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HomeMy WebLinkAboutSpecial Tax Refunding Bonds Series 2008 CFD No. 91-1 CITY OF PALM DESERT/PALM DESERT FINANCING AUTHORITY STAFF REPORT REQUEST: CONSIDERATION OF THE AUTHORIZATION OF ISSUANCE OF SPECIAL TAX REFUNDING BONDS, SERIES 2008, OF CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT (CFD) NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) AND APPROVAL OF RELATED DOCUMENTS SUBMITTED BY: DAVE YRIGOYEN, DIRECTOR OF REDEVELOPMENT/HOUSING DATE: DECEMBER 13, 2007 CONTENTS: RESOLUTION NO. 07-79 PALM DESERT FINANCING AUTHORITY RESOLUTION NO. FA-� FORM OF BOND INDENTURE FORM OF ESCROW AGREEMENT FORM OF BOND PURCHASE AGREEMENT FORM OF PRELIMINARY OFFICIAL STATEMENT (INCLUDES FORM OF CONTINUING DISCLOSURE AGREEMENT) Recommendation: Waive further reading and adopt: • Resolution No. 07-79 , a resolution of the City Council of the City of Palm Desert, acting for itself and as the legislative body of City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) to authorize the issuance of its special tax refunding bonds, Series 2008, in a principal amount not-to-exceed twelve million dollars ($12,000,000) and approving certain da(�uments and taking certain other actions in connection therewith. Waive further reading and adopt: • Resolution No. FA-�, a resolution of the Palm Desert Financing Authority making certain findings and determinations in connection with its 1997 revenue bonds (Assessment Districts Nos. 92-1 and 94-1 and Community Facilities District No. 91-1). Executive SummarY: Approval of the attached documents in substantially the form presented is required in order for the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) (the "Indian Ridge CFD") to issue a series of refunding special tax bonds (the "Series 2008 Bonds") to refinance the Palm Desert Financing Authority's outstanding 1997 Revenue Bonds (the "1997 Authority Bonds"). The total net present value savings will be G�roaW�a Scott�Wortl F�ies�StaH Replsun0�an R�tlge 2008 Reb Dec t3 200�DOC Staff Report Adoption of City/Financing Authority Resolutions for Issuance of Special Tax Refunding Bonds — CFD No. 91-1 (Indian Ridge Public Improvements) Page 2 of 5 December 13, 2007 10.08% or $1,604,567. This will be an annual savings of $761 per household for a total savings of $9,132 per household, over the twelve year life of the bonds. BackAround: The 1997 Authority Bonds were issued in 1997 to purchase and assist in the refinancing of three separate, smaller series of prior bonds issued to finance the public infrastructure to serve the properties within the Indian Ridge CFD, Assessment District No. 92-1 [Tierravista], and Assessment District No. 94-1 [Bighorn]. The Tierravista and Bighorn assessment district bonds have been previously prepaid, leaving only the Indian Ridge CFD bonds outstanding as sources of revenue for repayment of the 1997 Authority Bonds. The current outstanding principal amount of the 1997 Authority Bonds is $16,260,000. The monies remaining in the improvement fund established in connection with the 1997 Authority Bonds and with respect to the Indian Ridge CFD amount to approximately $5,020,741, which amount includes investment earnings accumulated on the fund. The Director of Public Works of the City and the Treasurer of the Authority have determined that the works of improvement with respect to the Indian Ridge CFD (and, therefore, the 1997 Authocity Bonds) have been completed, and all costs thereof have been paid from the improvement fund. The indenture of trust governing the 1997 Authority Bonds authorizes amounts remaining in the improvement fund to be used for prepayment of the underlying Indian Ridge CFD bonds. Therefore, the remaining balance in the improvement fund will be used to prepay a portion of the outstanding underlying Indian Ridge CFD bonds, which in turn will prepay a portion of the outstanding 1997 Authority Bonds. If adopted, Resolution No. 07-79 will authorize the Indian Ridge CFD to issue bonds in an aggregate principal amount not-to-exceed $12,000,000 designated as the "City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding Bonds, Series 2008" to refinance and defease the outstanding 1997 Authority Bands and defease the related underlying Indian Ridge CFD bonds, provided the overall interest rate does not exceed 6.00% per annum and the discount paid to the underwriter for the bonds, exclusive of original issue discount, does not exceed 1.50% of the principal amount of the bonds. As is typical for special tax bonds issued by community facilities districts established under the Act and assessment district bonds, the 1997 Authority Bonds were considered speculative in nature, due to the relationship of these bonds to real estate development, especially given the early stages of development and construction at the time of their issuance. Due to the foregoing factors, the 1997 Authority Bonds were unrated and uninsured. At this time, however, the development in the Indian Ridge development has since been completed and the homeownership diversified among many individual homeowners, rather than concentrated under the ownership of a single developer, thereby reducing certain of the risks attendant to the development and the bonds. The Mello-Roos Community Facilities Act of 2 Staff Report Adoption of City/Financing Authority Resolutions for Issuance of Special Tax Refunding Bonds— CFD No. 91-1 (Indian Ridge Public Improvements) Page 3 of 5 December 13, 2007 1982, under which the Series 2008 bonds will be issued, and the City's related Goals and Policies statement require a minimum 3 to 1 value-to-special tax lien ratio. Upon the refunding of the 1997 Authority Bonds, the assessed value-to-special tax lien ratio on the property is estimated to be at approximately 67.99 to 1, based upon projections prepared by the City's financial advisor, Del Rio Advisors, LLC. Therefore, it is expected that the Indian Ridge CFD will be able to obtain a rating(s) and a municipal bond insurance policy to insure payment of principal, interest, and redemption premium, if any, on the Series 2008 Bonds. The investors are expected to be institutional investors (such as mutual funds), and the undenNriters (Stinson Securities, LLC, and Kinsell, Newcomb & De Dios, Inc.) will sell the Series 2008 Bonds in a public offering to such investors. Due to the expected municipal bond insurance policy and related ratings to be obtained on the Series 2008 Bonds, together with the currently favorable interest rate market, the projections prepared by Del Rio Advisors, LLC, calculate projected gross savings on debt service payments (principal plus interest) to total approximately $9.76 million. Due to the availability of amounts remaining in the improvement fund and other funds related to the 1997 Authority Bonds and underlying Indian Ridge CFD bonds, which will reduce the amount of outstanding debt, the total net present value savings will be 10.08% or $1,604,567. This will be an annual savings of $761 per household for a total savings of $9,132 per household, over the twelve year life of the bonds. Again, per the projections prepared by Del Rio Advisors, LLC the average interest rate on the prior bonds is 6.25%, and the average interest rate for the new bonds is projected to be 4.05%. Resolution No. 07- 79 will also appoint the financing team with respect to the Series 2008 Bonds, who are Del Rio Advisors, LLC, as financial advisor; Stinson Securities, LLC, and Kinsell Newcomb & De Dios, Inc., as underwriters for the bonds; Richards Watson 8� Gershon, A Professional Corporation, as Bond Counsel; Lofton & Jennings, as Disclosure Counsel; Wells Fargo Bank, National Association, as trustee and escrow agent; and MuniFinancial, Inc. as special tax consultant. Resolution No. 07- 79 will also authorize certain officers of the City of Palm Desert to execute and deliver the following documents in connection with the issuance of the bonds, in substantially the form as such documents are on file with the City Clerk: (1) Bond Indenture by and between the Indian Ridge CFD and Wells Fargo Bank, National Association, as trustee (provides for the terms of the bonds) (2) Escrow Agreement, by and among the Palm Desert Financing Authority, the City, the Indian Ridge CFD, and Wells Fargo Bank, National Association, as Escrow Agent (provides for the escrow and transfer of monies to refund the 1997 Authority Bonds and the underlying Indian Ridge CFD bonds) 3 Staff Report Adoption of City/Financing Authority Resolutions for Issuance of Special Tax Refunding Bonds — CFD No. 91-1 (Indian Ridge Public Improvements) Page 4 of 5 December 13, 2007 (3) Bond Purchase Agreement by and among the fndian Ridge CFD, Stinson Securities, LLC, and Kinsell, Newcomb & De Dios, Inc., as unden�vriters for the bonds (provides for the sale of the bonds by the Indian Ridge CFD to the underwriter) (4) Preliminary Official Statement and final Official Statement for the bonds (offering documents used by the underwriter to market and sell the bonds to investors) (5) Continuing Disclosure Agreement (attached as Appendix E to the Preliminary Official Statement) by and among the Indian Ridge CFD, Wells Fargo Bank, National Association, as trustee, and MuniFinancial, Inc., as dissemination agent (governs the Indian Ridge CFD's and dissemination agent's provision of certain financial and special tax-related information on a continuing basis to the bond market). The Series 2008 Bonds will be repaid from special taxes levied on the parcels within the Indian Ridge CFD, in accordance with the rate and method of apportionment approved by the vote of the qualified electors within the Indian Ridge CFD and by this City Council. The payment of special taxes is secured by each taxable parcel in the Indian Ridge CFD. In the event special taxes become delinquent under circumstances described in the Bond Indenture, this City Council, as legislative body of the Indian Ridge CFD, will covenant in the attached resolution and in the Bond Indenture to commence and pursue foreclosure actions regarding delinquent installments of the special taxes. In addition to the reserve account to be established under the Bond Indenture (which is funded initially from bond proceeds and maintained thereafter at the prescribed amount with special tax transfers), proceeds from foreclosure sales provide back-up security in the event installments of special taxes are not paid by property owners. The offering documents disclose these sources of repayment of the Series 2008 Bonds, together with the many possible risks relating to repayment of the bonds (such as changes in the law, real estate development, natural disasters, etc.). The approved rate and method of apportionment of special taxes was prepared based on the developer's proposed development plan at the time of formation of the Indian Ridge CFD, with backup tax rates (up to a maximum tax rate) in case certain development thresholds are not met. Projections have been prepared to show that special tax revenues are expected to generate sufficient funds to repay the Series 2008 Bonds. These projections have been included in the offering documents for the bonds, together with an explanation of the assumptions used in making the projections and the associated risks. The Bond Indenture provides for the bond funds to be invested by the trustee in investments authorized for the investment of bond proceeds by the Indian Ridge CFD and City under Government Code Section 53601. The authorized types of investments will be disclosed to investors in the offering document. No future actions will be necessary. 4 Staff Report Adoption of City/Financing Authority Resolutions for Issuance of Special Tax Refunding Bonds — CFD No. 91-1 (Indian Ridge Public Improvements) Page 5 of 5 December 13, 2007 Staff recommends that the issuance of the Series 2008 Bonds to provide for the refunding of the 1997 Authority Bonds and underlying Indian Ridge CFD bonds, as outlined in the report, be authorized. Submitted by: Approval: v� � David Yrigo e J ti McCarthy Director edevelopmenUHousing ACM edevelopment Approval: Carlos L. Orte , City Manager aul S. Gibson, Director of Finance CITY COUNCIL ACTION: APPROVFD ✓ DENIED RECFIVED OTHERf o�G�£� . �� • -7 un�1 F/�- �/ MEBTING DATE �_�3_ -� AYES: �- • �� ,�� NOES: ABSENT; RBSTAIN: ( VERIFIED By; Original on File wi' City Clerk's Of�ice �i�v aUTH �-� ��?'; ,. . ... ��..�,..1.�_..�--�� �� . - _-..._ . . ��.���K n� r-3-� . . . . : , , e.�.,.�. .A r 7 Offi �-•. ...._. ,..:t ...... ..F4ic ':SY� `J����tC��S � � RESOLUTION NO. 07-79 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALM DESERT, ACTING FOR ITSELF AND AS THE LEGISLATIVE BODY OF CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) TO AUTHORIZE THE ISSUANCE OF ITS SPECIAL TAX REFUNDING BONDS, SERIES 2008, IN A PRINCIPAL AMOUNT NOT TO EXCEED TWELVE MILLION DOLLARS ($12,000,000) AND APPROVING CERTAIN DOCUMENTS AND TAKING CERTAIN OTHER ACTIONS IN CONNECTION THEREWITH RECITALS: WHEREAS, the City Council of the City of Palm Desert, located in Riverside County, California (the "City Council", and hereinafter sometimes referred to also as the "legislative body of the DistricY'), has heretofore undertaken proceedings and declared the necessity of City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) (the "District") to issue bonds pursuant to the terms and provisions of the Mello-Roos Community Facilities Act of 1982, as amended, being Chapter 2.5, Part 1, Division 2, Title 5 of the Government Code of the State of California (the "Act"); and WHEREAS, based upon Resolution Nos. 92-22 and 92-23 adopted by the legislative body of the District on March 12, 1992 and an election held March 12, 1992 authorizing the levy of a special tax and the issuance of bonds by the District, the District is authorized to issue bonds for one or more series, pursuant to the Act, in an aggregate principal amount not to exceed $35,000,000; and WHEREAS, on July 7, 1992, the District issued its $11,870,000 aggregate initial principal amount Special Tax Bonds, Series 1992A (the "1992A Bonds"); and WHEREAS, on December 12, 1995, the District issued its $12,385,000 aggregate initial principal amount Series 1995 Special Tax Bonds (the "1995 Bonds"); and WHEREAS, on December 11, 1997, the District issued its $22,989,000 aggregate initial principal amount Limited Obligation Refunding Bonds (Property Secured Only — No Issuer Liability), Series 1997 (the "1997 Local Obligations"), which refinanced the 1992A Bonds and the 1995 Bonds and which were sold to the Palm Desert Financing Authority (the "Authority"); and WHEREAS, concurrently with the District's issuance of the 1997 Bonds, the Authority issued its $30,915,000 aggregate initial principal amount 1997 Revenue Bonds (Assessment District Nos. 92-1 [Tierravista] and 94-1 [Bighorn] and Community Facilities District No. 91-1 [Indian Ridge]) (the "1997 Authority Bonds"); and ��xxn��.� WHEREAS, at this time, the Authority and the legislative body of the District intend to refinance the 1997 Authority Bonds and the 1997 Local Obligations through the issuance of refunding bonds in an aggregate principal amount not to exceed $12,000,000, designated as the "City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding Bonds, Series 2008" (the "Series 2008 Bonds"); and WHEREAS, the legislative body of the District has determined that it is prudent in the management of its fiscal affairs to issue the Series 2008 Bonds; and WHEREAS, the value of the real property in the District subject to the special tax to pay debt service on the Series 2008 Bonds is not less than three times the principal amount of the Series 2008 Bonds and the principal amount of all other bonds outstanding that are secured by a special tax levied pursuant to the Act or a special assessment levied on property within the District, which fact is required as a precondition to the issuance of the Series 2008 Bonds; and WHEREAS, in order to effect the issuance of the Series 2008 Bonds, the City Council, for itself and as the legislative body of the District, desires to approve the form of a Preliminary Official Statement for the Series 2008 Bonds and to approve the forms of, and authorize the execution and delivery of, a Bond Indenture, an Escrow Agreement, a Bond Purchase Contract, and a Continuing Disclosure Agreement for the Series 2008 Bonds, the forms of which are on file with the City Clerk. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF PALM DESERT, ACTING FOR ITSELF AND AS THE LEGISLATIVE BODY OF CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS), DOES HEREBY RESOLVE AS FOLLOWS: 1. Each of the above recitals is true and correct and is adopted by the City Council, acting for itself and as the legislative body of the District. 2. The legislative body of the District hereby finds and determines that, as determined in accordance with Section 53345.8 of the Act and as required by the City of Palm Desert policies adopted on October 13, 2005 pursuant to Section 53312.7 of the Act (the "Mello-Roos Goals and Policies"), the value of the real property in the District subject to the special tax to pay debt service on the Series 2008 Bonds is not less than three times the principal amount of the Series 2008 Bonds and the principal amount of all other bonds outstanding that are secured by a special tax levied pursuant to the Act or a special assessment levied on property within the District. This determination is based on the full cash value of the real property within the District as shown on the ad valorem assessment roll. � 3. The issuance of the Series 2008 Bonds in an aggregate principal amount not to exceed $12,000,000 is hereby authorized, with the exact principal amount of the Series 2008 Bonds to be determined by the official signing the Bond Purchase Contract in accordance with Section 7 below. In that regard, the City and the District hereby z ��Hs�s��.3 appoint Del Rio Advisors, LLC, to act as financial advisor in connection with the issuance of such bonds; Stinson Securities, LLC, and Kinsell, Newcomb & De Dios, Inc. to act as underwriter of the bonds (collectively, the "Underwriter"); Lofton & Jennings to act as disclosure counsel; Richards, Watson & Gershon, A Professional Corporation, to act as bond counsel ("Bond Counsel"); and MuniFinancial to act as special tax consultant. The legislative body of the District hereby determines that it is prudent in the management of its fiscal affairs to issue the Series 2008 Bonds. The Series 2008 Bonds shall mature on the dates and pay interest at the rates set forth in the Bond Purchase Contract to be executed on behalf of the District in accordance with Section 7 hereof. The Series 2008 Bonds shall be governed by the terms and conditions of the Bond Indenture presented at this meeting, on file with the City Clerk and incorporated herein by reference (the "Indenture"). The Indenture shall be executed by the Mayor of the City of Palm Desert (the "Mayor") or the City Manager of the City of Palm Desert (the "City Manager", and together with the Mayor, the "Authorized Officers") in substantially the form presented at this meeting, with such additions thereto and changes therein as may be approved by such officer upon consultation with Bond Counsel. Approval of such changes shall be conclusively evidenced by the execution and delivery of the Indenture by any one of the Authorized Officers. The date or dates, maturity or maturities, pledge or assignment of any revenues of the District to the repayment of the Series 2008 Bonds, the manner of investment of any bond proceeds and other revenues, manner of payment, interest rate or rates, interest payment dates, denominations, form, registration privileges, manner of execution, place of payment, terms of redemption, rebate provisions, funds designated to pay the costs of issuance the Series 2008 Bonds, and other terms of the Series 2008 Bonds shall be as provided in the Indenture as finally executed and shall be in conformance with any such terms set forth in the Bond Purchase Contract described in Section 7 below and Official Statement described in Section 8 below and delivered to the purchasers of the Series 2008 Bonds. Capitalized terms used in this Resolution which are not defined herein have the meanings ascribed to them in the Indenture. 4. The Series 2008 Bonds shall be executed on behalf of the District by the manual or facsimile signature of the Mayor and the seal of the District or the City, or a facsimile thereof shall be impressed or imprinted thereon and attested with the manual or facsimile signature of the City Clerk. The appointment of Wells Fargo Bank, National Association, as trustee (the "Trustee") under the Indenture and as escrow agent (the "Escrow Agent") under the Escrow Agreement described in Section 6 is hereby approved. 5. Pursuant to Section 53356.1 of the Act, the legislative body of the District hereby covenants, for the benefit of the Bondowners, to commence and diligently pursue any foreclosure action regarding delinquent installments of any amount levied as a special tax for the payment of interest or principal of the Series 2008 Bonds, such foreclosure action to be commenced and pursued as more completely set forth in the Indenture. 3 9�X75�1.3 6. The Escrow Agreement (the "Escrow Agreement"), proposed to be entered into by and among the District, the Authority and the Escrow Agent, in the form presented and on file in the office of the City Clerk, is hereby approved. Each Authorized Officer, acting singly, is hereby authorized and directed, for and in the name and on behalf of the Authority and the District, to execute and deliver the Escrow Agreement in substantially said form, with such changes therein as the Authorized Officer executing the same may approve (such approval to be conclusively evidenced by such officer's execution and delivery thereof). The date on which the 1997 Local Obligations and the 1997 Authority Bonds shall be defeased and no longer deemed to be outstanding shall be as provided in the Escrow Agreement as finally executed. 7. The form of the Bond Purchase Contract by and among the City (on behalf of the District) and the Underwriter presented at this meeting, on file with the City Clerk and incorporated herein by reference (the "Bond Purchase ContracY'), is hereby approved, and any one of the Authorized Officers is hereby authorized to execute the Bond Purchase Contract in substantially the form hereby approved, with such additions thereto and changes therein as may be approved by such officer upon consultation with Bond Counsel. Approval of such additions and changes shall be conclusively evidenced by the execution and delivery of the Bond Purchase Contract; provided, however, that the Bond Purchase Contract shall be signed only if the Series 2008 Bonds are purchased by the Underwriter at an overall interest rate that does not exceed 6.00% per annum for the issue as a whole (calculated utilizing the true interest cost method) and the discount paid to the Underwriter (exclusive of original issue discount) does not exceed 1.50% of the principal amount of the Series 2008 Bonds. The legislative body of the District hereby finds and determines, pursuant to Section 53360.4 of the Act, that the sale of the Series 2008 Bonds at negotiated sale to the Underwriter, as contemplated by the Bond Purchase Contract, will result in a lower overall cost than a public sale. Each of the Authorized Officers is authorized to determine the day on which the Series 2008 Bonds are to be priced in order to attempt to produce the lowest borrowing cost for the District and may reject any terms presented by the Underwriter if determined not to be in the best interest of the District. The authorization and powers delegated to such officer by this Section 7 shall be valid for a period commencing from the date of adoption of this Resolution, through and including February 15, 2008. 8. The form of the Preliminary Official Statement presented at this meeting, on file with the City Clerk and incorporated herein by reference (the "Preliminary Official Statement") is hereby approved, and the Underwriter is hereby authorized to distribute the Preliminary Official Statement to prospective purchasers of the Series 2008 Bonds in substantially the form hereby approved, together with such additions thereto and changes therein as are determined necessary by any one of the Authorized Officers to make the Preliminary Official Statement final as of its date for purposes of Rule 15c2-12 promulgated under the Securities Exchange Act of 1934 of the Securities and Exchange Commission, including, but not limited to, such additions and changes as are necessary to make all information set forth therein accurate and not misleading. Each of the Authorized Officers is hereby authorized to execute a final Official Statement in substantially the form of the Preliminary Official Statement, together with such changes as are determined necessary by the Authorized Officer executing the Official Statement 4 9HR759.3 to make such Official Statement complete and accurate as of its date. The Underwriter is further authorized to distribute the final Official Statement for the Series 2008 Bonds and any supplement thereto to the purchasers thereof upon its execution on behalf of the District as described above. 9. The form of the Continuing Disclosure Agreement presented at this meeting, on file with the City Clerk as appended to the Preliminary Official Statement and incorporated herein by reference (the "Continuing Disclosure Agreement"), is hereby approved, and any one of the Authorized Officers is hereby authorized and directed to execute the Continuing Disclosure Agreement in substantially the form hereby approved, with such additions therein and changes thereto as the Authorized Officer or Authorized Officers executing the same deem necessary to cure any defect or ambiguity therein if such change does not materially alter the substance or content thereof, with such approval to be conclusively evidenced by the execution and delivery of the Continuing Disclosure Agreement. 10. All actions heretofore taken by the officers and agents of the City and the District with respect to the establishment of the District, the issuance and sale of the Series 2008 Bonds, or in connection with or related to any of the agreements or documents referenced herein are hereby approved, confirmed, and ratified. The Mayor, each of the Authorized Officers, and the officers and staff of the City and the District responsible for the fiscal affairs of the District are hereby authorized and directed to take any actions, and execute and deliver any and all documents as are necessary to accomplish (a) the issuance, sale and delivery of the Series 2008 Bonds in accordance with the provisions of this Resolution; (b) the transactions contemplated by the Indenture, the Bond Purchase Contract, and the Continuing Disclosure Agreement, including without limitation establishing and determining such provisions as may be required by the terms of the bond insurance policy, if any, or debt service reserve surety bond(s), if any, purchased in connection with the issuance of the Series 2008 Bonds; and (c) the fulfillment of the purposes of the Series 2008 Bonds as described in the Indenture, including, but not limited to, providing certificates as to the accuracy of any information relating to the District which is included in the Official Statement. In the event that the Mayor is unavailable to sign any document authorized for execution herein, any Authorized Officer may sign such document. Any document authorized herein to be signed by the City Clerk may be signed by a duly appointed deputy clerk. 5 982i759.3 11. This Resolution shall take effect upon its adoption. The City Clerk shall certify to the passage and adoption of this Resolution and enter it into the book of original resolutions. PASSED AND ADOPTED this 13th day of December, 2007, by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Richard S. Kelly, Mayor ATTEST: Rachelle D. Klassen,City Clerk City of Palm Desert � ��Kx�s��.� RESOLUTION NO. FA-61 RESOLUTION OF THE PALM DESERT FINANCING AUTHORITY MAKING CERTAIN FINDINGS AND DETERMINATIONS IN CONNECTION WITH ITS 1997 REVENUE BONDS (ASSESSMENT DISTRICTS NOS. 92-1 AND 94-1 AND COMMUNITY FACILITIES DISTRICT NO. 91-1) RECITALS: WHEREAS, the City Council of the City of Palm Desert (the "City") has heretofore caused the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) (the "Indian Ridge CFD") to issue its $11,870,000 aggregate initial principal amount Special Tax Bonds, Series 1992A (the "1992A Bonds"), and its $12,385,000 aggregate initial principal amount Series 1995 Special Tax Bonds (the "1995 Bonds"); and WHEREAS, the Palm Desert Financing Authority (the "Authority") has heretofore issued its $30,915,000 aggregate initial principal amount 1997 Revenue Bonds (Assessment District Nos. 92-1 [Tierravista], Assessment District No. 94-1 [Bighorn], and Community Facilities District No. 91-1 [Indian Ridge]) (the "1997 Bonds"); and WHEREAS, in connection with the issuance of the 1997 Bonds, the 1992A Bonds and the 1995 Bonds were refunded and defeased, and the funds at that time on deposit in the improvement fund established in connection with the issuance of the 1992A Bonds and the 1995 Bonds were deposited and transferred to the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Improvement Fund (the "Improvement Fund") established by the indenture of trust (the "1997 Indenture") with respect to the 1997 Bonds, as a separate fund to be held by the fiscal agent under the 1997 Indenture; NOW, THEREFORE, THE PALM DESERT FINANCING AUTHORITY DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS: Section 1. In consultation with the Director of Public Works of the City, the Treasurer of the Authority, an authorized officer of the Authority, has certified that in connection with the Indian Ridge CFD and the 1997 Bonds, the works of improvement have been completed and all costs thereof have been paid from the Improvement Fund, and moneys on deposit in the Improvement Fund are not needed to complete such works of improvement or reimburse the cost thereof. Section 2. The amount of surplus remaining in the improvement fund is $5,020,741.68. Such amount shall be used for the purposes described in 1997 Indenture. P6401-1037\ 1013404v 1.doc 1 PASSED, APPROVED, and ADOPTED this 13th day of December 2007 by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Attest: Rachelle D. Klassen, Secretary Richard S. Kelly, President P6401-I037\1013404vI.doe 2 BOND INDENTURE By and Bctwccn CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) and WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee with reference to $�10,720,000] CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) SPECIAL TAX REFUNDING BONDS SERIES 2008 Dated as of January 1, 2008 ��s�a2i.a Tablc ot�C'ontcnts Pdi;c ARTICLE I DEFINITInNS...................................................................................................................2 Section1.1. Dcfinitions........................................................................................................2 ARTICLE II GENERAL AUTHORIZATION AND BOND TERMS................................................ 14 Section 2.1. Amount, Issuancc, Purposc and Naturc of Bonds and Parity Bonds..............14 Scction 2.2. Type and Nature of Bonds and Parity Bonds ................................................. 14 Section 2.3. Equality of Bonds and Parity Bonds and Pledge of Net Taxes ......................15 Section 2.4. Description of Bonds; Interest Rates.............................................................. 15 Section 2.5. Place and Fonn ol�Payment............................................................................16 Section 2.6. Form of Bonds and Parity Bonds.................................................................... 17 Section 2.7. Execution and Authentication......................................................................... 17 Scction2.8. Bond Register.................................................................................................17 Section 2.9. Registration of�Exchange or Transler.............................................................18 Section 2.10. Mutilated, Lc�st, Destroycd or Stolcn Bonds or Parity Bonds ........................ I 8 Section 2.1 1. Validity ot�Bonds and Parity Bonds...............................................................19 Section 2.12. Book-Entry System......................................................................................... 19 Section 2.13. Representation Letter......................................................................................20 Section 2.14. Transfers Outside Book-Entry Systcm...........................................................20 Section 2.15. Paymcnts to the Nominee...............................................................................20 Section 2.16. Initial Dcpository and Nominec......................................................................20 ARTICLE III CREATION OF FUNDS AND APPLICATION OF PROCEEDS ..............................20 Section 3.1. Crcation of Funds; Application of Proceeds...................................................20 Section 3.2. Deposits to and Disburscments from Special Tax Fund.................................21 Section 3.3. Administrative Expcnses Account of thc Special Tax Fund ..........................22 Section 3.4. lnterest Account and Principal Account of�the Special Tax Fund..................23 Section 3.5. Redemption Account of the Special Tax Fund...............................................23 Section 3.6. Reserve Account of�the Special Tax Fund......................................................24 Section3.7. Rcbate Fund....................................................................................................26 Section3.8. Surplus Fund...................................................................................................28 Scction 3.9. Costs of�[ssuance Fund...................................................................................29 Section3.10. ]nvestmcnts.....................................................................................................29 ARTICLE IV REDEMPTION OF BONDS AND PARITY BONDS.................................................31 Section 4.1. Redemption of Bonds. ....................................................................................31 Section 4.2. Selection of Bonds and Parity Bonds for Rcdemption...................................32 Section 4.3. Notice of Redemption.....................................................................................33 Section 4.4. Partial Redemption of Bonds or Parity Bonds................................................34 Section 4.5. Effect of Notice and Availability of Redemption Money...............................34 ARTCCLE V COVENANTS AND WARRANTY ..............................................................................34 Scction5.I. Warranty.........................................................................................................34 Secti�n 5.2. Covenanis .......................................................................................................35 i 9R7421 4 Tablc of Conienis (continucd) Pa�;c ARTICLE VI AMENDMENTS TO INDENTURE ............................................................................38 Section 6.1. Supplemental Incientures or Ordcrs Not Requiring Bondowner Consent...........................................................................................................38 Scction 6.2. Supplemental Indentures or Orders Rcyuiring Bondowner Consent..............38 Section 6.3. Notation of Bonds or Parity Bonds; Delivery of Amended Bonds or ParityBonds....................................................................................................39 ARTICLE VII TRUSTEE....................................................................................................................40 Section7.1. Trustee............................................................................................................40 Section 7.2. Removal of Trustee.........................................................................................40 Section 7.3. Resignation of�Trustee....................................................................................41 Section 7.4. Liability of�Trustce.........................................................................................41 Section 7.5. Merger or Consolidation.................................................................................42 ARTICLE VIII EVENTS OF DEFAULT; REMEDIES .....................................................................42 Section 8.1. Events of Default............................................................................................43 Section 8.2. Remedies of Owners.......................................................................................43 Scction 8.3. Application of Revenues and Other Funds After Default...............................44 Section 8.4. Power of Trustee to Control Proceedings.......................................................44 Seciion 8.5. Appointment of Receivers..............................................................................45 Section8.6. Non-Waiver....................................................................................................45 Section 8.7. Limitations on Rights and Remedies of Owners............................................45 Section 8.8. Termination of Proceedings............................................................................46 ARTICLE IX BOND INSURANCE....................................................................................................46 ARTICLE X DEFEASANCE AND PARITY BONDS ......................................................................4G Section 10.1. Defeasance......................................................................................................46 Scction 10.2. Conditions for thc Issuancc of Parity Bonds and Other Additional Indebtedness ...................................................................................................48 ARTICLE XI MISCELLANEOUS .....................................................................................................50 Section I I.I. Cancellation ot�Bonds and Parity Bonds........................................................50 Section 1 1.2. Execution of Documents and Proof of�Ownership.........................................50 Scction 1 1.3. Unclaimed Moncys.........................................................................................50 Section 1 1.4. Provisions Constitute Contract.......................................................................51 Section 1 1.5. Future Contracts..............................................................................................51 Section 11.6. Further Assurances.........................................................................................51 Section11.7. Severability.....................................................................................................51 Section1 1.8. Notices............................................................................................................51 ii �>x�azi a Table o1�Contents (continued) Pa�e EXHIBITS: EXHIBIT A FORM (�F SPECIAL TAX REFUNDING BOND, SERIES 2008 ..........................A-1 EXHIBIT B FORM nF REQUISITION FOR DISBURSEMENT nF PROJECT COSTS ........B-1 iii ��x�a2i a BONDINDENTURE THIS BOND [NDENTURE dated as of January 1, 2008, by and between CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) (thc"District") and WELLS FARGO BANK, NATIONAL ASSOCIATION, as trustcc (the"Trustee"), govcrns the tenns of thc Spccial Tax Rcfunding Bonds, Series 2008, of City of Palm Desert Community Facilitics District No. 91-1 (Indian Ridge Public Improvcmcnts) and any Parity Bonds issued in accordancc hcrcwith from timc to time. REClTAI.S: WHEREAS, the City Council oCthe City of Palm Desert, located in Riverside County, California (hereinafter sometimes referred to as the"legislative body of the District" or the "City"), has heretofore undertaken proceedings and declared the necessity to issue bonds on behalf of the District pursuant to the terms and provisions of the Mcllo-Roos Community Facilitics Act of 1982, as amended, being Chapter 2.5, Part l, Division 2, Title 5, of'the Government Code of the State of California(thc"Act"); and WHEREAS, based upon Resolution Nos. 92-22 and 92-23 adopted by the lcgislative body of the District on March 12, 1992 and an election held March 12, 1992 authori�ing the levy of a special tax and the issuance of bonds by the District, thc District is authorized to issue bonds for one or more scries, pursuant to the Act, in an aggregate principal amount not to exceed $35,000,000; and WHEREAS, on July 7, 1992, the District issued its $11,870,000 aggrcgate initial principal amount Special Tax Bonds, Series 1992A (the"1992A Bonds"); and WHEREAS, on December 12, 1995, the District issued its $12,385,000 aggregate initial principal amouni Series 1995 Special Tax Bonds (the"1995 Bonds"); and WHEREAS, on December 1 l, 1997, the District issued its $22,989,000 aggregate initial principal amount Limited Obligation Refunding Bonds (Property Secured Only - No Issuer Liability), Series 1997 (the"1997 Local Obligations"), which refinanced the 1992A Bonds and the 1995 Bonds and which were sold to the Palm Desert Financing Authority(the"Authority"); and WHEREAS, concurrcntly with thc District's issuance of thc 1997 Bonds, the Authority issued its $30,915,000 aggregate initial principal amount 1997 Rcvcnue Bonds(Asscssment District Nos. 92-1 [Tie�Yavista] and 94-1 [Bighorn] and Cocnmunity Facilitics District No. 91-1 [Indian Ridge]) (the "1997 Authority Bonds"); and WHEREAS, the Authority and thc legislative body of the District intend to refinance the 1997 Authority Bonds and the 1997 Local Obligations through the issuance of refunding bonds in an aggre�;ate principal amount of$[10,720,000] designatcd as the "City of Palm Desert Co►nmunity Facilities District No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding Bonds, Series 2008" (the "Series 2008 Bonds"); and WHEREAS, the District has detennined that all requirements of the Act for the issuance of the Series 2008 Bonds havc bccn satisficd; yx�azi a NnW, THEREFnRE, in order to estahlish the terms and conditions upon and subject to which the Series 2008 Bonds are to be issued, and in consideration of the premises and �f the mutual covenants contained hercin and of the purchase and acceptance of the Series 2008 Bo►lds by the Owners thereof, and for other valuable consideration, the receipt of which is hereby acknowledged, �he District does hereby covenant and agree, for thc bcncfit of the Owners of the Series 2008 Bonds and any Parity Bonds (as defined hercin) which may be issued hereunder from time to timc, as follows: ARTICLE 1 DEFINITIONS Section 1.1. Definitions. Unless the context otherwise requires, the following ternls shall have the following meanings: "Account" means any account created pursuant to this Indenture. "Act" means the Mello-Roos Cornmunity Facilities Act of 1982, as amended, being Section 5331 1 c�t sc�q. of the California Government Code. "Acquisition Agree►nent" means that certain Funding and Acquisition Agreement, dated as of May 14, 1992, by and between the City and Sunrise Desert Partners, a California limited partnership. "Administrativc Expenses" means thc administrative costs with respect to the calculation and collection of the Special Taxes, including all attorncys' fees and other costs relatcd thereto, the fecs and expenses of the Trustce, any fees and related costs for credit enhancement for the Bonds or any Parity Bonds which are not otherwise paid as Costs of Issuance, any costs related to the District's compliance with state and federal laws requiring continuing disclosure of�information concerning the Bonds and the District, and any other costs otherwise incurred by the City staff on behalf of�the District in order to carry out the purposes of thc District as set forth in the Resolution of Formation and any obligation of the District hereunder. "Administrative Expenses Account" means the account by that name created and established in the Special Tax Fund pursuant to Section 3.1 hereof. "Administrative Expenscs Priority Cap" means an amount equal to $ pei-Bond Year, escalating by 2% each Bond Year commencin�;July I, 2008. "Alternative Penalty Account" means the account by that name crcated and established in the Rebate Fund pursuant to Section 3.7 hereof. "Annual Debt Service" means the principal amount of any Outstanding Bonds or Parity Bonds payable in a Bond Year either at maturity or pursuant to a Sinking Fund Payment and any interest payablc on any Outstandin� Bonds or Parity Bonds in such Bond Year, if the Bonds and any Parity Bonds are retired as scheduled. "Authority" means the Palm Desert Financing Authority, a joint exercise of powers authoriiy fornled pursuant to a Joint Exercise of Powers Agreement, dated as of January 12, 1989, by and bctween the City and the Palm Desert Redevelopment Agency. 2 eH�azi a "Authorized [nvestments" means any of thc following which at the time of investment are legal investments under the laws of�the State ior the moncys proposed to be investcd thercin: (1) (A) Direct obligations (other than an obligation subject to variation in pi•incipal rcpayment) of the United States o1�America ("United States Treasury Obligations"); (B) obligations lully and unconditionally guaranteed as to timely payment of principal and interest by the Unitcd Statcs of America; (C) obligations i'ully and unconditionally guaranteed as to timely payment of principal and intei•est by any agency or instrumentality of the United States of Amcrica when such obligations are backed by the full faith and credit of the United Statcs of America; or(D) evidences of�ownership of�proportionate interests in future interest and principal payments on obligations described above held by a bank or trust company as custodian, under which the owner ofthe investment is thc real party in interest and has the right to proceed directly and individually against the obligor and the underlying government obligations are not available to any person claiming through the custodian or to whom thc custodian may be obligated. (2) Federal Housing Administration debentures. (3) The listcd obligations of government-sponsorcd agencies which are not backed by thc full faith and credit of the United States of America: - Federal Home Loan Mortgage Corporation (FHLMC) Participation certificates (excluded are stripped mortgage securities which ai•e purchased at prices exceeding their principal amounts) Senior Debt obligations - Farm Crcdit Banks (formerly: Federal Land Banks, Federal Intermediate Credit Banks and Banks for Cooperatives) Consolidated system-wide bonds and notes - Federal Home Loan Banks (FHL Banks) Consolidatcd dcbt obligations - Federal National Mortgage Association (FNMA) Scnior debt obligations Mortgage-backed securities (excluded are stripped mortgage securities which are purchased at prices exceeding their principal amounts) - Studcnt Loan Marketing Association(SLMA) Senior debt obligations (excluded are securities that do not have a fixed par value and/or whose terms do not promise a fixed dollar amount at maturity or call date) 3 ��s�a2�.a - Financing C�rp�ration (FICn) Dcbt obligations - Rcsolution Funding Co�poration (REFCORP) Dcbt obligations (4) Unsccured certificates of deposit, time deposits, and bankers' acceptances (having maturitics of not morc than 30 days) of any bank (including thc Trustcc and any afGliate) the short-te�m obligations of which are rated "A-1" or better by Standard & Poor's. (5) Dcposits the aggregate amount of which are fully insured by the Federal Deposit Insurance Corporation (FDIC), in banks (including the Trustee and any al�filiate) which have capital and surplus of at lcast $5 million. (6) Commercial paper(having original maturities of not more than 270 days rated "A-1+" by Standard & Poor's and "Primc-1" by Moody's and issued by an entity meeting the criteria in either clause (A) or(B): (A) the entity(i) is organized and operating in the United States as a general corporation, (ii) has total assets in excess of$500,000,000, and (iii) has debt other than commcrcial paper, if�any, that is rated "A" or higher by Standard & Poor's or Moody's; or (B) the entity(i) is organized within thc United States as a special purpose corporation, trust, or limited liability company, (ii) has programwide credit enhancements including, but not limited to, overcollateralization, letters of credit, or surety bond, and (ii) has commercial paper rated "A-1" or higher by Standard & Poor's or"A 1" by Moody's. (7) Money market tunds rated "AAm" or"AAm-G" by Standard 8c Poor's, or better(including thosc of thc Trustee or its affiliates). (8) "Statc nbligations," which means: (A) Direct general obligations ot'any state of the United Statcs ol' America or any subdivision or agency thereof to which is pledged thc full faith and credit of a state the unsecured gencral obligation debt of'which is ratcd "A3" by Moody's and "A" by Standard & Poor's, or bettcr, or any obligation fully and unconditionally guaranteed by any state, subdivision or agency whose unsecured general obligation debt is so rated. (B) Direct gener•al short-term obligations of any state agency or subdivision or agency thereof described in (A) above and rated "A-1+" by Standard & Poor's and "Prime-1" by Moody's. (C) Special Revenue Bonds (as defined in the United States Bankruptcy Code) of any state, state agency c�r subdivision described in (A) above and rated "AA" or bctter by Standard & Poor's and "Aa"or better by Moody's. 4 ��rc�az i a (9) Pre-retundcd municipal obligations ratcd "/\AA" by S & P and "Aaa" by Moody's mceting the following rcquiremcnts: (A) the municipal obligations are (1) not subjcct to redemption prior to cnaturity or(2) the trustee for the municipal obligations has been given it-��cvocable instructions concerning thcir call and redemption and the issuer of the municipal obligations has covcnanted not to redcem such municipal obligations other than as sct forth in such instructions; (B) the ►nunicipal obligations are secured by cash or Unitcd States Treasury Obligations which may be applied only to payment of the principal ot; interest and premium on such municipal obligations; (C) the principal ol'and interest on the United States Treasury Obligations (plus any cash in thc cscrow) has been verificd by thc rcport of indcpcndent certified public accountants to bc sufficient to pay in full all principal of, interest, and premium, if any, due and to becomc due on the municipal obligations ("Verification"); (D) the cash or United States Treasury Obligations serving as security for the municipal obligations are held by an escrow agent or trustee in trust (or owners of the municipal obligations; (E) no substitution ol�a Unitcd States Treasury Obligation shall be permitted except with another United Statcs Treasury Obligation and upon dclivcry of a new Verification; and (F) the cash or United States Treasury Obligations are not available to satisfy any other claims, includinb those by or against the trustee or escrow agent. (10) Repurchase agreements: (A) With (1) any domestic bank, or domestic branch of�a foreign bank, the long term debt of which is rated at least "A" by Standard & Poor's and Moody's; or (2) any broker-dealcr with"retail custoiners" or a rclatcd affiliate thereof which broker-dealer has, or the parcnt company(which guarantees the provider) of which has, long-tenn dcbt rated at least "A" by Standard c4c Poor's and Moody's, which broker-dealer falls under the jurisdiction of the Securities Investors Protection Corporation; or(3) any other entity rated"A" or better by Standard & P��r's and Moody's, provided that: (a) The market value of the collateral is maintained at levels equal to 104% of the amount of cash translerred by the Trustee to the provider of the repurchase agreement plus accrued interest with the collatcral being valued weekly and marked-to-market at one current market price plus accrued interest; (b) The Tiustee or a third party acting solely as agent therefor or for the District (the "Holder of thc Collateral") has possession of�the 5 ��8�az i.a cc�llatcral or thc collatcral has bcen transfcrred to thc Holder of thc Collatcral in accordance with applicable state and Cederal laws(other than by means of enti-ies cm the ti•ansferor's hc��ks); (c) The repurchasc agreement shall state and an opinion of counscl shall be rendered at the time such collateral is delivered that the Holder of the Collateral has a perfectcd first priority sccurity interest in the collateral, any substituted collateral and all proceeds thereof(in the case of bearer securities, this means the Holder of the Collateral is in possession); (d) The repurchase agreement shall provide that if during its term the provider's rating by either Moody's or Standard& Poor's is withdrawn c7r suspended or ialls bclow "A-" by Standard 8c. Poor's or"A3" by Moody's, as appropriaie, the provider must, at the direction of the District or the Trustee, within 10 days of receipt of such direction, repurchase all collateral and terminate the agreement, with no penalty or premium to the District or Trustcc. (B) Notwithstanding the above, if a repurchase agreement has a tcrm of 270 days or less (with no evergreen provision), collateral levels need not be as specified in(a) above, so long as such collatera! levels are 103%or better and thc provider is rated at least "A"by Standard & Poor's and Moody's, respectively. (1 1) Investment agreements with a domestic or foreign bank or corporation (other than a lifc or property casualty insurance company) the long-term debt of which or, in the case of a guarantccd corporation the long-term debt, or, in the case of a monoline financial guaranty insurance company, claims paying ability, of the guarantor is rated at least "AA" by Standard & Poor's and"Aa" by Moody's; provided that, by thc tcrms of the investcnent agreement: (A) intcrest payments are to bc made to the Trustee at times and in a►nounts as necessary to pay dcbt service on the Bonds; (B) thc invested funds are available for withdrawal without penalty or premiutn, at any time upon not more than seven days' prior notice; the District and the Trustee hereby agree to give or cause to be given notice in accordance with the terms of the investment agrcement so as to rcceive funds thereunder with no penalty or premium paid; (C) the invcstment agreement shall state that is the unconditional and general obligation of; and is not subordinated to any other obligation of, the provider thercof, or, in the case of a bank, that the obligation of�the bank to �nake payments undcr the agreement ranks pari passu with the obligations of�the bank to its other depositors and its other unsecured and unsubordinated creditors; (D) the District and the Trustee receives the opinion of domestic counsel (which opinion shall be addressed to the District and thc Trustee) that such invest►ncnt agreement is legal, valid, binding and enforceable upon the provider in 6 <�s�a2i.a accordance with its tcrms and of farcign counscl (if applicable) in form and substancc acceptable, and addressed to, the District; (E) thc investment agrecment shall provide that if during its tenn. (1) the provider's rating by cither Standard & Poor's or Mc�ody's falls bclow "AA-" or"Aa3", respectively, the provider shall, at its option, within 10 days of reccipt of publication of such downgrade, either (i)collatcralize the inveslment agreement by delivering or transferring in accordance with applicable state and federal laws (other than by means of entries on the provider's books) to the District, the Trustee or a third party acting solely as agent therefor(the "Holder of the Collateral") collateral frec and clear of any third-party liens or claims the market value of which collateral is maintained at levels and upon such conditions as would be acceptable to Standard & Poor's and Moody's to maintain an"A" ratin� in an "A" rated structured financing(with a market value approach); or(ii) repay the principal of and accrued but unpaid interest on the investment; and (2) the provider's rating by either Standard & Poor's or Moody's is withdrawn or suspcnded or falls below "A-" or"A3", respectively, the provider must, at the direction of thc District or the Trustee, within 10 days of receipt of�such direction, repay the principal of and accrued but unpaid interest on the investment, in either case with no penalty or premium to the District or Trustce; and (F) The investment agreement shall state and an opinion of counsel shall be rendered, in the event collateral is required to be pledged by the provider under the terms of the investment agreement at the time such collateral is delivered, that the Holdcr of the Collateral has a perfected first priority security interest in the collatcral, any substituted collateral and all proceeds thereof(in the case of bearer securities, this means the Holder of the Collatcral is in possession); and (G) the investment agrcement must provide that if during its term (1) the provider shall deiault in its payment obligations, the provider's obligations under the investment agreement shall, at the direction of the District or the Trustee, bc accelerated and amounts invested and accrucd but unpaid interest thereon shall be repaid to the District or Trustee, as appropriatc, and (2) the provider shall become insolvent, not pay its debts as they become due, be declared or petition to be declared bankrupt, etc. ("event of insolvency"), the provider's obligations shall automatically be accelerated and amounts invested and accrued but unpaid interest thereon shall be repaid to the District or Trustee, as appropriate. (12) The State of California Local Agcncy Investmcnt Fund; providcd that the Trustee may restrict invcstments in such Fund to the cxtent necessary to keep moneys available for the purposes of�this [ndenture. 7 ��x�azi a (I 3) Calilornia Asset Managemcnt Program (CAMP). "Authorized Represcntative of the City" means the City Managcr of�ttie City, the Finance Director-Tt•casurer ol�thc City, or any other person or persons designated by the City Managcr or thc Finance Director-Treasurer by a written ccr-tificatc signed by the City Manager or the Financc Director-Treasurer and containing the specimen signature of each such person. "Authorized Rcpresentativc of�the District" means the City Manager of the City, the Financc Director-Trcasurer of the City, or any other person or persons designatcd by the City Manager or the Finance Director-Treasurer by a written certificate signed by thc City Managcr or the Financc Director-Treasurer and containing the spccimen signaturc of each such �erson. "Bond Counsel" means an attorncy at law or a firm of attorneys selected by the District of nationally recognized standing in matters pertaining to thc tax-exempt nature of interest on bonds issued by states and thcir political subdivisions duly admitted to the practice of law bel'ore thc highest court of�any state of the United States of America or the District oi�Columbia. "Bond Registcr" means the books which the Trustee shall keep or cause to bc kept on which the registration and transfer of the Bonds and any Parity Bonds shall be recorded. "Bondowncr" or"Owner" means the person or persons in whose name or names any Bond or Parity Bond is registered. "Bonds•" means the Series 2008 Bonds. "Bond Year" mcans the twelvc month period commencing on nctober 2 of cach year and ending on October 1 of the i'ollowing year, cxcept that the first Bond Year for the Bonds or an issue of Parity Bonds shall begin on the Delivery Date and end on the first October 1 which is not more than 12 months after the Delivery Datc. "Business Day" means a day which is not a Saturday or Sunday or a day of the year on which banks in New York, New York, Los Angeles, California, or the city where the corporate trust oftice of the Trustee is located, are not required or authorized to remain closed. "Certiticate of an Authorized Representative" means a written certificate executed by an Authorized Representative of the City or District, as applicable. "Certificate ol'the Special Tax Administrator" means a ccrtificate of an Authori�ed Representative of the District, or any successor cntity appointed by the City, to administer the calculation and collection of�the Special Taxes. "City" means the City of Palm Descrt, California. "Code" means the Intcrnal Revenue Code of 1986, as amended, and any Regulations, rulings, judicial decisions, and notices, announcements, and other releases of the United States Treasury Department or Internal Revenue Scrvice interpreting and construing it. "Continuing Disclosure Agreement" means that certain Continuing Disclosure Agreement dated as of January I, 2008 between the City, on behalf oi'the District, and MuniFinancial, as dissemination agcnt, together with any amendments thcreto. 8 ��R�a2 i.a "Costs of Issuance" mcans the costs and expenses incurred in connection with the fo�mation ofthe District and the issuancc and sale ofthe Bonds or any Parity Bonds, including the acceptancc and initial annual fees and expenses�f the'1'rustcc, legal fecs and expenses, costs of printing the Bonds and Parity Bonds and thc �reliminary and tinal official statements for the Bonds and Parity Bonds, fees o('(inancial consultants and all other rclated fees and cxpenses, as set forth in a Certificatc of an Authori�ed Represcntative of�the City. "Costs of Issuance Fund" means the fund by that name created and established pursuant to Section 3.1 hereof. "Delivcry Date" means, with respect to the Bonds and each issuc of Parity Bonds, the date on which the bonds of such issue wcrc issued and dclivered to thc initial purchasers thereof. "Depository" shall mean The Depository Tcust Company, New York, New York, and its successors and assigns as securities depository for the Certificates, or any other securities depository acting as Dcpository under Article II hereot: "Developed Property" shall have the meaning ascribed to such term in the Rate and Method. "District" means City of Palm Desert Community Facilitics District No. 91-1 (Indian Ridgc Public Improvements) established pursuant to the Act and the Resolution of Fortnation. "Escrow Agreemenf' means the Escrow Agreement, datcd as of even date herewith, by and among the Authority, the City, the District, and Wells Fargo Bank, National Association, as escrow agent, relating to the refunding of the remaining outstanding portion of the Authority's 1997 Revcnue Bonds(Assessment District Nos. 92-1 [Tierravista] and 94-1 [Bighorn] and Community Facilities District No. 91-1 [Indian Ridge]), scheduled to mature on October 1, 2008 and thereafter through October 1, 2020. "Escrow Bonds" means the principal amount of any Parity Bonds deposited in an escrow account established by a Supplemcntal [ndenture which are not sccured by a pledge of the Nct Taxes while on deposit therein. "Escrow Fund" means thc fund by that name established under the Escrow Agrcement. "Event of Default"means an "event of default"describcd in Section 8.1 hereof. "Federal Securities" means any of the following: (a) non-callable direct obligations of thc United States of A►nerica ("Treasuries"), (b) evidence of ownership of proportionate interests in future interest and principal payments on Treasuries held by a bank or trust company as custodian, under which the owner of the investment is the real party in in�erest and has the righi to proceed directly and individually against the obligor and the undcrlying Treasuries arc not available to any person claiming through the custodian or to whom the custodian may be obligated, and (c) pre-refundcd municipal obligations rated "AAA" and "Aaa" by Standard & Poor's and Moody's, respcctively(or any combination therco�. "Fiscal Year" means the period beginning on July 1 of cach year and ending on the ncxt following Junc 30. 9 ��s�az i.a "Gross Taxes" means the amount ofall Spccial Taxes receivcd by the DisU-ict, to�ether with the proceeds collected ti•om the sale�f property pursuant to lhe f�>reclosure provisions of this Indenture for the delinyucncy of such Spccial Taxes remaining atter the payment �f all costs related to such foreclosurc actions. "Indenture" means this Bond Indenture, together with any Supplemcntal Indenture approved pu►•suant to Article 6 hercof. "Independent Financial Consultant" means a financial consultant or firm of such consultants generally recognized to be well yualitied in the financial consulting field, appointed and paid by the District, who, or cach of whom: (1) is in fact independent and not under the domination of the District or the City; (2) does not have any substantial interest, direct or indirect, in thc District or the City; and (3) is not connected with the District or thc City as a member, of'iicer oi• employcc of the District or the City, but who may be rcgularly retaincd to ►nake annual or other reports to the District or the City. "Insurance Policy" means the municipal bond insurance policy issued by the Insurer insuring the payment when due of the principal of and interest on the Bonds. "Insurer" means , and its successors and assigns. "Interest Account" means the account by that name created and established in the Special Tax Fund pursuant to Section 3.1 hereof. "Interest Payment Date" means each April 1 and October 1, commencing October 1, 2008; provided, however, that, if�any such day is not a Business Day, interest up to the Interest Payment Date will be paid on thc Business Day next succeeding such date. "Invest►nent Agrecment" mcans one or more agreements for the investment of funds of the District complying with the criteria therefor as sct forth in Subsection (1 1) of the definition of Authorized Investments herein. "Maximum Annual Debt Service"means the inaximum sum obtained for any Bond Year prior to the final maturity of the Bonds and any Parity Bonds by adding the follawing for each Bond Year: (1) the principal a►nount of all Outstanding Bonds and Parity Bonds payable in such Bond Year either at maturity or pursuant to a Sinking Fund Payment; and (2) the interest payable on the aggregate principal amount of all Bonds and Parity Bonds Outstanding in such Bond Year if the Bonds and Parity Bonds arc rctired as schcduled. "Moody's" means Moody's Investors Service, its successors and assigns. 