HomeMy WebLinkAbout2018A Letter of Engagement 2018 05.164) EHLERS
LEADERS IN PI)BLiC FMANCE
May 16, 2018
Tom Kelly
City Treasurer
City of Gem Lake
4200 Otter Lake Road
White Bear Lake, MN 55110
Re: Letter of Engagement to Retain Ehlers as Dissemination Agent for Issuer Continuing Disclosure
Required Under Securities and Exchange Commission (SEC) Rule 15c2-12 (the "Rule")
As an issuer of municipal securities, the City ("Issuer") is required to comply with all continuing disclosure
obligations enumerated in the Continuing Disclosure Agreement/Certificate/Undertaking (CDU) associated
with each issue of securities subject to the Rule. Many Issuers have CDU's that vary significantly from one
CDU to another. Ehlers & Associates, Inc. ("Ehlers") can help you comply with all CDU obligations as
Dissemination Agent. Fulfilling this obligation requires research, preparation and filing of disclosure reports
within specific time frames.
This Letter of Engagement ("Letter") is being presented to memorialize and clarify the terms of the Issuer's
engagement of Ehlers as the Issuer's Dissemination Agent. In this regard, Ehlers agrees to provide Issuer
with those services described in Appendix A ("Services"). Ehlers shall be entitled to compensation by the
Issuer also as described in Appendix A.
This Letter shall be effective as of the date of its execution by the Issuer and shall remain in effect for a period
of one (1) year (the "Initial Term"). This Letter shall renew automatically on each anniversary of the
effective date of this Letter (each an "Additional Tern"). Notwithstanding the foregoing, this Letter may be
terminated by either party upon sixty (60) days prior written notice. The Initial Term and each Additional
Tern shall collectively be referred to herein as the "Term".
In order to perform the engagement, Issuer agrees to provide Ehlers all documents and information as are
deemed necessary to fulfill the Issuer's reporting requirements under each respective CDU, and within the
applicable timeframe(s) ("Disclosure Information"). With respect to Issuer's obligation to report the
occurrence of any event for which a material event notice ("Event Notice") is to be filed, Issuer shall provide
Disclosure Information related to the event to Ehlers within five (5) days of its occurrence. All other
Disclosure Information must be provided to Ehlers within fourteen (14) days of Issuer's receipt of any such
request from Ehlers. If Issuer fails to provide any Disclosure Infonnation to Ehlers in accordance with the
foregoing, Ehlers shall not be held liable for any reason in the event that any necessary disclosure filing is
not disseminated to the appropriate party within the applicable timeframe(s). Further, if for any reason Issuer
fails to provide required Disclosure Information to Ehlers in accordance with the foregoing and Issuer's delay
results in any disclosure filing being after a stated deadline, Ehlers shall, without further direction or
instruction from Issuer, file a notice(s) with the applicable recipient submitting information provided by
Issuer, if any, and/or describing the failure and providing any other information as Ehlers deems appropriate.
Ehlers shall deem all Disclosure Information provided to it by the Issuer to be accurate and free of defect, as
well as not containing any material misstatements, falsehoods, or omissions of fact. Issuer acknowledges that
Ehlers shall be entitled to rely on all Disclosure Information provided by the Issuer without further
investigation as to its completeness or accuracy.
Issuer shall indemnify, hold harmless and defend Ehlers from and against any damages, costs or other
liabilities (including reasonable attorneys' fees) arising from or relating to any breach of this Letter by Issuer,
including, but not limited to, damages, costs and other liabilities arising out of any Disclosure Information
received and disseminated by Ehlers. Further, in no event shall Ehlers' total aggregate liability under this
Letter be in excess of the amount of fees paid by Issuer to Ehlers during the Term then in effect
notwithstanding anything contained herein. In addition, Issuer acknowledges that Ehlers shall not be
responsible and/or liable for any errors, misstatements or omissions associated with any continuing disclosure
report or filing, or for the correction thereof, that was prepared or disseminated by any party other than
Ehlers.
This Letter constitutes the entire agreement between the parties and is intended to supersede any and all
agreements, whether oral or written, between the parties that were entered into relative to the subject matter
hereof prior to the effective date of this Letter. No amendment or modification of this Letter shall be deemed
valid unless made in writing and signed by both parties.
