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HomeMy WebLinkAboutSR - BONDS PA1 - AMND 2007 Series/Res 06-144/Res FA-59/Res 534/ PA1 AmndsResolution Resolution Resolution No. 06-144 No. FA-59 No. 534 CITY OF PALM DESERT PALM DESERT FINANCING AUTHORITY PALM DESERT REDEVELOPMENT AGENCY STAFF REPORT REQUEST: APPROVAL OF RESOLUTION NO.06-144 OF THE CITY COUNCIL OF THE CITY OF PALM DESERT MAKING A FINDING OF SIGNIFICANT PUBLIC BENEFIT IN CONNECTION WITH THE ISSUANCE AND SALE BY THE PALM DESERT FINANCING AUTHORITY OF ITS TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED), 2007 SERIES A APPROVAL OF RESOLUTION NO. FA- 59 OF THE PALM DESERT FINANCING AUTHORITY ACKNOWLEDGING A FINDING OF SIGNIFICANT BENEFIT AND APPROVING AS TO FORM AND AUTHORIZING THE EXECUTION AND DELIVERY OF CERTAIN DOCUMENTS IN CONNECTION WITH THE ISSUANCE, SALE AND DELIVERY OF THE AUTHORITY'S TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED), 2007 SERIES A, AND AUTHORIZING CERTAIN OTHER MATTERS RELATING THERETO APPROVAL OF RESOLUTION NO. 5340F THE PALM DESERT REDEVELOPMENT AGENCY APPROVING AS TO FORM AND AUTHORIZING THE EXECUTION AND DELIVERY OF CERTAIN DOCUMENTS IN CONNECTION WITH THE SALE AND ISSUANCE BY THE PALM DESERT FINANCING AUTHORITY OF THE AUTHORITY'S TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED), 2007 SERIES A, AND AUTHORIZING CERTAIN OTHER MATTERS RELATING THERETO SUBMITTED BY: DAVID YRIGOYEN, DIRECTOR OF REDEVELOPMENT/HOUSING DATE: NOVEMBER 16, 2006 CONTENTS: (1) (2) (3) (4) (5) (6) (7) (8) (9) CITY COUNCIL RESOLUTION NO. 06- 144 PALM DESERT FINANCING AUTHORITY RESOLUTION NO. FA- 59 PALM DESERT REDEVELOPMENT AGENCY RESOLUTION NO. 534 INDENTURE OF TRUST PROJECT AREA NO. 1, AS AMENDED, LOAN AGREEMENT ESCROW AGREEMENT PRELIMINARY OFFICIAL STATEMENT BOND PURCHASE AGREEMENT CONTINUING DISCLOSURE AGREEMENT G \RDA\Mana Hun1\W PDATA\YRIGOYEN\STFRPTS\111606 PA91 Refunding 2007 DOC 924190.5 Resolution No. 06-144 Staff Report Resolution No. FA-59 Approval of City, Agency and Authority Resolutions Resolution No. 534 PA#1 Tax Allocation Refunding Revenue Bonds, 2007 Series A Page 2 of 5 November 16, 2007 Recommendation: By Minute Motion: That the City Council approve Resolution No. 06-_, making a finding of significant public benefit in connection with the issuance and sale of the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A (the "Bonds"); 2. That the Palm Desert Financing Authority approve Resolution No. FA - acknowledging finding of significant public benefit in connection with the issuance and sale of the Bonds, approving of the issuance, sale and delivery of the Bonds and authorizing the execution and delivery of documents relating to the Bonds; and 3. That the Palm Desert Redevelopment Agency approve Resolution No. approving and authorizing the execution and delivery of documents relating to the Bonds. Executive Summary Adoption of the attached resolutions will allow Staff to proceed with the issuance of the Bonds and the use of proceeds from the Bonds to pay for the costs of the identified projects. Backaround and discussion: Staff recommends the issuance of the Bonds relating to the financing and refinancing of projects for the Agency's Project Area No. 1. The Bonds will be issued as tax-exempt bonds. The primary purpose for issuing the Bonds is to effect a refunding of the Authority's outstanding Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), Series 1997 (the "1997 Bonds") and to convert the annual savings into cash for approved projects. The remaining 1997 Bonds are scheduled to mature on April 1 of 2007, 2008, 2009, 2010, 2011, 2012, 2014 and 2018. The 2007 maturity will be paid to maturity and 1997 Bonds maturing between 2008 and 2018 will be redeemed as part of the refunding. The refunding Bonds will pay principal from April 1, 2008 to April 1, 2018 to match the payment dates of the 1997 Bonds being refunded. Earlier this year, the Authority issued its Tax Allocation Revenue Bonds (Project Area No. 1, As Amended), 2006 Series A ("2006A Bonds"). The resolution adopted by the City Council on June 8, 2006, in connection with the 2006A Bonds identified certain Agency projects (the "PA#1 Projects"), which are being funded, in whole or part, by proceeds of the 2006A Bonds. Approximately $1.7 million (based on current estimates by the Financial Advisor and the Underwriter) of cash generated from the refunding will be set aside in a Project Fund to provide additional funding for the PA#1 Projects. The debt service on the refunding Bonds for any year will not exceed the debt service on the refunded 1997 Bonds for such year. The Financial Advisor has recommended moving forward with the proposed issuance as long as the cash generated for the projects exceeds $1 million (approximately three percent net present value benefit). 924190-5 Resolution No. 06-144 Staff Report Resolution No. FA--W 534 Resolution No. Approval of City, Agency and Authority Resolutions PA#1 Tax Allocation Refunding Revenue Bonds, 2007 Series A Page 3 of 5 November 16, 2007 The repayment of the Bonds will be primarily secured by tax increments generated with respect to Project Area No. 1. The Bonds will rank on a parity with the outstanding bonds previously issued for Project Area No. 1. The Bonds will be current interest bonds. Adoption of the attached resolutions will allow Staff to proceed with the issuance of the Bonds and the use of proceeds to pay for the costs of the identified projects. Staff is utilizing the following financing team: Del Rio Advisors, LLC, Modesto, CA — Financial Advisor Richards, Watson & Gershon, A Professional Corporation, Los Angeles, CA— Bond Counsel Lofton & Jennings, San Francisco, CA — Disclosure Counsel Wells Fargo Bank, National Association, Los Angeles, CA — Trustee and Escrow Agent Stone & Youngberg, LLC, San Francisco, CA — Underwriter Rosenow Spevacek Group, Inc., Santa Ana, CA — Fiscal Consultant MuniFinancial, Inc., Temecula, CA — Dissemination Agent SUMMARY OF DOCUMENTS TO BE APPROVED: Indenture of Trust The Indenture sets forth all of the terms and conditions of the Bonds (e.g., principal amounts, maturity and redemption schedules, payment, registration and transfer provisions and the form of the Bonds), the covenants and other obligations of the Authority to the bondholders, and the role and the duties of the Trustee. As presented, the Indenture is in substantially final form, except that final dollar amounts and interest rates will be added after the Bonds have been priced and sold and that provisions may be added, deleted or otherwise modified to accommodate the bond insurer requirements. Loan Agreement Pursuant to the Loan Agreement, the Authority agrees to lend the Agency funds that would be used by the Agency to refund the 1997 Bonds and provide additional funding for capital projects for benefit to Project Area No. 1. The Agency agrees to pay tax increment revenues to the Trustee, as the Authority's assignee, in sufficient amounts to pay debt service on the Bonds. Bond Purchase Agreement The Bond Purchase Agreement is an agreement among the Authority, the Agency and the Underwriter for the purchase and sale of the bonds. Pursuant to the Bond Purchase Agreement, the Underwriter agrees to purchase the Authority bonds at specified prices and interest rates, subject to the receipt of certain opinions, certificates and other conditions. The Bond Purchase Agreement will be presented to the appropriate officers of the Authority and Agency for approval and execution as soon as the Underwriter has completed the process of offering and then pricing the Bonds in the market. 924190-5 Resolution No. 06-144 Resolution No. FA-59 ResoluticnNo. 534 Staff Report Approval of City, Agency and Authority Resolutions PA#1 Tax Allocation Refunding Revenue Bonds, 2007 Series A Page 4 of 5 November 16, 2007 Preliminary Official Statement A Preliminary Official Statement relating to the Bonds, in substantially final form, has been prepared by Disclosure Counsel. The Preliminary Official Statement is designed to provide material information to investors with respect to the terms and the security of the Bonds. It includes a full description of the legal and financial aspects, as well as the various legal documents in regard to the Bonds, except for certain information which will be determined upon the pricing of the Bonds (such as the final principal amounts, the interest rates and the redemption dates). The Preliminary Official Statement also includes information regarding the Authority, the Agency, and the Project Area. The Preliminary Official Statement will be utilized by the Underwriter in its effort to market the bonds to the public. Once the Bonds have been priced and the Bond Purchase Agreement has been signed, Disclosure Counsel will insert the final pricing information into the Preliminary Official Statement, thereby converting it to the Official Statement. The Underwriter will then distribute the Official Statement to the individuals and institutions that purchased the Bonds. Continuinq Disclosure Aqreement The Continuing Disclosure Agreement is an agreement among the Agency, the Trustee and the Dissemination Agent. This agreement directs the Agency to provide an annual report to the Dissemination Agent. The Annual Report contains the Agency's audited financial statements and other pertinent information relating to Project Area No. 1. The Annual Report is sent to state and national repositories so that this information is available to the bondholders. This mechanism is used to keep bondholders informed on an annual basis of the financial status of the Agency. Escrow Aqreement The Escrow Agreement is an agreement among the Agency, the Authority and the Trustee, acting as Escrow Agent. The refunded 1997 Bonds will be redeemed on April 1, 2007. Between the issuance date of the Bonds and April 1, 2007, money derived from the proceeds of the Bonds that are to be used for the refunding of the 1997 Bonds, together with other moneys transferred by the Agency, will be held by the Escrow Agent in an Escrow Fund. The Escrow Agreement provides for the establishment and maintenance of such Escrow Fund and the release of money on the redemption date. Conclusion The resolutions permit Staff to make the necessary changes to all of the documents in order to finalize and execute the documents. Staff is recommending that the City Council, the Authority and 924190-5 Resolution No. 06-144 Resolution No. FA-59 ResolutionNNo. 534 Staff Report Approval of City, Agency and Authority Resolutions PA#1 Tax Allocation Refunding Revenue Bonds, 2007 Series A Page 5 of 5 November 16, 2007 the Agency adopt their respective resolutions approving and authorizing the sale and issuance of the Bonds, and the execution and delivery of the related documents. Submitted by: d Dave Yrigoy n,! Director of velopment/Housing Approval: v Ju Carthy, ACM elopment Carlos L. Ortega City Manager/CA xecutive Director pw BY RDA ON VERIFIED BY P i Original on file with City Clerk"s Old BY F/I�N/ AUTH Ly 924190-5 aul S. Gibson, Director of Finance/Treasurer CITY COUNCIL�CTION: APPROVED DENIED CE IVED OTHER d _ d.. MEETINQ DATE I — I � Q AYES. ,,, fr--"-KDIl j..����PJ ffA rGt�Yri NOES: NO,r%k ABSENT:.W ABSTAIN• VERIFIED BY: Original on File with City Clerk's Of fi� RESOLUTION NO. 06-144 = -- A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALM DESERT MAKING A FINDING OF SIGNIFICANT PUBLIC BENEFIT IN CONNECTION WITH THE ISSUANCE AND SALE BY THE PALM DESERT FINANCING AUTHORITY OF ITS TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED), 2007 SERIES A RECITALS: WHEREAS, the Palm Desert Financing Authority (the "Authority") has proposed to sell and issue its Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A (the "Bonds"); and WHEREAS, the proceeds of the Bonds will be applied to make a loan (the "Loan") to the Palm Desert Redevelopment Agency (the "Agency") pursuant to a loan agreement between the Authority and the Agency; and WHEREAS, a portion of the proceeds of the Loan, together with other available funds, will be used to effect the refunding of the Authority's Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), Series 1997, scheduled to mature on April 1, 2008 and thereafter through April 1, 2018; and WHEREAS, a portion of the proceeds of the Loan also will be used to provide additional financing for certain public capital improvements of benefit to Project Area No. 1, As Amended, of the Agency, including: (i) the construction of on and off ramps at Portola Avenue and Interstate 10; (ii) the widening of various portions of Monterey Avenue, Portola Avenue, Country Club Drive, and various other street improvements throughout the Project Area; (iii) improvements to the frontage roads along Highway 111; (iv) a sound attenuation wall along portions of Fred Waring Drive; (v) landscape, lighting, median and parkway improvements along El Paseo; (vi) landscape improvements throughout the Project Area; (vii) a Portola Avenue Bridge over the Whitewater Channel; (viii) drainage improvements along a portion of Monterey Avenue; (ix) the development of a visitors center (including the Henderson Building, botanical gardens and related public improvements) at El Paseo and Highway 111; (x) neighborhood and arterial street utility undergroundings throughout the Project Area; (xi) a parking structure to accommodate a hotel and related development at the Desert Willow Golf Resort; (xii) a business facade enhancement grant program; and (xiii) the construction of a swimming pool and related athletic facilities at the College of the Desert; and WHEREAS, pursuant to Section 6586.5 of the California Government Code, after notice duly published in accordance with law, this City Council held a public hearing on this date with respect to the issuance of the proposed Bonds and received evidence concerning the public benefits therefrom; and NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF PALM DESERT DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS: Section 1. Recitals. The above recitals, and each of them, are true and correct. P6402-1058\921994v3.doc Resolution No. 06-144 Section 2. ADDroval of Financina. The City Council hereby finds that the financing and refinancing of public capital improvements described above through the issuance by the Authority of the Bonds will result in significant public benefits to the constituents of the Agency and the City of Palm Desert, including demonstrable savings in effective interest rate and more efficient delivery of Agency and City services to residential and commercial development. The City Council hereby approves the issuance of the Bonds by the Authority. Section 3. Other Acts. The officers of the City are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they may deem necessary or advisable in order to effectuate the purposes of this Resolution and any such actions previously taken by such officers are hereby ratified and confirmed. adoption. vote, to wit: AYES: NOES: Section 4. Effective Date. This Resolution shall take effect immediately upon APPROVED and ADOPTED this 16th day of November 2006 by the following ABSENT: ABSTAIN: Jim Ferguson, Mayor ATTEST: Rachelle D. Klassen, City Clerk P6402-1058\921994v3.doc 2 RESOLUTION NO. FA- 59 A RESOLUTION OF THE PALM DESERT FINANCING AUTHORITY ACKNOWLEDGING A FINDING OF SIGNIFICANT BENEFIT AND APPROVING AS TO FORM AND AUTHORIZING THE EXECUTION AND DELIVERY OF CERTAIN DOCUMENTS IN CONNECTION WITH THE ISSUANCE, SALE AND DELIVERY OF THE AUTHORITY'S TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED), 2007 SERIES A, AND AUTHORIZING CERTAIN OTHER MATTERS RELATING THERETO RECITALS: WHEREAS, the Palm Desert Financing Authority (the "Authority") is a joint powers authority duly organized and existing under and pursuant to Articles 1 through 4 (commencing with Section 6500), Chapter 5, Division 7, Title 1 of the California Government Code (the "Act") and that certain Joint Exercise of Powers Agreement dated as of January 26, 1989, by and between the City of Palm Desert (the "City") and the Palm Desert Redevelopment Agency (the "Agency"), and is authorized pursuant to Article 4 of the Act to issue bonds for the purpose of making loans to the Agency to provide financing and refinancing for public capital improvements; and WHEREAS, the Authority desires to issue and sell its Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A (the "Bonds") to be issued and secured pursuant to a certain Indenture (as defined below); and WHEREAS, the proceeds of the Bonds will be applied to make a loan (the "Loan") to the Palm Desert Redevelopment Agency (the "Agency") pursuant to a certain Loan Agreement (as defined below); and WHEREAS, a portion of the proceeds of the Loan, together with other available funds, will be used to effect the refunding of the Authority's Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), Series 1997, scheduled to mature on April 1, 2008 and thereafter through April 1, 2018; and WHEREAS, a portion of the proceeds of the Loan also will be used to provide additional financing for certain public capital improvements of benefit to Project Area No. 1, As Amended, of the Agency; and WHEREAS, the City Council has made a finding, after a duly noticed public hearing pursuant to Section 6586.5 of the California Government Code, that the issuance of the Bonds will result in significant public benefit; NOW, THEREFORE, THE PALM DESERT FINANCING AUTHORITY DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS: P6402-1058\9219870.duc Resolution No. FA-59 Section 1. Recitals. The above recitals, and each of them, are true and correct. Section 2. Acknowledgment of Citv Council Findings. The Authority hereby acknowledges and concurs with the City Council's finding of significant public benefit and hereby approves and authorizes the issuance and sale of the Bonds. Section 3. Issuance of Bonds; Indenture. The Indenture of Trust (the "Indenture"), proposed to be entered into by and between the Authority and the Trustee (defined in Section 4 below), in the form presented and on file in the office of the Secretary of the Authority (the "Secretary"), is hereby approved. The issuance of the Bonds, in an aggregate principal amount not exceeding $36,000,000, pursuant to the Indenture is hereby approved. Subject to Section 10 below, each of the President, the Chief Administrative Officer and the Treasurer of the Authority, any deputy of such officers, and any member of the Authority Commission (each, an "Authorized Officer'), acting singly, is hereby authorized and directed, for and in the name and on behalf of the Authority, to execute and deliver the Indenture in substantially said form, with such additions or changes as the Authorized Officer executing the same may approve (such approval to be conclusively evidenced by such Officer's execution and delivery thereof). Section 4. Appointment of Trustee and Escrow Agent. 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. Section 5. Loan Aqreement. The Project Area No. 1, As Amended, Loan Agreement (the "Loan Agreement"), proposed to be entered into by and among the Agency, the Authority and the Trustee, in the form presented and on file in the office of the Secretary, is hereby approved. Each Authorized Officer, acting singly, is hereby authorized and directed, for and in the name and on behalf of the Authority, to execute and deliver the Loan 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). Section 6. Escrow Aqreement. The Escrow Agreement (Project Area No. 1, As Amended), proposed to be entered into by and among the Agency, the Authority and the Escrow Agent, in the form presented and on file in the office of the Secretary, is hereby approved. Each Authorized Officer, acting singly, is hereby authorized and directed, for and in the name and on behalf of the Authority, 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). Section 7. Preliminary Official Statement. The Preliminary Official Statement relating to the Bonds (the "Preliminary Official Statement"), in the form presented and on file with the Secretary, is hereby approved. Each Authorized Officer, acting singly, is hereby authorized and directed, for and in the name and on behalf of the Authority, to cause the Preliminary Official Statement in substantially said form, with such 2 P6402-1058\9219870. duc Resolution No. FA-59 changes therein as such Authorized Officer may approve, to be deemed final for the purposes of Rule 15c2-12 promulgated under the Securities and Exchange Act of 1934. The distribution by Stone & Youngberg LLC (the "Underwriter") of copies of the Preliminary Official Statement to potential purchasers of the Bonds is hereby approved. Section 8. Official Statement. Each Authorized Officer, acting singly, is hereby authorized and directed to cause the Preliminary Official Statement to be brought into the form of a final Official Statement (the "Official Statement"), and to execute the same for and in the name and on behalf of the Authority, with such changes therein as such Authorized Officer may approve (such approval to be conclusively evidenced by such Authorized Officer's execution and delivery thereof). The distribution and use of the Official Statement by the Underwriter in connection with the sale of the Bonds are hereby approved. Section 9. Purchase Aqreement. The form of the Bond Purchase Agreement (the "Purchase Agreement") as presented by the Underwriter and the sale of the Bonds pursuant thereto upon the terms and conditions set forth therein are hereby approved. Subject to Section 10 below, each Authorized Officer, acting singly, is authorized and directed, for and in the name and on behalf of the Authority, to execute and deliver the Purchase Agreement in substantially said form, with such changes therein as the officer executing the same may require or approve, including such matters as are authorized by Section 10 hereof (such approval to be conclusively evidenced by such Authorized Officer's execution and delivery thereof). Section 10. Terms of Sale of Bonds. Each Authorized Officer, acting singly, is hereby authorized and directed to act on behalf of the Authority to establish and determine: (a) the aggregate principal amount of the Bonds, which amount shall not exceed $36,000,000; (b) interest rates on the Bonds, provided that the true interest cost with respect to the Bonds shall not exceed 5.25 percent; (c) the Underwriter's compensation (i.e., underwriter's discount) with respect to the sale of the Bonds, provided that such compensation shall not exceed one percent of the aggregate principal amount of the Bonds; and (d) such provisions as may be required by the terms of the bond insurance, if any, or debt service reserve surety bond(s), if any, purchased in connection with the issuance of the Bonds. The authorization and powers delegated to such officer by this Section 10 shall be valid for a period of 120 days from the date of adoption of this Resolution. Section 11. Other Acts. The Authorized Officers and all other officers of the Authority are hereby authorized and directed, jointly and severally, to do any and all things, to execute and deliver any and all documents which they may deem necessary or advisable in order to consummate the issuance, sale and delivery of the Bonds, or otherwise to effectuate the purposes of this Resolution, the Indenture, the Loan Agreement, the Escrow Agreement, the Purchase Agreement and the Official Statement, and any such actions previously taken by such officers are hereby ratified and confirmed. 3 P6402-1058\9219870.duc Resolution No. FA-59 Section 12. Effective Date. This Resolution shall take effect immediately upon adoption. APPROVED AND ADOPTED this 16th day of November 2006 by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Jim Ferguson, President ATTEST: Rachelle D. Klassen, Secretary .19 P6402-1058\921987v3.doc RESOLUTION NO. 534 A RESOLUTION OF THE PALM DESERT REDEVELOPMENT AGENCY APPROVING AS TO FORM AND AUTHORIZING THE EXECUTION AND DELIVERY OF CERTAIN DOCUMENTS IN CONNECTION WITH THE SALE AND ISSUANCE BY THE PALM DESERT FINANCING AUTHORITY OF THE AUTHORITY'S TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED), 2007 SERIES A, AND AUTHORIZING CERTAIN OTHER MATTERS RELATING THERETO RECITALS: WHEREAS, the Palm Desert Financing Authority (the "Authority") has determined to sell and issue its Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A (the "Bonds"); and WHEREAS, the proceeds of the Bonds will be applied to make a loan (the "Loan") to the Palm Desert Redevelopment Agency (the "Agency") pursuant to a certain Loan Agreement (as defined below); and WHEREAS, a portion of the proceeds of the Loan, together with other available funds, will be used to effect the refunding of the Authority's Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), Series 1997, scheduled to mature on April 1, 2008 and thereafter through April 1, 2018; and WHEREAS, a portion of the proceeds of the Loan also will be used to provide additional financing for certain public capital improvements of benefit to Project Area No. 1, As Amended, of the Agency; NOW, THEREFORE, THE PALM DESERT REDEVELOPMENT AGENCY DOES HEREBY RESOLVE, DETERMINE AND ORDER AS FOLLOWS: Section 1. Recitals. The above recitals, and each of them, are true and correct. Section 2. Loan Agreement. The Project Area No. 1, As Amended, Loan Agreement (the "Loan Agreement"), proposed to be entered into by and among the Authority, the Agency and Wells Fargo Bank, N.A., as trustee (the "Trustee"), in the form presented and on file with the Secretary of the Agency (the "Secretary") is hereby approved. Each of the Chairman and the Executive Director, or either of them, or their designee (each, an "Authorized Officer'), is hereby authorized and directed, for and in the name and on behalf of the Agency, to execute and deliver the Loan 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 Authorized Officer's execution and delivery thereof). P6402-1058\92199 10.doc Resolution No. 534 Section 3. Escrow Aqreement. The Escrow Agreement (Project Area No. 1, As Amended), proposed to be entered into by and among the Agency, the Authority and the Escrow Agent, in the form presented and on file in the office of the Secretary, is hereby approved. Each Authorized Officer, acting singly, is hereby authorized and directed, for and in the name and on behalf of the Authority, 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). Section 4. Continuina Disclosure Aqreement. The Continuing Disclosure Agreement (the "Continuing Disclosure Agreement"), proposed to be entered into by and among the Agency, the Trustee and MuniFinancial, Inc., as Dissemination Agent, in the form presented and on file in the office of the Secretary, is hereby approved. Each Authorized Officer, acting singly, is hereby authorized and directed, for and in the name and on behalf of the Agency, to execute and deliver the Continuing Disclosure 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). Section 5. Purchase Agreement. The Bond Purchase Agreement (the "Purchase Agreement") proposed to be entered into by the Authority, the Agency and Stone & Youngberg LLC (the "Underwriter"), in the form presented and on file with the Secretary, and the sale of the Bonds pursuant thereto upon the terms and conditions set forth therein, are hereby approved. Subject to the limitations imposed by the Authority by its Resolution relating to the issuance and sale of the Bonds, each Authorized Officer, acting singly, is authorized and directed, for and in the name and on behalf of the Agency, to execute and deliver the Purchase Agreement in substantially said form, with such changes therein as the Authorized Officer executing the same may require or approve (such approval to be conclusively evidenced by his execution and delivery thereof). Section 6. Requisitions. Each Authorized Officer, acting singly, is hereby authorized and directed to execute one or more requisitions authorizing the Trustee to pay costs relating to the incurrence of the Loan and the issuance of the Bonds from the proceeds of the Bonds pursuant to the Loan Agreement. Section 7. Other Acts. The Authorized Officers and all other officers of the Agency are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they may deem necessary or advisable in order to effectuate the purposes of this Resolution, the Loan Agreement, the Escrow Agreement, the Continuing Disclosure Agreement and the Purchase Agreement, and any such actions previously taken by such officers are hereby ratified and confirmed. P6402-1059\9219910.doc Resolution No. 534 Section 8. Effective Date. This Resolution shall take effect immediately upon adoption. APPROVED and ADOPTED this 16th day of November 2006 by following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Jim Ferguson, Chairman ATTEST: Rachelle D. Klassen, Secretary P6402-1058\921991k3.doc The additional documents associated with this request are available for viewing in the City Clerk's Office. 1.&J DRAPT #2 11 /3/06 S PALM DESER'f FINANCING AUTHORITY TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECI' AREA NO. 1, AS AMENDED) 2007 SERIES A BOND PURCHASE AGREEMENT December , 2006 Palm Desert Financing Authority 73-510 Fred Waring Drive Palm Desert, California 92260-2578 Ladies and Gentlemen: Stone & Youngberg LLC (the "Unrlenvriter•"), offers to enter into this Bond Purchase Agreement (the "Purcha.se Agreement ") with the Palm Desert Financing Authority (the "Financing Au�horitl� "), a joint po�vers authority created by a Joint Lxercise of Powers Agreement dated January 26, 1989 (the "JPA Agreenrenr ") between the City of Palm Desert and the Palm Desert Redevelopmcnt Agency (the "Rerlei�elopmenr Agency"), which upon acceptance and approval, will be binding upon the Financing Authority and the Underwriter. This offer is made subject to acceptance by the Financing Authority and approval by the Redevelopment Agency by execution of this Purchase Agreement and delivery of the same to the Underwriter on or before 11:59 p.m. (California time) on the date hereof, and, if not so accepted and approved, will be subject to withdrawal by the Underwriter upon notice delivered to the Financing Authority at any time prior to such acceptance and approval. Capitalized terms used in this Purchase Agreement and not otherwise defined herein shall have the respective meanings set forth for such terms in the 2007 Indenture (defined below) and if not othenvise defined therein, shall have the meanings given to such terms as set forth in the Official Statemcnt (defined below). Section 1. Purchase and Sale of the 2007 Bonds. Upon the terms and conditions and upon the basis of the representations set forth in this Purchase Agreement, the Underwriter agrees to purchase from the Financing Authority, and the Financing Authority agrees to sell and deliver to the Undenvriter, all (but not less than all) of the $ aggrebate principal amount of the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A (the "Z007 Bon�l.c "). 'I'he 2007 Bonds shall be dated the date of delivery and shall have the maturities, bear interest at the rates per annum, have the yields and be subject to mandatory sinking fund redemption all as set forth on Schedule [ attached hereto. The purchase price for the 2007 Bonds shall be $ (calculated as the principal amount of the 2007 Bonds, less a net original issue discount in the amount of � and less an Lnderwriter's discount in the amount of S l. ��4-ur>ua2 �x 2 Section 2. Preliminary Official Statement. The Financing Authority has delivered to the Underwriter a Preliminary Official Statement, dated December _, 2006 (the "Pre/iminn��� O�Jiciul Stutement "), and will deliver to the [lndcrwriter a tinal Official Statement dated the date hereof as provided in Section 5 of this Purchase Agreement (as amended and supplemented from time to time pursuant to Section 6(k) of this Purchasc Agreement, the "Ofrciril State,rrent "). The Financing Authority and the Redevelopment Agency have each delivered to the Underwriter a certificate pursuant to Securities and Exchange Commission Rule 15c2-12 ("Rule 15c2-12") relating to the Preliminary Official Statement, in substantially the forms attached hereto as Exhibit A-1 and Exhibit A-2, respectively. Section 3. Description of the 2007 Bonds. The 2007 Bonds are issued pursuant to the Community Redevelopment Law of the State of California, constituting Part 1 of Division 24 of the Health and Safety Code, commencing with Section 33000 (the "Redevelopment Law ") and Resolution No. adopted by the Financing Authority on November _, 2006 (the "Financing Authorit}� Resolution "). The 2007 Bonds shall be payable and subject to redemption as provided in the 2007 Indenture (dcfined herein) and as set forth in the Official Statement. The 2007 Bonds are legal, valid and binding limited obligations of the Financing Authority, and are payable solely from and secured by a pledge of Revenues (as defined in the 2007 Indenture) derived primarily from loan paymenis made by the Redevelopment Agency pursuant to the 2007 Loan Agreement (defined herein). The 2007 Bonds shall be substantially in the form described in, shall be issued and secured under the provisions of, and shall be payable as provided in, the Indenture of Trust, dated as of January 1, 2007 (the "2007 h��tenture "), by and between the Financing Authority and Wells Fargo Bank, National Association (the "Trustee"). The Financing Authority is issuing the 2007 Bonds to make a loan (the "Lnan "), to the Palm Desert Redevelopment Agency (the "Reclevelopmen� Agenc•y") pursuant to the terms of a Project Area No. 1, As Amended Loan Agreement made and executed as of January 1, 2007 (the "2�J07 Loan Ag►•eement") by and among the Financing Authority, the Redevelopment Agency and the Trustee. The Redevelopment Agency will apply the proceeds of the 2007 Loan to: (i) refnance all but the April 1, 2007 payment outstanding obligations of the Redevelopment Agency under a loan agreement dated as of July 1, 1997 (the "Prior Loan Agreement "); (ii) finance various redevelopment activities within Project Area No. 1, As Amended located in the City of Palm Desert (the "Project Area"); and (iii) pay the costs associated with the issuance of the 2007 Bonds. The payment of principal of and interest on the 2007 Bonds when due will be insured by a financial guaranty insurance policy (the "Fincrncial Gttnrant}� Insuraiice Policy ") to be issued by MBIA Insurance Corporation (the "Bond Insi�rer• "), simultaneously with the delivery of the 2007 Bonds. Section 4. Public Offering. The Underwriter agrees to make a bona fide public offering of all the 2007 Bonds at not in excess of the initial public offering prices or yields set forth in Schedule I attached hereto, plus interest accrued thereon, if applicable, from the date of the 2007 Bonds. The Underwriter reserves the ribht to make concessions to dealers and to change such initial public offerinb prices or yields as the Underwriter reasonably deems necessary in connection with the marketing of the 2007 Bonds. Tl�e iinderwriter also reserves the right (i) to over-allot or effect transactions that stabili�e or maintain the market price of the 2007 Bonds at a level above that which might otherwise prevail in the open market and (ii) to discontinue such stahilizing, if commenced, at any time. Section 5. Delivery of Official Statement. The Financing Authoriry shall deliver to the Undenvriter, as promptly as practical but in no event later than the Closing Date (as detined herein), such number of copies of the final Official Statement, as the Underwriter ►nay reasonably requcst in order to comply �vith the Securities and Exchange Comm�ssion Rule 15c2-12(b) and the rules of the Municipal Securities Rulemakin�; T3oard (the "MSRB "). z3a-oansz ik-z /] "Che Financing Authority hereby authorizes the Underwriter to use the Official Statement and the information contained therein in connection with the offering and sale of thc 2007 Bonds and ratifies and confirms the authorization of the use by the Underwriter prior to the date hereof of the Preliminary Official Statement, furnished to the Underwriter by the Financing Authority in connection with such offering and sale. "I'he Underwriter agrees that from the time the Official Statement becomes available until the earlier of (i) the "En�f of the Un�te�ti�•►•iting Perio�t, " as defined in Section 6(j) herein, or (ii) the time when the Official Statement is available to any person from a nationally recognized municipal securities inforrnation repository, but in no case less than 25 days following the End of the Underwriting Period, the Underwriter shall send no later than the next business day following a request for a copy thereof, by first class mail or other equally prompt means, to any Potential Customer, as defined in Rule 15c2-12, on request, a single copy of the Officia] Statement. The Underwriter agrees to file as soon as reasonably practicable a copy of the Official Statement with a nationally recognized municipal securities information repository and take any and all actions necessary to comply with applicable Securities and Exchange Commission rules and MSRB rules governing the offering, sale and delivery of the 2007 Bonds to ultimate purchasers. At the time of pricing, the Underwriter shall deliver to the Financing Authority a summary of the orders by maturity. Section 6. Representations, Warranties and Covenants of the Financing Authority. The Financing Authority represents, warrants and covenants with the Underwriter that: (a) the governing board of the Financing Authority has by the Financing Authoriry Resolution adopted by a majority of its members at a meeting duly called, noticed and conducted, at which a quorum was present and acting throughout on November _, 2006, taken all action necessary for the execution, delivery and due performance of the 2007 Indenture, the 2007 Loan Agreement, the Escrow Agreement dated as of January l, 2007 (the "Escrnx� Agreement"), by and among the Financing Authority, the Redevelopment Agency and Wells Fargo Bank, National Association, as escrow bank (the "Escr•otiti� Bank") regarding the refunding of $31,885,000 outstanding principal amount of Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), Series 1997 (the "Prior Bond.s"), the Certificate Regarding Compliance of Certain 1'ax Matters of the Financing Authority dated as of the ciate of the initial delivery of the 2007 Bonds (the "TaY Certificutc� ") and this Purchase Agreement (collecti��ely, the "Finuncing Authorit}� Agreemen[s ") and the authorization and approval of the Preliminary Official Statement and the Official Statemenr the Financing Authoriry Resolution is in full force and ef%ct and has not been amended, modified or rescinded; the adoption of the Financing Authoriry Resolution constitutes all necessary action to be taken by the Financial Authority for the execution, issuance and delivery of the 2007 Bonds and the execution delivery and due perf'ormance of the Financing Authority A�,�reements. (b) the k'inancing Authority is and will be on the Closing Date a joint exercise of� powers authoriry duly organized and existing under the laws of the State of Califomia (the "State ") and the JPA Agrcement and has all necessary power and authority to adopt the Financing Authority Resolution, to enter into and perform its duties under the Financing Authority Agreements; and, when executed and delivered by the respective parties thereto, the Financing Authority Agreements will each constitute legal, valid and binding obligation of the Financing Authoriry enforceable in accordance with its respective terms, except as enforcement may be limited by bankrupicy, insolvency, reorganization, moratorium or similar laws or equitable principles relating to or affecting creditors' rights generally. ?t-l-nhn.i� Pc., (c) this Purchase Agreement has been duly executed and delivered by the Fii�ancing Authonry, and constitutes, and upon their execution and delivery, the Financing Authority Agreements and the 2007 Bonds will constitute, [egal, valid and binding oblibations of the Financing Authority enforceable in accordance with their terms, except as enforceability may be limited by bankruptcy, insolvency, moratorium or creditors' rights generally; and the execution and delivery of the Purchase Agreement does not and the execution and delivery of the Financing Authoriry Agreements and the 2007 Bonds and compliance with the provisions of each thereof will not conflict with or constitute a breach of or a default under any applicable law or administrative regulation of the State or the United States, or any appiicable judgment, decree, agreement or other instrument to which the Financing AuU�ority is a party or is otherwise subject; (d) at the time of acceptance hereof by the Financing Authority, and (�nless an event occurs of the nature described in Section 6(k)) at all times during the penod from the date of this Purchase Agreement to and including the date which is 25 days following the End of the Underwriting Period for the 2007 Bonds (as detecmined in accordance with Section 6(j)), the statements and information contained in the Preliminary Official Statement as of its date, and the Official Statement as of its date under the caption "THE FINANCING AUTHORITY" is true, correct and complete in all material respects and such statements with respect to the Preliminary Official Statement do not, and with respect to the Official Statement will not, omit to state any material fact necessary to make such statements, in light of the circumstances under which they were made, not misleading; (e) to the best of its knowledge, the Financing Authority is not in violation or breach of or default under any applicable constitutional provision, la�v or administrative rule or regulation of the State of California or the United States of America, or any abency or instrumentality of either of them, or any applicable judgment or decree, or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Financing Authority is a party or is otherwise subject, which would constitute a default under any of the Financing Authority Agreements or the 2007 Bonds, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both would constitute a violation or a breach of or a desault under any such loan agreemeni, indenture, bond, note, resolution, agreement or other instrument to which the Financing Authority is a party or is otherwise subject; ( fl at the date hereof and on the Closing Date, the Financing Authority will be in compliance in all respects with the material covenants and agreements contained in the Financing Authority Agreements and no event of default and no event has occurred and is continuing which, with the passage of time or giving of notice, or both, would constitute an event of default thereunder shall have occurred and be continuing; (g) to the best knowledge of the Financing Authority, after due investigation, other than as set forth in the Official Statement or as the Financing Authority has otherwise disclosed in writing to the Underwriter, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, or by or before any court, governmental agency, public board or body, pending and served on the Financing Authority or threatened against the Financing Authority, (i) wherein an unfavorable decision, rulin� or finding �vould adversely affect the existence of the Financing Authority or the title of any official of the h'inancing Authority to such person's office, or (ii) seeking to restrain or enjoin the issuance, sale or delivery of the 2007 Bonds, or thc assignment by the Financing Authority of its rights under the 2007 Indenture, or (iii) in any way contesting or affecting the validiry or enforceability of the Financing Authority Agreements or the 2007 Bonds, or (iv) contesting in any way the completeness or accuracy of the Pretiminary Official Statement, or (v) contesting the power of the Financing Author�ty or its authonty �v�th respect to the 2007 Bonds or the f�inancing Authority Agreements, or (vi) contestin� the exclusion of interest on the 2007 Bonds from gross inrome for federal and State income �vherein an unfavorable ?3�.��nn�z �x-2 decision, ruling or finding would materially adversely affect the validity of the Financing Authority Agreements or the authorization, execution, delivery or performance by the Financing Authority of the 2007 Bonds or the Financing Authority Agreements; (h) the Financing Authority will furnish such information, execute such instruments and take such other action not inconsistent with law in cooperation with the Underwriter which the Underwriter may reasonably request in order for the Underwriter to qualify the 2007 Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions of the United States as the Underwriter may designate and to determine the eligibility of the 2007 Bonds for investment under the laws of such states and other jurisdictions; provided, however, that in no event shall the Financing Authority be required to take any action which would subject it to service of process in any jurisdiction in which it is not now subject; (i) to the best of knowledge of the Financing Authority, all approvals, consents and orders of any governmental authority or agency having jurisdiction in the matter which would constitute a condition precedent to the due performance by the Financing Authority of its obligations under the Financing Authority Agreements or the 2007 Bonds have been duly obtained or made, and are, and will be on the Closing Date, in full force and effect; (j) as used in this Purchase Agrecment, the term "End oJ 1he Underx�riting Periorf' for the 2007 Bonds shall mean the earlier of (i) the Closing Date unless the Financing Authority shall have been notified in �vriting to the contrary by the Underwriter on or prior to the Closing Date or (ii) the date on which the End of the Underwriting Period for the 2007 Bonds has occurred under Rule 15c2-12, provided, however, that the Financing Authority may treat as the End of the Underwriting Period for the 2007 Bonds the date specified as such in a notice from the Underwriter stating the date which is the End of the Underwriting Period; (k) if between the date hereof and the date which is 25 days after the End of the Underwriting Period for the 2007 Bonds, an event occurs, or facts or conditions become known to the Financing Authoriry which, in the reasonable opinion of Richards, Watson 8c Gershon, A Professional Corporation ("Bond Counsel") or Lofton & Jennings, San Francisco, California ("Disclnsw•e C'ounsel "), might or 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 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, the Financing Authority will notify the Underwriter, and if in the opinion of the Underwriter such event requires the preparation and publication of a supplement or amendment to the Official Statement, the Financing Authority will forthwith prepare and furnish to the Underwriter (at the expense of the Financing Authority) a reasonable number of copies of an amendment of or supplement to the Offcial Statement (in the form and substance satisfactory to the Underwriter) which will amend or supplement the Official Statement so that it will not contain an untrue statement of a material fact or omit to state a material fact necessary in order to make the statements therein, in the light of the circumstances existing at the time the Official Statement is delivered to prospective purchasers, not misleading in any material respect with respect to the information of the Financing Authority. [f� such notification shall be subsequent to the Closing Date, the Financin� Authonty shall forthwith provide to the Underwriter such legal opinions, certificates, instruments and other documents as the Underwriter may reasonably deem necessary to evidence the truth and accuracy of such supplement or amendment to the Ofticial Statement. For the purposes of this subsection, between the date hereof and the date which is 25 days after the End of the Underwriting Period for the 2007 Bonds, the Financing Authority will furnish such information with respect to itself as the Underwriter may from time to time reasonably request; z3a-o�,o-�� �,c.z (l) if the information contained in the Official Statement relating to the Financing Authority is amended or supplemented pursuant to Section G(k), 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 Underwritin� Period for the 2007 Bonds, the portions of the Official Statement so supplemented or amended (including any financial and statistical data contained therein), 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; (m) any certificate signed by any officer of the Financing Authority and delivered to the Underwriter pursuant to the 2007 Indenture or this Purchase Agreement or any document contemplated thereby shall be deemed a representation and warranty by the Financing Authority to the Underwriter as to the statements made therein and that such officer shall have been duly authorized to execute the same; (n) to the best knowledge of the Financing Authority, there is no public vote or referendum pending or proposed, the results of which could materially adversely affect the transactions contemplated by the Official Statement or the Financing Authority Agreements or the 2007 Bonds, or the validity or enforceability of the 2007 Bonds; (o) the Financing Authority will comply with the requirements of the "I'ax Certificate executed by the Financing Authority in connection with the delivery of the 2007 Bonds; and (p) the Financing Authority will apply the proceeds from the sale of the 2007 Bonds for the purposes specified in the 2007 Indenture. Section 7. Representations, Warranties and Covenants of the Redevelopment Agency. The Redevelopment Agency represents, warrants and covenants with the Underwriter that: (a) the Redevelopment Abency is a public body corporate and politic, organized and existing under the laws of the State, including the Redevelopment Law, with full right, power and authoriry to execute, deliver and perform its obligations under the 2007 Loan Agreement, the Escrow Agreement, the Continuing Disclosure Agreement among the Redevelopment Agency, the Trustee and MuniFinancial, Inc., as Dissemination Agent, dated the Closing Date and substantially in the form attached to the Official Statement as Exhibit F(the "Cnntinuing Disclosu►•e Agreement "), and to approve this Purchase Agreement (collectively, the "Redevelnpmc>nt Agency Agreements "), and to carry out all transactions contemplated by each of the Redevelopment Agency Aereements and the Official Statement. (b) the Redevelopment Agency has by Resolution No. (the "Redevelopment Agencl• Resohrtion") adopted by a majority of its members at a meeting duly called, noticed and conducted, at which a quonun was present and acting throughout, on November _, 2006, taken all action necessary to be taken by it to authorize and approve the execution, delivery of and the performance by the Redevelopment Agency of the obligations contained in the Redevelopment Agency Agreements; the Redevelopment Agency Resolution is in Full Force and effect and has not been amended, modified or rescinded; and the adoption of the Redevelopment Agency Resolution constitutes all action necessary to be taken by the Redevelopment Agency for the execution, delivery and duc performance of the Redevelopment Agency Agreements; (c) when executed and delivered by the respective parties thereto, each of the Redevelopment Abency ngreements will constitute a legally valid and binding obligation of the �la.nc,naz i,�-z Redevelopment Agency enforceable in accordance with their respective terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws or equitablc principles relating to or affecting creditors' rights generally; the Redevelopment Agency has complied, and will at the Closing be in compliance in all material respects, with the terms of the Redevelopment Agency Agreements; (d) at ihe time of acceptance hereof by the Redevelopment Agency, and (unless an event occurs of the nature described in Section 7(k)) at all times during the period from the date of this Purchase Agreement to and including the date which is 25 days following the End of the Underwriting Period for the 2007 Bonds (as determined in accordance with Section 7(j)), the statements and information contained in the Preliminary Official Statement as of its date, and the Official Statement as of its date (excluding the information under the captions "FINANCIAL GUARANTY INSURANCE,'� and "UNDERwRITINC;," and contained in APPENDIX G-"DTC AND THE BOOK-ENTRY SYSTEM," and APPENDIX H-"SPECIMEN FINANCIAI. GL�ARANTY INSURANCE POLICY" and APPENDIX I-"SPECIMEN RESERVE FL'ND SURGTY POLICY") are true, correct and complete in all material respects and such statements do not with respect to the Preliminary Official Statement, and will not with respect to the Official Statement, omit to state any material fact necessary to make such statements, in light of the circumstances under which they were made, not misleading; (e) to the best of its knowledge, the Redevelopment Agency is not in violation or breach of or default under any applicable constitutional provision, law or administrative rule or regulation of the State or the United States of America, or any agency or instrumentality of either of them, or any applicable judgment or decree, or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Redevelopment Agency is a party or is otherwise subject, which would constitute a default under any of the Redevelopment Agreements, no event has occurred and is continuing which, with the passage of time or the giving of notice, or both would constitute a violation or a breach of or a default under any such loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Redevelopment Agency is a party or is otherwise subject; and compliance with the provisions of the Redevelopment Agency Agreements will not materially conflict with or constitute a breach of or default under any applicable constitutional provision, la�v, administrative regulation, court order or consent decree or any applicable judgment or decree or any loan agreement, note, resolution, indenture, agreement or other instrument to which the Redevelopment Abency is a party or may be otherwise subject; (� at the date hereof and on the Closing Date, the Redevelopment Agency will be in compliance in all respects with the material covenants and agreements contained in the Redevelopment Agency Agreements and no event of default and no event has occurred and is continuing which, with the passage of time or giving of notice, or both, would constitute an event of default thereunder shall have occurred and be continuing; (g) to the best knowledge of the Redevelopment Agency, after due investigation, other than as set forth in the Official Statement or as the Redevelopmei�t Agency has otherwise disclosed in �vriting to the tlnderwriter, there is no action, suit, proceeding, inquiry or investigation, at law or in eyuity, or by or before any court, governmental agency, public board or body, pending and served on the Redevelopment Agency or threatened against the Redevelopment Agency, (i) wherein an unfavorable decis�on, ruling or findinb would adversely affect the existence of the Redevelopment Agency or the title of any official of the Redevelopment Agency to such person's office, or (ii) in any way contesting or affecting the validity or enforceability of the Redevelopment Agency Agreements or the 2007 Bonds, or (iii) contesting in any way the completeness or accuracy of the information in the Preliminary Official Statement, or (iv) contesting the po�ver of the Redevelopment Agency or its authority with respect to the z;�-nr,oaz 4,�., Redevclopment Agency Agreements; wherein an unfavorable decision, ruling or finding would materially adversely affect the validity of the Redevelopment Agency Agreements or the authorization, execution, delivery or performance by the Redevelopment Agcncy of the Redevelopment Agency Agreements; (h) the Redevelopment Agency will furnish such information, execute such instruments and take such other action not inconsistent with law in cooperation with the Underwriter which the Underwriter may reasonably request in order for the Underwriter to qualify the 2007 Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions of the United States as the Underwriter may designate and to determine the eligibility of the 2007 Bonds for investment under the laws of such states and other jurisdictions; provided, however, that in no event shall the Redevelopment Agency be required to take any action which would subject it to service of process in any jurisdiction in which it is not now subject; (i) to the best of knowledge of the Redevelopment Agency, all approvals, consents and orders of any governmental authoriry or agency having jurisdiction in ihe matter which would constitute a condition precedent to the due performance by the Redevelopment Agency of its obligations under the Redevelopment Agency Agreements have been duly obtained or made, and are, and will be on the Closing Date, in full force and effect; (j) as used in this Purchase Agreement, the term "Enrl nJt/re Undenti�riting PerrocP' for the 2007 Bonds shall mean the carlier of (i) the Closing Date unless the Redevelopment Agency shall have been notified in writing to the contrary by the Underwriter on or prior to the Closing Date or (ii) the date on which the End of the Underwriting Period for the 2007 Bonds has occurred under Rule 15c2-12, provided, however, that the Redevelopment Agency may treat as the End of the Underwriting Period for the 2007 Bonds the date specified as such in a notice from the Underwriter stating the date which is the End of the Underwriting Period; (k) if between the date hereof and the date which is 25 days after the �nd of the Underwriting Period for the 2007 Bonds, an event occurs, or facts or conditions become known to the Redevelopment Agency which, in the reasonable opinion of the Bond Counsel or Disclosure Counsel, might or 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 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, the Redevelopment Agency will notify the Underwriter, and if in the opinion of the Underwriter such event requires the preparation and publication of a supplement or amendment to the Ofticial Statement, the Redevelopment Agency will forthwith prepare and furnish to the Underwriter or cause the Financing Authority to prepare and furnish to the Underwriter (at the expense of the Redevelopment Agency) a reasonable number of copies of an amendment of or supplement to the Official Statement (in the form and substance satisfactory to the L!nderwriter) which will amend or supplement the Official Statement so that it will not contain an untrue statement of a material fact or omit to state a material fact necessary in order to make the statements therein, in the light of the circumstances existing at the time the Official Statement is delivered to prospective purchasers, not misleading in any material respect with respect to the information of the Redevelopment A�ency. If such notitication shall be subsequent to the Closing Date, the Redevelopment Agency shall forthwith provide to the Underwriter such lebal opinions, certificates, instruments and ot}ier documents as the Underwriter may reasonably deem necessary to evidence the truth and accuracy of such supplement or amcndment to the Ofticial Statement. For the purposes of this subsection, bet�veen the date hereof and the date which is 25 days after the End of the Underwriting Period for ihe 2007 Boncls, the Redevelopment Agency will furnish such information with respect to itself� as the Underwriter may from time to time reasonably request; �z.�-nGn�tz �,.-� (1) if the information contained in the Official Statement relating to the Redevelopment Agency is amended or supplemented pursuant to Section 7(k), at the time of such supplement or amendment thereto and (unless subsequently again supplemented or amended pursuanl to such subparagraph) at all times subsequent thereto up to and �ncluding the date which is 25 days atter the End of the Underwriting Period for the 2007 Bonds, the portions of the Officiai Statement so supplemented or amended (including any financial and statistical data contained therein), 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; (m) any certificate signed by any officer of the Redevelopment Agency and delivered to the Underwriter pursuant to the Redevelopment Agency Agreements or this Purchase Agreement or any document contemplated thereby shall be deemed a representation and wananty by the Redevelopment Agency to the Underwriter as to the statements made therein and that such officer shall have been duly authorized to execute the same; (n) to the best knowledge of the Redevelopment Agency, there is no public vote or referendum pending or proposed, the results of which could materially adversely affect the transactions contemplated by the Official Statement or the Redevelopment Agency Agreements or the validity or enforceability of the 2007 Bonds; (o) the Redevelopment Agency will apply the proceeds from the 2007 Loan for the purposes specified in the 2007 Loan Agreement; (p) the Low and Moderate Income Housing Fund does not, on the date hereof, contain any "excess surplus" (as that term is defined in Section 33334.12 of the Redevelopment Law) that would cause the Redevelopment Agency to be subject to the prohibitions contained in Section 33334.12(e) of the Redevelopment Law. (q) as of the time of acceptance hereof and as of the date of the Closing, except as otherwise disclosed in the Official Statement, the Redevelopment Agency has complied with all material provisions of the Redevelopment Law, without limitation, use of the Tax Revenues and the filing requirements of Section 33080, 33080.6 and 33334.6 of the Redevelopment Law as applicable to the Redevelopment Abency and the Project Area. (r) the iinancial statements of the Redevelopment Agency contained in the Ofiicial Statement as Appendix B fairly present the financial positions and results of operations thereof as of the dates and for the periods therein set forth, and the Redevelopment Agency has no reason to believe that such financial statements have not been prepared in accordance with generally accepted accounting principles consistently applied; and (s) the Redevelopment Agency is in compliance with all of its prior continuing disclosure undertakings entered into pursuant to Rule ISc2-12 and at or prior to the Closing Date, the Redevelopment Abenry shall have duly authorized, executed and delivered the Continuing Disclosure Agreement. Section 8. Closing. At 8:00 A.M., Califomia time, on January _, 2007, or on such earlier or later date as may be mutually agreed upon by parties hcrcto (the "Closi�rg Dute"), the �inancing Authority, will deliver or cause to be delivered to the Underwriter the duly executed Bonds through the facilities of The Depository 'I'rust Company in New York, New York ("DTC"') by the initial deposit with the �frustee (in care of DTC) through the Fast Automated Securities Transfer System, and will deliver or z��-oc�u�z �x-z cause to bc delivered at the offices of Bond Counsel in I.os Angeles, Califomia, or such other place as shall have been mutually agreed upon by the parties,the other documents described herein; and the Undenvriter shall pay the purchase price of each Series of 2007 Bonds as set forth in Section 1 of this Purchase Agreement, less the premium for the Financial Guaranty Policy in the amount of � , which the Underwriter will wire directly to the Bond Insurer. The 2007 Bonds shall be issued in fully registered foRn. It is anticipated that CUSIP identification numbers will be inserted on the 2007 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 Undenvriter to accept delivery of the 2007 Bonds in accordance with the terms of this Purchase Agreement. Section 9. Termination. The Underwriter shall have the right to terminate the obligations of the underwriters under this Purchase Agreement to purchase, to accept delivery of and to pay for the 2007 i3onds by notifying the Financing Authority of its election to do so if, after the execution hereof and prior to the Closing Date: (1) legislation (including any amendments thereto), resolution, rule or rebulation (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 rendered which, in the reasonable opinion of the linderwriter, would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the 2007 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 or escalation of military hostilities by or against 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 emergency or calamity or crisis or any change in financial markets resulting from the foregoing, which, in the reasonable opinion of the Undenvriter, would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the 2007 Bonds on the terms and in the manner contemplated 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 any national securities exchange which materially adversely affects the market price of the 2007 Bonds; (4) the imposition by the New York Stock Exchange or other national securities exchange, or any governmental authority, of any material restrictions not now in force with respect to the 2007 Bonds or obligations of the general character of the 2007 Bonds or securities generally, or the material increase of any such restrictions now in force, including those relating to the extension of credit by, or the charge to the net capital requirements of, the Underwriter which, in the reasonable opinion of the Undenvriter would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the 2007 Bonds on the terms and in the manner contemplated in the Official Statement; (S) legislation enacted (or resolution passed) by or introduced or pending legislation amended in the Congress or recommended for passage by the President of the United States, or an order, decree or injunction issued by any court of competent jurisdiction, or an order, ruling, regulation (final, temporary or proposed) issued or made by or on behalf of the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter, to the effect that securities of the general character of the 2007 Bonds, or the 2007 Bonds, including any or all underlying arrangements, are not exempt from registration under the Securities Act of 1933, as amended, or that the 2007 Indenture is not exempt from qualification under the Trust Indenture Act of 1939, as amended, or that the execution, offering or sale of obligations of the general character of the 2007 Bonds, including any or all underlying arrangements, as contemplated hereby or by the Official Statement, otherwise is or would be in violation of the federal securities laws as amended and then in effect; (6) action by or on behalf of the State or the California Franchise '1'ax E3oard, with the purpose or effect, directly or indirectly, of imposing California personal income taxation upon such interesi as would be received by the Owners of the 2007 Bonds; (7) (i) legislation (including any amcndment thereto) shall have been introduced in or adopted by either House of the Congress of the United States or recommcnded to the Congress or otherw�se endorsed for passage 2?4-ut,n42 �x-2 10 by the President of the United States, the Treasury Department of the United States, the Internal Revenue or the chairman or ranking minority member of the Committee on Finance of the United States Senate or the C'ommittee on Ways and Means of tlie United States House of Representatives, or legislation is proposed for consideration by either such committee by any member thereof or presented as an option for consideration by either such committee by the staff of such committee, or by the staff of the Joint Committee on Taxation of the Congress of the United States, or a bill to amend the Internal Revenue Code shall be filed in either house, or (ii) a decision shall have been rendered by any federal or state court, or (iii) an order, filing, ruling or regulation shall have been issued or proposed by or on behalf of the 'Creasury Department of the United States or the Internal Revenue Service or any other agency of the United States, or (iv) a release or official statement shall have been issued by the President of the United States or by the Treasury Department of the United States or by the Internal Revenue Service, the effect of which, in any such case described in clause (i), (ii), (iii), or (iv), would be to impose, directly or indirectly, federal income taxation upon interest received on obligations of the general character of the 2007 Bonds or upon income of the general character to be derived by the Financing Authority, other than as imposed on the 2007 Bonds and income therefrom under the federal tax laws in effect on the date hereof, in such a manner as in the reasonable judgment of the Underwriter would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the 2007 Bonds on the terms and in the manner contemplated in the Official Statement; (8) the withdrawal or downgrading or any notice of an intendcd or potential downgrading of any rating of the obligations of the Financing Authority or the Redevelopment Agency (including the rating to be issued with respect to the 2007 Bonds) by a "nationally recognized statistical rating organization," as such term is defined for purposes of Rule 436(g)(2) under the Securities Act of 1933, as amended which, in the reasonable opinion of the Underwriter, would make it impracticable or inadvisable to proceed with the offer, sale or delivery of the 2007 Bonds on the terms and in the manner contemplated in the Official Statement; (9) any event occurring, or information becoming known which, in the reasonable judgment of the Underwriter, makes 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 of a material fact or omits to state a material fact to be stated therein or necessary in order to make the statements therein, in the light of the circumstances under which they were made, not misleading; (]0) any change or development involving a prospective change in the condition of the Financing Authority or the Redevelopment Agency, financial or otherwise, or in the operations of the Financing Authority or the Redevelopment Agency from those set forth in the Official Statement that makes the 2007 Bonds, in the reasonable judgment of the Underwriter, impracticable or inadvisable to offer, sell or deliver the 2007 Bonds on the terms and in the manner contemplated by the Official Statement; (1 I)(i) trading generally shall have been suspended or materially limited on or by, as the case may be, any of the New York Stock Exchange or the Nasdaq National Market; (ii) trading of any securities of the Financing Authority shall have been suspended on any exchange or in any over-the-counter market; (iii) a material disruption in securities settlement, payment or clearance services in the United States shall have occuned; or (iv) any moratorium on commercial banking activities shall have been declared by Federal or New York State authorities; or (12) the purchase of and payment for the 2007 Bonds by the Underwriter, or the resale of the 2007 Bonds by the Underwriter, on the terms and conditions herein provided shall be prohibited by any applicable law, governmental authority, board, agency or commission. Section 10. Closing Conditions. l�he Underwriter hereby enters into this Purchase Agreement in reliance upon the representations and warranties of the Financing Authority and the Rcdcvclopment Agency contained hercin and the represeiitations and warranties to be contained in the documents and instruments to be delivered on the Closing Date and upon the performance by the Financing Authority, the Redevelopment Agency and the Trustee of their respective oblibations both on and as of the date hereof and as of the Closing I�ate. Accordingly, the obligations of the tlnderwriter under this Purchase Agreement to purchase, to accept delivery of and to pay tor the 2007 Bonds shall be subject, at the option ??4-nb���l? �x-2 �� of the Underwriter, to the accuracy in all material respects of the representations and warranties of the f�inancing Authority and the Redevelopment Agency contained herein as of the date hereof and as of the Closing Date, to the accuracy in all material respects of the statements of the officers and other offic�als of the Financing Authority, the Redevelopment Agency and the Trustee made in any certificate or document furnished pursuant to the provisions hereof, to the performance by ihe Financing Authority, the Redevelopment Agency and the Trustee of their respective obligations to be performed hereunder and under the Financing Authority Agreements and the Redevelopment Agency Agreements, at or prior to the Closinb Date, and also shall be subject to the following additional conditions: (a) the Underwriter shall receive, within seven business days after the date hereof, copies of the Official Statement (including all information permitted to have been omitted from the Preliminary Official Statement by the Rule 15c2-12 and any amendments or supplements as have been approved by the Underwriter), in such reasonable quantiry as the Underwriter shal! have requested; (b) on the Closing Date, the Financing Authority Abreements and the Redevelopment Agency Abreements shall have been duly authorized, executed and delivered by the parties thereto, all in substantially the forms heretofore submitted to the Underwriter, with only such changes as shall have been agreed to in writing by the Underwriter, and such agreements shall be in full force and effect; and there shall be in full force and effect such resolutions of the governing boards of the Financing Authority and the Redevelopment Agency as, in the opinion of Bond C:ounsel, shall be necessary or appropriate in connection with the transactions contemplated hereby; (c) on the Closing Date, all necessary action of the Financing Authority relating to the execution and delivery of the 2007 Bonds will have been taken and will be in full force and effect and �vill not have been amended, modified or supplemented; (d) at or prior to the Closing Date, the Underwriter shall have received the follo�ving documents, in each case satisfactory in form and substance to the Underwriter: (i) the Financing Authority Agreements, the Redevelopment Agency Agreements and ihe Official Statemeni, each duly executed and delivered by the respective parties thereto, and certified copies of the Financing Authority Resolution, the Redevelopment Agency Resolution and Resolution No. 07- adopted by the City Council of the City on November _, 2006 making, among other things, a Fnding of sibnificant public benefit; (ii) the approving opinion of Bond Counsel, dated the Closing Date and addressed to the Pinancing Authority, in substantially the form attached to the Official Statement as Appendix E, together with a letter of Bond Counsel, addressed to the Underwriter to the effect that such opinion may be relied upon by the Underwriter to the same extent as if such opinion were addressed to it; (iii) the supplemental opinion of Bond Counsel, dated the Closing Date and addressed to the lJnderwriter, substantially to the effect that: (A) this Purchase Agreement has been duly authorized, executed and delivered by the Financing Authority and is a valid and binding agreement of the Financing Authority, enforceable in accordance «�ith its terms, except as enforcement thereof may be limited by bankruptcy, insolvency or other laws affecting the enforcement of creditors, rights and by the application of equitable principles if equitable remedies are sought; (B) the 2007 Bonds are not subject to the registration requirements of the Securit�es Act of 1933, as amended, and the 2007 Indenture is exempt trom qualification under the 'I'rust Indenture Act of 1939, as amended; (C) the ('ontinuing Disclosure Agreement has been duly author�zed, executed and delivered by the Financing Authority; and (D) the statements contained in the Official Statement under the captions "TIiE SF.RIFS 2007 A BUNDS," � �a-ur,ud2yx-2 � "SECURITY AND SOURCES OF PAYMENT FOR THE BONDS" and "TAX MnTTERS" and contained in Appendix E, insofar as such statements expressly summarize certain provisions of the 2007 Bonds, the 2U07 [ndenture, and the final opinion of Bond Counsel concerning certain federal tax matters relating to the 2007 Bonds, are accurate in all material respects; (iv) an opinion of Bond Counsel with respect to the Prior Bonds, dated the Closing Date and addressed to the Financing Authority, the Redevelopment Agency and the Underwriter, to the effect that all of the liability of the Financing Authority with respect to the Prior Bonds has ceased and been completely discharged (except that the holders thereof shall be entitled to the payment of the principal, interest and premium with respect to the Prior Bonds from moneys deposited in the applicable Escrow Fund), and the Prior Bonds will no longer be considered outstanding under the Trust Agreement pursuant to which each such Prior Bonds �vere issued. (v) the opinion of Richards, Watson & Gershon, A Professional Corporation, as General Counsel to the Financing Authority, dated the Closing Date and addressed to the Financing Authority and the Underwriter, in substantially the form of Exhibit B; (vi) the opinion of Richards, Watson & Gcrshon, A Professional Corporation, as General Counsel to the Redevelopment Agency, dated the Closing Date and addressed to the Financing Authority and the Underwriter in substantially the form of Exhibit C; (vii) the opinion of Disclosure Counsel, dated the Closing Date and addressed to thc Financing Authority and the Redevelopment Abency �and the Underwriter], to the effect that, on the basis of the information made available to them, no facts came to their attention in connection with the preparation of the Official Statement which cause them to believe that the Official Statement as of its date (excluding therefrom financial, engineering and statistical data, forecasts, projections, estimates, assumptions and expressions of opinions, statements relating to DTC, Cede & Co. and the operation of the book-entry system, the Bond Insurer and the Financial Guaranty Insurance Policy and the appendices (except for Appendix F), as to all of which no view need be expressed) contained any untrue statcment of a material fact or omitted to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading in any material respect, the 2007 Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the 2007 Indenture is exempt from qualification under the Trust Indenture Act of 1939 as amended[, and the Continuing Disclosure Agreement provides a suitable basis for the Underwriter, in connection with the Offering (as defined in Rule 15c2-12) of the 2007 Bonds to make a reasonable determination as required by section (b)(5) of such Rule.]. [(viii) the opinion of ("Underwriter's Counsel") dated the Closing Date and addressed to the Underwriter to the effect that, on the basis of the information made available to them, no facts came to their attention in connection with the preparation of the Official Statement which cause them to believe that the Official Statement as of its date (excluding therefrom financial, engineering and statistical data, forecasts, projections, estimates, assumptions and expressions of opinions, statements relating to DTC, Cede & Co. and the operation of the book-entry system, the Bond Insurer and the Financial (ivaranty Insurance Policy and the appendices (except for Appendix F), as to all of which no view need be expressed) contained any untrue statement of a material fact or omitted to state a mater�al fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading in any material respect, the 2007 Bonds are not subject to the registration requirements of the Securities Act of ] 933, as amended, and the 2007 Indenture is exempt trorn qualification under the Trust Indenture Act of 1939, as amended, and the Continuing Uisclosure Agreement provides a suitable basis for the tJnderwr�ter, in connection �vith the Offering (as defined in z;�-uc,uaz.i,�-z 13 Rule 15c2-12) of the 2007 Bonds to make a reasonable detern�ination as required by section (b)(5) of such Rule. � (ix) the opinion of counsel to the Trustee, dated the Closing Date and addressed to the [Jndenvriter and the Financing Authority, to the effect that: (A) the Trustee has been duly incorporated as a national banking association, duly organized and validly existing and in good standing under the laws of the United States of America and the State, having the legal authority to exercise trust powers in the State and having full power and authority to enter into and to perform its duties as Trustee under the 2007 Indenture; (B) the Trustee has duly authorized, executed and delivered the 2007 Indenture and the 2007 Loan Agreement, and by all proper corporate action has authorized the acceptance of the trusts of the 2007 Indenture; (C) the 2007 Indenture and the 2007 I�oan Agreement constitutes a legally valid and binding agreement of the Trustee, enforceable against it in accordance with its respective terms; (D) the 2007 Bonds have been validly authenticated, registered and delivered by the Trustee; (E) no authorization, approvai, consent or other order of the State or any other govemmental authority or agency within the State having jurisdiction over the Trustee, or, to such counsel's knowledge after reasonable investigation, any other person or corporation, is required for the valid authorization, execution, delivery and performancc by the Trustee of the 2007 Indenture; and (F) the execution and delivery of the 2007 Indenture, and compliance by the Trustee with the provisions of the 2007 Indenture under the circumstances contemplated thereby, does not and will not in any material respect conflict with or constitute on the part of the Trustee a breach or default under any agreements or other instrument to which the Trustee is a parry (and of which such counsel is aware after reasonable investigation) or by which it is bound (and of which such counsel is aware after reasonable investigation) or any existing law, regulation, court order or consent decree to which the Trustee is subjecr (x) the opinion of co�snsel to Wells Fargo Bank, National Association ("Wells Fargo "), dated the Closing Date and addressed to the Underwriter and the Financing Authority, to the effect that: (A) Wells Fargo has been duly incorporated as a national banking association, duly organized and validly existing and in good standing under the laws of the United States of America and the State, having the legal authority to exercise trust powers in the State and having full power and authority to enter into and to perform its duties as Trustee Fargo under the 2007 Indenture and as Escrow Bank under the Gscrow Agreement; (B) Wells Fargo has duly authorized, executed and delivered the each of the 2007 Indenture, the 2007 Indenture Loan Agreement and the Escrow Agreement, and by all proper corporate action has authorized the acceptance of the trusts of the 2007 Indenture; (C) each of the 2007 Indenture, the 2007 Indenture Loan Agreement and the Escrow Agreement constitutes a legally valid and binding agreement of Wells Fargo, enforceable against it in accordance with its respective terms; (D) the 2007 Bonds have been validly authenticated, registered and delivered by Wells Fargo, as Trustee; (E) no authorization, approval, consent or other order of the State or any other governmental authority or agency within the State having jurisdiction over Wells Fargo, or, to such counsel's knowledge after reasonable investigation, any other person or corporation, is required for the valid authorization, execution, delivery and performance by Wells Fargo of the 2007 Indenture or the Escrow Agreement; and (F) the execution and delivery of the 2007 Indenture and the Escrow Agreement, and compliance by Wells Fargo with the provisions of each of the 2007 Indenture and the Escrow Agreement under the circumstances contemplated thereby, does not and �vill not in any material respect conflict with or constitute on the part of Wells Fargo a breach or default under any agreements or other instrument to which Wells Fargo is a party (and of which such counsel is aware after reasonable investigation) or by which it is bound (and of which such counsel is aware after reasonable investigation) or any existing law, regulation, court order or consent decree to which Wells Fargo is sub�ect; (xi) a certiticate of the Financing Authority dated the Closing Date, s�gned by a duly authorized official, in form and substance satisfactory to the ilndenvriter, to the effect that, to the best of '_�.l-nGud? pr-� 14 such official's knowledge: (A) the representations and warranlies of the Financing Authority contained in the Purchase Agreement are true and correct in all material respects on and as of the Closing Date with the same effect as if made on the Closing Date; (B) the Financing Authority has compl�ed tvith the requirements of the Financing Authority Agreements required to be complied with on and as of the Closing Date with respect to the 2007 Bonds; and (C) no event materially adversely affect�ng the Financing Authority has occurred since the date of the Official Statement; (xii) a certificate of the Redevelopment Agency dated the Closing Date, signed by a duly authorized official, in form and substance satisfactory to the Underwriter, to the effect that, to the best of such official's knowledge: (A) the representations and warranties of the Redevelopment Agency contained in the Purchase Agreement are true and correct in all material respects on and as of the Closing Date with the same effect as if made on the Closing Date; (B) the Redevelopment Agency has complied with the requirements of the Redevelopment Agency Agreements required to be complied with on and as of the Closing Date; (C) no event materially adversely affecting the Redevelopment Agency has occurred since the date of the Offcial Statement; and (D) that the financial statements of the Redevelopment Agency contained in the Official Statement fairly present the financial positions and results of operations thereof as of the dates and for the periods therein set forth, and such officer has no reason to believe that such financial statemenis have not been prepared in accordance with generally accepted accounting principles consistently applied; (xiii) a certificate of the Trustee dated the Closing Date, signed by a duly authorized official, in form and substance satisfactory to the Underwriter, to the effect that: (A) the Trustee is a national banking association organized and existing under and by viriue of the laws of the United States, having the fuli power and being qualified to enter into and perform its duties under the 2007 Indenturc and to authenticate and deliver the 2007 Bonds to the Underwriter; (B) the Trustee is duly authorized to enter into the 2007 Indenture and to execute and deliver the 2007 Bonds to the Underwriter pursuant to the 2007 Indenture; (C) the 2007 Bonds will have been duly authenticated and delivered by the Trustee; (D) the execution and delivery of the 2007 Indenture and the 2007 Loan Agreement and compliance with the provisions on ihe pari of ihe "I'rustee contained in the 2007 Indenture and ihe 2007 Loan Agreement, will not conflict with or constitute a breach of or default under any law, administrative regulation, judgment, decree, loan agreement, indenture, note, resolution, agreement or other instrument to which the Trustee is a party or is otherwise subject (except that no representation or warranty is made with respect to any federal or state securities or blue sky laws or regulations), nor will any such execut�on, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the properties or assets held by the Trustee pursuant to the lien created by the 2007 Indenture under the terms of any such law, administrative regulation, judgment, decree, [oan agreement, indenture, bond, note, resolution, agreement or other instrument, cxcept as provided by the 2007 Indenture; and (E) to the best of the knowledge of the Trustee, it has not been served with any action, suit, proceeding, inquiry or investigation in law or in equity, before or by any court, govemmental agency, public board or body, nor is any such action or other proceedinb threatened against it, affecting its existence, or the titles of its officers to their respective offices or seekinb to prohibit, restrain, or enjoin�ng the execution and delivery of the 2007 Bonds or the collection of revenues to be applied to pay the principal, premium, if any, and interest with respect to the 2007 Bonds, or the pledge thereof, or in any way contesting or affecting the validity or enforceability of the 2007 Indenture or contesting the powers of the "frustee or its authority to enter into, adopt or perform its obl�gations under any of the fore�oing to which it is a party, wherein an unfavorable decision, ruling or finciing �vould materially adversely affect the validity or enforceability of� the 2007 E3onds, the 2007 lndcnture and the 2007 Loan Agreement or the power and authoriry of the "I'rustee to enter into and perform its respective duties under the 2007 Indenture and to authenticate and deliver the 2007 Bonds to t}ie Underwriter; , z�.