10 ���7azi.a "Net Taxes" mcans Gr-oss Taxcs minus amounts set asidc to pay Administrative Expenses n�t to cxceed thc Adminish-ative Lxpenses Priority Cap. "1992A Bonds" means the Disti-ict's $1 1,870,000 aggregate initial principal a►nount S�ecial Tax Bonds, Series 1992A. "1995 Bonds" means thc District's $12,385,000 aggregatc initial principal amount Series 1995 Spccial Tax Bonds. "1997 Authority Bonds" means the Authority's $30,915,000 aggregatc initial principal amount 1997 Revenue Bonds (Assessmcnt District Nos. 92-1 [Tie�ravista] and 94-1 [Bighorn] and Community Facilitics District No. 91-1 [Indian Ridge]). "1997 Local Obligations" mcans the District's $22,989,000 aggregate initial principal amount Limited Obligation Refunding Bonds (Property Secured Only—No lssuer Liability), Scries 1997. "No►ninee" shall mcan the nomince of the Dcpository, which may be the Dcpository, as determincd f'rom time to time pursuant to Section 2.16 hereof. "Ordinancc" means Ordinance No. 674 adopted by the Icgislative body of thc District on March 26, 1992,providing for the levying ofthe Spccial Tax. "Outstanding" or"Outstanding Bonds and Parity Bonds" means all Bonds and Parity Bonds theretofore issued by the Districi, except: (I) Bonds and Parity Bonds theretofore cancelled or surrendered for cancellation in accordance with Section 11.1 hereof; (2) Bonds and Parity Bonds for payment or redcmption of which moneys shall have been theretofore deposited in trust (whcther upon or prior to the maturity or the redemption date of such Bonds or Parity Bonds), provided that, if such Bonds or Parity Bonds are to be redeemed prior to the maturity thereof, notice of such redemption shall havc been given as provided in this Indenture or any applicable Supplemental [ndenture for Parity Bonds; and (3) Bonds and Parity Bonds which have been surrcndered to the Trustcc lor transter or exchange pursuant to Section 2.9 hereof or for which a re�lacement has been issued pursuant to Section 2.10 he►•eof. "Parity Bonds" means all bonds, notes or other similar evidcnces of indebtedncss hereafter issued, payable out of the Nct Taxes and which, as provided in this Indenture or any Supplemental Indenture, rank on a parity with the Bonds. "Participants" shall cncan those broker-dealers, banks and other financial institutions from time to time for which the Depository holds Bonds or Parity Bonds as sccurities depository. "Pcrson" means natural persons, firms, corporations, partnerships, associations, trusts, public bodies and other entities. 11 ��s�azi a "Pre�ayments" mcans any amounts paid by thc District to the T»stec and dcsignated by tllc District as a prepayment of Special Taxes for one or morc parccls in the DisU•ict made in accordance with the Rate and Method. "Principal Account" mcans thc account by that name created and established in the Spccial Tax Fund pursuant to Scction 3.1 hercof. "Principal Officc of the Trustee" means the coi-�orate ttust ofticc of thc Trustce located in Los Angeles, California, or such other office or offices as the Trustee may designate ti•om time to time, or the office of any successor Trustec whcre it principally conducts its business of scrving as trustee under indentur-es pursuant to which municipal or governmental obligations are issucd. "Prior Local Obligations Account" means the account within the Escrow Fund established and held by the Escrow Agcnt pursuant to thc Escrow Agreement. "Project" means those public facilities described in the Resolution oi�Formation which are to be acquired or constructcd within and outsidc of the District, including all engineering, planning and design services and other incidental expenses related to such facilities and other facilities, if any, authorized by the yualified electors within the District Irom time to time. "Project C�sts" mcans thc amounts nccessary to finance the Project, to create and replcnish any necessary reserve funds, to pay the initial and annual costs associated with the Bonds or any Parity Bonds, including, but not limited to, remarketing, credit enhancement,Trustee and othcr fces and expenses relating to the issuancc of the Bonds or any Parity Bonds and the formation of the District, and to pay any other"incidental expcnses"of the District, as such term is defined in the Act. "Ratc and Method" means thc ratc and method of apportionment of Special Taxes attached to the Resolution of Formation, as it may be amended or modified from time to time. "Rating Agency" means Moody's and Standard & Poor's, or both, as the context requires. "Rebate Account" means the account by that name created and established in thc Rebate Eund pursuant to Section 3.1 hereof. "Rebate Fund" means the fund by that name established pursuant to Section 3.1 hereof in which there are established the Accounts described in Seciion 3.1 hereof. "Rebate Regulations" mcans any final, temporary or proposcd Rcgulations promulgatcd under Section 148(t) of thc Code. "Record Date" means the fiftccnth day of the month prcccding an Intcrest Payment Date, regardless of whether such day is a Business Day. "Redemption Account" means the account by that name creatcd and cstablished in the Special Tax Fund pursuant to Scction 3.1 hereof. "Regulations" means the regulations adopted or proposed by the Department of Treasury from time to time with respect to obligations issued pursuant to Scction 103 of the Codc. 12 ��x�az i.a "Representation Lettcr" shall mcan the Blanket Letter of Representations fi-om the District and the Paying Agent to the Depository as described in Section 2.13 hereof: "Reserve Account" means the account by that name created and established in the Special Tax Fund pursuant to Section 3.1 hcreol�. "Reserve Requirement"means that amount as of�any date of calculation equal to the lesscr of (i) 10% of the initial principal amount ol�thc Bonds and Parity Bonds, if any, (ii) Maximum Annual Deb� Service on the then Outstanding Bonds and Parity Bonds, if any; and (iii) 125% of average Annual Debt Service on thc then Outstanding Bonds and Parity Bonds, if any. "Resolution of Formation" means Resolution No. 92-2 adopted by the City Council of the City on March 12, 1992, pursuant to which the City Cormed the District. "Series 2008 Bonds" means the District's Spccial Tax Refunding Bonds, Series 2008, issucd on their Delivery Date in the aggre�;ate principal amount of�[10,720,000]. "Sinking Fund Payment" means tlie annual payment to be deposited in the Redemption Account to redeem a portion of the Term Bonds in accordance with the schedules set f'orth in Section 4.1(b) hcreof�and any annual sinking fund paycnent schedule to retirc any Parity Bonds which are designated as Term Bonds. "Six-Month Pcriod" means the period of time bcginning on the Delivery Date of each issue of Bonds or Parity Bonds, as applicable, and ending six consecutive months thereafter, and each six-month period thercafter until the latest maturity datc of the Bonds and the Parity Bonds (and any obligations that reCund an issue of the Bonds or Parity Bonds). "Special Tax Fund" means the fund by that name creatcd and established pursuant to Section 3.1 hereof. "Special Taxes" means the taxes authorized to be levied by the District on property within the District in accordance with the Ordinance, the Resolution of Formation, the Act and the voter approval obtained at the March 12, 1992 election in the District, including any scheduled payments and any Prepayments thereof, thc net proceeds of the redemption or sale of property sold as a result of foreclosure�f the lien of the Special Taxes to the amount �f said lien, and penalties and interest thec•con. "Standard & Poor's" means Standard & Poor's Ratinbs Group, a division ot'McGraw-Hill, its successors and assigns. "Subaccount" means any subaccount created pursuant to this Indenture. "Supplcmental lndcnture"means any supplemental indenture amending or supplementing this [ndenture. "Surplus Fund" means the i'und by lhat name created and established pursuant to Section 3.1 hereof. "Tax Certificate" means the Certiticate Regarding Compliance with Cei-tain Tax Matters (or similar document)pertaining to the use and investment of proceeds of a series of Bonds, executed 13 ��s�a2i.a and dclivered by a duly authorired oiTiccr of the District and of the City on thc relatcd Delivcry Uate, including any and all exhibits and attachinents theretc�. "Tax-exempt" means, with respect to interest on any obligations of a state or local government, including the interest on the Bonds, that such intcrest is excludcd from gross income for federal income tax purposes whether or not such intcrest is includable as an item of tax preference or otherwise includable directly or indirectly for purposes of calculating tax liabilities, including any altcrnativc minimum tax, under the Code. "Term Bonds" ►neans the Series 2008 Bonds maturing on Octobcr 1, 20_ and October 1, 20 "Trustee" means Wells Fargo Bank, National Association, a national banking association duly organized and existing under the laws of the United States of America, at its corporate trust office in Los Angeles, California, and its successors or assigns, or any other bank or tiust company which may at any time be substitutcd in its place as pi•ovided in Sections 7.2 or 7.3 and any successor thereto. "Underwriter" means, collectively, Stinson Securitics LLC and Kinsell, Newco►nb & Dc Dios, [nc., with respect to the Bonds. ARTICLE II GENERAL AUT'HORIZATION AND BOND TERMS Section 2.1. Amount, Issuance, Purpose and Nature of Bonds and Parity Bonds. Under and pursuant to the Act, the Bonds in the aggregate principal amount of$[10,720,000] shall bc issued for the purpose of tinancing the Project and paying Costs of Issuance, togcther with any Parity Bonds authorized by the legislative body in accordance with Section 10.2 hereof, provided that the aggregate principal amount of the Bonds and any Parity Bonds shall not exceed the total indebtedness presently authorized or subsequently authori�ed by the qualificd electors of the District in accordance with the Act. The Bonds and any Parity Bonds shall be and are limited obligations of the District and shall be payablc as to the principal thercof and interest thereon and any premiums upon the redemption thereof solely from the Net Taxes and the other amounts in the Special Tax Fund (othcr than amounts in the Administrative Expcn�es Account of the Spccial Tax Fund). Section 2.2. Type and Nature of Bonds and Parity Bonds. Neither the faith and credit nor the taxing power of thc City, thc State of California or any political subdivision thcreof othcr than the District is pledged tc� the payment of the Bonds or any Parity Bonds. Except for the Special Taxes, no other taxes are pledged to thc payment of thc Bonds or any Pai•ity Bonds. The Bonds and any Parity Bonds are not general or special obligations of the City nor general obligations of the District, but arc limited obligations of the District payable solely from certain amounts deposited by the District in the Special Tax Fund (exclusive of the Administrative Expenses Account), as more fully described herein. The District's limited obligation to pay the principal of, premium, if�any, and interest on the Bonds and any Parity Bonds from amounts in the Special Tax Fund (exclusive of the Administrative Expenses Account) is absolute and unconditional, tree of deductions and withc�ut any abatement, offset, recoupment, diminution or set-ofl�whatsoevcr. No Owner of the Bonds or any Parity Bonds may compel the exercise of the taxing power by the District (except as pertains to the Special Taxes)or the City or the forfeiture of any of their property. The principal of and interest on 14 ��x�az i.a thc I3onds and any Parity B�nds and prcmiums upon the rcdemption thercc�f; if any, arc not a debt �1' the City, the State of California or any of its political subdivisions within ihe meaning of any c�nstitutional or statutory limitation or restriction. The Bonds and any Parity Bonds are nc�t a legal or eyuilable pledge, charge, lien, or encumbrance upon any of the District's proper-ty, or upon any of its income, receipts or revenues, except the Net Taxes and other amounts in the Special Tax Funci (exclusive of the Administrative Expenses Account) which are, under thc tern�s of this Indenture and the Act, sct asidc f'or the payment of the Bonds, any Parity Bonds and interest thereon and ncither the membcrs of the legislative body of the DisU•ict or thc City Council of the City nor any persons executing the Bonds or any Parity Bonds, arc liable personally on the Bonds or any Parity Bonds, by reason of their issuance. Notwithstanding anything to ihe contrary contained in this Indenture, the District shall not be required to advance any money derivcd irom any source of income other than the Net Taxes for the payrncnt of'thc interest on or the principal of the Bonds or any Parity Bonds, or for the performance of any covenants contained herein. The District may, however, advance funds for any such purpose, provided that such funds are derivcd froin a source lcgally available for such purpose. Scction 2.3. Equality of Bonds and Parity Bonds and Pledge of Net Taxes. Pursuant io the Act and this Indenture, the Bonds and any Parity Bonds shall be cqually payable from the Net Taxes and othcr amounts in the Special Tax Fund (exclusive of�the Administrative Expenses Account), without priority for number, date of�the Bonds or Par•ity Bonds, date of'sale, date of execution, or date of delivcry, and the payment of thc interest on and principal of the Bonds and any Parity Bonds and any premiums upon the rede►nption thereof, shall be exclusively paid from the Net Taxes and othcr amounts in thc Special Tax Fund (exclusivc of thc Administrative Expenses Account), which are hcreby set aside for the payment of�the Bonds and any Parity Bonds. Amounts in the Special Tax Fund (other than thc Administrative Expenses Account therein) shall constitute a trust fund held for the benefit of the Owners to be applied to the payment of the interest on and principal of the Bonds and any Parity Bonds and so long as any of the Bonds and any Parity Bonds or interest thereon remain Outstanding shall not be used for any other purpose, except as permitted by this Indenture oi•any Supplemcntal Indenture. Notwithstanding any provision contained in this Indenture to the contrary, Net Taxes deposited in the Rebate Fund and the Surplus Fund shall no longer be considered to be pledged to the Bonds or any Parity Bonds, and none of the Rebate Fund, the Suiplus Fund, the Costs of Issuance Fund, or the Administrativc Expenses Account of the Special Tax Fund shall be construed as a trust fund held for the bencfit of the Owners. Nothing in this Indenture or any Supplemental Indenture shall preclude: (a) subject to the limitations containcd hercunder, the redemption prior to maturity of any Bonds or Parity Bonds subjcct to call and redemption and payment of said Bonds or Parity Bonds fi•om proceeds of rcfunding bonds issued under the Act as the same now cxists or as hcreaftcr amendcd, or under any other law of the State of California; or(b) the issuance, subject to the limitations contained herein, of Parity Bonds which shall be payable fram Nct Taxes. Section 2.4. Description of Bonds; Interest Rates. The Bonds and any Parity Bonds shall be issued in fully registcred form in denominations of$5,000 or any integral multiplc thercoi: The Bonds and any Parity Bonds of each issue shall be numbered as desired by the Trustee. The Bonds shall be designated "CITY OF PALM DESERT COMMUMTY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) SPECIAL TAX REFiJNDING BnNDS, SERIES 2008." Thc Series 2008 Bonds shall be dated as of thcir Delivcry 15 es�azi a Date and shall mature and be payablc on October I in thc years and in the aggregate principal amounts and shall be subject to and shall bear interest at thc ratcs sct forth in thc tablc bclow payable on October l, 2008 and each Interest Payment Date thereafter: Maturity Date (October 1) Pi-incipal Amount Interest Rate 2008 � % 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Intcrest shall be payable on each Bond and Parity Bond from thc datc established in accordance with Section 2.5 below on each Interest Payment Date thereatter until the principal sum of that Bond or Parity Bond has been paid; provided, however, that if at the maturity date of any Bond or Parity Bond (or if the same is redeemable and shall be duly called for redemption, then at the date fixed for redemption) funds are available for the payment or redemption thcrcof in full, in accordance with the tcrms of this Indenture, such Bonds and Parity Bonds shall then ccasc to bear interest. Interest due on the Bonds and Parity Bonds shall be calculated on the basis of a 360-day year compriscd of twelve 30-day months. Section 2.5. Place and Form of Payment. The Bonds and Parity Bonds shall be payable both as to principal and interest, and as to any premiums upon the redemption thereof, in lawful money of the United States of America. The principal of the Bonds and Parity Bonds and any premiums due upon the redemption thereof shall be payablc upon presentation and surrender thercof at the Principal Officc of the T'rustee, or at thc dcsignated ofCcc of any successor Trustee. Interest on any Bond or Parity Bond shall be payable from the Interest Payment Date next preceding the date of authentication of that Bond or Parity Bond, unless (i) such date of authentication is an Interest Payinent Date in which event interest shall be payable from such date of authentication, (ii) the date of authentication is afrcr a Record Date but prior to the immcdiately succeeding Interest Payment Date, in which event interest shall bc payable from thc Interest Payment Datc immediately succeeding thc date of�authentication, or(iii) the date of authentication is prior to the close oi' business on the tirst Record Date occurring after the issuance of such Bond or Parity Bond, in which event intcrest shall be payable from thc dated date of such Bond or Parity Bond, as applicable; provided, howevei•, that if�at the time of authentication of such Bond or Parity Bond, interest is in default, intcrest on that Bond or Parity Bond shall be payable from thc last lnterest Payment Date to which thc interest has been paid or made available for payment or, if no interest has been paid or madc available for paymcnt on that Bond or Parity Bond, intcrest on that Bond or Parity Bond shall be payable froin its dated date. Interest on any Bond or Parity Bond shall be paid to the person whose name shall appcar in the Bond Registci•as the Ownei•oi�such Bond or Parity Bond as of the 16 9x7a2�a closc of busincss on the Recc�rd Datc. Such interest shaU be paid by chcck �f the Trustee mailed by first class mail, postagc prcpaid, to such Bondowncr at his on c�r address as it appcars on the Bond Registcr. In addition, upon a rcqucst in writing received by the Trustee on or bctore the applicable Record Date fi•om an Owner of�1,000,000 or more in principal amount of the Bonds or�f any issuc of Parity Bonds, payment shall be made on the Interest Payment Date by wire transfer in i►nmediatcly available funds to an account designated by such Owner. Section 2.6. Form of Bonds and Parity Bonds. The definitive Bonds may be printed from stecl engraved or lithographic plates or may be typewritten. The Bonds and the certificate of authentication shall be substantially in the for►n attached hercto as Exhibit A, which fonn is hereby appi•oved and adopted as the form oi'such Bonds and of the certificate of authentication. Each issue of Parity Bonds and the certiticate of authentication therefor shall be in thc forcn provided in thc Supplemental Indenture for such issue of Parity Bonds. Until definitive Bonds or Parity Bonds, as applicable, shall bc prepared, the District may cause to be executed and delivered in lieu oi'such definitive Bonds or Parity Bonds temporary bonds in typcd, printed, lithographed or engraved f'orn� and in fully registered form, subject to the same provisions, limitations and conditions as are applicable in the case of definitive Bonds or Parity Bonds, except that they may be in any denominations authorired by the District. Until exchangcd for definitive Bonds or Parity Bonds, as applicable, any ternpor•ary bond shall be entitled and subject to the same benefits and provisions of this Indenturc as definitive Bonds and Parity Bonds. If the District issues temporary Bonds or Parity Bonds, it shall exccute and furnish definitive Bonds or Parity Bonds, as applicable, without unnccessary delay and thercupon any temporary Bond or Parity Bond may be surrendered to the Trustee at its otiicc, without expense to the Owner, in cxchange for a definitive Bond or Parity Bond of the same issue, maturity, intcrest rate and principal amount in any authorized denoinination. All te►nporary Bonds or Parity Bonds so surrendered shall be cancelled by the Trustce and shall not be reissued. Scction 2.7. Execution and Authentication. The Bonds and Parity Bonds shall be signed on behalf�of the District by the manual or facsimilc signature of the Mayor of the City and countersigned by the manual or facsimilc signature of the City Clerk of thc City, or any duly appointed deputy City Clerk, in their capacity as officers of the District, and the seal of the District (or a facsimile thereo� may bc impressed, imprinted, engraved or otherwise reproduced thereon, and attested by the signature of the City Clcrk of�the City Council. In case any one or more of the officers who shall have signed or sealed any of the Bonds or Parity Bonds shall cease to be such officer before the Bonds or Parity Bonds so signed and sealed have becn authenticated and delivcred by the Trustec (including new Bonds or Parity Bonds delivered pursuant to thc provisions hec•eof with reference to the transfer and exchange of Bonds or Parity Bonds or to lost, stolen, destroyed or inutilated Bonds or Parity Bonds), such Bonds and Parity Bonds shall nevertheless be valid and may be authenticated and delivered as hcrein provided, and may be issued as if the person who signcd or sealed such Bonds or Parity Bonds had not ceased to hold such office. nnly the Bonds as shall bear thereon such certificate of authentication in the form set forth in Exhibit A attached hereto shall be entitled to any right or benefit under this Indenture, and no Bond shall be valid or obligatory for any purpose until such certificate of'authentication shall have bcen duly executed by the Trustce. Section 2.8. Bond Register. The Trustee will keep or cause to be kept, at its office, sufficicnt books lor the registraiion and transfer of the Bonds and any Parity Bonds which shall upon 17 9R7421.4 reasonablc prior noticc bc open to inspection by the District during all rcgular busincss h�urs, and, subject to the limitations set forth in Section 2.9 below, upon presentation for such purpose, the Trustee shall, under such reasonable regulations as it may prescribe, registcr or transfer or cause to bc ti-ansferred on said Bond Rcgister, Bonds and any Parity Bonds as hercin providcd. The District and the Trustec may treat the Owner of any Bond or Parity Bond whosc namc appears on the Bond Register as the absolute nwner of that Bond or Parity Bond for any and all purposes, and the District and the Trustec shall not bc affected by any notice to the contrary. The District and the Trustee may rely on thc addr•ess oi�the Bondowner as it appears in thc Bond Registcr for any and all purposes. It shall be the duty of the Bondowner to give written notice to the Trustee of any change in the Bondowner's address so that the Bond Register may be revised accordingly. Section 2.9. Registration of Exchange or Transfer. Subject to the limitations set forth in the following paragraph, the registration of any Bond or Parity Bond may, in accordance with its ter-►ns, be transferred upon the Bond Register by the per•son in whose namc it is registercd, in person or by his or her duly authorized attorney, upon surrender of�such Bond or Parity Bond for cancellation at the ofTice of the Trustee, accompanied by delivery of written instrument of transfcr in a form acceptable to the Trustec and duly cxecuted by the Bondowner or his or her duly authori�cd attorney. Bonds or Parity Bonds may be exchanged at the office of the Trustce for a like aggregatc principal amount of Bonds or Parity Bonds for other authorired denominations of the same maturity and issue. The Trustee shall not collect from the Owner any charge for any new Bond or Parity Bond issued upon any exchange or transfer, but shall rcquire the Bondowner requesting such exchange or transfer to pay any tax or other governmental charge required to be paid with respect to such exchange or transfer. Whenever any Bonds or Parity Bonds shall be surrendered for registration of transfer or exchange, the District shall execute and thc Trustce shall authenticate and deliver a new Bond or Bonds or a new Parity Bond or Parity Bonds, as applicable, of the same issue and maturity, for a like aggregate principal amount; provided that the Trustec shall not be requircd to register transfers ar make exchanges of'(i) Bonds or Parity Bonds f'or a period of fifteen (15) days next preceding any selection of the Bonds or Parity Bonds to be redcemed; or(ii) any Bonds or Parity Bonds chosen for redcmption. Section 2.10. Mutilated, Lost, Destroyed or Stolen Bonds or Parity Bonds. If any Bond or Parity Bond shall become mutilated,the District shall execute, and the Trustee shall authenticate and deliver, a new Bond or Parity Bond of like tenor, date, issue and maturity in exchange and substitution foi•the Bond or Parity Bond so mutilated, but only upon surrender to the Trustce oi�the Bond or Parity Bond so mutilated. Every mutilated Bond or Parity Bond so surrendered to the Trustee shall be cancellcd by thc Trustee pursuant 10 Seclion 11.1 hereof. If any Bond or Parity Bond shall be lost, destroyed or stolen, evidence of'such loss, destruction or theft may be submitted to the Trustee and, if such evidence is satisfactory to the Trustee and, if any indemnity satisfactory to thc Trustce shall be given, the District shall exccute and the Trustee shall authenticate and deliver, a ncw Bond or Parity Bond, as applicable, of like tenor, rnaturity and issue, numbered and dated as the Trustee shall determine in lieu of and in substitution for the Bond or Parity Bond so lost, destroyed or stolen. Any Bond or Parity Bond issued in lieu of any Bond or Parity Bond alleged to be mutilated, lost, destroyed or stolen, shall be equally and proportionately entiticd to the benefits hcreof with all othcr Bonds and Pai-ity Bonds issued hereunder. The Trustee shall not treat both the oi-iginal Bond or Parity Bond and any replacement Bond or Parity Bond as being nutstanding for the purpose of determining the principal amount of Bonds or Parity Bonds which may be executed, aulhenticated 18 yx�azi a and dclivcred hereunder o►- f�r tlic purposc of detcrniining any perccntagc of Bonds or Parity Bonds nutstanding hcreunder, but both the original and replacement Bond or Parity Bond shall bc trcated as one and the same. Notwithstanding any other provision ot�this Section, in licu of delivcrin� a ncw Bond or Parity Bond which has been mutilated, lost, destroyed or stolen, and which has matured, the Trustec may makc payment with respect to such Bonds or Parity Bonds. Section 2.1 1. Validity of Bonds and Parity Bonds. The validity of the authorizaticm and issuancc of�the Bonds and any Parity Bonds shall not be aftected in any way by any defect in any proceedin�s taken by the District for thc financing of the Project, or by the invalidity, in whole or-in part, of any contracts made by the District in conncction thci•ewith, and shall not be dcpendent upon the completion of the financing of�the Project or upon the performance by any Person ot�his obligation with respect to the Project, and the recital contained in the Bonds or any Parity Bonds that the same are issued pursuant to the Act and othcr•applicable laws of�thc State shall be conclusive evidence of'their validity and of the regularity of their issuance. Section 2.12. Book-Entry System. The Bonds shall be initially delivered in the for►n of a separate single fully re�;istered Bond(which may be typewritten) for each of the maturities of the Bonds. Upon initial delivery, the ownership of cach such Bond shall bc registcred in the registration books kcpt by the Trustee in the name of thc Nominee as nominec of the Depository. Except as providcd in Scction 2.14 hercot; all of the nutstanding Bonds shall be rcgistercd in the re�istration books kept by thc Trustce in the name of the Nominee. At lhe election of the District, any Parity Bonds may also bc issued as book-entry bonds registered in the name of the Nomince as provided hcrein, in which case the refercnces in Sections 2.12 through 2.15 to"Bonds" shall be applicable to such Parity Bonds. With respect to Bonds registered in the registration books kept by the Trustee in the name of' the Nomince, the District and the Trustce shall have no responsibility or obligation to any such Participant or to any Person on behalf of which such a Participant holds an interest in thc Bonds. Without limiting the immediatcly preceding sentencc, the District and the Trustee shall have no responsibility or obligation with respect to (i) the accuracy of the rccords of the Depository, the Nominee, or any Participant with respect to any ownership interest in the Bonds, (ii) the delivery to any Participant or any other Person, other than an Owner as shown in the registration books kept by the Trustee, of any notice with respect to the Bonds, including any noticc of redemption, (iii) the selection by the Depository and its Participants of the beneticial interests in the Bonds to be redeemed in the event the Bonds are redeemed in part, or(iv) the payment to any Participant or any other Pcrson, other than an Owner as shown in the registration books kept by the Trustee, of'any amount with respect to principal of, premium, if any, or interest due with respect to the Bonds. The District and the Trustee may treat and considcr the Person in whosc name each Bond is registered in the registration books kept by the Trustec as the holder and absolute owner of such Bond for the purpose of payment of the pr•incipal of, pi•emium, if�any, and interest on such Bond, for the purpose of giving notices of redemption and other matters with respect to such Bond, for the puipose of� i•ebistering transfcrs with respect to such Bond, and for all other purposes whatsoever. The Trustee shall pay all pr•incipal of, premium, if any, and interest due on the Bonds only to or upon the order of the respectivc Owner, as shown in the registration books kept by the Trustee, or their respective attorneys duly authorized in wc•iting, and all such payments shall be valid and effective to satisfy and discharge fully the District's obligations with respect to payment of the principal, premium, if any, and interest due on ihe Bonds to the extent of�the sum or sums so paid. No Person other than an Owner, as shown in the registration books kept by the Trustee, shall receive a Bond evidencing the �bligation �f the Dist►-ict to ►nake payments of principal, pre►nium, if any, and intcrest pursuant to 19 ��s�azi.a this Indenturc. Upon dclivc►•y by the Dcpository to the Tiustce and thc Di�trict of�writtcn noticc tc� the etfect that the Depository has detennincd to substitute a new nomince in place of the Nomince, and subject to the provisions herein with respect to Record Datcs, the w�rd Nominee in this Indenture shall refer to such new nomince of the Depository. Section 2.13. Representation Letter. In order to qualify the Bonds and any Parity Bonds which the District elects to register in the name�f thc Nc�minee for the Deposit�ry's book-cntry system, an author•ized representative of the Trustec is hereby authorized to execute from ticne to time and deliver to such Deposit�ry the Representation Lctter. The execution and delivery of thc Represcntation Lctter shall not in any way limit the provisions of�Section 5.1 or in any other way imposc upon the District or the Trustee any obligation whatsoever with respect to persons having interests in the Bonds other than the Owners, as shown on the registration books kept by the Trustee. The Trustee agrees to take all action necessary to continuously comply with all representations madc by it in the Represcntation Letter. In addition to the execution and delivery oCthe Representation Letter, thc Authorizcd Represcntatives of the District are hereby authorized to take any other actions, not inconsistent with this Indenture, to yualify the Bcmds for the Depository's book-entry program. Section 2.14. Transfers Outside Book-Entry System. In the event (i) thc Depository detennines not to continue to act as securities depository for the Bonds, or(ii) the District determines that the Depository shall no longer so act, then the District will discontinue the book-entry system with the Depository. If the District fails to identify another qualitied securities depository to replacc thc Depository then thc Bonds so designated shall no longer be restricted to being registered in the registration books kept by thc Trustee in the name of the Nominee, but shall be rcgistered in whatever namc or names Persons transferring or exchanging Bonds shall designate, in accordance with the provisions of Section 2.9 hereof. Section 2.15. Payments to the Nominee. Notwithstanding any other provisions of this Indenture to the contrary, so long as any Bond is registered in ihe name of ihe Nominee, a!1 payments with respect to principal, premium, if any, and interest due with respect to such Bond and all notices with respect to such Bond shall be made and given, respectivcly, as provided in the Representation Letter or as othci-wise instructed by the Depository. Section 2.16. Initial Depository and Nominee. The initial Depository under this Article shall be The Depository Trust Company, New York, New York. The initial Nominee shall be Cede &Co., as Nominee of The Depository Trust Company, New York, New York. ARTICLE III CREATION nF FUNDS AND APPLICATION OF PROCEEDS Section 3.1. Creation of Funds; Application of Proceeds. (a) There is hereby created and established and shall be maintained by the Trustee the following funds and accounts: (1) The City of Palm Desert Community Facilities District No. 91-1 Special Tax Fund (the"Special Tax Fund") (in which there shall be established and created an Interest Account, a Principal Account, a Redemption Account, a Reserve Account, and an Administrative Expenses Account). 20 9k742I 4 (2) Thc City of Palm Descrt Community Facilitics District N�. 91-1 Rcbatc Fund (thc "Rcbate Fund") (in wllich there shall be establishcd a Rebate Account and an Alternativc Penalty Acc�unt). (3) The City of Palm Desert Community Facilities District No. 91-1 Costs of Issuancc Fund (thc"Costs of Issuance Fund") (in which there shall bc established a Costs of� Issuancc Account). (4) The City of Palm Desert Community Facilities District No. 91-1 Surplus Fund (the "Surplus Fund"). The amounts on deposit in the fc�regoing f'unds, accounts and subaccounts shall bc held by thc Trustee and the Trustee shall invest and disburse the amounts in such f'unds, accounts and subaccounts in accordance with the provisions of'this Article 3 and shall disburse investment earnings thereon in accordance with the provisions of Section 3.10 hereof. In connection with the issuance of any Parity Bonds, the Trustee, at the direction of an Authoriied Representative of the District, may create new funds, accounts or subaccounts, or may create additional accounts and subaccounts within any of the foregoing funds and accounts for the purpose of'separately accounting for the proceeds oCthe Bonds and any Parity Bonds. (b) A portion of the pr-oceeds of the sale of the Bonds in thc amount of � (such amount being equal to the principal amount oCthe Series 2008 Bonds, (plus/less] a net original issue [premium/discount� of� , less an Underwriter's discount of� $ , less an amount oi�$ wired by the Underwriter at the request of the District to pay the premiucn for the Insurance Policy) shall be received by the Trustec on behalf of the District and deposited and transferred as follows: (1) $ shall be deposited in the Costs of Issuance Fund to pay the Costs of Issuance of�the Bonds; (2) � shall be deposited in thc Prior Local Obligations Account of the Escrow Fund; and (3) $ shall be deposited in the Reserve Account of the Special Tax Fund to fund the Reservc Requirement. The Trustcc may, in its discretion, establish a temporary fund or account in its books and records to facilitate such transfers. Scction 3.2. Deposits to and Disbursements from Special Tax Fund. (a) To the extent the District receives any Prepayments, the District shall deposit such Prepayments with the Trustee, together with a Certificate of an Authori�ed Representative designating such Special Taxes as Prepayments and specifying the respective amounts tc� be deposited in the various funds and accounts hereunder, and the Trustee shall make such deposits as speciGed in such certificate on the same day as its receipt thereof. Except for any Prepayments to be deposited pursuant to the forcgoing, thc Trustee shall, on each datc on which the Special Taxes arc received trom the District, deposit the Special Taxes in the Special Tax Fund to be held in trust for 21 4$7a21 4 the Owners. The Trustec shall iransfer the Special Taxes on deposit in the Spccial Tax Fund on the dates and in the amounts set forth in the following Sections, in thc following ordcr of�priority, to: (1) thc Administrative Expenscs Account of the Specia) Tax Fund; (2) the [nterest Account ol�the Special Tax Fund; (3) the Principal Account oi'the Special Tax Fund; (4) the 2edemption Account of the Special Tax Fund; (5) the Reserve Account of the Special Tax Fund; (6) the Rebate Fund; and (7) the Surplus Fund. (b) At least [ive (5) Business Days prior to each Interest Payment Date the Trustee shall transfer to the Interest Account, thc Principal Account and the Redemption Account, as applicable, from the Special Tax Fund the amounts required for debt service on the Bonds and Parity Bonds on such Interest Payment Datc. (c) At maturity of all of'the Bonds and Parity Bonds and, after all principal and interest then due on thc Bonds and Parity Bonds then Outstanding has been paid or provided for and any amounts owed to the Trustee have been paid in Iull, moneys in the Special Tax Fund and any accounts therein may be used by the District for any lawful purpose. Section 3.3. Administrative Expenses Account of the Special Tax Fund From timc to time, the District may provide the Trustee with a Certificate of an Authorized Representative of the District, requesting the payment of Administrative Expenses as set forth therein. Upon its rcceipt of any such certificate, the Trustee shall transfer from thc Special Tax Fund and deposit in thc Administrativc Expenscs Account of the Special Tax Fund amounts necessary to make timely payment of any such Administrativc Expenses as set forth in the Certificate of�an Authori�ed Representative ofthe District; provided, however, that, except as set forth in the following sentence, the total amount transferred in a Bond Year shall not exceed the Administrative Expenses Priority Cap until such time as thcre has been deposited (a) to the Interest Account and the Principal Account an amount, together with any amounis alrcady on deposit therein, that is sufficicnt to pay the interest and principal on all Bonds and Parity Bonds duc in such Bond Year, (b) to the Rcdemption Account an amount, togethcr with any ainounts alr•eady on deposit therein, that is sufticient to call and redecm Term Bonds in accordance with thc Sinking Fund Payment schedules set forth in Section 4.1(b) hcreof and to redeem Parity Bonds in accordance with any Sinking Fund Payment schedule in the Supplemcntal Indcnture for such Parity Bonds, and (c) to the Reserve Account an amount, togcther with any amounts already on deposit therein, that is sufficient to restore the Reserve Account to the Rcserve Requiremcnt. Notwithstanding the f'orcgoing, amounts in excess of the Administrative Expcnses Priority Cap may bc transferred to the Administrative Expenscs Account to the cxtent necessary to collect delinquent Special Taxes. Moneys in the Administrative Expenses Account of the Special Tax Fund may be invested in any Authorizcd Investmcnts as directed in writinb by an Authorized Representative of�the District and shall be disbursed as dii•ected in a Certificate of an Authori�ed Rcpresentative. Thc Trustee shall have no oblibation to transfer any amount fi-orn thc 22 ��tc�azi a Spccial Tax Fund tor deposit in the Ad►ninistrative Expenses Account ot�the Special Tax Fund except upon its reccipt of a Ceriificate of an Authori�ed Rcpresentative of thc District pursuant to this section. Sectio�l 3.4. Interest Account and Principal Account of the Special Tax Fund. The principal of and interest due on the Boncis and any Parity Bonds until maturity, other than pi•incipal due upon redemption, shall be paid by the Trustee fi•om the Principal Account and the Intel•est Account of the Special Tax Fund, respectively. For the purpose of assuring that the payment of principal of and interest on the Bonds and any Parity Bonds will bc made when due and after making thc transfer required by Section 3.3, if any, at least five (5) Business Days prior to each April 1 and Octobei• 1, the Trustee shall make the following transfers fi•om the Special Tax Fund first to the Interest Account and then to the Principal Account; provided, however, that to the cxtent that deposits have becn made in thc Interest Account or the Principal Account from thc proceeds of the sale oi�an issue of the Bonds, any Parity Bonds, or otherwise, the transfer from the Special Tax Fund need not be made; and provided, further, that, if amounts in the Special Tax Fund (exclusive of the Reserve Account) are inadequate to make the foregoing transfers, then any deficiency shall be made up by transfers from the Reserve Account: (a) To the Interest Account, an amount such that the balance in thc Interest Account five (5) Business Days prior to each Intcrest Payment Date shall be equal to thc installment of interest due on the Bonds and any Parity Bonds on said Interest Paymenl Date and any installmcnt of interest due on a previous [nterest Payment Date which remains unpaid. Moneys in the Interest Account shall be used for the payment of interest on the Bonds and any Parity Bonds as the same become due. (b) To the Principal Account, an amount such that the balance in the Principal Account five (5) Business Days prior to October 1 of each year, commencing Octobcr 1, 2008, shall equal the principal payment duc on the Bonds and any Parity Bonds maturing on such October 1 and any principal payment due on a previous October 1 which remains unpaid. Moneys in the Principal Account shall be used for the payment of the principal of such Bonds and any Parity Bonds as thc same become due at maturity. Section 3.5. Redemption Account of thc Special Tax Fund. (a) With respect to cach October 1 on which a Sinking Fund Paymcnt is due and after the deposits have been made to the Administrative Expenses Account, the Interest Account, and the Principal Account of the Special Tax Fund as reyuired by Sections 3.3 and 3.4 hereof, the Trustee shall next transfer into the Redemption Account of the Special Tax Fund from the Special Tax Fund the amount needed to make the balance in the Redemption Account five (5) Business Days prior to each October 1 eyual to the Sinking Fund Payment due on any Outstanding Bonds and Parity Bonds on such October 1; provided, howevcr, that, if amounts in the Special Tax Fund are inadequate to �nake the Coregoing transfers, then any deficiency shall be made up by an immediatc transfer from the Reserve Account, if funded, pursuant to Section 3.6 below. Moneys so deposited in thc Redemption Account shall be used and applied by the Trustee to call and redeem Term Bonds in accordance with the Sinking Fund Payment schedules set forth in Section 4.1(b) hereof, and to redeem Parity Bonds in accordance with any Sinking Fund Payment schedule in the Supplemental Indenture for such Parity Bonds. 23 yx�a�i.a (b) After making thc dep�sits to the Administrative Expenses Account, thc Intcrest Account and the Principal Account of the Special Tax Fund pursuant io Seciions 3.3 and 3.4 above and to thc Redcmpti�n Account ior Sinking Fund Payments thcn duc pursuant to subparagraph (a) oC this Section, and in accordancc with the District's election to call Bonds for optional redemption as set forth in Section 4.1(a) hereof, or to call Parity Bonds for optional redemption as set forth in any Supplemental Indenture for Parity Bonds, the Trustee shall transfei- fi•om the Spccial Tax Fund and deposit in the Redemption Account moncys available fol•thc puipose and sut'ficient to pay the principal and the prcmiums, if any, payablc on the Bonds or Parity Bonds callcd tor optional redemption; provided, however, that amounts in the Special Tax Fund (other than thc Administrative Expenses Account therein) may be applied to optionally rcdeem Bonds and Parity Bonds only ii' immcdiately following such redemption the amount in the Reserve Account will equal the Reserve Requirement. (c) Prcpaymcnts dcposited to thc Redemption Account shall be applied on the redemption date established pursuant to Section 4.1(c) hereof for the use of such Prepayinents to the payment oi'the principal of, premiu►n, and intcrest on the Bonds and Parity Bonds to be redecmed with such Prepayinents. (d) Moneys set aside in the Redemption Account shall be used solely for the purpose of redceming Bonds and Parity Bonds and shall be applied on or after the redemption date to the payrnent of principal of and premium, if any, on thc Bonds or Parity Bonds to be redcemed upon presentation and surrender of such Bonds or Parity Bonds and in the case of an optional redemption or an extraordinary rcdemption from Prepayments to pay the intcrest thereon; provided, however, that in lieu or partially in lieu of such call and redemption, moneys deposited in the Redemption Account, other than Prepayments, may be used to purchase Outstanding Bonds or Parity Bonds in the manner hereinafter providcd. Purchascs of Outstanding Bonds or Parity Bonds may be made by thc District at public or private sale as and when and at such prices as the District may in its discretion detennine but only at prices (including brokerage or other expenses) not more than par plus accrued interest, plus, in the case of moneys set aside for an optional redcmption or an extraordinary redemption, the premium applicable at the next following call datc according to the premium schedule established pursuant to Section 4.I(a) or 4.1(c) hereof; as applicable, or in the case o1'Parity Bonds the premium established in any Supplemental Indenture. Any accrued interest payable upon the purchase of Bonds or Parity Bonds may be paid irom the amount reserved in the Intcrest Account of the Special T'ax Fund i'or the payment of'interest on the next following Interest Payment Date. Section 3.6. Reserve Account of the Special Tax Fund. There shall be maintained in the Reserve Account of�the Special Tax Fund an amount equal to the Reserve Reyuircment. If funded, the amounts in the Reserve Account shall be applied as follows: (a) Except as otherwise provided in this Section 3.6, moneys in the Reserve Account shall be used solcly for the purpose of paying the principal of, including Sinking Fund Payments, and intcrest on the Bonds and any Parity Bonds when due in thc event that the moneys in the Interest Account and the Principal Account of the Special Tax Fund are insufficient therefor or moneys in thc Rcdemption Account of the Special Tax Fund arc insufficient to make a Sinking Fund Payment whcn due and for the puipose of making any required transfer to the Rebate Fund pursuant to Section 3.7 hereof upon written dir•ection i'rom the District. [f the amounts in the Interest Account, the Principal Account or the Redemption Account of the Special Tax Fund are insufficient to pay the principal of, including Sinking Fund Payments, or interest on any Parity Bonds when due, or amounts in the Special Tax Fund are insufticient to make transfers to the Rebate Fund when rcquired, the Trustec 24 qx�az i a shall withdraw from thc Reserve Account for deposit in the Intci•est Account, thc Principal Account or the Redemption Account of the Special Tax Fund or the Rebate Fund, as applicable, moncys necessary for such purposes. (b) Whenevcr moneys arc withdrawn from the Reseivc Account, atter making the required translers referred to in Sections 3.3, 3.4 and 3.5 above, the Trustee shall transfer to the Reserve Account from available moneys in the Special Tax Fund, or from any other legally available funds which the District clects to apply to such purpose, the amount needed to restorc the amount of such Reserve Account to the Rescrve Requirement. Moneys in the Special Tax Fund shall bc dccined available far transfer to thc Reserve Account only if thc Trustec determincs that such amounts will not be necdcd to makc the deposits required to be made to thc Administr-ative Expcnses Account, the Interest Account, the Principal Account or the Redemption Account of�the Special Tax Fund on or before the next October 1. If�amounts in the Special Tax Fund togethcr with any other amounts transferred to rcplenish the Reserve Account are inadequatc to restore the Reservc Account to the Reserve Requiremcnt, then the District shall include the amount necessary fully to restore the Reserve Account to the Reservc Rcquirement in the next annual Special Tax levy to the extent oi�the maximu►n permitted Special Tax rates. (c) In connection with a redemption of Bonds pursuant to Section 4.1(a) or(c) or Pai•ity Bonds in accordance with any Supplemental Indenture, or a partial defcasance of Bonds or Parity Bonds in accordance with Section 10.1 hercof, amounts in the Reserve Account may be applied to such redemption or partial defcasance so long as the amount on deposit in the Reserve Account following such redemption or partial defeasance equals the Reserve Requirement. The District shall set forth in a Certiticate of an Authorized Representative the amount in the Reserve Account to be transferred to the Redemption Account on a redemption date or to be transferred pursuant to Scction 10.1(c) to partially defease Bonds, and the Trustee shall inake such transter on the applicablc redernption or defeasance date, subject to the limitation in the preceding sentence. (d) To the extent that the Rescrve Account is at the Rescrve Requircment as of the tirst day of the tinal Bond Year for the Bonds in accordance herewith or, if applicable, with any Supplemental Indenture for an issue of Parity Bonds, amounts in the Rcserve Account may be applied to pay the principal of and intei•est duc on the Bonds and Parity Bonds, as applicable, in the final Bond Ycar for such issue. (e) Moneys in the Reserve Account in excess of ihe Reserve Requirement not transfened in accordance with the preceding provisions of this section shall be withdrawn from the Rescrve Account on the Business Day before each April 1 and October 1, and such moneys shall be transterred and deposited into the Interest Account of thc Special Tax Fund; provided, however, to the cxtent that, as of a date ninety(90) days prior to the next occurring Interest Payment Date, the amount on deposit in the Rcserve Account is cqual to or gi•cater than the aggregate remaining principal paymcnts to be paid on thc Bonds and any Parity Bonds, any and all amounts in the Reserve Account may be applied to ef�fect a redemption of all Outstanding Bonds pursuant to Section 4.1(a) and any Outstanding Parity Bonds in accordance with any Supplemental Indenture. The District shall set forth in a Cci-tificate of an Authorized Representative the amount in the Reserve Account to be transferred to the Redemption Account on a redempticm date or to be transierred pursuant to Section 10.1(c) to defease Bonds, and the Trustee shall make such transter on the applicable rcdemption or defcasance datc. 25 ��K�azi.a Secti�n 3.7. Rebatc Fund. (a) The Trustee shall establish and mai►itain a fund separate fi•om any other fund established and maintained hereundcr designated as the Rebate Fund and shall establish a separate Rebate Accc�unt and Alternative Penalty Account therein. All money at any time deposited in the Rebate Account or the Alternative Penalty Account of�thc Rebate Fund shall be held by the Ttustee in trust, tor payment to the United States Treasury. A separate subaccount of the Rebate Account and the Alternative Pcnalty Account shall be established for the Bonds and each issuc of Parity Bonds the interest on which is excluded ti•om gross income for �edcral income tax pui-poses. All amounts on deposit in the Rebate Fund with respect to the Bonds or an issuc of Parity Bonds shall be governed by this Section 3.7 and the Tax Certificate for such issue, unless the District obtains an opinion of Bond Counsel that the exclusion from gross income for federal income tax purposes of interest payments on thc Bonds and Parity Bonds will not be adversely affected if such requirements are not satisfied. (1) Rebate Account. The following reyuirements shall be satisfied with respcct to each subaccount of the Rebate Account: (i) Annual Computation. Within 55 days of the end of each Bond Year, the District shall calculate or cause to be calculated the amount of rebatable arbitrage for the Bonds and each issue of Parity Bonds to which this Section 3.7 is applicable, in accordancc with Section 148(�(2) of ihe Codc and Section 1.148-3 oC the Rcbate Regulations (taking into account any applicable exceptions with respect to the computation oCthe rebatable arbitrage described in the Tax Certificate for each issue(e.�, the temporary investments exceptions of Section 148(�(4)(B) and (C) of the Code), and taking into account whether the election pursuant to Section 148(�(4)(C)(vii) of the Code (the "1'/�% Penalty") has been made), for this purpose treating the last day of the applicable Bond Year as a computation date, within the meaning of Section 1.148-1(b) of the Rebate Regulations (thc "Rebatable Arbitrage"). The District shall obtain expert advice as to the amount of the Rebatable Arbitragc to comply with this Scction. (ii) Annual Transfcr. Within 55 days of the end of each Bond Ycar for which Rebatable Arbitrage must be calculated as required by the Tax Certificate for cach issue, upon the written direction of an Authorized Representative of the District, an amount shall be deposited to each subaccounl of the Rebate Account by the Trustee from any funds so designated by the District if and to the extent required, so that the balance in the Rebate Account shall equal the amount of Rebatable Arbitrage so calculated by or on bchalCof the District in accordance with (i) of this Subscction (a)(1) with respect to the Bonds and each issue of�Parity Bonds to which this Section 3.7 is applicablc. In the event that immediately following any transfer required by the previous sentence, or the date on which the District detennines that no transfer is requircd for such Bond Year, the amount then on deposit to thc credit of the applicablc subaccount of thc Rebate Account exceeds the amount rcquired to be on deposit therein, upon written instr•uctions from an Authorized Representative of'the District, the Trustee shall withdraw the excess from the appropriate subaccount of the Rebate Account and then credit the cxcess to the Special Tax Fund. (iii) PaYnent to the Treasury. The Trustee shall pay, as directcd in writing by an Authorizcd Representative of the District, to the United States Treasury, out of amounts in each subaccount of the Rebate Account, 26 ����az i.a (X) not later than 60 days after the end of(A) the fifth Bond Year for the Bonds and cach issuc of Parity Bonds to which this Section 3.7 is applicable, and (B) each applicable fifth Bond Year thereaftcr, an am�unt cqual to at least 90% of the Rebatable Arbitrage calculated as of thc end of such Bond Ycar for the Bonds and cach issue of Parity Bonds, as applicable; and (Y) not later than 60 days after the paymcnt or redemption c�f all oi�thc Bonds or an issuc of Parity Bonds, as applicable, an a►nount cyual to 100% oi'the Rebatable Arbitrage calculated as�f the end of such applicable Bond Year, and any income attributable to the Rebatable Arbitrage, computed in accordance with Section 148(� �f the Code. In the event that, prior to the time ot'any payment required to bc ►nade Crom thc Rebate Account, the amount in the Rebate Account is not sufficient to make such payment when such payment is due, the District shall calculate or cause to be calculated the amount of such deficiency and deposit an amount rcceived from any legally available source equal to such deficiency prior to the time such payment is due. Each payment required to be made pursuant to this Subsection (a)(1) shall be made to the Internal Revenuc Service Center, Ogden, Utah 84201 on or before the date on which such payment is due, and shall be accompanied by Internal Revenue Service Foi-m 8038-T, or shall be made in such othei• ►nanner as provided under the Codc. (2) Alternative Penalty Account. (i) Six-Month Computation. If the 1'/�% Penalty has been ciccted for the Bonds or an issue of Parity Bonds, within 85 days of each particular Six-Month Period, thc District shall determine or cause to be determined whether the 1'/z% Penalty is payable(and the amount of such penalty) as of the close of the applicable Six-Month Period. The District shall obtain expert advice in making such detcrminations. (ii) Six-Month Transfer. Within 85 days of the close of each Six-Month Period, the Trustee, at the written direction of an Authori•r.ed Representative of the District, shall deposit an amount in the appropriate subaccounts of the Alternativc Penalty Account . from any source of funds held by the Trustee pursuant to this Indenture and designated by thc District in such written directions or provided to it by the District, if and to thc cxtcnt required, so that the balance in each subaccount of the Alternative Penalty Account equals the amount of 1%z% Penalty due and payable to the United States Treasury determined as provided in Subsection (a)(2)(i) above. In the cvent that iin►nediately following any transfer provided for in the previous scntence, or the date on which thc District detcrmines that no transfer is required for such Bond Ycar, the amount then on deposit in a subaccount of the Alternative Penalty Account exceeds the amount required to be on deposit therein to make the payments required by Subscction(iii) below, the Trustee, at the written direction oCan Authori�ed Representative of the District, may withdraw thc cxcess from thc applicable subaccount of the Alternative Penalty Account and credit the exccss to the Special Tax Fund. (iii) Payment to the Treasury. The Trustee shall pay, as directed in writing by an Authorized Representative of the District, to the United States Treasury, out o(' amounts in a subaccount of the Alternative Penalty Account, not later than 90 days after the close of each Six-Month Period the 1'/z% Penalty, if applicable and payable, computed with respect to the Bonds and any issue of Parity Bonds in accordance with Section 148(f)(4} of 27 yx�azi a the C�dc. In thc cvent that. prior to the timc of any paymcnt requircd to bc made li-om a subaccount of thc Alternative Penalty Account, the amount in such subaccount is n�t sufficient to make such payment when such payment is due, thc District shall calculate thc amount of such deiiciency and direct the Trustcc, in wi-iting, to deposit an amount cqual to such dcficiency into such subaccount of the Alternative Penalty Account from any funds held by the Trustee pursuant to this lndcnture and designated by the District in such written directions prior to the time such payment is due. Each payment required to be made pursuant to this Subsection (a)(2) shall be made to the Intcrnal Revcnue Seivicc, Ogden, Utah 84201 on or before the date on which such payment is duc, and shall be accompanied by Intcrnal Revenue Scrvice Form 8038-T or shall be made in such other manner as provided under the Code. (b) Disposition of Unexpended Funds. Any funds remaining in the Accounts of thc Rebate Fund with respect to the Bonds or an issuc of�Parity Bonds after redemption and payment of such issue and after making the payments described in Subsection (a)(1)(iii) or(a)(2)(iii) (whichever is applicable), may be withdrawn by the Trustec at the written direction of the District and utilizcd in any manner by the District. (c) Survival of Defeasance and Final Pavment. Notwithstanding anything in this Section or this Indenture to the contrary, the obligation to comply with the requiremcnts of this Section shall survive the defcasance and final payment of the Bonds and any Parity Bonds with respect to which an Account has bccn created in the Rebate Fund. (d) Amendment Without Consent of Owners. This Section 3.7 may bc deleted or amended in any manner without the consent ot'the Owners, provided that prior to such event there is delivered to the District an opinion of Bond Counsel to the cffect that such delction or amendment will not adversely affect the exclusion from gross income for federal income tax purposes of interest on the Bonds and any issue of Parity Bonds issued on a tax-exempt basis. The Trustee shall not be responsible for calculating rebatablc arbitrage or for the adcquacy or correctness or any rebate report or rebate calculations. The Trustee shall be deemed conclusively to have complied with the provisions of this Indenture regarding calculation and payment of rebatable arbitrage if it follows the directions of the District and it shall have no independent duty to review or such calculations or enforce the compliance by the District with such rebate require►nents. Section 3.8. Surplus Fund. Aiter making the transfers required by Sections 3.3, 3.4, 3.5, 3.6 and 3.7 hereof, as soon as practicable after each October 1, and in any event prior to each November I, the Trustee shall transfer all remaining amounts in the Special Tax Fund to thc Surplus Fund, unless on or prior to such date, it has received a Certificate of an Authori�ed Representative directing that ccrtain amounts bc rctained in thc Special Tax Fund bccause the District has included such amounts as being available in the Special Tax Fund in calculating the amount of the levy of Special Taxes for such Fiscal Year pursuant to Section 5.2(b) hereof. Moneys depositcd in the Surplus Fund will be transferred by the Trustee at the direction of an Authorized Representative of the District (i) to the Interest Account, the Principal Account or the Rcdemption Account of the Special Tax Fund to pay the principal of, including Sinking Fund Payments, premium, if any, and interest on the Bonds and any Parity Bonds when due in the event that moncys in the Special Tax Fund and the Reserve Account ol�the Special Tax Fund are insul'licient therefor, (ii) to the Reserve Account in order to replenish the Reserve Account to the Resetve Requirement, (iii) to the Administrative Expenses Account of the Special Tax Fund to pay Administrativc Expenses to thc 28 ��R�a�i .s extcnt that thc amounts c�n dcposit in thc Administrative Expenses Account of the Special Tax Fund arc insufficient to pay Administrative Expenses, or(iv) i�r-any other lawfu] purp�se ofthe DisU�ict. The amounts in the Surplus Fund are not pledged to thc repayment of the Bonds or the Parity Bonds and may be used by the District for any lawful purpose. In the event that the District reasonably expects to use any portion of the moneys in the Surplus Fund to pay debt service on any Outstanding Bonds or Parity Bonds, the District will notify the Tiustee in a Ccrtificate of an Authorized Representative and the Trustcc will segrcgate such amount into a separate subaccount and the ►noneys on deposit in such subaccount of the Surplus Funci shall be invested at the written direction of the District in Authorized Investments the interest on which is excludable (rom gross income under Section 103 of thc Code (other than bonds the interest on which is a tax preference item for purposes of computing the alternative mini►num tax of individuals and corporations under the Code) or in Authorizcd Investments at a yield not in excess of the yield on the issuc of Bonds or Parity Bonds to which such amounts are to be applicd, unless, in the opinion of Bond Counsel, investment at a higher yield will not adversely affect the exclusion from gross income for federal income tax purposes of interest on the Bonds�r any Parity Bonds which were issued on a tax-excmpt basis for federal income tax purposes. Section 3.9. Costs of Issuance Fund. The moneys in the Costs of Issuance Fund shall be disbursed by the Trustee pursuant to a Certificate of an Authori�ed Representative of the District, and any balance therein shall be transferrcd by the Trustee to thc Special Tax Fund 180 days after the Delivery Date of the Bonds or Parity Bonds, as applicable. Section 3.10. Investments. Moneys held in any of the Funds, Accounts, and Subaccounts under this Indenture shall be invested at the written dircction of the District in accordance with the limitations set forth below only in Authori�ed Investments which shall be deemed at all times to bc a part of such Funds, Accounts and Subaccounts. Any loss resulting from such Authorized Investinents shall be crcdited or charged to the Fund, Account or Subaccount from which such investment was made, and any investment earnings on a Fund, Account or Subaccount shall be applied as Collows: (i) investment earnings on all amounts deposited in the Costs of Issuancc Fund, the Special Tax Fund, the Surplus Fund and the Rebate Fund and each Account and Subaccount therein (other than the Reservc Account of the Special Tax Fund) shall be depositcd in those respective Funds, Accounis, and Subaccounts, and (ii) investrnent earninbs on all amounts deposited in the Reserve Account shall be deposited therein to be applied as set forth in Section 3.6. Moneys in the Funds, Accounts, and Subaccounts held under this Indenture may be invested by the Trustee as directed in writing by the District, from time to time, in Authori�ed Invcstments subject to the following restrictions: (a) Moneys in the Costs of Issuance Fund shall be invested in Authorized Investments which will by their tenns mature, or in the case of'an Investment Agreement are available wi�hout pcnalty, as close as practicable to the date the District estimates the moneys represented by the particular investment will be needed for withdrawal from the Costs of Issuance Fund. (b) Moneys in the Interest Account, thc Principal Account and the Redemption Account of the Special Tax Fund shall be invested only in Authorized Investments which will by their terms mature, or in the case of an Investment Agreement are available for withdrawal without penalty, on 29 ��a�az i a such datcs so as to ensw•c thc paymcnt ol'principal �l; prcmium, ifany, and intcrest on the Bonds and any Parity Ronds as the same bec<�me due. (c) Moncys in the Rcseive Account of the Special Tax Fund may be invested only in Authori�ed Investments which, takcn together, have a weighted average maturity nc�t in excess of� five ycars; provided that such amounts may be invested in an Investment Agreement to the later of the final matuc•ity oi'the Bonds or any Parity Bonds so long as such amounts may be withdrawn at any time, without penalty, for application in accordance with Section 3.6 hereof; and provided that no such Authorized Invcstment of amounts in the Rescrve Account allocable to the Bonds or an issue of Parity Bonds shall mature later than the respective final maturity date of the Bonds or the issuc ol� Parity Bonds, as applicablc. (d) Moneys in the Rebate Fund shall be invested only in Authorized lnvestments of the type described in clause (1) of the definition thereof which by their terms will mature, as nearly as practicable, on the dates such amounts are needed to be paid to the United States Government pursuant to Section 3.7 hereof or-in Authori�ed Investments of the type described in clause (7) of the definition thereof. (e) In the absence of�written investment directions from the District, the Trustee shall invest solely in Authorized Investments specified in clause(7) of the definition thcreof. The Trustee shall sell, or present for redemption, any Authorized Investment whenever-it may be necessary to do so in order to provide moncys to meet any payment or transfer to such Funds and Accounts or from such Funds and Accounts. For the purpose of determining at any given time the balance in any such Funds and Accounts, any such investments constituting a part of such Funds and Accounts shall be valued at their cost, except that amounts in the Rcserve Account shall be valued at the market value thereol�at Icast semiannually on or bef'ore cach [nterest Payment Date. In making any valuations hereunder, the Trustec ►nay utilize such computerized sccurities pricing services as may be available to it, including, without li►nitation, those available through its regular accounting system, and conclusively i•cly thereon. Notwithstanding anything herein to the contrary, the Trustee shall not be responsible for any loss f'rom investments, sales or transfcrs undertaken in accordance with thc provisions of this Indenturc. The Trustee or an aftiliate may act as principal or agent in the making or disposing of any investment and shall be entiticd to its customary fee for such invcstment. The Trustee may scll at the best market price obtainable, or present for redemption, any Authorized Investment so purchased whenever it shall be necessary to provide moneys to mcet any required payment, transfer, withdrawal or disbursement from the Cund or account to which such Authorized Investment is credited, and, subjcct to the provisions of Scction 7.4, the Trustee shall not be liable or responsible for any loss resulting from such investment. For investmcnt purposes, the Trustee may comminglc thc f'unds and accounts established hcreunder, but shall account for each separately. The District acknowledges that, to the extent regulations of the Comptroller of the Currency or other applicable regulatory cntity grant the District the right to reccive brokerage confiimations oi' security transactions as they occur, the District specifically waives receipt of such confirmations to the extent permitted by law. The Trustee will furnish the District periodic cash transaction statements which include detail for all investment transactions made by the Trustec hereunder. 