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Tab_102I, the undersigned officer of the City and Borough of Juneau, Alaska (the "City and Borough"), make this certification for the benefit of all persons interested in the exclusion from gross income for federal income tax purposes of the interest to be paid on the City and Borough's General Obligation Bond, 2016 (the "General Purpose Bond"), and General Obligation School Refunding Bond, 2016 (the "School Refunding Bond," and together with the General Purpose Bond, the "Bonds") which are being issued in the principal amount of $2,635,000 and $17,575,000, respectively, and delivered simultaneously with the delivery of this certificate. In part pursuant to Section 1.148-2(b)(2) of the Regulations (defined below), I do hereby certify as follows in good faith on the date of issue of the Bonds: 1. Responsible Officer. I am the duly chosen, qualified and acting officer of the City and Borough for the office shown below my signature; as such, I am familiar with the facts herein certified and I am duly authorized to execute and deliver this certificate on behalf of the City and Borough. I am the officer of the City and Borough charged, along with other officers of the City and Borough, with responsibility for issuing the Bonds. 2. Code and Regulations. For purposes of this certificate, the "Code" means the Internal Revenue Code of 1986, as amended, and the "Regulations" means the Treasury Regulations promulgated thereunder. 3. Definitions. The capitalized terms used in this certificate (unless otherwise defined) that are defined in the Ordinance Serial No. 2012-44, authorizing the issuance of the General Purpose Bond and Ordinance Serial No. 2016-31, authoring the issuance of the School Refunding Bond (together, the "Bond Ordinances") shall for all purposes hereof have the meanings therein specified. All terms defined in the Code or Regulations shall for all purposes of this certificate have the same meanings as given to those terms in the Code and Regulations unless the context clearly requires otherwise. 4. Reasonable Expectations. The facts and estimates that are set forth in this certificate are accurate. The expectations that are set forth in this certificate are reasonable in light of such facts and estimates. There are no other facts or estimates that would materially change such expectations. In connection with this certificate, the undersigned has to the extent necessary reviewed the certifications set forth herein with other representatives of the City and Borough as to such accuracy and reasonableness. The undersigned is aware of no fact, estimate or circumstance that would create any doubt regarding the accuracy or reasonableness of all or any portion of such documents. 5. Description of Governmental Purpose. The City and Borough is issuing the Bonds pursuant to the Bond Ordinances (a) to provide funds that will be used to refund currently and redeem the entire outstanding principal amount of the City and Borough's General Obligation School Bonds, 2006B in the aggregate principal amount of $18,560,000 (the "Refunded Bonds"), (b) to provide funds that will be used to finance renovations to the Capital Transit maintenance shop (the "New Money Project"), and (c) to pay the costs of issuance of the Bonds. 6. The Refunded Bonds. (a) General. No portion of the purchase price of the Refunded Bonds represents a loan made from the proceeds of another tax-exempt obligation. All of the original and investment proceeds allocable to the Refunded Bonds have been expended. In addition, other than to the extent of preliminary expenditures (i.e., architectural, engineering, surveying, soil testing, reimbursement bond issuance, and similar costs that are incurred prior to commencement of acquisition, construction, or rehabilitation of a project, other than land acquisition, site preparation, and similar costs incident to commencement of construction), no portion of the proceeds of the Refunded Bonds was used to reimburse the City and Borough for any expenditures made by the City and Borough prior to the issuance date of the Refunded Bonds or 60 days prior to the date that the City and Borough adopted a declaration of intent to reimburse itself from proceeds of the Refunded Bonds. (b) No Working Capital. Except for an amount that did not exceed five percent of the sale proceeds of the Refunded Bonds (and that was directly related to capital expenditures financed by the Refunded Bonds), the City and Borough only expended proceeds of the Refunded Bonds for (i) costs that would be chargeable to a capital account if the City and Borough's income were subject to federal tax purposes and (ii) interest on the Refunded Bonds in an amount that is attributable to the period that commenced on the date the Refunded Bonds were issued and ended on the later of (A) the date that was three years from the issue date of the Refunded Bonds or (B) the date that was one year after the date on which the projects financed by the Refunded Bonds were placed in service, and (iii) issuance costs of the Refunded Bonds. 