-3001 (4-04) 658-8700 1275 PENNSYLVANIA AVENUE, N.W. WASHINGTON.D. C. 20004-2404 (202) 383-0100 June 28, 1989 Co., Inc. Re: tionwith the issuance bonds (the "Bonds"), we have of the idation proceedings in the , Georgia pertaining to the Bonds ordinance of the Council of the City on May 25, 1989, authorizing the "Ordinance"), the Official Statement to the Bonds (the "Official documents, certificates, instruments necessary or appropriate for of the op~nion that the Statement under the captions OBLIGATIONS," "THE SERIES and "THE BOND ORDINANCE," ined therein purport to summarize , the Ordinance and our approving summary of such items. letter is Co., Inc. to upon by us for the sole benefit of Lex person or entity shall be opinion without our express written Very truly yours, SUTHERLAND, ASBILL & BRENNAN By: REGISTRAR AND PAYING AGENCY AGREEMENT THIS AGENCY day of June, 1989, here called Georgia, hereinafte In cons ide set the $3 Bonds, to as "Bonds"). lowing te 1. It is cu be issued and about June 28, 19 "Pl<3.C~ of Closing") practicable, the I the following documents, Which shall either be originally executed are certified or otherwise counterparts or copies nance of adopted May ivery i s made and entered into as of the 22nd tween the City of Smyrna, Georgia, r, and the Bank South, N.A., Atlanta, led the Bank, WIT N E SSE T H: of the mutual covenants and agreements here- Issuer hereby appoints the Bank, and the tment, as Bond Registrar and Paying City of Smyrna Water and Sewerage Revenue 1989, dated June 1, 1989 (hereinafter Such appointment is made and accepted an conditions: anticipated that the Bonds will actually to the original purchasers thereof on or "Closing Date") in Atlanta, Georgia (the At such time or as soon thereafter as 1 cause to be delivered to the Bank to the satisfaction of the Bank: Mayor and Council of the City of Smyrna 1989 providing for the issuance and Bonds; r executed by the Issuer; (c) Specimen Bond; and (d) Approving Legal Opinion from Bond Counsel. 2. The Issuer shall furnish the Bank a sufficient supply of blank Bonds and time to time shall renew such supply as requested. Such blank Bonds shall be signed by the facsimile signature as speci.fled in the ordinance adopted May 25, 1989 by the Issuer providing.for issuance and delivery of the Bonds (herein called the. !'Bond Ordinance") of authorized officers of the Issuer designated to sign on behalf of the Issuer, and shall bear the .facsimile of cial seal of the Issuer and shall bear tion te of the Clerk of Superior Court of Cobb County executed ed as required in the Bond Ordinance. The pro'llisioDS of the Ordinance relating to the rights, duties and>responsibiliti the Bank as Bond Registrar and Paying Agent for the Bonds hereby incorporated herein and made a part hereof. 3. No later three (3) business days prior to the anti- cipated Closing Date the Issuer shall deliver or cause to be delivered to the Bank written specifications for preparation of the Bonds to be del to the original purchaser or purchasers reof, including names and addresses of registered owners and ons in Bonds are to be issued. The Bonds prepared istered by the Bank in accordance with instructions and delivered by the Bank to the Place of Closing or otherwise as specified in said written instructions of the to the Bank~ such Place of Closing the Bank shall make at a time designated by the Issuer or its - 2 - representative a authorized officer or officers of the Bank for the purpose of e:xecuting an appropriate certificate of authentication on such Bonds prior to delivery. The Bank shall be responsible for safekeeping all Bonds authenticated by it until the time speci r delivery. No such Bonds shall be initially delivered by the Bank except in accordance with an Authentication Order or other appropriate written direction to the Bank executed by an authorized offlcial of the Issuer. In the event that the Bank shall not receive an Authentication Order on the Closing Date and the authent certificate on any of the Bonds shall have been executed by or if the Issuer shall so direct in writing, the Bank 1 be authorized to cancel the certificates representing such Bonds, provided that it delivers to the Issuer appropriate evidence that such Bonds have been cancelled and were not delivered. 