30 v��a2t a ARTICLE I V REDEMPTI(�N OF f30NDS AND PARITY BONDS Section 4.1. Redemption of Bonds. (a) Optional Redemption. The Bonds maturing on or bcfore October 1, 20 are not subject to call and redemption prior to ►naturity. The Bonds maturing on or afrcr October 1, 20 shall be subject to call and redemption prior to maturity and ►nay bc redeemcd, at the option of the District, Crom any source of (unds on any Intei•est Payment Date in whole, or in part, from such maturities as are selccted by thc District and by lot within a maturity, at thc following redemption prices expresscd as a percentage of the principal amount to be redeemed, together with accrued intcrest to the date of'redemption: Redemption Dates Redcmption Prices Octobcr 1, 20_and April 1, 20_ % Octobcr I, 20_ and April I, 20_ _ October I, 20_ and Interest Paymcnt Dates thereatter In thc event the District clects to redeem Bonds as provided above, the District shall give written notice to the Trustee of its election to so redeem, the redemption date and the principal amount of the Bonds of each maturity to be redeeined. The notice to thc Trustee shall be given at least forty-five (45) but no more than ninety(90) days prior to the redemption date, or by such latcr date as is acccptable to the Trustee, in its sole discretion. (b) Mandatory Sinkin�l Fund Redemption. (i) The Term Bonds maturing on October 1, 20_ and October 1, 20_ shall be callcd before maturity and redcemed, from the Sinking Fund Payments that have been deposited into the Redemption Account, on October 1, 20_ and October 1, 20 , respectively, and on each October 1 thereafter prior to maturity, in accordance with the schedule of Sinking Fund Payments set forth below. The Term Bonds so called for redemption shall be selected by the Trustee by lot and shall be redeemed at a redemption price for each redeemed Term Bond equal to the principal amount ther•eof, plus accrued interest to the redemption date, without premium, as follows: BONDS MATURING OCT(�BER 1, 20 Redemption Date (October 1) Principal Amount $ (maturity) 31 ��tc7a�i.a BONDS MATIIRING OCTnBER l, 20 Redemption Date (nctober 1) Principal Amount � (maturity) (ii) Purchase of Term Bonds in Licu of Redemption. If during the Fiscal Year immediately preceding one of the redemption dates specified above the District purchases Tenn Bonds, at least forty-five (45) days prior to the redemption date the District shall notify the Trustee as to thc principal amount purchascd and thc amount of Term Bonds so purchased shall be credited at the time of purchase, to the extent of the full principal amount thereof, to reduce such upcoming Sinking Fund Paymcnt for thc applicablc maturity of the Term Bonds so purchased. All Term Bonds purchased pursuant to this subsection shall be cancelled pursuant to Section 1 1.1 hereof. In the event of a partial optional rcdcmption or extraordinary redemption of the Tern� Bonds, each of thc rcmaining Sinking Fund Payments for such?erm Bonds, as described above, will bc reduced, as nearly as practicable, on a pro rata basis, in intcgral multiples of$5,000. (c) Extraordinary Rcdcmption. The Bonds are subject to extraordinary redemption as a whole, or in part on a pro rata basis among maturities, on any [nterest Payment Date, and shall be redeemed by the Trustee, from Prepayments deposited to the Redemption Account pursuant to Section 3.2, plus amounts transferred from the Reserve Account pursuant to Section 3.6(c), at the following redemption prices, expressed as a percentage of the principal amount to be redeemed, together with accrued interest to the redemption date: Redemption Dates Redemption Prices October 1, 20_ and April 1, 20_ _% October 1, 20_ and April 1, 2U_ _ October 1, 20_ and April 1, 20_ _ October 1, 20 and Interest Paytncnt Dates thereafter The District shall give written notice to the Trustee of its intention to redeem Bonds pursuant to this subsection, the redemption date, and the principal amount of the Bonds of each maturity to be redeemed at lcast forty-fivc (45) but no more than ninety(90) days prior to the redemption date, or by such later date as is acceptable to the Trustee, in its sole discretion. (d) The redemption provisions for Parity Bonds shall be set forth in a Supple►nental Indcnture. Section 4.2. Selection of Bonds and Parity Bonds for Redemption. If�less than all of' the Bonds or Parity Bonds Outstanding are to be r•edeemed, the portion of any Bond or Parity Bond 32 987421 4 of a denomination of morc than �5,000 to bc redcemcd shall be in the principal amount of�5,000 or an integral multiple thereof. In selecting portions of such Bonds or Parity Bonds for redemption, thc Trustee shall treat such f3onds or Parity Bonds, as applicablc, as representing that number of Bonds or Parity Bonds of$5,000 denominations which is obtaincd by dividing thc principal amount of such Bonds or Parity Bonds to be redeemed in part by �5,000. The procedure for the selection of Parity Bonds for redemption may be modified as set forth in the Supplcmental Indenture for such Parity Bonds. The Trustee shall promptly notify the District in writing of�the Bonds or Parity Bonds, �r portions thcreof; selected for redemption. Section 4.3. Notice of Redemption. When Bonds or Parity Bonds are duc for redcmption under Section 4.1 above or under anothcr i•edemption provision set forth in a Supplemental Indenturc relating to any Parity Bonds, the Trustee shall give notice, in the namc of the District, of thc redemption of such Bonds or Parity Bonds; provided, however, that a notice ot�a redemption to bc made from other than from Sinking Fund Payments shall be conditioned on there being on deposit on the redcmption date sufficient moncy to pay thc redemption price of the Bonds or Parity Bonds to be redcemed. Such notice of redcmption shall (a) specify the CUSIP numbers (if any), the bond numbers and the maturity date or dates of the Bonds or Parity Bonds selected for redemption, cxcept that wherc all of the Bonds or all of an issue of Parity Bonds are subject to redemption, or all the Bonds or Parity Bonds of one maturity, are to be redeemed, ihe bond numbers of such issue need not be specified; (b) state the datc fixed for redemption and surrender of the Bonds or Parity Bonds to bc redccmed; (c) statc the redemption pricc; (d) state the place or places whcre the Bonds or Parity Bonds are to bc redeemed; (e) in the case of Bonds or Parity Bonds to be redeemed only in part, state the portion of such Bond or Parity Bond which is to be redeemed; (t) statc the date of issue of the Bonds or Parity Bonds as originally issued; (g) state the rate of�interest borne by each Bond or Parity Bond being redeemed; and (h) statc any other descriptive infornlation needed to identify accurately the Bonds or Parity Bonds being redeemed as shall be specified by thc Trustee. Such notice shall further state that on the date fixed for redemption, there shall become due and payable on each Bond, Parity Bond or portion thereof called for i-edemption, the principal thereof, together with any premium, and interest accrued to the redcmption datc, and that from and after such date, interest thcreon shall cease to accrue and be payable. At lcast thirty(30) days but no more than forty-five (45) days prior to the redecnption date, thc Trustee shall mail a copy of such notice,by first class mail, postage prepaid, to the respective Owners thcreof'at their addresses appearing on the Bond Register, and to the original purchaser of the Bonds or Parity Bonds, as applicable. Thc actual receipt by the Owner of�any Bond or Parity Bond or the original purchaser of�any Bond or Parity Bond of noticc of such redemption shall not be a condition precedent to redemption, and neither the failure to receive nor any defect in such noticc shall affect the validity of the proceedings for the redemption of�such Bonds or Parity Bonds, or the cessation of interest on thc redemption datc. A certificate by the Trustee that notice of such redemption has been given as herein providcd shall be conclusive as against all parties and thc Owner shall not bc entitled to show that he or she failcd to receivc notice of such redemption. In addition to the foregoing notice, further notice shall be given by the Trustee as set out below, but no defect in said further notice nor any f'ailurc to givc all or any portion of such further notice shall in any manner defeat thc effectiveness of a call for redemption if notice thereof is given as above prescribed. Each furthcr notice of rcdcmption shall be scnt not laler than thc date that notice or redemption is mailed to the Bondowners pur•suant to the first paragraph of this Section by registered or certiticd mail or overnight delivery service to the Depository and to any other registered securities 33 98742I 4 depositories then in thc business of holding substantial amounts �f obligations of typcs comrrising the Bondti and Parity Bonds as dctcrmined by Trustce and ro one or more national inforniation services that the Trustee deterniines are then in the business �f disseminating notice �f redernpticm of obligations such as thc E3onds and Parity Bonds: Upon the payment of�thc redemption price of any Bonds and Par•ity Bonds being redecmed, each check or other transfcr of funds issued for such purpose shall to the extent practicablc bear the CUSIP number identifying, by issue and maturity, the Bonds and Parity Bonds being redcemed with the proceeds of such check or other iransi'er. Section 4.4. Partial Redemption of Bonds or Parity Bonds. Upon surrendcr of any Bond or Parity Bond to be i-edeemed in part only, the District shall execute and the T�ustee shall authenticate and deliver to the Bondowner, at the expense of'thc District, a new Bond or Bonds or a new Parity Bond or Parity Bonds of authoriied denoininations eyual in aggregate principal amount to thc unredecmed portion of the Bonds surrendcred, with thc samc interest rate and the samc maturity or, in the case of surrender of a Parity Bond, a new Parity Bond or Parity Bonds subject to thc Corcgoing limitations. Section 4.5. Effect of Notice and Availability of Redemption Money. Notice of redemption having been duly given, as provided in Section 4.3 hereof, and the amount necessary for the redemption having been madc availablc for that purpose and being available thcref'or on the date fixed for such redemption: (a) the Bonds and Parity Bonds, or portions thereof, designated for redemption shall, on the date fixed for redemption, bccome due and payable at the redemption pricc thereof�as provided in this Indenture or in any Supplemental Indenture with respect to any Parity Bonds, anything in this Indenture or in the Bonds or the Parity Bonds to the contrary notwithstanding; (b) upon presentation and surrender thereof at the office of the Trustee, the redemption price of such Bonds and Parity Bonds shall be paid to the Owners thereof; (c) as of the redemption date the Bonds or thc Parity Bonds, or portions thereof so designated for redemption shall be decmed to be no longer Outstanding and such Bonds or Parity Bonds, or portions thercof, shall cease to bcar further interest; and (d) as oi�the date fixed f��r redeinption no Owner of any of the Bonds, Parity Bonds or portions thereof�so designated for redemption shall be entitled to any of the benefits of this Indenture or any Supplemental Indenture, or to any other rights, except with respect to payment of thc redemption pricc and intcrest accrued to the redemption date from the amounts so made available. ARTICLE V COVENANTS AND WARRANTY Section 5.1. Warranty. The District shall preserve and protect the security pledged hercunder to the Bonds and any Parity Bonds abainst all claims and demands of all persons. 34 ��K�azi.a Section 5.2. Covenants. So long as any�f the Bonds or Parity Bonds issued hcreunder are Outstanding and unpaid, the District makes the foll�wing covenants with the f3ondo�vners under thc provisions of the Act and this Indenture (t� bc performcd by the District or its proper�fficci•s, agents or employees), which covenants ar-c necessaiy and desirable to secure the Bonds and Parity Bonds and tend to make thcm more marketablc; prc�vided, howevcr, that said covenants do not r•equire the District to cxpend any funds or moncys other than the Special Taxes and other amounts deposited to the Special Tax Fund: (a) Punctual Pavment; A�ainst Encumbrances. The District covenants ihat it will receive all Spccial Taxes in trust for the Owners and will instruct thc Treasurer to deposit all Special Taxes with the Trustee immediately upon their apportionment to the District, and the District shall have no beneficial right or interest in the amounts so deposited except as provided by this Indenture. All such Spccial Taxes shall be disbursed, allocatcd and applied solely to the uses and purposes set forth herein, and shall be accounted for scparately and apart from all other money, funds, accounts or othec- resources of the District. The District covenanis that it will duly and punctually pay or cause to be paid the pr•incipal of and interest on every Bond and Parity B�nd issued hereunder, togcther with the prcmium, if any, thereon on the date, at the place and in thc manner set forth in the Bonds and the Parity Bonds and in accor•dance with this Indenturc to the extent that Net Taxes and other amounts pledged hereunder arc available therefor, and that the payments into the Funds and Accounts crcated hereundcr will bc inade, all in strict conformity with the tcrms of the Bonds, any Parity Bonds, and this Indenture, and that it will faithfully observe and perform all of the conditions, covenants and requirements of this Indenture and all Supplemcntal lndentures and of the Bonds and any Parity Bonds issued hereunder. The District will not mortgage or otherwise encumber, pledge or place any chargc upon any of the Net Taxes except as provided in this Indenture, and will not issue any obligation or security having a lien or charge upon the Net Taxes superior to or on a parity with the Bonds, other than Parity Bonds. Nothing herein shall prevent the District from issuing or incurring indebtedncss which is payable from a pledge of�Net Taxes which is subordinate in all respects to the pledge of Net Taxes to repay the Bonds and the Parity Bonds. (b) Levy of Special Tax. The legislative body of the District represents it has levied thc Special Tax for Fiscal Year 2006-07 pursuant to the Rate and Method, and so long as any Bonds o►• Parity Bonds issued under this Indcnture are Outstanding, but subject to the Rate and Method, the lcgislative body of the District covenants it will continue to levy the Special Tax in an amount eyual to the Special Tax Require►nent (as detined in the Rate and Method), which includes, but is not limited to, amounts sufficient, togcther with othcr amounts on deposit in the Special Tax Fund and available for such purpose, to pay(1) the principal of and interest on the Bonds and any Parity Bonds when duc, (2) the Administrative Expenses, and (3) any amounts required to rcplenish the Rescrve Account of the Special Tax Fund to the Rcserve Requirement. Thc District further covenants that it will take no actions that would discontinue or cause the discontinuance of the Special Tax levy or the District's authority to levy the Special Tax for so long as the Bonds and any Parity Bonds are Outstanding. (c) Commence Foreclosure Actions. The District covenants for the benetit of the Owners of the Bonds and any Parity Bonds that it (i) will commence foreclosure actions against parcels with at lcast four(4) installments of delinyuent Special Taxes which total in the aggregate at 35 ��s�az i.a Icast �6,000 by the October 1 following the close of each Fiscal Year in which such Spccial Taxes were due; and (ii) will commence foreclosurc actions against all parcels with delinquent Special ��axes by the nctober 1 following the close of each Fiscal Year in which it receives Special Taxes in an amount which is Icss than 95% of the total Specia( Tax levied and the amount on deposit in the Reserve Account is at less than the Rescrve Requirement, and (iii) will diligently pursue such toreclosure actions until the delinyuent Special Taxes are paid, and in no event shall such foreclosurc actions excecd thc time periods specif ied in Section 53356.1 of the Act. The District covenants ihat it will deposit the net proceeds of�any foreclosure in the Special Tax Fund and will apply such proceeds remaining aCter the payinent of Administrative Expenses to make current payments of�principal and interest on thc Bonds and any Parity Bonds, to bring the amount on deposit in the Reservc Account up to the Reservc Requirement and to pay any delinquent installments of principal or interest due on the Bonds and any Parity Bonds. Notwithstanding the foregoing, the District may elect (but is not obligated) to advance the amount of any particular delinquency(excluding penalties and interest) and deposit such amount to the Special Tax Fund. Upon a deposit of such money in the Special Tax Fund, the District will not need to initiate a foreclosure action as provided abovc;provided, however, thc District may reimburse itself for such advance when the Special Tax on such property is paid in the amount of such advance plus interest on such amount at a rate equal to the yield on the Outstanding Bonds. Interest and penaltics paid in excess of the amount advanced by the District shall be deposited in thc Special Tax Fund. (d) Books and Accounts. The District will keep proper books of records and accounts, separate from all other records and accounts of the District, in which complete and correct entries shall be made of all transactions relating to the Project, the levy of the Special Tax and the dcposits to the Special Tax Fund. Such books of records and accounts shall at all times during business hours be subject to the inspection of thc Trustee or of thc Owners of not less than 10% of the principal amount of the Bonds or the Owners of not less than l0% of�any issue of Parity Bonds then nutstandinb or their representatives authorized in writing. (c) Federal Tax Covenants. Notwithstanding any other provision of this [ndenture, absent an opinion of Bond Counsel that the exclusion from gross income of interest on the Bonds and any Parity Bonds issued on a tax-cxempt basis for federal income tax purposes will not be adversely affected for ['ederal income tax purposes, the District covenants to comply with all applicable requirements of the Code necessary to preserve such cxclusion from gross income and specifically covenants, without limiting the gencrality of�the foregoing, as follows: (1) The District shall not take any action, or fail to take any action, if any such action or failure to take action would adversely affect the Tax-excmpt status of intcrest on the Bonds under Section 103(a) of the Code or cause interest on the Bonds to be an item of tax preference for purposes of the federal alternative ininimum tax imposed on individuals and corporations under Section 55 of thc Code. (2) In furtherance of the forcgoing tax covenant, the District shall comply with the provisions of the Tax Certircate, which is incorporated herein as if fully set forth herein. These covenants shall survive payment in full or defeasance of thc Bonds. 36 yti7d2I.4 (t) Reduction of Maximum Special "raxes. The District hereby finds and dctennines that, historically, delinyucncics in the payment of spe�ial taxes authorired pursuant to the Act in community facilitics disU•icts in Southern Calif�rnia have trom time to time becn at levcis reyuiring the levy of special taxes ac the maximum authorized rates in ordcr to makc timely payment of principal �f and interest on the outstanding indebtedness of such cotnmunity facilities districts. For this reason, the District hereby determines that a reduction in the maximum Special Tax rates authorized to bc levied on parcels in the Disti•ict bclow the levels pr•ovided in this Section 5.2(� would interfere with the tiinely retirement of the Bonds and Parity Bonds. The District determincs it to be necessary in order to preserve the security for the Bonds and Parity Bonds to covcnant, and, to the maximum extent that the law pennits it to do so, the District hcreby does covenant, that it shall not initiate proccedings to reduce the maximum Special Tax ratcs ior the District, unless, in connection therewith, (i) the District reccives a certiticate from one or more Independent Financial Consultants which, when taken together, ccrtify that, on the basis of the parcels of land and improvemenis existing in the District as of the July 1 preceding the rcduction, the maximum amount of the Special Tax which may be levied on then existing Developed Property in cach Bond Year for any Bonds and Parity Bonds Outstanding will equal at least the sum of the estimated Administrative Expenses and 1 l 0% of ihe gross debt service in cach Bond Year on all Bonds and Parity Bonds to remain Outstanding after the reduction is approved, (ii) thc District finds that any reduction made under such conditions will not adversely affect the interests of the Owners of'the Bonds and Parity Bonds, and (iii) thc District is not dclinquent in the paycnent oI�the principal of or interest on ihe Bonds or any Parity Bonds. For purposes of estimating Administrativc Expenses for thc foregoinb calculation, the Independent Financial Consultants shall compute the Administrative Expenses for the current Fiscal Ycar and cscalate that amount by two percent (2%) in each subseyucnt Fiscal Year. (g) Covenants to Defend. The District covenants that, in the event that any initiativc is adopted by the qualificd electors in the District which purports to reduce the maximum Special Tax below the levels specified in Section 5.2(� above or to limit the powcr of the District to levy the Special Taxes for the purposes set forth in Section 5.2(b) above, it will commencc and pursue legal action in order to preserve its ability to comply with such covenants. (h) Limitation on Ri�ht to Tender Bonds. The District hereby covenants that it will not adopt any policy pursuant to Section 53341.1 of the Act permitting the tender of Bonds or Parity Bonds in full paymcnt or partial payment of any Special Taxes unless the District shall have first received a certificate from an Independent Financial Consultant that the acceptance of such a tender wili not result in ihe District having insul�ticient Special Tax revenues to pay the principal of and interest on the Bonds and Parity Bonds when due. (i} Continuin�Disclosure. The District covenants to comply with 1he terms of the Continuing Disclosure Agreement and with the terms of any agreement executed by thc District with respect to any Parity Bonds to assist the Underwriter in complying with Rule 15(c)2-12 adopted by the Securities and Exchange Commission. (j) Further Assurances. The District shall make, execute and deliver any and all such further agreements, instruments and assuranccs as may be reasonably necessary or proper to carry out the intention or to facilitatc the perfonnance of this Resolution and for the better assuring and confirming unto the nwners of�the Bonds and any Parity Bonds of the rights and benefits providcd in this Resolution. 37 ��s�a2 i.a ART'ICI_E VI AMENDMENTS '1�0 INDENTURE Scction 6.1. Supplemcntal Indentures or Orders Not Requiring Bondowner Consent. The District may frc�m time to time, and at any limc, with the written conscnt of the Insurer(as long as the Insurance Policy is in full force and eflect) but without notice to or consent of any�f the Bondowners, adopt Supplemental Indentures for any o(�the tollowing purposes: (a) to cure any ambiguity, to con•ect or supplcment any provisions herein which may be inconsistent with any other provision herein, or to rnake any other provision with respect to matter•s oi-questions arising under this Indenture or in any additional resolution or ordcr, provided that such action is not matcrially adverse to the interests of'the Bondowners; (b) to add to the covenants and agrecments of and thc limitations and the restrictions upon the District contained in this Indenture, other covenants, agreements, limitations and restrictions to be observed by thc District which are not contrary to or inconsistent with this Indenture as theretofore in effect or which further secure Bond or Parity Bond payments; (c) to provide for the issuance of any Parity Bonds, and to provide the terms and conditions under which such Parity Bonds may be issucd, subject to and in accordance with the provisions ofthis Indenture; (d) to modify, amend or supplement this Indenture in such manner as to permit the qualification hereof under the Trust Indenture Act of 1939, as amended, or any similar federal statute hereafter in effect, or to comply with the Code or regulations issued thereunder, and to add such other terms, conditions and provisions as inay be permitted by said act or similar federal statute, and which shall not materially adversely affect the interests of thc Owners of the Bonds or any Parity Bonds then Outstanding; (e) to modify, altcr or amend the Rate and Method in any manner so long as such changes do not reduce the maximum Special Taxes that may be levied in cach year on property within the District to an amount which is less than the sum of the estimated Administrative Expenses and 110% of the principal and intcrest due in each con-esponding future Bond Year with respcct to the Bonds and Parity Bonds Outstandin�as of the date of such amendment;or (n to modify, alter, amend or supplement this Indenture in any other respect which is not materially adverse to the Bondowners. Scction 6.2. Supplemental Indentures or Orders Requiring Bondowner Consent. Exclusivc of the Supplemental Indentures described in Section 6.1 and with the written consent of the Insurer(as long as the Insurance Policy is in full force and cfT'ect), the Owners of not less than a ►najority in aggregate principal amount of�the Bonds and Parity Bonds Outstandin�;shall have the right to consent to and approve the adoption by the District of�such Supplemental Indentures as shall be deemcd neccssary or desirable by the District for the purpose of waiving, ►nodifying, altering, amending, adding to or rescinding, in any particular, any of the terms or provisions contained in this Indenture; provided, however, that nothing hcrein shall pennit, or be construed as permitting, (a) an cxtension of the maturity date of'the principal, or the payment date of interest on, any Bond or Parity Bond, (b) a reduction in the principal amount oi; or redemption premium on, any Bond or Parity 38 yx�a�i a Bond or the ratc of interest thereon, (c) a prcference or priority of�any Bond or Pai-ity Bond over any other Bond or Parity Bond, or(d) a rcduction in thc aggregate principal amount of the Bonds and Parity Bonds the Owners of which are required to cc�nsent to such Supplementa) Indenture, without thc conscnt of�thc Owncrs of�all Bonds and Parity Bonds thcn Outstanding. If at any time the District shall desire to adopt a Supplemental Indenture, which pursuant to the terms oCthis Section shall require the consent of'the Bondownei-s, the District shal! so notify the Trustee and shall delivcr to the Trustee a copy of the proposed Supplemental Indenture. The Trustce shall, at the expcnse of the District, cause notice of'the proposed Supplemental Indentui•e to be mailed, by first class mail, postagc prepaid, to all Bondownei-s at their addresses as thcy appear in the Bond Register. Such notice shall brielly set forth thc nature oi�the proposed Supplemental Indenturc and shall state that a copy thereof is on file at thc of'fice of the Trustee for inspection by all Bondowners. The failure ol�any Bondowners to rcceive such noticc shall not affect the validity of such Supplemental Indenture when consented to and approved by the Owners of�not less than a majority in aggregate principal amount of the Bonds and Parity Bonds Outstanding as required by this Section. Whenever at any time within one year after the date of the first mailing of such notice, the Trustee shall receive an instrument or insttuments purporting tc� be executed by the Owners oi�not less than a majority in aggregate principal amount of the Bonds and Parity Bonds Outstanding, which instrument or instruments shall refer to the proposed Supplemental [ndenture dcscribed in such notice, and shall specifically consent to and approve the adoption thereof by the District substantially in the form of the copy refen•ed to in such notice as on file with the Trustee, such proposed Supplemental Indcnture, when duly adopted by the District, shall thereafter become a part of the proceedings for the issuance of thc Bonds and any Parity Bonds. In determinin� whether the Owners of a majority of the aggregate principal amount of the Bonds and Parity Bonds have consented to the adoption of any Supplemental [ndenture, Bonds or Parity Bonds which are owned by the District or by any person directly or indirectly controlling or controlled by or under the direct or indirect common control with the District, shall be disregarded and shall be treated as though they were not Outstanding for the purpose of any such detennination. Upon the adoption of any Supplcmental Indenture and the receipt of consent to any such Supplemental Indenture from the Owners of not less than a majority in aggregatc principal amount of� the Outstanding Bonds and Parity Bonds in instances where such consent is required pursuant to the provisions of this section, this Indenture shall be, and shall bc deemed to be, modified and amended in accordance therewith, and the respective rights, duties and obligations under this Indenturc of the District and all Owners of Outstanding Bonds and Parity Bonds shall thereafter be detennined, exerciscd and enforccd hereunder, subject in all respects to such modifications and amendments. Section 6.3. Notation of Bonds or Parity Bonds; Dclivery of Amended Bonds or Parity Bonds. After the effective date of any action taken as hereinabove provided, the District may determine that the Bonds or any Parity Bonds may bear a notation, by endorsement in fonn approved by the District, as to such action, and in that case upon demand of the Owner of'any Outstanding Bond or Parity Bond at such effective date and presentation of his Bond or Parity Bond for the purpose at the office of the Trustec or at such additional offices as the Trustec cnay select and designate for that purpose, a suitable notation as t� such action shall be made on such Bonds or Parity Bonds. If the Disirict shall so detennine, new Bonds or Parity Bonds so modified as, in the opinion of the District, shall be necessary to conform to such action shall be prepared and executed, and in that case upon deinand of the Owner of any Outstanding Bond or Parity Bond at such effective date such new Bonds or Parity Bonds shall be exchangcd at the otlice of the Trustee�r at such additional 39 �s�azi a offices as the Trustee inay select and designate fc�r that pur�osc, without cost to each nwner c►f Outstanding Bonds�r Parity Bonds, upon su►-render of such Outstandin� Bonds or Parity Bonds. ARTICLE VIl TRUSTEE Scction 7.1. Trustee. Wells Fac•go Bank, National Association, shall be the Trustcc for the Bonds and any Parity Bonds unless and until another Trustee is appointed by the District hereunder. The District may, at any time, appoint a successor Trustee satisfying the rcyuirements of Section 7.2 below for the purpose of rcceiving all money which the District is reyuircd to deposit with the Trustee hcreunder and to allocate, use and apply thc same as provided in this Indenture. The Trustee is hereby authorized to and shall mail by lirst class mail, postage prepaid, or wire transfer in accordance with Section 2.5 above, intcrest payments to the Bondowners, to select Bonds and Parity Bonds i'or redcmption, and to maintain the Bond Register. The Trustee is hereby authorized to pay the principal of and premium, if'any, on the Bonds and Parity Bonds when the samc are duly prescnted to it for payment at maturity or on call and redemption, to provide for the registration of transfer and exchange of Bonds and Parity Bonds presented to it for such purposes, to provide for the cancellation of�Bonds and Parity Bonds all as provided in this Indcnture, and to provide for the authcntication of�Bonds and Parity Bonds, and shall perform all othcr duties assigned to or imposed on it as provided in this Indenture. The Trustee shall keep accurate records of all funds administered by it and all Bonds and Parity Bonds paid, discharged and cancclled by it. The Trustee is hereby authorized to redeem thc Bonds and Parity Bonds when duly prescnted for payment at maturity, or on redemption prior to maturity. The Trustee shall cancel all Bonds and Parity Bonds upon paymcnt thereof in accordancc with the provisions of Section 1 I.1 hereof: The District shall from time to time, subject to any agreement bctween the District and thc Trustee then in force, pay to the Trustcc compensation for iis services, reimburse thc Trustee for all its advances and expenditures, including, but not limited to, advances to and fees and expenses of independent accountants or counsel employcd by it in the exercise and performance of'its powers and duties hereunder, and indemnify and save the Trustce, its officers, directors, cmployees and agents, harmless against costs, claims, expenscs and liabilities, including, without limitation, Cees and expenses of its attorneys, not arisinb from its own negligence or willful misconduct which it may incur in the cxcrcise and performance of its powers and dutics hereunder. The foregoing obligation of the District to indemnify the Trustec shall survivc the removal or resignation of the Trustee or the discharge oi�the Bonds. Section 7.2. Removal of Trustee. The District may at any time at its sole discretion remove thc Trustee initially appointed, and any successor thereto, by delivering to the Trustee a written notice of its decision to remove thc Trustee and may appoint a successor or successors thereto; provided that any such successor shall be a bank or trust company having a coinbined capital (exclusivc of borrowed capital) and surplus of at least �,100,000,000, and subject to supervision or cxamination by federal or state authority. Any removal shall become effective only upon acceptance of appointment by the successor Trustee. If�any bank or trust company appointcd as a successor publishes a report of condition at least annually, pursuant to law or to the rcquirements of�any supervising or examining authority above referred to, then for the purposes of�this scction the combined capital and surplus of such bank �r trust company shall be deemed to be its combined 40 987�2I A capital and surplus as set forth in its inost recent repc�ri of condition so published. Any rcmoval �f the Trustee and appointment ofa successor Trustee shall become effective only upon acceptance o1' appointment by the successor Trustee and notice beieig sent by thc successor Trustee to the B�ndowncrs of the successor Trustce's idcntity and address. Section 7.3. Resignation of Trustee. The Trustee may at any time resign by givinb wr•itten notice to the District and by giving to thc Owners notice ol�such resignation, which noticc shall be mailed to the Owners at their addresses appearing in the registi•ation books in the officc ol' the Trustee. Upon receiving such noiice of resignation, thc District shall promptly appoint a successor Trustee satisfying the critei•ia in Section 7.2 abovc by an instrument in writing. Any resignation or removal of the Trustee and appointment of a successor Trustee shall become eCfective only upon acccptancc of appointment by thc succcssor Trustcc. Section 7.4. Liability of Trustec. The recitais of fact and all promiscs, covenants and agreements contained herein and in the Bonds and any Parity Bonds shall be taken as statements, promises, covenants and agreements of the District, and the Trustee assumes no responsibility for the correctness of the same and makes no representations as to the validity or sufficiency of this [ndenture, the Bonds or any Parity Bonds, and shall incur no responsibility in respect thereof, other than in connection with its duties or obligations specifically set forth herein, in the Bonds and any Parity Bonds, or in the certiticate of authentication assigncd to or imposed upon the Trustee. The Trustcc shall be under no responsibility or duty with respect to thc issuance of the Bonds or any Parity Bonds for value. The Trustee shall not be liable in connection with the performance of its duties hereunder, except for its own negligence or willful misconduct. The Trustee shall be responsible for the performance of the duties of the Trustee expressly set forth in this Indcnture, and no implied duties or obligations shall be read into this Indenture against the T'rustee. The Trustce shall have no responsibility for, and makes no representations with respect to, any information, statement, or recital in any oFficial statement, offering memorandum or any other disclosure matcrial prepared or distributed with respect to the Bonds. Before taking any action under Article VIII hereof the Trustec may rcquire indemnity satisfactory to the Trustec be Curnished from any expcnses and to protcct it against any liability it may incun c�s�eundcr. The Trustee shall not be liable for any action taken or not takcn by it in accordance with thc direction of the (�wners of at least twenty-live percent (25%) (or other percentage provided for hcrein) in aggregate principal amount of�0utstanding Bonds relating to the cxercisc of any right, power or re►nedy available to the Trustee. The permissive right of�the Trustee to do things enumerated in this Indenture shall not be const►ued as a duty. The Trustee may becomc the owner or pledgee of Bonds with thc same rights it would have if it wcrc not Trustcc. The Trustee shall be protected in acting upon any notice, resolution, request, consent, order, certificate, rcport, Bond, Parity Bond, facsimile transmission, electronic mail or other paper or 41 yR74?I �1 document belicved by it to bc genuine and to have been signed or prescnted by the proper party or parties. The"i'rustec may consult with counscl, who may be c�unsel to the District, with rcgard t� legal questions, and the opinion of such counsel shall be full and complete authori�ation and protection in respect of any acti�n takcn or suficred hereunder in good faith and in accoi•dance therewith. The Trustee shall not be bound to recognize any person as the Owncr oC a Bond or Parity Bond unless and until such Bond or Parity Bonci is submitted for inspection, if required, and his title thereto satisfactorily establishcd, if disputed. Whenever in the administration of its dutics under this indenturc the Trustee 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 evidcnce in respect thereof be herein specifically prescribed) may, in the absence of bad faith on the part ot'the Trustee,bc deemed to be conclusively proved and established by a written certificate of the District, and such certificate shall be full wairant to the Trustee for any action taken or suffered under the provisions of this Indenturc upon thc faith thereot; but in its discretion the Trustee may, in lieu thereof, accept other evidence of such matter or may require such additicmal evidence as to it may seem reasonable. The Trustee shall have no duty or obligation whatsoever to enforce the collection of Special Taxes or other funds to be depositcd with it hereundcr, or as to thc correctness of any amounts received, but its liability shall be limited to the proper accounting for such funds as it shall actually receive. No provision in this Indenture shall require the Trustee to expend or risk its own funds or otherwise incur any financial liability in thc performance of�any of�its duties hereunder, or in the exercise of its rights or powers. The Trustee shall not bc deemed to have knowledge of any default or cvent of default until an of'ficer at the Trustee's corporate trust office responsible for the administration of its duties hereundcr shall have actual knowledge thereof or the Trustce shall have receivcd written notice thereof at its corporate trust office. Section 7.5. Merger or Consolidation. Any company into which the Trustee 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 thc Trustee �nay sell or transfer all or substantially all of its corposate trust business, shall be the successor to the Trustee without the execution or filing of any paper or further act, anything herein to the contrary notwithstandinb. ARTICLE VIII EVENTS OF DEFAULT; REMEDIES NOTWITHSTANDING ANYTHING TO THE CnNTRARY HEREIN, SO LONG AS THE INSURANCE POLICY REMAINS IN EFFECT AND THE INSURER HAS NOT DEFAULTED WITH RESPECT TO ITS PAYMENT OBLIGATIONS UNDER THE INSURANCE POLICY, ALL PROVISIONS OF TI-�1S ARTICLE VI11 SHALL BE SUBJECT TO, AND QUALIFIED BY, THE PROVISIONS SET FORTH IN ARTICLE IX, INCLUDING, WITHOUT LIMITATION, THE INSURER'S RIGHT TO CONSENT TO ACCELERAT[ON OF THE BONDS, AND THE 42 �,x�az i.a INSURER'S RIGHT TO CONSENT TO OR DiRECT CERTAIN D1STRiCT, TRUSTEE OR BONDnWNER ACTIONS. Section 8.1. Events of Default. Any one o►•more of the Collowing events shall constitute an "event ol�default": (a) default in the due and punctual paymcnt of the principal of or redemption premium, if any, on any Bond or Parity Bond when and as thc same shall become duc and payable, whether at inaturity as thercin expressed, by declaration or otherwise; (b) delault in the due and punctual paymcnt of the interest on any Bond or Parity Bond when and as the same shall become due and payable; or (c) except as described in (a)or(b), dcfault shall be tnade by the District in the obscrvance of any of thc agreements, conditions or covcnants on its part contained in this Indenture, the Bonds or any Parity Bonds, and such default shall have continued for a period of thirty(30) days after the District shall have been given notice in writing of such default by the Trustee or the Owners of twenty-five percent (25%), in aggregate principal amount of the Outstanding Bonds and Parity Bonds. The Trustec agrees to give notice to the Owners as soon as practicable upon thc occurrencc of an Evcnt of Default under(a) or(b) above and within thirty(30) days of the Trustce's knowledge of an cvent of default under(c) above. Section 8.2. Remedies of Owners. Upon the occurrence of an Eveni of Defaull, the Trustee may pursue any available remedy at law or in equity to enforce the payment of the principal c�f, premium, if any, and interest on the Outstanding Bonds and Parity Bonds, and to enforce any rights of the Trustee under or with respect to this Indenture, including: (a) By mandamus or other suil or proceeding at law or in equity to enforce his rights against the District and any of the members, officers and employees of the District, and to compel the District or any such members, officers or employees to perform and carry out thcir duties under the Act and their agreements with the Owners as provided in this Indenture; (b) By suit in equity to enjoin any actions or things which are unlawful or violate thc rights of the Owners; or (c) By a suit in equity to require the District and its mccnbers, officers and employees to account as the trustee of an express trust. If an Event of Default shall have occurred and be continuing and if requested so to do by the Owners of at least twcnty-five percent (25%) in aggregate principal arnount of Outstanding Bonds and Parity Bonds and if indemnified to its satisfaction, the Trustec shall be obligated to exercise such one or more of the ri�hts and powers confcrred by this Article 8, as thc Trustee, being advised by counscl, shall deem most expedient in the interests oC thc Owners of the Bonds and Parity Bonds. No rcmedy herein conferred upon or reserved to the Trustec or to thc Owners is intended to bc exclusive of any othcr remedy. Every such remedy shall be cumulative and shall bc in addition to 43 ��K�azi a every other remedy given hereunder or now or hercafter existin�, at law or in equity c�r by statute or c�therwise, and may be exercised witl�out exhausting and without regard tc� any other remedy conferrcd by tl�e Act or any other law. Section 8.3. Application of Revenues and Othcr Funds Aftcr Default. All a►nounts receivcd by thc Trustec pursuant to any right given or action taken by the Trustee under the provisions of this Indenture relating to the Bonds and Parity Bonds shall bc applied by the Trustee in the following order upon presentation of the several Bonds and Parity Bonds: First, to the payment of the fecs, costs and cxpenses ol�thc Trustee in declaring such Evcnt of Dcfault and in carrying out the provisions of this Article 8, including reasonable compensation to its agents, attorneys and counscl, and to the payment of all other outstanding fees and expenses of the Trustee; and Sccond, to the payment of the whole amount of interest on and principal of the Bonds and Pai•ity Bonds then due and unpaid, with intcrest on overdue installmcnts of principal and interest to the extent permitted by law at the net effective rate ot'interest then bornc by the Outstanding Bonds and Parity Bonds; provided, however, that in the event such amounts shall bc insufficicnt to pay in full the full atnount of such interest and principal, thcn such amounts shall be applied in the following order of priority: (a) (irst to the payment of all installments of intcrest on the Bonds and Parity Bcmds then due and unpaid on a pro rata basis based on the total amount thcn due and owing, (b) second, to the payment of all installments of principal, including Sinking Fund Payments, of the Bonds and Parity Bonds then due and unpaid on a pro rata basis based on the total amount then due and owing, and (c) third, to the payment of interest on overdue installments of principal and interest on the Bonds and Parity Bonds on a pro rata basis based on the total amount then due and owing. Section 8.4. Power of Trustee to Control Proceedings. In the event that the Trustee, upon the happening of an Event of Default, shall have taken any action, by judicial procecdings or otherwise, pursuant to its duties hercunder, whcther upon its own discretion or upon the reyuest of� the Owners of twenty-five percent (25%) in aggrebate principal amount of the Bonds and Parity Bonds then Outstanding, it shall have full power, in the exercise of its discrction for thc best interests of the Owners of the Bonds and Parity Bonds, with respect to the continuance, discontinuance, withdrawal, compromise, scttlement or other disposal of such action; provided, however, that the Trustee shall not, unless there no longer continues an Event of Dcfault, discontinue, withdraw, compromise or scttle, or otherwise dispose of any litigation pending at law or in equity, if at the timc there has been filcd with it a written rcquest signed by the Owners oi�a majority in aggregate principal amount of the Outstanding Bonds and Parity Bonds hereunder opposing such discontinuance, withdrawal, compromise, settlement or other such litigation. Any suit, action or proceeding which any Owner of Bonds or Parity Bonds shall have the right to bring to enforce any right or remedy hereunder may be brought by the Trustee for the equal benetit and protection of all Owners ot�Bonds and Parity Bonds similarly situated and the Trustee is hereby appointed (and the successive respective Owners of the Bonds and Parity Bonds issued hereunder, by taking and holding the same, shall be conclusively deemed so to have appointed it) the true and lawful attorncy in f'act �f 44 �,s�azi a the respective Owners of the Bonds and Parity Bonds tor the ��uiposes of bringin� any such suit, action or procecding and to do and perfoi•m any and all acts and things for and on behalf�f�thc respective Owners oi'the Bonds and Parity Bonds as a class or classes, as may be necessary�r advisable in the opinion ol�thc Trustec as such attc�rncy-in-fact. Section 8.5. Appointment of Receivers. Upon the c�ccu�z-ence of an Event oC Default hereunder, and upon the liling oi�a suit or other coin►ncncement of judicial proccedings to enforce thc rights of the Trustee and of�the Owners of the Bonds and Parity Bonds under this Indenture, thc Trustee shall be entitled, as a matter of right, to the appointment of a receiver or receivers of the Net Taxes and othcr amounts pledgcd hereunder, pending such proceedings, with such powers as the court making such appointment(s) shall confer. Scction 8.6. Non-Waiver. Nothing in this Arlicic 8 or in any other provision of this Indenturc,or in thc Bonds or the Parity Bonds, shall affect or impair the obligation of the District, which is absolute and unconditional, to pay the interest on and principal of the Bonds and Parity Bonds to thc respective Owners of the Bonds and Parity Bonds at the respcctive dates of'maturity, as hcrein pi•ovided, out of the Net Taxes and other moneys herein plcdged for such payment. A waiver of any default or breach of duty or contract by the Trustee or any()wners shall not affect any subsequent default or breach of duty or contract, or impair any rights or remedies on any such subsequent default or breach. No dclay or omission of the Trustee or any Owner of any of the Bonds or Parity Bonds to exercisc any right or power accruing upon any default shall impair any such right or power or shall be construed to be a waiver of any such default or an acquiescence thcrein; and every power and remedy confcrred upon the Trustee or the Owners by the Act or by this Article 8 may be enforced and exercised from time to time and as often as shall be deemed expedient by the Trustec or the Owners, as the casc may be. Scction 8.7. Limitations on Rights and Rcmedies of Owners. No Owner of any Bond or Parity Bond issued hcreunder shall have the right to institute any suit, action or proceeding at law or in eyuity, for any remedy under or upon this Indcnture, unless(a) such Owner shall havc previously given to the Trustee written notice of the occui-rence of an Event of'Default; (b) the Owners of a majority in aggrcgate principal amount of all thc Bonds and Parity Bonds then Outstanding shall have made writtcn request upon the Trustee to exercisc the powers hereinbefore granted or to institute such action, suit or procecding in its own name; (c) said Owners shall have tendered to the Truslee indcinnity reasonably acccplable to the Trustee against the costs, expenses and liabilities to be incurred in compliance with such request; and (d) the Trustee shall have refused or omitted to comply with such reyuest for a period of�sixty(60) days after such wr•itten request shall have been received by, and said tender of indemnity shall have becn made to, the Trustec. Such notification, i•equest, tcnder of indemnity and refusal or omission are hereby declared, in every case, to be conditions pi•ecedent to the exercise by any Owner of Bonds and Parity Bonds of any remedy hereunder; it being understood and intendcd that no one or more Owners of Bonds and Parity Bonds shall have any r•ight in any manner whatever by his or their action to enforce any right undcr this Indenture, except in the manner herein provided, and that all proceedings at law or in equity to enfoi•ce any provision of this Indenture shall be instituted, had and maintained in the manner herein provided and for the equal benefit ol�all Owners of thc Outstanding Bonds and Parity Bonds. 45 9s�a2t a The i-ight of any Owner of any Bond and Parity Bond to receive payment of�the principal ot� and interest and prcmium (if�any) on such Bond and Parity Bond as hcrcin provided or to institute suit tor the enforcement oi�any such payment, shall not be impaired or affected without the written consent oCsuch Ownec•, notwithstanding the foregoing pr�visi�ns ol'this Section or any other provision of�this Indenture. Section 8.8. Termination of Proceedings. In case the Trustee shall have proceeded to cnforce any right under this [ndenture by the appointment of a receiver or otherwise, and such proceedings shall have bcen discontinued or abandoned for any reason, or shall have bcen detcrmined adversely, then and in every such case, thc District, the Trustee and the Owners shall bc restored to their Corrr►er positions and rights hereunder, respectively, with regard to the property subject to this Indenture, and all rights, remedies and powers of the Trustec shall continue as if no such proceedings had been taken. ARTICLE IX BONDINSURANCE �to comeJ ARTICLE X DEFEASANCE AND PARITY BONDS Section 10.1. Defeasance. If the District shall pay or cause to be paid, or there shall otherwise be paid, to the Owner of an Outstanding Bond or Parity Bond the interest due thereon and the principal thereof, at the times and in the manner stipulated in this Indenture or any Supplemental Indenture, then the Owner of such Bond or Parity Bond shall cease to be entitled to the pledge of Net Taxes, and, other than as set forth below, all covcnants, agreements and other obligations of the District to the Owner of such Bond or Parity Bond under this Indenture and any Supplemental Indenture relating to such Parity Bond shall thereupon cease, terminate and becc�me void and be discharged and satisfied. In thc event of a defeasance of all Outstanding Bonds and Parity Bonds pursuant to this Section, the Trustee shall execute and deliver to the District all such instruments as may be desirahle to evidence such discharge and satisfaction, and the Truslee shall pay over or deliver to the District's general fund all money or securities hcld by it pursuant to this Indenture which are not required for the paymcnt of the principal of; premium, if any, and interest due on such Bonds and Parity Bonds. Any Outstanding Bond or Parity Bond shall be decmed to have been paid within the mcaning expressed in the first paragraph of this Section if such Bond or Parity Bond is paid in any one or morc of the following ways: (a) by paying or causing to be paid the principal of, premium, if any, and interest on such Bond or Parity Bond, as and when the same become due and payable; (b) by depositing with the Trustec, in trust, at or bcfore maturity, money which, together with the amounts then on deposit in the Special Tax Fund (exclusive �f the Administrative Expenses Account) and available for such purpose, is fully sufficient to pay 46 987421�3 thc principal of, prcmium, ifany, and interest on such Bond or Parity Bond, as and whcn thc samc shall bcc�me duc and payablc; c►r (c) by depositing with the Trustec or another escrow bank appointcd by the Disti-ict, in trust, Federal Sccurities, in which the District may lawfully invest its moncy, in such amount as will bc sufficient, together with the interest t� accrue thereon and moneys then on deposit in the Special Tax Fund (exclusive of�the Administrative Expcnses Account) and available tor such purpose, together with the interest tc� accrue thereon, to pay and discharge the principal of, premium, if any, and interest on such Bond or•Parity Bond, as and when thc same shall become due and payable. Ifpaid as provided above, then, at the election of the District, and notwithstanding that any Outstanding Bonds and Parity Bonds shall not havc been surrendered for payment, all obligations of the District under this Indentuce and any Supplcmenta4 (ndenture with respect to such Bond or Parity Bond shall cease and tenninate, except for the obligation of the Trustee to pay or cause to be paid to the Owners of any such Bond or Parity Bond not so surrendered and paid, all sums due thereon and except for the covenants of the District contained in Scction 5.2(e) or any covcnants in a Supplcmental Indenturc relating to compliance with the Code. Notice of such election shall be filed with the Trustee not lcss than ten (]0) days pi•ior to the proposed defeasancc date, or such shorter period of time as may bc acceptable to the Trustec. In connection with a defeasance under(b) or(c) above, there shall be provided to thc District a verification report from an independent nationally recognized certified public accountant stating its opinion as to the sufficicncy of the moneys or securities deposited with the Trustee or thc cscrow bank to pay and discharge the principal of, premium, if any, and interest on all Outstanding Bonds and Parity Bonds to be defeased in accordance with this Scction, as and when the same shall bccome due and payable, and an opinion of Bond Counsel (which may rely upon the opinion of the certified public accountant) to the effect that thc Bonds or Parity Bonds being defeased have been Icgally defeascd in accordance with this Indenture and any applicable Supplcmcntal Indenturc. Upon a defeasance, thc Trustee, upon request of the District, shall rclease the rights of the Owners of such Bonds and Parity Bonds which have been de(eased under this Indenture and any Supplemental Indenture and cxecute and deliver to the District all such instruments as may be desirable to evidence such release, discharge and satisfaction. In the case of�a defeasance hereunder of all Outstanding Bonds and Parity Bonds, the Trustec shall pay over or deliver to the District any funds held by the Trustee at tt�e tisne af a deteasance,which are no1 required for 1he purpose of paying and discharging the principal of'or interest on the Bonds and Parity Bonds when due. The Trustee shall, at the written dircction of the District, mail, first class, postagc prepaid, a noticc to the Bondowners whose Bonds or Parity Bonds havc been defeased, in thc form directed by the District, stating that the defeasance has occurred. 47 yR 732 I.4 Scction 10.2. Conditions for the Issuancc of Parity Bonds and Other Additional lndcbtedness. Thc District may at any timc after the issuance and dclivery of thc Bonds hercunder issuc Parity Bonds payable fmm thc Net Taxes and other am�unts deposited in thc Special Tax Fund (other than in the Administrative Expenses Account therein) and secured by a lien and charge upon such amounts equal to the lien and charge securing the Outstanding Bonds and any other Parity Bonds theretofore issued hercunder or undei-any Supplemental Indenture; providcd, howcver, Parity Bonds ►nay only be issued for the purpose of refunding all or a por-tion of the Bonds or any Parity Bonds then ()utstanding. Parity Bonds issued are subject to the following specilic conditions, which are hereby made conditions precedent to the issuance c�f any such Parity Bonds: (a) The District shall be in compliancc with all covcnants set forth in this Indentui-e and any Supplc►nental Indenture then in effcct and a certificate of the District to that effect shall have been filcd with thc T�ustee; provided, however, that Parity Bonds may be issued notwithstanding that the District is noi in compliance with all such covenants so long as immediately following the issuance of such Parity Bonds the District will be in compliance with all such covenants. (b) The issuance of such Parity Bonds shall have been duly authorized pursuant to thc Act and all applicablc laws, and thc issuance of such Parity Bonds shall have been provided f'or by a Supplemental Indenture duly adopted by the District which shall specify the following: (1) the purpose for which such Parity Bonds are to bc issued and the fund or funds into which the proceeds thereof are to be deposited, including a provision requiring the proceeds of such Parity Bonds to be applied solcly f'or the purpose of refunding any Outstanding Bonds or Parity Bonds, including payment of all costs and the funding of all rescrves incidcntal to or connccted with such refunding; (2) thc authorized principal amount of such Parity Bonds; (3) the date and the maturity date or dates of such Parity Bonds; providcd that (i) each maturity date shall fall on an October 1, (ii) all such Parity Bonds of like maturity shall be identical in all respects, except as to number, and(iii) fixed serial maturities or Sinking Fund Payments, or any combination thereof, shall bc established to provide for the retircment of all such Parity Bonds on or before their respective maturity dates; (4) the description of the Parity Bonds, the placc of payment thereof and the procedure for execution and authentication; (5) thc denominations and mcthod of numbcring of such Parity Bonds; (6) thc amount and due date of each ►nandatory Sinking Fund Payment, if any, for such Parity Bonds; (7) the amount, if any, to be deposited fi�om the proceeds of such Parity Bonds in thc Reserve Account of the Special Tax Fund to increase the amount therein to the Reserve Requirement; (8) the form of such Parity Bonds; and 48 ��R�azi.a (9) such other provisions as are necessary �r appropriate and not inconsistent with this [ndenture. (c) 7�he District shall have received the tollowing documents or money or securitics, all of such documcnts dated or cer-tified, as the casc may be, as ot�the date ol�delivery ofsuch Parity Bonds by the Trustee (unless the Trustee shall accept any of�such documents bcaring a prior date): (1) a certificd copy of the Supplemental Indenture authorizing the issuance of such Parity Bonds; (2) a written request of the District as to the delivcry of such Parity Bonds; (3) an opinion c�f Bond Counsel and/or general counsel to the District to the effect that (a) the District has the right and power under the Act to adopt this Indenture and the Supplemental [ndentures relating to such Parity Bonds, and this Indenture and all such Supplemental Indcntures have been duly and lawlully adopted by the District, are in full forcc and efiect and arc valid and binding upon the District and enforceable in accordancc with their teims (except as enforcement may be limited by bankruptcy, insolvency, reorganization and other similar laws relating to thc enforcement of�ci•editors' rights); (b) this Indenture crcatcs the valid pledge which it purports to create of the Nct Taxes and other amounts as provided in this lndenture, subject to the application thereof to the purposes and on the conditions permitted by this Indenture; and (c) such Parity Bonds are valid and binding limited obligations of the District, cnforceablc in accordance with their terms (except as cnforcement may bc limited by bankruptcy, insolvency, reorganization and other similar laws relatin�to the enforcement of'creditors' ribhts) and the terms of this Indenture and all Supplemental Indentures thereto and entitled to the benefits of this Indenturc and all such Supplemental Indentures, and such Parity Bonds have been duly and validly authorized and issued in accordance with thc Act (or other applicable laws) and this Indenture and all such Supplcmental Indentures; and a further opinion of Bond Counsel to thc effect that, assuming compliance by the District with certain tax covenants, thc issuance of the Parity Bonds will not adversely affect the exclusion from gross income for federal income tax purposes of interest on thc Bonds and any Parity Bonds theretof'ore issued on a tax-exempt basis, or the exemption from State of California personal income taxation of intcrest on any Outstanding Bonds and Parity Bcmds theretofore issued; (4) a certificate of the District containing such statements as may be reasonably necessa►y to show compliance with the rcquirements of'this Indcnture; (5) a certificate of an Independent Financial Consultant certifying that in each Bond Year the Annual Debt Service on the Bonds and Parity Bonds to remain Outstanding following the issuancc of the Parity Bonds proposcd to be issucd is less than thc Annual Debt Scrvice on thc Bonds and Parity Bonds Outstanding prior to the issuance of such Parity Bonds; and (6) such further documents, money and securities as are required by the provisions of�this Indenture and the Supplemental Indenture providing for the issuance of such Parity Bonds. 