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HomeMy WebLinkAboutMINUTES - 04221997 - C89 V TO: BOARD OF SUPERVISORS 5E--L. Contra FROM: J/ Costa Phil Batchelor ._ County DATE: April 22, 1997 s � SUBJECT: 1997-1998 TAX AND REVENUE ANTICIPATION NOTE BORROWING PROGRAM SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: 1. Adopt resolution prepared by the Bond Counsel authorizing the 1997-1998 Tax and Revenue Anticipation Note Borrowing Program and approving the necessary documents. 2. Approve and authorize the sale of the Notes using a competitive sale and authorize the County Administrator, in consultation with the financial advisor and bond counsel, to retain the flexibility to proceed with a negotiated sale if the market conditions require it. 3. Approve and authorize the County Administrator or his designee to carry out the necessary actions to complete the 1997-1998 Tax and Revenue Anticipation Note borrowing, including execution of necessary consultant and service agreements. 4. Approve continuation of Fulbright & Jaworski, L.L.P. for the required Disclosure Counsel for the issue at a fixed fee of $4,490. 5. Approve continuation of C.M. DeCrinis & Co. , Inc. as the Financial Advisor for the issue for a fixed fee plus reimbursement of expenses related to the issue. Jean Buckley from the DeCrinis firm has advised the County on the Note issues for the past several years. 6. Approve continuation of U.S. Trust as the Trustee/Paying Agent for the issue for a fee of $750.00 plus minor transaction fees. 7. Approve continuation of Orrick, Herrington & Sutcliffe as the Bond and Tax Counsel for the issue at a fixed fee plus expenses. CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURE(S): ACTION OF BOARD ON April 22 , 1997 APPROVED AS RECOMMENDED XX_ OTHER VOTE OF SUPERVISORS XX _ _ _ I HEREBY CERTIFY THAT THIS IS A TRUE UNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN. ATTESTED April 22 , 1997 Contact: PHIL BATCHELOR,CLERK OF THE BOARD OF cc: SEE PAGE 2 SUPERVISORS AND COUNTY ADMINISTRATOR �Q I BY DEPUTY -2- 8. Direct that the property tax apportionment advances required under the Teeter Plan be included in the Tax and Revenue Anticipation Note program as was done for 1996-1997. 9. Direct, to the extent feasible and economically advantageous, that requirements for the self-insurance and employee benefits programs be included in the annual Note program borrowing. FINANCIAL IMPACTS: The annual program for Tax and Revenue Anticipation Note borrowing has become an essential part of the cash management for the County. It is required in order to meet the cash flow needs during the fiscal year. The expenses of the program are paid from revenues generated by the program and revenues generated in excess of the expenses are available to the General Fund. For the past two years Contra Costa County has had the lowest borrowing rate for the Note program of any county in California. BACKGROUND: The County has issued Notes for cash flow borrowing needs every year since 1979. During 1996 the County issued notes for $120,000,000. The amount of borrowing is based upon the maximum cash flow deficit as projected by the Auditor-Controller and is carefully regulated by the Internal Revenue Service. It is essential that the proposed issue be reviewed by an expert, experienced tax counsel in order to fully comply with the complex IRS rules. Orrick, Herrington & Sutcliffe is a recognized leader in this area. They have many years of experience with our County and are able to accomplish the legal work for a very low fee. The changes to the issuance requirements and market demands resulting from the Orange County bankruptcy have required the county to include a Disclosure Counsel and an outside Trustee/Paying Agent on the financing team for the past two years. These services are at low cost and will be an on-going requirement. The County, for the first time in 1996-1997, included in the TRAN program a component to assist in the financing for the cash flow requirements of the Teeter Plan. Under the Teeter Plan, which was pioneered in this County in 1951 by the first County Administrator, Desmond Teeter, each taxing jurisdiction (county, cities, schools, districts, etc.) receives 100% of the property taxes levied on their behalf in the current fiscal year though a portion of these taxes may remain delinquent. The amounts advanced in excess of actual collections have, in prior years, been financed within the County Treasurer's pool of available cash resources. The Treasurer is ultimately reimbursed when the delinquencies (plus penalties and interest) are collected from the property owner or through proceeds of a tax sale. Incorporation of the advances required under the Teeter Plan in the Note Program has eliminated the internal borrowing procedure and generated additional revenues of an estimated $300,000 to $500,000. Studies have been underway for several months to include cash requirements for the County self-insurance and employee benefit programs in the Note program to achieve similar savings and to better manage cash flows. To the extent that it is determined to economically advantageous these programs will be included in the 1997-1998 TRAN program. The consultant team has been working with County staff for some time preparing for the Tax and Revenue Anticipation Program and are proceeding with a planned sale date of June 3, 1997. Contact: D. Bell 335-1093 cc: County Administrator Auditor-Controller Treasurer-Tax Collector C.M. DeCrinis & Co. , Inc. (via CAO) Orrick, Herrington & Sutcliffe (via CAO) Fulbright & Jaworski, L.L.P. (via CAO) County Counsel RESOLUTION NO. 9 7/2 0 7 OF THE BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA CALIFORNIA RESOLUTION APPROVING ISSUANCE AND SALE OF 1997-1998 TAX AND REVENUE ANTICIPATION NOTES OF THE COUNTY; APPROVING FORMS AND EXECUTION OF A TRUST AGREEMENT, OFFICIAL NOTICE OF SALE, NOTICE OF INTENTION TO SELL NOTES AND CONTINUING DISCLOSURE CERTIFICATE; APPROVING FORM OF AND DISTRIBUTION OF PRELIMINARY OFFICIAL STATEMENT FOR THE SALE OF SAID NOTES; DELEGATING TO COUNTY ADMINISTRATOR OR HIS DESIGNEE AUTHORIZATION TO AWARD BIDS FOR SAID NOTES; AND AUTHORIZING TAKING OF NECESSARY ACTIONS AND EXECUTION OF NECESSARY CERTIFICATES WHEREAS, the County of Contra Costa (the "County") is a political subdivision of the State of California; WHEREAS, pursuant to Sections 53850 et seq. of the Government Code of the State of California (the "Government Code"), this Board of Supervisors (the 'Board") has found and determined that the sum of not to exceed One Hundred Fifty Million Dollars ($150,000,000) is needed for the requirements of the County of Contra Costa (the "County") to satisfy obligations payable from the General Fund and that it is necessary that said sum be borrowed for such purpose at this time by the issuance of temporary notes (the "Notes") therefor in one or more series in anticipation of the receipt of taxes, revenue and other moneys to be received by the County for the General Fund of the County allocable to Fiscal Year 1997-1998; and WHEREAS, it appears, and the Board hereby finds and determines, that said sum of One Hundred Fifty Million Dollars ($150,000,000), when added to the interest estimated to be payable thereon, does not exceed eighty-five percent (85%) of the estimated amount of the uncollected taxes, income, revenue, cash receipts and other moneys of the County for the General Fund of the County attributable to Fiscal Year 1997-1998 and available for the payment of the principal of and interest on the Notes; WHEREAS, no money has heretofore been borrowed by the County through the issuance of any temporary notes in anticipation of the receipt of, or payable or secured by, taxes, income, revenue, cash receipts or other moneys of the County received or accrued during or allocable to Fiscal Year 1997-1998; SF2-71793.2 WHEREAS, the County proposes to enter into a Trust Agreement, dated as of July 1, 1997, with U.S. Trust Company of California, N.A., as trustee (the "Trustee"), to provide for the issuance and payment of the Notes; WHEREAS, the County desires to authorize the issuance of the Notes in two series, with an initial issuance of a first series of notes (the "Series A Notes") in the month of July and an authorization to issue and sell a second series of notes (the "Series B Notes") prior to January 1, 1998; WHEREAS, the Series A Notes shall be sold to the highest bidder or bidders pursuant to a competitive sale to be held on June 3, 1997 or on such earlier or later date as is established by the County Administrator of the County in accordance with the terms of an Official Notice of Sale for the Notes; WHEREAS, a form of Official Statement describing the Notes and a form of an Official Notice of Sale for the sale of the Notes will be distributed to potential purchasers of the Notes and a form of Notice of Intention to Sell the Notes will be published in THE BOND BUYER; WHEREAS, this Board has been presented with the form of each document hereinafter referred to, relating to the Notes, and the Board has examined and approved each document and desires to authorize and direct the execution of such documents and the issuance of the Notes; WHEREAS, the County has full legal right, power and authority under the Constitution and the laws of the State of California to enter into the transactions hereinafter authorized; and NOW, THEREFORE, the Board of Supervisors of the County of Contra Costa hereby finds, determines, declares and resolves as follows: Section 1. Recitals. All of the recitals herein above set forth are true and correct, and this Board so finds and determines. Section 2. Trust Agreement. The proposed form of the Trust Agreement, to be dated as of July 1, 1997, by and between the County and the Trustee (a copy of which is on file with the Clerk of the Board of Supervisors), is hereby approved. The County Administrator of the County (the "County Administrator") and the Clerk of the Board of Supervisors, and their designees, are hereby authorized and directed to execute and deliver the Trust Agreement in substantially said form, with such changes, additions, completions and corrections therein as such officers may require or approve, such approval to be conclusively evidenced by the execution and delivery thereof. Section 3. Sale of Notes. The proposed form of the Official Notice of Sale for the Series A Notes, in substantially the form presented to this meeting (a copy of which is on file with the Clerk of the Board), is hereby approved and adopted as the Official Notice SF2-71793.2 2 of Sale for the Series A Notes, with such changes, additions, completions and corrections therein as the County Administrator shall require or approve. All of the Series A Notes shall be offered-for public sale in accordance with the Official Notice of Sale. C. M. de Crinis & Co., Inc. (the "Financial Advisor") is hereby authorized and directed to cause to be mailed to prospective bidders for the Series A Notes copies of said Official Notice of Sale, subject to such changes, additions and completions as may be acceptable to the County Administrator. The proposed form of the Notice of Intention to Sell Notes, in substantially the form presented to this meeting (a copy of which is on file with the Clerk of the Board), is hereby approved. The County Administrator is hereby directed to cause said Notice of Intention to Sell to be published once, no later than 15 days before the date of sale of the Series A Notes, in THE BOND BUYER, a financial publication generally circulated throughout the State of California. Sealed proposals shall be received by or on behalf of the County up to the hour of 