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HomeMy WebLinkAbout2018A GO Bonds Preliminary StatementPRELIMINARY OFFICIAL STATEMENT DATED JUNE 7, 2018 � � a E ° In the opinion of Kennedy & Graven, Chartered, Bond Counsel, based on present federal and Minnesota laws, regulations, rulings and decisions (which exclude any «a � opending legislation which may have a retroactive effect), and assuming compliance with certain covenants, interest to be paid on the Bonds is excludedfrom gross income a a for federal income tax purposes and, to the same extent. from taxable net income of individuals, estates and trusts for Minnesota income tax purposes, and is not a „ preference item for purposes of computing the federal alternative minimum tax (although interest on the Bonds is included in adjusted current earnings in calculating o E corporate alternative minimum taxable income for taxable years that began prior to January 1. 2018) or the Minnesota alternative minimum tax imposed on tndrorduals, a ° m trusts, and estates. Such interest is subject to Minnesota franchise taxes on corporations (including financial institutions) measured by income. No opinion will be " .2 ' terest on the Bonds or arisingwith respect to ownership expressed by Bond Counsel regarding other state orfederal tax consequences caused by the receipt or accrual of in E d of the Bonds. See "Tax Exemption" herein. ds ° The City will designate the Bonds as "qualified lax -exempt obligations"for purposes of Section 265(b)(3) of the Internal Revenue Code of 1986, as amended, relating to the ability offtnancial institutions to deduct from income for federal income tax purposes, interest expense that is allocable to carrying and acquiring lax -exempt ° .215 5 obligations. doa New Issue Rating Application Made: S&P Global Ratings u ovN a a.w CITY OF GEM LAKE, MINNESOTA q� (Ramsey County) d�U W � O o (Minnesota City Credit Enhancement Program) o v a�a $665,000* GENERAL OBLIGATION IMPROVEMENT BONDS, SERIES 2018A w ovv E PROPOSAL OPENING: June 19, 2018, 10:00 A.M., C.T. CONSIDERATION: June 19, 2018, 7:00 P.M., C.T. a .o " q PURPOSE/AUTHORITY/SECURITY: The $665,000* General Obligation Improvement Bonds, Series 2018A (the "Bonds") are being t v issued pursuant to Minnesota Statutes, Chapters 429 and 475, by the City of Gem Lake, Minnesota (the "City") for the purpose of E g a financing various public improvements within the City. The Bonds will be general obligations of the City for which its full faith, credit € and taxing powers are pledged. Delivery is subject to receipt of an approving legal opinion of Kennedy & Graven, Chartered, = o Minneapolis, Minnesota. T E DATE OF BONDS: July 12, 2018 MATURITY: February 1 as follows: E2 Year Amount* Year Amount* Year Amount* 0 2020 $35,000 2025 $40,000 2030 $45,000 c E 2021 40,000 2026 45,000 2031 50,000 2022 40,000 2027 45,000 2032 50,000 o .L 2023 40,000 2028 45,000 2033 50,000 e- . 2024 40,000 2029 45,000 2034 55,000 s W MATURITY * The City reserves the right to increase or decrease the principal amount of the Bonds on the day of o t ADJUSTMENTS: sale, in increments of $5,000 each. Increases or decreases may be made in any maturity. If any principal R ' amounts are adjusted, the purchase price proposed will be adjusted to maintain the same gross spread tea quo per $1,000. TERM BONDS: See "Term Bond Option" herein. o E.2 INTEREST: February 1, 2019 and semiannually thereafter. E N OPTIONAL REDEMPTION: Bonds maturing February 1, 2028 and thereafter are subject to call for prior redemption on February 1, 2027 and any date thereafter, at a price of par plus accrued interest. =° ° MINIMUM PROPOSAL: $655,025. o GOOD FAITH DEPOSIT: A good faith deposit in the amount of $13,300 shall be made by the winning bidder by wire transfer of E funds. «ate N 5 1 PAYING AGENT: Bond Trust Services Corporation 82 BOND COUNSEL: Kennedy & Graven, Chartered O " o y MUNICIPAL ADVISOR: Ehlers and Associates, Inc. « BOOK -ENTRY -ONLY: See "Book -Entry -Only System" herein (unless otherwise specified by the purchaser). EE m0 v_ PEEE RECEIVED z 0 TOWN OF WHITE BEAR REPRESENTATIONS No dealer, broker, salesperson or other person has been authorized by the City to give any information or to make any representation other than those contained in this Preliminary Official Statement and, if given or made, such other information or representations must not be relied upon as having been authorized by the City. This Preliminary Official Statement does not constitute an offer to sell or a solicitation of an offer to buy any of the Bonds in any jurisdiction to any person to whom it is unlawful to make such an offer or solicitation in such jurisdiction. This Preliminary Official Statement is not to be construed as a contract with the Syndicate Manager or Syndicate Members. Statements contained herein which involve estimates or matters of opinion are intended solely as such and are not to be construed as representations of fact. Ehlers & Associates, Inc. prepared this Preliminary Official Statement and any addenda thereto relying on information of the City and other sources for which there is reasonable basis for believing the information is accurate and complete. Bond Counsel has not participated in the preparation of this Preliminary Official Statement and is not expressing any opinion as to the completeness or accuracy of the information contained therein. Compensation of Ehlers & Associates, Inc., payable entirely by the City, is contingent upon the sale of the issue. COMPLIANCE WITH S.E.C. RULE 15c2-12 Certain municipal obligations (issued in an aggregate amount over $1,000,000) are subject to Rule 15c2-12 promulgated by the Securities and Exchange Commission pursuant to the Securities Exchange Act of 1934, as amended (the "Rule"). Preliminary Official Statement: This Preliminary Official Statement was prepared for the City for dissemination to potential investors. Its primary purpose is to disclose information regarding the Bonds to prospective underwriters in the interest of receiving competitive proposals in accordance with the sale notice contained herein. Unless an addendum is posted prior to the sale, this Preliminary Official Statement shall be deemed nearly final for purposes of the Rule subject to completion, revision and amendment in a Final Official Statement as defined below. Review Period: This Preliminary Official Statement has been distributed to prospective bidders for review. Comments or requests for the correction of omissions or inaccuracies must be submitted to Ehlers & Associates, Inc. at least two business days prior to the sale. Requests for additional information or corrections in the Preliminary Official Statement received on or before this date will not be considered a qualification of a proposal received from an underwriter. If there are any changes, corrections or additions to the Preliminary Official Statement, interested bidders will be informed by an addendum prior to the sale. Final Official Statement: Copies of the Final Official Statement will be delivered to the underwriter (Syndicate Manager) within seven business days following the proposal acceptance. Continuing Disclosure: Subject to certain exemptions, issues in an aggregate amount over $1,000,000 may be required to comply with provisions of the Rule which require that underwriters obtain from the issuers of municipal securities (or other obligated party) an agreement for the benefit of the owners of the securities to provide continuing disclosure with respect to those securities. This Preliminary Official Statement describes the conditions under which the Bonds are exempt or required to comply with the Rule. CLOSING CERTIFICATES Upon delivery of the Bonds, the underwriter (Syndicate Manager) will be furnished with the following items: (1) a certificate ofthe appropriate officials to the effect that at the time of the sale of the Bonds and all times subsequent thereto up to and including the time of the delivery of the Bonds, this Preliminary Official Statement did not and does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; (2) a receipt signed by the appropriate officer evidencing payment for the Bonds; (3) a certificate evidencing the due execution of the Bonds, including statements that (a) no litigation of any nature is pending, or to the knowledge of signers, threatened, restraining or enjoining the issuance and delivery of the Bonds, (b) neither the corporate existence or boundaries of the City nor the title of the signers to their respective offices is being contested, and (c) no authority or proceedings for the issuance of the Bonds have been repealed, revoked or rescinded; and (4) a certificate setting forth facts and expectations of the City which indicates that the City does not expect to use the proceeds of the Bonds in a manner that would cause them to be arbitrage bonds within the meaning of Section 148 of the Internal Revenue Code of 1986, as amended, or within the meaning of applicable Treasury Regulations. R TABLE OF CONTENTS INTRODUCTORY STATEMENT ........... . . ........ I FINANCIAL STATEMENTS .......................... A-1 THE BONDS ......................................... 1 FORM OF LEGAL OPINION .......................... B-1 GENERAL....................................... 1 OPTIONAL REDEMPTION ......................... 2 BOOK -ENTRY -ONLY SYSTEM ....................... C-1 AUTHORITY; PURPOSE ........................... 2 ESTIMATED SOURCES AND USES ................. 2 FORM OF CONTINUING DISCLOSURE CERTIFICATE ... D-1 SECURITY...................................... 2 RATING ......................................... 3 TERMS OF PROPOSAL .............................. E-1 STATE OF MINNESOTA CREDIT ENHANCEMENT PROGRAM.................................... 3 CONTINUING DISCLOSURE ....................... 4 LEGAL OPINION ................................. 4 TAX EXEMPTION ................................ 4 QUALIFIED TAX-EXEMPT OBLIGATIONS ........... 5 MUNICIPAL ADVISOR ............................ 5 MUNICIPAL ADVISOR AFFILIATED COMPANIES .... 6 INDEPENDENT AUDITORS ........................ 6 RISK FACTORS .................................. 6 VALUATIONS ....................................... 8 OVERVIEW ...................................... 8 CURRENT PROPERTY VALUATIONS ............... 9 2017/18 NET TAX CAPACITY BY CLASSIFICATION.. 10 TREND OF VALUATIONS ........................ 10 LARGER TAXPAYERS ........................... 11 DEBT.............................................. 12 DIRECT DEBT .................................. 12 SCHEDULES OF BONDED INDEBTEDNESS ......... 13 DEBT LIMIT .................................... 15 OVERLAPPING DEBT ............................ 15 DEBT RATIOS .................................. 16 DEBT PAYMENT HISTORY ....................... 16 FUTURE FINANCING ............................ 16 TAX RATES, LEVIES AND COLLECTIONS .............. 17 TAX LEVIES AND COLLECTIONS ................. 17 TAX CAPACITY RATES .......................... 17 LEVY LIMITS ................................... 18 THE ISSUER ........................................ 19 CITY GOVERNMENT ............................ 19 EMPLOYEES; PENSIONS; UNIONS ................ 19 POST EMPLOYMENT BENEFITS .................. 19 LITIGATION .................................... 19 MUNICIPAL BANKRUPTCY ...................... 19 FUNDS ON HAND ............................... 20 ENTERPRISE FUNDS ............................ 20 SUMMARY GENERAL FUND INFORMATION ....... 21 GENERAL INFORMATION ............................ 22 LOCATION ..................................... 22 LARGER EMPLOYERS ........................... 22 BUILDING PERMITS ............................. 23 U.S. CENSUS DATA .............................. 24 EMPLOYMENT/UNEMPLOYMENT DATA .......... 24 u CITY OF GEM LAKE CITY COUNCIL Robert Uzpen Mayor Faith Kuny Council Member Jim Linder Council Member Gretchen Artig-Swomley Council Member Len Cacioppo Council Member ADMINISTRATION Tori Leonhardt, City Administrator -Clerk Tom Kelly, City Treasurer PROFESSIONAL SERVICES Term Expires January 2021 January 2021 January 2021 January 2019 January 2019 Kennedy & Graven, Chartered, Bond Counsel, Minneapolis, Minnesota Ehlers & Associates, Inc., Municipal Advisors, Roseville, Minnesota (Other offices located in Waukesha, Wisconsin, Chicago, Illinois and Denver, Colorado) iv INTRODUCTORY STATEMENT This Preliminary Official Statement contains certain information regarding the City of Gem Lake, Minnesota (the "City") and the issuance of its $665,000* General Obligation Improvement Bonds, Series 2018A (the "Bonds"). Any descriptions or summaries of the Bonds, statutes, or documents included herein are not intended to be complete and are qualified in their entirety by reference to such statutes and documents and the form of the Bonds to be included in the resolution authorizing the sale of the Bonds ("Award Resolution") to be adopted by the City Council on June 19, 2018. Inquiries may be directed to Ehlers & Associates, Inc. ("Ehlers" or the "Municipal Advisor"), Roseville, Minnesota, (651) 697-8500, the City's Municipal Advisor. A copy of this Preliminary Official Statement may be downloaded from Ehlers' web site at www.ehlers-inc.com by connecting to the Bond Sales link and following the directions at the top of the site. THE BONDS GENERAL The Bonds will be issued in fully registered form as to both principal and interest in denominations of $5,000 each or any integral multiple thereof, and will be dated, as originally issued, as of July 12, 2018. The Bonds will mature on February 1 in the years and amounts set forth on the cover of this Preliminary Official Statement. Interest will be payable on February 1 and August 1 of each year, commencing February 1, 2019, to the registered owners of the Bonds appearing of record in the bond register as of the close of business on the 15th day (whether or not a business day) of the immediately preceding month. Interest will be computed upon the basis of a 360-day year of twelve 30- day months and will be rounded pursuant to rules of the Municipal Securities Rulemaking Board ("MSRB"). The rate for any maturity may not be more than 1.00% less than the rate for any preceding maturity. (For example, if a rate of 4.50% is proposed for the 2020 maturity, then the lowest rate that may be proposed for any later maturity is 3.50%.) All Bonds of the same maturity must bear interest from the date of issue until paid at a single, uniform rate. Each rate must be expressed in an integral multiple of 5/100 or 1/8 of 1%. Unless otherwise specified by the purchaser, the Bonds will be registered in the name of Cede & Co., as nominee for The Depository Trust Company, New York, New York ("DTC"). (See "Book -Entry -Only System" herein.) As long as the Bonds are held under the book -entry system, beneficial ownership interests in the Bonds may be acquired in book -entry form only, and all payments of principal of, premium, if any, and interest on the Bonds shall be made through the facilities of DTC and its participants. If the book -entry system is terminated, principal of, premium, if any, and interest on the Bonds shall be payable as provided in the Award Resolution. The City has selected Bond Trust Services