Loading...
10-18-2011 - Letter of Credit Substitution for the 2004 Lease R - Item 9 (2).pdfThomas Bachman Assistant City Manager/ Finance Director ($108,585), with a 3-year commitment. This would generate a savings of approximately $72,000 per year. All other terms and conditions of the offers were generally the same. The interest rate paid on the Bonds is partly based on letter of credit bank's credit rating. Because Wells Fargo has a better rating than Union Bank, staff believes a substitution will not negatively impact the extremely low interest rate carried by the Bonds, currently 0.26%, and may actually have a positive impact. Therefore, staff is recommending that the City and the PFA substitute a Wells Fargo Bank letter of credit in place of the Union Bank letter of credit securing the Bonds. The substitution will require that all existing Bondholders tender their Bonds and there be a complete remarketing of the Bonds to new investors based on the Wells Fargo Bank letter of credit. This remarketing requires a complete update of the original official statement prepared in connection with the issuance of the Bonds in 2004. The substitution of the letter of credit and the remarketing of the Bonds are expected to occur on or about November 30, 2011. In addition, staff is recommending that the remarketing agent for the Bonds be changed from Gates Capital to Wells Fargo Bank. Wells Fargo Bank offered these services at a lower fee (.1% vs. .125%) than the current provider. This action is expected to generate a savings of about $3,000 per year. The City resolution approves the distribution of the Reoffering Memorandum by the Remarketing Agent in connection with the remarketing of the Bonds, and the execution of the Reimbursement Agreement with Wells Fargo Bank in connection with the delivery of the letter of credit. The Reoffering Memorandum describes the security for the Bonds and financial information relating to the City. The Reimbursement Agreement governs how the City will repay Wells Fargo Bank for any draws under the Letter of Credit, as well as the fees payable to Wells Fargo Bank. The Authority resolution approves the distribution of the Reoffering Memorandum by the Remarketing Agent in connection with the remarketing of the Bonds, minor amendments to the existing Bond Indenture to accommodate the substitution of the letter of credit, and the execution of the Remarketing Agreement with Wells Fargo Bank. The Remarketing Agreement governs how the Remarketing Agent will be paid for services. Copies of the draft forms of the Reimbursement Agreement, amendment to the Bond Indenture and the Remarketing Agreement are on file with the City Clerk. The draft Reoffering Memorandum is included with the staff report. The resolutions authorize staff to make changes to these documents as needed to reflect the terms of the transaction as negotiated with the Wells Fargo Bank, and to update any financial information relating to the City in the Reoffering Memorandum. ALTERNATIVES: Renew the letter of credit with Union Bank and keep the current remarketing agent. FISCAL IMPACT: The City will pay certain one-time expenses in connection with the substitution of the letter of credit. These include the fees of legal counsel to Wells Fargo, bond counsel fees, and fees for preparation and distribution of the Reoffering Memorandum. The total expenses of the substitution are expected to be approximately $45,500. This amount will be more than recouped in the first year due to the $75,000 annual savings on the letter of credit fees. Dennis Swink City Controller Prepared by: Finance Docs/Agenda Items/Bonds/Bonds-2004 LOC Substitution 10-18-11 RESOLUTION NO. RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WEST COVINA AUTHORIZING THE EXECUTION AND DELIVERY BY THE CITY OF A REIMBURSEMENT AGREEMENT, APPROVING A REOFFERING MEMORANDUM AND THE TAKING OF OTHER CERTAIN ACTIONS IN CONNECTION THEREWITH NOW, THEREFORE, BE IT RESOLVED by the City Council (the "City Council") of the City of West Covina (the "City") as follows: WHEREAS, the City and the West Covina Community Development Commission, as successor to the Redevelopment Agency of the City of West Covina (the "Commission") have heretofore entered into a Joint Exercise of Powers Agreement establishing the West Covina Public Financing (the "Authority") for the purpose, among others, of issuing its bonds to be used to provide financial assistance to the City and the Commission; and WHEREAS, the Authority has previously issued $8,165,000 aggregate principal amount of West Covina Public Financing Authority Variable Rate Lease Revenue Bonds, 2004 Series A (Golf Course Project) and its $5,335,000 Variable Rate Lease Revenue Bonds, 2004 Series B (Golf Course Project) (collectively, the "2004 Bonds") in order to assist the City in the financing of the acquisition, construction and equipping of certain public capital improvements within the City; and WHEREAS, the 2004 Bonds were issued pursuant to an Indenture, dated August 1, 2004 (the "Indenture"), by and between the Authority and U.S. Bank National Association, a national banking association organized and existing under the laws of the United States, as Trustee (the "Trustee"); and WHEREAS, the 2004 Bonds were executed and delivered as variable rate obligations supported by a direct pay letter of credit delivered pursuant to a reimbursement agreement, dated as of August 1,2004, by and between the City and Union Bank of California, N.A.; WHEREAS, the City and the Authority desire to cause the delivery of a substitute letter of credit to be issued pursuant to the terms of a Reimbursement Agreement, dated as of November 1, 2011 (the "Reimbursement Agreement"), by and between the City and Wells Fargo Bank, National Association; and WHEREAS, in connection with the remarketing of the 2004 Bonds with the support of the substitute letter of credit, a Reoffering Memorandum has been prepared for delivery to holders of the 2004 Bonds; WHEREAS, there have been prepared and submitted to this meeting the form of the Reimbursement Agreement and the Reoffering Memorandum; NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of West Covina (the "City Council") as follows: Section 1. Approval of the Reimbursement Agreement. The Reimbursement Agreement, in substantially the form submitted to this meeting and made a part hereof as though set forth in full herein, is hereby approved. The Mayor, the City Manager, the Assistant City Manager and the Controller (the "Authorized Officers") are hereby authorized and directed, for and in the name of the City, to execute and deliver the Reimbursement Agreement in substantially the form presented to this meeting, with such changes, insertions and omissions as the such officer executing the same may require or approve, such requirement or approval to be conclusively evidenced by the execution of the Reimbursement Agreement by such officer. Section 2. Approval of the Reoffering Memorandum. The Reoffering Memorandum, in substantially the form presented to this meeting and made a part hereof as though set forth in full herein, with such changes, insertions and omissions therein as may be approved by an Authorized Officer, is hereby approved, and the use of the Reoffering Memorandum in connection with the remarketing of the 2004 Bonds is hereby authorized and approved. Section 3. The Mayor, the City Manager, the Assistant City Manager and the Controller or any member of the City Council, is hereby authorized and directed to execute and deliver any and all documents and instruments and to do and cause to be done any and all acts and things necessary or proper for carrying out the transactions contemplated by this Resolution. Section 4. This Resolution shall take effect from and after its passage and approval. Section 5. The City Clerk shall certify to the adoption of this Resolution. 50444604.2 APPROVED AND ADOPTED this day of October, 2011. Mayor ATTEST: City Clerk , CITY CLERK of the City of West Covina, do hereby certify that the foregoing resolution no. was duly adopted by the City Council of the City of West Covina, California, at a regular meeting thereof held on , 2011. YES: NOES: ABSENT: City Clerk APPROVED AS TO FORM: City Attorney 50444604.2 3 RESOLUTION NO.- A RESOLUTION OF THE WEST COVINA PUBLIC FINANCING AUTHORITY AUTHORIZING THE EXECUTION AND DELIVERY BY THE AUTHORITY OF A FIRST AMENDMENT TO INDENTURE AND A REMARKETING AGREEMENT, AUTHORIZING THE DISTRIBUTION OF A REOFFERING MEMORANDUM REGARDING WEST COVINA PUBLIC FINANCING AUTHORITY VARIABLE RATE LEASE REVENUE BONDS, 2004 SERIES A AND SERIES B (GOLF COURSE PROJECT), AND THE TAKING OF OTHER CERTAIN ACTIONS IN CONNECTION THEREWITH WHEREAS, the City of West Covina (the "City") and the West Covina Community Development Commission, as successor to the Redevelopment Agency of the City of West Covina (the "Commission") have heretofore entered into a Joint Exercise of Powers Agreement establishing the West Covina Public Financing Authority (the "Authority") for the purpose, among others, of issuing its bonds to be used to provide financial assistance to the City and the Commission; and WHEREAS, the Authority has previously issued $8,165,000 aggregate principal amount of West Covina Public Financing Authority Variable Rate Lease Revenue Bonds, 2004 Series A (Golf Course Project) and its $5,335,000 Variable Rate Lease Revenue Bonds, 2004 Series B (Golf Course Project) (collectively, the "2004 Bonds") in order to assist the City in the financing of the acquisition, construction and equipping of certain public capital improvements within the City; and WHEREAS, the 2004 Bonds were issued pursuant to an Indenture, dated as of August 1, 2004 (the "Indenture"), by and between the Authority and U.S. Bank National Association, a national banking association organized and existing under the laws of the United States, as Trustee (the "Trustee"); and WHEREAS, the 2004 Bonds were executed and delivered as variable rate obligations supported by a direct pay letter of credit delivered pursuant to a reimbursement agreement, dated as of August 1, 2004, by and between the City and Union Bank of California, N.A.; WHEREAS, the Authority desires to clarify the requirements for, and to explicitly provide for the substitution of a letter of credit provider through the delivery of a First Amendment to the Indenture, dated as of November 1, 2011 (the "First Amendment to Indenture"), by and between the Authority and the Trustee; and WHEREAS, the Authority desires to cause Wells Fargo Bank, National Association ("Wells Fargo") to deliver a substitute letter of credit issued pursuant to the terms of a Reimbursement Agreement, dated as of November 1, 2011 (the "Reimbursement Agreement"), by and between the City and Wells Fargo; and 50444584.3 WHEREAS, the 2004 Bonds will be remarketed pursuant to a Remarketing Agreement, dated as of October 1, 2011, as amended (the "Remarketing Agreement"), by and among the Authority and Wells Fargo Bank, National Association, as remarketing agent; and WHEREAS, in connection with the remarketing of the 2004 Bonds with the support of the substitute letter of credit, a Reoffering Memorandum has been prepared for delivery to holders of the 2004 Bonds; WHEREAS, there have been prepared and submitted to this meeting forms of: (a) The First Amendment to the Indenture; (b) the Remarketing Agreement; and (c) the Reoffering Memorandum; WHEREAS, the Authority has reviewed the documentation related to the remarketing of the 2004 Bonds which documentation is on file with the secretary of the Authority; NOW, THEREFORE, BE IT RESOLVED by the Board of Directors of the West Covina Public Financing Authority as follows: Section 1. Approval of Recitals. All of the recitals herein contained are true and correct and the Board of Directors of the Authority (the "Board") so finds. Section 2. Approval of First Amendment. The First Amendment to the Indenture, in substantially the form submitted to this meeting and made a part hereof as though set forth in full herein, be and the same is hereby approved. The Chairman, the Vice Chairman, the Executive Director and the Assistant Director of the Authority, and any designee thereof, (the "Authorized Officers") are, and each of them is, hereby authorized and directed, for and in the name of the Authority, to execute and deliver the First Amendment to Indenture in substantially the form presented to this meeting, with such changes, insertions and omissions as the Authorized Officer executing the same may require or approve, such requirement or approval to be conclusively evidenced by the execution of the First Amendment to the Indenture by such Authorized Officer. Section 3. Approval of the Remarketing Agreement. The Remarketing Agreement, in substantially the form submitted to this meeting and made a part hereof as though set forth in full herein, is hereby approved. The Authorized Officers are, and each of them is, hereby authorized and directed, for and in the name of the Authority, to execute and deliver the Reimbursement Agreement in substantially the form presented to this meeting, with such changes, insertions and omissions as the Authorized Officer executing the same may require or approve, such requirement or approval to be conclusively evidenced by the execution of the Remarketing Agreement by such Authorized Officer. Section 4. Approval of the Reoffering Memorandum. The Reoffering Memorandum, in substantially the form presented to this meeting and made a part hereof as though set forth in full herein, with such changes, insertions and omissions therein as may be approved by an Authorized Officer, is hereby approved, and the use of the Reoffering Memorandum in connection with the remarketing of the 2004 Bonds is hereby authorized and approved. 50444584.3 2 Section 5. Further Authorization. The Authorized Officers are, and each of them hereby is, authorized and directed to execute and deliver any and all documents and instruments and to do and cause to be done any and all acts and things necessary or proper for carrying out the execution and delivery of the First Amendment to Indenture, the Reimbursement Agreement, the Remarketing Agreement, the Reoffering Memorandum, and the transactions contemplated by the agreements or documents referenced in this Resolution. Section 6. Effective Date. This Resolution shall take effect immediately upon i adoption. Section 7. Certification. The Secretary of the Authority shall certify the adoption of this Resolution. APPROVED AND ADOPTED at a regular meeting held On October , 201 Chairman ATTEST: Secretary APPROVED: City Attorney Arnold Alvarez-Glasman 50444584.3 STATE OF CALIFORNIA ) SS COUNTY OF LOS ANGELES , SECRETARY of West Covina Public Financing Authority, do hereby certify that the foregoing Resolution No. was passed and adopted at a regular meeting of said Board of Directors on the th day of October 2011, by the following vote, to wit: AYES: NOES: ABSTENTIONS: ABSENT: Secretary APPROVED AS TO FORM: City Attorney Arnold Alvarez-Glasman 50444584.3 REOFFIRI ‘1ORAND1 D 2011 (Dli‘VI OF 0/11/11) REOFFERING - NOT A NEW ISSUE - BOOK-ENTRY-ONLY RATING Standard & Poor's: (See "CONCLUDING INFORMATION - Rating on the Bonds" herein) On August 19, 2004, Fulbright & Jaworski L.L.P., Los Angeles, California, delivered its opinion in connection with the delivery of the Bonds. Such opinion stated that, under existing law, interest on the Bonds is exempt from personal income taxes of the State of California and, assuming compliance with the tax covenants described herein, interest on the Bonds is excluded pursuant to section 103(a) of the Internal Revenue Code of 1986 (the "Code"), from the gross income of the owners thereof for federal income tax purposes and is not an item of tax preference for purposes of the federal alternative minimum tax. In the further opinion of Fulbright & Jaworski L.L.P., dated August 19, 2004, such interest is exempt from State of California personal income taxes. In connection with the delivery of the Letter of Credit, Fulbright & Jaworski L.L.P., Bond Counsel, will deliver its opinion that such delivery of the Letter of Credit will not, in and of itself adversely affect the exclusion from gross income of the interest due with respect to the Bonds. Fulbright & Jcrworski L.L.P has not taken and does not intend to take any action to update its opinion or to determine if interest on the Bonds is presently excluded from gross income for federal income tax purposes or exempt from State of California personal income taxes. See, however; "LEGAL MATTERS - Tax Matters" herein. LOS ANGELES COUNTY STATE OF CALIFORNIA WEST COVINA PUBLIC FINANCING AUTHORITY $8,165,000 VARIABLE RATE LEASE REVENUE BONDS, 2004 SERIES A $5,335,000 VARIABLE RATE LEASE REVENUE BONDS, 2004 SERIES B (GOLF COURSE PROJECT) 2004 Series A CUSIP: 95236PAY6 2004 Series B CUSIP: 95236PAZ3 Dated: Date of Initial Delivery Due: May 1,2034 This Reoffering Memorandum amends, supplements and restates the original Official Statement dated August 12, 2004. The Variable Rate Lease Revenue Bonds, 2004 Series A and Variable Rate Lease Revenue Bonds, 2004 Series B (collectively, the "Bonds") were originally issued in the principal amounts of $8,165,000 and $5,335,000, respectively, pursuant to an Indenture dated as of August 1, 2004 (the "Indenture") by and between the West Covina Public Financing Authority (the "Authority") and U.S. Bank National Association as trustee (the "Trustee") and are payable from Lease Payments to be made by the City of West Covina (the "City") to the Authority as rental for certain public facilities (the "Leased Property") pursuant to a Lease Agreement (the "Lease"), as described herein and from certain funds held under the Indenture and insurance or condemnation awards. The City is required under the Lease to make payments in each fiscal year in consideration of the use and possession of the Leased Property from legally available funds of the City, in an amount sufficient to pay the annual principal and interest due on the Bonds then outstanding, subject to abatement, as described herein (see "SOURCES OF PAYMENT FOR THE BONDS" and "RISK FACTORS" herein). Payment of the principal and Purchase Price of and interest on the Bonds is supported by an irrevocable, direct-pay letter of credit (the "Credit Facility") to be issued by Wells Fargo Bank, National Association (the "Credit Entity"). [Bank Logo] The Credit Facility will permit the Trustee to draw up to an amount sufficient to pay (i) the principal of the Bonds when due, (ii) the Purchase Price of the Bonds that are purchased pursuant to tenders and that are not remarketed, and (iii) up to 42 days' interest accrued on the Bonds, all as more completely described in this Reoffering Memorandum. The Credit Facility will expire on November 29, 2014 and, unless extended or unless an alternate letter of credit, or other security meeting the requirements of the Indenture is provided in replacement therefor, the Bonds are subject to mandatory tender for purchase as described herein (see "THE BONDS - Tender and Purchase of Bonds - Mandatory Tender of Bonds" herein). On November 30, 2011, the Bonds will be remarketed at a variable interest rate determined weekly (the "Variable Rate"), and, after the Fixed Rate Conversion Date (as defined herein), semiannually as described herein at fixed interest rates (the "Fixed Rates") determined in accordance with the Indenture (see "THE BONDS - General Provisions" herein). Each Variable Rate shall be determined by Wells Fargo Securities, as remarketing agent (the "Remarketing Agent"), having due regard for prevailing financial market conditions, to be the rate (but not higher than the rate) which would be necessary in order to enable the Remarketing Agent to remarket tendered Bonds at a price equal to 100% of the principal amount thereof on the date such Variable Rate is determined. While bearing interest at the Variable Rate, interest on the Bonds will be payable on the first Business Day of each calendar month. So long as the Bonds bear interest at the Variable Rate, Bondholders will have the right to demand to have their Bonds purchased in the manner described herein. Bonds bearing a Variable Rate being converted to Fixed Rates will be subject to mandatory tender for purchase on the Fixed Rate Conversion Date, as described herein. The Bonds are also subject to optional and mandatory sinking fund prepayment and mandatory tender prior to maturity as described herein. See "THE BONDS - Tender and Purchase of Bonds" and "- Redemption" herein. This Reoffering Memorandum describes the Bonds only while bearing interest at a Variable Rate. Investors should not rely upon the information in this Reoffering Memorandum in the event that the method of determining the interest rate on the Bonds is changed to a Fixed Rate. Rather, investors should rely upon the offering document used in connection with any such change in interest rate mode. This cover page contains certain information for general reference only It is not intended to be a summary of the security or terms of the Bonds. Investors are advised to read the entire Reoffering Memorandum to obtain information essential to making an informed investment decision. Certain legal matters will be passed on for the Authority and the City by Alvarez-Glasman & Colvin, West Covina, California, City Attorney and by Fulbright & Jaworski L.L.P., Los Angeles, California, as Bond Counsel and Disclosure Counsel. Certain legal matters will be passed on for the Credit Entity by Karl Christiansen, Senior Counsel of Wells Fargo Bank, National Association and by its Counsel, Kathleen C. Johnson, Esq. Attorney at Law. It is anticipated that the remarketed Bonds, in book-entry form, will be available for delivery through the facilities of The Depository Trust Company on or about November 30, 2011 (see "APPENDIX E - BOOK-ENTRY-ONLY SYSTEM" herein). The date of the Reoffering Memorandum is , 2011. Wells Fargo Securities F,NERAL INFORMATION ABOUT THIS REOFFERING MEMORANDUM Use of Reoffering Memorandum. This Reoffering Memorandum is submitted in connection with the offer and sale of the Bonds referred to herein and may not be reproduced or used, in whole or in part, for any other purpose. This Reoffering Memorandum is not to be construed as a contract with the purchasers of the Bonds. Estimates and Forecasts. When used in this Reoffering Memorandum and in any continuing disclosure by the Authority or the City in any press release and in any oral statement made with the approval of an authorized officer of the City or any other entity described or referenced herein, the words or phrases "will likely result," "are expected to," "will continue," "is anticipated," "estimate," "project," "forecast," "expect," "intend" and similar expressions identify "forward-looking statements" within the meaning of the Private Securities Litigation Reform Act of 1995. Such statements are subject to risks and uncertainties that could cause actual results to differ materially from those contemplated in such forward- looking statements. Any forecast is subject to such uncertainties. Inevitably, some assumptions used to develop the forecasts will not be realized and unanticipated events and circumstances may occur. Therefore, there are likely to be differences between forecasts and actual results, and those differences may be material. Limit of Offering. No dealer, broker, salesperson or other person has been authorized by the Authority or the City to give any information or to make any representations in connection with the offer or sale of the Bonds other than those contained herein and if given or made, such other information or representation must not be relied upon as having been authorized by the Authority, the City, the Financial Advisor or the Remarketing Agent. This Reoffering Memorandum does not constitute an offer to sell or the solicitation of an offer to buy nor shall there be any sale of the Bonds by a person in any jurisdiction in which it is unlawful for such person to make such an offer, solicitation or sale. Involvement of Remarketing Agent. The Remarketing Agent has submitted the following statement for inclusion in this Reoffering Memorandum: The Remarketing Agent has reviewed the information in this Reoffering Memorandum in accordance with, and as a part of, its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction, but the Remarketing Agent does not guarantee the accuracy or completeness of such information. Information Subject to Change. The information and expressions of opinions herein are subject to change without notice and neither delivery of this Reoffering Memorandum nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the Authority or the City or any other entity described or referenced herein since the date hereof. All summaries of the documents referred to in this Reoffering Memorandum are made subject to the provisions of such documents, respectively, and do not purport to be complete statements of any or all of such provisions. THE BONDS HAVE NOT BEEN REGISTERED UNDER THE SECURITIES ACT OF 1933, AS AMENDED, IN RELIANCE UPON AN EXCEPTION FROM THE REGISTRATION REQUIREMENTS CONTAINED IN SUCH ACT. THE BONDS HAVE NOT BEEN REGISTERED OR QUALIFIED UNDER THE SECURITIES LAWS OF ANY STATE. The CUSIP number of the Bonds is provided by Standard & Poor's CUSIP® Service Bureau and is set forth herein for convenience of reference only. Neither the Authority nor the Remarketing Agent takes any responsibility for the accuracy of such number. WEST COVINA PUBLIC FINANCING AUTHORITY, CALIFORNIA AUTHORITY BOARD MEMBERS AND CITY COUNCIL Steve Herfert, Mayor Mike Touhey, Mayor Pro Tern Karin Armbrust, Councibnember Sherri Lane, Councilmember Shelley Sanderson, Councilmember CITY STAFF Andrew G. Pasmant, City Manager Thomas E. Bachman, Assistant City Manager/Finance Director Chris Freeland, Deputy City Manager Dennis Swink, Controller Sue Rush, City Clerk Marian Smithson, City Treasurer Arnold M. Alvarez-Glasman, City Attorney PROFESSIONAL SERVICES Bond Counsel and Disclosure Counsel Fulbright & Jaworski L.L.P. Los Angeles, California Financial Advisor Harrell & Company Advisors, LLC Orange, California Credit Entity Wells Fargo Bank, National Association Los Angeles, California Trustee and Tender Agent U.S. Bank National Association Los Angeles, California Remarketing Agent Wells Fargo Securities Los Angeles, California TABLE OF CONTENTS INTRODUCTION 1 Appropriations Limit 30 The Authority 1 General Fund Revenues and Expenditures 30 The City 1 Ad Valorem Property Taxes 33 The Bonds 1 Taxable Property and Assessed Valuation 33 Security and Sources of Repayment 2 Redevelopment Agencies 34 Information Concerning this Reoffering Largest Taxpayers 35 Memorandum 3 State Legislative Shift of Property Tax Allocation....36 Local Taxes 36 THE BONDS 4 Motor Vehicle License Fees 37 General Provisions 4 Tender and Purchase of Bonds 6 Retirement Programs 37 Other Post Employment Benefits 42 Redemption 9 Employee Relations and Collective Bargaining 44 SPECIAL CONSIDERATIONS RELATING Risk Management 44 TO THE BONDS SUBJECT TO OPTIONAL City Investment Policy and Portfolio 45 TENDER AND REMARKETING 12 Indebtedness of the City 46 The Remarketing Agent is Paid by the Authority 12 Direct and Overlapping Debt 47 The Remarketing Agent Routinely Purchases Financial Statements 49 Bonds for Its Own Account 12 Bonds May Be Offered at Different Prices on Any Date Including a Rate Determination Date The Ability to Sell the Bonds Other Than Through Tender Process May Be Limited 13 Under Certain Circumstances, the Remarketing Agent May Cease Remarketing the Bonds, Without a Successor Being Named 13 RISK FACTORS 52 Base Rental 52 State Budget 53 Future State Budgets 53 Constitutional Limitation on Taxes and Expenditures 54 Early Redemption Risk 58 Loss of Tax Exemption 58 .... 