7. Expenditure of Proceeds of the Bonds. The City and Borough sold the Bonds to the Alaska Municipal Bond Bank (the "Bond Bank"), for $21,858,034.05. Such amount represents the stated redemption price at maturity of the Bonds of $20,210,000.00, plus original issue premium of $1,648,034.05. The Bond Bank purchased the Bonds from proceeds of its General Obligation and Refunding Bonds, 2016 Series Three (the "Bond Bank's Bonds"). The sale proceeds will be expended as follows: (a) The sale proceeds will be expended as follows: (i) The amount of $18,755,988.00 will be deposited in the escrow fund established pursuant to the Escrow Agreement (the "Escrow Fund") and used on the date hereof to purchase United States Treasury Certificates of Indebtedness and Notes, State and Local Government Series (the "Escrowed Securities"), the proceeds of which will be used to pay the principal of, and interest and redemption premium, if any, on, the Refunded Bonds. No portion of the proceeds of the Bonds is expected to be used to pay any interest on, or principal of, any issue of governmental obligations other than the Bonds and the Refunded Bonds. (ii) The amount of $52,298.62 will be allocated to the underwriter's discount or compensation. (iii) The amount of $31,083.49 will be disbursed to pay other costs of issuance of the Bonds. -2- (iv) The amount of $4,853.42 will be deposited in the Bond Fund as a rounding amount and disbursed to pay interest on the Bonds on the first debt service date. (v) The amount of $13,800.25 will be allocated on the date of issuance of the Bonds to the payment of premium for a surety policy on the Bond Banks Bonds. (vi) The amount of $3,000,000.00 will be deposited in the Construction Funds and used to pay the costs of the New Money Project. The aggregate amount of the costs of acquisition and construction of the New Money Project is anticipated to be not less than such amount. Any costs of the New Money Project not financed out of original or investment proceeds of the Bonds will be financed out of the City and Borough's available funds. (vii) The amount of $10.27 will be deposited as the initial cash balance in the Escrow Fund and used to pay debt service on the Refunded Bonds. (b) Reimbursement. Other than to the extent of preliminary expenditures (i.e., architectural, engineering, surveying, soil testing, Bond issuance, and similar costs that are incurred prior to commencement of acquisition, construction, or rehabilitation of the New Money Project, other than land acquisition, site preparation, and similar costs incident to commencement of construction) not in excess of 20% of the issue price of the General Purpose Bond, no portion of the amounts described in paragraph 7(a)(vi) above will be disbursed to reimburse the City and Borough for any expenditures made by the City and Borough prior to the date that is 60 days before the earlier of the date hereof or the date the City and Borough adopted a Bond Ordinance (the "Declaration"), if any, describing the New Money Project, stating the maximum principal amount of obligations expected to be issued for the New Money Project, and stating the City and Borough's reasonable expectation on that date that it would reimburse expenditures for costs of the New Money Project with proceeds of an obligation. The Declaration, if any, is not an official intent to reimburse that was declared as a matter of course, or in an amount substantially in excess of the amount expected to be necessary for the New Money Project. The City and Borough has not engaged in a pattern of failure to reimburse original expenditures covered by declarations of official intent. Such reimbursed portion will be treated as spent for purposes of paragraphs 13(b) and 17 below on the date an allocation is made in writing that evidences the City and Borough's use of the proceeds for original expenditure (provided, however, that an allocation made within 30 days of the date of issue may be treated as made on the date of issue). (c) No Working Capital. Except for an amount that does not exceed five percent of the sale proceeds of the General Purpose Bond (and that is directly related to capital expenditures financed by the General Purpose Bond), the City and Borough will only expend proceeds of the General Purpose Bond for (i) costs that would be chargeable to a capital account if the City and Borough's income were subject to federal income taxation and (ii) interest on the General Purpose Bond in an amount that does not exceed that amount of interest on the General Purpose Bond that is attributable to the period that commences on the date hereof and ends on the later of (A) the date that is three years from the issue date of the Bonds or (B) the date that is one year after the date on which the New Money Project is placed in service. 8. Pre-issuance Accrued Interest. The Bonds are dated as of the initial date of delivery to the Bond Bank, and the City and Borough will receive no pre-issuance accrued interest on the Bonds. 