HomeMy WebLinkAboutResolution No. 049-20 - Resolution Approving Conduit Financing and Housing Program for the Eastridge Estates Project
RESOLUTION
Authorizing the issuance, sale, and delivery of its conduit multi-family housing
revenue note (Eastridge Estates Project) series 2020 and approving a housing
program pursuant to Minnesota Statutes, Chapter 462C; approving the form of and
authorizing the execution and delivery of the note and related documents;
providing for the security, rights, and remedies with respect to the note; and,
granting approval for certain other actions with respect thereto.
WHEREAS, the City of Rochester, Minnesota (the “City”), is a home rule charter city duly
organized and existing under its Charter and the Constitution and laws of the State of
Minnesota; and
WHEREAS, pursuant to Minnesota Statutes, Chapter 462C, as amended (the “Act”), the
City is authorized to carry out the public purposes described in the Act by issuing revenue
bonds and notes or other obligations to finance or refinance multifamily housing
developments located within the City, and as a condition to the issuance of such revenue
obligations, adopt a housing program providing the information required by Section
462C.03, subdivision 1a, of the Act; and
WHEREAS, in the issuance of the City’s revenue obligations and in the making of a loan
to finance a multifamily housing development, the City may exercise, within its corporate
limits, any of the powers that the Minnesota Housing Finance Agency may exercise under
Minnesota Statutes, Chapter 462A, as amended, without limitation by any provisions of
Minnesota Statutes, Chapter 475, as amended; and
WHEREAS, Eastridge Housing Partners, LP, a limited partnership (the “Borrower”), has
requested that the City issue its revenue bonds, notes or other obligations, in one or more
series, at one time or from time to time pursuant to the Act, in an aggregate amount not
to exceed $15,000,000 (collectively, the “Obligations”) and lend the proceeds thereof to
the Borrower to (i) finance the acquisition, rehabilitation, and equipping of an
approximately 126-unit multifamily rental housing development, consisting of six 3-story
buildings and functionally related facilities, with its office located at 2009 17th Street SE
in the City, including funding capitalized interest and certain reserves and paying certain
costs of issuance of the Obligations (the “Project”) (ii) fund one or more reserve funds to
secure the timely payment of the Obligations, if necessary; (iii) pay interest on the
Obligations during the rehabilitation of the Project, if necessary; and (iv) pay the costs of
issuing the Obligations, if necessary; and
WHEREAS, Minnesota Statutes, Section 471.656, as amended, authorizes a municipality
to issue obligations to finance the acquisition or improvement of property located outside
of the corporate boundaries of such municipality if the obligations are issued under a joint
powers agreement between the municipality issuing the obligations and the municipality
in which the property to be acquired or improved is located. Pursuant to Minnesota
Statutes, Section 471.59, as amended, by the terms of a joint powers agreement entered
into through action of their governing bodies, two municipalities may jointly or
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cooperatively exercise any power common to the contracting parties or any similar
powers, including those which are the same except for the territorial limits within which
they may be exercised and the joint powers agreement may provide for the exercise of
such powers by one or more of the participating governmental units on behalf of the other
participating units; and
WHEREAS, Section 146(i)(6) of the Internal Revenue Code of 1986, as amended (the
“Code”) permits the reuse of bonding authority for affordable housing projects and treats
the reuse as a refunding for tax purposes if: (i) the “refunding” occurs within 4 years after
the original bonds were issued, (ii) the “refunding” bonds are issued within 6 months after
the principal payment of the original bonds, and (iii) the “refunding” bonds mature within
34 years of the original issue date; and
WHEREAS, the Borrower has represented to the City that the Obligations will meet the
requirements of Section 146(i)(6) of the Code with respect to the reuse of a portion of the
bonding authority from the Housing and Redevelopment Authority of the City of Saint
Paul, Minnesota (the “Saint Paul HRA”) Multifamily Housing Revenue Bonds (Pioneer
Press Apartments Project), Series 2017B and Multifamily Housing Revenue Bonds
(Pioneer Press Apartments Project), Series 2017C (collectively, the “Saint Paul HRA
Bonds”); and
WHEREAS, in order to better leverage public funding by recycling bonding authority as