12 USES OF FUNDS 13 IRS Audit of Tax-Exempt Bond Issues 58 THE LEASED PROPERTY 14 LEGAL MATTERS 59 THE CREDIT FACILITY AND THE REIMBURSEMENT AGREEMENT 14 The Credit Facility 14 The Credit Entity 15 The Reimbursement Agreement 16 SOURCES OF PAYMENT FOR THE BONDS 17 General 17 Base Rental 17 No Reserve Fund 18 Property Insurance 18 Reentering and Reletting 19 Encumbrances 19 Enforceability of Remedies 59 Approval of Legal Proceedings 59 Tax Matters 59 Litigation 61 CONCLUDING INFORMATION 61 Rating on the Bonds 61 Remarketing Agent 61 The Financial Advisor 62 Continuing Disclosure 62 Additional Information 62 References 62 Execution 62 Additional Obligations Payable from Base APPENDIX A — SUMMARY OF THE LEGAL Rental 19 DOCUMENTS THE CITY OF WEST COVINA 21 Government Organization 21 Community Information 22 Transportation 22 Population 23 Employment 24 Per Capita Income 26 Commercial Activity 27 Building Activity 29 FINANCIAL INFORMATION 30 Budgetary Process and Administration 30 APPENDIX B — CITY AUDITED FINANCIAL STATEMENTS APPENDIX C - FORM OF CONTINUING DISCLOSURE AGREEMENT APPENDIX D — OPINIONS OF COUNSEL APPENDIX E - BOOK- ENTRY-ONLY SYSTEM APPENDIX F - FORM OF IRREVOCABLE LETTER OF CREDIT REOFFERING MEMORANDUM WEST COVINA PUBLIC FINANCING AUTHORITY $8,165,000 VARIABLE RATE LEASE REVENUE BONDS, 2004 SERIES A $5,335,000 VARIABLE RATE LEASE REVENUE BONDS, 2004 SERIES B (GOLF COURSE PROJECT) INTRODUCTION This Reoffering Memorandum dated November , 2011 amends, supplements and restates the original Official Statement dated August 12, 2004, with respect to the West Covina Public Financing Authority s' Variable Rate Lease Revenue Bonds, 2004 Series A (the "Series A Bonds') and Variable Rate Lease Revenue Bonds, 2004 Series B (the "Series B Bonds, and together with the Series A Bonds, the "Bonds"). The Series A Bonds were originally issued on August 19, 2004 in the principal amount of $8,165,000, of which $6,715,000 remains outstanding. The Series B Bonds were originally issued on August 19, 2004 in the principal amount of $5,335,000, of which $5,085,000 remains outstanding. This Introduction is subject in all respects to the more complete information contained and referenced elsewhere in this Reoffering Memorandum. The offering of the Bonds to potential investors is made only by means of the entire Reoffering Memorandum. The Authority The West Covina Public Financing Authority (the "Authority") is a joint exercise of powers authority organized and existing under and by virtue of the Joint Exercise of Powers Act, constituting Articles 1 through 4 (commencing with Section 6500) of Chapter 5, Division 7, Title 1 of the Government Code of the State of California (the "Joint Powers Act"). The City of West Covina (the "City"), and the Redevelopment Agency of the City of West Covina (now the West Covina Community Development Commission), formed the Authority by the execution of a joint exercise of powers agreement on June 1, 1990. Pursuant to the Joint Powers Act, the Authority is authorized to issue lease revenue bonds to provide funds to acquire or construct public capital improvements, such revenue bonds to be repaid from the lease payments for such improvements, such as the lease payments described herein. The members of the City Council of the City comprise the Authority Board of Directors. The City The City was incorporated in 1923 as a general law city and operates under the council-manager form of government. The City encompasses 17 square miles in northeastern Los Angeles County. It is approximately 19 miles northeast of Los Angeles. Neighboring communities include Covina, Baldwin Park, Walnut, Industry and La Puente (see "THE CITY OF WEST COVINA" herein). The Bonds The Bonds will bear interest at the Variable Rate, which will be computed on the basis of a year of 365 days (366 days in leap years) and the actual days elapsed. The initial interest period will commence on November 30, 2011. Such interest will be paid on the first Business Day of the following month, commencing January 2, 2012. While the Bonds bear interest at the Variable Rate, interest will be determined as described under the caption "THE BONDS - General Provisions - Interest on the Bonds - Variable Rates." The interest rate borne by the Bonds may be converted at the option of the Authority in accordance with the terms of the Indenture, upon notice to the Owners of the Bonds, to a Fixed Rate and in such event the Bonds will be subject to mandatory tender and purchase. See the caption "THE BONDS - General Provisions - Conversion to Fixed Interest Rates," and "- Tender and Purchase of Bonds." This Reoffering Memorandum describes the Bonds only while bearing interest at a Variable Rate. Investors should not rely upon the information in this Reoffering Memorandum in the event that the method of determining the interest rate period on the Bonds is changed to a Fixed Rate. Rather, investors should rely upon the offering document used in connection with any such change in interest rate mode. Security and Sources of Repayment The Bonds. The Bonds of each Series were originally issued pursuant to an Indenture dated as of August 1, 2004 (the "Indenture"), by and among the City, the Authority and U.S. Bank National Association, as trustee (the "Trustee") as variable rate lease revenue bonds bearing interest at a Variable Rate, on August 19, 2004. On November 30, 2011 (the "Reoffering Date"), the Bonds will be remarketed at a Variable Rate, supported by an irrevocable direct-pay letter of credit to be issued by Wells Fargo Bank, National Association (the "Credit Entity"). See "THE CREDIT ENTITY AND THE REIMBURSEMENT AGREEMENT" herein. The Bonds presently and will continue to bear interest at a Variable Rate unless and until the Bonds are converted to a Fixed Rate pursuant to the Indenture. The Bonds are payable from the base rental payments to be made by the City to the Authority as the rental for the Leased Property, as described herein, pursuant to a lease agreement dated as of August 1, 2004, between the Authority, as Lessor, and the City, as Lessee (the "Lease"), from certain funds held under the Indenture and investment earnings thereon, and from net proceeds of insurance or condemnation awards (see "SOURCES OF PAYMENT FOR THE BONDS," "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - THE LEASE AGREEMENT," and "FINANCIAL INFORMATION" herein). For a summary of the Indenture, the Lease and the Reimbursement Agreement see "APPENDIX A - SUMMARY OF LEGAL DOCUMENTS" herein. Certain capitalized terms used in this Reoffering Memorandum and not otherwise defined have the meaning given them in "APPENDIX A." Base Rental. In general, the City is required under the Lease to pay to the Trustee specified amounts for use and possession of the Leased Property, which amounts are sufficient in both time and amount to pay, when due, the principal of and interest on the Bonds. The base rental payments due under the Lease (the "Base Rental") are intended to repay the Bonds. The City is also required to pay any taxes and assessments and the cost of maintenance and repair of the Leased Property. The City has covenanted in the Lease to take such actions as may be necessary to include all Base Rental in its annual budget and to make the necessary annual appropriations for all such Base Rental subject to complete or partial abatement of such Base Rental resulting from a taking of the Leased Property (either in whole or in part) under the powers of eminent domain or resulting from damage or loss of all or any portion of the Leased Property. Except for the Authority's right, title and interest in and to the Lease, no funds or properties of the Authority or the City are pledged to or otherwise liable for the obligations of the Authority (see "RISK FACTORS" herein). The Lease is, in the opinion of Bond Counsel, a valid and binding obligation of the City enforceable against the City in accordance with its terms, except to the extent enforceability thereof may be limited by bankruptcy, insolvency, moratorium and other similar laws affecting creditors' rights heretofore or hereinafter enacted and may be subject to the exercise of judicial discretion in accordance with general principles of equity which are deemed to preclude the enforcement of judgments against funds held by a city which serve the public welfare and interest (see "RISK FACTORS - Base Rental" and "Limited Recourse on Default" herein). 2 The City is permitted in certain circumstances to amend the Lease in order to provide for additional Base Rental intended to repay additional series of bonds (see "SOURCES OF PAYMENT FOR THE BONDS - Additional Obligations Payable from Base Rental" herein). The Leased Property. The Leased Property being leased under the Lease includes the real property and improvements thereon constituting the Police Administration Building, the Public Safety Communications Building and North Parking Structure, comprising a portion of the West Covina Civic Center Complex. A description of the Leased Property can be found under the heading "THE LEASED PROPERTY." The obligation of the City to pay Base Rental does not constitute an obligation for which the City is obligated to levy or pledge any form of taxation or for which the City has pledged any form of taxation. The obligation of the City to pay Base Rental does not constitute a debt or liability of the State of California or of any political subdivision thereof within the meaning of any constitutional or statutory debt limitation or restriction. Letter of Credit. Payments of principal, redemption amount (but not any premium) and interest on the Bonds will initially be paid from drawings under an irrevocable direct-pay letter of credit (the "Credit Facility") issued by Wells Fargo Bank, National Association (the "Credit Entity"). Drawings under the Credit Facility will be used to pay the principal of and interest on the Bonds when due. The Credit Facility will also be drawn on if remarketing proceeds or other funds are not available to purchase Bonds tendered by Owners at the Purchase Price (as defined herein) or on any optional or mandatory tender date (see "THE CREDIT FACILITY AND THE REIMBURSEMENT AGREEMENT" herein). Information Concerning this Reoffering Memorandum This Reoffering Memorandum speaks only as of its date. The information set forth herein has been obtained by the Authority and the City with the assistance of Harrell & Company Advisors, LLC (the "Financial Advisor") from sources which are believed to be reliable and such information is believed to be accurate and complete but such information is not guaranteed as to accuracy or completeness, nor has it been independently verified and is not to be construed as a representation by the Financial Advisor, Disclosure Counsel or the Remarketing Agent. Statements contained in this Reoffering Memorandum which involve estimates, forecasts or matters of opinion, whether or not expressly so described herein, are intended as such and are not to be construed as representations of fact. The information and expressions of opinion herein are subject to change without notice and the delivery of this Reoffering Memorandum shall not, under any circumstances, create any implication that there has been no change in the information or opinions set forth herein or in the affairs of the City since the date hereof. Availability of Legal Documents. The summaries and references contained herein with respect to the Indenture, the Lease, the Reimbursement Agreement, the Bonds and other statutes or documents do not purport to be comprehensive or definitive and are qualified by reference to each such document or statute, and references to the Bonds are qualified in their entirety by reference to the form thereof included in the Indenture. Copies of these documents may be obtained after delivery of the Bonds at the corporate trust office of the Trustee, U.S. Bank National Association, or from the City at 1444 West Garvey Avenue, West Covina, California 91790. THE BONDS This Reoffering Memorandum describes the Bonds only while bearing interest at a Variable Rate. Investors should not rely upon the information in this Reoffering Memorandum in the event that the method of determining the interest rate on the Bonds is changed to a Fixed Rate. Rather, investors should rely upon the offering document used in connection with any such change in interest rate mode. The Series A Bonds were originally issued in the principal amount of $8,165,000, of which $6,715,000 remains outstanding, taking into account an optional partial prepayment by the Authority in the amount of $1,145,000 on December 1, 2006. The Series B Bonds were originally issued in the principal amount of $5,335,000, of which $5,085,000 remains outstanding. The Bonds are dated the date of initial delivery of the Bonds, and will bear interest at a Variable Rate, until converted to a Fixed Rate as described herein. The Bonds will mature, subject to prior prepayment, on May 1, 2034. Interest with respect to the Bonds will be determined as described herein. While bearing interest at the Variable Rate, the Bonds will be issued in Authorized Denominations of $100,000 or any integral multiple of $5,000 in excess thereof. The Bonds will be registered in the name of Cede & Co., as registered owner and nominee of The Depository Trust Company, New York, New York ("DTC"). So long as DTC, or its nominee Cede & Co., is the registered owner of all the Bonds, all payments of principal of and interest on the Bonds and the Purchase Price of the Bonds will be made directly to DTC. Disbursement of such payments to the DTC Participants (as defined below) will be the responsibility of DTC. Disbursement of such payments to the Beneficial Owners (as defined below) of the Bonds will be the responsibility of the DTC Participants as more fully described herein. See the caption "Book-Entry-Only System" below and "APPENDIX E - BOOK-ENTRY-ONLY SYSTEM." There are a number of provisions in the Indenture relating to the terms of Bank Bonds (i.e., Bonds purchased by the Credit Entity pursuant to the Letter of Credit and Reimbursement Agreement) that are not described in this Reoffering Memorandum. All references to the terms of the Bonds in this Reoffering Memorandum describe only Bonds that are not owned by the Credit Entity unless expressly indicated herein. General Provisions Repayment of the Bonds. Interest on the Bonds is payable at the Variable Rate or the Fixed Rate, as described below (see "Interest on the Bonds - Variable Rates" and "Conversion to Fixed Interest Rates" below). Said interest will represent the portion of Base Rental designated as interest and coming due in the period preceding each Bond Payment Date (as defined below) computed by multiplying the portion of Base Rental designated as principal with respect to such Bonds by the rate of interest applicable to such Bonds. Prior to the date that the Bonds are converted from a Variable Rate to a Fixed Rate (a "Fixed Rate Conversion Date") interest on such Bonds and the related Base Rental will be computed on the basis of a year consisting of 365 (or 366, as applicable) days and the actual number of days elapsed. Following the Conversion Date, interest on the Bonds payable at the Fixed Rate and the related Base Rental will be computed on the basis of a year consisting of 360 days and twelve 30-day months. Principal with respect to the Bonds is payable from the principal component of Base Rental on May 1 in each of the years and in the amounts set forth below. Prior to the Fixed Rate Conversion Date, interest on the Bonds is payable on the first Business Day of each calendar month (each, a "Bond Payment Date"). Following the Fixed Rate Conversion Date, Bond Payment Dates will be May 1 and November 1 of each year, commencing on the first such date to occur 75 or more days after the Conversion Date, except that, after the Fixed Rate Conversion Date, the Bond Payment Dates for any Bonds which are acquired from amounts drawn on the Credit Facility and owned 4 by the Credit Entity ("Bank Bonds") shall be the last business day of each calendar month so long as such Bonds remain Bank Bonds. Commencing November 30, 2011, interest on the Bonds will be payable from the Bond Payment Date next preceding the date of authentication thereof, unless (a) such Bond is authenticated after a Record Date and on or before the following Bond Payment Date, in which event interest thereon will be payable from such Bond Payment Date; or (b) such Bond is authenticated on or before December 30, 2011, in which event interest thereon will be payable from November 30, 2011; provided, however, that if, as of the date of authentication of any Bond, interest on any Outstanding Bond is in default, interest represented by such Bond will be payable from the Bond Payment Date to which interest has previously been paid or made available for payment with respect to the Outstanding Bonds. Remarketing. The Authority has entered into a Remarketing Agreement, dated as of October 20, 2011 (the "Remarketing Agreement") with Wells Fargo Securities, as remarketing agent (the "Remarketing Agent"), pursuant to which the Remarketing Agent undertakes, among other things, to use its best efforts to remarket all Bonds tendered for repurchase. Wells Fargo Securities is the trade name for certain capital markets and investment banking services of Wells Fargo & Company and its subsidiaries, including Wells Fargo Bank, National Association. The Authority or the Remarketing Agent may terminate the Remarketing Agreement under the circumstances and in the manner described in the Remarketing Agreement. Upon termination of the Remarketing Agreement, the Authority will appoint a replacement remarketing agent in accordance with the Indenture. Notwithstanding the foregoing, there shall not be any remarketing of the Bonds if there shall have occurred and be continuing an Event of Default (as defined in the Indenture) or if any event shall have occurred which with notice or the lapse of time would constitute an Event of Default. Book-Entry-Only System. The Depository Trust Company ("DTC"), New York, New York, will act as securities depository for the Bonds. The Bonds will be issued as fully registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. Interest on and principal of the Bonds will be payable when due by wire of the Paying Agent to DTC which will in turn remit such interest and principal to DTC Participants (as defined herein), which will in turn remit such interest and principal to Beneficial Owners (as defined herein) of the Bonds (see "APPENDIX E - BOOK-ENTRY-ONLY SYSTEM" herein). As long as DTC is the registered owner of the Bonds and DTC's book-entry method is used for the Bonds, the Paying Agent will send any notices to bond owners only to DTC. Tender of Bonds in Book-Entry System Are Subject to DTC Procedures. As long as the book-entry system is in effect with respect to the Bonds, all tenders for purchase and deliveries of Bonds optionally tendered for purchase upon election of the Bondholder or subject to mandatory tender under the provisions of the Indenture will be made pursuant to DTC's procedures as in effect from time to time, and none of the Authority, the City, the Trustee or the Remarketing Agent have any responsibility for or liability with respect to the implementation of such procedures. For a description of the tender procedures through DTC, see "APPENDIX E - BOOK-ENTRY-ONLY SYSTEM." Discontinuance of Book-Entry Only System; Method of Payment. DTC may discontinue providing its services as securities depository with respect to the Bonds at any time by giving reasonable notice to the Authority or the Trustee. Under such circumstances, in the event that a successor securities depository is not obtained, Bonds are required to be printed and delivered as described in the Indenture. The Authority may decide to discontinue use of the system of book-entry transfers through DTC (or a successor securities depository). In that event, the Bonds will be printed and delivered as described in the Indenture. In addition, the following provisions shall apply: interest with respect to the Bonds will be payable by check of the Trustee mailed by first class mail on the applicable Interest Payment Date to the Holders thereof at his address as it appears on the Bond registration books or, upon written request of a Bondholder of at least $1,000,000 in principal amount of Bonds received at least 15 days prior to a Record Date, by wire transfer in immediately available funds to an account in the United States designated by such Bondholder, irrespective of the cancellation of such Bond upon the transfer or exchange thereof subsequent to such Record Date and prior to such Interest Payment Date, unless the Authority shall default in the payment of interest due with respect to such Interest Payment Date. Payment of principal or premium, if any due shall be paid only upon surrender of such Bond at the principal corporate trust office of the Trustee in St. Paul, Minnesota. In the event of any default in the payment of interest, such defaulted interest shall be payable to the Holder of such Bond on a special record date for the payment of such defaulted interest, which date shall be established by the Trustee by notice mailed by or on behalf of the Authority to the Holders of the Bonds not less than 15 days preceding such special record date. Interest on the Bonds — Variable Rates The Bonds shall bear interest at the Variable Rate until the Fixed Rate Conversion Date. So long as the Bonds bear interest at a Variable Rate, the Remarketing Agent will set the Variable Rate on the second Business Day of each calendar week (except that the Variable Rate shall initially be set on November 30, 2011). Each Variable Rate will be the rate per annum equal to the minimum rate necessary (as determined by the Remarketing Agent) for the Remarketing Agent to sell the Bonds on the date the Variable Rate is set at 100% of the principal amount thereof plus accrued interest; provided, however, that in no event shall the interest rate borne by the Bonds (other than Bank Bonds) exceed the Maximum Rate. Each Variable Rate will be effective Wednesday through the next succeeding Tuesday (or through the end of the period in which the Bonds bear interest at a Variable Rate, whichever first occurs). If for any reason the Remarketing Agent does not set a Variable Rate on the second Business Day of a calendar week, then the Variable Rate for that period will be the Variable Rate set for the immediately preceding Wednesday through Tuesday period. If a court holds that the Variable Rate set for any period is invalid or unenforceable, the Variable Rate for that period for the Bonds will be the rate that is equal to the 30-day tax-exempt commercial paper rate as published in The Bond Buyer (or any successor to such publication) as of the date of determination of the unenforceable rate or, in the event The Bond Buyer (or any such successor) is no longer published, any other newspaper or journal containing financial news, printed in the English language and customarily published on each Business Day, of general circulation in New York, New York and selected by the Authority, whose decision shall be final and conclusive. Conversion to Fixed Interest Rates The interest rate to be payable with respect to each series of the Bonds (but not less than all of any series of Bonds) may be converted to a fixed interest rate at the election of the Authority, as provided in the Indenture. Tender and Purchase of Bonds Option to Tender Prior to Fixed Rate Conversion Date. Prior to the Fixed Rate Conversion Date, any Owner of the Bonds may give irrevocable written notice to the Tender Agent at its Principal Office and request that the Tender Agent purchase all or any part (in Authorized Denominations) of the Bonds then outstanding and registered in the name of such Owner at an amount or price equal to the unpaid principal amount thereof plus accrued and unpaid interest thereon to, but not including, the Business Day on which the Bonds are to be tendered to the Tender Agent (the "Optional Tender Date") and without premium. Such notice (the "Optional Tender Notice") shall be substantially in the form set forth in the Indenture and shall specify the Optional Tender Date (which shall not be less than 7 days after the date of receipt by the Tender Agent of such Optional Tender Notice), the CUSIP Number, the principal amount being tendered in integral multiples of Authorized Denominations and, so long as the Bonds are registered in the name of the nominee of DTC, such notice shall also specify the Participant number and the contact person of the Participant. Upon receipt of an Optional Tender Notice, the Tender Agent shall, as soon as is practicable but in no event later than the close of business on the Business Day following the day of receipt of such Optional Tender Notice, give notice to the Trustee, the Authority, the Credit Entity and the Remarketing Agent of the Optional Tender Notice, the Optional Tender Date specified therein and the principal amount of Bonds to be purchased on such Optional Tender Date. Owners providing an Optional Tender Notice shall be required to tender the Bonds