Corporation, Roseville, Minnesota, to act as paying agent (the "Paying Agent"). Bond Trust Services Corporation and Ehlers are affiliate companies. The City will pay the charges for Paying Agent services. The City reserves the right to remove the Paying Agent and to appoint a successor. *Preliminary, subject to change. OPTIONAL REDEMPTION At the option of the City, the Bonds maturing on or after February 1, 2028 shall be subject to optional redemption prior to maturity on February 1, 2027 and on any date thereafter, at a price of par plus accrued interest. Redemption may be in whole or in part of the Bonds subject to prepayment. If redemption is in part, the selection of the amounts and maturities of the Bonds to be redeemed shall be at the discretion of the City. If only part of the Bonds having a common maturity date are called for redemption, then the City or Paying Agent, if any, will notify DTC of the particular amount of such maturity to be redeemed. DTC will determine by lot the amount of each participant's interest in such maturity to be redeemed and each participant will then select by lot the beneficial ownership interest in such maturity to be redeemed. Notice of redemption shall be sent by mail not more than 60 days and not less than 30 days prior to the date fixed for redemption to the registered owner of each Bond to be redeemed at the address shown on the registration books. AUTHORITY; PURPOSE The Bonds are being issued pursuant to Minnesota Statutes, Chapters 429 and 475, by the City for the purpose of financing construction of the 2018 Scheuneman Road Reconstruction Project in the City. ESTIMATED SOURCES AND USES* Sources Uses Par Amount of Bonds $665,000 Total Sources $665,000 Total Underwriter's Discount (1.500%) $9,975 Costs of Issuance 33,000 Deposit to Capitalized Interest (CIF) Fund 11,188 Deposit to Project Construction Fund 610,179 Rounding Amount 658 Total Uses $665,000 *Preliminary, subject to change SECURITY The Bonds are general obligations of the City for which its full faith, credit and taxing powers are pledged without limitation as to rate or amount. The City anticipates that the debt service will be paid from a combination of special assessments levied against properties benefitted by improvements financed by the Bonds and from ad valorem property taxes. The City anticipates the ad valorem taxes to be cancelled each year with available sewer revenues and any future water revenues. Receipt of special assessments and collection of ad valorem taxes will be sufficient to provide not less than 105% of principal and interest on the Bonds as required by Minnesota law. Should the revenues pledged for payment of the Bonds be insufficient to pay the principal and interest as the same shall become due, the City is required to pay maturing principal and interest from moneys on hand in any other fund of the City not pledged for another purpose and/or to levy additional taxes for this purpose upon all the taxable property in the City, without limitation as to rate or amount. RATING The City will be participating in the State of Minnesota Credit Enhancement Program ("MNCEP") for this issue and is requesting a rating from S&P Global Ratings ("S&P"). S&P has a policy which assigns a minimum rating of "AA+" to issuers participating in the MNCEP. The "AA+" rating is based on the State of Minnesota's current "AA+" rating from S&P. See "STATE OF MINNESOTA CREDIT ENHANCEMENT PROGRAM" for further details. Such rating reflects only the views of such organization and explanations of the significance of such rating may be obtained from the rating agency furnishing the same. Generally, a rating agency bases its rating on the information and materials furnished to it and on investigations, studies and assumptions of its own. There is no assurance that such rating will continue for any given period of time or that it will not be revised downward or withdrawn entirely by such rating agency, if in the judgement of such rating agency circumstances so warrant. Any such downward revision or withdrawal of such rating may have an adverse effect on the market price of the Bonds. Such rating is not to be construed as a recommendation of the rating agency to buy, sell or hold the Bonds, and the rating assigned by the rating agency should be evaluated independently. Except as may be required by the Disclosure Undertaking described under the heading "CONTINUING DISCLOSURE" neither the City nor the underwriter undertake responsibility to bring to the attention of the owner of the Bonds any proposed changes in or withdrawal of such rating or to oppose any such revision or withdrawal. The City currently does not have an underlying rating and will not be requesting an underlying rating on this issue. STATE OF MINNESOTA CREDIT ENHANCEMENT PROGRAM By resolution adopted for this issue on May 15, 2018 (the "Resolution"), the City has covenanted and obligated itself to be bound by the provisions of Minnesota Statutes, Section 446A.086 (the "Act"), which provides for payment by the State of Minnesota in the event of a potential default of certain obligations. The City has entered into a Credit Enhancement Program Agreement (the "Agreement") with the Minnesota Public Facilities Authority (the "Authority"), which is acting on behalf of the State of Minnesota. The provisions of the Agreement shall be binding on the City as long as any obligations of the issue remain outstanding. The City covenants in the Agreement to deposit with the paying agent for the issue three business days prior to the date on which a payment is due an amount sufficient to make that payment. Under the Agreement, if the City believes it may be unable to make a principal or interest payment for this issue on the due date, it must notify the Authority not less than 15 business days prior to the date a payment is due on the Bonds if the City will be unable to make all or a portion of the payment. The City's agreement with the Paying Agent for the Bonds requires the Paying Agent to immediately inform the Minnesota Commissioner of Management and Budget, with a copy to the Authority, if the Paying Agent becomes aware of a default or potential default in the payment of principal or interest on the Bonds, or if, on the day two business days before the date a payment is due on the Bonds, there are insufficient funds on deposit with the Paying Agent to make the payment. If the City is unable to make any portion of the payment on the Bonds on or before the date due, the State of Minnesota, acting through the Authority, shall make such payment in its place pursuant to the Act, providing that funds are available in the State General Fund. The obligation to make a payment under the Act is not a general obligation of the State of Minnesota. The Act does not obligate the Minnesota legislature to provide for the availability of funds in the General Fund for this purpose. CONTINUING DISCLOSURE In order to assist the underwriters in complying with Rule 15c2-12 promulgated by the Securities and Exchange Commission, pursuant to the Securities Exchange Act of 1934, as amended (the "Rule"), the City shall covenant to take certain actions pursuant to the Award Resolution adopted by the Common Council by entering into a Continuing Disclosure Certificate (the "Disclosure Undertaking") for the benefit of holders, including beneficial holders. The Disclosure Undertaking requires the City to provide electronically or in the manner otherwise prescribed certain financial information annually and to provide notices of the occurrence of certain events enumerated in the Rule. The details and terms of the Disclosure Undertaking for this issue are set forth in Appendix D to be executed and delivered by the City at the time of delivery of the Bonds. Such Disclosure Undertaking will be in substantially the form attached hereto. In the previous five years, the City believes it has not failed to comply in all material respects with its prior undertakings under the Rule. A failure by the City to comply with any Disclosure Undertaking will not constitute an event of default on this issue or any issue outstanding. However, such a failure may adversely affect the transferability and liquidity of the Bonds and their market price. The City will file its continuing disclosure information using the Electronic Municipal Market Access ("EMMA") system or any system that may be prescribed in the future. Investors will be able to access continuing disclosure information filed with the MSRB at www.emma.msrb.ore. LEGAL OPINION An opinion as to the validity of the Bonds and the exemption from taxation of the interest thereon will be furnished by Kennedy & Graven, Chartered, Minneapolis, Minnesota, Bond Counsel to the City, and will be available at the time of delivery of the Bonds. The legal opinion will state that the Bonds are valid and binding general obligations of the City; provided that the rights of the owners of the Bonds and the enforceability of the Bonds may be limited by bankruptcy, insolvency, reorganization, moratorium, and other similar laws affecting creditors' rights and by equitable principles (which may be applied in either a legal or equitable proceeding). See "FORM OF LEGAL OPINION" found in Appendix B. TAX EXEMPTION In the opinion of Bond Counsel, under existing statutes, regulations, rulings and decisions, interest on the Bonds is excluded from gross income of the owners thereof for purposes of federal income taxation and is excluded from taxable net income of individuals, estates or trusts for purposes of State of Minnesota income taxation, but is subject to State of Minnesota franchise taxes measured by income that are imposed upon corporations, including financial institutions. Noncompliance following the issuance of the Bonds with certain requirements of the Internal Revenue Code of 1986, as amended (the "Code") and covenants of the Award Resolution may result in the inclusion of interest on the Bonds in gross income (for federal tax purposes) and taxable net income (for State of Minnesota tax purposes) of the owners thereof. No provision has been made for redemption of the Bonds, or for an increase in the interest rate on the Bonds, in the event that interest on the Bonds becomes subject to United States or State of Minnesota income taxation. 4 The Code imposes an alternative minimum tax with respect to individuals on alternative minimum taxable income (although interest on the Bonds is included in adjusted current earnings in calculating corporate alternative minimum taxable income for taxable years that began prior to January 1, 2018). Adjusted current earnings include income received that is otherwise exempt from taxation such as interest on the Bonds. The Code provides that in the case of an insurance company subject to the tax imposed by Section 831 of the Code, the amount which otherwise would be taken into account as "losses incurred" under Section 832(b)(5) shall be reduced by an amount equal to the applicable percentage of the interest on the Bonds that is received or accrued during the taxable year. Interest on the Bonds may be included in the income of a foreign corporation for purposes of the branch profits tax imposed by Section 884 of the Code. Under certain circumstances, interest on the Bonds may be subject to the tax on "excess net passive income" of Subchapter S corporations imposed by Section 1375 of the Code. The above is not a comprehensive list of all federal tax consequences which may arise from the receipt of interest on the Bonds. The receipt of interest on the Bonds may otherwise affect the federal or State income tax liability of the recipient based on the particular taxes to which the recipient is subject and the particular tax status of other items or deductions. Bond Counsel expresses no opinion regarding any such consequences. All prospective purchasers of the Bonds are advised to consult their own tax advisors as to the tax consequences of, or tax considerations for, purchasing or holding the Bonds. Legislative proposals Bond Counsel's opinion is given as of its date and Bond Counsel assumes no obligation to update, revise, or supplement such opinion to reflect any changes in facts or circumstances or any changes in law that may hereafter occur. Proposals are regularly introduced in both the United States House of Representatives and the United States Senate that, if enacted, could alter or affect the tax-exempt status on municipal bonds. For example, legislation has been proposed that would, among other things, limit the amount of exclusions (including tax-exempt interest) or deductions that certain higher -income taxpayers could use to reduce their tax liability. The likelihood of adoption of this or any other such legislative proposal relating to tax-exempt bonds cannot be reliably predicted. If enacted into law, current or future proposals may have a prospective or retroactive effect and could affect the value or marketability of tax-exempt bonds (including the Bonds). Prospective purchasers of the Bonds should consult their own tax advisors regarding the impact of any such change in law. QUALIFIED TAX-EXEMPT OBLIGATIONS The City will designate the Bonds as "qualified tax-exempt obligations" for purposes of Section 265(b)(3) of the Code relating to the ability of financial institutions to deduct from income for federal income tax purposes, interest expense that is allocable to carrying and acquiring tax-exempt obligations. "Qualified tax-exempt obligations" are treated as acquired by a financial institution before August 8, 1986. Interest allocable to such obligations remains subject to the 20% disallowance under prior law. MUNICIPAL ADVISOR Ehlers has served as municipal advisor to the City in connection with the issuance of the Bonds. The Municipal Advisor cannot participate in the underwriting of the Bonds. The financial information included in this Preliminary Official Statement has been compiled by the Municipal Advisor. Such information does not purport to be a review, audit or certified forecast of future events and may not conform with accounting principles applicable to compilations of financial information. Ehlers is not a firm of certified public accountants. Ehlers is registered with the Securities and Exchange Commission and the MSRB as a Municipal Advisor. MUNICIPAL ADVISOR AFFILIATED COMPANIES Bond Trust Services Corporation ("BTSC") and Ehlers Investment Partners, LLC ("EIP") are affiliate companies of Ehlers. BTSC is chartered by the State of Minnesota and authorized in Minnesota, Wisconsin, and Illinois to transact the business of a limited purpose trust company. BTSC provides paying agent services to debt issuers. EIP is a Registered Investment Advisor with the Securities and Exchange Commission. EIP assists issuers with the investment of bond proceeds or investing other issuer funds. This includes escrow bidding agent services. Issuers, such as the City, have retained or may retain BTSC and/or EIP to provide these services. If hired, BTSC and/or EIP would be retained by the City under an agreement separate from Ehlers. INDEPENDENT AUDITORS The basic financial statements of the City for the fiscal year ended December 31, 2016 have