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HomeMy WebLinkAboutStaff Report 5.A 02/07/2005CITY OF PETALUMA, CALIFORNIA 5.A AGENDA BILL nA�rgr��5 Aeenda Title: Resolution Approving the form of and authorizing the Meeting a e: a ru v 2 a execution and delivery of a purchase and sale agreement and related documents with respect to the sale of Petaluma's Vehicle License Fee Meeting Time: ® 3:00 PM Receivable from the State; and directing and authorizing certain other ❑ 7.00 PM actions in connection therewith. Cateeory (check one): ❑ Consent Calendar ❑ Public Hearing ® New Business ❑ Unfinished Business ❑ Presentation Department: Dire or: Contact Person: Phone Number: Admin Services JosepN}er Joseph D. Netter 778-4352 Cost of Proposal:. Not to Exceed: $94,945.60 Account Number: 44260 Net to City — Not Less Than: 90.02% of $951,083.48 ($951,083.48 represents VLF Receivable to City) Amount Budeeted: N/A Attachments to Agenda Packet Item: or $856,137.88 Name of Fund: 1. Resolution Approving Form and Authorizing the Execution.... 2. Staff Report 3. Other Back —up material from League of California Cities, etc. Summary Statement: State Motor Vehicle License Fee In June, 2003, the State suspended the VLF "backfill" due to insufficient State General Fund monies. The 2% rate was restored and became effective on October 1, 2003. Local governments lost about $1.2 billion during the three months of the suspension of the VLF "backfill" and the implementation of the higher fees. For the City of Petaluma, this equated to a loss of approximately $951,000 in VLF revenues. The State's 2004 budget included repayment of the $1.2 billion to local governments by August 15, 2006, as well as a permanent reduction of the VLF rate of 0.65%. The reduction in VLF revenue will be replaced by property taxes; however for 2005 and 2006, the payment will be reduced by a total of $700 million to assist the state in balancing its budget. Commencing in FY 2006-07, local governments will receive their full share of replacement property taxes and those taxes will be constitutionally protected against transfers by the State per the recent passage of Proposition 1-A. The California Statewide Communities Development Authority ("CSCDA"), which is a joint powers authority sponsored by the League of California Cities and the California State Association of Counties instituted the VLF Loan Program to enable cities and counties to sell their respective VLF Receivables to CSCDA for an up -front fixed purchase price estimated to be between 89% to 91 % of the VLF Gap Repayment. CSCDA is planning to issue notes and to use the note proceeds to purchase the VLF receivables and pay the financing costs. The balance of the proceeds will be used to cover any capitalized interest and issuance costs. By Selling the VLF Receivable, the City will avoid the potential risk that the State postpones or reneges on the payment. The City will also receive the funds eighteen (18) months earlier, which will help with cash flow needs and budget challenges. However, the City will not receive 100% of the receivable amount of $951,000. The total cost to the City to enter into this agreement would range from a high of $95,000 to a low of $79,000 --- depending on the interest rates at the time of the sale of the notes. The City of Petaluma would net from a high of $$871,653 to a low of $856,138. The total VLF Receivable amount due the City of Petaluma is $951,083.48. Recommended Citv Council Action/Suegested Motion: Revi„FF)vedll�y Fhrce Director: Reviewed by City Attornev: Approved t6v ManagEr: — i ` / ��i:q.�- D s '�1i1q Date: �I�/ Date: T av"stDate: `Revision # and Date Revised: File Cole: # CITY OF PETALUMA, CALIFORNIA FEBRUARY 7, 2005 AGENDA REPORT FOR Vehicle License Fee (VLF) Gap Loan Program With the California Statewide Communities Development Authority (CSCDA) EXECUTIVE SUMMARY: In June, 2003, the State suspended the VLF "backfill" due to insufficient State General Fund monies. The 2% rate was restored and became effective on October 1, 2003. Local governments lost about $1.2 billion during the three months of the suspension of the VLF "backfill" and the implementation of the higher fees. For the City of Petaluma, this equated to a loss of approximately $951,000 in VLF revenues. The State's 2004 budget included repayment of the $1.2 billion to local governments by August 12, 2006, as well as a permanent reduction of the VLF rate of 0.65%. The reduction in VLF revenue will be replaced by property taxes; however for 2005 and 2006, the payment will be reduced by a total of $700 million to assist the state in balancing its budget. Commencing in FY 2006-07, local governments will receive their full share of replacement property taxes and those taxes will be constitutionally protected against transfers by the State per the recent passage of Proposition 1-A. The California Statewide Communities Development Authority ("CSCDA"), which is a joint powers authority sponsored by the League of California Cities and the California State Association of Counties instituted the VLF Loan Program to enable cities and counties to sell their respective VLF Receivables to CSCDA for an up- front fixed purchase price estimated to be between 89% to 91% of the VLF Gap Repayment. CSCDA is planning to issue notes and to use the note proceeds to purchase the VLF receivables and pay the financing costs. The balance of the proceeds will be used to cover any capitalized interest and issuance costs. By Selling the VLF Receivable, the City will avoid the potential risk that the State postpones or reneges on the payment. The City will also receive the funds eighteen (18) months earlier, which will help with cash flow needs and budget challenges. However, the City will not receive 100% of the receivable amount of $951,000. The total cost to the City to enter into this agreement would range from a high of $95,000 to a low of $79,000 -- - depending on the interest rates at the time of the sale of the notes. The City of Petaluma would net from a high of $$871,653 to a low of $856,138. The total VLF Receivable amount due the City of Petaluma is $951,083.48. 2. BACKGROUND: Background Vehicle License Fees and VLF Gao Reoavment: Vehicle license fees ("VLF") were historically assessed in the amount of 2% of a vehicle's depreciated market value for the privilege of operating a vehicle on California's public highways. Beginning in 1999, the VLF paid by vehicle owners was offset (or reduced) to the effective rate of 0.65%. In connection with the offset of the VLF, the Legislature authorized appropriations from the State General Fund to "backfill" the offset so that local governments, which receive all of the vehicle license fee revenues, would not experience any loss of revenues. The legislation that established the VLF offset program also provided that if there were insufficient State General Fund moneys to fully "backfill" the VLF offset, the percentage offset would be reduced proportionately (i.e., the license fee payable by drivers would be increased) to assure that local governments would not be disadvantaged. In June 2003, the Director of Finance under the Davis Administration ordered the suspension of VLF offsets due to a determination that insufficient State General Fund moneys would be available for this purpose, and, beginning in October 2003, the VLF paid by vehicle owners were restored to the 2% level. However, the offset suspension was rescinded by Governor Schwarzenegger on November 17, 2003, and State offset payments to local governments resumed. Local governments received "backfill" payments totaling $3.80 billion in FY 2002-03. `Backfill" payments totaling $2.65 billion were paid to local governments in FY 2003- 04. However, approximately $1.2 billion was not received by local governments during the time period between the suspension of the VLF offsets and the implementation of higher fees and is still owed them by the State (the "VLF Gap Repayments"). The City of Petaluma's share of the VLF Gap Repayment is $951,083.48. This amount is identified as Petaluma's VLF Receivable. As part of the 2004 Budget Act negotiations, an agreement was made between the State and local government officials (the "State -local agreement") under which the VLF rate will be permanently reduced from 2% to 0.65%. The State -local agreement also provides for the repayment by August 15, 2006 of the approximately $1.2 billion VLF Gap Repayment. In order to protect local governments, the reduction in VLF revenue to cities and counties from this rate change will be replaced by an increase in the amount of property tax they receive. Under the State -local agreement, for FY 2004-05 and 2005-06 only, the replacement property taxes that cities and counties receive has been reduced by $700 million. Commencing in FY 2006-07, local governments will receive their full share of replacement property taxes and those replacement property taxes will now enjoy constitutional protection against transfers by the State due to the approval of Proposition IA at the November 2004 election. VLF Proeram: Authorized under SB 1096, the VLF Program was instituted by the California Statewide Communities Development Authority ("CSCDA") in 2004 to enable the [City/County] and other cities and counties to sell their respective VLF Receivables to CSCDA for an upfront fixed purchase price estimated to be 90.02% of the VLF Gap Repayments. CSCDA is planning to issue bonds ("VLF Bonds") and to use the bond proceeds to purchase the VLF Receivables and pay financing costs. The actual purchase price of the VLF Receivables will depend on the total amount of VLF Receivables that cities and counties sell to CSCDA and on bond market conditions at the time the VLF Bonds are priced. If the City of Petaluma sells its VLF Receivable under the VLF Program, CSCDA will pledge the City's VLF Receivable to secure the repayment of a corresponding portion of the VLF Bonds. The City's sale of its VLF Receivable will be irrevocable. Bondholders will have no recourse to the City if the State does not make the VLF Gap Repayment. VLF Proeram Sponsor: CSCDA is a joint powers authority sponsored by the League of California Cities and the California State Association of Counties. The member agencies of CSCDA include approximately 230 cities and 54 counties throughout California, including the City of Petaluma. Benefits of Participation in the VLF Prop -ram: The benefits to the City of Petaluma of participation in the VLF Program include: • Immediate cash relief— the sale of the City's VLF Receivable is estimated to provide the City with approximately 90.02% of its VLF Receivable in early 2005 which can be used to pay for immediate funding needs. • Level cash flow from the State over next two vears — as explained above, in each of FY 2004-05 and 2005-06, cities and counties across the State will lose a total of $700 million annually in property tax payments to the Educational Revenue Augmentation Fund ("ERAF"), which benefits the State. Accordingly, the City of Petaluma is projected to lose approximately $693,456 in each such fiscal year. This loss in property tax revenue in FY 2004-05 and 2005-06 will be followed by an increase in revenues in FY 2006-07 due to the payment by the State of the VLF Gap Repayment and due to the cessation of ERAF payments in that year. If the City sells its VLF Receivable through the VLF Program, it can use the sale proceeds to offset the loss of revenues due to its property tax contributions over the next two years and eliminate the spike in revenues in the third year, thereby creating a more level cash flow in each of the next three fiscal years. Rlitieates impact of nronerty tax in -lieu of VLF swan over next two vears_ — beginning in FY 2004-05, the State will permanently eliminate the VLF backfill paid to the City of Petaluma and will replace it with an equal amount of property tax. While these actions are intended to cancel each other out, the City is now receiving these payments semi-annually as property taxes, rather than monthly as VLF backfill payments. This situation creates potential cash flow problems for the City which could be temporarily alleviated by selling the City's VLF Receivable. Budsetary flexibility in FY 2004-05 and 2005-06 — the sale of the City's VLF Receivable would provide additional revenues in FY 2004-05 which