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HomeMy WebLinkAboutAgenda Report - March 2, 2022 G-03 PHww:5'• CITY OF LODI AGENDA ITEM ,. COUNCIL COMMUNICATION TM AGENDA TITLE: Adopt Resolutions and Authorize Documents and Actions Regarding the Financing for the Acquisition, Design and Construction of Capital Improvements (a) Hold a Noticed Public Hearing. (b) Adopt Resolution of the City Council of the City of Lodi Making Findings and Approving Documents and Official Actions Relating to the Proposed Issuance by the Lodi Public Financing Authority of Lease Revenue Bonds to Refinance Outstanding Lease Revenue Bonds and Provide Financing for Acquisition and Construction of Capital Improvements, Including an Animal Shelter and Parks and Playground Improvements and Upgrades, and (c) Adopt Resolution of Board of Directors of the Lodi Public Financing Authority Authorizing the Issuance and Sale of Lease Revenue Bonds to Refinance Outstanding Lease Revenue Bonds and Provide Financing for Acquisition and Construction of Capital Improvements, Including an Animal Shelter and Parks and Playground Improvements and Upgrades, and Approving Related Documents and Official Action MEETING DATE: March 2, 2022 PREPARED BY: Deputy City Manager and City Attorney RECOMMENDED ACTION: Adopt Resolutions and Authorize Documents and Actions Regarding the Financing for the Acquisition, Design and Construction of Capital Improvements. a. Hold a Noticed Public Hearing. b. Adopt Resolution of the City Council of the City of Lodi Making Findings and Approving Documents and Official Actions Relating to the Proposed Issuance by the Lodi Public Financing Authority of Lease Revenue Bonds to Refinance Outstanding Lease Revenue Bonds and Provide Financing for Acquisition and Construction of Capital Improvements, Including an Animal Shelter and Parks and Playground Improvements and Upgrades, and C. Adopt Resolution of Board of Directors of the Lodi Public Financing Authority Authorizing the Issuance and Sale of Lease Revenue Bonds to Refinance Outstanding Lease Revenue Bonds and Provide Financing for Acquisition and Construction of Capital Improvements, Including an Animal Shelter and Parks and Playground Improvements and Upgrades, and Approving Related Documents and Official Action. Adopt Resolutions and Authorize Documents and Actions Regarding the Financing for the Acquisition, Design and Construction of Capital Improvements March 2, 2022 BACKGROUND INFORMATION: The Lodi Public Financing Authority ("PFA") issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City. In connection with the issuance of the 2012 Bonds, the City and the PFA entered into a Site Lease and a Lease Agreement, each dated September 1, 2012, pursuant to which, respectively, the City leased to the PFA the land and improvements constituting the City's police building and Carnegie Forum, and the PFA sub -leased the assets back to the City. In order to take advantage of prevailing bond market conditions, the City is proposing to refund the 2012 Bonds. The City wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including a new animal shelter and parks and playground improvements and upgrades (the "Project"). In order to provide funds for the refunding of the 2012 Bonds and the financing of the Project, staff is proposing that the PFA issue lease revenue bonds (the "2022 Lease Revenue Bonds"). In connection with the issuance of the 2022 Lease Revenue Bonds, the City and the PFA will enter into a Site Lease and a Lease Agreement, pursuant to which, respectively, the City will lease to the PFA the land and improvements constituting the City's police building and the City's Fire Station #2, and the PFA will sub -lease the assets back to the City. Government Code Section 6586.5 requires the City to hold a public hearing on the proposed issuance of the 2022 Lease Revenue Bonds to finance the Project, and to make certain findings. As required by Section 6586.5, the City has caused publication of a notice of a public hearing once at least five days prior to the date hereof in a newspaper of general circulation in the City. SUMMARY OF DOCUMENTS: In order to complete the proposed financing, the City and the PFA are required to adopt resolutions and approve and execute several key legal documents. The resolutions and the key documents are summarized below. Resolutions: The Resolutions of the City and the PFA approve the issuance of the proposed 2022 Lease Revenue Bonds, the execution of the proposed legal documents, and the distribution of the Official Statement to investors. While the documents are in near -to -final form, the Resolutions authorize certain officers of the City and the PFA to make amendments, as necessary. The Resolutions specify the maximum principal amount for the 2022 Lease Revenue Bonds, maximum interest rate, and maximum underwriter's discount. The City, Council Resolution includes the findings required to be made by the City Council after holding the public hearing. Official Statement: The Preliminary Official Statement, approved and signed by the City and PFA, most importantly describes (i) the refunding of the outstanding 2012 Bonds; (ii) the financing of the Project; (iii) the City's lease payment obligation, which is the source of repayment for the 2022 Lease Revenue Bonds; (iv) potential risks to prospective investors in the 2022 Lease Revenue Bonds (described in the section entitled "RISK FACTORS"); (v) tax status of interest on the 2022 Lease Revenue Bonds (described in the section entitled "TAX MATTERS"); and (vi) the economic and demographic characteristics of the City (set forth in Appendix A). The Preliminary Official Statement (often referred to as the "POS") is distributed by the underwriter to prospective investors prior to the bond sale so that investors can make informed purchase decisions. The POS is the equivalent of a prospectus in the private sector. The Final Official Statement is sent to purchasers after the terms of the sale are finalized. 2 Adopt Resolutions and Authorize Documents and Actions Regarding the Financing for the Acquisition, Design and Construction of Capital Improvements March 2, 2022 The distribution of a POS is subject to federal securities laws, including the Securities Act of 1933 and the Securities Exchange Act of 1934. These laws require the POS to include all facts that would be material to an investor considering a purchase of the 2022 Lease Revenue Bonds. Material information is information that there is a substantial likelihood that a reasonable investor would consider important in deciding whether to buy or sell bonds. Materiality is determined in the context of all facts and circumstances. The Securities and Exchange Commission (the "SEC"), the agency with regulatory authority over the City and the PFA's compliance with the federal securities laws, has issued guidance as to the duties of the City Council and the PFA's Board of Directors with respect to their approval of the POS. In its "Report of Investigation in the Matter of County of Orange, California as it Relates to the Conduct of the Members of the Board of Supervisors" (Release No. 36761 / January 24, 1996) (the "Release"), the SEC stated that, if a member of the City Council/Board of Directors has knowledge of any facts or circumstances that an investor would want to know about prior to investing in the bonds, whether relating to their repayment, tax-exempt status, undisclosed conflicts of interest with interested parties, or otherwise, he or she should endeavor to discover whether such facts are adequately disclosed in the POS. In the Release, the SEC stated that the steps that a member of the City Council/Board of Directors could take include becoming familiar with the POS and questioning staff and consultants about the disclosure of such facts. Continuing Disclosure Certificate: The Continuing Disclosure Certificate, attached as Appendix E to the Official Statement, obligates the City to provide updated information to the bond markets on an ongoing basis. Disclosure is required annually, and on an exceptional basis for any significant listed events. Band Purchase A„^ rq eement: The Bond Purchase Agreement is executed among the City, the PFA and the Underwriter (Piper Sandler & Co.) on the day of the bond sale. It specifies the actual principal amounts, interest rates, and prices at which the 2022 Lease Revenue Bonds will be sold. Within the Bond Purchase Agreement, the Underwriter commits to purchase the 2022 Lease Revenue Bonds at closing and the PFA commits to sell the 2022 Lease Revenue Bonds at the agreed upon prices and amounts subject to certain closing conditions. Closing conditions generally relate to the execution and validity of all the required documents and the absence of material changes in the nature of the security, etc. Site Lease: The Site Lease is executed by the City, as lessor, and the PFA, as lessee. The City will lease the land and improvements constituting the City police building and the City's Fire Station #2 ("Leased Property"), in consideration of the payment by the Authority of an upfront rental payment (the "Site Lease Payment") that is sufficient to provide funds for the refunding of the 2012 Bonds and the financing of the Project. The PFA has authorized the issuance of the 2022 Lease Revenue Bonds under an Indenture of Trust (the "Indenture") between the PFA and U.S. Bank Trust Company, National Association, as trustee (the "Trustee"), for the purpose of providing the funds to enable the PFA to pay the Site Lease Payment to the City. Lease Agreement: The Lease Agreement is executed by the PFA, as lessor, and the City, as lessee. In order to provide revenues which are sufficient to enable the PFA to pay debt service on the 2022 Revenue Bonds, the PFA will sub -lease the Leased Property back to the City under the Lease Agreement and the City will pay semiannual lease payments as the rental for Leased Property. The lease payments made by the City under the Lease Agreement will be assigned by the PFA to the Trustee for the security of the 2022 Lease Revenue Bonds under an Assignment Agreement (described below), between the PFA, as assignor, and the Trustee, as assignee. 3 Adopt Resolutions and Authorize Documents and Actions Regarding the Financing for the Acquisition, Design and Construction of Capital Improvements March 2, 2022 Assignment Agreement: The Assignment Agreement is executed by the PFA and the Trustee. Under the Assignment Agreement, the PFA will assign certain of its rights under the Lease Agreement to the Trustee for the benefit of the 2022 Lease Revenue Bond owners. The Site Lease, the Lease Agreement, and the Assignment Agreement will be concurrently recorded in the real property records of San Joaquin County Recorder. Indenture of Trust: The Indenture of Trust is the legal document between the PFA and the Trustee that lays out the terms of the 2022 Lease Revenue Bonds. It will specify: ■ the payment dates and maturities of the 2022 Lease Revenue Bonds; • the Authority's right to redeem (or prepay) 2022 Lease Revenue Bonds prior to their scheduled maturity date (which the City/Authority would typically exercise to take advantage of lower interest rates); • the pledge of revenues for payment of the 2022 Lease Revenue Bonds; • the default and remedy provisions (in the event the City failed to make the lease payments under the Lease Agreement); ■ the obligations of the Trustee; and ■ the conditions for defeasance of the 2022 Lease Revenue Bonds (discharge of the indenture). Irrevocable Refunding Instructions: The Irrevocable Refunding Instructions will be given by the PFA to the trustee for the 2012 Bonds (U.S. Bank Trust Company, National Association) for the purpose of providing the 2012 Bond Trustee with irrevocable instructions as to the use of the proceeds of the 2022 Lease Revenue Bonds and other available money to redeem the 2012 Bonds. FISCAL IMPACT: An increase at current City debt of $15 million but no net increase in total debt service costs over the life of the new financing. FUNDING AVAILABLE: Refinanced debt service costs paid in interest savings. n rew Keys anice D Magdich Deputy City Manager orney JDM/Ist Attachments: Draft City Council Resolution and Appendicies Draft Lodi Public Financing Authority Resolution and Appendicies Draft Preliminary Official Statement and Appendices Bond Purchase Agreement Draft Site Lease Draft Lease Agreement Assignment Agreement Indenture of Trust Irrevocable Refunding Instructions 4 I.��Y�A���[�7►1►i;�1� � • A RESOLUTION OF THE LODI CITY COUNCIL MAKING FINDINGS AND APPROVING DOCUMENTS AND ACTIONS RELATING TO THE PROPOSED ISSUANCE BY THE LODI PUBLIC FINANCING AUTHORITY OF LEASE REVENUE BONDS TO REFINANCE OUTSTANDING LEASE REVENUE BONDS AND PROVIDE FINANCING FOR ACQUISITION AND CONSTRUCTION OF CAPITAL IMPROVEMENTS, INCLUDING AN ANIMAL SHELTER AND PARKS AND PLAYGROUND IMPROVEMENTS AND UPGRADES WHEREAS, the Lodi Public Financing Authority (the "Authority") previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City of Lodi (the "City"); and WHEREAS, in connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum; and WHEREAS, in order to take advantage of prevailing bond market conditions, the City Council wishes to authorize the refinancing of the 2012 Bonds; and WHEREAS, the City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including, among other things, a new animal shelter and park and playground improvements and upgrades (the "Project"); and WHEREAS, to that end, the City has proposed to lease the land and improvements constituting the City's police building and its Fire Station #2 (the "Leased Property") to the Authority under a Site Lease, the form of which is on file with the City Clerk, in consideration of the payment by the Authority of an upfront rental payment which is sufficient to provide funds to refinance the 2012 Bonds and finance the acquisition and construction of the Project; and WHEREAS, in order to raise funds for the upfront rental payment, the Authority proposes to issue and sell its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) (the "Bonds") under Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California, commencing with Section 6584 of said Code (the "Bond Law"); and WHEREAS, in order to secure the payments of principal of and interest on the Bonds, the Authority proposes to lease the Leased Property back to the City under a Lease Agreement (the "Lease Agreement"), the form of which is on file with the City Clerk, under which the City is obligated to pay semiannual lease payments as rental for the Leased Property, and the Authority will assign substantially all of its rights under the Lease Agreement to U.S. Bank Trust Company, National Association, as trustee for the Bonds; and WHEREAS, there has been submitted to the City Council a form of preliminary Official Statement in connection with the marketing of the Bonds and the City Council, with the aid of its staff, has reviewed the preliminary Official Statement to assure proper disclosure of all material facts relating to the Bonds that are in the personal knowledge of the members of the City Council and the City staff; and WHEREAS, the Authority and the City propose to sell the Bonds to Piper Sandler & Co. (the "Underwriter") pursuant to a Bond Purchase Agreement (the "Bond Purchase Agreement"), the form of which is on file with the City Clerk; and WHEREAS, in order to assist the Underwriter in complying with Rule 15c2-12 of the Securities and Exchange Commission, the City will undertake certain continuing disclosure obligations with respect to the Bonds pursuant to a continuing disclosure certificate to be executed by the City (the "Continuing Disclosure Certificate"), the form of which is on file with the City Clerk; and WHEREAS, as a condition precedent to the issuance by the Authority of the Bonds to provide financing for the Project, Section 6586.5 of the Bond Law requires that the City approve the proposed lease financing by the Authority and that the City make certain findings with respect to such financing, and Section 6586.5 further requires that such approval be given and findings be made only after a noticed public hearing; and WHEREAS, as required by Section 6586.5 of the Bond Law, the City has caused publication of a notice of a public hearing on the financing of the Project once at least five days prior to the hearing in a newspaper of general circulation in the City; and WHEREAS, the City Council held a public hearing at which all interested persons were provided the opportunity to speak on the subject of financing the Project; and WHEREAS, in accordance with Government Code Section 5852.1, the City Council has obtained and wishes to disclose the information set forth in Appendix A hereto; and WHEREAS, the City Council wishes at this time to approve all proceedings to which it is a party relating to the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Lodi as follows: SECTION 1. Issuance of Bonds. The City Council hereby approves the issuance of the Bonds by the Authority under the Bond Law in the maximum principal amount of $30,000,000, for the purpose of providing funds to refinance the 2012 Bonds and finance the Project. Pursuant to the Bond Law, and based on the information provided to the City Council by City staff and consultants, all as set forth in the proceedings and documents providing for the issuance and delivery of the Bonds, the City Council hereby finds and determines that the issuance of the Bonds and the transactions related thereto will result in significant public benefits within the contemplation of Section 6586 of the Bond Law, namely, demonstrable savings in bond preparation, bond underwriting and bond issuance costs. SECTION 2. Approval of Related Financing Agreements. The City Council hereby approves each of the following agreements required for the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project, in substantially the respective forms on file with the City Clerk together with any changes therein or additions thereto deemed advisable by the City Manager, the Deputy City Manager or the City Attorney (each, an "Authorized Officer"), whose execution thereof shall be conclusive evidence of the approval of any such changes or additions. An Authorized Officer is hereby authorized and directed for and -2- on behalf of the City to execute, and the City Clerk is hereby authorized and directed to attest, the final form of each such agreement, as follows: • Site Lease, between the City as lessor and the Authority as lessee, under which the City leases the Leased Property to the Authority in consideration of the payment of an amount which will be applied by the City to refinance the 2012 Bonds and finance the Project. • Lease Agreement, between the Authority as lessor and the City as lessee, under which the Authority leases the Leased Property back to the City and the City agrees to pay semiannual lease payments which are sufficient to provide revenues with which to pay principal of and interest on the Bonds when due. • Irrevocable Refunding Instructions, to be given by the Authority to the trustee for the 2012 Bonds, and to be consented to by the City, providing for the deposit, investment and application of funds to defease and redeem the 2012 Bonds. • Bond Purchase Agreement, among the City, the Authority and the Underwriter, which establishes the terms under which the Underwriter will purchase the Bonds from the Authority. • Continuing Disclosure Certificate, to be executed by the City. SECTION 3. Negotiated Sale of Bonds. The City Council hereby approves the negotiated sale of the Bonds by the Authority to the Underwriter. The Bonds shall be sold pursuant to the terms and provisions of the Bond Purchase Agreement. The Bonds shall be sold at a true interest cost not to exceed 4.0 percent. The Underwriter's discount shall not exceed 1.0 percent. SECTION 4. Official Statement. The City Council hereby approves the preliminary Official Statement describing the Bonds in substantially the form on file with the City Clerk. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to said preliminary Official Statement and to execute an appropriate certificate stating the Authorized Officer's determination that the preliminary Official Statement (together with any changes therein or additions thereto) has been deemed nearly final within the meaning of Rule 15c2-12 of the Securities Exchange Act of 1934. Distribution of the preliminary Official Statement by the Underwriter is hereby approved. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to a final form of said Official Statement, and the execution thereof by an Authorized Officer shall be conclusive evidence of approval of any such changes and additions. The City Council hereby authorizes the distribution of the final Official Statement by the Underwriter. The final Official Statement shall be executed on behalf of the City by an Authorized Officer. SECTION 5. Official Actions. The Mayor, the City Manager, the Deputy City Manager and the City Attorney and all other officers of the City are each authorized and directed on behalf of the City to make any and all leases, assignments, certificates, requisitions, agreements (including an escrow deposit and trust agreement, if needed), notices, consents, instruments of conveyance or termination, warrants and other documents, which they or any of them deem necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution, and the City Manager may direct the City Clerk to execute and deliver such other documents as the City Manager determines are necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution. An Authorized Officer may revise -3- the identity of the Leased Property as necessary in order to accomplish the purposes of this Resolution. An Authorized Officer may approve the purchase of municipal bond insurance or a debt service reserve fund policy if the Authorized Officer, in consultation with the City's municipal advisor, concludes such purchase would be economically beneficial for the City. Whenever in this Resolution any officer of the City is authorized to execute or countersign any document or take any action, such execution, countersigning or action may be taken on behalf of such officer by any person designated by such officer to act on his or her behalf in the case such officer is absent or unavailable. SECTION 6. Effective Date. This Resolution shall take effect immediately upon its passage and adoption. Dated: March 2, 2022 I hereby certify that Resolution No. 2022-61 was passed and adopted by the City Council of the City of Lodi in a regular meeting held March 2, 2022 by the following votes: AYES: COUNCIL MEMBERS — Hothi, Khan, Kuehne, Nakanishi, and Mayor Chandler NOES: COUNCIL MEMBERS — None ABSENT: COUNCIL MEMBERS — None ABSTAIN: COUNCIL MEMBERS — None jw&.,,d6� MARK CHANDLER Mayor PAMELA M. FARRIS Assistant City Clerk 2022-61 -4- APPENDIX A Government Code Section 5852.1 Disclosure The good faith estimates set forth herein are provided with respect to the Bonds in accordance with California Government Code Section 5852.1. Such good faith estimates have been provided to the City and the Authority by the Underwriter of the Bonds. Principal Amount. The Underwriter has informed the City and the Authority that, based on the financing plan and current market conditions, its good faith estimate of the aggregate principal amount of the Bonds to be sold is $26,475,000 (the "Estimated Principal Amount"), which excludes net premium that might be generated in the sale under current market conditions. True Interest Cost of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the true interest cost of the Bonds, which means the rate necessary to discount the amounts payable on the respective principal and interest payment dates to the purchase price received for the Bonds, is 3.34%. Finance Charge of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the finance charge for the Bonds, which means the sum of all fees and charges paid to third parties (or costs associated with the Bonds), is $611,071. Such fees and charges include fees for bond and disclosure counsel, municipal advisor, special tax consultant, fiscal agent, rating agencies, City and Authority expenses, City Attorney and staff time related to bond issuance, printing, and underwriting. Amount of Proceeds to be Received. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the amount of proceeds expected to be received for sale of the Bonds, less the finance charge of the Bonds, as estimated above, and any reserves or capitalized interest paid or funded with proceeds of the Bonds, is $28,330,255. Total Payment Amount. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the total payment amount, which means the sum total of all payments that the Authority will make to pay debt service on the Bonds, plus the finance charge for the Bonds, as described above, not paid with the proceeds of the Bonds, calculated to the final maturity of the Bonds, is $44,134,950. -5- The foregoing estimates constitute good faith estimates only. The actual principal amount of the Bonds issued and sold, the true interest cost thereof, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates, (b) the actual principal amount of Bonds sold being different from the Estimated Principal Amount, (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates, (d) the actual market interest rates at the time of sale of the Bonds being different than those estimated for purposes of such estimates, (e) other market conditions, or (f) alterations in the financing plan, delays in the financing, or a combination of such factors. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on the timing of the need for proceeds of the Bonds and other factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. 10 RESOLUTION NO. LPFA2022-03 A RESOLUTION OF THE LODI PUBLIC FINANCING AUTHORITY AUTHORIZING THE ISSUANCE AND SALE OF LEASE REVENUE BONDS TO REFINANCE OUTSTANDING LEASE REVENUE BONDS AND PROVIDE FINANCING FOR ACQUISITION AND CONSTRUCTION OF CAPITAL IMPROVEMENTS, INCLUDING AN ANIMAL SHELTER AND PARKS AND PLAYGROUND IMPROVEMENTS AND UPGRADES, AND APPROVING RELATED DOCUMENTS AND OFFICIAL ACTIONS WHEREAS, the Lodi Public Financing Authority (the "Authority") previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City of Lodi (the "City"); and WHEREAS, in connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum; and WHEREAS, in order to take advantage of prevailing bond market conditions, the City wishes to authorize the refinancing of the 2012 Bonds; and WHEREAS, the City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including a new animal shelter and park and playground improvements and upgrades (the "Project"); and WHEREAS, to that end, the City has proposed to lease the land and improvements constituting the City's police building and its Fire Station #2 (the "Leased Property") to the Authority under a Site Lease, the form of which is on file with the Secretary, in consideration of the payment by the Authority of an upfront rental payment which is sufficient to provide funds to refinance the 2012 Bonds and finance the acquisition and construction of the Project; and WHEREAS, in order to raise funds for the upfront rental payment, the Authority proposes to issue and sell its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) (the "Bonds") under Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California, commencing with Section 6584 of said Code (the "Bond Law"); and WHEREAS, in order to secure the payments of principal of and interest on the Bonds, the Authority proposes to lease the Leased Property back to the City under a Lease Agreement (the "Lease Agreement"), the form of which is on file with the Secretary, under which the City is obligated to pay semiannual lease payments as rental for the Leased Property, and the Authority will assign substantially all of its rights under the Lease Agreement to U.S. Bank Trust Company, National Association, as trustee for the Bonds; and WHEREAS, there has been submitted to the Board of Directors a form of preliminary Official Statement in connection with the marketing of the Bonds and the Board of Directors, with the aid of its staff, has reviewed the preliminary Official Statement to assure proper disclosure of all material facts relating to the Bonds that are in the personal knowledge of the members of the Board of Directors; and WHEREAS, the Authority and the City propose to sell the Bonds to Piper Sandler & Co. (the "Underwriter") pursuant to a Bond Purchase Agreement (the "Bond Purchase Agreement"), the form of which is on file with the Secretary; and WHEREAS, as a condition precedent to the issuance by the Authority of the Bonds to provide financing for the Project, Section 6586.5 of the Bond Law requires that the City approve the proposed lease financing by the Authority and that the City make certain findings with respect to such financing, and Section 6586.5 further requires that such approval be given and findings be made only after a noticed public hearing; and WHEREAS, as required by Section 6586.5 of the Bond Law, the City has caused publication of a notice of a public hearing on the financing of the Project once at least five days prior to the hearing in a newspaper of general circulation in the City; and WHEREAS, the City Council held a public hearing at which all interested persons were provided the opportunity to speak on the subject of financing the Project; and WHEREAS, in accordance with Government Code Section 5852. 1, the Board of Directors has obtained and wishes to disclose the information set forth in Appendix A hereto; and WHEREAS, the Board of Directors wishes at this time to approve all proceedings to which it is a party relating to the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project; NOW, THEREFORE, BE IT RESOLVED by the Board of Directors of the Lodi Public Financing Authority as follows: SECTION 1. Issuance of Bonds. The Board of Directors hereby authorizes the issuance of the Bonds under the Bond Law in the maximum principal amount of $30,000,000, for the purpose of providing funds to refinance the 2012 Bonds and finance the Project. The Bonds shall be issued under the Bond Law and the Indenture of Trust that is approved below. SECTION 2. Approval of Related Financing Agreements. The Board of Directors hereby approves each of the following agreements required for the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project, in substantially the respective forms on file with the Secretary together with any changes therein or additions thereto deemed advisable by the Executive Director, the Treasurer or the General Counsel (each, an "Authorized Officer"), whose execution thereof shall be conclusive evidence of the approval of any such changes or additions. An Authorized Officer is hereby authorized and directed for and on behalf of the Authority to execute, and the Secretary is hereby authorized and directed to attest, the final form of each such agreement, as follows: • Indenture of Trust, between the Authority and U.S. Bank National Association, as trustee (the "Trustee"), setting forth the terms and provisions relating to the Bonds. • Site Lease, between the City as lessor and the Authority as lessee, under which the City leases the Leased Property to the Authority in consideration of -2- the payment of an amount which will be applied by the City to refinance the 2012 Bonds and finance the Project. • Lease Agreement, between the Authority as lessor and the City as lessee, under which the Authority leases the Leased Property back to the City and the City agrees to pay semiannual lease payments which are sufficient to provide revenues with which to pay principal of and interest on the Bonds when due. • Assignment Agreement, between the Authority and the Trustee, whereby the Authority assigns certain of its rights under the Lease Agreement to the Trustee for the benefit of the Refunding Bond owners. • Bond Purchase Agreement, among the City, the Authority and the Underwriter, which establishes the terms under which the Underwriter will purchase the Bonds from the Authority. • Irrevocable Refunding Instructions, to be given by the Authority to the trustee for the 2012 Bonds, and to be consented to by the City, providing for the deposit, investment and application of funds to defease and redeem the 2012 Bonds. SECTION 3. Negotiated Sale of Bonds. The Board of Directors hereby authorizes and directs the negotiated sale of the Bonds to the Underwriter. The Bonds shall be sold at a true interest cost not to exceed 4.0 percent. The Underwriter's discount shall not exceed 1.0 percent. SECTION 4. Official Statement. The Board of Directors hereby approves the preliminary Official Statement describing the Bonds in substantially the form on file with the Secretary. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to said preliminary Official Statement and to execute an appropriate certificate stating the Authorized Officer's determination that the preliminary Official Statement (together with any changes therein or additions thereto) has been deemed nearly final within the meaning of Rule 15c2-12 of the Securities Exchange Act of 1934. Distribution of the preliminary Official Statement by the Underwriter is hereby approved. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to a final form of said Official Statement, and the execution thereof by an Authorized Officer shall be conclusive evidence of approval of any such changes and additions. The Board of Directors hereby authorizes the distribution of the final Official Statement by the Underwriter. The final Official Statement shall be executed on behalf of the Authority by an Adthorized Officer. SECTION 5. Official Actions. The Chair, the Executive Director, the Treasurer, the General Counsel and all other officers of the Authority are each authorized and directed on behalf of the Authority to make any and all assignments, certificates, requisitions, agreements (including an escrow deposit and trust agreement, if needed), notices, consents, instruments of conveyance and other documents, which they or any of them deem necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution, and the Executive Director may direct the Secretary to execute and deliver such other documents as the Executive Director determines are necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution. An Authorized Officer may revise the identity of the Leased -3- Property as necessary in order to accomplish the purposes of this Resolution. An Authorized Officer may approve the purchase of municipal bond insurance or a debt service reserve fund policy if the Authorized Officer, in consultation with the City's municipal advisor, concludes such purchase would be economically beneficial for the City. Whenever in this resolution any officer of the Authority is authorized to execute or countersign any document or take any action, such execution, countersigning or action may be taken on behalf of such officer by any person designated by such officer to act on his or her behalf if such officer is absent or unavailable. SECTION 6. Effective Date. This Resolution shall take effect immediately upon its passage and adoption. Dated: March 2, 2022 I hereby certify that Resolution No. 2022-03 was passed and adopted by the City Council of the City of Lodi in a regular meeting held March 2, 2022 by the following votes: AYES BOARD MEMBERS — Hothi, Khan, Kuehne, Nakanishi, and Chairperson Chandler NOES: BOARD MEMBERS — None ABSENT: BOARD MEMBERS — None ABSTAIN: BOARD MEMBERS — None MARK CHANDLER Chairperson PAMELA M. FARRIS Secretary LPFA2022-03 -4- APPENDIX A Government Code Section 5852.1 Disclosure The good faith estimates set forth herein are provided with respect to the Bonds in accordance with California Government Code Section 5852.1. Such good faith estimates have been provided to the City and the Authority by the Underwriter of the Bonds. Principal Amount. The Underwriter has informed the City and the Authority that, based on the financing plan and current market conditions, its good faith estimate of the aggregate principal amount of the Bonds to be sold is $26,475,000 (the "Estimated Principal Amount"), which excludes net premium that might be generated in the sale under current market conditions. True Interest Cost of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the true interest cost of the Bonds, which means the rate necessary to discount the amounts payable on the respective principal and interest payment dates to the purchase price received for the Bonds, is 3.34%. Finance Charge of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the finance charge for the Bonds, which means the sum of all fees and charges paid to third parties (or costs associated with the Bonds), is $611,071. Such fees and charges include fees for bond and disclosure counsel, municipal advisor, special tax consultant, fiscal agent, rating agencies, City and Authority expenses, City Attorney and staff time related to bond issuance, printing, and underwriting. Amount of Proceeds to be Received. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the amount of proceeds expected to be received for sale of the Bonds, less the finance charge of the Bonds, as estimated above, and any reserves or capitalized interest paid or funded with proceeds of the Bonds, is $28,330,255. Total Payment Amount. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the total payment amount, which means the sum total of all payments that the Authority will make to pay debt service on the Bonds, plus the finance charge for the Bonds, as described above, not paid with the proceeds of the Bonds, calculated to the final maturity of the Bonds, is $44,134,950. The foregoing estimates constitute good faith estimates only. The actual principal amount of the Bonds issued and sold, the true interest cost thereof, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates, (b) the actual principal amount of Bonds sold being different from the Estimated Principal Amount, (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates, (d) the actual market interest rates at the time of sale of the Bonds being different than those estimated for purposes of such estimates, (e) other market conditions, or (f) alterations in the financing plan, delays in the financing, or a combination of such factors. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on the timing of the need for proceeds of the Bonds and other factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. A-2 a N a (6 O � m 3 0 o .0 i •� p O 6� a" o O i y N -Q o o � c @ E N (1)Q -- 4-- Ct) c c 0 Q)O� ami c m coEm Z a o o .� o gL o h O 0 U w,0� � m N C a Et h i y N U t t6 O ,U �a0,c � � o G I U •co i a o � � o m EQT to a 'to 0 m •0 c > ` Q)a0Z CO N N E w 0 m 0 w 'm C U > vO � c •� QL o 0 c PRELIMINARY OFFICIAL STATEMENT DATED , 2022 NEW ISSUE - FULL BOOK -ENTRY RATING: Standard & Poor's: " " See "RATING" herein. In the opinion of Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel, subject, however to certain qualifications described herein, under existing law, the interest on the Bonds is excluded from gross income for federal income tax purposes and such interest is not an item of tax preference for purposes of the federal alternative minimum tax. In the further opinion of Bond Counsel, such interest is exempt from California personal income taxes. See "TAX MATTERS. " Dated: Date of Delivery P LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE BONDS (2012 Refunding; Capital Projects Financing) Due: October 1, as shown on inside cover Authority for Issuance. The bonds captioned above (the "Bonds") are being issued by the Lodi Public Financing Authority (the "Authority") under a resolution adopted by the Board of Directors of the Authority on March 2, 2022 by the Board of Directors of the Authority and an Indenture of Trust dated as of March 1, 2022 (the "Indenture") by and between the Authority and U.S. Bank Trust Company, National Association, as trustee for the Bonds (the "Trustee"). See "THE BONDS — Authority for Issuance." Purpose. The Bonds are being issued primarily to (i) refund the outstanding amount of the Authority's $19,080,000 original principal amount of 2012 Refunding Lease Revenue Bonds and the City's related lease payment obligation and (ii) finance the acquisition and construction of capital improvements of the City, including a new animal shelter and parks and playground improvements and upgrades. In addition, the proceeds of the Bonds will be used to [(i) fund a reserve fund for the Bonds, including, if elected by the Authority, to pay the premium for a debt service reserve policy, (ii) if elected by the Authority, pay the premium for a municipal bond insurance policy, and] (iii) pay the costs of issuing the Bonds. See "FINANCING PLAN." Security. Under the Indenture, the Bonds will be payable solely from and secured by Revenues and certain funds and accounts held under the Indenture. Revenues consist primarily of lease payments ("Lease Payments") to be made by the City pursuant to a Lease Agreement, dated as of March 1, 2022 (the "Lease"), by and between the Authority and the City, for the leasing of certain real property. Under the Lease, the City covenants to take such actions as necessary to include the Lease Payments in its annual budgets and to make all necessary appropriations for such Lease Payments (subject to abatement under certain circumstances as described in this Official Statement). The Authority is considering the use of a municipal bond insurance policy that guarantees the scheduled payment of principal of and interest on all or a portion of the Bonds when due and a debt service reserve policy guaranteeing certain payments. The Authority will decide whether or not to utilize a municipal bond insurance policy or a debt service reserve policy depending on market conditions at the time of sale of the Bonds. See "SECURITY FOR THE BONDS." Book -Entry Only. The Bonds will be issued in book -entry form only, and will be initially issued and registered in the name of Cede & Co. as nominee of The Depository Trust Company, New York, New York ("DTC"). The Bonds are issuable as fully registered securities in denominations of $5,000 or any integral multiple of $5,000. Purchasers of the Bonds (the "Beneficial Owners") will not receive physical certificates representing their interest in the Bonds. See "THE BONDS" and "APPENDIX F - DTC AND THE BOOK -ENTRY ONLY SYSTEM." Payments. Interest on the Bonds accrues from the date of delivery and is payable semiannually on April 1 and October 1 of each year, commencing October 1, 2022. Payments of principal and interest on the Bonds will be paid by the Trustee to DTC for subsequent disbursement to DTC Participants, which will remit such payments to the Beneficial Owners of the Bonds. See "THE BONDS - General Provisions." Redemption. The Bonds are subject to optional redemption, mandatory sinking fund payment redemption and special mandatory redemption from insurance or condemnation proceeds prior to maturity. See "THE BONDS — Redemption." NEITHER THE BONDS, NOR THE OBLIGATION OF THE AUTHORITY TO PAY PRINCIPAL OF OR INTEREST THEREON, NOR THE OBLIGATION OF THE CITY TO MAKE THE LEASE PAYMENTS, CONSTITUTE A DEBT OR A LIABILITY OF THE AUTHORITY, THE CITY, THE STATE OF CALIFORNIA OR ANY OF ITS POLITICAL SUBDIVISIONS WITHIN THE MEANING OF ANY CONSTITUTIONAL LIMITATION ON INDEBTEDNESS, OR A PLEDGE OF THE FULL FAITH AND CREDIT OF THE CITY. THE BONDS ARE SECURED SOLELY BY THE PLEDGE OF REVENUES AND CERTAIN FUNDS HELD UNDER THE INDENTURE. THE BONDS ARE NOT SECURED BY A PLEDGE OF THE TAXING POWER OF THE CITY. MATURITY SCHEDULE (see inside cover) Cover Page. This cover page contains certain information for general reference only. It is not a summary of all the provisions of the Bonds. Prospective investors must read the entire Official Statement to obtain information essential to making an informed investment decision. The Bonds are offered when, as and if issued and accepted by the Underwriter, subject to approval as to their legality by Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel, and subject to certain other conditions. Certain legal matters will also be passed upon for the Authority and the City by Jones Hall, A Professional Law Corporation, as Disclosure Counsel. Certain legal matters will be passed upon for the City by the City Attorney. Kutak Rock LLP, Irvine, California, is serving as counsel to the Underwriter. It is anticipated that the Bonds will be delivered in book -entry form through the facilities of DTC on or about April- 2022. [Piper Sandler Logo] The date of this Official Statement is: , 2022. Preliminary; subject to change. LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE BONDS (2012 Refunding; Capital Projects Financing) MATURITY SCHEDULE* (Base CUSIP:t ) $ Serial Bonds Maturity Date Principal Interest (October 1) Amount Rate Yield $ _% Term Bond Due October 1, , Yield _%, Price % Term Bond Due October 1, , Yield %, Price Price CUSIPt %, CUSIPt: %, CUSIPt: * Preliminary; subject to change. t CUSIP Copyright 2022, CUSIP Global Services, and a registered trademark of American Bankers Association. CUSIP data herein is provided by CUSIP Global Services, which is managed on behalf of American Bankers Association by S&P Capital IQ. None of the Authority, the City nor the Underwriter takes any responsibility for the accuracy of the CUSIP data. LODI PUBLIC FINANCING AUTHORITY CITY OF LODI AUTHORITY BOARD/CITY COUNCIL Mark Chandler, Mayor/Member Mikey Hothi, Mayor Pro Tem/Member Alan Nakanishi, Council Member/Member Doug Kuehne, Councilmember/Member Shak Khan, Councilmember/ Member AUTHORITY/CITY OFFICIALS Stephen Schwabauer, City Manager/Executive Director Andrew Keys, Deputy City Manager/Treasurer Janice D. Magdich, City Attorney/Authority Counsel Charles Swimley, Public Works Director BOND COUNSEL Jones Hall, A Professional Law Corporation San Francisco, California MUNICIPAL ADVISOR Fieldman, Rolapp & Associates, Inc. Irvine, California TRUSTEE U.S. Bank Trust Company, National Association San Francisco, California GENERAL INFORMATION ABOUT THIS OFFICIAL STATEMENT No Offering May Be Made Except by this Official Statement. No dealer, broker, salesperson or other person has been authorized to give any information or to make any representations with respect to the 2022 Bonds other than as contained in this Official Statement, and if given or made, such other information or representation must not be relied upon as having been authorized. No Unlawful Offers or Solicitations. This Official Statement does not constitute an offer to sell or the solicitation of an offer to buy in any state in which such offer or solicitation is not authorized or in which the person making such offer or solicitation is not qualified to do so or to any person to whom it is unlawful to make such offer or solicitation. Effective Date. This Official Statement speaks only as of its date, and the information and expressions of opinion contained in this Official Statement are subject to change without notice. Neither the delivery of this Official Statement nor any sale of the 2022 Bonds will, under any circumstances, create any implication that there has been no change in the affairs of the City, the Authority, or any other parties described in this Official Statement. Use of this Official Statement. This Official Statement is submitted in connection with the sale of the 2022 Bonds referred to in this Official Statement and may not be reproduced or used, in whole or in part, for any other purpose. This Official Statement is not a contract with the purchasers of the 2022 Bonds. Preparation of this Official Statement. The information contained in this Official Statement has been obtained from sources that are believed to be reliable, but this information is not guaranteed as to accuracy or completeness. The Underwriter has provided the following sentence for inclusion in this Official Statement: The Underwriter has reviewed the information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction, but the Underwriter does not guarantee the accuracy or completeness of such information. Document References and Summaries. All references to and summaries of the Indenture, the Lease, the Site Lease, or other documents contained in this Official Statement are subject to the provisions of those documents and do not purport to be complete statements of those documents. Bonds are Exempt from Securities Laws Registration. The issuance and sale of the Bonds have not been registered under the Securities Act of 1933, as amended (the "Securities Act'), or the Securities Exchange Act of 1934, as amended (the "Securities Exchange Act'), in reliance upon exemptions for the issuance and sale of municipal securities provided under Section 3(a)(2) of the Securities Act and Section 3(a)(12) of the Securities Exchange Act. Stabilization of Prices. In connection with this offering, the Underwriter may overallot or effect transactions which stabilize or maintain the market price of the Bonds at a level above that which might otherwise prevail in the open market. Such stabilizing, if commenced, may be discontinued at any time. The Underwriter may offer and sell the 2022 Bonds to certain dealers and others at prices lower than the public offering prices set forth on the cover page hereof and said public offering prices may be changed from time to time by the Underwriter. Estimates and Projections. Certain statements included or incorporated by reference in this Official Statement constitute "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995, Section 21E of the Securities Exchange Act and Section 27A of the Securities Act. Such statements are generally identifiable by the terminology used such as "plan," "expect," "estimate," "budget' or other similar words. THE ACHIEVEMENT OF CERTAIN RESULTS OR OTHER EXPECTATIONS CONTAINED IN SUCH FORWARD-LOOKING STATEMENTS INVOLVE KNOWN AND UNKNOWN RISKS, UNCERTAINTIES AND OTHER FACTORS WHICH MAY CAUSE ACTUAL RESULTS, PERFORMANCE OR ACHIEVEMENTS DESCRIBED TO BE MATERIALLY DIFFERENT FROM ANY FUTURE RESULTS, PERFORMANCE OR ACHIEVEMENTS EXPRESSED OR IMPLIED BY SUCH FORWARD-LOOKING STATEMENTS. NEITHER THE CITY NOR THE AUTHORITY PLAN TO ISSUE ANY UPDATES OR REVISIONS TO THOSE FORWARD-LOOKING STATEMENTS IF OR WHEN THEIR EXPECTATIONS, OR EVENTS, CONDITIONS OR CIRCUMSTANCES ON WHICH SUCH STATEMENTS ARE BASED OCCUR. Website. The City maintains a website; however, the information presented on the website is not a part of this Official Statement and should not be relied upon in making an investment decision with respect to the 2022 Bonds. TABLE OF CONTENTS INTRODUCTION Error! Bookmark not defined. Estimated Direct and Overlapping THE REFINANCING PLANError! Bookmark not defined. Debt ..... Error! Bookmark not defined. Refunding of 2012 BondsError! Bookmark not dMNCff..ITUTIONAL AND STATUTORY The ProjectError! Bookmark not defined. LIMITATIONS ON TAXES AND Estimated Sources and Uses APPROPRIATIONSErrod Bookmark not defined. of Funds Error! Bookmark not defined. Article XIIIA of the State Constitution Error! Bookmark ni THE LEASED PROPERTYError! Bookmark not defined. Legislation Implementing Article XIIIAError! Bookmark r Description Error! Bookmark not defined. Articles XIIB of the State Constitution Error! Bookmark n Modifications of Leased PropertyError! Bookmark not dAfiiu& XIIIC and XIIID of the State SubstitutionError! Bookmark not defined. Constitution Error! Bookmark not defined. Release of Leased PropertyError! Bookmark not defineftoposition 62Error! Bookmark not defined. THE BONDS Proposition 1A; Proposition 22Error! Bookmark not defi Authority for IssuanceError! Bookmark not defined. Possible Future Initiatives Error! Bookmark not defined. General Provisions Error! Bookmark not definedRISK FACTORS Error! Bookmark not defined. Transfer, Registration and ExchangeError! Bookmark nWdefM&hligations of the AuthorityError! Bookmark not RedemptionError! Bookmark not defined. No Pledge of TaxesError! Bookmark not defined. Book -Entry Only SystemsError! Bookmark not defined.Limitations on Taxes and FeesError! Bookmark not def SECURITY FOR THE BONDSError! Bookmark not defined. Additional Obligations of the CityError! Bookmark not d Pledge of RevenuesError! Bookmark not defined. Default... Error! Bookmark not defined. Lease Payments; Covenant to AbatementError! Bookmark not defined. AppropriateError! Bookmark not defined. Natural CalamitiesError! Bookmark not defined. AbatementError! Bookmark not defined. Public Health Emergencies Error! Bookmark not define Insurance; Condemnation Error! Bookmark not defined.Limitations on Remedies Available to RemediesError! Bookmark not defined. Bond OwnersError! Bookmark not defined. THE AUTHORITYError! Bookmark not defined. Loss of Tax ExemptionError! Bookmark not defined. THE CITY CybersecurityError! Bookmark not defined. General..Error! Bookmark not defined. IRS Audit of Tax -Exempt Bond Governance and ManagementError! Bookmark not defilisedes.... Error! Bookmark not defined. Public Health Emergency - Secondary Market for BondsError! Bookmark not defin COVID 19Error! Bookmark not defined. TAX MATTERS.. Error! Bookmark not defined. CITY FINANCIAL INFORMATIONErrod Bookmark not (W1hT3dLN LEGAL MATTERSError! Bookmark not defined. City BudgetError! Bookmark not defined. LITIGATION ....... Error! Bookmark not defined. Financial Policies SummaryError! Bookmark noIFkMhh6tkL STATEMENTS Error! Bookmark not defined. Financial Statements Error! Bookmark not defirMdTING ............. Error! Bookmark not defined. Major Tax RevenuesError! Bookmark not defin@@NTINUING DISCLOSUREError! Bookmark not defined. Outstanding General Fund Debt and MUNICIPAL ADVISORError! Bookmark not defined. Lease ObligationsError! Bookmark not definedUNDERWRITINGError! Bookmark not defined. Employee RelationsError! Bookmark not definVROFESSIONAL SERVICESError! Bookmark not defined. Retirement System Error! Bookmark not defined. Other Post -Employment BenefitsError! BookmaWy"t&bQ4d:---Error! Bookmark not defined. City InvestmentsError! Bookmark not defined. APPENDIX A — GENERAL INFORMATION ABOUT THE CITY OF LODI AND SAN JOAQUIN COUNTY....................................................................................................................................................A-1 APPENDIX B — AUDITED FINANCIAL STATEMENTS OF THE CITY FOR THE FISCAL YEAR ENDED JUNE 30, 2021................................................................................................B-1 APPENDIX C — SUMMARY OF PRINCIPAL LEGAL DOCUMENTS....................................................... C-1 APPENDIX D — FORM OF OPINION OF BOND COUNSEL................................................................... D-1 APPENDIX E — FORM OF CONTINUING DISCLOSURE CERTIFICATE................................................E-1 APPENDIX F — DTC AND THE BOOK -ENTRY ONLY SYSTEM..............................................................F-1 OFFICIAL STATEMENT LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE BONDS (2012 Refunding; Capital Projects Financing) INTRODUCTION This introduction is not a summary of this Official Statement. It is only a brief description of and guide to, and is qualified by, more complete and detailed information contained in the entire Official Statement, including the cover page and appendices, and the documents summarized or described in this Official Statement. A full review should be made of the entire Official Statement. The offering to potential investors is made only by means of the entire Official Statement. Capitalized terms used but not defined in this Official Statement have the meanings set forth in the Indenture (as defined below). See "APPENDIX C — Summary of Principal Legal Documents." Authority for Issuance. The Lodi Public Financing Authority (the "Authority") is issuing its 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) (the "Bonds") under the following legal authority: (a) Article 4 of Chapter 5 of Division 7 of Title 1 of the Government Code of the State of California, commencing with Section 6584 (the "Bond Law"), (b) a resolution adopted by the Board of Directors (the "Board") of the Authority on March 2, 2022 (the "Authority Resolution"), and a resolution adopted by the City Council (the "City Council") of the City of Lodi (the "City") on March 2, 2022 (the "City Resolution"), and (c) an Indenture of Trust (the "Indenture"), dated as of March 1, 2022, by and between the Authority and U.S. Bank Trust Company, National Association, as trustee (the "Trustee"). Form of Bonds; Book -Entry Only. The Bonds will be issued in fully registered form, registered in the name of The Depository Trust Company, New York, New York ("DTC"), or its nominee, which will act as securities depository for the Bonds. Purchasers of the Bonds will not receive certificates representing the Bonds that are purchased. See "THE BONDS - Book -Entry Only System" and "APPENDIX F — DTC AND THE BOOK -ENTRY ONLY SYSTEM." Purpose of the Bonds. The Bonds are being issued to provide funds to (i) refund the $13,315,000 outstanding principal amount of the Authority's 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") and the City's related lease payment obligation; (ii) finance the acquisition and construction of capital improvements of the City, including a new animal shelter and parks and playground improvements and upgrades (the "Project"); [(iii) fund a reserve fund for the Bonds, including, if elected by the Authority, to pay the premium for a debt service * Preliminary; subject to change. reserve policy guaranteeing certain payments, (iv) if elected by the Authority, pay the premium for a municipal bond insurance policy; and] (v) pay the costs of issuing the Bonds. Security for the Bonds and Pledge of Revenues. The Bonds will be payable solely from and secured by Revenues and certain funds and accounts held under the Indenture. Revenues consist primarily of Lease Payments to be made by the City pursuant to a Lease Agreement, dated as of March 1, 2022, between the City and the Authority (the "Lease"). See "THE LEASED PROPERTY." Under the Lease, the City covenants to take such action as necessary to include the Lease Payments in its annual budgets and to make all necessary appropriations for such Lease Payments (subject to abatement under certain circumstances described in the Lease). See "SECURITY FOR THE BONDS." The scheduled Lease Payments payable by the City under the Lease are calculated to be sufficient to permit the Authority to pay the principal of, and interest on, the Bonds when due. However, in the event of any damage or destruction such that there is substantial interference with the use and occupancy of all or any portion of the Leased Property, or a temporary taking of the Leased Property or a permanent taking of a portion of the Leased Property, Lease Payments may be abated under the Lease without constituting a default. See "SECURITY FOR THE BONDS — Abatement" and "RISK FACTORS — Abatement." However, proceeds of insurance may be available to pay Lease Payments in the event of insured damage, destruction or condemnation with respect to the Leased Premises. Pursuant to an Assignment Agreement, dated as of March 1, 2022 (the "Assignment Agreement"), by and between the Authority and the Trustee, the Authority has assigned to the Trustee for the benefit of the Owners of the Bonds, certain of the Authority's rights under the Lease, including its rights to receive Lease Payments and to enforce remedies in the event of a default by the City for the purpose of securing the payment of debt service on the Bonds. Potential Bond Insurance; Potential Reserve Fund. The Authority is considering the use of a municipal bond insurance policy that guarantees the scheduled payment of principal of and interest on all or a portion of the Bonds when due. The Authority will decide whether or not to utilize a municipal bond insurance policy depending on market conditions at the time of sale of the Bonds. The Authority is also considering the use of a reserve fund policy that guarantees certain payments, subject to the terms and conditions to be set forth therein. The Authority will decide whether or not to utilize a reserve fund policy depending on market conditions at the time of sale of the Bonds. No Additional Parity Obligations. Under the Indenture, the Authority covenants that no additional bonds, notes or other indebtedness shall be issued or incurred which are payable out of the Revenues in whole or in part. The Lease does not prohibit the City from entering into other obligations payable from the General Fund of the City. Redemption. The Bonds are subject to redemption prior to their stated maturity dates. See "THE BONDS - Redemption." Abatement. The Lease provides that the obligation of the City to pay Lease Payments will be subject to abatement by reason of (i) any damage or destruction such that there is substantial interference with the use and occupancy of all or any portion of the Leased Property, (ii) prior to the issuance of a certificate of occupancy for the project, if it constitutes all or a portion of the Leased Property, there is substantial interference with the use and occupancy by the City of the Leased Property or any portion thereof, provided that there will be no such 2 abatement to the extent that any capitalized interest is available to pay Lease Payments which would otherwise be abated, or (iii) a temporary taking of the Leased Property or a permanent taking of a portion of the Leased Property. However, to the extent proceeds of rental interruption insurance are available with respect to the Bonds (as described below), Lease Payments (or a portion thereof) may be made from that source. See "SECURITY FOR THE BONDS - Abatement" and "RISK FACTORS - Abatement." Risks of Investment. The Bonds are repayable primarily from Lease Payments and other amounts payable by the City under the Lease. For a discussion of some of the risks associated with the purchase of the Bonds, see "RISK FACTORS." NEITHER THE BONDS, THE OBLIGATION OF THE AUTHORITY TO PAY PRINCIPAL OF OR INTEREST ON THE BONDS, NOR THE OBLIGATION OF THE CITY TO MAKE THE LEASE PAYMENTS, CONSTITUTES A DEBT OR A LIABILITY OF THE AUTHORITY, THE CITY, THE STATE OF CALIFORNIA OR ANY OF ITS POLITICAL SUBDIVISIONS WITHIN THE MEANING OF ANY CONSTITUTIONAL LIMITATION ON INDEBTEDNESS, OR A PLEDGE OF THE FULL FAITH AND CREDIT OF THE CITY. THE BONDS ARE SECURED SOLELY BY THE PLEDGE OF REVENUES AND CERTAIN FUNDS HELD UNDER THE INDENTURE. THE BONDS ARE NOT SECURED BY A PLEDGE OF THE TAXING POWER OF THE CITY. THE AUTHORITY HAS NO TAXING POWER. THE FINANCING PLAN Refunding of 2012 Bonds A portion of the proceeds of the Bonds are being issued to provide funds to refund the 2012 Bonds and the City's related lease payment obligation. The Authority issued the 2012 Bonds pursuant to an Indenture of Trust, dated as of September 1, 2012 (the "2012 Indenture"), by and between the Authority and U.S. Bank Trust Company, National Association, as successor to U.S. Bank National Association, as trustee (the "2012 Trustee"), for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City. 3 The currently outstanding 2012 Bonds consist of the following: 2012 Refunding Lease Revenue Bonds Base CUSIPt Number: 540259 Maturity Date Principal CUSIP (October 1) Amount Numbers Redemption Date 2022 $1,065,000 AG3 _/_2022 2023 1,120,000 AH 1 _/_2022 2026 3,720,000 AK4 _/_2022 2031 7,410,000 AJ7 /2022 Upon the issuance of the Bonds, pursuant to Irrevocable Refunding Instructions given by the Authority to the 2012 Trustee, a portion of the proceeds of the Bonds and other available moneys with respect to the 2012 Bonds shall be transferred to the 2012 Trustee for deposit in the redemption fund established and held by the 2012 Trustee under the 2012 Indenture (the "Redemption Fund"). The 2012 Trustee will use the funds available in the Redemption Fund to pay accrued interest on the 2012 Bonds to April , 2022 (the "Redemption Date") and redeem the remaining outstanding 2012 Bonds on the Redemption Date, without premium. The amounts held in the Redemption Fund are pledged solely to the payment of the 2012 Bonds. Neither the funds deposited in the Redemption Fund nor any interest thereon will be available for the payment of debt service on the Bonds. The Project A portion of the proceeds of the Bonds is expected to be used to finance the costs of acquisition and construction of a new animal shelter for the City, parks and playground improvements and upgrades, and other capital improvements of the City. The City began planning and design work for the new animal shelter in early 2022 and expects to commence construction in summer 2023. I CUSIP Copyright 2022, CUSIP Global Services, and a registered trademark of American Bankers Association. CUSIP data herein is provided by CUSIP Global Services, which is managed on behalf of American Bankers Association by S&P Capital IQ. None of the Authority, the City nor the Underwriter takes any responsibility for the accuracy of the CUSIP data. 4 Estimated Sources and Uses of Funds The estimated sources and uses of funds relating to the Bonds and available money relating to the 2012 Bonds are as follows: Sources of Funds: Principal Amount of Bonds Plus: [Net] Original Issue Premium Plus: Available Money Relating to the 2012 Bonds TOTAL SOURCES Uses of Funds: Redemption of 2012 Bonds Deposit to Project Fund Costs of Issuance 0) Underwriter's Discount TOTAL USES $ (1) Represents funds to be used to pay Costs of Issuance, which include legal fees, printing costs, Municipal Advisor fees, rating agency fees, premiums for any municipal bond insurance policy or debt service reserve policy, if obtained, and other costs of issuing the Bonds. THE LEASED PROPERTY Lease Payments will be made by the City under the Lease for the use and occupancy of the Leased Property, which is described in greater detail below. Description The Property being leased under the Lease (the "Leased Property") consists of (i) the real property and facilities comprising the Police Building and (ii) the real property and facilities comprising Fire Station #2. The Police Building, located at 215 West Elm Street, houses the Police department, the Lodi City jail and 7,648 square feet of space rented by the State of California for a Superior Court branch. Completed in 2003, the 52,500 square foot building sits on property that is approximately 1.01 acres and is part of the larger complex of buildings that comprise the downtown campus, including City Hall, the old public safety building and Carnegie Forum. The Police Building has an insured value of approximately $22 million. Fire Station #2, located at 2 South Cherokee Lane, is an approximately 2,100 square foot building built in 2015 with a replacement value of approximately $3.05 million. Modifications of Leased Property Under the Lease, the City will have the right during the term of the Lease to make additions, modifications and improvements to the Leased Property or any portion thereof. Such additions, modifications and improvements may not in any way damage the Leased Property, or cause the Leased Property to be used for purposes other than those authorized under the provisions of state and federal law; and the Leased Property, upon completion of any additions, modifications and improvements, must be of a value which is not substantially less than the value thereof immediately prior to the making of such additions, modifications and improvements. 5 Substitution Under the Lease, the City has the option at any time and from time to time, to substitute other real property (the "Substitute Property") for the Leased Property or any portion thereof (the "Former Property"), upon satisfaction of all of the requirements set forth in the Lease, which includes (among others) the following: No Event of Default under the Lease has occurred and is continuing. The City has obtained a CLTA policy of title insurance insuring the City's leasehold estate under the Lease in the Substitute Property, subject only to Permitted Encumbrances (as defined in the Lease), in an amount at least equal to the estimated value thereof. The City has certified in writing to the Authority and the Trustee that the Substitute Property serves the municipal purposes of the City and constitutes property which the City is permitted to lease under the laws of the State of California, and has been determined to be essential to the proper, efficient and economic operation of the City and to serve an essential governmental function of the City. The Substitute Property does not cause the City to violate any of its covenants, representations and warranties made herein. The City has filed with the Authority and the Trustee a written certificate of the City or other written evidencing stating that the useful life of the Substitute Property at least extends to the final maturity date of the Bonds, that the estimated value of the Leased Property, after substitution of the Substitute Property and release of the Former Property, is at least equal to the aggregate Outstanding principal amount of the Bonds, and the fair rental value of the Leased Property, after substitution of the Substitute Property and release of the Former Property, is at least equal to the Lease Payments thereafter coming due and payable under the Lease. The City has mailed written notice of the substitution to each rating agency that then maintains a rating on the Bonds. See "APPENDIX C — Summary of Principal Legal Documents." After a substitution, the Former Property will be released from the leasehold, as appropriate. The Authority and the City will also make any amendments needed to be made to the Lease, Site Lease and Assignment Agreement, and will enter into any necessary site or ground leases in connection with such substitution. Such amendments may be made without the consent of Bondowners. The City is not entitled to any reduction, diminution, extension or other modification of the Lease Payments as a result of a substitution. Release of Leased Property Under the Lease, the City has the option at any time and from time to time during the term of the Lease to release from the Lease any portion of the Leased Property; provided that 0 the City satisfies all of the requirements under the Lease that are conditions precedent to such removal, which include (among others) the following: No Event of Default under the Lease has occurred and is continuing. The City has certified in writing to the Authority and the Trustee that the value of the property which remains subject to the Lease following such release is at least equal to the aggregate Outstanding principal amount of the Bonds, and the fair rental value of the property which remains subject to the Lease following such release is at least equal to the Lease Payments thereafter coming due and payable. See "APPENDIX C - Summary of Principal Legal Documents." THE BONDS Authority for Issuance The Bonds are being issued under the Bond Law, the Authority Resolution (which was adopted by the Board of Directors of the Authority on March 2, 2022), the City Resolution (which was adopted by the City Council on March 2, 2022), and the Indenture. General Provisions Bond Terms. The Bonds will be dated their date of delivery and issued in fully registered form without coupons in integral multiples of $5,000. The Bonds will mature in the amounts and on the dates, and bear interest at the annual rates, set forth on the inside cover page of this Official Statement. Payments of Principal and Interest. Interest on the Bonds will be payable on April 1 and October 1 in each year, beginning October 1, 2022 (each an "Interest Payment Date"). Principal on the Bonds will be payable on October 1 in the amounts and in the years set forth on the inside front cover of this Official Statement. While the Bonds are subject to the book -entry system, the principal, interest and any prepayment premium with respect to the Bonds will be paid by the Trustee to DTC for subsequent disbursement to beneficial owners of the Bonds. See APPENDIX F — "DTC AND THE BOOK -ENTRY ONLY SYSTEM." Interest on the Bonds is payable from the Interest Payment Date next preceding the date of authentication thereof unless: a Bond is authenticated on or before an Interest Payment Date and after the close of business on the preceding Record Date, in which event it will bear interest from such Interest Payment Date, a Bond is authenticated on or before the first Record Date, in which event interest thereon will be payable from the Closing Date, or 7 • interest on any Bond is in default as of the date of authentication thereof, in which event interest thereon will be payable from the date to which interest has been paid in full, payable on each Interest Payment Date. Principal and premium, if any, with respect to each Bond is payable upon surrender of such Bond at the Office of the Trustee in St. Paul, Minnesota, upon maturity or the earlier redemption thereof. The principal of, premium, if any, and interest on the Bonds will be payable in lawful money of the United States of America. Interest with respect to the Bonds will be computed on the basis of a 360 day year composed of twelve 30 -day months. Transfer, Registration and Exchange See "APPENDIX C - Summary of Principal Legal Documents" for a description of the provisions of the Indenture relating to the transfer, registration and exchange of the Bonds. Redemption' Optional Redemption. The Bonds maturing on or before October 1, 20 are not subject to optional redemption prior to their stated maturity. The Bonds maturing on or after October 1, 20 are subject to redemption, as a whole or in part at the election of the Authority among maturities on such basis as designated by the Authority and by lot within a maturity, at the option of the Authority, on April 1, 20 and on any date thereafter, at a redemption price equal to 100% of the principal amount of Bonds to be redeemed, together with accrued interest thereon to the date fixed for redemption, without premium. Special Mandatory Redemption From Insurance or Condemnation Proceeds. The Bonds are subject to redemption as a whole, or in part on a pro rata basis among maturities, on any date, from any Net Proceeds of insurance or an eminent domain award with respect to the Leased Property which are not applied to repair, rebuild or replace the Leased Property as provided in the Indenture, at a redemption price equal to 100% of the principal amount to be redeemed plus interest accrued thereon to the date fixed for redemption, without premium. Mandatory Sinking Fund Redemption. The Term Bonds are subject to mandatory redemption in part by lot, at a redemption price equal to 100% of the principal amount thereof to be redeemed, without premium, in the aggregate respective principal amounts and on October 1 in the respective years as set forth in the following tables; provided, however, that if some but not all of the Term Bonds have been redeemed pursuant to an optional redemption or special mandatory redemption from insurance or condemnation proceeds, the total amount of all future sinking fund payments shall be reduced by the aggregate principal amount of the Term Bonds so redeemed, to be allocated among such sinking fund payments on a pro rata basis in integral multiples of $5,000 (as set forth in a schedule provided by the Authority to the Trustee). * Preliminary; subject to change. 0 Mandatory Sinking Fund Redemption of Term Bonds Maturina October 1. 20 Sinking Fund Redemption Date (October 1 ) Principal Amount To Be Redeemed Mandatory Sinking Fund Redemption of Term Bonds Maturina October 1. 20 Sinking Fund Redemption Date (October 1) Principal Amount To Be Redeemed Notice of Redemption. Notice of redemption will be mailed by the Trustee, first class, postage prepaid, not more than 60 and not less than 20 days before any redemption date, to the respective registered Owners of any Bonds designated for redemption at their addresses appearing on the registration books maintained by the Trustee and to one or more Securities Depositories and the Municipal Securities Rulemaking Board. Neither the failure to receive any notice nor any defect therein will affect the proceedings for such redemption. Selection of Bonds for Redemption. Whenever provision is made in the Indenture for the redemption of less than all of the Bonds of a single maturity, the Trustee will select the Bonds to be redeemed from all Bonds of that maturity to be redeemed by lot in any manner which the Trustee in its sole discretion deems appropriate. For purposes of such selection, Bonds will be deemed to be comprised of $5,000 portions and each portion will be subject to redemption as if such portion were a separate Bond. Effect of Redemption. If notice of redemption has been duly given and money for the payment of the redemption price of the Bonds called for redemption has been duly provided, such Bonds so called will cease to be entitled to any benefit under the Indenture other than the right to receive payment of the redemption price, and no interest will accrue thereon from and after the redemption date specified in such notice. Rescission of Redemption. Any notice of optional redemption of the Bonds may provide that the redemption shall be conditional upon the receipt of sufficient funds to accomplish the redemption. The Authority has the right to rescind any notice of optional redemption of Bonds by written notice to the Trustee on or prior to the date fixed for redemption. Any notice of redemption shall be cancelled and annulled if for any reason funds will not be or are not available on the date fixed for redemption for the payment in full of the Bonds then called for redemption, and such cancellation shall not constitute an Event of Default. The Authority and the Trustee have no liability to the Bond Owners or any other party related to or 9 arising from such rescission of redemption. The Trustee shall mail notice of such rescission of redemption in the same manner as the original notice of redemption was sent under the Indenture. Book -Entry Only System The Bonds will be issued as fully registered bonds in book -entry only form, registered in the name of Cede & Co. as nominee of DTC, and will be available to ultimate purchasers in integral multiples of $5,000, under the book -entry system maintained by DTC. While the Bonds are subject to the book -entry system, the principal, interest and any prepayment premium with respect to a Bond will be paid by the Trustee to DTC, which in turn is obligated to remit such payment to its DTC Participants for subsequent disbursement to Beneficial Owners of the Bonds. Purchasers of the Bonds will not receive certificates representing their interests therein, which will be held at DTC. See "APPENDIX F — DTC AND THE BOOK -ENTRY ONLY SYSTEM" for further information regarding DTC and the book -entry system. 