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Resolution No. 2020-005RESOLUTION NO. 2020-05 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON AUTHORIZING AND APPROVING THE ISSUANCE OF WATER SYSTEM REVENUE BONDS; APPROVING THE INDENTURE OF TRUST PURSUANT TO WHICH SUCH BONDS ARE TO BE ISSUED; APPROVING A DISCLOSURE DOCUMENT, A CONTRACT OF PURCHASE, A CONTINUING DISCLOSURE AGREEMENT AND OTHER DOCUMENTS IN CONNECTION WITH SUCH BONDS; AND AUTHORIZING CERTAIN OTHER MATTERS RELATING THERETO WHEREAS, the City of Vernon (the "City") is a municipal corporation and a chartered city of the State of California organized and existing under its Charter and the Constitution of the State of California; and WHEREAS, the City is authorized pursuant to Article II of the City's Charter and the City of Vernon Municipal Facilities Revenue Bond Law, constituting Article XI of the City Code of the City, to issue bonds, notes and other obligations payable from the Net Revenues of the Water System (capitalized terms used herein and not otherwise defined shall have the meanings given such terms in the Indenture mentioned below) to finance the costs of any land, improvements, facilities, equipment and other property of any nature whatsoever that are used in the Water System; and WHEREAS, the City desires to provide for the issuance of its Water System Revenue Bonds, 2020 Series A (with such changes to such name as an Authorized Officer (as defined herein) may approve, the "Bonds") payable from the Net Revenues of the Water System for the purposes of financing certain capital improvements (the "2020 Project") to its Water System, paying costs of issuance of the Bonds and, if necessary, funding a deposit to (or procuring a letter of credit, insurance policy or other facility (each, a "reserve surety") to provide for the funding of) a reserve fund for the Bonds; and WHEREAS, the Bonds are to be issued under and pursuant to an Indenture of Trust, by and between the City and The Bank of New York Mellon Trust Company, N.A., as trustee (such Indenture of Trust in the form attached hereto as Exhibit B with such changes, insertions and deletions as are made pursuant to this Resolution, the "Indenture"); and WHEREAS, the Bonds are to be secured by revenues of the Water System to the extent set forth in the Indenture; and WHEREAS, J.P. Morgan Securities LLC, as underwriter (the "Underwriter"), has submitted a proposal to purchase the Bonds in the form of a Contract of Purchase (such Contract of Purchase, in the form attached hereto as Exhibit C with such changes, insertions and deletions as are made pursuant to this Resolution, being referred to herein as the "Purchase Contract"); and WHEREAS, in connection with the offering and sale of the Bonds there has been prepared a disclosure document in the form of a Preliminary Official Statement (such Preliminary Official Statement in the form attached hereto as Exhibit D with such changes, insertions and deletions as are made pursuant to this Resolution, being referred to herein as the "Preliminary Official Statement"); and WHEREAS, Rule 15c2-12 requires that, in order to be able to purchase or sell the Bonds, the Underwriter must have reasonably determined that an obligated person has undertaken in a written agreement or contract for the benefit of the owners of the Bonds to provide disclosure of certain financial information and operating data and certain enumerated events on an ongoing basis; and WHEREAS, in order to cause such requirement of Rule 15c2-12 - 2 - to be satisfied, the City desires to enter into a Continuing Disclosure Agreement with the Trustee (such Continuing Disclosure Agreement, in the form attached to the form of the Preliminary Official Statement attached hereto as Exhibit D, with such changes, insertions and deletions as are made pursuant to this Resolution, being referred to herein as the "Continuing Disclosure Agreement"); and WHEREAS, in compliance with Senate Bill 450 (Chapter 625 of the 2017-2018 Session of the California Legislature), which added Section 5852.1 to the California Government Code, the City has obtained from the Underwriter or the City's financial advisor required good faith estimates relating to the Bonds, and such estimates are disclosed and set forth in Exhibit A hereto; and WHEREAS, there have been submitted to this meeting drafts of the following: (1) the Indenture; (2) the Purchase Contract; and (3) the Preliminary Official Statement, including the Continuing Disclosure Agreement; and WHEREAS, after having reviewed and considered the proposal of the Underwriter to purchase the Bonds on the terms and conditions contained in the Purchase Contract, this City Council now desires to authorize the issuance and sale of the Bonds, including the execution of such documents and the performance of such acts as may be necessary or desirable to effect such issuance and sale, and the other actions contemplated by this Resolution. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF VERNON AS FOLLOWS: SECTION 1: The City Council of the City of Vernon hereby - 3 - finds and determines that the above recitals are true and correct. SECTION 2: The City Council of the City of Vernon finds that this action is exempt under the California Environmental Quality Act (CEQA) in accordance with Sections 15060(c)(3), 15378(b)(4), and 15378(b)(5) because the activity approved by this Resolution relating to the refinancing or funding of previously -approved projects will not result in direct or indirect physical changes in the environment and, therefore, is not a "project," as defined in Section 15378 of the CEQA Guidelines. SECTION 3: The City Council of the City of Vernon hereby approves the Indenture, in substantially the form attached hereto as Exhibit B, and made a part hereof as though set forth in full herein. SECTION 4: The City Council of the City of Vernon hereby authorizes the Mayor, the Mayor Pro Tem, the City Administrator and the Finance Director/City Treasurer (each an "Authorized Officer"), acting singly, to execute and deliver the Indenture, in the name of and on behalf of the City, in substantially the form attached hereto with such changes, insertions and deletions as may be approved by the Authorized Officer executing the Indenture, said execution being conclusive