10:00 a.m. California time on June 3, 1997 or on such earlier or later date determined by the County Administrator or his designee as set forth in the Official Notice of Sale, for the purchase of the Series A Notes for cash at not less than their principal amount and accrued interest thereon to the date of their delivery, the interest rate or rates (which shall not exceed 7% per annum) to be designated in the bid or bids, the County Administrator or his designee reserving the right to reject any and all bids, in accordance with the terms and conditions of said Official Notice of Sale. The County Administrator or his designee is hereby authorized to determine whether to accept partial bids in increments of a specified denominational amount, such as $25,000,000, and to award the Series A Notes to the highest responsible bidder or bidders resulting in the lowest net interest cost to the County or to reject any or all bids. If the Series A Notes are awarded to more than one bidder and at different rates of interest, each incremental amount of Notes of the same interest rate shall be given a separate designation. The County Administrator or his designee may, in his sole discretion, cancel the public sale of the Series A Notes and negotiate for the sale of the Series A Notes with an underwriter or underwriters, and enter into an agreement for the sale of the Series A Notes, upon such terms and conditions as he shall deem appropriate. The County Administrator or his designee is hereby authorized, subject to the requirements of the Trust Agreement and upon a determination it is in the best interests of the County, to sell the Series B Notes prior to January 1, 19989 by public or negotiated sale at not less than their principal amount at the interest rate or rates not to exceed 7% per annum. Section 4. Official Statement for Notes. The proposed form of official statement relating to the Series A Notes, in substantially the form presented to this meeting (a copy of which is on file with the Clerk of the Board), is hereby approved with such changes, additions, completions and corrections as the County Administrator or his designee may approve. The Financial Advisor is hereby authorized to distribute such official statement in preliminary form to the potential bidders for the Series A Notes and is hereby SF2-71793.2 3 authorized and directed to deliver such official statement in final form to the purchasers of the Series A Notes. The County Administrator or his designee is authorized to certify on behalf of the County that the preliminary form of the official statement is deemed final as of its date, within the meaning of Rule 15c2-12 promulgated under the Securities Exchange Act of 1934 (except for the omission of certain final pricing, rating and related information as permitted by said Rule). Section 5. Continuing Disclosure. The form of instrument, entitled "Continuing Disclosure Certificate," to be dated as of its date of execution, in substantially the form submitted to this meeting (a copy of which is on file with the Clerk of the Board), is hereby approved. The County Administrator or his designee is authorized and directed to execute and deliver an instrument in substantially said form, with such changes therein as such officer executing such instrument may require or approve, such approval to be conclusively evidenced by the execution and delivery thereof. Section 6. Approval of Actions. All actions heretofore taken by the officers and agents of the County or the Board with respect to the sale and issuance of the Notes are hereby approved, confirmed and ratified, and the officers of the County and the Board are hereby authorized and directed, for and in the name and on behalf of the County, to do any and all things and take any and all actions and execute any and all certificates, agreements and other documents which they, or any of them, may deem necessary or advisable in order to consummate the lawful issuance and sale of the Notes in accordance with this Resolution. PASSED AND ADOPTED by the Board of Supervisors of the County of Contra Costa, State of California, this 22nd day of April, 1997, by the following vote: AYES: Supervisors Rogers , Uilkema, Gerber, Canciamilla, DeSaulnier NOES: None ABSENT: None Chair of the Board of Supervisors of the County of Contra Costa (Seal) Attest: Philip J. Batchelor, County Administrator and Clerk of the Board of Supervisors of the County of Contra Costa By: Deputy Clerk SF2-71793.2 4 CLERK'S CERTIFICATE I, JEANNE O. MAGLIO, Deputy Clerk and Chief Clerk of the Board of Supervisors of the County of Contra Costa, hereby certify that the foregoing is a full, true and correct copy of a resolution duly adopted at a meeting of the Board of Supervisors of the County of Contra Costa duly and regularly held in Martinez, California, on April 22, 1997, of which meeting all of the members of said Board had due notice. I further certify that I have carefully compared the foregoing copy with the original minutes of said meeting on file and of record in my office; that said copy is a full, true and correct copy of the original resolution adopted at said meeting and entered in said minutes; and that said resolution has not been amended, modified, rescinded or revoked in any manner since the date of its adoption, and the same is now in full force and effect. I further certify that an agenda of said meeting was posted at least 72 hours before said meeting in the Lobby of 651 Pine St., Martinez, California, a location freely accessible to the public and a brief general description of the resolution to be adopted at said meeting appeared on said agenda. IN WITNESS WHEREOF, I have executed this certificate and affixed the seal of the Board of Supervisors of the County of Contra Costa hereto as of this6 th day of May 1997. By �-�� Deputy Clerk of and of Supervisors of the County of Contra Costa, State of California [SEAL] SP2-71793.2 AFFIDAVIT OF POSTING OF AGENDA STATE OF CALIFORNIA ) ) ss. COUNTY OF CONTRA COSTA ) C. S. Turner hereby declares that [s]he is a citizen of the United States of America, over the age of 18 years; that acting for the Board of Supervisors of the County of Contra Costa [s]he posted on Apr. 17, 1997 in the Lobby of 651 Pine Street, Martinez, California, a location freely accessible to members of the public, an agenda for the regular meeting of the Board of Supervisors of Contra Costa County to be held on April 22 , 1997, a copy of which is attached hereto. Dated: Apr- 1, 1997 I declare under penalty of perjury that the foregoing is true and correct. SF2-71793.2 OH&S SECOND DRAFT 04/21/97 TRUST AGREEMENT BY AND BETWEEN COUNTY OF CONTRA COSTA AND U.S. TRUST COMPANY OF CALIFORNIA, N.A., as Trustee RELATING TO COUNTY OF CONTRA COSTA, CALIFORNIA, 1997-1998 TAX AND REVENUE ANTICIPATION NOTES Dated as of July 1, 1997 sF2-71558.2 40511-103-NiAC44/21i97 This TRUST AGREEMENT, dated as of July 1, 1997, by and between the COUNTY OF CONTRA COSTA, a public body, corporate and politic, and a political subdivision of the State of California (the "County"), and U.S. TRUST COMPANY OF CALIFORNIA, N.A., a national banking association duly organized and existing under and by virtue of the laws of the United States of America, as Trustee and Paying Agent (the "Trustee"); WITNESSETH WHEREAS, pursuant to Sections 53850 et seq. of the Government Code of the State of California (the "Government Code"), the Board of Supervisors (the "Board") of the County has found and determined that the sum of not to exceed One Hundred Fifty Million Dollars ($150,000,000) is needed for the requirements of the County to satisfy obligations payable from the general fund and certain special reserve funds of the County (collectively the "General Fund") and that it is necessary that said sum be borrowed for such purpose by the issuance of temporary notes (the "Notes") therefor in one or more series in anticipation of the receipt of taxes, revenue and other moneys to be received by the County for the General Fund of the County allocable to Fiscal Year 1997-1998; and WHEREAS, it appears that said sum of One Hundred Fifty Million Dollars ($150,000,000), when added to the interest estimated to be payable thereon, does not exceed eighty-five percent (85%) of the estimated amount of the uncollected taxes, income, revenue, cash receipts and other moneys of the County for the General Fund of the County attributable to Fiscal Year 1997-1998 and available for the payment of the principal of and interest on the Notes; and WHEREAS, no money has heretofore been borrowed by the County through the issuance of any temporary notes in anticipation of the receipt of, or payable or secured by, taxes, income, revenue, cash receipts or other moneys of the County received or accrued during or allocable to Fiscal Year 1997-1998; and WHEREAS, pursuant to Section 53856 of the Government Code of the State of California (the "Government Code"), certain revenues which will be received by the County for the General Fund of the County and attributable to Fiscal Year 1997-1998 can be pledged for the payment of the principal of and interest on the Notes; WHEREAS, the County has authorized the issuance of the Notes in the amount not to exceed $150,000,000; WHEREAS, the execution and delivery of this Trust Agreement by and between the County and the Trustee and the issuance of the Notes hereunder have in all respects been duly and validly authorized by a resolution duly passed and approved by the Board of Supervisors of the County; and WHEREAS, the County represents that all acts, conditions and things required by law to exist, to have happened and to have been performed precedent to and in connection SF2-71558.2 40511-103-MAC-04121/97 with the execution and the entering into of this Trust Agreement do exist, have happened and have been performed in regular and due time, form and manner as required by law, and the parties hereto are now duly authorized to execute and enter into this Trust Agreement; Section 1. Authorization and Issuance. (A) Solely for the purpose of anticipating taxes, income, revenues, cash receipts and other moneys to be received by the County for the General Fund of the County allocable to Fiscal Year 1997-1998, and not pursuant to any common plan of financing, the County hereby determines to and shall borrow the aggregate principal sum of not to exceed One Hundred Fifty Million Dollars ($150,000,000), by the issuance of temporary notes in one or more series under Sections 53850 et seq. of the Government Code, designated the "County of Contra Costa, California, 1997-1998 Tax and Revenue Anticipation Notes". A first series of Notes labeled "Series A" (the "Series A Notes") shall be issued pursuant hereto in the aggregate principle amount of $ . A second series of Notes labeled "Series B" (the "Series B Notes") may hereafter be issued prior to January 1, 1998, by supplement to this Trust Agreement in an amount not to exceed $ (B) The Series A Notes shall be initially issued and registered as provided in Section 7 hereof and otherwise shall be in the denomination of$5,000 or any integral multiple thereof, and shall be dated the date of issuance thereof, shall mature (without option of prior redemption) on July 1, 1998, and shall bear interest, payable at maturity and computed on the basis of a 360-day year composed of twelve 30-day months, at the rate per annum of %. (C) Both the principal of and interest on the Notes shall be payable at maturity in lawful money of the United States of America, only to the registered owners of the Notes upon surrender thereof at the office of U.S. Trust Company of California, N.A. (the "Trustee") in Los