��c,ua� r,c-z 1� (xiv) a certificate of Wells Fargo dated the Closing Date, signed by a duly authorizcd official, in form and substance satisfactory to the Underwriter, to the effect that: (A) Wells Far�;o is a national banking association organized and existing under and by virtue of the laws of the United States, having the full power and being qualified to enter into and perform its duties under the 2007 Indenture and the Escro�v Agreement and to authenticate and deliver the 2007 Bonds to the Underwriter; (B) Wells Fargo is duly authorized to enter into the 2007 Indenture and the Escrow Agreement and to execute and dcliver the 2007 Bonds to the Underwriter pursuant to the 2007 Indenture; (C) the 2007 Bonds have been duly authenticated and delivered by Wells Fargo, as Trustee; (D) the execution and delivery of the 2007 Indenturc, the 2007 Indenture Loan Agreement and the Escrow Agreement and compliance with the provisions on the part of Wells Fargo contained in each of the 2007 Indenture, the 2007 Indenture Loan Agreement and the Escrow Agreement, will not conflict with or constitute a breach of or default under any ]aw, administrative regulation, judgment, decree, loan agreement, indenture, note, resolution, agreement or other instrument to which Wells Fargo is a party or is otherwise subject (except that no representation or warranry is made with respect to any federal or state securities or blue sky la�vs or regulations), nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the properties or assets held by Wells Fargo pursuant to the lien created by the 2007 Indenture under the terms of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument, except as provided by the 2007 Indenture; and (E) to the best of the knowledge of Wells Fargo, it has not been served with any action, suit, proceeding, inquiry or investigation in law or in equity, before or by any court, governmental agency, public board or body, nor is any such action or other proceeding threatened against it, affecting its existence, or the titles of its officers to their respective offices or seeking to prohibit, restrain, or enjoining the execution and delivery of the 2007 Indenture, the 2007 Bonds or the Escrow or the collection of revenues to be applied to pay the principal, premium, if any, and interest with respect to the 2007 Bonds, or the pledge thereof, or in any way contesting or affecting the validity or enforceability of the 2007 Indenture, the 2007 Indenture Loan Agreement or the Escrow Agreement or contesting its powers or its authority to enter into, adopt or perform its obligations under any of the foregoing to which it is a party, wherein an unFavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the 2007 Indenture, the 2007 Indenture Loan Agreement the 2007 Bonds or the Escrow Agreement or the power and authority of Wells Fargo to enter into and perform its respective duties under the 2007 Indenture, the 2007 Indenture Loan Agreement or the Escro�� Agreement and to authenticate and deliver the 2007 Bonds to the Underwriter; (xv) a certificate of the City signed by an authorized officer of the City dated the Closing Date to the effect that the information relating to the City in APPENDIX C-"GENERAI. INFORMATION CONCERNING THE CITY OF PALM DESERT" to the Official Statement, as of its date and as of the date of the Closing, is true and rorrect in all material respects; (xvi) a certificate of Grant Thornton LLP (the "�c�rificution Agen1 "), independent certified public accountants, dated the Closing Date, to the effect that it has verified the accuracy of the mathematical computations of the adequacy of the maturing principal amounts of the Escrow Securities with respect to the Prior Bonds to be held by the Escrow Bank, together with the interest earned and to be eamed thereon to make full and timely payment of all principal and interest due with respect to the Prior Bonds as are then outstanding, and on the specified dates at the then applicable redemption prices; (xvii) evidence of insured ratings with respect to the 2007 Bonds of "[Aaa]" by Moody's Investors Service and "[AAA]" by Standard & Poor's Ratings Services, a division of the McGraw Hill Companies being in full force and effect as of the C'losing Date; z;�t-nc,na� ix-� 16 (xviii) the Financial Guaranty Insurance Policy issued by the Bond Insurer; (xix) an opinion of Counsel to the Bond Insurer, dated the Closing Date and addresscd to the Financing Authority and the Underwriter to the effect that (a) the Financial Guaranty Insurance Policy described in the Official Statement is a legal, valid and binding obligation of the Bond Insurer enforceable in accordance with its terms, and (b) the statements in the Preliminary Official Statement and the Official Statement under the caption "FINANCIAL GUARANTY INSURANCE" and contained in APPENDIX H-"SPECIMEN FINANCfAL GUARANTY INSURANCE POL[CY'� accurately reflects and fairly represents the information purported to be shown therein; (xx) a certificate of Rosenow Spevacek Group Inc. (the "Fiscul Consul�nnt ") to the effect that the report of the Fiscal Consultant dated , 2006 (the "Report ") contained in the Official Statement does not contain any untrue statement of a material fact or omitted to state a material fact necessary to make the statemenis therein, in ihe light of the circumstances under which they were made, not misleading in any material respect, and consenting to the use of the Report in the Preliminary and Final Official Statements; (xxi) evidence that Lance, Soll and Lunghard has consented to the inclusion of its report in the Preliminary Official Statement and the Official Statement as APPENDIX B- "REDEVELOPMENT AGENCY AUDITED FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED 1UNE 30, 200[5];" (xxii) the Tax Certificate of the Financing Authority in form and substance acceptable to Fiond Counsel; filing; (xxiii) evidence that the federal tax information form 8038-G has been prepared for (xxiv) the preliminary and final Notices of Sale required to be delivered to the California Debt and Investment Advisory Commission pursuant to Section 8855(g) and 53583 of the California Government Code; and (xxv) the Blanket I.etter of Representations of the Financinb Authority to the Depository Trust Company, New York, New York, relating to the book-entry only system for the 2007 Bonds; and (xxvi) such additional legal opinions, certificates, instruments or evidences thereof and other documents as the Disclosure Counsel or Bond Counsel may reasonably request to evidence the due authorization, execution and delivery of the 2007 Bonds and the conformity of the 2007 Bonds and the 2007 Indenture with the terms of the 2007 Bonds and as summarized in the Official Statement. All of the opinions, letters, certifcates, instruments and other documents mentioned above or elsewhere in this Purchase Agreement will be deemed to be in compliance with the provisions hercof' it' and only if they are in form and substance satisfactory to the Undenvriter. If the �inanc�ng Authority shall be unable to satisfy the conditions to the Undenvriter's obligations contained in this Purchase Agreement or �f the lJnderwriter, obligations shall be terminated for any reason permitted hcrein, all obligations of the Underwriter hereunder may be terminated by thc iJndenvriter at, or at any time prior to, the Closing Date by written notice to the Financing Authority and z?a-nc,n.�z Fx-z 17 none of ihe Underwriter the Financing Authority shall have any further obligations hereunder, except that the respective obligations of the parties set forth in Sertion 10. Section 11. Expenses. (a) The Uncierwriter shall be under no obligation to pay, and the Financing Authority shall pay the following expenses incident to the performance of the Financing Authoriry's obligations hereunder: (i) the fees and disbursements of Bond Counsel and Disclosure Counsel; (ii) the cost of printing and delivering the 2007 Bonds, the Preliminary Official Statement and the Official Statement (and any amendment or supplement prepared pursuant to this Purchase Agreement); (iii) the fees and disbursements of Del Rio Advisors, LLC, as Financ�al Advisor to the Financing Authority, the Trustee and its counsel, the Escrow Bank and it counsel, the Fiscal Consultant, the Verification Agent, accountants, advisers and of any other experts or consultants retained by or for the Financing Authority or the Redevelopment Agency; and (iv) subject to Section 11(b) any other expenses and costs of the Financing Authoriry it�cident to the performance of their respective obligations in connection with the authorization, issuance and sale of the 2007 I3onds, including out-of-pocket expenses and regulatory expenses, and any other expenses agreed to by the parties. (b) The Underwriter shall pay all expenses incurred by them in connection with the public offering and distribution of the 2007 Bonds including, but not limited to: (i) all advertising expenses in connection with the offering of the 2007 Bonds; and (ii) all out-of-pocket disbursements and expenses incurred by the Underwriter in connection with the offering and distribution of the 2007 Bonds (including travel and other expenses, [the fees and expenses of Underwriter's Counsel], fees of the California Debt and Investment Advisory Commission, CUSIP Service Bureau fees and any other fees and expenses), except as provided in (a) above or as otherwise agreed to by the Underwriter and the Financing Authority Section 12. Notices Any notice or other communication to be given to the Financing Authority or the Financing Authority under this Purchase Agreement may be given by delivering the same in writing at the address of the Financing Authority set forth above, and any notice or other communication to be given to the Underwriter under this Purchase Agreement may be given by delivering the same in writing to the Underwriter: Stone & Youngberg LLC, One Ferry Building, San Francisco, Califomia 94111; Attention: [James R. Cervantes, Managing Director]. Section 13. Parties in Interest. This Purchase Abreement is made solely for the benefit of the Financing Authority and the Underwriter (including the successors or assigns of the Underwriter) and no other person shall acquire or have any right hereunder or by virtue hereof. All the representations and warranties of the parties hereto contained in this Purchase Abreement shall remain operative and in full force and effect, regardless of (a) any investigations made by or on behalf of the Underwriter or the Financing Authority or (b) delivery of and payment for the 2007 Bonds. The agreements contained in Section 10 herein shall survive any termination of this Purchase Agreement. Section 14. Severability. In the event any provision of this Purchase Agreement shall be held or deemed to be invalid, inoperative or unenforceable by any court of competent jurisdiction, such holdinb shall not invalidate or render unenforceable any other provision hereof. Section 15. Governing I,aw; Venue. "This Purchase Agreemeni shall be governed and interpreted exclusively 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 proceedings arising out of� this Purchase Agreement or any document related hereto shall be tiled and maintained in a court of competent jurisdiction for matters arising in Riverside County, Califomia. By execution of and delivery of this Purchase Agreement, the parties hereto accept and consent to the aforesaid jurisdiction. � za nc,uaz rx-'- 1R Section 16. Execution in Counterparts. This Purchase Agreement may be executed in any number of counterparts, all of which taken together shall constitute one agreement, and any of the parties hereto may execute the Purchase Agreement by signing any such counterpart. Section 17. Entire Agreement. The parties agree that the terms and conditions of this Yurchasc Agreement supersede those of all previous agreements between the parties, and that this Purchase Agreement contains the entire agreement between the parties hereto. In the event of a dispute between the parties under this Purchase Agreement, 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. Z�a-on�u2 �x-, I �) Section 18. Effectiveness. This Purchase Agreement shall be effective as of the date set forth above upon the execution of the acceptance hereof by authorized officers of the Financing Authority and approval by the Redevelopment Agency shall be valid and enforceable as of'the time of such acceptance and approval. Very truly yours, STONE & YOUNGBERG LLC : Acceptcd: PALM DESERT FINANCING AUTHORITY : Carlos L. Ortega, Chief Administrative Officer Approved: PALM DESERT REDEVELOPMENT AGENCY By: Carlos L. Ortega, Executive Director James R. Cervantes, Managing Director z��-uc,uaz ��� 20 SCHEDULEI SINKING FUND PAYMENT DATES, AMOUN"CS, RATES, YIELDS AND PRICES $ 2007 Series A Bonds Principal lnterest A ril 1 Amount Rate Yield Price %Term Bond due April l, 20_-Yield: %-Price: % z;a-��nruz �x-z IQl EXHIBIT A-1 PALM DESERT FINANCING AUTHORITY TAX ALI,OCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS ANENDED) 2007 SERIES A FORM OF THE CER'fIFICATE OF THE FIANCING AUT�IORI'fY REGARDING PRELIMINARY OFFICIAL STATLMENT The undersigned hereby states and certifies: 1. Tha1 he is 1he duly appointed, qualified and acling Chief Administrative Ofiicer of the Palm Desert Financing Authority (the "Financing Authority") and as such, is familiar with the facts herein certified and is authorized and qualified to certify the same; 2. That there has been delrvered to Stone & Youngberg LLC (the "Underwriter") of the captioned Bonds, a Preliminary Official Statement, relative to the captioned Bonds, dated December _ 2006 (including the cover page and all appendices thereto, the "Preliminary Official Statement"), which the Financing Authority, deems final as of its date for purposes of Rule ISc2-12 promulgated under the Securities Exchange Act of 1934, as amended ("Rule 15c2-12"), except for information permitted to be omitted therefrom by Rule 15c2-12; and 3. The Financing Authority hereby approves the use and distribution by the linderwriter of the Preliminary Official Statement. Dated: December , 200G PALM DESERT FINANCING AUTHORITY By: Carlos L. Orte�;a, Chief Administrative Officer � ;.t-nbu�1? pc-, /�-�-� EXHIBIT A-2 PALM DESERT FINAiVCING AU'I'HORITY TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED) 2007 SERIES A FORM OF THE CERTIFICATE OF THE FINANCING AUTHORII'Y REGARDING PRELIMINARY OFFICIAL STATEMENT The undersigned hereby states and certifies: l. That he is ihe duly appointed, Qualified and acting Executive Director of the Palm Desert Redevelopment Abency (the "Redevelopment Agency") and as such, is familiar with thc facts herein certificd and is authorized and qualified to certify the same; 2. That there has been delivered to Stone & Youngberg LLC (the "Undenvriter") of the captioned Bonds, a Preliminary Official Statement, relative to the captioned Bonds, dated December _ 2006 (including the cover page and all appendices thereto, the "Preliminary Official Statement"), which with respect to the statements contained under the captions "THE REDEVELOPMENT AGENCY" and "THE PROIECT AREA" and contained in APPENDIX B-"REDEVELOPMENT AGENCY AUDITED FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED 1UNE 30, 200[5]" are true, correct and complete in all material respects and such statements do not omit to state a material fact necessary to make such statements, in light of the circumstances under which they were made, not misleading. Dated: December , 2006 PALM DESERT REDEVELOPMENT AGENCY I� Carlos L.. Ortega, Executive Director ?;a-�K�1142 �x -'_ /�-Z- � � EXHIBIT B FOR11 OF OPINION OF FINANCIAL AIJTHORITY COIINSEL [Letterhead of Counsel to the Financing Authoriry] January _, 2007 Palm Desert Financing Authority Palm Desert, Califomia Stone & Youngberg LLC San Francisco, Califomia Re: Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A Ladies and Gentlemen: Our office has acted as counsel to the Palm Desert Financing Authoriry (the "Financing Authority") in connection with the issuance, sale and delivery of $ aggregate principal amount of the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A(the "2007 Bonds"). In connection with the 2007 Bonds, we have reviewed: (i) those documents relating to the existence, orbanization and operation of the Financing Authority; (ii) Resolution No. of the Financing Authority adopted November _, 2006 (the "Resolution") authorizing the issuance, execution and delivery of the 2007 Bonds; (iii) the Indenture of Trust dated as of January 1, 2007 with respect to the 2007 Bonds (the "2007 Indenture"), by and between the Financing Authority and Wells Fargo Bank, National Association, as trustee (the "Trustee"); (iv) the Escrow Agrecment dated as of January 1, 2007 (the "Escrow Agreement"), by and among the Financing Authority, the Redevelopment Agency and Wells Fargo Bank, National Association, as escrow banlc (the "Escrow Bank"); (v) the Project Area No. 1, As Amended Loan Agreement made and executed as of January 1, 2007 (the "2007 Loan Agreement"), by and among the Pinancing Authority, the Palm Desert Redevelopment Agency (the "Redevelopment Agency") and the Trustee with respect to the loan of the proceeds of the 2007 Bonds by the Financing Authority to the Redevelopment Agency, (the "2007 Loan"); (vi) the Bond Purchase Agreement, dated December _, 2006 (the "Purchase Agreement"), between the Financing Authority and Stone & Younbberg LLC, as underwriter (the "Undenvriter"), and approved by the Redevelopment Agency; and (vii) the Official Statement, dated December , 2006, with such changes and amendments thereto as of the date of this opinion (the "Official Statement"). The 2007 Indenture, the 2007 Loan Agreement, the 2007 Loan, the Escrow Agrecment and the Purchase Agreement are collectively referred to herein as the "Financing Authority Agreements." Any capitalized term used herein and not otherwise defined shall have the meanings given to such terms as specified in the Official Statement. ? �a-u��na� �x-2 I3- I Sased on ihe %regoing, we aze of the opinion that: l. The Financing Authority is a joint exercise of power authority duly creatcd, organized and existing under the laws of the State of Califomia pursuant to an Agreement entitled "Joint Exercise of Powers Ageement" dated January 26, 1989, between the City of Palm Desert and the Redevelopment Agency, and has full legal right, power, and authoriry to issue the 2007 Bonds. 2. The Resolution approving and authorizing the issuance, execution, and delivery of the 2007 Bonds, and the execution and delivery of the Financing Authority Agreements and the Official Statement has been duly adopted, and is in full force and effect and has not been modified, amended or rescinded. 3. The Financing Authoriry has the full legal right, power and authority to execute, deliver and perform its obligations and duties under the 2007 Bonds and Financing Authority Agreements, and the Financing Authority has complied with the provisions of applicable law in al] matters relatin� to the transactions contemplated by the 2007 Bonds and the Financing Authority A�eements. 4. The Financing Authority Agreements have each been duly authorized, executed and delivered by the Financing Authority, and assuming due authorization and delivery by the other parties thereto, each is in full force and ef%ct and, assuming due authonzation, execution, and delivery by the other parties thereto, constitute legal, valid and binding agreements of the Financing Authority enforceable against the Financing Authority in accordance with their respective terms, except as the enforceability thereof may be limited by any applicable bankruptcy, insolvency, debt adjustment, fraudulent conveyance or transfer, moratorium, reorganization or other similar laws affecting creditors' rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against public entities in the State of California. 5. No approval, consent, or authorization of any govemmental or public agency, authority, or person is required for the execution and delivery by the Financinb Authority of the Financing Authoriry Agreements or the Official Statement, or the performance by the Financing Authority of its obligations thereunder or for the issuance, sale and delivery of the 2007 Bonds, except as such approval, consent or authorization may have been obtained, and except as may be required under State securities or blue sky laws in connection with the purchase and distribution of the 2007 Bonds by the Underwriter. G. The execution and delivery of the Financing Authority Agreements by the Financing Authority, and compliance with the provisions thereof, under the circumstances contemplated thereby, does not in any material respect conflict with or constitute a breach of, or default under, any insmunent relating to the organization, existence or operation of the Financing Authoriry, or any commitment, agreement or other instrument to which the Financing Authority is a party, or by which it is bound, or any existing law, ruling, regulation, ordinance, judgment, order or decree to which the Financing Authonry is subject, which breach or default has or may have a material adverse effect on the ability of the Financing Authority to perform its obligations under the Financing Authority Agreements. z3�-uew� u,-z f3-2 7. To the best of our knowledge, except as otherwise disclosed in ihe Official Statement, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, or before any court, public board or body pending or threatened against the Financing Authority, challenging the creation, organization, existence or powers of the Financing Authority, or challenging the capacity of its officers, or the validiry of the 2007 Bonds, the Financing Authority Agreements or the transactions contemplated thereby, or the proceedings taken by the Financing Authoriry in connection �vith the authorization, execution or delivery of the 2007 Bonds or the Financing Authoriry Agreements, wherein any unfavorable decision, ruling or finding would adversely affect the transactions contemplated thereby or by the Official Statement, or which, in any way, would adversely affect the validity or enforceability of the 2007 Bonds or the Financing Authority Agreements or, in any material respect, the ability of the Financing Authority to perform its obligations thereunder. This opinion is based on such examination of the law of the State of Califomia as we deemed refevant for the purposes of ihis opinion. We have not considered the effect, if any, of the laws of any other jurisdiction upon matters covered by this opinion. We express no opinion herein as to the status of the 2007 Bonds or the interest thereon, or the Financing Authority Agreements under any federal securities laws or any state securities or "Blue Sky" law or any federal, state or local tax law. Further, we express no opinion with respect to any indemnifcation, contribution, choice of law, choice of forum or �vaiver provisions contained in the Financing Authority Agreements. Without limiting any of the foregoing, we express no opinion as to any matter other than as expressly set forth above. Whenever a statement herein is qualified by "to the best of our knowledge," it shall be deemed to indicate that, during the course of our representation of the Financing Authority in connection with the financing described herein, no information that would give us current, actual knowledge of the inaccuracy of such statement has come to our attention. We have not, however, undertaken any independent investigation to determine the accuracy of such statements, and any limited inquiry undertaken by us durinb the preparation of this opinion letter should not be regarded as such investigation. No inference as to our knowledge of any matters bearing upon the accuracy of any such statement should be drawn from the fact of our representation of the Financing Authority. This letter is furnished by us as counsel to the Financing Authority. Other than the Financing Authority, no attorney-client relationship has existed or exists between our firm and you in connection with the 2007 Bonds or by virtue of this letter. We disclaim any obligation to update this letter. This letter is delivered to you, is solely for your benefit and is not to be used, quoted or otherwise referred to or relied upon for any other purpose or by any other person. This letter is not intended to, and may, not, be rclied upon by owners of the 2007 Bonds. Very truly yours, �t4-OGu42�pc-2 R-3 EXHIBIT C FORM OF OPINION OF REDEVELOPMENT AGENCY COUNSEL [Letterhead of Counsel to the Redevelopment Agency] January _. 2007 Palm Desert Financing Authority Palm Desert, California Stone & Youngberg LLC San Francisco, California Re: Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. l, As Amended), 2007 Series A Ladies and Gentlemen: Our office has acted as counsel to the Palm Desert Redevelopment Agency (the "Redevelopment Agency") in connection with the issuance, sale and delivery of $ aggregate principal amount of the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. l, As Amended), 2007 Series A(the "2007 Bonds"). In connection with the 2007 Bonds, we have reviewed: (i) those documents relating to the existence, organization and operation of the Redevelopment Agency; (ii) Resolution No. of the Redevelopment Agency adopted November _, 2006 (the "Resolution") authorizing the execution and delivery of the Redevclopment Agency Agreements (defined below); (iii) the Project Area No. I, As Amended Loan Agreement made and executed as of January 1, 2007 (the "2007 Loan Agreement"), by and among the Palm Desert Financing Authority (the "Financing Authority"), the Redevelopment Agency and Wells Fargo Bank, National Association (the "Trustee") with respect to the loan of the proceeds of the 2007 Bonds by the Financing Authority to the Redevelopment Agency (the "2007 Loan"); (iv) the Bond Purchase Agreement, dated December _, 2006 (the "Purchase AgreemenP'), between the Financing Authority and Stone & Youngberg LLC, as underwriter (the "Underwriter"), and approved by the Redevelopment Agency; and (v) the Official Statement, dated December , 2006, with such changes and amendments thereto as of the date of this opinion (the "Official Statement"); and the Continuing Discloswe Agreement, dated January _, 2007 (the "Continuing Disclosure Agreement"), by and among the Redevelopment Agency, the Trustee and MuniFinancial, Inc., as dissemination agent. The 2007 Loan Agreement, the 2007 Loan, the Purchase Agreement and the Continuing Discloswe Agreement are collectively referred to herein as the "Redevelopment Agency A�eements." Any capitalized term used herein and not otherwise defined shall have the meanings given to such terms as specified in the Official Statement. 2?�-OGO-12,�x-2 ('-1 F3ased on the foregoing, we are of the opinion that: 1. 'rhe Redevelopment Agency is duly organized and validly existing under the Constitution and laws of the State of California. 2. The Resolution approving and authorizing the execution and delivery of the Redevelopment Agency Agreements was duly adopted at a meeting of the Redevelopment Agency which �vas called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout, and is in full force and effect and has not been amended or repealed; 3. No material litigation is pending, with service of process having been accomplished or, to the knowledge of the Redevelopment Agency, threatened, concerning the validity of the Redevelopment Agency Agreements, the corporate existence of the Redevelopment Agency, or the title of the officers of the Redevelopment Agency who will execute the Redevelopment Agency Agreements as to their respective offices; 4. The adoption of the Resolution, the execution and delivery of the Redevelopment Agency Agreements, and compliance by the Redevelopment Agency with the provisions of the foregoing, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the Redevelopment Agency a breach or default under any agreement or other instrument to which the Redevelopment Agency is a party (and of which such counsel is aware after reasonable investigation) or by which it is bound (and of which such counsel is aware aRer reasonable investigation) or by any existing law, regulation, court order or consent decree to which the Redevelopment Agency is subject; 5. The Redevelopment Agency Agreements each have been duly authorized, executed and delivered by the Redevelopment Agency and, assuming due authorization, execution and delivery by the other parties thereto, constitute legal, valid and binding agreements of the Redevelopment Agency enforceable in accordance with the respect�ve terms except as the enforceability thereof may be limited by any applicable bankruptcy, insolvency, debt adjustment, fraudulent conveyance or transfer, moratorium, reorganization or other similar laws affecting creditors' rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies abainst public entities in the State of Califomia. 6. No authorization, approval, consent, or other order of the State of California or any other governmental authority or agency �vithin the State of Califomia having jurisdiction over the Redevelopment Agency is required for the valid authorization, execution, delivery and performance by the Redevelopment Agency of the Redevelopment Agency Agreements, or for the adoption of the Resolution which has not been obtained. 7. To the best of our knowledge, except as otherwise disclosed in the Official Statement, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, or before any court, public board or body pending or threatened against the Redevelopment Agency, challenging the creation, organization, existence or powers of the Redevelopment Agency, or challenging the capacity of its officers, or the validity of the Redevelopment Agency Agreements or the transactions contemplated thereby, or the proceed►ngs talcen by the Redevelopment Agency in connection with the authorization, execution or delivery of the Redevelopment Agency Agreements, wherein any unfavorable decision, ruling or finding would adversely affect the transaciions contempiated thereby or by the Official Statement, or which, in any way, would adversely affect thc validity or enforceability of the Redevelopment Agency Ab�reements or, in any matenal respect, the ability of the Redevelopment Agency to perform rts obligations thereunder. z:.�_no�u, �x-, C-2 This opinion is based on such examination of the law of the State of Califomia as we deemed rclevant for the purposes of this opinion. We have not considered the effect, if any, of the laws of any other jurisdiction upon matters covered by this opinion. We express no opinion herein as to the status of the 2007 Bonds or the interest thereon, or the Redevelopment Agency Agreements under any federal securities laws or any state securities or "Blue Sky" law or any federal, state or locai tax law. Further, we express no opinion with respect to any indemnification, contribution, choice of law, choice of forum or waiver provisions contained in the Redevelopment Agency Agreements. Without limiting any of the foregoing, we express no opinion as to any matter other than as expressly set forth above. Whenever a statement herein is qualified by "to the best of our knowledge," it shall be deemed to indicate that, during the course of our representation of the Redevelopment Agency in connection with the financing described herein, no information that would give us current, actual knowledge of the inaccuracy of such statement has come to our attention. We have not, however, undertaken any independent investigation to determine the accuracy of such statements, and any limited inquiry undertaken by us during the preparation of this opinion letter should not be regarded as such investigation. No inference as to our knowledge of any matters bearing upon the accuracy of any such statement should be drawn from the fact of our representation of the Redevelopment Agency. This letter is furnished by us as counsel to the Redevelopment Agency. Other than the Redevelopment Agency, no attorney-client relationship has existed or exists between our firm and you in connection with the 2007 Bonds or by virtue of this letter. We disclaim any obligation to update this letter. This letter is delivered to you, is solely for your benefit and is not to be used, quoted or otherwise referred to or relied upon for any other purpose or by any other person. This letter is not intended to, and may, not, be relied upon by owners of the 2007 Bonds. Very truly yours, 2 ��s-nc,oa2 ix-? C'-3 L&J DRAFT 11 /03/06 CONTINUING DISCLOSURE AGREEMENT The Continuing Disclosure Agreement (the "Disclosure Agreement") is executed and delivered by the Palm Desert Redevelopment Agency (the "Redevelopment Agency"), Wells Fargo Bank, National Association (the "Trustee") and MuniFinancial, Inc. (the "Dissemination Agent") in connection with the issuance of the S principal amount of Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) 2007 Series A (the `Bonds"). The Bonds are being executed and delivered pursuant to an Indenture of Trust dated as of January 1, 2007 (the "Indenture"), by and between the Palm Desert Financing Authority (the "Financing Authority") and the Trustee. The Financing Authority will loan the proceeds of the Bonds to the Redevelopment Agency pursuant to a Loan Agreement made and entered into as of January 1, 2007. The Redevelopment Agency covenants and agrees as follows: SECTION 1. Puruose of this Disclosure Agreement. This Disclosure Agreement is being executed and delivered by the Redevelopment Agency for the benefit of the Holders and Beneficial Owners of the Bonds and in order to assist the Participating Underwriter in complying with Securities and Exchange Commission ("SEC") Rule 15c2-12(b)(5). The Redevelopment Agency acknowledges that the Financing Authority has undertaken no responsibility with respect to any reports, notices or disclosures provided or required under this Disclosure Agreement, and has no liability to any person, including the owners of the Bonds, with respect to any reports, notices or disclosures. SECTION 2. Definitions. In addition to the definitions set forth 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 meanings: "Annual Report" shall mean any annual report provided by the Redevelopment Agency pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. "Beneficial Owner" shall mean any person which (a) has the power, directly or indirectly, to vote or consent with respect to, or to dispose of ownership of, any Bonds (including persons holding Bonds through nominees, depositories or other intermediaries) or (b) is treated as the owner of any Bonds for federal income tax purposes. "Central Post Office" shall mean the Disclosure USA website maintained by the Municipal Advisory Council of Texas or any successor thereto, or any other organization or method approved by the staff or members of the Securities and Exchange Commission as an intermediary through which issuers may, in compliance with the Rule, make filings required by this Disclosure Agreement. "Dissemination Agent" shall mean MuniFinancial, Inc., acting in its capacity as Dissemination Agent hereunder, or any successor Dissemination Agent designated in writing by the Redevelopment Agency and which has filed with the Trustee a written acceptance of such designation. "Fiscal Year" shall mean with respect to the Redevelopment Agency, the period beginning on July 1 of each year and ending on the next succeeding June 30, or any twelve month or fifty-two week period thereafter selected by the Redevelopment Agency 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 depository, any applicable participant in its depository system. 00042 cdc- I "Listed Event" shall mean any of the events listed in Section 5(a) of this Disclosure Agreement. "National Repository" shall mean any Nationally Recognized Municipal Securities Information 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.E.C. website: http://www.sec.gov/info/municipaUnnnsir.htm. "Participating Underwriter" shall mean Stone & Youngberg LLC, as the original underwriter 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 Exchange Act of 1934, as the same may be amended from time to time. "State" shall mean the State of California. "State Repository" shall mean any public or private repository or entity designated by the State as a state repository for the purpose of the Rule and recognized as such by the Securities and Exchange Commission. As of the date of this Disclosure Agreement, there is no State Repository. SECTION 3. Provision of Annual Reports. (a) The Redevelopment Agency shall, not later than six months after the end of the Redevelopment Agency's Fiscal Year (which currently is June 30), commencing with the report for the 2006-07 Fiscal Year, provide to each Repository an Annual Report which is consistent with 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 Redevelopment Agency may be submitted separately from the balance of the Annual Report. The Redevelopment Agency 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 required to be furnished by the Redevelopment Agency hereunder. The Dissemination Agent and the Trustee may conclusively rely upon such certification of the Redevelopment Agency. If the Redevelopment Agency's Fiscal Year changes, it shall give notice of such change in the same manner as for a Listed Event under Section 5(c). (b) If the Dissemination Agent is other than the Redevelopment Agency, then not later than fifteen (15) Business Days prior to said date, the Redevelopment Agency shall provide the Annual Report to the Dissemination Agent. If the Dissemination Agent is unable to verify that an Annual Report has been provided to the Repositories by the date required 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 Exhibit A to this Disclosure Agreement. (c) The Dissemination Agent 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 required therefor by Section 3(a) and file any notice of a listed Event, if requested by the Redevelopment Agency, as soon as practicable following receipt from the Redevelopment Agency of such notice; and OM)42`cdc- I (iii) if the Dissemination Agent is other than the Redevelopment Agency, file a report with the Redevelopment Agency certifying that the Annual Report has been provided pursuant to this Disclosure Agreement, stating the date it was provided and listing all the Repositories to which it was provided. (d) Notwithstanding any other provision of this Disclosure Agreement, the City and the Dissemination Agent reserve the right to make any of the aforementioned filings through the Central Post Office. SECTION 4. Content of Annual Retorts. The Redevelopment Agency's Annual Report shall contain or incorporate by reference the following: (a) The audited financial statements of the Redevelopment Agency, presented in accordance with generally accepted accounting principles as promulgated to apply to governmental entities Commission from time to time. If the audited financial statements of the Redevelopment Agency are not available by the time the Annual Report is required to be filed as described above, the Annual Report shall contain unaudited financial statements in a format similar to the financial statements contained in the final Official Statement, and the audited financial statements shall be filed in the same manner as the Annual Report when they become available. (b) Unless otherwise provided in the audited financial statements filed on or prior to the annual filing deadline for Annual Reports provided in Section 3 above, financial information and operating data with respect to the Redevelopment Agency for the preceding Fiscal Year, substantially similar to that provided in the following tables and charts in the Official Statement: 0) Table 4-"Palm Desert Redevelopment Agency Project Area No. 1 - Combined - Principal Taxpayers;" (Table 4A-"Palm Desert Redevelopment Agency Project Area No. 1 - Original Area -Principal Taxpayers;" and Table 4B-"Palm Desert Redevelopment Agency Project Area No. 1 - Added Territory -Principal Taxpayers;"] and (ii) Table 6A-"Palm Desert Redevelopment Agency Project Area No. 1 - Original Area -Historical Taxable Values and Tax Increment Revenues;" and Table 6B-"Palm Desert Redevelopment Agency Project Area No. I - Added Territory -Historical Taxable Values and Tax Increment Revenues." (c) The outstanding principal amount of Bonds, for the preceding Fiscal Year. Such annual information and operating data described above may be included by specific reference to other documents, including official statements of debt issues of the Redevelopment Agency or related public entities, which have been submitted to each of the Repositories or the Securities and Exchange Commission; provided, that if the documents included by reference is a final official statement, it must be available from the Municipal Securities Rulemaking Board; and provided further, that the Redevelopment Agency shall clearly identify each such other document so included by reference. SECTION 5. RenortinR of Sienificant Events. (a) Pursuant to the provisions of this Section 5, the Redevelopment Agency 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 delinquencies. (ii) non-payment related defaults. ON"2 cdc-I Bonds. (iii) modifications to 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 (viii) unscheduled draws on the Reserve Fund reflecting financial difficulties. (ix) unscheduled draws on the credit enhancements reflecting financial difficulties. (x) substitution of the credit or liquidity providers or their failure to perform. (xi) release, substitution or sale of property securing repayment of the Bonds. (xii) Significant amendments to the land use regulations or entitlements of the City of Palm Desert within the Project Area which would adversely affect development of property therein. (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 Redevelopment Agency promptly notify the Dissemination Agent in writing whether or not to report the event pursuant to subsection (f) 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 of this Disclosure Agreement, "actual knowledge" of the occurrence of such Listed Events shall mean actual knowledge by the officer at the Trust Office of the Trustee with regular responsibility for the administration of the Indenture. (c) Whenever the Redevelopment Agency obtains knowledge of the occurrence of a Listed Event, whether because of a notice from the Trustee pursuant to Section 5(b) or otherwise, the Redevelopment Agency shall as soon as possible determine if such event would be material under applicable federal securities laws. (d) If the Redevelopment Agency determines that knowledge of the occurrence of a Listed Event would be material under applicable federal securities laws, the Redevelopment Agency shall promptly notify the Dissemination Agent and the Trustee in writing. Such notice shall instruct the Dissemination Agent to file 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 Holders of affected Bonds pursuant to the Indenture. (e) If in response to a request under subsection (b), the Redevelopment Agency determines that the Listed Event is not material, the Redevelopment Agency shall so notify 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 Reportinu Oblieation. The obligations of the Redevelopment Agency 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 Redevelopment Agency shall give notice of such termination in the same manner as for a Listed Event under Section 5(c). 06042 cdc 1 4 SECTION 7. Dissemination Agent. The Redevelopment Agency may, from time to time, appoint or engage a Dissemination Agent to assist it in carrying out its obligations under this Disclosure Agreement, and may discharge any such Dissemination Agent, with or without appointing a successor Dissemination Agent. The Dissemination Agent shall not be responsible in any manner for the content of any notice or report prepared by the Redevelopment Agency pursuant to this Disclosure Agreement. The initial Dissemination Agent shall be the MuniFinancial, Inc. The Dissemination Agent may resign its duties hereunder at any time upon written notice to the Redevelopment Agency. SECTION 8. Amendment. Notwithstanding any other provision of this Disclosure Agreement, the panties may amend this Disclosure Agreement (and the Trustee and the Dissemination Agent shall agree to any amendment so requested by the Redevelopment Agency provided that neither the Trustee nor the Dissemination Agent shall be obligated to enter into any such amendment that modifies or increases its duties or obligations hereunder) only if (a) the amendment is made in connection with a change in circumstances that arises from a change in legal requirements, change in law, or change in identity, nature, or status of the Redevelopment Agency, or type of business conducted; (b) this Disclosure Agreement, as amended, would have compiled with the requirements of the Rule at the 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 Owners, as determined by parties unaffiliated with the Redevelopment Agency (such as, but without limitation, the Redevelopment Agency's bond counsel) or by Owner's consent pursuant to Section 7.01 of the Indenture; and (d) the annual financial information containing (if applicable) the amended operating data or financial information will explain, in narrative form, the reasons for the amendment and the "impact" (as that word is used in the letter from the staff of the Securities and Exchange Commission to the National Association of Bond Lawyers dated June 23, 1995) of the change in the type of operating data or financial information being provided. SECTION 9. Additional Information. (a) The Redevelopment Agency agrees to provide public information concerning the Bonds and the Redevelopment Agency to any Holder or Beneficial Owner making a written request therefor. (b) Nothing in this Disclosure Agreement shall be deemed to prevent the Redevelopment Agency from disseminating any other information, using the means of dissemination set forth in this Disclosure Agreement or any other means 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 Disclosure Agreement. If the Redevelopment Agency chooses to include any information in any Annual Report or notice of occurrence of a Listed Event in addition to that which is specifically required by this Disclosure Agreement, the Redevelopment Agency shall have no obligation under this Disclosure Agreement to update such information or include it in any fixture Annual Report or notice of occurrence of a listed Event. ON)42 cdc-1 SECTION 10. Default. In the even to a failure of the Redevelopment Agency to comply with any provision of this 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 provided to it or it has been otherwise indemnified to its satisfaction from any cost, liability, expense or additional charges of the Trustee whatsoever, including, without limitation, fees and expenses of its attorneys), or any Owner may, take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the Redevelopment Agency, the Trustee or the Dissemination Agent, 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 specific performance may be sought or granted. A default under this Disclosure Agreement shall not be deemed an Event of Default under the Indenture or the Loan Agreement, and the sole remedy under this Disclosure Agreement in the event of a failure of the Redevelopment Agency, the Trustee or the Dissemination Agent to comply with this Disclosure Agreement shall be an action to compel performance. SECTION 11. Duties, Immunities and Liabilities of Dissemination AV-ent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Agreement, and the Redevelopment Agency agrees to indemnify and save the Dissemination Agent and the Trustee, their officers, directors, employees and agents, harmless against any loss, expense and liabilities which it may incur arising out of or in the exercise or performance of its powers and duties hereunder, including the costs and expenses (including attorneys fees) of defending against any claim of liability, but excluding liabilities due to the Dissemination Agent's or Trustee's negligence or willful misconduct. The Dissemination Agent may rely 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. The Dissemination Agent and the Trustee shall be paid compensation by the Redevelopment Agency 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 Redevelopment Agency hereunder and shall not be deemed to be acting in a fiduciary capacity for the Financing Authority, the Redevelopment Agency, the Owners, or any other parry. The obligations of the Redevelopment Agency 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. The Dissemination Agent shall not be liable under any circumstances for monetary damages to any person for any breach of this Disclosure Agreement. SECTION 12. Beneficiaries. This Disclosure Agreement shall inure solely to the benefit of the Redevelopment Agency, the Participating Underwriter, the Dissemination Agent and Holders and Beneficial Owners from 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 following information may be conclusively relied upon until changed in writing. Redevelopment Agency: Palm Desert Redevelopment Agency 73-510 Fred Waring Drive Palm Desert, California 92260 (760)346-0611 (760) 346-0574 Fax 06042�cdc-I Trustee: Wells Fargo Bank, National Association 700 South Flower Street, Suite 500 Los Angeles, California 90017A 104 (213) 630-6237 (213) 630-6215 Fax Dissemination Agency: MuniFinancial, Inc. 27368 Via Industrial, Suite 10 Temecula, California 92590 (909)587-3500 (909) 587-3510 Fax SECTION 14. Countervarts. 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 instrument. Date: .2007 PALM DESERT REDEVELOPMENT AGENCY OF 21 Authorized Officer WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee By: Authorized Officer MUNIFINANCIAL, INC., as Dissemination Agent : nrrN2 ak- 4 Authorized Officer EXHIBIT A NOTICE TO MUNICIPAL SECURITIES RULEMAKING BOARD OF FAILURE TO FILE ANNUAL REPORT Name of Obligated Party: Palm Desert Redevelopment Agency Name of Bond Issue: Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) 2007 Series A Date of Issuance: , 2007 NOTICE IS HEREBY GNEN that the Palm Desert Redevelopment Agency (the "Redevelopment Agency") has not provided an Annual Report with respect to the above -named Bonds as required by Section 3 of the Continuing Disclosure Agreement dated , 2007, by and among the Redevelopment Agency, the Trustee and the Dissemination Agent executed by the Dissemination Agent for the benefit of the Holders and Beneficial Owners of the above -referenced bonds. The Redevelopment Agency anticipates that the Annual Report will be filed by Dated: WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee, on behalf of the Redevelopment Agency By: Its: cc: Executive Director, Palm Desert Redevelopment Agency WAW2 AAc-I A-1 ESCROW AGREEMENT (PROJECT AREA NO. 1, AS AMENDED) by and among PALM DESERT FINANCING AUTHORITY and PALM DESERT REDEVELOPMENT AGENCY and WELLS FARGO BANK, NATIONAL ASSOCIATION as Escrow Agent Dated as of January 1, 2007 Relating to the Refunding of the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) Series 1997 (scheduled to mature on April 1, 2008 through April 1, 2018) P6402-1058\924118v4.doc RWG DRAFT: 11/2/2006 TABLE OF CONTENTS Page Section1. Definitions............................................................................................................... 2 Section 2. Appointment of Escrow Agent............................................................................... 2 Section3. Escrow Fund........................................................................................................... 2 Section 4. Deposit to Escrow Fund.......................................................................................... 3 Section 5. Investment of Escrow Fund.................................................................................... 3 Section 6. Reinvestment; Payment of Refunding Requirements ............................................. 4 Section7. Verification............................................................................................................. 4 Section 8. Compliance with Agreement and Prior Indenture .................................................. 4 Section9. Notices.................................................................................................................... 4 Section 10. Defeasance of Prior Bonds...................................................................................... 5 Section11. Nature of Lien......................................................................................................... 5 Section12. Amendments........................................................................................................... 5 Section 13. Compensation of Escrow Agent............................................................................. 5 Section 14. Resignation or Removal of Escrow Agent; Appointment of Successor ................. 6 Section 15. Limitation of Powers and Duties............................................................................ 7 Section 16. Indemnification....................................................................................................... 7 Section 17. Limitation of Liability............................................................................................. 8 Section18. Termination............................................................................................................. 8 Section19. Governing Law....................................................................................................... 8 Section20. Severability............................................................................................................. 9 Section 21. Counterparts............................................................................................................ 9 SCHEDULE A REFUNDING REQUIREMENTS SCHEDULE B ESCROW SECURITIES EXHIBIT A FORM OF DEFEASANCE NOTICE P6402-1058\9241 18v4.doc -1- ESCROW AGREEMENT (Project Area No. 1, As Amended) This Escrow Agreement (Project Area No. 1, As Amended) (this "Agreement') is made and entered into as of January 1, 2007, by and among the Palm Desert Financing Authority, a joint powers authority duly organized and existing pursuant to the laws of the State of California (the "Authority"), the Palm Desert Redevelopment Agency, a public body corporate and politic organized and existing pursuant to the laws of the State of California (the "Agency"), and Wells Fargo Bank, National Association, a national banking association duly organized and existing under the laws of the United States of America, as Escrow Agent (together with any successors and assigns, the "Escrow Agent'). RECITALS A. The Authority has previously issued its Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), Series 1997 (the "Series 1997 Bonds"), pursuant to the Indenture of Trust, dated as of July 1, 1997 (the "Prior Indenture"), by and between the Authority and Bank of America National Trust and Savings Association, as succeeded by Wells Fargo Bank, National Association, as trustee (the "Prior Bonds Trustee"). B. Pursuant to the Prior Indenture, the Series 1997 Bonds maturing on April 1, 2008 and thereafter through April 1, 2018 (the "Prior Bonds") are subject to redemption on any interest payment date on or after April 1, 2007. C. The Series 1997 Bonds are secured by revenues consisting of amounts payable to the Authority by the Agency with respect to a loan (the "Prior Loan") pursuant to the Loan Agreement (Project Area No. 1, As Amended), dated as of July 1, 1997 (the "Prior Loan Agreement'), by and among the Agency, the Authority and the Prior Bonds Trustee. D. The Agency and the Authority have determined to redeem the Prior Bonds pursuant to the Prior Indenture and effect a refunding thereof. E. The Authority has determined to issue its Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) 2007 Series A (the "Series 2007 Bonds"), pursuant to the Indenture of Trust, dated as of even date herewith, by and between the Authority and Wells Fargo Bank, National Association, as trustee (together with any successors and assigns, the "2007 Trustee"). F. Proceeds of the Series 2007 Bonds will be used to make a loan (the "Series 2007 Loan") to the Agency pursuant to the Loan Agreement, dated as of event date herewith (the "2007 Loan Agreement'), by and among the Agency, the Authority and the 2007 Trustee. G. Pursuant to the 2007 Loan Agreement, proceeds derived from the Series 2007 Loan 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. P6402-1058\924118v4.doc -1- H. In accordance with the Prior Indenture, if the Authority will pay or cause to be paid, or will have made provisions to pay, or there will have been set aside in trust funds to pay, to the holders of any portion of the Series 1997 Bonds, the principal and interest and premium, if any, to become due thereon, then with respect to such portion of the Series 1997 Bonds the lien of the Prior Indenture will thereupon cease, terminate and become void and be discharged and satisfied. 1. In order to provide for the proper and timely application of the moneys deposited in said escrow to the payment of the Prior Bonds, it is necessary to enter into this Agreement. NOW, THEREFORE, in consideration of the foregoing and of the mutual covenants hereinafter set forth, the parties hereto agree as follows: Section 1. Definitions. Unless the context clearly requires otherwise, capitalized terms 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 terms shall have the following meanings: "Escrow Fund" means the Escrow Fund established and held by the Escrow Agent pursuant to Section 3. "Escrow Securities" means 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 mature or be withdrawable, as the case may be, not later than the time when needed for the payment or redemption of the Prior Bonds in order to discharge the pledge and lien securing the Prior Bonds. "Refunding Requirements" means an amount sufficient to pay all installments of principal and interest of the Prior Bonds on their earliest available optional redemption date, as set forth in Schedule A attached hereto. Section 2. Appointment of Escrow Ap-ent. The Authority and the Agency hereby appoint Wells Fargo Bank, National Association, as Escrow Agent under this Agreement for the benefit of the holders of the Prior Bonds. The Escrow Agent hereby accepts the 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 Indenture, including particularly redemption provisions set forth in Article II thereof, are incorporated herein by reference. Reference herein to, or citation herein of, any provisions of the Prior Indenture shall be deemed to incorporate the same as a part hereof in the same manner and with the same effect as if the same were fully set forth herein. 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 P6402-1058\924118v4.doc -2- Fund") to be held by the Escrow Agent separate and apart from all other funds of the Agency, the Authority or the Escrow Agent and used only for the purposes and in the manner provided in this Agreement. Section 4. Deposit to Escrow Fund. Upon the issuance of the Series 2007 Bonds, the Authority and the Agency shall cause to be deposited with the Escrow Agent in the Escrow Fund, the following: (a) $ , representing a portion of the sale proceeds of the Series 2007 Bonds; and (b) $ from other available funds of the Agency. Moneys on deposit in the Escrow Fund shall be held in irrevocable trust by the Escrow Agent and applied solely as provided in this Agreement. Section 5. Investment of Escrow Fund. The Escrow Agent, upon receipt of the moneys described in Section 4, shall immediately invest $ of such moneys in the Escrow Securities, to deposit such Escrow Securities in the Escrow Fund and to deposit the remaining $ in the Escrow Fund to be held uninvested. The Escrow Agent is hereby authorized and empowered to deposit uninvested monies held hereunder from time to time in demand deposit accounts, without payment for interest thereon as provided hereunder, established at commercial banks that are corporate affiliates of the Escrow Agent. Notwithstanding the foregoing or any other provision of this Agreement to the contrary, at the written request of the Agency and upon compliance with the conditions hereinafter set forth, the Escrow Agent shall have the power to sell, transfer, request the redemption of or otherwise dispose of some 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 dates on which the anticipated transfers from the Escrow Fund to the Prior Bonds Trustee for the payment of the principal of, or interest on the Prior Bonds will not be diminished 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 Agency 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, immediately after such transaction, the principal of and interest on the Investment 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 Indenture and this Agreement, at any time for the payment when due as provided in Section 6, shall be transferred to the Agency. P6402-1058\924118A.doc -3- Section 6. Reinvestment; Pavment of Refunding- Requirements. As the 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 accordance with the written instructions of the Agency. On the redemption date of the Prior Bonds as set forth Schedule A (i.e., April 1, 2007), the Escrow Agent shall transfer an amount sufficient to pay the Refunding Requirements from the Escrow Fund to the Prior Bonds Trustee. Such amounts shall be applied by the Prior Bonds Trustee to the payment of the Refunding Requirements for the equal and ratable benefit of the holders of the Prior Bonds. Section 7. Verification. The Agency has caused schedules to be prepared relating to the sufficiency of the anticipated receipts from the Escrow Securities to pay the Refunding Requirements. The Agency shall furnish the Escrow Agent with the report of Grant Thornton LLP, verifying the mathematical accuracy of the computations contained in such schedules. Section 8. Compliance with Agreement and Prior Indenture. The Authority and the Agency 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 moneys for the payment of principal and interest with respect to the Prior Bonds, in order to effectuate this Agreement. The liability of the Escrow Agent for the payment of the Refunding Requirements, pursuant to this Section and, in its capacity as Prior Bonds Trustee, the Prior Indenture, shall be limited to the application, in accordance with this Agreement, of moneys and the Escrow Securities in the Escrow Fund (including interest earnings thereon, if any) available for the purposes of and in accordance with this Agreement. Section 9. Tax Covenants. Notwithstanding any other provision of this Agreement, the Agency and the Authority hereby covenant that no part of the proceeds of the Series 2007 Bonds or of the moneys or funds held by the Escrow Agent hereunder shall be used, and that it 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 2007 Bonds to be an "arbitrage bond" under Section 148 of the Code 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 2007 Bonds. None of the Authority, the Agency nor the Escrow Agent shall, except as set 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 the provisions of Section 15 relating to the transfer of rights and property to successor escrow agents. Section 10. Notices. The Authority hereby instructs the Escrow Agent, in its capacity as the Prior Bonds Trustee, to mail to the registered owners of the Prior Bonds, as soon as practicable upon receipt of the deposit of moneys in the Escrow Fund pursuant to Section 4, a notice substantially in the form set forth in Exhibit A attached hereto. The Authority 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 before the redemption date set forth in Schedule A, to the registered owners of the Prior Bonds, the Securities Depositories and to one or more Information Services (as defined in the Prior Indenture) in the form and manner P6402-1058\924118v4.doc -4- prescribed by Section 2.03(e) of the Prior Indenture. The Escrow Agent shall provide copies of the notices described in this Section 9 to MBIA Insurance Corporation, the insurer of Prior Bonds. Section 11. Defeasance of Prior Bonds. The Agency and the Authority represent and agree that, concurrently with the initial deposit of the Escrow Securities pursuant to Section 5, (i) the Prior Bonds will no longer be deemed to be outstanding and unpaid within the meaning and with the effect expressed in the Prior Indenture, and (ii) all principal installments of the Prior Loan scheduled to be due on or after April 1, 2008 will be deemed paid and will no longer be deemed to be outstanding within the meaning and with the effect expressed in the Prior Loan Agreement. Section 12. Nature of Lien. The trust hereby created shall be irrevocable and the holders of the Prior Bonds shall have an express lien on all moneys and Escrow Securities in the Escrow Fund, including the interest earnings thereon, until paid out, used and applied in accordance with this Agreement. Section 13. Amendments. This Agreement is made pursuant to and in furtherance of the Prior Indenture and for the benefit of the Agency, the Authority and the holders from time to time of the Prior Bonds and it shall not be repealed, revoked, altered, amended or supplemented without the written consent of all such holders and the written consent of the Escrow Agent, the Authority and the Agency; provided, however, that the Agency, the Authority 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 terms and provisions of this Agreement, for any one or more of the following purposes: (a) To cure any ambiguity or formal 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, remedies, powers or authority that may lawfully be granted to, or conferred upon, such holders or the Escrow Agent; (c) To transfer to the Escrow Agent and make subject to this Agreement additional funds, securities or properties; and (d) To make any other change determined by the Authority and the Agency to be not materially adverse to the holders of the Prior Bonds. The Escrow Agent shall be entitled to rely exclusively upon an opinion of counsel with respect to compliance with this Section, including the extent, if any, to which any change, modification or addition affects the rights of the holders of the Prior Bonds, or that any instrument executed hereunder complies with the conditions and provisions of this Section. Section 14. Compensation of Escrow Agent. In consideration of the services rendered by the Escrow Agent under this Agreement, the Agency 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 Agency, including all reasonable expenses, charges, counsel fees and P6402-1058\924118v4.doc -5- other disbursements incurred by it or by its attorneys, agents and employees in and about the performance of their powers and duties hereunder, from any moneys of the Agency lawfully available therefor and the Escrow Agent shall have no lien whatsoever upon any of the moneys or Escrow Securities in the Escrow Fund for the payment of such proper fees and expenses. Section 15. Resignation or Removal of Escrow Aizent, 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 Agency, 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 effect unless a successor Escrow Agent shall have been appointed by the holders of the Prior Bonds or by the Agency as hereinafter 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 Agency and the Authority and signed by the registered holders of a majority in principal amount of each series of the Prior Bonds. The Escrow Agent may also be removed at any time by the Agency with not less than 30 days' written notice to the Escrow Agent, the Authority, the Prior Bonds Trustee (if different from the Escrow Agent) and the registered holders of the Prior Bonds. In the event the 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 concurrent instruments in writing, signed by such holders, or by their attorneys in fact, duly authorized in writing; provided, nevertheless, that in any such event, the Agency shall appoint a temporary Escrow Agent to fill such vacancy until a successor Escrow Agent shall be appointed by the holders of a majority in principal amount of each series of the Prior Bonds, and any such temporary Escrow Agent so appointed by the Agency shall immediately and without further act be superseded by the Escrow Agent so appointed by such holders. The Agency shall give written notice of any such appointment made by it to the Authority 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 Agency 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 Agency, the holder of any of the Prior Bonds or any retiring Escrow Agent may apply to any court of competent jurisdiction for the appointment of a successor Escrow Agent, and such court may thereupon, after such notice, if any, as it shall deem proper, appoint a successor Escrow Agent. No successor Escrow Agent shall be appointed unless such successor Escrow Agent shall be a corporation with trust powers organized under the banking laws of the United States or any state, and shall have at the time of appointment capital and surplus of not less than $75,000,000. P6402-1058\9241 M4.doc -6- Every successor Escrow Agent appointed hereunder shall execute, acknowledge and deliver to its predecessor and to the Agency, 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 Agency execute and deliver an instrument transferring to such successor Escrow 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 successor. Should any transfer, assignment or instrument in writing from the Agency 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 request, be executed, acknowledged and delivered by the Agency. Any entity into which the Escrow Agent, or any successor to it in the trusts created by this Agreement, may be merged or converted or with which it or any successor to it may be consolidated, or any entity resulting from any merger, 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 Agency, be the successor Escrow Agent under this Agreement without the execution or filing of any paper or any other act on the part of any of the parties hereto, 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 the moneys held hereunder except as provided in this Agreement. Section 17. Indemnification. To the extent permitted by law, the Agency hereby assumes liability for, and hereby agrees (whether or not any of the transactions contemplated hereby are consummated) to indemnify, 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, penalties, 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 (whether or not also indemnified against the same by the Agency or any other person under any other agreement or instrument, but without double indemnity) in any way relating to or arising out of the execution, delivery and performance of this Agreement, the establishment hereunder of the Escrow Fund, the acceptance of the funds and securities deposited therein, the purchase of any securities to be purchased pursuant thereto, the retention of such securities or the proceeds thereof and any payment, transfer or other application of moneys or securities by the Escrow Agent in accordance with the provisions of this Agreement; provided, however, that the Agency shall not be required to indemnify the Escrow Agent against the Escrow Agent'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 Agency or the Escrow Agent be liable to any person by reason of the transactions contemplated hereby other than as set forth in this Section. P6402-1058\9241 M4.doc -7- 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, agents 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 moneys or any securities deposited 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 held hereunder to accomplish the payment and redemption 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 Agreement or by reason of any non -negligent act, non -negligent omission or non -negligent error of the Escrow Agent made 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 Agency 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 payment and redemption of the Prior Bonds pursuant to the Prior Indenture or to the validity of this Agreement as to the Agency or the Authority and, except 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 Agency, 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 firm of independent certified public accountants or an opinion of nationally recognized bond counsel) may be deemed to be conclusively established by a written certification of the Agency or the Authority, as applicable. Whenever the Escrow Agent shall deem it necessary or desirable that a matter specifically requiring a certificate of a nationally recognized firm of independent certified 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 financial liability in the performance or exercise of any of its duties in accordance with this Agreement, or in the exercise of its rights or powers. Section 19. Termination. This Agreement shall terminate when moneys have been transferred pursuant to Section 6 to the Prior Bonds Trustee sufficient to pay all Prior Bonds. Upon such termination, all moneys remaining in the Escrow Fund after payment of any amounts due the Escrow Agent hereunder shall be released to the Agency. Section 20. Governing Law. This Agreement shall be governed by the law of the State of California. P6402-1058\9241 18v4.doc -8- Section 21. Severability. If any one or more of the covenants or agreements provided in this Agreement on the part of the Agency, the Authority or the Escrow Agent to be performed should be determined 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 agreements herein contained and shall in no way affect the validity of the remaining provisions of this Agreement. All the covenants, promises and agreements in this Agreement contained by or on behalf of the Agency, the Authority or the Escrow Agent shall bind and inure to the benefit of their respective successors and assigns, whether so expressed or not. Section 22. Counterparts. This Agreement may be executed in several 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. [Remainder of Page Intentionally Left Blank] P6402-1058\9241 18v4.doc -9- (Escrow Agreement) IN WITNESS WHEREOF, the parties hereto have each caused this Agreement to be executed by their duly authorized officers and appointed or elected officials as of the date first written above. PALM DESERT FINANCING AUTHORITY Chief Administrative Officer PALM DESERT REDEVELOPMENT AGENCY Executive Director WELLS FARGO BANK, NATIONAL ASSOCIATION, as Escrow Agent Authorized Officer P6402-1059\9241 I Rv4.doc -10- SCHEDULE A REFUNDING REQUIREMENTS Redemption Redemption Date Principal Interest Premium April 1, 2007 $31,855,000 $842,192.50 $637,100 * Consists of the following Prior Bonds to be optionally redeemed on April 1, 2007: Maturity Date Interest Redemption (April 1) Principal Rate Price 2008 $ 2,290,000 4.90% 102% 2009 2,255,000 5.00 102 2010 2,505,000 5.10 102 2011 2,495,000 5.15 102 2012 2,755.000 5.20 102 2014 5,830,000 5.35 102 2018 13,725,000 5.45 102 Escrow Requirement $33,334,292.50 P6402-1058,,924118v4.doc Schedule A-1 SCHEDULE B ESCROW SECURITIES Type of Maturity Par Security Date Amount Rate Price , 2007 $ % $ P6402-1058\9241 i8v4.doc Schedule B-1 Accrued Interest Cost EXHIBIT A [FORM OF DEFEASANCE NOTICE] PALM DESERT FINANCING AUTHORITY Notice to the Holders of Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) Series 1997 scheduled to mature on April 1, 2008 and thereafter through April 1, 2018 CUSIP No. NOTICE IS HEREBY GIVEN on behalf of the Palm Desert Financing Authority (the "Authority"), that pursuant to Section 10.03 of the Indenture of Trust, dated as of June 1, 1997 (the "Indenture"), pertaining to the above -captioned Bonds with the maturity dates of April 1, 2008 and thereafter through April 1, 2018, the lien of such Indenture has been discharged through the irrevocable deposit in escrow of cash and Federal Securities. DATED this day of , 2007 WELLS FARGO BANK, NATIONAL ASSOCIATION, as Escrow Agent P6402-1058,924118%4.doc Exhibit A Indenture of Trust with reference to $ Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) 2007 Series A P6402-1058�92276Sv4.doc RWG DRAF'I': I 1/I/200G TABLE OF CONTENTS ARTICLE I DEFINITIONS; AUTHORIZATION AND PURPOSE OF BONDS; EQUALSECURITY .......................................................................................... Section1.1. Definitions ..................................................................................................... Section 1.2. Rules of Construction .................................................................................... Section 1.3. Authorization and Purpose of Bonds . ........................................................... Section1.4. Equal Security . .............................................................................................. ARTICLEII ISSUANCE OF BONDS .................................................................................... Section2.1. Designation . .................................................................................................. Section2.2. Terms of Bonds ............................................................................................. Section 2.3. Redemption of Bonds .................................................................................... Section2.4. Form of Bonds ............................................................................................... Section2.5. Execution of Bonds ....................................................................................... Section2.6. Transfer of Bonds .......................................................................................... Section 2.7. Exchange of Bonds ........................................................................................ Section 2.8. Temporary Bonds .......................................................................................... Section 2.9. Registration Books ........................................................................................ Section 2.10. Bonds Mutilated, Lost, Destroyed or Stolen ............................................... ARTICLE III llEPOSIT AND APPLICATION OF PROCEEDS OF BONDS; Pa�e ..........2 ..........2 ..........9 ..........9 ..........9 ........10 ........10 ........10 ........11 ........13 ........13 ........13 ........13 ........14 ........14 ........14 ISSUANCE OF BONDS ............................................................................................ I S Section 3.1. Issuance of Bonds ..................................................................................................15 Section 3.2. Loan Funds; Application of Proceeds of Sale of Bonds ........................................15 Section 3.3. Validity of Bonds ..................................................................................................15 ARTICLE IV REVENUES; FLOW OF FUNDS ..............................................................................15 Section 4.1. Pledge of Revenues; Assignment of Rights . .........................................................15 Section 4.2. Receipt, Deposit and Application of Revenues .....................................................16 Section 4.3. Investments . ..........................................................................................................17 Section 4.4. Valuation and Disposition of Investments . ...........................................................18 ARTICLE V COVENANTS OF THE AUTHORITY .....................................................................18 Section 5.1. Punctual Payment ..................................................................................................18 Section 5.2. Extension of Payment of Bonds ............................................................................18 Section 5.3. Against Encumbrances ..........................................................................................18 Section 5.4. Power to lssue Bonds and Make Pledge and Assignment .....................................18 Section 5.5. Accounting Records and Financial Statements .....................................................19 Section 5.6. No Additional Indebtedness ..................................................................................19 Section 5.7. Tax Covenants Regarding Bonds ..........................................................................19 Section 5.8. Loan Agreement ....................................................................................................20 Section 5.9. Further Assurances ................................................................................................21 ARTICLE VI THE TRUSTEE ..........................................................................................................21 Section 6.1. Appointment of Trustee . .......................................................................................21 Section 6.2. Acceptance of Trusts .............................................................................................22 Section 6.3. Fees, Charges and Expenses of Trustee . ...............................................................25 Section 6.4. Notice to Owners of Default . ................................................................................25 Section 6.5. Intervention by Trustee . ........................................................................................25 Section 6.G. Removal of Trustee . ..............................................................................................25 Section 6.7. Resignation by Trustee ..........................................................................................25 Section 6.8. Appointment of Successor Trustee . ......................................................................2G Section G.9. Merger or Consolidation . ......................................................................................2G P6�102-1 OS 8\922765 v4. dor 1 Section 6.10. Concerning any Successor Trustee . ....................................................................26 Section 6.11. Appointment of Co-Trustee . ...............................................................................26 Section 6.12. Indemnification; Limited Liability of Truslee . ...................................................27 ARTICLE VII MODIFICATION AND AMENDMENT OF THE INDENTURE ............................28 Section7.1. Amendment Hereof ...............................................................................................28 Section 7.2. Effect of Supplemental Indenture ..........................................................................28 Section 7.3. Endorsement or Replacement of Bonds After Amendment . .................................29 ARTICLE VIII EVENTS OF DEFAULT AND REMEDIES .............................................................29 Section 8.1. Events of Default ...................................................................................................29 Section 8.2. Remedies Upon Event of Default ..........................................................................30 Section 8.3. Application of Revenues and �ther Funds After Default . ....................................31 Section 8.4. Power of Trustee to Control Proceedings ..............................................................31 Section 8.5. Appointment of Receivers .....................................................................................32 Seclion8.6. Non-Waiver ...........................................................................................................32 Section 8.7. Limitation on Rights and Remedies of Owners . ...................................................32 Section 8.8. Termination of Proceedings . .................................................................................33 ARTICLEIX BOND II�ISURANCE .................................................................................................33 Section 9.1. Payments Under the Insurance Policy; Certain Rights of the lnsurer . ..................33 Section9.2. Notices ...................................................................................................................35 Section 9.3. Control of Remedies upon Default ........................................................................35 Section 9.4. Suspension or Termination of Rights of Insurer . ..................................................35 ARTICLE X BOOK-ENTRY SYSTEM ..........................................................................................36 Section 10.1. Book-Entry System; Limited Obligation of Authority . ......................................3G Section 10.2. Representation Letter ..........................................................................................37 Section 10.3. Transfers Outside Book-Entry System ................................................................37 Section 10.4. Payments to the Nominee ....................................................................................37 Section 10.5. Initial Depository and Nominee ..........................................................................37 ARTICLEXI MISCELLANEOUS ...................................................................................................37 Section 11.1. Limited Liability of Authority . ...........................................................................37 Section 11.2. Benefits of Indenture Limited to Parties . ............................................................38 Section 11.3. Discharge of Indenture ........................................................................................38 Section 11.4. Successor Deemed Included in All References to Predecessor . .........................39 Seclion I 1.5. Content of Certificates . .......................................................................................39 Section 11.6. Execution of Documents by Owners ...................................................................39 Section 11.7. Disqualified Bonds ..............................................................................................40 Section 11.8. Waiver of Personal Liability . ..............................................................................40 Section 11.9. Partiaf Invaiidity ..................................................................................................40 Section 11.10. Destruction of Cancelled Bonds . ......................................................................40 Section 1 I. I 1. Funds and Accounts ..........................................................................................41 Section 11.12. Payment on Business Days . ..............................................................................41 Section11.13. Notices ..............................................................................................................41 Section 11.14. Unclaimed Moneys ...........................................................................................42 Section 11.15. Governing Law . ................................................................................................42 EXHIBIT A— FORM OF BOND PG402-1 OS 8\922765 v4. doc 11 Indenture of Trust This Indenture of Trust (this "Indenture") is made and entered into as of January 1, 2007, by and between the Palm Desert Financing Authority, a joint powers authority duly organized and validly existing under the laws of the State of California (the "Authority") and Wells Fargo Bank, National Association, a national banking association duly organized and validly existing under the laws of the United States of America, having a corporate trust office in Los Angeles, California, and being qualified to accept and administer the trusts hereby created (the "Trustee"). Recitals: A. The Palm Desert Redevelopment Agency (the "Agency") is a redevelopment agency, a public body, corporate and politic, duly created, established and authorized to transact business and exercise its powers, all under and pursuant to the Redevelopment Law (defined below), and the powers of the Agency include the power to borrow money for any of its corporate purposes. B. A Redevelopment Plan, as amended, for the Project Area No. 1, As Amended, of the Agency has been duly approved and adopted by the City. C. The Authority is authorized to borrow money for the purpose of making loans to the Agency to provide financing and refinancing for public capital improvements of the Agency. D. For the purpose of aiding in the financing and refinancing for Project Area No. 1, As Amended, of the Agency, the Authority has determined to make a loan (the "Series 2007A Loan") to the Agency under and pursuant to the Project Area No. 1, As Amended, Loan Agreement, dated as of January 1, 2007 (the "Loan Agreement"), by and among the Authority, the Agency and the Trustee. E. To provide the moneys required to make the Series 2007A Loan under the Loan Agreement, the Authority has determined to issue its Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A, in the aggregate principal amount of $ (the "Bonds") pursuant to and secured by this Indenture in the manner provided herein. F. To provide for the authentication and delivery of the Bonds, to establish and declare the terms and conditions upon which the Bonds are to be issued and to secure the payment of the principal thereof, premium, if any, and interest thereon, the Auihority has authorized the execution and delivery of this Indenture. NOW, THEREFORE, THIS INDENTURE WITNESSETH, that in order to secure the payment of the principal of, premium, if any, and interest on the Bonds at any time issued and Outstanding under this Indenture, according to their tenor, and to secure the performance and observance of all the covenants and conditions therein and herein set forth, and to declare the terms and conditions upon and subject to which the Bonds are to be issued and received, and in consideration of the premises and of the mutual covenants herein contained and PG402-1058�92276Sv4.doc 1 of the purchase and acceptance of the Bonds by the Owners thereof, and for other valuable considerations, the receipt whereof is hereby acknowledged, the Authority hereby covenants and agrees with the Trustee, for the benefit of the Owners of ihe Bonds, as follows: ARTICLE I DEFINITIONS; AUTHORIZATION AND PURPOSE OF BONDS; EQUAL SECURITY Scction 1.1. Definitions. The following terms shall for all purposes of this Indenture and of any Supplemental Indenture and of any certificate, opinion, request or other documents herein mentioned have the meanings ascribed thereby. In addition, the terms defined in Section 1.1 of the Loan Agreement and not otherwise defined in this Section 1.1 shall have the meanings ascribed thereby in the Loan Agreement. "Act" means Articles 1 through 4(commencing with Section 6500) of Chapter 5, Division 7, Title 1 of the Government Code of the State, as in existence on the Closing Date or as thereafter amended from time to time. "A�ency" means the Palm Desert Redevelopment Agency, a redevelopment agency, a public body corporate and politic, duly created, established and authorized to transact business and exercise its powers all under and pursuant to the Redevelopment Law, and any successor to its duties and functions. "Authority" means the Palm Desert Financing Authority, a joint powers authority duly organized and existing under the Joint Exercise of Powers Agreement, dated January 26, 1989, by and between the City and the Agency, and under the laws of the State. "Authoritv Commission" means the governing body of the Authority. "Bond Counsel" means Richards, Watson & Gershon, A Professional Corporation, Los Angeles, California, or a firm of attorneys of favorable reputation in the field of municipal bond law. "Bond Law" means the Marks-Roos Local Bond Pooling Act of 1985, being Article 4 of the Act (commencing with Section 6584), as in existence on the Closing Date or as thereafter amended from time to time. "Bond Year" means each twelve-month period extending from April 2 in one calendar year to April 1 of the succeeding calendar year, both dates inclusive, except that the first Bond Year shall begin on the Closing Date and extend to and include April 1, 2007. "Bonds" means the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A. P(r102-1058�922765v4. doc 2 "Business Dav" means any day other than (i) a Saturday or a Sunday or (ii) any other day on which the New York Stock Exchange or banks are authorized or obligated by law or executive order to close in New York, New York, San Francisco, California, Los Angeles, California or any city in which the Trust Office is located. "Certificate" means a certificate in writing signed by any officer of the designated public entity, duly authorized by its legislative body for that purpose. "Citv" means the City of Palm Desert, a charter city and municipal corporation duly organized and validly existing under the laws of the State. "Closin� Date" means the date of delivery of the Bonds to the Underwriter as the original purchaser. "Code" means the Internal Revenue Code of 1986, as amended. "Countv" means the County of Riverside. "Defeasance Obli�ations" means any of the following: 1. Cash 2. U.S. Treasury Certificates, Notes and Bonds (including State and Local Government Series — "SLGS"); 3. Direct obligations of the Treasury which have been stripped by the Treasury itself, CATS, TIGRS and similar securities; 4. Resolution Funding Corp. (REFCORP), only the interest component of RECORP strips which have been stripped by request to the Federal Reserve Bank of New York in book entry form are acceptable; and 5. Pre-refunded municipal bonds rated "Aaa" by Moody's and "AAA" by S&P; provided, however, if the issue is only rated by S&P (i.e., there is no Moody's rating), then the pre-refunded bonds must have been pre-refunded with cash, direct U.S. or U.S. guaranteed obligations, or "AAA" rated pre-refunded municipals to satisfy this condition. "Depositorv" means The Depository Trust Company, New York, New York, and its successors and assigns as securities depository for the Bonds, or any other securities depository acting as Depository under Article X. "Event of Default" means any of the events described in Section 8.1. "Fiscal Year" means any twelve-month period extending from January 1 in one calendar year to June 30 of the succeeding calendar year, both dates inclusive, or any other twelve-month period selected and designated by the Authority as its official fiscal year period. P6402-1058\92276iv4.doc 3 "Indenture" means this Indenture of Trust, as may from time to time be supplemented, modified or amended by any Supplemental Indenture pursuant to the provisions hereof. "Independent Accountant" means any certified public accountant or firm of certified public accountants appointed and paid by the Authority, and who, or each of whom (i) is in fact independent and not under domination of the Authority, the City or the Agency; (ii) does not have any substantial interest, direct or indirect, in the Authority, the City or the Agency; and (iii) is not connected with the Authority, the City or the Agency as an officer or employee of the Authority, the City or the Agency but whom may be regularly retained to make annual or other audiis of the books of or reports to the Authority, the City or the Agency. "Information Services" means Financial Information, Inc.'s "Daily Called Bond Service," 30 Montgomery Street, lOth Floor, Jersey City, New Jersey 07302, Attention: Editor; Mergent's "Municipal and Government," 5254 77 Center Drive, Suite 150, Charlotte, North Carolina 28217, Attention: Called Bond Department; and Xcitek, 5 Hanover Square, New York, New York 10004; or, in accordance with then-current guidelines of the Securities and Exchange Commission, such other addresses and/or such other services providing information with respect to called bonds as the Agency may designate to [he Trustee in writing. "Insurance PavinQ A�ent" means U.S. Bank National Association or its successors under the Insurance Policy. "Insurance Policv" means, collectively, the municipal bond insurance policies issued by the Insurer insuring the payment when due of the principal of and interest on the Bonds. "Insurer" means MBIA Insurance Corporation, and its successors and assigns. "Interest Account" means the account by that name established and held by the Trustee pursuant to Section 4.2(b)(1). "Interest Pavment Date" means April 1 and October 1 of each year, commencing on October 1, 2007. "L.oan A�reement" means the Project Area No. 1, As Amended, Loan Agreement, dated as of January 1, 2007, by and among the Authority, the Agency and the Trustee relating to the Series 2007A Loan, as may from time to time be supplemented, modified or amended. "Moodv's" means Moody's Investors Service, its successors and assigns. "Nominee" means the nominee of the Depository, which may be the Depository, as determined from time to time pursuant to Article X. "Outstanding," when used as of any particular time with reference to Bonds, means (subject to the provisions of Section 11.7) all Bonds theretofore executed, issued and delivered by the Authority under this Indenture except (i) Bonds theretofore cancelled by the Trustee or surrendered to the Trustee for cancellation, (ii) Bonds paid or deemed to have been P6402-1058\922765v4.doc 4 paid within the meaning of Section 11.3, and (iii) Bonds in lieu of or in substitution for which other Bonds shall have been executed, issued and delivered pursuant to this Indenture. "�wner" means the person in whose name the ownership of any Bond or Bonds shall be registered on the Registration Books. "Participants" means those broker-dealers, banks and other financial institutions from time to time for which the Depository holds Bonds as securities depository. "Permitted Investments" means any of the following which at the time of investment are legal investments under the laws of the State for the moneys proposed to be invested therein: A. Direct obligations of the United States of America (including obligations issued or held in book-entry form on the books of the Department of the Treasury, and CATS and TIGRS) or obligations the principal of and interest on which are unconditionally guaranteed by the United States of America. For purposes of this paragraph A, "obligations the principal of and interest on which are unconditionally guaranteed by the United States of America" include without limitation tax exempt obligations of a state or a political subdivision thereof which have been defeased under irrevocable escrow instructions with non-callable obligations for which the full faith and credit of the United States of America are pledged for the payment of principal and interest and which are rated "Aaa" by Moody's and "AAA" by S&P. B. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by any of the following federal agencies, provided such obligations are backed by the full faith and credit of the United States of America (provided that stripped securities are only permitted if they have been stripped by the agency itself�: 1. U.S. Export-Import Bank (Eximbank) Direct obligations or fully guaranteed certificates of beneficial ownership 2. Farmers Home Administration (FmHA) Certificates of beneficial ownership 3. Federal Financin� Bank 4. Federal Housin� Administration Debentures (FHA) 5. General Services Administration Participation certificates 6. Government National MortQa�e Association (GNMA or "Ginnie Mae") GNMA - guaranteed mortgage-backed bonds GNMA - guaranteed pass-through obligations 7. U.S. Maritime Administration PG402- l OS8\9227GSv4.doc S Guaranteed Title XI financing 8. U.S. Department of Housin� and Urban Development (HUD} Project Notes Local Authority Bonds New Communities Debentures - U.S. government guaranteed debentures U.S. Public Housing Notes and Bonds - U.S. government guaranteed public housing notes and bonds C. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by any of the following non-full faith and credit U.S. govemment agencies (provided that stripped securities are only permitted if they have been stripped by the agency itsel�: Federal Home Loan Bank Svstem Senior debt obligations 2. Federal Home Loan Mort�a�e Comoration (FHLMC or "Freddie Mac") Participation Certificates Senior debt obligations 3. Federal National MortQa�e Association (FNMA or "Fannie Mae") Mortgage-backed securities and senior debt obligations 4. Resolution FundinQ Corp. (REFCORP) obligations D. Money market funds, including funds for which the Trustee or its affiliates provide investment advisory or other management services, registered under the Investment Company Act of 1940, whose shares are registered under the Securities Act of 1933, and having a rating by S&P of AAAm-G, AAAm, or AAm and, if rated by Moody's, rated Aaa, Aal or Aa2. E. Certificates of deposit secured at all times by collateral described in A and/or B above; provided that such certificates must be issued by commercial banks (including the Trustee and its affiliates), savings and loan associations or mutual savings banks and provided furthcr that the collateral must be held by a third party and the Trustee on behalf of the Owners must have a perfected first security interest in the collateral. F. Certificates of deposit, savings accounts, deposit accounts or money market deposits which are fully insured by the Federal Deposit Insurance Corporation, including those of the Trustee and its affiliates. G. Investment agreements, including guaranteed investment contracts, forward purchase agreements and reserve fund put agreements acceptable to the Insurer. PG402-1058\9227G5v4.doc 6 H. Commercial paper rated, at the time of purchase, "Prime - 1" by Moody's and "A-1" or better by S&P. I. Bonds or notes issued by any state or municipality which are rated by Moody's and S&P in one of the two highest rating categories assigned by such agencies. J. Federal funds or bankers acceptances with a maximum term of one year of any bank (including the Trustee and its affiliates) which has an unsecured, uninsured and unguaranteed obligation rating of "Prime - 1" or "A3" or better by Moody's and "A-1" or "A" or better by S&P. K. Repurchase Agreements which are acceptable to the Insurer and which provide for the transfer of securities from a dealer bank or securities firm (sellerlborrower) to the Trustee or third party custodian, as the case may be (buyer/lender), and the transfer of cash from the Trustee to the dealer bank or securities firm with an agreement that the dealer bank or securities firm will repay the cash plus a yield to the Trustee in exchange for the securities at a specified date. L. The Local Agency Investment Fund in the State Treasury or any similar pooled investment fund administered by the State, to the extent such investment is held in the name and to the credit of the Trustee. M. Medium-term notes issued by corporations organized and operating within the United States or by depository institutions licensed by the United States or any state and operating within the United States. Such notes shall have a minimum credit rating of "Aa3" by Moody's and "AA-" by S&P at time of purchase, and shall mature within three years or less. N. Shares of beneficial interest issued by the California Asset Management Trust, a common law trust established under the laws of the State. "Principal Account" means the account by that name established and held by the Trustee pursuant to Section 4.2(b)(2). "Proiect Area" means the territory within the project area described and defined in the Redevelopment Plan approved and adopted by the City by its Ordinance No. 80 and amended by its Ordinances Nos. 275 and 324. "Record Date" means, with respect to any Interest Payment Date, the 15th calendar day of the month immediately preceding such Interest Payment Date, whether or not such day is a Business Day. "Redemntion Account" means the account by that name established and held by the Trustee pursuant to Section 4.2(b)(3). "Redevelopment Law" means the Community Redevelopment Law, being California Health and Safety Code Section 33000, et se ., and all future acts supplemental thereto or amendatory thereof. PG402-1058\922765v4.doc % "Redevelopment Plan" means the Redevelopment Plan for the Project Area, approved and adopted by the City by its Ordinance No. 80 and includes any amendment of the Redevelopment Plan heretofore or hereafter made pursuant to law. "ReQistration Books" means the records maintained by the Trustee pursuant to Section 2.9 for the registration and transfer of ownership of the Bonds. "Report" means a document in writing signed by an Independent Redevelopment Consultant and including: (i) a statement that the person or firm making or giving such Report has read the pertinent provisions of the document or documenis to which such Report relates; (ii) a brief statement as to the nature and scope of the examination or investigation upon which the Report is based; and (iii) a statement that, in the opinion of such person or firm, sufficient examination or investigation was made as is necessary to enable said consultant to express an informed opinion with respect to the subject matter referred to in the Report. "Representation Letter" means the Blanket Issuer L.etter of Representations, dated July 1, 1997, from the Authority to the Depository, qualifying bonds issued by the Authority for the Depository's book-entry system. "ReQuest" means a request in writing signed by any officer of the designated public entity duly authorized by its legislative body for that purpose. "Revenue Fund" means the fund by that name established and held by the Trustee pursuant to Section 4.2(a). "Revenues" means (i) all amounts payable by the Agency pursuant to Section 2.3 or Section 2.4 of the Loan Agreement; (ii) any proceeds of the Bonds originally deposited with the Trustee and all moneys deposited and held from time to time by the Trustee in the funds and accounts established hereunder; and (iii) income and gains with respect to the investment of amounts on deposit in the funds and accounts established hereunder, other than amounts payable to the United States of America pursuant to Section 5.7. "S&P" means Standard & Poor's Ratings Services and its successors and assigns. "Securities Devositories" means The Depository Trust Company, 55 Water Street, 50`h Floor, New York, New York, 10041, Attn: Call Notification Department, Fax (212) 855- 7232; and, in accordance with then current guidelines of the Securities and Exchange Commission, such other addresses or such other securities depositories as the Authority may designate in a Certificate of the Authority delivered to the Trustee. "Series 2007A Loan" means the Series 2007A Loan, as defined in the Loan Agreemcnt, made by the Authority to the Agency. "Series 2007A Loan Fund" means the fund by that name established and held by the Trustee pursuant to Section 3.2. "Series 2007A Term Bonds" means the Bonds maturing on April 1, 20_. P6402- ] 058\9227GSv4.doc $ "State" means the State of California. "Supplemental Indenture" means any indenture, agreement or other instrument hereafter duly executed by the Authority and the Trustee in accordance with the provisions of Section 7.1. "Tax ReQulations" means temporary and permanent regulations promulgatcd under or with respect to Section 103 and Sections 141 through 150, inclusive, of the Code. "Trust Office" means the corporate trust office of the Trustee at the address set forth in Section 11.13 or such other offices as may be specified to the Authority by the Trustee in writing. With respect to presentation of Bonds for payment or for registration of transfer and exchange such term shall mean the office or agency of the Trustee at which, at any particular time, its corporate trust business shall be conducted. "Trustee" means Wells Fargo Bank, National Association, and its successors and assigns, and any other corporation or association which may at any time be substituted in its place as provided in Article VI. "Underwriter" means Stone & Youngberg LLC. Section 1.2. Rules of Construction. All references in this Indenture to "Articles," "Sections," and other subdivisions, unless indicated otherwise, are to the corresponding Articles, Sections or subdivisions of this Indenture; and the words "herein," "hereof," "hereunder," and other words of similar import refer to this Indenture as a whole and not to any particular Article, Section or subdivision hereof. Scction 1.3. Authorization and Purpose of Bonds. The Authority has reviewed all proceedings heretofore taken relative to the authorization of the Bonds and has found, as a result of such review, and hereby finds and determines that all things, conditions, and acts required by law to exisi, happen and be performed precedent to and in the issuance of the Bonds do exist, have happened and have been performed in due time, form and manner as required by law, and the Authority is now authorized under the Bond Law and each and every requirement of law, to issue the Bonds in the manner and form provided in this Indenture. The Authority hereby authorizes the issuance of the Bonds pursuant to the Bond Law and this Indenture for the purpose of providing funds to make the Series 2007A Loan to the Agency pursuant to the Loan Agreement. Section 1.4. Ec�ual Securitv. In consideration of the acceptance of the Bonds by the Owners thereof, this Indenture shall be deemed to be and shall constitute a contract among the Authority, the Trustee and the Owners of the Bonds; and the covenants and agreements herein set forth to be performed on behalf of the Authority shall be for the equal and proportionate benefit, security and protection of all Owners of the Bonds without preference, priority or distinction as to security or otherwise of any of the Bonds over any of the others by reason of the number or date thereof or the time of sale, execution or delivery thereof, or otherwise for any cause whatsoever, except as expressly provided therein or herein. P6402-1058\922765 v4.doc 9 ARTICLE II ISSUANCE OF BONDS Section 2.1. Desi�nation. The Bonds shall be designated the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A, and shall be issued in the original aggregate principal amount of $ . Sectiun 2.2. Terms of Bonds. (a) The Bonds shall be issued in fully registered form without coupons in denominations of $5,000 or any integral multiple thereof, so long as no Series 2007A Bond shall have more than one maturity date. The Bonds shall be dated the Closing Date, shall mature on April 1 in each of the years and in the amounts, and shall bear interest (calculated on the basis of a 360-day year of twelve 30-day months) at the rates, as follows: Maturity Date Principal Interest (April 1) Amount Rate $ % (b) Interest on the Bonds shall be payable on each Interest Payment Date to the person whose name appears on the Registration Books as the Owner thereof as of the close of business on the Record Date, such interest to be paid by check or draft of the Trustee mailed by first class mail, postage prepaid, on each Interest Payment Date to the Owner at the address of such Owner as it appears on the Registration Books on such Record Date; t�rovided, however, that at the written request of the Owner of at least $1,000,000 in aggregate principal amount of Outstanding Bonds filed with the Trustee prior to any Record Date, interest on such Bonds shall be paid to such Owner on each succeeding Interest Payment Date by wire transfer of immediately available funds to an account in the United States designated in such written request (unless and until such request has been revoked in writing). Payments of defaulted interest with respect to the Bonds shall be paid by check or draft to the Owners as of a special record date to be fixed by the Trustee, notice of which special record date shall be given to the Owners not less than ten days prior thereto. Principal of and premium, if any, on any Bond shal] be paid upon presentation and surrender thereof, at maturity or the prior redemption thereof, at the Trust P6402-1058\922765v4.doc 1 � Office. The principal of and interest and premium, if any, on the Bonds shall be payable in lawful money of the United States of America. Each Bond shall bear interest from the Interest Payment Date next preceding the date of authentication thereof, unless (i) it is authenticated during the period from the day after the Record Date for an Interest Payment Date to and including such Interest Payment Date, in which event it shall bear interest from such Interest Payment Date, or (ii) it is authenticated on or prior to the Record Date for the first Interest Payment Date, in which event it shall bear interest from the Closing Date; urovided, however, that if, at the time of authentication of any Bond interest with respect to such Bond is in default, such Bond shall bear interest from the Interest Payment Date to which interest has been paid or made available for payment with respect to such Bond. Section 2.3. Redemption of Bonds. (a) Redemntion from Ontional Loan Prenavments. In the event that the Agency shall exercise its option to prepay principal installments of the Series 2007A Loan pursuant to Section 2.4(a) of the Loan Agreement, the Revenues derived from such prepayment shall be applied to the redemption of the Bonds maturing on or after April 1, 20_, as a whole, or in part among maturities as designated in writing by the Authority and by lot within a maturity, in integral multiples of $5,000 principal amount, on any Interest Payment Date on or after April 1, 20_, at a redemption price equal to [ 100] percent of the principal amount of Bonds, plus accrued interest thereon to the date of redemption, without premium. The Authority shall provide written notice to the Trustee of any redemption pursuant to this Section 2.3(a) at least 45 but not more than 90 days prior to the date fixed for such redemption. (b) Mandatory Sinkin� Fund Redemntion. The Series 2007A Term Bonds shall also be subject to mandatory redemption by lot, on April 1 in each year commencing April 1, 20_, from sinking fund payments made by the Authority into the Principal Account pursuant to Section 4.2(b)(2), at a redemption price equal to the principal amount thereof to be redeemed, without premium, plus accrued interest to the date of redemption, in the aggregate respective principal amounts as set foRh in the following table; provided, however, that (i) in lieu of redemption thereof on April 1 of any year, the Series 2007A Term Bonds may be purchased by the Agency pursuant to Section 2.3 of the Loan Agreement and tendered to the Trustee for cancellation no later than the preceding January 15, and (ii) if some but not all of the Series 2007A Term Bonds have been redeemed pursuant to Paragraph (a) above, the total amount of all future sinking fund payments with respect to such Series 2007A Term Bonds shall be reduced by the aggregate principal amount of such Series 2007A Term Bonds so redeemed, to be allocated among such sinking fund payments on a pro rata basis. P6402-1058\922765v4.doc 11 Series 2007A Term Bonds MaturinQ April 1, 20 Sinking Fund Redemption Date Principal Amount (Anril 1) to be Redeemed $ * * maturity (c) Notice of Redemption. The Trustee on behalf and at the expense of the Authority shall send by first class mail (or such other means acceptable to such Owners and institutions) notice of any redemption to the respective Owners of any Bonds designated for redemption at their respective addresses appearing on the Registration Books, and to the Securities Depositories and to one or more Information Services, at least 30 but not more than 60 days prior to the date fixed for redemption; provided, however, that neither failure to receive any such notice so mailed nor any defect therein shall affect the validity of the proceedings for the redemption of such Bonds or the cessation of the accrual of interest thereon. Such notice shall state the date of the notice, the redemption date, the redemption place and the redemption price and shall designate the CUSIP numbers, the Bond numbers (but only if less than all of the Outstanding Bonds = are to be redeemed) and the maturity or maturities (in the event or redemption of all of the Bonds of such m�tiurity or maturities in whole) of the Bonds to be redeemed, and shall require such Bonds be then surrendered at the Trust Office of the Trustee in Los Angeles, California (or such other location as designated by the Trustee) for redemption at the redemption price, giving notice also that further interest on such Bonds will not accrue from and after the redemption date. (d) Selection of Bonds for Redemption. Whenever provision is made in this Indenture for the redemption of less than all of the Bonds of any maturity, the Trustee shall select the Bonds to be redeemed from all Bonds of such maturity not previously called for redemption, by lot in any manner which the Trustee in its sole discretion shall deem appropriate under the circumstances. For purposes of such selection, all Bonds be deemed to be comprised of separate $5,000 portions and such portions shall be treated as separate bonds which may be separately redeemed. (e) Partial Redemption of Bonds. In the event only a portion of any Bond is called for redemption, then upon surrender of such Bond the Authority shall execute and the Trustee shall authenticate and deliver to the Owner thereof, at the expense of the Authority, a new Bond or Bonds of the same tenor and maturity date, of authorized denominations in aggregate principal amount equal to the unredeemed portion of the Bond to be redeemed. (f� Effect of Redemption. From and after the date fixed for redemption, if funds available for the payment of the principal of, interest on and premium, if any, on the Bonds so called for redemption shall have been duly provided, such Bonds so called shall cease to be entitled to any benefit under the Indenture other than the right to receive payment of the redemption price, and no interest shall accrue thereon from and after the redemption date specified in such notice. All Bonds redeemed pursuant to this Section shall be destroyed. P6402-1058\922765v4.doc 12 Scction 2.4. Form of Bonds. The Bonds, the Trustee's certificate of authentication, and the form of assignment to appear thereon shall be substantially in the respective forms set forth in Exhibit A attached hereto and by this reference incorporated herein, with necessary or appropriate variations, omissions and insertions, as permitted or required by this Indenture. Section 2.5. Execution of Bonds. The Bonds shall be signed in the name and on behalf of the Authority with the manual or facsimile signatures of its President and attested with the manual or facsimile signature of its Secretary or any deputy duly appointed by the Authority Commission, and shall be delivered to the Trustee for authentication by it. In case any officer of the Authority who shall have signed any of the Bonds shall cease to be such officer before the Bonds so signed shall have been authenticated or delivered by the Trustee or issucd by the Authority, such Bonds may nevertheless be authenticated, delivered and issued and, upon such authentication, delivery and issue, shall be as binding upon the Authority as though the individual who signed the same had continued to be such officer of the Authority. Also, any Bond may be signed on behalf of the Authority by any individual who on the actual date of the execution of such Bond shall be the proper officer although on the nominal date of such Bond such individual shall not have been such officer. Only such of the Bonds as shall bear thereon a certificate of authentication in substantially the form set forth in Exhibit A manually executed by the Trustee, shall be valid or obligatory for any purpose or entitled to the benefits of this Indenture, and such certificate of the Trustee shall be conclusive evidence that the Bonds so authenticated have been duly authenticated and delivered hereunder and are entitled to the benefits of this Indenture. Section 2.6. Transfer of Bonds. Any Bond may, in accordance with its terms, be transferred, upon the Registration Books, by the person in whose name it is registered, in person or by such Owner's duly authorized attorney, upon surrender of such Bond for cancellation, accompanied by delivery of a written instrument of transfer in a form acceptable to the Trustee, duly executed. Whenever any Bond shall be surrendered for transfer, the Authority shall execute and the Trustee shall thereupon authenticate and deliver to the transferee a new Bond or Bonds of like tenor, maturity and aggregate principal amount. The cost of printing any Bonds and any services rendered or expenses incurred by the Trustee in connection with any such transfer shall be paid by the Authority, except that the Trustee shall require the payment by the Owner requesting such transfer of any tax or other governmental charge required to be paid with respect to such transfer. The Trustee shall not be required to transfer, pursuant to this Section 2.6, either (i) any Bond during the period established by the Trustee for the selection of Bonds for redemption, or (ii) any Bond selected for redemption pursuant to Section 2.3. Section 2.7. ExchanQe of Bonds. Bonds may be exchanged at the Trust Office for the same aggregate principal amount of Bonds of the same tenor and maturity and of other authorized denominations. The cost of printing any Bonds and any services rendered or expenses incurred by the Trustee in connection with any such exchange shall be paid by the Authority, except that the Trustee shall require the payment by the Owner requesting such exchange of any tax or other governmental charge required to be paid with respect to such exchange. The Trustee shall not be required to exchange, pursuant to this Section 2.7, either (i) P6402- ] 058\922765v4.doc 13 any Bond during the period established by the Trustee for the selection of Bonds for redemption, or (ii) any Bond selected for redemption pursuant to Section 2.3. Section 2.8. Temvorary Bonds. The Bonds may be issued initially in temporary form exchangeable for definitive Bonds when ready for delivery. The temporary Bonds may be printed, lithographed or typewritten, shall be of such denominations as may be determined by the Authority and may contain such reference to any of the provisions of this Indenture as may be appropriate. Every temporary Bond shall be executed by the Authority and be registered and authenticated by the Trustee upon the same conditions and in substantially the same manner as the definitive Bonds; provided that any temporary Bond need only be signed in the name and on behalf of the Authority with the manual or facsimile signature of the Secretary, or any deputy duly appointed by the Authority Commission, and need not be attested. If the Authority issues temporary Bonds, it will execute and furnish definitive Bonds without delay, and thereupon the temporary Bonds shall be surrendered, for cancellation, in exchange therefor at the Trust Office of the Trustee in Los Angeles, California (or such other location designated by the Trustee), and the Trustee shall authenticate and deliver in exchange for such temporary Bonds definitive Bonds of like term, maturity and aggregate principal amount in authorized denominations. Until so exchanged, the temporary Bonds shall be entitled to the same benefits under this Indenture as definitive Bonds authenticated and delivered hereunder. Section 2.9. ReQistration Books. The Trustee will keep or cause to be kept at its Trust Office sufficient records for the registration and transfer of the Bonds, which shall at all times during regular business hours be open to inspection by the Authority with reasonable prior notice; and, upon presentation for such purpose, the Trustee shall, under such reasonable regulations as it may prescribe, register or transfer or cause to be registered or transferred, on such records, Bonds as hereinbefore provided. Section 2.10. Bonds Mutilated, Lost, Destroved or Stolen. If any Bond shall become mutilated, the Authority, at the expense of the Owner of such Bond, shall execute, and the Trustee shall thereupon authenticate and deliver, a new Bond of like tenor, maturity and aggregate principal amount in authorized denominations in exchange and substitution for the Bond so mutilated, but only upon surrender to the Trustee of the Bond so mutilated. Every mutilated Bond so surrendered to the Trustee shall be cancelled by it and destroyed. If any Bond issued hereunder shall be lost, destroyed or stolen, evidence of such loss, destruction or theft may be submitted to the Trustee and, if such evidence be satisfactory to the Trustee and indemnity satisfactory to the Trustee shall be given, the Authority, at the expense of the Owner, shall execute, and the Trustee shall thereupon authenticate and deliver, a new Bond of like tenor in lieu of and in substitution for the Bond so lost, destroyed or stolen (or if any such Bond shall have matured or shall have been called for redemption, instead of issuing a substitute Bond the Trustee may pay the same without surrender thereof upon receipt of indemnity satisfactory to the Trustee). The Trustee may require payment of a reasonable fee for each new Bond issued under this Section 2.10 and of the expenses which may be incurred by the Authority and the Trustee. Any Bond issued under the provisions of this Section 2.10 in lieu of any Bond alleged to be lost, destroyed or stolen shall constitute an original contractual obligation on the part of the Authority whether or not the Bond alleged to be lost, destroyed or stolen be at any time enforceable by anyone, and shall be equally and proportionately entitled to the benefits of this Indenture with all other Bonds secured by this Indenture. P6402-1058\922765v4.doc 14 ARTICLE III DEPOSIT AND APPLICATION OF PROCEEDS OF BONDS; ISSUANCE OF BONDS Section 3.1. Issuance of Bonds. Upon the execution and delivery of this Indenture, the Authority shall execute and deliver the Bonds in the respective aggregate principal amounts set forth herein and shall deliver the Bonds to the Trustee for authentication and delivery to the original purchaser thereof upon the Request of the Authority. Scction 3.2. Series 2007A Loan Fund; Application of Proceeds of Sale of Bonds. The Trustee shall establish and maintain a separate fund to be known as the "Series 2007A Loan Fund." Upon the receipt of payment for the Bonds on the Closing Date, the Trustee shall deposit from the proceeds of sale thereof the amount of $ in the Series 2007A Loan Fund (such amount being equal to the principal amount of the Bonds, [plus/less] a net original issue [premium/discount) of $ , less an Underwriter's discount of $ , less an amount of $ wired by the Underwriter at the request of the Authority and the Agency to pay the premiums for the Insurance Policy and the Surety Bond allocable to the Bonds). The Trustee shall disburse all amounts in the Series 2007A Loan Fund pursuant to Section 2.2 of the Loan Agreement. Section 3.3. Validitv of Bonds. The validity of the authorization and issuance of the Bonds shall not be affected in any way by any proceedings taken by the Agency with respect to the application of the proceeds of the Series 2007A Loan, and the recital contained in the Bonds that the same are issued pursuant to the Bond Law shall be conclusive evidence of their validity and of the regularity of their issuance. ARTICLE IV REVENUES; FLOW OF FUNDS Section 4.1. P1edQe of Revenues; Assi�nment of Ri�hts. Subject to the provisions of Section 6.3, the Bonds shall be secured by a first lien on and pledge (which shall be effected in the manner and to the extent hereinafter provided) of all of the Revenues. The Bonds shall be equally secured by a pledge, charge and lien upon the Revenues without priority for number, date of Bonds, date of execution or date of delivery; and the payment of the interest on and principal of the Bonds and any premiums upon the redemption of any thereof shall be and are secured by an exclusive pledge, charge and lien upon the Revenues. So long as any of the Bonds are Outstanding, the Revenues shall not be used for any other purpose; except that out of the Revenues there may be apportioned such sums, for such purposes, as are expressly permitted by Section 4.2. The Authority hereby transfers in trust and assigns to the Trustee, for the benefit of the Owners from time to time of the Bonds, all of the Revenues and all of the right, title and interest of the Authority in the Loan Agreement (other than the rights of the Authority under Section 5.4 thereo�. The Trustee shall be entitled to and shall receive all of the Revenues, and P6402-1058\92276.5v4.doc 1$ any Revenues collected or received by the Authority shall be deemed to be held, and to have been collected or received, by the Authority as the agent of the Trustee and shall forthwith be paid by the Authority to the Trustee. The Trustee also shall be entitled to and, subject to the provisions hereof, shall take all steps, actions and proceedings reasonably necessary in its judgment to enforce, either jointly with the Authority or separately, all of the rights of the Authority and all of the obligations of the Agency under the Loan Agreement. Section 4.2. Receipt, Deposit and Application of Revenues. (a) Denosit of Revenues, Revenue Fund. All Revenues described in clause (i) of the definition thereof in Section 1.1 shall be promptly deposited by the Trustee upon receipt thereof in a special fund designated as the "Revenue Fund" which the Trustee shall establish, maintain and hold in trust hereunder. (b) Annlication of Revenues; Accounts. On or before each Interest Payment Date, the Trustee shall transfer from the Revenue Fund and deposit into the following respective accounts (each of which the Trustee shall establish and maintain within the Revenue Fund), the following amounts in the following order of priority, the requirements of each such account (including the making up of any deficiencies in any such account resulting from lack of Revenues sufficient to make any earlier required deposit) at the time of deposit to be satisfied before any transfer is made to any account subsequent in priority: (1) Interest Account. On or before each Interest Payment Date, the Trustee shall deposit in the Interest Account an amount required to cause the aggregate amount on deposit in the Interest Account to equal the amount of interest coming due and payable on such Interest Payment Date on all Outstanding Bonds. No deposit need be made into the Interest Account if the amount contained therein is at least equal to the interest coming due and payable upon all Outstanding Bonds on the next succeeding Interest Payment Date. All moneys in the Interest Account shall be used and withdrawn by the Trustee solely for the purpose of paying the interest on the Bonds as it shall become due and payable (including accrued interest on any Bonds redeemed prior to maturity). All amounts on deposit in the Interest Account on the first day of any Bond Year, to the extent not required to pay any interest then having come due and payable on the Outstanding Bonds, shall be withdrawn therefrom by the Trustee and transferred to the Agency to be used for any lawful purposes of the Agency. (2) Principal Account. On or before each date on which the principal of the Bonds shall be payable, the Trustee shall deposit in the Principal Account an amount required to cause the aggregate amount on deposit in the Principal Account to equal (i) the principal amount of the Bonds coming due and payable on such date pursuant to Section 2.2 and (ii) the principal amount of the Bonds subject to mandatory sinking fund redemption on such date pursuant to Section 2.3(b). All moneys in the Principal Account shall be used and withdrawn by the Trustee solely for the purpose of paying the principal of the Bonds (i) at the maturity thereof, or (ii) upon mandatory sinking fund redemption thereof. All amounts on deposit in the Principal Account on the first day of any Bond Year, to the extent not required to pay the principal of any Outstanding Bonds then having come due and payable, shall be withdrawn therefrom and transferred to the Agency to be used for any lawful purposes of the Agency. P6402-1058\922765v4.doc 16 (3) Redemntion Account. The Trustee, at any time that the Agency shall exercise its option to prepay principal installments of the Series 2007A Loan pursuant to Section 2.4 of the Loan Agreement, shall deposit the Revenues derived from such prepayment in the Redemption Account (which the Trustee shall also establish and maintain within the Revenue Fund), to be used and withdrawn by the Trustee solely for the purpose of paying the principal and redemption premiums, if any, on the Bonds to be redeemed on their respective redemption dates, as directed by the Authority. Section �.3. Investments. All moneys in any of the funds or accounts established with the Trustee pursuant to this Indenture or pursuant to the Loan Agreement shall be invested by the Trustee solely in Permitted Investments pursuant to the written direction of the Authority given to the Trustee two Business Days in advance of the making of such investments (and promptly confirmed in writing as to any such direction given orally); provided that moneys in the Reserve Fund established pursuant to the Loan Agreement shall be invested in Permitted Investments which mature not more than five years from the date of such investment. In the absence of any such direction from the Authority, the Trustee shall invest any such moneys in Permitted Investments described in Paragraph D of the definition thereof. Obligations purchased as an investment of moneys in any fund shall be deemed to be part of such fund or account. All interest or gain derived from the investment of amounts in any of the funds or accounts established hereunder shall be deposited in the fund or account from which such investment was made. For purposes of acquiring any investments hereunder, the Trustee may commingle funds held by it hereunder. The Trustee may (but shall not be obligated to) act as principal or agent in the acquisition or disposition of any investment. The Trustee shall incur no liability for losses arising from any investments made at the direction of the Authority, or otherwise made pursuant to this Section. The Trustee shall be entitled to rely conclusively upon the written instructions of the Authority directing investments in Permitted Investments as to the fact that each such investment is permitted by the laws of the State, and shall not be required to make further investigation with respect thereto. With respect to any restrictions set forth in the definition of Permitted Investments set forth in Section 1.1 which embody legal conclusions (e.g., the existence, validity and perfection of security interests in collateral), the Trustee shall be entitled to rely conclusively on an opinion of counsel or upon a representation of the provider of such Permitted Investment obtained at the Authority's or the Agency's expense. Except as specifically provided in this Indenture, the Trustee shall not be liable to pay interest on any moneys received by it, but shall be liable only to account to the Authority and the Agency for earnings derived from funds that have been invested. The Authority acknowledges that to the extent regulations of the Comptroller of the Currency or other applicable regulatory entity grant the Authority the right to receive brokerage confirmations of security transactions as they occur, the Authority specifically waives receipt of such confirmations to the extent permitted by law. The Trustee will furnish the Authority periodic cash transaction statements which include detail for all investment transactions made by the Trustee hereunder. P6402- ] 058\922765v4.doc 17 The Trustee or any of its affiliates may act as sponsor, advisor or manager in connection with any investments made by the Trustee hereunder. Scction 4.�. Valuation and Disposition of Investments. For the purpose of determining the amount in any fund or account established hereunder or under the Loan Agreement, any investments credited to such fund or account shall be valued at least annually, on or before July 1, at the market value thereof. In making any valuations hereunder the Trustee may utilize computerized securities pricing services that may be available to it, including those available through its regular accounting system. ARTICLE V COVENANTS OF THE AUTHORITY Sectiun 5. I. Punctual Pavment. The Authority shalt punctually pay or cause to be paid the principal, interest and premium, if any, to become due in respect of all the Bonds, in strict conformity with the terms of the Bonds and of this Indenture, according to the true intent and meaning thereof, but only out of Revenues and other assets pledged for such payment as provided in this Indenture. Section 5.2. Extension of Pavment of Bonds. The Authority shall not directly or indirectly extend or assent to the extension of the maturity of any of the Bonds or the time of payment of any claims for interest by the purchase of such Bonds or by any other arrangement, and in case the maturity of any of the Bonds or the time of payment of any such claims for interest shaIl be extended, such Bonds or claims for interest shall not be entitled, in case of any default hereunder, to the benefits of this Indenture, except subject to the prior payment in full of the principal of all of the Bonds then Outstanding and of all claims for interest thereon which shall not have been so extended. Nothing in this Section 5.2 shall be deemed to limit the right of the Authority to issue bonds or other obligations for the purpose of refunding any Outstanding Bonds, and such issuance shall not be deemed to constitute an extension of maturity of the Bonds. Section 5.3. A�ainst Encumbrances. The Authority shall not create, or permit the creation of, any pledge, lien, charge or other encumbrance upon the Revenues and other assets pledged or assigned under this Indenture while any of the Bonds are Outstanding, except the pledge and assignment created by this Indenture. Subject to this limitation, the Authority expressly reserves the right to enter into one or more other indentures for any of its corporate purposes, including other programs under the Bond Law, and reserves the right to issue other obligations for such purposes. Sectic�n 5.4. Power to Issue Bonds and Make Pled�e and Assi�nmcnt. The Authority is duly authorized pursuant to law to issue the Bonds and to enter into this Indenture and to pledge and assign the Revenues, the I,oan Agreement and other assets purported to be pledged and assigned, respectively, under this Indenture in the manner and to the extent provided in this Indenture. The Bonds anc! the provisions of this Indenture are and will be the legal, valid and binding special obligations of the Authority in accordance with their terms, and the Authority shall at all times, to the extent permitted by law, defend, preserve and protect said P6402-1058\922765v4.doc 1$ pledge and assignment of Revenues and other assets and all the rights of the Owners under this Indenture against all claims and demands of all persons whomsoever. Scction 5.5, Accounting Records and Financial Statements. The Trustee shall at all times keep, or cause to be kept, proper books of record and account, prepared in accordance with corporate trust industry standards, in which complete and accurate entries shall be made of all transactions made by the Trustee relating to the proceeds of thc Bonds, the Revenues, the Loan Agreement and all funds and accounts established pursuant to this Indenture. Such books of record and account shall be available for inspection by the Authority and the Agency, during regular business hours with reasonable prior notice. Section 5.6. No Additional Indebtedness. Except for the Bonds, the Authority shall not incur any indebtedness payable out of the Revenues. (For clarification, this provision does not prohibit the Agency from incurring additional debt secured by Tax Revenues, so long as the incurrence of such debt is in compliance with the Loan Agreement.) Section 5.7. Tax Covenants ReQardinQ Bonds. (a) The Authority covenants that, in order to maintain the exclusion from gross income for Federal income tax purposes of the interest on the Bonds, and for no other purpose, the Authority will satisfy, or take such actions as are necessary to cause to be satisfied, each provision of the Code necessary to maintain such exclusion. In furtherance of this covenant the Authority agrees to comply with such written instructions as may be provided by Bond Counsel. (b) The Authority covenants that no part of the proceeds of the Bonds shall be used, directly or indirectly, to acquire any Investment Property which would cause the Bonds to become arbitrage bonds, as that term is defined in Section 148 of the Code, or under applicable Tax Regulations. In order to assure compliance with the rebate requirements of Section 148 of the Code, the Authority further covenants that it will pay or cause to be paid to the United States the amounts necessary to satisfy the requirements of Section 148(f� of the Code, and that it will establish such accounting procedures as are necessary to adequately determine, account for and pay over any such amount required to be paid thereunder in a manner consistent with the requirements of Section 148 of the Code, such covenants to survive the defeasance of the Bonds. (c) The Authority covenants that it will not take any action or omit to take any action, which action or omission, if reasonably expected on the date of initial execution and delivery of the Bonds, would result in a loss of exclusion from gross income for purposes of Federal income taxation, under Section 103 of the Code, of interest on the Bonds. (d) The Authority covenants that it will not use or permit the use of any property financed with the proceeds of the Bonds by any person (other than a state or local governmental unit) in such manner or to such extent as would result in a loss of exclusion of the interest on the Bonds from gross income for Federal income tax purposes under Section ]03 of the Code. (e) Notwithstanding any provision of this Indenture, and except as provided below, the Authority covenants that none of the moneys contained in any of the funds or accounts created pursuant to the Indenture with respect to the Bonds shall be: (i) used in making loans guaranteed by the United States (or any agency or instrumentality thereof�, (ii) invested P6402-1058\922765v4.doc 19 directly or indirectly in a deposit or account insured by the Federal Deposit Insurance Corporation, National Credit Union Administration or any other similar Federally chartered corporation, or (iii) otherwise invested directly or indirectly in obligations guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof�; provided, however, that the above restrictions do not apply to: (a) the investment on moneys held in the Revenue Fund or any other "bona fide debt service fund" as defined for purposes of Section 148 of the Code, (b) investment in direct obligations of the United States Treasury, (c) investment in obligations guaranteed by the Federal National Mortgage Association, Government National Mortgage Association, or the Federal Home Loan Mortgage Corporation, (d) investment in obligations issued pursuant to Section 21B(d)(3) of the Federal Home Loan Bank Act, as amended by Section 511(a) of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989, (e) investments permitted under regulations issued pursuant to Section 149(b)(3)(B) of the Code, or (f� such other investments permitted under the Indenture as, in the opinion of Bond Counsel, do not jeopardize the exclusion from gross income for Federal income tax purposes of interest on the Bonds. Section 5.8. Loan AQreement. The Trustee, as assignee of the Authority's rights pursuant to Section 4.1, shall receive all amounts due from the Agency pursuant to the Loan Agreement and, upon an Event of Default, shall diligently enforce, and take all steps, actions and proceedings reasonably necessary for the enforcement of all of the rights of the Authority thereunder and for the enforcement of all of the obligations of the Agency thereunder. The Loan Agreement may be amended or modified pursuant to the applicable pravisions thereof, but only with the written consent of the Insurer (as long as the Insurance Policy is in full force and effect) and only: (i) if the Authority, the Agency or the Trustee first obtains the written consent of the Owners of a majority in aggregate principal amount of the affected Bonds then Outstanding to such amendment or modification; provided, however, that no such amendment or modification shall (a) extend the maturity of or reduce the amount of interest or principal payments on a Loan, or otherwise alter or impair the obligation of the Agency to pay the principal, interest or prepayment premiums on a Loan at the time and place and at the rate and in the currency provided therein, without the express written consent of the Owner of each affected Bond, (b) reduce the percentage of the Bonds required for the written consent to any such modification or amendment thereof or hereof, or (c) without its written consent thereto, modify any of the rights or obligations of the Trustee; or (ii) without the consent of any of the Owners, if such amendment or modification does not modify the rights or obligations of the Trustee without its prior written consent, and is for any one or more of the following purposes: (a) to add to the covenants and agreements of the Agency contained in the Loan Agreement other covenants and agreements thereafter to be observed, or to limit or surrender any rights or power therein reserved to or conferred upon the Agency so long as such limitation or surrender of such rights or powers shall not materially adversely affect the Owners of the Bonds; (b) to make such provisions for the purpose of curing any ambiguity, or of curing, correcting or supplementing any defective provision contained in the Loan Agreement, or in any other respect whatsoever as the Agency and the Authority may deem necessary or desirable, provided under any circumstances that such modifications or amendments shall not materially adversely affect the interests of the Owners of the Bonds; P6402-1058\922765 v4.doc 20 (c) to amend any provision thereof relating to the Code, to any extent whatsoever but only if and to the extent such amendment will not adversely affect the exclusion from gross income for federal income tax purposes of interest on any of the Bonds under the Codc, in the opinion of Bond Counsel; or (d) to provide for the issuance of Parity Debt in accordance with the provisions of the Loan Agreement. Noihing in this Section 5.8 shall prevent the Agency and the Authority, with the written consent of the Insurer (as long as the Insurance Policy is in full force and effect), from entering into any amendment or modifcation of the Loan Agreement which solely affects a particular Bond or Bonds all of the Owners of which shall have consented to such amendment or modification; urovided, however, no such amendment or modification shall affect the rights or obligations of the Trustee without its prior written consent. The Trustee shall be entitled to rely upon the opinion of Bond Counsel stating that the requirements of this Section 5.8 have been met with respect to any amendment or modification of the Loan Agreement. Sec�ion 5.9. Further Assurances. The Authority 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 the rights and benefits provided in this Indenture. ARTICLE VI TI-�E TRUSTEE Section 6.1. Appointment of Trustee. Wells Fargo Bank, National Association, a national banking association organized and existing under and by virtue of the laws of the United States of America, with a corporate trust office in Los Angeles, California, is hereby appointed Trustee by the Authority for the purpose of receiving all moneys required to be deposited with [he Trustee hereunder and to allocate, use and apply the same as provided in this Indenture. The Authority agrees that it will maintain a Trustee which shall be a financial institution having a corporate trust office in the State, with a combined capital and surplus of at least $75,000,000, and subject to supervision or examination by federal or State authority, so long as any Bonds are Outstanding. If such financial institution publishes a report of condition at least annually pursuant to law or to the requirements of any supervising or examining authority above referred to, then for the purpose of this Section 6.1 the combined capital and surplus of such financial institution shall be deemed to be its combined capital and surplus as set foRh in its most recent report of condition so published. The Trustee is hereby authorized to pay the principal of and interest and redemption premium, if any, on the Bonds when duly presented for payment at maturity, or on redemption or purchase prior to maturity, and to cancel all Bonds upon payment thereof. The Trustee shall keep accurate records of aIl funds administered by it and of all Bonds paid and discharged. P6402-1058\922765v4.doc 21 Section G.2. Acceptance of Trusts. The Trustee hereby accepts the trusts imposed upon it by this Indenture, and agrees to perform said trusts, but only upon and subject to the following express terms and conditions: (a) The Trustee, prior to the occurrence of an Event of Default and after curing of all Events of Default which may have occurred, undertakes to perform such duties and only such duties as are specifically set forth in this Indenture and no implied covenants, duties or obligations shall be read into the Indenture against the Trustee. In case an Event of Default hereunder has occurred (which has not been cured or waived), the Trustee may exercise such of the rights and powers vested in it by this Indenture, and shall use the same degree of care and skill and diligence in their exercise, as a prudent person would use in the conduct of its own affairs. (b) The Trustee may execute any of the trusts or powers hereof and perform the duties required of it hereunder by or through attorneys, agents, or receivers, and shall be entitled to advice of counsel concerning all matters of trust and its duty hereunder. The Trustee may conclusively rely on such advice or an opinion of counsel as full and complete protection for any action taken or suffered by it hereunder. (c) The Trustee shall not be responsible for any recital herein, in the Loan Agreement or in the Bonds, or for any of the supplements hereto or thereto or instruments of further assurance, or for the validity of this Indenture or the Loan Agreement, or for the sufficiency of the security for the Bonds issued hereunder or intended to be secured hereby, or the tax status of the interest on the Bonds, and the Trustee shall not be bound to ascertain or inquire as to the observance or performance of any covenants, conditions or agreements on the part of the Authority hereunder. (d) The Trustee (including its officers and employees) may become the Owner of Bonds secured hereby with the same rights which it would have if not the Trustee; may acquire and dispose of other bonds or evidences of indebtedness of the Authority with the same rights it would have if it were not the Trustee; and may act as a depositary for and permit any of its officers or directors to act as a member of, or in any other capacity with respect to, any committee formed to protect the rights of Owners of Bonds, whether or not such committee shall represent the Owners of the majority in aggregate principal amount of the Bonds then Outstanding. The Trustee, either as principal or agent, may engage in or be interested in any financial or other transaction with the Authority. (e) The Trustee shall be protected in acting upon any Report, notice, request, consent, certificate, order, affidavit, letter, direction, telegram, facsimile transmission, electronic mail or other paper or document believed by it to be genuine and correct and to have been signed or sent by the proper person or persons and need not make any investigation into the facts or matters contained therein. Any action taken or omitted to be taken by the Trustee pursuant to this Indenture upon the request or authority or consent of any person who at the time of making such request or giving such authority or consent is the Owner of any Bond, shall be conclusive and binding upon all future Owners of the same Bond and upon Bonds issued in exchange therefor or in place thereof. The Trustee shall not be bound to recognize any person as an Owner P6402-1058\922765v4.doc 22 of any Bond or to take any action at his request unless the ownership of such Bond by such person shall be reflected on the Registration Books. (f� As to the existence or non-existence of any fact or as to the sufficiency or validity of any instrument, paper or proceeding, the Trustee shall be entitled to rely upon a Certificate of the Authority as sufficient evidence of the facts therein contained and prior to the occurrence of an Event of Default hereunder of which the Trustee has been given notice or is deemed to have notice, as provided in Section 6.2(h), shall also be at liberty to accept a Certificate of the Authority to the effect that any particular dealing, transaction or action is necessary or expedient, but may at its discretion secure such further evidence deemed by it to be necessary or advisable, but shall in no case be bound to secure the same. (g) The permissive right of the Trustee to do things enumerated in this Indenture shall not be construed as a duty and it shall not be answerable for other than its negligence or willful misconduct. The immunities and exceptions from liability of the Trustee shall extend to its officers, directors, employees and agents. In the absence of negligence or willful misconduct, the Trustee shall not be liable for any enor of judgment. (h) The Trustee shall not be required to take notice or be deemed to have notice of any Event of Default hereunder except failure by the Authority to make any of the payments to the Trustee required to be made by the Authority pursuant hereto, unless the Trustee shall be specifically notified in writing of such default by the Authority, the Insurer or by the Owners of at least 25 percent in aggregate principal amount of the Bonds then Outstanding and all notices or other instruments required by this Indenture to be delivered to the Trustee must, in order to be effective, be delivered at the Trust Office of the Trustee in Los Angeles, California, and in the absence of such notice so delivered the Trustee may conclusively assume there is no Event of Default hereunder except as aforesaid. (i) At any and all reasonable times the Trustee, and its duly authorized agents, attorneys, experts, accountants and representatives, shall have the right, but not the obligation, fully to inspect all books, papers and records of the Authority pertaining to the Bonds, and to make copies of any of such books, papers and records such as may be desired but which is not privileged by statute or by law. (j) The Trustee shall not be required to give any bond or surety in respect of the execution of the said trusts and powers or otherwise in respect of the premises hereof. (k) Notwithstanding anything elsewhere in this Indenture with respect to the execution of any Bonds, the withdrawal of any cash, the release of any property, or any action whatsoever within the purview of this Indenture, the Trustee shall have the right, but shall not be required, to demand any showings, certificates, opinions, appraisals or other information, or corporate action or evidence thereof, as may be deemed desirable for the purpose of establishing the right of the Authority to the execution of any Bonds, the withdrawal of any cash, or the taking of any other action by the Trustee. (1) Before taking action referred to in Section 6.5, Section 8.2 or the first paragraph of Section 5.8, the Trustee may require that a satisfactory indemnity bond be furnishcd P6402-1058\922765v4.doc 23 for the reimbursement of all expenses to which it may be put and to protect it against all liability, except liability which is adjudicated to have resulted from its negligence or willful misconduct in connection with any such action. (m)All moneys received by the Trustee shall, until used or applied or invested as herein provided, be held in trust for the purposes for which they were received but need not be segregated from other funds except to the extent required by law. (n) The Trustee shall have no liability or obligation to the Bond Owners with respect to the payment of debt service by the Authority or with respect to the observance or performance by the Authority of the other conditions, covenants and terms contained in this Indenture, or with respect to the investment of any moneys in any fund or account established, held or maintained by the Authority pursuant to this Indenture or otherwise. (o) The Trustee makes no covenant, representation or warranty concerning the current or future tax status of interest on the Bonds. The Trustee need only keep accurate records of all investments and funds, and send rebate payments to the United States in accordance with explicit instructions from the Authority. (p) The Trustee shall have no responsibility with respect to any information, statement, or recital in any official statement, offering memorandum or any other disclosure material prepared or distributed with respect to the issuance of the Bonds. (q) The Trustee in its capacity as Trustee is authorized and directed to execute the Loan Agreement. (r) The Trustee shall not be considered in breach of or in default in its obligations hereunder or progress in respect thereto in the event of enforced delay ("unavoidable delay") in the performance of such obligations due to unforeseeable causes beyond its control and without its fault or negligence, including, but not limited to, Acts of God or of the public enemy or terrorists, acts of a government, acts of the other party, fires, floods, epidemics, quarantine restrictions, strikes, freight embargoes, earthquakes, explosion, mob violence, riot, inability to procure or general sabotage or rationing of labor, equipment, facilities, sources of energy, material or supplies in the open market, litigation or arbitration involving a party or others relating to zoning or other governmental action or inaction pertaining to the project, maiicious mischief, condemnation, and unusually severe weather or delays of suppliers or subcontractors due to such causes or any similar event and/or occurrences beyond the control of the Trustee; urovided that, in the event of any such unavoidable delay under this paragraph 6.02(r), the Trustee notify the Authority and the Agency in writing within five business days after (i) the occurrence of the event giving rise to the unavoidable delay, (ii) the Trustee's actual knowledge of the impending unavoidable delay, or (iii) the Trustee's knowledge of sufficient facts under which a reasonable person would conclude the unavoidable delay will occur. (s) The Trustee agrees to accept and act upon facsimile transmission of written instructions or directions pursuant to this Indenture, provided, however, that: (i) subsequent to such facsimile transmission of written instructions or directions the Trustee shall forthwith receive the originally executed instructions or directions, (ii) such originally executed P6402-1058\92276Sv4.doc 24 instructions or directions shall be signed by a person as may be designated and authorized to sign for the party signing such instructions or directions, and (iii) the Trustee shall have received a current incumbency certificate containing the specimen signature of such designated person. Section 6.3. Fees, CharQes and Exvenses of Trustee. The Trustee shall be entitled to payment and reimbursement for reasonable fees for its services rendered hereunder and all advances (with interest on such advances at the maximum rate allowed by law), counsel fees and expenses (including those of in-house counsel to the extent they are for services not duplicative of other counsels' work) and other expenses reasonably and necessarily made or incurred by the Trustee in connection with such services, which payment and reimbursement shall not be limited by any provision of law in regard to the compensation of a trustee of an express trust. Upon the occurrence of an Event of Default hereunder, but only upon an Event of Default, the Trustee shall have a first lien with right of payment prior to payment of any Bond upon the amounts held hereunder for the foregoing fees, charges and expenses incurred by it respectively, which right to payment shall survive the resignation or removal of the Trustee. Section G.4. Notice to Owners of Default. If an Event of Default hereunder occurs with respect to any Bonds of which the Trustee has been given or is deemed to have notice, as provided in Section 6.2(h), then the Trustee shall promptly given written notice thereof by first-class mail to the Owner of each such Bond, unless such Event of Default shall have been cured before the giving of such notice; provided, however, that unless such Event of Default consists of the failure by the Authority to make any payment when due, the Trustee may elect not to give such notice if and so long as the Trustee in good faith determines that such Event of Default does not materially adversely affect the interests of the Owners or that it is otherwise not in the best interests of the Owners to give such notice. Section 6.5. Intervention bv Trustee. In any judicial proceeding to which the Authority is a party which, in the opinion of the Trustee, has a substantial bearing on the interests of Owners of any of the Bonds, the Trustee may intervene on behalf of such Owners, and subject to Section 6.2(1), shall do so if requested in writing by the Owners of a majority in aggregate principal amount of such Bonds then Outstanding. Section 6.G. Removal of Trustee. The Owners of a majority in aggregate principal amount of the Outstanding Bonds may at any time, and the Authority may (and at the request of the Agency shall) so long as no Event of Default shall have occurred and then be continuing, remove the Trustee initially appointed, and any successor thereto, by an instrument or concurrent instruments in writing delivered to the Trustee, whereupon the Authority or such Owners, as the case may be, shall appoint a successor or successors thereto; provided that any such successor shall be a financial institution meeting the requirements set forth in Section 6.1. Section 6.7. Resi�nation bv Trustee. The Trustee and any successor Trustee may at any time give written notice of its intention to resign as Trustee hereunder, such notice to be given to the Authority and the Agency by registered or certified mail. Upon receiving such notice of resignation, the Authority shall promptly appoint a successor Trustee. Any resignation or removal of the Trustee and appointment of a successor Trustee shall become effective upon acceptance of appointment by the successor Trustee. Upon such