evidence of such approval, and the City Clerk is hereby authorized to attest thereto. SECTION 5: The City Council of the City of Vernon hereby authorizes and approves, subject to the limitations specified in this Resolution, the issuance of the Bonds on the terms and conditions set forth in the Indenture. The aggregate principal amount of the Bonds shall not exceed $15 million dollars ($15,000,000). The Bonds will be dated as provided in, will bear interest at the rates provided in, will mature on the date or dates provided in, will be issued in the form - 4 - provided in, will have the sinking fund Installments specified in, will be subject to redemption as provided in, and will have such other terms as shall be provided in, the Indenture as the same is completed as provided in this Resolution, provided that no Bond shall bear a stated rate of interest in excess of 5.50% per annum. SECTION 6: The City Council of the City of Vernon hereby authorizes the Authorized Officer executing the Indenture, subject to the limitations set forth in Section 5 hereof and in this Section 6, to determine the following: (i) the maturity date or dates of the Bonds (but no Bond shall mature later than August 1, 2050); (ii) the principal amount of the Bonds maturing on each maturity date; (iii) the interest rate or rates for the Bonds maturing on each maturity date; (iv) the maturity or maturities, if any, of the Bonds to be redeemed or paid at maturity from sinking fund installments (the "Term Bonds"); (v) the sinking fund installments for the Term Bonds; and (vi) the redemption provisions for the Bonds. SECTION 7: The net proceeds received on the sale of the Bonds shall be applied to such purposes as are set forth in the recitals to this Resolution in the manner provided in the Indenture. SECTION 8: The City Council of the City of Vernon hereby approves the Purchase Contract, in substantially the form attached hereto as Exhibit C, and made a part hereof as though set forth in full herein. Each Authorized Officer, acting singly, is hereby authorized to execute and deliver the Purchase Contract, in the name of and on behalf of the City, in substantially the form attached hereto with such changes, insertions and deletions as may be approved by the Authorized Officer executing the Purchase Contract, said execution being conclusive evidence of such approval, and the City Clerk is hereby - 5 - authorized to attest thereto. SECTION 9: The City Council of the City of Vernon hereby authorizes the Authorized Officer executing the Purchase Contract to determine the purchase price to be paid for the Bonds under the Purchase Contract; provided, however, that the aggregate Underwriter's discount (not including original issue discount which shall not exceed 15% of the aggregate principal amount of the Bonds) for the Bonds shall be not more than 0.5% of the aggregate principal amount of the Bonds. SECTION 10: The City Council of the City of Vernon hereby approves and authorizes the sale of the Bonds to the Underwriter on the terms and conditions contained in the Purchase Contract, as the same may be completed in accordance with the provisions of this Resolution, with such changes, insertions and deletions as are authorized hereby. SECTION 11: The City Council of the City of Vernon hereby approves the Preliminary Official Statement, in substantially the form attached hereto as Exhibit D, and made a part hereof as though set forth in full herein. Each of the Authorized Officers, acting singly, is hereby authorized to cause the Preliminary Official Statement to be delivered to the Underwriter, in substantially the form attached hereto as Exhibit D with such changes, insertions and deletions as may be approved by the Authorized Officer delivering the Preliminary Official Statement (including without limitation the insertion of the proposed terms of the Bonds), said delivery being conclusive evidence of such approval. SECTION 12: The City Council of the City of Vernon hereby authorizes and approves the use of the Preliminary Official Statement in connection with the offering and sale of the Bonds by the Underwriter, including delivery of the Preliminary Official Statement - 6 - in electronic form. Each of the Authorized Officers, acting singly, is hereby authorized to determine that the Preliminary Official Statement is deemed final for purposes of Rule 15c2-12. SECTION 13: The City Council of the City of Vernon hereby approves the preparation and delivery to the Underwriter of a final Official Statement (the "Official Statement") relating to the Bonds, and its use by the Underwriter in connection with the offering and sale of the Bonds, including delivery of the Official Statement in electronic form. The Official Statement shall be in substantially the form of the Preliminary Official Statement with such changes, insertions and deletions as may be approved by the Authorized Officer executing the Official Statement (including without limitation the insertion of the final terms of the Bonds), said execution being conclusive evidence of such approval. Each of the Authorized Officers, acting singly, is hereby authorized to execute the Official Statement, in the name and on behalf of the City, and thereupon to cause the Official Statement to be delivered to the Underwriter. Each of the Authorized Officers, acting singly, is hereby authorized to approve and execute any amendment or supplement to the Official Statement contemplated by the Purchase Contract, in the name and on behalf of the City, and thereupon to cause such amendment or supplement, to be delivered to the Underwriter. SECTION 14: The City Council of the City of Vernon hereby approves the Continuing Disclosure Agreement, in substantially the form attached to the Preliminary Official Statement attached hereto as Exhibit D, and made a part hereof as though set forth in full herein. Each Authorized Officer, acting singly, is hereby authorized to execute and deliver the Continuing Disclosure Agreement, in the name of and on - 7 - behalf of the City, in substantially the form attached hereto with such changes, insertions and deletions as may be approved by the Authorized Officer executing the Continuing Disclosure Agreement, said execution being conclusive evidence of such approval, and the City Clerk is hereby