Angeles, California upon the maturity thereof. No interest shall be payable on any Note for any period after maturity during which the registered owner thereof fails to properly present such Note for payment. (D) The Series B Notes shall be dated the date of issuance thereof, shall mature (without option of prior redemption) not more than 12 months thereafter and shall bear interest payable at maturity computed on the basis of a 360-day year composed of twelve 30-day months at the rate or rates specified in the Supplemental Trust Agreement related thereto. The issuance of the Series B Notes shall be subject to the following conditions: (1) Receipt of confirmation from Moody's Investors Service and Standard & Poor's (each an "Agency") (if such respective rating agency rated the Series A Notes) that the issuance of the Series B Notes will not cause a reduction or withdrawal in such Agency's rating on the Series A Notes; and (2) Receipt of an opinion of Bond Counsel to the effect that the interest on the Series B Notes is excludable from gross income for federal income tax purposes. s1na1558.2 2 40511-103-NMC-04121197 (E) At any time after the sale of a series of the Notes, the County shall execute the Notes of such series for issuance hereunder and shall deliver them to the Trustee, and thereupon such Notes shall be authenticated and delivered by the Trustee to the purchaser thereof upon the written request of the County and upon receipt of payment therefor from the purchaser thereof. Section 2. Disposition of Proceeds of Notes. The County shall, immediately upon receiving the proceeds of the sale of the Notes, place in the County General Fund maintained in the County Treasury all amounts received from such sale. Such amounts held in the County General Fund shall be invested as permitted by Section 53601 of the Government Code provided that no such investments shall be invested in "reverse repurchase agreements" permitted by subsection (i) of said Section 53601, and no such investments shall have a maturity later than the date that it is anticipated that such amounts will be required to be expended. Such amounts may be commingled with other funds of the County. Amounts in the County General Fund attributable to the sale of the Notes shall be withdrawn and expended by the County for any purpose for which the County is authorized to expend funds from the General Fund of the County, but (except for costs related to the issuance of the Notes) only after exhausting funds otherwise available for such purposes (which are not restricted funds), and only to the extent that on any given day such other funds are not then available, and for purposes of this section, otherwise available funds excludes amounts that are held or set aside in a reasonable working capital reserve (as described in the tax certificate of the County delivered upon issuance of the Notes and, in any event, not exceeding five percent (5%) of the County's total working capital expenditures from its available funds in fiscal year 1996-1997)). If on the date that is six months from the date of issuance of a series of Notes all amounts attributable to the proceeds of such series of Notes (including investment earnings thereon) have not been so expended, the County shall promptly notify Orrick, Herrington & Sutcliffe LLP ("Bond Counsel") and, to the extent of its power and authority, comply with the instructions from Bond Counsel as to the means of satisfying the rebate requirements of Section 148 of the Internal Revenue Code of 1986 (the "Code"). Section 3. Source of Payment. (A) The principal of and interest on the Notes shall be payable from taxes, income, revenue, cash receipts and other moneys which are received by the County for the General Fund of the County for the fiscal year 1997-1998 and which are lawfully available for the payment of current expenses and other obligations of the County (the "Unrestricted Revenues"). (B) As security for the payment of the principal of and interest on the Notes, the County hereby pledges to transfer to the Trustee for deposit in trust in a special fund designated as the "1997-1998 Tax and Revenue Anticipation Note Repayment Fund" (the "Repayment Fund"), which fund the Trustee hereby agrees to establish and maintain while any Notes are outstanding money or securities (eligible for investment pursuant to Section 4(C) hereof): (i) an amount equal to 50% of the principal amount of the Notes from the first Unrestricted Revenues received by the County during the accounting period commencing on December 12, 1997 and ending January 13, 1998, inclusive (the "Sixth sF2-71558.2 3 40511-103-MAC-02171197 Accounting Period"), and (ii) an amount equal to 50% of the principal amount of Notes from the first Unrestricted Revenues received by the County during the accounting period commencing on April 14, 1998 and ending May 12, 1998, inclusive (the "Tenth Accounting Period"), together with an amount sufficient (net of anticipated earnings on moneys in the Repayment Fund) (x) to satisfy and make up any deficiency in the Repayment Fund with respect to the prior Accounting Period and (y) to pay the interest on the Notes at maturity. The amounts pledged by the County for transfer to the Trustee for deposit into the Repayment Fund from the Unrestricted Revenues received during each indicated accounting period are hereinafter called the "Pledged Revenues." (C) In the event that there have been insufficient Unrestricted Revenues received by the County by the third business day prior to the end of any such Accounting Period to permit the transfer to the Trustee for deposit into the Repayment Fund of the full amount of the Pledged Revenues required to be deposited with respect to such Accounting Period, then the amount of any deficiency in the Repayment Fund shall be satisfied and made up from any other moneys of the County lawfully available for the payment of the principal of the Notes and the interest thereon (all as provided in Sections 53856 and 53857 of the Government Code) (the "Other Pledged Moneys") on such date or thereafter on a daily basis, when and as such Pledged Revenues and Other Pledged Moneys are received by the County. (D) The Repayment Fund shall be held by the Trustee, in trust, and applied only for the purposes and as directed in the Trust Agreement. Any moneys deposited in the Repayment Fund shall be for the benefit of the Owners of the Notes. All amounts in the Repayment Fund shall be held by the Trustee as trustee and pledge holder for the benefit of Owners of Notes. Section 4. Pledged Revenues. (A) The Pledged Revenues with respect to the accounting period in which received shall be transferred by the Treasurer-Tax Collector of the County to the Trustee for deposit in the Repayment Fund commencing the third business day of each respective accounting period, and thereafter at intervals of no more than every five business days, and applied as directed in this Trust Agreement; and the Other Pledged Moneys, if any, shall be transferred by the Treasurer-Tax Collector of the County to the Trustee for deposit in the Repayment Fund on the third business day prior to the end of such accounting period and on each business day thereafter; until the full amount of the moneys required by Section 3(B) has been so deposited in the Repayment Fund; provided that, if on the date that is six months from the date of issuance of a series of Notes all amounts attributable to the proceeds of such series of Notes (including investment earnings thereon) have not been expended in accordance with Section 2, the amounts to be transferred to the Trustee for deposit in the Repayment Fund during the accounting period in which received shall be transferred to the Trustee for deposit as soon as received. The principal of and interest on the Notes constitute a first lien and charge on, and shall be payable from, moneys in the Repayment Fund. Moneys in the Repayment Fund shall be applied only as hereinafter in this Section 4 provided. SF2-71558.2 4 40511-103-MAC-04/21197 (B) The Trustee shall use the moneys in the Repayment Fund on the maturity date of the Notes to pay the principal of and interest on the Notes then due. Any moneys remaining in the Repayment Fund after such payment, or after provision for such payment has been made, shall be transferred by the Trustee to the County Treasurer-Tax Collector for deposit in the General Fund of the County. If for any reason amounts in the Repayment Fund are insufficient to pay both series of Notes in full, such amounts shall be applied pro rata to the payment of each series of Notes based on the total principal of and interest payable upon the Notes at the maturity thereof. (C) Moneys in the Repayment Fund shall be invested by the Trustee upon receipt of written direction from the County and as permitted by Section 53601 of the Government Code, except that no moneys shall be invested in investments permitted by subsection (i) (to the extent that subsection (i) applies to reverse repurchase agreements) of said Section 53601, and no such investments shall have a maturity date later than the maturity date of the Notes. The proceeds of any such investments shall be retained in the Repayment Fund until payment of principal of and interest on the Notes (or provision therefor) has been made in accordance with paragraph (B), at which time any excess amount shall be transferred by the Trustee to the County Treasurer-Tax Collector for deposit in the General Fund of the County. Section 5. Execution of Notes. The Treasurer-Tax Collector of the County or his designee is hereby authorized to execute the Notes by use of his manual or facsimile signature, and the Clerk of the Board of Supervisors of the County or one of his assistants is hereby authorized to countersign, by manual or facsimile signature, the Notes and to affix the seal of the Board of Supervisors thereto by impressing the seal or by imprinting a facsimile of the seal thereon. Said officers are hereby authorized to cause the blank spaces in Exhibit A to be filled in as may be appropriate and to deliver the Notes to the Trustee. In case any officer whose signature appears on the Notes shall cease to be such officer before the delivery of the Notes to the purchaser thereof, such signature shall nevertheless be valid and sufficient for all purposes as if such officer had remained in office until such delivery of the Notes. Only those Notes bearing thereon a certificate of authentication and registration in the form hereinbefore recited, executed manually and dated by the Trustee, shall be entitled to any benefit, protection or security hereunder or be valid or obligatory for any purpose, and such certificate of the Trustee shall be conclusive evidence that the Notes so authenticated have been duly authorized, executed, issued and delivered hereunder and are entitled to the benefit, protection and security hereof. Section 6. Form of Notes and Certificate of Authentication and Registration. The Notes shall be issued in fully registered form without coupons and the Notes and the Certificate of Registration shall be substantially in the form and substance set forth in Exhibit A attached hereto and by reference incorporated herein, the blanks in said form to be filled in with appropriate words and figures. sF2-71558.2 5 40511-103-MAC-04r21i97 Section 7. Use of Depository; Registration, Exchange and Transfer. (A) The Depository Trust Company, New York, New York, is hereby appointed depository for the Notes. The Depository Trust Company shall perform such function pursuant to the Blanket Issuer Letter of Representation on file with the Trustee. The Notes shall be initially issued and