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HomeMy WebLinkAboutOrdinance #1802ORDINANCE NUMBER 1$02 AN ORDINANCE of the City of Canton, Fulton County, Illinois, authorizing and providing for an Installment Purchase Agreement for the purpose of paying a part of the cost of a redevelopment project, and authorizing and providing for the issue of $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004, evidencing the rights to payment under such Agreement, prescribing the details of the Agreement and Certificates, and providing for the security for and means of payment under the Agreement of the Certificates. PREAMBLES WHEREAS A. The City of Canton, Fulton County, Illinois (the "City"), is a City and unit of local government of the State of Illinois (the "State ") operating, inter alia, under and pursuant to the following laws: 1. the Illinois Municipal Code (the "Municipal Code "); 2. the Local Government Debt Reform Act of the State of Illinois (the "Debt Reform Act"), and in particular, the provisions of Section 17 of the Debt Reform Act (the "Installment Purchase Provisions of the Debt Reform Act"); and 3. all other Omnibus Bond Acts of the State; in each case, as supplemented and amended (collectively, "Applicable Law "). B. The City Council (the "City Council ") has considered the needs of the City and, in so doing, the City Council has deemed and do now deem it advisable, necessary, and for the best interests of the City to undertake a redevelopment project in and near an abandoned manufacturing facility formerly owned and operated in the City by International Harvester (the "Plant") in order to address and ameliorate blighting conditions. C. To that end the City Council has heretofore authorized a feasibility study (the "Study ") to determine whether the Plant and other nearby parcels lying within the corporate limits of the City (collectively, the "Proposed Redevelopment Project Area ") qualify as a redevelopment project area pursuant to the Tax Increment Allocation Redevelopment Act, as amended (the "TIF Act"). D. The City Council has reviewed the Study and has heretofore, and it hereby expressly is, determined that the Proposed Redevelopment Project Area qualifies as a "blighted area" as defined in the TIF Act. E. The City Council has heretofore, and it hereby expressly is, found and determined that the Proposed Redevelopment Project Area on the whole has not been subject to growth and development through investment by private enterprise and would not reasonably be anticipated to be developed without the adoption of a redevelopment plan (the "Redevelopment Plan ") and project (the "Redevelopment Project") pursuant to the TIF Act. F. The City Council has heretofore, and it hereby expressly is, determined that it will be necessary to demolish the Plant in order to accomplish the redevelopment objectives of the City as contemplated by the Redevelopment Plan for the Proposed Redevelopment Project Area. G. The original estimate for the costs of demolition of the Plant was approximately $4,500,000. H. The City Council has been advised that demolition of the Plant will generate substantial quantities of salvageable steel, and, due to recent increases in the value of scrap steel, has heretofore, and it is hereby, determined that it is possible substantially to reduce said costs of demolition, and, to that end, has received a bid for demolition services (the "Service Agreement") from N.E. Finch in the amount of $1,163,000. I. The Service Agreement constitutes personal property, an eligible "redevelopment project cost" as defined in the TIF Act and a preliminary expenditure by the City, being made in anticipation of the approval of the Redevelopment Plan and the Redevelopment Project, -2- l designation of the Proposed Redevelopment Project Area, and adoption of tax increment allocation financing therefore. J. Acquisition of the Service Agreement, together with all mechanical, electrical, and other services necessary, useful, or advisable thereto (collectively, the "2004 Service Agreement"), all as shown on preliminary plans and cost estimates on file with the City Council, is desirable and necessary and in the best interests of the City and its residents. K. The City Council has heretofore, and it hereby expressly is, determined the total cost of the 2004 Service Agreement and expenses incidental thereto, including financial, legal, architectural, and engineering services related to such work and to the Agreement hereinafter provided for in this Ordinance (collectively "Related Expenses ") to be not less than $1,200,000 plus estimated investment earnings which may be received on said sum prior to disbursement. L. Sufficient funds of the City are not available to pay the costs of the 2004 Service Agreement and Related Expenses, and it will, therefore, be necessary to borrow money in the amount of $1,200,000 for the purpose of paying such costs. M. Pursuant to the Installment Purchase Provisions of the Debt Reform Act, as amended by Public Act 91-868 of the 91st General Assembly of the State of Illinois, the City has the powers as follows: The governing body of each governmental unit may purchase or lease either real or personal property, including investments, investment agreements, or investment services, through agreements that provide that the consideration for the purchase or lease may be paid through installments made at stated intervals for a period of no more than 20 years or another period of time authorized by law, whichever is greater. Each governmental unit may issue certificates evidencing the indebtedness incurred under the lease or agreement. The governing body may provide for the treasurer, comptroller, finance officer, or other officer of the governing body charged with financial administration to act as counter-party to any such lease or agreement, as nominee lessor or seller. When the lease or agreement is executed by the officer of -3- the governmental unit authorized by the governing body to bind the governmental unit thereon by the execution thereof and is filed with and executed by the nominee lessor or seller, the lease or agreement shall be sufficiently executed so as to permit the governmental unit to issue certificates evidencing the indebtedness incurred under the lease or agreement. The certificates shall be valid whether or not an appropriation with respect thereto is included in any annual or supplemental budget adopted by the governmental unit. From time to time, as the governing body executes contracts for the purpose of acquiring and constructing the services or real or personal property that is a part of the subject of the lease or agreement, including financial, legal, architectural, and engineering services related to the lease or agreement, the governing body shall order the contracts filed with its nominee officer, and that officer shall identify the contracts to the lease or agreement; that identification shall permit the payment of the contract from the proceeds of the certificates; and the nominee officer shall duly apply or cause to be applied proceeds of the certificates to the payment of the contracts. The governing body of each governmental unit may sell, lease, convey, and reacquire either real or personal property, or any interest in real or personal property, upon any terms and conditions and in any manner, as the governing body shall determine, if the governmental unit will lease, acquire by purchase agreement, or otherwise reacquire the property, as authorized by this subsection or any other applicable law. All indebtedness incurred under this subsection, when aggregated with the existing indebtedness of the governmental unit, may not exceed the debt limits provided by applicable law. N. The City Council find that it is desirable and in the best interests of the City to avail of the provisions of the Installment Purchase Provisions of the Debt Reform Act, as quoted, as follows: 1. To authorize an Installment Purchase Agreement (the "Agreement") more particularly as described and provided below in the text of this Ordinance; 2. To name as counter-party to the Agreement the City Treasurer (the "City Treasurer "), as nominee-seller; -4- 3. To authorize the Mayor of the City (the "Mayor ") and the City Clerk of the City (the "City Clerk") to execute and attest, respectively, the Agreement on behalf of the City and to authorize the Mayor, City Clerk and City Treasurer to file same with the City Clerk in his or her capacity as keeper of the records and files of the City; and 4. To issue certificates evidencing the indebtedness incurred under the Agreement in the amount of $1,200,000, in form and having such details as set forth below in the text of this Ordinance. Now THEREFORE Be It Ordained by the City Council of the City of Canton, Fulton County, Illinois, as follows: Section 1. Definitions. Words and terms used in this Ordinance shall have the meanings given them unless the context or use clearly indicates another or different meaning is intended. Words and terms defined in the singular may be used in the plural and vice-versa. Reference to any gender shall be deemed to include the other and also inanimate persons such as corporations, where applicable. A. The following words and terms are as defined in the preambles hereto. Applicable Law City City Clerk City Council -5- City Treasurer Debt Reform Act Installment Purchase Provisions of the Debt Reform Act Municipal Code Mayor Plant Proposed Redevelopment Project Area Redevelopment Plan Redevelopment Project Service Agreement 2004 Service Agreement Related Expenses State TIF Act B. The following words and terms are defined as set forth. "Agreement" means the Installment Purchase Agreement, as referred to in the preambles of this Ordinance, for the purpose of purchasing and financing the 2004 Service Agreement and Related Expenses. "Book Entry Form" means the form of the Certificates as fully registered and available in physical form only to the Depository. "Certificate Fund" means the fund established and defined in this Ordinance. "Certificate Moneys" means moneys on deposit in the Certificate Fund. "Certificate Register" means the books of the City kept by the Certificate Registrar to evidence the registration and transfer of the Certificates. -6- City Treasurer Debt Reform Act Installment Purchase Provisions of the Debt Reform Act Municipal Code Mayor Plant Proposed Redevelopment Project Area Redevelopment Plan Redevelopment Project Service Agreement 2004 Service Agreement Related Expenses State TIF Act B. The following words and terms are defined as set forth. "Agreement" means the Installment Purchase Agreement, as referred to in the preambles of this Ordinance, for the purpose of purchasing and financing the 2004 Service Agreement and Related Expenses. "Book Entry Form" means the form of the Certificates as fully registered and available in physical form only to the Depository. "Certificate Fund" means the fund established and defined in this Ordinance. "Certificate Moneys" means moneys on deposit in the Certificate Fund. "Certificate Register" means the books of the City kept by the Certificate Registrar to evidence the registration and transfer of the Certificates. -6- "Certificate Registrar" means MidAmerica National Bank, Canton, Illinois, in its respective capacities as certificate registrar and paying agent hereunder, or a successor thereto or a successor designated as Certificate Registrar hereunder. "Certificates" means the $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004, authorized to be issued by this Ordinance. "Code" means the Internal Revenue Code of 1986, as amended. "Depository" means The Depository Trust Company, a New York limited trust company, its successors, or a successor depository qualified to clear securities under applicable state and federal laws. "Designated Officers" means the Mayor, the City Clerk, City Treasurer and the City Manager, or successors or assigns, or any two of them acting together. "Ordinance" means this Ordinance, numbered as set forth on the title page hereof, and passed by the City Council on the 15thday of June, 2004. "2004 Service Agreement Fund" means the 2004 Service Agreement Fund established and defined in this Ordinance. "Purchase Price" means the price paid by the Purchaser for the Certificates, to-wit: $1,200,000.00. "Purchaser" means the purchaser of the Certificates, namely, MidAmerica National Bank, Canton, Illinois. "Record Date" means the 1st day of the month in which any regular or other interest payment date occurs on the fifteenth day of that month and the 15th day preceding any interest payment date occasioned by a redemption of Certificates on other than a regularly scheduled interest payment date. -7- "Tax-exempt" means, with respect to the Certificates, the status of interest paid and received thereon as not includible in the gross income of the owners thereof under the Code for federal income tax purposes except to the extent that such interest is taken into account in computing an adjustment used in determining the alternative minimum tax for certain corporations and in computing the "branch profits tax" imposed on certain foreign corporations. C. Definitions also appear in the preambles hereto or in specific sections, as appear below. The headings in this Ordinance are for the convenience of the reader and are not a part of this Ordinance. Section 2. Incorporation of Preambles. The City Council hereby find that the recitals contained in the preambles to this Ordinance are true, correct, and complete and does incorporate them into this Ordinance by this reference. Section 3. Determination to Authorize and Enter into Agreement and to Issue Certificates. It is necessary and advisable for the public health, safety, welfare, and convenience of residents of the City to pay the costs of acquisition of the 2004 Service Agreement, including all Related Expenses, and to borrow money and, in evidence thereof and for the purpose of financing same, enter into the Agreement and, further, to provide for the issuance and delivery of the Certificates evidencing the indebtedness incurred under the Agreement. Section 4. Agreement is a General Obligation; Annual Appropriation. The City hereby represents, warrants, and agrees that the obligation to make the payments due under the Agreement shall be a lawful direct general obligation of the City payable from the corporate funds of the City and such other sources of payment as are otherwise lawfully available. The City represents and warrants that the total amount due the Seller under the Agreement, together with all other indebtedness of the City, is within all statutory and constitutional debt limitations. -8- The City agrees to appropriate funds of the City annually and in a timely manner so as to provide for the making of all payments when due under the terms of the Agreement. Section 5. Execution and Filing of the Agreement. From and after the effective date of this Ordinance, the Mayor and City Clerk be and they are hereby authorized and directed to execute and attest, respectively, the Agreement, in substantially the form thereof set forth below in the text of this Ordinance, and to do all things necessary and essential to effectuate the provisions of the Agreement, including the execution of any documents and certificates incidental thereto or necessary to carry out the provisions thereof. Further, as nominee-seller, the Treasurer is hereby authorized and directed to execute the Agreement. Upon full execution, the original of the Agreement shall be filed with the City Clerk and retained in the City records and constitute authority for issuance of the Certificates. Subject to such discretion of the officers signatory to the document as described in the foregoing text, the Installment Purchase Agreement shall be in substantially the form as follows: -9- INSTALLMENT PURCHASE AGREEMENT for purchase of real or personal property, or both, for the purpose of undertaking a redevelopment project, in and for the City of Canton, Fulton County, Illinois. THIS INSTALLMENT PURCHASE AGREEMENT (this "Agreement") made as of thel5tn day of June, 2004 by and between the City Treasurer, as Nominee-Seller (the "Seller"), and the City of Canton, Fulton County, Illinois, a municipality of the State of Illinois (the "City "): WITNESSETH A. The City Council (the "City Council ") of the City has determined to enter into an agreement for demolition services, constituting personal property, in order to undertake a redevelopment project (collectively, the "2004 Service Agreement"), all as previously approved by the City Council and on file with the City Clerk of the City (the "City Clerk"). B. Pursuant to the provisions of the Illinois Municipal Code (the "Municipal Code")• the Local Government Debt Reform Act of the State of Illinois (the "Debt Reform Act"), and, in particular, the provisions of Section 17 of the Debt Reform Act (the "Installment Purchase Provisions of the Debt Reform Act"); and all other Omnibus Bond Acts of the State of Illinois; in each case, as supplemented and amended (collectively "Applicable Law "); the City has the power to purchase real or personal property through agreements that provide that the consideration for the purchase may be paid through installments made at stated intervals for a period of no more than 20 years and has the power to issue certificates evidencing indebtedness incurred under such agreements. C. On thel5th day of June, 2004, the City Council, pursuant to Applicable Law and the need to provide for the 2004 Service Agreement, adopted an ordinance (the "Ordinance ") authorizing the borrowing of money for the 2004 Service Agreement, the execution and delivery I-1 of this Agreement to finance same, and the issuance of certificates evidencing the indebtedness so incurred. D. The Ordinance is (a) incorporated herein by reference; and (b) made a part hereof as if set out at this place in full; and each of the terms as defined in the Ordinance is also incorporated by reference for use in this Agreement. E. The Seller, as nominee as expressly permitted by the Installment Purchase Provisions of the Debt Reform Act, has agreed to make and acquire the 2004 Service Agreement on the terms as hereinafter provided. Now TxEREFORE in consideration of the mutual covenants and agreements hereinafter contained and other valuable consideration, it is mutually agreed between the Seller and the City as follows: 1. MAKE, ACQUIRE AND CONSTRUCT 2004 SERVICE AGREEMENT The Seller agrees to make and acquire the 2004 Service Agreement to provide for services upon real estate owned or to be owned by or upon which valid easements or licenses have been obtained in favor of the City. 2. CONVEYANCE The Seller agrees to perform each part of the 2004 Service Agreement to the City and to perform all necessary work as set out therein and the City agrees to purchase the 2004 Service Agreement from the Seller and pay for the 2004 Service Agreement the purchase price thereof; plus the amount of investment earnings which are earned on the amount deposited with the Treasurer from the sale of the Certificates provided that in no event shall the total aggregate principal purchase price to be paid pursuant to this Agreement exceed the sum of $1,200,000, I-2 plus the amount of investment earnings which are earned on the amount deposited with the Treasurer from the sale of the Certificates. 3. PAYMENTS The payment of the entire sum of said purchase price [net, however, of any such investment earnings] shall: (a) be payable in installments due on the dates and in the amounts; (b) bear interest at the rates percent per annum which interest shall also be payable on the dates and in the amounts; (c) be payable at the place or places of payment, in the medium of payment, and upon such other term; all as provided for payment of the Certificates in the Ordinance. 4. ASSIGNMENT Rights to payment of the Seller as provided in this Agreement are assigned as a matter of law, under the Installment Purchase Provisions of the Debt Reform Act, to the owners of the Certificates. This Agreement and any right, title, or interest herein, shall not be further assignable. The Certificates, evidencing the indebtedness incurred hereby, are assignable (registrable) as provided in the Ordinance. $. TAX COVENANTS The covenants relating to the Tax-exempt status of the Certificates, as set forth in the Ordinance, insofar as may be applicable, apply to the work to be performed and the payments made under this Agreement. I-3 E). TITLE (a) Vesting of Title. Title in and to any part of the 2004 Service Agreement, upon delivery or as made, during all stages of the making or acquisition thereof, shall and does vest immediately in the City. (b) Voiding of Service Agreeement. If, during the term of this Agreement, all or any part of the 2004 Service Agreement shall be voided for any reason; then the City shall continue to make payments as promised herein and in the Certificates and to take such action as it shall deem necessary or appropriate to ratify the 2004 Service Agreement. 