authorized to attest thereto. SECTION 15: The City Council of the City of Vernon hereby approves the appointment of The Bank of New York Mellon Trust Company, N.A., as Trustee under and pursuant to the Indenture, with the powers and duties of said office as set forth therein. SECTION 16: The City Council of the City of Vernon hereby authorizes the Authorized Officers: (i) to solicit bids on a municipal bond insurance policy and/or reserve surety for the benefit of the Bonds; (ii) to negotiate the terms of such policy or policies; (iii) to finalize, if appropriate, the form of such policy or policies with a municipal bond insurer; and (iv) if it is determined that the policy or policies will result in net savings for the City, to pay the insurance premium of such policy or policies from the proceeds of the issuance and sale of the Bonds. SECTION 17: The City Council of the City of Vernon hereby authorizes the Mayor, the Mayor Pro Tem, the City Administrator, the Finance Director/City Treasurer, the City Clerk, the City Attorney, the Director of Public Utilities and any other proper official, officer or employee of the City, acting singly, be and each of them to execute and deliver any and all documents and instruments and to do and cause to be done any and all acts and things necessary or convenient in carrying out the actions authorized by this Resolution and the transactions contemplated by the documents and instruments approved or authorized by this Resolution, including, without limitation, making any determinations or submission of any documents or reports which are required by any rule or regulation of any governmental entity, the giving of any notices and directions or the seeking of any consents or acknowledgements in connection with the issuance and sale of the Bonds, the execution of any agreement related to municipal bond insurance or a reserve surety for the Bonds and the authorization, execution, delivery of, and the performance by the City of its obligations under, the documents and instruments approved or authorized by this Resolution. SECTION 18: The City Council of the City of Vernon hereby ratifies, approves and confirms all actions heretofore taken by any committee of the City Council, or any official, officer, employee, representative or agent of the City, in connection with the issuance and sale of the Bonds or the authorization, execution, delivery, or performance of the City's obligations under the documents and instruments approved or authorized by this Resolution, and the other actions contemplated by this Resolution. - 9 - SECTION 19: The City Clerk of the City of Vernon shall certify to the passage, approval and adoption of this resolution, and the City Clerk of the City of Vernon shall cause this resolution and the City Clerk's certification to be entered in the File of Resolutions of the Council of this City. APPROVED AND ADOPTED this 18th day of February, 2020. ATTEST: P rL Rgr& Lisa Pope, Ci Clerk APPROVAP AS TO FORM: Brian yun, Senior Deputy City Utorney Name Melissa• W Sba=a Title: Mayor - 10 - STATE OF CALIFORNIA ) ss COUNTY OF LOS ANGELES ) I, Lisa Pope, City Clerk of the City of Vernon, do hereby certify that the foregoing Resolution, being Resolution No. 2020-05, was duly passed, approved and adopted by the City Council of the City of Vernon at a regular meeting of the City Council duly held on Tuesday, February 18, 2020, and thereafter was duly signed by the Mayor or Mayor Pro-Tem of the City of Vernon. Executed this Ar day of February, 2020 at Vernon, California. Lisa Pope, Ci y Clerk (SEAL) EXHIBIT A GOVERNMENT CODE SECTION 5852.1 DISCLOSURE The following information consists of estimates that have been provided by the Underwriter and has been represented by such party to have been provided in good faith: (A) True Interest Cost of the Bonds: 3.30% (B) Finance Charge of the Bonds (Sum of all fees/charges paid to third parties): $470,000 (C) Net Proceeds of the Bonds to be Received (net of finance charges, reserves and capitalized interest, if any): $15,000,000 (D) Total Payment Amount through Maturity of the Bonds: $25,908,878 The foregoing constitute good faith estimates only. The principal amount of the Bonds, the true interest cost of the Bonds, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to: (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates; (b) the actual principal amount of Bonds sold being different from the estimated amount used for purposes of such estimates; (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates; (d) the actual market interest rates at the time of sale of the Bands being different than those estimated for purposes of such estimates; (e) other market conditions; or (f) alterations in the City's financing plan, or a combination of such factors. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on a variety of factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. EXHIBIT A EXHIBIT A GOVERNMENT CODE SECTION 5852.1 DISCLOSURE The following information consists of estimates that have been provided by the Underwriter and has been represented by such party to have been provided in good faith: (A) True Interest Cost of the Bonds: 3.30% (B) Finance Charge of the Bonds (Sum of all fees/charges paid to third parties): $470,000 (C) Net Proceeds of the Bonds to be Received (net of finance charges, reserves and capitalized interest, if any): $15,000,000 (D) Total Payment Amount through Maturity of the Bonds: $25,908,878 The foregoing constitute good faith estimates only. The principal amount of the Bonds, the true interest cost of the Bonds, the finance charges thereof, the amount of proceeds received therefrom and total payment amount with respect thereto may differ from such good faith estimates due to: (a) the actual date of the sale of the Bonds being different than the date assumed for purposes of such estimates; (b) the actual principal amount of Bonds sold being different from the estimated amount used for purposes of such estimates; (c) the actual amortization of the Bonds being different than the amortization assumed for purposes of such estimates; (d) the actual market interest rates at the time of sale of the Bonds being different than those estimated for purposes of such estimates; (e) other market conditions; or (f) alterations in the