4. The Bank agrees that it shall maintain appropriate books and records on behalf of the Issuer reflecting the amount of the Bonds initial rized to be issued under the Authentication Order, the amount of the Bonds authenticated and delivered by the Bank from time to time, and the date, identifying numbers, name and address of registered owner or owners, denominations, maturity other appropriate information concerning the Bonds icated and delivered by the Bank hereunder from time to The Bank agrees with the Issuer that Bonds will not at any time be authenticated and delivered and permitted to be with respect to any maturity in an aggregate amount the amount iginally authorized and set forth in the - 3 - less the aggregate amount of Bonds which have been at maturity or which have been redeemed or purchased and for lation, except to the extent as may be permitted in the Ordinance in the case of lost, stolen or destroyed Bonds. 5. The Bank w~ll transfer the Bonds, register transfer of the Bonds and issue new bonds upon surrender of Bonds in the form deemed by the Bank be properly endorsed for transfer, accom- panied by such as the Bank deems necessary or appro- priate to evidence the authority of the person requesting such transfer, registrat issuance and the genuineness of all necessary endorsements. In making any such transfer of .Bonds the Bank>will endeavor to comply with requirements for maximum turn- around time apPl.:i.c:ab1e to corporate securities registered for trading on nat.:i.one'llsecurities exchanges as may then be in effect. 6. Unless the Bank shall have been provided with an opinion of counsel ssuer to the contrary, the Bank shall be entitled to that registration and transfer of the Bonds will be subject to and governed by the provisions of the Uniform Commercial Code in effect in the State of Georgia, and that all bond transfer simplification legislation and other statutes, and legal. authorities generally applicable to trans- investment securities in said state will be applicable to and Issuer. Accordingly, unless the Bank shall have with nion of counsel to the Issuer to the Bank fully protected in relying upon said regu or other legal authority and failing to - 4 - ry documentation and registering transrers inquiry into adverse claims, and accepting Bonds for meeting delivery" requirements of national securi- exchanges, laying registration for purposes of inquiry into adverse and in declining to effect the registration of Bonds wherein in the judgment or the Bank such registration should await resolut~on of such adverse claims. 7. The Bank been designated as paying agent ror the Bongs, and in ity will act as agent of the Issuer for th~pul:'pose or the registered owners of the Bonds interest coming from time to time and the principal amount thereof becoming due at maturity or prior thereto upon call for redemption and for selecting the Bonds to be redeemed in accordance wi Ordinance. In such capacity the Bank shall not be to advance funds for the purpose of making any such payments~ shall make such payments only with funds provided to the Bank by the Issuer and specifically designated for s1..lch purpose. UUl.;ess otherwise specifically directed by the Issuer, the Bank 1 not be authorized to utilize other funds of the Issuer on deposit with the Bank not specifically provided to the Bank for the purpose of payment of the Bonds. In the event the Bonds shall provide for a record date interest payment dates on which the registered owners of are to be determined for the purpose of receiving pay- mentsof interest Bonds, the Bank will promptly following such record date to prepare appropriate checks for payment of coming due the succeeding payment date at the rates - 5 - the terms specified in the Bond Ordinance, together with iate envelopes for the purpose of mailing such checks to owners of record of the Bonds. The Issuer agrees that it will endeavor to proviqeto the Bank collected funds for the purpose of making such paymer'lts not later than the earlier of the date on which such funds are required to be provided to the Bank under the terms of the Bond nance or the business day next preceding each such payment date. Provided that the Bank shall have been furnished with collected funds sufficient to make such payment, the Ea.nk shall mail the checks to the registered owners of the Bonds aforesaid later than the business day next preceding each such Payment of principal coming due on the Bonds at the thereof or prior thereto upon call for redemption sha d by the Bank to the registered owners thereof only upon tion and surrender of the Bonds with respect to which is to be made. Payments of principal of the Bonds will only to the registered owners of the Bonds, unless such Bonds rrendered for payment accompanied by assignments appropriate to effect transfer to the person to whom such payment is to made. In the event Bonds are surrendered payment with any such instruments of transfer, the Bank shall feet such transfer in the same manner as other Bonds are to be effected prior to making payment transferee. 