to the Tender Agent for purchase by 11:00 A.M., New York time, on the Optional Tender Date. In the event of a failure by Owners of Bonds to tender Bonds on the Optional Tender Date, said Owners of Bonds shall not be entitled to any payment (including any interest to accrue subsequent to the Optional Tender Date) other than the purchase price for such Untendered Bonds, and any Untendered Bonds shall no longer be entitled to the benefits of the Indenture, except for the purpose of payment of the purchase price thereof. Such Untendered Bonds shall be deemed purchased, canceled and no longer Outstanding under the Indenture. However, the purchase price will be paid only upon presentment of the Bonds to the Tender Agent. Upon the cancellation of Untendered Bonds, the Trustee shall authenticate new Bonds in the same aggregate principal amount as, and in substitution for the Bonds not so tendered by such Owner and shall hold, deliver and make available such new Bonds to the new Owner thereof in accordance with the provisions of this Indenture which shall be fully applicable notwithstanding that such new Bonds are authenticated in substitution for the Bonds not so tendered. From and after the Fixed Rate Conversion Date, the Tender Agent will not be required to purchase such Bonds on demand and optional tender by the Owners thereof in accordance with the Indenture. Mandatory Tender of Bonds. The Bonds shall be subject to mandatory tender on the following dates (collectively the "Mandatory Tender Dates") and under the circumstances as follows: (a) In the event the City has complied with the requirements of the Indenture to change the interest rate represented by the Bonds to a Fixed Rate, all Bonds shall be subject to mandatory tender and purchase on the Fixed Rate Conversion Date. When a conversion from the Variable Rate to the Fixed Rate is to be made, the Trustee shall notify the Owners of the Bonds so converted, the Credit Entity by first class mail at least 30 but not more than 60 days prior to the proposed Fixed Rate Conversion Date. (b) The Bonds are subject to mandatory tender on a Business Day at least 5 days prior to the date on which the Credit Facility is scheduled to expire or terminate in accordance with its respective terms and if the Trustee has not received notice at least 45 days prior to such date that an Alternate Credit Facility is to be provided. Not less than 30 days before each such Mandatory Tender Date under this provision of the Indenture, the Trustee shall send a notice to all Owners by first class mail, postage prepaid, which notice shall contain the following information: (1) that the Credit Facility is scheduled to expire or terminate and no Alternate Credit Facility will be provided, (2) that each Owner's Bond is subject to mandatory tender as provided in such notice, and (3) if any of the nationally recognized rating agencies which has a credit rating outstanding on the Bonds has indicated to the Trustee in writing that it will lower or withdraw its rating on the Bonds as of such Mandatory Tender Date, notice of such new rating, or if no new rating is available, notice that any of such rating agencies may lower or withdraw such rating as of such Mandatory Tender Date. (c) The Bonds are subject to mandatory tender on the first Business Day to occur on or after the seventh day following receipt by the Trustee of notice from the Credit Entity of the occurrence of an event of default or event of termination under the Reimbursement Agreement or that the Credit Entity will not reinstate the interest portion of the Credit Facility and directing the mandatory tender of the Bonds. Not later than the fifth Business Day after receipt by the Trustee of such notice, the Trustee shall send to all Owners by first class mail, postage prepaid, and to the Depository also by facsimile, a notice which shall contain the following information: (1) that the Credit Entity has declared an event of default or event of termination under the Reimbursement Agreement, or that the Credit Entity will not reinstate the interest portion of the Credit Facility, 7 and (2) that each Owner's Bond is subject to mandatory tender on the first Business Day to occur on or after the fifth day following the receipt by the Trustee of such notice from the Credit Entity. (d) The Bonds are subject to mandatory tender on the effective date of any Alternate Credit Facility in accordance with the provisions of the Indenture. (e) The Bonds are subject to mandatory tender on the first Business Day to occur on or after the seventh day following the day a properly presented and conforming drawing by the Trustee under the Credit Facility has not been timely honored or the Credit Facility has been repudiated. Not later than the fifth Business Day following the day a properly presented and conforming drawing by the Trustee under the Credit Facility has not been timely honored or the Credit Facility has been repudiated, the Trustee shall send to all Owners by first class mail, postage prepaid, and to the Depository also by facsimile, a notice which shall contain the following information: (1) that a properly presented and conforming drawing by the Trustee under the Credit Facility has not been timely honored or the Credit Facility has been repudiated, and (2) that each Owner's Bond is subject to mandatory tender on the first Business Day to occur on or after the fifth day following the day a properly presented and conforming drawing by the Trustee under the Credit Facility has not been timely honored or the Credit Facility has been repudiated. Owners of Bonds shall be required to tender the Bonds to the Tender Agent by 11:00 a.m. New York time on the Mandatory Tender Date for purchase at a purchase price equal to the principal amount thereof plus accrued interest thereon to and including the Mandatory Tender Date. So long as the Bonds are registered in the name of the nominee of DTC, such tenders shall be made through the book-entry system. Any Untendered Bonds shall be deemed to have been tendered. In the event of a failure by Owners of Bonds to tender Bonds on the Mandatory Tender Date, said Owners of Untendered Bonds shall not be entitled to any payment (including any interest to accrue on and after the Mandatory Tender Date) other than the purchase price for such Untendered Bonds, and any Untendered Bonds shall no longer be entitled to the benefits of the Indenture, except for the purpose of payment of the purchase price thereof. Such Untendered Bonds shall be deemed purchased, canceled and no longer Outstanding under the Indenture. However, the purchase price will be paid only upon presentation of the Bonds to the Tender Agent. In the case of the Fixed Rate Conversion Date only, if the Remarketing Agent notifies the Trustee not less than 15 days before the Fixed Rate Conversion Date that it cannot remarket all of the Bonds or if the requirements for the effectiveness of a Fixed Rate Conversion Date are not satisfied before the Fixed Rate Conversion Date, the Trustee shall give notice thereof by first-class mail, postage prepaid, to all Owners, the Remarketing Agent, the Credit Entity and the City and each of such parties shall be restored to their respective positions as if notice of the Fixed Rate Conversion Date had not been given and no mandatory tender shall occur. Remarketing of Bonds by Remarketing Agent. Subject to the terms of the Remarketing Agreement, the Remarketing Agent shall use its best efforts to remarket Bonds subject to purchase on a Tender Date and to remarket such Bonds registered in the name of the Credit Entity. The proceeds of any sale with respect to a Tender Date shall be delivered to the Tender Agent for deposit in the Remarketing Proceeds Account by no later than 11:00 a.m., New York time, on each Tender Date. The proceeds of the sale of any Bonds registered to or on behalf of the Credit Entity shall be delivered to the Tender Agent for deposit in the Remarketing Proceeds Account by 11:00 a.m., New York time, on the date of sale and the Tender Agent shall remit such amounts to the Credit Entity no later than 4:00 p.m., New York time, on such date. In the event that any Bonds are purchased for the benefit of the Credit Entity, the Remarketing Agent shall continue to offer for sale and use its best efforts to sell such Bonds. Prior to the release of any Bank Bonds or the remarketing of any Bonds purchased following the mandatory tender thereof, the Tender Agent shall have received notice from the Trustee that the Credit Facility has been, or will be upon such remarketing, reinstated or an Alternate Credit Facility has been delivered in an amount equal to the principal amount of the Bank Bonds to be released and interest thereon in accordance with its terms. Redemption Special Mandatory Redemption from Net Proceeds. The Bonds are subject to mandatory redemption on any Bond Payment Date, in whole or in part, from moneys drawn under the Credit Facility, which shall be reimbursed from net proceeds of any insurance or condemnation award paid with respect to the Leased Property ("Net Proceeds") following the deposit by the Trustee in the Lease Prepayment Account of the Redemption Fund of Net Proceeds deposited by the City under the Indenture, at least 45 days prior to a Bond Payment Date which have been credited towards the Prepayment made by the City pursuant to the Lease, at a redemption price equal to the principal amount of the Bonds to be redeemed, together with accrued interest to the date fixed for redemption, without premium; provided, however, that if there shall no longer be available a Credit Facility to secure the payment of principal and interest represented by the Bonds or if the Credit Facility does not permit a draw with respect to Prepayments, the Bonds are subject to redemption from Net Proceeds which the Trustee shall deposit in the Lease Prepayment Account of the Redemption Fund, to be used to redeem the Bonds by the Trustee as provided in the Lease and the Indenture. Optional Redemption During the Variable Rate Period. During the Variable Rate Period and on the Fixed Rate Conversion Date, the Bonds are subject to optional redemption in whole or in part (in an amount of $100,000 or any integral multiple of $5,000 in excess thereof) on any Business Day, at the option of the Authority at a redemption price equal to the principal amount thereof together with accrued interest to the date fixed for redemption, without premium. Mandatory Sinking Account Redemption. The Outstanding Bonds of each series are subject to mandatory redemption, in part, from Sinking Account Payments, on each May 1 on or after May 1, 2012, at a redemption price equal to the principal amount thereof together with accrued interest to the date fixed for redemption, without premium as follows: SCHEDULE OF MANDATORY SINKING ACCOUNT PAYMENTS OUTSTANDING SERIES A BONDS OUTSTANDING SERIES B BONDS May 1 Principal Year Amount May 1 Year 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 (maturity) Principal Amount* $170,000 175,000 185,000 195,000 200,000 215,000 225,000 235,000 245,000 255,000 265,000 280,000 290,000 305,000 325,000 335,000 345,000 365,000 385,000 400,000 420,000 440,000 460,000 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 (maturity) $130,000 135,000 140,000 150,000 155,000 160,000 170,000 175,000 185,000 195,000 200,000 210,000 220,000 230,000 240,000 255,000 265,000 275,000 290,000 305,000 320,000 330,000 350,000 $1,145,000 of Series A Bonds were redeemed in 2006. The amount of each such redemption shall be reduced proportionately in the event and to the extent of any and all redemptions of Bonds other than sinking account redemptions. Selection of Bonds for Redemption. Whenever provision is made in the Indenture for the redemption of Bonds and less than all Outstanding Bonds are called for redemption, the Trustee shall select Bonds for redemption, from the Outstanding Bonds not previously called for redemption, in Authorized Denominations, first from Credit Facility Bonds, then (i) on a pro-rata basis among maturities and by lot within a maturity, or (ii) from such maturities as are designated in a City Certificate; all in the manner provided in the Indenture. Notice of Redemption. When redemption is authorized or required, the Trustee shall give notice of the redemption of the Bonds. Such notice shall specify: (a) that the Bonds or a designated portion thereof are to be redeemed, (b) the CUSIP numbers and, if less than all of the Bonds of a maturity are to be redeemed, the serial numbers of the Bonds to be redeemed, (c) the date of redemption, (d) the place or places where the redemption will be made, (e) the following descriptive information regarding the Bonds: date, interest rates and stated maturity dates, and (f) that a new Bond in an amount equal to that portion not so redeemed will be executed by the Trustee and delivered to the Owner in the event of a partial redemption. Such notice shall further state that on the specified date there shall become due and payable 10 upon each Bond to be redeemed, the portion of the principal amount of such Bond to be redeemed, together with interest accrued to said date, and that from and after such date, provided that moneys therefore have been deposited with the Trustee, interest with respect thereto shall cease to accrue and be payable. Notice of such redemption shall be mailed by first-class mail, postage prepaid, to the City, to all municipal Securities Depositories and to at least one national Information Service which the City shall designate to the Trustee, and the respective Owners of any Bonds designated for redemption at their addresses appearing on the Bond registration books, at least 30 days, but not more than 60 days, prior to the redemption date; provided that neither failure to receive such notice nor any defect in any notice so mailed shall affect the sufficiency of the proceedings for the redemption of such Bonds, and provided, further, however, that the Trustee shall, on the day it receives notice of prepayment of Base Rental pursuant to the Lease from the City, provide telephonic, telegraphic or telex notice of such notice of redemption to the Remarketing Agent, the Credit Entity. Partial Redemption of Bonds. Upon surrender of any Bond redeemed in part only, the Trustee or the Tender Agent shall authenticate and deliver to the Owner thereof, at the expense of the City, a new Bond or Bonds which shall be of Authorized Denominations equal in aggregate principal amount to the unredeemed portion of the Bond surrendered and the of the same interest rate and the same maturity. Such partial redemption shall be valid upon payment of the amount thereby required to be paid to such Owner, and the City, the Authority and the Trustee shall be released and discharged from all liability to the extent of such payment. Effect of Redemption. Notice having been given as aforesaid, and the moneys for the redemption (including the interest to the applicable date of redemption), having been set aside in the Redemption Fund, the Bonds shall become due and payable on said date of redemption, and, upon presentation and surrender thereof at the Principal Office, said Bonds shall be paid at the unpaid principal price with respect thereto, plus interest accrued and unpaid to said date of redemption. If, on said date of redemption, moneys for the redemption of all the Bonds to be redeemed, together with interest to said date of redemption, shall be held by the Trustee so as to be available therefor on such date of redemption, and, if notice of redemption thereof shall have been given as aforesaid, then, from and after said date of redemption, interest with respect to the Bonds shall cease to accrue and become payable. All moneys held by or on behalf of the Trustee for the redemption of Bonds shall be held in trust for the account of the Owners of the Bonds so to be redeemed. SPECIAL CONSIDERATIONS RELATING TO THE BONDS SUBJECT TO OPTIONAL TENDER AND REMARKETING The Remarketing Agent is Paid by the Authority The Remarketing Agent's responsibilities include determining the interest rate from time to time and remarketing Bonds that are optionally or mandatorily tendered by the owners thereof (subject, in each case, to the terms of the Remarketing Agreement), as further described in this Reoffering Memorandum. The Remarketing Agent is appointed by the Authority and is paid by the Authority for its services. As a result, the interests of the Remarketing Agent may differ from those of existing holders and potential purchasers of Bonds. The Remarketing Agent Routinely Purchases Bonds for Its Own Account The Remarketing Agent acts as remarketing agent for a variety of variable rate demand obligations and, in its sole discretion, routinely purchases such obligations for its own account. The Remarketing Agent is permitted, but not obligated, to purchase tendered Bonds for its own account and, in its sole discretion, routinely acquires such tendered Bonds in order to achieve a successful remarketing of the Bonds (i.e., because there otherwise are not enough buyers to purchase the Bonds) or for other reasons. However, the Remarketing Agent is not obligated to purchase Bonds, and may cease doing so at any time without notice. The Remarketing Agent may also make a market in the Bonds by routinely purchasing and selling Bonds other than in connection with an optional or mandatory tender and remarketing. Such purchases and sales may be at or below par. However, the Remarketing Agent is not required to make a market in the Bonds. The Remarketing Agent may also sell any Bonds it has purchased to one or more affiliated investment vehicles for collective ownership or enter into derivative arrangements with affiliates or others in order to reduce its exposure to the Bonds. The purchase of Bonds by the Remarketing Agent may create the appearance that there is greater third party demand for the Bonds in the market than is actually the case. The practices described above also may result in fewer Bonds being tendered in a remarketing. Bonds May Be Offered at Different Prices on Any Date Including a Rate Determination Date Pursuant to the Remarketing Agreement, the Remarketing Agent is required to determine the applicable rate of interest that, in its judgment, is the lowest rate that would permit the sale of the Bonds bearing interest at the applicable interest rate at par plus accrued interest, if any, on and as of the commencement of the applicable weekly interest period. The interest rate will reflect, among other factors, the level of market demand for the Bonds (including whether the Remarketing Agent is willing to purchase Bonds for its own account). There may or may not be Bonds tendered and remarketed on the commencement of the applicable weekly interest period, the Remarketing Agent may or may not be able to remarket any Bonds tendered for purchase on such date at par and the Remarketing Agent may sell Bonds at varying prices to different investors on such date or any other date. The Remarketing Agent is not obligated to advise purchasers in a remarketing if it does not have third party buyers for all of the Bonds at the remarketing price. In the event that the Remarketing Agent owns any Bonds for its own account, it may, in its sole discretion in a secondary market transaction outside the tender process, offer such Bonds on any date, including the date of the commencement of the applicable weekly interest period, at a discount to par to some investors. The Ability to Sell the Bonds Other Than Through Tender Process May Be Limited The Remarketing Agent may buy and sell Bonds other than through the tender process. However, it is not obligated to do so and may cease doing so at any time without notice and may require holders that wish to tender their Bonds to do so through the Tender Agent with appropriate notice. Investors who purchase the Bonds in connection with a remarketing or otherwise should not assume that they will be able to sell their Bonds other than by tendering the Bonds in accordance with the tender process. The Letter of Credit is not available to purchase Bonds other than those tendered in accordance with the tender process and, as such, would not be drawn to purchase Bonds in connection with a sale of Bonds by the holder of a Bond to a Remarketing Agent. The Letter of Credit will only be drawn when such Bonds have been properly tendered in accordance with the terms of the transaction. Under Certain Circumstances, the Remarketing Agent May Cease Remarketing the Bonds, Without a Successor Being Named Under certain circumstances the Remarketing Agent may cease its remarketing efforts without a successor having been named, subject to the terms of the Remarketing Agreement. USES OF FUNDS The uses of funds with respect to the initial issuance of the Bonds were as follows: Deposit to the Construction Fund Debt Service Fund (1) Underwriters Discount Costs of Issuance Fund (2) Total Uses Series A Bonds $7,271,275 556,550 61,238 275,937 $8,165,000 Series B Bonds $4,726,028 366,422 40,013 202,537 $5,335,000 Amounts deposited in the Debt Service Fund and earnings thereon were used to pay interest and expenses on the Bonds through and including November 1, 2006. Amounts deposited in the Costs of Issuance Fund were used to pay costs of issuance of the Bonds, including fees of Bond Counsel, Disclosure Counsel, Counsel to the Credit Entity, the Financial Advisor, the Trustee, rating fees, letter of credit fees of the Credit Entity, fees of the Remarketing Agent, costs of printing the Official Statement, and other costs of delivery of the Bonds. THE LEASED PROPERTY The Leased Property is comprised of the Police Administration Building, the Public Safety Communications Building and North Parking Structure. These facilities are a part of the West Covina Civic Center Complex. The Civic Center Complex also includes the City Hall and South Parking Structure. It is located adjacent to the County of Los Angeles Citrus Municipal Court and the County's East Regional County Library. The Civic Center complex provides 113,544 square feet of space for the City's 415 safety and non-safety personnel. The City Hall and Police Administration Building were built in 1969, and the combined north and south 435-space multi-level parking structure was completed in 1972. In 1987, the City financed the construction of the Public Safety Communications Building. The City shall, at its own expense, have the right to make further additions, modifications and improvements to the Leased Property. All additions, modifications and improvements to the Leased Property shall thereafter comprise part of the Leased Property and be subject to the provisions of the Lease. The City may amend the Lease to substitute additional real property and/or improvements for existing Leased Property, or to remove real property or improvements from the definition of Leased Property, upon compliance with all of the conditions set forth in the Lease, as further described in "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - THE LEASE - Release, Substitution or Removal of Leased Property." THE CREDIT FACILITY AND THE REIMBURSEMENT AGREEMENT The Irrevocable Letter of Credit (the "Credit Facility") will be issued by the Credit Entity pursuant to the Reimbursement Agreement dated as of November 1, 2011 (the "Reimbursement Agreement"), by and between the City and the Credit Entity. The following summarizes certain provisions of the Credit Facility and the Reimbursement Agreement, to which documents reference is made for the complete provisions thereof. The provisions of any substitute letter of credit and related reimbursement agreement may be different from those summarized below. The Credit Facility The Credit Facility will be an obligation of the Bank (as defined below) to pay to the Trustee, upon request made with respect to the Bonds and in accordance with the terms thereof, up to: (i) $11,800,000 to pay principal of the Bonds when due, whether upon maturity, redemption or acceleration or to pay that portion of the Purchase Price of Bonds tendered for purchase and not remarketed, equal to the principal amount of such Bonds; plus (ii) $162,937 (an amount equal to 42 days' interest accrued on the Bonds calculated at the rate of 12% per annum (computed on the basis of a 365-day year)) to pay accrued interest on the Bonds when due or to pay the accrued interest portion of the Purchase Price of Bonds tendered for purchase and not remarketed, as such amounts may be reduced or reinstated pursuant to the terms of the Credit Facility. All drawings under the Credit Facility will be paid with the Bank's own funds. The Credit Facility shall terminate on the date which is the earliest of (i) honor by the Bank of a final draft presented to it by the Trustee under the Credit Facility; (ii) the date of receipt by the Bank of notice from the Trustee stating that the City has provided and the Trustee has accepted an Alternate Credit Facility; or (iii) the Expiration Date of the Credit Facility (initially November 29, 2014). 