been audited by CliftonLarsonAllen LLP, Minneapolis, Minnesota, independent auditors (the "Auditor"). The report of the Auditor, together with the basic financial statements, component units financial statements, and notes to the financial statements are attached hereto as "APPENDIX A — FINANCIAL STATEMENTS". The Auditor has not been engaged to perform and has not performed, since the date of its report included herein, any procedures on the financial statements addressed in that report. The Auditor also has not performed any procedures relating to this Preliminary Official Statement. RISK FACTORS Following is a description of possible risks to holders of the Bonds without weighting as to probability. This description of risks is not intended to be all-inclusive, and there may be other risks not now perceived or listed here. Taxes: The Bonds are general obligations of the City, the ultimate payment of which rests in the City's ability to levy and collect sufficient taxes to pay debt service should other revenue (special assessments) be insufficient. In the event of delayed billing, collection or distribution of property taxes, sufficient funds may not be available to the City in time to pay debt service when due. State Actions: Many elements of local government finance, including the issuance of debt and the levy of property taxes, are controlled by state government. Future actions of the state may affect the overall financial condition of the City, the taxable value of property within the City, and the ability of the City to levy and collect property taxes. Future Changes in Law: Various State and federal laws, regulations and constitutional provisions apply to the City and to the Bonds. The City can give no assurance that there will not be a change in or interpretation of any such applicable laws, regulations and provisions which would have a material effect on the City or the taxing authority of the City. Ratings; Interest Rates: In the future, the City's credit rating may be reduced or withdrawn, or interest rates for this type of obligation may rise generally, either possibility resulting in a reduction in the value of the Bonds for resale prior to maturity. Tax Exemption: If the federal government or the State of Minnesota taxes all or a portion of the interest on municipal obligations, directly or indirectly, or if there is a change in federal or state tax policy, the value of the Bonds may fall for purposes of resale. Noncompliance following the issuance of the Bonds with certain requirements of the Code and covenants of the Award Resolution may result in the inclusion of interest on the Bonds in gross income of the recipient for United States income tax purposes or in taxable net income of individuals, estates or trusts for State of Minnesota income tax purposes. No provision has been made for redemption of the Bonds, or for an increase in the interest rate on the Bonds, in the event that interest on the Bonds becomes subject to federal or State of Minnesota income taxation, retroactive to the date of issuance. Continuing Disclosure: A failure by the City to comply with the Disclosure Undertaking for continuing disclosure (see "CONTINUING DISCLOSURE") will not constitute an event of default on the Bonds. Any such failure must be reported in accordance with the Rule and must be considered by any broker, dealer, or municipal securities dealer before recommending the purchase or sale of the Bonds in the secondary market. Such a failure may adversely affect the transferability and liquidity of the Bonds and their market price. State Economy; State Aids: State of Minnesota cash flow problems could affect local governments and possibly increase property taxes. Book -Entry -Only System: The timely credit of payments for principal and interest on the Bonds to the accounts of the Beneficial Owners of the Bonds may be delayed due to the customary practices, standing instructions or for other unknown reasons by DTC participants or indirect participants. Since the notice of redemption or other notices to holders of these obligations will be delivered by the City to DTC only, there may be a delay or failure by DTC, DTC participants or indirect participants to notify the Beneficial Owners of the Bonds. Economy: A combination of economic, climatic, political or civil disruptions or terrorist actions outside of the control of the City, including loss of major taxpayers or major employers, could affect the local economy and result in reduced tax collections and/or increased demands upon local government. Real or perceived threats to the financial stability of the City may have an adverse effect on the value of the Bonds in the secondary market. Secondary Market for the Bonds: No assurance can be given that a secondary market will develop for the purchase and sale of the Bonds or, if a secondary market exists, that such Bonds can be sold for any particular price. The underwriters are not obligated to engage in secondary market trading or to repurchase any of the Bonds at the request of the owners thereof. Prices of the Bonds as traded in the secondary market are subject to adjustment upward and downward in response to changes in the credit markets and other prevailing circumstances. No guarantee exists as to the future market value of the Bonds. Such market value could be substantially different from the original purchase price. Bankruptcy: The rights and remedies of the holders may be limited by and are subject to the provisions of federal bankruptcy laws, to other laws, or equitable principles that may affect the enforcement of creditors' rights, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against local governments. The opinion of Bond Counsel to be delivered with respect to the Bonds will be similarly qualified. 7 VALUATIONS OVERVIEW All non-exempt property is subject to taxation by local taxing districts. Exempt real property includes Indian lands, public property, and educational, religious and charitable institutions. Most personal property is exempt from taxation (except investor -owned utility mains, generating plants, etc.). The valuation of property in Minnesota consists of three elements. (1) The estimated market value is set by city or county assessors. Not less than 20% of all real properties are to be appraised by local assessors each year. (2) The taxable market value is the estimated market value adjusted by all legislative exclusions. (3) The tax capacity (taxable) value of property is determined by class rates set by the State Legislature. The tax capacity rate varies according to the classification of the property. Tax capacity represents a percent of taxable market value. The property tax rate for a local taxing jurisdiction is determined by dividing the total tax capacity or market value of property within the jurisdiction into the dollars to be raised from the levy. State law determines whether a levy is spread on tax capacity or market value. Major classifications and the percentages by which tax capacity is determined are: Type of Property Residential homestead' Agricultural homestead' Agricultural non -homestead Seasonal recreational residential Residential non -homestead: Industrial/Commercial/Util ity' 2015/16 First $500,000 - 1.00% Over $500,000 - 1.25% First $500,000 HGA - 1.00% Over $500,000 HGA - 1.25% First $2,140,000 - 0.50% z Over $2,140,000 - 1.00%' Land - 1.00% z First $500,000 - 1.00%' Over $500,000 - 1.25%' 1 unit - 1 st $500,000 - 1.00% Over $500,000 - 1.25% 2-3 units - 1.25% 4 or more - 1.25% Small City 4 - 1.25% Affordable Rental: First $106,000 - .75% Over $106,000 - .25% First $150,000 - 1.50% Over $150,000 - 2.00% 2016/17 First $500,000 - 1.00% Over $500,000 - 1.25% First $500,000 HGA - 1.00% Over $500,000 HGA - 1.25% First $2,050,000 - 0.50%' Over $2,050,000 - 1.00% z Land - 1.00% z First $500,000 - 1.00%' Over $500,000 - 1.25%' 1 unit - 1st $500,000 - 1.00% Over $500,000 - 1.25% 2-3 units - 1.25% 4 or more - 1.25% Small City 4 - 1.25% Affordable Rental: First $115,000 - .75% Over $115,000 - .25% First $150,000 - 1.50% Over $150,000 - 2.00% 2017/18 First $500,000 - 1.00% Over $500,000 - 1.25% First $500,000 HGA - 1.00% Over $500,000 HGA - 1.25% First $1,940,000 - 0.50%2 Over $1,940,000 - 1.00%2 Land - 1.00% Z First $500,000 - 1.00%' Over $500,000 - 1.25%' 1 unit - 1st $500,000 - 1.00% Over $500,000 - 1.25% 2-3 units - 1.25% 4 or more - 1.25% Small City 4 - 1.25% Affordable Rental: First $121,000 - .75% Over $121,000 - .25% First $150,000 - 1.50% Over $150,000 - 2.00% A residential property qualifies as "homestead" if it is occupied by the owner or a relative of the owner on the assessment date. 2 Applies to land and buildings. Exempt from referendum market value tax. 3 Exempt from referendum market value tax. 4 Cities of 5,000 population or less and located entirely outside the seven -county metropolitan area and the adjacent nine -county area and whose boundaries are 15 miles or more from the boundaries of a Minnesota city with a population of over 5,000. 5 The estimated market value of utility property is determined by the Minnesota Department of Revenue. CURRENT PROPERTY VALUATIONS 2016/17 Economic Market Value $110.431.5351 2017/18 2017/18 Assessor's Estimated Net Tax Market Value Capacity Real Estate $109,242,300 $1,251,565 Personal Property 766,300 15,326 Total Valuation $110,008,600 $1,266,891 Less: Fiscal Disparities Contribution (139,622) Taxable Net Tax Capacity $1,127,269 Plus: Fiscal Disparities Distribution' 24,207 Adjusted Taxable Net Tax Capacity $1,151,476 According to the Minnesota Department of Revenue, the Assessor's Estimated Market Value (the "AEMV") for the City of Gem Lake is about 94.09% of the actual selling prices of property most recently sold in the City. The sales ratio was calculated by comparing the selling prices with the AEMV. Dividing the AEMV of real estate by the sales ratio and adding the AEMV of personal property and utility, railroads and minerals, if any, results in an Economic Market Value ("EMV") for the City of $110,431,535. 2 Each community in the seven -county metropolitan area contributes 40% of the growth in its commercial - industrial property tax base since 1972 to an area pool which is then distributed among the municipalities on the basis of population, special needs, etc. Each governmental unit makes a contribution and receives a distribution -- sometimes gaining and sometimes contributing net tax capacity for tax purposes. 0 2017/18 NET TAX CAPACITY BY CLASSIFICATION 2017/18 Percent of Total Net Tax Capacity Net Tax Capacity Residential homestead $ 666,627 52.62% Agricultural 2,200 0.17% Commercial/industrial 407,463 32.16% Non -homestead residential 149,695 11.82% Commercial & residential seasonal/rec. 25,580 2.02% Personal property 15,326 1.21 % Total $1,266,891 100.00% TREND OF VALUATIONS Assessor's Adjusted Assessor's Taxable Taxable Percent +/- in Levy Estimated Market Net Tax Net Tax Estimated Year Market Value Value Capacity' Capacity2 Market Value 2013/14 $87,053,000 $76,988,900 $ 972,912 $ 866,470 -5.99% 2014/15 91,031,000 81,794,200 1,021,435 917,463 +4.57% 2015/16 97,941,400 89,366,700 1,103,815 1,000,272 +7.59% 2016/17 103,949,600 94,614,300 1,177,923 1,074,813 +6.13% 2017/18 110,008,600 100,418,900 1,266,891 1,151,476 +5.83% Net Tax Capacity is before fiscal disparities adjustments. 2 Adjusted Taxable Net Tax Capacity is after fiscal disparities adjustments. 10 LARGER TAXPAYERS Percent of 2017/18 City's Total Net Tax Net Tax Taxpayer Type of Property Capacity Capacity Tousley Ford, Inc.' Commercial $ 65,206 5.15% Hansen Investments LLC Apartments 45,580 3.60% Barnett Properties Commercial 42,050 3.32% AMC Jeep Renault of White Bear, Inc. Commercial 33,594 2.65% Individuals Residential 29,405 2.32% DLW Properties LLC & C/O Waldoch Crafts Commercial 23,254 1.84% Individuals Residential 21,250 1.68% Individuals Residential 19,696 1.55% Gary Nelson Properties Commercial 19,200 1.52% Individuals Residential 19,043 1.50% Total $318,278 25.12% City's Total 2017/18 Net Tax Capacity $1,266,891 Source: Current Property Valuations, Net Tax Capacity by Classification, Trend of Valuations and Larger Taxpayers have been furnished by Ramsey County. ' Formerly listed as Tousley Ford. DEBT DIRECT DEBT' General Obligation Debt (see schedules following) Total g.o. debt being paid from taxes $ 655,000 Total g.o. debt being paid from special assessments and taxes (includes the Bonds)* 665,000 Total General Obligation Debt* $1,320 000 *Preliminary, subject to change. 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C)O C)O CD CD O O O O O O CD O O C m L L b4 'V O O O O O O O O O O O O O O O O '0 Q' 0) E C In O O O O O M LO LO LO Ln O C) CD LO MvvvvvvvvvvU)0LOLO LO (0 C: Y C Q a m E J C O d O Lu m 01 00 v 0 a+ T N LL N 0 C 0) O N M It Ln (D r�- 00 0) O N M V 0 3 (C ^ m O ate+ jp N N N N N N N N N N M M M M O O O O CD O O O CD O a O O O O } 4 LO c H N N N N N N N N N N N N N N N N t N QE Il UUSC�a Ln a) x co H 06 Q cn R a_ 14 DEBT LIMIT The statutory limit on debt of Minnesota municipalities other than school districts or cities of the first class (Minnesota Statutes, Section 475.53, subd. 1) is 3% of the Assessor's Estimated Market Value of all taxable property within its boundaries. "Net debt" (Minnesota Statutes, Section 475.51, subd. 4) is the amount remaining after deducting from gross debt: (1) obligations payable wholly or partly from special assessments levied against benefitted property (includes the Bonds); (2) warrants or orders having no definite or fixed maturity; (3) obligations issued to finance any public revenue producing convenience; (4) obligations issued to create or maintain a permanent improvement revolving fund; (5) funds held as sinking funds for payment of principal and interest on debt other than those deductible under 1-4 above; and (6) other obligations which are not to be included in computing the net debt of a municipality under the provisions of the law authorizing their issuance. 2017/18 Assessor's Estimated Market Value Multiply by 3% Statutory Debt Limit Less: Long -Term Debt Outstanding Being Paid Solely from Taxes Unused Debt Limit OVERLAPPING DEBT' 2017/18 Adjusted Taxable Net % In Taxing District Tax Capacity City Ramsey County $ 586,968,191 0.1962% I.S.D. No. 624 (White Bear Lake) 84,528,102 1.3622% Metropolitan Council 3,971,779,581 0.0290% City's Share of Total Overlapping Debt $110,008,600 0.03 $ 3,300,258 (655,000) $ 2,645,258 City's Total Proportionate G.O. Debt' Share $162,035,000 85,805,000 148,045,000 $ 317,913 1,168,836 42,933 $1,529,681 Overlapping debt is as ofthe dated date of the Bonds. Only those taxing jurisdictions with general obligation debt outstanding are included in this section. Does not include non -general obligation debt, self-supporting general obligation revenue debt, short-term general obligation debt, or general obligation tax/aid anticipation certificates of indebtedness. ' Outstanding debt is based on information in Official Statements obtained on EMMA and the Municipal Advisor's records. 