HomeMy WebLinkAboutItem 02 - c - Council Reading File - Continuing Disclosure Certificate_San Luis Obispo 2018 Water Revenue Bonds 4153-0337-9730 2OHS Draft 05/14/18
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CONTINUING DISCLOSURE CERTIFICATE
This Continuing Disclosure Certificate (the “Disclosure Certificate”) is executed and
delivered by the CITY OF SAN LUIS OBISPO, California (the “City”) in connection with the
execution and delivery of the City’s Water Revenue Refunding Bonds, Series 2018 (the “Bonds”).
The Bonds are being executed and delivered pursuant to an Indenture, dated as of _________,
2018 (the “Indenture”), by and between the City and U.S. Bank National Association, as trustee
(the “Trustee”). The City covenants and agrees 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 Securities and
Exchange Commission Rule 15c2-12(b)(5).
SECTION 2. Definitions. In addition to the definitions set forth in the Indenture, 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” shall mean any Annual Report provided by the City pursuant t o, and as
described in, Sections 3 and 4 of this Disclosure Certificate.
“Beneficial Owner” shall mean any person which has or shares the power, directly or
indirectly, to make investment decisions concerning the ownership of any Bonds (including
persons holding Bonds through nominees, depositories or other intermediaries).
“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.
As of the date of this Disclosure Certificate, the City has not appointed a separate Dissemination
Agent.
“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” shall mean any of the original underwriters of the Bonds
required to comply with the Rule in connection with offering of the Bonds.
“Report Date” means March 1 of each year.
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“Rule” shall mean 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.
“Significant Events” shall mean any of the events listed in Section 5(a) of this Disclosure
Certificate.
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 which is consistent
with the requirements of Section 4 of this Disclosure Certificate. Not later than 15 business days
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 Significant 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.
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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 any revision in the adopted rates and charges which
are generally imposed by the City upon users within the service area of the Water System;
(ii) total Net Revenues received by the City during the preceding fiscal year and
the amount by which such Net Revenues provide coverage for the payments of debt service
coming due in such fiscal year with respect to the Bonds, the Series 2012 Bonds, the Water
Reuse SRF Loan and any other Parity Obligations; and
(iii) for any customer whose total billings in the preceding fiscal year represent
10% or more of the Revenues of the Water System, (1) the total amount of Revenues
derived from such customer and (2) the percent of total Revenues represented by such
customer for such fiscal year.
(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.
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(a) The City shall give, or cause to be given, notice of the occurrence of any of the
following Significant 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.
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:
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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 Significant 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 Significant Event described in Section 5(a),
or determines that knowledge of a Significant 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
Significant Event described in subsections (a)(7) or (b)(3) need not be given under this subsection
any earlier than the notice (if any) of the underlying event is given to Holders of affected Bonds
pursuant to the Indenture.
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 (a) upon the legal defeasance, prior redemption or payment
in full of all of the Bonds or (b) if, in the opinion of nationally recognized bond counsel, the City
ceases to be an “obligated person” (within the meaning of the Rule) with respect to the Bonds or
the Bonds otherwise cease to be subject to the requirements of the Rule. If such termination occurs
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prior to the final maturity of the Bonds, the City shall give notice of such termination in the same
manner as for a Significant 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 Indenture for amendments to the Indenture 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
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
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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 Significant 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 Significant
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 Significant 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 Significant 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 Indenture, 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.
SECTION 13. Beneficiaries. This Disclosure Certificate shall inure solely to the benefit
of the City, the Dissemination Agent, the Participating Underwriters and Owners and Beneficial
Owners from time to time of the Bonds, and shall create no rights in any other person or entity.
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Date: _____________, 2018
CITY OF SAN LUIS OBISPO
By
Finance Director
EXHIBIT A
EXHIBIT A
FORM OF NOTICE TO THE MUNICIPAL SECURITIES RULEMAKING BOARD
OF FAILURE TO FILE ANNUAL REPORT
Name of Obligated
Person:
CITY OF SAN LUIS OBISPO
Name of Bond Issue: CITY OF SAN LUIS OBISPO, CALIFORNIA
Water Revenue Refunding Bonds,
Series 2018
Date of Issuance: __________, 2018
NOTICE IS HEREBY GIVEN that the City of San Luis Obispo, California, has not provided an
Annual Report with respect to the above-named Bonds as required by Section 3 of the
Continuing Disclosure Certificate of the City. The City anticipates that the Annual Report will
be filed by _____________.
Dated: _______________
CITY OF SAN LUIS OBISPO
By [to be signed only if filed
4153-0337-9730.2