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Resolution 12039RESOLUTION NO. 12039 A RESOLUTION PROVIDING FOR THE ISSUANCE OF SPECIAL TAX BONDS CITY OF ALAMEDA Community Facilities District No. 2 (Paragon Gateway) TABLE OF CONTENTS Page ARTICLE I STATUTORY AUTHORITY AND DEFINITIONS Section 1.01. Authority 2 Section 1.02. Agreement for Benefit of Owners of the Bonds 2 Section 1.03. Definitions 2 ARTICLE II THE BONDS Section 2.01. Principal Amount 9 Section 2.02. Terms of Bonds 9 Section 2.03. Redemption 10 Section 2.04. Form of Bonds 12 Section 2.05. Execution of Bonds 12 Section 2.06. Transfer of Bonds 12 Section 2.07. Exchange of Bonds 13 Section 2.08. Bond Register 13 Section 2.09. Temporary Bonds 13 Section 2.10. Bonds Mutilated, Lost, Destroyed or Stolen 13 Section 2.11. Limited Obligation 14 Section 2.12. Issuance of Parity Bonds 14 ARTICLE III ISSUANCE OF BONDS Section 3.01. Issuance and Delivery of Bonds 16 Section 3.02. Pledge of Special Tax Revenues 16 Section 3.03. Validity of Bonds 16 Section 3.04. Application of Proceeds of Sale of Bonds 16 ARTICLE IV ESTABLISHMENT OF FUNDS Section 4.01. Improvement Fund 17 Section 4.02. Costs of Issuance Fund 17 Section 4.03. Reserve Fund 18 Section 4.04. Bond Fund 18 Section 4.05. Special Tax Fund 19 Section 4.06. Administrative Expense Fund 19 ARTICLE V OTHER COVENANTS OF THE CITY Section 5.01. Punctual Payment 21 Section 5.02. Limited Obligation 21 Section 5.03. Extension of Time for Payment 21 Section 5.04. Against Encumbrances 21 Section 5.05. Books and Records 21 Section 5.06. Protection of Security and Rights of Owners 21 Section 5.07. Compliance with Law, Completion of Project 21 Section 5.08. Private Business Use Limitation 21 Section 5.09. Private Loan Limitation 22 Section 5.10. Collection of Special Tax Revenues 22 Section 5.11. Further Assurances 23 Section 5.12. No Arbitrage 23 Section 5.13. Federal Guarantee Prohibition 23 Section 5.14. Compliance with the Code 23 Section 5.15. Covenant to Foreclose 23 ARTICLE VI INVESTMENTS, DISPOSITION OF INVESTMENT PROCEEDS, LIABILITY OF THE CITY Section 6.01. Deposit and Investment of Moneys in Funds 24 Section 6.02. Rebate of Excess Investment Earnings to the United States 24 Section 6.03. Limited Obligation 25 Section 6.04. Liability of City 25 Section 6.05. Employment of Agents by City 25 ARTICLE VII THE AGENT Section 7.01. Appointment of Agent 27 Section 7.02. Liability of Agent 27 Section 7.03. Information 28 Section 7.04. Notice to Agent 28 Section 7.05. Compensation, Indemnification 29 ARTICLE VIII MODIFICATION OR AMENDMENT OF THIS RESOLUTION OF ISSUANCE Section 8.01. Amendments Permitted 30 Section 8.02. Owners' Meetings 30 Section 8.03. Procedure for Amendment with Written Consent of Owners 30 Section 8.04. Disqualified Bonds 31 Section 8.05. Effect of Supplemental Resolution 31 Section 8.06. Endorsement or Replacement of Bonds Issued After Amendments 31 Section 8.07. Amendatory Endorsement of Bonds 32 ARTICLE IX MISCELLANEOUS Section 9.01. Benefits of Agreement Limited to Parties 33 Section 9.02. Successor is Deemed Included in All References to Predecessor 33 Section 9.03. Discharge of Resolution of Issuance 33 Section 9.04. Execution of Documents and Proof of Ownership by Owners 34 Section 9.05. Waiver of Personal Liability 34 Section 9.06. Notices to and Demands on City and Agent 34 Section 9.07. Partial Invalidity 34 Section 9.08. Unclaimed Moneys 35 Section 9.09. Applicable Law 35 Section 9.10. Conflict with Act 35 Section 9.11. Conclusive Evidence of Regularity 35 Section 9.12. Payment on Business Day 35 Section 9.13. Effective Date 35 EXHIBIT A - Form of Bond RESOLUTION NO. 12039 A RESOLUTION PROVIDING FOR THE ISSUANCE OF SPECIAL TAX BONDS CITY OF ALAMEDA Community Facilities District No. 2 (Paragon Gateway) RESOLVED by the City Council (the "Council ") of the City of Alameda (the "City "), County of Alameda, State of California, that WHEREAS, pursuant to Chapter 16 of Title III of the Alameda Municipal Code (the "Act"), this Council heretofore conducted proceedings for the formation of Community Facilities District No. 2 (Paragon Gateway) (the "CFD ") and the levy of special taxes within the CFD under Resolution of Intention to Establish a Community Facilities District and to Authorize the Levy of a Special Tax, adopted November 7, 1990, and said proceedings are now complete; WHEREAS, pursuant to the Act, this Council heretofore conducted proceedings for the issuance of bonds to be issued upon the security of special taxes under Resolution of Intention to Incur Bonded Indebtedness, adopted November 7, 1990, and said proceedings are now complete (said resolutions hereinafter collectively called the `Resolutions of Intention "); and WHEREAS, pursuant to the Act, this Council may now provide for the form and manner of issuance of bonds and the covenants for their protection; NOW THEREFORE, BE IT RESOLVED THAT THE COUNCIL DETERMINES AND ORDERS as follows: 1 ARTICLE I STATUTORY AUTHORITY AND DEFINITIONS Section 1.01. Authority. This Resolution of Issuance is authorized pursuant to the provisions of the Act and proceedings of the Council pursuant to the Resolutions of Intention had thereunder. Section 1.02. Agreement for Benefit of Owners of the Bonds. The provisions, covenants and agreements herein set forth to be performed by or on behalf of the City shall be for the equal benefit, protection and security of the Owners of the Bonds. All of the Bonds, without regard to the time or times of their issuance or maturity, shall be of equal rank without preference, priority or distinction of any of the Bonds over any other thereof, except as expressly provided in or permitted by this Resolution of Issuance. Section 1.03. Definitions. Unless the context otherwise requires, the terms defined in this Section 1.03 shall, for all purposes of this Resolution of Issuance, of any Supplemental Resolution, and of any certificate, opinion or other document herein mentioned, have the meanings herein specified. All references herein to "Articles," "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of this Resolution of Issuance, and the words "herein," "hereof," "hereunder" and other words of similar import refer to this Resolution of Issuance as a whole and not to any particular Article, Section or subdivision hereof. `Act'" means Chapter 16 of Title III of the Alameda Municipal Code. "Administrative Expenses" means any or all of the following: the fees and expenses of the Agent (including any fees or expenses of its counsel), the expenses of the City in carrying out its duties hereunder (including, but not limited to, the levying and collection of the Special Taxes) including the fees and expenses of its counsel, an allocable share of the salaries of City staff directly related thereto and a proportionate amount of City general administrative overhead related thereto, and all other costs and expenses of the City or the Agent incurred in connection with the discharge of their respective duties hereunder and, in the case of the City, in any way related to the administration of the CFD. "Administrative Expense Fund" means the fund by that name established by Section 4.06(A) hereof. "Agent" means Security Pacific National Bank, which is designated under Section 7.01 hereof to perform the duties required under this Resolution of Issuance for the authentication, transfer, registration, and payment of the Bonds. "Annual Debt Service" means, for each Bond Year, the sum of (i) the interest due on the Outstanding Bonds in such Bond Year, assuming that the Outstanding Bonds are retired as scheduled, and (ii) the principal amount of the Outstanding Bonds due in such Bond Year. "Auditor" means the auditor /tax collector or such other official responsible for collection of general real property taxes of the County of Alameda. "Authorized Officer" means the City Manager, the City Director of Finance, the City Clerk, City Engineer, the Director of Public Works of the City or any other officer or employee authorized by the City Council of the City or by an Authorized Officer to undertake the action referenced in this Resolution of Issuance as required to be undertaken by an Authorized Officer. -2 "Bond Counsel" means any attorney or firm of attorneys acceptable to the City and nationally recognized for expertise in rendering opinions as to the legality and tax- exempt status of securities issued by public entities. "Bond Fund" means the fund by that name established by Section 4.04(A) hereof. "Bond Purchase Agreement" means the agreement between the City and the Original Purchaser for the purchase and sale of the Bonds. "Bond Year" means the one -year period beginning on the anniversary of the Closing Date in each year and ending on the day prior to the anniversary date of the Closing Date in the following year except that the first Bond Year shall begin on the Closing Date. "Bonds" means the City of Alameda Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds at any time Outstanding under this Resolution of Issuance or any Supplemental Resolution. "Business Day" means any day other than (i) a Saturday or a Sunday or (ii) a day on which banking institutions in the state in which the Agent has its principal corporate trust office are authorized or obligated by law or executive order to be closed. "CFD" means Community Facilities District No. 2 (Paragon Gateway) formed pursuant to the Resolution of Formation. "City" means the City of Alameda, State of California, and any successor thereto. "City Attorney" means any attorney or firm of attorneys employed by the City in the capacity of city attorney. "Closing Date" means the date upon which there is a physical delivery of the Bonds in exchange for the amount representing the purchase price of the Bonds by the Original Purchaser. "Code" means the Internal Revenue Code of 1986, as amended. "Costs of Issuance" means items of expense payable or reimbursable directly or indirectly by the City and related to the authorization, sale and issuance of the Bonds, which items of expense shall include, but not be limited to, printing costs, costs of reproducing and binding documents, closing costs, filing and recording fees, initial fees and charges of the Agent including its first annual administration fee, expenses incurred by the City in connection with the issuance of the Bonds and the establishment of the CFD, special tax consultant fees and expenses, preliminary engineering fees and expenses, Bond (underwriter's) discount, legal fees and charges, including bond counsel, and counsel to the financial consultant, financial consultants' fees, charges for execution, transportation and safekeeping of the Bonds and other costs, charges and fees in connection with the foregoing. "Costs of Issuance Fund" means the fund by that name established by Section 4.02(A) hereof. "Debt Service" means the scheduled amount of interest and amortization of principal payable on the Bonds during the period of computation, excluding amounts scheduled during such period which relate to principal which has been retired before the beginning of such period. 3 "Federal Securities" means any of the following which are non - callable and which at the time of investment are legal investments under the laws of the State of California for funds held by the Treasurer: (i) direct general obligations of the United States of America (including obligations issued or held in book entry form on the books of the United States Department of the Treasury) and obligations, the payment of principal of and interest on which are directly or indirectly guaranteed by the United States of America, including, without limitation, such of the foregoing which are commonly referred to as "stripped" obligations and coupons; or (ii) any of the following obligations of the following agencies of the United States of America: (a) direct obligations of the Export-Import Bank, (b) certificates of beneficial ownership issued by the Farmers Home Administration, (c) participation certificates issued by the General Services Administration, (d) mortgage- backed bonds or pass - through obligations issued and guaranteed by the Government National Mortgage Association, (e) project notes issued by the United States Department of Housing and Urban Development, and (f) public housing notes and bonds guaranteed by the United States of America. "Fiscal Year" means the twelve -month period extending from July 1 in a calendar year to June 30 of the succeeding year, both dates inclusive. "Gross Proceeds" means the sum of the following amounts: (i) original proceeds, namely, net amounts received by or for the City or the CFD as a result of the sale of the Bonds, excluding original proceeds which become transferred proceeds (determined in accordance with applicable Regulations) of obligations issued to refund in whole or in part the Bonds; (ii) investment proceeds, namely, amounts received at any time by or for the City or the CFD, such as interest and dividends, resulting from the investment of any original proceeds (as referenced in clause (i) above) or investment proceeds (as referenced in this clause (ii)) in Nonpurpose Investments, increased by any profits and decreased (if necessary, below zero) by any losses on such investments, excluding investment proceeds which become transferred proceeds (determined in accordance with applicable Regulations) of obligations issued to refund in whole or in part the Bonds; (iii) sinking fund proceeds, namely, amounts, other than original proceeds, investment proceeds (as referenced in clauses (i) above) of the Bonds, which are held in the Bond Fund and any other fund to the extent that the City reasonably expects to use such other fund to pay Debt Service; (iv) amounts in the Reserve Fund and in any other fund established as a reasonably required reserve for payment of Debt Service; (v) Investment Property pledged as security for payment of Debt Service; (vi) Special Taxes and amounts, other than as specified in this definition, used to pay Debt service; and (vii) amounts received as a result of investing amounts described in this definition. "Information Services" means Financial Information, Inc.'s "Daily Called Bond Service ", 30 Montgomery Street, 10th Floor, Jersey City, New Jersey 07302, Attention: Editor; Kenny Information Services' `Called Bond Service ", 55 Broad Street, 28th Floor, New York, New York 4- 10004; Moody's Investors Service "Municipal and Government ", 99 Church Street, New York, New York 10007, Attention: Municipal News Reports; Standard & Poors Corporation "Called Bond Record ", 25 Broadway, 3rd Floor, New York, New York 10004; and, in accordance with then current guidelines of the Securities and Exchange Commission, such other addresses and /or such services providing