10 DEBT SERVICE SCHEDULE The table below shows annual debt service payments on the Bonds, assuming no optional or extraordinary redemption. Year Ending October 1 Principal Interest Debt Service Total $ $ $ SECURITY FOR THE BONDS The principal of and interest on the Bonds are not a debt of the Authority (except to the limited extent described in this Official Statement) or the City, nor a legal or equitable pledge, charge, lien or encumbrance, upon any of their respective property, or upon any of their income, receipts, or revenues except the Revenues and other amounts pledged under the Indenture. This section provides summaries of the security for the Bonds and certain provisions of the Indenture and the Lease. See "APPENDIX C — Summary of Principal Legal Documents" for a more complete summary of the Indenture and the Lease. Capitalized terms used but not defined in this section have the meanings given in APPENDIX C. Pledge of Revenues The Bonds are payable from and secured by a pledge of Revenues and certain funds and accounts established and held by the Trustee under the Indenture. Revenues, as defined in the Indenture, mean: (a) all amounts received by the Authority or the Trustee under or with respect to the Lease, including, without limiting the generality of the foregoing, all of the Lease Payments (including both timely and delinquent payments, any late charges, and 11 whether paid from any source), but excluding (i) any amounts described in the provisions of the Lease relating to permitted amendments that provide for additional rental to be pledged or assigned for the payment of bonds issued to finance or refinance projects for which the City is authorized to expend its funds, and (ii) any Additional Rental Payments (consisting of certain administrative costs due to the Authority and the Trustee under the Lease), and (b) all interest, profits or other income derived from the investment of amounts in any fund or account established under the Indenture. Pursuant to the Assignment Agreement, the Authority has assigned to the Trustee for the benefit of the Owners of the Bonds, certain of its rights under the Lease, including its right to receive Lease Payments for the purpose of securing the payment of debt service on the Bonds and the right to pursue remedies in the event the City defaults under the lease. THE BONDS ARE SPECIAL OBLIGATIONS OF THE AUTHORITY PAYABLE SOLELY FROM AND SECURED BY A PLEDGE OF REVENUES AND CERTAIN FUNDS AND ACCOUNTS HELD UNDER THE INDENTURE. THE AUTHORITY HAS NO TAXING POWER. THE OBLIGATION OF THE CITY TO MAKE LEASE PAYMENTS UNDER THE LEASE DOES NOT CONSTITUTE AN OBLIGATION OF THE CITY FOR WHICH THE CITY IS OBLIGATED TO LEVY OR PLEDGE ANY FORM OF TAXATION OR FOR WHICH THE CITY HAS LEVIED OR PLEDGED ANY FORM OF TAXATION. NEITHER THE BONDS NOR THE OBLIGATION OF THE CITY TO MAKE LEASE PAYMENTS UNDER THE LEASE CONSTITUTES AN INDEBTEDNESS OF THE CITY, THE COUNTY, THE STATE OF CALIFORNIA (THE "STATE") OR ANY OF ITS POLITICAL SUBDIVISIONS (INCLUDING ANY MEMBER OF THE AUTHORITY) IN CONTRAVENTION OF ANY CONSTITUTIONAL OR STATUTORY DEBT LIMITATIONS. Lease Payments; Covenant to Appropriate The City covenants, under the Lease, to make Lease Payments as rental for the right to use and occupy the Leased Property under the Lease. Amounts of the scheduled Lease Payments are calculated to be sufficient to pay debt service on the Bonds when due. Lease Payments will be paid by the City semiannually to the Trustee on the Business Day immediately preceding each Interest Payment Date. Upon receipt, the Trustee will deposit the Lease Payments in the Bond Fund for the purposes of paying principal of and interest on the Bonds. The City covenants under the Lease to take such action as may be necessary to include all Lease Payments and Additional Rent in its annual budgets and to make the necessary annual appropriations for all such rental payments. Under certain circumstances described in the Lease, however, Lease Payments are subject to abatement during periods of substantial interference with the City's use and occupancy of all or a portion of the Leased Property, as described in " — Abatement" below. Abatement The Lease provides that the obligation of the City to pay Lease Payments will be subject to abatement by reason of (i) any damage or destruction such that there is substantial interference with the use and occupancy of all or any portion of the Leased Property, (ii) or prior to the issuance of a certificate of occupancy for the project, if it constitutes all or a portion of the Leased Property, there is substantial interference with the use and occupancy by the City of the 12 Leased Property or any portion thereof, provided that there will be no such abatement to the extent that any capitalized interest is available to pay Lease Payments which would otherwise be abated, or (iii) a temporary taking of the Leased Property or a permanent taking of a portion of the Leased Property. Such abatement will be in an amount determined by the City, such that the resulting unabated portion of the Lease Payments will represent fair consideration for the use and occupancy of the remaining usable portions of the Leased Property. Such abatement will continue for the period commencing with such damage or destruction or non -completion of the Project and ending, respectively, with the substantial completion of the work of repair or reconstruction or substantial completion of the Project. Notwithstanding the foregoing, under the Lease, the Lease Payments will not be subject to abatement to the extent that proceeds from rental interruption insurance are available to pay the portion of the Lease Payments which would otherwise be abated. Insurance; Condemnation In the event of an abatement of Lease Payments, debt service on the Bonds may, to a certain extent, be covered by insurance proceeds. The City is required to procure and maintain rental interruption or use and occupancy insurance to cover loss, total or partial, of the use of any portion of the Leased Property constituting buildings or other improvements as a result of certain hazards pursuant to the Lease. Such insurance will be in an amount at least equal to the maximum amount of Lease Payments coming due and payable during any consecutive two Fiscal Years. The Net Proceeds of such insurance, if any, will be paid to the Trustee and deposited in the Bond Fund, for application as a credit towards the payment of the Lease Payments allocable to the insured improvements as the same become due and payable. The Lease also requires the City to maintain title insurance, standard commercial general liability insurance and casualty insurance with respect to the Leased Property. Any Net Proceeds under such title insurance policy will be deposited with the Trustee in the Bond Fund, to be credited towards the prepayment of the remaining Lease Payments under the Lease. The required casualty insurance will have a coverage amount at least equal to the lesser of (a) 100% of the replacement value of the insured buildings, or (b) 100% of the aggregate principal amount of the Bonds, and may be subject to such deductibles as the City deems adequate and prudent. See Appendix C — "SUMMARY OF PRINCIPAL LEGAL DOCUMENTS" for a description of provisions of the Lease and the Indenture relating to the application of proceeds from the casualty insurance or condemnation awards. See "RISK FACTORS —Abatement." Remedies If the City defaults in performance of its obligations under the Lease, the Authority or the Trustee, as assignee of the Authority, may either terminate the Lease and re-enter and re -let all or a portion of the Leased Property or may retain the Lease and hold the City liable for all payments on an annual basis and still have the right to re-enter and re -let the Leased Property without effecting a surrender of the Lease. Additionally, the Trustee may pursue remedies at law or in equity to enforce the Lease. 13 Although the Lease and the Indenture provide that the Trustee, as assignee of the Authority, may take possession of the Leased Property if there is a default by the City, and the Lease provides that the Trustee may have such rights of access to the Leased Property as may be necessary to exercise any remedies, portions of the Leased Property may not be easily recoverable and, even if recovered, could be of little value to others. There can be no assurance that the Leased Property can be re -let for an amount equal to all outstanding Lease Payments. Due to the essential nature of the governmental functions of the Leased Property, it is not certain whether a court would permit the exercise of the remedies of repossession and re- letting with respect thereto. In addition, the remedy of repossession and re -letting may prove to be unavailable or not economically viable with respect to all or portions of the Leased Property because the Authority has only a leasehold or other possessory right to some of the Leased Property. Therefore, repossession of the Leased Property in such instances may not be an available remedy. In addition, assuming the Leased Property could be repossessed, it may prove functionally impossible to relet. In addition, approximately 7,600 square feet of the Police Building have been leased to the State Judicial Council, Administrative Office of the Courts ("AOC"), for use as trial court facilities, pursuant to a lease agreement originally executed in 2006. The rights of the Trustee under the Lease, including the right to relet, would be subordinate to the AOC's rights under its lease. THE AUTHORITY The Authority was created in July 2010 by a joint exercise of powers agreement, which was entered into between the City and Industrial Development Authority of the City of Lodi ("IDA"), pursuant to the provisions of the Act. Under the Joint Exercise of Powers Agreement, the Authority is a public entity, separate from the City and the IDA. The debts, liabilities and obligations of the Authority are not debts, liabilities and obligations of either the City or the IDA. The Authority is administered by a governing board consisting of the members of the Lodi City Council. THE CITY General The City is a general law city in the State of California incorporated in 1906. The City is located in the San Joaquin Valley of California, 35 miles south of the State capital of Sacramento, and 90 miles east of San Francisco. The City operates under a City Council -Manager form of government and provides the following services: public safety (police, fire and graffiti abatement), public utilities services (electric, water and sewer), transportation services (streets, flood control and transit), leisure, cultural and social services (parks and recreation, library, and community center), and general government services (management, human resources administration, financial administration, building maintenance and equipment maintenance). As of January 1, 2021, the City had an estimated population of 68,751. 14 See "APPENDIX A — GENERAL INFORMATION ABOUT THE CITY OF LODI AND SAN JOAQUIN COUNTY." Governance and Management The City is governed by a five -member City Council elected by district. Each council member is elected for four years with staggered terms. The current City Council members and the expiration dates of their terms are set forth below. Council Member Title Expiration of Term Mark Chandler Mayor November 2022 Mikey Hothi Mayor Pro Tem November 2024 Alan Nakanishi Councilmember November 2022 Doug Kuehne Councilmember November 2022 Shak Khan Councilmember November 2024 Stephen Schwabauer, City Manager, was appointed to the position by the City Council on June 5, 2014 after serving five -months as the Interim Manager. He had been City Attorney from 2004 to 2014, and Deputy City Attorney from 2000 to 2004. During his tenure as City Attorney, Schwabauer negotiated the resolution of a multimillion dollar groundwater contamination action and associated financing scheme. Schwabauer also led labor negotiations for much of his tenure as City Attorney and developed significant experience with budget operations and employee relations. Schwabauer earned his Bachelor of Arts degree from U.C. Davis in 1990 and his law degree from U.C. Berkeley in 1994. Andrew Keys, Deputy City Manager/Internal Services Director, has been the City's Deputy City Manager/Internal Services Director since March 27, 2017. As the City's administrative second -in -command, Keys oversees the City's Finance, Budget and Treasury, Information Systems and Human Resources functions. Keys came to the City after a 9 -year career with the City of Elk Grove, California. In Elk Grove, he served in various roles within the finance department, including Analyst, Accounting Manager and Budget Manager, as well as within administration serving as Assistant to the City Manager and Deputy City Manager. Keys began his career in the municipal finance sector with KNN Public Finance where he served for a year as an Analyst after receiving his Bachelor of Arts degree in International Relations from U.C. Davis in 2006. He later received his Master's degree in Business Administration from U.C. Davis in 2013. Charles Swimley, Public Works Director, began his tenure with the City in 2001 as Senior Civil Engineer, was promoted to Water Services Manager in 2006, then Deputy Director of Utilities in 2010 where he oversaw wastewater collection and treatment, water production and distribution and street maintenance. In 2012, Swimley was promoted to City Engineer until his appointment to Public Works Director in April 2016. Swimley, a registered civil engineer since 1994, earned his Bachelor of Science degree from California State University, Sacramento. Public Health Emergency — COVID-19 General. The spread of the novel strains of coronavirus that causes the disease known as COVID-19 ("COVID-19") and local, state and federal actions in response to COVID-19, is 15 having a significant impact on the economy and on the City's operations and finances. On February 11, 2020, the World Health Organization ("WHO") announced the official name for the outbreak of COVID-19, an upper respiratory tract illness. COVID-19 has since spread across the globe. The COVID-19 pandemic has had an adverse effect on, among other things, the world economy, global supply chain, international travel and a number of travel -related industries. The temporary and permanent business closures caused by the COVID-19 pandemic have led to a stark increase in unemployment across the County and the nation. Depending on the length and the breadth of the impacts of the COVID-19 pandemic, the economic costs may be very significant for the City and the region's economy. On June 8, 2020, the National Bureau of Economic Research announced that the United States of America officially entered into a recession in February 2020. In addition, capital markets in the United States and globally have been volatile. In mid-March 2020, based on guidance and directives from the State and public health agencies, including the County, California implemented and has since revised Shelter -in -Place ("Shelter -in -Place") emergency orders or directives, which directed individuals to stay home, except for limited travel for the conduct of essential services. Most retail establishments (including restaurants, bars and nightclubs, entertainment venues and gyms) were closed in response to the Shelter -in -Place orders or directives. In December 2020, two vaccines were approved for emergency use in the United States and vaccinations began in California. A third vaccine was approved for emergency use in February 2021. On June 15, 2021, California fully reopened its economy ending capacity limits, physical distancing and certain mask requirements for individuals who are fully vaccinated in accordance with guidance from the Centers for Disease Control and Prevention (the "CDC"). Masks are still required on public transportation, in hospitals and jails, in schools and in other child care centers pending updated guidance from the CDC. Public health measures currently remain for events with 5,000 or more people indoors or 10,000 attendees or more outdoors, with vaccine verification recommended. Certain public health measures, including but not limited to mask, testing and/or vaccination requirements, remain in certain business settings and for certain industries. Financial Impact on City. Overall, COVID-19 had a minimal impact on City revenues. Throughout the pandemic, City revenue continued to increase. General Fund revenue for Fiscal Year 2020-21 was approximately $71.3 million when excluding reimbursements for COVID-19-related activities provided by the Federal Emergency Management Agency (FEMA). This is an increase of approximately $17.1 million, or 31.4%, from Fiscal Year 2018-19, the last full year before the COVID-19 pandemic. A large portion of such increase is from Measure L, the City's transaction and use tax that was approved by voters in November 2018. Fiscal Year 2018-19 only includes one quarter of Measure L revenue, whereas Fiscal Year 2020-21 includes a full year. Excluding Measure L, General Fund revenues still increased approximately $10.1 million, or 19.1% from Fiscal Year 2018-19 through Fiscal Year 2020-21. On March 27, 2020, the $2.2 trillion Coronavirus Aid, Relief, and Economic Security Act (the "CARES Act") was enacted which provides, among other measures, $150 billion in financial assistance to states, tribal governments and local governments to provide emergency assistance to those most significantly impacted by the COVID-19 pandemic. Under the CARES Act, local governments are eligible for reimbursement of certain costs which are expended to ME address the impacts of the pandemic. The City received approximately $2.2 million in Fiscal Year 2019-20 (of which approximately $839,000 was allocated to the General Fund) and $2.9 million in Fiscal Year 2020-21 (of which approximately $839,000 was allocated to the General Fund) from the State from its share of funding under the CARES Act. Funds received by the City under the CARES Act are not available for payment of debt service on the Bonds and cannot be used to backfill City revenue losses related to the COVID-19 pandemic. On March 11, 2021, the President of the United States signed the American Rescue Plan, a $1.9 trillion economic stimulus package designed to help the United States' economy recover from the adverse impacts of the COVID-19 pandemic. The American Rescue Plan includes $350 billion in unrestricted economic relief to states, counties, and local governments. On May 10, 2021, the U.S. Treasury Department released interim guidance for use of the American Rescue Plan funds, and specifically authorized, among other things, the use of funds to help offset revenue shortfalls caused by the pandemic. As of the date of this Official Statement, the City estimates it will receive a total of approximately $15.7 million in funding under the American Rescue Plan. To date, the City has received approximately $7.8 million of such funds and anticipates receiving a second installment in 2022. The City has not yet allocated such funding for specific purposes pending the release of final guidance from the United States government. The COVID-19 pandemic is ongoing, and its dynamic nature leads to uncertainties. There are many variables that will continue to contribute to the economic impact of the COVID- 19 pandemic and the recovery therefrom, including the length of time social distancing measures are in place, the effectiveness of State and Federal governments' relief programs and the timing for the containment and treatment of COVID-19. Certain of the information in this Official Statement is dated prior to the onset of the COVID-19 pandemic, which has had a significant adverse impact on the nation, State and local economy, including, but not limited to, a dramatic increase in unemployment levels. Accordingly, such information is not necessarily indicative of the current financial condition or future prospects of the City and the region. The ultimate impact of COVID-19 on the City's operations and finances is not fully known, and it may be some time before the full impact of the COVID-19 pandemic is known. See "RISK FACTORS — Public Health Emergencies." CITY FINANCIAL INFORMATION City Budget Budget Procedure. The fiscal year of the City begins on the first day of July of each year and ends on the thirtieth day of June of the following year. Each annual budgetary cycle begins with departments submitting revenue and expenditure estimates in March for the upcoming fiscal year. Budget division staff assembles the data and meets with the departments and City Manager to refine the estimates and develop a draft budget. Public meetings are held with the City Council during the month of May and all issues related to each budget unit are discussed. A draft budget is typically released to the Council and publicly posted in mid-May. The City Council adopts a balanced budget in June for the fiscal year that starts the following July 1. In January or February, staff brings forward a mid -year review of the entire budget for the City and the City Council adopts any changes necessary based upon the projected financial conditions of the time. Throughout the year, adjustments to the budget are brought to the City Council as needed. 17 The City's 2021-22 Financial Plan and Budget (the "2021-22 Budget") was approved by the City Council on June 2, 2021. The following table sets forth the original and final budget for Fiscal Year 2020-21, audited actual revenues and expenditures for Fiscal Year 2020-21, as well as the adopted budget for Fiscal Year 2021-22. Budget Summary. The 2021-22 Budget totals $245 million from all funding sources. The 2021-22 Budget for the General Fund is approximately $61 million. The City's General Fund tax revenues are comprised primarily of property taxes and sales taxes. The General Fund sum of expenditures and net transfers out are approximately $60 million, the net result being a balanced General Fund budget for Fiscal Year 2021-22. The 2021-22 Budget includes various municipal improvements, contracted labor cost increases, and the addition of six positions. The table below presents a comparison of the City's General Fund budget for Fiscal Year 2020-21, along with the budget for Fiscal Year 2021-22. 18 Table 1 Statement of Revenues, Expenditures and Changes in Fund Balances Budget and Actual General Fund Budget Revenues Taxes Sales and Use Tax Licenses and Permits Intergovernmental Revenues Charges for Services Fines, Forfeits and Penalties Investment and Rental Income Miscellaneous Revenue Total Revenues Expenditures Current: City Manager City Clerk City Attorney Internal Services Admin Human Resources Information Systems Financial Services Revenue Services Budget and Treasury Non Departmental Total General Government Public Protection Police Fire Total Public Protection Public Works Library Total Expenditures Excess (Deficiency) of Revenues Over (Under) Expenditures Other Financing Sources (Uses) Transfers In Transfers Out Gain on Sale of Property Total Other Financing Sources (Uses) Net Change in Fund Balance Fund Balance, Beginning of Year Fund Balance, End of Year Basis Adjustment: Cumulative Pension Set Aside Fund Balance (Budgetary Basis) 387,970 (5,073,315) 13,533,392 18,606,707 1,027,270 4,697,816 4,697,816 4,697,816 - 8,038,130 Fiscal Year (5,458,817) Fiscal Year 2020-21 (9,188,300) 2021-22 1,000 14,666 13,666 1,000 Variance (760,001) (746,335) 13,666 (1,149,170) Audited with Final Adopted Original Final Actual Budget Budget $29,443,740 $29,443,740 $31,697,986 $2,254,246 $32,652,850 17,535,870 19,958,000 24,302,433 4,344,433 21,775,960 91,550 91,550 69,004 (22,546) 155,800 1,166,920 11,640,910 15,116,622 3,475,712 1,326,050 1,783,570 1,974,570 2,598,283 623,713 1,890,860 1,300,100 300,700 217,097 (83,603) 868,100 1,858,390 1,858,390 4,640,812 2,782,422 1,785,050 296,280 296,280 494,747 198,467 287,260 53,476,420 65,564,140 79,136,984 13,572,844 60,741,930 956,510 1,021,010 983,634 37,376 1,338,780 770,040 770,040 556,367 213,673 704,500 615,140 646,620 588,955 57,665 706,690 241,130 241,130 238,076 3,054 253,220 695,240 695,240 664,156 31,084 748,410 1,693,020 1,693,020 1,586,133 106,887 1,816,720 1,039,770 1,039,770 1,031,848 7,922 1,129,110 1,296,610 1,296,610 1,257,070 39,540 1,426,800 338,580 357,037 357,897 (860) 425,080 1,452,430 18,367,987 16,565,014 1,802,973 2,670,400 9,098,470 26,128,464 23,829,150 2,299,314 11,219,710 24,921,930 25,061,761 23,894,807 1,166,954 27,157,950 14,461,600 14,751,320 14,111,112 640,208 16,392,350 39,383,530 39,813,081 38,005,919 1,807,162 43,550,300 2,891,680 2,941,680 2,743,906 197,774 3,175,320 1,714,770 1,754,230 1,024,617 729,613 1,769,330 53,088,450 70,637,455 65,603,592 5,033,863 59,714,660 387,970 (5,073,315) 13,533,392 18,606,707 1,027,270 4,697,816 4,697,816 4,697,816 - 8,038,130 (5,458,817) (5,458,817) (5,458,817) - (9,188,300) 1,000 1,000 14,666 13,666 1,000 (760,001) (760,001) (746,335) 13,666 (1,149,170) (372,031) (5,833,316) 12,787,057 $18,620,374 (121,900) 27, 903, 041 27, 903, 041 27, 903, 041 $27,531,010 $22,069,725 $40,690,098 (15,641,640) $25,048,458 (1) Transfers out is composed primarily of General Fund operating support to the City's Library, Parks, Recreation and Cultural Services, and Community Development departments, among other operating transfers. The increase between Fiscal Year 2020-21 and Fiscal Year 2021-22 is due to full operations of the Library and Parks, Recreation 19 and Cultural Services departments, which were closed or partially closed during Fiscal Year 2020-21 as a result of the COVID-19 pandemic. Source: City of Lodi. State Budget and Its Impact on the City. Information about the Fiscal Year 2021-22 adopted State budget and other State budgets is regularly available at various State - maintained websites. An impartial analysis of the budget is posted by the Legislative Analyst Office at www.lao.ca.gov. In addition, various State official statements, many of which contain a summary of the current and past State budgets, may be found at the website of the State Treasurer, www.treasurer.ca.gov. The information referred to in this paragraph is prepared by the respective State agency maintaining each website and not by the City or the Underwriter, and the City and the Underwriter take no responsibility for the continued accuracy of the Internet addresses or for the accuracy or timeliness of information posted there, and such information is not incorporated in this Official Statement by these references. The City cannot predict what actions will be taken in future years by the State Legislature and the Governor to address a State budget deficit. Future State budgets will be affected by national and state economic conditions and other factors over which the City has no control. To the extent that the State budget process results in reduced revenues to the City, the City will be required to make adjustments to its budget. Financial Policies Summary General. The City Council has adopted a comprehensive set of financial management policies to provide for: (i) establishing targeted general fund reserves; (ii) the prudent investment of City funds; and (iii) establishing parameters for issuing and managing debt supported by the general fund and enterprise funds. General Fund reserves include (i) a Catastrophic Reserve, which is intended for use in times of emergency and is set at a minimum of 8% of General Fund revenues, including operating transfers and (ii) an Economic Reserve, which is intended to maintain the City's economic viability and to meet seasonal cash flow needs and is set at a minimum of 8% of General Fund revenues, including operating transfers. The City has also adopted a Pension Stabilization Funding Policy, under which the City Treasurer is required to invest all fund balances in excess of 16% of General Fund revenues in the City's Internal Revenue Code Section 115 Trust (the "Pension Stabilization Fund") with Public Agency Retirement Solutions ("PARS"). The Pension Stabilization Funding Policy was suspended in Fiscal Year 2020-21, so as to apply excess reserves as a buffer against impacts of the COVID-19 pandemic, but reinstated with the 2021-22 Budget. For additional information on the Pension Stabilization Fund, see "— Retirement System — Pension Stabilization Fund and Pension Funding Policy." The City's investment policy guides the investment of public funds in a manner which will provide a sound investment return with maximum security while meeting the daily cash flow demands of the entity and conforming to all state and local statues governing the investment of public funds. See "— City Investments." The City's debt management policy outlines the purposes for which debt may be issued, which includes long-term debt for the construction, acquisition, and rehabilitation of capital improvements and facilities, the types of debt the City may issue, policy goals, and internal control procedures related to the issuance and management of debt. 20 Financial Statements All governmental funds are accounted for using the modified accrual basis of accounting. The City's revenues are recognized when they become measurable and available as net current assets. Expenditures are generally recognized under the modified accrual basis of accounting when the related fund liability is incurred. The exception to this general rule is principal and interest on general long-term debt, which is recognized when due. Some debts and obligations may be payable from self-supporting enterprises or revenue sources other than property taxation. Special assessment bonds are not included in the tabulation; lease revenue obligations payable from the General Fund or equivalent sources are included. All proprietary funds are accounted for using the accrual basis for accounting. Revenues are recognized when they are earned, and expenses are recognized when they are incurred. Receivables are recorded and determined at the time of consumption, and unbilled receivables are not recorded. The City's most recent audited financial statements are included in the Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021, which is attached as APPENDIX B to this Official Statement. The financial statements were prepared by the City and audited by The Pun Group LLP (the "Auditor"). The Financial Statements should be read in their entirety. The City has neither requested nor obtained permission from the Auditor to include the audited financial statements as an appendix to this Official Statement. Accordingly, the Auditor has not performed any post - audit review of the financial condition or operations of the City or General Fund. In addition, the Auditor has not reviewed this Official Statement. Set forth on the following pages are (i) a general fund balance sheet for Fiscal Years 2016-17 through 2020-21 and (ii) a statement of revenues, expenditures and changes in fund balances for the City's general fund for the same period. 21 Table 2 General Fund Balance Sheet Assets: Cash and investments Accounts receivables, net Property taxes receivable Interest receivable Due from other funds Due from other governmental agencies Prepaid Restricted cash and investments Total assets Liabilities: Accounts payable and other liabilities Accrued salaries and wages Advances from other funds Unearned revenue Total liabilities Deferred inflows of resources: Unavailable revenue Total Deferred Inflows of Resources Fund Balance: Nonspendable: prepaid Restricted: pension Committed: Pension Video -related capital projects Unassigned Total fund balance Total liabilities, deferred inflows of resources and fund balance Audited Audited Audited Audited Audited 2016-17 2017-18 2018-19 2019-20 2020-21 $15,550,701 $10,247,211 $13,497,734 $16,459,714 $15,180,526 5,253,103 4,137,816 5,255,725 6,278,463 7,190,261 41,462 67,665 80,324 87,960 92,539 12,861 12,597 18,298 12,308 4,218 - - - 237,449 - - - - - 10,651,086 - - - - 53,739 - 8,573,950 10,716,555 12,671,440 15,641,640 20,858,127 23,039,239 29,568,636 35,747,334 48,814,009 $4,716,588 $3,797,974 $5,717,668 $7,269,460 $7,302,047 827,017 63,751 640,070 - 107,840 78,632 409,609 66,883 - - 5,622,237 4,271,334 6,424,621 7,269,460 7,409,887 267,533 - 691,603 574,833 714,024 267,533 - 691,603 574,833 714,024 - - - - 53,739 - - 10,716,555 12,671,440 15,641,640 2,941,844 8,573,949 - - - 578,528 457,170 563,374 711,621 557,686 11,447,985 9,736,786 11,172,483 14,519,980 24,437,033 14,968,357 18,767,905 22,452,412 27,903,041 40,690,098 20,858,127 23,039,239 29,568,636 35,747,334 48,814,009 Source: City of Lodi Annual Comprehensive Financial Reports for Fiscal Years indicated. 22 Table 3 Statement of General Fund Revenues, Expenditures and Changes in Fund Balance 23 Audited Audited Audited Audited Audited 2016-17 2017-18 2018-19 2019-20 2020-21 Revenues: Taxes $26,490,919 $27,422,477 $28,422,573 $30,223,587 $31,697,986 Sales and use tax '> - - 14,286,516 20,083,861 24,302,433 Licenses and permits 86,844 67,757 65,639 74,843 69,004 Intergovernmental revenues (1)(2) 12,830,329 12,377,159 1,186,022 939,172 15,116,622 Charges for services 1,852,855 1,934,180 1,772,088 1,992,262 2,598,283 Fines forfeits, and penalties 906,563 1,396,137 1,274,624 1,053,364 217,097 Investment and rental income 1,734,773 1,747,857 2,195,924 2,906,797 4,640,812 Miscellaneous revenues 319,373 342,549 221,949 438,325 494,747 Total revenues 44,221,656 45,288,116 49,425,335 57,712,211 79,136,984 Expenditures: Current: General government (2) 6,926,368 6,980,564 7,136,809 10,411,249 23,829,150 Public protection 29,969,781 30,576,759 31,743,158 36,865,475 38,005,919 Public works 1,698,518 1,852,852 2,180,840 2,512,089 2,743,906 Library 1,152, 721 1,058,133 1,165,499 1,181,184 1,024,617 Total expenditures 39,747,388 40,468,308 42,226,306 50,969,997 65,603,592 Excess (deficiency) of revenues over expenditures 4,474,268 4,819,808 7,199,029 6,742,214 13,533,392 Other financing sources (uses): Transfers in 3,952,000 5,949,190 4,233,780 4,393,660 4,697,816 Transfers out (6,705,104) (6,969,450) (7,749,000) (5,685,590) (5,458,817) Proceeds from sale of property 698 345 14,666 Total other financing sources (uses) (2,753,104) (1,020,260) (3,514,522) (1,291,585) (746,335) Net change in fund balances before special items 1,721,164 3,799,548 3,684,507 5,450,629 12,787,057 Fund balance - July 1 13,247,193 14,968,357 18,767,905 22,452,412 27,903,041 Fund balance - June 30 14,968,357 18,767,905 22,452,412 27,903,041 40,690,098 (1) Prior to Fiscal Year 2018-19, sales and use taxes were accounted for in Intergovernmental Revenues. The increase in sales and use taxes is also due to the imposition of Measure L, a 1/2 cent sales tax that began being levied on April 1, 2019. (2) Increase in intergovernmental revenues and general government expenditures between Fiscal Year 2019-20 and Fiscal Year 2020-21 primarily due to receipt and expenditure of funds from FEMA and other governmental entities related to the COVID-19 pandemic. Source: City of Lodi Annual Comprehensive Financial Reports for Fiscal Years indicated. 23 Major Tax Revenues Tax revenues by source for the City's General Fund are presented in the table below. Property Taxes Sales and use Tax Transient Occupancy Tax Franchise Documentary Transfer Motor Vehicle In Lieu Public Protection Business License In Lieu Franchise Total Table 4 General Fund Tax Revenues by Source (Dollar amounts in thousands) Fiscal Year Fiscal Year Fiscal Year Fiscal Year Fiscal Year 2016-17 2017-18 2018-19 2019-20 2020-21 $9,744 $10,043 $11,050 $11,980 $13,050 11,750 11,333 14,286 20,084 24,302 849 867 735 987 899 1,915 2,059 2,128 2,338 2,207 240 281 230 (25) 86 4,904 5,176 5,399 5,760 6,073 378 401 441 462 527 1,736 1,822 1,887 1,884 2,092 7,131 7,159 7,197 7,274 7,375 $38,647 $39,141 $43,353 $50,744 $56,611 (1) In the City's audited financial reports, sales and use tax is included in the intergovernmental revenues category prior to Fiscal Year 2018-19. Source: City of Lodi Annual Comprehensive Financial Report for the Year Ended June 30, 2021. Sales and Use Taxes. Sales taxes represent the largest source of tax revenue to the City at approximately 31 % in Fiscal Year 2020-21 of General Fund total revenues. The City has received approximately $24.3 million in Sales tax revenue for Fiscal Year 2020-21 (21% growth over prior year). The revenue growth is attributable a growing retail and distribution base in the City and increasing online sales deliveries in the City that provide a significant boost to Measure L revenue. The City continues to be successful in attracting large distribution centers to its industrial parks which not only increase the City's base tax, but add to the City's half -cent local Sales Tax revenue (Measure L). The City has two revenue streams for Sales Tax; Bradley Burns, the State's Sales Tax and Measure L, the City's local Sales Tax. The City receives a portion of the statewide Sales Tax, 1 cent per dollar transaction. In addition, the residents of the City approved an additional '/2 cent Sales Tax in 2018 known as Measure L, which began being levied on April 1, 2019. This section describes the current system for levying, collecting and distributing sales and use tax revenues in the State of California. Sales Tax Rates. The City collects a percentage of taxable sales in the City (minus certain administrative costs imposed by the State) pursuant to the Bradley -Burns Uniform Local Sales and Use Tax (the "Sales Tax Law"), as shown below. 24 Local taxes are included in the statewide sales and use tax rate of 7.25%. Additional local taxes approved by voters (also referred to as district taxes or "transaction taxes") are applied to purchases where the goods are delivered or placed into use in the City. Currently, taxable transactions in the City are subject to the following sales and use tax, of which the City's share is only a portion. The State collects and administers the tax, and makes distributions on taxes collected within the City, as follows: Table 5 Sales Tax Rates Fiscal Year 2021-22 Component Rate State and County Sales Tax Rate 7.25% District (Local) Sales Tax Rates Lodi Measure L 0.50% San Joaquin Transportation Authority (K) (SJTA) 0.50 Total 1.00% Total Sales Tax Rate 8.25% Source: City of Lodi. Sales and use taxes are complementary taxes; when one applies, the other does not. In general, the statewide sales tax applies to gross receipts of retailers from the sale of tangible personal property in the State of California. The use tax is imposed on the purchase, for storage, use or other consumption in the State of tangible personal property from any retailer. The use tax generally applies to purchases of personal property from a retailer outside the State of California where the use will occur within the State of California. The Sales Tax is imposed upon the same transactions and items as the statewide sales tax and the statewide use tax. Certain transactions are exempt from the State sales tax, including sales of the following products: • food products for home consumption; • prescription medicine; • newspapers and periodicals; • edible livestock and their feed; • seed and fertilizer used in raising food for human consumption; and • gas, electricity and water when delivered to consumers through mains, lines and pipes. This is not an exhaustive list of exempt transactions. A comprehensive list can be found in the State Board of Equalization's Publication No. 61 entitled "Sales and Use Taxes: Exemptions and Exclusions," which can be found on the California Department of Tax and Fee Administration (CDTFA) website at www.cdtfa.ca.gov. The reference to this Internet website is provided for reference and convenience only. The information contained within the website may 25 not be current, has not been reviewed by the City and is not incorporated in this Official Statement by reference. Sales Tax Collection Procedures. Collection of the sales and use tax is administered by the California Department of Tax and Fee Administration ("CDTFA") Retailers engaged in business in California must register with the CDTFA and pay the state's sales tax, which applies to all retail sales of goods and merchandise except those sales specifically exempted by law. The use tax generally applies to the storage, use, or other consumption in California of goods purchased from retailers in transactions not subject to the sales tax. Use tax may also apply to purchases shipped to a California consumer from another state, including purchases made by mail order, telephone, or Internet. The sales and use tax rate in a specific California location has three parts: the state tax rate, the local tax rate, and any district tax rate that may be in effect. These transmittals are required to be made at least twice in each calendar quarter. Under its procedures, CDTFA projects receipts of the sales and use tax on a quarterly basis and remits an advance of the receipts of the sales and use tax to the City on a monthly basis. The amount of each monthly advance is based upon CDTFA's quarterly projection. During the last month of each quarter, CDTFA adjusts the amount remitted to reflect the actual receipts of the sales and use tax for the previous quarter. According to CDTFA, it distributes quarterly tax revenues to cities, counties and special districts using the following method: CDTFA distributes sales tax revenue to each jurisdiction monthly on an advance basis and trues up to actual receipts once each quarter. CDTFA distributes to each jurisdiction a percentage of the statewide prepayments received in the current month to each jurisdiction based on that jurisdiction's pro rata share of statewide sales tax allocations in the prior year's like quarter. In addition, any money collected in the current month specific to each jurisdiction is distributed to that jurisdiction. One advance payment is made each month, and the quarterly reconciliation payment (clean-up) is distributed with the third payment. This clean-up payment simply makes the jurisdiction whole based on actual receipts of sales tax revenue for that jurisdiction in the quarter versus the advances made. Clean-up payments may be additive or subtractive to the advances previously made based on actual activity. Statements showing total collections, administrative costs, prior advances and the current advance are provided with each quarterly clean-up payment. CDTFA receives an administrative fee based on the cost of services provided by CDTFA to the City in administering the City's sales tax, which is deducted from revenue generated by the sales and use tax before it is distributed to the City. Property Taxes. General. This section describes property tax levy and collection procedures and certain information regarding historical assessed values and major property tax payers in the City. Property taxes represent one of the largest source of tax revenue to the City at approximately 16% in Fiscal Year 2020-21 of General Fund total revenues. The City has received approximately $13.1 million in property tax revenue for Fiscal Year 2020-21 (9% growth over prior year). The revenue growth is attributable to the 2% statutory inflationary increase on Assessed Valuation related to Proposition 13, as well as a steady increase in home sales and new construction that is expected to continue for several years. See " — Assessed Valuation" below. M, Property taxes have historically been the primary revenue source affected by voter initiatives and legislative actions. See "CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS" and "RISK FACTORS — Limitations on Taxes and Fees." ERAF Shift Legislation. Certain property taxes have been shifted from local government agencies to schools by the State Legislature for deposit in the Education Revenue Augmentation Fund ("ERAF"), a shift that has resulted in diversion of City property taxes since Fiscal Year 1992-93. Levy and Collection. Property taxes are levied for each Fiscal Year on taxable real and personal property as of the preceding January 1. For assessment and collection purposes, property is classified either as "secured" or "unsecured" and is listed accordingly on separate parts of the assessment roll. The "secured roll" is that part of the assessment roll containing State -assessed public utilities property and real property the taxes on which are a lien sufficient, in the opinion of the County Assessor, to secure payment of the taxes. Other property is assessed on the "unsecured roll." Property taxes on the secured roll are due in two installments, on November 1 and February 1 of each Fiscal Year, and become delinquent on December 10 and April 10, respectively. A penalty of 10% attaches immediately to all delinquent payments. Property on the secured roll with respect to which taxes are delinquent become tax defaulted on or about June 30 of the Fiscal Year. Such property may thereafter be redeemed by payment of a penalty of 1.5% per month to the time of redemption, plus costs and a redemption fee. If taxes are unpaid for a period of five years or more, the property may be sold at public auction. Property taxes on the unsecured roll are due as of the January 1 lien dates and become delinquent on August 31. A 10% penalty attaches to delinquent unsecured taxes. If unsecured taxes are unpaid at 5:00 p.m. on October 31, an additional penalty of 1.5% attaches to them on the first day of each month until paid. The County has four ways of collecting delinquent unsecured personal property taxes: (1) a civil action against the taxpayer; (2) filing a judgment in the office of the County Clerk specifying certain facts in order to obtain a 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 lien on certain property of the taxpayer; and (4) seizure and sale of personal property, improvements or possessory interests belonging or assessed to the assessee. Assessed Valuation. All property is assessed using full cash value as defined by Article XIIIA of the State Constitution. State law provides exemptions from ad valorem property taxation for certain classes of property such as churches, colleges, non-profit hospitals, and charitable institutions. See "CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS." Future assessed valuation growth allowed under Article XIIIA of the State Constitution (new construction, certain changes of ownership, 2% inflation) will be allocated on the basis of "situs" among the jurisdictions that serve the tax rate area within which the growth occurs. Local agencies and schools will share the growth of "base" revenues from the tax rate area. Each year's growth allocation becomes part of each agency's allocation in the following year. 27 Assessed Valuation History. The following table shows a ten-year history of the City's assessed valuation. Table 6 Assessed Value of Taxable Property Fiscal Years 2011-12 through 2020-21 (Dollar amounts in thousands) Fiscal Year Secured Roll Utility Roll Unsecured Roll Total Less Exemptions Net Assessed Value 2011-12 $4,738,823 $2,382 $226,651 $4,967,856 $314,448 $4,653,408 2012-13 4,737,807 2,382 233,398 4,973,587 327,783 4,645,804 2013-14 4,895,091 3,490 230,827 5,129,408 324,439 4,804,969 2014-15 5,156,704 3,490 257,856 5,418,050 326,833 5,091,217 2015-16 5,394,659 3,490 250,160 5,648,309 331,562 5,316,747 2016-17 5,603,023 2,299 254,946 5,860,268 334,485 5,525,783 2017-18 5,903,144 2,299 266,956 6,172,399 339,542 5,832,857 2018-19 6,174,155 2,299 258,682 6,435,136 345,178 6,089,958 2019-20 6,566,183 1,901 247,608 6,815,692 338,170 6,477,522 2020-21 6,962,679 2,047 231,423 7,196,149 353,561 6,842,588 Source: City of Lodi Annual Comprehensive Financial Report for the Year Ended June 30, 2021. Proposition 13 and Proposition 8 Property Value Adjustments. Proposition 13, adopted in 1978, established the base year value concept for property tax assessments. Under Proposition 13, the 1975-76 Fiscal Year serves as the original base year used in determining the assessment for real property. Thereafter, annual increases to the base year value are limited to the inflation rate, as measured by the California Consumer Price Index, or 2%, whichever is less. A new base year value, however, is generally established whenever a property, or portion thereof, has had a change in ownership or has been newly constructed. Proposition 8, enacted in 1978, allows for a temporary reduction in assessed value when a property suffers a "decline -in -value." As of January 1st (lien date) each year, the Assessor must enroll either a property's Proposition 13 value (adjusted annually for inflation by no more than 2%) or its current market value, whichever is less. When the current market value replaces the higher Proposition 13 value, the lower value is commonly referred to as a "Proposition 8 Value." "Proposition 8 values" are temporary and, once enrolled, must be reviewed annually by the assessor until the Proposition 13 adjusted base year value is enrolled. 28 Ten Largest Locally Secured Taxpayers. The following table shows ten largest locally secured taxpayers of the City for the Fiscal Year ended June 30, 2021, the most recent year for which such information is available, based on total taxable assessed valuation. Table 7 Principal Property Tax Payers (Dollar amounts in thousands) Source: City of Lodi Annual Comprehensive Financial Report for the Year Ended June 30, 2021. Teeter Plan. The Board of Supervisors of the County has approved the implementation of the Alternative Method of Distribution of Tax Levies and Collections and of Tax Sale Proceeds (the "Teeter Plan"), as provided for in Section 4701 et seq. of the California Revenue and Taxation Code. Under the Teeter Plan, the County apportions secured property taxes on an accrual basis when due (irrespective of actual collections) to local political subdivisions, including the City, for which the County acts as the tax -levying or tax -collecting agency. As a result, the City currently receives 100% of such levy and is not impacted by delinquencies in payment. The Teeter Plan is applicable to all tax levies on secured property for which the County acts as the tax -levying or tax -collecting agency, or for which the County treasury is the legal depository of the tax collections. The Teeter Plan is to remain in effect unless the Board of Supervisors of the County orders its discontinuance or unless, prior to the commencement of any fiscal year of the County (which commences on July 1), the Board of Supervisors receives a petition for its discontinuance joined in by resolutions adopted by at least two-thirds of the participating revenue districts in the County, in which event the Board of Supervisors is to order discontinuance of the Teeter Plan effective at the commencement of the subsequent fiscal year. If the Teeter Plan is discontinued subsequent to its implementation, only those secured property taxes actually collected would be allocated to political subdivisions (including the City) for which the County acts as the tax -levying or tax -collecting agency. 29 Percentage of Total City Taxable Taxable Assessed Assessed Taxpayer Value Rank Value Pacific Coast Producers $112,642 1 1.650% Calif Physicians Service Corp 54,565 2 0.800 Reynolds Ranch Sr Development Company LP 41,631 3 0.610 Big Box Property Owner E LLC 39,130 4 0.570 Cal -Purina Associates LP 34,545 5 0.510 Wal Mart Real Est Business Trust 32,665 6 0.480 Cepheid 32,217 7 0.470 Cottage Bakery Inc Et al 30,274 8 0.440 Winterfell Vintage CA Owner LP 30,134 9 0.410 Sandpiper Pennebaker Group LLC 28,272 10 0.300 TOP TEN TOTAL $436,075 6.240% Source: City of Lodi Annual Comprehensive Financial Report for the Year Ended June 30, 2021. Teeter Plan. The Board of Supervisors of the County has approved the implementation of the Alternative Method of Distribution of Tax Levies and Collections and of Tax Sale Proceeds (the "Teeter Plan"), as provided for in Section 4701 et seq. of the California Revenue and Taxation Code. Under the Teeter Plan, the County apportions secured property taxes on an accrual basis when due (irrespective of actual collections) to local political subdivisions, including the City, for which the County acts as the tax -levying or tax -collecting agency. As a result, the City currently receives 100% of such levy and is not impacted by delinquencies in payment. The Teeter Plan is applicable to all tax levies on secured property for which the County acts as the tax -levying or tax -collecting agency, or for which the County treasury is the legal depository of the tax collections. The Teeter Plan is to remain in effect unless the Board of Supervisors of the County orders its discontinuance or unless, prior to the commencement of any fiscal year of the County (which commences on July 1), the Board of Supervisors receives a petition for its discontinuance joined in by resolutions adopted by at least two-thirds of the participating revenue districts in the County, in which event the Board of Supervisors is to order discontinuance of the Teeter Plan effective at the commencement of the subsequent fiscal year. If the Teeter Plan is discontinued subsequent to its implementation, only those secured property taxes actually collected would be allocated to political subdivisions (including the City) for which the County acts as the tax -levying or tax -collecting agency. 29 In Lieu Franchise. Starting in 2007 the City's Electric Utility has made an annual payment to the City's General Fund as a payment in lieu of taxes ("PILOT"). The City Council established a formula in 2007 for the preexisting PILOT by Resolution 2007-25. The formula is based upon the net amount of the PILOT in 2006-07 budget year as adjusted by the annual percentage increase in the number of accounts. As expressly intended and anticipated by Resolution 2007-25, the new formula has effectively reduced the PILOT as a percentage of Electric Utility revenues since its adoption. California voters passed Proposition 26 in November of 2010, adding to the Constitution new definitions of the term "tax" and —as a result — added new limitations on the adoption of revenue measures defined by Proposition 26 to be a tax. In reliance on the 2018 decision of the California Supreme Court in Citizens for Fair REU Rates v. City of Redding, 6 Cal. 5th 1 (2018), the City does not believe that its PILOT is subject to Proposition 26. The Court found that a budgetary transfer from the City of Redding's electric utility enterprise fund to the city's general fund itself is not a tax. Further, as the City interprets Proposition 26, it is neither retroactive as to local government; nor does it apply to formulas for increasing revenue measures which formulas were established prior to the November 3, 2010 effective date of Proposition 26. However, the provisions of Proposition 26 are subject to judicial interpretation, and there can be no assurances that, if challenged, a court would not find that the PILOT violates Proposition 26 on grounds different from those in the Redding case. In such circumstances there can be no assurances that the City would not be required to discontinue the collection of the PILOT, and refund all or a portion of the PILOT collected after the passage of Proposition 26. The PILOT is budgeted to constitute approximately 11% of General Fund revenues in Fiscal Year 2021-22. See "CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS." Outstanding General Fund Debt and Lease Obligations The City currently has no outstanding general fund general obligation bonds outstanding. The 2012 Bonds currently constitute the only bonds payable from the General Fund. In addition, the City has an outstanding capital lease for dispatch equipment for the police department, which requires scheduled payments in Fiscal Years 2021-22 and 2022-23 with a total present value (as of June 30, 2021) totaling $173,080. In connection with the City's electric, water and wastewater utilities, the City has entered into installment purchase agreements, leases and other contractual commitments in connection with the financing of various facilities. These obligations are payable from the respective enterprise funds of the City, and are not payable from the General Fund. Employee Relations City employees are represented by various associations, and labor relations have been generally amicable in that there have been no major strikes, work stoppages or other similar incidents. The following table provides a list of departments in the City and the number of employees within these departments for Fiscal Year 2021-22. 30 Table 8 Employee Organizations Bargaining Group IBEW Fire Mid Management Lodi Police Dispatchers Association Police Officer's Association of Lodi Lodi Police Mid -Management Association Lodi Professional Firefighters Lodi City Mid -Management Association AFSCME General Services AFSCME Maintenance and Operators Total Source: City of Lodi. Contract Fiscal Year 2021-22 Expiration Date Budgeted Staff 12/31/2024 40 6/30/2022 5 6/30/2022 18 6/30/2022 60 6/30/2022 17 12/31/2022 49 12/31/2022 44 12/31/2022 79 12/31/2022 80 392 Of the 392 budgeted positions, 214 reside in the General Fund. The City provides retirement and other post -employment benefits to City employees. See " — Retirement System" herein. Retirement System This caption contains certain information relating to California Public Employees' Retirement System ("CaIPERS'). The information is primarily derived from the City's Comprehensive Annual Financial Report and information produced by CaIPERS, its independent accountants and actuaries. The City has not independently verified the information provided by Ca/PERS and makes no representations and expresses no opinion as to the accuracy of the information provided by CaIPERS. The comprehensive annual financial reports of Ca/PERS are available on its Internet website at www.calpers.ca.gov. The CaIPERS website also contains CaIPERS' most recent actuarial valuation reports and other information concerning benefits and other matters. Such information is not incorporated by reference in this Official Statement. None of the Authority, City or Purchaser can guarantee the accuracy of such information. Actuarial assessments are "forward-looking" statements that reflect the judgment of the fiduciaries of the pension plans, and are based upon a variety of assumptions, one or more of which may not materialize or may be changed in the future. Actuarial assessments will change with the future experience of the pension plans. Description of Plans. All qualified permanent and probationary employees are eligible to participate in the City's separate Miscellaneous and Safety Plans (the "Plans"), agent multiple -employer defined benefit pension plans administered by the California Public Employees' Retirement System ("CaIPERS"), which acts as a common investment and administrative agent for its participating member employers. Benefit provisions under the Plans are established by State statute and City resolution. Benefits Provided. CaIPERS provides service retirement and disability benefits, annual cost of living adjustments and death benefits to plan members, who must be public employees 31 and beneficiaries. Benefits are based on years of credited service, equal to one year of full-time employment. Members with five years of total service are eligible to retire at age 50 with statutorily reduced benefits. All members are eligible for non -duty disability benefits after 10 years of service. The death benefit is one of the following: the Basic Death Benefit, the 1957 Survivor Benefit, or the Optional Settlement 2W Death Benefit. The cost of living adjustments for each plan are applied as specified by the Public Employees' Retirement Law. Miscellaneous Plan Hire Date Benefit formula Benefit vesting schedule Benefit payments Retirement age Monthly benefit, as % of eligible compensation Required employee contribution rates Required employer contribution rates Prior to January 1, On or after January 1, 2013 2013 2% @ 55 5 yrs of service Monthly for life 50-67 1.426%-2.418% 7% 21.80% 2% @ 62 5 yrs of service Monthly for life 52-67 1%-2.5% 6.75% 21.80% Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. Hire Date Benefit formula Benefit vesting schedule Benefit payments Retirement age Monthly benefit, as % of eligible compensation Required employee contribution rates Required employer contribution rates Safety Plan Prior to December 22, 2012 3% @ 50 5 yrs of service Monthly for life 50-55 3% 9% 44.75% December 22, 2012 to December 31, 2012 3% @ 55 5 yrs of service Monthly for life 50-55 2.4%-3% 9% 44.75% Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. On or after January 1, 2013 2.7% @ 57 5 yrs of service Monthly for life 50-57 2%-2.7% 11.25% 44.75% Employees Covered. As of June 30, 2021, the most recent actuarial valuation available, the following employees were covered by the benefit terms of each Plan: Miscellaneous Safety Inactive employees or beneficiaries currently receiving benefits 135 115 Inactive employees entitled to but not yet receiving benefits 116 46 Active employees 269 24 Total 520 185 Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. California Public Employees' Pension Reform Act of 2013. Employees hired prior to January 1, 2013 and have remained under continuous employment with a CalPERS agency are considered "Classic" employees. California Public Employees' Pension Reform Act of 2013 ("PEPRA"), which was signed by the State Governor on September 12, 2012, established a new pension benefit tier for employees who were hired on and after January 1, 2013, who were not 32 previously CalPERS members or have left employment with a CaIPERS agency for more than 6 months. PEPRA adjusted the benefit formulas, required employee contribution, calculation of benefits and maximum pay, as well as other benefits. PEPRA employees receive the following benefit formulas: (i) 2.0% at age 62 formula for Miscellaneous employees; and (ii) 2.7% at age 57 for Safety employees. Employees are required to pay at least 50% of the total (annual) normal cost rate, and are required to make the full amount of required employee contributions themselves under PEPRA. Retirement benefits for such employees are calculated on the highest average annual compensation over a consecutive 36 -month period. Accordingly, retirement benefits for PEPRA miscellaneous employees are calculated as 2% of the average final 36 months compensation and retirement benefits for PEPRA safety employees are calculated as 2.7% of the average final 36 months of compensation. Retirement benefits for Classic miscellaneous employees are calculated as 2% of the average final 12 months of compensation and retirement benefits for Classic safety employees are calculated as 3% of the average final 12 months compensation. Retroactive benefits increases are also prohibited, as are contribution holidays, and purchases of additional non-qualified service credit. PEPRA also capped pensionable income as noted below. Maximum amounts are set annually, subject to adjustment in accord with the Consumer Price Index. Required Contributions. Section 20814(c) of the Retirement Law requires that the employer contribution rates for all public employers be determined on an annual basis by the actuary and shall be effective on the July 1 following notice of a change in the rate. The total plan contributions are determined through the CalPERS annual actuarial valuation process. The actuarially determined rate is the estimated amount necessary to finance the costs of benefits earned by employees during the year, with an additional amount to finance any unfunded accrued liability. The City is required to contribute the difference between the actuarially determined rate and the contribution rate of the employees. The City contribution rates may change if plan contracts are amended. Beginning in Fiscal Year 2017-18, CalPERS collects employer contributions for each plan as a percentage of payroll for the normal cost portion and as a dollar amount for contributions toward the UAL. The dollar amounts are billed on an annual basis. The actuarially determined normal cost rates and UAL contribution amounts for each Plan for Fiscal Years 2020-21, 2021-22 and 2022-23 are as follows: Fiscal Year 2020-21 Fiscal Year 2021-22 Fiscal Year 2022-23 Employer Employer Employer Employer Employer Employer Normal Payment Normal Payment Normal Payment Cost Rate of UAL Cost Rate of UAL Cost Rate of UAL Miscellaneous Plan 9.788% $4,595,521 9.29% $5,135,202 9.33% $5,381,579 Safety 19.444% $5,581,042 18.75% $6,138,313 17.95% $6,644,544 Source: Ca1PERS Actuarial Reports dated July 2019, July 2020 and July 2021. 33 The City's estimated total contribution amounts (including the required normal cost and UAL contributions) and as a percentage of estimated covered payroll for the Plans in Fiscal Years 2020-21, 2021-22, and 2022-23 are as follows: Fiscal Year 2020-21 Fiscal Year 2021-22 Fiscal Year 2022-23 Total % of Total % of Total % of Employer Covered Employer Covered Employer Covered Contribution Payroll Contribution Payroll Contribution Payroll Miscellaneous Plan $6,482,251 33.629% $7,033,549 34.42% $7,318,390 35.25% Safety $7,793,943 68.483% $8,477,415 67.95% $9,119,881 66.13% Source: CaIPERS Actuarial Reports dated, July 2019, July 2020 and July 2021. Projected Employer Contributions. The following tables show the City's actuarially - determined required employer contribution for Fiscal Year 2022-23 and projected employer contributions (before cost sharing) for Fiscal Years 2023-24 through 2027-28 for each Plan by normal cost (expressed as a percentage of total active payroll) and amortization of the unfunded accrued liability (expressed as a dollar amount). The projections assume a 7.00% annual rate of return for Fiscal Year 2020-21 but do not include any reductions in the normal cost that will occur over time as new employees are hired into PEPRA or other lower cost benefit tiers. Miscellaneous Plan Required Contribution Projected Future Employer Contributions Assumes 7.00% Return for Fiscal Year 2020-21 Fiscal Year 2022-23 2023-24 Fiscal Year 2022-23 2023-24 2024-25 2025-26 2026-27 2027-28 Normal Cost % 9.33% 9.2% 9.1% 8.9% 8.8% 8.7% UAL Payment $5,381,579 $5,740,000 $6,114,000 $5,943,000 $6,233,000 $6,389,000 Safety Plan Required Contribution Projected Future Employer Contributions Assumes 7.00% Return for Fiscal Year 2020-21 Fiscal Year 2022-23 2023-24 2024-25 2025-26 2026-27 2027-28 Normal Cost % 17.95% 17.8% 17.5% 17.3% 17.0% 16.7% UAL Payment $6,644,544 $7,065,000 $7,494,000 $7,776,000 $8,049,000 $8,254,000 Source: Ca1PERS Actuarial Reports dated July 2021. 34 Funded Status. The following table sets forth the schedule of funding for the Plans for the actuarial valuations as of June 30 of the years 2017 through 2020. Source: CaIPERS Actuarial Reports Dated July 2021 There is a two-year lag between the valuation date and the start of the contribution Fiscal Year. The UAL was determined in the June 30, 2020 actuarial valuation, but the corresponding UAL payments commence two years after the valuation date in Fiscal Year 2022- 23. This two-year lag is necessary due to the amount of time needed to extract and test the membership and financial data, and the need to provide public agencies with their required employer contribution well in advance of the start of the Fiscal Year. Net Pension Liability. The City's net pension liability for the Miscellaneous Plan and the Safety Plan totaled approximately $63.3 million and $83.8 million, respectively, measured as of June 30, 2019, using an actuarial valuation as of June 30, 2018 rolled forward to June 30, 2019 using standard update procedures. For the year ended June 30, 2021, the City recognized pension expense of $5,496,434 for the Miscellaneous Plan and $6,847,548 for the Safety Plan. Sensitivity to Changes in Discount Rate. The discount rate used to measure the total pension liability at June 30, 2019 with respect to the Plans was 7.15%. The following tables present the City's proportionate share of the net pension liability for the Miscellaneous Plan and the Safety Plan, calculated using the discount rate for the Plans, as well as what the City's net pension liability would be if it were calculated using a discount rate that is 100 basis points higher or 100 basis points lower than the current rate: Miscellaneous Plan 1% Decrease (6.15%) Discount Rate (7.15%) 1% Increase (8.15%) Net Pension Liability $89,658,828 $63,329,327 $41,451,990 Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. 35 Unfunded Valuation Date Accrued Market Value of Accrued Funded Annual Covered Ended June 30 Liability Assets (MVA) Liability Ratio Payroll Miscellaneous Plan 2017 $188,723,738 132,013,927 $56,709,811 70.0% $18,487,271 2018 201,144,399 138,770,921 62,373,478 69.0 17,769,303 2019 207,262,408 143,558,757 63,703,651 69.3 18,837,110 2020 214,092,376 146,008,797 68,083,579 68.2 19,136,393 Safety Plan 2017 $187,202,314 $111,871,224 $75,331,090 59.8% $11,568,201 2018 201,528,295 118,166,810 83,361,485 58.6 10,491,335 2019 207,837,399 123,051,225 84,786,174 59.2 11,500,121 2020 216,958,916 126,462,975 90,495,941 58.3 12,712,307 Source: CaIPERS Actuarial Reports Dated July 2021 There is a two-year lag between the valuation date and the start of the contribution Fiscal Year. The UAL was determined in the June 30, 2020 actuarial valuation, but the corresponding UAL payments commence two years after the valuation date in Fiscal Year 2022- 23. This two-year lag is necessary due to the amount of time needed to extract and test the membership and financial data, and the need to provide public agencies with their required employer contribution well in advance of the start of the Fiscal Year. Net Pension Liability. The City's net pension liability for the Miscellaneous Plan and the Safety Plan totaled approximately $63.3 million and $83.8 million, respectively, measured as of June 30, 2019, using an actuarial valuation as of June 30, 2018 rolled forward to June 30, 2019 using standard update procedures. For the year ended June 30, 2021, the City recognized pension expense of $5,496,434 for the Miscellaneous Plan and $6,847,548 for the Safety Plan. Sensitivity to Changes in Discount Rate. The discount rate used to measure the total pension liability at June 30, 2019 with respect to the Plans was 7.15%. The following tables present the City's proportionate share of the net pension liability for the Miscellaneous Plan and the Safety Plan, calculated using the discount rate for the Plans, as well as what the City's net pension liability would be if it were calculated using a discount rate that is 100 basis points higher or 100 basis points lower than the current rate: Miscellaneous Plan 1% Decrease (6.15%) Discount Rate (7.15%) 1% Increase (8.15%) Net Pension Liability $89,658,828 $63,329,327 $41,451,990 Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. 35 Safety Plan 1 % Decrease (6.15%) Discount Rate (7.15%) 1% Increase 8.15%) Net Pension Liability $112,354,313 $83,825,883 $60,406,238 Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. Pension Stabilization Fund and Pension Funding Policy. To address the issue of rising pension costs and UAL in the Plans, the City adopted a Pension Stabilization Policy (the "PSP") and created the Pension Stabilization Fund in late 2016 and first funded the Pension Stabilization Fund in April 2017. As of December 31, 2021, the Pension Stabilization Fund had a balance of $21,245,657. The PSF is held at Public Agency Retirement Services (PARS). The PSP requires 100% of General Fund reserves in excess of the 16% General Fund reserve target to be deposited into the Pension Stabilization Fund. All other funds invest a proportional share based on the budgeted pension obligations in each fiscal year. The PSP remains in effect until the funded status of the two Plans are at a combined 80% funded status when considering the market value of assets at CalPERS and funds in the Pension Stabilization Fund. As of the June 30, 2020 actuarial report (the most recent available report), the funded status for the Miscellaneous Plan was 68.2%, the funded status for the Safety Plan was 58.3%, and the funded status for the combined Plans was 63.2%. As of December 31, 2021, the combined funded status when considering the Pension Stabilization Fund assets increases to 68.1%, or an improvement of 4.9% over the funded ratio when considering assets at CalPERS alone. Due to the uncertainty of the financial impact of the COVID-19 pandemic, the City suspended contributions to the Pension Stabilization Fund during Fiscal Year 2020-21. However, due to stronger than anticipated revenues during the COVID-19 pandemic, the PSP was reinstated with the adoption of the Fiscal Year 2021-22 budget. In addition, partway through Fiscal Year 2020-21. the City Council elected to use the Fiscal Year 2019-20 fund balance in excess of reserves that would have otherwise been deposited into the Pension Stabilization Fund to make additional discretionary payments ("ADPs") to CalPERS, which directly reduces the City's liability with CaIPERS. In addition to funding the Pension Stabilization Fund, the PSP requires the City to budget the UAL portion of the pension bill at the monthly payment provided by CaIPERS, but to pay at the annual amount each July. The annual amount is approximately a 3.6% discount from the monthly amount due to expected earnings. The PSP further requires the City to take the additional 3.6% and use it to make ADPs to CalPERS to reduce pension liability. The City has executed this portion of the PSP every fiscal year beginning with the Fiscal Year 2018-19 budget year. Potential Impacts on Future Required Contributions. The CalPERS Board of Administration has adjusted and may in the future further adjust certain assumptions used in the CalPERS actuarial valuations, which adjustments may increase the City's required contributions to CalPERS in future years. Accordingly, the City cannot provide any assurances that the City's required contributions to CalPERS in future years will not significantly increase (or otherwise vary) from any past or current projected levels of contributions. Change in Assumptions/Discount Rate. On December 21, 2016, the CalPERS Board of Administration voted to lower its discount rate from the then -current rate of 7.50% to 7.00% over a three-year period. The change was reflected in the June 30, 2016 actuarial report, which 36 lowered the discount rate from 7.50% to 7.375%; in the June 30, 2017 actuarial report, which lowered the discount rate from 7.375% to 7.25%; and in the June 30, 2018 actuarial report, which lowered the discount rate from 7.25% to 7.00%. CalPERS further reduced the discount rate to 6.8% in September 2021. Investment Performance. CalPERS earnings reports for Fiscal Years 2010 through 2020 report investment gains of approximately 13.3%, 21.7%, 0.1%, 13.2%, 18.4%, 2.4%, 0.6%, 11.2%, 8.6%, 6.7% and 4.7%, respectively. The CalPERS Fiscal Year 2019-20 investment gain of 4.7% is not included as an amortization base in the most recent CalPERS valuation report and is not reflected in the numbers included herein. Future earnings performance may increase or decrease future contribution rates for plan participants, including the City. CalPERS has preliminarily reported a 21.3% investment return for Fiscal Year 2020- 21. The CaIPERS website contains the most recent actuarial valuation reports for the City's Miscellaneous Plan and Safety Plan and other information that concerns benefits and other matters. The Comprehensive Annual financial reports of Ca/PERS are also available on CaIPERS' Internet website at www.calpers.ca.gov. The textual reference to such Internet website is provided for convenience only. None of the information on such Internet website is incorporated by reference herein. Neither the City nor the Underwriter guarantee the accuracy of such information. See "APPENDIX B — ANNUAL COMPREHENSIVE FINANCIAL REPORT OF THE CITY FOR THE FISCAL YEAR ENDED JUNE 30, 2021 — Note 8" for additional information regarding the Plans, including a description of the actuarial methods and assumptions used to measure the City's net pension liability as of the June 30, 2019 measurement date. Other Post -Employment Benefits Plan Description. The City sponsors a single -employer defined -benefit postemployment healthcare plan (the "Retiree Health Plan") to provide medical insurance benefits to eligible retired employees and their spouses. The Plan does not issue a publicly available financial report. Medical coverage is provided through CalPERS healthcare program. Employees who retire from the City and receive a CalPERS pension are eligible for postemployment medical benefits. The City contributes the minimum amount provided under Government Code Section 22825 of the Public Employees Medical and Hospital Care Act. In general, retirees must contribute any premium amounts in excess of the City contribution. However, as described below, a closed group of active employees and retirees receive additional postemployment benefits. Employees hired prior to the dates shown in the following table are allowed to convert their accumulated sick leave into postemployment medical benefits at retirement as long as they have ten or more years of service with the City. Group Executive Management Mid -Management Fire Mid -Management Police Mid -Management General Services IBEW 37 Hired Prior to: July 1, 1994 July 1, 1994 December 6, 1995 July 1, 1994 July 1, 1995 July 1, 1995 Maintenance and Operators July 1, 1995 Dispatchers July 1, 1994 Police October 10, 1994 Fire December 6, 1995 Funding Policy. Contribution requirements of the Retiree Health Plan are based on pay-as-you-go financing. The City's policy is to fund the normal cost (current accrual for benefits being earned) plus an amortization of the net (unfunded accrued) OPEB liability. For fiscal year 2020-21, the City contributed $1,772,822. Net OPEB Liability. As of the June 30, 2019 measurement date, the City's actuarial accrued OPEB liability was approximately $26.4 million. The actuarial value of plan assets was approximately $2.0 million, resulting in an unfunded actuarial accrued OPEB liability of approximately $24.4 million. The following presents the OPEB liability of the City if it were calculated using a discount rate that is one percentage point lower or one percentage point higher than the current rate, for measurement period ended June 30, 2019: Discount Rate — 1 % 2.56% Net OPEB Liability $27,181,396 Current Discount Rate 3.56% $24,358,432 Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. Discount Rate + 1 % 4.56% $21,984,101 Actuarial valuations of an ongoing plan involve estimates of the value of reported amounts and assumptions about the probability of occurrence of events far into the future. Examples include assumptions about future employment, mortality, and the healthcare cost trend. Amounts determined regarding the funded status of the plan and the annual required contributions of the employer are subject to continual revision as actual results are compared with past expectations and new estimates are made about the future. 