City's financing plan, or a combination of such factors. The actual date of sale of the Bonds and the actual principal amount of Bonds sold will be determined by the City based on a variety of factors. The actual interest rates borne by the Bonds will depend on market interest rates at the time of sale thereof. The actual amortization of the Bonds will also depend, in part, on market interest rates at the time of sale thereof. Market interest rates are affected by economic and other factors beyond the control of the City. EXHIBIT B Stradling Ymm Carlson & Pa th Draft of 1130120 INDENTURE OF TRUST Dated as of March 1, 2020 By and between THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., as Trustee and the CITY OF VERNON Relating to S CITY OF VERNON WATER SYSTEM REVENUE BONDS, 2020 SERIES A TABLE OF CONTENTS Section 1.01. Section 1.02. Section 1.03. Section 2.01. Section 2.02. Section 2.03. Section 2.04. Section 2.05. Section 2.06. Section 2.07. Section 2.08. Pare ARTICLE I DEFINITIONS; CONTENT OF CERTIFICATES AND OPINIONS Definitions..............................................................................................................2 Content of Certificates and Opinions.................................................................... 11 Interpretation. ........................................................................................................ 12 ARTICLE B THE 2020 BONDS Authorization of 2020 Bonds................................................................................ 13 Terms of the 2020 Bonds...................................................................................... 13 Transfer of 2020 Bonds........................................................................................ 14 Exchangeof 2020 Bonds...................................................................................... 14 RegistrationBooks................................................................................................ 14 Form and Execution of 2020 Bonds..................................................................... 15 2020 Bonds Mutilated, Lost, Destroyed or Stolen. ............................................... 15 BookEntry System............................................................................................... 16 ARTICLE III ISSUANCE OF 2020 BONDS; APPLICATION OF PROCEEDS Section 3.01. Issuance of the 2020 Bonds.................................................................................. 18 Section 3.02. Application of Proceeds of the 2020 Bonds......................................................... 18 Section 3.03. Establishment and Application of Costs of Issuance Fund ................................... 19 Section 3.04. Validity of 2020 Bonds......................................................................................... 19 Section 3.05. Acquisition Fund.................................................................................................. 19 Section 3.06. Changes to the 2020 Project................................................................................. 19 ARTICLE IV REDEMPTION OF 2020 BONDS Section 4.01. Terms of Redemption........................................................................................... 20 Section 4.02. Selection of 2020 Bonds for Redemption............................................................. 20 Section 4.03. Notice of Redemption........................................................................................... 21 Section 4.04. Partial Redemption of 2020 Bonds....................................................................... 21 Section 4.05. Effect of Redemption............................................................................................ 21 ARTICLE V REVENUES, FUNDS AND ACCOUNTS; PAYMENT OF PRINCIPAL AND INTEREST Section 5.01. Pledge and Assignment; Revenue Fund............................................................... 22 Section 5.02. Allocation of Revenues......................................................................................... 23 TABLE OF CONTENTS (continued) Pare Section 5.03. Application of Interest Account............................................................................ 24 Section 5.04. Application of Principal Account......................................................................... 24 Section 5.05. Application of Redemption Fund......................................................................... 24 Section5.06. Investments ........................................................................................................... 24 Section5.07. Rebate Fond.......................................................................................................... 25 Section 5.08. Establishment and Application of Rate Stabilization Fund .................................. 26 Section5.09. Reserve Fund........................................................................................................ 27 Section 5.10. Application of Funds and Accounts When No 2020 Bonds are Outstanding....... 27 ARTICLE VI PARTICULAR COVENANTS Section 6.01. Punctual Payment................................................................................................. 28 Section 6.02. Extension of Payment of 2020 Bonds.................................................................. 28 Section 6.03. Against Encumbrances......................................................................................... 28 Section 6.04. Power to Issue 2020 Bonds and Make Pledge and Assignment ........................... 28 Section 6.05. Accounting Records and Financial Statements.................................................... 28 Section 6.06. Tax Covenants...................................................................................................... 29 Section 6.07. Waiver of Laws..................................................................................................... 30 Section 6.08. Further Assurances............................................................................................... 30 Section6.09. Budgets................................................................................................................. 30 Section 6.10. Observance of Laws and Regulations................................................................... 