49 9R 742 I.4 ARTICLE XI MISCEI.LANEOUS Section 1 1.1. Cancellation of Bonds and Parity Bonds. All Bonds and Parity Bonds surrcndered to the Trustee tor payment upon maturity or for redemption shall be upon payment therefor, and any Bond or Parity Bond purchaseci hy the District as authori�ed hercin and delivcred to the Trustee for such purpose shall be, cancelled forthwith and shall not be reissued. The Trustee shall destroy such Bonds and Parity Bonds, as provided by law, and, upon request of the District, furnish to the District a certificate of such destruction. Section 1 1.2. Execution of Documents and Proof of Ownership. Any request, direction, consent, revocation of consent, or other instrument in writing required or pennitted by this Indenture to be signed or executed by Bondowners may be in any numbcr of concurrent instruments of�similar tenor may be signed or executed by such ()wners in per•son or by their attorneys appointed by an instrument in writing for that purpose, or by the bank, trust company or othcr depository for such Bonds. Proof of the execution of any such instrument, or of any instrument appointing any such attorney, and ofthe owncrship of Bonds or Parity Bonds shall be sufficient for the purposes of this Indenture (except as otherwise herein provided), if made in the following cnanner: (a) The fact and date of the execution by any Owner or his or her attorney of any such instrument and oI�any instrument appointing any such attorncy, ►nay be proved by a signature guarantee of any bank or trust cornpany located within the Unitcd States of America. Where any such instiument is executed by an ofticer of a corporation or association or a member of a partnership on behalf of such corporation, association or partnership, such signature guarantee shall also constitute sufticient proof of his authority. (b) As to any Bond or Parity Bond, the person in whose natne the same shall bc registered in thc Bond Register shall bc deemed and regarded as the absolutc owner thereof for all purposes, and payment of or on account of'the principal of any such Bond or Parity Bond, and the interest thereon, shall be made only to or upon the ordcr of the registered Owner thereof or his or her legal representative. All such payments shall be valid and effectual to satisfy and discharge the liability upon such Bond or Parity Bond and the interest thereon to the extcnt of the sum or sums to be paid. Neither the District nor the Trustee shall be affectcd by any notice to the contrary. Nothing contained in this Indenture shall bc construcd as limiting the Trustee or thc District to such proof; it being intcnded that the Trustee or the District may accept any other evidence of thc mattcrs herein stated which the Trustee or the District may deem sufficicnt. Any request or consent of thc nwner of�any Bond or Parity Bond shall bind every future Owner of the same Bond or Parity Bond in respect of anything done or suf'fcred to be done by the Trustec or the District in pursuance of such request or-consent. Section 11.3. Unclaimed Moneys. Anything in this Indenture to the contrary notwithstanding, any money held by the Trustee in trust for the payment and dischargc of any of the Outstanding Bonds and Parity Bonds which remain unclaimcd for two (2) years afrer the date when such Outstanding Bonds or Parity Bonds have become due and payablc, if such moncy was held by thc Trustee at such date, or Ior two (2) years after the date of deposit of such money if deposited with the Trustee after the date when such Outstanding Bonds or Parity Bonds become duc and payable, shall be rcpaid by the Trustec to the District, as its absolute pr�perty and free from trust, and the 50 987J2I 4 Trustee shall thereupon be relea�ed and discharged with respect theret<� and the Owners shall look only to thc District for the paymcnt of such Outstanding Bonds�r Parity Bonds; provided, however, that, betore being reyuired to makc any such payment to thc District, thc Trustee, at the expense of' the District, shall cause to be ►nailed by tirst-class mail, postage prepaid, to the registered Owners oi' such Outstanding Bonds or Parity Bonds at their addresses as they appear on thc rcgistration books of the Trustee a notice that said money remains unclaimed and that, after a date named in said notice, which datc shall not be less than thirty(30) days after the date of the mailing of such notice, the balance ol�such money then unclaimed will be returned to the District. Section 1 1.4. Provisions Constitute Contract. The provisions of this Indenture shall constitute a coniract between the District and the Bondowncrs, and the provisions hcrcof shall bc construed in accordance with thc laws of thc Statc of Calif'ornia. In case any suit, action or proceeding to enforce any right or exercise any remedy shall be brought or taken and, shc�uld said suit, action or proceeding be abandoned, or be determined adversely to thc Bondowncrs or thc Trustee, thcn thc District, the Trustee and the Bondowners shall be restorcd to their former positions, rights and remedies as iI�such suit, action or proceeding had not been brought or taken. After the issuancc and delivery of the Bonds this lndenture shall be irrepealable, but shall be subjcct to modifications to the extent and in thc manner provided in this Indenture, but to no greater extent and in no other manner. Section 1 1.5. Future Contracts. Nothing herein contained shall be deemed to restrict or prohibit the District from making contracts or creating bondcd or other indebtedness payable froin a pledge of the Net Taxes which is subordinate to the pledge hereunder, or which is payable fro►n the general fund of thc District or from taxes or any source other than the Net Taxes and other amounts pledged hcrcunder. Section 1 1.6. Further Assurances. The District 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 Indenture, and for the better assuring and confirming unto the Owners of the Bonds or any Parity Bonds thc rights and benefits providcd in this Indenturc. Section 1 1.7. Severability. If any covenant, agreement or provision, or any portion thercof; contained in this Indenture, or the application thereof to any person or circumstance, is held to be unconstitutional, invalid or unenforceable, the remainder of this Indenturc and the application of any such covenant, agreement or provision, or portion thereof, to other persons or circumstances, shall be decmcd severable and shall not be affected thcreby, and this Indenture, the Bonds and any Parity Bonds issued pursuant hereto shall remain valid and the Bondowners shall rctain all valid rights and bcnefits accorded to them under the laws of�the State of California. Section 1 1.8. Notiees. Any notices required to be given to the District with respect to the Bonds o►•this Indenture shall be ►nailed, first class, postage prepaid, or personally delivered to the Finance Director-Treasurer of the City of Palm Desert, 73-510 Fred Waring Drive, Palm Descrt, California 92260, and all notices to the Trustec in its capacity as Trustee shall be mailed, first class, postage pr-epaid, or personally delivered to the Trustee, Wells Fargo Bank, National Association, 707 Wilshire Blvd., l7`h Floor, Los Angeles, California 90071, Attention: Robert Schneider. 51 9R742I.4 (Remainder of Pagc lntentionally Lcft Blank) 52 9�742 I.4 IN WITNESS WHEREOF, CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN R[DGE PUBLIC IMPROVEMENTS) has caused this I3ond lndenturc to be signed by the Mayor of the City of Palm Descrt, acting as the Icgislative hody of the District and attested thereto by the City Clerk of the City of Palm Desert, and Wells Farg� Bank, National Association, in token of its acceptance of the trust created hcreunder, has caused this Bond Indenture to be signed in its corporate namc by its of7iccr identified below, all as of�thc day and year first above written. C1TY OF PALM DESERT COMMUNITY FACILITIES DISTRICTNO. 91-1 (INDIAN R[DGE PUBLIC IMPROVEMENTS) By: Mayor of the City of Pal►n Desert, California ATTEST: City Clerk of the City of Palm Desert, California WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustec By: Its: Authorized Officer 53 ��x�a21 a EXHIBIT A FORM OF SPECIAL TAX REFUNDING BOND, SERIES 2008 Unless this Rond is presented by an authorized representative of The Uepository Trust Company, a New York corporation("DTC"), to thc nistrict or thc Trustcc for registration of transfcr, cxchange, or payment, ai�d any I3ond issued is registered in the riarne of Cede& Co. or in such other name as is requested by an authorized representative of ll'I�C (and any payment is made to Cede& Co. or to such other entity as is rec�uested by an authorizcd representative of�DTC), ANY 7�RANSI�ER, PLLDGL, OK UTHFR USL H�:RLOF FOR VALU�:OK O'rHLRWIS� BY ()R TO nNY P�:RSON IS WRONGI-�UL inasmuch as the registcred owner hereof, Cede& Co., has an interest herein. R- � UNITED STATES OF AMERICA STATE OF CALIFORNIA COUNTY OF RIVERSIDE CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) SPECIAL TAX REFUNDING BOND, SERIES 2008 INTEREST RATE MATURITY DATE DATED DATE CUSIP % October 1, January [15], 2008 REGISTERED OWNER: CEDE 8r. CO. PRINCIPAL AMOUNT: DOLLARS CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) (the"District") which was formed by the City of Palm Desert (the "City") and is situated in the County of Riverside, State of Calif'ornia, FnR VALUE RECEIVED, hereby promises to pay, solely from certain amounts held under the Indcnturc (as hereinafrer 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 sct forth above, and to pay interest on such Principal Amount from the Interest Payment Date (as hereinafter detined) next preceding the date of�authentication hereof, unless (i) the date oi� authentication is an Interest Payment Date in which event interest shall be payable from such date of authentication, (ii) the date of authentication is after a Record Date (as hereinafter defined) but prior to the immediately succeeding Interest Payment Date, in which event interest shall be payablc from the Interest Payment Date i►nmediately succccding the date of�authentication, or(iii) thc date of A-1 authentication is prior to thc closc of�business on the tirst Record Datc in whicll event interest shall be payable ii•om the Dated Date set lorth abovc. Nc�twithstanding the foregoing, if at thc timc of authcntication ot�this Bond intcrest is in default, interest on this Bond shall be payable from the lasl Intcrest Payment Date to which the interest has been paid or made available for payment or, if�no interest has been paid or madc availablc for payment, intcc-cst on this Bond shall bc payable from the Dated Date set forth above. Interest will be paid semiannually on April 1 and October I (each, an "Interest Paymcnt Date"), commencing October 1, 2008, at the Interest Rate set forth above, until the Principal Amount hereof is paid or made available Cor paymcnt. Thc principal ol�and premium, il�any, on this Bond ai•e payable to thc Rcgistcrcd Owner her-cof in lawiul money of the Unitcd States of America upon presentation and surrender of this Bond at the Principal Office oi�the Trustee (as such term is dcfined in the Bond Indenture), initially Wells Fargo Bank, National Association (the"Trustee"). Interest on this Bond shall be paid by check of the Trustee mailed by first class ►nail, postage prepaid, or in ccrtain circumstances described in the Indenture by wire transfer to an account within the Unitcd States of America, to the Rcgistered nwner hereof as of thc closc ofbusiness on the fifteenth 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 appcars on the registration books maintaincd by the Trustee. This Bond is one of a duly authori�ed issue of"City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding Bonds, Series 2008" (the "Bonds") issucd in the aggregate principal amount of$[10,720,000] pursuant to the Mello-Roos Community Facilities Act of 1982, as amended, being Scctions 53311, et.sc�y., of the California Governmcnt Code (the "Act") for the purpose of financing cerlain public facilitics, funding a reserve account, and paying certain costs related to the issuance of the Bonds. The issuance of the Bonds and the tenns and conditions thereof are provided for by a resolution adopted by the City Council of thc City acting in its capacity as the legislative body of thc District (the"Lcgislative Body") on [Deccmber 13, 2007] and a Bond lndenturc dated as oCJanuary 1, 2008, by and betwccn thc District and the Trustec executed in connection therewith (the"Indenture"), and this reference incc�rporates the Indcnture herein, and by acceptance hereof the Registcred Owner of this Bond assents to said terms and conditions. Thc Indenture is executed under and this Bond is issued under, and both are to be construed in accordance with, the laws of the State ofCalitornia. Pursuant to thc Act and the Indenture, the principal of, premium, if any, and interest on this Bond are payable solely from the portion of the annual special taxes authorized under the Act to be levied and cc�llected within the District (thc"Special Taxes") and ceriain othcr amounts pledged to the repayment of the Bonds as set forth in thc Indenture. Any amounts for the payment hereof shall be limited to the Special Taxes pledged and collected or foreclosure proceeds received following a default in payment of the Special Taxes and othec•amounts deposited to the Special Tax Fund (other than the Administr•ative Expenses Account therein) established under the Indenture, except to the cxtent that other provision f�r payment has been madc by the Legislative Body, as may be permittcd by law. The District has covenanted f'or the benefit of the owners of the Bonds that under certain circumstanccs described in the Indenturc it will conunence and diligcntly pursue to completion foreclosure actions in the event of delinquencies of Special Tax installments levied f'or payment of principal and interest on thc Bonds. Thc Bonds maturing on or before October 1, 20_ are not subject to call and redcmption prior to maturity. The Bonds maturing on or after October 1, 20 shall be subject to call and redemption prior to maturity and may be redeemed, at the option of the District, from any source of funds on any Intcrest Payment Date in whole, or in part, from such matui•ities as are selected by the n-2 District and by lot within a maturity, at thc following rcdemption prices expresscd as a percentage oC the; principal amount tc� be redeemed, together with accrued intci-est to the date of redempti�n: Redemption Dates Redemption Prices October 1, 20_ and April 1, 20 % October 1, 20_and April 1, 20_ ()ctc�ber 1, 20 and Interest Payment Dates thereafter Thc Bonds maturing on October I, 20_ and Octobcr 1, 20_(the "Term Bonds") shall bc called before maturity and redeemed, from Sinking Fund Payments deposited into thc Rcdcmption Account, on October I, 20 and October 1, 20 , respectively, and on each October 1 thereafter prior to maturity, in accordance with the schedule of Sinking Fund Payments set forth in the Bond Indcnture at a redemption price equal to the principal amount thereof, plus accrued interest to the rcde►nption date, without prcmium. Thc Bonds are subject to extraordinary redemption as a whole, or in part on a pro rata basis a►nong maturitics, on any [nterest Payment Date, and shall be redeemed by the Trustec, from Prepayinents ot�Special Taxes dcpositcd to the Rede►nption Account, plus amounts transterred trom the Reservc Account in connection with such transfers, at the following rcdcmption prices expressed as a percentage of the principal amount to be redeemed, together with accrued intcrest to thc redemption date: Redemption Dates Redemption Prices October 1, 20_ and April 1, 20_ % October 1, 20_ and April 1, 20_ Octobcr 1, 20_ and April 1, 20_ _ October 1, 20 and Intcrest Payinent Dates thereatter Notice of redemption with respect to the Bonds to be redccmed shall be mailed to the registered owners thereof not less than thirty(30) nor more than forty-five (45) days prior to the redemption date by Grst class mail, postage prepaid, to the addresses set forth in the registration books. Neither a failurc of the Registered Owner hercof to receivc such notice nor any defect therein will afCect the validity of the proceedings for redemption. All Bonds or ponions thereof so called for redemption will cease to accrue interest on the specified redemption date, provided that funds for thc redemption are on deposit with the Trustec on the redemption date. Thereaftcr, the registered owners of such Bonds shall have no rights except to receive payment of the redemption price up�n the surrendcr of the Bonds. This Bond shall be registcrcd in thc name of the Rcgistered Ownen c�reoi; as to both principal and interest, and the District and the Trustee may treat the Registered Owner hereof as the absolute owner i'or all purposes and shall not be affected by any notice to the contrary. The Bonds are issuable only in fully registered form in the denomination of$5,000 or any integral multiple thereof and may be exchanged for a like aggregate principal amount of Bonds of other authori�ed denominations of the same issue and maturity, all as more fully set forth in the Indenture. This Bond is transferable by the Rebistered Owner hereof, in person or by his attorney duly authorized in writing, at the Principal Office of thc Trustee, but only in the manner, subject to A-3 the limitations and upon payment of the char�;es nrc�vided in thc Indenturc, upon surrender and cancellation of this Bond. Upero such transfer, a ncw rcgistered Bond of authorized denomination or denominatic�ns for the saine aggregate principal amount of�the same issue and matui-ity will be issuecl tc� thc U•ansferec in cxchange therefor. The Trustee shall not be required to registcr transfers or make exchangcs of(i) any Bonds lor a period of tifteen (15) days next prcccding any selection of the Bonds to be redeemed, or(ii) any Bonds chosen for redemption. Thc rights and obligations of the District and of the registered owners of the Bonds may be amended at any ticne, and in certain cases without notice to or thc consent of the registcrcd owncrs, to the cxtcnt and upon the tenns providcd in thc Indcnture. THE BONDS DO NOT CONSTITUTE OBLIGATIONS OF THE CITY OF PALM DESERT nR OF THE DISTRICT FOR WHICH THE CITY OF PALM DESERT OR THE DISTRICT [S OBLIGATED TO LEVY OR PLEDGE, OR HAS LEVIED OR PLEDGED, GENERAL OR SPECIAL TAXES, OTHER THAN THE SPECIAL TAXES REFERENCED HEREIN. THE BONDS ARE LIMITED nBLIGATIONS nF THE DISTRICT PAYABLE FROM THE PORTION OF THE SPECIAL TAXES AND nTHER AMOUNTS PLEDGED UNDER THE INDENTURE BUT ARE NOT A DEBT OF THE CITY OF PALM DESERT, THE STATE OF CALIFORNIA OR ANY OF ITS POLITICAL SUBDIVISIONS WITHIN THE MEANING OF ANY CONSTITUTIONAL OR STATUTORY LIMITATION OR RESTRICT[ON. This Bond shall not become valid or obligatory for any purpose until the certiticate of authcntication and registration hereon endorsed shall have been dated and signed by the Trustcc. 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 do exist, havc happened and have becn performed in duc time, fonn and manner as required by law, and that the amount of this Bond, together with all other indebtedness of the District, does not exceed any debt limit prescribed by the laws or Constitution of the State of California. A-4 IN WITNESS WHEREOF, City of Palm Dcsert Community Facilitics Uistrict No. 91-I (lndian Ridge Public lmpmvements) has caused this Bond to be dated as of.lanuary �15�, 2008, to be signed on bchall�ol'the District by thc Mayoi•of�the City by his manual signature and attestcd by thc manual signaturc �f the City Clerk of the C'ity. CITY OF PALM DESERT CnMMUNITY FACILITIES DISTRICT NO. 91-I (INDIAN RIDGE PUBLIC IMPROVEMENTS) Mayor of thc City ot'Palm Desert, California ATTEST: City Clcrk of the City of Palm Dcscrt, California STATEMENT OF INSURANCE [to come] ---------------------------------------------------------------- ------------------------------------------------------------------- A-5 [FnRM OF TRUSTEE'S CERTIFICATE nF AUTHENTICATION AND REGISTRATION] This is one of the Bcmds described in thc within-mcntioned Indentw•e which has been registered on the Bond registration books. Dated: WELLS FARGO BANK, NATIONAL ASSOCIAT[ON, as Trustee By: Its: Authoriied Signatory [FORM OF ASSIGNMENT] For value received the undersigned hereby scll(s), assign(s) and transfer(s) unto (Name, Address, and Tax Identification or Social Security Numbcr of Assignee) the within-mentioned Bond and hereby irrevocably constitute(s) and appoint(s) attorney, to transfcr the samc on the Registration Books of the Trustee with full power of substitution in the premiscs. Dated: Signature Guaranteed: Notc: Signature must be guarantccd by a Note: The signature(s) on this Assignment member of an institution which is a participant must correspond with the name(s) as in the Securities Transter Agent Medallion written on the facc of the within Bond in Program (STAMP) or other similar program. evety particular without alteration or enlargement or any change whatsoever. A-6 ESCROW AGREEMENT by and among PALM DESERT FINANCING AUTHOR[TY and CITY OF PALM DESERT and CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) and WELLS FARGO BANK, NATIONAL ASSOCIATION as Escrow Agent Dated as of January 1, 2008 Relating to thc Rcfunding of�the Palm Desert Financing Authority 1997 Rcvcnuc Bonds (Assessment District Nos. 92-1 [Ticrravista] and 94-1 [Bighorn] and Community Facilities District No. 91-1 [Indian Ridge]) scheduled to mature on October 1, 2008 and thereafter through October 1, 2020 9R7440.3 TABLE OF CONTENI'S Page Sectionl. Dcfinitions............................................................................................................... 2 Scction 2. Appointment of Escrow Agent ............................................................................... 3 Scction3. Escrow Fund ........................................................................................................... 3 Scction 4. Dcposits to Escrow Fund ........................................................................................ 3 Section 5. Investment of Escrow Fund.................................................................................... 4 Section 6. Reinvcstmcnt; Payment of Refunding Requirements............................................. 4 Section7. Verification............................................................................................................. 5 Section 8. Compliance with Agreement, Prior Fiscal Agent Agreement, and Prior Indenture 5 Scction9. Tax Covenants ........................................................................................................ 5 Section10. Notices .................................................................................................................... 6 Section 11. Defeasance of Prior Local Obligations and Prior Bonds........................................ 6 Section12. Nature of Lien......................................................................................................... 6 Section13. Amendments........................................................................................................... 6 Section 14. Cocnpensation of Escrow Agent ............................................................................. 7 Section 15. Resi�mation or Removal of Escrow Agent; Appointment of�Successor................. 7 Section 16. Limitation of Powers and Duties ............................................................................ 8 Scction17. Indcmnification....................................................................................................... 8 Section 18. Limitation of Liability............................................................................................. 9 Section 19. Termination........................................................................................................... 10 Section20. Governing Law ..................................................................................................... 10 Scction21. Severability........................................................................................................... 10 Section 22. Counterparts.......................................................................................................... 10 9R7440.3 -i- SCHEDULE A REFUNDING REQUIREMENTS SCHEDULE B ESCROW SECURITIES EXHIBIT A FORM OF DEFEASANCE NOTICE 9R7440.3 -ii- ESCROW ACREEMENT This Escrow Agreement (this "Agr�ement") is made and entered into as of January 1, 2008, by and among the Palm Desert Financing Authority, a joint powers authority duly organized and existing pursuant to the laws of thc State of�California (the "Authority"), the City of Palm Desert, a municipal corporation (the "City"), the City of Palm Desert Community Facilities District No. 91-I (Indian Ridge Public Improvements), a community facilities district established under the Mello-Roos Community Facilities Act of 1982 ("District"), and Wells Fargo Bank, National Association, a national banking association duly organi�ed ai�d cxisting under thc laws of the United States of America, as Escrc�w Agent (together with ac�y successors and assigns, the "Escrow Agcnt"). RECITALS A. Thc Authority has prcviously issued its 1997 Revenue Bonds (Asscssmcnt District Nos. 92-1 [Tierravista] and 94-1 [Bighorn] and Community Facilitics District No. 91-1 [Indian Ridge]) (the "1997 Bonds"), pursuant to thc Indenture of Trust, dated as of November 1, 1997 (the "Prior Indcnture"), by and between the Authority and First Trust of California, National Association, as succeeded by Wells Fargo Bank, National Association, as trustee (the "Prior Bonds Trustec"). B. Pursuant to the Prior Indenture, the 1997 Bonds maturing on October 1, 2008 and thereafter through October 1, 2020 (the "Prior Bonds") are subject to mandatory redemption on any interest paymcnt datc from moneys receivcd by the Authority as the redemption prices for such of the District's Limited Obligation Refunding Bonds (Property Secured Only — No Issuer Liability), Series 1997 (the "Prior Local Obligations") as may be redeemed pursuant to the Fiscal Agent Agreement, dated as of November 1, 1997 (the "Prior Fiscal Agent Agreement"), by and bctwecn the City and the Prior Bonds T'rustee, relating to the Prior Local Obligations. The Prior Local Obligations, and therefore, the Prior Bonds, are subject to redemption on any interest payment date on or after Octobcr 1, 2002. C. The 1997 Bonds are secured by revenues consisting of amounts payable to the Authority by the City on the Prior Local Obligations. D. The District and the Authority have determined to redeem the Prior Bonds pursuant to the Prior Indenture and effect a refunding thereof, and in connection therewith, to redeem the Prior Local Obligations pursuant to the Prior Fiscal Agent Agreement. E. The City Council of the City, as thc legislative body of the District, has determined to cause the District to issue its Special Tax Refunding Bonds, Series 2008 (the "Series 2008 Bonds"), pursuant to the Bond Indenture, dated as of even date herewith (the "2008 Indenture"), by and between the Authority and Wells Fargo Bank, National Association, as trustcc (together with any successors and assigns, the"2008 Trustee"). F. Pursuant to the 2008 Indenture, a portion of the proceeds derived from the Series 2008 Bonds will be deposited in escrow with the Escrow Agent and applied to the purchase of noncallable direct obligations of, or noncallable obligations guaranteed by, the United States of America. 987440.3 -1- G. In accordance with the Prior Fiscal Agcnt Agreement, if the City, on behalf of the District, will pay or cause to be paid, or will have made provisions to pay, or there will have bcen set asidc in trust funds to pay, to thc holders of� any portion of thc Pric►r Local Obligations, the principal and interest and premium, if any, to become due thereon, then with respect to such portion of the Prior Local Obligations the pledge and lien of the Prior Fiscal Agent Agreement will thereupon cease, terminate and become void and be discharged and satisficd. H. In accordance with the Prior Indenture, if the Authority will pay or cause to be paid, or will have madc provisions to pay, or there will have been sct aside in trust funds to pay, to thc holders of any portion of the 1997 Bonds, the principal and interest and premium, if any, to becoine due thereon, then with respect to such portion of the 1997 Bonds the pledge and licn of the Prior lndenture will thereupon cease, terminate and become void and be discharged and satisfied. I. In order to provide for the proper and timely application of the moneys deposited in said escrow to the payment of the Prior Local Obligations and the Prior Bonds, it is ncccssary to entcr into this Agreement. NOW, THEREFORE, in considcration of the forcgoing and of the mutual covenants hereinafter set forth, the parties hereto agree as follows: Section 1. Definitions. Unless the context clearly requires otherwise, capitalized tenns used in this Agreement shall have the meanings ascribed to them in the introductory paragraph and the Recitals hereof. In addition, as used herein, the following tenns shall have the following meanings: "Code" means the Internal Revenuc Code of 1986, as amended. "Escrow Fund" means the Escrow Fund established and held by the Escrow Agent pursuant to Section 3. "Escrow Securities" ineans the Investment Securities set forth in Schedule B hereto. "Investment Securities" means noncallable direct obligations of the United States of America, or bonds or other obligations which are noncallable and for which the full faith and credit of the United States of America are pledged for the payment of principal and interest, to maturc or be withdrawable, as the case may be, not later than the time whcn needcd for the payment or redemption of the Prior Local Obligations and the Prior Bonds in order to discharge the respective pledges and liens securing the Prior Local Obligations and the Prior Bonds. "Prior Local Obligations Account" means the account within the Escrow Fund cstablished and held by thc Escrow A�ent pursuant to Scction 3. "Refunding Requirements" means an amount suf'ficient to pay all installments of principal and interest of�thc Prior Local Obligations and of the Prior Bonds, respectively, on their respective earliest available optional redemption date, as set forth in Schedule A attached hereto. 9R7440.3 -2- Scction 2. /1ppc�intment of� Escrow A,gent. The Authority and thc Uistrict hercby appc�int Wclls Fargo Bacik, National Association, as Escrow Agent u�ldcr this Agrccmcnt f��r the benetit of the holders of the Prior Local Obligations and the Prior Bonds. The Escrow Agent hercby accepts thc duties and obligations of Escrow Agent under this Agreement and agrees that the irrevocable instructions to the Escrow Agent herein provided are in a form satisfactory to it. The applicable and necessary provisions of the Prior Fiscal Agent Agreement, including particularly redemption provisions set forth in Article II thereof, are incorporated herein by reference. The applicable and necessary provisions of the Prior Indenture, including particularly redeinption provisions set forth in Article II thereof, are incorporated herein by reference. Reference herein to, or citation herein ot; any provisions of the Prior Fiscal Agent Agreement or the Prior Indenture shall bc deemed to incorporate the same as a part hereof in the same manner and with the same cffect as if thc same were fully set forth hcrein. Section 3. Escrow Fund. There is hereby created and established with the Escrow Agent a special and irrevocable trust fund designated the "Escrow Fund" (the "Escrow Fund") to be held by the Escrow Agent separate and apart from all other funds of the District, the Authority or the Escrow Agent and used only for the purposes and in the manner provided in this Agreemcnt. In the Escrow Fund, thcre shall be cstablished and created an account designated the "Prior Local Obligations Account." Section 4. Deposits to Escrow Fund. (a) Upon the issuance of the Series 2008 Bonds, the Authority, the City, and the District shall cause to be deposited with the Escrow Agent in the Prior Local Obligations Account of the Escrow Fund, the following: (i) $[9,374,633.60], representing a portion of the sale proceeds of the Series 2008 Bonds; (ii) money transferred by the District froin the Special Tax Fund (as defined in the Prior Fiscal Agent Agreement) in the amount of $[891.31] (representing moneys deposited in the Special Tax Fund that would have been used to pay debt service on the Prior Local Obligations on the next Interest Paycnent Date but for the refunding described herein); (iii) money transferred by the District from the Reserve Fund (as defined in the Prior Fiscal Agcnt Agreement) in the amount of$[1,896,492.67]; (iv) money transferred by the District from the Redemption Fund (as defined in the prior Fiscal Agent Agreement) in the amount of $[1,379.74]; and (v) money transferred by thc City and the Authority from the Improvement Fund (as defined in the Prior Indenture) in the arnouclt of$[5,020,741.68]. Moneys on deposit in the Prior Local Obligations Account of the Escrow Fund shall be held in irrevocable trust by the Escrow Agent and applied solely as providcd in this Agreemcnt. (b) Upon thc issuance of the Series 2008 Bonds, the Authority shall cause to be deposited with the Escrow Agent in the Escrow Fund, the following: (i) money transferred by the Authority from the Revcnue Fund (as dcfined in thc Prior Indenture) in thc ainount of$[142.61] (representing moneys deposited in the Rcvenue Fund that would have becn used to pay debt service on the Prior Bonds on the ncxt Interest Payment Date but for the refunding described herein); and (ii) money transfcrred by thc Authority from the Surplus Account within the Revenue Fund (as defined in the Prior Indenture) in the amount of$[313,21 1.97J. Moneys on deposit in the Escrow Fund shall be held in irrevocable trust by the Escrow Agent and applied solcly as provided in this Agreemcnt. 987440.3 -3- Scction 5. Investmcnt of Escrow Fund. (a) The Escrow Agent, upon receipt of the moncys described in Section 4(a), shall immediately invest al( ($J 6,294,139.00) of such mo►leys lil the Escrow Securities and shall deposit such Escrow Securities in the Prior Local Obligations Account of the Escrow Fund. (b) The Escrow Agent shall, upon receipt of the moneys described in Section 4(b), deposit the all ($[313,354.58]) of�such moneys in the Escrow Fund to be held uninvested. Tlle Escrow Agent is hereby authori�ed and cmpowered to deposit uninvested mo�lies held hereunder from time to time in demand depc�sit accounts, without payinent for interest thereon as provided hcreunder, established at commcrcial banks that are corporate affiliatcs of the Escrow Agent. Notwithstanding the foregoing or any other provision of this Agreement to the contrary, at the written request of the District and upon compliance with the conditions hercinafter set forth, the Escrow Agent shall have thc power to sell, transfer, request thc redemption of or otherwisc dispose of so�ne or all of the Escrow Securities in the Escrow Fund and to substitute Investment Securities. The foregoing may be effected only if: (a) the substitution of Investment Securities for the substituted Escrow Securities occurs simultaneously; (b) the amounts of and datcs on which the anticipatcd transfcrs from the Escrow Fund (and the Prior Local Obligations Account therein) to the Prior Bonds Trustee for the payment of the principal of; or interest on, the Prior Local Obligations and the Prior Bonds will not be dimin�shed or postponed thereby, as shown in the certification (described below) of� an independent certified public accountant; (c) the Escrow Agent shall receive the unqualified opinion of counsel to the effect that the District has the right and power to effect such disposition and substitution; and (d) the Escrow Agent shall receive from an independent certified public accountant a certification that, immcdiately after such transaction, the principal of and interest on the Invcstment Securities in the Escrow Fund will, together with other moneys available for such purpose, be sufficient to pay the Refunding Requirements. Any cash received from the disposition and substitution of Escrow Securities pursuant to this Section to the extent that, as shown in such certification, such cash will not be required, in accordance with the Prior Fiscal Agcnt Agreement, the Prior Indenture, and this Agreement, at any time for thc payment when due as providcd in Sectior� 6, shall be transferred to the District. Section 6. Reinvestment; Payinent of Refundin� Requirecnents. As thc principal of the Escrow Securities shall mature and be paid, and the investment income and earnings thereon are paid, the Escrow Agent shall reinvest such moneys in Investment Securities in accordancc with the written instructions of the District. (a) On the redemption date of�the Prior Local Obligations as set forth Schedule A (i.e., April l, 2008), the Escrow Agent shall transfer an amount sufficient to pay the Refunding Reyuirements of the Prior Local Obligations from the Prior Local Obligations Account of the Escrow Fund to the Prior Bonds Trustee. Such amounts transferred from the Prior Local Obligations Account of the Escrow Fund shall be applied by the Prior Bonds Trustee to the paymcnt of the Refunding Requirements of the Prior Local Obligations for the bencfit of the holder of the Prior Local Obligations (i.e., the Authority). The Authority hcreby agrees that 9R744U.3 -4- upon such transfer pursuant to the foregoing sentence, the Authority shall have been deemed to direct, pursuant to this Section 6 and the Prior Fiscal Agent Agreement, the Prior Bonds Trustee to apply such amounts, together �vith such other amc�unts transferred from the Escrow Fund, to thc paymcnt of tlie Refunding Rcquirements of tile Prior Bonds for thc equal and ratablc bcnefit of the holders of the Prior Bonds. (b) After effcctinb thc transfer pursuant to the foregoing paragraph (a), o�l the rcdemption date of the Prior Bonds as set forth Schedule A (i.e., April 1, 2008), the Escrow Agent shall transfer such amounts remaining in the Escrow Fund to the Prior Bonds Trustee, wl�ich, together with the amounts transferred pursuant to paragraph (a), shall be sufticient to pay thc Refunding Rcquiremcnts of thc Prior Bonds. Such amounts shall be applicd by thc Prior Bonds Trustee to the payment of thc Refunding Requiremcnts of the Prior Bonds for the equal and ratable benefit of the holders of the Prior Bonds. Section 7. Verification. The District has caused schedules to be prepared relating to the sufficiency of the anticipated receipts from the Escrow Securitics to pay the Refunding Requirements. The District shall furnish the Escrow Agent with the report of Grani Thornton LLP, verifying the mathematical accuracy of the computations contained in such schedules. Section 8. Compliance with A�reement, Prior Fiscal A�ent A�reement, and Prior Indenture. The Authority, the City, and the District hereby direct, and the Escrow Agent, in its capacities as escrow agent hereunder and as the Prior Bonds Trustee, hereby agrees that the Escrow Agent will take all the actions required to be taken by it hereunder, including the timely transfer of tnoneys for the payment of principal and interest with respect to the Prior Obligations and the Prior Bonds, in order to effectuate this Agreement. The liability of the Escrow Agent for the payment of ihe Refunding Requirements, pursuant to this Section and, in its capacity as Prior Bonds Trustee, the Prior Fiscal Agent A�neement and thc Prior Indenture, shall be limited to the application, in accordance with this Agreement, of moneys and the Escrow Securities in the Escrow Fund and the Prior Local Obligations Account therein (including interest earnings thereon, if any) available for the purposes of and in accordance with this Agreeinent. Section 9. Tax Covenants. Notwithstanding any other provision of this Abreement, the District, the City, and the Authority hereby covenaiit that cio part of the proceeds of thc Series 2008 Bonds or of the moncys or funds held by thc Escrow Agent hcreunder shall be used, and that the District, the City, and the Authority shall not direct the Escrow Agent to use, any of such moneys or funds at any time, directly or indirectly, in a manner that would cause any of the Series 2008 Bonds to be an "arbitrage bond" under Section 148 of the Codc and the regulations of the Treasury Department thereunder proposed or in effect at the time of such use and applicable to obligations issued on the date of issuance of the Series 2008 Bonds. None of the Authority, the District, the City, nor the Escrow Agent shall, except as sct forth in this Agreement, sell, transfer or otherwise dispose of the Escrow Securities; provided that the Escrow Agent may effectuate the transfer of such Escrow Securities to a successor escrow agent in accordance with ihe provisions of Section 15 relating to the transfer of rights and property to successor escrow agents. 987440.3 -5- Scction 10. Notices. The Authority hereby instructs the Escrow Agcnt, in its capacity as the Prior Bonds Trustee, to mail to the registered owners of the Prior Qonds, as soon as practicahle upon receipt of the deposit of moncys in the Cscrow Fund pursuant to Section 4, a notice substantially in the forrn sec fortl� in Exl�ibit A attached herero. The Auttiority also hereby instructs the Escrow Agent, in its capacity as the Prior Bonds Trustee, to send redemption notices, at least 30 days but no more than 60 days bcforc the redemption date set forth in Schedulc A, to the rcgistcrcd owncrs of the Prior Bonds, the Sccurities Depositorics and to onc or more Inforcnation Services (as defined in the Prior Indenture) in the fonn and manner prescribed by Section 2.02(d) of the Prior lndenture. Section 11. Defeasance of Prior Local Obligations and Prior Bonds. The District, the City, and the Authority represent and agree that, concurrently with the initial deposit of the Escrow Securitics pursuant to Section 5, (i) the Prior Local Obli�ations scheduled to cnature on or after October 1, 2QQ8 will be deemcd paid and wi�� no longer be deernec� to be outstanding within the mcaning and with the effect expressed in the Prior Fiscal Agent Agrccment, and (ii) thc Prior Bonds will no longer be deemed to be outstanding and unpaid within the tneaning and with the effect expressed in the Prior Indenture. Section 12. Nature of Lien. The trust hereby crcated shall be irrevocablc and thc holders of thc Prior Bonds shall have an express lien on all of the moneys and Escrow Securities in the Escrow Fund (and the Prior Local Obligations Account therein), including the interest earnings thercon, until paid out, used and applied in accordance with this Agreement. Section 13. Amendments. This Agreement is made pursuant to and in furthcrance of the Prior Fiscal Agcnt Agrccmcnt and the Prior Indenture and for the benetit of the District, thc City, the Authority and the holders from time to time of the Prior Bonds and it shall not bc repealed, revoked, altered, amended or supplemented without the written consent of all such holders and the written consent of the Escrow Agent, the Authority, the City, and the District; provided, however, that the District, the Authority, the City, and the Escrow Agent may, without the consent of, or notice to, such holders, enter into such agreement supplemental to this Agreement as shall not materially adversely affect the rights of such holders and as shall not be inconsistent with the tenns and provisions of this Agreemcnt, for any one or morc of thc following purposes: (a) To cure any ambiguity or fonnal defect or omission in this Agreement; (b) To grant to, or confer upon, the Escrow Agent for the benefit of the holders of the Prior Bonds, any additional rights, reinedies, powers or authority that inay lawfully be granted to, or conferred upon, such holders or the Escrow Agent; (c) To transfer to thc Escrow Agent and make subject to this Agreemcnt additional funds, securities or properties; and (d) To make any othcr changc dctcrmined by the Authority, thc City, and the District to be not materially advcrse to the holders of thc Prior Bonds. The Escrow Agent shall be entitled to rcly exclusively upon an opinion of counsel with respect to compliance with this Scction, including the extent, if any, to which any change, 9R7440.3 -6- modification �r addition affccts thc rights of the holders of the Pri�r Bonds, or that any instrument executed hercunder complies with the conditions and provisions of this Scction. Section 14. Compensation of Escrow Age�lt. In cc�nsideration of the services rendered by the Escrow Agent under this Agreement, the District agrees to and shall pay to the Escrow Agent its proper fees and expenses in accordance with the agreement therefor reached by the Escrow Agent and the District, including all reasonable expenses, charges, counsel fees and othcr disbursements incurred by it or by its attorneys, a�ents and employees in and about the performance of their powers and duties hereunder, from any moneys of the District lawfully available therefor and the Escrow Agent shall have no lien whatsoevcr upon any of the moncys or Escrow Securities in the Escrow Fund for the payment of such proper fees and expenses. Section l5. Resi�nation or Removal of Escrow Agent; Appointment of Successor. The Escrow Agent at the time acting hereunder may at any time resign and be discharged from the trusts hereby created by giving written notice to the District, the City, the Authority, and the Prior Bonds Trustee (if different from the Escrow Agent) specifying the date when such resignation will take effect, but no such resignation shall take ef�fect unless a successor Escrow Agent shall have been appointed by the holders of the Prior Bonds or by the District as hcreinafter provided and such successor Escrow Agent shall have accepted such appointment, in which event such resignation shall take effect immediately upon the appointment and acceptance of a successor Escrow Agent. The Escrow Agent may be removed at any time by an instrument or concurrent instruments in writing, delivered to the Escrow Agent and to the District, the City, and thc Authority and signed by the registered holders of a majority in principal amount of the Prior Bonds. The Escrow Agent may also be removed at any time by the District with not less than 30 days' written notice to the Escrow Agent, the Authority, the City, the Prior Bonds Trustcc (if different froin the Escrow Agent) and thc registered holders of thc Prior Bonds. In the cvcnt thc Escrow Agent hereunder shall resign or be removed, or be dissolved, or shall be in the course of dissolution or liquidation, or otherwise become incapable of acting hereunder, or in case the Escrow Agent shall be taken under the control of any public officer or officers, or of a receiver appointed by a court, a successor Escrow Agent may be appointed by the holders of a majority in principal amount of the Prior Bonds, by an instrument or concurrcnt instruments in writing, signcd by such holdcrs, or by their attorneys in fact, duly authorired in writing; provided, nevertheless, that in any such event, the District shall appoint a temporary Escrow Agent to fill such vacancy until a successor Escrow Agent shall be appointed by thc holders of a majority in principal amount of the Prior Bonds, and any such tcmporary Escrow Agcnt so appointed by thc District shall immediately and without further act be superseded by the Escrow Agent so appointed by such holders. The District shall give written notice of any such appointment made by it to the Authority, the City, and the Prior Bonds Trustee. In the event that no appointment of a successor Escrow Agent or a temporary successor Escrow Agent shall have been made by such holders or the District pursuant to the foregoing provisions of this Section within 60 days after written notice of the removal or resignation of the Escrow Agent has been given to the District, the holder of any of the Prior Bonds or any retiring Escrow Agent may apply to any court of competent jurisdiction for the 987440.3 -7- appointmcnt of a successor Escrow Agent, and such court may tliereupoil, aher such notice, if any, as it shall dc�m proper, appoint a successor Cscrow Agcnt. No successor Escrow Agent shall be appointed unlcss such successor Escrow Agcnt shall be a corporation with trust powers organized under the banking laws of thc Unitcd States or any state, and shall have at the time of appointment capital and surplus of not lcss than $]00,000,000. Every successor Escrow Agent appointed hereunder shall execute, acknowledgc and deliver to its predecessor and to the District, an instrument in writing accepting such appointment hereunder and thereupon such successor Escrow Agent without any further act, deed or conveyance, shall become fully vested with all the rights, immunities, powers, trusts, duties and obligations of its predecessor; but such predecessor shall, nevertheless, on the written request of such successor Escrow Agent or the District execute and deliver an instrument transferring to such successor Escr�w Agent all the estates, properties, rights, powers and trusts of such predecessor hereunder; and every predecessor Escrow Agent shall deliver all securities and moneys held by it to its succcssor. Should any transfer, assignment or instrument in writing frocn the District be required by any successor Escrow Agent for more fully and certainly vesting in such successor Escrow Agent the estates, rights, powers and duties hereby vested or intended to be vested in the predecessor Escrow Agent, any such transfer, assignment and instrument in writing shall, on requcst, bc cxccutcd, acknowledged and delivered by the District. Any entity into which the Escrow Agent, or any successor to it in the trusts created by this A��reetnent, may be merged or convertcd or with which it or any successor to it inay be consolidated, or any entity resulting from any inerger, conversion, consolidation or tax- free reorganization to which the Escrow Agent or any successor to it shall be a party, shall, if it meets the qualifications set forth in the fifth paragraph of this Section, and if it is otherwise satisfactory to the District, be the successor Escrow Agent under this Agreement without the exccution or filing of any paper or any othcr act on the part of any of thc parties hcrcto, anything herein to the contrary notwithstanding. Section 16. Limitation of Powers and Duties. The Escrow Agent shall have no power or duty to invest any funds held under this Agreement except as provided in Sections 5 and 6. The Escrow Agent shall have no power or duty to transfer or otherwise dispose of thc moneys held hereunder except as provided in this Agrccmcnt. Section 17. Indemnification. To the extent pennitted by law, the District hereby assumes liability for, and hereby agrees (whether or not any of the transactions contemplated hereby are consuintnated) to indetnnify, protect, save and keep harmless the Escrow Agent and its respective successors, assigns, agents, employees and servants, from and against any and all liabilities, obligations, losses, damages, penaltics, claims, actions, suits, costs, expenses and disbursements (including reasonable legal fees and disbursements) of whatsoever kind and nature which may be imposed on, incurred by, or asserted against, the Escrow Agent at any time (whcthcr or not also indemnified against the samc by the District or any other person under any other agreement or itistrument, but without double indemnity) in any way relating to or arising out of the execution, delivery and performance of this Abrecment, the establishment hereunder of the Escrow Fund, the acceptance of the funds and securities deposited therein, the 987440.3 -8- purchase of any sccuritics to bc purchascd pursuant thereto, thc retcntion of such securities or the proceeds thereof and any pa}nnent, transfer or other application of moncys or securitics by the Escrow Agent in accordancc with the provisions c�f this Agreemcnt; provided, h�wever, that the District shall not be requircd to indemnify thc Escrow Agent agairist tt�e Escrow Agcnt's own negligence or willful misconduct or the negligence or willful misconduct of the Escrow Agent's employees. In no event shall the Authority, the District or the Escrow Agent be liable to any person by reason of tlle transactions contemplated hereby other than as set forth in this Section. The indemnities contained in this Section shall survive the termination of� this Agreement and removal or resignation of the Escrow Agent. Section 18. Limitation of Liabilitv. The Escrow Agent and its respective successors, assigns, a�ents and servants shall not be held to any personal liability whatsoever, in tort, contract, or otherwise, in connection with the execution and delivery of this Agreement, the establishment of� the Escrow Fund, the acceptance of the mc�neys or any securities depc�sited therein, the purchase of the securities to be purchased pursuant hereto, the retention of such securities or the proceeds thereof; the sufficiency of�the securities or any uninvested moneys hcld hereunder to accomplish the payment and rede�nption of the Prior Bonds, or any payment, transfer or other application of moneys or securities by the Escrow Agent in accordance with the provisions of this A��reement or by reason of any non-negligent act, non-negligent omission or non-negligent error of the Escrow Agent inade in good faith in the conduct of its duties. The recitals of fact contained in the Recitals of this Agreement shall be taken as the statements of the District or the Authority, and the Escrow Agent assumes no responsibility for the correctness thereof. The Escrow Agent makes no representation as to the sufficiency of the securities to be purchased pursuant hereto and any uninvested moneys to accomplish the pay►nent and redernption of the Prior Bonds pursuant to the Prior Indenture or to the validity of this Agreement as to thc District or the Authority and, exccpt as otherwise provided herein, the Escrow Agent shall incur no liability in respect thereof. The Escrow Agent shall not be liable in connection with the performance of its duties under this Agreement except for its own negligence, willful misconduct or default, and the duties and obligations of the Escrow Agent shall be determined by the express provisions of this Agreement. The Escrow Agent may consult with counsel, who may or may not be counsel to the District, and in reliance upon the written opinion or advice of such counsel shall have full authorization and protection in respect of any action taken, suffered or omitted by it in good faith in accordance therewith. Whenever the Escrow Agent shall deem it necessary or desirable that a matter be proved or established prior to taking, suffering, or omitting any action under this Agreement, such matter (except the matters set forth herein as specifically requiring a certificate of a nationally recognized finn of� independent certified public accountants or an opinion of nationally reco�nized bond counsel) may bc deemed to be conclusively establishcd by a written certitication of the District or the Authority, as applicable. Whenever the Escrow Agent shall deem it necessary or desirable that a matter specifically requiring a ceriificate of a nationally recognized firm of independent certitied public accountants or an opinion of nationally recognized bond counsel be proved or established prior to taking, suffering, or omitting any such action, such matter may be established only by such a certificate or such an opinion. No provision of this Agreement shall require the Escrow Agent to expend or risk its own funds or otherwise incur any fiiiancial liability in the performance or exercise of any of its dutics in accordance with this Agreement, or in the exercise of its rights or powers. �x�aao.3 -y- Scction 19. Termination. This A�neement shall terminatc whcn mc�neys I�ave been transferred pursuant to Section G tc� the Prior Bonds Trustee sufficient to pay all Prior Local Obligations and all Prior Bonds. Upon such tennination, all moneys remaining in the Escrow Fund after payment of any amc>unts duc tiic Escrow Agent hereunder shall he releascd to tlle Special Tax Fund held under the 2008 Indcnture. Section 20. Governin ��, Law. This Agreement shall be governed by the law of thc Statc of California. Section 21. Severabilitv. If any one or more of the covenants or agreements provided in this Agrecment on the part of thc District, the Authority, the City, or the Escrow Agent to bc performed should be detennined by a court of competent jurisdiction to be contrary to law, such covenant or agreement shall be deemed and construed to be severable from the remaining covenants and a�neements herein contained and shall in no way affect the validity of thc remaining provisions of this Agreement. All thc covenants, promises and agreements in this Agreement contained by or on bchalf of thc District, thc Authority, the City, or the Escrow Agent shall bind and inure to thc benefit of their respective successors and assigns, whether so expressed or not. Section 22. Counterparts. This A�-eeinent may be executed in scveral counterparts, all or any of which shall be regarded for all purposes as one original and shall constitute and be but one and the same instrument. �Rc�mainder o/�Page /ntentionally Left BlankJ 9 R 7440.3 -10- (F.sc•rn►�•�1��-eem�nt) IN WITNESS WHEREOF, the parties hereto havc cach caused this Agrecment to be executed by their duly authori�ed officers and appointed or elected officials as of the date first written above. PALM DESERT FINANCING AUTHORITY By: Chief Administrative Officer CITY OF PALM DESERT By: Mayor CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) By: Mayor of the City of Palm Desert, California WELLS FARGO BANK, NATIONAL ASSOCIATION, as Escrow Agcnt By: Authorized Otficer 9 R 7440.3 -1 1- SCHEDULE A REFUNDING REQUIREMENTS "Prior Local Obli�ations" City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Limited Obligation Refunding Bonds, Series 1997 Redemption Redemption Escrow Date Principal Intcrest Premium Reyuirement April 1, 2008 $15,924,000.00 $498,689.25 $0.00 �,16,422,689.25 * Consists of the follo�ving Prior Local Obligations to bc optionally redeemcd on April l,2008: Maturitv Date Interest Redemption (October 1) Principal Ratc Price 200R $ 998.000 S.R25°/, 100% 2009 1,057.000 5.925 100 2010 1,120.000 6.025 100 2011 l,18E,,000 6.050 100 2012 1,261.000 6.325 100 2013 1,337,000 6.325 100 2014 1,426.000 6.325 100 2(1l5 1,S14.000 6.325 100 2016 1,613,000 6.425 100 2017 1,711,000 6.425 100 201 R 844,000 6.425 100 2019 901,000 6.425 100 2020 956,OOU 6.425 100 "Prior Bonds" Palm Desert Financing Authority 1997 Revenue Bonds (Assessment District Nos. 92-1 and 94-1 and Community Facilities District No. 91-1) Redemption Redemption Escrow Date Principal Interest Premium Requirement April l, 2008 $16,260,000.00 $474,285.63 �0.00 $16,734,285.63 * Consists of the following Prior Bonds to bc optionally redcemed on April 1, 200R: Maturity Uate Interest Redemption (October 1) Principal Rate Yrice 2008 $1,060,000 5.400% ]00% 2009 1,115,000 5.500 100 2010 1,1 R0,000 5.600 100 2011 1,245,000 S.fi25 100 2015 5,705,000 5.900 100 2020 5,955,000 6.U00 100 9R7440.3 Schedulc A-1 SCHEDULE B ESCROW SECURITIES Type of Maturity Date Par Securit�� Amount Rate SLG-Cert April 1, 20U8 $16,294,139.00 3.75% 987440.3 Schedule B-1 EXHIBIT A [FORM OF DEFEASANCE: NOT[CE] PALM DESERT FINANCING AUTHORITY Noticc to thc Holdcrs of Palm Desert Financing Authority 1997 Revenue Bonds (Asscssmcnt District Nos. 92-1 [Tierravista] and 94-1 [Bighorn] and Community Facilities District No. 91-1 [Indian Ridge]) scheduled to mature on October 1, 2008 and thereafter through October 1, 2020 CUSIP No. NOTICE IS HEREBY GIVEN on behalf of the Palm Desert Financing Authority (the "Authority"), that pursuant to Section 9.03 of the Indenture of Trust, dated as of Novc�nber 1, 1997 (t1�e "Indenture"), pertaining to the abovc-captioried Bonds with the maturity dates of October l, 2008 and thereafter through October l, 2020, the lien of such Indenture has bcen discharged through the irrevocable deposit in escrow of cash and Federal Securities. DATED this_ day of , 2008 WELLS FARGO BANK, NATIONAL ASSOCIATION, as Escrow Agent 9R7440.3 Exhibit A L&J DRAFT#2 1 1/28/07 $ CITY OF PALM DESERT COMMUNITY FACILI"I'IES DISTRIC7' NO.91-1 ([NDIAN RIDGE PUBLIC IMYROVEMENTS) SYECIAL TAX REFUNDING BONDS SERIES 2008 BOND PURCHASE CONTRACT Decembcr , 2007 City of Palm Desert Community Facilities District No. 91-1 (Indian Ridgc Public Improvemcnts) 73-510 Fred Waring Drive Palm Desen, California 92260 Ladies and(ientlemen: Stinson Securities, LLC, on bchalf of itself and as the rcprescntativc (the"Re�rese��tative") of Kinsell, Newcomb & De Dios, Inc. (together, with the Representative,the"Underw�•iters")offers to enter into the following Bond Purchase Contract (the"Purchuse C'nntracP') with the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) (the"Dist�•ict"), which, upon acceptance of this offer by the District and approval by the City of Palm Desert(the "Citv") will be binding upon the District and the Unde�writer. This oi�fer is made subject to acceptance ot�this Purcl�ase Contract by the City on or before 1 1:59 p.m. California time on the date hereof,and, if not so accepted, will be subject to withdrawal by the Underwriters upon written notice delivered to the District at any time prior to such acccptance. Capitalized terms used in this Purchase Contract and not otherwise defined herein shall ha��e thc meanings given to such terms as set forth in the Indenture (defincd below). Section 1. Purchase and Sale. Upon the terms and conditions and upon the basis ot�the representations set forth in this Purchase Contract,the Underwriters agree to purchase from the District, and the District agrecs to sell to the Undeiwriters, all (but not less than all)of the � _aggregate principal amount of the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvemcnts) Special Tax Refunding Bonds, Series 2008 (the"Bonds"). Thc Bonds shall be dated their date of delivery and shall have the �naturitics and bear interest at the rates per annum and have the yields all as sct forth on Schedule I attached hereto. The purchase price for the Bonds shall be S (�vhich incl��des an Under`vriters' discount in the amount of� , less a net original issue discount in the amount of S_�, and such purchase pricc represents %ot the principal amount of the Bonds. Section 2. [)escription of the Bonds. The Bonds are issued pursuant to the provisions of the Mello-Roos Community Facilities Act of 1982, as amended, being Chapter 2.5, Pan l, Division 2, Title 5, of the Government Code of the State of California(the"AcP')and shall be as described in and shall be secured under and issued pursuant to a Bond ]ndenture, dated as of January 1, 2008 (the"/ndenture") by and between the Uistrict and Wells Fargo Bank, National Association, as trustee(the"T!'1LSIPP��). The Bonds shall be payable and subject to redemption as provided in thc Indcnture and described in the OfGcial Statement. The Bunds are secured by a special tax (the "Sj�ec•ic�! Tu.r") levied and collected on the Taxablc Parccls located within the District and amounts held in certain lunds and accounts established by the lndenture, subject only to the provisions of the Indenture permitting the application thereof for the z;a-u�nz�r,�c.z purposes and on the tenns and conditions sct forth thercin. The Bonds are legal,valid and limited obligations of�the District which are payable solely from and secured by a pledge of the Special Tax, net of Administrative l;xpenses in an amount not to exceed the Administrative Expenses in an amount not to exceed the Administrative Expenses Priority Cap (as defined in the Indenture). The 13onds are bcing issued in order to: (i) refund and defcase all of the outstanding S principal amount of Palm Desert Financing Authority 1997 Revenue Bonds (Assessment Districts No. 92- 1 [Tierravista) and 94-1 [Bighorn] and Community Facilities District No. 91-1 [Indian Ridge]) (the"Priur Bonc%s") pursuant to the terms and conditions of an Escrow A�reement,dated as of January 1, 2008 (the "Esc��o�t�AgreemenP'), by and among the Palm Desert Financing Authority(the"Authority"), the City, the District and Wells I�argo Bank, National Association, as escrow agent(the"Escrotiv Agent'), (ii) fund a reserve account as securiry for the Bonds; and (iii)pay certain costs associated with the issuance of the Bonds. The payment of principal of and interest on thc Bonds when due will be guaranteed under a tinancial guaranry insurance policy (the"Finuncia!Gua�•ant}�Polic}'")to be issued by (the "Insurer")simultaneously with the deli��ery of the Bonds. Section 3. Authorit oy f Representative. Any authority, right,discretion or other power conferred upon the Underwriters by this Purchase Contract may be exercised jointly by the Underwriters or by the Representative on behalf of the Underwriters, and the District shall be entitled to rely upon any requcst, notice or statement if the same shall have been given or made by the Representative. Section 4. Public OCferin�. It shall be a condition to the obligation of the Underwriters to purchase, accept delivery of, and pay for the Bonds that the entire � principal amount ot�the Bonds authorized by the Indenture bc delivered by the Uistrict to thc Underwriters on the datc of Closing, defined below. The Underwriters agrcc to make a bnna frde public offering of all ofthe Bonds, at not in excess of the initial public offering yields or prices set forth on Schedule 1 attached hereto, however, the Bonds may be offered and sold to certain dealers(including dealers depositing the Bonds into investment trusts)at prices lower than such initial public offering prices or yields. The Underwriters reserve the right to make concessions to dealers and to change such initial public oftering prices or yields as the Undenvriters reasonably deem necessary in connection with the marketing of the Bonds. Tl�e Underwritcrs also reserve the right tc>: (i) ovcr-allot or effect transactions that stabilize or maintain the market price of the Bonds at a level above that which might otherwise prevail in the open market and (ii)discontinue such stabilizing, if'commenced, at any time. rollowing the initial public offering of the Bonds, the oftering prices may be changed from time to time by thc Undcrwritcrs. Section 5. Delivery of the Official Statement and Other pocuments. The District has delivered to the Underwriters a Preliminary Official State►nent dated December_, 2007, including the cover pagc and appendices thereto, in printed fonn and in electronic forrn in all material respects consistent with such printed forn� relatcd to the Bonds (the"Prelimina�}'O%Jiciul Stutement")as it may bc amcnded, and will deliver to the Underwriters as promptly as possible, but in no event later than the seventh f3usiness Day atter the City has accepted this Purchase Contract, such number of copies of the final Official Statement dated the date hereof relating to the Bonds, as it may be amended and supplcmented from time to time pursuant tu Section 6(t1 (the"nf�iciu!Stutemenf'), as the Underwriters may reasonably request in order for the Underwriters to comply with the rules of the Municipal Securities Rulemaking Board (the "ti1.SXB")and paragraph (b)(4) of 17.CFR.240 15c2-12 ("Rule ISc2-I2"). Prior to the date hereof, the District delivered to the Undcrwriters a cec-tificate pursuant to Securities and Exchange Commission Rule I Sc2-12(b)(1), relating to the Preliminary Official Statemcnt, in substantially the fo�m attached hereto as Lxhibit A. z�a-o�uz����-z 2 The [)istrict hereby authorizes the use of the Official Statcment by the