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Miami Beach RDA Sf) A 771:JWr liAS /J/:l:X OR If'!U Ii/:' '\(MI/: HI UWl'lJ' \\1111 URJ:.tLV RI:!jUIII/:.IIhVIS N1:l.AJlM; HI JIll:' I"SCHISm,V FRO'\( GROS\' INUW/:' lOll 1-1:/)/:11.11, INUW/:' lAX I'URHiS/:S OF I,V11:RJ:'IT ON 11//:' ,II:RlI:S 1~~8A nO,\lJS 1,\1l:R1:SION FIll: S/:RI/:S 19~8A nONDS IS INUJ!J)A/J/J:' IN GRUIS INCO,\(I:' OF JIll:' I}()WI:R,I FII/:R/:()F H)R IH)I:RAI. INOW/:' TAX I'URI'UI/:S. III Ibe opillioll oJ /ioml COllnsel. IIlliler existillg lau: (i) assl/ll/il/g col/til/llil/g colllplimlce by Ibe Age/Ie)' u.itb ce/1aill COI~'lllIIlts, illtefl!sl OIl Ibe Series 19~81J IJmuls is exclllded J/VIII g/Vss iI/collie Jilr Jedeml iI/collie liLt Pllrposes; ami (ii) illlelPslOlI Ibe Serie.I' 1Y~81J /i()/uls is 1101 all il(~1/ of lax IlIt'ferellw Jor Pllrposes of Ibe Jedeml allen/atil.,. lIIillillll/lll lar imposed 01/ Illdil'idllals alul wrpomtilJlls. Ikllld Crmmel is Jllrll)('r oJ Ibe opilliolllballbe Sen'es 1~~8A nomls alllllbe Series 1~~81i nlJluls (colledil'e!): the "Series 1 f)5)8 Bonds ") llW/ the income tI)('1tJ()1l tltt' e..\'emIJ/ from ltl.\'lltirJ1l wuler /be laws of the Slale (!{ Hmidll, ('-"({1)l Jill' eslate taxes iJJlI}()setll~)! Challler 198, Honda Slatllles, as amended, llnd 1let ;llrfJIne mul./itmc!.Jise taxes imj)()sed '~)' OW/J/l!r 110, HWi't!a Sla/fltes, as amended, Oil illten'sl, imvme or lJ1r~rils Oil debt oIJ/iRaUoIlS oU'ned by "tor/)()rll!iOIlS", "blinks" tlnd "savings ass(}cia!irnls", tiS t1(~filled (/X'1l.!i1l. 11I1t'rr.-st OIl tbe Series I~Y81J BOllds lillO' 1)(' su!Jj('ct to (w1aill fedef'a[tlL\'es im/Jo,wd (J1l~)' Oil (erMill Cm1JO!HtioIlS, im'l1ulillg the allenlllli,'(' milli1l1li1Jltax imposed OIll//NU'lioll (~rlbal in/ell'S'. Fora mOil' (mll/'/de discllssion ofo/ber tlLY cOllSel/uell(f!S (,./ownersln/J of the Selies /998lJollds, see tbe l!l:,'ulssiml under/be heading "lilx MalleI'S" bell'ill. NEW ISSUE - BOOK-ENTRY ONLY RatinllS: Moody's: Aaa Standard & Poor's: AM (M8IA Insun'<i) (x'C "RATINGS" herein) MIAMI BEACH REDEVELOPMENT AGENCY $29,105,000 Tax Increment Revenue Bonds, Taxable Series 1998A (City Center/Historic Convention Village) and $9,135,000 Tax Increment Revenue Bonds, Series 1998B (City Center/Hi.,toric Convention Village) Datcd:July 1, 1')')8 Due: /X-cemher I, as shown on the inside cover The lax Inerement Reeenue BonlL.. laxable ~eries 1998A (City Center/llistorie ConeC11tion Village) (tbe "Series 1~98A Bonds") and the Ttx Increment Reeenue Bonds. Series 19911B (City Center/llistoric COIll'ention Villagc) (the 'Series I 998B Bonds". and. collectieely with the Series 1998A Ilonlls. the "Series 1998 Bonds") are heing issucd hy the Miami Beach Redeeelopment Agency (the "Agency") in blx,k-t'ntry form. rt'gistered in the name of Cede & Co., as rt'gistered owner and nomint'e for 111e Depository 'Irust Company. New York, New York ("111'("). which will act as securities depository for the Series 19911 Bonds. Pureh:Lsers of the St'rics 1998 Bonds ("Benclkial Owners") will not recciee physical delivery of bond certificates. Ownership by the lleneficial Owners of interests in the Series 19911 BonlL. will be evidenced by a Ix)ok-entry-only system of regis!r;ltion. Accordingly. principal of and interest on the Series 1998 Bonds will Ix paid from the sources described Ixlow by First Union National Bank, Miami. Florida, as lftLstee, Paying Agent and Registrar for the Series 19911 lIonds. directly to IITC as the registered owner thereof. See "DESCRWIlON OF TilE SERIES 1998 BONDS" hert'in.lnlerest on the Series 1998 Bonds will be payable lIeeember 1. 1998 and semiannually on each June I and December 1 thereafter. The Series 1998A Bonus arc being issueu to (i) pay the costs of the Series 1998A Project. as described herein, whieh rdates to the City Center/Ilistoric Convention Village Redccelopment and Rnitali7"ttion Area (the "Redevelopment Area") of the City of Miami Beach. Florida (the "City"). includin~ repayment of any portion of the Cily Loan (herein defined) related to the Series 1998A Projt'ct: and (ii) pay the costs of issuance of Ihe Series 1998A Bonlls. '1l1e Serit's 1998B Bonds are Ixin~ issued to (i) pay the eosts of the Series 1998B Project. as described herein. relatin~ to the Redeeelopment Area. includin~ repayment of any IXlrtion of the City Loan related 10 the Series 1998B Project: and (ii) pay the costs of iss\L1nee of Ihe Series 19')8B Bomls. '111t' Series 19')11 Bomls are i$Sut'l1 pursuant 10 Chapter I ('." 1~lrt III, Florida Statutes. Chaptt'r I ';9. I~lft VII. Florida Statules. the Code of Ihe City of Miami lleach. Florida. and the Code of Miami-Dadt' County, Florida, each as amended. ami other applieable provisions of law (the "Act"), and Resollllion No. I ';O.9{ duly adoptt'd by the Chairman and Memlxrs of the Agency on January S. 19'J.i. as supplemented by Resolution No. 297-98 adopted on July 1. 1998 (collectively. the "Resolution"). The Series 1998 Bonus and tbe interest thercon arc payable from and seeuted solely by a lien on and pled~e of the rlcd~ed Funds, which include (i) the Net Trust Fund Rn'enut's, as descrilxd hercin, reecieed by the Agency from the Redlwlopment Area. (ii) until released as deseribnl herein. the portion of the proeeccls of the City's municipal resort tax In'jed and collel1ed by the City (the "Supplcment:t1 Rnenues") and reeeieed by the 'Irustee. and (iii) moneys and ineestments in the funds and accounts (other than the Rebate Fund) created unuer the Resolution. 'Il,e lien on the Net 'Irust Fund Reeenues is on a parity with Agency's 'nIX Inercment RevC11ue Ilonds. Series 199:\ (City Center(11istoric Coneention Village) outsLlnding in the aggregate principal amount of $2:\.200,000 (the "Series 199.' Ilonds"), its '!:IX Increment Revenue Bonds. hxablc Series 19%A (City Center/llistoric Cotll'C11tion Village) outstanding in the aggregate principal amount of $:\6,680,000 (the "Series I~%A Bonds") and its lax Incremenr Revenue Bonlls, Series 199(,B (City Center/llistorie Convention \'tllage) outst:mding in the aggreg.1le principal amount of $7.:\80,000 (the "Series 19'X,llllonlls" and, together with the Series 199:\ Bonds, the Series 19%A IIonds, the Series 19911 Bonds and any additional bon(ls is.sued on a parity therewilh, the "lIonds"). '111e lien on the Supplemental Revenues is junior and subordinate to the lien on Ihe proceeds of such municipal resort L1X in favor of the bolders of the City's Resort 'EIx Reeenue Refunding Bonds. Series I ~%. outstanding in the aggregate principal amount of $:1.910,000. and is on a parity with the Series 19')\ lkmd.s, the Series 19%A Bonds and the Series t~%B Ikll1ds. See "SECURflY FOR '1111' SERIES 1998110NDS - SupplemC11tal Reyel1lles" herrin. '1l1t'Series 1998 Bonds willlx subjt'et 10 optional and mandatory redcmption prior to malurily by the Agency as deseribed herein. The Series 1998 Ilonds, the premium, if any, and the interest thereon shall not he or constitute ohligations or indebtt.'(lncss of the AIIeney (or "honds- within the meaning of the COILstitution of the State of Florida), hut shall be payahle from and sccun-d solely by a lien UIXlII and a pk'dge of the I'k'<iged Funds, as provided in the Rcsolution. No lIolder of any Series 1998 Ilond shall ever have the riRlIl to compel the exercise of the ad valorem taxing IXlwer of the City, Miami-Dade County. Florida (the "County"), the State of Florida or any political sulx1i\'ision thereof or taxation in any form on any property within or wilhout the City or the County to pay the Serics 1998 Bonds, the premium, if any, or the interest thereon or he entitk'd to payment of such principal, premium, if any, and interest from any other funds of the Agency e.."eept from the Pledged Funds in the manner provided in the Resolution. The Series 1998 Ilonds, the premium, if any, and the interest thermn shall not Ita,'e or be a lien upon any property of the Agenl'}' or of or in the City, other than the Pk'dgcd Funds in the manner prm1ck'<i in the Resolution. The Agency has no taxing power. Timely payment of the principal of and interest on eaeh Series of the ~eries 1998 Bonds is guaranteed. respeetieely. under two separate financial guaranty insu\'Jnee policies to lx issued by ,',mlA Insurance Corporation simullancous~' wilh the deli,'er)' of Ihe Series 199811onds. See "MUNICIPAL BOND INSURANCE" herein. MBIA FOR MArtJRITY SCIIF.DUI.E, SEE INSII>E FRONT COVER 'Il,e Series 19')11 Bonds arc offered whm, as and if issut'd and accepted b)' Iht' Underwriters subject to the apprO\in~ opinion of Squire, Sanders & Dempse)' L1..I~. Miami. Florida. Ilond Counsel. Certain 1rg,11 mailers will be passed on for the A~t'lllT and the City by ,',lurray It. Dubbin, City AlIomey and General Cuunscl 10 Ihe A~ene}', ,',Iiami lleach. FlorilLl. and for Ihe Underwriters by their counsel. Ruden. McClosky. Smith, Schuster & Russell, I'A. and Dennis Scholl, I'A. [Jain R.1(lSCher Incorpor.lted is acting as Financial Ad,;sor to the A~enlT in connection with the issuance of Ihe Series 19')11 Ikll"ls. 'Ille Series 1998 Bonds are eXlxeted to Ix dt'livned in definiti,'e form to the Underwriters in Nlw York. Nlw York. on or alxllItJuly 29.19911. William R. Hough & Co. Dated JlI~' 22, 19')8 PaineWebber Incorporated Prudential Securities Incorporated Maturity Schedule $29,105,000 Taxable Series 1998A Bonds --' ~'.. ,:l:~;,~~', $13,885,000 6.70% Term Bonds Due December 1, 2014, Price NRO, Yield NRO $10,000,000 6.68% Term Bonds Due December 1,2020, Price 100,00, Yield 6.68% $5,220,000 7.00% Term Bonds Due Dccember 1, 2022, Price 99.179, Yield 7.07% Maturity (December 1) 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 $4,440,000 Serial Bonds $9,135,000 Series 1998B Bonds Principal Atnount $215,000 225,000 235,000 245,000 255,000 265,000 275,000 290,000 300,000 315,000 330,000 345,000 365,000 380,000 400,000 Interest Rate 3,60% 3.85 3.95 4.05 4.10 4.15 4.30 4.40 4.45 4.50 4.60 4.70 4.80 4.90 4.95 Yield 3.60% 3.85 4.95 4.05 4.10 4.15 4.30 4.40 4.45 4.50 4.60 4.70 4.80 4.90 4.95 Price 100,00 100.00 100.00 100.00 100.00 100.00 100.00 100,00 100.00 100.00 100.00 100.00 100.00 100.00 100.00 $2,335,000 5. 15'){, Term Bonds Duc Dcccmber 1, 2018, Price 99.369, Yield 5.20% $2,360,000 5.20% Term Bonds Due December 1, 2022, Price 99.310, Yield 5.25% , , MIAMI BEACH REDEVELOPMENT AGENCY 1700 Convention Center Drive Miami Beach, Florida 33139 Chairman Neisen Kasdin Vice Chairman Nancy Liebman Members Simon Cruz David Dermer Susan F. Gottlieb Martin Shapiro Jose Smith Executive Director of Agency Sergio Rodriguez Bond Counsel Squire, Sanders & Dempsey L.L.P. Miami, Florida Financial Advisor Dain Rauscher Incorporated Miami, Florida General Counsel of Agency Murray H. Dubbin ~ .. , ll!.~~~!.' . This Official Statement does not constitute an offer to sell the Series 1998 Bonds in any jurisdiction to any person to whom it is unlawful to make such offer in such jurisdiction. No deale;, salesman or othcr person ha'i bccn authorized to give any information or to make any representation other than those contained hcrein and, if given or made, such other information or representation must not be rclicd upon as having bccn authorizcd hy thc Agcncy or any othCl" pcrson. Ncither the delivery of this Official Statcment nor thc salc of any Serics 1998 Bonds implies that there has been no changc in the mattcrs dcscdbed hcrcin sincc thc datc hcrcof. TilE SERIES 1998 BONDS I1A VE NOT BEEN REGISTERED WITH THE SECURITIES AND EXCHANGE COMMISSION UNDER TIlE SECURITIES ACT 01" 1933, AS AMENDED, NOR liAS TilE RESOLUTION BEEN QUALIFIED UNDER TIlE TRUST INDENTURE ACT 01<' 1939, IN HELJANCE UPON EXEMPTIONS CONTAINED IN SUCII ACTS. TIlE REGISTRA TION OR QUALIFICATION OF TIlE SERIES 1998 BONDS IN ACCORDANCE WITH APPLICABLE PROVISIONS OF TIlE SECURITIES LAWS OF TilE STATES, IF ANY, IN WIIICH TilE SERIES 1998 BONDS HAVE BEEN REGISTERED OR QUALU'IED AND TIlE EXEMPTION FROM REGISTRATION OR QUALIFICATION IN CERTAIN OTHER STATES CANNOT BE REGARDED AS A RECOMMENDATION THEREOF. NEITHER THESE STATES NOR ANY OF THEIR AGENCIES HAVE PASSED UPON THE MERITS OF THE SERIES 1998 BONDS OR TIlE ACCURACY OR COMPLETENESS OF THIS OI~FICIAL STATEMENT. ANY REPRESENTATION TO TIlE CONTRAUY MAYBE A CUIMINAL OFFENSE. IN CONNECTION WITH THIS OFFEUING, THE UNDEUWRITERS MA Y OVEUALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OU MAINTAIN THE MAUKIn PRICE OF THE SERIES 1998 BONDS AT A LEVEL WHICH MIGHT NOT OTHERWISE PIffiVAIL IN TIlE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAYBE DISCONTINUED AT ANY TIME. The information set fOl.th hcrein has bccn obtain cd fl"Om the Miami Bcach Ucdcvelopment Agency and thc City of Miami Bcach, Florida and othel" SOUl"CeS that are believed to be reliablc, but is not guarantecd as to accnl'acy or completeness by, and is not to be constnlcd as a I"CPl'csentation of, the Undcl"\n-itcrs 01", as to information from other SOUl"CeS, the Miami Beach Ucdevclopmcnt Agcncy or thc City of Miami Bcach, Florida. Refcrcnccs hel"ein to laws, rulcs, l"cgulations, l'esoIutions, agl"eelllents, reports and other documents do not pUl"f)ort to be compl"ehcnsive 01" definitive. All references to such documents are qualified in theh- entirety by refel"enCe to the pmiicular document, the full text of which may contain <jualifications of and exceptions to statements made herein. The information and the expressions of opinion herein al"e subject to change without notice, and neithCl" the delivcry of this Official Statcment nor any sale madc hel"CUllder shall, under any circumstanccs, create any implication that there has becn no change in the affah-s of the Miami Beach Redevelopment Agency or the City of Miami Beach, Florida since the date hel"Cof or thc earliest date as of which such infol'lnation is givcn. TABLE OF CONTENTS Page INTRODUCTION DESCRIPTION OF THE SERIES 1998 BONDS ..........,...................... 2 General Description . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2 Book-Entry-Only System ..........................,................. 3 Additional Provisions Regarding Book-Entry System ....,...............,..... 4 Redemption . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5 Notice and Effect of Redemption ....................................... 8 ESTIMATED SOURCES AND USES OF FUNDS .............................. 10 DEBT SERVICE SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. II PROJECTED DEBT SERVICE COVERAGE ......,.,........................ 12 SECURITY FOR THE SERIES 1998 BONDS ................................. 13 Generally ..................................................... 13 Net Trust Fund Revenues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13 Application of Trust Fund Revenues .................................., 17 Supplemental Revenues ....,....................................... 18 Debt Service Reserve Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 24 Additional Parity Bonds . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . , . . . . . . .. 25 Investment of Funds .............................................. 26 Pooling of Money in Funds and Accounts ................................. 27 MUNICIPAL BOND INSURANCE. . . . . . . , . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . .. 27 General. . , . . . . . , . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . .. 27 The Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 27 THE AGENCY ...................................................... 29 Generally ..................................................... 29 The Redevelopment Plan ..................,........................ 29 Management of the Agency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 30 Fiscal Matters ...............,.................................. 30 Assessed Valuations .........................,.................... 31 THE PROJECT . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . .. 31 SUMMARY OF CERTAIN PROVISIONS OF THE RESOLUTION , . . . . . . . . . . . . . . . .. 33 Payment of Bonds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33 Enforceability of Collections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33 Accounting Records and Annual Audit ...,.............................. 33 Credit Facility/Liquidity Facility ...................................... 33 Modification or Amendment ... . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . , . . . . ., 34 Remedies ............................,......................,. 35 Discharge and Satisfaction of Bonds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 35 1 ilJ'.." RISK FACTORS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 37 General. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . .. 37 Tax Increment Financing ..............,............................ 37 Supplemental Revenues .......,......................,......,...... 38 LITIGATION ....................................................... 39 LEGAL MATTERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 39 TAX MATTERS ........................,............................ 39 Series 1998A Bonds ........,..................................... 39 Series 1998B Bonds . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 40 ORIGINAL ISSUE DISCOUNT . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 41 ENFORCEABILITY OF REMEDIES . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . , . . . . .. 41 UNDERWRITING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 41 RATINGS. . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 42 ADVISORS AND CONSULTANTS ........................................ 42 DISCLOSURE MATTERS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 42 Certificate as to Official Statement .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 42 Continuing Disclosure ........,.........,........................., 43 Miscellaneous .................................,.........,...... 43 APPENDIX A -- GENERAL INFORMA nON CONCERNING THE MIAMI BEACH REDEVELOPMENT AGENCY, THE CITY OF MIAMI BEACH AND MIAMI- DADE COUNTY, FLORIDA THE RESOLUTION CITY RESOLUTION NO. 94-21008 CONTINUING DISCLOSURE AGREEMENT FORM OF BOND COUNSEL OPINION SPECIMEN MUNICIPAL BOND INSURANCE POLICY APPENDIX B -- APPENDIX C -- APPENDIX D -- APPENDIX E-- APPENDIX F -- 11 INTRODUCTION OFFICIAL STATEMENT relating to MIAMI BEACH REDEVELOPMENT AGENCY $29,105,000 TAX INCREMENT REVENUE BONDS, TAXABLE SERIES 1998A (CITY CENTER/lIISTORIC CONVENTION VILLAGE) and $9,135,000 TAX INCREMENT REVENUE nONDS, SERIES 1998n (CITY CENTER/lIISTORIC CONVENTION VILLAGE) The purpose of this Official Statement, which includes the cover page and the Appendices hereto, is to furnish information with respect to the issuance by the Miami Beach Redevelopment Agency (the "Agency"), of its Tax Increment Revenue Bonds, Taxable Series 1998A (City Center/Historic Convention Village) in the aggregate principal amount of $29,105,000, (the "Series 1998A Bonds") and its Tax Increment Revenue Bonds, Series 1998B (City Center/Historic Convention Village) in the aggregate principal amount of $9,135,000 (the" Series 1998B Bonds" and, collectively with the Series 1998A Bonds, the "Series 1998 Bonds") issued pursuant to Chapter 163, Part III, Florida Statutes, as amended, Chapter 159, Part VII, Florida Statutes, as amended, and other applicable provisions of law (the" Act"), and Resolution No. 150-94, duly adopted by the Chairman and Members of the Agency on January 5, 1994. as supplemented by Resolution No. 297-98 adopted on July I, 1998 (collectively, the "Resolution"), and is subject to all the terms and conditions of the Resolution. The issuance of the Series 1998 Bonds has been approved by the City of Miami Beach, Florida (the "City"), by Resolution No. 98-22820 adopted by the Mayor and City Commission of the City on July 1, 1998 (the "City Approving Resolution"), and by Miami-Dade County, Florida (the "County"), by a resolution adopted by the Board of County Commissioners of the County on July 7, 1998. First Union National Bank, Miami, Florida, is acting as. Registrar, Paying Agent and Trustee for the Series 1998 Bonds (the "Trustee"). The Series 1998 Bonds and the interest thereon are payable from and secured solely by a lien on and pledge of the Pledged Funds, which include (i) the Net Trust Fund Revenues, as herein described, received by the Agency from the City Center/Historic Convention Village Redevelopment and Revitalization Area of the City (the "Redevelopment Area"); (ii) until released as provided herein, the portion of the proceeds of the municipal resort tax (the "Resort Tax") levied and collected by the City pursuant to Chapter 67-930, Laws of Florida, Acts of 1967, as amended (the" Resort Tax Act"), Chapter 166, Florida Statutes, as amended, the City Charter. as amended, and Chapter 41, Article V of the City Code, as amended. and available under Section 304(0)(4) of Resolution No. 88-19369 of the City, as supplemented (the "Resort Tax Bond Resolution"), pledged by the City for the benefit of the Holders of the Bonds (hereinafter defined) pursuant to Resolution No. 94-21008, adopted by the City on January 5, 1994, and the City Approving Resolution (collectively, the "Supplemental Revenues Resolution"), and received by the Trustee (such revenues are referred to as the "Supplemental Revenues"), and (iii) all moneys and investments held in the Funds and Accounts (other than the Rebate Fund) created and established by the Resolution. The lien on the Net Trust Fund Revenues is on a parity with the Agency's Tax Increment Revenue Bonds, Series 1993 (City Center/Historic Convention Village) outstanding in the aggregate principal amount of $23,200,000 (the "Series 1993 Bonds"), its Tax Increment Revenue Bonds, Taxable Series 1996A (City Center/Historic Convention Village) outstanding in the aggregate principal amount of $36,680,000 (the "Series 1996A Bonds") and its Tax Increment Revenue Bonds, Series 199613 (City Center/Historic Convention Village) outstanding in the aggregate principal amount of $7,380,000 (the "Series 1996B Bonds" and, together with the Series 1993 Bonds, the Series 1996A Bonds, the Series 1998 Bonds and any additional bonds issued on a parity therewith, thc "Bonds"). The lien on thc Supplemcntal nr =,:..: Revenues is junior and subordinate to the lien on the proceeds of the Resort Tax in favor of the holders of the City's Resort Tax Revenue Refunding Bonds, Series 1996 (the "Resort Tax Bonds") issued under the Resort Tax Bond Resolution, outstanding in the aggregate principal amount of $3,940,000 with a final maturity date of October I, 2022, and is on a parity with the Series 1993 Bonds, the Series 1996A Bonds and the Series 1996B Bonds. Until the pledge of the Supplemental Revenues is released, the City has covenanted in the Supplemental Revenues Resolution not to issue any additional obligations payable from the proceeds of the Resort Tax which are senior with respect to the lien in favor of the Holders of the Bonds, except for refunding bonds provided certain conditions are met. Under certain conditions, described herein, the City may issue additional obligations secured by Supplemental Revenues on a parity with the lien in favor of the Holders of the Bonds. The Series 1l198A Bonds are being issued to (i) pay the costs of the Series 1998A Project, as described herein, which relates to the City Center/Historic Convention Village Redevelopment and Revitalization Area (the "Redevelopment Area") of the City of Miami Beach, Florida (the "City"), including repayment of any portion of the City Loan (herein defined) related 10 the Series 1998A Project; and (ii) pay the costs of issuance of the Series 1998A Bonds. The Series 1998B Bonds are being issued to (i) pay the costs of the Series 1998B Project, as described herein, relating to the Redevelopment Area, including repayment of any portion of the City Loan related to the Series 1998B Project; and (ii) pay the costs of issuance of the Series 1998B Bonds. The Series 1998A Project and the Series 199813 Project are collectively referred to as the" Project. " Capitalized terms used but not defined herein have the same meaning as when used in the Resolution unless the context clearly indicates otherwise. The form of the Resolution is attached to this Official Statemellf as Appendix B. ond the f(mn of City Resolution No. 94-21008 is attached hereto as Appendix C. 171e description of the Series 1998 Bonds, the documents authorizing and securing the some, and the information fi"om various reports and statements collfained herein are not intended to be comprehensive or de.finitive. All references herein to such documems, reports and statemellfs ore qualified by the em ire, actual contellf o{such documents, reports and statements. Copies o{such dOC!lments, reports and statements referred to herein that ore not in eluded in their entirety in this OJ/icial Statement may be obtained fi"om the Agen(~y upon prepaymellf (?l reproduction costs, postage and handling e).penses. The assumptions, estimates, projections and matters of opinion contained in this Official Statement, whether or not so expressly stated, arc set forth as such and not as matters of fact, and no representation is made that any of the assumptions or matters of opinion herein are valid or that any projections or cstimates contained herein will bc realized. Neither this Official Statement nor any other statcment which may have been made verbally or in writing in connection with the Series] 998 Bonds, other than the Resolution, is to be construed as a contract with thc Registered Owners of the Series 1998 Bonds. DESCRIPTION OF THE SERIES 1998 BONDS General Description The Series 1998 Bonds are being issued in fully registered, book-entry-only form, in the denomina1ions of $5,000 each or integral multiples thereof, will be dated July I, 1998 and will bear interest at the rates and mature on the elates and in the amounts shown on the inside cover page of this Official Statemcnt. 2 Principal of and premium, if any, and interest on the Series 1998 Bonds will be payable in the manner described below under "Book-Entry-Only System." The Series 1998 Bonds will be subject to redemption as described below. Book-Entry-Ollly System The Depository Trust Company ("DTC"), New York, New York, will act as securities depository for the Series 1998 Bonds. The Series 1998 Bonds will be issued as fully-registered securities registered in the name of Cede & Co. (DTC's partnership nominee). One fully-registered 1998 Bond certificate will be issued for each maturity of the respective series of the Series 1998 Bonds, each in the aggregate principal amount of such maturity, and will be deposited with DTC. DTC is a limited-purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17 A of the Securities Exchange Act of 1934. DTC holds securities that its participants ("Participants") deposit with DTC. DTC also facilitates the settlement among Participants of securities transactions, such as transfers and pledges, in deposited securities through electronic computerized book-entry changes in Participants' accounts, thereby eliminating the need for physical movement of securities certificates. Direct Participants includes securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is owned by a number of its Direct Participants and by the New York Stock Exchange, Inc., the American Stock Exchange, Inc., and the National Association of Securities Dealers, Inc. Access to the DTC system is also available to others such as securities brokers and dealers, banks and trust companies that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). The rules applicable to DTC and its Participants are on file with the Securities and Exchange Commission. Purchase of the Series 1998 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the Series 1998 Bonds on DTC's records. The owilership interest of each actual purchaser of each 1998 Bond ("Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase, but Beneficial Owners are expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Series 1998 Bonds are to be accomplished by entries made on the books of Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in Series 1998 Bonds, except in the event that use of the book-entry system for the Series 1998 Bonds is discontinued. To facilitate subsequent transfers, all Series 1998 Bonds deposited by Participants with DTC are registered in the name of DTe's partnership nominee, Cede & Co. The deposit of Series 1998 Bonds with DTC and their registration in the name of Cede & Co. effect no change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Series 1998 Bonds. DTC' s records reflect only the identity of the Direct Participants to whose accounts such Series 1998 Bonds are credited, which mayor may not be in the Beneficial Owners. The Participants will remain responsible for keeping account of their holdings on behalf of their customers. 3 Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Redemption notices shall be sent to Cede & Co. If less than all of the Series 1998 Bonds within an issue are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. Neither DTC nor Cede & Co. will consent or vote with respect to Series 1998 Bonds. Under its usual procedures, DTC mails an Omnibus Proxy to the Agency as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co. 's consenting or voting rights to those Direct Participants to whose accounts the Series 1998 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Principal and interest payments on the Series 1998 Bonds will be made to DTC. DTC's practice is to credit Direct Participants' accounts on payable date in accordance with their respective holdings shown on DTC's records unless DTC has reason to believe that it will not receive a payment on the payable date. Payments by Participants to Beneficial Owners wiII be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of the Participant and not of DTC, the Paying Agent, or the Agency, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of principal and interest to DTC is the responsibility of the Agency or the Paying Agent; disbursement of such payments to Direct Participants is the responsibility of DTC; and disbursement of such payments to the Beneficial Owners is the responsibility of Direct and Indirect Participants. DTC may discontinue providing its services as securities depository with respect to the Series 1998 Bonds at any time by giving reasonable notice to the Agency. Under such circumstances, in the event that a successor securities depository is not obtained, 1998 Bond certificates are required to be printed and delivered. The Agency may decide to discontinue use of the system of book-entry transfers through DTC (or a successor securities depository). In that event, 1998 Bond certificates for each series will be printed and delivered. The foregoing information in this section concerning DTC and DTC's book-entry system has been supplied by DTC, and the Agency has relied on DTC as to the accuracy of this information. Additional Provisions Regal'ding Hook-Entry System The Agency and the Trustee, Registrar and Paying Agent will recognize and treat DTC (or any successor securities depository) or its nominee as the holder and owner of the Series 1998 Bonds for all purposes, including payment of debt service, notices, enforcement of remedies and voting. DTC (or any successor securities depository) or its nominee for all purposes under the Resolution will be, and will be considered by the Agency and the Paying Agent to be, the registered owner or registered holder of the Series 1998 Bonds. THE AGENCY AND TIlE PAYING AGENT CANNOT AND DO NOT GIVE ANY ASSURANCES THAT DTC, THE DTC PARTICIPANTS OR THE INDIRECT PARTICIPANTS WILL 4 DISTRIBUTE TO THE BENEFICIAL OWNERS OF THE SERIES 1998 BONDS (i) PAYMENTS OF PRINCIPAL OF OR INTEREST AND PREMIUM, IF ANY, ON THE SERIES 1998 BONDS, (ii) CERTIFICATES REPRESENTING AN OWNERSHIP INTEREST OR OTHER CONFIRMATION OF BENEFICIAL OWNERSHIP INTERESTS IN SERIES 1998 BONDS, OR (iii) REDEMPTION OR OTHER NOTICES SENT TO DTC OR CEDE & CO., ITS NOMINEE, AS THE REGISTERED OWNERS OF THE SERIES 1998 BONDS, OR THAT TIlEY WILL DO SO ON A TIMELY BASIS OR THAT DTC, DTC PARTICIPANTS OR INDIRECT PARTICIPANTS WILL SERVE AND ACT IN TilE MANNER DESCRIBED IN THIS OFFICIAL STATEMENT. TIlE CURRENT "RULES" APPLICABLE TO DTC ARE ON FILE WITH THE SECURITIES AND EXCHANGE COMMISSION AND TilE CURRENT "PROCEDURES" OF DTC TO BE FOLLOWED IN DEALING WITH DTC PARTICIPANTS ARE ON FILE WITH DTC. NEITHER THE AGENCY NOR THE PA YING AGENT WILL HA VE ANY RESPONSIBILITY OR OBLIGATIONS TO SUCH DTC PARTICIPANTS OR THE PERSONS FOR WHOM THEY ACT WITH RESPECT TO THE PAYMENTS TO OR TIlE PROVIDING OF NOTICE FOR THE DTC PARTICIPANTS, THE INDIRECT PARTICIPANTS, OR THE BENEFICIAL OWNERS WITH RESPECT TO: (I) TIlE ACCURACY OF ANY RECORDS MAINTAINED BY DTC OR ANY DTC PARTICIPANT OR INDIRECT PARTICIPANT; (2) THE PAYMENT BY DTC OR ANY DTC PARTICIPANT OR INDIRECT PARTICIPANT OF ANY AMOUNT DUE TO ANY BENEFICIAL OWNER IN RESPECT OF TIlE PRINCIPAL AMOUNT OR REDEMPTION PRICE OF OR INTEREST ON THE SERIES 1998 BONDS; (3) THE DELIVERY BY DTC OR ANY DTC PARTICIPANT OR INDIRECT PARTICIPANT OF ANY NOTICE TO ANY BENEFICIAL OWNER WHICH IS REQUIRED OR PERMITTED UNDER THE TERMS OF TIlE BOND RESOLUTION TO BE GIVEN TO BONDHOLDERS; (4) THE SELECTION OF 'I lIE BENEFICIAL OWNERS TO RECEIVE PAYMENT IN THE EVENT OF ANY PARTIAL REDEMPTION OF THE SERIES 1998 BONDS; OR (5) ANY CONSENT GIVEN OR OTHER ACTION TAKEN BY DTC AS BONDHOLDER. The rights of Beneficial Owners and the manner of transferring or pledging their interests is subject to applicable state law. Beneficial Owners may want to discuss the manner of transferring or pledging their book-entry interest in such Series 1998 Bonds with their legal advisors. In the event that the Book-Entry-Only System is discontinued, principal and premium, if any, will be payable upon surrender of the Series 1998 Bonds at the corporate trust office of First Union Nat ional Bank, Miami, Florida, as Paying Agent and Trustee under the Resolution, or its successor. Interest on the Series 1998 Bonds will be payable semiannually on June I and December] of each year, by check or draft mailed to the person in whose name the Series 1998 Bonds are registercd on the registration books kept by the Registrar ("Holder"), at the close of business on the 15th day (whether ur not a business day) of the calendar month preceding the applicable interest payment date; provided that, for any Holder of $1,000,000 or more in principal amount of Series 1998 Bonds, such paymcnt will, at the written request of such Holder, be made by wire transfer to the bank or bank accounts within the continental United States specified in writing by the Holder, provided that the I-Iokler has advanced to the Paying Agent the amount necessary to pay the cost of such wire transfer or authorized the Paying Agent to deduct the cost of such wire transfer from the payment due to such Holder. Redemption Optional Redemption. The Series I <J98A Bonds maturing on December I, 2020 are not redeemable prior to their stated date or maturity at the option or the Agency. The Series 1 <J<J8A Bonds maturing on December I, 2014 and on December 1,2022 are redeemable prior to their 5 maturity, at the option of the Agency, on or after December 1, 2008, in whole or in part on any date as directed by the Agency, at the redemption price of par and accrued interest to the date of redemption plus the following premiums, expressed as a percentage of the principal amount of the Series 1998A Bonds so redeemed if redeemed during the following redemption periods: Redemption Periods (Dates Inclusive) Redemption Premium December 1, 2008 through November 30, 2009 December 1, 2009 through November 30, 2010 December 1, 2010 and thereafter 1. 00 % 0.50% 0.00% The Series 1998B Bonds maturing on or prior to December 1, 2008 are not redeemable prior to their respective stated dates of maturity at the option of the Agency. The Series 1998B Bonds maturing on Dccember 1, 2009 and thereafter. are redeemable prior to their respective maturities, at the option of the Agency, on or aftcr December 1, 2008, in whole or in part on any date as directed by the Agency, at the redemption price of par and accrued interest to the date of redemption plus the following premiums. expressed as a percentage of the principal amount of the Series 1998B Bonds so redeemed if redeemed during the following redemption periods: Redemption Periods (Dates Inclusive) Redemption Premium December 1, 2008 through November 30, 2009 December 1, 2009 through November 30,2010 December 1, 2010 and thereafter 1.00% 0.50% 0.00% [THIS SPACE INTENTIONALLY LEFT BLANK.] 6 Mandatory Redemption. The Series 1998A Bonds maturing on December 1 in the years 2014, 2020 and 2022 (the" 1998A Term Bonds") are subject to mandatory redemption in part prior to maturity, by lot, at a redemption price equal to 100 % of the principal amount thereof plus accrued interest to the date of redemption, from moneys deposited by the Agency to the credit of the Bond Redemption Account representing the Amortization Requirements for such 1998A Term Bonds, on December 1 .in each of the years as follows: / 2014 Term Bond / / 2020 Term Bond / Amortization Amortization Year Requirement Year Requirement 1999 $ 490,000 2015 $1,480,000 2000 530,000 2016 1,585,000 2001 570,000 2017 1,695,000 2002 610,000 2018 1,820,000 2003 650,000 2019 1,940,000 2004 695,000 2020* 1,480,000 2005 750,000 2006 800,000 2007 855,000 2008 915,000 2009 980,000 2010 1,045,000 2011 1 ,125,000 2012 1,200,000 2013 1,290,000 2014* 1,380,000 / 2022 Term Bond / Year 2020 2021 2022* Amortization Requirement $ 600,000 2,230,000 2,390,000 *Maturity 7 " The Series 1998B Bonds maturing on December 1 in the years 2018 and 2022 (the" 1998B Term Bonds") are subject to mandatory redemption in part prior to maturity, by lot, at a redemption price equal to 100% of the principal amount thereof plus accrued interest to the date of redemption, from moneys deposited by the Agency to the credit of the Bond Redemption Account representing the Amortization Requirements for such 1998B Term Bonds, on December 1 in each of the years as follows: / 2018 Term Bond / / 2022 Term Bond / Amortization Amortization Year Re4uirement Year Requirement 2014 $420,000 2019 $545,000 2015 445,000 2020 575,000 2016 465,000 2021 605,000 2017 490,000 2022* 635,000 2018* 5] 5,000 *Maturity The 1998A Term Bonds and the 1998B Term Bonds subject to mandatory redemption for Amortization Requirements will be selected by lot by the Trustee. The Agency may satisfy all or a portion of the annual mandatory Amortization Requirements by purchasing in the open market such amount of the 1998A Term Bonds and the 1998B Term Bonds as may be purchased for a price not exceeding the redemption price which would otherwise be payable on the next redemption date for such 1998A Term Bonds and 1998B Term Bonds. Notice and Effect of Redemption Not more than 60 days or less than 30 days prior to the redemption date, notice of such redemption will be mailed to all Holders of Series 1998 Bonds to be redeemed at their addresses as they appear on the registration books of the Trustee. Failure to mail any such notice to a Holder of a Series 1998 Bond, or any defect therein, will not affect the validity of the proceedings for redemption of any Series 1998 Bond or portion thereof with respect to which no failure or defect occurred. Such notice will be in the form and contain the information required by the Resolution. Any notice mailed as provided in the Resolution will be conclusively presumed to have been duly given, whether or not the Holder of such Series 1998 Bond receives such notice. While the Series 1998 Bonds are held in book-entry form, such notices of redemption shall be solely mailed to DTC as the registercd owncr of the Scries 1998 Bonds. Notice having bcen given in the manner and under the conditions described above, the Series 1998 Bonds or portions thereof so called for redemption will, on the redemption date designated in such notice, become and be due and payable at the redemption price provided for redemption for such Series 1998 Bonds on such date. On the date so designatcd for redemption, moneys for payment of the redemption price being held in separate accounts by the Paying Agent in trust for the Holders of the Series 1998 Bonds 8 9 or portions thereof to be redeemed, all as provided in the Resolution. interest on the Series 1998 Bonds or portions of Series 1998 Bonds so called for redemption shall cease to accrue, such Series 1998 Bonds and portions of Series 1998 Bonds will cease to be entitled to any lien, benefit or security under the Resolution, will be deemed paid under the Resolution, and the Holders such Series 1998 Bonds or portions thereof will have no right in respect thereof except to receive payment of the redemption price thereof and to receive Series 1998 Bonds for any unredeemed portion. Notwithstanding the foregoing, notice of redemption in connection with an optional redemption of Series 1998 Bonds will not be given by the Agency unless on the date of giving of such notice of redemption the Agency has on deposit with the Paying Agent sufficient moneys to provide for such redemption. [THIS SPACE INTENTIONALLY LEFT BLANK.] ESTll\IATED SOURCES AND USES OF FUNDS The proceeds to be received from the sale of the Series 1998A Bonds, including accrued interest on the Series 1998A Bonds to the date of delivery, are expected to be applied substantially as follows: Sources of Funds Par Amount of Series 1998A Bonds Less: Original Issue Discount Plus: Accrued Interest TOTAL SOURCES $29,105,000.00 (42,856.20) 152.731.83 $29.214.875.63 Uses of Funds Deposit to Acquisition and Constructioll Fund for Cost of Series 1998A Project Deposit to Interest Account!I' Costs of Issuancelil TOTAL USES $28,125,000.00 152,731.83 937.143.80 $29.214.875.63 The proceeds to be received from the sale of the Series 199813 Bonds, including accrucd interest on thc Series 199813 Bonds to the date of delivery, arc expected to be applied substantially as follows: Sources of Funds Par Amount of Series 199813 Bonds Less: Original Issue Discount Plus: Accrued Interest TOTAL SOURCES $9,135,000.00 (3],0]7.85) 34.181.58 $9.138.163.73 Uses of Funds Deposit to Acquisition and Construction Fund for Cost of Series 199813 Project Deposit to Interest Account' Costs of Issuance2 TOTAL USES $8,875,000.00 34,181.58 228.982.15 $9.138.163.73 ] Represents accrued interest received upon sale of the applicable Series, which will be used to pay interest coming due thereon on December I, II)l)R. ~Incllldes premiuIlls for the financial guaranty insurance policies and debt service reserve fund surely bond, underwriters' discount and administrative and other costs associated with the issuance of the applicable Series. ]() ~ s ~ ~ u rJj ~ u ;; ~ ~ rJj E-< =:l ~ ~ " u ","1: '0 " f-o'" .E " Cl '" ])., CQ 'V, 00 " 0'0 ... 0'0 J!J - c ",- -e: " '" '" "'c:l I:: o a:l <1) ...c:: .... 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OI)~ ~ ~tI) ~ '" .~ ] ., .Q '" c:: ~ <U :s '" " " " E <l) ::s '" '" u u u ~ a t: "0 ~ 'E 'E 'E u '" " '" C <l) <U C ;. <U 0 ;::: " " " .5 {:S <l) ;:l .S " ;:l I:!l " fJJ fJJ fJJ " ~ > C ., Q:: c '" 15 15 15 <> <1) " l:l '1::s " 1;1 '" " 't ;> >- Q:: :c <U " " .S ~ " '" t: " f- 11 0 0 0 ~ ., .. .S ~ '" ~ ~ !! ~.c ] 'E t 'OJ ,.., \0 00 ~ "0 - ~ 5l t: a- '" '" .<5 o - C "0 '" f- " " ;> '" ::; ::; ~ " .~ ~ ~ ;:l ::s l:; ~ 00 fJ.< u.. <r: ~ t:: 0::: ~ '" EO - OJ '" '" .~ 1i Qj '" 0 ~ .~ .~ 5l 2 '" ~ '" ~ 15 >- <U <U " r3l <U <U " ~ 0 "'~ f- ....J ~ ....J f- fJJ fJJ fJJ U <r:::::- 13 SECURITY FOR THE SERIES 1998 BONDS Generally The Series 1998 Bonds are secured by a lien upon and pledge of the Pledged Funds which include (i) the Net Trust Fund Revenues. as hereinafter described, received by the Agency from the Redevelopment Area (ii) until released as described herein, the Supplemental Revenues, as hereinafter described and (iii) moneys and investments in the funds and accounts (other than the Rebate Fund) created under the Resolution. The lien on the Net Trust Fund Revenues is on a parity with the Series 1993 Bonds, the Series 1996A Bonds and the Series 1996B Bonds. The lien on the Supplemental Revenues is junior and subordinate to the lien on such proceeds of the Resort Tax in favor of the holders of the Resort Tax Bonds and is on a parity with the Series 1993 Bonds, the Series 1996A Bonds and the Series 1996B Bonds. Until the lien of the Supplemental Revenues is released, the City has covenanted in the Supplemental Revenues Resolution, described herein, not to issue any additional obligations payable from the proceeds of the City's Resort Tax which are senior with respect to the lien in favor of the Holders of the Bonds, except for refunding bonds provided certain conditions are met. Under certain conditions, the City may issue additional obligations secured by Supplemental Revenues on a parity with the lien in favor of the Holders of the Bonds, as further described herein. NEITHER THE PROJECT, NOR ANY ELEMENTS THEREOF, CONSTITUTE SECURITY FOR THE BONDS, AND THE BONDHOLDERS HAVE NO LIEN THEREON. THE BONDS ARE SECURED SOLELY BY A LIEN UPON AND PLEDGE OF THE PLEDGED FUNDS. The Series 1998 Bonds do not constitute an indebtedness of the Agency, the City. the County, the State or any political subdivision thereof, within the meaning of any constitutional, statutory, charter or code provisions or limitations, or a pledge of the faith and credit of the Agency, the City, the County, th.e State or any political subdivision thereof, but shall be payable solely as provided in the Resolution from the Pledged Funds. No Holder or Holders of any Series 1998 Bonds shall ever have the right to compel the exercise of the ad valorem taxing power of the City, the County, the State or any political subdivision thereof or taxation in any form of any real or personal property therein, or the application of any funds of the Agency or the City, the County, the State or any political subdivision thereof to pay the Series 1998 Bonds or the interest thereon or the making of any sinking fund or reserve payments provided for in the Resolution other than the Pledged Funds provided in the Resolution. The Agency has no power to levy ad valorem taxes for any purpose. Net Trust Fund Revenues Generally. As described herein under the heading "THE AGENCy:h the Act permits the establishment of a redevelopment trust fund into which is deposited tax increment funds to be used to finance redevelopment in a designated area. As described under the heading "THE AGENCY," the Agency and the City have adopted a redevelopment plan (the "Redevelopment Plan") and designated the Redevelopment Area. The Redevelopment Plan provides for a Redevelopment Trust Fund (the "Trust Fund") and, as approved by the City and the County, the tax increment revenues generated in the Redevelopment Area are required to be deposited into the Redevelopment Trust Fund on an annual basis in accordance with the Act. T11lst Fund Rel'ellues. Pursuant to the Act, the annual funding of a redevelopment trust fund is made on each January I and is based upon the assessed valuation of taxable real property as of January I of the previous year. Each taxing authority within the designated redevelopment area, with certain exceptions, must appropriate and pay into the redevelopment trust fund an amount not less than the increment in the income, proceeds, revenues, and funds of such taxing authority derived from or held in connection with the undertaking or carrying out of the redevelopment plan. With respect to the Redevelopment Area, the only taxing authorities required to make such payments arc the City and the County and the "increment" is that amount equal to 95 % of the difference between: (I) The amount of ad valorem taxes levied each year by each taxing authority, exclusive of any amount from any debt service millage, on taxable real property contained within the geographic boundaries of the Redevelopment Area; and (2) The amount of ad valorem taxes which would have been produced by the rate upon \vhich the tax is levied each year by or for that taxing authority, exclusive of any debt service millage, upon the assessed valuation of the taxable real property in the Redevelopment Area as shown on the most recent assessment roll used in connection with the taxation of such property by each taxing district prior to the effective date of the ordinance establishing the Trust Fund (the "Base Year"). The resulting incremental increase in ad valorem taxes is used to measure the amount of the contribution which must be appropriated and contributed by each taxing authority which is required to make payments. The taxing authorities are not required and cannot be compelled to levy ad valorem taxes to generate any such increment to make such payments. Under the Act, the statutory obligation of the taxing authorities to make the required payments to a duly established redevelopment trust fund continues for so long as a redevelopment agency has outstanding indebtedness secured by tax increment revenues, but not longer than 30 years after tax increment revenues are first deposited in the redevelopment trust fUllc! or the redevelopment plan is subsequently amended. Additionally, the obligation of the governing body which established the redevelopment agency to fund the redevelopment trust fund annually continues until all loans, advances and indebtedness, if any, and interest thereon, of a redevelopment agency incurred as a result of redevelopment in a redevelopment area have been paid. The payments required to be made by the City and the County are herein called the "Tax Increment Revenues" and upon receipt for deposit to the Trust Fund constitute the "Trust Fund Revenues." "Net Trust Fund Revenues" are the Trust Fund Revenues after the deduction of $500,000 per Fiscal Year for the cost of operation and administration of the Agency relating to the Redevelopment Plan. Ad Valorem Tax Matters. With respect to the payment of the Series 1998 Bonds, the general method of fixing millage provides pertinent background for understanding the method of measuring and calculating the contribution of Tax Increment Revenues required to be made by the City and the County. Generally, Florida law currently mandates the following procedures in fixing millage rates: (a) January I of each year is the statutory measurement date used by each county property appraiser for establishing just value of real property within the county. Real property improvements or portions thereof not substantially completed on January I arc deemed to have no 14 value placed thereon, and substantially completed property as of January 1 is assessed by the county property appraiser based on its just value. (b) On or before July 1 of each year, each county property appraiser is required to complete an assessment of the value of all property located within the county (unless extended for good cause by the State Department of Revenue). Upon completion of this assessment, the county property appraiser is required to certify to each taxing authority the taxable value within the jurisdiction of the taxing authority. This certification includes the just value of new construction, additions to structures, deletions and property added due to geographic boundary changes substantially complete as of January I of each year. @ Each taxing authority is required to compute the millage known as the "rolled back rate." That rate is the rate which, exclusive of (i) new construction, (ii) additions to structures. (iii) deletions, and (iv) property added due to geographic boundary changes, will provide the same ad valorem tax revenue for each taxing authority as was levied during the prior year. (d) Upon preparation of a tentative budget, but prior to adoption thereof, each taxing authority in addition to computing the "rolled back rate" is required to compute the proposed millage rate which would be necessary to fund the tentative budget, other than the portion of the budget to be funded from other than ad valorem taxes. In computing proposed or final millage rates, each taxing authority utilizes not less than 95 % of the taxable value certified by the county property appraiser. In establishing the tentative budget and the proposed millage rate the taxing authority is not bound by the" rolled back rate" and, in accordance with Florida law, may exceed the "rolled back rate" or may even adopt a tentative budget and proposed millage rate which would be less than the "rolled back rate." (e) Within 35 days of the county property appraiser's certification, each'taxing authority is required to advise the county property appraiser of its proposed millage rate and the "rolled back rate" and the date and time at which a public hearing will be held to consider the proposed millage rate and the tentative budget. The county property appraiser utilizes this information in preparing the notice of proposed property taxes required to be mailed to property owners. Additionally, if this information is not provided in a timely fashion as required by the statute, the taxing authority is prohibited from levying a millage rate greater than the "rolled back rate" for the upcoming fiscal year. (f) Each taxing authority is statutorily required to hold a minimum of two public hearings on the proposed millage rate and tentative budget prior to adopting a final millage rate and a final budget. At the first public hearing, the taxing authority may amend the tentative budget and proposed millage rate as it sees fit and adopt a tentative budget and proposed millage rate. At the second public hearing, the taxing authority may adopt the final budget and final millage rate. The final budget and final millage rate adopted at the second hearing cannot exceed the tentative budget and tentative millage rate adopted at the first public hearing. Except as otherwise provided by statute, no millage rate (exclusive of ad valorem debt service millage) for the county and the city may annually exceed 10 mills each without voter approval. It is the final millage rate that is used to calculate the tax increment revenue payments required to be made to a redevelopment trust fund on or before January 1 of the next year. Final millage rates generally should have been adopted by October 1 of each year, to allow sufficient time for taxing authorities to calculate the required payment to the redevelopment trust fund and 15 to submit the same on or before January 1. Pursuan1 to statute, unless otherwise permitted by law, final budgets must be adopted by taxing authorities prior to the beginning of a taxing authority's fiscal year. State Constitutional Limitation on Increases in Assessed Valuation. On November 3, 1992. the voters of the State of Florida passed an amendment to Article VII, Section 4 of the Florida Constitution establishing a limitation of the lesser of 3 % or the increase in the Consumer Price Index during the relevant year, on the annual increase in assessed valuation of homestead (primary residence) property, except in the event of a sale thereof during such year, and except as to improvements thereto during such year. Thc amcndmcnt became cffcctivc January I, 1995. The amcndment did not altcr any caps on millage ratcs otherwise set forth in the Florida Constitution. Thc Agcncy estimates that approximately 9 % of the real property in the Redevelopment Area is currently homestead property. The rest of the real property in the Redevelopment Area is currently commercial in nature and is not subject to the foregoing limitation on assessed valuation. Ad Valorem Tax Abatement. Pursuant to a referendum held on November 4, 1986, the County's Board of County Commissioners has by ordinance authorized the granting, at the discretion of such Board, of economic development ad valorem tax exemptions to new and expanding businesses located in areas designated as enterprise zones under Florida law, including an enterprise zone established in the South Miami Beach area of the County known as the "South Miami Beach Enterprise Zone." Although no such tax exemption has been granted with respect to the South Miami Beach Enterprise Zone, a portion of this enterprise zone overlaps the Redevelopment Area. The City requested the County to exclude the entire Redevelopment Area from the granting of ad valorem tax exemptions which otherwise may be granted by the Board of County Commissioners in the South Miami Beach Enterprise Zone. The Board of County Commissioners enacted an ordinance on December 14, 1993 which ordinance excludes the Redevelopment Area from the South Miami Beach Enterprise Zone for ad valorem tax exemption purposes. Tax Increment Revenues for the Redel'elopment Area. The Tax Increment Revenues will be collected by the Agency pursuant to the Redevelopment Plan, originally adopted in 1993, as further described herein under the heading "THE AGENCY." The aggregate assessed value of taxable real property in the Redevelopment Area as of January 1, 1992 (the Base Year). used for determining the incremental assessed valuation in future years, was $292,572,271. Thc amount of Tax Increment Revenues required to be paid into the Redevelopment Trust Fund depends upon (i) the assessed valuation of taxable real property in the Redevelopment Area as of each January 1, (ii) the incremental increase in such valuation above the valuation for the Base Year and (iii) the total millage rate levied by the relevant taxing authorities (the City and the County). All of these factors arc beyond the control or prediction of the Agency. See "RISK FACTORS" herein. The following table sets forth historical collections of Tax Increment Revenues in the Redevelopment Area for fiscal years 1993 through 1997. There arc certain circumstances that could adversely affect the realization of the Tax Increment Revenues. See the information under the captions "RISK FACTORS" herein. 