38 OPEB Expense and Deferred Outflows/Inflows of Resources Related to OPEB. For the fiscal year ended June 30, 2021, the City recognized OPEB expense of $1,836,904. At June 30, 2021, the City reported deferred outflows of resources related to OPEB from the following sources: Deferred Outflows of Deferred inflows of Resources Resources Contributions subsequent to measurement date $1,885,306 - Change of assumptions - $3,220,278 Difference between expected and actual liability - 4,393,056 Difference between expected and actual investment earnings 6,649 Total $1,891,955 $7,613,334 Source: City of Lodi Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2021. The $1,885,306 reported as deferred outflows of resources related to contributions subsequent to the measurement date will be recognized as a reduction of the net OPEB liability during the fiscal year ended June 30, 2021. The other amounts reported as deferred outflows of resources and deferred inflows of resources related to OPEB will be recognized as OPEB expense as follows: $(1,498,756) in the fiscal year ended June 30, 2022, $(1,490,544) in the fiscal year ended June 30, 2023, $(1,491,725) in the fiscal year ended June 30, 2024, $(1,163,749) in the fiscal year ended June 30, 2025, $(1,111,720) in the fiscal year ended June 30, 2026, and $(850,191) thereafter. See "APPENDIX B — COMPREHENSIVE ANNUAL FINANCIAL REPORT OF THE CITY FOR THE FISCAL YEAR ENDED JUNE 30, 2021 — Note 9" for additional information regarding the Retiree Health Plan, including a description of the actuarial methods and assumptions used to measure the City's net OPEB liability as of the June 30, 2019 measurement date. City Investments All funds of the City are invested by the City in accordance with the investment guidelines of the California Government Code (Section 53601 and 53635) and the City's Investment Policy, which is presented annually to the City Council for approval. Pursuant to the Investment Policy, the policy of the City is to invest public funds in a manner which will provide a sound investment return with maximum security while meeting the daily cash flow demands of the entity and conforming to all state and local statues governing the investment of public funds. The City's investment policy has three objectives: (1) protect principal, (2) provide for liquidity needs, and (3) obtain the most reasonable rate of return possible within the first two objectives. The Investment Policy may be changed at any time at the discretion of the City Council (subject to State of California law provisions relating to authorized investments) and as the California Government Code is amended. There can be no assurance, therefore, that the State of California law and/or the Investment Policy will not be amended in the future to allow for investments which are not currently permitted under such State law or the Investment Policy, or that the objectives of the City with respect to investments will not change. All investments, including the Authorized Investments and those authorized by law from time to time for 39 investments by public agencies, 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 receipt of principal. The occurrence of these events with respect to amounts held under the Indenture and the Installment Purchase Agreement, or other amounts held by the City, could have a material adverse effect on the City's finances. below. A summary of the City's pooled investment portfolio as of December 31, 2021 is set forth Table 9 Investment Portfolio Summary Type of Investment Market Value Cash and Equivalents $65,748,019 Bond Mutual Funds 10,464,224 Local Bank Certificates of Deposit 2,000,000 Negotiable Certificates of Deposit 6,408,191 Agency Securities 7,761,742 US Treasury Notes 8,589,545 Corporate Securities 23,379,664 Municipal Securities 34,833,381 Supranational Securities 4,447,051 Total $163,631,817 we, Percent of Total 40.18% 6.39 1.22 3.92 4.74 5.25 14.29 21.29 2.72 100.00% Estimated Direct and Overlapping Bonded Debt The estimated direct and overlapping bonded debt of the City as of February 1, 2022 is set forth below. 2021-22 Assessed Valuation: $7,353,233,712 OVERLAPPING TAX AND ASSESSMENT DEBT: % Applicable Debt 2/1/22 San Joaquin Delta Community College District 7.725% $ 14,560,080 Lodi Unified School District 36.895 111,496,690 TOTAL OVERLAPPING TAX AND ASSESSMENT DEBT $126,056,770 DIRECT AND OVERLAPPING GENERAL FUND DEBT: San Joaquin County Certificates of Participation 8.095% $ 4,889,380 Lodi Unified School District Certificates of Participation 36.895 3,713,482 City of Lodi General Fund Obligations 100.000 13,315,0000) TOTAL DIRECT AND OVERLAPPING GENERAL FUND DEBT $21,917,862 COMBINED TOTAL DEBT Ratios to 2021-22 Assessed Valuation: Total Overlapping Tax and Assessment Debt ..... 1.71% Total Direct Debt ($13,315,000) ....................... 0.18% Combined Total Debt .......................................... 2.01% $147,974,632(2) (1) Excludes the Bonds. (2) Excludes tax and revenue anticipation notes, enterprise revenue, mortgage revenue and non -bonded capital lease obligations Source: California Municipal Statistics, Inc. Risk Management The City is self-insured for dental care, long-term disability, workers' compensation, general liability and unemployment insurance. General liability and workers' compensation are administered by outside agencies. The City administers unemployment insurance and long-term disability. Self-insurance transactions are accounted for under the Insurance Funds. At June 30, 2021, the Insurance Fund had a net position of $7,798,135. CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS The constitutional and statutory provisions discussed in this section have the potential to affect the ability of the City to levy taxes and spend tax proceeds for operating and other purposes. Article XIIIA of the State Constitution On June 6, 1978, California voters approved Proposition 13, which added Article XIIIA to the State Constitution. Article XIIIA, as amended, limits the amount of any ad valorem tax on real property to one percent of the full cash value thereof, except that additional ad valorem taxes may be levied to pay debt service (i) on indebtedness approved by the voters prior to July 1, 1978, (ii) on bonded indebtedness approved by a two-thirds 41 vote on or after July 1, 1978, for the acquisition or improvement of real property or (iii) bonded indebtedness incurred by a school district, community college district or county office of education for the construction, reconstruction, rehabilitation or replacement of school facilities, including the furnishing and equipping of school facilities or the acquisition or lease of real property for school facilities, approved by 55 percent of the voters voting on the proposition. Article XIIIA defines full cash value to mean "the county assessor's valuation of real 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." This full cash value may be increased at a rate not to exceed two percent per year to account for inflation. Article XIIIA has subsequently been amended to permit reduction of the "full cash value" base in the event of declining property values caused by damage, destruction or other factors, to provide that there would be no increase in the "full cash value" base in the event of reconstruction of property damaged or destroyed in a disaster, and in other minor or technical ways. Legislation Implementing Article XIIIA Legislation has been enacted and amended a number of times since 1978 to implement Article XIIIA. Under current law, local agencies are no longer permitted to levy directly any property tax (except to pay voter -approved indebtedness). The one percent property tax is automatically levied by the County and distributed according to a formula among taxing agencies. The formula apportions the tax roughly in proportion to the relative shares of taxes levied prior to 1989. Increases of assessed valuation resulting from reappraisals of property due to new construction, change in ownership or from the two percent annual adjustment are allocated among the various jurisdictions in the "taxing area" based upon their respective "situs." Any such allocation made to a local agency continues as part of its allocation in future years. All taxable property is shown at full market value on the tax rolls. Consequently, the tax rate is expressed as $1 per $100 of taxable value. All taxable property value included in this Official Statement is shown at 100 percent of market value (unless noted differently) and all tax rates reflect the $1 per $100 of taxable value. Article XIIB of the State Constitution In addition to the limits Article XIIIA imposes on property taxes that may be collected by local governments, certain other revenues of the State and most local governments are subject to an annual "appropriations limit" imposed by Article XIIIB which effectively limits the amount of such revenues those entities are permitted to spend. Article XIIIB, approved by the voters in June 1979, was modified substantially by Proposition 111 in 1990. The appropriations limit of each government entity applies to "proceeds of taxes," which consist of tax revenues, State subventions and certain other funds, including proceeds from regulatory licenses, user charges or other fees to the extent that such proceeds exceed "the cost reasonably borne by such entity in providing the regulation, product or service." "Proceeds of taxes" excludes tax refunds and some benefit payments such as unemployment insurance. No limit is imposed on the appropriation of funds which are not "proceeds of taxes," such as reasonable user charges or fees, and certain other non -tax funds. Article XIIIB also does not limit appropriation of local revenues to pay debt service on Bonds existing or authorized by January 1, 1979, or 42 subsequently authorized by the voters, appropriations required to comply with mandates of courts or the federal government, appropriations for qualified capital outlay projects, and appropriation by the State of revenues derived from any increase in gasoline taxes and motor vehicle weight fees above January 1, 1990, levels. The appropriations limit may also be exceeded in case of emergency; however, the appropriations limit for the next three years following such emergency appropriation must be reduced to the extent by which it was exceeded, unless the emergency arises from civil disturbance or natural disaster declared by the Governor, and the expenditure is approved by two-thirds of the legislative body of the local government. The State and each local government entity has its own appropriations limit. Each year, the limit is adjusted to allow for changes, if any, in the cost of living, the population of the jurisdiction, and any transfer to or from another government entity of financial responsibility for providing services. Proposition 111 requires that each agency's actual appropriations be tested against its limit every two years. If the aggregate "proceeds of taxes" for the preceding two-year period exceeds the aggregate limit, the excess must be returned to the agency's taxpayers through tax rate or fee reductions over the following two years. The City has never exceeded its appropriations limit. Articles XIIIC and MID of the State Constitution General. On November 5, 1996, the voters of the State approved Proposition 218, known as the "Right to Vote on Taxes Act." Proposition 218 adds Articles XIIIC and MID to the California Constitution and contains a number of interrelated provisions affecting the ability of the City to levy and collect both existing and future taxes, assessments, fees and charges. On November 2, 2010, California voters approved Proposition 26, entitled the "Supermajority Vote to Pass New Taxes and Fees Act." Section 1 of Proposition 26 declares that Proposition 26 is intended to limit the ability of the State Legislature and local government to circumvent existing restrictions on increasing taxes by defining the new or expanded taxes as "fees." Proposition 26 amended Articles XIIIA and XIIIC of the State Constitution. The amendments to Article XIIIA limit the ability of the State Legislature to impose higher taxes (as defined in Proposition 26) without a two-thirds vote of the Legislature. The amendments to Article XIIIC define "taxes" that are subject to voter approval as "any levy, charge, or exaction of any kind imposed by a local government," with certain exceptions. Taxes. Article XIIIC requires that all new local taxes be submitted to the electorate before they become effective. Taxes for general governmental purposes of the City ("general taxes") require a majority vote; taxes for specific purposes ("special taxes"), even if deposited in the City's General Fund, require a two-thirds vote. Property -Related Fees and Charges. Article MID also adds several provisions making it generally more difficult for local agencies to levy and maintain property -related fees, charges, and assessments for municipal services and programs. Reduction or Repeal of Taxes, Assessments, Fees and Charges. Article XIIIC also removes limitations on the initiative power in matters of reducing or repealing local taxes, assessments, fees or charges. No assurance can be given that the voters of the City will not, in 43 the future, approve an initiative or initiatives which reduce or repeal local taxes, assessments, fees or charges currently comprising a substantial part of the City's General Fund. If such repeal or reduction occurs, the City's ability to pay debt service on the Bonds could be adversely affected. Burden of Proof. Article XIIIC provides that local government "bears the burden of proving by a preponderance of the evidence that a levy, charge, or other exaction is not a tax, that the amount is no more than necessary to cover the reasonable costs of the governmental activity, and that the manner in which those costs are allocated to a payor bear a fair or reasonable relationship to the payor's burdens on, or benefits received from, the governmental activity." Similarly, Article MID provides that in "any legal action contesting the validity of a fee or charge, the burden shall be on the agency to demonstrate compliance" with Article XIIID. Judicial Interpretation of Proposition 218. The interpretation and application of Articles XIIIC and MID will ultimately be determined by the courts, and it is not possible at this time to predict with certainty the outcome of such determination. Impact on City's General Fund. The City does not believe that any material source of General Fund revenue is subject to challenge under Proposition 218 or Proposition 26. The approval requirements of Articles XIIIC and MID reduce the flexibility of the City to raise revenues for the General Fund, and no assurance can be given that the City will be able to impose, extend or increase the taxes, fees, charges or taxes in the future that it may need to meet increased expenditure needs. Proposition 62 Proposition 62 was adopted by the voters at the November 4, 1986, general election and (a) requires that any new or higher taxes for general governmental purposes imposed by local governmental entities such as the City be approved by a two-thirds vote of the governmental entity's legislative body and by a majority vote of the voters of the governmental entity voting in an election on the tax, (b) requires that any special tax (defined as taxes levied for other than general governmental purposes) imposed by a local governmental entity be approved by a two- thirds vote of the voters of the governmental entity voting in an election on the tax, (c) restricts the use of revenues from a special tax to the purposes or for the service for which the special tax was imposed, (d) prohibits the imposition of ad valorem taxes on real property by local governmental entities except as permitted by Article XIIIA, (e) prohibits the imposition of transaction taxes and sales taxes on the sale of real property by local governmental entities, and (f) requires that any tax imposed by a local governmental entity on or after August 1, 1985, be ratified by a majority vote of the voters voting in an election on the tax within two years of the adoption of the initiative or be terminated by November 15, 1988. California appellate court cases have overturned the provisions of Proposition 62 pertaining to the imposition of taxes for general government purposes. However, the California Supreme Court upheld Proposition 62 in its decision on August 28, 1995, in Fresno County Transportation Authority v. Guardino. This decision reaffirmed the constitutionality of Proposition 62. Certain matters regarding Proposition 62 were not addressed in the Supreme Court's decision, such as what remedies exist for taxpayers subject to a tax not in compliance with Proposition 62, and whether the decision applies to charter cities. The City has not experienced any substantive adverse financial impact as a result of the passage of this initiative. 44 Proposition 1A; Proposition 22 Proposition 1A. Proposition 1A, proposed by the Legislature in connection with the State's Fiscal Year 2004-05 Budget, approved by the voters in November 2004 and generally effective in Fiscal Year 2006-07, provided that the State may not reduce any local sales tax rate, limit existing local government authority to levy a sales tax rate or change the allocation of local sales tax revenues, subject to certain exceptions. Proposition 1A generally prohibited the State from shifting to schools or community colleges any share of property tax revenues allocated to local governments for any Fiscal Year, as set forth under the laws in effect as of November 3, 2004. Any change in the allocation of property tax revenues among local governments within a county had to be approved by two-thirds of both houses of the Legislature. Proposition 22. Proposition 22, entitled "The Local Taxpayer, Public Safety and Transportation Protection Act," was approved by the voters of the State in November 2010. Proposition 22 eliminates or reduces the State's authority to (i) temporarily shift property taxes from cities, counties and special districts to schools, (ii) use vehicle license fee revenues to reimburse local governments for State -mandated costs (the State will have to use other revenues to reimburse local governments), (iii) redirect property tax increment from redevelopment agencies to any other local government, (iv) use State fuel tax revenues to pay debt service on State transportation bonds, or (v) borrow or change the distribution of State fuel tax revenues. Possible Future Initiatives Articles XIIIA, XIIIB, XIIIC and MID and Propositions 62, 111, 218, 22, 26 and 1A were each adopted as measures that qualified for the ballot pursuant to the State's initiative process. From time to time other initiative measures could be adopted, further affecting revenues of the City or the City's ability to expend revenues. The nature and impact of these measures cannot be anticipated by the City. RISK FACTORS The following describes certain special considerations and risk factors affecting the payment of and security for the Bonds. The following discussion is not meant to be an exhaustive list of the risks associated with the purchase of any Bonds and does not necessarily reflect the relative importance of the various risks. Potential investors in the Bonds are advised to consider the following special factors along with all other information in this Official Statement in evaluating the Bonds. There can be no assurance that other considerations will not materialize in the future. Special Obligations of the Authority The Bonds are special obligations of the Authority and are payable solely from, and secured by, a pledge of Revenues and certain funds and accounts held under the Indenture. Revenues consist primarily of Lease Payments payable by the City under the Lease. If, for any reason, the Revenues collected under the Indenture are not sufficient to pay debt service on the Bonds, the Authority will not be obligated to utilize any other of its funds, other than moneys on deposit in the Bond Fund and certain other funds and accounts established under the Indenture, to pay debt service on the Bonds. The Authority has no taxing power. 45 No Pledge of Taxes The obligation of the City to pay the Lease Payments and Additional Rental does not constitute an obligation of the City for which the City is obligated to levy or pledge any form of taxation or for which the City has levied or pledged any form of taxation. The obligation of the City to pay Lease Payments and Additional Rental does not constitute a debt or indebtedness of the Authority, the City, the State of California or any of its political subdivisions within the meaning of any constitutional or statutory debt limitation or restriction. Limitations on Taxes and Fees Certain taxes, assessments, fees and charges presently imposed by the City could be subject to the voter approval requirements of Article XIIIC and Article XIIID of the State Constitution. Based upon the outcome of an election by the voters, such fees, charges, assessments and taxes might no longer be permitted to be imposed, or may be reduced or eliminated and new taxes, assessments fees and charges may not be approved. The City has assessed the potential impact on its financial condition of the provisions of Article XIIIC and Article XIIID of the State Constitution respecting the imposition and increase of taxes, fees, charges and assessments and does not believe that an election by the voters to reduce or eliminate the imposition of certain existing fees, charges, assessments and taxes would substantially affect its financial condition. However, the City believes that if the initiative power was exercised so that all local taxes, assessments, fees and charges that may be subject to Article XIIIC and Article XIIID of the State Constitution are eliminated or substantially reduced, the financial condition of the City, including its General Fund, could be materially adversely affected. Although the City does not currently anticipate that the provisions of Article XIIIC and Article XIIID of the State Constitution would adversely affect its ability to pay Lease Payments and its other obligations payable from the General Fund, no assurance can be given regarding the ultimate interpretation or effect of Article XIIIC and Article XIIID of the State Constitution on the City's finances. See "CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS." Additional Obligations of the City The City is permitted to enter into other obligations which constitute additional charges against its revenues without the consent of Owners of the Bonds. To the extent that additional obligations are incurred by the City, the funds available to pay Lease Payments may be decreased. The Lease Payments and other payments due under the Lease (including payment of costs of repair and maintenance of the Leased Property, taxes and other governmental charges levied against the Leased Property) are payable from funds lawfully available to the City. If the amounts that the City is obligated to pay in a fiscal year exceed the City's revenues for such year, the City may choose to make some payments rather than making other payments, including Lease Payments and Additional Rental, based on the perceived needs of the City. The same result could occur if, because of California Constitutional limits on expenditures, the City is not permitted to appropriate and spend all of its available revenues or is required to expend available revenues to preserve the public health, safety and welfare. 46 Default Whenever any event of default referred to in the Lease happens and continues, the Authority is authorized under the terms of the Lease to exercise any and all remedies available under law or granted under the Lease. See APPENDIX C — "Summary of Principal Legal Documents" for a detailed description of available remedies in the case of a default under the Lease. In the event of a default, there is no remedy of acceleration of the total Lease Payments due over the term of the Lease. The Trustee is not empowered to sell the Leased Property and use the proceeds of such sale to prepay the Bonds or pay debt service on the Bonds. The City will be liable only for Lease Payments on an annual basis and, in the event of a default, the Trustee would be required to seek a separate judgment each year for that year's defaulted Lease Payments. Any such suit for money damages would be subject to limitations on legal remedies against municipalities in California, including a limitation on enforcement of judgments against funds of a fiscal year other than the fiscal year in which the Lease Payments were due and against funds needed to serve the public welfare and interest. Abatement Under certain circumstances related to damage, destruction, condemnation or title defects which cause a substantial interference with the use and possession of the Leased Property, the City's obligation to make Lease Payments will be subject to full or partial abatement and could result in the Trustee having inadequate funds to pay the principal and interest on the Bonds as and when due. See "SECURITY FOR THE BONDS — Abatement" and "APPENDIX C — Summary of Principal Legal Documents." Natural Calamities From time to time, the City is subject to natural calamities, including, but not limited to, earthquake, flood, drought, or wildfire, that may adversely affect economic activity in the City, and which could have a negative impact on City finances. There can be no assurance that the occurrence of any natural calamity would not cause substantial interference to the Leased Property (potentially resulting in abatement of the City's obligation to make Lease Payments), or that the City would have insurance or other resources available to make repairs to the Leased Property in order to make Lease Payments under the Lease. See "- Abatement" above. The City does not maintain earthquake insurance on the Leased Property. Flood. Based on flood risk evaluations prepared by the Federal Emergency Management Agency (FEMA) for the City and San Joaquin County, effective October 19, 2009, flood hazards are a constraint to development only in two areas of the City: the area immediately adjacent to the Mokelumne River along the City's northern boundary, and the area around the White Slough Water Pollution Control Facility, the City's wastewater treatment facility, in the southwest corner of the City. These areas lie within Zone AE, meaning that they are subject to a 1 % annual (100 -year) flood. Flooding depths in this area are generally greater than three feet. No new development is planned within either of these areas. Most of the City lies within Zone X, which describes lands subject to the 0.2% annual (500 -year) flood zone or that lie within the 100 -year flood zone, but with flooding depths less than one foot. The Leased Property lies within Zone X. 47 Drought. On October 19, 2021, the Governor declared a Statewide drought state of emergency and requested that all water users voluntarily reduce water use by 15%. The declaration encouraged water agencies to draw upon supplies other than groundwater and to implement their water shortage contingency plans and authorized the State Water Resources Control Board to adopt regulations that prohibit wasteful water use (such as the use of potable water to wash paved surfaces or to irrigate landscaping during the two days following rainfall). On January 4, 2022, the State Water Resources Control Board adopted regulations that prohibit overwatering yards, washing cars without a shutoff nozzle, and watering grass within 48 hours after rainfall. There can be no assurance that subsequent declarations will not impose stricter water use restrictions should dry conditions persist in future years. Seismic. Major earthquake fault zones in the vicinity of the City include the Greenville fault zone approximately 34 miles south of the City and the San Joaquin fault approximately 24 miles southwest of the City, among others. The City cannot predict how much damage may occur within the City to the Leased Property, specifically, and how much reduction in assessed valuation in the City may result from an earthquake. Under the Lease, the City is not required to obtain earthquake insurance on the Leased Property. Fire Hazards. In recent years, wildfires have caused extensive damage throughout the State. Certain of these fires have burned thousands of acres and destroyed hundreds and in some cases thousands of homes. In some instances, entire neighborhoods have been destroyed. Several fires which occurred in 2017 damaged or destroyed property in areas that were not previously considered to be at risk from such events. In November 2018, the Camp Fire occurred in Butte County, California. The Camp Fire is the deadliest and most destructive wildfire in the recorded history of the State burning more than 150,000 acres and destroying more than 11,500 structures, including most of the structures in the City of Paradise, California. Some commentators believe that climate change will lead to even more frequent and damaging wildfires in the future. However, the City and immediately surrounding area is not characterized by substantial areas of wildlands or other topography that contribute to wildland fires. No portion of the City is classified as having a "High" or "Very High" fire hazard risk. Public Health Emergencies In recent years, public health authorities have warned of threats posed by outbreaks of disease and other public health threats. On February 11, 2020, the WHO announced the official name for the outbreak of COVID-19, an upper respiratory tract illness. COVID-19 has since spread across the globe. The spread of COVID-19 is having significant adverse health and financial impacts throughout the world, including the City. The WHO has declared the COVID-19 outbreak to be a pandemic, and states of emergency have been declared by the Governor of the State and the President of the United States. The COVID-19 outbreak is ongoing, and its duration and severity and its economic effects are uncertain in many respects. Uncertain too are the additional actions, if any, that may be taken by federal and State governmental authorities to contain or mitigate the effects of the outbreak. The ultimate impact of COVID-19 on the City's operations and finances and the economy, real estate market and development within the City is not fully known, and it may be some time before the full adverse impact of the COVID-19 outbreak is known. Certain reports providing preliminary information regarding the impact of the COVID-19 pandemic are described in this Official Statement. Further, there could be future COVID-19 outbreaks or other public health emergencies that could have material adverse effects on the City's operations and finances. 48 Limitations on Remedies Available to Bond Owners The ability of the City to comply with its covenants under the Lease may be adversely affected by actions and events outside of the control of the City, and may be adversely affected by actions taken (or not taken) by voters, property owners, taxpayers or payers of assessments, fees and charges. See "CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES AND APPROPRIATIONS" above. Furthermore, any remedies available to the owners of the Bonds upon the occurrence of an event of default under the Lease or the Indenture are in many respects dependent upon judicial actions, which are often subject to discretion and delay and could prove both expensive and time consuming to obtain. In addition to the limitations on Bondholder remedies contained in the Lease and the Indenture, the rights and obligations under the Bonds, the Lease and the Indenture may be subject to the following: the United States Bankruptcy Code and applicable bankruptcy, insolvency, reorganization, moratorium, or similar laws relating to or affecting the enforcement of creditors' rights generally, now or hereafter in effect; usual equity principles which may limit the specific enforcement under State law of certain remedies; the exercise by the United States of America of the powers delegated to it by the Federal Constitution; and the reasonable and necessary exercise, in certain exceptional situations, of the police power inherent in the sovereignty of the State of California and its governmental bodies in the interest of serving a significant and legitimate public purpose. Bankruptcy proceedings, or the exercise of powers by the federal or state government, if initiated, could subject the Owners of the Bonds to judicial discretion and interpretation of their rights in bankruptcy or otherwise, and consequently may entail risks of delay, limitation or modification of their rights. The opinion of Bond Counsel notes that the rights of the owners of the Bonds and the enforceability of the Bonds and the Indenture are limited by bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights generally, and by equitable principles, whether considered at law or in equity. Loss of Tax -Exemption The City has covenanted in the Lease, and the Authority has covenanted in the Indenture, that each will not take any action, or fail to take any action, if any such action or failure to take action would adversely affect the exclusion from gross income of interest on the Bonds under Section 103 of the Internal Revenue Code of 1986. In the event either the City or the Authority fails to comply with the foregoing tax covenant, interest on the Bonds may be includable in the gross income of the Owners thereof for federal tax purposes retroactive to the risk of issuance. See "TAX MATTERS". Cybersecurity The City, like many other public and private entities, relies on computer and other digital networks and systems to conduct its operations. As a recipient and provider of personal, private or other sensitive electronic information, the City is potentially subject to multiple cyber threats, including without limitation hacking, viruses, ransomware, malware and other attacks. On April 4 and May 3, 2019, the City experienced information security incidents involving ransomware impacting multiple City systems. The City did not pay any ransom and its systems were either rebuilt or restored from backups. The City retained the services of outside professionals to provide legal, technical, and forensic services through the City's cyber insurance coverage. 49 With the exception of the City's $50,000 deductible, all costs associated with these information security incidents, including legal and forensic experts and employee overtime, were covered by insurance. The City believes it has taken reasonable steps to mitigate the adverse effects of cyberattacks, including steps to harden its cybersecurity. The City also provides regular and frequent training for employees in the use of its digital networks and systems and the methods outside actors use to attempt to gain access to the City's network. No assurance can be given that the City's efforts to manage cyber threats and attacks will be successful in all cases, or that any such attack will not materially impact the operations or finances of the City. The City is also reliant on other entities and service providers in connection with the administration of the Bonds, including without limitation the County tax collector for the levy and collection of property taxes, and the Trustee. No assurance can be given that the City, the Authority and these other entities will not be affected by cyber threats and attacks in a manner that may affect the Bond owners. IRS Audit of Tax -Exempt Bond Issues The Internal Revenue Service (the "IRS") has initiated an expanded program for the auditing of tax-exempt bond issues, including both random and targeted audits. It is possible that the Bonds will be selected for audit by the IRS. It is also possible that the market value of such Bonds might be affected as a result of such an audit of such Bonds (or by an audit of similar bonds or securities). Secondary Market for Bonds There can be no guarantee that there will be a secondary market for the Bonds or, if a secondary market exists, that any Bonds can be sold for any particular price. Prices of bond issues for which a market is being made will depend upon then -prevailing circumstances. Such prices could be substantially different from the original purchase price. No assurance can be given that the market price for the Bonds will not be affected by the introduction or enactment of any future legislation (including without limitation amendments to the Internal Revenue Code), or changes in interpretation of the Internal Revenue Code, or any action of the Internal Revenue Service, including but not limited to the publication of proposed or final regulations, the issuance of rulings, the selection of the Bonds for audit examination, or the course or result of any Internal Revenue Service audit or examination of the Bonds or obligations that present similar tax issues as the Bonds. In addition, a number of local governments in the State have recently instituted bankruptcy or pre -bankruptcy proceedings. No assurance can be given that the market price for the Bonds will not be affected by the outcomes of these bankruptcy proceedings or the institution of bankruptcy or pre -bankruptcy proceedings for additional local governments in the State. TAX MATTERS Federal Tax Status. In the opinion of Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel, subject, however to the qualifications set forth below, under existing law, the interest on the Bonds is excluded from gross income for federal income tax purposes and such interest is not an item of tax preference for purposes of the federal alternative minimum tax. 50 The opinions set forth in the preceding paragraph are subject to the condition that the Authority comply with all requirements of the Internal Revenue Code of 1986, as amended (the "Tax Code") that must be satisfied subsequent to the issuance of the Bonds in order that the interest thereon be, and continue to be, excludable from gross income for federal income tax purposes. The Authority has made certain representations and covenants in order to comply with each such requirement. Inaccuracy of those representations, or failure to comply with certain of those covenants, may cause the inclusion of such interest in gross income for federal income tax purposes, which may be retroactive to the date of issuance of the Bonds. Tax Treatment of Original Issue Discount and Premium. If the initial offering price to the public at which a Bond is sold is less than the amount payable at maturity thereof, then such difference constitutes "original issue discount" for purposes of federal income taxes and State of California personal income taxes. If the initial offering price to the public at which a Bond is sold is greater than the amount payable at maturity thereof, then such difference constitutes "bond premium" for purposes of federal income taxes and State of California personal income taxes. Under the Tax Code, original issue discount is treated as interest excluded from federal gross income and exempt from State of California personal income taxes to the extent properly allocable to each owner thereof subject to the limitations described in the first paragraph of this section. The original issue discount accrues over the term to maturity of the Bond on the basis of a constant interest rate compounded on each interest or principal payment date (with straight- line interpolations between compounding dates). The amount of original issue discount accruing during each period is added to the adjusted basis of such Bonds to determine taxable gain upon disposition (including sale, redemption, or payment on maturity) of such Bond. The Tax Code contains certain provisions relating to the accrual of original issue discount in the case of purchasers of the Bonds who purchase the Bonds after the initial offering of a substantial amount of such maturity. Owners of such Bonds should consult their own tax advisors with respect to the tax consequences of ownership of Bonds with original issue discount, including the treatment of purchasers who do not purchase in the original offering to the public at the first price at which a substantial amount of such Bonds is sold to the public. Under the Tax Code, bond premium is amortized on an annual basis over the term of the Bond (said term being the shorter of the Bond's maturity date or its call date). The amount of bond premium amortized each year reduces the adjusted basis of the owner of the Bond for purposes of determining taxable gain or loss upon disposition. The amount of bond premium on a Bond is amortized each year over the term to maturity of the Bond on the basis of a constant interest rate compounded on each interest or principal payment date (with straight-line interpolations between compounding dates). Amortized Bond premium is not deductible for federal income tax purposes. Owners of premium Bonds, including purchasers who do not purchase in the original offering, should consult their own tax advisors with respect to State of California personal income tax and federal income tax consequences of owning such Bonds. California Tax Status. In the further opinion of Bond Counsel, interest on the Bonds is exempt from California personal income taxes. Other Tax Considerations. Current and future legislative proposals, if enacted into law, clarification of the Tax Code or court decisions may cause interest on the Bonds to be subject, directly or indirectly, to federal income taxation or to be subject to or exempted from state income taxation, or otherwise prevent beneficial owners from realizing the full current benefit of the tax status of such interest. The introduction or enactment of any such legislative proposals, clarification of the Tax Code or court decisions may also affect the market price for, 51 or marketability of, the Bonds. It cannot be predicted whether or in what form any such proposal might be enacted or whether, if enacted, such legislation would apply to bonds issued prior to enactment. The opinions expressed by Bond Counsel are based upon existing legislation and regulations as interpreted by relevant judicial and regulatory authorities as of the date of such opinion, and Bond Counsel has expressed no opinion with respect to any proposed legislation or as to the tax treatment of interest on the Bonds, or as to the consequences of owning or receiving interest on the Bonds, as of any future date. Prospective purchasers of the Bonds should consult their own tax advisors regarding any pending or proposed federal or state tax legislation, regulations or litigation, as to which Bond Counsel expresses no opinion. Owners of the Bonds should also be aware that the ownership or disposition of, or the accrual or receipt of interest on, the Bonds may have federal or state tax consequences other than as described above. Other than as expressly described above, Bond Counsel expresses no opinion regarding other federal or state tax consequences arising with respect to the Bonds, the ownership, sale or disposition of the Bonds, or the amount, accrual or receipt of interest on the Bonds. CERTAIN LEGAL MATTERS The Bonds are offered when, as and if issued and received by the Underwriter and subject to the approval as to their legality by Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel. Certain legal matters will be passed upon for the City and the Authority by the City Attorney. Certain legal matters will be passed upon for the City by its Disclosure Counsel, Jones Hall, A Professional Law Corporation, San Francisco, California and for the Underwriter by Kutak Rock LLP, Los Angeles, California. Payment of the fees and expenses of Bond Counsel and Underwriter's Counsel is contingent upon execution and delivery of the Bonds. LITIGATION To the knowledge of the City, there is no controversy or litigation of any nature now pending or threatened restraining or enjoining the execution and delivery of the Bonds, the Indenture, the Lease or in any way contesting or affecting the validity of the Bonds or any proceedings of the City or the Authority taken with respect to the execution and delivery thereof. FINANCIAL STATEMENTS The Pun Group, Certified Public Accountants (the "Auditor"), audited the financial statements of the City for the Fiscal Year ended June 30, 2021. The Auditor's examination was made in accordance with generally accepted auditing standards and Governmental Auditing Standards, issued by the Comptroller General of the United States. See "APPENDIX B - Audited Financial Statements of the City for Fiscal Year Ended June 30, 2021." 52 The City has not requested nor did the City obtain permission from the Auditor to include the audited financial statements as an appendix to this Official Statement. Accordingly, the Auditor has not performed any post -audit review of the financial condition or operations of the City and has not participated in the preparation of, or reviewed, this Official Statement. RATING S&P Global Ratings, a business unit of Standard & Poor's Financial Services LLC ("S&P"), is expected to assign the Bonds the long-term rating of "". The rating reflects only the views of S&P, and any explanation of the significance of such rating may be obtained only from S&P. There is no assurance that the rating will remain in effect for any given period of time or that it will not be revised downward or withdrawn entirely by S&P, if, in their judgment, circumstances so warrant. The City undertakes no responsibility to oppose any such revision or withdrawal. Any downward revision or withdrawal of the rating may have an adverse effect on the market price of the Bonds. CONTINUING DISCLOSURE The City will covenant for the benefit of owners of the Bonds to provide certain financial information and operating data relating to the City by not later than 7 months after the end of each fiscal year of the City (currently June 30th), commencing with the report for the 2021-22 Fiscal Year (the "Annual Report"), and to provide notices of the occurrence of certain enumerated events. Such reports are required to be filed with the Municipal Securities Rulemaking Board through its Electronic Municipal Market Access system ("EMMA"). The specific nature of the information to be contained in the Annual Report or the notices of enumerated events is described in "APPENDIX E — Form of Continuing Disclosure Certificate," attached to this Official Statement. These covenants have been made in order to assist the underwriter of the Bonds in complying with Securities Exchange Commission Rule 15c2 - 12(b)(5). The City has entered into a number of continuing disclosure undertakings in connection with City obligations, including obligations payable from the City's General Fund, as well as obligations payable from the revenues relating to the water system and the City's electric and wastewater utilities. During the past five years, the City has prepared continuing disclosure reports pursuant to these undertakings. Within the past five years, the City and certain of its related entities have failed to comply in certain respects with continuing disclosure obligations related to outstanding indebtedness, by (i) filing audited financial statements and operating data on EMMA for Fiscal Years 2017-18 and 2018-19 up to 24 days late and (ii) failing to associate certain filings on EMMA with all relevant CUSIPs of outstanding indebtedness. The City has adopted a disclosure policy intended to assure future compliance with the City's continuing disclosure requirements. 53 MUNICIPAL ADVISOR Fieldman, Rolapp & Associates, Inc. (the "Municipal Advisor") has assisted the City with various matters relating to the planning, structuring and delivery of the Bonds. The Municipal Advisor is a financial advisory firm and is not engaged in the business of underwriting or distributing municipal securities or other public securities. The Municipal Advisor assumes no responsibility for the accuracy, completeness or fairness of this Official Statement. The Municipal Advisor will receive compensation from the City contingent upon the sale and delivery of the Bonds. UNDERWRITING The Bonds are being purchased by Piper Sandler & Co. (the "Underwriter"), at a purchase price of $ (which represents the aggregate principal amount of the Bonds ($ ), plus an original issue premium/less an original issue discount of $ less an Underwriter's discount of $ ). The purchase agreement relating to the Bonds provides that the Underwriter will purchase all of the Bonds, if any are purchased, the obligation to make such purchase being subject to certain terms and conditions set forth in such purchase agreement. The Underwriter may offer and sell the Bonds to certain dealers and others at prices lower than the offering prices stated on the inside cover page hereof. The offering prices may be changed from time to time by the Underwriter. Piper Sandler & Co. has entered into a distribution agreement with Charles Schwab & Co., Inc. ("CS&Co.") for the retail distribution of certain securities offerings at the original issue prices. Pursuant to the agreement, CS&Co. will purchase the Bonds from Piper Sandler & Co. at the original issue price less a negotiated portion of the selling concession applicable to any Bonds that CS&Co. sells. PROFESSIONAL SERVICES In connection with the issuance of the Bonds, all or a portion of the fees payable to the Bond Counsel, Underwriter's Counsel, the Financial Advisor and the Trustee are contingent upon the issuance and delivery of the Bonds. 54 EXECUTION The execution and delivery of this Official Statement have been authorized by the Board of Directors of the Authority and the City Council of the City. LODI PUBLIC FINANCING AUTHORITY M Executive Director CITY OF LODI City Manager 55 APPENDIX A GENERAL INFORMATION ABOUT THE CITY OF LODI AND SAN JOAQUIN COUNTY The following information concerning the City of Lodi (the "City') and San Joaquin County (the "County') are included only for the purpose of supplying general information regarding the community. The 2022 Bonds are not a debt of the City, the County, the State of California (the "State') or any of its political subdivisions, and neither the City, the County, the State nor any of its political subdivisions is liable therefor. General The City. The City is located in the County of San Joaquin (the "County") between Stockton and Sacramento, and adjacent to U.S. Highway 99, approximately 90 miles east of San Francisco. The City was incorporated as a General Law City on December 6, 1906. The City operates under a City Council -Manager form of government and provides the following services: public safety (police, fire and graffiti abatement), public utilities services (electric, water and sewer), transportation services (streets, flood control and transit), leisure, cultural and social services (parks and recreation, library, and community center), and general government services (management, human resources administration, financial administration, building maintenance and equipment maintenance). The County. The County is one of California's original counties and was created at the time of statehood in 1850. The County covers an area of approximately 1,436 square miles, consisting of 1,399 square miles of land and 27 square miles of water. The County is adjacent to Stanislaus County to the south and southeast, Alameda and Contra Costa Counties to the west, Sacramento County to the north, Amador County to the northeast, Calaveras County to the east and a corner of Santa Clara County to the southwest. Population Population figures for the City, the County and the State for the last five years are shown in the following table. CITY OF LODI, SAN JOAQUIN COUNTY AND THE STATE OF CALIFORNIA Population Estimates Calendar Years 2017 through 2021, as of January 1 Calendar City of San Joaquin State of Year Lodi County California 2017 65,606 744,843 39,352,398 2018 66,389 752,958 39,519,535 2019 67,430 752,958 39,605,361 2020 68,011 773,505 39,648,938 2021 68,751 773,505 39,466,855 Source: State Department of Finance estimates. A-1 Employment and Industry The City is included in the Stockton Metropolitan Statistical Area ("MSA"), which includes all of San Joaquin County. The unemployment rate in the County was 6.6% in November 2021, down from a revised 7.3% in October 2021, and below the year-ago estimate of 8.7%. This compares with an unadjusted unemployment rate of 5.4% for the State and 3.9% for the nation during the same period. Set forth below is data from calendar years 2016 to 2020 reflecting the County's civilian labor force, employment and unemployment. These figures are county -wide statistics and may not necessarily accurately reflect employment trends in the City. STOCKTON-LODI MSA (San Joaquin County) Annual Average Labor Force and Employment by Industry Calendar Years 2016 through 2020 (March 2020 Benchmark) Civilian Labor Force Employment Unemployment Unemployment Rate Wage and Salary Employment: (2) Agriculture Mining and Logging Construction Manufacturing Wholesale Trade Retail Trade Transportation, Warehousing and Utilities Information Financial Activities Professional and Business Services Educational and Health Services Leisure and Hospitality Other Services Federal Government State Government Local Government Total All Industries (3) 2016 2017 2018 2019 2020 318,300 323,200 324,200 326,500 331,800 292,400 300,400 304,300 306,900 294,500 25,900 22,800 19,900 19,600 37,400 8.2% 7.0% 6.1% 6.0% 11.3% 16,700 16,400 15,600 15,400 14,300 100 100 100 100 100 11,100 11,700 12,800 13,100 12,900 19,800 20,300 20,600 20,600 20,500 10,700 11,100 11,700 11,600 10,500 26,500 26,800 26,700 26,200 24,600 23,000 26,200 28,400 31,300 38,300 2,000 1,800 1,800 1,600 1,200 7,500 7,800 7,800 7,900 7,800 19,600 19,200 19,600 20,200 21,100 36,400 38,200 38,800 39,100 37,100 20,400 21,500 22,000 22,600 18,400 7,500 7,600 7,600 7,800 6,700 3,000 3,100 3,100 3,200 3,300 6,400 6,600 6,700 6,800 6,800 31,400 32,800 33,700 34,900 33,100 242,000 251,100 256,900 262,400 256,600 (1) Labor force data is by place of residence; includes self-employed individuals, unpaid family workers, household domestic workers, and workers on strike. (2) Industry employment is by place of work; excludes self-employed individuals, unpaid family workers, household domestic workers, and workers on strike. (3) Totals may not add due to rounding. Source: State of California Employment Development Department. A-2 Largest Employers The following table lists the major employers within the County, listed in alphabetical order without regard to the number of employees, as of January 2022. SAN JOAQUIN COUNTY Major Employers As of January 2022 Employer Name Location Industry A Sambado & Sons Inc Linden Nuts -Edible Amazon Fulfillment Ctr Stockton Mail Order Fulfillment Service Ashley Lane LP Stockton Real Estate Blue Shield of California Lodi Insurance Dameron Hospital Stockton Hospitals Deuel Vocational Instn Fire Tracy Fire Departments Foster Care Svc Stockton Government Offices -County Leprino Foods Co Tracy Cheese Processors (mfrs) Lodi Health Home Health Agency Lodi Home Health Service Lodi Memorial Hospital Lodi Hospitals NA Chaderjian Youth Stockton State Govt -Correctional Institutions Pacific Coast Producers Lodi Canning (mfrs) Prima Frutta Packing Inc Linden Fruit & Produce Packers Safeway Distribution Ctr Tracy Distribution Centers (whls) San Joaquin County CA Pubc Stockton Government Offices -County San Joaquin County Human Svc Stockton Government Offices -County San Joaquin County Sch Stockton School Districts San Joaquin General Hospital French Camp Hospitals San Joaquin Sheriff's Office French Camp Government Offices -County Sjgov Stockton Government Offices -County St Joseph's Cancer Ctr Stockton Cancer Treatment Centers St Joseph's Regional Health Stockton Hospitals Stockton Police Dept Stockton Police Departments Stockton Unified School Dist Stockton School Districts Walmart Supercenter Stockton Department Stores Source: State of California Employment Development Department, extracted from The America's Labor Market Information System (ALMIS) Employer Database, 2022 1st Edition. A-3 The following table lists the ten principal employers within the City, by number of employees, as of June 30, 2021. CITY OF LODI Principal Employers As of June 30, 2021 Employer Name Number of Employees Lodi Unified School District 1,389 Pacific Coast Producers 1,298 Adventist Health Lodi Memorial 1,204 Blue Shield of CA 1,042 Cepheid 750 Walmart Supercenter 439 City of Lodi 415 Rich Products formerly known as Cottage Bakery 276 Costco Wholesale 265 Frank C Alegre Trucking Inc. 210 Source: City of Lodi Annual Comprehensive Financial Report for fiscal year ended June 30, 2021; City of Lodi. A-4 Commercial Activity Summaries of historic taxable sales within the City and the County during the past five years in which data is available are shown in the following tables. Total taxable sales during the first three quarters of calendar year 2021 in the City were $1,039,174,212, a 22.30% increase over the total taxable sales of $849,721,205 reported during the first three quarters of calendar year 2020. CITY OF LODI Taxable Retail Sales Number of Permits and Valuation of Taxable Transactions (Dollars in Thousands) Source: State Department of Tax and Fee Administration. Total taxable sales during the first three quarters of calendar year 2021 in the County were $16,201,722,121, a 44.88% increase over the total taxable sales of $11,182,961,549 reported during the first three quarters of calendar year 2020. SAN JOAQUIN COUNTY Taxable Retail Sales Number of Permits and Valuation of Taxable Transactions (Dollars in Thousands) Retail Stores Number Taxable of Permits Transactions Total All Outlets Number Taxable of Permits Transactions 2016 Retail Stores Total All Outlets 14,682 Number Taxable Number Taxable 14,758 of Permits Transactions of Permits Transactions 2016 1,327 $779,583 1,987 $947,638 2017 1,300 856,206 1,972 1,029,268 2018 1,328 945,797 2,064 1,134,229 2019 1,344 972,278 2,107 1,162,963 2020 1,468 958,572 2,321 1,160,904 Source: State Department of Tax and Fee Administration. Total taxable sales during the first three quarters of calendar year 2021 in the County were $16,201,722,121, a 44.88% increase over the total taxable sales of $11,182,961,549 reported during the first three quarters of calendar year 2020. SAN JOAQUIN COUNTY Taxable Retail Sales Number of Permits and Valuation of Taxable Transactions (Dollars in Thousands) Retail Stores Number Taxable of Permits Transactions Total All Outlets Number Taxable of Permits Transactions 2016 9,480 $7,380,226 14,682 $10,922,271 2017 9,506 7,994,473 14,758 12,153,268 2018 9,660 8,855,169 15,457 13,457,721 2019 9,978 9,058,063 16,144 14,311,068 2020 11,188 10,122,979 18,358 15,609,880 Source: State Department of Tax and Fee Administration A-5 Effective Buying Income "Effective Buying Income" is defined as personal income less personal tax and nontax payments, a number often referred to as "disposable" or "after-tax" income. Personal income is the aggregate of wages and salaries, other labor -related income (such as employer contributions to private pension funds), proprietor's income, rental income (which includes imputed rental income of owner -occupants of non-farm dwellings), dividends paid by corporations, interest income from all sources, and transfer payments (such as pensions and welfare assistance). Deducted from this total are personal taxes (federal, state and local), nontax payments (fines, fees, penalties, etc.) and personal contributions to social insurance. According to U.S. government definitions, the resultant figure is commonly known as "disposable personal income." The following table summarizes the median household effective buying income for the City, the County, the State and the United States for the period 2018 through 2022. CITY OF LODI AND SAN JOAQUIN COUNTY Median Household Effective Buying Income 2018 through 2022 Source: The Nielsen Company (US), Inc for 2018; Claritas, LLC for 2019 through 2022. M 2018 2019 2020 2021 2022 City of Lodi $46,144 $50,111 $52,418 $53,760 $64,155 San Joaquin County 49,883 55,534 58,141 59,914 68,971 California 59,646 62,637 65,870 67,956 77,058 United States 50,735 52,841 55,303 56,790 64,448 Source: The Nielsen Company (US), Inc for 2018; Claritas, LLC for 2019 through 2022. M Building Activity The tables below summarize building activity in the City and the County for the past five available years. CITY OF LODI Building Permit Activity For Calendar Years 2016 through 2020 (Dollars in Thousands) Source: Construction Industry Research Board, Building Permit Summary A-7 2016 2017 2018 2019 2020 Permit Valuation New Single-family $47,331.6 $54,475.9 $55,587.1 $28,041.8 $12,473.4 New Multi -family 13,501.8 16,178.1 0.0 19,280.1 0.0 Res. Alterations/Additions 4,619.9 4,791.8 7,349.5 4,817.3 2,327.9 Total Residential $65,453.3 $75,445.8 $62,936.6 $52,139.2 $14,801.3 New Commercial $6,019.3 $21,785.2 $10,987.0 44,067.4 6,193.9 New Industrial 0.0 0.0 0.0 0.0 0.0 New Other 2,568.9 3,478.6 5,402.4 13,929.2 1,563.3 Com. Alterations/Additions 16,162.1 17,768.4 10,005.7 4,880.1 4,076.4 Total Nonresidential $25,750.3 $43,032.2 $26,395.1 $62,876.7 $11,833.6 New Dwelling Units Single Family 189 168 243 111 44 Multiple Family 82 134 0 158 0 TOTAL 271 302 243 269 44 Source: Construction Industry Research Board, Building Permit Summary. SAN JOAQUIN COUNTY Building Permit Activity For Calendar Years 2016 through 2020 (Dollars in Thousands) 2016 2017 2018 2019 2020 Permit Valuation New Single-family $467,494.7 $652,308.1 $883,071.1 $843,700.9 $870,859.6 New Multi -family 66,794.5 62,635.8 99,601.4 57,271.1 38,411.8 Res. Alterations/Additions 99,049.9 86,516.1 95,073.4 98,681.9 40,144.4 Total Residential $633,339.1 $801,460.0 $1,077,745.9 $999,653.9 $949,415.8 New Commercial $218,485.4 $357,856.9 $498,359.0 380,383.3 255,761.2 New Industrial 61,687.0 179,728.4 240,073.7 120,003.8 534,199.5 New Other 46,379.4 27,794.7 31,904.4 61,991.7 33,112.3 Com. Alterations/Additions 298,721.9 269,172.8 249,142.4 363,840.9 135,285.4 Total Nonresidential $625,273.7 $834,552.8 $1,019,479.5 926,219.7 958,358.4 New Dwelling Units Single Family 1,754 2,078 2,765 2,564 2,843 Multiple Family 550 516 293 461 245 TOTAL 2,304 2,594 3,358 3,025 3,088 Source: Construction Industry Research Board, Building Permit Summary A-7 APPENDIX B AUDITED FINANCIAL STATEMENTS OF THE CITY FOR THE FISCAL YEAR ENDED JUNE 30, 2021 s APPENDIX C SUMMARY OF PRINCIPAL LEGAL DOCUMENTS C-1 APPENDIX D FORM OF OPINION OF BOND COUNSEL , 2022 Lodi Public Financing Authority 221 West Pine Street Lodi, CA 95240 OPINION: $ Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Refunding; Capital Protects Financing) Members of the Board of Directors of the Authority: We have acted as bond counsel to the Lodi Public Financing Authority (the "Authority") in connection with the issuance by the Authority of the captioned bonds dated the date hereof (the "Bonds"). In such capacity, we have examined such law and such certified proceedings, opinions, certifications and other documents as we have deemed necessary to render this opinion. The Bonds are issued pursuant to Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California (the "Bond Law"), the Indenture of Trust, dated as of March 1, 2022 (the "Indenture"), by and between the Authority and U.S. Bank Trust Company, National Association, as trustee (the "Trustee "), and a resolution (the "Resolution") of the Board of Directors of the Authority adopted March 2, 2022. Under the Indenture, the Authority has pledged certain revenues (the "Revenues") for the payment of principal, premium (if any), and interest on the Bonds when due, including lease payments made by the City of Lodi (the "City") under a Lease Agreement dated as of March 1, 2022 (the "Lease Agreement") between the Authority and the City. Regarding questions of fact material to our opinion, we have relied on representations of the Authority contained in the Indenture and the City contained in the Lease Agreement, and in the certified proceedings and other certifications of public officials furnished to us, without undertaking to verify the same by independent investigation. Based on the foregoing, we are of the opinion that, under existing law: 1. The Authority is a duly created and validly existing joint exercise of powers authority with the power to adopt the Resolution, enter into the Indenture and perform the agreements on its part contained therein, and issue the Bonds. 2. The City is a duly created and validly existing general law city with the power to enter into the Lease Agreement and perform the agreements on its part contained therein. D-1 3. The Indenture has been duly authorized, executed and delivered by the Authority, and constitutes a valid and binding obligation of the Authority, enforceable against the Authority. 4. The Lease Agreement has been duly authorized, executed and delivered by the Authority and the City, and constitutes a valid and binding obligation of the Authority and the City, enforceable against the Authority and the City. 5. The Indenture creates a valid lien on the Revenues and other funds pledged by the Indenture for the security of the Bonds, on a parity with other bonds (if any) issued or to be issued under the Indenture. 6. The Bonds have been duly authorized and executed by the Authority, and are valid and binding limited obligations of the Authority, payable solely from the Revenues and other funds provided therefor in the Indenture. 7. Interest on the Bonds is excludable from gross income for federal income tax purposes and is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations. The opinions set forth in the preceding sentence are subject to the condition that the Authority and the City comply with all requirements of the Internal Revenue Code of 1986 that must be satisfied subsequent to the delivery of the Bonds in order that such interest be, or continue to be, excluded from gross income for federal income tax purposes. The Authority and the City have covenanted to comply with each such requirement. Failure to comply with certain of such requirements may cause the inclusion of interest on the Bonds in gross income for federal income tax purposes to be retroactive to the date of issuance of the Bonds. We express no opinion regarding other federal tax consequences arising with respect to the Bonds. 8. Interest on the Bonds is exempt from personal income taxation imposed by the State of California. The rights of the owners of the Bonds and the enforceability of the Bonds and the Indenture are limited by bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights generally, and by equitable principles, whether considered at law or in equity. This opinion is given as of the date hereof, and we assume no obligation to revise or supplement this opinion to reflect any facts or circumstances that may hereafter come to our attention, or any changes in law that may hereafter occur. Moreover, our opinions are not a guarantee of a particular result, and are not binding on the Internal Revenue Service or the courts; rather, our opinions represent our legal judgment based upon our review of existing law that we deem relevant to such opinions and in reliance upon the representations, covenants and opinions referenced above. Our engagement with respect to this matter has terminated as of the date hereof. Respectfully submitted, A Professional Law Corporation D-2 APPENDIX E FORM OF CONTINUING DISCLOSURE CERTIFICATE LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE BONDS (2012 Refunding; Capital Projects Financing) This Continuing Disclosure Certificate (this "Disclosure Certificate") is executed and delivered by the City of Lodi, a municipal corporation (the "City"), in connection with the issuance of the $ Lodi Public Financing Authority (the "Authority") 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) (the "2022 Bonds"). The 2022 Bonds are being issued pursuant to an Indenture of Trust dated as of March 1, 2022 (the "Indenture"), by and between the Authority and U.S. Bank Trust Company, National Association, as trustee for the 2022 Bonds (the "Trustee"). In connection therewith, the City covenants and agrees as follows: Section 1. Purpose of the Disclosure Certificate. This Disclosure Certificate is being executed and delivered by the City for the benefit of the holders and beneficial owners of the 2022 Bonds and in order to assist the Participating Underwriter in complying with S.E.C. Rule 15c2 -12(b)(5). Section 2. Definitions. In addition to the definitions set forth above and in the Indenture, which apply to any capitalized term used in this Disclosure Certificate unless otherwise defined in this Section, the following capitalized terms shall have the following meanings: "Annual Report" means any Annual Report provided by the City pursuant to, and as described in, Sections 3 and 4 of this Disclosure Certificate. "Annual Report Date" means the date that is seven months after the end of the City's fiscal year (currently January 31 based on the City's fiscal year end of June 30). "Dissemination Agent" shall mean the City, or any Dissemination Agent designated in writing by the City and which has filed with the City a written acceptance of such designation. "EMMA System" shall mean the MSRB's Electronic Municipal Market Access system, or such other electronic system designated by the MSRB. "Listed Events" means any of the events listed in Section 5(a) of this Disclosure Certificate. "MSRB" means the Municipal Securities Rulemaking Board, which has been designated by the Securities and Exchange Commission as the sole repository of disclosure information for purposes of the Rule. "Official Statement" means the final official statement dated 2022, executed by the City and Authority in connection with the issuance of the 2022 Bonds. E-1 "Participating Underwrite" means Piper Sandler & Co., the original underwriter of the 2022 Bonds required to comply with the Rule in connection with offering of the 2022 Bonds. "Rule" means Rule 15c2 -12(b)(5) adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as it may be amended from time to time. Section 3. Provision of Annual Reports. (a) The City shall, or shall cause the Dissemination Agent to, not later than the Annual Report Date, commencing January 31, 2023, with the report for the 2021-22 fiscal year, provide to the MSRB, in an electronic format as prescribed by the MSRB, an Annual Report that is consistent with the requirements of Section 4 of this Disclosure Certificate. Not later than 15 Business Days prior to the Annual Report Date, the City shall provide the Annual Report to the Dissemination Agent (if other than the City). If by the Annual Report Date the Dissemination Agent (if other than the City) has not received a copy of the Annual Report, the Dissemination Agent shall contact the City to determine if the City is in compliance with the previous sentence. 