7. LAMFUL CORPORATE OBLIGATION The City hereby represents, warrants, and agrees that the obligation to make the payments due hereunder shall be a lawful direct general obligation of the City payable from the corporate funds of the City and such other sources of payment as are otherwise lawfully available. The City represents and warrants that the total amount due the Seller hereunder, together with all other indebtedness of the City, is within all statutory and constitutional debt limitations. The City agrees to appropriate funds of the City annually and in a timely manner so as to provide for the making of all payments when due under the terms of this Agreement. S. GENERAL COVENANT AND RECITAL It is hereby certified and recited by the Seller and the City, respectively, that as to each, respectively, for itself, all conditions, acts, and things required by law to exist or to be done precedent to and in the execution of this Agreement did exist, have happened, been done and performed in regular and due form and time as required by law. 9. NO SEPARATE TAX THE SELLER AND THE CITY RECOGNIZE THAT THERE IS NO STATUTORY AUTHORITY FOR THE LEVY OF A SEPARATE TAX IN ADDITION TO OTHER TAXES OF THE CITY OR THE LEVY OF A SPECIAL TAX UNLIMITED AS TO RATE OR AMOUNT TO PAY ANY OF THE AMOUNTS DUE HEREUNDER. I-4 I ~. DEFAULT In the event of a default in payment hereunder by the City, the Seller or any Certificateholder may pursue any available remedy by suit at law or equity to enforce the payment of all amounts due or to become due under this Agreement, including, without limitation, an action for specific performance. I-5 IN WITNESS WHEREOF the Seller has caused this Installment Purchase Agreement to be executed and attested, and his or her signature to be attested by the City Clerk of the City, and the City has caused this Installment Purchase Agreement to be executed by its Mayor, and also attested by its City Clerk, and the official seal of the City to be hereunto affixed, all as of the day and year first above written. C SELLER: Signature: [Here type name]: Patty Beaird Franzoni as Nominee-Seller and the City Treasurer ATTEST: r - City Jerk [SEAL] ATTEST: C Clerk [SEAL] CITY OF CANTON, )"~JLTON COUNTY, ILLINOIS Mayor I-6 STATE OF ILLINOIS ) ) SS COUNTY OF FULTON ) CERTIFICATE OF INSTALLMENT PURCHASE AGREEMENT FILING I, the undersigned, do hereby certify that I am the duly qualified and acting City Clerk of the City of Canton, Fulton County, Illinois (the "City"), and as such officer I do hereby certify that on thel5th day of June, 2004 there was filed in my office a properly certified copy of that certain document, executed by the Mayor of the City, attested by me in my capacity as City Clerk, and further executed, as Nominee-Seller, by the City Treasurer, also attested by me, dated the 15th day of June, 2004, and entitled "INSTALLMENT PURCHASE AGREEMENT for Purchase of real or personal property, or both, for the purpose of undertaking a redevelopment agreement, in and for the City of Canton, Fulton County, Illinois"; and supporting the issuance of certain General Obligation Limited Tax Debt Certificates, Series 2004, of the City; that attached hereto is a true and complete copy of said Agreement as so filed; and that the same has been deposited in the official files and records of my office. IN WITNESS WHEREOF I have hereunto affixed my official signature and the seal of the City of Canton, Fulton County, Illinois at Canton, Illinois, this 15th day of June, 2004. ~~nn ~- ~/ i City Clerk j [SEAL] Section 6. Certificate Details. For the purpose of providing for making and acquisition of the 2004 Service Agreement and Related Expenses, there shall be issued and sold the Certificates in the principal amount of $1,200,000. The Certificates shall each be designated "General Obligation Limited Tax Debt Certificate, Series 2004"; be dated June 15, 2004 (the "Dated Date "); and shall also bear the date of authentication thereof. The Certificates shall be in fully registered form, shall be in denominations of $5,000 or integral multiples thereof (but no single Certificate shall represent principal maturing on more than one date), and shall be numbered consecutively in such fashion as shall be determined by the Certificate Registrar. The Certificates shall become due (subject to right of redemption prior to maturity as hereinafter provided) on December 15 of the years and in the amounts and bearing interest at the rates percent per annum as follows: DATE AMOUNT ($~ RATE (%) 2009 1,200,000 3.04 Each Certificate shall bear interest from the later of its Dated Date or from the most recent interest payment date to which interest has been paid or duly provided for, until the principal amount of such Certificate is paid or duly provided for, such interest (computed upon the basis of a 360-day year of twelve 30-day months) being payable semi-annually on June 15 and December 15 of each year, commencing on December 15, 2004. Interest on each Certificate shall be paid by check or draft of the Certificate Registrar, payable upon presentation thereof in lawful money of the United States of America, to the person in whose name such Certificate is registered at the close of business on the applicable Record Date, and mailed to the registered owner of the Certificate at the address as shown in the Certificate Registrar or at such other address furnished in writing by such registered owner or as otherwise agreed by the City and the Certificate Registrar and a qualified securities clearing corporation as depository, or nominee, for -8- so long as this Certificate shall be in Book Entry Form as provided for same. The principal of the Certificates shall be payable in lawful money of the United States of America upon presentation thereof at the office maintained for such purpose of the Certificate Registrar as currently maintained, as may be relocated from time to time, or at successor Certificate Registrar and locality. Section 7. Book Entry Provisions. If so specified by the Purchaser, the Certificates shall be initially issued in the form of a separate single fully registered Certificate for each of the maturities of the Certificates, and the following provisions shall apply. Upon initial issuance, the ownership of each such Certificate shall be registered in the Certificate Register in the name of the Depository or a designee or nominee of the Depository (such depository or nominee being the "Book Entry Owner"). Except as otherwise expressly provided, all of the outstanding Certificates from time to time shall be registered in the Certificate Register in the name of the Book Entry Owner (and accordingly in Book Entry Form as such term is used in this Ordinance). Any City officer, as representative of the City, is hereby authorized, empowered, and directed to execute and deliver or to utilize a previously executed and delivered Letter of Representations or Blanket Letter of Representations (either being the "Letter of Representations") substantially in the form common in the industry, or with such changes therein as any officer executing the Letter of Representations on behalf of the City shall approve, his or her execution thereof to constitute conclusive evidence of approval of such changes, as shall be necessary to effectuate Book Entry Form. Without limiting the generality of the authority given with respect to entering into such Letter of Representations, it may contain provisions relating to (a) payment procedures, (b) transfers of the Certificates or of beneficial interests therein, (c) redemption notices and procedures unique to the Depository, (d) additional notices or communications, and (e) amendment from time to time to conform with changing customs and practices with respect -9- to securities industry transfer and payment practices. With respect to Certificates registered in the Certificate Register in the name of the Book Entry Owner, none of the City, any of its financial officers, or the Certificate Registrar shall have any responsibility or obligation to any broker-dealer, bank, or other financial institution for which the Depository holds Certificates from time to time as securities depository (each such broker~.iealer, bank, or other financial institution being referred to herein as a "Depository Participant") or to any person on behalf of whom such a Depository Participant holds an interest in the Certificates. Without limiting the meaning of the immediately preceding sentence, the City, any of its financial officers, and the Certificate Registrar shall have no responsibility or obligation with respect to (a) the accuracy of the records of the Depository, the Book Entry Owner, or any Depository Participant with respect to any ownership interest in the Certificates, (b) the delivery to any Depository Participant or any other person, other than a registered owner of a Certificate as shown in the Certificate Register or as otherwise expressly provided in the Letter of Representations, of any notice with respect to the Certificates, including any notice of redemption, or (c) the payment to any Depository Participant or any other person, other than a registered owner of a Certificate as shown in the Certificate Register, of any amount with respect to principal of or interest on the Certificates. No person other than a registered owner of a Certificate as shown in the Certificate Register shall receive a certificate with respect to any Certificate. In the event that (a) the City determines that the Depository is incapable of discharging its responsibilities described herein and in the Letter of Representations, (b) the agreement among the City, the Certificate Registrar, and the Depository evidenced by the Letter of Representations shall be terminated for any reason, or (c) the City determines that it is in the best interests of the City or of the beneficial owners of the Certificates either that they be able to obtain certificated Certificates or that another depository is preferable, the City shall notify the Depository, and the Depository shall notify the Depository -10- Participants, of the availability of physical Certificates; and the Certificates shall no longer be restricted to being registered in the Certificate Register in the name of the Book Entry Owner. Alternatively, at such time, the City may determine that the Certificates shall be registered in the name of and deposited with a successor depository operating a system accommodating Book Entry Form, as may be acceptable to the City, or such depository's agent or designee, but if the City does not select such alternate book entry system, then the Certificates shall be registered in whatever name or names registered owners of Certificates transferring or exchanging Certificates shall designate, in accordance with the provisions of this Ordinance. Section 8. Execution; Authentication. The Certificates shall be executed on behalf of the City by the manual or duly authorized facsimile signature of its Mayor and attested by the manual or duly authorized facsimile signature of its City Clerk, as they may determine, and shall have impressed or imprinted thereon the corporate seal or facsimile thereof of the City. In case any such officer whose signature shall appear on any Certificate shall cease to be such officer before the delivery of such Certificate, such signature shall nevertheless be valid and sufficient for all purposes, the same as if such officer had remained in office until delivery. All Certificates shall have thereon a certificate of authentication, substantially in the form hereinafter set forth, duly executed by the Certificate Registrar as authenticating agent of the City and showing the date of authentication. No Certificate shall be valid or obligatory for any purpose or be entitled to any security or benefit under this Ordinance unless and until such certificate of authentication shall have been duly executed by the Certificate Registrar by manual signature, and such certificate of authentication upon any such Certificate shall be conclusive evidence that such Certificate has been authenticated and delivered under this Ordinance. The certificate of authentication on any Certificate shall be deemed to have been executed by it if signed by an -11- authorized officer of the Certificate Registrar, but it shall not be necessary that the same officer sign the certificate of authentication on all of the Certificates issued hereunder. Section 9. Registration of Certificates; Persons Treated as Owners. The City shall cause the Certificate Register to be kept at the office maintained for such purpose by the Certificate Registrar, which is hereby constituted and appointed the registrar of the City for the Certificates. The City is authorized to prepare, and the Certificate Registrar or such other agent as the City may designate shall keep custody of, multiple Certificate blanks executed by the City for use in the transfer and exchange of Certificates. Any Certificate may be transferred or exchanged, but only in the manner, subject to the limitations, and upon payment of the charges as set forth in this Ordinance. Upon surrender for transfer or exchange of any Certificate at the office of the Certificate Registrar maintained for the purpose, duly endorsed by or accompanied by a written instrument or instruments of transfer or exchange in form satisfactory to the Certificate Registrar and duly executed by the registered owner or an attorney for such owner duly authorized in writing, the City shall execute and the Certificate Registrar shall authenticate, date, and deliver in the name of the transferee or transferees or, in the case of an exchange, the registered owner, a new fully registered Certificate or Certificates of like tenor, of the same maturity, bearing the same interest rate, of authorized denominations, for a like aggregate principal amount and bearing the same provisions for redemption. The Certificate Registrar shall not be required to transfer or exchange any Certificate during the period from the close of business on the Record Date for an interest payment to the opening of business on such interest payment date or during the period of 15 days preceding the giving of notice of redemption of Certificates or to transfer or exchange any Certificate all or a portion of which has been called for redemption. The execution by the City of any fully registered Certificate shall constitute full and due authorization of such Certificate; and the Certificate Registrar shall thereby be -12- authorized to authenticate, date, and deliver such Certificate; provided, however, the principal amount of Certificates of each maturity authenticated by the Certificate Registrar shall not at any one time exceed the authorized principal amount of Certificates for such maturity less the amount of such Certificates which have been paid. The person in whose name any Certificate shall be registered shall be deemed and regarded as the absolute owner thereof for all purposes, and payment of the principal of or interest on any Certificate shall be made only to or upon the order of the registered owner thereof or his legal representative. All such payments shall be valid and effectual to satisfy and discharge the liability upon such Certificate to the extent of the sum or sums so paid. No service charge shall be made to any registered owner of Certificates for any transfer or exchange of Certificates, but the City or the Certificate Registrar may require payment of a sum sufficient to cover any tax or other governmental charge that may be imposed in connection with any transfer or exchange of Certificates, but the City or the Certificate Registrar may require payment of a sum sufficient to cover any tax or other governmental charge that may be imposed in connection with any transfer or exchange of Certificates, except in the case of the issuance of a Certificate or Certificates for the unredeemed portion of a Certificate surrendered for redemption. Section 10. Redemption. The Certificates are subject to redemption prior to maturity at the option of the City, from any available moneys, on any date, in whole or in part, and if in part in such principal amounts and from such maturities as the City shall determine and within any maturity by lot, at a redemption price of par plus accrued interest to the date fixed for redemption. Section 11. Redemption Procedure. The Certificates shall be redeemed only in the maturity amount of $5,000 and integral multiples thereof. The City shall, at least forty-five (45) days prior to the redemption date (unless a shorter time period shall be satisfactory to the -13- Certificate Registrar) notify the Certificate Registrar of such redemption date and of the maturity amount and maturity or maturities of Certificates to be redeemed. For purposes of any redemption of less than all of the outstanding Certificates of a single maturity, the particular Certificates or portions of Certificates to be redeemed shall be selected by lot not more than sixty (60) days prior to the redemption date by the Certificate Registrar, by such method of lottery as the Certificate Registrar shall deem fair and appropriate; provided that such lottery shall provide for the selection for redemption of Certificates or portions of Certificates in Maturity Amounts of $5,000 and integral multiples thereof. The Certificate Registrar shall promptly notify the City in writing of the Certificates or portions of Certificates selected for redemption and, in the case of any Certificate selected for partial redemption, the Maturity Amount thereof to be redeemed. Section I1. Redemption Procedure. Unless waived by any holder of Certificates to be redeemed, notice of the call for any such redemption shall be given by the Certificate Registrar on behalf of the City by mailing the redemption notice by first class mail at least thirty (30) days and not more than sixty (60) days prior to the date fixed for redemption to the registered owner of the Certificate or Certificates to be redeemed at the address shown on the Certificate Register or at such other address as is furnished in writing by such registered owner to the Certificate Registrar. All notices of redemption shall state: (1) the redemption date, (2) the redemption price, (3) if less than all outstanding Certificates are to be redeemed, the identification (and, in the case of partial redemption, the respective Maturity Amounts) of the Certificates to be redeemed, -14- (4) that on the redemption date the redemption price will become due and payable upon each such Certificate or portion thereof called for redemption, and that interest thereon shall cease to accrue from and after said date, (5) the place where such Certificates are to be surrendered for payment of the redemption price, which place of payment shall be the principal corporate trust office of the Certificate Registrar maintained for such purpose, and (6) such other information then required by custom, practice or industry standard. Prior to any redemption date, the City shall deposit with the Certificate Registrar an amount of money sufficient to pay the redemption price of all the Certificates or portions of Certificates which are to be redeemed on that date. Notice of redemption having been given as aforesaid, the Certificates or portions of Certificates so to be redeemed shall, on the redemption date, become due and payable at the redemption price therein specified, and from and after such date (unless the City shall default in the payment of the redemption price) such Certificates or portions of Certificates shall cease to bear interest. Upon surrender of such Certificates for redemption in accordance with said notice, such Certificates shall be paid by the Certificate Registrar at the redemption price. Installments of interest due on or prior to the redemption date shall be payable as herein provided for payment of interest. Upon surrender for any partial redemption of any Certificate, there shall be prepared for the registered holder a new Certificate or Certificates of the same Maturity Amount. If any Certificate or portion of Certificate called for redemption shall not be so paid