Underwriters in connection with thc public offerin�and the sale of the Bonds. The Underwritcrs hereby agree that they will not send any confirmation requesting payment for the purchase of any Bonds unless the confirmation is accompanied by or preceded by the delivery of a copy of the Official Statement. The Underwriters agree that from the time the Official Statement becomes available until the earlier of: (i) 90 days from the"enil o/thc>c�nde�•tivritin�period,"as defined in Section 6(h) of this Purchase Contract,or(ii)the time when the Official Statement is available to any person from a nationally recognized municipal securities information repository, but in no case less than 25 days following thc"end of the underwriting period"(as detined bclow), each Underwriter shall send, no later than the next business day following a request for a copy thereof, by first class mail or other eyually prompt means, to any Potential Customer, as detined in the Rule,on request, a single copy of the Official Statement. The Representative agrees to: (1)provide the District with final pricing information on the Bonds, (2)promptly file a copy of the Ofticial Statement, including any supplements prepared by the District with a nationally recognized municipal securitics intormation repository, (3) promptly notify the District of the end of the underwriting period(as such tenn is defined in Rule 15c2-12), and (4) take any and all other actions necessary ro comply with applicable Securities and Exchange Commission rules and MSRB rules governing the offering, sale and delivery of the Bonds to ultimatc purchasers. Section 6. Representations and Warranties of the I�istrict. The District represents and warrants to the Underwriters that: (a) The District is a cortununity facilities district duly organized and existing under the Act and the laws of tlie State of California(the"State")and has all necessary power and authority to enter into and perfonn its duties under the District Agreements (defined bclow) and, when duly authorized, executed and delivered by the other parties thereto, the District Agreements will each constitute a legal, valid and binding obligation of'the District enforceable in accordance with its respective terms, except as enforceability may be limited by bankruptcy, insolvency,moratoriinn or other laws affecting the enforcement of creditors' rights generally; (b) The(:ity(;ouncil as the legislative body of the District has,by a resolution adopted by a majority of the members of the City Council at a meeting duly called, noticed and conducted,at which a quorum was present and acting throughout, on December_, 2007 (the"Di.sn•ict Resoltrtron"), taken all ofticial action necessary to be taken by it for(i)the execution,delivery and due performance of the Indenture, Escrow Agreement, the Tax Certificate of the District dated the Closing Date as hereinafter detined(the"Tnx CertiJicate")and the Continuing Disclosurc Agrcement, dated the Closing Date(thc "Continuing Uisclos��r•e AgreemenP'), by and among the District, the Trustce and MuniPinancial,as Dissemination Agent, (collcctivcly, the"District Agreements") and this Purchase Contract; (ii) the distribution ot�the Preliminary OfGcial Statement and the execution and deliver of the Official Statement; (iii)thc issuance, sale and delivery of the Bonds; and (iv) and for the taking of any and all such action as may be required on the part oi the Uistrict to carry out,give eftect to and consummate the transactions contemplated hereby; (c) This Purchase Contract constitutes, and upon their issuance and delivery,the Bonds,and the District Agreements will constitute, legal, valid and binding oblibations of the District enforceable in accordance with their terms, except as enforceability may be limited by bankruptcy, insolvency, moratorium or creditors' rights benerally; and to the best knowledge of the District, the execution and delivery of the District Agrecments, the Bonds and this Purchase Contract, and compliance with the provisions of each thereof will not in any material respect conflict wilh or constitute a►naterial breaclti of or a material default under any applicable law or administrative regulation of the State of California or the United States, or any applicable judgment, decree, agreement or other instrument ro which the District is a party or is otherwisc subjcct; z3a-o�u��r��,�-z 3 (d) At the ti►ne of the District's acceptance hereof and at all times subsequent thereto up to and including the time of the Closing, the information and statements in Preliminary Official Statement and the Of�ficiai Stateinent did not and wi11 not contain any untrue statemenl of a inaterial fact or omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleadinb; (e) As of ti�e date i�ereof and except as otherwise disclosed in the Official Statement, there is no action, suit, proceeding or investigation, notice of which has been served on the District, before or by any court,public board or body pending against the District or to the best knowledge of the District threatened against the District, wherein an unfavorable decision, ruling or finding would: (i)affect the creation, organization, existence or powers of the District, or the titles of its members or officers, (ii) enjoin or restrain the issuance, sale and delivery of the Bonds, the levy and collection of the Special Tax or the utie of any other monies or properties pledged or to be pledged under the Indenture for the paymcnt of thc Bonds, (iii) in any way yuestion or affect any of the rights,�owers,duties or obligations of the District with respect to the monies pledged or to be pledged to pay the principal of,premium, if any,or intcrest on the Bonds, (iv) in any way question or affect any authority for the issuance of the Bonds,or the validity or enforceability of the Bonds or the District A�reements, or(v) in any way question or affect the Purchase Coniract,the Sonds,the transactions contemplated by the Purcl�ase Contract,the Official Statement, or any other abreement or instrument to which the District is a pai'ty relating to the issuance of the Bonds; (� If,between the date hercof and the datc which is 25 days after the"end oJthe auTdentiriting perind"(as defined in Section 6(h)), any event occurs, or facts or conditions become known of which the Uistrict or the City has knowledge and which in the reasonable opinion of Richards, Watson &Gershon, A Professional Corporation, Los Angcles, California("Bond CounseT'), Lofton&Jcnnings, San Francisco, California("Disclosur•e CucrnseP'), or Best, 13est& Krieger, LLP, Indian Wells, California, as City Attorney (the "Cit}�Attorney"), would cause the infonnation contained in the Ot�f icial Statement, as then supplemented or amended, to contain an untrue statement of a material fact or to omit to state a material fact necessary to make such information therein, in the light of the circumstances under which it was presented, not misleading in any material respect, the District will notify the Representative, and, if in the opinion of the Represcntative, such event requires the preparation and publication of a supplement or amcndment to the Official Statement, the District will forthwith prepare and furnish to thc Underwriters(at the expense of the District}a ceasonah4e number of cop'ses of an amendment of or supplement to the Official Statement(in form and substance satisfactory to the Underwriters) which will amend or supplement the Official Statement so that it will not contain an untrue statement of a material tact or omit to state a material fact necessary in order to make the statements therein, in the light of thc circumstances existing at the time the Osfi�iaf Statement is defivered to prospective purchasers, not misleading in any material respect. If such notification shall occur subsequent to the Closing, the District shall forthwith provide to the Underwriters such certificates as the Underwriters may reasonably deem necessary to evidence the truth and accuracy of such supplement or amendment to the Official Statement. For the purposes of this subsection,betwcen the date hereof and the date which is 25 days after the "end of the underwriting period" for the Bonds, the District will furnish such information with respect to itself as the Underwriters may from time to time reasonably request; (g) If the inCormation contained in the Ofticial Statement is amended or supplecnented pursuant to Section 6(fl, at the time of such supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such subparagraph) at all times subsequent thereto up to and including the date which is 25 days after the"end of the�undertit�riting pe�•iod,"as defined in Section 6(hl for the Bonds, the pot-tion of the Official Statement so supplemented or amended(including any iinancial and statistical data contained thercin),excluding statements and infonnation under the caption "UNULRNRIT[NG,"in APPL•NnIX D—"DTC AND THE• BOOK-ENTKY ONLY SYS"fEM"and information as to prlce and is�terest rate on t4�e cover of the Officia4 Statement,will not contain any untrue statement of a Z3a-u�Uz9�pc ' 4 material fact or omit to state a material fact necessary to make such information therein, in the light ot�thc circumstances under which it was made, not misleading in any material respect; (h) As used herein and for thc purposes of the foregoing, the term "end of underwriting period" for the Bonds shall ►nean the earlier of(i) the Closing Date unless the District shall have been notified in writing to the contrary by the Representative on or prior to the Closing Date or(ii) the date on which the"end of the underwriting period" for the Bonds has occurred under Rule 15c2-12,provided, however, that the District may treat as the"end of the underwriting period" for the Bonds the date specified as such in a notice from the Representative stating the date which is the "end of the underwriting period;" (i) Any certiticate signed by any official of the Uistrict authorized to do so shall be deemed a representation and warranty by the District to the Underwriters as to the statements made thercin; (j) The District shall apply the proceeds of the Bonds, including the investment earninbs thereon, in accordance with the Indenture and the L.scrow Abreement, and as described in the Official Statement; (k) The District is not in default in any materia) respect, and no such default has occurred and is occurring on any bond,note or other obligation for borrowed money or any agreement under which any such obligation is or was ouistanding; and (I) The District will undertake, pursuant to the Continuing Disclosure Agrcement to provide ccrtain annual tinancial information and notices of the occurrence of certain events, if material. A description of this undertakinb is set fonh in the Preliminary Ofticial Statement and will also be set forth in the final Official Statement. Section 7. Representations and Warranties oi�the City. T}ie City represents and warrants to thc Undcrwriters that: (a) The City is a charter city and municipal corporation duly organized and existing under the laws of the State of California (the"State")and has all necessary power and authority to enter into and perform its duties under the City Agreements(detined below)and, when duly authorized, executed and delivered by the other parties thereto, the City Agreements will each constitute a Iegal, valid and binding obligation of tl�e City enforceable in accordance with its respective ter►ns, except as enforceability may be limited by bankruptcy, insolvency, moratorium or other laws affecting the enforecment of creditors' rights �cnera44y; (b) The City Council of thc City has,by a resolution adopted by a majority of the membcrs of the City Council at a meeting duly called, noticed and conducted, at which a quorum was present and acting throughout,on December , 2007 (the "City Resoh�tion"), taken all official action necessary to be taken by it for(i) the execution, delivery and due performance of the, Escrow Agreement, the Tax Certificate of the City dated the Closing Date as hereinaRer defined (the"Tu.r Certifcnte")and the Continuing Disclosure Agreement of the City, dated the Closing Date(the "Continuing Disclosure Agrcement") (collectively, the "Citi�A�reements") and this Purchase Contract; (ii) the distribution of the Preliminary Ofticial Statement and the exccution and deliver of the official Statement; (iii)the issuance, sale and delivery of the Bonds; and(iv)and for the takin�of any and all such action as may be required on the pan of the City to carry out, give effect to and consummate the transactions contemplated hereby; z3a-o�uz9�pc-z 5 (c) This Purchase Contract constitutes, and upon their issuance and delivery, the City Agreements will constitute, Iegal, valid and binding obligations of the City enforceable in accordance with their terms, except as enforceability may be limited by bankruptcy, insolvency, moratorium or creditors' rights benerally; and to the best knowledge of�the City, the execution and delivery of the City Agreements and this Purchase Contract, and compliance with the provisions of each thereof will not in any inaterial respect conflict with or constitute a material breach of or a material detault under any applicable law or administrative regulation of the State of California or the United States,or any applicable judgment, decree, agreement or other instrument to which the City is a party or is otherwise subjert; (d) At the time of the City's acceptance hereof and at all times subsequent thereto up to and including the time of the Closing, the information and statements in Preliminary Official Statement and the Official Statement did not and will not contain any untrue state►nent of a material fact or omit to state a material fact necessary to make the statements therein, in the light of the circucnstances under which thcy were made, not misleading; (c) As of the date hereof anJ except as otherwise disclosed in the Ofticial Statement,there is no action, suit,proceeding or investigation, notice of which has been served on the District, before or by any coui-t, public board or body pending against the City or to the best knowledge of the City threatened against the City, �vherein an unfavorable decision, ruling or finding would: (i)aftect the creation, organization, existence or powers of the City,or the titles of its members or ofticers,(ii)enjoin or restrain the issuance, sale and delivery of the Bonds, the levy and collection of the Special Tax or the use of any other monies or propertics plcdged or to be pledged under the lndenture for the payment of the Bonds, (iii) in any way question or aftect any of the rights,powers,duiies or obligations of the City with respect to the monies pledged or to be pledged to pay the principal of,premium, if any, or intcrest on the f3onds, (iv) in any way question or affect any authority for the issuance of the Bonds,or the validity or entorccability of the Bonds,the Purchase Contract or the City Agreements, or(v) in any way question or affect the 1'urchase Contract, the Bonds, the City Agreements, the transactions contemplated by the Purchase Contract, the Official Statement, or any other agreement or instrument to which the City is a party relating to the issuance of the Bonds; (t) If, between thc date hereof and the date which is 25 days after the"end of the z�nclenti�riting pei�iocP'(as defined in Section 7(h)),any event occurs, or facts or conditions become known of which the City has knowledge and which in the reasonable opinion of Bond Counsel, Disclosure Counsel or the City Attorney, would cause the information contained in the Official Statement,as then supplemented or amended, to contain an untrue statement of a material fact or to omit to statc a matcrial fact necessary to make such infonnation therein, in the light of the circumstances under which it was presented, not misleading in any material respect, the City will notify thc Underwriters,and, if in thc opinion of the Undenvriters, such event requires the preparation and publication of a supplement or amendment to the Official Statement, the City will fonhwith prepare and furnish to the Underwriters (at the expense of the City) a reasonable number of copies of an amendment of or supplement to the Of(icial Statement (in form and substance satisfactory to the Unde�writers) which will amend or supplement the Ofticial Statement so that it will not contain an untrue statement of a material fact or omit to state a material fact necessary in ordcr to make the statements therein, in the light of the circumstances existing at the time the Ofticial Statement is delivered to prospective purchasers, not misleading in any material respect. If such notification shall occur subsequent to the Closing, the City shall forthwith provide to the Underwriters such ceniticates as the Underwriters may reasonably deem necessary to e��idence the truth and accuracy of such supplement or amendment to the Official Statement. For the purposes of this subsection, between the date hereof and the date which is 25 days after the"end of the underwritin� period" for the Bonds, the City will furnish such infom�ation with respect to itself as the Underwriters may from time to time reasonably request; ��a-n�uze,�,�_z 6 (g) If the information contained in the Official Statement in AP�L��DrX B—"G�NGRAL INFORMATION CONC�.RNING THC- CITY OF PnLM DESGRT" is amended or supplemented pursuant to Sertion 7�f , at the time of such supplement or amendment thcreto and(unless subsequently again supplemented or amendcd pursuant to such subparagraph)at all times subsequent thereto up to and including the date which is 25 days after the"end of the under-writing period,"as defined in Section 6(h) for the Bonds, the portion of ihe Official Statement so supplemented or amended(including any tinancial and statistical data contained therein), excluding statements and information under the caption "UNDLRWRITING,"in APPENDIX D—"DTC AND THE BOOK-ENTRY ONLY SYSTGM"and infonnation as to price and interest rate on the cover of the Ofticial Statement, will not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make such information therein, in the light of the circumstances under which it was made, not misleading in any material respect; (h) As used hcrein and for the purposes of thc foregoing, the tcrm"end of undertirriting pe�•ioc/" for the Bonds shall mean the earlier of(i)the Closing Date unless the City shall havc been notified in writinb to thc contrary by the Representative on or prior to the Closing Datc or(ii)tl�e date on which the"end of the underwriting period" for the Bonds has occurred under Rule I Sc2-12,provided, however,tliat the Ciry may treat as the"end of the underwriting period" for the Bonds the date specitied as such in a notice from the Representative stating the date which is the`'end of the underwriting period;" (i) Any certiticate signed by any ofticial of the City authorized to do so shall be deemed a represcntation and wan�anty by the City to the Underwriters as to thc statcments made therein; (j) The City shall apply the proceeds of the Bonds, including the investment earnings thereon, in accordance with the Indenture and the Escrow Agreement,and as described in the Official Statement; and (k) The City is not in dcfault in any material respect and no such default has occurred and is occurring, on any bond, note or other obligation for borrowed ►noney or any agreement under which any such obligation is or was outstanding. Section 8. The Closin�. At 8:00 A.M., California time, on January 15, 2008,or on such earlier or later datc as may be a�reed upon by the Representative and the District (the"Closing Dute"), the Underwriters will accept delivery of the Bonds through the tacilities of The Depository Trust Company in Ncw York, New York("DTC"') by the initial deposit with the Trustee(in care of DTC}through the Fast Automated Securities Transfer System procedures and will deliver or cause to be delivered at the offices of Bond Counsel in Los Angelcs, California, or such other place as shall have been mutually agreed upon by the parties,the other documents described herein and the Underwriters shall pay the purchase price of thr Bonds as set forth in Section 1 of this Purchase Contract in immediately available funds to the order of tl�e Trustee, less the premium for the Insurance Policy in the amount of S , which tl�e Representative will wire directly to thc Insurer. The Bonds shall be issued in fully registered form. It is anticipated that CUSIP identitication numbers will be insertcd on the Bonds, but neither the failure to provide such numbers nor any error with respect thereto shall constitute a cause for failure or refusal by the Underwriters to accept delivery of the t3onds in accordance with the terms of this Purchase Contract. z�a-u�oz��p�-z 7 Section 9. Termination bv the Underwritcrs. Tl�e Representative shall have the right to terminate the obligations of the Under�vriters under this Purchase Contract to purchase, to aceept delivery of and to pay for the Bonds by notifying the City of its elcction to do so it; after the execution hereof and prior to Closing: The Underwriters shall have the right to terminate their obligations tmder this Purchase Contract to purchase, to accept delivery of and to pay for the Bonds by notifying the County of its election to do so if, after the execution hereof and prior to Closing Date: (1) lcgislation (including any amendments thereto), resolution, rule or regulation (including any amendments thereto) shall be introduced in, considered by or be enacted by any governmental body, department or political subdivision of the State, or a decision by any court of competent jurisdiction within the State shall be rendercd which, in the reasonable opinion of the Underwriters would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the Bonds on the terms and in the manner contemplated in the Official Statement; (2)the outbreak or declaration of war, institution of a police action,engagement in military hostilities by the United States,or any escalation of any existing conflict or hostilities in which the United States is involved, or the occurrences of any other national or international emergency or calamity or crisis or any chanbe in tinancial markets resulting from or any escalation of the foreboing, which, in the reasonable opinion of the Underwriters�vould make it i►npracticable or inadvisable to proceed with the offer, sale or delivery of the 13onds on the tenns and in the manner conte►nplated in the Official Statement; (3)the declaration of a general banking moratorium by federal,New York or California authorities, or the general suspension or material limitation of trading on the New York Stock Exchange, the Nasdaq National ?vlarket, in any over-the-counter market or any national securities exchange which materially adversely affects the market price of the Bonds; (4)the imposition by the New York Stock Gxchange or other national securities exchan�e, or any governmental authority,of any material restrictions not now in force with respect to the Bonds or obligations of the general character of the Bonds or securities generally, or the material increase of any such restrictions now in f'orce, including those relating to the extension of credit by,or the charge to the net capital require►nents of,the Under�vriters which, in the reasonable opinion of the Undenvriters would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the Bonds on the tenns and in the manner contemplated in the Official Statement; (5) legislation enacted(or resolution passed) by or introduced or pending legislation amended in the Congress or recommended for passage by the President of the Unit�d States,or an order,decree or injunction issued by any court of competent jurisdiction,or an order, rulinb, regulation (17na1, temporary or proposed) issued or made by or on behalf of the Sccurities and Cxchange Commission,or any other governmental agency having jurisdiction of the subjcct matter, ro the effect that securities of the general character of the Bonds, or the Bonds, including any or all underlying arrangements, are not exempt trom registration under the Securities Act of 1933,as amended, or that the Indenturc is not exempt from qualification under the Trust Indenture Act of 1939,as amended, or ti�at the execution, oifering or safe of obligations of the general character of the F3onds, including any or all underlying arrangements, as contemplated hereby or by the Official Statemcnt,otherwise is or would be in violation of the federaf securities laws as amended and then in effect; (6) action is taken by or on bchalf of the State or the State Franchise Tax Board, with the purpose or effect, directly or indirectly, ot�imposing State personal income taxation upon such interest as would be received by the Owners of the Bonds; (7) thc withdrawal or downgradinb or any notice of an intcnded or potential downgrading ot�any raUng of�the obligations ot�the County(including the rating to be issued with respect to the 13onds)by a "nationally recognized statistical rating organization," as such term is detined for purposes oC Rule 436(g)(2) under the Securities Act of 1933 as amended which, in the reasonable opinion of the Underwriters would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the Bonds on the terms and in the manner contemplated in the Official Statement; (8)any event occurring, or information becoming known which, in the reasonable judgment of the Underwriters,make untrue in any material respect any statement or information contained in the Official Statement, or has the effect that the Official Statement contains any untrue statement ot�a material fact or omits to state a material fact to be stated therein ur necessary in order to make the statements thcrein, in the light of the circumstances iinder�vhich they were made, not misleading; (9) any change or development involving a prospective ���-o�uze��,�-z 8 change in the condition of the County, financial or otherwise, or in the operations of the County from those set lorth in the Official Statement that makes the Bonds, in the reasonable judgment of the Underwriters, iinpracticable or inadvisable to offer, sell or deliver the �3�nds on the terms and in the manner conte►nplated by the Official Statement; (10)a material disruption in securities settlement or commercial banking,payment or clearance services in the United States shall have occu�red and be continuing; or(11)the purchase of and payment for the Bonds by the Underwriters, or the resale of the Bonds by the Underwriters, on the terms and conditions herein providcd shall be prohibited by any applicable law, governmental authority, board, agency or commission; (12)a general suspension of trading, minimum or maximum prices for trading shall have bcen Gxed and be in force or maximum ranges or prices for securities shall have been required and be in force on the New York Stock Exchange or other national stock exchange whether by virtue of a determination by the New York Stock Exchanbe or by order of the Securities and Gxchange Commission or any other governmental agency having jurisdiction; or(13)any action, suit, proceeding, inquiry, litigaiion or investigation, at law or eyuity, before or by any court or public body, shall be instituted,pending or threatened that requires the preparation of a supplement or amendment to the Ofticial Statement. Section 10. Closin�Conditions. The Underwriters have entered into ihis Purchase Contract in reliance tipon the representations, warranties and agreements of the District contained herein and to be contained in the documents and instniments to be delivered at Closing, and upon the perfonnance by the District of its respective obligations hereunder, both as of the date hereof and as of the Closing Date. Accordingly, the obligations of the Underwriters under this Purchase Contract to purchase, to accept delivery of and to pay for the Bonds shall be subject to the performance by the District of its obligations to bc performed hereunder and under such documents and instruments at or prior to Closing, and shall �ilso be subject to the following conditions: (a) The representations and wan�anties of the District and the City contained herein shall be true,complete and con-ect on the datc hereof and on and as of the Closing Date, as if made on the Closing Datc; (b) As of the Closing Date: (i)each of the District Agreements and the City Agreements shall be in full force and effect,and shall not have been amended,moditied or supplemented,except as cnay have been agrced to by the City and the Underwriter,and(ii)the City shall perform or ha��e performed all of its obligations reyuired under or specified in the District Agreements to be perfonned by the City at or prior to the Closing Date; (c) As of the Closing Date, all necessary official action of the District relating to the Bonds and the I�istrict Agreements shall have been taken by the District, all necessary official action of the City relating ro the Bonds and the City Agree►nents shall ha��e been taken by tl�e City,and each of the District A�rccmcnts and thc City Agreements shall be in full force and effect and shall not havc becn amended, modified or supplemented in any material respect; (d) At or prior to Closing, the Underwriters shall have received each of the following documcnts: (i) Certified copies of the District Resolution and the City Resolution, and executed copies of each of the llistrict Agreements and the City Agreements. (ii) The Preliminary Official Statement and the Official Statement,with the Official Statement executed on bel�alf of the District by a duly authorized ofticer of the District; (iii) The Continuing Disclosure Agreement, executed on behalf�of the Dislrict by a duly authorized officer of the City; z�a-o�n,��.�,�., 9 (iv) An approving opinion of Bond Counsel, dated the Closing Date, substantially in the fonn attached as Appendix D to the Official Statement, and a reliance Ictter with respect thereto addresscd to the Underwriters and the Insurer. (v) A supplemental opinion of Bond Counsel,addressed to the Underwriters and the Insurer, to the effect that: (i) the Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Indenture is exempt from qualification under the Trust Indenture Act of 1939, as amendcd; and(ii)the statements contained in the Official Statement, under the captions"THf�: SI�:RI1:S 2008 BOhDS,"and"SECURI'I'Y AND SOURCES OF P�YMEhT FOR Tilf•,SLR]L•S 2008 BONUS" are accurate in all material respects insofar as such statements summarize certain provisions of the lndenture and the Bonds, and thc statements contained in the Official Statement under the caption"Tnx MArrLRs," insofar as such statements summarize the legal opinion and certain provisions of federal and State law, are accurate in all material respects. (vi) An opinion of Bond Counsel, dated the Closing Date, and addresscd to the Authority, the District and the Underwriters, in the form and substance satisfactory to the District and the Underwriters, to thc effect that the Prior Bonds have becn defcascd. (vii} A certiticate of the DisU�ict, dated the Closing Date, from a duly authurized ofticial of the llistrict to the effect that: (A) The representations and warranties of the District contained in Section 6 hereof are true and correct in all material respects on and as of the Closing Date as if made on the Closing Date; (B) To the best knowledge of such official, no event afCecting the District has occurred since the date of the Official Statement which should be disclosed in the Official Statement in order to make the statemenis therein not misleading. (C) No litigation,notice of which has been served on the District, is pending or to the best knowledge of such official threatened against the District: (1) to restrain or enjoin the issuance, sale or delivery of the Bonds, or the validity of the District Agreements or the Special Tax, (2) in any way contesting or affecting the validity of the I'urchase Contract, the Bonds, or the District Agreements, or(3) in any way contesting the existen�c of the llistrict. (viii) a certificate of the City signed by an authorized officer of the City dated the Closing Date to the effcct that: (A) the representations and warranties of the City contained in Scction 7 hereof are true and correct in all material respects on and as of the Closing Uate as if made on the Closing Date; and (13) the information relating to the City in APP�Nutx B—"GrN�:Rn� INFORMA"fION CONCE•RNING l'HE CITY OF PALM DLSERT" to the Of ticial State►nent, as ot� its date and as of the date of the Closing, is true and correct in all material respects. (ix) An opinion of the City Attorney,dated the Closing Date and addresscd to the City, the Underwriters and the Insurer in substantially the form of l:xhibit B. �34-07029',pr•2 �� (x) The opinion of Lotton&Jennings, Disclos�rre Counsel, dated the Closing Date and addressed to the District and the Underwriters, to the effect that, based upon the information made available to them in the course of their participation in the preparation of the Official Statement and without passing on and without assuming any responsibility for the accuracy, completeness and fairness of the statements in the Official Statement,and having made no independent invcstigation or verification thereof, no facts have come to their attention that lead them to believe that, as of the Closing Date, the Official State►nent (except for any financial or statistical data or forecasts, numbers, charis, estimates,projections, assumptions or expressions of opinion,as to which no opinion or view need be expressed)contains any untrue statement of a material fact or omits to state any material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading and that the Bonds are exempt from registration under the Securities Act and the Indenture is exempt from qualification pursuant to the Trust Indenture Act of 1939, as amended,and that the Continuing Disclosure Agrcement provides a suitable basis for the Underwritcrs, in connection with the Offering(as detined in the Securities and Exchange Commission Rule 15c2-12)of the Bonds, to make a reasonable determination as required by section (b)(5)of said Rule. (xi) The opinion ofcounsel to Wells Fargo. Bank National Association, as the Trustee,thc L.scrow Agent and the Dissemination Agent (the "l3ank"), dated the Closing Date, addressed to the District and the Underwriters, to the effect that: (A) the Bank is a national banking association duly organized and validly existing and in good standing under the laws of the United States of America and has ful l power and authority to execute and deliver d�e Indenture,the Escrow Agreement and the Continuing Disclosure Agreement and to perfonn its respective obligations thereunder; (�3) the Indenture, the Escrow Agreement and the Continuing Uisclosure Agreement have each been duly authorired,executed and delivered by the Bank, in its respective capacities described under each such agreement, and each constitutes a valid and binding obligation of the Bank enforceable against the Bank in accordance with is respective ternls, except insofar as the validity, binding nature and enforceability of the obligations of the Bank under such agreements may be limited by the effect of(I) insolvency, reorganization, ai-rangement, moratoriu►n, fraudulent transfer and other similar laws,(2) the discretion of any court of competent jurisdiction in awarding equitable re►nedies, including, without limitation,specific performance or injunctive relicf, and(3)tl�e effect of general principles of equity embodied in California statutes and common law; (C) the authorization,exccution and delivery of the Indenture, the �scrow Agreement and the Continuing Disclosure Agreement by the Bank,and compliance with the respective provisions thereof, will not contravene the Articles of Association or 13ylaws of the Bank or any law, ruling or regulation governing the banking and tnist powers of thc Bank; (D) there is no litigation pending against the Trustee to restrain thc Trustee's panicipation in, or in any way contesting the powers of the Trustee with respect to the transactions contemplated by the lndenture, the Escrow Agreement or the Continuing Disclosure Agreement; and (E) no authorization, approval, consent, or other order of any governmental agency or regulatory authority having jurisdiction over the Bank that has not bcen z�a-o�ozy�.���-z II obtained is required for thc authorization, execution and delivery by the Bank of the Indenture, the F,scrow Agreement or the Continuing Disclosure Agreement. (xii) A certiticate of the 13ank, dated the Closing Date,to the effect that: (A) The Bank is a trust company existing under the laws of the United States of A►nerica, and has full power and is qualified to accept and comply with the tenns of thc Indenture, the Escrow Agrcemcnt or the Continuing Disclosure Agreement, and to perform its respective obligations stated therein; (B) The Bank has accepted the duties and obligations imposed on it by the Indenture,the Lscrow Agrecmcnt or the Continuing Disclosure Agreement; (C) No consent,approval, authorization or other action by any governmental or regulatory authority having jurisdiction over the Bank that has not becn obtained is or will be required for tl�e consummation by the Bank of the transactions contemplated by the (ndenture and the Escrow Agreement to be undertakcn by the Bank, in its respective capacities under such agreements; (D) Compliance with the terms of the Indenture, the Escrow Agreement and the Continuing Disclosure Abreement will not conflict with, or result in a violation or breach of, or constitute a default under, any loan agreement, indenture, bond, note, resolution or any othcr agreemcnt or instrumcnt to which the Bank is a party or by which it is bound, or, to thc best knowledge of the Bank,after reasonable investigation, any law, rule, regulation, order or decree of any court or governmental agency or body having jurisdiction over the Bank or any of its activities or properties (except that no representation, warranty or agreement is made by the Bank with respcct to any Federal or state sccurities or Blue Sky laws or regulations); and (1:) To the best knowledge of the Bank, there is no action, suit, procceding, inquiry or invcstigation, at law or in equity, before or by any court or governmental agency,public board or body served on or threatened against or affecting the existence of the Bank, or in any way contesting or affectinb the validity or enforceability uf the 13onds, the Indenture, the Escrow Agreement and the Continuing Uisclosure A�reement or contesting the powers of'the Bank or its authority ro entcr into and perfonn its obligations under the Indenture, the Escrow Agreement, the Continuing Disclosurc Agreernent or the Bonds, wherein an unfavorable decision, ruling or fnding would adversely affect the validity of the Indenture, the �scrow Abreement, the Continuing Disclosure Agrcement or the Bonds. (xiii) The Insurance Policy insuring the payment of the principal of and interest on the Bonds issued by the Insurer. (xiv) The opinion of Counsel ro the Insurer addressed to the City and the Undenvriter, dated the Closing Uate, to the effect that the Insurance Policy is a legal, valid and binding obligation of tiie Insurer enforceable in accordance with its tenns. (xv) A Certiticate orthe Insurer, dated the Closing Uate, to the effect that the statements in the Preliminary Official Statement and the Official Starement under the caption "FfNnNCIAL GUnRnNTY INSUR�INCL•"and contained in AYP[?NDIX G-"SPGCIMEN FINANCI�L G�ARANf'1'INSURnNCE PUUCY"accurately reflects and fairly represents the information purported to be sho�vn therein. z 3�s-o�oz����,�-z 12 (xvi) Evidence from Standard& Poor's,a division of the McGraw Hill Companies, Inc. that it has assigned an insured rating to the Bonds of"AAA" [and evidence from Fitch Ratings that it has assigned an insured rating to the Bonds of"AAA."] (xvii) A certiticate of Grant Thornton LLP(the"Ve�•ifcueion Agent"), independent certified public accountants, dated the Closing Date, to the effect that it has veriGed the cnathematical accuracy relating ro: (i)computation of forecasted receipts of principal and interest on the l:scrow Securities and the forecasted payments of principal and interest to redeem the Prior Bonds, and(ii) computation of'the yields on the Bonds and the Escrow Sccurities to be deposited in the Rcfunding Fund; (xviii) A Tax Certificate,executed on behalf of the District by a duly authorized ofticer of the City. (xix) Evidcnce of required filings with the California Debt and Invcstment Advisory Commission. (xx) A copy of the executed Blanket Letter of Representations by and between the District and The Depository Trust Company, New York, New York, relating to the book-entry system for thc Bonds; (xxi) Such additional Iegal opinions, certificates, instruments and documents as the Underwriters may reasonably request to evidence the truth and accuracy,as of the date hereof and as of the Closing Date, of the representations and warranties of the District contained herein and of�the statements and information contained in the Official Statement and the due performance or satisfaction by the District on or prior to the Closing Date of all agreements then to be performed and all conditions then to be satisfied by the District. All of the opinions, letters, certificates, instru►nents and other documents mentioned above or elsewhere in this Yurchase Contract shall be deemed to be in compliance with the provisions hercof if, but only if, they are in form and substance satisfactory to the Underwriters. Receipt of; and payment for, the F3onds shall constitute evidence of the satisfactory nature of such as to the Underwriters. The perfonnance of any and all obligations of the District hereunder and the perfonnance of any and all conditions contained herein for the benefit of the Undeilvriters may be waived by the Representative in its solc discretion. If the District shall be unable to satisfy the conditions to the obligations of the Underwriters to rurchase, accept delivery of and pay for the Bonds contained in this Purchase Contract,or if the obli�ations of the Underwriters to purchase, accept dclivery of and pay for the Bonds shall be terminated for any reason permitted by this Purchase Contract, this Purchase Contract shall terminate, and non�of thc Underwriters nor the District shall be undcr further obligation hereunder, except that the respcctive obligations of the District and the Under�vriters set forth in Section 10 hereof shall continue in full force and cCf'ect. Section l 1. F.xnenses. (a) The Underwriters shall be under no obligation to pay and the Uistrict shall pay the following expenses incident to the performance of the obligations of the District hereunder: (i) the fecs and disbursements of Bond Counsel and Disclosure Counsel; (ii) the cost of printing and delivering the Bonds, the Preliminary Oflicial Statement and the Official Statement (and any amendment or supplcment prepared pursuant to Section 6 of this Purchase Contract); (iii) the fecs and disbursements uf I�el Itio Advisors, LLC, as Financial Advisor to the District, the Verification Agent, �IuniFinancial, as Special Tax Consultant, thc 13ank, accountants, advisers and of any other experts or consultants retained �3a-o�uz9�.pc-2 13 by the llistrict; and (iv) any other expenses and costs of the District incident to the performance of their respective obligations in connection with the authorization, issuance and sale of the Bonds, including out- of-pocket expenses and regulatory expenses, and any other expenses agrced to by the parties. (b) The Underwriters shall pay all expenses incurred by them in connection �vith the public offering and distribution of the Bonds including,but not limited to: (i) all advertisin�;expenses in connection with the offering of the Bonds; and(ii)all out-of-pocket disbursements and expenses incurred by ihe Underwriters in connection with the offering and distribution of the Bonds (including travel and other expenses, fees of the California Debt and Investment Advisory Commission, CUSIP Service Bureau fees, costs and fees to prepare any blue sky memoranda and any other fees and expenses), except as �rovided in(a) above or as otherwise agreed to by the Underwriters and ihe District. Section 12. Notices. Any notice or other communication to be given to the District under this Purchase Contract may be given by delivering the same in writing at the address for the District set forth above, and any notice or other com►nunication to be given to the Underwriters under this Purchase Contract may bc given by delivering the same in writing to the Representative: Stinson Sccurities, LLC, 55 I�rancisco Street,Penthouse A, San Francisco,California 94133; Attention: Lonnie Odom, C�;O. Section 13. Parties in Interest; Force and �,ffect. This Purchase Contract is made solely Cor the benefit of the llistrict and the Underwriters (including thcir successors and assigns), and no other person shall acyuire or have any right hereunder or by virtue hereof. All of the representations, warranties and abreements of the District contained in this Purchase Contract shall remain operative and in full force and ef�iect rcgardless ot`. (a) any investigations made by or on bchalf of the Underwriters; or (b) dclivery of and payment for the Bonds pursuant to this Purchase Contract . The agreements contained in this Section I 3 and in Section 1 1 shall survive any tennination of this Purchase Contract. Section l4. Unenforceable Provisions. In the event that any provision of this I'urchase Contract shall be held invalid or unenforceable by any court of competent jurisdiction, such holding shall not invalidate or rcnder unenforceable any other provision of this Purchase Contract. Scction 15. Counter�ans. This Purchasc Contract may be executed in any number of counterparts, all of w�hich taken together shall constitute one agreement, and any of the parties hereto may execute the Purchase Contract by signing any such co�mterpart. Section 16. Governin� Law; Venue. This Purchase Contract shall be governed and interpreted cxclusively by and construed in accordance with the laws of the State applicable to contracts made and to be performed in the State. Any and all disputes or legal actions or proceedinbs arising out of this Purchase Contract or any document related hereto shall be filed and►naintained in a court of cotnpetent jurisdiction for matters arising in Riverside County, California. By execution of and delivery of this Purchase Contract,the parties hereto accept and consent to the aforesaid jurisdiction. Section 17. Headin�s. The headings of the sections of this Purchase Contract are inserted for convenience only and shall not be deemed to be a part hereof. Section 1�. l:ntire Agreement. The parties agree that the terms and conditions of this Purchase Contract supersede those of all previous agreements between the parties, and that this Purchase Contract contains the cntire agreement between the parties hercto. In the event of a dispute between the parties under this Purchase Contract , the losing party in such dispute shall pay all reasonable costs and expenses incurred by the prevailing party in connection therewith, including but not limited to attorneys' fees. z3a-n�oz���,-z 14 Section 19. Ef�fectiveness. This Purchase Contract shall become effective upon the execution of the acceptance hereof by authorized officers of'the District, and shall be valid and enforceable as of�the time of such acceptance. Very truly yours, STINSON SCCURITIES. LLC KINS�LL, NEWCOMB & DE DIOS, INC. By: STINSON SECURITIES, LLC,as Representativc By: Lonnie Odom Chief Executive Officer Acccpted: CITY O1� PALM DESERT COMMUNITY PAC1LITlES DISTRICT NO. 91-1 (INDIAN R1UGE PUBLIC IMPROVEMENTS) By: Authorized Officcr Approved: CITY OF PALM DGS�RT By: Authorized Officer ��a-n�n�v���_, �5 SCHLDULEI � CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IVIPROVEMF.NTS) SPECIAL TAX REFUNDING BONDS SERIES 2008 MATURITIES, AMOUNTS, RATES, YIELDS AND PRICES Maturity Principal Intcrest {October 1) Amount Rate Yield Price 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 234-07029�pc-2 EXHIBIT A S CITY OF PALM DESERT COMi�1UNITY FACILI'fIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) SPECIAL TAX REFUNDING BOVDS SF,RIES 2008 CER'I'IFICATE OF THE DISTRICT RN:GARDING PRELIMINARY OFFICIAL STATEMF.N"1' The undersigned hereby states and certitics: 1. That she is the duly qualified and acting City ?vlanager of the City of'Palm Desert(the "City")as the legislative body of the City of Palm Uesen Community I�acilities District No. 91-1 (Indian Ridge Public Improvements) (the "District")and, as such, is familiar with the facts herein certitied and is authorized and qualitied to ceRify the same; 2. That there has been delivered to Stinson Securities, LLC and Kinsell, Newcomb & Uc Dios, Inc., as the underwriters of the captioned Bonds(the"Underwriters"), a Preliminary Ofticial Statement relative to the captioned Bonds, dated December , 2007 (including the cover page and all appendices thereto, in printed form and in electronic form in all material respects consistent with such printed form, the"Preliminary Official Statement"),which the City,on behalf of the District deems Final as of its date for purposes of Rule 15c2-12 promulgated under the Securities Excl�ange Act of 1934,as amended("Rule ]Sc2-12"), except for information permitted to be omitted therefrom by Rule 15c2-12; and 3. The Uistrict hereby approves thc use and distribution by the Underwriters of the Prelirninary Ufficial Statement. Datcd: Deccmber , 2007 CITY OF PALM DESERT COMMUNITY PACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PU�3LIC IMPROVLMLNTS) By: �:arlos L. Ortcga City Manager 234-07112y�pc-2 A-1 EXHIBI"C B FOR111 OF OPINION OF DISTRICT COUNSEL [Closing Date] City of Palm Descrt Community Facilitics l�istrict No. 91-I (Indian Ridge Public Improvcments) Palm Descrt,Califomia Stinson Securities, LLC San Francisco, Calisornia Kinsell, Newcomb& De Uios, Inc. Solana Bcach,California [Insurer] Ncw York, New York Re: City of Palm Desen Community Facilities Districi No. 91-1 (Indian Ridge Public Improvements) Special Tax Retunding Bonds, Series 2008 (District C'nunsel Opinion) Ladies and Gentlemen: I am the City Attorney of the City of Palm Desert (the "City"). In such capacity, in connection with the issuance of the above-referenced bonds (the "Bonds") by the City of Palm Desen Community Facilities District No. 91-1 (Indian Ridge Public Iinprovements) (the "District"), 1 have examined the original, cenified copies, or copies otherwise identitied to my satitifaction as being true copies of such resolutions, docu►nents, eertiticates, and records as I have deemed relevant and necessary as the basis for the opinions set forth herein relying on such examination and pertinent law and subject to ihe qualifications hereinafter set forth. Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the Bond 1'urchase Contract, dated December , 2007 (the "Purchase Contract"), by and among Stinson Securities, LLC, and Kinsell, Newcomb & De Dius, Inc.(the "Underwriters"), and the City, as the s thc legislative body of the District. F3ased upon the foregoing, I am of the opinion that: 1. The City is a municipal corporation duly organized and validity existing under the Constitution and laws of the State of California, with full legal right, power, and authority to form the llistrict; 2. Rcsolution No. 07- has been duly approved at a meeting of the City Council on Uecember , 2007, acting as the legislative body ot�the District, which �vas called and he4d pucs�iane to law and �vith all public notice required by law and at which a yuorum was present and acting throu�hout, and Resolution No. 07-_ has not been amended since its date of adoption and is now in full forcc and e(�tect; z3�-u�oz����-z 13-1 3. Othcr than as disclosed in the Official Statemcnt, no action, suit, procceding, inquiry or investigation, at law or in eyuity, before or by any court, regulatory agency, public board or body to which the City or the Disirict is a part and has been served with a summons or other notice thereof, is pending or, to ►ny knowledge, threatened, in any way affecting the existence of tl�e District, the existence of the City of the titles of its officers to their respective offices, or secking to restrain or to enjoin the issuance, sale or delivery of the Bonds, the application of the proceeds thereof in accordance with the Indcnture and the Escrow Agreement, the collection of application of the Spccial Taxes to pay the principal of, and interest on, the Bonds, or in any way contesting or affecting the validity or enforceability of the Bonds, the Indenture, the Escrow Agreement, this Purchase Contract, the Continuing Disclosure Agreement, or any action of the City or the District contemplated by any of such documents or in any way contesting the completeness or accuracy of the Official Statement or the powers of the City or thc district with respect to the Bonds, the Indenture, the Escrow Agreement, this Purchase Contract, the Continuing Disclosure Agreement, of any action on the part of the City or the District contemplated by any ot�such documents,or in any way seeking to enjoin or restrain the City from approving the development oi�any of the property within District, or which challenges the exclusion of the interest paid on the 13onds from federal income tax purposes and the cxemption of interest paid on the E3onds from State of Calif'ornia personal income taxation. 4. 7he statements in the Of�ficial Statement under the heading "NO LITIGATION" are as of the date of the Official Statement and as of the date of the opinion, true and correct in all material respects and do not, as oC the date of the Official Statement and as of the date of the opinion, contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in the light oC the circumstances under which they were made, not misleading. Sincercly, _'34-07029',pc-2 �-2 L�J l)raft r�4 - I I/l 5/07 PREL1�11NARl'Oh'FICIAL STATF.�IEN'I'DAl'N:U UE('E�1BN:R 14,2007 NF:\�'ItiSUE-I300K-EVTRI'ON1.1' RATInGS: S&P �H'itch� Insurcd: Ar N�r up�niun o/72ichen�d�. {�'ut�un ct�(;c��:�hon. A Prufe��.��uunl C'u���orrrtiun. L�,.�.dn�c�lee. ('cih/u�•nic�. Runri Cum�.ce(. hu.�erl on exLclin,L(a�, und «.�s�un��i,t cump/irrnre nrth rc�rruin cnrenurr�.s seI/nrlh b� Ihc�ducirmtml.c per�nrnbiK fu!he Se��e.ti lllll�Bonrlc culd�c�yture�mr�Ns u/lhe°/�rrr��nu/Rer�•iiuc• ('urlc�u//9�Yf. us mnr�rdr�!(rhe� ..('�,rle�..).n.c dr.cc r�he�d hevrrn. inrr�c�c�oi�Ihe Srric�?IIII,Y Bon�l.c(s nul inc(ti�le�tl in Kruss htcumr oJ thi�n�rne�:c Ihe�rru//ur /edrru( i�u��nir tu.r pu�7wsc:� fn dte- opiruort of Bu+ul Cuiuu'c�L intrres! tm Ihe Srrirs 111II,4 Bone(ti' i.c nut (rruled us nn i(rm u�(n.�'prrJere��tcr (ur (he� piu/ttuec oJ lhc�/edivr�(n(Ie�r�nNve mhr�mmn la.r bnpus�tl un intliridunLc ruul caE�a»�ions hiicve.c!on!he Se�ic�s 11111,'i Bwids mu}'he s��/,/��ct tn ccviain /��d��rnl lnxeec tmposi�A on ca/�uruttun.c. includtnt!he cu�y�o�'nle nherniNire mr�r�mrun �n.r un u ponron oJ�har rn�erc�.c1. /�t Ihr/tu lher upiniun u/Bnnr( C�otrn.�'el. inte�rc�s�un!he Bundc rs ex�inp�/rom per.eonnl i��c��me la.a�s�mpu.serl hr Ihe S�alr oJ(�nlr/orniu .k�e .T.�a�L1 i i iek.ti'." $10,720,000* CI'1�1'OF PALM DI�:S�RT COMMLNITI'FACILITIES UISTRICT NO.91-1 (INDIAN RIDGE PUBI.IC IMPROVEMF:NTS) SPF.CIAI.TAX R�:FUNDING BONDS SERIES 2008 Dated: Date of Issuance Due: October I,as sho��n on the inside co�•cr hereof The Ciry of Palm Desert('ommunity Facilities District No. 91-I (Indian Ridge Pubhc Impro�ements)(the"District") is issuing 510,720,000* principal amount of City of Palm Desert Community Facilities District No. 91-I (Indian Ridge Public Impro�ements) Special Tax Refunding Bonds, Srrics 200R(the"Senes 2008 Bonds")ro:(i)refund and defease all of the outstanding$IG,260,000 principal amount of Palm Uescrt Flnancing Authority 1997 Rc�•cnue Bonds(Assessmcnt Districts No.92-1 [Ilerra�ista�and 94-1 [BighornJ and Communiry Facilities District No.91-I 9�Indian RidgeJ)(the "Pnor[3onds"), (ii) fund a reserve account as secunty for the Series 2008 Bonds; and (iii)pay certain costs associated wrth the issuance of the Senes 200R Bonds. The Serics 200R Bonds�vill be issued by District pursuant to the temis of a Bond Indenture,dated as of January I,200R(the"indenture"). by and beaveen thc Uistnct and Wells Pargo Bank,National Associauon,as trusree(the"frustee"). The Series 2008 Bonds are special obligadons of the Uistnct payable solely from and secured by Vet Taxes and certain moneys held in thc Special Tax Pund rstablished under the Indenture (and designated accounts therein, but ercluding the Administrati�•e Expenses Account) as further described herein. "Net Taxes"are derived from annual installments of sprcial taxes(the"Special Taxes") le�ied and collected on the taxable property �vithin the Distnct. The Special Taxes are levied according to the rate and method of apportionment of Special Taxes as described herein. The Special Taxes arc securcd by a lien on certain real property within Ihe Dislrict and does not constitutc a personal indebtedness of the respective propeny o��ners. Ser"SP('l'RIT}'FOR'I Ilh.ShKII l?Q(1R BC11DS-S�CC12I TBXCi'and ANt�i�t�ix A-"R:�i r nxn Mernuu��r ANi�c�ki ux:nu v i or Srrci:�i Tnxrs." fhe Senes 2(IOR Bonds��ill be issued as fully registered instrumrnts without coupons,in the denomination of 55,000 or any integral multiple thereof, in book-entry fomi, initiall}• registered in ihe name of Cede& Co., as nominre c�f The Depository Trust Compan��, Ne�e l'ork, Ne�� York ("UTC"). Purchasers�iill not recri�e physical certrficates rrpresenting their interest in the Senes 2(I(1�Bonds. For so long as the Srries 20U2i Bonds are registered in the name of Cede&Co.,the"I rustec will make all payments of principal and interest on the Series 20118 Bonds to DTC, �vhich, in tum. is obligated to remit such principal and interest to DT('Participants(defined herein)for subsryucnt disbursement to the I3eneficial Owners(defined herein) of the Series?OOR I3onds. Sec APrrnoiz F "D1 C n�� nm Bcx�K-Fn rttv Oni v Svsre�t." Interrst on the Scnes 200R Bonds�vill be payablc on Apnl I and October I of each year(each an"Inrerest Payment Date"),commencing Octobrr I,200R,by check or draft,mailed on the Interest Paymeni Date to each O���ner of the Series 2008 Bonds as of thr Record Uatr preceding such Interest Payment Date. Ser"I Hr $i ttits 2(lOR 13��nns-Descnption of the Scncs 2U08 13onds." 'I'he Scrics 2008 Bonds are subject to optional redemption and extraordinar� redemption from prepayment of the Special Taxes as described hercin. Sec"Ti�e Se►t�ts 2008 Bonus-Redemption Provisions:' Payment of Ihr principal of and interest on the Series 200R Bonds when due will be insured by a financial guaranty insurance policy to be issued by simultaneously�vith the deli�•rry ofthr Senes 200R Bonds. See"Fin,�vc iai Gu:�R,��Tv Inst�R:anc r." [Insurcr Logo� TI1E SF.kIF:S 2U()H BONDS ARE LIMITED OI3LIGATIONS OF THI: [)ISTRI('T PAYABLE SOL.ELY FROM THE PROCEEDS OF SPF.CIAI. TAXES (INCLUDING ANY PREPAl'MENTS THEREOF AND PROCE�DS COLLECTED FROM THE SALE OF PROPERTI' PI:RSUANT"�C1 FORFC'LUSURE PROVISIONS AS SET FORT11 1N TfIE 1NU�NTURE FOR DELINQL'tNC'Y li� PAY'M�.N"l OF I H�. SYECIAL TAXES), 1'ET OF THE COSI IO IIIE CfI'1' Of PAI.M Df:Sk�:RT (THE "CITY") nF ADMINISTRATING THE DISTRICT, AND CERTAIN FUNDS ESIABLISHED PURSUA�IT TO THE INDEtiTURF. AtiD HELU BY THE TRUSIGG, AS MORE FLLLI' UESCRIBED IIEREIN. NEITHGR 1 H� FAITH AND CREDIT NOR TI1L GGNERAL TAXING POWF.R UF TIIE CI'I Y, I H�: COUN"I Y OF� RIVF:RSIDE (l Hl-: "COUVTY"),THE S I A"I I:Of CALIFORNIA(THE"STATE"),UR A1�Y POLITICAI.SUDDIVISION THF.RFOF,01 HI:R l'HAN I HE DISTRIC 1, IS PLEDGEU I'O THF.PAY�IGNT OF TfIE SBRIES 20UR QONUS. I HE SERIES 2OOti I30NDS DO NOT CONSTITUTE AN INDEE3TEDNC•SS OP I HE ('ITY', THh: COUNTY, THE STATE OR ANY POI.I�I ICAL SI�BDIVISION "I HER[nF, WITHIN THE �tEANING OF ANY ('O\'STITUTIONAL OR STATUTORY DC•QT LIMITATlON OR RESTRIC'l ION. MATURII Y SCHEDI;L[ (Scc insidc cover) The Se�te�?OOX Bo�tds iue nJJerer!i+hrn. ac n�td r���:cued ttnd aca�ple�tl h}�Ihe Undenrri[ers. suhjec�lo�he nppro��a!ns tn le�qnlin•l�r/liclia�rl.�. {f'ursun h Gershnn.A/'�v/essionn!Ca��a-nt'r�n, Lo.s AnQele.c. CuliJo�nia, eund('ounseL Ce�rain legn!mntte�s�,Nl be pn.csecf on jo�•�he ni.cn ict nnd rhe ('ut• b�� Be.ct Be.ct cYr /�7•ieKer LLP. lntfiari {f'e!l.c. CuliJorniu. ('i�ti• A��urnet• und Jo� �he Ui.ctrrcl ht' /.oj�un c� JenninKs. Strn Fraiicisco. C'nli�aniri. Disclu.ci�re(i��uise�l. /�i.c nniic�pared�hn��he Se�•ies?llll8 Baitl.s tirr!!he a��ur(uh(e Jnr de(ir���J•on a�n%u�U./unuru}•I5. 2fIfIK STINSON SECURITIES,LLC KINSELL,NE��'COMB B DE DIOS,INC. Datrd: ,2007. '" Prehminary,subject ro changc. $10,720,OU0* C1TY OF PALA1 1)F,SERT COMI11UN1"1'Y FACILITI}�:S DISTRIC'1' NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMEN"1'S) SPECIAL TAX REFUNDING BOI�DS SERIES 2008 �IATURITY SCIIEDULE I3ase CUSIP No.: � Maturity Date Principal Interest �Uctober 1) Amount Rate 1'rice Yield CUS1P' 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 + Copynght 200K. American Bankers Association. CUSIP data herein is provided by Standard and Poor's, CUSIP Senicc k3ureau,a division of The McGraw-Hill Companies,Inc. This data is not intendrd to cr�ate a database and does not scn e in any way as a substrture for the C'USIP Service. CI;SIP numbers are pro�ided for convenience of reference only. Neithrr the Ciry nor the Undcnvriters takc any responsibility for the accuracy or s��n CUSIP numbers. l'he C'USIP number for a specific maturity is subject to being changed after the issuance of the Senes 2(1(18 Bonds as a result of�anous subsequent a�tions including,but not lirnited lo,a rcfunding in whole or in part of such maturity. * Preliminary,subject ro change. a7u'_�)pus-4 CI7'Y OF YALA'I DESH;It'1' COMMUNITY FACILITIES UISTRIC7' NO. 91-1 (INDIAV RIUGE YI;RI.IC IMPROVEMEnTS) and C17'Y OF PALM DESF,RT DISTRICI' I.EGISLAI'IVE BOUY AVD CI1'Y COUNCII, Richard S. Kelly,M���•vr Jean M. Benson,h�u}•ur Pra 7��m Jim l�erguson, C��i�nrilntc�nther� Cindy Fincrty, Cor�rtc•ilmc mher Robert A. Spiegel, Crn�ncilmc�mhc�r CITY S"1'AFF Carlos L. Ortcga, Chic�/Adminisu•utii�c OJrcc��'/E.t�c�ctuii�c�Director/Cih�Mnnugc�r Paul S. Gibson, Ti•c n.curc�r/Ti•eusu�•er/Financc Dirc�ctor Rachelle D. Klassen,Se�cv�etury/Sec�•etc�n�/Cit3'Cl��•k David L. Yrigoyen. Dirc�ctvr o/�Re�cterelopme�ndHot�sing Arla K. Scott,Scnior Financiu/Ancrltst Veronica Tapia, Redc�vc�lnpment Accountunt David J. Erwin, Ci[}•Atta•ner SPI�;CIAL 5ERVICES Richards, Watson& Gershon, Lofton&Jennings A Profcssional Cocporation San Francisco,California Los Angeles, Califomia Disclosi�rc�Cai�n.cc�! Bonrl Counsel Wells Fargo Bank,National Association Del Rio Advisors, LLC Los An�;elcs,California Modesto, California Ti�u.�tec� Finuncin!Ach�isor Grant Thornton LLP MuniFinancial Minneapolis, Minnesota Temecula,Califomia VcriTcntion Agen� Spccinl "!'a.i� Con.sultnnt n7o'_'9,�n,s� 1 GENF,RAL INFORA1A'fI0'.V ABOI-'1"CIIIS UH'H'ICIAL S7'A'tE11H;N'1' Use of'Of'ficiulStutc�mcnt. '1'he infonnation sct forth hcrcin has bccn furnishcd by thc Pinancing �luthority and thc City and includes information which has been obtained from other sources which are believcd to be rcliable. The infoctnation and expressions of opinion contained herein are subject to change without notice and neither the delive�y of this Official Statement nor any sale madc hereunder shall undcr any circumstances create any implication that there has bcen no change in the affairs of thc Di�trict and the City since thr date hereof. F_stimates pnd Forecasls. Any statement made in this Official Statement involving any forecast or matter of cstimates or opinion, whcther or not cxpressly so stated, is intended solely as such and not as a representation of fact. Certain statements included or incorporated by refercnce in this Official Statement constitute "forward-looking statcments" within the meaning of the Unitcd States Private Securities Litigation Reform Act of 1995, Scction 21 E of the Unitcd States Securities �xchanbe Act of 1934, as amendcd, and Section 27A of the United States Securitics Act of 1933, as amcnded (the "Securities Act"). Such statements are generally idcntifiable by the tenninology used, such as "plan," "expect," "estimate," "budget"or other similar words. The achievemrnt of certain results or other expectations contained in such forward-looking statement5 involves known and unknown risks, uncertaintics and other factors which may cauae actual results, performance or achievements describcd to be materially different from any f�uturc results, perfonnance or achievements expressed or implied by cuch fonvard-lookinb statemcnts. The District and the City does not plan to issue any updatcc or rcvisions to those forward-looking statements if or when their expectations,or events,conditions or circumstanccs on which such statements arc based occur. Limit of OfJ'ering. No dealer, broker, salesperson or othcr person has been authorized to give any iniorniation or to make any representations in connection with the offer or salc of the Scries 2008 Bonds by the District, the City or thc Underwriters, other than those contained in this Official Statement, and, if given or made, such other infonnation or representations must not be relicd upon as having been authorized by the Uistrict or the City. "Chis Official Statement docs not constitute an offer to sell or the solicitation of an offer to buy, nor shall therc be any sale of thc Series 200R Bonds by any person in any jurisdiction in which it is unlawful for such person to makc such an otfer,solicitation or sale. Involvement of Underwriters. The Underwriters have provided the following sentence for inclusion in this Official Statement: T�he Undcrwriters have rcviewed thc information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applicd ro the tacts and circumstances of this transaction, but the Underwriters does not guaranty the accuracy or completcness of such information. In connection with the oflering of the Series 2008 Bonds, thc Underwriters may overallot or ef�fect transactions that stabilizc or maintain thc market pricc of the Series 200R Bonds at a level above that which might otherwise prevail in the open market. Such stabilizing, if commenced, may be discontinued at any time. 