registered in the name of ".Cede & Co.," as nominee of The Depository Trust Company, New York, New York and shall be evidenced by a single Note. Registered ownership of each Note, or any portion thereof, may not thereafter be transferred except as set forth in Section 7(B). (B) The Notes shall be initially issued and registered as provided in Section 7(A) hereof. Registered ownership of the Notes, or any portions thereof, may not thereafter be transferred except: (i) to any successor of Cede & Co., as nominee of The Depository Trust Company, or its nominee, or of any substitute depository designated pursuant to clause (ii) of this subsection (B) ("Substitute Depository"); provided that any successor of Cede & Co., as nominee of The Depository Trust Company or Substitute Depository, shall be qualified under any applicable laws to provide the service proposed to be provided by it; (ii) to any Substitute Depository not objected to by the County Administrator of the County, upon (1) the resignation of The Depository Trust Company or its successor (or any Substitute Depository or its successor) from its functions as depository, or (2) a determination by the County Administrator of the County to substitute another depository for The Depository Trust Company (or its successor) because the Depository Trust Company (or its successor) is no longer able to carry out its functions as depository; provided that any such Substitute Depository shall be qualified under any applicable laws to provide the services proposed to be provided by it; or (iii) to any person as provided below, upon (1) the resignation of The Depository Trust Company or its successor (or any Substitute Depository or its successor) from its functions as depository, or (2) a determination by the County Administrator of the County to discontinue using The Depository Trust Company or a depository. (C) In the case of any transfer pursuant to clause (i) or clause (ii) of subsection (B) of this Section 7, upon receipt of all outstanding Notes by the Trustee (together, in the case of a successor paying agent appointed by the County, with a written request of the County Administrator of the County to such successor paying agent . designating the Substitute Depository), a single new Note, which the County shall prepare or cause to be prepared, shall be executed and delivered, authenticated by the Trustee, and registered in the name of any such successor to Cede & Co. or such Substitute Depository, or their respective nominees, as the case may be, all as specified by the County Administrator of the County or, in the case of a successor paying agent appointed by the County pursuant to Section 10 hereof, as specified in the written request of the County Administrator of the County. In the case of any transfer pursuant to clause (iii) of SF2-71558.2 6 40511-103-MAC-04/21/97 Subsection (B) of this Section 7 upon receipt of all outstanding Notes by the Trustee (together, in the case of a successor paying agent appointed by the County pursuant to Section 10 hereof, with a written request of the County Administrator of the County to such successor paying agent), new Notes, which the County shall prepare or cause to be prepared, shall be executed and delivered in such denominations and registered in the names of such persons as specified by the County Administrator of the County or, in the case of a successor paying agent appointed by the County pursuant to Section 10 hereof, as are requested in such written request of the County Administrator of the County, subject to the limitations of this Section 7, provided that the Trustee shall deliver such new Notes as soon as practicable. (D) The County and the Trustee shall be entitled to treat the person in whose name any Note is registered as the owner thereof for all purposes of the Trust Agreement and for purposes of payment of principal of and interest on such Note, notwithstanding any notice to the contrary received by the Trustee or the County; and the County and the Trustee shall not have responsibility for transmitting payments to, communicating with, notifying, or otherwise dealing with any beneficial owners of the Notes. Neither the County nor the Trustee shall have any responsibility or obligation, legal or otherwise, to any such beneficial owners or to any other party, including The Depository Trust Company or its successor (or Substitute Depository or its successor), except to the owner of any Notes, and the Trustee may rely conclusively on its records as to the identity of the owners of the Notes. (E) Notwithstanding any other provision of this Trust Agreement and so long as all outstanding Notes are registered in the name of Cede & Co. or its registered assigns, the County and the Trustee shall cooperate with Cede & Co. or its registered assigns, as sole registered owner, in effecting payment of the principal of and interest on the Notes by arranging for payment in such manner that funds for such payments are properly identified and are made available on the date they are due all in accordance with the Letter of Representations, the provisions of which the Trustee may rely upon to implement the foregoing procedures notwithstanding any inconsistent provisions herein. (F) In the case of any transfer pursuant to clause (iii) of subsection (B) of this Section, any Note may, in accordance with its terms, be transferred or exchanged for a like aggregate principal amount in authorized denominations, upon the books required to be kept by the Trustee pursuant to the provisions hereof, by the person in whose name it is registered, in person or by his duly authorized attorney, upon surrender of such Note for cancellation, and, in the case of a transfer, accompanied by delivery of a written instrument of transfer, duly executed and in form approved by the Trustee. Whenever any Note shall be surrendered for transfer or exchange, the County shall execute and the Trustee shall authenticate and deliver a new Note or Notes of authorized denominations, for a like aggregate principal amount of the same interest rate. The Trustee shall require the owner requesting such transfer or exchange to pay any tax or other governmental charge required to be paid with respect to such transfer or exchange. SP2-71558.2 7 40511-103-1r1Ac-04i21i97 (G) The Trustee will keep or cause to be kept sufficient books for the registration and transfer of the Notes, which shall at all times be open to inspection by the County. Upon presentation for such purpose, the Trustee shall, under such reasonable regulations as it may prescribe, register or transfer or cause to be registered or transferred, on such books, Notes as hereinbefore provided. (H) If any Note shall become mutilated, the County, at the expense of the owner of such Note, shall execute, and the Trustee shall thereupon authenticate and deliver a new Note of like series, tenor, interest rate and number in exchange and substitution for the Note so mutilated, but only upon surrender to the Trustee of the Note so mutilated. Every mutilated Note so surrendered to the Trustee shall be cancelled by it and delivered to, or upon the order of, the County. If any Note shall be lost, destroyed or stolen, evidence of such loss, destruction or theft may be submitted to the County and the Trustee and, if such evidence be satisfactory to both and indemnity satisfactory to them shall be given, the County, at the expense of the owner, shall execute, and the Trustee shall thereupon authenticate, if required, and deliver a new Note of like series, interest rate, tenor and number in lieu of and in substitution for the Note so lost, destroyed or stolen (or if any such Note shall have matured or shall be about to mature, instead of issuing a substitute Note, the Trustee may pay the same without surrender thereof). The Trustee may require payment by the registered owner of a Note of a sum not exceeding the actual cost of preparing each new Note issued pursuant to this paragraph and of the expenses which may be incurred by the County and the Trustee. Any Note issued under these provisions in lieu of any Note alleged to be lost, destroyed or stolen shall constitute an original additional contractual obligation on the part of the County whether or not the Note so alleged to be lost, destroyed or stolen be at any time enforceable by anyone, and shall be entitled to the benefits of this Trust Agreement with all other Notes secured by this Trust Agreement. All Notes surrendered for payment or registration of transfer, if surrendered to any person other than the Trustee, shall be delivered to the Trustee and shall be promptly cancelled by it. The County may at any time deliver to the Trustee for cancellation any Notes previously authenticated and delivered hereunder which the County may have acquired in any manner whatsoever, and all Notes so delivered shall promptly be cancelled by the Trustee. No Note shall be authenticated in lieu of or in exchange for any Notes cancelled as provided herein, except as expressly permitted hereunder. All cancelled Notes held by the Trustee shall be disposed of as directed by the County. Section 8. General Covenants. It is hereby covenanted and warranted by the Board that all representations and recitals contained in this Trust Agreement are true and correct and that the Board and the County, and their appropriate officials, have duly taken all proceedings necessary to be taken by them, and will take any additional proceedings necessary to be taken by them, for the levy, collection and enforcement of the taxes, income, revenue, cash receipts and other moneys pledged hereunder in accordance with law and for carrying out the provisions of:this Trust Agreement and the Notes. sF2-71558.2 8 40511-103-Mnc-04/21/97 Section 9. Tax Covenants; Rebate Fund. (A) The County covenants that it shall make all calculations in a reasonable and prudent fashion relating to any rebate of excess investment earnings on the proceeds of the Notes due to the United States Treasury, shall segregate and set aside from lawfully available sources the amount such calculations may indicate may be required to be paid to the United States Treasury and shall otherwise at all times do and perform all acts and things necessary and within its power and authority, including complying with each applicable requirement of Section 103 and Sections 141 through 150 of the Code and complying with the instructions of Bond Counsel referred to in Section 2 hereof, to assure that interest paid on the Notes shall, for the purposes of federal income taxes and California personal income taxation, be excludable from the gross income of the recipients thereof and exempt from such taxation. As part of the performance of the covenant contained in the preceding sentence, promptly after six months from the date of the issuance of the Notes, the County will reasonably and prudently calculate the amount of the Note proceeds which have been expended, with a view to determining whether or not the County has met the requirements of Section 148(f)(4)(B) of the Code with respect to the Notes, and if it has not met such requirements, it will reasonably and prudently calculate the amount, if any, of investment profits which must be rebated to the United States and will immediately set aside, from revenues attributable to the 1997-1998 Fiscal Year or, to the extent not available from such revenues, from any other moneys lawfully available, the amount of any such rebate in the Fund referred to in paragraph (B) of this Section 9. (B) The County shall establish and maintain a fund separate from any other fund established and maintained hereunder designated as the "1997-1998 Tax and