upon surrender thereof for redemption, the principal shall, until paid, bear interest from the redemption date at the rate borne by such Certificate or portion of Certificate so called for redemption. All Certificates which have been redeemed shall be cancelled and destroyed by the Certificate Registrar and shall not be reissued. -15- Section 12. Form of Certificate. The Certificates shall be in substantially the form hereinafter set forth; provided, however, that if the text of the Certificates is to be printed in its entirety on the front side of the Certificates, then the second paragraph on the front side and the legend "See Reverse Side for Additional Provisions" shall be omitted and the text of paragraphs set forth for the reverse side shall be inserted immediately after the first paragraph. -16- [FORM OF CERTIFICATE -FRONT SIDE] REGISTERED REGISTERED No. $ UNITED STATES OF AMERICA STATE OF ILLINOIS COUNTY OF FULTON GENERAL OBLIGATION LIMITED TAX DEBT CERTIFICATE, SERIES 2004 See Reverse Side for Additional Provisions. Interest Maturity Rate: Date: December 15, Registered Owner: CEDE & Co. Principal Amount: Dated Date: June 15, 2004 CUSIP: KNOW ALL PERSONS BY THESE PRESENTS that the City Of Canton, Fulton County, Illinois, a municipality and political subdivision of the State of Illinois (the "City "), hereby acknowledges itself to owe and for value received promises to pay (subject to right of prior redemption as hereinafter provided) from the source and as hereinafter provided to the Registered Owner identified above, or registered assigns, on the Maturity Date identified above (subject to right of prior redemption), the Principal Amount identified above and to pay interest (computed on the basis of a 360-day year of twelve 30-day months) on such Principal Amount from the later of the Dated Date of this Certificate identified above or from the most recent interest payment date to which interest has been paid or duly provided for, at the Interest Rate per annum identified above, such interest to be payable semi-annually on June 15 and December 15 of each year, commencing December 15, 2004, until said Principal Amount is paid or duly provided for. The principal of this Certificate is payable in lawful money of the United States of America upon presentation hereof at the office maintained for such purpose of MidAmerica National Bank, Canton, Illinois, as paying agent and registrar (the "Certificate Registrar"). Payment of interest shall be made to the Registered Owner hereof as shown on the registration books of the City -17- maintained by the Certificate Registrar at the close of business on the applicable Record Date (the "Record Date "). The Record Date shall be the 1st day of the month in which any regular or other interest payment date occurs on the fifteenth day of that month and the 15th day preceding any interest payment date occasioned by a redemption of Certificates on other than a regularly scheduled interest payment date. Interest shall be paid by check or draft of the Certificate Registrar, payable upon presentation in lawful money of the United States of America, mailed to the address of such Registered Owner as it appears on such registration books or at such other address furnished in writing by such Registered Owner to the Certificate Registrar, or as otherwise agreed by the City and the Certificate Registrar and a qualified securities clearing corporation as depository, or nominee, for so long as this Certificate shall be in Book Entry Form as provided for same. Reference is hereby made to the further provisions of this Certificate set forth on the reverse hereof, and such further provisions shall for all purposes have the same effect as if set forth at this place. It is hereby certified and recited that all conditions, acts, and things required by the Constitution and Laws of the State of Illinois to exist or to be done precedent to and in the issuance of this Certificate, including Applicable Law as defined herein, have existed and have been properly done, happened, and been performed in regular and due form and time as required by law; that the obligation to make payments due hereon are a lawful direct general obligation of the City payable from the corporate funds of the City and such other sources of payment as are otherwise lawfully available; that the total amount due under the Agreement, represented by the Certificates, together with all other indebtedness of the City, is within all statutory and constitutional debt limitations; and that the City shall appropriate funds annually and in a timely manner so as to provide for the making of all payments hereon when due. TxE owrrER of Tars -18- CERTIFICATE ACKNOWLEDGES THAT THERE IS NO STATUTORY AUTHORITY FOR THE LEVY OF A SEPARATE TAX IN ADDITION TO OTHER TAXES OF THE CITY OR THE LEVY OF A SPECIAL TAX UNLIMITED AS TO RATE OR AMOUNT TO PAY ANY OF THE AMOUNTS DUE HEREUNDER. This Certificate shall not be valid or become obligatory for any purpose until the certificate of authentication hereon shall have been signed by the Certificate Registrar. IN WITNESS WHEREOF the City of Canton, Fulton County, Illinois, by its City Council, has caused this Certificate to be executed by the manual or duly authorized facsimile signature of its Mayor and attested by the manual or duly authorized facsimile signature of its City Clerk and its corporate seal or a facsimile thereof to be impressed or reproduced hereon, all as appearing hereon and as of the Dated Date identified above. ATTEST: City Clerk, City of Canton, ulton County, Illinois [SEAL] Ma r, City f Canton, Fulton County, Illinois -19- Date of Authentication: CERTIFICATE OF AUTHENTICATION Certificate Registrar and Paying Agent: This Certificate is one of the Certificates described in the within-mentioned Ordinance and is one of the General Obligation Limited Tax Debt Certificates, Series 2004, having a Dated Date of June 15, 2004, of the City of Canton, Fulton County, Illinois. MidAmerica National Bank, as Certificate Registrar By Authorized Officer MidAmerica National Bank, Canton, Illinois [FORM OF CERTIFICATE -REVERSE SIDE] This Certificate is one of a series (the "Certificates") in the aggregate principal amount of $1,200,000 issued by the City for the purpose of providing funds to pay part of the cost of making and acquiring the 2004 Service Agreement and Related Expenses, all as described and defined in the ordinance authorizing the Certificates (the "Ordinance "), pursuant to and in all respects in compliance with the applicable provisions of the City Code of the State of Illinois, as supplemented and amended, and in particular as supplemented by the Local Government Debt Reform Act of the State of Illinois, as amended, and the other Omnibus Bond Acts of the State of Illinois ("Applicable Law "), and with the Ordinance, which has been duly passed by the City Council of the City on the 15tH day of June, 2004, in all respects as by law required. The Certificates issued by the City in connection with the 2004 Service Agreement have been issued in evidence of the indebtedness incurred pursuant to a certain Installment Purchase Agreement (the "Agreement"), dated as of thel5th day of June, 2004, entered into by and between the City and its City Treasurer, as Seller-Nominee, to which reference is hereby expressly made for -20- further definitions and terms and to all the provisions of which the holder by the acceptance of this Certificate assents. The Certificates are subject to redemption prior to maturity at the option of the City, from any available moneys, on any date, in whole or in part and if in part, in such principal amounts and from such maturities as the City shall determine and within any maturity by lot, at a redemption price of par plus accrued interest to the date fixed for redemption, and as otherwise provided in the Ordinance. This Certificate is subject to provisions relating to registration, transfer, and exchange and such other terms and provisions relating to security and payment as are set forth in the Ordinance; to which reference is hereby expressly made; and to all the terms of which the registered owner hereof is hereby notified and shall be subject. The City and the Certificate Registrar may deem and treat the Registered Owner hereof as the absolute owner hereof for the purpose of receiving payment of or on account of principal hereof and interest due hereon and for all other purposes, and neither the City nor the Certificate Registrar shall be affected by any notice to the contrary. This Certificate is a "qualified tax exempt obligation" under the provisions of Section 265(b)(3) of the Internal Revenue Code of 1986, as amended. ASSIGNMENT FOR VALUE RECEIVED, the undersigned sells, assigns and transfers unto [Here insert identifying number such as TID, SSN, or other] (Name and Address of Assignee) the within Certificate and does hereby irrevocably constitute and appoint -21- as attorney to transfer the said Certificate on the books kept for registration thereof with full power of substitution in the premises. Dated: Signature guaranteed: NOTICE: The signature to this assignment must correspond with the name of the ,Registered Owner as it appears upon the face of the within Certificate in every particular, without alteration or enlargement or any change whatever. Section 13. Sale of Certificates; Official Statement. The City Treasurer is hereby expressly authorized to issue and deliver the Certificates to the Purchaser upon receipt of the Purchase Price without further official action by or approval of the City Council. It is hereby expressly determined that the contract for the sale of the Certificates (the "Purchase Contract") is in all respects ratified, approved and confirmed, it being hereby found and determined that the Certificates are being sold at such price and bearing interest at such rates that neither the true interest cost (yield) nor the net interest rate received upon such sale shall exceed the maximum rate otherwise authorized by Illinois law, that the Purchase Contract is in the best interests of the City and that no person holding any office of the City, either by election or appointment, is in any manner financially interested directly in his or her own name or indirectly in the name of any other person, association, trust or corporation, in the Purchase Contract. The use by the Purchaser of any Preliminary Official Statement and any final Official Statement relating to the Certificates and before the City Council at the time of the adoption hereof is hereby ratified, approved and authorized; the execution and delivery of said final Official Statement is hereby authorized; and the officers of the City Council are hereby authorized to take any action as may be required on the part of the City to consummate the transactions contemplated by the Purchase Contract, this Ordinance, said Preliminary Official Statement, said final Official Statement and the Certificates. -22- Section 14. Creation of Funds and Appropriations. A. There is hereby created the "General Obligation Limited Tax Debt Certificates, Series 2004, Certificate Fund" (the "Certificate Fund "), which shall be the fund for the payment of the principal of and interest on the Certificates. Accrued interest and premium, if any, received upon delivery of the Certificates shall be deposited into the Certificate Fund and be applied to pay the first interest coming due on the Certificates. Funds lawfully available for the purpose shall be deposited into the Certificate Fund and used solely and only for the purpose of paying the principal of and interest on the Certificates. Interest income or investment profit earned in the Certificate Fund shall be retained in the Certificate Fund for payment of the principal of or interest on the Certificates on the interest payment date next after such interest or profit is received or, to the extent lawful and as determined by the City Council, transferred to such other fund as may be determined. Moneys in the Certificate Fund shall be applied to pay interest when due and principal when due at maturity. B. The amount necessary from the proceeds of the Certificates shall be used either to pay expenses directly at the time of issuance of the Certificates or be deposited into a separate fund, hereby created, designated the "Expense Fund," to be used to pay expenses of issuance of the Certificates. Disbursements from such fund shall be made from time to time as necessary. Moneys not disbursed from the Expense Fund within six (6) months shall be transferred by the appropriate financial officers for deposit into the 2004 Service Agreement Fund, -and any deficiencies in the Expense Fund shall be paid by disbursement from the 2004 Service Agreement Fund. C. The remaining proceeds of the Certificates shall be deposited into the 2004 Service Agreement Fund (the "2004 Service Agreement Fund") hereby created. Moneys in the 2004 -23- Service Agreement Fund shall be used to pay costs of the 2004 Service Agreement in accordance with the following procedures: 1. Contracts ("Work Contracts") have been or shall be awarded, from time to time, by the City Council for the work on the 2004 Service Agreement; and the City Council represents and covenants that each Work Contract has been or will be let in strict accordance with Applicable Law and the rules and procedures of the City for same. 2. Pursuant to ordinance or resolution to be duly adopted, the City Council shall identify all or a designated portion of each Work Contract to the Agreement. This Ordinance and any such further ordinance or resolution shall be filed of record with the City Clerk and the City Treasurer. The adoption and filing of any such ordinance or resolution and the Work Contracts with such officers shall constitute authority for the officer or officers of the City to make disbursements from the 2004 Service Agreement Fund to pay amounts due under such Work Contracts from time to time, upon such further resolutions, orders, vouchers, warrants, or other proceedings as are required under Applicable Law and the rules and procedures of the City for same. No action need be taken by or with respect to the contractors under the Work Contracts as, pursuant to the Installment Purchase Provisions of the Debt Reform Act, the City Treasurer acts as Nominee-Seller of the 2004 Service Agreement for all purposes, enabling the issuance of the Certificates. Funds on deposit in the 2004 Service Agreement Fund shall be invested by the appropriate officers of the City in any lawful manner. Investment earnings shall first be reserved and transferred to such other account as and to the extent necessary to pay any "excess arbitrage profits" or "penalty in lieu of rebate" under Code Section 148 to maintain the Tax-exempt status of the Certificates, and the remainder shall be retained in the fund for costs of the 2004 Service Agreement. Within sixty (60) days after full -24- depletion of the 2004 Service Agreement Fund, the appropriate offices of the City shall certify to the City Council the fact of such depletion; and, upon approval of such certification by the City Council, the 2004 Service Agreement Fund shall be closed. D. Alternatively to the creation of the funds described above, the appropriate officers may allocate the Certificate Moneys or proceeds of the Certificates to one or more related funds of the City already in existence and in accordance with good accounting practice; provided, however, that this shall not relieve such officers of the duty to account and invest the Certificate Moneys and the proceeds of the Certificates, as herein provided, as if such funds had in fact been created. Section 1 S. Non-Arbitrage and Tax-Exemption. One purpose of this Section is to set forth various facts regarding the Certificates and to establish the expectations of the City Council and the City as to future events regarding the Certificates and the use of Certificate proceeds. The certifications, covenants and representations contained herein and at the time of the Closing are made on behalf of the City for the benefit of the owners from time to time of the Certificates. In addition to providing the certifications, covenants and representations contained herein, the City hereby covenants that it will not take any action, omit to take any action or permit the taking or omission of any action within its control (including, without limitation, making or permitting any use of the proceeds of the Certificates) if taking, permitting or omitting to take such action would cause any of the Certificates to be an arbitrage bond or a private activity bond within the meaning of the Code or would otherwise cause the interest on the Certificates to be included in the gross income of the recipients thereof for federal income tax purposes. The City acknowledges that, in the event of an examination by the Internal Revenue Service of the exemption from Federal income taxation for interest paid on the Certificates, under present rules, -25- the City is treated as the "taxpayer" in such examination. The City Council and the City certify, covenant and represent as follows: 1.1. Definitions. In addition to such other words and terms used and defined in this Installment Contract, the following words and terms used in this Section shall have the following meanings unless, in either case, the context or use clearly indicates another or different meaning is intended: "Bond Counsel" means Chapman and Cutler LLP or any other nationally recognized firm of attorneys experienced in the field of municipal bonds whose opinions are generally accepted by purchasers of municipal securities. "Capital Expenditures" means costs of a type that would be properly chargeable to a capital account under the Code (or would be so chargeable with a proper election) under federal income tax principles if the City were treated as a corporation subject to federal income taxation, taking into account the definition of Placed-in-Service set forth herein. "Closing" means the first date on which the City is receiving the purchase price for the Certificates. "Code" means the Internal Revenue Code of 1986, as amended. "Commingled Fund" means any fund or account containing both Gross Proceeds and an amount in excess of $25,000 that are not Gross Proceeds if the amounts in the fund or account are invested and accounted for, collectively, without regard to the source of funds deposited in the fund or account. An open-ended regulated investment company under Section 851 of the Code is not a commingled fund. "Control" means the possession, directly or indirectly through others, of either of the following discretionary and non-ministerial rights or powers over another entity: (a) to approve and to remove without cause a controlling portion of the governing body of a Controlled Entity; or (b) to require the use of funds or assets of a Controlled Entity for any purpose. "Controlled Entity" means any entity or one of a group of entities that is subject to Control by a Controlling Entity or group of Controlling Entities. "Controlling Entity" means any entity or one of a group of entities directly or indirectly having Control of any entities or group of entities. -26- "Controlled Group" means a group of entities directly or indirectly subject to Control by the same entity or group of entities, including the entity that has the Control of the other entities. "Costs of Issuance" means the costs of issuing the Certificates, including underwriters' discount and legal fees. "De minimis Amount of Original Issue Discount or Premium" means (a) any original issue discount or premium that does not exceed two percent of the stated redemption price at maturity of the Certificates plus (b) any original issue premium that is attributable exclusively to reasonable underwriter's compensation. "External Commingled Fund" means a Commingled Fund in which the City and all members of the same Controlled Group as the City own, in the aggregate, not more than ten percent of the beneficial interests. "GIC" means (a) any investment that has specifically negotiated withdrawal or reinvestment provisions and a specifically negotiated interest rate and (b) any agreement to supply investments on two or more future dates (e.g., a forward supply contract). "Gross Proceeds" means amounts in the Certificate Fund and the 2004 Service Agreement Fund. "Placed-in-Service" means the date on which, based on all facts and circumstances (a) a facility has reached a degree of completion that would permit its operation at substantially its design level and (b) the facility is, in fact, in operation at such