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 Certificate; provided that the audited financial statements of the City may be submitted separately from the balance of the Annual Report, and later than the Annual Report Date, if not available by that date. If the City's fiscal year changes, it shall give notice of such change in the same manner as for a Listed Event under Section 5(b). (b) If the City does not provide, or cause the Dissemination Agent to provide, an Annual Report by the Annual Report Date as required in subsection (a) above, the Dissemination Agent shall provide a notice to the MSRB, in a timely manner, in an electronic format as prescribed by the MSRB. (c) With respect to each Annual Report, the Dissemination Agent shall: (i) determine each year prior to the Annual Report Date the then -applicable rules and electronic format prescribed by the MSRB for the filing of annual continuing disclosure reports; and (ii) if the Dissemination Agent is other than the City, file a report with the City and the Participating Underwriter certifying that the Annual Report has been provided pursuant to this Disclosure Certificate, and stating the date it was provided. Section 4. Content of Annual Reports. The City's Annual Report shall contain or incorporate by reference the following documents and information: (a) The City's audited financial statements for the most recently completed fiscal year, prepared in accordance with Generally Accepted Accounting Principles as promulgated to apply to governmental entities from time to time by the Governmental Accounting Standards Board. If the City's audited financial statements are not available by the Annual Report Date, the Annual Report shall contain unaudited financial statements in a format similar to the financial statements contained in the Official Statement, and the audited financial statements shall be filed in the same manner as the Annual Report when they become available. E-2 (b) Unless otherwise provided in the audited financial statements filed on or before the Annual Report Date, financial information and operating data with respect to the City for the preceding fiscal year, substantially similar to that provided in the corresponding tables in the Official Statement: (i) Principal amount of 2022 Bonds outstanding as of the June 30 preceding the filing of the Annual Report. (ii) Balance in each fund under the Indenture as of the June 30 preceding the filing of the Annual Report. (iii) Updates as of the June 30 preceding the filing of the Annual Report of the substance of the information contained in the following tables in the Official Statement: (1) Table 1 - Statement of Revenues, Expenditures, and Changes in Fund Balances; (2) Table 4 - General Fund Tax Revenues by Source; (3) Table 6 - Assessed Value of Taxable Property; and (4) Table 7 - Principal Property Tax Payers. (c) In addition to any of the information expressly required to be provided under paragraph (b) above, the City shall provide such further material information, if any, as may be necessary to make the specifically required statements, in the light of the circumstances under which they are made, not misleading. (d) Any or all of the items listed above may be included by specific reference to other documents, including official statements of debt issues of the City or related public entities, which are available to the public on the MSRB's Internet web site or filed with the Securities and Exchange Commission. The City shall clearly identify each such other document so included by reference. Section 5. Reporting of Listed Events. (a) The City shall give, or cause to be given, notice of the occurrence of any of the following Listed Events with respect to the 2022 Bonds: (1) Principal and interest payment delinquencies. (2) Non-payment related defaults, if material. (3) Unscheduled draws on debt service reserves reflecting financial difficulties. (4) Unscheduled draws on credit enhancements reflecting financial difficulties. (5) Substitution of credit or liquidity providers, or their failure to perform. E-3 (6) Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax status of the 2022 Bonds, or other material events affecting the tax status of the 2022 Bonds. (7) Modifications to rights of security holders, if material. (8) Bond calls, if material, and tender offers. (9) Defeasances. (10) Release, substitution, or sale of property securing repayment of the securities, if material. (11) Rating changes. (12) Bankruptcy, insolvency, receivership or similar event of the City. (13) The consummation of a merger, consolidation, or acquisition involving the City, or the sale of all or substantially all of the assets of the City (other than in the ordinary course of business), the entry into a definitive agreement to undertake such an action, or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material. (14) Appointment of a successor or additional Trustee or the change of name of the Trustee, if material. (15) Incurrence of a financial obligation of the obligated person, if material, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a financial obligation of the obligated person, any of which affect security holders, if material. (16) Default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a financial obligation of the obligated person, any of which reflect financial difficulties. (b) Upon the occurrence of a Listed Event, the City shall, or shall cause the Dissemination Agent (if not the City) to, file a notice of such occurrence with the MSRB, in an electronic format as prescribed by the MSRB, in a timely manner not in excess of 10 Business Days after the occurrence of the Listed Event. Notwithstanding the foregoing, notice of Listed Events described in subsection (a)(8) above 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 under the Indenture. (c) The City acknowledges that the events described in subparagraphs (a)(2), (a)(7), (a)(8) (if the event is a bond call), (a)(10), (a)(13), (a)(14), and (a)(15) of this Section 5 contain the qualifier "if material" and that subparagraph (a)(6) also contains the qualifier "material" with respect to certain notices, determinations or other events affecting the tax status of the 2022 E-4 Bonds. The City shall cause a notice to be filed as set forth in paragraph (b) above with respect to any such event only to the extent that it determines the event's occurrence is material for purposes of U.S. federal securities law. Upon occurrence of any of these Listed Events, the City will as soon as possible determine if such event would be material under applicable federal securities law. If such event is determined to be material, the City will cause a notice to be filed as set forth in paragraph (b) above. (d) For purposes of this Disclosure Certificate, any event described in paragraph (a)(12) above is considered to occur when any of the following occur: the appointment of a receiver, trustee, or similar officer for the City in a proceeding under the United States Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the City, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement, or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the City. (e) For purposes of Section 5(a)(15) and (16), "financial obligation" means a (i) debt obligation; (ii) derivative instrument entered into in connection with, or pledged as security or a source of payment for, an existing or planned debt obligation; or (iii) guarantee of (i) or (ii). The term financial obligation shall not include municipal securities as to which a final official statement has been provided to the Municipal Securities Rulemaking Board consistent with the Rule. Section 6. Identifying Information for Filings with the MSRB. All documents provided to the MSRB under the Disclosure Certificate shall be accompanied by identifying information as prescribed by the MSRB. Section 7. Termination of Reporting Obligation. The City's obligations under this Disclosure Certificate shall terminate upon the legal defeasance, prior redemption or payment in full of all of the 2022 Bonds. If such termination occurs prior to the final maturity of the 2022 Bonds, the City shall give notice of such termination in the same manner as for a Listed Event under Section 5(b). Section 8. Dissemination Agent. The City may, from time to time, appoint or engage a Dissemination Agent to assist it in carrying out its obligations under this Disclosure Certificate, and may discharge any such Agent, with or without appointing a successor Dissemination Agent. The initial Dissemination Agent shall be the City. Any Dissemination Agent may resign by providing 30 days' written notice to the City. Section 9. Amendment; Waiver. Notwithstanding any other provision of this Disclosure Certificate, the City may amend this Disclosure Certificate, and any provision of this Disclosure Certificate may be waived, provided that the following conditions are satisfied: (a) if the amendment or waiver relates to the provisions of Sections 3(a), 4 or 5(a), it may only be made in connection with a change in circumstances that arises from a change in legal requirements, change in law, or change in the identity, nature, or status of an obligated person with respect to the 2022 Bonds, or type of business conducted; E-5 (b) the undertakings herein, as proposed to be amended or waived, would, in the opinion of nationally recognized bond counsel, have complied with the requirements of the Rule at the time of the primary offering of the 2022 Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; and (c) the proposed amendment or waiver either (i) is approved by holders of the 2022 Bonds in the manner provided in the Indenture for amendments to the Indenture with the consent of holders, or (ii) does not, in the opinion of the Trustee or nationally recognized bond counsel, materially impair the interests of the holders or beneficial owners of the 2022 Bonds. If the annual financial information or operating data to be provided in the Annual Report is amended pursuant to the provisions hereof, the first annual financial information filed pursuant hereto containing the amended operating data or financial information shall explain, in narrative form, the reasons for the amendment and the impact of the change in the type of operating data or financial information being provided. If an amendment is made to the undertaking specifying the accounting principles to be followed in preparing financial statements, the annual financial information for the year in which the change is made shall present a comparison between the financial statements or information prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles. The comparison shall include a qualitative discussion of the differences in the accounting principles and the impact of the change in the accounting principles on the presentation of the financial information, in order to provide information to investors to enable them to evaluate the ability of the City to meet its obligations. To the extent reasonably feasible, the comparison shall be quantitative. A notice of the change in the accounting principles shall be filed in the same manner as for a Listed Event under Section 5(c). Section 10. Additional Information. Nothing in this Disclosure Certificate shall be deemed to prevent the City from disseminating any other information, using the means of dissemination set forth in this Disclosure Certificate 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 Certificate. If the City 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 Certificate, the City shall have no obligation under this Disclosure Certificate to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event. Section 11. Default. In the event of a failure of the City to comply with any provision of this Disclosure Certificate, the Participating Underwriter or any holder or beneficial owner of the 2022 Bonds may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the City to comply with its obligations under this Disclosure Certificate. A default under this Disclosure Certificate shall not be deemed an Event of Default under the Indenture, and the sole remedy under this Disclosure Certificate in the event of any failure of the City to comply with this Disclosure Certificate shall be an action to compel performance. Section 12. Duties, Immunities and Liabilities of Dissemination Agent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Certificate, and the City agrees to indemnify and save the Dissemination Agent, its 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, E-6 including the costs and expenses (including attorneys' fees) of defending against any claim of liability, but excluding liabilities due to the Dissemination Agent's negligence or willful misconduct. The Dissemination Agent shall have no duty or obligation to review any information provided to it hereunder and shall not be deemed to be acting in any fiduciary capacity for the City, the Trustee, the 2022 Bond owners or any other party. The obligations of the City under this Section shall survive resignation or removal of the Dissemination Agent and payment of the 2022 Bonds. Section 13. Beneficiaries. This Disclosure Certificate shall inure solely to the benefit of the City, the Trustee, the Dissemination Agent, the Participating Underwriter and holders and beneficial owners from time to time of the 2022 Bonds, and shall create no rights in any other person or entity. Section 14. Counterparts. This Disclosure Certificate may be executed in several counterparts, each of which shall be regarded as an original, and all of which shall constitute one and the same instrument. Date: .2022 E-7 CITY OF LODI M APPENDIX F DTC AND THE BOOK -ENTRY ONLY SYSTEM The information in this Appendix F regarding DTC and its book -entry system has been obtained from DTC's website, for use in securities offering documents, and the City takes no responsibility for the accuracy or completeness thereof or for the absence of material changes in such information after the date hereof. The Depository Trust Company ("DTC"), New York, New York, acts as securities depository for the Bonds. The Bonds were issued as fully—registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully -registered bond certificate was issued for each maturity of each series of the Bonds, each in the aggregate principal amount of such maturity, and will be deposited with DTC. DTC, the world's largest securities depository, is a limited -purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934, as amended. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non - U.S. equity issues, corporate 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 between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). DTC has a Standard & Poor's rating of AA+. The DTC Rules applicable to Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com. Purchases of the Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the 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. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the 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 Bonds, except in the event that use of the book -entry system for the Bonds is discontinued. F-1 To facilitate subsequent transfers, all Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co. or such other name as may be requested by an authorized representative of DTC. The deposit of Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not affect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Bonds; DTC's records reflect only the identity of the Direct Participants to whose accounts such Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Bonds, such as redemptions, tenders, defaults and proposed amendments to the Bond documents. For example, Beneficial Owners of Bonds may wish to ascertain that the nominee holding the Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of the notices be provided directly to them. While the Bonds are in the book -entry -only system, redemption notices will be sent to DTC. If less than all of the Bonds of a maturity are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to the Bonds unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the City as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts the Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Principal and interest payments on the Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detail information from the City or the Trustee on the payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of such Participant and not of DTC, the Trustee or the City, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of principal and interest payments to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the City or the Trustee, disbursement 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. DTC may discontinue providing its services as depository with respect to the Bonds at any time by giving reasonable notice to the City or the Trustee. Under such circumstances, in F-2 the event that a successor depository is not obtained, certificates representing the Bonds are required to be printed and delivered. The City may decide to discontinue use of the system of book -entry -only transfers through DTC (or a successor securities depository). In that event, certificates representing the Bonds will be printed and delivered to DTC. F-3 LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE REFUNDING BONDS (2012 REFUNDING; CAPITAL PROJECTS FINANCING) BOND PURCHASE AGREEMENT 52022 Lodi Public Financing Authority P.O. Box 3006 Lodi, California 95241-1910 City of Lodi P.O. Box 3006 Lodi, California 95241-1910 Ladies and Gentlemen: Piper Sandler & Co. (the "Underwriter"), hereby offers to enter into this Bond Purchase Agreement with you, the City of Lodi (the "City") and the Lodi Public Financing Authority (the "Authority"), for the purchase by the Underwriter and the delivery by you of the Authority's 2022 Lease Revenue Refunding Bonds (the "Bonds"). The Bonds are primarily being issued to (i) refund the outstanding amount of the Authority's $19,080,000 original principal amount of 2012 Refunding Lease Revenue Bonds (the "Refunded Bonds") and the City's related lease payment obligation and (ii) finance the acquisition and construction of capital improvements of the City, including a new animal shelter. This offer is made subject to acceptance by you prior to 11:59 p.m., Los Angeles time, on the date hereof. Upon such acceptance, this Bond Purchase Agreement shall be in full force and effect in accordance with its terms and shall be binding upon you and the Underwriter. 1. Purchase and Sale. Upon the terms and conditions and upon the basis of the representations, warranties and agreements hereinafter set forth, the Underwriter agrees to purchase from the Authority all (but not less than all) of the $ aggregate principal amount of the Bonds. The purchase price for the Bonds shall be $ (being the principal amount of the Bonds, [plus original issue premium] [less original issue discount] in the amount of $ and less an Underwriter's discount in the amount of $). The Bonds will be dated the date of delivery thereof and will have the maturities and bear interest at the rates set forth on Exhibit A hereto. The Bonds will be subject to redemption as set forth in the Indenture and Official Statement herein described. The Bonds will be issued in book -entry form only. It is anticipated that CUSIP identification numbers will be inserted on the Bonds, but neither the failure to provide such numbers nor any error with respect thereto shall constitute a cause for failure or refusal by the Underwriter to accept delivery of the Bonds in accordance with the terms of this Bond Purchase Agreement. [The scheduled payment of principal of and interest on [the Bonds] [certain maturities of the Bonds indicated on Exhibit A hereto] when due will be guaranteed under a municipal bond insurance policy (the "Policy") to be issued concurrently with the delivery of the Bonds by (the "Insurer"). As an accommodation to the Authority and City, the Underwriter will wire from the Purchase Price the premium for the Policy in the amount of $ on the date of Closing (defined below).] 2. Authorizing Instruments and Law. The Bonds shall be issued pursuant to the provisions of a resolution (the "Resolution") adopted by the Authority on , 2022 authorizing the issuance of the Bonds and the Marks -Roos Local Bond Pooling Act of 1985, constituting Section 6584, et seq. of the California Government Code (the "JPA Act"). The Bonds are issued pursuant to an Indenture of Trust, dated as of March 1, 2022 (the "Indenture"), between the Authority and U.S. Bank National Association, as trustee (the "Trustee"), and shall be as described in the Indenture. The Bonds are limited obligations of the Authority payable primarily from and secured by certain lease payments (the "Lease Payments") to be paid by the City pursuant to a Lease Agreement, dated as of March 1, 2022, between the City and the Authority (the "Lease"), for certain real property and the improvements thereon (the "Leased Property"). The Refunded Bonds will be defeased and refunded in accordance with Irrevocable Refunding Instructions from the Authority to U.S. Bank National Association, as trustee for the Refunded Bonds, dated , 2022 (the "Irrevocable Refunding Instructions"). 3. Offering the Bonds. The Underwriter agrees to offer all the Bonds to the public initially at the prices (or yields) set forth on the cover pages of the Official Statement of the Authority pertaining to the Bonds, dated , 2022 (the Official Statement, together with all appendices thereto, and with such changes therein and supplements thereto as are consented to in writing by the Authority, the City, the Underwriter or its legal counsel in accordance with the provisions of Sections 60) and 70) hereof or otherwise consented to by the Underwriter pursuant to Section 10(b)(v), are herein called the "Official Statement"). Subsequent to the initial public offering of the Bonds, the Underwriter reserves the right to change the public offering prices (or yields) as they deem necessary in connection with the marketing of the Bonds. The Bonds may be offered and sold to certain dealers at prices lower than such initial public offering prices. "Public Offering" shall include an offering to a number of institutional investors or registered investment companies, regardless of the number of such investors to which the Bonds are sold. The City and the Authority acknowledge and agree that (i) the purchase and sale of the Bonds pursuant to this Bond Purchase Agreement is an arm's-length commercial transaction between the City, the Authority and the Underwriter, and that the Underwriter has financial and other interests that differ from those of the City and the Authority, (ii) in connection with such transaction the Underwriter is not acting as a municipal advisor, financial advisor or fiduciary to the City and the Authority or any other person or entity and have not assumed a fiduciary responsibility in favor of the City or the Authority with respect to the offering of the Bonds or the process leading thereto (whether or not the Underwriter has advised or is currently advising the City or the Authority on other matters), (iii) the only contractual obligations the Underwriter has to the City and the Authority with respect to the transaction contemplated hereby expressly are set forth in this Bond Purchase Agreement, except as otherwise provided by applicable rules and regulations of the SEC or the rules of the Municipal Securities Rulemaking Board (the "MSR -B") and (iv) the City and the Authority have consulted with their own legal and other professional advisors to the extent they deemed appropriate in connection with the offering of the Bonds. The City and the Authority acknowledge that they have previously provided the Underwriter with an acknowledgement of receipt of the required Underwriter disclosure 2 under Rule G-17 of the MSRB relating to disclosures concerning the Underwriter's role in the transaction, disclosures concerning the Underwriter's compensation, conflict disclosures, if any, and disclosures concerning complex municipal securities financing, if any. 4. Delivery of Official Statement. If requested by the Underwriter, the Authority shall deliver to the Underwriter two (2) copies of the Official Statement manually executed on behalf of the Authority and the City. The Authority shall also deliver copies of the Official Statement in such quantities as the Underwriter may reasonably request in order to enable the Underwriter to distribute a single copy of each Official Statement to any potential customer of the Underwriter requesting an Official Statement during the time period beginning when the Official Statement becomes available and ending on the End Date (defined below). The Authority shall deliver these copies to the Underwriter within seven (7) business days after the execution of this Bond Purchase Agreement and in sufficient time to accompany or precede any sales confirmation that requests payment from any customer of the Underwriter. The Authority and the City shall prepare the Official Statement, including any amendments thereto, in word -searchable PDF format as described in the MSRB's Rule G-32 and shall provide the electronic copy of the word -searchable PDF format of the Official Statement to the Underwriter no later than one (1) business day prior to the Closing Date to enable the Underwriter to comply with MSRB Rule G-32. The Authority and the Underwriter hereby agree that the end of the underwriting period shall be the date of Closing (as defined below) unless the Underwriter informs the Authority in writing of a different end of the underwriting period. "End Date" as used herein is that date which is the earlier of: (a) twenty-five (25) days after the end of the underwriting period, as defined in SEC Rule 15c2-12 originally adopted by the Securities and Exchange Commission on June 28, 1989, as amended ("Rule 15c2-12"); or (b) the time when the Official Statement becomes available from the MSRB, but in no event less than twenty-five (25) days after the underwriting period (as defined in Rule 15c2-12) ends. The Underwriter acknowledges that the "End Date" will be the date of Closing unless the Underwriter otherwise notifies the Authority and the City in writing that the Underwriter still owns some or all of the Bonds. The Authority and the City have authorized the use of the Official Statement in connection with the public offering of the Bonds. The Authority and the City also have consented to the use by the Underwriter prior to the date hereof of the Preliminary Official Statement dated , 2022, relating to the Bonds in connection with the public offering of the Bonds, (which, together with all appendices thereto, is herein called the "Preliminary Official Statement"). Authorized officers of the City and the Authority have certified to the Underwriter that such Preliminary Official Statement was deemed to be final as of its date for purposes of Rule 15c2-12, with the exception of certain final pricing and related information referred to in Rule 15c2-12. The Underwriter has distributed a copy of each Preliminary Official Statement to potential customers on request. 5. The Closing. At 9:00 A.M., California time, on , 2022, or at such other time or on such earlier or later business day as shall have been mutually agreed upon by the Authority, the City and the Underwriter, the Authority, upon receipt of the purchase price thereof, will deliver (i) the Bonds in book -entry form through the facilities of The Depository Trust Company ("DTC"), and (ii) the closing documents hereinafter mentioned at the offices of Jones Hall, A Professional Law Corporation, San Francisco, California ("Bond Counsel"), or another place to be mutually agreed upon by the Authority, the City and the Underwriter. The Underwriter will accept such delivery from the Authority. The Underwriter will pay the purchase price of the Bonds as set forth in Section 1 hereof by wire transfer of immediately available funds. This payment and delivery, together with the delivery of the aforementioned documents, is herein called the "Closing." 6. City Representations, Warranties and Covenants. The City represents, warrants and covenants to the Underwriter that: (a) The City is a general law city organized and operating pursuant to the laws of the State of California (the "State") with power and authority to enter into and perform its duties under the Lease, the Continuing Disclosure Certificate, dated , 2022 (the "Continuing Disclosure Certificate"), the Site Lease, dated as of March 1, 2022 (the "Site Lease"), between the City and the Authority, the Official Statement and this Bond Purchase Agreement (collectively, the "City Documents"). (b) To the best knowledge of the City, neither the approval, execution and delivery of the City Documents, and compliance with the provisions on the City's part contained therein, nor the consummation of any other of the transactions herein and therein contemplated, nor the fulfillment of the terms hereof and thereof, materially conflicts with or constitutes a material breach of or default under nor materially contravenes any law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject, nor does any such execution, delivery, adoption or compliance result in a security interest or encumbrance of any nature whatsoever upon any of the properties or assets of the City 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 City Documents. (c) The City Documents have been duly authorized, executed and delivered by the City, and, assuming due authorization, execution and delivery by the other parties thereto, constitute legal, valid and binding agreements of the City enforceable in accordance with their respective terms, except as the enforcement thereof may be limited by bankruptcy, insolvency, moratorium, reorganization, fraudulent conveyance or other laws affecting the enforcement of creditors' rights generally, and by the application of equitable principles if sought, by the exercise of judicial discretion, and by the limitations on legal remedies imposed on actions against cities in the State. (d) Except as may be required under blue sky or other securities laws of any state, there is no material consent, approval, authorization or other order of, or filing with, or certification by, any regulatory agency having jurisdiction over the City required for the execution and delivery of the Bonds or the consummation by the City of the other transactions contemplated by the Official Statement and this Bond Purchase Agreement. (e) To the best of the knowledge of the City, there is, and on the Closing there will be, no action, suit, proceeding or investigation at law or in equity before or by any court or governmental agency or body pending (notice of which has been received by the City) or threatened against the City to restrain or enjoin the delivery of any of the Bonds, or the payments to be made pursuant to the Lease, or in any way contesting or affecting the validity of the City Documents or the Bonds or the authority of the City to approve this Bond Purchase Agreement, or enter into the City Documents or contesting the powers of the City to enter into or perform its obligations under any of rd the foregoing or in any way contesting the powers of the City in connection with any action contemplated by this Bond Purchase Agreement or to restrain or enjoin the execution, sale and delivery of the Bonds, contesting the completeness or accuracy of the Preliminary Official Statement as of its date or the Official Statement or any supplement or amendment thereto wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the City Documents to be executed by it or asserting that the Preliminary Official Statement as of its date or the Official Statement contained any untrue statement of a material fact or omitted to state any material fact required to be stated therein or necessary to make the statements therein, in light of all the circumstances under which they were made, not misleading, or, except as described in the Preliminary Official Statement and the Official Statement, nor is there any basis for any such action, suit, proceeding or investigation. (f) The Preliminary Official Statement provided to the Underwriter has been deemed final by the City, as required by Rule 15c2-12. As of the date thereof and at all times subsequent thereto up to and including the Closing, the information relating to the City, the Bonds, the Leased Property and the City Documents contained in the Official Statement was and will be materially complete for its intended purposes. The information relating to the City, the Bonds, the Leased Property and the City Documents contained in the Official Statement as of the date hereof is true and correct in all material respects and such information does not contain any untrue or misleading statement of a material fact or omit to state any 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. (g) The City agrees to cooperate with the Underwriter in endeavoring to qualify the Bonds for offering and sale under the securities or blue sky laws of such jurisdictions of the United States as the Underwriter may request; provided, however, that the City will not be required to execute a special or general consent to service of process in any jurisdiction in which it is not now so subject or to qualify to do business as a foreign corporation in any jurisdiction where it is not so qualified. The Underwriter shall be responsible for all costs relating to such qualification of the Bonds under blue sky or similar laws. (h) By official action of the City prior to or concurrently with the execution hereof, the City has duly approved the distribution of the Official Statement, and has duly authorized and approved the execution and delivery of, and the performance by the City of the obligations on its part contained in the City Documents and the consummation by it of all other transactions contemplated by the Official Statement and this Bond Purchase Agreement. (i) To the best knowledge of the City, it is not in any material respect in breach of or default under any material applicable law or administrative regulation of the State or the United States or any material applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject and in connection with which the City is obligated to make payments from its own funds, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute a default or an event of default under any such instrument the consequence of which could materially and adversely affect the performance of the City under the City Documents. 0) If between the date of this Bond Purchase Agreement and the End Date an event occurs, of which the City has knowledge, which might or would cause the information relating to the City, the City's finances, the Leased Property, or the City's functions, duties and responsibilities 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 presented, not misleading in any material respect, the City will notify the Underwriter, and if, in the opinion of the Underwriter, the City or their respective legal counsel, such event requires the preparation and publication of a supplement or amendment to the Official Statement, the City will cooperate with the Underwriter in the preparation of an amendment or supplement to the Official Statement in a form and in a manner approved by the Underwriter, provided all expenses thereby incurred will be paid for by the City. (k) If the information relating to the Leased Property, the City, its functions, duties and responsibilities contained in the Official Statement is amended or supplemented pursuant to the immediately preceding subparagraph, at the time of each 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 of the Closing, 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 presented, not misleading in any material respect. (1) The City covenants that it will comply with all tax covenants relating to it in the City Documents and the Tax Certificate. (m) Any certificate signed by a duly authorized official of the City and delivered to the Underwriter shall be deemed a representation and warranty by the City to the Underwriter as to the statements made therein. (n) As of the time of acceptance hereof and as of the Closing, the City does not and will not have outstanding any indebtedness which is payable from the City's general fund except as disclosed in the Official Statement. (o) Between the date of this Bond Purchase Agreement and the date of Closing, the City will not, except as disclosed in the Official Statement, offer or issue any certificates, notes or other obligations for borrowed money, or, other than in the normal course of its operations, incur any material liabilities, direct or contingent, secured by or payable from the City's general fund. (p) The City will undertake, pursuant to the Continuing Disclosure Certificate, to provide or cause to be provided annual financial reports and notices of certain events; a description of this undertaking is set forth in the Official Statement. Except as disclosed in the Preliminary Official Statement and Official Statement, the City and its related entities have not failed to comply in any material respect with a continuing disclosure undertaking under Rule 15c2-12 during the previous five years. (q) The City is the owner in fee of title of the Leased Property and no other governmental authority, person, firm or corporation can claim ownership to the Leased Property. (r) The Leased Property is an essential asset of the City. (s) As of the time of acceptance hereof and as of the Closing, the value of the Leased Property is not less than the initial aggregate principal amount of the Bonds. (t) The financial statements of, and other financial information regarding the City in the Official Statement fairly present the financial position and results of the operations of the City as of the dates and for the periods therein set forth and the audited financial statements have been prepared in accordance with generally accepted accounting principles applicable to cities. 7. Authority Representations, Warranties and Covenants. The Authority represents, warrants and covenants to the City and the Underwriter that: (a) The Authority is a joint powers authority, duly organized and existing under the Constitution (the "Constitution") and laws of the State, including the JPA Act, with full right, power and authority to enter into, execute and deliver the Authority Documents (defined below) and to perform its obligations hereunder. (b) By all necessary official action, the Authority has duly authorized and approved the execution and delivery of, and the performance by the Authority of the obligations on its part contained in the Bond Purchase Agreement, the Bonds, the Indenture, the Lease, the Site Lease, the Irrevocable Refunding Instructions and the Assignment Agreement, dated as of March 1, 2022 (the "Assignment Agreement"), between the Authority and the Trustee (collectively, the "Authority Documents"), and has approved the use by the Underwriter of the Preliminary Official Statement, and the Official Statement and, as of the date hereof, such authorizations and approvals are in full force and effect and have not been amended, modified or rescinded. When executed and delivered by the parties hereto, the Authority Documents will constitute the legally valid and binding obligations of the Authority enforceable upon the Authority in accordance with their respective terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws or equitable principles relating to or affecting creditors rights generally, to the exercise of judicial discretion and to the limitations on legal remedies against joint powers authorities in California. The Authority has complied and will at the Closing, be in compliance in all respects, with the terms of the Authority Documents. (c) The Bonds, when issued in accordance with the Indenture, will be valid and binding limited obligations of the Authority, entitled to the benefits of the Indenture and enforceable in accordance with their terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws or equitable principles relating to or limiting creditors' rights generally, to the exercise of judicial discretion and to the limitations on legal remedies against joint powers authorities in California. (d) As of the time of acceptance hereof and as of the time of the Closing, except as otherwise disclosed in the Official Statement, to the best knowledge of the Authority, the Authority is not and will not be in any material respect in breach of or in default under any law or administrative rule or regulation of the State or the United States, or any applicable judgment or decree or any trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the Authority is a party or is otherwise subject, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute a default or event of default under any such instrument which breach, default or event could have an adverse effect on the Authority's ability to perform its obligations under the Authority Documents; and, as of such times, except as disclosed in the Official Statement, the authorization, execution and delivery of the Authority Documents and compliance by the Authority with the provisions thereof do not and will not conflict with or constitute a breach of or default under any applicable constitutional provision, law or administrative rule or regulation of the State or the United States or any applicable judgment, decree, 7 license, permit, trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the Authority is subject, or by which it or any of its properties is bound, nor will any such authorization, execution, delivery 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 its assets or properties under the terms of any such law, regulation or instrument except as provided in the Authority Documents. (e) As of the time of acceptance hereof and the Closing, except as disclosed in the Official Statement, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending (notice of which has been received by the Authority), or to the best knowledge of the Authority threatened against the Authority in any material respect: (i) affecting the existence of the Authority or the titles of the officers of the Authority to their respective offices; (ii) affecting, contesting or seeking to prohibit, restrain or enjoin the issuance or delivery of any of the Bonds, or the payment or collection of any amounts pledged or to be pledged to pay the principal of and interest on the Bonds, or in any way contesting or affecting the validity of the Authority Documents or the consummation of the transactions on the part of the Authority contemplated thereby, or contesting the exclusion of the interest on the Bonds from Federal or State taxation, as applicable, or contesting the powers of the Authority or its authority to enter into the Lease and to pledge the Lease Payments for repayment of the Bonds; (iii) which may result in any material adverse change relating to the financial condition of the Authority; (iv) contesting the completeness or accuracy of the Preliminary Official Statement as of its date or the Official Statement or any supplement or amendment thereto or asserting that the Preliminary Official Statement as of its date or the Official Statement contained any untrue statement of a material fact or omitted to state any material fact required to be stated therein or necessary to make the statements therein, in light of all the circumstances under which they were made, not misleading; or (v) challenging the ability of the Authority to sell the Bonds to the Underwriter. (f) The Authority will furnish such information, execute such instruments and take such other action in cooperation with the Underwriter as the Underwriter may reasonably request in order to qualify the Bonds for offer and sale under the blue sky laws or other securities laws and regulations of such states and other jurisdictions of the United States as the Underwriter may designate and will use its best efforts to continue such qualification in effect so long as required for distribution of the Bonds; provided however, that in no event shall the Authority be required to take any action which would subject it to general or unlimited service of process in any jurisdiction in which it is not now so subject. (g) Any certificate signed by a duly authorized officer of the Authority and delivered to the Underwriter shall be deemed to be a representation and warranty by the Authority to the Underwriter as to the statements made therein. (h) As of the time of acceptance hereof and as of the date of Closing, except as otherwise disclosed in the Official Statement, the Authority has complied with the filing requirements of the JPA Act. (i) The Authority will advise the Underwriter promptly of any proposal to amend or supplement the Official Statement from the delivery of the Official Statement to the End Date and will not effect or consent to any such amendment or supplement without prior consultation with the Underwriter. The Authority will advise the Underwriter promptly of the institution of any proceedings known to it by any governmental agency prohibiting or otherwise affecting the use of the Official Statement in connection with the offering, sale or distribution of the Bonds. 0) Substantially all the proceeds from the sale of the Bonds (after deducting the expenses of issuance and sale of the Bonds paid for from such proceeds) will be used as set forth in the Indenture and as described in the Official Statement, and the Authority will not take or omit to take any action which action or omission will in any way cause the proceeds from the sale of the Bonds to be applied in a manner contrary to that provided in the Indenture and the Lease, as amended from time to time. (k) For a period beginning on the date hereof and continuing until the End Date, (a) the Authority will not adopt any amendment of, or supplement to, the Official Statement without prior consultation with the Underwriter and Kutak Rock LLP, counsel to the Underwriter ("Underwriter's Counsel") and (b) if any event relating to or affecting the Authority shall occur as a result of which it is necessary, in the opinion of the Underwriter and Underwriter's Counsel, to amend or supplement the Official Statement in order to make the Official Statement not misleading in the light of the circumstances existing at the time it is delivered to a purchaser of the Bonds, the Authority will forthwith cause the City to prepare and furnish to the Underwriter a reasonable number of copies of an amendment of, or supplement to, the Official Statement (in form and substance satisfactory to Underwriter's Counsel) 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 a purchaser of the Bonds, not misleading. 8. Establishment of Issue Price. (a) The Underwriter agrees to assist the Authority in establishing the issue price of the Bonds and shall execute and deliver to the Authority at Closing an "issue price" or similar certificate, together with the supporting pricing wires or equivalent communications, substantially in the form attached hereto as Exhibit B, with such modifications as may be appropriate or necessary, in the reasonable judgment of the Underwriter, the Authority and Bond Counsel, to accurately reflect, as applicable, the sales price or prices or the initial offering price or prices to the public of the Bonds. (b) Except as otherwise set forth in Exhibit A attached hereto, the Authority will treat the first price at which 10% of each maturity of the Bonds (the "10% test") is sold to the public as the issue price of that maturity. At or promptly after the execution of this Bond Purchase Agreement, the Underwriter shall report to the Authority the price or prices at which it has sold to the public each maturity of Bonds. If at that time the 10% test has not been satisfied as to any maturity of the Bonds, the Underwriter agrees to promptly report to the Authority the prices at which it sells the unsold Bonds of that maturity to the public. That reporting obligation shall continue, whether or not the Closing Date has occurred, until either (i) the Underwriter has sold all Bonds of that maturity or (ii) the 10% test has 7 been satisfied as to the Bonds of that maturity, provided that, the Underwriter's reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Authority or Bond Counsel. For purposes of this Section, if Bonds mature on the same date but have different interest rates, each separate CUSIP number within that maturity will be treated as a separate maturity of the Bonds. (c) The Underwriter confirms that it has offered the Bonds to the public on or before the date of this Bond Purchase Agreement at the offering price or prices (the "initial offering price"), or at the corresponding yield or yields, set forth in Exhibit A attached hereto. Exhibit A also sets forth, as of the date of this Bond Purchase Agreement, the maturities, if any, of the Bonds for which the Underwriter represents that (i) the 10% test has been satisfied (assuming orders are confirmed by the close of the business day immediately following the date of this Bond Purchase Agreement) and (ii) the 10% test has not been satisfied and for which the Authority and the Underwriter agree that the restrictions set forth in the next sentence shall apply, which will allow the Authority to treat the initial offering price to the public of each such maturity as of the sale date as the issue price of that maturity (the "hold -the -offering -price rule"). So long as the hold -the -offering -price rule remains applicable to any maturity of the Bonds, the Underwriter will neither offer nor sell unsold Bonds of that maturity to any person at a price that is higher than the initial offering price to the public during the period starting on the sale date and ending on the earlier of the following: (A) the close of the fifth (5th) business day after the sale date; or (B) the date on which the Underwriter has sold at least 10% of that maturity of the Bonds to the public at a price that is no higher than the initial offering price to the public. The Underwriter will advise the Authority promptly after the close of the fifth (5th) business day after the sale date whether it has sold 10% of that maturity of the Bonds to the public at a price that is no higher than the initial offering price to the public. (d) The Underwriter confirms that: (i) any selling group agreement and any third -party distribution agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer who is a member of the selling group and each broker-dealer that is a party to such third -party distribution agreement, as applicable: (A)(i) to report the prices at which it sells to the public the unsold Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Bonds of that maturity allocated to it have been sold or it is notified by the Underwriter that the 10% test has been satisfied as to the Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be reasonable periodic intervals or otherwise upon request of the Underwriter and (ii) to comply with the hold -the -offering -price rule, if applicable, if and for so long as directed by the Underwriter, (B) to promptly notify the Underwriter of any sales of Bonds that, to its knowledge, are made to a purchaser who is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below), and 10 (C) to acknowledge that, unless otherwise advised by the dealer or broker-dealer, the Underwriter shall assume that each order submitted by the dealer or broker-dealer is a sale to the public. (ii) any selling group agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer that is a party to a third -party distribution agreement to be employed in connection with the initial sale of the Bonds to the public to require each broker-dealer that is a party to such third -party distribution agreement to (A) report the prices at which it sells to the public the unsold Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Bonds of that maturity allocated to it have been sold or it is notified by the Underwriter or the dealer that the 10% test has been satisfied as to the Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Underwriter or the dealer, and (B) comply with the hold -the -offering -price rule, if applicable, if and for so long as directed by the Underwriter or the dealer and as set forth in the related pricing wires. (e) The Authority acknowledges that, in making the representation set forth in this section, the Underwriter will rely on (i) in the event a selling group has been created in connection with the initial sale of the Bonds to the public, the agreement of each dealer who is a member of the selling group to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Bonds, as set forth in a selling group agreement and the related pricing wires, and (ii) in the event that a third - party distribution agreement was employed in connection with the initial sale of the Bonds to the public, the agreement of each broker-dealer that is a party to such agreement to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Bonds, as set forth in the third - party distribution agreement and the related pricing wires. The Authority further acknowledges that the Underwriter shall not be liable for the failure of any dealer who is a member of a selling group, or of any broker-dealer that is a party to a third -party distribution agreement, to comply with its corresponding agreement to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Bonds. (f) The Underwriter acknowledges that sales of any Bonds to any person that is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below) shall not constitute sales to the public for purposes of this section. Further, for purposes of this section: a. "public" means any person other than an underwriter or a related party; b. "underwriter" means (A) any person that agrees pursuant to a written contract with the Authority (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the public and (B) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (A) to participate in the initial sale of the Bonds to the public (including a member of a selling group or a party to a third -party distribution agreement participating in the initial sale of the Bonds to the public); C. a purchaser of any of the Bonds is a "related party" to an underwriter if the underwriter and the purchaser are subject, directly or indirectly, to (A) more than 11 50% common ownership of the voting power or the total value of their stock, if both entities are corporations (including direct ownership by one corporation of another), (B) more than 50% common ownership of their capital interests or profits interests, if both entities are partnerships (including direct ownership by one partnership of another), or (C) more than 50% common ownership of the value of the outstanding stock of the corporation or the capital interests or profit interests of the partnership, as applicable, if one entity is a corporation and the other entity is a partnership (including direct ownership of the applicable stock or interests by one entity of the other); and d. "sale date" means the date of execution of this Bond Purchase Agreement by all parties. 9. Closing Conditions. The Underwriter has entered into this Bond Purchase Agreement in reliance upon the representations, warranties and covenants herein and the performance by the Authority and the City of their respective obligations hereunder, both as of the date hereof and as of the date of the Closing. The Underwriter's obligations hereunder are and shall be subject to the following additional conditions: (a) Bring -Down Representation. The representations, warranties and covenants of the Authority and the City contained herein shall be true and correct at the date hereof and at the time of the Closing, as if made on the date of the Closing. (b) Executed Agreements and Performance Thereunder. At the time of the Closing: (i) the City Documents and the Authority Documents shall be in full force and effect, and shall not have been amended, modified or supplemented except with the prior written consent of the Underwriter; (ii) there shall be in full force and effect such resolutions (the "Authorizing Resolutions") as, in the opinion of Bond Counsel, shall be necessary in connection with the transactions on the part of the Authority and the City contemplated by the City Documents and the Authority Documents; (iii) the Authority shall perform or have performed its obligations required or specified in the Authority Documents to be performed at or prior to Closing; (iv) the City shall perform or have performed its obligations required as specified in the City Documents to be performed at or prior to Closing; and (v) the Official Statement shall not have been supplemented or amended, except pursuant to Paragraph 60) or 7(i), or as otherwise may have been agreed to in writing by the Underwriter. (c) No Default. At the time of the Closing, no default shall have occurred or be existing under the Authority Documents or the City Documents and neither the Authority nor the City shall be in default in the payment of principal or interest on any of its bonded indebtedness or other obligations payable from the City's general fund which default shall adversely impact the ability of the Authority to make payments on the Bonds or the City to make payments pursuant to the Lease. 12 (d) Termination Events. The Underwriter shall have the right to terminate this Bond Purchase Agreement, without liability therefor, by written notification to the Authority and the City if at any time at or prior to the Closing the market price or marketability of the Bonds, or the ability of the Underwriter to enforce contracts for the sale of the Bonds, shall have been materially adversely affected in the reasonable judgment of the Underwriter (evidenced by a written notice to the City and the Authority terminating the obligation of the Underwriter to accept delivery of and pay for the Bonds) by reason of any of the following: (i) an amendment to the Constitution of the United States or by any legislation in or by the Congress of the United States or by the State, or the amendment of legislation pending as of the date of the Authority Documents or the City Documents in the Congress of the United States, or the recommendation to Congress or endorsement for passage (by press release, other form of notice or otherwise) of legislation by the President of the United States, the Treasury Department of the United States, the Internal Revenue Service or the Chairman or ranking minority member of the Committee on Finance of the United States Senate or the Committee on Ways and Means of the United States House of Representatives, or the proposal for consideration of legislation by either such Committee, or the presentment of legislation for consideration as an option by either such Committee, or by the staff of the Joint Committee on Taxation of the Congress of the United States, or the favorable reporting for passage of legislation to either House of the Congress of the United States by a Committee of such House to which such legislation has been referred for consideration, or any decision of any Federal or State court or any ruling or regulation (final, temporary or proposed) or official statement on behalf of the United States Treasury Department, the Internal Revenue Service or other Federal or State authority materially adversely affecting the Federal or State tax status of the Authority or the City, or the interest on bonds or notes or obligations of the general character of the Bonds; or (ii) any legislation, ordinance, rule or regulation shall be introduced in, or be enacted by any governmental body, department or agency of the States or a decision by any court of competent jurisdiction within the State or any court of the United States shall be rendered which, in the reasonable opinion of the Underwriter, materially adversely affects the market price of the Bonds; or (iii) legislation shall be enacted by the Congress of the United States, or a decision by a court of the United States shall be rendered, or a stop order, ruling, regulation or official statement by, or on behalf of, the Securities and Exchange Commission or any other governmental agency having jurisdiction of the subject matter shall be issued or made to the effect that the issuance, offering or sale of obligations of the general character of the Bonds, or the issuance, offering or sale of the Bonds, including all underlying obligations, as contemplated hereby or by the Official Statement, is in violation or would be in violation of, or that obligations of the general character of the Bonds, or the Bonds, are not exempt from registration under, any provision of the federal securities laws, including the Securities Act of 1933, as amended and as then in effect, or that the Indenture needs to be qualified under the Trust Indenture Act of 1939, as amended and as then in effect; or (iv) the New York Stock Exchange or other national securities exchange, or any governmental or regulatory authority, shall impose, as to the Bonds or obligations of the general character of the Bonds, any material restrictions not now in force, or increase materially those now in force, with respect to the extension of credit by, or the charge to the net capital requirements of the Underwriter; or 13 (v) a general banking moratorium shall have been established by federal or State authorities; or (vi) there shall have occurred (i) an outbreak or escalation of hostilities or the declaration by the United States of a national emergency or war or (ii) any other calamity or crisis in the financial markets of the United States or elsewhere or the escalation of such calamity or crisis; or (vii) the commencement of any action, suit or proceeding described in Paragraphs 6(e) or 7(e) hereof, or (viii) a general suspension of trading on the New York Stock Exchange or other major exchange shall be in force, or minimum or maximum prices for trading shall have been fixed and be in force, or maximum ranges for prices for securities shall have been required and be in force on any such exchange, whether by virtue of determination by that exchange or by order of the Securities and Exchange Commission or any other governmental authority having jurisdiction; or (ix) [any rating of the Insurer shall have been downgraded, suspended or withdrawn or placed on negative outlook or negative watch by a national rating service, which, in the Underwriter's reasonable opinion, materially adversely affects the marketability or market price of the Bonds or the ability of the Underwriter to enforce contracts for the sale of the Bonds; or] (x) any event occurring or information becoming known which, in the reasonable judgment of the Underwriter, makes untrue or incorrect in any material respect any statement or information contained in the Preliminary Official Statement or in the Official Statement or has the effect that the Preliminary Official Statement or the Official Statement contains any untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; or (xi) any rating of the Bonds or other obligations of the City shall have been downgraded, suspended or withdrawn or placed on negative outlook or negative watch by a national rating service, which, in the Underwriter's reasonable opinion, materially adversely affects the marketability or market price of the Bonds or the ability of the Underwriter to enforce contracts for the sale of the Bonds; or (xii) any proceeding shall be pending or threatened by the Securities and Exchange Commission against the Authority or the City; or (xiii) any fact or event shall exist or have existed that requires or has required an amendment of or supplement to the Official Statement in which the market price or marketability of the Bonds, or the ability of the Underwriter to enforce contracts for the sale of the Bonds, shall have been materially adversely affected in the reasonable judgment of the Underwriter; or (xiv) there shall have occurred any materially adverse change in the affairs or financial condition of the Authority or the City; or (xv) a material disruption in securities settlement, payment or clearance services affecting the Bonds shall have occurred; or 14 (xvi) the marketability of the Bonds or the market price thereof, in the opinion of the Underwriter, has been materially and adversely affected by disruptive events, occurrences or conditions in the securities or debt markets; or (xvii) a decision by a court of the United States shall be rendered, or a stop order, release, regulation or no -action letter by or on behalf of the SEC or any other governmental agency having jurisdiction of the subject matter shall have been issued or made, to the effect that the issuance, offering or sale of the Bonds, including the underlying obligations as contemplated by this Bond Purchase Agreement or by the Official Statement, or any document relating to the issuance, offering or sale of the Bonds, is or would be in violation of any provision of the federal securities laws at the Closing Date, including the Securities Act, the Exchange Act and the Trust Indenture Act. (e) Closing Documents. At or prior to the Closing, the Underwriter shall receive with respect to the Bonds (unless the context otherwise indicates) the following documents: (1) Bond Opinion. The approving opinions of Bond Counsel dated the date of Closing and substantially in the forms included as APPENDIX D to the Official Statement and a reliance letter(s) thereon dated the date of Closing addressed to the Underwriter and the Trustee. (2) Supplemental Opinion. A supplemental opinion of Bond Counsel dated the date of Closing, addressed to the Underwriter, to the effect that: (A) the statements on the cover of the Official Statement and in the Official Statement under the captions "INTRODUCTION," "THE BONDS," "THE LEASED PROPERTY," "SECURITY FOR THE BONDS," and "TAX MATTERS," and in "APPENDIX C — SUMMARY OF PRINCIPAL LEGAL DOCUMENTS" and "APPENDIX D — FORM OF OPINION OF BOND COUNSEL," excluding any material that may be treated as included under such captions and appendices by any cross-reference, insofar as such statements expressly summarize provisions of the Bonds, the Lease, the Site Lease, the Indenture, and Bond Counsel's final opinion concerning certain federal tax matters relating to the Bonds, are accurate in all material respects as of the date of Closing; provided, that Bond Counsel need not express any opinion with respect to any financial or statistical data contained therein or with respect to DTC or the book -entry system in which the Bonds are initially delivered; (B) The Lease, the Site Lease, the Assignment Agreement, the Continuing Disclosure Certificate and this Bond Purchase Agreement have been duly authorized, executed and delivered by the City and the Authority, as applicable, and are valid, legal and binding agreements of the City and the Authority enforceable in accordance with their terms, except that the rights and obligations under the Lease, the Site Lease, the Assignment Agreement, the Continuing Disclosure Certificate and this Bond Purchase Agreement are subject to bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws affecting creditors' rights, to the application of equitable principles if equitable remedies are sought, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against public agencies in the State, and provided that no opinion is expressed with respect to any indemnification or contribution provisions contained therein. (C) The Bonds are exempt from registration under the Securities Act of 1933, as amended, and the Indenture is exempt from qualification as an indenture pursuant to the Trust Indenture Act of 1939, as amended. 1 (3) Negative Assurance Letter of Disclosure Counsel. A letter of Jones Hall, A Professional Law Corporation, Disclosure Counsel to the Authority and the City, dated the date of Closing and addressed to the Authority, the City, and the Underwriter to the effect that based upon their participation in the preparation of the Official Statement as Disclosure Counsel to the Authority and without having undertaken to determine independently the accuracy or completeness of the contents in the Official Statement, such counsel has no reason to believe that the Preliminary Official Statement (except for the completion of pricing information and any other matters or terms of the Bonds relating thereto) as of its date or as of the date of this Purchase Agreement or the Official Statement as of its date or as of the date of the Closing (except that no opinion need be expressed as to any financial, statistical, economic, engineering or demographic data or forecasts, numbers, charts, tables, graphs, maps, estimates, projections, assumptions or expressions of opinion, any information about feasibility, valuation, appraisals, assessed values, market absorption, real estate, ownership, environmental or archaeological matters, the appendices thereto, or any information about [the Insurer, the Policy,] book -entry, The Depository Trust Company, debt service requirements or tax exemption included or referred to therein, which may be expressly excluded from the scope of the opinions), contains any untrue statement of a material fact or omits to state any material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. (4) Municipal Advisor Certificate. A certificate of Fieldman, Rolapp & Associates, Inc. ("Fieldman"), dated the Closing Date and addressed to the Authority, the City and the Underwriter, to the effect that (i) Fieldman has reviewed the Preliminary Official Statement and the Official Statement and (ii) no information has come to its attention which would lead it to believe that the information contained in the Preliminary Official Statement, as of its date and as of the date of this Purchase Agreement and the Official Statement, as of its date and the Closing Date, is not true or correct in all material respects, or that the Preliminary Official Statement, as of its date and as of the date of this Purchase Agreement and the Official Statement, as of its date and the Closing Date contains any untrue statement of a material fact or omits to state a material fact where necessary to make a statement not misleading. (5) Opinion of City Attorney. An opinion of the City Attorney, dated the date of the Closing and addressed to the Authority, the Trustee and the Underwriter, to the effect that: (A) the City is a general law city duly organized and validly existing under the Constitution and laws of the State of California; (B) the resolution of the City approving and authorizing the execution and delivery of the City Documents and approving and authorizing the issuance of the Bonds and the delivery of the Official Statement and other actions of the City was duly adopted at a meeting of the governing body of the City which was 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 the resolution is now in full force and effect and has not been amended or superseded in any way; (C) the City Documents have been duly authorized, executed and delivered by the City, and (assuming due execution and delivery by parties other than the City) are valid, legal and binding agreements of the City enforceable in accordance with their terms, except that the rights and obligations under the City Documents are subject to bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws affecting creditors' rights, to the application of equitable principles if equitable remedies are sought, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against public agencies in the State; IV (D) the authorization, execution and delivery of the Bonds, the Official Statement, and the City Documents by the City and compliance with the provisions thereof by the City of its obligations thereunder, will not conflict with, or constitute a breach or default under, in any material respect, any law, administrative regulation, court decree, resolution, ordinance or other agreement to which the City is subject or by which it is bound; and (E) there is no action, suit, proceeding, inquiry or investigation at law or in equity before or by any court or public body pending with respect to which the City has been served or, to such counsel's knowledge, threatened against or affecting the City, except as may be disclosed in the Official Statement, which would materially adversely impact the City's ability to complete the transactions contemplated by the City Documents, the Official Statement or any other document or certificate related to such transactions, restrain or enjoin the collection of Lease Payments with respect to the Lease, or in any way contesting or affecting the validity of the Bonds, the Official Statement or the City Documents. (6) Authority Counsel Opinion. An opinion of counsel to the Authority, dated the date of the Closing and addressed to the City, the Trustee and the Underwriter, to the effect that: (A) the Authority is a joint exercise of powers authority organized and existing under the laws of the State of California; (B) the resolution of the Authority approving and authorizing the execution and delivery of the Authority Documents, the Bonds and the Official Statement and other actions of the Authority was duly adopted at a meeting of the governing body of the Authority which was 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 the resolution is now in full force and effect and has not been amended or superseded in any way; (C) the Authority Documents have been duly authorized, executed and delivered by the Authority, and (assuming due execution and delivery by parties other than the Authority) are valid, legal and binding agreements of the Authority enforceable in accordance with their terms, except that the rights and obligations under the Authority Documents are subject to bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws affecting creditors' rights, to the application of equitable principles if equitable remedies are sought, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against public agencies in the State; (D) there is no action, suit, proceeding, inquiry or investigation at law or in equity before or by any court or public body pending with respect to which the Authority has been served or, to the such counsel's knowledge, threatened against or affecting the Authority, except as may be disclosed in the Official Statement, which would materially adversely impact the Authority's ability to complete the transactions contemplated by the Authority Documents, the Official Statement or any other document or certificate related to such transactions, restrain or enjoin the collection of Lease Payments with respect to the Lease, or in any way contesting or affecting the validity of the Bonds, the Official Statement, the Authority Documents or the transactions described in and contemplated thereby wherein an unfavorable decision, ruling or finding would materially adversely affect the validity and enforceability of the Bonds or the Authority Documents or in which a final adverse decision could materially adversely affect the operations of the Authority; and 17 (E) the execution and delivery of the Authority Documents and the issuance of the Bonds and compliance with the provisions thereof, do not and will not in any material respect conflict with or constitute on the part of the Authority a breach of or default under any agreement or other instrument to which the Authority is a party or by which it is bound or any existing law, regulation, court order or consent decree to which the Authority is subject, which breach or default has or may have a material adverse effect on the ability of the Authority to perform its obligations under the Authority Documents. (7) Underwriter's Counsel Opinion. An opinion of Underwriter's Counsel, dated the date of the Closing addressed to the Underwriter, in such form as may be acceptable to the Underwriter. (8) City Certificate. A certificate, dated the date of Closing, signed by a duly authorized official of the City satisfactory in form and substance to the Underwriter to the effect that: (a) the representations, warranties and covenants of the City contained in this Bond Purchase Agreement are true and correct in all material respects on and as of the date of the Closing as if made on the date of the Closing; (b) the City has complied with all agreements, covenants and conditions to be complied with by the City at or prior to the Closing under the City Documents; (c) to the best of such official's knowledge, no event affecting the City has occurred since the date of the Official Statement which either makes untrue or incorrect in any material respect as of the Closing the statements or information contained in the Official Statement or is not reflected in the Official Statement but should be reflected therein in order to make the statements and information therein, in the light of the circumstances under which they were made, not misleading in any material respect. (9) Authority Certificate. A certificate of the Authority, dated the date of the Closing, signed on behalf of the Authority by the Chair or other duly authorized officer of the Authority to the effect that (a) the representations, warranties and covenants of the Authority contained herein and in the Authority Documents are true and correct in all material respects on and as of the date of the Closing as if made on the date of the Closing; (b) the Authority has complied with all agreements, covenants and conditions to be complied with by the Authority at or prior to the Closing under the Authority Documents and (c) to the best of such official's knowledge, no event affecting the Authority has occurred since the date of the Official Statement which has not been disclosed therein or in any supplement or amendment thereto which event should be disclosed in the Official Statement in order to make the statements therein, in the light of the circumstances under which they were made, not misleading. (10) Trustee's Certificate. A certificate of the Trustee, dated the Closing Date, in form and substance acceptable to the Authority, Bond Counsel, the Underwriter and Underwriter's Counsel. (11) Trustee Incumbency Certificate. A certified copy of a certificate of an officer of the Trustee certifying as to the incumbency, signature and signing authority of the officers who have executed and delivered the Indenture and agreed to accept the duties of Trustee under the Indenture. (12) Trustee Counsel's Opinion. An opinion, dated the date of the Closing addressed to the Authority, the City and the Underwriter, of the Trustee's Counsel, in form and content satisfactory to the Authority, Bond Counsel, the Underwriter and Underwriter's Counsel. I: (13) Title Policy. A copy of a CLTA or ALTA title insurance policy in an amount equal to the principal amount of the Bonds, insuring the City's leasehold interest in the Leased Property, subject only to Permitted Encumbrances (as defined in the Lease) or such other acceptable encumbrances. (14) Transcripts. Two CD transcripts of the proceedings prepared by Bond Counsel relating to the authorization and issuance of the Bonds will be delivered in due course after the Closing. (15) Official Statement. The Official Statement and each supplement or amendment, if any, thereto, executed on behalf of the Authority by a duly authorized officer of each. (16) Documents. An original executed or certified copy of each of the Authority Documents, the City Documents and the Joint Exercise of Powers Agreement (the "JPA Agreement"), dated , between the City and the Industrial Development Authority of the City of Lodi and any amendments thereto. (17) City Resolution. Certified copy by the City Clerk, of each resolution of the City relating to the City Documents, the actions contemplated thereby, provided that such resolutions may be contained in the transcripts. (18) Authority Resolution. Certified copy by the Secretary or Assistant Secretary of the Authority, of each resolution of the Authority relating to the Authority Documents, the Bonds and the transactions contemplated thereby, provided that such resolutions may be contained in the transcripts. (19) IRS Form 8038-G. Evidence that the federal tax information form 8038 G has been prepared for filing. (20) Tax Certificate. A Tax Certificate in a form satisfactory to Bond Counsel. (21) Rating. Evidence as of the Closing satisfactory to the Underwriter that the Bonds have received the rating set forth in the Official Statement and that such rating has not been reduced or withdrawn. (22) CDIAC Statement. A copy of the Notice of Final Sale required to be delivered to the California Debt and Investment Advisory Commission pursuant to section 53583 of the Government Code and section 8855(g) of the Government Code. (23) rPolic . The Policy, duly executed by the Insurer. (24) Insurer Counsel Opinion. An opinion of counsel to the Insurer, dated the Closing Date, addressed to the Authority, the City and the Underwriter, in form and substance satisfactory to the Underwriter and Bond Counsel. (25) Insurer Certificate. A certificate or certificates of the Insurer, dated the Closing Date, as to the accuracy of the information relating to the Insurer and the Policy included in the Official Statement and such other matters reasonably requested by the Underwriter and Bond Counsel.] 19 (26) Additional Documents. Such additional certificates, instruments and other documents as the Underwriter and Bond Counsel may reasonably deem necessary. If the Authority or the City shall be unable to satisfy the conditions contained in this Bond Purchase Agreement, or if the obligations of the Underwriter shall be terminated for any reason permitted by this Bond Purchase Agreement, this Bond Purchase Agreement may be terminated by the Underwriter, and none of the Underwriter, the Authority or the City shall be under further obligation hereunder. 10. Expenses. Except as otherwise provided in this Section, the Underwriter shall be under no obligation to pay, and the Authority or the City shall pay or cause to be paid, the expenses incident to the performance of the obligations of the Authority and the City hereunder including but not limited to: (a) the costs of the preparation and printing, or other reproduction (for distribution on or prior to the date hereof) of the City Documents and the Authority Documents and the cost of preparing, printing, issuing and delivering the Bonds; (b) the fees and disbursements of any counsel, municipal advisors, accountants, or other experts or consultants retained by the Authority or the City; (c) the fees and disbursements of Bond Counsel and Disclosure Counsel; (d) the cost of preparation and printing the Preliminary Official Statement and any supplements and amendments thereto and the cost of preparation and printing of the Official Statement, including a reasonable number of copies thereof for distribution by the Underwriter; and (e) charges of rating agencies for the rating of the Bonds. The Underwriter shall pay all expenses incurred by the Underwriter in connection with the public offering and distribution of the Bonds including, but not limited to: (i) the fees and disbursements of Underwriter's Counsel; and (ii) all out-of-pocket disbursements and expenses incurred by the Underwriter in connection with the offering and distribution of the Bonds (including other expenses, fees of the California Debt and Investment Advisory Commission, CUSIP Service Bureau fees, and any other fees and expenses), except as otherwise provided in the preceding paragraph or otherwise agreed to by the Underwriter, the Authority and the City in writing. Any meals in connection with or adjacent to meetings, rating agency presentations, pricing activities or other transaction -related activities shall be considered an expense of the transaction and included in the expense component of the Underwriter's discount. 