3 The above debt includes all outstanding general obligation debt supported by taxes of the Metropolitan Council. The Council also has general obligation sewer revenue, wastewater revenue, and radio revenue bonds and lease obligations outstanding all of which are supported entirely by revenues and have not been included in the Overlapping Debt or Debt Ratios sections. 15 DEBT RATIOS Debt/ Current Debt/Economic Population Market Value Estimate G.O. Debt ($110,431,535) (463) Direct G.O. Debt Being Paid From: Taxes $ 655,000 Special Assessments & Taxes* 665,000 Total General Obligation Debt (includes the Bonds)* $1,320,000 1.20% $2,850.97 City's Share of Total Overlapping Debt 1,529,681 1.39% $3,303.85 Total* $2,849,681 2.58% $6,154.82 *Preliminary, subject to change. DEBT PAYMENT HISTORY The City has no record of default in the payment of principal and interest on its debt. FUTURE FINANCING The City has no current plans for additional financing in the next 12 months. 16 TAX RATES, LEVIES AND COLLECTIONS TAX LEVIES AND COLLECTIONS Net Tax Tax Year Levy' 2013/14 $ 230,068 2014/15 254,107 2015/16 294,764 2016/17 425,017 2017/18 439,281 Total Collected Collected Following Year to Date % Collected $ 224,520 $ 226,909 98.63% 246,688 248,934 97.96% 289,898 291,757 98.98% 432,711 432,711 101.81% ---------- In process of collection ------, Property taxes are collected in two installments in Minnesota --the first by May 15 and the second by October 15.3 Mobile home taxes are collectible in full by August 31. Minnesota Statutes require that levies (taxes and special assessments) for debt service be at least 105% of the actual debt service requirements to allow for delinquencies. TAX CAPACITY RATES4 Ramsey County City of Gem Lake I.S.D. No. 624 (White Bear Lake) Metropolitan Council Metro Mosquito Control Regional Rail Authority Referendum Market Value Rates: I.S.D. No. 624 (White Bear Lake) 2013/14 2014/15 2015/16 2016/17 2017/18 59.105% 54.462% 54.012% 51.173% 49.473% 26.550% 27.728% 29.536% 41.111% 39.361% 28.562% 26.660% 26.236% 23.476% 23.685% 2.729% 2.524% 2.379% 2.243% 2.153% 0.554% 0.511% 0.475% 0.455% 0.440% 4.196% 3.938% 4.091% 3.875% 3.830% 0.27299% 0.23976% 0.23536% 0.22996% 0.22280% Source: Tax Levies and Collections and Tax Capacity Rates have been furnished by Ramsey County. This reflects the Final Levy Certification of the City after all adjustments have been made. 2 Collections are through December 31, 2017. 3 Second half tax payments on agricultural property are due on November 15th of each year. 4 After reduction for state aids. Does not include the statewide general property tax against commercial/industrial, non -homestead resorts and seasonal recreational residential property. 17 LEVY LIMITS The State Legislature has periodically imposed limitations on the ability of municipalities to levy property taxes. For taxes levied in 2013, payable in 2014, only, the Legislature imposed a one year levy limit on all counties with a population greater than 5,000, and all cities with a population greater than 2,500. While these limitations have expired, the potential exists for future legislation to limit the ability of local governments to levy property taxes. All previous limitations have not limited the ability to levy for the payment of debt service on bonded indebtedness. For more detailed information about Minnesota levy limits, contact the Minnesota Department of Revenue or Ehlers & Associates. 18 THE ISSUER CITY GOVERNMENT The City of Gem Lake was organized as a municipality in 1959. The City operates under a statutory form of government consisting of a five -member City Council of which the Mayor is a voting member. The City Administrator -Clerk and City Treasurer are responsible for administrative details and financial records. EMPLOYEES; PENSIONS; UNIONS The City currently has one full-time employee and no part-time or seasonal employees. All full-time employees of the City are covered by defined benefit pension plans administered by the Public Employee Retirement Association of Minnesota (PERA). PERA administers the General Employees Retirement Fund (GERF) and the Public Employees Police and Fire Fund (PEPFF) which are cost -sharing multiple -employer retirement plans. PERA members belong to either the Coordinated Plan or the Basic Plan. Coordinated members are covered by Social Security. See the Notes to Financial Statements in Appendix A for a detailed description of the Plans. Recognized and Certified Bargaining Units The City does not have any certified bargaining units. POST EMPLOYMENT BENEFITS The City does not pay directly for retirees' post -employment benefits. LITIGATION There is no litigation threatened or pending questioning the organization or boundaries of the City or the right of any of its officers to their respective offices or in any manner questioning their rights and power to execute and deliver the Bonds or otherwise questioning the validity of the Bonds. MUNICIPAL BANKRUPTCY Municipalities are prohibited from filing for bankruptcy under Chapter 11 (reorganization) or Chapter 7 (liquidation) of the U.S. Bankruptcy Code (11 U.S.C. §§ 101-1532) (the "Bankruptcy Code"). Instead, the Bankruptcy Code permits municipalities to file a petition under Chapter 9 of the Bankruptcy Code, but only if certain requirements are met. These requirements include that the municipality must be "specifically authorized" under State law to file for relief under Chapter 9. For these purposes, "State law" may include, without limitation, statutes of general applicability enacted by the State legislature, special legislation applicable to a particular municipality, and/or executive orders issued by an appropriate officer of the State's executive branch. As of the date hereof, Minnesota Statutes, 471.831, authorizes municipalities to file for bankruptcy relief under Chapter 9 of the Bankruptcy Code. A municipality is defined in United States Code, title 11, section 101, as amended through December 31, 1996, but limited to a county, statutory or home rule charter city, or town; or a housing and redevelopment authority, economic development authority, or rural development financing authority established under Chapter 469, a home rule charter or special law. r FUNDS ON HAND (As of April 30, 2018) Total Cash Fund and Investments General $ 253,400 Special Revenue 40,173 Debt Service 101,155 Capital Projects (248,059) Enterprise Funds 426,022 Total Funds on Hand $ 572,692 ENTERPRISE FUNDS Revenues available for debt service on the City's enterprise funds have been as follows as of December 31 each year: 2014 2015 2016 Sewer Utility Total Operating Revenues $ 49,582 $ 65,286 $ 45,117 Less: Operating Expenses (48,559) (50,205) (42,720) Operating Income $ 1,023 $ 15,081 $ 2,397 Plus: Depreciation 12,456 12,457 12,457 Revenues Available for Debt Service $ 13,479 $ 27,538 $ 14,854 i To be reimbursed from the proceeds of the Bonds. 20 SUMMARY GENERAL FUND INFORMATION Following are summaries of the revenues and expenditures and fund balances for the City's General Fund. These summaries are not purported to be the complete audited financial statements of the City, and potential purchasers should read the included financial statements in their entirety for more complete information concerning the City. Copies of the complete statements are available upon request. Appendix A includes the City's 2016 audited financial statements. FISCAL YEAR ENDING DECEMBER 31 COMBINED STATEMENT 2018 2014 2015 2016 2017 Adopted Audited Audited Audited Unaudited Budget' Revenues Property taxes Special assessments Intergovernmental Fees, licenses and permits Fines and forfeitures Charges for services Investment earnings Other miscellaneous revenues Total Revenues Expenditures Current: General government Public safety Public works Conservation and Development Capital outlay Total Expenditures Excess of revenues over (under) expenditures Other Financing Sources (Uses) Operating transfers in Operating transfers out Total Other Financing Sources (Uses) Net Changes in Fund Balances General Fund Balance January 1 Prior Period Adjustment Residual Equity Transfer in (out) General Fund Balance December 31 $ 186,063 $ 202,511 $ 223,118 $ 359,657 $ 369,252 0 0 799 0 0 3,393 13,348 9,796 16,618 8,500 57,674 39,222 34,108 45,672 31,200 3,048 2,182 3,210 3,152 3,000 7,616 12,927 5,705 36,949 3,800 2,877 1,677 1,701 869 1,195 21,252 53,969 17,084 5,881 6,500 $ 281,923 $ 325,836 $ 295,521 $ 468,798 $ 423,447 $ 107,590 $ 124,999 $ 134,037 $ 216,275 $ 270,197 109,973 115,115 119,793 133,361 96,750 79,801 102,228 37,508 18,837 36,300 50,892 44,647 51,122 0 0 0 0 0 0 0 $ 348,256 $ 386,989 $ 342,460 $ 368,473 $ 403,247 $ (66,333) $ (61,153) $ (46,939) $ 100,325 $ 20,200 $ 0 $ 0 $ 0 $ 0 0 0 0 0 $ 0 $ 0 $ 0 $ 0 $ (66,333) $ (61,153) $ (46,939) $ 100,325 388,010 321,677 260,524 213,585 0 0 0 0 0 0 0 0 $ 321,677 $ 260,524 $ 213,585 $ 313,910 DETAILS OF DECEMBER 31 FUND BALANCE Nonspendable $ 931 $ 633 $ 926 $ 666 Unassigned 320,746 259,891 212,659 313,244 Total $ 321,677 $ 260,524 $ 213,585 $ 313,910 ' The 2018 budget was adopted on November 21, 2017. 21 GENERAL INFORMATION LOCATION The City of Gem Lake, with a 2010 U.S. Census population of 393 and a current population estimate of 463, and comprising an area of 721 acres, is located approximately 8.6 miles northeast ofthe Minneapolis -St. Paul metropolitan area, and 2.4 miles west of the City of White Bear Lake. LARGER EMPLOYERS' Larger employers in the City of Gem Lake include the following: Estimated No. Firm Type of Business/Product of Employees Auto Nation Automobile dealer 250 Barnett KIA Automobile dealership 65 Tundra Companies Electronic parts assemblers 65 NewTrax Transportation for adults w/disabilities 60 The Trike Shop Motorcycle & motor scooter dealer 25 PAI Disability services 22 Gem Lake Golf Course Golf course & country club 20 Nelson Marine Boat dealer sales & service 15 Cafe Cravings Restaurant 10 White Bear Floral Florist 10 Source: Reference USA, written and telephone survey (May 2018), and the Minnesota Department ofEmployment and Economic Development. This does not purport to be a comprehensive list and is based on available data obtained through a survey of individual employers, as well as the sources identified above. Some employers do not respond to inquiries for employment data. 22 BUILDING PERMITS New Single Family Homes No. of building permits Valuation All Building Permits (including additions and remodelings) No. of building permits Valuation Source: The City. As of May 14, 2018. 2014 2015 2016 2017 2018' 5 1 1 2 2 $2,705,000 $500,000 $800,000 $940,000 $558,000 23 21 28 24 8 $3,056,815 $1,414,851 $1,085,721 $1,191,854 $623,500 23 0 U.S. CENSUS DATA Population Trend: City of Gem Lake, Minnesota 2000 U.S. Census population 2010 U.S. Census population 2016 State Demographer's Estimate Percent of Change 2000 - 2010 Income and Age Statistics 2016 per capita income 2016 median household income 2016 median family income 2016 median gross rent 2016 median value owner occupied units 2016 median age City % of 2016 per capita income City % of 2016 median family income Housing Statistics All Housing Units 419 393 463 -6.21 % City of Ramsey State of United Gem Lake County Minnesota States $56,371 $31,256 $33,225 $29,826 $118,750 $57,717 $63,217 $55,322 $130,000 $75,578 $79,595 $67,871 $1,146 $892 $873 $928 $295,500 $199,200 $191,500 $184,700 41.2 yrs. 34.6 yrs. 37.8 yrs. 37.7 yrs. State of Minnesota 169.66% 163.33% Cite or Gem Lake 2000 2016 145 181 United States 189.00% 191.54% Percent of Change 24.83% Source: 2000 and 2010 Census of Population and Housing, and 2016 American Community Survey (Based on a five-year estimate), U.S. Census Bureau (1vww. act tnder2.census.gov). EMPLOYMENT/UNEMPLOYMENT DATA Rates are not compiled for individual communities within counties. Average Employment Year Ramsey County 2014 265,141 2015 267,618 2016 270,438 2017 276,945 2018, April 282,427 Average Unemployment Ramsey County State of Minnesota 4.0% 4.2% 3.6% 3.7% 3.6% 3.8% 3.3% 3.5% 2.7% 3.1 % Source: Minnesota Department of Employment and Economic Development. 24 APPENDIX A FINANCIAL STATEMENTS Potential purchasers should read the included financial statements in their entirety for more complete information concerning the City's financial position. Such financial statements have been audited by the Auditor, to the extent and for the periods indicated thereon. The City has not requested the Auditor to perform any additional examination, assessments or evaluation with respect to such financial statements since the date thereof, nor has the City requested that the Auditor consent to the use of such financial statements in this Official Statement. Although the inclusion of the financial statements in this Official Statement is not intended to demonstrate the fiscal condition of the City since the date of the financial statements, in connection with the issuance of the Bonds, the City represents that there have been no material adverse change in the financial position or results of operations of the City, nor has the City incurred any material liabilities, which would make such financial statements misleading. Copies of the complete audited financial statements for the past three years and the current budget are available upon request from Ehlers. A-1 CITY OF GEM LAKE, MINNESOTA FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION YEAR ENDED DECEMBER 31, 2016 CITY OF GEM LAKE 4200 OTTER LAKE ROAD GEM LAKE, MINNESOTA 55110 A-2 Clifton LarsonAllen LLP CLAconnect.com Clifton Larson All n INDEPENDENT AUDITORS' REPORT Honorable Mayor Members of the City Council and Citizens City of Gem Lake Gem Lake, Minnesota Report on the Financial Statements We have audited the accompanying financial statements of the governmental activities, the business - type activities, each major fund, and the aggregate remaining fund information of the City of Gem Lake (the City), Minnesota as of and for the year ended December 31, 2016, and the related notes to the financial statements, which collectively comprise the City's basic financial statements as listed in the table of contents. Management's Responsibility for the Financial Statements Management is responsible for the preparation and fair presentation of these financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. Auditors' Responsibility Our responsibility is to express opinions on these financial statements based on our audit. We conducted our audit in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditors' judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the City's preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the City's internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions. A member of Nexia International A-3 Honorable Mayor Members of the City Council and Citizens City of Gem Lake, Minnesota Opinions In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of the governmental activities, the business -type activities, each major fund, and the aggregate remaining fund information of the City of Gem Lake, Minnesota as of December 31, 2016, and the respective changes in financial position and cash flows, where applicable, thereof for the year then ended in conformity with accounting principles generally accepted in the United States of America. Report on Summarized Comparative Information We have previously audited