9. Investment Proceeds. The best estimate of the City and Borough is that investment proceeds resulting from the investment of any proceeds of the Bonds pending expenditure of such proceeds for costs of the New Money Project will be retained in the Construction Funds and disbursed to pay or reimburse New Money Project costs in addition to those described in paragraph 7 above. 10. Transferred Proceeds. There are no transferred proceeds with respect to the Bonds because all of the proceeds of the Refunded Bonds have been or will be expended prior to the first dates on which amounts are disbursed to pay principal of the Refunded Bonds. 11. No Replacement Proceeds. Other than amounts in the Bond Fund, there are no amounts that have a sufficiently direct nexus to the Bonds or to the governmental purposes of the Bonds, including the expected use of amounts to pay debt service on the Refunded Bonds, that the amounts would have been used for such purpose if the proceeds of the Bonds were not used or to be used for such purpose. (a) No Sinking Funds. Other than to the extent described herein, there is no debt service fund, redemption fund, reserve fund, replacement fund, or similar fund reasonably expected to be used directly or indirectly to pay principal or interest on the Bonds. (b) No Pledged Funds. Other than amounts described herein, there is no amount that is directly or indirectly, other than solely by reason of the mere availability or preliminary earmarking, pledged to pay principal or interest on the Bonds, or to a guarantor of part or all of the Bonds, such that such pledge provides reasonable assurance that such amount will be available to pay principal or interest on the Bonds if the City and Borough encounters financial difficulty. For purposes of this certification, an amount is treated as so pledged if it is held under an agreement to maintain the amount at a particular level for the direct or indirect benefit of the holders or the guarantor of the Bonds. (c) No Other Replacement Proceeds. There are no other replacement proceeds allocable to the Bonds because the City and Borough reasonably expects that the term of the Bonds will not be longer than is reasonably necessary for the governmental purposes of the Bonds. Furthermore, if the term of the Bonds is longer than is reasonably necessary for the governmental purposes of the Bonds, the City and Borough does not reasonably expect to have available amounts during the portion of such period that is longer than is reasonably necessary. The Bonds would be issued to achieve a debt service savings independent of any arbitrage benefit as evidenced by the expectation that the Bonds reasonably would have been issued if the interest on the Bonds were included in gross income (assuming that the hypothetical taxable interest rate would be the same as the actual tax-exempt interest rate). (d) Weighted Average Maturity, The weighted average maturity of the School Refunding Bond is not greater than 120 percent of the weighted average estimated economic life of the portion of the projects financed by the Refunded Bonds (the "Prior El Projects"), and the weighted average maturity of the General Purpose Bond is not greater than 120 percent of the weighted average estimated economic life of the New Money Project, in each case determined in accordance with section 147(b) of the Code. Such weighted average estimated economic life is determined in accordance with the following assumptions: (a) the weighted average was determined by taking into account the respective costs of each of the assets financed or refinanced by the Bonds; (b) the reasonably expected economic life of an asset was determined as of the later of the date hereof or the date on which such asset is expected to be placed in service (i.e., available for use for the intended purposes of such asset); (c) the economic lives used in making this determination are not greater than the useful lives used for depreciation under section 167 of the Code prior to the enactment of the current system of depreciation in effect under section 168 of the Code (i.e., the "mid-point lives") under the asset depreciation range ("ADR") system of section 167(m) of the Code, as set forth in Revenue Procedure 83-3 5, 1983-1 C.B. 745, where applicable, and the "guideline lives" under Revenue Procedure 62-21, 1962-2 C.B. 418, in the case of structures; and (d) land or any interest therein has not been taken into account in determining the average reasonably expected economic life of such project, unless 25 percent or more of the net proceeds of any issue is to be used to finance land. 12. Yield on the Bonds. The Bonds were purchased by the Bond Bank from proceeds of the Bond Bank's Bonds. The yield on the Bond Bank's Bonds is 2.598457%, based on schedules provided to the Bond Bank by the underwriter for the Bond Bank's Bonds, as set forth in Exhibit A. Pursuant to Treas. Reg. § 1.148-4(a), the yield on the Bond is equal to the yield on the Bond Bank's Bonds. 