information with respect to called bonds as the City may designate. "Improvement Fund" means the fund by that name created by and held by the Treasurer pursuant to Section 4.01(A) hereof. "Interest Payment Dates" means September 1 and March 1 of each year, commencing September 1, 1991. "Investment Earnings" means all interest earned and any gains and losses on the investment of moneys in any fund or account created by this Resolution of Issuance. "Investment Property" means any security (as said term is defined in Section 165(g)(2)(A) or (B) of the Code), obligation, annuity contract or investment -type property, excluding, however, obligations (other than specified private activity bonds as defined in section 57(e)(5)(6) of the Code) the interest on which is excluded from gross income under Section 103 of the Code for federal income tax purposes. "Maximum Annual Debt Service" means the largest Annual Debt Service for any Bond Year after the calculation is made through the final maturity date of any Outstanding Bonds. "Nonpurpose Investment" means any Investment Property which is acquired with the Gross Proceeds of the Bonds and is not acquired in order to carry out the governmental purpose of the Bonds. "Original Purchaser" means the first purchaser of the Bonds from the City. "Officer's Certificate" means a written certificate, order, requisition, or statement of the City signed by an Authorized Officer of the City. "Ordinance" means any ordinance of the City levying the Special Taxes. "Outstanding," when used as of any particular time with reference to Bonds, means (subject to the provisions of Section 8.04) all Bonds except: (i) Bonds theretofore canceled by the Agent or surrendered to the Agent for cancellation; (ii) Bonds paid or deemed to have been paid within the meaning of Section 9.03; and (iii) Bonds in lieu of or in substitution for which other Bonds shall have been authorized, executed, issued and delivered by the City pursuant to the Resolution of Issuance or any Supplemental Resolution. "Owner" or "Bondowner" means any person who shall be the registered owner of any Outstanding Bond. "Parity Bonds" means any bonds issued pursuant to Section 2.12 hereof. "Permitted Investments" means (i) Federal Securities; 5 (ii) obligations of states or of any political subdivisions thereof, provided that the payment of principal thereof and interest thereon is fully secured by obligations described in (i) above: (iii) any of the following obligations of federal agencies not guaranteed by the United States of America: (a) debentures issued by the Federal Housing Administration; (b) participation certificates or senior debt obligations of the Federal Home Loan Mortgage Corporation or Farm Credit Banks (consisting of Federal Land Banks, Federal Intermediate Credit Banks, or Banks for Cooperatives); (c) bonds or debentures of the Federal Home Loan Bank Board established under the Federal Home Loan Bank Act, bonds of any federal home loan bank established under said act and stocks, bonds, debentures, participations or other obligations of or issued by the Federal National Mortgage Association, the Student Loan Marketing Association, the Government National Mortgage Association and the Federal Home Loan Mortgage Corporation; and bonds, notes or other obligations issued or assumed by the International Bank for Reconstruction and Development, with a member bank or banks of the Federal Reserve System; (iv) interest- bearing demand or time deposits (including certificates of deposit) in federal or State chartered savings and loan associations or in federal or State banks (including the Agent), provided that: (a) in the case of a savings and loan association, such demand or time deposits shall be fully insured by the Federal Deposit Insurance Corporation, or the unsecured obligations of such savings and loan association shall be rated in a Rating Category (as defined herein), and (b) in the case of a bank, such demand or time deposits shall be fully insured by the Federal Deposit Insurance Corporation, or the unsecured obligations of such bank (or the unsecured obligations of the parent bank holding company of which such bank is the lead bank) shall be rated in a Rating Category; (v) written repurchase agreements with any bank, savings institution or trust company (other than the Agent) which is insured by the Federal Deposit Insurance Corporation, or with any broker- dealer with retail customers which falls under Securities Investors Protection Corporation protection, provided that such repurchase agreements are fully secured by Federal Securities or obligations of any agency of instrumentality of the United States of America and provided further that (a) such collateral is held by the Treasurer or any agent acting solely for the Treasurer during the term of such repurchase agreement, (b) such collateral is not subject to liens or claims of third parties, (c) such collateral has a market value (determined at least once every 14 days) at least equal to the amount invested in the repurchase agreement, (d) the Treasurer has a perfected first security interest in the collateral, (e) the agreement shall be for a term not longer than 270 days and (f) the failure to maintain such collateral at the level required in (c) above will require the Treasurer to liquidate the collateral. (vi) taxable money market fund portfolios restricted to obligations with maturities of one year or less issued or guaranteed as to payment of principal and interest by the full faith and credit of the United States of America and repurchase agreements collateralized by such obligations; (vii) commercial paper having original maturities of not more than 365 days and rated in a Rating Category; (viii) bankers acceptances rated in a Rating Category, endorsed and guaranteed by banks described in clause (v) of this definition; (ix) obligations the interest on which is excluded from gross income for purposes of federal income taxation under Section 103 of the Code and which are rated in a Rating Category; and 6 (x) one or more agreement with financial institutions whose long term debt (or claims' paying ability) is rated in a Rating Category. "Principal Office" means the principal corporate trust office of the Agent at the principal corporate trust department of Security Pacific National Bank, in Los Angeles, California , or such other or additional offices as may be designated by the Agent. "Private Business Use" means use directly or indirectly in a trade or business carried on by a natural person or in any activity carried on by a person other than a natural person, excluding, however, use by a governmental unit and use by a nongovernmental unit as a member of the general public. "Proceeds" when used with reference to the Bonds, means the face amount of the Bonds, plus accrued interest and premium, if any, less original issue discount and less proceeds from the sale of the Bonds deposited in the Reserve Fund. "Project" means the facilities more particularly described in the Resolution of Formation. "Purchase Price," for the purpose of computation of the Yield of the Bonds, has the same meaning as the term "issue price" in sections 1273(b) and 1274 of the Code, and, in general, means the initial offering price of the Bonds to the public (not including bond houses and brokers, or similar persons or organizations acting in the capacity of underwriters or wholesalers) at which price a substantial amount of the Bonds are sold or if the Bonds are privately placed, the price paid by the first buyer of the Bonds or the acquisition cost of the first buyer. The term "Purchase Price," for the purpose of computation of the Yield of Nonpurpose Investments, means the fair market value of the Nonpurpose Investments on the date of use of Gross Proceeds of the Bonds for acquisition thereof, or if later, on the date that Investment Property constituting a Nonpurpose Investment becomes a Nonpurpose Investment of the Bonds. "Rating Category" means one of the two highest rating categories then in effect under the rating systems of Moody's Investors Service or Standard and Poor's Corporation, without regard to plus or minus sign or numerical or other qualifying designation. "Record Date" means the fifteenth day of the month next preceding the month of the applicable Interest Payment Date. "Regulations" means temporary and permanent regulations promulgated under the Code. "Reserve Fund" means the fund by that name established pursuant to Section 4.03(A) hereof. "Reserve Requirement" means, ten percent (10 %) of the Proceeds of the sale of the Bonds as referenced in Section 3.04 hereof. "Resolution of Formation" means Resolution No. 12035, adopted by the City Council on November 20, 1990. "Resolutions of Intention" means, collectively, Resolution Nos. 12030 and 12031, adopted by the City Council on November 7, 1990. "Resolution of Issuance" means this resolution as adopted by the Council and hereafter amended. 7 "Securities Depositories" means The Depository Trust Company, 711 Stewart Avenue, Garden City, New York 11530, Fax - (516)227 -4039 or -4190; Midwest Securities Trust Company, Capital Structures -Call Notification, 440 South LaSalle Street, Chicago, Illinois 60605, Fax - (312)663 -2343; Philadelphia Depository Trust Company, Reorganization Division, 1900 Market Street, Philadelphia, Pennsylvania 19103, Attention: Bond Department, Dex- (215)496- 5058; and, in accordance with then current guidelines of the Securities and Exchange Commission, such other addresses and/or such other securities depositories as the City may designate. "Special Taxes" means the special taxes levied within the CFD pursuant to the Act, the Ordinance and this Resolution of Issuance. "Special Tax Revenues" means the proceeds of the Special Taxes received by the City, including any scheduled payments and any prepayments thereof, interest and penalties thereon and proceeds of the redemption or sale of property sold as a result of foreclosure of the lien of the Special Taxes to the amount of said lien and interest and penalties thereon. "Special Tax Fund" means the fund by that name established by Section 4.05(A) hereof. "Supplemental Resolution" means a resolution which has been duly adopted by the City under the Act and which resolution is amendatory of or supplemental to this Resolution of Issuance, but only if and to the extent that such resolution is specifically authorized hereunder. "Treasurer" means the Director of Finance of the City. "Yield" means that yield which, when used in computing the present worth of all payments of principal and interest (or other payments in the case of Nonpurpose Investments which require payments in a form not characterized as principal and interest) on a Nonpurpose Investment or on the Bonds, produces an amount equal to the Purchase Price of such Nonpurpose Investment or the Bonds, all computed as prescribed in applicable Regulations. 8 ARTICLE II THE BONDS Section 2.01. Principal Amount; Designation. Bonds in the aggregate principal amount of One Million Six Hundred Fifteen Thousand Dollars ($1,615,000) are hereby authorized to be issued by the City for the CFD under and subject to the terms of this Resolution of Issuance, the Act and other applicable laws of the State of California. The Bonds shall be designated the "City of Alameda, Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds" and shall be secured by the Special Taxes. Section 2.02. Terms of Bonds. (A) Form; Denominations. The Bonds shall be issued as fully registered Bonds without coupons in the denomination of $5,000 or any integral multiple thereof. Bonds shall be lettered and numbered in a customary manner as determined by the Agent. (B) Date of Bonds. The Bonds shall be dated December 1, 1990. (C) CUSIP Identification Numbers. "CUSIP" identification numbers shall be imprinted on the Bonds, but such numbers shall not constitute a part of the contract evidenced by the Bonds and any error or omission with respect thereto shall not constitute cause for refusal of any purchaser to accept delivery of and pay for the Bonds. In addition, failure on the part of the City or the Agent to use such CUSIP numbers in any notice to Owners shall not constitute an event of default or any violation of the City's contract with such Owners and shall not impair the effectiveness of any such notice. (D) Maturities, Interest Rates. The Bonds shall mature and become payable on September 1 of each year, and shall bear interest at the rates, as follows: Maturity Date Principal Interest (September 1) Amount ($) Rate ( %) 1992 25,000 6.50 1993 25,000 6.75 1994 25,000 6.90 1995 30,000 7.00 1996 30,000 7.10 1997 35,000 7.20 1998 35,000 7.30 1999 40,000 7.40 2000 40,000 7.50 2001 45,000 7.60 2016 1,285,000 8.00 (E) Interest. The Bonds shall bear interest at the rates set forth above payable on the Interest Payment Dates in each year. Interest shall be calculated on the basis of a 360 -day year composed of twelve 30 -day months. Each Bond shall bear interest from the Interest Payment Date next preceding the date of authentication thereof unless (i) it is authenticated on an Interest Payment Date, in which event it shall bear interest from such date of authentication, or (ii) it is authenticated prior to an Interest Payment Date and after the close of business on the Record Date preceding such Interest Payment Date, in which event it shall bear interest from such Interest Payment Date, or (iii) 9 it is authenticated prior to the Record Date preceding the first Interest Payment Date, in which event it shall bear interest from December 1, 1990; provided, however, that if at the time of authentication of a Bond, interest is in default thereon, such Bond shall bear interest from the Interest Payment Date to which interest has previously been paid or made available for payment thereon. (F) Method of Payment. Interest on the Bonds (including the final interest payment upon maturity or earlier redemption) is payable by check or draft of the Agent mailed on the Interest Payment Dates by first class mail to the registered Owner thereof at such registered Owner's address as it appears on the registration books maintained by the Agent at the close of business on the Record Date preceding the Interest Payment Date, or by wire transfer made on such Interest Payment Date upon instructions of any Owner of $1,000,000 or more in aggregate principal amount of Bonds. The principal of the Bonds and any premium on the Bonds are payable in lawful money of the United States of America upon surrender of the Bonds at the Principal Office of the Agent. All Bonds paid by the Agent pursuant to this Section shall be cancelled by the Agent. The Agent shall destroy the cancelled Bonds and issue a certificate of destruction