level. "Qualified Administrative Costs of Investments" means (a) reasonable, direct administrative costs (other than carrying costs) such as separately stated brokerage or selling commissions (other than a broker's commission paid on behalf of either the City or the provider of a GIC to the extent such commission exceeds the present value of annual payments equal to 0.05 percent of the weighted average amount reasonably expected to be invested each year of the term of the GIC; for this purpose, present value is computed using the taxable discount rate used to compute the commission or, if not readily ascertainable, a reasonable taxable discount rate), but not legal and accounting fees, recordkeeping, custody and similar costs; (b) all administrative costs, direct or indirect, incurred by a publicly offered regulated investment company or an External Commingled Fund; or (c) in the case of purpose investments, costs or expenses paid directly to purchase, carry, sell or retire the investment and costs of issuing, carrying, or repaying the Certificates, and any placement agent fee or underwriter's discount. "Qualified Tax Exempt Obligations" means (a) any obligation described in Section 103(x) of the Code, the interest on which is excludable from gross income of the owner thereof for federal income tax purposes and is not an item of tax preference for purposes of the alternative minimum tax imposed by Section 55 of the Code; (b) an -27- interest in a regulated investment company to the extent that at least ninety-five percent of the income to the holder of the interest is interest which is excludable from gross income under Section 103 of the Code of any owner thereof for federal income tax purposes and is not an item of tax preference for purposes of the alternative minimum tax imposed by Section 55 of the Code; and (c) certificates of indebtedness issued by the United States Treasury pursuant to the Demand Deposit State and Local Government Series program described in 31 C.F.R. part 344. "Rebate Fund" means the fund, if any, identified and defined in paragraph 4.1 herein. "Rebate Provisions" means the rebate requirements contained in Section 148(f) of the Code and in the Regulations. "Regulations" means United States Treasury Regulations dealing with the tax- exempt Certificate provisions of the Code. "Reimbursed Expenditures" means amounts, if any, used from Sale Proceeds or investment earnings thereon to reimburse the City for an expenditure paid prior to Closing. "Sale Proceeds" means amounts actually or constructively received from the sale of the Certificates, including (a) amounts used to pay underwriters' discount or compensation and accrued interest, other than accrued interest for a period not greater than one year before Closing but only if it is to be paid within one year after Closing and (b) amounts derived from the sale of any right that is part of the terms of a Certificate or is otherwise associated with a Certificate (e.g., a redemption right). "Sale Proceeds Funds" means the funds containing amounts derived by the sale of the Certificates or investment earnings thereon. "Yield" means that discount rate which when used in computing the present value of all payments of principal and interest paid and to be paid on an obligation (using semiannual compounding on the basis of a 360-day year) produces an amount equal to the obligation's purchase price (or in the case of the Certificates, the issue price as established in paragraph 5.1 hereof), including accrued interest. "Yield Reduction Payment" means a rebate payment or any other amount paid to the United States in the same manner as rebate amounts are required to be paid or at such other time or in such manner as the Internal Revenue Service may prescribe that will be treated as a reduction in Yield of an investment under the Regulations. 2.1. Purpose of the Certificates. The Certificates are being issued to finance the 2004 Service Agreement in a prudent manner consistent with the revenue needs of the City. A breakdown of the sources and uses of funds is set forth in the preceding Section of this Ordinance. At least 75% of the sum of (i) Sale Proceeds plus (ii) investment -28- earnings thereon, less (iii) Costs of Issuance paid from Sale Proceeds or investment earnings thereon, less (iv) Sale Proceeds or investment earnings thereon deposited in a reasonably required reserve or replacement fund, are expected to be used for construction purposes with respect to property owned by a governmental unit or a Section 501(c)(3) organization. 2.2. The 2004 Service Agreement -Binding Commitment and Timing. The City has incurred or will, within six months of the Closing, incur a substantial binding obligation (not subject to contingencies within the control of the City or any member of the same Controlled Group as the City) to a third party to expend at least five percent of the Sale Proceeds on the 2004 Service Agreement. It is expected that all Sale Proceeds and investment earnings thereon will have been spent by January 1, 2005. The investment earnings on the 2004 Service Agreement Fund will be spent to pay costs of the 2004 Service Agreement and interest on the Certificates not later than the date set forth in the preceding paragraph, the investment earnings on the Certificate Fund will be spent to pay interest on the Certificates, or to the extent permitted by law, investment earnings on amounts in the 2004 Service Agreement Fund and the Certificate Fund will be commingled with substantial revenues from the governmental operations of the City, and the earnings are reasonably expected to be spent for governmental purposes within six months of the date earned. Interest earnings on the 2004 Service Agreement Fund and the Certificate Fund have not been earmarked or restricted by the City Council for a designated purpose. No proceeds of the Certificates will be used more than 30 days after the date of issue of the Certificates for the purpose of paying any principal or interest on any issue of Certificates, notes, certificates or warrants or on any installment contract or other obligation of the City or for the purpose of replacing any funds of the City used for such purpose. 2.3. Reimbursement. None of the Sale Proceeds or investment earnings thereon will be used for Reimbursed Expenditures. 2.4. Working Capital. All amounts in the Sale Proceeds Funds will be used, directly or indirectly, to finance Capital Expenditures other than the following: (a) an amount not to exceed five percent of the Sale Proceeds for working capital expenditures directly related to Capital Expenditures financed by the Certificates; (b) payments of interest on the Certificates for a period commencing at Closing and ending on the later of the date three years after Closing or one year after the date on which the 2004 Service Agreement is Placed-in-Service; (c) Costs of Issuance and Qualified Administrative Costs of Investments; -29- (d) payments of rebate or Yield Reduction Payments made to the United States under the Regulations; and (e) principal of or interest on the Certificates paid from unexpected excess Sale Proceeds and investment earnings thereon. 2.5. Consequences of Contrary Expenditure. The City acknowledges that if amounts in the Sale Proceeds Funds and investment earnings thereon are spent for non- Capital Expenditures other than as permitted by paragraph 2.4 hereof, a like amount of then available funds of the City will be treated as unspent Sale Proceeds. 2.6. Investment of Certificate Proceeds. Not more than 50% of the Sale Proceeds and investment earnings thereon are or will be invested in investments (other than Qualified Tax Exempt Obligations) having a Yield that is substantially guaranteed for four years or more. No portion of the Certificates is being issued solely for the purpose of investing a portion of Sale Proceeds or investment earnings thereon at a Yield higher than the Yield on the Certificates. 2.7. No Grants. None of the Sale Proceeds or investment earnings thereon will be used to make grants to any person. 2.8. Hedges. Neither the City nor any member of the same Controlled Group as the City has entered into or expects to enter into any hedge (e.g., an interest rate swap, interest rate cap, futures contract, forward contract or an option) with respect to the Certificates. The City acknowledges that any such hedge could affect the calculation of Certificate Yield under the Regulations, and that the Internal Revenue Service could recalculate Certificate Yield if the failure to account for the hedge fails to clearly reflect the economic substance of the transaction. 3.1. Use of Proceeds. (a) The use of the Sale Proceeds and investment earnings thereon and the funds held under the Ordinance at the time of Closing are described in the preceding Section of this Installment Contract. (b) Only the funds and accounts described in said Section will be funded at Closing. There are no other funds or accounts created under this Installment Contract. (c) Principal of and interest on the Certificates will be paid from the Certificate Fund. (d) Any Costs of Issuance incurred in connection with the Certificates to be paid by the City will be paid from the 2004 Service Agreement Fund. (e) The costs of the 2004 Service Agreement will be paid from the 2004 Service Agreement Fund and no other moneys (except for investment earnings on amounts in the 2004 Service Agreement Fund) are expected to be deposited therein. -30- 3.2. Purpose of Certificate Fund. The Certificate Fund will be used primarily to achieve a proper matching of revenues and earnings with principal and interest payments on the Certificates in each Certificate year. It is expected that the Certificate Fund will be depleted at least once a year, except for a reasonable carry over amount not to exceed the greater of (a) the earnings on the investment of moneys in the Certificate Fund for the immediately preceding Certificate year or (b) 1/12th of the principal and interest payments on the Certificates for the immediately preceding Certificate year. 3.3. No Other Gross Proceeds. (a) Except for the Certificate Fund and the 2004 Service Agreement Fund, and except for investment earnings that have been commingled as described in paragraph 2.2, the Credit Facility and any other credit enhancement or liquidity device related to the Certificates, after the issuance of the Certificates, neither the City nor any member of the same Controlled Group as the City has or will have any property, including cash or securities that constitutes: (i) Sale Proceeds; (ii) amounts in any fund and account with respect to the Certificates (other than the Rebate Fund); (iii) amounts that have a sufficiently direct nexus to the Certificates or to the governmental purpose of the Certificates to conclude that the amounts would have been used for that governmental purpose if the Certificates were not used or to be used for that governmental purpose (the mere availability or preliminary earmarking of such amounts for a governmental purpose, however, does not itself establish such a sufficient nexus); (iv) amounts in a debt service fund, redemption fund, reserve fund, replacement fund or any similar fund to the extent reasonably expected to be used directly or indirectly to pay principal of or interest on the Certificates or any amounts for which there is provided, directly or indirectly, a reasonable assurance that the amount will be available to pay principal of or interest on the Certificates or any obligations under any credit enhancement or liquidity device with respect to the Certificates, even if the City encounters financial difficulties; (v) any amounts held pursuant to any agreement (such as an agreement to maintain certain levels of types of assets) made for the benefit of the Certificateholders, or any credit enhancement provider, including any liquidity device or negative pledge (any amount pledged to pay principal of or interest on an issue held under an agreement to maintain the amount at a particular level for the direct or indirect benefit of Certificateholders, the Credit Facility Provider or any other guarantor of the Certificates); or (vi) amounts actually or constructively received from the investment and reinvestment of the amounts described in (i) or (ii) above. -31- (b) No compensating balance, liquidity account, negative pledge of property held for investment purposes or similar arrangement exists with respect to, in any way, the Certificates or any credit enhancement or liquidity device related to the Certificates. (c) The term of the Certificates is not longer than is reasonably necessary for the governmental purposes of the Certificates. The Principal Payment Schedule is not more rapid (i.e., having a lower average maturity) because a more rapid schedule would place an undue burden on tax rates and cause such rates to be increased beyond prudent levels, and would be inconsistent with the governmental purpose of the Certificates as set forth in paragraph 2.1 hereof. 4.1. Rebate Fund. The City is hereby authorized to create and establish a special fund to be known as the Rebate Fund (the "Rebate Fund"), which, if created, shall be continuously held, invested, expended and accounted for in accordance with this Installment Contact. Moneys in the Rebate Fund shall not be considered moneys held for the benefit of the Certificateholders. Except as provided in the Regulations, moneys in the Rebate Fund (including earnings and deposits .therein) shall be held in trust for payment to the United States as required by the Rebate Provisions and by the Regulations and as contemplated under the provisions of this Installment Contract. 4.2. Compliance with Rebate Provisions. The City covenants to take such actions and make, or cause to be made, all calculations, transfers and payments that may be necessary to comply with the Rebate Provisions applicable to the Certificates. The City will make, or cause to be made, rebate payments with respect to the Certificates in accordance with law. 4.3. Records. The City agrees to keep and retain or cause to be kept and retained until six years after the Certificates are paid in full adequate records with respect to the investment of all Gross Proceeds and amounts in the Rebate Fund. Such records shall include: (a) purchase price; (b) purchase date; (c) type of investment; (d) accrued interest paid; (e) interest rate; (f) principal amount; (g) maturity date; (h) interest payment date; (i) date of liquidation; and (j) receipt upon liquidation. If any investment becomes Gross Proceeds on a date other than the date such investment is purchased, the records required to be kept shall include the fair market value of such investment on the date it becomes Gross Proceeds. If any investment is retained after the date the last Certificate is retired, the records required to be kept shall include the fair market value of such investment on the date the last Certificate is retired. Amounts or investments will be segregated whenever necessary to maintain these records. 4.4. Prohibited Payments; Certificates of Deposit and Investment Agreements. In making investments of Gross Proceeds, the City shall take into account prudent investment standards including the date on which moneys to be invested may be needed. The City shall provide that all amounts which constitute Gross Proceeds and any amounts in the Rebate Fund shall be invested at all times to the greatest extent practicable in -32- investments permitted under this Installment Contract, and no amounts may be held as cash or be invested in zero Yield investments other than obligations of the United States purchased directly from the United States; provided, however, that in the event moneys cannot be invested, other than as provided in this sentence, due to the denomination, price or availability of investments, such amounts shall be invested in an interest bearing deposit account of a bank with a Yield not less than that paid to the general public or held uninvested (but uninvested amounts shall be held to the minimum amount necessary). For purposes of determining the purchase price of investments (for either yield restriction or rebate purposes), Gross Proceeds and any amounts in the Rebate Fund that are invested in certificates of deposit or in GICs shall be invested only in accordance with the following provisions: (a) Investments in certificates of deposit of banks or savings and loan associations that have a fixed interest rate, fixed payment schedules and substantial penalties for early withdrawal shall be made only if either (i) the Yield on the certificate of deposit (A) is not less than the Yield on reasonably comparable direct obligations of the United States and (B) is not less than the highest Yield that is published or posted by the provider to be currently available from the provider on reasonably comparable certificates of deposit offered to the public or (ii) the investment is an investment in a GIC and qualifies under paragraph (b) below. (b) Investments in GICs shall be made only if (i) the bid specifications are in writing, include all material terms of the bid and are timely forwarded to potential providers (a term is material if it may directly or indirectly affect the yield on the GIC); (ii) the terms of the bid specifications are commercially reasonable (a term is commercially reasonable if there is a legitimate business purpose for the term other than to reduce the yield on the GIC); (iii) all bidders for the GIC have equal opportunity to bid so that, for example, no bidder is given the opportunity to review others bids (a last look) before bidding; (iv) any agent used to conduct the bidding for the GIC does not bid to provide the GIC; (v) at least three of the providers solicited for bids for the GIC are reasonably competitive providers of investments of the type purchased (i.e., providers that have established industry reputations as competitive providers of the type of investments being purchased); -33- (vi) at least three of the entities that submit a bid do not have a financial interest in the Certificates; (vii) at least one of the entities that provided a bid is a reasonably competitive provider that does not have a financial interest in the Certificates; (viii) the bid specifications include a statement .notifying potential providers that submission of a bid is a representation that the potential provider did not consult with any other provider about its bid, that the bid was determined without regard to any other formal or informal agreement that the potential provider has with the City or any other person (whether or not in connection with the Certificates) and that the bid is not being submitted solely as a courtesy to the City or any other person for purposes of satisfying the federal income tax requirements relating to the bidding for the GIC; (ix) the determination of the terms of the GIC takes into account the reasonably expected deposit and drawdown schedule for the amounts to be invested; (x) the highest-yielding GIC for which a qualifying bid is made (determined net of broker's fees) is in fact purchased; and (xi) the obligor on the GIC certifies the administrative costs that it is paying or expects to pay to third parties in connection with the GIC. (c) If a GIC is purchased, the City will retain the following records with its Certificate documents until three years after the Certificates are redeemed in their entirety: (i) a copy of the GIC; (ii) the receipt or other record of the amount actually paid for the GIC, including a record of any administrative costs paid, and the certification under paragraph (b)(xi) of this section; (iii) for each bid that is submitted, the name of the person and entity submitting the bid, the time and date of the bid, and the bid results; and (iv) the bid solicitation form and, if the terms of the GIC deviated from the bid solicitation form or a submitted bid is modified, a brief statement explaining the deviation and stating the purpose for the deviation. -34- Moneys to be rebated to the United States shall be invested to mature on or prior to the anticipated rebate payment date. All investments made with Gross Proceeds or amounts in the Rebate Fund shall be bought and sold at fair market value. The fair market value of an investment is the price at which a willing buyer would purchase the investment from a willing seller in a bona fide, arm's length transaction. Except for investments specifically described in this section and United States Treasury obligations that are purchased directly from the United States Treasury, only investments that are traded on an established securities market, within the meaning of regulations promulgated under Section 1273 of the Code, will be purchased with Gross Proceeds. In general, an "established securities market" includes: (i) property that is listed on a national securities exchange, an interdealer quotation system or certain foreign exchanges; (ii) property that is traded on a Commodities Futures Trading Commission designated City Council of trade or an interbank market; (iii) property that appears on a quotation medium; and (iv) property for which price quotations are readily available from dealers and brokers. A debt instrument is not treated as traded on an established market solely because it is convertible into property which is so traded. An investment of Gross Proceeds in an External Commingled Fund shall be made only to the extent that such investment is made without an intent to reduce the amount to be rebated to the United States Government or to create a smaller profit or a larger loss than would have resulted if the transaction had been at arm's length and had the rebate or Yield restriction requirements not been relevant to the City. An investment of Gross Proceeds shall be made in a Commingled Fund other than an External Commingled Fund only if the investments made by such Commingled Fund satisfy the provisions of this paragraph. The foregoing provisions of this paragraph- 4.4 satisfy various safe harbors set forth in the Regulations relating to the valuation of certain types of investments. The safe harbor provisions of this paragraph 4.4 are contained herein for the protection of the City, who has covenanted not to take any action to adversely affect the tax-exempt status of the interest on the Certificates. The City will contact Bond Counsel if it does not wish to comply with the provisions of this paragraph 4.4 and forego the protection provided by the safe harbors provided herein. 