16 Tax Year/ (F Y. Ended Seot. 30) Total Ta xable Real Prooertv Increment of Taxable Real Pnmertv Annual Change in Taxable Values County Milla~e City Milla~e County Payments @95% City Payments @95% Tutal Tax Increment Miami Beach Redevelopment Agency Historical Taxable Real Property and Tax Increment Revenues City Center Historic Convention Village Hase/J 992 $292,572,271 (rY 93) I 993(FY94) 373,316,447 $ 80,744,176 27.6% 7.305 8.238 $ 560,344 $ 631,912 $1.192,256 I 994(FY95) 470,779.626 178.207,729 26.1 7.253 7.143 1,227,917 1.209,294 2.437.211 1 995(FY96) 491,677,581 199,105,729 4.4 6.828 7.499 1,291,519 1,418,439 2,709,958 J 996(FY97) 497,342,509 204,771.000 1.2 6.469 7,499 1,258,430 1,458,799 2.717,229 J 997(FY98) 531.364,583 238.793,000 6.8 6.023 7.499 1,366,338 1,701,173 3,067.511 Source: City of Miami Beach Finance Department Application of Trust Fund Revenues Under the Resolution, the Agency has covenanted to maintain the Trust Fund, which will be held by the Agency and maintained separately and distinct from all other Agency funds and will be used only for the purposes and in the manner set forth in the Resolution and in the Act. In each Fiscal Year, the first $500,000 in Tax Increment Revenues deposited in the Trust Fund during such Fiscal Year shall be set aside and retained by the Agency for the payment of the Agency's current operating expenses relating to the Redevelopment Plan (not including Debt Service Requirements on the Bonds). Under the Resolution, the Agency's anticipated annual collections of Net Trust Fund Revenues must be used in the following order of priority: (1) Net Trust Fund Revenues will first be used, immediately upon receipt and to the full extent required, for deposit into an "Interest Account" established under the Resolution with the Trustee in such amounts as will be sufficient to pay all interest coming due on the Bonds during the calendar year of such deposit. However, such deposits for interest will not be required to be made into the Interest Account to the extent that sufficient amounts are already on deposit therein. (2) (a) Net Trust Fund Revenues will next be used, immediately upon receipt and to the full extent required, for deposit into a "Principal Account" established under the Resolution with the Trustee, in such amounts as will be sufficient to pay the principal amount of all Serial Bonds, if any. that will mature during the calendar year of such deposit. However,. such deposits for principal will not be required to be made into the Principal Account to the extent that sufficient amounts are already on deposit therein. (b) Net Trust Fund Revenues will next be used, to the full extent required, for deposit into a "Bond Redemption Account" established under the Resolution with the Trustee. in such amounts as may be necessary to make the mandatory sinking fund redemption payments or payments at maturity, if any, of any Term Bonds required to be paid during such calendar year. Amounts in the Bond Redemption Account will be used solely for the purchase: or redemption of the Term Bonds payable therefrom. The Agency may at any time purchase any of such Term Bonds at prices not greater than the then redemption price of such Term Bonds, If the Term Bonds are not then redeemable, the Agency may purchase such Term Bonds at prices not 17 , I l greater than the redemption price of such Term Bonds on the next ensuing redemption date. The Agency will be obligated to use any moneys in the Bond Redemption Account for the redemption prior to maturity of such Term Bonds in such manner and at such times as the Term Bonds may be subject to mandatory redemption. If, by the application of moneys in the Bond Redemption Account, the Agency will purchase or call for redemption in any year Term Bonds in excess of the applicable payment or redemption requirements for such year. such excess of Term Bonds so purchased or redeemed will be credited in such manner and at such times as the Executive Director of the Agency may determine over the remaining payment dates. (3) Net Trust Fund Revenues will next be used, to the full extent required, and immediately upon receipt, for deposit into the "Debt Service Reserve Account" established under the Resolution with the Trustee to make up the difference, if any, between the amount on deposit in the Debt Service Reserve Account (including any Reserve Account Insurance Policy or Reserve Account Letter of Credit, as described below) and the aggregate Debt Service Reserve Requirements (as hereinafter defined) for all outstanding Bonds. However, no payments will be required to be made into the Debt Service Reserve Account whenever and as long as the amount deposited therein (including any Reserve Account Insurance Policy or Reserve Account Letter of Credit in accordance with the Resolution) is equal to the aggregate Debt Service Reserve Requirement for all outstanding Bonds. In the event that any amounts are withdrawn from the Debt Service Reserve Account for payments into the Interest Account, Principal Account or Bond Redemption Account, such withdrawals will be subsequently restored in the manner described in the previous paragraph from the first Net Trust Fund Revenues or other available funds after all required payments have been made into the Interest Account, Principal Account and Bond Redemption Account, including any deficiencies for prior payments, unless and to the extent the aggregate Debt Service Reserve Requirement is otherwise restored by available Supplemental Revenues, as further described herein under the subheading" Supplemental Revenues," or by the reinstatement of the maximum limits of a Reserve Account Insurance Policy or Reserve Account Letter of Credit. (4) Net Trust Fund Revenues will next be used for the payment of any obligations issued by the Agency pursuant to the Resolution which obligations are payable from Net Trust Fund Revenues on a subordinated basis to the Bonds. (5) After making all required deposits and satisfactions of any and all deficiencies or other obligations owed under the preceding paragraphs (I) through (4), the balance of any Net Trust Fund Revenues may then be used by the Agency for any other lawful purpose, including payment of any fees and expenses of the Fiduciaries. For further information regarding the application of Tax Increment,Revenues and Net Trust Fund Revenues, see "Appendix B, "THE RESOLUTION NO." , Supplemental Revenues Generally. Because the Net Trust Fund Revenues initially will not be sufficient to pay the principal of and interest on the Bonds, the City has, under the provisions of the Supplemental Revenues Resolution, pledged the Supplemental Revenues. The pledge of and lien on the Supplemental Revenues is subordinate to the lien on the proceeds of the Resort Tax in favor of the holders of the Resort Tax Bonds, and is on a parity with the Series 1993 Bonds, the Series 1996A Bonds and the Series 1996B Bonds. Until the pledge 18 of the Supplemental Revenues is released, the City has covenanted in the Supplemental Revenues Resolution not to issue any additional obligations payable from the proceeds of the Resort Tax which would be senior in right to the lien in favor of the Holders of the Bonds, except for refunding bonds provided certain conditions are met. Under certain conditions the City may issue additional obligations secured by the Supplemental Revenues on a parity with the lien thereon in favor of the Holders of the Bonds. The form of the City Resolution No. 94-21008 pledging the Supplemental Revenues is included herein as Appendix C. The Resort Tax Gellerally. Pursuant to the Resort Tax Act, the City Charter and City Ordinance 1727, as amended, codified as Chapter 41, Article V of the City Code, the City imposes, levies and collects a resort tax of two percent (2 %) upon rentals of rooms in any hotel, motel, apartment house or rooming house within the City (subject to the exceptions described below) and upon the sale price of all items of food or beverages sold at retail or alcoholic beverages for consumption on the premises of any place of business within the City required by law to be licensed by the state Division of Hotels and Restaurants (the "Resort Tax"). The City Code and the Resort Tax Act provide the following exemptions from imposition of the Resort Tax: (a) federal, state and city governments, or any agency thereof; (b) any non-profit religious. educational or charitable institution when engaged in carrying on customary non-profit activities; @ rents paid by a lessee with a written lease for a term longer than six months; (d) school lunches and hospital meals and rooms; (e) all premises and transactions exempted under state law from the imposition of the state sales tax on transient rentals; (t) transactions of less than fifty cents; and (g) sales of food or beverages delivered to a person's home under a contract providing for deliveries on a regular schedule when the price of each meal is less than ten dollars. The City estimates that the exempted transactions aggregate approximately eight percent (8 %) of all transactions that would otherwise be subject to the Resort Tax. Under the Resort Tax Act, the funds from the collection of the Resort Tax may be used for the following purposes only: creation and maintenance of convention and publicity bureaus, cultural and art centers, enhancement of tourism, publicity and adver1ising purposes. and for future costs, purchase, building, designing, engineering, planning, repairing, reconditioning, altering, expanding, maintaining, servicing and otherwise operating auditoriums, community houses, convention halls, convention buildings or structures, and other related purposes, including relief from ad valorem taxes theretoforc Ic'vied for such purposes. ]n November 1992, an increase of one percent (l %) in the Resort Tax levied upon room rents passed upon affirmative vote of the electorate, which increase became effective on October I, 1996. Subject to the rights of the holders of the Resort Tax Bonds and the Bondholders (which includes the Series 1998 Bonds) whose lien on the Resort Tax revenues is subordinate to the lien of the holders of the Resort Tax Bonds, such increase is to be used (A) 50% for public incentives for a convention center hotel development, and upon retirement of all debt related thereto, as in (B) below, and (8) 50 % for promotion of tourism related activities and facilities. The City has agreed in the Resort Tax Bond Resolution that so long as any of the principal of or interest on the bonds issued thereunder remains unpaid, it will not repeal Ordillance 1727, reduce the rate of the Resort Tax, or amend or modify Ordinance 1727 so as to impair or adversely affect the powers and obligation of the City to levy and collect the Resort Tax or adversely affect the pledge of the Resort Tax revenues and other funds pledged to pay the principal of and interest on the bonds issued under the Resort Tax Bond Resolution. The Resort Tax Bond Resolution provides for the application of the Resort Tax to the payment of the outs1anding bonds issued under the Resort Tax Bond Resolution, as well as the payment of subordinated indebtedness (including the Bonds). 19 Pursuant to ordinances of the City which are codified as Chapter 41, Article VI of the City Code, but subject to the prior rights of holders of bonds secured by the Resort Tax revenues, including the Series 1998 Bonds, the City is required to allocate and appropriate to the Miami Beach Visitor and Convention Authority (the "Authority") fifty percent (50%) of the Resort Tax revenues (but not including any Resort Tax revenues attributable to the one percent (I %) increase described above), net of a collection fee to the City of 4% of all Resort Tax revenues; provided, however, that the City's obligations to the Authority are deemed satisfied to the extent of payments made by the City to the Greater Miami Convention and Visitors Bureau (the "Bureau") under the Interlocal Agreement described below. Pursuant to an Interlocal Agreement among the City, the County, the City of Miami, Florida, the Village of Bal Harbour, Florida, and the Bureau, the City is required to annually contribute to the Bureau the lesser of (1) 50% of the net revenues collected from the City's Resort Tax, less $250,000 annually for special events and net of a collection fee to the City of 4 % of all Resort Tax revenues, or (2) the net revenues collected from the Resort Tax, less any and all payments required under any resolutions or ordinances pursuant to which bonds or other indebtedness of the City are issued which are secured by the Resort Tax, and less $250,000 annually for special events, and net of a collection fee to the City of 4 % of all Resort Tax revenues, In the event the City determines that the allocation of Resort Tax revenues to the Bureau would impair the City's obligations with respect to any bonds, the City is required to appropriate to the Bureau an alternative revenue source equal to the Resort Tax rcvenues that would otherwise have been required to be paid to the Bureau. The Supplemental Revenues Resolution determines that the obligations of the City under the Supplemental Revenues Resolution constitute other indebtedness of the City which is secured by the Resort Tax and therefore entitled to priority in payment to the amounts required to be contributed to the Bureau. Additionally, until the pledge of the Supplemental Revenues is released, the City has covenanted in the Supplemental Revenues Resolution not to issue any additional obligations secured by a lien on and pledge of the Resort Tax revenues, which pledge and lien would be senior in right to the Holders of the Bonds, except for refunding bonds, provided certain conditions are met. Pledge of Supplemental Revenues. If, on the first day of February in each Fiscal Year the amounts on deposit in any of the accounts in the Sinking Fund are less than the amounts required to be deposited therein during thc currcnt calendar year, thc Trustce shall immediatcly notify the City of thc deficiency and the City shall be obligated to 1ransfcr to the Trustee, in accordance with the timing requirements of the Supplemcntal Revenues Rcsolution, for deposit in the appl icable accounts in thc Sinking Fund. Supplemental Rcvcnues in an amount which shall be sufficient, together with the amollllts then on deposit therein, to pay all intercst and principal (including Amortization Requircmcnts) payable on the Bonds during the then currcnt calendar year, as the same is due and payablc, and to fund such deficiency in the Debt Service Rcserve Account by the last day of such calendar year. See "Appendix C - CITY RESOLUTION NO. 94-21008." The City has covenanted and agreed in the Supplemental Revenues Resolution that it will not repeal any ordinance by which the Resort Tax is levied allll will not reduce thc rate of the Resort Tax, or amend, modify or substitute, in any manner any ordinance so as to impair or adverscly affcct thc power and obligation of the City to levy and collect the Rcsort Tax or the application of the Supplcmental Rcvcnues, and the City is unconditionally and irrevocably obligated, as long as the pledge allll lien OIl thc Supplcmcntal Revenucs created by the Supplemental Revcnues Rcsolution is in efTect, to levy allll collect the Resort Tax at not less than the rate now being levied by the City. 20 21 Nothing in the Supplemental Revenues Resolution constitutes or shall be construed as a pledge of the City's ad valorem taxing power or of its full faith and credit, and the Supplemental Revenues Resolution represents a limited obligation of the City payable solely from the Supplemental Revenues pledged thereunder. Additionally, the City covenants in the Supplemental Revenues Resolution not to issue any additional revenue bonds under the Resort Tax Bond Resolution which revenue bonds would be secured by a lien on the Resort Tax revenues which is senior to the lien thereon created under the Supplemental Revenues Resolution, except for refunding bonds provided that the Finance Director of the City certifies that the maximum amlUal debt service of all senior lien bonds outstanding under the Resort Tax Resolution after the refunding will not be increased. Release of Suppleme1ltal Reve1lues. Notwithstanding anything to the contrary contained in the Resolution, the City's obligation to transfer Supplemental Revenues to the Trustee shall terminate and the pledge of and lien on the Supplemental Revenues under the Supplemental Revenues Resolution and the Resolution shall be released and extinguished upon the happening of the following conditions: (1) the Net Trust Fund Revenues (not including any portion thereof which may be attributable to investment earnings) for each of the immediately preceding two Fiscal Years. as certified by a certified public accountant in a certificate delivered to the Trustee, shall have been at least equal to one hundred seventy-five percent (175 %) of the Maximum Annual Debt Service on all Bonds then outstanding. (2) The Agency shall cause notice that the lien upon and pledge of the Supplemental Revenues has been released and extinguished to be mailed to the Registered Owners of the Bonds, to each rating agency maintaining a rating on the Bonds and the issuer of any Credit Facility or Liquidity Facility. See "RISK FACTORS" herein. Additio1lal Obligations Payable From Supplemental Revenues. The City further covenants in the Supplemental Revenues Resolution that so long as the pledge of and lien on the Supplemental Revenues is in effect it will not issue bonds or incur obligations (other than payment obligations undcr the Supplemental Revenues Rcsolution) payable on a parity with the Bonds from the Supplemental Revenues (the "Supplemental Revcnues Bonds") unless: (I) The Supplemental Revcnues reccived by the City during the immediately preceding Fiscal Year, as certified by an independent certified public accountant, were at least equal to 175 % of (A) the Maximum Annual Debt Service on (i) all Bonds issued and then Outstanding under the Resolution, (ii) in accordance with the next succeeding paragraph, any Supplemental Revenues Bonds issued and then Outstanding and (iii) in accordance with the next succeeding paragraph, the additional Supplemental Revenues Bonds then proposed to be issued, less (B) the Net Trust Revenues applied in such preceding Fiscal Year to the payment of principal of and interest on the Bonds. (2) The City need not comply with subparagraph (1) above in the issuance of Supplemcntal Revenues Bonds if and to the extent that the Supplemental Revenues Bonds to be issued are refunding Supplemental Revenues Bonds, that is, delivered in lieu of or in substitution for Supplcmental Revenues Bonds previously issued, if the City causes to be delivercd to the Trustee a certificate of the Finance Director of the City setting forth (i) the Maximum Annual Debt Service (A) with respect to the Bonds and, in accordance with Ihe next slIcceeding paragraph. the Supplemental Revenues Bonds, in each case OUlslanding immediately pri\Jr t\Jthe date of delivery of such refunding bonds and (B) with respect to the 13onds. ami in accordance with the next succeeding paragraph, the Supplemental Revenues Bonds, in each case to be Outstanding immediately thereafter, and (ii) that thc Maximum Annual Debt Service set forth pursuant to (B) above is no grcatcr than that set forth pursuant to (A) above. For purposes of subparagraphs (1) and (2) above, Supplemental Revenues Bonds are dcemed "Outstanding" and are included in "Debt Service Requirement" and "Maximum Annual Dcbt Service" therein based upon the same rules applicable to Bonds undcr the Rcsolution. Nothing contained in the Supplemental Revenue Resolution will restrict, prohibit or limit the ability or right of the City to issue bonds or incur other obligations payable from the Supplemental Revcnues, or create or cause to be created debts, lien, pledges, assignments, encumbrances and other charges upon the Supplemental Revenues, which is each case are junior, inferior and subordinate in all respects to the Bonds and any Supplemcntal Revenues Bonds as to lien on and source and security for payment from the Supplemcntal Revenues and in all other respects. Historical Resort Tax Collections. The table on the following page sets forth the City's Resort Tax collections from October, 1992 through September 30, 1997 and for the eight months ending May 31, 1998. [TIllS SPACE INTENTIONALLY LEFT BLANK]. 22 .... ,., ... " :; "" " "" " " ~ .c c; '" e .l: Oll 'il " .:; "" " " &; ~ '5~~ ~~~ .~ ~ B ::i1 ~ Ie' c.:~~ '" 1:: Oll .~. ~ 6 ug:.s N '" ~ <:> ,., ... " .c e " a Ji II "" " ~ ~ " .... << i;:i io: " .:; ... .E ~ t" Ii' Ii' 00 V) r---: ~ ~j s t;~~~~t-~ '"'! -0 0.. c: t--: ~ ."f. ...t V) M 00 ~I ; 'D ~ ~ ~ ~ o r- N N f"') '<:t 0'1 "1' r- Nr;.\Olrlo; ",i r--: ~ 00 :8. 8. ~ ;:6.' ~ ~ ~ ~ ~ ~ ~ g ~ oo~IV)r:!ri~~i~~ 0- f':. 0- 0- 00 f"')tr) 0 0"1 f"') InN ~oo If'") 000 V)tr) ~I tr) ~ ~ ~ ~ i ~ ~ '" ~ ~ ~ ~ 8 ~. ~ ~ V> .., '" '" .... Ii' t~ Ii' o 0'- l""! ~ ~ ~ tl:': ~ ~ ". 0 r...: 00 II") ("~ ...,. ("'i Ii' ~ Ii' ",,::c.'1 r-: ~ ~ ,., ,., In N r.l ~ ~ ~ \0 ~ ~I :! ~i ~I ~ ~ ~ ~ ~ i i ~ ~ ~ ~ ~ "" ~ ~I ::0 g: ~ ~ ~ ~ ~ ~ ~ ~ ~ i ~ ~I ~ ~ ; ~ ~ ; ~ ~ ~ ~ i ~ V> ~ ~ ~ ~ ~ ~ 5 ~ ~ ~ ~ ~ ~ ~I ~ @ ~ ~ i ~ i ~ ~ ; ~ ~ V> ~ ~ Ii' ~ ~ ~ ~ t" Ii' ~ ~ ~ ~.I ~I ~ ~ ~ ~ ~ ; ~ ~ ~ r-: ~ ~; ~I ~ ~ ~ : ~ ~ ~ ~ ~ ~ : ~ "" ;; ~I ~I ~ ~ i ~ ~ ; ~ ~ i ~ ~ ~ "" ~~tfi'~~~~fft~ ~ f"') ~ r- 00 ~ 0 0"1 tr) ~ ~ N ~ ~ ~ ~ M t" If' N t- S 0 ~ ~ ~ ~ ~ ~ : ~ ~ ~ ~ ~ ~ ~I ~ ~ ; ~ ~ i ~ ~ ~ ~ ~ ~ Vl ... ... ~t~~cC.c ~~ ~ J j ~ j I ~ ~ i J i J ! I I I ~I 1 I ~II ~II I ~jl ! ;11 ~ '" ~ o Vl ~II 91 ~II ~ ;11 ~ ;;; '0 I- 'li 1:: o 0. ~ -5 = o E ;: t 8 ~ o E " -5 .c "" :J o .s r<I M ;: ~ '" 0. " Cl ... " .0 o V a "'" o ~.s 0.= .~ E ... " .~ -5 ~.8 ~ ~ :J " ~ ~l ~-5 . " VI OIl " '" '5 5 o.U K& ~~~ s ~ ~ ]~~ .s ""' .:a -5:l-5 c: ~.s E-5il .s5~ ~>-- .5 ~]g = u. ~ 0_" ] ~ ~ "8 8.5 c;j.s~ 2 ... " ~tE] 'c " g '" = u:: '5 " " III .~ ;E "'" o c. U Vi UJ I- a z u ~ :J o '" Debt Service Reserve Account General The Resolution establishes a Debt Service Reserve Account into which there is required to be deposited or transferred: (1) All proceeds of the Bonds required to be deposited into the Debt Service Reserve Account by the terms of the Resolution or any supplemental resolution; (2) All amounts required to be transferred to the Debt Service Reserve Account under the Resolution; and (3) Any other available money or security which the Agency may determine to deposit into the Debt Service Reserve Account. The Resolution provides that the Agency will maintain in the Debt Service Reserve Account at all times from available revenues an amount (the "Reserve Account Requirement") equal to the least of (i) maximum annual debt service due on all Bonds outstanding in any Fiscal Year of the Agency, (ii) 125 % of the Average Annual Debt Service due on all Bonds outstanding, or (iii) 10% of the proceeds of the Bonds, as defined in the Internal Revenue Code of 1986, as amended (the "Code"). In lieu of or in substitution for all or a portion of any required cash amounts in or deposits into the Debt Service Reserve Account, the Resolution permits the Agency to cause to be deposited into the Debt Service Reserve Account a Reserve Account Insurance Policy or Reserve Account Letter of Credit. See" Appendix B -- THE RESOLUTION." On the date of issuance of the Series 1998 Bonds, the Reserve Account Requirement will equal $9,079,234.50. In order to meet the Reserve Account Requirement, on such date there will be on deposit in the Debt Service Reserve Account cash in the amount of $1,766,996.25 and a Reserve Account Insurance Policy (the "Series 1998 Reserve Account Insurance Policy") in the amount of $7,312,238.25, as described below under" Series 1998 Reserve Account Insurance Policy. " Except as otherwise provided in the Resolution, amounts in the Debt Service Reserve Account will be used only for the purpose of making payments of principal and interest on Bonds when amounts in the Trust Fund or other available funds or accounts under the Resolution are insufficient for such purpose. The Resolution further provides that, for purposes of computing amounts in the Debt Service Reserve Account, the Debt Service Reserve Account will be valued on the first day of each Fiscal Year and the investments in such Account will be valued at the lower of par or, if purchased at other than par, amortized value. The Debt Service Reserve Account will secure the Series 1998 Bonds, the Series 1996A Bonds. the Series 1996B Bonds and the Series 1993 Bonds, as well as any additional parity Bonds issued after the issuance of the Series 1998 Bonds. ~ Series 1998 Reserve Account Insurance Policy The following describes the Series 1998 Reserve Account Insurance Policy, which is being issued by MBIA Insurance Corporation ("MBlA" or the "Insurer"). Application has been made to MBlA for a commitment to issue the Series 1998 Reserve Account Insurance Policy. The Series 1998 Reserve Account Insurance Policy will provide that upon notice from 24 the Paying Agent to MBIA to the effect that insufficient amounts are on deposit in the Sinking Fund to pay the principal of (at maturity or pursuant to mandatory redemption requirements) and interest on the Bonds, MBIA will promptly deposit with the Paying Agent an amount sufficient to pay the principal of and interest on the Bonds or the available amount of the Series 1998 Reserve Account Insurance Policy, whichever is less. Upon the later of: (i) three (3) days after receipt by MBIA of a Demand for Payment in the form attached to the Series 1998 Reserve Account Insurance Policy, duly executed by the Paying Agent; or (ii) the payment date of the Bonds as specified in the Demand for Payment presented by the Paying Agent to MBIA, MBIA will make a deposit of funds in an account with State Street Bank and Trust Company, N.A., in New York, New York, or its successor, sufficient for the payment to the Paying Agent, of amounts which are then due to the Paying Agent (as specified in the Demand for Payment) subject to the Surety Bond Coverage (as defined in the Series 1998 Reserve Account Insurance Policy). The available amount of the Series 1998 Reserve Account Insurance Policy is the initial face amount of the Series 1998 Reserve Account Insurance Policy less the amount of any previous deposits by MBIA with the Paying Agent which have not been reimbursed by the Agency. The Agency and MBIA will enter into a Financial Guaranty Agreement dated as of the date of issuance of the Series 1998 Bonds (the "Agreement"). Pursuant to the Agreement, the Agency is required to reimburse MBIA, within one year of any deposit, the amount of such deposit made by MBIA with the Paying Agent under the Series 1998 Reserve Account Insurance Policy, together with interest thereon. Such reimbursement shall be made only after all required deposits to the Sinking Fund (other than the Debt Service Reserve Account) have been made. As security for the payment obligations under the Agreement, the Agency and the City have granted to MBIA a lien upon the Pledged Funds, subordinate to the lien thereon for the benefit of Bondholders, credit providers and liquidity providers. The Series 1998 Reserve Account Insurance Policy will be held by the Paying Agent in the Debt Service Reserve Account and is provided as an alternative to the Agency depositing funds equal to a portion of the Reserve Account Requirement for outstanding Bonds. The Series 1998 Reserve Account Insurance Policy will be issued in the face amount of $7,312,238.25, which together with the cash on deposit in the Debt Service Reserve Account, will equal the Reserve Account Requirement for all Outstanding Bonds as of the date of delivery of the Series 1998 Bonds. The premium for the Series 1998 Reserve Account Insurance Policy will be fully paid by the Agency at the time of delivery of the Series 1998 Bonds. Additional Padty Bonds The Agency may issue additional Bonds pursuant to the Resolution on a parity as to payment from and lien on the Pledged Funds with the Bonds. Proceeds of such additional Bonds may be used for any purposes which are authorized pursuant to the Act. However, additional Bonds may be issued only upon compliance with the following conditions: (I) The Agency must be current in all deposits required to be made into the various funds and accounts and all payments theretofore required to have been deposited or made by it under the provisions of the Resolution, and the Agency must be currently in compliance with the covenants and provisions of the Resolution and any supplemental resolution thereafter adopted for the issuance of additional Bonds unless, upon the issuance of such additional Bonds, the Agency will be in compliance with all such covenants and provisions. (2) The amount of the Net Trust Fund Revenues (not including any portion thereof which may be attributable to investment earnings thereon) received by the Agency and the Supplemental 25 Revenues received by the City, each during the immediately preceding Fiscal Year, as certified by an independent certified publ ic accountant, were at least equal to 175 % of the Maximum Annual Debt Service requirements on (i) the outstanding Series 1993 Bonds, (ii) any outstanding additional parity Bonds, including the Series 1996A Bonds, the Series 1996B Bonds and the Series 1998 Bonds, and (iii) the additional parity Bonds then proposed to be issued, and (iv) in accordance with the next succeeding paragraph, any Supplemental Revenues Bonds issued and then Outstanding; provided, however, that upon the release of the lien and pledge of the Supplemental Revenues, (A) "175 %" above shall be replaced with" 150%," and (B) the foregoing calculations will be based solely on Net Trust Fund Revenues and will not include Supplemental Revenues Bonds. (3) The Agency need not comply with paragraph (2) above in the issuance of additional parity Bonds if and to the extent the Bonds to be issued are refunding Bonds to be delivered in lieu of or in substitution for Bonds originally issued under the Resolution or previously issued additional parity Bonds, if the Agency causes to be delivered to the Trustee a certificate of its Executive Director setting forth (i) the Maximum Annual Debt Service (A) with respect to all Bonds and, in accordance with the next succeeding paragraph, the Supplemental Revenues Bonds in each case Outstanding immediately prior to the date of authentication and delivery of such refunding Bonds, and (B) with respect to all Bonds and, in accordance with the next succeeding paragraph, the Supplemental Revenues Bonds in each case to be outstanding immediately thereafter, and (ii) that the Maximum Annual Debt Service set forth pursuant to (B) above wilI be no greater than those set forth pursuant to (A) above; provided, however, that upon the release of the lien and pledge of the Supplemental Revenues, as provided in the Resolution, the foregoing calculations wilI not include the Supplemental Revenues Bonds. For purposes of the subparagraphs numbered 2 and 3 above, Supplemental Revenues Bonds shall be deemed "Outstanding" and shalI be included in "Debt Service Requirement" and "Maximum Annual Debt Service" therein based upon the same rules applicable to Bonds under the Resolution. The Series 1998 Bonds are being issued as additional Bonds in accordance with the provisions of clauses (1) and (2) above. In addition, the Agency may issue obligations payable from Tax Increment Revenues on a subordinate basis to the Bonds without meeting the foregoing conditions. Investment of J<'unds Amounts held in the Trust Fund, Interest Account, Principal Account, Bond Redemption Account and Costs of Issuance Fund may be invested and reinvested only in Permitted Investments maturing not later than the date on which the moneys therein will be needed, Permitted Investments in the Debt Service Reserve Account must mature not later than the final maturity date of the Bonds. Investment earnings on Permitted Investments in the Debt Service Reserve Account must be retained therein to the extent necessary to maintain the Debt Service Reserve Account at the level equal to the Reserve Account Requirement, or if in excess of the Reserve Account Requirement, must be transferred to the Interest Account, the Principal Account, or the Bond Redemption Account in the Sinking Fund. Earnings on moneys in the other accounts in the Sinking I~und are required to remain on deposit in the Sinking Fund. 26 MUNICIPAL BOND INSURANCE Pooling of Money in Funds and Accounts Cash and Permitted Investments required to be accounted for in each of the funds and accounts established by the Resolution (except the Rebate Fund) may be deposited in a single bank account, provided that accounting records, prepared in accordance with generally accepted accounting principles as applied to government entities, are maintained to reflect control or restricted allocation of the moneys therein for the various purposes of such funds and accounts. General Payment of the scheduled principal of and interest on the corresponding Series of the Series 1998 Bonds when due will be guaranteed by two separate financial guaranty insurance policies (collectively, the "Policy") to be issued by MBIA simultaneously with the delivery of the Series 1998 Bonds. For a discussion of the terms and provisions of the Policy, including the Policy's limitations, see "The Policy" below and Appendix F hereto. In connection with the issuance of the Policy and the Series 1998 Reserve Account Insurance Policy, MBIA has been granted certain rights and the Agency has agreed to deliver certain documents and notices to MBIA. Among the rights granted MBIA is the right to be treated as the Holder of all the Series 1998 Bonds, in lieu of the registered owners of the Series 1998 Bonds, for purposes of (i) consenting to the adoption of any supplemental resolution pursuant to the Resolution which requires the consent of Holders of the Bonds and (ii) exercising any rights and remedies granted to the Holders of the Series 1998 Bonds under the Resolution upon the occurrence of a default thereunder. Reference is hereby made to Appendix B for the covenants for the benefit of MBIA. By purchasing the Series 1998 Bonds, the owners thereof, on their own behalf and on behalf of all subsequent owners of the Series 1998 Bonds, will haVe consented to such covenants for the benefit of MBIA. The Policy The following information has been furnished by MBIA for use in this Official Statement. MBIA's municipal bond insurance policy (the "Policy") unconditionally and irrevocably guarantees the full and complete payment required to be made by or on behalf of the Agency to the Paying Agent or its successor of an amount equal to (1) the principal of (either at the stated maturity or by an advancement of maturity pursuant to a mandatory sinking fund payment) and interest on. the Series 1998 Bonds as such payments shall become due but shall not be so paid (except that in the event of any acceleration of the due date of such principal by reason of mandatory or optional redemption or acceleration resulting from default or otherwise, other than any advancement of maturity pursuant to a mandatory sinking fund payment, the payments guaranteed by MBIA's Policy shall be made in such amounts and at such times as such payments of principal would have been due had there not been any such acceleration); and (2) the reimbursement of any such payment which is subsequently recovered from any owner of the Series 1998 Bonds pursuant to a final judgment by a court of competent jurisdiction that such payment constitutes an avoidable preference to such owner within the meaning of any applicable bankruptcy law (a "Preference"). MBIA's policy does not insure against loss of any prepayment premium which may at any time be payable with respect to any Series 1998 Bond. MBlA's Policy does not, under any circumstance, insure against loss relating to: (1) optional or mandatory redemptions (other than mandatory sinking fund 27 redemptions) (2) any payments to be made on an accelerated basis; (3) payments of the purchase price of 1998 Bonds upon tender of any owner thereof; or (4) any preference relating to (1) through (3) above. MBIA's policy also does not insure against nonpayment of principal of or interest on the Series 1998 Bonds resulting from the insolvency, negligence or any other act or omission of the Paying Agent or any other paying agent for the Series 1998 Bonds. Upon receipt of telephonic or telegraphic notice, such notice subsequently confirmed in writing by registered or certified mail, or upon receipt of written notice by registered or certified mail, by MBIA from the Paying Agent or any owner of a Series 1998 Bond the payment of an insured amount for which is then due, that such required payment has not been made, MBlA on the due date of such payment or within one business day after receipt of notice of such nonpayment, whichever is later, will make a deposit of funds, in an account with State Street Bank and Trust Company, N.A., in New York. New York, or its successor, sufficient for the payment of any such insured amounts which are then due. Upon presentment and surrender of such Series 1998 Bonds or presentments of such other proof of ownership of the Series 1998 Bonds, together with any appropriate instruments of assignment to evidence the assignment of the insured amounts due on the Series 1998 Bonds as are paid by MBIA, and appropriate instruments to effect the appointment of MBIA as agent for such owners of the 1998 Bonds in any legal proceedings related to payment of insured amounts on the Series 1998 Bonds, such instruments being in a form satisfactory to State Street Bank and Trust Company, N .A., State Street Bank and Trust Company, N. A. shall disburse to such owners or the Paying Agent payment of the insured amounts due on such Series 1998 Bonds, less any amount held by the Paying Agent for the payment of such insured amounts and legally available therefor. MBIA is the principal operating subsidiary of MBIA Inc., a New York Stock Exchange listed company (the "Company"). The Company is domiciled in the State of New York and licensed to do business in, and subject to regulation under the laws of, all 50 states, the Agency of Columbia, the Commonwealth of Puerto Rico, the Commonwealth of the Northern Mariana Islands, the Virgin Islands of the United States and the Territory of Guam. MBlA has two European branches, one in the Republic of France and the other in the Kingdom of Spain, New York has laws prescribing minimum capital requirements, limiting classes and concentrations of investments and requiring the approval of policy rates and forms. State laws also regulate the amount of both the aggregate and individual risks that may be insured, the payment of dividends by M13IA, changes in control and transactions among affiliates. Additionally. MBIA is required to maintain contingency reserves on its liabilities in certain amounts and for certain periods of time. Effective February 17, 1998 the Company acquired all of the outstanding stock of Capital Markets Assurance Corporation ("CMAC") through a merger with its parent, CapMAC Holdings Inc. Pursuant to a reinsurance agreement, CMAC has ceded all of its net insured risks (including any amounts due but unpaid from third party reinsurers), as well as its unearned premiums and contingency reserves to MBIA. The Company is not obligated to pay the debts of or claims against CMAC. As of December 31, 1997. M13IA had admitted assets of $5.3 billion (audited), total liabilities of $3.5 billion (audited), and total capital and surplus of $1.8 billion (audited) determined in accordance with statutory accounting practices prescribed or permitted by insurance regulatory authorities. As of March 31, 1998, MBIA had admitted assets of $5.4 billion (unaudited), total liabilities of $3.6 billion (unaudited), and total capital and surplus of $1.8 billion (unaudited) determined in accordance with statutory accounting practices prescribed or permitted by insurance regulatory authorities. 28 Copies of MBIA's year end financial statements prepared in accordance with statutory accounting practices are available without charge from MBIA. A copy of the Annual Report on Form IO-K of the Company is available from MBIA or the Securities and Exchange Commission. The address of MBIA is 113 King Street, Armonk, New York 10504. The telephone number of MBIA is (914) 273-4545. Moody's Investors Service rates the claims-paying ability of MBIA "AAA". Standard & Poor's Ratings Services, a division of The McGraw Hill Companies, Inc., rates the claims-paying ability of MBIA "AAA". Fitch mCA, Inc. (formerly known as Fitch Investors Service, L.P.), rates the claims paying ability of MBIA "AAA". Each rating of MBIA should be evaluated independently. The ratings reflect the respective rating agency's current assessment of the creditworthiness of MBIA and its ability to pay claims on its policies of insurance. Any further explanation as to the significance of the above ratings may be obtained only from the applicable rating agency. The above ratings are not recommendations to buy, sell or hold the Series 1998 Bonds, and such ratings may be subject to revision or withdrawal at any time by the rating agencies. Any downward revision or withdrawal of any of the above ratings may have an adverse effect on the market price of the Series 1998 Bonds. MBIA does not guarantee the market price of the Series 1998 Bonds nor does it guarantee that the ratings on the Series 1998 Bonds will not be revised or withdrawn. The insurance provided by the Policy is not covered by the Florida Insurance Guaranty Association created under Chapter 631, Florida Statutes. THE AGENCY Generally The Agency is a public body corporate and politic, and a public instrumentality, created by the City in 1976, pursuant to the Act, in order to pursue a program of community redevelopment within the designated portions of the City as permitted by the Act. The primary objective is to foster development and redevelopment in certain designated areas within the City utilizing appropriate private and public resources to eliminate and prevent the development and spread of blighted conditions in the designated area. For general information regarding the City and the County, see Appendix A hereto. The Redevelopment Plan On February 12, 1993 the Agency approved a redevelopment plan for the revitalization of the area surrounding the Miami Beach Convention Center and Lincoln Road and to foster the development of a convention hotel and necessary linkages to the Miami Beach Convention Center. The Redevelopment Area (known as the City Center/Historic Convention VilIage Redevelopment and Revitalization Area) is located partly within and partly adjacent to the City's Art Deco District, and covers approximately 50 city blocks, containing approximately 332 acres of land, of which 29 percent is currently occupied by public space and 71 percent by private use. The Redevelopment Area is bounded generally by Fourteenth Lane to the south. Twenty-Fourth Street to the north, the Atlantic Ocean to the east and West Avenue to the west. The area 29 includes the Lincoln Road Mall, the Miami Beach Convention Center and the Jackie Gleason Theater of the Performing Arts. The Redevelopment Area is the second area within the City to be dcsignated For redevelopmcnt by the Agency, the first of which includes the redevelopmcnt of the South Shore area of the City in the redevelopment area known as South Pointe. Management of the Agency Since 1982, the City Commission has constituted the Agency, with thc City Commissioners sitting as the Agency members. Sergio Rodriguez is the Executive Director of the Agency. The current members of the Agency are as follows: Name Title Term Expiration(l) Neisen Kasdin(2) Nancy Liebman Simon Cruz David Denner Susan Gottlieb Martin Shapiro Jose Smith Chairman Vice Chairman!)) Commissioner Commissioner COlnmissinner Commissioner Commissioner November 1999 November 200 I November 1999 November 2001 November 1999 November 1999 November 2001 (I) Expiration of Mayor and City Commission Terms (2) Mayor, City of Miami Beach ()) Position of Vice Chairman rotates every four months. The City Manager acts as Executive Director of the Agency. Sergio Rodriguez was appointed City Manager of Miami Beach effective January 4, 1998. Prior to his appointment, Mr. Rodriguez served as Deputy City Manager (commencing August, 1995) and as the Assistant City Manager of the City of Miami (from 1987 through 1995). He received a B.A. degree from the University of Florida and a M.A. degree from the University of North Carolina at Chapel Hill. Fiscal Matters The Agency's financial statements arc reported separately from the City's. Pursuant to the Act, the Agency is required to provide for an independent financial audit of the redevelopment trust funds each fiscal year and a report of such audit. The Agency is also required to submit by March 31 of each year an annual report to the Florida Auditor General, which includes a complete f!nancial report. According to the most recent audited financial statements of the Agency (fiscal year ended September 30, 1997), the Agency's accounts are organized on the basis of funds and account groups, each of which are considered a separate accounting entity. The operations of each fund are accounted for with a separate set of self-balancing accounts that comprise its assets, liabilities, fund equity, revenues and expenditures, as appropriate. The modified accrual basis of accounting is used for all Governmental Fund Types and the Expendable Trust Fund. Modifications from the accrual basis to present the modified accrual basis are as follows: 30 Type of Property 1. Revenues are recognized when they become both measurable and available to finance expenditures of the current period. Property taxes and intergovernmental revenues are the significant revenue sources considered susceptible to accrual. 2. Purchases of capital assets providing future benefits are considered expenditures and are accounted for in the General Fixed Assets Account Group. 