thereof to the City. Section 2.03. Redemption. (A) Redemption Dates. (i) Optional Redemption. The Bonds maturing on or after September 1, 2000, are subject to optional redemption prior to their stated maturity on any Interest Payment Date on or after September 1, 1999, as a whole or in part, at a redemption price (expressed as a percentage of the principal amount of the Bonds to be redeemed), as set forth below, together with accrued interest thereon to the date fixed for redemption: Redemption Dates Redemption Prices September 1, 1999 and March 1, 2000 102% September 1, 2000 and March 1, 2001 101 September 1, 2001 and thereafter 100 (ii) Mandatory Redemption From Prepayments. All the Bonds are subject to redemption prior to their stated maturities from proceeds of prepayments of Special Taxes, on any Interest Payment Date, in whole or in part, at a redemption price (expressed as a percentage of the principal amount of the Bonds to be redeemed) as set forth below, together with accrued interest thereon to the date fixed for redemption: Redemption Dates Redemption Prices On or prior to March 1, 1998 103% September 1, 1999 and March 1, 2000 102 September 1, 2000 and March 1, 2001 101 September 1, 2001 and thereafter 100 (iii) Mandatory Redemption Following Completion. All the Bonds are subject to redemption prior to their stated maturities, in whole or in part, on the next Interest Payment Date occurring at least 60 days following the transfer from the Improvement Fund to the Bond Fund of all moneys on deposit in the Improvement Fund upon completion of the Project, as certified by the Treasurer at a redemption price equal to the principal amount thereof, together with accrued interest thereon to the date of redemption, without premium. - 10 - (iv) Mandatory Sinking Payment Redemption. The outstanding Bonds maturing on September 1, 2016, are subject to mandatory sinking payment redemption in part on September 1, 2002, and on each September 1 thereafter to maturity, by lot, at a redemption price equal to the principal amount thereof to be redeemed, together with accrued interest to the date fixed for redemption, without premium, from sinking payments as follows: September 1 2002 2003 2004 2005 2006 2007 2008 2009 Sinking Payments $45,000 50,000 55,000 60,000 65,000 70,000 75,000 80,000 September 1 2010 2011 2012 2013 2014 2015 2016 Sinking Payments $ 90,000 95,000 100,000 110,000 120,000 130,000 140,000 The amounts in the foregoing table shall be reduced pro rata, in order to maintain substantially level debt service, as a result of any prior partial redemption of the Bonds pursuant to Section 2.03(A)(i), (ii), and (iii) above. In lieu of redemption under this Section 2.03(A)(iv), moneys in the Bond Fund may be used and withdrawn by the Treasurer for purchase of Outstanding Bonds, upon the filing with the Agent of an Officer's Certificate requesting such purchase, at public or private sale as and when, and at such prices (including brokerage and other charges) as such Officer's Certificate may provide, but in no event may Bonds be purchased at a price in excess of the principal amount thereof, plus interest accrued to the date of purchase. (B) Notice to Agent. The City shall give the Agent written notice of its intention to redeem Bonds pursuant to subsection (A)(i) not less than sixty (60) days prior to the applicable redemption date. (C) Redemption Procedure by Agent. The Agent shall cause notice of any redemption to be mailed by first class mail, postage prepaid, at least thirty (30) days but not more than sixty (60) days prior to the date fixed for redemption, to the Securities Depositories and to one or more Information Services, and to the respective registered Owners of any Bonds designated for redemption, at their addresses appearing on the Bond registration books in the Principal Office of the Agent; but such mailing shall not be a condition precedent to such redemption and failure to mail or to receive any such notice, or any defect therein, shall not affect the validity of the proceedings for the redemption of such Bonds. The Agent, in addition to mailed notice, shall publish notice in a newspaper of general circulation circulated in the area of the CFD. The first such publication of the redemption notice shall not be less than 30 nor more than 60 days prior to the date fixed for redemption. Such notice shall state the redemption date and the redemption price and, if less than all of the then Outstanding Bonds are to be called for redemption, shall designate the CUSIP numbers and Bond numbers of the Bonds to be redeemed by giving the individual CUSIP number and Bond number of each Bond to be redeemed or shall state that all Bonds between two stated Bond numbers, both inclusive, are to be redeemed or that all of the Bonds of one or more maturities have been called for redemption, shall state as to any Bond called in part the principal amount thereof to be redeemed, and shall require that such Bonds be then surrendered at the Principal Office of the Agent for redemption at the said redemption price, and shall state that further interest on such Bonds will not accrue from and after the redemption date. Upon the payment of the redemption price of Bonds being redeemed, each check or other transfer of funds issued for such purpose shall, to the extent practicable, bear the CUSIP number identifying, by issue and maturity, of the Bonds being redeemed with the proceeds of such check or other transfer. Whenever provision is made in this Resolution of Issuance for the redemption of less than all of the Bonds or any given portion thereof, the Agent shall select the Bonds to be redeemed, from all Bonds or such given portion thereof not previously called for redemption, in inverse order of maturity and by lot within a maturity in any manner which the Agent in its sole discretion shall deem appropriate and fair. Upon surrender of Bonds redeemed in part only, the City shall execute and the Agent shall authenticate and deliver to the registered Owner, at the expense of the City, a new Bond or Bonds, of the same series and maturity, of authorized denominations in aggregate principal amount equal to the unredeemed portion of the Bond or Bonds. (D) Effect of Redemption. From and after the date fixed for redemption, if funds available for the payment of the principal of, and interest and any premium on, the Bonds so called for redemption shall have been deposited in the Bond Fund, such Bonds so called shall cease to be entitled to any benefit under this Resolution of Issuance other than the right to receive payment of the redemption price, and no interest shall accrue thereon on or after the redemption date specified in such notice. All Bonds redeemed and purchased by the Agent pursuant to this Section shall be cancelled by the Agent. The Agent shall destroy the cancelled Bonds and issue a certificate of destruction thereof to the City. Section 2.04. Form of Bonds. The Bonds, the form of Agent's certificate of authentication and the form of assignment, to appear thereon, shall be substantially in the forms, respectively, set forth in Exhibit A attached hereto and by this reference incorporated herein, with necessary or appropriate variations, omissions and insertions, as permitted or required by this Resolution of Issuance and the Act. Section 2.05. Execution of Bonds. The Bonds shall be executed on behalf of the City by the facsimile signatures of its Mayor and City Clerk who are in office on the date of adoption of this Resolution of Issuance or at any time thereafter, and the seal of the City shall be impressed, imprinted or reproduced by facsimile signature thereon. If any officer whose signature appears on any Bond ceases to be such officer before delivery of the Bonds to the owner, such signature shall nevertheless be as effective as if the officer had remained in office until the delivery of the Bonds to the owner. Any Bond may be signed and attested on behalf of the City by such persons as at the actual date of the execution of such Bond shall be the proper officers of the City although at the nominal date of such Bond any such person shall not have been such officer of the City. Only such Bonds as shall bear thereon a certificate of authentication in substantially the form set forth in Exhibit A, executed and dated by the Agent, shall be valid or obligatory for any purpose or entitled to the benefits of this Resolution of Issuance, and such certificate of authentication of the Agent shall be conclusive evidence that the Bonds registered hereunder have been duly authenticated, registered and delivered hereunder and are entitled to the benefits of this Resolution of Issuance. Section 2.06. Transfer of Bonds. Any Bond may, in accordance with its terms,. be transferred, upon the books required to be kept pursuant to the provisions of Section 2.08 by the person in whose name it is registered, in person or by his duly authorized attorney, upon surrender - 12 - of such Bond for cancellation, accompanied by delivery of a duly written instrument of transfer in a form approved by the Agent. The cost for any services rendered or any expenses incurred by the Agent in connection with any such transfer shall be paid by the City. The Agent shall collect from the Owner requesting such transfer any tax or other governmental charge required to be paid with respect to such transfer. Whenever any Bond or Bonds shall be surrendered for transfer, the City shall execute and the Agent shall authenticate and deliver a new Bond or Bonds, for like aggregate principal amount. No transfers of Bonds shall be required to be made (i) fifteen days prior to the date established by the Agent for selection of Bonds for redemption or (ii) with respect to a Bond after such Bond has been selected for redemption. Section 2.07. Exchange of Bonds. Bonds may be exchanged at the Principal Office of the Agent for a like aggregate principal amount of Bonds of authorized denominations and of the same maturity. The cost for any services rendered or any expenses incurred by the Agent in connection with any such exchange shall be paid by the City. The Agent shall collect from the Owner requesting such exchange any tax or other governmental charge required to be paid with respect to such exchange. No exchanges of Bonds shall be required to be made (i) fifteen days prior to the date established by the Agent for selection of Bonds for redemption or (ii) with respect to a Bond after such Bond has been selected for redemption. Section 2.08. Bond Register. The Agent will keep or cause to be kept, at its Principal Office sufficient books for the registration and transfer of the Bonds which books shall show the series number, date, amount, rate of interest and last known owner of each Bond and shall at all times be open to inspection by the City during regular business hours upon reasonable notice; and, upon presentation for such purpose, the Agent shall, under such reasonable regulations as it may prescribe, register or transfer or cause to be registered or transferred, on said books, the ownership of the Bonds as hereinbefore provided. Section 2.09. Temporary Bonds. The Bonds may be initially issued in temporary form exchangeable for definitive Bonds when ready for delivery. The temporary Bonds may be printed, lithographed or typewritten, shall be of such authorized denominations as may be determined by the City, and may contain such reference to any of the provisions of this Resolution of Issuance as may be appropriate. Every temporary Bond shall be executed by the City upon the same conditions and in substantially the same manner as the definitive Bonds. If the City issues temporary Bonds it will execute and furnish definitive Bonds without delay and thereupon the temporary Bonds shall be surrendered, for cancellation, in exchange for the definitive Bonds at the Principal Office of the Agent or at such other location as the Agent shall designate, and the Agent shall authenticate and deliver in exchange for such temporary Bonds an equal aggregate principal amount of definitive Bonds of authorized denominations. Until so exchanged, the temporary bonds shall be entitled to the same benefits under to this Resolution of Issuance as definitive Bonds authenticated and delivered hereunder. Section 2.10. Bonds Mutilated, Lost, Destroyed or Stolen. If any Bond shall become mutilated, the City, at the expense of the Owner of said Bond, shall execute, and the Agent shall authenticate and deliver, a new Bond of like tenor and principal amount in exchange and substitution for the Bond so mutilated, but only upon surrender to the Agent of the Bond so mutilated. Every mutilated Bond so surrendered to the Agent shall be cancelled by it and destroyed by the Agent who shall deliver a certificate of destruction thereof to the City. If any Bond shall be lost, destroyed or stolen, evidence of such loss, destruction or theft may be submitted to the Agent and, if such evidence be satisfactory to it and indemnity satisfactory to it shall be given, the City, at - 13 - the expense of the Owner, shall execute, and the Agent shall authenticate and deliver, a new Bond of like tenor and principal amount in lieu of and in substitution for the Bond so lost, destroyed or stolen. The City may require payment of a sum not exceeding the actual cost of preparing each new Bond delivered under this Section and of the expenses which may be incurred by the City and the Agent for the preparation, execution, authentication and delivery. Any Bond delivered under the provisions of this Section in lieu of any Bond alleged to be lost, destroyed or stolen shall constitute an original additional contractual obligation on the part of the City whether or not the Bond so alleged to be lost, destroyed or stolen is at any time enforceable by anyone, and shall be equally and proportionately entitled to the benefits of this Resolution of Issuance with all other Bonds issued pursuant to this Resolution of Issuance. Section 2.11. Limited Obligation. All obligations of the City under this Resolution of Issuance and the Bonds shall be special obligations of the City, payable solely from the Special Tax Revenues and the funds pledged therefore hereunder. Neither the faith and credit nor the taxing power of the City (except to the limited extent set forth herein) or the State of California or any political subdivision thereof is pledged to the payment of the Bonds. Section 2.12. Issuance of Parity Bonds. In addition to the Bonds, the City may issue Parity Bonds in such principal amount as shall be determined by the City, pursuant to a Supplemental Resolution adopted by the Council. The City may issue such Parity Bonds subject to the following specific conditions precedent: (A) The City shall