9. All Bonds which have been delivered to the Bank for trans r exchange shall, upon issuance of Bonds effecting such or exchange, be cancelled by the Bank but retained by the - 6 - in its pos:;;es:sioJ.'l; provided, that at any time all such led bonds may be delivered by the Bank to the Issuer and a ificate pertaining to such cancelled bonds shall be so delivered to Iss.uerfrom time to time as the Issuer may request. 10. In addition to the obligation of the Bank to notify the bondowners of an optional call for redemption of the Bonds as provided in the Bond Ordinance, further notice shall be given by the Bond Registrar on behalf of the Issuer as set out below, but no defect in said r notice nor any failure to give all or any portion of such further notice shall in any manner negate the effectiveness of a call for redemption if notice thereof is given as prescribed in the Bond Ordinance. (a) Each r notice of redemption given hereunder shall contain the information required for the official notice of redemption as set forth in the Bond Ordinance plus (i) the CUSIP numbers of all Bonds being redeemed; (ii) the bond date of the Bonds; (iii) the rate of interest borne by each Bond to be redeemed; (iv) the maturity date of each Bond to be redeemed; and (v) any other descr information needed to identify accurately the Bonds redeemed. (b) Each fu notice of redemption shall be sent at ty-five (35) days prior to the redemption date by or certi mail or overnight delivery service to one e of the r securities depositories then in the business of holding substantial amounts of obligations of the types comprising and to one or more of the national information services then in the business of disseminating notices - 7 - ion of obligations of the types comprising the Bonds as the Dep9$itory Trust Company of New York, New York and Informat vice, New York, New York, respectively). (c) further notice of redemption shall be pub- lished one time t thirty (30) days prior to the redemption date in The Bond Buyer or in such other financial newspaper or journal of general circulation in the City of New York, New York. ll. In the event the Bank shall receive any request or demand for inspec of any records of the Issuer maintained by the Bank under thi t, the Bank will promptly notify the Issuer of such r or demand, forward such request or demand (if made in wr to the Issuer and (unless directed to the cont%ary by any subpoena or similar process of a court or regulatory agency which the Bank believes to have jurisdiction, or unless the Bank shall be ised by its counsel that failure to permit such inspection may subject the Bank to liability) the Bank will permit or refuse to allow such inspection as the Issuer may direct. l2. In performance of its duties hereunder the Bank may apply to a designated officer of the Issuer for instructions and consult with counsel for the Issuer in respect of any matter in connection with this agency, and the Bank shall not be or accountable for any action taken or omitted by it in good faith in accordance with such instructions or any such opinion of counsel. The Issuer shall reimburse the Bank for any incur the Bank hereunder, provided that such with counsel has been previously authorized by the - 8 - r or is reasonably necessary in order for the Bank to ne its responsibilities under this Agreement. 13. In the event that Bonds are presented to the Bank for transfer, registra~~on of transfer or exchange, or for payment of the ipal amount thereof at maturity or prior t.hereto upon call redemption, the Bank shall use reasonable diligence in determining whether ~uch Bonds are genuine, but shall not other- wise incur any liability by reaSon of the transfer, registration of transfer, exchange or payment of any such forged or illegally issued Bonds. 14. The I assumes full responsibility for and agrees to indemnify and hold the Bank harmless from and against any claims, demands, actions, causes of action or suits, whether groundless or otherwise, and from and against any and all losses, damages, charges, cqunsel fees, payments, expenses and liabilities of what- arising ly or indirectly out of the agency r ip c eunder so long as the Bank has acted in good faith and with reasonable diligence. The Bank shall not be under any obligat prosecute or defend any action or suit in respect of such agency relationship which, in the opinion of counsel to the Bank, may involve it in any expense or liability the Issuer shal:!., upon the request of the Bank, furnish the th indemn ly satisfactory to the Bank against such expenses liabilities. 