11. Notice. Any notice or other communication to be given to the Underwriter may be given by delivering the same to Piper Sandler & Co., 2321 Rosecrans Avenue, Suite 3200, El Segundo, California 90245, Attention: Public Finance. Any notice or other communication to be given to the Authority or the City pursuant to this Bond Purchase Agreement may be given by delivering the same in writing to such entity, at the addresses set forth on the cover page hereof. 12. Entire Agreement. This Bond Purchase Agreement, when accepted by the Authority and the City, shall constitute the entire agreement among the Authority, the City and the Underwriter and is made solely for the benefit of the Authority, the City and the Underwriter (including the 20 successors or assigns of any Underwriter). Except as provided in Section 16 below, no other person shall acquire or have any right hereunder by virtue hereof, except as provided herein. All the Authority's and the City's representations, warranties and agreements in this Bond Purchase Agreement shall remain operative and in full force and effect, regardless of any investigation made by or on behalf of the Underwriter, until the earlier of (a) delivery of and payment for the Bonds hereunder, and (b) any termination of this Bond Purchase Agreement. 13. Definitions. Terms not otherwise defined herein shall have the same meaning as when used in the Indenture or the Lease. 14. Severability. In case any one or more of the provisions contained herein shall for any reason be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provision hereof. 15. State of California Law Governs. The validity, interpretation and performance of the Authority Documents shall be governed by the laws of the State. 16. No Assignment. The rights and obligations created by this Bond Purchase Agreement shall not be subject to assignment by the Underwriter, the Authority or the City without the prior written consent of the other parties hereto. 21 17. Counterparts. This Bond Purchase Agreement may be executed by the parties hereto in separate counterparts, each of which when so executed and delivered shall be an original, but all such counterparts shall together constitute but one and the same instrument. PIPER SANDLER & CO. Authorized Officer The foregoing is hereby agreed to and accepted as of the date first above written: LODI PUBLIC FINANCING AUTHORITY By:_ Title: Time of Execution: CITY OF LODI By: Titl Time of Execution: p.m. California time p.m. California time [EXECUTION PAGE OF BOND PURCHASE AGREEMENT] S-1 EXHIBIT A MATURITY SCHEDULE LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE REFUNDING BONDS (2012 REFUNDING; CAPITAL PROJECTS FINANCING) MATURITY SCHEDULE Subject to Hold -The- Offering - 10% Test Price Rule Maturity Principal Interest 10% Test Not (marked if (October 1) Amount Rate Yield Price Satisfied* Satisfied used) 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 20 (T) (I) Insured Bond. (T) Term Bond. (c)Priced to optional call at [par] on October 1, 20 * At the time of execution of this Purchase Agreement and assuming orders are confirmed by the close of the business day immediately following the date of this Purchase Agreement. A- I EXHIBIT B LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE REFUNDING BONDS (2012 REFUNDING; CAPITAL PROJECTS FINANCING) FORM OF ISSUE PRICE CERTIFICATE The undersigned, on behalf of Piper Sandler & Co. ("Piper") hereby certify as set forth below with respect to the sale and issuance of the above -captioned bonds (the "Bonds"). 1. Sale of the General Rule Maturities. As of the date of this certificate, for each Maturity of the General Rule Maturities, the first price at which at least 10% of such Maturity was sold to the Public is the respective price listed in Schedule A. 2. Defined Terms. (a) General Rule Maturities means those Maturities of the Bonds listed in Schedule A hereto as the "General Rule Maturities." (b) Issuer means the Lodi Public Financing Authority. (c) Maturity means Bonds with the same credit and payment terms. Bonds with different maturity dates, or Bonds with the same maturity date but different stated interest rates, are treated as separate maturities. (d) Public means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter. The term "related party" for purposes of this certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. (e) Underwriter means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Bonds to the Public (including a member of a selling group or a party to a retail or other third -party distribution agreement participating in the initial sale of the Bonds to the Public). The representations set forth in this certificate are limited to factual matters only. Nothing in this certificate represents Piper's interpretation of any laws, including specifically Sections 103 and 148 of the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the Certificate as to Tax Exemption and with respect to compliance with the federal income tax rules affecting the Bonds, and by Jones Hall, A Professional Law Corporation in connection with rendering its opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other federal income tax advice that it may give to the Issuer from time to time relating to the Bonds. PIPER SANDLER & CO. By: Name: Dated: , 2022 SCHEDULE A SALE PRICES OF THE GENERAL RULE MATURITIES (to be attached) Jones Hall 2-23-22 Agenda TO BE RECORDED AND WHEN RECORDED RETURN TO: Jones Hall, A Professional Law Corporation 475 Sansome Street, Suite 1700 San Francisco, California 94111 Attention: Christopher K. Lynch, Esq. THIS TRANSACTION IS EXEMPT FROM CALIFORNIA DOCUMENTARY TRANSFER TAX UNDER SECTION 11929 OF THE CALIFORNIA REVENUE AND TAXATION CODE. THIS DOCUMENT IS EXEMPT FROM RECORDING FEES UNDER SECTION 27383 OF THE CALIFORNIA GOVERNMENT CODE. SITE LEASE This SITE LEASE (this "Site Lease"), dated for convenience as of March 1, 2022, is between the CITY OF LODI, a general law city and municipal corporation duly organized and existing under the Constitution and laws of the State of California, as lessor (the "City"), and the LODI PUBLIC FINANCING AUTHORITY, a joint powers authority duly organized and existing under the laws of the State of California, as lessee (the "Authority"). BACKGROUND: 1. The Authority previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City. 2. In connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum. 3. In order to take advantage of prevailing bond market conditions, the City is proceeding to refund the 2012 Bonds. 4. The City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of certain capital improvements, including a new animal shelter and park and playground improvements and upgrades (the "Project"). 5. To that end, the City has proposed to lease the land and improvements constituting the City's police building and the City's Fire Station #2, as more particularly described in Appendix A attached hereto and by this reference incorporated herein (the "Leased Property"). to the Authority under this Site Lease, in consideration of the payment by the Authority of an upfront rental payment (the "Site Lease Payment") that is sufficient to provide funds for the refunding of the 2012 Bonds and the financing of the Project. 6. The Authority has authorized the issuance of its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) in the aggregate principal amount of $ (the "Bonds") under an Indenture of Trust dated as of March 1, 2022 (the "Indenture"), between the Authority and U.S. Bank Trust Company, National Association, as trustee (the "Trustee"), for the purpose of providing the funds to enable the Authority to pay the Site Lease Payment to the City in accordance with the Site Lease. 7. In order to provide revenues which are sufficient to enable the Authority to pay debt service on the Bonds, the Authority has agreed to lease the Leased Property back to the City under a Lease Agreement dated as of March 1, 2022 (the "Lease"), which has been recorded concurrently herewith, under which the City has agreed to pay semiannual Lease Payments as the rental for the Leased Property thereunder. 8. The lease payments made by the City under the Lease have been assigned by the Authority to the Trustee for the security of the Bonds under an Assignment Agreement dated as of March 1, 2022, between the Authority as assignor and the Trustee as assignee, which has been recorded concurrently herewith. AGREEMENT: In consideration of the above premises and of the mutual promises and covenants herein contained and for other valuable consideration, the parties hereto do hereby agree as follows: SECTION 1. Lease of Property to Authority. The City hereby leases the Leased Property to the Authority and the Authority hereby leases the Leased Property from the City, on the terms and conditions hereinafter set forth. SECTION 2. Term; Possession. The term of this Site Lease commences on the Closing Date and ends on the date on which the Indenture is discharged in accordance with Section 10.03 thereof, but under any circumstances not later than October 1, The provisions of this Section 2 are subject in all respects to any other provisions of this Site Lease relating to the termination hereof. SECTION 3. Rental. The Authority shall pay to the City as and for rental of the Leased Property hereunder, the sum of $ (the "Site Lease Payment"). The Site Lease Payment is due and payable upon the issuance of the Bonds and the execution and delivery hereof, and will be paid from the proceeds of the Bonds. The Authority and the City hereby find and determine that the total amount of the Site Lease Payment does not exceed the fair market value of the leasehold interest in the Leased Property which is conveyed hereunder by the City to the Authority. No other amount of rental is due and payable by the Authority for the use and occupancy of the Leased Property under this Site Lease. -2- As provided in the Indenture, a portion of the proceeds of the Bonds will be applied to make the Site Lease Payment by depositing an amount with the 2012 Trustee to be held, invested and administered in accordance with the Escrow Agreement for the purpose of refunding the 2012 Bonds, and another portion will be held by the Trustee to provide funds to finance the Project. SECTION 4. Leaseback to City. The Authority shall lease the Leased Property back to the City under the Lease. SECTION 5. Assignments and Subleases. Unless the City is in default under the Lease, the Authority may not assign its rights under this Site Lease or sublet all or any portion of the Leased Property, except as provided in the Assignment Agreement and in the Lease, without the prior written consent of the City. SECTION 6. Substitution or Release of Property. If the City exercises its option under Section 3.2 of the Lease to substitute property for the Leased Property in whole or in part, such substitution shall also operate to substitute property for the Leased Property which is leased hereunder. If the City exercises its option under Section 3.3 of the Lease to release a portion of the Leased Property from the Lease, such substitution shall also operate to release such portion of the Leased Property hereunder. The description of the Leased Property which is leased under the Lease shall conform at all times to the description of the Leased Property which is leased hereunder. SECTION 7. Right of Entry. The City reserves the right for any of its duly authorized representatives to enter upon the Leased Property, or any portion thereof, at any reasonable time to inspect the same or to make any repairs, improvements or changes necessary for the preservation thereof. SECTION 8. Termination. The Authority agrees, upon the termination of this Site Lease, to quit and surrender the Leased Property in the same good order and condition as the Leased Property was in at the time of commencement of the term hereof, reasonable wear and tear excepted, and agrees that all buildings, improvements and structures then existing upon the Leased Property shall remain thereon and title thereto shall vest thereupon in the City for no additional consideration. SECTION 9. Default. If the Authority defaults in the performance of any obligation on its part to be performed under the terms of this Site Lease, which default continues for 30 days following notice and demand for correction thereof to the Authority, the City may exercise any and all remedies granted by law, except that no merger of this Site Lease and of the Lease shall be deemed to occur as a result thereof and no such remedy may include termination hereof; provided, however, that so long as the Lease remains in effect, the Lease Payments payable by the City under the Lease shall continue to be paid to the Trustee. SECTION 10. Quiet Enjoyment. The Authority at all times during the term of this Site Lease shall peaceably and quietly have, hold and enjoy all of the Leased Property, subject to the provisions of the Lease and subject only to Permitted Encumbrances (as that term is defined in the Lease). SECTION 11. Waiver of Personal Liability. All liabilities under this Site Lease on the part of the Authority are solely corporate liabilities of the Authority as a public entity, -3- and the City hereby releases each and every member and officer of the Authority of and from any personal or individual liability under this Site Lease. No member or officer of the Authority or its governing board shall at any time or under any circumstances be individually or personally liable under this Site Lease for anything done or omitted to be done by the Authority hereunder. SECTION 12. Taxes. The City covenants and agrees to pay any and all assessments of any kind or character and also all taxes, including possessory interest taxes, levied or assessed upon the Leased Property and any improvements thereon. SECTION 13. Eminent Domain. If the whole or any part of the Leased Property or any improvements thereon is taken by eminent domain proceedings, the interest of the Authority shall be recognized and is hereby determined to be the amount of the then unpaid Lease Payments payable under the Lease and the balance of the award, if any, shall be paid to the City. SECTION 14. Partial Invalidity. If any one or more of the terms, provisions, covenants or conditions of this Site Lease shall to any extent be declared invalid, unenforceable, void or voidable for any reason whatsoever by a court of competent jurisdiction, the finding or order or decree of which becomes final, none of the remaining terms, provisions, covenants and conditions of this Site Lease shall be affected thereby, and each provision of this Site Lease shall be valid and enforceable to the fullest extent permitted by law. SECTION 15. Notices. Any notice, request, complaint, demand or other communication under this Site Lease shall be given by first class mail or personal delivery to the party entitled thereto at its address set forth below, or by telecopy, telex or other form of telecommunication, at its number set forth below. Notice shall be effective either (a) upon transmission by telecopy, telex or other form of telecommunication, (b) 48 hours after deposit in the United States mail, postage prepaid, or (c) in the case of personal delivery to any person, upon actual receipt. The City, the Authority and 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 City of Lodi or the City. 221 West Pine Street Lodi, CA 95240 Attention: City Manager Fax: (209) 333-6807 If to the Trustee: U.S. Bank Trust Company, National Association Attn.: Global Corporate Trust One California Street, Suite 1000 San Francisco, CA 94111 Fax: 415-677-3768 SECTION 16. Amendment of this Site Lease. The Authority and the City may at any time amend or modify any of the provisions of this Site Lease, but only (a) with the prior written consent of the Owners of a majority in aggregate principal amount of the Outstanding Bonds; or (b) without the consent of any of the Bond Owners, but only if such amendment or modification is for any one or more of the following purposes: -4- (i) to make cure any ambiguity, or to cure, correct or supplement any defective provision contained herein, or in any other respect whatsoever as the Authority and the City may deem necessary or desirable, provided that, in the opinion of Bond Counsel, such modifications or amendments do not materially adversely affect the interests of the Owners of the Bonds; (ii) to amend any provision hereof relating to the Tax 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 the Bonds under the Tax Code, in the opinion of Bond Counsel; (iii) to conform to any amendment of the Indenture which is made thereto in accordance with Section 9.01 of the Indenture; or (iv) for the purpose of effectuating any substitution or release of property under Section 6. SECTION 17. Governing Law. This Site Lease shall be construed in accordance with and governed by the Constitution and laws of the State of California. SECTION 18. Third Party Beneficiary. The Trustee is hereby made a third party beneficiary under this Site Lease with all rights of a third party beneficiary. SECTION 19. Binding Effect. This Site Lease inures to the benefit of and is binding upon the Authority, the City and their respective successors and assigns, subject, however, to the limitations contained herein. SECTION 20. Section Headings. All section headings contained herein are for convenience of reference only and are not intended to define or limit the scope of any provision of this Site Lease. SECTION 21. Execution in Counterparts. This Site Lease may be executed in any number of counterparts, each of which shall be deemed to be an original but all together shall constitute but one and the same lease. It is also agreed that separate counterparts of this Site Lease may be separately executed by the Authority and the City, all with the same force and effect as though the same counterpart had been executed by both the Authority and the City. SECTION 22. Defined Terms. All capitalized terms used herein and not otherwise defined have the respective meanings given those terms in the Indenture. -5- IN WITNESS WHEREOF, the City and the Authority have caused this Site Lease to be executed by their respective officers thereunto duly authorized, all as of the day and year first above written. Attest: Attest: [to come] City Clerk [to come] Secretary CITY OF LODI, as lessor Steve Schwabauer City Manager LODI PUBLIC FINANCING AUTHORITY, as lessee M If Steve Schwabauer Executive Director APPENDIX A DESCRIPTION OF THE LEASED PROPERTY The Leased Property consists of that certain real property situated in the City of Lodi, County of San Joaquin, State of California, which is more particularly described as follows: TRACT ONE: PARCEL ONE: THE SOUTH 120 FEET OF THE WEST 50 FEET OF LOT 8, IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI, FILED FOR RECORD AUGUST 25, 1869, IN VOL. 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL TWO: THE NORTH 50 FEET OF THE WEST 50 FEET OF LOT 8 AND THE EAST 30 FEET OF LOT 8, ALL IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI, FILED FOR RECORDED AUGUST 25, 1869, IN VOL 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL THREE: THE WEST 10 FEET OF LOT 7, IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI FILED FOR RECORD AUGUST 25, 1869, IN VOL 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL FOUR: COMMENCING AT THE SOUTH END OF THE LINE BETWEEN LOTS 6 AND 7, IN BLOCK 2 AND RUNNING IN A WESTERLY DIRECTION ALONG THE NORTH SIDE OF ELM STREET 70 FEET; THENCE NORTHERLY AND PARALLEL WITH THE BOUNDARY LINES OF SAID LOTS, 170 FEET; THENCE EASTERLY 70 FEET; THENCE IN A SOUTHERLY DIRECTION 170 FEET TO THE POINT OF BEGINNING, BEING THE EAST 70 FEET OF LOT 7 IN BLOCK NO. 2 IN THE TOWN OF LODI, (NOW CITY OF LODI) SAVE AND EXCEPT THEREFROM THE EAST 5 FEET THEREOF, HERETOFORE CONVEYED TO DAN W. BIRD, ALL ACCORDING TO THE OFFICIAL MAP OF THE FORMER TOWN OF MOKELUMNE, NOR ON FILE IN THE OFFICE OF THE COUNTY RECORDER, COUNTY OF SAN JOAQUIN, STATE OF CALIFORNIA. PARCEL FIVE: THE WEST 50 FEET OF LOT 6 AND THE EAST 5 FEET OF LOT 7 IN BLOCK 2 OF MOKELUMNE (NOT CITY OF LODI) ACCORDING TO THE OFFICIAL MAPS OR PLAT F-115 THEREOF FILED AUGUST 25, 1869 AT 8:48 A.M., IN BOOK OF MAPS AND PLATS, VOLUME 2, PAGE 12, OF SAN JOAQUIN COUNTY RECORDS. PARCEL SIX: THE WEST 20 FEET OF LOT 5 AND THE EAST 30 FEET OF LOT 6, IN BLOCK 2, CITY OF LODI, ACCORDING TO THE OFFICIAL MAP OR PLAT THEREOF, FILED FOR RECORD AUGUST 25, 1869, IN VOLUME 2 OF MAPS AND PLATS, PAGE 12 SAN JOAQUIN COUNTY RECORDS. A.P.N. 043-022-13 TRACT TWO: PARCEL ONE: LOT 2, IN BLOCK 1, AS SHOWN UPON MAP ENTITLED WEST LODI, FILED FOR RECORD SEPTEMBER 10, 1904, IN VOL. 3 OF MAPS AND PLATS, PAGE 25 SAN JOAQUIN COUNTY RECORDS. PARCEL ONE A: THE EASTERLY 0.60 FEET OF THE FOLLOWING DESCRIBED LAND: COMMENCING AT THE SOUTHEAST CORNER OF BLOCK 1 OF WEST LODI, AS SHOWN IN THE MAP FILED FOR RECORD IN BOOK OF MAPS AND PLATS. VOLUME 3 PAGE 25, SAN JOAQUIN COUNTY RECORDS; THENCE NORTH 86 17'30" WEST 119.90 FEET ALONG THE SOUTH LINE OF SAID BLOCK 1 TO THE SOUTHEAST CORNER OF LOT 3 OF SAID BLOCK 1, SAID SOUTHEAST CORNER ALSO BEING THE TRUE POINT OF BEGINNING; THENCE NORTH 86 17'30" WEST 119.90 FEET ALONG THE SOUTH LINE OF SAID BLOCK 1 TO THE SOUTHWEST CORNER OF LOT 4 OF SAID BLOCK 1; THENCE NORTH 3 42'40" EAST 169.83 FEET ALONG THE WEST LINE OF SAID LOT 4 TO THE NORTHWEST CORNER THEREOF; THENCE SOUTH 86 16'10" EAST 119.96 ALONG THE NORTH LINE OF SAID LOTS 4 AND 3 TO THE NORTHEAST CORNER OF SAID LOT 3; THENCE SOUTH 03 43'50" WEST 169.79 FEET ALONG THE EAST LINE OF SAID LOT 3 TO THE TRUE POINT OF BEGINNING. SAID PARCEL ONE AND ONE A ABOVE ARE DESCRIBED ON THAT CERTAIN CERTIFICATE OF LOT LINE ADJUSTMENT RECORDED JUNE 27, 2005 AS INSTRUMENT NO. 2005-154383, OF OFFICIAL RECORDS. PARCEL TWO: LOT 1 IN BLOCK 1 OF WEST LODI, ACCORDING TO THE OFFICIAL MAP FOR PLAT THEREOF FILED FOR RECORDED SEPTEMBER 10, 1904, AND RECORDED IN BOOK OF MAPS AND PLATS, VOL 3 PAGE 25, SAN JOAQUIN COUNTY RECORDS. TOGETHER WITH ALL THAT PORTION OF PLEASANT AVENUE FROM THE NORTH LINE OF ELM STREET TO THE SOUTH LINE OF THE 20 FOOT ALLEY BETWEEN ELM STREET AND LOCUST STREET AS SET FORTH AND DEPICTED IN RESOLUTION OF ABANDONMENT RECORDED OCTOBER 8, 2001, AS DOCUMENT NO. 01164151 SAN JOAQUIN PUBLIC RECORDS. UVA A.P.N. 037-270-50 I� C [add Fire Station #2] End of Legal Description P Jones Hall 2-23-22 Agenda TO BE RECORDED AND WHEN RECORDED RETURN TO: Jones Hall, A Professional Law Corporation 475 Sansome Street, Suite 1700 San Francisco, California 94111 Attention: Christopher K. Lynch, Esq. THIS TRANSACTION IS EXEMPT FROM CALIFORNIA DOCUMENTARY TRANSFER TAX UNDER SECTION 11922 OF THE CALIFORNIA REVENUE AND TAXATION CODE. THIS DOCUMENT IS EXEMPT FROM RECORDING FEES UNDER SECTION 27383 OF THE CALIFORNIA GOVERNMENT CODE. LEASE AGREEMENT Dated as of March 1, 2022 between the LODI PUBLIC FINANCING AUTHORITY, as lessor and the CITY OF LODI, as lessee Relating to Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) SECTION 4.1. SECTION 4.2. SECTION 4.3. SECTION 4.4. SECTION 4.5. SECTION 4.6. SECTION 4.7. SECTION 5.1. SECTION 5.2. SECTION 5.3. SECTION 5.4. SECTION 5.5. SECTION 5.6. SECTION 5.7. SECTION 5.8. SECTION 5.9. SECTION 5.10. SECTION 6.1. SECTION 6.2. SECTION 6.3. SECTION 6.3. SECTION 7.1. SECTION 7.2. SECTION 7.3. SECTION 7.4. SECTION 7.5. ARTICLE IV LEASE OF LEASED PROPERTY; TERM OF THIS LEASE; LEASE PAYMENTS Lease of Leased Property.............................................................. Term............................................................................................... LeasePayments............................................................................. Source of Payments; Covenant to Budget and Appropriate .......... Additional Rental Payments........................................................... QuietEnjoyment............................................................................. Title................................................................................................. ARTICLE V MAINTENANCE; TAXES; INSURANCE; AND OTHER MATTERS Maintenance, Utilities, Taxes and Assessments .................. Modification of Leased Property ........................................... Liability and Property Damage Insurance ............................ Casualty Insurance............................................................... Rental Interruption Insurance ............................................... Recordation Hereof; Title Insurance ..................................... Insurance Net Proceeds; Form of Policies ........................... Installation of City's Personal Property ................................. Liens..................................................................................... Advances................................................................................ ARTICLE VI DAMAGE, DESTRUCTION AND EMINENT DOMAIN; OF NET PROCEEDS Application of Net Proceeds ................................................. Termination or Abatement Due to Eminent Domain ............ Abatement Due to Damage or Destruction .......................... Abatement Due to Non -Completion of the Project ............... ARTICLE VII OTHER COVENANTS OF THE CITY Disclaimer of Warranties...................................................... Access to the Leased Property ............................................ Release and Indemnification Covenants .............................. Assignment and Subleasing by the City ............................... Amendment Hereof.............................................................. USE .3 .4 11 11 12 12 12 13 13 13 13 14 14 14 14 15 15 15 16 16 17 TABLE OF CONTENTS ARTICLE I DEFINITIONS; RULES OF INTERPRETATION SECTION1.1. Definitions....................................................................................... SECTION1.2. Interpretation.................................................................................. ARTICLE II COVENANTS, REPRESENTATIONS AND WARRANTIES SECTION 2.1. Covenants, Representations and Warranties of the City ............... SECTION 2.2. Covenants, Representations and Warranties of the Authority....... ARTICLE III DEPOSIT AND APPLICATION OF FUNDS; ACQUISITION AND CONSTRUCTION OF PROJECT; SUBSTITUTION AND RELEASE OF PROPERTY SECTION 3.1. Deposit of Moneys; Acquisition and Construction of Project.......... SECTION 3.2. Substitution of Property.................................................................. SECTION 3.3. Release of Property........................................................................ SECTION 4.1. SECTION 4.2. SECTION 4.3. SECTION 4.4. SECTION 4.5. SECTION 4.6. SECTION 4.7. SECTION 5.1. SECTION 5.2. SECTION 5.3. SECTION 5.4. SECTION 5.5. SECTION 5.6. SECTION 5.7. SECTION 5.8. SECTION 5.9. SECTION 5.10. SECTION 6.1. SECTION 6.2. SECTION 6.3. SECTION 6.3. SECTION 7.1. SECTION 7.2. SECTION 7.3. SECTION 7.4. SECTION 7.5. ARTICLE IV LEASE OF LEASED PROPERTY; TERM OF THIS LEASE; LEASE PAYMENTS Lease of Leased Property.............................................................. Term............................................................................................... LeasePayments............................................................................. Source of Payments; Covenant to Budget and Appropriate .......... Additional Rental Payments........................................................... QuietEnjoyment............................................................................. Title................................................................................................. ARTICLE V MAINTENANCE; TAXES; INSURANCE; AND OTHER MATTERS Maintenance, Utilities, Taxes and Assessments .................. Modification of Leased Property ........................................... Liability and Property Damage Insurance ............................ Casualty Insurance............................................................... Rental Interruption Insurance ............................................... Recordation Hereof; Title Insurance ..................................... Insurance Net Proceeds; Form of Policies ........................... Installation of City's Personal Property ................................. Liens..................................................................................... Advances................................................................................ ARTICLE VI DAMAGE, DESTRUCTION AND EMINENT DOMAIN; OF NET PROCEEDS Application of Net Proceeds ................................................. Termination or Abatement Due to Eminent Domain ............ Abatement Due to Damage or Destruction .......................... Abatement Due to Non -Completion of the Project ............... ARTICLE VII OTHER COVENANTS OF THE CITY Disclaimer of Warranties...................................................... Access to the Leased Property ............................................ Release and Indemnification Covenants .............................. Assignment and Subleasing by the City ............................... Amendment Hereof.............................................................. USE .3 .4 11 11 12 12 12 13 13 13 13 14 14 14 14 15 15 15 16 16 17 SECTION 7.6. Tax Covenants........................................................................................18 SECTION 7.7. Continuing Disclosure..............................................................................19 ARTICLE VIII EVENTS OF DEFAULT AND REMEDIES SECTION 8.1. Events of Default Defined........................................................................19 SECTION 8.2. Remedies on Default...............................................................................19 SECTION 8.3. No Remedy Exclusive.............................................................................21 SECTION 8.4. Agreement to Pay Attorneys' Fees and Expenses..................................21 SECTION 8.5. No Additional Waiver Implied by One Waiver.........................................22 SECTION 8.6. Application of Proceeds...........................................................................22 SECTION 8.7. Trustee and Bond Owners to Exercise Rights........................................22 ARTICLE IX PREPAYMENT OF LEASE PAYMENTS SECTION 9.1. Security Deposit......................................................................................22 SECTION 9.2. Optional Prepayment...............................................................................23 SECTION 9.3. Mandatory Prepayment From Net Proceeds of Insurance or Eminent Domain....................................................................................................23 SECTION 9.4. Credit for Amounts on Deposit................................................................23 ARTICLE X MISCELLANEOUS SECTION10.1. Notices.....................................................................................................23 SECTION 10.2. Binding Effect..........................................................................................24 SECTION 10.3. Severability..............................................................................................24 SECTION 10.4. Net -net -net Lease....................................................................................24 SECTION 10.5. Third Party Beneficiary............................................................................24 SECTION 10.6. Further Assurances and Corrective Instruments.....................................24 SECTION 10.7. Execution in Counterparts.......................................................................24 SECTION 10.8. Applicable Law........................................................................................24 SECTION 10.9. Authority and City Representatives.........................................................24 SECTION10.10 Captions...................................................................................................24 APPENDIX A DESCRIPTION OF THE LEASED PROPERTY APPENDIX B SCHEDULE OF LEASE PAYMENTS APPENDIX C DESCRIPTION OF PROJECT LEASE AGREEMENT This LEASE AGREEMENT (this "Lease"), dated for convenience as of March 1, 2022, Is between the LODI PUBLIC FINANCING AUTHORITY, a joint powers authority duly organized and existing under the laws of the State of California, as lessor (the "Authority"), and the CITY OF LODI, a general law city and municipal corporation duly organized and existing under the Constitution and laws of the State of California, as lessee (the "City"). BACKGROUND: 1. The Authority previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City. 2. In connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum. 3. In order to take advantage of prevailing bond market conditions, the City is proceeding to refund the 2012 Bonds. 4. The City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including a new animal shelter and park and playground improvements and upgrades (the "Project"). 5. To that end, the City has leased the land and improvements constituting the City's police building and the City's Fire Station #2, as more particularly described in Appendix A attached hereto and by this reference incorporated herein (the "Leased Property")to the Authority under a Site Lease dated as of March 1, 2022, which has been recorded concurrently herewith (the "Site Lease"), in consideration of the payment by the Authority of an upfront rental payment (the "Site Lease Payment") which is sufficient to provide funds for the refunding of the 2012 Bonds and the financing of the Project. 6. The Authority has authorized the issuance of its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) in the aggregate principal amount of $ (the "Bonds") under an Indenture of Trust dated as of March 1, 2022 (the "Indenture"), between the Authority and U.S. Bank Trust Company, National Association, as trustee (the "Trustee"), for the purpose of providing the funds to enable the Authority to pay the Site Lease Payment to the City in accordance with the Site Lease. 7. In order to provide revenues which are sufficient to enable the Authority to pay debt service on the Bonds, the Authority has agreed to lease the Leased Property back to the City under this Lease under which the City agrees to pay semiannual Lease Payments as the rental for the Leased Property. 8. The lease payments made by the City under this Lease have been assigned by the Authority to the Trustee for the security of the Bonds under an Assignment Agreement dated as of March 1, 2022, between the Authority as assignor and the Trustee as assignee, which has been recorded concurrently herewith. 9. The City and the Authority have found and determined that all acts and proceedings required by law necessary to make this Lease, when executed by the City and the Authority, the valid, binding and legal obligations of the City and the Authority, and to constitute this Lease 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 Lease have been in all respects duly authorized. AGREEMENT: In consideration of the material covenants contained in this Lease, the parties hereto hereby formally covenant, agree and bind themselves as follows: ARTICLE I DEFINITIONS; RULES OF INTERPRETATION SECTION 1.1. Definitions. Unless the context clearly otherwise requires or unless otherwise defined herein, the capitalized terms in this Lease have the respective meanings given them in the Indenture. SECTION 1.2. Interpretation. (a) Unless the context otherwise indicates, words expressed in the singular includes the plural and vice versa and the use of the neuter, masculine, or feminine gender is for convenience only and includes the neuter, masculine or feminine gender, as appropriate. (b) Headings of articles and sections herein and the table of contents hereof are solely for convenience of reference, do not constitute a part hereof and do not affect the meaning, construction or effect hereof. (c) All references herein to "Articles," "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of this Lease; the words "herein," "hereof," "hereby," "hereunder" and other words of similar import refer to this Lease as a whole and not to any particular Article, Section or subdivision hereof. -2- ARTICLE II COVENANTS, REPRESENTATIONS AND WARRANTIES SECTION 2.1. Covenants, Representations and Warranties of the City. The City makes the following covenants, representations and warranties to the Authority, the Trustee as of the date of the execution and delivery of this Lease: (a) Due Organization and Existence. The City is a general law city and municipal corporation duly organized and validly existing under the Constitution and laws of the State of California, has full legal right, power and authority under the laws of the State of California to enter into the Site Lease and this Lease and to carry out and consummate all transactions contemplated hereby, and by proper action the City has duly authorized the execution and delivery of the Site Lease and this Lease. (b) Due Execution. The representatives of the City executing the Site Lease and this Lease have been fully authorized to execute the same under a resolution duly adopted by the City Council of the City. (c) Valid, Binding and Enforceable Obligations. The Site Lease and this Lease have been duly authorized, executed and delivered by the City and constitute the legal, valid and binding obligations of the City enforceable against the City in accordance with their respective terms. (d) No Conflicts. The execution and delivery of the Site Lease and this Lease, the consummation of the transactions therein and herein contemplated and the fulfillment of or compliance with the terms and conditions thereof and hereof, do not and will not conflict with or constitute a violation or breach of or default (with due notice or the passage of time or both) under any applicable law or administrative rule or regulation, or any applicable court or administrative decree or order, or any indenture, mortgage, deed of trust, lease, contract or other agreement or instrument to which the City is a party or by which it or its properties are otherwise subject or bound, or result in the creation or imposition of any prohibited lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the City, which conflict, violation, breach, default, lien, charge or encumbrance would have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Site Lease and this Lease or the financial condition, assets, properties or operations of the City. (e) Consents and Approvals. No consent or approval of any trustee or holder of any indebtedness of the City or of the voters of the City, and no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority is necessary in connection with the execution and delivery of the Site Lease and this Lease, or the consummation of any transaction therein and herein -3- contemplated, except as have been obtained or made and as are in full force and effect. (f) No Litigation. There is no action, suit, proceeding, inquiry or investigation before or by any court or federal, state, municipal or other governmental authority pending or, to the knowledge of the City after reasonable investigation, threatened against or affecting the City or the assets, properties or operations of the City which, if determined adversely to the City or its interests, would have a material and adverse effect upon the consummation of the transactions contemplated by or the validity of the Site Lease and this Lease, or upon the financial condition, assets, properties or operations of the City, and the City is not in default with respect to any order or decree of any court or any order, regulation or demand of any federal, state, municipal or other governmental authority, which default might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Site Lease and this Lease or the financial conditions, assets, properties or operations of the City. SECTION 2.2. Covenants, Representations and Warranties of the Authority. The Authority makes the following covenants, representations and warranties to the City, the Trustee as of the date of the execution and delivery of this Lease: (a) Due Organization and Existence. The Authority is a joint exercise of powers authority duly organized and existing under a joint powers agreement and the laws of the State of California; has power to enter into this Lease, the Site Lease, the Assignment Agreement and the Indenture; is possessed of full power to own and hold, improve and equip real and personal property, and to lease the same; and has duly authorized the execution and delivery of each of the aforesaid agreements and such agreements constitute the legal, valid and binding obligations of the Authority, enforceable against the Authority in accordance with their respective terms. (b) Due Execution. The representatives of the Authority executing this Lease, the Site Lease, the Assignment Agreement and the Indenture are fully authorized to execute the same pursuant to official action taken by the governing body of the Authority. (c) Valid, Binding and Enforceable Obligations. This Lease, the Site Lease, the Assignment Agreement and the Indenture have been duly authorized, executed and delivered by the Authority and constitute the legal, valid and binding agreements of the Authority, enforceable against the Authority in accordance with their respective terms. (d) No Conflicts. The execution and delivery of this Lease, the Site Lease, the Assignment Agreement and the Indenture, the consummation of the transactions herein and therein contemplated and the fulfillment of or compliance with the terms and conditions hereof, do not and will not conflict with or constitute a violation or me breach of or default (with due notice or the passage of time or both) under any applicable law or administrative rule or regulation, or any applicable court or administrative decree or order, or any indenture, mortgage, deed of trust, lease, contract or other agreement or instrument to which the Authority is a party or by which it or its properties are otherwise subject or bound, or result in the creation or imposition of any prohibited lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the Authority, which conflict, violation, breach, default, lien, charge or encumbrance would have consequences that would materially and adversely affect the consummation of the transactions contemplated by this Lease, the Site Lease, the Assignment Agreement and the Indenture or the financial condition, assets, properties or operations of the Authority. (e) Consents and Approvals. No consent or approval of any trustee or holder of any indebtedness of the Authority, and no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority is necessary in connection with the execution and delivery of this Lease, the Site Lease, the Assignment Agreement or the Indenture, or the consummation of any transaction herein or therein contemplated, except as have been obtained or made and as are in full force and effect. (f) No Litigation. There is no action, suit, proceeding, inquiry or investigation before or by any court or federal, state, municipal or other governmental authority pending or, to the knowledge of the Authority after reasonable investigation, threatened against or affecting the Authority or the assets, properties or operations of the Authority which, if determined adversely to the Authority or its interests, would have a material and adverse effect upon the consummation of the transactions contemplated by or the validity of this Lease, the Site Lease, the Assignment Agreement or the Indenture, or upon the financial condition, assets, properties or operations of the Authority, and the Authority is not in default with respect to any order or decree of any court or any order, regulation or demand of any federal, state, municipal or other governmental authority, which default might have consequences that would materially and adversely affect the consummation of the transactions contemplated by this Lease, the Site Lease, the Assignment Agreement or the Indenture or the financial conditions, assets, properties or operations of the Authority. -5- ARTICLE III DEPOSIT AND APPLICATION OF FUNDS; ACQUISITION AND CONSTRUCTION OF PROJECT; SUBSTITUTION AND RELEASE OF PROPERTY SECTION 3.1. Deposit of Moneys; Acquisition and Construction of Project. (a) Deposit of Bond Proceeds. On the Closing Date, the Authority will cause the proceeds of sale of the Bonds to be deposited with the Trustee. The Trustee shall deposit such proceeds in accordance with Section 3.02 of the Indenture. (b) Acquisition and Construction of the Project. The Authority hereby appoints the City as its agent to carry out all phases of the acquisition and construction of the Project under and in accordance with the provisions hereof. The City hereby accepts its appointment as agent of the Authority and assumes all rights, liabilities, duties and responsibilities of the Authority regarding the acquisition and construction of the Project. The City, as agent of the Authority hereunder, shall enter into, administer and enforce all purchase orders or other contracts relating to the acquisition and construction of the Project. The City shall requisition the payment of Project Costs from amounts held by the Trustee in the Project Fund, pursuant to and in accordance with Section 3.04 of the Indenture. All contracts for, and all work relating to, the acquisition and construction of the Project are subject to all applicable provisions of law relating to the acquisition, construction, improvement, and equipping of like facilities and property by the City. As agent of the Authority, the City hereby agrees to supervise and provide for, or cause to be supervised and provided for, the acquisition and construction of the Project in accordance with the plans and specifications, purchase orders, construction contracts and other documents relating thereto and approved by the City under all applicable requirements of law. SECTION 3.2. Substitution of Property. The City has the option at any time and from time to time, to substitute other real property (the "Substitute Property") for the Leased Property or any portion thereof (the "Former Property"), upon satisfaction of all of the following requirements which are hereby declared to be conditions precedent to such substitution: (a) No Event of Default has occurred and is continuing. (b) The City has filed with the Authority and the Trustee, and caused to be recorded in the office of the San Joaquin County Recorder sufficient memorialization of, an amendment hereof which adds the legal description of the Substitute Property to Appendix A and deletes therefrom the legal description of the Former Property. (c) The City has obtained a CLTA policy of title insurance insuring the City's leasehold estate hereunder in the Substitute Property, subject only to Permitted Encumbrances, in an amount at least equal to the estimated value thereof. (d) The City has certified in writing to the Authority and the Trustee that the Substitute Property serves the municipal purposes of the City and constitutes property which the City is permitted to lease under the laws of the State of California, and has been determined to be essential to the proper, efficient and economic operation of the City and to serve an essential governmental function of the City. (e) The Substitute Property does not cause the City to violate any of its covenants, representations and warranties made herein. (g) The City has filed with the Authority and the Trustee a written certificate of the City or other written evidencing stating that the useful life of the Substitute Property at least extends to October 1, , that the estimated value of the Leased Property, after substitution of the Substitute Property and release of the Former Property, is at least equal to the aggregate Outstanding principal amount of the Bonds, and the fair rental value of the Leased Property, after substitution of the Substitute Property and release of the Former Property, is at least equal to the Lease Payments thereafter coming due and payable hereunder. (h) The City has mailed written notice of such substitution to each rating agency which then maintains a rating on the Bonds. Upon the satisfaction of all such conditions precedent, the Term of this Lease will thereupon end as to the Former Property and commence as to the Substitute Property, and all references to the Former Property will apply with full force and effect to the Substitute Property. The City is not entitled to any reduction, diminution, extension or other modification of the Lease Payments whatsoever as a result of any substitution of property under this Section. The Authority and the City will execute, deliver and cause to be recorded all documents required to discharge the Site Lease, this Lease and the Assignment Agreement of record against the Former Property and to cause the Substitute Property to become subject to all of the terms and conditions of the Site Lease, this Lease and the Assignment Agreement. SECTION 3.3. Release of Property. The City has the option at any time and from time to time to release any portion of the Leased Property from this Lease (the "Released Property") provided that the City has satisfied all of the following requirements which are hereby declared to be conditions precedent to such release: (a) No Event of Default has occurred and is continuing. (b) The City has filed with the Authority and the Trustee, and caused to be recorded in the office of the San Joaquin County Recorder sufficient memorialization of, an amendment hereof which removes the Released Property from the Site Lease and this Lease. (c) The City has certified in writing to the Authority and the Trustee that the value of the property which remains subject to this Lease following such release is at least equal to the aggregate Outstanding principal amount of the Bonds, and the fair rental value of the property 1115A which remains subject to this Lease following such release is at least equal to the Lease Payments thereafter coming due and payable hereunder. (d) The City has mailed written notice of such release to each rating agency which then maintains a rating on the Bonds. Upon the satisfaction of all such conditions precedent, the Term of this Lease will thereupon end as to the Released Property. The City is not entitled to any reduction, diminution, extension or other modification of the Lease Payments whatsoever as a result of such release. The Authority and the City shall execute, deliver and cause to be recorded all documents required to discharge the Site Lease, this Lease and the Assignment Agreement of record against the Released Property. ARTICLE IV LEASE OF LEASED PROPERTY; TERM OF THIS LEASE; LEASE PAYMENTS SECTION 4.1. Lease of Leased Property. The Authority hereby leases the Leased Property to the City and the City hereby leases the Leased Property from the Authority, upon the terms and conditions set forth in this Lease. SECTION 4.2. Term. The Term of this Lease commences on the Closing Date and ends on the date on which the Indenture is discharged in accordance with Section 10.03 thereof, but under any circumstances not later than October 1, . The provisions of this Section are subject to the provisions of Section 6.2 relating to the taking in eminent domain of the Leased Property in whole or in part. SECTION 4.3. Lease Payments. (a) Obligation to Pay. Subject to the provisions of Sections 6.2 and 6.3 and the provisions of Article IX, the City agrees to pay to the Authority, its successors and assigns, the Lease Payments in the respective amounts specified in Appendix B attached to this Lease, to be due and payable in immediately available funds on the Interest Payment Dates immediately following each of the respective Lease Payment Dates specified in Appendix B, and to be deposited by the City with the Trustee on each of the Lease Payment Dates specified in Appendix B. Any amount held in the Bond Fund, the Interest Account and the Principal Account on any Lease Payment Date (other than amounts resulting from the prepayment of the Lease Payments in part but not in whole under Article IX, and amounts required for payment of past due principal or interest on any Bonds not presented for payment) will be credited towards the Lease Payment then required to be paid hereunder. The City is not required to deposit any Lease Payment with the Trustee on any Lease Payment Date if the amounts then held in the Bond Fund, the Interest Account and the Principal Account are at least equal to the Lease Payment then required to be deposited with the Trustee. The Lease Payments payable in any Rental Period are for the use of the Leased Property during that Rental Period. (b) Effect of Prepayment. If the City prepays all Lease Payments in full under Sections 9.2 or 9.3, the City's obligations under this Section will thereupon cease and terminate. If the City prepays the Lease Payments in part but not in whole under Sections 9.2 or 9.3, the principal components of the remaining Lease Payments will be reduced in integral multiples of $5,000 among Lease Payment Dates on a basis which corresponds to the principal maturities of the Bonds which are redeemed thereby; and the interest component of each remaining Lease Payment will be reduced by the aggregate corresponding amount of interest which would otherwise be payable with respect to the Bonds thereby redeemed under Section 4.01 of the Indenture. (c) Rate on Overdue Payments. If the City fails to make any of the payments required in this Section, the payment in default will continue as an obligation of the City until the amount in default has been fully paid, and the City agrees to pay the same with interest thereon, from the date of default to the date of payment at the highest rate of interest on any Outstanding Bond. (d) Fair Rental Value. The aggregate amount of the Lease Payments and Additional Rental Payments coming due and payable during each Rental Period constitute the total rental for the Leased Property for such Rental Period, and are payable by the City in each Rental Period for and in consideration of the right of the use and occupancy of, and the continued quiet use and enjoyment of the Leased Property during each Rental Period. The parties hereto have agreed and determined that the total Lease Payments represent the fair rental value of the Leased Property. In making that determination, consideration has been given to the estimated value of the Leased Property, other obligations of the City and the Authority under this Lease, the uses and purposes which may be served by the Leased Property and the benefits therefrom which will accrue to the City and the general public. (e) Assignment. The City understands and agrees that all Lease Payments have been assigned by the Authority to the Trustee in trust, under the Assignment Agreement, for the benefit of the Owners of the Bonds, and the City hereby assents to such assignment. The Authority hereby directs the City, and the City hereby agrees to pay to the Trustee at its Office, all payments payable by the City under this Section and all amounts payable by the City under Article IX. SECTION 4.4. Source of Payments; Covenant to Budget and Appropriate. The Lease Payments are payable from any source of available funds of the City, subject to the provisions of Section 6.3. The City covenants to take all actions required to include the Lease Payments in each of its budgets during the Term of this Lease and to make the necessary appropriations for all Lease Payments and Additional Rental Payments. The foregoing covenant of the City contained constitutes a duty imposed by law and each and every public official of the City is required to take all actions required by law in the performance of the official duty of such officials to enable the City to carry out and perform the covenants and agreements in this Lease agreed to be carried out and performed by the City. SECTION 4.5. Additional Rental Payments. In addition to the Lease Payments, the City shall pay when due the following amounts of Additional Rental Payments in consideration of the lease of the Leased Property by the City from the Authority hereunder: M (a) all fees and expenses incurred by the Authority in connection with or by reason of its leasehold estate in the Leased Property, when due, (b) all reasonable compensation to the Trustee for all services rendered under the Indenture and for all reasonable expenses, charges, costs, liabilities, legal fees and other disbursements incurred in and about the performance of its powers and duties under the Indenture, (c) the reasonable fees and expenses of such accountants, consultants, attorneys and other experts as may be engaged by the Authority or the Trustee to prepare audits, financial statements, reports, opinions or provide such other services required under this Lease or the Indenture, (d) amounts coming due and payable as Excess Investment Earnings in accordance with Section 7.6(e), and (e) the reasonable out-of-pocket expenses of the Authority in connection with the execution and delivery of this Lease or the Indenture, or in connection with the issuance of the Bonds, including but not limited to any and all expenses incurred in connection with the authorization, sale and delivery of the Bonds, or incurred by the Authority in connection with any litigation which may at any time be instituted involving this Lease, the Bonds, the Indenture or any of the other documents contemplated hereby or thereby, or otherwise incurred in connection with the administration of this Lease. SECTION 4.6. Quiet Enjoyment. Throughout the Term of this Lease, the Authority shall provide the City with quiet use and enjoyment of the Leased Property and the City will peaceably and quietly have and hold and enjoy the Leased Property, without suit, trouble or hindrance from the Authority, except as expressly set forth in this Lease. The Authority will, at the request of the City and at the City's cost, join in any legal action in which the City asserts its right to such possession and enjoyment to the extent the Authority may lawfully do so. Notwithstanding the foregoing, the Authority has the right to inspect the Leased Property as provided in Section 7.2. SECTION 4.7. Title. Upon the termination of this Lease (other than under Section 8.2(b) hereof), all right, title and interest of the Authority in and to the Leased Property transfers to and vests in the City. The Authority shall take any and all steps and execute and record any and all documents reasonably required by the City to consummate any such transfer of title. -10- ARTICLE V MAINTENANCE; TAXES; INSURANCE; AND OTHER MATTERS SECTION 5.1. Maintenance, Utilities, Taxes and Assessments. Throughout the Term of this Lease, as part of the consideration for the rental of the Leased Property, all improvement, repair and maintenance of the Leased Property are the responsibility of the City, and the City will pay for or otherwise arrange for the payment of all utility services supplied to the Leased Property, which may include, without limitation, janitor service, security, power, gas, telephone, light, heating, water and all other utility services, and will pay for or otherwise arrange for the payment of the cost of the repair and replacement of the Leased Property resulting from ordinary wear and tear or want of care on the part of the City or any assignee or sublessee thereof. In exchange for the Lease Payments herein provided, the Authority agrees to provide only the Leased Property. The City waives the benefits of subsections 1 and 2 of Section 1932, Section 1933(4) and Sections 1941 and 1942 of the California Civil Code, but such waiver does not limit any of the rights of the City under the terms of this Lease. The City shall also pay or cause to be paid all taxes and assessments of any type or nature, if any, charged to the Authority or the City affecting the Leased Property or the respective interests or estates therein; provided that with respect to special assessments or other governmental charges that may lawfully be paid in installments over a period of years, the City shall pay only such installments as are required to be paid during the Term of this Lease as and when the same become due. The City may, at its expense and in its name, in good faith contest any such taxes, assessments, utility and other charges and, in the event of any such contest, may permit the taxes, assessments or other charges so contested to remain unpaid during the period of such contest and any appeal therefrom unless the Authority notifies the City that, in its reasonable opinion, by nonpayment of any such items the interest of the Authority in the Leased Property will be materially endangered or the Leased Property or any part thereof will be subject to loss or forfeiture, in which event the City shall promptly pay such taxes, assessments or charges or provide the Authority with full security against any loss which may result from nonpayment, in form satisfactory to the Authority and the Trustee. SECTION 5.2. Modification of Leased Property. The City has the right, at its own expense, to make additions, modifications and improvements to the Leased Property or any portion thereof. All additions, modifications and improvements to the Leased Property will thereafter comprise part of the Leased Property and become subject to the provisions of this Lease. Such additions, modifications and improvements may not in any way damage the Leased Property, or cause the Leased Property to be used for purposes other than those authorized under the provisions of state and federal law; and the Leased Property, upon completion of any additions, modifications and improvements made thereto under this Section, must be of a value which is not substantially less than the value thereof immediately prior to the making of such additions, modifications and improvements. The City will not permit any mechanic's or other lien to be established or remain against the Leased Property for labor or materials furnished in connection with any remodeling, additions, modifications, improvements, repairs, renewals or replacements made by the City under this Section; except that if any such lien is established and the City first notifies or causes to be notified the Authority of the City's intention to do so, the City may in good faith contest any lien filed or established against the Leased Property, SEE and in such event may permit the items so contested to remain undischarged and unsatisfied during the period of such contest and any appeal therefrom and shall provide the Authority with full security against any loss or forfeiture which might arise from the nonpayment of any such item, in form satisfactory to the Authority. The Authority will cooperate fully in any such contest, upon the request and at the expense of the City. SECTION 5.3. Liability and Property Damage Insurance. The City shall maintain or cause to be maintained throughout the Term of this Lease, but only if and to the extent available from reputable insurers at reasonable cost in the reasonable opinion of the City, a standard commercial general liability insurance policy or policies in protection of the Authority, the City, and their respective members, officers, agents, employees and assigns. Said policy or policies shall provide for indemnification of said parties against direct or contingent loss or liability for damages for bodily and personal injury, death or property damage occasioned by reason of the operation of the Leased Property. Such policy or policies shall provide coverage in such liability limits and be subject to such deductibles as the City deems adequate and prudent. Such insurance may be maintained as part of or in conjunction with any other insurance coverage carried by the City, and may be maintained in whole or in part in the form of self-insurance by the City, subject to the provisions of Section 5.7, or in the form of the participation by the City in a joint powers agency or other program providing pooled insurance. The proceeds of such liability insurance must be applied toward extinguishment or satisfaction of the liability with respect to which paid. SECTION 5.4. Casualty Insurance. The City shall procure and maintain, or cause to be procured and maintained, throughout the Term of this Lease, casualty insurance against loss or damage to all buildings situated on the Leased Property, in an amount at least equal to the lesser of (a) 100% of the replacement value of the insured buildings, or (b) 100% of the aggregate principal amount of the Outstanding Bonds. Such insurance must, as nearly as practicable, cover loss or damage by explosion, windstorm, riot, aircraft, vehicle damage, smoke and such other hazards as are normally covered by such insurance, and must include earthquake insurance if available at reasonable cost from reputable insurers in the judgment of the City. Such insurance may be subject to such deductibles as the City deems adequate and prudent. Such insurance may be maintained as part of or in conjunction with any other insurance coverage carried by the City, and may be maintained in whole or in part in the form of the participation by the City in a joint powers agency or other program providing pooled insurance; provided that such insurance may not be maintained by the City in the form of self-insurance. The Net Proceeds of such insurance must be applied as provided in Section 6.1. SECTION 5.5. Rental Interruption Insurance. The City shall procure and maintain, or cause to be procured and maintained, throughout the Term of this Lease, rental interruption or use and occupancy insurance to cover loss, total or partial, of the use of any portion of the Leased Property constituting buildings or other improvements as a result of any of the hazards covered in the insurance required by Section 5.4, in an amount at least equal to the maximum such Lease Payments coming due and payable during any consecutive two Fiscal Years. Such insurance may be maintained as part of or in conjunction with any other insurance coverage carried by the City, and may be maintained in whole or in part in the form of the participation by the City in a joint powers agency or other program providing pooled insurance; provided that such insurance may not be maintained by the City in the form of self-insurance. The Net Proceeds of such insurance, if any, must be paid to the Trustee and deposited in the Bond Fund, to be applied as a -12- credit towards the payment of the Lease Payments allocable to the insured improvements as the same become due and payable. SECTION 5.6. Recordation Hereof; Title Insurance. On or before the Closing Date the City shall, at its expense, (a) cause the Site Lease, the Assignment Agreement and this Lease, or a memorandum hereof or thereof in form and substance approved by Bond Counsel, to be recorded in the office of the San Joaquin County Recorder, and (b) obtain a CLTA title insurance policy insuring the City's leasehold estate hereunder in the Leased Property, subject only to Permitted Encumbrances, in an amount at least equal to the aggregate principal amount of the Bonds. All Net Proceeds received under any such title insurance policy must be deposited with the Trustee in the Bond Fund to be credited towards the prepayment of the remaining Lease Payments under Section 9.3. SECTION 5.7. Insurance Net Proceeds; Form of Policies. Each policy of insurance maintained under Sections 5.4, 5.5 and 5.6 must name the Trustee as loss payee so as to provide that all proceeds thereunder are payable to the Trustee. The City shall pay or cause to be paid when due the premiums for all insurance policies required by this Lease. All such policies shall provide that the Trustee is given 30 days' notice of each expiration, any intended cancellation thereof or reduction of the coverage provided thereby. The City must file with the Trustee annually, within 90 days following the close of each Fiscal Year, a certificate of the City stating that all policies of insurance required hereunder are then in full force and effect. The Trustee has no responsibility for the sufficiency, adequacy or amount of any insurance or self-insurance herein required and is fully protected in accepting payment on account of such insurance or any adjustment, compromise or settlement of any loss. If any insurance maintained under Section 5.3 is provided in the form of self- insurance, the City must file with the Trustee annually, within 90 days following the close of each Fiscal Year, a statement of the risk manager of the City or an independent insurance adviser engaged by the City identifying the extent of such self-insurance and stating the determination that the City maintains sufficient reserves with respect thereto. If any such insurance is provided in the form of self-insurance by the City, the City has no obligation to make any payment with respect to any insured event except from those reserves. SECTION 5.8. Installation of City's Personal Property. The City may at any time and from time to time, in its sole discretion and at its own expense, install or permit to be installed other items of equipment or other personal property in or upon the Leased Property. All such items shall remain the sole property of the City, in which neither the Authority nor the Trustee has any interest, and may be modified or removed by the City at any time, provided that the City must repair all damage to the Leased Property resulting from the installation, modification or removal of any such items. Nothing in this Lease prevents the City from purchasing or leasing items to be installed under this Section under a lease or conditional sale agreement, or subject to a vendor's lien or security agreement, as security for the unpaid portion of the purchase price thereof, so long as no such lien or security interest attaches to any part of the Leased Property. SECTION 5.9. Liens. The City may not, directly or indirectly, create, incur, assume or suffer to exist any mortgage, pledge, lien, charge, encumbrance or claim on or with respect to the Leased Property, other than as herein contemplated and except for such encumbrances as the City certifies in writing to the Trustee do not materially and adversely -13- affect the leasehold estate of the City in the Leased Property hereunder. If any such mortgage, pledge, lien, charge, encumbrance or claim does materially and adversely affect the leasehold estate of the City in the Leased Property hereunder, the City will promptly, at its own expense, take such action as may be necessary to duly discharge or remove any such mortgage, pledge, lien, charge, encumbrance or claim, for which it is responsible; provided that the City is not required to do so prior to the time when such mortgage, pledge, lien, charge, encumbrance or claim actually causes such material adverse effect. The City will reimburse the Authority for any expense incurred by it in order to discharge or remove any such mortgage, pledge, lien, charge, encumbrance or claim. SECTION 5.10. Advances. If the City fails to perform any of its obligations under this Article V, the Authority may (but is not required to) take such action as it deems necessary to cure such failure, including the advancement of money, and the City shall repay all such advances as Additional Rental Payments hereunder, with interest at the rate set forth in Section 4.3(c). ARTICLE VI DAMAGE, DESTRUCTION AND EMINENT DOMAIN; USE OF NET PROCEEDS SECTION 6.1. Application of Net Proceeds. The Trustee, as assignee of the Authority under the Assignment Agreement, has the right to receive all Net Proceeds. As provided in the Indenture, the Trustee will deposit all Net Proceeds in the Insurance and Condemnation Fund to be applied as set forth in Section 5.07 of the Indenture. SECTION 6.2. Termination or Abatement Due to Eminent Domain. If the Leased Property is taken permanently under the power of eminent domain or sold to a government threatening to exercise the power of eminent domain, the Term of this Lease thereupon ceases as of the day possession is taken. If less than all of the Leased Property is taken permanently, or if the Leased Property is taken temporarily, under the power of eminent domain, then: (a) this Lease shall continue in full force and effect with respect thereto and does not terminate by virtue of such taking, and the parties waive the benefit of any law to the contrary; and (b) the Lease Payments are subject to abatement in an amount determined by the City such that the resulting Lease Payments represent fair consideration for the use and occupancy of the remaining usable portions of the Leased Property. SECTION 6.3. Abatement Due to Damage or Destruction. The Lease Payments are subject to abatement during any period in which by reason of damage or destruction (other than by eminent domain which is hereinbefore provided for) there is substantial interference with the use and occupancy by the City of the Leased Property or any portion thereof. The Lease Payments are subject to abatement in an amount determined by the City such that the resulting Lease Payments represent fair consideration for the use and -14- occupancy of the remaining usable portions of the Leased Property not damaged or destroyed. Such abatement will continue for the period commencing with such damage or destruction and ending with the substantial completion of the work of repair or reconstruction. In the event of any such damage or destruction, this Lease continues in full force and effect and the City waives any right to terminate this Lease by virtue of any such damage and destruction. SECTION 6.4. Abatement Due to Non -Completion of the Project. The Lease Payments are subject to abatement during any period prior to the issuance of a certificate of occupancy for the Project, if it constitutes all or a portion of the Leased Property, there is substantial interference with the use and occupancy by the City of the Leased Property or any portion thereof. The Lease Payments are subject to abatement in an amount determined by the City such that the resulting Lease Payments represent fair consideration for the use and occupancy of the usable portions of the Leased Property. Such abatement will continue for the period commencing with the substantial interference with the use and occupancy of the Leased Property and ending with the substantial completion of the Project. In the event of any such interference with use and occupancy during construction of the Project, this Lease continues in full force and effect and the City waives any right to terminate this Lease by virtue of any substantial interference. Notwithstanding the foregoing, there shall be no abatement of Lease Payments under this Section 6.4 to the extent that any capitalized interest is available to pay Lease Payments which would otherwise be abated under this Section 6.4, it being hereby declared that such capitalized interest constitutes a special fund for the payment of the Lease Payments. ARTICLE VII OTHER COVENANTS OF THE CITY SECTION 7.1. Disclaimer of Warranties. THE AUTHORITY AND THE TRUSTEE MAKE NO AGREEMENT, WARRANTY OR REPRESENTATION, EITHER EXPRESS OR IMPLIED, AS TO THE VALUE, DESIGN, CONDITION, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OR FITNESS FOR THE USE CONTEMPLATED BY THE CITY OF THE LEASED PROPERTY OR ANY PORTION THEREOF, OR ANY OTHER REPRESENTATION OR WARRANTY WITH RESPECT TO THE LEASED PROPERTY OR ANY PORTION THEREOF. THE CITY ACKNOWLEDGES THAT THE AUTHORITY IS NOT A MANUFACTURER OF ANY PORTION OF THE LEASED PROPERTY OR A DEALER THEREIN, THAT THE CITY LEASES THE LEASED PROPERTY AS -IS, IT BEING AGREED THAT ALL OF THE AFOREMENTIONED RISKS ARE TO BE BORNE BY THE CITY. The Authority has no liability for incidental, indirect, special or consequential damages, in connection with or arising out of this Lease for the existence, furnishing, functioning or use of the Leased Property by the City. SECTION 7.2. Access to the Leased Property. The City agrees that the Authority and any Authorized Representative of the Authority, and the Authority's successors or assigns, have the right at all reasonable times to enter upon and to examine and inspect the Leased Property or any part thereof. The City further agrees that the Authority, any -15- Authority Representative and the Authority's successors or assigns may have such rights of access to the Leased Property or any component thereof as reasonably necessary to cause the proper maintenance of the Leased Property if the City fails to perform its obligations hereunder; provided, however, that neither the Authority nor any of its assigns has any obligation to cause such proper maintenance. SECTION 7.3. Release and Indemnification Covenants. The City agrees to indemnify the Authority, the Trustee and their respective officers, agents, successors and assigns, against all claims, losses and damages, including legal fees and expenses, arising out of any of the following: (a) the use, maintenance, condition or management of, or from any work or thing done on the Leased Property by the City, (b) any breach or default on the part of the City in the performance of any of its obligations under this Lease, (c) any negligence or willful misconduct of the City or of any of its agents, contractors, servants, employees or licensees with respect to the Leased Property, (d) any intentional misconduct or negligence of any sublessee of the City with respect to the Leased Property, (e) the acquisition, construction, improvement and equipping of the Leased Property, or the authorization of payment of the costs thereof, or (f) the acceptance and performance of the duties of the Trustee under the Indenture and under this Lease. No indemnification is made under this Section or elsewhere in this Lease for willful misconduct or negligence under this Lease by the Authority, the Trustee or their respective officers, agents, employees, successors or assigns. SECTION 7.4. Assignment and Subleasing by the City. The City may sublease the Leased Property, or any portion thereof, subject to all of the following conditions: (a) this Lease and the obligation of the City to make Lease Payments hereunder must remain obligations of the