Loading...
HomeMy WebLinkAboutPart 3 Obligations, less any amount held by the Paying Agent for the payment of such Insured Amounts and legally available therefor. This policy does not insure against loss of any prepayment premium which may at any time be payable w'(h respect to any Obligation. As used herein, the term "owner" n the registered owner of any Obligation as indicated in the books maintai by e Paying Agent, the Issuer, or any designee of the Issuer for such purpose. 'cm owner shall not include the Issuer or any party whose agreement with the Issuer colt3tutes the underlying security for the Obligations. Any service of process on the Insurer may be made to the Insurer at its offices located at 113 King Street, Armonk, New York 10504. This policy is non-cancelable for any reason. The premium on this policy is not refundable for any reason including the payment prior to maturity of the Obligations. In the event the Insurer were to become insolvent, any claims arising under a policy of financial guaranty insurance are excluded from coverage by the California Insurance Guaranty Association, established pursuant to Article 14.2 (commencing with Section 1063) of Chapter 1 of Part 2 of Division 1 of the California Insurance Code. MUNICIPAL BOND INVESTORS ASSURANCE CORPORATION 10 NUMBER R-ARS-1 $10,600,000 Unless this certificate is presented by an authorized representative of The Depository Trust Company, a New York corporation ("DTC"), to the Authority or its agent for registration of transfer, exchange, or payment, and any certificate issued is registered in the name of Cede & Co. or in such other name as is requested by an authorized representative of DTC (and any payment is made to Cede & Co. or to such other entity as is requested by an authorized representative of DTC), ANY TRANSFER, PLEDGE, OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL inasmuch as the registered owner hereof, Cede & Co., has an interest herein. THIS BOND MAY NOT BE SPLIT UP, TRANSFERRED OR EXCHANGED EXCEPT AS PROVIDED IN THE INDENTURE REFERRED TO HEREIN SANTA ANA FINANCING AUTHORITY POLICE ADMINISTRATION AND HOLDING FACILITY LEASE REVENUE BONDS, SERIES 1994A (AUCTION RATE SECURITY) INTEREST RATE MATURITY DATE DATED DATE CUSIP Cosi.b:ER Variable July 1, 2014 March 23, 1994 8C "'AA7 akt REGISTERED OWNER: CEDE & CO. PRINCIPAL SUM: TEN MILLION SIX HUNDRED THOUSAND DOLLARS FOR VALUE RECEIVED, the Santa Ana Financing Authority (the "Authority"), a joint powers authority, duly created and existing under the laws of the State of California (the "State"), hereby promises to pay (but only from revenues hereinafter referred to) to the registered owner named above or registered assigns, the principal amount specified above on the maturity date specified above, and to pay to the registered owner named above or registered assigns, solely from said sources, interest on said principal amount from January 1, 1995 or from the most recent Interest Payment Date(as hereafter defined)to which interest has been paid or duly provided for, until the principal hereof is paid or duly provided for, at the rate and on the dates determined as provided herein. The principal of and premium, if any, on this Bond shall be payable at the principal corporate trust office of Meridian Trust Company of California, as trustee under the Indenture hereinafter referred to (together with each successor trustee under the Indenture, the "Trustee"), or if a successor trustee is hereafter appointed, then at the principal corporate trust office of such successor, or at the principal corporate trust office of any other paying agent appointed under the Indenture, upon surrender of this Bond at such principal corporate trust office. Interest on this Bond (other than Defaulted Interest, as hereafter defined) shall be payable by check or draft drawn upon the Trustee or upon. any other paying agent LA1-70382.1 appointed under the Indenture, mailed to the person in whose name this Bond is registered in the registration books maintained by the Trustee (the "Bond Register") at the close of business on the Record Date (as hereafter defined) next preceding the relevant Interest Payment Date at such person's address as it appears in the Bond Register on such Record Date; provided that any holder of Bonds of this series in an aggregate principal amount equal to or greater than $1,000,000 may elect to be paid the interest on such Bonds by Federal Reserve wire transfer in immediately available funds to any bank in the United Stat; of America specified by such holder by written direction given to the Trustee not less too . c days prior to the first Interest Payment Date for which such notice shall become effe,- ;. The term "Record Date" shall mean with respect to any Interest Payment Date, th• : ,1 ess Day next preceding such Interest Payment Date. Any interest on this Bond whic 4 i c punctually paid when due ("Defaulted Interest") shall be payable to the holder in yip = ame this Bond is registered in the Bond Register at the close of business on a special r rd date selected by the Trustee which shall be at least ten but not more than 30 days prior to the date selected by the Trustee for payment of such Defaulted Interest. The Trustee shall give notice to the bondholders of the special record date and the date for payment of Defaulted Interest at least ten days prior to such special record date. The principal of, premium, if any, and interest on this Bond shall be payable in any currency of the United States of America which on the respective dates of payment thereof is legal tender for the payment of public and private debts. The term "Business Day" shall mean any day other than a Saturday, Sunday or other day upon which banking institutions located in the state in which the principal corporate trust office of the Trustee or the principal office of the Auction Agent (as defined in the Indenture) is located are closed or are required to close or on which the New York Stock Exchange is closed. If the date for any payment of the principal of, premium, if any, or interest on this Bond or the last date for performance of any act or the exercising of any right, as provided in this Bond or in the Indenture, is not a Business Day, such payment may be made or act performed or right exercised on the next succeeding Business Day with the same force and effect as if made, performed or exercised on such nominal date. This Bond is one of a duly authorized issue of bonds of the Authority designated as its "Santa Ana Financing Authority Police Facility Lease Revenue Bonds, Series 1994A" (the "Bonds"), in the aggregate principal amount of One Hundred Seven Million Three Hundred Ninety-Nine Thousand Four Hundred Thirty-Eight Dollars and Fifty Cents ($107,399,438.50), of which $84,730,000 aggregate principal amount shall be issued as Current Interest Bonds, $1,469,438.50 aggregate principal amount shall be issued as Capital Appreciation Bonds, $10,600,000 aggregate principal amount shall be issued as Auction Rate Securities ("ARS") and $10,600,000 aggregate principal amount shall be issued as Inverse Rate Securities ("IRS"), all of like tenor and date (except for such variations, if any, as may be required to designate varying numbers, maturities and interest rates), and is issued under and pursuant to the provisions of an indenture, dated as of March 1, 1994 (the "Indenture"), between the Authority and the Trustee (copies of which are on file at the office of the Secretary of the Authority and at the Corporate Trust Office of the Trustee). The Bonds are issuable only as fully registered bonds without coupons, in the denomination of$50,000 and integral multiples thereof. LAi-70382.1 2 The Bonds are issued to provide funds to finance the cost of acquiring, constructing and installing certain public capital improvements (the "Project") in the City of Santa Ana (the "City"). The Bonds are limited obligations of the Authority and are payable, as to interest thereon and principal thereof, solely from the revenues derived from base rental payments paid by the City pursuant to a lease, dated as of March 1, 1994 (the_ ')base"), between the Authority, as lessor, and the City, as lessee, for the use and possessi e Leased Property (as defined in the Lease) as long as the City has such use and pi of the Leased Property, which includes the Project, as well as from all other b• it charges, income, proceeds, profits, receipts, rents and revenues derived by the Aut *1 A s assignee of the Agency's rights under the Lease, from operation or use of the Lease: .I +perty (the "Revenues"). All the Bonds are equally and ratably secured in accordance with e terms and conditions of the Indenture by a pledge of the Revenues, which Revenues shall be held in trust for the security and payment of the interest on, principal of and redemption premiums, if any, on the Bonds as provided in the Indenture. The Bonds shall be limited obligations of the Authority and shall be payable solely from the Revenues and amounts on deposit in the funds and accounts established under the Indenture (other than amounts on deposit in the Rebate Fund). The Bonds do not constitute a debt or liability of the City, the State of California, or any of its political subdivisions, and neither the faith and credit of the City, the State of California, nor any of its political subdivisions are pledged to the payment of the principal of or interest on the Bonds. Reference is hereby made to the Indenture and any and all amendments thereof and supplements thereto for a description of the terms under which the Bonds are issued, the provisions with regard to the nature and extent of the Revenues, and the rights of the registered owners of the Bonds. All of the terms of the Indenture are hereby incorporated herein and constitute a contract between the Authority and the registered owner of this Bond, to all the provisions of which the registered owner of this Bond, by acceptance hereof, agrees and consents. Each registered owner hereof shall have recourse to all of the provisions of the Indenture and shall be bound by all of the terms and conditions thereof. The Authority has agreed and covenanted that, for the payment of the interest on, the principal of and redemption premium, if any, on this Bond and all other Bonds of this issue authorized by the Indenture when due, there has been created and will be maintained by the Trustee a special fund into which all Revenues (other than deposits to the Rebate Fund created by the Indenture) shall be deposited, and the Authority has allocated such Revenues solely to the payment of the interest on and principal of and redemption premiums, if any, on the Bonds, and the Authority will pay promptly when due the interest on and the principal of and redemption premium, if any, on this Bonds and all other Bonds of this issue authorized by the Indenture out of said special fund, all in accordance with the terms and provisions set forth in the Indenture. Interest Rate Provisions Interest on the ARS and IRS shall accrue for each Interest Period and shall be payable in arrears on each succeeding Interest Payment Date by the Trustee to the persons who are the registered owners of the ARS as of the Record Date. An "Interest Period" begins on and includes an Interest Payment Date and ends on but excludes the next succeeding Interest Payment LAI-70382.1 3 Date; however, the first Interest Period commences on the date of original delivery of the ARS. An "Interest Payment Date" for the ARS means January 1, 1995, semi-annually thereafter on each January 1 and July 1 and at maturity. If any such day is not a Business Day, interest due on such day shall be paid on the next succeeding Business Day without accrual of any additional interest. Interest on the ARS shall be computed on the ba 's f a 360-day year for the actual number of days elapsed. The interest rate on this Bond e 3.08% per annum for the initial Auction Period and the interest rate (the "Applicab te") for each subsequent Auction Period shall equal the sum of (A) the rate i rest (the "Auction Rate") determined periodically on the basis of orders placed Auction conducted on the Business Day immediately preceding the Interest Period a ) the Service Charge Rate (as described in the Indenture) in effect, and in such other manner as described in the Indenture. The procedures for conducting an Auction and determining the Auction Rate are set forth in the Auction Agent Agreement, dated as of March 1, 1994, Trustee and the Auction Agent. "Auction Period" shall mean the period from and including the Closing Date to, but not including, the first Auction Period Accrual Date and, thereafter, from and including each Auction Period Accrual Date to, but not including, the next succeeding Auction Period Accrual Date; provided, however, that if such date is later than the maturity date of a maturity of ARS, the last day of such Auction Period shall be the maturity date of such ARS. "Auction Period Accrual Date" shall mean September 20, 1994 and every 5th Tuesday thereafter (or such other day that the Market Agent shall establish as an Auction Period Accrual Date); provided, however, that if such day is not a Business Day, the Auction Period Accrual Date shall be the next succeeding Business Day. THE INTEREST PERIOD, THE APPLICABLE ARS RATE AND METHOD FOR DETERMINING IT, THE INTEREST PAYMENT DATES, AND THE AUCTION PROCEDURE RELATED THERETO WILL BE DETERMINED UPON THE TERMS AND CONDITIONS, INCLUDING REQUIRED NOTICES THEREOF TO THE HOLDERS OF THE BONDS, DESCRIBED IN THE INDENTURE INCLUDING APPENDIX A THERETO, TO WHICH PROVISIONS SPECIFIC REFERENCE IS HEREBY MADE AND ALL OF WHICH PROVISIONS ARE HEREBY SPECIFICALLY INCORPORATED HEREIN BY REFERENCE. Mandatory Tender of ARS, Fixing and Separating ARS and IRS Any Beneficial Owner of IRS may, at any time and from time to time, notify a Broker- Dealer that such Beneficial Owner intends to submit a Bid for a specified principal amount of ARS having the same maturity date as such IRS on the next succeeding Auction Date in order to cause such ARS to be Fixed with all or a portion of such IRS, and that if such Bid is unsuccessful, in whole or in part, such Beneficial Owner requires that ARS (which are not Fixed) in an aggregate principal amount equal to the unsuccessful portion of such Bid be tendered to such Beneficial Owner for purchase on the seventh Business Day prior to the next succeeding Auction Date following the Auction in which such Bid proved unsuccessful. LAI-70382.1 4 A Beneficial Owner of ARS may cause such ARS to be combined with IRS, or "Fixed", and traded as a unit as Regular Fixed AIRS or Newly Fixed AIRS. ARS which became Fixed with IRS will be considered Newly Fixed AIRS for the remainder of the Interest Period in which such ARS and IRS were Fixed. The Service Charge payable with respect to the ARS which were Fixed will continue to accrue for the remainder of such Interest Period. A Beneficial Owner of Regular Fixed AI' 0 '+ 4'- ly Fixed AIRS may cause such ARS and IRS to be "Separated", and traded separat . N 'S and ARS, during the seven-day period immediately preceding a Record Date e han during a Closed Period) by delivering instructions to a Broker-Dealer. Upo of notice from the Broker-Dealer, the Auction Agent will cause such Regular Fixed S or Newly Fixed AIRS to be Separated on the next succeeding Interest Payment Date, or if such Interest Payment Date falls within a Closed Period, on the next succeeding Auction Period Accrual Date. Redemption Provisions The ARS are subject to redemption at the option of the Authority in whole or in part on any Interest Payment Date on or after July 1, 2004. at a redemption price equal to the principal amounts thereof plus accrued interest to the redemption date. The ARS maturing on July 1, 2014, are also subject