be in compliance with all covenants set forth in this Resolution of Issuance and all Supplemental Resolutions. (B) The Supplemental Resolution providing for the issuance of such Parity Bonds shall provide that interest thereon shall be payable on September 1 and March 1, and principal thereof shall be payable on September 1 in any year in which principal is payable; (C) The Supplemental Resolution providing for the issuance of such Parity Bonds may provide for the establishment of separate funds and accounts; (D) The fair market value of all parcels in the CFD subject to Special Taxes, including then existing improvements and any facilities to be constructed or acquired with the proceeds of the proposed series of Parity Bonds, as determined by an appraisal performed on a basis consistent with the appraisal or appraisals prepared in connection with the issuance of Bonds theretofore issued and outstanding, or, in the alternative, the assessed value of all such parcels and improvements thereon as shown on the then current Alameda County tax roll, is at least 4.00 times the sum of (i) the aggregate principal amount of all Bonds then outstanding plus (ii) the aggregate principal amount of the series of Parity Bonds proposed to be issued, plus (iii) the aggregate principal amount of any assessment district bonds then outstanding and payable from assessments to be levied on parcels of land within the CFD, plus (iv) a portion of the aggregate principal amount of all other community facilities district Bonds then outstanding and payable at least partially from special taxes to be levied on parcels of land within the CFD (the "Other CFD Bonds ") equal to the aggregate principal amount of the Other CFD Bonds multiplied by a fraction, the numerator of which is the amount of special taxes levied for the Other CFD Bonds on parcels of land within the CFD, and the denominator of which is the total amount of special taxes levied for the Other CFD Bonds on all parcels of land against which the special taxes are levied to pay Other CFD Bonds (such fraction to be determined based upon the maximum special taxes which could be levied the year in which maximum annual debt service on the Other CFD Bonds occurs), based upon information from the most recent available fiscal year. (E) The City shall deliver to the Agent an Officer's Certificate certifying that the conditions precedent to the issuance of such Parity Bonds set forth in subsections (A), (B), (C), and (D) of this Section 2.12 have been satisfied. ARTICLE III ISSUANCE OF BONDS Section 3.01. Issuance and Delivery of Bonds. The Bonds shall be sold and delivered to the Original Purchaser pursuant to the Bond Purchase Agreement. The Authorized Officers of the City are hereby authorized and directed to deliver any and all documents and instruments necessary to cause the issuance of the Bonds in accordance with the provisions of the Act and this Resolution of Issuance, to authorize the payment of Costs of Issuance and costs of the Project by the Treasurer from the proceeds of the Bonds and to do and cause to be done any and all acts and things necessary or convenient for delivery of the Bonds to the Original Purchaser. The Treasurer and the City Clerk are authorized to complete and to approve changes in any provision of this Resolution in order to accomplish the delivery of any of the Bonds on schedule including, but not limited to, data with respect to maturities, redemption, and sinking payments. Section 3.02. Pledge of Special Tax Revenues. The Bonds shall be secured by a first pledge (which pledge shall be effected in the manner and to the extent herein provided) of all of the Special Tax Revenues and all moneys deposited in the Bond Fund, the Reserve Fund and, until disbursed as provided herein, in the Improvement Fund. The Special Tax Revenues and all moneys deposited into said funds (except as otherwise provided herein) are hereby dedicated to the payment of the principal of, and interest and any premium on, the Bonds as provided herein and in the Act until all of the Bonds have been paid and retired or until moneys or Federal Securities have been set aside irrevocably for that purpose in accordance with Section 9.03. Section 3.03. Validity of Bonds. The validity of the authorization and issuance of the Bonds shall not be dependent upon the completion of the construction and acquisition of the Project or upon the performance by any person of his obligation with respect to the Project. Section 3.04. Application of Proceeds of Sale of Bonds. On the Closing Date, the proceeds of the purchase of the Bonds by the Original Purchaser shall be paid to the Treasurer, who shall forthwith set aside, pay over and deposit such proceeds as set forth in appropriate Officer's Certificates and consistent with the terms of the Bond Purchase Agreement and this Resolution of Issuance. ARTICLE IV ESTABLISHMENT OF FUNDS Section 4.01. Improvement Fund. (A) Establishment of Improvement Fund. There is hereby established as a separate account to be held by the Treasurer, the Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds, Improvement Fund, to the credit of which a deposit shall be made as required by Section 3.04, and deposits shall be made as provided in Sections 4.03(D) and 4.04(C). Moneys in the Improvement Fund shall be held in trust by the Treasurer for the benefit of the City and the Owners of the Bonds, shall be disbursed, except as otherwise provided in subsection (D) of this Section, for the payment or reimbursement of costs of the Project and, pending such disbursement, shall be subject to a lien in favor of the Owners of the Bonds. (B) Procedure for Disbursement. Disbursements from the Improvement Fund shall be made by the Treasurer upon receipt of an Officer's Certificate which shall set forth the amount required to be disbursed, the purpose for which the disbursement is to be made and the person to which the disbursement is to be paid. (C) Investment. Moneys in the Improvement Fund shall be invested and deposited in accordance with Section 6.01. On each Interest Payment Date, interest earnings and profits from such investment and deposit shall be transferred by the Treasurer to the Bond Fund to be used for the purposes of such fund. (D) Closing of Fund. Upon the filing with the Treasurer of an Officer's Certificate stating that the Project has been completed and that all costs of the Project have been paid or are not required to be paid from the Improvement Fund, the Treasurer shall transfer the amount, if any, remaining in the Improvement Fund to the Bond Fund for application to the payment of Debt Service on the Bonds in accordance with Section 4.04, and the Improvement Fund shall be closed. Section 4.02. Costs of Issuance Fund. (A) Establishment of Costs of Issuance Fund. There is hereby established as a separate account to be held by the Treasurer, the Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds, Costs of Issuance Fund, to the credit of which a deposit shall be made as required by Section 3.04. Moneys in the Costs of Issuance Fund shall be held in trust by the Treasurer and shall be disbursed as provided in subsection (B) of this Section for the payment or reimbursement of Costs of Issuance. (B) Disbursement. Amounts in the Costs of Issuance Fund shall be disbursed from time to time to pay Costs of Issuance, as set forth in a requisition containing respective amounts to be paid to the designated payees, signed by the Treasurer. The Treasurer shall pay all Costs of Issuance upon receipt of an invoice from any such payee which requests payment in an amount which is less than or equal to the amount set forth with respect to such payee in such requisition, or upon receipt of an Officer's Certificate requesting payment of a Costs of Issuance. The Treasurer shall maintain the Costs of Issuance Fund for a period of 180 days from the date of delivery of the Bonds and then shall transfer any moneys remaining therein, including any investment earnings thereon, to the Administrative Expense Fund for payment of any unpaid Costs of Issuance. (C) Investment. Moneys in the Costs of Issuance Fund shall be invested and deposited in accordance with Section 6.01. Interest earnings and profits resulting from said investment shall be retained by the Treasurer in the Costs of Issuance Fund to be used for the purposes thereof. - 17 - Section 4.03. Reserve Fund. (A) Establishment of Fund. There is hereby established as a separate account to be held by the Treasurer the Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds Reserve Fund to the credit of which a deposit shall be made as required by Section 3.04, which deposit is equal to the initial Reserve Requirement, and deposits shall be made as provided in Section 4.05(B). Moneys in the Reserve Fund shall be held in trust by the Treasurer for the benefit of the Owners of the Bonds as a reserve for the payment of principal of, and interest and any premium on, the Bonds and shall be subject to a lien in favor of the Owners of the Bonds. (B) Use of Fund. Except as otherwise provided in this Section, all amounts deposited in the Reserve Fund shall be used and withdrawn by the Treasurer solely for the purpose of making transfers to the Bond Fund in the event of any deficiency at any time in the Bond Fund of the amount then required for payment of the principal of, and interest and any premium on, the Bonds or, in accordance with the provisions of this Section, for the purpose of redeeming Bonds from the Bond Fund. (C) Transfer Due to Deficiency in Bond Fund. Whenever transfer is made from the Reserve Fund to the Bond Fund due to a deficiency in the Bond Fund, the Treasurer shall provide written certification thereof. (D) Transfer of Excess of Reserve Requirement. Whenever, on any Interest Payment Date, or on any other date, the amount in the Reserve Fund exceeds the Reserve Requirement, the Treasurer shall transfer an amount equal to the excess from the Reserve Fund to the Bond Fund to be used for the payment of interest on the Bonds in accordance with Section 4.04. (E) Transfer When Balance Exceeds Outstanding Bonds. Whenever the balance in the Reserve Fund exceeds the amount required to redeem or pay the Outstanding Bonds, including interest accrued to the date of payment or redemption and premium, if any, due upon redemption, the Treasurer shall transfer the amount in the Reserve Fund to the Bond Fund to be applied, on the next succeeding Interest Payment Date to the payment and redemption, in accordance with Section 2.03 or 4.04, as applicable, of all of the Outstanding Bonds. In the event that the amount so transferred from the Reserve Fund to the Bond Fund exceeds the amount required to pay and redeem the Outstanding Bonds, the balance in the Reserve Fund shall be transferred to the City to be used for any lawful purpose of the City. (F) Investment and Transfer to Rebate. Moneys in the Reserve Fund shall be invested and deposited in accordance with Section 6.01. Interest earnings and profits resulting from said investment shall be used as required by the City to comply with Section 6.02, and shall otherwise be transferred on each Interest Payment Date to the Bond Fund to be used for the purposes thereof. Section 4.04. Bond Fund. (A) Establishment of Bond Fund. There is hereby established as a separate account to be held by the Treasurer the Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds Bond Fund to the credit of which deposits shall be made as required by Section 3.04, Section 4.01(C) and (D), Section 4.03, Section 4.05(B) and any other amounts required to be deposited therein by this Resolution of Issuance or the Act. Moneys in the Bond Fund shall be held in trust by the Treasurer for the benefit of the Owners of the Bonds, shall be disbursed for the payment of the principal of, and interest and any premium on, the Bonds as provided below, and, pending such disbursement, shall be subject to a lien in favor of the Owners of the Bonds. - 18 - (B) Disbursements. On or before each Interest Payment Date, the Treasurer shall withdraw from the Bond Fund and remit to the Agent for payment to the Owners of the Bonds the principal, and interest and any premium, then due and payable on the Bonds, including any amounts due on the Bonds by reason of the sinking payments set forth in Section 2,03(A)(iv). Notwithstanding the foregoing, amounts in the Bond Fund as a result of a transfer purauant to Section 4.01(D) shall be used to pay the principal of and interest on the Bonds prior to the use of any other amounts in the Bond Fund for such purpose. In the event that amounts in the Bond Fund are insufficient for the purpose set forth in the preceding sentence, the Treasurer shall withdraw from the Bond Fund to the extent of any funds therein amounts to cover the amount of such Reserve Fund insufficiency. Amounts so withdrawn from the Reserve Fund shall be deposited in the Bond Fund. If, after the foregoing transfers, there are insufficient funds in the Bond Fund to make the payments provided for in the first sentence of the first paragraph of this Section 4.04(B), the Treasurer shall apply the available funds first to the payment of interest on the Bonds, then to the payment of principal due on the Bonds other than by reason of sinking payments, and then to payment of principal due on the bonds by reason of sinking payments. Any sinking payment not made as scheduled shall be added to the sinking payment to be made on the next sinking payment date. (C) Investment. Moneys in the Bond Fund shall be invested and deposited in accordance with Section 6.01. Interest earnings and profits resulting from the investment and deposit of amounts in the Bond Fund shall be retained in the Bond Fund to be used for the purposes thereof. Section 4.05. Special Tax Fund. (A) Establishment of Special Tax Fund. There is hereby established as a separate account to be held by the Treasurer, the Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds Special Tax Fund to the credit of which the City shall deposit, immediately upon receipt, all Special Tax Revenue received by the City and any amounts required by Section 4.06(B) to be deposited therein. Moneys in the Special Tax Fund shall be held in trust by the Treasurer for the benefit of the City and the Owners of the Bonds, shall be disbursed as provided below and, pending and disbursement, shall be subject to a lien in favor of the Owners of the Bonds. (B) Disbursements. As soon as practicable after the receipt by the City of any Special Tax Revenues, but no later than thirty (30) Business Days after such receipt, the Treasurer shall withdraw from the Special Tax Fund and transfer (i) to the Reserve Fund an amount, taking into account amounts then on deposit in the Reserve Fund, such