permitted by Section 146(i)(6) of the Code, the Borrower, the City and the Saint Paul HRA
propose to enter into a Joint Powers Agreement whereby the parties will agree that the
City is authorized to use recycled bonding authority from the Saint Paul HRA Bonds to
finance the Project in accordance with Section 146(i)(6) of the Code (the “Joint Powers
Agreement”). The City will use up to approximately $5,000,000 of recycled bonding
authority from the Saint Paul HRA Bonds, pursuant to the Joint Powers Agreement, in
order to finance a portion of the Project; and
WHEREAS, in addition, the Issuer received an allocation of bonding authority from
Minnesota Department of Management and Budget (“MMB”) under Minnesota Statutes,
Chapter 474A, as amended (the “Allocation Act”), in the aggregate principal amount of
$10,393,031.55; and
WHEREAS, on August 19, 2019, the Common Council adopted a preliminary resolution
(the “Preliminary Resolution”) which constitutes a reimbursement resolution and an
official intent of the City to reimburse expenditures with respect to the Project from the
proceeds of tax-exempt revenue bonds in accordance with the provisions of Treasury
Regulations, Section 1.150-2; and
WHEREAS, the City has prepared a housing program providing the information required
by Section 462C.03, subdivision 1a of the Act (the “Housing Program”) regarding the
issuance by the City of Obligations in an aggregate principal amount of up to $15,000,000,
to finance the Project; and
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WHEREAS, a notice of public hearing (the “Public Notice”) was published in accordance
with the Act and Section 147(f) of the Internal Revenue Code of 1986, as amended (the
“Code”) with respect to (i) the required public hearing under the Code; (ii) the required
public hearing under Section 462C.04, subdivision 2, of the Act; (iii) the Housing Program;
and (iv) approval of the issuance of the Obligations and on this same date, the Common
Council conducted a public hearing on the date hereof at which a reasonable opportunity
was provided for interested individuals to express their views, both orally and in writing;
and
WHEREAS, the Public Notice was published at least 15 days before the regularly
scheduled meeting of the Common Council of the City (the “Common Council”), and on
this same date, the Common Council conducted a public hearing at which a reasonable
opportunity was provided for interested individuals to express their views, both orally and
in writing; and
WHEREAS, the Obligations will be purchased by Jones Lang LaSalle Multifamily, LLC,
or another financial institution selected by the Borrower (the “Funding Lender”) and the
Obligations will be issued pursuant to a Funding Loan Agreement, dated on or after March
1, 2020, (the “Funding Loan Agreement”), by and between the City, U.S. Bank National
Association, a national banking association, in its capacity as fiscal agent (the “Fiscal
Agent”), and the Funding Lender; and
WHEREAS, the proceeds derived from the sale of the Obligations (the “Funding Loan”)
will be loaned by the City to the Borrower pursuant to the terms of a Project Loan
Agreement, dated on or after March 1, 2020 (the “Project Loan Agreement”), by and
between the Borrower, the Fiscal Agent, and the City, whereby the City will apply the
proceeds derived from the sale of the Obligations to fund a loan to the Borrower to finance
the Project (the “Project Loan”). Additionally, the Borrower will issue a project note (the
“Project Note”) to the City to be endorsed by the City to the Fiscal Agent as security for
the Funding Loan; and
WHEREAS, as further security for the repayment of principal and interest on the
Obligations, the Borrower will execute a Multifamily Mortgage, Assignment of Rents,
Security Agreement and Fixture Filing (Minnesota), dated on or after March 1, 2020 (the
“Mortgage”), for the benefit of the City, which will be assigned by the City to the Fiscal
Agent; and
WHEREAS, the Obligations will be issued pursuant to this resolution and the Obligations
and the interest thereon: (i) shall be payable solely from the revenues pledged therefor
under the Project Loan Agreement, the Funding Loan Agreement, the Mortgage, and
additional sources of revenues provided by or on behalf of the Borrower; (ii) shall not
constitute a debt of the City within the meaning of any constitutional or statutory limitation;
(iii) shall not constitute nor give rise to a pecuniary liability of the City or a charge against
its general credit or taxing powers; (iv) shall not constitute a charge, lien, or encumbrance,
legal or equitable, upon any property of the City other than the City’s interest in the Project
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Loan Agreement and the Funding Loan Agreement; and (v) shall not constitute a general
or moral obligation of the City.
