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HomeMy WebLinkAboutOB 1 WTR SYS PURC 04-05-93OLD BUSINESS NO. 1 4-5-93 AGENDA DATE: MARCH 30, 1993 Inter -Com TO: WILLIAM A. HUSTON, CITY MANAGER FROM: RONALD A. NAULT, DIRECTOR OF FINANCE SUBJECT: ADOPT CITY OF TUSTIN RESOLUTION NO. PURCHASE AND OTHER RELATED ACTIONS RECOMMENDATION: 93-30 WATER SYSTEM Adopt City of Tustin Resolution No. 93-30 approving a Trust Agreement, Installment Purchase Agreement and Escrow Agreement; accepting a bid for the purchase of its $11,500,000 Water System Revenue Certification of Participation, 1993 Series; rejecting all other bids; approving the form of the Official Statement; and taking certain related actions. DISCUSSION: This is the last step in the bond issue process, accepting the bids and approving the documents in their new final form. Bids will be opened on the morning of April 5 at the City's Bond Counsel offices of Mudge Rose. The Bond Counsel and Financial Advisors will bring the bids and an award recommendation to the City Council meeting that evening. The actual bond closing will take place April 21 at the Mudge Rose offices in Los Angeles. As of the date of this staff report, the bonds of other agencies rated "A"+ have been sold at between 5.5 and 6.00 percent. We have received an "A" rating from Standard and Poor's and expect a similar rating from Moody's. The final documents will be forwarded for signatures before the closing date after all parties, including underwriters counsel, has had one last opportunity to make final changes that would be considered immaterial to documents as they appear at this time. �AM.'C.1 Ronald A. Nault Director of Finance RAN:ls wpurchase.wtr a 3 5 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 2i 2( Z 2E CITY OF TUSTIN RESOLUTION NO. 93-30 RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA, APPROVING A TRUST AGREEMENT, INSTALLMENT PURCHASE AGREEMENT AND ESCROW AGREEMENT, ACCEPTING A HID FOR THE PURCHASE OF ITS $11,500,000 WATER SYSTEM REVENUE CERTIFICATES OF PARTICIPATION, 1993 SERIES; REJECTING ALL OTHER SIDS; APPROVING THE FORM OF THE OFFICIAL STATEMENT; AND TARING CERTAIN RELATED ACTION WHEREAS, the City of Tustin (the "City") is a municipal corporation organized and existing under the Constitution and laws of the State of California; and WHEREAS, the City of Tustin Water Corporation (the "Corporation") is a nonprofit public benefit corporation organized and existing under the laws of the State of California with the authority to assist the City in the financing of costs related to, among other things, public improvements; and WHEREAS, the City has proposed that the Corporation assist the City in the financing of the acquisition of the water system currently owned by the Corporation (the "Project"); and WHEREAS, it has been proposed that. the Corporation sell the Project and that the City purchase such Project from the Corporation pursuant to an Installment Purchase Agreement, dated as of April 1, 1993, by and between the City and the Corporation (the "Installment Purchase Agreement"), the proposed form of which has been presented to this City Council, pursuant to which the City will agree to make certain purchase payments (the "Purchase Payments") in connection therewith; and WHEREAS, it has been proposed that the Corporation grant, assign and transfer all of its right to receive the Purchase Payments from the City to Bank of America National Trust and Savings Association, as Trustee (the "Trustee") pursuant to an Assignment Agreement, dated as of April 1, 1993, by and between the Corporation and the Trustee (the "Assignment Agreement"); and WHEREAS, the Corporation and the City have determined that it would be in the best interests of the Corporation, the City and the citizens of the City to authorize, pursuant to the Trust Agreement, dated as of April 1, 1993, by and among the Corporation, the Trustee and the City (the "Trust Agreement"), the proposed form of which has been presented to this City Council, the preparation, c\ 1080\1'miin\Ax-arNnldoc 3 5 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2E 2/ 2E execution, sale and delivery of Water System Revenue Certificates of Participation, 1993 Series, in an aggregate principal amount of $11,500,000 (the "Certificates"), which Certificates evidence and represent direct and proportionate interests in the Principal Components and Interest Components of the Purchase Payments; and WHEREAS, the City has determined that use of a portion of the proceeds of the Certificates to refund bonds issued in 1983 relating to the Project mill result in significant savings to the City; and WHEREAS, there has been presented to this City Council a proposed form of Escrow Agreement, dated as of April 1, 1993, among the City, the Corporation and the Trustee (the "Escrow Agreement"); and WHEREAS, this City Council, in compliance with all requirements of law has heretofore adopted, on March 1, 1993, Resolution No. 93-19 (the "Proposal Resolution"), entitled: "Resolution of the City Council of the City of Tustin, California Authorizing the Invitation of Proposals for the Purchase of Nct to Exceed $12,000,000 aggregate Principal Amount of Certificates of Participation of Said City; Approving the Notice Inviting Bids and the Notice of Intention to Sell Certificates; and Authorizing the Delivery of the Preliminary Official Statement and the Publication of the Notice of Intention to Sell Certificates and the Notice Inviting Bids"; and WHEREAS, the City has determined that it is in the best interest of the City and the citizens of the City to approve the above documents and authorize and approve the transactions contemplated thereby; and WHEREAS, this City Council deems it necessary to sell at this time the Certificates as authorized by the Proposal Resolution and this Resolution. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA, DOES HEREBY RESOLVE, DETERMINE AND ORDER as follows: Section 1: Approval of Documents. That the Trust Agreement, the Installment Purchase Agreement and the Escrow Agreement presented to this City Council are hereby approved. The Mayor, the City Manager, the Finance Director and the City Clerk are authorized and directed for and in the name of the City to execute and deliver -,said agreements. The agreements shall be executed. in the forms hereby approved, with such additions thereto and changes therein as are recommended or approved by Co -Special Counsel to the City and approved by such Officers or any such c\IObO\l'mnn\.\wadlr.7 J,w 5 0 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Officer, such approval to be conclusively evidenced by the execution and delivery thereof. Section 2. Appointment of Trustee. That Bank of America National Trust and Savings Association is hereby appointed as Trustee on behalf of the owners of the Certificates with the duties and powers of such Trustee as set forth in the Trust Agreement (as executed and delivered). Section 3. Compliance with Conditions Precedent. All steps required to be taken precedent to the authorization, issuance and sale of the Certificates have been duly and regularly taken as provided by law. Section 4. Notice of Intention to Sell Certificates and Notice Inviting Bids. The Notice of Intention to Sell Certificates (as approved by the City Council in the Proposal Resolution) was published as required by law and the Notice Inviting Bids was published as required by the Proposal Resolution. Pursuant to the Notice Inviting Bids and the Notice of Intention to Sell Certificates, proposals have been received, opened, read and examined. Section 5. Successful Bidder. The proposal for the purchase of the Certificates attached hereto and marked Exhibit A, and by this reference incorporated herein, is the best bid for the Certificates. Such proposal is hereby accepted in accordance with the terms thereof, and in accordance with and subject to the Proposal Resolution. Section 6. All Other Proposals Rejected. All proposals other than the one accepted pursuant to Section 5 hereof are rejected. Section 7. Interest Rates on the Certificates. The Certificates shall bear interest at the interest rates as set forth in the accepted proposal. Section S. Purchase Price for the Certificates. The Certificates shall be delivered to the successful bidder upon payment of the purchase price determined pursuant to the accepted proposal and the Notice Inviting Bids, plus accrued interest from April 1, 1993 to the date of delivery of the certificates. Section 9. Ratification. All actions and proceedings heretofore taken in connection with the authorization, issuance and sale of the Certificates are hereby ratified and confirmed. Section So. Official Statement Approved. A final Official Statement (the "final Official Statement") in substantially the form of the Preliminary Official Statement, with r.\10m\'r.m..\A,u,Rc 34, 1 2 3 4 5 6 7 8 9 101 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2E 2i 2E such changes thereto as are necessary to reflect the actual terms of the Certificates and such other changes as the Finance Director or the City Clerk shall approve, is hereby approved, and the City Council hereby approves the use of the final Official Statement by the successful bidder in connection with the offering and sale of the Certificates, and the City Council hereby further approves the use by the successful bidder of any supplement or amendment to the final official Statement which is necessary so that the final Official Statement does not include any untrue statement of a material fact and does not omit to state a material fact necessary to make the statements therein not misleading. Section 11. official Statement Furnished. The Finance Director and the Financial Advisor to the City for the issuance of the Certificates are hereby authorized and directed to cause to be furnished to the successful bidder a reasonable number of copies of the Official Statement. Section 12. General Authorization. The City Clerk, the Finance Director and all authorized officers, deputy officers or employees, consultants and counsel, are hereby authorized to do all acts and things necessary or desirable in carrying out the financing contemplated by the Trust Agreement, the Installment Purchase Agreement, the Escrow Agreement, the Proposal Resolution and this Resolution. Section 13. Effective Date. This Resolution shall take effect upon its adoption. (SEAL) ATTEST: ADOPTED, SIGNED AND APPROVED this 5th day of April, 1993. City Clerk 1:\100,"1'uq ,\Aua11k 13 J,.: 4 Mayor CLERK STATE OF CALIFORNIA ) COUNTY OF ORANGE ) ss. CITY OF TUSTIN ) I, Mary Wynn, City Clerk of the City of Tustin, do hereby certify that the ,foregoing Resolution No. 93-30 was introduced and adopted at a regular meeting provided by law, of the City Council of the City of Tustin held on the 5th day of April, 1993 by the following vote of the members thereof: AYES: COUNCIL MEMBERS: NOES: COUNCIL MEMBERS: ABSENT: COUNCIL MEMBERS: AND I FURTHER certify that the Mayor of the City of Tustin signed said Resolution No. 93-30 on the 5th day of April, 1993. IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of the City of Tustin this 5th day of April, 1993. CITY CLERK OF THE CITY OF TUSTIN (SEAL) I, Mary Wynn, City Clerk of the City of Tustin, do hereby certify that the foregoing is the original of Resolution No. 93-30 duly passed and adopted by the Tustin City Council on April 5, 1993. CITY CLERK OF THE CITY OF TUSTIN TRUST AGREEMENT by and among CITY OF TUSTIN WATER CORPORATION and BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION as Trustee and THE CITY OF TUSTIN Dated as of April 1, 1993 TABLE OF CONTENTS TITLE Page ARTICLE I ARTICLE III CERTIFICATESp TERMS AND PROVISIONS DEFINITIONS AND EXHIBITS SECTION SECTION 1.01. Definitions . . . . . . . . . . . . . . . 1 SECTION 1.02. Exhibit . . . . . . . . . . . . . . . 10 Distribution of Trust Estate . . . . . . . . 11 ARTICLE II 3.03. The 1993 Certificates . . . . . . . . . . 12 DECLARATION OF TRUST . . . . . . . . . 10 SECTION 2.01. Declaration of Trust by Trustee . . . . . 10 SECTION 2.02. Deposit of Moneys . .. . . . . 10 SECTION 2.03. Conditions Precedent Satisfied . . . . it ARTICLE III ARTICLE IV PREPAYMENT OF 1993 CERTIFICATES SECTION CERTIFICATESp TERMS AND PROVISIONS Prepayment . . . . . . . SECTION 3.01. Preparation of 1993 Certificates . . . . . 11 SECTION 3.02. Payments from Trust Estate Only; . . . . . . . . . . . . . . 19 Distribution of Trust Estate . . . . . . . . 11 SECTION 3.03. The 1993 Certificates . . . . . . . . . . 12 SECTION 3.05. Execution . . . . . . . . . . . . . . . . 13 SECTION 3.06. Exchange . . . . . . . . . . . . . 14 SECTION 3.07. Negotiability, Transfer and Registry . . . 14 SECTION 3.08. Certificate Registration Books . . . 15 SECTION 3.09. Regulations with Respect to Exchanges and Transfers . . . . . . . . . 15 SECTION 3.10. Certificates Mutilated, Destroyed, Stolen or Lost . . .. . . . . . . 15 SECTION 3.11. Temporary Certificates . . . . . . 16 SECTION 3.12. Cancellation of Certificates . . . . . . . 16 SECTION 3.13. Book -Entry Format . . . . . . . . . . . . 16 ARTICLE IV PREPAYMENT OF 1993 CERTIFICATES SECTION 4.01. Prepayment . . . . . . . 19 SECTION 4.02. Selection of Certificates for Prepayment . . . . . . . . . . . . . . 19 SECTION 4.03. Notice of Prepayment . . . . . . . . . . 19 SECTION 4.04. Payment of Certificates Upon Prepayment . 20 SECTION 4.05. Partial Prepayment of Certificates . . . 21 SECTION 4.06. Effect of Prepayment . . . . . . . . . . 21 B:\TRSTAGR6.DDC 1 ARTICLE V ESTABLISHMENT AND ADMINISTRATION OF CERTAIN FUNDS AND ACCOUNTS SECTION 5.01. Establishment of Project Trust Fund . . . 21 SECTION 5.03. Reserve Account . . . . . . . . . . . . . 23 SECTION 5.04. Construction Account . . . . . . . . . . . 24 SECTION 5.05. Deposits of Money . . . . . . . . . . . . 26 SECTION 5.06. Valuation and Sale of Investments . . . . 26 SECTION 5.07.. Investment of Certain Accounts . . . . . . 27 ARTICLE VI DEFEASANCE SECTION 7.01. Certificates Deemed Paid; Discharge of Trust Agreement . . . . . . . . . . . . . 35 SECTION 7.02. Application of Trust Money . . . . . . . . 36 ARTICLE VIII SECTION 8.01. Mailing . . . . . . . . . . . . 36 SECTION 8.02. Powers of Amendment . . . . . . . . . . 36 SECTION 8.04. Exclusion of Certificates . . . . . . . . 39 B:\TRSTAGR6.D0C i i THE TRUSTEE AND PAYING AGENT SECTION 6.01. Duties, Immunities and Liabilities of Trustee . . . . . . . . . . . . . . . . 28 SECTION 6.02. Right of Trustee to Rely upon Documents, Etc. . . 29 SECTION 6.03. Trustee Not Responsible*for Recitals . . . 29 SECTION 6.04. Right of Trustee to Acquire Certificates 29 SECTION 6.05. Moneys Received by Trustee to be Held in Trust . . . . . . . . . 30 SECTION 6.06. Compensation and Indemnification of Trustee . . . . . . . . . . 30 SECTION 6.07. Qualifications of Trustee . . . . . . . . 31 SECTION 6.08. Resignation and Removal of Trustee and Appointment of Successor Trustee . . . . . . 31 SECTION 6.09. Acceptance of Trust by Successor Trustee . 32 SECTION 6.10. Merger or Consolidation of Trustee . . . . 33 SECTION 6.11. Obligations of Trustee . . . . . . . 33 SECTION 6.12. Paying Agent for Certificates . . . . . . 33 SECTION 6.13. Resignation or Removal of Paying Agent; Appointment of Successor . . . . . . . . . . 34 ARTICLE VII DEFEASANCE SECTION 7.01. Certificates Deemed Paid; Discharge of Trust Agreement . . . . . . . . . . . . . 35 SECTION 7.02. Application of Trust Money . . . . . . . . 36 ARTICLE VIII SECTION 8.01. Mailing . . . . . . . . . . . . 36 SECTION 8.02. Powers of Amendment . . . . . . . . . . 36 SECTION 8.04. Exclusion of Certificates . . . . . . . . 39 B:\TRSTAGR6.D0C i i SECTION 8.05. Notation on Certificates . . . . . . . . . 39 'SECTION 8.06. Additional Certificates . . . . . . . 39 ARTICLE IB SECTION 9.01. Power to Enter into Trust Agreement, ARTICLE K EVENTS OF DEFAULT AND REMEDIES SECTION 10.01. Events of Default .. . . . . 45 SECTION 10.02. Institution of Legal • Proceedings by Trustee. . . 45 SECTION 10.03. Distribution of Proceeds of Remedies . . 46 SECTION 10.04. Suit By Owners . . . . . . . . 46 SECTION 10.05. Effect of Delay or Omission to Pursue Remedy . . . . . . . . . . . 47 SECTION 10.06. Remedies Cumulative . . . . . . . . . . . 47 ARTICLE %I MISCELLANEOUS SECTION 11.01. Payment of Purchase Payments; Unclaimed Installment Purchase Agreement and Assignment 47 SECTION Agreement •Binding 42 SECTION 9.02. Valid and Obligations 42 SECTION 9.03. Extension of Payment . . . . . . . . . . . 42 SECTION 9.04. Encumbrances . . . . . . . . . . . . . . . 42 SECTION 9.05. Tax Covenants . . . . . . 42 SECTION 9.06. Account Records and Statements . . . . . . 44 SECTION 9.07. Recording and Filing . . . . . . . . . 44 SECTION 9.08. Amendment of Installment Purchase 50 SECTION Agreement . . . . . . . . . . . . . . . . . . 44 SECTION 9.09. Enforcement . . . . . . . . . . . . . . . 45 SECTION 9.10. Further Assurances . . . . . . . . . . . . 45 ARTICLE K EVENTS OF DEFAULT AND REMEDIES SECTION 10.01. Events of Default .. . . . . 45 SECTION 10.02. Institution of Legal • Proceedings by Trustee. . . 45 SECTION 10.03. Distribution of Proceeds of Remedies . . 46 SECTION 10.04. Suit By Owners . . . . . . . . 46 SECTION 10.05. Effect of Delay or Omission to Pursue Remedy . . . . . . . . . . . 47 SECTION 10.06. Remedies Cumulative . . . . . . . . . . . 47 ARTICLE %I MISCELLANEOUS SECTION 11.01. Payment of Purchase Payments; Unclaimed B:\TRSTAGR6.DDC iii Moneys . . . . . . . . . . . .. . 47 SECTION 11.02. Evidence of Signatures of Owners and Ownership of Certificates . . . . 48 SECTION 11.03. Moneys Held for Particular Certificates 49 SECTION 11.04. Publication of Notice; Suspension of Publication . . . . . . . . 49 SECTION 11.05. Severability of Invalid Provisions . . . 49 SECTION 11.06. Notices . . . . . . . . . . . . . . . . 49 SECTION 11.07. California Law . . . . . . . . . . . . . 50 SECTION 11.08. Binding on Successors . . . . . . . . . . 50 SECTION 11.09. Headings . . . . . . . . . 50 SECTION 11.10. Execution in Counterparts . . . . . . . . 50 SECTION 11.11. Consent of Parties . . . . . . . . . . . 51 B:\TRSTAGR6.DDC iii ARTICLE XII CERTIFICATE FORK SECTION 12.01. Certificate Form . . . . . . . . . . . . 51 SIGNATURES AND SEALS . . . . . . . . . . . . . . . . . . . . 60 EXHIBIT A - Initial Deposits to Funds and Accounts . . . . A-1 8:\TRSTAGR6.DW iv THIS TRUST AGREEMENT, dated as of April 1, 1993 (the "Trust Agreement"), by and among CITY OF TUSTIN WATER CORPORATION, a California nonprofit public benefit corporation, BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION, a national banking association organized and existing under the laws of the United States, as trustee, and the CITY OF TUSTIN. W I T N E 8 8 E T H: WHEREAS, effective on the Delivery Date the Corporation will sell the Project to the City and the City will be obligated to make Purchase Payments pursuant to the Installment Purchase Agreement; and WHEREAS, the Corporation will establish a trust pursuant to this Trust Agreement and direct the Trustee to execute and deliver 1993 Certificates representing proportionate interests in the Principal Components and Interest Components of 1993 Purchase Payments to and including the earlier of the maturity or prepayment of all of such 1993 Certificates. NOW, THEREFORE, for and in consideration of the mutual covenants hereinafter contained, the parties hereto agree as follows: ARTICLE I DEFINITIONS AND EXHIBITS SECTION 1.01. Definitions. The terms defined in this Section 1.01 shall have the meanings ascribed to them in this Section 1.01 for all purposes of this Trust Agreement unless the context clearly indicates some other meaning. All capitalized terms used herein which are defined in the Installment Purchase Agreement and not defined herein shall have the meanings specified in the Installment Purchase Agreement. $'Assignment Agreementif shall mean that certain Assignment Agreement between the Corporation and the Trustee, dated as of April 1, 1993, pursuant to which the Corporation assigns certain rights to the Trustee for the benefit of the Owners of the 1993 Certificates, as originally entered into and as it may from time to time be amended, modified or supplemented. $'Authorized Manager and any person and authorized to act signed by the City Man that, in matters invo matters, the Treasurer act as the Authorized 6:\TRSTAGR6.D0C City Representative" shall mean the City or persons designated by the City Manager on behalf of the City by a Written Request ager and delivered to the Trustee; except, Lving the investment of funds and related of the City (or his or her designee) shall :ity Representative. $$Authorized Corporation Representative#@ shall mean the President of the Corporation or any other person or persons designated by the President or Board of Directors of the Corporation and authorized to act on behalf of the Corporation by a Written Request signed by the President of the Corporation or by a certified resolution adopted by the Board of Directors of the Corporation and delivered to the Trustee. IlAuthorized Newspaperit shall mean The Daily Bond Buyer or any other newspaper specializing in financial matters, customarily published at least once a day for at least five days (other than legal holidays) in each calendar week, printed in the English language, and of general circulation in the Borough of Manhattan, County and State of New York and a newspaper customarily published at least once a day for at least five days (other than legal holidays) in each calendar week, printed in the English language, and of general circulation in the City. 11Authorized Officer of the Trusteell shall mean and include the chairman of the board of directors, the president, every vice president, every assistant vice president, every trust officer and every officer and assistant officer of the Trustee. "Business DayU shall mean a day other than (i) a Saturday or Sunday or (ii) a day on which commercial banks in the city in which the trustee maintains its corporate trust office are authorized or required by law or executive order to close, (iii) a day on which the New York Stock Exchange is closed, (iv) a day on which the issuer of the Credit Facility, if any, is authorized or required by law or executive order to close or (v) a day on which the issuer of the Reserve Account Policy, if any, is authorized or required by law or executive order to close. o'Certificate" or ^Certificatesit shall mean the 1993 Certificates executed and delivered by the Trustee pursuant to this Trust Agreement, together with any additional certificates of participation executed and delivered pursuant hereto. $'City" shall mean the City of Tustin, California. "Codell shall mean the Internal Revenue Code of 1986, as amended. "Corporate Trust Office'$ shall mean, with respect to the Trustee, the office which is the corporate trust office of the Trustee situated in Los Angeles, California. IsCorporation" Corporation, a California its successors or assign Agreement. BATRSTAGR6.DDC shall mean the City of Tustin Water nonprofit public benefit corporation, or s appointed in accordance with this Trust IsCosts of Issuancell shall mean any costs or expenses paid or incurred in connection with the preparation, execution and delivery of the 1993 Certificates,; including but not limited to fees and expenses of the Trustee and its counsel, printing costs, word processing costs, special counsel and other legal fees and expenses, rating agency fees, financial advisor fees, accounting fees, legal fees and other expenses incurred by the City or the Corporation in connection with qualification or registration, or determining the exemption from registration or qualification, of the 1993 Certificates under the "Blue Sky" laws of any jurisdiction, and fees payable to any other consultants or experts retained in connection with such preparation, execution and delivery. IsCounsellf shall mean an attorney at law, or firm of attorneys, of recognized standing and who are qualified to pass on the legality of the particular matter. $'Credit Facility'$ shall mean an irrevocable and unconditional letter of credit, a standby purchase agreement, a line of credit or other similar credit arrangement issued by a Qualified Bank to satisfy all or a portion of the Reserve Requirement. "DTC" shall mean the Depository Trust Company, New York, New York, a limited purpose trust company organized under the laws of the State of New York, in its capacity as securities depository for the 1993 Certificates. I'Escrow Accountle shall mean the account so designated established pursuant to the Escrow Agreement. "Escrow AgentIf shall mean the Escrow Agent which is a party to the Escrow Agreement. "Escrow Agreementow shall mean the Escrow Agreement, dated as of April 1, 1993, between the City and the Escrow Agent. IfEvent of DefaultIl shall mean any of the events specified in Section 10.01 hereof. ('Government obligations'$ shall mean any of the following, to the extent noncallable by the issuer thereof: (i) obligations of, including specified portions thereof (which may consist of specified portions of the interest thereon), or obligations, including specified portions thereof (which may consist of specified portions of the interest thereon), the payment of the principal of and interest on which are unconditionally guaranteed by, the United States of America; 8:\TRSTRGR6.DOC (ii) bonds, debentures or notes issued by any of the following Federal Agencies: Banks for Cooperatives, Federal Land Banks, Federal Financing Bank, or Federal National Mortgage Association (including participation certificates); (iii) public housing bonds, temporary notes or preliminary loan notes, fully secured by contracts with the United States of America; (iv) bonds, debentures or notes issued by any Federal agency hereafter created by an act of Congress, the payment of the principal of and interest on which are unconditionally guaranteed by the United States of America; and (v) direct general obligations of, or obligations the payment of the principal of and interest on which are unconditionally guaranteed by the State or local agencies thereof. "Information Services') shall mean Financial Information, Inc.'s "Daily Called Bond Service," 30 Montgomery Street, 10th Floor, Jersey City, New Jersey 07302, Attention: Editor; Kenny Information Services' "Called Bond Service," 65 Broadway, 16th Floor, New York, New York 10006; Moody's "Municipal and Govern- ment," 99 Church Street, 8th Floor, New York, New York 10007, Attention: Municipal News Reports; and Standard & Poor's "Called Bond Record," 25 Broadway, 3rd Floor, New York, New York 10004; or, in accordance with the then current guidelines of the Securities and Exchange Commission, to such other addresses and/or such other services providing information with respect to called bonds as the City may designate. ',Installment Purchase Agreement" shall mean the Install- ment Purchase Agreement between the City and the Corporation, dated as of April 1, 1993, as amended or supplemented from time to time. ItInterest Component" shall mean any Purchase Payment, or portion thereof, which is designated and paid as interest pursuant to the terms of the Installment Purchase Agreement; the Interest Component of a Certificate is the proportionate interest in the Interest Component of the Purchase Payments which is evidenced by such Certificate. IfInterest Component Payment Date" shall mean October 1 and April 1 of each year (beginning, with respect to the 1993 Certificates, October 1, 1993, and ending on the final maturity date of such Certificates). 111993 Certificates" shall mean all the certificates of participation authorized by.Section 3.03 of this Trust Agreement BATRSTAGR6.DOC 4 and designated as "City of Tustin, Water System Revenue Certificates of Participation, 1993 Series." 110utstanding,11 when used with reference to Certificates, shall mean, as of any date, Certificates theretofore or thereupon prepared, executed and delivered under this Trust Agreement except: (a) Certificates cancelled by the Trustee or delivered to the Trustee for cancellation at or prior to such date; (b) Certificates (or portions of Certifi- cates) deemed paid pursuant to Section 7.01 hereof; and (c) Certificates in lieu of or in substi- tution for which other Certificates shall have been prepared, executed and delivered pursuant to Article III hereof. FlOwner" shall mean the registered owner of any Certificate or Certificates as shown on the Certificate register to be maintained by the Trustee pursuant to Section 3.08 hereof. flParticipantel shall mean a securities broker, dealer, bank, trust company, clearing corporation or other organization which has access, directly or indirectly, to DTC for holding of securities or clearance and settlement of securities transactions on its behalf as provided in Section 3.13 hereof. "Permitted Investments') shall mean any of the following except to the extent not permitted by the laws of the State: (i) Government Obligations; (ii) any of the following obligations of federal agencies not guaranteed by the United States of America: (a) debentures issued by the Federal Housing Administration; (b) participation certificates or senior debt obligations of the Federal Home Loan Mortgage Corporation or Farm Credit Banks (consisting of Federal Land Banks, Federal Intermediate Credit Banks or Banks for Cooperatives); (c) bonds of any federal home loan bank established under said act and stocks, bonds, debentures, participations and other obligations of or issued by the Federal National Mortgage Association, the Student Loan Marketing Association, the Government National Mortgage Association and the Federal Home Loan Mortgage Corporation; and bonds, notes or other obligations 8:\TRSTAGR6.D0C 5 issued or assumed by the International Bank for Reconstruction and Development; (iii) interest-bearing demand or time deposits (including certificates of deposit) in federal banks or banking associations (including the Trustee) or State of California chartered banks, provided that (a) in the case of a savings and loan association, such demand or time deposits shall be fully insured by the Federal Savings and Loan Insurance Corporation, or the unsecured obligations of such savings and loan association shall be rated in one of the two highest rating categories of a Rating Agency, and (b) in the case of a bank, such demand or time deposits shall be fully insured by the Federal Deposit Insurance Corporation, or the unsecured long-term obligations of such bank (or the unsecured obligations of the parent bank holding company of which such bank is the lead bank) shall be rated in one of the two highest rating categories of a Rating Agency; (iv) repurchase agreements entered into with financial institutions such as banks or trust companies organized under State law or national banks or banking associations, insurance companies or government bond dealers reporting to, trading with, and recognized as a primary dealer by, the Federal Reserve Bank of New York and a member of the Securities Investors' Protection Corporation or with a dealer or parent holding company provided that: (a) the unsecured obligations of any financial institution shall be rated in one of the two highest rating categories of a Rating Agency, or such financial institution shall be the lead bank of a banking holding company whose unsecured long-term obligations are rated in one of the two highest rating categories of a Rating Agency; (b) the most recent reported combined capital, surplus and undivided profits of such financial institution shall be not less than $100 million; (c) the repurchase obligation under any such repurchase obligation shall be required to be performed in not more than thirty (30) days; -and (d) the entity holding such securities as described in clause (c) shall have a valid and perfected first security interest therein for the benefit of the Trustee under the California Commercial Code or pursuant to the book entry procedures described by 31 C.F.R. 306.1 et seq. or 31 C.F.R. 850.0 et seq. and are rated in one of the two highest rating categories of a Rating Agency; BATRSTAGR&DDC (v) bankers acceptances endorsed and guaran- teed by banks described in clause (iv) above; (vi) obligations, the interest on which is excluded from federal income taxation under Section 103 of the Code and which are rated in'the one of the two highest rating categories of a Rating Agency; (vii) money market or mutual funds which invest solely in Government obligations or in obligations described in the preceding clause (ii) of this definition or money market funds which are rated in the highest rating category by a Rating Agency; (viii) units of a taxable government money market portfolio comprised solely of obligations listed in (i), (ii), or (iv) above; (ix) any investment which is a legal invest- ment for proceeds of the Certificates, and which investment is made pursuant to an agreement between the City or the Trustee or any successor Trustee and a financial institution or governmental body whose long-term obligations are rated in one of the two highest rating categories of a Rating Agency; (x) commercial paper of "prime" quality of the highest ranking or of the highest letter and numerical rating as provided for by a Rating Agency, of issuing corporations that are organized and operating within the United States and having total assets in excess of five hundred million dollars ($500,000,000) and having an "AA" or higher rating for the issuer's debentures or other long-term unsecured obligations, other than commercial paper, as provided for by a Rating Agency and provided that purchases of eligible commercial paper may not exceed 180 days maturity nor represent more than 10 percent of the outstanding paper of an issuing corporation; (xi) any general obligation of a bank or insurance company whose long-term debt obligations are rated in one of the two highest rating categories of a Rating Agency; or (xii) any other lawful investment for City funds under the Government Code of the State of California as amended from time to time. B.