acceptance, the Authority shall P6402-1058\922765v4.doc 2$ cause notice thereof to be given by first class mail, postage prepaid, to the Bond Owners at their respective addresses set forth on the Registration Books. Scc;tion 6.8. Aaaointment of Successor Trustee. In the event of the removal or resignation of the Trustee pursuant to Sections 6.6 or 6.7, respectively, with the prior written consent of Agency, the Authority shall promptly appoint a successor Trustee. In the event the Authority shall for any reason whatsoever fail to appoint a successor Trustee within 60 days following the delivery to the Trustee of the instrument described in Section 6.6 or within 60 days following the receip[ of notice by the Authority pursuant to Section 6.7, the Trustee may, at the expense of the Authority, apply to a court of competent jurisdiction for the appointment of a successor Trustee meeting the requirements of Section 6.1. Any such successor Trustee appointed by such court shall become the successor Trustee hereunder notwithstanding any action by the Authority purporting to appoint a successor Trustee following the expiration of such sixty-day period. Scction 6.9. Mer�er or Consolidation. Any bank or trust company into which the Trustee may be merged or converted or with which either of them may be consolidated or any bank or trust company resulting from any merger, conversion or consolidation to which it shall be a party or any bank or [rust company to which the Trustee may sell or transfer all or substantially all of its corporate trust business, provided such bank or trust company shall be eligible under Section 6.1, shall be the successor to such Trustee without the execution or filing of any paper or further act, excepi as provided in Section 6.10. Section 6.10. Concernin� anv Successor Trustee. Every successor Trustee appointed hereunder shall execute, acknowledge and deliver to its predecessor and also to the Authority an instrument in writing accepting such appointment hereunder and thereupon such successor, without any further act, deed or conveyance, shall become fully vested with all the estates, properties, rights, powers, trusts, duties and obligations of its predecessors; but such predecessor shall, nevertheless, on the Request of the Authority, or of the Trustee's successor, execute and deliver an instrument transferring to such successor all the estates, properties, rights, powers and trusts of such predecessor hereunder; and every predecessor Trustee shall deliver all securities and moneys held by it as the Trustee hereunder to its successor. Should any instrument in writing from the Authority be required by any successor Trustee for more fully and ceRainly vesting in such successor the estate, rights, powers and duties hereby vested or intended to be vested in the predecessor Trustee, any and all such instruments in writing shall, on request, be executed, acknowledged and delivered by the Authority. Section 6.11. Appointment of Co-Trustee. It is the purpose of this Indenture that there shall be no violation of any law of any jurisdiction (including particularly the law of the State) denying or restricting the right of banking corporations or associations to transact business as Trustee in such jurisdiction. It is recognized that in the case of li�igation under this Indenture, and in particular in case of the enforcement of the rights of the Trustee on default, or in the case the Trustee or the Authority deems that by reason of any present or future law of any jurisdiction it may not exercise any of the powers, rights or remedies herein granted to the Trustee or hold title to the properties, in trust, as herein granted, or take any other action which may be desirable or necessary in connection therewith, it may be necessary that the Trustee or the Authority P6402-1058\922765v4.doc 26 appoint an additional individual or institution as a separate co-trustee. The following provisions of this Section 6.11 are adopted to these ends. In the event that the Trustee or the Authority appoints an additional individual or institution as a separate or co-trustee, each and every remedy, power, right, claim, demand, cause of action, immunity, estate, title, interest and lien expressed or intended by this Indenture to be exercised by or vested in or conveyed to the Trustee with respect thereto shall be exercisable by and vest in or conveyed to the Trustee with respect thereto shall be exercisable by and vest in such separate or co-trusiee but only to the extent necessary to enable such separate or co-trustee to exercise such powers, rights and remedies, and every covenant and obligation necessary to the exercise thereof by such separate or co-trustee shall run to and be enforceable by either of them. The Trustee shall not be liable for the acts or omissions of any separate or co-trustee appointed hereunder. Should any instrument in writing from the Authority be required by the separate trustee or co-trustee so appointed by the Trustee for more fully and certainly vesting in and conforming to it such properties, rights, powers, trusts, duties and obligations, any and all such insiruments in writing shall, on request, be executed, acknowledged and delivered by the Authority. In case any separate trustee or co-trustee, or a successor to either, shall become incapable of acting, resign or be removed, all the estates, properties, rights, powers, trusts, duties and obligations of such separate trustee or co-trustee, so far as permitted by law, shall vest in and be exercised by the Trustee until the appointment of a new trustee or successor to such separate trustee or co-trustee. Section 6.12. Indemnification; Limited Liabilitv of Trustee. The Authority further covenants and agrees to indemnify, defend and save the Trustee and its officers, directors, agents and employees, harmless against any loss, expense and liabilities which it may incur arising out of or in the exercise and performance of its powers and duties hereunder, including the costs of expenses of defending against any claim of liability, but excluding any and all losses, expenses and liabilities which are due to the negligence or intentional misconduct of the Trustee, its officers, directors or employees. No provision in this Indenture shall require the Trustee to risk or expend its own funds or otherwise incur any financial liability hereunder if it shall have reasonable grounds for believing repayment of such funds or adequate indemnity against such liability or risk is not assured to it. The Trustee shall not be liable for any action taken or omitted to be taken by it in accordance with the direction of the Insurer or the Owners of at least a majority in aggregate principal amount of Bonds Outstanding relating to the time, method and place of conducting any proceeding or remedy available to the Trustee under this Indenture in exercising any trust or power conferred on the Trustee by this Indenture. The obligations of the Authority under this Section shall survive the payment and discharge of the Bonds or the resignation or removal of the Trustee under this Indenture. P6402- ] 058\922765v4.doc 27 � ARTICLE VII MODIFICATION AND AMENDMENT OF THE INDENTURE Section 7.1. Amendment Hereof. This Indenture and the rights and obligations of the Authority and of the Owners of the Bonds may be modified or amended at any time by a Supplemental Indenture which shall become binding upon adoption, with the written consent of the Insurer (as long as the Insurance Policy is in full force and effect) but without consent of any Bond Owners, to the extent permitted by law but only for any one or more of the following purposes: (a) To add to the covenants and agreements of the Authority in this Indenture contained, other covenants and agreements thereafter to be observed, or to limit or surrender any rights or powers herein reserved to or conferred upon the Authority so long as such limitation or sunender of such rights or powers shall not materially adversely affect the Owners of the Bonds; or (b) To make such provisions for the purpose of curing any ambiguity, or of curing, correcting or supplementing any defective provision contained in this Indenture, or in any other respect whatsoever as the Authority may deem necessary or desirable, provided under any circumstances that such modifications or amendments shall either (i) conform to the original intention of the Authority, or (ii) not materially adversely affect the interests of the Owners of the Bonds in the reasonable judgment of the Authority; or (c) To amend any provision hereof relating to the Code, to any extent whatsoever but only if and to the extent such amendment will not adversely affect the exclusion from gross income of interest on any of the Bonds under the Code, in the opinion of Bond Counsel. Except as set forth in the preceding paragraphs of this Section 7.1, this Indenture and the rights and obligations of the Authority and of the Owners of the Bonds may only be modified or amended at any time by a Supplemental Indenture which shall become binding when the written consent of the Insurer (as long as the Insurance Policy is in full force and effect) and of the Owners of a majority in aggregate principal amount of the affected Bonds then Outstanding are filed with the Trustee. No such modification or amendment shall (i) extend the maturity of or reduce the interest rate on any Bond or otherwise alter or impair the obligation of the Authority to pay the principal, interest or premiums, if any, at the time and place and at the rate and in the currency provided therein of any Bond without the express written consent of the Owner of such Bond or (ii) reduce the percentage of Bonds required for the written consent to any such amcndment or modification. In no event shall any Supplemental Indenture modify any of the rights or obligations of the Trustee without its prior written consent. Section 7.2. Effect of Sunplemental Indenture. From and after the time any Supplemental Indenture becomes effective pursuant to this Article VII, this Indenture shall be deemed to be modified and amended in accordance therewith, the respective rights, duties and obligations of the parties hereto or thereto and all Owners of Outstanding Bonds, as the case may be, shall thereafter be determined, exercised and enforced hereunder subject in all respects to such modification and amendment, and all the terms and conditions of any Supplemental P6402-1058\922765 v4.doc 2 g Indenture shall be deemed to be part of the terms and conditions of this Indenture for any and all purposes. Section �.3. Endorsement or Reulacement of Bonds After Amendment. After the effective date of any action taken as hereinabove provided, the Authority may determine that the Bonds shall bear a notation, by endorsement in form approved by the Authority, as to such action, and in that case upon demand of the Owner of any Bond Outstanding at such cffective date and presentation of his bond for that purpose at the Trust Office of the Trustee, a suitable notation as to such action shall be made on such Bond at the expense of the Authority. If the Authority shall so determine, new Bonds so modified as, in the opinion of the Authority, shall be necessary to conform to such Bond Owners' action shall be prepared and executed, and in that case upon demand of the Owner of any Bond Outstanding at such effective date such new Bonds shall be exchanged at the Trust Office of the Trustee at the expense of the Authority, for Bonds then Outstanding, upon surrender of such Outstanding Bonds. ARTICLE VIII EVENTS OF DEFAULT AND REMEDIES NOTWITHSTANDING ANYTHING TO THE CONTRARY 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 THIS ARTICLE VIII SHALL BE SUBJECT TO, AND QUALIFIED BY, THE PROVISIONS SET FORTH IN ARTICLE IX, INCLUDING, WITHOUT LIMITATION, THE INSURER'S RIGHT TO CONSENT TO ACCELERATION OF TI-IE BONDS, AND THE INSURER'S RIGHT TO CONSENT TO OR DIRECT CERTAIN AUTHORITY, TRUSTEE OR OWNER ACTIONS. Section 8.1. Events of Default. The following events shall be Events of Default hereunder: (a) Default in the due and punctual payment of the principal of any Bond when and as the same shall become due and payable, whether at maturity as therein expressed, by proceedings for redemption, by declaration or otherwise. (b) Default in the due and punctual payment of any installment of interest on any Bond when and as such interest installment shall become due and payable. (c) Failure by the Authority to observe and perform any of the covenants, agreements or conditions on its part in this lndenture or in the Bonds contained, other than as referred to in the preceding Paragraphs (a) and (b), for a period of 60 days after written notice, specifying such a failure and requesting that it be remedied has been given to the Authority by the Trustee, or to the Authority and the Trustee by the Owners of a majority in aggregate principal amount of the Outstanding Bonds; provided, however, that if in the reasonable opinion of the Authority the faiiure stated in such notice can be conected, but not within such 60 day period, such failure shall not constitute an Event of Default if corrective action is instituted by the Authority within such 60 day period and diligently pursued until such failure is corrected. P6402-1OS8\922765v4.doc 29 (d) The filing by the Authority of a petition or answer seeking reorganization or arrangement under the federal bankruptcy laws or any other applicable law of the United States of America, or if a court of competent jurisdiction shall approve a petition, filed with or without the consent of the Authority, seeking reorganization under the federal bankruptcy laws or any other applicable law of the United States of America, or if, under the provisions of any other law for the relief or aid of debtors, any court of competent jurisdiction shall assume custody or control of the Authority or of the whole or any substantial part of its property. (e) The occurrence of any Event of Default under, and as that term is defined in, the Loan Agreement. Section 8.2. Remedies Uvon Event of Default. Subject to the provisions of Article IX, if any Event of Default shall occur, then, and in each and every such case during the continuance of such Event of Default, the Trustee may, and at the written direction of the Owners of a majority in aggregate principal amount of the Bonds at the time Outstanding shall, upon notice in writing to the Authority and the Agency, declare the principal of all of the Bonds then Outstanding, and the interest accrued thereon, to be due and payable immediately, and upon any such declaration the same shall become and shall be immediately due and payable, anything in this Indenture or in the Bonds contained to the contrary notwithstanding. Any such declaration is subject to the condition that if, at any time after such declaration and before any judgment or decree for the payment of the moneys due shall have been obtained or entered, the Authority or the Agency shall deposit with the Trustee a sum sufficient to pay all the principal of and installments of interest on the Bonds payment of which is overdue, with interest on such overdue principal at the rate borne by the respective Bonds to the extent permitted by law, and the charges and expenses of the Trustee and its counsel (including the allocated costs and disbursements of in-house counsel to the extent the services of such counsel are not duplicative of services provided by outside counsel), and any and all other Events of Default known to the Trustee (other than in the payment of principal of and interest on the Bonds due and payable solely by reason of such declaration) shall have been made good or cured to the satisfaction of the Trustee or provision deemed by the Trustee to be adequate shall have been made therefor, then, and in every such case, the Owners of not less than a majority in aggregate principal amount of the Bonds then Outstanding, by written notice to the Authority, the Agency and the Trustee, or the Trustee if such declaration was made by the Trustee, may, on behalf of the Owners of all of the Bonds, rescind and annul such declaration and its consequences and waive such Event of Default; but no such rescission and annulment shall extend to or shall affect any subsequent Event of Default, or shall impair or exhaust any right or power consequent thereon. In addition, upon the occurrence and during the continuance of an Event of Default, the Trustee may pursue any available remedy at law or in equity to enforce the payment of the principal of and interest and premium, if any, on the Bonds, and to enforce any rights of the Trustee under or with respect to the Loan Agreement and this Indenture. If an Event of Default shall have occurred and be continuing and if requested so to do by the Owners of a majority in aggregate principal amount of Outstanding Bonds and indemnified as provided in Section 6.2(1), the Trustee shall be obligated to exercise such one or P6402-1058\922765v4.doc 3� more of the rights and powers confened by this Article VIII, as the Trustee, being advised by counsel, shall deem most expedient in the interest of the Bond Owners. No remedy by the terms of this Indenture conferred upon or reserved [o the Trustee (or to the Owners) is intended to be exclusive of any other remedy, but each and every such remedy shall be cumulative and shall be in addition to any other remedy given to the Trustee or to the Owners hereunder or now or hereafter existing at law or in equity. No delay or omission to exercise any right or power accruing upon any Event of Default shall impair any such right or power or shall be construed to be a waiver of any such Event of Default or acquiescence therein; such right or power may be exercised from time to time as often as may be deemed expedient. Section 8.3. Application of Revenues and Other Funds After Default. All amounts received by the Trustee pursuant to any right given or action taken by the Trustee under the provisions of this Indenture shall be applied by the Trustee in the following order upon presentation of the several Bonds, and the stamping thereon of the amount of the payment if only partially paid, or upon the surrender thereof if fully paid: First, to the payment of the fees, costs and expenses of the Trustee, including reasonable compensation to its agents, attorneys and counsel (including the allocated costs and disbursements of in-house counsel to the extent the services of such counsel are not duplicative of services provided by outside counsel); and Second, to the payment of the whole amount of interest on and principal of the Bonds then due and unpaid, with interest on overdue installments of principal, and such interest to the extent permitted by law at the net effective rate of interest then borne by the Outstanding Bonds; provided, however, that in the event such amounts shall be insufficient to pay in full the full amount of such interest and principal, then such amounts shall be applied in the following order of priority: (i) first, to the payment of all installments of interest on the Bonds then due and unpaid, on a pro rata basis in the event that the available amounts are insufficient to pay all such interest in full, (ii) second, to the payment of principal of all installments of the Bonds then due and payable, on a pro rata basis in the event that the available amounts are insufficient to pay all such principal in full, and (iii) third, to the payment of interest on overdue installments of principal and interest, on a pro rata basis in the event that the available amounts are insufficient to pay all such interest in full. Section 8.4. Power of Trustee to Control Proceedin�s. Subject to the provisions of Article IX, in the event that the Trustee, upon the happening of an Event of Default, shall have taken any action, by judicial proceedings or otherwise, pursuant to its duties hereunder, whether upon its own discretion or upon the request of the Owners of at least a majority in aggregate principal amount of the Bonds then Outstanding, it shall have full power, P6402-1 O58\922765v4.doc 31 in the exercise of its discretion for the best interests of the Owners, with respect to the continuance, discontinuance, withdrawal, compromise, settlement or other disposal of such action; nrovided, however, that the Trustee shall not, unless there no longer continues an Event of Default, discontinue, withdraw, compromise or settle, or otherwise dispose of any litigation pending at law or in equity, if at the time there has been filed with it a written request signed by the Owners of a majority in aggregate principal amount of the Outstanding Bonds hereunder opposing such discontinuance, withdrawal, compromise, settlement or other disposal of such litigation. Any suit, action or proceeding which any Owner shall have the right to bring to enforce any right or remedy hereunder may be brought by the Trustee for the equal benefit and protection of all Owners similarly situated and the Trustee is hereby appointed (and the successive respective Owners, by taking and holding the same, shall be conclusively deemed so to have appointed it) the true and lawful attorney-in-fact of the respective Owners for the purpose of bringing any such suit, action or proceeding and to do and perform any and all acts and things for and on behalf of the respective Owners as a class or classes, as may be necessary or advisable in the opinion of the Trustee as such attorney-in-fact. Section 8.5. Annointment of Receivers. Upon the occurrence of an Event of Default hereunder, and upon the filing of a suit or other commencement of judicial proceedings to enforce the rights of the Trustee and of the Owners under this Indenture, the Trustee shall be entitled, as a matter or right, to the appointment of a receiver or receivers of the Revenues and other amounts pledged hereunder, pending such proceedings, with such powers as the court making such appointment shall confer. Section 8.6. Non-Waiver. Nothing in this Article VIII or in any other provision of this Indenture, or in the Bonds, shall affect or impair the obligation of the Authority, which is absolute and unconditional, to pay the interest on and principal of the Bonds to the respective Owners of the Bonds at the respective dates of maturity, as herein provided, out of the Revenues and other moneys herein pledged for such payment. A waiver of any default or breach of duty or contract by the Trustee or any Owners 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 delay or omission of the Trustee or any Owner to exercise 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 any acquiescence therein; and every power and remedy conferred upon the Trustee or Owners by the Bond Law or by this Article VIII may be enforced and exercised, upon an Event of Default, from time to time and as often as shall be deemed expedient by the Trustee or the Owners, as the case may be. Section 8.7. Limitation on Ri�hts and Remedies of Owners. No Owner shall have the right to institute any suit, action or proceeding at law or in equity, for any remedy under or upon this Indenture, unless (i) such Owner shall have previously given to the Trustee written notice of the occurrence of an Event of Default; (ii) the Owners of a majority in aggregate principal amount of all the Bonds then Outstanding shall have made written request upon the Trustee to exercise the powers hereinbefore granted or to institute such action, suit or proceeding in its own name; (iii) said Owners shall have tendered to the Trustee indemnity reasonably acceptable to the Trustee against the costs, expenses and liabilities to be incurred in compliance with such request; and (iv) the Trustee shall have refused or omitted to comply with such request P6402-1058\922765v4.doc 32 for a period of 60 days after such written request shall have been received by, and said tender of indemnity shall have been made to, the Trustee. Such notification, request, tender of indemnity and refusal or omission are hereby declared, in every case, to be conditions precedent to the exercise by any Owner of any remedy hereunder; it being understood and intended that no one or more Owners shall have any right in any manner whatever by the Owner's or Owners' action to enforce any right under this Indenture, except in the manner herein provided, and that all proceedings at law or in equity to enforce any provision of this Indenture shall be instituted, had and maintained in the manner herein provided and for the equal benefit of all Owners. The right of any Owner of any Bond to receive payment of the principal of and interest and premium, if any, on such Bond as herein provided or to institute suit for the enforcement of any such payment, shall not be impaired or affected without the written consent of such Owner, notwithstanding the foregoing provisions of this Section or any other provision of this Indenture. Section 8.8. Termination of ProceedinQs. In case the Trustee shall have proceeded to enforce any right under this Indenture by the appointment of a receiver or otherwise, and such proceedings shall have been discontinued or abandoned for any reason, or shall have been determined adversely, then and in every such case, the Authority, the Trustee and the Owners shall be restored to their former positions and rights hereunder, respectively, with regard to the property subject to this Indenture, and all rights, remedies and powers of the Trustee shall continue as if no such proceedings had been taken. ARTICLE IX BOND INSURANCE Section 9.1. Pavments Under the Insurance Policv; Certain RiQhts of the Insurer. As long as the Insurance Policy is in full force and effect, the Authority and the Trustee agree to comply with the following provisions: (a) In the event thai, on the second Business Day, and again on the Business Day, prior to an Interest Payment Date, the Trustee has not received sufficient moneys to pay all principal of and interest on the Bonds due on the second following or following, as the case may be, Business Day, the Trustee shall immediately notify the Insurer or its designee on the same Business Day by telephone or telegraph, confirmed in writing by registered or certified mail, of the amount of the deficiency. (b) If a deficiency exists pursuant to paragraph (a) above and is made up in whole or in part prior to or on the Interest Payment Date, the Trustee shall so notify the Insurer or its designee by telephone or telegraph, promptly confirmed in writing by registered or certified mail or facsimile transmission. (c) If the Trustee has received written notice that any Owner has been required to disgorge payments of principal or interest on a Bond to a trustee in bankruptcy or creditors or others pursuant to a final judgment by a court of competent jurisdiction that such P6402-1058\922765 v4.doc 33 payment constitutes a voidable preference to such Owner within the meaning of any applicable bankruptcy laws, then the Trustee shall notify the Insurer or its designee of such fact by telephone or telegraphic notice, confirmed in writing by registered or certified mail. (d) The Trustee is hereby irrevocably designated, appointed, directed and authorized to act as attorney-in-fact for Owners as follows: (1) If and to the extent there is a deficiency in amounts required to pay interest on the Bonds, the Trustee shall (a) execute and deliver to the Insurance Paying Agent, in form satisfactory to the Insurance Paying Agent, an instrument appointing the Insurer as agent for such Owners in any legal proceeding related to the payment of such interest and an assignment to the Insurer of the claims for interest to which such deficiency relates and which are paid by the Insurer, (b) receive as designee of the respective Owners (and not as Trustee) in accordance with the tenor of the Insurance Policy payment from the Insurance Paying Agent with respect to the claims for interest so assigned, and (c) disburse the same to such respective Owners; and (2) If and to the extent of a deficiency in amounts required to pay principal of the Bonds, the Trustee shall (a) execute and deliver to the Insurance Paying Agent in form satisfactory to the Insurance Paying Agent an instrument appointing the Insurer as agent for such Owner in any legal proceeding relating to the payment of such principal and an assignment to the Insurer of any of the Bonds surrendered to the Insurance Paying Agent of so much of the principal amount thereof as has not previously been paid or for which moneys are not held by ihe Trustee and availab]e for such payment (but such assignment shall be delivered only if payment from the Insurance Paying Agent is received), (b) receive as designee of the respective Owners (and not as Trustee) in accordance with the tenor of the Insurance Policy payment therefor from the Insurance Paying Agent, and (c) disburse the same to such Owners. (e) Payments with respect to claims for interest on and principal of Bonds disbursed by the Trustee from proceeds of the Insurance Policy shall not be considered to discharge the obligation of the Authority with respect to such Bonds, and the Insurer shall become the owner of such unpaid Bonds and claims in accordance with the tenor of the assignment made to it under the provisions of this subsection or otherwise. (f� Irrespective of whether any such assignment is executed and delivered, the Authority and the Trustee hereby agree for the benefit of the Insurer that, (1) They recognize that to the extent the Insurer makes payments, directly or indirectly (as by paying through the Trustee), on account of principal of or interest on the Bonds, the Insurer will be subrogated to the rights of such Owners to receive the amount of such principal and interest from the Authority, with interest therefrom as provided and solely from the sources stated in this Indenture and the Bonds; and (2) They will accordingly pay to the Insurer the amount of such principal and interest (including principal and interest recovered under subparagraph (ii) of thc first paragraph of the Insurance Policy, which principal and interest shall be deemed past due and not to have been paid), with interest thereon as provided in this Indenture and the Bonds, but P6402- l OS8\922765v4.doc 34 only from the sources and in the manner provided herein for the payment of principal of and interest on the Bonds to Owners, and will otherwise treat the Insurer as the owner of such rights to the amount of such principal and interest. (g) In connection with the issuance of Parity Debt by the Agency, the Authority shall cause the Agency to deliver to the Insurer a copy of the disclosure document, if any, circulated with respect to such Parity Debt. (h) Copies of any amendments made to the documents executed in connection with the issuance of the Bonds which are consented to by the Insurer shall be sent by the Authority to S&P. (i) The Insurer shall receive notice from the Authority of the resignation or removal of the Trustee and the appointment of a successor thereto. (j) The Authority shall cause the Agency, on an annual basis, to furnish the Insurer with copies of the Agency's audited financial statements and annual budget. (k) The Insurer shall receive notice from the Authority at least fifteen Business Days prior to any advance refunding of any Outstanding Bonds. (1) Excepting the bond purchase agreement relating to the sale of the Bonds to the Underwriter and the lawful public trading of the Bonds in the securities market, the Authority shall not enter into any agreement nor shall it consent to or participate in any arrangement pursuant to which Bonds are tendered or purchased for any purpose other than the redemption and cancellation or legal defeasance of such Bonds without the prior written consent of the Insurer. Section 9.2. Notices. As long as the Insurance Policy is in full force and effect, the Trustee shall provide the Insurer a copy of any notice that is required to be given to an Owner pursuant to this Indenture. All notices required to be given to the Insurer under the Indenture shall be in writing and shall be sent by registered or certified mail addressed to MB1A Insurance Corporation, 113 King Street, Armonk, New York 10504, Attention: Insured Portfolio Management. Section 9.3. Control of Remedies upon Default. Notwithstanding the provisions of Sections 8.2 and 8.4, as long as the Insurance Policy is in full force and effect, upon the occurrence and continuance of an Event of Default, the Insurer, acting alone, shall be entitled to control and direct the enforcement of all rights and remedies granted to the Owners or the Trustee for the benefit of the Owners under this Indenture; provided, however, the Trustee shall not be liable for any action or inaction taken at the direction of the Insurer. Any acceleration of the Bonds or annulment thereof pursuant to Section 8.2 shall be subject to the prior written consent of the Insurer. No waiver of a default shall be effective without the written consent of the Insurer. Section 9.4. Susnension or Termination of RiQhts of Insurer. All rights of the Insurer to direct or consent to actions of the Authority, the Agency, the Trustee or the Owners under this Indenture or under the Loan Agreement shall be suspended during any period in which P6402- ] 058\922765v4.doc 35 the Insurer is in default in its payment obligations under the Insurance Policy (except to the extent of amounts previously paid by the Insurer and due and owing to the Insurer) and shall be of no force or effect in the event the Insurance Policy is no longer in effect or the Insurer asserts that the Insurance Policy is not in effect. ARTICLE X BOOK-ENTRY SYSTEM Section 10.1. Book-Entry Svstem; Limited Obli�ation of Authoritv. The Bonds shall be initially delivered in the form of a separate single fully registered Bond (which may be typewritten) for each of the maturities of the Bonds. Upon initial delivery, the ownership of each such Bond shall be registered in the registration books kept by the Trustee in the name of the Nominee as nominee of the Depository. Except as provided in Section 10.3, all of the Outstanding Bonds shall be registered in the registration books kept by the Trustee in the name of the Nominee. With respect to Bonds registered in the registration books kept by the Trustee in the name of the Nominee, the Authority and the Trustee shall have no responsibility or obligation to any Participant or to any person on behalf of which such a Participant holds an interest in the Bonds. Without limiting the immediately preceding sentence, the Authority and the Trustee shall have no responsibility or obligation with respect to (i) the accuracy of the records 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 notice of redemption, (iii) the selection by the Depository and its Pariicipants of the beneficial 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 person, other than an Owner as shown in the registration books kept by the Trustee, of any amount with respect [o principal of, premium, if any, or interest due with respect to the Bonds. The Authority and the Trustee may treat and consider the person in whose name each Bond is registered in the registration books kept by the Trustee as the holder and absolute owner of such Bond for the purpose of payment of principal, premium, if any, and interest with respect to such Bond, for the purpose of giving notices of redemption and other matters with respect to such Bond, for the purpose of registering transfers with respect to such Bond, and for all other purposes whatsoever. The Trustee shall pay ail principal of, premium, if any, and interest due with respect to the Bonds only to or upon the order of the respective Owners, as shown in the registration books kept by the Trustee, or their respective attorneys duly authorized in writing, and all such payments shall be valid and effective to satisfy and discharge fully the Authority's obligations with respect to payment of the principal, premium, if any, and interest due with respect to the 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 obligation of the Authority to make payments of principal, premium, if any, and interest pursuant to this Indenture. Upon delivery by the Depository to the Trustee and the Authority of written notice to the effect that the Depository has determined to substitute a new nominee in place of the Nominee, and subject to the provisions herein with respect to Record Dates, the word Nominee in this Indenture shall refer to such new nominee of the Depository. P6402-1058�922765v4.doc 36 Section 10.2. Representation Letter. In order to qualify ihe Bonds for the Depository's book-entry system, the Authority has heretofore executed and delivered to such Depository the Representation Letter. The execution and delivery of a Representation Letter shall not in any way impose upon the Authority 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 the Representation Letter io ihe extent that such action is not inconsistent with this Indenture. In addition to the execution and delivery of the Representation Letter, the officers of the Authority are hereby authorized to take any other actions, not inconsistent with this Indenture, to qualify the Bonds for the Depository's book-entry program. Section 10.3. Transfers Outside Book-Entry Svstem. In the event (a) the Depository determines not to continue to act as securities depository for the Bonds, or (b) the Authority determines that the Depository shall no longer so act, then the Authority will discontinue the book-entry system with the Depository. If the Authority fails to identify another qualified securities depository to replace the Depository, then the Bonds so designated shall no longer be restricted to being registered in the registration books kept by the Trustee in the name of the Nominee, but shall be registered in whatever name or names persons transferring or exchanging Bonds shall designate, in accordance with the provisions of Section 2.9. Section 10.4. Pavments to the Nominee. Notwithstanding any other provisions of this Indenture to the contrary, so long as any Bond is registered in the name of the Nominee, all 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, respectively, as provided in the Representation Letter or as otherwise instructed by the Depository. Section 10.5. Initial Deoository 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 XI MISCELLANEOUS Section 11.1. Limited Liabilitv of Authoritv. Notwithstanding anything in this Indenture contained, the Authority shall not be required to advance any moneys derived from any source of income other than the Revenues for the payment of the principal of or interest on the Bonds, or any premiums upon the redemption thereof, or for the performance of any covenants herein contained (except to the extent any such covenants are expressly payable hereunder from the Revenues or otherwise from amounts payable under the Loan Agreement). The Authority may, however, advance funds for any such purpose, provided that such funds are derived from a source legally available for such purpose and may be used by the Authority for such purpose without incurring indebtedness. The Bonds shall be revenue bonds, payable exclusively from the Revenues and other funds as in this lndenture provided. The general fund of the Authority is not liable, and the credit of the Authority is not pledged, for the payment of the interest and premium, if any, on or P6402-1058\922765v4.doc 37 principal of the Bonds. The Owners of the Bonds shall never have the right to compel the forfeiture of any property of the Authority. The principal of and interest on the Bonds, and any premiums upon the redemption of any thereof, shall not be a legal or equitable pledge, charge, lien or encumbrance upon any property of the Authority or upon any of its income, receipts or revenues except the Revenues and other funds pledged to the payment thereof as in this Indenture provided. Section 1 l.2. Bene�ts of Indenture Limited to Parties. Nothing in this Indenture, expressed or implied, is intended to give to any person other than the Authority, the Trustee, the Agency, the Insurer, and the Owners of the Bonds, any right, remedy or claim under or by reason of this Indenture. Any covenants, stipulations, promises or agreements in this Indenture contained by and on behalf of the Authority shall be for the sole and exclusive benefit of the Trustee, the Agency, the Insurer, and the Owners of the Bonds. Section 11.3. DischarQe of Indenture. If the Authority shall pay and discharge any or all of the Outstanding Bonds in any one or more of the following ways: (a) By well and truly paying or causing to be paid the principal of and interest and premium, if any, on such Bonds, as and when the same become due and payable; (b) By irrevocably depositing with the Trustee, in trust, at or before maturity, money which, together with the available amounts then on deposit in the funds and accounts established with the Trustee pursuant to this Indenture and the Loan Agreement, is fully sufficient to pay such Bonds, including all principal, interest and premiums, if any; or (c) By irrevocably depositing with the Trustee or any other fiduciary, in trust, non-callable Defeasance Obligations in such amount as an Independent Accountant shall determine will, together with the interest to accrue thereon and available moneys then on deposit in the funds and accounts established with the Trustee pursuant to this Indenture and the Loan Agreement, be fully sufficient to pay and discharge the indebtedness on such Bonds (including all principal, interest and redemption premiums) at or before their respective maturity dates; and if such Bonds are to be redeemed prior to the maturity thereof notice of such redemption shal] have been sent pursuant to Section 2.3 or provision satisfactory to the Trustee shall have been made for the sending of such notice, then, at the Request of the Authority, and notwithstanding that any of such Bonds shall not have been surrendered for payment, the pledge of the Revenues and other funds provided for in this Indenture with respect to such Bonds, and all other pecuniary obligations of the Authority under this Indenture with respect to all such Bonds, shall cease and terminate, except only the obligation of the Authority to pay or cause to be paid to the Owners of such Bonds not so surrendered and paid all sums due thereon from amounts set aside for such pucpose as aforesaid, and all expenses and costs of the Trustee. Any funds held by the Trustee, following any payment or discharge of the Outstanding Bonds pursuant to this Section 11.3 and the payment of the Trustee's and the Insurer's expenses and costs, shall be paid over to the Authority. In the case of a defeasance of all or a portion of the Bonds pursuant to clause (c) above, the Authority shall deliver to the Insurer the following: (i) a written opinion of Bond Counsel as to the discharge and satisfaction of the lien of this Indenture with respect to such Bonds (which P6402-1058\922765 v4.doc 3 g opinion may rely on the verification of an Independent Accountant of the amounts which shall be sufficient to discharge and satisfaction of the lien of this Indenture with respect to such Bonds); and (ii) with respect to any advance refunding (within the meaning of the Code), a written notice at least 15 Business Days before such defeasance, and a report prepared by the Independent Accountant verifying the amounts sufficient to discharge and satisfaction of the lien of this Indenture with respect to such Bonds. Section 11.4. Successor Deemed Included in All References to Predecessor. Whenever in this Indenture or any Supplemental Indenture the Authority is named or referred to, such reference shall be deemed to include the successor to the powers, duties and functions, with respect to the management, administration and control of the affairs of the Authority, thai are presently vested in the Authority, and all the covenants, agreements and provisions contained in this Indenture by or on behalf of the Authority shall bind and inure to the benefit of its successors whether so expressed or not. Section ] 1.5. Content of Certificates. Every Certificate of the Authority with respect to compliance with a condition or covenant provided for in this Indenture shall include (i) a statement that the person or persons making or giving such Certificate have read such covenant or condition and the definitions herein relating thereto; (ii) a brief statement as to the nature and scope of the examination or investigation upon which the statements or opinions contained in such Certificate are based; (iii) a statement that, in the opinion of the signers, they have made or caused to be made such examination or investigation as is necessary to enable them to express an informed opinion as to whether or not such covenant or condition has been complied with; and (iv) a statement as to whether, in the opinion of the signers, such condition or covenant has been complied with. Any such certificate made or given by an officer of the Authority may be based, insofar as it relates to legal matters, upon a certificate or opinion of or representations by counsel, unless such officer knows that the certificate or opinion or representations with respect to the matters upon which his certificate may be based, as aforesaid, are erroneous, or in the exercise of reasonable care should have known that the same were erroneous. Any such certificate or opinion or representation made or given by counsel may be based, insofar as it relates to factual matiers, on information with respect to which is in the possession of the Authority, or upon the certificate or opinion of or representations by an officer or officers of the Authority, unless such counsel knows that the certificate or opinion or representations with respect to the matters upon which his certificate, opinion or representation may be based, as aforesaid, are erroneous. Section i 1.6. Execution of Documents bv Owners. Any request, consent or other instrument required by this Indenture to be signed and executed by Bond Owners may be in any number of concurrent writings of substantially similar tenor and may be signed or executed by such Bond Owners in person or by their agent or agents duly appointed in writing. Proof of the execution of any such request, consent or other instrument or of a writing appointing any such agent, shall be sufficient for any purpose of this Indenture and shall be conclusive in favor of the Trustee and of the Authority if made in the manner provided in this Section 11.6. P6402-1058�922765v4.doc 39 The fact and date of the execution by any person of any such request, consent or other instrument or writing may be proved by the affidavit of a witness of such execution or by the certificate of any notary public or other officer of any jurisdiction, authorized by the laws thereof to take acknowledgments of deeds, certifying that the person signing such request, consent or other instrument or writing acknowledged to him the execution thereof. The ownership of Bonds shall be proved by the Registration Books. Any request, consent or vote of the Owner of any Bond shall bind every future Owner of the same Bond and the Owner of any Bond issued in exchange therefor or in lieu thereof, in respect of anything done or suffered to be done by the Trustee or the Authority in pursuance of such request, consent or vote. In lieu of obtaining any demand, request, direction, consent or waiver in writing, the Trustee may call and hold a meeting of the Bond Owners upon such notice and in accordance with such rules and obligations as the Trustee considers fair and reasonable for the purpose of obtaining any such action. Section 11.7. Disaualified Bonds. In determining whether the Owners of the requisite aggregate principal amount of Bonds have concurred in any demand, request, direction, consent or waiver under this Indenture, Bonds which are owned or held by or for the account of the Agency or the Authority (but excluding Bonds held in any employees' retirement fund) shal] be disregarded and deemed not to be Outstanding for the purpose of any such determination, provided, however, only Bonds which a responsible officer of the Trustee actually knows to be so owned or held shall be disregarded. Section I 1.8. Waiver of Personal Liabilitv. No officer, agent or employee of the Authority shall be individually or personally liable for the payment of the interest on or principal of the Bonds; but nothing herein contained shall relieve any such officer, agent or employee from the performance of any official duty provided by law. Section 11.9. PaRial Invaliditv. If any one or more of the covenants or agreements, or portions thereof, provided in this Indenture on the part of the Authority (or of the Trustee) to be performed should be contrary to law, then such covenant or covenants, such agreement or agreements, or such portions thereof, shall be null and void and shall be deemed separable from the remaining covenants and agreements or portions thereof and shall in no way affect the validity of this Indenture or of the Bonds; but the Bond Owners shall retain all rights and benefits accorded to them under the Bond Law or any other applicable provisions of law. The Authority hereby declares that it would have entered into this Indenture and each and every other section, paragraph, subdivision, sentence, clause and phrase hereof and would have authorized the issuance of the Bonds pursuant hereto irrespective of the fact that any one or more sections, paragraphs, subdivisions, sentences, clauses or phrases of this Indenture or the application thereof to any person or circumstance may be held to be unconstitutional, unenforceable or invalid. Scction 1 l.lU. Destruction of Cancelled Bonds. Whenever in this Indenture provision is made for the surrender to the Trustee of any Bonds which have been paid or cancelled pursuant to the provisions of this Indenture, the Trustee shall, as permitted by law, destroy such cancelled Bonds and, upon Request of the Authority, provide to the Authority a certificate of destruction duly executed by the Trustee, and the Authority shall be entitled to rely P6402-1058\922765 v4. doc 4� upon any statemen[ of fact contained in such certificate with respect to the destruction of any such Bonds therein referred to; provided, however, that the Authority shall reimburse the Trustee for the Trustee's costs incurred in connection with the microfilming or the required permanent recording, if any, related thereto. Section 11.1 1. Funds and Accounts. Any fund or account required by this Indenture to be established and maintained by the Authority or the Trustee may be established and maintained in the accounting records of the Authority or the Trustee, as the case may be, either as a fund or an account, and may, for the purpose of such records, any audits thereof and any reports or statements with respect thereto, be treated either as a fund or as an account. All such records with respect to all such funds and accounts held by the Authority shall at all times be maintained in accordance with generally accepted accounting principles and all such records with respect to all such funds and accounts held by the Trustee shall be at all times maintained in accordance with corporate trust industry practices. Any fund or account required by this Indenture to be established and maintained by the Authority or the Trustee may be established and maintained in the form of multiple funds, accounts or sub-accounts therein. Section I 1.12. Pavment on Business Days. Whenever in this Indenture any amount is required to be paid on a day which is not a Business Day, such payment shall be required to be made on the Business Day immediately following such day, provided that interest shall not accrue from and after such day. Section 11.13. Notices. Any notice, request, complaint, demand or other communication under this Indenture shall be given by first class mail or personal delivery to the party entitled thereto at its address set forth below, or by telecopy or other form of telecommunication, confirmed by telephone at its number set forth below. Notice shall be effective either (i) upon transmission by telecopy or other form of telecommunication, (ii) 48 hours after deposit in the United States mail, postage prepaid, or (iii) in the case of personal delivery to any person, upon actual receipt. The Authority, the Agency or the Trustee may, by written notice to the other parties, from time to time modify the address or number to which communications are to be given hereunder. If to the Authority: Palm Desert Financing Authority 73-510 Fred Waring Drive Palm Desert, California 92260 Attention: Chief Administrative Officer Facsimile: (760) 340-0574 If to the Agency: Palm Desert Redevelopment Agency 73-510 Fred Waring Drive Palm Desert, California 92260 Attention: Executive Director Facsimile: (760) 340-0574 r P6402-1058\922765v4.doc 41 If to the Trustee: Wells Fargo Bank, National Association 707 Wilshire Boulevard, 17th Floor Los Angeles, California 90017 Attention: Corporate Trust Department Facsimile: (213) 614-3355 If to the Insurer: MBIA Insurance Corporation 113 King Street Armonk, New York 10504 Attention: Insured Portfolio Management Group Facsimile: (914) 765-3161 The Authority, the Agency, the Trustee and the Insurer may designate any further or different addresses to which subsequent notices, certificates or other communications shall be sent. Notices to the Insurer shall be also governed by Section 9.2. Section 11.14. Unclaimed Monevs. Anything in this Indenture to the contrary notwithstanding, any moneys held by the Trustee in trust for the payment and discharge of any of the Bonds or the interest thereon which remain unclaimed for two years after the date when such Bonds or the interest thereon have become due and payable, either at their stated maturity dates or by call for earlier redemption, if such moneys were held by the Trustee at such date, or for two years after the date of deposit of such moneys if deposited with the Trustee after said date when such Bonds or the interest thereon become due and payable, shall, at the Request of the Authority, be repaid by the Trustee to the Authority, as its absolute property and free from trust, and the Trustee shal] thereupon be released and discharged with respect thereto and the Owners shall look only to the Authority for the payment of such Bonds; provided, however, that before making any such payment to the Authority, the Trustee shall, at the Request and at the expense of the Authority, cause to be mailed to the Owners of all such Bonds, at their respective addresses appearing on the Registration Books, a notice that said moneys remain unclaimed and that, after a date named in said notice, which date shall not be less than 30 days after the date of mailing of such notice, the balance of such moneys then unclaimed will be returned to the Authority. Section 11.15. GoverninQ Law. This Agreement shall be construed and governed in accordance with the laws of the State of California. P(Ki02-1058\922765v4.doc 42 IN WITNESS WHEREOF, the PALM DESERT FINANCING AUT'HORITY has caused this Indenture to be signed in its name by its duly authorized officer and WELLS FARGO BANK, NATIONAL ASSOCIATION, in token of its acceptance of the trust created hereunder, has caused this Indenture to be signed in its corporate name by its officer identified below, all as of the day and year first above written. PALM DESERT FINANCING AUTHORITY : Chief Administrative Officer WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee : Authorized Officer PG402-1058\922765v4.doc 43 EXHIBIT A (FORM OF BOND] Unless this certificate is presented by an authorized representative of The Depository Trust Company, a IVew York corporation ("DTC"}, to the Authority or its agent for registration of transfer, exchange, or payment, and any certificate issued is registered in the name of Cede & Co. or in such other name as is requested by an authorized representative of DTC (and any payment is made to Cede & Co. or to such other entity as is requested by an authorized representative of DTC), ANY TRANSFER, PLEDGE, OR OTHER USE HEREOF FOR VALLTE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL inasmuch as the registered owner hereof, Cede & Co., has an interest herein. No. � PALM DESERT FINANCING AUTHORITY TAX ALLOCATION REFUNDING REVENUE BOND (PROJECT AREA NO. 1, AS AMENDED) 2007 SERIES A INTEREST RATE MATURITY DATE ORIGINAL ISSUE DATE CUSIP ., REGISTERED OWNER: Apri 1 1, 20 CEDE & CO. PRINCIPAL AMOUNT: January _, 2007 The PALM DESERT FINANCING AUTHORITY, a joint powers authority organized and existing under the laws of the State of California (the "Authority"), for value received, hereby promises to pay (but only out of the Revenues, as defined in the Indenture hereinafter referred to, and certain other moneys) to the Registered Owner identified above or regis[ered assigns (the "Registered Owner"), on the Maturity Date identified above or any earlier redemption date, the Principal Amount identified above in lawful money of the United States of America; and to pay interest thereon at the Rate of Interest identified above in like money from the Interest Payment Date (as hereinafter defined) next preceding the date of authentication of this Series 2007A Bond (unless this Series 2007A Bond is authenticated on or before an Interest Payment Date and after the fifteenth calendar day of the month preceding such Interest Payment Date, in which event it shall bear interest from such Interest Payment Date, or unless this Series 2007A Bond is authenticated on or prior to September 15, 2007, in which event it shall bear interest from the Original Issue Date identified above; provided, however, that if, at the time of authentication of this Series 2007A Bond, interest is in default on [his Series 2007A Bond, this Series 2007A Bond shall bear interest from the Interest Payment Date to which interest hereon has previously been paid or made available for payment), payable semiannually on April 1 and P6402- ] 058\922765v4.doc f�-1 October 1 in each year, commencing October 1, 2007 (the "Interest Payment Dates") until payment of such Principal Amount in full. The Principal Amount hereof 15 payable upon presentation of this Series 2007A Bond upon maturity or earlier redemption at the corporate trust office of Wells Fargo Bank, National Association (the "Trustee") in Los Angeles, California, or such other location as the Trustee shall designate (the "Trust Office"). Interest hereon is payable by check or draft of the Trustee mailed by first class mail on each Interest Payment Date to the Registered Owner hereof at the address of the Registered Owner as it appears on the registration books of the Trustee as of the fifteenth calendar day of the month preceding such Interest Payment Date (except in the case of a Registered Owner of at least $1,000,000 in aggregate principal amount, such payment may, at such Registered Owner's option, be made by wire transfer of immediately available funds in accordance with written instructions provided by such Registered Owner prior to the fifteenth calendar day of the month preceding such Interest Payment Date). This Series 2007A Bond is one of a duly authorized issue of bonds of the Authority designaced the Palm Desert Financing Authority, Tax Allocation Refunding Revenue Bonds (Project Area No. l, As Amended), 2007 Series A(the "Bonds" or the "Bonds"), limited in principal amount to $ . The Bonds are secured by an Indenture of Trust, dated as of January 1, 2007 (the "Indenture"), by and between the Authority and the Trustee. Unless the context clearly requires otherwise, capitalized terms used but not defined herein have the meanings ascribed to them in the Indenture. Reference is hereby made to the Indenture and all indentures supplemental thereto for a description of the rights thereunder of the owners of the Bonds, of the nature and extent of the Revenues, of the rights, duties and immunities of the Trustee and of the rights and obligations of the Authority thereunder; and all of the terms of the Indenture are hereby incorporated herein and constitute a contract between the Authority and the Registered Owner hereof, and to all of the provisions of which Indenture the Registered Owner hereof, by acceptance hereof, assents and agrees. The Bonds are authorized to be issued pursuant to the provisions of the Marks-Roos Local Bond Pooling Act of 1985, constituting Article 4, Chapter 5, Division 7, Title 1 of the Government Code of the State of California (the "Act"). The Bonds are special obligations of the Authority and, as and to the extent set forth in the Indenture, are payable solely from and secured by a first lien on and pledge of the Revenues and certain other moneys and securities held by the Trustee as provided in the Indenture. All of the Bonds are equally secured by a pledge of, and charge and lien upon, all of the Revenues and such other moneys and securities, and the Revenues and such other moneys and securities constitute a trust fund for the security and payment of the principal of and interest on the Bonds. The full faith and credit of the Authority is not pledged for the payment of the principal of or interest or premium (if any) on the Bonds. The Bonds are not secured by a legal or equitable pledge of, or charge, lien or encumbrance upon, any of the property of the Authority or any of its income or receipts, except the Revenues and such other moneys and securities as provided in the Indenture. The Bonds have been issued for the purpose of making a loan (the "Series 2007A Loan") to the Palm Desert Redevelopment Agency (the "Agency") to finance certain public capital improvements with respect to a redevelopment project known and designated as Projcct Area No. 1, As Amended. The Series 2007A Loan has been made by the Authority to the Agency P6402-1058\92276Sv4.doc A-2 pursuant to a Project Area No. 1, as Amended, Loan Agreement dated as of January 1, 2007 (the "Loan Agreement"), by and among the Agency, the Authority and the Trustee. The Bonds maturing on or after April 1, 20_ are subject to redemption prior to their respective maturity dates as a whole, or in par[ among maturities as designated by the Authority and by lot within a maturity, from prepayments of the Series 2007A Loan made at the option of the Agency pursuant to the Loan Agreement, on any Interest Payment Date on or after April 1, 20_, at a redemption price equal to [100] percent of the principal amount of Bonds to be redeemed, plus accrued interest thereon to the date of redemption, without premium. The Series 2007A Term Bonds maturing on April 1, 20_ are also subject to mandatory sinking fund redemption by lot, on April 1, 20_, at a redemption price equal to the principal amount thereof to be redeemed, without premium, plus accrued interest to the date of redemption, in the aggregate respective principal amounts set forth in the Indenture; provided, however, that in lieu of redemption thereof, such Bonds may be purchased by the Agency pursuant to the Loan Agreement. The Trustee on behalf and at the expense of the Authority shall send by first class mail (or such other means acceptable to such registered owner and institutions) notice of any redemption to the respective owners of any Bonds designated for redemption, at their respective addresses appearing on the registration books maintained by the Trustee, to the Securities Depositories and to one or more Information Services, at least 30 but not more than 60 days prior to the redemption date; provided, however, that neither failure to receive any such notice so sent nor any defect therein shall affect the validity of the proceedings for the redemption of such Bonds or the cessation of the accrual of interest thereon. Such notice shall state the date of the notice, the redemption date, the redemption place and the redemption price and shall designate the CUSIP numbers, the serial numbers of each maturity or maturities (except that if the event of redemption is of all of the Bonds of such maturity or maturities in whole, the Trustee shall designate such maturities or the maturity in whole without referencing each individual number) of the Bonds to be redeemed, and shall require that such Bonds be then surrendered at the Trust Office for redemption at the redemption price, giving notice also that further interest on such Bonds will not accrue from and after the redemption date. Subject to the limitations and upon payment of the charges, if any, provided in the Indenture, this Series 2007A Bond may be exchanged at the Trust Office for a like aggregate principal amount and maturi[y of fully registered Bonds of other authorized denominations. This Series 2007A Bond is transferable by the Registered Owner hereof, in person or by the Registered Owner's attorney duly authorized in writing, at the Trust Office, but only in the manner, subject to the limitations and upon payment of the charges provided in the Indenture, and upon surrender and cancellation of this Series 2007A Bond. Upon such transfer a new fully registered Series 2007A Bond or Bonds, of authorized denomination or denominations, for the same aggregate principal amount and of the same maturity will be issued to the transferee in exchange therefor. The Trustee shall not be required to register the transfer or exchange of any Series 2007A Bond during the 15-day period preceding the selection of Bonds for redemption or any Series 2007A Bond selected for redemption. The Authority and the Trustee may treat the PG402-1058\922765v4.doc fi-3 Registered Owner hereof as the absolute owner hereof for all purposes, and the Authority and the Trustee shall not be affected by any notice to the contrary. The Indenture and the rights and obligations of the Authority and of the owners of the Bonds and of the Trustee may be modified or amended from time to time and at any time in the manner, to the extent, and upon the terms provided in the Indenture; provided that no such modification or amendment shall (a) extend the maturity of or reduce the interest rate on any Series 2007A Bond or otherwise alter or impair the obligation of the Authority to pay the principal, interest or premiums at [he time and place and at the rate and in the currency provided therein of any Series 2007A Bond without the express written consent of the Owner of such Series 2007A Bond, (b) reduce the percentage of Bonds required for the written consent to any such amendment or modification, or (c) without its written consent thereto, modify any of the rights or obligations of the Trustee, all as more fully set forth in the Indenture. It is hereby certified that all things, conditions and acts required to exist, to have happened and to have been performed precedent to and in the issuance of this Series 2007A Bond do exist, have happened and have been performed in due time, form and manner as required by the Constitution and statutes of the State of California and by the Act and the amount of this Series 2007A Bond, together with all other indebtedness of the Authority, does not exceed any limit prescribed by the Constitution or statutes of the State of California or by the Act. This Series 2007A Bond shall not be entitled to any benefit under the Indenture, or become valid or obligatory for any purpose, until the certificate of authentication hereon shall have been signed by the Trustee. P6402-1058\922765v4.doc A-4 IN WITNESS WHEREOF, the Authority has caused this Series 2007A Bond to be executed in its name and on its behalf by the manual or facsimile signatures of its President and Secretary all as of the Original Issue Date identified above. PALM DESERT FINANCING AUTHORITY : President Attest: Secretary STATEMENT OF INSURANCE MBIA Insurance Corporation (the "Insurer") has issued a policy containing the following provisions, such policy being on file at Wells Fargo Bank National Association, Los Angeles, California. The Insurer, in consideration of the payment of the premium and subject to the terms of this policy, hereby unconditionally and irrevocably guarantees to any owner, as hereinafter defined, of the following described obligations, the full and complete payment required to be made by or on behalf of the Authority to Wells Fargo Bank National Association, Los Angeles, California or its successor (the "Paying Agent") of an amount equal to (i) the principal of (either at the stated maturity or by any advancement of maturity pursuant to a mandatory sinking fund payment) and interest on, the Obligations (as that term is defined below) as such payments shall become due but shall not be so paid (except that in the event of any acceleration of the due date of such principal by reason of mandatory or optional redemption or acceleration resulting from default or otherwise, other than any advancement of maturity pursuant to a mandatory sinking fund payment, the payments guaranteed hereby shall be made in such amounts and at such times as such payments of principal would have been due had there not been any such acceleration); and (ii) the reimbursement of any such payment which is subsequently recovered from any owner pursuant to a final judgment by a court of competent jurisdiction that such payment constitutes an avoidable preference to such owner within the meaning of any applicable bankruptcy law. The amounts referred to in clauses (i) and (ii) of the preceding sentence shall be referred to herein collectively as the "Insured Amounts." "Obligations" shall mean: P6402-1058\922765 v4.doc A-$ $ PALM DESERT FINANCING AUTHORITY TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED) 2007 SERIES A Upon receipt of telephonic or telegraphic notice, such notice subsequently confirmed in writing by registered or certified mail, or upon receipt of written notice by registered or certified mail, by the Insurer from the Paying Agent or any owner of an Obligation the payment of an Insured Amount for which is then due, that such required payment has not been made, the Insurer on the due date of such payment or within one business day after receipt of notice of such nonpayment, whichever is later, will make a deposit of funds, in an account with U.S. Bank National Association, in New York, New York, or its successor, sufficient for the payment of any such Insured Amounts which are then due. Upon presentment and surrender of such Obligations or presentment of such other proof of ownership of the Obligations, together wiih any appropriate instruments of assignment to evidence the assignment of the Insured Amounts due on the Obligations as are paid by the Insurer, and appropriate instruments to effect the appointment of the Insurer as agent for such owners of the Obligations in any legal proceeding related to payment of Insured Amounts on the Obligations, such instruments being in a form satisfactory to U.S. Bank National Association, U.S. Bank National Association shall disburse to such owners or the Paying Agent payment of the Insured Amounts due on such Obligations, less any amount held by the Paying Agent for the payment of such Insured Amounts and legally available therefor. This policy does not insure against loss of any prepayment premium which may at any time be payable with respect to any Obligation. As used herein, the term "owner" shall mean the registered owner of any Obligation as indicated in the books maintained by the Paying Agent, the Authority, or any designee of the Authority for such purpose. The term owner shall not include the Authority or any party whose agreement with the Authority constitutes the underlying security for the Obligations. Any service of process on the Insurer may be made to the Insurer at its offices located at 113 King Street, Armonk, New York 10504 and such service of process shall be valid and binding. This policy is non-cancellable for any reason. The premium on this policy is not refundable for any reason including the payment prior to maturity of the Obligations. In the event the Insurer were to become insolvent, any claims arising under a policy of financial guaranty insurance are excluded from coverage by the California lnsurance Guaranty Association, established pursuant to Article 14.2 (commencing with Section 1063) of Chapter 1 of Part 2 of Division 1 of the California lnsurance Code. MBIA INSURANCE CORPORATION --------------------- --------------------- PEr302-1058\922765v4.doc A-6 [FORM OF TRUSTEE'S CERTIFICATE OF AUTI-�NTICATION] This is one of the Bonds described in the within-mentioned Indenture and registered on the Bond Registration Books. WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee Date: : Authorized Signatory [FORM OF ASSIGNMENT] For value received the undersigned do(es) hereby sell, assign and transfer unto whose tax identification number is _, the within-mentioned registered Series 2007A Bond and hereby irrevocably constitute(s) and appoint(s) attorney to transfer the same on the books of the Trustee with full power of substitution in the premises. Dated: Signature guaranteed: NOTE: The signature(s) on this Assignment must correspond with the name(s) as written on the face of the within Series 2007A Bond in every particular without alteration or enlargement or any change whatsoever. NOTE: Signature(s) must be guaranteed by a member of an institution which is a participant in the Securities Transfer Agent Medallion Program (STAMP) or other similar program. P6402-1058\922765v4.doc A-% Proiect Area No. 1, As Amended, Loan A�reement with reference to Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) 2007 Series A P6d112-II)SR'�)?�1176�5 doc RWG I)RAI T. I 1�220Ub TABLE OF CONTENTS Pa�e ARTICLE I DEFINITIONS ........................................................................................................... 2 Section1.1. Definitions .................................................................................................... 2 Section 1.2. Rules of Construction . ................................................................................. 5 ARTICLE II THE SERIES 2007A LOAN; APPLICATION OF LOAN PROCEEDS; PARITY DEBT................................................................................................................ 6 Section 2.1. Authorization . .............................................................................................. 6 Section 2.2. Disbursement and Application of Loan Proceeds ........................................ 6 Section 2.3. Repayment of Series 2007A Loan . .............................................................. 6 Section 2.4. Optional Prepayment . .................................................................................. 7 Section 2.5. Reserve Fund . .............................................................................................. 7 Section 2.6. Costs of Issuance Fund . ............................................................................... 9 Section2.7. Project Fund ................................................................................................. 9 Section2.8. Parity Debt . ................................................................................................ 10 Section 2.9. Issuance of Subordinate Debt . ................................................................... 10 Section 2.10. Validity of Series 2007A Loan . ................................................................. 11 ARTICLE III PLEDGE AND APPLICATION OF TAX REVENUES ...................................... 11 Section 3.1. Pledge of Tax Revenues ............................................................................. 11 Section 3.2. Special Fund; Deposit of Tax Revenues .................................................... 11 Section 3.3. Transfer of Tax Revenues From Special Fund . ......................................... 11 Section 3.4. Investment of Moneys; Valuation of Investments . .................................... 12 ARTICLE IV OTHER COVENANTS OF THE AGENCY ........................................................ l3 Section 4.1. Punctual Payment; Extension of Payments ................................................ 13 Section 4.2. Limitation on Additional Indebtedness ...................................................... 13 Section 4.3. Payment of Claims ..................................................................................... 13 Section 4.4. Books and Accounts; Financial Statements ............................................... 13 Section 4.5. Protection of Security and Rights . ............................................................. 14 Section 4.6. Paymenis of Taxes and Other Charges . ..................................................... 14 Section 4.7. Taxation of Leased Property ...................................................................... 14 Section 4.8. Disposition of Property . ............................................................................. 14 Section 4.9. Maintenance of Tax Revenues ................................................................... 14 Section 4.10. Payment of Expenses; lndemnification . .................................................... 15 Section 4.1 1. Tax Covenants . .......................................................................................... 15 Section 4.12. Redevelopment of Project Area . ................................................................ 16 Section 4.13. Low and Moderate Income Housing Fund . ............................................... 17 P��a��z- i nsR �>>a i ��,� s doc � Section 4.14. Annual Review of "Cax Revenues . ............................................................. 17 Section 4.15. Further Assurances ..................................................................................... 17 ARTICLE V EVENTS OF DEFAULT AND REMEDIES ......................................................... 17 Section 5.1. Events of Default and Acceleration of Maturities . .................................... 17 Section 5.2. Application of Funds Upon Default ........................................................... 18 Section5.3. No Waiver .................................................................................................. 19 Section 5.4. Agreement to Pay Attorneys' Fees and Expenses . .................................... 19 Section 5.5. Remedies Not Exclusive ............................................................................ 20 Section 5.6. Control of Remedies by Insurer ................................................................. 20 ARTICLE VI MISCELLANEOUS ..............................................................................................20 Section 6.1. Benefits Limited to Parties ......................................................................... 20 Section G.2. Successor Deemed Included in All References to Predecessor ................. 20 Section 6.3. Discharge of Loan Agreement ................................................................... 20 Section6.4. Amendment ................................................................................................ 21 Section 6.5. Waiver of Personal Liability ...................................................................... 21 Section 6.6. Payment on Business Days . ....................................................................... 21 Section6.7. Notices . ...................................................................................................... 22 Section 6.8. Rights of Insurer . ....................................................................................... 22 Section6.9. Surety Bond . .............................................................................................. 22 Section 6.10. Partial Invalidity ......................................................................................... 23 Section 6.11. Article and Section Headings and References . .......................................... 23 Section 6.12. Execution of Counterparts . ........................................................................ 23 Section 6.13. Governing Law . ......................................................................................... 23 Section 6.14. The Trustee . ............................................................................................... 