that the amount in the Reserve Fund equals the Reserve Requirement, and (ii) to the Bond Fund an amount, taking into account any amounts then on deposit in the Bond Fund such that the amount in the Bond Fund equals the principal, premium, if any, and interest due on the Bonds during the then current Fiscal Year. All other amounts then in the Special Tax Fund, concurrently with the foregoing transfers, shall be deposited by the Treasurer in the Administrative Expense Fund. (C) Investment. Moneys in the Special Tax Fund shall be invested and deposited in accordance with Section 6.01. Interest earnings and profits resulting from such investment and deposit shall be retained in the Special Tax Fund to be used for the purposes thereof. Section 4.06. Administrative Expense Fund. (A) Establishment of Administrative Expense Fund. There is hereby established as a separate account to be held by the Treasurer, the Community Facilities District No. 2 (Paragon -19- Gateway), Series 1990, Special Tax Bonds, Administrative Expense Fund to the credit of which deposits shall be made as required by Sections 4.02(B) and 4.05(B). In addition, any portion of the deposit made by the owners of property within the CFD with their petition to form the CFD that has not been expended to pay District formation costs prior to the Closing Date, shall be deposited by the Treasurer on the Closing Date in the Administrative Expense Fund. Moneys in the Administrative Expense Fund shall be held in trust by the Treasurer for the benefit of the City, and shall be disbursed as provided below. (B) Disbursement. Amounts in the Administrative Expense Fund shall be withdrawn by the Treasurer and paid to the City or its order upon receipt by the Treasurer of an Officer's Certificate stating the amount to be withdrawn, that such amount is to be used to pay an Administrative Expense (or Costs of Issuance), and the nature of such Administrative Expense (or Costs of Issuance). Annually, on the last day of each Fiscal Year, the Treasurer shall withdraw any amounts then remaining in the Administrative Expense Fund that have not been allocated to pay Administrative Expenses incurred but not yet paid, and which are not otherwise encumbered and transfer such amounts to the Special Tax Fund. (C) Investment. Moneys in the Administrative Expense Fund shall be invested and deposited in accordance with Section 6.01. Interest earnings and profits resulting from said investment shall be retained by the Treasurer in the Administrative Expense Fund to be used for the purposes thereof. ARTICLE V OTHER COVENANTS OF THE CITY Section 5.01. Punctual Payment. The City will punctually pay or cause to be paid the principal of, and interest and any premium on, the Bonds when and as due in strict conformity with the terms of this Resolution of Issuance and any Supplemental Resolution, and it will faithfully observe and perform all of the conditions covenants and requirements of this Resolution of Issuance and all Supplemental Resolutions and of the Bonds. Section 5.02. Limited Obligation. The Bonds are limited obligations of the City on behalf of the CFD and are payable solely from and secured solely by the Special Tax Revenues and the amounts in the Bond Fund, the Reserve Fund, the Improvement Fund and the Special Tax Fund created hereunder. Section 5.03. Extension of Time for Payment. In order to prevent any accumulation of claims for interest after maturity, the City shall not, directly or indirectly, extend or consent to the extension of the time for the payment of any claim for interest on any of the Bonds and shall not, directly or indirectly, be a party to the approval of any such arrangement by purchasing or funding said claims for interest or in any other manner. In case any such claim for interest shall be extended or funded, whether or not with the consent of the City, such claim for interest so extended or funded shall not be entitled, in case of default hereunder, to the benefits of this Resolution of Issuance, except subject to the prior payment in full of the principal of all of the Bonds then Outstanding and of all claims for interest which shall not have so extended or funded. Section 5.04. Against Encumbrances. The City will not encumber, pledge or place any charge or lien upon any of the Special Tax Revenues or other amounts pledged to the Bonds superior to or on a parity with the pledge and lien herein created for the benefit of the Bonds, except as permitted by this Resolution of Issuance. Section 5.05. Books and Records. The City will keep, or cause to be kept, proper books of record and accounts, separate from all other records and accounts of the City, in which complete and correct entries shall be made of all transactions relating to the expenditure of amounts disbursed from the Administrative Expense Fund and the Special Tax Fund and to the Special Tax Revenues. Such books of record and accounts shall at all times during business hours be subject to the inspection of the Agent and the Owners of not less than ten percent (10 %) of the principal amount of the Bonds then Outstanding, or their representatives duly authorized in writing. Section 5.06. Protection of Security and Rights of Owners. The City will preserve and protect the security of the Bonds and the rights of the Owners, and will warrant and defend their rights against all claims and demands of all persons. From and after the delivery of any of the Bonds by the City, the Bonds shall be incontestable by the City. Section 5.07. Compliance with Law, Completion of Project. The City will comply with all applicable provisions of the Act and law in completing the construction and acquisition of the Project. Section 5.08. Private Business Use Limitation. The City shall assure that: (A) not in excess of ten percent (10 %) of the Proceeds of the Bonds is used for Private Business Use if, in addition, the payment of the principal of, or the interest on more than' 10 percent of the Proceeds of the Bonds is (under the terms of the Bonds or any underlying arrangement) directly or indirectly, (i) secured by any interest in property, or payments in respect - 21 - of property, used or to be used for a Private Business Use, or (ii) to be derived from payments (whether or not to the City) in respect of property, or borrowed money, used or to be used for a Private Business Use; and (B) in the event that in excess of 5 percent of the Proceeds of the Bonds is used for a Private Business Use, and, in addition, the payment of the principal of, or the interest on, more than 5 percent of the Proceeds of the Bonds is, (under the terms of the Bonds or any underlying arrangement) directly or indirectly, secured by any interest in property, or payments in respect of property, used or to be used for said Private Business Use or is to be derived from payments (whether or not to the City) in respect of property, or borrowed money, used or to be used for a Private Business Use, then, (a) said excess over said 5 percent of the Proceeds of the Bonds which is used for a Private Business Use shall be used for a Private Business Use related to a government use of such Proceeds and (b) each such Private Business use over five percent of the Proceeds of the Bonds which is related to a government use of such Proceeds shall not exceed the amount of such Proceeds which is used for the government use of Proceeds to which such Private Business Use is related. Section 5.09. Private Loan Limitation. The City shall assure that not in excess of the lesser of five percent (5 %) of the Proceeds of the Bonds or $5,000,000 is to be used, directly or indirectly, to make or finance loans (other than loans constituting Nonpurpose Investments and other than loans which enable the borrower to finance any governmental tax or assessment of general application for a specific essential governmental function) to persons other than state or local government units. Section 5.10. Collection of Special Tax Revenues. The City shall comply with all requirements of the Act and this Resolution of Issuance so as to assure the timely collection of Special Tax Revenues, including without limitation, the enforcement of delinquent Special Taxes. On or within five (5) Business Days of each June 1, the Treasurer shall determine the amounts then on deposit in the Bond Fund and the Reserve Fund, and determine that the Special Taxes may need to be levied pursuant to the Ordinance as necessary to provide for Annual Debt Service and Administrative Expenses and replenishment (if necessary) of the Reserve Fund so that the balance therein equals the Reserve Requirement. The Treasurer shall then communicate with the Auditor to ascertain the relevant parcels on which the Special Taxes are to be levied, taking into account any parcel splits, or other changes in parcel configurations in the CFD during the preceding and then current year. The Treasurer shall effect the levy of the Special Taxes each Fiscal Year in accordance with the Ordinance by each August 1 that the Bonds are outstanding, such that the computation of the levy is complete before the final date on which Auditor will accept the transmission of the Special Tax amounts for the parcels within the CFD for inclusion on the next real property tax roll. Upon the completion of the computation of the amounts of the levy, the Treasurer shall prepare or cause to be prepared, and shall transmit to the Auditor, such data as the Auditor requires to include the levy of the Special Taxes on the next real property tax roll. The Treasurer shall fix and levy the amount of Special Taxes within the CFD required for the payment of principal of and interest on any outstanding Bonds of the CFD becoming due and payable during the ensuing year, including any necessary replenishment or expenditure of the Reserve Fund for the Bonds and an amount estimated to be sufficient to pay the Administrative Expenses during such year. The Special Taxes so levied shall not exceed the authorized amounts as provided in the proceedings pursuant to the Resolution of Formation. The Special Taxes shall be payable and be collected in the same manner and at the same time and in the same installment as the general taxes on real property are payable, and have the - 22 - same priority, become delinquent at the same time and in the same proportionate amounts and bear the same proportionate penalties and interest after delinquency as do the general taxes on real property. Section 5.11. Further Assurances. The City will adopt, make, execute and deliver any and all such further resolutions, instruments and assurances as may be reasonably necessary or proper to carry out the intention or to facilitate the performance of this Resolution of Issuance, and for the better assuring and confirming unto the Owners of the rights and benefits provided in this Resolution of Issuance. Section 5.12. No Arbitrage. The City shall not take, or permit or suffer to be taken by the Treasurer or otherwise, any action with respect to the Gross Proceeds of the Bonds which if such action had been reasonably expected to have been taken, or had been deliberately and intentionally taken, on the Closing Date would have caused the Bonds to be "arbitrage bonds" within the meaning of Section 148(a) of the Code and the Regulations. Section 5.13. Federal Guarantee Prohibition. The City shall not take any action or permit or suffer any action to be taken if the result of the same would be to cause the Bonds to be "federally guaranteed" within the meaning of Section 149(b) of the Code and the Regulations. Section 5.14. Compliance with the Code. The City covenants to take any and all action and to refrain from taking such action, which is necessary in order to comply with the Code or amendments thereto in order to maintain the exclusion from federal gross income, pursuant to Section 103 of the Code, of the interest on the Bonds paid by the City and received by the Owners. Section 5.15. Covenant to Foreclose. Pursuant to Section 3 -16610 of the Act, the City hereby covenants with and for the benefit of the owners of the Bonds that it will order, and cause to be commenced not later than the first day of August following the date of notice to the City of a delinquency, and thereafter diligently prosecute, an action in the superior court to foreclose the lien of any Special Tax or installment thereof not paid when due. The Treasurer shall notify the City Attorney of any such delinquency of which it is aware, and the City Attorney shall commence, or cause to be commenced, such proceedings. ARTICLE VI INVESTMENTS, DISPOSITION OF INVESTMENT PROCEEDS, LIABILITY OF THE CITY Section 6.01. Deposit and Investment of Moneys in Funds. Subject in all respects to the provisions of Section 6.02, moneys in any fund or account created or established by this Resolution of Issuance and held by the Treasurer shall be invested by the Treasurer in Permitted Investments. Subject in all respects to the provisions of Section 6.02, moneys in any fund or account created or established by this Resolution of Issuance and held by the Treasurer shall be invested by the Treasurer in any lawful investments that the City may make or in any Permitted Investment, which in any event by their terms mature prior to the date on which such moneys are required to be paid out hereunder. Obligations purchased as an investment of moneys in any fund shall be deemed to be part of such fund or account, subject, however, to the requirements of this Resolution of Issuance for transfer of interest earnings and profits resulting from investment of amounts in funds and accounts. Whenever in this Resolution of Issuance any moneys are required to be transferred by the City to the Agent, such transfer may be accomplished by transferring a like amount of Permitted Investments. The Treasurer may act as principal or agent in the acquisition or disposition of any investment. The Treasurer shall not incur any liability for losses arising from any investments made pursuant to this Section. For purposes of determining the amount on deposit in any fund or account held hereunder, all Permitted Investments or investments credited to such fund or account shall be valued at the cost thereof (excluding accrued interest and brokerage commissions, if any). Subject in all respects to the provisions of Section 6.02, investments in any and all funds and accounts may be commingled in a separate fund or funds for purposes of making, holding and disposing of investments, notwithstanding provisions herein for transfer to or holding in or to the credit of particular funds or accounts of amounts received or held by the Agent or the Treasurer hereunder, provided that the Agent or the Treasurer, as applicable, shall at all times account for such investments