can be applied to resolve budgetary challenges in FY 2004-05 and 2005-06. Estimated Proceeds of the Sale of the (City/Countvl's VLF Receivable: Upon delivery of the VLF Bonds, CSCDA will make available to the City of Petaluma its fixed purchase price. This payment will equal the City's VLF Receivable amount less capitalized interest costs (to pay interest on the VLF Bonds until maturity), credit enhancement fees and bond issuance costs. As discussed above, the [City/County]'s VLF Receivable is $951,083.48. The purchase price to be paid by CSCDA is estimated to be $94,945 but cannot be determined with specificity until the total number of participants in the VLF Program is known and bond market conditions are taken into account at the time the VLF Bonds are priced. Proposed VLF Receivables Sale Resolution: The proposed VLF Receivables Sale Resolution: (1) authorizes the sale of the City of Petaluma's VLF Receivable to CSCDA for a sale price at least equal to $951,083.48 (the "Target Amount"), or such lesser amount as determined by an Authorized Officer to be in the best interest of the City based on market conditions at the time of the sale of the VLF Bonds, provided that such lesser amount shall in no case be less than 90% of the Target Amount; (2) approves the form, and directs the execution and delivery, of the Purchase and Sale Agreement with CSCDA and related documents; (3) authorizes and directs any Authorized Officer to send, or to cause to be sent, an irrevocable written instruction required by statute to the State Controller notifying the State of the sale of the VLF Receivable and instructing the disbursement of the VLF Receivable to the VLF Bond Trustee; [(4) approves the use of the VLF Receivables proceeds for General Operating Expenses (5) appoints certain City officers and officials as Authorized Officers for purposes of signing documents and approving the final sale price of the VLF Receivable; and (6) authorizes miscellaneous related actions and makes certain ratifications, findings and determinations required by law. After the Petaluma City Council's discussion and questions, if the Council wishes to participate in the VLF Program, it should adopt the proposed VLF Receivables Sale Resolution which requires only a simple majority vote. 3. ALTERNATIVES: Do not accept the VLF Loan offer and wait until August 15, 2006 to receive the monies due from the State for the VLF Receivable backfill. This amount would be 100% of the receivable or $951,083.48. 4. FINANCIAL IMPACTS: The cost to the City of Petaluma would be a low of approximately $79,000 or 8.3% to a high of approximately $95,000 or 10%. The costs are to be used for issuance costs and capitalized interest on the bonds. However, the City would receive the balance, approximately $856,137 eighteen (18) months early. CONCLUSION: The real question is a TRUST issue. Does the City of Petaluma trust the State that they will keep their promise and repay all the City's VLF receivable in a timely manner? If not, then the VLF Loan is a good idea. If we do trust the State to meet its obligation, then it would be foolish to spend approximately $95,000 just to receive 90% of the monies due eighteen months earlier. 6. OUTCOMES OR PERFORMANCE MEASUREMENTS THAT WILL IDENTIFY SUCCESS OR COMPLETION: Receipt of the VLF Loan (Net Amount) in February or March 2005 to be used in the City's General Government Operations. RECOMMENDATION: After the Petaluma City Council's discussion and questions, if the Council wishes to participate in the VLF Program, it should adopt the proposed VLF Receivables Sale Resolution which requires only a simple majority vote. RESOLUTION NO. CITY COUNCIL OF THE CITY OF PETALUMA A RESOLUTION APPROVING THE FORM OF AND AUTHORIZING THE EXECUTION AND DELIVERY OF A PURCHASE AND SALE AGREEMENT AND RELATED DOCUMENTS WITH RESPECT TO THE SALE OF THE SELLER'S VEHICLE LICENSE FEE RECEIVABLE FROM THE STATE; AND DIRECTING AND AUTHORIZING CERTAIN OTHER ACTIONS IN CONNECTION THEREWITH WHEREAS, certain public agencies within the State of California (the "State") are entitled to receive certain payments payable by the State to each such local agency on or before August 15, 2006, in connection with vehicle license fees pursuant to Section 10754.11 of the California Revenue and Taxation Code ("VLF Gap Repayments"); WHEREAS, the City of Petaluma (the "Seller") is entitled to and has determined to sell all right, title and interest of the Seller in and to the "VLF Receivable", as defined in Section 6585(i) of the California Government Code (the "VLF Receivable"), namely, the right to payment of moneys due or to become due to the Seller out of funds payable in connection with vehicle license fees to a local agency pursuant to Section 10754.11 of the California Revenue and Taxation Code; WHEREAS, the California Statewide Communities Development Authority, a joint exercise of powers authority organized and existing under the laws of the State (the "Authority"), has been authorized pursuant to Section 6588(w) of the California Government Code to purchase the VLF Receivable; WHEREAS, the Authority desires to purchase the VLF Receivable and the Seller desires to sell the VLF Receivable pursuant to a purchase and sale agreement by and between the Seller and the Authority in the form presented to this City Council (the "Sale Agreement") for the purposes set forth herein; WHEREAS, in order to finance the purchase price of the VLF Receivable from the Seller and the purchase price of other VLF Receivables from other local agencies, the Authority will issue its taxable and tax-exempt notes (the "Notes") pursuant to Section 6590 of the California Government Code and an Indenture (tile "Indenture"), by and between the Authority and Wells Fargo Bank, National Association, as trustee (the "Trustee"), which Notes will be payable solely from the proceeds of the VLF Receivable and such other VLF Receivables; WHEREAS, the Seller acla3owledges that the Authority will grant a security interest in the VLF Receivable to the Trustee and any credit enhancer to secure payment of the Notes; and WHEREAS, a portion of the proceeds of the Notes will be used by the Authority to, among other things, pay the purchase price of the VLF Receivable; Taxable DOCSSF1:795390.1 WHEREAS, the Seller will use the proceeds received from the sale of the VLF Receivable for any lawfiil purpose as permitted under the applicable laws of the State; NOW THEREFORE, the City Council of the City of Petaluma hereby resolves as follows: Section 1. All of the recitals set forth above are true and correct, and this City Council hereby so finds and determines. Section 2. The Seller hereby authorizes the sale of the VLF Receivable to the Authority for a price no less than the Minimum Purchase Price set forth in ADDendix A. The form of Sale Agreement presented to the City Council is hereby approved. An Authorized Officer (as set forth in Annendix A) is hereby authorized and directed to execute and deliver the Sale Agreement on behalf of the Seller, which shall be in substantially the form presented to this meeting, with such changes therein, deletions therefrom and additions thereto, as such Authorized Officer shall approve, which approval shall be conclusively evidenced by the execution and delivery of the Sale Agreement. Section 3. Any Authorized Officer is hereby authorized and directed to send, or to cause to be sent, an irrevocable written instruction to the State Controller notifying the State of the sale of the VLF Receivable and instructing the disbursement pursuant to Section 6588.5(c) of California Government Code of the VLF Receivable to the Trustee, on behalf of the Authority. Section 4. The Authorized Officers and such other Seller officers, as appropriate, are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents, including but not limited to one or more tax certificates, if required, appropriate escrow instructions relating to the delivery into escrow of executed documents prior to the closing of the Notes, and such other documents mentioned in the Sale Agreement or the Indenture, which any of them may deem necessary or desirable in order to implement the Sale Agreement and otherwise to carry out, give effect to and comply with the terms and intent of this Resolution; and all such actions heretofore taken by such officers are hereby ratified, confirmed and approved. Section 5. All consents, approvals, notices, orders, requests and other actions permitted or required by any of the documents authorized by this Resolution, whether before or after the sale of the VLF Receivable or the issuance of the Notes, including without limitation any of the foregoing that may be necessary or desirable in connection with any default under or amendment of such documents, may be given or taken by an Authorized Officer without further authorization by this City Council, and each Authorized Officer is hereby authorized and directed to give any such consent, approval, notice, order or request, to execute any necessary or appropriate documents or amendments, and to take any such action that such Authorized Officer may deem necessary or desirable to further the purposes of this Resolution. Section 6. The City Council acknowledges that, upon execution and delivery of the Sale Agreement, the Seller is contractually obligated to sell the VLF Receivable to the Authority pursuant to the Sale Agreement and the Seller shall not have any option to revoke its approval of the Sale Agreement or to determine not to perform its obligations thereunder. Taxable DOCSSF1:795390.1 2 Section 7. This Resolution shall take effect from and after its adoption and approval. PASSED AND ADOPTED by the City Council of the City of Petaluma, State of California, this day of , 2005, by the following vote: AYES: NOES: ABSENT: Mayor Attest: City Clerk Approved as to farm : SELLER'S COUNSEL 10 Dated: Taxable uocssrI:795390.1 3 Minimum Purchase Price: Authorized Officers: Taxable UOCSSF1:795390.1 MQW0 CITY OF PETALUMA An amount equal to or greater than $855,934.63 (the "Minimum Purchase Price"). City Manager Interim Finance Director Accounting Manager any designee of any of them, as appointed in a written certificate of such Authorized Officer delivered to the Trustee. CITY OF PETALUMA, CALIFORNIA, as Seller and CALIFORNIA STATEWIDE COMMUNITIES DEVELOPMENT AUTHORITY, as Purchaser PURCHASE AND SALE AGREEMENT Dated March 2, 2005 Taxable DOCSSF1:795397A TABLE OF CONTENTS Page 1. DEFINITIONS AND INTERPRETATION......................................................................1 2. AGREEMENT TO SELL AND PURCHASE; CONDITIONS PRECEDENT ................ 2 3. CONVEYANCE OF VLF RECEIVABLE AND PAYMENT OF FINAL PURCHASEPRICE.......................................................................................................... 3 4. REPRESENTATIONS AND WARRANTIES OF THE PURCHASER .......................... 3 5. REPRESENTATIONS AND WARRANTIES OF THE SELLER ................................... 3 6. COVENANTS OF THE SELLER..................................................................................... 5 7. NOTICES OF BREACH................................................................................................... 7 8, LIABILITY OF SELLER; INDEMNIFICATION............................................................ 7 9. LIMITATION ON LIABILITY........................................................................................ 7 10. THE SELLER'S ACKNOWLEDGMENT........................................................................7 11. NOTICES...........................................................................................................................8 12. AMENDMENTS............................................................................................................... 8 13. SUCCESSORS AND ASSIGNS....................................................................................... 8 14. THIRD PARTY RIGHTS.................................................................................................. 8 15. PARTIAL INVALIDITY.................................................................................................. 8 16. COUNTERPARTS............................................................................................................ 8 17. ENTIRE AGREEMENT.................................................................................................... 