\TRSTAGR6.DDC ('Prepayment Date$, means the date fixed for an optional or mandatory prepayment, as the case may be, prior to maturity of the Certificates. IlPrepayment Price$$ shall mean a price equal to the Principal Component represented by a Certificate, plus the Interest Component accrued to the applicable Prepayment Date, plus premium, if applicable. $$Principal Componentil shall mean with respect to a Purchase Payment, the portion thereof which is designated and paid as principal pursuant to the terms of the Installment Purchase Agreement; the Principal Component of a Certificate is the proportionate interest in the Principal Component of the Purchase Payments which is evidenced by such Certificate. IlPrincipal Component Payment Date,, shall mean April 1 of each year (beginning, with respect to the 1993 Certificates, April 1, 1994 and ending on April 1, 2013.) "Qualified Hanks' shall mean a state or national bank or trust company or savings and loan association or a foreign bank with a domestic branch or agency which is organized and in good standing under the laws of the United States or any state thereof or any foreign country, which has a capital and surplus of $25,000,000 or more and which has a short-term debt rating of the highest ranking or of the highest letter and numerical rating as provided by Moody's or by S&P. "Rating Agency#' shall mean Moody's or S&P (together, the "Rating Agencies"). IlRecord Datell shall mean with respect to any Interest Component Payment Date for a Certificate the fifteenth day of the calendar month immediately preceding each Interest Component Payment Date. "Reserve Account Policyll shall mean a policy of insurance or surety bond issued by a municipal bond insurer, obligations insured by which have a rating by Moody's and S&P which at the time of issuance is the highest rating then issued by said Rating Agency, to satisfy all or a portion of the Reserve Requirement. IlReserve Requirements@ shall mean, at any date of determination and as computed by the City the least of (i) an amount equal to the maximum amount of Purchase Payments due on any April 1 and the next succeeding October 1 of any year with respect to Outstanding Certificates, (ii) an amount equal to 10% of the proceeds (within the meaning of Section 148 of the Code) of all Certificates then Outstanding, or (iii) an amount equal to 125% of the average annual Purchase Payments due with respect to Outstanding Certificates; provided, however that such Reserve B:\TRSTAGR6.DOC 8 Requirement or a portion thereof may be provided by one or more Reserve Account Policies or Credit Facilities upon the filing by the City with the Trustee of written evidence that the use of such Reserve Account Policies or Credit Facilities to satisfy the Reserve Requirement or any portion thereof will not by itself result in the downgrading or withdrawal of any credit rating then in effect with respect to the Certificates. ('Securities Depositories" shall mean The Depository Trust Company, 711 Stewart Avenue, Garden City, New York 11530, Fax -(516) 227-4039 or 4190; Midwest Securities Trust Company, Capital Structures -Call Notification, 440 South LaSalle Street, Chicago, Illinois 60605, Fax -(312) 663-2343; Philadelphia Depository Trust Company, Reorganization Division, 1900 Market Street, Philadelphia, Pennsylvania 19103, Attention: Bond Department, Dex-(215) 496-5058; or, in accordance with then current guidelines of the Securities Exchange Commission, to such other addresses and/or such other securities depositories as the City may designate. "Series" shall mean all Certificates designated by descriptive title or otherwise as a series and prepared, executed and delivered in a simultaneous transaction, and any Certificates thereafter prepared, executed and delivered in lieu of or in exchange or substitution for such Certificates, pursuant to the provisions of this Trust Agreement, regardless of variations in maturity, interest rate, prepayment or other provisions. especial Counsels' shall mean a nationally recognized law firm specializing in the area of tax-exempt municipal finance appointed by the City. OuStatell shall mean the State of California. 19supplemental Trust Agreement" shall mean any agreement supplemental to or amendatory of this Trust Agreement. ItTrust.Agreementot shall mean this Trust Agreement, dated as of April 1, 1993, entered into by and among the Trustee, the Corporation and the City, as originally executed and entered into and as it may from time to time be amended or supplemented in accordance herewith. "Trust Estate" shall mean all estate, right, title and interest of the Trustee in and to the Purchase Payments and the proceeds of the Certificates and all rights to enforce the Purchase Payments under the Installment Purchase Agreement, including, without limitation all amounts from time to time deposited in the funds, accounts and subaccounts created pursuant to this Trust Agreement and, to the extent set forth herein, investment earnings thereon. B:\TRSTAGR6.DOC ('Written Requests' shall mean a written instrument signed by an Authorized City Representative or an Authorized Corporation Representative, as the case may be. SECTION 1.02. Exhibit. The following Exhibit is attached to and by this reference made a part of this Trust Agreement: Exhibit A: Delivery Date Deposits to Accounts. ARTICLE II DECLARATION OF TRUST SECTION 2.01. Declaration of Trust by Trustee. The Corporation hereby establishes a trust and hereby grants, conveys, assigns and transfers the Trust Estate to the Trustee.. The Trustee hereby declares that it holds and will hold the Trust Estate upon the trusts hereinafter set forth and for the use and benefit of the Owners, as more particularly set forth herein. SECTION 2.02. Deposit of Moneys. In order to induce the City to enter into the Installment Purchase Agreement, and to insure that the Project will be available for use, the Corporation is entering into this Trust Agreement and will cause the Trustee to execute and deliver the 1993 Certificates, and from the proceeds of the sale of the 1993 Certificates (including accrued interest received) and the following transfers, the following deposits shall be made by the Trustee: (i) to the Purchase Payment Account, from the proceeds of the sale of the 1993 Certificates, the amount set forth with respect thereto in Exhibit A hereto, constituting accrued interest on the 1993 Certificates, to be applied toward the payment of the Interest Component of the 1993 Purchase Payment due on October 1, 1993; (ii) to the Reserve Account, from the proceeds of the sale of the 1993 Certificates, the amount set forth with respect thereto in Exhibit A hereto, constituting an amount equal to the Reserve Requirement on the Delivery Date with respect to the 1993 Certificates; (iii) to the Escrow Account, from the 1983 Reserve Account and the proceeds of the sale of the 1993 Certificates, the amount set forth with respect thereto in Exhibit A hereto, to acquire direct obligations of or guaranteed by the United States, the principal of and interest, when due, will provide moneys sufficient to pay the principal and interest when due and the redemption price, on B:\TRSTAGR6.D0C 10 October 1, 1993, of the Corporation's $3,675,000 outstanding City of Tustin water Corporation Lease Revenue Bonds, Series A; and (iv) to the Construction Account, from the proceeds of the sale of the 1993 Certificates, the amount set forth with respect thereto in Exhibit A hereto, constituting (a) an amount sufficient to pay Costs of Issuance with respect to the 1993 Certificates, (b) $772,292 to repay the balance owed by the City to - the Orange County Water District pursuant to the Nitrate Demonstration Project Agreement dated January 16, 1985 between Orange County Water District and the City (as amended, the "Demonstration Agreement") entered into for the benefit of the Water System, (c) $614,542 to reimburse the City for payments heretofore made by the City to the Orange County Water District pursuant to the Demonstration Agreement, and (d) the balance of the proceeds of the sale of the 1993 Certificates. SECTION'2.03. Conditions Precedent Satisfied. Each party hereto represents that all acts, conditions and things required of it by law to exist, happen and be performed by it precedent to and in connection with the execution and entering into of this Trust Agreement have happened and have been performed in regular and due time, form and manner as required by law, and each party hereto represents that it is now duly empowered to execute and enter into this Trust Agreement. ARTICLE III CERTIFICATES, TERMS AND PROVISIONS SECTION 3.01. Preparation of 1993 Certificates. The City is hereby directed to prepare and the Trustee is directed to execute and deliver 1993 Certificates evidencing direct and proportionate interests in the Purchase Payments to be paid by the City under the Installment Purchase Agreement. Each Certificate shall represent a direct and proportionate interest both in the Principal Components of Purchase Payments due and payable on the maturity date thereof or any Prepayment Date of the 1993 Certificates and in the Interest Components of Purchase Payments due and payable on Interest Component Payment Dates, to and including such maturity date or Prepayment Date. SECTION 3.02. Payments from Trust Estate Only; Distribution of Trust Estate. (a) Except as otherwise expressly provided herein, all amounts payable by the Trustee with respect to the Certificates pursuant to this Trust Agreement shall be paid only from the income of and proceeds from the Trust Estate and only 6:\TRSTAGR6.D0C 11 to the extent that the Trustee shall have actually received sufficient income or proceeds from the Trust Estate to make such payments in accordance with the terms of this Article III. Each Owner agrees, except as otherwise expressly provided herein, to look solely to the income of and the proceeds from the Trust Estate to the extent available for distribution to such Owner as herein provided and that the Trustee is not personally liable to any Owner for any amounts payable under this Trust Agreement. (b) So long as the Installment Purchase Agreement shall be in effect, all Purchase Payments shall be paid directly to the Trustee from the Treasurer of the City for distribution, in accordance with this Trust Agreement. SECTION 3.03. The 1993 Certificates. There are hereby authorized 1993 Certificates to be designated as "City of Tustin, Water System Revenue Certificates of Participation, 1993 Series." The 1993 Certificates evidence direct and proportionate interests in the right to receive Purchase Payments, shall be in the aggregate Principal Component of Eleven Million Five Hundred Thousand dollars ($11,500,000) and shall contain Interest Components accruing from the dates set forth below. The 1993 Certificates shall be prepared in the form of fully registered certificates in denominations of five thousand dollars ($5,000) or any integral multiple thereof. The interest, principal, and prepayment premiums, if any, due with respect to the 1993 Certificates shall be payable in lawful money of the United States of America. The interest due with respect to the 1993 Certificates shall be payable on their Interest Component Payment Dates by check or draft mailed on the applicable Interest Payment Date by the Trustee to the respective Owners thereof at their addresses as they appear in the books required to be kept by the Trustee pursuant to the provisions of Section 3.07 hereof on the Record Date with respect to each Interest Component Payment Date; provided, that in the case of an Owner of $1,000,000 or more in aggregate principal amount of 1993 Certificates, upon written request of such Owner delivered to the Trustee not less than twenty (20) days prior to any Interest Component Payment Date (which request shall remain in effect until revoked or revised by such Owner in a subsequent writing delivered to the Trustee), such interest shall be paid in immediately available funds by wire transfer at the expense of the City to an account specified by the Owner in such written request on the following Interest Component Payment Date. The principal and prepayment premiums, if any, due with respect to the 1993 Certificates shall be payable by check or draft upon surrender thereof at the Corporate Trust Office of the Trustee. The 1993 Certificates shall be dated April 1, 1993. Interest with respect to the 1993 Certificates shall accrue on 8:\TRSTAGR6.D0C 12 overdue principal at the same rate borne by the particular 1993 Certificates. Interest with respect to each 1993 Certificate shall accrue from the April 1 or October 1 next preceding the date of execution thereof unless (i) it is executed on an April 1 or October 1, in which event interest shall accrue from the date of execution thereof; (ii) it is executed on or prior to October 1, 1993 in which event interest shall accrue from April 1, 1993; or (iii) it is executed after a Record Date and prior to the next succeeding Interest Component Payment Date, in which case interest shall accrue from the next succeeding Interest Component Payment Date; provided, however, that if, at the time of execution of any Certificate, interest is in default on Outstanding Certificates, the Trustee shall establish a special record date for payment of any interest in default hereunder and interest with respect to such Certificate shall accrue from the date to which interest has previously been paid in full or made available for payment on such Outstanding Certificates. Interest Components with respect to the Certificates will be computed on the basis of a 360 -day year of twelve 30 -day months. SECTION 3.04. Payment Dates. The interest due with respect to the 1993 Certificates shall become due and payable on each Interest Component Payment Date from the date determined pursuant to Section 3.03 hereof to maturity or the Prepayment Date prior thereto, and shall evidence and represent the Interest Component of the Purchase Payments becoming due on each such Interest Component Payment Date. The Principal Component evidenced and represented by the 1993 Certificates shall become due and payable in the amounts and on April 1 in the years, and the interest due with respect to the 1993 Certificates shall be payable at the rates, as set forth below. SECTION 3.05. Execution. The Certificates shall be executed by the Trustee as registrar under this Trust Agreement, by B:\TRSTAGR6.D0C 13 PRINCIPAL PRINCIPAL AMOUNT OF AMOUNT OF MATURITY 1993 MATURITY 1993 (APRIL 1) CERTIFICATES RATE (APRIL 1) CERTIFICATES RATE 1994 $275,000 $ 2004 $ 550,000 1 1995 300,000 2005 600,000 1996 325,000 2006 625,000 1997 350,000 2007 675,000 1998 375,000 2008 725,000 1999 400,000 2009 775,000 2000 425,000 2010 825,000 2001 450,000 2011 875,000 2002 500,000 2012 925,000 2003 525,000 2013 1,000,000 SECTION 3.05. Execution. The Certificates shall be executed by the Trustee as registrar under this Trust Agreement, by B:\TRSTAGR6.D0C 13 the manual signature of an authorized signatory of the Trustee. In case any authorized signatory of the Trustee who shall have executed any of the Certificates shall cease to be an authorized signatory of the Trustee before the Certificates so executed shall have been delivered, such Certificates may nevertheless be delivered and, upon such delivery, shall be as binding as though such authorized signatory of the Trustee had continued to be an authorized signatory of the Trustee and also any Certificate may be executed on behalf of the Trustee by any person who at the actual date of the execution of such Certificate shall be an authorized signatory of the Trustee although at the nominal date of such Certificate any such person shall not have been an authorized signatory of the Trustee. SECTION 3.06. Exchange. Certificates, upon surrender thereof at the Corporate Trust Office of the Trustee, may, at the option of the Owner and upon payment by such Owner of any charges which the Trustee may make as provided in Section 3.09 hereof, be exchanged for an equal aggregate principal amount of registered Certificates of the same maturity, tenor and Series of any other authorized denominations. SECTION 3.07. Negotiability, Transfer and Registry. (a) Each Certificate shall be transferable only upon the books of the Trustee which shall be kept for that purpose at the Corporate Trust Office of the Trustee, by the Owner in person or by his or her attorney duly authorized in writing, upon surrender thereof together with a written instrument of transfer satisfactory to the Trustee duly executed by the Owner or his or her duly authorized attorney and upon payment of such Owner of any charges which the Trustee may make as provided in Section 3.09 hereof. Upon the transfer of any such Certificate the Trustee shall execute and deliver in the name of the transferee a new Certificate or Certificates of the same Principal Component, Series, tenor and maturity as the surrendered Certificate. (b) The Trustee may deem and treat the person in whose name any Certificate shall be registered upon the books of the Trustee as the absolute Owner of such Certificate, whether such Certificate shall be overdue or not, for the purpose of receiving payment of, or on account of, the Principal Component and premium, if any, and Interest Component with respect to such Certificate and for all other purposes, and all such payments so made to any such Owner or upon his or her order shall be valid and effectual to satisfy and discharge the liability upon such Certificate to the extent of the sum or sums so paid, and the Trustee shall not be affected by any notice to the contrary. (c) The Trustee shall not be required to transfer or exchange (i) any Certificate in the fifteen days prior to selection of Certificates for prepayment (whether or not such Certificate is BATRSTAGR6.000 14 thereafter selected for prepayment) and (ii) any Certificate selected for prepayment in whole or in part. SECTION 3.08. Certificate Registration Books. The Trustee will keep at its Corporate Trust Office sufficient books for the registration of the ownership, transfer and exchange of the Certificates, which books shall be available for inspection by the City and its designated agent or any Owner or his or her agent duly authorized in writing at reasonable hours and under reasonable conditions; and upon presentation for such purpose the Trustee shall, under such reasonable regulations as it may prescribe, register the ownership, transfer or exchange of the Certificates in such books as hereinabove provided. The ownership of any Certificates may be proved by the books required to be kept by the Trustee pursuant to the provisions of this Section 3.08. SECTION 3.09. Regulations with Respect to Exchanges and Transfers. In all cases in which the privilege of exchanging Certificates or transferring Certificates is exercised, the Trustee shall execute and deliver Certificates in accordance with the provisions of this Trust Agreement. All Certificates surrendered in any such exchanges or transfers shall forthwith be cancelled by the Trustee and destroyed, and the Trustee shall certify as to their destruction. For every such exchange or transfer of Certificates, whether temporary or definitive, the Trustee may make a charge to the Owners thereof sufficient to reimburse it for any tax, fee or charge required to be paid with respect to such exchange or transfer. SECTION 3.10. Certificates Mutilated, Destroyed, Stolen or Lost. In case any Certificate shall become mutilated or be destroyed, stolen or lost, the Trustee shall execute and deliver a new Certificate of like maturity, Series and Principal Component as the Certificate so mutilated, destroyed, stolen or lost, in exchange and substitution for such mutilated Certificate, upon surrender and cancellation of such mutilated Certificate, or in lieu of and substitution for the Certificate destroyed, stolen or lost, upon filing with the Trustee evidence satisfactory to the Trustee that such Certificate has been destroyed, stolen or lost and proof of ownership thereof, and upon furnishing the Trustee with indemnity satisfactory to the Trustee and complying with such other reasonable regulations as the Trustee may prescribe and paying such expenses as the Trustee may incur. All Certificates so surrendered to the Trustee shall be cancelled by it and destroyed, and the Trustee shall certify in writing as to their destruction. Any such new Certificates issued pursuant to this Section 3.10 in substitution for Certificates alleged to be destroyed, stolen or lost shall be entitled to equal and proportionate benefits, with all other Certificates delivered under this Trust Agreement, in any moneys or security held by the Trustee for the benefit of the Owners. BATRSTAGR&DOC 15 SECTION 3.11. Temporary Certificates. (a) Until definitive Certificates are prepared, the Corporation or the City may direct the Trustee to execute and deliver, in the same manner as is provided in this Article III, in lieu of definitive Certificates, one or more temporary Certificates substantially of the tenor of the definitive Certificates in lieu of which such temporary Certificate or Certificates are issued, in denominations authorized hereunder, so long as no such Certificate shall have its Principal Component becoming payable in more than one year, and with such omissions, insertions and variations as may be appropriate to temporary Certificates. At the expense of the City, the City shall prepare and the Trustee shall execute and, upon the surrender of such temporary Certificates and the cancellation of such surrendered temporary Certificates, the Trustee shall without charge to the Owner thereof, in exchange therefor, deliver definitive Certificates, of the same Principal Component, Series and maturity as the temporary Certificates surrendered. Until so exchanged, the temporary Certificates shall in all respects be entitled to the same benefits and security as definitive Certificates executed and delivered pursuant to this Trust Agreement. (b) If the City shall request the execution and delivery of temporary Certificates in more than one denomination, the Owner of any temporary Certificate or Certificates may, at his or her option, surrender the same to the Trustee in exchange for another temporary Certificate or Certificates of like Principal Component, Series and maturity of any other authorized denomination or denominations, and thereupon the Trustee shall execute and deliver, in exchange for the temporary Certificate or Certificates so surrendered and upon payment of the taxes, fees and charges provided for in Section 3.09 hereof, a temporary Certificate or Certificates of like aggregate Principal Component, Series and maturity in such other authorized denomination or denominations as shall be requested by such Owner. (c) All temporary. Certificates surrendered in exchange either for another temporary Certificate or Certificates or for a definitive Certificate or Certificates shall be forthwith cancelled by the Trustee and destroyed, and the Trustee shall certify in writing as to their destruction SECTION 3.12. Cancellation of Certificates. All Certificates paid or prepaid, either at or before maturity, shall be delivered to the Trustee when such payment or prepayment is made and such Certificates shall thereupon be promptly cancelled and destroyed, and the Trustee shall certify in writing as to their destruction. SECTION 3.13. Book -Entry Format. (a) Except as provided in subsection (c) of this Section 3.13, the registered owner of all of the 1993 Certificates shall initially be Cede & Co., as nominee B:\TRSTAW6_DOC 16 of DTC. Payment of Interest Components for any 1993 Certificates registered as of each Record Date in the name of Cede & Co. shall be made by wire transfer to the account of Cede & Co. on the Interest Component Payment Date for the 1993 Certificates at the address indicated on the Record Date for Cede & Co. in the registration books kept by the Trustee. (b) The 1993 Certificates shall initially be issued in the form of separate single authenticated fully registered 1993 Certificates in the Principal Component of each separate stated maturity of the 1993 Certificates. Upon initial issuance, the ownership of each such 1993 Certificate shall be registered in the registration book kept by the Trustee in the name of Cede & Co., as nominee of DTC. The Trustee shall treat DTC (or its nominee) as the sole and exclusive owner of the 1993 Certificates registered in its name for the purposes of payment of the Principal Component, premium or Interest Component represented by the 1993 Certificates, selecting the 1993 Certificates or portions thereof to be prepaid, giving any notice permitted or required to be given to the Owners thereof under the Trust Agreement, registering the transfer of 1993 Certificates, obtaining any consent or other action to be taken by the Owners thereof and for all other purposes whatsoever; and the Trustee shall not be affected by any notice to the contrary. The Trustee shall not have any responsibility or obligation to any DTC Participant or any Beneficial Owner. The City and the Trustee shall have no responsibility with respect to the accuracy of any records maintained by DTC, Cede & Co. or any Participant with respect to any ownership interest in the 1993 Certificates; the payment by DTC or any Participant to any Beneficial Owner of any amount of the Principal Component, premium, if any, or Interest Component with respect to the 1993 Certificates; the delivery to any Participant or any Beneficial Owner of any notice which is permitted or required to be given to the Owners thereof hereunder; the selection by DTC or any Participant of any person to receive payment in the event of a partial prepayment of 1993 Certificates; or any consent given or other action taken by DTC as the Owners thereof. The Trustee shall pay all Principal Components of, premium, if any, and Interest Components with respect to the 1993 Certificates only to or "upon the order of" (as that term is used in the Uniform Commercial Code as adopted in the State of New Jersey) Cede & Co., as nominee of DTC, and all such payments shall be valid and effective to fully satisfy and discharge the City's obligations with respect to the Principal Components of, premium, if any, and Interest Components with respect to the 1993 Certificates to the extent of the sum or sums so paid. Said Principal Components and premium, if any, shall be paid to DTC in immediately available funds on each Principal Component Payment Date or Prepayment Date to: B:\TRSTAGR6.D0C 17 Muni Redemption Department The Depository Trust Company 55 Water street 23rd Floor New York, New York 10041 Attention: Collections supervisor Upon delivery by DTC to the Trustee of written notice to the effect that DTC had determined to substitute a new nominee in place of Cede & Co., and subject to the provisions herein with respect to record dates, the word "Cede & Co." in this Trust Agreement shall refer to such new nominee of DTC. (c) In the event the City determines that it is in the best interest of the Beneficial Owners of the 1993 Certificates that they be able to obtain certificates, the City will notify DTC and the Trustee of the availability through DTC of 1993 Certificates. In such event, the Trustee shall execute, transfer and exchange 1993 Certificates as requested by DTC and any other Owner thereof in appropriate amounts. DTC may determine to discontinue providing its services with respect to the 1993 Certificates at any time by giving notice to the City and the Trustee and discharging its responsibilities with respect thereto under applicable law. Under such circumstances (if there is no successor securities depository), the City and the Trustee shall be obligated to deliver 1993 Certificates as described in this Trust Agreement. In the event 1993 Certificates are issued to any Owner other than DTC, the provisions of this Trust Agreement shall apply to, among other things, the transfer and exchange of such 1993 Certificates and the method of payment of Principal Components of, and Interest Components with respect to, such 1993 Certificates and the amounts due on the Interest Component Payment Dates and the Principal Component Payment Dates of such 1993 Certificates. Whenever DTC requests the City and the Trustee to do so, the Trustee and the City will cooperate with DTC in taking appropriate action after reasonable notice (a) to make available one or more separate certificates -evidencing the 1993 Certificates to any DTC Participant having 1993'Certificates credited to its DTC account or (b) to arrange for another securities depository to maintain custody of certificates evidencing the 1993 Certificates. (d) In connection with any notice or other communication to be provided to Owners- of 1993 Certificates pursuant to this Trust Agreement by the Trustee with respect to any consent or other action to be taken by Owners of 1993 Certificates so long as any 1993 Certificate is registered in the name of Cede & Co., as nominee of DTC, the Trustee shall establish a record date for such consent or other action and give DTC notice of such record date not less than 15 calendar days in advance of such record date to the extent possible. B:\TRSTAGR6.DOC is ARTICLE IV PREPAYMENT OF 1993 CERTIFICATES SECTION 4.01. Prepayment. (a) Optional Prepayment. The 1993 Certificates maturing on or after April 1, 2004, are subject to prepayment at the option of the City at any time on or after April 1, 2003 in integral multiples of $5,000, at the Principal Component thereof together with any applicable premium, and the related Interest Components due on the date fixed for such prepayment, from any source of funds, upon notice as provided herein. The prepayment price (expressed as a percentage of the total principal amount prepaid) upon prepayment is set forth below: Period During Which Prepaid Prepayment (both dates inclusive) Price April 1, 2003 through March 31, 2004 102% April 1, 2004 through March 31, 2005 101 April 1, 2005 and thereafter 100 (b) Revised Schedule of 1993 Purchase Payments. Upon prepayment pursuant to Section 4.01(a), the City shall provide the Trustee and the Corporation with a revised schedule of 1993 Purchase Payments which schedule shall take into account such prepayment. SECTION 4.02. Selection of Certificates for Prepayment. In the case of prepayment of less than all Outstanding Certificates, the Trustee shall select the Certificates representing the Principal Components to be prepaid to correspond to the Principal Components of Purchase Payments prepaid by the City in conformance with Section 5.6 of the Installment Purchase Agreement. Any selection of the Certificates by the Trustee shall be binding upon the Owners. When Principal Components represented by the Certificates are to be prepaid at the option of the City as set forth in Subsection 4.01(a) above, the City shall give written notice to the Trustee of the exercise of such option at least forty-five (45) days but not more than ninety (90) days prior to the proposed Prepayment Date. Such notice shall state the proposed Prepayment Date, the aggregate Principal Component of the Certificates to be prepaid and the maturity or maturities from which each prepayment shall be made. SECTION 4.03. Notice of Prepayment. Notice of prepayment shall be mailed by the Trustee by first-class mail postage prepaid, B:\TRSTAGR6.DOC 19 not less than thirty (30) nor more than sixty (60) days prior to the Prepayment Date to (i) the respective Owners of any certificates representing Principal Components designated for prepayment at their addresses appearing on the Certificate registration books of the Trustee and (ii) each Information Service. Notice of prepayment shall also be given by telecopy, certified, registered or overnight mail to the Securities Depositories on the day of the mailing of notice of prepayment to the Owners and the Information Services. Each notice of prepayment shall state the date of such notice, the Prepayment Date, the Prepayment Price, the place or places of prepayment (including the name and appropriate address or addresses of the Trustee), the CUSIP number, if any, of the maturity or maturities to be prepaid and, if less than all of such maturity, the distinctive certificate numbers of the Certificates of such maturity to be prepaid and, in the case of Certificates representing Principal Components to be prepaid in part only, the respective portions of the Principal Component represented thereby to be prepaid. Each such notice shall also state that on said date there will become due and payable with respect to each of said Certificates the Prepayment Price thereof or of said specified portion of the Principal Component represented thereby in the case of a Certificate to be prepaid in part only, and that from and after such Prepayment Date, the related Interest Component due with respect thereto shall cease to accrue, and shall require that such Certificates be then surrendered at the address or addresses of the Trustee specified in the prepayment notice. Notwithstanding anything herein to the contrary, the Trustee shall not give notice of any prepayment pursuant to Section 4.01 hereof until and unless the Trustee has received and has available from all sources sufficient funds to pay the Prepayment Price represented by all Certificates to be prepaid. Notice of prepayment of Certificates shall be given by the Trustee, at the expense of the City, for and on behalf of the City. Failure by the Trustee to give notice pursuant to this Section 4.03 to any one or more of the Information Services or Securities Depositories shall not affect the sufficiency of the proceedings for prepayment. Failure by the Trustee to mail notice of prepayment pursuant to this Section 4.03 to any one or more of the respective Owners of any Certificates representing Principal Components designated for prepayment shall affect the sufficiency of the proceedings for prepayment only with respect to the Owner or Owners to whom such notice was not mailed. An affidavit of an Authorized Officer of the Trustee that notice of prepayment was mailed to the Owners of the Certificates shall be conclusive evidence of the mailing of such notice. SECTION 4.04. Payment of Certificates Upon Prepayment. - Prior to each Prepayment Date, the Trustee shall make provision for the payment of the Principal Components to be prepaid on such date B:\TRSTAGR6.DOC 20 by setting aside from moneys available therefor and holding in trust, an amount within the Purchase Payment Account sufficient to pay the Prepayment Price of such Certificates. Upon presentation and surrender of any such Certificate at the Corporate Trust Office of the Trustee on or after the Prepayment Date, the Trustee shall pay the Prepayment Price of such Certificate only to the extent that moneys are set aside for such purpose. The Trustee shall be responsible only to prepay Principal Components to the extent of available moneys and shall not be liable or responsible for, and shall be indemnified by the City against, failure to prepay Principal Components to the extent that no moneys are available therefor. SECTION 4.05. Partial Prepayment of Certificates. Upon surrender of any Certificate representing Principal Components to be prepaid in part only, the Trustee shall execute and deliver to the Owner thereof a new Certificate or Certificates representing Principal Components equal to the unprepaid Principal Component of the Certificate surrendered of the same maturity. SECTION 4.06. Effect of Prepayment. If notice of prepayment has been duly given as aforesaid and funds for the payment of the Prepayment Price of the Certificates to be prepaid are held by the Trustee on the designated Prepayment Date, then on the Prepayment Date designated in such notice, the Prepayment Price of the Certificates representing Principal Components so called for prepayment shall become payable as specified in such notice; and from and after the date so designated Interest Components due with respect to the Principal Components of the Certificates or portions thereof so called for prepayment shall cease to accrue, such Certificates shall cease to be entitled to any benefit, protection or security hereunder and the Owners of such Certificates shall have no rights in respect thereof except to receive payment of the Prepayment Price. The Trustee shall, upon surrender for payment of any of the Certificates to be prepaid on their Prepayment Dates, pay such Certificates at the Prepayment Price. All Certificates representing Principal Components prepaid in whole or in part pursuant to the provisions of this article shall be cancelled by the Trustee and destroyed, and the Trustee shall certify in writing as to their destruction. ARTICLE V ESTABLISHMENT AND ADMINISTRATION OF