NOW, THEREFORE, BE IT RESOLVED by the Common Council of the City of Rochester,
Minnesota, as follows:
1. Findings. The City acknowledges, finds, determines, and declares that the
issuance of the Obligations is authorized by the Act and is consistent with the purposes
of the Act and that the issuance of the Obligations, and the other actions of the City under
the Funding Loan Agreement, the Project Loan Agreement, and this resolution constitute
a public purpose and are in the interests of the City. The Project constitutes a “qualified
residential rental project” within the meaning of Section 142(d) of the Code, and a
“multifamily housing development” authorized by the Act, and furthers the purposes of the
Act. In authorizing the issuance of the Obligations for the financing of the Project and the
related costs, the City’s purpose is and the effect thereof will be to promote the public
welfare of the City and its residents by providing or preserving affordable multifamily
housing developments for low or moderate income residents of the City and otherwise
furthering the purposes and policies of the Act.
2. Authorization of Obligations. For the purposes set forth above, there is
hereby authorized the issuance, sale, and delivery of the Obligations in one or more series
in the maximum aggregate principal amount not to exceed $15,000,000. The Obligations
shall bear interest at the rates, shall be designated, shall be numbered, shall be dated,
shall mature, shall be in the aggregate principal amount, shall be subject to redemption
prior to maturity, shall be in such form, and shall have such other terms, details, and
provisions as are prescribed in the Funding Loan Agreement, in substantially the form
now on file with the City, with necessary and appropriate variations, omissions, and
insertions (including changes to the aggregate principal amount of the Obligations, the
stated maturity of the Obligations, the interest rates on the Obligations and the terms of
redemption of the Obligations) as are approved as evidenced by the execution thereof as
provided in Section 8 hereof. The City hereby authorizes the Obligations to be issued, in
whole or in part, as “tax-exempt bonds,” the interest on which is excludable from gross
income for federal and State of Minnesota income tax purposes or as a taxable bond. The
Obligations shall be special, limited obligations of the City payable solely from the
revenues provided by the Borrower pursuant to the Project Loan Agreement and other
funds pledged pursuant to the Mortgage and the Funding Loan Agreement; the City does
not pledge its general credit or taxing powers or any funds of the City to the payment of
the Obligations.
All of the provisions of the Obligations, when executed as authorized herein, shall
be deemed to be a part of this resolution as fully and to the same extent as if incorporated
verbatim herein and shall be in full force and effect from the date of execution and delivery
thereof.
3. Financing Structure. The Obligations shall be sold to the Funding Lender
under the terms and conditions of the Funding Loan Agreement and the proceeds derived
from the sale of the Obligations shall be loaned to the Borrower in accordance with the
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terms and conditions of the Project Loan Agreement. The Borrower shall apply the
proceeds of the Loan made pursuant to the terms and conditions of the Project Loan
Agreement to the payment of a portion of the capital costs of the Project and related costs.
The Loan repayments to be made by the Borrower under the Project Loan Agreement
are to be fixed so as to produce revenues sufficient to pay the principal of, premium, if
any, and interest on the Obligations when due. Pursuant to the Funding Loan Agreement,
the City will assign its rights to the basic payments and certain other rights and interests
under the Project Loan Agreement, the Project Loan, the Project Note, the Mortgage, and
certain moneys and securities held by the Fiscal Agent in the funds and accounts
established under the Funding Loan Agreement to the Fiscal Agent.
The Common Council hereby provides that the Funding Loan Agreement shall
provide the terms and conditions, covenants, rights, obligations, duties, and agreements
of the owners of the Obligations and the City as set forth therein.
All of the provisions of the Funding Loan Agreement, when executed as authorized
herein, shall be deemed to be a part of this resolution as fully and to the same extent as
if incorporated verbatim herein and shall be in full force and effect from the date of
execution and delivery thereof.
All of the provisions of the Project Loan Agreement, when executed and delivered
as authorized herein, shall be deemed to be a part of this resolution as fully and to the
same extent as if incorporated verbatim herein and shall be in full force and effect from
the date of execution and delivery thereof.
4. Compliance with Certain Rental and Occupancy Restrictions as to the
Project. To ensure compliance with certain rental and occupancy restrictions imposed by
the Act and Section 142(d) of the Code and to ensure compliance with certain restrictions
imposed by the City, the Mayor and City Clerk are also hereby authorized and directed to
execute and deliver a Regulatory Agreement, dated on or after March 1, 2020 (the
“Regulatory Agreement”), among the City, the Borrower, and the Fiscal Agent.
5. Approval of Housing Program. The Housing Program, in substantially the
form on file with the City, is hereby approved. The City Clerk is hereby authorized to do
all other things and take all other actions as may be necessary or appropriate to carry out
the Housing Program in accordance with the Act and any other applicable laws and
regulations.
