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2018A General Certificate
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2018A General Certificate
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6/8/2026 8:47:38 AM
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6/8/2026 8:47:07 AM
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Bonds
Code
BON 00300
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BOND SALE
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PERMANENT
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the Bonds to be deemed to be an "arbitrage bond" within the meaning of Section 148 of the Code and <br />applicable Regulations. <br />15. No Federal Guarantee. The Bonds will not be "federally guaranteed" within the meaning <br />of Section 149(b) of the Code. For purposes of this Section 15, the Bonds are "federally guaranteed" if- <br />(i) the payment of principal or interest with respect to the Bonds is guaranteed, directly or indirectly (in <br />whole or in part) by the United States (or any agency or instrumentality thereof), or (ii) five percent (5%) <br />or more of the proceeds of the Bonds are (A) used to make loans the payment of principal or interest with <br />respect to which is to be guaranteed (in whole or in part) by the United States (or any agency of <br />instrumentality thereof) or (B) invested (directly or indirectly) in federally insured deposits or accounts. <br />For purposes of the preceding paragraph, the Bonds shall not be treated as "federally guaranteed" by <br />reason of any investment of proceeds of the Bonds (i) during the initial three-year temporary period until <br />such proceeds are needed for the governmental purpose for which the Bonds are being issued, (ii) during <br />the thirteen -month temporary period applicable to bona fide debt service fund investments, (iii) in bonds <br />issued by the United States Treasury, and (iv) in any other investments permitted by the Regulations. <br />16. Hedge Bonds. For purposes of Section 149(g) of the Code, the City represents and <br />certifies as follows: (i) the City reasonably expects that eighty-five percent (85%) of the spendable <br />proceeds of the Bonds will be used to carry out the governmental purposes of the Bonds within the <br />three-year period beginning on the date the Bonds are issued; and (ii) not more than fifty percent (50%) of <br />the proceeds of the Bonds are to be invested in nonpurpose investments (as defined in <br />Section 148(f)(6)(A) of the Code) having a substantially guaranteed yield for four years or more. <br />17. Investment of Proceeds. Any investments purchased with the proceeds of the Bonds will <br />be purchased at Fair Market Value. "Fair Market Value" shall mean a price at which a willing buyer <br />would purchase the investment from a willing seller in a bona fide, arm's length transaction. <br />18. No Other Facts. To the best knowledge and belief of the undersigned, there are no facts <br />or estimates, other than these contained in the underlying documents upon which this certification is <br />based, which would materially change the foregoing expectations. <br />19. No Notification From IRS. The undersigned have not been notified nor do they have any <br />knowledge to indicate that the City has been listed or is proposed to be listed by the Internal Revenue <br />Service as an issuer whose certifications may not be relied upon. <br />20. Not Arbitrage Bonds. On the basis of the foregoing, it is not expected that the proceeds <br />of the Bonds will be used in a manner that would cause the Bonds to be arbitrage bonds under <br />Sections 103 and 148 of the Code, and the rules and regulations promulgated under those sections, <br />including Sections 1.148-1 through 1.148-10 of the Regulations, as amended. <br />21. Post -Issuance Compliance. The City has adopted written procedures to (a) ensure that all <br />nonqualified bonds of this issue are remediated according to the requirements of the Code, and <br />(b) monitor the requirements of Section 148 of the Code. <br />22. Establishment of Issue Price. The provisions of Section 1.148-1(f)(2)(ii) of the <br />Regulations, which sets forth a special rule for use of determining the initial offering price of the Bonds to <br />the public, applies to the initial sale of the Bonds because the winning bidder agreed in writing that it will <br />neither offer nor sell the Bonds to any person at a price that is higher than the initial offering price to the <br />public during the period starting on the sale date (June 19, 2018) and ending on the earlier of the <br />following: (i) the close of the fifth business day after the sale date; or (ii) the date on which the winning <br />bidder has sold a substantial amount (ten percent (10%)) of the Bonds to the public at a price that is no <br />527553A GAF GE190-14 5 <br />
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