Revenue Anticipation Note Rebate Fund". _ There shall be deposited in the Rebate Fund such amounts as are required to be deposited therein in accordance with the written instructions from Bond Counsel pursuant to Section 2 hereof. (C) Notwithstanding any other provision of this Trust Agreement to the contrary, upon the County's failure to observe, or refusal to comply with, the covenants contained in this Section, no one other than the owners or former owners of the Notes or the Trustee shall be entitled to exercise any right or remedy under this Trust Agreement on the basis of the County's failure to observe, or refusal to comply with, such covenants. (D) The covenants contained in this Section shall survive the payment of the Notes. (E) Notwithstanding any provision of this section, if the County shall provide to the Trustee an opinion of Bond Counsel that any specified action required under this section is no longer required or that some further or different action is required to maintain the exclusion from gross income for federal income tax purposes of interest on the Notes, the Trustee and the County may conclusively rely on such opinion in complying with the requirements of this section, and the covenants hereunder shall be deemed to be modified to that extent. SF2-71558.2 9 40511-103-MAC-04/21/97 Section 10. Trustee. (A) U.S. Trust Company of California, N.A. is hereby appointed as trustee and paying agent for the Notes. The County hereby directs and authorizes the payment by the Trustee of the interest on and principal of the Notes when such become due and payable, from the Repayment Fund in the manner set forth herein. The County hereby covenants to transfer to the Trustee funds or securities for deposit in the Repayment,Fund at the times and in the amounts specified herein to provide sufficient moneys to pay the principal of and interest on the Notes on the day on which they mature. Payment of the Notes shall be in accordance with the terms of the Notes and this Trust Agreement. (B) The Trustee is also appointed as registrar and upon the request of any registered owner is authorized to record the transfer or exchange of Notes in accordance with the provisions hereof. (C) The Trustee shall be protected and shall incur no liability in acting or proceeding in good faith upon any affidavit, bond, certificate, consent, notice, request, requisition, resolution, statement, telegram, voucher, waiver or other paper or document which it shall in good faith believe to be genuine and to have been adopted, executed or delivered by the proper party or pursuant to any of the provisions hereof, and the Trustee shall be under no duty to make any investigation or inquiry as to any statements contained or matters referred to in any such instrument, but may accept and rely upon the same as conclusive evidence of the truth and accuracy of such statements. The Trustee shall not be bound to recognize any person as an owner of any Notes or to take any action at the request of any such person unless such Note shall be deposited with the Trustee or satisfactory evidence of the ownership of such Note shall be furnished to the Trustee. The Trustee may consult with counsel, who may be counsel to the County, with regard to legal questions, and the opinion of such counsel shall be full and complete authorization and protection in respect to any action taken or suffered by it hereunder in good faith in accordance therewith. Whenever in the administration of its rights and obligations hereunder the Trustee shall deem necessary or desirable that a matter be proved or established prior to taking or suffering any action hereunder, such matter (unless prescribed) may be deemed to be conclusively proved and established by a Certificate of the County, and such certificate shall be full warrant to the Trustee for any action taken or suffered under the provisions hereof upon the faith thereof, but in its discretion the Trustee may, in lieu thereof, accept other evidence of such matter or may require such additional evidence as to it may seem reasonable. The recitals of facts herein and in the Notes contained shall be taken as statements of the County, and the Trustee shall not assume responsibility for the correctness of the same, or make any representations as to the validity or sufficiency of the Trust Agreement or of the Notes or incur any responsibility in respect thereof, other than in connection with the respective duties or obligations herein or in the Notes assigned to or imposed upon it. SF2-71558.2 10 40511-103-MAC-04/21/97 The Trustee has no obligation or liability to the owners of any Notes to make payment of principal, premium, if any, or interest pertaining to the Notes except from Pledged Revenues. No provision of this Trust Agreement shall require the Trustee to expend or risk its own funds or otherwise incur any financial liability in the performance of its duties hereunder, or in the exercise of any of its rights and powers, if it shall have reasonable grounds for believing the repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. The Trustee undertakes to perform such duties and only such duties as are specifically set forth in this Trust Agreement, and no implied covenants or obligations shall be read in this Trust Agreement against the Trustee. The Trustee shall not be liable with respect to any action taken by it in good faith and reasonably believed by it to be authorized or within the discretion or rights or powers conferred upon it under this Trust Agreement. The Trustee shall not be liable for any error of judgment made in good faith by a responsible officer, unless it shall be proved that the Trustee was negligent or engaged in.willful misconduct in ascertaining pertinent facts. (D) The County shall pay the Trustee compensation for its services and reimburse the Trustee for its advances and expenditures hereunder, including but not limited to advances of and fees and expenses of accountants, agents, consultants, counsel, or other experts employed by it in the exercise and performance of its rights hereunder. The County shall indemnify and hold harmless the Trustee to the extent and in the amounts provided by the laws of the State of California from and against claims, damages and loss, liability, expense or advance incurred or made, in the absence of negligence or wilful misconduct on the part of the Trustee, arising out of or in connection with its performance of its duties hereunder. The Trustee's rights to immunities and protection from liability hereunder and its rights to payment of its fees and expenses shall survive its resignation or removal and the final payment or defeasance of the Notes. Section 11. Proceedings Constitute Contract. The provisions of the Notes and of this Trust Agreement shall constitute a contract between the County and the registered owners of the Notes, and such provisions shall be enforceable by mandamus or any other appropriate suit, action or proceeding at law or in equity in any court of competent jurisdiction, and, upon issuance of the Notes, shall be irrepealable. Section 12. Governing Law. This Trust Agreement shall be construed and governed in accordance with the laws of the State of California. Section 13. Severability. If any one or more of the agreements, conditions, covenants or terms contained herein required to be observed or performed by or on the part S 2.71558.2 11 40511-103-MAC-04/21/97 of the County or the Trustee shall be contrary to law, then such agreement or agreements, such condition or conditions, such covenant or covenants or such term or terms shall be null and void and shall be deemed severable from the remaining agreements, conditions, covenants and terms hereof and shall in no way affect the validity hereof or of the Notes, and the owners of the Notes shall retain all the benefit, protection and security afforded to them hereunder and under all provisions of applicable law. The County and the Trustee hereby declare that they would have executed and entered into the Trust Agreement and each and every other section, paragraph, subdivision, sentence, clause and phrase hereof and would have authorized the issuance of the Notes pursuant hereto irrespective of the fact that any one or more of the sections, paragraphs, subdivisions, sentences, clauses or phrases hereof or the application thereof to any person or circumstance may be held to be unconstitutional, unenforceable or invalid. Section 14. Effective Date of Trust Agreement. This Trust Agreement shall take effect upon its execution and delivery. SF2-71558.2 12 40511-103-Mnc-04n1/97 Section 15. Execution in Counterparts. This Trust Agreement may be executed in several counterparts, each of which shall be deemed an original, and all of which shall constitute but one and the same instrument. U.S. TRUST COMPANY OF CALIFORNIA, N.A., as Trustee and Paying Agent By Authorized Officer COUNTY OF CONTRA COSTA County Administrator of the County of Contra Costa Attest: Chief Clerk of the Board of Supervisors of the County of Contra Costa By: SF2-71558.2 13 40511-103-Nrwc-04121197 EXHIBIT A REGISTERED REGISTERED No. R-1 $150,000,000 COUNTY OF CONTRA COSTA, CALIFORNIA, 1997-1998 TAX AND REVENUE ANTICIPATION NOTE, SERIES [A/B] Rate of Interest: Note Date: Maturity Date: CUSIP No.: % July 1, 1997 July 1, 1998 Registered Owner: CEDE & CO. Principal Amount: ONE HUNDRED FIFTY MILLION DOLLARS FOR VALUE RECEIVED, the County of Contra Costa (the "County"), State of California, acknowledges itself indebted to and promises to pay to the Registered Owner identified above, or registered assigns, at the office of U.S. Trust Company of California, N.A. (the "Trustee"), the Principal Amount specified above, in lawful money of the United States of America, on the Maturity Date specified above, together with interest thereon payable at the maturity thereof, at the Rate of Interest per annum set forth above (computed on the basis of a 360-day year composed of twelve 30-day months) in like lawful money from the Note Date specified above until payment in full of said principal sum. The principal of and interest on this Note shall be payable at the maturity hereof only to the registered owner hereof upon surrender of this Note at the office of the Trustee as the same shall fall due; provided, however, that no interest shall be payable for any period after maturity during which the registered owner hereof fails to properly present this Note for payment. It is hereby certified, recited and declared that this Note is one of a series of Notes of the Series specified above issued in the aggregate principal amount of$ and is part of an authorized issue of Notes entitled "County of Contra Costa, California, 1997-1998 Tax and Revenue Anticipation Notes" (the "Notes"), authorized in the aggregate principal amount of One Hundred Fifty Million Dollars ($150,000,000), all of like tenor, made, executed and given pursuant to the authority of Article 7.6 (commencing with Section 53850) of Chapter 4, Part 1, Division 2, Title 5 of the California Government Code and all laws amendatory thereof or supplemental thereto, and under and pursuant to the provisions of a Trust Agreement, dated as of July 1, 1997 (herein called the "Trust Agreement"), between the Trustee and the County, authorizing the issuance of the Notes, and that all acts, conditions and things required to exist, happen and be performed precedent to and in the issuance of this Note have existed, happened and been performed in regular and due time, sF2-71558.2 A-1 4os11-103-MAC-04/21/97 form and manner as required by law, and that this Note, together with all other indebtedness and obligations of the County, does