City; (b) the City must, within 30 days after the delivery thereof, furnish or cause to be furnished to the Authority and the Trustee a true and complete copy of such sublease; (c) no such sublease by the City may cause the Leased Property to be used for a purpose which is not authorized under the provisions of the laws of the State of California; and (d) the City must furnish to the Authority and the Trustee a written opinion of Bond Counsel stating that such sublease does not cause the -16- interest on the Bonds to become included in gross income for purposes of federal income taxation or to become subject to personal income taxation by the State of California. SECTION 7.5. Amendment Hereof. The Authority and the City may at any time amend or modify any of the provisions of this Lease, but only: (a) with the prior written consents of the Owners of a majority in aggregate principal amount of the Outstanding Bonds; or (b) without the consent of the Trustee or any of the Bond Owners, but only if such amendment or modification is for any one or more of the following purposes: (i) to add to the covenants and agreements of the City contained in this Lease, other covenants and agreements thereafter to be observed, or to limit or surrender any rights or power herein reserved to or conferred upon the City; (ii) to make such provisions for the purpose of curing any ambiguity, or of curing, correcting or supplementing any defective provision contained herein, to conform to the original intention of the City and the Authority; (iii) to modify, amend or supplement this Lease in such manner as to assure that the interest on the Bonds remains excluded from gross income under the Tax Code; (iv) to amend the description of the Leased Property to reflect accurately the property originally intended to be included therein, or in connection with any substitution or release of property under Sections 3.2 or 3.3; (v) to obligate the City to pay additional amounts of rental for the use and occupancy of the Leased Property, but only if (A) such additional amounts of rental are pledged or assigned for the payment of any bonds, notes, leases or other obligations the proceeds of which are applied to finance or refinance the acquisition or construction of any real or personal property for which the City is authorized to expend funds subject to its control, (B) the City has obtained and filed with the Trustee an appraisal showing that the appraised value of the Leased Property is at least equal to the aggregate principal amount of the Outstanding Bonds and all such other bonds, notes, leases or other obligations, and (C) the City has filed with the Trustee written evidence that the amendments made under this clause (v) will not of themselves cause a reduction or withdrawal of any rating then assigned to the Bonds; or (vi) in any other respect whatsoever as the Authority and the City deem necessary or desirable, if in the opinion of Bond Counsel such modifications or amendments do not materially adversely affect the interests of the Owners of the Bonds. No such modification or amendment may (a) extend or have the effect of extending any Lease Payment Date or reducing any Lease Payment or any premium payable upon -17- the prepayment thereof, without the express consent of the Owners of the affected Bonds, or (b) modify any of the rights or obligations of the Trustee without its written assent thereto. SECTION 7.6. Tax Covenants (a) Private Business Use Limitation. The City shall assure that the proceeds of the Bonds are not used in a manner which would cause the Bonds to satisfy the private business tests of Section 141(b) of the Tax Code or the private loan financing test of Section 141(c) of the Tax Code. (b) Federal Guarantee Prohibition. The City may not take any action or permit or suffer any action to be taken if the result of the same would be to cause the Bonds to be "federally guaranteed" within the meaning of Section 149(b) of the Tax Code. (c) No Arbitrage. The City may not take, or permit or suffer to be taken by the Trustee or otherwise, any action with respect to the proceeds of the Bonds or of any other obligations which, if such action had been reasonably expected to have been taken, or had been deliberately and intentionally taken, on the Closing Date, would have caused the Bonds to be "arbitrage bonds" within the meaning of Section 148(a) of the Tax Code. (d) Maintenance of Tax Exemption. The City shall take all actions necessary to assure the exclusion of interest on the Bonds from the gross income of the Owners of the Bonds to the same extent as such interest is permitted to be excluded from gross income under the Tax Code as in effect on the Closing Date. (e) Rebate of Excess Investment Earnings to United States. The City shall calculate or cause to be calculated the Excess Investment Earnings in all respects at the times and in the manner required under the Tax Code. The City shall pay the full amount of Excess Investment Earnings to the United States of America in such amounts, at such times and in such manner as may be required under the Tax Code. Such payments shall be made by the City from any source of legally available funds of the City, and shall constitute Additional Rental Payments hereunder. The City shall keep or cause to be kept, and retain or cause to be retained for a period of six years following the retirement of the Bonds, records of the determinations made under this subsection (e). In order to provide for the administration of this subsection (e), the City may provide for the employment of independent attorneys, accountants and consultants compensated on such reasonable basis as the City may deem appropriate. The Trustee has no duty or obligation to monitor or enforce compliance by the City of any of the requirements under this subsection (e). (f) Record Retention. The City will retain its records of all accounting and monitoring it carries out with respect to the Bonds for at least 3 years after the Bonds mature or are redeemed (whichever is earlier); however, if the Bonds are redeemed and refunded, the City will retain its records of accounting and monitoring at least 3 years after the earlier of the maturity or redemption of the obligations that refunded the Bonds. (g) Compliance with Tax Certificate. The City will comply with the provisions of the Certificate as to Arbitrage and the Use of Proceeds Certificate with respect to the aM Bonds, which are incorporated herein as if fully set forth herein. The covenants of this Section will survive payment in full or defeasance of the Bonds. SECTION 7.7. Continuing Disclosure. The City shall comply with and carry out all of the provisions of the Continuing Disclosure Certificate executed by the City as of the Closing Date, as originally executed and as it may be amended from time to time in accordance with its terms. Notwithstanding any other provision of this Lease, failure of the City to comply with such Continuing Disclosure Certificate will not constitute an Event of Default, although any Participating Underwriter (as that term is defined in such Continuing Disclosure Certificate) or any Owner or beneficial owner of the Bonds may take such actions as may be necessary and appropriate to compel performance by the City of its obligations under this Section, including seeking mandate or specific performance by court order. ARTICLE VIII EVENTS OF DEFAULT AND REMEDIES SECTION 8.1. Events of Default Defined. Any one or more of the following events constitute an Event of Default hereunder: (a) Failure by the City to pay any Lease Payment or other payment required to be paid hereunder at the time specified herein. (b) Failure by the City to observe and perform any covenant, condition or agreement on its part to be observed or performed, other than as referred to in the preceding subsection (a), for a period of 30 days after written notice specifying such failure and requesting that it be remedied has been given to the City by the Authority or the Trustee. If in the reasonable opinion of the City the failure stated in the notice can be corrected, but not within such 30 -day period, the failure will not constitute an Event of Default if the City commences to cure the failure within such 30 -day period and thereafter diligently and in good faith cures the failure in a reasonable period of time. (c) The filing by the City of a voluntary petition in bankruptcy, or failure by the City promptly to lift any execution, garnishment or attachment, or adjudication of the City as a bankrupt, or assignment by the City for the benefit of creditors, or the entry by the City into an agreement of composition with creditors, or the approval by a court of competent jurisdiction of a petition applicable to the City in any proceedings instituted under the provisions of the Federal Bankruptcy Code, as amended, or under any similar acts which may hereafter be enacted. SECTION 8.2. Remedies on Default. Whenever any Event of Default has happened and is continuing, the Authority may exercise any and all remedies available under law or granted under this Lease. Notwithstanding anything herein or in the Indenture to the contrary, neither the Authority nor the Trustee may accelerate the Lease Payments or otherwise declare any Lease Payments not then in default to be immediately due and -19- payable. Each covenant hereof to be kept and performed by the City is expressly made a condition and upon the breach thereof the Authority may exercise any and all rights granted hereunder; except that no termination of this Lease may be effected either by operation of law or acts of the parties hereto, except only in the manner herein expressly provided. Upon the occurrence and during the continuance of any Event of Default, the Authority may exercise each and every one of the following remedies, subject in all respects to the limitations set forth in Section 8.3. (a) Enforcement of Payments Without Termination. If the Authority does not elect to terminate this Lease in the manner hereinafter provided for in subparagraph (b) hereof, the City agrees to and shall remain liable for the payment of all Lease Payments and the performance of all conditions herein contained and shall reimburse the Authority for any deficiency arising out of the re-leasing of the Leased Property, or, if the Authority is unable to re -lease the Leased Property, then for the full amount of all Lease Payments to the end of the Term of this Lease, but said Lease Payments and/or deficiency shall be payable only at the same time and in the same manner as hereinabove provided for the payment of Lease Payments hereunder, notwithstanding such entry or re-entry by the Authority or any suit in unlawful detainer, or otherwise, brought by the Authority for the purpose of effecting such re-entry or obtaining possession of the Leased Property or the exercise of any other remedy by the Authority. The City hereby irrevocably appoints the Authority as the agent and attorney-in-fact of the City to enter upon and re -lease the Leased Property upon the occurrence and continuation of an Event of Default and to remove all personal property whatsoever situated upon the Leased Property, to place the Leased Property in storage or other suitable place in the County of San Joaquin for the account of and at the expense of the City, and the City hereby exempts and agrees to save harmless the Authority from any costs, loss or damage whatsoever arising or occasioned by any such entry upon and re- leasing of the Leased Property and the removal and storage of the Leased Property by the Authority or its duly authorized agents in accordance with the provisions herein contained. The City agrees that the terms of this Lease constitute full and sufficient notice of the right of the Authority to re -lease the Leased Property in the event of such re-entry without effecting a surrender of this Lease, and further agrees that no acts of the Authority in effecting such re-leasing shall constitute a surrender or termination of this Lease irrespective of the term for which such re-leasing is made or the terms and conditions of such re-leasing, or otherwise, but that, on the contrary, in the event of such default by the City the right to terminate this Lease shall vest in the Authority to be effected in the sole and exclusive manner hereinafter provided for in subparagraph (b) hereof. The City agrees to surrender and quit possession of the Leased Property upon demand of the Authority for the purpose of enabling the Leased Property to be re -let under this paragraph, and the City further waives the right to any rental obtained by the Authority in excess of the Lease Payments and hereby conveys and releases such excess to the -20- Authority as compensation to the Authority for its services in re- leasing the Leased Property. (b) Termination of Lease. If an Event of Default occurs and is continuing hereunder, the Authority at its option may terminate this Lease and re -lease all or any portion of the Leased Property. If the Authority terminates this Lease at its option and in the manner hereinafter provided on account of default by the City (and notwithstanding any re-entry upon the Leased Property by the Authority in any manner whatsoever or the re-leasing of the Leased Property), the City nevertheless agrees to pay to the Authority all costs, loss or damages howsoever arising or occurring payable at the same time and in the same manner as is herein provided in the case of payment of Lease Payments and Additional Rental Payments. Any surplus received by the Authority from such re-leasing shall be deposited in the Bond Fund. Neither notice to pay rent or to deliver up possession of the premises given under law nor any proceeding in unlawful detainer taken by the Authority shall of itself operate to terminate this Lease, and no termination of this Lease on account of default by the City shall be or become effective by operation of law, or otherwise, unless and until the Authority shall have given written notice to the City of the election on the part of the Authority to terminate this Lease. The City covenants and agrees that no surrender of the Leased Property, or of the remainder of the Term hereof or any termination of this Lease shall be valid in any manner or for any purpose whatsoever unless stated or accepted by the Authority by such written notice. (c) Proceedings at Law or In Equity. If an Event of Default occurs and continues hereunder, the Authority may take whatever action at law or in equity may appear necessary or desirable to collect the amounts then due and thereafter to become due hereunder or to enforce any other of its rights hereunder. SECTION 8.3. No Remedy Exclusive. No remedy herein conferred upon or reserved to the Authority is intended to be exclusive and every such remedy is cumulative and in addition to every other remedy given under this Lease or now or hereafter existing at law or in equity. No delay or omission to exercise any right or power accruing upon the occurrence of any Event of Default impairs any such right or power or operates as a waiver thereof, but any such right and power may be exercised from time to time and as often as may be deemed expedient. In order to entitle the Authority to exercise any remedy reserved to it in this Article VIII it is not necessary to give any notice, other than as expressly required in this Article VIII or by law. SECTION 8.4. Agreement to Pay Attorneys' Fees and Expenses. If the Authority or the City defaults under any of the provisions of this Lease and the nondefaulting party employs attorneys or incurs other expenses for the collection of moneys or the enforcement or performance or observance of any obligation or agreement on the part of the defaulting party herein contained, the defaulting party will on demand therefor pay to the nondefaulting party the reasonable fees of such attorneys and such other expenses so incurred by the nondefaulting party; provided, however, that the Trustee shall not be required to expend its own funds for any payment described in this Section. -21- SECTION 8.5. No Additional Waiver Implied by One Waiver. If the Authority or the City breaches any agreement in this Lease and thereafter the other party waives the breach, such waiver is limited to the particular breach so waived and does not operate to waive any other breach hereunder. SECTION 8.6. Application of Proceeds. All net proceeds received from the re -lease of the Leased Property under this Article VIII, and all other amounts derived by the Authority or the Trustee as a result of the occurrence of an Event of Default, must be paid to and applied by the Trustee in accordance with Section 7.03 of the Indenture. SECTION 8.7. Trustee and Bond Owners to Exercise Rights. Such rights and remedies as are given to the Authority under this Article VIII have been assigned by the Authority to the Trustee under the Assignment Agreement for the benefit of the Bond Owners, to which assignment the City hereby consents. The Trustee and the Bond Owners shall exercise such rights and remedies in accordance with the Indenture. ARTICLE IX PREPAYMENT OF LEASE PAYMENTS SECTION 9.1. Security Deposit. Notwithstanding any other provision of this Lease, the City may on any date secure the payment of the Lease Payments allocable to the Leased Property in whole or in part by depositing with the Trustee an amount of cash which, together with other available amounts on deposit in the funds and accounts established under the Indenture, is either: (a) sufficient to pay such Lease Payments, including the principal and interest components thereof, in accordance with the Lease Payment schedule set forth in Appendix B, or (b) invested in whole or in part in non -callable Federal Securities in such amount as will, in the opinion of an independent certified public accountant, (which opinion must be addressed and delivered to the Trustee), together with interest to accrue thereon and together with any cash which is so deposited, be fully sufficient to pay such Lease Payments when due under Section 4.3(a), as the City instructs at the time of said deposit. If the City makes a security deposit under this Section with respect to all unpaid Lease Payments, and notwithstanding the provisions of Section 4.2, (a) the Term of this Lease will continue, (b) all obligations of the City under this Lease, and all security provided by this Lease for said Lease Payments, will thereupon cease and terminate, excepting only the obligation of the City to make, or cause to be made all of said Lease Payments from such security deposit, and (c) under Section 4.7, title to the Leased Property will vest in the City on the date of said deposit automatically and without further action by the City or the Authority. Said security deposit constitutes a special fund for the payment of Lease Payments in accordance with the provisions of this Lease. 902 SECTION 9.2. Optional Prepayment. The City has the option to prepay the principal components of the Lease Payments in whole, or in part in any integral multiple of $5,000, from any source of legally available funds, on any date on or after April 1, , at a prepayment price equal to the aggregate principal components of the Lease Payments to be prepaid, together with the interest component of the Lease Payment required to be paid on such Interest Payment Date, and together with a prepayment premium equal to the premium (if any) required to be paid on the resulting redemption of Bonds under Section 4.01(a) of the Indenture. Such prepayment price shall be deposited by the Trustee in the Redemption Fund to be applied to the redemption of Bonds under Section 4.01(a) of the Indenture. The City shall give written notice to the Trustee of its intention to prepay the Lease Payments under this Section in sufficient time to enable the Trustee to give notice of the corresponding redemption of Bonds in accordance with Section 4.03 of the Indenture. . SECTION 9.3. Mandatory Prepayment From Net Proceeds of Insurance or Eminent Domain. The City shall prepay the principal components of the Lease Payments allocable to the Leased Property in whole or in part on any date, from and to the extent of any Net Proceeds of insurance award or eminent domain award with respect to the Leased Property theretofore deposited in the Redemption Fund for that purpose under Article VI hereof and Section 5.07 of the Indenture. Such Net Proceeds, to the extent remaining after payment of any delinquent Lease Payments, will be credited towards the City's obligations under this Section and applied to the corresponding redemption of Bonds under Section 4.01(b) of the Indenture. SECTION 9.4. Credit for Amounts on Deposit. If the principal components of the Lease Payments are prepaid in full under this Article IX, such that the Indenture is discharged by its terms as a result of such prepayment, at the written election of the City filed with the Trustee any or all amounts then on deposit in the Bond Fund (and the accounts therein) will be credited towards the amounts then required to be so prepaid. ARTICLE X MISCELLANEOUS SECTION 10.1. Notices. Any notice, request, complaint, demand or other communication under this Lease shall be given by first class mail or personal delivery to the party entitled thereto at its address set forth below, or by facsimile transmission or other form of telecommunication, at its number set forth below. Notice shall be effective either (a) upon transmission by facsimile transmission or other form of telecommunication, (b) 48 hours after deposit in the United States of America first class mail, postage prepaid, or (c) in the case of personal delivery to any person, upon actual receipt. The Authority, the City 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 City of Lodi or the City. 221 West Pine Street Lodi, CA 95240 Attention: City Manager Fax: (209) 333-6807 -23- If to the Trustee: U.S. Bank Trust Company, National Association Attn.: Global Corporate Trust One California Street, Suite 1000 San Francisco, CA 94111 Fax: 415-677-3768 SECTION 10.2. Binding Effect. This Lease inures to the benefit of and binds the Authority, the City and their respective successors and assigns. SECTION 10.3. Severability. If any provision of this Lease is held invalid or unenforceable by any court of competent jurisdiction, such holding will not invalidate or render unenforceable any other provision hereof. SECTION 10.4. Net -net -net Lease. This Lease is deemed and construed to be a "net -net -net lease" and the City hereby agrees that the Lease Payments are an absolute net return to the Authority, free and clear of any expenses, charges or set -offs whatsoever. SECTION 10.5. Third Party Beneficiary. The Trustee is hereby made a third party beneficiary hereunder with all rights of a third party beneficiary. SECTION 10.6. Further Assurances and Corrective Instruments. The Authority and the City shall, from time to time, execute, acknowledge and deliver, or cause to be executed, acknowledged and delivered, such supplements hereto and such further instruments as may reasonably be required for correcting any inadequate or incorrect description of the Leased Property hereby leased or intended so to be or for carrying out the expressed intention of this Lease. SECTION 10.7. Execution in Counterparts. This Lease may be executed in several counterparts, each of which is an original and all of which constitute but one and the same instrument. SECTION 10.8. Applicable Law. This Lease is governed by and construed in accordance with the laws of the State of California. SECTION 10.9. Authority and City Representatives. Whenever under the provisions of this Lease the approval of the Authority or the City is required, or the Authority or the City is required to take some action at the request of the other, such approval or such request shall be given for the Authority and for the City by an Authorized Representative thereof, and any party hereto may conclusively rely upon any such approval or request. SECTION 10.10. Captions. The captions or headings in this Lease are for convenience only and in no way define, limit or describe the scope or intent of any provisions or Section of this Lease. -24- IN WITNESS WHEREOF, the Authority and the City have caused this Lease to be executed in their respective names by their duly authorized officers, all as of the date first above written. Attest: Attest: [to come] Secretary [to come] City Clerk LODI PUBLIC FINANCING AUTHORITY, as lessor M Steve Schwabauer Executive Director CITY OF LODI, as lessee By -25- Steve Schwabauer City Manager APPENDIX A DESCRIPTION OF THE LEASED PROPERTY The Leased Property consists of that certain real property situated in the City of Lodi, County of San Joaquin, which is more particularly described as follows: TRACT ONE: PARCEL ONE: THE SOUTH 120 FEET OF THE WEST 50 FEET OF LOT 8, IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI, FILED FOR RECORD AUGUST 25, 1869, IN VOL. 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL TWO: THE NORTH 50 FEET OF THE WEST 50 FEET OF LOT 8 AND THE EAST 30 FEET OF LOT 8, ALL IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI, FILED FOR RECORDED AUGUST 25, 1869, IN VOL 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL THREE: THE WEST 10 FEET OF LOT 7, IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI FILED FOR RECORD AUGUST 25, 1869, IN VOL 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL FOUR: COMMENCING AT THE SOUTH END OF THE LINE BETWEEN LOTS 6 AND 7, IN BLOCK 2 AND RUNNING IN A WESTERLY DIRECTION ALONG THE NORTH SIDE OF ELM STREET 70 FEET; THENCE NORTHERLY AND PARALLEL WITH THE BOUNDARY LINES OF SAID LOTS, 170 FEET; THENCE EASTERLY 70 FEET; THENCE IN A SOUTHERLY DIRECTION 170 FEET TO THE POINT OF BEGINNING, BEING THE EAST 70 FEET OF LOT 7 IN BLOCK NO. 2 IN THE TOWN OF LODI, (NOW CITY OF LODI) SAVE AND EXCEPT THEREFROM THE EAST 5 FEET THEREOF, HERETOFORE CONVEYED TO DAN W. BIRD, ALL ACCORDING TO THE OFFICIAL MAP OF THE FORMER TOWN OF MOKELUMNE, NOR ON FILE IN THE OFFICE OF THE COUNTY RECORDER, COUNTY OF SAN JOAQUIN, STATE OF CALIFORNIA. PARCEL FIVE: THE WEST 50 FEET OF LOT 6 AND THE EAST 5 FEET OF LOT 7 IN BLOCK 2 OF MOKELUMNE (NOT CITY OF LODI) ACCORDING TO THE OFFICIAL MAPS OR PLAT F-115 THEREOF FILED AUGUST 25, 1869 AT 8:48 A.M., IN BOOK OF MAPS AND PLATS, VOLUME 2, PAGE 12, OF SAN JOAQUIN COUNTY RECORDS. PARCEL SIX: THE WEST 20 FEET OF LOT 5 AND THE EAST 30 FEET OF LOT 6, IN BLOCK 2, CITY OF LODI, ACCORDING TO THE OFFICIAL MAP OR PLAT THEREOF, FILED FOR RECORD AUGUST 25, 1869, IN VOLUME 2 OF MAPS AND PLATS, PAGE 12 SAN JOAQUIN COUNTY RECORDS. A.P.N. 043-022-13 TRACT TWO: PARCEL ONE: LOT 2, IN BLOCK 1, AS SHOWN UPON MAP ENTITLED WEST LODI, FILED FOR RECORD SEPTEMBER 10, 1904, IN VOL. 3 OF MAPS AND PLATS, PAGE 25 SAN JOAQUIN COUNTY RECORDS. PARCEL ONE A: THE EASTERLY 0.60 FEET OF THE FOLLOWING DESCRIBED LAND: COMMENCING AT THE SOUTHEAST CORNER OF BLOCK 1 OF WEST LODI, AS SHOWN IN THE MAP FILED FOR RECORD IN BOOK OF MAPS AND PLATS. VOLUME 3 PAGE 25, SAN JOAQUIN COUNTY RECORDS; THENCE NORTH 86 17'30" WEST 119.90 FEET ALONG THE SOUTH LINE OF SAID BLOCK 1 TO THE SOUTHEAST CORNER OF LOT 3 OF SAID BLOCK 1, SAID SOUTHEAST CORNER ALSO BEING THE TRUE POINT OF BEGINNING; THENCE NORTH 86 17'30" WEST 119.90 FEET ALONG THE SOUTH LINE OF SAID BLOCK 1 TO THE SOUTHWEST CORNER OF LOT 4 OF SAID BLOCK 1; THENCE NORTH 3 42'40" EAST 169.83 FEET ALONG THE WEST LINE OF SAID LOT 4 TO THE NORTHWEST CORNER THEREOF; THENCE SOUTH 86 16'10" EAST 119.96 ALONG THE NORTH LINE OF SAID LOTS 4 AND 3 TO THE NORTHEAST CORNER OF SAID LOT 3; THENCE SOUTH 03 43'50" WEST 169.79 FEET ALONG THE EAST LINE OF SAID LOT 3 TO THE TRUE POINT OF BEGINNING. SAID PARCEL ONE AND ONE A ABOVE ARE DESCRIBED ON THAT CERTAIN CERTIFICATE OF LOT LINE ADJUSTMENT RECORDED JUNE 27, 2005 AS INSTRUMENT NO. 2005-154383, OF OFFICIAL RECORDS. PARCEL TWO: LOT 1 IN BLOCK 1 OF WEST LODI, ACCORDING TO THE OFFICIAL MAP FOR PLAT THEREOF FILED FOR RECORDED SEPTEMBER 10, 1904, AND RECORDED IN BOOK OF MAPS AND PLATS, VOL 3 PAGE 25, SAN JOAQUIN COUNTY RECORDS. TOGETHER WITH ALL THAT PORTION OF PLEASANT AVENUE FROM THE NORTH LINE OF ELM STREET TO THE SOUTH LINE OF THE 20 FOOT ALLEY BETWEEN ELM STREET AND LOCUST STREET AS SET FORTH AND DEPICTED IN RESOLUTION OF ABANDONMENT RECORDED OCTOBER 8, 2001, AS DOCUMENT NO. 01164151 SAN JOAQUIN PUBLIC RECORDS. UVA A.P.N. 037-270-50 [add Fire Station #2] End of Legal Description I� C APPENDIX B SCHEDULE OF LEASE PAYMENTS Lease Principal Interest Aggregate Payment Date* Component Component Lease Payment * Lease Payment Dates are the Business Day immediately preceding each date listed in the schedule B-1 APPENDIX C DESCRIPTION OF PROJECT The Project consists of the acquisition and construction of an Animal Shelter to be owned and operated by the City, park and playground upgrades and improvements, and such other improvements identified by the City from time to time. C-1 Jones Hall 2-23-22 Agenda TO BE RECORDED AND WHEN RECORDED RETURN TO: Jones Hall, A Professional Law Corporation 475 Sansome Street, Suite 1700 San Francisco, California 94111 Attention: Christopher K. Lynch, Esq. THIS DOCUMENT IS EXEMPT FROM RECORDING FEES UNDER SECTION 27383 OF THE CALIFORNIA GOVERNMENT CODE. ASSIGNMENT AGREEMENT This ASSIGNMENT AGREEMENT (this "Agreement"), dated for convenience as of March 1, 2022, is between the LODI PUBLIC FINANCING AUTHORITY, a joint powers authority duly organized and existing under the laws of the State of California (the "Authority"), and U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, a national banking association organized and existing under the laws of the United States of America, as trustee (the "Trustee"). BACKGROUND: 1. The Authority previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City. 2. In connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum. 3. In order to take advantage of prevailing bond market conditions, the City is proceeding to refund the 2012 Bonds. 4. The City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including, among other things, a new animal shelter and park and playground improvements and upgrades (the "Project"). 5. To that end, the City has leased the land and improvements constituting the City's police building and the City's Fire Station #2, as more particularly described in Appendix A attached hereto and by this reference incorporated herein (the "Leased Property"), to the Authority under a Site Lease dated as of March 1, 2022, which has been recorded concurrently herewith (the "Site Lease"), in consideration of the payment by the Authority of an upfront rental payment (the "Site Lease Payment") that is sufficient to provide funds for the refunding of the 2012 Bonds and the financing of the Project. 6. The Authority has authorized the issuance of its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) in the aggregate principal amount of $ (the "Bonds") under an Indenture of Trust dated as of March 1, 2022 (the "Indenture"), between the Authority and U.S. Bank Trust Company, National Association, as trustee (the "Trustee"), for the purpose of providing the funds to enable the Authority to pay the Site Lease Payment to the City in accordance with the Site Lease. 7. In order to provide revenues which are sufficient to enable the Authority to pay debt service on the Bonds, the Authority has agreed to lease the Leased Property back to the City under the Lease Agreement dated as of March 1, 2022 which has been recorded concurrently herewith (the "Lease") under which the City has agreed to pay semiannual Lease Payments as the rental for the Leased Property. 8. The Authority has requested the Trustee to enter into this Agreement for the purpose of assigning certain of its rights under the Lease to the Trustee for the benefit of the Bond owners. AGREEMENT: In consideration of the material covenants contained in this Agreement, the parties hereto hereby formally covenant, agree and bind themselves as follows: SECTION 1. Defined Terms. All capitalized terms not otherwise defined herein have the respective meanings given those terms in the Indenture. SECTION 2. Assignment. The Authority hereby assigns to the Trustee, for the benefit of the Owners of all Bonds which are issued and Outstanding under the Indenture, all of the Authority's rights under the Lease (excepting only the Authority's rights under Sections 4.5, 5.10, 7.3 and 8.4 of the Lease), including but not limited to: (a) the right to receive and collect all of the Lease Payments from the City under the Lease; (b) the right to receive and collect any proceeds of any insurance maintained thereunder with respect to the Leased Property, or any eminent domain award (or proceeds of sale under threat of eminent domain) paid with respect to the Leased Property; and (c) the right to exercise such rights and remedies conferred on the Authority under the Lease as may be necessary or convenient (i) to -2- enforce payment of the Lease Payments and any amounts required to be deposited in the Insurance and Condemnation Fund established under Section 5.07 of the Indenture, or (ii) otherwise to protect the interests of the Bond Owners in the event of a default by the City under the Lease. The Trustee shall administer all of the rights assigned to it by the Authority under this Agreement in accordance with the provisions of the Indenture, for the benefit of the Owners of Bonds. The assignment made under this Section 2 is absolute and irrevocable, and without recourse to the Authority. SECTION 3. Acceptance. The Trustee hereby accepts the assignments made herein for the purpose of securing the payments due under the Lease and Indenture to, and the rights under the Lease and Indenture of, the Owners of the Bonds, all subject to the provisions of the Indenture. The recitals contained herein are those of the Authority and not of the Trustee, and the Trustee assumes no responsibility for the correctness thereof. SECTION 4. Conditions. This Agreement confers no rights and imposes no duties upon the Trustee beyond those expressly provided in the Indenture. The assignment hereunder to the Trustee is solely in its capacity as Trustee under the Indenture. SECTION 5. Execution in Counterparts. This Agreement may be executed in any number of counterparts, each of which is an original and all together constitute one and the same agreement. Separate counterparts of this Agreement may be separately executed by the Trustee and the Authority, both with the same force and effect as though the same counterpart had been executed by the Trustee and the Authority. SECTION 6. Binding Effect. This Agreement inures to the benefit of and binds the Authority and the Trustee, and their respective successors and assigns, subject, however, to the limitations contained herein. SECTION 7. Governing Law. This Agreement is governed by the Constitution and laws of the State of California. -3- IN WITNESS WHEREOF, the parties have executed this Agreement by their duly authorized officers as of the day and year first written above. Attest: [to come] Secretary LODI PUBLIC FINANCING AUTHORITY Steve Schwabauer Executive Director U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, as Trustee a ie Serena M. Kohne Authorized Officer APPENDIX A DESCRIPTION OF THE LEASED PROPERTY The Leased Property consists of that certain real property situated in the City of Lodi, County of San Joaquin, which is more particularly described as follows: TRACT ONE: PARCEL ONE: THE SOUTH 120 FEET OF THE WEST 50 FEET OF LOT 8, IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI, FILED FOR RECORD AUGUST 25, 1869, IN VOL. 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL TWO: THE NORTH 50 FEET OF THE WEST 50 FEET OF LOT 8 AND THE EAST 30 FEET OF LOT 8, ALL IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI, FILED FOR RECORDED AUGUST 25, 1869, IN VOL 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL THREE: THE WEST 10 FEET OF LOT 7, IN BLOCK 2, AS SHOWN UPON MAP ENTITLED CITY OF LODI FILED FOR RECORD AUGUST 25, 1869, IN VOL 2 OF MAPS AND PLATS, PAGE 12, SAN JOAQUIN COUNTY RECORDS. PARCEL FOUR: COMMENCING AT THE SOUTH END OF THE LINE BETWEEN LOTS 6 AND 7, IN BLOCK 2 AND RUNNING IN A WESTERLY DIRECTION ALONG THE NORTH SIDE OF ELM STREET 70 FEET; THENCE NORTHERLY AND PARALLEL WITH THE BOUNDARY LINES OF SAID LOTS, 170 FEET; THENCE EASTERLY 70 FEET; THENCE IN A SOUTHERLY DIRECTION 170 FEET TO THE POINT OF BEGINNING, BEING THE EAST 70 FEET OF LOT 7 IN BLOCK NO. 2 IN THE TOWN OF LODI, (NOW CITY OF LODI) SAVE AND EXCEPT THEREFROM THE EAST 5 FEET THEREOF, HERETOFORE CONVEYED TO DAN W. BIRD, ALL ACCORDING TO THE OFFICIAL MAP OF THE FORMER TOWN OF MOKELUMNE, NOR ON FILE IN THE OFFICE OF THE COUNTY RECORDER, COUNTY OF SAN JOAQUIN, STATE OF CALIFORNIA. PARCEL FIVE: THE WEST 50 FEET OF LOT 6 AND THE EAST 5 FEET OF LOT 7 IN BLOCK 2 OF MOKELUMNE (NOT CITY OF LODI) ACCORDING TO THE OFFICIAL MAPS OR PLAT THEREOF FILED AUGUST 25, 1869 AT 8:48 A.M., IN BOOK OF MAPS AND PLATS, VOLUME 2, PAGE 12, OF SAN JOAQUIN COUNTY RECORDS. PARCEL SIX: THE WEST 20 FEET OF LOT 5 AND THE EAST 30 FEET OF LOT 6, IN BLOCK 2, CITY OF LODI, ACCORDING TO THE OFFICIAL MAP OR PLAT THEREOF, FILED FOR RECORD AUGUST 25, 1869, IN VOLUME 2 OF MAPS AND PLATS, PAGE 12 SAN JOAQUIN COUNTY RECORDS. A.P.N. 043-022-13 TRACT TWO: PARCEL ONE: LOT 2, IN BLOCK 1, AS SHOWN UPON MAP ENTITLED WEST LODI, FILED FOR RECORD SEPTEMBER 10, 1904, IN VOL. 3 OF MAPS AND PLATS, PAGE 25 SAN JOAQUIN COUNTY RECORDS. PARCEL ONE A: THE EASTERLY 0.60 FEET OF THE FOLLOWING DESCRIBED LAND: COMMENCING AT THE SOUTHEAST CORNER OF BLOCK 1 OF WEST LODI, AS SHOWN IN THE MAP FILED FOR RECORD IN BOOK OF MAPS AND PLATS. VOLUME 3 PAGE 25, SAN JOAQUIN COUNTY RECORDS; THENCE NORTH 86 17'30" WEST 119.90 FEET ALONG THE SOUTH LINE OF SAID BLOCK 1 TO THE SOUTHEAST CORNER OF LOT 3 OF SAID BLOCK 1, SAID SOUTHEAST CORNER ALSO BEING THE TRUE POINT OF BEGINNING; THENCE NORTH 86 17'30" WEST 119.90 FEET ALONG THE SOUTH LINE OF SAID BLOCK 1 TO THE SOUTHWEST CORNER OF LOT 4 OF SAID BLOCK 1; THENCE NORTH 3 42'40" EAST 169.83 FEET ALONG THE WEST LINE OF SAID LOT 4 TO THE NORTHWEST CORNER THEREOF; THENCE SOUTH 86 16'10" EAST 119.96 ALONG THE NORTH LINE OF SAID LOTS 4 AND 3 TO THE NORTHEAST CORNER OF SAID LOT 3; THENCE SOUTH 03 43'50" WEST 169.79 FEET ALONG THE EAST LINE OF SAID LOT 3 TO THE TRUE POINT OF BEGINNING. SAID PARCEL ONE AND ONE A ABOVE ARE DESCRIBED ON THAT CERTAIN CERTIFICATE OF LOT LINE ADJUSTMENT RECORDED JUNE 27, 2005 AS INSTRUMENT NO. 2005-154383, OF OFFICIAL RECORDS. PARCEL TWO: LOT 1 IN BLOCK 1 OF WEST LODI, ACCORDING TO THE OFFICIAL MAP FOR PLAT THEREOF FILED FOR RECORDED SEPTEMBER 10, 1904, AND RECORDED IN BOOK OF MAPS AND PLATS, VOL 3 PAGE 25, SAN JOAQUIN COUNTY RECORDS. TOGETHER WITH ALL THAT PORTION OF PLEASANT AVENUE FROM THE NORTH LINE OF ELM STREET TO THE SOUTH LINE OF THE 20 FOOT ALLEY BETWEEN ELM STREET AND LOCUST STREET AS SET FORTH AND DEPICTED IN RESOLUTION OF ABANDONMENT RECORDED OCTOBER 8, 2001, AS DOCUMENT NO. 01164151 SAN JOAQUIN PUBLIC RECORDS. A.P.N. 037-270-50 [add Fire Station #2] End of Legal Description A-3 Jones Hall 2-23-22 Agenda INDENTURE OF TRUST Dated as of March 1, 2022 between U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, as Trustee and the LODI PUBLIC FINANCING AUTHORITY Authorizing the Issuance of Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) TABLE OF CONTENTS ARTICLE I DEFINITIONS; RULES OF CONSTRUCTION SECTION1.01. Definitions...........................................................................................................2 SECTION1.02. Authorization.......................................................................................................2 SECTION 1.03. Interpretation.......................................................................................................3 ARTICLE II THE BONDS SECTION 2.01. Authorization of Bonds........................................................................................3 SECTION 2.02. Terms of the Bonds.............................................................................................3 SECTION 2.03. Transfer and Exchange of Bonds........................................................................5 SECTION 2.04. Book -Entry System.............................................................................................5 SECTION 2.05. Registration Books..............................................................................................7 SECTION 2.06. Form and Execution of Bonds.............................................................................7 SECTION 2.07. Bonds Mutilated, Lost, Destroyed or Stolen........................................................8 ARTICLE III ISSUANCE OF BONDS; APPLICATION OF PROCEEDS SECTION 3.01. Issuance of the Bonds.........................................................................................8 SECTION 3.02. Application of Proceeds of Sale of Bonds; Transfer of Prior Funds .....................8 SECTION 3.03. Establishment and Application of Costs of Issuance Fund..................................9 SECTION 3.04. Establishment and Application of Project Fund...................................................9 SECTION 3.05. Validity of Bonds...............................................................................................10 ARTICLE IV REDEMPTION OF BONDS SECTION 4.01. Terms of Redemption........................................................................................10 SECTION 4.02. Selection of Bonds for Redemption...................................................................11 SECTION 4.03. Notice of Redemption; Rescission.....................................................................11 SECTION 4.04. Partial Redemption of Bonds.............................................................................12 SECTION 4.05. Effect of Redemption........................................................................................12 ARTICLE V REVENUES; FUNDS AND ACCOUNTS; PAYMENT OF PRINCIPAL AND INTEREST SECTION 5.01. Security for the Bonds; Bond Fund....................................................................13 SECTION 5.02. Allocation of Revenues.....................................................................................13 SECTION 5.03. Application of Interest Account..........................................................................14 SECTION 5.04. Application of Principal Account........................................................................14 SECTION5.05. Reserved..........................................................................................................14 SECTION 5.06. Application of Redemption Fund.......................................................................14 SECTION 5.07. Insurance and Condemnation Fund..................................................................14 SECTION 5.08. Investments......................................................................................................16 SECTION 5.09. Valuation and Disposition of Investments..........................................................16 ARTICLE VI COVENANTS OF THE AUTHORITY SECTION 6.01. Punctual Payment.............................................................................................18 SECTION 6.02. Extension of Payment of Bonds........................................................................18 SECTION 6.03. Against Encumbrances.....................................................................................18 SECTION 6.04. Power to Issue Bonds and Make Pledge and Assignment................................18 SECTION 6.05. Accounting Records..........................................................................................18 SECTION 6.06. Limitation on Additional Obligations..................................................................19 SECTION 6.07. Tax Covenants..................................................................................................19 SECTION 6.08. Enforcement of Lease.......................................................................................19 SECTION 6.09. Waiver of Laws.................................................................................................20 SECTION 6.10. Further Assurances...........................................................................................20 ARTICLE VII SECTION 11.01. EVENTS OF DEFAULT AND REMEDIES SECTION 7.01. Events of Default...............................................................................................20 SECTION 7.02. Remedies Upon Event of Default......................................................................21 SECTION 7.03. Application of Revenues and Other Funds After Default...................................21 SECTION 7.04. Trustee to Represent Bond Owners..................................................................22 SECTION 7.05. Limitation on Bond Owners' Right to Sue..........................................................22 SECTION 7.06. Absolute Obligation of Authority........................................................................23 SECTION 7.07. Termination of Proceedings..............................................................................23 SECTION 7.08. Remedies Not Exclusive...................................................................................23 SECTION 7.09. No Waiver of Default.........................................................................................23 SECTION 7.10. Notice to Bond Owners of Default.....................................................................23 ARTICLE VIII THE TRUSTEE SECTION 8.01. Appointment of Trustee.....................................................................................24 SECTION 8.02. Acceptance of Trusts; Removal and Resignation of Trustee .............................24 SECTION 8.03. Merger or Consolidation....................................................................................26 SECTION 8.04. Liability of Trustee.............................................................................................26 SECTION 8.05. Right to Rely on Documents..............................................................................28 SECTION 8.06. Preservation and Inspection of Documents.......................................................29 SECTION 8.07. Compensation and Indemnification...................................................................29 ARTICLE IX MODIFICATION OR AMENDMENT HEREOF SECTION 9.01. Amendments Permitted.....................................................................................30 SECTION 9.02. Effect of Supplemental Indenture......................................................................31 SECTION 9.03. Endorsement of Bonds; Preparation of New Bonds..........................................31 SECTION 9.04. Amendment of Particular Bonds........................................................................32 ARTICLE X DEFEASANCE SECTION 10.01. Discharge of Indenture....................................................................................32 SECTION 10.02. Discharge of Liability on Bonds.......................................................................32 SECTION 10.03. Deposit of Money or Securities with Trustee...................................................33 SECTION 10.04. Unclaimed Funds............................................................................................33 ARTICLE XI MISCELLANEOUS SECTION 11.01. Liability of Authority Limited to Revenues........................................................34 SECTION 11.02. Limitation of Rights to Parties and Bond Owners............................................34 SECTION 11.03. Funds and Accounts.......................................................................................34 SECTION 11.04. Waiver of Notice; Requirement of Mailed Notice.............................................34 SECTION 11.05. Destruction of Bonds.......................................................................................35 SECTION 11.06. Severability of Invalid Provisions.....................................................................35 SECTION11.07. Notices............................................................................................................35 SECTION 11.08. Evidence of Rights of Bond Owners................................................................35 SECTION 11.09. Disqualified Bonds..........................................................................................36 SECTION 11.10. Money Held for Particular Bonds.....................................................................36 SECTION 11.11. Waiver of Personal Liability.............................................................................36 SECTION 11.12. Successor Is Deemed Included in All References to Predecessor ..................36 SECTION 11.13. Execution in Several Counterparts..................................................................37 SECTION 11.14. Payment on Non -Business Day......................................................................37 SECTION 11.15. Governing Law................................................................................................37 APPENDIX A DEFINITIONS APPENDIX B FORM OF BOND APPENDIX C FORM OF PROJECT FUND REQUISITION INDENTURE OF TRUST This INDENTURE OF TRUST (this "Indenture"), dated for convenience as of March 1, 2022, is between the LODI PUBLIC FINANCING AUTHORITY, a joint powers authority duly organized and existing under the laws of the State of California (the "Authority"), and U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, a national banking association organized and existing under the laws of the United States of America, with a corporate trust office in San Francisco, California, being qualified to accept and administer the trusts hereby created (the "Trustee"). BACKGROUND: 1. The Authority previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City of Lodi (the "City"). 2. In connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum. 3. In order to take advantage of prevailing bond market conditions, the City is proceeding to refund the 2012 Bonds. 4. The City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including a new animal shelter and park and playground improvements and upgrades (the "Project"). 5. To that end, the City has leased the City's police building and the City's Fire Station #2 (the "Leased Property") to the Authority under a Site Lease dated as of March 1, 2022 (the "Site Lease"), in consideration of the payment by the Authority of an upfront rental payment (the "Site Lease Payment") which is sufficient to provide funds for the refunding of the 2012 Bonds and the financing of the Project. 6. The Authority has authorized the issuance of its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) in the aggregate principal amount of $ (the "Bonds") under this Indenture for the purpose of providing the funds to enable the Authority to pay the Site Lease Payment to the City in accordance with the Site Lease. 7. In order to provide revenues which are sufficient to enable the Authority to pay debt service on the Bonds, the Authority has leased the Leased Property back to the City under a Lease Agreement dated as of March 1, 2022 (the "Lease"), under which the City has agreed to pay semiannual Lease Payments as the rental for the Leased Property thereunder. 8. The lease payments made by the City under the Lease have been assigned by the Authority to the Trustee for the security of the Bonds under an Assignment Agreement, dated as of March 1, 2022, between the Authority as assignor and the Trustee as assignee. 9. In order 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 Authority has authorized the execution and delivery of this Indenture. 10. The Authority has found and determined, and hereby affirms, that all acts and proceedings required by law necessary to make the Bonds, when executed by the Authority, authenticated and delivered by the Trustee and duly issued, the valid, binding and legal special obligations of the Authority, and to constitute this Indenture 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 Indenture have been in all respects duly authorized. AGREEMENT: In order to secure the payment of the principal of and the interest and redemption premium (if any) on all the Outstanding Bonds 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 of the purchase and acceptance of the Bonds by the Owners thereof, and for other valuable considerations, the receipt of which is hereby acknowledged, the Authority and the Trustee do hereby covenant and agree with one another, for the benefit of the respective Owners from time to time of the Bonds, as follows: ARTICLE I DEFINITIONS; RULES OF CONSTRUCTION SECTION 1.01. Definitions. Unless the context clearly otherwise requires or unless otherwise defined herein, the capitalized terms defined in Appendix A attached to this Indenture have the respective meanings specified in that Appendix when used in this Indenture. SECTION 1.02. Authorization. Each of the parties hereby represents and warrants that it has full legal authority and is duly empowered to enter into this Indenture, and has taken all actions necessary to authorize the execution hereof by the officers and persons signing it. -2- SECTION 1.03. Interpretation. (a) Unless the context otherwise indicates, words expressed in the singular shall include the plural and vice versa and the use of the neuter, masculine, or feminine gender is for convenience only and shall be deemed to include the neuter, masculine or feminine gender, as appropriate. (b) Headings of articles and sections herein and the table of contents hereof are solely for convenience of reference, do not constitute a part hereof and shall not affect the meaning, construction or effect hereof. (c) All references herein to "Articles," "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of this Indenture; the words "herein," "hereof," "hereby," "hereunder" and other words of similar import refer to this Indenture as a whole and not to any particular Article, Section or subdivision hereof. ARTICLE II THE BONDS SECTION 2.01. Authorization of Bonds. The Authority has reviewed all proceedings heretofore taken and has found, as a result of such review, and hereby finds and determines that all things, conditions and acts required by law to exist, happen or be performed precedent to and in connection with 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 duly empowered, under 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 Bonds in the aggregate principal amount of $ under the Bond Law for the purposes of providing funds to pay the Site Lease Payment to the City and thereby provide funds to refund the 2012 Bonds and finance the Project. The Bonds are authorized and issued under, and are subject to the terms of, this Indenture and the Bond Law. The Bonds are designated the "Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing)." SECTION 2.02. Terms of the Bonds. (a) Payment Provisions. 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 Bond has more than one maturity date. The Bonds shall mature on October 1 in each of the years and in the amounts, and 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 (October 1) Amount Rate -3- (T)Term Bond Interest on the Bonds is payable from the Interest Payment Date next preceding the date of authentication thereof unless: (a) a Bond is authenticated on or before an Interest Payment Date and after the close of business on the preceding Record Date, in which event it will bear interest from such Interest Payment Date, (b) a Bond is authenticated on or before the first Record Date, in which event interest thereon will be payable from the Closing Date, or (c) interest on any Bond is in default as of the date of authentication thereof, in which event interest thereon will be payable from the date to which interest has been paid in full, payable on each Interest Payment Date. Interest is payable on each Interest Payment Date to the persons in whose names the ownership of the Bonds is registered on the Registration Books at the close of business on the immediately preceding Record Date, except as provided below. Interest on any Bond which is not punctually paid or duly provided for on any Interest Payment Date is payable to the person in whose name the ownership of such Bond is registered on the Registration Books at the close of business on a special record date for the payment of -4- such defaulted interest to be fixed by the Trustee, notice of which is given to such Owner by first-class mail not less than 10 days prior to such special record date. The Trustee will pay interest on the Bonds by check of the Trustee mailed by first class mail, postage prepaid, on each Interest Payment Date to the Owners of the Bonds at their respective addresses shown on the Registration Books as of the close of business on the preceding Record Date. At the written request of the Owner of Bonds in an aggregate principal amount of at least $1,000,000, which written request is on file with the Trustee as of any Record Date, the Trustee will pay interest on such Bonds on each succeeding Interest Payment Date by wire transfer in immediately available funds to such account of a financial institution within the United States of America as specified in such written request, which written request will remain in effect until rescinded in writing by the Owner. The Trustee will pay principal of the Bonds in lawful money of the United States of America by check of the Trustee upon presentation and surrender thereof at the Office of the Trustee. SECTION 2.03. Transfer and Exchange of Bonds. (a) Transfer. 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 a duly authorized attorney of such person, upon surrender of such Bond to the Trustee at its Office for cancellation, accompanied by delivery of a written instrument of transfer in a form acceptable to the Trustee, duly executed. The Trustee shall require the Owner requesting such transfer to pay any tax or other governmental charge required to be paid with respect to such transfer. Whenever any Bond or Bonds shall be surrendered for transfer, the Authority shall execute and the Trustee shall authenticate and deliver to the transferee a new Bond or Bonds of like series, interest rate, maturity and aggregate principal amount. The Authority shall pay the cost of printing Bonds and any services rendered or expenses incurred by the Trustee in connection with any transfer of Bonds. (b) Exchange. The Bonds may be exchanged at the Office of the Trustee for a like aggregate principal amount of Bonds of other authorized denominations and of the same series, interest rate and maturity. The Trustee shall require the Owner requesting such exchange to pay any tax or other governmental charge required to be paid with respect to such exchange. The Authority shall pay the cost of printing Bonds and any services rendered or expenses incurred by the Trustee in connection with any exchange of Bonds. (c) Limitations. The Trustee may refuse to transfer or exchange, under the provisions of this Section 2.03, any Bonds selected by the Trustee for redemption under Article IV, or any Bonds during the period established by the Trustee for the selection of Bonds for redemption. SECTION 2.04. Book -Entry System. (a) Original Delivery. The Bonds will be initially delivered in the form of a separate single fully registered bond (which may be typewritten) for each maturity of the Bonds. Upon initial delivery, the Trustee shall register the ownership of each Bond on the Registration Books in the name of the Nominee. Except as provided in subsection (c), the ownership of all of the Outstanding Bonds shall be registered in the name of the Nominee on the Registration Books. -5- With respect to Bonds the ownership of which shall be registered in the name of the Nominee, the Authority and the Trustee has no responsibility or obligation to any Depository System Participant or to any person on behalf of which the Nominee holds an interest in the Bonds. Without limiting the generality of the immediately preceding sentence, the Authority and the Trustee has no responsibility or obligation with respect to (i) the accuracy of the records of the Depository, the Nominee or any Depository System Participant with respect to any ownership interest in the Bonds, (ii) the delivery to any Depository System Participant or any other person, other than a Bond Owner as shown in the Registration Books, of any notice with respect to the Bonds, including any notice of redemption, (iii) the selection by the Depository of the beneficial interests in the Bonds to be redeemed if the Authority elects to redeem the Bonds in part, (iv) the payment to any Depository System Participant or any other person, other than a Bond Owner as shown in the Registration Books, of any amount with respect to principal, premium, if any, or interest on the Bonds or (v) any consent given or other action taken by the Depository as Owner of the Bonds. The Authority and the Trustee may treat and consider the person in whose name each Bond is registered as the absolute owner of such Bond for the purpose of payment of principal of and premium, if any, and interest on such Bond, for the purpose of giving notices of redemption and other matters with respect to such Bond, for the purpose of registering transfers of ownership of such Bond, and for all other purposes whatsoever. The Trustee shall pay the principal of and the interest and premium, if any, on the Bonds only to the respective Owners or their respective attorneys duly authorized in writing, and all such payments shall be valid and effective to fully satisfy and discharge all obligations with respect to payment of principal of and interest and premium, if any, on the Bonds to the extent of the sum or sums so paid. No person other than a Bond Owner shall receive a Bond evidencing the obligation of the Authority to make payments of principal, interest and premium, if any, under this Indenture. Upon delivery by the Depository to the Authority of written notice to the effect that the Depository has determined to substitute a new Nominee in its place, and subject to the provisions herein with respect to Record Dates, such new nominee shall become the Nominee hereunder for all purposes; and upon receipt of such a notice the Authority shall promptly deliver a copy of the same to the Trustee. (b) Representation Letter. In order to qualify the Bonds for the Depository's book -entry system, the Authority shall execute and deliver to such Depository a letter representing such matters as shall be necessary to so qualify the Bonds. The execution and delivery of such letter shall not in any way limit the provisions of subsection (a) above or in any other way impose upon the Authority or the Trustee any obligation whatsoever with respect to persons having interests in the Bonds other than the Bond Owners. Upon the written acceptance by the Trustee, the Trustee shall agree to take all action reasonably necessary for all representations of the Trustee in such letter with respect to the Trustee to at all times be complied with. In addition to the execution and delivery of such letter, the Authority may take any other actions, not inconsistent with this Indenture, to qualify the Bonds for the Depository's book -entry program. (c) Transfers Outside Book -Entry System. If either (i) the Depository determines not to continue to act as Depository for the Bonds, or (ii) the Authority determines to terminate the Depository as such, then the Authority shall thereupon discontinue the book - entry system with such Depository. In such event, the Depository shall cooperate with the Authority and the Trustee in the issuance of replacement Bonds by providing the Trustee with a list showing the interests of the Depository System Participants in the Bonds, and M by surrendering the Bonds, registered in the name of the Nominee, to the Trustee on or before the date such replacement Bonds are to be issued. The Depository, by accepting delivery of the Bonds, agrees to be bound by the provisions of this subsection (c). If, prior to the termination of the Depository acting as such, the Authority fails to identify another Securities Depository to replace the Depository, then the Bonds shall no longer be required to be registered in the Registration Books in the name of the Nominee, but shall be registered in whatever name or names the Owners transferring or exchanging Bonds shall designate, in accordance with the provisions hereof. If the Authority determines that it is in the best interests of the beneficial owners of the Bonds that they be able to obtain certificated Bonds, the Authority may notify the Depository System Participants of the availability of such certificated Bonds through the Depository. In such event, the Trustee will issue, transfer and exchange Bonds as required by the Depository and others in appropriate amounts; and whenever the Depository requests, the Trustee and the Authority shall cooperate with the Depository in taking appropriate action (y) to make available one or more separate certificates evidencing the Bonds to any Depository System Participant having Bonds credited to its account with the Depository, or (z) to arrange for another Securities Depository to maintain custody of a single certificate evidencing such Bonds, all at the Authority's expense. (d) Payments to the Nominee. Notwithstanding any other provision 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 of and interest and premium, if any, on such Bond and all notices with respect to such Bond shall be made and given, respectively, as provided in the letter described in subsection (b) of this Section or as otherwise instructed by the Depository. SECTION 2.05. Registration Books. The Trustee will keep or cause to be kept, at the Office of the Trustee, sufficient records for the registration and transfer of ownership of the Bonds, which shall upon reasonable notice as agreed to by the Trustee, be open to inspection during regular business hours by the Authority; 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, the ownership of the Bonds as hereinbefore provided. SECTION 2.06. Form and Execution of Bonds. The Bonds, the form of Trustee's certificate of authentication, and the form of assignment to appear thereon, are set forth in Appendix B attached hereto and by this reference incorporated herein, with necessary or appropriate variations, omissions and insertions, as permitted or required by this Indenture. The Chairman of the Authority shall execute, and the Secretary of the Authority shall attest each Bond. Either or both of such signatures may be made manually or may be affixed by facsimile thereof. If any officer whose signature appears on any Bond ceases to be such officer before the Closing Date, such signature will nevertheless be as effective as if the officer had remained in office until the Closing Date. Any Bond may be signed and attested on behalf of the Authority by such persons as at the actual date of the execution of such Bond are the proper officers of the Authority, duly authorized to execute debt instruments on behalf of the Authority, although on the date of such Bond any such person was not an officer of the Authority. -7- Only those Bonds bearing a certificate of authentication in the form set forth in Appendix B, manually executed and dated by the Trustee, are valid or obligatory for any purpose or entitled to the benefits of this Indenture, and such certificate of the Trustee is conclusive evidence that such Bonds have been duly authenticated and delivered hereunder and are entitled to the benefits of this Indenture. SECTION 2.07. Bonds Mutilated, Lost, Destroyed or Stolen. If any Bond is 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 in exchange and substitution for the Bond so mutilated, but only upon surrender to the Trustee of the Bond so mutilated. The Trustee shall cancel every mutilated Bond surrendered to it and deliver such mutilated Bond to, or upon the order of, the Authority. If any Bond is lost, destroyed or stolen, evidence of such loss, destruction or theft may be submitted to the Trustee and, if such evidence is satisfactory and if indemnity satisfactory to the Trustee is 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. The Trustee may require payment of a sum not exceeding the actual cost of preparing each new Bond issued under this Section and of the expenses which may be incurred by the Trustee in connection therewith. Any Bond issued under the provisions of this Section in lieu of any Bond alleged to be lost, destroyed or stolen will constitute an original additional contractual obligation on the part of the Authority whether or not the Bond so 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 issued under this Indenture. Notwithstanding any other provision of this Section 2.07, in lieu of delivering a new Bond for which principal has become due for a Bond which has been mutilated, lost, destroyed or stolen, the Trustee may make payment of such Bond in accordance with its terms upon receipt of indemnity satisfactory to the Trustee. ARTICLE III ISSUANCE OF BONDS; APPLICATION OF PROCEEDS SECTION 3.01. Issuance of the Bonds. At any time after the execution of this Indenture, the Authority may execute and the Trustee shall authenticate and, upon the Written Request of the Authority, deliver the Bonds to the Original Purchaser. SECTION 3.02. Application of Proceeds of Sale of Bonds; Transfer of Prior Funds. Upon the receipt of payment for the Bonds in the amount of $ on the Closing Date, the Trustee shall deposit the proceeds thereof into a temporary account, which shall be disbursed in full on the Closing Date (whereupon said temporary account shall be closed) as follows: (a) The Trustee shall deposit the amount of $ into the Costs of Issuance Fund. (b) The Trustee shall deposit the amount of $ into the Project Fund. (c) The Trustee shall transfer the amount of $ , constituting the remainder of such proceeds and representing the full amount of the Site Lease Payment, to the 2012 Trustee for deposit into the Redemption Fund established and held by the 2012 Trustee for the 2012 Bonds. In addition to the foregoing transfers, on the Closing Date the 2012 Trustee will transfer any moneys in the funds and accounts established for the 2012 Bonds and deposit them in the Redemption Fund for the 2012 Bonds. SECTION 3.03. Establishment and Application of Costs of Issuance Fund. The Trustee shall establish, maintain and hold in trust a separate fund designated as the "Costs of Issuance Fund" into which the Trustee shall deposit a portion of the proceeds of sale of the Bonds under Section 3.02(a). The Trustee shall disburse amounts in the Costs of Issuance Fund from time to time to pay the Costs of Issuance upon submission of a Written Requisition of the Authority stating the person to whom payment is to be made, the amount to be paid, the purpose for which the obligation was incurred and that such payment is a proper charge against said fund. Each such Written Requisition of the Authority shall be sufficient evidence to the Trustee of the facts stated therein and the Trustee shall have no duty to confirm the accuracy of such facts. The Trustee may conclusively rely on such Written Requisitions and shall be fully protected in relying thereon. On June 30, 2022, or upon the earlier Written Request of the Authority, the Trustee shall transfer all amounts remaining in the Costs of Issuance Fund to the Project Fund and shall thereupon close the Costs of Issuance Fund. SECTION 3.04. Establishment and Application of Project Fund. The Trustee shall establish, maintain and hold in trust a separate fund designated as the "Project Fund" into which the Trustee shall deposit a portion of the proceeds of sale of the Bonds under Section 3.02(b). The Trustee shall administer such fund as provided in this Section 3.04. Amounts on deposit in the Project Fund shall be used, as provided below, to pay the Project Costs, and to reimburse the City for the same. Pending such use, amounts on deposit in the Project Fund shall be invested only in Permitted Investments, with interest earnings and other investment income thereon being retained therein. All moneys remaining in the Project Fund upon the completion of the Project (as determined by the City in its sole discretion with written notice to the Trustee) shall be transferred by the Trustee and the Project Fund shall be closed as hereinafter provided. The Trustee shall, from time to time, disburse money from the Project Fund to pay the Project Costs for the Project, as hereinafter provided, in each case promptly after receipt of, and in accordance with, a Written Certificate in the form attached hereto as Appendix C. In making such payments, the Trustee may rely upon the representations made in the Written Certificate. If for any reason the City should decide prior to the payment of any item in said Written Certificate not to pay such item, then it shall give written notice of such decision to the Trustee and thereupon the Trustee shall not make such payment, and the Trustee shall have no liability to the City or the designated payee as a result of such nonpayment. In no event shall the Trustee be responsible for the adequacy or due performance of any contracts relating to the Project or for the use or application of money properly disbursed pursuant to requests made under this Section 3.04. If, after payment by the Trustee of all Written Certificates theretofore tendered to the Trustee under the provisions of this Section 3.04 and after the City has notified the Trustee of the completion of the Project, there shall remain any balance of money in the Project Fund, all money so remaining (other than a reasonable retainage to pay Project Costs, as determined in the sole discretion of the City with written notice to the Trustee) shall be transferred to the Bond Fund and used to pay principal of and interest on the Bonds, as directed by the City. At such time as no moneys remain in the Project Fund, the Project Fund shall be closed. SECTION 3.05. Validity of Bonds. The recital contained in the Bonds that the same are issued under the Constitution and laws of the State of California shall be conclusive evidence of their validity and of compliance with the provisions of law in their issuance. ARTICLE IV REDEMPTION OF BONDS SECTION 4.01. Terms of Redemption. (a) Optional Redemption. The Bonds maturing on or before October 1, , are not subject to optional redemption prior to their stated maturity. The Bonds maturing on or after October 1, , are subject to redemption, as a whole or in part at the election of the Authority among maturities on such basis as designated by the Authority and by lot within a maturity, at the option of the Authority, on April 1, , and on any date thereafter, at a redemption price equal to 100% of the principal amount of Bonds to be redeemed, together with accrued interest thereon to the date fixed for redemption, without premium. The Authority must give the Trustee written notice of its intention to redeem Bonds under this subsection (a), and the manner of selecting such Bonds for redemption from among the maturities thereof, in sufficient time to enable the Trustee to give notice of such redemption in accordance with Section 4.03. (b) Special Mandatory Redemption From Insurance or Condemnation Proceeds. The Bonds are subject to redemption as a whole, or in part on a pro rata basis among maturities, on any date, from any Net Proceeds required to be used for such purpose as provided in Section 5.07, at a redemption price equal to 100% of the principal amount thereof plus interest accrued thereon to the date fixed for redemption, without premium. (c) Mandatory Sinking Fund Redemption. The Term Bonds are subject to mandatory redemption in part by lot, at a redemption price equal to 100% of the principal amount thereof to be redeemed, without premium, in the aggregate respective principal -10- amounts and on October 1 in the respective years as set forth in the following tables; provided, however, that if some but not all of the Term Bonds have been redeemed under subsections (a) or (b) of this Section, the total amount of all future sinking fund payments shall be reduced by the aggregate principal amount of the Term Bonds so redeemed, to be allocated among such sinking fund payments on a pro rata basis in integral multiples of $5,000 (as set forth in a schedule provided by the Authority to the Trustee). Mandatory Sinking Fund Redemption of Term Bonds Maturing October 1, Sinking Fund Redemption Date (October 1) Principal Amount To Be Redeemed Mandatory Sinking Fund Redemption of Term Bonds Maturing October 1, Sinking Fund Redemption Date (October 1) Principal Amount To Be Redeemed SECTION 4.02. Selection of Bonds for Redemption. Whenever provision is made in this Indenture for the redemption of less than all of the Bonds of a single maturity, the Trustee shall select the Bonds of that maturity to be redeemed by lot in any manner which the Trustee in its sole discretion deems appropriate. For purposes of such selection, the Trustee shall treat each Bond as consisting of separate $5,000 portions and each such portion shall be subject to redemption as if such portion were a separate Bond. SECTION 4.03. Notice of Redemption; Rescission. The Trustee shall mail notice of redemption of the Bonds by first class mail, postage prepaid, not less than 20 nor more than 60 days before any redemption date, to the respective Owners of any Bonds designated for redemption at their addresses appearing on the Registration Books and to one or more Securities Depositories and to the Municipal Securities Rulemaking Board as provided in the Continuing Disclosure Certificate. Each notice of redemption shall state the date of the notice, the redemption date, the place or places of redemption, whether less than all of the Bonds (or all Bonds of a single maturity) are to be redeemed, the CUSIP numbers and (in the event that not all Bonds within a maturity are called for redemption) Bond numbers of the Bonds to be redeemed and the maturity or maturities of the Bonds to be redeemed, and in the case of Bonds to be redeemed in part only, the respective portions of