3. Interest on general long-term indebtedness in not accrued but is recorded as an expenditure on its due date. Assessed Valuations In the Redevelopment Area the aggregate assessed value of taxable real property in the Redevelopment Area as of January 1, 1992 (the Base Year), used for determining the incremental assessed valuation in future years, was $292,572,271. The aggregate assessed value of taxable real property in the Redevelopment Area as of January I, 1997 was $531,364,583. Ten Largest Assessed Valuations Within the City Center/Historic Convention Village Redevelopment District 1997 Owner Roney Plaza Associates, Ltd. Oceanside Resorts, Inc. De Lido Inc. Beach Hotel Assoc. Ltd. Partnership Lincoln Road Associates Uccello Immobilien Florida Resort Management Phillips South Beach Ltd. Ritz-Plaza Hotel Corp. Paul M. Kasden Assessed Value Apartments Holiday lnn Oceanside De Lido Hotel $ 46,500,000 14,162,994 11,250,000 Delano Hotel Office Building Office Building National Hotel Shore Club Hotel Ritz-Plaza Hotel Days Inn Hotel 10,750,000 8,384,590 8,138,477 7,650,000 6,328,000 6,122,800 5.882.000 Total (Representing 23.6% of Total Assessed Value of the Redevelopment Area as of January 1, 1997) $125.168.861 " THE PROJECT In February, 1993, the City Center/Historic Convention Village Redevelopment and Revitalization Area was officially established by the adoption of the Redevelopment Plan. The Redevelopment Plan was the result of the combined efforts of the City, the County and the State of Florida. The Redevelopment Plan represents the effort and commitment of the City to eliminate blight and foster the development of convention quality hotels and ancillary commercial facilities, as well as necessary linkages to the Miami Beach Convention Center. The Redevelopment Area includes properties listed in the National Register of Historic Places. The Redevelopment Plan includes the criteria for a "Historic Convention Village" concept 31 which recognizes the scale of the neighborhood and integrates existing hotels' historic structures with compatible new hotel development. Pursuant to the Act and the Redevelopment Plan, the Agency may purchase, lease, obtain options upon, acquire by gift, grant or bequest or any other means, or acquire by eminent domain, any real or personal property, any interest in property, and any improvements thereon, within the Redevelopment Area whenever such action is necessary in order to achieve the purposes of the Redevelopmcnt Plan. The Series 1998A Project consists of the following: 1. Complction of development and construction of ccrtain public areas of the Loews Miami Beach Hotel located in the Redevelopment Area at 1601 Collins A venue. 2. Completion of development and construction of a public parking garage located in the Redevelopment Area between Washington Avenue and Collins Avenue proximate to 16th Street. 3. Acquisition of property for the development and construction of the Royal Palm Crowne Plaza Resort Hotel to be located in the Redevelopment Area at 15th Street and CoIl ins A venue. 4. Acquisition of property for and development and construction of a portion of the cultural center facilities to be located in the Redevelopment Area between 20th Street and 23rd Street, proximate to Collins Avenue, consisting of Collins Park, a regional library facility, the Miami City Ballet building and a public parking garage. The Series 1998A Project will also include repayment of that portion of an interim loan from the City (the "City Loan") relating to the Series 1998A Project, which City Loan was made to fund a portion of the Series 1998A Project and the Series 1998B Project. The Series 1998B Project consists of the following: 1. Acquisition of property for and development and construction of a portion of the cultural center facilities to be located in the Redevelopment Area between 20th Street and 23rd Street, proximate to Collins Avenue, consisting of Collins Park, a regional library facility, the Miami City Ballet building and a public parking garage. 2. Additional public improvements which the Agency by resolution determines to undertake within the Redevelopment Area in accordance with thc Redevelopment Plan and which may be funded from proceeds of bonds the interest on which is excludable from gross income for federal income tax purposes. The Series 1998B Project will also include repayment of that portion of the City Loan relating to the Series 1998B Project. ALTHOUGH THE PROJECT IS EXPECTED TO GENERATE ADDITIONAL NET TRUST FUND REVENUES AND SUPPLEMENTAL REVENUES WHICH MAYBE USED TO PAY DEBT SERVICE ON THE BONDS, NEITHER THE PROJECT NOR ANY ELEMENTS THEREOF. CONSTITUTE SECURITY FOR THE BONDS, AND THE BONDHOLDERS HAVE NO LIEN THEREON. THE BONDS ARE SECURED SOLELY BY A LIEN UPON AND PLEDGE OF TIlE PLEDGED FUNDS AS DESCRII3ED UNDER "SECURITY FOR TilE SERIES 1998 llONOS". 32 Reference is made to the table under the heading "ESTIMATED DEBT SERVICE COVERAGE" for estimates of debt service coverage on the Bonds prior to construction of the Project. SUMMARY OF CERTAIN PROVISIONS OF THE RESOLUTION Certain provisions of the Reso)u1ion are summarized below, but these summaries are qualified by the complete provisions of the Resolution, and reference is made to the Resolution for additional provisions not summarized herein. See Appendix I3 hereto for the form of Agency Resolution No. 150-94. Capitalized terms used but not defined in this Official Statement have the same meaning as when used in the Resolution unless the context would clearly indicate otherwise. The applicable definitions are contained in the Agency Resolution No. 150-94 attached as Appendix- B hereto. Payment of Bonds The Agency covenants in the Resolution to duly and timely payor cause to be paid from the Pledged Funds, the principal of, redemption premium, if any, and interest on all Bonds, when due. The Trustee shall transfer moneys in the required amounts from the funds and accounts created in the Resolution to the principal office of the Paying Agent at least one business day prior to the date on which such payments of principal, interest and premium are due. Enforceability of Collections The Agency covenants in the Resolution to diligently enforce and collect the Trust Fund Revenues and take all actions within its control to cause the City to transfer Supplemental Revenues as required under the Resolution and under the Supplemental Revenues Resolution and will take all steps, actions and proceedings for the enforcement and collection of such Trust Fund Revenues and transfer of Supplemental Revenues to the full extent permitted or authorized by applicable laws. All Net Trust Fund Revenues and. Supplemental Revenues shall, as collected and transferred, respectively, be held in trust to be applied as provided in the Resolution and not otherwise. Accounting Records and Annual Audit The Agency covenants in the Resolution to maintain separately identifiable accounting records for the receipt of the Pledged Funds; any Holder has the right at all reasonable times to inspect all records, accounts and data of the Agency relating thereto. The Agency also covenants in the Resolution to, immediately after the close of each Fiscal Year, cause the books, records and accounts relating to the Trust Fund Revenues to be properly audited by a recognized independent certified public accountant. Such audit must contain, but is not limited to, the statements required by generally accepted accounting principles applicable to governmental units, and a certificate by the auditors disclosing any default on the part of the Agency of any covenant herein. A copy of such annual audit must be made available to any Holder upon " request. Cl'edit Facility/Liquidity Facility As long as any of the Series of Bonds are secured by a Credit Facility or Liquidity Facility, (i) the Agency covenants to comply with the requirements and conditions imposed on the Agency by the issuer of the Credit Facility or Liquidity Facility and (ii) all rights granted under the Resolution to the Holders of bonds so secured shall be exercisable by the issuer of such Credit Facility or Liquidity Facility, in lieu of the Holders of such Bonds. 33 Modification 0.' Amendment No adverse material modification or amendment of the Resolution may be made without the consent in writing of (i) the Holders of more than 50% in principal amount of the Bonds then Outstanding; or (ii) in case less than all of the several Series of Bonds then Outstanding are affected by the modification or amendment, the Holders of more than fifty percent (50 %) in aggregate principal amount of the Bonds of each Series so affected and Outstanding at the time such consent is given; provided, however, that no modification or amendmcnt shall permit a changc in the ma1urity of such Bonds or a reduction in the rate of interest thereon, or affecting the promise of the Agency to pay the principal of and interest on the Bonds, as the same mature or become due, from the Pledged Funds, or reduce the percentage of Holders of Bonds required above for such modification or amendment, without the consent of the Holders of all the Bonds. To the extent any Series of Bonds is secured by a Credit Facility or Liquidity Facility, then the consent of the issuer of the Credit Facility or Liquidity Facility shall constitute the consent of the Holders of such Series. The Resolution may be amended, changed, modified and altered without the consent of the Holders of Bonds or any Credit Facility or Liquidity Facility: I. to cure any ambiguity or formal defcct or omission in the Resolution or in any supplemental resolutions or to correct or supplement any provision contained herein which may be defective or inconsistent with any other provisions contained herein; or 2. to grant to or confer upon the Bondholders any additional rights, rcmedies, powers, authority or security that may lawfully be granted to or conferred upon the Bondholders; or 3. to add to the conditions, limitations and restrictions on the issuance of Bonds under the provisions of the Resolution, other conditions. limitations and restrictions thereafter to be observed; or 4. to add to the covenants and agreements of the Agency in the Resolution other covenants and agreements thereafter to be observed by the Agency or to surrender any right or power herein reserved 10 or conferred upon the Agency; or 5. to permit the issuance of Bonds, the interest on which is intended to be excludable from gross income for Federal income tax purposes under the Code to the Holders thereof in coupon form, if as a condition precedent to the adoption of such supplemental resolution, there shall be delivered to the Agency an opinion of counsel of recognized standing relating to municipal bonds to the effect that the issuance of Bonds in coupon form is then permitted by law and that the issuance of such Bonds in coupon form would not cause interest on such Bonds to be included in gross income for Federal income tax purposes under the Code to the Holders thereof; or 6. to permit the Agency to issue Bonds the interest on which is not excludable from gross income for Federal income tax purposes under the Code to the Holders thercof; or 34 10. to permit Bonds to be issued in book entry form with or without physical bonds; 7. to qualify the Bonds or any of the Bonds for registration under the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended; or 8. to qualify the Resolution as an "indenture" under the Trust Indenture Act of 1939, as amended; or 9. to make such changes as may be necessary to adjust the terms hereof, including the provisions of Section 304(0) of the Resolution, so as to facilitate the issuance of Capital Appreciation Bonds, Capital Appreciation and Income Bonds, Put Bonds, Interim Bonds and such other Bonds as may be marketable from time to time; or or 11. to make such changes as may be necessary to comply with the provisions of the Code relating to the exclusion of interest on the Bonds from gross income thereunder; or 12. to make such changes as may evidence the interest herein of an issuer of a Credit Facility or a Liquidity Facility that secures any Series of Bonds. The consent of the Holders of any additional Series of Bonds shall be deemed given if the underwriters or initial purchasers for resale consent in writing to such supplemental resolution and the nature of the amendment effected by such supplemental resolution is disclosed in the official statement or other offering document pursuant to which such additional Series of Bonds is offered and sold to the public. Remedies Any Holders of Bonds issued under the provisions of the Resolution or the Trustee may by suit, action, mandamus or other proceedings in any court of competent jurisdiction, protect and enforce any and all rights, including the right to the appointment of a receiver, existing under the laws of the State of Florida, or granted and con1ained in the Resolution, and may enforce and compel the performance of all duties therein required or required by any applicable statutes to be performed by the Agency or by any officer thereof. Nothing in the Resolution, however, may be construed to grant to any Holder of such Bonds any lien on any property of the Agency, except the lien created under the Resolution. No Holders of any Bonds, however, have any right in any manner whatever to affect, disturb or prejudice the security of the Resolution or to enforce any right thereunder except in the manner provided in the Resolution, and all proceedings at law or in equity must be instituted and maintained for the benefit of all Holders of Bonds. Discharge and Satisfaction of Bonds ~ The covenants, liens and pledges entered into, created or imposed pursuant to the Resolution may be fully discharged and satisfied with respect to all or a portion of the Bonds in anyone or more of the following ways: (i) by paying the principal of and interest on such Bonds when the same shall become due and payable; or (ii) by depositing in the Interest Account, the Principal Account and the Bond Redemption Account and/or in such other accounts which are irrevocably pledged to the payment 35 of Bonds as the Agency may hereafter create and establish by resolution, certain moneys which together with other moneys lawfully available therefor, if any, shall be sufficient at the time of such deposit to pay when due the principal, redemption premium, if any, and interest due and to become due on said Bonds on or prior to the redemption date or maturity date thereof; or (iii) by depositing in the Interest Account, the Principal Account and the Bono Redemption Account and/or such other accounts which are irrevocably pledged to the payment of Bonds as the Agency may hereafter create and establish by resolution, moneys which together with other moneys lawfully available therefor when invested in such Defeasance Obligations which shall not be subject to redemption prior to their maturity other than at the option of the Holder thereot", will provide moneys which shall be sufficient to pay when due the principal, redemption premium, if any, and interest due and to become due on said Bonds on or prior to the redemption date or maturity date thereof. Upon such payment or deposit in the amount and maImer described above, Bonds shall be deemed to be paid and shall no longer be deemed to be Outstanding and all liability of the Agency with respect to said Bonds shall cease, terminate and be completely discharged and extinguished, and the Holders thereof shall be entitled for payment solely out of the moneys or securities so deposited; provided that (i) in connection with any discharge and satisfaction pursuant to subsection (ii) or (iii) above, the Agency shall concurrently with such deposit deliver (A) an opinion of nationally recognized bond counsel to the effect that interest on the Bonds being discharged, if the same are excluded from gross income for federal income tax purposes, will not, by reason of such discharge, become includable in gross income for federal income tax purposes and that such Bonds have been discharged in accordance with the provisions hereof, and (B) an accountant's verification report showing the sufficiency of such moneys and/or Defeasance Obligations to provide for the payment of said Bonds, and (ii) in the event said Bonds do not mature and are not to be redeemed within the next succeeding sixty (60) days, the Agency shall have given the Registrar irrevocable instructions to give, as soon as practicable, a notice to the Holders of said Bonds by first-class mail, postage prepaid, stating that the deposit of said moneys or Defeasance Obligations has been made with an appropriate fiduciary institution acting as escrow agent solely for the Holders of said Bond and other Bonds being defeased, and that said Bonds are deemed to have been paid in accordance with the provisions hereof and stating such maturity or redemption date upon which moneys are to be available for the payment of the principal of and premium, if any, and interest on said Bonds. (iv) Notwithstanding any of the provisions of the Resolution to the contrary, Put Bonds and Extendible Maturity Bonds may only be fully discharged and satisfied either pursuant to paragraph (i) above or by depositing in the Interest Account, the Principal Account and the Bond Redemption Account, or in such other accounts which are irrevocably pledged to the payment of the Put Bonds or Extendible Maturity Bonds as the Agency may hereafter create and establish by resolution, moneys which together with moneys lawfully available therefor, if any, shall be sufficient at the time of such deposit to pay when due the maximum amount of principal of and redemption premium, if any, and interest on such Put Bonds and Extendible Maturity Bonds which could become payable to the Holders of such Bonds upon the exercise of any options provided to the Holders of such Bonds or the Agency; provided however, that if, at the time a deposit is made pursuant to this paragraph, the options originally exercisable by the Holder of a Put Bond or Extendible Maturity Bond or 1he Agency are no longer exercisable, such Bond shall not he considereo a Put Bond or Extendible Maturity Bono for purposes of this paragraph. 36 RISK FACTORS (v) Notwithstanding the foregoing, all references to the discharge and satisfaction of Bonds shall include the discharge and satisfaction of any issue of Bonds, any portion of an issue of Bonds. any maturity or maturities of an issue of Bonds, any portion of a maturity of an issue of Bonds or any combination thereof. provided that the provisions of this paragraph shall not affect the requirements regarding Put Bonds and Extendible Maturity Bonds set forth in paragraph (iv). (vi) If any portion of the moneys deposited for the payment of the principal of and redemption premium, if any, and interest on any portion of Bonds is not required for such purpose, the Agency may use the amount of such excess free and clear of any trust, lien, security interest, pledge or assignment securing said Bonds or otherwise existing under the Resolution. In the event that the principal and redemption price, if applicable, and interest due on the Bonds shall be paid by the issuer of a Credit Facility or Liquidity Facility pursuant to the terms thereof, the assignment and pledge created under the Resolution and all covenants, agreements and other obligations of the Agency to the Bondholders shall continue to exist and the issuer of such Credit Facility or Liquidity Facility shall be subrogated to the rights of such Bondholders. General The ability of the Agency to make timely payments of principal of, redemption premium, if any, and interest on the Bonds depends substantially upon the ability of the Agency to collect sufficient Tax Increment Revenues based upon real property in the Redevelopment Area which together with earnings thereon and, while pledged thereto, the Supplemental Revenues, will be adequate to make such payments. The Bonds are not general obligations supported by the full faith and credit of the City, the Agency, the County or the State or any political subdivision of the foregoing, but are payable solely from the Pledged Funds. Neither the State, the County, the City, the Agency, or any other political subdivision of the State has any obligation or power under the Resolution or under Florida law to levy any taxes in order to pay debt service on the Bonds or to avail or cure any default in any such payments. Except for the Debt Service Reserve Account, there is no fund or amount under the Resolution which is required to contain amounts to make up for any deficiencies in the event of one or more defaults by the Agency in making payments of debt service on the Bonds, and there is no source from which the Sinking Fund will be replenished except the Tax Increment Revenues, the Supplemental Revenues, and investment income on moneys in the Funds held by the Trustee. There can be no representation or assurance that the Agency will realize sufficient Tax Increment Revenues or Supplemental Revenues to pay, when due, all required payments of debt service on the Bonds. The following paragraphs summarize some of the risks involved in a Florida tax increment financing such as the Series 1998 Bonds. Such summaries are not intended to be an exhaustive list of risk factors in connection with the Series 1998 Bonds. Tax Increment Financing Competition from Comparable Developments Outside the Redevelopment Area. The Agency's growth strategy for the Redevelopment Area is in competition with other communities located outside the Redevelopment Area whose growth will not generate Tax Increment Revenues for thc payment of the Bonds. In the event that a large number of condominium. rcntal or commercial projects are constructed 37 in the City outside the Redevelopment Area, the demand for residential housing and commercial space within the Redevelopment Area could be reduced, thereby leading to a possible reduction in future development in the Redevelopment Area and a reduction in collections of Tax Increment Revenues. State, Natiollal alld Illternatiollal Ecollomic alld Political Factors. Certain economic or pol itical developments, such as downturns in the State, national or international economy, increased national or international barriers to tourism or trade or international currency Ouctuations could all adversely affect the continued development of the Redevelopment Area or its attraction to businesses and investors. Failure to Achieve III creases ill Propelty Values. Numerous events could occur that might reduce or cause stagnation in the value of real property within the Redevelopment Area, including natural disasters; public acquisition of property within the Redevelopment Area by the State or political subdivisions exercising their respective rights of eminent domain; or social, economic or demographic factors (or adverse public perceptions thereto) beyond the control of the Agency, the City or the taxpayers in the Redevelopment Area. Any or all of such events could adversely affect the realization and collection of Tax Increment Revenues. The Agency has not engaged a feasibility consultant to calculate projected Tax Increment Revenues in the Redevelopment Area. Impact oJ Additiollal Taxpayers or Illcreased Property Values Outside the Redevelopmellt Area. The addition of significant numbers of new taxpayers or an increase of property values outside the Redevelopment Area could result in an environment l~lVorable to the reduction of the County and/or City millage rates that could, in turn, reduce the amount of Tax Increment Revenues payable by the County and/or the City. Appeals oJ Assessmellts. State law allows taxpayers to dispute assessment valuations. The statutory method for determining Tax Increment Revenues uses a factor of 95 %, due in part to an expectation of some such appeals. Any volume of appeals which are successful in reducing the overall assessed value of the Redevelopment Area in excess of such a margin of error could result in reduced amounts of Tax Increment Revenues payable by the County and/or the City. Adverse Legislative, Judicial or Admillistratil'e Actioll. The State legislature, the courts or an administrative agency with jurisdiction in the matter could enact new laws or regulations or interpret. amend, alter, change or modify the laws or regulations governing the collection, distribution, definition or accumulation of ad valorem tax revenues generally, or Tax Increment Revenues specifically, in a fashion that would adversely affect the ability of the Agency to pay debt service on the Series 1998 Bonds. Supplemental Revenues The Bonds are additionally secured by a pledge of the Supplemental Revenues. However, the lien on the Supplemental Revenues may be released under certain conditions, including that Net Trust Fund Revenues received by the Trustee have been in a specified amount for the prior two fiscal years. Once the lien on the Supplemental Revenues is released, the City will be under no obligation to supplement the moneys available to pay debt service on the Bonds. The test for release of the Supplemental Revenues, and the issuance of additional parity Bonds as well, docs not require the Agency to provide, obtain or calculate projected Net Trust Fund Revenues. There is no assurance that once the lien on the Supplemental Revenues is released the Net Trust Fund Revenues will be sufficient in future years to pay debt service on the Bonds. The release of the lien on the Supplemental Revenues does not require the consent of the Trustee or of the Holders of the Bonds. 38 Additionally, economic and other conditions outside the control of the City may affect the amount of Resort Tax collected in any year. There is no assurance that the amount of Resort Tax collected will remain or exceed the amounts collected in prior years. A material reduction in the amount of Resort Tax collected in the City may result in there not being sufficient Supplemental Revenues to meet the City's obligations under the Supplemental Revenues Resolution. LITIGATION As of the date of issuance and delivery of the Bonds, the General Counsel of the Agency and the City Attorney of the City will deliver his opinion, dated such date, that no litigation or other proceedings for which the Agency or the City has received service of process are pending, or to his actual knowledge, threatened against the Agency or the City in any court or other tribunal, that seeks to restrain or enjoin the issuance or delivery of the Series 1998 Bonds or the proceedings or authority under which they are to be issued, or which in any manner questions the right of the Agency or the City to pledge the Pledged Funds or the Supplemental Revenues, respectively, to the 'repayment of the Series 1998 Bonds or undertake the Project, or which would have a materially detrimental impact upon the Agency's financial condition. LEGAL MATTERS Certain legal matters incident to the issuance of the Series 1998 Bonds will be passed upon by Squire, Sanders & Dempsey L.L.P., Miami, Florida, Bond Counsel, in substantially the form set forth as. Appendix E hereto. Certain legal matters will be passed upon for the Agency and the City by Murray H. Dubbin, City Attorney and General Counsel of the Agency, and for the Underwriters by Ruden, McClosky, Smith, Schuster & Russell, P.A., Miami, Florida, and Dennis Scholl, P.A., Miami, Florida, Co- Underwriters' Counsel. TAX MATTERS Series 1998A Bonds NO ATTEMPT HAS BEEN OR WILL BE MADE TO COMPLY WITH CERTAIN REQUIREMENTS RELATING TO THE EXCLUSION FROM GROSS INCOME FOR FEDERAL INCOME TAX PURPOSES OF INTEREST ON THE SERIES 1998A BONDS. INTEREST ON THE SERIES 1998A BONDS IS INCLUPABLE IN GROSS INCOME OF THE HOLDERS THEREOF FOR FEDERAL INCOME TAX PURPOSES. In the opinion of Bond Counsel, the Series 1998A Bonds and the income thereon are exempt from taxation under the laws of the State of Florida, except for estate taxes imposed by Chapter 198, Florida Statutes, as amended, and net income and franchise taxes imposed by Chapter 220, Florida Statutes, as amended, on interest, income or profits on debt obligations owned by "corporations", "banks" and "savings associations" as said terms are defined in said Chapter 220. Bond C6unsel will express no opinion regarding any other federal or state tax consequences relating to the Series 1998A Bonds. Payments of principal and interest on the Series 1998A Bonds may be subject to the "backup withholding tax" under Section 3406 of the Internal Revenue Code of 1986, as amended (the "Code"), at a rate of thirty-one percent (31 %) if recipients of such payments (other than foreign investors who have properly provided certifications) fail to properly provide to the payor certain information, including their taxpayer identification numbers, or otherwise fail to establish an exemption from such tax. Any amounts deducted and withheld from a payment to a recipient are allowed as a credit against the federal income tax 39 of such recipient. Furthermore, certain penaIlies may be imposed by the Internal Revenue Service on a recipient of payments who is required to supply information but does not do so in the proper manner. Series 1998B Bonds In the opinion of Bond Counsel, under existing law, (i) interest on the Series 1998B Bonds is excluded from gross income for federal income tax purposes under Section 103(a) of the Code; (ii) interest on the Series 1998B Bonds is !lQJ; an item of tax preference under Section 57 of the Code for purposes of the alternative minimum tax imposed on individuals and corporations; and (iii) the Series 1998B Bonds and the income thereon are exempt from taxation under the laws of the State of Florida, except for estate taxes imposed by Chapter 198, Florida Statutes, as amended, and net income and franchise taxes imposed by Chapter 220, Florida Statutes, as amended, on interest, income or profits on debt obligations owned by "corporations," "banks" and "savings associations" as such terms are defined in said Chapter 220. Bond Counsel will express no opinion as to other tax consequences regarding the Series 1998B Bonds. The opinion on federal tax matters will be based on and will assume the accuracy of certain representations and certifications and compliance with certain covenants of the Agency to be contained in the transcript of proceedings and which are intended to evidence and assure the foregoing, including that the Series 1998B Bonds are and will remain obligations the interest on which is excluded from gross income for federal income tax purposes. Bond Counsel will not independently verify the accuracy of the certifications and representations made by the Agency. Under Code provisions applicable only to certain corporations (as defined for federal income tax purposes), a portion of the excess of adjusted current earnings (which includes interest on all tax-exempt bonds, including the Series 1998B Bonds) over other alternative minimum taxable income is included in alternative minimum taxable income that may be subject to a corporate alternative minimum tax. In addition, interest on the Series 1998B Bonds may be subject to a branch profits tax imposed on certain foreign corporations doing business in the United States and to a tax imposed on excess net passive income of certain S corporations. The Code prescribes a number of qualifications and conditions for the interest on state and local obligations to be and to remain excluded from gross income for federal income tax purposes, some of which, including provisions for potential payments by the Agency to the federal government, require future or continued compliance after issuance in order for the interest to be and to continue to be so excluded from the date of issuance. Noncompliance with these requirements by the Agency could cause the interest on the Series 1998B Bonds to be included in gross income for federal income tax purposes and thus to be subject to federal income taxes retroactively to the date of their issuance. The Agency will covenant to take actions required of it for the interest on the Series 1998B Bonds to be and to remain excluded from gross income for federal income tax purposes, and not to take any actions that would adversely affect that exclusion. Under the Code, the exclusion of interest from gross income for federal income tax purposes can have certain adverse federal income tax consequences on items of income, deduction or credit for certain taxpayers, including among them financial institutions, certain insurance companies, FASITs (financial asset securitization investment trusts), recipients of Social Security and Railroad Retirement benefits, those that are deemed to incur or continue indebtedness to acquire or carry tax-exempt obligations and individuals otherwise eligible for the earned income tax credit. The applicability and extent of these and other tax consequences will depend upon 1he particular tax slatus or other tax items of the owner of the Series 1998B Bonds. Bond Counsel will express no opinion regarding such consequences. 40 From time to time, there are legislative proposals in Congress which, if enacted, could alter or amend one or more of the federal income tax matters referred to herein or adversely affect the market value of the Series 1998B Bonds. It cannot be predicted whether or in what form any such proposal might be enacted or whether, if enacted, it would apply to obligations (such as the Series 1998B Bonds) issued prior to enactment. The discussion of tax matters in this subheading applies only in the case of purchasers of the Series 1998B Bonds at their original issuance and at the respective prices indicated on the inside cover. It does not address any other tax consequences such as, among others, the consequence of the existence of any market discount to subsequent purchasers of the Series 199813 Bonds. ORIGINAL ISSUE DISCOUNT Although the Series 1998A Bonds maturing in the year 2022 have been offered and sold to the public at an original issue discount ("DID"), that DID is de minimis under Section 1273(a)(3) of the Code and therefore treated as zero. The Series 1998B Bonds maturing in the years 2018 and 2022, respectively, (collectively, the "Discount Bonds"), have been offered and sold to the public with DID. DID is the excess of the stated redemption price at maturity (original principal amount) over the "issue price" of each Discount Bond. The issue price of a Discount Bond is the initial offering price to the public (other than to bond houses, brokers or similar persons acting in the capacity of underwriters or wholesalers) at which a substantial amount of the Discount Bonds of the same maturity are sold pursuant to that offering. For federal income tax purposes, DID accrues to the owner of a Discount Bond over the period to maturity based on the constant yield method, compounded semiannually (or over such shorter permitted compounding interval selected by the owner). The portion of DID that accrues during the period of ownership by the initial purchaser of a Discount Bond (i) is interest excludable from that purchaser's gross income for federal income tax purposes to the same extent and subject to the same considerations discussed above as to other interest on the Series 1998B Bonds, and (ii) is added to that purchaser's tax basis for purposes of determining gain or loss on the maturity, redemption, prior sale or other disposition of that Discount Bond. A purchaser of a Discount Bond at its issue price in the initial public offering who holds that Discount Bond to maturity will realize no gain or loss upon the retirement of that Discount Bond. Owners of Series 199813 Bonds should consult their own tax advisers as to the determination for federal income tax purposes of the amount of OlD accruable each year with respect to such Bonds and as to other federal tax consequences and the treatment of DID for state and local tax purposes. ENFORCEABILITY OF REMEDIES The remedies available to the Holders of the Series 1998 Bonds upon an event of default under the Resolution are in many respects dependent upon judicial actions which are often subject to discretion and delay. Under existing constitutional and statutory law and judicial d~cisions, including specifically the federal bankruptcy code, the remedies specified in the Resolution upon an event of default thereunder may not be readily available or may be limited. The various legal opinions to be delivered concurrently with the delivery of the Series 1998 Bonds (including Bond Counsel's approving opinions) will be qualified, as to the enforceability of the various legal instruments, by limitations imposed by bankruptcy, reorganization, insolvency or other similar laws affecting the rights of creditors enacted before or after such delivery. UNDERWRITING The Series 1998A Bonds will be purchased by the Underwriters at an aggregate purchase price of $28,856,954.78 (which reflects $29,105,000 principal amount of the Series 1998A Bonds less an underwriters' discount of $205,189.02 and an original issue discount of $42,856.20), plus accrued interest 41 to the date of delivery. The Series 19988 Bonds will be purchased by the Underwriters at an aggregate purchase price of $9,038,377 .67 (which reflects $9,135,000 principal amount of the Series 199813 Bonds less an underwriters' discount of $65,604.48 and an original issue discount of $31,017.85), plus accrued interest to the date of delivery. The offer of the Underwriters to purchase the Series 1998 Bonds, accepted by the Agency, provides for the purchase of all but not less than all of the Series 1998 Bonds. The Underwriters have furnished the information on the cover page of this Official Statement pertaining to the public offering price of the Series 1998 Bonds. The Underwriters may offer to sell the Series 1998 Bonds to certain dealers (including dealers depositing the Series 1998 Bonds into investment trusts) and others at prices lower than the public offering prices stated on the cover page hereof. The initial public offering prices may be changed from time to time by the Underwriters. RA TINGS Moody's Investors Service ("Moody's") and Standard & Poor's Ratings Service, a division of The McGraw-Hili Companies, Inc. ("Standard & Poor's") have assigned their municipal bond ratings of "Baa2" and "131313", respectively, to the Series 1998 Bonds, without regard to whether the Series 1998 Bonds are insured. Moody's and Standard & Poor's have also assigned their municipal bond ratings of "Aaa" and "AAA", respectively, to the Series 1998 Bonds, with the understanding that upon issuance, the Series 1998 Bonds will be insured by the Policy issued by MBlA. There is no assurance that such ratings will continue for any given period of time or that they will not be lowered or withdrawn entirely by the rating agencies, or either of them, if in their judgment circumstances so warrant. A downward change in or withdrawal of such ratings, or either of them, may have an adverse effect on the market price of the Series 1998 Bonds. Such ratings reflect the respective views of such organizations and an explanation of the significance of such ratings may be obtained only from the rating agencies furnishing the same. ADVISORS AND CONSULTANTS The Agency has retained certain advisors and consultants in connection with the issuance of the Series 1998 Bonds. These advisors and consultants arc compensated from a portion of the proceeds of the Series 1998 Bonds, identified as "Cost of Issuance" under the heading "SOURCES AND USES OF FU N DS" herein; their compensation is contingent upon the issuance of the Series 1998 Bonds and the receipt of the proceeds thereof. Financial Advisor. Dain Rauscher Incorporated, Miami, Florida, is serving as Financial Advisor in connection with the preparation of the Agency's plan of financing and with respect to the authorization and issuance of the Series 1998 Bonds. The Financial Advisor will not engage in any underwriting activities with regard to the issuance and delivery of the Series 1998 Bonds. Bond Counsel. Squire, Sanders & Dempsey L.L.P., Miami, Florida, is serving as Bond Counsel with respect to the issuance of the Series 1998 Bonds. DISCLOSURE MATTERS Cel.tificate as to Official Statement The execution and delivery of this Official Statement has been duly authorized by the Agency. At the time of delivery of the Series I Y98 Bonds to the Underwriters, the Agency will provide to the Underwriters a certificate (which may be included in a consolidated closing certificate of the Agency), signed by those Agency officials who signed this Official Statement, relating to the accuracy and completeness of this Official Statement. 42 Continuing Disclosure The Agency and the City will covenant for the benefit of Series 1998 Bondholders to provide certain financial information and operating data relating to the Agency and the City not later than 240 days following the end of each Fiscal Year (the "Annual Report"), and to provide, or cause to be provided, notices of the occurrence of certain enumerated events, if deemed by the Agency to be material. The Annual Report is required to be filed with each Nationally Recognized Municipal Securities Information Repository and with any state information depository with which filings are required to be made. The notices of material events will be filed with the Municipal Securities Rulemaking Board or each Nationally Recognized Municipal Securities Information Repository and with any state information depository with which filings are required to be made. Pursuant to the above requirements, the Agency has agreed to provide in a timely manner information concerning any of the following events with respect to the Series 1998 Bonds: principal and interest payment delinquencies; non-payment related defaults; unscheduled draws on the Debt Service Reserve Account reflecting financial difficulties; unscheduled draws on credit enhancements reflecting financial difficulties; substitution of credit or liquidity providers, or their failure to perform; adverse tax opinions or events affecting the tax-exempt status of the Series 1998B Bonds; modifications to rights of Holders or beneficial owners; bond calls; defeasances; release, substitution, or sale of property securing repayment of the Bonds; and rating changes. The Agency has also agreed to provide in the Annual Report the following information with respect to the prior Fiscal Year: information appearing in the Official Statement in the table under the caption "ESTIMATED DEBT SERVICE COVERAGE" and in the table entitled "Miami Beach Redevelopment Agency Historical Taxable Real Property and Tax Increment Revenues City Center Historic Convention Village," the release of the pledge of Supplemental Revenues and issuance of additional debt payable from the Pledged Funds. The City has agreed to provide in the Annual Report the following information with respect to the prior Fiscal Year: Resort Tax revenues and Supplemental Revenues, issuance of additional debt payable from the Resort Tax revenues or Supplemental Revenues and changes in the Resort Tax with respect to the percentage rate imposed or the exemptions therefrom. For a more complete description of the obligations of the Agency and the City regarding continuing disclosure, see "APPENDIX D - Continuing Disclosure Agreement." These covenants have been made in order to assist the Underwriters in complying with S.E.C. Rule 15c2-12(b)(5). Miscellaneous The references, excerpts and summaries of all documents, resolutions and ordinances referenced herein do not purport to be completc statemcnts of the provisions of such documents, resolutions and ordinances, and reference is directed to all such documents, resolutions and ordinances for full and complete statements of all matters of fact relating to the Series 1998 Bonds, the security for and the repayment of the Series 1998 Bonds and the rights and obligations of the holders thereof. By: Is/Neisen Kasdin Chairman MIAMI BEACH REDEVELOP 43 [This page intentionally left blank] APPENDIX A General Information Regarding the Miami Beach Redevelopment Agency, the City of Miami Beach and Miami-Dade County. Florida \. [This page intentionally left blank] GENERAL INFORMA nON REGARDING THE MIAMI BEACH REDEVELOPMENT AGENCY, THE CITY OF MIAMI BEACH AND MIAMI-DADE COUNTY, FLORIDA The following information pertaining to the Miami Beach Redevelopment Agency (the "Agency"), the City of Miami Beach, Horiua (the "City") anu Miami-Dade County, Florida (the "County") is set forth for purposes of background only. The Series 1998 Bonds are payable only from Net Trust Fund Revenues of the Agency which include payments by the County and the City into the Redevelopment Trust Fund, as described in this Official Statement, and Supplemental Revenues of the City. The Series 1998 Bonds do not constitute a debt, liability or obligation or a pledge of the faith, credit or taxing power of the City, County, the State of Florida, or any political subdivision thereof. INTRODUCTION The Miami Beach Redevelopment Agency is a Special District established by the City of Miami Beach for the purpose of promoting redevelopment in the designated area of the City covered in the redevelopment plan. The Agency currently has two such areas under its jurisdiction. The first area, which is not related to the Series 1998 Bonds and the tax increment revenues of which are not pledged to the Series 1998 Bonds, is the South Pointe Redevelopment Area consisting of all of the area in the City south of Sixth Street. The second area, for which the Series 1998 Bonds are being issued and to which the revenues of the district are pledged, is the City Center/Historic Convention Village Redevelopment and Revitalization Area. This redevelopment area consists of fifty-five blocks bounded on the south by Fourteenth Lane, on the north by Twenty-fourth Street, on the east by the Atlantic Ocean and on the west by West Avenue. Within the second area significant redevelopment has occurred with renovations to the Ritz Plaza Hotel, the Delano Hotel, the Raleigh Hotel and the National Hotel. Three construction projects are close to completion. These projects are the II Villaggio Condominium project consisting of 127 units on fourteen floors, the Michael Graves/Constructa project consisting of residential and mixed retail use and the Loews Miami Beach Hotel which will consist of approximately 800 rooms and serve as a he~dquarters hotel for the Convention Center. In addition, the Royal Palm Crowne Plaza, a 420-room convention hotel adjacent to the Loews is scheduled to break ground in mid-July. The City comprises seven square miles of land area and ten square miles of Biscayne Bay. The climate is tropical with an average annual temperature of 75 degrees fahrenheit, 24 degrees celsius. The City is the home of the Art Deco Historic District, consisting of one of the greatest concentrations of this style of architecture in the United States. Within this Historic District is the world famous Ocean Drive, which has been called the "Riviera" of Florida. The economy of the area is based on tourism. For fiscal year 1997, room rents, food and beverage sales accounted for an estimated $621 million in sales within the City. The population demographics of the City have drasticaIly changed over the last fifteen years. In the 1980 Census, the average age of the population was 65.3 years old. In the 1990 Census the average age had declined to 44.5 and 2000 estimates place it at 43.7 years old. The City is a group of islands between Biscayne Bay and the Atlantic Ocean and is connected to the mainland by four causeways. The County is the largest county in the southeastern United States in terms of population and one of the largest in terms of land area. The County consists of 2,042 square miles of land area. The population is clustered mainly along the coast, with the western area of the County comprising a part of the Everglades. There are numerous incorporated municipalities in the County, which include Miami, Hialeah and Coral Gables, as well as the City. POPULA TION The U.S. Bureau of the Census estimated the population of the City at 91,848 as of January 1, 1996. According to estimates of the City's Department of Economic and Community Development, the population is expected to increase to 95,881 by the year 2000 based on Census information. The County's population, as estimated by the Miami-Dade County Planning Department, was 2,057,000 for 1996 and the COllllty estimates growth (0 2,2(iO,OOO hy 2000. [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] 2 Population Projection, City of Miami Beach and Miami-Dade County 1970 - 2010 City of Percent Miami-Dade Percent Year Miami Beach Change !drnnU: Chanl:e 1970 87,072 (I) 1,267,800 (I) 1980 96,298 (I) 10.6% 1,625,598 (I) 28.2% 1990 92,639 (I) (3.8)% 1,937,094 (1) 19.2% 2000 95,881 (2) 3.5% 2,260,000 (3) 16.7% 2010 98,757 (2) 3.0% 2,557,000 (3) 13.1 % Source: (1) U. S. Census (2) City Department of Economic Development (3) Miami-Dade Planning Department Population Breakdown by Age, City of Miami Beach, 1980 - 2000 Age Group 1980 1990 2000 00-14 6.5% 12.0% 20.6% 15-24 7.2% 9.8% 8.2% 25-44 13.7% 28,8% 21.5% 45-64 22.0% 19.3% 23.2% 65-74 24.4% 11.5% 10.4% 75+ 26.2% 18.6% 16.2% Median Age: 65.3 44.5 " 43.7 Source: Miami-Dade Countv Plannina Deoartment 3 GOVERNMENT The Miami Beach Redevelopment Agency is governed by a seven member Board of Directors. The Chairman of the Board is the Mayor of the City and the other six members of the Board are the elected Commissioners of the City. The Board appoints the Executive Director and the General Counsel of the Agency who are respectively the City Manager and the City Attorney. The Board establishes policies which are carried out by the Administration of the Agency. The City of Miami Beach is organized under the Commission-City Manager form of government. The governing body is an elected City Commission of six members and an elected Mayor. The City Commission sets policy for the administration of the City and appoints a City Manager and a City Attorney. The City Attorney appoints his staff and the City Manager is responsible for the appointment of the balance of the employees of the City. The City Commissioners are elected to staggered four year terms and the Mayor is elected every two years. Both the City Attorney and the City Manager serve at the pleasure of the City Commission. The City Manager carries out the policies of the City Commission, directs the operations of the City and, with the exception of the City Attorney's Office, has the power to appoint or remove all heads of the various Departments. CERTAIN AGENCY AND CITY STAFF MEMBERS Sergio Rodriguez, City Manager Appointed City Manager on January 4. 1998; Appointed Deputy City Manager August 1995; Assistant City Manager, City of Miami, 1987-1995; Chief Planner, The Maryland- National Capital Park and Planning Commission, Prince George's County, Maryland. Education: University of Florida, B.A.; University of North Carolina at Chapel Hill, M.A. Harry Mavl'ogenes, Asst. Agency Director and Asst. City Manager Appointed Assistant City Manager in 1993; Director of Development, Design and Historic Preservation, 1990-1993: Downtown Plan Coordinator, San Jose Redevelopment Agency, 1985- 1990: Principal Planner, San Jose Redevelopment Agency, 1980-1985: Senior Planner and Planner, City of San Jose Planning Department, 1971-1980. Education: San Francisco State University, B.A., Urban Studies MaYI'a Diaz-Buttacavoli, Asst. City Manager Appointed Assistant City Manager in 1993; Fiscal Management Bureau Commander, Corrections and Rehabilitation, Miami-Dade County, Florida, 1991-1993; Director of Administrative Services Division, General Services Administration, Miami-Dade County, 1987-1989; Assistant to the Director, General Services Administration, Miami-Dade County, Florida, 1984-1987. Education: University of Miami, B.S., Accounting; University of Miami, M.S. 4 Patricia D. Walker, City Finance Director Appointed Finance Director, City of Miami Beach in March 1997; Director of Airports, Broward County, Florida, 1994-1997; Deputy Director, Broward County Aviation Department 1992-1994, Director of Finance, 1992, Executive Assistant to the Aviation Director, 1991-1992; Comptroller, Dade County Aviation Department, 1980-1990, Chief Accountant, 1978-1980; Senior Accountant, Price Waterhouse & Co., 1973-1978. Education: Florida State University, B.S., Accounting; Florida International University, M.S.M., Accounting Certification: Certified Public Accountant, Florida 1974 SCOPE OF SERVICES The services provided by the Agency include the elimination of the conditions of slum and blight within its redevelopment areas, and are limited in scope and established pursuant to Florida law. The City provides a full range of municipal services, including police, fire, parks, water, sewer, sanitation and zoning through its twelve (12) departments. The total workforce has remained approximately 1,620 for the past several years; however, significant changes have occurred in the personnel assigned to various activities. ECONOMIC AND DEMOGRAPHIC DATA INCOME The mean family income for Miami Beach increased by almost 92 percent, from $23,324 in 1980 to $44,738 in 1990. This compares well to growth rates experienced by Miami-Dade County, which experienced a mean family growth rate of approximately 59 percent during the same period. In 1990, the mean family income for Miami Beach exceeded that of Miami-Dade County by 18 percent, while in 1980, they were almost even. MEAN FAMILY INCOMES 1980 - 1990 1980 1990 of,.' % CHANGE Miami Beach $23,324 $44,738 91.8% Miami-Dade $23,846 $37,903 58.9% County Source u. S. Bureau of the Census. 