CERTAIN FUNDS AND ACCOUNTS SECTION 5.01. Establishment of Project Trust Fund. There is hereby established with the Trustee a special trust fund for the 1993 Certificates, which special trust fund shall be designated as the 111993 Project Trust Fund." The Trustee shall keep the 1993 Project Trust Fund separate and apart from all other funds and BATRSTAGR6.00C 21 moneys held by it. Within the 1993 Project Trust Fund, there are hereby established the Purchase Payment Account and the Reserve Account. SECTION 5.02. Purchase Payment Account. (a) The Trustee shall deposit in the Purchase Payment Account the following: (i) on the Delivery Date, the amount representing accrued interest on the 1993 Certificates, set forth with respect to the Purchase Payment Account in Exhibit A hereto; and (ii) when received, Purchase Payments made by the City pursuant to Section 5.2 of the Installment Purchase Agreement; and (iii) from time to time, moneys transferred from the Construction Account pursuant to Sections 5.04(d) and 5.04(e)(iv) hereof, which moneys shall be used as provided in such Sections; and (iv) from time to time, moneys transferred from the Reserve Account pursuant to Section 5.03(b) hereof; and (v) amounts delivered to the Trustee by the City for the payment of the premium portion of the Prepayment Price to be paid pursuant to Section 4.01(a) hereof; and (vi) all other moneys received by the Trustee under and pursuant to the provisions of the Installment Purchase Agreement which are required to be or which are accompanied by directions that such moneys are to be paid into the Purchase Payment Account. (b) The Trustee shall withdraw moneys from the Purchase Payment Account at such times and in such amounts as are necessary to make payments of Principal Components, Interest Components or premium, if any; provided, however, that such payments shall be deemed made first from investment income, if any, transferred to the Purchase Payment Account from the Reserve Account pursuant to Section 5.03(d) hereof and investment income received with respect to moneys deposited to the Purchase Payment Account pursuant to Section 5.02(a)(i) hereof. (c) The amounts deposited in the Purchase Payment Account pursuant to subsection 5.02(a)(i) hereof, and the investment income B:\TRSTAGR6.DOC 22 therefrom, shall be applied toward the payment of the Interest Component of the 1993 Purchase Payment due on October 1, 1993. (d) After the Completion Certificate is filed with respect to the Project, if, on the day after any Purchase Payment Date (i) all Principal Components, premium and Interest Components which became due and payable on or before such date have been paid in full, and (ii) there are moneys on deposit in the Purchase Payment Account, other than that required for prepayment of Certificates, and (iii) the amount on deposit in the Reserve Account is less than the Reserve Requirement, then the Trustee shall transfer from the Purchase Payment Account to the Reserve Account the lesser of (i) an amount which, when added to the amount on deposit in the Reserve Account, will equal the Reserve Requirement, or (ii) all amounts on deposit in the Purchase Payment Account. (e) After the Completion Certificate is filed with respect to the Project, if, on the day after any Purchase Payment Date (i) all transfers have been made pursuant to Section 5.02(d) hereof, and (ii) there are moneys on deposit in the Purchase Payment Account other than that required for prepayment of Certificates and other than excess Construction Account moneys transferred pursuant to Section 5.04(d) hereof, then the Trustee shall (i) at the request of the City, transfer such funds to the City or (ii) apply such funds to reduce the next succeeding Purchase Payment payable by the City. SECTION 5.03. Reserve Account. (a) The Trustee shall deposit in the Reserve Account the following: (i) on the Delivery Date, from the proceeds of the sale of the 1993 Certificates, the amount set forth with respect to such Account in Exhibit A hereto, constituting an amount equal to the Reserve Requirement with respect to the 1993 Certificates on the Delivery Date; and (ii) from time to time, any Purchase Payment, or portion thereof, made after the appropriate Purchase Payment Date in an amount equal to the amount transferred from the Reserve Account to the Purchase Payment Account on such Purchase Payment Date pursuant to subsection 5.03(b) hereof; and (iii) from time to time, moneys transferred from the Purchase Payment Account pursuant to Section 5.02(d) hereof. (b) If, on any Purchase Payment Date, the amount available in the Purchase Payment Account is less than the amount necessary to pay the Principal Component or the Interest Component B:\TRSTAGR6.D0C 23 to be paid on such date with respect to any Certificate, then the Trustee shall transfer from the Reserve Account to the Purchase Payment Account the lesser of: (i) an amount sufficient to enable the Trustee to pay the Principal Component and Interest Component with respect to such Certificate from the Purchase Payment Account, or (ii) all amounts on deposit in the ReserveAccount. In the event of such transfer, the Trustee shall, within five (5) days after making such transfer, provide written notice to the City and the Corporation of the amount and date of such transfer. (c) Until the Completion Certificate is filed for the Project, the Trustee shall, on the first Business Day of each month, transfer to the Treasurer for deposit in the Construction Account moneys in the Reserve Account in excess of the Reserve Requirement, to the extent that such moneys constitute investment income received at or prior to the end of the immediately preceding month. (d) After the Completion Certificate is filed for the Project, the Trustee shall, on each Purchase Payment Date, transfer to the Purchase Payment Account moneys in the Reserve Account in excess of the Reserve Requirement, to the extent that such moneys constitute investment income received since the immediately preceding Purchase Payment Date. SECTION 5.04. Construction Account. (a) There is hereby established with the Treasurer the Construction Account, which Account shall be kept separate and apart from all other funds and moneys held by the City. The Treasurer shall deposit in the Construction Account the following: (i) on the Delivery Date, from the proceeds of the sale of the 1993 Certificates, the amount set forth with respect to the Construction Account in Exhibit A hereto; and (ii) from time to time, moneys transferred by the Trustee from the Reserve Account pursuant to subsection 5.03(c) hereof. (b) Costs of Issuance shall be paid from amounts on deposit in the Construction Account. The Treasurer shall make such payments in the amounts, at the times, in the manner, and on the other terms and conditions set forth herein. No such payment shall be made until the Treasurer shall have received a requisition signed by an Authorized City Representative stating with respect to each payment to be made: (1) the requisition number, (2) the name and address of the person, firm, corporation or agency to which payment is due or has been made, (3) the amount to be paid, (4) identification of the item to which such payment is to be applied, (5) that each obligation mentioned therein is a proper charge against the Construction Account and has not been the basis of any BATRSTAGR6.DDC 24 previous withdrawal from the Construction Account. In addition, each requisition shall have attached a copy of each invoice, statement or other billing documentation for which payment is claimed. (c) The Cost of the Project shall be paid from the amounts on deposit in the Construction Account. The Treasurer shall make such payments in the amounts, at the times, in the manner, and on terms and conditions as set forth in this subsection (c). No such payment shall be made until the Treasurer shall have received a requisition signed by an Authorized City Representative setting forth with respect to each payment to be made: (1) the requisition number, (2) the name and address of the person, firm, corporation or agency to whom payment is due or has been made, (3) the amount to be paid, (4) the item to which such payment is to be applied, and (5) that such payment obligation has been properly incurred, is an item of Cost of the Project, is a proper charge against the Construction Account and has not been the basis of any previous withdrawal from the Construction Account. (d) Notwithstanding any of the other provisions of this Section 5.04, to the extent that other moneys are not available therefor, amounts in the Construction Account shall be withdrawn and transferred to the Trustee for deposit in the Purchase Payment Account and applied by the Trustee to the payment of the Principal Component or Interest Component with respect to the Certificates. (e) After the Completion Certificate is filed for the Project, the Authorized City Representative will direct the Treasurer to transfer any moneys held in the Construction Account and not required for the payment of any remaining part of the Cost of the Project, as stated in the Completion Certificate to the Trustee for deposit in the Reserve Account to the extent the amount on deposit in the Reserve Account is less than the Reserve Requirement, and, thereafter the Authorized City Representative will direct the Treasurer to apply such moneys, at the City's discretion, to (i) the expansion or enlargement of the Project, (ii) the betterment or improvement of the Project, (iii) the expansion, enlargement or improvement of the Water System, or (iv) the Purchase Payment Account held by the Trustee for (1) the payment of Interest Components, (2) the payment of Principal Components represented by the Certificates, or the prepayment of Principal Components represented by the Certificates if such prepayment may be made at the option of the City pursuant to Section 4.01(a) hereof, (3) the purchase of Certificates on the open market, to the extent such Certificates are available for purchase at a purchase price no greater than one hundred percent (100%) of the Principal Component thereof plus accrued interest to the date of such purchase, or (v) any combination of the foregoing (i) through (iv). No payment pursuant to clauses (i), (ii) or (iii) of this Section 5.04(e) shall be made until the Treasurer shall have received a requisition signed by an Authorized City B.XTRSTAGR6.DDC 2 5 Representative setting forth with respect to each payment to be made: (1) the requisition number, (2) the name and address of the person, firm, corporation or agency to whom payment is due or has been made, (3) the amount to be paid, (4) the time to which such payment is to be applied, and (5) that such payment obligation has been properly incurred, is a proper charge against the Construction Account and has not been the basis of any previous withdrawal from the Construction Account. In addition, each requisition shall have attached a copy of each invoice, statement or other billing documentation for which payment is claimed. SECTION 5.05. Deposits of Money. All moneys held by or deposited with the Trustee or the City under the provisions of this Trust Agreement shall be held in trust and applied only in accordance with the provisions of this Trust Agreement, and the 1993 Project Trust Fund established by this Trust Agreement shall be a trust fund for the purposes thereof. All moneys deposited with the Trustee and the City shall be credited to the particular account to which such moneys belong. SECTION 5.06. Valuation and Sale of Investments. Obligations purchased as an investment of moneys in any account created under the provisions of this Trust Agreement shall be deemed at all times to be a part of such account or subaccount and any profit realized from the liquidation of such investment and any income or interest received on account of such investment, except as otherwise provided in Sections 5.03(c) and 5.03(d) with respect to interest earnings, shall be credited to, and any loss resulting from the liquidation of such investment shall be charged to, such account. In computing the amount in any account created under the provisions of this Trust Agreement for any purpose provided in this Trust Agreement, obligations purchased as an investment of moneys therein shall be valued at the lower of cost or the market value of such obligations (including accrued interest). Except as otherwise provided in this Trust Agreement, the Trustee shall sell at the best price obtainable or present for prepayment or transfer as provided in the next sentence any obligation so purchased as an investment whenever it shall be requested in writing by an Authorized City Representative to do so or whenever it shall be necessary in order to provide moneys to meet any payment or transfer from any account held by it. In lieu of such sale or presentment for prepayment, the Trustee may, in making the payment or transfer from any account mentioned in the preceding sentence, transfer such investment obligations or interest appertaining thereto at its acquisition cost if such investment obligations shall mature or be collectable at or prior to the time the proceeds thereof shall be needed, and such transfer of investment obligations may be made in book entry form. The Trustee shall not be liable or responsible for making any such B:\TRSTAGR6.DOC 2 6 investment in the manner provided above or for any loss resulting from any such investment. The Trustee may act as principal or agent in the acquisition or disposition of any investment. The Trustee shall hold all investments in its name as trustee. SECTION 5.07. Investment of Certain Accounts. (a) Moneys in the Construction Account and the Purchase Payment Account shall be invested and reinvested by the City and the Trustee, respectively, to the fullest extent practicable in Permitted Investments which mature not later than such times as shall be necessary to provide moneys when needed for payments to be made from such accounts and in any event not later than the final maturity of the Certificates. Notwithstanding the foregoing, moneys deposited in the Purchase Payment Account pursuant to Section 5.02(a)(i) hereof shall be held in cash by the Trustee or shall be invested and reinvested by the Trustee in obligations described in clauses (i) through (iv) of the definition of Government Obligations. Moneys in the Reserve Account shall be invested and reinvested by the Trustee to the fullest extent practicable in Permitted Investments which mature or are available not more than ten years from the date of investment. The Trustee shall make all such investments of moneys held by it in accordance with instructions, confirmed in writing, received from an Authorized City Representative. The Authorized City Representative may instruct the Trustee at least two Business Days prior to making any investment in any Permitted Investments with moneys in any account established under this Trust Agreement, to combine such moneys with moneys in any other account, but solely for purposes of making such investment in such Permitted Investments. The Trustee shall account for investments in accordance with the funds and accounts to which they are credited. In the absence of instruction from the Authorized City Representative, the Trustee shall invest only in Permitted Investments described in subparagraph (vii) of the definition of Permitted Investments. The Trustee shall not be liable for losses on investments made in accordance with this Section 5.07. (b) If the City or the Corporation or both enter into one or more interest rate swap agreements corresponding to the interest payable with respect to one or more Series of Certificates or any portion thereof, the amounts received by the Corporation or the City, if any, pursuant to such a swap agreement may be applied to the deposits required hereunder. (c) Nothing in this -Trust Agreement shall prevent any Government Obligations acquired as investments of funds held under the Trust Agreement from being issued or held in book -entry form on the books of the Department of the Treasury of the United States of America. B:\TRSTAGR6.DOC 2 7 ARTICLE VI THE TRUSTEE AND PAYING AGENT SECTION 6.01. Duties, Immunities and Liabilities of Trustee. The Trustee shall, prior to an Event of Default, and after the curing of all Events of Default which may have occurred, perform such duties and only such duties as are specifically set forth in this Trust Agreement. The Trustee shall, during the existence of any Event of Default (which has not been cured), exercise such of the rights and powers vested in it by this Trust Agreement, and use the same degree of care and skill in their exercise, as a prudent man would exercise or use under the circumstances in the conduct of his own affairs. No provision of this Trust Agreement (including particularly Section 3.02 hereof) shall be construed to relieve the Trustee from liability for its own willful misconduct or negligence, except that: (a) prior to such an Event of Default hereunder and after the curing of all Events of Default which may have occurred and in the absence of bad faith on the part of the Trustee, the Trustee may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed therein, upon any certificate or opinion furnished to the Trustee conforming to the requirements of this Trust Agreement; but in the case of any such certificate or opinion which by any provisions hereof is specifically required to be furnished to the Trustee, the Trustee shall be under a duty to examine the same to determine whether or not it conforms to the requirements of this Trust Agreement; and (b) at all times, regardless of whether or not any Event of Default shall exist: (1) the Trustee shall not be liable for any error of judgment made in,good faith by an Authorized Officer or Officers of the Trustee unless it shall be proved that the Trustee was negligent in ascertaining and/or failing to ascertain the pertinent facts; and (2) the Trustee shall not be liable with respect to any action taken or omitted to be taken by it in good faith in accordance with the direction of the Owners of Outstanding Certificates representing not less than a majority of the Principal Components relating to the time, method and place of conducting any proceeding for any remedy available to the Trustee, or exercising any trust or power conferred upon the Trustee under this Trust Agreement. None of the provisions contained in this Trust Agreement shall require the Trustee to expend or risk its own funds or B:\TRSTAGR6.D0C 28 otherwise incur individual financial liability in the performance of any of its duties or in the exercise of any of its rights or powers if there shall be reasonable grounds for believing that the repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. SECTION 6.02. Right of Trustee to Rely upon Documents, Etc. Except as otherwise provided in Section 6.01 hereof: (a) the Trustee may rely and shall be protected in acting upon*any resolution, certificate, statement, instrument, opinion, report, notice, request, consent, order, certificate or other paper or document believed by it to be genuine and to have been signed or presented by the proper party or parties; (b) any notice, request, direction, election, order or demand of the Corporation or the City mentioned herein shall be sufficiently evidenced by an instrument signed in the name of the Corporation or of the City by an Authorized Corporation Representative or an Authorized City Representative, respectively; (c) the Trustee may consult with Counsel (who may be Counsel for the Corporation or the City) and the opinion of such Counsel shall be full and complete authorization and protection in respect of any action taken or suffered by it hereunder in good faith and in accordance with the opinion of such Counsel; and (d) whenever in the administration of the trusts of this Trust Agreement the Trustee shall deem it necessary or desirable that a matter be proved or established prior to taking or suffering any action hereunder, such matter (unless other evidence in respect thereof be herein specifically prescribed) may be deemed to be conclusively proved and established by a certificate of an Authorized City Representative or an Authorized Corporation Representative, as appropriate; and such certificate shall be full warrant to the Trustee for any action taken or suffered by it under the provisions of this Trust Agreement upon the faith thereof. SECTION 6.03. Trustee Not Responsible for Recitals. The recitals contained herein and in the Certificates shall be taken as the statements of the Corporation and the City, and the Trustee assumes no responsibility for the validity or correctness of the same. The Trustee makes no representation as to the validity or sufficiency of this Trust Agreement or of the Certificates. The Trustee shall not be accountable for the use or application of any of the Certificates delivered hereunder or of the proceeds of such Certificates except as provided herein. SECTION 6.04. Right of Trustee to Acquire Certificates. The Trustee and its officers and directors may acquire and hold, or become the pledgee of, Certificates and otherwise deal with the B:\TRSTAGR6.DDC 2 9 corporation and the City in the manner and to the same extent and with like effect as though it were not the Trustee hereunder. SECTION 6.05. Moneys Received by Trustee to be Held in Trust. All moneys received by the Trustee shall, until used or applied as herein provided, be held in trust for the purposes for which they were received, but need not be segregated from other trust funds except to theextent specifically required by this Trust Agreement or required by law. The Trustee shall be obligated to invest all moneys received by it hereunder in accordance with Section 5.07 hereof. Any interest allowed on any such moneys shall be deposited in the account to which such moneys are credited. SECTION 6.06. Compensation and Indemnification of Trustee. The City covenants to cause the Trustee to be paid from time to time, and the Trustee shall be entitled to, reasonable compensation for all services rendered by it in the execution of the trusts hereby created and in the exercise and performance of any of the powers and duties hereunder of the Trustee pursuant to any agreement entered into between the City and the Trustee, which compensation shall not be limited by any provision of law in regard to the compensation of a trustee of an express trust, and the City will cause the Trustee to be paid or reimbursed, upon request of the Trustee for all reasonable expenses and disbursements incurred or made by the Trustee in accordance with any of the provisions of this Trust Agreement (including the reasonable compensation and the expenses and disbursements of its Counsel and of all persons not regularly in its employ). The City also covenants to indemnify the Trustee for, and to hold it harmless against, any loss, liability, expense or advance incurred or made without negligence or willful misconduct on the part of the Trustee, arising out of or in connection with (i) the acceptance or administration of this trust, (ii) the condition, management, maintenance or use of or from any work or thing done in connection with the Project by the City, (iii) any act of negligence or willful misconduct of the City or the Corporation or any of their agents, contractors, employees, invitees, licensees or officers in connection with the Project, (iv) the delivery or sale of the Certificates and the carrying out of any of the transactions contemplated by the Certificates, this Trust Agreement, the Assignment Agreement or the Installment Purchase Agreement, other than those transactions to be performed by the Trustee hereunder or thereunder, as the case may be; and (v) any untrue statement or alleged untrue statement of any material fact or omission or alleged omission to state a material fact necessary to make the statements made, in light of the circumstances under which they were made, not misleading in any official statement or other disclosure document utilized in connection with the delivery or sale of the Certificates including the fees, costs and expenses of defending itself against any claim of liability. The obligations of the City under this Section 6.06 and Section 6.12 hereof to cause the Trustee to be compensated for services and to be paid or reimbursed for expenses, disbursements B:\TRSTAGR6.DOC 30 and liabilities shall constitute additional obligations hereunder. Such additional obligations shall have priority over the Certificates in respect of all property and funds held or collected by the Trustee as such, except funds held by the Trustee for the benefit of the Owners of particular Certificates and except funds held in the Purchase Payment Account. Notwithstanding any contrary provision hereof, this covenant shall remain in full force and effect, even though all obligations secured hereby may have been fully paid and satisfied and this Trust Agreement may have been released and discharged. SECTION 6.07. Qualifications of Trustee. There shall at all times be a trustee hereunder which shall be a bank or trust company organized and doing business under the laws of the United States or any of the states of the United States, authorized under such laws to exercise corporate trust powers, subject to supervision or examination by federal or state authority and, if required by law, qualified to do business in the State. Any successor Trustee to Bank of America National Trust and Savings Association shall have a combined capital and surplus of at least seventy-five million dollars ($75,000,000). If such bank or trust company publishes reports of condition at least annually, pursuant to law or to the requirements of any supervising or examining authority above referred to, then for the purposes of this Section 6.07, the combined capital and surplus of such corporation shall be deemed to be its combined capital and surplus as set forth in its most recent report of condition so published. In case at any time the Trustee shall cease to be eligible in accordance with the provisions of this Section 6.07, the Trustee shall resign immediately in the manner and with the effect specified in Section 6.08 hereof. SECTION 6.08. Resignation and Removal of Trustee and Appointment of Successor Trustee. (a) The Trustee may at any time resign by giving written notice to the City and by giving to the Owners of the Certificates notice by mail of such resignation. Upon receiving such notice of resignation, the City, with the written approval of the Corporation (which approval shall not be unreasonably withheld), shall promptly appoint a successor trustee by an instrument in writing executed by an Authorized City Representative. If no successor trustee shall have been so appointed and shall have accepted appointment within sixty (60) days after the mailing of such notice of resignation, the resigning trustee may at the expense of the City petition any court of competent jurisdiction for the appointment of a successor trustee, or any Owner may, on behalf of himself or herself and others similarly situated, petition any such court for the appointment of a successor trustee. Such court may thereupon, after such notice, if any, as it may deem proper and prescribe, appoint a successor trustee. (b) In case any of the following shall occur -- 8:\TRSTAGR6.DOC 31 (1) the Trustee shall cease to be eligible in accordance with the provisions of Section 6.07 hereof and shall fail to resign after written request therefor by the City or by any Owner who has been a bona fide Owner of a Certificate for at least six months, (2) the Trustee shall become incapable of acting, or shall be adjudged bankrupt or insolvent, or a receiver of the Trustee or substantially all of its property shall be appointed, or any public officer shall take charge or control of the Trustee or substantially all of its property or affairs for the purpose of rehabilitation, conservation or liquidation, or (3) at such time as there is no Event of Default hereunder, the Corporation shall determine to remove the Trustee then, in any such case, the City, with the written approval of the Corporation {which approval shall not be unreasonably withheld), may remove the Trustee and appoint a successor trustee by an instrument in writing executed by an Authorized City Representative, or any such Owner may, on behalf of himself or herself and all others similarly situated, petition any court of competent jurisdiction for the removal of the Trustee and the appointment of a successor trustee. Such court may thereupon, after such notice, if any, as it may deem proper and prescribe, remove the Trustee and appoint a successor trustee. (c) The Owners of Outstanding Certificates representing a majority in aggregate Principal Component may at any time remove the Trustee and appoint a successor trustee by an instrument or concurrent instruments in writing signed by such Owners. (d) Any resignation or removal of the Trustee and appointment of a successor trustee pursuant to any of the provisions of this Section 6.08 shall become effective upon acceptance of appointment by the successor trustee as provided in Section 6.09 hereof. SECTION 6.09. Acceptance of Trust by Successor Trustee. Any successor trustee appointed as provided in Section 6.08 hereof shall execute, acknowledge and deliver to the Corporation, the City and to its predecessor trustee an instrument accepting such appointment hereunder, and thereupon the resignation or removal of the predecessor trustee shall become effective and such successor trustee, without any further act, deed or conveyance, shall become vested with all the rights, powers, trusts, duties and obligations of its predecessor in the trusts hereunder, with like effect as if originally named as Trustee herein; but, nevertheless, on the written request of the Corporation executed by an Authorized Corporation Representative or of the City executed by an Authorized B:\TRSTAGR6.DOC 32 City Representative or on the request of the successor trustee, the trustee ceasing to act shall execute and deliver an instrument transferring to such successor trustee, upon the trusts herein expressed, all the rights, powers and trusts of the trustee so ceasing to act. Upon request of any such successor trustee, the Corporation and the City shall execute any and all instruments in writing necessary or desirable for more fully and certainly vesting in and confirming to such successor trustee all such rights, powers and duties. No successor trustee shall accept appointment as provided in this Section 6.09 unless at the time of such acceptance such successor trustee shall be eligible under the provisions of Section 6.07 hereof. Upon acceptance of appointment by a successor trustee as provided in this Section 6.09, notice of the succession of such trustee to the trusts hereunder shall be published at least once in an Authorized Newspaper. If the Corporation or the City fails to publish such notice -within ten (10) days after acceptance of appointment by the successor trustee, the successor trustee shall cause such notice to be published at the expense of the City. Notice of the succession of such Trustee shall also be given by the successor trustee by first class mail to each Rating Agency having a rating in effect for the Certificates. BECTIO14 6.10. Merger or Consolidation of Trustee. Any corporation into which the Trustee may be merged or with which it may be consolidated, or any corporation resulting from any merger or consolidation to which the Trustee shall be a party, or any corporation succeeding to the business of the Trustee, shall be the successor of the Trustee hereunder without the execution or filing of any paper or any further act on the part of any of the parties hereto, anything herein to the contrary notwithstanding, provided that such successor trustee shall be eligible under the provisions of Section 6.07 hereof. SECTION 6.11. Obligations of Trustee. Upon payment in full of all Certificates within the meaning of Section 7.01 hereof, the Trustee shall execute any certificate which the Corporation or the City may reasonably request to evidence payment in full under the terms of the Installment Purchase Agreement. SECTION 6.12. Paying Agent for Certificates. The Trustee may appoint a Paying Agent for the Certificates, with the prior consent of the City, which shall be a bank or trust company duly organized under the laws of the United States or any state or territory thereof, having a capital stock and surplus aggregating at least $10,000,000, and willing and able to accept the office on reasonable and customary terms and authorized by law to perform all the duties imposed by it by this Trust Agreement. B:\TRSTAGR6.DDC 33 The Paying Agent shall perform such duties and only such duties as are specifically, authorized by the Trustee and in exercising such duties shall be entitled to the immunities and standard of care applicable to the Trustee prior to an Event of Default and after the curing of an Event of Default. The City covenants to cause the Paying Agent to be paid from time to time, and the Paying Agent shall be entitled to, reasonable compensation for all services rendered by it pursuant to the agreement entered into between the City and the Paying Agent, subject to the provisions of Section 6.06 hereof, in the exercise and performance of any of the powers and duties hereunder of the Paying Agent, which compensation shall not be limited by any provision of law in regard to the compensation of a trustee of an express trust, and the City will cause the Paying Agent to be paid or reimbursed, upon request of the Paying Agent for all expenses and disbursements incurred or made by the Paying Agent in accordance with any of the provisions of this Trust Agreement (including the reasonable compensation and the expenses and _. disbursements of its Counsel and of all persons not regularly in its employ) except any such expense or disbursement as may arise from its own negligence or willful misconduct. The City also covenants to indemnify the Paying Agent for, and to hold it harmless against, any loss, liability, expense or advance incurred or made without negligence or willful misconduct on the part of the Paying Agent, arising out of or in connection with the acceptance or administration of this trust, including the costs and expenses of defending itself against any claim of liability in the premises. SECTION 6.13. Resignation or Removal of Paying Agent; Appointment of Successor. Any Paying Agent may at any time resign and be discharged of the duties and obligations created by this Trust Agreement by giving at least sixty (60) days written notice to the Trustee and the City. Any Paying Agent may be removed at any time by an instrument filed with such Paying Agent and the Trustee. Any successor Paying Agent shall be appointed by the City, with the approval of the Corporation, and shall be a bank or trust company duly organized under the laws of the United States or any state or territory thereof, having a capital stock and surplus aggregating at least $10,000,000, and willing and able to accept the office on reasonable and customary terms and authorized by law to perform all the duties imposed upon it by this Trust Agreement. In the event of the resignation or removal of any Paying Agent, such Paying Agent shall pay over, assign and deliver any moneys held by it as Paying