'I�he Underwriters may ofter and sell the Series 2008 Bonds to certain dealers and others at prices lower than the public offering prices set forth on the inside cover page hereof and caid public offering prices may bc changcd from time to timc by the Undcrwriters. "The Series 2QOR Bonds have not been registered under the Securities Act of 1933, as amended, in reliance upon an exemption from thc registration rcquirements contained in such Act. The Series 2008 I�onds have not been registcred or qualified under thc sccurities laws of any state. u7o3'��.Pos-a 11 "1'ABI.F,UF COI�'1'I�:N7'S Not Gcncral Ubligation of thc('ity...........2S INTR()DUC'"1'ION .............................................1 Levy of thc Spccial Taxes.........................2S General; Authority for Is�uance..................1 Not a I'ersonal Obligation.........................26 I'urpose........................................................2 Cc�llection of the Spccial Taxes.................26 "1'hc City.......................................................2 Bankruptcy................................................26 The District..................................................2 Parity"l�axe�and Special A�sessments......2$ Security and Sources of Yaytnent for Exempt f'ropertics.....................................28 the Series 2008 13onds...........................2 Land Values..............................................29 Risks to I3ondowners...................................3 Natural Disasters.......................................29 Continuing Disclosurc.................................3 Ila�ardous Substancec...............................30 Additional liifoimation................................3 Disclosure� to l�uture Purchasers..............30 PI.AN OF REFUNUING...................................4 Limitation on Remedies; No Refunding of Prior 13onds............................4 Accelcration........................................31 Estimated Sourcc�and Uses of I�unds.........5 Loss of'l�ax l�:xcmption.............................31 Debt Service Schedule.................................fi Risk of Tax Audit......................................32 Secondary Market.....................................32 THL: SIiRII:S 200R BONDS..............................R Yroposition 21 R and the Initiative I)cscription of the SerieS 2008 Bond�.........R Power..................................................32 Redemption Provision,................................8 Redemption Procedures...............................9 CONS'I'I'I'UTIONAL AND Sl'A"I'UTORY I.IMITATIONS ON TAXI:S, SIiCURITY AND SUURCIiS OF REVENUES ANI� PAYMENI' 1�'OR THE SERI�S APPROPRIATIONS ..........................33 2008 BONDS......................................10 Article XIII A of the Califomia Gcncral ......................................................10 Con�titution........................................33 Special Tax Authorization.........................10 Article XIII B of the California Special 'I'ax is not a Personal Constitution........................................33 Oblibation...........................................12 Proposition 21 R.........................................34 Special Tax Fo►mula .................................12 I�uture Initiatives.......................................35 Rrserve Account........................................14 Deposit of Special Tax; Flow of CF,RTAIN I.I:GA[. MATTERS......................36 �unds...................................................15 TAX MATTERS .............................................36 Covcnant for Foreclosurc..........................16 Limited Obligation....................................1 R NO MATF.RIAI. I.ITIGATION......................37 Issuance of Parity Bonds...........................18 RA"I'[NGS........................................................3R FINANCInL C;UARANTY INSURANCE.....19 �INANCIAL AUVISOR.................................38 T�IE I�IS"l'RIC"f............................................... 19 General; Location......................................19 VERIFICATION OF MATHLMA"I'ICAL Status of Uevelopment..............................19 COMPUTAT[ONS.............................3R Land Use Classifications...........................20 UNDI:RWRITING..........................................39 Valuc of the llistrict..................................20 Secured 1'roperty Tax Levies, CONTINUING DISCLOSURE.......................39 Collections and Delinquencies............22 Direct and Ovcrla �n Debt.....................23 MISCELLt�NEOUS........................................40 PP g I30NI)OWNrRS' RISKS................................25 n�o�e,��,.-a iii 1�9AYS AND TABI,H:S C'ity and Ui�trict Map....................................................................................................................................v "I�ablc 1 - 1997 Rcvcnue Bonds..............................................................................................................4 �I'able 2 - Dcbt Service Schcdule...........................................................................................................6 '1'ablc 3 - Projectcd Dcbt Servicc...........................................................................................................7 Table 4 - Maximum Tax Ratc,by Land Use C'ategory....................................................................... 13 Table 5 - Maxi►nu►n Special Tax by Land U�e Catcgory.................................................................... 14 "I'able 6 - Property Cla,�itication By Land Use Categories.................................................................20 Table 7 - AsSessed Value-to-Special 7�ax Lien C'atcgories .................................................................21 Table 8 - 1'roperty()wner's By nssesscd Valuation and Prorated Lien..............................................22 ��able 9 - Ilistorical Special Tax Dclinquency.....................................................................................23 Table 10 - Dircct and Overlapping Debt Report ...................................................................................24 API'ENDICES t\PP�NDIX A - RATE ANI) METIiOI)OF APPOR'I�IONMENT UF SPECIAI.TAXES................A-1 APPENDIX B - GF.Ni:RAL INFORMATION CONCERNING "I�HE CITY OF Pt\LM DFSERT....I3-1 nPPENDIX C - SUMMnRY OI'PRINCII'AL LEGt\L DOCUMrNTS ...........................................C-1 APP�NDIX D - FORM O}�OPINION OF BOND COLJNSEL...........................................................D-1 APPF,NDIX E - FORM OF CON"I'INUING UISCI.OSURE AGRLLMENT..................................... r-1 AYPT:NDIX F - D1'C AND TIIE BOOK-EN"fRY ONLY SYSTEM ..................................................I�-1 APPENDIX G - SPECIMGN I�INANCIAI.GUt\RANTY INSURANCE POLICY............................G-1 u�uzy.Nos-a Iv CI7'ti'AI�D DIS'1'RIC'I'I�'IAY o�u�y�.�,�-a �� OFFICIAL S'fA7�H:�1H:N7' $10,720,000* CI'CY OF PALVI DF:SF,RT COM;�IUI�ITY FACl1.ITIES DISTRIC'1' NO. 91-1 (INDIAI� RIDGF, PUBLIC IAIPROVEMF.nTS) SYECIAI.TAX REFUNUING BONDS SERIES 2008 1 VTRODt1CTION This introduction conlclin.c onl1�u hric�/summcriy ��/'certuin u/thc� tcrms orthc Scric�.c ZO(JR Bunc/s hc�ing c�rrc�,'cd, nnd«f tll rerie�ir shottld he�m�rcte n/thc�e�nlirc� O/%iciul Stutem�nt inch�c/ing t{re cui�c>r pugc�, the tuhle� uTconte�nt.s und thc appc�nclicc�.c for u more comp/c�tc�descriptrnn o/�the terinc o/thc� Sc�ries 1U08 Boncls. A!! slcrtemc�nt.c cont�ined in tltis introductiun ctre quuliJicrl in lheir entiret}� h,ti� rc./��rencc to Ihc� cntirc�OJJiciul Stutement. Rc�rerence�.c to. und sununnries oJ prorisiun.c u/: unr oth�r clucum�nts �•c-/�rred tu here�in rlo not p�upo�•t[o hc�canple�te und.circh rc/i>rc�nees urc�yea�liTc�r/in their c nti�•c ti�hr rc�r��r��nc�to thc� co�n/�letc>prori.ciun�ursuch d��cerment.s. General; Authority for Issuance 'I'he purpose of this Official Statement, including the cover page, the inside cover page and thc appendiccs is to furnish information in connection with the sale and dclivcry by thc City of Palm I)cscrt Community Facilities District No. 91-1 (Indian Ridge Public Improvements) (the "District") of $10,720,000* principal amount of City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding Bonds, Series 2008(the"Scrics 2008 Bonds"). The Serie� 200R Bonds are issued pursuant to the provision� of the Mello-Roos Community Facilities Act of 19R2, a� amended, being Chapter 2.5, Part l, Division 2, Title 5, of the Government Code of the State of California (the "Act") and pursuant to a Bond Indenture, dated as of January 1, 2008 (the "Indenture"), by and between the District and Wells Fargo Bank, National Association (the ""Crustee"). The Act was enacted by the California Legislature to provide an alternate method of financing certain public capital facilities and services, especially in developing areas of the State of California (the "State"). Subject to approval by a two-thirds vote of a district's qualified electors and compliance with the provisions of the Act, a legislative body of a local agency may act as the legislative body of a community facilities district, cause such community facilities district to issue bonds and may ievy and collect a special tax within such district to repay such indebtedness. The Series 200R Bonds will be �ecured solely by a pledge of annual special taxes (the "Special Taxes") levicd by thc City (including any prepayment thercof and proceeds from toreclo�ure sales pursuant to thc Indenturc) net of Administrative �:xpensca in an amount not to exceed the Admini�trative 1-:xpenses Priority Cap(each as defined herein)on Taxable Parcels (defined herein) within the District, the Reserve Account established under the Indenture and moncys in ceriain other funds and accounts establishcd under the Inden[ure. See "SECURITY AND SOURCES OF PAYMENT FOR THE SERIES 2008 BONDS." Thc Special "I�axes are included on thc rcgular property tax bill sent to the rccord owncrs of properties within the District. The District has covenanted for the benefit of the owners of the Serics 200R Bonds, under certain circumstances described herein, to commence foreclosure actions against property with delinqucnt Special Taxes and to diligently pursue such actions to completion. See "SFCURIT�'AND SOURCES OF PAl'ME\T FOR THE SER(ES 2008 BONDS Special Tax Authorization"and"— Covenant for Porcc losure." 'Preliminary,subject to change. (17U'_y�pos-�3 P�n•pose The Series 20UR l3onds are bcing issucd to provide tLnds to: (i) to refund and defease all ol�thr outstanding $16,260,000 principal amount of Nalm I�esert Financinb Authority 1997 Rcvcnue Bonds (nssessmcnt Districts No. 92-1 [Tierravista] and 94-1 [Bighorn] and Community Facilitics I)istrict No. 91-1 �Indian Ridge]) (the "Prior Iionds"); (ii) fund a resei•ve account as security for the Series 200R i3onds; and (iii) pay certain costs associated with the issuance of the Series 200R Bonds. See "PLAN OF KFFUNDING"and"I;S I 1�1ATED SUURCES AND USES OP FI;NDS." "l�hc Citv 1�he City of Palm Descrt (the "City") is located in the Coachella Valley and is approximately mid- way bctween the cities of Indio and Palm Sprinbs, 1 17 miles east of I.os Angeles, 118 miles northeast of San Dicgo and 51$ miles southeast of San Prancisco. According to the State Department of Finance, the City population as of January l, 2007 wa� approximately 49,539. Thc Series 2008 Bondc are not an obligation of the City. Por certain information regarding the City, see nPPENDIx B—"GENERAI. INFORMATIO\CONCtR\ING l HE CITY OI�PALM UESERT." 7'he District The District was created in 1992, comprises approximately 641 gross acres and ic located in the northern section of the City. The development within the District iti known as the"Indian Ridbe Country Club" and fcatures two 18-hole golf courses, a sports club with health spa and tennis facilities, a golf clubhousc and a sports clubhouse. The Fiscal Year 2007-08 Assessed Value of thc �l�axable Property in the District is $72R,R3R,545. The Fiscal Year 2007-08 assessed value of Taxable Property-to-outstandinb Special "I'ax lien (in the amount of $15,979,000) as of January 1, 2008 is 45.61:1; and the Fiscal Year 2007-OR acse�scd value of Taxable Property-to-outstanding total direct and overlappinb tax and as�cssment debt within the Uistrict (in thc amount of$21,K80,513)as of January 1, 200R is 33.31:1. There are 1,092 parcels within the District, of which all are developed and 1,063 parcels (representing approximately 97.3%) are subjcct to the Special Taxes. '1'he predominant land use within the District is single-family detached housing. See"THG DISTRICT." Security and Sources of Payment for the Series 2008 Bonds Payments of interest on and principal of the Series 2008 Bonds are to be made solely tcom the proceeds of the Special Taxes authorized to be levied annually by the City Council, acting as the ]egislative body of the District on all Taxable Property in the District undcr and pursuant to the Act and the elrction held in the District on March 12, 1992 (the"Special 'l�ax"). See"SECUKITY AND SOURCES OF PAYME!�T 1��OR THF SERIES 200R BnNDS �I�he Special Taxcs." 'I'HF. SERIES 200R BONDS ARF. I.IM[TED OBLIGA"I'IUNS OF "1'H� DISTRICT PAYnBLL SOL�:LY FROM '1'HE PROCGEDS OF SPF,CIAL "I'AXGS (INCLUDING ANY PREPt�YMENTS TIIERLnI� AND PROCEL:US COI.LF.CTF.D FROM THL SAI.E OF I'ROPF,RTY PURSUAN�' "f0 FORECI.OSUR� PKOVISIONS AS SET POR"1'H IN THE IND�:NTURE FOR UELINQUENCY IN PAYMF..NT OF T(IE SPF.CIAL TAXLS), NET OF T[IE COS"1' TO TI(E C11Y OF ADMINISTRATING THr UISTRICT, AND CERTnIN FUNDS ESTABLISHED PURSUANT TO THE INULN"I�URE AND H�LD BY TH�. TRUSTF.E, AS MORE FULLY DESCRIBED HEREIN. NE[TEiER TEiF. FAiTH ANn CREDIT NOR TIfE GF.NERAL '1'AXING POWER OF THL CITY, THL COUNTY OF RIVF.RSIDE (�'HL-' "COUN'I'Y"), TfiE STATE, OR ANY POLITICAL SUBDIVIS[ON THLREOF, OTHER T}1AN THG DISTRICT, IS PLEUGF.I) TO THE PAYMEN'I' Ol� THE SERIhS 2008 BONDS. '1'H�; S�RII:S 200R BONDS DO NOT CONSTITU'I'1: AN INDEBTEDNLSS OF THE C17�Y, 'I�Fi�: COUNTY, THE u7u�v,p�,s-� 2 STATF. OR ANY I'OL111CnL SUBUIVISION 7�IIEREOF, WI'I'HIN 'I'lIE MEANING OT' ANY CnNS'1'I"1'Ul�[ONAI.OR STATUTORY DF.BT I,IMITi1TION OR RrSTRICTION. Reserve Account. n Reserve Account for the Series 200R 13onds is established under the Indenturc which is required to be maintained in the amount of the Rescrvc Requirement (defined herein). Upon the issuance and delivery of the Series 2008 Bonds, procecds of the Series 2008 Bonds in the amount of$ will be deposited into the Reserve Account, which amount is equal to the Reserve Requiremcnt. Sce "SECURITY AN� SOURCES OE 1'nY'MI-:N"1' fUR TIIL SERIFS 2008 [30��[)S—Rcscrvc Account." Financiul Guaranty Insurance. Yayment of principal and interect on the Serics 2008 Bonds will be insurcd in accordance with the terms of a financial guaranty insurancc policy (the "Financial Guaranty Policy") to be issued simultaneously with the dclivery of the Series 200R Bonds by (thc "Insurer"). See "FINA�CIAL GI:ARANTti' INSI!RAN('L" and APPENDIX G-"SPGCIMEN FINAI�CIAL GI;ARAN l l' INSURANCE POLICY." Risks to Bondowncrs Ccrtain events could at�iect the ability of the City to pay debt service on the Series 2008 Bonds when due and an inve5tmcnt in thc Series 2008 Bonds involve� ri5k5 that should be considered in addition ro other matters described herein in evaluating the investment quality of the Series 2008 Bonds. See "B()NDnWNFRS' FtISKS" for a discussion of certain factors that should be considered, in addition to other matters set forth herein, in cvaluating an investment in the Series 2008 Bonds Continuing Disclosure The District has covenanted for the benefit of Bondowners and 13cneficial Uwners to provide certain financial and operating data relating to the District not later than six months after the end of each Fiscal Year,commencing with the Fiscal Year ending June 30, 2008 (the"Annual Report"),and to provide notices of the occurrcnce of cenain enumerated events, if material. The Annual Report will be filed with each Nationally Recognized Municipal Securities Repository and with any then existing State Repository (collectivcly, the"Repositories"). The notices of material events will be filed with the Municipal Securities Rulemaking Board (the "MSRI3") and to the State Repository, if any. 'l�he specific nature of the information to be containcd in the Annual Report or the notices of material cvents is set lorth in APPENDIX E- "FORM OF CONTINUING DISCLOSURE AGREE�IENT." �fhcse covenants have been made in order to assist the Underwriters in complying with S.E.C. Rule 15c2-12(b)(5). Additional Information This Oflicial Statement contains brief descriptions of, among other thinbs, the Series 2008 Bonds, the security for the Series 200R Bonds, the District, and the Indcnture and certain othcr documents. Such descriptions do not purport to be comprehencive or definitive. All references herein to the Indenture are yualified in their entirety by reference to such documents, copies of which are available for inspection at the office of Trustee in Los An�;cles,California. u�o�y��,os-a 3 NI.AN OH� RH;F[JI�DII�(: Refunding of Prior Bonds A portion of thc procecds from thc sale of the Series 200R I3onds will be used by the District together with othcr available moneys, to establish an irrevocable escrow (the "Escrow Fund") to rcdccm all of thc I'alm Desert Financing Authority 1997 Revcnuc I3onds (nssessmcnt Districts No. 92-1 �'1'ierravistaJ and 94-1 �Bighorn� and Community Facilities District No. 91-1 �Indian Ridge]) in the outstanding principal amount of$16,260,000(the"Prior I3onds")on April l, 200R. "I�hc Prior Bonds were issued by the Palm Desert l�iiiancing /\uthoriry (thr "Authority") in connection with two asscssment districts and the District to purchase separate series of refunding bonds and to rcdeem certain outctanding bonds. The bonds associatcd with the two assessment districts werc previously redeemed lcaving only the Prior Bonds Outstanding, all of which are related solely ro the Uistrict. The proceeds of thc Yrior Bonds were used to rcfinance bonds issued in 1992 and 1995, the proceeds of which tinanccd the construction of various off-site public improvemcnts within the District, includinb street and water facilities, and to pay tees required by public agencies for sewer, water, schools, parks, traffic mitigation and other related fecs, charges and expenses all of which have been completed. See"THF UIS I RICT." The Prior Bonds consist of thc following: "fable 1 $16,260,000 Palm Desert H inancing Authoritv 1997 Revenue Bonds (Assessment Districts No. 92-1 [Tierravista� and 94-1 [Bighorn� and Community Facilities District No.91-1 �Indian Ridge�) Dated Datc: December 11, 1997 Paymcnt or Maturity Date Interest Redemption Date Redemption (October 1) Amount Rate CUSIP�'� A ril 1 Price 200R $1,060,000 5.400 69661 NAYO 2008 100% 2009 1,115,000 5.500 69661 NAZ7 2008 100 2010 1,I R0,000 5.600 69661 NBA 1 2008 100 2011 1,245,000 S.h25 69661NBB9 200R 100 2015 5,705,000 5.900 69661 NBFO 2008 100 2020 5,955,000 6.000 69661 NBL7 2008 100 + Copynght 200R, Amencan Bankers Association. CUSIP data herein is pro�ided by Standard and Poor's, CUSIP Sen�ice Bureau,a division of The McGra��-Hill Companies, Inc. This data is not intended to create a database and does not serve in any ���ay as a substitute for the C'USIP Senice. CL;SIP numbers are pro��ided for reference only. None of the Distnct,the c�ey, en� Flnancing Authority, the Unden�riters or the Finandal Ad�isor take any responsibility for the accuracy of such numbers. Upon the sale of the Series 200R Bonds, the City will apply a portion of the proceeds therefrom, together with certain other available moneys, to establish thc Escrow Fund pursuant ro the Escrow Agreement, datcd January 1, 200R (the "Escrow Agreemcnt") by and among the District, the Financing nuthority and Wells Fargo Bank, National Association, as escrow agent (the "Escrow Agent"). Amounts deposited in the Escrow Fund will be invesred in noncallable direct obligations of the United States, or obligations, thc principal and interest on which are fully and unconditionally guaranteed as to timely pay►nent by the United States of America, which �vhen received will be sufficient to pay the principal ot; interest on o�0���.4,�»-�s 4 and redcmption premium of,the I'rior 13onds. (irant Thornton I.I.P, indcpcndcnt ccrtificd public accountants, as th� Verification ngent, w�ill deliver a repoi-t on the verification of the mathematical accuracy of ccrtain computations based upon certain infonnation and asscrtions providcd to them by the Undeiwriter relatin� to the adcyuacy of the maturinb principal of and interest on the obligations to pay all of the principal ot; interest on and redemption premium on the Yrior Bonds to their respective redemption dates. Sec"VERIFICATION OF MA"fl i[�tAT1C'AL COMPUTATIONS.�� 'l�he Fiscal Year 2007-08 asscsscd value of land and improvements of Taxable Property �vithin the District is $72$,838,545. See also"The District-Dircct and Ovcrlapping Debt-Table 10." F.stimated Sources and l;ses of Funds The estimatcd sources and uses of funds, excludinb accrued interest on the Series 200R Bonds, is sumrnarizcd as follows: Sources of Funds Par Amount of�Bonds............................................. $10,720.000* Transier of Prior Bonds I�und,............................... Lc�.c.s: Net Original Issue Discount.......................... TOTAI.SOUR('C•5................................................ l'ses of Funds [)cposit to thc Fscrow Fund��'................................ Deposit to Resen�c: Account................................... Deposit to Costs of Issuancc I�und'Z'...................... Undcrwriters' Discount.......................................... TnTALUSLS...................................................... ' � See"-Refunding of Prior Qonds." �'' Includes thr fees and rrpenses of Bond C'ounsel and Disclosure Counsel, fees and expenses of thr Trustee, the Financial Ad�isor and the Venfication Agent, printing costs, raung agency fers, thr Financial Guaranq� Insurance Policy premiurn, and other costs related to the issuance of the Sencs 200R Bonds. ' Preliminary,subject to change. '" Preliminary,sub�ect ro change. 0'o?y,pn<-.3 5 Debt Servicc Schedule Scmi-annual debt servicc for the Series 2008 I3onds is sct forth bclow. Table 2 Debt Service Schedule Bond Year Ending Fiscal Year (October 1) Princiaal* Interest 'I'otal Total October 1,200Y F April 1,2009 October 1,2009 April 1, 2010 October 1,2010 April 1,201 1 October 1,2011 April 1,2012 October l,2012 April ], 2013 Octobcr 1, 2013 April 1,2014 Ocrobcr 1,2014 April l,2015 October 1,2015 April l,2016 October 1,2016 April 1, 2017 October 1,2017 April 1,2018 October 1,201 R April 1,2019 October I,2019 April 1,2020 October 1,2020 T�TAL S 10,720,000* *PreGminary,sub�cct ro change. 11711_'9`�riiti•�3 � Projected Debt Service Covera�;e Tablc 3 shows projcctcd annual scheduled debt scrvicc on thc Scries 200H Bonds, without regard to any optional redemption and the net estimated annual coverage. Scc"—Debt Service Schedule" for the schcduled semiannual debt service on the Series 200R Bonds. "rablc 3 Citv of Palm Descrt Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Projected Debt Service Coverage Gross Series Net Srries Le.ss 200R Bonds Gross /.ess Kesene 200$ Bonds [3ond Maximum AdnunistraU�c Net Maximum Debl Annual Fund and Debt '�let Annual Yrar SpecialTax��� Expenses''' SoecialTax�'� Service"�� Co�era¢e�`�� F.amings� Senice"'� Co�•eraYe„� 2OQR $3.365,-370.U0 S(3U.01A).00) $3.3ti,.�7u0U 51.94u.'_8�3.�34 1.7� 1 S(30,49�.�1� 51.909,79?.00 IJ5:1 211(1�) 3,365,�3711.U0 �3o.nOn.0p1 3,33s,a�ono I,IRR.525.00 �';cl:l 1�2.8�O.OU1 1.1�1i,b�3;uU 2vl l 2010 1,3�5.470.OQ (3U.OU000) 3.335;370.011 I.IR�),II�SUO 2.ifl:l (42,KKUU1)) 1.146.14�.U0 '_.91 1 ?(11� 1,36S.47p U11 �30.00D UU) 3,33t,q711.1)O I.I`t7,$�S.11(1 2.81:1 1�2,KRQ00) 1.14�3,6�1�.011 '_.91:1 2U12 3.;A>,.t7ppp 130.00Oi�i�) 3,;;5,�37n.On I,IR7,7?S.uO �.itl:l (�32.KSO.OU) 1.14�3,84i.1�p '.41:1 2U13 1,36�.47UU0 (30.00OOU) 3.33i,�170.UU I.IR7.475.1111 '_}SI:I (-1'_.BRO.UII) 1.1�1�1,iyi011 '_91'I 2014 3.;hi,.170.00 (3U,UUUUO) 3,33?.47uuu I.IKU,�3751)p '.Q0:1 142.xS0n(i� I,I�1nj95.p0 '_.��I:I 2015 3.36>,47U.(�0 (30,UOO U0) 1,33>.47u oo I.I$9.875 0(1 ?2tU l (�32.RR0.00) I,I�tG,9�)S UU 2 91:I 21)�(� 1,36?.47000 (j0,00000) 3.115,47000 1.141.2511.(10 �.80:1 (�32,i�$000) �.I-3K.370.00 '_40:1 ?0l7 3,36�.470.00 {30c1000i1) 3,33i,�70.00 1.183.�50.00 ?.82J 1>3;,KKf)00) naK.57a0U � IdJ 2018 3,36�.470 00 �30.00O.oO) 3.335.�37U.uu �ux.'_uu uu Ih.a?:I (�u�s,�uu oo� viA 2019 3,1ni,470A0 (30 nun U0) 3.33S,47U U0 210,ROU.00 15.8?:I ('-IO,ROO.Op� ��A ?02�I1 3.16>.47p.00 13(I OOO OUl 3.33?.�70.OU ?�1H!J00.00 16.0�3:1 (2�)2i.00p.Up) NiA Tc�ini �a3,�51.1I0oi� 513����,ou000l 5�3,36I.iloAu Si3�ni.no9.aa" 5(I.S35.41'aal SII.�2r,,lm.nn• (11 Represents the Max�mum Tax pursuant to the Rate and Method of Apportionment of Special Taxcs. Sec Ai�i�evoix A- ..R:�i i::�ni��iri nuo oF APPc�rcrumnte�r oF SNeci.a�T.azes... (2) Represcnts amounts paid to the City for ongoing administration and staff nme related ro Distnct operations. (3) Maximum Special Tar Icss Annual City Adnunistration Expenses. (4) Represents gross Debt Service on the Senes 2UUR Bonds(prior to Reserve Fund eamings and c:orpus credits). (5) Represents Nct Maximum Special Tax divided by the Gross Srries 2008 Bonds Debt Srn ice. (6) Assumes an interest earnings rate at 4.00°b and application of the Resen�e Fund balance and interest earnings in final years as offsets to the payment of Debt Service. (7) Represents net Debt Sen ice on the Senes 20QR Bonds(aRer application of Resen e Fund and eamings). (8) Represents Net Maximum Special Tax divided by net Series 20118 Bonds dcbt scn ice. • Prclirninary,subject to changc. Sourccs: Dcl Rio Ad�isc�rs,LLC. q70�9�pu>--3 � THE SERIF,S 2008 BONDS 1)escription of the Series 2008 Bonds The Scrics 200R Bonds will be issued only in fully registered t�irm, without coupons, in thc denomination of $5,000 or any integral multiple thereof�. 7�he Series 2008 Bonds shall mature on thc dates and in the principal amounts and bcar interest at thc rates as set forth on the inside cover page of this Ofticial Statement. The Series 200R l3onds will be dated the date of issuance and delivery, issued in fully rcgistcrcd form, without coupons, and, when issued will be registered in the name of Cede & Co., as nomince for "I�he Depository "1'nist Company, New York, New York ("DTC"), as registered owncr of all Series 2008 Bonds. Ownership interests in thc Serics 2008 Bonds may be purchascd in book-entry fonn only. Purchasers ���ill not receivc certificates representin� thcir interests in the Serics 2008 Bonds purchased. Payments of principal of�and interest on the Series 200R I3onds, will be paid by the 1�rustee to DTC, which is obligated in tum to remit such principal and interest to its DTC Participants for subsequent disbursement to thc beneficial owners of the Serics 2008 13onds. See APPF.NDIx F—"DTC AND THE BOOK- F,N�I KY' ONLI' Sl'STEM." Ownership may be changed only upon thc registration books maintained by the Trustcc as provided in the Indenture. Interest on the Series 200R Bonds will be payable on April 1 and October 1 of each year, comtnencinb October 1, 2008 (each an "Interest Payment Date"). Each Series 2008 Bond will bear interest t�om the Interest Payment Date next preccding the date of authentication thereof unless (i) such date of authentication is an Interest Payment Date, in which event it will bcar intere�t from such date of authentication; (ii) it iti authenticated durinb the period fi�om the day after a Record Datc for an Interest Payment Date to and includinb such Interest Payment Date, in which event it will bear interest f�om such Interest Payment Datc, or (iii) it is authenticated on or priar to the Record Datc for the first Interest Payment Date, in which event it will bear interest from the datc of issuance;proricled, ho�rei•er, that if, at the time of authentication of a Series 200R Bond, interest is in default thereon, such Series 200R Bond shall bear interest from thc last Interest Payment Datc to which interest has been paid or made available for paymcnt thereon. Redemption Provisions Optionu! Redemption. The Series 200$ Bonds maturing on or beforc October 1, 20_ are nut subject to call and redcmption prior to maturity. The Series 2008 Bonds maturinb on or after October 1, 20 are subject to call and redemption prior to maturity and tnay be redeemed, at the option of the District, from any source of funds on any Intcrest Payment llatc in whole, or in part, from such maturities as are selected by thc District and by lot within a maturiry, at thc following redemption prices expresscd as a percentagc of the principal amount to bc redeemed, togcther with accrued interest to the date of redemption: Redemption Dates Redemption Prices October 1, 20 and April 1, 20_ _% October 1, 20_and April 1, 20_ � October 1, 20_and Interest Paymcnt Dates thereafter _ n�n�e��,us-a R F.xlruordinury Redemptrun frum Prc/�u,y�ment i�`the Spccru/ Tuxes. 'I he Series 200H Bonds are subjcct to cxtraordinary redemption as a wholc, or in pai-t on a pru rutu basis among maturitics, on any Interest Payment Date, and shall be redeemed by the Trustee, from 1'repaymcnts dcposited to thc Redemption Account, plus amounts transierred from the Resen�e Account, at the following redemption prices, expressed as a percentage of the principal amount to be redeemed, togcthcr with acc�ued interest to the redemption datr. Redemption Dates Redcmation Prices October 1, 20 and April 1, 20 _% Octobcr 1, 20 and April l, 20 _ October 1, 20_and April l, 20_ _ October l, 20_and Interest Payment Dates thcrcafter _ Redemption Procedures Selectinn of Bnnds fiir Redemption. If less than all of thc Scries 2008 Bonds Outstanding arc to be redeemed, thc portion of any Scries 200R Bond of a denomination of more than $5,000 to be redeemed is required to be in the principal amount of�5,000 or an intcbral multiple thereof. In selecting portions of such Series 200H Bonds for redemption, the Trustee is required to treat such Scrics 2008 Bonds as representinb that nutnber of�Series 200R Bonds of$5,000 dcnominations which is obtained by dividing the principal amc�unt of such Series 200R Bonds to be redee►ned in part by $5,000. Notice of Redemption. The 'frustee on behalf of the District will send (by first-class mail, postage prepaid, or such other meanc accepted to such Owncrs or institutions)notice of any redcmption to �he respective Owners of any Series 200R Bonds dcsibnatcd for rcdcmption at their respective addressca appearing on the Bond Register, and to the original purchasers of the Series 200R Bonds, at least 30 but not more than 45 days prior to the redemption date;p�-u��idecl, ho�reti�er, that ncither failure to receive any such notice so mailed nor any dcfect therein will affect the validity of the proceedings for the redemption of such Series 2008 Bonds or the cessation of the accrual of interest thereon. Such notice will state the date of the notice, thc redetnption date, the redemption place and the redemption price and will designate the CUSII' numbers, the Serie� 2008 13ond numbers (but only if less than all of the Outstanding Scries 2008 Bonds are to be redeemed) and the maturity or maturitics (in the event of redemption of all of the Series 2008 13onds of such maturity or maturities in whole) of the Scrics 2008 f3onds ro bc rcdcemed, biving notice also that further interest on such Series 2008 Bonds will not accrue irom and alter the redemption date. Partial Reden:ption of Series 2008 Bonds. In thc cvcnt only a portion of any Series 200R Bond is callcd for redemption, then upon surrender of such Scrics 2008 Bond, the District is rcquircd to cxccutc and the Trustee is required to authenticate and dclivcr to the Bondowner, at the expense of the District, a new Series 200R Bond or Series 2008 Bonds, in authorized denominations, equal in agbregate principal amount to thc unredeemed portion of the Scrics 200R I3ond or Scries 200R Bonds surrendered. F_ffe�ct of Redemption. From and aftcr the datc fixcd for redemption, if notice of redemption shall have been duly mailed and funds available for the payment of the principal of and interest (and premium, if any) on the Series 2008 Bonds so called for redemption shall have been duly provided, such Series 200R Bonds so called shall ceasc to be entitled to any benefit undcr the Indenture other than the right to receive paymcnt of� the redemption price, and no interest shall accrue thereon from and after the redcmption date specified in such notice. 07(1'_9,Poa-4 9 SF,C[IW'I'Y AVU SOURCES OF PAY1�1F.N7' FOR THF. SERIES 2008 BONDS Genc ral The Serics 2008 Bonds constitute limited obligations of thc Uistrict payment as to both principal and interest and redemption premium, if any, from the Special Taxes levied by the Ciry on land �vithin thc Uistrict, including proceeds from the sale of property collected as result of foreclosure of the licn of the Spccial "1'axes, net of the cost to the City of administering the District, and certain funds and accounts held under the Indenture. TIIE SF,RIES 2008 BONDS ARE LIMITED OBLIGATIO:VS OF THE DIS1'RICT YAYABLE SOLELY FROM TI�E PROCEEDS OF SPECIAL TAXES (INCLUDING ANY PREPAYMEN"CS TIIEREOF AND PROCEEDS COI,I,EC"fED FROM "I'HE SALE OF' PROYF.RTY PURSUAN'1' "CO FORECI.OSURE PROVISIONS AS SET FORTH IN THE INDENTURE FOR DELINQUENCY IN PAYMEI�T OF 7'HE SPECIAL "fAXES), NET OF THE COST TO THE CITY OF' ADMINISTRATING THE DISTRICT, A'.VD CERTAIN F�NUS ESTABLISHED PCJRSUA'.�1T TO THE IVDENTURE AND HELD BY THE TRt1STEE, AS A'IORE FIILLY DESCRIBED HEREIN. NEITHER 1'HE FAITH AND CIi�:DIT NOR TIiE GENERAI. 'I'AXIVG POWER OF TIIE CITY, TIIE COUN"I'Y, TIIE STATE, OR AI�Y POLITICAL SUBDIVISIOn THEREOF, O"I'HER THAV TIIE DIS'1'RICT, IS PLEDGED TO "1'HE PAYMF,nT OF THE SERIES 2008 BONDS. 'I'HE SERIES 2008 BONDS DO VOT CONSTITUTE AN INUEBI'EDNESS OF "I'HE CI"1'Y, TIiE COUNTY, THE STATE OR ANY POLITICAL SUBDIVISION THEIi�OF, WITHIN THE MEANING OF ANY C0�ISTITt1TIONAI. OR STATUTORY DEBT LIMITATION OR RESTRICTION. Except with respect to the l�et Taxes, neither the credit nor the taxing power of the District or the City is pledged for the payment of the Series 2008 Bonds, the interest thereon, or redemption premium, if any, and no owner of the Series 2008 Bonds may compel the exercise of general taxing power by thc District or the City or for the forfeiture of any of their property. The Series 2008 Bonds are not a legal or equitable pledge, charge, lien or encumbrance, upon any of the property, within the District, or upon any of its income, receipts or revenues, except the amounts which are, under the Indenture and the Act, set aside for the payment of the Scries 2008 Bonds and interest thereon, and redemption premium, if any. Neither the members of the legislative body of the District or the City Council of the City nor any persons executing the Series 2008 Bonds are liable personally on the Series 2008 Bonds by reason of their issuance. Although the Special Taxes will constitute a lien on property subject to taxation in the l�istrict, it will not constitute a per,onal indebtedness of the owners of such properry. "I'here is no assurance that the owners will be financially able to pay the Special Taxes or that they will pay such tax evcn if financially able to do so. �I�he risk of nonpayment by pmperty owncrs is morc fully described in"I30NDOWNL•RS'R�Stcs-Collection of the Special 7�axes." Special Tax Authorization Pursuant to the Act, on March 12, 1992 the City Council adopted a resolution establishing the District and calling a special election to authorize the issuance of�bonds and thc levy of the Special Taxes. On March 27, 1992, at an election hcld pursuant to the Act, the landowners who werc the qualified electors of the District authorized (by more than the requisite two-thirds vote) the issuance of bonded indcbtedness in an amount not to exceed $35,000,000 and approved the rate and method of apportionment of thc Special Taxcs to pay the principal of, and intere�t on, and redemption pre►nium, if any, thc authorized bondcd indebtedness. The District i��ucd thc Prior Ronds pursuant to this authorization. Pursuant to Government Code Scction 533fi2.7, the Series 200R Bonds do not reduce the principal n�o�y��,�,-.� 10 amount ol� 13onds that may bc issued pursuant to thc authorization. The Spccial Taxes arc levied according to thc and method of apportionmcnt of�Special "1'axcs (the "Special "l'ax Fornwla") �et forth in Appendix A. 'l�he City Council, as the legislative body of the Di,trict, is requircd ro establish tax rates, and levy and apportion the Spccial 'Caxes against property within the District on an annual basis. Covenunt to Levy. Pursuant to the Indenture, so lonb as any Bc�nds are outstanding, the District is required annually ro levy the Special Taxes, subjcct to the maximum tax rates approved by the landowner voters, against all 'Caxable Property in the District and to make provision for the collection of thc Special Taxes in amounts that, together with other moneys available to the District, will be sufficient to pay the principal of and interest on the Bonds when due, to pay the annual expenses of administcrinb the District, to cure delinquencies in the payment of debt service on the Bonds that have occurred or are expected ro occur in the current tiscal year, and to replenish the Reservc Account to an amount equal ro the Reserve Requircment. In the opinion of Bond Coumel, the Special "t'axes is excepted from the tax ratc limitation of California Constitution Article XII[A pursuant to Scction 4 thereof as a "special tax" authorized by two- thirds vote of�the qualiGed electors as set forth in the Act. Consequcntly, the District has the power and is obligated to cause the levy and collection of the Spccial 'l�axes in an amount detennined according ro the Spccial Tax Fonnula. Thc Act prohibit, thc C'ity (:ouncil, as thc Icgislative body of the Uistrict, from adopting a resolution to initiate proccedinbs to reduce the rate of the Special 1'axes or terminatc the levy of the Special Taxes unless the City Counc;il, as thc legislativc body of the District, determines that thc rcduction or tcrmination of the Special Taxes"would not interfere with thc timely retirement"of outstanding Bonds secured by the Special Taxe,. Munner of Collecrion. The Special Taxes will be collected in the manner and at the same time as nd ti�crlorem property taxes are collccted by the County and, except as described bclow under the caption "I)elinquent Payments of Special Tax: Covenant for roreclosure," shall be subject to thc same penalties and the same procedures, sale and lien priority in the case of delinquency as is provided for ucl i�alorc�m property taxes. "I'axes are levied by the County for cach fiscal year on taxable real property that is situated in the County as of the preceding January 1. Por collection purposes,property is classified either as "securcd" or "unsecurcd" and is listed accordingly on scparate parts of the assessment roll. 'I�he "secured roll" is that part of the assessment roll containing State-assessed public utilities property and real property having a tax lien that is ,ufficicnt, in thc opinion of the County Asse,sor, to secure paymcnt of the taxes. Other property is assessed and collected on thc"unsecured roll." Property taxes on the secured roll are duc in two installments, on November 1 and February 1 of each liscal year. If�unpaid, tiuch taxes become delinquent on I�ecember 10 and April 10, respectively,and a 10"/o penalty attachcs to any delinquent payment. Property on the sccured roll with respect to which taxes are delinquent beco►ne tax defaulted on June 30 of the fiscal year; such property may thcrcaftcr be redecmcd by pay►ncnt of a penalty of l.$% per month to the date of redetnption, together with the defaulted taxc,, the delinquency pcnalty, costs, and a redemption fee. If taxes are unpaid Sor a period of tivc years or morc, the property is subject to auction sale by the County. Property taxes on the unsccurcd roll are due as of thc lien date and become delinquent, if unpaid, on August 31. A 10% penalty attaches to delinquent unsecured taxes. If unsecured taxes are unpaid at 5:00 p.m. on October 31, aii additional penalty of 1.5'% attaches to them on thc first day of each month unti] paid. Thc County has four ways of collecting delinquent unsecured property taxes: (1) bringinb a civil action against the taxpayer; (2) filing a certificate in the office of the County Clerk specifying certain facts in ordcr to obtain a licn on certain property of thc taxpayer, (3) filing a certificate of delinquency for rccord in the County Clerk and County Recorder's ofticc in order to obtain a lien on certain property of o7u'_U p��x-a 11 the taxpaycr; and (4) seizinb and sclling personal proprrty, improvements, or possescory intcrest� belonging or a�sessed to the a��c�sec. Special Tax is not a Pcrsonal Obli�ation Although the Spccial "1'axes constitute a lien on property subjcct to taxation within the District, it does not constitute a personal indcbtcdncss of thc owners of such property. �I�here is no assurance that the owners will be financially able to pay the Special "l�axes or that thcy „�ill pay such tax evcn if financially able to do so. �Che risk of thc property o�vncrs not paying the Special '1'axes is more fully described in "E30NDOWNERS' R�SKS-('ollection oi�the Special Taxes." Special Tax Formula Thc Spccial Tax Fonnula is used to allocate the amount of the Special Taxcs that is needed to be collected cach Fiscal Year from all non-exetnpt parcels within tl�e Di�trict (thc "Taxable Property"), based upon the land use class of the property (i.c�. De��eloped Property, Undeveloped Property, Golf Course Property or Exempt Property), subject to a maximum tax rate (the "Maximum Special Tax") that may bc lcvied against each land uce class. The Special Tax Fonnula is set forth in full in Appendix A. A summary of the Spccial "Cax Formula is set forth below. The City collects the Special Taxes on all 'l�axable Property at a Icvel sufficient to pay the debt service and related administrative costs for the Series 200R Bonds and any Parity Bonds in accordance with the Special Tax Formula as follows: On or prior to August 1 of each Fiscal Ycar, or such other date as may be established by law, the City Council, as thc Icgislative body of the District, is required to deter►nine the amount of Special Taxec to be levied and collected in that Fiscal Year in order to (i) saticfy the amount required in any Fiscal Ycar to pay debt service on all bonds or indebtedness within the District, (ii) pay cost incurred by the City and the District in the annual levy or collection of Special 7�axcs; (iii) other reasonable costs related the administration of the District; (iv) any amounts required to replcnish a reserve fund cstablished for the bonds and (v) thc costs of remarketing, credit enhancement and liquidity fees, including such fees for instruments that serve as a basis of the reserve fund in lieu of cash (collectivcly, the "Special Tax Requirements") for such Fiscal Year. The Special Taxe� are levied as follows until the amount necessary to satisfy the�pecial tax requircmcnt for such Fiscal Ycar has been reachcd. Step l: 'I'he Special Taxes are levied annually fir,t on Developed Property in Classcs 1 and 2 at 100% of� the Assigned Special 'Cax Kate, however, if� such amount exceeds the Spccial Tax Requirement, the levy of Special Taxes on all parccls of I�evelopcd Property in Classes 1 and 2 are decreascd proportionately until the revenues produced equal the Spccial Tax Rcquircmcnt. Step 2: If the revenues produced by levying the Special Taxes pursuant to Step 1 arc Icss than the Special Tax Requirement, the Special 'l�axes are levied proportionately on all Yarccls of Undeveloped Property up to 100"/0 of the Maximum Special Tax Rate to produce abbregate revenues equal to the Special Tax Requiremcnt. Step 3: [f the revenucs produced by levying the Special "1'axes pursuant to Steps 1 and 2 are less than the Special Tax Requircments, the Special "1'axes are levied proportionately on all Parccls of Golf Course Property up to 100% of thc Maximum Special 1'ax Rate to produce aggre�ate rcvenucs equal to the Special "I'ax Requircmcnt. n�o�9,�x„-a 12 Sten 4: If thr rcvenues which may be produced by levying the Spccial 1ax pw•suant to Steps, 1, 2 and 3 arc less than Uie Special "fax Requirement,the Special"1'axes arc levied proportionately on all Parccls of Devcloped Property up to 100% of thc niternate Special Tax Rate to produce revenucs equal to the Special 1�ax Revenues. Although Golf Coursc Property is not an cxempt land use pursuant to the Special "l�ax Fonnula, Special 'Caxes have never becn levied against Golf Course Propeny and the District does not expect that Special'I�axes will be levicd against such property in the futurc. "Che Maximum Special Tax which may be imposed upon property depending upon thc class and land use category is shown in"l�able 4. Table 4 City of Palm Desert Communit,y Facilities District No.91-1 (Indian Ridge Public Improvements) Maximum Tax Rates by I.and Use Category Class Land Usc Assi�ned Spccial Tax Ratc DEVEI.OPED PROPERTI': Dctached Single f amily Residential 1 A O��cr 3,600 squarc fcct �3,R50 per Dwclling Unit 1I3 3,100- 3,599 squarc fcct 3,300 per Dwelling Unit 1 C 2,600 - 2,099 square fect 2,750 per Dwelling Unit 1 D 2,100- 2,599 cquare fcct 2,450 per Dwelling Unit 1 E Under 2,099 square feet 1,650 per Dwelling Unit Attached Residential 2A Over 2,500�quare feet 2,100 per Dwelling Unit 2B 2,100- 2,499 square feet 1,R00 per Dwelling Unit 2C 1,700 - 2,099 square feet 1,500 per Dwelling Unit 2n 1,300 - 1,699 square feet 1,200 per Dwelling Unit 2L Under 1,299 square feet 900 per Dwelling Unit GnLF COI;RSE PROPFR1�1": 1,500 per Net Taxable Acre UNDEVI:LOPED PROPI-:R I Y: 13,120 per Net Taxablc Acre Source: Ri�erside Counry 2(106-(17 Secured Tas Roll for the 1=iscal Year 2006-07 Assessed Values, as compiled by !vluniFinancial. Pursuant to Section 53340 of the Act, the Special "Cax Formula exempts propertics that are or are intended to be publicly owned (i.c. road,, common area,, and property owncd by State, fcderal or other local governments and approximately 3.1 acres designated as well sites); exccpt that the Special Taxes on property not otherwise cxempt that is acquired by a public entity shall be required to be permanently satisfied pursuant to Sections 53317.3 and 53317.5 of the Act. Parcels for which the owner has prepaid and satisfied the Special Taxes are also exempt from further Special Taxes. See"BONDOW\FRS' RISKS- �:xempt Properties." n�n2U�poc--1 13 7�able 5 below shows the Maximum Special Tax Kcvenue for Fiscal Year 2007-OR based on thc Maximum Spccial Tax for cach land use catego�y. Scc also"'I�HE DlS1 KICl—Slatus of De�elopincsit.�� Table 5 City of Palm llescrt Community Facilities 1)istrict No. 91-1 (Indian Ridgc Public Improvcments) Maximum Special Tax by Land Use Categor,y (As of the l�'iscal Year 2007-08 Secured Tax Roll) Assessed Value Maximum Soecial Tax Number of l axable ParcelslAcres 1ota1 Value Pcrcent��' Amount I'ercent��' lleveloped Propert,y Detached Single Family Residential Over 3,600 square fect 94 $114,836,228 15.16% $361,900 10.75% 3,100 - 3,599 square feet 25R 207,946,251 27.46 851,400 25.30 2,600- 2,099 square feet 294 197,305,697 26.05 808,500 24.02 2,100- 2,599 ,quare feet 195 108.603.855 14.34 477,750 14.20 Under 2,099 square feet 3 1,455,966 0.19 4,950 0.1� nttached Rcsidential Over 2,500 square feet 0 0 0.00%, 0 0.00 2,100-2,499 square feet 132 61,422,492 8.11 237,600 7.06 1,700 - 2,099 square feet 77 33,703,615 4.45 115,500 3.43 1,300- 1,699 square feet 10 3,Sh4,441 0.47 12,000 0.36 Under 1,299 square feet 0 0 0.00 0 0.00 Golf Course Property''' 29 _ 28,465,203 3.76 495,870 14.73 �I�O1AL 1,092 $757,303,74R 100.00`% $3,365,470 100.00% (1) Column figures do not rotal due to rourxiing. (2) Represents approximately 330.6 acres. Pursuant to the Special Tax Fomiula, Special Taxes ha�e never been lerird against Golf Course Property and are not expected to be levied against such property in the future. Sources: Ri�erside Counry 2007-OR Secured Tax Roll for the Assessed values and acreage,as compiled by MuniFinancial. Reserve Account "1'he Series 2008 Bonds are secured by a Rcaerve Account in an amount equal to the "Reservc Requircmcnt," which is held by the Trustcc in trust for the owners of the Series 200R 13onds, solely for the purpose of paying the principal of(including sinking fund payments) and intere�t on the Series 2008 Bonds. The "Reserve Requirement" is defined in the Indenture as that amount, as of any date of� calculation, equal to the lesser of: (i) 10'% of the initial principal amount of the Series 2008 Iionds; (ii) Maximutn Annual Debt Scrvice on the Outstanding Scries 200R Bonds; and (iii)125"/0 of the average Annual Debt Service on thc Series 200R Bonds. Exccpt as othenvise provided in the Indenture, moneys in the Reaerve Account �hall be used solely for the purpose of paying the principal of, including Sinking Fund Payments, and interest on the Scries 2008 Bonds and any parity Bonds when due in the event that the moneys in the Interest Account and thc Principal Account of the Special Tax Fund arc insufficient thercfor or moneys in the Redemption Account of the Special Tax Fund are insufficient to make a Sinking Pund Payment whcn due and for the pu�pose of making any required transfer to the Rebate Fund pursuant to the Indenturc upon written dircction from the District. [f amounts on deposit in the Reserve Account arc lcss than the Reservc Rcquirement, after making the reyuired transfers ro the Adminish�ativc rxpenses Account, the Interest Account, the Principal Account and the Redc►nption Account of� the Special Tax u7o_'9.po,-a 14 I�und, the Trustcc is required to hansfer to the Reserve Account from available moneys in the Special Tax I�und, or 1�rom any other legally available Cunds desi�.nated hy tk�c District, the atinouslt lticcdcd to resiore the amount on deposit in thc Reser��e nccount to the Rcscil•c Requiremcnt. If amounts on deposit in the Special "I'ax Fund together with any other amounts transferred to rcplenish the Rescn'e Account are inadcyuatc to restore the Reserve Account to the Rcscrve Requirement, then the I)istrict is rcquired to include the amount necessary to fully restore thc Reserve llccount to thc Resen�e Requirernent in the next annual Special Tax levy to the extent of the maximum prrrnittcd Special Tax ratcs. If, on the first day of the final Bond Year the amount on deposit in the Rcscrve Account is equal to the Reserve Requircment for the Series 2008 Bonds or any Parity l3ond�, the amounts in the Reserve Account may be applied to pay the principal of and interest due on the Series 200R Bonds and Parity Bonds, as applicabl�, in the final Bond Year for such issue. Moneys in thc Kese»�e Account in cxcctis of the Reserve Requirement not transferred in accordance with the Indenture are required to be withdrawn from thc Reserve nccount on the Business Day before each April 1 and October 1, and transferred to the Interest Account of the Special Tax Fund; provided, howcver, to the extent that, as of a date 90 days prior to the next occurring Interest Payment Date, the amount on deposit in the Reserve Account is equal to or greater than the aggregate remaining principal paymcnts to be paid on the Bond� and any Parity Bonds, any and all amount� in the Reserve Account may be applied to effect a redemption of all Outstandin�; Bonds pursuant to the Indenture and any Outstanding Parity Bonds in accordance with any Supplcmcntal Indenture.. Deposit of SQecial"I�ax; Flow of Funds Pursuant to the Indcnture, on each datc on which the Special Taxes are rcceived from the District, the Trustee is required to deposit such Special Taxes in the Special Tax Fund and such amounts are to be allocated in the followinb order of priority: First: to the Administrative Expenses Account of the Special Tax Fund - from time to time, the Trustcc is required to transfer ro the Administrative Expenses Account for the payment of any administrative costs with respect to the calculation and collection of the Special Taxcs, includinb all attorneys' fees and other costs related thereto, the fees and expenscs of the Trustee, any fec� and relatcd costs for credit enhancement for the Series 200R Bonds or any Parity Bonds which are not otherwise paid as Co,ts of lssuance, any costs rclated to the compliance by the District with state and federal laws requiring continuinb discfosure of infonnation concerning the Serics 2008 Bonds and the Uistrict, and any other costs otherwise incurred by the City staff on behalf of the District in order to carry out the pu�poses of the District as set forth in the Resolution of Formation and any obligation of the District under the Indenturc (collectivcly, the "Administrative Expenses") as set forth in the Certificate of an Authorized Represcntative of thc District; prurirlc�d, hotire�rcr, that, except as set forth in thc following sentence, the rotal amount transferred in a 13ond Year may not excced an amount equal ro $ per Bond Year, escalating by 2%each Bond Year commencinb July 1, 200R (thc"Administrative: F.xpensc� Priority C:ap") until such time as there has been deposited to: (i) the Interest Account and thc Principal Account an amount, rogether with any amounts already on deposit therein, that is sufficicnt to pay the interest and principal on all Series 200R Bonds and Parity Bonds duc in such Bond Ycar; (ii) the Redemption Account an amount, together with any amounts already on deposit thercin, that is sufficicnt to �call and redeem '1�e�7n Bonds in accordance with the Sinking Fund Payment schcdules tiet forth in the Indenture and to] redeem Parity Bonds in accordance with any Sinking Fund I'ayment schedule in the Supplemental Indenture for such Parity Bonds; and (iii) to the Reservc Account an amount, together with any amounts already on deposit therein, that is �ufficient to restore the Resen�e Account to the Resen�e Requirement. Notwithstanding the t��regoing, amounts in excess oi the Administrative Expenses Priority Cap may be 0 7a?�,.pi,s--3 15 h•ansfen�ed to thc Admini�h�ative Expcnses Account to the extent nccessary to collect delinyucnt Spccial "T'axes. Second: the Interest Account of the Special 1�ax Pund, an amount such that the balance in the Interest Account five Business Days prior to each Interest Payment Uate will be equal to the installment of interest due on the Serics 2008 Bonds and any Parity Bonds on tiaid Interest Payment Uate and any installmcnt of interest due on a previous Intcrest Pay►nent Uate which remains unpaid; 7hird: thc Principal Account of the Spccial Tax Fund, the amount nceded to make the balance in thc Redemption nccount five Ausincss Days prior to each Ocrober 1 cqual to the Sinking Fund Payment due on any Outstanding I3onds and Parity Bonds on such October 1; provided, however, that, if amounts in the Spccial Tax Fund are inadequate to tnakc the foregoing transfers, then any deficiency shall bc made up by an immediate transfer from the Reserve Account, if funded; Fourth: the Redemption Account of the Special 'l�ax Fund .olely for the purpose of�rcdeeming BondS and Parity E3onds and �hall be applied on or after the rede►nption date to the payment of principal of and premium, if any, on the Bonds or Yarity Bonds ro bc redeemed upon presentation and currender of such Bonds or Parity Bonds and in the case of an optional redemption or an extraordinary redemption fi�om Prepayments to pay thc interest thereon; provided, however, that in lieu or partially in lieu of such call and redemption, moncys deposited in the Redemption Account, othcr than Prepayments, may bc uscd to purchase Outstanding Bonds or Parity Bonds in thc manner providcd in the Indcnture; Fifth: the Reserve Account of the Special Tax I�'und solely for the purpose of paying thc principal of, including Sinkinb I�und Payments, and intere5t on the Bond, and any Parity Bondti when due in the event that the moneys in the Interest Account and thc Principal Account of thc Special Tax Fund are insufficicnt therefor or moneys in the Redemption Account of the Special Tax Fund are insufficient to make a Sinking Fund Payment when due and for thc purpose of making any required tran�fcr to the Rebate I�und pursuant to the Indenture; Sizth: the Rebate Fund, for payment to the United States"I'reasury; and Seventh: thc Surplus Fund, aft�r making the transfers describcd in paragraphs H'irst through Sixth, the "I'rustee ia required 10 transfcr all remaining amount, in the Special Tax Fund to the Surplus I�und, which amounts may be transferred by the 1�rustee at the direction of�an Authorized Representative of the District to: (i) the Interest Account, the Principal Account or the Redemption Account of the Special Tax Fund to pay the principal of, including Sinkinb Fund Payments, premium, if any, and interest on thc Series 200R Bonds and any Parity Bonds when duc in the evcnt that moncys in the Special Tax Fund and the Rcserve Account of the Special "1'ax I�und are insufficient therefore; (ii) the Reserve Account in ordcr to replenish the Reserve Account to the Reserve Requirement; (iii) the Administrative Expenses Account of the Special Tax Fund to pay Administrative Fxpenscs to the extent that the amounts on depo�it in the Administrative I:xpcnses Account of thc Special Tax Fund arc insufficient to pay Administrative �xpenscs; or(iv)to thc I�istrict ior any other lawlul purpose. Covenant for Foreclosure Generul. Thc Indenture provides that the Special 'I'axes are to be collected in the same manner as ordinary ucl rulorem property taxes are collected and, except as provided in thc special covcnant for foreclosure described below and in the Act, are subject to the same penalties and the same procedure, sale, and lien priority in case of delinquency as is provided for url rnlorc�m property taxes. Pursuant to Section 53356.1 0l� the Act, if any payment of the Special Taxes for a parcel of 'I'axable Property i� delinquent, the District may order the in.titution of a court action to foreclose the lien u�n��,�,,,,a 16 on thc Taxablr Property within speciticd timc limits. In such an action, the rcal property subjcct to thc unpaid amount may be sold at judicial forcclosure salc. The ability of the District to foreclosc the licn of delinquent unpaid Special �l�axes may be limited in ccrtain instances and may requirc prior consent of the property owncr if the property is owned by or in reccivership of the Fcderal Dcposit Insurancc Co�poration(thc"FDIC"). See"Bc)NnOwNERS'RISKS -Bankruptcy." Such judicial foreclosure action is not mandatory. However, the District covenants in the Indenture for the benefit of the nwners of the Series 2008 Bonds and any Parity I3onds that it wilL (i) commence foreclosure actions against parcels with at least four dclinquent installments of Spccial 'l�axes which total in the aggregate at least $6.000 by the October 1 t�illowing the close of each I�iscal Year in which such Special Taxes were duc; and (ii) co►nmence foreclosure actions against all parcels with delinquent Special 1�axes by the October 1 following the close of each Piscal Year in which it receives Special Taxes in an amount which is less than 95"/0 of thc total Spccial Tax lcvied and the amount on deposit in the Rese�ve nccount is at less than the Reserve Kcquirement, and (iii) diligently pursue such foreclosure proccedings until the delinquent Special Taxes are paid, and in no event will such foreclo�ure actions exceed the time periods specified in Scction 53356.1 of the Act. The District is required to deposit the net proceeds of any foreclosure in the Spccial 'l�ax Fund and apply such proceeds re►naining after the payment of Administrative Expenscs to make current paymcnts of principal and interest on the Scries 200R Bonds and any Parity Bonds, to bring the amount on deposit in the Rescrve Account up to the Rescrve Reyuirement and to pay any delinqucnt installments of�principal or interest duc on the Scries 2008 Bonds and any Parity Bonds. "l�he District may elcct (but is not obligated) to advance the amount of any particular delinquency (excluding pcnalties and interest) and deposit such amount to the Special Tax Fund. Upon a deposit of such money in the Special Tax Fund, the District need not initiate a foreclosure action as provided abovc; proi�idc�t, hoirei�c>��, the District may reimburse itself for such advance when the Special 1'axes on such property ia paid in the amount of such advance plus interest on such amount at a rate equal to thc yield on the Outstanding Series 200R Bonds. Interest and penalties paid in cxcess of�thc a►nount advanced by the District shall bc deposited in the Special Tax Fund. Subjcct to the Maximum Special Tax Rate, the Special Tax Formula is designed to gcnerate from all non-exempt property within the District the current year's debt service, Administrative Expenses, and replenishment of the Recerve Account to the Re�erve Requirement, including an amount eyual to the prior year's delinyuencies. Ilowever, if foreclosure proceeding arc necessary, and the Reserve Account has been depleted, there could be a delay in payments to Bondowners pending prosecution of the foreclosure procccding� and receipt by the City of the proceeds of the foreclosure sale. Sec "BONDOWNf-:RS' RIShS- Bankruptcy." Priority of Lien. "I'he Act specifies that the Spccial Taxes will have the same lien priority as u�t��ul��rc�m property taxes in the case of delinquency but does not further specify the priority relationship, if any, bctween the Spccial Taxes and other special taxes and ad valorem taxe� on a taxed parcel. The City (and other jurisdictions) may lcvy additional special taxes to financc other infrastructurc needed for development in the arra. See "SC•C'I;RITY AND SOURCGS OF PAYMENT FOR TIIE SF'.KIGS 200R BONDS- Issuance of Additional Bonds," "TIiE DISTKICT General" and "-Direct and Overlapping I)ebt," and "BONDOWNERS' RISKS-Parity Taxes and Special Assessment�." If foreclosure proceedinbs were ever instituted, any holder of a mortgage or deed of trust on the affccted property could, but would not bc required to, advance the amount of the delinquent Special 'l�ax paymcnt to protect its security interest. n�u�v��,�„-a 17 Suffrciency �f'Foreclosure Sulc Procecds. No assurances can bc given that thc rcal property subject to a judicial Corcclosure salc will be sold or, if.old, that the pr�ceeds of salc �vill be sufficicnt to pay any delinquent Special Tax installment. The Act does not require the City to purchasc or othen�isc acquirc any lot or parcel of�property sold if therr is no other purchaser at such sale. Section 53356.6 of the Act requires that property sold pursuant to foreclosure under the Act be sold for not less than the amount of judgment in the forcclosure action, plus post-judgmcnt interest and authorized costs, unles� thc conscnt of the owners of 75'% of the outstanding I3onds is obtained. Limited Obligation Neither the full faith and credit nor the general taxing power of the Ciry, thc County, the State, or any political subdivision thereof; other than the District, i, pledged to the payment of thc Series 200R [3onds. The Series 2008 I�ondc are not beneral obligations of the City but are limited obligations of the Uistrict payable sole�ly from the proceeds of the Special Taxes (net of the City's costs of administerinb the District) and other sources described in the Indcnture. �I�he Series 200R Bonds are secured by a pledge of and lien upon the Special Taxes and from amounts on dcposit in the Interest Account, the Principal Account, and the Reserve Account. Amounts on deposit in the Costs of Issuance Fund and the Rebate Account are not pledbed ro the payment of the Scries 2008 Bonds. Moneys held in any of the accounts or special funds under thc Indenture are required to be invested at the���ritten direction of the District only in Authorized Invcstments,as defincd in the Indcnture. Issuancc of Parity Bonds Under the Indenture, the District may at any time issue one or more series of Bondc payable f�om the Net Taxes and other amounts deposited in the Special Tax �'und (other than in the Administrative Expenses Account therein) and sccured by a lien and chargc upon such amounts equal to the lien and charge securing thc Series 2008 Bond, and any other Parity [3onds, provided, howevcr, that Parity Bonds may only be issued for the purpose of refunding all or a portion of the Series 2008 Bonds or any Parity Bonds then Outstanding. The issuance of Parity F3onds are subjcct to the conditions contained in the Indenture, including the following: (1) The District is be in compliance with all covenants set forth in the Indenturc, and a certificate to that effect is filed with the Trustee; (2) The issuance of such Narity Bonds has been duly authorized pursuant to the Act and all applicable laws, and the is�uance of such Parity Bonds has been provided for by a Supplemental Indenture, in the fot7n and satisfying the requirements specified in thc Indenture,duly adopted by the District; (3) The District has received the following documents or money or securities, all of such documents dated or cenificd, as the casc may be, as of the date of delivery ol�such Parity Bonds by the 'l�rustee (unless the Trustcc shall accept any of such documents bearin�, a prior date): (i) a certificd copy of thc supplemental indenturc authori�ing the issuance of the Parity I�onds; (ii) a written request of the Uistrict instructing the delivery thc f'arity Bonds; (iii) an opinion of Bond Counsel and/or general counsel to the District in the foren and content specified in the Indenture; u�u�y��us-a 1R (iv) ccrtificatcs of thc District, thc lndcpendent Financial Consultant, in the casc of a refunding, and thc Special 1�ax ndtninisu•ator, as applicable, in the forn� and a� describcd in the Indcnture. See al`o APPLNDIX C-"Sl!MMAR�'OF PRINCIPAI.I.FGAL DOCUMh:\'TS- " FII�ANCIAL GUARAVIY INSURANCE �lt� %!loi+•ing rn�ormcition hrr.s hc�crn %t�rnishc�d hJ� 11tc� In.tiw•er for tr.cc� in lhis OJ�c•icr! Stc�tc�mc�nt. Re%rcnce is mctrle to �1PPE,�'DIx G��r u .�pecimc�n o(thc�/inunciul gucn-unn� inst�rnnee pulic►� to he� i.s.cuc�c/ ht� thc Insurer. The Di.ctricl mukc�.c nn reprc�sent�rtions us to tl�e crccuruc�� or cunrplelC'I1C'SS U� Ij1l.0 inja•mution or u.c tu t/ic� crhscncc o%mutc�riul adi�cr.ce clran�,Je�s in thi.c in%n��m��iort suhseyiu�n� ro th�� cicuc� !Jc�'�ur . [TO COMI-:] TIIE DISTRICT (:eneral; I.ocation The District is located in the northern section of the City known at the time of fonnation as the "Indian Ridge Country Club." The land within the District is divided into 1,092 parccl�, of which 1,063 Taxable Parcels are owned by/1,057J individual parties and is roughly bordered by Country Club Drive to the north, by Oasis Club Drive and Palm Desert Redevelopment Agency Projcct Area No. 4 to the cast, Hovley Lane to the south and �l Dorado Drive to the west. Thc District contains a total area of approximatcly 641 �;ross acres and is located minutes from Interstate Hi�;hway ]0 and State Highway 1 1 1 and is ncar La Quinta, the Bermuda Dunes private air��ort, Rancho Mirage, Indian Wells and the City of Palm Springs. The District has no contro] over the amouni of additiona] debt payable frorn taxes or asscssments on all or a portion of the property within the Di�trict that may be i��ued in the future by other govemmental entitics or districts, including but not limited to school districts, water districts, or any othcr district having jurisdiction over all or a portion of the land within the District. Nothing prevents the owners of land within the District from consenting to the issuance of additional debt by other public agencies that would be secured by taxes or assessments on a parity with the Special Taxes. To the extent such indebtedness is payable from asscssments, othcr spccial taxes levied pursuant to thc Act or uc!i�crlo,•c�m properly taxes, such assessments, speeial taxes and ad rula•em property taxes will have a lien on the property within the District on a pariry with the lien of the Special Taxes. See "BONDOWNERS' RISKS-Parity Taxes and Special nssessments." Status of Uevelopment The District was fo�mcd in 1992. Ucvelopment within the District was undertaken by Sunrisc Desert Partners, a Califomia l.imited Partnership (the "Dcvcloper") as a planned communiry containing approximately 1,137 attached and detached single family homes, two Arnold Pal►ner Championship designed 18-hole bolf courses, and an approximately 22,000 �yuare foot sportc clubhouse, featuring a full service restaurant, a health and fitness spa, a 14-court tennis facility, a golf clubhouse and a sports clubhouse. Two casual dining restaurants and a snack bar are al�o located in the facilities. u�u�vy,,,<.a 19 /�II of the parccls �vithin the I)istrict are currcntly devclopcd, including l,Ofi3 sin�;le family residences, all of� which are o���ned by individual property owncrs and 29 parcels (representing approximately 330.6 acres)of Golf Course I'roperty. Land LJse Classifications 'I'he land within the Uistrict is zoned for residential and commercial/industrial developmcnt. 