23 EXHIBIT A- SCHEDULE OF SERIES 2007A LOAN PAYMENTS P6402-Illi�i y?4176�> du� I1 PROJECT AREA NO. l, AS AMENDED, LOAN AGREEMENT This Project Area No. 1, as Amended, Loan Agrecment (this "Loan Agreement") is made and entered into as of January 1, 2007, by and among the Palm Desert Redevelopment Agency, a public body, corporate and politic, duly organized and validly existing under the laws of the State of California (the "Agency"), the Palm Desert Financing Authority, a joint powers authority duly organized and validly existing under the laws of the State of California (the "Authority"), and Wells Fargo Bank, National Association, a national banking association duly organized and validly existing under the laws of the United States of America (the "Trustee"). Recitals A. The Agency is a redevelopment agency, a public body, corporate and politic, duly created, established and authorized to transact business and exercise its powers, all under and pursuant to the Redevelopment Law, and the powers of the Agency include the power to borrow money for any of its corporate purposes. B. A Redevelopment Plan, as amended, for the Project Area (as defined in thc below-mentioned Indenture) has been duly approved and adopted by the City. C. The Agency has determined to incur a loan (the "Series 2007A Loan") hereunder for the object and purpose of financing and refinancing public capital improvements of benefit to the Project Area, as provided herein, pursuant to the Redevelopment Law and the Marks-Roos Local Bond Pooling Act of 1985, Article 4, Chapter 5, Division 7, Title 1 of the Government Code of the State of California (the "Bond Law"). D. Concurrently with the execution and delivery of this Loan Agreement, the Authority has issued its $ Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended), 2007 Series A(the "Bonds"), pursuant to the Bond Law and an Indenture of Trust, dated as of January l, 2007 (the "Indenture"), by and between the Authority and the Trustee, for the purpose of providing funds to make the Series 2007A Loan to the Agency. E. The Authority has determined that there will be significant public benefits accruing from such borrowing, consisting of demonstrable savings in effective interest rates and financing costs associated with the issuance of the Bonds pursuant to the Bond Law. F. The Authority and the Agency have determined that all acts and proceedings required by law necessary to make this Loan Agreement, when executed by the Agency, the Trustee and the Authority, the valid, binding and legal obligation of the Agency and the Authority, and to constitute this Loan Agreement a valid and binding agreement for the uses and purposes herein set forth in accordance with its terms, have been done and taken, and the execution and delivery of this Loan Agreement have been in all respects duly authorized. NOW, THEIZEFORE, in consideration of the premises and the mutual agreements herein containcd, the parties hereto do hereby agree as follows: PGau2- ���ss•��?a � �6� � doc 1 ARTICLE I DEFINITIONS ��rti�n I.l. Definitions. Unless the context clearly requires or unless otherwise defined herein, the capitalized terms in this Loan Agreement shall have the respective meanings which such terms are given in the Indenture. In addition, the following terms defined in this Section 1.1 shall, for all purposes of this Loan Agreement, have the respective meanings herein specified. "Bonds" means the Palm Desert Financing Authority Tax Allocation Refunding Revenue Bonds (Project Area No. l, As Amended), 2007 Series A. "Costs of Issuance" means all expenses incurred in connection with the authorization, issuance, sale and delivery of the Bonds and the making of the Series 2007A Loan pursuant to the Loan Agreement, including but not limited to all compensation, fees and expenses (including but not limited to fees and expenses for legal counsel) of the Authority and any trustee, compensation to any financial advisors or underwriters and their counsel, legal fees and expenses, filing and recording costs, rating agency fees, credit enhancement fees (including insurance, surety bonds and letters of credit), costs of preparation and reproduction of documents and costs of printing. "Costs of Issuance Fund" means the fund by that name established and held by the Trustee pursuant to Section 2.6. "Escrow Fund" means the fund by that name established under the Escrow Agreement (Project Area No. l, as Amended), dated as of even date herewith, by and among the Authority, the Agency and Wells Fargo Bank, National Association, as escrow agent, relating to the refunding of the portion of the Authority's Tax Allocation Refunding Revenue Bonds (Project Area No. 1, As Amended) Series 1997, scheduled to mature on April 1, 2008 and thereafter through April 1, 2018. "Event of Default" means any of the events described in Section 5.1. "Financial Guarantv A�reement" means the Financial Guaranty Agreement, by and between the Agency and the Insurer relating to the issuance of the Surety Bond. "Indenture" means the Indenture of Trust, dated as of January 1, 2007, by and between the Authority and the Trustee, authorizing the issuance of the Bonds, as may from time to time be supplemented, modified or amended. "Independent Redevelopment Consultant" means any consultant or firm of such consultants appointed by or acceptable to the Agency, and who, or each of whom: (i) is judged by the Agency to have experience in matters relating to the collection of Tax Revenues or otherwise with respect to the financing of redevelopment projects; (ii) is in fact independent and not under the domination of the Agency; (iii) does not have any substantial interest, direct or indirect, with the Agency, other than as original purchaser of any obligations of the Agency; and I�o-tn2- � n;s•�)?a � 7Gvs doc 2 (iv) is not connected with the Agency as an officer or employee of the Agency, but who may be regularly retained to make reports to the Agency. "Loan A�reement" means this Project Area No. l, As Amended, Loan Agreement, as it may from time to time be amended, modified or supplemented. "Maximum Annual Debt Service" means, as of the date of calculation, the largest amount obtained by totaling, for the current or any future Bond Year, the sum of (i) the amount of interest payable on the Series 2007A Loan and all outstanding Parity Debt in such Bond Year, assuming that principal thereof is paid as scheduled and that any mandatory sinking fund payments are made as scheduled, and (ii) the amount of principal payable on the Series 2007A Loan and all outstanding Parity Debt in such Bond Year, including any principal required to be prepaid by operation of mandatory sinking fund payments. For purposes of such calculation, at the option of the Agency and specified to the Trustee in writing, there may be excluded a pro rata portion of each installment of principal of any Parity Debt, together with the interest to accrue thereon, in the event and to the extent that the proceeds of such Parity Debt are deposited in an escrow fund from which amounts may not be released to the Agency unless the Tax Revenues for the current Fiscal Year at least equal 115 percent of the amount of Maximum Annual Debt Scrvice. "1997 Loan" means the outstanding balance of the loan made by the Authority to the Agency pursuant to the 1997 Loan Agreement. "1997 Loan A�reement" means the Project Area No. 1, As Amended, Loan Agreement dated as of July 1, 1997, by and among the Agency, the Authority and First Trust of California, National Association, as succeeded by Wells Fargo Bank, National Association, as trustee. "Parity Debt" means the 1997 Loan, the 2002 Loan, the 2003 Loan, the 2004 Loan, the 2006 Loans and any other loans, bonds, notes, advances, or indebtedness payable from Tax Revenues on a parity with the Series 2007A Loan, issued or incuned pursuant to and in accordancc with the provisions of Section 2.8. "Paritv Debt Instrument" means the 1997 Loan Agreement, the 2002 Loan Agreement, the 2003 Loan Agreement, the 2004 Loan Agreement, the 2006 Loan Agreement and any other resolution, indenture of trust, trust agreement or other instrument authorizing the issuance of any Parity Debt. "Pass-Throu�h A�reements" means, collectively, the agreements entered into by the Agency on or prior to the date hereof pursuant to Section 33401 of the Redevelopment Law with (i) the County of Riverside, (ii) the Coachella Valley Mosquito Abatement District, (iii) the Coachella Valley Recreation and Park District, (iv) the Coachella Valley Water District, (v) the Desert Community College District, (vi) the Desert Sands Unified School District and (vii) the Riverside County Superintendent of Schools. "Plan Limitations" means the limitations contained or incorporated in ttie Redevelopment Plan on (i) the aggregate principal amount of bonded indebtedness payable from Tax Revenues which may be outstanding at any time, (ii) the ag�regate amount of taxes which PG-11�2- I U�8 9?-31 ?�n S.duc � may be divided and allocated to the Agency pursuant to the Redevelopment Plan, and (iii) the period of time for establishing or repaying loans, advances and indebtedness payable from Tax Revenues. "Proiect Fund" means the fund by that name established and held by the Trustee pursuant to Section 2.7. "Qualified Reserve Fund Credit Instrument" means an irrevocable standby or direct-pay letter of credit or surety bond issued by a commercial bank or insurance company and deposited with the Trustee pursuant to Section 2.5, provided that all of the following requirements are met at the time of deposit with the Trusiee: (i) either (a) the long-term credit rating of such bank is within one of the two highest rating categories by Moody's or S&P, or the claims paying ability of such insurance company is rated within one of the two highest rating categories by Moody's or S&P, at the time of delivery of such letter of credit or surety bond, or (b) the Authority shall cause to be filed with the Trustee written evidence from Moody's and S&P that the delivery of such letter of credit or surety bond will not, of itself, cause a reduction or withdrawal of any rating then assigned to the Bonds; (ii) such letter of credit or surety bond has a term of at least 12 months; (iii) such ietter of credit or surety bond has a stated amouiit at least equal to the portion of the Reserve Requirement with respect to which funds are proposed to be released pursuant to Section 2.5; and (iv) the Trustee is authorized pursuant to the terms of such letter of credit or surety bond to draw thereunder an amount equal to any deficiencies which may exist from time to time with respect to deposits required pursuant to Section 3.3(a). "Redevelovment Fund" means the Project Area No. l, As Amended, Redevelopment Fund, heretofore established and held by the Agency. "Redevelopment Proiect" means the undertaking of the Agency pursuant to the Redevelopment Plan and the Redevelopment Law for the redevelopment of the Project Area. "Reserve Fund" means the Project Area No. 1, As Amended, Reserve Fund held by the Trustee pursuant to Section 2.5. "Reserve ReQuirement," means the least of (i) Maximum Annual Debt Service, (ii) 125 percent of average annual debt service on the Series 2007A Loan and all outstanding Parity Debt, and (iii) 10 percent of the proceeds of the Series 2007A Loan (i.e., the original principal amount of the Bonds) and of the proceeds of any Parity Debt. The amount of the Reserve Requirement on any date is subject to confirmation by the Authority to the Trustee upon the Trustee's written request. At the Closing Date, the Reserve Requirement shall be $ "Series 2007A Loan" means the loan made by the Authority to the Agency pursuant to Section 2.1(a) from the proceeds of the Bonds in the principal amount of $ "Special Fund" means the fund by that name held by the Agency pursuant to Section 3.2. "Subordinate Debt" means any loans, advances or indebtedness issued or incurred by the Agency in accordance with the reyuirements of Section 2.9, which are either: (i) payable from, but not secured by a pledge of or lien upon, the Tax Revenues; or (ii) secured by a pledge P�,an2- i n5� 9?� 1 �r,� � duc 4 of or lien upon the Tax Revenues which is subordinate to the pledge of and lien upon the Tax Revenues hereunder for the security of the Series 2007A Loan and any Parity Debt. "Suretv Bond" means thc Qualified Reserve Fund Credit ]nstruments issued by the Insurer concurrently with the issuance and delivery of the Bonds guaranteeing certain payments into the Reserve Fund as provided therein and subject to the limitations set forth therein. "Tax Revenues" means that portion of the taxes levied upon taxable property in the Project Area, allocated and paid into a special fund of the Agency pursuant to Article 6 of Chapter 6 of the Redevelopment Law and Section 16 of Article XVI of the California Constitution, exclusive of amounts placed into the Low and Moderate Income Housing Fund of the Agency pursuant to Sections 33334.2 and 33334.3 of the Redevelopment Law, and excluding amounts payable to affected taxing agencies pursuant to the Pass-Through Agreements or pursuant to Section 33607.5 or 33607.7 of the Redevelopment Law. "2006 Loans" means the outstanding balance of the loans madc by the Authority to the Agency pursuant to the 2006 Loan Agreement. "2006 Loan AQreement" means the Project Area No. l, As Amended, Loan Agreement dated as of July l, 2006, by and among the Agency, the Authority and Wells Fargo Bank, National Association, as trustee. "2004 Loan" means the outstanding balance of the loan made by the Authority to the Agency pursuant to the 2004 Loan Agreement. "2004 Loan AQreement" means the Project Area No. 1, As Amended, Loan Agreement dated as of June 1, 2004, by and among the Agency, the Authority and BNY Western Trust Company, as succeeded by Wells Fargo Bank, National Association, as trustee. "2003 Loan" means the outstanding balance of the loan made by the Authority to the Agency pursuant to the 2003 Loan Agreement. "2003 Loan A�reement" means the Project Area No. 1, As Amended, Loan Agreement dated as of July l, 2003, by and among the Agency, the Authority and BNY Western Trust Company, as succeeded by Wells Fargo Bank, National Association, as trustee. "2002 Loan" means the outstanding balance of the loan made by the Authority to the Agency pursuant to the 2002 Loan Agreement. "2002 Loan AQreement" means the Project Area No. 1, As Amended, Loan Agreement dated as of March 1, 2002, by and among the Agency, the Authority and BNY Western Trust Company, as succeeded by Wells Fargo Bank, National Association, as trustee. ��; tic��� l.'_. Rules of Construction. All references herein to "Articles," "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of this Loan Agreemcnt, and thc words "herein," "hereof," "hereunder" and other words of similar P(,�3112• 11)SR!)2� 17(,� i duc S import refer to this Loan Agreement as a whole and not to any parcicular Article, Section or subdivision hereof. ARTICLE II THE SERIES 2007A LOAN; APPLICATION OF LOAN PROCEEDS; PARITY DEBT S�cti��n '.I . Authorization. (a) The Authority hereby agrees to lend and the Agency agrees to accept the Series 2007A Loan in the principal amount of $ under and subject to the terms of this Loan Agreement, the Bond Law and the Redevelopment Law. (b) This Loan Agreement constitutes a continuing agreement to secure the full and final payment of the Series 2007A Loan, subject to the covenants, agreements, provisions and conditions herein contained. ���ctiun �.�. Disbursement and Apolication of Loan Proceeds. On the Closin� Date, the Authority shall cause to be deposited into the Series 2007A Loan Fund the amount of $ , which shall be held by the Trustee and which shall be disbursed as follows: Issuance Fund. (i) The Trustee shall transfer the amount of $� to the Costs of (ii} The Trustee shatl transfer the amount of $_ to the Escrow Fund. (iii) The Trustee shall transfer the remaining amount of $ to the Project Fund. On the Closing Date, the Authority and the Agency shall also cause the amount of $_ to be paid to the Insurer for the cost of the premiums for the Insurance Policy and the Surety Bond. The Trustee may, in its discretion, establish a temporary fund or account to facilitate or accouni for the foregoing transfers. S�ctiem ?. �. Repavment of Series 2007A Loan. The Agency shall, subject to prepayment as provided in Section 2.4(a), repay the principal of the Series 2007A Loan in installments on April 1 in each of the years and in the amounts, and shall pay interest on the unpaid principal balance of the Series 2007A Loan due on each Interest Payment Date not later than the fifth Business Day preceding such Interest Payment Date in the amounts set forth in Exhibit A attached hereto and by this reference incorporated herein. Such interest shall accrue from the Closing Date. Any installment of principal or interest which is not paid when due shall continue to accrue interest from and including the date on which such principal or interest is payable to but not including the date of actual payment. In the event any unpaid principal installments of the Series 2007A Loan shall be prepaid pursuant to Section 2.4(a), or in the event the Bonds shall be redeemed pursuant to Section 2.3(a) of the Indentiire, the schedule of P�,du?- � ns£+�9za � ��,� >��oc G principal installments set forth in Exhibit A hereto shall be reduced as directed by the Agency to the Trustee. The obligation of the Agency to repay the Series 2007A Loan is, subject to Section 3.1, absolute and unconditional, and such payments shall not be subject to reduction whether by offset or otherwise and shall not be conditional upon the performance or nonperformance by any party to any agreement for any cause whatsoever. Principal of and interest on the Series 2007A Loan shall be payable by the Agency to the Trustee, as assignee of the Authority under the Indenture, in lawful money of the United States. Payment of such principal and interest shall be secured, and amounts for the payment thereof shall be deposited with the Trustee at the times, as set forth in Article III. Notwithstandir►g the foregoing provisions of this Section 2.3, in lieu of payment of any installment of principal of the Serics 2007A Loan coming due and payable on April 1 in any year in which any Bonds are subject to mandatory sinking fund redemption, the Agency shall have the right to purchase any of such Bonds in an amount not exceeding the amount thereof which is subject to mandatory sinking fund redemption on such April 1, and tender sucl� Bonds for cancellation, provided that such tender shall be made before the preceding January 15. Section 2.4. Optional Prenavment. (a) The Agency shall have the right to prepay principal installments of the Series 2007A Loan, in any integral multiple of $5,000, such prepayment to be allacated among such principal installments as the Agency may determine upon Request to the Authority and the Trustee provided not less than 45 days prior to the prepayment date, on any Interest Payment Date on which the Bonds are subject to redemption pursuant to Section 2.3(a) of the Indenture, by depositing with the Trustee an amount sufficient to redeem a like aggregate principal amount of Bonds together with the amount of accrued interest and premium, if any, required to be paid upon such redemption. (b) Before making any prepayment pursuant to this Section, the Agency shall give written notice to the Authority and the Trustee describing such event and specifying the date on which the prepayment will be paid and the order thereof, which date shall be not less than 45 days from the date such notice is given; provided, that notwithstanding any such prepayment, the Agency shall not be relieved of its obligations with respect to the Series 2007A Loan, including specifically its obligations under this Article, until the Series 2007A Loan shall have been fully paid (or provision for payment thereof shall have been made pursuant to Section 6.3). (c) The Authority agrees that upon payment by the Agency to the Trustee of such amount, the Authority shall take or cause to be taken any and all steps required under the Indenture to redeem such Outstanding Bonds of the applicable series on the redemption date designated by the Agency; nrovided, however, that such date shall be a date of redemption of such Bonds, for which notice has been timely given pursuant to the Indenture. Sccti���� �.�. Reserve Fund. There is heretofore established a separate fund known as the "Project Area No. 1, As Amended, Reserve Fund," which shall continue to be held by the Trustee in trust for the benefit of the Atithority and thc Owners of thc Bonds and the N�,ao?-i osa��2a i ��>� s<io� 7 registered owners of all other bonds issued by the Authority in connection with any Parity Debt. The Agency hereby pledges and grants a lien and a security interest in the Reserve Fund to the Trustee in order to securc the Agency's payment obligations under Sections 2.3 and 3.3(a). The amount on deposit in the Reserve Fund shall be maintained at the Reserve Requirement ai all times, except to the extent required for the purposes set forth in this Section. In the event that the Agency shall fail to deposit with the Trustee the full amount required to be deposited pursuant to Section 3.3(a), the Trustee shall withdraw from the Reserve Fund and transfer to the Interest Account and the Principal Account, in such order, an amount equal to the difference between (i) the amount required to be deposited pursuant to Section 3.3(a) and (ii) the amount actually deposited by the Agency. In the event that the amount on deposit in the Reserve Fund shall at any time be less than the Reserve Reyuirement, the Trustee shall notify the Agency as soon as practicable of the amount required to be deposited therein to restore the balance to the Reserve Requirement, such notice to be given by telephone, telefax or other form of telecommunications promptly confirmed in writing, and the Agency shall thereupon transfer to the Trustee the amount needed to restore the Reserve Fund to the Reserve Requirement. In the event that the amount on deposit in the Reserve Fund on the 15th calcndar day preceding any Interest Payment Date (other than the final Interest Payment Date) provided that the deposits required by Section 3.3(a) have been made — exceeds the Reserve Requirement, the Trustee shall withdraw from the Reserve Fund all amounts in excess of the Reserve Requirement and shall (i) transfer such amounts to the Revenue Fund, (ii) if directed by the Agency pursuant to a Written Request, apply such amounts toward the prepayment of the Series 2007A Loan pursuant to Section 2.4 or the prepayment of any Parity Debt, or (iii) upon receipt of prior Request of the Agency to pay such amounts to the Agency to be used for any lawful purpose relating to the Project Area, as specified in such Request of the Agency. Notwithstanding the foregoing provisions of this paragraph, however, no amounts shall be withdrawn from the Reserve Fund and transferred to the Agency pursuant to this paragraph during any period in which an Event of Default shall have occurred and be continuing hereunder. With the written consent of the Insurer (as long as the Insurance Policy is in full force and effect) and of the insurer of any Parity Debt (as long as the policy insuring such Parity Debt is in full force and effect), the Reserve Requirement may be satisfied by crediting to the Reserve Fund moneys or a Qualified Reserve Fund Credii Instrument or any combination thereof, which in the aggregate make funds available in the Reserve Fund an amount equal to the Reserve Requirement. Upon the deposit with the Trustee of such Qualified Reserve Fund Credit Instrument, the Trustee shall release moneys then on hand in the Reserve Fund to the Agency, to be uscd for any lawful purpose relating to the Project Area, in an amount equal to the face amount of the Qualified Reserve Fund Credit Instrument. If at any time the amount on deposit in, or credited to, the Reserve Fund includes both cash and the Surety Bond, any draw on the Surety Bond shall be made only after all cash in thc Reserve Fund has been expendcd. If at any time the amount credited to the Reserve Fund includes more than one Qualified Reserve Fund Credit Instrument, any draw on the Qualified Reserve Fund Credit Instruments shall be made on a pro rata basis based on the relative amounts of debt service of the applicable bonds covered by each Qualified Reserve Fund Credit Instrument in such Fiscal Year. Pb40?-IO�R�`12d17C>v; doc g ��e:t���i� ?.��. Costs of Issuance Fund. There is hereby established a fund to be held by the Trustee known as the "Costs of Issuance Fund." A portion of the proceeds of the Series 2007A Loan shall be deposited in the Costs of Issuance Fund pursuant to Section 2.2(a). The moneys in the Costs of Issuance Fund shal] be used to pay Cosis of Issuance of the Bonds from time to time upon receipt of a Request of the Agency. On the 120th day after the Closing Date (or the first Business Day thereafter), or upon the eartier receipt by the Trustee of a Request of the Agency stating that all Costs of Issuance have been paid, the Trustee shall transfer all remaining amounts in the accounts of the Costs of Issuance Fund to the Revenue Fund. �crtion 2.%. Proiect Fund. There is hereby established a fund to be known as the "Project Fund," which shall be held and maintained by the Trustee. Amounts on deposit in such fund shall be derived solely from the portion of the proceeds of the Series 2007A Loan transferred thereto, or from excess amounts transferred thereto from the Reserve Fund, and from earnings on the investment of amounts therein. Except as provided in this Section, the moneys set aside and placed in the Project Fund shall remain therein until expended from time to time for the purpose of paying any portion of the costs of the Redevelopment Project, and otlier costs related thereto, which other costs may include, but are not limited to, (a) the cost of improvements and other costs which may not benefit the Redevelopment Project exclusively but which are necessary to the redevelopment of the Project Area and the disposition of land therein; (b) the repayment of any advances made by the City for the Redevelopment Project; and (c) to the extent not paid from the Costs of Issuance Fund, the necessary expenses in connection with the issuance and sale of the Bonds. Before any payment of money is made from the Project Fund, the Agency shall file with the Trustee a Request of the Agency showing with respect to each payment of money to be made: (a) the name and address of the person to whom payment is due; (b) the amount of money to be paid; (c) the purpose for which the obligation to be paid was incurred; and (d) that such amount has not been paid previously for such purpose from the Project Fund. Each such Request of the Agency shall state and shall be sufficient evidence to the Trustee: (i) that an obligation in the stated amount has been properly incurred under and pursuant to this Loan Agreement and that such obligation is a proper charge against the Project Fund; and (ii) that there has not been filed with or served upon the Agency a stop notice or any other notice of any lien, right to lien or attachment upon, or claim affecting the right io receive payment of, any of the money payable to the person named in such Request of the Agency which has not been released or will not be released simultaneously with the payment of such obligation, other than liens accniing by mere operation of law. Fh�lu2-� 1�ss9"_'a � 7G� s �or 9 Upon receipt of each such Request of the Agency, the Trustee shall pay the amount set forth in such Request of the Agency as directed by the terms thereof within three Business Days. If any moneys deposited in the Project Fund remain therein after the full accomplishment of the objects and purposes for which the Series 2007A Loan was made, said moneys shall be transferred to the Special Fund. Cccti��n ?.�. Paritv Debt. From time to time, the Agency may issue or incur additional Parity Debt in such principal amount as shall be determined by the Agency, subject to the following specific conditions which are hereby made conditions precedent to the issuance and delivery of such Parity Debt issued under this Section 2.8: (a) No Event of Default shall have occurred and be continuing, and the Agency shall otherwise be in compliancc with all covenants set forth in this Loan Agreement. (b) The amount of Tax Revenues for the then current Fiscal Year, as set forth in a Certificatc of the Agency, based on assessed valt�ation of property in the Project Area as evidenced in the written records of the Cou�ity, and projected annual Tax Revenues over the ternl of this Loan Agreement based on current Tax Revenue collections, shall be at least equal to 115 percent of Maximum Annual Debt Service. (c) The related Parity Debt Instrument shall provide that the balance of the Reserve Fund shall be increased to the new Reserve Requirement effective after the incurrence of such Parity Debt. (d) The related Parity Debt Instrument shall provide that: (1) With respect to any Parity Debt which bears current interest, interest on such Parity Debt shall not be payable on a date other than April 1 and October 1 of any year, and (2) The principal of such Parity Debt shall not be payable on any date other than the date on which principal of the Series 2Q07A Loan is payable. (e) The issuance of such Parity Debt shall not cause the Agency to exceed any applicable Plan Limitations. (� The Agency shall deliver to the Trustee a Certificate of the Agency certifying that the conditions precedent to the issuance of such Parity Debt set forth in Paragraphs (a) through (e) above have been satisfied. Scctiun �.��. Issuance of Subordinate Debt. In addition to the Series 2007A Loan and any Parity Debt, from time to time the Agency may issue or incur Subordinate Debt in such principal amount as shall be deternlined by the Agency, provided that the issuance of such Subordinate Debt shall not cause the Agency to exceed any applicable Plan Limitations. P(,4u2- I U;g :92-i 17h� 5 cfor 1 � ����t���i� ?. f t�. Validity of Series 2007A Loan. The validity of the Series 2007A Loan shall not be dependent upon the completion of the Redevelopment Project or upon the performance by any person of any obligation with respect to the Redevelopment Project. ARTICLE III PLEDGE AND APPLICATION OF TAX REVENUES ���ti��i� 3.1. Pled�e of Tax Revenues. The Series 2007A Loan and all Parity Debt shall be equally secured by a first pledge of and lien on all of the Tax Revenues and all of the moneys on deposit in the Specia] Fund, without preference or priority for series, issue, number, dated date, sale date, date of execution or date of delivery. Except for the Tax Revenues and other funds pledged hereunder, no funds or properties of the Agency shall be pledged to, or otl�erwisc liablc for, thc paymcnt of principal of or interest on or prepayment premium, if any, on the Series 2007A Loan. ���tie�n 3.�. Special Fund; Deposit of Tax Revenues. The A�ency has heretofore established a special fund known as the "Special Fund," �vhich is and shall coiltinue to be held by the Agency as a separate fund apart from all other funds and accounts of the Agency. The Agency shall deposit all Tax Revenues in the Special Fund promptly upon the receipt thereof. Except as may be otherwise provided in any Parity Debt lnstrument, any Tax Revenues received during the Bond Year in excess of amounts required to be transferred to the Trustee pursuant to Section 3.3 shall be released from the pledge and lien hereunder and may be used for any lawful purposes of the Agency. Prior to the payment in full of the principal of and interest and prepayment premium, if any, on the Series 2007A Loan and all Parity Debt and the payment in full of all other amounts payable hereunder and under any Parity Debt Instrument, ihe Agency shall not have any beneficial right or interest in the moneys on deposit in the Special Fund, except only as provided in this Loan Agreement and in any Parity Debt Instrument, and such moneys shall be used and applied as set forth herein and in any Parity Debt Instrument. ti�ctioi> ;.�. Transfer of Tax Revenues From Special Fund. In addition to the transfers required to be made pursuant to any Parity Debt Instrument, the Agency shall withdraw from the Special Fund and transfer to the Trustee the following amounts at the following times and in the following order of priority: (a) Interest and Principal DeUosits. No later than the fifth Business Day preceding each date on which the principal of or interest on the Series 2007A Loan or any Parity Debt shall become due and payable, including but not limited to the principal amounts of the Series 2007A Loan to be prepaid hereunder together with any prepayment premium thereon, the Agency shall withdraw from the Special Fund and transfer to the Trustee an amount which, together with the amounts then held on deposit in the Interest Account, the Principal Account and the Revenue Fund, is equal to the aggregate amount of such principal, interest and prepayment premium. (b) Reserve Fund Deposits. In the event that the Trustee shall notify thc Agency pursuant to Section 2.5 that the amount on deposit in the Reserve Fund is less than the Ph=1n?-Iu�ti���2417G�; doc 1 1 � Reserve Requirement, the Agency shall immediately withdraw from the Special Fund and transfer to the Trustee for deposit in the Reserve Fund an amount of money necessary to maintain the Reserve Requirement in the Reserve Fund (including repayment of any draw made under a Qualified Reserve Fund Credit Instrument, including the Surety Bond, prior to replenishing any cash in the Reserve Fund). (c) Surplus. Except as may be otherwise provided in any Parity Debt Instrument, the Agency shall not be obligated to deposit in the Special Fund in any Bond Year an amount of Tax Revenues which, together with other available amounts in the Special Fund, exceeds the amounts reguired in such Bond Year pursuant to this Section 3.3. All Tax Revenues which are received by the Agency during any Bond Year in excess of the amounts required to be deposited in the Special Fund in such Bond Year shall be released from the pledge thereof and lien thereon which is established pursuant hereto. In the event that for any reason whatsoever any amounts shall remain on dcposit in the Special Fund on any April 2 after making all of the transfers theretofore rcquircd to be made pursuant to the preccding Paragraphs (a) and (b) anc� pursuant to any Parity Debt Instniment, the Agency may withdraw such amounts from the Special Fund, to be used for any la�vful purposes of t}ie Agency, including but not limited to the paymcnt of any Subordinate Debt or thc payilie�it of any amounts ciue �lI1CI OW111� 10 111C Unitec] States pursuant to Section 4.11. ��cti���13.-�. Investment of Monevs; Valuation of Investments. Subject to Section 4.3 of the Indenture, all moneys in the Special Fund, the Project Fund, the Reserve Fund and the Costs of Issuance Fund shall be invested in Permitted Investments. Absent any prior written instruction from the Agency or the Authority, moneys in any fund held by the Trustee hereunder or under the Indenture shall be invested in Permitted Investments described in clausc D of the definition thereof. Absent the written consent of the Insurer, investments of moneys in the Reserve Fund (not including any Qualified Reserve Fund Credit Instrument) shall not have maturities extending beyond five years. Obligations purchased as an investment of moneys in any fund or account established hereunder shall be credited to and deemed to be part of such fund or account. The Agency or the Trustee, as the case may be, may commingle any amounts in any of the funds and accounts held hereunder with any other amounts held by the Agency or the Trustee for purposes of making any investment, nrovided that the Agency and the Trustee shall maintain separate accounting procedures for the investment of all funds and accounts held hereunder. All interest, profits and other income received from the invesiment of moneys in any fund or account established hereunder shall be credited to such fund or account. Notwithstanding anything to the contrary contained in this Section 3.4, an amount of interest received with respect to any investment equal to the amount of accrued interest, if any, paid as part of the purchase price of such investment shall be credited to the fund or account from which such accrued interest was paid. For the purpose of determining the amount in any fund or account established hereunder, any investments credited to such fund shall be valued at least annually at the market value thereof. P641)2-111;R'92�317G� i dor l2 ARTICLE IV OTHER COVENANTS OF THE AGENCY ���tic�n -1.1. Punctual Pavment; Extension of Pavments. The Agency shall punctually pay or cause to be paid the principal of and interest and prepayment premium, if any, on the Series 2007A Loan in strict conformity with the terms of this Loan Agreement, and it will faithfully observe and perform all of the conditions, covenants and requirements of this Loan Agreement. The Agency shall not directly or indirectly extend or assent to the extension of the maturity of any installment of principal of or interest or prepayment premium, if any, on the Series 2007A Loan, and in case the principal of or interest or premium, if any, on the Series 2007A Loan or the time of payment of any such claims therefor shall be extended, such principal, interest, premium or claims for interest shall not be entitled, in case of any Event of Default hereunder, to the benefits of this Loan Agreement except for payment of all amounts which shall not have been so extencled. ��i:�i�,�i -1.�. Limitation on Additional Indebtedness. The Agcncy hereby covenants that it shall not issue any bonds, notes or other obligations, enter into any agrccment or otherwise incur any indebtedness, which is in any case payable from all or any part of tl�e 'I'ax Revenues, excepting only the Series 2007A Loan, any Parity Debt, and any Subordinate Debt, and any other obligations permitted by this Loan Agreement. 5�cti��n �l. �. Pavment of Claims. The Agency shall pay and discharge, or cause to be paid and discharged, any and all lawful claims for labor, materials or supplies which, if unpaid, might become a lien or charge upon the properties owned by the Agency or upon the Tax Revenues or any part thereof, or upon any funds in the hands of the Trustee, or which might impair the security of the Series 2007A Loan. Nothing herein contained shall require the Agency to make any such payment so long as the Agency in good faith shall contest the validity of said claims. ��cti�n a.-�. Books and Accounts: Financial Statements. The Agency shall keep, or cause to be kept, proper books of record and accounts, separate from all other records and accounts of the Agency and the City, in which complete and correct entries shall be made of all transactions relating to the Redevelopment Project, the Tax Revenues, the Special Fund, the Reserve Fund, the Low and Moderate Income Housing Fund and the Redevelopment Fund. Such books of record and accounts shall at all times during business hours be subject, upon prior written request, to the reasonable inspection of the Authority, the Trustee and the Owners of not less than ten percent in aggregate principal amount of a series of Bonds then Outstanding, or their representatives authorized in writing. The Agency will cause to be prepared annually, within 180 days after the close of each Fiscal Year so long as any of the Bonds are Outstanding, complete audited financial statements with respect to such Fiscal Year showing the Tax Revenues, all disbursements from thc Special Fund and the Redevelopment Fund and the financial condition of the Redevelopment Project, including the balances in all funds and accounts relating to the Redevelopment Project, as of the end of such Fiscal Year. The Agency will furnish a copy of such statements, upon reasonable request, to any Owner. Pb�l�i2- I(��%�y2a 17r�. s.doc 1 3 ti�•r�ini� -�.�. Protection of Securitv and RiQhts. The Agency will preserve and protect ihe security of the Series 2007A Loan and the rights of the Trustee and the Owners with respect to the Series 2007A Loan. From and after the Closing Date, the Series 2007A Loan shall be inconiestable by the Agency. The Series 2007A Loan and the provisions of this Loan Agreement are and will be the legal, valid and binding special obligations of the Agency enforceable in accordance with their terms, and the Agency shall at all times, to the extent permitted by law, defend, preserve and protect all the rights of the Authority, the Trustee and the Owners under this Loan Agreement against all claims and demands of all persons whomsoever. The Agency's obligations to the Trustee under this Section 4.5 shall survive the payment of the Bonds and the discharge of the Indenture, the removal or resignation of the Trustee pursuant to the Indenture or the payment of the Series 2007A Loan and the discharge of this Loan Agreement. ��cti�,�� -l.t�. Pavments of Taxes and Other CharQes. The Agency will pay and discharge, or cause to be paid and discharged, all taxes, scrvice charges, assessments and otl�er �ovcrnmcntal char�es which may hereaftcr be lawfully imposed upon ihe Agency or thc properties then owned by the Agency in the Project Area when the same shall become due. Nothin� herein contained shall require the A�ency to make any such paymcnt so lon� as the Agency i�l good faith shall contest the validity of such taxes, assessments or cl�arges. The Agency will duly obscrve and comply with all valid requirements of any governmental authority relative to the Redevelopment Project or any part thereof. S�rtiun -1.7. Taxation of Leased Propertv. All ad valorem property taxes derived by the Agency pursuant to Section 33673 of the Redevelopment Law with respect to the lease of property for redevelopment shall be treated as Tax Revenues for all purposes of this Loan Agreement, and shall be deposited by the Agency in the Special Fund promptly upon receipt. Scctic�n 4.�. Disnosition of Provertv. The Agency will not participate in the disposition of any land or real property in the Project Area to anyone which will result in such property becoming exempt from taxation because of public ownership or use or otherwise (except property dedicated for public right-of-way and except property planned for public ownership or use by the Redevelopment Plan in effect on the date of this Loan Agreement) so that such disposition shall, when taken together with other such dispositions, aggregate more than ten percent of the land area in the Project Area unless such disposition is permitted as hereinafter provided in this Section 4.8. If the Agency proposes to participate in such a disposition, it shall thereupon appoint an Independent Redevelopment Consultant to report on the cffect of said proposed disposition. If the Report of the Independent Redevelopment Consultant concludes that the security of the Series 2007A Loan or the rights of the Authority, the Owners and the Trustee hereunder will not be materially impaired by said proposed disposition, the Agency tnay thereafter make such disposition. If such Report concludes that such security will be materially impaired by such proposed disposition, the Agency shall disapprove said proposed disposition. ����ti��n 1.�� Maintenance of Tax Revenues. The Agency shall comply with all requirements of the Redevelopment Law to insure the allocation and payment to it of the Tax Revenucs, including without limitation the timely filing of any necessary statements of PGJU'- l u;8�'��-� � ��,.;.<i�� ( 4 indebtedness with appropriate officials of the County and (in thc case of supplemental revenues and other amounts payable by the State) appropriate officials of the State. The Agency shail not amcnd the Redevelopment Plan (except for the purpose of extending or eliminating the time limit on 1he establishment of loans, advances, and indebtedness, extending the time limit on the effectiveness of the Redevelopment Plan, extending the time limit on the payment of indebtedness, extending ihe time limit for ihe receipt of tax increment, or increasing the limitation on the number of dollars of taxes to be allocated to the Agency) or any of the Pass- Through Agreemenis, or enter into any agreement with the County or any other governmental unit, which would have the effect of reducing the amount of Tax Revenues available to the Agency for payment of the Series 2007A Loan, unless the Agency shall first obtain (a) the Report of an Independent Redevelopment Consultant stating that the amount of Tax Revenues for the ihen current Fiscal Year (calculated on the assumption that such reduction of Tax Revenues was in effect throughout such Fiscal Year), shall be at least equal to 115 percent of Maximum Anntial Debt Service, and (b) as long as the Insurance Policy is in fiill force anci effect, the written consent of the Insurer. Nothing l�erein is intended or shall be constnied in any �vay to prohibit or impose any limitations on the entering into by the Agency of any sucl� agreement, amendment or supplement �vhich by its term is subordinate to the payment of the Series 2007A Loan ancl ail Parity Debt. ����i���� -�.1��. Pavment of Expenses; Indemnification. The Agency shall pay to the Trustee from time to time all compensation for all services rendered under this Loan Agreement and the Indenture, including but not limited to all reasonable expenses, charges, legal and consulting fees and other disbursements and those of its attorneys, agents and employees, incuned in and about the performance of its powers and duties hereunder and thereunder. Upon the occurrence of an Event of Default, the Trustee shall have a first lien on the funds held by it under the Indenture to secure the payment to the Trustee of all fees, costs and expenses, including reasonable compensation to its experts, attorneys and counsel (including the allocated costs and disbursemenls of in-house counsel to the extent the services of such counsel are not duplicative of services provided by outside counsel) incurred in performing its duties under the Indenture and this Loan Agreement. The Agency further covenants and agrees to indemnify, defend and save the Trustee and its officers, directors, agents and employees, harmless against any losses, expenses and liabilities which it may incur arising out of or in the exercise and performance of its powers and duties in accordance with the Indenture and this Loan Agreement, including the costs and expenses of defending against any claim of liability, but excluding any and all losses, expenses and liabilities which are due to the negligence or intentional misconduct of the Trustee, its officers, directors, agents or employees. The obligations of the Agency under this paragraph shall survive the resignation or removal of the Trustee under ihe Indenture, this Loan Agreement and payment of the Series 2007A Loan and the discharge of this Loan Agreement. Section 4.11. Tax Covenants. (a) The Agency covenants that, in order to maintain the exclusion from �ross income for Federal income tax purposes of the interest on the Bonds, and for no other purpose, the Agency will satisfy, or take such actions as are necessary to cause to be satisfied, each P��auz- i nss����a i ��,� >�i�,�� l� provision of the Code recessary to maintain such exclusion. In furtherance of this covenant the Agency agrees to comply with such written instructions as may be provided by Bond Counsel. (b) The Agency covenants that no part of the proceeds oi ihe Bonds shail be used, directly or indirectly, to acquire any Investment Property which would cause the Bonds to become arbitrage bonds as that term is defined in Section 148 of the Code, or under applicable Tax Regulations. In order to assure compliance with the rebate requirements of Section 148 of the Code, the Agency further covenants that it will pay or cause to be paid to the United States the amounts necessary to satisfy the requirements of Section 148(n of the Code, and that it will establish such accounting procedures as are necessary to adequately determine, account for and pay over any such amount required to be paid thereunder in a manner consistent with the requirements of Section 148 of the Code, such covenants to survive the defeasance of the Bonds. (c) T'he Agency covenants that it will not take any action or omit to take any action, �v}lich action or omission, if reasonably expected on the datc of initial execution ancl deli��ery of the Bonds, would result in a loss of exclusion from gross income for pur�oses of Federal income taxation, under Section 103 of ihe Cocle, of i►lterest on tl�e Bonds. (d) "fhe A�ency covenants that it will not use or pennit the use of any property financed with the proceeds of the Bonds by any person (other than a state or local governmental unit) in such manner or to such extent as would result in a loss of exclusion of the interest on the Bonds from gross income for Federal income tax purposes under Section 103 of thc Codc. (e) Except as provided below, the Agency covenants that none of the moneys contained in any of the funds or accounts with respect to the Bonds shall be: (i) used in making loans guaranteed by the United States (or any agency or instrumentality thereo fl, (ii) invested directly or indirectly in a deposit or account insured by the Federal Deposit Insurance Corporation, National Credit Union Administration or any other similar Federally chartered corporation, or (iii) otherwise invested directly or indirectly in obligations guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereo�; provided, however, that the above restrictions do not apply to: (a) the investment on moneys held in the Revenue Fund or any other "bona fide debt service fund" as defined for purposes of Section 148 of the Code, (b) investment in direct obligations of the United States Treasury, (c) investment in obligations guaranteed by the Federal National Mortgage Association, Govemment National Mortgage Association, or the Federal Home Loan Mortgage Corporation, (d) investment in obligations issued pursuant to Section 21B(d)(3) of the Federal Home Loan Bank Act, as amended by Section 51 1(a) of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989, (e) investments permitted under regulations issued pursuant to Section 149(b)(3)(B) of thc Code, or (� such other investments permitted under the Indenture as, in the opinion of Bond Counsel, do not jeopardize the exclusion from gross income for Federal incomc tax purposes of interest on the Bonds. ��� ti«n -l. !.'_. Redevelopment of Proiect Area. The Agency shall ensure that all activities undertaken by the Agency with respect to the redevelopment of the Project Area are undertaken and accomplished in conformity with all applicable requirements of the Redevelopment Plan and the Redevelopment Law. The Agency shall mana�c and operate all P(�411?-1 Ilj R'92a 17G� S.doc � i) properties owned by the Agency and comprising any part of the Redevelopment Projecl in a sound and business-like manner and in conformity with all valid requirements of any governmental authority, and will keep such properties insured at all times in conformity with sound business practice. 5cctic�n 4. I�. Low and Moderate Income HousinQ Fund. The Agency covenants and a�-ees to use the moneys in the Low and Moderate Income Housing Fund in accordance with Sections 33334.2 and 33334.3 of the Redevelopment Law, and further covenants and agrees to disburse, expend or encumber any "excess surplus" (as defined in Section 33334.12 of the Redevelopment Law) in the Low and Moderate Income Housing Fund at such times and in such manner that the Agency shall not be subject to sanctions pursuant to subdivision (e) of said Section 33334.12. tic��tir.+� -t. !�. Annual Review of Tax Revenues. On or before June 30th of each year commencing June 30, 2007, the Agency shall submit a Report of an Indcpendent Redevclopmcnt Consultant to the lnsurer, which Report shall show the total amount of Tax Revenues remaining available to be received by the A�ency under the Redevelo�ment Plan's cumulativc tax increment limitation, as well as future cumulative annual dcbt ser��icc ��•ith respect to the Series 2007A Loan and all Parity Debt. The Agency will not accept Tax Revenues greater than such annual debt service in any year, if such acceptance will cause the amount remaining under the tax increment limit to fall below remaining cumulative annual debt service with respect to the Series 2007A Loan and all Parity Debt, except for the purpose of depositing such revenues in escrow for the payment of such debt service or for the prepayment or redemption of the Series 2007A Loan or any Parity Debt. Once it is deiermined that Tax Revenues available to be received by the Agency under the aforementioned tax increment limitation in an upcoming year will not exceed 110 percent of aggregate remaining debt service on the Series 2007A Loan and all outstanding Parity Debt, the Agency shall escrow all current and future Tax Revenues and use such amounts solely for the purpose of paying (or prepaying) debt service on the Series 2007A Loan and Parity Debt. �ccti��n �4. I�. Further Assurances. The Agency 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 Loan Agreement and for the better assuring and confirming unto the Trustee, the Authority and the Owners of the Bonds of the rights and benefits provided in this Loan Agreement. ARTICLE V EVENTS OF DEFAULT AND REMEDIES ti���tiu» >.I. Events of Default and Acceleration of Maturities. The following events shall constitute Events of Default hereunder: (a) Failure by the Agency to pay the principal of or interest or prepayment premium, if any, on the Series 2007A Loan or any Parity Debt when and as the same shall becomc due and payable. Y���lu2-lUSi; �)2-317G�S doc I7 (b) Failure by the Agency to observe and perform any of the covenants, agreements or conditions on its part contained in this Loan Agreement, other than as referred to in the preceding Paragraph (a), for a period of 60 days after written notice specifying such failure and requesting that it be remedied has been given to the Agency by the Trustee; provided, however, that if the failure stated in such notice can be corrected, but not within such 60-day period, such failure shall not constitute an Event of Default if corrective action is instituted by the Agency within such 60-day period and thereafter is diligently pursued until such failure is corrected. (c) The filing by the Agency of a petition or answer seeking reorganization or arrangement under the federal bankruptcy laws or any other applicable law of the United States of America, or if a court of competent jurisdiction shall approve a petition, filed with or without the consent of the Agency, seeking reorganization under the federal bankruptcy laws or any other applicable law of the Uniied States of America, or if, under the provisions of any other law for the relief or aid of c3ebtors, any court of competent jurisdiction shall assume custody or control ol' the Agency or of the whole or any substantial part of its property. If an Event of Default has occurrcd and is continuing, the Authority or thc Tnistee may, and at the written direction of the Owners of a majority in aggregate principal amount of the Outstanding Bonds the Authority or the Trustee shall, (i) declare the principal of the Series 2007A Loan, together with the accrued interest on all unpaid installments thereof, to be due and payable immediately, and upon any such declaration the same shall become immediately due and payable, anything in this Loan Agreement to the contrary notwithstanding, and (ii) subject to the receipt of indemnity as provided in the Indenture, exercise any other remedies available to the Trustee at law or in equity. Immediately upon becoming aware of the occurrence of an Event of Default, the Authority, or the Trustee as assignee of the Authority, shall give notice of such Event of Default to the Agency by telephone, telecopier or other telecommunication device, promptly confirmed in writing. This provision, however, is subject to the condition that if, at any time afler the principal of the Series 2007A Loan shall have been so declared due and payable, and before any judgment or decree for the payment of the moneys due shall have been obtained or entered, the Agency shall deposit with the Trustee a sum sufficient to pay all installments of principal of the Series 2007A Loan matured prior to such declaration and all accrued interest thereon, with interest on such overdue installments of principal and interest at the net effective rate then borne by the Outstanding Bonds, and the reasonable expenses of the Trustee (including but not limited to attomeys' fees), and any and all other defaults known to the Trustee (other than in the payment of principal of and interest on the Series 2007A Loan due and payable solely by reason of such declaration) shall have been made good or cured to the satisfaction of the Trustec or provision deemed by the Trustee to be adequate shall have been made therefor, then, and in every such case, the Owners of a majority in aggregate principal amount of the Outstanding Bonds may, by written notice to the Trustee and the Agency, rescind and annul such declaration and its consequences. However, no such rescission and annulment shall extend to or shall affect any subsequent default, or shall impair or exhaust any right or power consequent thereon. Sc�tir�r� �'. Avvlication of Funds Uvon Default. All amounts received by the Trustee pursuant to any right given or action taken by the Trustee under the provisions of this Loan Agreement, shall be applied by the Trustee in the following order: P(,4uz-1 f�;8 ;93�117r,v5.doc 1 8 First, to the payment of the fees, costs and expenses of the Trustec, including reasonable compensation to its agents, attorneys and counsel (including the aliocated costs and disbursements of in-house counsel to the extent the services of such counsel are not duplicative of services provided by outside counsel); and Second, to the payment of the whole amount of interest on and principal of the Series 2007A Loan then due and unpaid, with interest on overdue installments of principal, and such interest to the extent permitted by law at the net effective rate of interest then borne by the Outstanding Bonds; provided, however, that in the event such amounts shall be insufficient to pay in full the full amount of such interest and principal, then such amounts shall be applied in the following order of priority: (i) first, to the payment of all installments of interest on the Series 2007A Loan then due and unpaid, on a pro rata basis in the event that the available amoimis are insufficient to pay all such i�iterest iil full, (ii) second, to the payment of all instaliments of principal of the Series 2007A Loan then due and payable, on a pro rata basis in the event that thc availablc amounts arc installmcnts of principal in full, and (iii) third, to the payment of interest on overdue installments of principal and interest, on a pro rata basis in the event that the available amounts are insufficient to pay all such interest in full. ��rtion 5.3. No Waiver. Nothing in this Ariicle V or in any other provision of this Loan Agreement, shall affect or impair the obligation of the Agency, which is absolute and unconditional, to pay from the Tax Revenues and other amounts pledged hereunder, the principal of and interest and premium, if any, on the Series 2007A Loan to the Trustee when due, as herein provided, or affect or impair the right of action, which is also absolute and unconditional, of the Trustee to institute suit to enforce such payment by virtue of the contract embodied in this Loan Agreement. A waiver of any default by the Trustee shall not affect any subsequent default or impair any rights or remedies on the subsequent default. No delay or omission of the Trustee to exercise 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 therein, and every power and remedy conferred upon the Trustee by the Redevelopment Law or by this Article V may be enforced and exercised from time to time and as often as shall be deemed expedient by the Trustee. If a suit, action or proceeding to enforce any right or exercise any remedy shall be abandoned or determined advcrsely to the Trustee, the Agency, the Authority and the Trustee shall be restored to their former positions, rights and remedies as if such suit, action or proceeding had not been brought or taken. ��rti���� 5.-1. A�reement to Pav Attornevs' Fees and Expenses. In the evcnt the Agency or the Authority should default under any of the provisions hereof and the nondefaulting party or the Trustee should employ attorneys or incur other expenses for the collection oF f'G�lu2-1OS$`•92417bt�5.dor � �) moneys or the enforccment or performance or observance of any obligation or agreement on the part of the defaulting party herein contained, the defaulting party agrees that it will on demand therefor pay to the nondefaulting pafly or the Trustee, as the case may be, the reasonable fees of such attorneys and such other expenses so incurred (including the allocated costs and disbursements of in-house counsei to the extent the services of such counsel are not duplicative of services provided by outside counsel). S�ctic�T� ti.�. Remedies Not Exclusive. No remedy herein conferred upon or reserved to the Trustee is intended to be exclusive of any other remedy. Every such remedy shall be cumulative and shall be in addition to every other remedy given hereunder or now or hereafter existing, at law or in equity or by statute or otherwise, and may be exercised without exhausting and without regard to any other remedy conferred by the Redevelopment Law or any other law. tirctic�n �.{�. Control of Remedies bv Insurcr. Notwithstanding ihe provisions of Section 5.1 and subject to any rights heretofore granted by the Authority or the Agency to any insurer of Parity Debt, as long as Instirance Policy is in full foree and effect and the Insurer has not defau(ted with respect to its payment obligatioi�s thereunder, upon thc occurrence ancl continuance of an Event of Default, the Insurer shall be entit(ed to control and direct thc enforcement of all rights and remedies granted to the Owners or the Trustee for the benefit of the Owners under this Loan Agreement. Any acceleration of the Series 2007A Loan or annufinent thereof pursuant to Section 5.1 shall be subject to the prior written consent of the Insurer. No waiver of a default shall be effective without the written consent of the Insurer. ARTICLE VI MISCELLANEOUS �r�tio» ��.I. Benefits Limited to Parties. Nothing in this Loan Agreement, expressed or implied, is intended to give to any person other than the Agency, the Trustee, the Insurer and the Authority, any right, remedy or claim under or by reason of this Loan Agreement. All covenants, stipulations, promises or agreements in this Loan Agreement contained by and on behalf of the Agency shall be for the sole and exclusive benefit of the Authority, the Trustee acting as trustee for the benefit of the Owners of the Bonds, and the Insurcr so long as the Insurance Policy remains in full force and effect. ��•�tiu» ��.�. Successor Deemed Included in All References to Predecessor. Whenever in this Loan Agreement, the Agency, the Authority, the Trustee or the Insurer is named or referred to, such reference shall be deemed to include the successors or assigns thereof, and all the covenants and agreements in this Loan Agreement contained by or on behalf of the Agency, the Authority, the Trustee or the Insurer shall bind and inure to the benefit of thc respective successors and assigns thereof whether so expressed or not. ��•�ti���� c�. �. Dischar�e of Loan AQreement. If the Agency shall pay and discharge the indebtedness on the Series 2007A Loan or any portion thereof in any one or more of the following ways: Pb�ioz- � ��sit.<�za t �6� i.doc 20 (a) by well and truly paying or causing to be paid the principal of and interest and prepayment premiums, if any, on the Series 2007A Loan or such portion thereof, as and when the same become due and payable; (b) by irrevocably depositing with the Trustee, in trust, at or before maturity, cash in an amount which, together with the available amounts then on deposit in any of the funds and accounts established pursuant to the Indenture or this Loan Agreement, in the opinion or report of an Independent Accountant is fully sufficient to pay all principal of and interest and prepayment premiums, if any, on the Series 2007A Loan or such portion thereof; or (c) by irrevocably depositing with the Trustee or any other Cduciary, in trust, non-callable Defeasance Obligations in such amount as an Independent Accountant shall determine will, together with the interesi to accrue ihereon and available moneys then on deposit in the filnds and accounts established pursuant to the Indenture or this Loan Agreemcnt, be fully sufficient to pay and discharge the indebtedness on the Series 2007A Loan or siich portion thereof (including all principal, interest and prepayment premiums) at or before maturity; then, at the election of the Ageiicy but only if all other amo�ints the» due and payahle hereu»der shall have been paid or provision for their payment made, the pledge of and licn upon thc Tax Revenues and other funds provided for in tliis Loan Agreement and all other obligations of the Trustee, the Authority and the Agency under this Loan Agreement with respect to the Series 2007A Loan or such portion thereof shall cease and terminate, except only the obligation of the Agency to pay or cause to be paid to the Trustee, from the amounts so deposited with the T'rustee or such other fiduciary, all sums due with respect to the Series 2007A Loan or such portion thereof, and to pay all expenses and costs of the Trustee when and as such expenses and costs become due and payable. Notice of such election shall be filed with the Authority and the Trustee. Any funds thereaRer held by the Trustee hereunder, which are not required for said purpose, shall be paid over to the Agency. ��ctiuii t>.4. Amendment. This Loan Agreement may be amended by the parties hereto but only under the circumstances set forth in, and in accordance with, the provisions of Section 5.8 of the Indenture. The Authority and the Trustee covenant that the Indenture shall not be amended, nor shall the Authority agree or consent to any amendment of the Indenture, without the prior written consent of the Agency (except that such consent shall not be required in the event that an Event of Default shall have occurred and be continuing hereunder). ��•cti��r� ��.�. Waiver of Personal Liability. No member, officer, agcnt or employee of the Agency shall be individually or personally liable for the payment of the principal of or interest on the Series 2007A Loan; but nothing herein contained shall relieve any such member, officer, agent or employee from the performance of any official duty provided by law. �:rtiv>> t>.c�. Pavtnent on Business Days. Whenever in this Loart Agreement any amount is required to be paid on a day which is not a Business Day, such payment shall be reyuired to be made on the Business Day immediately following such day, provided that interest ori such payment shall not accrue from and after such day. P(�4112-I(�5g,�12y17b��j duc � 1 �c� ric;n t�.--. Notices. Any notice, request, complaint, demand or other communication under this Loan Agreement shall be given in the same manner as provided in Section 1 l.13 of the Indenture, which is hereby incorporated. S:cti��n ��.� Ri�hts of Insurer.(a) As long as the Insurance Policy is in full force and effect with respect to the Bonds, the Agency shall, on an annual basis, furnish the Insurer with copies of its audited financial statements and its annual budget; and shal) deliver to the Insurer a copy of the disclosure document, if any, circulated with respect to any Parity Debt. (b) The Agency agrees to reimburse the Insurer immediately and unconditionally upon written demand thereof, to the extent permitted by law, for all reasonable expenses, including attorneys' fees and expenses, incurred by the Insurer in connection with (i) the enforcement by the Insurer of the Authority's or the Agency's obligations, or the preservation or defcnse of any rights of tt�e Insurer, under the Indenture or this Loan Agree�nent, and (ii) any consent, amendment, waiver or other action with respect to the Indenture or a�iy related cioc�iment, �vhether or not granted or appro��ed, and together witl�, if demanded by the (nst�rer in writin�, interest on all such expe»ses Irom and includi»� the ciate incurred to the ciate of payment at Citibailk's Primc Rate plus three percent or the maximum intcrest rate pcnnitted by la�v, whichever is lcss. In addition, thc Insurer reserves the right to charge a fee in co►�ncction with its review of any such consent, amendment or waiver, whether or not grantcd or approvcd. (c) The Authority and the Agency agree not to use the Insurer's name in any public document including, without limitation, a press release or presentation, announcement or forum without the Insurer's prior consent; provided however, such prohibition on the use of the Insurer's name shall not relate to the use of the Insurer's standard approved form of disclosure in public documents issued in connection with the Bonds; and provided further such prohibition shall not apply to the use of the Insurer's name in order to comply with public notice, public meeting or public reporting requirements. Scrtiui� ��.�). Suretv Bond. (a) To draw upon the Surety Bond pursuant to Section 2.5, the Trustee shall deliver to the Insurer a Demand for Payment, in the form attached to the Surety Bond, at least three days prior to the date on which funds are required under Section 3.3(a). (b) As security for its rights hereunder, the Insurer shall be deemed to have a security interest in the Tax Revenues, subject only to any security interest of the T'rustee or of the Owners of the Bonds or of the owners of any Parity Debt. (c) Notwithstanding the provisions of Section 6.3, this Loan Agreement shall not ierminate and no money shall be released by the Trustee to the Agency until alt sums owed to the Insurer by the Agency or the Authority under the terrns of the Financial Guaranty Agreement or any other document have been paid in full. (d) The Trustee shall maintain adequate records, verified with the Insurer, as to the amount available to be drawn at any given time under the Surety Bond and as to the amounts paid and owing to the Insurer under the terms of the Financial Guaranty Agreement. P(,�1u2-1u;8�9?�317(,.; doc 22 ���cti��n (�. I�>. Partial Invalidity. If any Section, paragraph, sentence, clause or phrase of this Loan Agreement shall for any reason be held illegal, invalid or unenforceable, such holding shall not affect the validity of the remaining portions of this Loan Agreement. The Agency hereby declares that it would have adopted this Loan Agreement and each and every other Section, paragraph, sentence, clause or phrase hereof and authorized the Series 2007A Loan irrespective of the fact that any one or more Sectians, paragraphs, sentences, clauses, or phrases of this Loan Agreement may be held illegal, invalid or unenforceable. �cctirn� (>. I 1. Article and Section HeadinQs and References. The headings or titles of the several Articles and Sections hereof, and any table of contents appended to copies hereof, shall be solely for convenience of reference and shall not affect the meaning, construction or effect of this Loan Agreement. All references herein to "Articles," "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of this Loan Agreement; the words "herein," "hereof," "hercby," "hereunder" and other words of similar import refer to this Loan Agreement as a whole and not to any particular Article, Section or subdivision hereof; and words of thc masculine gender shall mean and includc �t�ords of the feminine and ncuter genders. ���. t;��;� e,. i'. Execution of Counterparts. This Loan Agreement may be executed in any number of counterparts, eacl� of which shall for all purposes be deemeci to be an original and all of which shall together constitute but one and the samc instrumcnt. Sccti��� (�.I �. GoverninQ Law. This Loan Ageement shal] be construed and governed in accordance with the laws of the State. S�rti��i� (�.l�l. The Trustee. The Trustee is entering into this Loan Agreement solely in its capacity as Trustee under the Indenture and all provisions of the Indenture relating to the rights, privileges, powers and protections of the Trustee shall apply with equal force and effect to all actions taken by the Trustee in connection with this Loan Agreement. The Trustee shall be responsibie only for the duties of the Trustee expressly set forth herein. �Remuinder of Page Intentionally Left BlnnkJ PG4U7,- I U� J 92a I?r,� > doc 2? jPFajec! Area No. 1, As Amended, Loan Agreernenf) IN WITNESS WHERE4F, the AGENCY, the AUTHORITY and the TRl3S"FLE I��ve caused this Loan Agreement to be signed by their respective officers, all as of the clay arxi �ear �irst above written. PALM DESERT REDEVELOPMENT AGENCY : Executivc Dircctor PAI,M DF,SERT FINANCING AUTHORITY : Chief Administrative Officer WELLS FARGO BANK, NATIONAL ASSOCIATION as Trustee : Authorized Officer Phd11?-II�SH 7?�317���j doc �4 EXHIBIT A SCHEDULE OF SERIES 2007A LOAN PAYMENTS� Date Principal Interest Total 4/ 1 /2007 10/ 1 /2007 4/ 1 /2008 10/ 1 /2008 4/ 1 /2009 1 Ql l /2009 4/1/2010 10/1/2010 4/ 1 /201 I 10/1/2011 4/1/2012 10!1/2012 4/1/2013 10/1/2013 4/1/2014 10/ 1 /201 �1 4/11201 S 10/1i201� 4/1/2016 ]0/1/2016 4/1/2017 10/1/2017 4/1/2018 TOTAL * Payable semiannually on the fifth Business Day preceding each Interest Payment Date indicated on the leftmost column Pr�a��?-� ��58 9za► �G� s.doc A-1 L&J DRAFT �2 -- 11 /3/06 PRFI.1�11\.1R1 (1F'fl('1.11.�'f.1fF�lk:\"11)1fF:l)l1F:CF�16F12 .20116 NEW 1SSUE - BOOK-�NTRY ONLY RA1'INGS: �loodv's S&P INSURED: (See "RnTI�'GS" herein) !n the opinion oJRichards, �Vatson & Gershon, A Projessronu! Corpnrafion, Los Anbeles, Cu! jornia, Bnnd Counsel, based on e.rrsling lu�+� und �u.ivuning compl�nnce xith rertain crnenunts set jnrth m rhe documenu pei•rninrng ro the 2007 Serrrs .9 Bnnds ond requiremenu �%the Inrernul Reremue Codr o% 148b, as umend�c! (the ' Cude "), us described herern, interest on the 2�07 Serie.v A Bonds is not included in gross �nenme of 1he ox•ners thereoj Jnr jederal income tar purposes. !n rhe opinion oJeond Cnunsel, inleresr on the 2007 Series A Bnnds is not treuted as an item oJtux prejerence in culculatrng thrJederuJ ulternatrve mrnnnr�m [arahle income ojrndivrduals and corporaduns. Interest un the 2007 Series A Bnnd.s muy be suhject 10 cennin jedera! taxes imposed nn corpa•urronr, including the cnrpnrate al�ernative mrnrmum tar on u portion ojlhut interest. fn the jurrher upinion ojBond Counsel, interest on !he 2007 Serie,s A Bond.r es rxempl Jrnm persona! income tazes rmpnsed by� Ihe Srote olCuliJornia. See "TAX MA7'I'f•.RS" hcrein. [TO BE REVIEWED BY BOND COUNSEL] $ * PALM DESERT FINANCING AUTHORITY TAX ALLOCATION REFUNDING REVENUE BONDS (PRaJECT AREA NO. 1, AS AMENDED) 2007 SERIES A D�tcd: Date of Delivery Due: April l, as shown on the inside cover page Thrs cover puge conrarns certuin rnjormatrnn fr�r qurck rejerence on(�•. !t u not a summan� ojthese issues. /nvestors are uclvued to reud tlre entire O�Jrcia/ Stutement ro nhrain injormurion essentral to the makrng ojan injmned inveslment decisron. For a discussion of some of the nsks assoaated with the purchasc of the 2007 Scries A Bonds, sec "CF,R'fNT: RISKS TO BO�DHOLDERS." The Palm Desert Financing Authonry (the "Financing Autlioriry") is issumg b • principal amount of Palm Desert Financing Authonry Tax Allocahon Rcfunding Revcnuc Bonds (Pro�ect Area No. 1, As Amended) 2(�7 Scries A(thc "2007 Series A Bonds") to make a loan to tlie Palm Desert Rrdevclopment Agency (the "Rcdevelopmcnt Agency") pursuant to the terms of s Project Area No. I, As Amended, Loan Agrccment dated as of January I, 2007 (tlu "2007 Loan Agrccmcnt") by and among the Financing Authority, the Redcvelopment Agency and Wclls Fargo Bank, Netional Association (thc "Trustec"). The Redevelopment Agency will apply the proceed, of thc 2007 Loan to: (i) refinanec a portion of the outstanding obligations of the ReJevelopment Agency under a loan agreement dated as of July 1, 1997 (the "1997 Loan AgreemenP'); (ii) finance vanous redevelopment actrvrties within the Palm Desert Redevelopment Agency Project Arca No. 1, As Amended (the "Project Area"); xnd (iii) pny the costs associated with the issuance of die 2007 Senes A Bonds. See "PLAV OF FIVAVCE.�� l'he 2007 Scries A Bonds arc issued pursuant to an Indcnture uf Trust, dated as of lanuary 1, 2007 (the "2007 Indenture"), by and bct�rrern the Financing Authunty and thc Trustce The 2007 Scries A Bonds will be issued in bouk-entry fortn, mitially registercd in the name of Cede & Co. as nommec of the Depository Tnut Company, New York, Ncw York ("DTC"), who will act as xcurincs depository for the 2W7 Serics A Bonds. Individual purchases of thc 2007 Series A Bonds will bc in book- entry fonn only, and in denominations of $5,000. Purchasers will not reccive physical cernficntes representing their interesu m the 2007 Ser�es A k3onds. 1'rincipal of, interest on and redemption premium, if any, on the 2007 Scnes A E3ondti will be paid by thc Trustee dircctly to DTC, which m tum is obligated to rcmrt such pnncipal, intcrest, and redcmption premium, if any, to DTC Participants for subsequent disburscment to the Beneficial Owners of the applicable 2007 Scrics A BondS. SeC APPLNDIX G—"llTC MD 771E BOOK—E\TRY OvLY SYSTEM." Interest on the 2007 Series A Bonds will be payable vn cacli April I and October 1 of each year, commencing October 1, 2007 at the re,p��ctive rates set forth on the inside cover page, and pnncipal of the 2007 Serics A Bond, is payable on Apnl I of each yenr, commencing Apnl l, 200R in the amoimtti set torth on the inside covcr page. The 2007 Scries A Bonds are subject to opHonal and sinking account redemption as described hercin. Sce "7'HE 2W7 SeRies A Bonn� Redemption Prnvisinns." 7lic 2007 Scries A Bonds are special obligations of the Financing Authoriry payable from and secured by Revenues (as defined herein), consisting pnmarily of amounu payablc by thc Rcdevelopment Agency undcr the 2007 Loan Agreemcnt. The 2007 Loan Agreement is secured by and payable from tax incrcment revcnucs derived from property in the Project Area and allocated to the Redevelopment Agency pursuant to the Redevclopment Law. The 2007 Loan is payable on a panry basis with certain outstanding obhgations of the Redcvclopmcnt Ag�mcy remainmg made undcr loan agreements entcrui into m 1997 (thc "1997 Loan Agreement"), in 2002 (die "2002 Loan Agreement"), in 2003 (the "2003 Loan Agreement") in 2004 (the "2W4 Loan Agrecmcnt") and in 2006 (thc "2006 Loan Agrecmcnt"). The Redevclopmcnt Agcncy may, pursuant to thc ternu of the 2007 Loan Ab�rcemcnt and the 2007 Indenture, secure addiuonal obligations on a panry wnh the 2007 Loan, thc 2002 Loan, the 2003 Loan, the 2004 Loan and the 2006 Loaas. No funds or propernes of the Redevelopment Agency, other than thc Tax Rcv�nues xcure peyment of the 2007 Loan Agrecment. See "SECUR1lY nND SOURCES OF PnYMF:�T �OR THF. BOVDS—Panty Debt and Subordmate Debt." 'Ilie scheduled paymcnt of the principal and interest on the 2007 Serics A Bonds when due will be bvarantecd under a financial guaranry insurance policy to bc issued concurrcndy H�rth the delivery of the 2007 Series A Bonds by Mf3lA Insurance Corporation. [MBIA Logo] THE 2007 SFRIES A f30NDS ARE NOT A DEBT OF THE CITY OE PALM DESERT (Tfi� "CITY"), TIiE STATE OF CALIFORNIA (TIiE "STAT�") OR ANY OF ITS POLITICAL SUHDIVISIONS, OTIi�R TIiAN THE FINANCING AUTIIORITY, AND NONE OF TI�E CITY, THF STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, OTHER TNAN 77�E FINANCING AU7'HORITY, IS LIABLE THEREFOR. THE 2007 LOAN IS NOT A D�BT OF THE F'INANCING AUTHORITY OR THE STATE OR ANY OF ITS POLITICAL SUBD1V1S10NS, AND NON� OF TIi� FINANCING AUTFIORITY OR TlIE STATE OR ANY OF lTS PO[.IT[CAL SUBDIVISIONS, IS LIABLE THEREFOR. NONE OF THE MEMBERS OF THE FINANCING AUTIIORITY, THE CITY COUNCIL, TIIE REDEVELOPMENT AGENCY OR ANY PERSONS EXECUTING T{IE 2007 SERIES A BONDS OR THE 2007 LUAN AGRF�MENT ARt LIAk3Lf: P�RSONALLY WITH RESPECT TO THE 2007 SERIES A BONDS OR THF 2W6 LOANS. TIIF. OBL[GATIONS OF THk: RI:DF.VELOPMENT AG�NC:Y WITH RESPECT TO T71E 2007 LOAN IS PAYABLE SOLFLY FROM TtIE TAX REVENUtS (AS D�.FINHD FI�R�IN) AS SET FORTH 1N TIiE 2007 LOAN AGREEMENT. NEfTHER TFIE FINANCING AUTHORITY NOR THE REDEVELOPMENT AGENCY fIAS TAXING POWI:R. Tlu 2007 Series A Bonds are ofTcred when, as and if issued by the Financing Authority and received by the Undenvriter, sub�ect to the approval as to thcir lcgaliry by Richarde, Watsun & Gcrshon, A Professional Corporation, Los Angelcs, Califomia, Bond Counscl. Certam Icgal mattcrs will bc passcd upon for the Financing Authoriry and thc Rcdevelopment Agency by their Gcneral Counsel, Itichards, Watson & Gershon, A Professional Corporation and by LoRon & lennings, San Francisco, Califomia, Discloswe Counsel. It is anticipated that the 2007 Sencs A �3onds m book-entry only form will bc available for delivery tl�rough the facilrties of DTC in New York, New York on or about January 8, 2007. STONE & YOUNGBERG LLC Uated� , 2007 ` Preliminary, subject to changc. 0�042�pos-2 S * PALM DESERT FINANCING AUTHORITY TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED) 2007 SERIES A MATURITY SCHEDULE Base CUSIP: Maturity Date (Anril 11 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Principal Interest Amount Ratc Yield CUSIPf Copyright, Amcrican Bankers Association. CUSIP data hcrein is provided by Standard and Poor's, CUSIP Scrvicc Bureau, a division of Thc McGraw-Hill Companics, Inc. This data is not intendeJ to creatc a databasc and docs not serve in any way as a substitute for the CUSIY Service. CUSIP numbers are provided for convenience of reference only. None of thc Financing Authonty, the Redevelopment Agency or the Underwriter take any responsibility for the accuracy of such CUSIP numbers. The CUSIP number for a specific maturity is subject to being changed after the issuance of the 2007 Series A Bonds as a result of various subsequent actions including, but not limited to, a refunding in whole or in part of such maturity. 06(142�Yx�s-2 PALM DESERT FINANCING AUTHORITY PALM DESERT REDEVELOPMENT AGENCY CITY OF PALM DESERT FINANCING AUTHORITY COMMISSION Jim Fcrguson, President��� Richard S. Kelly, Vice President Jcan M. Benson, Commissionerr" Robert A. Spiegel, Commissioner Vacant, CommissronerJ2j REDEVELOPMENT AGENCY BOARD AND CITY COUNC[L Jim Ferguson, Chairmarr/Mayor��� Richard S. Kelly, Vice Chuirman/Mayor Pro Tem Jean M. Benson, Member/Councilmember��� Robert A. Spiegel, Member/Counci(nrember Vacant, Member/Councilmember�z� FINANCING AUTHORITY, REDEVELOPMENT AGENCY AND CITY STAFF Carlos L. Ortega, ChiefAdministrative O�cer/Executive Director/Ciry Manuger Paul S. Gibson, Treasurer%1'reasurer/Finance Director Rachelle D. Klassen, Secretary/Secretary/Ciry Clerk Justin McCarthy, Assistant City Manager/Redevelopment Shcila R. Gilligan, Assisrant Ciry Manager Community Services David L. Yrigoyen, Director oJRedevelopment and Housing David J. Erwin, Ciry Attorney Arla K. Scott, Senior Financial Analyst Veronica Tapia, Redevelopment Accountant SPECIAL SERVICES Richards, Watson & Gershon, A Professional Corporation Los Angeles, California Bond Cotinsel Wclls Fargo Bank, National Association Los Angcles, California Trustee Rosenow Spevacek Group Inc. Santa Ana, California Fiscal Consultant Grant Thomton LLP Minneapolis, Minnesota Verifrcution Agent Lofton & Jennings San Francisco, Califomia Disclosure Counsel Del Rio Advisors, LLC Modesto, Califomia Financial Advisor MuniFinancial Tcmccula, California Dissemination Agen1 (1) 7he tcmu fur these members of the financing Authonty and City Council cxp�rc in Novcmbcr 2W6. The persons rlectrd at thc November 20(K� Statewide General Electwn w�ll be swom m and take office December 14, 2006. (2) "Ihis vacancy will fx ti11cJ at the Novcmlxr 2006 StatewiJe General Election. The pecson clectcd to fill this posuion wdl be awom m:�nd takc ofl'ice on Dccember ]4, 2006. OGU42\p�s-2 GEI�ERAL INFORMATION ABOUT THIS OFFICIAL STATEMENT Use of OffrciaJ Statement The information set forth hercin has been fumished by thc Financing Authority, the Redevelopment Agency and the Ciry and includes information which has becn obtained from othcr sources which are believed to be reliable. The information and expressions of opinion contained hercin are subject to change without notice and neither the delivery of this Official Statement nor any sale made hereunder shall under any circumstances create any implication that there has been no change in the affairs of the Financing Authority and the Redevelopment Agency since the date hereof. Es[inra[es and Forecasts. Any statement made in this Official Statement involving any forecast or matter of estimates or opinion, whether or not expressly so stated, is intended solely as such and not as a representation of fact. Certain statements included or incorporated by reference in this Official Statement constitute "forward-looking statements" within the meaning of the United Statcs Private Securitics Litigation Reform Act of 1995, Section 21 E of the United States Securities Exchange Act of 1934, as amended, and Section 27A of the United States Securities Act of 1933, as amended (the "Securities Act"). Such statements are generally identifiable by the terminology used, such as "plan," "expect," "estimate," "budget" or other similar words. Such forward-looking statcments include, but are not limited to, certain statements contained in thc information under the caption "THE PROJECT ARLA" and contained in APPENDIX A-"REPORT OF THE FISCAL CONSULTANT." The achievement of certain results or other expectations contained in such forward-looking statements involves known and unknown risks, uncertainties and other factors which may cause actual results, performancc or achievements describcd to be materially different from any futurc results, performance or achievements expressed or implied by such forward-looking statements. The Financing Authority and the Redevclopment Agency does not plan to issue any updates or revisions to thosc forward-looking statements if or when their expectations, or events, conditions or circumstances on which such statecnents are based occur. Limit oJ Offering. No dealer, broker, salesperson or other person has been authorized to give any information or to make any representations in connection with the offer or sale of the 2007 Series A Bonds by thc Financing Authority, thc Redevelopment Agcncy or the Underwriter, other than thosc contained in this Official Statement, and, if given or made, such other information or representations must not be relied upon as having been authorized by the Financing Authoriry and the Redevelopment Agency. This Official Statemcnt does not constitute an offcr to sell or the solicitation of an offer to buy, nor shall thcre be any sale of the 2007 Series A Bonds by any person in any jurisdiction in which it is unlawful for such person to make such an offer, solicitation or sale. Involvement of Underwriter. The Underwriter has provided thc following scntcnce for inclusion in this Of�icial Statement: The Underwriter ha.s reviewed the information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applicd to the facts and circumstances of this transaction, but the Underwriter does not guaranty the accuracy or complctcness of such information. In connection with the offering of the 2007 Series A Bonds, the Underwriter may overallot or effect transactions that stabilize or maintain the market price of the 2007 Series A Bonds at a lcvel above that which might otherwisc prevail in the opcn market. Such stabilizing, if commenced, may be discontinued at any timc. Thc Underwriter may offer and scll the 2007 Serics A Bonds to certain dcalers and others at priccs lower than the public offcring priccs set forth on the inside cover page hereof and said public offering prices may be changed from time to time by the Underwriter. The 2007 Scries A Bonds have not been rcgistered under the Securities Act of 1933, as amendcd, in reliance upon an exemption from the regish-ation requirements contained in such Act. The 2007 Scrics A Bonds have not been rebistered or qualified undcr the securitics laws of any state. oboaz��,s-z �i TABLE OFCONTENTS Pa�e INTRODUCTION .................................................. 