not exceed any limit prescribed by the Constitution or statutes of the State of California. The Notes of each series shall be payable on a parity with each other. The principal of and interest on the Notes shall be payable from taxes, income, revenue, cash receipts and other moneys which are received by the County for the General Fund of the County for the fiscal year 1997-1998 and which are lawfully available for the payment of current expenses and other obligations of the County (the "Unrestricted Revenues"). As security for the payment of the principal of and interest on the Notes, the County has pledged to transfer to the Trustee for deposit in the Repayment Fund (as defined in the Trust Agreement): (i) an amount equal to 50% of the principal amount of the Notes from the first Unrestricted Revenues received by the County during the accounting period commencing on December 12, 1997 and ending January 13, 1998, inclusive (the "Sixth Accounting Period"), and (ii) an amount equal to 50% of the principal amount of Notes from the first Unrestricted Revenues received by the County during the accounting period commencing on April 14, 1998 and ending May 12, 1998, inclusive (the "Tenth Accounting Period"), together with an amount sufficient (net of anticipated earnings on moneys in the Repayment Fund) (x) to satisfy and make up any deficiency in the Repayment Fund with respect to the prior Accounting Period and (y) to pay the interest on the Notes at maturity (such pledged amounts being hereinafter called the "Pledged Revenues"). In the event that there are insufficient Pledged Revenues received by the County by the third business day prior to the end of any such accounting period to permit the transfer to the Trustee for deposit into the Repayment Fund of the full amount of the aforesaid moneys to be deposited, then the amount of any deficiency in the Repayment Fund shall be satisfied and made up from any other moneys of the County lawfully available for the payment of the principal of and interest on the Notes (such other pledged moneys being hereinafter called the "Other Pledged Moneys"). The Pledged Revenues and Other Pledged Moneys shall be transferred to the Trustee for deposit in the Repayment Fund at the intervals specified in the Trust Agreement. The principal of and interest on the Notes shall constitute a first lien and charge on, and shall be payable from, moneys in the Repayment Fund. This Note is transferable by the registered owner hereof in person or by such owner's attorney duly authorized in writing at the office of the Trustee, but only in the manner, subject to the limitations and upon payment of the charges provided in the Trust Agreement, and upon surrender and cancellation of this Note. Upon such transfer a new Note or Notes of authorized denominations and for the same aggregate principal amount will be issued to the transferees in exchange herefor. The County and the Trustee may deem and treat the registered owner hereof as the absolute owner hereof for the purpose of receiving payment of or on account of principal hereof and interest due hereon and for all other purposes, and neither the County nor the Trustee shall be affected by any notice to the contrary. This Note shall not be valid or become obligatory for any purpose until the Certificate of Registration hereon shall have been signed by the Trustee. SF2-71558.2 A-2 40511-103-MAC-04/21/97 IN WITNESS WHEREOF, the County of Contra Costa has caused this Note to be executed by the manual or facsimile signature of its Treasurer-Tax Collector and countersigned by the manual or facsimile signature of the Clerk of its Board of Supervisors and caused the official seal of its Board of Supervisors to be impressed hereon, all as of the Note Date specified above. COUNTY OF CONTRA COSTA By Treasurer-Tax Collector (SEAL) Countersigned: County Administrator and Clerk of the Board of Supervisors [FORM OF TRUSTEE'S CERTIFICATE OF AUTHENTICATION AND REGISTRATION] This Note is one of the Notes described in the within-mentioned Trust Agreement, which Note has been authenticated and registered on the date set forth below. Date of Authentication: U.S. TRUST COMPANY OF CALIFORNIA, N.A., as Trustee and Paying Agent By Authorized Officer SF2-71558.2 A-3 40511-103-MAC-04121/97 [FORM OF ASSIGNMENT] For value received the undersigned do(es) hereby sell, assign and transfer unto (insert Social Security Number or taxpayer identification number) the within-mentioned registered Note and hereby irrevocably constitute(s) and appoint(s) attorney, to transfer the same on the books of the Trustee with full power of substitution in the premises. Dated: Signature NOTE: The signature to the assignment must correspond to the name as written on the face of this Note in every particular, without any alteration or change whatsoever. Signature Guaranteed By: NOTE: The signature to the assignment must be guaranteed by a member firm of the New York Stock Exchange or a commercial bank or trust company. [FORM OF DTC LEGEND] Unless the certificate is presented by an authorized representative of The Depository Trust Company to the issuer or its agent for registration of transfer, exchange or payment, and any certificate issued is registered in the name of Cede & Co. or such other name as requested by an authorized representative of The Depository Trust Company and any payment is made to Cede & Co., ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL, since the registered owner hereof, Cede & Co., has an interest herein. SF2-71558.2 40511-103-MAC-04/21/97 OH&S Draft 04/21/97 NOTICE OF INTENTION TO SELL $150,000,000 ° COUNTY OF CONTRA COSTA, CALIFORNIA 1997-1998 TAX AND REVENUE ANTICIPATION NOTES, SERIES A NOTICE IS HEREBY GIVEN that the Board of Supervisors of the County of Contra Costa(the"County"), State of California,intends to offer for public sale on Tuesday,June 3, 1997, at the hour of 10:00 a.m., local time, at the offices of Bond Counsel, Orrick, Herrington&Sutcliffe LLP, 400 Sansome Street, San Francisco, California 94111, $150,000,000* principal amount of tax and revenue anticipation notes of the County of Contra Costa designated "County of Contra Costa, California, 1997-1998 Tax and Revenue Anticipation Notes, Series A" (the "Notes"). The County reserves the right to postpone to a later date in June said public sale date or to change the principal amount by announcing such postponement or change by Munifacts News Service no later than 24 hours prior to 10:00 a.m. local time on June 3, 1997. If no legal bid or bids are received for the Notes on June 3, 1997 (or such other date as is established by Munifacts News Service) at the time and place specified, bids will be received for the Notes at the same place and at such time as shall be designated by Munifacts News Service. As an accommodation to bidders, telephonic or fax notice of the postponement of the sale date will be given to any bidder requesting such notice from C. M. de Crinis & Co., Inc., the County's Financial Advisor: Attn. Jean Buckley (415) 339-8944. Failure of any bidder to receive such Munifacts, telephonic or fax notice shall not affect the legality of the sale. NOTICE IS HEREBY FURTHER GIVEN that the Notes will be offered for public sale subject to the terms and conditions of the Official Notice of Sale for the Notes, dated , 1997, and copies of said Official Notice of Sale and the Official Statement relating to the Notes will be furnished upon request to C. M. de Crinis & Co., Inc., 3000 Bridgeway, Suite 206, Sausalito, California 94965. Dated: , 1997. /s/Philip J. Batchelor County Administrator and Clerk of the Board of Supervisors, County of Contra Costa, State of California * Preliminary - subject to change SF2-719'73.2 OFFICIAL NOTICE OF SALE AND BID FORM COUNTY OF CONTRA COSTA STATE OF CALIFORNIA $_,000,000' 1997-1998 TAX AND REVENUE ANTICIPATION NOTES, SERIES A DATE OF SALE JUNE 3, 1997 10:00 A.M., LOCAL TIME BIDS TO BE RECEIVED AT THE OFFICES OF BOND COUNSEL ORRICK, HERRINGTON & SUTCLIFFE LLP 400 SANSOME STREET SAN FRANCISCO, CALIFORNIA 94111 (415) 392-1122 Preliminary - subject to change. SF2-71796.2 OFFICIAL NOTICE OF SALE $_,000,000' COUNTY OF CONTRA COSTA, CALIFORNIA 1997-1998 TAX AND REVENUE ANTICIPATION NOTES NOTICE IS HEREBY GIVEN that sealed proposals will be received and opened on behalf of the County of Contra. Costa (the "County") at the place and up to the time specified below: TEWE: 10:00 a.m. local time on Tuesday, June 3, 1997, or at such later date as shall be established by the County Administrator of the County or his designee (the "County Administrator") and communicated through Munifacts News Service not less than 24 hours prior to the time bids are to be received. If no legal bid or bids are received for the Notes on June 3, 1997 (or such other date as is communicated by Munifacts News Service) at the time and place specified, bids will be received at the same time and place specified on such other date as shall be designated by Munifacts News Service. As an accommodation to bidders, telephonic or fax notice of the postponement of the sale date or change in the principal amount will be given to any bidder requesting such notice by request directed to the County's Financial Advisor, C. M. de Crinis & Co., Inc., 3000 Bridgeway, Suite 206, Sausalito, California 94965; Attn. Jean Buckley (Phone - (415) 339-8944). Failure of any bidder to receive such Munifacts, telephonic or fax notice shall not affect the legality of the sale. PLACE: Orrick, Herrington & Sutcliffe LLP 400 Sansome Street 2nd Floor, Conference Room A San Francisco, California 94111 MAIL BIDS: Mailed bids should be addressed to: County of Contra Costa c/o Orrick, Herrington & Sutcliffe LLP 400 Sansome Street San Francisco, California 94111 Attn: Thomas R. Shearer, Jr. Preliminary - subject to change. SF2-71796.2 for the purchase of $_,000,000'' principal amount of 1997-1998 Tax and Revenue Anticipation Notes, Series A (the "Notes") of the County of Contra Costa pursuant to a Trust Agreement (the "Trust Agreement") to be entered into by the County and U.S. Trust Company of California, N.A. (the "Trustee"). Copies of the Trust Agreement will be furnished to any interested bidder upon request to County Administrator, County of Contra Costa, 651 Pine Street, 11th Floor, Martinez, CA 94553-0063, (510) 335-1086, Attn: Philip J. Batchelor. BOOK-ENTRY ONLY: The Notes shall be issued in registered form by means of a book entry system with no distribution of note certificates made to the public. One Note certificate representing the Note issue will be issued to The Depository Trust Company, New York, New York ("DTC") registered in the name of Cede & Co., its nominee. The book-entry system will evidence ownership of the Notes in the principal amount of $5,000 or any integral multiple thereof, with transfers of ownership effected on the records of DTC. MATURITY: The Notes will be dated the date of issuance thereof, will pay interest at the maturity thereof and will mature on July 1, 1998. PREPAYMENT: The Notes are not subject to prepayment prior to maturity. PURPOSE: The proceeds of the sale of the Notes will provide moneys to help meet current (fiscal year 1997-1998) County expenditures, including current expenses, capital expenditures and the discharge of other obligations or indebtedness of the County. ADDITIONAL NOTES: The County has authorized the issuance of additional parity notes (the "Series B Notes") up to an aggregate principal amount with the Series A Notes of$150,000,000. SECURITY: The principal amount of the Notes and Series B Notes, together with interest thereon, shall be payable from taxes, income, revenue, cash receipts and