the City of Gem Lake's 2015 financial statements of the governmental activities, the business -type activities, each major fund, and the aggregate remaining fund information, and we expressed unmodified audit opinions on those financial statements in our report dated May 10, 2016. In our opinion, the summarized comparative information presented herein as of and for the year ended December 31, 2015 is consistent, in all material respects, with the audited financial statements from which it has been derived. Other Matters Required Supplementary Information Accounting principles generally accepted in the United States of America required that the budgetary comparison information as listed in the table of contents, be presented to supplement the basic financial statements. Such information, although not a part of the basic financial statements, is required by the Governmental Accounting Standards Board who considers it to be an essential part of financial reporting for placing the basic financial statements in an appropriate operational, economic, or historical context. We have applied certain limited procedures to the required supplementary information in accordance with auditing standards generally accepted in the United States of America, which consisted of inquiries of management about the methods of preparing the information and comparing the information for consistency with management's responses to our inquiries, the basic financial statements, and other knowledge we obtained during our audit of the basic financial statements. We do not express an opinion or provide any assurance on the information because the limited procedures do not provide us with sufficient evidence to express an opinion or provide any assurance. Management has omitted the management's discussion and analysis that accounting principles generally accepted in the United States of America require to be presented to supplement the basic financial statements. Such missing information, although not a part of the basic financial statements, is required by the Governmental Accounting Standards Board who considers it to be an essential part of financial reporting for placing the basic financial statements in an appropriate operations, economic, or historical context. Our opinion on the basic financial statements is not affected by this missing information. Supplementary Information Our audit was conducted for the purpose of forming opinions on the financial statements that collectively comprise the City's basic financial statements. The accompanying combining nonmajor fund financial statements, as listed in the table of contents, are presented for purposes of additional analysis and are not a required part of the basic financial statements. A-4 Honorable Mayor Members of the City Council and Citizens City of Gem Lake, Minnesota Other Matters (Continued) Supplementary Information (Continued) The combining nonmajor fund financial statements are the responsibility of management and were derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. The information has been subjected to the auditing procedures applied in the audit of the basic financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the financial statements or to the financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the supplementary information is fairly stated in all material respects in relation to the basic financial statements taken as a whole Other Reporting Required by Government Auditing Standards In accordance with Government Auditing Standards, we have also issued our report dated on our consideration of the City of Gem Lake; Minnesota's internal control over financial reporting and on our tests of its compliance with certain provisions of laws, regulations, contracts, grant agreements, and other matters. The purpose of that report is to describe the scope of our testing of internal control over financial reporting and compliance and the results of that testing and not to provide an opinion on the internal control over financial reporting or on compliance. That report is an integral part of an audit performed in accordance with Government Auditing Standards and should be considered in assessing the results of our audit. v CliftonLarsonAllen LLP Minneapolis, Minnesota June 20, 2017 A-5 CITY OF GEM LAKE, MINNESOTA STATEMENT OF NET POSITION DECEMBER 31, 2016 ASSETS Cash and Investments Taxes Receivable Special Assessments Receivable Accounts Receivable Due from Other Governments Accrued Interest Prepaid Items Internal Balances Capital Assets: Capital Assets Being Depreciated Accumulated Depreciation Total Assets LIABILITIES Vouchers and Accounts Payable Accrued Interest Payable Due to Other Governments Payroll Taxes and Withholdings Unearned Revenue Long -Term Liabilities: Amounts Due Within One Year Amounts Due in More than One Year Total Liabilities NET POSITION Net Investment in Capital Assets Restricted for Debt Service Restricted for Park Improvements Restricted for Street Projects Unrestricted Total Net Position See accompanying Notes to Basic Financial Statements. Governmental Business -Type Activities Activities Total $ 565,337 $ 39,256 $ 604,593 21,317 - 21,317 491,601 3,253 494,854 6,828 15,970 22,798 856 - 856 498 1,207 1,705 926 2,526 3,452 (397,252) 397,252 2,046,271 617,539 2,663,810 (682,481) (149,257) (831,738) 2,053,901 927,746 2,981,647 8,954 7,033 3,065 484 11,300 60,000 715,000 805,836 8,954 7,033 3,065 484 11,300 60,000 715,000 805,836 593,813 468,282 1,062,095 181,785 181,785 39,872 39,872 3,194 - 3,194 429,401 459,464 888,865 $ 1,248,065 $ 927,746 $ 2,175,811 A-6 FUNCTIONS/PROGRAMS GOVERNMENTAL ACTIVITIES General Government Public Safety Public Works Conservation and Development Interest and Fiscal Charges Total Governmental Activities BUSINESS -TYPE ACTIVITIES Sewer Total Primary Government CITY OF GEM LAKE, MINNESOTA STATEMENT OF ACTIVITIES YEAR ENDED DECEMBER 31, 2016 Expenses Net (Expense) Revenue and Program Revenues Changes in Net Position Fees, Charges, Operating Capital Business - Fines, and Grants and Grants and Governmental Type Other Contributions Contributions Activities Activities $ 157,813 $ 119,793 79,690 51,122 34.842 443,260 Total 39,305 $ 8,572 $ 799 $ (109,137) $ $ (109.137) - - - (119,793) (119,793) 20,776 25.460 (33,432) (33,432) (51,122) (51,122) (34,842) (34,842) 60,083 8.572 26.279 (348.326) (348,326) 42,720 45,117 S 485 980 5 05.200 S a.572 S 26,279 GENERAL REVENUES Taxes: Property Taxes, Levied for General Purposes Property Taxes, Levied for Debt Service Investment Earnings (Loss) Miscellaneous Total General Revenues CHANGE IN NET POSITION Net Position - Beginning of Year NET POSITION - END OF YEAR See accompanying Notes to Basic Financial Statements. 2,397 2,397 (348,326) 2,397 (345,929) 224,696 - 224,896 69,261 69.261 (377) 4,211 3,834 1.248 - 1,248 295.028 4.211 299,239 (53,298) 6,608 (46,690) 301 363 921.' 38 2.222.501 5 1.248.065 S 927,74E S 2,175.811 A-7 CITY OF GEM LAKE, MINNESOTA BALANCE SHEET GOVERNMENTAL FUNDS DECEMBER 31, 2016 (WITH SUMMARIZED FINANCIAL INFORMATION AS OF DECEMBER 31, 2015) GO Capital 2016 Improvement Hoffman Street Other Total General Plan Bonds Road Improvements Governmental Governmental 2015 Fund Series 2007A Fund Fund Funds Funds Totals ASSETS Cash and Investments $ 220,556 S 118,846 S S 132 932 S 93,004 $ 565,337 S 462.297 Cash with Fiscal Agent - - - - - 740.503 Taxes Receivable 16,541 4,776 - - 21,317 14,282 Special Assessments Receivable 475,361 16,240 491,601 541,856 Accounts Receivable 6,828 - 6,628 5,972 Due from Other Governments 856 856 1,153 Accrued Interest Receivable 565 243 (943) 393 240 498 2,474 Due from Other Funds 1,464 1.464 126.505 Prepaid Items 926 926 633 Total Assets S 247.736 S 123,854 S 47g418 5 133.325 S 109.484 S 1,088.827 S 1895.676 LIABILITIES, DEFERRED INFLOWS OF RESOURCES, AND FUND BALANCES LIABILITIES Voucners and Accounts Payable 8 954 S S S - S - S 8,954 S 20.233 Payroll Deductions 484 - 464 387 Due to Other Governments 3.065 3,065 14,035 Unearned Revenue 11.300 11.300 11.300 Due to Other Funds 397,252 1.464 398, 716 126,506 Total Liabilities 23.802 - 397,252 - 1,464 422,519 172,461 DEFERRED INFLOWS OF RESOURCES Unavailable Resources 10,348 2,849 468,851 15,751 497,799 550,862 FUND BALANCES Nonspendable 926 926 633 Restricted Debt Service - 121 015 50,867 171,662 867.210 Park Improvements - 39,672 39,872 39,462 Street Projects 3,194 3.194 3.161 Assigned: Individual Property Owners 133,325 133,325 132.336 Unassigned 212,659 130* al 1 (1,464) 11804Aa 129,551 Total Fund Balances 217.!Sd 121.015 1181 f185; 133,325 92.269 168.509 1,172,353 Total Liabilities, Deal -red Inflows of Resources, and Fund Balances S 2,17.736 S 123 664 S .174416 S 133.325 S 109,404 S 1.088,827 5 1.895,676 See accompanying Notes to Basic Financial Statements Han A-8 CITY OF GEM LAKE, MINNESOTA RECONCILIATION OF THE GOVERNMENTAL FUNDS BALANCE SHEET TO THE STATEMENT OF NET POSITION GOVERNMENTAL ACTIVITIES DECEMBER 31, 2016 TOTAL FUND BALANCES FOR GOVERNMENTAL FUNDS Total net position reported for governmental activities in the statement of net position is different because: Capital assets used in governmental activities are not financial resources and, therefore, are not reported in the funds. These capital assets consist of: Buildings Office Equipment Infrastructure Accumulated Depreciation Some of the City's property taxes and special assessments will be collected after year-end, but are not available soon enough to pay for the current period's expenditures and, therefore, are reported as unavailable resources in the governmental funds Some liabilities are not due and payable in the current period and, therefore, are not reported as fund liabilities. Balances at year-end are: General Obligation Bonds Payable Accrued Interest on Long -Term Debt TOTAL NET POSITION OF GOVERNMENTAL ACTIVITIES See accompanying Notes to Basic Financial Statements. $ 902,232 12,895 1,131,144 (682,481) $ 168,509 1,363,790 497,799 (775,000) (7,033) (782,033) $ 1,248,065 A-9 CITY OF GEM LAKE, MINNESOTA STATEMENT OF REVENUES, EXPENDITURES, AND CHANGES IN FUND BALANCES GOVERNMENTAL FUNDS YEAR ENDED DECEMBER 31, 2016 (WITH SUMMARIZED FINANCIAL INFORMATION FOR YEAR ENDED DECEMBER 31, 2015) GO Capital 2016 Improvement Hoffman Street Other Total General Plan Bonds Road Improvements Governmental Governmental 2015 Fund Series 2007A Fund Fund Funds Funds Totals REVENUES Taxes $ 223,118 $ 69,261 $ 5 $ $ 292,379 $ 251,341 Special Assessments 799 - 65,938 14,383 01,120 42,427 Intergovernmental 9,796 9,796 13,348 Licenses and Permits 34,108 34,108 39,222 Fines and Forfeits 3,210 3,210 2,182 Public Charges for Services 5,705 5,705 12,927 Miscellaneous: Earnings (Loss) on Investments 1,701 943 (5,024) 989 1,014 (377) 3,350 Other 17,084 17,084 53,969 Total Revenues 295,521 70,204 60,914 989 15,397 443,026 418,766 EXPENDITURES Current: General Govemment 134,037 134,037 124,999 Public Safely 119,793 119,793 115,115 Public Works 37.508 37.508 102,228 Conservation and Development 51,122 51,122 44,647 Capital Outlay 323,988 323,988 118,856 Debi Service: Principal 745,000 745,000 15,000 Interest and Fiscal Charges 35,421 35,421 32,904 Debt Issuance Costs 29,985 Total Expenditures 342,460 780,421 323.988 1,446,869 583,734 NET CHANGE IN FUND BALANCES (46.939) (710,217) (263.074) 969 15.397 (1,003,844) 610,032 Fund Balances- Beginning of Year 260,524 831,232 (128,611) 132,336 76.872 1,172,353 562,321 FUND BALANCES - END OF YEAR $ 213.585 5 121,Oi5 $ 1391 685P $ 133,325 $ 42,269 $ 168,509 $ 1,172,353 See accompanying Notes to Basic Financial Statements. A-10 CITY OF GEM LAKE, MINNESOTA RECONCILIATION OF THE GOVERNMENTAL FUNDS STATEMENT OF REVENUES, EXPENDITURES, AND CHANGES IN FUND BALANCE TO THE STATEMENT OF ACTIVITIES GOVERNMENTAL ACTIVITIES YEAR ENDED DECEMBER 31, 2016 NET CHANGE IN FUND BALANCES -TOTAL GOVERNMENTAL FUNDS $ (1,003,844) Amounts reported for governmental activities in the statement of activities are different because: Governmental funds report capital outlays as expenditures. However, in the statement of activities, assets are capitalized and the cost is allocated over their estimated useful lives and reported as depreciation expense. Capital Outlays $ 323,989 Depreciation Expense (65,959) 258,030 Delinquent and deferred property taxes and special assessments receivable will be collected subsequent to year-end, but are not available soon enough to pay for the current period's expenditures and, therefore, are unavailable resources in the governmental funds. Unavailable Resources - December 31, 2015 550,862 Unavailable Resources - December 31, 2016 497,799 (53,063) The governmental funds report bond proceeds as financing sources, while repayment of bond principal is reported as an expenditure. In the statement of net position, however, issuing debt increases long-term liabilities and does not affect the statement of activities and repayment of principal reduces the liability. Also, governmental funds report the effect premiums and discounts when debt is first issued, whereas these amounts are deferred and amortized in the statement of activities. Interest is recognized as an expenditure in the governmental funds when it is due. In the statement of activities, however, interest expense is recognized as it accrues, regardless of when it is due. The net effect of these differences in the treatment of general obligation bonds and related items is as follows: Repayment of Bond Principal 745,000 Change in Accrued Interest Payable 6,323 Amortization of Bond Discount (5.744) 745,579 CHANGE IN NET POSITION OF GOVERNMENTAL ACTIVITIES $ (53,298) See accompanying Notes to Basic Financial Statements A-11 CITY OF GEM LAKE, MINNESOTA STATEMENT OF NET POSITION PROPRIETARY FUND DECEMBER 31, 2016 ASSETS Cash and Cash Equivalents Customer Accounts Receivable Accrued Interest Receivable Special Assessments Receivable Due From Other Funds Prepaid Items Total Current Assets Capital Assets: Utility Plant in Service Accumulated Depreciation Net Capital Assets Total Assets LIABILITIES Accounts Payable NET POSITION Net Investment in Capital Assets Unrestricted Total Net Position See accompanying Notes to Basic Financial Statements Sewer Utility $ 39,256 15,970 1,207 3,253 397,252 2,526 459,464 617,539 (149, 257) 468,282 927,746 468,282 459,464 $ 927,746 A-12 CITY OF GEM LAKE, MINNESOTA STATEMENT OF REVENUES, EXPENSES, AND CHANGE IN NET POSITION PROPRIETARY FUND YEAR ENDED DECEMBER 31, 2016 OPERATING REVENUES Public Charges for Services OPERATING EXPENSES Operating Expenses Depreciation Total Operating Expenses OPERATING INCOME NONOPERATING REVENUES Interest Revenue CHANGE IN NET POSITION Net Position - Beginning of Year NET POSITION - END OF YEAR See accompanying Notes to Basic Financial Statements. Sewer Utility $ 45,117 30,263 _ 12,457 42 720 2,397 4,211 6,608 921.138 $ 927,746 A-13 CITY OF GEM LAKE, MINNESOTA STATEMENT OF CASH FLOWS PROPRIETARY FUND YEAR ENDED DECEMBER 31, 2016 CASH FLOWS FROM OPERATING ACTIVITIES Cash Received from Utility Customers Cash Payments to Suppliers for Goods and Services Net Cash Provided by Operating Activities CASH FLOWS FROM NONCAPITAL FINANCING ACTIVITIES Interfund Loans CASH FLOWS FROM INVESTING ACTIVITIES Interest on Investments NET DECREASE IN CASH AND CASH EQUIVALENTS Cash and Cash Equivalents - Beginning of Year CASH AND CASH EQUIVALENTS - END OF YEAR RECONCILIATION OF OPERATING INCOME TO NET CASH PROVIDED BY OPERATING ACTIVITIES Operating Income Adjustments to Reconcile Operating Income to Net Cash Provided by Operating Activities: Depreciation Changes in Assets and Liabilities: Accounts Receivable Special Assessments Receivable Prepaid Items Accounts Payable Due to Other Governments Net Cash Provided by Operating Activities See accompanying Notes to Basic Financial Statements. Sewer Utility $ 51,685 (32, 922) 18,763 (397,252) 5.012 (373,477) 412,733 $ 39256 $ 2,397 12.457 6,256 312 (184) (15) (2,460) $ 18,763 A-14 a TLa cy _ o —6 6 �E m�ovm N mi 'E m C yp�i�vi aacia� Fmm -QEL Leow~ co mm Nmy=a� x 2 mNcN.