to mandatory redemption on July 1, 2010 in the years 2010 through 2014 and in the respective principal amounts set forth in the Indenture, at a redemption price equal to 100% of the principal amount thereof plus accrued interest thereon to the redemption date. The Bonds are also subject to redemption prior to their respective maturity dates, in authorized denominations, on any date, as a whole or in part, from net insurance proceeds or condemnation awards, upon the terms and conditions of, and as provided in, the Indenture, at the principal amount thereof together with accrued interest to the date of redemption. In the event of any partial redemption of Bonds, the Bonds or portions thereof to be redeemed shall be selected as provided in the Indenture. The Authority shall not redeem ARS on any date unless on the same date the Authority redeems an equal principal amount of IRS. Notice of any redemption shall be given by the payment of the redemption price thereof shall be made at the time and in the manner set forth in the Indenture. If at the time of mailing of any notice of optional redemption the Authority shall not have deposited with the Trustee monies sufficient to redeem all Bonds called for redemption, such notice may state that it is subject to the deposit of the redemption monies with the Trustee not later than the opening of business on the redemption date and shall be of no effect unless such monies are so deposited. If on the redemption date sufficient moneys shall have been deposited with the Trustee to effect such redemption in accordance with the Indenture, then interest shall cease to accrue on the redemption date on all Bonds or portions thereof so called for redemption. As provided in the Indenture, notice of redemption of this Bond shall be given by first class mail not less than thirty (30) days nor more than sixty (60) days before the redemption date to the registered owner hereof. If notice of redemption has been duly given and money for the payment of the redemption price is held by the Trustee, then on the redemption date designated LAI-70382.1 5 in such notice, this Bond shall become due and payable, and from and after the date so designated, interest on this Bond shall cease to accrue and the registered owner of this Bond shall have no rights with respect hereto except to receive payment of the redemption price hereof. To the extent permitted by, and as provided in, Appendix A to the Indenture, modifications or amendments of Appendix A, and of the ri is and obligations of the Authority and of the owners of the Bonds may be made with sent of the Bond Insurer by the Authority, (i) upon obtaining an opinion of counsel h same does not materially adversely affect the rights of the owners of the Bonds, or�(i� obtaining the consent of the owners of all ARS and IRS or, in the event all of the A '. IRS are Fixed, by obtaining the consent of the owners of all Newly Fixed AIRS and 'i ,la Fixed AIRS. In the second event, the Trustee shall mail notice of such amendment to the . , ners of the ARS, and if, on the first Auction Date occurring at least 30 days after the date on which the Trustee mailed such notice, Sufficient Clearing Bids (as defined in the Auction Agent Agreement) have been received or all of the ARS are subject to Submitted Hold Orders (as defined in the Auction Agent Agreement),the proposed amendment shall be deemed to have been consented to by the owners of all ARS. As an additional condition precedent to any such amendment pursuant to the provisions of the Indenture, there shall be delivered to the Authority and the Trustee an opinion of counsel to the effect that such amendment will not adversely affect the validity of the ARS or IRS or the exclusion of interest on any of the Bonds from gross income for federal income tax purposes. Written notice of each such amendment shall be delivered by the Authority to the Trustee, the Auction Agent and each Broker-Dealer. • If an Event of Default, as defined in the Indenture, shall occur, the principal of all outstanding Bonds may be declared due and payable upon the conditions, in the manner and with the effect provided in the Indenture; except that the Indenture provides that in certain events such declaration and its consequences may be rescinded by the registered owners of at least a majority in aggregate principal amount of the Bonds then outstanding. This Bond is transferable only on the books required to be kept for that purpose by the Trustee by the registered owner hereof in person or by his duly authorized attorney upon payment of the charges provided in the Indenture and upon surrender of this Bond together with a written instrument of transfer in a form approved by the Trustee duly executed by the registered owner or his duly authorized attorney, and thereupon a new fully registered Bond or Bonds in the same aggregate principal amount will be issued to the transferee in exchange therefor. The Trustee shall not be required to register the transfer of or exchange any Bond (1) during the period commencing on the day five (5) business days before the date on which Bonds are to be selected for redemption and ending on such date of selection, or (2) which has been selected for redemption in whole or in part. The Authority and the Trustee may deem and treat the registered owner hereof as the absolute owner hereof for the purpose of receiving payment of the interest hereon and principal hereof and for all other purposes, whether or not this Bond shall be overdue, and neither the Authority nor the Trustee shall be affected by any notice or knowledge to the contrary; and payment of the interest on and principal of this Bond shall be made only to such registered LA1-70382.1 6 owner, which payments shall be valid and effectual to satisfy and discharge liability on this Bond to the extent of the sum or sums so paid. If the Authority shall pay or cause to be paid o there shall otherwise be paid to the registered owners of all outstanding Bonds the in t ereon, the principal thereof and the redemption premiums, if any, thereon at the ti in the manner stipulated herein and in the Indenture, then the registered owners o lcl onds shall cease to be entitled to the pledge of the Revenues as provided in the I re, and all agreements, covenants and other obligations of the Authority to the reg d owners of such Bonds under the Indenture shall thereupon cease, terminate and become void and be discharged and satisfied. This Bond shall not be entitled to any benefit, protection or security under the Indenture or become valid or obligatory for any purpose until the certificate of authentication and registration hereon endorsed shall have been manually executed and dated by the Trustee. It is hereby certified that all acts and proceedings required by law necessary to make this Bond, when executed by the Authority, authenticated and delivered by the Trustee and duly issued, the valid, binding and legal limited obligation of the Authority have been done and taken, and have been in all respects duly authorized. LA1-70382.1 7 IN WITNESS WHEREOF, the Santa Ana Financing Authority has caused this Bond to be executed in its name and on its behalf by the manual or facsimile signature of its Chairman and attested to by the manual or facsimile signature of its Secretary, and has caused this Bond to be dated as of the day and year first above written. SANTA ANA FINANCING AUTHORITY ,x . By ghWan Attest: cotS. cretary CERTIFICATE OF AUTHENTICATION AND REGISTRATION This is one of the Bonds described in the within mentioned Indenture which has been authenticated and registered on March 23, 1994. MERIDIAN TRUST COMPANY OF CALIFORNIA, as Trustee e � By �� 4i�ed Signatory LAI-70382.1 9 ASSIGNMENT For value received the undersigned hereby sells, assigns and transfers unto _ , whose tax identification number is , the within bond and all rights thereunder, and hereby irrevocably constitutes and appoints attorney, to transfer the within bond on the books kept for registration thereof, with full power of substitution in the premises. Dated: NOTE: The signature to this Assignment must correspond with the name as written upon the face of the bond in every particular, without alteration or enlargement or any change whatsoever. Signature Guara� • NOTICIO4C The signature must be guaranteed by a member of the New York Stock Exchange CO' or a commercial bank or trust company. LA1-70382.1 10 STATEMENT OF INSURANCE The Municipal Bond Investors Assurance Corporation (the "Insurer") has issued a policy containing the following provisions, such policy being on file at Meridian Trust Company of California, San Francisco, California. The Insurer, in consideration of the payment of the premium and subject to the terms of this policy, hereby unconditionally and irrevocably guarantees to any owner, as hereinafter defined, of the following described obli lions, the full and complete payment required to be made by or on behalf of the Sant PLFinancing Authority (the "Issuer") to Meridian Trust Company of California, or its su c (the "Paying Agent") of an amount equal to (i) the principal of (either at the stated m r by any advancement of maturity pursuant to a mandatory sinking fund payment) a est on, the Obligations (as that term is defined below) as such payments shall becom �ut shall not be so paid (except that in the event of any acceleration of the due date of such cipal by reason of mandatory or optional redemption or acceleration resulting from default or otherwise, other than any advancement of maturity pursuant to a mandatory sinking fund payment, the payments guaranteed hereby shall be made in such amounts and at such times as such payments of principal would have been due had there not been any such acceleration); and (ii) the reimbursement of any such payment which is subsequently recovered from any owner pursuant to a final judgment by a court of competent jurisdiction that such payment constitutes an avoidable preference to such owner within the meaning of any applicable bankruptcy law. The amounts referred to in clauses (i) and (ii) of the preceding sentence shall be referred to herein collectively as the "Insured Amounts." "Obligations" shall mean: $107,399,438.50 Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A Upon receipt of telephonic or telegraphic notice, such notice subsequently confirmed in writing by registered or certified mail, or upon receipt of written notice by registered or certified mail, by the Insurer from the Paying Agent or any owner of an Obligation the payment of an Insured Amount for which is then due, that such required payment has not been made, the Insurer on the due date of such payment or within one business day after receipt of notice of such nonpayment, whichever is later, will make a deposit of funds, in an account with State Street Bank and Trust Company, N.A., in New York, New York, or its successor, sufficient for the payment of any such Insured Amounts which are then due. Upon presentment and surrender of such Obligations or presentment of such other proof of ownership of the Obligations, together with any appropriate instruments of assignment to evidence the assignment of the Insured Amounts due on the Obligations as are paid by the Insurer, and appropriate instruments to effect the appointment of the Insurer as agent for such owners of the Obligations in any legal proceeding related to payment of Insured Amounts on the Obligations, such instruments being in a form satisfactory to State Street Bank and Trust Company, N.A., State Street Bank and Trust Company, N.A. shall disburse to such owners or the Paying Agent payment of the Insured Amounts due on such LA1-70382.1 11 Obligations, less any amount held by the Paying Agent for the payment of such Insured Amounts and legally available therefor. This policy doe not insure against loss of any prepayment premium which may at any time be payabb respect to any Obligation. As used herein, the term "owner" mean the registered owner of any Obligation as indicated in the books maintai e Paying Agent, the Issuer, or any designee of the Issuer for such purpose. owner shall not include the Issuer or any party whose agreement with the Issuer co utes the underlying security for the Obligations. Any service of process on the Insurer may be made to the Insurer at its offices located at 113 King Street, Armonk, New York 10504. This policy is non-cancelable for any reason. The premium on this policy is not refundable for any reason including the payment prior to maturity of the Obligations. In the event the Insurer were to become insolvent, any claims arising under a policy of financial guaranty insurance are excluded from coverage by the California Insurance Guaranty Association, established pursuant to Article 14.2 (commencing with Section 1063) of Chapter 1 of Part 2 of Division 1 of the California Insurance Code. MUNICIPAL BOND INVESTORS ASSURANCE CORPORATION LAI-70382.1 12 NUMBER R-IRS-1 $10,600,000 Unless this certificate is presented by an authorized representative of The Depository Trust Company, a New York corporation ("DTC"), to the Authority or its agent for registration of transfer, exchange, or payment, and any certificate issued is registered in the name of Cede & Co. or in such other name as is requested by an authorized representative of DTC (and any payment is made to Cede & Co. or to such other entity as is requested by an authorized representative of DTC), ANY TRANSFER, PLEDGE, OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL inasmuch as the registered owner hereof, Cede & Co., has an interest herein. THIS BOND MAY NOT BE SPLIT UP, TRANSFERRED OR EXCHANGED EXCEPT AS PROVIDED IN THE INDENTURE REFERRED TO HEREIN SANTA ANA FINANCING AUTHORITY POLICE ADMINISTRATION AND HOLDING FACILITY LEASE REVENUE BONDS, SERIES 1994A (INVERSE RATE SECURITY) INTEREST RATE MATURITY DATE DATED DATE CUSI ER Variable July 1, 2014 March 23, 1994 09AB5 cQk J` REGISTERED OWNER:CEDE & CO. PRINCIPAL SUM: TEN MILLION SIX HUNDRED THOUSAND DOLLARS FOR VALUE RECEIVED, THE Santa Ana Financing Authority (the "Authority"), a joint powers authority, duly created and existing under the laws of the State of California (the "State"), hereby promises to pay, but solely from the sources hereinafter described and from no other source, to the registered owner named above or registered assigns, the principal amount specified above on the maturity date specified above, and to pay to the registered owner named above or registered assigns, solely from said sources, interest on said principal amount from January 1, 1995 or from the most recent Interest Payment Date (as hereafter defined) to which interest has been paid or duly provided for, until the principal hereof is paid or duly provided for, at the rate and on the dates determined as provided herein. The principal of and premium, if any, on this Bond shall be payable at the principal corporate trust office of Meridian Trust Company of California, as trustee under the Indenture hereinafter referred to (together with each successor trustee under the Indenture, the "Trustee"), or if a successor trustee is hereafter appointed, then at the principal corporate trust office of such successor, or at the principal corporate trust office of any other paying agent appointed under the Indenture, upon surrender of this Bond at such principal corporate trust office. Interest on this Bond (other than Defaulted Interest, as hereafter defined) shall LA1-70383.I be payable by check or draft drawn upon the Trustee or upon any other paying agent for the Bonds appointed under the Indenture, mailed to the person in whose name this Bond is registered in the registration books maintained by the Trustee (the "Bond Register") at the close of business on the Record Date (as hereafter defined) next preceding