6. Approval of Forms; Execution. The Mayor and the City Clerk (the “City
Officials”) are hereby authorized and directed to execute and deliver the Funding Loan
Agreement, the Joint Powers Agreement, the Project Loan Agreement, the Obligations,
the Regulatory Agreement, an Assignment of the Multifamily Mortgage, Assignment of
Rents, Security Agreement and Fixture Filing (the “Assignment of Mortgage”), from the
City to the Fiscal Agent, any consents or such other documents as are necessary or
appropriate in connection with the issuance, sale, and delivery of the Obligations,
including without limitation various certificates of the City, the Information Return for Tax-
Exempt Private Activity Bond Issues, Form 8038, an endorsement to the tax certificate of
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the Borrower, and similar documents (collectively, the “Financing Documents”). All of the
provisions of the Financing Documents, when executed and delivered as authorized
herein, shall be deemed to be a part of this resolution as fully and to the same extent as
if incorporated verbatim herein and shall be in full force and effect from the date of
execution and delivery thereof. The Financing Documents shall be in substantially the
forms on file with the City which are hereby approved, with such necessary and
appropriate variations, omissions, and insertions as are approved by bond counsel to the
City and do not materially adversely change the substance thereof with respect to the
City, and as the City Officials, in their discretion, shall determine, and the execution
thereof by the City Officials shall be conclusive evidence of such determinations.
7. Security for Obligations. The City hereby authorizes the Borrower to
provide such security for payment of its obligations under the Funding Loan Agreement
and the Project Loan Agreement and for payment of the Obligations, including the
Mortgage, one or more guaranties, or any other security agreed upon by the Borrower,
Fiscal Agent, and the Funding Lender, and the City hereby approves the execution and
delivery of such security.
8. Bond Opinion. The City hereby authorizes Kennedy & Graven, Chartered,
as bond counsel, to prepare, execute, and deliver its approving legal opinions with respect
to the Obligations.
9. Council Authority; Limitation of Liability. Except as otherwise provided in
this resolution, all rights, powers, and privileges conferred and duties and liabilities
imposed upon the City or the Common Council by the provisions of this resolution or of
the aforementioned documents shall be exercised or performed by the City or by such
members of the Common Council, or such officers, board, body or agency thereof as may
be required or authorized by law to exercise such powers and to perform such duties.
No covenant, stipulation, obligation or agreement herein contained or contained in
the aforementioned documents shall be deemed to be a covenant, stipulation, obligation
or agreement of any member of the Common Council, or any officer, agent or employee
of the City in that person’s individual capacity, and neither the Common Council nor any
officer or employee executing the Obligations shall be personally liable on the Obligations
or be subject to any personal liability or accountability by reason of the issuance thereof.
No provision, covenant or agreement contained in the aforementioned documents,
the Obligations, or in any other document relating to the Obligations, and no obligation
therein or herein imposed upon the City or the breach thereof, shall constitute or give rise
to a general or moral obligation of the City or any pecuniary liability of the City or any
charge upon its general credit or taxing powers. In making the agreements, provisions,
covenants, and representations set forth in such documents, the City has not obligated
itself to pay or remit any funds or revenues, other than funds and revenues derived from
the Funding Loan Agreement and the Project Loan Agreement which are to be applied to
the payment of the Obligations, as provided therein.
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Except as otherwise expressly provided herein, nothing in this resolution or in the
aforementioned documents expressed or implied, is intended or shall be construed to
confer upon any person or firm or corporation, other than the City, any holder of the
Obligations issued under the provisions of this resolution, any right, remedy or claim, legal
or equitable, under and by reason of this resolution or any provisions hereof, this
resolution, the aforementioned documents, and all of their provisions being intended to
be and being for the sole and exclusive benefit of the City, and any holder from time to
time of the Obligations issued under the provisions of this resolution.
10. Severability. In case any one or more of the provisions of this resolution
(other than the provisions contained in the last sentence of Section 2, Sections 9 and 13
and any other provisions limiting the liability of the City, the City Officials, or any officer,
employee, or agent of the City contained herein) or of the aforementioned documents, or
of the Obligations issued hereunder shall for any reason be held to be illegal or invalid,
such illegality or invalidity shall not affect any other provision of this resolution, or of the
aforementioned documents, or of the Obligations, but this resolution, the aforementioned
documents, and the Obligations shall be construed and endorsed as if such illegal or
invalid provisions had not been contained therein.