14 See "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - Credit Facility" for a more complete description of the requirements and operation of the Credit Facility to pay the principal and Purchase Price with respect to the Bonds and accrued interest as well as the requirements for substitution of a new Credit Facility for an existing Credit Facility. The Credit Entity The following information concerning the Credit Entity has been provided by representatives of the Credit Entity and has not been independently confirmed or verified by the City, the Authority, the Financial Advisor, Bond Counsel, the Underwriter or the Remarketing Agent. No representation is made herein as to the accuracy or adequacy of such information or as to the absence of material adverse changes in such information subsequent to the date hereof, or that the information contained or incorporated herein by reference is correct as of any time subsequent to its date. Wells Fargo Bank, National Association (the "Bank") The Bank is a national banking association organized under the laws of the United States of America with its main office at 101 North Phillips Avenue, Sioux Falls, South Dakota 57104, and engages in retail, commercial and corporate banking, real estate lending and trust and investment services. The Bank is an indirect, wholly owned subsidiary of Wells Fargo & Company, a diversified financial services company, a financial holding company and a bank holding company registered under the Bank Holding Company Act of 1956, as amended, with its principal executive offices located in San Francisco, California ("Wells Fargo"). Effective at 11:59 p.m. on December 31, 2008, Wells Fargo acquired Wachovia Corporation and its subsidiaries in a stock-for-stock merger transaction. Information about this merger has been included in filings made by Wells Fargo with the Securities and Exchange Commission ("SEC"). Copies of these filings are available free of charge on the SEC's website at www.sec.gov or by writing to Wells Fargo's Corporate Secretary at the address given below. Each quarter, the Bank files with the FDIC financial reports entitled "Consolidated Reports of Condition and Income for Insured Commercial Banks with Domestic and Foreign Offices," commonly referred to as the "Call Reports." The Bank's Call Reports are prepared in accordance with regulatory accounting principles, which may differ from generally accepted accounting principles. The publicly available portions of the Call Reports contain the most recently filed quarterly reports of the Bank, which include the Bank's total consolidated assets, total domestic and foreign deposits, and total equity capital. These Call Reports, as well as the Call Reports filed by the Bank with the FDIC after the date of this Reoffering Memorandum, may be obtained from the FDIC, Disclosure Group, Room F518, 550 17`11 Street, N.W., Washington, D.C. 20429 at prescribed rates, or from the FDIC on its Internet site at http://www.fdic.gov , or by writing to the Wells Fargo Corporate Secretary's Office, Wells Fargo Center, Sixth and Marquette, MAC N9305-173, Minneapolis, MN 55479. The Credit Facility will be solely an obligation of the Bank and will not be an obligation of, or otherwise guaranteed by, Wells Fargo & Company, and no assets of Wells Fargo & Company or any affiliate of the Bank or Wells Fargo & Company will be pledged to the payment thereof. Payment of the Credit Facility will not be insured by the FDIC. The information contained in this section, including financial information, relates to and has been obtained from the Bank, and is furnished solely to provide limited introductory information regarding the Bank and does not purport to be comprehensive. Any financial information provided in this section is qualified in its entirety by the detailed information appearing in the Call Reports referenced above. The delivery hereof shall not create any implication that there has been no change in the affairs of the Bank since the date hereof. The Reimbursement Agreement The Reimbursement Agreement and the other agreements securing the City's obligation to reimburse the Bank do not secure the Trustee, the Owners of the Bonds, or the Bonds. Events of Default. The following is a summary of the circumstances set forth in the Reimbursement Agreement which constitute events of default thereunder. This summary is qualified by referenced to the complete text of the Reimbursement Agreement. Capitalized terms used under this caption and not otherwise defined shall have the meanings given to such terms in the Reimbursement Agreement. (a) Misrepresentation. Any representation or warranty made by the City in the Reimbursement Agreement or in any certificate, financial or other statement furnished by the City pursuant to the Reimbursement Agreement shall prove to have been untrue or incomplete in any material respect when made; (b) Required Payments. The City shall fail to pay to Bank or deposit with Bank any amount specified in the Reimbursement Agreement or in the Fee Letter when due to be paid or deposited; (c) Other Covenants. The City shall fail to perform or observe any other material term, covenant or agreement on its part to be performed or observed under the Reimbursement Agreement (other than as specified in (b) above) and, except in the case of the certain covenants set forth in the Reimbursement Agreement any such failure shall remain unremedied for a period of twenty (20) calendar days; (d) Invalidity. Any material provision of the Reimbursement Agreement or any Related Document shall at any time for any reason cease to be in full force and effect or valid and binding on the City, or shall be declared to be null and void, or the validity or enforceability thereof shall be contested by the City or the City shall deny that it has any further liability or obligation under the Reimbursement Agreement, and such event shall have, or be likely to have, a material adverse effect on the condition of the City and its ability to perform its obligations under the Reimbursement Agreement or the Related Documents; (e) Voluntary Insolvency. The City shall (i) apply for or consent to the appointment of a receiver, trustee, liquidator or custodian or the like of itself or of its property, (ii) admit in writing its inability to pay its debts generally as they become due, (iii) make a general assignment for the benefit of creditors, (iv) be adjudicated a bankrupt or insolvent, or (v) commence a voluntary case under the federal bankruptcy laws of the United States of America or file a voluntary petition or answer seeking reorganization, an arrangement with creditors, or an order for relief, or seeking to take advantage of any insolvency law, or file an answer admitting the material allegations of a petition filed against it in any bankruptcy, reorganization or insolvency proceeding; or corporate action shall be taken by it for the purpose of effecting any of the foregoing; (f) Default under Indenture or Related Documents. Any Event of Default shall occur under the Indenture or any of the Related Documents; (g) Other Defaults. The City shall default in the payment or performance of any obligation, or the occurrence of any defined event of default under the terms of any contract or instrument pursuant to which City has incurred any debt or other liability, including, without limitation, the Related Documents, to any person or entity, including, without limitation, the Bank, which in any case could result in a judgment in excess of $1,000,000.00; (h) Material Adverse Change. A Material Adverse Change with respect to the City, as determined by Bank in the good faith exercise of its discretion, shall occur; 16 Rights Upon an Event of Default. Upon the occurrence of an Event of Default, the Bank may, and the Bank shall upon the occurrence of an Event of Default for which the Bank has received a notice from the Trustee that an event of default has occurred under the Indenture and such default is not cured by the City within the applicable time period, (a) exercise all of its rights and remedies under any Related Document (to which the Bank is a party or the Bank is a third party beneficiary) or applicable law, (b) require the Trustee to cause a mandatory tender as provided in the Indenture, or (c) exercise all or any combination of the remedies available at law or in equity. No remedy conferred upon or reserved to the Bank in the Reimbursement Agreement is intended to be exclusive of any other available remedy or remedies, but each and every such remedy shall be cumulative and in addition to every other remedy given under the Reimbursement Agreement, the Indenture, the Lease or the other Related Documents, now or hereafter existing at law or in equity or by statute. OURCES OF PAYMENT FOR THE BOND General Each Bond represents a direct, undivided fractional interest in certain of the Base Rental to be paid by the City to the Authority under the Lease. The Authority has assigned all of its rights under the Lease including its rights to receive Base Rental from the City and its remedies under the Lease to the Trustee for the benefit of the Owners of the Bonds. The Base Rental is calculated to be sufficient to pay, when due, the annual principal of and interest due with respect to the Bonds. Principal and interest on the Bonds will be paid from the Base Rental paid by the City for the use and possession of the Leased Property, from insurance or condemnation Net Proceeds received with respect to the Leased Property to the extent that such Net Proceeds are not used for repair or replacement, and from interest or other income derived from the investment of the funds held by the Trustee for the City pursuant to the Indenture. The obligation of the City to pay Base Rental does not constitute an indebtedness of the City for which the City is obligated to levy or pledge any form of taxation or for which the City has levied or pledged any form of taxation. Neither the Bonds nor the obligation of the City to pay Base Rental constitutes an indebtedness of the City, the State of California, or any of its political subdivisions within the meaning of any constitutional or statutory debt limitation or restriction. Base Rental The City is required to pay to the Authority specified amounts for use of the Leased Property, which are equal to the principal and interest due with respect to the Bonds. The Lease requires the City to pay Base Rental to the Authority on the twenty-fifth day of the month immediately preceding each Bond Payment Date. Base Rental to be paid by the City is assigned and is to be transmitted directly to the Trustee. The Indenture requires that the Base Rental be deposited in the Lease Payment Account of the Debt Service Fund and applied to make principal and interest payments when due with respect to the Bonds. The City shall receive a credit against the Base Rental due equal to the amount on deposit in the Lease Payment Account of the Debt Service. The City has covenanted in the Lease to take such action as may be necessary to include all Base Rental in its annual budget and to make annual appropriations for all such Base Rental. The Lease provides that the several actions required by such covenants are deemed to be and shall be construed to be ministerial duties imposed by law and that it is the duty of each and every public official of the City to take such action and do such things as are required by law in the performance of the official duty of such official to enable the City to carry out and perform the covenants in the Lease agreed to be carried out and performed by the City. The Lease provides that Base Rental for any portion of the Leased Property will be abated during any period in which there is substantial interference with the City's use of such portions of the Leased Property because of damage, destruction or condemnation of such portions. The amount of such abatement shall be an amount such that the portion of Base Rental remaining represents the fair rental value of the remaining portion of the Leased Property, as calculated by the City. Such abatement shall continue for the period commencing with such taking, damage or destruction and ending with the substantial completion of the work of replacement, repair or reconstruction. In the event of any such damage or destruction, the Lease shall continue in full force and effect and the City waives any right to terminate the Lease by virtue of such damage and destruction. Notwithstanding the foregoing, there shall be no abatement of Base Rental under the Lease to the extent that the proceeds of rental interruption insurance or amounts in the Debt Service Fund are available to pay Base Rental which would otherwise be abated under the Lease. During any period of abatement of Base Rental, the Trustee may pay principal and interest on the Bonds allocable to such portions of the Leased Property, if available, from proceeds of insurance or condemnation award. The City's reduced rental payments will constitute the total Base Rental. The reduced Base Rental may not be sufficient to pay principal and interest on the Bonds in the amounts and at the rates set forth therein. The failure to make such payment of principal and interest would not constitute a default by the City under the Indenture, the Lease or otherwise. No Reserve Fund No Reserve Fund has been established under the Indenture while the Bonds are payable at the Variable Rate. Property Insurance The Lease requires the City to maintain or cause to be maintained with respect to the Leased Property, comprehensive general public liability and property damage insurance and fire insurance with extended coverage (see "FINANCIAL INFORMATION - Risk Management" herein). The City is not obligated to and currently does not maintain insurance against earthquake related damage. The City is required to maintain rental interruption insurance covering loss of the use of any part of the Leased Property in an amount equal to the maximum aggregate amount of Base Rental scheduled to be payable in any 24 month period at an assumed rate of 5.24% (see "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - THE LEASE AGREEMENT - Insurance" herein). In the event the Leased Property is damaged or destroyed, the City may apply the net proceeds of any insurance award (except that received for the purposes of rental interruption) to replace, repair, restore, modify or improve (collectively, "repair") the Leased Property, or if repairing the Leased Property is not economically feasible, or in the best interest of the City, to prepay Bonds on a pro-rata basis. In the event the Leased Property has been damaged or destroyed and the City directs the Trustee to apply insurance proceeds arising from such damage or destruction to the payment or redemption of Base Rental, then the Trustee shall apply such proceeds to the redemption of Bonds as described under the caption "THE BONDS - Redemption - Special Mandatory Redemption from Net Proceeds" herein. The amount of the Base Rental allocable to the portion of the Leased Property comprising the improvements and facilities will be adjusted or abated (but only after all available moneys have been depleted) during any period in which damage or destruction to the Leased Property or condemnation of the Leased Property substantially interferes with the City's use and possession thereof. If there are not sufficient insurance proceeds to complete repair of the Leased Property, the Base Rental schedule will be proportionally reduced in accordance with the Lease. Such reduced Base Rental may not be sufficient to pay principal and interest on the Bonds in the amounts and at the rates set forth thereon. Such reduction would not constitute a default under either the Indenture or the Lease. The Lease required the City to obtain title insurance insuring the City's leasehold interest on the Leased Property in an amount equal to the outstanding principal component of the Bonds (see "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - THE INDENTURE - THE LEASE AGREEMENT"). Reentering and Reletting If the City defaults in performance of its obligations under the Lease, the Trustee, as assignee of the Authority, may re-enter and relet the Leased Property and may enforce the Lease and hold the City liable for all Base Rental on an annual basis while re-entering and reletting the Leased Property. Such re-entry and reletting shall not effect a surrender of the Lease. The City, in the event of default, waives all rights to any rentals received by the Trustee through reletting of the Leased Property. The City agrees to pay all costs, loss or damage howsoever occurring. Encumbrances The City and the Authority may not create any mortgage, pledge, lien, charge or encumbrance upon the Leased Property other than "Permitted Encumbrances." Permitted Encumbrances are defined to mean, as of any particular time: (i) liens for general ad valorem taxes and assessments, if any, not then delinquent, or which the City may, pursuant to the Lease, permit to remain unpaid; (ii) the Lease and the Site Lease; (iii) the Assignment Agreement; (iv) any right or claim of any mechanic, laborer, materialman, supplier or vendor filed or perfected in the manner prescribed by law after the date of the Lease; (v) easements, rights of way, mineral rights, drilling rights and other rights, reservations, covenants, conditions or restrictions which exist of record as of the date of initial issuance of the Bonds and which an Authorized Representative of the City certifies in writing will not materially impair the beneficial use and occupancy of the Leased Property by the City; and (vi) easements, rights of way, mineral rights, drilling rights and other rights, reservations, covenants, conditions or restrictions established following the date of recordation of the Lease and to which the Authority and the City consent in writing. The Credit Entity does not hold a security interest in the form of a mortgage on the Leased Property. Additional Obligations Payable from Base Rental Issuance of Additional Bonds. In addition to the Bonds, the Authority may, by Supplemental Indenture, establish one or more other issues of Additional Bonds on a parity with the Bonds, and may issue and deliver such Additional Bonds in such principal amount as shall be determined by the City, but only upon compliance by the Authority and the City with the provisions of the Indenture and subject to the following specific conditions: (a) The Authority shall be in compliance with all covenants and undertakings set forth in the Indenture and the City shall be in compliance with all covenants and undertakings set forth in the Lease. (b) The Supplemental Indenture authorizing issuance of such Additional Bonds shall require that the balance on deposit in the Reserve Fund upon delivery of said Additional Bonds is a sum at least equal to the Reserve Requirement of the Bonds and said Additional Bonds, if any. (c) Such Additional Bonds shall be equally and ratably secured with all other Bonds, without preference or priority. (d) The City and the Authority shall have entered into an amendment to the Lease in and by which the City obligates itself in the manner provided in the Lease to make payments of rental for the use of the Leased Property at the times and in the amounts sufficient to provide for the payment of the principal of and interest on such Additional Bonds as such principal and interest become due and to make all other payments in the manner provided in the Lease. (e) The Authority and the City shall obtain the written consent of the Credit Entity. Proceedings for the Issuance of Additional Bonds. Whenever the Authority shall have determined to issue Additional Bonds pursuant to the Indenture, the Authority shall adopt a Supplemental Indenture determining that the issuance of such Additional Bonds is necessary for the purposes specified above, specifying the principal amount of such Additional Bonds and prescribing the terms and conditions of such Additional Bonds and the funds to be established for the security and payment thereof. Before such Additional Bonds shall be issued and delivered, the Authority and the City shall file the following documents with the Trustee: (a) An executed copy of the Supplemental Indenture authorizing such Additional Bonds. (b) An opinion of Bond Counsel stating: (i) that the execution and delivery of the Additional Bonds have been sufficiently and duly authorized by the Authority and the City; (ii) that the issuance of the Additional Bonds is authorized by the Indenture; (iii) that the Additional Bonds when duly executed and delivered, will be valid and binding obligations of the City, payable from Base Rental in accordance with the terms of the Indenture and the Supplemental Indenture authorizing the issuance of such Additional Bonds; (iv) that upon the delivery of the Additional Bonds the aggregate principal amount of Bonds then Outstanding will not exceed the amount at the time permitted by law or the then limits of indebtedness of the City, if any; and (v) that the issuance of such Additional Bonds will not, of itself, cause interest on the Bonds to become includable in gross income for federal income tax purposes. (c) A Certificate of the City certifying that these requirements have been either met or provided for, together with a copy of the amendment to the Lease. (d) A Certificate of the City certifying that the estimated value of the Leased Property is equal to or greater than the Outstanding amount of the Bonds and the Additional Bonds. 20 THE CITY OF WEST COVINA The City of West Covina encompasses approximately 17 square miles within the San Gabriel Valley and is located in the northeast portion of the County of Los Angeles. The City is 19 miles northeast of downtown Los Angeles. Government Organization The City of West Covina was incorporated on February 17, 1923 as a general law city and uses the Council-Manager form of municipal government. The City Council members are elected to overlapping terms of four years and select one of their members to serve as Mayor. The City Manager is appointed by the City Council and directs day-to-day administration of the City's business. The members of the City Council, the expiration dates of their terms and key administrative personnel are set forth in the charts below. Council Member Steve Herfert, Mayor Mike Touhey, Mayor Pro Tern Karin Armbrust, Councilmember Sherri Lane, Councilmember Shelley Sanderson, Councilmember Term Expires November 8, 2011 November 5, 2013 November 8, 2011 November 5, 2013 November 5, 2013 KEY ADMINISTRATIVE PERSONNEL Andrew G. Pasmant, City Manager Thomas E. Bachman, Assistant City Manager/Finance Director Chris Freeland, Deputy City Manager Christopher J. Chung, Community Development Commission Director Michele McNeill, Community Services Director Shannon Yauchzee, Public Works Director Erin Hope, Risk Management Director Dennis Swink, Controller Sue Rush, City Clerk Marian Smithson, City Treasurer Arnold M. Alvarez-Glasman, City Attorney West Covina currently employs 348 full-time staff members and 65 full-time equivalent part-time workers. West Covina provides both police and fire protection. As of June 30, 2011, the City had 96 sworn police officers and the City's Fire Department had 64 sworn officers. In addition to public safety, other City services include building permit and inspection, landscape and public infrastructure maintenance, weed abatement, municipal code compliance and landfill enforcement, extensive parks and recreation programs and facilities, as well as a local bus shuttle and paratransit system. Community Information The West Covina Unified School District serves more than 10,000 students in 8 elementary schools, 3 middle schools, 2 high schools (including one alternative) and 2 charter schools. There are numerous private preschools and elementary schools within the City. Within a 30-mile radius of West Covina are higher education facilities of all levels. With a selection of nearby community colleges as well as four year universities, residents have a wide choice to continue or complete their education. Community Colleges Citrus Community College Mount San Antonio College Rio Hondo Community College Whittier Community College Pasadena City College Four Year Universities Cal State Polytechnic University, Pomona Cal State University, Fullerton Cal State University, Los Angeles Claremont McKenna College Occidental College Azusa Pacific University University of La Verne West Covina has five medical facilities and one trauma center available in close proximately for residents of West Covina. Hospitals providing health care to City residents include Queen of the Valley Hospital, West Covina Hospital and Kaiser Permanente Medical Group. There are sixteen parks and two recreation centers, including the Community Youth Center and Cameron Community Center and Gymnasium, with programs for sports and recreation. The Senior Citizen's Center is active and hosts tournaments, trips and social gatherings. Transportation The City's close proximity to several major sources of transportation gives the City access to regional, national and international markets. Ontario International Airport is located 20 miles east of the City and is served by most domestic carriers. Los Angeles International Airport is located 40 miles west of the City and is served by every major airline. The Metropolitan Transit District serves the City locally with two routes. West Covina serves as a transit hub for bus service within the San Gabriel Valley. Together, Foothill Transit District and the Los Angeles County Metropolitan Transportation Authority provide over 400 bus arrivals and departures in West Covina daily. These buses serve express and local routes throughout West Covina and the greater Los Angeles County area. The City is served by two Metrolink train stations in the nearby cities of Covina and Baldwin Park. Metrolink provides daily light-rail commuter train service between residential and major commercial areas within Los Angeles, Riverside, San Bernardino and Ventura Counties. The City also offers local shuttle bus service, providing convenient connections between regional malls, Civic Center, Senior Citizens' Center, regional hospital facilities and the Baldwin Park Metrolink train station. 22 West Covina enjoys easy access to the Los Angeles Freeway System. A major freeway, Interstate 10 (the San Bernardino Freeway) runs through the northern section of the city. The following major freeways also serve the city: State Highway 60 (Pomona Freeway) to the south; Interstate 605 (San Gabriel Valley River Freeway) to the West; and State Highway 57 (Orange Freeway) to the east. Population The following table provides a comparison of population growth for the City of West Covina, surrounding cities and Los Angeles County between 2007 and 2011. TABLE NO. 1 CHANGE IN POPULATION CITY OF WEST COVINA, SURROUNDING CITIES AND LOS ANGELES COUNTY 2007 — 2011 WEST COVINA SURROUNDING CITIES LOS ANGELES COUNTY Year Percentage Percentage Percentage Population Change Population Change Population Change 2007 106,985 165,131 9,780,808 2008 106,426 (0.5%) 164,447 (0.4%) 9,785,474 0.0% 2009 106,231 (0.2%) 163,894 (0.3%) 9,801,096 0.2% 2010 106,189 0.0% 163,648 (0.2%) 9,822,121 0.2% 2011 106,400 0.2% 163,976 0.2% 9,858,989 0.4% % Increase Between 2007 -2011 (0.5%) (0.7%) 0.8% Surrounding cities include Baldwin Park, Covina, Industry and La Puente. Source: State of California, Department of Finance, "E-4 Population Estimates for Cities, Counties and the State, 2001-2010, with 2000 & 2010 Census Counts" Sacramento, California, August 2011, "E-5 Population and Housing Estimates for Cities, Counties, and the State, 2010-2011, with 2010 Benchmark" Sacramento, California, May 2011 and "January 2011 Tables of City Population Ranked by Size, Numeric and Percent Change" Sacramento, California, May 2011. 