1980 and 1990 5 Per Capita Personal Income (Current Dollars) 1980 -1995 Miami-Dade County Florida United States Current Current Current Year Dollars % of U.S. Dollars % of U,S. Dollars 1980 9,541 100.5 9,245 94.4 9,494 1985 13,992 100.6 13,898 99.9 13,910 1990 17,823 95.3 18,539 99.2 18,696 1991 18,252 95.6 18,985 99.4 19,091 1992 17,340 86.2 19,797 98.5 20,105 1993 19,779 95.1 20,828 100.1 20,800 1994 20,362 93.8 21,767 100.3 21,696 1995 21 ,058 90.8 23,031 99.3 23,196 Source: Florida Statistical Abstract 1997, University Press of Florida and Miami Business Profile 96-97; Beacon Council, 1997 EMPLOYMENT City of Miami Belich Employment 1991-1996 1991 1992 1993 1994 1995 199~ Labor Force Employed 38,618 38,355 39,600 40,150 40,070 40,108 Labor Force Unemployed 4,415 5,040 3,917 4,112 3,443 3,710 Total Labor Force 43,033 43,395 43,517 44,262 43,513 43,818 Unemployment Rate 10.3% 11.6% 9.0% 9.3% 7.9% 8.5% Source: Florida Department of Labor [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] 6 Major Employers on Miami Beach Rank EmDloyer Service Number Employed 1 Mount Sinai Medical Center Hospital 3,300 2 Clfy' of Miami tieacn Government 1.620 3 Fountainbleu Hilton Hotel 1,200 4 Miami Heart Institute Hospital 1,200 5 South Shore Hospital Hospital 742 6 Eden Roc Resort & Spa Hotel 415 7 Doral on the Beach Hotel 350 8 Ramada Resort Deauville Hotel 250 9 Alexander Hotel Hotel 230 10 Shawnee Beach Resort Hotel 140 Source: Personnel Divisions of ComDanies Ten Largest Public and Private Employers Located in Miami-Dade County Public Employers Private EmDloyers Dade County Public Schools 33,658 American Airlines 9,000 . Metropolitan Dade County 28,000 University of Miami 7,574 State of Florida 17,700 BellSouth Telecommunications 5,000 Federal Government 17,600 Florida Power & light 3,400 Jackson Memorial Hospital 7,216 Burdines Department Stores 3,400 City of Miami 3,189 Baptist Health Systems of Florida 3,275 Florida International University 2,775 Mount Sinai Medical Center 3,228 Miami-Dade Community College 2,668 Kmart 3,000 Veterans Affairs Medical Center 2,610 Publix Supermarkets, Inc. 3,000 City of Miami Beach 1,620 Winn-Dixie Stores, Inc. 2,672 , Source: The Beacon Council Miami Business Profile 1997. 7 BUILDING PERMITS The following is a calculation of the total value of the Building Permits issued by the City during the past 10 years. City of Miami Beach, Florida Value of Building Permits Issued Calendar Years 1988 - 1998 New Additions, Year Construction Rehabilitations. Etc. Total Value 1988 17,835,490 36,334,701 54,170,191 1989 55,422,320 51,804,525 107,226,845 1990 62,594,905 34,366,872 96,961,777 1991 32,863,120 40,545,996 73,409,116 1992 9,544,515 40,398,741 49,943,256 1993 150,549,661 81,156,235 231,705,896 1994 91,566,442 68,358,627 159,925,069 1995 147,712,100 56,564,305 204,276,405 1996 137,664,400 60,538,264 198,202,264 1997 96,643,651 82,576,295 179,219,946 1998* 16,263,500 53.710.187 69,973,687 Source: City of Miami Beach Building Department, 1997 . Four months through April 1998. [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] 8 DIRECT AND OVERLAPPING TAX RATES The following table summarizes the direct and overlapping tax (millage) rates for the past ten years. The Florida Constitution and statutes provide that the maximum millage (tax rate) that municipalities, counties and school districts in Florida may each levy, without a referendum, is $10.00 per $1,000 of assessed valuation (10 mills). As shown in the following table, the City has reduced its tax rates over the past to years. City of Miami Beach, Florida Direct and Overlapping Tax Rates ($1 per $1,000 of Assessed Value) For Tax Years 1988 Through 1997 Debt Tax General Service City School Year(1) Fund Funds Total District Countv Other Total 1988 9.966 3.705 13.671 7.551 8.965 0.564 30.751 1989 9.966 3.705 13.671 7.693 8.213 0.587 30.164 1990 9.966 3.705 13.671 9.001 7.368 0.602 30,642 1991 9.966 3.200 13.166 9.104 7.368 0.600 30.238 1992 9.743 2.200 11.943 9.528 8.795 0.599 30.865 1993 9.302 2.545 11.847 9.923 9.236 0.648 31.654 1994 8.238 2.311 10.549 10.266 9.202 0.652 30.669 1995 7.143 2.039 9.182 10.345 9.214 0.696 29.437 1996 7.499 1.862 9.361 10.389 7.946 0.687 28.383 1997 7.499 1.879 9.378 1 0.366 7.582 0.710 28.036 Source: City of Miami Beach, Comprehensive Annual Financial Report 1997; City of Miami Beach; Adopted Budget 1996/97 Fiscal Year; Miami.Dade County Tax Collector (1 ) Assessments as of January 1 of the year listed; bills mailed in October of that year; taxes become delinquent at the end of April of the subsequent year, 9 City of Miami Beach, Florida Property Tax Levies and Collections Fiscal Years 1987 - 1996 Assessed Valuation (1) Tax Including Excluding Total Total Coli Percent Year (2) Homesteads Homesteads Tax Levy in Year (3) Collected 1987 $3,617,648,031 $3,009,079,061 $41,137,120 $41,100,410 99.9 1988 3,786,641,043 3,105,045,655 42,449,079 41,266,273 97.2 1989 3,939,311,340 3,269,628,413 44,699,090 43,872,953 98.1 1990 4,376,417,088 3,632,426,183 47,824,523 46,497,571 97.2 1991 4,654,936,873 3,863,597,605 46,142,946 45,196,736 97.9 1992 4,726,911,403 3,932,985,608 45,610,535 46,102,609 101.1 1993 5,354,688,618 4,444,391,552 45,477,364 45,933,970 101,0 1994 6,369,445,913 5,286,640,108 47,359,133 46,885,783 99.0 1995 6,713,103,433 5,639,006,884 51,698,797 51,834,737 100.3 1996 7,161,079,764 6,015,307,002 54,155,090 55,496,245 102.4 Source: City of Miami Beach, Comprehensive Annual Financial Report (FY 1997) (1) Assessments are at 100% of fair market value. (2) Assessments as of January 1 of the year listed; bills mailed in October of that year; taxes become delinquent at the end of April of the subsequent year. (3) Actual collections of current and delinquent Real and Personal Property Taxes. [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] 10 City of Miami Beach Ten Largest Taxpayers 1997 Owner Type of ProDerty Assessed Value Hotelerama Assoc., Ltd. Hotel $88,051,861 Roney Plaza Assoc., Ltd. Apartments 46,500,000 Richard and Alan Morton Towers Apartments 40,085,375 Portofino Real Estate Fund Offices 36,548,585 IHC/Miami Beach Corp.. Hotel 30,000,000 Tri-County Community Hospital Health Care 25,800,000 5600 Collins Corp. Apartments 21,370,790 Suncoast Towers South Assoc. Apartments 18,800,000 Forte Towers South Inc. Apartments 17,000,000 South Gate Towers Apartments 15.000.000 $339.156.611 Source: Miami.Dade County; Department of Property Appraisal; City of Miami Beach Valuation Roll, 1997 FILM AND PRINT INDUSTRY The film and print industry has become an important part of the Miami Beach economy. This industry spends approximately $58.4 million a year in the City for the production of movies and fashion photographs (Source: 1997 City of Miami Beach Film and Print Industry Statistics). Many international talent and model agencies have located in the City. [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] II Film and Print Industry Permits Issued and Production Budgets For the Calendar Years 1990 -1997 Fiscal Permits Production Year Issued Budaets 1990 1281 $57,111,250 1991 1604 43,570,250 1992 1901 49,547,200 1993 1871 59,119,950 1994 1827 52,363,600 1995 1939 58,512,750 1996 1900 59,961,610 1997 1936 58.449,200 Source: City of Miami Beach. Office of Film and Print 1997 CONVENTION AND MEETING ACTIVITY Miami-Dade County and the Miami Beach Convention Center host a large number of conventions each year. Miami-Dade County Convention Activity for the Ten Years ended December 31,1996 Number of Number of Number of Total Year Conventions Deleqates Room Niqhts Expenditures 1987 425 475,000 1,176,000 $285,000,000 1988 475 546,000 1,380,000 368,400,000 1989 515 600,000 1,500,000 405,300,000 1990 525 650,000 1,750,000 439,000,000 1991 500 620,000 1,674,000 428,000,000 1992 525 680,000 1,850,000 469,404,000 1993 550 704,000 1,970,000 485,971,200 1994 616 857,578 2,401,218 600,304,600 1995 660 929,603 2,597,288 958,210,800 1996 N/A 1,445,825 3 036 232 1 ,463 174 900 Source: Greater Miami Convention and Visitor's Bureau 12 TOURISM AND VISITOR ACTIVITY DOMESTIC AND INTERNATIONAL OVERNIGHT VISITORS TO GREATER MIAMI AND THE BEACHES, 1994 -1996 Origin 1994 1995 1996 Caribbean 900,600 844,800 746,900 Central America 719,800 464,200 396,100 South America 1.937.400 1.948.400 1.969.200 Total Latin 3,557,800 3,257.400 3,112.200 America Europe: England 201,200 244,400 264,000 Germany 158,200 373,400 398,700 Other Europe 579.700 521.300 617.300 Total Europe 939,100 1,139,100 1,280,000 Canada 406,200 501,300 593,100 Other International 125.600 163.800 127.800 ~ Tota/lnternational 5,028,700 5,061,600 5,113,100 Total Domestic 3.728.600 4.317.600 4.462.000 Total Overnight 8.757.300 9,379.200 9.575.100 Expenditures: Domestic $2,513,470,000 $3,291,134,000 $4,300,000.000 International 4.402.705.000 5.078.716.000 6.600.000.000 , Total Expenditures $6.916.175.000 $8.369.850.000 $10.900.000.000 Source: Greater Miami Convention and Visitors Bureau, 1997; Miami Business Profile, 1997-98 Beacon Council 13 . ....,.........,....'_..n"....,....,.~._.,'" Overnight Visitors by Region 1994 1995 1996 Miami Beach 32.9% 32.3% 32.8% Downtown Miami 15.1% 15.3% 14.3% North Dade 18.4% 18.1% 13.7% Airport Area 17.3% 14.4% 18.3% South Dade 8.7% 10.8% 10.8% Grove/Gables/Key Biscayne 6.2% 8.2% 10.1% Other 1.4% 0.9% 0.0% Source: Greater Miami Convention and Visitors Bureau TRANSPORTATION The City is located within two hours by air from the major population centers of the northeastern United States and is also at the terminus of a highway network. The Port of Miami has become the world's largest passenger port. The Port estimates that more than 80 % of these cruise ship passengers arrive and depart Miami by air. The Port specializes in trailer and container cargo. From 1988 to 1995, the total cargo handled increased from 2.6 million tons to over 5.8 million tons, an increase of 123%. The Port has become the', nation's leading port for exports to Latin America and the Caribbean. The summary of the growth in passengers and cargo for the previous ten years is presented below: [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] 14 PASSENGERS AND CARGO HANDLED BY PORT OF MIAMI 1988-1997 Year Ended Cruise Cargo September 30 Passengers (in tons) 1988 2,502,411 2,602,556 1989 3,100,055 3,206,417 1990 2,734,816 3,590,937 1991 2,928,532 3,882,284 1992 3,095,487 4,596,481 1993 3,157,130 5,198,292 1994 2,967,081 5,574,252 1995 2,974,703 5,840,815 1996 3,052,450 5,859,538 1997 3,191,885 6 735 388 Source: Miami.Dade County Florida Seaport Department; Port of Miami, 1997 Five separate airports owned and operated by Miami-Dade County are within easy reach of the City. Miami International Airport ranks 6th in the nation and 10th in the world in the number of passengers using its facilities. It ranks third in the nation and third in the world in the movements of domestic and international air cargo. In 1996 the airport served 33.5 million passengers and handled bver 1.8 million tons of cargo. Statistics from 1988- 1996 are presented below: [BALANCE OF PAGE INTENTIONALLY LEFT BLANK] (. 15 PASSENGERS AND CARGO HANDLED BY MIAMIINTERNA TIONAL AIRPORT 1988-1996 Year Ended Passengers Cargo September 30. (In Thousands) (in tons) 1988 24,210 773,599 1989 23,422 869,612 1990 25,294 945,773 1991 26,709 951,328 1992 26,125 1,073,429 1993 28,246 1,215,553 1994 29,351 1,402,979 1995 32,852 1,703,367 1996 33,504 1,885,232 Source: Miami-Dade Countv Aviation Deoartment Miami International Airoort RECREATION There are numerous parks and playgrounds in the City of Miami Beach. Each park provides different amenities, from tennis and boccia courts to swimming pools and tot lots, to Vita courses and barbecue pits. There are four Vita courses, two swimming pools, and numerous tennis courts, including the Holtz Tennis Stadium which houses championship, professional and amateur tournaments. Offshore, the Gulf stream provides a variety of game fish, while the Miami Beach Marina provides an abundance of space to house boats as well as direct access to the Atlantic Ocean and Gulf stream. The Marina is a private development on City-owned bay front land in the South Pointe area. Renovation has increased the number of boat slips to 388, making the Marina the largest in the area and a first class facility. In the north part of the City, the public can enjoy a leisurely sail in the quiet waters of Biscayne Bay from Miami Beach Sailport. The facility, though open to all ages, was specially designed to teach young adults the basic art of sailing on small prams. The City owns two championship golf courses and one Par 3 course'that are open to the public. The two championship courses, Bayshore and Normandy, offer a clubhouse complete with a restaurant, lounge and pro shop. 16 APPENDIX B THE RESOLUTION ~": [This page intentionally left blank] RESOLUTION NO. 150-94 A RESOLUTION OF THE MIAMI BEACH REDEVELOPMENT AGENCY AUTHORIZING THE ISSUANCE OP NOT MORE THAN $25,000,000 IN PRINCIPAL AMOUNT OF MIAMI BEACH REDEVELOPMENT AGENCY TAX INCREMENT REV- ENUE BONDS, SERIES 1993 (CITY CENTER/HISTORIC CONVENTION VILLAGE), FOR THE PURPOSE OF FINANCING THE ACQUISITION, CLEARING AND/OR REHABILITATION OF CERTAIN PROPERTY AND THE CONSTRUCTION OF CERTAIN PUBLIC IMPROVEMENTS; PLEDGING THE PLEDGED FUNDS TO THE PAYMENT OF SAID BONDS; PROVIDING FOR THE ISSUANCE OF ADDITIONAL BONDS ON A PARITY THEREWITH; PROVIDING FOR THE RIGHTS AND SECURITY OF ALL BONDS ISSUED PURSUANT TO THIS RESOLUTION; PROVIDING CERTAIN DETAILS OF THE SERIES 1993 BONDS; DELEGATING CERTAIN MATTERS IN CONNEC- TION WITH THE ISSUANCE OF THE SERIES 1993 BONDS TO THE CHAIRMAN OF THE AGENCY; APPROVING THE FORM AND EXECUTION OF THE BOND PURCHASE AGREEMENT FOR THE SERIES 1993 BONDS; APPROVING THE FORM OF THE PRELIMINARY OFFICIAL STATEMENT FOR THE SERIES 1993 BONDS AND AUTHORIZING EXECUTION OF THE FINAL OFFICIAL STATEMENT FOR THE SERIES 1993 BONDS; AUTHORIZING OFFICIALS OF THE AGENCY TO TAKE ALL NECESSARY ACTIONS IN CONNECTION WITH THE ISSUANCE OF THE SERIES 1993 BONDS; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the Miami Beach Redevelopment Agency (the "Agency"), a public body corporate and politic, has been duly created and established to transact business and exercise powers under and pursuant to the Florida Community Redevelopment Act, Chapter 163, Part III, Florida Statutes (together with other applicable pro. visions of law, the "Act"), including the issuance of revenue bonds, in order to achieve the purposes of redevelopment as set forth in the Act; WHEREAS. all the requirements of law have been complied with in the creation of the Agency, the adoption of a redevelopment plan (the "Redevelopment Plan") under the Act for that portion of the City of Miami Beach (the "City") described in the Redevelopment Plan and known as the "City Center/Historic Convention Village Redevelopment and Revitalization Area" (the "Redevelopment Area") and the creation and funding of the City Center/Historic Convention Village Redevelopment and Revitalization Trust Fund (the "Trust Fund") in accordance with the Act; WHEREAS, the Agency now desires to finance the acquisition, clearing and/or rehabilitation of certain property and the con. struction of certain public improvements in accordance with the Redevelopment Plan (the "Series 1993 Redevelopment Project") by issuing its Tax Increment Revenue Bonds, Series 1993 (City Center/ Historic Convention Village) (the "Series 1993 Bonds"); \ WHEREAS, the Agency also desires to set forth the provisions pursuant to which it may issue bonds on a parity with the Series 1993 Bonds and to make provision for the rights and security of the Holders of all bonds issued hereunder; and WHEREAS, the Board of Commissioners of the Agency (the "Commission") has determined that it is in the best interest of the Agency to delegate to the Chairman of the Agency the determination of various terms of the Series 1993 Bonds, the award of the Series 1993 Bonds, including execution of a bond purchase agreement for the Series 1993 Bonds, and all other actions necessary or desirable in connection with the issuance of the Series 1993 Bonds, subject to the limitations herein; and WHEREAS, for reasons more fully set forth herein, the Agency finds and determines it to be in the best interests of the Agency to authorize the sale of the Series 1993 Bonds on the basis of a negotiated sale rather than a public sale by competitive bid; NOW THEREFORE, BE IT DULY RESOLVED BY THE BOARD OF COMMIS- SIONERS OF THE MIAMI BEACH REDEVELOPMENT AGENCY: ARTICLE I DEFINITIONS, AUTHORITY AND FINDINGS; RESOLUTION CONSTITUTES A CONTRACT SECTION 101. DEFINITIONS. In addition to the terms defined elsewhere in this Resolution, as used in this Resolution, the following terms shall have the following meanings: "Accreted Value" shall mean, as of any date of computation with respect to any Capital Appreciation Bond, an amount equal to the principal amount of such Capital Appreciation Bond (the prin. cipal amount at its initial offering) plus the interest accrued on such Capital Appreciation Bond from the date of delivery to the original purchasers thereof to the Interest Payment Date next pre- ceding the date of computation or the date of computation if an Interest Payment Date, such interest to accrue at a rate not exceeding the legal rate as set forth in the resolution of the Commission providing for the issuance of such Bonds, compounded periodically, plus, with respect to payment upon redemption of the Capital Appreciation Bonds, if such date of computation shall not be an Interest Payment Date, a portion of the difference between the Accreted Value as of the immediately preceding Interest Payment Date (or the date of original issuance if the date of computation is prior to the first Interest Payment Date succeeding the date of original issuance) and the Accreted Value as of the immediately succeeding Interest Payment Date, calculated based on the assump. tion that Accreted Value accrues', in equal daily amounts on the basis of a year of twelve 3D-day months. "Act" shall mean the Florida Community Redevelopment Act, Chapter 163, Part III, Florida Statutes, as amended, and other applicable provisions of law. "Agency" shall mean the Miami Beach Redevelopment Agency, a body corporate and politic, created pursuant to the Act. "Amortization Requirements" shall mean such moneys required to be deposited in the Bond Redemption Account for the purpose of the mandatory redemption or payment at maturity of any Term Bonds, the specific amounts of such deposits to be determined by the Chairman in the Chairman's Certificate with respect to the Series 1993 Bonds and pursuant to any resolution authorizing any other Series of Bonds with respect to such other Series of Bonds. "Appreciated Value" shall mean (i) as of any date of compu- tation with respect to any Capital ApPl'eciation and Inc;ome Bond up to the Interest Commencement Date set forth in the resolution of the Commission providing for the issuance of such Bond, an amount equal to the principal amount of such Bond (the principal amount at its initial offering) plus the interest accrued on such Capital Appreciation and Income Bond from the date of delivery to the original purchasers thereof to the Interest Payment Date next preceding the date of computation or the date of computation if an Interest Payment Date, such interest to accrue at a rate not exceeding the legal rate as set forth in the resolution of the Commission providing for the issuance of such Bonds, compounded periodically, plus, with respect to the payment upon redemption of the Capital Appreciation and Income Bonds, if such date of computa- tion shall not be an Interest Payment Date, a portion of the difference between the Appreciated Value as of the immediately ."'\.rllu.\I....'."IIlIlHIU 2 preceding Interest Payment Date (or the date of original issuance if the date of computation is prior to the first Interest Payment Date succeeding the date of original issuance) and the Appreciated Value as of the immediately succeeding Interest Payment Date cal- culated based upon an assumption that Appreciated Value accrues in equal daily amounts on the basis of a year of twelve 30'day months and (ii) as of any date of computation on and after the Interest Commencement Date, the Appreciated Value on the Interest Commence. ment Date. "Average Annual Debt Service" shall mean, at any time and with respect to all of the Bonds or any particular Series of Bonds (as appropriate), the sum of the Debt Service Requirements for the then current and every succeeding Fiscal Year divided by the number of such Fiscal Years. "Bonds" shall mean the Series 1993 Bonds, authorized to be issued pursuant to this Resolution, together with any additional parity Bonds hereafter issued pursuant to this Resolution. "Bondholder", "Holder", "Holder of Bonds" or "Owner" or any similar term, shall mean any person, who shall be the registered owner of any Outstanding Bond or Bonds. "Capital Appreciation Bonds" shall mean any Bonds issued under this Resolution as to which interest is compounded periodically on each of the applicable periodic dates designated for compounding and payable in an amount equal to the then current Accreted Value only at the maturity, earlier redemption or other payment date therefor, all as so designated by subsequent proceedings of the Commission relating to the issuance thereof, and which may be either Serial Bonds or Term Bonds; "Capital Appreciation and Income Bonds" shall mean any Bonds issued under this Resolution as to which accruing interest is not paid prior to the Interest Commencement Date specified in the resolution authorizing such Bonds', and the Appreciated Value for such Bonds is compounded periodically on certain designated dates prior to the Interest Commencement Date for such Series of Capital Appreciation and Income Bonds, all as so designated by subs~quent proceedings of the Commission relating to the issuance thereof and' which may be either Serial Bonds or Term Bonds. "Chairman" shall mean the Chairman of the Agency or in the absence or disability of the Chairman, the Vice Chairman of the Agency or the officers succeeding to their principal functions. "Chairman's Certificate" shall mean the Certificate to be executed by the Chairman prior to or at the time of the execution of the Bond Purchase Agreement (as defined in Section 201 hereof) , which Certificate shall provide the details of the Series 1993 Bonds. "City" ~hall mean the City of Miami Beach, Florida. "Code" shall mean the Internal Revenue Code of 1986, as amended from time to time, and the regulations promulgated there- under and applicable regulations promulgated under the Internal Revenue Code of 1954, as amended. "Commission" shall mean the Board of Commissioners of the Agency. "County" shall mean Dade County, Florida. "Credit Facility" shall mean an irrevocable letter of credit, policy of municipal bond insurance, guaranty, purchase agreement, credit agreement or similar facility in which the entity providing such facility irrevocably agrees 'to provide funds to make payment of the principal of, premium, if any and interest on Bonds and 3 which entity is rated on the date of delivery of such facility, in the case of a policy of municipal bond insurance, in the highest rating categories of Moody's Investors Service, Inc. or any successors thereof and Standard & Poor's Corporation or any successors thereof and, in the case of any other such facility, in any of the two highest rating categories of Moody's Investors Service, Inc. or any successors thereof and Standard & Poor's Corporation or any successors thereof. "Debt Service Requirement" for any period, as applied to all of the Bonds or all of the Bonds of any Series las appropriate), shall mean the respective amounts which are needed to provide: la) for paying the interest on all Bonds or all Bonds of such Series (as appropriate) then Outstanding which is payable on each Interest Payment Date in such period, (b) for paying the principal of all Serial Bonds or all Serial Bonds of such Series (as appropriate) then Outstanding which is payable upon the maturity of such Serial Bonds in such period, and (c) the Amortization Requirements, if any, for all Term Bonds or the Term Bonds of such Series (as appropriate) for such period. The following rules shall apply in determining the amount of the Debt Service Requirement for any period: la) In the case of Extendible Maturity Bonds, the Bonds shall be deemed to mature on the later of the stated maturity date or the date to which such stated maturity date has been extended; lb) In the case of Capital Appreciation Bonds, the prin- cipal and interest portions of the Accreted Value of Capital Appreciation Bonds becoming due at maturity or by virtue of an Amortization Requirement shall be included in the calculations of accrued and unpaid Debt Service Requirements in the year in which said principal and interest portions are due and pay- able; (c) In the case of Capital Appreciation and Income Bonds, the principal and interest portions of the Appreciated Value of Capi tal Appreciation and Income Bonds shall be included in the calculations of accrued and unpaid Debt Service Requirements in the year in which said principal and interest portions are due and payable; (d) If all or a portion of the principal of (including, without limitation, Amortization Requirements) or interest on a Series of Bonds is payable from funds irrevocably set aside or deposited for such purpose, together with projected earn- ings thereon to the extent such earnings are projected to be from Permitted Investments which are rated, or the p~ovider of which Permi t ted Inves tments is rated, at the time of the investment of such funds therein, at least "Baa" by Moody's Investors Service, Inc. or any successors thereof and "BBB" by Standard & Poor's Corporation or any successors thereof, such principal or interest shall not be included in determining Debt Service Requirements if such funds and/or Permitted Investments will provide moneys which shall be sufficient to pay when due such principal or interest. law: "Defeasance Obligations" shall mean to the extent permitted by la) Direct general obligations of, or obligations the timely payment of the principal of and the interest on which is unconditionally guaranteed by, the United States of America; and (b) Evidences of indebtedness issued by the Bank for Cooperatives, Federal Home Loan Banks, Federal Home Loan Mortgage Corporation lincluding participation certificates), Federal Land Banks, Federal Financing Banks, or any other agency or instrumentality of the United States of America created by an act of Congress which is substantially similar to the foregoing in its legal relationship to the United States of America; provided that the obligations of such agency or instrumentality are unconditionally guaranteed by the United States of America or any other agency or instru- mentality of the United States of America; and Ie) Evidences of ownership of proportionate interests in future interest and principal payments on specified obliga- tions described in (a) above held by a bank or trust company as custodian, under which the owner of the investment is the real party in interest and has the right to proceed directly and individually against the obligor on the underlying obliga- tions described in (a) above, and which underlying obligations are not available to satisfy any claim of the custodian or any person claiming through the custodian or to whom the custodian may be obligated; and (d) Obligations described in Section 103(a) of the Code which do not permit redemption prior to maturity at the option of the obligor and provision for the payment of the principal of, premium, if any, and interest on which shall have been made by the irrevocable deposit with a bank or trust company acting as a trustee or escrow agent for the holders of such obligations, securities described in clauses (a) or (b) above, the maturing principal of and interest on which, when due and payable, will provide sufficient monies to pay when due the principal of, premium if any, and interest on such obliga- tions, and which securities described in clauses la) or (b) above are not available to satisfy any other claim, including any claim of the trustee or escrow agent or of any person claiming through the trustee' or escrow agent or to whom the trustee or escrow agent may be obligated, including in the event of the insolvency of the trustee or escrow agent or proceedings arising out of such insolvency. "Executive Director" shall mean the Executive Director of the Agency. "Extendible Maturity Bonds" shall mean Bonds the maturities of which, by their terms, may be extended by and at the option of the Agency. "Fiduciaries" shall mean the Paying Agent, the Registrar and the Trustee appointed and acting under this Resolution. "Fiscal Year" shall mean that period commencing on October 1, and continuing to and including the next succeeding September 30, or such other annual period as may be prescribed by law or "by the Agency in accordance with law. "Interest Commencement Date" shall mean, with respect to any particular Capital Appreciation and Income Bonds, the date speci- fied in the resolution providing for the issuance of such Bonds, (which date must be prior to the maturity date for such Bonds) after which interest accruing on such Bonds shall be payable semi-annually or otherwise on a periodic basis prior to maturity, with the first" such payment date being the applicable Interest Payment Date immediately succeeding such Interest Commencement Date. "Interest Payment Date" shall mean for each Series of Bonds such dates on which interest on the Bonds is payable on such Bonds that are Outstanding, as set forth in the proceedings of the Agency providing for the issuance of such Series of Bonds. '''''.''".''''''''','"11'11'''' 5 "Liquidity Facility" shall mean a letter of credit, line of credit, policy of municipal bond insurance, guaranty, purchase agreement or similar facility in which the entity providing such facility agrees to provide funds to pay the purchase price of Put Bonds upon their tender by the Holders of Put Bonds and which entity is rated on the date of delivery of such facility, in the case of a policy of municipal bond insurance, in the highest rating categories of Moody's Investors Service, Inc. or any successors thereof and Standard & Poor's Corporation or any successors thereof and, in the case of any other such facility, in any of the two highest rating categories of Moody's Investors Service, Inc. or any successors thereof and Standard & Poor's Corporation or any successors thereof. "Maximum Annual Debt Service" shall mean, at any time and with respect to all of the Bonds or any particular Series of the Bonds (as appropriate), the greatest Debt Service Requirement in the then current or any succeeding Fiscal Year. "Net Trust Fund Revenues" shall mean the Trust Fund Revenues after deducting $500,000 therefrom in each Fiscal Year for the payment of the Agency's current operating expenses relating to the Redevelopment Plan (not including Debt Service Requirements on the Bonds) . "Outstanding" when used with reference to the Bonds, shall mean, as of any date of determination, all Bonds theretofore authenti~ated and delivered except: (a) Bonds theretofore cancelled by the Registrar or delivered to the Registrar for cancellation; (b) Bonds which are deemed paid and no longer Out- standing as provided herein; (c) Bonds in lieu of which other Bonds have been issued pursuant to the provisions helfeof relating to Bonds destroyed, stolen or lost, unless evidence satisfactory to the Registrar has been received that any such Bond is held by a bona fide purchaser; and (d) For purposes of any consent or other action to be taken hereunder by the Holders of a specified percentage of principal amount of Bonds, Bonds held by or for the account of the Agency. "Paying Agent" shall mean any bank or trust company or any successor bank or trust company appointed by the Agency to act as Paying Agent hereunder. "Permitted Investments" shall mean and include such obliga- tions as shall be permitted to be legal investments of the Agency by the laws of the State. "Pledged Funds" shall mean, collectively, (i) the Net Trust Fund Revenues, (ii) for so long as the City is obligated to transfer Supplemental Revenues to the Trustee for deposit under Section 304 (D) of this Resolution pursuant to the Supplemental Revenues Resolution, the Supplemental Revenues received by the Trustee, and (iii) except for moneys, securities and instruments in the Rebate Fund, all moneys, securities and instruments held in the Funds and Accounts created and established by this Resolution. "Put Bonds" shall mean the Bonds which by their terms may be tendered by and at the option of the owner thereof for payment by the Agency prior to the stated maturity thereof. "Purchasers" shall mean Clayton Brown & Associates, Inc., Morgan Stanley & Co. Incorporated and AIBC Investment Services Corporation. .""'.lllr_" 1....' I . ~\ft, Ie, I._ 6 "Redevelopment Area" shall mean the "City Center/Historic Convention Village Redevelopment and Revitalization Area" located within the City and found by the City to be a "blighted area" within the meaning of the Act and described in the Redevelopment Plan, as the geographic boundaries of such area may be changed from time to time as permitted under the Act. "Redevelopment Plan" shall mean the redevelopment plan for the Redevelopment Area adopted by the Agency by Resolution No. 128-93 adopted on February 12, 1993 and approved by the City by Resolution No. 93-20721 adopted on February 12, 1993 and by the County by Resolution.No. 317-93 adopted on March 30, 1993, as the same may be amended from time to time. ' "Redevelopment Projects" shall mean the particular community redevelopment projects undertaken by the Agency pursuant to the Redevelopment Plan within the Redevelopment Area in accordance with the Act, including the Series 1993 Redevelopment Project. "Registrar" shall mean the officer of the Agency or a bank or trust company appointed by the Agency, located within or without the State of Florida, who or which shall maintain the registration books of the Agency and be responsible for the transfer and exchange of the Bonds, and who or which may also be the Paying Agent and the Trustee for the Bonds. "Reserve Account Insurance Policy" shall mean the insurance policy, surety bond or other acceptable evidence of insurance, if any, deposited in the Debt Service Reserve Account in lieu of or in partial substitution for cash or securities on deposit therein. The issuer providing such insurance shall be a municipal bond insurer rated, at the time of deposit in the Debt Service Reserve Account, in the highest rating categories of Moody's Investors Service, Inc. or any successors thereof and Standard Poor's Corpo- ration or any successors thereof. "Reserve Account Letter of Credit" shall mean the irrevocable, transferable letter of credit, if any, deposited in the Debt Service Reserve Account in lieu of or in partial substitution for cash or securities on deposit therein. The issuer providing such letter of credit shall be a banking association, bank or trus& company or branch thereof rated, at the time of deposit into the Debt Service Reserve Account, in any of the two highest rating categories of Moody's Investors Service, Inc. or any successors thereof and Standard Poor's Corporation or any successors thereof. "Reserve Account Requirement" shall mean the lesser of (i) Maximum Annual Debt Service on all Bonds Outstanding, (ii) 125% of Average Annual Debt Service on all Bonds Outstanding, or (iii) 10% of the proceeds of the Bonds within the meaning of the Code. "Reaolution" shall mean this Resolution as the same may from time to time be amended and supplemented in accordance with the terms hereof. "Resort Tax" shall mean the municipal resort tax imposed, levied and collected by the City pursuant to Chapter 67-930, Laws of Florida, Acts of 1967, as amended, Chapter 166, Florida Statutes, as amended, the City Charter, as amended, and Chapter 41, Article V of the City Code, as amended. Tax. "Resort Tax Revenues" shall mean the proceeds of the Resort "Serial Bonds" shall mean the Bonds of any Series which shall be stated to mature in annual installments but not including Term Bonds. "Series" shall mean all of the Bonds authenticated and delivered on original issuance and pursuant to this Resolution or 7 any supplemental resolution authorizing such Bonds as a separate Series of Bonds, or any Bonds thereafter authenticated and deliv- ered in lieu of or in substitution for such Bonds pursuant to Article II hereof, regardless of variations in maturity, interest rate or other provisions. "Series 1993 Bonds" shall mean the Tax Increment Revenue Bonds, Series 1993 (City Center/Historic Convention Village), authorized to be issued under this Resolution in the aggregate principal amount not to exceed $25,000,000. "Series 1993 Redevelopment Project" shall mean the acquisi- tion, clearing and/or rehabilitation of certain property and the constructicn of certain public improvements within the Redevelop- ment Area being financed with the proceeds of the Series 1993 Bonds. 'State" shall mean the State of Florida. 'Supplementa1 Revenues" shall mean the portion of the Resort Tax Revenues pledged by the City for the benefit of the Holders of the Bonds under the provisions of the Supplemental Revenues Resolu- tion. "Supplemental Revenues Bonds" shall mean any and all bonds issued by the City or other obligations incurred by the City (other than the payment obligations under Section 5 of the Supplemental Revenues Resolution), from time to time, which are payable from, and are secured by a pledge and lien upon, the Supplemental Revenues on a parity with the City's payment obligations under Section 5 of the Supplemental Revenues Resolution and the pledge and lien granted under Section 6 of the Supplemental Revenues Resolution. "Supplemental Revenues Resolution" shall mean the resolution adopted by the City on January 5, 1994 pledging the Supplemental Revenues for the benefit of the Holders of the Bonds. jj. "Term Bonds" shall mean the Bonds of any Series which shall be stated to mature on one date and for the amortization of which payments are required to be made into the Bond Redemption Account in the Sinking Fund. ";~f ; "Trust Fund" shall mean the City Center/Historic Convention Village Redevelopment and Revitalization Trust Fund established by Ordinance No. 93-2836 adopted by the City on February 24, 1993 and by Ordinance No. 93-28 enacted by the County on April 27, 1993 in accordance with the Act. "Trust Fund Revenues" shall mean the revenues derived from the Redevelopment Area and received by the Agency for deposit in the Trust Fund pursuant to Section 163.387, Florida Statutes, as amended, Ordinance No. 93-28 enacted by the County on April 27, 1993, as amended from time to time, and Ordinance No. 93-2836 adopted by the City on February 24, 1993, as amended from time to time. "Trustee" shall mean any bank or trust successor bank or trust company appointed by the Trustee hereunder, and which may also be the Registrar for the Bonds. company or any Agency to act as Paying Agent and Words importing singular number shall include the plural number in each case and vice versa, and words importing persons shall include firms and corporations. Words defined in Section 101 hereof that appear in this Resolution in lower case form shall have the meanings ascribed to them in the definitions in Section 101 unless the context shall otherwise indicate. The words "Bond", "Owner", "Holder" and "person" shall include the plural as well as the singular number unless the context shall otherwise indicate. ......,,,,."'...11 ~\"I'M'.. 8 The word "person" shall include corporations and associations, including public bodies, as well as natural persons, unless the context shall otherwise indicate. The word "Bond" or "Bonds" and the words "revenue bond" or "revenue bonds" shall mean any Bond or Bonds or all of the Bonds, as the case may be, issued under the provisions of this Resolution. The word "Resolution" shall include this Resolution and each resolution supplemental hereto. SECTION 102. AUTHORITY FOR THIS RESOLUTION. This resolution is adopted pursuant to the provisions of the Act. SECTION 103. and declared: FINDINGS. It is hereby ascertained, determined (a) That the Agency is authorized to receive, deposit and apply the Trust Fund Revenues and Supplemented Revenues pursuant to the Act. (b) It is necessary and desirable to issue the Series 1993 Bonds in order to finance the Series 1993 Redevelopment Project. (c) The principal of and interest on the Bonds and all required sinking fund, reserve and other payments shall be payable solely from the Pledged Funds. None of the City, the County, or the State of Florida or any political subdivision thereof or governmental authority or body therein shall ever be required to levy ad valorem taxes to pay the principal of or interest on the Bonds or to make any of the sinking fund, reserve or other payments required by this Resolution or the Bonds, and the Bonds shall not constitute indebtedness of the Agency, the City, the County, the State or any political subdivision thereof within the meaning of any constitutional, statutory or other provision or limitation or a lien upon any property owned by or situated within the corporate territory of the Agency or the City, except as provided herein with respect to the Pledged Funds~ (d) Due to the character of the Series 1993 Bonds, the complexity of structuring an issue of bonds secured by the Trust Fund Revenues, prevailing market conditions, and the recommendation of the financial advisor to the Agency that the sale of the Series 1993 Bonds be by negotiation, the sale of the Series 1993 Bonds on the basis of negotiated sale rather than a public sale by competitive bid is in the best interest of the Agency and is hereby authorized. SECTION 104. RESOLUTION CONSTITUTES CONTRACT. In conside- ration of the acceptance of the Bonds authorized to be issued hereunder by those who shall own the same from time to time, this Resolution shall be deemed to be and shall constitute a contract between the Agency and such Bondholders, and the covenants and agreements herein set forth to be performed by the Agency shall be for the equal benefit, protection and security of the owners of any and all of such Bonds, all of which shall be of equal rank and without preference, priority, or distinction pf any of the Bonds over any other thereof except as expressly provided therein and herein. [END OF ARTICLE I] 9 ARTICLE II AUTHORIZATION, TERMS, EXECUTION AND REGISTRATION OF BONDS SECTION 201. AUTHORIZATION OF THE SERIES 1993 BONDS. Sub- ject and pursuant to the provisions of this Resolution, Bonds of the Agency to be known as Tax Increment Revenue Bonds, Series 1993 (City Center/Historic Convention Village) lthe "Series 1993 Bonds"), are hereby authorized to be issued in an aggregate principal amount not to exceed Twenty Five Million Dollars ($25,000,000), [or the purpose of providing funds, together with certain other available moneys, to finance the Series 1993 Redevel- opment proj ect, to fund the Debt Service Reserve Account and to pay costs of issuance of the Series 1993 Bonds, which Bonds may be issued all at one time or from time to time in Series, and if in Series, may be dated, numbered, and designated as to Series, all as shall be determined in the Chairman's Certificate. The financing of the Series 1993 Redevelopment Project and its acquisition is hereby authorized. Subject to the limitations contained herein, the Series 1993 Bonds shall be issued in such aggregate amount, shall be dated, shall mature on such dates and in such years, but not later than December 31, 2022, and in such amounts, shall be in the form of Serial Bonds or Term Bonds or a combination thereof, shall have such Interest Payment Dates in each year, shall bear interest at such rates not to exceed 8%, shall have such Amortization Require- ments, if any, and shall be subject to redemption at such times and at such prices, all as shall be set forth in the Chairman's Certificate. The Commission hereby appoints First Union National Bank of Florida, Miami, Florida, as Trustee, Registrar and Paying Agent hereunder. The Commission hereby approve5 the distribution of copies of the Preliminary Official Statement with respect to the Series 1993 Bonds (the "Preliminary Official Statement") in substantially the form presented at this meeting with such changes as may be approved by the Chairman. The Chairman or his designee is hereby authorized to deem the Preliminary Official Statement "final" for purposes of Securities and Exchange Commission Rule 15c2-12 and to execute any certificates in connection with such finding. The Chairman and the Executive Director or his designee, are hereby authorized to execute the Official Statement with respect to the Series 1993 Bonds (the "Official Statement") on behalf of the Agency, in substantially the form of the draft of the Preliminary Official Statement presented at this meeting with such changes therein as shall be necessary to evidence the terms of the Series 1993 Bonds and such additional changes as may be approved by the Chairman, with such execution to constitute conclusive evidence of such officer's approval and the Agency's approval of any change therein. The use of the Preliminary Official Statement and the final Official Statement in the marketing and sale of the Series 1993 Bonds is hereby approved. The Commission hereby approves the form of the Bond'Purchase Agreement (the "Bond Purchase Agreement") for the purchase of the Series 1993 Bonds by the Purchasers, a copy of which draft form of Bond Purchase Agreement has been presented at this meeting. In connection with the sale of the Series 1993 Bonds, the Chairman is hereby authorized to execute the Bond Purchase Agreement, upon compliance by the Purchasers with any and all requirements of Florida Statutes, Section 218.385(4), in substantially the form presented at this meeting, subject to such changes, insertions and omissions and such filling-in of blanks therein as may be necessary to evidence the terms of the Series 1993 Bonds and such additional changes as may be approved by the Chairman. The purchase price at which the Series 1993 Bonds shall be awarded to the Purchasers 10 shall be determined by the Chairman in consultation with the financial advisor of the City and Agency but shall not be less than 98% of the principal amount of the Series 1993 Bonds (not including original issue discount). The execution and delivery by the Chairman of the Bond Purchase Agreement for and on behalf of the Agency shall be conclusive evidence of the approval of such officer and the Agency of any such changes, insertions, omissions or filling-in of blanks. SECTION 202. DESCRIPTION OF BONDS. Unless otherwise speci- f ied by the Agency in subsequent proceedings, any Bonds issued pursuant to this Resolution shall be issued in fully registered form and, if the Registrar issues notice of the availability of exchanging registered Bonds for coupon Bonds, in coupon form. If the Registrar receives an opinion of counsel of recognized standing in the field of law relating to municipal bonds to the effect that the issuance of any of the Bonds in coupon form will not adversely affect the exclusion from gross income for Federal income tax purposes of the interest on any of the Bonds, the Registrar may, at the written direction of the Agency, mail notice to the registered owners of the Bonds of the availability of exchanging registered Bonds for coupon Bonds. Registered Bonds may then be exchanged for an equal aggregate principal amount of coupon Bonds of the same Series and maturity of any authorized denomination and coupon Bonds may be exchanged for an equal aggregate principal amount in the manner provided in this Resolution. Unless otherwise specified by the Agency in subsequent pro- ceedings, the Bonds of a Series shall be dated as determined in a Chairman's Certificate as to the Series 1993 Bonds and pursuant to subsequent resolution of the Agency as to the issuance of any other Series of Bonds; shall be payable in any coin or currency of the United States of America that is legal tender at the time of such payment; shall bear interest from their date at a fixed rate not exceeding the legal rate per annum, with interest paid to the registered Holder thereof on each Interest Payment Date by the Paying Agent at the address shown ~n the registration books of trre Agency (held by the Registrar) at the close of business on the 15th day of the calendar month preceding an Interest Payment Date or any other date with respect to any Series of Bonds as may be dete~ined pursuant to subsequent resolution of the Agency lin each case a "Regular Record Date"), except for Ii) Capital Appreciation Bonds which shall bear interest as described under the defined term Accreted Value, payable only upon redemption or maturity thereof and Iii) Capital Appreciation and Income Bonds which shall bear interest as described under the defined term Appreciated Value, payable on the amount due at maturity but only from and after the Interest Commencement Date; shall be lettered and shall be numbered in such manner as determined in a Chairman's Certificate as to the Series 1993 Bonds and pursuant to subsequent resolution of the Agency relating to the issuance of any other Seri~s of Bonds; shall be in denominations of $5,000 or any integral multiples thereof as to the Series 1993 Bonds and as determined pursuant to subsequent resolution of the Agency relating to the issuance of any other Series of Bonds; and shall mature on such dates, in such years and in such amounts, as determined in a Chairman's Certificate as to the Series 1993 Bonds and as provided fo~pursuant to subsequent resolution of the Agency relating to any other Series of Bonds. Notwithstanding anything in this paragraph to the contrary, any interest not punctually paid on an Interest Payment Date shall forthwith cease to be payable to the registered Holder on the Regular Record Date and may be paid to the registered Holder as of the close of business on a special record date for the payment of such defaulted interest to be fixed by the Paying Agent, notice of which shall be given not less than 10 days prior to such special record date to the registered Holders. The principal of and redemption premium, if any, on the Bonds shall be payable upon presentation and surrender at the principal 11 office of the Paying Agent. Interest on the Bonds shall be paid by check or draft drawn upon the Paying Agent and mailed to the registered owners of the Bonds on each Interest Payment Date; provided, however, that (i) if ownership of Bonds is maintained in a book-entry only system by a securities depository, such payment may be made by automatic funds transfer to the securities depository or its nominee or (ii) if such Bonds are not maintained in a book-entry only system by a securities depository, upon written request of the Holder of $1,000,000 or more in principal amount of Bonds, such payments may be made by wire transfer to the bank and bank account specified in writing by such Holder (such bank being a bank within the continental United States), if such Holder has advanced to the Paying Agent the amount necessary to pay the cost of such wire transfer or authorized the Paying Agent to deduct the cost of such wire transfer from the payment due to such Holder. The Bonds