11. Validity. The Obligations, when executed and delivered, shall contain a
recital that it is issued pursuant to the Act, and such recital shall be conclusive evidence
of the validity of the Obligations and the regularity of the issuance thereof, and that all
acts, conditions, and things required by the laws of the State of Minnesota relating to the
adoption of this resolution, to the issuance of the Obligations, and to the execution of the
aforementioned documents to happen, exist, and be performed precedent to the
execution of the aforementioned documents have happened, exist, and have been
performed as so required by law.
12. Authorization; Direction. The officers of the City, bond counsel, other
attorneys, and other agents or employees of the City are hereby authorized to do all acts
and things required of them by or in connection with this resolution, the aforementioned
documents, and the Obligations, for the full, punctual, and complete performance of all
the terms, covenants, and agreements contained in the Obligations, the aforementioned
documents, and this resolution. If for any reason the Mayor or the City Clerk is unable to
execute and deliver the documents referred to in this Resolution, such documents may
be executed by any member of the Common Council or any officer of the City delegated
the duties of the Mayor or the City Clerk with the same force and effect as if such
documents were executed and delivered by the Mayor or the City Clerk.
13. City Costs. The Borrower shall pay the administrative fee of the City as
provided in the Funding Loan Agreement. The Borrower will also pay, or, upon demand,
reimburse the City for payment of, any and all costs incurred by the City in connection
with the Project and the issuance of the Obligations, whether or not the Obligations is
issued, including any costs for attorneys’ fees. The Borrower shall indemnify the City
against all liabilities, losses, damages, costs and expenses (including attorney’s fees and
expenses incurred by the City) arising with respect to the Project or the Obligations, as
further provided in the Project Loan Agreement.
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14. Future Amendments and Consents. The authority to approve, execute and
deliver future amendments to the Financing Documents herein authorized entered into by
the City in connection with the issuance of the Obligations and any consents required
under the Financing Documents is hereby delegated to the City Officials upon
consultation with the City’s Bond Counsel, subject to the following conditions: (a) such
amendments or consents do not require the consent of the holder of the Obligations or
such consent has been obtained; (b) such amendments or consents do not materially
adversely affect the interests of the City; (c) such amendments or consents do not
contravene or violate any policy of the City; and (d) such amendments or consents are
acceptable in form and substance to the City’s Bond Counsel. The authorization hereby
given shall be further construed as authorization for the execution and delivery of such
certificates and related items as may be required to demonstrate compliance with the
agreements being amended and the terms of this Resolution. The execution of any
instrument by the City Officials shall be conclusive evidence of the approval of such
instruments in accordance with the terms hereof. In the absence of either of the City
Officials, any instrument authorized by this paragraph to be executed and delivered may
be executed by the officer of the City or the City authorized to act in his/her place and
stead.
15. Governmental Program. The City has established a governmental program
of acquiring purpose investments for qualified residential rental projects. The
governmental program is one in which the following requirements of §1.148-1(b) of the
federal regulations relating to tax-exempt obligations shall be met:
(a) the program involves the origination or acquisition of purpose
investments;
(b) at least 95% of the cost of the purpose investments acquired under
the program represents one or more loans to a substantial number of persons
representing the general public, states or political subdivisions, 501(c)(3)
organizations, persons who provide housing and related facilities, or any
combination of the foregoing;
(c) at least 95% of the receipts from the purpose investments are used
to pay principal, interest, or redemption prices on issues that financed the program,
to pay or reimburse administrative costs of those issues or of the program, to pay
or reimburse anticipated future losses directly related to the program, to finance
additional purpose investments for the same general purposes of the program, or
to redeem and retire governmental obligations at the next earliest possible date of
redemption;
(d) the program documents prohibit any obligor on a purpose investment
financed by the program or any related party to that obligor from purchasing
Obligations of an issue that finances the program in an amount related to the
amount of the purpose investment acquired from that obligor; and
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(e) the City shall not waive the right to treat the investment as a program
investment.
16. Effective Date. This Resolution shall be in full force and effect from and after
its approval.
PASSED AND ADOPTED BY THE COMMON COUNCIL OF THE CITY OF
ROCHESTER, MINNESOTA, THIS __________ DAY OF _______________, 2020.
___________________________________
PRESIDENT OF SAID COMMON COUNCIL
ATTEST: __________________________
CITY CLERK
APPROVED THIS _____ DAY OF ______________________, 2020.
___________________________________
MAYOR OF SAID CITY
(Seal of the City of
Rochester, Minnesota)
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