23 Employment As of July 1, 2011, the civilian labor force for the City was approximately 54,600 of whom 48,200 were employed. The unadjusted unemployment rate as of July 2011 was 11.7% for the City as compared to 13.2% for the County and 12.4% for the State. Civilian labor force, employment and unemployment statistics for the City, County, the State and the nation, for the years 2006 through 2010 are shown in the following table: TABLE NO. 2 CITY OF WEST COVINA CIVILIAN LABOR FORCE, EMPLOYMENT AND UNEMPLOYMENT ANNUAL AVERAGES Year Civilian Labor Force Employment Unemployment Unemployment Rate 2006 City of West Covina 54,700 52,400 2,300 4.2% Los Angeles County 4,806,600 4,578,700 229,900 4.8 California 17,686,700 16,821,300 865,400 4.9 United States 151,413,000 144,419,000 7,001,000 4.6 2007 City of West Covina 55,400 52,900 2,500 4.4 Los Angeles County 4,874,600 4,626,900 247,600 5.1 California 17,928,700 16,970,200 958,500 5.3 United States 153,126,000 146,049,000 7,078,000 4.6 2008 City of West Covina 55,800 52,200 3,700 6.5 Los Angeles County 4,930,900 4,563,200 347,600 7.5 California 18,191,000 16,833,400 1,307,600 7.2 United States 154,329,000 145,368,000 8,924,000 5.8 2009 City of West Covina 55,200 49,600 5,600 10.1 Los Angeles County 4,900,100 4,336,600 563,500 11.5 California 18,204,200 16,141,500 2,062,700 11.3 United States 154,142,000 139,877,000 14,265,000 9.3 2010 City of West Covina 55,100 48,900 6,100 11.2 Los Angeles County 4,879,500 4,262,300 617,200 12.6 California 18,176,200 15,916,300 2,259,900 12.4 United States 153,889,000 139,064,000 14,825,000 9.6 Source: California State Employment Development Department and United States Bureau of Labor Statistics. 24 The City is located in the Los Angeles-Long Beach-Glendale Metropolitan Division. Six major job categories constitute 78.6% of the work force. They are service producing (15.5%), government (14.6%), professional and business services (14.0%), educational and health services (13.9%), leisure and hospitality (10.5%), and manufacturing (10.1%). The July 2011 unemployment rate in the Los Angeles- Long Beach-Glendale Metropolitan Division was 13.3%. The State of California July 2011 unemployment rate (unadjusted) was 12.4%. TABLE NO. 3 LOS ANGELES-LONG BEACH-GLENDALE METROPOLITAN DIVISION WAGE AND SALARY WORKERS BY INDUSTRY 0) (in thousands) Industry 2007 2008 2009 2010 2011 Government 578.4 588.0 579.5 554.9 549.0 Other Services 147.0 146.9 137.1 136.8 135.4 Leisure and Hospitality 403.4 410.8 389.0 388.9 395.7 Educational and Health Services 479.8 493.4 503.1 505.9 521.3 Professional and Business Services 602.9 584.1 518.3 525.8 525.4 Financial Activities 245.3 233.8 214.6 209.8 206.6 Information 209 209.8 188.1 189.1 202.7 Transportation, Warehousing and Utilities 166.0 165.1 148.1 151.2 147.7 Service Producing Retail Trade 422.0 413.5 379.5 382.8 385.0 Wholesale Trade 226.8 223.3 201.2 203.3 199.3 Manufacturing Nondurable Goods 198.1 192.7 171.1 168.4 168.8 Durable Goods 250.9 244.3 214.7 208.2 209.3 Goods Producing Construction 160.6 145.4 115.4 105.2 99.7 Mining and Logging 4.4 4.4 4.0 4.3 4.2 Total Nonfarm 4,094.6 4,055.5 3,763.7 3,734.6 3,750.1 Farm 7.7 6.9 5.9 6.2 6.2 Total (all industries) 1,112_3. 4,062.4 3,769.6 3.7.401 3,756.3 Source: State of California Employment Development Department, Labor Market Information Division, "Industry Employment & Labor Force - by month, March 2010 Benchmark." 0) Annually, as of July. 25 The major employers operating within the City and their respective number of employees as of June 30, 2011 are as follows: TABLE NO. 4 CITY OF WEST COVINA LARGEST EMPLOYERS Name of Company Queen of the Valley Campus West Covina Unified School District Target Store #TI028 & #T2147 City of West Covina Macy's SGV Newspaper Group J C Penney Corp Inc. #1505-7 Interspace/Concorde Battery B.J.'s Restaurant and Brewery Sears Roebuck & Company Number of Employees Product/Service 1,781 Education 1,354 Education 482 Retail Store 459 Municipal Services 273 Department Store 264 Newspaper 256 Department Store 213 Manufacturing 181 Restaurant 149 Department Store Source: City of West Covina Finance Department. Per Capita Income Per capita income information for West Covina, Los Angeles County, the State of California and the United States is summarized in the following table. TABLE NO. 5 PER CAPITA INCOME CITY OF WEST COVINA, LOS ANGELES COUNTY, STATE OF CALIFORNIA AND UNITED STATES 2005 — 2009 Year West Covina Los Angeles County State of California United States 2005 $37,543 $34,214 $37,183 $34,685 2006 40,538 36,196 39,358 36,629 2007 42,278 36,762 41,571 38,615 2008 42,916 39,657 43,641 40,208 2009 42,818 37,718 42,395 39,635 Source: West Covina Comprehensive Annual Financial Report; U.S. Department of Commerce, Bureau of Economic Analysis. 26 Commercial Activity The following table summarizes the volume of retail and food services sales and taxable transactions for the City for 2005 through 2009 (the most recent year for which statistics are available for the full year). The City's sales tax receipts declined by approximately 12% for Fiscal Year 2009/10 and increased by 4% for Fiscal Year 2010/11. On September 1, 2011 Westfield West Covina hosted a grand opening ceremony for the completion of the mall's Phase III development, which includes Nordstrom Rack, Gold's Gym and a new state-of-the-art Playspace. Nordstrom Rack and Gold's Gym will join many new tenants at the mall, including XXI Forever and H&M. These new businesses are expected to increase the City's sales tax receipts in future years. TABLE NO. 6 CITY OF WEST COVINA TOTAL TAXABLE TRANSACTIONS (in thousands) 2005 — 2009 Retail and Retail and Total Taxable Food Services Food Services Transactions Issued Sales Year ($000's) % Change Permits ($000's) % Change Permits 2005 $1,231,009 1,101 $1,344,132 1,914 2006 1,246,069 1.2% 1,123 1,361,247 1.3% 1,886 2007 1,249,018 0.2% 1,146 1,353,441 (0.6%) 1,841 2008 1,133,830 (9.2%) 1,139 1,251,547 (7.5%) 1,813 2009 967,357 (14.7%) 1,183 1,081,262 (13.6%) 1,631 Source: State Board of Equalization, "Taxable Sales in California." The following table summarizes the change in taxable transactions for the City of West Covina and surrounding cities for 2005 through 2009 (the most recent year for which statistics are available for the full year). TABLE NO. 7 CITY OF WEST COVINA AND SURROUNDING CITIES CHANGE IN TOTAL TAXABLE TRANSACTIONS (in thousands) 2005 — 2009 % Change from City 2005 2006 2007 2008 2009 2005 - 2009 WEST COVINA $1,344,132 $1,361,247 $1,353,441 $1,251,547 $1,081,262 (19.6%) Baldwin Park 530,775 557,750 566,938 528,973 462,814 (12.8%) Covina 804,873 808,666 790,660 701,315 581,911 (27.7%) Industry 2,810,034 2,989,254 3,067,172 2,758,613 2,362,529 (15.9%) La Puente 221,950 230,991 219,884 200,713 179,370 (19.2%) Source: State Board of Equalization, "Taxable Sales in California." All Other Outlets 113,123 115,178 104,423 117,717 113,905 Total All Outlets $1 344 32 51,361,247 $1 353 441 $I 251 547 $1 081 262 Taxable transactions by type of business for the City are summarized below for 2005 through 2009 (the most recent year for which statistics are available for the full year). TABLE NO. 8 CITY OF WEST COVINA TAXABLE TRANSACTIONS BY TYPE OF BUSINESS (in thousands) 2005 - 2009 2005 2006 2007 2008 2009 Retail and Food Services Clothing and Clothing Accessories Stores $ 109,792 $ 111,315 $ 105,702 $ 100,212 $ 99,768 General Merchandise Stores 244,493 239,489 232,571 214,295 167,992 Food and Beverage Stores 42,203 43,174 46,154 43,304 47,804 Food Services and Drinking Places 127,138 141,155 144,280 145,907 139,998 Home Furnishings and Appliance Stores 59,230 57,259 50,077 52,428 60,346 Building Materials and Garden Equipment and Supplies 16,522 14,490 7,318 # # Motor Vehicle and Parts Dealers 391,155 383,094 422,505 358,583 269,143 Gasoline Stations 72,406 85,224 89,283 83,865 73,758 Other Retail Group 168 070 170,869 151,128 135,236# 108,54911 Total Retail and Food Services 1,231,009 1,246,069 1,249,018 1,133,830 967,357 Source: State Board of Equalization, "Taxable Sales in California." # Sales omitted because their publication would result in the disclosure of confidential information. 28 Building Activity The following table summarizes building activity valuations for the City of West Covina for the five fiscal years 2006/07 through 2010/11. TABLE NO. 9 CITY OF WEST COVINA BUILDING ACTIVITY AND VALUATION (in thousands) 2006/07 to 2010/11 2006/07 2007/08 2008/09 2009/10 2010/11 Residential $ 28,599,403 $ 24,664,628 $ 21,318,098 $ 13,201,353 $ 15,927,162 Commercial 74,417,833 54,441,750 48,458,333 34,664,157 24,334,341 Total Valuation $103 017 236 $ 79,106,379 $ 69,776,431 $ 47,865,510 $ 40,261,503 Number of Residential Units 29 29 48 Source: City of West Covina. FINANCIAL INFORMATION Budgetary Process and Administration The annual budget adopted by the City Council provides for the general operation of the City. The annual budget is adopted in summary by the City Council in June of each year for the General, special revenue, debt service funds and capital projects funds. The resolution sets a combined appropriation of the funds for the operation of the City. The City Manager is authorized to transfer budgeted amounts between departments to assure adequate and proper standards of service. Budgetary revisions, including supplemental appropriations which increase appropriations in individual funds, must be approved by the City Council. The budgetary level of control is at the fund level. The budgeted figures used in the financial statements are the final amended amounts, which do not vary significantly from the original adopted budget. The budget is formally integrated into the accounting system and employed as a management control device during the year for the General Fund, special revenue funds, debt service funds and capital projects funds. Budgets for governmental fund types are adopted on a basis consistent with generally accepted accounting principles. Operating appropriations lapse at the end of the fiscal year. Capital projects funds are appropriated on a project basis and appropriations are funded by the council to continue until the specific projects are completed. Appropriations Limit Section 7910 of the Government Code of the State of California requires the City to adopt a formal appropriations limit for each fiscal year. The City's appropriations limit for fiscal year 2011/12 is $110,790,424. The City's appropriations subject to the limit for 2011/12 are $36,052,346. Based on this, the appropriations limit is not expected to have any impact on the ability of the City to continue to budget and appropriate the Lease Payments as required by the Lease. General Fund Revenues and Expenditures The City's General Fund Budget includes programs which are provided on a largely citywide basis. The programs and services are financed primarily by the City's share of property taxes, sales tax, revenues from the State, and charges for services provided. (See "RISK FACTORS - State Budget" herein). A comparison of the Fiscal Year 2010/11 Budget, estimated actual results for Fiscal Year 2010/11 and the Fiscal Year 2011/12 Budget is shown in Table No. 10. The City's budget for 2011/12 reflects the City's assessment of the continuing impact of the recession on revenues. Fiscal Year 2011/12 Budget Some key assumptions incorporated into the Fiscal Year 2011/12 General Fund Budget prepared by the City in June 2011 are as follows: • Property tax will remain at its 2010/11 level; • Sales tax will increase by 10% due to the opening of new major tenants at Westfield shopping center; • Non-safety employees will begin contributing the employees' share of the CalPERS contribution; 30 • $825,000 positive net impact of FEMA grant on Fire Department budget; • Elimination of 14 vacant sworn police officer positions; • Inclusion of cost of City Election in November 2011; • Reduction of $500,000 in public safety overtime costs; and • A drawdown of fund balance of $1.8 million Revenues The revenues in Table No. 10 that follows are categorized as: Taxes, detailed in Table No. 15 "Tax Revenues by Source," which includes general property tax, sales tax, transient occupancy taxes, franchise taxes (cable, utility, trash), business license tax, documentary transfer tax and contractor's license tax; Licenses and Permits, which includes construction building permits, and dog licenses; Fines and Forfeitures, which includes municipal and vehicle code violations and vehicle impound fees; Revenue from Use of Money, which includes interest income (primarily on amounts due from the West Covina Community Development Commission (CDC) on amounts borrowed from the City) and rental income; Intergovernmental Revenue, which includes motor vehicle license fees, state reimbursements for mandated costs and Proposition A funds; Charges for Services, comprised of ambulance fees (55%), towing and other charges such as plan checking, building inspection, and other municipal services; Interfund Charges for overhead charged to other departments and funds for General Fund support and administrative functions, and a sales tax reimbursement from the CDC. Miscellaneous Revenue. The largest components of estimated Fiscal Year 2011/12 General Fund revenues are property tax (approximately 36%) and sales tax (approximately 26%). Expenditures The expenditures in Table No. 10 that follows are categorized by governmental function. Each function generally includes salaries and benefits, materials and supplies, and capital outlay, if any. Salaries and Benefits include direct personnel costs, benefits, health insurance costs and workers' compensation and unemployment insurance costs. Materials and supplies include non-personnel operating costs and contract professional services. The City has both a police department and a fire department. Public safety expenditures represent approximately 80% of the total budgeted General Fund expenditures for Fiscal Year 2011/12. Table No. 10 provides a comparison of the Fiscal Year 2010/11 Budget, estimated actual results for Fiscal Year 2010/11 and the Fiscal Year 2011/12 Budget. TABLE NO. 10 CITY OF WEST COVINA GENERAL FUND REVENUES AND EXPENDITURES 2010/11 Budget 2010/11 Estimated Actual 2011/12 Budget Change Amount % Revenues: Taxes $35,194,000 $36,018,006 $37,310,000 $ 1,291,994 3.6% License and Permits 1,064,900 1,099,084 1,223,800 124,716 11.3% Fines and Forfeitures 156,000 157,041 136,000 (21,041) (13.4%) Use of Money and Property 3,015,000 3,082,869 3,040,228 (42,641) (1.4%) Revenue from Other Agencies 1,308,000 1,704,024 2,903,092 1,199,068 70.4% Charges for Services 3,513,150 3,204,286 3,037,700 (166,586) (5.2%) Interfund Charges 2,950,000 2,234,635 2,375,000 140,365 6.3% All Other Revenues 105,620 146,311 149,000 2,689 1.8% Transfers In 1,604,650 1,592,645 1,449,000 (143,645) (9.0%) Total Revenues $48,911,320 $49,238,901 $51,623,820 $ 2,384,919 4.8% Expenditures: General Government $ 1,282,433 $ 1,118,704 $ 1,215,934 $ 97,230 8.7% Public Safety 41,352,521 40,831,073 42,514,559 1,683,486 4.1% Public Works 4,674,414 4,398,238 4,511,977 113,739 2.6% Community Services 1,189,022 1,097,794 1,163,627 65,833 6.0% Administrative Services 3,225,936 3,040,323 3,268,452 228,129 7.5% Transfers Out 1,020,266 966,050 811,050 (155,000) (16.0%) Total Expenditures $52,744,592 $51,452,182 $53,485,599 $ 2,033,417 4.0% Net Change in Fund Balance $ (3,833,272) $ (2,213,281) $ (1,861,779) $ 351,502 Beginning Undesignated Fund Balance 9,710,686 9,710,686 7,497,405 Ending Undesignated Fund Balance $ 5,877,414 $ 7,497,405 $ 5,635,626 Source: City of West Covina. Ad Valorem Property Taxes Taxes are levied for each fiscal year on taxable real and personal property which is situated in the City as of the preceding January L For assessment and collection purposes, property is classified either as "secured" or "unsecured," and is listed accordingly on separate parts of the assessment roll. The "secured roll" is that part of the assessment roll containing State assessed property and real property having a tax lien which is sufficient, in the opinion of the assessor, to secure payment of the taxes. Other property is assessed on the "unsecured roll." Property taxes on the secured roll are due in two installments, on November 1 and February 1 of the fiscal year. If unpaid, such taxes become delinquent on December 10 and April 10, respectively, and a 10% penalty attaches to any delinquent payment. In addition, property on the secured roll with respect to which taxes are delinquent is sold to the State on or about June 30 of the fiscal year. Such property may thereafter be redeemed by payment of the delinquent taxes and the delinquency penalty, plus a redemption penalty of 11/2% per month to the time of redemption. If taxes are unpaid for a period of five years or more, the property is subject to sale by the County Tax Collector. Property taxes on the unsecured roll become delinquent, if unpaid on August 31. A 10% penalty attaches to delinquent taxes on property on the unsecured roll, and an additional penalty of 11/2% per month begins to accrue on November 1 of the fiscal year. The County of Los Angeles has four ways of collecting delinquent unsecured personal property taxes: (1) a civil action against the taxpayer; (2) filing a certificate in the office of the County Clerk specifying certain facts in order to obtain a judgment lien on certain property of the taxpayer; (3) filing a certificate of delinquency for record in the County Recorder's Office, in order to obtain a lien on certain property of the taxpayer; and (4) seizure and sale of personal property, improvements or possessory interests belonging or assessed to the assessee. Taxable Property and Assessed Valuation Set forth in Table No. 11 are assessed valuations for secured and unsecured property within the City of West Covina. TABLE NO. 11 CITY OF WEST COVINA GROSS ASSESSED VALUE OF ALL TAXABLE PROPERTY Fiscal Year 2007/08 2008/09 2009/10 2010/11 2011/12 Secu red $8,086,113,985 8,612,770,792 8,392,455,137 8,384,860,755 8,552,654,130 Unsecured $159,288,793 165,246,871 177,464,312 167,778,142 164,604,305 Total $8,245,402,778 8,778,017,663 8,569,919,449 8,552,638,897 8,717,258,435 Source: County of Los Angeles Auditor-Controller. 33 Property tax levies and collections for the City are set forth in Table No. 12. TABLE NO. 12 CITY OF WEST COVINA SECURED TAX LEVIES AND COLLECTIONS Fiscal Total Collections within the Fiscal Collections Year Tax Year of the Levy in Total Ended Levy for Percentage Subsequent Tax Percentage June 30 Fiscal Year (1) Amount of Levy Years Collections of Levy 2007 2008 2009 2010 2011 $8,255,755 8,788,631 9,207,210 8,913,839 $7,536,422 7,766,633 8,509,721 8,152,304 91.29% 88.37% 92.42% 91.46% (7,738) (65,994) 104,568 111,790 $7,528,684 7,700,639 8,614,289 8,264,094 91.19% 87.62% 93.56% 92.71% Source: City of West Covina and Los Angeles County Auditor-Controller. (I) Includes City property taxes and CDC tax increment, prior to any passthroughs to other agencies. Redevelopment Agencies The California Redevelopment Law (Part 1 of Division 24 of the Health & Safety Code of the State) authorizes the redevelopment agency of any city or county to receive an allocation of tax revenues resulting from increases in assessed values of properties within designated redevelopment project areas (the "incremental value") occurring after the year the project area is formed. In effect, local taxing authorities, such as the City, realize tax revenues only on the assessed value of such property at the time the redevelopment project is created for the duration of such redevelopment project. There are 2 redevelopment projects in the City, the merged West Covina Redevelopment Project and the City-Wide Redevelopment Project. Table No. 13 sets forth total assessed valuations and redevelopment agency incremental values. The State Legislature approved ABX1 26 and ABX1 27 during the 2011/12 State budget process, which have been signed by the Governor. ABX1 26 eliminates redevelopment agencies State-wide. ABX1 27 allows for redevelopment agencies to continue operating if payments are made by the community to provide increased levels of school funding. The California Supreme Court has stayed certain provisions of ABX1 26 and all of ABX1 27 until a ruling can be made on a challenge to those bills. See "RISK FACTORS - State Budget." No assurance can be given on the impact of ABX1 26 and ABX1 27 on the City's General Fund Property Taxes. 34 TABLE NO. 13 CITY OF WEST COVINA TOTAL AND NET PROPERTY TAX VALUATIONS Total Redevelopment Fiscal Assessed Agency Net Percent Year Valuation Incremental Value Value Change 2007/08 2008/09 2009/10 2010/11 2011/12 $8,245,402,778 8,778,017,663 8,569,919,449 8,552,638,897 8,717,258,435 $1,681,925,670 1,371,047,710 1,182,546,582 1,089,683,961 1,111,677,728 $6,563,477,108 7,406,969,953 7,387,372,867 7,462,954,936 7,605,580,707 12.9% (0.3%) 1.0% 1.9% Source: County of Los Angeles Auditor-Controller. Largest Taxpayers The principal taxpayers as of June 30, 2011 are as shown in Table No. 14. TABLE NO. 14 CITY OF WEST COVINA LARGEST TAXPAYERS Assessed Percent Taxpayer Valuation of Total Plaza West Covina LLC Eastland Shopping Center LLC Gateway Crescent LLC PPC WR Apartments LLC Eastland Tower Partnership Legacy Partners Verandas LP CP Lafayette Parc LLC SP Torrey Pines LLC Hassen Real Estate Partnership Kor Barn Sunset Plaza LLC Source: West Covina Annual Financial Report. $185,090,345 2.16% 102,072,600 1.19 56,730,228 0.66 51,361,141 0.60 51,008,272 0.60 48,065,859 0.56 43,724,863 0.51 40,107,000 0.47 34,956,936 0.41 30,540,327 0.36 $643,657,571 7.53% 35 State Legislative Shift of Property Tax Allocation Beginning in 1992/93, the State has required that local agencies including cities remit a portion of property taxes received to augment school funding. These funds are deposited in each county's Education Revenue Augmentation Fund ("ERAF"). This was a permanent shift of property tax from the City's General Fund. On July 24, 2009, the California legislature approved amendments to the 2009/10 Budget to close an anticipated $26.3 billion budget shortfall. The approved amendments included borrowing from local governments by withholding the equivalent of 8% of Fiscal Year 2008/09 property related tax revenues from cities' and counties' property tax collections under provisions of Proposition 1A (approved by the voters in 2004), which the State must repay with interest within three years. The City participated in the Proposition 1A securitization program undertaken by the California Statewide Community Development Authority, whereby the City sold the $1,722,830 receivable that resulted from the State borrowing of property tax revenues. The State may not implement additional borrowing under Proposition 1A in 2011/12, but could as soon as 2012/13. In addition, certain other provisions in the State budget have resulted in a realignment of property tax revenues: On March 2, 2004, voters approved a bond initiative formally known as the "California Economic Recovery Act." This act authorized the issuance of $15 billion in bonds to finance the 2002/03 and 2003/04 State budget deficits, to be payable from a fund to be established by the redirection of tax revenues through the "Triple Flip." Under the "Triple Flip," one-quarter of local governments' 1% share of the sales tax imposed on taxable transactions within their jurisdiction is redirected to the State. In an effort to eliminate the adverse impact of the sales tax revenue redirection on local government, the legislation provides for property taxes in the ERAF to be redirected to local government. Because the ERAF moneys were previously earmarked for schools, the legislation provides for schools to receive other state general fund revenues. It is expected that the swap of sales taxes for property taxes would terminate once the deficit financing bonds were repaid, which is currently expected to occur in approximately 12 years. The sales tax estimated to be received through an in lieu payment from State property tax revenues, approximately $3.3 million, is included in sales taxes shown in Table No. 15. The City receives a portion of Department of Motor Vehicles license fees ("VLF") collected statewide. Several years ago, the State-wide VLF was reduced by approximately two-thirds. However, the State continued to remit to cities and counties the same amount that those local agencies would have received if the VLF had not been reduced, known as the "VLF backfill." The City's budgeted VLF amount of $250,000 for Fiscal Year 2011/12 is based on the VLF expected to be paid to the County. The State VLF backfill to be received through an in lieu payment from State property tax revenues, approximately $8.6 million, is included in property taxes shown in Table No. 15. Local Taxes In addition to ad valorem taxes on real property, the City receives the following local taxes: Sales and Use Taxes. Sales tax is collected and distributed by the State Board of Equalization. Each local jurisdiction receives an amount equal to 1% of taxable sales within their jurisdiction. In addition, the City receives a portion of a 1/2 cent sales tax increase approved by voters in 1993. Sales tax generated by this increase is used to offset certain expenses for public safety. Franchise Taxes. The City levies a franchise tax on its cable television, trash collection and utility franchises. Business License Taxes. The City levies a business license tax based on the number of employees. 