- fpmo C a m N U C E m a E C %n T m UJ N CD N° alN j m C= O m m m N N a) N m C C m > V U m O m m L C '1 U m w m m N 0 a N ELLI 0 m O ° m N a N L C« m N p C_ N n— a E Z L m U m O U N > m ._ U « O O L> rn Z n°ooin> c m m 3m�Z�n3 a c m m ammo Z W U a m r c m O Y m m 2, N O N m -0.- > a '= C Q LU rn W C N C p C N m C 0 ayO N C C YO c 3m 7 OH rn a U na�z' mJ ) CL 0mcE m N m N mmZ,a�o N E E C y O n U > c m m m .�>-. .'-j' m o —_ p m N Q E 2 a) cmi a o«° E 55 _ C7 p O-O m>� mc in C m O— aC ON mWU 0 A C° . a!0 Y � Z O °C m E m a 2Q wav °O.Cb o mnC^ Jzm LL V O E d C E N O CcN�m> U N w U V O E N n N>LU y > c mpU — N CCmmZ L< LU E c,� Na) d`E,o1 Om0 d 3 m °: a mac Ey Om >0O FU C) -U:Enm m Q o m m a`mENN so m EC E o on 00 i m oa)tn m E Z U) 0 V C (V O T m m C N a) E N N C C N N :y U m °) a C .L+ N a d m y w o m m C C m ll .N. a C a m w E E C m i LL > i N E D U C o m N> U •� .OI.a .J. 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U .� Q' a) G U U L F U N V C C a)��N". o o N H as E al Ol y c ° N :. m E m � >N eu c m a m (J U L o U W U K E U A-28 APPENDIX B FORM OF LEGAL OPINION (See following page) _ Offices in 470 U.S. Bank Plaza 200 South Sixth Street Minneapolis Minneapolis Wi 55402-1458 Saint Paul (612)337-9300telephone Graven(612) 337-9310 fax St. Cloud www.kennedy-graven_com C H A R T E R E D Aff=B&eAoion,EgmdOpporlmhyEmployer $665,000 General Obligation Improvement Bonds Series 2018A City of Gem Lake Ramsey County, Minnesota We have acted as bond counsel to the City of Gem Lake, Ramsey County, Minnesota (the "Issuer") in connection with the issuance by the Issuer of its General Obligation Improvement Bonds, Series 2018A (the "Bonds"), originally dated the date hereof, and issued in the original aggregate principal amount of $665,000. In such capacity and for the purpose of rendering this opinion we have examined certified copies of certain proceedings, certifications and other documents, and applicable laws as we have deemed necessary. Regarding questions of fact material to this opinion, we have relied on certified proceedings and other certifications of public officials and other documents furnished to us without undertaking to verify the same by independent investigation. Under existing laws, regulations, rulings and decisions in effect on the date hereof, and based on the foregoing we are of the opinion that: 1. The Bonds have been duly authorized and executed, and are valid and binding general obligations of the Issuer, enforceable in accordance with their terms. 2. The principal of and interest on the Bonds are payable from special assessments levied or to be levied on property specially benefited by local improvements, and ad valorem taxes for the Issuer's share of the cost of the improvements, but if necessary for the payment thereof additional ad valorem taxes are required by law to be levied on all taxable property of the Issuer, which taxes are not subject to any limitation as to rate or amount. 3. Interest on the Bonds is excludable from gross income of the recipient for federal income tax purposes and, to the same extent, is excludable from taxable net income of individuals, trusts, and estates for Minnesota income tax purposes, and is not a preference item for purposes of the computation of the federal alternative minimum tax (although interest on the Bonds is included in adjusted current earnings in calculating corporate alternative minimum taxable income for taxable years that began prior to January 1, 2018), or the computation of the Minnesota alternative minimum tax imposed on individuals, trusts and estates. However, such interest is subject to Minnesota franchise taxes on corporations (including financial institutions) measured by income. The opinion set forth in this paragraph is subject to the condition that the Issuer comply with all requirements of the Internal Revenue Code of 1986, as amended, that must be satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or continue to be, excludable from gross income for federal income tax purposes and from taxable net income for Minnesota income tax purposes. The Issuer has covenanted to comply with all such requirements. Failure to comply with certain of such requirements may cause interest on the Bonds to be included in gross income for federal income tax purposes and taxable net income for Minnesota income tax purposes retroactively to the date of issuance of the Bonds. We express no opinion regarding tax consequences arising with respect to the Bonds other than as expressly set forth herein. 526797v1 GAF GE190-14 B-2 4. The rights of the owners of the Bonds and the enforceability of the Bonds may be limited by bankruptcy, insolvency, reorganization, moratorium, and other similar laws affecting creditor's rights generally and by equitable principles, whether considered at law or in equity. We have not been asked and have not undertaken to review the accuracy, completeness or sufficiency of the Official Statement or other offering material relating to the Bonds, and accordingly we express no opinion with respect thereto. This opinion is given as of the date hereof and we assume no obligation to update, 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. Dated July _, 2018 at Minneapolis, Minnesota. 526797v1 GAF GE190-14 B-3 APPENDIX C BOOK -ENTRY -ONLY SYSTEM The Depository Trust Company ("DTC"), New York, New York, will act as securities depository for the securities (the "Securities"). The Securities will be 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 Security certificate will be issued for [each issue of] the Securities, [each] in the aggregate principal amount of such issue, and will be deposited with DTC. [If, however, the aggregate principal amount of [any] issue exceeds $500 million, one certificate will be issued with respect to each $500 million of principal amount, and an additional certificate will be issued with respect to any remaining principal amount of such issue.] 2. 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 ofthe New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. 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 its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com. Purchases of Securities under the DTC system must be made by or through Direct Participants, which will receive a credit for the Securities on DTC's records. The ownership interest of each actual purchaser of each Security ("Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confinnation 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 Securities 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 Securities, except in the event that use of the book -entry system for the Securities is discontinued. 4. To facilitate subsequent transfers, all Securities 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 Securities with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Securities; DTC's records reflect only the identity of the Direct Participants to whose accounts such Securities 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. C-1 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 Securities may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Securities, such as redemptions, tenders, defaults, and proposed amendments to the Security documents. For example, Beneficial Owners of Securities may wish to ascertain that the nominee holding the Securities 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 notices be provided directly to them.] 6. Redemption notices shall be sent to DTC. If less than all of the Securities within an issue 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. 7. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Securities unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to 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 Securities are credited on the record date (identified in a listing attached to the Omnibus Proxy). 8. Redemption proceeds, distributions, and dividend payments on the Securities 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 Agent, on 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, Agent, or the City, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of redemption proceeds, distributions, and dividend 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 Agent, 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. A Beneficial Owner shall give notice to elect to have its Securities purchased or tendered, through its Participant, to [Tender/Remarketing] Agent, and shall effect delivery of such Securities by causing the Direct Participant to transfer the Participant's interest in the Securities, on DTC's records, to [Tender/Remarketing] Agent. The requirement for physical delivery of Securities in connection with an optional tender or a mandatory purchase will be deemed satisfied when the ownership rights in the Securities are transferred by Direct Participants on DTC's records and followed by a book -entry credit oftendered Securities to [Tender/Remarketing] Agent's DTC account. 10. DTC may discontinue providing its services as depository with respect to the Securities at any time by giving reasonable notice to the City or Agent. Under such circumstances, in the event that a successor depository is not obtained, Security certificates are required to be printed and delivered. 11. 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, Security certificates will be printed and delivered to DTC. 12. The information in this section concerning DTC and DTC's book -entry system has been obtained from sources that the City believes to be reliable, but the City takes no responsibility for the accuracy thereof. C-2 APPENDIX D FORM OF CONTINUING DISCLOSURE CERTIFICATE (See following page) D-1 $665,000 City of Gem Lake, Minnesota General Obligation Improvement Bonds Series 2018A CONTINUING DISCLOSURE CERTIFICATE , 2018 This Continuing Disclosure Certificate (the "Disclosure Certificate") is executed and delivered by the City of Gem Lake, Minnesota (the "Issuer") in connection with the issuance of its General Obligation Improvement Bonds, Series 2018A (the "Bonds"), in the original aggregate principal amount of $665,000. The Bonds are being issued pursuant to resolutions adopted by the City Council of the Issuer (the "Resolutions"). The Bonds are being delivered to (the "Purchaser"), on the date hereof. Pursuant to the Resolutions, the Issuer has covenanted and agreed to provide continuing disclosure of certain financial information and operating data and timely notices of the occurrence of certain events. The Issuer hereby covenants and agrees as follows: Section 1. Purpose of the Disclosure Certificate. This Disclosure Certificate is being executed and delivered by the Issuer for the benefit of the Holders (as defined herein) of the Bonds in order to assist the Participating Underwriters (as defined herein) in complying with SEC Rule 15c2-12(b)(5) (the "Rule"). This Disclosure Certificate, together with the Resolutions, constitutes the written agreement or contract for the benefit of the Holders of the Bonds that is required by the Rule. Section 2. Definitions. In addition to the defined terms set forth in the Resolutions, 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 the Issuer's Audited Financial Statements. "Audited Financial Statements" means the financial statements of the Issuer, audited annually by an independent certified public accounting firm, and prepared in accordance with generally accepted accounting principles ("GAAP") for Governmental Units as Prescribed by the Governmental Accounting Standards Board ("GASB") or as otherwise required by Minnesota law for the preceding Fiscal Year, including a balance sheet and statement of revenues, expenditures and changes in fund balances. "Bonds" means the General Obligation Improvement Bonds, Series 2018A, issued by the Issuer in the original aggregate principal amount of $665,000. "EMMA" means the Electronic Municipal Market Access system operated by the MSRB as the primary portal for complying with the continuing disclosure requirements of the Rule. Bonds. "Fiscal Year" means the fiscal year of the Issuer. "Holder" means the person in whose name a Bond is registered or a beneficial owner of such a Bond. "Issuer" means the City of Gem Lake, Minnesota., which is the obligated person with respect to the "Material Event" means any of the events listed in Section 4(a) of this Disclosure Certificate. 