other moneys which are received by the County for the General Fund of the County attributable to the fiscal year 1997-1998 and which are lawfully available for the payment of current expenses and other obligations of the County (the "Unrestricted Revenues"). The Notes and Series B Notes are secured by the County's pledge to transfer to the Trustee for deposit in trust in a special fund designated as the "1997-1998 Tax and Revenue Anticipation Note Repayment Fund" (the "Repayment Fund") specific amounts on specific dates. Bidders are referred to the Trust Agreement and the Official Statement for further information. CONTINUING DISCLOSURE: The County will deliver to the accepted bidder or bidders a Continuing Disclosure Certificate in connection with the issuance of the Notes in which, among other things, the County covenants to provide notice of certain material events to nationally recognized municipal securities information depositories. Preliminary - subject to change. Sn-71796.2 2 LEGAL OPINION -- DISCLOSURE COUNSEL: The accepted bidder or bidders will receive a disclosure opinion from Fulbright & Jaworski L.L.P., Los Angeles, California regarding the Official Statement. A copy of the proposed form of disclosure opinion can be obtained upon request from the County's Financial Advisor. LEGAL OPINION -- TAX EXEMPT STATUS: The Notes will be issued subject to the approving legal opinion of Orrick, Herrington & Sutcliffe LLP ("Bond Counsel") of San Francisco, California, approving the validity of the Notes and stating that, in the opinion of Bond Counsel, based on an analysis of existing laws, regulations, rulings, and court decisions, and assuming, among other matters, compliance with certain covenants, interest on the Notes 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. A copy of the proposed opinion of Bond Counsel is set forth in Appendix C of the Official Statement. FORM OF BID -- NO DISCOUNT: The bids may be for all or part (in increments of $25,000,000) of the Notes hereby offered for sale. Bids for less than all of the issue are required to be made in increments of $25,000,000 and no bid for less than $25,000,000 principal amount of Notes will be entertained. Awards will be made in increments of $25,000,000 up to $ with the remainder to be then awarded. Each bid shall state the purchase price, which shall not be less than par, and the interest rate, which shall not exceed 7% per annum, and together with the bidder's good faith check described herein (unless a Financial Surety Bond is furnished pursuant to "BID CHECK OR BOND"), must be enclosed in a sealed envelope addressed to the County with the envelope and bid clearly marked "Proposal for Purchase of County of Contra Costa, California, 1997- 1998 Tax and Revenue Anticipation Notes." Each bid must be in accordance with the terms and conditions set forth in this Official Notice of Sale. INTEREST RATE: Interest with respect to the Notes will be computed on the basis of a 360-day year and a 30-day month and accrues from the date of issuance of the Notes. Interest on the Notes is payable at the maturity of the Notes. In connection with the bid submitted for the Notes, (1) each bidder must bid an interest rate in a multiple of one one-thousandth.of.one percent (1/1000 of 1%) per annum, which rate must be less than 7% per annum; (2) interest with respect to a Note shall be computed from the date of issuance thereof (expected to be July 1, 1997) to the stated maturity date of July 1, 1998, at the interest rate specified in the bid; (3) the same interest rate shall apply to all Notes (within the specified $25,000,000 increments); and (4) any premium must be paid as part of the purchase price, and no bid will be accepted which contemplates the waiver of any interest or other concession by the bidder as a substitute for payment in full of the purchase price. BEST BID: The Notes will be awarded to the best responsible bidder or bidders, considering the rate specified and the premium offered, if any, in increments of $25,000,000 up to $_,000,000, and the remainder out of the next best $25,000,000 until all $_,000,000 of Notes have been awarded. Therefore, a bidder may be awarded Notes in an amount which is less than that requested by such bidder. The highest bid or bids will be determined by deducting the amount of the premium bid, if any, from the total amount of interest which would be required to be paid with respect to the $25,000,000 incremental sr2-71796.2 3 amount of Notes (or lesser final amount) from July 1, 1997 to their maturity date at the interest rate specified in the bid, and the award will be made on the basis of lowest net interest cost. RIGHT OF REJECTION: The County reserves the right, in its sole discretion, to reject any and all bids and to waive any irregularity or informality in any bid. PROMPT AWARD: The County Administrator or his designee will take action awarding the Notes or rejecting all bids not later than twenty-six (26) hours after the expiration of the time herein prescribed for the receipt of proposals, unless such period for award is waived by the successful bidder or bidders. Notice of the award will be given promptly to the successful bidder or bidders. DELIVERY AND PAYMENT: Delivery of the Notes through DTC is expected to be made to the successful bidder on or about July 1, 1997. Payment for the Notes must be made in Federal Reserve Bank funds or other immediately available funds. Any expense in providing immediately available funds, whether by transfer of Federal Reserve Bank funds or otherwise, shall be borne by the purchaser. CERTIFICATE REGARDING REOFFERING PRICE: As soon as practicable, but not later than the delivery date of the Notes, the successful bidder or bidders for each accepted bid must submit to the County a certificate or certificates specifying the reoffering price at which at least 10% of the Notes of such bid or bids were sold (or were offered in a bona fide public offering and as of the date of award of the Notes to the successful bidder were reasonably expected to be sold) to the public. Such certificate or certificates shall be in form and substance satisfactory to Bond Counsel and shall include such additional information as may be requested by Bond Counsel. RIGHT OF CANCELLATION: The successful bidder or bidders shall have the right, at their option, to cancel the contract of purchase if the County shall fail to execute the Notes and tender the same on or before sixty days after the award thereof, and in such event the successful bidder or bidders shall be entitled to the return of the deposit accompanying the bid. BID CHECK OR BOND: A Good Faith Deposit ("Deposit") in the form of a certified or cashier's check or a bid bond ("Financial Surety Bond"), in the amount of two hundred fifty thousand dollars ($250,000) payable to the order of the County, must accompany each proposal as a guarantee that the bidder, if successful, will accept and pay for the Notes in accordance with the terms of the bid. If a check is used, it must accompany the bid and be drawn on a bank or trust company having an office in San Francisco or Los Angeles, California. If a Financial Surety Bond is used, it must be from a pre-qualified insurance company whose claims paying ability is rated in the highest rating category by Moody's Investors Service or Standard & Poor's, and is licensed to issue such a bond in the State of California. The form of such Financial Surety Bond is subject to prior approval by Orrick, Herrington & Sutcliffe LLP, San Francisco, California, Bond Counsel, and such form must be submitted to C. M. de Crinis & Co., Inc., the Financial Advisor, prior to the opening of proposals. Such Financial Surety Bond must provide that the surety shall make SF2-71796.2 4 payment of the full amount of the Deposit by wire transfer to the County within 24 hours of the receipt of written notice from either the County or the Financial Advisor that the bidder has failed to submit the Deposit as required by this Official Notice of Sale. The Financial Surety Bond must identify each bidder whose Deposit is guaranteed by such Financial Surety Bond. If the Notes are awarded to a bidder utilizing a Financial Surety Bond, then the purchaser ("Purchaser") is required to submit its Deposit to the County in the form of a certified or cashier's check or wire transfer not later than 3:30 p.m., California time, on the next business day following the award. If such Deposit is not received by that time, the Financial Surety Bond may be drawn by the County to satisfy the Deposit requirement. The Deposit shall be cashed by the County and shall then be applied toward the purchase price of the Notes. If after the award of the Notes the successful bidder or bidders fail to complete their purchase on the terms stated in their proposal, the Deposit will be retained by the County. The checks accompanying unaccepted proposals will be returned promptly. No interest on the Deposit will accrue to any bidder. STATEMENT OF NET INTEREST COST: Each bidder is requested, but is not required, to state in its bid the net interest cost in dollars, which shall be considered as informative only and not binding. OFFICIAL STATEMENT: The County will approve a Preliminary Official Statement relating to the Notes, which will be "deemed final" by the County for purposes of SEC Rule 15c2-12, except for the omission of certain pricing and related information, and has authorized the use of the final Official Statement in connection with the sale of the Notes. Up to three hundred copies of the final Official Statement will be supplied to the purchaser or purchasers of the Notes for this purpose at the expense of the County. RESALE IN OTHER STATES: The successful bidder or bidders will assume responsibility for taking any action necessary to qualify the Notes for offer and sale in jurisdictions other than California, and for complying with the laws of all jurisdictions on resale of the Notes, and shall indemnify and hold harmless the County and its officials and supervisors from any loss or damage resulting from any failure to comply with any such law. CALIFORNIA DEBT ADVISORY COMMISSION: The successful bidder or bidders will be required, pursuant to State law, to pay any fees to the California Debt Advisory Commission ("CDAC"). CDAC will invoice the successful bidder or bidders after the delivery of the Notes. RATINGS IN EFFECT: Each proposal will be understood to be conditioned upon their being in place at the date of delivery of the Notes a rating or ratings at least as high as the rating or ratings, if any, as were in place with respect to the Notes at the time fixed for receiving bids. CHANGE IN TAX-EXEMPT STATUS: At any time before the Notes are tendered for delivery, the successful bidder or bidders may disaffirm and withdraw its proposal if the interest received by private holders of obligations of the same type and character as the Notes (as determined by Bond Counsel) shall be declared to be includable in SF2-71796.2 5 gross income under present federal income tax laws, either by a federal court, or by legislation enacted subsequent to the date of this Official Notice of Sale. CLOSING DOCUMENTS: Each proposal will be understood to be conditioned upon the County's furnishing to the accepted bidder or bidders, without charge, concurrently with payment and delivery of the Notes, the following closing papers, each dated the date of such delivery: (a) Legal Opinion: The legal opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel, described in this Official Notice of Sale under the heading "Legal Opinion -- Tax Exempt Status." (b) No Litigation Certificate: Certificate of the