1'he property classifications within the District by land usc category is as of the Piscal Year 2007-08 secured tax roll and is set forth in 1�able 6 below. "1'able 6 City of Palm Desert Communit,y F'acilities District No.91-1 (Indian Ridge Public lmprovements) Property Classification B,y I.and Use Categories Fiscal Year 2007-08 2007-OR Assessed Value Maximum Svecial Tax Number of %of Total Land Use Cate�ory Parcels Parcels Total %of"l�otal Lien"�* Perccnt* Developcd Recidential 1,063 97.34'% 728,838,545 96.24% $9,140,510 100.00%, Developed Golf Course' 29 2.66 28,465,203 3.76 1,579,490 0.00 "CoTn� 1,092 ]00.00% $757,303,748 ]00.00% $10,720,000 100.00% • Prelirninary,subject to change. i Rcpresents approximatrly 330.G acres. Pursuant ro thc Special Tax Portnula, Special Taxcs ha�e never bccn levied against Golf Course Property and are not expectrd ro be le�icd against such property in the future. Sourcrs: Ri�erside County Piscal 1'car 20117-OR Secured l ax Roll for the Assessed Values,as compiled by MuniFinancial. See �l�able 1 under the caption "SECI.'RITt' AND SOURCF.S Of PAl"MF.NT �OR IHF. SERIES 200R TiONDs Special 'I'ax Formula" which scts forth the Maximum Tax for each land use category. Value of the District "I�he gro5s a��essed value of land and improvements of Taxable Property within the District for ri5cal Year 2007-08 is $728,838,545. Upon the refunding of the Prior Bonds, a abgregate Special Tax licn in the amount of$10,720,000* will be recorded against Taxable Parcels within the Di�trict resulting in an assessed value-to-Special Tax lien ratio equal to 67.99:1* and the assesscd value-to-outstandinb total direct and overlapping tax and assessmctit debt within thc District (in thc amount of$16,621,513) will be eyual to 43.R$:1*. See also"-Direct and Ovcrlapping Dcbt." '" Preliminary,subject to change. n�n�U�.p�,.-a 20 1�his amount may not be representative of thc actual market ��aluc of the property in the Uistrict, howcvcr, since Article XIIIA of the California Constitution limits any incrcase in a�sesscd value to no more than 2% per year unless propei-ty is sold or U•ansfcrred. As a consequencc, assessed values arc typically less than actual market valucs unless the property has recently changed ownership. This value docs not account for any reassessmcnts based on changes in owneiship or improvemcnts to property occun�ing after January 1, 2007. /1 summary of the assessed valuc of Taxablc Propeny-to-special tax lien categories, including the Series 2008 Bonds, is set f��rth in"1'able 7. "1'able 7 City of Palm Desert Community Facilitics Uistrict No. 91-1 (Indian Ridge Public Improvements) Asscssed Value of Taxable Property-to-Special Tax I.ien Categories As of the Fiscal Ycar 2007-OS Secured Tax Roll Value-ro- Assessed Value Spccial Tax Lien* Special 'I'ax 'I'axable Licn Cates�ory Propertv t�mount Percent' Amount Percent 10:1 and Greater 1,Ofi1 S72R,770,RR3 6R.12`Y, 510,698,520 99.R0% 5.1:1 to 9.9:1 1 47,R97 5.23 9,152 0.09 3.1:1 to 4.9:1 0 0 0.00 0 0.00 1.1:1 to 2.9:1 1 19,765 1.60 12,328 0.12 Icss than 1:1 0 0 0.00 0 0.00 �I�OTAL 1,063 �728,R3R,545 100.000"/0 $10,720,000* 100.00% Agbrcgate nssessed Value of Taxable Propcny-to-Special 'l�ax Lien Ratio: 67.99:1* t ('olumn does not total due ro rounding. • Prelinunary,subject to change. Sources: Ri�crside C'ount��2(l(17-08 Secured Ta� Roll for the Assessed Values,as compiled by'vluniFinancial. 071124�.�os-a 2� The following'I abic R �ets forth the top ten property o�vners by assrsscd valuation and prorated lien. Table 8 City of Palm Uesert Community Facilitics District vo. 91-1 (Indian Ridge Public Improvements) '1'op Ten Property Owner's BV Assessed Valuation and Prorated I,ien (As of the Fiscal Year 2007-08 Secured Txx Roll) Valuc-to- Parcels Assessed Value Prorated I.ien'�' I.ien Property Owner Owned Amount Percent�'� Amount Percent�'' Ratio��� Lopcz,Joseph A.and Patricia A. 2 $3,687,467 0.51% $24,656 0.23% 149.56:1 Chiuminatta,Ldward R.and Charlottc M. 2 3,4b1,O51 0.47 26.710 0.25 129.SR:1 Braden,Denver and Loritta M. 2 3.196,816 0.44 26,710 0.25 119.6R:1 Hoffman,Peggy Moorc 2 2,595.119 0.36 21.480 0.20 120.R 1:1 Fusco Prop. 2 2,298,977 0.32 19,052 0.18 120.67:1 Michael,,'�ola 2 1,933,409 0.27 22,601 0.21 85.55:1 945 Miner�Ridge C't. 2 1,727,500 0.24 20,546 0.19 R4.08:1 Schocnlaub,Peter and Lori 2 1,617A68 0.22 19,426 0.1 ft 83.24:1 Eilef�on,Gary L.and fiarbara A. 2 1,478.050 0.20 15,R77 0.15 93.10:1 Cate,Moniyue 2 1,343,004 O.1R 21,480 0.20 62.52:1 Su�r�rra,i_ 20 23.33R,461 3.20 218,539 2.04 lOG.79:1 Othcr Taxable Property 1,04,i 705,SOO,OR4 96.80 10,501,461 97.96 69.89:1 Tc�TAI."f,�xnHt.t:Pkc�i�t:k i v 1.063 $728,838.545 100.00`%i $10.720,000 100.00"/0 70.G4:1 (I) Preliminary,subject to changr. (2) Column does not total due to rounding. Source: Riverside Counry 20(X�-07 Secured Tax Roll for the Piscal 1'ear 2UU6-07 Assessed Valurs,as compiled by MuniFinancial. Secured I'roperty Tax Levies,Collections and Delinquencies t�istorically, delinquencies for each property tax in�tallment period arc higher immediatcly following the respectivc installment paymcnt due datc. Late payments received after the respective due date reduce the outstanding delinquencics for each installment period, to a level of approximately 0% aiter 1 R months. For thc 2006-07 Fiscal Year, Special "I'axes in the amount of$2,020,198.40 were Ievicd against 1,063 parcels in the I�istrict. ()f this amount, an aggregate of $17,265.60 for 19 parcels are currently delinquent (rcpresenting O.RS% of the abgregate amount of Special Tax levied in the District and 1.89"/0 of the parcels levied). While the City currently reccives 100"/0 of its tax levies, under thc Tcctcr Plan with the County the Special Taxes for the I)istrict are not included in the "[�cctcr Plan. Therefore, delinqucncics in the paymcnt of Special Taxes may have a material adverse effect on the ti►nely payment of principal of and intcrc�t on thc Series 200R Bonds. Sce "BUNDOWNERS' RISKS-Collcction of Special Taxe�." n�o�v,�„„-a 22 Sct ti>nh in Tablc 9 is a summary of payment history f�r taxes levicd in thc District for the past tive riscal Years. Table 9 Citv of Palm Desert Communitv Facilities District l�o. 91-1 (Indian Ridge Public Improvements) Historical Specia!"I'ax Delinyuencyr Fiscal Year/ nmount %Amount Yarcels Parcels Yarcels Installment Dollars Levied Delinquent Delinquent Lcvicd Delinguent'�' DelinUuent'�� 2003-04 - 1 $1,015,401.17 0.00 0.00 1,047 0 0.00% 2003-04 - 2 1,015,401.17 0.00 0.00 1,047 0 0.00 2Q04-OS- 1 1,013,093.22 0.00 0.00 1,048 0 0.00 2004-OS - 2 1,013,093.22 0.00 0.00 1,04R 0 0.00 2005-06- 1 1,016,566.R6 0.00 0.00 1,063 0 0.00 2005-06 - 2 1,016,566.86 974.20 0.10 1,Ofi3 1 0.09 2006-07 - 1 1,010,099.20 7,304.00 0.72 1,063 8 0.75 2006-07 - 2 1,010,099.20 9,961.60 0.99 1,063 1 1 1.03 2007-08 - 1 1,01 1,223.13 ''' N/A 1,063 ''' N/A 2007-08-2 1,01 1,223.13 '�' N/n 1,063 'Z' N/A � Amount delinqucnt as of October 31,2007. ''' Property taxes are due in t��o installments and become delinquent on December 10 with respect to the installment due on No�cmber 1,and on Apnl 1(1 with respect to the installment due on February I. Suwre Ri�erside Counry 2Ui�f�-07 Secured Tax Roll for the Piscal Year 2006-U7 Assessed Values, as compiled by �tuniPinancial. Direct and Overlapping Debt Contained within the boundaries of the District are numerous overlapping local agencics providing public scrvices. Many of these local abencies have outstanding debt. The direct and overlapping debt(the"Debt Report")of the District as of January 1, 2008, is shown in thc following table which was prepared by California Municipal Statistics, Inc. 1�he Dcbt Report is included for general information purposes only. "I'he City has not revicwed the Debt Rcport for completeness or accuracy and makes no rcpresentation in conncction therewith. The Debt Rcport genrrally includes lon�; tenn obli�ations sold in the public crcdit markets by public agencies whose boundaries overlap the boundaries of the District in whole or in part. Such long tenn obligations gcnerally are not payable from revenues of thc I�istrict (except as indicated) nor are they necessarily obligations sccured by land within the Uistrict. In many cascs long terrn obligations issued by a public agency are payable only from the general fund or other revenue,of such public abency. o�o����Pos-a 23 "1'able 10 City of Palm Descrt Community Facilitics Uistrict No.91-1 (Indian Ridgc Public Improvements Direct and Overlapping Debt Report 2007-08 Local Secured A.ses.ed Valuation: $762,264,R71 DIRI�CT AND OVI:RLAPPIVG TAX AND ASSESSMENT DEBT: %Apulicable Ucbt 1/1/08 Dcscrt Community College District 1.080% $ 608.81G Ucscrt Sands[Jnified School Disuict 2.123 5,024,425 Coachclla Valley Counry Water Uistrict, I.U.No. 58 12.420 268,272 City of Palm Desert Community Facilities District No.91-1 100. 15,979,000 ��' Tn'l'AL DIRECT ANU OVI�:RLnPPItiG 7 AX ANU ASSI:SSMI•:NT DEBT $21.880,51:� OVERLAPPII�G GENERAL FUND DEBT: %Applicablc�`� I)ebt 1/1/08 Rivenide County General Fund Obligation� 0.438% $3,127,453 Riverside County PenSion Obligations 0.438 1,720,R58 Ri��erside('ounty Board of Education Certificates of Participation 0.438 40,625 Desen Sands Unified School Di,trict Certificates of Participation 4.842 1,445,095 Coachclla Valley Recreation and Park District Certificates of Participation 3.618 90,R12 C'oachella Valley County Water District, I.D.No. 71 Ccrtificates of Participation 3.249 207,611 TO"1'AL GROSS OVFRLAPPING GENERAL FUVD DEB7 �6,632,454 Less: Riverside County self-supporting obligations 81,386 'I'O"1'AL NET OVERLAPPII�'G GE:�ERAL FUND DFBT $6,SS1A6R <iROSS COMBINED TOTAL UEB'l �28,512,9G7 ''' NET COViBINLD TOTAL DEBT $28,431,581 (1) Excludes Mello-Roos Act bonds to be sold. (2) Based on asse„ed valuation not adjusted for redevelopment. (3) Excludcs tax and revenue anticipation notcs,cnterprisc revcnue,mortgage re��enuc and tax allocation bondti and non-bonded capital lease obligations. Ratios to 2007-08 Assessed Valuation: Direct Debt ($15,979,000).................................................................2.10% I otal Direct and O��erlapping Tax and As�essment Debt....................2.87°/� Gros�Combined'l otal Dcbt................................................................3.74% Net Combined Total Debt....................................................................3.73% STATE SCHOOL BUILDING AID REPAYABLE AS OF 6/30/07: $0 Source� Califomia Municipal Statistics, Inc. o�n�y,i,o,-a 24 so�nown�:ks� wsxs Th�� /i,/lutiring i.c u discu.s.cion o/ c•c�r�uin ri.ck /i�ctor.ti �hcr� .tihuulr( hr cun.c�i(c�rc�d, in udcliti��n �u uthc�r mutter.�• .cc�t Jurl{r herc�in. in c�rcrJtrnling thc� im�c�slnrc�n� quuli!}' uJ lhc� Seric�.c ZOOK Bnnd.s. "!'hi.c cli.ccu.�.�ion c/oc., nut pir�port tu hc� contp�z�hc�n�ii�e ur ctc�/initirc� unc! thc� urdcr in irhich �hc follu�ring %actur.c ru•c�rrc�sc�nte�l is not inte�ndc�d to re./Ic�ct the �•c�/utirc� impa•lance� n/.such ri.ck.c. The occtrrrc�ncc� o/ onc� a• �nw•e� orthc� c�i�c�nts disc•ic�.��cc/ herein coirlc/ uch�c�r.�c�lr a//i��� tJrc� uhilitr ur tit�il/ingness orp�-upc��-ti• nxvtc�r.� in �hc�Di.stric•t to pul•their Sj�c�c•iul �a.r tinc��n duc�. S�u�h_/iriltu�c>.s �o perr S�c�riul "1'u.� could re�.ctr!! in n �•upic!�/c>plc>tiun u/�hc�Kc�.cc�rrc�Acc•oun!crnd/or u dc�%uttlt in pu.vntc�nts orthc�principu!u/, crncl intc�rc�.ct on. thc� Sc�rie.� 20(IcY Bonds. In «c/dition, thc� occ►�rrc�ncc ofone ur morc� o/ Ihc� c�vc>>iLc r/iscc�.c.cc�d hc�rc>in cuulc/ uclrc>r.tic�lt•u%/�c�et thc�rulue of t/rc J�rope�•IJ•in the�District. Not General Obligation of the City The Series 2008 Bonds are not general obligations of the City but are limited oblibations of thc City payablc solely from procecds of thc Special Taxes (aftcr payment of thc City's co5t of administering the District), proceeds of the Series 2008 Bonds and certain moneys held in the Special Tax Fund (and dcsignatcd account� therein, but cxcluding the Administrative F.xpense Account, established under the Indcnture. Any tax for thc payment of the Series 200R Bonds shall be limited to the Special Taxes to be collected within the District. I.evy of the Special"I'axes The principal sourcc of�payment of debt service on the Series 2008 Bonds is the proceeds of the annual levy and collection of the Special Taxes. The annual levy of the Special Taxes is subject to the maximum tax rates authorized. The [evy cannot be made at a higher rate even if the failure ro do so means that the estimated proceeds of the levy and collection of the Special Taxes, together with other availablc funds, will not be suf�ficicnt to pay debt service on the Scrie� 200R Bonds. Other funds that might be available include fund� derived from the payment of delinquent cpecial taxes and funds deri��ed from thc tax salc of forcclo5urc and sale of parcels on which thc spccial taxes levied are delinqucnt. Thc levy of thc Spccial Taxes will rarely, if ever, result in a uniform relationship between the value of the Taxable Property and the amount of the levy of the Special Taxes. Thu�, there will rarely, if ever, be a uniforcn relationship bet�veen the value of a parcel and the proportionate share of Series 2001 l3ond dcbt 5crvice levied on the parccl, and certainly not a direct relationship. 'I�he Special Taxes levied in any particular tax year on a parcel of Taxable Property i5 based upoti the maximum rate and application of the Special Tax Fonnula. Application of the Special Tax Formula will, in turn, br depcndent upon certain development factors with respect to each parcel of Taxable Property by comparison with similar development factors with respect to the other Taxable Property within the DistricL Thus, the following are some of thc factors that might cause the levy of the Special Taxes on any particular parcel of Taxable Property to vary from the Spccial Taxes that might otherwisc be expected: • Rrduction in the number of parcels of Taxable Property, for such reasons as acquisition of Taxable Property by a govemment and failure of the government to pay the Special Taxes based upon a claim of exemption, thereby resulting in an increased tax burden on the rcmaininb Taxable I'roperty. • railure of thc owncrs of'I'axablc Property to pay the Special Taxes and dclays in thc collcction of or inability to collect the Special 'Taxcs by tax sale or forcclosure and sale of the delinquent parcels, thereby resulting in an incrcased tax burden on the remaining parccls. u�n��r 4,�„-.� 25 Not a 1'ersonal()bligation An owner of Taxable Property is not personally obligatcd to pay the Spccial Taxes. Rathcr, thc Special Taxes are an obligation only against the Taxable Property. If the value of the Taxable Property is not sufticient, takinb into account other obligationc also payable thereby to fully secure the Spccial Taxes, the City has no recourse against the property owner. Collection of the Special T�axcs Neither thc City nor the District has any obligation to pay dcbt service on the Scries 2008 Bonds in the cvcnt Special Tax installments are delinquent, nor is the City or thc I)istrict obligated to advance funds to pay such debt service. The Indenture provides that the Special Taxes are to bc collected in the samc manner as ordinary ad valorcm property taxes arc collected and, except a5 provided in the special covenant for foreclosure described below and in the Act, is to be subject to the same penaltics and the sa►ne procedure, sale, and lien priority in case of dclinquency as is provided for ad valorem property taxes. Pursuant to these procedures, if taxes are unpaid for a period of five ycars or more, the property is subject to sale by the Counry. Pursuant to the Act, in the event of any delinquency in the payment of the Special Taxes, the City Council may ordcr the institution of a superior court action to foreclose the licn therefor in the amount of the delinquent Special Taxes plus pcnalties, intcrest, and costs (including attorney's fces within specified time limits. In such an action, the real property subject to the unpaid amount may be sold at judicial foreclosure sale. Such judicial foreclosure action is not mandatory. However, the District has covenanted to cause foreclosure actions to be commenced and prosecuted abainst those properties that are delinquent in the paymcnt of the Special Taxes. l�or a de�cription of the foreclosure covenant, see "SEC'URITY AND SOURCES O�PAYMFN I hOR THE SERIES 200R BUNDS—Lovenant for Forcclosure." In the event that sales or foreclosures of property are necessary, there could be a dclay in payment of the Seriec 2008 E3onds pending such sales or the pro�ecution of foreclosure actions and receipt by the City of the proceeds of sale if the Reserve Account is depletcd. [n addition, there can be no assurance that the sale of�delinquent parccls in foreclosure will produce sufficient procceds to cover delinyucncics. Bankruptcy GeneruL The payment of the Special Taxes and the abiliry of the City to foreclose the lien of a delinquent unpaid tax, as discussed in "SLCURITY AND SOURC�:S OF PAYME�'I h'OR THE SGRIGS 2008 130NDS," may be limited by bankruptcy, insolvency or other laws generally affecting creditors' rights or by the laws of the Statc of California relating to judicial foreclosurc. In addition, thc prosecution of a forcclosure action could be delayed due ro crowded local court calendars or delays in the legal process. 'l�hc various legal opinions to be delivered concun•ently with the delivery of the Series 2008 Bonds (including Bond Counsel's approving Icgal opinion) will be qualified as to the enforccabiliry of the various legal instruments by bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights and by the application of equitable principles and by the exercise of judicial discretion in appropriate cases. Although bankruptcy proceedings would not cause the lien of the Special Taxrs to become extinguished, bankruptcy of a property owner could result in a delay in prosecuting superior court foreclosure proceedings. The federal bankruptcy laws provide for an automatic stay of foreclosure and tax �ale proceedings, thereby delaying such proceedings, perhaps for an extended period. Any such a�nzy�.��„-a 26 delays �vould incrcase thc likclihood of a dclay or detault in payment of the principal ol�and interest �n the Serics 2008 Bond�and the pos�ibility of delinquent tax installments not bcing paid in full. 'I'o the extent that bankruptcy or similar proceedings were ro involve a larbe property owner, the chances would increase that the Resen�e Account could be fully dcplctcd during any resulting delay in receivinb payment of delinquent Special "Caxes. As a result, sufticicnt monies �vould not be available in the Reserve Account for transfer ro thc Debt Service Account to make up any shortfalls resultinb from delinquent paytnents of the Special 'l�axes and thereby ro pay principal ot�and interest on the Series 200R Fionds on a timely basis. Property Owned by the FDlC: The ability of thc City to foreclose upon the lien relating to property on which Special Taxes have not been paid may bc limited in certain respects with regard to properties in which the Federal Deposit Insurance Corporation (the "FDIC") has an interest. Under federal law, when the FDIC is liquidating assets of an insured depository in its receivership capacity; property owned by the FDIC in that capacity is subject ro state and local real property taxes that are assessed according ro the property's value but is not subject to taxes assessed on some other basis, such as the Special '�axcs. The FDI(' is liable for any such non-ad-valorem taxea that wcre due or delinquent at the time the FDIC acquircd the property but not any penalties for delinquency. Howevcr, pursuant to its policy, the FDIC may cicct not to pay such claims where abandonment of its interest in the property is appropriate, in its busincss judgmcnt. In addition, no property of the FDIC is subject to levy, attachmcnt, barnishment, foreclosure, or sale without the FDIC's consent. Furthemiore, pursuant to FDIC policy, while other liens may attach to property in which the I��DIC has a lien or security interest, the FDIC will not permit a lien or securiry interest hcld by the FDIC to be eliminated by the foreclosure of other licns without the FDIC's consent. If the FDIC had a lien on a parcel subject to the Special Taxes, prohibiting the lien of the FDIC to be eliminated at a judicial foreclosure sale would likely reduce the number (possibly to none) of persons willing to purchase a parcel at a foreclosure sale. Owners of the Series 2008 Bonds should assume that the City will be unable to foreclose on parcels of land in the District owned by thc PDIC Such an outcomc would cause a draw on the Reserve Account and perhaps, ultimately, a default in payment of the Series 200R Bonds. Glasnly Marine Industries. On July 30, 1992, the United States Court of Appcals for the Ninth Circuit issued its opinion in a bankruptcy case entitled In re Glusply Murine Inclu.sa•ies. In that case, the court held that nd rrilorem property taxes levied by Snohomish County in thc State of Washington after the date that the property owner filed a petition for bankruptcy were not entiticd to priority over a secured crediror with a prior licn on the property. Although the court upheld the prioriry of unpaid taxes imposed before the filing of thc bankruptcy petition, unpaid taxcs imposcd after the filing of the bankruptcy petition were declared to be"administrative expenses" of�the bankruptcy e�tate, payable after all securrd creditors. As a result, the secured creditor was ablc to foreclose on the property and retain all the proceeds of the sale except the amount of the pre-petition taxes. (Because it lies within the court's discrction, no assurancc can be �;ivcn that a court would declare the Spccial Taxes to be an "administrative expcnse.") nccording ro the court's ruling in Glasplt�, as administrative expenses, post-petition taxes would be paid, assuming that the debtor has sufficient assets ro do so. In certain circumstances,payment of such admini�trative expensea may be allowed to be defcrred. Once the property is transferred out of the bankruptcy estate (through foreclosure or otherwisc), it would at that time become subjcct to current taxcs. Congress amended the Bankruptcy Code in 1994 to allow local governments to perfect their liens for ucl rulorc�m property taxcs cven after the filing of a bankruptcy petition, effectively overtuming o�o����os-a 27 G/u.cpl��, but only as it applies to «cl rcrlur��m property taxes. The Special Taxes, however, are not crcl rulurc�m taxcs. F.xcept to thc cxtent reversed by the amendcd Rankruptcy Code, C�Irr.cp!}' remains controlling precedcnt on bankruptcy cow-ts in the State. No other casc law exists with respect to how a bankruptcy court would treat thc lien for Special Taxes levied aftcr the filing of a petition in bankruptcy. [f a court applied the logic of Glu.cpl}�, a bankruptcy petition filing would prevent the licn for Special Taxes levied in subsequent fiscal years from attaching so long as thc property was a part of the e�tate in bankruptcy. If the Gla.cpl}�precedent were applied ro the Ievy of the Special "l'axes, the amount of Special Taxes received from parcels whose owners declarc bankruptcy could be reduccd. Pariry'I'axes and Special Assessments The Special Taxe� and any penaltics thcrcon will constitute a lien against the lots and parccis of land on which they will be annually impoacd until thcy are paid. Such lien is on a parity with all special taxes and special assessments lcvied by other agencies and is co-equal to and independent of the ]ien for general property taxes regardlc,� of when they are imposed upon the �ame property. The Special 'I�axes have priority over all existing and futurc private licns imposed on the property. The City, however, has no control over the ability of other entities and districts to issue indebtedness secured by special taxes or assessmcnts payable from all or a portion of the property within the District. In the event any additional improvements or fees are financed pursuant to the establishmcnt of an assessment district or another district fonned pursuant to the Act, any taxes or assessment levied to finance such improvements will havc a lien on a parity with the lien of the Special Taxes. [n addition ro the Special Taxes, the property within the District is subject to other parity taxes and asscssments. For information concerning existing direct and overlapping public indebtedness within the District, cee "SECURIT'�' AND SOURCES OF PAYMENT FOR l HP. SERIBS 200R I30NDS—Uirect and Overlapping Debt" herein. The existence of general property taxes, other special taxes, and assessments may reduce the value-to-debt ratio of the affected parcels and increascs the possibility that forcclosure proceeds will not be adequate to pay delinquent Special "I�axes or the principal of and interest on thc Scries 2008 Bonds when due. The City has covcnanted that it will not issue additional I3onds on a parity with the Series 200R Bonds, unless certain conditions are meL See "SEC'URITY A1�D SOURCBS OF PAYMFNT POR THE SERIES 200R BO'.DS—Issuance of Additional Bonds." Exempt Yroperties Certain properties are exempt from thc Special Taxes in accordance with the approved formula. In addition, the Act provides that properties or entities of the state, federal or local government arc exempt tro►n the Special "I'axes; provided, however, that property within the Uistrict acquired by a public cntity through a nebotiated transaction, or by gift or devise, that ia not otherwise exempt from the Special Taxes, will continue to be �ubjcct to the Special Taxes. It ia po,siblc that property acquired by a public cntity following a tax sale or forcclosure based upon failure to pay taxes could become exe►npt from the Special Taxcs. In addition, the Act provides that if property subject to the Special Taxes is acquired by a public entity through eminent domain proceedings, the obli�ation to pay the Special Taxes with respect to that property, for outstanding Bonds only, is to be treated as if it were a spccial assessmenL The constitutionality and operation of these provisions of the Act have not been tested. See "SEC'�R�I'v nrvD SOURCLS()F PAYME\T FOR THF SERIES 200R BO\DS Special Tax Authorization." [n particular, insofar as the Act require, payment of the Special Taxes by a federal entity acquiring property within the District, it may bc unconstitutional. If for any reason property within the District becocnes exempt from taxation by reason of ownership by a nontaxable entity such as the fedcral �overnmcnt or another public agency subject to the limitation of the maximum rates, the Special Taxes (170]4-.p��t-�3 zx will b� reallocated to th� rcmainin�; Taxablr Properties within the l�i�trict. "l�his would result in the owners of such property paying a greater amount of�the Special Taxes and could have an adverse i►npact upon the timely paymcnt of thc Special "l�axes. Morcover, it� a sub�tantial ponion of land �vithin thc Di�trict becomcs excmpt from the Special Taxes because of public ownership, or otherwise, thc maximum rate that could bc levied upon the remaining acrcage might not be sufficicnt to pay principal of and interest on the Serie� 2008 Bonds when due and a default would occur with respcct to the payment of such principal and interest. "1'he Act further provides that no othrr properties or entities arc exempt from the Special "faxes unlcss the propertics or entitics are expressly exempted in a resolution of�consideration to le��y a new special tax or to alter the rate and method of apportionmcnt of an existing cpccial tax. Land Valucs The valuc of Taxable Property within the District is a critical tactor in dctermining the investmcnt quality of the Serics 200R Bonds. If a property owner defaults in the payment of the Special Taxes, thc City's only remedy is to foreclose on the dclinquent property in an attempt to obtain funds with which to pay thc delinquent Special 1'axes. Land values could be advcrsely aTfected by economic tactors beyond the City's control, such as relocation of employers out of thc area, stricter land use regulations, the abscncc of watcr, or destruction of property causcd by, among other eventualities, earthquake, tic>od or other natural disaster, or by environmental pollution or contamination. Natural Disasters The value of the 'I�axable Property in the District could be adversely af�fccted by a varicty of natural occurrences, particularly those that cnay affect infrastructure, other public and private improvements on the 'I�axable Property and the continucd habitability and enjoyment of such improvements. Such occurrenccs include, without limitation, wildfires, floods, landslides and earthquakes. One or more of such natural disasters could occur and could result in damage to i►nprovements of varyin�; seriousness. "1'he damage ►nay entail significant repair or replacement costs and that repair or replacement may never occur either because of the cost, or because repair or replacement will not facilitate habitability or other usc, or becauce other considerations prcclude such repair or replacement. Wi/dfires. 1�he City is located in area where wildfires are a common occurrence. While there have not bcen any wildfires in the City, the occurrence of any natural disaster or physical calamity could reault in damage within the District. The occurrence of any such events couid adversely impaet the value of real property in the District, the collection of Special Taxes, the economy of the City, and, accordin�;ly, the ability of the District to make paymcnts on the Serie, 2(lOR Bond�when due. Floodin�. Plood zones are identified by the Fedcral Emerbency Management Agency ("F�MA"). FEMA designates land locatcd in a low- to modcrate-risk flood zone(i.c�. not in a floodplain) as being within a Non-Special Flood Hazard Area (a "NSI'HA"). I��.MA defincs an NSrHA as an arca that is in a low- to modcrate-risk flood zone (i.e. not in a tloodplain) and has less than a 1% chance of (looding each year. The City is located within a NSFHA and severe, concentrated rainfall could result in localized flooding and river overflows. The City has adopted a Uraina�cway, Floodway, and Watercow�se Ordinance that regulates development in flood prone areas by preventing construction in such areas. Development is permitted in these areas oncc floodtlow hazards are eliminated. Areas in thc City that have received flood control icnprovements are those subject to potentially destructive floods. Significant capital investmcnts have bccn made in the community where these threats occur. The City can make no represcntation that future maps will not be revised to include the City within an area deemed subject to floodinb. Thc occurrence of flooding in thc District could result in a reduction in Special Taxes n�n��r.�,�,.--� 29 and such a reduction could havc an advene effect on the ability ol�the Di�trict to make paymcnts on thc Series 200R 1-3onds when duc. Seismic Fuctors. Generally, seismic activity occurs on a regular basis in the State. Periodically, the magnitude of a single seismic c��ent can cause significant ground shaking and potential damage to property located at or ncar thc centcr of such seismic activity. The occurrence of severe seismic activity in the City could result in damage to roads, infrastructure and other property within the District. The occun�ence of such a severe seismic could have a negative i►npact on assessed valucs of taxablc ��alues of property in the District and could result in a reduction in Special 'I�axes. Such a reduction could have an adverse effect on the ability on the ability of the District to make payments on the Series 200R Bonds when due. Hazardous Substances One of the most serious risks in tenns of the potential reduction in the value of a parcel of 'l�axable Propeny is a claim with regard to a ha�ardous substance. In gcncral, the owners and operators of a parcel may bc rcquired by law to remedy condition5 of the parcel relating to relea�e� or threatened rcleases of hazardous substances. The federal Comprehensive Environmental Response, Compensation and I.iability Act of 19$0, sometimes referred to as "CERCLA"or the"Supertund Act," is the most well- known and widely applicable of these laws, but State laws with regard to hazardous substances are also stringcnt and similar. Under many of these laws, the owner or operator is obligated to remedy a hazardous substance condition of property whcthcr or not the owner or operator has anything to do with creating or handlin�; the hazardous substance. The effect, therefore, should any of the Taxable Property bc affccted by a hazardous substance, is to reduce the marketability and value of the parcel by the costs of remedying ttie condition, because the purchaser, upon becoming owner, will become obligated to remedy thc condition just as is thc ticllcr. The assessed values oC property in the District do not take into account the possible reduction in markctability and value of any of thc"I'axable Property by reason of the possible liability of the owncr or operator for the remedy of a hazardous substance condition of thc parcel. It is possible that such liabilitics cun�ently exist and that the Di�trict and City have not been notified of such liabilities. Furthcr, it is possible that liabilities may arise in the futurc with respect to any of thc Taxablc I'roperty resulting from the existence, currently, on the parcel of a sub,tance presently classified as hazardous but that has not bccn released or the releasc of which is not presently threatened, or may arise in the futurc resultin�; from the existencc, currently on the parcel of a substance not presently classified as hazardous but that may in thc future be so classificd. Purthcr, such liabilities may arise not simply from the existcncc of a hazardous substance but from the method of handling it. All of these possibilities could significantly affcct the value of a parcel of'l�axable Yroperty within thc DisU�ict. Uisclosures to Future Purchasers The willingncs, or ability ot�an o�vner of a parcel oC"l�axable Property to pay the Spccial Taxes even if the value ic sufficient may be affected by whether or not the owner was given due noticc of the authori•r.ation of� the Special Taxes at the time the owner purchased the parcel, was informed of the amount of the Special Taxes on the parcel should the Special Taxes be levied at the maximum tax rate and the risk of such a levy and, at the time of such a levy, has the ability to pay it as well as pay other expcnscs and obligations. "I�hc District has caused a notice of the Special "l�axes to be recorded in thc Office of the Recorder for the County against each parcel of Taxable Property. While title companics normally refer to such notices in title reports, there can be no guarantee that such reference will be made or, if made, that a prospective purchaser or lender will consider such Special "fax obligation in thc purchase of a property within the llistrict or lending of money thereon. 070�9.pos-4 30 I,imitation on Remedies; vo Acccleration Remcdies available to l3ondholders may be limited by a variety of lactors and may be inadequate to assure the timely payment of principal of and intcrest on thr Series 2008 Bonds, or to preserve the tax- cxcmpt status of thc Bonds. Bond C'ounsel has limited its opinion as to the enforceability of thr Bonds and the Indenture to the extent that enforceability may be limitcd by bankruptcy, insolvency, or similar laws affecting gencrally the enforcement of crcditors' rights. Additionally, the Scries 200R 13onds are not subject to acceleration in the cvent of the brcach of any covenant or dury under the Indenturc. Lack of rcmedies may entail risks of dclay, limitation, or modification of E3ondowncr rights. Judicial rcmedies, such as foreclosure and enforcement of covenants, are subjcct to exercise of judicial discretion. A California court may not strictly apply certain remedies or enforce certain covenants if it concludes that application or enforcement would be unrcasonable under the circumstances and it may dclay the application of such rcmedies and enforcement. Loss of Tax Exemption In order to maintain the exclusion from gross incomc for federal income tax purposes of the intcrest on thc Bonds, the District has covcnanted in the Indcnture to comply with the applicable requiremcnts of thc Internal Revenue Code of 19R6, as amcnded. The interest on thc Series 2008 Bonds could become includable in gross income for purposes of federal income taxation retroactive to the date of issuancc of such Scrics 2008 Bonds as a result of acts or omissions of thc Uistrict in violation of this or other covenants in the Indenture applicable to the Series 200Q Bonds. 'I�hc Series 2008 Bonds are not tiubject to rcdemption or any increa�e in intcrest rates should an evcnt of taxability occur and will remain outstanding until maturity or prior redemption in accordance with thc provisions contained in thc Indenturc. See"TAX MATTERS.'� Legislation affecting the tax cxcmption of interest on the Series 2008 Bonds may be considered by the United States Congress and the State lcbislature. Federal and State court proceedings and the outcomc of such proceedings could also affect the tax excmption of interest on the Series 200R l3onds. No assurance can be given that legislation enacted or proposcd, or action, by a court, after the date of issuance of the Series 2008 Bond� will not havc an adverse effect on the tax cxemption of interest on thc Series 200R Bonds or the market value of the Series 2008 l3onds. As one example, on November 5, 2007, the United States Supreme Court heard arguments in Kc�ntuc�-�� Dc�nrtme�nt o/ Rc>i�en��e t�. U�ri�is, an appeal from a Kentucky state court that ruled that the United States Constitution prohibited the state from providing a tax exemption for interest on bonds issued by the statc and its political subdivisions but taxing interest on obligations issued by other states and their political subdivi�ions. If the Unitcd States Supreme Court afGrrns the Kentucky appellate court decision,such ruling could overturn other state income tax laws similar to that in Kentucky. In that event, each affected state could cnact legislation to either extend its tax excmption to bonds issued by other states and their political subdivisions, or tax the intcrest on its home-state bonds in thc same manner as it taxes the interest on out-of-state bondc. It is uncertain whether any such new laws, if enacted,would have retroactive effect. "fhe introduction or enactment ol�any such future legislation, or clarification of the Code or court decisions may also affect thc market price for, or marketability of, the Series 200R Bonds. Prospective purchasers of the Series 200R I�onds should consult their own tax advisers regarding any pending or proposed federal or state tax legislation, regulations or litigation as to which Bond Counsel expresses no opinion. 1170_'9�pos--3 31 Risk of Tax Audit In December 1999, as a part of a larger reorganization o}� thc Inter►ial Revenuc Service (thc "IKS"), the IRS com►nenccd operation of its "Cax Exempt and Goveinment Gntities Division (thc "TE/(iE Di��ision"), as the succcssor to its Cmployee Plans and F.xempt Organizations division. Thc ncw "I�E/GF. Division ha� a subdivision that is �pecifically dcvotcd to tax-exempt bond compliance. Public statemcnts by IRS officials indicate that the number of tax-cxcmpt bond examinations (which would include thc issuancr of securitics such as the Series 2008 Bonds) is cxpected to increase significantly undcr the new 7�E/(iE Division. 'I�here is no assurance that if an IRS examination of the Serics 200R Bonds was undertaken that it would not adversely affect the market valuc of the Scrie� 2008 13onds. See ""Cnx Mn�rrtRs." Neither the District nor the City has been contacted by thc IRS regardinb the examination of any of its bond transactions. Secondary Market "1'here can bc no guarantee that there will bc a sccondary market for thc Series 2008 [;onds or, if a secondary market exists, that the Series 200R Bonds can be sold for any particular price. Occasionally, due to bcneral market conditions or becau�e of adverse history or economic prospccts connected with a particular issue, secondary marketing practices are suspended or terminated. Additionally, prices of issucs for which a market is being made will depend upon then prcvailing circumstanccs. Such prices could be substantially different from the original purchase price. Proposition 218 and the Initiativc Power On Nove►nbcr 5, 1996, the voters of the State approved 1'roposition 218, a constitutional initiative entitled thc "Right to Vote on Taxes Act" ("Proposition 218"). Proposition 218 adds Articles XIIIC and XIIID to thc California Constitution and contains a number of interrelated provisions affecting the ability of local governments to levy and collect both existing and future taxes, assessmcnts, fees and charges. Proposition 218 becamc effective for most purposes on November 6, 1996. Anicle XIII C of Proposition 21 R removes all limitations in State law on the initiative power to rcduce or repcal "any local tax, assessment, fee or charge." Thc initiative powcr is, however, limited by the United States Constitution's prohibition abainst State or local laws "impairing the obligation of contracts." The Serics 200R Bonds represcnt a contract between the District and the Bondowners secured by the Special �I'axe�. While not free fro►n doubt, it is likely that, once the Series 2008 Bonds are issued, the Special Taxes would not be subject to repeal or reduction by initiativc, at least to thc extent the taxes arc necessary ro enable the District to make timely paymcnt on principal and interest on the Series 2008 Bonds, but not necessarily to the lull extent of the maximum tax. 1'he intc►pretation and application of these provisions of Proposition 218 and the federal Constitution's Contracts Clause will ultimately be detern�ined by the courtc, and it is not possible at this time ro predict with certainty thc outcome of such detertnination or the timcliness of�any remedy affordcd by the courts. See also "CUNSTITUTIONAL AND STATIJTORY LIMI7nTIONS ON TAXE:S, RF.VF.NU�S AND APPROI'RIA�IONS Propo�ition 218." a�ma,Pos--� 32 CONS1'[T[?TIOnAL AND S"1'AT[JTORY L1M17�ATIONS OV TAXES, REVENUES ANU APPItOPRIA"CIOI�S Articic XIII A of the California Constitution On June 6, 197R, Califomia voters approved an amendment (commonly known as both I'roposition 13 and thc Jarvis-Gann Initiative) to the California Constitution. 7�his amendment, which added /\rticic XIII A to the C:alifo�7iia Constitution, among other thing� aflects the valuation of real property for the purposc of taxation in that it defincs the full cash propci-ty value to mean "the county assessor's valuation of real property as sho�vn on the 1975-71, tax bill under "full cash value," or thercafter, the appraised value of rcal property newly constructed, or when a change in ownership has occurred after thc 1975 assessment." The full cash value may be adjusted annually to rcflect inflation at a ratc not to exceed 2"/o per year, or a reduction in the consumcr price index or comparable local data at a rate not to exceed 2% per year, or reduced in the event of declining properiy value caused by damage, destruction or other factors includinb a grncral economic downturn. The amendment further limits thr amount of any ud rerlure�m tax on rcal property to one percent of the full cash value except that additional taxcs may be levied to pay debt service on indebtedness approved by the voters prior to July l, 197R, and bonded indebtedness for the acquisition or improvement of real property approved on or after July I, 1978 by two-thirds of the votes cast by the voters votinb on the proposition. Legislation enacted by the California Legislature to implement Article X[II A providcs that all taxable property i5 5hown at full assessed value as described above. In confonnity with thic procedurc, all taxable property valuc included in this Official Statement(except as noted) is shown at 100% of assessed value and all general tax ratcs rcflect the $1 per $100 of taxable value. Tax ratcs for voter approved bonded indebtcdness and pension liability arc al�o applied to l00"/0 of asses�ed value. Sincc its adoption, Articic Xlll A has been amended a number of times. These amendments have crcated a number of exceptions to the requirement that property bc assessed when purchased, newly constructed or a change in owncrship has occurred. These exceptions include certain transfers of rcal property between fa►nily members, certain purchases of replacement dwcllings for persons ovcr age 55 and by property owners whose oribinal property has been destroyed in a declared disaster and certain improvements to accommodate disabled persons and for seismic upgrades to property. Thrsr amcndments have resulted in marginal rcductions in the property tax revenues of the City Both the California State Supreme Court and the United Statcs Supreme Court have upheld the validity of Article XIII A. Article XIII B of the California Constitution On November fi, 1979, California votcrs approved Proposition 4, the Gann Initiativc, which added Article XIII B to the California Constitution. In June 1990, Article XIII B was amended by the voters throubh their approval of Proposition 11 1. Article Xll[ Fi of the California Constituticm limits the annual appropriations of the State and any ciry, county, school district, authority or other political subdivi,ion of the State to the lcvel of appropriations for the prior tiscal year, as adjusted annually for changes in the cost of livinb, population and services rendered by the �;overnmental entity. The "base year" for c�tabliching such appropriation limit i� fi�cal year 197$-79. Increases in appropriations by a governmental entity are also permitted (1) if financial responsibility for providing services is transferred to the governmental entity, or (2) for cmerbencies so long as the appropriations limits for the three years following the emcrgency are rcduced to prevent any aggregate increase above thc Constitutional limit. Decreases are required where responsibility for providing services is transferred fmm the government entity. u�u?�T,p,,,-.3 33 nppropriations subject to nrticic XII[ B include �;enerally any authorization ro expend durin� thc fiscal year thc procced� of taxcs ]e�icd by the State or other entity of local govcrnment, cxclusi��e oi� certain State subventions, refunds of taxes, bcncfit payments from retirement, unemployment insurance and disability imw�ancc funds. Appropriations subject to limitation pursuant to Article XIII B do not include debt service on indebtedness cxisting or legally authorized as of January l, 1979, on bondcd indebtedness thereafter approved according to law by a votc of the clecrors of the issuing cntity votinb in an cicction for such putposc, such as the Series 200R Bonds, appropriations required to comply with mandates ot� courts or thc Pederal government, appropriations for qualified outlay projects, and appropriations by thc State of rcvcnucs derived from any incrcase in gasoline taxes and motor vehicle weight fees above January 1, 1990 levels. "Proceeds of taxcs" include, but arc not limited to, all tax revcnucs and the proceeds to any entity of government from (1)rcgulatory liccnses, user charbes, and user fees to the extent such proceeds exceed thc cost of providing the service or regulation, (2) the investment of tax revenues and(3)certain State subventions received by local governments. As amended by Proposition 11 l, the appropriations limit is tested over consecutive two-year periods. Any excess of the aggregate "proceeds of taxes" recei��ed by the City over such two-year period above the combined appropriations limits for those two years is to be returned to taxpaycrs by reductions in tax rates or fcc schedules over the subsequent two years. As amended in June 1990, the appropriations limit for the Ciry in each year is based on the limit for the prior year, adjusted annually for changes in the costs of living and changes in population, and adjusted, where applicable, for transfer of financial responsibility of providing scrvices to or from another unit of govcrnmcnt. 1�he chanbc in the cost of living is, at thc City's option, cither (1) thc percentage chanbe in California per capita personal income, or(2)the percentage change in the local assessment roll for the jurisdiction due to the addition of nonresidential new construction. 'I�he measurement of chanbc in population is a blended average of statewide overall population growth, and change in attendance at local school and community college("K-14") districts. Article X[I[ B pennits any govemment cntity to change the appropriations limit by vote of�the electorate in conformity with statutory and Constitutional voting requirements, but any such voter- approved chanbc can only be effective for a maximum of four years. Proposition 218 nn November 5, 1996, the voters of the State approved Proposition 21 R, known as the "Right to Vote on Taxes Act." Proposition 218 added nrticles XI11 C and XIII D to the California Constitution, which contain a nu►nber of�provisions affecting the ability of cities and countics to Ievy and collcct both existin�;and futurc taxcs, assessmcnts, tcrs and charges. Article Xlll C requires that all new local taxes be submitted to the elecrorate before they become cffective. Taxes for general governmental purposcs of the City require a majority vote and taxes fa� specific purposes, evcn if dcpotiitcd in the City's general fund, reyuire a two-thirds vote. The voter approval requircments of Proposition 218 rcduce the flexibility of the City Council ro raisc rcvcnucs for the general fund, and no assurance can be given that the City will be able to impose, extend or increase such taxes in the future to meet increased expenditurc rcyuircmcnts. In addition, Article XIII D contains new provisions rclating to how local a�cncic. may levy and maintain "a,sessments" for municipal services and programs. "Asscssment" is defined to mean any levy or charge upon real property for a special benefit conferred upon the real property. This definition applies to landscape and ►naintenance a�sessments for opcn space areas, street medians, street lights and parks. Article XIII U also contains several provi�ions affecting "fees" and "charges," deCned for purposes of Article XIII D to mean "any levy other than an uc/ r�lar�m tax, a spccial tax, or an assessment, imposed by a local gove�nment upon a parcel or upon a person as an incident of property o�n�a.E,�,�-a 34 owncrship, including a uscr tcc or charbc for a property rclated servicc." All new and cxistin� property rclated fees and charge. must confonn to rcyuirement� prohibiting, among othrr things, fces and charges which (i) generate re��enucs cxceeding the funds required ro provide the property rclated service, (ii) arc used for any puipose other than those for which the fces and charges are imposed, (iii) are for a service not acwally used by, or immediatcly availablc to, the owner of thc property in question, or(iv) are uscd for general bovcrnmental serviccs, includinb police, fire or library services, where the service is available to thc public at large in substantially thc sa►ne manner as it is to property o�vners. l�urther, bet��re any property related fee or charge may be imposcd or increased, written notice must be given ro the record owner of each parcel of land affected by such fce or charbe. The City must then hold a hearinb upon the proposed imposition or incrcase, and if written protcsts against the proposal are presented by a majority of the owners of the identitied parcels, the Ciry may not impose or increase the fec or charge. Moreover, except for fees or charges for sewer, watcr and refuse collection services, or fces for electrical and gas service, which arc not treated as "properiy related" for purposes of Article XIII U, no property rclated fee or charge may be imposcd or increased without majority approval by the property owncrs subject to the fee or charge or, at the option of the local agency, two-thirds voter approval by the electorate residing in the affcctcd area. In addition to the provisions described above, Article XIII C removed many of the limitations on the initiative power in matters of reducing or repealing any local tax, assessment, fee or charge. No assurance can bc�;iven that the voters of thc City will not, in the future, approve an initiative or initiatives which reduce or repeal local taxes, assessments, fccs or chargcs currently comprising a substantial part of thc City's general fund. "Assessment,""fee" and "charge" are not defined in Article XIII C, and it is not clear whethcr thc dctinitions of thcse terms in Articic XIII D (which are generally property rclated as described above) would be applicd to Article XIII C. If the Articic XIII D definitions are not held to apply to l�rticle XIII C, the initiative power could potcntially apply to revenue sourccs which currently constitute a substantial portion of beneral fund revenues. No assurancc can be given that the voters of the City will not, in the futurc, approve initiatives which repeal, reduce or prohibit the future itnposition or increase of local taxes, assessments, fees or chargec. In addition, Proposition 218 addcd several requirements ►naking it gcnerally more difficult for counties and other local agencies to lcvy and maintain asscssments for municipal services and programs. Finally, Proposition 218 requires that all new local taxes be submitted to the electorate belorc thcy become effective. "I'axc� for general bovernment purposes of the City requirc a majority vote and taxes for specific pu�poscs only requirc a two-thirds vote. The voter approval requirements rcduce the flexibility of the City Council to deal �vith fiscal problems by rai�ing revenue and no assurance can be given that the City wi11 be able to raise taxes in the future to meet increased expenditure requirements. Futurc Initiatives Article XIII A, Article XIII B and Proposition 21 R were each adoptcd as measures that qualified for the ballot pursuant to the State's initiativc process. From time to time, other initiative mcasurec could be adopted, which may place further limitations on the ability of the State, thc City, the District or local districts to increasc rcvenues or ro increase appropriations which may affcct revenues or thc ability to expend�uch rcvenue�. u�uz��.p�s-a 35 tax-exempt obli�ations, and individuals othcnvise cligiblc ti>r the eamcd income tax credit. Thc applicability and extent of thcse and other tax consequcnces will depend upon the particular tax status or other tax items of the owncrs of the Series 2008 Bonds. Bond Counsel ���ill express ►�o opinion rebarding thosc concequenccs. Any exccss of the stated redemption price at maturity of the Series 2008 I3onds over the initial ofTering price to the public of the Seric� 200R Bonds set foi-th on the insidc cover of this Official Statement is `bribinal issue discount." Such original issue discount accruing on a Series 200R Bond is treated as interest excluded from the gross income ot�the owner thereof for tederal income tax purpc�ses and cxcmpt from California personal income tax. Original issue discount on any Scries 2008 I3ond purchased at such initial offering price and pursuant to such initial offerinb will accrue on a semiannual basis ovcr the tenn of the Series 200R Bond on the basis of a constant yicld method and, within each semiannual period, will accrue on a ratable daily basi�. The amount of oribinal issuc discount on such a Series 2008 Bond accruing during each period is added to the adju5ted basis of such Series 2008 Bond to determine taxable gain upon disposition (including sale, redemption or payment on maturity) of such Series 2008 Bond. The Code includcs certain provisions relating to the accrual of original issue discount in thc case of purchascrs of the Series 2008 Bonds who purchase the Serics 200R Bonds other than at the initial offerinb price and pursuant to thc initial offerinb. Any person considering purchasinb a Series 2008 Bond should consult his or her own tax advisors with respect to thc tax consequenccs of owncrship of bonds with original iscue discount, including the treatmcnt of purchasers who do not purchase in the original offering and the original offering price, the allowance of a deduction for any loss on a sale or other disposition, and the trcatment of accrued original issue discount on such bonds under federal individual and corporate altcrative minimum taxcs. If the Series 2008 Bond� wcre offercd and sold to the public at a pricc in excess of�their stated redemption price (the principal amount) at mawrity, that excess constitutes "premium." For federal income tax purposes, that premium is amortized over the period to maturity of the Series 2008 Bonds, based on the yield to maturity of the Scries 2008 Bonds, compoundcd semiannually. No portion of that premium is dcductible by the owner of a Series 2008 Bond. For pu►po5es of determining the owncr's bain or loss on the sale, redemption (including mdemption at maturity) or other disposition of a Series 200R Bond, the owner's tax basis in the Series 20U8 Bond is reduced by the amount of premium that accrues during the period of ownership. As a result, an owncr may realize taxable gain for federal income tax putposcs from the sale or other disposition of a Series 200R Bond for an amount equal to or less than thc amount paid by thc owner for that Series 2008 Bond. A purchaser of a Serics 2008 Bond in the initial public offering at the price for that Series 200R Bond stated on the cover of this Official Statement who holds that Series 2008 Bond to maturity will realize no gain or loss upon thc retirement of that Series 200R Bond. Owner� of the Series 2008 Bonds should consult their own tax advisers as ro the deterniination for federal income tax pu�poses of the amount of prentium properly accruable in any period with respect to the Series 200R Bonds and as to other federal tax conscquences and thc treatment of premium for purposes of statc and local taxes on,or based on, income. Purchasers of the Series 2008 Bonds at other than their oribinal issuance at thc respective prices indicated on the cover of this Oflicial Statement should consult their own tax advisers regarding other tax considerations such as thc consequences of market discount. VO MATERIAL LITIGAI'IOn At the time of delivery of and payment for the Series 2008 Bonds, the Uistrict and the City �aill each certify that thcrc is no action, suit, proceeding, inyuiry or im�estigation,at law or in cquity, before or by any court or rcbulatory agency, public board or body pending or threatened against the District or the City affectinb their cxistence, or the titles of their respective officers, or seeking to restrain or to enjoin a�ozy,�os-a 37 the issuance, salc or dclivcry of the Scrie� 200R Ronds, the application of the procecds thercot� in accrn•dancc with thc Indcnture, rn� the collection or Ic�y of thc Special "l axes to pay the principal of and interest on the Local Obligations,or in any way contesting or afiectinb the validity or enforccability of the Local Obligations and the Scrie� 200R Bonds, the Financing Abreement, the Bond Purchase Contract entered into betwecn the Uistrict and the Unden��riters, or any other applicable agrcements or any action of the J)istrict or the City contemplated by any of said documents, or in any way contecting th� completeness or accuracy of this Official Statement or any amendment or supplemcnt thercto, or contesting the powcrs of the Uistrict or the City or their authority with respect ro the Series 2008 Bonds or any action of the District or the City contcmplatcd by any of said documcnts, nor, to the knowledge of'the l)i�;trict or the City, is there any basi�therefor. RATII�GS Standard & Poor's Ratings Serviccs, A Division of the McGraw IIill Companies ("S&P") [and Fitch Ratings ("Pitch")] [are expectcd to assign ratings/have assigned a ratings] of"AAn" [and "AAA," respectivelyJ to the Series 2008 Bonds baacd upon the understanding that, upon dclivery of the Serics 2008 Bonds, the Financial Guaranty Insurancc Policy will be issued by the Insurer. Sce "FINANCIAL GUARAI�I1' 1\SURANCE" and APPENDIX G "SPECIME� FINANC'IAL GUARAKTI' IKSURANCE PULICl'." [Such ratings reflcct only the views of S&P and Fitch and do not constitute a recommendation to buy, seli or hold the Series 2008 Bonds.] l:xplanation of the sibnificancc of such ratings may be obtained only from Standard & Poor's Ratings Scrvices, 55 Water Street, New York, Nc�v York 10041; phonc: 212- 20R-1767 and fitch Ratings, One State Strect Plaza, New York, New York 10041; phonc: 212-90R-O500. Thcre is no assurance that cither such rating will continuc for any given period of time or that thcy will not be revised downward or withdrawn entirely by the ratinb agency, if in the judbment of such rating agency circumstances so warrant. Any such dowmvard revision or withdrawal of such rating may ha��c an adverse cffect on the market price of and/or thc ability ro tradc the Serics 200R Bonds. FINANCIAL ADVISOR "rhe Ciry has retained Del Rio Advisors, LLC, Modcsto, Califomia, as financial advisor (the "Financial ndvisor") in connection with the preparation of this Official Statement and with respect to thc issuance of the Serics 200R Bonds. The Financial Advisor is not obligated to undertake, and has not undertaken to make, an independent verification or assume responsibility for the accuracy, complctenes�, or fairness of the information contained in this Official Statement. The compensation of the Financial Advisor is contingent upon the issuancc of the Scries 200R Bcmds. VERIFICATION OF MATHEMATICAL COMP�1'ATIONS Upon delivery of the Serics 2008 Bonds, Grant Thornton I.I.P (the "Verification Agcnt"), will deliver a report stating that it has rcviewed and confirmed the mathematical accuracy of certain computations relating to the adequacy of the funds and/or securities deposited in the �scrow Funds and the interest thereon, if any, to pay, when due, the redemption price and interest on the Prior Bonds on the specified redemption date thereof. u�uzy,ix,�-a 38 U!VUER��I�RI7'I�G l�hc Series 200R Bonds are being purchased by Stinson Securities, LI.0 and Kinscfl, Newcomb & nc Uios, Inc. (the "Unde�writers"). The Underwriters have agreed, subject to ccrtain conditions, ro purchase such Serics 200R Bonds at the purchase price of $ (representing thc aggregate principal amount of the Serics 200R Bonds of $ , Iccs an Underwriters' discount of $ ). 'The Bond Purchase Agrccment, dated , 200K relating to the Scries 200$ Bonds (the "Purchasc Agreement") providec that the Undei�vriters will purchase all of the Series 2008 Bonds if any are purchased, the obligation to make such purchase being subject to certain tenns and conditions set forth in the Purchase nbrcement, the approval of ceriain lcgal matters by counsel and certain other conditions. "I'hc Underwritcrs may offer and sell the Serics 200R Bonds to certain dealers and others at prices lowcr than the oftering prices statcd on thc inside cover page. The offering prices may be changed trom time to time by the Underwriters. CONTINUING DISCLOStIRE The llistrict has covenanted for the benefit of the Owners and I3cneFcial Owners of the Serics 2008 Bonds to provide annually while any Scries 2008 Bonds are outstanding, to each nationally recognized municipal sccurities information repository and any public or private reposito�y or cntity dcsignated by the State ofCalifornia as a state repository for purposes of�Rule 15c2-12(b)(5) (the "Rule") adopted by the Securities and Exchange Commission (each, a "Repository") certain annual financial information and operating data, including its Comprchensive Auditcd Financial Report by not latcr than 270 days atter the cnd of each Fiscal Year (thc "nnnual Repori") commencing with the report for riscal Year 2007-OR. The specific naturc of the information to be contained in the Annual Report or the notices of material cventc is contained in APPENDIX �:—"FORM OF CONTINUING DIS('LOSURE 11GREFMG!�T.'� Thesc covenants have been made in order to ascist the Undcrwriters in complying with the Rule. n�u������x„-.s 39 11ISCELI.AVEOt'S This Official Statement is not to be construcd as a contract or agreement among the District, thc City and the purchascrs of the Scries 200R Bonds. My statements made in this Ofticial Statement involving mattcrs of opinion or of estimates, whcther or not so expressly stated, are set forth as such and not as represcntations of fact, and no representation is made that any of the estimates will be realized. 'l�hc information and expressionc of opinion hercin are subject ro change without notice and neither the delivery of the Official State►nent nor any sale ►nade hereundcr sl�all, under any circumstances, crcate any implication that there has bcen no change in the affairs of the District or thc City since the date hercof. The execution and delivery of the Official Statement by the District has been duly authorized by the lcgislative body of the District. CITY OF PAI.M DESER'I'COMMUNII�Y FACILITIES DISTRIC'f NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVl:MENTS) sy: [Name] [Title] o�o�v�p�,s-a 40 AYPENDIX A METHOD OF APYORTIONMEVT OF SPECIAL'I'AX�;S o�uz�,,�o,-a A-1 APPEI�DIX B GENH;kAI. INFORMA'I'ION CONCERNING TI1E CI"fY OF PAL�I DESER7' %hc fullux�ing infnrmution cunce�rning tl�c Citt� u% Pulm Ue.cc�i7. the Coin��}• ��/ Kirc�i•sicle und stu�rot�nding n�•c�a.c i.c inc/t�dc�r/ nn/r ��r thc� ptr�/�os� u/ .strppli•ing gc�ncrcrl inlurmution i•c�grrrcling lhc� contmi�nitti•. O��erview '1'he City of Palm Desert (thc "City"), incorporatcd in November 26, 1973 as a general law city, becamc a charter city through thc adoption of�Ordinance 858 by the City Council on January R, 1998. The City is located in thc Coachella Valley and is approximately mid-way between thc cities of Indio and Palm Sprinbs, 117 miles east of Los Anbeles, 11 R miles northeast of San Diego and 5]5 milcs southeast of San I�rancisco. The City occupies an area of approximatcly 26 square miles. Elevation of the City is 243 feet and the mcan tcmperature is 73.1 degrees. E:xcept in�ummer, the wcather is mild and annual avcrage rainfall is 3.38 inches. According to the Statc Ucpartment of Finance, thc City population as ofJanuary 1, 2007 was approximately 49,�52, an increase of approximately 16.7% since 2000, attributable in part to tcrritoria] anncxation. Governmcnt The City Council is comprised of five members, elected at large for four-year staggered tenns every two years. 