the relevant Interest Payment Date at such person's address as it appears in the Bond Register on such Record Date; provided that any holder of Bonds of this series in an aggregate principal amount equal to or greater than $1,000,000 may elect I be paid the interest on such Bonds by Federal Reserve wire transfer in immediately ay.' funds to any bank in the United States of America specified by such holder by wri i •ction given to the Trustee not less than 30 days prior to the first Interest Payment or which such notice shall become effective. The term "Record Date" shall me. w' respect to any Interest Payment Date, the Business Day next preceding such Inte l.j ayment Date. Any interest on this Bond which is not punctually paid when due (".j): .ulted Interest") shall be payable to the holder in whose name this Bond is registered in the :and Register at the close of business on a special record date selected by the Trustee which shall be at least ten but not more than 30 days prior to the date selected by the Trustee for payment of such Defaulted Interest. The Trustee shall give notice to the bondholders of the special record date and the date for payment of Defaulted Interest at least ten days prior to such special record date. The principal of, premium, if any, and interest on this Bond shall be payable in any currency of the United States of America which on the respective dates of payment thereof is legal tender for the payment of public and private debts. The term "Business Day" shall mean any day other than a Saturday, Sunday or other day upon which banking institutions located in the state in which the principal corporate trust office of the Trustee or the principal office of the Auction Agent (as defined in the Indenture) is located are closed or are required to close or on which the New York Stock Exchange is closed. If the date for any payment of the principal of, premium, if any, or interest on this Bond or the last date for performance of any act or the exercising of any right, as provided in this Bond or in the Indenture, is not a Business Day, such payment may be made or act performed or right exercised on the next succeeding Business Day with the same force and effect as if made, performed or exercised on such nominal date. This Bond is one of a duly authorized issue of bonds of the Authority designated as its "Santa Ma Financing Authority Police Facility Lease Revenue Bonds, Series 1994A" (the "Bonds"), in the aggregate principal amount of One Hundred Seven Million Three Hundred Ninety-Nine Thousand Four Hundred Thirty-Eight Dollars and Fifty Cents ($107,399,438.50), of which $84,730,000 aggregate principal amount shall be issued as Current Interest Bonds, $1,469,438.50 aggregate principal amount shall be issued as Capital Appreciation Bonds, $10,600,000 aggregate principal amount shall be issued as Auction Rate Securities ("ARS") and $10,600,000 aggregate principal amount shall be issued as Inverse Rate Securities ("IRS"), all of like tenor and date (except for such variations, if any, as may be required to designate varying numbers, maturities and interest rates), and is issued under and pursuant to the provisions of an indenture, dated as of March 1, 1994 (the "Indenture"), between the Authority and the Trustee (copies of which are on file at the office of the Secretary of the Authority and at the Corporate Trust Office of the Trustee). LA1-70383.I • 2 The Bonds are issuable only as fully registered bonds without coupons, in the denomination of$50,000 and integral multiples thereof. The Bonds are issued to provide funds to finance the cost of acquiring, constructing and installing certain public capital improvements (the "Project") in the City of Santa Ana (the "City"). The Bonds are limited obligations of the A hority and are payable, as to interest thereon and principal thereof, solely from the r,s: - '. •s derived from base rental payments paid by the City pursuant to a lease, dated • '. arch 1, 1994 (the "Lease"), between the Authority, as lessor, and the City, as N.' ', for the use and possession of the Leased Property (as defined in the Lease) as lo e City has such use and possession of the Leased Property, which includes the Pro' : s well as from all other benefits, charges, income, proceeds, profits, receipts, rents a r. -venues derived by the Authority, as assignee of the Agency's rights under the Lease, fro operation or use of the Leased Property (the "Revenues"). All the Bonds are equally and ratably secured in accordance with the terms and conditions of the Indenture by a pledge of the Revenues, which Revenues shall be held in trust for the security and payment of the interest on, principal of and redemption premiums, if any, on the Bonds as provided in the Indenture. The Bonds shall be limited obligations of the Authority and shall be payable solely from the Revenues and amounts on deposit in the funds and accounts established under the Indenture (other than amounts on deposit in the Rebate Fund). The Bonds do not constitute a debt or liability of the City, the State of California, or any of its political subdivisions, and neither the faith and credit of the City, the State of California, nor any of its political subdivisions are pledged to the payment of the principal of or interest on the Bonds. Reference is hereby made to the Indenture and any and all amendments thereof and supplements thereto for a description of the terms under which the Bonds are issued, the provisions with regard to the nature and extent of the Revenues, and the rights of the registered owners of the Bonds. All of the terms of the Indenture are hereby incorporated herein and constitute a contract between the Authority and the registered owner of this Bond, to all the provisions of which the registered owner of this Bond, by acceptance hereof, agrees and consents. Each registered owner hereof shall have recourse to all of the provisions of the Indenture and shall be bound by all of the terms and conditions thereof. The Authority has agreed and covenanted that, for the payment of the interest on, the principal of and redemption premium, if any, on this Bond and all other Bonds of this issue authorized by the Indenture when due, there has been created and will be maintained by the Trustee a special fund into which all Revenues (other than deposits to the Rebate Fund created by the Indenture) shall be deposited, and the Authority has allocated such Revenues solely to the payment of the interest on and principal of and redemption premiums, if any, on the Bonds, and the Authority will pay promptly when due the interest on and the principal of and redemption premium, if any, on this Bonds and all other Bonds of this issue authorized by the Indenture out of said special fund, all in accordance with the terms and provisions set forth in the Indenture. LA1-70383.1 3 Interest Rate Provisions Interest on the ARS and IRS shall accrue for e ch Interest Period and shall be payable in arrears on each succeeding Interest Payment Da he Trustee to the persons who are the registered owners of the ARS as of the Reco e. An "Interest Period" begins on and includes an Interest Payment Date and ends o xcludes the next succeeding Interest Payment Date; however, the first Interest • io commences on the date of original delivery of the ARS. An "Interest Payment Dat-. .1 the ARS means January 1, 1995, semi-annually thereafter on each January 1 and July 1 1 at maturity. If any such day is not a Business Day, interest due on such day shall be paid on the next succeeding Business Day without accrual of any additional interest. Interest on the ARS shall be computed on the basis of a 360-day year for the actual number of days elapsed. The interest rate on the ARS shall be 3.08% per annum for the initial Auction Period and the interest rate (the "Applicable ARS Rate") for each subsequent Auction Period shall equal the sum of (A) the rate of interest (the "Auction Rate") determined periodically on the basis of orders placed in an Auction conducted on the Business Day immediately preceding the Interest Period and (B) the Service Charge Rate (as described in the Indenture) in effect, and in such other manner as described in the Indenture. The procedures for conducting an Auction and determining the Auction Rate are set forth in the Auction Agent Agreement, dated as of March 1, 1994, between the Trustee and the Auction Agent. Interest on the IRS shall be computed on the basis of a 360-day years for the number of days elapsed on the basis of twelve 30-day months. The interest rate on this Bond shall be 8.35% per annum for the initial Auction Period and the interest rate (the "Applicable IRS Rate") for each subsequent Auction Period shall equal the result, if any, taken to the nearest one-thousandth (.001) of 1% (without rounding), of (A) the Fixed Rate of 5.75% per annum multiplied by two, minus (b) the Applicable ARS Rate for such Interest Period multiplied by the Applicable Day Count Fraction, all as set forth in the Indenture. For purposes of the Applicable IRS Rate, the Applicable ARS Rate is multiplied by the Applicable Day Count Fraction in order to adjust such rate (which is calculated on the basis of actual days elapsed) to a rate per annum calculated on the basis of the number of days elapsed on the basis of twelve 30-day months. "Auction Period" shall mean the period from and including the Closing Date to, but not including, the first Auction Period Accrual Date and, thereafter, from and including each Auction Period Accrual Date to, but not including, the next succeeding Auction Period Accrual Date; provided, however, that if such date is later than the maturity date of a maturity of ARS, the last day of such Auction Period shall be the maturity date of such ARS. "Auction Period Accrual Date" shall mean September 20, 1994 and every 5th Tuesday thereafter (or such other day that the Market Agent shall establish as an Auction Period Accrual Date); provided, however, that if such day is not a Business Day, the Auction Period Accrual Date shall be the next succeeding Business Day. "Applicable Day Count Fraction" shall mean, with respect to any period the actual number of days in such period divided by the number of days in such period on the basis of twelve 30-day months. LAI-70383.1 4 THE INTEREST PERIOD, THE APPLICABLE IRS RATE AND METHOD FOR DETERMINING IT, THE APPLICABLE ARS RA D METHOD FOR DETERMINING IT, THE INTEREST PAYME ES, AND THE AUCTION PROCEDURE RELATED THERETO WILL ERMINED UPON THE TERMS AND CONDITIONS, INCLUDING REQ OTICES THEREOF TO THE HOLDERS OF THE BONDS, DESC THE INDENTURE INCLUDING Appendix A THERETO, TO WHICH PROVIS PECIFIC REFERENCE IS HEREBY MADE AND ALL OF WHICH PROVISIONS RE HEREBY SPECIFICALLY INCORPORATED HEREIN BY REFERENCE. Mandatory Tender of ARS, Fixing and Separating ARS and IRS Any Beneficial Owner of IRS may, at any time and from time to time, notify a Broker-Dealer that such Beneficial Owner intends to submit a Bid for a specified principal amount of ARS having the same maturity date as such IRS on the next succeeding Auction Date in order to cause such ARS to be Fixed with all or a portion of such IRS, and that if such Bid is unsuccessful, in whole or in part, such Beneficial Owner requires that ARS (which are not Fixed) in an aggregate principal amount equal to the unsuccessful portion of such Bid be tendered to such Beneficial Owner for purchase on the seventh Business Day prior to the next succeeding Auction Date following the Auction in which such Bid proved unsuccessful. A Beneficial Owner of IRS may cause such IRS to be combined with ARS, or "Fixed", and traded as a unit as Regular Fixed AIRS or Newly Fixed AIRS. IRS which became Fixed with ARS will be considered Newly Fixed AIRS for the remainder of the Interest Period in which such IRS and ARS were Fixed. The Service Charge payable with respect to the ARS which were Fixed will continue to accrue for the remainder of such Interest Period. A Beneficial Owner of Regular Fixed AIRS or Newly Fixed AIRS may cause such ARS and IRS to be "Separated", and traded separately as IRS and ARS, during the seven-day period immediately preceding a Record Date (other than during a Closed Period) by delivering instructions to a Broker-Dealer. Upon receipt of notice from the Broker-Dealer, the Auction Agent will cause such Regular Fixed AIRS or Newly Fixed AIRS to be Separated on the next succeeding Interest Payment Date, or if such Interest Payment Date falls within a Closed Period, on the next succeeding Auction Period Accrual Date. Redemption Provisions The IRS are subject to redemption at the option of the Authority in whole or in part on any Interest Payment Date on or after July 1, 2004, at the following redemption prices LA1-70383.1 5 (expressed as a percentage of their principal amount) plus accrued interest to the redemption date: IRS maturing in 2014 Redemption Dates (inclusive) Redemption Prig July 1, 2004 to June 30, 2005 104 July 1, 2005 to June 30, 2006 1t July 1, 2006 and thereafter �Qe, ,0 The IRS maturing on July 1, 2004, are also subj2t to mandatory redemption on July 1, 2010 in the years 2010 through 2014 and in the respective principal amounts set forth in the Indenture, at a redemption price equal to 100% of the principal amount thereof plus accrued interest thereon to the redemption date. The Bonds are also subject to redemption prior to their respective maturity dates, in authorized denominations, on any date, as a whole or in part, from net insurance proceeds or condemnation awards, upon the terms and conditions of, and as provided in, the Indenture, at the principal amount thereof together with accrued interest to the date of redemption. In the event of any partial redemption of Bonds, the Bonds or portions thereof to be redeemed shall be selected as provided in the Indenture. The Authority shall not redeem IRS on any date unless on the same date the Authority redeems an equal principal amount of ARS. Notice of any redemption shall be given by the payment of the redemption price thereof shall be made at the time and in the manner set forth in the Indenture. If at the time of mailing of any notice of optional redemption the Authority shall not have deposited with the Trustee monies sufficient to redeem all Bonds called for redemption, such notice may state that it is subject to the deposit of the redemption monies with the Trustee not later than the opening of business on the redemption date and shall be of no effect unless such monies are so deposited. If on the redemption date sufficient moneys shall have been deposited with the Trustee to effect such redemption in accordance with the Indenture, then interest shall cease to accrue on the redemption date on all Bonds or portions thereof so called for redemption. As provided in the Indenture, notice of redemption of this Bond shall be given by first class mail not less than thirty (30) days nor more than sixty (60) days before the redemption date to the registered owner hereof. If notice of redemption has been duly given and money for the payment of the redemption price is held by the Trustee, then on the redemption date designated in such notice, this Bond shall become due and payable, and from and after the date so designated, interest on this Bond shall cease to accrue and the registered owner of this Bond shall have no rights with respect hereto except to receive payment of the redemption price hereof. To the extent permitted by, and as provided in Appendix A to the Indenture, modifications or amendments of Appendix A, and of the rights and obligations of the Authority and of the owners of the Bonds may be made with the consent of the Bond Issuer LA1-70383.1 6 by the Authority, (i) upon obtaining an opinion of counsel that the same does not materially adversely affect the rights of the owners