strictly in accordance with the funds and accounts to which they are credited and otherwise as provided in this Resolution of Issuance. The Treasurer shall sell at the highest price reasonably obtainable, or present for redemption, any investment security whenever it shall be necessary to provide moneys to meet any required payment, transfer, withdrawal or disbursement from the fund or account to which such investment security is credited and the Treasurer shall not be liable or responsible for any loss resulting from the acquisition or disposition of such investment security in accordance herewith. Section 6.02. Rebate of Excess Investment Earnings to the United States. The City hereby covenants to calculate or cause to be calculated and rebate to the federal government, in accordance with the Regulations, excess investment earnings to the extent required by section 148(f) of the Code. The Agent hereby agrees to cooperate with the City in connection with the City's calculation of any rebate due. The Treasurer, at the direction of the City, shall withdraw from the earnings on amounts in the Reserve Fund any amounts required to be rebated to the federal government. Any fees or expenses incurred by the Agent or the City under or pursuant to this Section 6.02 shall be Administrative Expenses. In order to provide for the administration of this Section 6.02, the City or the Treasurer may provide for the employment of independent attorneys, accountants and consultants compensated on such reasonable basis as the City may deem appropriate, and in addition and without limitation of the provisions of Section 7.02, the Treasurer may rely conclusively upon and shall be fully protected from all liability in relying upon the opinions, calculations, determinations - 24 - and advice of such attorneys, accountants and consultants employed hereunder, and upon any directions of the City delivered pursuant to this Section 6.02. Section 6.03. Limited Obligation. The City's obligations hereunder are limited obligations of the City on behalf of the CFD and are payable solely from and secured solely by the Special Tax Revenues and the amounts in the Special Tax Fund, the Improvement Fund, the Bond Fund and the Reserve Fund created hereunder. Section 6.04. Liability of City. The City shall not incur any responsibility in respect of the Bonds or this Resolution of Issuance other than in connection with the duties or obligations explicitly herein or in the Bonds assigned to or imposed upon it. The City shall not be liable in connection with the performance of its duties hereunder, except for its own negligence or willful default. The City shall not be bound to ascertain or inquire as to the performance or observance of any of the terms, conditions covenants or agreements of the Agent herein or of any of the documents executed by the Agent in connection with the Bonds, or as to the existence of a default or event of default thereunder. In the absence of bad faith, the City, including the Treasurer, may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed therein, upon certificates or opinions furnished to the City and conforming to the requirements of this Resolution of Issuance. The City, including the Treasurer, shall not be liable for any error of judgment made in good faith unless it shall be proved that it was negligent in ascertaining the pertinent facts. No provision of this Resolution of Issuance shall require the City to expend or risk its own general funds or otherwise incur any financial liability (other than with respect to the Special Tax Revenues) in the performance of any of its obligations hereunder, or in the exercise of any of its rights or powers, if it shall have reasonable grounds for believing that repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. The City may rely and shall be protected in acting or refraining from acting upon any notice, resolution, request, consent, order, certificate, report, warrant, bond or other paper or document believed by it to be genuine and to have been signed or presented by the proper party or proper parties. The City may consult with counsel, who may be the City Attorney, with regard to legal questions, and the opinion of such counsel shall be full and complete authorization and protection in respect of any action taken or suffered by it hereunder in good faith and in accordance therewith. The City shall not be bound to recognize any person as the Owner of a Bond unless and until such Bond is submitted for inspection, if required, and his title thereto satisfactory established, if disputed. Whenever in the administration of its duties under this Resolution of Issuance the City shall deem it necessary or desirable that a matter be proved or established prior to taking or suffering any action hereunder, such matter (unless other evidence in respect thereof be herein specifically prescribed) may, in the absence of willful misconduct on the part of the City, be deemed to be conclusively proved and established by a certificate of the Agent, and such certificate shall be full warrant to the City for any action taken or suffered under the provisions of this Resolution of Issuance or any Supplemental Resolution upon the faith thereof, but in its discretion the City may, in lieu thereof, accept other evidence of such matter or may require such additional evidence as to it may seem reasonable. Section 6.05. Employment of Agents by City. In order to perform its duties and obligations hereunder, the City and /or the Treasurer may employ such persons or entities as it deems necessary or advisable. The City shall not be liable for any of the acts or omissions of such - 25 - persons or entities employed by it in good faith hereunder, and shall be entitled to rely, and shall be fully protected in doing so, upon the opinions, calculations, determinations and directions of such persons or entities. ARTICLE VII THE AGENT Section 7.01. Appointment of Agent. Security Pacific National Bank, at its principal corporate trust department in Los Angeles, California is hereby appointed registrar, authentication agent, transfer agent, and paying agent and paying agent for the Bonds and the Treasurer is hereby authorized and directed to enter into an agreement with the Agent for such purposes. The Agent undertakes to perform such duties, and only such duties, as are specifically set forth in this Resolution of Issuance, and no implied covenants or obligations shall be read into this Resolution of Issuance against the Agent. Any company into which the Agent may be merged or converted or with which it may be consolidated or any company resulting from any merger, conversion or consolidation to which it shall be a party or any company to which the Agent may sell or transfer all or substantially all of its corporate trust business, provided such company shall be eligible under the following paragraph of this Section, shall be the successor to such Agent without the execution or filing of any paper or any further act, anything herein to the contrary notwithstanding. The City may remove the Agent initially appointed, and any successor thereto, and may appoint a successor or successors thereto, but any such successor shall be a bank or trust company having a combined capital (exclusive of borrowed capital) and surplus of at least Fifty Million Dollars ($50,000,000), and subject to supervision or examination by federal or state authority. If such bank or trust company publishes a report of condition at least annually, pursuant to law or to the requirements of any supervising or examining authority above referred to, then for the purposes of this Section 7.01, combined capital and surplus of such bank or trust company shall be deemed to be its combined capital and surplus as set forth in its most recent report of condition so published. The Agent may at any time resign by giving written notice to the City and by giving to the Owners notice by mail of such resignation. Upon receiving notice of such resignation, the City shall promptly appoint a successor Agent by an instrument in writing.Any resignation or removal of the Agent shall become effective upon acceptance of appointment by the successor Agent. If no appointment of a successor Agent shall be made pursuant to the foregoing provisions of this Section within forty -five (45) days after the Agent shall have given to the City written notice or after a vacancy in the office of the Agent shall have occurred by reason of its inability to act, the Agent or any Owner may apply to any court of competent jurisdiction to appoint a successor Agent. Said court may thereupon, after such notice, if any, as such court may deem proper, appoint a successor Agent. If, by reason of the judgment of any court, the Agent is rendered unable to perform its duties hereunder, all such duties and all of the rights and powers of the Agent hereunder shall be assumed by and vest in the Treasurer of the City in trust for the benefit of the Owners. The City covenants for the direct benefit of the Owners that its Treasurer in such case shall be vested with all of the rights and powers of the Agent hereunder, and shall assume all of the responsibilities and perform all of the duties of the Agent hereunder, in trust for the benefit of the Owners of the Bonds. Section 7.02. Liability of Agent. The recitals of facts, covenants and agreements herein and in the Bonds contained shall be taken as statements, covenants and agreements of the City, and the Agent assumes no responsibility for the correctness of the same, or makes any representations as to the validity or sufficiency of this Resolution of Issuance or of the Bonds, or - 27 - shall incur any responsibility in respect thereof, other than in connection with the duties or obligations herein or in the Bonds assigned to or imposed upon it. The Agent shall not be liable in connection with the performance of its duties hereunder, except for its own negligence or willful default. The Agent assumes no responsibility or liability for any information, statement or recital in any offering memorandum or other disclosure material prepared or distributed with respect to the issuance of the Bonds. In the absence of bad faith, the Agent may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed therein, upon certificates or opinions furnished to the Agent and conforming to the requirements of this Resolution of Issuance; but in the case of any such certificates or opinions by which any provision hereof are specifically required to be furnished to the Agent, the Agent shall be under a duty to examine the same to determine whether or not they conform to the requirements of this Resolution of Issuance. Except as provided above in this paragraph, Agent shall be protected and shall incur no liability in acting or proceeding, or in not acting or not proceeding, in good faith, reasonably and in accordance with the terms of this Resolution of Issuance, upon any resolution, order, notice, request, consent or waiver, certificate, statement, affidavit, or other paper or document which it shall in good faith reasonably believe to be genuine and to have been adopted or signed by the proper person or to have been prepared and furnished pursuant to any provision of this Resolution of Issuance, and the Agent shall not be under any duty to make any investigation or inquiry as to any statements contained or matters referred to in any such instrument. The Agent shall not be liable for any error of judgment made in good faith by a responsible officer unless it shall be proved that the Agent was negligent in ascertaining the pertinent facts. No provision of this Resolution of Issuance shall require the Agent to expend or risk its own funds or otherwise incur any financial liability in the performance of any of its duties hereunder, or in the exercise of any of its rights or powers, if it shall have reasonable grounds for believing that repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. The Agent shall be under no obligation to exercise any of the rights or powers vested in it by this Resolution of Issuance at the request or direction of any of the Owners pursuant to this Resolution of Issuance unless such Owners shall have offered to the Agent reasonable security or indemnity against the costs, expenses and liabilities which might be incurred by it in compliance with such request or direction. The Agent may become the owner of the Bonds with the same rights it would have if it were not the Agent. Section 7.03. Information. The Agent shall provide to the City such information relating to the Bonds and any funds and accounts maintained by the Agent hereunder as the City shall reasonably request, including but not limited to quarterly statements reporting any funds held and transactions by the Agent. Section 7.04. Notice to Agent. The Agent may rely and shall be protected in acting or refraining from acting upon any notice, resolution, request, consent, order, certificate, report, warrant, Bond or other paper or document believed by it to be genuine and to have been signed or presented by the proper party or proper parties. The Agent may consult with counsel, who may be counsel to the City, with regard to legal questions, and the opinion of such counsel shall be full and complete authorization and protection in respect of any action taken or suffered by it hereunder in good faith and in accordance therewith. - 28 - The Agent shall not be bound to recognize any person as the Owner of a Bond unless and until such Bond is submitted for inspection, if required, and his title thereto satisfactorily established, if disputed. Whenever in the administration of its duties under this Resolution of Issuance the Agent shall deem it necessary or desirable that a matter be proved or established prior to taking or suffering any action hereunder, such matter (unless other evidence in respect thereof be herein specifically prescribed) may, in the absence of willful misconduct on the part of the Agent, be deemed to be conclusively proved and established by an officer's certificate, and such certificate shall be full warrant to the Agent for any action taken or suffered under the provisions of this Resolution of Issuance or any Supplemental Resolution upon the faith thereof, but in its discretion the Agent may, in lieu thereof, accept other evidence of such matter or may require such additional evidence as to it may seem reasonable. Section 7.05. Compensation, Indemnification. The City shall pay to the Agent from time to time reasonable compensation for all services rendered as Agent under this Resolution of Issuance, and also all reasonable expenses, charges, counsel fees and other disbursements, including those of their attorneys, agents and employees, incurred