9 18. GOVERNING LAW........................................................................................................ 10 EXHIBITA — DEFINITIONS................................................................................................... A -i EXHIBIT BI —OPINION OF SELLER'S COUNSEL...........................................................Bl-1 EXHIBIT B2 — BRINGDOWN OPINION OF SELLER'S COUNSEL ................................. B2-1 EXHIBIT CI —CLERK'S CERTIFICATE... ...................................... ................................... cl-I EXHIBIT C2 — SELLER CERTIFICATE............................................................................... C2-1 EXHIBIT C3 — BILL OF SALE AND BRINGDOWN CERTIFICATE ................................ C3-1 EXHIBIT D — IRREVOCABLE INSTRUCTIONS TO CONTROLLER ................................ D-1 EXHIBITE — RESERVED....................................................................................................... E -I EXHIBIT F — ESCROW INSTRUCTION LETTER ............... ...... ........ ................ .............. ...... F -I Taxable DOCSSF1:795397.1 1 PURCHASE AND SALE AGREEMENT THIS PURCHASE AND SALE AGREEMENT, dated March 2, 2005 (this "Agreement'), is entered into by and between: (1) CITY OF PETALUMA, a municipal corporation of the State of California (the "Seller"); and (2) CALIFORNIA STATEWIDE COMMUNITIES DEVELOPMENT AUTHORITY, a joint exercise of powers authority organized and existing under the laws of the State of California (the "Purchaser"). RECITALS A. The Seller is the owner of the VLF Receivable (as defined below). B. The Seller is willing to sell, and the Purchaser is willing to purchase, the VLF Receivable upon the terms specified in this Agreement. C. The Purchaser will issue its taxable and tax-exempt notes (the "Notes") pursuant to an Indenture (the "Indenture"), between the Purchaser and Wells Fargo Bank, National Association, as trustee (the "Trustee"), and will use a portion of the proceeds thereof to purchase the VLF Receivable from the Seller. D. The Purchaser will grant a security interest in such VLF Receivable to the Trustee and each Credit Enhancer to secure the Notes. AGREEMENT NOW, THEREFORE, in consideration of the above Recitals and the mutual covenants herein contained, the parties hereto hereby agree as follows: 1. Definitions and Intororetation. (a) For all purposes of this Agreement, except as otherwise expressly provided herein or unless the context otherwise requires, capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in Exhibit A attached hereto and which is incorporated by reference herein. (b) The words "hereof," "herein," "hereunder" and words of similar import when used in this Agreement shall refer to this Agreement as a whole and not to any particular provision of this Agreement; section and exhibits references contained in this Agreement are references to sections and exhibits in or to this Agreement unless otherwise specified; and the term "including" shall mean "including without limitation." (c) Any agreement, instrument or statute defined or referred to herein or in any instrument or certificate delivered in connection herewith means such agreement, instrument or statute as from time to time may be amended, modified or supplemented and includes (in the Taxable nOCSSF1:795397.1 case of agreements or instruments) references to all attachments and exhibits thereto and instruments incorporated therein; and any references to a Person are also to its permitted successors and assigns. 2. Aereement to Sell and Purchase: Conditions Precedent. (a) The Seller agrees to sell, and the Purchaser agrees to purchase, on the Closing Date, for cash paid by the Purchaser in an amount equal to the amount determined pursuant to Section 3(a) (the "Final Purchase Price"), which shall be not less than $855,934.63 (the "Minimum Purchase Price"), all future right, title and interest of the Seller in and to the "VLF Receivable" as defined in Section 6585(i) of the California Government Code (the "VLF Receivable"), namely, the right to payment of moneys due or to become due to the Seller out of funds payable in connection with vehicle license fees to a local agency pursuant to Section 10754.11 of the California Revenue and Taxation Code. The Purchaser shall pay the Final Purchase Price by transferring such Final Purchase Price directly to the Seller. (b) The performance by the Purchaser of its obligations hereunder shall be conditioned upon: (i) Transaction Counsel receiving on or before the date the Notes are sold (the "Pricine Date"), to be held in escrow until the Closing Date and then delivered to the Purchaser on the Closing Date, the following documents duly executed by the Seller or its counsel, as applicable: (1) an opinion of counsel to the Seller dated the Pricing Date in substantially the form attached hereto as Exhibit B1, (2) certificates dated the Pricing Date in substantially the forms attached hereto as Exhibit Cl and Exhibit C2. (3) irrevocable instructions to the Controller dated as of the Closing Date in substantially the form attached hereto as Exhibit D, (4) this Agreement, (5) a certified copy of the resolution of the Seller's City Council approving this Agreement, the transactions contemplated hereby and the documents attached hereto as exhibits, and (6) an escrow instruction letter in substantially the form attached hereto as Exhibit F; (ii) Transaction Counsel receiving on or before the Closing Date, (1) a bringdown opinion of counsel to the Seller dated as of the Closing Date in substantially the form attached hereto as Exhibit B2. and (2) a bill of sale and bringdown certificate of the Seller (the "Bill of Sale") in substantially the form attached hereto as Exhibit C3: provided that the Purchaser may waive in its sole discretion the requirements of Section 2(b)(ii)(1); and (iii) the Purchaser issuing notes in an amount which will be sufficient to pay the Final Purchase Price. (c) The performance by the Seller of its obligations hereunder shall be conditioned solely upon the Purchaser's payment of the Final Purchase Price as set forth in this Agreement and no other act or omission on the part of the Purchaser or any other party shall excuse the Seller from performing its obligations hereunder. Taxable DOCSSFI :795397.1 2 (d) The Final Purchase Price shall be an amount that satisfies the conditions of Section 2 of the Resolution referred to in Section 2(b)(i)(5) above. 3. Convevance of VLF Receivable and Payment of Final Purchase Price. (a) Upon pricing of the Notes by the Purchaser, the Purchaser will inform the Seller of the Final Purchase Price, which shall be an amount at least equal to the Minimum Purchase Price, and which shall be determined by the Purchaser based on the final interest rates, costs of credit enhancement and issuance and terms of the Notes. Upon pricing of the Notes, the Purchaser shall deliver a certificate to the Seller indicating the Final Purchase Price to be paid to the Seller on the Closing Date. (b) In consideration of the payment and delivery by the Purchaser to the Seller of the Final Purchase Price, the Seller agrees to (a) transfer, grant, bargain, sell, assign, convey, set over and deliver to the Purchaser, absolutely and not as collateral security, without recourse except as expressly provided herein, and the Purchaser agrees to purchase, accept and receive, the VLF Receivable, and (b) assign to the Purchaser, to the extent permitted by law (as to which no representation is made), all present or future rights, if any, of the Seller to enforce or cause the enforcement of payment of the VLF Receivable pursuant to the Act and other applicable taw. 4. Representations and Warranties of the Purchaser. The Purchaser represents and warrants to the Seller that, as of the date hereof, (a) it is duly organized, validly existing and in good standing under the laws of the State of California, (b) it has full power and authority to enter into this Agreement and to perform its obligations hereunder, (c) neither the execution and delivery by the Purchaser of this Agreement, nor the performance by the Purchaser of its obligations hereunder, shall conflict with or result in a breach or default under any of its organizational documents, any law, rule, regulation, judgment, order or decree to which it is subject or any agreement or instrument to which it is a party, and (d) this Agreement, and its execution, delivery and performance hereof have been duly authorized by it, and this Agreement has been duly executed and delivered by it and constitutes its valid and binding obligation enforceable against it in accordance with the terms hereof, subject to the effect of bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws relating to or affecting creditors' rights generally or the application of equitable principles in any proceeding, whether at law or in equity. 5. Reuresentations and Warranties of the Seller. The Seller hereby represents and warrants to the Purchaser, as of the date hereof, as follows; (a) The Seller is a municipal corporation validly existing under the city charter and Constitution of the State of California, with full power and authority to execute and deliver this Agreement and to carry out its terms. (b) The Seller has full power, authority and legal right to sell and assign the VLF Receivable to the Purchaser and has duly authorized such sale and assignment to the Purchaser by all necessary action; and the execution, delivery and performance by the Seller of this Agreement has been duly authorized by the Seller by all necessary action. Taxable DOCSSFI :797397.1 3 (c) This Agreement has been, and as of the Closing Date the Bill of Sale will have been, duly executed and delivered by the Seller and, assuming the due authorization, execution and delivery of this Agreement by the Purchaser, constitutes a legal, valid and binding obligation of the Seller enforceable in accordance with its terms, subject to the effect of bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws relating to or affecting creditors' rights generally or the application of equitable principles in any proceeding, whether at law or in equity. (d) All approvals, consents, authorizations, elections and orders of or filings or registrations with any governmental authority, board, agency or commission having jurisdiction which would constitute a condition precedent to, or the absence of which would adversely affect, the sale by the Seller of the VLF Receivable or the performance by the Seller of its obligations under the Resolution and the Transaction Documents and any other applicable agreements, have been obtained and are in full force and effect. (e) Insofar as it would materially adversely affect the Seller's ability to enter into, carry out and perform its obligations under any or all of the Transaction Documents to which it is a party, or consummate the transactions contemplated by the same, the Seller is not in breach of or default under any applicable constitutional provision, law or administrative regulation of the State of California or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which it is a party or to which it or any of its property or assets is otherwise subject, and, to the best of the knowledge of the Seller, no event has occurred and is continuing which with the passage of time or the giving of notice, or both, would constitute a default or an event of default under any such instrument, and the adoption of the Resolution and the execution and delivery by the Seller of the Transaction Documents to which it is a party, and compliance by the Seller with the provisions thereof, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the Seller a breach of or default under any agreement or other instrument to which the Seller is a party or by which it is bound or any existing law, regulation, court order or consent decree to which the Seller is subject. (f) To the best of the knowledge of the Seller, no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, public board or body, is pending or threatened in any way against the Seller affecting the existence of the Seller or the titles of its City Council members or officers to their respective offices, or seeking to restrain or to enjoin the sale of the VLF Receivable or to direct