of the Bonds, or (ii) by obtaining the consent of the owners of all ARS and IRS or, in the event all of the ARS and IRS are Fixed, by obtaining the consent of the owners of all Newly Fixed AIRS and Regular Fixed AIRS. In the second event, the Trustee shall mail notice of such amendme .to the owners of the ARS, and if, on the first Auction Date occurring at least 30 days a - e date on which the Trustee mailed such notice, Sufficient Clearing Bids (as define. i - Auction Agent Agreement) have been received or all of the ARS are subject to Subr >• Hold Orders (as defined in the Auction Agent Agreement), the proposed amendince,W11 be deemed to have been consented to by the owners of all ARS. As an addition eition precedent to any such amendment pursuant to the provisions of the Indent, there shall be delivered to the Authority and the Trustee an opinion of counsel to the effect that such amendment will not adversely affect the validity of the ARS or IRS or the exclusion of interest on any of the Bonds from gross income for federal income tax purposes. Written notice of each such amendment shall be delivered by the Authority to the Trustee, the Auction Agent and each Broker-Dealer. If an Event of Default, as defined in the Indenture, shall occur, the principal of all outstanding Bonds may be declared due and payable upon the conditions, in the manner and with the effect provided in the Indenture; except that the Indenture provides that in certain events such declaration and its consequences may be rescinded by the registered owners of at least a majority in aggregate principal amount of the Bonds then outstanding. This Bond is transferable only on the books required to be kept for that purpose by the Trustee by the registered owner hereof in person or by his duly authorized attorney upon payment of the charges provided in the Indenture and upon surrender of this Bond together with a written instrument of transfer in a form approved by the Trustee duly executed by the registered owner or his duly authorized attorney, and thereupon a new fully registered Bond or Bonds in the same aggregate principal amount will be issued to the transferee in exchange therefor. The Trustee shall not be required to register the transfer of or exchange any Bond (1) during the period commencing on the day five (5) business days before the date on which Bonds are to be selected for redemption and ending on such date of selection, or (2) which has been selected for redemption in whole or in part. The Authority and the Trustee may deem and treat the registered owner hereof as the absolute owner hereof for the purpose of receiving payment of the interest hereon and principal hereof and for all other purposes, whether or not this Bond shall be overdue, and neither the Authority nor the Trustee shall be affected by any notice or knowledge to the contrary; and payment of the interest on and principal of this Bond shall be made only to such registered owner, which payments shall be valid and effectual to satisfy and discharge liability on this Bond to the extent of the sum or sums so paid. If the Authority shall pay or cause to be paid or there shall otherwise be paid to the registered owners of all outstanding Bonds the interest thereon, the principal thereof and the redemption premiums, if any, thereon at the times and in the manner stipulated herein and in the Indenture, then the registered owners of such Bonds shall cease to be entitled to the pledge of the Revenues as provided in the Indenture, and all agreements, covenants and other LA1-70383.1 7 obligations of the Authority to the registered owners o uch Bonds under the Indenture shall thereupon cease, terminate and become void and arged and satisfied. This Bond shall not be entitled to an :se it, protection or security tinder the Indenture or become valid or obligatory .. -1 •+'purpose until the certificate of authentication and registration hereon endorsed shall .0 - been manually executed and dated by the Trustee. It is hereby certified that all acts and proceedings required by law necessary to make this Bond, when executed by the Authority, authenticated and delivered by the Trustee and duly issued, the valid, binding and legal limited obligation of the Authority have been done and taken, and have been in all respects duly authorized. • LA1-70383.1 8 IN WITNESS WHEREOF, the Santa Ana Financing Authority has caused this Bond to be executed in its name and on its behalf by the manual or facsimile signature of its Chairman and attested to by the manual or facsimile signature of its Secretary, and has caused this Bond to be dated as of the day and year first above written. SANTA ANA FINANCINGIORITY ASS By , Attest: . CERTIFICATE OF AUTHENTICATION AND REGISTRATION This is one of the Bonds described in the within mentioned Indenture which has been authenticated and registered on March 23, 1994. MERIDIAN TRUST COMPANY OF CALIFORNIA, as Trustee By • eed Signatory LA1-70383.1 10 ASSIGNMENT . For value received the undersigned hereby sells, assigns and transfers unto , whose tax identification number is , the within bond and all rights thereunder, and hereby irrevocably constitutes and appoints attorney, to transfer the within bond on the books kept for registration thereof, with full power of substitution in the premises. Dated: NOTE: The signature to this Assignment must correspond with the name as written upon the face of the bond in every particular, without alteration or enlarnt or any change whatsoever. Signature Guaran` 4) NOTIC% The signature must be guaranteed by a member of the New York Stock Exchange or a commercial bank or trust company. LA1-70383.1 11 STATEMENT OF INSURANCE The Municipal Bond Investors Assurance Corporation (the "Insurer") has issued a policy containing the following provisions, such policy being on file at Meridian Trust Company of California, San Francisco, California. The Insurer, in consideration of the paym t of the premium and subject to the terms of this policy, hereby unconditionally and irre guarantees to any owner, as hereinafter defined, of the following described o i ' s, the full and complete payment required to be made by or on behalf of the S a Financing Authority (the "Issuer") to Meridian Trust Company of California, or 10, cessor (the "Paying Agent") of an amount equal to (i) the principal of (either at th ber maturity or by any advancement of maturity pursuant to a mandatory sinking fund pa ent) and interest on, the Obligations (as that term is defined below) as such payments shall become due but shall not be so paid (except that in the event of any acceleration of the due date of such principal by reason of mandatory or optional redemption or acceleration resulting from default or otherwise, other than any advancement of maturity pursuant to a mandatory sinking fund payment, the payments guaranteed hereby shall be made in such amounts and at such times as such payments of principal would have been due had there not been any such acceleration); and (ii) the reimbursement of any such payment which is subsequently recovered from any owner pursuant to a final judgment by a court of competent jurisdiction that such payment constitutes an avoidable preference to such owner within the meaning of any applicable bankruptcy law. The amounts referred to in clauses (i) and (ii) of the preceding sentence shall be referred to herein collectively as the "Insured Amounts." "Obligations" shall mean: $107,399,438.50 Santa Ma Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A Upon receipt of telephonic or telegraphic notice, such notice subsequently confirmed in writing by registered or certified mail, or upon receipt of written notice by registered or certified mail, by the Insurer from the Paying Agent or any owner of an Obligation the payment of an Insured Amount for which is then due, that such required payment has not been made, the Insurer on the due date of such payment or within one business day after receipt of notice of such nonpayment, whichever is later, will make a deposit of funds, in an account with State Street Bank and Trust Company, N.A., in New York, New York, or its successor, sufficient for the payment of any such Insured Amounts which are then due. Upon presentment and surrender of such Obligations or presentment of such other proof of ownership of the Obligations, together with any appropriate instruments of assignment to evidence the assignment of the Insured Amounts due on the Obligations as are paid by the Insurer, and appropriate instruments to effect the appointment of the Insurer as agent for such owners of the Obligations in any legal proceeding related to payment of Insured Amounts on the Obligations, such instruments being in a form satisfactory to State Street Bank and Trust Company, N.A., State Street Bank and Trust Company, N.A. shall disburse to such owners or the Paying Agent payment of the Insured Amounts due on such LA1-70383.1 12 Obligations, less any amount held by the Paying Agent for the payment of such Insured Amounts and legally available therefor. This policy does not insure against loss of any prepayment premium which may at any time be pay'A�le with respect to any Obligation. As used herein, the term "ow all mean the registered owner of any Obligation as indicated in the books main y the Paying Agent, the Issuer, or any designee of the Issuer for such purpos term owner shall not include the Issuer or any party whose agreement with the Iss o stitutes the underlying security for the Obligations. Any service of process on the Insurer may be made to the Insurer at its offices located at 113 King Street, Armonk, New York 10504. This policy is non-cancelable for any reason. The premium on this policy is not refundable for any reason including the payment prior to maturity of the Obligations. In the event the Insurer were to become insolvent, any claims arising under a policy of financial guaranty insurance are excluded from coverage by the California Insurance Guaranty Association, established pursuant to Article 14.2 (commencing with Section 1063) of Chapter 1 of Part 2 of Division 1 of the California Insurance Code. MUNICIPAL BOND INVESTORS ASSURANCE CORPORATION LA1-70383.1 13 .+PORT OI? PROPOSED DEBT LSSUA: c Castes Dee Advisory Coast 915 CatpW[fag,Rem 400,Memo,CA f51114 P.O.Iles M2Nl,Sneer°,CA 942N-4001 Ole 324.1305 Completion and timely submittal of this form to the California Debt Advisory Commission (CDAC) at the above address will assure your compliance with existing California State law and will oast in the maintenance of a complete data base.Thank you for your cooperation. ' Santa Ana Financing Authority NAME OF ISSUER 20 Civic Center Plaza, Santa Ana, California 92701 ADDRESS OF ISSUER COUNTY: Orange County PROPOSED SALE DATE February 1 , 19 9 4 TYPE OF SALE: 0 Competitive ® Negotiated PROPOSED PRINCIPAL TO BE SOLD: $ 105, 000, 000 DOES THE ISSUER INTEND TO SELL THE DEBT ISSUE IN A FOREIGN CURRENCY/t X No 0 Yes IS THE INTEREST ON THE DEBT MEW,'FROM TAXATION? Under State law: 0 NO(taxable) YES(tax-exempt) Under Federal lam 0 NO(taxable) [jJ YES(tax-exempt)IftbeissueisFederalytax-exempt.is interest a specific preference item for the of alternative minimum tax? tJ Yet preference item ® No,not a prehteace item IS ANY PORTION OF THE DEBT FOR REFUNDING?3 ® No 0 Yes,proposed.mount for refunding $ TYPE OF DEBT INSTRUMENT NOTE BOND ❑ Tax anticipation(T101) 0 Genual obligation(1201) ❑ Tax and revenue anticipation(T102) 0 Limited tax obligation(T202) ❑ Revenue anticipation(T103) 0 Revenue(Public enterprise)(1203) ❑ Bond anticipation(T104) 0 Condttit teems(Print obligor)(T204) ❑ Gram anticipation(T103) 0 Special aireaneeet(1206) ❑ Tax allocation(T106) 0 Tax allocation(T206) ❑ Other note(Please specify below.)(MT) El Public leen revenue(T207) 0 Other hoed(Please specify below.)(120S) ❑ FINANCING LEASE MOO 0 COMMERCIAL PAPER(T4on ❑ CERTIFICATES OF PARTICIPATION 0"301) 0 'own(Please specify below.)(T601) Please specify if"Other emefOther bond/OTHER"was checked: SOURCE(S)OF REPAYMENT 0 Tax•inaetoent(5106) ❑ Public enterprise revenues(SlOI) ❑ Private obligor payments(S102) ❑ Special arasmeea(S107) ❑ Bond proceeds($103) 0 genial tax rttnennas(SIN) ❑ Grants(S104) 0 Property m tens(SIO9) ❑ tntanavrmmenW wanders other then grants(Star) 0 General hot d using Jurisdiction(S110) 0 Other(Pkaae pecifyd(Slltk Lease revenue payments made pursuant to a Ground TIPacP Sagas adl3fydot'rCakarmiiCaww.rnddinsfl srisairef prspooderw ' 'YNosirodYtaissoutrr/bprpdalYY/rmlCrlserAot30*rprorn de ask r Seca 592200of ifs fi VonSGeiew.urtCe/rnririsMiosirenprti0L7sp'brerMYMiarriusaYarimirasaip7ihitaassrwcyaAeNwb.'1W^parr of Or Owed Salo f Muria s scam 11Jd3fe1f2Xa1MArGyfareisCarwtrrGrgirlrsiy baiter sdi'rRisky Wokswhom aioresse Yrlissit r.omsaam ent.whn two wads aerdr bash ate wit is dr MAC epi_ Ar net shy she kiwi arc/raid is of Ar bask•tpee raker eta awned MS lad of at p.th&r,e Sias STATE OF CALIFORNIA . �,. CALIFORNIA DEBT ADVISORY COMMISSION 915 CAPITOL MALL,ROOM 400 - MEMBERS P.O. BOX 942809 SACRAMENTO,CA 94209-0001 Kathleen Brown State Treasurer TELEPHONE: (916)653-3269 Pete wilson FAX: (916)654-7440 December 16, 1993 Governor • Steve Juarez Gray n Executive Director States Co Controller Robert G.Beverly State Senator Lucy Killea TO: Lawrence N. Tonomura, Esq. statesenator Orrick Herrington & Sutcliffe Jim Costa 777 South Figueroa Street, Suite 3200 State Assemblyman Patrick J.Nolan Los Angeles, CA 90017 Score Assemblymen Donald W.Metz Treasurer/Tax Collector County of Sonoma Phyllis E.Currie, • FROM: CALIFORNIA DEBT ADVISORY COMMISSION Chief Financial(Nicer Los Angeles City Degartrnent of Water end Power SUBJECT: Acknowledgment of Report of Proposed Debt Issuance Section 8855 (g) of the California Government Code requires written notice to be given to the California Debt Advisory Commission no later than 30 days prior to the proposed sale of any public agency debt issue. The California Debt Advisory Commission (CDAC) acknowledges your written notice of the following proposed debt issuance: CDAC Number: 93-2026 Issuer: SANTA ANA FA Project: Police Facility Project Proposed Amount: $105, 000, 000 • Proposed Sale Date: February 1, 1994 Date Notice Received: December 15, 1993 Please submit the "Report of Final Sale" and the Official Statement (or offering circular) on this issue after the sale is completed. Any questions regarding reporting requirements may be directed to the CDAC staff at (916) 653-3269. cc: David N. Ream, Executive Director � 7 law Printed on Recycled Paper CDAC#: 93-2026 REPORT OF FINAL SALE • California Debt Advisory Commission V F D 915 Capitol Mall,Room 400,Sacramento,CA 95814, P.O.Box 942809,Sacramento,CA 94209-0001 (916)653-3269 APR 4.1994 Completion of this form is requested to provide information which was not available when the"Report of Propos_e� ance" was filed with the CDAC or to verify information which was reported as"proposed."Additionally,please send a copy of�fli�idfl gyp( t(or offering circular)with this form to the CDAC. ADVISOR'(L'Jll'�� NAME OF ISSUER: Santa Ana Financing Authority $107, 399,438 . 50 Santa Ana Financing Authority Police Administration ISSUENAME: and Holding Facility Lease Revenue Bonds, Series 1994A OFFICIAL STATEMENT: ❑X Enclosed El Tb be sent ❑ None available SALE DATE: March 23 , 1994 PRINCIPAL AMOUNT SOLD $ 107, 399,438. 50 IS THE DEBT ISSUE DENOMINATED IN A FOREIGN CURRENCY? • ® No 0 Yes,type of foreign currency IS THE INTEREST ON THE DEBT EXEMPT FROM TAXATION? Under State law: ❑ NO(taxable) ® YES(tax-exempt) Under Federal law: 0 NO(taxable) El YES(tax-exempt)If the issue is federally tax-exempt,is interest a specific preference item for the purpose of alternative minimum tax? 0 Yes,preference item 0 No,not a preference item IS ANY PORTION OF THE DEBT FOR REFUNDING? ® No 0 Yes,amount of this issue(including costs)which is for refunding of existing debt $ • UNDERWRITER OR PURCHASER: Smith Barney Shearson . Inc. FINANCIAL ADVISOR: Kelling, Northcross & Norbriga INDICATE CREDIT RATING: (For example,"AAA"or"Aaa") 0 RATED Standard&Poor's: AAA Fitch: Moody's: Aaa Other: ❑ NOT RATED WAS THE ISSUE INSURED OR GUARANTEED? 