13. Temporary Periods and Yield Restriction. (a) Current Refunding. The amount described in paragraph 7(a)(i) will be used within 90 days of the date hereof to pay principal of and interest on the Refunded Bonds. Therefore, such amount may be invested for an allowable temporary period. (b) New Money Project. The City and Borough has incurred or will incur within six months of the date hereof a binding obligation to a third party which is not subject to any contingencies within the control of the City and Borough or a related party pursuant to which the City and Borough is obligated to expend at least five percent of the sale proceeds of the General Purpose Bond on the New Money Project. The City and Borough reasonably expects that work on or acquisition of the New Money Project will proceed with due diligence to completion and that the proceeds of the General Purpose Bond will be expended on the New Money Project with reasonable dispatch. The City and Borough reasonably expects that 85 percent of the sale proceeds of the General Purpose Bond will have been expended on the New Money Project prior to three years from the date hereof. Accordingly, the City and Borough may invest the sale proceeds of the General Purpose Bond at an unrestricted yield for a three year temporary period. Any original proceeds not expended prior to three years from the date hereof, will be invested at a yield not "materially higher" than the yield on the Bonds, except as set forth in paragraph 15 below. The City and Borough reasonably expects that any amount derived from the investment of sale proceeds of the General Purpose Bond and from the investment of such investment income will not be commingled with substantial other receipts or revenues of the City and Borough and will be expended prior to three years from the date hereof, or one year after receipt of such investment income, whichever is later. Accordingly, the City and Borough may invest such investment proceeds at an unrestricted yield. Any such investment proceeds not expended prior to such date will be invested at a yield not "materially higher" than the yield on the Bonds, except as set forth in paragraph 15 below. For purposes of this certificate, "materially higher" shall have the meaning set forth in section 1.1 48-2(d)(2) of the Regulations. 14. Debt Service Fund. Pursuant to the Bond Ordinances, the City and Borough has created or continued, as the case may be, a debt service fund (the "Bond Fund") and the proceeds from all taxes levied, assessed and collected for and on account of the Bond are to be deposited in such Bond Fund. The City and Borough expects that taxes levied, assessed and collected for and on account of the Bond will be sufficient each year to pay such debt service. The Bond Fund will be used primarily to achieve a proper matching of revenues and principal and interest payments on the Bond within each bond year. Amounts deposited in the Bond Fund will be depleted at least once each bond year, except for a reasonable carryover amount not in excess of the greater of the earnings on the Bond Fund for the immediately preceding bond year or one- twelfth of the principal and interest payments on the Bond for the immediately preceding bond year. Amounts held in the Bond Fund may be invested at an unrestricted yield because such amounts will be expended within 13 months of the date such amounts are received. 15. Minor Portion. All gross proceeds will be invested in accordance with paragraphs 13 and 14 above. To the extent such amounts remain on hand following the periods set forth in paragraphs 13 and 14 above or exceed the limits set forth in paragraph 14 above, the City and Borough will invest such amounts at a restricted yield as set forth in such paragraphs; provided, however, that a portion of such amounts, not to exceed in the aggregate the lesser of $100,000 or five percent of the sale proceeds of the Bonds, may be invested at a yield which is higher than the yield on the Bonds. 16. Issue. There are no other obligations which (a) have been or will be sold within 15 days of the Bonds, (b) are sold pursuant to the same plan of financing with the Bonds, and (c) will be paid out of substantially the same source of funds as the Bonds. 17. Compliance With Rebate Requirements. The City and Borough has covenanted in the Bond Ordinances that it will take all necessary steps to comply with the requirement that rebatable arbitrage earnings on the investment of the gross proceeds of the Bonds, within the meaning of section 148(f) of the Code be rebated to the federal government. Specifically, the City and Borough will (a) maintain records regarding the investment of the gross proceeds of the Bonds as may be required to calculate such rebatable arbitrage earnings separately from records of amounts on deposit in the funds and accounts of the City and Borough which are allocable to other bond issues of the City and Borough or moneys which do not represent gross proceeds of any bonds of the City and Borough, (b) calculate at such intervals as may be required by applicable Regulations, the amount of rebatable arbitrage earnings, if any, earned from the investment of the gross proceeds of the Bonds and (c) pay, not less often than 60 days after every fifth anniversary date of the delivery of the Bonds and within 60 days following