the application of the proceeds of the sale thereof, or in any way contesting or affecting the validity or enforceability of any of the Transaction Documents or any other applicable agreements or any action of the Seller contemplated by any of said documents, or in any way contesting the powers of the Seller or its authority with respect to the Resolution or the Transaction Documents to which the Seller is a party or any other applicable agreement, or any action on the part of the Seller contemplated by the Transaction Documents, or in any way seeking to enjoin or restrain the Seller from selling the VLF Receivable or which if determined adversely to the Seller would have an adverse effect upon the Seller's ability to sell the VLF Receivable, nor to the knowledge of the Seller is there any basis therefor. Taxable nOCSSFi:795397.1 4 (g) Prior to the sale of the VLF Receivable to the Purchaser, the Seller was the sole owner of the VLF Receivable, and has such right, title and interest as provided in the Act. From and after the conveyance of the VLF Receivable by the Seller to Purchaser on the CIosing Date, the Seller shall have no interest in the VLF Receivable. Except as provided in this Agreement, the Seller has not sold, transferred, assigned, set over or otherwise conveyed any right, title or interest of any kind whatsoever in all or any portion of the VLF Receivable, nor has the Seller created, or to the knowledge of the Seller permitted the creation of, any lien, pledge, security interest or any other encumbrance (a "Lien") thereon. Prior to the sale of the VLF Receivable to the Purchaser, the Seller held title to the VLF Receivable free and clear of any Liens. As of the Closing Date, this Agreement, together with the Bill of Sale, constitutes a valid sale to the Buyer of the Seller's right, title and interest in and to the VLF Receivable. (h) The Seller acts solely through its authorized officers or agents. (i) The Seller maintains records and books of account separate from those of the Purchaser. 0) The Seller maintains its respective assets separately from the assets of the Purchaser (including through the maintenance of separate bank accounts); the Seller's funds and assets, and records relating thereto, have not been and are not commingled with those of the Purchaser. (k) The Seller's principal place of business and chief executive office is located at 11 English Street, Petaluma, CA 94952. (1) The Seller has received reasonably equivalent value for the VLF Receivable. - (m)The Seller does not act as an agent of the Purchaser in any capacity, but instead presents itself to the public as an entity separate from the Purchaser. (n) The Seller has not guaranteed and shall not guarantee the obligations of the Purchaser, nor shall it hold itself out or permit itself to be held out as having agreed to pay or as being liable for the debts of the Purchaser; and the Seller has not received nor shall the Seller accept any credit or financing from any Person who is relying upon the availability of the assets of the Purchaser to satisfy the claims of such creditor. (o) All transactions between or among the Seller, on the one hand, and the Purchaser on the other hand (including, without limitation, transactions governed by contracts for services and facilities, such as payroll, purchasing, accounting, legal and personnel services and office space), whether existing on the date hereof or entered into after the date hereof, shall be on terms and conditions (including, without limitation, terms relating to amounts to be paid thereunder) which are believed by each such party thereto to be both fair and reasonable and comparable to those available on an arms -length basis from Persons who are not affiliates. 6. Covenants of the Seller. (a) The Seller shall not take any action or omit to take any action which adversely affect the interests of the Purchaser in the VLF Receivable and in the proceeds thereof. The Taxable DOCSSFl:795397.1 5 Seller shall not take any action or omit to take any action that shall adversely affect the ability of the Purchaser, and any assignee of the Purchaser, to receive payments made under the Act. (b) The Seller shall not take any action or omit to take any action that would impair the validity or effectiveness of the Act, nor, without the prior written consent of the Purchaser or its assignee, amend, modify, terminate, waive or surrender, or agree to any amendment, modification, termination, waiver or surrender of, the terms of the Act, or waive timely performance or observance under the Act, in each case if the effect thereof would be materially adverse to the Purchaser or to the Noteholders or any Credit Enhancer as assignees of the Purchaser. Nothing in this agreement shall impose a duty on the Seller to seek to enforce the Act or to seek enforcement thereof by others, or to prevent others from modifying, terminating, discharging or impairing the validity or effectiveness of the Act. (c) Upon request of the Purchaser or its assignee, (i) the Seller shall execute and deliver such further instruments and do such further acts (including being named as a plaintiff in an appropriate proceeding) as may be reasonably necessary or proper to carry out more effectively the purposes and intent of this Agreement, and (ii) the Seller shall take all actions necessary to preserve, maintain and protect the title of the Purchaser to the VLF Receivable, provided that such acts shall not impose any additional cost on the Seller that is not reimbursed. (d) On or before the Closing Date, the Seller shall send (or cause to be sent) an irrevocable instruction to the Controller pursuant to Section 6588.5(c) of California Government Code to cause the Controller to disburse all payments of the VLF Receivable to the Trustee, together with notice of the sale of the VLF Receivable to the Purchaser and the assignment of all or a portion of such assets by the Purchaser to the Trustee. Such notice and instructions shall be in the form of Exhibit D hereto. The Seller shall not take any action to revoke or which would have the effect of revoking, in whole or in part, such instructions to the Controller. The Seller hereby relinquishes and waives any control over the VLF Receivable, any authority to collect the VLF Receivable, and any power to revoke or amend the instructions to the Controller contemplated by this paragraph. The Seller shall not rescind, amend or modify the instruction described in the first sentence of this paragraph. The Seller shall cooperate with the Purchaser or its assignee in giving instructions to the Controller if the Purchaser or its assignee transfers the VLF Receivable. In the event that the Seller receives any proceeds of the VLF Receivable, the Seller shall hold the same in trust for the benefit of the Purchaser and the Trustee and each Credit Enhancer, as assignees of the Purchaser, and shall promptly remit the same to the Trustee. (e) The Seller hereby covenants and agrees that it will not at any time institute against the Purchaser, or join in instituting against the Purchaser, any bankruptcy, reorganization, arrangement, insolvency, liquidation, or similar proceeding under any United States or state bankruptcy or similar law. (f) The financial statements and books and records of the Seller prepared after the Closing Date shall reflect the separate existence of the Purchaser. (g) The Seller shall treat the sale of the VLF Receivable as a sale for regulatory and accounting purposes. Taxable DOCSSFI :795397.1 6 (h) From and after the date of this Agreement, the Seller shall not sell, transfer, assign, set over or otherwise convey any right, title or interest of any kind whatsoever in all or any portion of the VLF Receivable, nor shall the Seller create, or to the knowledge of the Seller permit the creation of, any Lien thereon. 7. Notices of Breach, (a) Upon discovery by the Seller or the Purchaser that the Seller has breached any of its covenants or that any of the representations or warranties of the Seller or the Purchaser are materially false or misleading, in a manner that materially and adversely affects the value of the VLF Receivable, the discovering party shall give prompt written notice thereof to the other party and to the Trustee, as assignee of the Purchaser, who shall, pursuant to the Indenture, promptly thereafter notify each Credit Enhancer and the Rating Agencies. (b) The Seller shall not be liable to the Purchaser, the Trustee, the Noteholders, or any Credit Enhancer for any loss, cost or expense resulting solely from the failure of the Trustee, any Credit Enhancer or the Purchaser to promptly notify the Seller upon the discovery by an authorized officer of the Trustee, any Credit Enhancer or the Purchaser of a breach of any covenant or any materially false or misleading representation or warranty contained herein. 8. Liabilitv of Seller: Indemnification. The Seller shall be liable in accordance herewith only to the extent of the obligations specifically undertaken by the Seller under this Agreement. The Seller shall indemnify, defend and hold harmless the Purchaser, the Trustee and each Credit Enhancer, as assignees of the Purchaser, and their respective officers, directors, employees and agents from and against any and all costs, expenses, losses, claims, damages and liabilities to the extent that such cost, expense, loss, claim, damage or liability arose out of, or was imposed upon any such Person by the Seller's breach of any of its covenants contained herein or any materially false or misleading representation or warranty of the Seller contained herein. Notwithstanding anything to the contrary herein, the Seller shall have no liability for the payment of the principal of or interest on the Notes issued by the Purchaser. 9. Limitation on Liabilitv. (a) The Seller and any officer or employee or agent of the Seller may rely in good faith on the advice of counsel or on any document of any kind, prima facie properly executed and submitted by any Person respecting any matters arising hereunder. The Seller shall not be under any obligation to appear in, prosecute or defend any legal action regarding the Act that is unrelated to its specific obligations under this Agreement. (b) No officer or employee of the Seller shall have any liability for the representations, warranties, covenants, agreements or other obligations of the Seller hereunder or in any of the certificates, notices or agreements delivered pursuant hereto, as to all of which recourse shall be had solely to the assets of the Seller. 10. The Seller's Acknowledsment. The Seller hereby agrees and acknowledges that the Purchaser intends to assign and grant a security interest in all or a portion of (a) its rights hereunder and (b) the VLF Receivable, to the Trustee and each Credit Enhancer pursuant to the Indenture. The Seller further agrees and acknowledges that the Trustee, the Noteholders, and Taxable nocssFi:795397.1 7 each Credit Enhancer have relied and shall continue to rely upon each of the foregoing representations, warranties and covenants, and further agrees that such Persons are entitled so to rely thereon. Each of the above representations, warranties and covenants shall survive any assignment and grant of a security interest in all or a portion of this Agreement or the VLF Receivable to the Trustee and each Credit Enhancer and shall continue in full force and effect, notwithstanding any subsequent termination of this Agreement and the other transaction documents. The above representations, warranties and covenants shall inure to the benefit of the Trustee and each Credit Enhancer. 11. Notices. All demands upon or, notices and communications to, the Seller, the Purchaser, the Trustee or the Rating Agencies under this Agreement shall be in writing, personally delivered or mailed by certified mail, return receipt requested, to such party at the appropriate notice address, and shall be deemed to have been duly given upon receipt. 12. Amendments. This Agreement may be amended by the Seller and the Purchaser, with (a) the consent of the Trustee, (b) the consent of each Credit Enhancer, and (c) a Rating Agency Confirmation, but without the consent of any of the Noteholders, for the purpose of adding any provisions to or changing in any manner or eliminating any of the provisions of this Agreement. Promptly after the execution of any such amendment, the Purchaser shall furnish written notification of the substance of such amendment to the Trustee and to the Rating Agencies. 