0 No ® Bond insurance 0 Letter(s)of credit 0 Other GUARANTOR'S NAME: Municipal Bond Investors Assurance Corporation INTEREST COST: 5.705862 % ❑ TIC El NIC ❑ Variable(Please specify.) IF NEGOTIATED SALE,INDICATE GROSS SPREAD: See Official Statement FINANCIAI,ADVISORFEE: To be determined BOND COUNSEL FEE: To be determined d 3R COSTS OF ISSUANCE PAID BY THE ISSUER:(For example,advertising,printing,bond registration,bond rating,etc.Please specify amountandpurpose.) See Official Statement Section 5.4.583(c)(2)(B)of the California Government Code requires that am'local agency selling refunding bonds at private sale or on a negotiated basis shall send a written statement,within two weeks after rite bones are sold to the CDAC explaining the reasons why the local agency determined to sell the bonds at private sale or on a negotiated basis instead of at public sak. 19' $ Ll information Return for Tax-Exempt GovernmentaG 1.- Under Internal Revenue Code section 149(e) OMtoV1V 23 • (Rev.May 1993) oftIOSST Form . 0.- See separate Instructions. , . C + Department elate Treasury (Use Form 8038-GC if the issue price is under$100,¶t' L Internal Revenue Senke Reporting Authority ed Return,check here ► ❑ 1 Issuer's name Issuer's employer identification number SANTA ANA FINANCING AUTHORITY 5-3$60326 3 Number and street(or P.O.box if mail is not delivered to street address) I Room/suite 4 Report number 20 Civic Center Plaza G19 94 -1 5 City,town,state,and ZIP code 6 Date of issue Santa Ana, California 92701 March 23. 1994 7 Name of Issue Santa Ana Financing Authority Police Administration 8 CUSIP Number �d Holding Facility Tease Revenue Bonds, Series 1994A 801109AB5 Type of Issue(check applicable box(es) and enter the issue price) Issue price 9 0 Education (attach schedule-see instructions) - gr $ 10 0 Health and hospital (attach schedule-see instructions). ta 'yi t :� 11 0 Transportation 1ys,.�.�4. 12 0 Public safety ,. 4 g 13 0 Environment(including sewage bonds) 6 o. 14 0 Housing OW 15 ❑ Utilities Vi ,, > ' 16 ® Other. Describe(see Instructions) ► Jail Facility ////1/1//1/057 339.65 17 If obligations are tax or other revenue anticipation bonds,check t➢o nil �18 If obligations are In the form of a lease or installment sale,check x I it .i�' ""s Descri tion of Obligations (a) •b) (c) (d) tel (9 l91 Maturity dale Interest rate Issue price.,. Stated redemption Weighted field Net interest price at maturity average maturity cost 19 Final maturity. 7 1 2024 6.250% 9,174,139.20 . • 8 685,000.00 ���������/.7����/���������j 20 Entire Issue . �J���//��/7����A11.057.339.65 207,399,436.50 22.482 years * % ** % _I Uses of Original Proceeds of Bond Issue (including underwriters'discount) 21 Proceeds used for accrued interest 21 315,258.63 22 Issue price of entire issue(enter amount from line 20, column(c)) 22 111,057,339.65 23 Proceeds used for bond issuance costs(including underwriters'discount) . 23 1,177,459_01 24 Proceeds used for credit enhancement -• 24 1.091.000.00I 25 Proceeds allocated to reasonably required reserve or replacement fund . . 25 9,72 7-R12.50 26 Proceeds used to refund prior issues 26 -0 27 Total(add lines 23 through 6) • 27 11,496,271.51 28 Nonrefunding proceeds of the issue(subtract line 27 from line 22 and enter amount here). . . 28 99,561,068.14 10:110 Description of Refunded Bonds (complete this part only for refunding bonds) 29 Enter the remaining weighted average maturity of the bonds to be refunded ► years 30 Enter the last date on which the refunded bonds will be called P. 31 Enter the date(s)the refunded bonds were issued ► Latal Miscellaneous 32 Enter the amount of the state volume cap allocated to the issue P. 33 Enter the amount of the bonds designated by the issuer under section 265(b)(3)(B)(l)(III) (small issuer exception) ► 34 Pooled financings: a Enter the amount of the proceeds of this issue that are to be used to make loans to other governmental units P. b If this issue is a loan made from the proceeds of another tax-exempt issue, check box P. ❑ and enter the name of the issuer E. . and the date of the issue ► 35 If the issuer has elected to pay a penalty in lieu of rebate, check box P. ❑ Under pen. es'el perjury,I deda a I have examined this return and accompanying schedules and statements.and to the best of my knowlecce and bel' ,they ale true,ecrrec.and complete. Please / /72 Type Si n Here �[ David N. Ream 8 40re7<)l f/an- _ March 23, 1994 i Executive Director Signature of officer Dale or print name and title For Paperwork Reduction Act Notice, see page 1 of the Instructions. cal No.63773S Form 8038-G (Rev e-93; * 5.855178% ** 5.705862% REQUISITION FOR MONEY (SANTA ANA FINANCING AUTHORITY) I. Requisition No.: 1. II. The Santa Ana Financing Authority (the "Authority") hereby requests Meridian Trust Company of California, as trustee ("Trustee") pursuant to that certain Indenture, dated as of March 1, 1994 (the "Indenture"), between the Authority and the Trustee, under the terms of which Indenture the Authority has issued its Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A (the "Bonds"), to pay from the moneys in the Costs of Issuance Fund established pursuant to Section 4.01 of the Indenture (the "Costs of Issuance Fund"), upon receipt of an invoice therefor, an amount not to exceed the total amount shown on Schedule I attached hereto to the order of the persons shown therein, as reimbursement for the costs incurred or expenditures made in connection with the issuance of the Bonds. III. The payees, the purpose for which the cost has been incurred, and the amount of the disbursement requested are itemized on Schedule I hereto. IV. Each obligation mentioned in Schedule I hereto has been properly incurred and is a proper charge against the Costs of Issuance Fund. None of the items for which payment is requested has been reimbursed previously from the Costs of Issuance Fund. Dated: March 23, 1994 SANTA ANA FINAN G AUTH TY By le; • David N. Ream, Executive Director LA 1-69935.2 SCHEDULE I Payee Purpose Amount Meridian Trust Company of Acceptance Fee, Administration $ 8,500.00 California Fee as Trustee, Trustee Counsel Fee and Closing Expenses Orrick, Herrington & Sutcliffe Bond Counsel Fee, plus 50,000.00 disbursements Wire payment as follows: Bank of America NT & SA San Francisco Main Branch For Account of Orrick, Herrington & Sutcliffe Account No. 1499-4-10382 ABA No. 121000358 RR Donnelley Financial Printing of Preliminary Official 17,831.53 Statement and Official Statement TOTAL $76.331.53 LAI-69935.3 TAB#33 TITLE INSURANCE POLICIES ON FILE WITH THE TRUSTEE FOR THIS TRANSACTION LA1-63221.5 INSURANCE CERTIFICATE I, DAVID N. REAM, City Manager for the City of Santa Ana (the "City"), hereby certify that I am familiar with the provisions of that certain Lease, dated as of March 1, 1994 (the "Lease"), between the City, as lessee, and the Santa Ana Financing Authority, as lessor, and that the City has caused policies of insurance to be obtained, as required by Section 6.03 of the Lease, which policies of insurance are evidenced by the Certificate of Insurance attached hereto as Exhibit A. Dated: March 23, 1994 CITY OF SANTA,kNA By :t._ r'G.___, //117_ David N. Ream, City Manager LA 1-69935.2 :ACIOI:Ds U SE TIFIV :II : I88UE DATE MM OD ....:.�ATIi ��4NSUFIANGE.. PRODUCE THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND Marsh & McLennan, Incorporated CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE 695 MacArthur Court DOES NOT AMEND,EXTEND OR ALTER THE COVERAGE AFFORDED BY THE ,ite 550 POLICIES BELOW. Newport Beach, CA 92660 COMPANIES AFFORDING COVERAGE COMPAIETTERNY A RELIANCE INSURANCE CO INSURED COMPANY B ALLIANZ INSURANCE CO. CRSS Constructors, Inc. 2500 Michelson Drive COMTERNY C Suite 100 Irvine, CA 92714 LETTER"Y D COMPANY LETTER E IMMLI ,...:,,...c.,,Ka-a.,m p.vc:3R^rc.:.:..::.Aax.r.:,piNp ^::^ccc. .:.:.. ..... :...,k..._->....n.}:....):.vc...}:.c....a::::.;�.:..c:p,:�:c5ic.:::::V?�:cer:..:c:Rc:.'co>::::i'a>a;::.:..: THIS IS ...............,..}}:<.:�.:., �::...:.c�..,:y�:<::<�::.�::::::..:-`;;2:y::%S:'<:i=::s�_:::;c:,:�e:.:r::.::}:..:».:>:;::>::>s;:rs:�.:�y::%>:::�:::a>,::;%r.��::c�-:<:;:;:::.:.::e::•::•;}: TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOWa:.E<I..SUR.,D,,,AM �:>...;.VE,.F ..,,.HE.POL.C.:...PERIOD:.'::4'�"x'a>,�.;.:.,..... HAVE BEEN ISSUED T THE INSURED NAMED ABOVE FOR ECT TO WHICH T a...-� �� INDICATED,NOTWITHSTANDING ANY REQUIREMENT, TERM OH CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN,THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO AU.THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS, T CO TYPE OF INSURANCEEFFECTIVE LA POLICY NUMBER POUC DATEV(MM/°D/YY)RAIION LIMITS A GENERAL UABIUTY SJ 2539905 1 3/31/94 3/31/Y5 GENERAL AGGREGATE $ I000000 X COMMERCIALGENERAL UABIUTY $ ,.,,, (CLAIMS MADE X OCCUq, PRODUCTS-COMP/OP AGG. $ 10000001 X OWNER'S&CONTRACTOR'S PROT. PERSONAL&ADV.INJURY $ 1000000 EACH OCCURRENCE $ 1000000 FIRE DAMAGE(Any one fire) $ 50000 AUTOMOBILE LAMM - MED.EXPENSE(Any one person) $ 5000 ANY AUTO COMBINED SINGLE LIMIT $ ALL OWNED AUTOS SCHEDULED AUTOS BODILY INJURY (Per person) $ HIRED AUTOS NON-OWNED AUTOS BODILY INJURY (Per eccldenl) $ GARAGE LIAR um PROPERTY DAMAGE $ EICESS WBIUTY UMBRELLA FOAM EACH OCCURRENCE $ AGGREGATE OTHER THAN UMBRELLA FORM $ WORKER'S ..... ................................ COMPENSATION �' MSLTanaM ISTATUTORY�LIMITS��` AND EACH ACCIDENT "g 2ia.::..a::.....:.....^•..., EMPLOYERS'WHAM DISEASE-POLICY OMIT S OTHER DISEASE-EACH EMPLOYEE $ B FIRE & ALLIED ATO 1022009 3/31/94 3/31/96 $78,300,000 Blanket All risks of physical damage - builders risk form. DESCRIPTION OF°PEMTIONS/LOCAVON$/VEHICLEB/BpECIAL VEILS Certificate holder is named as loss payee and additional insured with respect to the Santa Ana Police Administration/Holding Facility as their interest May appear. PAVERWAgitiO .,...;Qkrt3>a°^*�c:.�"�a��:s^�s>..�..3.".ate,<za.<.w....�:.:.c.;:;<,>:. . .........:.:..:........ :�.^.... ....... ^...:2:.,....d.•.x.:.:....:......CAH @LLATJ. :ESI:.:.EWMI:os:a:::M::>::`:,.:>:::::>.:,;;}::.,>}}:...,}:^..:..:::„.. gagagnig £y SHOULD ANY OF THE MOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE Meridian Trust Co. of CA sr.` EXPIRATION DATE THEREOF,THE ISSUING COMPANY WILL ENDEAVOR TO 650 California St, 8th Floor MAIL.1O DAYS WRITTEN NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE Attn: Todd Duncan LEFT,BUT FAILURE TO MAIL SUCH NOTICE SHALL IMPOSE NO OBLIGATION OR San Francisco, CA 94108 LIABILITY OF ANY KIND UPON THE COMPANY, ITS AGENTS OR REPRESENTATIVES. AUTHORIZED REPRESENTATIVE • why{. �l,Apg MeiG41�.P1::(,('#'Y:;.. aC<Gvry ,.::ur...^.x}.}.:R:c✓:»zay.3<{%Ta::':41^:_wn:'.:ie!xc:.:,:::.c::v`:S. :,r .r....... Q. %js:.aa.ox�,."�'jr*:`.,.vi:>.;<:;:..:oe:..,x$ss�:,n:ms`:`.c«;:c.�Ey:,::.e, QAI " ._: ......... .::.....:.,.. .c.:...}n:aiY:::�"�:;::>},<::\..'::J�.tw'e08�!:.�''.lS''.��}I#�V�».}"':%3:81aU' MaIA FINANCIAL GUARANTY INSURANCE POLICY Municipal Bond Investors Assurance Corporation Armonk,New York 10504 Policy No. 15491 Municipal Bond Investors Assurance Corporation (the "Insurer"), in consideration of the payment of the premium and subject to the terms of this policy,hereby unconditionally and irrevocably guarantees to any owner, as hereinafter defined, of the following described obligations, the full and complete payment required to be made by or on behalf of the Issuer to Meridian Trust Company of California,San Francisco,California or its successor (the"Paying Agent")of an amount equal to(i)the principal of(either at the stated maturity or by any advancement of maturity pursuant to a mandatory sinking fund payment)and interest on, the Obligations(as that teen is defined below)as such payments shall become due but shall not be so paid (except that in the event of any acceleration of the due date of such principal by mason of mandatory or optional redemption or acceleration resulting from default or otherwise,other than any advancement of maturity pursuant to a mandatory sinking fund payment,the payments guaranteed hereby shall be made in such amounts and at such times as such payments of principal would have been due had there not been any such acceleration); and(ii) the reimbursement of any such payment which is subsequently recovered from any owner pursuant to a final judgment by a court of competent jurisdiction that such payment constitutes an avoidable preference to such owner within the meaning of any applicable bankruptcy law. The amounts referred to in clauses(i)and(ii)of the preceding sentence shall be referred to herein collectively as the"Insured Amounts." "Obligations"shall mean: $107,399,438.50(Original Principal Value) $108,255,000(Maturity Value) Santa Ma Financing Authority Police Administration and Holding Facility Lease Revenue Bonds Series 1994A Upon receipt of telephonic or telegraphic notice,such notice subsequently confirmed in writing by registered or certified mail,or upon receipt of written notice by registered or certified mail,by the Insurer from the Paying Agent or any owner of an Obligation the payment of an Insured Amount for which is then due,that such required payment has not been made,the Insurer on the due date of such payment or within one business day after receipt of notice of such nonpayment,whichever is later,will make a deposit of funds,in an account with State Street Bank and Trust Company,NA.,in New York, New York,or its successor,sufficient for the payment of any such Insured Amounts which are then due. Upon presentment and surrender of such Obligations or presentment of such other proof of ownership of the Obligations,together with any appropriate insnrments of assignment to evidence the assignment of the Insured Amounts due on the Obligations as are paid by the Insurer,and appropriate instruments to effect the appointment of the Insurer as agent for such owners of the Obligations in any legal proceeding related to payment of Insured Amounts on the Obligations,such instruments being in a form satisfactory to State Street Bank and Trust Company,N.A.,State Street Bank and Trust Company,N.A.shall disburse to such owners, or the Paying Agent payment of the Insured Amounts due on such Obligations,less any amount held by the Paying Agent for the payment of such Insured Amounts and legally available therefor. This policy does not insure against loss of any prepayment premium which may at any time be payable with respect to any Obligation. As used herein,the term"owner"shall mean the registered owner of any Obligation as indicated in the books maintained by the Paying Agent,the Issuer,or any designee of the Issuer for such purpose. The term owner shall not include the Issuer or any party whose agreement with the Issuer constitutes the underlying security for the Obligations. My service of process on the Insurer may be made to the Insurer at its offices located at 113 King Street,Armonk,New York 10504 and such service of process shall be valid and binding. This policy is non-cancellable for any mason. The premium on this policy is not refundable for any mason including the payment prior to maturity of the Obligations. In the event the Insurer were to become insolvent,any claims arising under a policy of financial guaranty insurance are excluded from coverage by the California Insurance Guaranty Association,established pursuant to Article 142(commencing with Section 1063)of Chapter 1 of Part 2 of Division 1 of the California Insurance Code. IN WITNESS WHEREOF,the Insurer has caused this policy to be executed in facsimile on its behalf by its