This Letter covers the Issuer's current outstanding securities. The Issuer may request in writing that Ehlers
act as the Dissemination Agent on any future securities subject to the Rule.
If our engagement under the terms of this Letter is acceptable, please sign this Letter in the appropriate
signature block below and return a signed copy to us for our records. If, however, you do not wish to engage
our services, please note that election and return a copy of this Letter to us.
Please contact me if you have any questions or would like to discuss our engagement further.
Sincerely,
Ehlers
Todd Hagen
Senior Municipal Advisor
SO ACCEPTED BY ISSUER
Issuer hereby accepts this Letter and engages Ehlers to provide the services noted herein and executes this
Letter as of the date noted below:
By: 4,a---")�-s�
Name:
SO DECLINED BY ISSUER
Title: &,&
Date:
Issuer hereby acknowledges that it will be responsible for updating and submitting all necessary continuing
disclosure reports and filings as may be required of Issuer without the assistance of Ehlers. Issuer further
acknowledges and agrees that Ehlers assumes no responsibility for the compilation and/or submission of any
such continuing disclosure reports or filings.
LIM
Title:
Name: Date:
APPENDIX A
EHLERS DISSEMINATION AGENT SERVICES AND FEES
Ehlers' continuing disclosure services are designed to assist the Issuer in meeting its continuing disclosure
obligations. Depending on the size of a transaction and the total amount of debt outstanding at the time of
issuance, different debt issues may be subject to different reporting requirements. Ehlers will provide the
services identified below, which are reflective of the Issuer's requirements under its respective Continuing
Disclosure Undertaking (CDU). In no event will Ehlers assist Issuer with assessing whether information
provided or omitted as part of an annual filing is "material" or whether an event is "material" under the
federal securities laws requiring the filing of an event notice pursuant to a CDU. If the Issuer accepts this
letter and engages Ehlers as the Dissemination Agent, Ehlers shall provide the following services and charge
the following fees:
Full Disclosure Services.
Background
Since 1995, Securities and Exchange Commission (SEC) rule 15c2-12 (the "Rule") has required underwriters
of municipal securities to ensure that issuers are obligated to provide periodic reporting of specific
information with respect to certain issues of municipal securities. An issuer is classified as a "full disclosure"
reporting entity when it issues securities subject to the Rule in an amount of $1 million or more, and further
provided that total securities subject to the Rule and currently outstanding exceed $10 million. Full disclosure
reporting entities must:
• File reports consisting of specific information at least annually with the Municipal Securities Rulemaking
Board's (MSRB) Electronic Municipal Market Access (EMMA) system (http://emina.nisrb.org).
• File "Event Notices" regarding enumerated events specified in SEC rules and CDUs within 10 business
days of occurrence. Event Notices are filed through the same EMMA system.
Description of Services
Issuer engages Ehlers to provide the following services in connection with the preparation and dissemination
of Issuer's continuing disclosure reports and Event Notice filings in connection with all outstanding debt
issues of Issuer subj ect to the Rule and for which continuing disclosure reports or filings are required. During
the Term of the engagement, Ehlers shall provide the services hereinafter described with respect to all existing
and future securities of the Issuer subject to the Rule and having continuing disclosure requirements. Ehlers
shall provide these services for any other securities of the Issuer when requested in writing by the Issuer.
Annual Filings, or More Frequently, if Required
a. Review and catalog of all Continuing Disclosure Agreement/Certificate/Undertaking (CDU)'s of
Issuer relative to current and future issues of securities subject to the Rule.
b. Creation of a timetable for the anticipated schedule of events relating to the preparation of Issuer's
annual (or more frequently, if required) continuing disclosure report.
c. Collection of information from third parties and Issuer, as applicable, to the extent necessary to
prepare the annual (or more frequently, if required) continuing disclosure report.
d. Preparing the annual (or more frequently, if required) continuing disclosure report in a standardized
fonnat acceptable for submission to the EMMA system, or any future industry standard.
e. Submission of the annual (or more frequently, if required) continuing disclosure report and any Event
Notices to the designated recipient based on the applicable CDU's of Issuer and all laws, rules and
regulations relative thereto.