13. Successors and Assigns. This Agreement shall be binding upon and inure to the benefit of the Seller, the Purchaser and their respective successors and permitted assigns. The Seller may not assign or transfer any of its rights or obligations under this Agreement without the prior written consent of the Purchaser. Except as specified herein, the Purchaser may not assign or transfer any of its rights or obligations under this Agreement without the prior written consent of the Seller. 14. Third Partv Rights. The Trustee and each Credit Enhancer are express and intended third party beneficiaries under this Agreement. Nothing expressed in or to be implied from this Agreement is intended to give, or shall be construed to give, any Person, other than the parties hereto, the Trustee and each Credit Enhancer, and their permitted successors and assigns hereunder, any benefit or legal or equitable right, remedy or claim under or by virtue of this Agreement or under or by virtue of any provision herein. 15. Partial Invaliditv. If at any time any provision of this Agreement is or becomes illegal, invalid or unenforceable in any respect under the law of any jurisdiction, neither the legality, validity or enforceability of the remaining provisions of this Agreement nor the legality, validity or enforceability of such provision under the law of any other jurisdiction shall in any way be affected or impaired thereby. 16. Countemarts. This Agreement may be executed in any number of identical counterparts, any set of which signed by all the parties hereto shall be deemed to constitute a complete, executed original for all purposes. Taxable DOCSSFI :795397.1 8 17. Entire Aareement. This Agreement sets forth the entire understanding and agreement of the parties with respect to the subject matter hereof and supersedes any and all oral or written agreements or understandings between the parties as to the subject matter hereof. Taxable DOCSSF1:795397.1 9 18. Governine Law, This Agreement shall be governed by and construed in accordance with the laws of the State of California. IN WITNESS WHEREOF, the Seller and the Purchaser have caused this Purchase and Sale Agreement to be duly executed as of the date first written above. CITY OF PETALUMA, as Seller Authorized Officer CALIFORNIA STATEWIDE COMMUNITIES DEVELOPMENT AUTHORITY, as Purchaser Member Taxable DOCSS F1:795397.1 10 EXHIBIT A DEFINITIONS For all purposes of this Agreement, except as otherwise expressly provided herein or unless the context otherwise requires, capitalized terms not otherwise defined herein shall have the meanings set forth below. "Act" means Section 10754.11 of the California Revenue and Taxation Code. "Bill of Sale" has the meaning give to that term in Section 2(b)(ii) hereof. "Credit Enhancer" means any municipal bond insurance company, bank or other financial institution or organization which is performing in all material respects its obligations under any Credit Support Instrument for some or all of the Notes. "Credit Support Instrument" means a policy of insurance, a letter of credit, a stand-by purchase agreement, revolving credit agreement or other credit arrangement pursuant to which a Credit Enhancer provides credit or liquidity support with respect to the payment of interest, principal or the purchase price of the Notes. "Closing Date" means the date the Notes are issued. "Controller" means the Controller of the State. "Final Purchase Price" has the meaning ascribed thereto in Section 2. "Minimum Purchase Price" has the meaning ascribed thereto in Section 2. "Noteholder" means, with respect to any Note, the person in whose name such Note is registered. "Oustanding" has the meaning given to that term in the Indenture. "Pricing Date" means the date the Notes are sold. "Rating Agency" means any nationally recognized rating agency then providing or maintaining a rating on the Notes at the request of the Purchaser. "Rating Agency Confirmation" means written confirmation from each Rating Agency that any proposed action will not, in and of itself, cause the Rating Agency to lower, suspend or withdraw the rating then assigned by such Rating Agency to any Outstanding Notes. "Resolution" means the resolution adopted by the City Council approving the sale of the VLF Receivable. "State" means the State of California. "Transaction Counsel" means Orrick, Herrington & Sutcliffe LLP. Taxable DOCSSFI :795397. t A- I "Transaction Documents" mean this Agreement, the Bill of Sale, the Indenture, and the Notes. Taxable DOCSSF1:795397.1 A"2 EXHIBIT BI to CITY OF PETALUMA March 2, 2005 California Statewide Communities Development Authority Sacramento, California Wells Fargo Bank, National Association Los Angeles, California Re: Sale of VLF Receivable Ladies & Gentlemen: This Office acted as counsel for the City of Petaluma (the "Seller") in connection with the adoption of that certain resolution (the "Resolution") of the City Council of the Seller (the "Governing Body") pursuant to which the Seller authorized the sale to the California Statewide Communities Development Authority (the "Purchaser") of the Seller's `VLF Receivable", as defined in and pursuant to the Purchase and Sale Agreement dated March 2, 2005 (the "Sale Agreement") between the Seller and the Purchaser. In connection with these transactions, the Seller has issued certain Irrevocable Instructions For Disbursement of the Seller's VLF Receivable to the Controller of the State of California (the "Disbursement Instructions" and collectively with the Sale Agreement, the "Transaction Documents"). Unless the context otherwise requires, capitalized terns used but not otherwise defined herein shall have the meanings given to such terms in the Sale Agreement. I have examined and am familiar with those documents relating to the existence, organization, and operation of the Seller, the Resolution, the Transaction Documents and such certified proceedings, certifications of officers of the Seller and others, and such other agreements, instruments and documents, and have satisfied myself as to such other matters, as I deem necessary in order to render the following opinions. Based upon the foregoing, I am of the opinion that: 1. The Seller is a municipal corporation of the State of California, duly organized and validly existing pursuant to the city charter and the Constitution of the State of California. Taxable DOCSSF1:795397.1 BI -1 2. The Seller has full power and authority to adopt the Resolution and to execute and deliver the Transaction Documents. 3. The Seller has duly authorized and executed the Transaction Documents and, assuming delivery, each Transaction Document will be legal, valid, and binding against the Seller, and enforceable against the Seller in accordance with its terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, fraudulent conveyance, moratorium or laws relating to or affecting creditors' rights, and the application of equitable principles and the exercise of judicial discretion in appropriate areas. 4. The Resolution was duly adopted at a meeting of the Governing Body which was called and held pursuant to law with all public notice required by law and at which a quorum was present and acting when the Resolution was adopted. 5. The Resolution is in full force and effect and has not been amended, modified, supplemented or rescinded. 6. To the best of my knowledge, no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, public board or body, is pending or threatened in any way against the Seller affecting the existence of the Seller or the titles of its Governing Body members or officers to their respective offices, or seeking to restrain or to enjoin the sale of the VLF Receivable or to direct the application of the proceeds of the sale thereof, or in any way contesting or affecting the validity or enforceability of the Resolution, the Transaction Documents or any other applicable agreements or any action of the Seller contemplated by any of said documents, or in any way contesting the powers of the Seller or its authority with respect to the Resolution or the Transaction Documents or any other applicable agreement, or any action on the part of the Seller contemplated by any of said documents, or in any way seeking to enjoin or restrain the Seller from selling the VLF Receivable or which if determined adversely to the Seller would have a material and adverse effect upon the Seller's ability to sell the VLF Receivable, nor to my knowledge is there any basis therefor. 7. Insofar as it would materially adversely affect the Seller's ability to enter into, carry out and perform its obligations under any or all of the foregoing agreements, or consummate the transactions contemplated by the same, the Seller is not in breach of or default under any applicable constitutional provision, law or administrative regulation of the State or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which it is a party or to which it or any of its property or assets is otherwise subject, and, to the best of my knowledge, no event has occurred and is continuing which with the passage of time or the giving of notice, or both, would constitute a default or an event of default under any such instrument, and the adoption of the Resolution and the execution and delivery by the Seller of the Transaction Documents, and compliance with the provisions thereof, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the Seller a breach of or default under any agreement or other instrument to which the Seller is a party or by which it is bound or any existing law, regulation, court order or consent decree to which the Seller is subject. Taxable DOCSSFl:795397.1 BI -2 8. Prior to the sale of the VLF Receivable to the Purchaser, the Seller was the sole owner of the VLF Receivable, and has such right, title and interest as provided in the Act. From and after the conveyance of the VLF Receivable by the Seller to Purchaser on the Closing Date, the Seller shall have no interest in the VLF Receivable. Except as provided in the Sale Agreement, the Seller has not sold, transferred, assigned, set over or otherwise conveyed any right, title or interest of any kind whatsoever in all or any portion of the Seller's VLF Receivable, nor has the Seller created, or to my knowledge permitted the creation of, any Lien thereon. Prior to the sale of the VLF Receivable to the Purchaser, the Seller held title to the VLF Receivable free and clear of any Liens. 9. To the best of my knowledge, all approvals, consents, authorizations, elections and orders of or filings or registrations with any governmental authority, board, agency or commission having jurisdiction which would constitute a condition precedent to, or the absence of which would materially adversely affect, the sale by the Seller of the VLF Receivable or the performance by the Seller of its obligations under the Resolution and the Transaction Documents and any other applicable agreements, have been obtained and are in fill force and effect. 