County that there is no litigation pending concerning the validity of the Notes, the existence of the County or the entitlement of the County Officers thereof to their respective offices except as set forth in the Official Statement. (c) Certificate: A certificate of an official of the County stating that as of the date thereof, to the best of the knowledge and belief of said official, the Official Statement does not contain an untrue statement of a material fact or omit to state any material fact necessary in order to make the statements made therein, in light of the circumstances under which they are made, not misleading. (d) Receipt: A receipt of the County showing that the purchase price of the Notes has been received by the County. (e) Disclosure Opinion: The legal opinion of Fulbright & Jaworski L.L.P., Disclosure Counsel, described in this Official Notice of Sale under the heading "Legal Opinion - Disclosure Counsel". (f) Continuing Disclosure Certificate: The Certificate described in this Official Notice of Sale under the heading "Continuing Disclosure." sF2-717%.2 6 ADDITIONAL INFORMATION: A copy of said Preliminary Official Statement and any other information concerning the proposed financing will be furnished upon request to either the financial advisor to the County, C. M. de Crinis & Co., Inc., 3000 Bridgeway, Suite 206, Sausalito, California 94965, (415) 339-8944, or the Office of the County Administrator of the County, (510) 335-1086. Dated: , 1997. COUNTY OF CONTRA COSTA By /s/ Philip J. Batchelor County Administrator and Clerk of the Board of Supervisors, County of Contra Costa, State of California SF2-71796.2 7 BID FORM PROPOSAL FOR THE PURCHASE OF COUNTY OF CONTRA COSTA, CALIFORNIA 1997-1998 TAX AND REVENUE ANTICIPATION NOTES , 1997 Mr. Philip J. Batchelor County Administrator County of Contra Costa c/o C. M. DE CRINIS & CO., INC. 3000 Bridgeway, Suite 206 Sausalito, California 94965 Attn.: Jean Buckley Dear Sir: Pursuant to the Official Notice of Sale, dated , 1997, and in accordance with all terms and conditions of your Official Notice of Sale for the sale of the County of Contra Costa, California, 1997-1998 Tax and Revenue Anticipation Notes (the "Notes"), we offer to purchase the Notes, to be dated the date of issuance thereof(July 1, 1997) and to mature on July 1, 1998, in the principal amount set forth below (as a whole in the amount of$`,000,000 or in part in increments of $25,000,000), as follows: Principal Amount Premium Interest Rate This proposal is made subject to all the terms and conditions of the Official Notice of Sale dated , 1997, all of which terms and conditions are made a part hereof as though set forth in full in this proposal. This proposal is subject to acceptance within twenty-six (26) hours after the expiration of the time for the receipt of proposals, as provided pursuant to said Official Notice of Sale. SF2-71796.2 Bid Purchase Proposal County of Contra Costa 1997-1998 TRANS Page 2 Check One: ❑ There is enclosed herewith a certified or cashier's check for $250,000 payable to the order of the County of Contra Costa; or ❑ We have obtained a Financial Surety Bond in the amount of$250,000 payable to the County of Contra Costa. Our calculation, made as provided in the Official Notice of Sale, but not constituting any part of this proposal, of the net interest cost with respect to each $25,000,000 increment of Notes is as follows: Total Interest $ Less Premium ( ) Net Interest Cost $ We understand that bids will be awarded in increments of $25,000,000 up to $_,000,000 and then the remainder will be awarded out of the next $25,000,000 bid so that all $^,000,000 of Notes are awarded. Therefore, we may be awarded Notes in an amount which is less than that requested by us. We represent that we have full and complete authority to submit this bid on behalf of our bidding syndicate and that the undersigned will serve as the lead manager for the group if the Notes are awarded pursuant to this bid. Respectfully submitted, (Firm) (Authorized Signature) SF2-71796.2 Bid Purchase Proposal County of Contra Costa 1997-1998 TRANS Page 3 Address: Telephone #: Telecopy #: If this proposal is not accepted, the good faith check should be returned to the following: Name: Address: Following is a list of the members of our account on whose behalf this bid is made: SF2-71796.2 CONTINUING DISCLOSURE CERTIFICATE COUNTY OF CONTRA COSTA, CALIFORNIA 1997-1998 TAX AND REVENUE ANTICIPATION NOTES, SERIES A This Continuing Disclosure Certificate (the "Disclosure Certificate") is executed and delivered by the County of Contra Costa, California (the "County") in connection with the issuance of$_,000,000 aggregate principal amount of its County of Contra Costa 1997-1998 Tax and Revenue Anticipation Notes, Series A (the "Notes") pursuant to Resolution No. 97/ authorizing the issuance of the Notes adopted by the Board of Supervisors of the County on , 1997 (the "Resolution"); and in connection therewith the County covenants and agrees as follows: SECTION 1. Purpose of the Disclosure Certificate. The Disclosure Certificate is being executed and delivered by the County for the benefit of the registered owners of the Notes and in order to assist the underwriter of the Notes in complying with S.E.C. Rule 15c2-12. SECTION 2. Definitions. In addition to the definitions set forth above and in the Resolution, which apply to any capitalized term used in the Disclosure Certificate unless otherwise defined in this section, the following capitalized terms shall have the following meanings: "Beneficial Owner" shall mean any person which has the power, directly or indirectly, to vote or consent with respect to, or to dispose of ownership of, any Note or Notes, including persons holding Notes through nominees or depositories. "Holders" shall mean either the registered owners of the Notes, or, if the Notes are registered in the name of The Depository Trust Company or another recognized depository, any Beneficial Owner or applicable participant in its depository system. "Listed Event" shall mean any of the events listed in Section 3(a) of the Disclosure Certificate. "National Repository" shall mean any Nationally Recognized Municipal Securities Information Repository for purposes of the Rule. The National Repositories currently approved by the Securities and Exchange Commission are set forth in Exhibit A hereto. "Repository" shall mean each National Repository and each State Repository. sP2-71797.1 "Rule" shall mean Rule 15c2-12(b)(5) adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as the same may be amended from time to time. "State Repository" shall mean any public or private repository or entity designated by the State of California as a state repository for the purpose of the Rule and recognized as such by the Securities and Exchange Commission. As of the date of the Disclosure Certificate, there is no State Repository. "Tax-exempt" shall mean that interest on the Notes is excluded from gross income for federal income tax purposes, whether or not such interest is includable as an item of tax preference or otherwise includable directly or indirectly for purposes of calculating any other tax liability, including any alternative minimum tax or environmental tax. "Underwriter" shall mean and any other original underwriters of the Notes, if any, required to comply with the Rule in connection with the offering of the Notes. SECTION 3. Rgportin of Significant Events. (a) Pursuant to the provisions of this section, the County shall give notice of the occurrence of any of the following events with respect to the Notes, if material: (i) principal and interest payment delinquencies. (ii) non-payment related defaults. (iii) modifications to the rights of the Holders. (iv) optional, contingent or unscheduled note calls. (v) defeasances. (vi) rating changes. (vii) adverse tax opinions or events adversely affecting the tax- exempt status of the Notes. (viii) unscheduled draws on the debt service reserves reflecting financial difficulties. (ix) unscheduled draws on the credit enhancements reflecting financial difficulties. sF2-71797.1 2 (x) substitution of the credit or liquidity providers or their failure to perform. (xi) release, substitution or sale of property securing repayment of the Notes. (b) Whenever the County obtains knowledge of the occurrence of a Listed Event, the County shall as soon as possible determine if the occurrence of such event would be material. (c) If the County determines that the occurrence of a Listed Event would be material, the County shall promptly file a notice of such occurrence with each Repository. SECTION 4. Termination of Reportin O�bli ag tion. The County's obligations under the Disclosure Certificate shall terminate upon the defeasance, prior redemption or payment in full of all of the Notes. SECTION 5. Additional Information. Nothing in the Disclosure Certificate shall be deemed to prevent the County from disseminating any other information, using the means of dissemination set forth in the Disclosure Certificate or any other means of communication, or including any other information in any notice of occurrence of a Listed Event, in addition to that which is required by the Disclosure Certificate. If the County chooses to include any information in any notice of occurrence of a Listed Event in addition to that which is specifically required by the Disclosure Certificate, the County shall have no obligation under the Disclosure Certificate to update such information or include it in any future notice of occurrence of a Listed Event. , SECTION 6. Default. In the event of a failure of the County to comply with any provision of the Disclosure Certificate, the Underwriter or any Holder may take such actions as may,be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the County to comply with its obligations under the Disclosure Certificate; provided, that the sole remedy under the Disclosure Certificate in the event of any failure of the County to comply with the Disclosure Certificate shall be an action to compel performance.hereunder. sF2-71797.1 3 V SECTION 7. Beneficiaries. The Disclosure Certificate shall inure solely to the benefit of the County, the Underwriter and the Holders, and shall create no rights in any other person or entity. Dated: July 1, 1997. COUNTY OF CONTRA COSTA By Phil Batchelor, County Administrator and Clerk of the Board of Supervisors of the County of Contra Costa sF2-71797.1 4 EXHIBIT A Nationally Recognized Municipal Securities Information Repositories approved by the Securities and Exchange Commission as of the date of the Disclosure Certificate: Bloomberg Municipal Repository P.O. Box 840 Princeton, NJ 08542-0840 Internet address: MUNIS@bloomberg.doe (609)279-3200 (609)279-3235 or(609)279-5963 [FAX] Contact: Dave Campbell Thompson Financial Services Secondary Market Disclosure 395 Hudson Street, 3rd Floor New York, NY 10014 Internet address: Disclosure@muller.com (212) 807-3814 (212) 989-9282 [FAX] Contact: Thomas Garske Disclosure, Inc. Document Augmentation/Municipal Securities 5161 River Road Bethesda, MD 20816 (301) 951-1450 (301) 718-2329 [FAX] Contact: Barry Sugarman (301)215-6015 JJ Kenny Information Services The Repository 65 Broadway, 16th Floor New York, NY 10006 (212) 770-4568 (212) 797-7994 [FAX] Contact: Joan Horai, Repository Moody's NRMSIR Public Finance Information Center 99 Church Street New York, NY 10007-2796 (800) 339-6306 (212) 553-1460[FAX] Contact: Claudette Stephensen (212) 553-0345 R.R. Donnelley Financial Attn: Municipal Securities Disclosure Archive 559 Main Street Hudson, MA 01749 (800) 580-3670 (508) 562-1969 [FAX] Contact: Jamie Johnson SP2-71797.1 5