the principal amount thereof to be redeemed. Each such notice shall also state that on the redemption date there will become due and payable on each of said Bonds the redemption price thereof, and that from and after such redemption date interest thereon -11- shall cease to accrue, and shall require that such Bonds be then surrendered to the Trustee. Neither the failure to receive any notice nor any defect therein shall affect the sufficiency of the proceedings for such redemption or the cessation of accrual of interest from and after the redemption date. Notice of redemption of Bonds shall be given by the Trustee, at the expense of the Authority, for and on behalf of the Authority. Any notice of a redemption of Bonds under Section 4.01(a) may provide that the redemption shall be conditional upon the receipt of sufficient funds to accomplish the redemption. The Authority has the right to rescind any notice of the redemption of Bonds under Section 4.01(a) by written notice to the Trustee on or prior to the dated fixed for redemption. Any notice of redemption shall be cancelled and annulled if for any reason funds will not be or are not available on the date fixed for redemption for the payment in full of the Bonds then called for redemption, and such cancellation shall not constitute an Event of Default. The Authority and the Trustee have no liability to the Bond Owners or any other party related to or arising from such rescission of redemption. The Trustee shall mail notice of such rescission of redemption in the same manner as the original notice of redemption was sent under this Section. SECTION 4.04. Partial Redemption of Bonds. Upon surrender of any Bonds redeemed in part only, 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 authorized denominations equal in aggregate principal amount to the unredeemed portion of the Bonds surrendered. SECTION 4.05. Effect of Redemption. Notice of redemption having been duly given as aforesaid, and moneys for payment of the redemption price of, together with interest accrued to the date fixed for redemption on, including any applicable premium, the Bonds (or portions thereof) so called for redemption being held by the Trustee, on the redemption date designated in such notice, the Bonds (or portions thereof) so called for redemption shall become due and payable, interest on the Bonds so called for redemption shall cease to accrue, said Bonds (or portions thereof) shall cease to be entitled to any benefit or security under this Indenture, and the Owners of said Bonds shall have no rights in respect thereof except to receive payment of the redemption price thereof. All Bonds redeemed under the provisions of this Article shall be canceled by the Trustee upon surrender thereof and destroyed in accordance with the retention policy of the Trustee then in effect. -12- ARTICLE V REVENUES; FUNDS AND ACCOUNTS; PAYMENT OF PRINCIPAL AND INTEREST SECTION 5.01. Security for the Bonds; Bond Fund. (a) Pledge of Revenues and Other Amounts. Subject only to the provisions of this Indenture permitting the application thereof for the purposes and on the terms and conditions set forth herein, all of the Revenues and all amounts (including proceeds of the sale of the Bonds) held in any fund or account established under this Indenture are hereby pledged to secure the payment of the principal of and interest and premium (if any) on the Bonds in accordance with their terms and the provisions of this Indenture. Said pledge constitutes a lien on and security interest in the Revenues and such amounts and shall attach, be perfected and be valid and binding from and after the Closing Date, without the need for any physical delivery thereof or further act. (b) Assignment to Trustee. Under the Assignment Agreement, the Authority has transferred to the Trustee all of the rights of the Authority in the Lease (other than the rights of the Authority under Sections 4.5, 5.10, 7.3 and 8.4 thereof). The Trustee is entitled to collect and receive all of the Revenues, and 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 is also entitled to and shall, subject to the provisions of Article VIII, take all steps, actions and proceedings which the Trustee determines to be 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 City under the Lease. (c) Deposit of Revenues in Bond Fund. All Revenues shall be promptly deposited by the Trustee upon receipt thereof in a special fund designated as the "Bond Fund" which the Trustee shall establish, maintain and hold in trust; except that all moneys received by the Trustee and required hereunder or under the Lease to be deposited in the Redemption Fund or the Insurance and Condemnation Fund shall be promptly deposited in such funds. All Revenues deposited with the Trustee shall be held, disbursed, allocated and applied by the Trustee only as provided in this Indenture. Any surplus remaining in the Bond Fund, after payment in full of (i) the principal of and interest on the Bonds or provision therefore under Article X, and (ii) any applicable fees and expenses to the Trustee, shall be withdrawn by the Trustee and remitted to the City. SECTION 5.02. Allocation of Revenues. On or before each Interest Payment Date, the Trustee shall transfer from the Bond Fund and deposit into the following respective accounts (each of which the Trustee shall establish and maintain within the Bond Fund), the following amounts in the following order of priority: (a) Deposit to Interest Account. The Trustee shall deposit in the Interest Account an amount required to cause the aggregate amount on deposit in the Interest Account to be at least equal to the amount of interest becoming due and payable on such Interest Payment Date on all Bonds then Outstanding. -13- (b) Deposit to Principal Account. The Trustee shall deposit in the Principal Account an amount required to cause the aggregate amount on deposit in the Principal Account to equal the principal amount of the Bonds coming due and payable on such Interest Payment Date, including principal of any Term Bonds payable as a result of mandatory sinking fund redemption under Section 4.01(c). SECTION 5.03. Application of Interest Account. All amounts in the Interest Account shall be used and withdrawn by the Trustee solely for the purpose of paying interest on the Bonds as it comes due and payable (including accrued interest on any Bonds purchased or redeemed prior to maturity), including principal of any Term Bonds payable as a result of mandatory sinking fund redemption under Section 4.01(c). SECTION 5.04. Application of Principal Account. All amounts in the Principal Account shall be used and withdrawn by the Trustee solely to pay the principal amount of the Bonds at their respective maturity dates. SECTION 5.05. Reserved. SECTION 5.06. Application of Redemption Fund. The Trustee shall establish and maintain the Redemption Fund, into which the Trustee shall deposit a portion of the Revenues received, in accordance with a Written Request of the Authority, amounts in which shall be used and withdrawn by the Trustee solely for the purpose of paying the principal and premium (if any) of the Bonds to be redeemed under Section 4.01, other than the principal of any Term Bonds payable as a result of mandatory sinking fund redemption under Section 4.01(c); provided, however, that at any time prior to the selection of Bonds for redemption, the Trustee may apply such amounts to the purchase of Bonds at public or private sale, when and at such prices (including brokerage and other charges, but excluding accrued interest, which is payable from the Interest Account) as shall be directed under a Written Request of the Authority, except that the purchase price (exclusive of accrued interest) may not exceed the redemption price then applicable to the Bonds. The Trustee shall be entitled to conclusively rely on any Written Request of the Authority received under this Section 5.06, and shall be fully protected in relying thereon. SECTION 5.07. Insurance and Condemnation Fund. (a) Establishment of Fund. Upon the receipt of proceeds of insurance or eminent domain with respect to the Leased Property, the Trustee shall establish and maintain an Insurance and Condemnation Fund, to be held and applied as hereinafter set forth in this Section 5.07. (b) Application of Insurance Proceeds. Any Net Proceeds of insurance against accident to or destruction of the Leased Property collected by the City or the Authority in the event of any such accident or destruction shall be paid to the Trustee under Section 6.3 of the Lease and deposited by the Trustee promptly upon receipt thereof in the Insurance and Condemnation Fund. If the City fails to determine and notify the Trustee in writing of its determination, within 45 days following the date of such deposit, to replace, repair, restore, modify or improve the Leased Property which has been damaged or destroyed, then such Net Proceeds shall be promptly transferred by the Trustee to the Redemption Fund and applied to the redemption of Bonds under Section 4.01(b). Notwithstanding the foregoing sentence, however, if the Leased Property is damaged or -14- destroyed in full, the Net Proceeds of such insurance shall be used by the City to rebuild or replace the Leased Property if such proceeds are not sufficient to redeem Outstanding Bonds equal in aggregate principal amount to the unpaid Lease Payments allocable to the Leased Property. All proceeds deposited in the Insurance and Condemnation Fund and not so transferred to the Redemption Fund shall be applied to the prompt replacement, repair, restoration, modification or improvement of the damaged or destroyed portions of the Leased Property by the City, upon receipt of a Written Request of the City which: (i) states with respect to each payment to be made (A) the requisition number, (B) the name and address of the person to whom payment is due, (C) the amount to be paid and (D) that each obligation mentioned therein has been properly incurred, is a proper charge against the Insurance and Condemnation Fund and has not been the basis of any previous withdrawal; and (ii) specifies in reasonable detail the nature of the obligation. Any balance of the proceeds remaining after such work has been completed as certified by the City under a Written Certificate to the Trustee shall be paid to the City. The Trustee shall be entitled to conclusively rely on any Written Request or Written Certificate received under this subsection (b) of this Section 5.07 and in each case, shall be fully protected in relying thereon. (c) Application of Eminent Domain Proceeds. If all or any part of the Leased Property is taken by eminent domain proceedings (or sold to a government threatening to exercise the power of eminent domain) the Authority shall deposit or cause to be deposited with the Trustee the Net Proceeds therefrom, which the Trustee shall deposit in the Insurance and Condemnation Fund under Section 6.2(b) of the Lease and which shall be applied and disbursed by the Trustee as follows: (i) If the City has not given written notice to the Trustee, within 45 days following the date on which such Net Proceeds are deposited with the Trustee, of its determination that such Net Proceeds are needed for the replacement of the Leased Property or such portion thereof, the Trustee shall transfer such Net Proceeds to the Redemption Fund to be applied towards the redemption of the Bonds under Section 4.01(b). (ii) If the City has given written notice to the Trustee, within 45 days following the date on which such Net Proceeds are deposited with the Trustee, of its determination that such Net Proceeds are needed for replacement of the Leased Property or such portion thereof, the Trustee shall pay to the City, or to its order, from said proceeds such amounts as the City may expend for such replacement, upon the filing of Written Requisitions of the City as agent for the Authority. In each case, the Trustee may conclusively rely upon any notice received under this subsection (c)(ii) of this Section and is protected in relying thereon. (d) Reliance on Independent Advice. In making any such determination whether to repair, replace or rehabilitate the Leased Property under this Section 5.07, the City may obtain, but is not required to obtain, at its expense, the report of an independent engineer or other independent professional consultant, a copy of which must be filed with the Trustee. The Trustee shall have no duty to review or examine such report. Any such determination by the City is final. -15- SECTION 5.08. Investments. All moneys in any of the funds or accounts established with the Trustee under this Indenture shall be invested by the Trustee solely in Permitted Investments. Such investments shall be directed by the Authority in a Written Request of the Authority filed with the Trustee at least 2 Business Days in advance of the making of such investments. In the absence of any such directions from the Authority, the Trustee shall invest any such moneys in Permitted Investments which constitute money market funds; provided, however, that any such investment shall be made by the Trustee only if, prior to the date on which such investment is to be made, the Trustee shall have received a Written Request of the Authority specifying a specific money market fund and, if no such Written Request of the Authority is so received, the Trustee shall hold such moneys uninvested. Permitted Investments purchased as an investment of moneys in any fund shall be deemed to be part of such fund or account. To the extent Permitted Investments are registrable, such Permitted Investments must be registered in the name of the Trustee. All interest or gain derived from the investment of amounts in any of the funds or accounts established hereunder shall be deposited in the Bond Fund. For purposes of acquiring any investments hereunder, the Trustee may commingle funds held by it hereunder. The Trustee or any of its affiliates may act as principal or agent in the acquisition or disposition of any investment and may impose its customary charges therefor. The Trustee shall incur no liability for losses arising from any investments made under this Section 5.08. The Trustee may make any investments hereunder through its own bond or investment department or trust investment department, or those of its parent or any affiliate. The Trustee or any of its affiliates may act as sponsor, advisor or manager in connection with any investments made by the Trustee hereunder. The Trustee is hereby authorized, in making or disposing of any investment permitted by this Section, to deal with itself (in its individual capacity) or with any one or more of its affiliates, whether it or such affiliate is acting as an agent of the Trustee or for any third person or is dealing as a principal for its own account. The Trustee shall furnish the Authority periodic cash transaction statements which include detail for all investment transactions effected by the Trustee or brokers selected by the Authority. Upon the Authority's election, such statements will be delivered via the Trustee's Online Trust and Custody service and upon electing such service, paper statements will be provided only upon request. The Authority waives the right to receive brokerage confirmations of security transactions effected by the Trustee as they occur, to the extent permitted by law. The Authority further understands that trade confirmations for securities transactions effected by the Trustee will be available upon request and at no additional cost and other trade confirmations may be obtained from the applicable broker. SECTION 5.09. Valuation and Disposition of Investments. (a) Except as otherwise provided in subsection (b) of this Section, the Authority covenants that all investments of amounts deposited in any fund or account created by or under this Indenture, or otherwise containing gross proceeds of the Bonds (within the meaning of Section 148 of the Tax Code) shall be acquired, disposed of and valued at the Fair Market Value thereof as such term is defined in subsection (d) below. The Trustee -16- shall have no duty in connection with the determination of Fair Market Value other than to follow the investment directions of the Authority in any Written Request of the Authority. (b) Investments in funds or accounts (or portions thereof) that are subject to a yield restriction under applicable provisions of the Tax Code; provided that the Authority shall inform the Trustee in writing which funds are subject to a yield restriction. (c) For the purpose of determining the amount in any fund or account established hereunder, the value of Permitted Investments credited to such fund shall be valued by the Trustee at least annually on or before July 15. The Trustee may sell or present for redemption, any Permitted Investment so purchased by the Trustee whenever it is necessary in order to provide moneys to meet any required payment, transfer, withdrawal or disbursement from the fund to which such Permitted Investment is credited, and the Trustee shall not be liable or responsible for any loss resulting from any such Permitted Investment. (d) For purposes of this Section 5.09, the term "Fair Market Value" means the price at which a willing buyer would purchase the investment from a willing seller in a bona fide, arm's length transaction (determined as of the date the contract to purchase or sell the investment becomes binding) if the investment is traded on an established securities market (within the meaning of Section 1273 of the Tax Code) and, otherwise, the term "Fair Market Value" means the acquisition price in a bona fide arm's length transaction (as referenced above) if (i) the investment is a certificate of deposit that is acquired in accordance with applicable regulations under the Tax Code, (ii) the investment is an agreement with specifically negotiated withdrawal or reinvestment provisions and a specifically negotiated interest rate (for example, a guaranteed investment contract, a forward supply contract or other investment agreement) that is acquired in accordance with applicable regulations under the Tax Code, or (iii) the investment is a United States Treasury Security -- State and Local Government Series which is acquired in accordance with applicable regulations of the United States Bureau of Public Debt. (e) To the extent of any valuations made by the Trustee hereunder, the Trustee may utilize and rely upon computerized securities pricing services that may be available to it, including those available through its regular accounting system. -17- ARTICLE VI COVENANTS OF THE AUTHORITY SECTION 6.01. Punctual Payment. The Authority shall punctually pay or cause to be paid the principal of and interest and premium (if any) on 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 the Revenues and other amounts pledged for such payment as provided in this Indenture. SECTION 6.02. Extension of Payment 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 shall 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 have not been so extended. Nothing in this Section 6.02 limits the right of the Authority to issue Bonds for the purpose of refunding any Outstanding Bonds, and such issuance does not constitute an extension of maturity of the Bonds. SECTION 6.03. Against 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, and reserves the right to issue other obligations for such purposes. SECTION 6.04. Power to Issue Bonds and Make Pledge and Assignment. The Authority is duly authorized under law to issue the Bonds and to enter into this Indenture and to pledge and assign the Revenues and other amounts purported to be pledged and assigned, respectively, under this Indenture and under the Assignment Agreement in the manner and to the extent provided in this Indenture and the Assignment Agreement. The Bonds and 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 and the Trustee shall at all times, subject to the provisions of Article VIII and to the extent permitted by law, defend, preserve and protect said pledge and assignment of Revenues and other assets and all the rights of the Bond Owners under this Indenture against all claims and demands of all persons whomsoever. SECTION 6.05. Accounting Records. The Trustee shall at all times keep, or cause to be kept, proper books of record and account, prepared in accordance with corporate industry standards, in which complete and accurate entries shall be made of all transactions made by it relating to the proceeds of Bonds and all funds and accounts established under this Indenture. The Trustee shall make such books of record and account available for inspection by the Authority and the City, during business hours, upon reasonable notice, and under reasonable circumstances. -18- SECTION 6.06. Limitation on Additional Obligations. The Authority covenants that no additional bonds, notes or other indebtedness shall be issued or incurred which are payable out of the Revenues in whole or in part. SECTION 6.07. Tax Covenants. (a) Private Business Use Limitation. The Authority shall assure that the proceeds of the Bonds are not used in a manner which would cause the Bonds to satisfy the private business tests of Section 141(b) of the Tax Code or the private loan financing test of Section 141(c) of the Tax Code. (b) Federal Guarantee Prohibition. The Authority may not take any action or permit or suffer any action to be taken if the result of the same would be to cause the Bonds to be "federally guaranteed" within the meaning of Section 149(b) of the Tax Code. (c) No Arbitrage. The Authority may not take, or permit or suffer to be taken by the Trustee or otherwise, any action with respect to the proceeds of the Bonds or of any other obligations which, if such action had been reasonably expected to have been taken, or had been deliberately and intentionally taken, on the Closing Date, would have caused the Bonds to be "arbitrage bonds" within the meaning of Section 148(a) of the Tax Code. (d) Maintenance of Tax Exemption. The Authority shall take all actions necessary to assure the exclusion of interest on the Bonds from the gross income of the Owners of the Bonds to the same extent as such interest is permitted to be excluded from gross income under the Tax Code as in effect on the Closing Date. (e) Rebate of Excess Investment Earnings to United States. The Authority shall calculate or cause to be calculated all amounts of excess investment earnings with respect to the Bonds which are required to be rebated to the United States of America under Section 148(f) of the Tax Code, at the times and in the manner required under the Tax Code. The Authority shall pay when due an amount equal to excess investment earnings to the United States of America in such amounts, at such times and in such manner as may be required under the Tax Code, such payments to be made from amounts paid by the City for that purpose under Section 4.5(d) of the Lease. The Authority shall keep or cause to be kept, and retain or cause to be retained for a period of six years following the retirement of the Bonds, records of the determinations made under this subsection (e). (f) Record Retention. The Authority will retain its records of all accounting and monitoring it carries out with respect to the Bonds for at least 3 years after the Bonds mature or are redeemed (whichever is earlier); however, if the Bonds are redeemed and refunded, the Authority will retain its records of accounting and monitoring at least 3 years after the earlier of the maturity or redemption of the obligations that refunded the Bonds. (g) Compliance with Tax Certificate. The Authority will comply with the provisions of the Certificate as to Arbitrage and the Use of Proceeds Certificate with respect to the Bonds, which are incorporated herein as if fully set forth herein. The covenants of this Section will survive payment in full or defeasance of the Bonds. SECTION 6.08. Enforcement of Lease. The Trustee shall promptly collect all amounts (to the extent any such amounts are available for collection) due from the City under the Lease. Subject to the provisions of Article VIII, the Trustee shall enforce, and -19- take all steps, actions and proceedings which the Trustee determines to be reasonably necessary for the enforcement of all of its rights thereunder as assignee of the Authority and for the enforcement of all of the obligations of the City under the Lease. SECTION 6.09. Waiver of Laws. The Authority shall not at any time insist upon or plead in any manner whatsoever, or claim or take the benefit or advantage of, any stay or extension law now or at any time hereafter in force that may affect the covenants and agreements contained in this Indenture or in the Bonds, and all benefit or advantage of any such law or laws is hereby expressly waived by the Authority to the extent permitted by law. SECTION 6.10. Further Assurances. The Authority will make, execute and deliver any and all such further indentures, 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 of the rights and benefits provided in this Indenture. ARTICLE VII EVENTS OF DEFAULT AND REMEDIES SECTION 7.01. Events of Default. The following events constitute Events of Default hereunder: (a) Failure to pay any installment of the principal of any Bonds when due, whether at maturity as therein expressed, by proceedings for redemption, by acceleration, or otherwise. (b) Failure to pay any installment of interest on the Bonds when due. (c) Failure by the Authority to observe and perform any of the other covenants, agreements or conditions on its part contained in this Indenture or in the Bonds, if such failure has continued for a period of 30 days after written notice thereof, specifying such failure and requiring the same to be remedied, has been given to the Authority by the Trustee; provided, however, if in the reasonable opinion of the Authority the failure stated in the notice can be corrected, but not within such 30 -day period, such failure shall not constitute an Event of Default if the Authority institutes corrective action within such 30 - day period and thereafter diligently and in good faith cures the failure in a reasonable period of time. (d) The commencement by the Authority of a voluntary case under Title 11 of the United States Code or any substitute or successor statute. (e) The occurrence and continuation of an event of default under and as defined in the Lease. -20- SECTION 7.02. Remedies Upon Event of Default. If any Event of Default occurs, 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, in each case, upon receipt of indemnification satisfactory to Trustee against the costs, expenses and liabilities to be incurred in connection with such action, upon notice in writing to the Authority, 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 deposits 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 reasonable fees, charges and expenses (including those of its legal counsel, including the allocated costs of internal attorneys) of the Trustee, 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) have been made good or cured to the satisfaction of the Trustee or provision deemed by the Trustee to be adequate has been made therefor, then, and in every such case, the Owners of a majority in aggregate principal amount of the Bonds then Outstanding, by written notice to the Authority, the City and 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. SECTION 7.03. Application of Revenues and Other Funds After Default. If an Event of Default occurs and is continuing, all Revenues and any other funds then held or thereafter received by the Trustee under any of the provisions of this Indenture shall be applied by the Trustee in the following order of priority: (a) To the payment of reasonable fees, charges and expenses of the Trustee (including reasonable fees and disbursements of its legal counsel including outside counsel and the allocated costs of internal attorneys) incurred in and about the performance of its powers and duties under this Indenture; (b) To the payment of the principal of and interest then due on the Bonds (upon presentation of the Bonds to be paid, and stamping or otherwise noting thereon of the payment if only partially paid, or surrender thereof if fully paid) in accordance with the provisions of this Indenture, as follows: First: To the payment to the persons entitled thereto of all installments of interest then due in the order of the maturity of such installments, and, if the amount available shall not be sufficient to pay in full any installment or installments maturing on the same date, then to the payment thereof ratably, according to the -21- amounts due thereon, to the persons entitled thereto, without any discrimination or preference; Second: To the payment to the persons entitled thereto of the unpaid principal of any Bonds which shall have become due, whether at maturity or by acceleration or redemption, with interest on the overdue principal at the rate borne by the respective Bonds (to the extent permitted by law), and, if the amount available shall not be sufficient to pay in full all the Bonds, together with such interest, then to the payment thereof ratably, according to the amounts of principal due on such date to the persons entitled thereto, without any discrimination or preference; and SECTION 7.04. Trustee to Represent Bond Owners. The Trustee is hereby irrevocably appointed (and the successive respective Owners of the Bonds, by taking and holding the same, shall be conclusively deemed to have so appointed the Trustee) as trustee and true and lawful attorney-in-fact of the Owners of the Bonds for the purpose of exercising and prosecuting on their behalf such rights and remedies as may be available to such Owners under the provisions of the Bonds, this Indenture and applicable provisions of any law. All rights of action under this Indenture or the Bonds may be prosecuted and enforced by the Trustee without the possession of any of the Bonds or the production thereof in any proceeding relating thereto, and any such suit, action or proceeding instituted by the Trustee shall be brought in the name of the Trustee for the benefit and protection of all the Owners of such Bonds, subject to the provisions of this Indenture. SECTION 7.05. Limitation on Bond Owners' Right to Sue. Notwithstanding any other provision hereof, no Owner of any Bonds has the right to institute any suit, action or proceeding at law or in equity, for the protection or enforcement of any right or remedy under this Indenture, the Lease or any other applicable law with respect to such Bonds, unless (a) such Owner has given to the Trustee written notice of the occurrence of an Event of Default; (b) the Owners of a majority in aggregate principal amount of the Bonds then Outstanding have requested the Trustee in writing to exercise the powers hereinbefore granted or to institute such suit, action or proceeding in its own name; (c) such Owner or Owners have tendered to the Trustee reasonable indemnity against the costs, expenses and liabilities to be incurred in compliance with such request; (d) the Trustee has failed to comply with such request for a period of 60 days after such written request has been received by, and said tender of indemnity has been made to, the Trustee; and (e) no direction inconsistent with such written request has been given to the Trustee during such 60 day period by the Owners of a majority in aggregate principal amount of the Bonds then Outstanding. 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 Bonds of any remedy hereunder or under law; it being understood and intended that no one or more Owners of Bonds shall have any right in any manner whatever by his or their action to affect, disturb or prejudice the security of this Indenture or the rights of any other Owners of Bonds, or to enforce any right under the Bonds, this Indenture, the Lease or other applicable law with respect to the Bonds, except in the manner herein provided, and that all proceedings at law or in equity to enforce any such right shall be instituted, had and -22- maintained in the manner herein provided and for the benefit and protection of all Owners of the Outstanding Bonds, subject to the provisions of this Indenture. SECTION 7.06. Absolute Obligation of Authority. Nothing herein or in the Bonds contained affects or impairs the obligation of the Authority, which is absolute and unconditional, to pay the principal of and interest and premium (if any) on the Bonds to the respective Owners of the Bonds at their respective dates of maturity, or upon acceleration or call for redemption, as herein provided, but only out of the Revenues and other assets herein pledged therefor, or affect or impair the right of such Owners, which is also absolute and unconditional, to enforce such payment by virtue of the contract embodied in the Bonds. SECTION 7.07. Termination of Proceedings. In case any proceedings taken by the Trustee or by any one or more Bond Owners on account of any Event of Default have been discontinued or abandoned for any reason or have been determined adversely to the Trustee or the Bond Owners, then in every such case the Authority, the Trustee and the Bond Owners, subject to any determination in such proceedings, shall be restored to their former positions and rights hereunder, severally and respectively, and all rights, remedies, powers and duties of the Authority, the Trustee and the Bond Owners shall continue as though no such proceedings had been taken. SECTION 7.08. Remedies Not Exclusive. No remedy herein conferred upon or reserved to the Trustee, to the Owners of the Bonds is intended to be exclusive of any other remedy or remedies, and each and every such remedy, to the extent permitted by law, shall be cumulative and in addition to any other remedy given hereunder or now or hereafter existing at law or in equity or otherwise. SECTION 7.09. No Waiver of Default. No delay or omission of the Trustee or any Owner of the Bonds to exercise any right or power arising upon the occurrence of any default or Event of Default shall impair any such right or power or shall be construed to be a waiver of any such default or Event of Default or an acquiescence therein; and every power and remedy given by this Indenture to the Trustee or to the Owners of the Bonds may be exercised from time to time and as often as may be deemed expedient by the Trustee or the Bond Owners. SECTION 7.10. Notice to Bond Owners of Default. Immediately upon becoming aware of the occurrence of an Event of Default, but in no event later than five Business Days following becoming aware of such occurrence, the Trustee shall promptly give written notice thereof by first class mail, postage prepaid, to the Owner of each Outstanding Bond, unless such Event of Default has been cured before the giving of such notice; provided, however that except in the case of an Event of Default described in Sections 7.01(a) or 7.01(b), the Trustee may elect not to give such notice to the Bond Owners if and so long as the Trustee in good faith determines that it is in the best interests of the Bond Owners not to give such notice. -23- ARTICLE VIII THE TRUSTEE SECTION 8.01. Appointment of Trustee. U.S. Bank Trust Company, National Association is hereby appointed Trustee by the Authority for the purpose of receiving all moneys required to be deposited with the Trustee hereunder and to allocate, use and apply the same as provided in this Indenture. The Authority will maintain a Trustee which is qualified under the provisions of the foregoing provisions of this Article VIII, so long as any Bonds are Outstanding. SECTION 8.02. Acceptance of Trusts; Removal and Resignation of Trustee. The Trustee hereby accepts the express 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 shall, prior to an Event of Default, and after the curing or waiver of all Events of Default which may have occurred, perform such duties and only such duties as are expressly and specifically set forth in this Indenture and no implied duties or covenants shall be read into this Indenture against the Trustee. If an Event of Default has occurred (which has not been cured), the Trustee shall exercise such of the rights and powers vested in it by hereunder, and use the same degree of care and skill in their exercise, as a prudent man would exercise or use under the circumstances in the conduct of his own affairs. (b) The Authority may remove the Trustee at any time, unless an Event of Default has occurred and is then continuing, and shall remove the Trustee (a) if at any time requested to do so by the Owners of a majority in aggregate principal amount of the Bonds then Outstanding (or their attorneys duly authorized in writing) or (b) if at any time the Trustee ceases to be eligible in accordance with Section 8.02, or becomes incapable of acting, or is adjudged a bankrupt or insolvent, or a receiver of the Trustee or its property is appointed, or any public officer takes control or charge of the Trustee or of its property or affairs for the purpose of rehabilitation, conservation or liquidation. (c) The Trustee may at any time resign by giving written notice of such resignation to the Authority and the City, and by giving the Bond Owners notice of such resignation by mail at the addresses shown on the Registration Books. (d) Any removal or resignation of the Trustee and appointment of a successor Trustee shall become effective upon acceptance of appointment by the successor Trustee. In the event of the removal or resignation of the Trustee under subsections (b) or (d), respectively, the Authority shall promptly appoint a successor Trustee. -24- If no successor Trustee has been appointed and accepted appointment within 45 days of giving notice of removal or notice of resignation as aforesaid, the resigning Trustee may petition any court of competent jurisdiction for the appointment of a successor Trustee, and such court may thereupon, after such notice (if any) as it may deem proper, appoint such successor Trustee. Any successor Trustee appointed under this Indenture, must signify its acceptance of such appointment by executing and delivering to the Authority, to its predecessor Trustee a written acceptance thereof, and after payment by the Authority of all unpaid fees and expenses of the predecessor Trustee, and thereupon such successor Trustee, without any further act, deed or conveyance, shall become vested with all the moneys, estates, properties, rights, powers, trusts, duties and obligations of such predecessor Trustee, with like effect as if originally named Trustee herein; but, nevertheless at the Written Request of the Authority or the request of the successor Trustee, such predecessor Trustee shall execute and deliver any and all instruments of conveyance or further assurance and do such other things as may reasonably be required for more fully and certainly vesting in and confirming to such successor Trustee all the right, title and interest of such predecessor Trustee in and to the Leased Property held by such predecessor Trustee under this Indenture and shall pay over, transfer, assign and deliver to the successor Trustee any money or other property subject to the trusts and conditions herein set forth. Upon request of the successor Trustee, the Authority shall execute and deliver any and all instruments as may be reasonably required for more fully and certainly vesting in and confirming to such successor Trustee all such moneys, estates, properties, rights, powers, trusts, duties and obligations. Upon acceptance of appointment by a successor Trustee as provided in this subsection, the Authority shall promptly mail or cause the successor trustee to mail a notice of the succession of such Trustee to the trusts hereunder to each rating agency which is then rating the Bonds and to the Bond Owners at the addresses shown on the Registration Books. If the Authority fails to mail such notice within 15 days after acceptance of appointment by the successor Trustee, the successor Trustee shall cause such notice to be mailed at the expense of the Authority. (e) Any Trustee appointed under this Indenture shall be a corporation or association organized and doing business under the laws of any state or the United States of America or the District of Columbia, shall be authorized under such laws to exercise corporate trust powers, shall have (or, in the case of a corporation or association that is a member of a bank holding company system, the related bank holding company has) a combined capital and surplus of at least $50,000,000, and shall be subject to supervision or examination by a federal or state agency, so long as any Bonds are Outstanding. If such corporation or association publishes a report of condition at least annually under law or to the requirements of any supervising or examining agency above referred to, then for the purpose of this -25- subsection (e), the combined capital and surplus of such corporation or association shall be deemed to be its combined capital and surplus as set forth in its most recent report of condition so published. If the Trustee at any time ceases to be eligible in accordance with the provisions of this subsection (e), the Trustee shall resign immediately in the manner and with the effect specified in this Section. SECTION 8.03. Merger or Consolidation. Any bank, national banking association, federal savings association, or trust company into which the Trustee may be merged or converted or with which it may be consolidated or any bank, national banking association, federal savings association, or trust company resulting from any merger, conversion or consolidation to which it shall be a party or any bank, national banking association, federal savings association, or trust company to which the Trustee may sell or transfer all or substantially all of its corporate trust business, provided such bank, national banking association, federal savings association, or trust company shall be eligible under subsection (e) of Section 8.02 shall be the successor to such Trustee, without the execution or filing of any paper or any further act, anything herein to the contrary notwithstanding. SECTION 8.04. Liability of Trustee. (a) The recitals of facts herein and in the Bonds contained shall be taken as statements of the Authority, and the Trustee shall not assume responsibility for the correctness of the same, or make any representations as to the validity or sufficiency of this Indenture, the Bonds or the Lease (including any right to receive moneys thereunder or the value of or title to the premises upon which the Leased Property is located), nor shall the Trustee incur any responsibility in respect thereof, other than as expressly stated herein in connection with the respective duties or obligations of Trustee herein or in the Bonds assigned to or imposed upon it. The Trustee shall, however, be responsible for its representations contained in its certificate of authentication on the Bonds. The Trustee shall not be liable in connection with the performance of its duties hereunder, except for its own negligence. The Trustee may become the Owner of Bonds with the same rights it would have if it were not Trustee, and, to the extent permitted by law, may act as depository 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 Bond Owners, whether or not such committee shall represent the Owners of a majority in principal amount of the Bonds then Outstanding. (b) The Trustee is not liable for any error of judgment made by a responsible officer, unless it is proved that the Trustee was negligent in ascertaining the pertinent facts. (c) The Trustee is not liable with respect to any action taken or omitted to be taken by it in accordance with the direction of the Owners of a majority in aggregate principal amount of the Bonds at the time Outstanding relating to the time, method and place of conducting any proceeding for any remedy available to the Trustee, or exercising any trust or power conferred upon the Trustee under this Indenture or assigned to it under the Assignment Agreement. (d) The Trustee is not liable for any action taken by it and believed by it to be authorized or within the discretion or rights or powers conferred upon it by this Indenture. -26- (e) The Trustee shall not be deemed to have knowledge of any Event of Default hereunder, or any other event which, with the passage of time, the giving of notice, or both, would constitute an Event of Default hereunder unless and until it shall have actual knowledge thereof, or a corporate trust officer shall have received written notice thereof at its Office from the City, the Authority or the Owners of at least 25% in aggregate principal amount of the Outstanding Bonds. Except as otherwise expressly provided herein, the Trustee shall not be bound to ascertain or inquire as to the performance or observance by the Authority or the City of any of the terms, conditions, covenants or agreements herein, under the Lease or the Bonds or of any of the documents executed in connection with the Bonds, or as to the existence of a default or an Event of Default or an event which would, with the giving of notice, the passage of time, or both, constitute an Event of Default. The Trustee is not responsible for the validity, effectiveness or priority of any collateral given to or held by it. Without limiting the generality of the foregoing, the Trustee shall not be required to ascertain or inquire as to the performance or observance by the City or the Authority of the terms, conditions, covenants or agreements set forth in the Lease, other than the covenants of the City to make Lease Payments to the Trustee when due and to file with the Trustee when due, such reports and certifications as the City is required to file with the Trustee thereunder. (f) No provision of this Indenture requires the Trustee to expend or risk its own funds or otherwise incur any financial liability in the performance of any of its duties hereunder, or in the exercise of any of its rights or powers. (g) The Trustee may execute any of the trusts or powers hereunder or perform any duties hereunder either directly or through agents, receivers or attorneys and the Trustee shall not be responsible for any misconduct or negligence on the part of any agent, receiver or attorney appointed with due care by it hereunder. (h) The Trustee has no obligation to exercise any of the rights or powers vested in it by this Indenture at the request or direction of the Bond Owners under this Indenture, unless such Owners have offered to the Trustee reasonable security or indemnity against the costs, expenses and liabilities (including but not limited to fees and expenses of its attorneys) which might be incurred by it in compliance with such request or direction. No permissive power, right or remedy conferred upon the Trustee hereunder shall be construed to impose a duty to exercise such power, right or remedy. (i) Whether or not therein expressly so provided, every provision of this Indenture relating to the conduct or affecting the liability of or affording protection to the Trustee is subject to the provisions of Section 8.02(a), this Section 8.04 and Section 8.05, and shall be applicable to the assignment of any rights under the Lease to the Trustee under the Assignment Agreement. (j) The Trustee is not accountable to anyone for the subsequent use or application of any moneys which are released or withdrawn in accordance with the provisions hereof. (k) The Trustee makes no representation or warranty, expressed or implied as to the title, value, design, compliance with specifications or legal requirements, quality, durability, operation, condition, merchantability or fitness for any particular purpose for the use contemplated by the Authority or the City of the Leased Property. In no event shall the Trustee be liable for incidental, indirect, special or consequential damages in -27- connection with or arising from the Lease or this Indenture for the existence, furnishing or use of the Leased Property. (1) The Trustee has 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 Bonds. (m) The Trustee is authorized and directed to execute the Assignment Agreement in its capacity as Trustee hereunder. (n) The Trustee agrees to accept and act upon instructions or directions pursuant to this Indenture sent by unsecured e-mail (provided, that for purposes of this Agreement, an e-mail does not constitute a notice, request or other communication hereunder but rather the portable document format or similar attachment attached to such e-mail shall constitute a notice, request or other communication hereunder), facsimile transmission or other similar unsecured electronic methods, provided, however, that, the Trustee shall have received an incumbency certificate listing persons designated to give such instructions or directions and containing specimen signatures of such designated persons, which such incumbency certificate shall be amended and replaced whenever a person is to be added or deleted from the listing. If the Authority or the City elects to give the Trustee e-mail or facsimile instructions (or instructions by a similar electronic method) and the Trustee in its discretion elects to act upon such instructions, the Trustee's understanding of such instructions shall be deemed controlling. The Trustee shall not be liable for any losses, costs or expenses arising directly or indirectly from the Trustee's reliance upon and compliance with such instructions notwithstanding such instructions conflict or are inconsistent with a subsequent written instruction. The Authority and the City agree to assume all risks arising out of the use of such electronic methods to submit instructions and directions to the Trustee, including without limitation the risk of the Trustee acting on unauthorized instructions, and the risk of interception and misuse by third parties. (o) The Trustee shall not be liable to the parties hereto or deemed in breach or default hereunder if and to the extent its performance hereunder is prevented by reason of force majeure. The term "force majeure" means an occurrence that is beyond the control of the Trustee and could not have been avoided by exercising due care. Force majeure shall include, but not be limited to, acts of God, terrorism, war, riots, strikes, fire, floods, earthquakes, epidemics or other similar occurrences. SECTION 8.05. Right to Rely on Documents. The Trustee shall be protected and shall incur no liability in acting or refraining from acting in reliance upon any notice, resolution, request, consent, order, certificate, report, opinion, bonds or other paper or document believed by them to be genuine and to have been signed or presented by the proper party or parties. The Trustee is under no duty to make any investigation or inquiry as to any statements contained or matter referred to in any paper or document but may accept and conclusively rely upon the same as conclusive evidence of the truth and accuracy of any such statement or matter and shall be fully protected in relying thereon. The Trustee may consult with counsel, who may be counsel of or to the Authority, with regard to legal questions, and the opinion of such counsel shall be full and complete authorization and protection in respect of any action taken or suffered by it hereunder in good faith and in accordance therewith. -28- The Trustee may treat the Owners of the Bonds appearing in the Registration Books as the absolute owners of the Bonds for all purposes and the Trustee shall not be affected by any notice to the contrary. Whenever in the administration of the trusts imposed upon it by this Indenture the Trustee deems it necessary or desirable that a matter be proved or established prior to taking or suffering any action hereunder, such matter (unless other evidence in respect thereof be herein specifically prescribed) may be deemed to be conclusively proved and established by a Written Certificate, Written Request or Written Requisition of the Authority or the City, and such Written Certificate, Written Request or Written Requisition shall be full warrant to the Trustee for any action taken or suffered under the provisions of this Indenture in reliance upon such Written Certificate, Written Request or Written Requisition, and the Trustee shall be fully protected in relying thereon, but in its discretion the Trustee may, in lieu thereof, accept other evidence of such matter or may require such additional evidence as to it may deem reasonable. SECTION 8.06. Preservation and Inspection of Documents. All documents received by the Trustee under the provisions of this Indenture shall be retained in its respective possession and in accordance with its retention policy then in effect and shall, upon reasonable notice to Trustee, be subject to the inspection of the Authority, the City and any Bond Owner, and their agents and representatives duly authorized in writing, during business hours and under reasonable conditions as agreed to by the Trustee. SECTION 8.07. Compensation and Indemnification. The Authority shall pay to the Trustee from time to time, on demand, the compensation for all services rendered under this Indenture and also all reasonable expenses, advances (including any interest on advances), charges, legal (including outside counsel and the allocated costs of internal attorneys) and consulting fees and other disbursements, incurred in and about the performance of its powers and duties under this Indenture. The Authority shall indemnify the Trustee, its officers, directors, employees and agents against any cost, loss, liability or expense whatsoever (including but not limited to fees and expenses of its attorneys) incurred without negligence or willful misconduct on its part, arising out of or in connection with the acceptance or administration of this trust and this Indenture, including costs and expenses of defending itself against any claim or liability in connection with the exercise or performance of any of its powers hereunder or under the Assignment Agreement or the Lease. As security for the performance of the obligations of the Authority under this Section 8.07 and the obligation of the Authority to make Additional Rental Payments to the Trustee, the Trustee shall have a lien prior to the lien of the Bonds upon all property and funds held or collected by the Trustee as such. The rights of the Trustee and the obligations of the Authority under this Section 8.07 shall survive the resignation or removal of the Trustee or the discharge of the Bonds and this Indenture and the Lease. -29- ARTICLE IX MODIFICATION OR AMENDMENT HEREOF SECTION 9.01. Amendments Permitted. (a) Amendments With Bond Owner Consent. This 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 by Supplemental Indenture, which the Authority and the Trustee may enter into when the written consents of the Owners of a majority in aggregate principal amount of all Bonds then Outstanding are filed with the Trustee. No such modification or amendment may (i) extend the fixed maturity of any Bonds, or reduce the amount of principal thereof or extend the time of payment, or change the method of computing the rate of interest thereon, or extend the time of payment of interest thereon, without the consent of the Owner of each Bond so affected, or (ii) reduce the aforesaid percentage of Bonds the consent of the Owners of which is required to effect any such modification or amendment, or permit the creation of any lien on the Revenues and other assets pledged under this Indenture prior to or on a parity with the lien created by this Indenture except as permitted herein, or deprive the Owners of the Bonds of the lien created by this Indenture on such Revenues and other assets (except as expressly provided in this Indenture), without the consent of the Owners of all of the Bonds then Outstanding. It is not necessary for the consent of the Bond Owners to approve the particular form of any Supplemental Indenture, but it is sufficient if such consent approves the substance thereof. (b) Amendments Without Owner Consent. This Indenture and the rights and obligations of the Authority, of the Trustee and the Owners of the Bonds may also be modified or amended from time to time and at any time by a Supplemental Indenture, which the Authority and the Trustee may enter into without the consent of any Bond Owners, if the Trustee has been furnished an opinion of counsel that the provisions of such Supplemental Indenture shall not materially adversely affect the interests of the Owners of the Bonds, including, without limitation, for any one or more of the following purposes: (i) to add to the covenants and agreements of the Authority in this Indenture contained, other covenants and agreements thereafter to be observed, to pledge or assign additional security for the Bonds (or any portion thereof), or to surrender any right or power herein reserved to or conferred upon the Authority; (ii) to cure any ambiguity, inconsistency or omission, or to cure or correct any defective provision, contained in this Indenture, or in regard to matters or questions arising under this Indenture, as the Authority deems necessary or desirable, provided that such modification or amendment does not materially adversely affect the interests of the Bond Owners, in the opinion of Bond Counsel filed with the Trustee; (iii) to modify, amend or supplement this Indenture in such manner as to permit the qualification hereof under the Trust Indenture Act of 1939, as amended, or any similar federal statute hereafter in effect, and to -30- add such other terms, conditions and provisions as may be permitted by said act or similar federal statute; (iv) to modify, amend or supplement this Indenture in such manner as to assure that the interest on the Bonds remains excluded from gross income under the Tax Code; or (v) to facilitate the issuance of additional obligations of the City under the Lease Agreement as provided in Section 7.5(b)(5) thereof. (c) Limitation. The Trustee is not obligated to enter into any Supplemental Indenture authorized by subsections (a) or (b) of this Section 9.01 which materially adversely affects the Trustee's own rights, duties or immunities under this Indenture or otherwise. (d) Bond Counsel Opinion Requirement. Prior to the Trustee entering into any Supplemental Indenture hereunder, the Authority shall deliver to the Trustee an opinion of Bond Counsel stating, in substance, that such Supplemental Indenture has been adopted in compliance with the requirements of this Indenture and that the adoption of such Supplemental Indenture will not, in and of itself, adversely affect the exclusion from gross income for purposes of federal income taxes of interest on the Bonds. (e) Notice of Amendments. The Authority shall deliver or cause to be delivered a draft of any Supplemental Indenture to each rating agency which then maintains a rating on the Bonds, at least 10 days prior to the effective date of such Supplemental Indenture under this Section 9.01. SECTION 9.02. Effect of Supplemental Indenture. Upon the execution of any Supplemental Indenture under this Article IX, this Indenture shall be deemed to be modified and amended in accordance therewith, and the respective rights, duties and obligations under this Indenture of the Authority, the Trustee and all Owners of Bonds Outstanding 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 such Supplemental Indenture shall be deemed to be part of the terms and conditions of this Indenture for any and all purposes. SECTION 9.03. Endorsement of Bonds; Preparation of New Bonds. Bonds delivered after the execution of any Supplemental Indenture under this Article may, and if the Authority so determines shall, bear a notation by endorsement or otherwise in form approved by the Authority as to any modification or amendment provided for in such Supplemental Indenture, and, in that case, upon demand on the Owner of any Bonds Outstanding at the time of such execution and presentation of his Bonds for the purpose at the Office of the Trustee or at such additional offices as the Trustee may select and designate for that purpose, a suitable notation shall be made on such Bonds. If the Supplemental Indenture shall so provide, new Bonds so modified as to conform, in the opinion of the Authority, to any modification or amendment contained in such Supplemental Indenture, shall be prepared and executed by the Authority and authenticated by the Trustee, and upon demand on the Owners of any Bonds then Outstanding shall be exchanged at the Office of the Trustee, without cost to any Bond Owner, for Bonds then Outstanding, upon surrender for cancellation of such Bonds, in equal aggregate principal amount of the same maturity. -31- SECTION 9.04. Amendment of Particular Bonds. The provisions of this Article IX do not prevent any Bond Owner from accepting any amendment as to the particular Bonds held by such Owner. ARTICLE X DEFEASANCE SECTION 10.01. Discharge of Indenture. Any or all of the Outstanding Bonds may be paid by the Authority in any of the following ways, provided that the Authority also pays or causes to be paid any other sums payable hereunder by the Authority: (a) by 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 depositing with the Trustee, in trust, at or before maturity, money or securities in the necessary amount (as provided in Section 10.03) to pay or redeem such Bonds; or (c) by delivering all of such Bonds to the Trustee for cancellation. If the Authority also pays or causes to be paid all other sums payable hereunder by the Authority, then and in that case, at the election of the Authority (evidenced by a Written Certificate of the Authority, filed with the Trustee, signifying the intention of the Authority to discharge all such indebtedness and this Indenture), and notwithstanding that any of such Bonds shall not have been surrendered for payment, this Indenture and the pledge of Revenues and other assets made under this Indenture with respect to such Bonds and all covenants, agreements and other obligations of the Authority under this Indenture with respect to such Bonds shall cease, terminate, become void and be completely discharged and satisfied, subject to Section 10.02. In such event, upon the Written Request of the Authority, the Trustee shall execute and deliver to the Authority all such instruments as may be necessary or desirable to evidence such discharge and satisfaction, and the Trustee shall pay over, transfer, assign or deliver to the City all moneys or securities or other property held by it under this Indenture which are not required for the payment or redemption of any of such Bonds not theretofore surrendered for such payment or redemption. The Trustee is entitled to conclusively rely on any such Written Certificate or Written Request and, in each case, is fully protected in relying thereon. SECTION 10.02. Discharge of Liability on Bonds. Upon the deposit with the Trustee, in trust, at or before maturity, of money or securities in the necessary amount (as provided in Section 10.03) to pay or redeem any Outstanding Bonds (whether upon or prior to the maturity or the redemption date of such Bonds), provided that, if such Bonds are to be redeemed prior to maturity, notice of such redemption shall have been given as provided in Article IV or provision satisfactory to the Trustee shall have been made for the giving of such notice, then all liability of the Authority in respect of such Bonds shall cease, terminate and be completely discharged, and the Owners thereof shall thereafter be -32- entitled only to payment out of such money or securities deposited with the Trustee as aforesaid for their payment, subject, however, to the provisions of Section 10.04. The Authority may at any time surrender to the Trustee, for cancellation by the Trustee, any Bonds previously issued and delivered, which the Authority may have acquired in any manner whatsoever, and such Bonds, upon such surrender and cancellation, shall be deemed to be paid and retired. SECTION 10.03. Deposit of Money or Securities with Trustee. Whenever in this Indenture it is provided or permitted that there be deposited with or held in trust by the Trustee money or securities in the necessary amount to pay or redeem any Bonds, the money or securities so to be deposited or held may include money or securities held by the Trustee in the funds and accounts established under this Indenture and shall be: (a) lawful money of the United States of America in an amount equal to the principal amount of such Bonds and all unpaid interest thereon to maturity, except that, in the case of Bonds which are to be redeemed prior to maturity and in respect of which notice of such redemption shall have been given as provided in Article IV or provision satisfactory to the Trustee shall have been made for the giving of such notice, the amount to be deposited or held shall be the principal amount of such Bonds, premium, if any, and all unpaid interest thereon to the redemption date; or (b) non -callable Federal Securities, the principal of and interest on which when due will, in the written opinion of an Independent Accountant filed with the City, the Authority and the Trustee, provide money sufficient to pay the principal of and interest and premium (if any) on the Bonds to be paid or redeemed, as such principal, interest and premium become due, provided that in the case of Bonds which are to be redeemed prior to the maturity thereof, notice of such redemption shall have been given as provided in Article IV or provision satisfactory to the Trustee has been made for the giving of such notice; provided, in each case, that (i) the Trustee shall have been irrevocably instructed (by the terms of this Indenture or by Written Request of the Authority) to apply such money to the payment of such principal, interest and premium (if any) with respect to such Bonds, and (ii) the Authority shall have delivered to the Trustee an opinion of Bond Counsel to the effect that such Bonds have been discharged in accordance with this Indenture (which opinion may rely upon and assume the accuracy of the Independent Accountant's opinion referred to above). The Trustee shall be entitled to conclusively rely on such Written Request or opinion and shall be fully protected, in each case, in relying thereon. SECTION 10.04. Unclaimed Funds. Notwithstanding any provisions of this Indenture, any moneys held by the Trustee in trust for the payment of the principal of, or interest on, any Bonds and remaining unclaimed for 2 years after the principal of all of the Bonds has become due and payable (whether at maturity or upon call for redemption or by acceleration as provided in this Indenture), if such moneys were so held at such date, or 2 years after the date of deposit of such moneys if deposited after said date when all of the Bonds became due and payable, shall be repaid to the Authority free from the trusts -33- created by this Indenture, and all liability of the Trustee with respect to such moneys shall thereupon cease; provided, however, that before the repayment of such moneys to the Authority as aforesaid, the Trustee shall (at the cost of the Authority) first mail to the Owners of Bonds which have not yet been paid, at the addresses shown on the Registration Books, a notice, in such form as may be deemed appropriate by the Trustee with respect to the Bonds so payable and not presented and with respect to the provisions relating to the repayment to the Authority of the moneys held for the payment thereof. ARTICLE XI MISCELLANEOUS SECTION 11.01. Liability of Authority Limited to Revenues. Notwithstanding anything in this Indenture or in the Bonds contained, the Authority is not required to advance any moneys derived from any source other than the Revenues, the Additional Rental Payments and other assets pledged under this Indenture for any of the purposes in this Indenture mentioned, whether for the payment of the principal of or interest on the Bonds or for any other purpose of this Indenture. Nevertheless, the Authority may, but is not required to, advance for any of the purposes hereof any funds of the Authority which may be made available to it for such purposes. SECTION 11.02. Limitation of Rights to Parties and Bond Owners. Nothing in this Indenture or in the Bonds expressed or implied is intended or shall be construed to give to any person other than the Authority, the Trustee, the City and the Owners of the Bonds, any legal or equitable right, remedy or claim under or in respect of this Indenture or any covenant, condition or provision therein or herein contained; and all such covenants, conditions and provisions are and shall be held to be for the sole and exclusive benefit of the Authority, the Trustee, the City and the Owners of the Bonds. SECTION 11.03. Funds and Accounts. Any fund or account required by this Indenture to be established and maintained by the Trustee may be established and maintained in the accounting records of the Trustee, either as a fund or an account, and may, for the purposes of such records, any audits thereof and any reports or statements with respect thereto, be treated either as a fund or as an account; but all such records with respect to all such funds and accounts shall at all times be maintained in accordance with corporate industry standards to the extent practicable, and with due regard for the requirements of Section 6.05 and for the protection of the security of the Bonds and the rights of every Owner thereof. The Trustee may establish such funds and accounts as it deems necessary or appropriate to perform its obligations under this Indenture. SECTION 11.04. Waiver of Notice; Requirement of Mailed Notice. Whenever in this Indenture the giving of notice by mail or otherwise is required, the giving of such notice may be waived in writing by the person entitled to receive such notice and in any such case the giving or receipt of such notice shall not be a condition precedent to the validity of any action taken in reliance upon such waiver. Whenever in this Indenture any notice is required to be given by mail, such requirement may be satisfied by the deposit of such notice in the United States mail, postage prepaid, by first class mail. -34- SECTION 11.05. Destruction of Bonds. Whenever in this Indenture provision is made for the cancellation by the Trustee, and the delivery to the Authority, of any Bonds, the Trustee shall destroy such Bonds as may be allowed by law and deliver a certificate of such destruction to the Authority. SECTION 11.06. Severability of Invalid Provisions. If any one or more of the provisions contained in this Indenture or in the Bonds shall for any reason be held to be invalid, illegal or unenforceable in any respect, then such provision or provisions shall be deemed severable from the remaining provisions contained in this Indenture and such invalidity, illegality or unenforceability shall not affect any other provision of this Indenture, and this Indenture shall be construed as if such invalid or illegal or unenforceable provision had never been contained herein. The Authority hereby declares that it would have entered into this Indenture and each and every other Section, paragraph, sentence, clause or phrase hereof and authorized the issuance of the Bonds pursuant thereto irrespective of the fact that any one or more Sections, paragraphs, sentences, clauses or phrases of this Indenture may be held illegal, invalid or unenforceable. SECTION 11.07. Notices. All notices or communications to be given 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 at such address as the party may provide to the other party in writing from time to time. Notice shall be effective either (a) upon transmission by facsimile transmission or other form of telecommunication, confirmed by telephone, (b) 48 hours after deposit in the United States mail, postage prepaid, or (c) in the case of personal delivery to any person, upon actual receipt. The Authority, the City 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 City of Lodi or the City: 221 West Pine Street Lodi, CA 95240 Attention: City Manager Fax: (209) 333-6807 If to the Trustee: U.S. Bank Trust Company, National Association Attn.: Global Corporate Trust One California Street, Suite 1000 San Francisco, CA 94111 Fax: 415-677-3768 SECTION 11.08. Evidence of Rights of Bond Owners. Any request, consent or other instrument required or permitted by this Indenture to be signed and executed by Bond Owners may be in any number of concurrent instruments of substantially similar tenor and shall be signed or executed by such Bond Owners in person or by an 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, or of the holding by any person of Bonds transferable by delivery, shall be sufficient for any purpose of this Indenture and shall be conclusive in favor of the Trustee and the Authority if made in the manner provided in this Section 11.08. 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 certificate of any notary public or other -35- 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 acknowledged to him the execution thereof, or by an affidavit of a witness of such execution duly sworn to before such notary public or other officer. The ownership of Bonds shall be proved by the Registration Books. Any request, consent, or other instrument or writing of the Owner of any Bond shall bind every future Owner of the same Bond and the Owner of every 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 accordance therewith or reliance thereon. SECTION 11.09. Disqualified 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 known by the Trustee to be owned or held by or for the account of the Authority or the City, or by any other obligor on the Bonds, or by any person directly or indirectly controlling or controlled by, or under direct or indirect common control with, the Authority or the City or any other obligor on the Bonds, shall be disregarded and deemed not to be Outstanding for the purpose of any such determination. Bonds so owned which have been pledged in good faith may be regarded as Outstanding for the purposes of this Section if the pledgee shall establish to the satisfaction of the Trustee the pledgee's right to vote such Bonds and that the pledgee is not a person directly or indirectly controlling or controlled by, or under direct or indirect common control with, the Authority or the City or any other obligor on the Bonds. In case of a dispute as to such right, the Trustee shall be entitled to rely upon the advice of counsel in any decision by Trustee and shall be fully protected in relying thereon. Upon request, the Authority shall certify to the Trustee those Bonds disqualified under this Section 11.09, and the Trustee may conclusively rely on such certifications. SECTION 11.10. Money Held for Particular Bonds. The money held by the Trustee for the payment of the interest, premium, if any, or principal due on any date with respect to particular Bonds (or portions of Bonds in the case of Bonds redeemed in part only) shall, on and after such date and pending such payment, be set aside on its books and held in trust by it for the Owners of the Bonds entitled thereto, subject, however, to the provisions of Section 10.04 but without any liability for interest thereon. SECTION 11.11. Waiver of Personal Liability. No member, officer, agent or employee of the Authority shall be individually or personally liable for the payment of the principal of or interest or premium (if any) on the Bonds or be subject to any personal liability or accountability by reason of the issuance thereof; but nothing herein contained shall relieve any such member, officer, agent or employee from the performance of any official duty provided by law or by this Indenture. SECTION 11.12. Successor Is Deemed Included in All References to Predecessor. Whenever in this Indenture either the Authority, the City or the Trustee 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 Indenture contained by or on behalf of the Authority, the City or the Trustee shall bind and inure to the benefit of the respective successors and assigns thereof whether so expressed or not. -36- SECTION 11.13. Execution in Several Counterparts. This Indenture may be executed in any number of counterparts and each of such counterparts shall for all purposes be deemed to be an original; and all such counterparts, or as many of them as the Authority and the Trustee shall preserve undestroyed, shall together constitute but one and the same instrument. SECTION 11.14. Payment on Non -Business Day. In the event any payment is required to be made hereunder on a day which is not a Business Day, such payment shall be made on the next succeeding Business Day and with the same effect as if made on such preceding non -Business Day. SECTION 11.15. Governing Law. This Indenture shall be governed by and construed in accordance with the laws of the State of California. -37- IN WITNESS WHEREOF, the LOBI PUBLIC FINANCING AUTHORITY has caused this Indenture to be signed in its name by its Executive Director and attested to by its Secretary, and U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, In token of Its acceptance of the trusts created hereunder, has caused this Indenture to be signed in its corporate name by its officer thereunto duly authorized, all as of the day and year first above written. Attest: Secretary LODI PUBLIC FINANCING AUTHORITY By Executive Director U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, as Trustee M -38- Authorized Officer APPENDIX A DEFINITIONS "Additional Rental Payments" means the amounts of additional rental which are payable by the City under Section 4.5 of the Lease or which are otherwise identified as Additional Rental Payments under the Lease. "Assignment Agreement" means the Assignment Agreement dated as of March 1, 2022, between the Authority as assignor and the Trustee as assignee, as originally executed or as thereafter amended. "Authority" means the Lodi Public Financing Authority, a joint exercise of powers authority duly organized and existing under the laws of the State of California. "Authorized Representative" means: (a) with respect to the Authority, its Chair, Executive Director, Treasurer, General Counsel or any other person designated as an Authorized Representative of the Authority by a Written Certificate of the Authority signed by its Executive Director and filed with the City and the Trustee; and (b) with respect to the City, its City Manager, Deputy City Manager, City Attorney or any other person designated as an Authorized Representative of the City by a Written Certificate of the City signed by its City Manager and filed with the Authority and the Trustee. "Bond Counsel" means (a) Jones Hall, A Professional Law Corporation, or (b) any other attorney or firm of attorneys appointed by or acceptable to the Authority of nationally - recognized experience in the issuance of obligations the interest on which is excludable from gross income for federal income tax purposes under the Tax Code. "Bond Fund" means the fund by that name established and held by the Trustee under Section 5.01. "Bond Law" means Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California, commencing with Section 6584 of said Code. "Bond Year" means each twelve-month period extending from October 2 in one calendar year to October 1 of the succeeding calendar year, both dates inclusive; except that the first Bond Year commences on the Closing Date and extends to and including October 1, 2022. "Bonds" means the $ aggregate principal amount of Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) authorized by and at any time Outstanding under this Indenture. "Business Day" means a day (other than a Saturday or a Sunday) on which banks are not required or authorized to remain closed in the City in which the Office of the Trustee is located. "City" means the City of Lodi, a general law city and municipal corporation organized and existing under the Constitution and laws of the State of California. A-1 "Closing Date" means the date of delivery of the Bonds to the Original Purchaser. "Costs of Issuance" means all items of expense directly or indirectly payable by or reimbursable to the City relating to the authorization, issuance, sale and delivery of the Bonds, the refunding of the 2012 Bonds and the financing of the Project, including but not limited to: printing expenses; rating agency fees; filing and recording fees; initial fees, expenses and charges of the Trustee and their respective counsel, including the Trustee's first annual administrative fee; fees, charges and disbursements of attorneys, financial advisors, accounting firms, consultants and other professionals; fees and charges for preparation, execution and safekeeping of the Bonds; and any other cost, charge or fee in connection with the original issuance of the Bonds, the refunding of the 2012 Bonds and the financing of the Project. "Costs of Issuance Fund" means the fund by that name established and held by the Trustee under Section 3.03. "Depository" means (a) initially, DTC, and (b) any other Securities Depositories acting as Depository under Section 2.04. "Depository System Participant" means any participant in the Depository's book -entry system. "DTC" means The Depository Trust Company, New York, New York, and its successors and assigns. "Event of Default" means any of the events specified in Section 7.01. "Excess Investment Earnings" means an amount required to be rebated to the United States of America under Section 148(f) of the Tax Code due to investment of gross proceeds of the Bonds at a yield in excess of the yield on the Bonds. "Federal Securities" means: (a) any direct general 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 of the United States of America), for which the full faith and credit of the United States of America are pledged; (b) obligations of any agency, department or instrumentality of the United States of America, the timely payment of principal and interest on which are directly or indirectly secured or guaranteed by the full faith and credit of the United States of America. "Fiscal Year" means any twelve-month period extending from July 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. "Indenture" means this Indenture of Trust, as originally executed or as it may from time to time be supplemented, modified or amended by any Supplemental Indenture under the provisions hereof. "Independent Accountant" means any certified public accountant or firm of certified public accountants appointed and paid by the Authority or the City, and who, or each of whom (a) is in fact independent and not under domination of the Authority or the City; (b) A-2 does not have any substantial interest, direct or indirect, in the Authority or the City; and (c) is not connected with the Authority or the City as an officer or employee of the Authority or the City but who may be regularly retained to make annual or other audits of the books of or reports to the Authority or the City. "Insurance and Condemnation Fund" means the fund by that name established and held by the Trustee under Section 5.07. "Interest Account" means the account by that name established and held by the Trustee in the Bond Fund under Section 5.02. "Interest Payment Date" means each April 1 and October 1, commencing October 1, 2022, so long as any Bonds remain unpaid. "Lease" means the Lease Agreement dated as of March 1, 2022, between the Authority as lessor and the City as lessee of the Leased Property, as originally executed and as it may from time to time be supplemented, modified or amended in accordance with the terms thereof and of this Indenture. "Lease Payment Date" means, with respect to any Interest Payment Date, the Business Day immediately preceding such Interest Payment Date. "Lease Payments" means the amounts payable by the City under Section 4.3(a) of the Lease, including any prepayment thereof and including any amounts payable upon a delinquency in the payment thereof. "Leased Property" means the real property described in Appendix A to the Lease, together with all improvements and facilities at any time situated thereon. "Net Proceeds" means amounts derived from any policy of casualty insurance or title insurance with respect to the Leased Property, or the proceeds of any taking of the Leased Property or any portion thereof in eminent domain proceedings (including sale under threat of such proceedings), to the extent remaining after payment therefrom of all expenses incurred in the collection and administration thereof. "Nominee" means (a) initially, Cede & Co. as nominee of DTC, and (b) any other nominee of the Depository designated under Section 2.04(a). "Office" means the corporate trust office of the Trustee in St. Paul, Minnesota, or such other or additional offices as the Trustee may designate in writing to the Authority from time to time as the corporate trust office for purposes of the Indenture; except that with respect to presentation of Bonds for payment or for registration of transfer and exchange such term means the office or agency of the Trustee at which, at any particular time, its corporate trust agency business is conducted. "Original Purchaser" means Piper Sandler & Co., as original purchasers of the Bonds upon their delivery by the Trustee on the Closing Date. "Outstanding", when used as of any particular time with reference to Bonds, means all Bonds theretofore, or thereupon being, authenticated and delivered by the Trustee under this Indenture except: (a) Bonds theretofore canceled by the Trustee or surrendered A-3 to the Trustee for cancellation; (b) Bonds with respect to which all liability of the Authority shall have been discharged in accordance with Section 10.02, including Bonds (or portions thereof) described in Section 11.09; and (c) Bonds for the transfer or exchange of or in lieu of or in substitution for which other Bonds shall have been authenticated and delivered by the Trustee under this Indenture. "Owner", whenever used herein with respect to a Bond, means the person in whose name the ownership of such Bond is registered on the Registration Books. "Permitted Encumbrances" means, as of any time: (a) liens for general ad valorem taxes and assessments, if any, not then delinquent, or which the City may permit to remain unpaid under Article V of the Lease; (b) the Site Lease, the Lease and the Assignment Agreement; (c) any right or claim of any mechanic, laborer, material man, supplier or vendor not filed or perfected in the manner prescribed by law; (d) that certain Lease Agreement (A-06-194) dated as of March 28, 2006, by and between the County of San Joaquin and the City (as modified by an Assignment and Assumption of Lease, dated as of July 1, 2008, among the County, the City and the Judicial Council of California, Administrative Office of the Courts); (e) the exceptions disclosed in the title insurance policy with respect to the Leased Property issued as of the Closing Date by Stewart Title Guaranty Company; and (f) easements, rights of way, mineral rights, drilling rights and other rights, reservations, covenants, conditions or restrictions which exist of record and which the City certifies in writing will not materially impair the use of the Leased Property for its intended purposes. "Permitted Investments" means any of the following: (a) any direct general 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 of the United States of America), for which the full faith and credit of the United States of America are pledged. (b) obligations of any agency, department or instrumentality of the United States of America, the timely payment of principal and interest on which are directly or indirectly secured or guaranteed by the full faith and credit of the United States of America. (c) Any direct or indirect obligations of an agency or department of the United States of America whose obligations represent the full faith and credit of the United States of America, or which are rated A or better by S&P. (d) Interest-bearing deposit accounts (including certificates of deposit) in federal or State chartered savings and loan associations or in federal or State of California banks (including the Trustee), provided that: (i) the unsecured obligations of such commercial bank or savings and loan association are rated A or better by S&P; or (ii) such deposits are fully insured by the Federal Deposit Insurance Corporation or secured at all times by collateral described in (a) or (b) above. (e) Commercial paper rated "A-1+" or better by S&P. A-4 (f) Federal funds or bankers acceptances with a maximum term of one year of any bank which an unsecured, uninsured and unguaranteed obligation rating of "A-1+" or better by S&P. (g) Money market funds registered under the Federal Investment Company Act of 1940, whose shares are registered under the Federal Securities Act of 1933, and having a rating by S&P of at least AAAm-G, AAAm or AAm, which funds may include funds for which the Trustee, its affiliates, parent or subsidiaries provide investment advisory or other management services. (h) Obligations the interest on which is excludable from gross income pursuant to Section 103 of the Tax Code and which are either (a) rated A or better by S&P, or (b) fully secured as to the payment of principal and interest by Permitted Investments described in clauses (a) or (b). (i) Obligations issued by any corporation organized and operating within the United States of America having assets in excess of $500,000,000, which obligations are rated A or better by S&P. Q) Bonds or notes issued by any state or municipality which are rated A or better by S&P. (k) Any investment agreement with, or guaranteed by, a financial institution the long-term unsecured obligations or the claims paying ability of which are rated A or better by S&P at the time of initial investment, by the terms of which all amounts invested thereunder are required to be withdrawn and paid to the Trustee in the event either of such ratings at any time falls below A. (1) The Local Agency Investment Fund of the State of California, created pursuant to Section 16429.1 of the California Government Code, to the extent the Trustee is authorized to register such investment in its name. "Principal Account" means the account by that name established and held by the Trustee in the Bond Fund under Section 5.02. "Project" means the public capital improvements described in Appendix C attached to the Lease. "Project Costs" means, with respect to the Project, all costs of the acquisition, construction and installation thereof which are paid from moneys on deposit in the Project Fund, including but not limited to: (a) all costs required to be paid to any person under the terms of any agreement for or relating to the acquisition, construction and installation of the Improvements; A-5 (b) obligations incurred for labor and materials in connection with the acquisition, construction and installation of the Improvements; (c) the cost of performance or other bonds and any and all types of insurance that may be necessary or appropriate to have in effect in connection with the acquisition, construction and installation of the Improvements; (d) all costs of engineering and architectural services, including the actual out- of-pocket costs for test borings, surveys, estimates, plans and specifications and preliminary investigations therefor, development fees, sales commissions, and for supervising construction, as well as for the performance of all other duties required by or consequent to the proper acquisition, construction and installation of the Improvements; (e) any sums required to reimburse the City for advances made for any of the above items or for any other costs incurred and for work done which are properly chargeable to the acquisition, construction and installation of the Improvements; (f) all Costs of Issuance of the Bonds and other financing costs incurred in connection with the acquisition, construction and installation of the Project; and (g) the interest components of the Lease Payments allocable to the Project or any component thereof, which come due during the period of acquisition, construction and installation of the improvements or such component. "Project Fund" means the fund by that name established and held by the Trustee under Section 3.04. "Record Date" means, with respect to any Interest Payment Date, the 151" calendar day of the month preceding such Interest Payment Date, whether or not such day is a Business Day. "Redemption Fund" means the fund by that name established and held by the Trustee under Section 5.06. "Registration Books" means the records maintained by the Trustee under Section 2.05 for the registration and transfer of ownership of the Bonds. "Revenues" means: (a) all amounts received by the Authority or the Trustee under or with respect to the Lease, including, without limiting the generality of the foregoing, all of the Lease Payments (including both timely and delinquent payments, any late charges, and whether paid from any source), but excluding (i) any amounts described in Section 7.5(b)(v) of the Lease, and (ii) any Additional Rental Payments; and (b) all interest, profits or other income derived from the investment of amounts in any fund or account established under this Indenture. "Securities Depositories" means DTC; and, in accordance with then current guidelines of the Securities and Exchange Commission, such other securities depositories as the Authority designates in written notice filed with the Trustee. A-6 "Site Lease" means the Site Lease dated as of March 1, 2022, between the City as lessor and the Authority as lessee, as amended from time to time in accordance with its terms. "Site Lease Payment" means the amount payable by the Authority to the City on the Closing Date under Section 3 of the Site Lease. "S&P" means Standard & Poor's, a division of the McGraw Hill Companies, of New York, New York, its successors and assigns. "Supplemental Indenture" means any indenture hereafter duly authorized and entered into between the Authority and the Trustee, supplementing, modifying or amending this Indenture; but only if and to the extent that such Supplemental Indenture is specifically authorized hereunder. "Tax Code" means the Internal Revenue Code of 1986 as in effect on the Closing Date or (except as otherwise referenced herein) as it may be amended to apply to obligations issued on the Closing Date, together with applicable proposed, temporary and final regulations promulgated, and applicable official public guidance published, under said Code. "Term" means, with reference to the Lease, the time during which the Lease is in effect, as provided in Section 4.2 thereof. "Term Bonds" means the Bonds maturing on October 1, and October 1, "Trustee" means U.S. Bank Trust Company, National Association, a national banking association organized and existing under the laws of United States of America, or its successor or successors, as Trustee hereunder as provided in Article VIII. "2012 Bonds" has the meaning given that term in the recitals. "2012 Trustee" means U.S. Bank Trust Company, National Association, its successors and assigns, as successor trustee for the 2012 Bonds. "Written Certificate," "Written Request" and "Written Requisition" of the Authority or the City mean, respectively, a written certificate, request or requisition signed in the name of the Authority or the City by its Authorized Representative. Any such instrument and supporting opinions or representations, if any, may, but need not, be combined in a single instrument with any other instrument, opinion or representation, and the two or more so combined shall be read and construed as a single instrument. A-7 LODI PUBLIC FINANCING AUTHORITY 2022 LEASE REVENUE BOND (2012 BONDS REFUNDING; CAPITAL PROJECTS FINANCING) INTEREST RATE: MATURITY DATE: ORIGINAL ISSUE DATE: CUSIP: % October 1, , 2022 REGISTERED OWNER: CEDE & CO. PRINCIPAL AMOUNT: "' The LODI PUBLIC FINANCING AUTHORITY, a public body corporate and politic duly organized and existing under the laws of the State of California (the "Authority"), for value received, hereby promises to pay to the Registered Owner specified above or registered assigns (the "Registered Owner"), on the Maturity Date specified above (subject to any right of prior redemption hereinafter provided for), the Principal Amount specified above, in lawful money of the United States of America, and to pay interest thereon in like lawful money from the Interest Payment Date (as hereinafter defined) next preceding the date of authentication of this Bond unless (i) this Bond is authenticated on or before an Interest Payment Date and after the close of business on the 15th day of the month preceding such interest payment date, in which event it shall bear interest from such Interest Payment Date, or (ii) this Bond is authenticated on or before September 15, 2022, in which event it shall bear interest from the Original Issue Date specified above; provided, however, that if at the time of authentication of this Bond, interest is in default on this Bond, this Bond shall bear interest from the Interest Payment Date to which interest has previously been paid or made available for payment on this Bond, at the Interest Rate per annum specified above, payable semiannually on April 1 and October 1 in each year, commencing October 1, 2022 (the "Interest Payment Dates"), calculated on the basis of a 360 -day year composed of twelve 30 -day months. Principal hereof and premium, if any, upon early redemption hereof are payable upon presentation and surrender hereof at the corporate trust office of U.S. Bank Trust Company, National Association, in St. Paul, Minnesota (the "Trust Office"), as trustee (the "Trustee"). Interest hereon is payable by check of the Trustee mailed to the Registered B-1 Owner hereof at the Registered Owner's address as it appears on the registration books of the Trustee as of the close of business on the fifteenth day of the month preceding each Interest Payment Date (a "Record Date"), or, upon written requestfiled::viFith the Trustee as of such Record Date by a registered owner of at least $4-;-0.00-,00-6-.fn.--a---9-gfegate principal amount of Bonds, by wire transfer in immediatety� avaifab16 f..und8"-to an account in the United States designated by such,regi:-sterb�`bwn�r in s6ch written request. This Bond:.fs.not 6.d:bbt,.-`of'the:City of LQdi (the "City"), the County of San Joaquin, the State of Gaj06rnla of any oriits politic:ai_"st�tl isions, and neither the City, said County, said State, npr::9hiy of iIts political subdivisions.,:°is liable hereon nor in any event shall this Bond be payable out of any funds or properties of the Authority other than the Revenues. This Bond is one of a duly authorized issue of bonds of the Authority designated as the "Lodi Public Financing Authority 2022 Lease Revenue Bonds" (the "Bonds"), in an aggregate principal amount of $ , all of like tenor and date (except for such variation, if any, as may be required to designate varying numbers, maturities, interest rates or redemption provisions) and all issued under the provisions of Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California, commencing with Section 6584 of said Code, and under an Indenture of Trust dated as of March 1, 2022, between the Authority and the Trustee (the "Indenture") and a resolution of the Authority adopted on March 2, 2022, authorizing the issuance of the Bonds. Reference is hereby made to the Indenture (copies of which are on file at the office of the Authority) and all supplements thereto for a description of the terms on which the Bonds are issued, the provisions with regard to the nature and extent of the Revenues, and the rights thereunder of the owners of the Bonds and the rights, duties and immunities of the Trustee and the rights and obligations of the Authority thereunder, to all of the provisions of which the Registered Owner of this Bond, by acceptance hereof, assents and agrees. The Bonds have been issued by the Authority to refinance certain outstanding lease revenue bonds issued by the Authority and to finance the acquisition and construction of improvements owned by the City. This Bond and the interest and premium, if any, hereon are special obligations of the Authority, payable from the Revenues, and secured by a charge and lien on the Revenues as defined in the Indenture, consisting principally of lease payments made by the City under a Lease Agreement dated as of March 1, 2022, between the Authority as lessor and the City as lessee (the "Lease"). As and to the extent set forth in the Indenture, all of the Revenues are exclusively and irrevocably pledged in accordance with the terms hereof and the provisions of the Indenture, to the payment of the principal of and interest and premium (if any) on the Bonds. The rights and obligations of the Authority and the owners of the Bonds may be modified or amended at any time in the manner, to the extent and upon the terms provided in the Indenture, but no such modification or amendment shall extend the fixed maturity of any Bonds, or reduce the amount of principal thereof or premium (if any) thereon, or extend the time of payment, or change the method of computing the rate of interest thereon, or extend the time of payment of interest thereon, without the consent of the owner of each Bond so affected. The Bonds maturing on or before October 1, , are not subject to optional redemption prior to their respective stated maturity dates. The Bonds maturing on or after October 1, , are subject to redemption in whole, or in part at the request of the B-2 Authority among maturities on such basis as the Authority may designate and by lot within a maturity, at the option of the Authority, on any date on or after April 1, , from any available source of funds, at a redemption price equal to 100% of the principal amount to be redeemed plus accrued interest to the date of redemption, without premium. The Bonds are subject to redemption as a whole, or in part by lot, on any date, to the extent of any net proceeds of hazard or title insurance with respect to the property which has been leased under the Lease (the "Leased Property") or any portion thereof which are not used to repair or replace the Leased Property pursuant to the Lease, or to the extent of any net proceeds arising from the disposition of the Leased Property or any portion thereof in eminent domain proceedings which the City elects to be used for such purpose pursuant to the Lease, at a redemption price equal to the principal amount thereof plus interest accrued thereon to the date fixed for redemption, without premium. The Bonds maturing on October 1, and October 1, ("Term Bonds") are subject to mandatory redemption in part by lot, at a redemption price equal to 100% of the principal amount thereof to be redeemed, without premium, in the aggregate respective principal amounts and on October 1 in the respective years as set forth in the following tables; provided, however, that if some but not all of the Term Bonds have been redeemed as a result of an optional redemption or a special mandatory redemption, the total amount of all future sinking fund payments will be reduced by the aggregate principal amount of the Term Bonds so redeemed, to be allocated among such sinking fund payments on a pro rata basis in integral multiples of $5,000 (as set forth in a schedule provided by the Authority to the Trustee). Mandatory Sinking Fund Redemption of Term Bonds Maturing October 1, Sinking Fund Redemption Date (October 1) Principal Amount To Be Redeemed Mandatory Sinking Fund Redemption of Term Bonds Maturing October 1, Sinking Fund Redemption Date (October 1) Principal Amount To Be Redeemed As provided in the Indenture, notice of redemption will be mailed by the Trustee by first class mail not less than 30 nor more than 60 days prior to the redemption date to the respective owners of any Bonds designated for redemption at their addresses appearing L1X3 on the registration books of the Trustee, but neither failure to receive such notice nor any defect in the notice so mailed shall affect the sufficiency of the proceedings for redemption or the cessation of accrual of interest thereon from and after the date fixed-f& redemption. Notice of any optional redemption of the Bonds may be rescin.dedr�der.fk�e-circumstances set forth in the Indenture, upon notice to the owners-eflWch. 6ai6W,4 `.._.:: If this Bond is called for -rede" M" itidn,.anc :`payment is duly provided therefor as specified in the Ind nture -it�i4 s�;::Sk�all`-cease to accrue hereon from and after the date fixed for redemp�jpri::: , This 8.6i d is transferable by tq:.:Registered Owner hereof, in person or by his 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 Bond. Upon registration of such transfer, a new 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 herefor. This Bond may be exchanged at the Trust Office for Bonds of the same tenor, aggregate principal amount, interest rate and maturity, of other authorized denominations. The Authority and the Trustee may treat the 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. Unless this Bond is presented by an authorized representative of The Depository Trust Company to the Authority or the Trustee for registration of transfer, exchange or payment, and any Bond issued is registered in the name of Cede & Co. or such other name as requested by an authorized representative of The Depository Trust Company and any payment is made to Cede & Co., ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL since the registered owner hereof, Cede & Co., has an interest herein. It is hereby certified by the Authority that all of the things, conditions and acts required to exist, to have happened or to have been performed precedent to and in the issuance of this Bond do exist, have happened or have been performed in due and regular time, form and manner as required by the Ordinance and the laws of the State of California and that the amount of this Bond, together with all other indebtedness of the Authority, does not exceed any limit prescribed by the Ordinance or any laws of the State of California, and is not in excess of the amount of Bonds permitted to be issued under the Indenture. This 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 endorsed shall have been manually signed by the Trustee. IN WITNESS WHEREOF, the Lodi Public Financing Authority has caused this Bond to be executed in its name and on its behalf with the facsimile signature of its Chair and attested to by the facsimile signature of its Secretary, all as of the Original Issue Date specified above. LODI PUBLIC FINANCING.; VTHORITY Chair Dated: CERTIFICATE OF AUTHENTICATION This is one of the Bonds described in the within -mentioned Indenture. U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, as Trustee 1 ASSIGNMENT Authorized Signatory For value received the undersigned hereby sells, assigns and transfers unto whose address and social security or other tax identifying number is the within -mentioned Bond and hereby irrevocably constitute(s) and appoint(s) attorney, to transfer the same on the registration books of the Trustee with full power of substitution in the premises. Dated: Signature Guaranteed: Note: Signature(s) must be guaranteed by an eligible guarantor institution. B-5 Note: The signature(s) on this Assignment must correspond with the name(s) as written on the face of the within Bond in every particular without alteration or enlargement or any change whatsoever. APPENDIX C FORM OF PROJECT FUND REQUISITION DISBURSEMENT REQUEST NO.: U.S. Bank Trust Company, National Association One California Street, Suite 1000 San Francisco, CA 94111 Attn: Global Corporate Trust Re: $ Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bonds Refunding; Capital Projects Financing) Ladies and Gentlemen: In accordance with the terms of an Indenture of Trust, by and between you and the undersigned, dated as of March 1, 2022 (the "Indenture"), I am an Authorized Representative and you are hereby authorized and requested to make immediate disbursement of funds held by you in the Project Fund for Project Costs relating to the Project (as such terms are defined in the Indenture) pursuant to Section 3.04 of the Indenture. You are hereby requested to pay from the Project Fund established by the Indenture, to the person(s), corporation(s) or other entity(ies) designated on Schedule A attached hereto, in payment of all or a portion of the Project Costs described on said Schedule. The undersigned hereby certifies that (i) the amounts listed on Schedule A constitute Project Costs (as defined in the Indenture), (ii) no part of the amount requested herein has been included in any other request previously filed with you; (iii) to the knowledge of the undersigned, there has not been filed with or served upon the City any notice of any lien or attachment upon or claim (except for any preliminary notice of lien as may be filed in accordance with law) affecting the right of the person, corporation or other entity stated below to receive payment of the amount stated below, which lien has not been released or will not be released simultaneously with the payment requested hereunder; and (iv) the labor, services and/or materials covered hereby have been performed upon or furnished to the Improvements and the payment requested herein is due and payable under a purchase order, contract or other authorization; Dated: , 20 C-1 CITY OF LODI 0 Authorized Officer SCHEDULE A Payee Description Project Costs (include address) of Costs Amount C-2 Jones Hall 2-23-22 Agenda IRREVOCABLE REFUNDING INSTRUCTIONS Relating to $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds These IRREVOCABLE REFUNDING INSTRUCTIONS (these "Instructions"), are dated 2022, and are given by the Lodi Public Financing Authority, a joint exercise of powers agency duly established and authorized to transact business and exercise powers under and pursuant to the provisions of Section 6500 of the California Government Code (the "Authority"), to U.S. Bank Trust Company, National Association, a national banking association organized and existing under the laws of the United States of America, successor to U.S. Bank National Association acting as trustee for the hereinafter defined 2012 Bonds (the "2012 Trustee"); WITNESSETH: 1. The Authority previously issued its Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds"). 2. The 2012 Bonds were issued pursuant to an Indenture of Trust, dated as of September 1, 2012 (the "2012 Indenture of Trust"), by and between the Authority and the 2012 Trustee. The 2012 Bonds were issued for the purpose of (a) providing funds for the City of Lodi (the "City") to prepay outstanding certificates of participation of the City and (b) paying the costs of issuing the 2012 Bonds. 3. The City has determined that it is in its best financial interests at this time to refund the currently outstanding 2012 Bonds, and intends concurrently to finance acquisition and construction of additional capital improvements. 4. To that end, the City has proposed to lease to the Authority certain real property and improvements of the City (the "Leased Property"), under a Site Lease, dated as of the date hereof, by and between the City and the Authority (the "Site Lease") in consideration of the payment by the Authority of an upfront rental payment (the "Site Lease Payment") which is sufficient to provide funds for, among other things, the redemption of the 2012 Bonds. 5. In order to provide eligible funds to enable the Authority to pay the Site Lease Payment to the City in accordance with the Site Lease, the Authority has issued its Lodi Public Financing Authority Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) in the aggregate principal amount of $ (the "2022 Bonds"), pursuant to an Indenture of Trust dated as of March 1, 2022 (the "2022 Indenture") by and between the Authority and U.S. Bank Trust Company, National Association (the "2022 Trustee"). 6. The Authority will use a portion of the proceeds from the issuance of the 2022 Bonds, together with certain other moneys, to defease the 2012 Bonds and provide for the discharge of the City's obligations under the Lease Agreement dated as of September 1, 2012, by and between the City and the Authority (the "Lease Agreement"). 7. The Authority wishes to give these Instructions to the 2012 Trustee for the purpose of providing the terms and conditions relating to the deposit and application of moneys to provide for the defeasance, payment and redemption of all of the outstanding 2012 Bonds pursuant to Section 4.01(a) and Section 10.01(b) of the 2012 Indenture of Trust. NOW, THEREFORE, the Authority hereby irrevocably instructs the 2012 Trustee as follows: Section 1. Proceedings for Redemption of 2012 Bonds. The Authority hereby irrevocably elects and directs the 2012 Trustee to redeem the 2012 Bonds on , 2022. The Authority previously directed the 2012 Trustee to give notice of the redemption of the 2012 Bonds in accordance with Section 4.03 of the 2012 Indenture of Trust in substantially the form of Exhibit A. The Authority hereby directs the 2012 Trustee to file a notice of defeasance of the 2012 Bonds in substantially the form of Exhibit B on the Electronic Municipal Market Access system ("EMMA") on the date hereof. The sole remedy for failure to post such notice on EMMA shall be an action by the holders of the 2012 Bonds in mandamus for specific performance or similar remedy to compel performance. Section 2. Deposit into Redemption Account; Use of Amounts in the Redemption Account. (a) On the date hereof, the 2022 Trustee shall transfer to the 2012 Trustee proceeds of the 2022 Bonds in the amount of $ to be held in the Redemption Fund established and held by the 2012 Trustee under the 2012 Indenture, and such funds, along with other available moneys held by the 2012 Trustee under the 2012 Indenture ($ ), which shall also be transferred to the Redemption Fund on the date hereof, shall be held uninvested. [discuss] (b) The 2012 Trustee shall use the funds available in the Redemption Fund to pay the accrued interest on the 2012 Bonds to , 2022 and redeem the remaining outstanding 2012 Bonds on , 2022, without premium, pursuant to Section 4.01(a) of the 2012 Indenture of Trust. (c) The deposits into the Redemption Fund as described in this Section 2 constitute prepayment of the City's Lease Payment obligation and the establishment of a security deposit by the City under the Lease Agreement. (d) On , 2022, following the payment and redemption of the 2012 Bonds as described in this Section 2, the 2012 Trustee shall withdraw any amounts remaining on deposit in the Redemption Fund and any other fund or account held by the 2012 Trustee under the 2012 Indenture of Trust, less any unpaid fees and expenses of the 2012 Trustee, and transfer such amounts to the 2022 Trustee to be held in the Interest Account held by the 2022 Trustee under the 2022 Indenture and to be used to pay interest on the 2022 Bonds. Section 3. Amendment. These Instructions may be amended or supplemented by the Authority, but only if the Authority shall file with the 2012 Trustee (a) an opinion of nationally recognized bond counsel engaged by the Authority stating that such amendment or supplement will not, of itself, adversely affect the exclusion from gross income of interest on the 2012 Bonds or the 2022 Bonds under federal income tax law, and (b) a certification of an independent certified public accountant stating that such amendment or supplement will not affect the sufficiency of funds invested and held hereunder to make the payments required by Section 2. 2 Section 4. Concerning the 2012 Trustee. The 2012 Trustee shall not be liable for any loss from any investment made by it in accordance with the terms of these Instructions. The 2012 Trustee shall not be liable for the recitals or representations contained in these Instructions and shall not be responsible for the sufficiency of amounts described in Section 2 to pay the redemption price of the 2012 Bonds on the date specified in Section 2. The protections, limitations from liability and indemnities provided to the 2012 Trustee under the 2012 Indenture of Trust shall be afforded to the 2012 Trustee in acting pursuant to these Instructions and such provisions of the 2012 Indenture are incorporated by reference herein. Section 5. Governing Law. These Instructions shall be construed in accordance with and governed by the laws of the State of California. LODI PUBLIC FINANCING AUTHORITY go ACCEPTED: U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, as 2012 Trustee Z Authorized Officer ACCEPTED: CITY OF LODI, City Manager 3 Executive Director EXHIBIT A FORM OF CONDITIONAL NOTICE OF REDEMPTION $19,080,000 Lodi Public Financing Authority 2012 Lease Revenue Bonds Date of issuance: September 5, 2012 NOTICE IS HEREBY GIVEN, by the Lodi Public Financing Authority (the "Authority") that all of the captioned bonds maturing on or after October 1, 2022 have been called for redemption under and within the meaning of the Indenture of Trust, dated as of September 1, 2012 (the "2012 Indenture of Trust"), on , 2022 (the "Redemption Date"), at a redemption price equal to 100% of the par amount of the 2012 Bonds to be redeemed together with accrued interest thereon to the redemption date (the "Redemption Price"). The 2012 Bonds to be refunded consist of the following: Maturity Date (October 1) Principal Amount Interest Rate CUSIP 2022 $1,065,000 5.000% 540259AG3 2023 1,120, 000 5.000 540259AH 1 2026 3,720,000 5.250 540259AK4 2031 7,410,000 4.125 540259AJ7 The CUSIP number of the 2012 Bonds has been assigned by an independent service and is included in this notice solely for the convenience of the bond owners and neither U.S. Bank Trust Company, National Association, as trustee for the 2012 Bonds (the "2012 Trustee"), the Authority nor the City of Lodi (the "City") shall be liable for any inaccuracies in such numbers. Redemption of the 2012 Bonds as described in this notice shall be conditioned upon the receipt by the 2012 Trustee from the City of the funds necessary for the proposed redemption on or before the Redemption Date. Payment of the Redemption Price of the 2012 Bonds called for redemption will become due and payable on the Redemption Date upon presentation and surrender thereof in the following manner: Holders of the 2012 Bonds are requested to present their 2012 Bonds, at the following addresses: U.S. Bank Trust Company, National Association 111 Fillmore Avenue East St. Paul, MN 55107 Additional information regarding the foregoing actions may be obtained from U.S. Bank Trust Company, National Association, Corporate Trust Department, Bondholder Relations, telephone number: 1-800-934-6802. Interest on the principal amount designated to be prepaid shall cease to accrue on and after the Redemption Date. IMPORTANT NOTICE Federal law requires the withholding of taxes at the applicable rate from the payment if an IRS Form W-9 or applicable IRS Form W-8 is not provided. Please visit www.irs.gov for additional information on the tax forms and instructions. Dated: 2022 U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, as Trustee A-2 EXHIBIT B FORM OF DEFEASANCE NOTICE $19,080,000 Lodi Public Financing Authority 2012 Lease Revenue Bonds Date of issuance: September 5, 2012 NOTICE IS HEREBY GIVEN, by the Lodi Public Financing Authority (the "Authority") that all of the captioned bonds (the "2012 Bonds") maturing on or after October 1, 2022 have been defeased and discharged under and within the meaning of the Indenture of Trust, dated as of September 1, 2012 (the "2012 Indenture of Trust"). The Authority has irrevocably elected to redeem all of the outstanding 2012 Bonds on 2022, at a redemption price equal to 100% of the par amount of the 2012 Bonds to be redeemed together with accrued interest thereon to the redemption date. The 2012 Bonds consist of the following: Maturity Date (October 1) Principal Amount 2022 $1,065,000 2023 1,120, 000 2026 3,720,000 2031 7,410,000 Interest Rate CUSIP 5.000% 540259AG3 5.000 540259AH 1 5.250 540259AK4 4.125 540259AJ7 The CUSIP number of the 2012 Bonds has been assigned by an independent service and is included in this notice solely for the convenience of the bond owners and neither U.S. Bank Trust Company, National Association, as trustee for the 2012 Bonds (the "2012 Trustee"), the Authority nor the City of Lodi shall be liable for any inaccuracies in such numbers. Proceeds of the issuance of the Authority's Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Bond Refunding; Capital Projects Financing) sufficient to pay interest and the redemption price of the 2012 Bonds on , 2022 are held in cash by the 2012 Trustee for the payment and redemption of the 2012 Bonds, as permitted under the 2012 Indenture of Trust. As a consequence of the foregoing actions and in accordance with the 2012 Indenture of Trust, the 2012 Bonds are no longer secured by a pledge of revenues under the 2012 Indenture of Trust, and the 2012 Bonds are now payable solely from the moneys set aside for that purpose under the 2012 Indenture of Trust. Dated: 2022 B-1 4� - 3 RESOLUTION NO. 2022 - A RESOLUTION OF THE LODI CITY COUNCIL MAKING FINDINGS AND APPROVING DOCUMENTS AND ACTIONS RELATING TO THE PROPOSED ISSUANCE BY THE LODI PUBLIC FINANCING AUTHORITY OF LEASE REVENUE BONDS TO REFINANCE OUTSTANDING LEASE REVENUE BONDS AND PROVIDE FINANCING FOR ACQUISITION AND CONSTRUCTION OF CAPITAL IMPROVEMENTS, INCLUDING AN ANIMAL SHELTER AND PARKS AND PLAYGROUND IMPROVEMENTS AND UPGRADES WHEREAS, the Lodi Public Financing Authority (the "Authority") previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City of Lodi (the "City"); and WHEREAS, in connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum; and WHEREAS, in order to take advantage of prevailing bond market conditions, the City Council wishes to authorize the refinancing of the 2012 Bonds; and WHEREAS, the City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including, among other things, a new animal shelter and park and playground improvements and upgrades (the "Project"); and WHEREAS, to that end, the City has proposed to lease the land and improvements constituting the City's police building and its Fire Station #2 (the "Leased Property") to the Authority under a Site Lease, the form of which is on file with the City Clerk, in consideration of the payment by the Authority of an upfront rental payment which is sufficient to provide funds to refinance the 2012 Bonds and finance the acquisition and construction of the Project; and WHEREAS, in order to raise funds for the upfront rental payment, the Authority proposes to issue and sell its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) (the "Bonds") under Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California, commencing with Section 6584 of said Code (the "Bond Law"); and WHEREAS, in order to secure the payments of principal of and interest on the Bonds, the Authority proposes to lease the Leased Property back to the City under a Lease Agreement (the "Lease Agreement"), the form of which is on file with the City Clerk, under which the City is obligated to pay semiannual lease payments as rental for the Leased Property, and the Authority will assign substantially all of its rights under the Lease Agreement to U.S. Bank Trust Company, National Association, as trustee for the Bonds; and WHEREAS, there has been submitted to the City Council a form of preliminary Official Statement in connection with the marketing of the Bonds and the City Council, with the aid of its staff, has reviewed the preliminary Official Statement to assure proper disclosure of all material facts relating to the Bonds that are in the personal knowledge of the members of the City Council and the City staff; and WHEREAS, the Authority and the City propose to sell the Bonds to Piper Sandler & Co. (the "Underwriter") pursuant to a Bond Purchase Agreement (the "Bond Purchase Agreement"), the form of which is on file with the City Clerk; and WHEREAS, in order to assist the Underwriter in complying with Rule 15c2-12 of the Securities and Exchange Commission, the City will undertake certain continuing disclosure obligations with respect to the Bonds pursuant to a continuing disclosure certificate to be executed by the City (the "Continuing Disclosure Certificate"), the form of which is on file with the City Clerk; and WHEREAS, as a condition precedent to the issuance by the Authority of the Bonds to provide financing for the Project, Section 6586.5 of the Bond Law requires that the City approve the proposed lease financing by the Authority and that the City make certain findings with respect to such financing, and Section 6586.5 further requires that such approval be given and findings be made only after a noticed public hearing; and WHEREAS, as required by Section 6586.5 of the Bond Law, the City has caused publication of a notice of a public hearing on the financing of the Project once at least five days prior to the hearing in a newspaper of general circulation in the City; and WHEREAS, the City Council held a public hearing at which all interested persons were provided the opportunity to speak on the subject of financing the Project; and WHEREAS, in accordance with Government Code Section 5852.1, the City Council has obtained and wishes to disclose the information set forth in Appendix A hereto; and WHEREAS, the City Council wishes at this time to approve all proceedings to which it is a party relating to the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project; NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Lodi as follows: SECTION 1. Issuance of Bonds. The City Council hereby approves the issuance of the Bonds by the Authority under the Bond Law in the maximum principal amount of $30,000,000, for the purpose of providing funds to refinance the 2012 Bonds and finance the Project. Pursuant to the Bond Law, and based on the information provided to the City Council by City staff and consultants, all as set forth in the proceedings and documents providing for the issuance and delivery of the Bonds, the City Council hereby finds and determines that the issuance of the Bonds and the transactions related thereto will result in significant public benefits within the contemplation of Section 6586 of the Bond Law, namely, demonstrable savings in bond preparation, bond underwriting and bond issuance costs. -2- SECTION 2. Approval of Related Financing Agreements. The City Council hereby approves each of the following agreements required for the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project, in substantially the respective forms on file with the City Clerk together with any changes therein or additions thereto deemed advisable by the City Manager, the Deputy City Manager or the City Attorney (each, an "Authorized Officer"), whose execution thereof shall be conclusive evidence of the approval of any such changes or additions. An Authorized Officer is hereby authorized and directed for and on behalf of the City to execute, and the City Clerk is hereby authorized and directed to attest, the final form of each such agreement, as follows: • Site Lease, between the City as lessor and the Authority as lessee, under which the City leases the Leased Property to the Authority in consideration of the payment of an amount which will be applied by the City to refinance the 2012 Bonds and finance the Project. • Lease Agreement, between the Authority as lessor and the City as lessee, under which the Authority leases the Leased Property back to the City and the City agrees to pay semiannual lease payments which are sufficient to provide revenues with which to pay principal of and interest on the Bonds when due. ■ i rrevocable Refunding Instructions, to be given by the Authority to the trustee for the 2012 Bonds, and to be consented to by the City, providing for the deposit, investment and application of funds to defease and redeem the 2012 Bonds. + Bond Purchase Agreement, among the City, the Authority and the Underwriter, which establishes the terms under which the Underwriter will purchase the Bonds from the Authority. • Continuing Disclosure Certificate, to be executed by the City. SECTION 3. Negotiated Sale of Bonds. The City Council hereby approves the negotiated sale of the Bonds by the Authority to the Underwriter. The Bonds shall be sold pursuant to the terms and provisions of the Bond Purchase Agreement. The Bonds shall be sold at a true interest cost not to exceed 4.0%. The Underwriter's discount shall not exceed 1.0%. SECTION 4. Official Statement. The City Council hereby approves the preliminary Official Statement describing the Bonds in substantially the form on file with the City Clerk. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to said preliminary Official Statement and to execute an appropriate certificate stating the Authorized Officer's determination that the preliminary Official Statement (together with any changes therein or additions thereto) has been deemed nearly final within the meaning of Rule 15c2-12 of the Securities Exchange Act of 1934. Distribution of the preliminary Official Statement by the Underwriter is hereby approved. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to a final form of said Official Statement, and the execution thereof by an Authorized Officer shall be conclusive evidence of approval of any such changes and additions. The City Council hereby authorizes the distribution of the final -3- Official Statement by the Underwriter. The final Official Statement shall be executed on behalf of the City by an Authorized Officer. SECTION 5. Official Actions. The Mayor, the City Manager, the Deputy City Manager and the City Attorney and all other officers of the City are each authorized and directed on behalf of the City to make any and all leases, assignments, certificates, requisitions, agreements (including an escrow deposit and trust agreement, if needed), notices, consents, instruments of conveyance or termination, warrants and other documents, which they or any of them deem necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution, and the City Manager may direct the City Clerk to execute and deliver such other documents as the City Manager determines are necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution. An Authorized Officer may revise the identity of the Leased Property as necessary in order to accomplish the purposes of this Resolution. An Authorized Officer may approve the purchase of municipal bond insurance or a debt service reserve fund policy if the Authorized Officer, in consultation with the City's municipal advisor, concludes such purchase would be economically beneficial for the City. Whenever in this Resolution any officer of the City is authorized to execute or countersign any document or take any action, such execution, countersigning or action may be taken on behalf of such officer by any person designated by such officer to act on his or her behalf in the case such officer is absent or unavailable. SECTION 6. Effective Date. This Resolution shall take effect immediately upon its passage and adoption. Dated: March 2, 2022 ------------------------------------------------------------------ ------------------------------------------------------------------ I hereby certify that Resolution No. 2022- was passed and adopted by the City Council of the City of Lodi in a regular meeting held March 2, 2022 by the following votes: AYES: COUNCIL MEMBERS — NOES: COUNCIL MEMBERS — ABSENT: COUNCIL MEMBERS — ABSTAIN COUNCIL MEMBERS — Approved as to Form: Janice D. Magdich -4- Mayor PAMELA M. FARRIS Assistant City Clerk 2022- -5- APPENDIX A Government Code Section 5852.1 Disclosure The good faith estimates set forth herein are provided with respect to the Bonds in accordance with California Government Code Section 5852.1. Such good faith estimates have been provided to the City and the Authority by the Underwriter of the Bonds. Principal Amount. The Underwriter has informed the City and the Authority that, based on the financing plan and current market conditions, its good faith estimate of the aggregate principal amount of the Bonds to be sold is $26,475,000 (the "Estimated Principal Amount"), which excludes net premium that might be generated in the sale under current market conditions. True Interest Cost of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the true interest cost of the Bonds, which means the rate necessary to discount the amounts payable on the respective principal and interest payment dates to the purchase price received for the Bonds, is 3.34%. Finance Charge of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the finance charge for the Bonds, which means the sum of all fees and charges paid to third parties (or costs associated with the Bonds), is $611,071. Such fees and charges include fees for bond and disclosure counsel, municipal advisor, special tax consultant, fiscal agent, rating agencies, City and Authority expenses, City Attorney and staff time related to bond issuance, printing, and underwriting. Amount of Proceeds to be Received. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the amount of proceeds expected to be received for sale of the Bonds, less the finance charge of the Bonds, as estimated above, and any reserves or capitalized interest paid or funded with proceeds of the Bonds, is $28,330,255. Total Payment Amount. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the total payment amount, which means the sum total of all payments that the Authority will make to pay debt service on the Bonds, plus the finance charge for the Bonds, as described above, not paid with the proceeds of the Bonds, calculated to the final maturity of the Bonds, is $44,134,950. A-1 The foregoing estimates constitute good faith estimates only. The actual principal amount of the Bonds issued and sold, the true interest cost thereof, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates, (b) the actual principal amount of Bonds sold being different from the Estimated Principal Amount, (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates, (d) the actual market interest rates at the time of sale of the Bonds being different than those estimated for purposes of such estimates, (e) other market conditions, or (f) alterations in the financing plan, delays in the financing, or a combination of such factors. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on the timing of the need for proceeds of the Bonds and other factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. A-2 RESOLUTION NO. 2022 - A RESOLUTION OF THE BOARD OF DIRECTORS OF LODI PUBLIC FINANCING AUTHORITY AUTHORIZING THE ISSUANCE AND SALE OF LEASE REVENUE BONDS TO REFINANCE OUTSTANDING LEASE REVENUE BONDS AND PROVIDE FINANCING FOR ACQUISITION AND CONSTRUCTION OF AN CAPITAL IMPROVEMENTS, INCLUDING AN ANIMAL SHELTER AND PARKS AND PLAYGROUND IMPROVEMENTS AND UPGRADES, AND APPROVING RELATED DOCUMENTS AND OFFICIAL ACTIONS WHEREAS, the Lodi Public Financing Authority (the "Authority") previously issued its $19,080,000 Lodi Public Financing Authority 2012 Refunding Lease Revenue Bonds (the "2012 Bonds") for the purpose of refinancing outstanding certificates of participation that were executed and delivered to finance various municipal facilities of the City of Lodi (the "City"); and WHEREAS, in connection with the issuance of the 2012 Bonds, the City and the Authority entered into a Site Lease and a Lease Agreement, each of which was dated as of September 1, 2012, pursuant to which, respectively, the City leased to the Authority and subleased from the Authority the land and improvements constituting the City's police building and Carnegie Forum; and WHEREAS, in order to take advantage of prevailing bond market conditions, the City wishes to authorize the refinancing of the 2012 Bonds; and WHEREAS, the City further wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including a new animal shelter and park and playground improvements and upgrades (the "Project"); and WHEREAS, to that end, the City has proposed to lease the land and improvements constituting the City's police building and its Fire Station #2 (the "Leased, Property") to the Authority under a Site Lease, the form of which is on file with the Secretary, in consideration of the payment by the Authority of an upfront rental payment which is sufficient to provide funds to refinance the 2012 Bonds and finance the acquisition and construction of the Project; and WHEREAS, in order to raise funds for the upfront rental payment, the Authority proposes to issue and sell its Lodi Public Financing Authority 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) (the "Bonds") under Article 4 of Chapter 5, Division 7, Title 1 of the Government Code of the State of California, commencing with Section 6584 of said Code (the "Bond Law"); and WHEREAS, in order to secure the payments of principal of and interest on the Bonds, the Authority proposes to lease the Leased Property back to the City under a Lease Agreement (the "Lease Agreement"), the form of which is on file with the Secretary, under which the City is obligated to pay semiannual lease payments as rental for the Leased Property, and the Authority will assign substantially all of its rights under the Lease Agreement to U.S. Bank Trust Company, National Association, as trustee for the Bonds; and WHEREAS, there has been submitted to the Board of Directors a form of preliminary Official Statement in connection with the marketing of the Bonds and the Board of Directors, with the aid of its staff, has reviewed the preliminary Official Statement to assure proper disclosure of all material facts relating to the Bonds that are in the personal knowledge of the members of the Board of Directors; and WHEREAS, the Authority and the City propose to sell the Bonds to Piper Sandler & Co. (the "Underwriter") pursuant to a Bond Purchase Agreement (the "Bond Purchase Agreement"), the form of which is on file with the Secretary; and WHEREAS, as a condition precedent to the issuance by the Authority of the Bonds to provide financing for the Project, Section 6586.5 of the Bond Law requires that the City approve the proposed lease financing by the Authority and that the City make certain findings with respect to such financing, and Section 6586.5 further requires that such approval be given and findings be made only after a noticed public hearing; and WHEREAS, as required by Section 6586.5 of the Bond Law, the City has caused publication of a notice of a public hearing on the financing of the Project once at least five days prior to the hearing in a newspaper of general circulation in the City; and WHEREAS, the City Council held a public hearing at which all interested persons were provided the opportunity to speak on the subject of financing the Project; and WHEREAS, in accordance with Government Code Section 5852. 1, the Board of Directors has obtained and wishes to disclose the information set forth in Appendix A hereto; and WHEREAS, the Board of Directors wishes at this time to approve all proceedings to which it is a party relating to the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project. NOW, THEREFORE, BE IT RESOLVED by the Board of Directors of the Lodi Public Financing Authority as follows: SECTION 1. Issuance of Bonds. The Board of Directors hereby authorizes the issuance of the Bonds under the Bond Law in the maximum principal amount of $30,000,000, for the purpose of providing funds to refinance the 2012 Bonds and finance the Project. The Bonds shall be issued under the Bond Law and the Indenture of Trust that is approved below. SECTION 2. Approval of Related Financing Agreements. The Board of Directors hereby approves each of the following agreements required for the issuance and sale of the Bonds, the refinancing of the 2012 Bonds and the financing of the Project, in substantially the respective forms on file with the Secretary together with any changes therein or additions thereto deemed advisable by the Executive Director, the Treasurer or the General Counsel (each, an "Authorized Officer"), whose execution thereof shall be conclusive evidence of the approval of any such changes or additions. An Authorized Officer is hereby authorized and directed for and on behalf of the A-2 Authority to execute, and the Secretary is hereby authorized and directed to attest, the final form of each such agreement, as follows: • Indenture of Trust, between the Authority and U.S. Bank National Association, as trustee (the "Trustee"), setting forth the terms and provisions relating to the Bonds. • Site Lease, between the City as lessor and the Authority as lessee, under which the City leases the Leased Property to the Authority in consideration of the payment of an amount which will be applied by the City to refinance the 2012 Bonds and finance the Project. • Lease Agreement, between the Authority as lessor and the City as lessee, under which the Authority leases the Leased Property back to the City and the City agrees to pay semiannual lease payments which are sufficient to provide revenues with which to pay principal of and interest on the Bonds when due. ■ Assignment Agreement, between the Authority and the Trustee, whereby the Authority assigns certain of its rights under the Lease Agreement to the Trustee for the benefit of the Refunding Bond owners. • Bond Purchase Agreement, among the City, the Authority and the Underwriter, which establishes the terms under which the Underwriter will purchase the Bonds from the Authority. • Irrevocable Refunding Instructions, to be given by the Authority to the trustee for the 2012 Bonds, and to be consented to by the City, providing for the deposit, investment and application of funds to defease and redeem the 2012 Bonds. SECTION 3. Negotiated Sale of Bonds. The Board of Directors hereby authorizes and directs the negotiated sale of the Bonds to the Underwriter. The Bonds shall be sold at a true interest cost not to exceed 4.0%. The Underwriter's discount shall not exceed 1.0%. SECTION 4. Official Statement. The Board of Directors hereby approves the preliminary Official Statement describing the Bonds in substantially the form on file with the Secretary. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to said preliminary Official Statement and to execute an appropriate certificate stating the Authorized Officer's determination that the preliminary Official Statement (together with any changes therein or additions thereto) has been deemed nearly final within the meaning of Rule 15c2-12 of the Securities Exchange Act of 1934. Distribution of the preliminary Official Statement by the Underwriter is hereby approved. An Authorized Officer is hereby authorized and directed to approve any changes in or additions to a final form of said Official Statement, and the execution thereof by an Authorized Officer shall be conclusive evidence of approval of any such changes and additions. The Board of Directors hereby authorizes the distribution of the A-3 final Official Statement by the Underwriter. The final Official Statement shall be executed on behalf of the Authority by an Authorized Officer. SECTION 5. Official Actions. The Chair, the Executive Director, the Treasurer, the General Counsel and all other officers of the Authority are each authorized and directed on behalf of the Authority to make any and all assignments, certificates, requisitions, agreements (including an escrow deposit and trust agreement, if needed), notices, consents, instruments of conveyance and other documents, which they or any of them deem necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution, and the Executive Director may direct the Secretary to execute and deliver such other documents as the Executive Director determines are necessary or appropriate in order to consummate any of the transactions contemplated by the agreements and documents approved under this Resolution. An Authorized Officer may revise the identity of the Leased Property as necessary in order to accomplish the purposes of this Resolution. An Authorized Officer may approve the purchase of municipal bond insurance or a debt service reserve fund policy if the Authorized Officer, in consultation with the City's municipal advisor, concludes such purchase would be economically beneficial for the City. Whenever in this resolution any officer of the Authority is authorized to execute or countersign any document or take any action, such execution, countersigning or action may be taken on behalf of such officer by any person designated by such officer to act on his or her behalf if such officer is absent or unavailable. SECTION 6. Effective Date. This Resolution shall take effect immediately upon its passage and adoption. Dated: March 2, 2022 PASSED AND ADOPTED by the Board of Directors of the Lodi Public Financing Authority at a regular meeting held this 2nd day of March, 2022, by the following vote: AYES: COUNCIL MEMBERS — NOES: COUNCIL MEMBERS — ABSENT: COUNCIL MEMBERS — ABSTAIN: COUNCIL MEMBERS — Approved as to Form: Janice D. Magdich A-4 Mayor PAMELA M. FARRIS Assistant City Clerk 2022- A-5 APPENDIX A Government Code Section 5852.1 Disclosure The good faith estimates set forth herein are provided with respect to the Bonds in accordance with California Government Code Section 5852.1. Such good faith estimates have been provided to the City and the Authority by the Underwriter of the Bonds. Principal Amount. The Underwriter has informed the City and the Authority that, based on the financing plan and current market conditions, its good faith estimate of the aggregate principal amount of the Bonds to be sold is $26,475,000 (the "Estimated Principal Amount"), which excludes net premium that might be generated in the sale under current market conditions. True Interest Cost of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the true interest cost of the Bonds, which means the rate necessary to discount the amounts payable on the respective principal and interest payment dates to the purchase price received for the Bonds, is 3.34%. Finance Cham of the Bonds. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the finance charge for the Bonds, which means the sum of all fees and charges paid to third parties (or costs associated with the Bonds), is $611,071. Such fees and charges include fees for bond and disclosure counsel, municipal advisor, special tax consultant, fiscal agent, rating agencies, City and Authority expenses, City Attorney and staff time related to bond issuance, printing, and underwriting. Amount of Proceeds to be Received. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the amount of proceeds expected to be received for sale of the Bonds, less the finance charge of the Bonds, as estimated above, and any reserves or capitalized interest paid or funded with proceeds of the Bonds, is $28,330,255. Total Payment Amount. The Underwriter has informed the City and the Authority that, assuming that the Estimated Principal Amount of the Bonds is sold, and based on market interest rates prevailing at the time of preparation of such estimate, its good faith estimate of the total payment amount, which means the sum total of all payments that the Authority will make to pay debt service on the Bonds, plus the finance charge for the Bonds, as described above, not paid with the proceeds of the Bonds, calculated to the final maturity of the Bonds, is $44,134,950. W. The foregoing estimates constitute good faith estimates only. The actual principal amount of the Bonds issued and sold, the true interest cost thereof, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates, (b) the actual principal amount of Bonds sold being different from the Estimated Principal Amount, (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates, (d) the actual market interest rates at the time of sale of the Bonds being different than those estimated for purposes of such estimates, (e) other market conditions, or (f) alterations in the financing plan, delays in the financing, or a combination of such factors. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on the timing of the need for proceeds of the Bonds and other factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. A-7 CITY COUNCIL/PUBLIC FINANCING AUTHORITY MEETING 2022 Lease Revenue Bonds (2012 Refunding; Capital Projects Financing) 0-1 3/212022 Background It ', r 4 Z FO RNIA In 2012, the Lodi Public Financing Authority ("PFA") issued its Refunding Lease Revenue Bonds (the "2012 Bonds") 2012 Bonds were issued to refund outstanding certificates of participation • The 2012 Bonds are payable from Lease Payments made by the City to the Authority for the subleasing of the Leased Property Leased Property consists of Police Building and Carnegie Forum The 2012 Bonds are currently outstanding in a par amount of $13.315 million Final maturity of the 2012 Bonds is October 1, 2031 Annual debt service of the 2012 Bonds is approx. $1.68 million 2012 Bonds currently rated `A+' from S&P N r zi Overview �- LI CALIFORNIA In order to take advantage of prevailing bond market conditions, the City is proposing to refund the 2012 Bonds Additionally, the City wishes to leverage the savings achieved by refinancing the 2012 Bonds to finance the acquisition and construction of capital improvements, including new animal shelter and parks and playground improvements and upgrades (the "Project") Staff is proposing that the PFA issue lease revenue bonds (the "2022 Bonds") in order to provide funds for the refunding of the 2012 Bonds and finance the Project 3 Estimated Financing Structure C A L I F O ZRN I A One series of bonds to refund the 2012 Bonds and to finance the Project 0 Secured by Lease Payments from City's General Fund and other available funds for lease of certain pledged assets Pledged assets comprised of Police Building and Fire Station #2 0 Surety and insurance bids expected 0 Received credit rating on the bonds from S&P 4 Interest payments on April 1; principal and interest on October 1 3 Final maturity of October 1, 2052 0 2022 Bonds' annual debt service payments not expected to exceed the 2012 Bonds' max annual debt service payments 4 Estimated Financing Results $2.0 Sources ParAmount Premium Total Sources Uses Escrow Fund Project Fund Costs of Issuance Bond Insurance Surety Total Uses Estimated Sources and Uses* Refunding New Money Total $12,315,000 $14,160,000 $26,475,000 1,284,776 1,181,550 2,466,326 $13,599,776 $15,341,550 $28,941,326 $13,330,255 183,794 65,841 19,885 $15,000,000 208,317 110,369 22,865 $13,330,255 15,000,000 392,111 176,210 42,750 $13,599,776 $15,341,550 $28,941,326 Debt Service Comparison* CO zi CA L 1 FO ON I q 5 Bond Year *Preliminary, subject to change `ma 2022 Refunding 2022New Money �2012Bonds Tonight's Actions `r •�a�_iFORNIA Hold a Noticed Public Hearing Adopt Resolution of the City Council of the City of Lodi Making Findings and Approving Documents and Official Actions Relating to the Proposed Issuance by the Lodi Public Financing Authority of Lease Revenue Bonds to Refinance Outstanding Lease Revenue Bonds and Provide Financing for Acquisition and Construction of Capital Improvements, Including an Animal Shelter and Parks and Playground Improvements and Upgrades Adopt Resolution of Board of Directors of the Lodi Public Financing Authority Authorizing the Issuance and Sale of Lease Revenue Bonds to Refinance Outstanding Lease Revenue Bonds and Provide Financing for Acquisition and Construction of Capital Improvements, Including an Animal Shelter and Parks and Playground Improvements and Upgrades, and Approving Related Documents and Official Action 0 Summary of Financing Documents Official Statement - describes the 2022 Bonds, the relative risks associated with the purchase and other necessary information pertinent to investors Continuing Disclosure Certificate - which requires the City to submit annual continuing disclosure reports and notice of certain listed events to the marketplace as long as the 2022 Bonds are outstanding Bond Purchase Agreement - among the City, the Authority and the Underwriter, which establishes the terms under which the Underwriter will purchase the 2022 Bonds from the Authority Summary of Financing Documents a` �M ,Zi Z A_ i F O R N I A Site Lease - between the City and Authority whereby the City is leasing property to the Authority in consideration of the payment by the Authority of upfront rental payment Lease Agreement - between the Authority and the City, under which the City leases property to the Authority and the Authority leases property back to City Assignment Agreement— between the Authority and US Bank whereby the Authority assigns lease payments to US Bank to pay debt service to bondholders Indenture of Trust— between the Authority and US Bank, as Trustee, setting forth the terms and provisions relating to the 2022 Bonds Irrevocable Refunding Instructions - provides for the deposit, investment and application of funds to defease and redeem the 2012 Bonds 0 Next Steps* March 2 (Tonight) City Council/Board Approves Financing Documents *Preliminary, subject to change +/- March 10 Pricing Call a_iFOR N IA E SUBJECT: PUBLISH DATE: Please immediately confirm receipt o f this fax by calling 333-6702 CITY OF LODI P. O. BOX 3006 LODI, CALIFORNIA 95241-1910 ADVERTISING INSTRUCTIONS NOTICE OF PUBLIC HEARING TO CONSIDER FINANCING FOR ACQUISITION, DESIGN, AND CONSTRUCTION OF CAPITAL IMPROVEMENTS SATURDAY, FEBRUARY 19, 2022 TEAR SHEETS WANTED: One (1) please SEND AFFIDAVIT AND BILL TO: PAMELA M. FARRIS, ASSISTANT CITY CLERK LNS ACCT. #5100152 City of Lodi P.O. Box 3006 Lodi, CA 95241-1910 DATED: THURSDAY, FEBRUARY 17, 2022 ORDERED BY: PAMELA M. FARRIS ASSISTANT CITY CLERK 00 PAMELA M. FARRIS ASSISTANT CITY CLERK KAYLEE CLAYTON ADMINISTRATIVE CLERK Emailed to the Sentinel at legals@lodinews.com at '5 time) on 1 ate) (pages) forms\advins.doc DECLARATION OF POSTING NOTICE OF PUBLIC HEARING TO CONSIDER FINANCING FOR ACQUISITION, DESIGN, AND CONSTRUCTION OF CAPITAL IMPROVEMENTS On Thursday, February 17, 2022, in the City of Lodi, San Joaquin County, California, a copy of a Notice of Public Hearing to consider financing for acquisition, design, and construction of capital improvements (attached hereto, marked Exhibit "A") was posted at the following locations: Lodi City Clerk's Office Lodi City Hall Lobby Lodi Carnegie Forum WorkNet Office I declare under penalty of perjury that the foregoing is true and correct. Executed on February 17, 2022, at Lodi, California. PAMELA M. FARRIS ASSISTANT CITY CLERK ORDERED BY: PAMELA M. FARRIS ASSISTANT CITY CLERK KAY CLAYTON ADMINISTRATIVE CLERK \\cvcfilv01\administration$\Administration\CLERK\Public Hearings\AFFADAVITS\DECPOSTI.DOC CITY OF LORI . Carnegie Forum 305 West Pine Street, Lodi NOTICE OF PUBLIC HEARING Date: March 2, 2022 Time: , 7:00 p.m. For information regarding this notice please contact. Pamela M. Farris Assistant City Clerk Telephone: (209) 333-6702 NOTICE OF PUBLIC HEARING NOTICE IS HEREBY GIVEN that on Wednesday, March 2, 2022, at the hour of 7:00 p.m., or as soon thereafter as the matter may be heard, the City Council will conduct a public hearing at the Carnegie Forum, 305 West Pine Street, Lodi, to consider the following matter: a) Financing for acquisition, design, and construction of Capital Improvements. Information regarding this item may be obtained in the City Attorney's Office, 221 West Pine Street, Lodi, (209) 333-6701. All interested persons are invited to present their views and comments on this matter, Written statements may be filed with the City Clerk, City Hall, 221 West Pine Street, 2®d Floor, Lodi, 95240, at any time prior to the hearing scheduled herein, and oral statements may be made at said hearing. Comments may be made in person or via the following link: h tts:11asQ6web.zoom,us/181287658564? wd=VEJ4dm9mcFNYbTJXKzkIYUZX5VRmQT09 If you challenge the subject matter in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice or in written correspondence delivered to the City Clerk, 221 West Pine Street, at or prior to the close of the public hearing. By Order of the Lodi City Council: Pamela M. Farris Assistant City Clerk Dated: February 16, 2022 Approved as to form: Janice D. Magdich Janice D. Magdich City Attorney L Para obtener ayuda interpretativa con esta noticia, por favor Ilame a la oficina de la aria Municipal, a las (209) 333-6702. CLERKIPUBHEARINOTICESIPH NOTICE Cap! lallmprovemenlFinancing 2/14/22