4.5. Arbitrage Elections. The Mayor, City Clerk and Treasurer of the City Council are hereby authorized to execute one or more elections regarding certain matters with respect to arbitrage. 5.1. Issue Price. For purposes of determining the Yield on the Certificates, the purchase price of the Certificates is equal to the first offering price at which the Purchaser sold at least ten percent of each maturity of the Certificates or is equal to par, plus accrued interest, if the Purchaser does not intend to resell the Certificates. 5.2. Yield Limits. (a) Except as provided in paragraph (b) or (c), all Gross Proceeds shall be invested at market prices and at a Yield (after taking into account any -35- Yield Reduction Payments) not in excess of the Yield on the Certificates plus, for amounts in the 2004 Service Agreement Fund only, 1/8th of one percent. (b) The following may be invested without Yield restriction: (i) amounts invested in Qualified Tax Exempt Obligations (to the extent permitted by the Act and this Installment Contract); (ii) amounts in the Rebate. Fund; (iii) amounts on deposit in the Certificate Fund (except for capitalized interest) that have not been on deposit under the Ordinance for more than 13 months, so long as the Certificate Fund continues to qualify as a bona fide debt service fund as described in paragraph 3.2 hereof; (iv) amounts on deposit in the 2004 Service Agreement Fund prior to the earlier of three years after Closing or the completion (or abandonment) of the 2004 Service Agreement; (v) amounts in the Certificate Fund to be used to pay capitalized interest on the Certificates prior to the earlier of three years after Closing or the payment of all capitalized interest; (vi) all amounts other than Sale Proceeds for the first 30 days after they become Gross Proceeds; and (vii) all amounts derived from the investment of Sale Proceeds or investment earnings thereon for a period of one year from the date received. (c) An amount not to exceed the lesser of $100,000 or five percent of the Sale Proceeds may be invested without regard to Yield restriction. 5.3. Continuing Nature of Yield Limits. Except as provided in paragraph 7.6, once moneys are subject to the Yield limits of paragraph 5.2 hereof, such moneys remain Yield restricted until they cease to be Gross Proceeds. 5.4. Federal Guarantees. Except for investments meeting the requirements of paragraph 5.2(b) hereof, investments of Gross Proceeds shall not be made in (a) investments constituting obligations of or guaranteed, directly or indirectly, by the United States (except obligations of the United States Treasury, obligations guaranteed by the Federal Housing Administration, the Federal National Mortgage Association, the Federal Home Loan Mortgage Corporation, the Government National Mortgage Association, the Student Loan Marketing Association, any guarantee by the Bonneville Power Authority pursuant to the Northwest Power Act (16 U.S.C. 839d) as in effect on the date of enactment of the Tax Reform Act of 1984, or investments in obligations issued pursuant to Section 21B(d)(3) of the Federal Home Loan Bank, as amended (e.g., -36- Refcorp Strips)); or (b) federally insured deposits or accounts (as defined in Section 149(b)(4)(B) of the Code). Except as permitted in the immediately prior sentence and in the Regulations, no portion of the payment of principal or interest on the Certificates or any credit enhancement or liquidity device relating to the foregoing is or will be guaranteed, directly or indirectly (in whole or in part), by the United States (or any agency or instrumentality thereof). No portion of the Gross Proceeds has been or will be used to make loans the payment of principal or interest with respect to which is or will be guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof). 6.1. Payment and Use Tests. (a) The payment of more than five percent of the principal of or the interest on the Certificates will not be, directly or indirectly (i) secured by any interest in (A) property used or to be used in any activity carried on by any person other than a state or local governmental unit or (B) payments in respect of such property or (ii) on a present value basis, derived from payments (whether or not to the City or a member of the same Controlled Group as the City) in respect of property, or borrowed money, used or to be used in any activity carried on by any person other than a state or local governmental unit. (b) No more than the lesser of five percent of the Sale Proceeds and investment earnings thereon or $5,000,000 will be used, directly or indirectly, to make or finance loans to any persons. (c) No user of the 2004 Service Agreement other than a state or local governmental unit will use more than five percent of the 2004 Service Agreement, in the aggregate, on any basis other than the same basis as the general public; and no person other than a state or local governmental unit .will be a user of more than five percent of the 2004 Service Agreement, in the aggregate, as a result of (i) ownership, (ii) actual or beneficial use pursuant to a lease or a management, service, incentive payment, research or output contract, or (iii) any other similar arrangement, agreement or understanding, whether written or oral. (d) No more than the lesser of five percent of the proceeds of the- Certificates or $5,000,000 have been or will be used to provide professional sports facilities. For purposes of this paragraph, the term "professional sports facilities" (i) means real property or related improvements used for professional sports exhibitions, games or training, regardless of whether the admission of the public or press is allowed or paid and (ii) includes any use of a facility that generates a direct or indirect monetary benefit (other than reimbursement for out-of-pocket expenses) for a person who uses such facilities for professional sport exhibitions, games or training. 6.2. I.R.S. Form 8038-G. The information contained in the Information Return for Tax-Exempt Governmental Obligations, Form 8038 ~, is true and complete. The City will file Form 8038-G (and all other required information reporting forms) in a timely manner. -37- 6.3. Bank Qualification. (a) The City hereby designates each of the Certificates as a "qualified tax-exempt obligation" for the purposes and within the meaning of Section 265(b)(3) of the Code. In support of such designation, the City hereby certifies that (i) none of the Certificates will be at anytime a "private activity bond" (as defined in Section 141 of the Code) other than a "qualified 501(c)(3) bond" (as defined in Section 145 of the Code), (ii) as of the date hereof, the City has not issued any tax-exempt obligations of any kind in calendar year 2004 other than the Certificates nor have any tax-exempt obligations of any kind been issued on behalf of the City and (iii) not more than $10,000,000 of obligations of any kind (including the Certificates) issued by or on behalf of the City during calendar year 2004 will be designated for purposes of Section 265(b)(3) of the Code. (b) The City is not subject to Control by any entity, and there are no entities subject to Control by the City. (c) On the date hereof, the City does not reasonably anticipate that for calendar year 2004 it will issue any Section 265 Tax-Exempt Obligations (other than the Certificates), or that any Section 265 Tax-Exempt Obligations will be issued on behalf of it. "Section 265 Tax-Exempt Obligations" are obligations the interest on which is excludable from gross income of the owners thereof under Section 103 of the Code, except for private activity bonds other than qualified 501(c)(3) bonds, both as defined in Section 141 of the Code. The City will not issue or permit the issuance on behalf of it or by any entity subject to Control by the City (which may hereafter come into existence) of Section 265 Tax-Exempt Obligations (including the Certificates) that exceed the aggregate amount of $10,000,000 during calendar year 2004 unless it first obtains an opinion of Bond Counsel to the effect that such issuance will not adversely affect the treatment of the Certificates as "qualified tax-exempt obligations" for the purposes and within the meaning of Section 265(b)(3) of the Code. 7.1. Termination; Interest of City in Rebate Fund. The terms and provisions set forth in this Section shall terminate at the later of (a) 75 days after the Certificates have been fully paid and retired or (b) the date on which all amounts remaining on deposit in the Rebate Fund, if any, shall have been paid to or upon the order of the United States and any other payments required to satisfy the Rebate Provisions of the Code have been made to the United States. Notwithstanding the foregoing, the provisions of paragraph 4.3 hereof shall not terminate until the sixth anniversary of the date the Certificates are fully paid and retired. 7.2. No Common Plan of Financing. Since a date that is 15 days prior to the date of sale of the Certificates by the City to the Purchaser, neither the City nor any member of the same Controlled Group as the City has sold or delivered any obligations other than the Certificates that are reasonably expected to be paid out of substantially the same source of funds as the Certificates. Neither the City nor any member of the same Controlled Group as the City will sell or deliver within 15 days after the date hereof any obligations other than the Certificates that are reasonably expected to be paid out of substantially the same source of funds as the Certificates. No obligation other than the -38- Certificates were sold on the same date as the Certificates, are being issued on the date of the Closing and were or are being offered pursuant to a single offering document. 7.3. Reserved. 7.4. Reserved. 7.5. Future Events. The City acknowledges that any changes in facts or expectations from those set forth herein may result in different Yield restrictions or rebate requirements from those set forth herein. Such changes in facts or expectations might include, but are not in any respect whatsoever limited to, moneys or investments being pledged or otherwise set aside for payment of principal of or interest on the Certificates, amounts being derived from the sale of any right that is part of the terms of a Certificate or is otherwise associated with a Certificate (e.g., a redemption right), the City entering into any agreement to maintain certain levels of types of assets for the benefit of a holder of a Certificate or any credit enhancement with respect to the Certificates or the sale of any Certificate-financed property. The City shall promptly contact Bond Counsel if such changes do occur. 7.6. Permitted Changes; Opinion of Bond Counsel. The Yield restrictions contained in paragraph 5.2 or any other restriction or covenant contained herein need not be observed or may be changed if the City receives an opinion of Bond Counsel to the effect that such nonobservance or change will not result in the loss of any exemption for the purpose of federal income taxation to which interest on the Certificates is otherwise entitled. 7.7. Successors and Assigns. The terms, provisions, covenants and conditions of this Section shall bind and inure to the benefit of the respective successors and assigns of the City Council and the City. 7.8. Expectations. The City Council has reviewed the facts, estimates and circumstances in existence on the date of issuance of the Certificates. Such facts, estimates and circumstances, together with the expectations of the City as to future events, are set forth in summary form in this Section. Such facts and estimates are true and are not incomplete in any material respect. On the basis of the facts and estimates contained herein, the City has adopted the expectations contained herein. On the basis of such facts, estimates, circumstances and expectations, it is not expected that the Sale Proceeds or investment earnings thereon or any other moneys or property will be used in a manner that will cause the Certificates to be arbitrage bonds within the meaning of the Rebate Provisions and the Regulations. Such expectations are reasonable and there are no other facts, estimates and circumstances that would materially change such expectations. The City also agrees and covenants with the purchasers and holders of the Certificates from time to time outstanding that, to the extent possible under Illinois law, it will comply with -39- whatever federal tax law is adopted in the future which applies to the Certificates and affects the tax-exempt status of the Certificates. The City Council hereby authorize any Designated Officer to make such further covenants and certifications as may be necessary to assure that the use thereof will not cause the Certificates to be arbitrage bonds and to assure that the interest on the Certificates will be exempt from federal income taxation. In connection therewith, the City and the City Council further agree: (a) through their officers, to make such further specific covenants, representations as shall be truthful, and assurances as may be necessary or advisable; (b) to consult with counsel approving the Certificates and to comply with such advice as may be given; (c) to pay to the United States, as necessary, such sums of money representing required rebates of excess arbitrage profits relating to the Certificates; (d) to file such forms, statements, and supporting documents as may be required and in a timely manner; and (e) if deemed necessary or advisable by their officers, to employ and pay fiscal agents, financial advisors, attorneys, and other persons to assist the City in such compliance. Section 16. Registered Form. The City recognizes that Section 149(a) of the Code requires the Certificates to be issued and to remain in fully registered form in order that interest thereon is exempt from federal income taxation under laws in force at the time the Certificates are delivered. In this connection, the City agrees that it will not take any action to permit the Certificates to be issued in, or converted into, bearer or coupon form. Section 17. Pertaining to the Certificate Registrar. If requested by the Certificate Registrar, any officer of the City is authorized to execute a standard form of agreement between the City and the Certificate Registrar with respect to the obligations and duties of the Certificate Registrar under this Ordinance. In addition to the terms of such agreement and subject to modification thereby, the Certificate Registrar by acceptance of duties under this Ordinance -40- agrees (a) to act as registrar, paying agent, authenticating agent, and transfer agent as provided herein; (b) to maintain a list of Certificateholders as set forth herein and to furnish such list to the City upon request, but otherwise to keep such list confidential to the extent permitted by law; (c) to give notice of redemption of Certificates as provided herein; (d) to cancel and/or destroy Certificates which have been paid at maturity or upon earlier redemption or submitted for exchange or transfer; (e) to furnish the City at least annually a certificate with respect to Certificates cancelled and/or destroyed; and (f) to furnish the City at least annually an audit confirmation of Certificates paid, Certificates outstanding and payments made with respect to interest on the Certificates. The City covenants with respect to the Certificate Registrar, and the Certificate Registrar further covenants and agrees as follows: A. The City shall at all times retain a Certificate Registrar with respect to the Certificates; it will maintain at the designated office(s) of such Certificate Registrar a place or places where Certificates may be presented for payment, registration, transfer, or exchange; and it will require that the Certificate Registrar properly maintain the Certificate Register and perform the other duties and obligations imposed upon it by this Ordinance in a manner consistent with the standards, customs, and practices of the municipal securities industry. B. The Certificate Registrar shall signify its acceptance of the duties and obligations imposed upon it by this Ordinance by executing the certificate of authentication on any Certificate, and by such execution the Certificate Registrar shall be deemed to have certified to the City that it has all requisite power to accept and has accepted such duties and obligations not only with respect to the Certificate so authenticated but with respect to all the Certificates. Any Certificate Registrar shall be the agent of the City and shall not be liable in connection with the performance of its duties except for its own negligence or willful wrongdoing. Any Certificate -41- Registrar shall, however, be responsible for any representation in its certificate of authentication on Certificates. C. The City may remove the Certificate Registrar at any time. In case at any time the Certificate Registrar shall resign, shall be removed, shall become incapable of acting, or shall be adjudicated a bankrupt or insolvent, or if a receiver, liquidator, or conservator of the Certificate Registrar or of the property thereof shall be appointed, or if any public officer shall take charge or control of the Certificate Registrar or of the property or affairs thereof, the City covenants and agrees that it will thereupon appoint a successor Certificate Registrar. Any Certificate Registrar appointed under the provisions of this Section shall be a bank, trust company, or national banking association maintaining its principal corporate trust office in Illinois and having capital and surplus and undivided profits in excess of $50,000,000. The City Clerk is hereby directed to file a certified copy of this Ordinance with the Certificate Registrar. Section 18. Continuing Disclosure Undertaking. Any Designated Officer is hereby authorized, empowered and directed to execute and deliver a Continuing Disclosure Undertaking (the "Continuing Disclosure Undertaking ") in connection with the issuance of the Certificates, with such provisions therein as he or she shall approve, his or her execution thereof to constitute conclusive evidence of his or her approval of such provisions. When the Continuing Disclosure Undertaking is executed and delivered on behalf of the City as herein provided, the Continuing Disclosure Undertaking will be binding on the City and the officers, employees and agents of the City, and the officers, employees and agents of the City are hereby authorized, empowered and directed to do all such acts and things and to execute all such documents as may be necessary to carry out and comply with the provisions of the Continuing Disclosure Undertaking as executed. Notwithstanding any other provision of this Ordinance, the sole remedies for failure to comply with the Continuing Disclosure Undertaking shall be the ability of the beneficial owner of any -42- i Certificate to seek mandamus or specific performance by court order, to cause the City to comply with its obligations under the Continuing Disclosure Undertaking. Section 19. Defeasance. Any Certificate or Certificates which (a) are paid and cancelled, (b) which have matured and for which sufficient sums been deposited with the Certificate Registrar to pay all principal and interest due thereon, or (c) for which sufficient United States of America dollars and direct United States Treasury obligations have been deposited with the Certificate Registrar or similar institution to pay, taking into account investment earnings on such obligations, all principal of and interest on such Certificate or Certificates when due at maturity, pursuant to an irrevocable escrow or trust agreement, shall cease to have any lien on or right to receive or be paid from the Certificate Moneys hereunder and shall no longer have the benefits of any covenant for the registered owners of outstanding Certificates as set forth herein as such relates to lien and security of the outstanding Certificates. All covenants relative to the Tax-exempt status of the Certificates; and payment, registration, transfer, and exchange; are expressly continued for all Certificates whether outstanding Certificates or not. Section 20. Superseder and Effective Date. All ordinances, resolutions, and orders, or parts thereof, in conflict herewith, are to the extent of such conflict hereby superseded; and this Ordinance shall be in full force and effect upon its passage. ADOPTED: this 15th day of June, 2004 -43- +.