30 Section 6.11. Compliance with Contracts................................................................................... 30 Section 6.12. Prosecution and Defense of Suits......................................................................... 30 Section 6.13. Continuing Disclosure .......................................................................................... 31 Section 6.14. Additional Contracts and Bonds........................................................................... 31 Section 6.15. Against Sale or Other Disposition of Property ..................................................... 32 Section 6.16. Against Competitive Facilities............................................................................. 32 Section 6.17. Maintenance and Operation of the Water System ................................................ 32 Section 6.18. Payment of Claims................................................................................................ 32 Section6.19. Insurance............................................................................................................... 33 Section 6.20. Payment of Taxes and Compliance with Governmental Regulations .................. 33 Section 6.21. Amount of Rates and Charges.............................................................................. 34 Section 6.22. Collection of Rates and Charges........................................................................... 34 Section 6.23. Eminent Domain Proceeds................................................................................... 34 Section 6.24. Enforcement of Contracts..................................................................................... 35 ARTICLE VB EVENTS OF DEFAULT AND REMEDIES OF 2020 BOND OWNERS Section 7.01. Events of Default.................................................................................................. 35 Section 7.02. Remedies Upon Event of Default......................................................................... 36 Section 7.03. Application of Revenues and Other Fonds After Default ..................................... 36 Section 7.04. Trustee to Represent 2020 Bond Owners............................................................. 37 Section 7.05. 2020 Bond Owners' Direction of Proceedings..................................................... 38 Section 7.06. Suit by Owners ..................................................................................................... 38 TABLE OFCONTE TY (continued) Page Section 7.07. Absolute Obligation of the City ............................................................................ 39 Section 7.08. Remedies Not Exclusive....................................................................................... 39 Section 7.09. No Waiver of Default........................................................................................... 39 ARTICLE VIII THE TRUSTEE Section 8.01. Duties, Immunities and Liabilities of Tmstee...................................................... 39 Section 8.02. Merger in Consolidation....................................................................................... 40 Section 8.03. Liability of Trustee............................................................................................... 41 Section 8.04. Right to Rely on Documents................................................................................. 43 Section 8.05. Preservation and Inspection of Documents.......................................................... 44 Section 8.06. Compensation andIndemnification...................................................................... 44 ARTICLE IX MODIFICATION OR AMENDMENT OF THE INDENTURE Section 9.01. Amendments Permitted........................................................................................ 44 Section 9.02. Effect of Supplemental Indenture......................................................................... 46 Section 9.03. Endorsement of 2020 Bonds; Preparation of New 2020 Bonds ........................... 46 Section 9.04. Amendment of Particular 2020 Bonds................................................................. 46 ARTICLE X DEFEASANCE Section 10.01. Discharge of Indenture......................................................................................... 46 Section 10.02. Discharge of Liability on 2020 Bonds.................................................................. 47 Section 10.03. Deposit of Money or Securities with Trustee....................................................... 47 Section 10.04. Payment of 2020 Bonds After Discharge of Indenture ......................................... 48 ARTICLE XI MISCELLANEOUS Section 11.01. Liability of City Limited to Revenues.................................................................. 48 Section 11.02. Successor Is Deemed Included in All References to Predecessor ........................ 48 Section 11.03. Limitation of Rights to Parties and 2020 Bond Owners ....................................... 48 Section 11.04. Waiver of Notice; Requirement of Mailed Notice ................................................ 49 Section 11.05. Destruction of 2020 Bonds...................................................................................49 Section 11.06. Severability of Invalid Provisions........................................................................49 Section11.07. Notices..................................................................................................................49 Section 11.08. Evidence of Rights of 2020 Bond Owners...........................................................49 Section 11.09. Disqualified 2020 Bonds...................................................................................... 50 Section It. 10. Money Held for Particular 2020 Bonds................................................................ 50 Section 11.11. Funds and Accounts.............................................................................................. 50 iii TABLE OF CONTENTS (continued) Pare Section 11.12. Waiver of Personal Liability................................................................................. 50 Section 11.13. Execution in Several Counterparts....................................................................... 