duly authorized officers,this 23rd day of March,1994. MUNICIPAL BOND INVESTORS ASSURANCE CORPORATION trefuAa. teat,. Presid t �/J� Attest�2r.Q. e w / // c Assistant Secretary SID-RCA-5 Municipal Bond Investors Assurance Corporation 113 King Street Armonk,NY 10504 914 273 4545 TAX CERTIFICATE City of Santa Ana 20 Civic Center Plaza M Gi V'�A Santa Ana,California 92702 RE: $107,399,438.50 (Original Principal Value) $108,255,000 (Maturity Value) Santa Ana Financing Authority, Police Administration and Holding Facility Lease Revenue Bonds,Series 1994A (the"Obligations") Ladies and Gentlemen: In connection with the issuance of the above-referenced obligations(the "Obligations"), Municipal Bond Investors Assurance Corporation (the "Insurer") is issuing a financial guaranty insurance policy(the"Policy")securing the payment of principal and interest on the Obligations. This is to advise you that: 1. The Policy is an unconditional obligation of the Insurer to pay scheduled payments of principal and interest on the Obligations in the event of a failure to do so by the City of Santa Ana; • 2. The insurance premium in the amount of$1,091,000 represents the charge for a transfer of credit risk and was determined in arm's length negotiations and is required to be paid as a condition to the issuance of the Policy; 3. No portion of such premium represents an indirect payment of costs related to the issuance of the Obligations other than the transfer of credit risk; 4. The Insurer does not reasonably expect that it will be called upon to make any payment under the Policy;and 5. To the extent the Insurer is called upon to make any payment under the Policy,the Insurer reasonably expects to pursue all available legal remedies to secure reimbursement for such payment. Dated:March 23, 1994. MUNICIPAL BOND INVESTORS/ ASSURANCE CORPORATION jte4_44,1 Assistant Secretary /H O CERTIFICATE OF MUNICIPAL BOND INVESTORS ASSURANCE CORPORATION I, Pauline M. Cullen, Assistant Secretary of Municipal Bond Investors Assurance Corporation, do hereby certify that the information concerning Municipal Bond Investors Assurance Corporation and its policies as set forth in the Official Statement, dated March 23, 1994 under the caption "BOND INSURANCE",regarding$107,399,438.50 Santa Ana Financing Authority, Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A, is accurate. IN WITNESS WHEREOF, I hereunto set my hand and deliver this Certificate on this 23rd day of March, 1994. Assistant Secretary MAYOR Daniel H.Young etarh ALL-AMERICA CITY 1982-83 MAYOR PRO TEM Miguel A.Pulido CITY MANAGER 'JNCILMEMBERS education ISM David N. Ream homas E.Lutz CITY ATTORNEY Patricia A.McGuigan Edward J.Cooper Lisa Mills CITY OF SANTA ANA CLERK OF THE COUNCIL Ted R Moreno Janice C.Guy Robert L.Richardson 20 CIVIC CENTER PLAZA • P.O.BOX 1988 SANTA ANA,CALIFORNIA 92702 March 23 , 1994 Smith Barney Shearson Inc. , as representative 333 South Grand Avenue Fifty-first Floor Los Angeles, California 90071 Orrick, Herrington & Sutcliffe 777 South Figueroa Street, Suite 3200 Los Angeles, California 90017 Re: Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A Ladies and Gentlemen: We have acted as counsel to the Santa Ana Financing Authority (the "Authority") pursuant to an Indenture (the "Indenture") by and between the Authority and Meridian Trust Company of California, as trustee, and Resolution No. 94-001 SAFA adopted by the Authority on February 22 , 1994 (the "Authority Resolution") , in connection with the sale by the Authority of $107 , 399, 438 .50 aggregate principal amount of the above-mentioned bonds (the "Bonds") . In that connection, we have examined the record of proceedings submitted to us relative to the issuance of the Bonds and such other documents as are in our opinion necessary to enable us to express an informed opinion with respect to the following matters. Unless otherwise indicated, capitalized terms used herein have the respective meanings given to such terms in the Purchase Contract, dated March 8, 1994 (the "Purchase Contract") , by and among the Authority, the City, and Smith Barney Shearson Inc. , as representative of the underwriters. We are of the opinion that: (i) The Authority is a joint exercise of powers agency duly organized and validly existing under the constitution and the laws of the State with full right, power and authority to execute, deliver and perform its obligations CITY ATTORNEY - (714) 647-5201 FAX NO. (714) 647-6515 C S-679 Smith Barney Shearson Inc. , as representative Orrick, Herrington & Sutcliffe March 23 , 1994 Page 2 under the Authority Documents and to carry out and consummate the transactions contemplated by the Authority Documents, the JPA Agreement and the Official Statement; (ii) By all necessary official action of the Authority, the Authority has duly authorized and approved the execution and delivery of, and the performance by the Authority of the obligations contained in the Authority Documents and the JPA Agreement and the Authority Documents and the JPA Agreement constitute the legally valid and binding obligations of the Authority enforceable against the Authority in accordance with their respective terms; (iii) The resolution of the Authority approving and authorizing the execution and delivery of the Authority Document, and approving the Official Statement, has been duly adopted at a meeting of the governing body of the Authority, which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout, and the resolution is in full force and effect and has not been modified, amended or rescinded; (iv) The Authority is not in default, nor has it been in default, as to principal or interest with respect to an obligation issued or incurred by the Authority and the Authority is not and will not, in any manner which would materially adversely affect the transactions contemplated by the Authority Documents or the JPA Agreement, be in breach of or in default under any applicable constitutional provision, law or administrative rule or regulation of the State or the United States of America, or any applicable judgment or decree or any trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the Authority is a party or is otherwise subject, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute, in any manner which would materially adversely affect the transactions contemplated by the Authority Documents, a default or event of default under any such instrument; (v) The authorization, execution and delivery of the Authority Documents and compliance with the provisions of each of such agreements or instruments and of the JPA Agreement do not and will not, in any manner which would materially adversely affect the transactions contemplated by the Authority Documents or the JPA Agreement, conflict with or constitute a breach of or default under any applicable Smith Barney Shearson Inc. , as representative Orrick, Herrington & Sutcliffe March 23, 1994 Page 3 constitutional provision, law or administrative rule or regulation of the State or the United States of America, or any applicable judgment, decree, license, permit, trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the Authority (or any of its officers in their respective capacities as such) is subject, or by which it or any of its properties is bound, nor will any such authorization, execution, delivery or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of its assets or properties or under the terms of any such law, regulation or instrument, except as may be provided by the Authority Documents or the JPA Agreement; (vi) The information in the Official Statement under the captions "THE AUTHORITY, " and "LITIGATION, " is true and accurate to the best of my knowledge at and as of the date hereof; (vii) All authorizations, approvals, licenses, permits, consents and orders of or filings with any governmental authority, legislative body, board, agency or commission having jurisdiction in the matters which are required for the due authorization of, which would constitute a condition precedent to or the absence of which would materially adversely affect the due performance by the Authority of its obligations in connection with, the Authority Documents or the JPA Agreement have been duly obtained or made, except as may be required under the Blue Sky or securities laws of any state in connection with the offering and sale of the Bonds; (viii) No action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, is pending or, to the best knowledge of the Authority after due investigation, threatened (i) in any way questioning the existence of the Authority or the titles of the officers of the Authority to their respective offices; (ii) affecting, contesting or seeking to prohibit, restrain or enjoin the execution or delivery of any of the Bonds, or in any way contesting or affecting the validity of the Bonds, the Authority Documents or the JPA Agreement or the consummation of the transactions contemplated thereby, or contesting the exclusion of the interest on the Bonds from gross income for federal income tax purposes or contesting the powers of the Authority to enter into the Authority Documents; (iii) which may result in any Smith Barney Shearson Inc. , as representative Orrick, Herrington & Sutcliffe March 23 , 1994 Page 4 material adverse change to the financial condition of the Authority; or (iv) contesting the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto or asserting that the Preliminary Official Statement or the Official Statement contained any untrue statement of a material fact or omitted to state any material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, provided, however, that no opinion is given as to information contained under the caption "BOND INSURANCE" or in APPENDIX F thereto, and there is no basis for any action, suit, proceeding, inquiry or investigation of the nature described in clauses (i) through (iv) of this sentence; and (ix) Nothing has come to my attention which would lead such counsel to believe that the Official Statement (excluding therefrom the financial and statistical data and forecasts included therein, as to which no opinion need be expressed) contains any untrue statement of a material fact or omits to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. Very truly yours, ,ram, - •wa coop-r City Atto -y MAYOR Daniel H.Young etaN ALL-AMERICA CITY 1982-83 MAYOR PRO TEM Miguel A.Pulido CITY MANAGER 'JNCILMEMBERS .,dncation 1st David N.Ream .homas E. Lutz CITY ATTORNEY Patricia A.McGuigan Edward J.Cooper Lisa Mills CITY OF SANTA ANA CLERK OF THE COUNCIL Ted R Moreno Janice C.Guy Robert L.Richardson 20 CIVIC CENTER PLAZA• P.O.BOX 1988 SANTA ANA,CALIFORNIA 92702 March 23 , 1994 Smith Barney Shearson Inc. , as representative 333 South Grand Avenue Fifty-first Floor Los Angeles, California 90071 Municipal Bond Investors Assurance Corporation 113 King Street Armonk, New York 10504 Orrick, Herrington & Sutcliffe 777 South Figueroa Street, Suite 3200 Los Angeles, California 90017 Re: Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A Ladies and Gentlemen: We have acted as counsel to the City of Santa Ana (the "City") in connection with the issuance by the Santa Ana Financing Authority (the "Authority") of the bonds referenced in the caption hereto (the "Bonds") pursuant to Articles 1, 2 and 4 of Chapter 5 of Division 7 of Title 1 of the Government Code of the State of California (the "Law") , and Resolution No. 94-001 SAFA, adopted by the Authority on February 22 , 1994 . We have examined the Law and such certified proceedings and other papers as we deem necessary to render this opinion. Capitalized terms used herein, unless otherwise defined, have the meanings assigned to such terms in the Purchase Contract, dated March 8, 1994 (the "Purchase Contract") , by and among the City, the Authority and Smith Barney Shearson Inc. , as representative of the underwriters. As to questions of fact material to our opinion, collectively we have relied upon representations of the City contained in the City Documents and Resolution No. 94-007 adopted by the City on February 22 , 1994 approving and authorizing the execution and delivery of the City Documents and approving the Official Statement (the "City Resolution") and in the certified proceedings and other certifications of public officials furnished CITY ATTORNEY - (714) 647-5201 FAX NO. (714) 647-6515 CS-679 Smith Barney Shearson Inc. , as representative Municipal Bond Investors Assurance Corporation Orrick, Herrington & Sutcliffe March 23 , 1994 Page 2 to us, without undertaking to verify such facts by independent investigation. Based upon our examination, we are of the opinion, as of the date hereof, that: (i) The City is .a municipal corporation duly organized and existing under the Constitution and laws of the State of California with full right, power and authority to execute, deliver and perform its obligations under the City Documents and the JPA Agreement and to carry out and consummate the transactions contemplated by the City Documents, the JPA Agreement and the Official Statement; (ii) By all necessary official action of the City, the City has duly authorized and approved the execution and delivery of, and the performance by the City of the obligations contained in the City Documents and the JPA Agreement and the City Documents and the JPA Agreement constitute the legally valid and binding obligations of the City and the Redevelopment Agency, as the case may be, enforceable against the Authority in accordance with their respective terms; (iii) The City Resolution has been duly adopted at a meeting of the governing body of the City, which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout and the resolution is in full force and effect and has not been modified, amended or rescinded; (iv) The City is not in default, nor has it been in default, as to principal or interest with respect to an obligation issued or incurred by the City, and the City is not and will not, in any manner which would materially adversely affect the transactions contemplated by the City Documents or the JPA Agreement, be in breach of or in default under any applicable constitutional provision, law, Charter provision (including, but not limited to, Section 1307 thereof) or administrative rule or regulation of the State or the United States of America, or any applicable judgment or decree or any trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the City is a party or is otherwise subject, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute, in any manner which would Smith Barney Shearson Inc. , as representative Municipal Bond Investors Assurance Corporation Orrick, Herrington & Sutcliffe March 23 , 1994 Page 3 materially adversely affect the transactions contemplated by the City Documents, a default or event of default under any such instrument; (v) The authorization, execution and delivery of the City Documents and compliance with the provisions of each of such agreements or instruments and of the JPA Agreement do not and will not, in any manner which would materially adversely affect the transactions contemplated by the City Documents or the JPA Agreement, conflict with or constitute a breach of or default under any applicable constitutional provision, law, Charter provision (including, but not limited to, Section 1307 thereof) or administrative rule or regulation of the State or the United States of America, or any applicable judgment, decree, license, permit, trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the City (or any of its officers in their respective capacities as such) is subject, or by which it or any of its properties is bound, nor will any such authorization, execution, delivery or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of its assets or properties or under the terms of any