36 Transient Occupancy Taxes. The City levies a 10% transient occupancy tax on hotel and motel bills. TABLE NO. 15 CITY OF WEST COVINA TAX REVENUES BY SOURCE Estimated Budget 2008 2009 2010 2011 2012 Property Taxes $17,841,038 $18,565,796 $17,841,038 $17,590,376 $17,685,000 Sales and Use Taxes (I) 11,043,774 12,572,858 11,043,774 11,503,540 12,700,000 Franchise Taxes 3,367,958 3,512,830 3,093,538 3,159,080 3,325,000 Transient Occupancy Taxes 1,057,734 787,286 647,123 756,573 850,000 Business License Taxes 1,566,042 1,828,915 2,075,987 2,182,985 2,200,000 Other Taxes 651,518 514,083 416,560 354,151 550,000 Total General Fund Tax Revenues $35,530,072 $37,781,768 $35,118,020 $35,546,705 $37,310,000 Source: City of West Covina. (I) On September 1, 2011 Westfield West Covina hosted a grand opening ceremony for the completion of the mall's Phase III development, which includes Nordstrom Rack, Gold's Gym and a new state-of-the-art Playspace. Nordstrom Rack and Gold's Gym will join many new tenants at the mall, including XXI Forever and H&M. These new businesses are expected to increase the City's sales tax beginning in 2011/12. Motor Vehicle License Fees As described above, the City receives a portion of Department of Motor Vehicles license fees ("VLF") collected statewide. The total VLF estimated for Fiscal Year 2011/12 is $8,850,000, of which $250,000 is expected to be received through a payment from the State and is included in "revenue from other agencies" in the City's budget. The balance of $8.6 million is budgeted as property tax, to be received through an in lieu payment from State property tax revenues. A temporary two-year increase in VLF rates went into effect on May 19, 2009 and expired on July 1, 2011. This increased the funding of VLF from fees and reduced the State's VLF backfill from the property tax realignment. See "RISK FACTORS - State Budget" herein. Retirement Programs California Public Employees Retirement System (PERS) Plan Description. The City contributes to the California Public Employees Retirement System (PERS), an agent multiple-employer public employee defined benefit pension plan. PERS provides retirement, disability benefits, and death benefits to plan members and beneficiaries. PERS acts as a common investment and administrative agent for participating public entities within the State of California. Copies of PERS' annual financial report may be obtained from its executive office at 400 "P" Street, Sacramento, California 95814. Funding Policy. Participants are required to contribute 8% of their annual covered salary for miscellaneous employees and 9% for safety employees. The City makes the contributions required of City employees on their behalf and for their account. Benefit provisions and all other requirements are established by state statute and City contracts with employee bargaining groups. Under GASB 27, an employer reports an annual pension cost (APC) equal to the annual required contribution (ARC) plus an adjustment for the cumulative difference between the APC and the employer's actual plan contributions for the year. The cumulative difference is called the net pension obligation (NPO). The ARC for the period July 1, 2009 to June 30, 2010 has been determined by an actuarial valuation of the plan as of June 30, 2007. The contribution rate indicated for the period is 27.246% of payroll for the safety plan and 9.131% of payroll for the miscellaneous plan. In order to calculate the dollar value of the ARC for inclusion in financial statements prepared as of June 30, 2010, the contribution rate is multiplied by the payroll of covered employees that were paid during the period from July 1, 2009 to June 30, 2010. The excess of total actuarial accrued liability over the actuarial value of plan assets is called the unfunded actuarial accrued liability. Changes in the liability due to subsequent plan amendments are amortized as a level percent of pay over a closed 20-year period. Gains and losses that occur in the operation of the plan are amortized over a rolling 30-year period. If the plan's accrued liability exceeds the actuarial value of plan assets, then the amortization period may not be lower than the payment calculated over a 30-year amortization period. For the safety plan, the unfunded actuarial liability is amortized over a period ending June 30, 2039. For the miscellaneous plan, the unfunded actuarial liability is amortized over a period ending June 30, 2038. Contribution Rates. The contribution requirements of plan members and the City are established by PERS. PERS set contribution rates for 2010/11 at 9.66% for miscellaneous employees and 27.535% for safety employees. For 2011/12, PERS has set contribution rates at 14.207% for miscellaneous employees and 33.657% for safety employees. These rates are factored in to the City's 2011/12 budget. PERS set contribution rates for 2010/11 based on a 4.9% negative return on investments which occurred in 2007/08. For the Fiscal Year 2008/09, the PERS portfolio had lost more than 23% of its value. This loss will begin affecting PERS contribution rates in 2011/12. For Fiscal Year 2009/10 the PERS portfolio rate of return was 11.6%. From July 1,2010 through June 30, 2011, the PERS portfolio rate of return was 20.9%. The City's percentage of payroll for PERS payments for each retirement account for 2005/06 through 2011/12 and estimates for 2012/13 and for 2013/14 are shown in the table below. Fiscal Year 2005/06 2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13* 2013/14* Miscellaneous 6.986% 10.017 9.529 8.596 9.131 9.660 14.207 15.700 19.500 Safety 27.234% 26.728 25.512 25.197 27.246 27.535 33.657 35.600 40.700 * Projected by PERS. 38 Annual Pension Costs. The City's annual pension cost for 2010/11 and the two previous years was $6,049,513, $6,473,430 and $5,266,213, respectively. These were equal to the City's required and actual contributions. The required contribution was determined as part of the June 30, 2007, actuarial valuation using the entry age normal actuarial cost method. The actuarial assumptions included; (a) 7.75% investment rate of return (net of administrative expenses), (b) projected salary increases of 3.25% to 14.45% for miscellaneous employees and 3.25% to 13.15% for safety employees, depending on age, service, and type of employment, (c) 3.0% per year cost-of-living adjustments and (d) 3.25% payroll growth. Both (a) and (b) included an inflation component of 3%. The actuarial value of PERS assets was determined using techniques that smooth the effects of short-term volatility in the market value of investments over a fifteen-year period. PERS unfunded actuarial accrued liabilities (or surplus) is being amortized as a level percentage of projected payroll on a closed basis. The average remaining amortization period at June 30, 2007 was 31years for miscellaneous employees and 32 years for safety employees for prior and current service unfunded liability. Fiscal Year THREE-YEAR TREND INFORMATION FOR PERS Annual Pension Cost (Employer Contribution) Percentage of Safety Miscellaneous APC Contributed Net Pension Obligation 6/30/09 $4,182,392 $1,083,821 100% 6/30/10 5,253,816 1,219,614 100% 6/30/11 4,872,146 1,177,367 100% The Schedule of Funding Progress for each of the City's employee groups below shows the recent history of the actuarial value of assets, actuarial accrued liability, their relationship, and the relationship of the unfunded accrued liability to payroll. The schedule of funding progress, presented below presents multiyear trend information about whether the actuarial value of plan assets is increasing or decreasing over time relative to the actuarial accrued liability for benefits. Valuation Date 6/30/07 6/30/08 6/30/09 Entry Age Normal Accrued Liability $218,973 233,093 255,522 Safety Employees (dollar amount in thousands) Unfunded Actuarial Liability/ Value (Excess Funded of Assets Assets) Status $186,780 $32,193 85.3% 197,914 35,179 84.9% 204,352 51,170 80.0% Annual Covered Payroll $18,185 19,632 20,372 UAAL As a % of Payroll 177.0% 179.2% 251.2% As of June 30, 2009, the market value of assets in this plan were $148,554,336, representing a funded status on a market value basis of 58.1%, compared to June 30, 2008, when the market value of assets was $202,894,626 and the funded status on a market value basis was 87.0%. 39 Entry Age Normal Accrued Liability Miscellaneous Employees (dollar amount in thousands) Unfunded Actuarial Liability/ Value (Excess of Assets Assets) Valuation Date Annual UAAL Covered As a % of Payroll Payroll Funded Status 6/30/07 $ 92,669 $90,614 $ 2,055 97.8% $13,696 15.0% 6/30/08 99,307 96,052 3,255 96.7% 13,833 23.5% 6/30/09 111,022 99,657 11,365 89.8% 13,834 82.2% As of June 30, 2009, the market value of assets in this plan were $72,620,160, representing a funded status on a market value basis of 65.4%, compared to June 30, 2008, when the market value of assets was $98,060,451 and the funded status on a market value basis was 98.7%. Public Agency Retirement System (PARS) Effective November 1, 2007, the City established two retirement plans with the Public Agency Retirement System (PARS) to supplement the current CalPERS retirement benefits. PARS is a single-employer defined benefit plan. It meets the requirements of a pension trust under the California Government Code. Phase II Systems is the PARS Trust Administrator. EPMC Replacement Supplemental Retirement Plan Participants in this plan include all full-time employees and council members, except members of the Police Officers Association. The EPMC Replacement Plan was established to replace a long-standing benefit for city employees no longer allowed by CalPERS. The plan provides for a benefit in an amount equal to the member's years of service, times the member's final pay, times the CalPERS age factor, times .70% for miscellaneous employees (times .89% for safety employees). At the time of retirement, employees will make an election to receive either a lump sum payment or receive ongoing stipends over their lifetime. Annual Pension Costs. The City makes all contributions to these plans. Participants do not make any contributions. For the fiscal year ended June 30, 2011, the City's required and actual contributions were $174,492. For the fiscal year ended June 30, 2010, the City's required contributions were $108,218 and actual contributions were $187,218. The required contribution was based on the October 1, 2007 actuarial valuation using the entry age normal actuarial cost method. The unfunded actuarial liability is based on a 20-year open amortization with amortization payments increasing 3.25% annually. The actuarial assumptions include: investment rate of return of 7%, projected salary increases of 3.25% to 12.65% (depending on years of service), and assumed inflation rate of 3%. The ongoing stipends will contain a 2% annual cost of living adjustment consistent with CalPERS pensions. 40 Supplemental Retirement Plan for Executive Staff and City Council This plan is separated into three tiers. Tier 1 (full-time non-safety Department Head) and Tier 2 (City Council) provides an additional retirement amount to miscellaneous department heads and City Council in an amount equal to the amount of the Retiree Medical Benefit received by the Police and Fire Chiefs. In order to be eligible for this benefit, participants must have five years of service with the City and must retire into PERS from the City. Tier 3 (City Manager) provides an increased retirement benefit to the City Manager consistent with the terms of his contract. It will convert the retirement formula for all years of prior CalPERS service at non- West Covina agencies to the CalPERS 2.5% @ 55 formula currently in place with the City of West Covina. Annual Pension Costs. All three tiers are combined for funding purposes in this plan. The City makes all contributions to these plans. Participants do not make any contributions. For the fiscal year ended June 30, 2011, the City's required and actual contributions were $52,716. For the fiscal year ended June 30, 2010, the City's required and actual contributions were $167,382. The required contribution was based on the November 1, 2007 actuarial valuation using the entry age normal actuarial cost method. The unfunded actuarial liability is based on a 20-year open amortization (10-years for Tier 3) with amortization payments remaining level. The actuarial assumptions include: investment rate of return of 7%, assumed inflation rate of 3%, projected salary increases of 3.25% to 12.65% (depending on years of service and 2% annual cost of living adjustments for Tier 3. THREE-YEAR TREND INFORMATION FOR PARS Annual Pension Cost (Employer Contribution) Fiscal Percentage of Net Pension Year EPMC Executive APC Contributed Obligation 6/30/08 $148,659 $146,569 100% $ - 6/30/09 95,989 168,074 100% - 6/30/10 187,218 167,382 100% The Schedule of Funding Progress below shows the recent history of the actuarial value of assets, actuarial accrued liability, their relationship, and the relationship of the unfunded accrued liability to payroll. The schedule of funding progress, presented below presents multiyear trend information about whether the actuarial value of plan assets is increasing or decreasing over time relative to the actuarial accrued liability for benefits. EPMC Entry Age Unfunded Normal Actuarial Liability/ Annual UAAL Valuation Accrued Value (Excess Funded Covered As a % of Date Liability of Assets Assets) Status Payroll Payroll 10/1/07 $1,359,333 $ - $1,359,333 0.00% $31,852,549 4.27% 6/30/09 1,028,173 27,130 1,001,043 2.64% 23,766,042 4.21% Actuarial Actuarial Value of Valuation Assets Date faj 7/1/09 $0 Annual required contribution Interest on net OPEB obligation Adjustment to annual required contribution Annual OPEB cost (expense) Contributions made (including premiums paid) Increase in net OPEB obligation Net OPEB obligation-beginning of year Net OPEB obligation-end of year $3,317,000 3,317,000 (1,114,523) 2,202,477 1,390,000 $3 592 477 The City's annual OPEB cost, the percentage of annual OPEB cost contributed to the plan, and the net OPEB obligation for 2010 and the two preceding years were as follows: Percentage of Fiscal Annual Year OPEB Cost 6/30/08 N/A 6/30/09 $2,437,000 6/30/10 3,317,000 OPEB Cost Net Pension Contributed Obligation N/A N/A 43.0% $1,390,000 33.6% 3,592,477 The City's actual contribution to OPEB costs was $1,114,523 for Fiscal Year 2010/11 and is estimated to be $ for Fiscal Year 2011/12. This estimated OPEB contribution is factored in to the City's 2011/12 budget. Funded Status and Funding Progress. Actuarial valuations of an ongoing plan involve estimates of the value of reported amounts and assumptions about the probability of occurrence of events far into the future. Examples include assumptions about future employment, mortality, and the healthcare cost trend. Amounts determined regarding the funded status of the plan and the annual required contributions of the employer are subject to continual revision as actual results are compared with past expectations and new estimates are made about the future. The schedule of funding progress presents multi-year trend information about whether the actuarial value of plan assets is increasing or decreasing over time relative to the actuarial accrued liabilities for the benefits. Schedule of Funding Progress (dollar amounts in thousands) Actuarial Accrued Liability Unfunded (AAL) - AAL Funded Entry Age (UAAL) Ration (b) (b-a) (a/b) $45,391 $45,391 0% UAAL as a Percentage of Covered Covered Payroll Payroll ((b-a)/c) $30,254 150.0% The next OPEB actuarial valuation will be dated as of June 30, 201 43 Actuarial Methods and Assumptions. Projections of benefits for financial reporting purposes are based on the substantive plan (the plan as understood by the employer and the plan members) and include the types of benefits provided at the time of each valuation and the historical pattern of sharing of benefit costs between employer and plan members to that point. The actuarial methods and assumptions used include techniques that are designed to reduce the effects of short-term volatility in actuarial accrued liabilities and the actuarial assets, consistent with the long-term perspective of the calculations. The actuarial cost method used for determining the benefit obligations is the Entry Age Normal Cost Method. The actuarial assumptions included a 5.0% investment rate of return, which is the assumed rate of the expected long-term investment returns on plan assets calculated based on the funded level of the plan at the valuation date, and an annual healthcare cost trend rate of 10% initially, reduced by decrements of 1% per year to an ultimate rate of 5% after the sixth year. Both rates included an inflation assumption. The UAAL is being amortized as a level percentage of projected payroll on an open basis over 30 years. It is assumed the City's payroll will increase 3% per year. Employee Relations and Collective Bargaining City employees are represented by one labor union and seven associations covering the following employee groups: Confidential/Exempt, Public Safety Dispatchers, General Employees, Maintenance Employees, Mid-Management, Fire, Police, and Police Management. The largest association is the Police Officers Association, representing approximately 24% of all City employees. Currently 100% of all City employees are covered by negotiated agreements. All current negotiated agreements expire on June 30, 2012. Risk Management The City is exposed to various risks of loss related to its operation, including losses associated with errors and omissions, injuries to employees and members of the public. The City's Internal Service Self Insurance Fund is used to account for and finance its uninsured risks of loss. The City of West Covina participates in a joint powers insurance authority insurance pooling arrangement with other public agencies for general liability coverage in excess of the City's self-insured retention of $1,000,000 per occurrence. The pool shares losses from $1 million to $2 million among its members and purchases commercial insurance/reinsurance for losses from $2 million to $27 million, per occurrence. The City of West Covina purchases statutory limits through a joint powers authority insurance pooling arrangement with other public agencies for worker's compensation coverage in excess of the City's self- insured retention of $1 million per occurrence. Claims for general liability and worker's compensation did not exceed the self insurance retention level in 2009, 2010 and 2011. The claims and judgments liability reported in the Internal Service Self Insurance Fund is based on the requirements of Governmental Accounting Standards Board Statement No. 10, which requires that a liability for claims and judgments be reported if information prior to the issuance of the financial statements indicates that it is probable that a liability has been incurred at the date of the financial statements and the amount of loss can be reasonably estimated. As of June 30, 2010 and June 30, 2011, claims and judgments payable, including estimated claims for incurred but not reported claims, amounted to $11,586,006 and $11,207,107, respectively. 44 City Investment Policy and Portfolio The City administers a pooled investment program, except for those funds which are managed separately by trustees appointed under bond indentures. This program enables the City to combine available cash from all funds and to invest cash that exceeds current needs. Under the City's Investment Policy and in accordance with the Government Code, the City may invest in the following types of investments subject to certain limitations on maturity and amount: U.S. Treasury Obligations, U.S. Agency Securities, Banker's Acceptances, Commercial Paper, Negotiable Certificates of Deposit, Repurchase Agreements, Reverse Repurchase Agreements, Medium-Term Notes, Time Certificates of Deposit, Money Market Mutual Funds, Mortgage Pass-Through Securities, County Pooled Investment Funds, Local Agency Investment Fund. As of August 31, 2011, the market value of the City Treasurer's investment portfolio was $50,081,087. The diversification of the City Treasurer's investment portfolio assets as of such date is shown in the following table. Type of Investment "A) of Combined Portfolio U.S. Government Agencies 32.2% Los Angeles County Investment Pool 38.7 Local Agency Investment Fund 29.1 100.0% The weighted average maturity of the investment portfolio was 819 days. The current yield of the investment portfolio at August 31, 2011 was 2.8%. 45 Indebtedness of the City The City had the following outstanding indebtedness as of June 30, 2011, exclusive of obligations to be paid from specifically pledged revenues, such as revenue bonds, tax allocation bonds and special tax bonds. Category of Indebtedness (1) 2002 Lease Revenue Bonds (2) 2003 Lease Revenue Bonds (3) 2004 Lease Revenue Bonds (4) 2005 Lease Revenue Bonds (5) 2006 Lease Revenue Bonds (6) Notes Payable (7) Capital Leases (8) Compensated Absences Original Obligation $21,895,000 3,625,000 13,500,000 2,735,000 18,005,000 2,741,000 3,050,000 Amount Outstanding $17,060,000 2,675,000 11,800,000 2,480,000 17,925,000 2,195,596 1,843,538 3,992,754 Final Maturity 2035 2023 2034 2034 2036 2023 2015 N/A (1)1(4) In 2002, the City entered into a lease agreement with the Authority to pay rental payments securing the Authority's Variable Rate Lease Revenue Bonds, 2002 Series A and B ("2002 Bonds"). Interest is payable at a variable rate of interest. In 2005, the City prepaid a portion of the lease agreement relating to the 2002 Bonds, Series A by entering into an amendment to the lease agreement. The rental payments now also secure the Authority's Variable Rate Lease Revenue Bonds, Series C. The annual lease payments, including credit fees, are estimated to be $720,000 in fiscal year 2011/12, based on an estimated interest rate of 0.32%. (2) In 2003, the City entered into a lease agreement with the Authority to pay rental payments securing the Authority's Lease Revenue Bonds, 2003 Series A. The annual lease payments are approximately $290,000. (3) The Lease. The annual lease payments, including credit fees, are estimated to be $465,000 in fiscal year 2011/12, based on an estimated interest rate of 0.49%. (5) In 2006, the City entered into a lease agreement with the Authority to pay rental payments securing the Authority's Variable Rate Lease Revenue Bonds, 2006 Series A and B. The annual lease payments are approximately $950,000 in Fiscal Year 2011/12, increasing to $1.4 million annually by 2023. (6) The City has entered into various notes payable for the acquisition of property. Annual payments in future years are approximately $210,000, after payment in full of one note in 2011/12 of $250,000. (7) The City has capitalized certain leases for equipment purchases. Annual lease payments are approximately $500,000. (8) Represents that portion of compensated absences not expected to be paid during the current year, as of June 30, 2010. 46 Direct and Overlapping Debt Set forth below is a direct and overlapping debt report (the "Debt Report") prepared by HdL Coren & Cone, as of June 30, 2011. The Debt Report is included for general information purposes only. The City has not reviewed the Debt report for completeness or accuracy and makes no representations in connection therewith. Any inquiries concerning the scope and methodology of procedures carried out to compile the information presented should be directed to HdL Coren & Cone, Diamond Bar, California. The Debt Report generally includes long-term obligations sold in the public credit markets by public agencies whose boundaries overlap the boundaries of the City in whole or in part. Such long-term obligations are not payable from the City's General Fund nor are they necessarily obligations secured by property within the City. In many cases, long-term obligations issued by a public agency are payable only from the general fund or other revenues of such public agency. TABLE NO. 16 CITY OF WEST COVINA DIRECT AND OVERLAPPING DEBT Gross Bonded °A Applicable Net Bonded Debt Balance To City Debt 6/30/2011 Direct Debt Revenue Lease Bonds & Capital Leases $119,854,497 100.000% $119,854,497 Total Direct Debt 119,854,497 Overlapping Debt Metropolitan Water District $107,259,876 0.773 829,425 Mt. San Antonio CCD DS 2001 S-A 1,130,000 12.849 145,196 Mt. San Antonio CCD 2001 Series 2004B 8,080,000 12.849 1,038,215 Mt. San Antonio CCD 2005 Refunding Bond 55,835,843 12.849 7,174,458 Mt. San Antonio CCD 2001, Series C 2006 79,461,712 12.849 10,210,193 Mt SAC CD DS 2001, 2008 Series D 24,602,430 12.849 3,161,215 Baldwin Park Unified DS 96 Series A 2,713,733 0.292 7,915 Baldwin Park USD 2001 Refunding Bonds 5,890,000 0.292 17,179 Baldwin Park USD 2002 Series 2003 375,000 0.292 1,094 Baldwin Park USD 2002 Series 2004 6,356,248 0.292 18,539 Baldwin Park USD 2005 Refunding Bonds 9,936,887 0.292 28,983 Baldwin Park USD 2002 Series 2005 4,813,699 0.292 14,040 Baldwin Park USD 2002 Series 2006 17,473,384 0.292 50,965 Baldwin Pk Unif DS 2006 Ser 2007 23,600,000 0.292 68,834 Baldwin Pk Unif DS 2006 Ser 2008 14,001,457 0.292 40,838 Bassett USD DS 2004 Series 2005 A 11,203,352 0.069 7,780 Bassett Unified DS 2004 Series 2005 B 10,616,192 0.069 7,372 Bassett Unif DS 2006 Ser 2007 14,139,566 0.069 9,819 Bassett Unif DS 2006 Ser B 4,999,970 0.069 3,472 (Continued on next page). Gross Bonded Debt Balance $ 14,775,000 21,135,713 45,010,000 17,359,117 2,724,899 8,290,987 29,790,000 55,280,000 2,514,562 39,899,075 15,400,173 42,400,000 32,422,549 12,000,000 27,987,385 13,465,000 23,247,718 255,000 13,715,243 6,001,837 11,420,000 25,580,000 6,950,887 8,030,000 15,340,000 8,465,000 ')/o Applicable To City 31.997 31.997 31.997 31.997 1.402 1.399 1.399 1.399 15.152 15.152 15.152 15.152 15.152 15.152 0.747 0.747 0.747 0.747 0.747 0.747 0.747 0.747 0.747 95.170 95.170 95.170 Net Bonded Debt 6/30/2011 $ 4,727,554 6,762,791 14,401,843 5,554,394 38,194 115,955 416,635 773,131 381,018 6,045,684 2,333,502 6,424,635 4,912,808 1,818,293 209,151 100,625 173,732 1,906 102,495 44,852 85,342 191,161 51,944 7,642,139 14,599,055 8,056 128 $108,800,498 $228,654,995 (Continued from previous page). Covina Valley USD DS 2001 Series B Covina Valley USD DS 2002 Series B Covina Valley USD DS 2006 Series 2006 Covina Valley Unif DS 2006, 2007 Ser B Hacienda-La Puente USD DS 2000 Series A Hacienda- La Puente USD DS 2000 S-03B Hacienda-La Puente Unified DS 2005 Refunding Bond Hacienda-La Puente Unified DS 2007 Refunding Rowland Heights USD DS 2000 Series A Rowland Heights USD DS 2000 Series B Rowland Heights Unified DS 2005 Ref. Bonds Rowland USD DS 2006 Series A Rowland Heights USD DS 2006 Series B Rowland Heights Unif UDS DS 2006 Series C BABS Walnut Valley Unified DS 2011 Walnut Valley Unified 2011 Refunding Bonds Walnut Valley Ref. DS Series 97 A Walnut Valley USD DS 2000 Series C Walnut Valley USD DS 2000 Series D Walnut Valley USD DS 2000 Series E Walnut Valley USD DS 2005 Ref. bond Walnut Val Unif DS 2007 Ser A (Measure 5) Walnut Val Unif DS 2007 Ser A (Measure Y) West Covina USD 2000 Series C West Covina USD 2002 Refunding Series A West Covina USD 2000 Series D Total Overlapping Debt Total Direct and Overlapping Debt 2010/11 Assessed Valuation: $6,567,105,460 After Deducting $1,985,533,437 Redevelopment Increment. Debt to Assessed Valuation Ratios: Direct Debt 1.83% Overlapping Debt 1.66% Total Debt 3.48% Source: HdL Coren & Cone, Diamond Bar, California 48 Financial Statements The City's accounting policies conform to generally accepted accounting principles and reporting standards set forth by the State Controller. The audited financial statements also conform