10. The Disbursement Instructions are irrevocable by the Seller, and comply with the requirements of Section 6588.5{c} of the California Government Code. Each Credit Enhancer, the underwriters of the Notes and Transaction Counsel may rely upon this legal opinion as if it were addressed to them. Very truly yours, Seller's Counsel Taxable nOCSSF1:795397. f B 1-3 EXHIBIT B2 OPINION OF COUNSEL to CITY OF PETALUMA [Closing Date] California Statewide Communities Development Authority Sacramento, California Wells Fargo Bank, National Association Los Angeles, California Re: Sale of VLF Receivable (Brinedown Opinion) Ladies & Gentlemen: Pursuant to that certain Purchase and Sale Agreement dated March 2, 2005 (the "Sale Agreement") between the City of Petaluma (the "Seller") and the California Statewide Communities Development Authority (the "Purchaser"), this Office delivered an opinion (the "Opinion") dated the Pricing Date (as defined in the Sale Agreement) as counsel for the Seller in connection with the sale of the Seller's VLF Receivable (as defined in the Sale Agreement), the execution of documents related thereto and certain other related matters. I confirm that you may continue to rely upon the Opinion as if it were dated as of the date hereof. Each Credit Enhancer, the underwriters of the Notes and Transaction Counsel may rely upon this legal opinion as if it were addressed to them. This letter is delivered to you pursuant to Section 2(b)(ii)(1) of the Sale Agreement. Very truly yours, In Seller's Counsel Taxable DOCSSF1:795397.1 132-1 EXHIBIT CI CLERK'S CERTIFICATE CERTIFICATE OF THE CITY CLERK OF CITY OF PETALUMA, CALIFORNIA Dated: March 2, 2005 The undersigned City Clerk of the City of Petaluma, California, do hereby certify that the foregoing is a full, true and correct copy of Resolution No. duly adopted at a regular meeting of the City Council of said Seller duly and regularly and legally held at the regular meeting place thereof on the day of , 2005, of which meeting all of the members of said City Council had due notice and at which all members thereof were present, and that at said meeting said resolution was adopted by the following vote: AYES: NOES: ABSENT: ABSTAIN: I do hereby farther certify that I have carefully compared the same with the original minutes of said meeting on file and of record in my office and that said resolution is a full, true and correct copy of the original resolution adopted at said meeting and entered in said minutes and that said resolution has not been amended, modified or rescinded since the date of its adoption and the same is now in full force and effect. 1 do hereby further certify that an agenda of said meeting was posted at least 72 hours before said meeting at a location in the City of Petaluma, California freely accessible to members of the public, and a brief general description of said resolution appeared on said agenda. WITNESS my hand as of the day and year first above written. M1 City Clerk of the City of Petaluma, California Taxable nOCSSF1:795397.1 Cl -1 EXHIBIT C2 SELLER CERTIFICATE SELLER CERTIFICATE Dated: March 2, 2005 We, the undersigned officers of the City of Petaluma (the "Seller"), State of California, holding the respective offices herein below set opposite our signatures, do hereby certify that on the date hereof the following documents (the "Transaction Documents") were officially executed and delivered by the Authorized Officer or Officers whose names appear on the executed copies thereof, to wit: Document I. Purchase and Sale Agreement, dated March 2, 2005 (the "Sale Agreement"), between the Seller and the California Statewide Communities Development Authority (the "Purchaser") 2. Irrevocable Instructions For Disbursement of Seller's VLF Receivable to the Controller of the State of California dated the CIosing Date Capitalized terms used herein and not defined herein shall have the meaning given such teens in the Sale Agreement. We further certify as follows: At the time of signing the Transaction Documents and the other documents and opinions related thereto, we held said offices, respectively, and we now hold the same. 2. The representations and warranties contained in the Transaction Documents are true and correct as of the date hereof in all material respects. The City Council duly adopted its resolution (the "Resolution") approving the sale of the Seller's VLF Receivable at a meeting of the City Council which was duly called and held pursuant to law with all public notice required by law and at which a quorum was present and acting when the Resolution was adopted, and such Resolution is in full force and effect and has not been amended, modified, supplemented or rescinded. 4. To the best knowledge of the undersigned, no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, public board or body, is pending or threatened, in any way against the Seller affecting the existence of the Seller or the titles of its City Council members or officers to their respective offices, or seeking to restrain or to enjoin the sale of the Seller's VLF Receivable or to direct the application thereof of the Taxable DOCSSFL795397.1 C2-1 proceeds of the sale thereof, or in any way contesting or affecting the validity or enforceability of the Resolution, the Transaction Documents, the Indenture, the Notes, or any other applicable agreements or any action of the Seller contemplated by any of said documents, or in any way contesting the powers of the Seller or its authority with respect to the Resolution or the Transaction Documents or any other applicable agreement, or any action on the part of the Seller contemplated by any of said documents, or which if determined adversely to the Seller would have a material and adverse effect upon the Seller's ability to sell the Seller's VLF Receivable, nor to our knowledge is there any basis therefor. 5. Insofar as it would materially adversely affect the Seller's ability to enter into, carry out and perform its obligations under any or all of the Transaction Documents, or consummate the transactions contemplated by the same, the Seller is not in breach of or default under any applicable constitutional provision, law or administrative regulation of the State of California or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which it is a party or to which it or any of its property or assets is otherwise subject, and, to the best of our knowledge, no event has occurred and is continuing which with the passage of time or the giving of notice, or both, would constitute a default or an event of default under any such instrument, and the adoption of the Resolution and the execution and delivery by the Seller of the Transaction Documents, and compliance by the Seller with the provisions thereof, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the Seller a breach of or default under any agreement or other instrument to which the Seller is a party or by which it is bound or any existing law, regulation, court order or consent decree to which the Seller is subject. 6. Prior to the sale of the VLF Receivable to the Purchaser, the Seller was the sole owner of the VLF Receivable, and has such right, title and interest as provided in the Act. From and after the conveyance of the VLF Receivable by the Seller to Purchaser on the Closing Date, the Seller shall have no interest in the VLF Receivable. Except as provided in the Sale Agreement, the Seller has not sold, transferred, assigned, set over or otherwise conveyed any right, title or interest of any kind whatsoever in all or any portion of the Seller's VLF Receivable, nor has the Seller created, or to our knowledge permitted the creation of, any Lien thereon. Prior to the sale of the VLF Receivable to the Purchaser, the Seller held title to the VLF Receivable free and clear of any Liens. 7. All approvals, consents, authorizations, elections and orders of or filings or registrations with any governmental authority, board, agency or commission having jurisdiction which would constitute a condition precedent to or the absence of which would materially adversely affect, the sale by the Seller of the Seller's VLF Receivable or the performance by the Seller of its obligations under the Resolution and the Transaction Documents and any other applicable agreements, have been obtained and are in Rill force and effect. Taxable DOCSSFI :795397.1 C2-2 Dated as of the date first above written. Name, Official Title Michael Bierman, City Manager Joseph D. Netter, Interim Finance Director Cinde Rubaloff, Accounting Manager genuine. Signature I HEREBY CERTIFY that the signatures of the officers named above are Dated as of the date first above written. M City Clerk of the City of Petaluma, California Taxable DOCSSFL79539TI C2-3 EXHIBIT C3 BILL OF SALE AND BRINGDOWN CERTIFICATE BILL OF SALE AND BRINGDOWN CERTIFICATE In consideration of the payment and delivery by the California Statewide Communities Development Authority (the "Purchaser") to the undersigned (the "Seller") of $[Final Purchase Price] (the "Final Purchase Price"), and pursuant to terms and conditions of the Purchase and Sale Agreement (the "Sale Agreement'), dated March 2, 2005, between the Seller and the Purchaser, the Seller does hereby (a) transfer, grant, bargain, sell, assign, convey, set over and deliver to the Purchaser, absolutely and not as collateral security, without recourse except as expressly provided in the Sale Agreement, the VLF Receivable as defined in the Sale Agreement (the "VLF Receivable"), and (b) assign to the Purchaser, to the extent permitted by law (as to which no representation is made), all present or future rights, if any, of the Seller to enforce or cause the enforcement of payment of the VLF Receivable pursuant to the Act (as defined in the Sale Agreement) and other applicable law. The Seller hereby acknowledges receipt of the Final Purchase Price. The Seller hereby certifies that the representations and warranties of the Seller set forth in the Certificate of the City Clerk dated March 2, 2005, the Seller Certificate dated March 2, 2005, and in the Transaction Documents (as such terms are defined in the Sale Agreement) are true and correct in all material respects as of the date hereof (except for such representations and warranties made as of a specified date, which are true and correct as of such date), Dated: [Closing Date]_ CITY OF PETALUMA E Taxable nOCSSFI:795397.1 C3-1 Authorized Officer EXHIBIT D IRREVOCABLE INSTRUCTIONS TO CONTROLLER IRREVOCABLE INSTRUCTIONS FOR DISBURSEMENT OF VLF RECEIVABLE OF CITY OF PETALUMA ,2005 Office of the Controller State of California P.O. Box 942850 Sacramento, California 94250-5872 Re: Notice of Sale of VLF Receivable by the City of Petaluma and Wirine Instructions Information Form Dear Sir or Madam: Pursuant to Section 6588.5(c) of the California Government Code, City of Petaluma (the "Seller") hereby notifies you of the sale by the Seller, effective as of the date of these instructions written above, of all right, title and interest of the Seller in and to the "VLF Receivable" as defined in Section 6585(1) of the California Government Code (the "VLF Receivable"), namely, the right to payment of moneys due or to become due to the Seller out of funds payable in connection with vehicle license fees to a local agency pursuant to Section 10754.11 of the California Revenue and Taxation Code. By resolution, the Seller's City Council authorized the sale of the VLF Receivable to the California Statewide Communities Development Authority (the "Purchaser") pursuant to a Purchase and Sale Agreement, dated March 2, 2005 and a Bill of Sale, dated [Closing Date]. The VLF Receivable has been pledged and assigned by the Purchaser pursuant to an Indenture, dated March 2, 2005 (the "Indenture") between the Purchaser and Wells Fargo Bank, National Association, as Trustee (the "Trustee"). The Seller hereby irrevocably requests and directs that, commencing as of the date of these instructions written above, all payments of the VLF Receivable (and documentation related thereto) be made directly to Wells Fargo Bank, National Association, as Trustee, in accordance with the wire instructions and bank routing information set forth below. Please note that the sale of the VLF Receivable by the Seller is irrevocable and that (i) the Seller has no power to revoke or amend these instructions at any time, (ii) the Purchaser shall have the power to revoke or amend these instructions only if there are no notes of the Purchaser outstanding under the Indenture and the Indenture has been discharged, and (iii) so long as the Indenture has not been discharged, these instructions cannot be revoked or amended by the Purchaser without the consent of the Trustee. Taxable OOCSSF1:795397.1 D -I Bank Name: Bank ABA Routing #: Bank Account #: Bank Account Name: Further Credit To: Bank Address: Bank Telephone #: Bank Contact Person: Wells Fargo N.A. 121000248 0001038377 Corporate Trust Clearing CSCDA VLF #16914200 Wells Fargo Bank 707 Wilshire Blvd., 17 Floor Los Angeles, CA 90017 (213)614-3353 Robert Schneider Please do not hesitate to call the undersigned if you have any questions regarding this transaction. Thank you for your assistance in this matter. Very truly yours, CITY OF PETALUMA M Authorized Officer Taxable DOCSSFI :795397.1 D-2 EXHIBIT E RESERVED Taxable DOCSSF1:795397.1 E-1 EXHIBIT F ESCROW INSTRUCTION LETTER PARTICIPATION AGREEMENT AND ESCROW INSTRUCTION LETTER March 2, 2005 California Statewide Communities Development Authority 1100 K Street