'l�he general ►nunicipal clection is conducted in November of even-numbered years, consolidated with the Statewide General Election and councilmembers are swom in and take office at thc first mecting in December following each election. . The City Council sclects one of its mcmbers to serve as Mayor for a onc-year term and appoints a City Manager to conduct thc day to day busincss of the City and the City Clerk. The City Attomey is appointed by City Council. �l�hc City operates as "Contract City" utilizing, primarily, agrcements with other governmental entities, private companies and individuals to provide services. Contracted sen�ices include police and fire protection provided through the County, animal control, health scrvicec, legal scrvices and landscape maintenance. "(�hc City Council also sen�es as the governing board of the Financing Authority, the Redevelopment ngency, the IIousing Authority and the Parkinb Authority and the City Manger serves as the Chicf Administrative Officer of thc Financing Authority and the Exccutive Director of the Redevelopmcnt Agency, the ��ousinb Authority and thc Parking nuthority. 'I�he City Attorney and the City Clerk also serve as the General Counsel and Secretary, respectively, of the Redevelopmcnt Agency and these Authorities. The currcnt members of the City Council and key administrative per�onncl of the Ciry are listed in"I�able B-1 and Table B-2,respectively: ino��,�ro�-a B-1 "I�ABI.E B-1 CITY OF YAI.M UES}�;RT Citv Council Members Name Of�ficc "l cnn Expires Occupation Richard S. Kclly Mayor November 200R Retired G'l�L l:xccuti��c Jean M. Benson Mayor Pro Tem November 2010 Kctircd Travel Industry Professional Jim l��erguson Councilmember Novembcr 2010 Attorncy Cindy l�inerty Councilmember November 200R 13usinesswoman Robert A. Spie�;el Councilmember November 200R Rctircd Retail Industry Executivc TABLI�: B-2 CITY OF'PALM DESERT Kev Administrativc Personnel Name Position Carlos L. Ortcba City Manabcr Justin McCarthy Assistant City Manager Paul S. Gibson Treasurer/Financc Director David L. Yrigoyen Dircctor of Redcvclopment/FIousing Rachelle [). Klacsen City Clerk Population Between 2003 and 2007, the City's population increased by a total of 5,452 or approximately 12.3%. In addition to permanent resident�, the City has approximately 15,000 scasonal residential residents who live three to six months in the Ciry, primarily during the winter months. Tablc I3-3 illustrates the population of the City,the County and the State for 2000 and 2003 through 2007. 7'able B-3 CITY OF PALM DESERT AND RIVERSIDE COt1NTY AND STATE OF CAI,IH'ORNIA POPUI.ATION Year (January 1) Citv of Palm llescrt Riverside Countv State of Califomia 2000 41,450 I,557,800 34,207,000 2003 44,300 1,719,000 35,591,000 2004 45,610 1,807,RSR 36,271,091 2005 49,595 1,8R8,31 1 3fi,728,196 2006 49,879 1,966,607 37,195,240 2007' 49,752 2,031,625 37,662,518 + Preliminary. Sources: Uni�ec!S�ates Depcurment oJ Cumme�ce. Bw�rcm uj�he Census /w•20llll unr(S�rr��of C'ulifonr�u Dc�pru�nnenl uj h'innnce,/o��i-em�ininR yen��s. 070'9.�x�s-�3 B-2 I.abor Forcc and Employmcnt The main sources of rcvcnuc in the City are derived trom touris►n and salcs tax. Historically, the unemploymcnt ratr in the City has been lower than that for the County and the State. 'l able F3-4 table represents the labor patte�7is in the City, thc(`ounty, the State,and the Unitcd States from 2002 through 2006. Tablc 13-4 CITY OF' YALM DI�:SERT,RIVERSIDE COUNTY, STATE OF CALIFORI�IA���AND UNITEU S"1'ATES CI�'II,IAN I.ABOR FORCE, EMPLOYMENT, AND i'NEI�IPLOY�IE'.VT 2002 through 2006 Unemploymcnt Year and Area Labor 1�'orce �mvlovment Unemployment Ratc 2002 City 21,100 20,300 R00 3.6% County 749,R00 702,300 47,500 6.3 State 17,326,900 16,165,100 1,161,800 6.7 Unitcd States 144,R63,000 136,4R5,000 8,378,000 S.R 2003 City 21,900 21,100 R00 3.6 County 781,600 732,300 49,300 6.3 State 17,414,000 16,223,500 1,190,500 6.8 United States 146,510,000 137,736,000 R,774,000 6.0 2004 City 22,R00 22,100 700 3.3 County R I 2,000 764,900 47,100 5.8 State 17,SS2,300 16,459,900 1,092,400 6.2 United Statca 147,401,000 139,252,000 R,149,000 5.5 2005 City 24,000 23,300 700 2.R County 849,600 R06,700 42,900 S.l State 17,695,600 1 fi,746,900 94R,700 5.4 United States 149,321,000 141,730,000 7,591,000 5.1 2006 City 25,100 24,400 700 2.9 County 8R6,400 842,000 44,400 S.0 State 17,901,900 17,029,300 R72,600 4.9 United States 151,42R,000 144,427,000 701,000 4.6 Labor forcr data for thr Ciry,the County and the State reflect the March 2006 annual rr�ision or(benchmark)and Census 2000 population controls at the State le�el. Labor force data produced using older benchmarks are no longer comparable ro data based on ihe 2006 benchmark. Sources: ('uf�fr��n�n S�cne Em/�/ot•ment Dc��e/opment D�pariment nru�C/.S nepartrne�n�of Luhur.Bturm�u�Lu(x�� S1rul�tic:c. 070'_'9\puti--1 B-3 1�able 13-5 dcscribrs the largest employcrs in the City. Table 13-5 CITY OF PAL:VI DF.SER1'f LARGF,ST EMPLOYF.RS (As of January 1,2007) Number of Companv ProducUService F.mvloveeti JW Marriott Desert Springs Resort IIospitality 1,300 Securitas Securiry Svc USA Inc. Sccurity Se�vices 700 College of the Desen �ducation 630 Marriott's Desert Spas Villas Hospitality S00 Sunshine Landscape Landscaping Services 500 Desert Valley Industries Business Support Services 400 Man�iott Owncrship Rcsorts Inc. Hospitality 300 Sunrise Colony Co. Golf Course Community 250 Foundation For the Retarded Social Services 236 Time Warner Cable "fciccommunications 220 13ighorn Golf Club Golf Resort 220 Springs At the Fountains Convalescent and Nursinb Carc 200 Macy's West Retail 200 Monterey Palms Health Care Hcalthcare 200 Fountains At the Carlotta Convalescent and Nursing Care 200 Indian Ridge Country Club Golf Course Community 200 Williams Mechanical Inc. Plumbing 200 Palm Valley Country Club Golf Coursc Community 200 Koala Tee Printing Screen Printinb 200 j' Fcdcral and Statr Go�emment not included. Source: Amcrica's Labor�larket Information System(ALMIS). Commercial Activity A tiale� tax is imposed on retail salc or consumption of personal property. Sales tax rcvenues are determined by the tota] taxable transactions within a jurisdiction and distributed by the State Board of Equalization to the juri�diction where the sale took placr. Sales taxes collected from merchant, with no permanent place of bu�ineti� (i.c�., manufacturers, construction contractors, etc.) are accu►nulated to a Counrywidc or State-widc (out-of-state businesses) pool and distributed to cities and counties in proportion to thcir collections from all sales taxpayers. "I'hc valuc and volumc of the,e taxable transactions are dependent on economic conditions and othcr factors. Such factors included the level of inflation affecting the price of goods and services subjcct ro the sales tax, thc rate of population growth in the general area, the characteristics of retail dcvclopincnts, �uch as the relativc sizc of market service areas, the sensitivity of the types of businesses within the City to changcs in the economy, and competing retail establishments outside the City. A deterioration of economic conditions and other factors influencing taxable sales benerated in the City, may reduce thc City's sales tax revenues. u�o��r,i,o,-a B-4 l'able I3-6 �ummarizes taxable transactions in the City for calendar years 2001 throubh 2005. "1'ABL�: B-6 CI1'Y OF YALM UESF.R"I' Taxable Retail Sales Data Calendar Years 2001 to 2005' ($in 000's) 2001 2002 2003 2004 2005�`� RF.TAIL.STORI-:S Apparel Stores $93,792 597,924 $108,R29 �132,831 $14R,723 General Merchandise 272,856 278,583 307,186 340,277 374,757 Food Stores 52,2R2 51,73R 52,461 47,455 51,404 �:atinb& llrinking Places I55,91 1 148,228 152,SOR 167,315 ]76,486 IIome Furnishings and Appliances 125,130 129,623 135,694 155,921 154,580 Building Matcrials and Farm 64,251 54,111 56,180 68,737 66,579 Implcmcnts Auto Dealers and Auto Supplies 8,R25 6,904 R,21 1 S,R62 5,841 Scrvicc Stations 22,633 23,930 39,146 45,585 56,681 Other Retail Stores 220,250 228,2R6 243,474 264,129 2R2,2R6 TOTAL RETAIL STnRES 1,015,932 1,019,327 1,103,689 1,228,112 1,317,337 All Other Outlets 195,137 190,OSR 193,041 205,184 212,005 TOTAL ALL()l1TLF'I S S 1,211,069 �1,209,3 R5 $1,296,730 $1,433,296 g 1,529,342 Most recent annual data a�ailablr. Source: Stute Buurd ojEqunli_ution. Construction Activity In calendar year 2006, the City issued construction pennits valued in excess of$257 million. Of this amount, approximately 42.5% consisted of new single family construction and approximately 14.2% consisted of new multifamily construction. A five-year history of building permits and valuation appears in 1�able B-7. Table B-7 C[TY OF' PALM UESER"f BUILDING PEItMITS AND VALUATIONS 2002-2006 Residential Number of Units Nonresidcntial Valuation Valuation Year Sin�le Familv Multifamilv ($in 000's)+ ($in 000's)' Total 2002 221 310 $100,486.0 541,413.7 $141,R99.7 2003 237 101 R6,387.6 20,123.0 106,510.6 2004 325 111 103,73R.2 43,112.1 146,R50.3 2005 100 135 78,130.9 92,535.4 170,663.3 2006 285 442 163,104.8 94,310.R 257,415.6 � Includcs value of individual unrts,alrerations and addmons. Sourcr: Cunctilictrun/ridte�tr}'Resenrcl�6oeud.QuildinY Permit Suivei:c. n�u�y��,ot-a B-5 Ycrsonal Incomc 'l�otal personal income is defined by the Bureau of T:conomic Analysis (the"BEA"), an agency of the U.S. [)cpartmcnt of Commercc as income received from all sources, including income received from participation in production as well as from governmcnt and business transfer payments. It represents the sum of compensation of reccived by employees , supplements to wages and salaries, proprietors' income with inventory valuation adjustment and capital consumption adjustment(the"CCAdj"), rental income of persons with the C:Cndj, personal income receipts on assets, and personal current transfer receipts, less contributions for bovernment social insurancc. Per capita income is calculatcd as the personal incomc divided by the resident population based upon the Census f3ureau's annual midyear population estimates. The followin�; table summarizes the total personal income and per capita income lor the County, the State and the United States for the calendar years 2002 through 2006. Although the City is the lOth largcst city within the Counry, the I3LA does not currently maintain separate incomc data for thc City. See also" Population." Tablc A-6 RIVERSIDE COUN"1'Y STATE OF CAI,IFORNIA AND l,'NITEU S"1'A"1'ES Pcrsonal Income Total Personal Income Per Capita Year and Area ithousands of dollars) 1'crsonal Income 2006 Counry $ $ State 1,434,909,558 39,358 United Statec 10,966,80R,000 36,629 2005 Counry 52,850,398 27,167 State 1,347,942,750 37,283 United States 10,284,37R,000 34,fiR5 2004 County 49,225,374 26,361 State 1,265,657,107 35,313 United States 9,711,271,000 33,072 2003 County 45,023,257 25,276 State 1,187,040,144 33,469 United States 9,]50,320,000 31,466 2002 County 42,010,066 24,7R9 State 1,147,715,704 32,769 United States 8,R72,871,000 30,795 Source: U.S.Department of C'ornmerce, Bureau of Economic Analysis. 0702y.pos-�3 H-f1 Utilities Water, sewagc trcatment and ���aste�vatcr disposal are provided by the Coachella Valley Water District. Southern California Gas Company supplies natural gas to the City and electric power is provided by thc Southern California Edison Company. 'I'elephone sen�icc is available through Verizon. Cable television servicc is provided by�l�ime Warner. Transportation Inter-City transportation is provided by Greyhound Bus which providcs scrvice from its connection points in the City ro its lines outside of the City in addition ro thc community owned and operated Sunline �us System which provides service throughout the entire Coachella Valley. Intra-City transportation is provided by Tel-a-Ride and local taxi finns. The City's ccntral highways are California Highway 1 1 1 and 74 which conncct to US Interstate 10 and to California lIighway 63 and 86. Shipping is providcd by numerous truck carriers which have overnight service to Los Angeles, San Francisco, San Diego and Phoenix. Rail transportation is provided by the Southern Pacific Railroad located in Indio, l0 miles east of the City, and by Amtrak, which has two stations located in Coachclla Vallcy. A full service airport is located in Palm Springs, 12 milcs northwect of the City, with approximatcly scven carriers providing service. The ai�port has an R,500 foot runway and general aviation facilitics. Thcre is also a private airport in Bermuda Dunes,eight miles northeast of the City. Communitv Services The City of Palm Decert provide� both policc and fire protection through contracts with the County of Riverside. The Riverside County Public Library Systcm provides library services to the City. The City also operates a 43,000 square foot public library on the Collcge of the Desert campus which is jointly used by the public and the College of thc Desert. Education,Culturc and Recrcation Educution. Public school education is provided by the Desert Sands Unified School Uistrict (the "School I)istrict"). 'I'he School District provides preschool through grade 12 education ro students living in the C'ity and the communities of Indian Wells, Indio, La Quinta, Rancho Mirabe and Bermuda Dunes. The School District operates three elementary schools, one middle school and one comprehensive high school. During I-�iscal year 2006-07 there were 5,942 students attending classes in schools located within the City. Thc Collcge of the Uecert, the Coachclla Valley Community College is located in the City. A satellite campus of California State Univercity, San Bcrnardino ("CSUSB") is located approximatcly five miles northeast of City Hall. In November 2006, CSUSB commenced construction of an approximately 23,000 square foot health sciences building containing labs, classrooms and an electronic library. This facility is expected to be completed in 200R and will complete the initial three-building phase ot� the CSUSF3 Palm Desert Campus, which includcs the approximately 37,000 square foot three-story Mary Stuart Rogers Gateway }3uilding which was completcd in 2002 and the approximately 30,000 square foot three-story Indian Wells Center for Educational Excellencc and the 300-seat perfonning arts Indian Wcll, Theater both of which were completed in 2005. o�o��r,P„s-a B-7 The University ofCalifornia, Riverside has also established a campus in the City. 'fhe UCR Palm I�cscrt Graduate Center opened as a pennanent satellitc campus in 2005, �vhen construction was completed cm tlie approximately 21,200 square foot Richard J. Heckmann International Center f��r lintreprcncurial Management and an approximatcly 23,600 square foot educational facility. Culturc and Recreation. Culwral facilitics in thc City include the 1,127 scat McCallum Theatcr for the Performing Arts located in Bob Iiopc Cultural Center, thc 1,200 acre Living Desert Loo and Gardens, and the Art in Public Placcs (a muscum without walls fcaturing more than 130 works of�art throughout the City). Recrcation programs for residents of the City and other neighboring communities are offered throubh the Coachella Vallcy Recrcation and Park District (the "Park District"). Thc Yark District provides rccreational activities and programs ranging from tiny tots programs, kids clubs and summer day camp, to dance, health and fitness and music instruction, to the senior games. The I�esert Willow Golf Resort, two championship 1R-hole, public golf course, is locatcd on approximately $40 acres in the northern area of the City. l�his golf course also features a 33,000 square foot clubhouse with restaurant, dining and banquet tacilities. Thc Ciry also is home to five other public golf courses and resorts and 20 private or semi-private bolf clubs and resorts. a�n�9�i,�,..a B-R nrrEnn�x c SUMMARY OF PRINCIPAL LF,GAL UOCU11'IEI�TS Thc� /i�//oiring i.c n hric�/�.sumntur�• oJ �hc� /n•ori.sinn.c oJ thc� /nrlenttu•c�. Such .stunnuuy i.s no! intendc>d ro he�rlc�/ini�ii•e�. unc!r-c�Ji�rc�nce i.s mc��/e�o lhc�contple�e ducinn�nt.s/i�r thc�cump/e�te�tc�rms�/u�rc�uf n�o��,�,o,-.� C-1 ANPEI�UIX D H'ORn1 OI��OPII�ION()F BOI�D COUNSEL o�a��r..p�,ti-a I)-1 APPEVUIX E FOItM OF CON"I'Il�U1NG DISCLOStiRF,A(;It�;E1�iF.l�T The Continuing Disclosure Agreement (the "Uisclosure Abreement") is executed and delivered by and among the City of Palm Desert Community Pacilitics Di,trict No. 91-1 (Indian Ridge Public Improvements) (thc "District"), Wclls Farbo Bank, National Association (the "�l�rustee") and MuniFinancial, Inc. (the "Uisscmination Agent") in connection with the issuance of the $ principal amount of thc City of Palm Desert Community Pacilities vistrict No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding I3ondc. Series 2008 (the"Bonds"). The Bonds are beinb executed and delivered pur,uant to an Bond Indenture dated as of January l, 200R (the "Indenturc"), by and between thc District and the"I�rustee. The Uistrict covcnants and agrccs ac follows: SECTION 1. Pumose of this Disclosure Agrcement. This Disclosure Abrccmcnt is being executed and delivered by the District for the benefit of the I Iolders and Beneficial Owners of the Bonds and in order to assist thc Participatinb Underwriters in complying with Securities and Exchange Commission("SEC") Rule 15c2-12(b)(5). SF.CTION 2. Uefinitions. In addition to the definitions sct forih in the Indcnture, which apply to any capitalized term used in this Disclosure Agrccment UIlICtiti otherwise defincd in thic Section, thc following capitalized tenns shall have the follo���ing meanin�;s: "Annual Report" shall mean any annual report provided by the Dist�ict pursuant to, and as described in, Sections 3 and 4 of this Disclosurc Agreemcnt. "Beneficial Owner" shall mean any person which (a) has the power, dircctly or indirectly, to votc or consent with respect to, or to dispose of ownership of, any Bonds (including persons holdinb Bonds through nominees, dcpositories or other intermediaries) or (b) is treated as the owner of any Bonds for federal incomc tax purposes. "Central {'ost Office" shall mcan the Disclosure USA website maintained by the Municipal Advisory Council of Texas or any succeti�or thereto, or any othcr organization or mcthod approved by the staff or members of the Securities and Lxchange Commission aa an intermediary through which issuers may, in compliance with thc Rule,make filings required by thi�Continuing Disclosure Certificate. "Dissemination Agent" shall mean MuniFinancial, Inc., acting in its capacity as Dissemination Agcni hereunder, or any successor Dissemination /lgent designated in writing by the District and �vhich has filed with the Trustee a written acceptance of such designation. "Fiscal Year" shall ►nean with respect to the District, the period be�;inning on July 1 of each year and ending on the next succeeding Junc 30, or any twelve month or 52 week period thereafter ticlected by thc DiStrict with notice of such scicction of change in fiscal ycar to be provided as�ct forth herein. "liolders" shall mean cither the registcred owner� of�the Bonds, or, if the 13onds are registered in the name of 1�he Deposirory Trust Company or another recognized deposirory, any applicable participant in its depository system. "Listed Lvcnt"shall mean any of the events listed in Section 5(a) of this Disclosure Agreement. "National Repository" shall mean any Nationally Recognized Municipal Securities [nfonnation Repository for purposes of the Rule. A list of the current National Repositories approved by the S.F.C. may be found at the S.E.C. website: http://www.sec.gov/info/municipal/nrmsir.htm. o�o�e�F,,,,-a E-1 "1'articipatinb Underwriters" shall Illl'dtl Stinson Secw�ities, LLC and Kinscll, Newcomb & De Dios, Inc., as the oribinal underwrite�s of the �3onds rcyuired to comply ���ith the Rule in connection with offerinb of the Bonds. "Repository"shall mean each National Repository and each Statc Repository, if any. "Kule" shall mean Rule 15c2-12(b)(5) adoptcd by the Securitics and h:xchange Commission under the Securities Exchangc Act of 1934, as the same may be amcnded from time to time. "State"shall mean the State of California. "State Repository" shall mean any public or privatc repository or entity dcsi�;natcd by the State as a state repository for the purposc of the Rule and recognized as such by the Securities and Exchangc Commission. �1s of the date of this Disclosure Agreemcnt, there is no State Rcpository. SECTION 3. Provision of Annual Reports. (a) The District shall, not later than six months after the end thc City's l�iscal Year (which currently is June 30), commencinb with the report for the [2006-07] I�iScal Year, provide to each Repository an Annual Report which is consistent with the requircmcnts of Section 4 of this Disclosure Agreement. The Annual Repo��t may bc submitted as a single document or as separate documents comprising a package, and may includc by reference othcr information as provided in Scction 4 of this Disclosurc Abrccmcnt; providcd that the audited financial statcmcnts of the District may be submitted separately from the balance of the Annual Report. The District ,hall provide a written certification �vith cach Annual Report furnished to the Dissemination Agent and the "I�rustee to thc effect that such Annual Report constitutes the Annual Report required to be furnished by the District hereundcr. The DisScmination Agent and the Trustee may conclusively rely upon such certification of the District. If the District's Fiscal Year changes, it shall give notice of such change in the same manncr as for a Listed Event under Section 5(c). (b) If thc Uissemination Agent is other than the District, thcn not later than fifteen (15) Business DayS prior to said date, the Uistrict shall provide the Annual Report to thc Disscmination Agent. If the Uissemination Agent is unable to verify that an Annual Rcport has becn provided to the Rcpositorie� by the date required in subsection (a), the Dissemination Agent shall send a notice to the Municipal Securities Rulemakinb I3oard and the Statc Repository, if any, in substantially the fonn attached as F.xhibit A to this Disclosure Agreemcnt. (c) l�he Disscmination A�;cnt shall: (i) determine each year prior to the date for providing the Annual Report the name and address of each Repository; (ii) file the Annual Report with each Repository by the date reyuired therefor by Section 3(a) and file any notice of a listed �vent, if requested by the District, as soon as practicable following receipt from thc District of such notice; and (iii) if the Dissemination Abent is other than the Uistrict, tile a report with the District certifying that the Annual Report has been provided pursuant to this Disclosure Agreement, stating the date it was provided and listin�all the Repositories to which it was provided. o�o��r,4x„-a E-2 (d) Notwithstanding any other provision of thi� Continuing Uisclosur� Certificate, thc City and thc Dissemination A�;cnt reserve thc ri�ht to make any of the aiorcmcntioned filin�s through the Ccntral Post Of�ficc. S�C'I�ION 4. Cbntent of Annual Renorts. (a) The District's Annual Rcport shall contain or incor��orate by reference the following infonnation for the immediately prcceding Fiscal Year substantially similar to that providcd in the following tables and charts in thc Official Statcmcnt: (i) Table 6 I'roperty Classification By I.and Use Categories; (ii) "Cable 7 Asscssed Value-to Special Tax Lien Categories; (iii) Table 8 I'roperty Owner� F3y Asses�cd Valuation and Prorated Lien; and (iv) Table 9 -Historical Spccial Tax Uclinquency. (b) 'Che outstanding principal amount of Honds for the precedin� Fiscal Year. Such annual infonnation and operating data de�cribcd above may be included by specitic refcrence to other documcnts, including official statements of dcbt issues of the District or he Ciry, which have been submitted to each of the Repositories or the Securities and Exchange Commission; proi�iderl, that if the documents included by reference is a final ofticial statement, it must be available from the Municipal Securitics Rulemaking Board; and prorided�w•ther, that the District shall clearly identify each tiuch other documcnt �o included by refercnce. SI:C'I ION $. Reportin��of Sit�nificant Events. (a) Pursuant to the provisions of this Section 5, the District shall givc, or cause to be givcn, notice of the occun�ence of any of the following events with re�pect ro the Bonds, if matcrial: (i) principal and interest payment delinqucncies. (ii) non-paymcnt related defaults. (iii) modifications to rights of I3ondholders. (iv) optional,contingent or unscheduled bond calls. (v) deteasances. (��i) rating changes. (vii) adverse tax opinions or e��ents adversely affecting the tax-exempt status of the Bonds. (viii) unschedulcd draws on thc Recerve Account reflecting financial difticulties. (ix) unschedulcd draws on the credit enhancemcnts reflecting financial difficulties. (x) �ub�titution of�thc credit or liquidity providers or their failure to perionn. o�n,y�.ix„-� E-3 (xi) rcicase, substitution or sale of property sccuring repayment ot�the F�onds. (b) The"l�rustcc shall, promptly upon obtaining actual knowledge of the occui-��ence of any of the I.isted Cvents contact thc Disclosure Representative, lI1tOI7I1 such person of the event, and request that the District promptly notify the Disscmination Agent in writin� whether or not to report the event pursuant to subsrction (� and promptly notify the Trustee in writing �vhether a�not to report the evcnt to the Owners (unless noticc ro the nwncrs is required by the Indenture). For pur��oses of this [)isclosure Agreement, "actual knowlcdge" of thc occurrence of such I.isted Tivents shall mean actual knowledge by the officer at the Trust Office of the Trustee with regular responsibility for the administration of the Indenture. (c) Whcncver the District obtains knowledge of the occurrencc of a Listed Event, whether because of a notice from the Trustec pursuant to Section 5(b) or otherwise, the District shall as soon as possible deteimine if such event would be material under applicable federal securities laws. (d) If the District detectnines that knowledge of the occun•cnce of a I_istcd l:vent would be material undcr applicable federal securities laws, thc District 5ha11 promptly notify the I)issemination Agent and the Trustee in writinb. Such notice shall instruct the Dissemination Abent to file a notice of �uch occurrence with the Municipal Securities Rulemaking Board and thc State Repository, if any. Notwithstanding the foregoing, notice of Listcd Events described in subsections (a)(iv) and (a)(v) need not be givcn under thi� subsection any earlicr than thc notice (if any) of thc underlying event is given to Holders of affccted Bonds pursuant to the Indenture. (e) If in recponse to a request under tiubsection (b), the District deterrnines that the I.isted l:vent is not material, the District shall co notify the Disscmination Agent and thc Trustee in writing and instruct the Dissemination A�;ent and thc'Crustee not to report the occurrence. SECTION 6. 1�ennination of Renorting Obli�ation. The obligations of the District undcr this llisclosure Agrcement shall terminate upon the lega] defeasance, prior redemption or payment in full of all of the Bonds. If such termination occurs prior to the final maturity of the Bonds, the District shall givr notice of such tcr�nination in the samc manner as for a Listcd E��ent under Section 5(c), Sf:CTION 7. Dissemination AQent. The District rnay, from time to timc, appoint or engagr a Dissemination Agent to assist it in carryin�; out its obligations under this Disclosure Agreement, and may discharge any such Dissemination Agent, with or without appointing a succcssor Dissemination Agent. The Dissemination Agcnt shall not be responsible in any manner for the content of any noticc or report prepared by thc District pursuant to this Disclosure Agreemcnt. Thc initial Dissemination Agent shall be the Munil�inancial, Inc. The Ui�sctnination Agent may resign its duties hercunder at any time upon written notice to the District. SECTION R. Amendmcnt. Notwithstanding any other provision of this Disclosurc Agreement, the parities may amend this Disclosure Agreement (and thc Trustee and the Dissemination Agent shall agree to any amendmcnt so requested by the District provided that ncither the Trustee nor the Dissemination ngent shall be obligated to enter into any such amendment that modifies or increases its duties or obligations hereunder)only if: (a) the amendment i~ made in connection with a change in circumstances that arises from a change in lcgal rcquirements, change in law, or changc in identity, nature, or status of the District,or type of business conducted; n�my.4,�,.-a E-4 (b) this Disclosure ngreemcnt, as amended, �vould have compiled ���ith the requirements of thc Rulc at the time of sale of the Fionds, ai�ter taking into account any amendments or interprctations of tlic }tule, as well as any chaii�c in circumstances; (c) the amcndment does not materially impair thc interests of the O�;mcrs, as drtennined by parties unaffiliated with the Uistrict (such as, but without limitation, the District's bond counscl) or by Owner's consent purcuant to Section 7.01 of the Indenture; and (d) the annual financial information containing (if applicablc) the amended operating data or financial infonnation will explain, in nan�ative fonn, the rcasons for the amcndment and the "impact" (as that word is used in the letter fi�om the staff of the Securities and Exchangc Commission to the National Association of Bond I.awyers dated June 23, 1995)of the change in the type of operatinb data or financial information being provided. SECTION 9. Additional Information. (a) The District agrees to provide public infonnation conccrnin�; the Bonds and the District to any Holder or Beneficial Owner makinb a written request therefor. (b) Nothinb in this Disclosure Agreemcnt shall be dccmed to prevent the District from disseminating any othcr information, using the means of dissemination set forth in this Disclosurc Abrcement or any other ►neans of communication, or including any other information in any Annual Rcport or notice of occurrence of a Listed T:vent, in addition to that which is required by this Disclosure Agreement. If the District chooscs to include any information in any Annual Report or notice of occurrcnce of a Listed Event in addition ro that which is specifically required by this Disclosure Agreemcnt, the District shall have no obligation under this Disclosure t�greement to update auch infomiation or include it in any t�uture Annual Report or notice of occurrence of a Listed Event. SECTION 10. Default. In thc even to a failure of the District to comply with any provision of thic Disclosure Agreement, the Trustee shall, at the written direction of any Participating Underwriter or the Owners of a majority in aggregate principal amount of Outstanding Bonds (but only to the extent funds have been providcd to it or it has been otherwise indemnified to its satisfaction trom any cost, liability, expense or additional charges of the 1'rustee whatsoevcr, including, without limitation, fees and expenses of its attomeys), or any Owncr may, take such actions as may be ncccssary and appropriate, including seeking mandate or specific perfonnance by court order, to cause the District, the"I�rustec or the Dissemination Agcnt, as the case may be, to comply with its obligations under this Disclosure Agreement; provided that any such action may be instituted only in the Federal or State Court located in the County of Los Angeles, State of California and no remedy other than spccific performancc may be sought or granted. A default under this Disclosure Agreement shall not be deemed an Lvent of Dcfault under the Indenturc or thc Loan Agrccment, and the sole remedy under this Disclosure Agreement in the event of a failure of the District, the Tiustcc or the Dissemination Agent to comply with this Disclosure A�*rccmcnt shall be an action to compel performance. SECTION 11. Duties, Immunities and Liabilities of Dissemination Agent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclocure Agreement, and the District agrees to indemnify and save the Dissemination Agent and thc Trustee, their ofticers, directors, employees and agents, harmless against any loss, expense and liabilities which it ►nay incur arising out of or in thc cxcrcise or performance of its powers and duties hereunder, including the costs and expenses (including attorneys fccs) of defending against any claim of liability, but excluding liabilities due ro the Dissemination Agent's or Trustee's negligencc or willful misconduct. Thc Dissemination Agent may rely on and shall be protected in acting or refraining from acting upon any dircction from thc Issucr or an opinion of nationally recognized bond counscl. The Uisscmination Agent and the Trustee shall be paid u�u?y�,�,.a r-s compensation by the District tin- its sen�ices provided hercunder in accordance with its schedule of fers as amended from time to time and all expenscs, legal fees and advanccs made or incurred by thc Disscmination Abent in the perfonnance oi' its duties hcreundcr. The I)issemination Agent and thc 'frustee shall have no duty or oblibation ro review any information provided to them by the Uistrict hereunder and shall not be deemed to be acting in a tiduciary capacity for the District, the City, the Owners, or any other pa►-ty. The oblibations of the District undcr this Section shall survivc resignation or removal of the vissemination Agent and payment ot� the Fionds. No person shall have any right to commence any action against thc Dissemination Abcnt ceeking any remedy other than ro compel spccific performance of this Disclosure Agreemcnt. Thc Di�semination A�;ent shall not be liable under any circumstances for monetary damages to any person ti�r any breach of this Disclosure Agreement. SECI�ION 12. Beneficiaries. This Disclosure /\grcement shall inure solrly to the benefit of the District, the Participating Undcrwriters, the Dissemination Agent and Ilolders and Beneficial Owners from time to tirne of the Bonds, and shall create no right�in any othcr person or cntity. ST:CTInN 13. Notices. Notices should be sent in writing to the following addressec. 1'he following infonnation may be conclusively rclied upon until changed in writing. District: City ot� Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvcments) 73-510 I��rcd Warinb Drive Pahn Desert, California 9221�0 (760) 346-0611 (760) 346-0574 Fax 'I'rustee: Wclls Fargo Ban[c, National Association 700 South Flowe►•Street, Suite 500 I.o� Angeles,Califomia 90017-4104 (213) 630-6237 (213) 630-6215 Fax Disscmination t�gency: MuniFinancial, Inc. 2731,R Via lndustrial, Suite 10 Temecula, California 92590 (951) SR7-3500 (951) 587-3510 Fax n�uz4,p�,s-� l:-f� S�:C�I�ION 14. Counte�parts. 1�his Uisclosurc A�recmcnt may bc cxccuted in scveral counterparts, each of�vhich shall be an original and all of���hich shall constitute but one and the same instru►nent. Date: , 2008 CI'1'Y OF PnLM DESrRT COMMUNITY FACILITll?S U[STRICT NO. 91-1 (INUTAN RInGl: PUBLIC IMPROVEMENTS) By: Authorized Officer WF.I.LS FARGO Bt�NK, NnTIONAL ASSOCIA"CION, as Trustee 13y: Authorized Officer MLTNIFINANCIAL, INC., as Disscmination Agent By: Authori�ed Officcr o�oz��,�o�-� �:-7 �.XIIIBIT A NO'I�ICf�.7�0 MUNICIPnL SECURI'I�[I:S RULEMAKING [�OAR[) OP rA1I.URE TO I'ILI; ANNUAL R�:I'ORT Name ofObligatcd Party: City of Palm Dcsen Community I�acilitics District No. 91-1 (Indian Ridge Public Improvements) Name of Bond Issue: City of�Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Spccial Tax Refunding Bonds, Series 200R Uatc of Issuance: , 200R NOTICE IS HERF.BY GIVEN that thc City of Palm Dcscrt Community Facilities District No. 91-1 (Indian Ridge Public Improvement�) (the "District") has not provided an nnnual Report with respect to the abovc-named Bonds as required by Section 5.2 of the Bond Indenture datcd as of January 1, 200R, by and bctween llistrict and thc Trustee. "I�he District anticipates that the Annual Keport will be filed by Dated: WT:I.I.S FARGO BANK, NATIONAL ASSOCIATION, as"I�rustec, on behalf of the District By: Its: cc: City of�Yalrn Uesert Community i�acilities District No. 91-1 (lndian Ridge Public Improvements) n�o�e,�„-a �-R AI'I'ENDIX F DTC AVD "I'HE BOOK-F,NTRY ONLY SYS"1'EM Thc� inJor-mution in �/ti.ti Appc�ncli.r !�concc�rning Thc� Dc�posi�urt Ti•cr.ct Compun}•, Nc i+� ]'ork. Nc�it� Ya�k ("U1�C") und DTC'.c honk-c�nn�i' s}�.clenr hus bec�n ohtuinect /i�om DTC and tl7e District tcrkc�.� no rc�spun.cihilit►� f�r thc> com/�lc�tc��tc�ss ur ucccu•ucy� thc�r��o/: 7he Di.ctrict cc�nnot crnd d��c�.c not givc� an}• us.surunec�s �hu[ DTC, UTC Pcrrtici��c�nts or/nclir�et Pcu�ticipunts tirill di.�•t�•ihtrle� to thc� Bc�neTciu/ Ox•ner.c (u) pu}�ments o/ inte�re�.ct, principa! or premit�m. i/ un}�, �a�it{� recp�ct to tlic� Sc�rie.c 20Ut� Bond.,•, (h) cc�rli/icutes rep�•e.��c�nting otirnc�iship inlc°��c�st in or other con/irmuliun or rnrnc�r.��hip in�e�re�.st in thc� Seric�.c 10O8 Bonc/s, or(c•) rc��lc�mption oi•e�the�r no�iccs sent lo DTC or Cede c� Co.. it.c nontince, us !h�re�gi.cterc�d utirner o/the Sc�ric�.c 2008 Ronds, or thut thc�ti� �t�ill.so dn on u timelr husi.c, or�rh�u/)%'C, DTC Purticipuntc or DTC Inclirc�ct Pcrr7icipunt.s �a�i!/ uct in �hc� munner c/e�sc•ribe��t in this �Ippc�ndix. The� c�u�i�ent "Rules" u/�plicuhle� to DTC nrc� un /i1c� irith Ihc� Se�ctu•ities und Exchange� Commis.cion «ncl the ciu•rc�n1 "Procechu•e.c"o/U%�C to bc follo�rc�d in cte�ling ti+�ith DTC Purticipunt.s ure�on/ilc� x�ith DTC. 'l�hc Depository Trust Company("DTC"), New York, NY, will act as securities depository for the Series 200R Bonds. The Series 200R I3onds will be issued as fully-registcred securities registered in the name of Ccde & Co. (DTC's partncrship nominee) or such other name as may be requested by an authorized representative of�DTC. One fully-registered security ccrtificate will bc issued for each maturity of�the Series 2008 Bond�, each in the aggregate principal amount of cuch maturity, and will be depositcd with D"I'C. DTC, the world's largest depository, is a limited-purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Rcscrve System, a "clearing corporation" within the meaning of thc New York Unifonn Commercial Codc, and a "clearing agency" registered pursuant to the provisions of Section 17A of thc Securities Exchange Act of� 1934. DTC holds and provides a,5et �ervicing for over 2.2 million issues of U.S. and non-U.S. equity is5uec, corporate and municipal debt issues, and money market instruments from ovcr l00 countries that DTC's participants ("Direct Participants") deposit with DTC. D"I�C also facilitates the post-trade settlement among Dircct Participants of sales and other securities transactions in deposited securities, through electronic computerized book-cntry transfers and pledges bctween Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants includc both U.S. and non-U.S. securities brokers and dcalers, banks, trust companies, clearing corporations, and ccrtain other organizations. I�TC is a wholly-owned subsidiary of "l�hc Depo,itory Trust & Clearing Co►poration("D1�CC"). DTCC, in turn, is owned by a numbcr of Direct Participants of DTC and Members of thc National Securities Clearing Corporation, Governmcnt Securities Clearing Corporation, MBS Clearing Corporation, and F.tnerging Markets Clearing Corporation, (respectively, "NSCC", "GSCC", "MBSCC", and "EMCC", also subsidiaries of DTCC), as well as by the New York Srock Exchan�;c, Inc., the American Stock Gxchange LLC, and the National A,sociation of Securities Dcalcrs, Inc. Access to the DTC system is also availablc to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial rclationship with a Direct Participant, either directly or indirectly ("Indircct Yarticipants"). DTC has Standard & Poor's hibhest rating: AAA. '1'he DTC Rules applicable to its Yarticipants are on tile with the Securitics and Exchanbe Commission. More info�mation about DTC can be found at www.dtcc.com and www.dtc.org. Purchases of the Series 2008 13onds under the DTC system must be made by or through Direct Participants, which will receive a credit for the Scries 2008 Bonds on DTC's records. "l�he owncrship interest of each actual purchascr of� each Bond ("Beneficial Owner") is in turn to be recorded on thc Direct and Indirect Nariicipants' records. Beneficial Owners will not receive written confirmation from DTC of thcir purchase. Beneficial Owncrs are, howe��cr, cxpected to receive written confirmations n�a�yy,�„-a F-1 pro��iding details of the tran�action, as well as periodic statements of thcir holdingti, frrnn thc I)irect or Indircct Participant through which the f3eneficial nwner cntered into thc transaction. Transfcrs of owncrship interests in thc Scries 200R Bonds are to bc accrnnplished by entrics made on the books of Direct and Indirect I'articipants aeting on bchalf of I3eneficial Owners. Bcncticial (hvners will not rcecive certiGcatcs rcpresenting their ownership interests in the Series 2008 I3onds, except in the cvent that use of the book-cntry system for thc Scries 200R Iiond� is discontinued. To facilitate subsequent transfers, all Series 200R Bonds deposited by I)irect Participants with nTC are registcrcd in the name of U'I�C's partnership nomincc, Cede 8c Co., or such other name as may be requestcd by an authorized representative of [)TC. The deposit of thc Series 200R Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial owncrship. DTC has no knowledge of the actual I3eneticial Owncrs of the Series 200R Bonds; D1'C's recordc retlect only the idcntiry of the Direct Participants to whose accounts such 13onds are creditcd, which may or may not be the Beneficial Ou�ncrs. The Direct al�d Indirect }'articipants wil! remain responsiblc for keeping account of their holdinbs on behalf of their customers. Conveyanee of notices and other communications by D1'C to Direct Participants, by nirect }'articipants to Indirect Participants, and by Direct Participants and Indirect I'articipants to Beneficial Owners will bc boverned by arranbcmcnts amonb them, subject to any �tatutory or regulatory requiremcnts as may be in effect from time to time. Beneficial (lwners of�thc Series 2008 Bonds may wish to take certain steps to augmcnt the trantimission to thcm of noticcs of significant events with respect to thc Scries 200$ Bonds, such as redemptions, tenders, dcfaults, and proposcd amendments to the Indenture. For cxample, Beneficial Owners of the Serics 200R Bonds may wish to asccrtain that the nominec holding the Series 2008 Bonds for their bcnefit has agreed to obtain and transmit notices to B�neficial Owners, In thc alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of notices be provided directly to ihem. Redemption notices shall bc sent to DTC. The conveyance of notices and other communications by DTC ro D"I�C Participants, by DTC Participants to Indirect Participants and by DTC Participants and Indirect Participants to Beneficial Ownen will bc boverned by arrangements among them, subject to any statutory or regulatory requiremcnts as may be in cffect from time to time. Any failure of DTC to advise any DTC Participant, or of any DTC Participant or Indirect Participant to notify a Beneficial Owner, of any such notice and its content or effect will not affcct the validity of the redemption ot�the Series 200R F3ond� called for redemption or of any other action premised on such notice. Redemption of portions of the Serics 200R Bonds by the District will reduce the outstanding principal amount of Bonds held by D�I�C. In such event, DTC will implement, through its book-entry systcm, a redemption by lot of interests in the Series 2008 Bonds held fc�r thc account of D7'C }'articipatits in accordance with its own rule, or other agreemcnts with I�'I�C Participants and then DTC Narticipants and Indirect Participants will implement a redcmption of thc Series 200R Bonds tor the I3eneficial Owners. Any such selection of Bonds to bc redecmcd will not be go��emed by thc lndenturc and will not be conductcd by the District or the Trustee. Ncither DTC nor Cede& Co. (nor any other DTC norninee) will consent or vote with respect to the Series 2008 Bonds unless authori�ed by a Uirect Participant in accordance with D"['C's Procedures. Under its usual proccdures, D"l�C mails an Omnibus Proxy ro the issuer as soon as possible aftcr the record date. The Omnibus Proxy assigns Cede & Co.'s consentinb or voting rightc to those Direct Participants to whose accounts the Series 2008 Bonds are credited on the record date (identificd in a listing attachcd to the Omnibus Proxy). Paymcnts of principal of, premium, if any, and interest evidenced by the Series 2008 I�onds will be made to Ccde & Co., or such other nominee a� may be requested by an authorized representative of DTC. DTC's practice is to crcdit Direct Participants' accounts upon DTC's receipt of funds and n�n��r,i,�„-a F-2 correspondinb detail inti�rmation trom the Uistrict or the'1'rustec, on payable date in accordance���ith thcir respectivc holding` shown on I�TC's rccords. Payments by Participants to Bcncficial Owners will bc govcrned by standing instructions and customary practice�, as is the case with securities held for the accounts of customcrs in bearer fonn or rcbistered in"street name,"and will be the responsibility of such Yarticipant and no1 of DTC (nor its nominec), the �Crustce, or thc District, subject to any statutory or regulatory requirements as may bc in effect from time to time. Payment of principal of, premium, if any, and interest cvidcnced by the Series 200R Bonds to Ccde & Co. (or such other nomincc as may be requested by an authorized representative of DTC) is the respon�ibility of the District or thc Trustee, disbursement of such payments to Direct Participants will be the responsibiliry of�ll"CC, and disbursement of such payments to thc Bcneticial Uwners will be the responsibility of I�irect and Indirect Participants. NLI'I'HI;R 'I'HE DISTRICT NOR "I'HE TRUSI�I:I: WILL HAVE ANY RESPONSIBII.ITY OR OBLIGA'1'ION TO DTC PARTICIPAN'CS, INDIRECI� PARTICINANTS OR BENEFICIAI. OWNERS WITH RF.SPECT TO TIIE PAYMF.NTS OR THE PROVIDIN(� OF N01�ICE TO DTC PAR"I�ICIPANTS, [NDIRECT PARI�ICIPANTS OR BF.NEFICIAI. OWNERS OR 'I'HC SEI,F.CTION Of� BONDS FOR REDEMPTION. Neither the District nor thc Trustee can give any assurances that DTC, D'I�C Participants, Indirect Participants or others will distribute payments of principal of, premium, if any, and interest on the Scries 2008 I3onds paid to DTC or its nanince, as the registercd Owner, or any redemption or other notice, ro the f3eneticial Owners or that they will do so on a timcly basis or that DTC will serve and act in a manner describcd in this Of�ficial Statement. DTC may discontinue providing its serviccs as depository with respect to the Scries 2008 Bonds at any time by giving reasonable notice to the District or the Trustcc. Under such circumstances, in the event that a succcssor depository is not obtained, Bond ccrtificates are requircd to be printed and delivered. The District may decide to discontinue use of the system of book-entry transfers through D1�C (or a successor securities depository). In that event, Bond certificates �vill be printed and delivered. In the evcnt that thc book-entry system is discontinued as described above, the requirements of the Indrnture will apply. The foregoinb infonnation concerning DTC concerning and DTC's book-entry system has been provided by D7�C, and neither the District nor the�I�rustee take any responsibility for thc accuracy thercof. The District and the Trustec cannot and do not give any assuranccs that U"CC, thc Participants or others will distribute payments of principal, interest or premium, if any, evidenccd by thc Series 200R iiond. paid to DTC or its nominee as the registered owncr, or will distributc any redemption notices or othcr notices, to the Beneficial Owners, or that they will do so on a timely basis or will serve and act in the manncr described in this Official Statement. Neither the District nor the Trustee are responsible or liable for the failure of DTC or any Participant to make any payment or give any notice to a Bcncficial Owner with respect to the Series 2008 Bonds or an error or delay relating thcrcto. o�o2Q.ix��-a P-3 APPF,NDIX(: SPECIMEN FII�ANCIAL GI-ARAN"fY IVSCIRANCF. POL[CY o�u�y,�,�,s-a G-1 L&J Draft 11/28/07 CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (INDIAN RIDGE PUBLIC IMPROVEMENTS) SPEC[AL TAX REPUNDING BONUS SERIL'-S 200R CONTINUING DISCLOSURG AGREEMF.NT Thc Continuing Disclosure Agreement(the"Disclosure Agreement") is executed and delivcrcd by and among the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) (the"District"), Wells Fargo Bank, National Association (tlie"Trustee")and MuniFinancial, Inc. (the"Dissetnination Agent") in connection with the issuance of the � principal amount of the City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) Special Tax Refunding Bonds, Series 2008 (the"Bonds"). The Bonds are being executed and delivered pursuant to an Bond Indenture dated as of January 1, 2008 (the "Indenture"), by and between the District and the Trustee. The District covenants and agrees as follows: SECTION I. Purpose of this Disclosure Agreement. This llisclosure Agreement is being executed and delivered by the District for the benefit of the Holders and Beneficial Owners of the Bonds and in order to assist the Participating Underwriters in complying with Securities and Gxchange Commission ("SEC") Rule 15c2-12(b)(5). SECTION 2. Definitions. In addition to the definitions set forih in the Indenture, which apply to any capitalized term used in this Disclosure Agreement unless otherwise defined in this Section, the following capitalized terms shall have the following mcanings: "Annual Report"shall mean any annual repori provided by the District pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. "F3eneGcial Owner" shall mean any person which (a) lias the power, directly or indirectly, to vote or consent with respect to, or to dispose of ownership of, any 13onds(including persons holding Bonds through nominces, depositories or other intennediarics)or(b) is treated as the owner of any Bonds for fedcral income tax purposes. "(:entral ['ost Office" shall mean the Disclosure USA wcbsite maintained by the Municipal Advisory Council of Texas or any successor therew, ur any other organization or method approved by the stafT or mcmbers of the Sccurities and Exchange Commission as an intermediary through which issuers may, in compliance with the Rule, make filings required by this Continuing Disclosurc Certificate. "Uitisemination Agent"shall mean MuniFinancial, Inc., acting in its capacity as Dissemination Agent hereunder,or any successor Dissemination Agent designated in writing by the Uistrict and which has filed with the Trustee a written acceptance of such designation. "Fiscal Year"shall mean with respect to the District, the period beginning on July 1 of each ycar and ending on the next succeeding June 30, or any twelve month or 52 week period thereafter selected by the District with notice of such selection of change in fiscal year to be provided as set forth herein. "Holders" shall mean either the registered owners of the Bonds, or, if the Bonds are registered in the name of The Depository Trust Company or another recognized depositoiy, any applicable participant in its depusitory system. "Listed Lvent"shall mean any of the events listed in Section 5(a)of this Disclosure Agreement. "National Repository" shall mean any Nationally Recogniicd Municipal Securities ]nform�ition Repository for purposes of the Rule. A list of the current National Repositories approved by the S.E.C. may be found at the S.L;.C. website: http://www.sec.gov/info/municipal/nnnsir.htm. "Participating Undenvriters"shall mean Stinson Securities, LLC and Kinscll, Newcomb& De Dios, Inc., as the original underwriters of the Bonds required to comply with the Rule in connection with offering of the Bonds. "Repository"shall mean each National Repository and each State Repository, if any. "Rule" shall mean Rule 15c2-12(b)(5) adopted by the Securities and Exchange Commission under the Securities Fxchange Act of 1934, as the same inay be amended from time to time. "State"shall mean the State of California. "State Repository"shall mean any public or private repository or cntity designated by the State as a state repository for the purpose of the Rule and recognized as such by the Securities and Exchange Comrnission. As of the date of this Disclosure Agreement, there is no State Repository. SECTION 3. Provision of Annual Reports. (a) The District shall, not later than six months after the end the City's Fiscal Year(which currently is June 30), commencing with the report for the 2007-08 Piscal Year, provide to each Repository an Annual Report which is consistent witl� the requirements of Section 4 of this Disclosure Agreement. The Annual Report may be submitted as a single document or as separate documents comprising a package, and may include by reference other information as provided in Section 4 of this Disclosure Agreement; provided that the audited financial statements of the District may be submitted separately from the balance of the Annual Report. The District shall provide a written certification with each Annual Report furnished to the Dissemination Agent and the Trustee to the effect that such Annual Report constitutes the Annual Report reyuired to bc furnished by the District hereunder. Thc Dissemination Agcnt and the Trustee may conclusively rely upon such certiGcation of the District. If the I�istrict's Fiscal Year changes, it shall �ive notice of such change in the same manner as for a Listed E��ent under Section 5(c). (b) It�the Dissemination Agent is other than the District, then not later than fiRecn (15) Husiness Days prior to said date, the District shall provide thc Annual Report to thc llissemination Agcnt. If the Dissemination Agent is unable to verify that an Annual Report has been provided to the Repositories by the date reyuired in subsection (a), the Dissemination Agent shall send a notice to the Municipal Securities Rulemaking Board and the State Repository, if any, in substantially the form attached as F.xhibit A to this Disclosure Agreement. (c) The Dissemination Agent shall: (i) dctcnnine each year prior to the date for providing thc Annual Report the name and address of each Rcpository; (ii) tile the Annual Report with each Repository by the datc required thercfor by Section 3(a)and file any notice of a listed �vent, if requested by the District, as soon as practicable followinb receipt trom the District of such notice; and 2 (iii) if thc Dissemination Agcnt is other than the District, file a report with thc District certifying that the Annual Report has been provided pursuant to this Disclosure Agreement, statinb the date it was provided and listing all the Repositories to which it was provided. (d) Notwithstanding any other provision of this Continuing Disclosure Certiticate, the City and the Dissemination Agent reserve the right to make any of the aforcmentioned filings through the Central Post Office. SECTION 4. Content of Annual Rcports. (a) The District's Annual Report shall contain or incorporate by reference the following infonnation for the immediately preceding Fiscal Year substantially similar to that provided in the following tables and charts in the Official State►nent: (i) Table 6—Property Classification By Land Usc Categories; (ii) Table 7—Assessed Value-to Special Tax Lien Categories; (iii) Table 8 —Property Owners By Assessed Valuation and Prorated Lien; and (iv) Table 9—Historical Special Tax Uelinquency. (b) The outstanding principal amount of Bonds for the preceding Piscal Year. Such annual information and operating data described above may be included by speci(ic reference to other documents, including official statements of debt issues of the District or he City, which have been submitted to each of the Repositories or the Securities and Fxchangc Co►n►nission;provicled, that if the documents included by reference is a final official statement, it must be available trom the Vlunicipal Securities Rulemaking Board; and provided fiu•ther, that the District shall clearly identify each such other document so included by reference. SE(;TION 5. Rcportin�of Si�nificant Lvents. (a) Pursuant to the provisions of this Section 5, the District shall give, or cause to be given, notice of the occurrence of any of the following events with respect to the Bonds, if material: (i) principal and interest payment dclinquencies. (ii) non-payment related defaults. (iii) modifications ro rights of Bondholders. (iv) optional,contingent or unscheduled bond calls. (v) defeasances. (vi) rating changes. (vii) adverse tax opinions or events adversely affecting the tax-exempt status of the Bonds. (viii) unscheduled draws on the Reserve Account reflecting financial difticulties. 3 (ix) �mscheduled draws on the credit enhancements re(lecting financial difticulties. (x) substitution of ihe credit or liquidity providers or their failure to perform. (xi) release, substitution or sale of property securing repayment of the Bonds. (b) The Trustee shall, promptly upon obtaining actual knowledge of the occurrence of any of the Listed Events contact the Disclosure Representative, inform such person of the event, and request that the District promptly notify the Dissemination Agent in writing whether or not to report the event pursuant to subsection (�and promptly notify the Trustee in writing whether or not to report the event to the Owners(unless notice to the Owners is required by the Indenture). For purposes ofthis Disclosure Agreement, "actual knowledge"of the occurrence of'such Listed Events shall mean actual knowledge by the ofticer at the Trust Oftice of the Trustcc with regular responsibility for thc administration of the Indenture. (c) Whenever the District obtains knowledbe of the occurrence of a Listed Event, whether because of a notice fro►n the Trustee pursuant to Section 5(b)or otherwise, the District shall as soon as possible determine if such event would be material under applicable federal securities laws. (d) If the District determines that knowledge of the occurrence of a Listed Cvent would be material under applicable federal securities laws, the District shall promptly notify the Dissemination Agent and the Tc�ustee in writing. Such notice shall instruct the Dissemination Agent to tile a notice of such occurrence with the Municipal Securities Rulemaking Board and the State Repository, if any. Notwithstanding the foregoing, notice of Listed Events described in subsections (a)(iv)and(a)(v) need not be given under this subsection any earlier than the notice (if any)of the underlying event is given to Holdcrs uf at�fected F3onds pursuant to the Indenture. (e) If in response to a request under subsection (b), the Uistrict detennines that the Listed Event is not material,the District shall so notif'y the Dissemination Agent and the Trustee in writing and instruct the Dissemination Agent and the Trustee not to report the occurrence. SECTION 6. Termination of Reportin ��,Obli ag t�. The obligations of thc District under this Disclosure Agreement shall terminate upon the legal defeasance,prior redemption or payment in full of all of the Bonds. If such termination occurs prior to the final maturity of the Bonds, the District shall give notice of such termination in the same manner as for a Listed Event under Section 5(c). SECT'1ON 7. I�issemination A�ent. Thc District may, from timc to time, appoint or engage a Disscmination Agent to assist it in carryin�out its obligations under this Disclosure Agreement, and may discharge any such Dissemination Agent, with or without appointing a succcssor Dissemination Agent. The Dissemination Agent shall not be responsible in any manner for the content of any notice ur report prepared by the Uistrict pursuant to this Disclosure A�reement. The initial Dissemination Agent shall be the MuniFinancial, Inc. The Dissemination Agent may resign its duties here�mder at any time upon written notice to thc [liscricc. SECTION R. Amendment. Notwithstanding any other provision of this Disclosure Agreement, thc parities may amend this Uisclosure Agreement (and the Trustee and the Disscmination Agent shall agree to any amendment so requested by the District provided that neither thc Trustee nor the Dissemination Agent shall be obligated to enter into any such amendment that modifies or increases its dutics or obligations hereunder) only if: 4 (a) the amendment is made in connection with a change in circumstances that ariscs from a change in legal requirements, change in law, or change in identity, nature, or status of the District, or type ot�business conducted; (b) this Disclosure Agreement, as amended, would have compiled with the requirements of the Rule at thc time of sale of the Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; (c) the amendment does not materially impair the interests of the Owncrs, as determined by parties unaffiliated with the District (such as, but without limitation, the Uistrict's bond counsel)or by Owncr's consent pursuant to Section 7.01 of the Indenture; and (d) the annual financial information containing(if applicable) the amended operating data or tinancial information will explain, in narrative form, the reasons for the amendmcnt and the"impact" (as that word is used in the letter from the staff of the Securities and F.xchange Commission to the National Association of Bond Lawycrs dated June 23, 1995)of the change in the type of operating data or financial information being provided. SECTION 9. Additional Information. (a) The District agrees to provide public information concerning the Bonds and the District to any Holder or Beneticial Owner making a written request therefor. (b) Nothing in this Disclosure Agreement shall be deemed to prevent the District from disscminating any other information, using the means of dissemination set forth in this Disclosure Agreement or any other mcans of communication, or including any other information in any Annual Report or notice of occurrence of a Listed Event, in addition to that which is required by this Uisclosure Agreement. If the District chooses to include any information in any Annual Report or notice of occurrence ofa Listed Event in addition to that which is specifically required by this Uisclosure Agreement, the Uistrict shall have no obligation under this Disclosure Agreement to update such information or include it in any future Annual Report or notice of occurrence of a Listed Lvent. SECTION 10. Default. In the even to a failure of the District to co►nply with any provision of this Disclosure Agreement, the Trustee shall, at the written direction of any Participating Underwriter or the Owners of a ►najority in aggregate principal amount of Outstanding Bonds(but only to the extent funds have been provided to it or it has been otherwise indemnitied to its satisfaction from any cost, liability, expense or additional charges of the Trustee whatsoever, including, without limitation, Cees and expenses of its attorneys),or any Uwner inay, take such actions as may be necessary and appropriate, including seeking mandate or specific perfonnance by court order, to cause the llistrict, the Trustee or the Dissemination Agent, as thc case may be,to comply with its obli�ations under this Disclosure Agreement; provided that any such action may be instituted only in the Federal or State Court located in the County of Los Angeles, State of California and no remedy other than specific performance may be sought or granted. A default undcr this Disclosure Agreement shall not be deemed an Event of Default undcr the Indcnture or the Loan Agreement, and the sofe remedy under this Disclosure Agreement in the event of a failure of the District, the Trustee or the Dissemination Agent to comply with this Disclosure Agrecment shall be an action to compel perfonnance. SECTION 1 1. Uuties, Immunities and Liabilities of Dissemination A�t. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Agreement, and the District agrees to indemnify and save the Uissemination Agent and the Trustee, their officers, directors, employees and agcnts, harmless against any loss, expensc and liabilities which it may incur arising out of or in the exercise or performancc of its powers and duties hcreunder, includinb the costs and expenses (including attorneys fees)of defending against any claim of liability, but excluding liabilitics due to the [)isseminatiun Agent's or Trustee's negligence or willtul misconduct. The Dissemination A�ent may rely 5 on and shall be protected in acting or refraining from acting upon any direction from the Issuer or an opinion of nationally recognized bond counsel. Thc Dissemination Agent and thc Tnistee shall be paid compensation by the District for its services provided hereunder in accordance with its schedule of fees as amended from time to time and all expenses, legal fees and advances made or incurred by the Dissemination Agent in the performance of its duties hereunder. The Dissemination Agent and the Trustee shall have no duty or obligation to review any information provided to them by the District hereunder and shall not be deemed to be acting in a fiduciary capacity for the District,the City,the nwners, or any other party. The obligations of the District under this Section shall survive resignation or removal of the Dissemination Agent and payment of the Bonds. No person shall have any right to commence any action against the Dissemination Agent seeking any remedy other than to compel specific performance of this Disclosure Agreement. Thc Dissemination Agent shall not be liable under any circumstanees for monetary dama�es to any person for any breach of this Disclosure Agreement. SECTION l2. Benef►ciaries. This Disclosure Agscement sha11 inure solefy to the bencfit of tlie Uistrict, the Participating Underwriters, the Dissemination Agent and flolders and Bencficial Owners trom time to time of the Bonds, and shall create no rights in any other person or entity. SECTION 13. Notices. Notices should be sent in writing to the following addresses. The ft>Ilowing information ►nay be conclusively relied upon until changed in writing. District: City of Palm Desert Community Facilities District No. 91-1 (Indian Ridge Public Improvements) 73-510 Fred Waring Drive Palm Desert, California 92260 (760) 346-0611 (760) 346-0574 Fax Trustee: Wells Pargo Bank, National Association 700 South l�lower Street, Suite 500 Los Angeles, California 90017-4104 (213) 630-6237 (213) 630-6215 Fax Dissemination Agency: MuniFinancial, Inc. 27368 Via lnciustrial, Suite 10 Tcmecula, California 92590 (951) 587-3500 (951) 587-3510 Fax 6 SECTION 14. Counterparts. This Disclosure Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrumcnt. Datc: , 2008 CITY OF PALM DESERT COMMUNITY FACILITIES DISTRICT NO. 91-1 (1NDIAN RIDGE PUBLIC IMPROVEMENTS) By: Authorized Officer WELLS FARGO BANK, NATIONAL ASSOCIATION, as Tcustee 13y: Authorized Officer ;�iUNIFINANCIAL, INC., as Dissemination Agent �y: Authorized Officcr 7