~ Mayor, ity of Canton, Fulton County, Illino s ATTEST: City Clerk, 1 City of Canton, Fulton County, Illinois -44- EXTRACT of MINUTES of the regular public meeting of the City Council of the City of Canton, Fulton County, Illinois, held at the Historic Depot, 50 N. 4th. Ave., in said City, at 6:30 p.m., on the 15thday of June, 2004. The Mayor called the meeting to order and directed the City Clerk to call the roll. Upon the roll being called, the Mayor, Jerry ^-~. Bohler ,and the following Aldermen answered present: Larry Sarff, Marv Fillingham, Bob :4olleck, Elny Harn, Les Carl, Jim Hartford Rick Reed and Craiq West The following were absent: none The City Council then discussed the proposed financing of a redevelopment project in and for the City, including, specifically, the demolition of an abandoned International Harvester manufacturing facility. Thereupon, Alderman presented, and there was placed before each Alderman in full the following ordinance: f ORDINANCE NUMBER 1 ~,0 AN ORDINANCE of the City of Canton, Fulton County, Illinois, authorizing and providing for an Installment Purchase Agreement for the purpose of paying a part of the cost of a redevelopment project, and authorizing and providing for the issue of $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004, evidencing the rights to payment under such Agreement, prescribing the details of the Agreement and Certificates, and providing for the security for and means of payment under the Agreement of the Certificates. Introduced for first reading on June 1, 2004. Adopted by the City Council of said City on the 15 nth day of June, 2004 1690589.01.03 218651 Canton2004illpmc • 5/20/04 STATE OF ILLINOIS ) ) SS COUNTY OF FULTON ) CERTIFICATION OF MINUTES AND ORDINANCE AND PUBLICATION IN PAMPHLET FORM I, the undersigned, do hereby certify that I am the duly qualified and acting City Clerk of the City of Canton, Fulton County, Illinois (the "City"), and as such official I am the keeper of the official journal of proceedings, books, records, minutes, and files of the City and of the City Council (the "City Council") thereof. I do further certify that the foregoing is a full, true, and complete transcript of that portion of the minutes of the meeting (the "Meeting ") of the City Council held on the 15th day of June, 2004, insofar as the same relates to the adoption of an ordinance, numbered 1 X02 ,and entitled: AN ORDINANCE of the City of Canton, Fulton County, Illinois, authorizing and providing for an Installment Purchase Agreement for the purpose of paying a part of the cost of a redevelopment project, and authorizing and providing for the issue of $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004, evidencing the rights to payment under such Agreement, prescribing the details of the Agreement and Certificates, and providing for the security for and means of payment of the Certificates. (the "Ordinance ") a true, correct, and complete copy of which Ordinance as adopted at the Meeting appears in the foregoing transcript of the minutes of the meeting. I do further certify that the deliberations of the City Council on the adoption of the Ordinance were taken openly; that the vote on the adoption of the Ordinance was taken openly; that the Meeting was held at a specified time and place convenient to the public; that notice of the Meeting was duly given to all newspapers, radio or television stations, and other news media requesting such notice; that an agenda for the Meeting (the "Agenda ") was posted at the location AN ORDINANCE of the City of Canton, Fulton County, Illinois, authorizing and providing for an Installment Purchase Agreement for the purpose of paying a part of the cost of a redevelopment project, and authorizing and providing for the issue of $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004, evidencing the rights to payment under such Agreement, prescribing the details of the Agreement and Certificates, and providing for the security for and means of payment under the Agreement of the Certificates. (the "Certificate Ordinance"). A City Council discussion of the matter followed. During the City Council discussion, ~ ~ - gave a public recital of the nature of the matter, which included a complete reading of the title of the Certificate Ordinance. The Mayor directed that the roll be called for a vote upon the motion to adopt the Certificate Ordinance. Upon the roll being called, the following Aldermen voted AYE: craia Flest Rick Reed, Jim Hartford, Les Carl, Elny Harn, Bob D4olleck, Mary Fillinqham and Larrv Sarf.f . and the following Aldermen voted NnY: WHEREUPON the Mayor declared the motion carried and the Certificate Ordinance adopted and did direct the City Clerk to record the same in full in the records of the City Council of the City of Canton, Fulton County, Illinois. -2- Other business was duly transacted at said meeting. Upon motion duly made and carried, the meeting adjourned. „. Cit Jerk -3- where the Meeting was held and at the principal office of the City Council on a day which was not a Saturday, Sunday or legal holiday for Illinois municipalities and at least 48 hours in advance of the holding of the Meeting; that the Agenda described or made specific reference to the Ordinance; and that the Meeting was called and held in strict compliance with the provisions of the Open Meetings Act of the State of Illinois, as amended, and the Illinois Municipal Code, as amended, and that the City Council has complied with all of the provisions of said Act and said Code and with all of the procedural rules of the City Council in the adoption of the Ordinance. I do further certify that said Ordinance was published in sufficient numbers for public inspection in pamphlet form on the 15th day of June, 2004, by direction of the City Council. I do further certify that I have attached hereto as SCHEDULE I a true, correct and complete copy of the Agenda as so posted. IN WITNESS WHEREOF I hereunto affix my official signature and the seal of the City this 15tMlay of June, 2004. City Clerk [SEAL] -2- SCHEDULEI CITY CLERK TO ATTACH AGENDA A G E N D A CANTON CITY COUNCIL June 15, 2004 6:30 p.m. PLEDGE OF ALLEGIANCE INVOCATION ROLL CALL MINUTES OF COUNCIL MEETING June 1, 2004 TREASURER'S REPORT BILLS FOR MAY COMMITTEE REPORTS: Finance Vacuum Pump Repair - WWTP Audit Engagement Letter - Hocker & Fitzjarrald Pay request #1 -N.E. Finch for IH Project Legal & Ordinance Animal Shelter Agreement Community & Industrial Development Negotiations, Grievance & Personnel COMMUNICATIONS FROM MAYOR BOHLER Liquor Commissioner Report: Official Time Out June 26 -11:00 to 10:00 p.m. For Canton Freshman Sports Fundraiser Agreement with Environmental Operations, Inc Retain Chapman & Cutler -Debt Certificate OLD BUSINESS: ORDINANCE -AMENDING TITLE 8, CHAPTER 18, SECTION 1, OF THE CANTON MUNICIPAL CODE RELATING TO GARBAGE DISPOSAL SYSTEM. ORDINANCE - AUTHORIZING AND PROVIDING FOR AN INSTALLMENT PURCHASE AGREEMENT FOR THE PURPOSE OF PAYING A PART OF THE COST OF A REDEVELOPMENT PROJECT, AND AUTHORIZING AND PROVIDING FOR THE ISSUE OF $1,200,000 GENERAL OBLIGATION LIMITED TAX DEBT CERTIFICATES, SERIES 2004, EVIDENCING THE RIGHTS TO PAYMENT UNDER SUCH AGREEMENT, PRESCRIBING THE DETAILS OF THE AGREEMENT AND CERTIFICATES, AND PROVIDING FOR THE SECURITY FOR AND MEANS OF PAYMENT UNDER THE AGREEMENT OF THE CERTIFICATES. ORDINANCE -AUTHORIZING, DIRECTING AND SETTING THE DATE FOR THE SALE AT PUBLIC AUCTION OF CERTAIN PERSONAL PROPERTY OWNED BY THE CITY OF CANTON, AND NO LONGER NEEDED FOR CITY PURPOSES. NEW BUSINESS: ORDINANCE -APPROPRIATING FOR ALL CORPORATE PURPOSES OF THE CITY OF CANTON, FULTON COUNTY, ILLINOIS, FOR THE FISCAL YEAR BEGINNING MAY 1, 2004, AND ENDING APRIL 30, 2005. ORDINANCE -DESIGNATING THE INTERNATIONAL HARVESTER SITE REDEVELOMENT PROJECT AREA. ORDINANCE -APPROVING THE REDEVELOPMENT PLAN AND PROJECT FOR THE INTERNATIONAL HARVESTER SITE REDEVELOPMENT PROJECT AREA. ORDINANCE -ADOPTING TAX INCREMENT FINANCING FOR THE CITY OF CANTON, IN CONNECTION WITH THE DESIGNATION OF THE INTERNATIONAL HARVESTER SITE REDEVELOMENT PROJECT AREA. RESOLUTION - ASCERTAINING THE PREVAILING RATE OF WAGES FOR LABORERS, MECHANICS AND OTHER WORKMEN EMPLOYED IN ANY PUBLIC WORKS BY THE CITY OF CANTON, ILLINOIS. RESOLUTION -CANTON PRIDE COMMITTEE TO HOLD A 4TH OF JULY PARADE FROM 7:00 P.M. TO 8:00 P.M. EXECUTIVE SESSION - NEGOTIATIONS, GRIEVANCE & PERSONNEL - PURPOSE OF DISCUSSING PUBLIC WORKS CONTRACTS. • STATE OF ILLINOIS ) ) SS COUNTY OF FULTON ) CERTIFICATE OF FILING We, the undersigned, do hereby certify that we are, respectively, the duly qualified and acting City Clerk and Treasurer of the City of Canton, Fulton County, Illinois (the "City "), and as such officers we do hereby certify that on the 15t1~ day of June, 2004, there was filed with each of us, respectively, and placed on deposit in our respective records, a properly certified copy of Ordinance Number ~, passed by the City Council of the City, on thel5th day of June, 2004, and approved by the Mayor, and entitled: AN ORDINANCE of the City of Canton, Fulton County, Illinois, authorizing and providing for an Installment Purchase Agreement for the purpose of paying a part of the cost of a redevelopment project, and authorizing and providing for the issue of $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004, evidencing the rights to payment under such Agreement, prescribing the details of the Agreement and Certificates, and providing for the security for and means of payment under the Agreement of the Certificates. and that the same has been deposited in, and all as appears from, the official files and records of our respective offices. IN WITNESS WHEREOF we have hereunto affixed our official signatures and the seal of the City this 15th day of June, 2004. n' ~ ~ ty Clerk [SEAL] /...---_." Treasurer CERTIFICATE STATE OF ILLINOIS, ) CITY OF CANTON, ) SS. COUNTY OF FULTON. ) I, Nancy Whites, City Clerk of the City of Canton, in the City of Canton, in the County of Fulton and State of Illinois, do hereby certify that as the City Clerk of the City of Canton, I am the keeper of records, minutes, ordinances and other books, records and papers of said City, and that the foregoing is a true and correct copy of ORDINANCE N0. 1802 AN ORDINANCE OF THE CITY OF CAIV'iDN, FULTON OOUN'iY, ILLIlVOIS , AUTHORIZING AND PROVIDING FOR AN INSTALir~]T PURC~~ASE AGREII~'lEIVT FOR THE PURPOSE OF PAYING A PART OF THE COST OF A REDEVEIAPM~]T PROJECT, AND AUTHORIZING AND PROVIDING FOR Tf~ ISSUE OF $1,200,000 GENERAL OBLIGATION LIlKITID TAX DEBT (~TIFICATES, SERIES 2004, EVIDENCING THE RIGHTS TD PAYP'1ENT UNDIIt SUCH AGREII~I' , PRESCRIBIlVG THE DETAILS OF THE AGREEL~]T AND CIItTIFICATES , AND 'PROVIDING FOR THE SECURITY FOR AND MF.AI~TS OF PAYMENT UNDER THE AGREII"IIIVT OF THE CERTIFICATES. Adopted by the City Council of said City and approved by the Mayor thereof on the 15th- day of T1mP , 20 04 . WITNESS my hand and the Corporate Seal of the City of Canton, Illinois this 12thday of July 20 04 . ~~ ' ~~ Nancy Whi s, City Clerk (SEAL) STATE OF ILLINOIS ) SS COUNTY OF FULTON ) ORGANIZATION CERTIFICATE We, the undersigned, do hereby certify that we are the duly qualified and acting Mayor and City Clerk, respectively, of the City of Canton, Fulton County, Illinois (the "City', and as such officials we do further certify as follows: That the City was organized and incorporated as a City under the laws of the State of Illinois on or about the year 1849, has continuously since its incorporation operated under the general laws of the State of Illinois as a City governed by a Mayor and City Council, has never changed its form of government, is now operating under the provisions of the Illinois Municipal Code, as amended (65ILCS 5/1-1-1 et seq.) (the "Code"), and is not now operating under the provisions of any special act or charter. 2. That the City has not adopted and is not now operating under the provisions of Article 4 of the Code, said article providing for The Commission Form of Municipal Government, has not adopted and is not now operating under the provisions of Article 5 of the Code, said article providing for The Managerial Form of Municipal Government, has not adopted and is not now operating under the provisions of Articles 6, 14 and 18 of the Election Code of the State of Illinois, as amended (10 ILCS 516, 5/14 and 5118), said articles being known as the City Election Law, and has not elected by referendum to become a home rule unit under the provisions of the 1970 Constitution of the State of Illinois. 3. That the present duly qualified and acting officials of the City are as follows: Jerry M. Bohler, Mayor Nancy S. Whites, City Clerk Patty Beaird Franzoni, City Treasurer Ronald Weber, City Attorney with a City Council (the "Council ") composed of eight (8) duly qualified and acting Aldermen as follows: James Hartford, Robert Molleck, Larry Sarff, Craig West, Les Carl, Rick Reed, Elny Harn and Mary Fillingham, and that said members of t e Council have been the duly qualified and acting Council since ,ac~3, and provided there are no vacancies created by resignation or of a ise, will constitute the Council until the election for members of the Council to be held in April, 2005, is canvassed and a new Council duly constituted. Certificates 2118651 4. That the changes in the boundaries of the City during the past five (5) years were as follows: None. That The County of Fulton, Illinois, is the only county within which the City is wholly or partly located, and that said county has not adopted and is not now operating under the provisions of Article 6A of the Election Code of the State of Illinois, as amended (10 ILCS 5/6A), said article providing for a county board of election commissioners. 6. That no portion of the District is now or ever has been located in a county of 3,000,000 or more inhabitants, a county contiguous to a county with 3,000,000 or more inhabitants or a county that has held a referendum on the applicability of the Property Tax Extension Limitation Law of the State of Illinois, as amended (35 IL,CS 200/18-185 et seq.). 7. That the Daily Ledger is a local, community newspaper with a general circulation within the City. 8. That all of the news media that have filed a request for notice of the meetings of the Council pursuant to the Open Meetings Act of the State of Illinois, as amended (5 II.CS 120/1 et seq.), are as follows: WBYS. 9. That the regular meetings of the Council are held on first and third Tuesdays of each month at 6:30 o'clock P.M., in the Historic Depot, 1 Depot Road, Canton, Illinois, within the City, that the Council has given public notice of said schedule of regular meetings stating the regular dates, times and places of said meetings at the beginning of each calendar or fiscal year by posting a copy of said public notice at the principal office of the Council and by supplying copies of said public notice to all of the newspapers, radio or television stations and other news media that have filed a request for such notice, and that the Council has made said schedule available to the public. 10. That the City has an official population of 15,288, and that there are approximately 9,314 legal voters in the City. 11. That no petition has been filed or is now pending praying for the disconnection of any territory from the present corporate limits of the City. 12. That there is no litigation or controversy pending or threatened and there are no tax objections pending or threatened questioning or affecting in any manner whatsoever the corporate existence of the City, the boundaries thereof, the right of the City to levy taxes for municipal purposes or the title of any of its present officials to their respective offices. -2- IN WITNESS WHEREOF, we hereunto affix our official signatures and the seal of the City, this 12th day of July, 2004. Mayor 1 City Cl rk (SEAT.) -3- STATE OF ILLINOIS ) SS COUNTY OF FULTON ) INDEBTEDNESS CERTIFICATE We, the undersigned, do hereby certify that we are the duly qualified and acting City Clerk and City Treasurer, respectively of the City of Canton, Fulton County, Illinois (the "City "), and as such officials we do further certify that the total aggregate indebtedness of the City, of every kind and nature and howsoever evidenced or incurred, excluding the proposed Debt Certificates, Series 2004, does not exceed the total sum of $ ,which said indebtedness is itemized as follows: Bonds issued by the City (not including alternate bonds, funding bonds, revenue bonds, special service area bonds, tax increment allocation bonds and bonds issued pursuant to Sections 8-4-1(13) or 8-5-16 of the Illinois Municipal Code, as amended (the "Code'~) ................................................................ $ Alternate bonds issued pursuant to Section 15 of the Local Government Debt Reform Act of the State of Illinois, as amended ........................................................................................... $3, $~/~ 05/ Funding bonds issued pursuant to Sections 8-1-4 and 8-5-2 of the Code ....................................................................................... $ Special service area bonds issued pursuant to the Special Service Area Tax Law of the State of Illinois, as amended ................ $ Tax increment allocation bonds issued pursuant to Section 11-74.4-7 of the Code .......................................................... $ "Compliance schedule or order bonds" issued pursuant to Section 8-4-1(13) of the Code .......................................................... $ Bonds issued pursuant to Section 8-5-16 of the Code ....................... $ Contracts (including all payments on installment purchase contracts and public utility contracts) ................................................ $~„~, X05 Indebtedness resulting from annexations of territory .......................... $ Judgments ........................................................................................ $ Leases (including all payments on with public building commission leases) ........................................................................... $ Miscellaneous floating indebtedness .................................................. $ Special Assessments levied against City property .............................. $ Unpaid public benefit judgments ....................................................... $ Other forms of debt (not including warrants issued in anticipation of the collection of taxes levied) ......................................... C; all of which appears from the books and records in our official respective care and custody. IN WITNESS WHEREOF, we hereunto affix our official signatures and the seal of the City, this 12th day of July, 2004. Z ~ ~~'~~ City Clerk (SEAL) c City reasu r -2- STATE OF ILLINOIS ) SS COUNTY OF FULTON ) 2003 VALUATION CERTIFICATE I, the undersigned, do hereby certify that I am the duly qualified and acting and County Clerk of The County of Fulton, Illinois (the "County "); and as such official I do further certify that the equalized assessed value of all taxable real property located in the County included within the boundaries of the City of Canton, Fulton County, Illinois, as of the date of this certificate, is the sum of $ /D11 ~ D~~ ~~ 3 , as last equalized or assessed by the Department of Revenue of the State of Illinois, for State and County taxes for the year 2003, all as appears from the books of assessment of the County now in my possession. IN WITNESS WI~REOF I hereunto affix my official signature and t seal of The County of Fulton this ~ day of July, 2004. ounty Clerk The County of Fulton, Illinois [SEAL] STATE OF ILLINOIS ) SS COUNTY OF FULTON ) CERTIFICATE OF CITY ATTORNEY RE CITY CODE I do hereby certify that I am the City Attorney for the City of Canton, Fulton County, Illinois (the "City'. I do further certify that I have reviewed the Code of Ordinances of the City, the journal of proceedings, books, records, minutes and files of the City and of the City Council (the "Corporate Authorities ") of the City and that, from such review, I am of the opinion that: 1. The Corporate Authorities have taken no action to modify the provisions of the Illinois Municipal Code, as amended, with respect to the calling, holding, or giving of notice of regular or special meetings. 2. The Corporate Authorities have taken no action to modify the provisions of said Illinois Municipal Code with respect to the introduction and passage of resolutions or ordinances, except as maybe hereinafter expressly noted. 3. The Corporate Authorities do not require the second reading or laying over of resolutions or ordinances, except as follows: The City has a first reading requirement. 4. The Corporate Authorities have taken no action to limit in any way the powers of the City to incur debt; and there are no special ordinances, resolutions, or other procedures applicable to the incurrence of debt by the City. IN WITNESS WHEREOF we have hereunto affixed our official signature this 12th day of July, 2004. By Ronald Weber, City Attorney INSTALLMENT PURCHASE AGREEMENT for purchase of real or personal property, or both, for the purpose of undertaking a redevelopment project, in and for the City of Canton, Fulton County, Illinois. THis INSTALLMENT PURCHASE AGREEMENT' (this "Agreement ") made as of the day of June, 2004 by and between the City Treasurer, as Nominee-Seller (the "Seller', and the City of Canton, Fulton County, Illinois, a municipality of the State of Illinois (the "City "): WTTNESSETH A. The City Council (the "City Council's of the City has determined to enter into an agreement for demolition services, constituting personal property, in order to undertake a redevelopment project (collectively, the " 20D4 Service Agreement "), all as previously approved by the City Council and on file with the City Clerk of the City (the "City Clerk'. B. Pursuant to the provisions of the Illinois Municipal Code (the "Municipal Code "); the Local Government Debt Reform Act of the State of Illinois (the "Debt Reform Act's, and, in particular, the provisions of Section 17 of the Debt Reform Act (the "Installment Purchase Provisions of the Debt Reform Act "); and all other Omnibus Bond Acts of the State of Illinois; in each case, as supplemented and amended (collectively "Applicable Law "); the City has the power to purchase real or personal property through agreements that provide that the consideration for the purchase may be paid through installments made at stated intervals for a period of no more than 20 years and has the power to issue certificates evidencing indebtedness incurred under such agreements. C. On the 15th day of June, 2004, the City Council, pursuant to Applicable Law and the need to provide for the 2004 Service Agreement, adopted an ordinance (the "Ordinance "), authorizing the borrowing of money for the 2004 Service Agreement, the execution and delivery I-1 of this Agreement to finance same, and the issuance of certificates evidencing the indebtedness so incurred. D. The Ordinance is (a) incorporated herein by reference; and (b) made a part hereof as if set out at this place in full; and each of the terms as defined in the Ordinance is also incorporated by reference for use in this Agreement. E. The Seller, as nominee as expressly permitted by the Installment Purchase Provisions of the Debt Reform Act, has agreed to make and acquire the 2004 Service Agreement on the terms as hereinafter provided. Now THEREFORE in consideration of the mutual covenants and agreements hereinafter contained and other valuable consideration, it is mutually agreed between the Seller and the City as follows: 1. MAKE, ACQUIRE AND CONSTRUCT 2004 SERVICE AGREEMENT The Seller agrees to make and acquire the 2004 Service Agreement to provide for services upon real estate owned or to be owned by or upon which valid easements or licenses have been obtained in favor of the City. 2. CONVEYANCE The Seller agrees to perform each part of the 2004 Service Agreement to the City and to perform all necessary work as set out therein and the City agrees to purchase the 2004 Service Agreement from the Seller and pay for the 2004 Service Agreement the purchase price thereof; plus the amount of investment earnings which are earned on the amount deposited with the Treasurer from the sale of the Certificates provided that in no event shall the total aggregate principal purchase price to be paid pursuant to this Agreement exceed the sum of $1,200,000, I-2 plus the amount of investment earnings which are earned on the amount deposited with the Treasurer from the sale of the Certificates. 3. PAY1vIENTS The payment of the entire sum of said purchase price [net, however, of any such investment earnings] shall: (a) be payable in installments due on the dates and in the amounts; (b) bear interest at the rates percent per annum which interest shall also be payable on the dates and in the amounts; (c) be payable at the place or places of payment, in the medium of payment, and upon such other term; all as provided for payment of the Certificates in the Ordinance. 4. ASSIGNMENT Rights to payment of the Seller as provided in this Agreement are assigned as a matter of law, under the Installment Purchase Provisions of the Debt Reform Act, to the owners of the Certificates. This Agreement and any right, title, or interest herein, shall not be further assignable. The Certificates, evidencing the indebtedness incurred hereby, are assignable (registrable) as provided in the Ordinance. 5. TP.x CovENp,NTs The covenants relating to the Tax-exempt status of the Certificates, as set forth in the Ordinance, insofar as may be applicable, apply to the work to be performed and the payments made under this Agreement. I-3 6. TITLE (a) Vesting of Title. Title in and to any part of the 2004 Service Agreement, upon delivery or as made, during all stages of the making or acquisition thereof, shall and does vest immediately in the City. (b) Voiding of Service Agreeement. ff, during the term of this Agreement, all or any part of the 2004 Service Agreement shall be voided for any reason; then the City shall continue to make payments as promised herein and in the Certificates and to take such action as it shall deem necessary or appropriate to ratify the 2004 Service Agreement. 7. LAWFUL CORPORATE OBLIGATION The City hereby represents, warrants, and agrees that the obligation to make the payments due hereunder shall be a lawful direct general obligation of the City payable from the corporate funds of the City and such other sources of payment as are otherwise lawfully available. The City represents and warrants that the total amount due the Seller hereunder, together with all other indebtedness of the City, is within all statutory and constitutional debt limitations. The City agrees to appropriate funds of the City annually and in a timely manner so as to provide for the making of all payments when due under the terms of this Agreement. 8. GENERAL COVENANT Arm RECITAL It is hereby certified and recited by the Seller and the City, respectively, that as to each, respectively, for itself, all conditions, acts, and things required by law to exist or to be done precedent to and in the execution of this Agreement did exist, have happened, been done and performed in regular and due form and time as required by law. 9. NO SEPARATE TAX THE SELLER AND THE CITY RECOGNIZE TART THERE IS NO STATUTORY AUTHORITY FOR THE LEVY OF A SEPARATE TAX IN ADDTTION TO OTHER TAXES OF THE CITY OR THE LEVY I-4 OF A SPECIAL TAX UNLIMITED AS TO RATE OR AMOUNT TO PAY ANY OF THE AMOUNTS DUE HEREUNDER. 10. DEFALJI.T In the event of a default in payment hereunder by the City, the Seller or any Certificateholder may pursue any available remedy by suit at law or equity to enforce the payment of all amounts due or to become due under this Agreement, including, without limitation, an action for specific performance. I-5 IN WrINESS WHEREOF the Seller has caused this Installment Purchase Agreement to be executed and attested, and his or her signature to be attested by the City Clerk of the City, and the City has caused this Installment Purchase Agreement to be executed by its Mayor, and also attested by its City Clerk, and the official seal of the City to be hereunto affixed, all as of the day and year first above written. SELLER: Signature: ' ~- Patty Beaird-Franzoni as Nominee-Seller and the City Treasurer ATTEST: ~~ City erk [SEAL] CITY OF CANTON, FULTON COUNTY, ILLINOIS Mayor ATTEST: ~' ~~ City Jerk [SEAL] I-6 STATE OF ILLINOIS ) SS COUNTY OF FULTON CERTIFICATE OF INSTALLMENT PURCHASE AGREEMENT FILING I, the undersigned, do hereby certify that I am the duly qualified and acting City Clerk of the City of Canton, Fulton County, lllinois (the "City', and as such officer I do hereby certify that on the i 5 day of June; 2004 there was filed in my office a properly certified copy of that certain document, executed by the Mayor of the City, attested by me in my capacity as City Clerk, and further executed, as Nominee-Seller, by the City Treasurer, also attested by me, dated the 15 day of June, 2004, and entitled "INSTALLMENT PURCHASE AGREEMENT for Purchase of real or personal property, or both, for the purpose of undertaking a redevelopment agreement, in and for the City of Canton, Fulton County, Illinois"; and supporting the issuance of certain General Obligation Limited Tax Debt Certificates, Series 2004, of the City; that attached hereto is a true and complete copy of said Agreement as so filed; and that the same has been deposited in the official files and records of my office. IN WITNESS WI-IExEOF I have hereunto affixed my official signature and the seal of the City of Canton, Fulton County, Illinois at Canton, Illinois, this l.~ day of July, 2004. ~,~ ~~ ~~i City Clerk [SEAL] InstallAgree-Fi lingCert CERTIFICATE STATE OF ILLINOIS, ) CITY OF CANTON, ) SS. COUNTY OF FULTON. ) I, Nancy Whites, City Clerk of the City of Canton, in the City of Canton, in the County of Fulton and State of Illinois, do hereby certify that as the City Clerk of the City of Canton, I am the keeper of records, minutes, ordinances and other books, records and papers of said City, and that the foregoing is a true and correct copy of: The minutes of the City Cotmcil meeting of Jtme 15, 2004, City of Canton, Illinois. Adopted by the City Council of said City and approved by the Mayor thereof on the 15t1z_ day of .T,~,P , 20 04 WITNESS my hand and the Corporate Seal of the City of Canton, Illinois this 1~.~ day of July 20 04 ~( /,. . l ~ ~~ ~ ~ /~,r ,l t .r/1 / YI~~J / ancy White, City Clerk (SEAL) A regulaz meeting of the Canton City Council was held on June 15, 2004 in the Council Chambers at the Historic Depot, 50 North 4'~ Avenue, Canton, Illinois. _ PLEDGE OF ALLEGIANCE OPENED THE MEETING FOLLOWED BY THE INVOCATION GIVEN BY NANCY WHITES, CITY CLERK. Mayor Bohler asked for roll call at 6:30 p.m. Present -Aldermen Larry Sazff, Mazy Fillingham, Bob Molleck, Elny Ham, Les Cazl, Jim Hartford, Rick Reed, Craig West. Absent -None. MINUTES OF JUNE 1~, 2004 COUNCIL MEETING. Motion and second by Aldermen Molleck/Hartford, the minutes of June 1, 2004 be accepted and placed on file. Voice vote, motion carried unanimously. TREASURER'S REPORT. Patty Beaird Franzoni said she has to postpone given out her report for another week. BILLS FOR MAY. Motion and second by Aldermen West/Reed, all bills properly presented be paid. Roll call. AYES -Aldermen West, Reed, Hartford, Cazl. Harn, Molleck, Fillingham, Sazff. NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. COMMITTEE REPORTS: Finance. Council Action Motion and second by Aldermen Hartford/Cazl, to approve payment of $750 to repair the Vacuum Pump at the Wastewater Treatment Plant. Discussion. Chuck Jarvis reported for Supt. Joe Carruthers the repairs came to $750 instead of the original estimated cost of $3,000. Roll call. Aldermen Saz~ Fillingham, Molleck, Harn, Carl, Hartford, Reed, West. NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. Motion and second by Aldermen Hartford/Sar~ to approve the engagement letter of Hocker & Fitzjarrald in the amount of $18,500 for the yeaz ended of April 30, 2004. Roll call. AYES -Aldermen West, Reed, Hartford, Carl, Ham, Molleck, Fillingham, Sarff. NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. Motion and second by Aldermen Hartford/Reed, to approve of pay request # 1 from N. E. Finch for the lH Project in the amount of $517,500.00. Roll call. AYES -Aldermen Saris Fillingham, Molleck, Ham, Cazl, Hartford, Reed, West. NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. Legal & Ordinance. Council meeting June 15, 2004 Mayor Bohler mentioned good news for the City of Canton by receiving two $200,000 USEPA grants. They will be used on the S.W. side between Maple and Pine Street where the Power House used to be. This is due to the efforts of Clark Wilson, David Byerly and Vandewalle & Associates from all their hazd work in obtaining these two grants. OLD BUSINESS: ORDINANCE -AMENDING TITLE 8, CHAPTER 18, SECTION 1, OF THE CANTON MUNICIPAL CODE RELATING TO GARBAGE DISPOSAL SYSTEM. Second reading, read by title. Motion and second by Aldermen Hartford/West, the ordinance be placed on its passage. Roll call. AYES -Aldermen Sari Fillingham, Molleck, Hazn, Cazl, Hartford, Reed, West. NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. Ordinance being #1801. ORDINANCE -AUTHORIZING AND PROVIDING FOR AN INSTALLMENT PURCHASE AGREEMENT FOR THE PURPOSE OF PAYING A PART OF THE COST OF A REDEVELOPMENT PROJECT, AND AUTHORIZING AND PROVIDING FOR THE ISSUE OF $1,200,000 GENERAL OBLIGATION LIMITED TAX DEBT CERTIFICATES, SERIES 2004, EVIDENCING THE RIGHTS TO PAYMENT UNDER SUCH AGREEMENT, PRESCRIBING THE DETAILS OF THE AGREEMENT AND CERTIFICATES, AND PROVIDING FOR THE SECURITY FOR AND MEANS OF A PAYMENT UNDER THE AGREEMENT OF THE CERTIFICATES. Second reading, read by title. Motion and second by Aldermen Sarff/Haztford, to waive the bidding process. Discussion. Ron Weber said this did not go out in the process of bidding, Mid America National Bank would provide 3.3% with no principle repayment for 5 years. This allows the borrower the money. Then the financing would be replaced by revenue bonds when they come available. Alderman Sarff wanted to no if the $400,000 EPA grant would be applied to this ordinance? Ron Weber explained that is up to council. Roll call. AYES - Aldermen West, Reed, Hartford, Cazl, Hare, Molleck, Fillingham, Sarff NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. Motion and second by Aldermen Molleck/West, the ordinance be placed on its passage. Roll ca1L AYES -Aldermen Saz$ Fillingham, Molleck, Ham, Cazl, Hartford, Reed, West. Ordinance being #1802. ORDINANCE -AUTHORIZING, DIRECTING AND SETTING THE DATE FOR THE SALE AT PUBLIC AUCTION OF CERTAIN PERSONAL PROPERTY OWNED BY THE CITY OF CANTON, AND NO LONGER NEEDED FOR CITY PURPOSES. Second reading, read by title. Motion and second by Aldermen WestlReed, the ordinance be placed on its passage. Roll call. AYES -Aldermen West, 3 Council meeting June 15, 2004 Fillingham, Molleck, Harn, Cazl, Hartford, Reed, West. NAYS -None. 8 AYES, 0 NAYS, 0 ABSENT. Motion carried. The regulaz scheduled council meeting convened into executive session at the time of 6:53 p.m. The Executive Session for negotiations of Public Works Contract aze on file in the office of the city clerk for review. The regulaz scheduled council meeting reconvened from executive session at 8:49 p.m. in to open session for adjournment. ADJOURNMENT. Voice vote, motion adjourned at 8:50 p.m. Motion and second by Aldermen Molleck/Fillingham, to adjourn. carried unanimously. The regulaz scheduled council meeting Nancy Whi s, City Clerk APPROVED: Jerry M. Bohler, Mayor 5 A G E N D A CANTON CITY COUNCIL June 15, 2004 6:30 p.m. PLEDGE OF ALLEGIANCE INVOCATION ROLL CALL MINUTES OF COUNCIL MEETING June 1, 2004 TREASURER'S REPORT BILLS FOR MAY COMMITTEE REPORTS: Finance Vacuum Pump Repair - WWTP Audit Engagement Letter - Hocker & Fitzjarrald Pay request #1 -N.E. Finch for IH Project Legal & Ordinance Animal Shelter Agreement Community & Industrial Development Negotiations, Grievance & Personnel COMMUNICATIONS FROM MAYOR BOHLER Liquor Commissioner Report: Official Time Out June 26 - 11:00 to 10:00 p.m. For Canton Freshman Sports Fundraiser Agreement with Environmental Operations, Inc Retain Chapman & Cutler -Debt Certificate OLD BUSINESS: ORDINANCE -AMENDING TITLE 8, CHAPTER 18, SECTION 1, OF THE CANTON MUNICIPAL CODE RELATING TO GARBAGE DISPOSAL SYSTEM. ORDINANCE - INSTALLMENT PAYING A PAR AUTHORIZING AND PROVIDING FOR AN PURCHASE AGREEMENT FOR THE PURPOSE OF T OF THE COST OF A REDEVELOPMENT PROJECT, ~.N AND AUTHORIZING AND PROVIDING FOR THE ISSUE OF $1,200,000 GENERAL OBLIGATION LIMITED TAX DEBT CERTIFICATES, SERIES 2004, EVIDENCING THE RIGHTS TO PAYMENT UNDER SUCH AGREEMENT, PRESCRIBING THE DETAILS OF THE AGREEMENT AND CERTIFICATES, AND PROVIDING FOR THE SECURITY FOR AND MEANS OF PAYMENT UNDER THE AGREEMENT OF THE CERTIFICATES. ORDINANCE -AUTHORIZING, DIRECTING AND SETTING THE DATE FOR THE SALE AT PUBLIC AUCTION OF CERTAIN PERSONAL PROPERTY OWNED BY THE CITY OF CANTON, AND NO LONGER NEEDED FOR CITY PURPOSES. NEW BUSINESS: ORDINANCE -APPROPRIATING FOR ALL CORPORATE PURPOSES OF THE CITY OF CANTON, FULTON COUNTY, ILLINOIS, FOR THE FISCAL YEAR BEGINNING MAY 1, 2004, AND ENDING APRIL 30, 2005. ORDINANCE -DESIGNATING THE INTERNATIONAL HARVESTER SITE REDEVELOMENT PROJECT AREA. ORDINANCE -APPROVING THE REDEVELOPMENT PLAN AND PROJECT FOR THE INTERNATIONAL HARVESTER SITE REDEVELOPMENT PROJECT AREA. ORDINANCE -ADOPTING TAX INCREMENT FINANCING FOR THE CITY OF CANTON, IN CONNECTION WITH THE DESIGNATION OF THE INTERNATIONAL HARVESTER SITE REDEVELOMENT PROJECT AREA. RESOLUTION - ASCERTAINING THE PREVAILING RATE OF WAGES FOR LABORERS, MECHANICS AND OTHER WORKMEN EMPLOYED IN ANY PUBLIC WORKS BY THE CITY OF CANTON, ILLINOIS. RESOLUTION -CANTON PRIDE COMMITTEE TO HOLD A 4~ OF JULY PARADE FROM 7:00 P.M. TO 8:00 P.M. EXECUTIVE SESSION - NEGOTIATIONS, GRIEVANCE & PERSONNEL - PURPOSE OF DISCUSSING PUBLIC WORKS CONTRACTS. STATE OF ILLINOIS ) SS COUNTY OF FULTON ) CERTIFICATE AND REQUEST OF THE CITY OF CANTON FULTON COUNTY, ILLINOIS, ON DELTi~ERY OF CERTIFICATES We, the undersigned, do hereby certify that we are the officers of the City of Canton, Fulton County, Illinois (the "City "), whose names and offices are, respectively, as follows: NAME OF OFFICER OFFICE HELD Jerry M. Bohler Mayor Nancy S. Whites City Clerk Patty Beaird Franzoni City Treasurer A. PURPOSE OF THIS CERTIFICATE This certificate is given in connection with the delivery by the City of its $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004 (the "Certificates "). The Certificates have been issued pursuant to the authorization contained in Ordinance Number 1802 of the City, adopted by the City Council on June 15, 2004 (the "Ordinance "). The Certificates are being delivered to MidAmerica National Bank, Canton, Illinois (the "Purchaser "). The Certificates are being authenticated by MidAmerica National Bank, Canton, Illinois (the "Certificate Registrar "), as certificate registrar and paying agent on the Certificates. B. EXECUTION OF CERTIFICATES We the undersigned Mayor and City Clerk (only) have caused the execution of each of the Certificates by our facsimile signatures, as appearing thereon, in the principal amount as shown above. The Certificates are dated as of June 15, 2004 (the "Dated Date "); and shall become finally due and payable (without option of prior redemption) on December 15 of the years and in the amounts and bearing interest at the rates percent per annum as follows: YEAR AMOUNT ($) RATE (%) 2009 $1,200,000 3.04 Each Certificate shall bear interest from the later of its Dated Date or from the most recent interest payment date to which interest has been paid or duly provided for, until the principal amount of such Certificate is paid or duly provided for, such interest (computed upon the basis over a 360-day year of twelve 30-day months) being payable on June 15 and December 15 of each year commencing December 15, 2004. We have executed each of the Certificates in the manner and capacity indicated by our signatures and the titles subscribed hereto. We aze now and were at the time of the adoption of the Ordinance and have continuously in such period been the duly chosen, qualified and acting officers indicated by said titles. There has been impressed on each of the Certificates the official seal or facsimile thereof of the City. C. CITY DOCUMENTS; AUTHENTICATION 1. The Ordinance was adopted on June 15, 2004; and the record of proceedings of the Corporate Authorities on said date does properly reflect due adoption of the Ordinance (which ordinance and meeting may be referred to, collectively, as the "City Proceedings "). The Ordinance authorized each of the following documents or instruments to be delivered by the City in connection with the issuance of the Certificates, all of which, as executed and delivered by the proper officers of the City, aze in form as authorized, enumerated as follows; DOCUMENT DATE OTHER SIGNATORY PARTY OR PARTIES Installment Purchase Agreement June 15, 2004 City Treasurer, (the "Agreement ") as Nominee Seller All of the aforesaid are herein collectively referred to as the "City Documents " 2. We aze (one or more) the persons signatory to the City Documents; we were on the date or dates of the execution of the City Documents and aze on the date hereof the duly elected -2- and qualified incumbents of the offices of the City as set forth therein and herein; and the signatures appearing at the right of our respective names at the end of this Certificate are our genuine signatures. 