such law, regulation or instrument, except as may be provided by the City Documents or the JPA Agreement; (vi) The information in the Official Statement under the captions "THE CITY, " and "LITIGATION, " is true and accurate to the best of my knowledge at and as of the date hereof; (vii) All authorizations, approvals, licenses, permits, consents and orders of or filings with any governmental authority, legislative body, board, agency or commission having jurisdiction in the matters which are required for the due authorization of, which would constitute a condition precedent to or the absence of which would materially adversely affect the due performance by the City of its obligations in connection with, the City Documents and the JPA Agreement have been duly obtained or made, except as may be required under the Blue Sky or securities laws of any state in connection with the offering and sale of the Bonds; (viii) No action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, is pending or, to the Smith Barney Shearson Inc. , as representative Municipal Bond Investors Assurance Corporation Orrick, Herrington & Sutcliffe March 23 , 1994 Page 4 best knowledge of the City after due investigation, threatened (i) in any way questioning the existence of the City or the titles of the officers of the City to their respective offices; (ii) affecting, contesting or seeking to prohibit, restrain or enjoin the execution or delivery of any of the Bonds, or in any way contesting or affecting the validity of the Bonds, the City Documents or the JPA Agreement or the consummation of the transactions contemplated thereby, or contesting the exclusion of the interest component of Base Rental payments from gross income for federal income tax purposes or contesting the powers of the City to enter into the City Documents or the JPA Agreement; (iii) which may result in any material adverse change to the financial condition of the City or to its ability to pay the Base Rental payments when due; or (iv) contesting the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto or asserting that the Preliminary Official Statement or the Official Statement contained any untrue statement of a material fact or omitted to state any material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, provided, however, that no opinion is given as to information contained under the caption "BOND INSURANCE" or in APPENDIX F thereto, and there is no basis for any action, suit, proceeding, inquiry or investigation of the nature described in clauses (i) through (iv) of this sentence; and (ix) Nothing has come to my attention which would lead such counsel to believe that the Official Statement (excluding therefrom the financial and statistical data and forecasts included therein, as to which non opinion need be expressed) contains any untrue statement of a material fact or omits to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. (x) The exceptions set forth in the title insurance policies delivered with respect to the Leased Property, as defined in the Lease, constitute Permitted Encumbrances, as defined in the Lease, and such exceptions do not materially impair the use of the Project, as defined in the Lease, the existing facilities and the real property constituting the Leased Property, for the purposes for which they are, or may reasonably be expected to be, held. Smith Barney Shearson Inc. , as representative Municipal Bond Investors Assurance Corporation Orrick, Herrington & Sutcliffe March 23, 1994 Page 5 Very truly yours, Edward./ foop_r City Attor- - LAW OFFICES BURKE, WILLIAMS & SORENSEN VENTURA COUNTY OFFICE 611 WEST SIXTH STREET,SUITE 2500 FRESNO OFFICE 2310 PONDEROSA DRIVE LOS ANGELES,CALIFORNIA 90017 7801 NORTH FRESNO STREET SUITE 1 SUITE 401 CAMARILLO,CALIFORNIA 03010 12131 236-0600 FRESNO,CALIFORNIA 93720-2038 18061987-3488 1208)281-0103 ORANGE COUNTY OFFICE TELECOPIER: (2131 236-2700 BURKE,WILLIAMS,SORENSEN&GAM 3200 BRISTOL STREET LIOHTON PLAZA SUITE 840 7300 COLLEGE BOULEVARD COSTA MESA,CALIFORNIA 82828 SUITE 220 (7141 646-6660 OVERLAND PARK,KANSAS 88210 1913)339-8200 March 23, 1994 City of Santa Ana Santa Ana Financing Authority 20 Civic Center Drive Santa Ana, California 92701 $107,399,438.50 Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A Ladies and Gentlemen: We have acted as special counsel to Meridian Trust Company of California, in connection with its serving as Trustee (the "Trustee") under that certain Indenture of Trust dated as of March 1, 1994 (the "Indenture"), by and between Santa Ana Financing Authority (the "Authority") and the Trustee, relating to the captioned Bonds (the "Bonds"). Capitalized terms used herein and not otherwise defined shall have the meaning assigned to them in the Indenture unless as the context otherwise requires. Acceptance of this opinion by you shall conclusively operate as acknowledgment that this opinion letter addresses all of the specific legal issues that are to be dealt with in our opinions set forth herein. In rendering these opinions, we have examined and relied with your express permission upon such corporate records, original documents, including the Indenture and the Assignment Agreement (as defined below) and certificates of public officials and of the Trustee as we have deemed necessary for the purpose of rendering the opinions set forth below. We have assumed without independent investigation or verification (i) the genuineness of all signatures to all documents and other papers (other than the signatures of the Trustee to the Indenture and the Assignment Agreement), (ii) the authenticity of all documents submitted to us as originals, (iii) the conformity to original documents of all documents submitted to us as copies, (iv) other than for the Trustee's entry into the Indenture and the Assignment Agreement, each entity has the power to enter into and perform all its obligations thereunder, the due LAX:87219.1 Municipal Blond Investors Assurance Corporation 113 King Street Armonk,NY 10504 914 273 4545 March 23, 1994 City of Santa Ana frida, /1 20 Civic Center Plaza Vi Santa Ana, California 92702 Smith Barney Shearson Inc. 333 South Grand Avenue Los Angeles, California 90071 $107,399,438.50 (Original Principal Value) $108,255,000 (Maturity Value) Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds Series 1994A Ladies and Gentlemen: I am Assistant General Counsel of the Municipal Bond Investors Assurance Corporation, a New York corporation (the "Corporation"), and have acted as counsel to the Corporation in connection with the issuance of Financial Guaranty Insurance Policy No. 15491 (the "Policy") relating to $107,399,438.50 (Original Principal Value) $108,255,000 (Maturity Value) Santa Ana Financing Authority, Police Administration and Holding Facility, Lease Revenue Bonds, Series 1994A. In so acting, I have examined a copy of the Policy and such other relevant documents as I have deemed necessary. Based upon the foregoing, I am of the following opinion: 1. The Corporation is a stock insurance corporation, duly incorporated and validly existing under the laws of the State of New York and is licensed and authorized to issue the Policy under the laws of the State of New York and its policy form may be used in the State of California. 2. The Policy has been duly executed and is a valid and binding obligation of the Corporation enforceable in accordance with its terms except that the enforcement of the Policy may be limited by laws relating to bankruptcy, insolvency, reorganization, moratorium, receivership and other similar laws affecting creditors' rights generally and by general principles of equity (regardless of whether such enforceability is considered in a proceeding in equity or at law). V` ruly yours, Pauline M. Cullen Assistant General Counsel Municipal Bond Investors Assurance Corporation 113 King Street Armonk.NY 10504 914 273 4545 - - March 23, 1994 City of Santa Ana �a■ /� 20 Civic Center Plaza V'� Santa Ana, California 92702 Smith Barney Shearson Inc. 333 South Grand Avenue Los Angeles, California 90071 $107,399,438.50 (Original Principal Value) $108,255,000(Maturity Value) Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds Series 1994A Ladies and Gentlemen: I am Assistant General Counsel of the Municipal Bond Investors Assurance Corporation, a New York corporation (the "Corporation"), and have acted as counsel to the Corporation in connection with the issuance of Financial Guaranty Insurance Policy No. 15491 (the "Policy") relating to $107,399,438.50 (Original Principal Value) $108,255,000 (Maturity Value) Santa Ana Financing Authority, Police Administration and Holding Facility, Lease Revenue Bonds, Series 1994A. In so acting, I have examined a copy of the Policy and such other relevant documents as I have deemed necessary. Based upon the foregoing, I am of the following opinion: 1. The Corporation is a stock insurance corporation, duly incorporated and validly existing under the laws of the State of New York and is licensed and authorized to issue the Policy under the laws of the State of New York and its policy form may be used in the State of California. 2. The Policy has been duly executed and is a valid and binding obligation of the Corporation enforceable in accordance with its terms except that the enforcement of the Policy may be limited by laws relating to bankruptcy, insolvency, reorganization, moratorium, receivership and other similar laws affecting creditors' rights generally and by general principles of equity (regardless of whether such enforceability is considered in a proceeding in equity or at law). Very truly yours, Pauline M. Cullen Assistant General Counsel ONE WORLD TRADE CENTER BROWN & WOOD BIS CONNECTICUT AVENUE,N.W. NEW YORK, N.Y. 10048-0557 WASHINGTON,D.C. 20006-4004 TELEPHONE: 212-839-5300 TELEPHONE: 202-973-0600 FACSIMILE: 212-S39-5599 10900 WI LSHI RE BOULEVARD FACSIMILE: 202-223-0465 Los ANGELES, CALIFORNIA 9002 4-39 5 9 S55 CALIFORNIA STREET 172 WEST STATE STREET SAN FRANCISCO, CA. 94104-171S TELEPHONE:310-443-0200 TRENTON, N.J. OB60E1-1104 TELEPHONE: 415-772-1200 FACSIMILE: 310-20B-5740 TELEPHONE: 609- 393-0303 FACSIMILE: 415-397-4521 FACSIMILE: 609-393-1990 SHIROYAMA JT MORI BUILDING, 15TH FLOOR BLACKWELL HOUSE 3-I, TORANOMON 4-CHOME, MINATO-KU GUILDHALL YARD TOKYO 105, JAPAN LONDON EC2V BAB TELEPHONE: 03-647 2-5380 TELEPHONE: 071-606-1888 FACSIMILE: 03-S472-5050 FACSIMILE: O>I-)BB-1 BO> March 23, 1994 Smith Barney Shearson Inc. , as representative 1345 Avenue of the Americas New York, New York 10105 $107, 399,438 . 50 Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds Series 1994A Ladies and Gentlemen: We have acted as counsel for you, Smith Barney Shearson Inc . in your capacity as representative (the "Representative" ) of the underwriters listed on the execution page of the Purchase Contract (the "Purchase Contract") , dated March 8, 1994, by and among Smith Barney Shearson Inc . , as Representative, the Santa Ana Financing Authority (the "Authority" ) and the City of Santa Ana (the "City" ) , in connection with the sale of the Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A in the aggregate principal amount of $107, 399, 438 . 50 (the "Bonds") . We have as such counsel examined originals, or copies certified or otherwise identified to our satisfaction, of such documents, records and other instruments as we deemed necessary or appropriate for the purpose of this opinion. In rendering our opinion herein, we are not expressing any opinion or view on the validity, accuracy or sufficiency of documents, certificates or opinions that we have examined or on the authorization, issuance, delivery or validity of the Bonds nor the exclusion from gross income for Federal income tax purposes or the exemption from taxation in the State of California of interest on the Bonds . Further, we have assumed, but not independently verified, that the signatures of all documents, certificates and opinions that we have reviewed are genuine. Smith Barney Shearson Inc. , as representative March 23 , 1994 Page 2 Based on and subject to the foregoing, we are of the opinion that the Bonds are exempt from registration under the Securities Act of 1933 , as amended and that the Indenture, dated as of March 1, 1994 , by and between the Authority and Meridian Trust Company of California, as trustee, is exempt from qualification under the Trust Indenture Act of 1939, as amended. Without having undertaken to determine independently the accuracy, completeness or fairness of the statements contained in the Official Statement, dated March 8, 1994 relating to the Bonds (the "Official Statement") , we cannot make any representation to you concerning the accuracy, completeness or fairness of such statements, but based upon the information made available to us in the course of our participation in the preparation of the Official Statement, as counsel to the Representative, nothing has come to our attention to lead us to believe that the Official Statement (excluding therefrom the reports, financial and statistical data and forecasts therein and information relating to The Depository Trust Company and its book-entry system, information relating to Municipal Bond Investors Assurance Corporation and the municipal bond insurance policy provided thereby as to which we express no opinion) as of the date hereof contains any untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. This opinion is furnished by us to you solely for your benefit and we are not assuming any professional responsibility to any other person whomsoever. This opinion is not to be used, circulated, quoted or otherwise referred to for any other purpose . Respectfully submitted, ,cvkvk. £. L,Ocrec9- 2 • O RRICK, HERRINGTON & SUTCLIFFE March 23, 1994 Smith Barney Shearson Inc. 333 South Grand Avenue, Fifty-First Floor Los Angeles, California 90071 Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A (Supplemental Opinion) Ladies and Gentlemen: This letter is addressed to you, as representative of the Underwriters, pursuant to Section 7(e)(2) of the Purchase Contract, dated March 8, 1994 (the "Purchase Contract"), between you, the City of Santa Ana (the "City") and the Santa Ana Financing Authority (the "Issuer"), providing for the purchase of $107,399,432.50 aggregate principal amount of Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A (the "Bonds"). The Bonds are being issued pursuant to an Indenture, dated as of March 1, 1994 (the "Indenture"), between the Issuer and Meridian Trust Company of California, as trustee (the "Trustee"). Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the Indenture or, if not defined in the Indenture, in the Purchase Contract. We have delivered our final legal opinion (the "Bond Opinion") as bond counsel concerning the validity of the Bonds and certain other matters, dated the date hereof and addressed to the Issuer. You may rely on such opinion as though the same were addressed to you. In connection with our role as bond counsel, we have reviewed the Purchase Contract, the Indenture, opinions of counsel to the Issuer and the City, certificates of the Issuer, the City, the Trustee and others, and such other documents, opinions and matters to the extent we deemed necessary to provide the opinions or conclusions set forth herein. The opinions or conclusions expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such opinions may be affected by actions taken or omitted or events occurring after the date hereof. We have not undertaken to determine, or to inform any person, whether any such actions are taken or omitted or events do occur. We have assumed the genuineness of all documents and signatures presented to us (whether as originals or as copies) LA1-70770.1 777 South Figueroa Street • Los Angeles, California 90017 Telephone 213 629 2020 • Facsimile 213 612 2499 San Francisco 415 392 1122 • New York 212 326 8800 • Sacramento 916 447 9200 QRRICK,HERRINGTON & SUTCLIFFE Smith Barney Shearson Inc. March 23, 1994 Page 2 and the due and legal execution and delivery thereof by, and validity against, any parties other than the Issuer. We have not undertaken to verify independently, and have assumed, the accuracy of the factual matters represented, warranted or certified in the documents, and of the legal conclusions contained in the opinions of counsel to the Issuer and the City, referred to in the third paragraph hereof. We have further assumed compliance with all covenants and agreements contained in such documents. In addition, we call attention to the fact that the rights and obligations under the Bonds, the Indenture, the Tax Certificate, the Lease, the Ground Lease and the Purchase Contract may be subject to bankruptcy, insolvency, reorganization, arrangement, fraudulent conveyance, moratorium and other laws relating to or affecting creditors' rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against municipal corporations in the State of California. We express no opinion with respect to any indemnification, contribution, choice of law, choice of forum or waiver provisions contained therein. Based on and subject to the foregoing, and in reliance thereon, as of the date hereof, we are of the following opinions or conclusions: 1. The Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Indenture is exempt from qualificatin pursuant to the Trust Indenture Act of 1939, as amended. 2. The Purchase Contract, the Ground Lease and the JPase have been duly authorized, executed and delivered by the Issuer and (assuming due authorization, execution and delivery by and validity against the respective parties thereto) are valid and binding agreements of the Issuer; provided, however, that no opinion is expressed with respect to the effect of Section 1307 of the City's Charter on the Lease and the Ground Lease. 3. The statements contained in the Official Statement, dated March 23, 1994, with respect to the Bonds (the "Official Statement"), under the captions "THE BONDS," "SECURITY FOR THE BONDS," "CERTAIN TAX MA TIERS," "APPENDIX A - DEFINITIONS AND SUMMARY OF PRINCIPAL LEGAL DOCUMENTS," "APPENDIX G - SUMMARY OF CERTAIN PROVISIONS RELATING TO THE AIRS" insofar as such statements summarize certain provisions of the Indenture, the JPase, the Ground Lease, the Assignment Agreement, the Auction Agent Agreement, the Market Agent Agreement, the Broker-Dealer Agreement and our Bond Opinion concerning certain federal tax matters relating to the Bonds, are accurate in all material respects. LA1-70770.1 O RRICK,HERRINGTON & SUTCLIFFE Smith Barney Shearson Inc. March 23, 1994 Page 3 This letter is furnished by us as bond counsel. No attorney-client relationship has existed or exists between our firm and you in connection with the Bonds or by virtue of this letter. We disclaim any obligation to update this letter. This letter is delivered to you as representative of the Underwriters of the Bonds, is solely for your benefit as such representative of the Underwriters and is not to be used, circulated, quoted or otherwise referred to or relied upon for any other purpose or by any other person. This letter is not intended to, and may not, be relied upon by owners of the Bonds. Very t ly-yo s, f:g(& ORRICK, HERRI TON S CLIFFE LA1-70770.1 O RRICK, HERRINGTON & SUTCLIFFE March 23, 1994 Santa Ana Financing Authority 20 Civic Center Plaza Santa Ana, California 92710 Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds. Series 1994A (Final Opinion) Ladies and Gentlemen: We have acted as bond counsel in connection with the issuance by the Santa Ana Financing Authority (the "Issuer") of $107,399,438.50 aggregate principal amount of Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds,Series 1994A(the "Bonds"), issued pursuant to the provisions of the Marks-Roos Local Bond Pooling Act of 1985 (constituting Article 4 of Division 7 of Title 1 of the California Government Code) and an Indenture, dated as of March 1, 1994 (the "Indenture"), between the Issuer and Meridian Trust Company of California, as trustee (the "Trustee"). The Bonds are issued for the purpose of enabling the Issuer to finance certain capital improvements. Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the Indenture. In such connection, we have reviewed the Indenture, the Tax Certificate of the Issuer and the City of Santa Ana (the "City") dated the date hereof (the "Tax Certificate"), certifications of the Issuer, the Trustee, the City, and others, opinions of counsel to the Issuer, the City, the Trustee and such other documents, opinions and matters to the extent we deemed necessary to render the opinions set forth herein. Certain agreements, requirements and procedures contained or referred to in the Indenture, the Tax Certificate and other relevant documents may be changed, and certain actions (including, without limitation,defeasance of the Bonds)may be taken or omitted under the circumstances and subject to the terms and conditions set forth in such documents. No opinion is expressed herein as to any Bond or the interest thereon if any such change occurs or action is taken or omitted to be taken upon the advice or approval of counsel other than ourselves. The opinions expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such opinions may be affected by actions taken or omitted to be taken or events occurring after the date hereof. We have not undertaken to determine, or to inform any person, whether any such actions or events are taken or do occur. We have assumed the genuineness of all documents and signatures presented to us. 777 South Figueroa Street • Los Angeles, California 90017 Telephone 213 629 2020 • Facsimile 213 612 2499 San Francisco 415 392 1122 • New York 212 326 8800 • Sacramento 916 447 9200 LA1-68714.1 O RRICK,HERRINGTON & SUTCLIFFE Santa Ana Financing Authority March 23, 1994 Page 2 We have not undertaken to verify independently, and have assumed, the accuracy of the factual matters represented, warranted or certified in the documents referred to in the second paragraph hereof. Furthermore, we have assumed compliance with all covenants and agreements contained in the Indenture and the Tax Certificate, including(without limitation)covenants and agreements compliance with which is necessary to assure that future actions, omissions or events will not cause interest on the Bonds to be included in gross income for federal income tax purposes. We call attention to the fact that the rights and obligations under the Bonds and the Indenture are subject to bankruptcy, insolvency, reorganization, arrangement, fraudulent conveyance, moratorium and other laws relating to or affecting creditors' rights, to the application of equitable principles and to the exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against political subdivisions in the State of California. We express no opinion with respect to any indemnification, contribution or choice of law provisions contained in the documents referred to herein. Finally,we undertake no responsibility for the accuracy, completeness or fairness of the Official Statement or other offering material relating to the Bonds and express no opinion relating thereto. Further, neither the faith and credit nor the taxing power of the City or the State of California or any political subdivision thereof is pledged to the payment of the principal of or interest on the Bonds. The Bonds are not a debt of the City or the State of California, and neither said State, nor the City is liable for the payment thereof. Based on and subject to the foregoing, and in reliance thereon, as of the date hereof, we are of the following opinions: 1. The Bonds constitute the valid and binding limited obligations of the Issuer. 2. The Indenture has been duly authorized, executed and delivered by, and constitutes the valid and binding obligation of, the Issuer. The Indenture creates a valid pledge,to secure the payment of the principal of and interest on the Bonds, of the Revenues and any other amounts (including proceeds of the sale of the Bonds) held by the Trustee in any fund or account established pursuant to the Indenture (except the Rebate Fund), subject to the provisions of the Indenture permitting the application thereof for the purposes and on the terms and conditions set forth in the Indenture. 3. The Bonds are not a lien or charge upon the funds or property of the Issuer except to the extent of the aforementioned pledge. 4. Interest on the Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986, and is exempt from State of California personal income taxes. Interest on the Bonds is not a specific preference item for purposes of the federal individual or corporate alterative minimum taxes, although we observe that it is included in adjusted LA168714.1 SANTA ANA FINANCING AUTHORITY POLICE ADMINISTRATION AND HOLDING FACILITY LEASE REVENUE BONDS, SERIES 1994A CLOSING MEMORANDUM The following memorandum will summarize the procedures to be followed in completing the sale of $107,399,438.50 aggregate principal amount of Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A (the "Bonds"). Time and Place The closing will be held at the offices of Orrick, Herrington & Sutcliffe, 777 South Figueroa Street, 32nd Floor, Main Conference Room, Los Angeles, California, beginning at 8:00 a.m., California time, on March 23, 1994 (the "Closing"). A preclosing review will be held at the same location beginning at 1:00 p.m. on March 22, 1994, to confirm that all documents and papers are on hand, in proper form and properly executed (the "Preclosing"). Parties The following parties are expected to be present or represented at the Preclosing and at the Closing: Santa Ana Financing Authority ("Authority"); City of Santa Ana ("City"); Meridian Trust Company of California ("Trustee"); Smith Barney Shearson Inc., as representative of the underwriters ("Underwriter"); Kelling, Northcross & Nobriga ("Financial Advisor"); Edward J. Cooper, Esq. ("Authority Counsel" and "City Attorney"); Orrick, Herrington & Sutcliffe ("Bond Counsel"); Brown & Wood ("Underwriters' Counsel"); and Municipal Bond Investors Assurance Corporation ("MBIA"). LA1-69935.3 The parties will deliver the respective documents indicated below in ten (10) copies. Documents will be executed in advance of the Closing by the respective parties thereto. All deliveries will be deemed to have been made in escrow until final delivery at the Closing. Responsibility for preparing, assembling or delivering the documents is indicated in parentheticals. LA I-69935.3 11 $107,399,438.50 SANTA ANA FINANCING AUTHORITY POLICE ADMINISTRATION AND HOLDING FACILITY LEASE REVENUE BONDS, SERIES 1994A TRANSCRIPT INDEX Legal Documents 1. Indenture, dated as of March 1, 1994 (executed by the Authority and the Trustee) (Bond Counsel). 2. Ground Lease, dated as of March 1, 1994 (executed by the City and the Authority) (Bond Counsel). 3. Lease, dated as of March 1, 1994 (executed by the Authority and the City) (Bond Counsel). 4. Assignment Agreement, dated as of March 1, 1994 (executed by the Authority and the Trustee) (Bond Counsel). 5. Auction Agent Agreement, dated as of March 1, 1994, by and between the Trustee and the Bank of New York, as Auction Agent (Bond Counsel). 6. Market Agent Agreement, dated as of March 1, 1989, by and between Smith Barney Shearson Inc., as Market Agent and the Trustee (Bond Counsel). 7. Broker-Dealer Agreement, dated as of March 1, 1994, by and between the Bank of New York, as Auction Agent and Smith Barney Shearson Inc., as Broker-Dealer (Bond Counsel). Documents Relating to the Sale of the Bonds 8. Purchase Contract, dated March 8, 1994 (executed by the Managing Underwriter, Authority and City) (Underwriters' Counsel). 9. Preliminary Official Statement, dated February 25, 1994 (Underwriters' Counsel). 10. Official Statement (Underwriters' Counsel). 11. Rule 15c2-12 Certificates, dated February 25, 1994 (Underwriters' Counsel). 12. Preliminary and Supplemental Blue Sky Memoranda (Underwriters' Counsel). LA1-69935.3 Ili Documents Relating to the Authority 13. Joint Exercise of Powers Agreement, dated as of August 1, 1993, together with Authority Bylaws (certified by the Secretary of the Authority; conformed copies) (Authority Counsel). 14. Resolution No. 94-001 SAFA of the Authority approving the forms of and authorizing the execution and delivery by the Authority of a Ground Lease, a Lease, an Indenture and a Purchase Contract, authorizing the execution and sale of the Bonds, authorizing and approving the distribution of the Official Statement in connection therewith, authorizing and approving execution of necessary documents and related actions (certified by the Secretary of the Authority) (Authority Counsel). 15. Notice filed with Secretary of State pursuant to Section 6503.5 of the California Government Code (Bond Counsel). 16. Certificate of the Authority (Bond Counsel). 17, Signature and Bond Delivery Certificate of the Authority (Bond Counsel). Documents Relating to City 18. Resolution No. 94-007 of the City approving a form of Ground Lease, Lease and Purchase Contract; making certain determinations relating thereto; and authorizing certain other actions in connection therewith (certified by City Clerk) (City Attorney). 19. Certificate of the City (Bond Counsel). 20. Signature and Incumbency Certificate of the City (Bond Counsel). Documents Relating to the Trustee 21. Certificate of the Trustee, together with Authorizing Resolution and Incumbency Certificate (Trustee and Bond Counsel). 22. Trustee's Certificate of Deposit and Receipt (Bond Counsel). LA1-69935.3 iv Closing Documents 23. Written request of the Authority regarding delivery of Bonds (Bond Counsel). 24. Tax Certificate, together with exhibits thereto (executed by Authority, City, Financial Advisor and Managing Underwriter) (Bond Counsel). 25. Receipt for Purchase Price (Bond Counsel). 26. Receipt for the Bonds (Bond Counsel). 27. DTC Letters of Representations (Bond Counsel). 28. Rating Letters (MBIA). 29. Specimen Bonds (Bond Counsel). 30. California Debt Advisory Commission Notices (Bond Counsel). 31. Internal Revenue Service Form 8038-G (Bond Counsel). 32. Requisition No. 1 re Costs of Issuance (Bond Counsel). 33. Title Insurance (City). 34. Insurance Certificate (City). Documents Relating to Insurer 35. Municipal Bond Insurance Policy (MBIA). 36. Tax Certificate of Insurer (MBIA). 37. Insurer's Certificate relating to the Official Statement (MBIA), Legal Opinions 38. Opinion of Authority Counsel (Authority Counsel). 39. Opinion of City Attorney (City Attorney). 40. Opinion of Trustee Counsel. LA1-69935.3 - V 41. Opinion of Counsel to Insurer (MBIA). 42. Opinion of Counsel to Underwriters (Underwriters' Counsel). 43. Supplemental Opinion of Bond Counsel (Bond Counsel). 44. Final Opinion of Bond Counsel (Bond Counsel). Miscellaneous 45. Closing Memorandum (Bond Counsel). LAI-69935.3 - Vi Closing As soon as practicable after the Closing, each of the parties will receive a copy of each of the documents listed above, subsequent to the following_events: A. The Managing Underwriter will wire transfer to the Trustee the aggregate amount of $109,504,139.27 in immediately available funds (representing $107,399,438.50 aggregate principal amount of the Bonds, plus $3,657,901.15 of original issue premium, plus $315,258.63 in accrued interest, less an underwriter's discount of $777,459.01 less municipal insurance premium of$1,091,000.00). B. The Managing Underwriter will wire transfer to MBIA the municipal bond insurance premium in the amount of$1,091,000.00. C. The Trustee will release to the Managing Underwriter the Bonds in the aggregate principal amount of $107,399,438.50. LAI-69935.3 Vn