the final maturity of the Bonds, or on such other dates required or permitted by applicable Regulations, all amounts required to be rebated to the federal government. Further, the City and Borough will not indirectly pay any amount otherwise payable to the federal government pursuant to the foregoing requirements to any person other than the federal government by entering into any investment arrangement with respect to the gross proceeds of the Bonds that might result in a in reduction in the amount required to be paid to the federal government because such arrangement results in a smaller profit or a larger loss than would have resulted if the arrangement had been at ann' s-length and had the yield on the issue not been relevant to either party. The City and Borough hereby covenants to pay any rebate due on the Refunded Bonds within 60 days after the date the Refunded Bonds are retired. 18. Not an Abusive Transaction. (a) General. No action taken in connection with the issuance of the Bonds is or will have the effect of (a) enabling the City and Borough to exploit, other than during an allowable temporary period, the difference between tax-exempt and taxable interest rates to obtain a material financial advantage (including as a result of an investment of any portion of the gross proceeds of the Bonds over any period of time, notwithstanding that, in the aggregate, the gross proceeds of the Bonds are not invested in higher yielding investments over the term of the Bonds), and (b) overburdening the tax-exempt bond market by issuing more bonds, issuing bonds earlier, or allowing bonds to remain outstanding longer than is otherwise reasonably necessary to accomplish the governmental purposes of the Bonds, based on all the facts and circumstances. Specifically, (i) the primary purpose of each transaction undertaken in connection with the issuance of the Bonds is a bona fide governmental purpose; (ii) each action taken in connection with the issuance of the Bonds would reasonably be taken to accomplish the governmental purposes of the Bonds if the interest on the Bonds were not excludable from gross income for federal income tax purposes (assuming the hypothetical taxable interest rate would be the same as the actual tax-exempt interest rate on the Bonds); (iii) the proceeds of the Bonds will not exceed by more than a minor portion the amount necessary to accomplish the governmental purposes of the Bonds and will in fact not be substantially in excess of the amount of proceeds allocated to expenditures for the governmental purposes of the Bonds. (b) No Re-refunding. No portion of the Refunded Bonds has been refunded or defeased other than by reason of the issuance of the Bonds. (c) No Sinking Fund. No portion of the Bonds has a term that has been lengthened primarily for the purpose of creating a sinking fund or similar fund with respect to the Bonds and thereby eliminating significant amounts of negative arbitrage in the Escrow Fund. (d) No Noncallable Bonds. The Refunded Bonds does not include any noncallable Refunded Bonds that have been refunded in order to invest proceeds in the Escrow Fund allocable to the noncallable Refunded Bonds at a yield that is higher than the yield on the Bonds and thereby eliminate significant amounts of negative arbitrage in the Escrow Fund. (e) No Window Refunding. No portion of the Bonds has been structured with maturity dates the primary purpose of which is to make available released revenues that will enable the City and Borough to avoid transferred proceeds or to make available revenues that may be invested to be ultimately used to pay debt service on another issue of obligations. -7- (f) No Sale of Conduit Loan. No portion of the gross proceeds of the Refunded Bonds or the Bonds has been or will be used to acquire, finance, or refinance any conduit loan to any party. 19. No Arbitrage. On the basis of the foregoing facts, estimates and circumstances, it is expected that the gross proceeds of the Bonds will not be used in a manner that would cause any of the Bonds to be an "arbitrage bond" within the meaning of section 148 of the Code and the Regulations. To the best of the knowledge and belief of the undersigned, there are no other facts, estimates or circumstances that would materially change such expectations. 20. No Private Use, Payments or Loan Financing. (a) General. The City and Borough reasonably expects, as of the date hereof, that no action or event during the entire stated term of the Bonds will cause either the "private business use test," the "private security or payment test" or the "private loan financing test," as such terms are defined in the Regulations, to be met. Specifically, (i) Not more than 10 percent of the proceeds of the Bonds will be used and no portion of the proceeds of the Refunded Bonds has been used in a trade or business of a nongovernmental person. For purposes of determining use, the City and Borough will apply rules set forth in applicable Regulations and Revenue Procedures promulgated by the Internal Revenue Service, including, among others, the following rules: (A) any activity