in and about the performance of their powers and duties under this Resolution of Issuance, but the Agent shall not have a lien therefor on any funds at any time held by it under this Resolution of Issuance. The City further agrees, to the extent permitted by applicable law, to indemnify and save the Agent, its officers, employees, directors and agents harmless against any liabilities which it may incur in the exercise and performance of its powers and duties hereunder which are not due to its negligence or willful misconduct. The obligation of the City under this Section shall survive resignation or removal of the Agent under this Resolution of Issuance and payment of the Bonds and discharge of this Resolution of Issuance, but any monetary obligation of the City arising under this Section shall be limited solely to amounts on deposit in the Administrative Expense Fund. ARTICLE VIII MODIFICATION OR AMENDMENT OF THIS RESOLUTION OF ISSUANCE Section 8.01. Amendments Permitted. This Resolution of Issuance and the rights and obligations of the City and of the Owners of the Bonds may be modified or amended at any time by a Supplemental Resolution pursuant to the affirmative vote at a meeting of Owners, or with the written consent without a meeting, of the Owners of at least sixty percent (60 %) in aggregate principal amount of the Bonds then Outstanding, exclusive of Bonds disqualified as provided in Section 8.04. No such modification or amendment shall (i) extend the maturity of any Bond or reduce the interest rate thereon, or otherwise alter or impair the obligation of the City to pay the principal of, and the interest and any premium on, any Bond, without the express consent of the Owner of such Bond, or (ii) permit the creation by the City of any pledge or lien upon the Special Taxes superior to or on a parity with the pledge and lien created for the benefit of the Bonds (except as otherwise permitted by the Act, the laws of the State of California or this Resolution of Issuance), or reduce the percentage of Bonds required for the amendment hereof. Any such amendment may not modify any of the rights or obligations of the Agent without its written consent. This Resolution of Issuance and the rights and obligations of the City and of the Owners may also be modified or amended at any time by a Supplemental Resolution, without the consent of any Owners, only to the extent permitted by law and only for any one or more of the following purposes: (a) to add to the covenants and agreements of the City in this Resolution of Issuance contained, other covenants and agreements thereafter to be observed, or to limit or surrender any right or power herein reserved to or conferred upon the City; (b) to make modifications not adversely affecting affecting any outstanding series of Bonds of the City in any material respect; (c) to make such provisions for the purpose of curing any ambiguity, or of curing, correcting or supplementing any defective provision contained in this Resolution of Issuance, or in regard to questions arising under this Resolution of Issuance, as the City and the Agent may deem necessary or desirable and not inconsistent with this Resolution of Issuance, and which shall not adversely affect the rights of the Owners of the Bonds; (d) to make such additions, deletions or modifications as may be necessary or desirable to assure compliance with section 148 of the Code relating to required rebate of Excess Investment Earnings to the United States or otherwise as may be necessary to assure exclusion from gross income for federal income tax purposes of interest on the Bonds or to conform with the Regulations. Section 8.02. Owners' Meetings. The City may at any time call a meeting of the Owners. In such event the City is authorized to fix the time and place of said meeting and to provide for the giving of notice thereof, and to fix and adopt rules and regulations for the conduct of said meeting. Section 8.03. Procedure for Amendment with Written Consent of Owners. The City and the Agent may at any time adopt a Supplemental Resolution amending the provisions of the Bonds or of this Resolution of Issuance or any Supplemental Resolution, to the extent that such amendment is permitted by Section 8.01, to take effect when and as provided in this Section. A copy of such Supplemental Resolution, together with a request to Owners for their consent - 30 - thereto, shall be mailed by first class mail, by the Agent to each Owner of Bonds Outstanding, but failure to mail copies of such Supplemental Resolution and request shall not affect the validity of the Supplemental Resolution when assented to as in this Section provided. Such Supplemental Resolution shall not become effective unless there shall be filed with the Agent the written consents of the Owners of at least sixty percent (60 %) in aggregate principal amount of the Bonds then Outstanding (exclusive of Bonds disqualified as provided in Section 8.04 and a notice shall have been mailed as hereinafter in this Section provided. Each such consent shall be effective only if accompanied by proof of ownership of the Bonds for which such consent is given, which proof shall be such as is permitted by Section 9.04. Any such consent shall be binding upon the Owner of the Bonds giving such consent and on any subsequent Owner (whether or not such subsequent Owner has notice thereof) unless such consent is revoked in writing by the Owner giving such consent or a subsequent Owner by filing such revocation with the Agent prior to the date when the notice hereinafter in this Section provided for has been mailed After the Owners of the required percentage of Bonds shall have filed their consents to the Supplemental Resolution, the City shall mail a notice to the Owners in the manner hereinbefore provided in this Section for the mailing of the Supplemental Resolution, stating in substance that the Supplemental Resolution has been consented to by the Owners of the required percentage of Bonds and will be effective as provided in this Section (but failure to mail copies of said notice shall not affect the validity of the Supplemental Resolution or consents thereto). Proof of the mailing of such notice shall be filed with the Agent. A record, consisting of the papers required by this Section 8.03 to be filed with the Agent, shall be proof of the matters therein stated until the contrary is proved. The Supplemental Resolution shall become effective upon the filing with the Agent of the proof of mailing of such notice, and the Supplemental Resolution shall be deemed conclusively binding (except as otherwise hereinabove specifically provided in this Article) upon the City and the Owners of all Bonds at the expiration of sixty (60) days after such filing, except in the event of a final decree of a court of competent jurisdiction setting aside such consent in a legal action or equitable proceeding for such purpose commenced within such sixty -day period. Section 8.04. Disqualified Bonds. Bonds owned or held for the account of the City, excepting any pension or retirement fund, shall not be deemed Outstanding for the purpose of any vote, consent or other action or any calculation of Outstanding Bonds provided for in this Article VIII, and shall not be entitled to vote upon, consent to, or take any other action provided for in this Article VIII. Section 8.05. Effect of Supplemental Resolution. From and after the time any Supplemental Resolution becomes effective pursuant to this Article VIII, this Resolution of Issuance shall be deemed to be modified and amended in accordance therewith, the respective rights, duties and obligations under this Resolution of Issuance of the City and all Owners of Bonds Outstanding shall thereafter be determined, exercised and enforced hereunder subject in all respects to such modifications and amendments, and all the terms and conditions of any such Supplemental Resolution shall be deemed to be part of the terms and conditions of this Resolution of Issuance for any and all purposes. Section 8.06. Endorsement or Replacement of Bonds Issued After Amendments. The City may determine that Bonds issued and delivered after the effective date of any action taken as provided in this Article VIII shall bear a notation, by endorsement or otherwise, in form approved by the City, as to such action. In that case, upon demand of the Owner of any Bond Outstanding at such effective date and presentation of his Bond for that purpose at the Principal Office of the Agent or at such other office as the City may select and designate for that purpose, a suitable notation shall be made on such Bond. The City may determine that new Bonds, so modified as in the opinion of the City is necessary to conform to such Owners' action, shall be prepared, executed and delivered. In that case, upon demand of the Owner of any Bonds - 31 - then Outstanding, such new Bonds shall be exchanged at the Principal Office of the Agent without cost to any Owner, for Bonds then Outstanding, upon surrender of such Bonds. Section 8.07. Amendatory Endorsement of Bonds. The provisions of this Article VIII shall not prevent any Owner from accepting any amendment as to the particular Bonds held by him, provided that due notation thereof is made on such Bonds. ARTICLE IX MISCELLANEOUS Section 9.01. Benefits of Agreement Limited to Parties. Nothing in this Resolution of Issuance, expressed or implied, is intended to give to any person other than the City, the Agent and the Owners, any right, remedy, claim under or by reason of this Resolution of Issuance. Any covenants, stipulations, promises or agreements in this Resolution of Issuance contained by and on behalf of the City shall be for the sole and exclusive benefit of the Owners and the Agent. Section 9.02. Successor is Deemed Included in All References to Predecessor. Whenever in this Resolution of Issuance or any Supplemental Resolution either the City or the Agent is named or referred to, such reference shall be deemed to include the successors or assigns thereof, and all the covenants and agreements in this Resolution of Issuance contained by or on behalf of the City or the Agent shall bind and inure to the benefit of the respective successors and assigns thereof whether so expressed or not. Section 9.03. Discharge of Resolution of Issuance. The City shall have the option to pay and discharge the entire indebtedness on all or any portion of the Bonds Outstanding in any one or more of the following ways: (A) by well and truly paying or causing to be paid the principal of, and interest and any premium on, such Bonds Outstanding, as and when the same become due and payable; (B) by depositing with the Agent, in trust, at or before maturity, money which, together with the amounts then on deposit in the funds and accounts provided for in Sections 4.02 and 4.03 is fully sufficient to pay such Bonds Outstanding, including all principal, interest and redemption premiums; or (C) by irrevocably depositing with the Agent, in trust, cash and Federal Securities in such amount as the City shall determine as confuuied by an independent certified public accountant will, together with the interest to accrue thereon and moneys then on deposit in the fund and accounts provided for in Sections 4.02 and 4.03, be fully sufficient to pay and discharge the indebtedness on such Bonds (including all principal, interest and redemption premiums) at or before their respective maturity dates. If the City shall have taken any of the actions specified in (A), (B) or (C) above, and if such Bonds are to be redeemed prior to the maturity thereof notice of such redemption shall have been given as in this Resolution of Issuance provided or provision satisfactory to the Agent shall have been made for the giving of such notice, then, at the election of the City, and notwithstanding that any Bonds shall not have been surrendered for payment, the pledge of the Special Taxes and other funds provided for in this Resolution of Issuance and all other obligations of the City under this Resolution of Issuance with respect to such Bonds Outstanding shall cease and terminate. Notice of such election shall be filed with the Agent. Notwithstanding the foregoing, the obligation of the City to pay or cause to be paid to the Owners of the Bonds not so surrendered and paid all sums due thereon and all amounts owing to the Agent pursuant to Section 7.05 shall continue in any event. Upon compliance by the City with the foregoing with respect to all Bonds Outstanding, any funds held by the Agent after payment of all fees and expenses of the Agent, which are not required for the purposes of the preceding paragraph, shall be paid over to the City and any Special - 33 - Taxes thereafter received by the City shall not be remitted to the Agent but shall be retained by the City to be used for any purpose permitted under the Act. Section 9.04. Execution of Documents and Proof of Ownership by Owners. Any request, declaration or other instrument which this Resolution of Issuance may require or permit to be executed by Owners may be in one or more instruments of similar tenor, and shall be executed by Owners in person or by their attorneys appointed in writing. Except as otherwise herein expressly provided, the fact and date of the execution by any Owner or his attorney of such request, declaration or other instrument, or of such writing appointing such attorney, may be proved by the certificate of any notary public or other officer authorized to take acknowledgments of deeds to be recorded in the state in which he purports to act, that the person signing such request, declaration or other instrument or writing acknowledged to him the execution thereof, or by an affidavit of a witness of such execution, duly sworn to before such notary public or other officer. Except as otherwise herein expressly provided, the ownership of registered Bonds and the amount, maturity, number and date of holding the same shall be proved by the registry books. Any request, declaration or other instrument or writing of the Owner of any Bond shall bind all future Owners of such Bond in respect of anything done or suffered to be done by the City or the Agent in good faith and in accordance therewith. Section 9.05. Waiver of Personal Liability. No member, officer, agent or employee of the City shall be individually or personally liable for the payment of the principal of, or interest or any premium on, the Bonds; but nothing herein contained shall relieve any such member, officer, agent or employee from the performance of any official duty provided by law. Section 9.06. Notices to and Demands on City and Agent. Any notice or demand which by any provision of this Resolution of Issuance is required or permitted to be