1 General; Authority for Issuance ....................... 1 Purpose............................................................. 1 7'hc City ............................................................2 The Financing Authority .................................. 2 The Redevelopment Agency ............................ 2 Thc Projcct Area ...............................................2 Security for the 2007 Series A Bonds .............. 2 Bond lnsurancc .................................................5 Report of the Fiscal Consultant ........................ 5 Ccrtain Risks to Bondholders ...........................5 Continuing Disclosure ...................................... Additional Information ..................................... 5 6 PLAN OF REFUNDING ........................................6 Rcfunding of Prior Bonds ................................. 6 Redevelopment Projec�s ................................... 7 Estimated Sources and Uses of Funds .............. 8 Debt Service Schcdules .................................... 8 T�IE 2007 SERIES A BONDS ...............................9 Gcneral............................................................. 9 SECURITY AND SOURCES OF PAYMENT FOR THE BONDS ................... 11 Revenucs and Loan Agrecments .................... 11 Tax Rcvenucs ................................................. 12 Tax Allocation Financing ............................... 13 Redevelopment Plan Limitations ................... 13 Allocation of Taxes ........................................ 15 Rcservc Fund .................................................. 16 Parity Debt and Subordinate Debt .................. 17 Investment of Funds ....................................... 18 FINANCIAL GUARANTY INSURANCE..........18 MBIA Insurancc Corporation ......................... 18 Rcgulation...................................................... 18 Financial Strcngth Ratings of MBIA .............. 19 MBIA Financial Information .......................... 19 Experts............................................................ 20 LIMITATIONS ON TAX REVENUES ...............21 Artic�e XIII A of the Statc Constitution ......... 21 Article XIII B of the State Constitution; Appropriation Limitations ........................22 Articles XIII C and XII1 D of the State Constitution .............................................. 23 Paec Taxation of Unitary Property ......................... 23 Property Tax Collection Procedures .............. 24 Property Tax Administrative Costs ................ 25 Housing Set-Asidc ......................................... 25 Stipulation Agreement ................................... 26 Certification of Redevelopment Agcncy lndebtedness ............................................. 26 Pass-Through Agreements and Tax Sharing Paymcnts ..................................... 27 Limitation of Tax Revenues from Certain Increased Tax Rates ..................... 28 Ballot Initiatives and Legislative Matters ...... 28 CERTAIN RISKS TO BONDHOLDERS............ 29 Added Territory Projected to Reach Limit in Fiscal Ycar 2021-22 ................... 29 Accuracy of Assumptions .............................. 29 Reduction of Tax Revenues ........................... 30 Reductions in Unitary Valucs ........................ 30 Appcals to Asscsscd Valucs ........................... 30 Rcduction in Inflation Rate ............................ 31 Bankruptcy and Foreclosure .......................... 31 Delinquencies ................................................. 32 State Budgct ................................................... 32 Natural Disastcrs ............................................ 33 Hazardous Substances .................................... 34 Loss of Tax Exemption .................................. 34 Risk of Tax Audit ........................................... 34 Secondary Market .......................................... 35 THE FINANCING AUTHORITY ....................... 35 THE REDEVELOPMENT AGENCY ................. 35 Authority, Members and Personnel ................ 35 Powcrs............................................................ 37 Redevelopment Agency Finances .................. 37 THE PROJECT AREA ......................................... 38 General........................................................... 3 8 Redevelopment Plan Limits ........................... 39 Controls, Land Use and Building Rcstrictions ............................................... 40 Summary of Dcvelopment ............................. 42 Principal Taxpaycrs ........................................ 42 TaxRates ........................................................ 45 Historical, Current and Projcctcd Tax Revenues .................................................. 46 o�oa2��,s-z iii Debt Service Coverage Projcctions ................50 Asscssment Appcals ....................................... 52 Tax Levies, Collections and Delinquencies ........................................... 54 TAX MATTERS ...................................................55 APPROVAL OF LEGAL PROCEEDINGS......... 56 ABSENCE OF MATERIAL LITIGATION ......... 57 Gencral........................................................... 57 Other Matters .................................................. 57 FINANCIAL ADVISOR ...................................... 57 CONTINUING DISCLOSURE ............................ 57 VERIFICATION OF MATHEMATICAL COMPUTATIONS ....................................... 58 UNDERWRITING ............................................... 58 RATINGS............................................................. 58 FINANCIAL STATEMENTS .............................. 59 MI SCELLANEOU S ............................................. 59 MAPS AND TABLES CityLocation Map .............................................................................................................................................viii ProjectArca Map ................................................................................................................................................ ix Tablc1- Prior Bonds ........................................................................................................................................ 7 Table 2A - Original Area—Summary of Redevelopmcnt Plan Limits .............................................................. 39 Table 2B - Added Territory—Summary of Redevelopmcnt Plan Limits ..........................................................40 Table3- Land Uses by Category ...................................................................................................................41 Tablc4 - Principal Taxpaycrs .........................................................................................................................43 Table 4A - Original Area - Principal Taxpayers ...............................................................................................44 Tablc 4B - Added Territory - Principal Taxpayers ...........................................................................................44 Table5- Breakdown of Tax Rate .................................................................................................................. 45 Table 6A- Original Area—Historical Taxablc Values and Tax Increment Revenues ..................................... 47 Table 6B - Added Temtory—Historical Taxable Values and Tax Increment Revenues ................................. 48 Table 7A - Original Area—Projection of Incremental Taxable Value and Tax Increment Revenue ...............49 Table 7B - Added Territory—Projcction of Incremcntal Taxable Value and Tax Incremcnt Revenue........... 50 Table 8- Projected Tax Increment Revenues and Debt Service Coverage ...................................................51 Table 9A - Original Area —Assessment Appeals .............................................................................................. 53 Table 9B - Added Territory—Assessment Appcals ...........................................................................................53 Tablc 10 - Outstanding Appeals by the Top Ten Taxpayers ........................................................................... 54 obcwz��,s-z iv APPENDICES APPENDIX A- REPORT OF THE FISCAL CONSULTANT ...........................................................A-1 APPENDIX B- REDEVELOPMENT AGENCY AUDITED FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED JUNE 30, 200[5] ............................................... B-1 APPENDIX C- GENERAL INFORMATION CONCERNING THE CITY OF PALM DESERT ..C-1 APPENDIX D- SUMMARY OF PRINCIPAL LEGAL DOCUMENTS ............................................D-1 APPENDIX C- PROPOSED FORM OF BOND COUNSEL OPINION ............................................ E-1 APPENDIX F- FORM OF CONTINU]NG DISCLOSURE AGREEMENT ..................................... F-1 APPENDIX G- DTC AND THE BOOK-ENTRY ONLY SYSTEM ..................................................G-1 APPENDIX H— SPECIMEN FINANCIAL GUARANTY INSURANCE POLICY ...........................H-1 o�,��az��5-z v ; `Nr��sl';y City of Palm Desert �y, O' d r�' �? JAH•SHORE�DR � �O � , ♦ < � � � > W � K '�� W � Redevelopment " Agency GERAI•D•FORD•DR � Project Areas W > - -- � � (GL STATE, USBi n m ��'C�.. U� i DESERT WILLOW PUBL►C OOLT COURSE' i ,��� CE1Yl'ER ^ , COLiEC�E OF TXE DESERT. Projecl�a No U;L� z � Oii inal � � s � g 1975 --' WE.STFIELD � ' EL-PAS O�-} SFIOPP/NGTOWN � �.MOUNTAIN•DR=�- ' � . � � � =O� I y < � � GRAPEVINEBT S � � � � _� � ' _ , _ _ ' _ H .YSTA� RD� � i � � MESA•VIEWDltvppR•TOb�'' � Project Area No. 1 i'. �' � 1 1 1 ' � � ' � . Added Terntory 1982 ♦ ' •� � BfOHORN� � _ �� ,� 1 1 � � 1 • , � � � FRAN K• Area No. 2 '987 � �� , . /TCLTUB'DR y �COUNdR+/.EL•UB�DR� 1 K � N Q � •y L% m 8 � � J � � U I (I) iif I N�E I I \ i O Project Area No. 3 � •� • �1991 � ' IOVL•EY L-N•C � Project Area No. 4 9993 � �` "��; � ED�W �RING�Df" r TfIE ENS � l AT EL PA3E0 -FAIRVVAI DR r� .�:` t 3 NG'OR RDA Project Areas 0 Project Area No. 1- Original (1975) � Project Area No. 1- Added Territory (1982) � Project Area No. 2(1987) � Project Area No. 3(1991 } � ProjectArea No. 4 (1993) � � � Ci Limits L . _ tY - Parks and Open Space N W�E s 0 os � � M es MARCH, 2006 vi Project Arca Map 06042�pos-2 Vll S * PALM DESERT FINANCING AUTHORITY TAX ALLOCATION REFUNDING REVENUE BONDS (PROJECT AREA NO. 1, AS AMENDED) 2007 SERIES A INTRODUCTION This intr•oduction contains only a 6rief summary of cer•tain oJ the term.s oj the 2007 Series A Bond.s being offerecl, und a full reviex� should be made of !he entire Offtcial Statement including the cover page, the table oJcontents and the appendices for a more complete description oI the terms ojthe 2007 Series A Bnnd.s. A[l stutements contained in this introduction are gualired in their• entirery 6y rejerence to the entire O�cia! Statement. References to, and strmmaries of provisions of, any othef• documents referred to herein do not purport to be complete and such references ure qualified in tlreir entirery by rejerence to the complete� provisions ofsuc•h documents. Cencral; Authority for Issuance The purpose of this Official Statcment, including the cover page, inside cover page and appendices, is to furnish inforcnation in connection with the sale and delivcry by the Palm Desert Financing Authority (the "Financing Authority") of $_,_,000* aggregate principal amount of Palm Desert Financing Authoriry 'Tax Allocation Bonds Refunding Revenue Bonds (Project Area No. 1, As Amended) 2007 Scries A(thc "2U07 Scrics A Bonds"). The 2007 Scries A Bonds are issued pursuant to the provisions of the Mark-Roos Local Bond Pooling Act of 1985, consisting of Article 4 of Chapter 5 of Division 7 of Title 1(commencing with Section 6584) of the California Government Code (the `Bond Law"). The 2007 Series A Bonds will be issued pursuant to an Indenture of Trust, dated as of January 1, 2007 (the "2007 Indenture"), by and between the Financing Authority and Wells Fargo Bank, National Association (thc "Trustee"). Purposc The proceeds of the 2007 Series A Bonds will be used by the Financing Authority to makc a loan (thc "2007 Loan") to the Palm Descrt Redevelopment Agency (the "Redcvelopment Agcncy") pursuant to a Projcct Area No. 1, As Amended, Loan Agrecment made and entered into as of January I, 2007 (the "2007 Loan Agreement") by and among the Financing Authoriry, the Redevclopment Agency and the Trustcc. The Redcvelopment Agency will apply the proceeds of the 2007 Loan to: (i) rcfinance a portion of the outstanding obligations of the Redevelopment Agency under a loan agreement dated as of July l, 1997 (the "1997 Loan Agrecment"); (ii) finance various redevelopment activities within the Palm Desert Redevclopmcnt Agency Projcct Area No. 1, As Amended (the "Project Arca"); and (iii) pay the costs associated with the issuance of thc 2007 Series A Bonds. See "PLAN OF FINANCG," "ESTIMATED SOURCES AND USGS OF FUNDS" and "TrIE PROJC•CT AREA—Summary of Dcvelopment." Thc 2007 Scries A Bonds will mature in the years and amounts and bcar interest at the ratcs set forth on thc inside cover pagc. ' Preliminary, subjcct to changc. 06042�s-2 Thc City The Ciry of Palm Desert (the "City") is located in thc Coachella Valley and is approximately mid- way between the citics of Indio and Palm Springs, 1 17 miles cast of Los Angeles, I 18 miles northeast of San Diego and 515 miles southeast of San Francisco. According to the State Department of Financc, the City population as of January 1, 2006 was approximately 45,539. The 2007 Series A Bonds are not an obligation of thc City. For certain information regarding the City, see APPENDIX C—"G�NERAL INFORMATION CONC[RNING THE CITY OF PALM DESERT." The Financing Authority The Financing Authority is a joint exercise of powers agency organized under the laws of the State of California (the "State") and composed of the Ciry and the Redevelopment Agency. The Financing Authoriry was fonncd pursuant to a Joint Exercise of Powcrs Agreement, dated January 26, 1989 by and bctwecn thc City and the Redevelopment Agency to assist in the financing of public capital improvements. See "7'F�� FINANCING AUTHORITY." The Redevclopmcnt Agency The Redcvelopment Agency was activatcd by the City in 1974 and is authorized to exercise the powcrs grantcd by the Communiry Redevelopment Law of the State of Califomia (constituting Part 1 of Division 24 of the Health and Safery Code of the State of California, commencing with Section 33000) (the "Redevelopmcnt Law") and, by an ordinance, the Ciry Council of the Ciry (the "City Council") dcclarcd itsclf to be the Redevelopment Agency. Although the Redevelopment Agency is an entity distinct from the Ciry, certain City personnel provide staff support for thc Rcdevelopment Agcncy. See "THE RLDEV6LOPMET�iT AGENCY." The Project Area The Project Area was formally established with thc adoption by the City Council of a redcvelopment plan (the "Original Plan") for approximately 580 acres (the "Original Area") pursuant to Ordinance No. 80, adopted on July 16, 1975. Approximately 5,240 acres (the "Added Temtory") wcre added to the Original Area pursuant to amendments to the Original Plan approved and adopted by the City Council by Ordinance No. 275, adopted on November 25, 1981 and Ordinance No. 324, adopted on October 13, 1983 (collectively, thc "Amendments"). The Original Plan, as amended by the Amendments, is referred to as the "Redevelopment Plan." The Project Area contains approximately 5,820 acres, comprising approximately 12,825 parcels within the City. See "THE PROJECT ARGA." Security for the 2007 Series A Bonds Tax Allocation Financing. Thc Redevelopment Law provides a means for financing redevelopment projccts based upon an allocation of property taxes collected within a project area. Subject to thc more dctailcd discussion contained under the caption "SECURITY AND SOURCES OF PAYMENT FOR THE BONUS," the taxable valuation of a project area last cqualized prior to adoption of the redevelopmcnt plan, or base roll, is establishcd and, except for any period during which thc taxable valuation drops below thc base ycar level, or as may otherwise be agreed to among taxing agencies, the taxing agencies thereafter receive the taxes produced by the levy of the then current tax rate upon the base roll. Taxes collected upon any increase in taxablc valuation over the base roll (except such portion benerated by rates levied to pay voter-approvcd bonded indebtcdness after January 1, 1989 for the acquisition or improvecncnt of real property), gcnerally refcrred to as tax increment revenues, are allocated to a redcvelopment agency and may be pledgcd by a rcdevclopment agency to the rcpayment of any indebtedness incurred in financing or refinancing a rcdevelopmcnt project. Sec "SECURITY AND SOURCES OF PAYMENf FOR THE BONDS." Rcdevclopment 06042�pos-2 agencies themselves havc no authority to levy property taxes and must look specifically to the allocation of� taxcs described above. Any future decrease in the taxable valuation in the Project Arca or in the applicablc tax rates will rcduce the Tax Rcvenues allocatcd to thc Redcvelopment Agency from the Project Area and conscquently may have an adverse impact on the ability of the Redevelopment Agency to pay debt service on the 2007 Scnes A Bonds. See "CERTAIN RISKS TO BONDHOLDERS." Pledge of Tax Revenues. The 2007 Scries A Bonds are secured by a first lien on and pledgc of Rcvenues consisting primarily of amounts paid by the Redevclopmcnt Agency to thc Financing Authority pwsuant to the 2007 Loan Agreement and certain other funds held by the Trustee pursuant to the 2007 Indenturc. The Redevelopment Agcncy is obligated undcr thc 1997 Loan Agreement, a loan agreement madc and cntered into as of March 1, 2002 (the "2002 Loan Agrcemcnt"), a loan agreement made and entered into as of July I, 2003 (the "2003 Loan Agrcement"), a loan ageemcnt made and entered into as of Junc 1, 2004 (the "2004 Loan Agreemcnt") and a loan agrcements made and entered into as of July 1, 2006 (the "2006 Loan Agrecment") to pay from Tax Revenues (defined below) the amounts set forth in the 2002 Loan Agreement, the 2003 Loan Agrccment, the 2004 Loan Agrcement and the 2006 Loan Agrcemcnt, respectively. See "SECURITY AND SOURCGS OF PAYM[NT FOR THG BONDS." The obligations of thc Redcvelopment Agency undcr thc 2007 Loan Agreement are on a pariry with thc loan obligation that will remain outstanding under the 1997 Loan Agreement and thc loan obligations under the 2002 Loan Agreemcnt, the 2003 Loan Agreemcnt, the 2004 Loan Agreement and thc 2006 Loan Agrccment (collcctively with the 2007 Loan Agreement, the "Parity Loan Agreements") as describcd below. The loans incurred by the Redcvelopment Agency arc referred to as the "2007 Loan," thc "2002 Loan," thc "2003 Loan," the "2004 Loan" and the "2006 Loans," respcctively. No funds or properties of the Rcdevelopment Agency, other than ihe Tax Revenues, secure payment obligations under the Parity Loan Agrcemcnts. 1997 Loan Aereement. Following the issuance of the 2007 Series A Bonds, the 1997 Loan Agreement will secure repayment of $2,065,000 outstanding principal amount of Palm Descrt Financing Authority Tax Allocation Rcfunding Revenue Bonds (Project Area No. 1, As Amended), Serics 1997, which mature April 1, 2007 (the "Remaining 1997 Series Bonds"). 2002 Loan Aereement. The 2002 Loan Agrcement secures repaymcnt of $22,U70,000 outstanding principal amount of Palm Desert Financing Authority Tax Allocation Refunded Revenue Bonds (Project Area No. 1, As Amended), Series 2002 (the "Series 2002 Bonds"), which wcre issucd pursuant to an Indenturc of Trust dated as of March 1, 2002 (the "2002 Indenture") by and bctwecn the Financing Authority and BNY Western Trust Company, as prior trustee. 2003 Loan Aareement. The 2003 Loan secures repayment of � 19,000,000 outstanding principal amount of Palm Desert Financing Authority Tax Allocation Revenuc Bonds (Project Area No. 1, As Amended), Series 2003 (the "Series 2003 Bonds"), which were issued pursuant to an Indenture of Trust dated as of July I, 2003 (thc "2003 Indenture") by and between the Financing Authority and BNY Western Trust Company, as prior trustee. 2004 Loan A�recment. The 2004 Loan Agreement secures rcpayment of �23,595,000 outstanding principal amount of Palm Descrt Financing Authority Tax Allocation Rcfunding Revcnue Bonds (Project Area No. 1, As Amended), Series 2004 (the "Series 2004 Bonds"), which were issued pursuant to an lndenture of Trust dated as of June 1, 2004 (the "2Q04 Indenturc") by and bctween the Financing Authority and BNY Westcrn Trust Company, as prior trustce. o��oaz�s-Z 2006 Loan Aercement. Thc 2006 Loan Agreement secures repayment of $37,780,000 outstanding principal amount of Palm Dcsert Financing Authority Tax Allocation Revcnue Bonds (Project Arca No. 1, As Amended), 2006 Serics A and 524,540,000,000 outstanding principal amount of Palm Desert Financing Authority Tax Allocation Rcfunding Revenue Bonds (Projcct Area No. 1, As Amended), 2006 Series B(Taxablc) (together, the "2006 Serics Bonds"), which werc issucd pursuant to an Indenture of Trust dated as of July 1, 2006 (the "2006 Indcnture") by and betwccn the Financing Authoriry and the Trustee. The Remaining 1997 Series Bonds, the Series 2002 Bonds, the Series 2003 Bonds, thc Series 2004 Bonds and the 2006 Series Bonds are rcferred to collectively, as the "Parity Bonds." 71�e Redevelopment Agency has pledgcd for thc repayment of the 1997 Loan, thc 2007 Loan, the 2002 Loan, thc 2003 Loan, the 2004 Loan and the 2006 Loans monies allocated or paid to the Redevelopment Agency derived from: that portion of taxes levied upon taxablc property within thc Project Arca allocatcd and paid into the Special Fund of the Rcdevelopmeni Agency pursuant to Article 6 of Chaptcr 6 of the Redcvclopment Law and Section 16 of Articic XVI of the Constitution of the State of Califomia (thc "State"), exclusive of amounts placed in the low and moderate income housing fund of the Redcvelopment Agency pursuant to Sections 33334.2 and 33334.3 Rcdevelopmcnt Law (see also "—Stipulation Agreemcnt") and excluding amounts payable to local taxing agencies pursuant to pass-through agreements (collectively, the "Pass-Through Agreements") or pursuant to Section 33607.5 or 33607.7 of the Redcvclopmcnt Law (collectively, [he "Tax Revenues"). See "SGCURITY AND SOURCES OF PAYMENT FOR THE BONDS," "Lltvt�T,aT►orvs ON TAx REVENUEs—Pass-Through Agreements and Tax Sharing Payments" and "CBRTAIN RISKS TO BONDHOLDGRS." Thc Original Area has a Base Ycar Valuc of $27,485,836 that was established based on the asscsscd value for 1976-776 Fiscal Ycar and the Added Temtory has a Base Yeaz Value of $656,065,059 that was established based on the assessed value with respect to the 1982-83 Fiscal Year, each of which were last equalized prior to thc respective effective datc of the ordinance approving the redcvelopment plan and thc amendmcnt thereto. The Added Territory is projected to reach its $500 million tax increment revenue limit in Fiscal Year 2020-21. See "SECURITY AND SOURCES OF PAYMENT FOR THE BONDS—Rcdevelopment Plan Limitations" "CERTAIN RISKS TO BOND[iOLDERS—Added Territory Projected to Reach Revenue Limit in Fiscal Year 2021-22" and "THE PROJECT AREA—Redevelopment Plan Limits." S[ipulation Agreement. On May 15, 1991, a Stipulation for Entry of Judgment, as amcnded (the "Stipulation") was entcred into among the Redevelopment Agcncy, thc Western Center on Law and Poverty, Inc. and the California Rural Legal Assistance, whereby, among other things, the Redevelopment Agency agreed that future indebtedncss would be payable senior to obligations imposed by the Stipulation provided ccrtain findings were made by thc Redevelopment Agency, except, in cases, such as this transaction, where debt scrvice savings can be dcmonstrated. Sec "LIMITATIONS ON TAX RGVENLIES—Stipulation Agree►ncnt." Reserve Fund. As additional security for the payment of the Parity Loans by thc Redcvelopment Agency, a reservc fund (the "Reserve Fund") was established. The Rescrve Fund is required to be maintained in the amount cqual to the Rcserve Requirement (as dcfined herein). Amounu on dcposit in the Reservc Fund will be used for the payment of debt service on the Parity Bonds in the event that amounts on deposit in thc applicable Interest Account or the Principal Account held under the respective Indenture arc insufficient therefor. See "SECURITY AND SOURCES OF PAYIvtENT FOR THE BONDS—Reserve Fund." Following thc issuance of the 2007 Series A Bonds, the Reserve Requiremcnt for the 2007 Serics A Bonds and the Parity Bonds will bc S . oboaz��os-z 4 THE 2007 SERIES A BONDS ARE NOT A DEBT OF THE CITY, THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, OTHER THAN THE FINANCING AUTHORITY, AND NONE OF THE CITY, THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, OTHER THAN THE FINANCING AUTHORITY, IS LIABLE THEREFOR. THE 2007 LOAN IS NOT A DEBT OF THE FINANCING AU"I'HORITY OR THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, AND NONE OF THE FINANCING AUTHORITY OR THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, IS LIABLE THEREFOR. NONE OF THE MEMBERS OF THE FINANCING AUTHORITY, THE CITY COUNCIL, THE REDEVELOPMENT AGENCY OR ANY PERSONS EXECUTING THE 2007 SERIES A BONDS OR THE 2007 LOAN AGRE6MENT ARE LIABLE PERSONALLY WITH RESPECT TO THE 2007 SERIES A BONDS OR THE 2007 LOAN. THE OBLIGATIONS OF THE REDEVELOPMENT AGENCY WITH RESPECT TO THE 2007 LOAN IS PAYABLE SOLELY FROM THE TAX REVENUES (AS DEFINED HEREIN) AS SET FORTH IN THE 2007 LOAN AGREEMENT. NEITHER THE FINANCING AUTHORITY NOR THE REDEVELOPMENT AGENCY HAS TAXING POWER. Bond Insurancc Payment of the principal and interest on thc 2007 Series A Bonds when due will be insurcd by a financial guaranry insurancc policy (the "Insurancc Policy") to bc issued simultaneously with thc cxecution and delivcry of the 2007 Serics A Bonds by MBIA Insurancc Corporation (the "Bond Insurcr"). Scc "FINANCIAL GUARANTY INSURANCE" and APPENDIX H—"SPECIMEN FINANCIAL GUARANTY INSURANCE POLICY." Report of thc Fiscal Consultant Included as Appcndix A to this Official Statement is a report (thc "Report of the Fiscal Consultant") prepared by Roscnow Spevacek Group Inc. (the "Fiscal Consultant") which, among othcr things, analyzes the Tax Revenues generated frocn taxable property within the Project Area and pledged to the repayment of the Bonds. The findings and projections in thc Report of the Fiscal Consultant are subject to a number of assumptions that should be reviewed and considered by prospcctive investors. No assurances can be givcn that the projcctions and expectations discussed in the Report of the Fiscal Consultant will be achievcd. Actual results may differ materially from the projcctions described therein. See APPEAiDtX A—"RGPORT OF THB FISCAL CONSULTANf." Certain Risks to Bondholdcrs Investment in the 2007 Series A Bonds involvcs risk. For a discussion of ccrtain considerations rcicvant to an invcstment in the 2007 Series A Bonds, sec "CERTAIN RISKS TO BONDHOLDERS." Continuing Disclosure The Redevelopment Agency has agreed to provide, or cause to be provided, to cach nationally recognized municipal securities information repository or the Municipal Securities Rulemaking Board and any public or private repository or entity designated by the State as a state rcpository for purposcs of Rulc 15c2-12(b)(5) adopted by the Securities and Exchange Commission certain annual financial information and operating data and, in a timely manner, notice of certain material events. These covenants have been made in order to assist the Underwriter in complying with the Securities and Exchange Commission Rule 15c2-12(b)(5). Sce "CONTINUING DISCLOSURG" and APPENDIX F—"FORM OF CONTINUiNG DISCLOSURE AGRGGMENT" for a description of the specific nature of the annual report and notices of material events and a summary description of the terms of the disclosure agreement pursuant to which such reports are to be made. 06042�pos-2 The Redevclopment Agency has never failed to comply in all material respects with any prcvious undcrtakings with regard to said Rule to provide annual reports or notices of material events. Additional Information This Official Statement contains summarics of the 2007 Series A Bonds, the security for the 2007 Series A Bonds, the 2007 Indenture, the 2007 Loan Agreemcnt, the Rcdevelopment Law, the Redevelopment Agency, the Project Area and certain other information relevant to the issuance of the 2007 Series A Bonds. All referenccs herein to the 2007 Indenture and the 2007 Loan Agrccment are qualified in their entirety by reference to the complete text thereof and all references to the 2007 Series A Boncis are further qualified by rcference to thc form thercof contained in the applicable 2007 Indenture. The audited financial statements of the Rcdevelopment Agency for the Fiscal Ycar ended June 30, 200[5] arc included in APPENDIX B. Thc proposed form of legal opinion of Bond Counscl for the 2007 Series A Bonds is set forth in APPet�rDlx E. See APPENDIX �"SLTMMARY OF PRINCIPAL LEGAL DOCLJMBNTS" for definitions of certain words and terms used hcrein. All capitalized terms used in this Official Statement and not otherwise defined herein have thc samc meanings as in thc applicablc 2007 Indcnture. The information set forth herein and in the Appendices hereto has been fumished by the Redevelopment Agency and the City and includes information which has bccn obtaincd from other sources which arc believed to be reliable but is not guaranteed as to accuracy or completeness by the Financing Authoriry or the Undcrwriter and is not to be construed as a representation by the Underwriter. Copies of documents rcferred to hcrein and information concerning thc 2007 Series A Bonds are available upon written rcquest from the Senior Financial Analyst of the Redevelopment Agency, 73-510 Fred Waring Drive, Palm Desert, Califomia 92260-2578; tclephone: 760-346-0611. The Redevelopment Agency may impose a charge for copying, mailing and handling. PLAN OF REFUNDING Refunding of Prior Bonds The Financing Authority will loan the procccds of the 2007 Series A Bonds to the Redevelopment Agency. The Redevelopment Agency will use a portion of thc procecds of the 2007 Loan to prepay certain amounts that rcmain due with respect to the 1997 Loan Agrccment. The Financing Authority will usc thosc prepaid loan amounts to refund a portion of the Palm Desert Financing Authority Tax Allocation Revenue Bonds (Project Area No 1, As Amcnded), Series 1997 in the principal amount of $31,855,000 (the "Prior Bonds"). Such proceeds of the 2007 Series A Bonds will be deposited in an escrow fund (the "Escrow Fund") to be held by Wclls Fargo Bank, National Association, as escrow bank (the "Escrow Bank") pursuant to an Escrow Agreement dated as of January 1, 2007 (the "Escrow Agreement"), by and among the Financing Authority, the Redevelopment Agency and thc Escrow Bank. Followin� the refunding of the Prior Bonds, there will be S2,065,000 principal amount of Series 1997 Bonds outstanding which mature on April 1, 2007. The amounts deposited under the Escrow Agrcement will be held by the Escrow Bank and invested in 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 mature or be withdrawable, as the case may be, not latcr than thc timc when needed for thc payment or redemption of the Prior Bonds in order to discharge thc pledgc of the lien securing the Prior Bonds (collectively, "Escrow Securities"). Thc principal of and interest on such Escrow Securities, when received, will be sufficient to pay the principal or redemption price of, including premium, and intcrest on the Prior Bond upon redemption thcreof. Upon delivcry of thc 2007 Bonds, the Prior Bonds will be irrevocably called for redemption on April 1, 2007 as specified below. Sce also "V�RIFICATION OF MATHEMATICAL COMPUTATIONS." 06042�,oa-2 The Prior Bonds to be refunded consist of the following: Tablc l $31,855,000 Palm Desert Financing Authority Tax Allocation Revenue Bonds (Project Area No 1, As Amended), Series 1997 Dated Date: July 1997 Maturity Date (Anril 11 2008 2009 ZO10 2011 2012 2014 ?018 Amount $2,290,000 2,255,000 2,505,000 2,495,000 2,755,000 5,830,000 13,725,000 Intcrest Rate 4.90% 5.00 5.10 5.15 5.20 5.35 5.45 CUSIP (696617)' Payment or Redemption Datc (April 11 2007 2007 2007 2007 2007 2007 2007 Rcdcmption Price 102% 102 102 102 102 102 102 Copyright, Amcrican Bankers Association. CUSIP data herein is provided by Standard and Poor's, CUSIP Service Burcau, a division of The McGraw-Hill Companies, Inc. This data is not intended to create a database and dces not scrve in any way as a substitute for the CUSIP Service. CUSIP numbers are provided for convenience of reference only. None of the Authority, the City or the Underwriter take any responsibility for the accuracy of such numbers. Redevelopmcnt Projects A portion of the remaining procecds of the 2007 Loan will be used by the Redevelopmcnt Agcncy to financc ccrtain redcvclopment activities within the Project Area. Sce "THE PRO.TECT AREA—Summary of Devclopment—Redevelopment Agency Projects." (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) o���sz��o,-z Estimated Sources and Uses of Funds The anticipated sourccs and uses of funds rclating to the 2007 Series A Bonds are as follows: Sources: Principal Amount of thc 2007 Series A Bonds Transfcr from Prior Bonds Funds Plus: Net Original Issuc Prcmium TOTAL SOURCES Uses: Deposit to Escrow Fund Deposit to Projcct Fund�'� Costs of Issuance�2� TOTAL USGS �'� To be used to finance redevelopment activities in ►he Project Area. See "THE PRo��.Cr Arttn—Summary of Development." �'� Includcs thc Undcrwritcr's discount, fecs and expenses of Bond Counsel and Disclosurc Counsel, fees and expcnscs of the Trustee, the Financial Advisor, the Fiscal Consultant and the Verification Agent, printing costs, rating agency fees, bond insurance and rescrvc fund surcty prcmiums, and other costs rclatcd to thc issuance of the 2007 Scrics A Bonds. For information regarding the Underwriter's discount for cach scrics of 2007 Series A Bonds, see "U!JUERWRITIN(;.�� �'� A debt service reserve fund surcty bond will be deposited in the Iteserve Fund. Sce "SECURITY A\U SOI;RCf.S UF PAYh1LV'I' foK'rHt Bouos—Rcscrvc Fund." Debt Service Schedules Annual dcbt service for the 2007 Series A Bonds is set forth below. Bond Ycar Ending A ril 1 Principal Interest Total 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 TOTAL 06(Y32�pos-2 ....,.., The tollowing table shows schcdulcd annual dcbt scrvicc on thc Parity Loan Agreements. Scc also "Prto1GCT AREA—Projccted Tax Incrcmcnt Rcvcnucs and Dcbt Scrvicc Covcrag�Table 8." Payment Date A ril 1 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 TOTAL Series 1997 Bonds $3,848,505 $3,848,505 Series 2002 Bonds $ I ,114,665 1,114,665 1, I 14,665 1,114,665 1,114,665 1, I I 4,665 1,114,665 1,114,665 1,114,665 1,114,665 1, l I 4,665 1,1 l 4,665 1,114,665 1,114,665 1, I 14,665 1,114,665 1,114,665 5,894,665 7,000,665 2,584,415 2,586,650 2,588,530 2,584,800 2,585.460 $44,774,490 ' Prcliminary, subject to changc. Series 2003 Bonds $950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 950,000 4,390,000 4,388,000 4,387,500 4,388,000 4389,000 $39,992,500 Series 2004 Bonds $2,037,412.50 1,909,812.50 2,055,812.50 1,919,312.50 2,057,062.50 1,926,212.50 1,983,962.50 1,986,987.50 1,963,587.50 1,956,100.00 1,953,500.00 2,018,425.00 1,910,900.00 1,939,900.00 1,967,700.U0 ] ,965,750.00 391,OOU.00 2,430,750.00 1,323,000.00 535,697,187.50 2006 Series Bonds $4,663,676.00 5,168,349.00 6,167,326.50 5, I 69,259.00 5,168,266.00 5,164,634.00 5,168,269.00 5,167,240.00 5,167,481.00 5,168,410.00 2,914,445.00 2,869,445.00 6,876,682.50 6,830,770.00 6,808,307.50 6,816,307.50 8,390,057.50 1,275,557.50 l ,267,557.50 3,552,557.50 300,807.50 299,057.50 301,837.50 303.775.00 $99,980,075.50 THE 2007 SERIES A BONDS Gencral 2007 Total Pariry Series A Bonds Debt Service Thc 2007 Scries A Bonds will be issued only in fully registered form in denominations of S5,000 and shall mature on the dates and in the principal amounts and bear interest at the rates as set forth on the insidc cover of this Official Statement. The 2007 Serics A Bonds will be dated the date of issuance and delivery, issued in fully rcgistered form, without coupons, and, when issued will be registercd in the namc of Cede & Co., as nomince for The Depository Trust Company, Ncw York, New York ("DTC"), as registercd owncr of all 2007 Series A Bonds. Ownership intcrests in the 2007 Serics A Bonds may be purchascd in book-cntry form only. Purchasers will not receive certificates representing their interests in the 2007 Serics A Bonds purchascd. Payments of principal and of the interest on the 2007 Series A Bonds will be paid by the Trustcc to DTC, which is obligated in tum to remit such principal and interest to iu DTC Participants for subsequent disburscmcnt to the beneficial owncrs of the 2007 Serics A Bonds. See APPENDIx G—"DTC AND THL BOOK- ENTRY ONLY SYSTEM." Ownership may be changed only upon the registration books maintained by the Trustee as provided in the 2007 Indcnture. Interest on the 2007 Series A Bonds shall be payablc semiannually on April 1 and October 1 of each year, commencing October 1, 2007 (each, an "Interest Payment Date"). oboaz�,-z Interest on thc 2007 Series A Bonds shall be payable semiannually on April 1 and October 1 of each year, commencing October 1, 2007 (each, an "Interest Paymcnt Datc"). Interest on the 2007 Series A Bonds will bc payablc on cach Interest Payment Date to the person whose namc appears on the Registration Books as thc Owncr as of the closc of busincss on the Record Date, such interest to be paid by check or draft of the Trustee mailed by first class mail, postage prepaid, on each Interest Payment Date to the Owner at the address of such Owner as it appears on the Registration Books on such Rccord Datc; provided, however, that at the written request of the Owner of at least �1,000,000 in aggregate principal amount of Outstanding 2006 Series A Bonds filed with the Trustee prior to any Record Datc, interest on such 2006 Series A Bonds shall bc paid to such Owner on cach succeeding Interest Paymcnt Date by wire transfer of immediately available funds to an account in the United States designated in such written rcqucst (unlcss and until such request has been revoked in writing). Rcdemption Provisions Redemption from Optional Loan Prepayment. If the Redevelopment Agency cxcrciscs its option to prcpay principal installments of the 2006 Series A Loan pursuant to the 2007 Loan Agreement, thc Rcvenues dcrivcd from such prcpaymcnt will bc applicd to thc redemption of the 2007 Series A Bonds maturing on or aftcr April 1, 20 , as a wholc, or in part among maturities as designated in writing by the Financing Authority and by lot within a maturity, in integral multiples of �5,000 principal amount, on any Interest Payment Date on or after April 1, 20� at a redemption price equal to [100"/0] of the principal amount of 2007 Scries A Bonds to be rcdccmcd, plus accrucd intcrest thcreon to the date of rcdemption, without prcmium. Mandatory Sinking Fund Redemption. The 2007 Series A Bonds maturing on April 1, 20_ (thc "2007 Scrics A Term Bonds") are also subject to mandatory redemption by lot, on April 1 in cach year commencing April 1, 20_ from sinking fund payments made by the Financing Authority into the Principal Account, at a redemption price equal to 100% of the principal amount thcreof to be redccmed, without premium, plus accrued interest to the date of redemption, in the aggregate respective principal amounts as set forth below, provided, however, that if some but not all of the 2007 Series A Bonds of a mariu-ity havc bccn rcdcemcd, the total amount of all future sinking fund payments with respect to the 2007 Series A Term Bonds of such maturity will be reduced by the aggregate principal amount of such 2007 Series A Term Bonds so redcemed, to be allocated among such sinking fund payments on a pro rata basis: 2007 Series A Term Bonds MaturinQ April 1, 20 Sinking Fund Redemption Date Principal Amount A ril I to be Redeemed f Maturity. 06(k12�pos-2 10 Purchase in Lieu of Redemption. In lieu of Mandatory Sinking Fund redcmption of thc 2007 Series A Bonds on April 1 in any year, the 2007 Series A Bonds may be purchased by the Redevelopment Agency pursuant to the 2007 Loan Agrcement and tendered to the Trustee for cancellation no later than the preceding January 15. Notice of Redemption. The Trustee on bchalf and at thc expense of the Financing Authority will send by first class mail (or such other means acceptable to such Owners or institutions) notice of any redcmption to the respective Owners of any 2007 Series A Bonds designated for redemption at thcir respcctive addresses appearing on the Rcgistration Books and to the Securities Depositories and to one or more Information Services, at least 30 but not more than 60 days prior to the datc fixcd for redemption; provided, however, that neither any defect or failure to receive any such notice will affect the validiry of thc proceedings for the redemption of such 2007 Series A Bonds or the cessation of the accrual of related interest. Such notice is required to state the date of the notice, the redemption date, the redemption place and the redemption pricc and shall designate the CUSIP numbcrs thc 2007 Series A Bond numbcrs (but only if less than all of thc Outstanding Bonds are to be redeemed) and the maturiry or maturities of the 2007 Serics A Bonds (in the event of redemption of all of the 2007 Series A Bonds of such maturity or maturitics in wholc) of the 2007 Scrics A Bonds to be redeemed, and require such Bonds to bc surrendered at the Trust Office of the Trustee in Los Angeles, California (or such other location as designated by the Trustee) for redcmption at the redemption price, giving notice also that further interest on such 2007 Series A Bonds will not accrue or accrete, as applicablc, from and after the redemption date. Se%ction of Bonds for Redemp[ion. If less than all of the 2007 Series A Bonds of a maturity are callcd for redemption, the Trustee will select the 2007 Series A Bonds to be redccmed from all 2007 Series A Bonds of such maturity not previously called for redemption, by lot in any manner which the Trustee in its sole discretion deems appropriate under the circumstances. Partial Redemption of Bonds. In the event only a portion of any 2007 Series A Bond is called for rcdcmption, then upon surrender of such 2007 Series A Bond the Financing Authority is required to executc and the Trustee is rcquircd to authenticatc and deliver to thc Owner thercof, at the cxpcnse of thc Financinb Authoriry, a new 2007 Scries A Bond or 2007 Series A Bonds of thc same tenor and maturity datc, of authorized denominations in aggrcgatc principal amount cqual to the unredeemed portion of thc 2007 Scries A Bond to bc redeemed. Effect of Redemption. From and aftcr the date fixed for redemption, if funds availablc for the payment of the principal of, intcrest on and premium, if any, on the 2007 Series A Bonds so callcd for redemption shall have been duly provided, such 2007 Scries A Bonds so called will cease to be entiticd to any bcnefit under thc 2007 Indenture othcr than the right to receive paymcnt of the redemption price, and no interest shall accrue thereon from and after the redemption date specified in such notice. SECURITY AND SOURCES OF PAYMEN'T FOR THE BONDS Revenucs and Loan Agreements 1�he 2007 Series A Bonds are secured by a first lien on and pledge of the Revenues, which are defined in the 2007 lndenture to include (i) all amounts payable by the Redevelopment Agency as payments or prepayments for the 2007 Loan pursuant to the 2007 Loan Agreement; (ii) any procceds of the 2007 Series A Bonds originally depositcd with the Trustee and all moneys deposited and held from time to time in thc funds and accounts established under the 2007 ]ndcnture; and (iii) income and gains with respect to the investment of amounts on deposit in thc funds and accounts established under the 2007 Indcnture, othcr than amounts payable to thc United States of America pursuant to the tax covcnants contained in the 2007 Indenture. The primary sccuriry for the 2007 Series A Bonds, therefore, consists of amounts payable by the o�oaz��,s-z 11 Rcdcvelopment Agency under the 2007 Loan Agreement, amounts held in the Rcserve Fund and amounts hcld by the Trustce under the 2007 Indenture. The 2007 Loan is securcd by a first pledge of and lien on the Tax Revenues on a parity with the pledge of and lien of the 1997 Loan securing repayment of the S2,065,000 outstanding principal amount of Series 1997 Bonds maturing April 1, 2007, the 2002 Loan, the 2003 Loan, thc 2004 Loan and the 2006 Loans and any additional parity dcbt that may be incurred subject to the 2007 Loan Agreement (collectively, "Parity Debt"), as more fully described under "—Tax Revenucs." The Redevelopment Agency may, pursuant to the terms of the 2007 Loan Agreemcnt, the 2002 Loan Agreemcnt, thc 2003 Loan Agreement, the 2004 Loan Agrecmcnt and the 2006 Loan Agreement, issue additional obligations securcd by Tax Rcvenues on a pariry with thc 2007 Loan. See "—Parity Debt and Subordinate Dcbt." Tax Revenues "Tax Revenues" is defined in thc 2007 Loan Agrecmcnt to mean monics allocatcd or paid to the Rcdcvclopment Agency derived from that portion of taxcs lcvied upon taxable property within the Project Area allocated and paid into a special fund of the Redevelopcnent Agency pursuant to Article 6 of Chapter 6 of the Redevelopcnent Law and Section 16 of Article XVI of the Constitution of the State, exclusive of amounts placed in the Low and Moderatc lncomc Housing Fund of the Redevelopment Agency pursuant to Sections 33334.2 and 33334.3 of the Redevelopment Law, and excluding amounts payable to the Affected Taxing Agencies pursuant to the Pass-Through Agreements or pursuant to Section 33607.5 or 33607.7 of the Rcdcvclopment Law. The Redevelopment Agency's receipt of Tax Revenues with respect to the Project Area is subject to certain limitations (the "Plan Limitations") contained in the Redevelopment Plan on the dollar amount of taxes which may be divided and allocated to the Rcdevelopment Agency pursuant to the Redevelopmcnt Plan, as such limitation is prescribed by Section 33333.4 of the Redevclopment Law. See "LIMITATIONS ON TAX RGVGNUES." Pursuant to the 2007 Loan A��eement, the Redevelopment Agency covenants to comply with all requircments of the Redcvelopment Law to insure the allocation and payment to it of thc Tax Revenues, and furthcr covenants not to enter into any agreement with the County of Riverside (the "Counry") or any other govcrnmental unit which would have the effcct of reducing the amount of Tax Revenucs available to the Redevelopment Agency for payment of the 2007 Series A Bonds, unless the Redevelopment Agency has obtained a rcport of an Independent Rcdevelopcncnt Consultant stating that the amount of Tax Revenues for the then current Fiscal Year (calculated on the assumption that such reduction of Tax Revenues was in effect throughout such Fiscal Year), is at least equal to 115% of Maximum Annual Debt Service; and as long as the [nsurance Policy is in full force and effect, the written consent of the Bond [nsurer. See also "—Pariry Debt and Subordinatc Debt." The Redevelopment Agency has no power to levy and collect property taxes, and any property tax li�nitation, lcgislative measure, voter initiative or provisions of additional sources of income to taxing agcncies having the effect of reducing the property ta�c rate, could reduce the amount of Tax Revenues that would otherwise be available to pay debt service on the 2007 Series A Bonds and, consequently, the principal of, and interest on, the 2007 Series A Bonds. Likcwise, broadcned property tax cxemptions or succcssful assessment appeals could havc a similar effcct. See "LIMITATIONS ON TAX R�VENULS" and "CERTAIN RISKS TO BONDHOLDERS." THE 2007 SERIES A BONDS ARE NOT A DEBT OF THE CITY, THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, OTHER THAN THE FINANCING AUTHORITY, AND NONE OF THE CITY, THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, OTHER THAN THE FINANCING AUTI�ORITY, IS LIABLE THEREFOR. THE 2007 LOAN IS NOT A DEBT OF THE FINANCING AUTHORITY OR THE STATE OR ANY OF ITS POLITICAL SUBDIVIS[ONS, AND NONE OF THE o�>oaz��-z 12 FINANCING AUTHORITY OR THE STATE OR ANY OF ITS POLITICAL SUBDIVISIONS, IS LIABLE THEREFOR. NONE OF THE MEMBERS OF THE FINANCING AUTHORITY, THE CITY COUNCIL, THE REDEVELOPMENT AGENCY OR ANY PERSONS EXECUTING THE 2007 SERIES A BONDS OR THE 2007 LOAN AGREEMENT ARE LIABLE PERSONALLY WITH RESPECT TO THE 2007 SERIES A BONDS OR THE 2007 LOAN. THE OBLIGATIONS OF THE REDEVELOPMENT AGENCY WITH RESPECT TO THE 2007 LOAN IS PAYABLE SOLCLY FROM THE TAX REVENUES (AS DEFINED HEREIN) AS SET FORTH IN THE 2007 LOAN AGREEMENT. NEITHER THE FINANCING AUTHORITY NOR THE REDEVELOPMENT AGENCY HAS TAXING POWER. Tax Allocation Financing Thc Redevelopmcnt Law provides a means for financing rcdevelopment projects based upon an allocation of taxcs collected within a project area. The taxable valuation of a project area last cqualized prior to adoption of the redevelopment plan, or base roll, is established and, except for any period during which thc taxable valuation drops below the base year level and for ccrtain cxceptions described below, thc taxing agencies thcreaftcr receive the taxes produced by the levy of the thcn current tax ratc upon thc basc roll. Taxcs collected upon any increase in taxable valuation ovcr the base roll (except such portion gencratcd by rates levicd to pay bonded indebtedncss approved by the voters on or aftcr January 1, 1989, for the acquisition or improvement of real property) are allocatcd to a redevelopment agency and may bc plcdged by a rcdcvelopment agency to the repayment of any indcbtedness incuired in financing or refinancing a redevelopment project. Tax Revenues consist of a poRion of such taxes. Redevelopment agencies themselves have no authoriry to levy property taxes and must look specifically to the allocation of taxes produccd as indicated abovc. Redevelopment Plan Limitations The State Legislaturc has in thc past enacted legislation altcring spending limitations or establishing minimum funding provisions for particular activities. The Redevelopment Agency cannot predict whether the State Lcgislature will enact other legislation requiring additional or increased future shifts of tax increment revenues to the State and/or to schools, whether through an arrangement similar to the local County Education Revenue Augmentation Funds (the "ERAF") or by other arrangements, and, if so, thc effect of such legislation on future Tax Revenues. A dcscription of such legislation is summarized below. AB 1290. Pursuant to Section 33607.7 of thc Statc Health and Safcry Code added by Assembly Bill (Statutes of 1993, Chapter 942) ("AB 1290") a redevelopment plan amendment for any redevclopmcnt plan adopted prior to January 1, 1994 that increases the limitation on the number of dollars to be allocated to the redevelopmcnt abency or thc timc limit on thc cstablishing of loans, advanccs and indebtedness, must bcgin making statutory payments to affected taxing entities that do not have existing pre-AB 1290 tax sharing agreements. These payments are to begin once any of the original redevelopment plan limitations would have takcn effcct. The first limit encountered or to be encountered in the Project Area is the debt cstablishmcnt limit. T'he AB 1290 payments are computed using the increase in revenue, if any, over the amount of rcvcnuc gcncratcd by a project area in the year that the debt establishment limit would have been reached. In cffcct, the year in which the debt establishment limit is met becomes a new "base year" for purposcs of calculating payments. AB 1290 payments are paid from revenues resulting from the growth in the ncw tax basc ycar. Among other amendments to the Law, AB 1290 limits the time for: (i) cstablishing indcbtedness in a projcct area to the later of 20 years from the date of adoption of the redevelopment plan or January 1, 2004; (ii) the life of existing rcdevclopmcnt plans to the later of 40 years from the date of adoption or January 1, oFoazV,�,s-z 13 2009; (iii) paying indcbtedness with tax incremcnt beyond 10 years after thc cxpiration of the rcdcvelopment plan, except to fund defcrred Low and Moderate Income Housing Fund (the "Housing Set-Asidc") requircments and to repay indebtedness incurred prior to January 1, 1994. The time limits imposed by AB 1290 apply individually to each plan as wcll as to specific temtory added by amendments to a redevelopment plan. On December 8, 1994, the Ciry Council adopted Ordinance No. 765 amending the Redevelopment Plan and cstablishing timc limits for the Project Area. For a summary of the plan amendmcnts and limitations, see "TrIE PROJECT AREA-0riginal Arca- Summary of Redevelopment Plan Limits-Table 2A" and "-Added Territory-Summary of Redevelopmcnt Plan Limits-Table 2B." For additional Iegislation affccting plan limits, see "�SB 211" and "-SB 1096." SB 211. Senate Bill 211 (Chaptcr 741, Statutes of 2001) ("SB 211") was adopted by thc California Lcgislature and bccame law on January 1, 2002. Among other thiags, SB 211 authorizes a redevelopment agency that adoptcd a redevelopmcnt plan prior to January 1, 1994, to amend that plan in accordancc with spccified proccdures to extcnd its effectivcness and reccive tax incremcnt rcvcnucs with respect to thc plan for not more than 10 years if ccrtain specificd findings are made. If a plan is so amcnded, the requirement for allocating tax increment revenues to low and moderate income housing is increased from 20% to 30%. Howevcr, such elimination also triggers statutory tax sharing with those taxing entities that do not have tax sharing agreements for the period commencing in the year the eliminated plan limit would havc takcn ctfcct. Tax sharing will be calculated based on the increase in assessed valuation after the year in which the timc limit would havc otherwise become effectivc. SB 211 also allows redevelopment agencies to amend rcdevelopment plans to eliminatc the time limit for the establishment of loans, advances and indebtedness within project areas. However, such an amendment would also require a redevelopment agcncy to bcgin makinb statutory tax sharing payments to affected taxing entities. Sec "-AB 1290." On February 27, 2003, pursuant to SB 211 thc Ciry Council adoptcd Ordinancc No. 1035 climinating the time limit to incur debt within the Project Area. See "LIMITATIONS ON TAX RGVGNUBS-Pass-Throubh Agreemcnts and Tax Sharing Paymcnts-,Statutory Taz Sharing Payments" and "THE PROJECT AREA- Original Area-Summary of Redevelopmcnt Plan Limits-Tablc 2A" and "-Added Temtory-Summary of Redcvclopment Plan Limits-Table 2B" for a summary of the plan amendment and limitations. SB 1045. Senate Bill 1045 (Chapter 260, Statutcs of 2003) ("SB 1045") was enacted as part of thc State Fiscal Year 2003-04 budget legislation and required redevelopment agcncics Statcwidc to contributc S135 million to the ERAF in order to reduce the amount of State funding for schcx�ls. (See also "Ctrt'rA►tv RISKS TO BONDHOLDERS-State Budget"). In accordancc with SB 1045, the Redevelopment Agcncy transferred $291,686 to the County by the May 10, 2004 deadline. In addition, SB 1045 amended the Redevelopment Law to permit redevelopment agcncics to usc a simplified mcthodology to amend the redevelopment plans to extend by one year thc cffcctivcncss of thc plan and the time during which a redevclopment agency may repay debt with tax increment revcnucs, and permitted a redevelopment agency to deduct the amount of ERAF payments in Fiscal Year 2003-04 and in prior years from the amount of the cumulative tax increment revenues for a project area. On Deccmber 9, 2004 the City Council adopted Ordinance No. 1082 extending by one year the cxpiration datc of thc Rcdcvelopment Plan and the time limit to repay debt in the Project Area. Sec "THE PRo1ECT Ax�A-0riginal Area-Summary of Redevelopment Plan Limits-Table 2A." SB 1096. Senate Bill 1096 (Chapter 211, Statutes of 2004) ("SB 1096") permits a redevelopment agency to extend the term of the redevelopment plans effectiveness and the periods within which a rcdevelopmcnt agcncy may repay indebtedness by up to two additional years, provided thc redevelopment o�oaz�o�-z 14 agency pays its ERAF obligations for Fiscal Ycars 2004-OS and 2005-06. SB 1096 authorizcs the following cxtcnsions of redcvelopment plans: (i) for componcnts of a project area that have 10 years or lcss of plan effectiveness remaining after June 3Q, 2005, a two-year extension is authorized; and (ii) for components of a project area that have more than 10 years and less than 20 years of plan effectivcness remaining after Junc 30, 2005, a two-year extension is authorized if the legislative body of the redevelopment agency makes certain findings. For those components of a project area with more than 20 years of plan effectiveness remaining aftcr June 30, 2005, no extension of timc is authorized under SB 1096. The Redevelopment Agency paid its ERAF obligation for Fiscal Year 2004-OS in thc amount of 53,887,133 and for Fiscal Ycar 2005-06 in the amount of $3,995,041. Since the Project Arca has more than 20 ycars of plan effectiveness remaining, the Rcdevclopment Agency is not permitted to cxtend thc repayment provisions within the Project Area pursuant to SB 1096. See "THB PROJECT AREA-0riginal Arca—Summary of Redevelopment Plan Limits—Table 2A" and "—Added Territory—Summary of Rcdevclopmcnt Plan Limits—Tablc 2B." SB 1206. Senate Bill 1206 Chaptcr 595, Statutcs of 2006 ("SB 1206") amends sections of the Redcvelopment Law to, among other things, revisc the conditions that characterizc a blightcd arca; standardize thc requirements for mergers of project areas; and prohibit the inclusion of nonblighted parccls in a redcvclopment project area for thc purpose of obtaining property tax revenue without substantial justification for inclusion. Allocation of Taxes As providcd in the Redevelopment Plan, and pursuant to Article 6 of Chapter 6 of the Redevclopment Law (commencing with Section 33670 of the California Health and Safety Code) and Section 16 of Article XVI of the Statc Constitution, taxes levied upon taxable property in the Projcct Area cach ycar by or for the bencfit of the Statc, Riverside Counry (the "Counry"), the Ciry, any district or other public corporation (herein collectively referred to as"taxing agencies") for each Fiscal Year beginning after the cffective dates of the ordinance approving the redevelopment plans and any amendmcnts adding tcrritory thcreto arc dividcd as follows: 1. To other taxin� a�encies: That portion of thc taxes which would be produced by thc rate upon which the tax is levied each year by or for each of said taxing agencies upon the total sum of� the assessed value of the taxable property in the Project Area as shown upon the assessment roll used in connection with the taxation of such property by such taxing agency last equalized prior to the effective date of thc applicable ordinance adopting the redcvelopmcnt plan or amending the rcdevelopmcnt plan to add property into the Project Arca, shall be allocated to, and when collected shall be paid into the funds of the respective taxing agencies as taxes by or for said taxing agencies on all other property are paid; and 2. To the Redevelopment AQencv: Exeept for taxes which are attributable to a tax rate levy by a taxing agency for the purpose of producing revenues to rcpay bondcd indebtedness approvcd by the voters of the taxing agcncy on or after January 1, 1989, which shall be allocated to and when collccted shall bc paid to thc respective taxing agency and except for statutory pass-through payments, that portion of the levied taxcs cach year in exccss of thc amounts provided for in paragraph (1) abovc, shall be allocated to, and when collected, shall be paid into a special fund of the Redevelopment Agency to pay the principal of and interest on bonds, loans, moneys advanccd to, or indebtcdness (whcther funded, refunded, assumcd, or othcrwise) incurred by the Rcdevelopment Agency to finance or refinance, in whole or in part, projects and programs for the Project Area. When said bonds, loans, advances, and indebtedness, if any, and interest thereon, have been paid, all moneys thcreafter received from taxes upon the taxable property in the Project Arca, shall bc paid into the funds of the respcctive taxing agencies as taxes on all other properry are paid. o�cwz�s-z 15 Thc portion of taxes divided and allocated to the Redcvclopment Agency from the Projcct Arca pursuant to paragraph (2) above shall not excecd a total of $758 million with respect to thc Original Area and �500 million with respect to the Added Tcrritory (inclusive of pass through paymcnts to affcctcd taxing agencies and the Housing Set-Aside) cxcept by amendmcnt of the Redevelopment Plan. This limit docs not apply to, include or prevent the Redevelopment Agency from incurring debt to be paid from the Housing Set-Aside, or any amounts rcquired to fulfill the Redevelopment Agency's obligations under scction 33413 of the Redevelopment Law in cxcess of the $600 million limit. The Redevelopment Agency is authorized to make plcdges of the portion of taxes mentioned in paragraph (2) above as to specifc advances, loans and indebtcdness as appropriate in carrying out the Rcdcvelopment Plan in the Projcct Area, subject to the limitations on allocation of taxes, dcbt creation, and bonded indebtedness contained in the Statc Health and Safety Code and other applicable laws. Undcr thc provisions of thc Redevelopmcnt Plan, the Redevelopment Agency shall not cstablish or incur loans, advances, or indebtedness to finance in whole or in part activities in the Project Area bcyond the dates for thc areas indicated in "THE PROlECT AREA—Redcvclopment Plan Limits—Tablc 2A and Tablc 2B." Loans, advanccs, or indebtedncss may be repaid over a period of time beyond said time limits. Thcse limits, however, shall not prevent the Redevelopmcnt Agency from incuning dcbt to bc paid from the Housing Fund established pursuant to Section 333343 of the Redevelopment Law and the Redevclopment Plan, or establishing more debt in order to fulfill the Redevelopment Agcncy's obligations under Section 33413 of the Redevelopmcnt Law and the Redevelopment Plan. This limit shall not prevent thc Redevelopment Agency from refinancing, refunding or restructuring indebtedness aftcr the time limit if the indebtedness is not increased and the time during which the indebtedness is to be rcpaid is not extendcd beyond the time limits contained in the Redevelopment Plan. The Redevelopment Agcncy may not receive and shall not repay indebtedness with thc procccds fi-ocn property taxes received pursuant to Section 33670 of the Redevclopment Law and the Redcvclopment Plan beyond the datcs for the areas indicated in Table 2A and Table 2B, except to repay debt to be paid from thc Housing Fund established pursuant to the Section 33334.3 of the Redevelopment Law and the Rcdevclopment Plan, or debt establishcd in order to fulfill thc Redcvclopmcnt Agency's obligations undcr Scction 33413 of the Redevelopment Law and the Redevelopment Plan. Rescrvc Fund General. A Reserve Fund was establishcd as additional security for the payment by thc Redcvelopmcnt Agency of amounts due undcr the Parity Loan Agreements. The Reserve Fund is required to be maintaincd by the Trustee in the amount of thc "Reserve Requirement." The Reserve Requirement is defincd in thc Parity Loan Agreements, as of any date of calculation, as the least of: (i) Maximum Annual Debt Service; (ii) 125% of average annual debt service on the 2007 Loan and all outstanding Parity Debt; and (iii) 10% of the proceeds of the applicablc 2007 Loan (i.e. the original Principal Amount of the 2007 Series A Bonds) and the proceeds of any Parity Dcbt. The Rcdcvelopmcnt Agcncy pledges and grants a lien and security interest to the Trustcc in thc Reservc Fund to sccurc the payment obligations of the Redevelopment Agency under the Parity Loan A��reements. Amounts on deposit in a Reserve Fund may be used for the purpose of making transfers to the applicable Intcrest Account, Principal Account, in such order, in the event of a deficiency at any time in any such accounts with respect to the amounts due on the applicable series of Parity Bonds. oboaz�s-z 16 Parity Debt and Subordinate Dcbt Issuance of Parity Deb� In addition to the 2007 Series A Bonds, the Redevelopment Agency may, by supplemental indenture, issue or incur other loans, advances or indebtedness payable from Tax Rcvenucs or Subordinate Tax Revcnues, on a parity with the 2007 Series A Bonds and the Parity Bonds and refunding bonds issued solely to finance and refinance redevelopment activities with respect to the Project Area in such principal amount as shall be determined by the Redevclopment Agency. The Redevelopment Agency covenants in the 2007 Loan Agreement that it will not incur any indebtedness payablc from all or any part of the Tax Revenues other than: (i) the 2007 Loan; (ii) additional Parity Debt subjcct to the conditions describcd bclow, and (iii) any debt secured by a pledge of Tax Revenues which is subordinate to the plcdge of Tax Revenues created by the Parity Loan Agrccmcnts. The Redcvclopment Agency has fur[her covenanted in thc 2007 Loan Agreement that it will not amcnd thc Redevelopment Plan (except for the purpose of extend or eliminating the time limit for the receipt of tax incrcmcnt, or increasing the limitation on the number of dollars of taxes to be allocated to the Rcdevclopment Abency) or any of the Pass-Through Agrcements, or enter into any agreement with the Counry or any other governmental unit, which would have the cffcct of reducing the amount of Tax Revenues available to thc Redevclopenent Agency for payment of the Pariry Loans unless the Redevelopment Agency has first obtaincd: (i) a report of an Independent Rcdevclopment Consultant stating that the amount of Tax Revenues for the then current Fiscal Ycar (calculated on the assumption that such reduction of Tax Rcvcnucs was in effect throughout such Fiscal Year), plus, at the option of the Redevelopment Agency, the Additional Revenues, will meet the covcrage tcst sct forth in paragraph (b) below, and (ii) the permission of thc Bond Insurcr. Pursuant to the 2007 Loan Agecment, the Redevelopment Agency may issue or incur additional Parity Debt subject to the following specitic conditions: (a) No Event of Default has occurred and is continuing under and as defined in the 2007 Loan Agreement, and the Redevelopment Agency is otherwise in compliance with all covenants set forth in thc 2007 Loan Agreement. (b) The amount of Tax Revenues for the then current Fiscal Year, as set forth in a Certificate of the Redevelopment Agency, based on assessed valuation of property in the Project Area as evidcnced in the writtcn rccords of thc Counry and projected annual Tax Revenues over the term of thc 2007 Loan Agreemcnt based on currcnt Tax Revenue collections is at least equal to 115% of Maximum Annual Debt Service. (c) The related Parity Debt Instrument provides that the balance of thc Reserve Fund will be increased to the new Reserve Requirement effective after the incurrence of such Parity Debt. (c) The related Parity Debt Instrument provides that any Parity Dcbt that bears current intcrest is payablc on April 1 and October 1 of any year; and the principal on such Parity Debt is payablc on thc same date as principal and interest on the 2007 Loan arc payable. (e) The issuance of such Parity Debt will not cause the Redevelopment Agency to exceed any applicable limitations contained in the Redevelopment Plan. (� The Redevelopment Agency delivers to the Trustee a written certificatc ccrtifying that the conditions precedent to the issuance of such Parity Debt set forth in subparagraphs (i) throubh (v) above havc been satisfied. oboaz��,s-z 17 Suburdinate Debt. In addition to the Parity Loans and any Parity Debt, the Redevclopment Agency may from time to time issue or incur Subordinate Debt (as defined in the 2007 Loan Agreement) in such principal amount as determined by the Redevelopment Agency, provided that the issuance of such Subordinatc Debt will not cause the Redcvelopment Agency to exceed any applicable limitations containcd in the Rcdevclopmcnt Plan. Investment of Funds All funds held by thc Trustce under thc 2007 Indenture and the Special Fund hcld by thc Redevelopment Agency are required to be invested in Permitted Investments. See APPENDIX D attached hercto for the definition of Permitted Investments. Sce thc audited financial statemcnts of the Rcdevelopmcnt Agency for the year ended June 30, 2005 attached hereto as APPENDIX B for a description of the Redcvelopmcnt Agency's investment policy at Junc 30, 2005. All investments, including thc Pcnnitted Investments contain a certain degree of risk. Such risks include, but are not limited to, a lower rate of return than expected and loss or delayed reccipt of principal. The occurrence of these events with respect to amounts held under the 2007 Indcnture or the Special Funds could have a material adverse affcct on the sccurity for the 2007 Scrics A Bonds. FINAIVCIAL GUARANTY INSURANCE The following information has been furnished by the Bond Insurer for use in this OJficial Statement. Reference is made to APPENDIX H for a.spec•imen of the financia! gzraranty insurance policy to be isst�ed b�� the Bond lnsurer. The Redevelopment Agency makes no repre.sentations as to the accuracy or completene.s.s orthis information or us to the absence of material adverse changes in this information subseyuent to the date hereof. MBIA Insurance Corporation MBIA Insurance Corporation ("MBIA ') is the principal operating subsidiary of MBlA Inc., a Netiv Yw•k Stock Exchange listed compuny (the "Company'). The Company is not obligated to pay the debts vJor cluims against MBIA. MBIA is domiciled in the State of New York and licensed to do business in and subject to regulation under the laws of all SO states, the District of Columbia, the Commonwealth of Puerto Rico, the Commonx�ealth of the Northern Muriana Islands, the virgin /slancls of the United Stutes and the Territory oj Guam. MBIA, either directly or through sufisidiaries, is licensed to do business in the Republic nf Franc•e, t17e United Kingdom and the Kingdom o.f Spain and is subject to r•egulation under the lativs of those . jurisclictions. The principal executive o�ces of MBIA ure loc•ated at 113 King Street, Armonk, New York 10504 and the muin telephone number at that address is (914) 273-4595. MBIA docs not accept any responsibility for the accuracy or completcncss of this Official Statemcnt or any information or disclosurc contained herein, or omittcd herefrom, other than with respcct to the accuracy of the information regarding the Policy and MBIA set forth undcr the heading "FINANCIAL GUARANTY INSURANCE." Additionally, MBIA makes no rcpresentation regarding the 2007 Serics A Bonds or the advisability of investing in thc 2007 Series A Bonds. Regulation As a financial guaranry insurance company licensed to do business in the State of New York, MBIA is .sa�bject to the New York /nsurance Law which, among other things, prescribes minimum capital requirements und contingency reserves against liabilities for MB/A, limits the classes und concentrations ojinve.stments oboaz��s-2 18 that are made by MBIA and requires the approval qf policy rates and forms thut are employed by MBlA. State luw also regulates the amount of both the aggregate und individual risks that may be in.sured by MBIA, the payment of dividends by MBIA, changes in control with respect to MBIA and transactions umong MBIA and its a�liutes. The Policy is not covered by the Propercy/Casualty Insurance Securiry Fund specified in Article 76 of the Ncw York Insurancc Law. Financial Strcngth Ratings of MBIA Moody's Investors Service, Inc. rates the financial strength of MBIA "Aaa." Standard & Poor's, a division of The McGraw-Hill Companies, Inc., rates the financial strength of MBIA "AAA." Fitch Ratings rates thc financial strcngth of MBIA "AAA." Each rating of MBIA should be evaluated independently. The ratings reflect the respective rating agcncy's current assessment of the creditworthiness of MBIA and its abiliry to pay claims on its policies of insurancc. Any furthcr explanation as to the significance of thc above ratings may be obtained only from the applicable rating agency. The abovc ratings are not recommendations to buy, scll or hold the 2007 Series A Bonds, and such ratings may be subject to revision or withdrawal at any time by the rating agencies. Any downward revision or withdrawal of any of the above ratings may have an adversc effect on the market price of the 2007 Serics A Bonds. MBIA does not guaranty the market price of the 2007 Series A Bonds nor docs it guaranty that thc ratings on the 2007 Series A Bonds will not be revised or withdrawn. MBIA Financial Information The tables below present selected financial information of MBIA determined in accordance with statutory accounting practices prescribed or permitted by insurance regulatory authorities ("SAP") as well as selected financial information of MBIA on a consolidated basis determined in accordance with accounting principlcs gencrally accepted in the United States of America ("GAAP"): In millions Admittcd Asscts Liabilities Capital and Surplus In millions Assets Liabilities Equity June 30, 2006 (Unauditedl $11,273 6,929 4,344 June 30, 2006 (Unaudited� S13,388 6,305 7,083 SAP GAAP December 31, 2005 (Audited) S11,037 7,237 3,800 December 31, 2005 (Audited) � 13,506 6,426 7,080 For further information conceming MBIA, see the consolidated financial statements of MBIA and its subsidiaries as of December 31, 2005 and December 31, 2004 and for each of the three years in the period ended December 31, 2005, prepared in accordance with generally accepted accounting principles, included in ot,c�az��,��-z 19 � thc Annual Report on Form 10-K of the Company for the year ended Dccembcr 31, 2005 and the consolidated financial statcmenu of MBIA and its subsidiarics as of June 30, 2006 and for the six month periods cndecl June 30, 2006 and June 30, 2005 included in the Quatterly Report on Form 10-Q of the Company for the period ended June 30, 2006, which arc hereby incorporated by reference into this Official Statement and shall be deemed to be a part hcreof. Copics of thc statutory financial statccnents filed by MBIA with the State of New York Insurancc Department are available over the Internet at the Company's web site at http://www.mbia.com and at no cost, upon requcst to MBIA at its principal executive offices. Incorporation of Certain Documents by Reference The following documents filed by the Company with the Securities and Exchange Commission (the "SEC") are incorporated by reference into this Official Statement: (1) The Company's Annual Rcport on Fortn 10-K for the year cnded Dcccmber 31, 2005; and (2) Thc Company's Quartcrly Report on Fonn 10-Q for thc quarter ended Junc 30, 2006. Any documents, including any financial statements of MBIA and its subsidiaries that are includcd thcrcin or attached as exhibits thcreto, filcd by the Company pursuant to Sections 13(a), 13(c), 14 or 15(d) of thc Exchange Act aftcr the date of thc Company's most rccent Quarterly Report on Form 10-Q or Annual Report on Fonn 10-K, and prior to the termination of the offering of the 2007 Series A Bonds offcred hereby shall be dccmed to be incorporated by rcferencc in this Official Statemcnt and to be a part hcreof from thc respective dates of filing such documents. Any statcment contained in a document incorporated or deemed to be incorporated by reference herein, or contained in this Official Statement, shall be deemed to be modified or superscded for purposes of this Of�icial Statcment to the extent that a statemcnt contained hcrein or in any othcr subsequently filed document which also is or is deemed to be incorporated by reference herein modifics or supersedes such statement. Any such statement so modificd or superseded shall not be decmed, exccpt as so modified or superscded, to constitute a part of this Official Statement. Thc Company files annual, quarterly and special reports, information statcmcnts and othcr information with the SEC under File No. 1-9583. Copies of the Company's SEC filings (including (1) thc Company's Annual Report on Form ]0-K for the year ended December 31, 2005, and (2) the Company's Quarterly Reports on Form 10-Q for the quarters cnded March 31, 2006 and June 30, 2006) are availablc (i) over the Intemet at the SEC's web site at httU://www.sec.!?ov; (ii) at the SEC's public reference room in Washington, D.C. (iii) over the Internet at the Company's web site at http://www.mbia.com; and (iv) at no cost, upon request to MBIA at its principal executive offices. Fxperts The financial statements, financial statement schedules and management's assessment of thc effectiveness of internal control over financial repoRing (which is included in Management's Report on Internal Control Over Financial Reporting) of MBIA Inc. and subsidiaries and the financial statements of MBIA Insurance Corporation and subsidiaries incorporated in this Official Statement by reference to MBIA Inc.'s Annual Report on Form 10-K for the ycar ended December 31, 2005 have been so incorporated in rcliancc on the reports of PricewatcrhouseCoopers LLP, an independent registercd public accounting firm, given on the authority of said firm as experts in auditing and accounting. 