issued hereunder may be Serial Bonds or Term Bonds and may be Capital Appreciation Bonds, Capital Appreciation and Income Bonds, Extendible Maturity Bonds, Put Bonds and such other types of bonds as may be marketable from time to time, including, without limitation, taxable Bonds and Bonds issued in book entry form, as determined hereunder or by subsequent proceedings of the Agency. SECTION 203. REDEMPTION PROVISIONS. The Bonds of each Series, other than the Series 1993 Bonds, may be subj ect to redemption prior to maturity at such times, at such redemption prices and upon such terms in addition to the terms contained in this Resolution as may be determined pursuant to subsequent resolutions of the Agency, which subsequent resolutions may contain different redemption notice provisions than those contained in this Resolution. The redemption provisions for the Series 1993 Bonds shall be established in the manner described in the second para- graph of Section 201 of this Resolution. Notice of redemption for Bon~s being redeemed shall be given by deposit in the U. S. mails of a copy of a redemption notice, postage prepaid, at least thirty (30) and not more than sixty (60) days before the redemption date to all registered owners of the Bonds or portions of the Bonds to be redeemed at their addresses as they appear on the registration books to be maintained in accord- ance with the provisions hereof. Failure to mail any such notice to a registered owner of a Bond, or any defect therein, shall not affect the validity of the proceedings for redemption of any Bond or portion thereof with respect to which no failure or defect occurred. Such notice shall set forth the date fixed for redemp- tion, the rate of interest borne by each Bond being redeemed, the date of publication, if any, of a notice of redemption, the name and address of the Registrar and Paying Agent, the redemption price to be paid and, if less than all of the Bonds then outstanding shall be called for redemption, the distinctive numbers and letters, including CUSIP numbers, if any, of such Bonds to be redeemed and, in the case of Bonds to be redeemed in part only, the portion of the principal amount thereof to be redeemed. If any Bond is to be redeemed in part only, the notice of redemption which relates to such Bond shall also state that on or after the'redemp- tion date, upon surrender of such Bond, a new Bond or Bonds in a principal amount equal to the unredeemed portion of such Bond will be issued. Any notice mailed as provided in this section shall be conclusively presumed to have been duly given, whether or not the owner of such Bond receives such notice. In addition to the redemption notice described above, the Agency shall give notice of redemption for Bonds being redeemed to registered securities depositories and to national information services that disseminate redemption notices at least 2 business days in advance of the notice mailed to Holders of Bonds by sending notice to depositories such as Depository Trust Company of New York, New York, Midwest Securities Trust Company of Chicago, 12 1 Illinois, Pacific Securities Depository Trust Company of San Francisco, California, and Philadelphia Depository Trust Company of Philaaelphia, Pennsylvania and to national information services such as Financial Information Inc.'s Daily Called Bond Service, Interactive Data Corporation's Bond Service, Kenny Information Service's Called Bond Service, Moody's Municipal and Government News Reports and Standard and Poor's Called Bond Record. In addition, the Paying Agent shall publish notice of redemp- tion one time in The Bond Buver of New York, New York or if the Paying Agent believes that such publication is impractical or unlikely to reach a substantial number of owners of the Bonds to be redeemed, in some other financial newspaper or journal which regu- larly carries notices of redemption of other obligations similar to the Bonds, such publication to be made at least 30 days prior to the date fixed for redemption. Notice having been given in the manner and under the condi- tions described in the second paragraph of this Section 203, the Bonds or portions of Bonds so called for redemption shall, on the redemption date designated in such notice, become and be due and payable at the redemption price provided for redemption for such Bonds or portions of Bonds on such date. On the date so designated for redemption, moneys for payment of the redemption price being held in separate accounts by the Paying Agent in trust for the registered owners of the Bonds or portions thereof to be redeemed, all as provided in this Resolution, interest on the Bonds or portions of Bonds so called for redemption shall cease to accrue, such Bonds and portions of Bonds shall cease to be entitled to any lien, benefit or security under this Resolution and shall be deemed paid hereunder, and the registered owners of such Bonds or portions of Bonds shall have no right in respect thereof except to receive payment of the redemption price thereof and to receive Bonds for any unredeemed portions of the Bonds. Notwithstanding the foregoing, notice of redemption in connection with an optional redemption of Bonds shall not be given by the Agency unless on the date of giving of such notice of redemption the Agency has on deposit with the Paying Agent sufficient moneys to provide for such redemption. SECTION 204. EXECUTION OF BONDS. The Bonds shall be exe- cuted in the name of the Agency by the Chairman, and the seal of the Agency or a facsimile thereof shall be affixed thereto or imprinted or reproduced thereon and attested by the Executive Director, either manually or with their facsimile signatures. In case anyone or more of the officers who shall have signed or sealed any of the Bonds shall cease to be such officer before the Bonds so signed and sealed shall have been actually sold an delivered, such Bonds may nevertheless be sold and delivered as herein provided and may be issued as if the person who signed and sealed such Bonds had not ceased to hold such office. Any Bond may be signed and sealed on behalf of the Agency by such peTs on as at the actual time of the execution of such Bond shall hold the proper office, although at the date of such Bonds such person may not have held such office or may not have been so authorized. \" The Bonds of each Series shall bear thereon a certificate of authentication, in the form set forth in Exhibit A hereto, executed manually by the Registrar. Only such Bonds as shall bear thereon such certificate of authentication shall be entitled to any right or benefit under this Resolution and no Bond shall be valid or obligatory for any purpose until such certificate of authentication shall have been duly executed by the Registrar. Such certificate of the Registrar upon any Bond executed on behalf of the Agency shall be conclusive evidence that the Bond so authenticated has been duly authenticated and delivered under this Resolution and that the Holder thereof is entitled to the benefits of this Resolution. If the Bonds of a Series have been validated, the validation certificate on each of the Bonds of such Series shall be 13 signed with the facsimile signatures of the present or any future Chairman, and the Agency may adopt and use for that purpose the facsimile signature of any person who shall have been such Chairman at any time on or after the date of the Bonds, notwithstanding that he may have ceased to be such Chairman at the time when said Bonds shall be actually delivered. SECTION 205. NEGOTIABILITY, REGISTRATION AND CANCELLATION. At the option of the registered Holder thereof and upon surrender thereof at the principal corporate trust office of the Registrar with a written instrument of transfer satisfactory to the Registrar duly executed by the registered Holder or his duly authorized attorney and upon payment by such Holder of any charges which the Registrar or the Agency may make as provided in this Section, the Bonds may be exchanged for Bonds of the same aggregate principal amount of the same Series and maturity of any other authorized denominations. The Registrar shall keep books for the registration of Bonds and for the registration of transfers of Bonds. The Bonds shall be transferable by the Holder thereof in person or by his attorney duly authorized in writing only upon the books of the Agency kept by the Registrar and only upon surrender thereof together with a written instrument of transfer satisfactory to the Registrar duly executed by the Holder or his duly authorized attorney. Upon the transfer of any such Bond, the Agency shall cause to be issued in the name of the transferee a new Bond or Bonds. The Agency, the Trustee, the Paying Agent and the Registrar may deem and treat the person in whose name any Bond shall be registered upon the books kept by the Registrar as the absolute Holder of such Bond, whether such' Bond shall be overdue or not, for the purpose of receiving payment of, or on account of, the prin- cipal of, premium, if any, and interest on such Bond as the same becomes due and for all other purposes. All such payments so made to any such Holder or upon his order shall be valid and effectual to satisfy and discharge the liabhlity upon such Bond to the extent of the sum or sums so paid, and neither the Agency, the Trustee, the Paying Agent nor the Registrar shall be affected by any notice to the contrary. In all cases in which the privilege of exchanging Bonds or transferring Bonds is exercised, the Agency shall execute and the Registrar shall authenticate and deliver Bonds in accordance with the provisions of this Resolution. All Bonds surrendered in any such exchanges or transfers shall forthwith be delivered to the Registrar and cancelled by the Registrar in the manner provided in this Section. There shall be no charge for any such exchange or transfer of Bonds, but the Agency or the Registrar may require the payment of a sum sufficient to pay any tax, fee or other govern- mental charge required to be paid with respect to such exchange or transfer. Neither the Agency nor the Registrar shall be required (a) to transfer or exchange Bonds of any Series for a period of 15 days next preceding any selection of Bonds of such Series to be redeemed or thereafter until after the mailing of any notice of redemption; or lb) to transfer or exchange any Bonds of pny Series called for redemption. ", Except as may otherwise be provided with respect to Put Bonds in the proceedings of the Agency providing for the issuance there- of, all Bonds paid or redeemed, either at or before maturity shall be delivered to the Trustee when such payment or redemption is made, and such Bonds, together with all Bonds purchased by the Agency, shall thereupon be promptly cancelled. Bonds so cancelled may at any time be destroyed by the Trustee, who shall execute a certification of destruction in duplicate by the signature of one of its authorized officers describing the Bonds so destroyed, and one executed certificate shall be filed with the Agency and the other executed certificate shall be retained by the Trustee. 14 SECTION 206. BONDS MUTILATED, DESTROYED, STOLEN OR LOST. In case any Bond shall become mutilated, destroyed, stolen or lost, the Agency may execute and the Registrar shall authenticate and deliver a new Bond of like Series, date, maturity, denomination and interest rate as the Bond so mutilated, destroyed, stolen or lost; provided that, in the case of any mutilated Bond, such mutilated Bond shall first be surrendered to the Agency and, in the case of any lost, stolen or destroyed Bond, there shall first be furnished to the Agency and the Registrar evidence of such loss, theft, or destruction satisfactory to the Agency and the Registrar, together with indemnity satisfactory to them. In the event any such Bond shall be about to mature or have matured or have been called for redemption, instead of issuing a duplicate Bond, the Agency may direct the Paying Agent to pay the same without surrender thereof. The Agency and Registrar may charge the Holder of such Bonds their reasonable fees and expenses in connection with this transaction. Any Bond surrendered for replacement shall be cancelled in the same manner as provided in Section 205 hereof. Any such duplicate Bonds issued pursuant to this Section shall constitute additional contractual obligations on the part of the Agency, whether or not the lost, stolen or destroyed Bonds be at any time found by anyone, and such duplicate Bonds shall be entitled to equal and proportionate benefits and rights as to lien on and source and security for payment .from the Pledged Funds, with all other Bonds issued hereunder. SECTION 207. PREPARATION OF DEFINITIVE BONDS; TEMPORARY BONDS. Unless otherwise speci f ied by the Agency in subsequent proceedings, the definitive Bonds of each Series shall be litho- graphed, printed or typewritten. Until the definitive Bonds are prepared, the Chairman and Executive Director may execute and the Registrar may authenticate, in the same manner as is provided in Section 204, and deliver, in lieu of definitive Bonds, but subject to the same provisions, limitations and conditions as the defini- tive Bonds, one. or more printed, lithographed or typewritten tempo- rary fully registered Bonds, sub~tantially of the tenor of the definitive Bonds in lieu of which such temporary Bond or Bonds are issued, in authorized denominations or any whole multiples thereof, and with such omissions, insertions and variations as may be appro- priate to such temporary Bonds. The Agency at its own expense shall prepare, execute and, upon the surrender at the corporate trust office of the Registrar of such temporary Bonds for which no payment or only partial payment has been provided, the Registrar shall authenticate and, without charge to the Holder thereof, deliver in exchange therefor, at the principal corporate trust office of the Registrar, definitive Bonds of the same aggregate principal amount, Series and maturity as the temporary Bonds sur- rendered. Until so exchanged, the temporary Bonds shall in all respects be entitled to the same benefits and security as defini- tive Bonds issued pursuant to this Resolution. SECTION 208. FORM OF BONDS. The text of the Bonds shall be of the tenor set forth in Exhibit A to this Resolution, with such omissions, insertions and variations as may be necessary and desirable and authorized or permitted by this Resolution or a Chairman's Certificate. ' SECTION 209. BOOK-ENTRY ONLY SYSTEM FOR THE BONDS; QUALIFI- CATION FOR THE DEPOSITORY TRUST COMPANY. The Bonds may be issued as uncertificated securities through the book-entry only system maintained by The Depository Trust Company of New York ("DTC") or such other securities depository as may be selected by the Agency. The Agency, the Trustee, the Registrar and the Paying Agent are hereby authorized to take such actions as may be necessary to qualify the Bonds for deposit with DTC, including but not limited to those actions as may be set forth in a letter agreement (the "DTC Agreement") to be entered into by and among the Agency, the Fiduciaries and DTC, the execution and delivery of which with respect to the Series 1993 Bonds by the Chairman or Executive 15 Director of the Agency is hereby authorized, wire transfers of interest and principal payments with respect to the Bonds, utiliz- ation of electronic book entry data received from DTC in place of actual delivery of Bonds and provisions of notices with respect to Bonds registered by DTC (or any of its designees identified to the Agency, the Trustee, the Registrar or the Paying Agent) by over- night delivery, courier service, telegram, telecopy or other similar means of communication. [END OF ARTICLE II] " ''''''''''.''11''"..""""" l6 ARTICLE III COVENANTS, FUNDS AND APPLICATION THEREOF SECTION 301. BONDS NOT TO BE INDEBTEDNESS OF THE AGENCY OR THE CITY. The Bonds shall not be and shall not constitute an indebtedness of the Agency, the City, the County, the State or any political subdivision thereof, within the meaning of any consti- tutional, statutory or charter provisions or limitations, or a pledge of the faith and credit of the Agency, the City, the County, the State or any political subdivision thereof, but shall be pay- able solely, as provided in this Resolution, from the Pledged Funds. No Holder or Holders of any Bonds issued hereunder shall ever have the right to compel the exercise of the ad valorem taxing power of the City, the County, the State or any pOlitical subdi- vision thereof or taxation in any form of any real or personal property therein, or the application of any funds of the Agency or the City, the County, the State or any political subdivision thereof to pay the Bonds or the interest thereon or the making of any sinking fund or reserve payments provided for herein other than the Pledged Funds as provided in this Resolution. SECTION 302. BONDS SECURED BY PLEDGE OF PLEDGED FUNDS. The payment of the principal of, interest and premium, if any, on all of the Bonds issued hereunder and any additional parity Bonds hereafter issued, as provided herein, shall be secured forthwith equally and ratably by a first lien on and pledge of the Pledged Funds. The Pledged Funds in an amount sufficient to pay the principal of and interest on the Bonds herein authorized and to make the payments into the Sinking Fund (hereinafter created and established) and all other payments provided for in this Resolu- tion, as well as moneys held in'the funds and accounts created under this Resolution (other than the Rebate Fund), are hereby irrevocably pledged to the payment of the principal of and interest on the Bonds authorized herein, and other payments provided for herein, as the same become due and payable. Pursuant to the provi- sions of the Supplemental RevenueS Resolution and subject to the limitations and conditions therein contained, the City has pledged the Supplemental Revenues as security for the payment of the prin- cipal of and interest on the Bonds, such Supplemental Revenues being part of the Pledged Funds hereunder upon receipt of the same by the Trustee. The Bonds and the obligation evidenced thereby shall not con- stitute a lien upon any property owned by or situated within the corporate territory of the Agency or the City, but shall constitute a lien only on the Pledged Funds all in the manner provided in this Resolution. SECTION 303. APPLICATION OF BOND PROCEEDS; ACQUISITION AND CONSTRUCTION FUND. (a) All moneys received by the Agency from the sale of the Series 1993 Bonds issued pursuant to this Resolution, unless other- wise provided in the Chairman's Certificate shall be simultaneously disbursed as follows: " (1) Proceeds derived from the sale of the Series 1993 Bonds equal to the accrued interest on the Series 1993 Bonds shall be deposited in the Interest Account, hereinafter created and established, and used for the purpose of paying interest on the Series 1993 Bonds as the same becomes due and payable. (2) Proceeds derived from the sale of the Series 1993 Bonds, together with other moneys lawfully available therefor, if any, shall be deposited in a "Miami Beach Redevelopment Agency Cost of Issuance Fund (City Center/Historic Convention Village)" lhereinafter referred to as the "Cost of Issuance Fund") which is hereby created and established to be held by 17 the Agency and used for the purpose of paying such costs of issuance of the Series 1993 Bonds as the Agency shall deter- mine are appropriate. (3) Proceeds derived from the sale of the Series 1993 Bonds in an amount equal to the Reserve Account Requirement shall be deposited in the Debt Service Reserve Account, here- inafter created and established. (4) The balance of the proceeds derived from the sale of the Series 1993 Bonds, together with other moneys lawfully available therefor, if any, shall be deposited in an account designated "Series 1993 Account" of a special fund hereby created, established and designated as the "Miami Beach Redevelopment Agency Acquisition and Construction Fund lCity Center/Historic Convention Village)" (hereinafter referred to as the "Acquisition and Construction Fund") to be held and administered by the Trustee. Such proceeds and other avail- able moneys shall be applied by the Trustee as set forth in Section 303(c) below. (b) All moneys received by the Agency from the sale of any Series of Bonds, other than the Series 1993 Bonds, authorized and issued pursuant to this Resolution, unless otherwise provided by subsequent proceedings of the Agency authorizing such Series of Bonds, shall be simultaneously disbursed as follows: (1) The accrued interest, if any, derived from the sale of Bonds shall be deposited in the Interest Account and for the purpose of paying interest on the Bonds as the same becomes due and payable. (2) Proceeds derived from the sale of Bonds, together with other moneys lawfully available therefor, if any, shall be deposited in the Cost of Issuance Fund and used for the purpose of paying such costs of issuance of such Bonds as the Agency shall determine are appropriate. (3) Proceeds of the sale of such Bonds, together with other moneys lawfully available therefor, if any, shall be deposited in the Debt Service Reserve Account in an amount sufficient to make the amount in the Debt Service Reserve Account equal to the Reserve Account Requirement on the Bonds Outstanding under the Resolution; provided, however, that the Agency may elect to fund any increase in the Reserve Account Requirement as a result of the sale of the Bonds by the deposit of a Reserve Account Insurance Policy or Reserve Account Letter of Credit as provided in Section 304(D) hereof. (4) The balance of the proceeds derived from the sale of such Bonds, other than Bonds issued to refund Outstanding Bonds, together with other moneys lawfully available therefor, if any, shall be deposited in an account of the Acquisition and Construction Fund designated with the Series of Bonds applicable thereto. Such proceeds and other available moneys shall be applied by the Trustee as set forth in Section 303(c) below. (5) The balance of the proceeds derived from the sale of such Bonds issued to refund Outstanding Bonds shall be applied to provide for the refunding of such Outstanding Bonds to be refunded in accordance with a resolution adopted by the Commission prior to the issuance of such Bonds. (c) Proceeds and other moneys on deposit in the Acquisition and Construction Fund shall be disbursed by the Trustee in accor- dance with the provisions of this subsection (c). Withdrawals may be made by the Agency from the Acquisition and Construction Fund upon receipt by the Trustee of a written requisition executed by a duly authorized official of the Agency, specifying the purpose for ,...,.,.".\\'....f.S\"""".. 18 which such withdrawal is to be made, including reimbursement to the Agency or the City for funds advanced by them, as applicable, in connection with a Redevelopment Project, and certifying that such purpose is included within the scope of the Redevelopment Project for which the applicable Series of Bonds was issued. In addition, (i) in the case of the Series 1993 Bonds, an authorized official of the Agency shall deliver to the Trustee with each such requisition a certificate in the form of Exhibit B, attached hereto and made a part hereof and (ii) in the case of any other Series of Bonds, an authorized official of the Agency shall deliver to the Trustee with each such requisition such other certificates, as may be provided for in a resolution of the Agency authorizing such Series of Bonds. If for any reason the moneys in the Acquisition and Construction Fund, or any part thereof including any investment earnings on deposit therein, are not necessary for, or are not applied to the purposes provided for the applicable Series of Bonds, then such unapplied proceeds, upon certification of a duly authorized offi- cial of the Agency that such surplus proceeds are not needed for such purposes, shall be applied to the redemption or purchase or payment of principal of Outstanding Bonds. Moneys on deposit in the Acquisition and Construction Fund may be invested and reinvested at the direction of the Agency to the fullest extent practicable in Permitted Investments maturing not later than such date or dates on which such moneys shall be needed for the purposes of the Acquisition and Construction Fund. The earnings and investment income derived from the moneys and invest- ments on deposit in the Acquisition and Construction Fund shall be deposited and maintained in the applicable account within the Acquisition and Construction Fund and used for the purposes there- of. (d) The proceeds of the sale of the Bonds shall be and con- stitute trust funds for the purposes hereinabove provided and there is hereby created a lien upon such moneys, until so applied, in favor of the Holders of said Bonds. " SECTION 304,. COVENANTS OF THE AGENCY. The Agency hereby covenants and agrees with the Holders of any and all of the Bonds issued pursuant to this Resolution as follows: A. TAX COVENANTS. (1) The Agency will not take any action or omit to take any action, which action or omission, if reasonably expected on the date of initial issuance and delivery of the Bonds, would result in the failure to exclude interest on the Bonds from gross income for Federal income tax purposes under Section 103(a) of the Code. Par- ticularly, the Agency will not take any action or omit to take any action, which action or omission, if reasonably expected on the date of the initial issuance and delivery of the Bonds, would have caused any of the Bonds to be "arbitrage bonds" within the meaning of Section 148 of the Code. (2) The Agency shall comply with the arbitrage rebate covenants as provided in Section 304(E) hereof. B. REDEVELOPMENT PLAN. The Agency will carry out the pur- poses of the Redevelopment Plan within the Redevelopment Area all in accordance with the Act and will, take all such actions as are required to carry out the full intent of the Redevelopment Plan. C. TRUST FUND. As soon as the same are received by the Agency, all of the Trust Fund Revenues shall be forthwith deposited into the Trust Fund. The Trust Fund shall constitute a trust fund for the purposes provided in this Resolution, shall be held by the Agency and shall be maintained separate and distinct from all other funds of the Agency and used :only for the purposes and in the manner provided in this Resolution and the Act. 19 D. DISPOSITION OF TRUST FUND REVENUES; SUPPLEMENTAL REV- ENUES. There is hereby created and established a special fund designated the "Miami Beach Redevelopment Agency Sinking Fund (City Center/Historic Convention Village)" (hereinafter referred to as the "Sinking Fund"). There are also hereby created four (4) sep- arate accounts in the Sinking Fund to be known as the "Interest Account", the "Principal Account", the "Bond Redemption Account" and the "Debt Service Reserve Account". The Sinking Fund and the accounts therein shall be held and administered by the Trustee. In each Fiscal Year, the first $500,000 in Trust Fund Revenues deposited in the Trust Fund during such Fiscal Year shall be set aside and retained by the Agency for the payment of the Agency's current operating expenses relating to the Redevelopment Plan (not including Debt Service Requirements on the Bonds). Thereafter, all Net Trust Fund Revenues deposited in the Trust Fund during such Fiscal Year shall be disposed of by the Agency only in the following manner: (1) Net Trust Fund Revenues shall first be used, to the full extent required, for deposit with the Trustee into the Interest Account in the Sinking Fund, immediately upon receipt of such Net Trust Fund Revenues, of such sums as shall be sufficient to pay the interest becoming due on the Bonds during the current calendar year (or if such Net Trust Fund Revenues are deposited in the Trust Fund during the first quarter of such Fiscal Year, to pay the interest becoming due on the Bonds through the end of the next succeeding calendar year) ; provided, however, that such deposit for interest shall not be required to be made into the Interest Account to the extent that money on deposit therein is sufficient for such purpose. The Trustee shall, on each Interest Payment Date, trans- fer to the Paying Agent moneys in an amount equal to the interest due on such Interest Payment Date or shall advise the Paying Agent of the amount of any deficiency in the amount on deposit in the Interest Account so that the Paying Agent may give appropriate notice required to provide for the payment of such deficiency from any Reserve Account Insurance Policy or Reserve Account Letter of Credit on deposit in the Debt Service Reserve Account. (2) (a) Net Trust Fund Revenues shall next be used, to the full extent required, for deposit with the Trustee into the Principal Account in the Sinking Fund, immediately upon receipt of such Net Trust Fund Revenues, of such sums as shall be sufficient to pay the principal amount of Serial Bonds which will mature during the current calendar year lor if such Net Trust Revenues are deposited in the Trust Fund during the first quarter of such Fiscal Year, to pay the principal amount of Serial Bonds which will mature through the end of the next succeeding calendar year); provided, however, that such deposit for principal shall not be required to be made into the Principal Account to the extent that money ,on deposit therein is sufficient for such purpose. The Trustee shall, on the business day prior to each principal payment date, transfer to the Paying Agent moneys in an amount equal to the principal due on such principal payment date or shall advise the Paying Agent of the amount of any deficiency in the amount on deposit in the Principal Account so that the Paying Agent may give appropriate notice required to provide for the payment of such deficiency from any Reserve Account Insurance Policy or Reserve Account Letter of Credit on deposit in the Debt Service Reserve Account. (b) Net Trust Fund Revenues shall next be used, to the full extent required, for deposit with the Trustee into the Bond Redemption Account in the Sinking Fund, immediately 20 upon receipt of such Net Trust Fund Revenues, of such Amorti- zation Requirements as may be required for the payment of the Term Bonds payable from the Bond Redemption Account during the current calendar year (or if such Net Trust Fund Revenues are deposited in the Trust Fund during the first quarter of such Fiscal Year, for the payment of the Term Bonds payable from the Bond Redemption Account through the end of the next succeeding calendar year) . The moneys in the Bond Redemption Account shall be used solely for the purchase or redemption of. the Term Bonds payable therefrom. The Agency may at any time purchase any of said Term Bonds at prices not greater than the then redemption price of said Term Bonds. If the Term Bonds are not then redeemable, the Agency may purchase said Term Bonds at prices not greater than the redemption price of such Term Bonds on the next ensuing redemption date. The Agency shall be manda- torily obligated to use any moneys in the Bond Redemption Account for the redemption prior to maturity of such Term Bonds at such times as the same are subject to mandatory redemption. If, by the application of moneys in the Bond Redemption Account, however, the Agency shall purchase or call for redemption in any year Term Bonds in excess of the Amortization Requirements for such year, such excess of Term Bonds so purchased or redeemed shall be credited in such manner and at such times as the Executive Director shall determine over the remaining payment dates. (3) Net Trust Fund Revenues shall next be used, to the full extent required, for deposit with the Trustee into the Debt Service Reserve Account, immediately upon receipt of such Net Trust Fund Revenues, of the difference between the amount on deposit in the Debt Service Reserve Account (including any Reserve Account Insurance Policy or Reserve Account Letter of Credi t) and the Reserve Account Requirement for the Bonds Outstanding, and, provided, further, that no payments shall be required to be made into th€ Debt Service Reserve Account whenever and as long as the amount deposited therein (includ- ing any Reserve Account Insurance Policy or Reserve Account Letter of Credit) shall be equal to the Reserve Account Requirement for the Bonds Outstanding. Moneys in Debt Service Reserve Account shall be used only for the purpose of making payments of principal of and interest on the Bonds when the moneys in the Funds and Accounts held pursuant to this Resolution and available for such purpose are insufficient therefor. Any moneys in the Debt Service Reserve Account in excess of the Reserve Account Requirement for the Bonds Outstanding may, in the discretion of the Agency, be transferred to and deposited in the Interest Account, the Principal Account or the Bond Redemption Account as the Agency at its option may determine. Notwithstanding the foregoing provisions; in lieu of or in substitute for the required deposits (including existing deposits therein) into the Debt Service Reserve Account, the Agency may, wi th the consent of any issuer of any Credi t Facility in respect of the Bonds, cause to be deposited into the Debt Service Reserve Account a Reserve Account Insurance Policy or a Reserve Account Letter of Credit for the benefit of the Holders of the Bonds Outstanding, which Reserve Account Insurance Policy or Reserve Account Letter of Credit shall be payable or available to be drawn upon, as the case may be, (upon the giving of notice as required thereunder) on any Interest Payment Date on which a deficiency exists which cannot be cured by moneys in any other Fund or Account held pursuant to this Resolution and available for such purpose. If any such Reserve Account Insurance Policy or Reserve 21 Account Letter of Credit is substituted for moneys on deposit in the Debt Service Reserve Account, the excess moneys in the Debt Service Reserve Account shall be transferred to and deposited in the Interest Account, the Principal Account or the Bond Redemption Account as the Agency at its option may determine. If a disbursement is made under the Reserve Account Insurance Policy or the Reserve Account Letter of Credit, the Agency shall be obligated to either reinstate the maximum limits of such Reserve Account Insurance Policy or Reserve Account Letter of Credit following such disbursement or to deposit into the Debt Service Reserve Account from the Net Trust Fund Revenues, as herein provided, funds in the amount of the disbursements made under such Reserve Account Insurance Policy or Reserve Account Letter of Credit, or a combination of such alternatives as shall equal the Reserve Account Requirement for the Bonds Outstanding. In the event that upon the occurrence of any deficiency in the Interest Account, the Principal Account or the Bond Redemption Account, the Debt Service Reserve Account is then funded with one or more Reserve Account Insurance Policies and/or Reserve Account Letters of Credit, the Agency or the Paying Agent, as applicable, shall, on an interest or prin- cipal payment date or mandatory redemption date to which such deficiency relates, draw upon or cause to be paid under such facilities, on a pro-rata basis thereunder, an amount sufficient to remedy such deficiency, in accordance with the terms and provisions of such facilities and any corresponding reimbursement or other agreement governing such facilities; provided however, that if at the time of such deficiency the Debt Service Reserve Account is only partially funded with one or more Reserve Account Insurance Pol icies and/or Reserve Account Letters of Credit, prior to drawing on such facilities or causing payments to be made thereunder, the Trustee shall first apply any cash and securities on deposit in the Debt Service Reserve Account to remedy the deficiency and, if after such application a deficiency still exists, the Agency or the Paying Agent, as applicable, shall make up the balance of the deficiency by drawing on such facilities or causing payments to be made thereunder, as provided in this paragraph. Amounts drawn or paid under a Reserve Account Insurance Policy or Reserve Account Letter of Credit shall be applied as set forth in the second paragraph of this Section 304 (d) (3) . Any amounts drawn or paid under a Reserve Account Insurance Policy or Reserve Account Letter of Credit shall be reimbursed to the issuer thereof in accordance with the terms and provisions of the reimbursement or other agreement governing such facility. The Debt Service Reserve Account shall be valued on the first day in each Fiscal Year and the value of securities on deposit therein shall be the lower of par,. or if purchased at other than par, amortized value. Amortized value, when used with respect to securities purchased at a premium above or a discount below par, shall mean the value at any given date obtained by dividing the total premium or discount at which such securities were purchased by the number of interest payment dates remaining to maturity on such securities after such purchase and by multiplying the amount so calculated by the number of interest payment dates having passed since the date of purchase; and Ii) in the case of securities purchased at a premium, by deducting the product thus obtained from the purchase price, and (ii) in the case of securities purchased at a discount, by adding the product thus obtained to the purchase price. (4) Net Trust Fund Revenues shall next be used for the payment of any subordinated obligations hereafter issued by the Agency in accordance with Section 3041G) of this Resolu- tion, which subordinate obligations shall have such lien on the Net Trust Fund Revenues as the Agency shall determine in 22 the proceedings authorizing the issuance of such subordinated obligations. (5) Thereafter, the balance of any Net Trust Fund Reven- ues remaining in said Trust Fund shall, subject to Section 304(A), be used by the Agency for any lawful purposes, includ- ing payment of any fees and expenses of the Fiduciaries; pro- vided, however, that none of such Net Trust Fund Revenues shall ever be used for the purposes provided in this paragraph (5) unless all payments required in paragraphs (1) through (4) above, including any deficiencies for prior payments and any amounts due to the issuer of any Reserve Account Insurance Policy or Reserve Account Letter of Credit, have been made in full to the date of such use. If on the first (1st) day of February in each Fiscal Year the amounts on deposit in any of the accounts established in the Sinking Fund are less than the amounts required to be on deposit therein under clauses (1), (2) and (3) of this Section 304 (D) for the payment of interest on and principal (including Amortization Requirements) of the Bonds during the current calendar year and to cause the amounts on deposit in the Debt Service Reserve Account. to equal the Reserve Account Requirement, the Trustee shall immedi- ately notify the City of the deficiency in any of such accounts and the City shall be obligated, in accordance with the provisions of the Supplemental Revenues Resolution, to transfer to the Trustee for deposit in the applicable accounts in the Sinking Fund Supple- mental Revenues in an amount which, after all such required transfers are completed as provided under the Supplemental Revenues Resolution, shall be sufficient, together with the amounts then on deposit in each of the accounts in the Sinking Fund, to pay all interest and principal (including Amortization Requirements) payable on the Bonds during the then current calendar year, as the same is due and payable, and to fund such deficiency in the Debt Service Reserve Account by the last day of such calendar year. The Trustee shall, immediately upon receipt thereof, deposit the Supplemental Revenues in the app~icable accounts in the Sinking Fund and apply the same as provided in clauses (1), (2) and (3) of . this Section 304(D). Notwithstanding anything to the contrary contained in this Resolution, the City's obligation to transfer Supplemental Revenues to the Trustee pursuant to the Supplemental Revenues Resolution shall terminate and the pledge of and lien on the Supplemental Revenues hereunder and under the Supplemental Revenues Resolution shall be released and extinguished upon the happening of the following events and conditions: ( 1 ) the Net Trus t Fund Revenues (not incl uding any portion thereof which may be attributable to investment earnings) for each of the immediately preceding two Fiscal Years, as certified by a certified public accountant in a certificate delivered to the Trustee, shall have been at least equal to one hundred seventy-five percent (175\) of the Maximum Annual Debt Service on all Bonds then Outstanding; and (2) the Agency shall have cause~notice to the effect that the lien upon and pledge of the Supplemental Revenues to secure payment of the Bonds has been released and extinguished to be mailed to the Registered Owners of the Bonds, to each rating agency maintaining a rating on the Bonds and the issuer of any Credit Facility or Liquidity Facility. Notwithstanding anything in Section 3041D) (1) and (2) to the contrary, failure to make the scheduled payments specified therein shall not constitute a breach of the Agency's obligations under this Resolution so long as, on the date that any interest or prin- cipal payment is due on the Bonds, monies sufficient to make such payment are on deposit in the. Interest Account, Principal Account or the Bond Redemption Account, as the case may be. 23 Notwithstanding the foregoing or any other provision herein to the contrary, if any amount applied to the payment of principal of and premium, if any, and interest on the Bonds that would have been paid from an account in the Sinking Fund, is paid instead under a Credit Facility or a Liquidity Facility, amounts deposited in such relevant account may be paid, to the extent required, to the issuer of the Credit Facility or Liquidity Facility having therefore made said corresponding payment. E. REBATE FUND. There is hereby created and established the "Miami Beach Redevelopment Agency Rebate Fund (City Center/Historic Convention Village)" which fund shall be maintained with the Trustee separate and apart from all other funds and a~counts of the Trustee or the Agency. Notwithstanding anything in this Resolution to the contrary, the Agency shall transfer or cause to be trans- ferred from Pledged Funds the amounts required to be transferred in order to comply with the arbitrage rebate covenants contained in a certificate to be executed and delivered by the Agency in connec- tion with the issuance of each Series of Bonds. The Agency shall cause the Trustee to make payments from the Rebate Fund of amounts required to be deposited therein to the United States of America in the amounts and at the times required by such arbitrage rebate covenants. The Agency covenants for the benefit of the Bondholders that it will comply with the requirements of the arbitrage rebate covenants. There shall be excluded from the pledge and lien of this Resolution the Rebate Fund, together with all moneys and securities from time to time held therein and all investment earnings derived therefrom. The Agency shall not be required to comply with the requirements of this Section 304(E} in the event that the Agency obtains an opinion of nationally recognized bond counsel that (i) such compliance is not required in order to maintain the exclusion from gross income for Federal income tax purposes of interest on the Bonds and/or (ii) compliance with some other requirement is necessary to maintain the exclusion from gross income for Federal income tax purposes of interest on the Bonds. F. INVESTMENT OF FUNDS. The Trust Fund, the Sinking Fund, including the Interest Account, Principal Account, Bond Redemption Account and Debt Service Reserve Account and the Cost of Issuance Fund and all other special funds (other than the Rebate Fund) created and established by this Resolution shall constitute trust funds in favor of the Bondholders and shall be invested at the direction of the Agency as provided in this Section 304(F). Moneys on deposit in the Trust Fund, Interest Account, Prin- cipal Account, Bond Redemption Account and Cost of Issuance Fund may be invested at the direction of the Agency in Permitted Investments maturing not later than the dates on which such moneys will be needed for the purposes of such fund or account. Moneys on deposit in the Debt Service Reserve Account may be invested at the direction of the Agency in Permitted Investments maturing not later than the final maturity of any of the Bonds. All income and earnings received from the investment and reinvestment of moneys in the Interest Account, the Principal Account and the Bond Redemption Account in the Sinking Fund shall be retained in the respective accounts and applied as a credit against the obligation of the Agency to transfer moneys to such accounts pursuant to Section 304 (0) (1) and Section 304 (0) (2) (a) and Section 304 (D) (2) (b) of this Resolution, respectively, and the obligation of the City t6 transfer moneys to such accounts pursuant to the Supplemental Revenues Resolution. All income and earnings received from the investment and reinvestment of moneys in the Debt Service Reserve Account in the Sinking Fund shall be retained in the Debt Service Reserve Account and applied as a credit against the obligation of the Agency and the City to transfer moneys to such account, unless the amount in such account shall exceed the Reserve Account Requirement, in which 24 event such excess may be applied in the manner set forth for excess amounts in the Debt Service Reserve Account, as described in Section 304 (0) (3) . All income and earnings received from the investment and rein- vestment of moneys in the Cost of Issuance Fund shall be trans- ferred to the Trust Fund. For the purpose of investing or reinvesting, the Agency and the Trustee may commingle moneys in the funds and accounts created and established hereunder lother than the Rebate Fund) in order to achieve greater investment income; provided that the Agency and the Trustee shall separately account for the amounts so commingled. The amounts required to be accounted for in each of the funds and accounts designated herein (other than the Rebate Fund) may be deposited in a single bank account provided that adequa~e account- ing procedures are maintained to reflect and control the restricted allocations of the amounts on deposit therein for the various purposes of such funds and accounts as herein provided. G. ISSUANCE OF OTHER OBLIGATIONS PAYABLE OUT OF PLEDGED FUNDS. Except upon the conditions and in the manner provided herein, the Agency will not issue any other obligations payable from the Pledged Funds, nor voluntarily create or cause to be created any debt, lien, pledge, assignment, encumbrance or an other charge having priority to or being on a parity with the lien of the Bonds issued pursuant to this Resolution and the interest thereon, upon any of the Pledged Funds; provided that the Agency may enter into agreements with issuers of Credit Facilities and Liquidity Facilities which involve liens on Pledged Funds on a parity with that of the Series of Bonds or portion thereof which is supported by such Credit Facilities or Liquidity Facilities solely with respect to any reimbursement obligations due such issuers which evidence amounts equal to the scheduled stated principal (includ- ing, without limitation, Amortization Requirements) and interest due on the Series of Bonds or portion thereof which is supported by such Credit Facilities or Liquidity Facilities. Any other obliga- tions, in addition to the Bonds authorized by this Resolution or additional parity Bonds issued under the terms, restrictions and conditions contained in this Resolution and Obligations to issuers of Credit Facilities and Liquidity Facilities as described above, shall provide that such obligations are junior, inferior and subordinate in all respects to the Bonds issued pursuant to this Resolution as to lien on and source and security for payment from the Pledged Funds and in all other respects. Nothing in this Resolution shall be deemed to prohibit the Agency from entering into currency swaps or other arrangements for hedging interest rates on any indebtedness provided that, while either Moody's Investors Service, Inc. or Standard & Poor's Corporation, or their respective successors, shall maintain ratings on any of the Bonds, the Agency shall not enter into any such currency swaps or other arrangements with respect to Bonds without obtaining. the prior written consent of such rating agencies with respect thereto. Not- withstanding the foregoing, the City may issue bonds or incur other obligations payable from the Supplemental Revenues, including Sup- plemental Revenues Bonds, and create or cause to be created debts, liens, pledges, assignments, encumbrances and o~her charges upon the Supplemental Revenues to the extent provided in the Supple- mental Revenues Resolution. H. ISSUANCE OF ADDITIONAL PARITY BONDS. No additional parity Bonds, as in this subsection defined, payable on a parity with Bonds issued pursuant to this Resolution out of Pledged Funds, including, without limitation, Net Trust Fund Revenues, shall be issued after the issuance of any Bonds pursuant to this Resolution unless the following, among other conditions, are complied with: (1) The Agency must be current in all deposits into the various funds and accounts and all payments theretofore required to have been deposited or made by it under the provi- 25 sions of this Resolution and the Agency must be currently in compliance with the covenants and provisions of this Reso- lution and any supplemental resolution hereafter adopted for the issuance of additional parity Bonds; unless upon the issu- ance of such additional parity Bonds the Agency will be in compliance with all such covenants and provisions. (2) The aggregate of the Net Trust Fund Revenues lnot including any portion thereof which may be attributable to investment earnings) received by the Agency and the Supple- mental Revenues received by the City, each during the immedi- ately preceding Fiscal Year, as certified by an independent certified public accountant, were at least equal to one hundred seventy-five percent (175%) of the Maximum Annual Debt Service on (1) the Bonds originally issued pursuant to this Resolution and then Outstanding, (2) any additional parity Bonds theretofore issued and then Outstanding, (3) the additional parity Bonds then proposed to be issued, and (4) in accordance with the next succeeding paragraph, any Supple- mental Revenues Bonds issued and then Outstanding; provided, however, that upon the release of the lien and pledge of the Supplemental Revenues as provided by Section 304(0) herein, (A) the phrase "one hundred seventy- five percent (175%)" above will be replaced with the phrase "one hundred fifty percent (150%)" and (B) the foregoing calculations will (i) be based solely upon the Net Trust Fund Revenues and (ii) not include (4) above. (3) The Agency need not comply with subparagraph (2) of this paragraph in the issuance of additional parity Bonds if and to the extent the Bonds to be issued are refunding Bonds, that is, delivered in lieu nf or in substitution for Bonds originally issued under this Resolution or previously issued additional parity Bonds, if the Agency shall cause to be delivered to the Trustee a certificate of the Executive Director of the Agency setting forth Ii) the Maximum Annual Debt Service lA) with respec~ to the Bonds of all Series and, in accordance with the next succeeding paragraph, the Supple- mental Revenues Bonds, in each case Outstanding immediately prior to the date of authentication and delivery of such refunding Bonds, and (B) with respect to the Bonds of all Series and, in accordance with the next succeeding paragraph, the Supplemental Revenues Bonds, in each case to be Outstand- ing immediately thereafter, and (ii) that the Maximum Annual Debt Service set forth pursuant to (B) above is no greater than that set forth pursuant to (A) above; provided, however, that upon