to the principles and standards for public financial reporting established by the National Council of Government Accounting and the Governmental Accounting Standards Board. Basis of Accounting and Financial Statement Presentation. The government-wide financial statements are reported using the accrual basis of accounting. Revenues are recorded when earned and expenses are recorded when a liability is incurred, regardless of the timing of related cash flows. Property taxes are recognized as revenues in the year for which they are levied. Grants and similar items are recognized as revenue as soon as all eligibility requirements imposed by the provider have been met. Governmental fund financial statements are reported using the modified accrual basis of accounting. Revenues are recognized as soon as they are both measurable and available. Revenues are considered to be available when they are collectible within the current period or soon enough thereafter to pay liabilities of the current period. Expenditures generally are recorded when a liability is incurred, as under accrual accounting. However, debt service expenditures are recorded only when payment is due. The City retained the firm of Diehl Evans, & Company, LLP, Certified Public Accountants, Irvine, California, to examine the general purpose financial statements of the City as of and for the year ended June 30, 2010. The following tables summarize the Balance Sheet and Statement of Revenues, Expenditures and Changes in Fund Balance of the City's General Fund for the last five fiscal years. The City received a Certificate of Achievement for Excellence in Financial Reporting for the Fiscal Year ended June 30, 2010. See "APPENDIX B" hereto for the audited financial statements for the fiscal year ended June 30, 2010. The City has not requested, and the auditor has not provided, any review or update of such statements in connection with the inclusion in this Reoffering Memorandum. See Table No. 10 herein for a summary of estimated results for Fiscal Year 2010/11. TABLE NO. 17 CITY OF WEST COVINA GENERAL FUND BALANCE SHEET As of June 30 2006 2007 2008 2009 20 Assets Cash and investments Receivables, net: Accounts Taxes Interest Due from other funds Due from other governments Prepaids and other assets Advances to other funds Total assets 6,641,674 $12,693,469 $ 9,677,975 $ 7,133,437 $ 6,799,084 203,686 218,014 211,610 171,196 216,610 3,258,765 2,933,315 3,016,718 2,577,013 2,696,505 145,336 154,459 100,639 54,834 14,346 4,752,871 4,745,023 4,699,985 2,851,580 826,181 2,157,791 2,043,620 2,104,729 58,454 34,849 61,842 47,594 71,949 44,510 60,765 $42,461,44¢ Liabilities and Fund Balance Liabilities: Accounts payable Other accrued liabilities Deposits Deferred revenue Due to other funds Fund balance: Reserved for: Encumbrances Prepaids and other assets Advances to other funds Unreserved, reported in General fund Total fund balance 900,731 $ 752,959 $ 746,396 $ 665,597 $ 576,981 1,772,589 2,043,353 2,445,868 2,257,459 2,379,916 223,683 222,508 223,959 377,135 306,800 6,127,179 4,843,850 4,218,193 1,365,550 964,214 _ - - - 77,050 $ 9,024,182 $ 7,862,670 $ 7,634,416 $ 4,665,741 $ 4,304,961 280,933 453,272 373,894 - 61,842 47,594 71,949 44,510 24,611,809 24,292,809 23,359,648 22,576,490 23,982,187 19,315,808 16,021,539 12,846,323 9,710,686 $48,936,771 $44,109,483 $39,827,030 $35,467,323 $31,567,950 $57.960.953 $51.972.153 $47.461.446 $40,133,064 $35,872.911 36,142 60,765 21,760,357 Source: City of West Covina Financial Statements. TABLE NO. 18 CITY OF WEST COVINA GENERAL FUND STATEMENT OF REVENUES, EXPENDITURES AND CHANGES IN FUND BALANCE For the year ended June 30 2006 2007 2008 2009 2010 Revenues: Taxes Licenses and Permits Fines and Forfeitures Investment income Rental income Revenue from other agencies Charges for services Other revenues Total revenues $34,380,808 $37,020,080 $37,866,384 1,329,125 1,831,001 1,188,547 108,320 154,215 156,913 4,358,369 4,679,267 4502310 96,888 178,695 221864 2,855,483 1,041,918 791,144 3,195,003 2,836,597 2,971,886 241,268 221,880 178,948 46,565,264 47,963,653 47,877,996 $37,781,768 1,085,650 195,325 3,278,279 302,658 1,507,997 3,146,647 1,422,382 48,720 706 $35,118,020 904,985 201,339 3,063,036 288,319 1,349,097 3,285,523 739,518 44,949,837 Expenditures: Current: General government Less interfund revenues Public safety Public works Community services Community development Total expenditures Excess (deficiency) of revenues over (under) ) expenditures Other financing sources (uses): Loss on sale of property Transfers in Transfers out Total other financing sources (uses) Net change in fund balance Fund balance at beginning of year Fund balance at end of year 4,302,189 (1,881,624) 38,810,835 4,179,688 963,118 561,520 46,935,726 3,021,877 (1 430 000) 1,591,877 4,614,107 (3,069,508) 40,049,486 4,713,285 1,283,609 590,983 48,181,962 1,180,000 (5,788,979) (4,608,979) 5,047,965 (2,818,068) 43,362,282 5,099,806 1,260,286 616,900 52 569,171 1,324,998 (916,276) 408.722 4,647,495 (1,979,438) 43,214,194 5,229,300 915,840 499,571 52,526,962 1,957,412 (2,510,863) (553,451) 4,572,167 (1,610,642) 42,980,283 4,665,175 787,274 431,979 51,826,236 3,118,140 (141,114) 2,977,026 (370,462) (218,309) (4,691,175) (3,806,256) (6,876,399) 1,221,415 (4,827,288) (4,282,453) (4,359,707) (3,899,373) 47,715,356 48,936,771 44,109,483 39,827,030 35,467,323 $48 936 771 $44 109 483 $ 9 827 030 $35 467 323 $31,567,950 Source: City of West Covina Financial Statements. 51 RISK FACTORS The purchase of the Bonds involves investment risk. If a risk factor materializes to a sufficient degree, it could delay or prevent payment of principal of and/or interest on the Bonds. Such risk factors include, but are not limited to, the following matters and should be considered, along with other information in this Reoffering Memorandum, by potential investors. Base Rental City's Base Rental and Other Payments. The Base Rental and other payments due under the Lease (including a proportionate share of the costs of improvement, repair and maintenance of the Leased Property and taxes, other governmental charges and assessments levied against the Leased Property) are not secured by any pledge of taxes or other revenues of the City but are payable from yearly appropriations of any funds lawfully available to the City. In the event the City's revenue sources are less than its total obligations, the City could choose to fund other services before paying Base Rental and other payments due under the Lease. The same result could occur if, because of State Constitutional limits on expenditures, the City is not permitted to appropriate and spend all of its available revenues (see "Constitutional Limitations on Taxes and Expenditures" below). To the extent these types of events or other events adversely affecting the funds available to the City occur in any year, the funds available to pay Base Rental may be decreased. The City has the capacity to enter into other obligations, including additional base rental payments under the Lease, which may constitute additional charges against its revenues. To the extent that additional obligations are incurred by the City, the funds available to the City to pay Base Rental may be decreased (see "FINANCIAL INFORMATION - Indebtedness of the City" herein). Abatement. The amount of Base Rental due under the Lease will be adjusted or abated during any period in which by reason of damage or destruction to the Leased Property or eminent domain proceedings there is substantial interference with the use and possession of the Leased Property. Notwithstanding the provisions of the Lease and the Indenture specifying the extent of abatement in the event of the City's failure to have use and possession of the Leased Property, such provisions may be superseded by operation of law, and, in such event, the resulting Base Rental may not be sufficient to pay all of that portion of the remaining principal and interest represented by the Bonds. The amount of such abatement shall reduce the Base Rental applicable to the Bonds. Earthquake Risk. According to the City's General Plan, the City is located in a seismically active region and could be impacted by a major earthquake originating from numerous faults in the area. Of primary concern to the City are the Sierra Madre Fault, the San Andreas Fault and the Whittier Fault. According to the Safety Element of the City's General Plan, groundshaking is the most significant seismic hazard. Potential surface rupture in the City is not considered a significant seismic risk, since this occurs primarily along fault lines and none of the known fault lines lie within the City. This hazard could result in damage to the Leased Property, and possibly, abatement of all or a portion of Base Rental. The City does not currently and is not required to maintain earthquake insurance with respect to the Leased Property. It also does not maintain earthquake insurance on other City-owned facilities. Insurance. The Lease obligates the City to obtain and keep in force various forms of insurance, to assure repair or replacement of the Leased Property in the event of damage or destruction to the Leased Property (see "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - THE LEASE AGREEMENT - Insurance" herein). The City makes no representation as to the ability of any insurer to fulfill its obligations under any insurance policy provided for in the Lease. In addition, certain risks, such as earthquake, may not be covered by such property insurance (see "SOURCES OF PAYMENT FOR THE BONDS - Property Insurance" herein). In the event the Leased Property is partially or completely damaged or destroyed due to any uninsured or underinsured event, it is likely that Base Rental will be partially or completely abated. Apart from the proceeds of insurance, the City and the Authority will have no obligation to expend any funds to repair or replace such damaged or destroyed property. If any leased property so damaged or destroyed is not repaired or replaced within the period during which the proceeds of rental interruption insurance are available, any such abatement could prevent the City from timely paying Base Rental. Discovery of a Hazardous Substance That Would Limit the Beneficial Use of the Property. In general, the owners and lessees of a parcel may be required by law to remedy conditions of the property relating to the releases or threatened releases of hazardous substances. The federal Comprehensive Environmental Response, Compensation and Liability Act of 1980 sometimes referred to as CERCLA or the Superfund Act, is the most well known and widely applicable of these laws but California laws with regard to hazardous substances are also stringent and similar. Under many of these laws, the owner (or lessee) is obligated to remedy a hazardous substance condition of property whether or not the owner (or lessee) had any involvement in creating or handling the hazardous substance. The effect, therefore, should the Property be affected by a hazardous substance, might be to limit the beneficial use of the Property upon discovery and during remediation. The City is not aware of any such condition on the property. State Budget [to be completed] Future State Budgets Changes in the revenues received by the State can affect the amount of funding, if any, to be received from the State by the City and other cities and counties in the State. The City cannot predict the extent of the budgetary problems the State will encounter in this or in any future fiscal year, and, it is not clear what measures would be taken by the State to balance its budget, as required by law. In addition, the City cannot predict the final outcome of current or future State budget negotiations, the impact that such budgets will have on its finances and operations or what actions will be taken in the future by the State Legislature and Governor to deal with changing State revenues and expenditures. Current and future State budgets are being and will be affected by national and State economic conditions and other factors, including the current economic downturn, over which the City has no control. Accordingly, there can be no assurances that State actions to respond to State financial difficulties will not adversely affect the financial condition of the City, significantly reduce or delay revenues to local governments or shift financial responsibility for programs to local governments. Accordingly, no prediction can be made by the City as to what future measures the State will adopt to respond to the current or potential future financial difficulties. If an event of default occurs and is continuing under the Lease Agreement, there is no remedy of acceleration of any Lease Payments which have not come due and payable in accordance with the Lease. The City will continue to be liable for Lease Payments as they become due and payable in accordance with the Lease if the Trustee does not terminate the Lease, and the Trustee would be required to seek a separate judgment each year for that year's defaulted Lease Payments. Any such suit for money damages would be subject to limitations on legal remedies against counties in California, including a limitation on enforcement of judgments against funds or property needed to serve the public welfare and interest. In addition, the enforcement of any remedies provided in the Lease and the Indenture could prove both expensive and time-consuming. The Lease permits the Trustee to take possession of and re-lease the Property in the event of a default by the City under the Lease. However, due to the fact that the Leased Property serves essential governmental purposes, it is unlikely that a court would permit such remedy to be exercised. Even if such remedy may be exercised, due to the specialized nature of the Leased Property it is unlikely that the Trustee could readily re-lease it for rents which are sufficient to enable it to pay principal of and interest on the Bonds in full when due. Constitutional Limitation on Taxes and Expenditures State Initiative Measures Generally. Under the California Constitution, the power of initiative is reserved to the voters for the purpose of enacting statutes and constitutional amendments. Voters have exercised this power through the adoption of Proposition 13 ("Article XIIIA") and similar measures, the most recent of which were approved as Propositions 22 and 26 in the general election held on November 2, 2010. Any such initiative may affect the collection of fees, taxes and other types of revenue by local agencies such as the City. Subject to overriding federal constitutional principles, such collection may be materially and adversely affected by voter-approved initiatives, possibly to the extent of creating cash-flow problems in the payment of outstanding obligations such as the Lease. Article XIIIA. Article XII1A of the California Constitution limits the taxing powers of California public agencies. Article XIIIA provides that the maximum ad valorem tax on real property cannot exceed 1% of the "full cash value" of the property, and effectively prohibits the levying of any other ad valorem property tax except for taxes above that level required to pay debt service on voter-approved general obligation bonds. "Full cash value" is defined as "the County assessor's valuation of real property as shown on the 1975/76 tax bill under 'full cash value' or, thereafter, the appraised value of real property when purchased, newly constructed, or a change in ownership has occurred after the 1975 assessment." The "full cash value" is subject to annual adjustment to reflect inflation at a rate not to exceed 2% or a reduction in the consumer price index or comparable local data. Article XIIIA has subsequently been amended to permit reduction of the "full cash value" base in the event of declining property values caused by substantial damage, destruction or other factors, and to provide that there would be no increase in the "full cash value" base in the event of reconstruction of property damaged or destroyed in a disaster and in other special circumstances. There may also be declines in valuations if the California Consumer Price Index is negative. The foregoing limitation does not apply to ad valorem taxes or special assessments to pay the interest and redemption charges on any indebtedness approved by the voters before July 1, 1978 or any bonded indebtedness for the acquisition or improvement of real property approved by two-thirds of votes cast by the voters voting on the proposition. In the general election held November 4, 1986, voters of the State of California approved two measures, Propositions 58 and 60, which further amend the terms "purchase" and "change of ownership," for purposes of determining full cash value of property under Article XIIIA, to not include the purchase or transfer of (1) real property between spouses and (2) the principal residence and the first $1,000,000 of other property between parents and children. Proposition 60 amends Article XII1A to permit the Legislature to allow persons over age 55 who sell their residence and buy or build another of equal or lesser value within two years in the same city, to transfer the old residence's assessed value to the new residence. In the March 26, 1996 general election, voters approved Proposition 193, which extends the parents-children exception to the reappraisal of assessed value. Proposition 193 amended Article XIIIA so that grandparents may transfer to their grandchildren whose parents are deceased, their principal residences, and the first $1,000,000 of other property without a re-appraisal of assessed value. 54 Because the Revenue and Taxation Code does not distinguish between positive and negative changes in the California Consumer Price Index used for purposes of the inflation factor, there was a decrease of 0.237% in 2009/10 — applied to the 2010/11 tax roll — reflecting the actual change in the California Consumer Price Index, as reported by the State Department of Finance. For each fiscal year since Article XIIIA has become effective (the 1978/79 Fiscal Year), the annual increase for inflation has been at least 2% except in seven fiscal years as shown below: Tax Roll Percentage 1981/82 1.000% 1995/96 1.190 1996/97 1.110 1998/99 1.853 2004/05 1.867 2010/11 (0.237) 2011/12 0.753 Proposition 8 Adjustments. Proposition 8, approved in 1978, provides for the assessment of real property at the lesser of its originally determined (base year) full cash value compounded annually by the inflation factor, or its full cash value as of the lien date, taking into account reductions in value due to damage, destruction, obsolescence or other factors causing a decline in market value. Reductions based on Proposition 8 do not establish new base year values, and the property may be reassessed as of the following lien date up to the lower of the then-current fair market value or the factored base year value. The State Board of Equalization has approved this reassessment formula and such formula has been used by county assessors statewide. Article XIIIB. On November 6, 1979, California voters approved Proposition 4, or the Gann Initiative, which added Article XIIIB to the California Constitution. Article XIIIB limits the annual appropriations of the State and any city, county, city and county, school district, authority or other political subdivision of the State. The "base year" for establishing such appropriations limit is the 1978/79 Fiscal Year, and the limit is to be adjusted annually to reflect changes in population, consumer prices and certain increases in the cost of services provided by public agencies. Appropriations subject to Article XIIIB include generally the proceeds of taxes levied by or for the entity and the proceeds of certain State subventions, refunds of taxes, benefit payments from retirement, unemployment insurance and disability insurance funds. "Proceeds of taxes" include, but are not limited to, all tax revenues, certain State subventions, and the proceeds to an entity of government, from (1) regulatory licenses, user charges and user fees, to the extent that such charges and fees exceed the costs reasonably borne in providing the regulation, product or service, and (2) the investment of tax revenues. Article XIIIB includes a requirement that if an entity's revenues in any year exceed the amounts permitted to be spent, the excess would have to be returned by revising tax rates or fee schedules within the next two subsequent fiscal years. In the June 1990 election, the voters approved Proposition 111 amending the method of calculation of State and local appropriations limits. Proposition 111 made several changes to Article XIIIB. First, the term "change in the cost of living" was redefined as the change in the California per capita personal income ("CPCPI") for the preceding year. Previously, the lower of the CPCPI or the United States Consumer Price Index was used. Second, the appropriations limit for the fiscal year was recomputed by adjusting the 1986/87 limit by the CPCPI for the three subsequent years. Third and lastly, Proposition 111 excluded appropriations for "qualified capital outlay for fiscal 1990/91 as defined by the legislature" from proceeds of taxes. Section 7910 of the Government Code requires the City to adopt a formal appropriations limit for each fiscal year. The City's appropriations limit for 2011/12 is $ 110,790,424. The City's appropriations subject to the limit for 2011/12 are $ 36,052,346. Based on this, the appropriations limit is not expected to have any impact on the ability of the City to continue to budget and appropriate the Lease Payments as required by the Lease. Proposition 62. Proposition 62 was a statutory initiative adopted in the November 1986 general election. Proposition 62 added Sections 53720 to 53730, inclusive, to the California Government Code. It confirmed the distinction between a general tax and special tax, established by the State Supreme Court in 1982 in City and County of San Francisco v. Farrell, by defining a general tax as one imposed for general governmental purposes and a special tax as one imposed for specific purposes. Proposition 62 further provided that no local government or district may impose (i) a general tax without prior approval of the electorate by majority vote or (ii) a special tax without such prior approval by two-thirds vote. It further provided that if any such tax is imposed without such prior written approval, the amount thereof must be withheld from the levying entity's allocation of annual property taxes for each year that the tax is collected. By its terms, Proposition 62 applies only to general and special taxes imposed on or after August 1, 1985. Proposition 62 was generally upheld in Santa Clara County Local Transportation Authority v. Guardino, a California Supreme Court decision filed September 28, 1995. Proposition 218. On November 5, 1996, California voters approved Proposition 218 — Voter Approval for Local Government Taxes — Limitation on Fees, Assessments, and Charges — Initiative Constitutional Amendment. Proposition 218 added Articles XIIIC and XIIID to the California Constitution, imposing certain vote requirements and other limitations on the imposition of new or increased taxes, assessments and property-related fees and charges. Proposition 218 states that all taxes imposed by local governments shall be deemed to be either general taxes or special taxes. Special purpose districts, including school districts, have no power to levy general taxes. No local government may impose, extend or increase any general tax unless and until such tax is submitted to the electorate and approved by a majority vote. No local government may impose, extend or increase any special tax unless and until such tax is submitted to the electorate and approved by a two-thirds vote. Proposition 218 also provides that no tax, assessment, fee or charge shall be assessed by any agency upon any parcel of property or upon any person as an incident of property ownership except: (i) the ad valorem property tax imposed pursuant to Article XIII and Article XIIIA of the California Constitution, (ii) any special tax receiving a two-thirds vote pursuant to Section 4 of Article XIIIA the California Constitution, and (iii) assessments, fees, and charges for property related services as provided in Article XIIID. Proposition 218 added voter requirements for assessments and fees and charges imposed as an incident of property ownership, other than fees and charges for sewer, water, and refuse collection services. In addition, all assessments and fees and charges imposed as an incident of property ownership, including sewer, water, and refuse collection services, are subjected to various additional procedures, such as hearings and stricter and more individualized benefit requirements and findings. The effect of such provisions will presumably be to increase the difficulty a local agency will have in imposing, increasing or extending such assessments, fees and charges. Proposition 218 also extended the initiative power to reducing or repealing any local taxes, assessments, fees and charges. This extension of the initiative power is not limited to taxes imposed on or after November 6, 1996, the effective date of Proposition 218, and could result in retroactive repeal or reduction in any existing taxes, assessments, fees and charges, subject to overriding federal constitutional principles relating to the impairment of contracts. Proposition 218 provides that, effective July 1, 1997, fees that are charged "as an incident of property ownership" may not "exceed the funds required to provide the property related services" and may only be charged for services that are "immediately available to the owner of the property." 