06042�pos-2 2� LIMITATIONS ON TAX REVENUES Article XIII A of the State Constitution On Junc 6, 1978, Califomia voters approved Proposition 13 ("Proposition 13"), which addcd Article XI[I A to thc State Constitution ("Articic XI11 A"). Articic XIII A, as amended, limits the amount of any ud valorem tax on real property to one perccnt of the full cash value thereof, except that additional ad valorem taxcs may be levicd to pay debt scrvice on (i) indcbtcdncss approved by the voters prior to July 1, 1978, (ii) (as a result of an amendment to Article XIII A approved by State voters on June 3, 1986) on bonded indebtedness for the acquisition or improvement of real properry which has been approved on or aftcr July 1, 1978 by two-thirds of the voters on such indebtcdness, and (iii) bonded indebtedness incutred by a school district or community collcge district for the construction, rcconstruction, rehabilitation or replacement of school facilities or the acquisition or lease of real property for school facilities, approved by 55% of the voters of the district, but only if certain accountability measures are includcd in the proposition. Article XI11 A, amonb other things affects the valuation of rcal property for thc purpose of taxation in that it defines the full cash property value to mean "the counry assessor's valuation of rcal property as shown on the 1975-76 tax bill under `full cash value', or thereafter, the appraised value of real property when purchased, newly constructed, or a change in ownership has occurred after the 1975 assessment." The full cash value may bc adjusted annually to reflect inflation at a rate not to exceed 2% per year, a reduction in the consumer price index or comparable local data, or declining property value causcd by damage, destruction or other factors including a gcncral cconomic downturn. In the general elections of 1986, 1988 and 1990, California voters approved various measures which further amendcd Article XIII A. One such amendment generally provides that the purchasc or �-ansfcr of (i) real property between spouscs or (ii) the principal residcnce and the first S1,000,000 of the full cash value of other real property beiween parents and children, do not constitute a"purchase" or "change of ownership" triggering reassessmcnt under Article XIII A. This amendment reduces the property tax revenucs of thc City and the tax increment of the Redevelopment Agency. Other amendments permitted the Legislature to allow persons over 55 who sell their residence and on or after November 5, 1986, buy or build another residence of cqual or lesser value within two years in the same county, to transfcr thc old residcnce's asscsscd valuc to thc new residence, and permitted the Legislature to authorize each counry under certain circumstances to adopt an ordinance makinb such transfer or assessed value applicable to situations in which the replacc►ncnt dwelling purchased or constructed after November 8, 1988, is located within that county and the original property is located in another county within thc Statc. In the June 1990 election, the voters of the State approved additional amendments to Article XIII A permitting the California Legislature to extend the replacement dwelling provisions applicable to persons over 55 to severely disabled homeowners for replacement dwellings purchased or ncwly constructcd on or after June 5, 1990, and to exclude &om the definition of "new construction" triggering reassessment improvcments to certain dwellings for thc purpose of making the dwelling more accessible to severcly disabled persons. In the November 1990 clection, the voters approved the amenciment to Article X1fI A to permit the State Legislature to exclude from the definition of "new construction" seismic retrofitting improvcments or improvements utilizing carthquake hazard mitigation technologies constructed or installed in cxisting buildings after November 6, 1990. Both the California Supreme Court and the United States Supreme Court have upheld thc constitutionality of Articic XIII A. Challenges [o Article XIII A. On September 22, 1978, the California Supreme Court upheld the amcndment over challenges on sevcral state and federal constitutional brounds (Amador Vallev Joint Union High School District v. State Board of Equalization). Thc Court rescrvcd ccrtain constitutional issucs and the validity of legislation implementing the amendment for future determination in proper oboaz��„-, 21 cascs. Since 1978, scvcral cascs have been dccided interpreting various provisions of Article XIII A; howcvcr, none of thcm have questioncd thc ability of rcdcvelopment agencies to use tax allocation financing. The United States Supreme Court upheld the validity of the assessment procedures of Articic XIII A in Nordlinger v. Hahn. The Redevelopment Agency cannot predict whether there will be any future challenges to California's present system of property tax assessment and cannot evaluate the ultimate effect on the Redevelopment Agency's receipt of Tax Revcnues should a future decision hold unconstitutional the method of assessing property. Implementing Legislation. Legislation enacted by the California Legislature to implemcnt Anicic XII1 A providcs that all taxable property is shown at full assessed value as described above. In conformity with this procedure, all taxable property value included in this Official Statemcnt (cxcept as notcd) is shown at 100% of asscssed value and all general tax rates reflect the �,1 per S 100 of taxable value. Tax rates for voter approvcd bonded indcbtcdness and pension liability arc also applicd to 100% of asscssed valuc. Future assessed valuation growth allowed under Article XIII A(new construction, change of ownership, 2% annual value growth) will be allocated on the basis of "situs" among the jurisdictions that serve the tax rate area within which the growth occurs, except for certain utility property assesscd by the State Board of Equalization. Local a�encies and school districts will share the growth of "base" revenuc from the tax rate area. Each year's growth allocation becomes part of each agency's allocation the following year. The Redevelopment Agency is unable to predict the nature or magnitude of future revcnue sourccs which may be provided by the State to replace lost property tax revenues. Article XIII A cffectively prohibits the levying of any other ad vUlorem property tax abovc the 1% limit except for taxes to support indebtcdness approved by thc voters as dcscribed above. See "CERTAIN RISKS TO BONDHOLDERS—Reduction in Inflation Rate" regarding certain litigation rclating to property asscssments and the provision of Articic XIII A limiting the annual inflation adjustment to two perccnt when the assessor tried to "recapture" the tax value of the property by incrcasing its asscssed value by approximately four perccnt in a single year. Litigation Regarding 1% Limitation. Section 51 of the Revenue and Taxation Code permits county assessors who have reduced the assessed valuation of a property as a result of natural disa.sters, economic downturns or other factors, to subsequently "recapture" such value (up to the pre-dccline value of the property) at an annual rate higher than 2%, depending on the assessor's measure of the restoration of valuc of the damaged property. The constitutionaliry of this procedure was challenged in a lawsuit brought in thc Orangc County Superior Court entit(ed County of Orange v. Orange Counry Assessment .4ppeal.s Board No. 4 and in similar lawsuits brought in other counties, on the basis that the decrease in assessed value crcates a new "basc year valuc" for purposes of Proposition 13 and that subsequent increases in the assessed value of a property by more than 2% in a single year violatc Articic XIII A. In 2001, the Orangc County Superior Court issucd an order declaring the recapture practice to be unconstitutional as applied to the plaintiff taxpayer. On March 26, 2004, the Court of Appeal held that the trial court erred in ruling that assessed valuc determinations arc always limited to no more than 2% of thc previous year's asscssed value and reverscd the judgmcnt of the trial court. On July 21, 2004, the California State Suprcmc Court denied a petition to revicw thc decision of the Court of Appeal. Articic XIII B of the Statc Constitution; Appropriation Limitations An initiative to amend the State Constitution was approved on September 6, 1979 thcreby adding Article XIII B to the State Constitution ("Article XIII B"). Article XIII B limits the annual appropriations from the proceeds of taxes of the State and any city, counry, school district, authority or other political �_� 06042�os-2 22 subdivision of the Statc to the Icvel of appropriations for thc prior fiscal year, as adjusted for changcs in the cost of living, population and scrvices rendcred by the govcrnmental entity. Ariicle XIII B includcs a requirement that if an entity's revenues in any year exceed the amount permittcd to bc spent, thc: cxccss would have to be returncd by revising tax or fee schedules over thc subsequent two ycars. Effectivc September 30, 1980, the Statc Lcgislature added Section 33678 to the Redevelopment Law which provides that the allocation of taxcs to a rcdevelopment agency for the purpose of paying principal of, or interest on, loans, advances or indebtedness incurred for redevelopment activity shall not be deemed the receipt by such agency of proceeds of taxes within the meaning of Article XIII B, nor shall such portion of taxes be dcemcd receipt of proceeds of taxcs by, or any appropriation subject to the limitation of, any other public body within the meaning or the purposc of the Constitution and laws of the State, including Section 33678 of the Redevclopment Law. Two State appellate court decisions have upheld the constitutionality of Section 33678, and in thc one case in which a petition for rcview was filed in the California Supreme Court, such petition was denied. Articles XIII C and XIII D of the State Constitution On Novembcr 5, 1996, California voters approved Proposition 218—Voter Approval for Local Government Taxes—Initiative Constitutional Amendment. Proposition 218 added Articles XIII C and XIII D to the California Constitution, imposing certain vote requirements and other limitations on the imposition of� new or increased taxes, assessments and property-related fees and charges. The Bonds are secured by sourccs of revcnucs that arc not subject to limitation by Proposition 218. Taxation of Unitary Property AB 454 (Statutes of 1987, Chaptcr 921) provides a revised method of reporting and allocating property tax revenues gencrated from most State-assessed unitary properties commencing with Fiscal Year 1988-89. Under AB 454, the State reports to each county auditor-controller on the counry-wide unitary taxable value of each utility, without an indication of the distribution of the value among tax rate arcas. AB 454 provides two formulas for auditor-controllers to use in order to determine the allocation of unitary properry taxes generated by the county-widc unitary value, which are: (i) for rcvenue gencrated from thc 1% tax rate, each jurisdiction is to receive up to 102% of its prior year unitary property tax increment revenue, howcver, if county-wide revenues gcnerated for unitary properties are greater than 102% of prior ycar revenucs, each jurisdiction receives a percentage share of the excess unitary revenues equal to the percentage of each jurisdiction's share of secured property tax revenues; or (ii) for revenue generated from the application of the debt service tax rate to county-wide unitary taxable value, each jurisdiction is to receive a percentage share of revenue based on the jurisdiction's annual debt service requirements and the percentage of property taxes received by each jurisdiction from unitary property taxes. The provisions of AB 454 apply to all State-asscssed property, except railroads and non-unitary properties the valuation of which will continue to bc allocated to individual tax rate areas. The provisions of AB 454 do not constitute an elimination or reversion of ihe method of assessing utilitics by the State Board of Equalization. AB 454 allows, gencrally, valuation growth or dccline of State-asscssed unitary property to bc sharcd by all jurisdictions within a county. The unitary revenue allocation made by the County Auditor-Controller to the Original Area for 1�'iscal Ycar 2005-06 was $300,930 is estimated to be the same for Fiscal Year 2005-06. The unitary rcvcnue allocation madc by thc County Auditor-Controller to the Added Tcrritory for Fiscal Year 2005-06 was � 167,752 and is estimatcd to be the same for Fiscal Year 2006-07. o�aaz�s-z 23 Property Tax Collection Procedures Classifications. In California, property which is subject to ad valorem taxes is classified as "secured" or "unsecured." Secured and unsecured property are entered on separate parts of the assessment roll maintained by the county assessor. The secured classification includes property on which any property tax levied by the County becomes a lien on that property sufficient, in the opinion of the counry assessor, to secure payment of the taxes. Every tax which becomes a lien on secured property has priority over all other liens on the secured property, regardless of the time of the creation of other liens. A tax levied on unsecured property does not become a lien against the property, but may become a lien on ccrtain other property owned by thc taxpayer. Collections. The method of collecting dclinquent taxes is substantially differcnt for the two classifications of property. The taxing authority has four ways of collecting unsecured property taxes in the abscncc of timely payment by the taxpayer: (1) a civil action against the taxpayer; (2) filing a certificate in the office of the county clerk specifying certain facts in order to obtain a judgment lien on certain property of the taxpayer; (3) filing a certificate of delinquency for record in the county recorder's office, in order to obtain a licn on certain property of the taxpayer; and (4) seizure and sale of thc personal property, improvcments or possessory interests bclonging or asscsscd to the asscssce. The exclusive means of enforcing the payment of delinquent taxes with respect to property on the secured roll is the sale of property securing the wxes to the State for the amount of taxes which arc dclinquent. Current tax payment practices by the County provide for paymcnt to the Redevelopment Agency of Tax Revcnues monthly throughout the fiscal year, with the majority of Tax Revenues derived from secured property paid to thc Redevelopment Agency in mid-Deccmbcr and mid-April, and thc majority of Tax Rcvenucs derivcd from unsecured property paid to the Redevelopment Agcncy by mid-Novcmber. A tinal reconciliation is made after the close of the fiscal year to incorporate all adjustments to previously reported current year taxable values. The difference between the final reconciliation and Tax Revenues previously allocated to thc Redevelopment Agency is allocated mid-August. Penalties. A 10% pcnalty is added to dclinquent taxes which have been levied with respect to property on the secured roll. In addition, property on the securcd roll on which taxes are delinquent is sold to thc State on or about June 30 of thc fiscal year. Such property may thcreafter be redeemed by payment of the delinquent taxes and a delinquency penalty, plus a redemption penalty of 1% per month to the time of redemption and a$15 Redemption Fee. If taxes are unpaid for a period of five ycars or more, the properiy is deeded to the State and then is sub}ect to sale by the county tax collector. A 10% penalty also applies to the delinquent taxes on property on the unsecured roll, and further, an additional penalty of 1% per month accrues with respect to such taxes bcginning the first day of the third month following the delinquency date. Delinquencies. The valuation of property is determined as of January 1 each year and equal installments of taxes levicd upon secured property bccome delinquent after the following Dccember 10 and April 10. Taxes on unsecurcd property arc due April 1. Unsccured taxes enrolled by July 31, if unpaid, are delinqucnt August 31 at 5:00 p.m. and are subject to penalty; unsecured taxes added to the roll after July 31, if unpaid, are dclinquent on the last day of the month succeeding the month of enrollment. Supplemental Assessments. A bill enacted in ] 983, SB 813 (Statutes of 1983, Chapter 498), provides for the supplemental assessment and taxation of property as of the occurrence of a change in ownership or completion of new construction. Previously, statutes enabled the assessment of such changes only as of the next January 1 tax lien date following the change and thus delayed the realization of incrcased property taxes from the new assessments for up to 14 months. As enactcd, Chapter 498 provides increased revcnuc to redevclopment agencies to the cxtcnt that supplcmental assessments as a result of new ob�az��s-z 24 construction or changes of ownership occur within the boundaries of redevelopment projects subsequent to thc January 1 lien date. To the extent such supplcmental assessments occur within the Project Area, Tax Revenues may increase. Property Tax Administrativc Costs Legislation enacted by the State Legislature authorizcs county auditors to determine pruperty tax ad►ninistrative costs proportionately attributable to local jurisdictions and to submit invoiccs to the jurisdictions for such costs. Subsequent legislation specifically includes redevelopment agencies among the entities that are subject to such charges. Specifically, in 1990 the State legislature enacted SB 2557 (Chapier 466, Statutes of 1990) authorizing counties to charge for the cost of assessing, collecting and allocating prope�ty tax revenues to local governmcnts jurisdictions in proportion to the tax derivcd revenucs allocatcd to each. SB 1559 (Chapter 697, Statutes of 1992) explicitly includes redevelopmcnt agencieti among the jurisdictions which are subject to such charges. The Counry collects property tax administration costs from the Redevelopment Agency by deducting such costs from tax revenues prior to delivering such amounts to thc Redcvelopment Agcncy. The County administration fec is also prorated to thc Low and Moderate Income Housing Fund and to taxing agencies (including the County Capital Fund (the "CIF") that rcceive a portion of the tax increment revenucs pursuant to tax sharing agreements. For pucposes of projecting Tax Revenues, the Fiscal Consultant assumes that the administrative fces will remain constant at the Fiscal Year 2005-06 rates. See also APPENDIX A—"REPORT OF THE FISCAL CONSULTANT." Origina! Area. For Fiscal Year 2005-06 the Counry's administrative fee in the Original Area was 0.869% of the gross tax increment rcvenues from the Original Arca or $78,987, and for Fiscal Ycar 2006-07 is estimated to bc $77,466. Added Territory. For Fiscal Year 2005-06, the Counry's adminish-ative fce in thc Addcd Tc►ritory was 0.101% of the gross tax incrcmcnt revenues paid to the Redcvelopment Agency from thc Added Temtory or S298,669, and for Fiscal Year 2006-07 is estimated to be $293,492. Housing Set-Aside Sections 333342 and 33334.3 of the Redevelopment Law (added by Chapter 1337, Statutcs of 1976) require rcdevclopment agencies to set aside 20% of all tax incremcnt derived from redevelopment project areas established after December 31, 1976 in a low- and moderate-income housing fund. Section 33334.2 provides that this low- and modcrate-income housing requiremcnt can be reduced or eliminated if a redevelopment agency finds annually by resolution, consistent with the housing element of the community's gcneral plan, the following: (a) that no need cxists in the community to improve, increase, or preserve thc supply of low- and moderatc-incomc housing, including its share of the regional housing nceds of very low income households and persons and families of low or moderate income; (b) that some stated percentage less than 20% of the tax increment is sufficient to meet the housing needs of the communiry, including its share of the regional housing needs of persons and families of low or moderate income and very low income households; or (c) that the community is making substantial efforts, consisting of direct financial contributions of funds from state, local and fcderal sources for low- and moderate-income housing of cquivalent impact, to meet its existing and projected housing needs (including its sharc of regional housing nceds). The Redevelopmcnt Agency currently deposits the 20% of gross tax increment revenues in its Low and Moderate Income Housing Fund. Such funds are not Tax Revenues and are not pledged to the repaymcnt of the 2007 Loan. Pursuant to the Redevelopment Law, housing sct-aside funds may be pledged to thc repaymcnt of bonds only to the extcnt procccds of such bonds are uscd (or are uscd to refund bonds, the procceds of which were used) to finance low and moderate income housing puiposes. See "SECURITY AND SOLRCGS OF PAYMENT FOR THE BONDS—Allocation of Taxes." 06042�pos-2 25 As amended by AB 315 (Chapter 872, Statutcs of 1991), Section 33334.2 has additional restrictions on the abiliry to reduce or eliminate the low and moderate income housing requirement. A community can claim that no necd exists, or can claim that less than 20% of tax increment revenue is sufficient, only if that claim is consistent with the housing element of the communiry's general plan. The authority for communities to claim an "equivalent effort" exemption was repealed as of June 30, 1993, except for obligations incurred prior to May l, 1991, which wcre cntered into with the understanding that the "equivalent effort" exemption would remain intact. T1�e Redevelopment Agency has made no such findings. Stipulation Agreement On May 15, 1991, thc Riverside County Superior Court entered a final judgment incorporating a Stipulation for Entry of Judgment (the "Stipulation") among the Redevelopment Agency, thc Wcstcm Center on Law and Poverty, Inc. and California Rural Legal Assistancc in connection wich litigation filed over the adoption of thc Redevelopment Plan for Project Arca No. 1, As Amended (Ciry of Palm Springs v. All Persnns /nterested, etc., Case No. Indio 51143). On June 18, 1997 and on September 20, 2002, thc Coun entered amendments to its 1991 judgment, incotporating Stipulations Amending Stipulation for Entry of Judgment. Under the tcrms of the Stipulation, as amcnded, the Rcdevelopment Agency has generally agrecd to usc its 20% housing set-aside funds, and other tax increment revenues, if neccssary, to devclop, rehabilitate, or otherwisc financially assist a certain number of affordable housing units and to mcet certain housing needs of the Ciry. Sec "—Housing Set-Aside." The Stipulation, as amended, provides that future indebtedness incurred by the Redevelopment Agency will be payable on a basis which is prior to the obligations imposed by the Stipulation, as amended, if thc Rcdevelopmcnt Agency makes a 6nding by resolution, based upon a report, that the Redevelopment Agency will have sufficient revenues to meet that indebtedness as well as its obligations under the Stipulation, as amendcd. Under the tcrms of the Stipulation, as amended, notwithstanding its other tcrms, the Redcvelopmcnt Agency may incur indebtedness and plcdgc tax increment revenues to refinance its obligations, so long as(i) the total amount of debt service payable in connection with such refinancing is less than the total amount of debt service remaining to be paid on the refunded obligations, or (ii) the total amount of debt service payable in connection with such refinancing rcflccts a present value savings when compared with the total amount of dcbt service rcmaining to be paid on thc refunded obligations. Thc total dcbt servicc payable on thc 2007 Scries A Bonds will be less than the total amount of thc dcbt servicc payable with respeci to thc Prior Bonds being rcfunded, and the total debt servicc payablc on the 2007 Series A Bonds reflects a present value savings compared to the total amount of dcbt service remaining on thc Prior Bonds rcfunded. Certification of Redevelopment Agency Indcbtedness Under the Rcdevclopment Law, redcvelopmcnt agencies must file with the county auditor a statement of indebtedness for each project area not later than the first day of October of each year. As described below, the statement of indebtedness controls the amount of tax increment revcnue that will be paid to thc Redcvelopmcnt Agency in each fiscal year. Each statcment of indebtedncss is filed on a form prescribed by the State Controller and specifies, among other things: (i) the total amount of principal and interest payable on all loans, advanccs or indcbtedness (thc "Dcbt"), both over thc lifc of the Debt and for the current fiscal year, and (ii) the amount of "available revenue" as of the end of the previous fiscal year. "Available revenue" is calculated by subtracting the total payments on Debt during thc previous fiscal year from thc total revenues (both tax incrcmcnt revcnues and other revenues) rcceived during thc prcvious fiscal year, plus any carry forward from the prior fiscal year. Available revenues include amounts held by thc Redevelopment Agency and irrevocably pledged to the payment of Debt, but do not includc amounts set asidc for low and modcrate income housing. 06(Y12�pos-2 26 The counry auditor may only pay tax increment revenue to the redevelopment agency in any fiscal year to thc extent that the total remaining principal and intcrest on all Debt exceeds thc amount of availablc rcvcnucs as shown on the statement of indcbtedncss. Thc statemcnt of indebtedness constitutcs prima facie evidence of the indebteciness of the rcdevelopment agcncy; howcver, the county auditor may dispute the statement of indebtedness in certain cases Section 33675 provides for eettain time limits controlling any dispute of the statement of indebtedness, and allows for Superior Court detcrmination of such disputc in the event it cannot bc resolvcd by the redevelopment agency and thc county. Any such action may only challenge the amount of the Debt as shown on the statement, and not the validiry of any Dcbt or related contract or the cxpenditures related thereto. No challenge can be made to payments to a fiscal agcnt in connection with a bond issue or payments to a public agency in connection with payments by that public agency with respect to a Icasc or bond issue. Pass-Through Agreements and Tax Sharing Payments Pass-Through Agreements. Thc Rcdevelopmcnt Agency cntcred into a pass-through a�,neemcnts with ccrtain local taxing agencies (collectively, the "Pass-Through Agreements"). Pursuant to each such agrecment, thc Redevelopmcnt Agency is obligated to pay tax increment revenues to each such taxing entity, other than thc City, that has temtory located within the Project Area in the acnount which the Redevelopment Agcncy dctermincs is appropriate to alleviatc any financial burden or detriment caused to such taxing entity as a result of rcdcvelopment activities within the Project Area. Each Pass-Through Agreement provides for a pass-through of tax increment revenue directly to the related taxing entity. For a description of thc Pass- Through A�;reemcnts, see APPENDIX A—"REPORT OF THE FISCAL CONSULTANT—Payments to Af'fectcd 1'axing Agcncies." Statutory Taz Sharing Payments. "I'he Redevelopment Plan for the Project Area was amended by Ordinancc No. 1035 on March 11, 2004 and therefore is subject to the statutory tax-sharing payments mandated in the Redevelopment Law, as amended by AB 1290, requiring that a portion of thc tax increment rcvenues be shared with local taxing agencies. See also "SGCURITY AND SOURCES OF PAYMENT FOR THE BotvDs—Redevelopment Plan Limitations—AB 1290." These tax-sharing payments are set by statute and are not negotiatcd. Thc County Auditor-Controller allocatcs all tax increment revenue to the Redevelopment Agency for payment of tax-sharing payments. This defined tax sharing amount has three Tiers. Tier 1: Commenccs with the first year that the Project Area receive tax incremcnt revenue and continucs for the life of thc Project Area. The Tier 1 ta�c-sharing amount is equal to 25% of the gross tax incremcnt revenue allocated from thc Project Arca net of the Housing Set-Asidc Requircment. The City may chose to forgo its share of this tier of ta�c-sharing payments. Tier 2: Commences in the 11 th year after the Redevclopment Agency first receives tax incremcnt revenuc (i.e. Fiscal Year 2024-25), and is in an amount equal to 21 % of the tax increment revenue net of the Housing Set-Aside Requiremcnt, derived from thc growth in assessed valuc that is in excess of the asscssed valuc of the Project Area in the tenth year. Thc City may not reccivc any portion of the Tier 2 tax-sharing payments. Tier 3: Commences in the 31st year after the Rcdevelopment Agency first rcceives tax increment revenues and is an amount equal to 14% of the tax increment revenue net of Housing Sct- Aside derived from the �owth in assessed valuc that is in exccss of the assesscd value of the Project Area in the 30th ycar. The City may not rcceive any portion of the Ticr 3 tax-sharing payments. Thesc three tiers of tax sharing are calculated indcpendcnt of one anothcr and continue from their inccption through the life of the Project Area. O6042\pos-2 2% In the Original Area, the Redevelopmcnt Agency had not previously entercd into any tax sharing agreements, however, the adoption of Ordinance No. 1035 (discussed bclow) imposed statutory tax-sharing payments for all those taxing agencies for which the Redevelopcncnt Agency had not previously cntered into a tax sharing agrcemcnt. SB 211 Tax Sharing Payments. On March 1 l, 2004, the City Council adopted Ordinance No. 1035 eliminating the time limit to incur debt in the Original Area. Pursuant to SB 211, thc adoption of such an ordinance requires the Redevelopment Agency to begin making statutory tax sharing payments in the Fiscal Year following thc expiration of thc original time limit for the incurrence of new indebtcdness. Sce also "SECURITY AND SOURCES OF PAYMENT FOR THE BONDS—Redevelopment Plan Limitations—SB 211." In accordance with SB 1045, the plan limit for the Original Area was extended by one year. By extending this limit to July 16, 2016, the Redevclopment Agency caused statutory tax sharing payments to commence with Fiscal Year 2004-05. The assessed valucs in the last Fiscal Year prior to initiation of the statutory tax sharing payments are used as the base value for calculation of the tax sharing payments. The projections of the Fiscal Consultant assume that the Ciry will elect to receive its share of these payments, however, currcntly, if the City elects not to receivc its share of these tax sharing payments, that portion of the statutory tax sharinb payment will remain with the Redevclopment Agency for its use. The Counry Auditor- Controller allocatcs all tax increment revenue to the Redevelopmcnt Agency and it is the responsibility of the Rcdcvelopmcnt Agency to make the rcquired tax sharing payments. The Redevelopment Agency has detemuned at this time not to seek subordination of thcse statutory tax shuing payments from the taxing agencies. Limitation of Tax Revenues from Certain Increased Tax Rates An initiative to amend the California Constitution entitled "Property Tax Revenues—Redevelopmcnt Agcncics" was approvcd by Califomia voters at thc November 8, 1988 general clection. This initiativc amcnds thc California Constitution to allow the California Legislature to prohibit redcvclopment agencies frocn receiving any of the property tax revenue raised by increased property tax e-ates imposed by local governmcnts to makc payments on their bonded indebtedness. The initiative applies to tax rates lcvicd to finance bonds approved by the voters on or after January 1, 1989. The Redevelopment Agency does not currently project receiving any tax revenues as a result of general obligation bonds which may have been approvcd on or after January 1, 1989. Ballot Initiativcs and Lcgislative vlattcrs Articics XIIIA, XIIIB, X1IIC and XIIID wcre each adopted pursuant to a measure qualified for thc ballot pursuant to the State's constitutional initiative process; the State Legislature has in the past enacted legislation which has altered the spending limitations or established minimum funding provisions for pa►ticular activities under the Redevelopment Law. From time to iime, other initiative measures could be adopted by voters of the State or Iegislation enacted by the State Legislature. The adoption of any such initiativc measures or legislation might place limitations on thc abiliry of thc State, the Rcdevelopmcnt Agency or local districts to incrcase revenucs, to increase appropriations or on the ability of a landowncr to complete ihe dcvelopment of properry. o�oaz�,s-z 28 CERTAIN RISKS TO BONDHOLDERS The following injormation should be considered hy prospective investors in evaluating the 2007 SC'/'IL'S A Bonds. However, the following does not purport to be an exhaustive listing of risks and other considerations which may be relevant to making an investment decisions with respect tn the 2007 Series A Bonds. In addition, the order in which the following injormation i.s presented is not intended to reJlect the relative importance ojany such risks. Added Territory Projected to Reach Limit in Fiscal Year 2021-22 In Fiscal Year 2005-06, Tax Revenues coming from property within the Added Temtory represented approximatcly _% of total 1'ax Rcvenues in the Projcct Area. Tax Revenues in the Added Tccritory arc subject to a maximum of $500,000,000 (cxclusive of ccrtain amounts). See "LIMITATION ON TAX R1;veNU�s." Accordinbly, Tax Revenues available to pay debt service on the 2007 Loan (and thercforc thc 2007 Series A Bonds) will be substantially reduced aRer the limit in the Added Territory is reached. The Redevelopment Agcncy expects this limitation will bc reached prior to the final maturity date of thc 2007 Series A Bonds. As stated in thc Report of the Fiscal Consultant, assuming �-owth in the annual assessed value at ratc equal to 2%, the Added Terntory will rcach its �500,000,000 tax increment limit in Fiscal Year 2021-22. See APPENDIX A—"RGPORT OF TI-IG FISCAL CONSULTANT—Tablc 2B." The Redevelopment Agency can give be no assurance as to when the gross tax increment limit wi11 for the Added Terrilory wi!l be reached. The Report of the Fiscal Consultant contains only a projection and if average growth exceeds 2% the Tax Revenue limit for the Added Territory will he reached sooner. Furthermorc, the gross tax increment limit may be changed by future acts of the State Legislature or amendments to the Redcvelopment Plan by the Rcdevelopment Agency. See "CLRTA(N RISKS TO BONDHOLDLRS." In the 2007 Loan Agreement, 1hc Redcvelopmcnt Agency covcnants that on or bcfore June 30 of cach ycar, commencing Junc 30, 2007, it will submit a Report of an Indcpendent Rcdevclopmcnt Consultant (as dcfincd in the 2007 Loan Agreement) to the Bond Insurer showing thc total amount of Tax Revcnues rcmaining available to be received by the Redcvelopment Agency under the cumulative tax incrcmcnt limitation of the Redevelopment Plan, as well as future cumulative annual debt service with respect to the 2007 Loan and all Parity Debt. Subject to any limitation set forth in the documents that �overn the Pariry 13onds, thc Redevelopment Agency will not accept Tax Rcvenues greater than such annual debt scrvicc in any year, if such acceptance will cause the amount remaining under the tax increment limit to fall below remaining cumulative annual dcbt scrvice with respcct to the 2007 Loan and all Pariry Dcbt, except for thc purpose of depositing such revenucs in escrow for the payment of such debt service or for the prepaymcnt or redemption of the Outstanding Parity Debt, the 2007 Loan or any Parity Debt. Once it is determined that Tax Rcvenues available to be rcceivcd by the Rcdevelopment Agency under thc aforementioncd tax incrcmcnt limitation in an upcoming year will not exceed 110% of aggregate rcmaining debt service on the 2007 Loan and all outstanding Parity Debt, the Redcvelopment Agency is required to escrow all current and future Tax Revenucs and use such amounts solely for the purpose of paying dcbt scrvice on thc Outstanding Parity Dcbt, thc 2007 Loan and all Parity Dcbt. Sec APPGNDIx E—"SUMMARY OF PRINCIPAL LEGAL DOCUMENTS—Tr1G LoAtv AGRE�MENT-0ther Covcnants of the Redcvelopment Agency—Annual Review of Tax Rcvenues." Accuracy of Assumptions To estimate the revenues available to pay debt service on the Bonds, the Redevclopment Agency has made certain assumptions with regard to the assessed valuation of taxable properry in the Projcct Area, future tax ratcs, percentage of taxes collected, the amount of funds available for investment and the interest rate at which those funcis will be invested. The Redevelopmcnt Agency bclievcs these assumptions to be rcasonable, but to the extent that the assessed valuation, the tax rates and the percentages collected, are less than thc Redevelopment Agency's assumptions, the Tax Revenues available to make thc Loan Paymcnts and oec�a2��,�-z 29 thc resulting debt service on the Bonds will, in all likclihood, be less than those projected herein. Sce "DGBT SERVICE SCi-IEDULE" and "THE PRO.TECT AREA—Debt Service Coverage Projections." Reduction of Tax Revenues Tax Rcvenues allocated to the Redevelopment Agcncy, which constitute the primary securiry for the Bonds, are determined by the incremental assessed value of taxable property in the Project Area, the current rate or rates at which property in the Project Area is taxed, and the percentage of taxes collected in the Project Area. Several rypes of events which are beyond the control of the Redevelopment Agency could occur and cause a reduction in available Tax Revenues. A reduction of taxable values of property in the Project Area or a reduction of the rate of increase in taxable valucs of property in the Project Area caused by economic or other factors beyond the control of the Redevelopment Agency (such as a successful appeal by a property owncr for a rcduction in a property's assesscd value, a reduction of the general inflationary rate, a reduction in value, or the destruction of property causcd by natural or other disasters) could occur, thereby causing a reduction in the Tax Revenues that secure the Bonds. Such a reduction in Tax Revenues could have an adverse impact on the Redevelopment Agency's ability to make timely payment of principal of and interest on thc Bonds. Moreover, in addition to the other limitations on Tax Revenues described under "LIMITATIONS ON TAX RGVENCTES," the State clectorate or Lcgislature could adopt a constitutional or Iegislativc property tax decrcase with the effect of reducing Tax Revenucs payable to the Redevelopment Agcncy. Therc is no assurance that the State clectorate or Legislaturc will not at somc future timc approve additional limitations that could reduce Tax Revenues and adversely affect the security of the Bonds. Additionally, thc Redevclopment Agency has no power to levy and collect property taxes. The rcceipt of tax revenues by thc Redevelopment Agency is dependent on thc timely payment of property taxes by landowncrs within thc Projcct Area. Substantial delinqucncics or other reductions in thc payment of property taxes on real property in the Project Area by a large number of landowners could have an adversc cffect on the Redevelopmcnt Agency's ability to make timely debt service payments on the Bonds securcd by Tax IZevenues derived from the Project Area. Tax revenues allocated to the Redevelopment Agency are distributed throughout the fiscal year in installmcnts, with a first installmcnt in Deccmber and the sccond installment in June of the same fiscal year. The payments are adjusted to reflect actual collections. Reductions in Unitary Valucs As the resull of the adoption of AB 454 (Chapter 921, Statutes of ] 986), a portion of the County- wide unitary values assigned to public utilities was allocated to thc Project Area. In Fiscal Ycar, 2005-06, approximatcly 3.76% of the Tax Revenues in the Original Area and approximately 0.54% of the Tax Revenues in the Added Teiritory was attributable to such unitary values. Any substantial reduction in the values of public utility propertics, either because of deregulation of a utiliry industry or for any other reason, will have an adverse impact on the amount of Tax Revenues. However, any such impact with respect to utility properties within the Project Area will be lcssened because the impact will be spread on a Counry-wide basis. For furthcr information conceming unitary values, see "LIMITATIONS ON TAX REVC•NU�S—PropCrty Tax Collection Proccdures" and "—Taxation of Unitary Property." Appeals to Assessed Values There are two basic types of assessment appeals providcd for under State law. The first type of appeal, commonly referred to as a base year asscssment appcal, involves a dispute on the valuation assigned by the Counry assessor immediately subsequent to an instance of a change in ownership or complction of new construction. If the basc year valuc assigned by the County assessor is reduced, thc valuation of the property cannot increase in subsequent years more than two percent annually unless and until anothcr change o�uaz��s-z 30 in owncrship andlor additional new construction activity occurs. The second type of appcal, commonly referred to as a Proposition 8 appeal, can result if factors occur causing a decline in the market value of the property to a Icvel below the property's then current taxable value (escalated base year valuc). Pursuant to California law, a property owner may apply for a Proposition 8 reduction of the property tax assessment for such owner's property by filing a written application, in form prescribed by the State Board of Equalization, with the appropriate counry board of cqualization or asscss►nent appeals board. In the County, a property owner desiring a Proposition 8 reduction of the assesscd valuc of such owncr's property in any one year must submit an application to the Riverside County Assessment Appcals Board (the "Appeals Board"). Applications for any tax year must be submittcd by Scptembcr 15 of such tax year. Following a review of the application by the Riverside County Assessor's Office (the "County Assessor"), the County Assessor may offer to the property owner the opportunity to stipulate to a reduccd assessment, or may confirm the assessment. If no stipulation is agreed to, and the applicant elccts to pursue thc appeal, the matter is brought before the Appcals Board (or, in some cases, a hearing examiner) for a hcaring and decision. The Appeals Board generally is required to deternune the outcome of appeals within two years of each appcal's filing date. Any rcduction in the assessment ultimately grantcd applics only to the year for which application is madc and during which the writtcn application is filed. The assessed valuc increascs to its pre-reduction levcl (cscalated to the inflation rate of no more than two percent) following the ycar for which the reduction application is filed. Howcver, the Counry Assessor has the power to grant a reduction not only for the year for which application was originally made, but also for the then current ycar and any intervening years as well. In practice, such a reduced assessment may and often does remain in effcct bcyond the year in which it is �-anted. See "LIMITAT(ONS ON TAX REVENUGS—PCopCrty Tax Collection Procedures" and "THE PR01�CT AReA—Assessment Appeals." An appeal may result in a reduction to the County Assessor's original ta�cable valuc and a tax refund to the applicant property owner. A reduction in taxable values within the Project Area and the refund of taxes which may arise out of successful appeals by these owners will affect the amount of Tax Revenues and Subordinatc Tax Rcvenues availablc to pay debt servicc on the 2007 Series A Bonds. Reduction in Inflation Rate As described in greater detail above, Article XIII A of the California Constitution provides that the full cash valuc base of real property used in determining taxablc value may be adjusted from year to year to reflect the inflation rate, not to exceed a two percent increase for any given year, or may be reduced to reflect a reduction in the consumer price index, comparable local data or any reduction in the event of declining property value causcd by damage, destruction or other factors (as described above). Such measurc is computed on a calendar year basis. Any resulting reduction in the full cash value basc over thc term of the 2007 Serics A Bonds could reduce Tax Revenues. See "LIMITATIONS ON TAX REVENLJES—AltiClC XIII A Of thc State Constitution." Bankruptcy and Foreclosure The rights of the Owners of the 2007 Series A Bonds and the enforceabiliry of the obligation to makc payments on the Bonds may be subject to bankruptcy, insolvency, reorganization, moratorium and othcr similar laws affccting creditors' rights under cuncntly existing law or laws enacted in the future and may also be subject to the exercise of judicial discretion under certain circumstances. 'fhe opinions of Bond Counsel as to thc enforceability of the obligation to make payments on the 2007 Series A Bonds will be qualified as to bankruptcy and such othcr lcgal events. Sec ApPe1Jv►x E—"PROPOSBD FORM OF BOND COUNSEL OPINION." Furthcr, the payment of the tax incrcment revenues and the ability of thc County to timely foreclosc the licn of a delinquent unpaid tax may be limited by bankruptcy, insolvency, or other laws generally affecting creditors' rights or by the laws of the State rclating to judicial foreclosure. Any delay in prosecuting o�oaz�os-z 31 superior court foreclosure proceedings would increase the likelihood of a dclay or default in payment of thc principal of and interest on the 2007 Series A Bonds and thc possibility of delinquent tax inswllmcnts not being paid in full. Delinquencies If thc Tecter Plan were discontinued, dclinqucncies in thc payment of property taxes and the impact of bankruptcy proceedings on the legal ability to collect property taxes could have an advcrse impact on the abiliry of the Redevelopment Agcncy to make timely payments under the 2007 Loan A�-eement. The valuation of property is determined as of thc January 1 lien date as equalized in August of each year and equal installments of taxes levied upon secured property become delinquent on the following December 10 and April 10. Taxes on unsecured property are due April I and bccome delinqucnt August 31. Sec "THE PRo7ECr ARLA—Tax Levies, Collections and Delinquencies." Statc Budget The following informution concerning the State's 2005-06 and 2006-07 Fiscal Year Budgets have been obtained from publicly available information on the State Depurtment ojFinance, the State Treasurer and the California Legislative Analyst O�ce websites. The e.stimates and projections provided be%w are based upon various assumptions us updated in the 2006-07 Budget, which may he af�ected by numerou.s factors, including future economic conditions in the State und the nation, and there can be no ussurunce that the estimates will be achieved. For f:�rther information and discussion oJ factors underlying the State'.s projections, .see the aforementioned websites. The Redeve/opment Agenc•y believes such injormation to be reliable, however, the Redevelopment Agency takes no responsibiliry as to !he accuracy or completenes.s thereof and has not independently verifred such information. In connection with its approval of the budget for Fiscal Years 1992-93, 1993-94, 1994-95, 2002-03, 2003-04, 2004-OS and 2005-06, 1he Staie Legislature cnactcd legislation which, among other things, rcallocated funds from redevelopment agencics to school districts by shifting a portion of each redevclopment agency's tax increment, net of amounts due to other taxing agencies, to school districts for such fiscal years for deposit in the Education Revcnue Augmentation Fund ("ERAF"). The amount required to be paid by a redevclopmcnt agcncy under such Icgislation is apportioncd among all of its rcdevelopment projcct arcas on a collective basis, and was not allocated separately to individual project areas. In Fiscal Year 2002-03, thc aggrcgatc amount transferred by redevclopment agencics into ERAF was $1.3 billion, was $250 million for Fiscal Year 2U04-OS and �250 million for Fiscal Ycar 2005-06. Based on the tax increment revenucs shown in of the State Controllcr's Annual Report as being rctaincd by thc Redevclopmcnt Agcncy, the Redevelopment Agency was requircd to pay 52,113,709 into ERAF in Fiscal Year 2003-04 of which S was amibutable to the Original Area and S was attributablc to the Added Territory, $3,887,133 in Fiscal Year 2004-OS of which � was attributable to the Original Area and S was attributable to the Added Teiritory, and $3,995,041 in Fiscal Year 2005-06 of which S is attributable to the Original Area and $ was attributable to the Added Temiory. Fisca! Year 2005-06. The 2005-06 Budget Act (the "State 2005 Budget Act") was adopted by the Legislaturc on July 7, 2005, along with a number of implcmenting measures, and signed by Govcmor Schwancneggcr on July 11. The State 2005 Budget Act reflected an improving State fiscal picture brought about by better- than-expccted growth in General Fund revenues. Thc Statc 2005 Budgct Act funds the Proposition 42 transfer of general fund sales taxes to transpoRation special funds, and included significant increascs in both K-12 and higher education. Thc State 2005 Budget Act did not use any of the remaining S3.7 billion in dcficit-financing bonds authorizcd by Proposition 57, and the State prepaid the $1.2 billion VLF "gap" loan that was duc to local governments in Fiscal Ycar 2006-07 in August 2005. 06042�pos-2 32 At the same time, State 2005 Budget Act included approximately $6 billion in savings and related budget solutions in order to maintain budgetary balance, including, among other solutions, thc ERAF transf'er from redevelopment agcncics in the ag�,�regate amount of S25Q cnillion After taking into account the higher revenues and other offsetting factors (including higher Proposition 98 funding requirements under current law) the resulting operating shortfall for Fiscal Year 2005-06 was cstimated at �4.9 billion. Fiscal Year 2006-07. The 2006-07 Budget Act (the "State 2006 Budget Act") was adopted by the Legislaturc on June 27, 2006 and signed by the Governor on June 30, 2006. The State 2006 Budget Act assumes Piscal Ycar 2006-07 revenues of $94.4 billion and cxpenditures of �]01.3 billion, resulting in an operating shon-fall of �7 billion, which partly reflects the prepayment of �2.8 billion in budgetary dcbt oblibations, lcaving the State Gencral Fund with a ycar-cnd reserve of �2 billion, compared to the $9 billion year-end reserve in Fiscal Year 2005-06. The Statc 2006 Budget Act, among othcr things, (i) allocates new revenues to K-12 and community collcge cducation, increases funding for higher education, and prepays approximately �2.8 billion in budgetary debt, which is roughly consistent with the Governor's budget revision released on May 13, 2006; (ii) makes partial repayments of debt; (ii) funds a budget stabilization account; (iv) makes augmentations to hcalth, resources, corrections and local govemments (including increases in funding for county block grants for California Work Opportuniry and Responsibility Kids, Child Welfare Services, and foster care; additional funding for local law enforcement and local flood control; and largely one-time funding to hospitals to increase patient capacity to meet public health emergencics, such as an avian flu pandemic); and (v) makes the first payment of a proposed settlemcnt in the amount of �2.9 billion, which will bc paid ovcr six years commcncing in Fiscal Year 2007-08, rclatcd to a lawsuit involving school funding. The State 2006 Budget Act does not include any ERAF transfers from redevelopment agencies. The Rcdevelopmcnt Agency cannot predict whether the State Legislature will cnact future legislation requiring additional or increased future shifts of tax increment revenues to the Sate and/or to schools, whether through an arrangcmcnt similar to ERAF or by othcr arrangemcnts, and, if so, the effcct on future Tax Revenues. Natural Disastcrs [Wildfres. The City is located in area where wildfires are a common occurrence. [Discussion of effects recent Palm Springs Fire- TO COME]. Any natural disaster or physical calamity, including wildfires, floods, landslides and earthquakes could result in damage within the Project Area. The occurrence of such cvcnts could adversely impact the value of real property in thc Project Area and resulting Tax Revenues, thc economy of the City, and, accordingly, the ability of the Redevelopment Agency to make payments under the Loan Agrccmcnts whcn due.) Flooding. Flood zones are identified by the Federal Emergency Management Agency ("FEMA"). FEMA dcsignatcs land locatcd in a low- to moderate-risk flood zone (i.e. not in a floodplain) as being within a Non-Special Flood Hazard Area (a "NSFHA"). FEMA defines an NSFHA as an arca that is in a low- to moderate-risk flood zone (i.e. not in a floodplain) and has less than a 1% chance of flooding 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 Drainageway, Floodway, and Watercourse Ordinance that regulates deveiopment in flood prone areas by preventing construction in such areas. Development is permitted in these areas once floodflow hazards are eliminated. Areas in thc City that have received flood control improvements are those subject to potentially dcstructive floods. Significant capital investments have becn made in the community where these thrcats occur. The City can make no representation that future maps will o�oaz�PoS-z 33 not bc reviscd to includc the Ciry within an area dcemed subject to flooding. The occurrencc of flooding in thc Project Area could result in a reduction in Tax Rcvenues and Subordinate Tax Rcvcnucs. Such a reduction of Tax Revenues could have an adverse effect on the ability of the Redevelopment Agency ability to make timcly paymcnts of principal and interest on thc 2007 Loan. Seismic Factors. Generally, seismic activiry occurs on a regular basis in the State. Periodically, the magnitude of a single seismic event can cause significant ground shaking and potential damage to property located at or near the center of such seismic activity. The occurrence of severe scismic activity in the City could result in damage to roads, infrastructure and other property within the Project Area. The occunence of such a severe scismic could have a negative impact on assessed values of taxable values of property in the Project Area and could result in a reduction in Tax Revenues and Subordinate Tax Revenues. Such a reduction of Tax Revenues or Subordinate Tax Revenues could have an adverse effect on the ability of the Rcdevelopment Agency ability to make timely payments of principal and interest on the 2007 Loan. Hazardous Substances An additional environmental condition that may result in the reduction in the assessed valuc of property would be the discovery of a hazardous substance that would limit the beneficial use of taxable property within thc Projcct Area. In gcneral, thc owncrs and operators of a property may be rcquircd by law to remedy conditions of the property relating to releases or threatened releases of hazardous substances. The owner or operator may be required to remedy a hazardous substance condition of property whcther or not the owner or operator has anything to do with creating or handling the hazardous substancc. The effect, thcreforc, should any of the property within the Project Area be affected by a hazardous substance, could be to reducc the marketability and valuc of the property by the costs of remedying the condition. Loss ol' Tax Exemption In order to maintain the exclusion from gross income for fedcral income tax purposes of the intcrest on the Bonds, the Redevelopment Agency has covenanted in the Indenture to comply with the applicablc rcquircmcnts of the Intemal Revcnue Code of 1986, as amcnded. The interest on the 2007 Serics A Bonds could become includable in gross income for purposes of federal income taxation retroactive to the date of issuance of such 2007 Series A Bonds as a result of acts or omissions of the Redevelopment Agency in violation of this or other covenants in the Indcnture applicable to the 2007 Series A Bonds. Thc 2007 Series A Bonds are not subject to redemption or any increase in interest rates should an event of taxability occur and will remain outstanding until maturity or prior redemption in accordance with the provisions contained in the Indcnturc. Sec "TAx MATTERS." Risk of Tax Audit In Deccmber 1999, as a part of a larger reorganization of the Internal Revcnue Service (the "IRS"), thc IRS commenccd operation of its Tax Exempt and Government Entities Division (thc "TElGE Division"), as the successor to its Employee Plans and Exempt Organizations division. The new TE/GE Division has a subdivision that is specifically devoted to tax-exempt bond compliance. Public state►nents by IRS officials indicate that the number of tax-exempt bond examinations (which would include the issuance of securities such as the 2007 Series A Bonds) is expected to increase significantly under thc ncw TE/GE Division. There is no assurance that if an IRS examination of the 2007 Series A Bonds was undertaken that it would not adversely affect the market value of the 2007 Scries A Bonds. See "TAx MATTGRS." The Redevelopment Agency has not becn contacted by the IRS regarding the examination of any of its bond transactions. 06432�pos-2 34 Sccondary Market There can bc no guarantcc that therc will be a secondary market for the 2007 Serics A Bonds or, if a sccondary markct exists, that the 2007 Series A Bonds can bc sold for any particular price. Occasionally, because of general market conditions or because of adverse history or economic prospects connected with a particular issuc, secondary marketing practices are suspended or terminated. Additionally, prices of issues for which a market is being made will depend upon then prevailing circumstances. Such prices could bc substantially different from the original purchase pricc. THE FINANCING AUTHORITY The Financing Authoriry is duly organized and existing under a Joint Exercise of Powers Agreement dated January 26, 1989, by and bctween the Ciry and the Redcvelopment Agency, and under thc provisions of Chaptcr 5 of Division 7 of Title 1 of the Statc Government Codc. The membcrs of the City Council servc as the Commission members of the Financing Authoriry. The Financing Authority has no taxing power and no sourcc of revcnue to pay debt service on thc Bonds other than the Rcvenues. The Financing Authority has no taxing powcr. Scc "SECURITY AND SOURCGS OF PAYMENT FOR THG BONDS." THE REDEVELOPMENT AGENCY Authority, Members and Pcrsonnel The 12edevelopment Agency was established pursuant to the Redevelopment Law, and was activated in 1974. The Redevelopment Agency adopted the redevelopment plan for the Project area in July 1991. The Project Area is thc only project area of the Redevelopmcnt Agency. The Redevelopment Agency has no taxing power. Members of thc Ciry Council of the City serve as members of the Redevelopment Agency. The City Council membcrs arc clected at large for four-year overlapping terms. The current members of the Redevclopment Agency are set forth on the inside covcr pagc of�this Official Statement. The Rcdevelopment Agency is administered by a staff selected from the employees of the City and is undcr the ovcrall direction of Mr. Ortega. Brief resumes of the professional staff of the Rcdevelopmcnt Agency are set forth below: Carlos L. Ortega, Executive Director. Mr. Ortega has served as Executive Director of the Redevclopment Agency since 1983. He was also appointed City Manager in August 2000. From 1980 to 2000, Mr. Ortega served as Assistant City Manager and from 1977 to 1980 as Assistant to the City Manager. Prior to 1977, he servcd as Interim City Manager for one ycar and Assistant City Manager/Finance Dircctor (five years) for the City of Coachella, California. Mr. Ortega received a Bachelor of Science degree in Economics from University of Califomia, Riverside, and has completed graduatc studies in Public Administration and Management at Univcrsity of California, Riversidc and University of Redlands. Justin McCarthy, Assistant City Manager for Redevelopment. Mr. McCarthy has servcd as Assistant City Managcr for Redevelopmcnt sincc November 2001. From 1983 to 1987, Mr. McCarthy was an analyst in the City of Long Beach implementing redevelopment projects in the downtown central business district, the port industrial area and Long Beach Airport. From 1987 to 1988 he served as thc Redcvelopment Managcr for the San Dicgo Southeast Economic Dcvclopmcnt Corporation managing industrial and commercial projects and from 1988 to 2001 he served as the Deputy Executive Dircctor and Community oboa2���,s-z 35 Dcvelopment Director for thc City of Commerce. Mr. McCarthy received a Bachelors dcgree in Political Science and a Masters degree in Public Administration from California State University Long Beach. Arla K. Scon, Senior Financial Analyst jor Redevelopmenl. Ms. Scott was appointed as Senior Financial Analyst for Redcvelopment in January 2006 and is responsible for the review, analysis and budget tnonitoring of the finances and bond issues of the Redevelopment Agency. From 1990 to 2006, she was e►nployed by JPMorgan Chasc Bank, where shc began in thc Trust Operations Department and was later promoted to the Treasury and Security Services Department as a Relationship Manager. In that position she worked in the Municipal and Corporate Debt Department, where she workcd with various municipalities and corporations serving as a bond trustee. She was later promoted to the Trust Compliance Departmcnt whcre shc was responsible for reviewing documents, laws and regulations in order to mitigate risk. Shc received a Bachclor of Business Administration degree in Finance from University of Houston. Sheila R. Gilligan, Assistant City Manager for Community Services. Ms. Gilligan has served as the Assistant City Manager for Community Services since 2000. She is responsible for the areas of Administration (including grants and franchise agreements), Human Resources, City Clerk, Civic Arts, Marketing and Promotion, Public Info�nation, thc Visitor's lnforcnation Centcr, and spccial events for the City. Prior to appointment to her cuncnt position, Ms. Gilligan served as the Director of Communiry Affairs while also scrving as thc City Clerk. Ms. Gilligan served as Ciry Clcrk from 1976 to June, 2001. Paul S. Gibson, Treasurer/Finance Director. Mr. Gibson has served as Treasurer/Finance Director of the City since 1988 wherc he is responsible for prcparation of the Ciry budgets and annual financial reports, administration of debt, investment of surplus cash, collection of business license fees, payroll, purchasing, accounts payable and oversight of information systems. He has also served as the Treasurer of the Redevelopmcnt Agency sincc 1988. Mr. Gibson has been employed by the Ciry since June 1985, when he was hired as the Accounting Supervisor. Prior to joining the City, he served from 1980 to 1985 as the Accountant-Auditor for the Imperial Counry Auditor-Controllcr's office. Mr. Gibson holds a Bachelor of Science dcgrce in Accounting from San Diego State University. David L. Yrigoyen, Director of Redevelopment and Housing. Mr. Yrigoyen was appointed as Dircctor of Redevelopment and Housing and is responsible for all housing and redevelopment activities within the City. He has becn employed with the City since 1985 when he servcd as thc Senior Administrative Assistant to the Redevelopment Agency and thcn was promoted to Redevelopment Manager. From 1982 to 1985, Mr. Yrigoyen worked with the City of Coachella, as the Economic Development Cc�ordinator. Mr. Yrigoyen receivcd a Bachelor of Arts degree in Political Science from Univcrsity of California, Berkeley, and a Mastcr of Arts degrcc in Managcment from National University, San Diego. Rache!!e D. Klassen, Secretary. Ms. Klassen has bcen Secretary of the Redevelopment Agency and Ciry Clerk since July 1, 2002. She has bcen cmploycd by the City since 1995. In 1997, she began working in City Clerk's Office; initially as the Records Technician, was appointed Deputy Ciry Clerk in 1998, and then Ciry Clerk. She received Certified Municipal Clerk status from the Intemational Institute of Municipal Clerks in October, 2001. As City Clerk, she also serves as Secretary to Housing Authority and the Finance Authority, with responsibilities of preparing and presenting all agendas and minutcs for same, maintaining all official City/Agency/Authority records, as wcll as the related duties of the City elections and being availablc to the public for information on lcgislative and adminislrative actions. Ms. Klasscn holds an Associate in Arts Degrec, with honors, from Waldorf College, Forest City, lowa, with continuing units obtained at College ofthc Dcsert. Veronica Tapia, Redevelopment Accountan[. Ms. Tapia has been employed by the City for morc than nine years, and for the last two yeazs has scrved as the Accountant for the Redevelopment Agcncy. Ms. Tapia is responsible for compiling the federal and State mandated reports, thc administration of thc outstanding bond issues of the Redevelopment Agency, and the overall accounting duties for both thc 06042�pos-2 36 Rcdevelopment Agency and thc Housing Departmcnt. Ms. Tapia received a Bachelor of Science dcgree, graduating Summa Cum Laudc, in Business and Management from thc University of Redlands and currently is completing graduatc studies in Management at the University of Redlands. Powcrs All powers of thc Redevelopment Agency are vested in its five-member Board. They are charged with thc responsibility of eliminating blight through the proccss of redevelopment. Gcnerally, this process culminatcs when the Redevclopmcnt Agcncy disposes of land for development by the private sector. In order to accomplish this, the Redevclopmcnt Agency has broad authority to acquire, develop, administer, sell or lcase property, including the right of eminent domain and the authoriry to issue bonds and expcnd their procccds. Prior to disposing of land for redevelopment, the Redevelopment Agency must complete the proccss of acquiring and assembling the necessary sites, relocating residents and businesses. In addition, the Redcvelopment Agency may demolish dcteriorated improvements, undertake environmental mitigation, grade and prepare sites for purchase, and in connection with any devclopment can cause streets, highways and sidewalks to be constructed or reconstructed and public utilities to be installcd. Rcdevclopmcnt in the State of California is camed out pursuant to thc Community Redcvelopment Law (Section 33000 et seq. of the Health and Safety Code). Section 33020 of the Redevelopment Law defincs rcdevelopment as the planning, development, replanning, redesign, clearance, reconstruction or rehabilitation, or any combination of these, of all or part of a survey area and the provision of such residential, commcrcial, industrial, public or other structures or spaces as may be appropriate or necessary in the interest of thc gencral wclfarc, including recreational and other facilities incidental or appurtenant to them. Thc Rcdevelopmcnt Agency may, out of the funds availablc to it for such purposes, pay for all or part of the value of the land and thc cost of buildings, facilities, structures or other improvements to be publicly owned and operated to thc extcnt that such improvements arc of bencfit to thc project area and no other reasonable means of financing is available. The Redevelopment Agency must sell or lease remaining property within a project area for redevelopment by others in strict conformity with the redevelopment plan, and may specify a period within which such redevclopment must begin and be completed. In accordance with these criteria, the Rcdevclopment Agcncy has adoptcd a Redcvelopment Plan, as amendcd, in the Project Arca that authorizcs thc use of thc redevelopmcnt process and proccdures. Redevelopment Agency Finances Financia! Statements. The accounts of the Redevelopment Agency arc organized on thc basis of funds and account groups. The operations of each fund are accounted for with a separate set of self-balancing accounts that comprise its assets, liabilities, fund equity, revenues and expenditures. The audited financial statements of the Redevelopment Agency for thc Fiscal Year ending June 30, 200[5] are sct forth in APpr•tvD1x B. The auditor has consented to the inclusion of its report in this Official Statement. See also "FINANCIAL STAT'GMENTS." Retirement Plan. Substantially all full-timc City employees, including employces of thc Redevclopment Agency, are eligible to participate in retirement br,nefit plans through a contract with the California Public Employees' Retirement Systcm ("PERS"), a multiple-employer public sector employec defincd bcnefit pension plan. PERS providcs rctiremcnt and disability benefits, annual cost-of-living adjustmcnts and death benefits to PERS members and beneficiaries. PERS acts as a common investment and o�oar��s-z 37 administrative agcnt for participating public entities within the State. PERS is a contributory plan dcriving funds from employcc contributions as well as from cmployer contributions and eamings from investments. PERS maintains two pension plans for the City, a Safety Plan (the "Safety Plan") and a Miscellaneous Plan (the "Miscellaneous Plan" and, together with the Safety Plan, the "PERS Plans"). Thc City contributes to PERS amounts equal to the recommcnded rates for the PERS Plans multiplied by thc payroll of those current employccs of the City, including the Rcdevclopment Agency, who are eligiblc undcr PERS. Thcre arc 19 positions in the Redevelopment Agcncy cligible to participatc in PERS. For information conceming PERS, including information relating to its financial position and investments contact PERS directly at CaIPERS, Lincoln Plaza, 400 P Street, Sacramento, California 95814, telcphonc: 888-225-7377. Information regarding the contributions made by the City to PERS for the PERS Plans is available in the City's Comprehensive Annuai Financial Report copics of which are available upon request from thc City of Palm Dcsert Department 73-510 Fred Waring Drivc, Palm Desert, California 92260-2578; tclephonc: 760-346-0611. Ot/:er Post Employment Benefits. The City offers thc PERS Hcalth Care Program to its retirces. The City contributcs S48 per month on behalf of each rctircc eligible for PERS and makcs an additional contribution towards certain rctirees' premiums undcr a Rctirce Scrvicc Stipcnd program. If the rctircc retires from both the City and PERS simultaneously, has attained the age of 50 and completed a minimum of 10 ycars of service with the City and satisfies any other requirements specified in such program continued covcrage for cligible retirees, spouses and/or eligible dependents for the lifctime of the retiree upon satisfaction of the above-rcferenced criteria. The Retiree Service Stipend is not actuarially funded and thc assets are accounted for in an agency fund. An actuarial valuation completed for the Retiree Servicc Stipend program as of July 1, 2002 indicated that the amount of the actuarial liabiliry to current and future liabilitics for thc City to bc �9,761,065. [UPDATE] THE PROJECT AREA Gencral The Project Area is located in the Ciry and includes approximately 5,820 acres, comprising approximately 12,825 parcels, zoned for residential, office, commercial, industrial, public and open space uses. The Project Area incorporates an approximately 70-acre Civic Center campus, including the Sheriff's and County Library facilities; multifamily rental, townhouse and single-family developments; the Canyons at Bighorn, a 275-unit luxury custom homc development; and over two million square fect of retail spacc, including three major retail malls. The Westfield Shoppin�;town (located in the Original Area) was expanded in 20 to add two parking garages totaling 1,000 parking spaces, the expansion of Macy's, and an additional 40,000 square feet of retail space, including Barnes & Noble. For a map of thc Project Arca scc page viii. For certain information regarding the City, see APPENDIX C—"GENERAL 1NFORMATION CONCERNTI�G THE CITY OF PALM DESERT." Origina! Area. The Original Area comprising approximately 580 acres and 444 parcels is generally bounded by the City limits on thc west and east, Alessandro Drivc on the north and El Paseo on thc south. Added Territory. The Added Temtory comprising approximately 5,240 acres and 12,665 parccls is gencrally boundcd by the Whitcwatcr Storm Channel on the north, the Ciry limits on thc east and south and the Palm Valley Storm Channel and thc City limits on the west. 06042\pns-2 38 Redevelopment Plan Limits The Project Arca was formally established with the adoption by the City Council of a redcvclopment plan (the "Original Plan") for approximately 580 acres (the "Original Area") pursuant to Ordinancc No. 80, adopted on July 16, 1975. Approximately 5,240 acres (the "Added Territory") were addcd to the Oribinal Area pursuant to amendments to the Original Plan approved and adopted by the City Council by Ordinancc No. 275, adopted on November 25, 1981 and Ordinance No. 324, adopted on October 13, 1983 (collectively, the "Amendments"). The Original Plan, as amended by the Amendments, is referred to as thc "Redevelopment Plan." On December 8, 1994, thc Ciry adopted Ordinance No. 765 establishing Plan licnits required by AB 1290 for Project Area No. l, the Original Area and Added Territory. On February 27, 2003 the Ciry adoptcd Ordinance No. 1035, amcnding thc Rcdevelopment Plan as permitted by SB 211 to eliminate the time limit on incurring indebtedncss. Pursuant to SB 1045 thc Redevclopment Agency amended the limits of the Projcct Area by adopting Ordinance No. 1082, adding one year to thc term of effectiveness and thc time limit to collect tax increment. Origina! Area. On December 11, 1986, the City adopted Ordinance No. 484 which limits the amount of tax revenues which can be divided and allocated to the Agency from the Original Project Arca pursuant to thc Redcvelopment Plan to a maximum of S758,000,000. Table 2A summarizes the Redevelopment Plan Limits within the Original Area. Table 2A Palm Desert Redevelopment Agency Project Area No. 1— Origina! Area Summary of Redevelopment Plan Limits Plan Limit Termination Receipt of Tax Increment Base Debt Plan and Debt Year Incurrence Exniration Re�avment 1976-77 None"� 7/16/16� 7/16/26�z� Revenue Limits ($ in millions) Gross Tax lncrement Can $758 Gross Net Tax Bonded Amount Increment Debt Received N/A $200 $125.881� (1) Pursuant to SB 211, City Council adoptcd Ordinance No. 1035 on Fcbruary 27, 2003, amending the Redcvelopment Plan to eliminate the time limit to incur debt. (2) Pursuant to SB 1045, the Redevelopment Agency amendcd thc Redevelopment Plan through the adoption of Ordinancc ho. 1082 to add one year to the term of eft'ectiveness and the timc limit to collect tax increment. (3) Rcpresents b�ross tax increment revenues received as of June 30, 2006. Gross tax inerement revenues includes secured, unsecured, utility and supplemcntal revenue, less property tax administrative costs paid to the County pursuant to SB 2557. Sec "Ltnu rnTtoxs ov Ta.x Re.venUts—Propeny Tax Administrative Costs: ' Source: Reclevelopmen� Agency. Added Territory. On January 24, 1991, the City approved the Sixth Amendment to thc Redevclopment Plan (the "Amenclment") limiting the amount of tax revenues which can be dividcd and allocated to the Agency from the Added Tcrritory to a maximum of $500,000,000 (exclusive of amounts paid to any taxing agency, and exclusive of ainounts used to pay debt service, directly or indirectly, on obligations of the Agency or any taxin�; agency, to finance the acquisition of land or the construction of buildings, facilities, structures, or improvements of such taxing agencies). Through Fiscal Year 2004-05, the Added Territory has received $166,120,639 in net tax increment revenue. Both amounts are prior to the allowed adjustmcnt of dollars rcceived pursuant to Section 33683 of the Rcdevclopment Law which providcs for an adjustment based on payments made to ERAF. See also "CERTAR�I RISKS TO BONDHOLDERS—State obcuz�,��-z 39 Budget.") Thc Sixth Amcndmcnt also limits the amount of bonded indebtedness which can be outstanding at onc time to 5200,000,000 (exclusive of bonds issucd to finance the acquisition of land or thc construction of buildings, facilities, structures or improvcments of taxing agcncies). Tablc 26 summarizes the Redevelopment Plan Limits within thc Addcd Tcrritory. Table 2B Palm Desert Redcvclopmcnt Agency Project Area No. 1— Added Territory Summary of Redevelopment Plan Limits Plan Limit Tcrmination Reccipt of Tax Increment Base Debt Plan and Debt Year Incurrence Exairation Reoavment 1982-83 None�'� 11/25/22 11/25/32 Revenue Limits ($ in millions) Gross Tax Increment Net Tax Cao Increment SSOO�Z� N/A�j� Gross Bonded Amount Debt Received $200 � $295.983�`� (I) Pursuant to SB 211, City Council adopted Ordinance No. ]035 on February 27, 2003, amcnding thc Redevelopment Plan to eliminate thc timc limit to incur debt.(2) Pursuant to the Sixth Amendment to thc Rcdevelopment Plan adoptcd on January 24, 1991, the lax increment limit Cor the Project Arca is exclusive of amounts paid to taxing agencies and exclusive of amounts paid directly or indirectly by the Redevelopment Agency or any taxing entity to finance the acquisition of land, construction of buildings, facilities, structures or improvements for such taxing agencies. (3) Pursuant to SB 1045, thc Redevelopment Agency amended the Redevelopment Plan through the adoption of Ordinance No. l OR2 to add one ycar to the tertn of effectiveness and the time limit to collect tax increment. (4) Pursuant to the Sixth Amendment to the Redevelopment Plan, the Bonded Debt Cap excludcs bonds issued to financc the acyuisition of land, construction of buildings, facilities, structures or improvements to taxing agencies. (5) Represents b�ross tax increment revenues received as of June 30, 2006. Gross tax increment revenues includes secured, unsecured, utility and supplemental revenue, less property tax administrative costs paid to thc County pursuant to SB 2557. See "L�titiTnrioNs o� Tnx Revenues-Property Tax Administrativc Costs." Source: Redevelnpmen� �lgency. Controls, Land Usc and Building Restrictions The Redevelopment Plan for the Project Arca scts forth the principal land uscs permitted and thc building restrictions to be imposed in project development. It also assigns the Redevelopment Agency and thc City thcir respective responsibilities in carrying out thc Rcdcvclopment Plan. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) 064f2�pos-2 40 o � L � ��T � � L.' bA � � � � i " G *- o .� ❑ w w C � O � U '� �. � o ,� � � � � Q U U � •y ��a+ ci u '�' U � 4; O c.-� � � �� a� O � U � C .= O N N U +J > G � �d � � '� '� 'C � .O � U aU •C � N bA � bt.., � � (C U .� a � � ��� .� 'J N V: F'. � � � C 'b b C � O ,� O '� � � p io � . � � .� M � � � N � ., � � � Ca C '� � p � U � c c. � � � � �° V '3 C i„ ,� � > :3 � 3 U u O � � o � U N 'O c� � u C � u d bL � � � � ���° EU � !'7 O ^ V � � C � `° •'a Z a F` v ea v� �" L = u � e � � � o ., a 0 �" L CL � a ed �.r � F" u 0 � � "� h y � �V y Q � � O ti' � ` L •C [� � � 6� � � � a O O N R V Q CE C � � � �p �I N�O N� 00 � O N O O h ^� O� N O O O g ` O[� M O N��O ^ M p oo �D � 00 O M t� �--� �O O � 0�0 �O � � � � o0 � v1 N Q� �--� O' Q � � 0 0 o I O � N��� p I I N O �n �--� � N O O � n N OO �O O M��D I N .. v� Q� � M O� N-- I� C O O �O � M[� �7 � O�i �� N M� O � � N N N Q � � o � \ O � NO O N O I�--� [� ��000�oo o^ "�o��noo�o I ---� C�o � o0 0o t� .� C� � [� V') O� �n �--� fi v�i °O v�i �n �° � � � � � «�+ .-�-� � O � � Q� � ~ ^� y �I � .-. .--� M � V � � O N N � M � �0 � � .�p •b : ^ O �D L � L O ^� �--� N .G Q [� � ', z C RIO N�--� [� M O O--� � �C a M � N M �--� M 0 cC c ,o � � H � = o a � � � � ;� o � � V � q � � O � � c�i � ia °� OQ� �� O '� U U � .�L ' ^ ,��, � E"' y cC U'J C in .- ^� x>r�U�S�5 � 0 O � � Q T C 7 O U � � o 0 � E E � .� U d c a u aXi €e��ia C T O � � � s s � � oss E €s � � � �o � �'��a N K X V � d L �' � � o o ° � �; aa� �� � � aEi u Q � n' 6XJ U ...T O o�i �y � 7 y X � O .` y`�U � � v rn � y �- N y � � � Q y� ^ r O o. � � � �' N �; C C C � � � � � � (J yq N N O r,� v� V� 0 C � �p. N � C � � M p�: � pC � � � v�i v�i 7 G0 � r � � . a�No � � r � v, � � � 6A (n � � 7 3 . _ � .''_' �a �====3 s > > > >�c � 'C � '� '� c � H °� °� � N t�/1 f�r. f�/1 N i�i � A � � � � c $ v �v v v � U v�i v�i v�'i cn c°'i 3 � `.���.v� o6aaz��so-i 41 Summary of Development Redevelopment Agency Projects. The primary objective of the Redevelopment Plan is to correct infrastructure and traffic circulation deficiencies and promote the rehabilitation of property within thc Project Arca through the construction of certain public, recreational and open space improvements. To date the Redevelopment Agency has completed the following projects within the Project Arca: construction and installation of certain sewer and storm drain improvements and landscaping improvements; and undergrounding certain utilities, street widening, construction of parking facilities and renovation of public recreational facilities. The Redevelopment Agency expects to use a portion of the proceeds from the sale of the 2007 Scrics A Bonds to: construct on and off ramps at Portola Avenue and Interstate 10; widen various portions of Montcrcy Avcnuc, Portola Avcnuc, Country Club Drive and construct and install various othcr street improvements throughout the Project Arca; improve frontage roads along Highway 11 l; construct a sound attcnuation wall along portions of Fred Waring Drive; construct and install landscape, lighting, parkway and median improvements; construct a bridge on Portola Avenue over the Whitewater Channel; develop a visitors center (including the Henderson Building, bc�tanical gardens and relatcd public improvements) at El Paseo and Highway 111; underground utilities; construct a parking structure to accommodatc a hotcl and related development at the Desert Willow Golf Resort; fund a business facadc enhancement grant program; and construct a public swimming pool and related athletic facilitics at the College of the Desert. Privale Development. In addition to the projects directly sponsored by the Redevelopment Agency and described above, the following private projects are in various stages of devclopment within the Project Area including: renovation of scvcral commercial retaiUrestaurant developments on El Paseo, design and construction of hotel properties near El Paseo in thc Original Area, upgrade and conversation of a mobilc home park to condominium ownership and construction of a new restaurant at Entrada del Paseo. Principal Taxpaycrs The top 10 taxpayers within the Project Area for Fiscal Year 2006-07 own property with an aggregate value of $569,538,659, representing approximately 11% of the assessed value and % of the total incremental value of the Project Area for Fiscal Year 2006-07. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) 06042�os-2 42 Tablc 4, Tablc 4A and Tablc 4B list thc principal taxpayers and primary Area, the Original Area and the Added Tcrritory, respectively, based on the Fiscal value. Owner WEA Palm Dcscrt LP Elisabcth Stcwart Gardens SPE II PRU Dcscrt Crossing I-V Bighorn Development Harsch Invcstmcnt Realty May Departmcnt Stores Co. El Paseo Collection ROP lnc. - Federated Westem Sears Roebuck & Co. SUBTOTAL TOP TGN All Othcrs TOTAL Table 4 Palm Descrt Redevelopment Agency Project Area No. l- Combined Principal Taxpayers Fiscal Year 2006-07 No. of Parcels 6 349 1 11 170 11 558 12.267 I 2,825 Project Area Component Original Area Added Territory Added Territory Original Area Added Temtory Original Area Original Area Original Arca Original Arca Original Area Primary Land Use Commercial Rcsidential Commercial Commercial Rcsidcntial Commercial Commercial Commercial Commercial Commercial land uses in the Projcct Year 2006-07 assessed 2006-07 Total Assessed Value��� Amount�2� $117,156,693 94,645,204 91,234,317 90,505,974 41,495,986 31,646,751 29,681,029 29,945,320 22,543,253 20,684.132 $569,538,659 4,599,874,689 55,169,413,348 (1) Docs not reflect homeowners exemption. (1) 1ncluJes secured value (54,963,093,354) and unsecured valuc ($206,349,994). (?) Column does not total duc to independent rounding. Source: Cuun�v Assessor's OJJice 2006-07 Equnlized Loca/ A.ssessmen� Roll. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) % 227% 1.83 1.76 1.75 0.80 0.61 0.57 0.58 0.44 0.40 11.02% $8.98 100.00% o�oaz��s-, 43 Table 4A Palm Descrt Redevelopment Agency Project Area No. 1— Original Area Principal Taxpaycrs Fiscal Year 2006-07 Owncr WEA Palm Desen LP PRU Desert Crossing I-V Harsch Invcsnncnt Realty May Department Stores Co. El Pasco Collcction Scars Roebuck & Co. ROP Inc. - Federated Wcstcrn Dayton Hudson Corp. SKB PTP El Paseo Land Co. SUBTOTAL TOP TEN All Others TOTAL No. of Parcels 6 11 11 1 1 3 1 43 401 444 Primary Land Use Commcrcial Commercial Commercial Commcrcial Commcrcial Commercial Commcrcial Corrunercial Commercial Commercial (1) Does not reflect homeowners exemption. (2) Includcs sccurcd valuc ($775,429,430) anJ unsccurcd value (S I 13,909,971). (3) Column does not total due to indcpcndcnt rounding. Source: Countv A.cses.cor's O/fice 1006-07 Equulized Locu! Assessmen/ Roll. 2006-07 Total Assessed Value��� Amount�Z� $117,156,693 90,505,974 31,646,751 29,681,029 29,945,320 20,684,132 22,543,253 14,719,176 12,280,378 14,327,544 S383,490,250 505,849,151 S889,339,401 % 2.27% 1.75 0.61 0.57 0.58 0.40 0.44 0.28 0.24 0.28 7.42% 9.79 17.20% Table 4B Palm Desert Redevelopment Agency Project Area No. 1— Added Territory Principal Taxpayers Fiscal Year 2006-07 2006-07 Total Assessed Value��� Owner Elisabcth Stcwart Gardcns SPE II Bighorn Development Nationwide Health Properties Boslcy, L. Fcicor TRS Deep Canyon Partner Summit Cablc Scrviccs CC Palm Lake St. Margret's Episcopal SUBTOTAL TOP T�N All Othcrs TOTAL No. of Parccls 349 1 170 3 2 4 5 1 90 2 627 11,754 12,381 Primary Land Use Rcsidcntial Commercial Residential Rcsidcntial Residential Commcrcial Vacant Commcrcial Residential Institutional Amount�2j S94,645,204 91,234,317 41,495,986 16,823,682 12,704,715 12,223,221 11,541,775 10,908,404 9,184,073 9,036.753 S309,762,130 3,970,311.817 $4,280,073,947 % 2.19% 1.73 0.97 0.36 0.30 0.29 0.27 0.25 0.21 0.21 5.99% 76.80 82.80% ( I) Does not reflect homeowners exemption. (2) Includes securcd value ($4,187,633,924) and unsecured value (592,440,023). (3) Column Joes not totxl due to indcpendent rounding. Source: Cuunty Assessor's O(rce 1006-07 Equalrzed Loca! Assessmen! Ro/!. 061k12�pus-2 � Tax Rates Within the Statc tax ratcs vary from arca to arca, as well as within a communiry and a project area. The tax rate for any particular parccl is based upon the jurisdictions levying the tax rate for the arca (a "Tax Rate Area") in which thc parcel is locatcd. The tax rate applied to incremental taxable values consist of two components: (i) the general levy rate which may not exceed � 1.00 per S 100 of taxable values in accordance with Article XIII A of the State Constitution and (ii) the over-ride tax rate that is levied to pay voter approved indebtedness or contractual obligations that existed prior to the enactment of Proposition XIII. See "LIMITATION ON TAX REVENUES" and "C[RTAIN RISKS TO BONDHOLDERS-Reduction in Assessed Value." The over-ride tax rates can decline each year as increasing properiy values reduce the over-ride rate needed to be levied by the taxing entities to satisfy voter approved dcbt service obligations and as the voter approved debts is retircd over time. The taxing entities within a Tax Rate Area each rcceive a proratcd share of thc general levy and thc revenues resulting from any voter approved ovcr-ridc tax rates. The components that make up the tax ratc applicable to the Projcct Area are set forth in Table 5 below: Table 5 Palm Desert Redevelopment Agency Project Arca No 1 Breakdown of Tax Rate Fiscal Ycar 2006-07 TaxinQ AQencv County Gcncral Fund County Library County Fire City of Palm Dcscrt Dcscrt Sands Unificd School Desert Community College County Superintendent of Schools Riverside County Regional Park and Open Space Coachella Valley Public Cemetery Palm Springs Public Cemetery Dcscrt Hospital Coachella Vallcy Mosquito Abatcmcnt Coachclla Valley Recreation and Park Coachclla Vallcy Watcr District Coachclla Valley Resource Conservation Coachclla Valley Water District Improvement District 80 Coachclla Valley Watcr District Storm Water Unit Rancho Mirage Library Rancho Mira�;e Fire Asscssment District 1�0'l'AL Proiect Area No. 1 Tax Rates Orieinal Area Added Territory 0.28396% 0.28336% 0.02749 0.02885 0.05919 0.06211 0.36502 0.07585 0.04127 0.00429 0.00343 0.02012 0.01380 0.02088 0.02758 0.02221 0.03491 1.00000% Source: Crry of Pulm Deserl Finance Depu�7ment. 0.02171 0.36904 0.08038 0.04373 0.00430 0.00302 0.00028 0.01322 0.01463 0.01840 0.02921 0.00021 0.00976 0.01730 0.00016 0.00035 1.00000% 06042�pos-2 45 Historical, Current and Projected Tax Revenucs The Redcvclopment Agency's primary source of funds to make payments with respect to the 2007 Loan and thc Parity Debt is thc Rcdcvelopment Agcncy's share of ad valorem property tax revenucs which generally result from increases in thc assessed valucs (whether due to annual inflation, thc completion of new rcal estate developments, or general reassessment of property) within thc Project Area. The purposc of redevelopment is to revitalize deteriorated or underdeveloped areas within a community. As new construction progresses, property values normally increase and the ultimate result is a proportionate incrcase in ad valorem property tax rcvenues. The total taxable valuc of all properties within a givcn project area on the property assessmcnt roll last equalized prior to the effcctivc date of the ordinance adopting the redevelopment plan for such project area and related amendment areas, if any, esWblishes a base from which increases in taxable value are computed. Thc basc so established for the Origina! Area is the Fiscal Year 1976-77 assessment roll and for thc Added Territory the Fiscal Year 1982-83 assessment roll. Undcr the Redcvelopment Law, property taxcs lcvied based upon the amount shown on the basc year asscssment rolls will continuc to be paid to and retained by all taxing agencies levying property taxes in the Project Area. Taxes levied by the respectivc taxing agencies on any incrcascs in taxablc value realized in the Projcct Area will be allocatcd to thc Redevelopment Agency. It should be undcrstood that this proccdure does not involve the Icvy of any additional taxes, but provides that revenues produced by thc tax ratcs in effect from year to year are apportioncd to the taxing agencies levying the taxes and to the Redevelopment Agency on the basis described above. After all loans, advanccs and othcr indebtcdncss, including interest, incurrcd by thc Redevelopment Agency in connection with the Project Area have been paid, the tax revenues will be paid to and retained by the respective taxing agencies in the normal manner. Sec also "CERTAIN RISKS TO BONDHOLDERS—Reduction of Tax Revenues." (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) ot,oaz�P�S-z 46 Tablc 6A prescnts thc abgregate taxable value of all property within the Project Area and thc tax incrcmcnt rcvcnucs rcccivcd for Fiscal Years ended June 30, 2002 through June 30, 2006. Table 6A , Palm Desert Redevelopment Agency Project Arca No 1- Original Area Historical Taxablc Valucs and Tax Increment Revenues Assessed Value Local Secured�'� Utiliry (SBE) Unsecured TOTAL ASSF,SSEU VALI;E Base Year Value Incremental Value Percentage Increase Estimated Revenue�''� Tax Increment Revenue Unitary Utility Revenue County Administration Charge TOTAL ESTIMA'I'EU RFVENUG 2001-02 2002-03 2003-04 $564,983,710 $582,303,437 $614,105,002 98.628.475 95.533.915 ] 06,856.251 �663,612,185 $677,837,352 $720,961,253 27,485,R36 27.485.836 27.485,836 $636,126,349 $650,351,516 $693,475,417 - 2.24% 6.63% $6,361,263 $6,503,515 $6,934,754 332,579 288,489 297,098 (]04.8831 (101,7971 (103,877) $6,588,960 $6,690,207 $7,127,975 2004-OS $665,801,195 102,344,827 $768,146,022 27.485.836 $740,661,186 6.80°/u $7,406,602 300,931 (101.6531, $7,605,880 2005-06 $730,954,568 96, I 84,53 I $827,139,099 27,485,836 $799,653,263 7.96% $7,996,533 3 00,93 I (78,987) $8.218,477 Actual Receipts Secured, Unsecured and Unitary Utility $6,646,083 $6,792,005 $7,231,852 $7,707,533 $8,270,799 Suppicmental Payments 104,267 49,849 151,075 200,879 823,767 County Administration Charge (107,137) ( I 01,7971 ( I 03,877) (] 01,6531, (78.9871, T()'I'AL AC'I'�AL RtC'�IPTS $6,643,213 $6,740,057 $7,279,051 $7,806,759 $9,015,579 (1) Valucs include homcowncrs exemption valucs. (2) Assuming a 1.0% tax rate. Sources: Riverside County O�ce oj�he Audilor-Con�ruller und City ojPu(m Deser� Finance Depur�ment. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) 06042�os-� 47 Tablc 6B Palm Desert Redevelopment Agency Project Area No 1— Added Territory Historical Taxable Values and Tax Increment Revenues 2001-U2 2002-03 2003-04 2004-OS 2005-06 Assessed Value Local Secured��� $2,578,872,509 �2,885,218,745 $3,101,000,504 $3,353,983,977 $3,700,665,201 Utility (SBE) — — — — — Unsecured 60,136,657 67,614,013 79.783.947 79,970,509 79.183.032 TUTALASSGSSF:DVALI;E $2.639,009,166 $2,952,832,758 $3,180,784,451 $3,433,954,486 $3,779,848,233 Base Year Value 656.065,059 656,065.059 656.065.059 656,065,059 656.065.059 Incremental Value $1,982,944,107 $2,296,767,699 $2,524,719,392 $2,777,889,427 $3,123,783,174 AnnualIncrease — 15.83% 9.92% ]0.03% 12.45% Estimated Revenue�Z� Tax lncrement Revenue Unitary Utility Revenue County Administration Charge TOTnL ESTIMATFU RLVENUG $19,826.257 $22,967,677 134,804 136,266 (321,5511 (346,155) $19,639,510 $22,757,788 $25,247,194 $27,778,894 144,829 142,166 (�64,6721 (368.2401 $25,027,351 $27,552,820 Actual Receipts Secured, Lnsecured and Unitary Utility $19,961,028 $23,103,974 $25,392,023 $27,921,060 Supplemental Payments 2,011,351 910,786 886,454 1,502,190 County Administration Charge (321.551) (346,155) (364.6721 (368,2401 TOTAL ACTUAL RLCF.IPTS $21,650,828 $23,688,605 $25,913,805 $29,055,010 (1) Values include homeowners cxemption values. (2) Assuming a 1.0% tax ratc. Souroes: Riverside County O�ce oJJhe Audilor-Con�rollcr and Ciry ojPa/m Deserr Finunce Deparlmenl. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) $31,237,832 I 67,752 (298.669) $3 I ,106,915 $31,405,584 5,644,432 (298,669) S36,751,347 oboaz��-z 48 Tablc 7A and Table 7B summarizc the projcctcd Tax Revenues received by the Projcct Arca, thc Original Arca and the Addcd Territory, respectivcly, for the Fiscal Years ending June 30, 2007 through June 30, 2011. To date, the County has paid to thc Redevelopment Agency the full amount of Tax Revcnues expcctcd to be rcccived by thc Redevelopment Agcncy, without regard to delinquencics in tax collcction. S Taxable Values Secured�z� Unsecured�3� New Developmeat�a� Total Value Base Year Value Taxable Value over Base Table 7A Palm Descrt Redevclopment Agency Project Area No 1— Original Arca Projection of Incremental Taxable Valuc and Tax Increment Revenuc Gross Tax Increment Revenue Unitary Tax Revenue Gross Revenues Le.s.r: SQ 2557 Admin. Fee�s� Housing Set-Aside Rec�uirement«� Tax Sharing Payments� � 2006-07 2007-08 2008-09 2009-10 2010-11�'� $775,429,430 $790,938,019 $825,540,691 113,909,971 114,194,746 114,480,233 — 18,415,600 — 889,339,401 923,548,365 940,020,924 27,485,836 27,485,836 27,485,836 861,853,565 89G,062,529 912,535,088 $842,051,505 5859,402,535 114,766,433 1 I S,OS 3,349 500,000 — 957,317,938 974,455,884 27,485,836 27,485,836 929,832,102 946,970,048 8,618,536 8,960,625 9,125,351 300,930 300,930 300.930 8,842,000 9,181,118 9,344,413 (77,466) (80,437) (81,868) 1,768,400 1,836,224 1,868,883 312.590 380,414 413.073 9,298,321 300,930 9,515,881 (83,370) I ,903,176 447,366 9,469,700 300.930 9,685.772 (84,859) 1,937,154 48 I .344 Tax Revenues $6,761,010 $6,964,481 $7,062,458 �7,165,339 $7,267,273 (1) Assessed valucs are based on actual data, all remaining information is projccted. (2) Growth in secured values is projected at 2.00% annually. (3) Growth in unsecured values is projected at 0.25% annually. (4) Represcnts valuc of anticipatcd new dcvelopmcnt based upon building permits issucd by thc City bctween and (5) Rcpresents property tax administrative costs, in the amount equal to 0.869% of the annual gross tax incrcment, that arc paid ro the County pursuant to SB 2557. See "Lint�'rnTloNs oN Tnx REVEnuGs—Property Tax Administrativc Costs." (6) For a discussion of the Housing Set-Aside, see "LIMITA7lONS ON TAX REVEVUES—Housing Set-Aside." (7) Represcnts paymcnts to all taxing entitics payable on a senior basis to payments on the 2007 Series A Bonds and thc Parity 8onds, including statutory paymcnts. See "LlhtrinTioNs or Tnx R�vENues—Pass Through Agreements and Tax Sharing Payments." Sources: Riversrde Coun(ti� O�ce oJ�he Audi�or-Cuntroller and Rosenow Spevucek Group Inc. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) o�uaz��s-z 49 Tablc 7B Palm Desert Redevclopment Agency Project Arca No 1— Added Territory Projection of Incremental Taxable Value and Tax Increment Revenue Taxable Values , Secured�`� Unsecured�31 New Development�'� Total Value Base Year Value Taxable Value over Base Gross Tax Increment Revenue Unitary Tax Revenue Gross Revenues Less: SB 2557 Admin. Fee�`� Housing Sct-Aside Requirement«� Tax Sharing Payments"� 2006-07 2007-08 2008-09 2009-10 $4,187,633,924 54,271,386,602 $4,568,153,681 �4,723,958,932 92,440,023 92,671,123 92,902,801 93,135,058 - 207.195.438 63.178.605 18.895.175 4,280,073,947 4,427,236,330 4,679,951,657 4,839,753,715 656,065,059 656,065,059 656,065,059 656,065,059 3,624,008,888 3,915, ] 88,105 4,068,170,028 4,180,014, I 06 36,240,089 167.752 36,407,84 I (293,492) 7,222,870 17,069.129 39,15 I ,881 167,752 39,319,633 (316,965) 7,800,534 18.561,935 40,681,700 167,752 40, 849,452 (329,297) 8, ] 04,031 19.346,237 41,800,141 167,752 41,967,893 (338,3 I 3) 8,325,916 19.919,635 2010-11�'� $4,837,802,989 93,367,896 22,659,725 18,434,21 I ,087 656,065,059 4,297,765,551 42,977,656 167,752 43,145,407 (347,805) H,559,520 20,523.318 Tax Revenues $11,822,350 $12,640,199 $13,069,887 S 13,384,029 $ l 3,714,763 (1) Asscsscd valucs arc based on actual data, all remaining information is projectcd. (2) Growth in secured valucs is projccted at 2.00% annually. (3) Growth in unsecured valucs is projected at 0.25% annuxlly. (4) Represcnts value of anticipated new developmcnt based upon building permits issued by the City betwccn _ and (5) Rcpresents property tax administrative costs, in the amount equal to 0.101% of the annual gross tax incremcnt, that arc paid to the County pursuant to SB 2557. Sce "LintrrnTioNs oN Tnx REVEnues—Property Tax Administrative Costs." (6) For a discussion of the Housing Sct-Aside, see "LiMITn7��Ons ON Tnx RF.vEVU�s—Housing Sct-Aside." (7) Rcprescnts paymcnts to all taxing entities payable on a scnior basis to payments on the 2007 Scries A BonSs and the Parity Bonds, including statutory paymcnts. See "LiMrrnnoNs oN Tnx RFVENues—Pass Through Agreements and Tax Sharing Paymcnts." Sourees: Rh�ero•ide Countv O�ce ojthe Audllor-Conlrol/er uncl Rosenuw Spevacek Group Ine. Debt Service Coverage Projections The following Tablc 8 shows schedulcd debt service on the 2007 Series A Bonds and Pariry Bonds, without regard to any optional rcdemption and estimated coverage. Sec "DEBT SGRVICG SCHEDULE" for the schcduled semiannual debt service on the 2007 Scrics A Bonds. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) 06412�pos-2 50 � � � v > O V .Vr � •� u � C v V � � � � � u '� � O � a Z Ce � � i � � � d � � � v � � � � .� � y a` � U � L � u C� �I 0. ye � E"' � V �O � a � � � =� � .� � E �n o w � A � Q �I E"' � C� O r W 8 Q N v. 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'� �j t,Q� � � U N yj C N �i iC w C �p '-+ Z ' o u r�,- o � � � � o � � ��u¢ 'oL� a � ` �U ` � � C � OC r ;L G p 8 � � v � � F N � Y � p C r _ 5 � o � 8 f� � °' ` � � � o ��Lj Q 'S � mC � `j c � Y O � C'C G lZi'. � y OO z°��� �� v > .. �Q<� �E� o �� �i- � � ° 5 p �p > � c � � Z m � � 3 ��� � � ��� j� � rj Fa- �� O G � " ` u `�y� � � � .. u y �'' C � y ' C � 7 �O. '� = c, ;7S �t �a 2 � 3 $�;���E�� U � � ; Z � ,,7� ` � geCeu°�:��� _. .. _ • � ot�oaz�s-z 51 Assessment Appcals Property tax values dctcrmined by the County Asscssor may be subject to an appeal by the property owners. Assessmcnt appcals are annually filed with the Assessment Appeals Board for a hearinb and resolution. The resolution of an appeal may result in a reduction to the County Assessor's original taxable value and a tax rcfund to the applicant/property owncr. The reduction in futurc Projcct Area taxable values and thc refund of taxes affects all taxing entities, including the Redevelopment Agency. Each assessment appeal could result in a reduction of the taxable value of the real property, personal properiy or possessory interest of the property which is the subject of the appeal. A reduction in such taxable value would result in a reduction of the rcvenues of the Rcdevelopment Agency available for Tax Rcvcnucs with respect to the 2007 Series A Bonds. Altematively, an appeal may bc withdrawn by thc applicant or the Appcals Board may deny or modify the appcal at a hearing or by stipulation. Of the 10 principal taxpaycrs in the Project Area shown in Table 3, two Sears Roebuck & Co. ("Sears") and El Pasco Collection ("El Pasco") havc appeals outstanding and unresolved with thc County Asscssor as of September 1, 2006. Sears owns one parcel in thc Original Area and is seeking a reduction to thc Piscal Year 2005-06 assessed value in the amount of 58,579,199 which, if granted, would result in a 0.17% rcduction in thc aggregate Fiscal Year 2005-06 assessed value within thc Project Arca. EL Pasco owns one parcel in thc Original Area and is seeking a rcduction to the Fiscal Ycar 2005-06 assessed value in the amount of S885,241 which, if granted, wou(d result in a 0.02% reduction in the a�;gregatc Fiscal Year 2005-06 assessed valuc within the Project Area. Origina! Area. Between Fiscal Year 2002-03 through Septcmber 1, 2006 there have bcen 143 asscssmcnt appeals filcd within the Original Area. Of thc appcals filed, 13 resulted in reductions in valuc (S 10,054,459 or 1.48%), 121 were withdrawn and nine are pending. The pcnding appcals have a combincd assesscd valuc of S21,633,292 under appeal and include assessment appeals of valuc for Fiscal Ycars 2005-06 and 2006-07. Added Territory. Betwccn Fiscal Ycar 2002-03 through Septcmber 1, 2006 there have been 161 assessment appeals filed within the Addcd Territory. Of thc appeals filcd, 14 resulted in reductions in value ($6,739,118 or 0.22%), 125 werc withdrawn and 22 are pending. The pending appeals have a combined assessed value in the amount of $40,669,441 and include appeals of value for Fiscal years 2003-04 throubh 2005-06. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) o�oaz�s-z 52 Tablc 9 summarizes the appeals filed in the Project Area between Fiscal Year 2001-02 and Scptember l, 2006. Table 9A Palm Desert Redevelopment Agency Project Arca No 1— Original Area Assessment Appeals Fiscal Years 2000-01 through September 1, 2006 Roll Ycar 2006-07 2005-06 2004-OS 2003-04 2002-03 ToTni, Total # of Appcals Fifcd i 1R 43 31 50 143 Appeals VVithdrawn/ No Appcarance/ Latc File 0 10 43 30 38 121 Appeals Adjusted/ Reduced/ Stiuulated 0 0 0 I 12 13 Appeals Pendine i 8 0 0 0 9 Total Secured Assessed Valuc $776, I 89,725 azs,�6�,xx2 768,146,022 720,961,253 677.837.352 $3,768,902,234 Total Requested Reduction $86,700 34,747,611 67,858,453 74,452,334 86, I 23,1 14 S263,268,212 Actual ReducHon in Assessed Value $0 0 0 I 6,569 10,037.890 S 10,054,459 Sources: Rrverside County O�ce ojlhe Audilor-Catlruller und Rosenow Spevucek Group Inc. Table 9B Palm Desert Redevclopment Agency Project Area No 1— Added Territory Assessment Appeals Fisca{ Years 2000-01 through September 1, 2006 Roll Ycar 200Cr07 2005-OG 2004-OS 2003-04 2002-03 ToTn i, Total # of Appcals Filed 0 17 45 42 57 161 Appeals Withdrawn/ No Appearancc/ Late File 0 $ 32 39 46 125 Appeals Ad j usted/ Reduced/ Stiaulated 0 0 t 2 Il 14 Appesls Pendine 0 9 12 1 0 22 Total Secured Asscssed Value $4,258,751,34A 5.772,744,132 3,433,954,486 3, I 80,784,45 I 2.952.832.758 S 19,559,067,175 Total Requested Reduction SO 19,763,829 30,161,112 36,624,510 48,633.054 S l 35,182,505 Actual ReducNon in Assessed Value $0 0 597,381 251,997 5,889.740 $6,739, I 18 Sources: Riversrde Count}• O�ce ojthe Audr�or-Comro!!er und Rosenow Spevucek Group /nc. Actual Reduction % of total Assessed Value 0.00% �.ax 1.48°/a Actual Reducdon % of total Asscssed Value 0.00% 0.00 0.02 0.01 0.20 0.22% (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) o�cwz�s-z 53 Pendin� Reduction in Assessed Valuc sx�,�oo 20,674,907 0 871,685 0 $21,633,292 Pending ReducHon in Assessed Value SO 16,988,318 14,417,734 9,263,389 0 $40,669,44 I Pending ReducNon % of Total Assessed Value o.o i 2.50 0.00 0.12 o.00 2.64% Pending Reduction % of Total Asscssed Value 0.00% 0.29 0.42 0.29 0_00 I.OI% Tablc 10 lists thc principal taxpayers (scc Table 4 above) who have filed such appcals, thc assessed value, the reduction requestcd and the status of the appeal. Table 10 Palm Desert Redevelopment Agency Project Arca No l- Combined Outstanding Appeals by the Top Ten Taxpayers Fiscal Years 2000-01 through 2005-06 Total Sccured Applicant Appeal No. Assessed Opinion Applicant Year Parcels Value Value Scars Rocbuck & Co. 2005-06 1 S 17,169,199 $8,590,000 El Paseo Collection 2005-06 2 7,185,241 6,300,000 TOTAL 3 S24,354,440 �14,890,000 Sources: Riverside Counry O�ce ojthe Audr�or-Con�roller und Rosenow Spevucek Group Inc. 7'ax Levies, Collections and Delinquencics Potential Reduction Amount �8,579,199 885,241 $9,464,440 The County dc�es not track secured tax charges and delinquencies by Project Area. Thc County has adopted thc Altemative Method of Distribution of Tax Levies and Collections and of Tax Sale Procccds (the "Teeter Plan"), as provided for in Scction 4701 et. seq. of the State Rcvcnue and Taxation Code. Under the Teeter Plan, each participating local agency, including cities, levying propeny taxes in its counry may receive the amount of uncollected taxes credited to its fund in the same manner as if the amount credited had been collected. In return, the county would receive and retain dclinquent payments, pcnalties and interest, as collected, that would have been due to the local agcncy. However, although a local agency could receive the total levy for its property taxes without regard to actual collections, funded from a reservc established and held by the counry for this purposc, the basic legal liabiliry for property tax dcficiencies at all times remains with the local agency. The Teeter Plan cemains in effect unless the County Board of Supervisors orders its discontinuance or unless, prior to the commencement of any fiscal year of the County (which commences on July 1), thc County Board of Supervisors receives a petition for its discontinuance joined in by resolutions adopted by two-thirds of the participating revenue districts in the Counry, in which event, the Counry Board of Supervisors is to order discontinuancc of the Teeter Plan effective at the commencement of thc subscquent fiscal ycar. The County Board of Supervisors may, by resolution adopted not later than July 15 of the Fiscal Ycar for which it is to apply, aftcr holding a public hearing on the matter, discontinue the proccdures under thc Tectcr Plan with respcct to any tax lcvying agency in the county. The Rcdevelopment Agency is a participant in the Teeter Plan. See "LIMITATIONS ON TAX REvclvUEs—Property Tax Collection Procedures." oFoaz��,s_z 54 TAX MATTERS [TO BE REVISED BY BOND COUNSEL] ln thc opinion of Richards, Watson & Gershon, A Professional Corporation, Bond Counsel, under cxisting law, interest on the 2007 Series A Bonds is excluded from gross income for fedcral incomc tax purposcs undcr Section 103 of the Internal Revcnue Code of 1986, as amended (thc "Code"), and is not an itcm of tax preference for purposes of the federal alternativc minimum tax imposed on individuals and corporations. In addition, Bond Counsel is of the opinion that, under existing law, the excess of Accretcd Value of the Capital Appreciation Bonds over thc original Principal Amount thereof, to the extent that such cxcess represents interest properly allocated to the Owner of such Capital Appreciation Bonds (the "Excess Accreted Value"), is cxcluded from gross incomc for federal income tax purposes under the Code, and is not an itcm of tax preference for purposes of the federal altemative minimum tax imposed on individuals and corporations. Bond Counsel will express no opinion as to any other federal tax consequcnces regarding the 2007 Scries A Bonds. The opinion on federal tax mattcrs will be based on and will assume the accuracy of certain representations and ccrtifications, and continuing compliance with certain covenants, of the Agency and the Authority that are intendcd to assure the foregoing, including that the 2007 Series A Bonds are and will remain obligations, the interest on which is excluded from gross income for federal income tax purposes. Bond Counsel will not indcpcndently verify the accuracy of those rcpresentations and certifications. The Code prescribes a number of qualifications and conditions for the interest on state and local govemment obligations to be and to remain excluded from gross income for federal income tax purposes. Some of these qualifications and conditions require future or continued compliance after issuance of the obligations for the interest to be and to continue to bc excluded from the date of issuancc. Noncompliance with these qualifications and conditions by the Authority or the Agency may cause the interest on the 2007 Serics A Bonds to be included in gross income for federal income tax purposcs retroactively to the date of issuance of the 2007 Serics A Bonds. The Authority and the Agency have covenanted to take the actions requircd of thcm for thc interest on the 2007 Series A Bonds to be and to remain excluded from gross income for fedcral income tax pwposes, and not to take any actions that would adversely affect that exclusion. Undcr the Code, a portion of the interest on thc 2007 Scries A Bonds earned by certain cotporations ►nay be subject to a corporate altemative minimum tax. In addition, intcrest on the 2007 Series A Bonds may bc subjcct to a branch profits tax imposed on certain foreign corporations doing business in the Unitcd States and to a tax imposed on excess net passive income of certain S corporations. Under thc Code, the cxclusion of interest from gross income for federal income tax pucposcs may have certain adverse federal income tax consequences on items of income, deduction or credit for certain taxpayers, including financial institutions, certain insurance companies, recipients of Social Security and Railroad Retirement bcnefits, those that are deemed to incur or continue indebtedness to acquire or can-y tax- exempt obligations, and individuals otherwisc eligible for the eamed incomc tax credit. The applicabiliry and cxtent of thesc and othcr tax consequences will depend upon the particular tax status or other tax items of thc owners of the 2007 Series A Bonds. Bond Counsel will express no opinion regarding those conscquences. Any excess of the stated redemption price at maturiry of the 2007 Series A Bonds over the initial offcring price to the public of thc 2007 Scries A Bonds set forth on the inside cover of this Official Statement is "original issuc discount" Such original issuc discount accruing on a 2007 Series A Bond is treatcd as intcrest cxcluded from the �-oss incomc of the owner thereof for fedcral income tax purposes and excmpt from California personal income tax. Original issue discount on any 2007 Series A Bond purchased at such initial offering price and pursuant to such initial offering will accrue on a semiannual basis over the term of the 2007 Series A Bond on the basis of a constant yield method and, within cach semiannual period, will accrue on a ratable daily basis. The amount of original issue discount on such a 2007 Series A Bond accruing 06042�os-2 55 during each period is added to the adjusted basis of such 2007 Series A Bond to determine taxable gain upon disposition (including sale, redemption or payment on maturity) of such 2007 Series A Bond. The Code includes ccrtain provisions relating to the accrual of original issue discount in the case of purchasers of thc 2007 Series A Bonds who purchase the 2007 Series A Bonds other than at the initial offering price and pursuant to the initial offering. Any person considering purchasing a 2007 Series A Bond should consult his or her own tax advisors with respect to the tax consequences of ownership of bonds with original issuc discount, including the treatment 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 treatmcnt of� accrued original issue discount on such bonds under federal individual and corporate alterative minimum taxes. If the 2007 Serics A Bonds were offered and sold to the public at a pricc in cxccss of thcir statcd redemption price (the principal amount) at maturiry, that excess constitutes "premium." For iederal incomc tax purposcs, that premium is amortized over the period to maturiry of the 2007 Series A Bonds, bascd on thc yield to maturity of the 2007 Series A Bonds, compounded semiannually. No portion of that premium is dcductible by thc owncr of a 2007 Scries A Bond. For purposes of detcrmining the owner's gain or loss on thc salc, redcmption (including redemption at maturity) or other disposition of a 2007 Serics A Bond, thc owner's tax basis in the 2007 Series A Bond is rcduced by the amount of premium that accrues during the period of owncrship. As a result, an owner may realizc taxablc gain for fedcral income tax purposes from thc salc or other disposition of a 2007 Series A Bond for an amount equal to or less than the amount paid by the owncr for that 2007 Series A Bond. A purchascr of a 2007 Series A Bond in the initial public oi%ring at the price for that 2007 Series A Bond stated on the inside cover of this Official Statement who holds that 2007 Scries A Bond to manu-ity will realizc no gain or loss upon the retiremcnt of that 2007 Scries A Bond. Owners of the 2007 Serics A Bonds should consult thcir own tax advisers as to thc detcrmination for federal income tax purposes of the amount of premium properly accruable in any period with respect to the 2007 Scries A Bonds and as to other federal tax consequenccs and the treatmcnt of premium for purposes of statc and local taxes on, or based on, incomc. Purchasers of the 2007 Series A Bonds at other than their original issuance at ihe respective prices indicated on the inside cover of this Official Statement should consult their own tax advisers regarding other tax considerations such as the consequences of market discount or premium. In the further opinion of Bond Counsel, interest on the 2007 Series A Bonds is exempt from personal income taxation imposed by the State of California. A copy of the proposed form of Bond Counsel's final approving opinions with respect to the 2007 Series A Bonds is attached hereto as APPENDIx E. APPROVAL OF LEGAL PROCEEDINGS Ceitain legal matters incident to the authorization, issuance and sale of the 2007 Series A Bonds are subject to the approval of Richards, Watson & Gershon, A Professional Corporation Los Angelcs, California, Bond Counscl. A copy of the proposcd form of Bond Counscl's opinion is containcd in APPGNDIX E to this Official Statement, and thc final opinion will be made available to the owners of the 2007 Serics A Bonds at thc time of delivery of the 2007 Serics A Bonds. Certain legal matters will be passed upon for thc Financing Authority and the Redevclopmcnt Agency by thcir General Counscl, Richards, Watson & Gershon, A Prof'essional Corporation, and by Lofton & Jennings, San Francisco, California, Disclosure Counsel. Bond Counsel will also deliver a supplemental opinion as to the accuracy in all enaterial respects of the descriptions contained in this Of�icial Statement of the Bonds, and Bond Counsel's federal and State tax opinions. Except as expressly described in said opinion, Bond Counscl is not passing upon and undcrtakes o�oaz��5-z 56 no responsibiliry for the accuracy, complctcncss or fairncss of the information containcd in this Official Statcmcnt. Bond Counsel and Disclosure Counscl will each rcceive compensation from thc Redcvc[opmcnt Agcncy that is contingent upon the sale and delivery of thc 2007 Scries A Bonds. ABSENCE OF MATERIAL LITIGATION Ccncral Therc is no litigation pending, noticc of which has bccn servcd, or known to the Financing Authority or the Rcdevelopment Agency conceming the validity of the 2007 Indenturc or thc 2007 Serics A Bonds or the issuance and dc�ivery thcreof, the existence of thc Financing Authority or the Redevclopment Agency, the title of the offcers thereof who shall execute the 2007 Series A Bonds to their respective offices, the pledge of Revenues to the payment of the 2007 Series A Bonds, or the pledge of Tax Rcvenues to the paymcnt of the 2007 Loan. Other Matters ln the rcgular course of the business, thc Financing Authority and the Redevelopment Agcncy arc cach partics to a variety of pending and threatencd lawsuits and administrative proceedings, in addition to those specifically discussed herein. Neither the Financing Authoriry nor the Redevelopment Agency bclicves that any such lawsuits or proceedings will have a material adverse effect on the operations or financial condition of the Financing Authority and the Redevelopment Agency, respectively. FINANCIAL ADVISOR Del Rio Advisors, LLC, Modesto, Califomia, has served as Financial Advisor to the Financing Authority and the Redevelopment Agency with respect to the sale of the 2007 Scries A Bonds. The Financial Advisor has assisted the Financing Authority and the Redevelopment Agency in the review of this Official Statcment and in othcr matters relating to the planning, structuring, execution and delivery of the 2007 Scries A Bonds. The Financial Advisor has not independently verified any of the data contained herein or conductcd a detailcd invcstigation of the affairs of the Financing Authority and the Redcvelopment Agency to detcrmine the accuracy or completcness of this Official Statement. Due to their limited participation, the Financial Advisor assumes no responsibility for the accuracy or completeness of any of the information contained herein. The Financial Advisor will receive compensation from the Redevelopment Agency contingent upon the salc and dclivery of the 2007 Series A Bonds. CONTINUin'G DISCLOSURE The Redevelopment Agency has covenanted in the Continuin�; Disclosure Agreement dated , 2006, by and among the Redevelopment Agency, thc Trustee, and MuniFinancial Inc., as Dissemination Agent for the benefit of the holders and bencficial owners of thc 2007 Series A Bonds to provide certain financial information and operating data relating to the Redevclopment Agency each ycar by not latcr than the date which is six months following the end of the Fiscal Year, commencing with the report for the 2006-07 Fiscal Year (the "Annual Report"), and to provide notices of the occurrence of certain cnucncrated evcnts, if material. The Annual Report and notices of material evenu will be filed by thc Trustcc obcriz�,-z 57 as Dissemination Agent with each nationally Recognizcd Municipal Securities Information Repository and with any thcn existing State Repository, if any. Currently, there is no State Rcpository. The covenants sct forth in the Continuing Disclosure Agreement havc been made by the Redevelopment Agency in order to assist the Underwriters in complying with Securities and Exchange Commission Rulc I Sc2-12(b)(5). The specific naturc of thc inforenation to be containcd in thc Annual Rcport and the notices of material events is sct forth in APPet�rDlx F—"FORM OF CONTINUING DISCLOSURE AGREEMGNT." The Redevclopmcnt Agcncy has never failed to comply in all matcrial respects with any prcvious undertakin�;s with regard to said Rule to provide annual rcports or notices of material events. VERIFICATION OF MATHEMATICAL COMPUTATIONS Upon delivcry of the 2007 Scries A Bonds, Grant Thornton LLP, Minneapolis, Minnesota (thc "Verification Agent"), will deliver a report stating that it has reviewed and confirmed the mathematical accuracy of certain computations relating to the adequacy of the funds and/or securities deposited in the Escrow Securities and the interest thereon, if any, to pay, when due, the redemption price and interest on the Prior Bonds on the specified payment or redemption date thereof. UNDERWRITING Pursuant to the terms of a Bond Purchase Agreement dated . 2006 (the "Purchase Agreement"), among the Financing Authority, the Redevelopment Agency and Stone & Youngberg LLC (the "Undcrwriter"), thc Underwritcr will purchase all of thc 2007 Series A Bonds, if any are purchascd, howevcr, the obligation of the Underwriter to make such purchase is subject to certain terms and conditions set forth in the Purchase Agreement. The Underwriter purchased the 2007 Series A Bonds, at a price of S (representing the principal amount of the 2007 Series A Bonds, plus an original issue premium in the amount of $ and less an Underwriter's discount in the amount of $ ). The public offering prices of the 2007 Series A Bonds may be changed from time to time by the Underwritcr. The Underwriter may of%r and se112007 Series A Bonds to certain dealers and others at a price lower than the offering price stated on the inside cover page hereof. RATINGS Moody's Investors Scrvice ("Moody's") and Standard & Poor's Ratings Services, a division of the McGraw Hill Companies ("S&P") have assigned their ratings of "Aaa" and "AAA," respectively, to the 2007 Serics A Bonds with the understanding that upon delivery of the 2007 Series A Bonds the Insurance Policy will bc issucd by the Bond Insurer. See "FINANCIAL GUARANTY INSURANCE" and APPENDiX H-"SPECIMEN F[NANCIAL GUARANTY INSURANCG POLICY." A rating reflects only the view of the agency giving such rating and is not a recommendation to buy, sell or hold the 2007 Series A Bonds. An explanation of the significancc of the rating may be obtained from Moody's at Moody's ]nvestors Scrvicc, 99 Church Strcet, Ncw York, New York ] 0007 and from S&P at Standard & Poor's, 55 Water Street, Ncw York, New York 10041. There is no assurance that such ratings will continue for any given period of time or that they will not bc reduced or withdrawn cntirely by S&P or Fitch, if in their individual judgment circumstances so warrant. T'he Redevelopment Agency has not undertaken any responsibility to oppose any such proposed revision or withdrawal. Any such revision or withdrawal of a rating may havc an adverse ef%ci on the marketabiliry or markct price of the 2007 Series A Bonds. o�,�z��o�-z 58 FINANCIAL STATEMENTS The audited financial statements of the Redcvelopment Agency for Fiscal Year [2004-OS], prcpared by Lance, Soll and Lunghard LLP, independent certified public accountants, in accordancc with Governmental Accounting Standards Board guidelines, are included as APPGNDIX B attached here[o. Lance, Soll and Lunghard LLP has consented to the inclusion of its report in APP[NDIX B, and has not undcrtaken to update its report or take any action intended or likely to elicit information conccrning thc accuracy, completeness or fairness of statements made in this Official Statement and no opinion is cxpresscd by Lance, Soll and Lunghard LLP with respcct to any evcnt subsequent to the date of its report. MISCELLANEOUS All of the preceding summaries of the 2007 Scrics A Bonds, thc 2007 Tndenture, the 2007 Loan Agreement, the Rcdevelopment Law, thc Redevclopment Plan, the Project Area, other applicablc legislation, agrccments and other documents are made subjcct to the provisions of the 2007 Series A Bonds and such documents, respectively, and do not purport to be complete statements of any or all of such provisions. Refercnce is hereby made to such documents on file with the Rcdcvelopment Agency for further information in connection therewith. Any statements madc in this Official Statement involving matters of opinion or of cstimates, whethcr or not expressly stated, are set forth as such and not as representations of fact, and no representation is made that any of thc cstimatcs will bc realizcd. The execution and delivery of this Official Statement by the Chief Administrative Officer of the Financing Authority has been duly authorized by the Financing Authority. PALM DESERT FINANCING AUTHORITY I' , Carlos L. Ortega, Chief Administrative Officer Ohp42�Os-2 59 APPENDIX A REPORT OF THE FISCAL CONSULTANT OG042��s-2 A-1 APPENDiX B REDEVELOPMENT AGENCY AUDITED FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED JUNE 30, 2005 06(M2�pos-2 B-1 APPENDIX C GENERAL INFORMATION COn`CERNING THE CITY OF PALM DESERT The follox�ing in.fvrmution concerning the City of Palm Desert, the County oj Riverside and surrounding ureas is included onlv for the purpose of supplying general information regarcling the cnmmunity. Ovcrvicw The City of Palm Desert (the "City"), incorporated in November 26, 1973 as a general law city, bccamc a chartcr city through the adoption of Ordinance 858 by the City Council on January 8, 1998. The City is located in the Coachella Valley and is approximately mid-way between the cities of Indio and Palm Springs, 117 miles cast of Los Angelcs, 118 miles northcast of San Diego and 515 miles southcast of San Francisco. Thc City occupies an area of approximately 26 square miles. Elevation of the City is 243 feet and thc mcan tcmperaturc is 73.1 dcgrecs. Exccpt in summcr, the weather is mild and annual avcragc rainfall is 3.38 inches. According to the State Department of Finance, the City population as of January 1, 2006 was approximatcly 49,539, an incrcase of approximately 19.5% sincc 2000, attributable in part to territorial anncxation. Government Thc Ciry Council is comprised of five mcmbers, elected at large for four-year staggcred tcrms evcry two years. The general municipal election is conducted in November of even-numbered years, consolidated with the Statewide General Election and councilmembers are sworn in and take office at the first meeting in Dccembcr following each election. There is currcntly one vacancy on the City Council. The City Council selccts one of its members to serve as Mayor for a one-year term and appoints a City ;vlanager to conduct the day to day business of the Ciry and the City Clerk. The City Attomcy is appointed by City Council. The Ciry operates as"Contract City" utilizing, primarily, agreements with other govern►nental entities, private companies and individuals to provide services. Contracted services include police and fire protection provided through the Counry, animal control, health services, legal scrvices and landscape maintcnancc. The City Council also serves as the governing board of thc Financing Authority, thc Redevelopmcnt Agency, the Housing Authority and the Parking Authority and the City Manger servcs as the Chief Administrative Officer of the Financing Authoriry and the Executive Director of the Redevelopment Agency, the Housing Authority and the Parking Authority. The Ciry Attorney and the City Clerk also servc as the General Counsel and Secretary, respectively, of the Redevelopment Agency and these Authorities. The current members of the City Council and key administrativc personnel of the City arc listed in Table C-1 and Table C-2, respectively: oboaz�,�-z C-1 TABLE C-1 CITY OF PALM DESERT City Council Members Name Office Jim Ferguson Mayor Richard S. Kclly Mayor Pro Tcm Jean M. Benson Councilmembcr Robcrt A. Spiegcl Councilmember Vacant Councilmember � �2) Term Exoires Novembcr 2006��� November 2008 November 2006��� Novcmber 2008 November 2008�'� Occuvation Attomcy Rctired GTE Executive Retircd Travel Industry Profcssional Rctired Retail Industry Executive Thc tertns for thesc membcrs of the �inancing Authonty anJ City Council expire in November 20(16. 'I he persons clectcd xt thc Novcmber 2006 Statew•ide Venerai C•lechon will be swom in and take office necember 14, 2006. This vacxncy will be filled at the November 2006 Statewide Cieneral Election. The person eiected to fill this position w�ll be swom m and wke ofTice on [�ccmbcr 14, 2W6. TABLE C-2 CITY OF PALM DESERT Kcy Administrative Personnel Namc Carlos L. Ortega Justin McCarthy Paul S. Gibson David L. Yrigoyen Rachclle D. Klasscn Population Position Ciry Managcr Assistant City Managcr Treasurer/Finance Director Dircctor of Rcdevelopmcnt and Housing City Clcrk Between 2000 and 2006, the City's population increased by a total of 8,089 or approximatcly 19.5%. In addition to permancnt residents, the Ciry has approximately 15, 000 seasonal residential residents who live three to six months in thc City, primarily during the winter months. Table C-3 illustratcs the population of the City, the County and the State for 2000 and 2002 through 2006. Table C-3 C1TY OF PALM DESERT AND RIVERSIDE COUNTY AND STATE OF CALIFORNIA POPULATION Ycar (January 1) 2000 2002 2003 2004 2005 2006 Citv of Palm Dcsert 41,450 42,900 44,300 45,610 49,595 49,539 Riversidc Countv 1,557,800 1,645,300 1,719,000 1,807,858 1,888,311 1,953,330 State of California 34,207,000 35,037,000 35,591,000 36,271,091 36,728,196 37,172,015 Sources: Unrted Sla�e.r Deparlmenl of Conrmerce, Bureau of lhe Cen.sus jor 2000 and Stu�e oJCulijornia Depar�men� ojFinunce jor remarning}•eurs. 06042�pos-2 C-2 Labor Forcc and Employment The main sources of revenue in the Ciry are derived from tourism and sales tax. Historically, thc unemploymcnt rate in the City has been lower than that for thc County and the State. Table C-4 table represents the labor pattems in the City, the Counry, the State, and the United States from 2001 through 2005. Table C-4 CITY OF PALM DESERT, RIVERSIDE COUNTY, STATE OF CALIFORNIA AND UNITED STATES CIVILIAN LABOR FORCE, EMPLOYMENT, A1�D UNEMPLOYMENT 2001 through 2005 Year and Area 2U01 City County State United Statcs 2002 Ciry Counry State Unitcd Statcs 2003 City Counry Statc United States 2004 City Counry State United States Labor Forcc Emt�lovment Unemnlovment 20,000 711,200 17,150,100 141,815,000 19,400 672,500 16,217,500 135,073,000 600 38,700 932,600 6,742,000 21,100 749,800 17,326,900 144,863,000 21,900 781,600 17,414,000 146,510,000 22,800 812,000 17,552,300 147,401,000 20,300 702,300 16,165,100 136,485,000 21,100 732,300 16,223,500 137,736,000 22,100 764,900 16,459,900 139,252,000 800 47,500 1,161,800 8,378,000 Unemploymcnt Ratc 3.1% 5.4 5.4 4.8 3.6 6.3 6.7 5.8 800 3.6 49,300 6.3 1,190,500 6.8 8,774,000 6.0 700 47,100 1,092,400 8,149,000 3.3 5.8 6.2 5.5 2005 City 24,000 23,300 700 2.8 Counry 849,640 806,700 42,900 5.1 State 17,695,600 16,746,900 948,700 5.4 Unitcd States 149,321,000 141,730,000 7,591,000 5.1 Sources: CulJorniu Sta�e F,mpiny�ment Developnrenf Deparlment und U S. Depar�ment ojLahor, Bureau nf Lahor Stutrstic.�. 06042�pus-2 C-3 Table C-5 dcscribes the largest cmployers in the City. Tablc C-5 CITY OF PALM DESERT' LARGEST EMPLOYERS (As of January 1, 2006) Companv Product/Scrvice Numbcr of Emnlovees JW Marriott Desert Springs Resort Sccuritas Security Svc USA Inc. Collcge of the Dcscrt Marriott's Desen Spas Villas Sunshinc Landscapc Desert Vallcy Industries Mamott Owncrship Rcsorts Inc. Sunrise Colony Co. Foundation For the Retarded Time Warner Cable Bighorn Golf Club Springs At the Fountains Macy's Wcst Monterey Palms Health Care Fountains At the Carlotta Indian Ridge Country Club Williams Mcchanical Inc. Palm Valley Country Club Koala Tce Printing Hospitality Security Scrviccs Education Hospitality Landscaping Services Business Support Services Hospitality Golf Course Community Social Services Telecommunications Golf Rcsort Convalescent and Nursing Care Retail Hcalthcare Convalescent and Nursing Care Golf Course Community Plumbing Golf Coursc Community Screcn Printing j' Fedcral and State Govemmcnt not included. Source: America's Labor Markcl Infortnation System (ALMIS). Commercial Activity 1,300 700 630 500 500 400 300 250 236 220 220 200 200 200 200 200 200 200 200 A sales tax is imposed on retail sale or consumption of personal property. Sales tax revenucs are detem►incd by the total taxablc transactions within a jurisdiction and distributed by the State Board of Equalization to the jurisdiction where the sale took place. Sales taxes collected from merchants with no permanent place of business (i.e., manufacturers, construction contractors, etc.) are accumulated to a Countywide or State-wide (out-of-state businesses) pool and distributed to cities and counties in proportion to their collections from all sales taxpaycrs. The value and volume of these taxable transactions are dcpendent on economic conditions and other factors. Such factors included the level of inflation affecting the price of goods and services subject to thc sales tax, the rate of population growth in the general area, the characteristics of retail developments, such as thc relative sizc of ►narket scrvice areas, the scnsitivity of the types of businesses within the City to changes in the economy, and competing retail establishments outside 1he City. A deterioration of economic conditions and other factors influencing taxable sales gcneratcd in the City, may reduce the City's sales tax rcvenues. Table C-6 summarizes taxable transactions in thc City for calendar years 2000 through 2004. obwz�Pos-z C-4 TABLE C-6 CITY OF PALM DESERT Taxable Retail Sales Data Calendar Ycars 2000 to 2004 ($ in 000's) 2000 2001 RCTAIL STORES Apparel Stores �92,192 593,792 Gencral Merchandisc 269,776 272,856 Food Stores 55,817 52,282 Eating & Drinking Placcs 153,970 155,911 Homc Furnishings and Appliances 128,899 125,130 Building Matcrials and Farm 57,865 64,251 Impiements Auto Dealers and Auto Supplies 8,108 8,825 Scrvice Stations 25,807 22,633 Other Rctail Stores 227,591 220.252 TOTAL RETAIL STORES 1,020,025 1,015,932 All Othcr Outicts 197,961 195,137 2002 2003 S97,924 $108,829 278,583 307,186 51,738 52,461 148,228 152,508 129,623 135,694 54,111 56,180 6,904 8,211 23,930 39,146 228,286 243,474 1,019,327 1,103,689 190,058 193,041 2004' $132,831 340,277 47,455 167,315 155,921 68,737 5,862 45,585 264,129 1,228,112 205.1 �4 TOTALALLOUTLGTS 51,217,986 �1,211,069 $1,209,385 S1,296,730 S1,433,296 � Most recent annual data available. Source: Stule Board o%Equulizu[ion. Construction Activity In Fiscal Year 2005-06, the City issued construction permits valued in excess of $269 million. This total amount, approximately 41% consisted of new single family construction and approximatcly 1.6% consisted of new multifamily construction. A five-year history of building permits and valuation appcars in Table C-7. Tablc C-7 CITY OF PALM DESERT BUILDING PERMITS AND VALUATIONS 2001-2005 Residential Numbcr of Units Ycar Sin�lc Familv Multifamilv 2001 255 411 2002 221 310 2003 237 101 2004 325 111 2005 100 135 Valuation ($ in 000's)t $120,073.2 100,486.0 86,387.6 103,738.2 78,130.9 t includcs valuc of individual units, altcrations and additions. Source: Consrruction Industry Research Board, Building Permi( Survey. Nonresidential Valuation ($ in 000's)f 536,319.0 41,413.7 20,123.0 43,112.1 92,535.4 Total � 156,392.0 141,899.7 106,510.6 146,850.3 170,663.3 06042\pus-2 G5 Effcctive Buying Incomc "Effcctive buying income" ("EBl") is a classification developed exclusivcly by Sales 8c Marketing Manugement magazine to distinguish it from other sources reporting income statistics. EBI is defined as "money income" less personal tax and nontax payments - a number oftcn referred to as"disposable" or "after-tax" income. Money income is the aggegate of wages and salaries, net facm and nonfarm self- employment income, interest, dividends, net rental and royalty income, Social Security and railroad retirement income, other rctirement and disabiliry income, public assistance income, unemployment compcnsation, Veterans Administration payments, alimony and child support, military family allotments, net winnings from gambling and other periodic income. Money income does not include money rcceived from thc sale of property (unless the recipient is engaged in the business of selling property); the value of "in-kind" income such as food stamps, public housing subsidies, medical care, employer contributions for persons, ctc.; withdrawal of bank deposits; money borrowed; tax refunds; exchange of money between relatives living in the samc houschold; gifts and lump-sum inheritances, insurance payments, and other rypes of lump-sum receipts. EBl is computed by deducting from money income al] personal income taxes (federal, statc and local), personal contributions to social insurance (Social Security and federal retirement payroll deductions), and taxes on owner-occupied nonbusiness real estate. The total EBI for thc Ciry, as reportcd by Sales & Marketing Managcment in its 2005 Survey nJ' Buying Power, was $1,295,785 and the median household EBI was S42,769. The 2005 Ciry mcdian houschold EBI of S42,769 compares that of S33,357 for the City of Palm Springs; $39,287 for thc Ciry of Ontario; S51,803 for thc Ciry of Corona; $53,205 for thc City of Temecula; and S39,414 for the City of Los Angcics. (REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK) o�oa2��„-z C-6 Table C-8 prescnts the latest available total effectivc buying income and median household effcctivc buying incomc for the City, the County, the State and the nation. Tablc C-8 CITY OF PALM DESERT, RIVERSIDE COUNTY, STATE OF CALIFORNIA AND UNITED STATES EFFECTIVE BUYING INCOME Year and Area 2000 City Counry Statc Unitcd States 2001 City County Statc Unitcd States 2002 City County State United States 2003 City Counry State United Statcs 20U4 City Counry Statc United Statcs Total Effective Buying Incomc (� in 000's) S 1,109,327 25,144,120 652,190,282 5,230,824,904 1,008,568 23,617,301 650,521,407 5,303,481,498 1,184,128 25,180,040 647,879,427 5,340,682,818 ],238,323 27,623,743 674,721,020 5,466,880,008 1,295,785 29,468,208 705,108,410 5,692,909,567 Suurces: Salcs & Marketing Managemcnt, 2001 through 2005 Surveys �(Buying Power. Utilitics Median Household Effective Buvine Income 546,046 39,293 44,464 39,129 37,975 3 7,480 43,532 38,365 42,299 38,691 42,484 38,035 41,699 39,321 42,924 38,201 42,769 40,275 43,915 39,324 Water, sewage treatment and wastcwater disposal are provided by the Coachella Valley Watcr District. Southern California Gas Company supplies natural gas to the City and elecuic power is provided by the Southem California Edison Company. Telephone service is available through Verizon. Cablc telcvision service is provided by Time W amer. o�oa2�5-z C-7 Transportation Inter-City transportation is provided by Greyhound Bus which provides service from its connection points in thc City to its lincs outside of the Ciry in addition to thc community owncd and operated Sunlinc Bus System which provides service throughout the entire Coachella Valley. Intra-City transportation is provided by Tel-a-Ride and local taxi firms. The City's central highways are California Highway 1 I 1 and 74 which conncct to US [ntcrstate 10 and to California Highway 63 and 86. Shipping is provided 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, 10 milcs east of the Ciry, and by Amtrak, which has two stations located in Coachella Valley. A full service airport is located in Palm Springs, 12 miles northwest of the City, with approximatcly seven carriers providing service. The airport has an 8,500 foot runway and general aviation facilities. There is also a private airport in Bermuda Dunes, eight miles northeast of the City. Community Scrvices Thc Ciry of Palm Desert provides both police and fire protection through contracts with the Counry of Rivcrsidc. The Riverside County Public Library Systcm provides library services to the City. The Ciry also operatcs a 43,000 square foot public library on the College of the Dcsert campus which is jointly used by thc public and the College of the Desert. Education, Culture and Recreation Public school education is provided by the Desert Sands Unificd School District (the "School District"). The School District provides preschool through grade 12 education to students living in the City and the communities of Indian Wells, lndio, La Quinto, Rancho Mirage and Bermuda Dunes. The School District and operates 17 clementary schools, six middle schools, three comprehcnsive high schools, one independent study/alternative school and a continuation high school. Thc College of the Descrt, the Coachclla Valley Community College is located in the City. A satellitc campus of Califomia Staie University, San Bcmardino is also located on the College of the Descrt Campus. Cultural facilities in the Ciry include thc 1,127 seat McCallum Thcater for the Performinb Arts located in Bob Hope Cultural Center, the 1,200 acre Living Desert Zoo and Gardens, and the Art in Public Places (a museum without walls featuring more than 130 works of art throughout the City). Recreation programs for residents of the City and other neighboring communities arc offered through the Coachella Valley Recreation and Park District (the "Park District"). The Park District providcs rccrcational activitics and programs ranging from tiny tots programs, kids clubs and summer day camp, to d•ance, health and fimess and music instruction, to the senior games. The Desert Willow Golf Resort, two championship 18-hole, public golf course, is located on approximately 540 acres in the northcrn area of the City. This golf course also features a 33,000 square foot clubhouse with restaurant, dining and banquet facilities. The City also is home to five other public golf courses and resorts and 20 private or semi-private golf clubs and resorts. oboaz��5-z C-8 APPENDIX D SUMMARY OF PRINCIPAL LEGAL DOCUMENTS oboaz���s•z D-1 APPENDIX E PROPOSED FORM OF BOND COUNSEL OPINION 060�i2�pos-? E-1 APPENDIX F FORM OF CONTINUING DISCLOSURE AGREEMENT The Continuing Disclosure Agreement (the "Disclosure Agreement") is executed and dclivered by the Palm Desert Redevelopment Agency (the "Redevclopment Agency"), Wells Fargo Bank, National Association (the "Trustee") and MuniFinancial, Inc. (the "Dissemination AgenP') in connection with the issuance of the S principal amount of Palm Desert Financing Authority Tax Allocation Refunding Rcvcnuc Bonds (Project Area No. 1, As Amcnded) 2007 Series A(the "Bonds"). The Bonds are bcing executed and delivered pursuant to an Indcnturc of Trust dated as of January 1, 2007 (the "Indenture"), by and between the Palm Desert Financing Authority (the "Financing Authority") and the Trustee. The Financing Authority will loan the proceeds of thc Bonds to the Rcdevelopment Agency pursuant to a Loan Agreement made and entercd into as of January I, 2007. Thc Redevelopment Agency covenants and agrces as follows: SECTION 1. Puroose of this Disclosure A�reemcnt. This Disclosure Agrecmcnt is being executcd and dclivcred by the Redevclopment Agency for ihe benefit of the Holders and Beneficial Owners of the Bonds and in order to assist the Participating Underwriter in complying with Securities and Exchange Commission ("SEC") Rule 15c2-12(b)(5). The Redevelopment Agency acknowledges that the Financing Authoriry has undertaken no responsibiliry with respect to any reports, notices or disclosures provided or required under this Disclosure Agreement, and has no liability to any person, including the owners of the Bonds, with respect to any reports, noticcs or disclosures. SECTION 2. Definitions. In addition to thc dcfinitions sct forth in the Indenturc, 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 meanings: "Annual Report" shall mean any annual rcport provided by thc Redevelopment Agency pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. "Beneficial Owner" shall mean any person which (a) has the power, directly or indirectly, to vote or consent with respcct to, or to dispose of owncrship of, any Bonds (including persons holding Bonds through nominces, depositorics or other intcrmcdiaries) or (b) is treated as the owner of any Bonds for fedcral income tax putposes. "Central Post Office" shall mean the Disclosure USA website maintained by the Municipal Advisory Council of Texas or any successor thereto, or any other organization or method approved by the staff or members of the Securities and Exchange Commission as an intermediary through which issuers may, in compliance with the Rule, make filings required by this Disclosure Agreement. "Dissemination Agent" shall mean MuniFinancial, Inc., acting in its capacity as Dissemination Agent hercunder, or any succcssor Dissemination Agent dcsignated in writing by the Redevelopmcnt Agcncy and which has filed with the Trustee a written acceptance of such designation. "Fiscal Year" shall mean with respect to the Redevelopment Agency, the period beginninb on July 1 of' each year and ending on the next succeeding June 30, or any twclve month or fifry-two week period thereafter selected by the Redevelopment Agcncy with notice of such selection of change in fiscal year to be provided as set forth herein. o�oa2��s-z F-1 "Holders" shall mean either the registered owners of the Bonds, or, if the Bonds are registcrcd in the namc of Thc Dcpository Trust Company or another recognizcd depository, any applicable participant in its dcpository system. "Listed Event" shall mean any of the evcnts listcd in Section 5(a) of this Disclosure Agreemcnt. "National Repository" shall mean any Nationally Rccognized Municipal Securities lnformation Rcpository for purposes of the Rule. A list of the current National Repositories approved by the S.E.C. may be found at the S.E.C. website: http://www.sec.gov/info/municipaUnrmsir.htm. "Participating Underwriter" shall mcan Stone & Youngberg LLC, as thc original underwriter of the Bonds required to comply with the Rule in connection with offering of the Bonds. "Rcpository" shall mean each National Rcpository and cach State Repository, if any. "Rule" shall mean Rulc 15c2-12(b)(5) adopted by thc Securities and Exchange Commission undcr the Securitics Exchange Act of 1934, as the same may be amended from time to time. "State" shall mean thc State of California. "Statc Repository" shall mean any public or private repository or entity designated by thc State as a statc repository for the purpose of the Rule and recognized as such by the Securities and Exchange Commission. As of the date of this Disclosure Agreement, there is no State Repository. SECTION 3. Provision of Annual Renorts. (a) The Redevelopment Agency shall, not later than six months after thc end of' the Redevelopment Agency's Fiscal Year (which cutrently is June 30), commencing with the report for the 2006-07 Fiscal Year, provide to each Repository an Annual Report which is consistent with the requircments of Section 4 of this Disclosure Agreement. The Annual Report may be submitted as a single document or as separate documcnts comprising a package, and may include by reference other information as provided in Section 4 of this Disclosure�Agreement; provided that the auditcd financial statements of the Rcdevelopment Abency may be submitted separately from the balance of the Annual Report. The Redcvelopment Agency shall providc a written certification with each Annual Repon fumished to the Dissemination Agent and thc Trustee to the cffect that such Annual Report constitutes the Annual Report required to be fumished by the Redevelopment Agency hereunder. The Dissemination Agent and ihe Trustee may conclusively rely upon such certification of the Redevelopment Agency. If the Redevelopment Agency's Fiscal Year changes, it shall give notice of such change in the same manncr as for a Listcd Event under Section 5(c). (b) lf the Dissemination Agent is other than thc Redevelopment Agcncy, then not later than fiftecn (15) Busincss Days prior to said date, the Redevelopment Agcncy shall provide the Annual Report to thc Dissemination Agcnt. If thc Disscmination Agent is unable to verify that an Annual Report has been provided to thc Repositories by the date required in subsection (a), the Disscmination Agent shall send a notice to the Municipal Securities Rulemaking Board and the State Repository, if any, in substantially the form attachcd as E�chibit A to this Disclosure Agreement. (c) The Dissemination Agent shall: (i) detcrmine each year prior to the date for providing the Annual Report the name and address of each Repository; oboaz�s-z F-2 (ii) file the Annual Report with each Repository by the date requircd thercfor by Section 3(a) and file any noticc of a listcd Event, if requested by the Rcdevclopment Agcncy, as soon as practicable following receipt from the Redevelopment Agency of such notice; and (iii) if thc Dissemination Agent is othcr than the Redevelopment Agency, file a repoct with the Redevelopment Agency ccrtifying that the Annual Report has been provided pursuant to this Disclosurc Agrcement, stating the date it was provided and listing all the Repositories to which it was provided. (d) Notwithstanding any other provision of this Disclosure Agreement, thc Ciry and the Dissemination Agent reservc the right to makc any of the aforementioncd filings through the Ccntral Post Office. SECTION 4. Content of Annual Reports. Thc Redevelopmcnt Agency's Annual Report shall contain or incorporate by referencc the following: (a) The audited financial statements of the Redcvelopment Agency, presented in accordance with gcnerally accepted accounting principles as promulgated to apply to governmental entities Commission from time to time. If the audited financial statements of ihc Redevelopment Agency are not available by the time the Annual Report is required to be filed as described above, the Annual Report shall contain unaudited financial statements in a format similar to the financial statemcnts contained in the final Official Statemcnt, and the auditcd financial statements shall be filed in the same manner as the Annual Report whcn they become available. (b) Unless otherwise provided in the audited financial statements fled on or prior to the annual filing dcadline for Annual Reports provided in Section 3 above, financial information and operating data with respect to the Redevelopment Agency for the preceding Fiscal Year, substantially similar to that providcd in the following tables and charts in the Official Statement: (i) Table 4—"Palm DeseR Rcdevelopmcnt Agency Project Area No. 1- Combined— Principal Taxpayers;" (Table 4A—"Palm Descrt Redevelopment Agency Project Area No. 1- Original Area—Principal Taxpayers;" and Table 4B—"Palm Desert Rcdevelopment Agency Projcct Area No. 1- Added Territory—Principal Taxpaycrs;"] and (ii) Table 6A—"Palm Desert Redevelopment Agency Projcct Area No. 1- Original Arca—Historical Taxable Values and Tax Incrcment Revenucs;" and Table 6B—"Palm Desert Redevelopmcnt Agency Project Arca No. 1- Added Territory—Historical Taxable Values and Tax Increment Revenues." (c) The outstanding principal amount of Bonds, for the preceding Fiscal Year. Such annual information and operating data described above may be included by specific reference to other documents, including official statements of debt issues of the Redevelopment Agency or related public entities, which have been submitted to each of the Repositories or the Securities and Exchangc Commission; providecl, that if the documents included by reference is a final official statement, it must be available from the Municipal Securities Rulcmaking Board; and provided furcher, that the Redevclopmcnt Agency shall clearly identify each such other document so included by reference. 06(}42�os-2 F-3 SECTION 5. Revortins of Si�nificant Events. (a) Pursuant to the provisions of this Section 5, the Redcvelopment Agency shall givc, or causc to bc givcn, notice of the occurrencc of any of the following cvents with respect to the Bonds, if matcrial: (i) principal and interest payment delinquencies. (ii) non-paymcnt related defaults. (iii) modifications to rights of Bondholdcrs. (iv) optional, contingent or unscheduled bond calls. (v) defeasances. (vi) rating changcs. (vii) adversc tax opinions or evcnts advcrsely affecting the tax-exempt status of the Bonds. (viii) unscheduled draws on the Rcserve Fund reflecting financial difficultics. (ix) unscheduled draws on the credit enhancements rcflecting financial difficulties. (x) substitution of the credit or liquidity providers or their failure to perforcn. (xi) release, substitution or salc of property securing repaymcnt of the Bonds. (xii) Significant amendmcnts to the land use regulations or entitlements of the City of Palm Desert within the Project Area which would adversely affect development of property therein. (b) The Trustee shall, promptly upon obtaining actual knowledge of the occurrence of any of the Listed Eve:nts contact the Disclosure Representative, inform such person of the event, and request that the Rcdevclopment Agency promptly notify the Dissemination Agent in writing whether or not to repon the cvent pursuant to subsection (� and promptly notify the Trustce in writing whether or not to report the evcnt to the Owners (unless notice to the Owners is required by the Indenture). For purposes of this Disclosurc Agreement, "actual knowledge" of the occurrence of such Listed Events shall mean actual knowledge by the officer at thc Trust Office of the Trustee with regular responsibiliry for the administration of thc Indenturc. (c) Whenever the Redcvelopment Agency obtains knowledge of the occurrence of a Listed Event, whcther because of a notice from the Trustec pursuant to Section 5(b) or otherwise, ihc Redevelopment Agency shall as soon as possible determine if such event would be material under applicable fcderal sccurities laws. (d) If the Redevelopment Agcncy determines that knowledge of the occurrence of a Listcd Evcnt would be material under applicable fedcral securities laws, the Redevelopment Agency shall promptly notify the Dissemination Agent and the Trustee in writing. Such notice shall instruct the Disscmination Agent to file a notice of such occunence with the Municipal Securities Rulemaking Board and the State Repository, if any. Notwithstanding the foregoing, notice of Listed Events describcd in subsections (a)(iv) and (a)(v) nced not be given under this subsection any earlier than the noticc (if any) of the underlying event is givcn to Holders of affected Bonds pursuant to the Indenture. 06042�pos-2 F� (c) lf in response to a requcst undcr subscction (b), the Rcdevelopment Agency determines that the Listed Evcnt is not material, the Redevelopment Agency shall so notify the Dissemination Agent and the 1�rustee in writing and instruct the Dissemination Agent and the Trustee not to report the occurrence. SECTION 6. Tcrmination of Renortine Oblieation. The obligations of the Redevclopmcnt Agency under this Disclosure Agreement shall terminate upon the legal defeasance, prior redemption or paymcnt in full of all of the Bonds. If such termination occurs prior to the final maturity of the Bonds, the Rcdcvelopment Agency shall give notice of such termination in the same manncr as for a Listcd Evcnt under Section 5(c). SECTION 7. Dissemination AQcnt. The Rcdcvelopment Agency may, from time to time, appoint or engagc a Dissemination Agent to assist it in carrying out its obligations under this Disclosure Agreement, and may discharge any such Dissemination Agent, with or without appointing a successor Dissemination Agent. Thc Dissemination Agent shall not be responsiblc in any manncr for thc content of any noticc or repon prcpared by the Redevelopment Agency pursuant to this Disclosure Agreement. The initial Dissemination Agent shall be the MuniFinancial, Inc. Thc Disscmination Agent may resign its duties hereunder at any time upon written notice to the Redevelopment Agency. SECTION 8. Amendment. Notwithstanding any other provision of this Disclosure Agreement, the parities may a►ncnd this Disclosure Agreement (and the Trustec and the Dissemination Agent shall agrce to any a►nendmcnt so requestcd by the Redcvclopment Agency provided that neither the Trustec nor thc Dissemination Agent shall be obligated to entcr into any such amendment that modifics or increases its duties or obligations hereunder} only if: (a) the amendment is made in connection with a change in circumstances that arises from a change in legal requircments, change in law, or change in identity, nature, or status of thc Redevelopment Agcncy, or typc of business conducted; (b) this Disclosure Agreement, as amended, would have compiled with the requirements of' the Rulc at thc time of sale of thc Bonds, after taking into account any amenciments or intcrpretations of the Rule, as well as any change in circumstances; (c) thc amendmcnt does not materially impair the interests of the Owners, as detcrmined by parties unaffiliated with the Redevelopment Agency (such as, but without limitation, the Redevelopment Agcncy's bond counsel) or by Owner's consent pursuant to Section 7.01 of the Indcnture; and (d) the annual financial information containing (if applicable) the amended operating data or financial information will cxplain, 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 Exchange Commission to the National Association of Bond Lawyers dated June 23, 1995) of the change in the rype of operating data or financial information bcing providcd. SECTION 9. Additional Information. (a) The Redevelopment Agcncy ab�rees to provide public information concerning the Bonds and the Rcdcvelopment Agcncy to any Holder or Beneficial Owner making a written request thcrefor. oboaz��os-z F-5 (b) Nothing in this Disclosure Agrcemcnt shall be deemed to prevcnt the Redevclopment Agcncy from disseminating any other information, using the mcans of dissemination set forth in this Disclosure Agrecment or any other means of communication, or including any other information in any Annual Report or notice of occurrcnce of a Listcd Event, in addition to that which is requircd by this Disclosure Agreement. If the Redevelopment Agcncy chooses to include any inforrnation in any Annual Rcpon or notice of occurrence of a Listed Event in addition to that which is specifically rcquired by this Disclosurc Agrcement, the Redcvelopment Agcncy shall have no obligation under this Disclosure Agrcemcnt to updatc such information or include it in any future Annual Report or notice of occurrence of a Listed Evcnt. SECTION 10. Default. In the even to a failure of the Redevelopment Agency to comply with any provision of this 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 thc extent funds have been provided to it or it has becn otherwise indcmnified to its satisfaction from any cost, liability, expense or additional charges of the Trustee whatsoever, including, without limitation, fees and expenscs of its attorneys), or any Owner may, take such actions as may be necessary and appropriatc, including seeking mandate or specific performance by court order, to cause the Redevelopment Agency, the Trustec or the Dissemination Agent, as the case may be, to cocnply with its obligations under this Disclosure Agrecment; providcd that any such action may bc institutcd only in the Fedcral or State Court located in the County of Los Angeles, State of California and no remedy other than specific performance may be sought or grantcd. A default under this Disclosure Agreement shall not be deemed an Event of Default under the Indcnturc or thc Loan Agrecment, and the sole remedy undcr this Disclosurc Agreement in the event of a failure of the Redevelopment Agcncy, the Trustee or the Dissemination Agent to comply with this Disclosure Agrcement shall be an action to compel performance. SECTION 11. Duties. Immunities and Liabilities of Dissemination Aeent. The Dissemination Agent shall have only such dutics as are specifically set forth in this Disclosure Agreement, and the Redevelopmcnt Agency agrees to indemnify and save the Dissemination Agent and the Trustee, their officers, directors, employees and agcnts, harmless against any loss, expense and liabilities which it may incur arising out of or in thc exercise or performance of its powers and duties hereunder, including the costs and expenses (including attomeys fees) of defending against any claim of liability, but excluding liabilities due to the Dissemination Agent's or Trustce's negligence or willful misconduct. The Dissemination Agcnt may rely 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. The Dissemination Agent and the Trustee shall be paid compensation by the Redevelopment Agency for its services provided hereunder in accordance with its schedule of fccs as amendcd from time to time and all expenscs, lcgal 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 Redevclopment Agcncy hereunder and shall not be deemed to be acting in a fiduciary capaciry for the Financing Authority, the Redevelopment Agency, the Owners, or any other parry. The obligations of the Redevelopment Agency under this Section shall survive resig�ation or rcmoval of the Dissemination Agent and payment of the Bonds. No person shall havc any right to commence any action against thc Dissemination Agent seeking any remedy other than to compel specific performance of this Disclosure Agreement. The Dissemination Agent shall not be liable under any circumstances for monetary damages to any person for any breach of this Disclosure Agrcement. SECTION 12. Beneficiaries. This Disclosure Agrcemcnt shall inure solely to the benefit of thc Redevclopment Agency, the Participating Underwriter, the Dissemination Abent and Holders and Beneficial Owners from time to time of the Bonds, and shall create no rights in any othcr person or entity. 06042�pos•2 F-6 SECTION 13. Notices. Notices should be sent in writing to the following addresscs. Thc following information may be conclusivcly relied upon until changed in writing. Redevelopment Agency: Palm Dcsert Redevelopment Agency 73-510 Fred Waring Drivc Palm Desert, Califomia 92260 (760) 346-0611 (760)346-0574 Fax Trustee: Wells Fargo Bank, National Association 700 South Flower Street, Suite 500 Los Angeles, California 90017-4104 (213)630-6237 (213)630-6215 Fax Disscmination Agency: MuniFinancial, Inc. 27368 Via lndustrial, Suite 10 Tcmecula, California 92590 (909)587-3500 (909) 587-3510 Fax ot,oaz��,-z F-7 SECTION 14. Counteraarts. This Disclosure Agreement may bc exccuted in scveral counterpares, each of which shall be an original and all of which shall constitute but one and the same instrument. Datc: . 2007 PALM DESERT REDEVELOPMENT AGENCY OF � Authorized Officer WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustec I� Authorized Officcr MLJNIFINANCIAL, INC., as Disscmination Agent : Authorized Officcr o�oaz��s-z F-8 EXHIBIT A NOTICE TO MUNICIPAL SECURITIES RULEMAKING BOARD OF FAILURE TO FILE ANNUAL REPORT' Name of Obligatcd Party: Palm Dcsert Redevelopmcnt Agency Name of Bond Issue: Palm Descrt Financing Authority Tax Allocation Refunding Revcnuc Bonds (Project Area No. 1, As Amended) 2007 Series A Datc of Issuance: , 2007 NOTICE IS HEREBY GIV�N that ihc Pal►n Desert Redevclopment Agency (the "Rcdevclopment Agency") has not providcd an Annual Report with respect to the abovc-named Bonds as required by Scction 3 of thc Continuing Disclosure Agreement dated , 2007, by and among the Redevelopment Agcncy, the Trustee and the Dissemination Agcnt executed by the Disscmination Agent for thc benefit of thc Holders and Beneficial Owners of the above-referenced bonds. The Redevelopment Agency anticipates that thc Annual Report will be filed by . Dated: WEL,LS FARGO BANK, NATIONAL ASSOCIATION, as Trustce, on behalf of the Redevelopment Agency By: Its: cc: Executive Director, Palm Desert Redevelopment Agency o�,oaz��s-z F-9 APPENDIX G DTC AND THE BOOK-ENTRY ONLY SYSTEM The information in this Appendi,z G c�ncerning The Depository Trust Company, New Ynrk, Netiti� York ("DTC') and DTC's book-entry system has been obtained from DTC and the Redevelopment Agency take.s no responsibiliry for the completeness or uccuracy thereof. The Redevelopment Agency cunnot and does not give any assurances that DTC, DTC Participants or Indirect Participants will distribule to the Beneficial Chvners (a) payments of interest, principal nr premium, if any, with respect to the 2007 Series A Bonds, (b) certificates represerrting ownership interest in or other confirmation or ownership interest in the Z007 Series A Bond.s, or (c•) redemption or other notices sent to DTC or Cede 8c Co., its nominee, as the registered owner of the 2007 Series A Bonds, or that they will so do on a timely basis, or that DTC, DTC Participants or UTC lndirect Purticipants wi!! act rn the manner described in this Appendix. The c•urrent "Rules" upplicable to DTC are on ftle with the Securities and Exchange Commission and the current "Yrocedures " ojDTC to be jollowed in dealrng with DTC Purtrcipants are orr frle with DTC. The Depository Trust Company ("DTC"), New York, NY, will act as securities depository for the 2007 Series A Bonds. The 2007 Scries A Bonds will be issued as fully-registered securities registered in the name of Cedc & Co. (DTC's partncrship nomince) or such other namc as may be requestcd by an authorized rcprescntative of DTC. One fully-registercd security certificate will be issued for each maturity of thc 2007 Series A Bonds, each in the aggregate principal amount of such maturity, and will be deposited with DTC. DTC, thc world's largest depository, is a limited-purpose trust company organized undcr thc New York Banking Law, a"banking organization" within the meaning of the New York Banking Law, a mcmbcr of thc Federal Reservc System, a"clearing corporation" within the meaning of the New York Uniform Commcrcial Codc, and a"clearing agency" registered pursuant to the provisions of Section 17A of thc Securitics Exchange Act of 1934. DTC holds and provides asset servicing for over 22 million issues of U.S. and non-U.S. cquity issucs, corporatc and municipal debt issues, and money market instruments from over 100 countries that DTC's participants ("Direct Participants") deposit with DTC. DTC also facilitates the post- trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book-entry transfers and pledges betwcen Direct Participants' accounts. This eliminates thc nced for physical movement of securities certificates. Direct Participants includc both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and cenain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC, in turn, is owncd by a numbcr of Direct Participants of DTC and Members of thc National Securities Clearing Corporation, Govemment Securities Clearing Corporation, MBS Clearing Corporation, and Emerging Markets Clearing Corporation, (respectively, "NSCC", "GSCC", "MBSCC", and "EMCC", also subsidiaries of DTCC), as well as by the New York Stock Exchange, Inc., the American Stock Exchangc LLC, and the National Association of Sccurities Dcalcrs, Inc. Access to the DTC system is also available to others such as both U.S. and non-U.S, securities brokers and dealers, banlcs, trust companies, and clearing coiporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). DT'C has Standard & Poor's highest rating: AAA. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com and www.dtc.org. Purchascs of the 2007 Series A Bonds undcr the DTC system must be made by or through Direct Pacticipants, which will receive a credit for the 2007 Series A Bonds on DTC's records. The ownership interest of each actual purchaser of each Bond ("Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Bcneficial Owncrs will not receive written confirmation from DTC of thcir purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of thc transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the 2007 oboa���„-2 G-I Series A Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in the 2007 Series A Bonds, except in the event that use of the book-entry systcm for the 2007 Scrics A Bonds is discontinucd. To facilitate subsequent transfers, all 2007 Series A Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nomince, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of the 2007 Scries A Bonds with DTC and iheir registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owncrs of the 2007 Series A Bonds; DTC's records reflect only the identiry of the Direct Parlicipants to whose accounts such Bonds are credited, which may or may not be the Bcneficial Owners. The Dircct and Indirect Participants will remain responsible for keeping account of their holdings on bchalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Panicipants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any slatutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of the 2007 Series A Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the 2007 Series A Bonds, such as redemptions, tenders, defaults, and proposed amendmenis to the Indenturc. For cxample, Beneficial Owners of thc 2007 Scries A Bonds may wish to ascertain that the nominee holding the 2007 Serics A Boncis for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the altemative, Beneficial Owncrs may wish to provide their names and addresses to the registrar and request that copies of notices bc provided directly to them. Redemption notices shall be sent to DTC. The conveyance of notices and other communications by DTC to DTC Participants, by DTC Participants to Indirect Participants and by DTC Participants and Indircct Participants to Beneficial Owncrs will bc governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect 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 affect the validity of the redemption of the 2007 Series A Bonds called for redemption or of any other action premised on such notice. Redemption of portions of the 2007 Serics A Bonds by the Redevelopment Agency will reduce the outstanding principal amount of Bonds held by DTC. In such event, DTC will implemcnt, through its book-cntry system, a redemption by lot of interests in the 2007 Series A Bonds held for the account of DTC Participants in accordance with its own rules or othcr agreements with DTC Participants and then DTC Participants and Indirect Participants will implcment a redemption of the 2007 Series A Bonds for the Beneficial Owncrs. Any such selection of Bonds to be redcemed will not be governed by the Indenture and will not be conducted by the Redevelopment Agency or the Trustee. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to thc 2007 Scries A Bonds unless authorized by a Direct Participant in accordance with DTC's Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the issuer as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consentin�; or voting rights to those Direct Parlicipanis to whose accounts the 2007 Series A Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Payments of principal of, premium, if any, and interest evidenced by the 2007 Series A Bonds will be made to Cede & Co., or such other norriinee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Patticipants' accounts upon DTC's receipt of funds and coc7esponding detail information from the Redevelopment Agcncy or the Trustee, on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be oboaz��os-z G-2 govemcd by standing instnictions and customary practiccs, as is the case with securities hcld for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of such Participant and not of DTC (nor its nominee), the Trustce, or the Redevelopment Agency, subject to any statutory or rcgulatory requircments as may be in effect from time to time. Payment of principal of, premium, if any, and interest evidenccd by the 2007 Series A Bonds to Cede & Co. (or such other nominee as may bc requcsted by an authorized represcntative of DTC) is thc responsibility of the Redevelopmcnt Agency or the Trustce, disburscment of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants. NEITHER THE REDEVELOPMENT AGENCY NOR THE TRUSTEE WILL HAVE ANY RESPONSIBILITY OR OBLIGATION TO DTC PARTICIPANTS, INDIRECT PARTICIPANTS OR BENEFICIAL OWNERS WITH RESPECT TO THE PAYMENTS OR THE PROVIDING OF NOTICE TO DTC PARTICIPANTS, INDIRECT PARTICIPANTS OR BENEFICIAL OWNEAS OR THE SELECTION OF BONDS FOR REDEMPTION. Neither thc Redevclopment Agency nor the Trustee can give any assurances that DTC, DTC Paiticipants, Indirect Participants or others will distribute payments of principal of, premium, if any, and interest on the 2007 Serics A Bonds paid to DTC or its nominee, as the registered Owner, or any redemption or othcr notice, to the Beneficial Owncrs or that they will do so on a timely basis or that DTC will serve and act in a manner described in this Official Statement. DTC may discontinue providing its services as depository with respect to the 2007 Series A Bonds at any time by giving reasonable notice to the Redevelopment Agency or the Trustee. Under such circumstances, in 1he event that a successor depository is not obtained, Bond certificates are required to be printed and delivered. The Redevelopment Agency may decide to discontinue use of the system of book-entry transfers t}u-ough DTC (or a successor securities depository). In that event, Bond certificates will be printed and delivcrcd. ]n the event that the book-entry system is discontinued as described abovc, thc requiremcnts of thc Indenture will apply. The foregoing information concerning DTC conceming and DTC's book-entry system has been provided by DTC, and neilher the Redevelopmcnt Agency nor thc Trustee takc any responsibility for the accuracy thereof. The Redevelopment Agency and the Trustee cannot and do not give any assurances that DTC, the Participants or others will distribute payments of principal, intcrest or premium, if any, evidenced by thc 2007 Series A Bonds paid to DTC or its nominee as the registered owner, or will distribute any redemption notices or othcr noticcs, to the Beneficial Owners, or that thcy will do so on a timely basis or will scrve and act in the manner described in this Official Statement. Neither the Redevelopment Agency 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 Bcneficial Owner with respect to the 2007 Scrics A Bonds or an error or delay rclating thcrcto. ut�cwz�os-z G-3 APPENDIX H SPECIMEN FINANCIAL GUARANTY INSURANCE POLICY 06042�pos-2 Ii-1