the release of the lien and pledge of the Supple- mental Revenues as provided in Section 304(D) herein, the foregoing calculations will not include the Supplemental Revenues Bonds. For purposes of subparagraphs (2) and (3) above, Supplemental Revenues Bonds shall be deemed "Outstanding" and shall be included in "Debt Service Requirement" and "Maximum Annual Debt Service" therein based upon the same rules applicable to Bonds hereunder. Simultaneously with the delivery of any Bonds issued pursuant to Sections (2) and (3) above for the purpose of refunding any Bonds issued under this Resolution, the Agency may withdraw from the Sinking Fund amounts theretofore deposited which are allocable to the Bonds being refunded and shall transfer said amounts in accordance with the resolution providing for the issuance of the refunding Bonds, provided that after such withdrawal the Agency shall be in compliance with the provisions of this Resolution. The term "additional parity Bonds" as used in this Resolution shall be deemed to mean additional obligations evidenced by Bonds issued upon the provisions and within the limitations of this subsection to finance Redevelopment Projects payable from the Pledged Funds on a parity with Bonds originally authorized and '''''~I'I.l\U.''I'.1,e'"''f.' 26 issued pursuant to this Resolution. Such Bonds shall be deemed to have been issued pursuant to this Resolution the same as the Bonds originally authorized and issued pursuant to this Resolution and all of the covenants and other provisions of this Resolution lexcept as to details of such Bonds evidencing such additional parity obligations inconsistent therewith), shall be for the equal benefit, protection and security of the Holders of any Bonds originally authorized and issued pursuant to this Resolution and the Holders of any Bonds evidencing additional obligations subsequently issued within the limitations of and in compliance with this subsection. All of such Bonds, regardless of the time or times of their issuance shall rank equally with respect to their lien on the Pledged Funds and their sources, and security for payment therefrom without preference of any Bonds over any other. The term "additional parity Bonds" as used in this Resolution shall not be deemed to include bonds, notes, certificates or other obligations subsequently issued in accordance with this Resolution, the lien of which on the Pledged Funds is subject to the prior and superior lien on the Pledged Funds of Bonds and the Agency shall not issue any obligations whatsoever payable from the Pledged Funds, which rank equally as to lien and source and security for their payment from such Pledged Funds with Bonds except in the manner and under the conditions provided in subsection (G) above and this subsection. I. BOOKS AND RECORDS. The Agency will keep separately identifiable accounting records for the receipt of the Trust Fund Revenues by the use of a fund established in accordance with gener- ally accepted accounting principles, and any Holder of a Bond or Bonds issued pursuant to this Resolution, shall have the right at all reasonable times to inspect all records, accounts and data of the Agency relating thereto. The Agency shall promptly after the close of each Fiscal Year cause the books, records and accounts relating to the Trust Fund Revenues for such Fiscal Year to be properly audited by a qualified, recognized and nationally known independent firm of certified public accountants and shall file the report of such certified public accountants in the office of the Executive Director, and shall mail upon request, and make available generally, said report, or a reasonable summary thereof, to any Holder or Holders of Bonds issued. pursuant to this Resolution. Such audited books, records and accounts shall contain the statements required by generally accepted accounting principles applicable to governmental entities, and a certificate of such certified public accountants disclosing any breach on the part of the Agency of any covenant herein. J. NO IMPAIRMENT OF CONTRACT. The Agency has full power and authority to irrevocably pledge the Pledged Funds to the payment of the principal of and interest on the Bonds. Except as provided in Section 304 (D) with respect to the Supplemental Revenues, the pledge of such Pledged Funds, in the manner provided herein, shall not be subject to repeal, modification or impairment by any sub- sequent resolution, ordinance or other proceedings of the Agency so long as any Bonds are Outstanding hereunder. T~e Agency shall take all actions necessary and pursue such legal remedies which may be available to it either in law or in equity to prevent or cure any impairment by any entity other than the Agency within the meaning of this subsection. K. REMEDIES. Any Holder of Bonds issued under the pro- visions of this Resolution or the Trustee acting for such Bond- holders, may either at law or in equity, by suit, action, mandamus or other proceedings in any court of competent jurisdiction, pro- tect and enforce any and all rights under the laws of the State or granted and contained in this Resolution, and may enforce and compel the performance of all duties required by this Resolution or 27 by any applicable statutes, including the Act, to be performed by the Agency or by any officer thereof. Nothing herein, however, shall be construed to grant any Holder of such Bonds any lien on any property of the Agency, except as provided herein. No Holder of Bonds, however, shall have any right in any manner whatever to affect adversely, or prejudice the security of this Resolution or to express any right hereunder except in the manner herein pro- vided, and all proceedings at law or in equity shall be instituted and maintained for the benefit of all Holders of Bonds. The Holder or Holders of Bonds in an aggregate principal amount of more than twenty-five per centum (25%) of Bonds issued under this Resolution then Outstanding may by a duly executed certificate in writing request the Trustee to represent such Bond- holders in any legal proceedings for the enforcement and protection of the rights of such Bondholders. Such certificate shall be executed by such Bondholders or their duly authorized attorneys or representatives, and shall be filed in the office of the Executive Director. L. ENFORCEMENT OF COLLECTIONS. The Agency will diligently enforce and collect the Trust Fund Revenues and take all actions within its control to cause the City to transfer Supplemental Revenues as required hereunder and under the Supplemental Revenues Resolution and will take all steps, actions and proceedings for the enforcement and collection of such Trust Fund Revenues and transfer of Supplemental Revenues to the full extent permitted or authorized by applicable laws, including the Act. All Net Trust Fund Revenues and Supplemental Revenues shall, as collected and transferred, respectively, be held in trust to be applied as herein provided and not otherwise. M. DISCHARGE AND SATISFACTION OF BONDS. The covenants, liens and pledges entered into, created or imposed pursuant to this Resolution may be fully discharged and satisfied with respect to all or a portion of the Bonds in anyone or more of the following ways: (1) by paying the principal of and interest on such Bonds when the same shall become due and payable; or (2) by depositing in the Interest Account, the Principal Account and the Bond Redemption Account and/or in such other accounts which are irrevocabiy pledged to the payment of Bonds as the Agency may hereafter create and establish by resolu- tion, certain moneys which together with other moneys lawfully available therefor, if any, shall be sufficient at the time of such deposit to pay when due the principal, redemption premium, if any, and interest due and to become due on said Bonds on or prior to the redemption date or maturity date thereof; or (3) by depositing in the Interest Account, the Principal Accost and the Bond Redemption Account and/or such other accounts which are irrevocably pledged to the payment of Bonds as the Agency may hereafter create and establish by resolu- tion, moneys which together with other moneys lawfully avail- able therefor when invested in such Defeasance Obligations which shall not be subject to redemption prior to their maturity other than at the option of the Holder thereof, will provide moneys which shall be sufficient to pay when due the principal, redemption premium, if any, and interest due and to become due on said Bonds on or prior to the redemption date or maturity date thereof. Upon such payment or deposit in the amount and manner provided in this Section 3041M), Bonds shall be deemed to be paid and shall no longer be deemed to be Outstanding for the purposes of this Resolution and all liability of the Agency with respect to said Bonds shall cease, terminate and be com- 28 pletely discharged and extinguished, and the Holders thereof shall be entitled for payment solely out of the moneys or securities so deposited; provided that (i) in connection with any discharge and satisfaction pursuant to subsection (2) or (3) above, the Agency shall concurrently with such deposit deliver (A) an opinion of nationally recognized bond counsel to the effect that interest on the Bonds being discharged will not, by reason of such discharge, become includable in gross income for federal income tax purposes and that such Bonds have been discharged in accordance with the provisions of this Section, and lB) an accountant's verification report showing the sufficiency of such moneys and/or Defeasance Obligations to provide for the payment of said Bonds, and (iil in the event said Bonds do not mature and are not to be redeemed within the next succeeding sixty (60) 'days, the Agency shall have given the Registrar irrevocable instructions to give, as soon as practicable, a notice to the Holders of said Bonds by first-class mail, postage prepaid, stating that the deposit of said moneys or Defeasance Obligations has been made with an appropriate fiduciary institution acting as escrow agent solely for the Holders of said Bond and other Bonds being defeased, and that said Bonds are deemed to have been paid in accordance with this Section and stating such maturity or redemption date upon which moneys are to be available for the payment of the principal of and premium, if any, and interest on said Bonds. (4) Notwithstanding any of the provisions of this Resolution to the contrary, Put Bonds and Extendible Maturity Bonds may only be fully discharged and satisfied either pursuant to subsection (1) above or by depositing in the Interest Account, the Principal Account and the Bond Redemp- tion Account, or in such other accounts which are irrevocably pledged to the payment of the Put Bonds or Extendible Maturity Bonds as the Agency may hereafter create and establish by resolution, moneys which together with moneys lawfully avail- able therefor, if any, shall be sufficient at the time of suc~ deposit to pay when due the maximum amount of principal of and' redemption premium, if any, and interest on such Put Bonds and Extendible Maturity Bonds which could become payable to the Holders of such Bonds upon the exercise of any options 'pro- vided to the Holders of such Bonds or the Agency; provided however, that if, at the time a deposit is made pursuant to this subsection (4), the options originally exercisable by the Holder of a Put Bond or Extendible Maturity Bond or the Agency are no longer exercisable, such Bond shall not be considered a Put Bond or Extendible Maturity Bond for purposes of this subsection (4). (5) Notwithstanding the foregoing, all references to the discharge and satisfaction of Bonds shall include the dis- charge and satisfaction of any issue of Bonds, any portion of an issue of Bonds, any maturity or maturities of an issue of Bonds, any portion of a maturity of an issue of Bonds or any combination thereof, provided that the provisions of this subsection (5) shall not affect the requirements regarding Put Bonds and Extendible Maturity Bonds set forth in subsection (4) . (6) If any portion of the moneys deposited for the pay- ment of the principal of and redemption premium, if any, and interest on any portion of Bonds is not required for such pur- pose, the Agency may use the amount of such excess free and clear of any trust, lien, security interest, pledge or assign- ment securing said Bonds or otherwise existing under this Resolution. In the event that the principal and redemption price, if applicable, and interest due on the Bonds shall be paid by the issuer of a Credit Facility or Liquidity Facility pursuant to 29 ._..IU.l\I....,J.".lf.".. the terms thereof, the assignment and pledge created hereunder and all covenants, agreements and other obligations of the Agency to the Bondholders shall continue to exist and the issuer of such Credit Facility or Liquidity Facility shall be subrogated to the rights of such Bondholders. N. CONCERNING THE RESERVE ACCOUNT INSURANCE POLICY, THE RESERVE ACCOUNT LETTER OF CREDIT, CREDIT FACILITY AND/OR LIQUIDITY FACILITY. As long as the Agency shall have a Reserve Account Insurance Policy and/or a Reserve Account Letter of Credit on deposit in the Debt Service Reserve Account, the Agency covenants that it will comply with the provisions of the Reserve Account Insurance Policy and/or Reserve Account Letter of Credit and any reimbursement or similar agreement with respect to any such Reserve Account Insurance Policy and/or Reserve Account Letter of Credit. As long as any Series of Bonds of the Agency are secured by a Credit Facility or Liquidity Facility, (i) the Agency covenants to comply with the requirements and conditions imposed on the Agency by the issuer of the Credit Facility or Liquidity Facility and (ii) all rights hereunder granted to the Holders of Bonds so secured shall be exercisable by the issuer of such Credit Facility or Liquidity Facility in lieu of the Holders of such Bonds. Notwithstanding anything in this Resolution to the contrary, the rights of any issuer of a Credit Facility or Liquidity Facility created under this Resolution shall remain in full force and effect only so long as the applicable Credit Facility or Liquidity Facility shall remain in effect and the issuer of such Credit Facility or Liquidity Facility shall not be in default in its payment obligations to the Holders of Bonds secured by such facility. [END OF ARTICLE III] '. 30 ARTICLE IV CONCERNING THE FIDUCIARIES SECTION 401. ADDITIONAL PAYING AGENTS, APPOINTMENT AND ACCEPTANCE OF DUTIES. The Agency may at any time or from time to time appoint one or more other Paying Agents having the quali- fications set forth in this Article IV for a successor Paying Agent; provided that nothing herein shall prevent the Agency from appointing itself as the Paying Agent hereunder. Each Paying Agent shall signify its acceptance of the duties and obligations imposed upon it by this Resolution by executing and delivering to the Agency a written acceptance thereof. SECTION 402. RESPONSIBILITIES OF FIDUCIARIES. The recitals of facts herein and in the Bonds contained shall be taken as the statements of the Agency and no Fiduciary assumes any responsi- bility for the correctness of the same. No Fiduciary makes any representation as to the validity or sufficiency of this Resolution or of any Bonds issued thereunder or as to the security afforded by this Resolution, and no Fiduciary shall incur any liability in respect thereof, The Registrar shall, however, be responsible for its representation contained in its certificate of authentication of the Bonds. No Fiduciary shall be under any responsibility or duty with respect to the application of any moneys paid by such Fiduciary in accordance with the provisions of this Resolution to or upon the order of the Agency or any other Fiduciary. No Fiduciary shall be under any obligation or duty to perform any act which would involve it in expense or liability or to institute or defend any suit in respect thereof, or to advance any of its own moneys, unless properly indemnified. No Fiduciary shall be liable in connection with the performance of its duties hereunder except for its own negligence, misconduct or default. SECTION 403. EVIDENCE ON WHICH FIDUCIARIES MAY ACT. la) Each Fiduciary, upon receipt of any notice, resolution, request, consent, order, certif~cate, report, opinion, bond, or other paper or document furnished' to it pursuant to any provision of this Resolution, shall examine such instrument to determine whether it conforms to the requirements of this Resolution and shall be protected in acting upon any such instrument believed by it to be genuine and to have been signed or presented by the proper party or parties. Each Fiduciary may reasonably consult with counsel, who mayor may not be of counsel to the Agency, and the opinion of such counsel shall be full and complete authorization and protection in respect of any action taken or suffered by it under this Resolution in good faith and in accordance therewith. lb) Whenever any Fiduciary shall deem it necessary or desirable that a matter be proved or established prior to taking or suffering any action under this Resolution, such matter (unless other evidence in respect thereof be therein specifically prescribed) may be deemed to be conclusively proved and established by a certificate of the Chairman, Executive Director or his designee, and such certificate shall be full warrant for any action taken or suffered in good faith under the provisions, of this Reso- lution upon the faith thereof; but in its discretion'the Fiduciary may in lieu thereof accept other evidence of such fact or matter or may require such further or additional evidence as it may deem reasonable. lc) Except as otherwise expressly provided in this Resolu- tion, any request, order, notice or other direction required or permitted to be furnished pursuant to any provision thereof by the Agency to any Fiduciary shall be sufficiently executed in the name of the Agency by the Chairman, Executive Director or designee of either of them. 31 SECTION 404. COMPENSATION. The Agency may agree with any Fiduciary to pay to such Fiduciary from time ~o time re~sonable compensation for all services rendered under th~s Resolut~on, and also all reasonable expenses, charges, counsel fees and other disbursements, including those of its attorneys, ag~nts and employees, incurred in and about the performance of the~r pow~rs and duties under this Resolution. The Agency may also agree w~th any Fiduciary to indemnify any Fiduciary for any and all of its reasonable fees, costs and expenses resulting from any claim, liability or the like incurred in and about the performance of its powers and duties under this Resolution. SECTION 405. CERTAIN PERMITTED ACTS. Any Fiduciary, indi- vidually or othRrwise, may become the owner of any Bonds, with the same rights it would have if it were not a Fiduciary. To the extent permitted by law, any Fiduciary may act as depositary for, and permit any of iLs officers or directors to act as a member of, or in any other capacity with respect to, any committee formed to prutecL ll"e r j 'ihU; of Bondholders or to effect or aid in any reorganization growing out of the enforcement of the Bonds or this Resolution, whether or not any such committee shall represent Holders of a majority in principal amount of the Bonds then Out- standing. SECTION 406. MERGER OR CONSOLIDATION. Any entity into which any Fiduciary may be merged or converted or with which it may be consolidated or any entity resulting from any merger, conversion or consolidation to which it shall be a party or any entity to which any Fiduciary may sell or transfer all or substantially all of its corporate trust business shall be a successor Fiduciary hereunder provided such entity shall be a bank or trust company organized under the laws of any state of the United States or a national banking association or shall be a successor entity to the Agency, if the Agency is acting as Fiduciary hereunder, shall be authorized by law to perform all duties imposed upon it by this Resolution, and shall be such successor without the execution or filing of any paper or the performance of any further act. SECTION 407. ADOPTION OF AUTHENTICATION. In case any of the Bonds contemplated to be issued under this Resolution shall have been authenticated but not delivered, any successor Registrar may adopt the certificate of authentication of any predecessor Registrar so authenticating such Bonds and deliver such Bonds so authenticated; and in case any of the said Bonds shall not have been authenticated, any successor Registrar may authenticate such Bonds in the name of the predecessor Registrar, or in the name of the successor Registrar, and in all such cases such certificate shall be fully effective. SECTION 408. RESIGNATION OR REMOVAL OF FIDUCIARY AND APPOINTMENT OF SUCCESSOR. Any Fiduciary may at any time resign an be discharged of the duties and obligations created by this Resolution by giving at least 60 days' written notice to the issuer of a Credit Facility or Liquidity Facility, the Agency, and the other Fiduciaries. Any Fiduciary may be removed at any. time by an instrument filed with such Fiduciary and the issuer. of each Credit Facility or Liquidity Facility and signed by the Chairman, Executive Director or his designee. Any successor Fiduciary shall be appointed by the Agency and shall be, if other than the Agency or its successor entity, a bank or trust company organized under the laws of any state of the United States or a national banking association, willing and able to accept the office on reasonable and customary terms and authorized by law to perform all the duties imposed upon it by this Resolution. The Agency shall notify the issuer of each Credit Facility or Liquidity Facility of the appointment of any successor Fiduciary. In the event of the resignation or removal of any Fiduciary, such Fiduciary shall pay over, assign and deliver any moneys held by it as Fiduciary to its successor. 3 ~~ SECTION 409. VACANCY. If at any time hereafter any Fidu- ciary shall resign, be removed, be dissolved, or otherwise become incapable of acting, or if the bank or trust company acting as any Fiduciary shall be taken over by any governmental official, agency, department or board, the position of Fiduciary shall thereupon become vacant. If the position of such Fiduciary shall become vacant for any of the foregoing reasons or for any other reasons, the Agency shall appoint a successor Fiduciary and shall publish notice of any such appointment by it made once in each week for two (2) successive weeks in a daily newspaper of general circulation or a financial journal published in the Borough of Manhattan, City and State of New York. At any time within one year after any such vacancy shall have occurred, the Holders of a majority in aggregate principal amount of the Bonds hereby secured and then Outstanding, by an instrument or concurrent instruments in writing, executed by such Bondholders or their attorneys in fact or legal representatives and filed with the Agency, may appoint a successor Fiduciary which shall supersede such Fiduciary theretofore appointed by the Agency. Photostatic copies of each such instrument shall be delivered promptly by the Agency to the predecessor Fiduciary and to the Fiduciary so appointed by the Bondholders. If no appointment of a successor Fiduciary shall be made pursuant to the foregoing provisions of this Section, the Holder of any Bond Outstanding hereunder or any retiring Fiduciary may apply to any court of competent jurisdiction to appoint a successor Fiduciary. Such court may thereupon, after such notice, if any, as such court may deem proper and prescribe, appoint a successor Fiduciary. Any Fiduciary hereafter appointed, if not the Agency or its successor entity, shall be a bank or trust company authorized by law to exercise corporate trust powers and subject to examination by federal or state authority, of good standing and having at the time of its appointment a combined capital and surplus aggregate not less than Fifty Million Doll~rs ($50,000,000). . [END OF ARTICLE IV] " 33 ARTICLE V EXECUTION OF INSTRUMENTS BY BONDHOLDERS AND PROOF OF OWNERSHIP OF BONDS SECTION 501. PROOF OF EXECUTION OF DOCUMENTS AND OWNERSHIP. (a) Any request, direction, consent or other instrument in writing required by this Resolution to be signed or executed by Bondholders may be in any number of concurrent instruments of similar tenor and may be signed or executed by such Bondholders in person or by their attorneys or legal representatives appointed by an instrument in writing. Proof of the execution of any such instrument and of the ownership of Bonds shall be sufficient for any purpose of this Resolution and shall be conclusive in favor of the Fiduciary with regard to any action taken by it under such instrument if made in the following manner: (1) The fact and date of the execution by any person of any such instrument may be proved by the verification of any officer in any jurisdiction who, by the laws thereof, has power to take affidavits within such jurisdiction, to the effect that such instrument was subscribed and sworn to before him, or by an affidavit of a witness to such execution. Where such execution is in behalf of a person other than an individ- ual, such verification shall also constitute sufficient approval of the authority of the signor thereof. (2) The ownership of Bonds shall be proved by the registration books required to be maintained pursuant to the provisions of this Resolution. Nothing contained in this Article shall be construed as limiting the Fiduciary to such proof, it being intended that the Fiduciary may accept any other evidence of the matters herein stated which it may deem sufficient. (b) If the Agency shall solicit from the Holders any request, direction, consent or other in8'trument in writing required or permitted by this Resolution to be signed or executed by the Holders, the Agency may, at its option, fix in advance a record date for determination of Holders entitled to give each request, direction, consent or other instrument, but the Authority shall have no obligation to do so. If such a record date is fixed, such request, direction, consent or other instrument may be given before or after such record date, but only the Holders of record at the close of business on such record date shall be deemed to be Holders for the purposes of determining whether Holders of the requisite proportion of Bonds have authorized or agreed or consented to such request. direction, consent or other instrument. and for that purpose the Bonds shall be computed as of such record date. lc) Any request or consent of the Holder of any Bond shall bind every future Holder of the same Bond in respect of anything done by the Agency or any Fiduciary in pursuance of such request or consent. [END OF ARTICLE V) 34 ARTICLE VI MISCELLANEOUS PROVISIONS SECTION 601.. MODIFICATION OR AMENDMENT. Except as otherwise provided in the second paragraph hereof, no adverse material modification or amendment of this Resolution, or of any resolution amendatory hereof or supplemental hereto, may be made without the consent in writing of (i) the Holders of more than fifty per centum (50%) in aggregate principal amount of the Bonds then Outstanding or (ii) in case less than all of the several Series of Bonds then Outstanding are affected by the modification or amendment, the Holders of more than fifty per centum (50%) in ~ggregate principal amount of the Bonds of each Series so affected and Outstanding at the time such consent is given; provided, however, that no modifi- cation or amendment shall permit a change in the maturity of such Bonds or a reduction in the rate of interest thereon, or affecting the promise of the Agency to pay the principal of and interest on the Bonds, as the same mature or become due, from the Pledged Funds, or reduce the percentage of Holders of Bonds required above for such modification or amendment, without the consent of the Holders of all the Bonds. For the purposes of this Section 601, to the extent any Series of Bonds is secured by a Credit Facility or Liquidity Facility, then the consent of the issuer of the Credit Facility or Liquidity Facility shall constitute the consent of the Holders of such Series. This Resolution may be amended, changed, modified and altered without the consent of the Holders of Bonds or any Credit Facility or Liquidity Facility: (a) to cure any ambiguity or formal defect or omission in this Resolution or in any supplemental resolutions or to correct or supplement any provision contained herein which may be defective or inconsistent with any other provisions contained herein; or '. (b) to grant to or confer upon the Bondholders any additional rights, remedies, powers, authority or security that may lawfully be granted to or conferred upon the Bond- holders or (c) to add to the conditions, limitations and restric- tions on the issuance of Bonds under the provisions of this Resolution, other conditions, limitations and restrictions thereafter to be observed; or (d) to add to the covenants and agreements of the Agency in this Resolution other covenants and agreements thereafter to be observed by the Agency or to surrender any right or power herein reserved to or conferred upon the Agency; or Ie) to permit the issuance of Bonds, the interest on which is intended to be excludable from gross income for Federal income tax purposes under the C9de to the Holders thereof in coupon form, if as a conditioh precedent to the adoption of such supplemental resolution, there shall be delivered to the Agency an opinion of counsel of recognized standing relating to municipal bonds to the effect that the issuance of Bonds in coupon form is then permitted by law and that the issuance of such Bonds in coupon form would not cause interest on such Bonds to be included in gross income for Federal income tax purposes under the Code to the Holders thereof; or (f) to permit the Agency to issue Bonds the interest on which is not excludable from gross income for Federal income tax purposes under the Code to the Holders thereof; or 35 I . (g) to qualify the Bonds or any of the Bonds for registration under the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended; or (hI to qualify this Resolution as an "indenture" under the Trust Indenture Act of 1939, as amended; or (i) to make such changes as may be necessary to adjust the terms hereof, including the provisions of Section 304(D), so as to facilitate the issuance of Capital Appreciation Bonds, Capi tal Appreciation and Income Bonds, Put Bonds, Extendible Maturity Bonds and such other Bonds as may be marketable from time to time; or (j) to permit Bonds to be issued in book entry form with or without physical bonds; or lk) to make such changes as may be necessary to comply with the provisions of the Code relating to the exclusion of interest on the Bonds from gross income thereunder; or (I) to make such changes as may evidence the interest herein of an issuer of a Credit Facility or a Liquidity Facility that secures any Series of Bonds. If at any time the Agency shall so request the Trustee, the Trustee shall cause a notice of a proposed supplemental resolution requiring the consent of Bondholders to be mailed, postage prepaid, to all Holders of Bonds then Outstanding at their addresses as they appear on the registration books. Such notice shall briefly set forth the nature of the proposed supplemental resolution and shall state that a copy thereof is on file at the principal corporate trust office of the Trustee for inspection by all Bondholders. The Trustee shall not, however, be subject to any liability to any Bondholder by reason of its failure to mail the notice required by this Section, and any such failure shall not affect the validity of such supplemental resolution when consented to or approved as provided in this Section. '. Whenever, at any time after the date of the mailing of such notice, the Agency shall deliver to the Trustee an instrument or instruments purporting to be executed by the Holders of at least a majority in aggregate principal amount of the Bonds then Out- standing, which instrument or instruments shall refer to the proposed supplemental resolutions described in such notice and shall specifically consent to and approve the adoption thereof, and the Agency shall deliver to the Trustee a certificate signed by the Chairman that the Holders of such required percentage of Bonds have filed such consents, the Agency may adopt such supplemental resolu- tions in substantially such form without liability or responsibil- ity to any Holder of any Bond, whether or not such Holder shall have consented thereto. It shall not be necessary for the consent of the Holders to approve the particular form of any proposed supplemental resolution, but it shall be sufficient if such consent shall approve the substance thereof. If the Holders of more than fifty per centum (50\) in aggre- gate principal amount of the Bonds of each Series as affected and Outstanding at the time of the adoption of such supplemental resolution shall have consented to and approved the adoption thereof as herein provided, no Holder shall have any right to object to the adoption of such supplemental resolution, or to object to any of the terms and provisions therein contained, or the operation thereof, or in any manner to question the propriety of the adoption thereof, or to enjoin or restrain the Agency from adopting the same or from taking any action pursuant to the pro- visions thereof. The consent of the Holders of any additional Series of Bonds to be issued hereunder shall be deemed given if the underwriters or ."".I"...\l.....,r."."U,.. 36 initial purchasers for resale consent in writing to such sup- plemental resolution and the nature of the amendment effected by such supplemental resolution is disclosed in the official statement or other offering document pursuant to which such additional Series of Bonds is offered and sold to the public. SECTION 602. SEVERABILITY OF INVALID PROVISIONS. If anyone or more of the covenants, agreements or provisions of this Resolution should be held contrary to any express provision of law or contrary to the policy of express law, though not expressly prohibited, or against public policy, or shall for any reason whatsoever be held invalid, then such covenants, agreements or provisions shall be null and void and shall be deemed separate from the remaining covenants, agreements or provisions, and shall in no way affect the validity of any of the other provisions of this Resolution or of the Bonds issued hereunder. SECTION 603. SALE OF BONDS. Except as otherwise provided in Section 201 with respect to the Series 1993 Bonds, the Bonds shall be issued and sold at one time or from time to time and at such price or prices consistent with the provisions of the Act and the requirements of this Resolution as the Agency shall hereafter determine by resolution. SECTION 604. CAPITAL APPRECIATION BONDS; CAPITAL APPRE- CIATION AND INCOME BONDS. (a) For the purposes of (i) receiving payment of the redemption price if a Capital Appreciation Bond is redeemed prior to maturity, or (ii) computing the amount of Bonds held by the registered owner of a Capital Appreciation Bond in giving to the Agency any notice, consent, request or demand pursuant to this Resolution for any purpose whatsoever, the principal amount of a Capital Appreciation Bond shall be deemed to be its Accreted Value. (b) For the purpose of (i) receiving payment of the redemp- tion price if a Capital Appreciation and Income Bond is redeemed prior to maturity, or (ii) computing the amount of Bonds held by the registered owner of a Capital Appreciation and Income Bond in giving to the Agency any notice,' consent, request or demand pur- suant to this Resolution for any purpose whatsoever, the principal.. amount of a Capital Appreciation and Income Bond shall be deemed to be its Appreciated Value. SECTION 605. UNCLAIMED MONEY. Notwithstanding any pro- visions of this Resolution, any money held by any Fiduciary for the payment of the principal or redemption price of, or interest on, any Bonds and remaining unclaimed for five (5) years after the principal of all of the Bonds has become due and payable (whether at maturity or upon call for redemption), if such money were so held at such date, or five (S) years after the date of deposit of such money if deposited after such date when all of the Bonds became due and payable, shall be repaid to the Agency free from the provisions of this Resolution, and all liability of the Fiduciary with respect to such money shall thereupon cease; provided, however, that before the repayment of such money to the Agency as aforesaid, the Agency shall first publish at least once in a financial newspaper or journal published ahd/or of general circulation in New York, New York, a notice, in such form as may be deemed appropriate by the Agency with respect to the Bonds so payable and not presented, and with respect to the provisions relating to the repayment to the Issuer of the money held for the payment thereof. SECTION 606. PAYMENTS DUE ON SATURDAYS, SUNDAYS AND HOLIDAYS. In any case where the date of maturity of interest on or principal of the Bonds or the date fixed for redemption of any Bonds shall be a Saturday, Sunday or a day on which any Paying Agent is required, or authorized or not prohibited, by law lincluding executive orders) to close and is closed, then pa~nent of such interest or principal and any redemption premium need not 37 be paid by the Paying Agent on such date but may be paid on the next succeeding business day on which the Paying Agent is open for business with the same force and effect as if paid on the date of maturity or the date fixed for redemption, and no interest shall accrue for the period after such date of maturity. SECTION 607. CONTROLLING LAW; MEMBERS OF GOVERNING BODY OF AGENCY NOT LIABLE. The provisions of this Resolution shall be governed by, and interpreted in accordance with, the laws of the State. All covenants, stipulations, obligations and agreements of the Agency contained in this Resolution shall be deemed to be covenants, stipulations, obligations and agreements of' the Agency to the full extent authorized by the Act and provided by the Constitution and laws of the State. No covenant, stipulation, obligation or agreement contained herein shall be deemed to be a covenant, stipulation, obligation or agreement of any present or future member, agent or employee of the Board or the Agency in his individual capacity, and neither the members of the Board nor any official executing the Bonds shall be liable personally on the Bonds or this Resolution or shall be subject to any personal liability or accountability by reason of the issuance or the execu- tion by the Board or such members thereof. SECTION 608. FURTHER AUTHORIZATIONS. The Chairman, the Executive Director and such other officers, employees and staff members of the Agency as may be designated by the Chairman and the Executive Director or either of them are each designated as agents of the Agency in connection with the issuance and delivery of the Bonds and are authorized and empowered, collectively or individu- ally, to take all action and steps and to execute all instruments, documents and contracts on behalf of the Agency, that are necessary or desirable in connection with the execution and delivery of the Bonds, and which are not inconsistent with the terms and provisions of this Resolution. SECTION 609. HEADINGS FOR CONVENIENCE ONLY. Any headings preceding the texts of the several articles and sections hereof shall be solely for convenien~e of reference and shall not constitute a part of this Resolution, nor shall they affect its meaning, construction or effect. SECTION 610. TIME OF TAKING EFFECT. This Resolution shall take effect immediately upon its adoption. PASSED AND ADOPTED this ~ day (SEAL) Attest: r-"G~~,.1~ 2' ~nvv\;--- 3E'~1'etary 1"".rlf(.I'......JJ.HOIfO".. 38 I hen:by certi1Y that the above 3IId at'oregoing is a lJUe oopy t:J: In witness tbercaf Il11:t ~ Iumd 3IId lad Ihisd3:r;:~1o' DY~ N~/Juuf~') iAdJ V" I nYI' / fQ~;'1 EXHIBIT A BOND FORM (Face of Bond) No. R- $ UNITED STATES OF AMERICA STATE OF FLORIDA MIAMI BEACH REDEVELOPMENT AGENCY TAX INCREMENT REVENUE BONDS, SERIES (CITY CENTER/HISTORIC CONVENTION VILLAGE) Interest Rate Maturity Date Date of Original Issuance Q.lllE REGISTERED OWNER: PRINCIPAL AMOUNT: DOLLARS KNOW ALL MEN BY THESE PRESENTS that the Miami Beach Redevelopment Agency (the "Agency"), for value received, hereby prom1ses to pay to the registered owner specified above, or registered assigns, on the date specified above, but solely from the sources hereinafter mentioned, upon presentation and surrender hereof at the principal corpora:te trust office of First Union National Bank of Florida, Miami, Florida, as paying agent (said bank and/or any bank or trust company to become successor paying agent being herein called the "Paying Agent"), the principal sum specified above with interest thereon at the rate per annum specified above, payable on the first day of and of each year, commencing on Principal of this Bond is payable at the office of the Paying Agent in lawful money of the United States of America. Interest on this Bond is payable by check or draft of the Paying Agent made payable to the registered owner as its name and address shall appear on the registry books of First Union National Bank of Florida, Miami, Florida, as Registrar lsaid bank and any successor Registrar being herein called the "Registrar") at the close of business on the fifteenth day of the calendar month preceding each interest payment date (the "Regular Record Date"); provided, however, that (i) if ownership of the Bonds is maintained in a book-entry only system by a securities depository, such payment may be made by automatic funds transfer (wire) to such securities depos~tory of its nominee or (ii) if such Bonds are not maintained in\ a book-entry only system by a securities depository, upon written request of the Holder of $1,000,000 or more in principal amount of Bonds, such payments may be made by wire transfer to the bank and bank account specified in writing by such Holder lsuch bank being a bank within the continental United States), if such Holder has advanced to the Paying Agent the amount necessary to pay the cost of such wire transfer or authorized the Paying Agent to deduct the cost of such wire transfer from the payment due such Holder. Any interest not punctually paid on an interest payment date shall forthwith cease to be payable to the registered owner on the Regular Record Date and may be paid to the registered owner as of the close of business on a special record date for the payment of such defaulted interest A-1 , , to be fixed by the Paying Agent, notice whereof shall be given not less than 10 days prior to such special record date to the registered owners. Such interest shall be payable from the most recent interest payment date next preceding the date of authentication to which interest has been paid, unless the date of authentication is an 1 or 1 to which interest has been paid, in which case from the date of authentication, or unless the date of authentication is prior to , 19 , in which case from ,19 or unless the date of -authentication is between a Regular RecordlDate and the next succeeding interest payment date, in which case from such interest payment date. This Bond is one of an authorized issue of Bonds of the Agency designated as its "Tax Increment Revenue Bonds, Series ____ (City Center/Historic Convention Village)" (herein called the "Bonds"), in the aggregate principal amount of Dollars ($ ) of like date, tenor, and effect, except as to number, date of maturity and interest rate, issued for the purpose of under the authority of and in full compliance with the Constitution and Statutes of the State of Florida, including particularly Chapter 163, Part III, Florida Statutes, as amended from time to time, and other applicable provisions of law, and a resolution duly adopted by the Agency on , 1993 (hereinafter referred to as the "Resolution") and is subj ect to all the terms and conditions of the Resolution. REFERENCE IS HEREBY MADE TO THE FURTHER PROVISIONS OF THIS BOND SET PORT ON THE REVERSE SIDE HEREOF AND SUCH FURTHER PROVI- SIONS SHALL FOR ALL PURPOSES HAVE THE SAME EFFECT AS IF SET FORTH ON THE FRONT SIDE HEREOF. It is hereb~ certified and recited that all acts, conditions and things requJ.re to exist, to happen, and to be performed, precedent to and in the issuance of this Bond exist, have happened and have been performed in regular and due form and time as required by the Laws and Consti,tution of the State of Florida applicable thereto, and that the Issuance of this Bond, and of the issue of Bonds of which this Bond is one, is in full compliance with all constitutional, statutory or charter limitations or provisions. IN WITNESS WHEREOF, the Miami Beach Redevelopment Agency has caused this Bond to be signed by its Chairman, either manually or with his facsimile signature, and the seal of the Miami Beach Redevelopment Agency or a facsimile thereof to be affixed hereto or imprinted or reproduced hereon, and attested by the Executive Director, either manually or with his facsimile signature. MIAMI BEACH REDEVELOPMENT AGENCY CHAIRMAN (SEAL) Attest: EXECUTIVE DIRECTOR .,.'''.IIU.l\'....''",,,,.,,.. A-2 FORM OF CERTIFICATE OF AUTHENTICATION This Bond is one of the Bonds delivered pursuant to the within mentioned Resolution. Date of Authentication: FIRST UNION NATIONAL BANK OF FLORIDA, as' Registrar By: Authorized Officer '. j' ". ."'\.e'''...''....''..\.I/.,'... A-3 [Back of Bond] This Bond is payable solely from and secured by a first lien on and pledge of the Net Trust Fund Revenues (as defined in the Resolution) collected by the Agency pursuant to Section 163.387, Florida Statutes, as amended, the Supplemental Revenues las defined in the Resolution) received by First Union National Bank of Florida, Miami, Florida, as trustee (said bank and any successor trustee being herein called the "Trustee") for so long as the City of Miami Beach, Florida (the "City") is obligated to transfer Supplemental Revenues to the Trustee as described in the Resolution and all moneys held in certain funds and accounts established under the Resolution I collectively, the "Pledged Funds"), all in the manner provided in the Resolution. Neither the Agency, the City, Dade County, Florida (the "County"), the State of Florida (the "State") nor any of its political subdivisions is obligated to pay this Bond or the interest hereon except from the Pledged Funds pledged thereto and neither the faith and credit nor the taxing power of the City, the County, the State or any of its political subdivisions is pledged to the payment of the principal of, or the interest on, this Bond. This Bond does not constitute an indebtedness of the Agency, the City, the County, the State or any political subdivision thereof within the meaning of any constitutional, statutory or other provision or limitation and it is expressly agreed by the Holder of this Bond that such Holder shall never have the right to require or compel the exercise of the ad valorem taxing power of the City, the County, the State or any political sUbdivision thereof or taxation in any form on any real or personal property therein, for the payment of the principal of and interest on this Bond and other payments provided for in the Resolution. It is further agreed between the Agency and the Holder of this Bond that this Bond and the obligation evidenced thereby shall not constitute a lien upon property owned by or situated within the corporate territory of the Agency or the City, but shall constitute a lien only on the Pledged Funds, all in the manner provided in the Resolution. '. Under the provisions of Section 163.387, Florida Statutes, as amended, the City and the County have established the City Center/Historic Convention Village Redevelopment and Revitalization Trust Fund into which the County and the City have agreed to deposit on an annual basis their respective portions of the Trust Fund Revenues (as defined in the Resolution) for so long as the Bonds are outstanding. In addition, the City has covenanted to transfer to the Trustee the Supplemental Revenues as required for payment of the principal of and interest on the Bonds and to make the required deposits to the Debt Service Reserve Account; provided, however, that the lien on and pledge of the Supplemental Revenues for the benefit of the owners of the Bonds may be released and extinguished under the terms and conditions specified in the Resolution. The Agency in the Resolution has established with the Trustee the Miami Beach Redevelopment Agency Sinking Fund (City Center/Historic Convention Village) and certain accounts therein and covenanted to deposit into said Sinking Fund and accounts therein solely from the Pledged Funds moneys to provide for the timely payment of principal of and interest on the Bonds and to create a reserve therefor, all to the extent and in the manner provided in the Resolution. Reference is hereby made to the Resolution for the specific provisions governing the Bonds. [Redemption Provisions] Additional parity bonds may be issued by the Agency from time to time upon the conditions and within the limitations and in the manner provided in the Resolution. ,,,,,,IIIHI'\I..''',I\0I/0'''' A-4 The original registered owner, and each successive registered owner of this Bond shall be conclusively deemed to have agreed and consented to the following terms and conditions: 1. The Registrar shall keep books for the registration of Bonds and for the registration of transfers of Bonds as provided in the Resolution. The Bonds shall be transferable by the registered owner thereof in person or by his attorney duly authorized in writing only upon the books of the Agency kept by the Registrar and only upon surrender hereof together with a written instrument of transfer satisfactory to the Registrar duly executed by the registered owner or his duly authorized attorney. Upon the transfer of any such Bond, the Agency shall issue in the name of the transferee a new Bond or Bonds. 2. The Agency, the Trustee, the Registrar and the Paying Agent may deem and treat the person in whose name any Bond shall be registered upon the books kept by the Registrar as the absolute owner of such Bond, whether such Bond shall be overdue or not, for the purpose of receiving payment of, or on account of, the principal of and interest on such Bond as the same becomes due, and for all other purposes. All such payments so made to any such registered owner or upon his order shall be valid and effectual to satisfy and discharge the liability upon such Bond to the extent of the sum or sums so paid, and neither the Agency, the Trustee, the Paying Agent, nor the Registrar shall be affected by any notice to the contrary. 3. At the option of the registered owner thereof and upon surrender hereof at the principal corporate trust office of the Registrar with a written instrument of transfer satisfactory to the Registrar duly executed by the registered owner or his duly authorized attorney and upon payment by such registered owner of any charges which the Registrar or the Agency may make as provided in the Resolution, the Bonds may be exchanged for Bonds of the same series and maturity of any other authorized denominations. I II 4. In all cases in which the privilege of exchanging Bonds or transferring Bonds is exercised, the Agency shall execute and the Registrar shall authenticate and deliver Bonds in accordance with the provisions of the Resolution. There shall be no charge for any such exchange or transfer of Bonds, but the Agency or the Registrar may require payment of a sum sufficient to pay any tax, fee or other governmental charge 'required to be paid with respect to such exchange or transfer. Neither the Agency nor the Registrar shall be required (a) to transfer or exchange Bonds for a period of 15 days next preceding an interest payment date on such Bonds or next preceding any selection of Bonds to be redeemed or thereafter until after the mailing of any notice of redemption; or (b) to transfer or exchange any Bonds called for redemption. A-5 [FORM OF ABBREVIATIONS FOR BONDS] The following abbreviations, when used in the inscription on the face of the within Bond, shall be construed as though they were written out in full according to applicable laws or regulations. TEN COM - as tenants in common TEN ENT - as tenants by the entireties JT TEN - as joint tenants with the right of survivor- ship and not as tenants in common UNIFORM GIFT MIN ACT - Custodian (Cust) (Minor) under Uniform Gifts to Minors Act lState) Additional abbreviations may also be used though not in the above list. [FORM OF ASSIGNMENT FOR BONDS] For value received, the undersigned hereby sells, assigns and transfers unto the within Bond, and all rights thereunder, an hereby irrevocably constitutes and appoints , attorney to transfer the said Bond on the bond register, with full power of substitution in the premises. Dated: Please insert Social Security or other identifying number of transferee: '. Signature guaranteed: NOTICE: The transferor's signature to this Assignment must correspond with the name as it appears on the face of the within Bond in every particular without alteration or any change whatever. ''''''.'''',"11''''',''.'''''