15. The Bank shall be entitled to compensation for services rendered in performance its duties hereunder, in accordance with the Schedule of Pees attached hereto. The Issuer shall - 9 - re Bank for its out-of-pocket expenses incurred of its duties hereunder (including expenses of and lodging for any required travel outside the met area of Atlanta, Georgia in connection with any delivery of Bonds or performance of its other duties hereunder). Such fees and reimbursement of expenses shall be due and payable to the Bank from time to time periodically upon presentation of a written statement therefor. The Bank reserves the right to amend said Schedule of om time to time upon not less than thirty (30) days notice Issuer. The Bank shall not be obligated to allow and cr rest upon any moneys in respect of principal, inte premium, if any, due in respect to the Bonds, which it at any time receive under any of the provisions Bond Ordinance or this Agreement. Bank may resign the agency created under this t any time on not less than ninety (90) days written the Issuer, and the Issuer may terminate this agency at <':l.nytime upon noti the Bank. In the event of any such termination, the 11 deliver to the Issuer or to such successor or other blank Bonds then verified the Issuer may direct any inventory the Bank, together with originals or es of all records of the Bank s agency then in the possession of the Bank. such delivery of Bonds and records to the Issuer, the Bank no further tion hereunder except as may have arisen. any such termination, the Issuer shall rther on under this Agreement except to pay to - 10 - any fees and expenses incurred or accrued through the such termination which have not theretofore been paid, and ion l4hereof. as may have theretofore arisen or may thereafter arise the parties he l7. This Agreement constitutes the entire understanding of ith respect to the subject matter hereof, and may not be amended or modified except in writing signed by the parties hereto. IN WITNESS WHEREO~, the undersigned acting by and through their duly authorized officers have hereunto set their respective hands and seals as of the date and year first above written. (S E A L) Attest: BANK SOUTH, N.A. Atlanta, Georgia By: - II - Bank South BANK SOUTH, N.A. PAYING AGENT AND REGISTRAR FEE AGREEMENT FOR $3,510,000 CITY OF SMYRNA WATER AND SEWERAGE REVENUE BONDS, SERIES 1989 ACCOUNT ACCEPTANCE . . $750.00 . . .. . . . . (minimum of $1,000) . . . . . . . . . .. (per holder) (minimum of $500 per year) ACCOUNT MAINTENANCE. $ 4.25 Maintain holder me and address, share position and record of certificate issuance and cancellation, record address changes; placement of "stops" on lost or stolen certificate(s) CERTIFICATE ISSUANCE Review of legal aspects of transfer, actual production of certificate, authentication of transfer by Agent ORIGINAL ISSUANCE OF CERTIFICATES. (per certificate) TRANSFERS ROUTINE:. . . ... (per certificate) (minimum of $500 per year) PAYMENTS INTEREST CHECK ISSUANCE:. (per check) STOP PAYMENT{S)/REPLACEMENT CHECK(S): (per check) PRINCIPAL CHECK ISSUANCE: (per check) WITHHOLDING TAXES W-9 Forms:. .(per form) $ 1.50 $ 1.50 $ .25 $20.00 $ 8.50 $ .30 Certification (as required by law) of social Security Number or Tax Identification Number CALL NOTICES . (per holder) (4450A) Bank South, P.O_ Box 3144. Atlanta, GeorgIa 30302/(404} 529-4575 $ 1.50 Registrar & paying Agent Fee Schedule Page 2 Filing of Form 941: .(per form) $15.00 Payment to IRS of funds withheld from interest and/or principal MISCELLANEOOS HOLDERS' LIST. TRANSFERS STATEMENT CHECK REGISTER . . . . . . . ESS OF 4 PER YEAR . (each) (each) (each) (each) $40.00 $10.00 $50.00 $40.00 All out-of-pocket ~xpenses such as postage, envelopes, insurance, stationary, etc. will be paid by issuer. This schedule is effective for the current services of the Bank, and may be modified only upon revision by the Bank of its regularly published Schedule of Fees for services of the type contracted for, and such revision of the Schedule of Fees shall become effective 30 days after the mailing of a notice of the revision to the undersigned at the undersigned's address shown on the records of the Bank. Approved this day of , 19 BANK SOUTH, N.A. By: CITY OF SMYRNA By: Title: (4450A)