51 Section 11.14. CUSIP Numbers ...................................................................................................51 Section 11.15. Choice of Law....................................................................................................... 51 Section 11.16. Paired Obligation Provider Guidelines................................................................. 51 Signatures S-1 Exhibit A Form of 2020 Bond............................................................................................. A-1 Exhibit B Description of2020 Project................................................................................ B-1 iv INDENTURE OF TRUST TIES INDENTURE OF TRUST is made and entered into and dated as of March 1, 2020 (the `Indenture'), by and between the CITY OF VERNON, a municipal corporation that is duly organized and existing under its charter and the Constitution of the State of California (the "City"), and THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., a national banking association that is duly organized and existing under the laws of the United States of America, as trustee hereunder (the "Trustee'). RECITALS A. The City desires to finance certain capital improvements to its municipal water system. B. The City is authorized pursuant to Article H of the City's charter and Article XI of the City's Code of Ordinances to issue revenue bonds for the purpose of financing capital improvements to its municipal water system; and. C. In order to provide for the authentication and delivery of water revenue bonds (the "2020 Bonds"), to establish and declare the terms and conditions upon which such 2020 Bonds are to be issued and secured and to secure the payment of the principal thereof and interest and premium, if any, thereon, the City has authorized the execution and delivery of this Indenture. D. The City has determined that all acts and proceedings which are required by law and necessary to make the 2020 Bonds, when executed by the City, authenticated and delivered by the Trustee, and duly issued, the valid, binding and legal special obligations of the City, and to constitute the Indenture a valid and binding agreement for the uses and purposes herein set forth in accordance with its terms, have been done and taken, and the execution and delivery of the Indenture have been in all respects duly authorized; GRANTING CLAUSES The City, in consideration of the premises and the acceptance by the Trustee of the trusts hereby created and of the mutual covenants herein contained and of the purchase and acceptance of the 2020 Bonds by the owners thereof, and for other valuable considerations, the receipt whereof is hereby acknowledged, in order to secure the payment of the principal of and the interest and premium (if any) on all 2020 Bonds at any time issued and Outstanding under the Indenture, according to their tenor, and to secure the performance and observance of all the covenants and conditions therein and herein set forth, does hereby assign and pledge unto, and grant a security interest in, the following (the "Trust Estate") to the Trustee, and its successors in tout and assigns forever, for the securing of the performance of the obligations of the City to the 2020 Bond Owners hereinafter set forth: FIRST All right, title and interest of the City in and to the Revenues (as such term is defined herein), including, but without limiting the generality of the foregoing, the present and continuing right to make claim for, collect, receive and receipt for any Revenues payable to or receivable by the City under the Constitution of the State, the Government Code of the State, the Indenture, the charter of the City and any other applicable laws of the State or otherwise, to bring actions and proceedings thereunder for the enforcement thereof, and to do any and all things which the City is or may become entitled to do thereunder, subject to the terms hereof. SECOND All moneys and securities held in funds and accounts of this Indenture, except amounts which are held in the Rebate Fund, and all other rights of every name and nature from time to time herein or hereafter by delivery or by writing of any kind pledged, assigned or transferred as and for additional security hereunder to the Trustee by the City or by anyone on its behalf, or with its written consent, and to hold and apply the same, subject to the terms hereof. TO HAVE AND TO HOLD all and singular the Trust Estate, whether now owned or hereafter acquired, unto the Trustee and its respective successors in trust and assigns forever for the benefit of the Owners, and such pledge shall constitute a lien on and security interest in such Trust Estate; IN TRUST, upon the terms and trusts herein set forth for the equal and proportionate benefit, security and protection of all present and future owner: of the 2020 Bonds issued under and secured by the Indenture without privilege, priority or distinction as to the lien or otherwise of any of the 2020 Bonds over any of the other 2020 Bonds; PROVIDED, HOWEVER, that if the City, its successors or assigns shall well and truly pay, or cause to be paid, the principal of and interest and any redemption premium on the 2020 Bonds due or to become due thereon, at the times and in the manner provided in the 2020 Bonds according to the true intent and meaning thereof, and shall well and truly keep, perform and observe all of the covenants and conditions pursuant to the terns of the Indenture to be kept, performed and observed by it, and shall pay or cause to be paid to the Trustee all sums of money due or to become due in accordance with the terms and provisions hereof, then upon such final payments or deposits as herein provided, the Indenture and the rights hereby granted shall cease, terminate and be void; otherwise the Indenture shall remain in full force and effect. It is expressly declared that all 2020 Bonds which me issued and secured hereunder me to be issued, authenticated and delivered, and all sold property, rights and interests, including, without limitation, the Revenues, which are hereby assigned and pledged, are to be dealt with and disposed of, under, upon and subject to the terns, conditions, stipulations, covenants, agreements, trusts, uses and purposes