.4 A- 6 . . EXHIBIT B AGENCY CERTIFICATE First Union National Bank of Florida, as Trustee Miami, Florida The undersigned authorized official of the Miami Beach Redevelopment Agency hereby certifies that payment of the amounts specified in the requisition to which this Certificate is attached, when added to all other payments made, from proceeds of the Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Series 1993 (City Center/Historic Convention Village) (the "Series 1993 Bonds") will not result in less than 95 percent of the net proceeds of the Series 1993 Bonds and the investment earnings thereon or attributable thereto being used for "redevelopment purposes" within the meaning of Section 144(c) of the Internal Revenue Code of 1986, as amended. Dated: MI~I BEACH REDEVELOPMENT AGENCY By: Authorized Official " ...O\el'""'""",.".".".. B-1 , . [This page intentionally left blank] RESOLUTION NO. 297-98 A RESOLUTION OF THE CHAIRMAN AND MEMBERS OF THE MIAMI BEACH REDEVELOPMENT AGENCY AUTHORIZING ISSUANCE OF NOT MORE THAN $40,000,000 IN PRINCIPAL AMOUNT OF MIAMI BEACH REDEVELOPMENT AGENCY TAX INCREMENT REVENUE BONDS, TAXABLE SERIES 1998A (CITY CENTER/HISTORIC CONVENTION VILLAGE), AND NOT MORE THAN $10,000,000 IN PRINCIPAL AMOUNT OF MIAMI BEACH REDEVELOPMENT AGENCY TAX INCREMENT REVENUE BONDS, SERIES 1998B (CITY CENTER/HISTORIC CONVENTION VILLAGE), FOR THE PURPOSE OF FUNDING CERTAIN CAPITAL IMPROVEMENTS IN CONNECTION WITH THE AGENCY'S REDEVELOPMENT PLAN FOR THE CITY CENTER/HISTORIC CONVENTION VILLAGE REDEVELOPMENT AND REVIT ALIZA TION AREA, INCLUDING REPAYMENT OF A LOAN, FUNDING ANY NECESSARY DEPOSIT TO THE DEBT SERVICE RESERVE ACCOUNT AND PAYING COSTS OF ISSUANCE, ALL PURSUANT TO SECTION 304(H) OF RESOLUTION NO. 150-94 ADOPTED BY THE AGENCY ON JANUARY 5, 1994; PROVIDING THAT SAID SERIES 1998 BONDS AND INTEREST THEREON SHALL BE PAY ABLE SOLELY FROM PLEDGED FUNDS; PROVIDING CERTAIN DETAILS OF THE SERIES 1998 BONDS; DELEGATING OTHER DETAILS AND MATTERS IN CONNECTION WITH THE ISSUANCE OF THE SERIES 1998 BONDS TO THE CHAIRMAN, WITHIN THE LIMITATIONS AND RESTRICTIONS STATED HEREIN; . AUTHORIZING A BOOK-ENTRY REGISTRATION SYSTEM FOR THE SERIES 1998 BONDS; AUTHORIZING THE NEGOTIATED SALE ANp AWARD BY THE CHAIRMAN OF THE SERIES 1998 BONDS TO THE UNDERWRITERS, WITHIN THE LIMITATIONS AND RESTRICTIONS STATED HEREIN; APPROVING THE FORM OF AND AUTHORIZING THE CHAIRMAN TO EXECUTE AND DELIVER A BOND PURCHASE AGREEMENT; APPROVING THE FORM OF AND DISTRIBUTION OF A PRELIMINARY OFFICIAL STATEMENT AND OFFICIAL STATEMENT AND AUTHORIZING THE EXECUTION AND DELIVERY OF THE OFFICIAL STATEMENT; COVENANTING TO PROVIDE CONTINUING DISCLOSURE IN CONNECTION WITH THE SERIES 1998 BONDS IN ACCORDANCE WITH SECURITIES AND EXCHANGE COMMISSION RULE 15c2-12 AND AUTHORIZING THE EXECUTIVE DIRECTOR TO EXECUTE AND DELIVER AN AGREEMENT WITH RESPECT THERETO; PROVIDING FOR A CREDIT FACILITY FOR THE SERIES 1998 BONDS; PERMITTING THE SATISFACTION OF ALL OR A PORTION OF THE RESERVE ACCOUNT REQUIREMENT WITH A RESERVE ACCOUNT INSURANCE POLICY AND APPROVING THE FORM OF AND AUTHORIZING THE CHAIRMAN TO EXECUTE AND DELIVER AN INSURANCE AGREEMENT WITH THE PROVIDER THEREOF; PROVIDING COVENANTS FOR THE PROVIDER OF SUCH CREDIT FACILITY AND/OR RESERVE ACCOUNT DOA: [04548. DOCS. MIA 180298)A UTH-RESO-3 INSURANCE POLICY; AND AUTHORIZING OFFICERS AND EMPLOYEES OF THE AGENCY TO TAKE ALL NECESSARY ACTIONS IN CONNECTION WITH THE SALE AND DELIVERY OF THE SERIES 1998 BONDS AND OTHER RELATED MATTERS. WHEREAS, the Miami Beach Redevelopment Agency (the "Agency") has heretofore issued its (i) $25,000,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Series 1993 (City Center/Historic Convention Village), (ii) $37,500,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Taxable Series 1996A (City Center/Historic Convention Village) and (iii) $7,705,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Series 1996B (City Center/Historic Convention Village) (collectively, the "Prior Bonds"), to fund the acquisition and clearing of certain property and the construction of certain public improvements (collectively, the "Prior Projects") in connection with the Agency's redevelopment plan (the "Redevelopment Plan") for that portion of the City of Miami Beach, Florida (the "City") known as the "City Center/Historic Convention Village Redevelopment and Revitalization Area" (the "Redevelopment Area"), said Prior Bonds having been issued pursuant to Resolution No. 150-94, adopted by the Agency on January 5, 1994, as supplemented (as amended and supplemented from time to time, the "Bond Resolution") and Resolution No. 94-21008, adopted by the City on January 5, 1994, as supplemented; and WHEREAS, the Agency now desires to finance the completion of the Prior Projects, the acquisition and clearing of certain additional property and the develQpment and construction of certain additional public improvements in connection with the Redevelopment Plan, as more particularly described in Exhibit A attached hereto and made a part hereof (collectively, the "Series '1998 Redevelopment Project"), including repayment of a $20,000,000 interim loan from the City to fund a portion of the Series 1998 Redevelopment Project (the "City Loan"); and 2 DOA;[04548. DOCS .MIA 180298)A UTH-RESO-J WHEREAS, Section 304(H) of the Bond Resolution provides for the issuance of additional parity bonds for the purpose of financing community redevelopment projects undertaken by the Agency pursuant to the Redevelopment Plan within the Redevelopment Area in accordance with the Act (as such term is defined in the Bond Resolution) ("Redevelopment Projects"); and WHEREAS, the Series 1998 Redevelopment Project constitutes a Redevelopment Project under the Bond Resolution; and WHEREAS, the Agency has determined that it is desirable to issue additional parity bonds (collectively, the "Series 1998 Bonds") pursuant to the provisions of Section 304(H) of the Bond Resolution and this Resolution for the purpose of providing funds, together with any other available funds, to finance the Series 1998 Redevelopment Project, including repayment of the City Loan, to fund any necessary deposit to the Debt Service Reserve Account (as defmed in the Bond Resolution) and to pay costs of issuance thereof; and WHEREAS, the Taxable Bond Act of 1987, being Chapter 159. Part VII, Florida Statutes, as amended (the "Taxable Bond Act"). provides for the issuance by governmental units. including the Agency, of bonds the interest on whicb is not excludable from gross income for federal income tax purposes; and WHEREAS. as a result of the provisions of the Internal Revenue Code of 1986. as amended (the "Code"), it is necessary to issue (i) a portion of the Series 1998 Bonds as bonds the interest on which is not excludable from gross income for federal income tax purposes (the "Series 1998A Bonds") and (ii) the balance of the Series 1998 Bonds as bonds the interest on which is excludable from gross income for federal income tax purposes (the "Series 1998B Bonds"); and 3 DOA: [04548. DOCS. MIA I 80298] A UTH-RESO-3 - WHEREAS, the Chairman and Members of the Agency (the "Commission") have determined that it is in the best interest of the Agency to delegate to the Chainnan the determination of various terms of the Series 1998 Bonds and their sale and other actions in connection with the issuance of the Series 1998 Bonds, all as provided and subject to the limitations contained herein; and WHEREAS, the Agency has determined that due to the character of the Series 1998 Bonds, current favorable market conditions, time constraints, the uncertainty inherent in a competitive bidding process and the recommendations of Dain Rauscher Incorporated, the financial advisor to the Agency in cOilllection with the issuance of the Series 1998 Bonds (the "Financial Advisor"), it is in the best interest of the Agency to authorize the negotiated sale of the Series 1998 Bonds; and WHEREAS, based upon the recommendations of the Financial Advisor, the Agency has further determined to secure two separate financial guaranty insurance policies guaranteeing the scheduled payment of principal of and interest on the corresponding Series of the Series 1998 Bonds (collectively, the II Series 1998 Bond Insurance Policy ") and to the extent so determined by the Chairman in accordance with the provisions of this Resolution, a debt service reserve fund surety bond for deposit to the credit of the Debt Service Reserve Account in satisfaction of all or any portion of the Reserve Account Requirement (as defined in the Bond Resolution) (the "Series 1998 Reserve Policy") from MBIA Insurance Corporation ("MBIA"); and WHEREAS, each of the Series 1998 Bond Insurance Policy shall constitute a Credit Facility under the Bond Resolution and, to the extent all or any portion of the Reserve Account Requirement is satisfied with the Series 1998 Reserve Policy, the Series 1998 Reserve Policy shall constitute a Reserve Account Insurance Policy under the Bond Resolution; and 4 DOA:(04548. DOCS.MIA 180298JA UTH-RESO-J WHEREAS, the Commission has found and determined that the issuance of the Series 1998 Bonds and the undertaking of the Series 1998 Redevelopment Project will serve a valid public purpose; NOW, THEREFORE, BE IT RESOLVED BY THE CHAIRMAN AND MEMBERS OF THE MIAMI BEACH REDEVELOPMENT AGENCY: Section 1. The above recitals are incorporated herein as findings. This Resolution supplements the Bond Resolution. All terms used in capitalized form herein and not defined shall have the meanings set forth in the Bond Resolution. Section 2. Two Series of additional parity Bonds of the Agency are authorized to be issued pursuant to Section 304(H) of the Bond Resolution and the authority granted to the Agency by the Act, including with respect to the Series 1998A Bonds, the Taxable Act. The Series 1998A Bonds shall be issued in a principal amount not to exceed $40,000,000, shall be designated "Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Taxable Series 1998A (City Center/Historic Convention Village)" and shall be issued for the purpose of providing funds, together with other available funds, to fmance the portion of the Series 1998 Redevelopment Project described in Part I of Exhibit A (the "Series 1998A Redevelopment Project"), including repayment of any portion of the City Loan related thereto, to fund any necessary deposit to the Debt Service Reserve Account and to pay costs of issuance thereof. The , I I Series 1998B Bonds shall be issued in a principal amount not to <exceed $10,000,000, shall be designated "Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Series 1998B (City Center/Historic Convention Village)" and shall be issued for the purpose of providing funds, together with other available funds, to finance the portion of the Series 1998 Redevelopment Project described in Part II of Exhibit A (the "Series 1998B Redevelopment 5 DOA: [04548.DOCS .MIA 180298]A lTTH-RESO-3 . , Project"), including repayment of any portion of the City Loan related thereto, to fund any necessary deposit to the Debt Service Reserve Account and to pay costs of issuance thereof. Each Series of the Series 1998 Bonds shall be issued in fully registered form as provided in Section 202 of the Bond Resolution, shall be in the denominations of $5,000 or any integral multiple thereof, and shall be dated and issued at such time, shall be in the form of Serial Bonds and/or Term Bonds, shall have such Interest Payment Dates, shall bear interest at such rates, but not to exceed 8.50% per armum with respect to the Series 1998A Bonds and 6.50% per annum with respect to the Series 1998B Bonds, shall be stated to mature, but not later than December 31, 2022, as to any Term Bonds, shall have Amortization Requirements payable in such amounts and on such dates, and shall be subject to redemption prior to maturity, all as shall be specified in a certificate of the Chairman executed prior to or at the time of the sale of the Series 1998 Bonds (the "Series 1998 Chairman's Certificate"). Term Bonds, if any, will be callable at par with accrued interest, without premium, each year in amounts equal to the . respective Amortization Requirements therefor. Section 3. In accordance with the provisions of the Bond Resolution, the Series 1998 Bonds shall be limited obligations of the Agency payable solely from the Pledged Funds which are pledged to the payment thereof in the manner and to the extent provided in the Bond Resolution, and nothing shall be construed as obligating the Agency or the City to pay the principal, interest and premium, if any, thereon except from the "Pledged Funds or as pledging the full faith and credit of the Agency or the City or as obligating the Agency or the City, directly or indirectly or contingently, to levy or pledge any form of taxation whatever therefor. Section 4. It is hereby found and detennined that due to the character of the Series 1998 Bonds, current favorable market conditions, time constraints, the uncertainty inherent in a 6 DOA: [04548. DOCS .MIA 180298)A UTH-RESO-3 competitive bidding process and the recommendations of the Financial Advisor, the negotiated sale of the Series 1998 Bonds is in the best interest of the Agency. The negotiated sale of the Series 1998 Bonds to PaineWebber Incorporated (the "Senior Managing Underwriter") on behalf of itself and Prudential Securities Incorporated and William R. Hough & Co. (collectively with the Senior Managing Underwriter, the "Underwriters") is hereby authorized at a purchase price determined in such a fashion so that the total compensation to be derived by the Underwriters in connection with the public offering of the Series 1998 Bonds will not exceed 2 % of the aggregate principal amount thereof. The Chairman, after consultation with the Financial Advisor and the Executive Director, is hereby authorized to award the Series 1998 Bonds to the Underwriters at a price determined in accordance with the preceding sentence and as shall be further set forth in the Series 1998 Bond Purchase Agreement (as hereinafter defmed). The execution and delivery of the Series 1998 Bond Purchase Agreement for and on behalf of the Agency by the Chairman shall be conclusive evidence of the Agency's acceptance of the' Underwriters' proposal to purchase the Series 1998 Bonds. Section 5. The Chairman, after consultation with the Financial Advisor and the Executive Director, with respect to each Series of Series 1998 Bonds, is hereby authorized to determine the principal amount of Series 1998 Bonds to be issued, the date of the Series 1998 Bonds and the time of issuance thereof, the Interest Payment Dates therefor, the maturities and dates upon which Amortization Requirements are payable, but not later than December 31, 2022, the redemption features thereof and the principal amounts of the Serial Bond maturities and the Term Bond Amortization Requirements, all of which shall be set forth in the Series 1998 Chairman's Certificate. The Chairman, after consultation with the Financial Advisor and the Executive Director, is also hereby authorized to determine the interest rates for the Series 1998 7 DOA: [04548. DOCS. MIA 180298)A UTH-RESO-J " Bonds, which interest rates shall be set forth in the Series 1998 Chairman's Certificate and shall not exceed the limits hereinabove set forth. Section 6. The Commission hereby authorizes the Chairman to execute and deliver a Bond Purchase Agreement for the Series 1998 Bonds (the "Series 1998 Bond Purchase Agreement") for and on behalf of the Agency, in substantially the fonn presented at the meeting at which this Resolution was considered, subject to such changes, modifications, insertions and omissions and such filling-in of blanks therein as may be detennined and approved by the Chairman, after consultation with the Executive Director and General Counsel of the Agency. The execution of the Series 1998 Bond Purchase Agreement for and on behalf of the Agency by the Chairman shall be conclusive evidence of the Agency's approval of the Bond Purchase Agreement. The Registrar is hereby authorized and directed to authenticate the Series 1998 Bonds and the Executive Director is hereby authorized to cause the Series 1998 Bonds to be delivered to or upon the order of the Underwriters upon payment of the purchase price, as shall be set forth in the Series 1998 Bond Purchase Agreement, and satisfaction of the conditions contained in Section 304(H) of the Bond Resolution. Section 7. The proposed Preliminary Official Statement (the "Series 1998 Preliminary Official Statement") and Official Statement (the "Series 1998 Official Statement") in connection with the issuance of the Series 1998 Bonds are hereby approved in substantially the form of the Series 1998 Preliminary Official Statement presented at the meeting at which this Resolution was considered, subject to such changes, modifications, insertions and omissions and such filling-in of blanks therein as may be detennined and approved by the Chainnan, after consultation with the Executive Director and General Counsel of the Agency. The execution of the Official Statement, for and on behalf of the Agency by the Chainnan shall be conclusive evidence of the 8 DOA: (04548. DOCS .MIA 180298)A UTH-RESO-J Agency's approval of the Series 1998 Preliminary Official Statement and the Series 1998 Official Statement. The distribution of said Series 1998 Preliminary Official Statement and Series 1998 Official Statement in connection with the marketing of the Series 1998 Bonds and the execution and delivery of the Series 1998 Official Statement by the Chainnan are hereby authorized. The Chainnan or his designee after consultation with the Executive Director and General Counsel of the Agency, is hereby authorized to make any necessary certifications to the Underwriters regarding a near final or deemed final Series 1998 Official Statement, if and to the extent required by Rule 15c2-12 of the United States Securities and Exchange Commission (the "Rule"). Section 8. The proceeds of each Series of the Series 1998 Bonds (including accrued interest, if any) shall be applied as provided in Section 303(b) of the Bond Resolution and a certificate of the Executive Director delivered concurrently with the issuance of the Series 1998 Bonds. With respect to each Series of the Series 1998 Bonds, there are hereby created accounts within each of the Acquisition and Construction Fund and the Cost of Issuance Fund established under the Bond Resolution designated as the "Series 1998A Account" and the "Series 1998B Account". Proceeds of each Series of the Series 1998 Bonds for deposit to the credit of the Acquisition and Construction Fund and the Cost of Issuance Fund shall be deposited in the applicable accounts hereinabove created in accordance with clauses (2) and (4) of Section 303(b) of the Bond Resolution and disbursed pursuant to Section 303 of the Bond Resolution. Section 9. Upon issuance of the Series 1998 Bonds and solely for accounting purposes, the Trustee is hereby authorized to establish separate subaccounts with respect to each Series of Bonds Outstanding under the Bond Resolution within each account of the Sinking Fund in order 9 DOA:[04S48. DOCS. MIA 180298JA UTH-RESO-3 " to permit compliance with the arbitrage rebate requirements under the Code relating to each Series of tax-exempt Bonds issued under the Bond Resolution. Section 10. The Series 1998 Bonds shall be executed in the form and manner provided in the Bond Resolution. The Series 1998 Bonds are hereby authorized to be issued initially in book-entry form and registered in the name of The Depository Trust Company, New York, New York ("DTC"), or its nominee which will act as securities depository for the Series 1998 Bonds. The Executive Director is hereby authorized and directed to execute any necessary letters of representations with DTC and, notwithstanding the provisions of the Bond Resolution, to do all other things, comply with all requirements and execute all other such documents as are incidental to such book-entry system. In the event a book-entry system for the Series 1998 Bonds ceases to be in effect, the Series 1998 Bonds shall be issued in fully registered form without coupons. Section 11. For the benefit of the holders and beneficial owners from time to time of the Series 1998 Bonds, the Agency agrees, in accordance with the Rule, to provide or cause to be provided such annual financial information and operating data, fmancial statements and notices, in such manner, as may be required for purposes of paragraph (b)(5) of the Rule. In order to describe and specify certain terms of the Agency's continuing disclosure agreement, including provisions for enforcement, amendment and termination, the Executive Director is hereby authorized and directed to enter into, execute and deliver, in the name and on behalf of the Agency, a Continuing Disclosure Agreement (the "Series 1998 Continuing Disclosure Agreement") with the City and the Trustee, in substantially the form presented at the meeting at which this Resolution was considered, subject to such changes, modifications, insertions and omissions and such filling-in of blanks therein as may be determined and approved by the Executive Director, after consultation with General Counsel of the Agency. The execution of 10 DOA: (04548. DOCS .MIA 180298]A lJfH-RESO-J -._~~ :::.: 1,1_ __ the Series 1998 Continuing Disclosure Agreement, for and on behalf of the Agency by the Executive Director, shall be deemed conclusive evidence of the Agency's approval of the Series 1998 Continuing Disclosure Agreement. Notwithstanding any other provisions of the Bond Resolution or this Resolution, any failure by the Agency or the City to comply with any provisions of the Series 1998 Continuing Disclosure Agreement shall not constitute a default under the Bond Resolution and the remedies therefor shall be solely as provided in the Series 1998 Continuing Disclosure Agreement. The Executive Director is further authorized and directed to establish, or cause to be established, procedures in order to ensure compliance by the Agency with the Series 1998. Continuing Disclosure Agreement, including the timely provision of information and notices. Prior to making any filing in accordance with such agreement, the Executive Director shall consult with, as appropriate, General Counsel of the Agency or the Agency's bond counsel. The Executive Director, acting in the name and on behalf of the Agency, shall be entitled to. rely upon any legal advice provided by General Counsel of the Agency or the Agency's bond counsel in determining whether a filing should be made. Section 12. The Agency is hereby authorized to secure the Series 1998 Bond Insurance Policy guaranteeing the scheduled payment of principal of and interest on the Series 1998 Bonds and to pay the premiums with respect thereto. Each Series 1998 Bond Insurance Policy shall constitute a Credit Facility under the Bond Resolution. For so long as the Series 1998 Bond Insurance Policy is in effect and MBIA has not defaulted in its obligations thereunder, and notwithstanding any provisions to the contrary contained in the Bond Resolution, the Agency, the Trustee, the Paying Agent, the Registrar and 11 DOA: (04S48. OOCS . MIA 180298)A UTH-RESO-3 . . . . the Holders of the Series 1998 Bonds, as applicable, covenant and agree, but solely for the benefit of MBIA, as follows: (a) In connection with the issuance of additional parity Bonds under the Bond Resolution, the Agency shall deliver to MBIA a copy of the disclosure document, if any, circulated with respect to such additional parity Bonds. (b) MBIA will be deemed the Bondholder of all Series 1998 Bonds under the Bond Resolution, in lieu of the registered owners thereof, for purposes of (i) consenting to the adoption of any supplemental resolution which requires the consent of Bondholders pursuant to the Bond Resolution and (ii) exercising any rights and remedies granted to the Bondholders of the Series 1998 Bonds under the Bond Resolution upon the occurrence of a default thereunder; provided, however, that MBIA shall not have the right to decrease the amount of principal or interest due and owing on the Series 1998 Bonds or extend the dates of payment of installments of principal of and interest on the Series 1998 Bonds. (c) The Agency shall provide MBIA and Standard & Poor's Ratings Services ("S&P") with a copy of all supplemental resolutions adopted pursuant to the Bond Resolution. (d) Defeasance Obligations in connection with any defeasance of the Series 1998 Bonds shall be limited to: 1. U.S. Treasury Certificates, Notes and Bonds (including State and Local Government Series--" SLGS "). 2. Direct obligations of the Treasury which have been stripped by the Treasury itself, CATS, TIGRS and similar securities. 3. The interest component of Resolution Funding Corp. securities ("REFCORP") which have been stripped by request to the Federal Reserve Bank of New York in book entry form. 4. Pre-refunded municipal bonds rated "Aaa" by Moody's Investors Service, Inc. ("Moody's") and "AAA" by S&P. If however, the issue is only rated by S&P (i.e., there is no Moody's rating), then the pre-refunded bonds must have been pre-refunded with cash, direct U.S. or U.S. guaranteed obligations, or AAA rated pre-refunded municipals. 5. Obligations issued by the following agencies which are backed by the full faith and credit of the U.S.: 12 OOA:[04S48.DOCS.MIA180298jA UTH-RESO-3 a. U.S. Export-Imoort Bank (Eximbank) Direct obligations or fully guaranteed certificates of beneficial ownership b. Fanners Home Administration (FmHA) Certificates of beneficial ownership c. Federal Financifil! Bank d. General Services Administration Participation certificates e. U.S. Maritime Administration Guaranteed Title XI financing f. U.S. Department of Housine: and Urban Development (HUD) Project Notes Local Authority Bonds New Communities Debentures - U.S. government guaranteed debentures U.S. Public Housing Notes and Bonds - U.S. government guaranteed public housing notes and bonds. (e) Pennitted Investments under the Bond Resolution shall be limited to: 1. Direct obligations of the United States of America (including obligations issued or held in book-entry fonn on the books of the Department of the Treasury, and CATS and TGRS) or obligations the principal of and interest on which are unconditionally guaranteed by the United States of America. 2. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by any of the following federal agencies and provided such obligations are backed by the full faith and credit of the United States of America (stripped securities only if they have been stripped by the agency itself) : a. U.S. Export-Imoort Bank (Eximbank) Direct obligations or fully guaranteed certificates of beneficial ownership b. Fanners Home Administration (FmHA) Certificates of beneficial ownership c. Federal Financing Bank 13 DOA: [04S48.00CS. MIA 180298)A UTH-RESO-3 I, I o d. Federal Housing Administration Debentures (FHA) e. General Services Administration Participation certificates f. Government National Mortgage Association (GNMA or Ginnie Mae) GNMA - guaranteed mortgage-backed bonds GNMA - guaranteed pass-through obligations g. U.S. Maritime Administration Guaranteed Title XI financing h. U.S. Department of Housing and Urban Development (HUD) Project Notes Local Authority Bonds New Communities Debentures - U.S. government guaranteed debentures U.S. Public Housing Notes and Bonds - U.S. government guaranteed public housing notes and bonds. 3. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by any of the following non-full faith and credit U.S. government agencies (stripped securities only if they have been stripped by the agency itself): a. Federal Home Loan Bank System Senior debt obligations b. Federal Home Loan Mortgage Corooration (FHLMC or Freddie Mac) Participation Certificates Senior debt obligations c. Federal National Mortgage Association (FNMA or Fannie Mae) Mortgage-backed securities and senior debt obligations d. Student Loan Marketing Association (SLMA or Sallie Mae) Senior debt obligations e. Resolution Funding Corp. (REFCORP) Obligations f. Farm Credit System Consolidated systemwide bonds and notes 14 DOA:[04548. DOCS .MIA 180298]A UTH-RESO-J 4. Money market funds registered under the Federal Investment Company Act of 1940, whose shares are registered under the Federal Securities Act of 1933, and having a rating by S&P of AAAm-G, AAAm, or Aam and if rated by Moody's, having a rating by Moody's of Aaa, Aal or Aa2. 5. Certificates of deposit secured at all times by collateral described in (1) and/or (2) above. Such certificates must be issued by commercial banks, savings and loan associations or mutual savings banks. The collateral must be held by a third party and the Bondholders must have a perfected first security interest in the collateral. 6. Certificates of deposit, savings accounts, deposit accounts or money market deposits which are fully insured by the Federal Deposit Insurance Corporation. 7. Investment agreements acceptable to MBIA. 8. Commercial paper rated, at the time of purchase, "Prime-I" by Moody's and "A-I" or better by S&P. 9. Bonds or notes issued by any state or municipality which are rated by Moody's and S&P in one of the two highest rating categories assigned by such agencies. 10. Federal funds or bankers acceptances with a maximum tenn of one year of any bank which has an unsecured, uninsured and unguaranteed obligation rating of "Prime-I" or "A3" or better by Moody's and "A-I" or "A" or better by S&P. 11. Repurchase agreements for 30 days or less which satisfy the following criteria or which exceed 30 days as are otherwise approved by MBIA: 1. Entered into by the Agency or the Trustee, as applicable, with: a. Primary dealers on the Federal Reserve reporting dealer list which are rated A or better by S&P and Moody's. b. Banks rated "A" or above by S&P and Moody's. 2. The repurchase agreement includes the following: a. Securities which are acceptable for transfer are: (1) Direct U.S. government obligations, or 15 DOA: [04548.DOCS.MlA 180298)AUTH.RESO-J 1 , (2) Federal agencies backed by the full faith and credit of the U.S. government (and FNMA & FHLMC). b. The term of the repurchase may be up to 30 days. c. The collateral must be delivered to the Agency, the Trustee or a third party acting as agent simultaneous with payment (perfection by possession of certificated securities). d. Valuation of collateral: (1) The securities must be valued weekly marked-to- market at current market price plus accrued interest; and (2) The value of collateral must be equal to 104% of the amount of cash transferred by the Agency or the Trustee, as applicable, to the dealer bank or security firm plus accrued interest. If the value of securities held as collateral falls below 104% of the value of the cash transferred by the Agency or the Trustee, as applicable, then additional cash or acceptable securities must be transferred by the dealer bank or security firm. If, however, the securities used as collateral are FNMA or FHLMC, then the value of collateral must equal 105 %. 3. A legal opinion must be delivered to the Agency to the effect that the repurchase agreement meets guidelines under State of Florida law for legal investment of public funds. 12. Any State of Florida administered pool investment fund in which the City is statutorily permitted or required to invest. (f) Investments of moneys held under the Debt Service Reserve Account shall be valued at fair market value, marked to market at least once per year and have maturities not exceeding five (5) years except for investment agreements approved by MBIA. (g) The Trustee, the Paying Agent and the Registrar must each be a conunercial bank with trust powers. (h) The Agency shall provide MBIA notice of the resignation or removal of the Trustee, the Paying Agent or the Registrar and the appointment of a successor thereto. 16 DOA: [04548. DOCS. MIA 1802981A UTH-RESO-3 (i) MBIA shall receive copies of all notices required to be delivered to Bondholders of the Series 1998 Bonds under the Bond Resolution and, on an annual basis, copies of the Agency's audited financial statements and annual budget. (j) All notices required to be given to MBIA shall be in writing and shall be sent by registered or certified mail addressed as follows: MBIA Insurance Corporation 113 King Street Armonk, New York 10504 Attention: Insured Portfolio Management (k) The Trustee shall, not later than the third business day preceding each payment date on the Series 1998 Bonds, transfer from moneys on deposit in the applicable Accounts to the Paying Agent the amounts necessary to pay the principal of and interest on the Series 1998 Bonds. In the event that, on the second business day, and again on the business day, prior to the payment date on the Series 1998 Bonds, the Paying Agent has not received sufficient moneys to pay all principal of and interest on the Series 1998 Bonds due on the second following or following, as the case may be, business day, the Paying Agent shall immediately notify MBIA or its designee on the same business day by telephone or telecopy, confIrmed in writing by registered or certified mail, of the amount of the deficiency. If the deficiency is made up in whole or in part prior to or on the payment date, the Paying Agent shall so notify MBIA or its designee. In addition, if the Paying Agent has notice that any Bondholder has been required to disgorge payments of principal or interest on the Series 1998 Bonds to a trustee in bankruptcy or creditors or other pursuant to a final judgment by a court of competent jurisdiction that such payment constitutes a voidable preference to such Bondholder within the meaning of any applicable bankruptcy laws, then the Paying Agent shall notify MBIA or its designee of such fact by telephone or telegraphic notice, confIrmed in writing by registered or certified mail. (I) The Paying Agent is hereby irrevocably designated, appointed, directed and authorized to act as attorney-in-fact for Bondholders of the Series 1998 Bonds as follows: 1. If and to the extent there is a deficiency in amounts required to pay interest on the Series 1998 Bonds, the Paying Agent shall (a) execute and deliver to State Street Bank and Trust Company, N.A., or its successors under the Bond Insurance Policy (the "Insurance Paying Agent"), in form satisfactory to the Insurance Paying Agent, an instrument appointing MBIA as agent for such Bondholders in any legal proceeding related to the payment of such interest and an assignment to MBIA of the claims for interest to which such deficiency relates and which are paid by MBIA, (b) receive as designee of the respective Bondholders (and not as Paying 17 DOA; [04548.DOCS .MIA 180298]A UTH-RESO-3 Agent) in accordance with the tenor of the Series 1998 Bond Insurance Policy payment from the Insurance Paying Agent with respect to the claims for interest so assigned and (c) disburse the same to such respective bondholders; and 2. If and to the extent of a deficiency in amounts required to pay principal of the Series 1998 Bonds, the Paying Agent shall (a) execute and deliver to the Insurance Paying Agent in fonn satisfactory to the Insurance Paying Agent an instrument appointing MBIA as agent for such Bondholder in any legal proceeding relating to the payment of such principal and assignment to MBIA of any of the Series 1998 Bonds surrendered to the Insurance Paying Agent of so much of the principal amount thereof as has not previously been paid or for which moneys are not held by the Paying Agent and available for such payment (but such assignment shall be delivered only if payment from the Insurance Paying Agent is received), (b) receive as designee of the respective Bondholders (and not as Paying Agent) in accordance with the tenor of the Series 1998 Bond Insurance Policy payment therefor from the Insurance Paying Agent, and (c) disburse the same to such Bondholders. (m) Payments with respect to claims for interest on and principal of Series 1998 Bonds disbursed by the Paying Agent from proceeds of the Series 1998 Bond Insurance Policy shall not be considered to discharge the obligation of the Agency with respect to such Series 1998 Bonds, and MBIA shall become the owner of such unpaid Series 1998 Bonds and claims for the interest in accordance with the tensor of the assignment made to it under the provisions of this section or otherwise. (n) Irrespective of whether any such assigrunent is executed and delivered, the Agency, the Trustee, the Paying Agent and the Registrar hereby agree for the benefit of MBIA that: 1. They recognize that to the extent MBIA makes payments, directly or indirectly (as by paying through the Paying Agent), on account of principal of or interest on tlle Series 1998 Bonds, MBIA will be subrogated to the rights of such Bondholders to receive the amount of such principal and interest from the Agency, with interest thereon as provided and solely from the sources stated in the Bond Resolution and the Series 1998 Bonds; and I 2. They will accordingly pay to MBIA tlle amount of such principal and interest (including principal and interest recovered under subparagraph (ii) of the first paragraph of the Series 1998 Bond Insurance Policy, which principal and interest shall be deemed past due and not to have been paid), with interest thereon as provided in tlle Bond Resolution and the Series 1998 Bonds, but only from the sources and in the manner provided in the 18 DOA :(04548. DOCS.MIA 180298)AlJTH.RESO_J Bond Resolution for the payment of principal of and interest on the Series 1998 Bonds to Bondholders, and will otherwise treat MBIA as the owner of such rights to the amount of such principal and interest. Section 13. The Chainnan, based upon the recommendations of the Financial Advisor, is hereby authorized to determine to satisfy all or a portion of the Reserve Account Requirement with the deposit of the Series 1998 Reserve Policy to the credit of the Debt Service Reserve Account, to provide for the payment of the premium with respect thereto and, subject to the provisions of the Bond Resolution, to apply any moneys released from the Debt Service Reserve Account as a result of the deposit of the Series 1998 Reserve Policy therein, all as shall be provided in the Series 1998 Chairman's Certificate. The Commission hereby approves the form of a Financial Guaranty Agreement to be entered into between the Agency and MBIA to the extent the Series 1998 Reserve Policy is deposited to the credit of the Debt Service Reserve Account (the "Series 1998 Insurance Agreement"), a copy of which draft form of Series 1998 Insurance Agreement has been presented at the meeting at which this Series Resolution was considered. To the extent applicable, the Chainnan is hereby authorized to execute the Series 1998 Insurance Agreement in substantially the form presented at the meeting at which this Series Resolution was considered, subject to such changes, modifications, insertions and omissions and such filling-in of blanks therein as may be necessary to secure delivery of the Series 1998 Reserve Policy. The execution and delivery by the Chainnan of the Series 1998 Insurance Agreement for and on behalf of the Agency shall be conc!usive evidence of the Agency's approval of the Series 1998 Insurance Agreement. For so long as the Series 1998 Reserve Policy is in effect and MBIA has not defaulted in its obligations thereunder, and notwithstanding any provisions to the contrary contained in the Bond Resolution, the Agency, the Trustee, the Paying Agent, the Registrar and the Holders of 19 DOA :[04548 .DOCS.MIA 180298)A UTH-RESO-3 , . the Series 1998 Bonds, as applicable, covenant and agree, but solely for the benefit of MBIA, as follows: (a) A Reserve Account Insurance Policy or Reserve Account Letter of Credit ~ be limited to (i) those facilities issued by an insurance company rated in highest rating category by Moody's and S&P and, if rated by A.M. Best Company, rated in the highest rating category by A.M. Best & Company or (I such other facilities authorized under the Bond Resolution and approved b. MBIA. (b) Net Trust Fund Revenues shall be applied under the proVISIOns of Section 304(D)(3) of the Bond Resolution and Supplemental Revenues shall be applied under the provisions of the Supplemental Revenues Resolution first, to reimburse MBIA for any payments made under the Series 1998 Reserve Policy, thereby reinstating the Series 1998 Reserve Policy, and second, for deposit with the Trustee of any cash required to be deposited in the Debt Service Reserve Account after taking into account the amounts available under all Reserve Account Insurance Policies and/or Reserve Account Letters of Credit, including the Series 1998 Reserve Policy; provided, however, that if reimbursements are also due to issuers of other Reserve Account Insurance Policies or Reserve Account Letters of Credit, the reimbursements to MBIA and such other providers shall be paid on a pro-rata basis. (c) The Paying Agent shall deliver a "Demand for Payment" in the form attached to the Series 1998 Reserve Policy at least three days prior to the date on which funds are required. (d) The Paying Agent shall maintain adequate records, verified with MBIA, as to the amount available to be drawn at any given time under the Series 1998 Reserve Policy. In addition, so long as amounts are due and owing to MBIA under the Series 1998 Insurance Agreement, the Agency, the Trustee, the Paying Agent, the Registrar and the Holders of the Series 1998 Bonds, as applicable, covenant and agree, but solely for the benefit of MBIA, as follows: (a) The Agency hereby pledges and grants a lien upon the Pledged Funds, subordinate to the lien thereon granted for the benefit of Bondholders, Credit Providers and Liquidity Providers under the provisions of the Bond Resolution, in order to secure the Agency's payment obligations under the Series 1998 Insurance Agreement. Such payment obligations under the Series 1998 Insurance Agreement are junior, inferior and subordinate in all respects to the Bonds as to 20 [lOA :(04548. DOCS. MIA 180298JA UTH-RESO-J lien on and source and security for payment from the Pledged Funds and in all other respects. (b) The Bond Resolution shall not be discharged until all amounts due and payable to MBIA have been paid in full or provision for their payment in full has been made. (c) The Agency shall maintain adequate records, verified by MBIA, as to the amounts paid and owing to MBIA under the terms of the Series 1998 Insurance Agreement. (d) The Agency shall not optionally redeem any Bonds or apply Net Trust Fund Revenues pursuant to Section 304(0)(5) of the Bond Resolution, other than for the payments required in clauses (1) through (4) of said Section 304(D), unless the Agency is current in all of its payment obligations under the Series 1998 Insurance Agreement. Section 14. The officers, agents and employees of the Agency, Trustee, Registrar and Paying Agent are hereby authorized and directed to do all acts and things required of them by the provisions of the Series 1998 Bonds, the Bond Resolution, the Series 1998 Bond Purchase Agreement, the Series 1998 Continuing Disclosure Agreement, the Series 1998 Bond Insurance Policy, the Series 1998 Reserve Policy, the Series 1998 Insurance Agreement and this Resolution, for the full, punctual and complete performance of all the terms, covenants, provisions and agreements of the Series 1998 Bonds, the Bond Resolution, the Series 1998 Bond Purchase Agreement, the Series 1998 Continuing Disclosure Agreement, the Series 1998 Bond Insurance Policy, the Series 1998 Reserve Policy, the Series 1998 Insurance Agreement and this Resolution. 21 DOA: [04S48.DOCS.MIA 180298jAUTH-RESO-3 , , , . Section 15. This Resolution shall take effect immediately upon its adoption. PASSED AND ADOPTED this 1st day of July , 1998. wI Chainnan (Seal) Attest: /1 ! f '~! .f l" \.-L \' i i \, 1.., \ ' . Ii. iJ'- VI_,. APPROVED AS TO FORM & LANGUAGE & FOR EXECUTION Secretary ~q G~:)era' Counsel &!~!0g I Date 1 hereby certify that the above and aforegoing is a true copy of In witness thereof I set my hand and seal this day of 19 CITY CLERK BY - DEPUTY ( Seal) 22 DOA: [04548. DOCS. MIA 180298JA UTH-RESO-3 APPENDIX C CITY RESOLUTION NO. 94-21008 ~.,r,.v- JT " " [This page intentionally left blank] RESOLUTION NO. 94-21008 r' ~2:5-.:'z..,:77:-......t.; ':2 I"H~ ~Y~"'r\. lL.'-:- .:.:'r"! C~...'MM1S$-:'-..'N OF TilE CITY OF MIAMI BEACH, FLORIDA, REGARDING A CERTAIN GEOGRAPHIC AREA WITHIN THE CITY OF MIAMI BEl'.CH CALLED THE CITY CENTER/HISTORIC CONVENTION VILLAGr, REDEVELOPMENT AND REVITALI- ZATION AREA, DEbCRIBED GEN~RALLY AS BEING BOUNDED ON THE EAST BY THE ATJ.~TIC OCEAN, ON TilE NORTII BY 21TH STREET, ON ..HE WEST BY WEST AVENUE AND ON TilE SOUTH BY 11TH LANE; PLEDGING PROCEEDS OF THE RESORT TAX LEVIED BY THE CITY TO THE EXTENT PROVIDED HEREIN AND ON A BASIS SUBORDINl.TE TO CERTAIN OTHER OBLIGATIONS TO TilE PAYMENT OF THE MIAMI BEACH REDEVELOPMENT AGENCY TAX INCREMENT REVENUE BONDS, SERIES 1993 (CITY CENTER/HISTORIC CONVENTION VIL- LAGE) , TO BE ISSUED IN THE AGGREGATE PRINCIPAL AMOUNT OF NOT EXCEEDING $25,000,000; PROVIDING THE TERMS AND CONDITIONS UPON WHICH SUCH PLEDGE SHALL BE RELEASED AND EXTINGUISHED; AUTHORIZING THE ISSUANCE BY THE MIAMI BEACH REDEVELOPMENT AGENCY OF SAID TAX INCREMENT REVENUE BONDS, SERIES 1993 (CITY CENTER/ HISTORIC CONVENTION VILLAGE), IN ACCORDANCE WITII THE REQUIREMENTS OF CHAPTER 163, PART III, FLORIDA STATUTES, AS AMENDED; AND CONFIRMING THE DELEGATION TO THE MIAMI BEACH REDEVELOPMENT AGENCY OF ALL POWERS PERMITTED BY CHAPTER 163, PART III, FLORIDA STATUTES, AS }\HENDED, WIIICH WERE DELEGATED TO TilE CITY COMMISSION BY DADE COUNTY, FLORIDA. WIIEREAS, tile Miami Beach Redevelopment Agency (the "Agency") is issuin':J its Tax IncJ:ement R,.'venue Bonds, Series 1993 (City CenteJ:/llistodc Convention Village) (the "Series 1993 Bonds" and together with any additional bonds issued on a parity therewith under the pruvisions of the Bond Resolution (as defined below), the "Bonds"), in the aggl'egate principal amount of not exceeding $25,000,000, under tile provisions of a resolution adopted by the Agency on January 5, 1994 lthe "Bond Resolution"), a copy of which is attached lleJ:eto as Exhibit "A" and made a part hereof, for the purpose o[ pJ:oviding funds [or the acquisition, clearing and/or rehabilitation o[ certain property and the construction of certain public improvements (the "Series 1993 Redevelopment Project") in an aJ:ea of the City o[ Miami Beach, Florida (the "City") known as the "City Centel'/lIistoJ:ic Convention Village Redevelopment and Revitalization AJ:ea", all in accordance witll a redevelopment plan (the "Redevelopment Plan") adopted by the Agency under Chapter,163, Part III, Florida Statutes, as amended (tile "Act"), and approved by the City pursuant to Resolution No. 93'20721 adopted by the City on February 12, 1993; and WHEREAS, the Bonds will be pJ:imarily payable fromf,certClin Net Trust Fund Revenues (as defined in the Bond Resolution) received by the Agency pursuant to Section 163.387 of tile Act, Ordinance No. 93'2836 adopted by the City on February 21, 1993 and Ordinance No. 93,28 enacted by Dad~ County, Florida (tile "County") on April 27, 1933; and WHEREAS, the l1et "J'L'usL Fund Revenues initially will not be sufficient to pay th'2 pJ:insipal o[ and interest on the Bonds; anq WIIEREAS, because o[ Lhe importance of the Series 1993 Redevel- opment Project and the Redevelopment Plan to the economic develop- ment of the City. the City is willing, and desires to pl'ovide a supplemental SOUl'ce of funds to the Agency for tile payment of principal of and interest on tile Bonds, and to make certain other deposits lequil'ed in l'espect of the Bonds, and, in furtherance of this end, the City is willing and desires to pledge the Supple- mental Revenues (as defined herein) to the payment of the principal of and interest on the Bonds, and to make such other deposits as are required in respect of the Bonds, on the basis provided herein and in the Bond Resolution; and WHEREAS, the City desires to authorize and approve the issu- ance of the Series 1993 Bonds by the Agency, in accordance with the requirements of the Act; and WHEREAS, the City further desires to confirm the delegation to the Agency of all powers permitted by the Act which were delegated to the City by the County; NOW, THEREFORE, BE IT DULY RESOLVED 'BY THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA: SECTION 1. The foregoing recitations are deemed true and correct and are hereby incorporated as a part of this resolution. SECTION 2. This resolution is adopted pursuant to the Act and Chapter 166, Part II, Florida Statutes, as amended, and other applicable provisions of law. SECTION 3. In this resolution terms used as defined terms in the reci tals hereto shall have the same meaning throughout the resolution, terms used in capitalized form and not defined herein shall have the meanings ascribed to such terms in the Bond Resolu- tion and, in addition, the following terms shall have the meanings specified below: "Resort Tax Bond Resolution~ shall mean Resolution No. 88- 19369 adopted by the City on September 22, 1988 pursuant to which the City is authorized to issue revenue bonds secured by Resort Tax Revenues, as the same may be amended, substituted or modified from time to time. " "Supplemental Revenues" shall mean the Resort Tax Revenues available under Section 304(D) (4) of the Resort Tax Bond Resolution for the payment of subordinated obligations issued in accordance with Section 304(G) of the Resort Tax Bond Resolution. "Supplemental Revenues Bonds" shall mean any and all bonds issued by the City or other obligations incurred by the City (other than payment obligations under Section 5 hereof), from time to time, which are payable from, and are secured by a pledge and lien upon, the Supplemental Revenues on a parity with the City's payment obligations under Section 5 hereof and the pledge and lien granted under Section 6 hereof. SECTION 4. In consideration of the acceptance of the Bonds by those who shall own the same from time to time, this resolution shall be deemed to constitute a contract between the City and the owners of the Bonds, and the covenants and agreements herein set forth to be performed by the City shall be for the equal benefit, protection and security of the owners of any and all such Bonds, all of which shall be of equal rank and without preference, priority or distinction of any of the Bonds over any other thereof. SECTION 5. Upon receipt of notice from the Trustee in accor- dance with the provisions of Section 304(0) of the Bond Resolution as to a deficiency in the amounts required to be on deposit in any of the accounts established in the Sinking Fund, as provided in said Section 304 (D), the City shall, as provided below, transfer to the Trustee for deposit in the applicable accounts in the Sinking Fund Supplemental Revenues in an amount which, after the required transfers are completed as provided herein, shall be sufficient, together with the amounts then on deposit in each of the accounts in the Sinking Fund, to pay all interest and principal (including Amortization Requirements) payable on the Bonds during the then - 2 - I, I . current calendar year, as the same become due and payable, and to fund such deficiency in the Debt Service Reserve Account by the last day of such calendar year. The City shall make such transfers on a monthly basis on the sixteenth day of each month, commencing on February 16th, in such substantially equal amounts with respect to the deficiencies in each of such accounts in the Sinking Fund as shall cure any such deficiency (i) with respect to the Interest Account, the Principal Account and the Bond Redemption Account prior to the applicable Interest Payment Dates or principal payment dates and (ii) with respect to the Debt Service Reserve Account, by the last day of such calendar year. SECTION 6. As further security for the payment of the prin- cipal of and interest on the Bonds and the City's obligation to make the payments required under Section 5 hereof, the City hereby pledges and grants a lien on the Supplemental Revenues for the benefit of the holders of the Bonds. The City's obligation to make the payments required under Section 5 hereof and the pledge and lien granted under this Section 6 shall constitute a "subordinated obligation" under Section 304(G) of the Resort Tax Bond Resolution junior, inferior and subordinate in all respects to the revenue bonds issued by the City pursuant to the Resort Tax Bond Resolution as to lien on and source and security for payment from the Resort Tax Revenues and in all other respects. For purposes of Chapter 41, Article VI, Section 41-68 (e) (3) of the City Code and that certain Interlocal Agreement entered into between the County, the City, The City of Miami and the Village of Bal Harbour and the Greater Miami Convention and Visitors Bureau, establishing a uni- fied effort in the promotion and marketing of conventions and con- vention sales in the County, as each may be amended from time to time, the obligations of the City hereunder shall constitute indebtedness of the City secured by the Resort Tax entitled to priority over all payment obligations thereunder. SECTION 7. Notwithstanding anything to the contrary con- tained in this resolution, the City's obligation to transfer Sup- plemental Revenues to the Trustee .