3. The City has duly authorized, executed, and delivered by all necessary action the Certificates and the City Documents; and as of the date hereof, each is in full force and effect and each constitutes the valid, binding, and enforceable obligation of the City; and the City is entitled to the benefits of the same. The City has authorized by all necessary action the execution, delivery, receipt, and due performance of the Certificates and the City Documents and any and all such other agreements and documents as may be required to be executed, delivered, and received by the City in order to carry out, give effect to, and consummate the transaction contemplated by the Certificates, the Ordinance, and the City Documents. No other consent, approval, authorization, or order of any court or governmental agency or body is required for the issuance, delivery, or sale of the Certificates or the consummation of the other transactions effected or contemplated in or by the Certificates, the Ordinance, and the City Documents, except such as may be required under the "Blue Sky" or other securities laws or regulations as may be required in connection with the offer and sale of the Certificates by the Purchaser. 4. The Seal affixed to this Certificate and Request and which has been affixed to the Certificates and the City Documents (where required) is the legally adopted, proper, and only official corporate seal of the City. 5. All of the conditions and agreements provided in the Ordinance and the City Documents to be satisfied or performed by the City at or prior to the issuance and sale of the Certificates have been satisfied or performed in the manner and with the effect contemplated therein. -3 - D. NON-LITIGATION, NO BREACH OF OBLIGATION AND NO DEFAULT 1. No controversy or litigation is threatened or pending in any court; no referendum or public vote is threatened or pending; and no action, suit, inquiry, investigation, or proceeding at law or in equity before or by any court, governmental agency, authority, body, board, or arbitrator is threatened or pending (a) seeking to prohibit, restrain, or enjoin the execution of the City Documents or the issuance, sale, or delivery of the Certificates or the payment, collection, or application of the revenues or taxes pledged or to be pledged to pay the principal of and interest on the Certificates or the pledge thereof or the expenditure of the Certificate proceeds; (b) in any way questioning or affecting the validity of the Ordinance or any of the City Documents or any proceedings taken by the City with respect to the foregoing; {c) questioning or contesting the City's creation, organization, or corporate existence, the titles to office of any of its officers. or its power to engage in any of the transactions contemplated by the Ordinance, the other City Proceedings relating to the Certificates, or to levy or impose real estate taxes for municipal purposes; (d) questioning the exemption of interest on the Certificates from federal income taxation; or (e) in any way contesting or affecting the execution or delivery by the City of the Certificates or the City Documents. 2. The City is not in breach of or default under any applicable law or administrative regulation of the State of Illinois or the United States of America, or any applicable judgment or decree, or any loan agreement, note, regulation, or other agreement or instrument to which the City is a party or is otherwise subject, which breach or default would in any way materially adversely affect the authorization or issuance and delivery of the Certificates or the City Documents; and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute such a breach or default; and the execution and delivery of the City Documents and the Certificates, and the adoption of the Ordinance, and -4- compliance with the respective provisions thereof, will not conflict with or constitute such a breach or default. 3. Upon the issuance of the Certificates, (a) no event of default exists under the Agreement or the Ordinance upon the part of the City, and (b) no event which with notice or with lapse of time or both would become an event of default has occurred. E. RECEIPT 1. Regarding receipt of funds for the Certificates, the City, by the undersigned City Treasurer, has received from the Purchaser the purchase price of the Certificates as follows: ITEM Principal (Par) Accrued Interest Total AMOUNT ($) 1,200,000.00 3,040.00 1.203.040.00 in compliance with the Purchase Agreement. 2. The amounts received from the sale of the Certificates will be deposited under and used pursuant to the Agreement as described in the Ordinance. 3. Simultaneously and as a part of the same transaction as the issue and delivery of the Certificates, the undersigned Treasurer deposited the proceeds of sale of the Certificate as follows: PURPOSE To pay interest on the Certificates To acquire the property under the Agreement TOTAL TO FUND AMOUNT ($) Certificate Fund as created under 3,040 the Ordinance Project Fund as created under the 1,200,000 Ordinance 1 203 040 -5- F. OTHER FINANCIAL REPRESENTATIONS The total aggregate indebtedness of the City, howsoever evidenced and howsoever incurred, including the Certificates, does not exceed the sum of $ ,which is not greater than any lawful limitation for the City [number should equal the total indebtedness figure on the indebtedness certificate]. G. REQUEST Pursuant to the provisions of the Ordinance, the Certificate Registrar is hereby requested to authenticate the Certificates in accordance with the Ordinance and deliver the Certificates to the Purchaser. H. NO CONFLICT OF INTEREST No person holding any office of the City, either by election or appointment, is in any manner financially interested, either directly in his own name or indirectly in the name of any other person, association, trust or corporation, in the transaction effected by the Purchase Agreement. I. NON-ARBITRAGE AND TAX EXEMPTION All of the certifications, conclusions, expectations, representations and statements made and set forth by the Corporate Authorities in Section 15 of the Ordinance are still reasonable and true; that the foregoing certification is based in part upon the amounts set forth in said section of the Ordinance having actually been received and paid into the various funds and accounts of the City as set forth in said section; that the undersigned have reviewed the facts, estimates and circumstances in existence on the date hereof and such facts, estimates and circumstances, together with the expectations of the City as to future events, are set forth in summary form in said section; that said facts and estimates are true and are not incomplete in any material respect; and that such expectations are reasonable and there are no other facts, estimates or circumstances that would materially change such expectations. -6- 1. REPRESENTATIONS INCONNECTION WITH SALE OF CERTIFICATES We do further certify that to the best of our knowledge and belief all Official Statements, Notices of Sale and other documents, information or materials, together with any supplements thereto, distributed and all representations made by the City and by its officials in any manner whatsoever in connection with the sale of the Certificates were at all times and are now true and correct in all material respects and did not at any time and do not now contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made therein, in light of the circumstances under which they were made, not misleading; that the City has duly performed all of its obligations under the Ordinance to be performed on or prior to the date hereof; and that all representations and warranties of the City contained in all contracts entered into by the City providing for the sale of the Certificates are true and correct on and as of the date hereof as if made at the date hereof and the City has complied with all of the agreements and satisfied all the conditions on its part to be performed or satisfied prior to the date hereof. K. CONTINUING DISCLOSURE UNDERTAKING We do further certify that the City is in compliance with each and every undertaking previously entered into by it pursuant to Rule 15c2-12 adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934. -7- WITNESS IN WcrNESS WHEREOF we have hereunto affixed our official signatures and the seal of the City this 15th day of July, 2005. TITLE Mayor, City of Canton, Fulton County, Illinois SIGNATURE City Clerk, City of Canton, Fulton County, Illinois City Treasurer, City of Canton, Fulton County, Illinois [SEAL] -8- SIGNATURE IDENTIFICATION I hereby certify that I am ~%~-c1.~1,,.~-~: U .~-~ ~ ~~-,~.~ of MidAmerica National Bank, Canton, Illinois, and that I am personally acquainted with the officers whose signatures appear above, and that I know they are now the duly qualified and acting officials of the City, as indicated by the titles appended to said signatures, and that I hereby identify said signatures, together with those facsimiles as appearing on the above-described Certificates, as being in all respects true and genuine. IN WITNESS WHEREOF I have hereunto subscribed my official signature and impressed hereon my seal as of the date subscribed to the foregoing certificate. ~; [AFFIX BANK SEAL HERE] -9- i FROEHLING~ WEBER & EVANS ATTORNEYS AT LAW Ralph Froehling Ronald J. Weber Michael E. Evans Nancy A. Schell Susan M. Maxwell July 15, 2004 City Council City of Canton Fulton County, Illinois Chapman and Cutler LLP Chicago, Illinois Ladies and Gentlemen: 167 West Elm Street Canton, Illinois 61520 (309) 647-6317 Fax (309) 647-6350 www.fwelaw.com MidAmerica National Bank Canton, Illinois I am the attorney for the City of Canton, Fulton County, Illinois (the "City "), and in connection with the issuance on this date by the City of its $1,200,000 General Obligation Limited Tax Debt Certificates, Series 2004 (the "Certificates "), I have examined the public records, proceedings, and documents of the City in connection with the issuance of the Certificates which I consider necessary for the purpose of this opinion, including the following: (a) Ordinance Number 1802 (the "Ordinance "), duly adopted by the City Council of the City (hereinafter "Corporate Authorities ") on the 15th day of June, 2004, and the minutes of the meeting of the Corporate Authorities showing the adoption of same (collectively the Ordinance and minutes so described being "City Proceedings "); (b) The following document of the City as authorized, described and defined in the Ordinance: INSTALLMENT PURCHASE AGREEMENT for purchase of real or personal property, or both, for the purpose of undertaking a redevelopment project, in and for the City of Canton, Fulton County, Illinois. as executed by the Mayor and City Clerk of the City, as Purchaser, and the Treasurer of the City, as Nominee-Seller, together with a "Certificate of Installment Purchase Agreement Filing," as executed by the City Clerk (said agreement and filing certificate, collectively, the "City Documents "). ~' Based upon the foregoing and upon such other information and documents furnished to me as I believe necessary to enable me to render this opinion, I am of the following opinion: 1. The City is a duly organized and operating municipality and unit of local government of the State of Illinois, operating, among other laws, under the provisions of the Illinois Municipal Code, as amended, the Open Meetings Act, as amended, and the Local Government Debt Reform Act, as amended (collectively, "Illinois Law "). 2. The City Proceedings are presently in full force and effect and have not been repealed or rescinded or amended; and the Corporate Authorities have not adopted any other ordinance, resolution, or other proceeding affecting in any manner the procedures for or the issuance of the Certificates. 3. The City has no special ordinances of limitation or procedural ordinance, rule, or order relating to the issuance of general obligation corporate purpose bonds, notes, or certificates for corporate or refunding purposes without referendum; and there is no City-imposed limitation upon the amount of its existing debt different in any way than Illinois Law. 4. The City Proceedings were held in compliance with Illinois Law and applicable City procedures. 5. Each of the City Documents was duly authorized in the Ordinance and (where applicable) has been duly executed and delivered by proper officers of the City as so authorized, and assuming, in the case of multiparty documents, the due authorization, execution, and delivery by the other parties thereto, constitutes the valid and binding agreement of the City in accordance with its terms. 6. After due inquiry of appropriate City officials and agents and to the best of our knowledge and belief, (a) there is no action, suit, proceeding, or investigation, at law or in equity, before or by any court or any governmental agency or public board or body, pending against the City or, to our knowledge, threatened against the City, to restrain or enjoin, or threatening or seeking to restrain or enjoin, the issuance, sale, or delivery of the Certificates or the collection of taxes or other amounts pledged or to be pledged to pay the Certificates or in any way contesting or affecting the validity of the Certificates or in any way questioning or affecting (1) the City Proceedings; (2) the validity or enforceability of any provision of the Certificates or any of the City Proceedings; (3) the authority of the City to impose or collect the pledged taxes or other funds pledged to the payment of the Certificates; or (4) the legal existence of the City, the right of its officers to their offices, the City's authority to perform its obligations pursuant to the City Proceedings or with respect to the Certificates or to consummate any of the transactions to which it is or is to be a party as contemplated by the City Proceedings, or the City Documents; and (b) there is no action, suit, proceeding, or investigation, at law or in equity, before or by any court or any governmental agency or public board or body, pending against the City or, to our knowledge, threatened against the City, involving any -~- of the property or assets within the City which may result in any material adverse change in the revenues, assets, or the financial condition of the City. 7. Upon due inquiry of City officials and agents, to the best of our knowledge and belief, there is no action, suit, proceeding, or investigation at law or in equity before or by any court, public board, or body pending, threatened against, or affecting the City wherein an unfavorable decision, ruling, or finding would in our judgment in any way materially and adversely affect the transactions described in or contemplated by any of the City Proceedings or City Documents or the validity or enforceability of the City Documents or the Certificates. 8. There is no lien or encumbrance on any of the taxes or the other funds pledged to the payment of the Certificates that is senior to the claims of the holders of the Certificates; there is to our knowledge no existing, pending, threatened, or anticipated event or circumstance which might give rise to any lien or encumbrance on any such taxes or the other funds pledged to the payment of the Certificates which would be senior to the claims of the holders of the Certificates. 9. No additional approval, permit, consent, authorization, or order from any court or any governmental or public agency, authority, or person not already obtained is required with respect to the authority of the City in connection with the authorization, issuance, and sale to the purchaser of the Certificates or for the adoption or effectiveness of any of the City Proceedings or City Documents. 10. As of the date of this opinion, the adoption of the City Proceedings, the execution of delivery by the City of the Certificates and the City Documents and compliance by the City with the provisions thereof under the circumstances contemplated thereby, do not and will not violate any applicable judgment, order, or regulations of any court or of any public or governmental agency or authority of the State of Illinois and will not conflict with or result in a breach of any of the terms and provisions of or constitute a default under any existing law, court or administrative regulation decree, order, or any agreement, indenture, mortgage, lease, or other instrument to which the City is subject or by which it is or may be bound. Very truly yo rs, By Ronald Weber, City Attorney -3- STATE OF ILLINOIS ) SS COUNTY OF FULTON ) CLOSING CERTIFICATE OF THE CITY We, the undersigned, do hereby certify that we are the duly qualified and acting Mayor and City Clerk, respectively, of the City of Canton, Fulton County, Illinois (the "City "), and as such officials we do further certify as follows: 1. The representations and warranties of the City contained in the Installment Purchase Agreement, dated as of June 15, 2004 (the "Agreement "), by and between the City and the Treasurer of the City, as Nominee-Seller (the "Seller ") are true and correct in all material respects at and as of the date hereof with the same effect as if made on this date. 2. In connection with the issuance of its General Obligation Limited Tax Debt Certificates, Series 2004 (the "Certificates "), to MidAmerica National Bank, Canton, Illinois, (the "Bank "), the City has furnished the Bank all material facts concerning the City, the Agreement and the Certificates, including the audits and financial reports concerning the City, necessary to insure that the Bank was able to make a fully informed investment decision on the Certificates. 3. The City has carefully and conservatively analyzed its current and future financial resources and has concluded that such financial resources are and will be completely adequate to pay the principal of and interest on the Certificates when the same become due without impairing in any respect whatsoever the ability of the City to provide the usual and customary municipal services in and for the City. 4. The City has complied with all the agreements and satisfied all the conditions on its part to be performed or satisfied on or prior to the date hereof as set forth in or required by the Agreement. IN WITNESS WHEREOF, we hereunto affix our official signatures and the seal of the City, this 15th day of July, 2004. ~- ~ Mayor ~. ~ ') City C k [Seal]