hereinafter expressed, and the City has agreed and covenanted and does hereby covenant and agree with the Trustee, for the benefit of the respective Owners from time to time of the 2020 Bonds, as follows: ARTICLE I DEFINITIONS; CONTENT OF CERTIFICATES AND OPINIONS Section 1.01. Definitions. Unless the context otherwise requires, the terns defined in this Section 1.01 shall, for all purposes of the Indenture and of any indenture supplemental hereto and of any certificate, opinion or other document herein mentioned, have the meanings herein specified, to be equally applicable to both the singular and plural forms of any of the terms herein defined. Accountant's Report. The tern "Accountant's Report" means a report signed by an Independent Certified Public Accountant. Acquisition Fund. The term "Acquisition Fund" means the fund by that name created pursuant to Section 3.05 of the Indenture. Authorized Representative. The term "Authorized Representative" means, with respect to the City, its Mayor, Mayor Pro Tempore, City Clerk, City Administrator, Finance Director or any other person designated as an Authorized Representative of the City by a Certificate of the City signed by its Mayor, Mayor Pro Tempore, City Clerk, City Administrator or Finance Director and filed with the Trustee. Bond Counsel. The tern "Bond Counsel" means Stradling Yocca Carlson & Rauth, a Professional Corporation, or another firm of nationally recognized attorneys experienced in the issuance of obligations the interest on which is excludable from gross income under Section 103 of the Code. Bonds. The tern "Bonds" means all revenue bonds or notes of the City authorized, executed, issued and delivered by the City, the payments of which are payable from Net Revenues on a parity with the 2020 Bonds and which are secured by a pledge of and lien on Revenues as described in Section 5.01 hereof. Bond Year. The tern "Bond Year' has the meaning that is set forth in the Tax Certificate. Business Day. The term "Business Day" means: (1) a day which is not a Saturday, Sunday or legal holiday on which banking institutions in the State, or in any other state in which the Office of the Trustee is located, we closed; or (2) a day on which the New York Stock Exchange is not closed. Certificate; Direction Request; Requisition. The terms "Certificate," "Direction," "Request" and "Requisition" of the City mean a written certificate, direction, request or requisition signed in the name of the City by its Authorized Representative. 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 1.02, each such instrument shall include the statements provided for in Section 1.02. CC. The term "City" means the City of Vernon, a municipal corporation that is duly organized and existing under its charter and the Constitution of the State of California. Closing Date. The term "Closing Date" means the date on which the 2020 Bonds are delivered to the original purchaser thereof. Code. The term "Code" means the Internal Revenue Code of 1986, as amended. Continuing Disclosure Agreement. The term "Continuing Disclosure Agreement" means the Continuing Disclosure Agreement dated as of March 1, 2020, by and between the City and the Trustee, as dissemination agent, relating to the 2020 Bonds, as originally executed or as it may be from time to time amended or supplemented in accordance with its terms. Contracts. The term "Contracts" means all contracts of the City previously or hereafter authorized and executed by the City, the payments under which are payable from Net Revenues on a parity with the 2020 Bonds and which are secured by a pledge and lien on Revenues as described in Section 5.01 hereof, but excluding contracts entered into for operation and maintenance of the Water System. Costs of Issuance. The term "Costs of Issuance" means all items of expense directly or indirectly payable by or reimbursable to the City and related to the authorization, issuance, sale and delivery of the 2020 Bonds, including but not limited to costs of preparation and reproduction of documents, printing expenses, filing and recording fees, initial fees and charges of the Trustee and counsel to the Trustee, legal fees and charges, fees and disbursements of consultants and professionals, rating agency fees, title insurance premiums, letter of credit fees and bond insurance premiums (if any), fees and charges for preparation, execution and safekeeping of the 2020 Bonds and any other cost, charge or fee in connection with the original issuance of the 2020 Bonds. Costs of Issuance Fund. The term "Costs of Issuance Fund" means the fund by that name established pursuant to Section 3.03. Debt Service. The tern "Debt Service" means, for any period of calculation, the sum of. (1) the interest payable during such period on all outstanding Bonds, assuming that all outstanding serial Bonds are retired as scheduled and that all outstanding term Bonds are redeemed or paid from sinking fund payments as scheduled (except to the extent that such interest is capitalized or is reasonably anticipated to be reimbursed to the City by the United States of America pursuant to Section 54AA of the Code (Section 1531 of Title 1 of Division B of the American Recovery and Reinvestment Act of 2009 (Pub. L. No. 111-5, 23 Stat. 115 (2009), enacted February 17, 2009)), or any future similar program); (2) those portions of the principal amount of all outstanding serial Bonds maturing in such period; (3) those portions of the principal amount of all outstanding term Bonds required to be redeemed or paid in such period; and (4) those portions of the Contracts required to be paid during such period, (except to the extent that the interest evidenced and represented thereby is capitalized or is reasonably anticipated to be reimbursed to the City by the United States of America pursuant to Section 54AA of the Code (Section 1531 of Title f of Division B of the American Recovery and Reinvestment Act of 2009 (Pub. L. No. 111-5, 23 Star. 115 (2009), enacted February 17, 2009)), or any future similar program); but less the earnings to be derived from the investment of moneys on deposit in debt service reserve funds established for Bonds or Contracts; provided that, as to any such Bonds or Contracts bearing or comprising interest at other than a fixed rate, the rate