(Iereunder shall terminate and the pledge of and lien on the Supplemental Revenues in favor of the Bonds shall be released and extinguished upon the happening of the following events and conditions: (a) the Net Trust Fund Revenues (not including any portion thereof which may be attributable to investment earnings) for each of the immediately preceding two Fiscal Years, as certified by a certified public accountant in a certificate delivered to the Trustee, shall have been at least equal to one hundred seventy-five percent (175\) of the Maximum Annual Debt Service on all Bonds then Outstanding; and lb) the Agency shall have caused notice to the effect that the lien upon and pledge of the Supplemental Revenues to secure payment of the Bonds has been released and extinguished to be mailed to the registered owners of the Bonds, to each rating agency maintaining a rating on the Bonds and the issuer of any Credit Facility or Liquidity Facility. SECTION 8. The City does hereby covenant and agree that as long as the pledge and lien created hereunder shall be in effect it will not (i) repeal Chapter 41, Article V of the City Code pursuant to which the Resort Tax is levied, (ii) reduce the rate of the Resort Tax, (iii) amend, substitute or modify said City Code pro- visions or the Resort Tax Bond Resolution, in any manner so as to impair or adversely affect the power and obligation of the City to levy and collect the Resort Tax or the application of the Supple- mental Revenues, or (iv) issue additional revenue bonds pursuant to Section 3041H) lother than refunding bonds pursuant to Section 304(H) (3)) of the Resort Tax Bond Resolution, and the City shall be unconditionally and irrevocably obligated, as long as the pledge and lien created hereunder shall be in effect, to levy and collect ''''''I "1.1\"'~11.t\~""' '.. - 3 - , I I, the Resort Tax at not less than the rate now being levied by the City. The City does hereby further covenant and agree that as long as the pledge and lien created hereunder shall be in effect it will not issue or incur Supplemental Revenues Bonds after the issuance of the Series 1993 Bonds unless: (1) The Supplemental Revenues received by the City during the immediately preceding Fiscal Year, as certified by an independent certified public accountant, were at least equal to one hundred seventy-five percent (175%) of (A) the Maximum Annual Debt Service on (i) all Bonds issued and then Outstanding under the Bond Resolution, (ii) in accordance with the next succeeding paragraph, any Supplemental Revenues Bonds issued and then Outstanding and (iii) in accordance with the next succeeding paragraph, the additional Supplemental Revenues Bonds then proposed to be issued less (B) the Net Trust Revenues applied in such preceding Fiscal Year to the payment of principal of and interest on the Bonds. (2) The City need not comply with subparagraph (1) above in the issuance of Supplemental Revenues Bonds if and to the extent that the Supplemental Revenues Bonds to be issued are refunding Supplemental Revenues Bonds, that is, delivered in lieu of or in substitution for Supplemental Revenues Bonds previously issued, if the City causes to be delivered to the Trustee a certificate of the Finance Director of the City set- ting forth (i) the Maximum Annual Debt Service (A) with respect to the Bonds and, in accordance with the next succeed- ing paragraph, the Supplemental Revenues Bonds, in each case Outstanding immediately prior to the date of delivery of such refunding bonds and (B) with respect to the Bonds and, in accordance with the next succeeding paragraph, the Supple- mental Revenues Bonds, in each case to be Outstanding immedi- ately thereafter, and (ii) that the Maximum Annual Debt Ser- vice set forth pursuant to l"l!) above is no greater than that set forth pursuant to (A) above. For purposes of subparagraphs (1) and (2) above, Supplemental Revenues Bonds shall be deemed "Outstanding" and shall be included in "Debt Service Requirement" and "Maximum Annual Debt Service" therein based upon the same rules applicable to Bonds under the Bond Resolution. Nothing contained herein or otherwise shall restrict, prohibit or limit the ability or right of the City to issue bonds or incur other obligations payable for the Supplemental Revenues, or create or cause to be created debts, liens, pledges, assignments, encum- brances and other charges upon the Supplemental Revenues, which in each case are junior, inferior and subordinate in all respects to the Bonds and any Supplemental Revenues Bonds as to lien on and source and security for payment from the Supplemental Revenues and in all other respects. SECTION 9. In accordance with the requirements of Sections 163.358(3) and 163.385(1) and (3) of the Act, the issuance by the Agency of the Series 1993 Bonds, in the aggregate principal amount of not exceeding $25,000,000, under the provisions of the Bond Resolution, is hereby authorized and approved by the City Commis- sion of the City. SECTION 10. The City hereby confirms the delegation to the Agency of all powers permitted by the Act, which powers were delegated to the City by the County. SECTION 11. Nothing in this resolution shall be construed as constituting a pledge of the City's ad valorem taxing power or of its full faith and credit. The obligations of the City under - 4 - Sections 5 and 6 hereof shall be a limited obligation of the City payable solely from the Supplemental Revenues pledged hereunder. SECTION 12. The officers and employees of the City are hereby authorized and directed to take all other necessary actions and execute all necesary documents, including, without limitation, a letter of representation for the benefit of the Purchasers of the Series 1993 Bonds, to carry out the provisions of this resolution and provide for the issuance of the Bonds by the Agency. SECTION 13. This resolution shall become effec ive immedi- ately upon its adoption. /:7 A . \ ~'G~"\' 't City Clerk l.' tJ..r~' v~ PASSED AND ADOPTED this ~ lSEAL) ATTEST: ~ Date I hmby oer1iIY that lhc above and aforegoing is a bue copy of In wilncsS thl:mIC 1 set my band and &rAl! tbis~t3~~~' BY M.t~;Bwdan-,o . DEPUTY (Seal) I '''"'.'''''''\IU'H.".,"",U - 5 - EXHIBIT A BOND RESOLUTION See Resolution #150-94 in Appendix B - I, I . APPENDIX D CONTINUING DISCLOSURE AGREEMENT " [This page intentionally left blank] " I . CONTINUING DISCLOSURE AGREEMENT THIS CONTINUING DISCLOSURE AGREEMENT (the "Agreement") dated as of July 1, 1998, is made by and among the MIAMI BEACH REDEVELOPMENT AGENCY, a public body corporate and politic duly created and existing under the Constitution and laws of the State of Florida (the "Agency"), the CITY OF MIAMI BEACH, FLORIDA, a political subdivision duly organized and existing under the Constitution and laws of the State of Florida (the "City"), and FIRST UNION NATIONAL BANK, a national banking association duly organized and existing under the laws of the United States of America, with its principal place of business located in Miami, Florida, as trustee (the "Trustee"), under the circumstances summarized in the following recitals (each capitalized term used but not otherwise defined herein has the meaning assigned to it in Section 1 below or in the Resolution hereinafter defined): A. The Agency has determined to issue and sell the Bonds, and the Bonds will be issued pursuant to and secured by the Resolution. B. The Original Purchaser is required under the Rule to not purchase or sell the Bonds in a primary offering unless the Original Purchaser has reasonably determined that the Agency and the City have made an agreement in accordance with the provisions of the Rule. NOW, THEREFORE, in consideration of the recitals and the mutual representations and agreements hereinafter contained, the Agency, the City and the Trustee agree, in accord~nce with the provisions of the Rule, for the benefit of the holders and beneficial owners from time to time of the Bonds, as follows: Section 1. Definitions and Interpretation. In addition to the words and terms defined elsewhere in this Agreement or by reference to the Resolution, unless the context or use clearly indicates another or different meaning or intent: "Accounting Principles" means the accounting principles applied from time to time in the preparation of each of the Obligated Person's annual financial statements, initially generally accepted accounting principles as recommended from time to time by the Governmental Accounting Standards Board of the American Institute of Certified Public Accountants. "Agency Annual Information" means financial informatiOI~ and operating data to be provided by the Agency for each Fiscal Year as follows: information appearing in the Official Statement in the table under the caption "ESTIMATED DEBT SERVICE COVERAGE" and in the table entitled "Miami Beach Redevelopment Agency Historical Taxable Real Property and Tax Increment Revenues City Center Historic Convention Village," the release of the pledge of Supplemental Revenues and issuance of additional debt payable from the Pledged Funds. "Annual Information" means (i) with respect to the Agency, the Agency Annual Information and (ii) with respect to the City, the City Annual Information. "Authorized Disclosure Representative" means (i) with respect to the Agency, the Executive Director of the Agency and (ii) with respect to the City, the Finance Director, or, in , , either case, any other person or persons at the time designated to act on behalf of such Obligated Person by written certificate furnished to the Trustee, containing the specimen signature of such person or persons and signed on behalf of the Agency by the Executive Director or on behalf of the City by the Finance Director. That certificate may designate an alternate or alternates, each of whom shall have the same authority, duties and powers as such Authorized Disclosure Representative. "Bonds" means collectively, the $29,105,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Taxable Series 1998A (City Center/Historic Convention Village), and $9,135,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds, Series 1998B (City Center/Historic Cunvention Village), each dated as of July 1, 1998. "Business Day" means any day other than a Saturday, Sunday or a day on which the Trustee is required, or authorized or not prohibited by law (including executive orders), to close and is closed. "City Annual Information" means financial information to be provided by the City for each Fiscal Year as follows: Resort Tax Revenues and Supplemental Revenues, issuance of additional debt payable form the Resort Tax Revenues or Supplemental Revenues and changes in the Resort Tax with respect to the percentage rate imposed or the exemptions therefrom. "Filing Date" means, with respect to each Obligated Person, the 240th day following the end of each Fiscal Year of such Obligated Person (or the next preceding Business Day if that day is not a Business Day). "Fiscal Year" means the fiscal year of each Obligated Person ending on or after September 30, 1998. "Holder" has the meaning assigned to it in the Resolution. "MSRB" means the Municipal Securities Rulemaking Board. "NRMSIR" means each nationally recognized municipal securities information repository designated from time to time by the SEC in accordance with the Rule. "Notice Addresses": As to the Trustee: First Union National Bank First Union Financial Center 200 South Biscayne Boulevard Miami, Florida 33131 Attention: Corporate Trust Department Telephone No.: (305) 789-4682 Facsimile No.: (305) 789-4678 2 As to the Agency: Miami Beach Redevelopment Agency 1700 Convention Center Drive Miami Beach, Florida 33139 Attention: Executive Director Telephone No.: (305) 673-7010 Facsimile No.: (305) 673-7782 As to the City: City of Miami Beach, Florida 1700 Convention Center Drive Miami Beach, Florida 33139 Attention: Finance Director Telephone No.: (305) 673-7466 Facsimile No.: (305) 673-7795 "Obligated Person" means the Agency or the City, as applicable. "Obligated Persons" means collectively, the Agency and the City. "Official Statement" means the Official Statement dated July 22, 1998 relating to the Bonds. "Original Purchaser" means collectively, PaineWebber Incorporated, Prudential Securities Incorporated and William R. Hough & Co. . "Resolution" means collectively, Resolution No. 150-94, adopted by the Agency on January 5, 1994, as supplemented by Resolution No. 297-98, adopted by the Agency on July 1, 1998, and as further supplemented and amended from time to time, and Resolution No. 94- 21008, adopted by the City on January 5, 1994, as supplemented by Resolution No. 98-22820, adopted by the City on July 1, 1998, and as further supplemented and amended from time to time. . "Rule" means Rule 15c2-12 promulgated by the SEC pursuant to the Securities Exchange Act of 1934. " "SEC" means the Securities and Exchange Commission. "Specified Events" means the occurrence of any of the following events, within the meaning of the Rule, with respect to the Bonds: principal and interest payment delinquencies; non-payment related defaults; unscheduled draws on the Debt Service Reserve Account reflecting financial difficulties; unscheduled draws on credit enhancements reflecting financial difficulties; substitution of credit or liquidity providers, or their failure to perfonn; adverse tax opinions or events affecting the tax-exempt status of the Bonds; modifications to rights of Holders or 3 " " beneficial owners; bond calls; defeasances; release, substitution, or sale of property securing repayment of the Bonds; and rating changes. "SID" means the state information depository, if any, designated by the State of Florida and with which filings are required to be made by the Obligated Person in accordance with the Rule. The captions and headings in this Agreement are solely for convenience of reference and in no way derme, limit or describe the scope or intent of any Sections, subsections, paragraphs, subparagraphs or clauses hereof. Reference to a Section means a section of this Agreement and to an Exhibit means an exhibit to this Agreement, unless otherwise indicated. ~'ir ...~. Section 2. Provision of Annual Information: Audited Financial Statements. (a) Each Obligated Person hereby agrees to provide or cause to be provided to each NRMSIR, to any SID and to the Trustee, (i) its Annual Information for the preceding Fiscal Year not later than the Filing Date for that Fiscal Year; and (ii) when and if available, audited financial statements of such Obligated Person for each Fiscal Year prepared in accordance with the Accounting Principles. Each Obligated Person expects that audited annual financial statements of such Obligated Person wiIl be prepared and will be available together with its Annual Information. (b) Each Obligated Person expects that its Annual Information will be provided directly by such Obligated Person or through the other Obligated Person as its designated agent. (c) If the Trustee has not received the Annual Information for a Fiscal Year by its close of business on the fifteenth Business Day preceding the Filing Date for that Fiscal Year, the Trustee shall provide a notice to the applicable Authorized Disclosure Representative, not later than its close of business on the next Business Day, substantially in the form of Exhibit A, by facsimile transmission (or other means similarly prompt) and by certified or registered mail, postage prepaid, return receipt requested. If the Trustee has not received that Annual Information by its close of business on the Filing Date, the Trustee shall provide a notice to the applicable Authorized Disclosure Representative, not later than its close of business on the next Business Day, substantially in the form of Exhibit B, by facsimile transmission (or other means similarly prompt). The applicable Obligated Person shall be entitled to provide written evidence of the submission of the Annual Information in accordance with subsection 2(a)(i), including a certificate of the Authorized Disclosure Representative as to the relevant facts, and, if applicable, a written statement regarding any failure to comply with subsection 2(a)(i). The Trustee shall be entitled to rely conclusively upon any written evidence provided by the Obligated Person regarding the provision of that information to any NRMSIR or SID. If, in any instance, the required information was not timely filed or the Obligated Person fails to provide evidence, by 3:00 p.m., eastern time, on the second Business Day following the Filing Date, of its timely 4 filing with each NRMSIR and any SID, the Trustee shall send or cause to be sent promptly after receipt of any such evidence or statement from the Obligated Person, but in any event not later than its close of business on the second Business Day following the Filing Date, a notice substantiaUy in the form of Exhibit C, modified to reflect the pertinent facts, to each NRMSIR or to the MSRB, and to any SID by facsimile transmission (or other means similarly prompt). Section 3. Notice of Specified Events: Changes in AccountinlZ Principles or Fiscal Year. (a) The Agency, with respect to (i) below, and each Obligated Person, as applicable, with respect to (ii) and (iii) below, agrees to provide or cause to be provided to each NRMSIR or to the MSRB, and to the Trustee and to any SID, in a timely manner, (i) notice of any Specified Event, if that Event is material, (ii) in the manner described in subsection 2(c), notice of its failure to provide or cause to be provided the Annual Information on or prior to the Filing Date, and (iii) notice of any change in the Accounting Principles applied in the preparation of the annual financial statements of such Obligated Person or any change in the dates on which the Fiscal Year of such Obligated Person begins and ends. (b) The Trustee shall promptly notify each Authorized Disclosure Representative upon becoming aware of the occurrence of any Specified Event (other than the giving of a notice of optional redemption of any Bonds or defeasance of the Bonds). (c) If the Agency becomes aware of a Specified Event that is material, the Agency shall provide or cause to be provided notice of that Event in accordance with subsection 3(a). (d) The Trustee shall mail to each Holder, by first class mail, postage prepaid, a copy of any notice that is filed with it by an Obligated Person in accordance with subsection 3(a). Section 4. OblilZated Persons: Dissemination Agent. The Obligated Persons represent that they will be the only obligated persons with respect to the Bonds at the time the Bonds are delivered by the Agency to the Original Purchaser and that no other person is expected to become so committed at any time after issuance of the Bonds. Either Obligated Person or the Trustee may, from time to time, appoint or engage an agent to act on its behalf in performing its obligations under this Agreement and may discharge any such agent, with or without appointing a successor; provided, that neither the Obligated Persons nor the Trustee shall be relieved in any respect by appointment of an agent from primary liability for the performance of their obligations under this Agreement. Section 5. Remedy for Breach. This Agreement shall be solely for the benefit of the holders and beneficial owners from time to time of the Bonds. The exclusive remedy for any breach of this Agreement by an Obligated Person shall be limited, to the extent permitted by law, to a right of holders and beneficial owners, or the Trustee, to institute and maintain, or to cause to be instituted and maintained, such proceedings in Miami-Dade County, Florida as may be authorized at law or in equity to obtain the specific performance by such Obligated Person of its obligations under this Agreement. The Trustee may exercise any such right and, if requested to do so by the Holders of at least 25 % in aggregate principal amount of the Bonds then outstanding, subject to the same conditions, limitations and procedures that would apply 5 I, I . under the Resolution, the Trustee shall exercise any such right. Any holder or beneficial owner may exercise any such right; provided that, except in the instance of an alleged failure of an Obligated Person to provide or cause to be provided a pertinent filing if such a filing is due and has not been made, any such right shall be exercised in the same manner and subject to the same conditions and limitations that would apply under the Resolution. Holders and beneficial owners shall not be entitled to institute or maintain any such proceedings individually that assert a breach of this Agreement that is based on the alleged inadequacy of any pertinent filing that has been made. Section 6. Perfonnance by the Trustee: Compensation. (a) Solely for the purpose of (i) defining the standards of care and performance applicable to the Trustee in the performance of its obligations under this Agreement, (ii) the manner of execution by the Trustee of those obligations, (iii) defining the manner in which, and the conditions under which, the Trustee may be required to take any action at the direction of Holders, including the condition that indemnification be provided, and (iv) matters of removal, resignation and succession of the Trustee under this Agreement, the Resolution is hereby made applicable to this Agreement as if this Agreement were contained in the Resolution; provided that the Trustee shall have only such duties under this Agreement as are specifically set forth. in this Agreement. (b) Subject to Section 9, the Obligated Persons agree to pay to the Trustee from time to time reasonable compensation for services provided by the Trustee under this Agreement and to payor reimburse the Trustee upon request for all reasonable expenses, disbursements and advances incurred or made in accordance with this Agreement (including the reasonable compensation and the expenses and disbursements of its counsel and of all agents and other persons regularly in its employ), except to the extent that any such expense, disbursement or advance is due to the negligence or bad faith of the Trustee. (c) The obligations of the Obligated Persons under this Section shall survive resignation or removal of the Trustee and termination of other provisions of this Agreement pursuant to Section 8. (d) The Trustee is a party to this Agreement for and on behalf of the holders and beneficial owners of the Bonds and shall not be considered to be the agent of the Obligated Persons when performing any actions required to be taken by the Trustee under this Agreement. (e) The Trustee shall not have any obligation under this Agreement to investigate or determine whether any filing made under this Agreement complies with federal securities laws or rules. Section 7. Amendment: Waiver. This Agreement may be amended, and noncompliance with any provision of this Agreement may be waived, as may be necessary or appropriate to achieve its compliance with any applicable federal securities law or rule, to cure any ambiguity, inconsistency or formal defect or omission, and to address any change in circumstances arising from a change in legal requirements, change in law, or change in the identity, nature, or status 6 of the Obligated Persons, or either of them, or type of business conducted by the Obligated Persons, or either of them. Any such amendment or waiver shall not be effective unless the Agreement (as amended or taking into account such waiver) would have complied with the requirements of the Rule at the time of the primary offering of the Bonds, after taking into account any applicable amendments to or official interpretations of the Rule, as well as any change in circumstances, and until the Obligated Persons and the Trustee shall have received either (a) a written opinion of bond or other qualified independent special counsel selected by the Agency, or determination by the Trustee, that the amendment or waiver would not materially impair the interests of holders or beneficial owners, or (b) the written consent to the amendment or waiver of the Holders of at least a majority of the principal amount of the Bonds then outstanding. Annual Information containing any revised operating data or financial information shall explain, in narrative form, the reasons for any such amendment or waiver and the impact of the change on the type of operating data or financial information being provided. Section 8. Term. The obligations of each Obligated Person under this Agreement shall remain in effect only for such period that (i) the Bonds are outstanding in accordance with their terms and (ii) such Obligated Person remains an "obligated person" with respect to the Bonds within the meaning of the Rule, subject to the survival of certain provisions to the extent expressly provided in Section 6. The obligation of each Obligated Person to provide the Annual. Information and notices of events set forth in subsection 3(a) shall terminate, if and when such Obligated Person no longer remains an "obligated person" with respect to the Bonds, provided such Obligated Person shall provide notice of such termination to each NRMSIR, the MSRB, any SID and the Trustee. Section 9. Sources of Payments: Extent of Covenants: No Personal Liability. The Agency shall be required to use only Trust Fund Revenues (as defined in the Resolution) and the City shall be required to use only Supplemental Revenues (as defined in the Resolution) to pay any costs and expenses to be incurred in the performance of this Agreement, and the performance of the obligations hereunder shall be subject to the availability of Trust Fund Revenues and Supplemental Revenues, as applicable, for that purpose. This Agreement does not and shall not constitute a general obligation of the Agency or the City. All covenants, stipulations, obligations and agreements of the Obligated Persons contained in this Agreement are and shall be deemed to be covenants, stipulations, obligations and agreements of the Obligated Persons to the full extent authorized by law. No covenant, stipulation, obligation or agreement of the Obligated Persons contained in this Agreement shall be deemed to be a covenant, stipulation, obligation or agreement of any present or future officer, agent or employee of the Obligated Persons in other than that person's official capacity. Section 10. Notices. Except as otherwise expressly provided in this Agreement, it shall be sufficient service or giving of any notice, if that notice is either mailed by first class mail, postage prepaid, addressed to the relevant party at its Notice Address, or transmitted by facsimile transmission addressed to the relevant party at its number for receipt of facsimile transmissions set forth in its Notice Address. The Obligated Persons and the Trustee may designate from time to time, by notice given hereunder,. any further or different addresses (including facsimile transmission numbers) to which any subsequent notice shall be sent. 7 f I 'I Section 11. Beneficiaries. This Agreement shall inure solely to the benefit of the Obligated Persons, the Trustee and the holders and beneficial owners from time to time of the Bonds, and any official, employee or agent thereof acting for and on its behalf, and shall not create any rights in any other person or entity. Section 12. Severability. In case any section or provision of this Agreement, or any covenant, stipulation, obligation, agreement, act or action, or part thereof made, assumed, entered into, or taken thereunder or any application thereof, is for any reason held to be illegal or invalid, such illegality or invalidity shall not affect the remainder thereof or any other section or provision thereof or any other covenant, stipulation, obligation, agreement, act or action, or part thereof made, assumed, entered into, or taken thereunder (except to the extent that such remainder or section or provision or other covenant, stipulation, obligation, agreement, act or action, or part thereof is wholly dependent for its operation on the provision determined to be invalid), which shall be construed and enforced as if such illegal or invalid portion were not contained therein, nor shall such illegality or invalidity of any application thereof affect any legal and valid application thereof, and each such section, provision, covenant, stipulation, obligation, agreement, act or action, or part thereof shall be deemed to be effective, operative, made, entered into or taken in the manner and to the full extent permitted by law. Section 13. Counterparts. This Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. 8 I I \ \ \ Section 14. Governing Law. This Agreement shall be deemed to be an agreement made under the laws of the State of Florida and for all purposes shall be governed by and construed in accordance with the laws of the State of Florida. IN WITNESS WHEREOF, the Agency, the City and the Trustee have caused this Agreement to be duly executed in their respective names, all as of the date set forth above. MIAMI BEACH REDEVELOPMENT AGENCY By: Executive Director CITY OF MIAMI BEACH, FLORIDA By: Finance Director FIRST UNION NATIONAL BANK, as Trustee By: Authorized Officer 9 t I I. EXHIBIT A MIAMI BEACH REDEVELOPMENT AGENCY $29,105,000 TAX INCREMENT REVENUE BONDS, TAXABLE SERIES 1998A (CITY CENTER/HISTORIC CONVENTION VILLAGE) and $9,135,000 TAX INCREMENT REVENUE BONDS, SERIES 1998B (CITY CENTER/HISTORIC CONVENTION VILLAGE) NOTICE TO OBLIGATED PERSON OF FAILURE TO FILE ANNUAL INFORMATION TO: [Authorized Disclosure Representative], [Obligated Person] The undersigned, as the trustee with respect to the captioned bonds (the "Bonds"), and serving in that capacity under the Continuing Disclosure Agreement dated as of July 1, 1998 (the "Agreement"), among the undersigned and the Miami Beach Redevelopment Agency and the City of Miami Beach, Florida (each an "Obligated Person") hereby notifies you (with each capitalized term used but not defined herein having the meaning assigned to it in the Agreement), that you, as an Obligated Person, as of the date of this notice, have not provided or caused to be provided to the undersigned the Annual Information that is required under the Agreement to be so provided not later than . The Annual Information is required under the Agreement to be provided both to the undersigned and to each NRMSIR and any SID not later than that date. FIRST UNION NATIONAL BANK, as Trustee Dated: By: Title: A-I EXHIBIT B MIAMI BEACH REDEVELOPMENT AGENCY $29,105,000 TAX INCREMENT REVENUE BONDS, TAXABLE SERIES 1998A (CITY CENTER/IDSTORIC CONVENTION VILLAGE) and $9,135,000 TAX INCREMENT REVENUE BONDS, SERIES 1998B (CITY CENTERlIDSTORIC CONVENTION VILLAGE) SECOND NOTICE TO OBLIGATED PERSON OF FAILURE TO FILE ANNuAL INFORMATION TO: [Authorized Disclo~ure Representative], [Obligated Person] The undersigned, as the trustee with respect to the captioned bonds (the "Bonds"); . and serving in that capacity under the Continuing Disclosure Agreement dated as of July 1, 1998 (the "Agreement"), among the undersigned and the Miami Beach Redevelopment Agency and the City of Miami Beach, Rorida (each an "Obligated Person"), hereby notifies you (with each capitalized tenn used but not defined herein having the meaning assigned to it in the Agreement), that you, as an Obligated Person, as of the date of this notice, have not provided to the undersigned the Annual Information that was required under the Agreement to be so provided not Jater than Please provide the required Annual Infonnation to the undersigned, together with written evidence as to whether that infonnation has been provided to each NRMSIR and any SID and, if so, when it was provided. If, in any instance, the Annual Information was not timely provided to a NRMSIR or any SID in accordance with subsection 2(a)(i) of the Agreement, you may submit a written statement regarding the Obligated Person's failure to comply that would be provided to each NRMSIR or to the MSRB, and to any SIp with the notice that the undersigned mnst give of that failure to comply under subsection 2(c) of the Agreement. Any such written evidence or statement must be received by the undersigned not later than 3: 00 p. m. , eastern time, on . If the undersigned has not received written evidence by that time that a timely filing was made, a notice wiJJ be filed promptly thereafter with each NRMSIR or the MSRB, and any SID, substantially in the form attached as Exhibit C to the Agreement. FIRST UNION NATIONAL BANK, as Trustee Dated: By: Title: B-1 t. I, EXHIBIT C MIAMI BEACH REDEVELOPMENT AGENCY $29,105,000 TAX INCREMENT REVENUE BONDS, TAXABLE SERIES 1998A (CITY CENTER/HISTORIC CONVENTION VILLAGE) and $9,135,000 TAX INCREMENT REVENUE BONDS, SERIES 1998B (CITY CENTER/HISTORIC CONVENTION VILLAGE) NOTICE TO REPOSITORIES[, MSRB AND] [SID] OF FAILURE TO [TIMELY] FILE ANNUAL INFORMATION TO: [NRMSIRs or MSRB, SID] The undersigned, as the trustee with respect to the captioned bonds (the "Bonds"), an~ serving in that capacity under the Continuing Disclosure Agreement dated as of July 1, 1998 (the " Agreement"), among the undersigned and the Miami Beach Redevelopment Agency and the City of Miami Beach, Florida (each an "Obligated Person"), hereby notifies you (with each capitalized term used but not defined herein having the meaning assigned to it in the Agreement), that: [1. , as an Obligated Person, as of the date of this notice, has not provided or caused to be provided to the Trustee the Annual Information for its Fiscal Year that ended " and has not provided any written evidence to the Trustee concerning the timeliness of its filing of that Annual Information with each NRMSIR and any SID. That Annual Information was required under the Agreement to be provided to the Trustee, each NRMSIR and any SID not later than ] [1. , as an Obligated Person provided or caused to be provided the Annual Information that was required to be provided to each NRMSIR and any SID not later than , to [ ] on ]. [2. , as an Obligated Person has provided the attached statement concerning its failure to provide or cause to be provided the Annual Information in accordance with the Agreement. The Trustee does not assume any responsibility for the accuracy or completeness of that statement and has not undertaken, and will not undertake, any investigation to determine its accuracy or completeness.] FIRST UNION NATIONAL BANK, as Trustee Dated: By: Title: cc: [Authorized Disclosure Representative, Obligated Person] C-l ... . ~.,~......- ........... -,r. . 'qJ APPENDIX E FORM OF BOND COUNSEL OPINION " [This page intentionally left blank] I~;.i, . t. I. " FORM OF APPROVING OPINION OF BOND COUNSEL , 1998 Miami Beach Redevelopment Agency Miami Beach, Florida Ladies and Gentlemen: We have examined the Constitution and laws of the State of Florida, particularly the Florida Community Redevelopment Act, codified as Chapter 163, Part III, Florida Statutes, as amended (the "Redevelopment Act"), the Municipal Home Rule Powers Act, codified as Chapter 166, Florida Statutes, as amended, the Taxable Bond Act of 1987, codified as Chapt~r 159, Part VII, Florida Statutes, as amended, Chapter 67-930, Laws of Florida, Acts of 1967, as amended (the "Resort Tax Act"), the Charter of the City of Miami Beach, Florida (the "City"), as amended, Ordinance No. 93-2836 adopted by the Mayor and City Commissioners (the "City Commission") of the City on February 24,1993, and Ordinance No. 93-28 enacted by the Board of County Commissioners of Miami-Dade County, Florida (the "County") on April 27, 1993 (COllectively, the "Act"), Resolution No. 150-94 adopted by the Chairman and Members (the "Commission") of the Miami Beach Redevelopment Agency (the "Agency") on January 5, 1994 (the "General Resolution"), as supplemented by Resolution No. 297-98 adopted by the Commission on July 1, 1998 (the "Series Resolution" and together with the General Resolution, the "Bond Resolution") and Resolution No. 94-21008 adopted by the City Commission on January 5, 1994, as supplemented by Resolution No. 98-22820 adopted by the City Commission on July 1, 1998 (collectively, the "Supplemental Revenues Resolution") and other proofs submitted, relative to the issuance and sale of " $29,105,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds Taxable Series 1998A (City Center/Historic Convention Village) (the "Series 1998A Bonds") and {! '. Miami Beach Redevelopment Agency , 1998 Page 2 $9,135,000 Miami Beach Redevelopment Agency Tax Increment Revenue Bonds Series 1998B (City Center/Historic Convention Village) (the "Series 1998B Bonds") issued on the date hereof (collectively, the "Series 1998 Bonds"). The Series 1998 Bonds mature in such amounts and at such times, bear interest at such rates and are subject to redemption, all as described in a certificate of the Chairman of the Agency, dated July 22, 1998 delivered in connection with the issuance of the Series 1998 Bonds. The Series 1998 Bonds are being issued to finance the acquisition and clearing of certain property and the development and construction of certain capital improvements as described in the Series Resolution (collectively, the "Series 1998 Project") in an area of the City designated as a "redevelopment area" pursuant to the Redevelopment Act and known as the "City Center/Historic Convention Village Redevelopment and Revitalization Area". (the "Redevelopment Area"). As to questions of fact material to our opinion, we have relied upon such certified proceedings and other certifications of public officials furnished to us without undertaking to verify the same by independent investigation. We have also examined one of the Series 1998 Bonds as executed and authenticated. We assume that all other Series 1998 Bonds have been similarly executed and authenticated. Based on the foregoing, we are of the opinion that: 1. Such proceedings and proofs show lawful authority for the issuance and sale of the Series 1998 Bonds by the Agency pursuant to the Act. 2. The Bond Resolution has been duly adopted by the Commission and constitutes a legal, valid and binding obligation of the Agency enforceable in accordance with its terms. 3. The Supplemental Revenues Resolution has been duly adopted by the City Commission and constitutes a legal, valid and binding obligation of the City enforceable in accordance with its terms. Miami Beach Redevelopment Agency , 1998 Page 3 4. The Series 1998 Bonds have been duly authorized, executed and delivered under the provisions of the Bond Resolution to finance the Series 1998 Project. 5. The Series 1998 Bonds are legal, valid and binding special obligations of the Agency enforceable in accordance with their terms and payable solely from the funds pledged therefor under the Bond Resolution and, to the extent and on the basis provided therein, from the funds pledged therefor under the Supplemental Revenues Resolution. The Agency has covenanted in the Bond Resolution to deposit into a redevelopment trust fund established with respect to the Redevelopment Area pursuant to the Redevelopment Act all revenues required to be paid to the Agency by the County and the City under the Redevelopment Act as the same are received and has pledged (i) a portion of said revenues as set forth in the Bond Resolution (the "Net Trust Fund Revenues"), (ii) for so long as the City is obligated pursuant to the Supplemental Revenues Resolution to transfer Supplemental Revenues (as defined below) for deposit under the Bond Resolution, the Supplemental Revenues received by First Union National Bank, as trustee (the "Trustee") under the Bond Resolution and (Hi) all moneys, securities and instruments held in the funds and accounts established under the Bond Resolution (other than,the Rebate Fund) to the payment of the principal of, premium, if any and interest on all Bonds (as defined in the General Resolution), including the Series 1998 Bonds. The City has covenanted in the Supplemental Revenues Resolution that upon the occurrence of certain shortfalls in the Net Trust Fund Revenues deposited in the Sinking Fund established under the Bond Resolution, the City will transfer to the Trustee for deposit in the Sinking Fund sufficient revenues, to the extent available and as provided in the Supplemental Revenues Resolution, from the proceeds of the municipal resort tax (the "Resort Tax Revenues") imposed, levied and collected by the City pursuant to the Resort Tax Act, the Charter of the City, as amended, and Chapter 41, Article V of the Code of the City, as amended, which are available for the payment of subordinated obligations under Resolution No. 88-19369 adopted by the City Commission on September 22, 1988, as supplemented by Resolution No. 96-21957 adopted by the City Commission on April 17, 1996 (collectively, the "Resort Tax Bond Resolution") (such available portion of the Resort Tax Revenues referred to as the "Supplemental Revenues"), to make up such shortfalls and has pledged such Supplemental Revenues for such purpose in the Supplemental Revenues Resolution. The pledge thereunder is subordinate to the pledge of the Resort Tax Revenues for the benefit of the outstanding City of Miami Beach, Florida Resort Tax Revenue Refunding Bonds, Series 1996, issued under the Resort Tax Bond Resolution and on a parity with certain other obligations secured by the City under the Supplemental Revenues Resolution, including other Bonds. The pledge of the Supplemental Revenues terminates upon the occurrence of certain' events as described in the Supplemental Revenues Resolution. The full faith and credit of the Agency, the City, the County or the State I, " Miami Beach Redevelopment Agency , 1998 Page 4 of Florida (the "State ") is not pledged to the payment of the principal of, premium, if any, and interest on the Series 1998 Bonds and neither the Agency, the City, the County nor the State is obligated to levy any taxes (other than with respect to the Supplemental Revenues as provided in tlll:; Supplemental Revenues Resolution) for the payment thereof. 6. The interest on the Series 1998B Bonds is excluded from gross income for federal income tax purposes under Section 103(a) of the Internal Revenue Code of 1986, as amended (the "Code"), and is not an item of tax preference under Section 57 of the Code for purposes of the alternative minimum tax imposed on individuals and corporations. The Series 1998 Bonds and the income thereon are exempt from taxation under the laws of the State of Florida, except for estate taxes imposed by Chapter 198, Florida Statutes, as amended, and net income and franchise taxes imposed by Chapter 220, Florida Statutes, as amended, on interest, income or profits on debt obligations owned by "corporations," "banks" and "savings associations, 1I as such terms are defined in said Chapter 220. We express no opinion as to other tax consequences regarding the Series 1998 Bonds. Interest on the Series 1998A Bonds is includable in gross income of the holders thereof for federal income tax purposes. No attempt has been made or will be made to comply with certain requirements relating to the exclusion from gross income for federal income tax purposes of interest on the Series 1998A Bonds. Under the Code, portions of the interest on the Series 1998B Bonds earned by certain corporations (as defined for federal income tax purposes) may be subject to a corporate alternative minimum tax and interest on the Series 1998B Bonds may be subject to a branch profits tax imposed on certain foreign corporations doing business in the United States and to a tax imposed on excess net passive income of certain S corporations. In giving the foregoing opinion with respect to the treatment of interest on the Series 1998B Bonds and the status of the Series 1998B Bonds under the federal tax laws, we have assumed and relied upon compliance with the covenants of the Agency and the accuracy, which we have not independently verified, of the representations and certifications of the Agency contained in the proceedings relating to the Series 1998 Bonds. The accuracy of celia in of those representations and certifications, and compliance by the Agency with certain of those covenants, may be necessary for the interest on the Series 1998B Bonds to be and to remain excluded from gross income for federal income tax purposes. Failure to comply with certain requirements with respect to the Series 1998B Bonds subsequent to issuance could cause the interest on the Series 1998B Bonds to be included in gross income for federal income tax purposes retroactively to their date of issuance. Miami Beach Redevelopment Agency , 1998 Page 5 It is to be understood that the rights of the holders of the Series 1998 Bonds and the enforceability thereof and of the Bond Resolution and the Supplemental Revenues Resolution may be subject to bankruptcy, insolvency, reorganization, moratorium or other similar laws affecting creditors' rights heretofore or hereinafter enacted and that their enforcement may be subject to the exercise of judicial discretion in accordance with general principles of equity. We express no opinion as the statement of insurance printed on the Series 1998 Bonds referring to the financial guaranty insurance policies issued by MBIA Insurance Corporation or as to that insurance referenced in the statement of insurance. Respectfully submitted, ( . '. [This page intentionally left blank] APPENDIX F SPECIMEN MUNCIPAL BOND INSURANCE POLICY . r, . [This page intentionally left blank] MBIA FINANCIAL GUARANTY INSURANCE POLICY MBIA Insurance Corporation Armonk, New York 10504 Policy No. Ml3IA Insurance Corporation (the "Insurer"), in consideration of the payment of the premium and sul~ject to the tel1llS of this policy, hereby unconditionally and ilTevocably guarantees to any owner, as hereinaller defined, of the following described obligations, the full ,Uld complete payment required to be made by or on behalfoftlle Issuer to or its successor (the "Paying Agent") ofilll amount equal to (i) the principal of (either at the stated maturity or by illlY adv,Ulcement of maturity pursuant to a m,UldatolY sinking fund payment) and interest on, the Obligations (as tJlat tenll is defined below) as such payments shall become due but shall not be so paid (except that in tJle event of illlY acceleration of the due date of such principal by reason of millldatory or optional redemption or acceleration resulting li'om dclilUlt or otllelwise, otller tllilll any advancement of matw'ity pursuillllto a mandatolY sinking fund payment, tlle paymenL<; gu,uollteed hereby shall be made in such amounts eUld at such times as such payments of principal would have been due had there not been ,Uly such acceleration); illld (ii) tJle reimbursement of allY such payment which is subsequently n:covered li'om ill1Y owner pursUill1t to a final judgment by a COUlt of competent jurisdiction tJJat such payment constitutes ,m avoidable preference to such owner within the meaning of ,my applicable bankl1lptcy law. '111e illnounts relCned to in clauses (i) illld (ii) oftJle preceding sentence shall be refelTed to herein collectively as tJle "Insured Amounts." "Obligations" shall mean: Upon receipt oftelcphonic or telegraphic notice, such notice subsequently conlil111ed in writing by registered or celtified mail, or upon receipt of written notice by registered or eeltified mail, by the Insurer fi"Om tJ1e Paying Agent or illlY owner of ill1 Obligation the payment of illl Insured Amount for which is tJlen due, tJlat such required payment has not been made, the Insurer on tJle due date of such payment or within one business day aller receipt of notice of such nonpayment, whichever is later, will make a deposit of funds, in an account WitJl State Street Bank and TlllSt Company, N.^-, in New York, New York, or its successor, suflicient for the payment of illlY such Insured Amounts which &e then due. U,XlIl presentment and sUITender of such Obligations or presentment of such other proof of ownership of tJ1e Obligations, togetJler with emy appropriate instl1Jments of assignment to evidence the assignment of tJ1e Insured Amounts due on tJ1C Obligations as ill'e paid by tJle Insurer, ,md appropriate instl1Jments to ellcctthe appointmenLof the Insurer as agent for such owners of the Obligations in illlY legal proceeding related to payment of Insured Amounts on the Obligations, such instl1Jments being in a 1'01111 satis!i.lctory to State Street B,Ulk ,Uld Tl1Jst Comp,UlY, N.^-, State Street B,mk ,md Tmst CompilllY, N.A. shall disbursc to such owners, or the Paying Agent payment of tJle Insured Amounts due on such Obligations, less eUlY ,U11ount held by tJ1e Paying Agent lor the payment of such Insured Amounts and legally available therefor. 111is policy docs not insure against loss of illlY prepaymcnt premium which may at ill1Y time be payable with respcetto illlY Obligation. As used herein, tJle telln "owner" shallmeem tlle registered owner of any Obligation as indicated in the books maintained by the Paying Agent, the Issuer, or any designee of tlle Issuer for such purpose. 111e tel111 owner shall not include the Issuer or illlY pm1y whose agreement witJl the Issuer constitutes tJ1C underlying security for the Obligations. Any servicc of process on tJ1e Insurer may be made to the Insurer at its oflices located at 113 King Street, Arl11onk, New York 10504 illld such service of process shall be valid ,Uld binding. "Ill is poli<:y is non-c,Ulcellablc for illlY reason. 111e premium on this policy is not refundable for ,my reason including the payment prior to maturity of the Obligations. 'l11e insurcUlce provided by this policy is not covered by tJ1C Florida Insurancc Guaranty Association created under chapter 631, Florida Statutes. IN WITNESS WHEREOF, tlle Insurer has caused tJlis policy to be cxecuted in lilcsimilc on its bchalfby iLs duly authorized onicers, this day or COUNTERSIGNED: Resident Liccnsed Agent MBIA InslII'ance Corporation p",'d"" ~~ ~ ~ S~ ~..~---~--~--~_. Allest: City, Slate Assistillll Secret,uy )11)-RCS-FI,-6 1/')5