carried on by a person other than a natural person or a state or local governmental unit will be treated as a trade or business of a nongovernmental person; (B) the use of all or any portion of the New Money Project or the project financed by the Refunded Bonds (the "Projects") is treated as the direct use of proceeds; (C) a nongovernmental person will be treated as a private business user of proceeds of the Bonds or the Refunded Bonds as a result of ownership, actual or beneficial use of the proceeds pursuant to a lease, or a management or incentive payment contract, or certain other arrangements such as a take-or-pay or other output-type contract; and (D) a nongovernmental person will be treated as a private business user of the proceeds of the Bonds if the person has special legal entitlements to use directly or indirectly the Projects. (ii) The City and Borough has not taken and will not take any deliberate action that would cause or permit the use of any portion of the Projects to change such that such portion will be deemed to be used in the trade or business of a nongovernmental person for so long as any of the Bonds remains outstanding (or until an opinion of nationally recognized bond counsel is received to the effect that such change in use will not adversely affect the excludability from gross income for federal income tax purposes of interest payable on the Bonds). For this purpose any action within the control of the City and Borough is treated as a deliberate action. A deliberate action occurs on the date the City and Borough enters into a binding contract with a nongovernmental person for use of the Projects that is not subject to any material contingencies. 10 (iii) All payments of the debt service on the Bonds will be paid from and secured by a generally applicable tax. For this purpose, a generally applicable tax is a tax (A) which is an enforced contribution exacted pursuant to legislation adopted by the City and Borough Assembly in the exercise of its taxing power and that is imposed and collected for the purpose of raising revenue to be used for governmental purposes and (B) which has a uniform tax rate that is applied to all persons of the same classification in the appropriate jurisdiction using a generally applicable manner of determination and collection. No portion of the payment of the debt service on the Bonds will be directly or indirectly derived from payments (whether or not to the City and Borough or any related party) in respect of property, or borrowed money, used or to be used for a private business use. Furthermore, no portion of the payment of the debt service on the Bonds will be directly or indirectly secured by any interest in property used or to be used for a private business use or payments in respect of property used or to be used for a private business use. (iv) No portion of the proceeds of the Bonds will be directly or indirectly used to make or finance a loan to any person other than a state or local governmental unit. (b) Dispositions of Personal Property in the Ordinary Course. The City and Borough does not reasonably expect that it will sell or otherwise dispose of personal property components of the Project financed or refinanced with the Bonds other than in the ordinary course of an established governmental program that satisfies the following requirements: (i) The weighted average maturity of the portion of the Bonds financing personal property is not greater than 120 percent of the reasonably expected actual use of such personal property for governmental purposes; (ii) The reasonably expected fair market value of such personal property on the date of disposition will be not greater than 25 percent of its cost; (iii) Such personal property will no longer be suitable for its governmental purposes on the date of disposition; and (iv) The City and Borough is required to deposit amounts received from such disposition in a commingled fund with substantial tax or other governmental revenues and the City and Borough reasonably expects to spend such amounts on governmental programs within 6 months from the date of commingling. (c) Other Agreements. The City and Borough will not enter into any agreement with any nongovernmental person regarding the use of all or any portion of the Project during the stated term of the Bonds unless such agreement will not adversely affect the treatment of interest on the Bonds as excludable from gross income for federal income tax purposes. 21. Weighted Average Maturity. The weighted average maturity of the Bonds is the sum of the products of the issue price of each group of identical Bonds and the number of years In to maturity (determined separately for each group of identical Bonds and taking into account mandatory redemptions), divided by the aggregate sale proceeds of the Bonds. 