Sacramento, CA 95814 Re: VLF Receivable Financine Dear Sir or Madam: The City of Petaluma (the "Seller") hereby notifies you of its agreement to participate in the California Statewide Communities Development Authority VLF Receivable Financing. By adoption of a resolution (the "Resolution") authorizing the sale of its VLF Receivable, the Seller's City Council has agreed to sell to the California Statewide Communities Development Authority, for a purchase price that meets the conditions set forth in the Resolution, all of its right, title and interest in the VLF Receivable. Enclosed herewith are the following documents which have been duly approved and executed by the Seller and which are to be held in escrow by Orrick, Herrington & Sutcliffe LLP, as transaction counsel ("Transaction Counsel"), as instructed below: 1. certified copy of the Resolution, together with a certificate of the City Clerk, dated March 2, 2005; 2. the Seller Certificate, dated March 2, 2005; 3. the Opinion of Seller's Counsel, dated March 2, 2005; 4. the Purchase and Sale Agreement, dated March 2, 2005; and 5. the Irrevocable Instructions to the Controller, undated. The foregoing documents are to be held in escrow by Transaction Counsel and shall be delivered only upon payment to the Seller on or before April 29, 2005, of the Final Purchase Price (as defined in the Purchase and Sale Agreement) that meets the conditions of the Resolution. Upon such payment, Transaction Counsel is hereby authorized to fill in the closing date on the Irrevocable Instructions to the Controller. Taxable F-1 DOCSSF7:795397.I If the Final Purchase Price meeting the conditions of the Resolution is not paid to the Seller on or before April 29, 2005, this agreement shall terminate and Transaction Counsel shall return all of the enclosed documents to the Seller. Very truly yours, CITY OF PETALUMA 10 Authorized Officer Enclosures cc: Orrick, Herrington & Sutcliffe LLP Taxable F-2 DOCSSFI :795397.1 Netter, Joe From: Gomez, Michael T (MSDj (michael.t.gomez@citigroup.comj Sent: Monday, January 24, 2005 9:49 AM To: Netter, Joe Subject: VLF Financing - Minimum Net Proceeds Petaluma_taxable-Petaluma _ taxable_ current_i-21.... current+100-1... Joe - [dice to speak with you this morning. Attached please find two files which I hope will help you decide the minimum acceptable sale price for your VLF receivable. This is a number that Orrick will insert in the Sale Resolution to be adopted by your City Council. The first file estimates net proceeds using current interest rates. The second file shows the effect of a 100 by increase in interest rates. The full detail of the components of the discount (interest, credit enhancement costs, other program fees) can be found on the second pace of each file. If you give me the number you want to put in before 1pm, documents in final, adoptable form will arrive from Orrick the next day by FED EX. If you tell me after 1pm, we promise the documents for delivery the second morning after. Please call if you have any questions, and to let me know what you decide. Best, Michael Michael T. Gor az Director Citigroup Global Markets Inc. One Sansome Street, 28th Floor San Francisco, California 94104 Tel: (415) 951-1615 Fax: (415) 951-1748 E-mail: michael.t.gomez@citigroup.com 1 Program Size- $200,000,000 Local Agency PETALUMA VLF Amount $951,083.48 Taxable Boirotning Coupon Rate 3.75% Yield - 3.75% - CAPI Earnings Rate 2.50% Using this set of assumptions, PETALUMA would receive Proceeds in the amount of (1): Proceeds as a % of VLF Gap Loan Amount (1): Possible, Additional Proceeds/Reinvestment $871,653.47 91.65% There, are -two -ways in which Local Agencies may be able to takeadvantageof, reinvestment opportunities to increase the percentage ofttteir VLF Gap Loan amount they -will ultimately receive. First, for those who participate in the taxable program (2) and do not spendm , the sale proceeds immediately; Investment_ earnings may increase the net proceeds which the Local Agency can count on'in future periods. An estimate of the total ,net proceeds — original sale proceeds plus interest earnings — which would be available to your Local Agency on August 15;, 2006.(the date the State has promised torepaythe VLF Gap Loan), November 15; 2006 (the maturity date of the VLF Notes) and'August 15, 2007 (the one-year anniversary of the State's promised repayment date), if all of the original sale proceeds were reinvested for the time period.at the rates indicated, is listed in Table 1, below. - - - - Second; if the State actually repays the VLF Gap Loan on August 15,'2006, all Local Agencies -who participate inthe program — whether 'on a taxable; or tax-exempt basis - will receive additional funds. This is. because CSCDA will capitalize all required interest expepse on the Notes through the final maturity date --November 15, 2006. Tf. the State pays CSCDA on August 15, 2006, CSCDA will' invest the amount of the State's, repayment until November 15, 2006, when it will be,used to iedre the Notes. lateresi earnings generated, durin&that.period will be "excess" to the. debt service requirements on the Notes, ,:CSCDA intends to return.that "excess" to Local Agency participants. An estimate of the totals net proceeds —original sale proceeds -plus interest earnings — which the Program would be able to pay to your Local Agency by November 15, 2006--assuming.the State repays the Crap Loan amount onA11Ru5t 15, 2006'- is listed in Table 2, below. - °- -- - From_ 16 Mac -OS to Assumed Rate' -Earnings % of VLF Gap; LoanilmountRecetved iaNet Proceeds and Eamings by 15 -Nov -06 - �.-.. 15 -Aug -06 .3.12% .''- $38,451.54 95.69%. 15 -Nov -06.- 3.19% - $46,265.67 1 96.51"/0, 1'5-Aug707 3.33% 1 $70,065.69 99.02% - Table 2: Tn7tial Sale Proceeds as % "Excess" Earnings Assuming State Repays I % of VLF Gap Loan AmountReceived in Net of VLF Amount VLF Gap Loan on 15 -Aug -06 - Proceeds and Earnings by 15 -Nov -06 I1 91 65% 0.57% I - 9 21% 1 (I) PRELIAlINARY- Subject to Change;This analysis is preliminary and is subject to market conditions and actual costs of issuance and credit enhancement at pricing. This analt+sis provides an estimate of the net proceeds available as of the date of analysis but it, no way guarantees the final amount available upon delivery. (2) Participants in the tar -exempt program nun, be able to retabt some interest earnings on proceeds mvaiting expenditure, but these will depend on the individual circumstances ofeach participant and are not easy to estimate. (3) Applies only to tavable borrowing scenario. Uses as % of Gap Loan Amount Deposit to Capitalized Interest Fund CIT IF s 6.08% Bond Insurance Premium VLF GAP LOAN FINANCING PROGRAM 0.69% CSCDA Bonds used to purchase Petaluma VLF Receivable Analysis assuming Taxable Borrowing Net Proceeds Sources and Uses of Funds 91.65% Sources -- Par Amount of Bonds $951,083.48 Premium[ Original Issue Discount $0.00 Total $951,083.48 53,233.68 CSCDA Fees Deposit to Capitalized Interest Fund 557.79271 Bond Insurance Premium 0,650'. 56,567.78 Other Program Costs 515,064.52 Net Proceeds $871,653.47 Total $951,083.48 Uses as % of Gap Loan Amount Deposit to Capitalized Interest Fund 6.08% Bond Insurance Premium 0.69% Other Program Casts Net Proceeds 91.65% Total 100.00°5 Other Progrant Cosh ". ' ' - ' Fee Basis ' = : -' ` " - -" PETALUMA Share(I) " Underwriters' Discount 53.40/51000 53,233.68 CSCDA Fees $0.5/51000 $47554 Disclosure/Undenvriters' Counsel 580,000 5380.43 Rating Agency Fees $130,000 5618.20 Bond Counsel Flat Fee: 'S100.000 52,500 50.00 $101,000-5399,000 $5,000 $0.00 >$400,000 10,000 00 $10,00000 Bond Counsel Additional Fee Tax Exempt (Capital Projects) 510,000/borrower $0.00 Tax Exempt (Working Capital) 520,000/borrower 5000 Administrative Costs (2) 575,000 535666 Total Other Program Costs $15,064.52 (1) rlasesnes a program sce of S200.00000 00 (2) Include., troveeJec , pnnnngJce.,, program development and marketing erpen,c., and mevicelluncow ora -of -pocket espenaev * PRELIMINARY- Subject to Change. 2 Program Size Local Agency VLF Amount Taxable Borrowing Coupon Rate Yield CAP] Earnings Rate $200,000,000 PETALUMA . $951,083.48 4.75% 4.75%; 2.50% Using this set of assumptions, PETALUMA would receive Proceeds in the amount of (1): Proceeds as a % of VLF Gap Loan Amount (1): ,.� ltA+,I:i 5856,137.88 90.02% J Possible Additional Proceeds/Reinvestment There are two ways in, which Local Agencies may -be able to take advantage of reinvestment opportunities to. increase the percentage of their VLF Gap Loan amount they will ultimately receive. First;" for those tivho participate in the taxable program (2) and -do not spend the ;sale proceeds immediately, investment earnings may increase the net proceeds "which the.LocalAgency can count on in future periods. Art estimate of the total net proceeds - original sale proceeds plus interest earnings - which would-be available to your Local Agency on August 15; 2006 (thedatethe State hos ,promised to repay the VLF Gap Loan), November 15, 2006 (the maturity date of the-VLF.Notes) and AuIgust,15, 2007 (the one-year anniversary of the State's promised repayment date), if all of the;original sale proceeds_ were reinvested _for the time period at the 'rates indicated, is listed in Table l; below. - - - - Second, if the State actually repays the, VLF Gap Loan on August 15,_2006, all Local Agencies who participate in the program - Whether on, a taxable or tax-exempt basis - will receive additional -funds. This is because CSCDA will capitalize all required interest expense on the Notes through the final maturity date -November 15, 2006, If the State pays CSCDA on _August 15, 2006, CSCDA will invest the amount of the State's repayment until November?15, 2006,"when it will be- used,to'retire the Notes. Interest earnings generated during that. period will be,"excess to the, debt service requirements an the Notes: CSCDA, intends to retum that "excess" to Local Agency participants.:I An estimate, of. the total net proceeds— original sale proceeds plus interest earnings- which the Program would be able to pay to your Local Agency by November 15, 2006- assuming the State repays the Gal) Loan amount on August 15,'2006 - is listed in Table'-), below. - - From`' 16MarOS;to. Assumed Eammgs.";', - %ofVLFGripLoanArnountRe7. ceivedinNet Proceeds and Earnings by 15 -Nov -06 15=Au -06 3.12%-$37,767:10 93;99/ 15-Nov-06' .'' 3.19% ... $45,442.13 �. - 94.80% I:" 15 -Aug -07 - 3.33% $68;818.50 97.25%' Table 2: Initial Sale Proceeds as % ' "Excess" Earnings Assuming State Repays _% of VLF Gap Loan Amount Received in Net of VLF Amount VLF Gap Loan "on 15 -Aug -06 ; : Proceeds and Earnings by 15-Nov46 J 90.02%: 0.57% -: 90:58% (1) PRELIMINARY- Subject to Change;This analysis is preliminary and is subject to market conditions and actual costs of issuance and credit enhancement at pricing. This analysis provides an estimate of the net proceeds available as of the date of analysis bat in no mm+guarantees thefinal amount mailable upon delivery. (2) Participants in the tax-exempt program may be able to retain some interest earnings on proceeds awaiting expenditure, but these will depend on the individual circumstances of each participant and are not easy to estimate. (3) Applies only to taxable borrowing scenario. VLF GAP LOAN FINANCING PROGRAM CSCDA Bonds used to purchase Petaluma VLF Receivable Analysis assuming Taxable Borrowing Sources and Uses of Funds* Sources Par Amount of Bonds Premium / Original Issue Discount Total Uses: Deposit to Capitalized Interest Fund Bond Insurance Premium 0.550% Other Program Costs Net Proceeds Total ftes. as'06vf Gap Loan Amount CIi IF. �i 5951,083.48 $0.00 S951,083.48 $73,210.44 $6,67064 $15,064.52 $856,137.88 5951,083.48 Deposit to Capitalized Interest Fund 7.7045 Bond Insurance Premium 0.70 Other Program Costs 1.5890 Net Proceeds 9002% Tutu] 100 0045 OdierProgranr Cases* - Fee Basis - PETAL VM Sh tre(l) Underwriters' Discount 53.40/$1000 $3,23368 CSCDA Fees $0.5/$1000 $475.54 Disclosure/Undenvnters Counsel $80,000 $380.43 Rating Agency Fees $130,000 $618.20 Bond Counsel Flat Fee: <S 100,000 $2,500 $0.00 $101,000-$399,000 $5,000 $000 >s400,000 10,000.00 $10,00000 Bond Counsel Additional Fee Tax Exempt (Capital Projects) $10,000/borrower 50.00 Tax Exempt (Working Camml) S20,000/bomower $0.00 Administrative Costs (2) $75,000 $356.66 Total Other Program Costs $15,064.52 (1) Aseumea aprogram .wr-c of $200,000,000.00 (1) Include., rncwree Jeer, printingfeer, program development and marketing erpemree and meccellanemrs out-n(-pockel espenim PRELIMINARY- Subject to Change. 