56 Proposition 1A. Proposition IA ("Proposition 1A"), proposed by the Legislature in connection with the 2004/05 Budget Act and approved by the voters in November 2004, restricts State authority to reduce major local tax revenues such as the tax shifts permitted to take place in Fiscal Years 2004/05 and 2005/06. Proposition 1 A provides that the State may not reduce any local sales tax rate, limit existing local government authority to levy a sales tax rate or change the allocation of local sales tax revenues, subject to certain exceptions. Proposition IA generally prohibits the State from shifting to schools or community colleges any share of property tax revenues allocated to local governments for any fiscal year, as set forth under the laws in effect as of November 3, 2004. Any change in the allocation of property tax revenues among local governments within a county must be approved by two-thirds of both houses of the Legislature. Proposition IA provides, however, that beginning in Fiscal Year 2008/09, the State may shift to schools and community colleges up to 8% of local government property tax revenues, which amount must be repaid, with interest, within three years, if the Governor proclaims that the shift is needed due to a severe state financial hardship, the shift is approved by two-thirds of both houses and certain other conditions are met. Such a shift may not occur more than twice in any ten-year period. The State may also approve voluntary exchanges of local sales tax and property tax revenues among local governments within a county. For Fiscal Year 2009/10, $1,722,830 of the City's property tax revenues were diverted to the State as a result of a Proposition 1A suspension. The City participated in a Proposition I A Securitization Program (the "Program") sponsored by the California Statewide Communities Development Authority. The Program allowed the City to exchange its anticipated State property tax receivable for cash. Proposition 1 A also provides that if the State reduces the vehicle license fee ("VLF") rate currently in effect, 0.65% of vehicle value, the State must provide local governments with equal replacement revenues. Further, Proposition 1A requires the State to suspend State mandates affecting cities, counties and special districts, excepting mandates relating to employee rights, schools or community colleges, in any year that the State does not fully reimburse local governments for their costs to comply with such mandates. Proposition 22. On November 2, 2010, voters in the State approved Proposition 22. Proposition 22, known as the "Local Taxpayer, Public Safety, and Transportation Protection Act of 2010," eliminates or reduces the State's authority to (i) temporarily shift property taxes from cities, counties and special districts to schools, (ii) use vehicle license fee revenues to reimburse local governments for State- mandated costs (the State will have to use other revenues to reimburse local governments), (iii) redirect property tax increment from redevelopment agencies to any other local government, (iv) use State fuel tax revenues to pay debt service on State transportation bonds, or (v) borrow or change the distribution of State fuel tax revenues. Proposition 26. On November 2, 2010, voters in the State also approved Proposition 26. Proposition 26 amends Article XIIIC of the State Constitution to expand the definition of "tax" to include "any levy, charge, or exaction of any kind imposed by a local government" except the following: (1) a charge imposed for a specific benefit conferred or privilege granted directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of conferring the benefit or granting the privilege; (2) a charge imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product; (3) a charge imposed for the reasonable regulatory costs to a local government for issuing licenses and permits, performing investigations, inspections, and audits, enforcing agricultural marketing orders, and the administrative enforcement and adjudication thereof; (4) a charge imposed for entrance to or use of local government property, or the purchase, rental, or lease of local government property; (5) a fine, penalty, or other monetary charge imposed by the judicial branch of government or a local government, as a result of a violation of law; (6) a charge imposed as a condition of property development; and (7) assessments and property-related fees imposed in accordance with the provisions of Article XIIID. Proposition 26 provides that the local government bears the burden of proving by a preponderance of the evidence that a levy, charge, or other exaction is not a tax, that the amount is no more than necessary to cover the reasonable costs of the governmental activity, and that the manner in which those costs are allocated to a payor bear a fair or reasonable relationship to the payor's burdens on, or benefits received from, the governmental activity. The City does not expect the provisions of Proposition 26 to materially impede its ability to pay Lease Payments when due. Future Initiatives. From time to time other initiative measures could be adopted, affecting the ability of the City to increase revenues and appropriations. Early Redemption Risk Early redemption of the Base Rental and redemption of the Bonds may occur in whole or in part without premium, on any Bond Payment Date if the Leased Property or a portion thereof is lost, destroyed or damaged beyond repair or taken by eminent domain and from the proceeds of title insurance, or on any Bond Payment Date, without a premium (see "THE BONDS - Special Mandatory Redemption From Net Proceeds"), if the City exercises its right to prepay Base Rental in whole or in part pursuant to the provisions of the Lease and the Indenture. Further, the Bonds are subject to mandatory tender on the Fixed Rate Conversion Date, in the event the interest portion of the Credit Facility is not reinstated following a draw thereon, in an event of default under the Reimbursement Agreement, upon expiration of the Credit Facility, or upon delivery of an Alternate Credit Facility (see "APPENDIX A - SUMMARY OF THE LEGAL DOCUMENTS - THE INDENTURE - Substitution of the Credit Facility" and "THE BONDS - Tender and Purchase of Bonds" herein). Loss of Tax Exemption As discussed under the caption "LEGAL MATTERS - Tax Matters" herein, interest on the Bonds could become includable in gross income for purposes of federal income taxation retroactive to the date the Bonds were issued as a result of future acts or omissions of the City or the Authority in violation of their covenants contained in the Indenture and the Lease. Should such an event of taxability occur, the Bonds are not subject to special redemption or any increase in interest rate and will remain outstanding until maturity or until prepaid under one of the redemption provisions contained in the Indenture. IRS Audit of Tax-Exempt Bond Issues The Internal Revenue Service has initiated an expanded program for the auditing of tax-exempt bond issues, including both random and targeted audits. It is possible that the Bonds will be selected for audit by the Internal Revenue Service. It is also possible that the market value of the Bonds might be affected as a result of such an audit of the Bonds (or by an audit of similar bonds). LEGAL MATTERS Enforceability of Remedies The remedies available to the Trustee and the Owners of the Bonds upon an event of default under the Indenture, the Lease or any other document described herein are in many respects dependent upon regulatory and judicial actions which are often subject to discretion and delay. Under existing law and judicial decisions, the remedies provided for under such documents may not be readily available or may be limited. The various legal opinions delivered concurrently with the delivery of the Bonds and to be delivered by Bond Counsel and bank Counsel on the date of the delivery of the Credit Facility are qualified to the extent that the enforceability of certain legal rights related to the Indenture, the Lease and the Credit Facility are subject to limitations imposed by bankruptcy, reorganization, insolvency or other similar laws affecting the rights of creditors generally and by equitable remedies and proceedings generally. Approval of Legal Proceedings Certain legal matters will be passed on for the City by Alvarez-Glasman & Colvin, West Covina, California, as City Attorney and by Fulbright & Jaworski L.L.P., Los Angeles, California, as Disclosure Counsel and for the Credit Facility by Karl Christiansen, Senior Counsel of Wells Fargo Bank, National Association and by its Counsel, Kathleen C. Johnson, Esq. Attorney at Law. Tax Matters Original Opinion On August 19, 2004, Fulbright & Jaworski L.L.P., in connection with the issuance of the Bonds, delivered its opinion to the effect that, based upon an analysis of then existing statutes, regulations, rulings and judicial decisions, and assuming, among other matters, compliance with certain covenants and requirements, interest on the Bonds is excluded from gross income for federal income tax purposes, and is not an item of tax preference for purposes of federal individual or corporate alternative minimum tax, but such interest may be included in the calculation of corporation alternative minimum taxable income, and such interest is exempt from State of California personal income taxes. A complete copy of the opinion of Fulbright & Jaworski L.L.P. delivered at the original issuance of the Bonds is set forth in "APPENDIX D" hereto. No Updated Opinion of Fulbright & Jaworski L.L.P. Fulbright & Jaworski L.L.P. has not taken, and does not intend to take, any action to update its original opinion or to determine if the interest on the Bonds is presently excluded from gross income for federal income tax purposes or exempt from State of California personal income taxes. Opinion of Bond Counsel Fulbright & Jaworski L.L.P., Los Angeles, California, Bond Counsel, will deliver its opinion that the delivery of the Credit Facility will not, in and of itself, result in the inclusion of the interest on the Bonds in gross income for purposes of federal income taxation. Bond Counsel expresses no opinion as to whether the interest on the Bonds is currently excluded from gross income for federal income tax purposes. The opinion of Bond Counsel to be delivered in connection with the remarketing of the Bonds is set forth in "APPENDIX D" hereto. 59 General Considerations Notwithstanding the foregoing, investors should be aware of the following information. The Code imposes various restrictions, conditions and requirements relating to the exclusion from gross income for federal income tax purposes of interest on obligations such as the interest on the Bonds. The Authority and the City have made certain representations and covenanted to comply with certain restrictions, conditions and requirements designed to ensure that the interest on the Bonds will not be included in federal gross income. Inaccuracy of these representations or failure to comply with these covenants may result in the interest on the Bonds being included in gross income for federal income tax purposes, possibly from the date of original issuance of the Bonds. The opinion of Fulbright & Jaworski L.L.P. delivered in connection with the initial execution and delivery of the Bonds assumed the accuracy of these representations and compliance with these covenants. Fulbright & Jaworski L.L.P. has not undertaken to determine (or to inform any person) whether any actions taken (or not taken), or events occurring (or not occurring), or any other matters coming to its attention after the date of issuance of the Bonds may adversely affect the value of, or the tax status of interest with respect to, the Bonds. Accordingly, the opinion of Fulbright & Jaworski L.L.P. delivered in connection with the initial issuance of the Bonds is not intended to, and may not, be relied upon in connection with any such actions, events or matters. Although Fulbright & Jaworski L.L.P. has rendered an opinion that interest on the Bonds is excluded from gross income for federal income tax purposes and is exempt from State of California personal income taxes, the ownership or disposition of, or the accrual or receipt of interest with respect to, the Bonds may otherwise affect a Beneficial Owner's federal, state or local tax liability. The nature and extent of these other tax consequences depends upon the particular tax status of the Beneficial Owner or the Beneficial Owner's other items of income or deduction. Fulbright & Jaworski L.L.P. expresses no opinion regarding any such other tax consequences. Future legislative proposals, if enacted into law, clarification of the Code or court decisions may cause the interest on the Bonds to be subject, directly or indirectly, to federal income taxation or to be subject to or exempted from state income taxation, or otherwise prevent Beneficial Owners from realizing the full current benefit of the tax status of such interest. The introduction or enactment of any such future legislative proposals, clarification of the Code or court decisions may also affect the market price for, or marketability of, the Bonds. Prospective purchasers of the remarketed Bonds should consult their own tax advisors regarding any pending or proposed federal or state tax legislation, regulations or litigation, as to which Fulbright & Jaworski L.L.P. expresses an opinion. The opinion of Fulbright & Jaworski L.L.P. delivered in connection with the initial execution and delivery of the Bonds was based on current legal authority existing as of August 19, 2004, covered certain matters not directly addressed by such authorities, and represented its judgment as to the proper treatment of the Bonds for federal income tax purposes. It is not binding on the Internal Revenue Service ("IRS") or the courts. Furthermore, Fulbright & Jaworski L.L.P. cannot give and has not given any opinion or assurance about the future activities of the Authority or the City, or about the effect of future changes in the Code, the applicable regulations, the interpretation thereof or the enforcement thereof by the IRS. The Authority and the City have covenanted, however, to comply with the requirements of the Code. Fulbright & Jaworski L.L.P.'s engagement with respect to the issuance of the Bonds ended on August 19, 2004 with the original issuance of the Bonds. Bond Counsel's engagement with respect to the Bonds will end on the date its opinion is delivered to the Trustee. Unless separately engaged, Fulbright & Jaworski L.L.P. is obligated to defend the Authority, the City or the Beneficial Owners regarding the tax-exempt status of the interest on the Bonds in the event of an audit examination by the IRS. Under current procedures, parties other than the Authority and the City and their appointed counsel, including the Beneficial Owners, would have little, if any, right to participate in the audit examination process. Moreover, because achieving judicial review in connection with an audit examination of tax-exempt bonds is difficult, obtaining an independent review of IRS positions with which the City legitimately disagrees, may not be practicable. Any action of the IRS, including but not limited to selection of the Bonds for audit, or the course or result of such audit, or an audit of bonds presenting similar tax issues may affect the market price for, or the marketability of, the Bonds and may cause the Authority or the Beneficial Owners to incur significant expense. Litigation There is no action, suit or proceeding known by the Authority or the City to be pending or threatened, restraining or enjoining the Authority or the City in the execution or delivery of any documents related to the delivery of the Credit Facility and the remarketing of the Bonds, or in any way contesting or affecting the validity of, the Bonds. There is no litigation known to be pending, or to the knowledge of the Authority and the City, threatened, questioning the existence of the Authority or the City or the title of the officers of the Authority or the City to their respective offices. There exist lawsuits and claims against the City, which are incidental to the ordinary course of operations of the City. In the view of the City's management and of the City Attorney, there is no litigation, present or pending, which will individually or in the aggregate materially impair the City's ability to service its indebtedness or which will have a material adverse effect on the business operations of the City. CONCLUDING INFORMATION Rating on the Bonds In connection with the remarketing of the Bonds, as described in this Reoffering Memorandum, it is expected that Standard & Poor's Ratings Services ("S&P") will assign the Bonds the rating of" 17 1 with the understanding that the Credit Facility will be issued by the Credit Entity on November 30, 2011. The rating should be evaluated independently of any other ratings of the City. No application has been made to any other rating agency in order to obtain additional ratings on the Bonds. The credit enhanced ratings on the Bonds reflect S&P' current assessment of the creditworthiness of the Credit Entity and its ability to pay draws under the Credit Facility. Any further explanation as to the significance of the above ratings may be obtained from S&P. The above described ratings are not recommendations to buy, sell or hold the Bonds, and such rating may be subject to revision or withdrawal at any time by S&P. Neither the City, the Authority nor the Remarketing Agent undertake any responsibility either to bring to the attention of the owners of the Bonds the downward revision or withdrawal of any rating obtained or to oppose any such revision or withdrawal. Any downward revision or withdrawal of a rating may have an adverse effect on the market price of the Bonds. Remarketing Agent Wells Fargo Securities serves as Remarketing Agent for the Bonds. The Remarketing Agent will carry out the duties and obligations provided for the Remarketing Agent under and in accordance with the provisions of the Trust Agreement and the Remarketing Agreement, by and between the Authority and the Remarketing Agent, dated as of October 20, 2011. Wells Fargo Securities is the trade name for certain capital markets and investment banking services of Wells Fargo & Company and its subsidiaries, including Wells Fargo Bank, National Association. The principal office of the Remarketing Agent (for purposes of its responsibilities as Remarketing Agent) is 301 S College Street, Charlotte, North Carolina 28202. The Financial Advisor The material contained in this Reoffering Memorandum was prepared by the Authority with the assistance of the Financial Advisor, who advised the Authority and the City as to the financial structure and certain other financial matters relating to the Bonds. The information set forth herein has been obtained from sources, which are believed to be reliable, but such information is not guaranteed by the Financial Advisor as to accuracy or completeness, nor has it been independently verified. Fees paid to the Financial Advisor are contingent upon the sale and delivery of the Bonds. Continuing Disclosure The City has covenanted to provide annually certain financial information and operating data relating to the City by not later than March 31 each year commencing March 31, 2012, to provide the audited Financial Statements of the City for the Fiscal Year ending June 30, 2011 and for each subsequent Fiscal Year when they are available (together, the "Annual Report"), and to provide notices of the occurrence of certain other enumerated events. The Annual Report will be filed by the City on the Electronic Municipal Market Access Website ("EMMA") operated by the Municipal Securities Rulemaking Board (www.emma.msrb.org). The specific nature of the information to be contained in the Annual Report or the notices of listed events and certain other terms of the continuing disclosure obligation are summarized in "APPENDIX C - FORM OF CONTINUING DISCLOSURE AGREEMENT." These covenants will be made in order to assist the Underwriter in complying with Rule 15c2-12 of the Securities Exchange Act of 1934 (the "Rule"). Additional Information The summaries and references contained herein with respect to the Indenture, the Lease, the Bonds, statutes and other documents, do not purport to be comprehensive or definitive and are qualified by reference to each such document or statute and references to the Bonds are qualified in their entirety by reference to the form hereof included in the Indenture. Copies of the Indenture and the Lease may be obtained from the Authority through the Executive Director, 1444 West Garvey Avenue, West Covina, California 91790. References Any statements in this Reoffering Memorandum involving matters of opinion, whether or not expressly so stated, are intended as such and not as representations of fact. Execution The execution of this Reoffering Memorandum by the Treasurer has been duly authorized by the West Covina Public Financing Authority. WEST COVINA PUBLIC FINANCING AUTHORITY By: Treasurer APPENDIX A SUMMARY OF THE LEGAL DOCUMENTS [to be provided by Bond Counsel] A-1 APPENDIX B CITY AUDITED FINANCIAL STATEMENTS APPENDIX C FORM OF CONTINUING DISCLOSURE AGREEMENT APPENDIX D OPINIONS OF COUNSEL [to be provided by Bond Counsel] APPENDIX E DTC AND THE BOOK-ENTRY-ONLY SYSTEM The following description of the Depository Trust Company ("DTC'), the procedures and record keeping with respect to beneficial ownership interests in the Bonds, payment of principal, interest and other payments on the Bonds to DTC Participants or Beneficial Owners, confirmation and transfer of beneficial ownership interest in the Bonds and other related transactions by and between DTC, the DTC Participants and the Beneficial Owners is based solely on information provided by DTC. Accordingly, no representations can be made concerning these matters and neither the DTC Participants nor the Beneficial Owners should rely on the foregoing information with respect to such matters, but should instead confirm the same with DTC or the DTC Participants, as the case may be. Neither the issuer of the Bonds (the "Issuer') nor the trustee, fiscal agent or paying agent appointed with respect to the Bonds (the "Agent') take any responsibility for the information contained in this Appendix. No assurances can be given that DTC, DTC Participants or Indirect Participants will distribute to the Beneficial Owners (a) payments of interest, principal or premium, if any, with respect to the Bonds, (b) certificates representing ownership interest in or other confirmation or ownership interest in the Bonds, or (c) redemption or other notices sent to DTC or Cede & Co., its nominee, as the registered owner of the Bonds, or that they will so do on a timely basis, or that DTC, DTC Participants or DTC Indirect Participants will act in the manner described in this Appendix. The current "Rules" applicable to DTC are on file with the Securities and Exchange Commission and the current "Procedures" of DTC to be followed in dealing with DTC Participants are on file with DTC. 1. The Depository Trust Company ("DTC"), New York, NY, will act as securities depository for the Bonds (the "Securities"). The Securities will be issued as fully-registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully-registered Security certificate will be issued for each issue of the Securities, each in the aggregate principal amount of such issue, and will be deposited with DTC. If, however, the aggregate principal amount of any issue exceeds $500 million, one certificate will be issued with respect to each $500 million of principal amount, and an additional certificate will be issued with respect to any remaining principal amount of such issue. 2. DTC, the world's largest securities depository, is a limited-purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC's participants ("Direct Participants") deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book- entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-US. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). DTC has a Standard & Poor's rating of AA+. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com . The information contained on these Internet sites is not incorporated herein by reference. 3. Purchases of Securities under the DTC system must be made by or through Direct Participants, which will receive a credit for the Securities on DTC's records. The ownership interest of each actual purchaser of each Security ("Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Securities are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in Securities, except in the event that use of the book-entry system for the Securities is discontinued. 4. To facilitate subsequent transfers, all Securities deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of Securities with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Securities; DTC's records reflect only the identity of the Direct Participants to whose accounts such Securities are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. 5. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of Securities may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Securities, such as redemptions, tenders, defaults, and proposed amendments to the Security documents. For example, Beneficial Owners of Securities may wish to ascertain that the nominee holding the Securities for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of notices be provided directly to them. 6. Redemption notices shall be sent to DTC. If less than all of the Securities within an issue are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. 7. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Securities unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to Issuer as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts Securities are credited on the record date (identified in a listing attached to the Omnibus Proxy). 8. Redemption proceeds and distributions on the Securities will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detail information from Issuer or Agent, on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of such Participant and not of DTC, Agent, or Issuer, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of redemption proceeds, distributions, and dividend payments to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of Issuer or Agent, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants. 9. DTC may discontinue providing its services as depository with respect to the Securities at any time by giving reasonable notice to Issuer or Agent. Under such circumstances, in the event that a successor depository is not obtained, Security certificates are required to be printed and delivered. 10. Issuer may decide to discontinue use of the system of book-entry-only transfers through DTC (or a successor securities depository). In that event, Security certificates will be printed and delivered to DTC. 11. The information in this section concerning DTC and DTC's book-entry system has been obtained from sources that Issuer believes to be reliable, but Issuer takes no responsibility for the accuracy thereof. E-3 APPENDIX F FORM OF IRREVOCABLE LETTER OF CREDIT