22. Federal Guarantee Prohibition. The Bonds are not "federally guaranteed" and the City and Borough will not cause or allow the Bonds to become "federally guaranteed". Unless otherwise excepted under section 149(b) of the Code, the Bonds will be considered federally guaranteed if: (a) The payment of principal or interest with respect to the Bonds is guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof); (b) 5 percent or more of the proceeds of the Bonds are to be: (i) used in making loans the payment of principal or interest with respect to which are to be guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof), or (ii) invested (directly or indirectly) in federally insured deposits or accounts; or (c) The payment of principal or interest on the Bonds is otherwise indirectly guaranteed (in whole or in part) by the United States (or an agency or instrumentality thereof). The federal guarantee prohibition shall not apply to (i) proceeds of the issue invested for an initial temporary period until such proceeds are needed for the purpose for which such issue was issued, (ii) investments of a bona fide debt service fund, (iii) investments of a reasonably required reserve fund, (iv) investments in bonds issued by the United States Treasury, or (v) other investments permitted under Regulations. 23. Bonds are not Hedge Bonds. The Bonds are not hedge bonds because not more than 50 percent of the proceeds of the General Purpose Bond will be invested in nonpurpose investments (as defined in section 148(f)(6)(A) of the Code) having a substantially guaranteed yield for four years or more within the meaning of section 1 49(g)(3)(A)(ii) of the Code, and the City and Borough reasonably expects that at least 85 percent of the spendable proceeds of the new money portion of the Bonds will be used to carry out the governmental purposes of the Bonds within the three-year period beginning on the date the Bonds are issued. Furthermore, the City and Borough represents that not more than 50 percent of the proceeds of the Refunded Bonds are a part of was invested in nonpurpose investments (as defined in section 1 48(f)(6)(A) of the Code) having a substantially guaranteed yield for four years or more within the meaning of section 1 49(g)(3 )(A)(ii) of the Code, and the City and Borough reasonably expected at the time of issue of the Refunded Bonds that at least 85 percent of the spendable proceeds of such issue would be used to carry out the governmental purposes of such issue within the three-year period beginning on the date of issue of the Refunded Bonds. EXECUTION PAGE FOLLOWS -10- SIGNATURE PAGE TO FEDERAL TAX CERTIFICATE CITY ANDiBOROUGHtOF JUI aXS$ By: Title: Finance Director Date: November 3, 2016 500069020 vi -11- i :i :110 [Attach here copies of the appropriate schedules prepared for the Bond Bank by RBC Capital Markets.] Iml Oct 28, 2016 3:19 pm Prepared by RBC Capital Markets Page 1 FORM 8038 STATISTICS City and Borough of Juneau Alaska Municipal Bond Bank GO Bonds 2016 Series Three & Four Pricing Results -- October 18, 2016 Dated Date 11/03/2016 Delivery Date 11/03/2016 Redemption Bond Component Date Principal Coupon Price Issue Price at Maturity 2016-3 Serial Bonds (Non-AMT) (Unin) (Non-Call): 12/01/2017 3,450,000,00 2.000% 100.982 3,483,879.00 3,450,000.00 12/01/2018 3,580,000.00 4.000% 105.516 3,777,472,80 3,580,000.00 12/01/2019 3,715,000.00 4,000% 107.679 4,000,274.85 3,715,000.00 12/01/2020 3,800,000.00 4,000% 109,561 4,163,318.00 3,800,000.00 12/01/2021 4,205,000.00 4.000% 111.194 4,675,707.70 4,205,000,00 12/01/2022 265,000,00 5.000% 118.216 313,272.40 265,000,00 12/01/2023 280,000.00 5.000% 119,414 334,359.20 280,000.00 12/01/2024 290,000.00 5.000% 120,452 349,310.80 290,000.00 12/01/2025 305,000,00 5,000% 121.274 369,885.70 305,000,00 12/01/2026 320,000.00 5.000% 122.048 390,553.60 320,000.00 20,210,000.00 21,858,034.05 20,210,000.00 Stated Weighted Maturity Interest Issue Redemption Average Date Rate Price at Maturity Maturity Yield Final Maturity 12/01/2026 5.000% 390,553.60 320,000.00 Entire Issue 21,858,034,05 20,210,000,00 3.6152 2.5985% Proceeds used for accrued interest 0.00 Proceeds used for bond issuance costs (including underwriters discount) 83,38211 Proceeds used for credit enhancement 13,800,25 Proceeds allocated to reasonably required reserve or replacement fund 0,00 Proceeds used to currently refund prior issues 18,755,998.27 Proceeds used to advance refund prior issues 0.00 Remaining weighted average maturity of the bonds to be currently refunded 2.9207 Remaining weighted average maturity of the bonds to be advance refunded 0,0000 Oct 28, 2016 3:19 pm Prepared by RBC Capital Markets Page 2 FORM 8038 STATISTICS City and Borough of Juneau Alaska Municipal Bond Bank GO Bonds 2016 Series Three & Four Pricing Results -- October 18, 2016 Refunded Bonds Bond Component Date Principal Coupon Price Issue Price CBJ 2006B Thunder Mountain School Bonds: SER 09/01/2017 3,385,000.00 4.000% 100.160 3,390,416.00 SER 09/01/2018 3,545,000.00 4.100% 100.402 3,559,250.90 SER 09/01/2019 3,680,000.00 4.125% 100,199 3,687,323,20 SER 09/01/2020 3,770,000.00 4.125% 99,421 3,748,171.70 SER 09/01/2021 4,180,000.00 4.250% 99.450 4,157,010.00 18,560,000.00 18,542,171,80 Remaining Last Weighted Call Issue Average Date Date Maturity CBJ 2006B Thunder Mountain School Bonds 12/05/2016 09/27/2006 2.9207 All Refunded Issues 12/05/2016 2.9207