526796v1 GAF GE190-14 D-2 "MSRB" means the Municipal Securities Rulemaking Board located at 1300 I Street NW, Suite 1000, Washington, DC 20005. "Participating Underwriter" means any of the original underwriter(s) of the Bonds (including the Purchaser) required to comply with the Rule in connection with the offering of the Bonds. "Purchaser" means "Repository" means EMMA. "Rule" means SEC Rule 15c2-12(b)(5) promulgated by the SEC under the Securities Exchange Act of 1934, as the same may be amended from time to time, and including written interpretations thereof by the SEC. "SEC" means Securities and Exchange Commission, and any successor thereto. Section 3. Provision of Annual Report. To the extent such information is customarily prepared by the Issuer and is publicly available, the Issuer shall provide not later than 12 months after the end of the Fiscal Year commencing with the year that ends December 31, 2017, the Repository with its Annual Report. The Annual Report may be incorporated by reference from other documents, including official statements of debt issues of the Issuer or related public entities, which have been submitted to the Repository or the SEC. If the document incorporated by reference is a final official statement, it must also be available from the MSRB. The Issuer shall clearly identify each such other document so incorporated by reference. The Annual Report may be submitted as a single document or as separate documents comprising a package, and may cross-reference other information as provided in Section 4 of this Disclosure Certificate; provided that the Audited Financial Statements of the Issuer may be submitted separately from the balance of the Annual Report. Section 4. Reporting of Material Events. (a) This Section 4 shall govern the giving of notices of the occurrence of any of the following events if material with respect to the Bonds: 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; 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 security, or other material events affecting the tax status of the security; 7. Modifications to rights of security holders, if material; 526796v1 GAF GE190-14 D-3 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 obligated person; 13. The consummation of a merger, consolidation, or acquisition involving an obligated person or the sale of all or substantially all of the assets of the obligated person, 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; and 14. Appointment of a successor or additional trustee or the change of name of a trustee, if material. (b) The Issuer shall file a notice of such occurrence with the Repository or with the MSRB within ten (10) business days of the occurrence of the Material Event. (c) Unless otherwise required by law and subject to technical and economic feasibility, the Issuer shall employ such methods of information transmission as shall be requested or recommended by the designated recipients of the Issuer's information. Section 5. EMMA. The SEC has designated EMMA as a nationally recognized municipal securities information repository and the exclusive portal for complying with the continuing disclosure requirements of the Rule. Until the EMMA system is amended or altered by the MSRB and the SEC, the Issuer shall make all filings required under this Disclosure Certificate solely with EMMA. Section 6. Termination of Reporting Obligation. The Issuer's obligations under the Resolutions and this Disclosure Certificate shall terminate upon the redemption in full of the Bonds or payment in full of all the Bonds. Section 7. Agent. The Issuer may, from time to time, appoint or engage a dissemination agent to assist it in carrying out its obligations under the Resolutions and this Disclosure Certificate, and may discharge any such agent, with or without appointing a successor dissemination agent. Section 8. Amendment; Waiver. Notwithstanding any other provision of the Resolutions and this Disclosure Certificate, the Issuer may amend this Disclosure Certificate, and any provision of this Disclosure Certificate may be waived, if such amendment or waiver is supported by an opinion of nationally recognized bond counsel to the effect that such amendment or waiver would not, in and of itself, cause a violation of the Rule. This Disclosure Certificate, or any provision hereof, shall be null and void in the event that the Issuer delivers to the Repository, an opinion of nationally recognized bond counsel to the effect that those portions of the Rule which require the Resolutions and this Disclosure Certificate are invalid, have been repealed retroactively or otherwise do not apply to the Bonds. The provisions of the Resolutions and this Disclosure Certificate may be amended without the consent of the Holders of the Bonds, but only upon the delivery by the Issuer to the Repository, of the proposed amendment and an opinion of nationally recognized 526796vI GAF GE190-14 D-4 bond counsel to the effect that such amendment, and giving effect thereto, will not adversely affect the compliance of the Resolutions and this Disclosure Certificate and by the Issuer with the Rule. Section 9. Additional Information. Nothing in this Disclosure Certificate shall be deemed to prevent the Issuer 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 Material Event, in addition to that which is required by this Disclosure Certificate. If the Issuer chooses to include any information in any Annual Report or notice of occurrence of a Material Event in addition to that which is specifically required by this Disclosure Certificate, the Issuer 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 Material Event. Section 10. Default. In the event of a failure of the Issuer to comply with any provision of this Disclosure Certificate any Holder of the Bonds may take such actions as may be necessary and appropriate, including seeking mandamus or specific performance by court order, to cause the Issuer to comply with its obligations under the Resolutions and this Disclosure Certificate. A default under this Disclosure Certificate shall not be deemed an event of default with respect to the Bonds and the sole remedy under this Disclosure Certificate in the event of any failure of the Issuer to comply with this Disclosure Certificate shall be an action to compel performance. Section 11. Beneficiaries. This Disclosure Certificate shall inure solely to the benefit of the Issuer, the Participating Underwriters and Holders from time to time of the Bonds, and shall create no rights in any other person or entity. (The remainder of this page is intentionally left blank. 526796v1 GAF GE190-14 D-5 IN WITNESS WHEREOF, we have executed this Disclosure Certificate in our official capacities effective as of the date and year first written above. (SEAL) CITY OF GEM LAKE, MINNESOTA Mayor City Administrator -Clerk (Signature Page to Continuing Disclosure Certificate) 526796v1 GAF GE190-14 D-6 APPENDIX E TERMS OF PROPOSAL $665,000* GENERAL OBLIGATION IMPROVEMENT BONDS, SERIES 2018A CITY OF GEM LAKE, MINNESOTA Proposals for the purchase of $665,000* General Obligation Improvement Bonds, Series 2018A (the "Bonds") of the City of Gem Lake, Minnesota (the "City") will be received at the offices of Ehlers & Associates, Inc. ("Ehlers"), 3060 Centre Pointe Drive, Roseville, Minnesota 55113-1105, Municipal Advisors to the City, until 10:00 A.M., Central Time, and ELECTRONIC PROPOSALS will be received via PARITY, in the manner described below, until 10:00 A.M. Central Time, on June 19, 2018, at which time they will be opened, read and tabulated. The proposals will be presented to the City Council for consideration for award by resolution at a meeting to be held at 7:00 P.M., Central Time, on the same date. The proposal offering to purchase the Bonds upon the terms specified herein and most favorable to the City will be accepted unless all proposals are rejected. PURPOSE The Bonds are being issued pursuant to Minnesota Statutes, Chapters 429 and 475, by the City for the purpose of financing various public improvements within the City. The Bonds will be general obligations of the City for which its full faith, credit and taxing powers are pledged. DATES AND MATURITIES The Bonds will be dated July 12, 2018, will be issued as fully registered Bonds in the denomination of $5,000 each, or any integral multiple thereof, and will mature on February 1 as follows: Year Amount* Year Amount* Year Amount* 2020 $35,000 2025 $40,000 2030 $45,000 2021 40,000 2026 45,000 2031 50,000 2022 40,000 2027 45,000 2032 50,000 2023 40,000 2028 45,000 2033 50,000 2024 40,000 2029 45,000 2034 55,000 ADJUSTMENT OPTION * The City reserves the right to increase or decrease the principal amount of the Bonds on the day of sale, in increments of $5,000 each. Increases or decreases may be made in any maturity. If any principal amounts are adjusted, the purchase price proposed will be adjusted to maintain the same gross spread per $1,000. TERM BOND OPTION Proposals for the Bonds may contain a maturity schedule providing for any combination of serial bonds and term bonds, subject to mandatory redemption, so long as the amount of principal maturing or subject to mandatory redemption in each year conforms to the maturity schedule set forth above. All dates are inclusive. E-1 INTEREST PAYMENT DATES AND RATES Interest will be payable on February 1 and August 1 of each year, commencing February 1, 2019, to the registered owners of the Bonds appearing of record in the bond register as of the close of business on the 15th day (whether or not a business day) of the immediately preceding month. Interest will be computed upon the basis of a 360-day year of twelve 30-day months and will be rounded pursuant to rules of the Municipal Securities Rulemaking Board. The rate for any maturity may not be more than 1.00% less than the rate for any preceding maturity. (For example, if a rate of 4.50% is proposed for the 2020 maturity, then the lowest rate that may be proposed for any later maturity is 3.50%.) All Bonds of the same maturity must bear interest from date of issue until paid at a single, uniform rate. Each rate must be expressed in an integral multiple of 5/100 or 1/8 of 1%. BOOK -ENTRY -ONLY FORMAT Unless otherwise specified by the purchaser, the Bonds will be designated in the name of Cede & Co., as nominee for The Depository Trust Company, New York, New York ("DTC"). DTC will act as securities depository for the Bonds, and will be responsible for maintaining a book -entry system for recording the interests of its participants and the transfers of interests between its participants. The participants will be responsible for maintaining records regarding the beneficial interests of the individual purchasers of the Bonds. So long as Cede & Co. is the registered owner of the Bonds, all payments of principal and interest will be made to the depository which, in turn, will be obligated to remit such payments to its participants for subsequent disbursement to the beneficial owners ofthe Bonds. PAYING AGENT The City has selected Bond Trust Services Corporation, Roseville, Minnesota, to act as paying agent (the "Paying Agent"). Bond Trust Services Corporation and Ehlers are affiliate companies. The City will pay the charges for Paying Agent services. The City reserves the right to remove the Paying Agent and to appoint a successor. OPTIONAL REDEMPTION At the option of the City, the Bonds maturing on or after February 1, 2028 shall be subject to optional redemption prior to maturity on February 1, 2027 and on any date thereafter, at a price of par plus accrued interest. Redemption may be in whole or in part of the Bonds subject to prepayment. If redemption is in part, the selection of the amounts and maturities of the Bonds to be redeemed shall be at the discretion of the City. If only part of the Bonds having a common maturity date are called for redemption, then the City or Paying Agent, if any, will notify DTC of the particular amount of such maturity to be redeemed. DTC will determine by lot the amount of each participant's interest in such maturity to be redeemed and each participant will then select by lot the beneficial ownership interest in such maturity to be redeemed. Notice of redemption shall be sent by mail not more than 60 days and not less than 30 days prior to the date fixed for redemption to the registered owner of each Bond to be redeemed at the address shown on the registration books. DELIVERY On or about July 12, 2018, the Bonds will be delivered without cost to the winning bidder at DTC. On the day of closing, the City will furnish to the winning bidder the opinion of bond counsel hereinafter described, an arbitrage certification, and certificates verifying that no litigation in any manner questioning the validity of the Bonds is then pending or, to the best knowledge of officers of the City, threatened. Payment for the Bonds must be received by the City at its designated depository on the date of closing in immediately available funds. E-2 LEGAL OPINION An opinion as to the validity of the Bonds and the exemption from taxation of the interest thereon will be furnished by Kennedy & Graven, Chartered, Minneapolis, Minnesota, Bond Counsel to the City, and will be available at the time of delivery of the Bonds. The legal opinion will state that the Bonds are valid and binding general obligations of the City; provided that the rights of the owners of the Bonds and the enforceability of the Bonds may be limited by bankruptcy, insolvency, reorganization, moratorium, and other similar laws affecting creditors' rights and by equitable principles (which may be applied in either a legal or equitable proceeding). See "FORM OF LEGAL OPINION" found in Appendix B. SUBMISSION OF PROPOSALS Proposals must not be for less than $655,025 plus accrued interest on the principal sum of $665,000 from date of original issue of the Bonds to date of delivery. Prior to the time established above for the opening of proposals, interested parties may submit a proposal as follows: 1) Electronically to bondsale(&ehlers-inc.com: or 2) Facsimile submission to Ehlers, Facsimile Number (651) 697-8555; or 3) Electronically via PARITY in accordance with this Terms of Proposal until 10:00 A.M. Central Time, but no proposal will be received after the time for receiving proposals specified above. To the extent any instructions or directions set forth in PARITY conflict with this Terms of Proposal, the terms of this Terms of Proposal shall control. For further information about PARITY, potential bidders may contact Ehlers or i-Deal LLC at 1359 Broadway, 2nd Floor, New York, New York 10018, Telephone (212) 849-5021. Proposals must be submitted to Ehlers via one of the methods described above and must be received prior to the time established above for the opening of proposals. Each proposal must be unconditional except as to legality. Neither the City nor Ehlers shall be responsible for any failure to receive a facsimile submission. A good faith deposit ("Deposit") in the amount of $13,300 shall be made by the winning bidder by wire transfer of funds to KleinBank, 1550 Audubon Road, Chaska, Minnesota, ABA No. 091915654 for credit: Ehlers & Associates Good Faith Account No. 3208138. Such Deposit shall be received by Ehlers no later than two hours after the proposal opening time. The City reserves the right to award the Bonds to a winning bidder whose wire transfer is initiated but not received by such time provided that such winning bidder's federal wire reference number has been received by such time. In the event the Deposit is not received as provided above, the City may award the Bonds to the bidder submitting the next best proposal provided such bidder agrees to such award. The Deposit will be retained by the City as liquidated damages if the proposal is accepted and the Purchaser fails to comply therewith. The City and the winning bidder who chooses to so wire the Deposit hereby agree irrevocably that Ehlers shall be the escrow holder of the Deposit wired to such account subject only to these conditions and duties: 1) All income earned thereon shall be retained by the escrow holder as payment for its expenses; 2) If the proposal is not accepted, Ehlers shall, at its expense, promptly return the Deposit amount to the winning bidder; 3) If the proposal is accepted, the Deposit shall be returned to the winning bidder at the closing; 4) Ehlers shall bear all costs of maintaining the escrow account and returning the funds to the winning bidder; 5) Ehlers shall not be an insurer of the Deposit amount and shall have no liability hereunder except if it willfully fails to perform or recklessly disregards, its duties specified herein; and 6) FDIC insurance on deposits within the escrow account shall be limited to $250,000 per bidder. No proposal can be withdrawn after the time set for receiving proposals unless the meeting of the City scheduled for award of the Bonds is adjourned, recessed, or continued to another date without award of the Bonds having been made. E-3 AWARD The Bonds will be awarded to the bidder offering the lowest interest rate to be determined on a True Interest Cost (TIC) basis. The City's computation of the interest rate