given or served by the Agent to or on the City may be given or served by being deposited postage prepaid in a post office letter box addressed (until another address is filed by the City with the Agent) as follows: City of Alameda 2263 Santa Clara Avenue Alameda, California 94501 Attention: Director of Finance Any notice or demand which by any provision of this Resolution of Issuance is required or permitted to be given or served by the City to or on the Agent may be given or served by being deposited postage prepaid in a post office letter box addressed (until another address is filed by the Agent with the City) as follows: Security Pacific National Bank Corporate Trust Department P.O. Box 7887 33 New Montgomery, 1lth Floor San Francisco, CA 94105 Attn: Loyce Harrison, Assistant Vice President Section 9.07. Partial Invalidity. If any Section, paragraph, sentence, clause or phrase of this Resolution of Issuance shall for any reason be held illegal or unenforceable, such - 34 - holding shall not affect the validity of the remaining portions of this Resolution of Issuance. The City hereby declares that it would have adopted this Resolution of Issuance and each and every other Section, paragraph, sentence, clause or phrase hereof and authorized the issue of the Bonds pursuant thereto irrespective of the fact that any one or more Sections, paragraphs, sentences, clauses, or phrases of this Resolution of Issuance may be held illegal, invalid or unenforceable. Section 9.08. Unclaimed Moneys. Anything contained herein to the contrary notwithstanding, any moneys held by the Agent in trust for the payment and discharge of the principal of, and the interest and any premium on, the Bonds which remains unclaimed for three (3) years after the date when the payments of such principal, interest and premium have become payable, if such moneys was held by the Agent at such date, shall be repaid by the Agent to the City as its absolute property free from any trust, and the Agent shall thereupon be released and discharged with respect thereto and the Bond Owners shall look only to the City for the payment of the principal of, and interest and any premium on, such Bonds. Section 9.09. Applicable Law. This Resolution of Issuance shall be governed by and enforced in accordance with the laws of the State of California applicable to contracts made and performed in the State of California. Section 9.10. Conflict with Act. In the event of a conflict between any provision of this Resolution of Issuance with any provision of the Act as in effect on the Closing Date, the provision of the Act shall prevail over the conflicting provision of this Resolution of Issuance. Section 9.11. Conclusive Evidence of Regularity. Bonds issued pursuant to this Resolution of Issuance shall constitute conclusive evidence of the regularity of all proceedings under the Act relative to their issuance and the levy of the Special Taxes. Section 9.12. Payment on Business Day. In any case where the date of the maturity of interest or of principal (and premium, if any) of the Bonds or the date fixed for redemption of any Bonds or the date any action is to be taken pursuant to this Resolution of Issuance is other than a Business Day, the payment of interest or principal (and premium, if any) or the action need not be made on such date but may be made on the next succeeding day which is a Business Day with the same force and effect as if made on the date required and no interest shall accrue for the period after such date. Section 9.13. Effective Date. This Resolution of Issuance shall be effective upon the date of its adoption. FORM OF BOND No. $ UNITED STATES OF AMERICA STATE OF CALIFORNIA COUNTY OF ALAMEDA CITY OF ALAMEDA COMMUNITY FACILITIES DISTRICT NO. 2 (PARAGON GATEWAY) SERIES 1990, SPECIAL TAX BOND INTEREST RATE MATURITY DATE DATED DATE CUSIP December 1, 1990 REGISTERED OWNER: PRINCIPAL AMOUNT: DOLLARS The City of Alameda (the "City ") for and on behalf of Community Facilities District No. 2 (Paragon Gateway) (the "CFD "), for value received, hereby promises to pay solely from the Special Tax (as hereinafter defined) to be collected in the CFD or amounts in the funds and accounts held under the Resolution of Issuance (as hereinafter defined), to the registered owner named above, or registered assigns, on the maturity date set forth above, unless redeemed prior thereto as hereinafter provided, the principal amount set forth above, and to pay interest on such principal amount from December 1, 1990, or from the most recent interest payment date to which interest has been paid or duly provided for, semiannually on September 1 and March 1, commencing September 1, 1991, at the interest rate set forth above, until the principal amount hereof is paid or made available for payment. The principal of this Bond is payable to the registered owner hereof in lawful money of the United States of America upon presentation and surrender of this Bond at the principal corporate trust department of Security Pacific National Bank, in Los Angeles, California (the "Agent "). Interest on this Bond shall be paid by check of the Agent mailed by first class mail on each interest payment date to the registered owner hereof as of the close of business on the 15th day of the month preceding the month in which the interest payment date occurs (the "Record Date ") at such registered owner's address as it appears on the registration books maintained by the Agent. REFERENCE IS HEREBY MADE TO THE FURTHER PROVISIONS OF THIS BOND SET FORTH ON THE REVERSE SIDE HEREOF, WHICH FURTHER PROVISIONS SHALL FOR ALL PURPOSES HAVE THE SAME EFFECT AS IF FULLY SET FORTH IN THIS PLACE. EXHIBIT A Page 1 The Resolution of Issuance and the rights and obligations of the City thereunder may be modified or amended as set forth therein. This Bond shall not become valid or obligatory for any purpose until the certificate of authentication and registration hereon endorsed shall have been dated and signed by the Agent. IT IS HEREBY CERTIFIED, RECITED AND DECLARED that all acts, conditions and things required by law to exist, happen and be performed precedent to and in the issuance of this Bond have existed, happened and been performed in due time, form and manner as required by law, and that the amount of this Bond does not exceed any debt limit prescribed by the laws or Constitution of the State of California. IN WITNESS WHEREOF, City of Alameda has caused this Bond to be dated December 1, 1990, to be signed by the facsimile signature of its Mayor and countersigned by the facsimile signature of the City Clerk. [S E A L] CITY OF ALAMEDA By: Mayor AIIEST: City Clerk EXHIBIT A Page 2 [FORM OF BACK OF BOND] This Bond is one of a duly authorized issue of bonds in the maximum aggregate principal amount of $2,1.00,000 approved by the qualified electors of the CFD on November 20, 1990 pursuant to Chapter 16 of Title 11I of the Alameda Municipal Code (the "Act) for the purpose of financing the acquisition of certain facilities in the vicinity of the CFD (the "Project "), and is one of the series of Bonds designated "City of Alameda, Community Facilities District No. 2 (Paragon Gateway), Series 1990, Special Tax Bonds" in the aggregate principal amount of $1,615,000 (the "Bonds "). The creation of the Bonds and the terms and conditions thereof are provided for by a resolution adopted by the City Council of the City of Alameda on November 20, 1990 (the "Resolution of Issuance ") and this reference incorporates the Resolution of Issuance herein, and by acceptance hereof the owner of this Bond assents to said terms and conditions. Pursuant to and as more particularly described in the Resolution of Issuance, parity bonds may be issued by the City in a principal amount of not to exceed $485,000. The Resolution of Issuance is adopted under and this Bond is issued under, and both are to be construed in accordance with, the laws of the State of California. Pursuant to the Act, the Resolution of Issuance, the principal of and interest on this Bond are payable solely from the annual special tax authorized under the Act to be collected within the CFD (the "Special Tax ") and certain funds held under the Resolution of Issuance. Interest on this Bond shall be payable from the interest payment date next preceding the date of authentication hereof, unless (i) it is authenticated on an interest payment date, in which event it shall bear interest for such interest payment date, or (ii) such date of authentication is after a Record Date but on or prior to an interest payment date, in which event interest will be payable from such interest payment date, or (iii) such date of authentication is on or before the first Record Date, in which event interest will be payable from December 1, 1990; provided however, that if at the time of authentication of this Bond, interest is in default hereon, this Bond shall bear interest from the interest payment date to which interest has previously been paid or made available for payment hereon. Any tax for the payment hereof shall be limited to the Special Tax, except to the extent that provision for payment has been made by the City of Alameda, as may be permitted by law. The Bonds do not constitute obligations of the City of Alameda for which said City is obligated to levy or pledge, or has levied or pledged, general or special taxation other than described hereinabove. The City has covenanted for the benefit of the owners of the Bonds that it will commence within not later than the first day of August following notification of a delinquency and diligently pursue to completion appropriate foreclosure actions in the event of delinquencies of any Special Tax installments levied for payment of principal and interest. The Bonds maturing on or after September 1, 2000, are subject to optional redemption prior to their stated maturity on any Interest Payment Date on or after September 1, 1999, as a whole or in part, at a redemption price (expressed as a percentage of the principal amount of the Bonds to be redeemed), as set forth below, together with accrued interest thereon to the date fixed for redemption: Redemption Dates Redemption Prices September 1, 1999 and March 1, 2000 102% September 1, 2000 and March 1, 2001 101 September 1, 2001 and thereafter 100 EXHIBIT A Page 3 All the Bonds are subject to redemption prior to their stated maturities from proceeds of prepayments of Special Taxes, on any Interest Payment Date, in whole or in part, at a redemption price (expressed as a percentage of the principal amount of the Bonds to be redeemed) as set forth below, together with accrued interest thereon to the date fixed for redemption: Redemption Dates Redemption Prices On or prior to March 1, 1998 September 1, 1999 and March 1, 2000 September 1, 2000 and March 1, 2001 September 1, 2001 and thereafter 103% 102 101 100 All the Bonds are subject to redemption prior to their stated maturities, in whole or in part, on the next Interest Payment Date occurring at least 60 days following the transfer from the Improvement Fund to the Bond Fund of all moneys on deposit in the Improvement Fund upon completion of the Project, as certified by the Treasurer at a redemption price equal to the principal amount thereof, together with accrued interest thereon to the date of redemption, without premium. The outstanding Bonds maturing on September 1, 2016, are subject to mandatory sinking payment redemption in part on September 1, 2002, and on each September 1 thereafter to maturity, by lot, at a redemption price equal to the principal amount thereof to be redeemed, together with accrued interest to the date fixed for redemption, without premium, from sinking payments as follows: September 1 2002 2003 2004 2005 2006 2007 2008 2009 Sinking Payments $45,000 50,000 55,000 60,000 65,000 70,000 75,000 80,000 September 1 2010 2011 2012 2013 2014 2015 2016 Sinking Payments $ 90,000 95,000 100,000 110,000 120,000 130,000 140,000 Notice of redemption with respect to the Bonds to be redeemed shall be given to the registered owners thereof, in the manner, to the extent and subject to the provisions of the Resolution of Issuance. This Bond shall be registered in the name of the owner hereof, as to both principal and interest. Each registration and transfer of registration of this Bond shall be entered by the Agent in books kept by it for this purpose and authenticated by its manual signature upon the certificate of authentication endorsed hereon. No transfer or exchange hereof shall be valid for any purpose unless made by the registered owner, by execution of the form of assignment endorsed hereon, and authenticated as herein provided, and the principal hereof, interest hereon and any redemption premium shall be payable only to the registered owner or to such owner's order. The Agent shall require the registered owner requesting transfer or exchange to pay any tax or other governmental charge required to be paid with respect to such transfer or exchange. No transfer or exchange hereof shall be required to be made (i) fifteen days prior to the date established by the Agent for selection of Bonds for redemption or (ii) with respect to a Bond after such Bond has been selected for redemption. EXHIBIT A Page 4 [FRONT OF BOND] AGENT'S CERTIFICATE OF AUTHENTICATION This is one of the Bonds described in the Resolution of Issuance which has been authenticated on SECURITY PACIFIC NATIONAL BANK, as Agent By: Authorized Signatory EXHIBIT A Page 5 ASSIGNMENT For value received the undersigned do(es) hereby sell, assign and transfer unto (Name, Address and Tax Identification or Social Security Number of Assignee) the within- mentioned registered Bond and hereby irrevocably constitute(s) and appoint(s) , attorney, to transfer the same on the Bond registration books of the Agent with full power of substitution in the premises. Dated: Signature Guaranteed: Signature: NOTE: Signature(s) must be guaranteed by a member NOTE: The signature(s) on this Assignment must firm of the New York Stock Exchange or a correspond with the name(s) as written on the commercial bank or trust company. face of the within Bond in every particular without alteration or enlargement or any change whatsoever. EXHIBIT A Page 6 I, the undersigned, hereby certify that the foregoing Resolution was duly and regularly adopted and passed by the Council of the City of Alameda in regular meeting assembled on the twentieth day of November, 1990, by the following vote to wit: AYES: Councilmembers Arnerich, Camicia, Thomas, Withrow and President Corica - 5. NOES: None. ABSENT: None. ABSTENTIONS: None. IN WITNESS, WHEREOF, I have hereunto set my hand and affixed the official seal of said City this twenty -first day of November, 1990. Diane Felsch, City Clerk City of Alameda