Agent to its successor, or if there is no successor, to the Trustee. In the event that for any reason there shall be a vacancy in the office of any Paying Agent, the Trustee shall act as such Paying Agent. B:\TRSTAGR6.DDC 34 ARTICLE VII DEFEASANCE SECTION 7.01. Certificates Deemed Paid; Discharge of Trust Agreement. The Principal Components and Interest Components with respect to any Certificate will be deemed paid for all purposes of this Trust Agreement when (a) Payment of the Principal Component and Interest Component with respect to such Certificate to the due date of such Principal Component and Interest Component (whether at maturity, upon prepayment or otherwise) either has been (1) made in accordance with the terms of the Certificates or (2) provided for by depositing with the Trustee (i) moneys sufficient to make such payment and/or (ii) to the extent permitted by law, Government Obligations maturing as to principal and interest in such amounts and at such times as will, together with any moneys held by the Trustee for such purpose, assure the availability of sufficient moneys to make such payment and any applicable premium thereon; and (b) All compensation and expenses of the Trustee and the Paying Agent, pertaining to each Certificate in respect of which such payment or deposit is made, have been paid or provided for to the Trustee and the Paying Agent's satisfaction. When the Principal Components and Interest Components with respect to a Certificate are deemed paid, such Certificate will no longer be secured by or entitled to the benefits of this Trust Agreement, except for payment from the sources specified in Section 7.01(a) and it may be transferred, exchanged, registered or replaced as provided in Article III hereof. To assure compliance with clause (2) of Section 7.01(a) hereof, if applicable, the City shall deliver to the Trustee an opinion or report of an independent certified public accountant confirming the availability of sufficient moneys as described therein. The Trustee may conclusively rely upon such opinion or report. Notwithstanding the foregoing, no deposit under clause (2) of Section 7.01(a) shall be deemed a payment of the Principal Components or Interest Components with respect to the Certificates until (1) (a) in the case of any such Certificates that are to be prepaid on any date prior to their maturity, the City shall have given to the Trustee in form satisfactory to the Trustee irrevocable instructions to mail notice of prepayment of such Certificates in accordance with Section 4.03 hereof and (b) in the event such Certificates are not by their terms subject to prepayment within the next succeeding sixty (60) days, the City shall have given the Trustee, in form satisfactory to the Trustee, irrevocable instructions to mail a notice to the Owners of such B:\TRSTAGR6.DOC 35 Certificates that the deposit required by Section 7.01 (a)(2) above has been made with the Trustee and that the Principal Components or Interest Components with respect to the Certificates are deemed to have been paid under this Section 7.01 and stating the maturity or prepayment date upon which moneys are to be available for the payment of the Principal Components of and prepayment premiums, if any, due with respect to such Certificates, or (2) the maturity of the Principal Component represented by the Certificate. Any notice given under clause (1) of this paragraph with respect to Principal Components constituting fewer than all Principal Components of a maturity shall specify the letter and number or other distinguishing mark of each such Certificate representing Principal Components to be paid. When all Outstanding Certificates are deemed paid under the foregoing provisions of this Section 7.01, and the requirements of Section 6.4 of the Installment Purchase Agreement have been met, the Trustee will upon request of the City acknowledge the discharge of the Corporation's and City's obligations under this Trust Agreement and the Certificates except for obligations under (i) Article III hereof in respect of the transfer, exchange, registration and replacement of Certificates, (ii) Section 9.05 hereof and (iii) Section 6.06 hereof. SECTION 7.02. Application of Trust Money. The Trustee shall hold in trust money or direct obligations of (including obligations issued or held in book entry form on the books of) the Department of the Treasury of the United States of America deposited with it pursuant to Section 7.01 and shall apply the deposited money and the money from such direct obligations in accordance with this Trust Agreement only to the payment of the Principal Components, premium, if any, and Interest Components with respect to the Certificates for which the deposit has been made. ARTICLE VIII AMENDMENTS SECTION 8.01. Mailing. Any provision in this Article VIII for the mailing of a notice or other paper to Owners shall be fully complied with if it is mailed postage prepaid only to each Owner of Certificates then Outstanding at his or her address appearing upon the registration books of.the Trustee. SECTION 8.02. Powers of Amendment. This Trust Agreement and the rights and obligations provided hereby may be modified or amended at any time by a Supplemental Trust Agreement, entered into among the Corporation, the City and the Trustee without the consent of any Owners but only (1) to cure any ambiguity, supply any omission, or cure or correct any defect or inconsistent provision in this Trust Agreement, (2) to insert such provisions clarifying matters or questions arising under this Trust Agreement as are R:\TRSTAGR6.D0C - 3 6 necessary or desirable and are not contrary to or inconsistent with this Trust Agreement as theretofore in effect, (3) if, in the opinion of Counsel, such amendment or modification does not materially adversely affect the rights of the Owners of the Certificates or (4) to provide for the preparation and execution by the Trustee of additional Certificates permitted by Section 8.06 hereof. Any other modification or amendment of this Trust Agreement and of the rights and obligations of the City and of the Owners of the Certificates hereunder, in any particular, may be made by a Supplemental Trust Agreement, entered into among the Trustee, the Corporation and the City and with the written consent, given as provided in Section 8.03 hereof, of the Owners of Outstanding Certificates representing at least a majority of the aggregate unpaid Principal Component at the time such consent is given; provided, however, that if any such modification or amendment will, by its terms, not take effect so long as any Certificates of any specified maturity remain Outstanding, the consent of the Owners of such Certificates shall not be required and such Certificates shall not be deemed to be Outstanding for the purpose of any calculation of Outstanding Certificates under this Section 8.02. No such modification or amendment shall permit a change in the terms of prepayment or maturity of the Principal Component represented by any Outstanding Certificates or of any Interest Component represented thereby or a reduction in the Principal Component or the Prepayment Price represented thereby or in the rate of interest represented thereby without the consent of the Owner of such Certificate, or shall reduce the percentages or otherwise affect the classes of Certificates the consent of the Owners of which is required to effect any such modification or amendment, or shall change or modify any of the rights or obligations of the Trustee without its written assent thereto. Such amendment shall not be effective unless and until there shall have been filed with the Trustee an opinion of Counsel stating that such Supplemental Trust Agreement has been duly and lawfully entered into by the parties thereto and filed with the Corporation, the City and the Trustee in accordance with the provisions of this Trust Agreement, is authorized or permitted by this Trust Agreement, and is valid and binding upon the parties thereto in accordance with its terms. Notice of any modification or amendment of this Trust Agreement, together with a copy of such modification or amendment, shall be given by first class mail to each Rating Agency having a rating in effect for the Certificates. SECTION 8.03. Consent of Owners. Whenever a modification or amendment requires the consent of the Owners, then the Trustee, the Corporation and the City may at any time enter into a Supplemental Trust Agreement making a modification or amendment permitted by the provisions of Section 8.02 hereof to take effect when and as provided in this Section 8.03. A copy of such Supplemental Trust Agreement (or brief summary thereof or reference B:\TRSTAGR6.D0C 37 thereto in form approved by the Trustee), together with a request to Owners for their consent thereto in form satisfactory to the Trustee and the City, shall be mailed by the Trustee to the owners (but failure to mail such copy and request shall not affect the validity of the Supplemental Trust Agreement when consented to as in this Section 8.03 provided). Such Supplemental Trust Agreement shall not be effective unless and until (a) there shall have been filed with the Trustee (i) the written consents of Owners of the percentages of Outstanding Certificates specified in Section 8.02 hereof and (ii) an opinion of Counsel stating that such Supplemental Trust Agreement has been duly and lawfully entered into by the parties thereto and filed with the Corporation, the City and the Trustee in accordance with the provisions of this Trust Agreement, is authorized or permitted by this Trust Agreement, and is valid and binding upon the parties thereto in accordance with its terms. Each such consent shall be effective only if accompanied by proof of the Owner, at the date of such consent, of the Certificates with respect to which such consent is given, which proof shall be such as is permitted by Section 11.02 hereof. ---A certificate or certificates executed by the Trustee and filed with the Corporation and the City stating that it has examined such proof and that such proof is sufficient in accordance with Section 11.02 hereof shall be conclusive that the consents have been given by the Owners of the Certificates described in such certificate or certificates of the Trustee. Any such consent shall be binding upon the Owner of the Certificates giving such consent and, anything in Section 11.02 hereof to the contrary notwithstanding, upon any subsequent Owner of such Certificates and of any Certificates issued in exchange therefor (whether or not such subsequent Owner thereof has notice thereof). At any time after the Owners of the required percentages of Certificates shall have filed their consents to the Supplemental Trust Agreement,. the Trustee shall make and file with the Corporation and the City a written statement that the owners of such required percentages of Certificates have filed such consents. Such written statements shall be conclusive that such consents have been so filed. At any time thereafter, a - notice stating in substance that the Supplemental Trust Agreement (which may be referred to as a Supplemental Trust Agreement entered into by the parties thereto on a stated date, a copy of which is on file with the Trustee) has been consented to by the owners of the required percentages of Certificates and will be effective as provided in this Section 8.03, shall be given to Owners by the Trustee at the expense of the City by mailing such notice to Owners (but failure to mail such notice shall not prevent such Supplemental Trust Agreement from becoming effective and binding as in this Section 8.03 provided). The Trustee shall file with the Corporation and the City proof of the mailing of such notice. A record, consisting of the certificates or statements required or permitted by this Section 8.03 to be made by the Trustee, shall be proof of the matters therein stated. Such Supplemental Trust Agreement making such amendment or modification shall be deemed conclusively binding upon B:\TRSTAGR6.DOC 3 8 the Corporation, the City and the Trustee and the Owners of all Certificates at the expiration of forty (40) days after the filing by the Trustee of the proof of the mailing of such last mentioned notice, except in the event of a final decree of a court of competent jurisdiction setting aside such Supplemental Trust Agreement in a legal action or equitable proceeding for such purpose commenced within such forty (40) day period; provided, however, that the Trustee, the Corporation and the City during such forty (40) day period and any such further period during which any such action or proceeding may be pending shall be entitled in their absolute discretion to take such action, or to refrain from taking such action, with respect to such Supplemental Trust Agreement as they may deem expedient. SECTION 8.04. Exclusion of Certificates. Certificates owned or held by or for the account of the City or the Corporation shall not be deemed Outstanding for the purpose of consent or other action or any calculation of Outstanding Certificates provided for in this Article VIII, and the City and the Corporation shall not be entitled with respect to such Certificates to give any consent or take any other action provided for in this Article VIII. At the time of any consent or other action taken under this Article VIII, the City shall furnish the Trustee a certificate of an Authorized City Representative and an Authorized Corporation Representative, upon which the Trustee may rely, describing all Certificates so to be excluded. SECTION 8.05. Notation on Certificates. Certificates executed and delivered after the effective date of any action taken as in this Article VIII provided may, and if the Trustee so determines shall, bear a notation by endorsement or otherwise in form approved by the City and the Trustee as to such action, and in that case upon demand of the Owner of any Certificate Outstanding at such effective date and presentation of his or her Certificate for the purpose at the Corporate Trust Office of the Trustee or upon any transfer or exchange of any Certificate Outstanding at such effective date, -suitable notation shall be made on such Certificate or upon any Certificates executed and delivered upon any such transfer or exchange by the Trustee as to any such action. If the City shall so determine, new Certificates so modified as in the opinion of the City to conform to such action shall be prepared by the City and executed and delivered by the Trustee, and upon demand of the Owner of any Certificate then Outstanding shall be exchanged, without cost to such Owner, for Certificates of the same maturity and principal amount then Outstanding, upon surrender of such Certificates. SECTION 8.06. Additional Certificates. Subsequent to the execution and delivery by the Trustee of the 1993 Certificates, the Trustee shall, upon written request or requests of an Authorized City Representative and of an Authorized Corporation Representative, execute and deliver from time to time one or more 8:\TRSTAGR6.DOC 3 9 Series of additional Certificates representing such aggregate Principal Components as may be set forth in such written request or requests, provided that the City shall have delivered to the Trustee a certificate of an Authorized City Representative certifying as to the compliance by the City with all of the conditions set forth in Section 6.6 of the Installment Purchase Agreement which are hereby made conditions precedent to the preparation, execution and delivery of such additional Certificates and compliance with each of the following conditions: (a) The parties to this Trust Agreement shall have executed a Supplemental Trust Agreement setting forth the terms and provisions of such additional Certificates, including the establishment of such funds and accounts, separate and apart from the funds and accounts established hereunder for the 1993 Certificates, as shall be necessary or appropriate; (b) The Principal Components and Interest Components with respect to such additional Certificates and any premium payable upon prepayment of- such additional Certificates shall be payable only on Purchase Payment Dates applicable to the 1993 Certificates; (c) The Installment Purchase Agreement shall have been amended by the parties thereto if necessary to (i) increase or _. adjust the Purchase Payments due and payable on each Purchase Payment Date to an amount sufficient to pay the Principal Components, premium (if any) and Interest Components payable with respect to all Outstanding Certificates, including all additional Certificates as and when such Principal Components and Interest Components mature or become due and payable (except to the extent such Principal Components, premium (if any) and Interest Components may be payable out of moneys then in the Reserve Account or otherwise on deposit with the Trustee in accordance with this Trust Agreement), (ii) amend the definition of "Project", if necessary, to include as part of the Project all additions, betterments, extensions, improvements or replacements, or such other real or personal property (whether or not located upon the Project as such Project is constituted as of the date of this Trust Agreement), to be financed, acquired or constructed by the preparation, execution and delivery of such additional Certificates, and (iii) make such other revisions to the Installment Purchase Agreement as are necessitated by the execution and delivery _of such additional Certificates (provided, however, that such other revisions shall not prejudice the rights of the Owners of Outstanding Certificates to payments under the terms of this Trust Agreement); (d) There shall have been delivered to the Trustee a counterpart of the amendments required by Section 8.06(c); (e) The Trustee shall have received a certificate of an Authorized Corporation Representative that there exists on the part of the Corporation no Event of Default; B:\TRSTAGR6.DOC 4 0 (f) The Trustee shall have received a certificate of an Authorized City Representative that there exists on the part of the City no Event of Default; (g) The Trustee shall have received an opinion of special Counsel stating to the effect that (i) said Supplemental Trust Agreement and said amendments to the Installment Purchase Agreement comply in all respects with the requirements of this Section 8.06, (ii) said Supplemental Trust Agreement and said amendments to the Installment Purchase Agreement have been duly authorized, executed and delivered by each of the respective parties thereto (provided that said opinion of Counsel, in rendering the opinions set forth in this clause (ii), shall be entitled to rely upon one or more other opinions of Counsel, including counsel to any of the respective parties to said Supplemental Trust Agreement or said Installment Purchase Agreement), (iii) assuming that no Event of Default has occurred and is continuing, this Trust Agreement, as amended by said Supplemental Trust Agreement, and the Installment Purchase Agreement, as amended by the respective amendments thereto, constitute the legal, valid and binding obligations of the respective parties thereto, enforceable against said parties in accordance with their respective terms (except to the extent that enforcement thereof may be limited by bankruptcy, insolvency, moratorium, debt adjustment or other laws affecting creditors' rights generally, and except to the extent that enforcement thereof may be limited by general principles of equity, regardless of whether enforcement is sought in a legal or equitable proceeding) and (iv) the execution of such Supplemental Trust Agreement and said amendments to the Installment Purchase Agreement, and performance by the parties thereunder, does not adversely affect the exclusion from gross income for Federal income tax purposes or the exemption under State law of the Interest Components with respect to any Certificates, including additional Certificates, theretofore prepared, executed and delivered; and (h) Such other conditions shall have been satisfied, and such other instruments shall have been duly executed and delivered to the Trustee, as the Trustee, the City or the Corporation shall have reasonably requested. Upon delivery to the Trustee of the foregoing instruments, the Trustee shall cause to be executed and delivered additional Certificates representing the aggregate Principal Components specified in such Supplemental Trust Agreement, and such additional Certificates shall be equally and ratably secured with all Certificates, including any additional Certificates, theretofore prepared, executed and delivered, all without preference, priority or distinction (other than with respect to maturity, payment, prepayment or sinking fund payments (if any)) of any one Certificate, including additional Certificates, over any other; provided, however, that no provision of this Trust Agreement shall require the City to consent to or otherwise permit the 8:\TRSTAGR6.DW 4 1 preparation, execution and delivery of additional Certificates, it being understood and agreed that any such consent or other action of the City to permit the preparation, execution and delivery of additional Certificates, or lack thereof, shall be in the sole discretion of the City. ARTICLE IS COVENANTS SECTION 9.01. Power to Enter into Trust Agreement, Installment Purchase Agreement and Assignment Agreement. The Corporation and the City each covenant that each will observe and faithfully perform at all times all of its covenants, undertakings and agreements contained in this Trust Agreement and the Installment Purchase Agreement. The Corporation and the City each represent and covenant that each is duly authorized to enter into this Trust Agreement and the Installment Purchase Agreement and the Corporation represents and covenants that it is duly authorized to enter into the Assignment Agreement; that all action on the part of each for the delivery, of Certificates and the execution and delivery of this Trust Agreement has been duly and effectively taken. SECTION 9.02. Valid and Binding Obligations. The obligation of the City to make Purchase Payments under and pursuant to the Installment Purchase Agreement and the provisions of this Trust Agreement shall be legal, valid and binding obligations of the City. The Corporation shall at all times, to the extent permitted by law, defend, preserve and protect said obligations and assignment of all its interest in the Installment Purchase Agreement, and all the rights of the Owners under this Trust Agreement against all claims and demands made thereon. SECTION 9.03. Extension of Payment. Neither the Corporation, the City nor the Trustee shall directly or indirectly extend or assent to the extension of the payment dates of any of the Purchase Payments or the maturity of the Certificates representing an interest therein, or the time of payment of any claims for interest by the Owners of Certificates. SECTION 9.04. Encumbrances. The Corporation and the City each covenant that each will not create or suffer to be created any lien; encumbrance or charge upon the Project or any improvements thereto except as permitted herein and in the Installment Purchase Agreement. SECTION 9.05. Tax Covenants. (a) The Corporation and the City each covenant that, in order to maintain the exclusion from gross income for federal income tax purposes of the Interest B'\TRSTAGR6.DDC 4 2 Components of the Purchase Payments, and for no other purpose, each will satisfy, or take such actions as may be necessary to cause to be satisfied, each provision of the Code necessary to maintain such exclusion. In furtherance of this covenant, the Corporation and the City each covenant to comply with the Tax Certificate as a source of guidance with the requirements of the Code. (b) The Corporation and the City each covenant that no part of the proceeds of the Certificates shall be used, directly or indirectly, to acquire any "investment property", as defined in Section 148 of the Code, and it shall not take or permit to be taken any other action or actions, which would cause the obligation represented by the Installment Purchase Agreement to be an "arbitrage bond" within the meaning of Section 148 of the Code, as in effect from time to time, or under applicable Treasury regulations promulgated thereunder. In order to assure compliance with the rebate requirements of Section 148 of the Code, the Corporation and the City each further covenant that it will pay or cause to be paid to the United States Treasury Department the amounts necessary to satisfy the requirements of Section 148(f) of the Code, as required in the Tax Certificate, and that it will establish such accounting procedures as are necessary to adequately determine, account for and pay over any such amount or amounts required to be paid to the United States in a manner consistent with the requirements of Section 148 of the Code, such covenant to survive the termination of this Trust Agreement pursuant to Section 7.01 hereof. (c) The Corporation and the City each covenant that it will not take any action or omit to take any action, which action or omission, if reasonably expected on the date of initial execution and delivery of the Certificates, would result in a loss of exclusion from gross income for purposes of federal income taxation, under Section 103(a) of the Code, of Interest Components paid by the City and received by the Owners of the Certificates. (d) The Corporation and the City each covenant that it will not use or permit the use of the Project by any person (other than the City or other state or local governmental unit) in such manner or to such extent as would result in a loss of exclusion of the Interest Components of Purchase Payments from gross income for Federal income tax purposes under Section 103(a) of the Code. (e) Notwithstanding any provision of this Trust Agreement, and except as provided below, the Corporation and the City each covenant that none of the moneys contained in any of the funds or accounts created pursuant to this Trust Agreement shall be: (i) used in making loans guaranteed by the United States (or any agency or instrumentality thereof), (ii) invested directly or indirectly in a deposit or account insured by the Federal Deposit Insurance Corporation, National Credit Union Administration or any other similar Federally chartered corporation, or (iii) otherwise B:\TRSTAGR6.DOC 43 - invested directly or indirectly in obligations guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof); provided, however, that the above restrictions do not apply to: (i) the investment of moneys held in the Purchase Payment Account or any other "bona fide debt service fund" as defined in the Tax Certificate, and in the Reserve Account, (ii) to investments in direct obligations of the United States Treasury, (iii) to investments in obligations guaranteed by the Federal National Mortgage Association, Government National Mortgage Association or the Federal Home Loan Mortgage Corporation, (iv) to investments permitted under regulations issued pursuant to Section 149 (b)(3)(B) of the Code, or (v) to such other investments as, in the opinion of Special Counsel, are investments permitted under this Trust Agreement which do not jeopardize the exclusion from gross income for Federal. income tax purposes of the Interest Components with respect to the Certificates. SECTION 9.06. Account Records and Statements. The Trustee shall at all times keep proper accounting records and statements in which complete and correct entries shall be made of all transactions relating to the receipt, deposit and disbursement of the proceeds of the Certificates, the Purchase Payments, and all funds and accounts established pursuant to this Trust Agreement. Such accounting records shall be available for inspection by the _ Corporation, the City and any Owner of Outstanding Certificates representing at least twenty-five percent (25%) of the aggregate unpaid Principal Component or his or her agent duly authorized in writing at reasonable hours and under reasonable conditions. Not later than the 15th day of each month commencing on May 15, 1993 and continuing so long as any Certificates remain Outstanding, the Trustee will furnish to the City and any Owner of Outstanding Certificates representing at least twenty-five percent (25%) of the aggregate unpaid Principal Component who may so request (at the expense of such Owner) a complete statement covering the receipts, deposits and disbursements of the proceeds of the Certificates, the Purchase Payments, and all funds and accounts established pursuant to this Trust Agreement -for the preceding month. SECTION 9.07. Recording and Filing. The City shall file, re¢e6Zdregister, renew, refile and all documents as may be required by law in order to maintain the Installment Purchase Agreement and this Trust Agreement, in such manner, at such times and in such places as required and to the extent permitted by law in order to fully perfect, preserve and protect the rights and interests of the Owners. SECTION 9.08. Amendment of Installment Purchase Agreement. The Corporation shall not consent to the amendment, alteration or modification, in whole or in part, of the Installment Purchase Agreement except (a) to the extent such amendment, alteration or modification shall cure an ambiguity, supply an omission, or cure or correct a defect or inconsistent provision B ATRSTAGR6.DDC 44 therein, (b) to the extent such amendment, alteration or modification shall insert such provisions clarifying matters or questions arising thereunder as are necessary or desirable and are not contrary to or inconsistent with the Trust Agreement, (c) if, in the opinion of Counsel, such amendment, alteration or modification does not materially adversely affect the rights of the Owners of the Certificates, (d) as may be necessary in connection with the issuance of additional Certificates pursuant to the provisions of this Trust Agreement, or (e) with the written consent of the Owners of a majority in aggregate Principal Component of the Certificates then outstanding, exclusive of Certificates owned by the Corporation or the City. Any such written consent shall be obtained in the manner provided in Article VIII hereof for amendments to the Trust Agreement. No such amendment, alteration or modification shall be effective unless and until there shall have been filed with the Trustee an opinion of Counsel stating that such amendment, alteration or modification has been duly and lawfully entered into by the parties thereto, is authorized or permitted by this Trust Agreement and is valid and binding upon the parties thereto in accordance with its terms. For purposes of this Trust Agreement, no change or revision of Exhibit A made pursuant to Section 4.1(a) of the Installment Purchase Agreement shall constitute an amendment, alteration or modification of the Installment Purchase Agreement. SECTION 9.09. Enforcement. The Trustee shall promptly collect all amounts due pursuant to the Installment Purchase Agreement subject at all times to Article VI hereof, and upon default hereunder, shall enforce, take all steps, actions and proceedings reasonably necessary to protect and preserve all rights and interests of the Trustee and the Owners under the Installment Purchase Agreement and this Trust Agreement as provided in Article X. SECTION 9.10. Further Assurances. The Corporation and the City each covenant that each shall promptly execute and deliver or cause to be executed and delivered all other and further assurances, documents or instruments and promptly do or cause to be done all such other and further things as may be necessary or reasonably required in order to carry out the purposes and intentions of this Trust Agreement and for preserving and protecting the rights and interests of the Owners. ARTICLE X EVENTS OF DEFAULT AND REMEDIES SECTION 10.01. Events of Default. The existence of an Event of Default under the Installment Purchase Agreement is hereby declared an Event of Default under this Trust Agreement. SECTION 10.02. Institution of Legal Proceedings by Trustee. If an Event of Default shall happen and be continuing, 8:\TRSTAGR6.D0C 4 5 r the Trustee in its discretion may, and upon the written request of the owners of outstanding Certificates representing not less than twenty-five percent (25%) of the aggregate unpaid Principal Component, and upon being indemnified to its satisfaction therefor, shall, proceed to protect or enforce its rights or the rights of the owners of Certificates under this Trust Agreement by a suit in equity or action at law, either for the specific performance of any covenant or agreement contained herein or in the Installment Purchase Agreement, or in aid of the execution of any power herein granted, or for the enforcement of any other appropriate legal or equitable remedy as the Trustee shall deem most effectual in support of any of its rights or duties hereunder. SECTION 10.03. Distribution of Proceeds of Remedies. All moneys received by the Trustee pursuant to remedies taken under this Trust Agreement or held in any fund or account established by this Trust Agreement are to be applied, after the payment of all fees and expenses of the Trustee, as follows, in the following order: First: To the payment to the persons entitled thereto of all Interest Components then due in the order of the due date thereof, and, if the amount available shall not be sufficient to pay in full any Interest Component maturing on the same date, then to the payment thereof ratably, according to the amounts due thereon, to the persons entitled thereto; Second: To the payment to the persons entitled thereto of the unpaid Principal Component with respect to any Certificates which shall have become due, whether at maturity or by call for prepayment, in the order of their due dates, with interest on the overdue Principal Component at the rate borne by the respective Certificates, and, if the amount available shall not be sufficient to pay in full all the Certificates due on any date, then to the payment thereof ratably, according to the amounts of Principal Component due on such date to the persons entitled thereto, without any discrimination or preference; and Third: If there shall exist any remainder after the foregoing payments, such remainder shall be paid to the City. SECTION 10.04. suit By Owners. No Owner has any right, remedy or power to institute any suit, action or proceeding for the enforcement of this Trust Agreement, the Installment Purchase Agreement or the Certificates, for the execution of any trust, or exercise of any other right, remedy or power under such agreements or instruments, unless (a) there has occurred and is continuing an Event of Default of which the Trustee has been notified; (b) the Owners of Outstanding Certificates representing at least twenty-five percent (25%) of the aggregate unpaid Principal Component shall have made a written request to the Trustee and shall have afforded the Trustee a reasonable opportunity to proceed 8:\TRSTAGR6.DDC 46 to exercise the rights, remedies and powers or to institute the suit, action or proceeding in its own name, and shall have offered indemnification to the Trustee as provided in this Trust Agreement; and (c) the Trustee shall have failed or refused thereafter to exercise the rights, remedies and powers or to institute the suit, action or proceeding in its own name. SECTION 10.05. Effect of Delay or Omission to Pursue Remedy. No delay or omission of the Trustee or of any Owner to exercise any right or power arising from any Event of Default shall impair any such right or power or shall be construed to be a waiver of any such Event of Default or acquiescence therein; and every power and remedy given by this Article X to the Trustee or to the Owners may be exercised from time to time, and as often as shall be deemed expedient. In case the Trustee shall have proceeded to enforce any right under this Trust Agreement and such proceedings shall have been discontinued or abandoned because of waiver or for any other reasons, or shall have been determined adversely to the Trustee, then and in every such case the Trustee and the Owners, severally and respectively, shall be restored to their former positions and rights hereunder; and all remedies, rights and powers of the Trustee and the Owners shall continue as though no such proceedings had been taken. SECTION 10.06. Remedies Cumulative. No remedy herein conferred upon or reserved to the Trustee or to any Owner is intended to be exclusive of any other remedy, but each and every such remedy shall be cumulative and shall be in addition to every other remedy given hereunder or now or hereafter existing in law or in equity or by statute or otherwise; and the exercise by the Trustee or by any Owner or any remedy hereunder shall not limit or impair the exercise of any other remedy given hereunder. ARTICLE XI MISCELLANEOUS SECTION 11.01. Payment of Purchase Payments; Unclaimed Moneys. (a) If and when the Principal Components and Interest Components with respect to the Certificates delivered pursuant hereto shall become due and payable in accordance with their terms, or shall become subject to prepayment and have been called for prepayment in accordance with Section 4.01 hereof, all amounts payable to the Trustee and the Paying Agent have been paid and the whole amount of the Principal Component and Interest Component due and payable with respect to all of the Certificates shall have been paid or set aside for payment with the Trustee or a Paying Agent, then and in that case, the right, title and interest of the Trustee under this Trust Agreement shall thereupon cease, terminate and become void, and the Trustee shall convey all property, other than money held by the Trustee or Paying Agent for the payment of unpresented Certificates, and interest therein which it obtained B:\TRSTAGR6.D0C 47 under this Trust Agreement free and clear of all liens thereon which the Trustee may have. (b) Anything in this Trust Agreement to the contrary notwithstanding, any moneys held by the Trustee in trust for the payment and discharge of the Principal Component, Prepayment Price, if applicable, and Interest Component with respect to any of the Certificates which remain unclaimed for one (1) year after the date when the payment shall have become due and payable, shall, at the Written Request of the City be repaid by the Trustee to the City, as its absolute property and free from trust, and the Trustee shall thereupon be released and discharged with respect thereto and the Owners shall look only to the City for the payment of such Certificates; provided, however, that before making any such payment to the City, the Trustee shall, at the expense of the City, cause to be published at least twice, at an interval of not less than seven (7) days between publication, in an Authorized Newspaper, a notice that said moneys remain unclaimed and that, after a date named in said notice, which date shall not be less than thirty (30) days after the date of the first publication of such notice, the balance of such moneys then unclaimed will be returned to the City. SECTION 11.02. Evidence of Signatures of Owners and Ownership of Certificates. (a) Any request, consent, revocation of consent or other instrument which this Trust Agreement may require or permit to be signed and executed by the Owners may be in one or more instruments of similar tenor, and shall be signed or executed by such Owners in person or by their attorneys appointed in writing. Proof of the execution of any such instrument, or of an instrument appointing any such attorney shall be sufficient for any purpose of this Trust Agreement (except as otherwise therein expressly provided) if made in the following manner, or in any other manner satisfactory to the Trustee, which may nevertheless in its discretion require further or other proof in cases where it deems the same desirable: the fact and date of the execution by any Owner or his or her attorney of such instruments may be proved by a guarantee of the signature thereon by a bank or trust company or by the certificate of any notary public or other officer authorized to take acknowledgments of deeds, that the person signing such request or other instrument acknowledged to him or her the execution thereof, or by an affidavit of a witness of such execution, duly sworn to before such notary public or other officer. Where such execution is by an officer of a corporation or association or a member of a partnership, on behalf of such corporation, association or partnership, such signature guarantee, certificate or affidavit shall also constitute sufficient proof of his or her authority. (b) The ownership of Certificates and the amount, numbers and other identification, and date of holding the same shall be proved by the registration books. B:\TRSTAGR6.D0C 4 8 (C) Any request or consent by the owner of any Certificate shall bind all future Owners of such Certificate in respect of anything done or suffered to be done by the Corporation, the City or the Trustee in accordance therewith. SECTION 11.03. Moneys Held for Particular Certificates. The amounts held by the Trustee for the payment of the Interest Component, Principal Component or premium, if any, due on any date with respect to particular Certificates shall, on and after such date and pending such payment, be set aside on its books, held in trust by it for the Owners of the Certificates entitled thereto, and shall not be invested by the Trustee and the Trustee shall not be held liable for interest thereon. SECTION 11.04. Publication of Notice, Suspension of Publication. (a) Any publication to be made under the provisions of this. Trust Agreement in successive weeks or on successive dates may be made in each instance upon any Business Day of the week and need not be made in the same Authorized Newspaper for any or all of the successive publications but may be made in different Authorized Newspapers. (b) If, because of the temporary or permanent suspension of the publication or general circulation of one or more Authorized Newspapers, or for any other reason, it is impossible or impractical to publish any notice pursuant to this Trust Agreement in the manner herein provided, then such publication in lieu thereof as shall be made with the approval of the City shall constitute a sufficient publication of such notice. SECTION 11.05. Severability of Invalid Provisions. If any one or more of the covenants or agreements provided in this Trust Agreement on the part of the City or the Corporation to be performed should be contrary to law, then such covenant or covenants or agreement or agreements shall be deemed severable from the remaining covenants and agreements, and shall in no way affect the validity of the other provisions of this Trust Agreement. SECTION 11.06. Notices. Except as expressly set forth herein, all notices, certificates, requests or other communications (other than payments by the City) hereunder shall be in writing and shall be sufficiently given and shall be deemed given when delivered or mailed by first class mail, postage prepaid, to the parties at their respective places of business. All notices or other communications required by the provisions hereof required to be given by telephone, telex or other high-speed means of communication shall be given to the numbers indicated below. 8:\TRSTAGR6.DDC 49 With respect to the City, notices shall be directed to: Treasurer City of Tustin 15222 Del Amo Avenue Tustin, California 92680 With respect to the Corporation, notices shall be directed to: City of Tustin 15222 Del Amo Avenue Tustin, California 92680 Attn: Secretary, City of Tustin Water Corporation With respect to the Trustee, notices shall be directed to: Sank of America National Trust and Savings Association Corporate Trust Document Review #H23-80 333 South Hope Street 23rd Floor Los Angeles, California 90071 Any such notice, certificate, request or other communication given to the Corporation shall specify whether the same shall be retained by the Corporation and the length of time of such retention. Any of the foregoing persons may, by notice given under this Section 11.06, designate any further or different addresses, telephone numbers or telex numbers to which subsequent notices, certificates, requests or other communications shall be directed. SECTION 11.07. California Law. This Trust Agreement shall be construed and governed in accordance with the laws of the State of California. SECTION 11.08. Binding on Successors. This Trust Agreement shall be binding upon and inure to the benefit of the parties and their respective successors and assigns. SECTION 11.09. Headings. Headings preceding the text of the several Articles and Sections hereof, and the table of contents, are solely for convenience of reference and shall not constitute a part of this Trust Agreement or affect its meaning, construction or effect. SECTION 11.10. Execution in Counterparts. This Trust Agreement may be executed in several counterparts, each of which BATRSTAGR&DOC 50 shall be deemed an original, and all of which shall constitute but one and the same instrument. SECTION 11.11. Consent or approval of any party to this terms of this Trust Agreement, party shall not be unreasonably of Parties. Whenever the consent Trust Agreement is required by the the consent or approval of such withheld. ARTICLE %II CERTIFICATE FORM SECTION 12.01. Certificate Form. The 1993 Certificates to be issued under this Trust Agreement, the form of assignment and the provisions for registration are to be in substantially the following form, respectively, with necessary and appropriate variations, omissions and insertions as permitted or required by this Trust Agreement: B:\TRSTACR6.DOC 51 NO. WATER SYSTEM INTEREST RATE: REGISTERED OWNER: PRINCIPAL CITY OF TUSTIN REVENUE CERTIFICATE 1993 SERIES MATURITY DATE - OF PARTICIPATION CDB THIS IS TO CERTIFY that the registered owner (the "Owner") named above, or registered assigns, of this Certificate of Participation, one of an issue of the City of Tustin, Water System Revenue Certificates of Participation, 1993 Series (the 111993 Certificates") -in an aggregate initial amount of $11,500,000, is the Owner of a direct and proportionate interest in the right to receive certain Purchase Payments (the "Purchase Payments") to be made by the City of Tustin (the "City") pursuant to an Installment Purchase Agreement dated as of April 1, 1993 (the "Installment Purchase Agreement") between the City and the City of Tustin Water Corporation (the "Corporation"). The Owner of this 1993 Certificate is entitled to receive, subject to the terms of the Installment Purchase Agreement and any rights of prepayment as set forth in the Trust Agreement dated as of April 1, 1993 (the "Trust Agreement") among the Corporation, the City and Bank of America National Trust and Savings Association, as Trustee (the "Trustee") (i) upon surrender of this 1993 Certificate to the Trustee on the maturity date specified above or on the Prepayment Date, the principal component specified above, representing the Owner's proportionate share of the Purchase Payments designated and paid as principal (the "Principal Component"), due and payable on the maturity date specified above or on such Prepayment Date, and (ii) on each April 1 and October 1, commencing October 1, 1993, as set forth herein, the interest component, representing the Owner's proportionate share of each Purchase Payment designated and paid as interest due and payable (the "Interest Component") to and including the date of maturity or prepayment. Interest with respect to this 1993 Certificate will accrue from the April 1 or October 1 next preceding the date of execution thereof unless (i) it is executed on an April 1 or October 1, in which event interest will accrue from the date of execution hereof; (ii) it is executed on or prior to October 1, 1993, in which event interest will accrue from April 1, 1993, or (iii) it is executed after a Record Date and prior to the next succeeding Interest Component Payment Date, in which case 9:\TRSTAGR6.DOC 52 interest will accrue from the next succeeding Interest Component Payment Date; provided, however, that if, at the time of execution of this 1993 Certificate, interest is in default on Outstanding 1993 Certificates, the Trustee will establish a special record date for the payment of any interest in default under the Trust Agreement, and interest with respect to such 1993 Certificate will accrue from the date to which interest has previously been paid in full or made available for payment on such Outstanding 1993 Certificates. The Interest Component will be payable by check or draft mailed to the Owner of this 1993 Certificate at the address shown on the registration records maintained by the Trustee as of the Record Date. The Principal Component and prepayment premiums, if any, due with respect to this 1993 Certificate shall be payable by check or draft upon surrender thereof at the Corporate Trust Office of the Trustee. All capitalized undefined terms used herein which are defined in the Trust Agreement and the Installment Purchase Agreement shall have the meanings specified in the Trust Agreement and the Installment Purchase Agreement. REFERENCE IS HEREBY MADE TO THE FURTHER THIS 1993 CERTIFICATE SET FORTH ON THE REMAINING WHICH FURTHER PROVISIONS SHALL FOR ALL PURPOSES EFFECT AS IF SET FORTH HERE. 9:\TRSTAGR6.D0C 53 PROVISIONS OF PAGES HEREOF, HAVE THE SAME IN WITNESS WHEREOF, this 1993 Certificate has been executed by the manual signature of an authorized signatory of the Trustee on the date set forth below. BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION 35 as Trustee Dated: BY Authorized Signatory [Form of Back of 1993 Certificate] This 1993 Certificate has been executed by the Trustee pursuant to the terms of the Trust Agreement. Copies of the Trust Agreement and the Installment Purchase Agreement are on file at the Corporate Trust Office of the Trustee. Reference is made to the Trust Agreement and the Installment Purchase Agreement and to any and all amendments thereof and supplements thereto for a description of the covenants securing the 1993 Certificates, for the nature, extent and manner of enforcement of such covenants, for the rights and remedies of the Owners of the 1993 Certificates with respect thereto and for the other conditions and terms upon which the 1993 Certificates are executed and delivered thereunder. The 1993 Certificates, together with any additional Certificates, are payable from Gross Revenues in the Qualified Obligations Account and moneys held in certain funds and accounts established pursuant to the Trust Agreement, subject to the provisions of the Trust Agreement and the Installment Purchase Agreement permitting the disbursement thereof for or to the purposes and on the conditions and terms set forth therein. The Purchase Payments and all other payments with respect to Qualified Obligations shall be secured by a pledge, charge and lien upon the Gross Revenues in the Qualified Obligations Account and shall be paid from Gross Revenues in the Qualified Obligations Account unless otherwise paid from other sources of legally available funds. Purchase Payments and all other payments with respect to Qualified Obligations shall be equally secured by the Gross Revenues in the Qualified Obligations Account without priority for number or date. The Gross Revenues in the Qualified Obligations Account shall be held in trust by the Treasurer of the City for the benefit of the Owners of the 1993 Certificates and any other Qualified Obligations. The obligation of the City to make the Purchase Payments and to pay Additional Purchase Payments is absolute and unconditional, payable without any rights of set-off, recoupment, abatement or counterclaim the City might have against 0:\TRSTAGR6.DOC 54 the Corporation, the Trustee or any other party or parties, except that (i) the City will be obligated to make Purchase Payments and to pay Additional Purchase Payments solely from the Gross Revenues in the Qualified Obligations Account, and (ii) the obligation of the City to make Purchase Payments and to pay Additional Purchase Payments will not in any way be construed to be a debt of the City, or the State of California, or any political subdivision thereof, in contravention of any applicable constitutional or statutory limitation or requirement concerning the creation of indebtedness by the City, the State of California, or any political subdivision thereof, nor will anything contained in the Installment Purchase Agreement constitute a pledge of general revenues, funds or monies of the City or an obligation 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. The 1993 Certificates are authorized to be executed and delivered in the form of fully registered Certificates in the denomination of $5,000 or any integral multiple thereof upon the terms -and subject to the conditions set forth in the Trust Agreement. Subject to the conditions and terms of the Trust Agreement, upon payment of the charges, if any, provided in the Trust Agreement, 1993 Certificates may be exchanged for fully registered 1993 Certificates of the same aggregate Principal Component, tenor and maturity but of other authorized denominations at the Corporate Trust Office of the Trustee. The Interest Component represented by this 1993 Certificate will accrue at the rate set forth under "Interest Rate". The Interest Component will be computed on the basis of a 360 -day year of twelve 30 -day months. Interest with respect to each 1993 Certificate will accrue on any overdue principal at the same rate borne by the particular 1993 Certificate. The 1993 Certificates maturing on or after April 1, 2004 are subject to prepayment at the option of the City in whole at any time or in part on any Interest Component Payment Date in integral multiples of $5,000, on or after April 1, 2003, at the principal amount thereof together with any applicable premium and the related Interest Component due on the date fixed for such prepayment, from any source of funds, upon notice as provided in the Trust Agreement. The prepayment price (expressed as a percentage of the total principal amount prepaid) upon such prepayment is set forth below: B:\TRSTAGR6.D0C 55 Period During Which Prepaid Prepayment (both dates inclusive) Price April 1, 2003 through March 31, 2004 102% April 1, 2004 through March 31, 2005 101 April 1, 2005 and thereafter 100 In the case of prepayment of less than all Outstanding 1993 Certificates, the Trustee will select the 1993 Certificates representing the Principal Components to be prepaid in such manner as it shall determine is reasonable, in conformance with the Installment Purchase Agreement. When prepayment of 1993 Certificates is to be made, the Trustee will give notice of the prepayment of such Certificates, which notice will specify the date of such notice, the Prepayment Price, the Prepayment Date, the place or places of prepayment, the CUSIP number, if any, of the maturity or maturities and, if less than all of such maturity, the distinctive certificate numbers of the 1993 Certificates of such maturity -to be prepaid and, in the case of 1993 Certificates to be prepaid in part only, such notice will also specify the respective portions of the Principal Component represented thereby to be prepaid. Such notice will further state that on such date there will become due and payable with respect to each 1993 Certificate to be prepaid the Prepayment Price thereof, or the Prepayment Price of the specified portions of the Principal Component thereof in the case of 1993 Certificates to be prepaid in part only, and that from and after such Prepayment Date, the related Interest Component due with respect thereto will cease to accrue and will require that such 1993 Certificates be then surrendered at the address or addresses of the Trustee specified in the prepayment notice. As provided in the Trust Agreement, notice of prepayment will be given by mail, first class postage prepaid, not less than 30 nor more than 60 days prior to the Prepayment Date, to the respective Owners of any 1993 Certificates representing Principal Components which are to be prepaid, at their addresses appearing upon the registration books. Failure by the Trustee to mail notice of prepayment as specified in the Trust Agreement to any one or more of the respective Owners of any 1993 Certificates designated for prepayment will affect the sufficiency of the proceedings for prepayment only with respect to the Owner or Owners to whom such notice was not mailed. If notice of prepayment has been duly given as aforesaid and funds for the payment of the Prepayment Price of the 1993 Certificates to be prepaid are held by the Trustee on the designated Prepayment Date, then on the Prepayment Date designated in such notice, the Prepayment Price of the 1993 Certificates so called for prepayment will become payable as specified in such notice; and from and after the date so designated Interest Components due with respect to the Principal Components of the 1993 B:\TRSTAG1t6.D0C 56 Certificates or portions thereof so called for prepayment shall cease to accrue, such Certificates shall cease to be entitled to any benefit, protection or security under the Trust Agreement and the Owners of such Certificates shall have no rights in respect thereof except to receive payment of the Prepayment Price. If a 1993 Certificate is prepaid in part only, the Trustee will execute and deliver, upon the surrender of such Certificate, a new 1993 Certificate or Certificates representing Principal Components equal to the unprepaid Principal Component of the 1993 Certificate surrendered of the same maturity. Additional terms and conditions and procedures governing prepayments are specified in the Trust Agreement. Upon compliance with certain terms and conditions set forth in the Trust Agreement, the Trustee may execute and deliver additional Certificates payable from Gross Revenues in the Qualified Obligations Account. This 1993 Certificate is transferable only upon the books of the Trustee kept for that purpose at the Corporate Trust Office of the Trustee by the Owner in person or by the owners's attorney duly authorized in writing, upon surrender hereof together with a written instrument of transfer satisfactory to the Trustee duly executed by the Owner or the Owner's duly authorized attorney. Upon the transfer of any 1993 Certificate the Trustee will execute and deliver in the name of the transferee a new 1993 Certificate or Certificates of the same Principal Component, tenor and maturity as the surrendered 1993 Certificate. The Trustee may deem and treat the person in whose name any 1993 Certificate is registered upon the books of the Trustee as the absolute Owner of such 1993 Certificate, whether such 1993 Certificate is overdue or not, for the purpose of receiving payment of, or on account of, the Principal Component and premium, if any, and Interest Component with respect to such 1993 Certificate and for all other purposes, and all such payments so made to any such Owner or upon such Owner's order will be valid and effectual to satisfy and discharge the liability upon such 1993'Certificate to the extent of the sum or sums so paid, and the Trustee will not be affected by any notice to the contrary. The Trustee will not be required to transfer or exchange (i) any 1993 Certificate in the fifteen days prior to selection of 1993 Certificates for prepayment (whether or not such Certificate is thereafter selected for prepayment) and (ii) any 1993 Certificate selected for prepayment in whole or part. To the extent and in the manner permitted by the terms of the Trust Agreement, the provisions of the Trust Agreement may be modified or amended by the parties thereto, but no such modification or amendment will (1) permit a change in the terms of prepayment or maturity of the Principal Component represented hereby or of any Interest Component represented hereby or a reduction in the amount of the Principal Component or the B:\TRSTAGR6.DOC 57 Prepayment Price represented hereby or in the rate of interest represented hereby, without the prior written consent of the Owner hereof, or (2) reduce the percentage of Owners of 1993 Certificates whose consent is required to effect any modification or amendment of the Trust Agreement, or (3) modify any rights or obligations of the Trustee without its prior written consent thereto. The Trustee has no obligation or liability to the Owner to make payments of Principal Components, Interest Components or premium with respect to the 1993 Certificates, except from amounts on deposit for such purposes with the Trustee. The Trustee's sole obligations are to administer for the benefit of the Owners the various funds and accounts established under the Trust Agreement and, to the extent provided in the Trust Agreement, to enforce its rights under the Installment Purchase Agreement. 6:\TRSTAGR6.DDC 58 For value received, the undersigned do(es) hereby sell, assign and transfer untothe within 1993 Certificate and do(es) hereby irrevocably constitute and appoint attorney to transfer such Certificate on the register of the Trustee, with full power of substitution in the premises. Dated: Note: The signature(s) of this Assignment must correspond with name(s) as written on the face of the within Certificate in every particular, without alteration or enlargement or any change whatsoever. B:\TRSTAGR6.DDC 59 IN WITNESS WHEREOF, the parties have executed and attested this Trust Agreement by their officers thereunto duly authorized as of the date and year first written above. ATTEST: Secretary [SEAL] ATTEST: City Clerk CITY OF TUSTIN WATER CORPORATION By: President THE CITY OF TUSTIN By Mayor BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION By:_ Title: B:\TRSTAGR6.DOC 6 0 EXHIBIT A DELIVERY DATE DEPOSITS TO ACCOUNTS Aggregate Principal Component ................ Less: Original Issue Discount ............... Less: Underwriter's Discount ................ Plus: Accrued Interest Received ............. Plus: Balance from 1983 Reserve Account ............................... Proceeds of 1993 Certificates and 1983 Reserve Account ................ Less Delivery Date Deposits: Deposit to Purchase Payment Account.......... Deposit to Reserve Account ................... Deposit to Construction Account .............. Deposit to Escrow Account .................... Total Deposits .......................... B:\7RSTMM6.DDC 61 INSTALLMENT PURCHASE AGREEMENT BY AND BETWEEN CITY OF TUSTIN WATER CORPORATION, as Seller and THE CITY OF TUSTIN, as Purchaser Dated as of April 1, 1993 1993 Certificates o:\IvAa.00c SECTION 1.1. SECTION 1.2. SECTION 1.3. Table of Contents Page ARTICLE I DEFINITIONS AND EXHIBITS Definitions . . . . . 2 Content of Statements and Opinions . . . 5 Exhibits . . . . . . . . . . . . . . . . 6 ARTICLE II REPRESENTATIONS AND WARRANTIES SECTION 2.1. Representations and Warranties of the City .. . . 6 SECTION 2..2. Representations, Warranties and Covenant of the Corporation . . . . . . . . . . . 8 ARTICLE III PURCHASE AND SALE OF THE PROJECT; AGENT; FUNDS AND ACCOUNTS; FLOW OF REVENUES; SECURITY SECTION 3.1. Purchase and Sale of the Project . . . . 10 SECTION 3.2. Agent . . . . . . . . . . . . . . . . 10 SECTION 3.3. Purchase Payment Account . . . . . . . . 11 SECTION 3.4. Construction Account . . . . . . . . . . 11 SECTION 3.5. Reserve Account . . . . . . . . . . . . it SECTION 3.6. Funds and Accounts . . . . . . . . . . . 11 SECTION 3.7. Flow of Gross Revenues . . . . . . . . 12 SECTION 3.8. Security for the Purchase Payments . . . 12 ARTICLE IV THE PROJECT; PROHIBITED USES; DISBURSEMENTS SECTION 4.1. Acquisition and Construction of the Project . . . . . . . 13 SECTION 4.2. Disbursements from the Construction Account . . . . . . . . . . . . . . . . 13 D:\IPA{.DOC 1 ARTICLE V EFFECTIVE DATE OF THIS AGREEMENT; DURATION; PAYMENT PROVISIONS; LIABILITY SECTION 5.1. Effective Date of this Installment . . 26 SECTION 6.1. Purchase Agreement; Duration . . . . . . 14 SECTION 5.2. Purchase Price; 1993 Purchase Payments 14 SECTION 5.3. Additional Purchase Payments . . . . . . 15 SECTION 5.4. Source for City Payments . . . . . . . . 17 SECTION 5.5. Obligations of the City Unconditional; 20 SECTION 6.5. Net Contract; Obligations of Corporation Unconditional . . . . . . . . . . . 17 SECTION 5.6. Prepayment of 1993 Purchase Payments 19 SECTION 5.7. Termination of Installment Purchase Agreement . . . . . . . . . . . . . 19 SECTION 5.8. City's Liability . . . . . . . . . . . . 20 ARTICLE VI ARTICLE VII LLL, SECTION 7.1. Maintenance and Operation of the Water System . . . . . . . . . . . . . . . . . 25 SECTION 7.2. Insurance . . . . . . . . . . . . . . . . 25 ARTICLE VIII NON -LIABILITY OF CORPORATION; EXPENSES; INDEMNIFICATION SECTION 8.1. PARTICULAR COVENANTS . . 26 SECTION 6.1. Limitation on Encumbrances; Against . . 26 SECTION 8.3. Sale . . . . . . . . . . . . 20 SECTION 6.2. Accounting Records . . . . . . . . . . . 20 SECTION 6.3. Rates and Charges . . . . . . . . . . . 20 SECTION 6.4. Tax Covenants. 20 SECTION 6.5. Provisions andRestrictions with Respect to Defeasance . . . . . . . . 22 SECTION 6.6. Limits on Bonds and Obligations . . . . . 23 ARTICLE VII LLL, SECTION 7.1. Maintenance and Operation of the Water System . . . . . . . . . . . . . . . . . 25 SECTION 7.2. Insurance . . . . . . . . . . . . . . . . 25 ARTICLE VIII NON -LIABILITY OF CORPORATION; EXPENSES; INDEMNIFICATION SECTION 8.1. Non -Liability of Corporation . . . . . . 26 SECTION 8.2. Expenses . . . . . . . . . . . . . . 26 SECTION 8.3. Indemnification . . . . . . . . . . . . 26 SECTION 8.4. Survive Termination . . . . . . . . . . . 27 1X\WM.D0C ii ARTICLE IX DEFAULTS AND REMEDIES SECTION 9.1. Events of Default . . . . . . . . . . . . 27 SECTION 9.2. Remedies on Default . . . . . 29 SECTION 9.3. Remedies Not Exclusive; No Waiver of 30 SECTION 10.4. Rights . .. . . . . . 29 SECTION 9.4. Expenses on Default . . . . . . 30 SECTION 9.5. Notice of Default . . . . . . . . . . . . 30 ARTICLE Y MISCELLANEOUS SECTION 10.1. Further Assurances . . . . . . . . . . . 30 SECTION 10.2. Notices . . . . . . . . . . . . . . . . 30 SECTION 10.3. Governing Law . . . . . . . . . . . . . 30 SECTION 10.4. Binding Effect . . . . . . 30 SECTION 10.5. Severability of Invalid Provisions . . . 31 SECTION 10.6. Article and Section Headings and References . . . . . . . . . . . . . . 31 SECTION 10.7. Amendments. . . . . . . . . . 31 SECTION 10.8. Disclaimer ofwarranties . . . . . . . . 31 SECTION 10.9. Claims; Warranties, etc . . . . . . 32 SECTION 10.10. Waiver of Personal Liability . . . . . . 32 SECTION 10.11. Termination of Lease. . . . . . . . . 32 SECTION 10.12. Execution of Counterparts . . . . . . . 32 EXHIBIT A - DESCRIPTION OF PROJECT . . . . . . . . . A-1 EXHIBIT B - SCHEDULE OF 1993 PURCHASE PAYMENTS . . . B-1 b:\1vMAOC i i i INSTALLMENT PURCHASE AGREEMENT THIS INSTAIX NT PURCHASE AGREEMENT, dated as of April 1, 1993 (the "Installment Purchase Agreement"), by and between the CITY OF TUSTIN WATER CORPORATION, a California nonprofit public benefit corporation (hereinafter referred to as the "Corporation"), as seller, and the CITY OF TUSTIN (hereinafter referred to as the "City"), as purchaser. W I T N E S 8 E T H: WHEREAS, the Corporation was organized, among other things, to assist the City in the financing of costs related to capital improvements; and WHEREAS, the City has the power to purchase real and personal property; and WHEREAS, the Corporation will assist the City by further constructing and improving the Project; and WHEREAS, the Corporation will sell the Project to the City and the City will purchase the Project from the Corporation and perform the other covenants contained herein; and WHEREAS, the City will make Purchase Payments to the Corporation (or its assignee) and Additional Purchase Payments pursuant to this Installment Purchase Agreement; and WHEREAS, the Corporation will establish a trust pursuant to the Trust Agreement and direct the Trustee to execute and deliver certificates of participation representing proportionate interests in the Principal Components and Interest Components of the Purchase Payments to be made by the City pursuant to this Installment Purchase Agreement; and WHEREAS, the Corporation will grant, assign and transfer to the Trustee all of the right, title and interest of the Corporation in and to the Purchase Payments and all rights to enforce the payment of Purchase Payments under this Installment Purchase Agreement; and WHEREAS, the City and the Corporation have duly authorized the execution and delivery of this Installment Purchase Agreement; and NOW, THEREFORE, for and in consideration of the premises and the material covenants hereinafter contained, the parties hereto mutually agree as follows: ARTICLE I DEFINITIONS AND EXHIBITS SECTION 1.1. Definitions. The following terms shall, for all purposes of this Installment Purchase Agreement, have the respective meanings ascribed to them. Words in the singular shall include the plural and words in the plural shall include the singular where the context so requires. All capitalized terms used herein which are defined in the Trust Agreement and not defined herein shall have the meanings specified in the Trust Agreement. *'Accountant'@ shall mean any independent certified public accountant or firm of such accountants selected by the City. #$Additional Purchase Payments9l shall mean the payments so designated and required to be made by the City pursuant to Section 5.3 hereof. ItAverage Annual Qualified. obligation Servicell shall mean, as of any date, the average amount of Qualified Obligation Service payable in the then current or in any subsequent Fiscal Year. "Bondli shall mean any revenue bond, revenue note, warrant or other evidence of indebtedness issued, incurred or delivered for the financing or refinancing of extensions of, additions to, repairs and replacements to, renewals of, and improvements of the Water System, designated by the City at the initial delivery thereof as payable from Gross Revenues in the Qualified Obligations Account, to the extent the payments under such revenue bond, revenue note, warrant or other evidence of indebtedness are payable from Gross Revenues in the Qualified Obligations Account. "Bond" shall not include any Obligation or 1993 Certificate. IlCompletion Certificate" shall mean, with respect to the Project, a certificate of an Authorized City Representative, (i) stating that the acquisition of the Project has been completed and all costs of such acquisition have been paid except as identified in clause (iii), below, (ii) setting forth the Completion Date, (iii) setting forth the amount, if any, required, in the opinion of the signer or signers, for the payment of any remaining part of the Cost of the Project and (iv) giving such further directions as required by Section 5.04(e) of the Trust Agreement. $'Completion Date" shall mean, with respect to the Project, the date on which the Project has been completed. 11Cost11 shall mean all costs of acquisition or financing of any component of the Project, whether incurred prior to or after the date of this Installment Purchase Agreement, including, but not limited to, (i) administrative costs and capital expenditures relating to acquisition or financing, inspection costs, filing and D:\IPA4.D0C 2 recording costs, printing costs, reproduction and binding costs, fees and charges of the Trustee and its counsel pursuant to the Trust Agreement, costs of financing documents, Costs of Issuance, legal fees and charges, financial, accounting and other professional consultant fees, costs of rating agencies or credit ratings, and fees for the printing, execution, transportation and safekeeping of the Certificates; (ii) all other costs which the City or the Corporation shall be required to pay under the terms of any contract or contracts for the acquisition or financing of the Project, including, but not limited to the cost of insurance; (iii) such other expenses not specified herein as may be necessary for or incidental to any of the foregoing; and (iv) any sums required to reimburse the City or the Corporation for advances made for any of the above items. Cost as defined herein shall also include the cost and expenses incurred by any agent of the City or the Corporation for any of the above items. ('Delivery Datell shall mean the date on which the 1993 Certificates are delivered by the Trustee pursuant to the Trust Agreement to the original purchaser or purchasers thereof. INFiscal Yearn shall mean the twelve month fiscal period of the City which commences on July 1 in every year and ends on June 30 of the succeeding year, or any other twelve-month, or fifty-two week, period hereafter selected and designated as the official fiscal year period of the City. 11Gross Revenuesit shall mean all rates, fees and charges for providing water service to persons and real property and all other fees, rents and charges and other income derived by the City, from the ownership, operation, use or services of the Water System. 'Maintenance and Operation Expensesit shall mean the reasonable and necessary current expenses of maintaining, repairing and operating the Water System, but excluding depreciation, interest, amortization and interfund transfers from the Revenue Fund to the City's General Fund, all computed in accordance with sound accounting principles and consistent with existing accounting practices of the City. I'Moody's'l shall mean Moody's Investors Service, a corporation organized and existing under the laws of the State of Delaware, its successors and their assigns, or, if such corporation shall be dissolved or liquidated or shall no longer perform the functions of a statistical rating organization, any other nationally recognized securities rating agency designated by the City, with the approval of the Corporation by notice to the Trustee. _ OlNet Revenuesll shall mean the Gross Revenues less the Maintenance and Operation Expenses. b-.\ivM.DM 3 911993 Purchase Payments" shall mean the payments so designated and required to be made by the City pursuant to Section 5.2 hereof. ssobligation" shall mean any contract, instrument or other agreement for the purchase, acquisition or lease of facilities, properties, structures or equipment for the Water System, designated by the City at the initial delivery thereof as payable from Gross Revenues in the Qualified Obligations Account, to the extent the payments under such contract, instrument or agreement are payable from Gross Revenues in the Qualified obligations Account, and the final payments under which are due more than one year following the incurrence thereof. "Obligation" shall not include any Bond. $'opinion of Counsel's shall mean a written opinion of counsel selected by the City. If and to the extent required by the provisions of Section 1.2 hereof, each Opinion of Counsel shall include the statements provided for in Section 1.2 hereof. IlPerson'l shall mean an individual, corporation, firm, association, partnership, trust, or other legal entity or group of entities, including a governmental entity or any agency or political subdivision thereof. '@Project, shall mean the improvements and facilities described in Exhibit A attached hereto, as said Exhibit A may be revised from time to time in accordance with Section 4.1(a) hereof. IsPurchase Payments" shall mean all payments made or to be made by the City to the Corporation under this Installment Purchase Agreement, excluding Additional Purchase Payments. "Purchase Payment Dates's shall mean the dates on which the Purchase Payments are required to be made as provided in this Installment Purchase Agreement, such dates being each April 1 and October 1, commencing -October 1, 1993. ItPurchase Prices' shall mean the amount to be paid by the City to the Corporation for the Project as specified in Section 5.2 hereof. OuQualified obligationses shall mean, without duplication, (i) 1993 Purchase Payments; and (ii) Bonds and Obligations which at the time of initial delivery thereof satisfy the covenant set forth in Section 6.6 hereof. nQualified obligation Service" shall mean, with respect to any period, the amount of principal and interest or other payments accrued or to accrue in such period with respect to all outstanding Qualified Obligations (excluding the amount of proceeds of Qualified Obligations held in any fund or account for the bAIPA4.DOC 4 payment of Qualified Obligation Service accrued or to accrue during such period). For purposes of accrual under this definition, all payments with respect to Qualified Obligations due in a calendar month shall be deemed due on the first day of such calendar month. "8&P" shall mean Standard & Poor's Corporation, a corporation organized and existing under the laws of the State of New York, its successors and their assigns, or, if such corporation shall be dissolved or liquidated or shall no longer perform the functions of a statistical rating organization, any other nationally recognized securities rating agency designated by the City, with the approval of the Corporation, by notice to the Trustee. "Statement," "Request," "Requisition" or "Order" of the Corporation or the City shall mean, respectively, a written statement, request, requisition or order signed in the name of the Corporation or the City by an Authorized Representative of the Corporation or the City, as the case may be. Any such instrument and supporting opinions or representations, if any, may, but need not, be combined in a single instrument with any other instrument, opinion or representation, and the two or more so combined shall be read and construed as a single instrument. If and to the extent required by Section 1.2 hereof, each such instrument shall include the statements provided for in Section 1.2 hereof. "Tax Certificate" shall mean the Tax and Non -Arbitrage Certificate and Instructions as to Compliance with the Provisions of Section 103(a) of the Internal Revenue Code of 1986, executed and delivered by the City, on the Delivery Date, as amended or supplemented from time to time. "Treasurer" shall mean the Treasurer of the City. "Trustee" shall mean Bank of America National Trust and Savings Association, a national banking association, organized and existing under the laws of the United States, having its principal corporate trust office in San Francisco, California, or its successor, as trustee under the Trust Agreement, and any Co -Trustee appointed under the Trust Agreement. "Water System" shall mean the entire water system of the Corporation hereby acquired by the City pursuant to this Installment Purchase Agreement, including the Project and all improvements later constructed or acquired. SECTION 1.2. Content of Statements and Opinions. Every statement or opinion provided for in this Installment Purchase Agreement with respect to compliance with any provision hereof _ shall include (1) a statement that the person making or giving such statement or opinion has read such provision and the definitions herein relating thereto; (2) a brief statement as to the nature and b:\IPA4.DM 5 scope of the examination or investigation upon which the statement or opinion is based; (3) a statement (a) that, in the opinion of such person, he or she has made or caused to be made such examination or investigation as is necessary to enable him or her to express an informed opinion with respect to the subject matter or (b) that he or she has made or caused to be made his or her examination or investigation with respect to the subject matter in accordance with specified professional standards; and (4) a statement as to whether, in the opinion of such person, such provision has been complied with. Any such statement or opinion made or given by an officer of the Corporation or the City may be based, insofar as it relates to legal, accounting or City matters, upon a statement or opinion of or representation by counsel or an Accountant, unless such officer knows, or in the exercise of reasonable care should have known, that the statement, opinion or representation with respect to the matters upon which such statement or statements may be based, as aforesaid, is erroneous. Any such statement or opinion made or given by counsel or an Accountant may be based, insofar as it relates to factual matters (with respect to which information is in the possession of the Corporation or the City, as the case may be) upon a statement or opinion of or representation by an officer of the Corporation or the City, unless such counsel or accountant knows, or in the exercise of reasonable care should have known, that the statement or opinion or representation with respect to the matters upon which such person's statement or opinion or representation may be based, as aforesaid, is erroneous. The same officer of the Corporation or the City, or the same counsel or Accountant, as the case may be, need not certify to all of the matters required to be certified under any provision of this Installment Purchase Agreement, but different officers, counsel or Accountants may certify to different matters, respectively. SECTION 1.3. Exhibits. The following Exhibits are attached to and by this reference made a part of this Installment Purchase Agreement: Exhibit A: Description of the Project. Exhibit B: Schedule of 1993 Purchase Payments. ARTICLE II AND WARRANTIES SECTION 2.1. Representations and Warranties of the City. The City makes the following representations and warranties to the Corporation as of the date of the execution and delivery of this Installment Purchase Agreement and as of the Delivery Date (such representations and warranties to remain operative and in full force and effect regardless of delivery of the Certificates or any b-.\IPA4.D0C investigations by or on behalf of the Corporation or the results thereof): (i) The City is a municipal corporation duly organized and existing, has full legal right, power and authority to enter into this Installment Purchase Agreement and the Trust Agreement, and to carry out and consummate all transactions contemplated by this Installment Purchase Agreement and the Trust Agreement, and by proper action has duly authorized the execution and delivery of this Installment Purchase Agreement and the Trust Agreement. (ii) The officers of the City executing this Installment Purchase Agreement and the Trust Agreement are duly and properly in office and fully authorized to execute the same. (iii) Each of this Installment Purchase Agreement and the Trust Agreement has been duly authorized, executed and delivered by the City, and constitutes a legal, valid and binding agreement of the City enforceable against the City in accordance with its terms. (iv) The execution and delivery of this Installment Purchase Agreement and the Trust Agreement, the consummation of the transactions herein and therein contemplated and the fulfillment of or compliance with the terms and conditions hereof and thereof, will not in any material respect conflict with or constitute a violation or breach of or default (with due notice or the passage of time or both), under statutory law or any indenture, mortgage, deed of trust, agreement, lease, contract or other agreement or instrument to which the City is a party or by which it or its properties are otherwise subject or bound, or any applicable law or administrative rule or regulation, or any applicable court or administrative decree or order, or any trust agreement, mortgage, deed of trust, loan agreement, lease, contract or other agreement to which the City is a party or by which it or its properties are otherwise subject or bound, or result in the creation or imposition of any lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the City, which conflict, violation, breach, default, lien, charge or encumbrance might have consequences that would materially and adversely affect the consummation of the transactions contemplated by this Installment Purchase Agreement or the Trust Agreement, or the financial condition, assets, properties or operations of the City. b:\1vA4.00c 7 (v) No consent or approval of any trustee or holder of any indebtedness of the City or any other Person, and no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority is necessary in connection with the execution and delivery of this Installment Purchase Agreement or the Trust Agreement, or the consummation of any transaction herein or therein contemplated, or the fulfillment of or compliance with the terms and conditions hereof or thereof, except as have been obtained or made and as are in full force and effect and except such other permits as the City contemplates obtaining in due course. (vi) There are no easements, encumbrances or interests with respect to the Project which prohibit or materially impair the execution, delivery and performance of this Installment Purchase Agreement or the acquisition or use of the Project. SECTION 2.2. Representations, Warranties and Covenant of the Corporation. (a) The Corporation makes the following representations and warranties to the City as of the date of the execution and delivery of this Installment Purchase Agreement and as of the Delivery Date (such representations and warranties to remain operative and in full force and effect regardless of delivery of the Certificates or investigations by or on behalf of the City or the results thereof): (i) The Corporation is a nonprofit public benefit corporation duly organized and existing under and pursuant to the laws of the State of California, has full legal right, power and authority to enter into this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement and to carry out and consummate all transactions contemplated by this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement, and by proper action has duly authorized the execution and delivery of this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement. (ii) The officers of the Corporation executing this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement are duly and properly in office and fully authorized to execute the same. (iii) Each of this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement has been duly authorized, executed and delivered by the Corporation, and constitutes a legal, valid and binding b:\IP^4.DM 8 agreement of the Corporation enforceable against the Corporation in accordance with its terms. (iv) The execution and delivery of this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement, the consummation of the transactions herein and therein contemplated and the fulfillment of or compliance with the terms and conditions hereof and thereof, will not in any material respect conflict with or constitute a violation or breach of or default (with due notice or the passage of time or both), under the Articles of Incorporation of the Corporation or the Bylaws of the Corporation or any indenture, mortgage, deed of trust, agreement, lease, contract or other agreement or instrument to which the Corporation is a party or by which it or its properties are otherwise subject or bound, or any applicable law or administrative rule or regulation, or any applicable court or administrative decree or order, or any trust agreement, mortgage, deed of trust, loan agreement, lease, contract or other agreement to which the Corporation is a party or by which it or its properties are otherwise subject or bound, or result in the creation or imposition of any lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the Corporation, which conflict, violation, breach, default, lien, charge or encumbrance might have consequences that would materially and adversely affect the consummation of the transactions contemplated by this Installment Purchase Agreement, the Assignment Agreement or the Trust Agreement, or the financial condition, assets, properties or operations of the Corporation. (v) No consent or approval of any trustee or holder of any indebtedness of the Corporation or any other Person, and no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority is necessary in connection with the execution and delivery of this Installment Purchase Agreement, the Assignment Agreement or the Trust Agreement, or the consummation of any transaction herein or therein contemplated, or the fulfillment of or compliance with the terms and conditions hereof or thereof, except as have been obtained or made and as are in full force and effect and except such other permits as the City or the Corporation contemplates obtaining in due course. (vi) There are no easements, encumbrances or interests with respect to the Project which prohibit or materially impair the execution, delivery and performance of this Installment Purchase Agreement, the Assignment b:\IPM.DOC 9 Agreement or the Trust Agreement or the acquisition or use of the Project. (vii) The Corporation has determined that (i) it is necessary and proper for the Corporation to assist the City in financing the Project in the manner provided for in this Installment Purchase Agreement in order to provide, among other things, water facilities for the City and (ii) this Installment Purchase Agreement, the Assignment Agreement and the Trust Agreement and the transactions contemplated hereby and thereby are just and reasonable as to the Corporation. (b) The Corporation covenants that it will not intentionally take or consent to be taken any action which results in the interest paid on the Interest Components of the Purchase Payments being included in the gross income of the recipient thereof for purposes of federal or state income taxation. ARTICLE III PURCHASE AND SALE OF THE PROJECT; AGENT; FUNDS AND ACCOUNTS; FLOW OF REVENUES; SECURITY SECTION 3.1. Purchase and Sale of the Project. (a) The Corporation agrees to sell, and hereby sells, to the City, and the City agrees to purchase, and hereby purchases, from the Corporation, the Project at the Purchase Price (payable in installments) specified in Section 5.2 hereof and otherwise in the manner and in accordance with the provisions of this Installment Purchase Agreement. The Corporation hereby transfers and assigns to the City all of the Corporation's right, title and interest to all or any portion of the Project; provided, that, title to all or any portion of the Project shall pass whenever the City takes physical possession thereof. (b) From time to.time, at the request of the City, the Corporation shall promptly deliver to the City any instruments necessary to confirm the rights of the City to the Project. SECTION 3.2. Agent. The Corporation hereby appoints the City as its agent for the purpose of acquisition and construction of the Project, and the City hereby agrees to enter into such contracts as may be necessary, as agent for the Corporation, to provide for the complete acquisition and construction of the Project. The City hereby agrees that as such agent it will cause the acquisition and construction of the Project to be diligently completed. Notwithstanding the foregoing, it is hereby expressly understood and agreed that the Corporation shall be under no liability of any kind or character whatsoever for the payment of any costs or expenses incurred by the City for the acquisition and construction of the Project and that all such costs and expenses b:\IPM.DOC 10 shall be paid by the City, regardless of whether the funds deposited in the Construction Account are sufficient to cover all such costs. SECTION 3.3. Purchase Payment Account. The Corporation shall create, or cause to be created, under the Trust Agreement a Purchase Payment Account into which it shall deposit or cause to be deposited on the Delivery Date the amount specified in Exhibit A to the Trust Agreement with respect to the Purchase Payment Account. The Corporation shall cause the Trustee to make deposits to and payments from the Purchase Payment Account in accordance with the terms of this Installment Purchase Agreement and the Trust Agreement. SECTION 3.4. Construction Account. (a) The Corporation shall create, or cause to be created, under the Trust Agreement, a Construction Account into which it shall deposit or cause to be deposited on the Delivery Date the amount specified in Exhibit A to the Trust Agreement with respect to the Construction Account. (b) On and after the Delivery Date, the Treasurer shall make payments from the Construction Account to pay the Cost of an item of the Project upon the receipt of a requisition signed by an Authorized City Representative conforming to the requirements of Section 5.04(c) of the Trust Agreement. (c) Within thirty days after the Completion Date, an Authorized City Representative shall file a Completion Certificate with respect to the Project with the Treasurer. (d) Following delivery of the Completion Certificate for the Project, any moneys remaining in the Construction Account shall be applied by the Treasurer as provided in the Trust Agreement. SECTION 3.5. Reserve Account. The Corporation shall create, or cause to be created, under the Trust Agreement, a Reserve Account into_ which it shall deposit or cause to be deposited on the Delivery Date, the amount specified in Exhibit A to the Trust Agreement with respect to the Reserve Account. The Corporation shall cause the Trustee to make deposits to and payments from the Reserve Account in accordance with the terms of this Installment Purchase Agreement and the Trust Agreement. SECTION 3.6. Funds and Accounts. The following funds and accounts are hereby created, each of which is to be held by the Treasurer: (i) Water System Revenue Fund (the "Revenue Fund"); (ii) Water System Maintenance and Operation Account (the "M & O Account"); b:\IPA4.DOC 11 (iii) Qualified Obligations Account (the "Qualified Obligations Account"); and (iv) Water System Surplus Revenue Fund (the "Surplus Revenue Fund"). SECTION 3.7. Flow of Gross Revenues. The Treasurer shall deposit the Gross Revenues of the Water System as received in the Revenue Fund. On or before the twentieth day of each calendar month, the Finance Director of the City shall withdraw the entire amount on deposit in the Revenue Fund and shall allocate and deposit such amount in the indicated priority to the following accounts and funds: First, so long as any of the Certificates are Outstanding, there shall be transferred to the M & O Account an amount sufficient for the payment of Maintenance and Operation Expenses as said expenses become due and payable; Second, so long as any of the Certificates are Outstanding, there shall be transferred to the Qualified Obligations Account the amount of Qualified Obligation Service with respect to such calendar month (to the extent not already transferred to such Account in such month), or the entire amount of Gross Revenues then• available for transfer to the Qualified Obligations Account, whichever is less; and Third, all remaining Gross Revenues remaining in the Revenue Fund after the above transfers have been made shall be transferred to the Surplus Revenue Fund. Moneys in the Surplus Revenue Fund at any time may be used for any lawful purpose of the City, Provided. that, moneys remaining on deposit in the Surplus Revenue Fund at any time shall be transferred as needed, to the Qualified Obligations Account, in the amount necessary (or all available moneys in the Surplus Revenue Fund if less than the amount necessary) to make up any deficiency therein. SECTION 3.8. Security for the Purchase Payments. The Purchase Payments and all other payments with respect to Qualified Obligations shall be secured by a pledge, charge and lien upon the Gross Revenues in the Qualified Obligations Account and shall be paid from Gross Revenues in the Qualified Obligations Account unless otherwise paid from other sources of legally available funds. Purchase Payments and all other payments with respect to Qualified Obligations shall be equally secured by the Gross Revenues in the Qualified Obligations Account without priority for number or date of incurrence of such Qualified Obligations. The Gross Revenues in the Qualified Obligations Account shall be held in trust by the Treasurer of the City for the benefit of the holders of the Certificates and any other Qualified Obligations. b:\IPA4.D0C 12 ARTICLE IV THE PROJECT; PROHIBITED USES; DISBURSEMENTS SECTION 4.1. Acquisition and Construction of the Project. (a) The Project, as constituted on the Delivery Date (including the design and improvements financed from the proceeds of the 1993 Certificates), is described in Exhibit A to this Installment Purchase Agreement. The City, as agent of the Corporation, shall have the right to make any changes to the composition and description of the Project or of any component thereof, whenever the City deems such changes to be necessary and appropriate; provided, however, that any such change shall not alter the essential nature of the Project, or impair the ability of the City to make Purchase Payments under this Installment Purchase Agreement; and provided further that, prior to expending any moneys from the Construction Account with respect to any changes to the Project, the City shall file -with -the Corporation and the Trustee a revised Exhibit A reflecting such change and a certificate of an Authorized City Representative certifying that such change (i) is necessary and appropriate, (ii) does not impair the essential nature of the Project, and (iii) does not impair the ability of the City to make Purchase Payments. (b) The City agrees that from and after the Delivery Date, it will be responsible for the letting of contracts for the acquisition and construction of the improvements financed from the proceeds of the 1993 Certificates and supervising the acquisition and construction thereof. The City agrees that it will use its best efforts to cause the design work and improvements financed from the proceeds of the 1993 Certificates (which work and improvements are designated as such in Exhibit A hereto) to be completed and acquired on or before November 1, 1994. SECTION 4.2-. Disbursements from the Construction Account. Disbursements will be made from the Construction Account established for the Project to pay the Cost of the Project, in the manner and subject to the terms and conditions set forth in the Trust Agreement. In the event that amounts in the Construction Account are not sufficient to pay the Cost of the Project in full, the City nevertheless shall pay all Costs of the Project in excess of the amounts available in the Construction Account from its own funds, without diminution or postponement of amounts due to the Corporation or the Trustee, including any Purchase Payment or Additional Purchase Payment, and without any right of reimbursement from the Corporation. D.\IPM.DOC 13 EFFECTIVE DATE OF THIS AGREEMENT; DURATION; PAYMENT PROVISIONS; LIABILITY SECTION 5.1. Effective Date of this Installment Purchase Agreement; Duration. This Agreement shall become effective upon its execution and delivery, and shall expire on such date as shall be determined in accordance with Section 5.7 hereof. SECTION 5.2. Purchase Price; 1993 Purchase Payments. (a) The City agrees to pay the Purchase Price for the Project by making installment payments, referred to herein as 111993 Purchase Payments," in the respective amounts and at the times shown in Exhibit B hereto, which the City agrees to pay to the Trustee, as assignee of the Corporation, for deposit in the Purchase Payment Account held by the Trustee and which, in the aggregate, shall be in an amount sufficient for the payment in full of all obligations to the Owners of the 1993 Certificates from time to time Outstanding under the Trust Agreement, including (i) the total Interest Components due and payable with respect to the 1993 Purchase Payments, (ii) the total Principal Components of such 1993 Purchase Payments, and (iii) the prepayment premiums, if any, that shall be payable on the prepayment of the 1993 Certificates prior to their respective stated payment dates; less the amount of other funds available for such payment as provided in the Trust Agreement. The Purchase Price is payable over a period of 20 years, subject to prepayment. In lieu of making all or part of any 1993 Purchase Payment due on any Purchase Payment Date, the City may deliver to the Trustee for cancellation (not less than 45 days in advance of such Purchase Payment Date) 1993 Certificates representing an interest in the subject 1993 Purchase Payment. The amount of such 1993 Purchase Payment shall be reduced by the aggregate amount of the Principal Component and Interest Component represented by the 1993 Certificates so delivered to the Trustee. For purposes of income taxation, any original issue discount arising as a result of -this. Installment Purchase Agreement and the sale of certificates of'participation herein shall be construed to be interest for the purposes of, and to the extent permitted under, such income tax law. In addition, as the balance of the Purchase Price for the Project, the City agrees to apply $ from the proceeds of the 1993 Certificates toward the refunding or payment at maturity of the Corporation's $3,675,000 outstanding City of Tustin Water Corporation Lease Revenue Bonds, Series A. (b) On or before the Business Day immediately preceding the last Business Day of March and September in each year, the City shall transfer from the Qualified Obligations Account to the Trustee for deposit in the Purchase Payment Account the amount of the 1993 Purchase Payments due on the next succeeding April 1, and b.\IPM.DOC 14 October 1, respectively. Any amount required to be so transferred for any period shall be reduced by the amount, if any, with respect to that period set forth in Exhibit B to the Trust Agreement. (c) Each 1993 Purchase Payment hereunder shall be paid by the City in funds available on the due date in lawful money of the United States of America to the Trustee at its Corporate Trust Office, and held, invested, disbursed and applied as provided in the Trust Agreement. In the event the City fails to make any of the payments required by paragraph (a) of this Section 5.2, the installment so in default shall continue as an obligation of the City payable from Gross Revenues until the amount in default shall have been fully paid with interest thereon at a rate of interest equal to the highest rate of interest applicable to any then unpaid Principal Component. (d) The City shall make other Purchase Payments as and when required by any amendment to this Installment Purchase Agreement executed in accordance with Section 9.08 of the Trust Agreement. For purposes of determining the amount to be deposited into the Qualified Obligations Account with respect to the 1993 Certificates in any month, (i) each Principal Component of Purchase Payments shall accrue ratably over the twelve (12) months immediately preceding the Principal Component Payment Date on which such Principal Component is due and (ii) each Interest Component of Purchase Payments shall accrue ratably over the six (6) months immediately preceding the Interest Component Payment Date on which such Interest Component is due. SECTION 5.3. Additional Purchase Payments. (a) In addition to 1993 Purchase Payments, the City shall also pay to the Corporation, the Trustee or to the United States Treasury Department, as the case may be, "Additional Purchase Payments," as follows: (i) All taxes and assessments of any type or character charged to the Corporation or to the Trustee affecting the amount available to the Corporation or the Trustee from payments to be received hereunder or in any way arising due to the transactions contemplated hereby (including taxes and assessments assessed or levied by any public agency or governmental authority of whatsoever character having power to levy taxes or assessments) but excluding franchise taxes based upon the capital and/or income of the Trustee and taxes based upon or measured by the net income of the Trustee; provided, however, that the City shall have the right to b:\PAu.DOC 15 protest any such taxes or assessments and to require the Corporation or the.Trustee, at the City0s expense, to protest and contest any such taxes or assessments levied upon them and the City shall have the right to withhold payment of any such taxes or assessments pending disposition of any such protest or contest unless such withholding, protest or contest would adversely affect the rights or interests of the Corporation or the Trustee; (ii) Any taxes which may be imposed on the sale, resale, use, possession or ownership of the Project pursuant to this Installment Purchase Agreement; (iii) All reasonable fees, charges and expenses of the Trustee, as and when the same become due and payable; (iv) The reasonable fees and expenses of such accountants, consultants, attorneys and other experts as may be engaged by the Corporation or the Trustee to prepare audits, financial statements, reports, opinions or provide such other services required under this Installment Purchase Agreement or the Trust Agreement; (v) The reasonable costs and expenses of the Corporation as provided herein in connection with this Installment Purchase Agreement, the Certificates or the Trust Agreement, including any and all expenses incurred in connection with the authorization, sale and delivery of any such Certificates or in connection with any litigation which may at any time be instituted involving this Installment Purchase Agreement, the Certificates or the Trust Agreement or any of the other documents contemplated hereby or thereby; and (vi) Any amount required to be paid to the United States Treasury Department pursuant to Section 6.4 hereof. (b) Such Additional Purchase Payments to the Corporation or the Trustee shall be billed to the City by the Corporation or the Trustee, as the case may be, from time to time, together with a statement certifying that the amount billed has been incurred or paid by the Corporation or the Trustee, for one or more of the b:\IPM.DOC 16 above items. After such a demand, amounts so billed shall be paid by the City within thirty (30) days after receipt of the bill by the City. SECTION 5.4. Source for City Payments. (a) The City shall be obligated to make Purchase Payments hereunder solely from the Gross Revenues in the Qualified obligations Account. (b) Notwithstanding Section 5.4(a) hereof, 1993 Purchase Payments shall not be made from Gross Revenues in the Qualified Obligations Account to the extent (i) the proceeds of the sale of the 1993 Certificates deposited in the Purchase Payment Account, in the amounts, and at the times set forth in Exhibit B to the Trust Agreement, or (ii) other moneys transferred to or deposited in, the Purchase Payment Account pursuant to Section 5.02 of the Trust Agreement. (c) The City shall be obligated to make Additional Purchase Payments hereunder solely from the Gross Revenues in the Surplus Revenue Fund. Subject to the foregoing provisions of this Section 5.4, nothing herein shall preclude the City from making Purchase Payments and Additional Purchase Payments from other lawfully available moneys of the City. SECTION 5.5. Obligations of the City Unconditional; Net Contract; Obligations of Corporation Unconditional. (a) Subject to Section 5.4 hereof, the obligations of the City to make the Purchase Payments and Additional Purchase Payments required hereunder and to perform and observe the other agreements on its part contained herein shall be absolute and unconditional, and shall not be abated, rebated, set-off, reduced, abrogated, terminated, waived, diminished, postponed or otherwise modified in any manner or to any extent whatsoever, while any Purchase Payments or Additional Purchase Payments remain unpaid, regardless of any contingency, act of God, event or cause whatsoever, including, without limiting the generality of the foregoing, any acts or circumstances that may constitute failure of consideration, eviction or constructive eviction, the taking by eminent domain or destruction of or damage to the Project, commercial frustration of purpose, any change in the tax or other laws of the United States of America or of the State or any political subdivision of either or in the rules or regulations of any governmental authority, or any failure of the Corporation or the Trustee to perform and observe any agreement, whether express or implied, or any duty, liability or obligation arising out of or connected with this Installment Purchase Agreement or the Trust Agreement. This Installment Purchase Agreement shall be deemed and _ construed to be a "net contract," and the City shall pay absolutely net the Purchase Payments, Additional Purchase Payments and all b:\IPM.DOC 17 other payments required hereunder, regardless of any rights of set-off, recoupment, abatement or counterclaim that the City might otherwise have against the Corporation or the Trustee or any other party or parties. The Corporation and the City understand, agree and intend that the obligation of the City to make Purchase Payments and to pay Additional Purchase Payments hereunder shall not in any way be construed to be a debt of the City, or the State of California, or any political subdivision thereof, in contravention of any applicable constitutional or statutory limitation or requirement concerning the creation of indebtedness by the City, the State of California, or any political subdivision thereof, nor shall anything contained herein constitute a pledge of general revenues, funds or moneys of the City or an obligation 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. (b) The City covenants to take such action as may be necessary to include and maintain the applicable Purchase Payments and Additional Purchase Payments due hereunder in its budget for the appropriate Fiscal Year or pursuant to separate resolution of the City Council and further shall make the necessary appropriations for all such Purchase Payments and Additional Purchase Payments required herein. The covenant on the part of the City contained in this subsection (b) shall be deemed to be and shall be construed to be ministerial duties and it shall be the ministerial 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 such official duty of such officials to enable the City to carry out and perform such covenant. (c) The obligation of the Corporation to perform and observe the agreements on its part contained herein shall be absolute and unconditional and, until such time as all of the Purchase Payments shall have been fully paid (or provision for the payment thereof shall have been made in accordance with Article VII of the Trust Agreement), the Corporation (i) will perform and observe all of its agreements contained in this Installment Purchase Agreement and (ii) will not terminate this Installment Purchase Agreement for any cause including, without limiting the generality of the foregoing, any acts or circumstances that may constitute failure of consideration, destruction of or damage to the Project, commercial frustration of purpose, any change in the tax or other laws of the United States of America or of the State or any political subdivision of either or in the rules or regulations of any governmental authority or any failure of the City to perform and observe any agreement, whether express or implied, or any duty, liability or obligation arising out of or connected with this Installment Purchase Agreement. D:\IPA4.DOC 18 Nothing contained in this Section 5.5(c) shall be construed to release the City from the performance of any of the agreements on its part herein contained; and in the event the City should fail to perform any such agreement, the Corporation may institute such action against the City as the Corporation may deem necessary to compel performance or recover its damages for nonperformance so long as such action shall not violate the agreements of the Corporation contained in the first paragraph of this Section 5.5(c). SECTION 5.6. Prepayment of 1993 Purchase Payments. 1993 Purchase Payments are subject to prepayment as provided in this Section 5.6. All prepayments of 1993 Purchase Payments shall be made in funds immediately available on the Prepayment Date. (a) Optional Prepayment. The City shall have the option to prepay, with respect to 1993 Certificates, remaining Principal Components of 1993 Purchase Payments at any time (in the principal amount of $5,000, or any integral multiple thereof), on or after April 1, 2003, by paying the Prepayment Price with respect thereto on or before the Prepayment Date. The City shall give the Trustee written notice of its intention to exercise its option to prepay not more than ninety (90) and not less than forty-five (45) days in advance of the date of such prepayment. (b) Effect of Prepayment. In the event that the City prepays the 1993 Purchase Payments with respect to the 1993 Certificates in whole, the amount paid shall be applied to the prepayment in full of the Principal Components and Interest Components with respect to the 1993 Certificates in accordance with the Trust Agreement. In the event that the City prepays the 1993 Purchase Payments with respect to the 1993 Certificates in part but not in whole, such prepayment shall be applied to the prepayment of the 1993 Purchase Payments as follows: (i) the City shall designate which Principal Components are being prepaid, and to what extent, and the Principal Component of each remaining 1993 Purchase Payment shall be reduced accordingly, in each case in integral multiples of $5,000; and (ii) the Interest Component of each remaining 1993 Purchase Payment shall be reduced by the aggregate corresponding amount of interest which would otherwise be payable with respect to the 1993 Certificates thereby prepaid pursuant to the Trust Agreement. SECTION 5.7. Termination of Installment Purchase Agreement. Except as otherwise specifically provided herein, this Installment Purchase Agreement shall terminate upon the earlier of the following events: (i) the payment by the City of all remaining Purchase Payments as provided in Section 5.2 hereof and all other amounts to be paid by the City hereunder (including any Additional Purchase Payments which are W\IPACDOC 19 then due or will become due) and the retirement of all Certificates; or '(ii) all Certificates have been paid, or deemed paid, in accordance with Section 7.01 of the Trust Agreement. SECTION S.S. CityPS Liability. As between the Corporation and the City, the City assumes liability for all risks of loss during the construction and acquisition of the Project. ARTICLE VI PARTICULAR COVENANTS SECTION 6.1. Limitation on Encumbrances; Against Sale. The City covenants and agrees that it will not create, assume or suffer to exist any mortgage, deed of trust, pledge, security interest, encumbrance, lien or charge of any kind (including the charge upon property purchased under conditional sales or other title retention agreements) upon the Water System which impairs the ability of the City to comply with its covenant set forth in Section 6.3 hereof. The City covenants that the Project shall not be sold, leased or disposed of as a whole or substantially as a whole if such sale, lease or disposal would impair the ability of the City to comply with its covenant set forth in Section 6.3 hereof. SECTION 6.2. Accounting Records. The City covenants and agrees at all times to keep, or cause to be kept, proper books of record and account, prepared in accordance with generally accepted accounting principles, in which complete and accurate entries shall be made of all transactions of or in relation to the business, properties and operations of the Water System. Such books of record and account shall be available for inspection by the Trustee at reasonable hours and under reasonable circumstances. SECTION 6.3. Rates and Charges. The City shall prescribe, revise and collect such charges for the services and facilities of the Water System so that, in each Fiscal Year, the Net Revenues shall at least equal the sum of: (i) 1.20 times the amount of Qualified Obligation Service with respect to such Fiscal Year; and (ii) 1.00 times all other payments required to be made from Gross Revenues in such Fiscal Year. SECTION 6.4. Tax Covenants. (a) The Corporation and the City each covenant that, in order to maintain the exclusion from gross income for federal income tax purposes of the Interest Components of the Purchase Payments, and for no other purpose, each W\IPMAOC 20 will satisfy, or take such actions as may be necessary to cause to be satisfied, each provision of the Code necessary to maintain such exclusion. In furtherance of this covenant, the Corporation and the City each covenant to comply with the Tax Certificate as a source of guidance with the requirements of the Code. (b) The Corporation and the City each covenant that no part of the proceeds of the Certificates shall be used, directly or indirectly, to acquire any "investment property", as defined in Section 148 of the Code, and it shall not take or permit to be taken any other action or actions, which would cause the obligation represented by this Installment Purchase Agreement to be an "arbitrage bond" within the meaning of Section 148 of the Code, as in effect from time to time, or under applicable Treasury regulations promulgated thereunder. In order to assure compliance with the rebate requirements of Section 148 of the Code, the Corporation and the City each further covenant that it will pay or cause to be paid to the United States Treasury Department the amounts necessary to satisfy the requirements of Section 148(f) of the Code, as required in the Tax Certificate, and that it will establish such accounting procedures as are necessary to adequately determine, account for and pay over any such amount or amounts required to be paid to the United States in a manner consistent with the requirements of Section 148 of the Code, such covenant to survive the termination of this Installment Purchase Agreement pursuant to Section 5.7 hereof and the expiration of the Trust Agreement pursuant to Section 7.01 thereof. (c) The Corporation and the City each covenant that it will not take any action or omit to take any action, which action or omission, if reasonably expected on the date of initial execution and delivery of the Certificates, would result in a loss of exclusion from gross income for purposes of Federal income taxation, under Section 103(a) of the Code, of Interest Components paid by the City and received by the Owners of the Certificates. (d) The Corporation and the City each covenant that it will not use or permit the use of the Project by any person (other than the City or other state or local governmental unit) in such manner or to such extent as would result in a loss of exclusion of the Interest Components of Purchase Payments from gross income for Federal income tax purposes under Section 103(a) of the Code. (e) Notwithstanding any provision of this Installment Purchase Agreement, and except as provided below, the Corporation and the City each covenant that none of the moneys contained in any of the funds or accounts created pursuant to the Trust Agreement shall be: (i) used in making loans guaranteed by the United States (or any agency or instrumentality thereof), (ii) invested directly _ or indirectly in a deposit or account insured by the Federal Deposit Insurance Corporation, National Credit Union Administration or any other similar Federally chartered corporation, or (iii) b:\IPM.DOC 21 otherwise invested directly or indirectly in obligations guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof); provided, however, that the above restrictions do not apply to: (i) the investment of moneys held in the Purchase Payment Account or any other "bona fide debt service fund" as defined in the Tax Certificate, and in the Reserve Account, (ii).investments in direct obligations of the United States Treasury, (iii) investments in obligations guaranteed by the Federal National Mortgage Association, Government National Mortgage Association or the Federal Home Loan Mortgage Corporation, (iv) investments permitted under regulations issued pursuant to Section 149 (b)(3)(B) of the Code, or (v) sudh other investments as, in the opinion of Special Counsel, are investments permitted under the Trust Agreement which do not jeopardize the exclusion from gross income for Federal income tax purposes of the Interest Components with respect to the Certificates. SECTION 6.5. Provisions and Restrictions with Respect to Defeasance. (a) In the event the City shall seek, prior to the date of payment or provision for payment thereof, to pay or cause to be paid, within the meaning and with the effect expressed in Section 7.01 of the Trust Agreement, all Purchase Payments and the provisions of Section 6.4 herein shall then be of any force or effect, then, notwithstanding the provisions of Section 7.01 of the Trust Agreement, such Purchase Payments shall not be deemed to have been paid within the meaning and with the effect expressed in Section 7.01 of the Trust Agreement unless, in addition to all other requirements of Section 7.01 of the Trust Agreement hereof: (i) The City shall have delivered to the Trustee a certificate of an Authorized City Representative to the effect that: (A) the City is then in compliance with Section 6.4 herein; (B) the City has, irrevocably deposited with the Trustee such moneys, securities, documents and other things and issued such irrevocable instructions to the Trustee so that any remaining and continuing applicable requirements of the Code, with respect to the Purchase Payments, from compliance with which the City has not theretofore been relieved under the provisions of Section 7.01 of the Trust Agreement, are ministerial and reportorial in nature; and (C) the City has irrevocably authorized the Trustee, and delegated to the Trustee the authority, to perform such remaining and D:\IPA/.DM 22 continuing applicable requirements on the City's behalf, and such Trustee has undertaken so to do. (ii) There shall have been delivered to the Trustee an opinion of special Counsel to the effect that based upon the matters set forth in the certificate described in (i) above and assuming compliance by the Trustee with its undertaking described in (i)(C) above, no further action by or on the part of the City will be required under the applicable requirements of the Code to maintain the Federal income tax exclusion from gross income of the Interest Component of the Purchase Payments. (b) In the event the City shall seek, prior to the date of payment or provision for payment thereof, to pay or cause to be paid, within the meaning and with the effect expressed in this Installment Purchase Agreement, less than all of the Purchase Payments, and the provisions of Section 6.4 hereof shall then be of any force or effect, then, notwithstanding the provisions of Section 7.01 of the Trust Agreement, the Purchase Payments which the City then seeks to pay or cause to be paid shall not be deemed to have been paid within the meaning and with the effect expressed in Section 7.01 of the Trust Agreement unless there shall have been delivered to the Trustee an opinion of a nationally recognized bond counsel firm to the effect that either (i) noncompliance thereafter with the applicable provisions of the Code will not change the then current Federal income tax status of the Interest Component of the Purchase Payments, or (ii) there are no provisions of the Code which must thereafter be complied with by the City in order to maintain the Federal income tax exclusion from gross income of the Interest Component of the Purchase Payments. SECTION 6.6. Limits on Bonds and Obligations. (a) After the Delivery Date, no Bond or Obligation shall be issued, incurred or delivered unless, at the initial delivery thereof, (i) the Net Revenues calculated on -sound accounting principles, as shown by the books of the City for the most recently audited Fiscal Year prior to the adoption of the resolution approving the delivery of such Bonds or Obligations (as shown by an audit certificate or opinion of an independent certified public accountant or firm of certified public accountants employed by the City or by a certificate or opinion of an independent engineer or of an independent financial advisor employed by the City), plus, at the option of the City, the allowance for earnings hereinafter set forth in subparagraph (c) of this Section 6.6, shall have amounted to at least 1.20 times the Average Annual Qualified Obligation Service on all Qualified Obligations to be outstanding immediately subsequent to the initial delivery of such Bond or Obligation or (ii) the estimated Net Revenues calculated on sound accounting principles for the first Fiscal Year following the estimated completion date of the portion of the Project to be financed with the proceeds of such Bonds or W\IPACDOC 23 Obligations, plus, at the option of the City, an allowance for estimated earnings for such Fiscal Year arising from any increase in the rates and charges made for service from the Water System, shall amount to at least 1.20 times the Average Annual Qualified Obligation Service on all Qualified obligations to be outstanding immediately subsequent to the initial delivery of such Bond or obligation. (b) Subparagraph (a) of this Section 6.6 notwithstanding, Bonds or Obligations may be issued to refund outstanding Qualified Obligations if, after giving effect to the application of the proceeds thereof, either (i) total Qualified Obligation Service will not be increased in any Fiscal Year in which Qualified Obligations (outstanding on the date of issuance or incurrence of such refunding Bonds or Obligations, but excluding such refunding Bonds or Obligations) not being refunded are outstanding, or (ii) the Net Revenues, calculated on sound accounting principles, as shown by the books of the City for the most recently audited Fiscal Year prior to the adoption of the resolution approving the delivery of such Bonds or Obligations (as shown by an audit certificate or opinion of an independent certified public accountant or firm of certified public accountants employed by the City or by a certificate or opinion of an independent engineer or of an independent financial advisor employed by the City), plus, at the option of the City, the allowance for earnings hereinafter set forth in subparagraph (c) of this Section 6.6, shall have amounted to at least 1.20 times total Qualified Obligation Service in the Fiscal Year next succeeding the Fiscal Year in which such Bond or Obligation is initially delivered. (c) The following may be added to the Net Revenues of the Water System for the purpose of applying the restrictions contained in this Section 6.6: An allowance for earnings arising from any increase in the charges made for service from the Water System which has become effective prior to the initial delivery of such Bond or Obligation but which, during all or any part of said most recently audited Fiscal Year, was not in effect, in an amount equal to 95% of the amount by which the Net Revenues would have been increased if such increase in charges had been in effect during the whole of said most recently audited Fiscal Year, as shown by the certificate or opinion of an independent certified accountant or firm of certified public accountants employed by the City or by the certificate or opinion of an independent engineer or independent financial advisor employed by the City. (d) The City further covenants that the Net Revenues shall not be mortgaged, encumbered, sold, leased, pledged, any b:\IPM.DOC 24 charge placed thereon, or disposed of or used except as authorized by the terms of this Installment Purchase Agreement. ARTICLE VII AND INSURANCE SECTION 7.1. Maintenance and Operation of the Water System. The City covenants and agrees that it will operate and maintain the Water System in accordance with all governmental laws, ordinances, approvals, rules, regulations and requirements including, without limitation, such zoning, sanitary, pollution and safety ordinances and laws and such rules and regulations thereunder as may be binding upon the City. The City further covenants and agrees that it will maintain and operate the Water System, and all machinery, apparatus, fixtures, fittings and equipment of any kind in or that shall be placed in any building or structure now or hereafter at any time constituting part of the Water System in good repair, working order and condition, and that it will from time to time make or cause to be made all necessary and proper replacements, repairs, renewals and improvements thereto. SECTION 7.2. Insurance. The City covenants that it shall at all times maintain with responsible insurers all such insurance on the Water System as is customarily maintained by similar water systems with respect to works and properties of like character against accident to, loss of or damage to such works or properties and against loss of revenues. If any useful part of the Water System shall be damaged or destroyed such part shall be restored to use. The money collected from insurance against accident, loss or damage shall be used for repairing or rebuilding the lost, damaged or destroyed works and properties, and to the extent not so applied, shall be applied to the retirement of outstanding Qualified Obligations and for such purpose paid into the appropriate funds or accounts. The money collected from any loss of revenues insurance shall be deposited in the Revenue Fund. The City shall also maintain with responsible insurers worker's compensation insurance and insurance against public liability and property damage to the extent reasonably necessary and obtainable. Notwithstanding the foregoing, the City may provide any insurance required by this covenant through a self-insurance program or it may provide such insurance as part of any blanket coverages maintained by the City. b.\IPA4.00c 25 ARTICLE VIII NON -LIABILITY OF CORPORATION; EXPENSES; INDEMNIFICATION SECTION 8.1. Non -Liability of Corporation. The Corporation shall not be obligated to pay Purchase Payments or the Principal Component, and premium, if any, and Interest Component with respect to the Certificates. Neither the faith and credit nor the taxing power of the State or any political subdivision thereof is pledged to the payment of the Principal Component or premium or Interest Component with respect to the Certificates. The City hereby agrees that if the payments to be made hereunder shall ever prove insufficient to pay all Principal Components, and premium, if any, and Interest Components with respect to the Certificates as the same shall become due (whether by maturity, prepayment or otherwise), then upon notice from the Trustee, the City shall, subject to Section 5.4 hereof, pay such amounts as are required from time to time to prevent any deficiency or default in the payment of such Principal Components, premium or Interest Components, including, but not limited to, any deficiency caused by acts, omissions, nonfeasance or malfeasance on the part of the Trustee, the City, the Corporation or any third party. The City, the Trustee and/or the Owners shall have no right to compel the Corporation to pay Principal. Components or Interest Components of Purchase Payments or prepayment premiums, if any. SECTION 8.2. Expenses. The City covenants and agrees to pay and to indemnify, defend and hold harmless the Corporation and the Trustee against all costs and charges, including reasonable fees of attorneys, accountants, consultants and other experts, incurred in good faith or arising out of or in connection with this Installment Purchase Agreement, the Assignment Agreement, the Certificates or the Trust Agreement. The City shall have the right to select any attorneys employed pursuant to this Section 8.2; provided, however, that if the City fails to select attorneys pursuant to this Section 8.2 after notice from the Trustee, the Trustee may select such attorneys. SECTION 8.3. Indemnification. The City agrees, to the extent permitted by law, to indemnify, defend and hold harmless the Corporation and its directors, officers, employees and agents from and against any and all losses, claims, damages, liabilities or expenses, of every conceivable kind, character and nature whatsoever, including, but not limited to, losses, claims, damages, liabilities, or expenses arising out of, resulting from or in any way connected with (1) the Project or the condition, use, possession, conduct or management of, or work done in or about, or from the acquisition of such Project or any part thereof; (2) the execution and delivery of any Certificates and the carrying out of b:\IPM.DOC 26 any of the transactions contemplated by this Installment Purchase Agreement or the Trust Agreement; or (3) any untrue statement or alleged untrue statement of any material fact or omission or alleged omission to state a material fact necessary to make the statements made, in light of the circumstances under which they were made, not misleading in any official statement or other offering circular utilized in connection with the sale of the Certificates. The City further agrees, to the extent permitted by law, to pay or to reimburse the Corporation and its officers, employees and agents for any and all costs, reasonable attorneys fees, liabilities or expenses incurred in connection with investigating, defending against or otherwise in connection with any such losses, claims, damages, liabilities, expenses or actions. However, the City shall not hold harmless or indemnify the Corporation, its directors and officers for any losses which are caused by the bad faith or willful misconduct of the Corporation, its directors or officers. SECTION 8.4. Survive Termination. Notwithstanding Section 5.7 hereof, the provisions of this Article VIII shall survive payment in full of the Purchase Payments and the Certificates, the expiration of the Trust Agreement and the termination of this Installment Purchase Agreement. ARTICLE I% DEFAULTS AND REMEDIES SECTION 9.1. Events of Default. Each of the following events shall be an "Event of Default": (a) If the City shall fail to pay in full any Purchase Payment pursuant to Section 5.2 hereof, Additional Purchase Payment or other payment required to be paid hereunder at the time and in the manner specified herein; (b) If the City shall fail to observe or perform any covenant, condition, agreement or provision in this Installment Purchase Agreement on its part to be observed or performed, other than as referred to in subsection (a) of this Section 9.1, or shall breach any warranty by the City herein contained, for a period of sixty (60) days after written notice, specifying -such failure or breach and requesting that it be remedied, has been given to the City by the Corporation or the Trustee; except that, if such failure or breach can be remedied but not within such sixty (60) day period and if the City has taken all action reasonably possible to remedy such failure or breach within such sixty (60) day period, such failure or breach shall not become an Event of Default for so long as the City shall diligently proceed to remedy same in W\IPMAOC 27 accordance with and subject to any directions or limitations of time established by the Corporation or the Trustee, as the case may be; (c) Failure by the City to perform or observe any other covenant, agreement or obligation on its part contained in the Trust Agreement, which failure shall have continued for a period of sixty (60) days after written notice given to the City by the Trustee, specifying the failure or default and requesting the same to be remedied, which notice shall be given by the Trustee upon the written request of the Owners of Outstanding Certificates representing not less than twenty-five percent (258) of the aggregate unpaid Principal Component; provided that the Trustee may agree in writing to a reasonable extension of such period prior to the expiration of such sixty (60) day period; provided further, however, that if the City shall proceed to take curative action which, if begun and prosecuted with due. diligence, cannot be completed within such a period of sixty (60) days, then such period shall be increased without such written extension to such extent as shall be necessary to enable the City to diligently complete such curative action; (d) If the City files a petition in voluntary bankruptcy, for the composition of its affairs or for its corporate reorganization under any state or federal bankruptcy or insolvency law, or makes an assignment for the benefit of creditors, or admits in writing to its insolvency or inability to pay debts as they mature, or consents in writing to the appointment of a trustee or receiver for itself or for the whole or any substantial part of the Water System; (e) If a court of competent jurisdiction shall enter an order, judgment or decree declaring the City an insolvent, or adjudging it bankrupt, or appointing a trustee or receiver of the City or of the whole or any substantial part of the Water System, or approving a petition filed against the City seeking reorganization of the City under any applicable law or statute of the United States of America or any state thereof, and such order, judgment or decree shall not be vacated or set aside or stayed within sixty (60) days from the date of the entry thereof; or (f) If, under the provisions of any other law for the relief or aid of debtors, any court of competent jurisdiction shall assume custody or control of the City, and such custody or control shall not be terminated b:\IPA4.DOC 28 within sixty (60) days from the date of assumption of such custody or control. SECTION 9.2. Remedies on Default. If an Event of Default specified in Section 9.1 hereof shall occur, then, and in each and every case during the continuance of such Event of Default: (i) The Corporation or the Trustee may take whatever action, at law or in equity, as may appear necessary or desirable to collect the Purchase Payments, Additional Purchase Payments and any other payments then due and thereafter to become due under this Installment Purchase Agreement or to enforce the performance and observance of any obligation, covenant, agreement or provision contained in this Installment Purchase Agreement or the Trust Agreement to be observed or performed by the City; and (ii) The Corporation or the Trustee may take whatever other legal action may appear necessary or desirable to enforce their rights and the rights of the Owners of the Certificates. SECTION 9.3. Remedies Not Exclusive; No Waiver of Rights. No remedy herein conferred upon or reserved to the Corporation or the Trustee is intended to be exclusive of any other available remedy or remedies, but each�and every such remedy, to the extent permitted by law, shall be cumulative and shall be in addition to every other remedy given under this Installment Purchase Agreement or now or hereafter existing at law or in equity or otherwise. In order to entitle the Corporation or the Trustee to exercise any remedy, to the extent permitted by law, reserved to it or contained in this Installment Purchase Agreement, it shall not be necessary to give any notice, other than such notice as may be herein expressly required. Such rights and remedies as are given to the Corporation hereunder shall also extend to the Trustee, and the Trustee may exercise any rights under this Installment Purchase Agreement, and the Trustee and the Owners of the Certificates issued under the Trust Agreement shall be deemed third party beneficiaries of all covenants and conditions herein contained. No delay in exercising or omitting to exercise any right or power accruing upon any default shall impair any such right or power or shall be construed to be a waiver of any such default or an acquiescence therein, and every such right and power may be exercised from time to time and as often as may be deemed expedient. b:\IPM.DM 29 SECTION 9.4. Expenses on Default. In the event the City should default under any of the provisions of this Installment Purchase Agreement and the Corporation or the Trustee should employ attorneys or incur other expenses for the collection of the payments due hereunder, the City agrees that it will on demand therefor pay to the Corporation or the Trustee the fee of such attorneys and such other expenses so incurred by the Corporation or the Trustee. SECTION 9.5. Notice of Default. The City agrees that, as soon as is practicable, and in any event within ten (10) days, the City will furnish the Trustee notice of any event which is an Event of Default pursuant to Section 9.1 hereof (other than an Event of Default pursuant to Sections 9.1(d), 9.1(e) or 9.1(f) hereof) which has occurred and is continuing on the date of such notice, which notice shall set forth the nature of such event and the action which the City proposes to take with respect thereto. ARTICLE B M 14 IF -lei DO 0) hill 4 SECTION 10.1. Further Assurances. The City agrees that it will execute and deliver any and all such further agreements, instruments, financing statements or other assurances as may be reasonably necessary or requested by the Corporation or the Trustee to carry out the intention or to facilitate the performance of this Installment Purchase Agreement, including, without limitation, to perfect and continue the security interests herein intended to be created. SECTION 10.2. Notices. All notices or communications herein required or permitted to be given shall be in writing and, if to the City, mailed or delivered to it as follows: Treasurer, City of Tustin, 15222 Del Amo Avenue, Tustin, California 92680 and, if to the Corporation, mailed or delivered to it as•follows: City of Tustin, 15222 Del Amo. Avenue, Tustin, California 92680, Attention: Secretary, City of Tustin Water Corporation; and if to the Trustee, mailed or delivered to it as provided in the Trust Agreement. A duplicate copy of each notice or communication given hereunder by either the Corporation or the City to the other shall also be given to the Trustee. The Corporation, the City and the Trustee may, by notice given hereunder, designate any further or different address to which subsequent notices, certificates and other communications shall be sent. SECTION 10.3. Governing Law. This Agreement shall be construed in accordance with and governed by the Constitution and laws of the State. SECTION 10.4. Binding Effect. This Agreement shall inure to the benefit of and shall be binding upon the Corporation, b:\IPA4.DOC 30 the City and their respective successors and assigns, subject, however, to the limitations contained herein. SECTION 10.5. Severability of Invalid Provisions. If any one or more of the provisions contained in this Installment Purchase Agreement shall for any reason be held to be invalid, illegal or unenforceable in any respect, then such provision or provisions shall be deemed severable from the remaining provisions contained in this Installment Purchase Agreement and such invalidity, illegality or unenforceability shall not affect any other provision of this Installment Purchase Agreement, and this Installment Purchase Agreement shall be construed as if such invalid, illegal or unenforceable provision had never been contained herein. The Corporation and the City each hereby declares that it would have entered into this Installment Purchase Agreement and each and every other Section, paragraph, sentence, clause or phrase hereof irrespective of the fact that any one or more Sections, paragraphs, sentences, clauses or phrases of this Installment Purchase Agreement may be held illegal, invalid or unenforceable. SECTION 10.6. Article and Section Headings and References. The headings or titles of the several Articles and Sections hereof, and any table of contents appended to copies hereof, shall be solely for convenience of reference and shall not affect the meaning, construction or effect of this Installment Purchase Agreement. All references herein to "Articles," "Sections" and other subsections are to the corresponding Articles, Sections or subsections of this Installment Purchase Agreement; the words "herein," "hereof," "hereby," "hereunder" and other words of similar import refer to this Installment Purchase Agreement as a whole and not to any particular Article, Section or subsection hereof; and words of the masculine gender shall mean and include words of the feminine and neuter genders. SECTION 10.7. Amendments. This Agreement may not be effectively amended, changed, modified, altered or terminated except by the written agreement of the City and the Corporation and the concurring written consent of the Trustee, given in accordance with the provisions of the Trust Agreement. SECTION 10.8. Disclaimer of Warranties. The Corporation makes no warranty or representation, either express or implied, as to the value, design, condition, merchantability or fitness for any particular purpose or fitness for the use contemplated by the City of the Project, or any portion thereof, or any other representation or warranty with respect to the Project, or any portion thereof. In no event shall the Corporation be liable for incidental, indirect, special or consequential damages, in connection with this Installment Purchase Agreement or the existence, furnishing or functioning of the Project, or the City's or the Corporation's or any other person's use of the Project, except such damages as may b:\IP^4.DOC 31 arise by reason of the Corporation's breach of this Installment Purchase Agreement. SECTION 10.9. Claims; Warranties, etc. The Corporation irrevocably appoints the City as its agent and attorney-in-fact, so long as the City shall not be in default hereunder, to assert from time to time whatever claims and rights, including warranties with respect to any portion of the Project, which the Corporation may have against the manufacturer, supplier or contractor of such portion of the Project. As between the Corporation and the City, the City's sole remedy for the breach of any warranty, indemnification or representation shall be against the manufacturer, supplier or contractor of any portion of the Project, and not against the Corporation, nor shall such matter have any effect whatsoever on the rights of the Corporation with respect to this Installment Purchase Agreement, including the rights to receive full and timely payments hereunder. The City expressly acknowledges that neither the Corporation nor the Trustee makes, or has made, any representation or warranty whatsoever as to the existence or availability of such warranties of the manufacturer, supplier or contractor with respect to any item of the Project. SECTION 10.10. Waiver of Personal Liability. No director, officer, agent or employee of the Corporation or member, director, officer, agent or employee of the City shall be individually or personally liable for the payment of Purchase Payments or any other sum hereunder or be subject to any personal liability or accountability by reason of the execution and delivery of this Installment Purchase Agreement; but nothing herein contained shall relieve any such director, member, officer, agent or employee from the performance of any official duty provided by law or by this Installment Purchase Agreement. SECTION 10.11. Termination of Lease. The City and the Corporation hereby agree and acknowledge that upon the execution and delivery of the 1993 Certificates and the deposit of a portion of the proceeds of the 1993 Certificates into the Escrow Account as provided in the Trust Agreement, the Lease between the City and the Corporation, dated as of October 1, 1983, shall terminate immediately in accordance with Article 22 of the Lease. SECTION 10.12. Execution of Counterparts. This Agreement may be executed in any number of counterparts, each of which shall for all purposes be deemed to be original and all of which shall together constitute but one and the same instrument. b:\IPA{.DM 32 IN WITNESS WHEREOF, the Corporation and the City have caused this Installment Purchase Agreement to be executed in their respective names by their duly authorized representatives, all as of the date first above written. Attest: By. THE CITY OF TUSTIN By. Mayor City Clerk CITY OF TUSTIN WATER CORPORATION By President Secretary D.\IPM.DOC 33 EXHIBIT A DESCRIPTION OF PROJECT At the Delivery Date, the Project consists of the water system operated by the City of Tustin Water Corporation (the "Corporation") as in existence at the time the City takes physical possession thereof in accordance with Section 3.1 of this Installment Purchase Agreement, including, without limitation, all of the real and personal property of the Corporation; all land, easements, rights of way and other rights in land; buildings, plants, wells, pumping structures, reservoirs, appurtenances and other improvements to or on land; transmission and distribution pipelines and mains, hydrants, meters and services; machinery and equipment; trucks, cars and other vehicles; tools, supplies, spare parts and other shop, garage and electrical equipment; and miscellaneous office furniture, equipment, and supplies. The Project also consists of the improvements (and design and engineering relating thereto) to be financed from the proceeds of the 1993 Certificates, including, without limitation (i) design and construction of water mains and related distribution facilities; (ii) design, planning, and commencement of construction of the Main Street reservoir; (iii) design and construction of improvements at the Rawlings reservoir; (iv) structural analysis and site evaluation at the Foothill reservoir; (v) structural analysis and site planning at the Simon reservoir; (vi) site evaluation, design, and construction of the Zone II booster station; and (vii) acquisition of portable generator at the Columbus Tustin well. D:\IPA4.D0C A-1 EXHIBIT B SCHEDULE OF 1993 PURCHASE PAYMENTS Interest Principal Date Component Component 10/1/93 $ $ 04/1/94 275,000 10/1/94 04/1/95 300,000 10/1/95 04/1/96 325,000 10/1/96 04/1/97 350,000 10/1/97 04/1/98 375,000 10/1/98 04/1/99 400,000 10/1/99 04/1/00 425,000 10/1/00 04/1/01 450,000 10/1/01 ' 04/1/02 500,000 10/1/02 04/1/03 525,000 10/1/03 04/1/04 550,000 10/1/04 04/1/05 600,000 10/1/05 04/1/06 625,000 10/1/06 04/1/07 675,000 10/1/07 04/1/08 725,000 10/1/08 04/1/09 775,000 10/1/09 04/1/10 825,000 10/1/10 04/1/11 875,000 10/1/11 04/1/12 925,000 10/1/12 04/1/13 1,000,000 10/1/13 D:\IPM.DM B-1 Total 1993 Purchase Payments ESCROW AGREEMENT by and among THE CITY OF TUSTIN and THE CITY OF TUSTIN WATER CORPORATION and BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION Dated as of April 1, 1993 c:\1080\tustin\escrow5.doc ESCROW AGREEMENT THIS ESCROW AGREEMENT is entered into as of April 1, 1993, by and among the City of Tustin (the "City"), the City of Tustin Water Corporation (the "Corporation") and Bank of America National Trust and Savings Association, as Escrow Bank (the "Escrow Bank"). Capitalized terms used herein and not otherwise defined shall have the meanings provided for in Section 1 hereof. WITNESSETH: WHEREAS, there are currently outstanding, under an Indenture, dated as of October 1, 1983, by and between the Corporation and Bank of America National Trust and Savings Association, as successor to Security Pacific National Bank, as Trustee (the "1983 Trustee") (the "Indenture") $3,675,000 aggregate principal amount of City of Tustin Water Corporation Lease Revenue Bonds, Series A (the "Refunded Bonds"); and WHEREAS, the City has determined that a savings in payments will be realized through the issuance of $11,500,000 aggregate principal amount of City of Tustin, Water System Revenue Certificates of Participation, 1993 Series (the "Refunding Certificates"), evidencing proportionate interests of the owners thereof in Installment Payments to be made by the City pursuant to an Installment Purchase Agreement, dated as of April 1, 1993, between the City and _ the Corporation, for the purpose of providing a portion of the funds necessary to pay, when due, the principal and interest with respect to the Refunded Bonds to and including October 1, 1993 and to redeem the remaining outstanding Refunded Bonds on October 1, 1993 (the "Redemption Date") at the respective redemption price expressed as a percentage of the principal amount thereof (the "Redemption Price") set forth below for the speed maturity of the Refunded Bonds: Refunded Bonds maturing Redemption October 1 Price 1994 100.25% 1995 100.50 1996 100.75 1997 101.00 1998 101.25 1999 101.50 2000 101.75 2001 102.00 2002 102.00 2003 102.00 WHEREAS, in order to obtain the remaining portion of the moneys needed for such purpose, in addition to the funds available from the proceeds of the sale of the Refunding Certificates, the City and the Corporation have authorized the transfer, on the date of execution c:\1080\tustin\escrow5.doc and delivery of the Refunding Certificates, of moneys from the Reserve Fund established by the Indenture (the "Original Reserve Fund"), which moneys shall be deposited in the Escrow Account; and WHEREAS, the Refunded Bonds are subject to payment or redemption, as the case may be, on the Redemption Date, and the City and the Corporation have determined to provide for the call for redemption on the Redemption Date of the remaining Refunded Bonds outstanding on the Redemption Date; and WHEREAS, upon the deposit of moneys in the Escrow Account and the initial investment thereof as provided herein, the rights of the owners of the Refunded Bonds under the Indenture will be discharged except for the right to receive payment from the Escrow Account which the City and the Corporation have caused to be established hereunder; and NOW THEREFORE, in consideration of the mutual covenants and agreements herein contained, the City, the Corporation and the Escrow Bank agree as follows: Section 1. Definitions. Unless otherwise defined herein, capitalized terms used herein shall have the meanings ascribed to such terms in the Trust Agreement, dated as of April 1, 1993 (the "Trust Agreement"), among the City, the Corporation and Bank of America National Trust and Savings Association, as trustee, a copy of which shall be provided to the Escrow Bank. Section 2. The Escrow Account. (a) There is hereby established an account (the "Escrow Account") to be held in an irrevocably pledged escrow by the Escrow Bank which the Escrow Bank shall keep separate and apart from all other funds and accounts of the City, the Corporation and the Escrow Bank and to be applied solely as provided in this Agreement. The Escrow Account is 'an irrevocable escrow account. Pending application as provided in this Agreement, amounts on deposit in the Escrow Account are hereby pledged and assigned solely to the payment of (i) the principal of and accrued interest on the Refunded Bonds coming due on the Redemption Date and (ii) the Redemption Price on the Redemption Date, which amounts shall be held in trust by the Escrow Bank for the owners of the Refunded Bonds. Upon the deposit of moneys in the Escrow Account in accordance with the terms of this Agreement, the City and the Corporation shall be obligated to make payments with respect to the Refunded Bonds solely from amounts on deposit in the Escrow Account. (b) Upon the execution and delivery of the Refunding Certificates, there shall be deposited in the Escrow Account the following: (i) $ received from the proceeds of the sale of the Refunding Certificates; and (ii) $ transferred from the Original Reserve Fund. c:\1080\tustin\escrow5.doc 2 (c) Upon the deposit of moneys pursuant to Section 2(b), the moneys on deposit in the Escrow Account will be at least equal to an amount sufficient to purchase the aggregate principal amount of direct noncallable obligations of the United States of America (the "Government Obligations") set forth in Exhibit I hereto (the "Exhibit 1 Securities"), which principal, together with all interest due or to become due on such Exhibit I Securities, and any uninvested cash held by the Escrow Bank in the Escrow Account, will be sufficient in time and amount to make the payments required by Section 4 hereof. Section 3. Use and Investment of Escrow Account Moneys. (a) The Escrow Bank hereby acknowledges receipt of the moneys described in Section 2(b) and agrees to invest $ of such moneys in the Exhibit 1 Securities upon receipt of certification by a nationally recognized firm of independent certified public accountants that the Exhibit 1 Securities will mature in such principal amounts and earn interest in such amounts and, in each case, at such times, so that sufficient moneys will be available from maturing principal and interest on the Exhibit 1 Securities, together with any uninvested moneys then held by the Escrow Bank in the Escrow Account, to make all payments required by Section 4 hereof. Except as provided in Section 3(b) or Section 3(c), the balance of the moneys described in Section 2 or otherwise held by the Escrow Bank under this Agreement shall be held uninvested in the Escrow Account. (b) Upon the written request of an Authorized City Representative, but subject to the conditions and limitations herein set forth, the Escrow Bank shall purchase substitute Government Obligations for the Government Obligations then held hereunder with the proceeds derived from the sale, transfer or other disposition of Government Obligations then on deposit in the Escrow Account and any uninvested money then held by the Escrow Bank hereunder in accordance with the provisions of this Section 3(b). Such sale, transfer or other disposition of Government Obligations then on deposit in the Escrow Account and substitution of other Government Obligations shall be effected by the Escrow Bank upon the written request of an Authorized City Representative but only by a simultaneous transaction and only upon receipt of: (i) certification by a nationally recognized firm of independent certified public accountants that the Government Obligations to be substituted, together with the Government Obligations which will continue to be held in the Escrow Account, will mature in such principal amounts and earn interest in such amounts and, in each case, at such times so that, without taking into account any reinvestments earned thereon, sufficient moneys will be available from maturing principal and interest on such Government Obligations held in the Escrow Account, together with any uninvested moneys, to make all payments required by Section 4 hereof which have not previously been made; and (il) receipt by the Escrow Bank of an opinion of independent counsel to the effect that the sale, transfer or other disposition and substitution of Government Obligations will not adversely affect the exclusion of interest on any Refunded Bonds or Refunding Certificates from gross income for purposes of federal income taxation. (c) Upon the written request of an Authorized City Representative, but subject to the conditions and limitations herein set forth, the Escrow Bank will apply any moneys received from the maturing principal of or interest or other investment income on any Government Obligations held in the Escrow Account, or the proceeds from any sale, transfer or other disposition of Government Obligations pursuant to Section 3(b), as follows: (i) to the extent such moneys will not be required at any time for the purpose of making a payment required by Section 4 hereof, as c:\1080\tustin\escrow5.doc certified by a nationally recognized firm of independent certified public accountants delivered to the Escrow Bank, such moneys shall be paid over to the City upon the written request of an Authorized City Representative as received by the Escrow Bank, free and clear of any trust, lien, pledge or assignment securing the Refunded Bonds or otherwise existing hereunder; and (ii) to the extent such moneys will be required for such purpose at a later date, shall, to the extent practicable, be invested or reinvested in Government Obligations maturing at times and in amounts sufficient to make such payment required by Section 4 hereof provided that the amount of the funds to be realized from time to time from such investment or reinvestment shall be certified by a nationally recognized firm of independent certified public accountants delivered to the Escrow Bank by the City and provided that the City shall deliver to the Escrow Bank an opinion of independent counsel to the effect that such investment or reinvestment will not adversely affect the exclusion of interest on any Refunded Bonds or Refunding Certificates from gross income for purposes of federal income taxation, and interest earned from such investments or reinvestments shall be paid over to the City upon the written request of an Authorized City Representative as received by the Escrow Bank, free and clear of any trust, lien, pledge or assignment securing the Refunded Bonds or otherwise existing hereunder. (d) All Government Obligations purchased pursuant to this Section 3 shall be deposited in and held for the credit of the Escrow Account. Except as provided in this Section 3, no moneys or Government Obligations deposited with the Escrow Bank pursuant to this Agreement nor principal of, or interest payments or other investment income on, any such Government Obligations shall be withdrawn or used for any purpose other than, and shall be held in trust for, the payment of the principal, interest and Redemption Price with respect to the Refunded Bonds as provided by Section 4 hereof. (e) The owners of the Refunded Bonds shall have a first lien on the moneys and Government Obligations in the Escrow Account until such moneys and Government Obligations are used and applied as provided in this Agreement. (f) The Escrow Bank shall not be held liable for investment losses resulting from compliance with the provisions of this Agreement. Section 4. Payment of Refunded Bonds. From the maturing principal of the Government Obligations held in the Escrow Account and the investment income and other earnings thereon and any uninvested money then held in the Escrow Account, the Escrow Bank shall on the Redemption Date, pay (i) principal and interest due on the Refunded Bonds on said Redemption Date and (ii) the Redemption Price for the then remaining outstanding Refunded Bonds to the 1983 Trustee in accordance with the terms of the Indenture; provided, however, that, to the extent that the amount on deposit in the Escrow Account on the Redemption Date is in excess of the amount necessary to make all such required payments with respect to the Refunded Bonds, as shown in the then applicable escrow verification of the nationally recognized firm of independent certified public accountants, such excess shall be transferred to the City. Section S. Irrevocable Instructions to Publish Notices and Mail Notice. The Corporation hereby irrevocably designates the Refunded Bonds maturing on and after October 1, 1994 for prior redemption on the Redemption Date and hereby irrevocably instructs Bank of America National Trust and Savings Association, as 1983 Trustee under the Indenture, to publish notice of redemption, not less than 30 calendar days nor more than 60 calendar days prior to the c:\1080\tustin\escrow5.doc 4 Redemption Date, as provided in Section 4.02 of the Indenture. The form of the notice required to be published pursuant to Section 4.02 of the Indenture is attached hereto as Exhibit 2. The Corporation also hereby irrevocably instructs Bank of America National Trust and Savings Association, as 1983 Trustee under the Indenture, to mail notice of such redemption to each owner of the Refunded Bonds to be redeemed, as provided in Section 4.02 of the Indenture. The Corporation hereby irrevocably instructs Bank of America National Trust and Savings Association, as 1983 Trustee under the Indenture, to publish, as soon as practicable, a notice to the owners of the Refunded Bonds, in substantially the form attached hereto as Exhibit 3. Such instructions constitute the provisions for the notice that moneys are available for the payment of the Refunded Bonds, as required by Section 10.02 of the Indenture. Section 6. Performance of Duties. The Escrow Bank agrees to perform the duties set forth herein and agrees that the irrevocable instructions to the Escrow Bank herein provided are in a form satisfactory to it. Section 7. Escrow Bank's Authority to Make Investments. The Escrow Bank shall have no power or duty to invest any funds held under this Agreement except as provided in Section 3 hereof. The Escrow Bank shall have no power or duty to transfer or otherwise dispose of the moneys held hereunder except as provided in this Agreement. Section & Indemnity. To the extent permitted by law, the City hereby assumes liability for, and hereby agrees (whether or not any of the transactions contemplated hereby are consummated) to indemnify, protect, save and keep harmless the Escrow Bank and its respective successors, assigns, agents, employees and servants, from and against any and all liabilities, obligations, losses, damages, penalties, claims, actions, suits, costs, expenses and disbursements (including reasonable legal fees, expenses and disbursements) of whatsoever kind and nature (collectively, the "Liabilities") which may be imposed on, incurred by, or asserted against, the Escrow Bank at any time (whether or not also indemnified against the same by the City or any other person under any other agreement or instrument, but without double indemnity) in any way relating to or arising out of the execution, delivery and performance of this Agreement, the establishment hereunder of the Escrow Account, the acceptance of the funds and securities deposited therein, the purchase of any securities to be purchased pursuant hereto, the retention of such securities or the proceeds thereof and any payment, transfer or other application of moneys or securities by the Escrow Bank in accordance with the provisions of this Agreement; provided, however, that the City shall not be required to indemnify the Escrow Bank against liabilities attributable to the Escrow Bank's own negligence or willful misconduct or the material breach by the Escrow Bank of the terms of this Agreement. In no event shall the City or the Escrow Bank be liable to any person by reason of the transactions contemplated hereby other than to each other as set forth in this Section 8. The indemnities contained in this Section shall survive the termination of this Agreement. Section 9. Responsibilities of Escrow Bank. The Escrow Bank and its respective successors, assigns, agents and servants shall not be held to any personal liability whatsoever, in tort, contract, or otherwise, in connection with the execution and delivery of this Agreement, the establishment of the Escrow Account, the acceptance of the moneys or any securities deposited therein, the purchase of the, securities to be purchased pursuant hereto, the retention of such securities or the proceeds thereof, the sufficiency of the securities or any uninvested moneys held hereunder to accomplish the payment or redemption of the Refunded Bonds, as the case may be, c:\1080\tustin\escrow5.doc or any payment, transfer or other application of moneys or securities by the Escrow Bank in accordance with the provisions of this Agreement or by reason of any non -negligent act, non - negligent omission or non -negligent error of the Escrow Bank made in good faith in the conduct of its duties. The recitals of fact contained in the "Whereas" clauses herein shall be taken as the statements of the City and the Corporation, and the Escrow Bank assumes no responsibility for the correctness thereof. The Escrow Bank makes no representation as to the sufficiency of the securities to be purchased pursuant hereto and any uninvested moneys to accomplish the payment or redemption of the Refunded Bonds, as the case may be, pursuant to the Indenture or to the validity of this Agreement as to the City or the Corporation and, except as otherwise provided herein, the Escrow Bank shall incur no liability in respect thereof. The Escrow Bank shall not be liable in connection with the performance of its duties under this Agreement except for its own negligence, willful misconduct or default, and the duties and obligations of the Escrow Bank shall be determined by the express provisions of this Agreement. The Escrow Bank may consult with counsel, who may or may not be counsel to the City, and in reliance upon the written opinion of such counsel shall have full and complete authorization and protection in respect of any action taken, suffered or omitted by it in good faith in accordance therewith. Whenever the Escrow Bank shall deem it necessary or desirable that a matter be proved or established prior to taking, suffering, or omitting any action under this Agreement, such matter (except the matters set forth herein in specifically requiring a certificate of a nationally recognized firm of independent certified public accountants or an opinion of independent counsel) may be deemed to be conclusively established by a written certification of the City. Whenever the Escrow Bank shall deem it necessary or desirable that a matter specifically requiring a certificate of a nationally recognized firm of independent certified public accountants or an opinion of independent counsel be proved or established prior to taking, suffering or omitting any such action, such matter may be established only by a certificate signed by a nationally recognized firm of certified public accountants or such opinion of independent counsel. Section 10. Amendments. The City, the Corporation and the Escrow Bank may, without the consent of, or notice to, such owners, amend this Agreement or enter into such agreements supplemental to this Agreement as shall not adversely affect the rights of the owners of the Refunded Bonds and as shall not be inconsistent with the terms and provisions of this Agreement or the Indenture, for any one or more of the following purposes: (i) to cure any ambiguity or formal defect or omission in this Agreement; (ii) to grant to, or confer upon, the Escrow Bank for the benefit of the owners of the Refunded Bonds any additional rights, remedies, powers or authority that may lawfully be granted to, or conferred upon, such owners or the Escrow Bank; and (iii) to include under this Agreement additional funds, securities or properties. The Escrow Bank shall be entitled to rely conclusively upon an opinion of independent counsel with respect to compliance with this Section, including the extent, if any, to which any change, modification, addition or elimination affects the rights of the owners of the Refunded Bonds or that any instrument executed hereunder complies with the conditions and provisions of this Section. Prior written notice of any amendment to this Agreement and drafts of legal documents in connection with any such amendment shall be delivered to Moody's Investors Service and Standard & Poor's Corporation. Notices and documents required to be delivered hereunder to Moody's Investors Service shall be sent to Moody's Investors Service, 99 Church Street, New York, New York 10007, Attn: Public Finance Rating Desk/ Refunded Bonds. Notices and documents required to be delivered hereunder to Standard & Poor's Corporation shall be sent to Standard & Poor's Corporation, 25 Broadway, New York, New York, 10004, Attn: Refunded Bonds. c:\1081D\tustin\escrow5.doc Section 11. Term. This Agreement shall commence upon its execution and delivery and, except as provided in Section 8 hereof, shall terminate on the date upon which the Refunded Bonds have been paid in full in accordance with this Agreement. Section 12. Compensation. The City shall, upon the execution hereof by the City, the Corporation and the Escrow Bank will pay or cause to be paid to the Escrow Bank the agreed upon compensation for its services to be rendered hereunder, if any. The City shall from time to time, on demand, reimburse the Escrow Bank for all of its reasonable advances in the exercise and performance of its duties hereunder; provided, however, that under no circumstances shall the Escrow Bank be entitled to any lien whatsoever on any moneys or obligations in the Escrow Account for the payment of fees and expenses for services rendered or expenses incurred by the Escrow Bank under this Agreement, under the Trust Agreement, or otherwise. Section 13. Discharge of Obligations. The Escrow Bank, as 1983 Trustee under the Indenture, acknowledges the discharge of the Corporation's obligations under the Indenture and the Refunded Bonds except for obligations under Article II of the Indenture in respect of the transfer, exchange, registration and replacement of Refunded Bonds. Section 14. Severability. If any one or more of the covenants or agreements provided in this Agreement on the part of the City, the Corporation or the Escrow Bank to be performed should be determined by a court of competent jurisdiction to be contrary to law, such covenants or agreements shall be null and void and shall be deemed separate from the remaining covenants and agreements herein contained and shall in no way affect the validity of the remaining provisions of this Agreement. The City shall notify Moody's Investors Service and Standard & Poor's Corporation in the event of such severability. Section 15. Counterparts. This Agreement may be executed in several counterparts, all or any of which shall be regarded for all purposes as an original but all of which shall constitute and be but one and the same instrument. Section 16. Governing Law. This Agreement shall be construed under the laws of the State of California. Section 17. Assignment. This Agreement shall not be assigned by the Escrow Bank or any successor thereto without the prior written consent of the City and the Corporation. c:\1080\tustin\escrow5.doc IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed by their duly authorized officers and attested as of the date first above written. CITY OF TUSTIN Mayor CITY OFTUSTIN WATER CORPORATION President BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION, as Escrow Bank Tide: EXHIBIT 1 SECURITIES TO BE DEPOSITED IN THE ESCROW ACCOUNT [UNITED STATES TREASURY NOTES AND I Principal Purchase Maturily Amount Price c:\1080\tustin\escrow5.doc EXHIBIT 2 NOTICE OF REDEMPTION CITY OF TUSTIN WATER CORPORATION LEASE REVENUE BONDS, SERIES A Maturing on and after October 1, 1994 and bearing the following CUSIP Numbers: NOTICE IS HEREBY GIVEN to the owners of the above-mentioned bonds (the "Refunded Bonds") that such Bonds have been called for redemption, prior to maturity, on October 1, 1993, at the respective redemption price expressed as a percentage of the principal amount thereof (the "Redemption Price") set forth below for the specified maturity of the Refunded Bonds: Refunded Bonds maturing Redemption October 1 Price 1994 100.25% 1995 100.50 1996 100.75 1997 101.00 1998 101.25 1999 101.50 2000 101.75 2001 102.00 2002 102.00 2003 102.00 On October 1, 1993 there shall become due and payable upon presentation and surrender of such Bonds at the office of Bank of America National Trust and Savings Association, located at , California, the Redemption Price of said Bonds, together with accrued interest thereon. FROM AND AFTER THE REDEMPTION DATE, ALL INTEREST REPRESENTED ON THE REFUNDED BONDS WILL CEASE TO ACCRUE AND BE PAYABLE. To avoid a 20% backup withholding tax required by the Interest and Dividend Tax Compliance Act of 1983, Bond owners must submit with their Refunded Bonds a completed IRS Form W-9. DATED this c:\1080\tustin\escrow5.doc day of 1993. EXHIBIT 3 NOTICE OF REDEMPTION CITY OF TUSTIN WATER CORPORATION LEASE REVENUE BONDS, SERIES A NOTICE IS HEREBY GIVEN to the owners of the City of Tustin Water Corporation Lease Revenue Bonds, Series A (the "Bonds"), that there has been deposited with Bank of America National Trust and Savings Association, as Trustee under the Indenture, dated as of October 1, 1983 between the City of Tustin Water Corporation and Bank of America National Trust and Savings Association, as successor to Security Pacific National Bank (the 'Trustee") (the "Indenture"), obligations of or guaranteed as to principal and interest by the United States of America (the "Government Obligations"), the principal and interest on which when due will provide moneys which, together with the moneys; if any, deposited with the Escrow Bank at the same time, shall be sufficient and available (i) to pay when due the principal of and interest with respect to the Bonds to and including October 1, 1993 and (ii) to redeem the remaining outstanding Bonds on October 1, 1993, at the respective redemption price expressed as a percentage of the principal amount thereof (the "Redemption Price") set forth below for the specified maturity of the Bonds: Bonds maturing Redemption October 1 Price 1994 100.25% 1995 10050 1996 100.75 1997 101.00 1998 101.25 1999 10150 2000 101.75 2001 102.00 2002 102.00 2003 102.00 The Government Obligations and moneys, if any, are being held for the payment of all Bonds, including the Bonds maturing on or after October 1, 1994 which will be redeemed on October 1, 1993. The Bonds are deemed to have been paid under Section 10.02 of the Indenture. DATED this _ day of , 1993. BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION, as Trustee and Escrow Bank