2 California Communities I VLF Program CALIFORNIA COMMUNITIES VLF Gap Loan Financing Program (VLF Program) Page 1 of 7 Anticipated Schedule summary November 2004 - Regional California Communities plans to issue bonds to purchase Vehicle informational workshops & conference License Fee Gap Loan (VLF) receivables from cities and counties calls ("Local Agencies"). Local Agencies can elect to sell their VLF End of November 2004 - Local receivables to California Communities for an upfront fixed price Agencies complete online preliminary between 90-96%** of the VLF receivables' value. participation form End of January 2005 - Approval by Jump to: ■The VLF Gap-Locn_ Financino Prooram Presentation Local Agency governing bodies (Pdf) February 2005 - Bonds are issued and ■ Fill Out Online Preliminary Participation Form Local Agencies receive their money ■ What is my VLF Gap Loan Amount? ■ How Much Will Your Agent Receive? ■ What is the Issuance Process? ■ Contact Us Proqram Benefits to Local Aqencies • Provides Immediate Cash Relief • Levels Out Cash Flow from the State Over the Next Two Years • Mitigates Impact of Property Tax In -Lieu of VLF Swap Over Next Two Years • Creates Financial Flexibility for Budgets This Year and Next • Financing for Ongoing or Extraordinary Capital Needs on Tax -Exempt Basis • Financing to Make Debt Payments or Repay Existing Debt https:Hsecure.cacommunities.com/eacomm/apps/vlf/ 11/23/2004 California Communities I VLF Program Overview In FY 2003-2004, the State failed to make 3 months of VLF backfill payments (totaling about $1.3 billion) to cities and counties resulting in a VLF funding gap ("VLF gap loan"). The State has agreed to make these VLF gap loan payments to cities and counties by August 15, 2006. To find out the amount of the VLF gap loan payment owed to your Local Agency, please use the VLF Gap Loan Amount lookup. Page 2 of 7 VLF Gap Loan Amount Type In your city or county to determine the VLF gap loan due to your agency from the State by August 15, 2006. City or County: jPetaluma VLF Gap Loan Amount: $951,083.48 (Due by August 15, 2006) Authorized under SB 1096, the California Communities VLF Gap Loan Financing Program ("VLF Program") enables Local Agencies to sell their VLF receivable to California Communities for an upfront fixed price between 90-96%** of their receivable. California Communities is planning to issue bonds and use the proceeds to purchase the VLF receivables and pay financing costs ("VLF Bonds"). California Communities will pledge the VLF receivables to secure payment on the VLF Bonds. A Local Agency's sale of its VLF receivable is irrevocable and investors will have no recourse to the Local Agency if the State does not repay the VLF gap loan. After paying financing costs, Local Agencies will receive their share of the proceeds. The VLF Bonds will be issued as fixed rate bonds on either a taxable or tax-exempt basis depending on the use of the bond sale proceeds by participants. Prooram Benefits The VLF Program provides Local Agencies many benefits: • Provides Immediate Cash Relief - Selling your VLF receivable will provide your agency approximately 90-96%*` of your future VLF gap loan payment today which can be used to pay for immediate funding needs. • Levels Out Cash Flow From State Over Next Few Years - In this fiscal year and next, cities and counties will lose $700 million annually in ERAF payments to the State. Thereafter, the obligation to make Lc,Ct1A V,LV GaE Laan Financing Bridge the Gap htti)s://secure.eacommunities.com/cacomm/apps/vlf/ 11/23/2004 California Communities I VLF Program Page 3 of 7 ERAF payments will end - just at the very same time cities and counties receive their VLF gap loan payments in FY 2006-07. The chart on the left below represents the cash flow a Local Agency can expect from the State if no action is taken. In contrast, a Local Agency can "level out" its receipts and payments from the State over the next few years by participating in the VLF Program. Namely, a Local Agency could use the proceeds from the sale of its VLF receivables today to offset its ERAF contributions over the next two years. The chart on the right below conceptually represents how cash from the State would be "leveled out" utilizing this approach. "Cash From the State if No Action Taken" "Cash From the State After Selling VLF Gap Receivable" 2004-05 2005-08 2008-07 Mitigates Impact of Property Tax In -Lieu of VLF Swap Over Next Two Years - Beginning in FY 2004- 05, the State has permanently eliminated the VLF backfill paid to Local Agencies and replaced it with an equal amount of property tax. While the dollar impacts of these actions are intended to cancel each other out, Local Agencies are now receiving these payments semi-annually as property taxes, rather than monthly as VLF backfill payments. This situation may create cash flow problems for some Local Agencies which could be solved temporarily by utilizing the VLF Program. Creates Financial Flexibility for Budgets This Year and Next - Many Local Agencies have made difficult decisions for their budgets this year. By participating in the VLF Program, Local Agencies can apply their proceeds to solve their budget challenges in this and the next fiscal years' budgets. Financing for Ongoing or Extraordinary Capital Needs on Tax -Exempt Basis - A Local Agency may elect to have its VLF receivable purchased on a tax-exempt basis to lower the interest costs on the VLF Bonds (i.e. enabling California Communities to pay a higher price for that participant's VLF receivable). htt.ns:Hsecure.cacommunities.com/cacomm/ands/vlf/ 11/23/2004 California Communities I VLF Program Page 4 of 7 A participant may qualify for this tax-exempt option by demonstrating that the sale proceeds will be spent on tax-exempt uses such as: • Capital Improvement Costs (Hard & Soft Costs) • Court -Mandated Judgment Obligations • Working Capital To qualify for the tax-exempt option, a Local Agency will need to provide additional information and work with Bond Counsel to complete the required tax analysis. In the case of reimbursing capital costs, a Local Agency must adopt a reimbursement resolution prior to paying any of these costs. In the case of financing working capital, a Local Agency must provide evidence that it expects to run a cash flow deficit during the life of the VLF bonds. If a Local Agency chooses to finance on a tax-exempt basis, its share of total issuance costs will reflect the additional legal work involved. As a result, this option is likely to make economic sense only for those Local Agencies with a large VLF gap loan. Financing to Make Debt Payments or Repay Existing Debt — Enables a Local Agency to make debt payments or refund existing debt, as long as the refunded debt was used for tax-exempt purposes and is not prohibited from being refunded under federal tax law. A Local Agency will need to provide Bond Counsel information on the prior debt issue. How Much Will Your Aaencv Receive? Upon delivery of the bonds, California Communities will make available to each Local Agency a fixed dollar payment. The payment will be equal to an Agency's VLF gap loan amount less capitalized interest costs, credit enhancement fees and bond issuance costs. For an Agency selling a $1 million receivable on a Taxable basis, the payment from California Communities (based on interest rates as of November 3, 2004) is estimated to be approximately 92%' of the gap loan amount. Interest Costs — By selling its gap loan receivable, an Agency will receive its payment earlier than if it waits until the State pays in 2006. It can receive its money early because California Communities borrows the purchase price from investors who must be paid interest. Therefore, about 70%` of the reduction in an Agency's payment below its gap loan amount is the interest it pays to receive its money early. California Communities will retain a portion of bond proceeds to pay interest to investors until 2006. This funding of interest from the bonds (known as capitalized interest) reduces the amount payable to an Agency. Credit Enhancement Fees — To broaden the appeal of the bonds to investors and secure the lowest possible interest rate, California Communities expects to purchase credit enhancement from a highly rated financial institution that will guarantee the repayment of bond principal in 2006. Using credit enhancement increases the net 11/23/2004 California Communities I VLF Program proceeds received by Local Agencies. Page 5 of 7 Bond Issuance Costs — These include the fees and expenses of such participants as legal counsel, the underwriters, the rating agencies and California Communities. A Local Agency's share of the total fees will depend upon the size of its gap loan and whether it finances on a taxable or tax-exempt basis. For a hypothetical $1 million taxable sale, issuance costs are estimated to reduce the payment by about 1.4%*. On a percentage basis, a Local Agency's share of issuance costs will be larger if its loan amount is less, and smaller if its loan amount is more. In addition, Local Agencies that sell their gap loan receivables on a tax-exempt basis will pay larger issuance costs. The chart below shows the breakdown of sale proceeds and financing costs based on the taxable sale of a $1 million VLF gap loan. 100% - 90% - 80% - 70% - 60% - 50%_ 40% 0%- 40% - 30% - 20% - 10% - 0% Issuance Process VLF Crap Loan Financing Cost 13realcdown* I - ( $14,000-BmullssmweCosts jVZ- ` ' _= =.i'PTl $9,000- Cmdlt Enhamement $55,000 - Capitahmd lntamst id to Agency* Eslinated salepmceeds and f=winb coslx 1. Complete the on-line VLF Preliminary Particioation Form. Filling out this form does not commit a Local Agency to participate in the program. 2. CSCDA Program Manager and financing team members will assist the Local Agency in understanding the benefits and requirements of the VLF Program. Review California Communities' General_ Policies and Issuance California Communities I VLF Program Page 6 of 7 Policies. 3. CSCDA Program Manager and financing team members will assist the Local Agency in determining whether it can participate in on a tax-exempt or taxable basis. If the tax-exempt option is pursued, the Local Agency will be required to provide Bond Counsel the proper paperwork and evidence to complete the tax-exempt analysis. 4. Governing body of Local Agency approves and executes a sales agreement between itself and California Communities subject to meeting minimum threshold net proceeds levels. If the tax-exempt option is pursued, additional legal documents will be required. 5. Bonds are issued. 6. Issuance fee collected. Contact Us Please contact Program Manager James Hamill at (925) 933-9229 ext. 216, if you have any questions. The following financing team members are also available to answer you questions. Financing Team Contacts Underwriter Co -Senior Manager Citigroup Global Markets Inc. Michael Gomez (SF) (415) 951-1615 michael.t.aomez@)citiaroup,com Kimberly Quinones (LA) (213) 486-7175 kimberly.quinones Citi roup_com Jamison Feheley (SF) (415) 951-1699 is mison.fehelev(o) citia rouo.com Tony Hughes (SF) (415)951-1690 Co -Senior Manager E. J. De La Rosa & Co., Inc. Paul Rosenstiel (SF) (415) 495-8863 prosenstiel(@eidelarosa.com John Kim (SF) (415)495-8863 jkim(a)eidelarosa.com Raul Amezcua (LA) (310) 207-1975 ramezcuaCa)eidela rosa.com California Communities I VLF Program tonv.huahes(alcitiarouo.com Bond Counsel Orrick, Herrington & Sutcliffe LLP John H. Knox (415) 773-5626 iknox(a)orrick.com Disclosure Counsel Sidley, Austin, Brown & Wood LLP Mary Neale (213) 896-6083 mneale(a)sidlev.com Underwriters' Counsel O Melveny & Myers LLP Rick Jones (213) 430-6695 riones(d)omm.com Sponsors League of California Cities Daniel B. Harrison (916) 658-8267 dharrisonecacities.ora *'Preliminary, subject to change. Printer -friendly version California State Association of Counties Norma Lammers (916) 327-7500 ext.554 nlammersacounties.ora California Communities 1 2175 North California Blvd., Suite 559, Walnut Creek, CA 94596 1 (888) 635-3993 1 info@cacommunities.com Page 7 of 7 htins://secure.cacommunities.com/cacomm/apps/vlf/ 11/23/2004