of each proposal, in accordance with customary practice, will be controlling. In the event of a tie, the sale of the Bonds will be awarded by lot. The City reserves the right to reject any and all proposals and to waive any informality in any proposal. BONDINSURANCE If the Bonds are qualified for any bond insurance policy, the purchase of such policy shall be at the sole option and expense of the winning bidder. Any cost for such insurance policy is to be paid by the winning bidder, except that, if the City requested and received a rating on the Bonds from a rating agency, the City will pay that rating fee. Any rating agency fees not requested by the City are the responsibility of the winning bidder. Failure of the municipal bond insurer to issue the policy after the Bonds are awarded to the winning bidder shall not constitute cause for failure or refusal by the winning bidder to accept delivery of the Bonds. CUSIP NUMBERS The City will assume no obligation for the assignment or printing of CUSIP numbers on the Bonds or for the correctness of any numbers printed thereon, but will permit such numbers to be printed at the expense of the winning bidder, if the winning bidder waives any delay in delivery occasioned thereby. QUALIFIED TAX-EXEMPT OBLIGATIONS The City will designate the Bonds as qualified tax-exempt obligations for purposes of Section 265(b)(3) ofthe Internal Revenue Code of 1986, as amended. CONTINUING DISCLOSURE In order to assist the Underwriters in complying with the provisions of Rule 15c2-12 promulgated by the Securities and Exchange Commission under the Securities Exchange Act of 1934 the City will enter into an undertaking for the benefit of the holders of the Bonds. A description of the details and terms of the undertaking is set forth in Appendix D of the Preliminary Official Statement. NEW ISSUE PRICING The winning bidder will be required to provide, in a timely manner, certain information necessary to compute the yield on the Bonds pursuant to the provisions of the Internal Revenue Code of 1986, as amended, and to provide a certificate which will be provided by Bond Counsel upon request. (a) The winning bidder shall assist the City in establishing the issue price of the Bonds and shall execute and deliver to the City at closing an "issue price" or similar certificate satisfactory to Bond Counsel setting forth the reasonably expected initial offering price to the public or the sales price or prices of the Bonds, together with the supporting pricing wires or equivalent communications. All actions to be taken by the City under this Terms of Proposal to establish the issue price of the Bonds may be taken on behalf of the City by the City's municipal advisor identified herein and any notice or report to be provided to the City may be provided to the City's municipal advisor. (b) The City intends that the provisions of Treasury Regulation Section 1. 148- 1 (f)(3)(i) (defining "competitive sale" for purposes of establishing the issue price of the Bonds) will apply to the initial sale of the Bonds (the "competitive sale requirements") because: E-4 (1) The City shall disseminate this Terms of Proposal to potential underwriters in a manner that is reasonably designed to reach potential investors; (2) all bidders shall have an equal opportunity to bid; (3) the City may receive proposals from at least three underwriters of municipal bonds who have established industry reputations for underwriting new issuances of municipal bonds; and (4) the City anticipates awarding the sale of the Bonds to the bidder who submits a firm offer to purchase the Bonds at the highest price (or lowest interest cost), as set forth in this Terms of Proposal. Any proposal submitted pursuant to this Terms of Proposal shall be considered a firm offer for the purchase of the Bonds, as specified in this proposal. (c) If all of the requirements of a "competitive sale" are not satisfied, the City shall advise the winning bidder of such fact prior to the time of award of the sale of the Bonds to the Underwriter. In such event, any proposal submitted will not be subject to cancellation or withdrawal and the City agrees to use the rule selected by the Underwriter on its proposal form to determine the issue price for the Bonds. On its proposal form, each Underwriter must select one of the following two rules for determining the issue price of the Bonds: (1) the first price at which 10% of a maturity of the Bonds (the "10% test") is sold to the public as the issue price of that maturity or (2) the initial offering price to the public as of the sale date as the issue price of each maturity of the Bonds (the "hold -the -offering - price rule"). (d) I f all of the requirements of a "competitive sale" are not satisfied and the Underwriter selects the hold-the- ofiering-price rule, the winning bidder shall (i) confirm that the underwriters have offered or will offer the Bonds to the public on or before the date of award at the offering price or prices (the "initial offering price"), or at the corresponding yield or yields, set forth in the proposal submitted by the winning bidder and (ii) agree, on behalf of the underwriters participating in the purchase of the Bonds, that the underwriters will neither offer nor sell unsold Bonds of any maturity to which the hold -the -offering -price rule shall apply 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: (1) the close of the fifth (5 h) business day after the sale date; or (2) the date on which the underwriters have 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 winning bidder shall promptly advise the City when the underwriters have 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, if that occurs prior to the close of the fifth (5") business day after the sale date. The City acknowledges that in making the representation set forth above, the winning bidder will rely on (i) the agreement of each underwriter to comply with the hold -the -price rule, as set forth in an agreement among underwriters and the related pricing wires, (ii) 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 hold - the -offering -price rule, as set forth in a selling group agreement and the related pricing wires, and (iii) in the event that an underwriter is a party to a retail distribution agreement that was employed in connection with the initial sale of the Bonds to the public, the agreement of each broker -dealer that is party to such agreement to comply with the hold -the -offering -price rule, as set forth in the retail distribution agreement and the related pricing wires. The City further acknowledges that each underwriter shall be solely liable for its failure to comply with its agreement regarding the hold -the -offering -price rule and that no underwriter shall be liable for the failure of any other underwriter, or of any dealer who is a member of a selling group, or of any broker -dealer that is a party to a retail distribution agreement to comply with its corresponding agreement regarding the hold -the -offering -price rule as applicable to the Bonds. E-5 (e) If all of the requirements of a "competitive sale" are not satisfied and the Underwriter selects the 10% test, the Underwriter agrees to promptly report to the City, Bond Counsel and Ehlers the prices at which the Bonds have been sold to the public. That reporting obligation shall continue, whether or not the closing date has occurred, until the 10% test has been satisfied as to each maturity of the Bonds or until all of the Bonds of a certain maturity have been sold. (f) By submitting a proposal, each bidder confirms that (i) any agreement among underwriters, any selling group agreement and each retail distribution agreement (to which the bidder is a party) relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each underwriter, each dealer who is a member of the selling group, and each broker -dealer that is party to such retail distribution agreement, as applicable, to (A) report the prices at which it sells to the public the unsold Bonds of each maturity allotted to it until it is notified by the winning bidder that either the 10% test has been satisfied as to the Bonds of that maturity or all Bonds of that maturity have been sold to the public, and (B) comply with the hold -the - offering -price rule, if applicable, in each case if and for so long as directed by the winning bidder and as set forth in the related pricing wires, and (ii) any agreement among underwriters relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each underwriter that is a party to a retail 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 retail distribution agreement to (A) report the prices at which it sells to the public the unsold Bonds of each maturity allotted to it until it is notified by the winning bidder or such underwriter that either the 10% test has been satisfied as to the Bonds of that maturity or all Bonds of that maturity have been sold to the public, and (B) comply with the hold -the -offering -price rule, if applicable, in each case if an for so long as directed by the winning bidder or such underwriter and as set forth in the related pricing wires. (g) Sales of any Bonds to any person that is a related party to an underwriter shall not constitute sales to the public for purposes of this Terms of Proposal. Further, for purposes of this Terms of Proposal: (i) "public" means any person other than an underwriter or a related party, (ii) "underwriter" means (A) any person that agrees pursuant to a written contract with the City (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 retail distribution agreement participating in the initial sale of the Bonds to the public), (iii) 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 (i) at least 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), (ii) 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 (iii) 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 (iv) "sale date" means the date that the Bonds are awarded by the City to the winning bidder. E-6 PRELIMINARY OFFICIAL STATEMENT Bidders may obtain a copy of the Preliminary Official Statement relating to the Bonds prior to the proposal opening by request from Ehlers at www.ehlers-inc.com by connecting to the Bond Sales link. The Syndicate Manager will be provided with an electronic copy of the Final Official Statement within seven business days of the proposal acceptance. Up to 10 printed copies of the Final Official Statement will be provided upon request. Additional copies of the Final Official Statement will be available at a cost of $10.00 per copy. Information for bidders and proposal forms may be obtained from Ehlers at 3060 Centre Pointe Drive, Roseville, Minnesota 55113-1105, Telephone (651) 697-8500. By Order of the City Council City of Gem Lake, Minnesota E-7 PROPOSALFORM The City Council June 19, 2018 City of Gem Lake, Minnesota RE: $665,000* General Obligation Improvement Bonds, Series 2018A DATED: July 12, 2018 For all or none of the above Bonds, in accordance with the Terms of Proposal and terms of the Global Book -Entry System (unless otherwise specified by the Purchaser) as stated in this Official Statement, we will pay you $ (not less than $655,025) plus accrued interest to date of delivery for fully registered Bonds bearing interest rates and maturing in the stated years as follows: % due 2020 % due 2025 % due 2030 % due 2021 % due 2026 % due 2031 % due 2022 % due 2027 % due 2032 % due 2023 % due 2028 % due 2033 % due 2024 % due 2029 % due 2034 * The City reserves the right to increase or decrease the principal amount of the Bonds on the day of sale, in increments of $5,000 each. Increases or decreases may be made in any maturity. If any principal amounts are adjusted, the purchase price proposed will be adjusted to maintain the same gross spread per $1,000. The rate for any maturity may not be more than 1.00% less than the rate for any preceding maturity. (For example, if a rate of 4.50% is proposed for the 2020 maturity, then the lowest rate that may be proposed for any later maturity is 3.50%.) All Bonds of the same maturity must bear interest from date of issue until paid at a single, uniform rate. Each rate must be expressed in an integral multiple of 51100 or 1/8 of 1%. We enclose our Deposit in the amount of $13,300, to be held by you pending delivery and payment. Alternatively, if we are the winning bidder, we will wire our Deposit to KleinBank,1550 Audubon Road, Chaska, Minnesota, ABA No.091915654 for credit: Ehlers & Associates Good Faith Account No. 3208138. Such Deposit shall be received by Ehlers & Associates no later than two hours after the proposal opening time. The City reserves the right to award the Bonds to a winning bidder whose wire transfer is initiated but not received by such time provided that such winning bidder's federal wire reference number has been received. In the event the Deposit is not received as provided above, the City may award the Bonds to the bidder submitting the next best proposal provided such bidder agrees to such award. If our proposal is not accepted, said deposit shall be promptly returned to us. If the Deposit is wired to such escrow account, we agree to the conditions and duties of Ehlers & Associates, Inc., as escrow holder of the Deposit, pursuant to the Terms of Proposal. This proposal is for prompt acceptance and is conditional upon delivery of said Bonds to The Depository Trust Company, New York, New York, in accordance with the Terms of Proposal. Delivery is anticipated to be on or about July 12, 2018. This proposal is subject to the City's agreement to enter into a written undertaking to provide continuing disclosure under Rule 15c2-12 promulgated by the Securities and Exchange Commission under the Securities Exchange Act of 1934 as described in the Preliminary Official Statement for this Issue. We have received and reviewed the Official Statement and have submitted our requests for additional information or corrections to the Final Official Statement. As Syndicate Manager, we agree to provide the City with the reoffering price of the Bonds within 24 hours of the proposal acceptance. This proposal is a firm offer for the purchase of the Bonds identified in the Terms of Proposal, on the terms set forth in this proposal form and the Terms of Proposal, and is not subject to any conditions, except as permitted by the Terms of Proposal. By submitting this proposal, we confirm that we are an Underwriter and have an established industry reputation for underwriting new issuances of municipal bonds. YES: NO: If the competitive sale requirements are not met, we elect to use the (circle one): 10% test / hold -the -offering -price rule to determine the issue price of the Bonds. Account Manager: By. Account Members: Award will be on a true interest cost basis. According to our computations (the correct computation being controlling in the award), the total dollar interest cost (including any discount or less any premium) computed from July 12, 2018 of the above proposal is $ and the true interest cost (TIC) is %. The foregoing offer is hereby accepted by and on behalf of the City Council of the City of Gem Lake, Minnesota, on June 19, 2018. By: By: Title: Title: