HomeMy WebLinkAboutContinuing Disclosure Certificate - City of San Luis Obispo 2018 LRRB 4142-3640-2703 v4OH&S Draft 1/29/18
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CONTINUING DISCLOSURE CERTIFICATE
This Continuing Disclosure Certificate (this “Disclosure Certificate”) is executed and
delivered by the City of San Luis Obispo (the “City”), on behalf of itself and the San Luis
Obispo Public Financing Authority (the “Authority”), in connection with the issuance of the
Authority’s Lease Revenue Refunding Bonds, Series 2018 (the “Bonds”). The Bonds are being
issued under a Trust Agreement dated as of April 1, 2018 (the “Trust Agreement”) between the
Authority and U.S. Bank National Association, as trustee (the “Trustee”). The City covenants
and agrees, on behalf of itself and the Authority, as follows:
SECTION 1. Purpose of the Disclosure Certificate. This Disclosure Certificate is being
executed and delivered by the City for the benefit of the holders and beneficial owners of the
Bonds and in order to assist the Participating Underwriters in complying with S.E.C. Rule 15c2-
12(b)(5).
SECTION 2. Definitions. In addition to the definitions set forth in the Trust Agreement,
which apply to any capitalized term used in this Disclosure Certificate unless otherwise defined
in this Section, the following capitalized terms shall have the following meanings:
“Annual Report” means any Annual Report provided by the City under, and as described
in, Sections 3 and 4 of this Disclosure Certificate.
“Dissemination Agent” means the City or any successor Dissemination Agent designated
in writing by the City and which has filed with the City a written acceptance of such designation.
“Listed Events” means any of the events listed in Section 5(a) hereof.
“MSRB” means the Municipal Securities Rulemaking Board, which has been designated
by the Securities and Exchange Commission as the sole repository of disclosure information for
purposes of the Rule.
“Official Statement” means the final official statement dated [__________], 2018,
prepared with respect to the Bonds.
“Participating Underwriter” means the original underwriter of the Bonds required to
comply with the Rule in connection with offering of the Bonds.
“Report Date” means March 1 of each year.
“Rule” means Rule 15c2-12(b)(5) adopted by the Securities and Exchange Commission
under the Securities Exchange Act of 1934, as the same may be amended from time to time.
SECTION 3. Provision of Annual Reports.
(a) The City shall, or shall cause the Dissemination Agent to, not later than the Report
Date, commencing March 1, 2019, with the report for the 2017-18 fiscal year, provide to the
MSRB, in an electronic format as prescribed by the MSRB, an Annual Report that is consistent
with the requirements of Section 4 of this Disclosure Certificate. Not later than 15 Business Days
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prior to the Report Date, the City shall provide the Annual Report to the Dissemination Agent (if
other than the City). If by 15 business days prior to the Report Date the Dissemination Agent (if
other than the City) has not received a copy of the Annual Report, the Dissemination Agent shall
contact the City to determine if the City is in compliance with the previous sentence. The Annual
Report may be submitted as a single document or as separate documents comprising a package,
and may include by reference other information as provided in Section 4 of this Disclosure
Certificate; provided that the audited financial statements of the City may be submitted
separately from the balance of the Annual Report, and later than the Report Date if not available
by the Report Date. If the City’s fiscal year changes, it shall give notice of such change in the
same manner as for a Listed Event under Section 5(c). The City shall provide a written
certification with each Annual Report furnished to the Dissemination Agent to the effect that
such Annual Report constitutes the Annual Report required to be furnished by the City
hereunder.
(b) If the City does not provide (or cause the Dissemination Agent to provide) an Annual
Report by the Report Date, the City shall provide (or cause the Dissemination Agent to provide)
to the MSRB, in an electronic format as prescribed by the MSRB, a notice in substantially the
form attached as Exhibit A.
(c) With respect to each Annual Report, the Dissemination Agent shall:
(i) determine each year prior to the Report Date the then-applicable rules and
electronic format prescribed by the MSRB for the filing of annual continuing disclosure
reports; and
(ii) if the Dissemination Agent is other than the City, file a report with the
City certifying that the Annual Report has been provided pursuant to this Disclosure
Certificate, and stating the date it was provided.
SECTION 4. Content of Annual Reports. The City’s Annual Report shall contain or
incorporate by reference the following:
(a) Audited Financial Statements of the City prepared in accordance with generally
accepted accounting principles as promulgated to apply to governmental entities from time to
time by the Governmental Accounting Standards Board. If the City’s audited financial
statements are not available by the Report Date, the Annual Report shall contain unaudited
financial statements in a format similar to the financial statements contained in the final Official
Statement, and the audited financial statements shall be filed in the same manner as the Annual
Report when they become available.
(b) To the extent not contained in the audited financial statements filed under the
preceding clause (a), the Annual Report shall contain information showing:
(i) information concerning the actual revenues, expenditures and beginning
and ending fund balances relating to the General Fund of the City for the most recent
completed Fiscal Year;
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(ii) information showing the aggregate principal amount of long-term bonds,
leases and other obligations of the City which are payable out of the General Fund of the
City, as of the close of the most recent completed Fiscal Year;
(iii) information concerning the assessed valuation of properties within the
City for the most recent completed Fiscal Year;
(iv) information showing the total secured property tax levy and actual
amounts collected for the most recent completed Fiscal Year; and
(v) with respect to the top 10 property taxpayers in the City, information
showing the identity of each such taxpayer, and the total assessed valuation of properties
owned by each such taxpayer.
(c) In addition to any of the information expressly required to be provided under
paragraphs (a) and (b) of this Section, the City shall provide such further information, if any, as
may be necessary to make the specifically required statements, in the light of the circumstances
under which they are made, not misleading.
(d) Any or all of the items listed above may be included by specific reference to other
documents, including official statements of debt issues of the City or related public entities,
which are available to the public on the MSRB’s Internet web site or filed with the Securities and
Exchange Commission. The City shall clearly identify each such other document so included by
reference.
SECTION 5. Reporting of Significant Events.
(a) The City shall give, or cause to be given, notice of the occurrence of any of the
following Listed Events with respect to the Bonds in a timely manner not later than ten business
days after the occurrence of the event:
1. Principal and interest payment delinquencies;
2. Unscheduled draws on debt service reserves reflecting financial difficulties;
3. Unscheduled draws on credit enhancements reflecting financial difficulties;
4. Substitution of credit or liquidity providers, or their failure to perform;
5. Issuance by the Internal Revenue Service of proposed or final determination of
taxability or of a Notice of Proposed Issue (IRS Form 5701 TEB);
6. Tender offers;
7. Defeasances;
8. Rating changes; or
9. Bankruptcy, insolvency, receivership or similar event of the obligated person.
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Note: for the purposes of the event identified in subparagraph (9), the
event is considered to occur when any of the following occur: the
appointment of a receiver, fiscal agent or similar officer for an obligated
person in a proceeding under the U.S. Bankruptcy Code or in any other
proceeding under state or federal law in which a court or governmental
authority has assumed jurisdiction over substantially all of the assets or
business of the obligated person, or if such jurisdiction has been assumed
by leaving the existing governmental body and officials or officers in
possession but subject to the supervision and orders of a court or
governmental authority, or the entry of an order confirming a plan of
reorganization, arrangement or liquidation by a court or governmental
authority having supervision or jurisdiction over substantially all of the
assets or business of the obligated person.
(b) The City shall give, or cause to be given, notice of the occurrence of any of the
following events with respect to the Bonds, if material, in a timely manner not later than ten
business days after the occurrence of the event:
1. Unless described in paragraph 5(a)(5), adverse tax opinions or other material
notices or determinations by the Internal Revenue Service with respect to the tax
status of the Bonds or other material events affecting the tax status of the Bonds;
2. Modifications to rights of Bond holders;
3. Optional, unscheduled or contingent Bond calls;
4. Release, substitution, or sale of property securing repayment of the Bonds;
5. Non-payment related defaults;
6. The consummation of a merger, consolidation, or acquisition involving an
obligated person or the sale of all or substantially all of the assets of the obligated
person, other than in the ordinary course of business, the entry into a definitive
agreement to undertake such an action or the termination of a definitive
agreement relating to any such actions, other than pursuant to its terms; or
7. Appointment of a successor or additional trustee or the change of name of a
trustee.
(c) Whenever the City obtains knowledge of the occurrence of a Listed Event
described in Section 5(b), the City shall determine if such event would be material under
applicable federal securities laws.
(d) If the City learns of the occurrence of a Listed Event described in Section 5(a), or
determines that knowledge of a Listed Event described in Section 5(b) would be material under
applicable federal securities laws, the City shall within ten business days of occurrence file a
notice of such occurrence with the MSRB. Notwithstanding the foregoing, notice of the Listed
Event described in subsections (a)(7) or (b)(3) need not be given under this subsection any
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earlier than the notice (if any) of the underlying event is given to Holders of affected Bonds
pursuant to the Trust Agreement.
SECTION 6. Identifying Information for Filings with the MSRB. All documents provided
to the MSRB under the Disclosure Certificate shall be accompanied by identifying information
as prescribed by the MSRB.
SECTION 7. Termination of Reporting Obligation. The City’s obligations under this
Disclosure Certificate shall terminate upon the legal defeasance, prior redemption or payment in
full of all of the Bonds. If such termination occurs prior to the final maturity of the Bonds, the
City shall give notice of such termination in the same manner as for a Listed Event under Section
5(c).
SECTION 8. Dissemination Agent. The City may, from time to time, appoint or engage a
Dissemination Agent to assist it in carrying out its obligations under this Disclosure Certificate,
and may discharge any such Agent, with or without appointing a successor Dissemination Agent.
SECTION 9. Amendment; Waiver. Notwithstanding any other provision of this Disclosure
Certificate, the City may amend this Disclosure Certificate, and any provision of this Disclosure
Certificate may be waived, provided that the following conditions are satisfied:
(a) if the amendment or waiver relates to the provisions of Sections 3(a), 4 or 5(a), it
may only be made in connection with a change in circumstances that arises from a change in
legal requirements, change in law, or change in the identity, nature, or status of an obligated
person with respect to the Bonds, or type of business conducted;
(b) the undertakings herein, as proposed to be amended or waived, would, in the
opinion of nationally recognized bond counsel, have complied with the requirements of the Rule
at the time of the primary offering of the Bonds, after taking into account any amendments or
interpretations of the Rule, as well as any change in circumstances; and
(c) the proposed amendment or waiver either (i) is approved by holders of the Bonds
in the manner provided in the Trust Agreement for amendments to the Trust Agreement with the
consent of holders, or (ii) does not, in the opinion of the Trustee or nationally recognized bond
counsel, materially impair the interests of the holders or beneficial owners of the Bonds.
If the annual financial information or operating data to be provided in the Annual Report
is amended under the provisions hereof, the first annual financial information filed pursuant
hereto containing the amended operating data or financial information shall explain, in narrative
form, the reasons for the amendment and the impact of the change in the type of operating data
or financial information being provided.
If an amendment is made to the undertaking specifying the accounting principles to be
followed in preparing financial statements, the annual financial information for the year in which
the change is made shall present a comparison between the financial statements or information
prepared on the basis of the new accounting principles and those prepared on the basis of the
former accounting principles. The comparison shall include a qualitative discussion of the
differences in the accounting principles and the impact of the change in the accounting principles
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on the presentation of the financial information, in order to provide information to investors to
enable them to evaluate the ability of the City to meet its obligations. To the extent reasonably
feasible, the comparison shall be quantitative. A notice of the change in the accounting principles
shall be filed in the same manner as for a Listed Event under Section 5(c).
SECTION 10. Additional Information. Nothing in this Disclosure Certificate shall be
deemed to prevent the City from disseminating any other information, using the means of
dissemination set forth in this Disclosure Certificate or any other means of communication, or
including any other information in any Annual Report or notice of occurrence of a Listed Event,
in addition to that which is required by this Disclosure Certificate. If the City chooses to include
any information in any Annual Report or notice of occurrence of a Listed Event in addition to
that which is specifically required by this Disclosure Certificate, the City shall have no
obligation under this Disclosure Certificate to update such information or include it in any future
Annual Report or notice of occurrence of a Listed Event.
SECTION 11. Default. In the event of a failure of the City to comply with any provision of
this Disclosure Certificate any holder or beneficial owner of the Bonds may take such actions as
may be necessary and appropriate, including seeking mandate or specific performance by court
order, to cause the City to comply with its obligations under this Disclosure Certificate. A default
under this Disclosure Certificate shall not be deemed an Event of Default under the Trust
Agreement, and the sole remedy under this Disclosure Certificate in the event of any failure of
the City to comply with this Disclosure Certificate shall be an action to compel performance.
SECTION 12. Duties, Immunities and Liabilities of Dissemination Agent. The
Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure
Certificate, and the City agrees to indemnify and save the Dissemination Agent, its officers,
directors, employees and agents, harmless against any loss, expense and liabilities which it may
incur arising out of or in the exercise or performance of its powers and duties hereunder,
including the costs and expenses (including attorneys fees) of defending against any claim of
liability, but excluding liabilities due to the Dissemination Agent’s negligence or willful
misconduct. The obligations of the City under this Section shall survive resignation or removal
of the Dissemination Agent and payment of the Bonds.
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SECTION 13. Beneficiaries. This Disclosure Certificate shall inure solely to the benefit of
the City, the Dissemination Agent, the Participating Underwriters and holders and beneficial
owners from time to time of the Bonds, and shall create no rights in any other person or entity.
Date: [__________], 2018
CITY OF SAN LUIS OBISPO
By:
Treasurer
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CONTINUING DISCLOSURE EXHIBIT A
FORM OF NOTICE TO THE MUNICIPAL SECURITIES RULEMAKING BOARD
OF FAILURE TO FILE ANNUAL REPORT
Name of Issuer: SAN LUIS OBISPO PUBLIC FINANCING AUTHORITY
Name of Obligated
Person:
CITY OF SAN LUIS OBISPO
Name of Bond Issue: SAN LUIS OBISPO PUBLIC FINANCING AUTHORITY
Lease Revenue Refunding Bonds,
Series 2018
Date of Issuance: [__________], 2018
NOTICE IS HEREBY GIVEN that the Issuer has not provided an Annual Report with respect to
the above-named Bonds as required by Section 4 of the Continuing Disclosure Certificate of the
Issuer, dated the Date of Issuance. [The Issuer anticipates that the Annual Report will be filed by
_____________.]
Dated: _______________
CITY OF SAN LUIS OBISPO
By [to be signed only if filed]