of interest used to calculate Debt Service shall, for all purposes, be assumed to bear interest at a fixed rate equal to the higher of: (1) the then current variable interest rate borne by such Bonds or Contracts plus 1%; and (ii) the highest variable rate home over the preceding 24 months by outstanding variable rate debt issued by the City or, if no such variable rate debt is at the time outstanding, by variable rate debt of which the interest rate is computed by reference to an index comparable to that to be utilized in determining the interest rate for the debt then proposed to be issued; provided further that if any series or issue of such Bonds or Contracts have twenty-five percent (25%) or more of the aggregate principal amount of such series or issue due in any one year, Debt Service shall be determined for the period of determination as if the principal of and interest on such series or issue of such Bonds or Contracts were being paid from the date of incurrence thereof in substantially equal annual amounts over a period of twenty-five (25) years from the date of calculation; and provided further that, as to any such Bonds or Contracts or portions thereof bearing no interest but which are sold at a discount and which discount accretes with respect to such Bonds or Contracts or portions thereof, such accreted discount shall be treated as interest in the calculation of Debt Service; and provided further that if the Bonds or Contracts constitute Paired Obligations, the interest rate on such Bonds or Contracts shall be the resulting linked rate or the effective fixed interest rate to be paid by the City with respect to such Paired Obligations, but only if the applicable Paired Obligations satisfies the requirement set forth in Section 11.16 hereof; and provided further that the amount on deposit in a debt service reserve fund (including the Reserve Fund) on any date of calculation of Debt Service shall be deducted from the amount of principal due at the final maturity of the Bonds and Contracts for which such debt service reserve fund was established and to the extent that the amount in such debt service reserve fund is in excess of such amount of principal, such excess shall be applied to the full amount of principal due, in each preceding year, in descending order, until such amount is exhausted. Deoositorv; DTC. The term "Depository" or "DTC" means 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 2020 Bonds. Event of Default. The term "Event of Default" means any of the events specified in Section 7.01 Federal Securities. The term "Federal Securities" means any direct, noncallable general obligations of the United States of America (including obligations issued or held in book entry form on the books of the Department of the Treasury of the United States of America), or noncallable obligations the timely payment of principal of and interest on which are fully and unconditionally guaranteed by the United States of America. Fiscal Year. The term "Fiscal Year' means the twelve month period beginning on July I of each year and ending on the next succeeding June 30, both dates inclusive, or any other twelve month period hereafter selected and designated as the official fiscal year period of the City. Fitch. The term "Fitch" means Fitch Ratings, Inc., or any successor thereto. Generally Accepted Accounting Principles. The term "Generally Accepted Accounting Principles" means the uniform accounting and reporting procedures set forth in publications of the American Institute of Certified Public Accountants or its successor, or by any other generally accepted authority on such procedures, and includes, as applicable, the standards set forth by the Governmental Accounting Standards Board or its successor. Indenture. The term "Indenture" means the Indenture of Trust, dated as of Match 1, 2020, by and between the City and the Trustee, as originally executed or as it may from time to time be supplemented, modified or amended by any Supplemental Indenture. Independent Certified Public Accountant. The tens "Independent Certified Public Accountant" means any firm of certified public accountants appointed by the City, each of whom is independent of the City pursuant to the Statement on Auditing Standards No. 1 of the American Institute of Certified Public Accountants. Independent Financial Consultant. The term "Independent Financial Consultant" means a financial consultant or firm of such consultants appointed by the City, who, or each of whom: (1) is in fact independent and not under domination of the City; (2) does not have any substantial interest, direct or indirect, with the City; and (3) is not connected with the City as an officer or employee thereof, but who may be regularly retained to make reports thereto. Information Services. The term "Information Services" means the Municipal Securities Rulemaking Board; or, in accordance with thencurrent guidelines of the Securities and Exchange Commission, such other services providing information with respect to called bonds as the City may specify in a certificate to the Trustee. htitial Rating Requirement. The term `Initial Rating Requirement" means the rating requirement described in Section 1 t.16(a). Insurer. The term "Insurel' means Interest Account. The term "Interest Account" means the account by that name in the Payment Food established pursuant to Section 5.02. Interest Payment Date. The term "Interest Payment Date" means [August 1, 2020] and each February I and August 1 thereafter. Investment Agreement. The term `Investment Agreement" means any investment agreement (including guaranteed investment contracts, forward delivery agreements, repurchase agreements or similar obligations) with, or guaranteed by, an entity the long-term unsecured obligations or the claims paying ability of which are rated "A" or better by a nationally recognized rating agency (without regard to gradations or modifiers within such category) at the time of initial investment. Letter of Representations. The term "Letter of Representations" means the letter of the City delivered to and accepted by the Depository on or prior to delivery of the 2020 Bonds as book entry bonds setting forth the basis on which the Depository serves as depository for such book entry bonds, as originally executed or as it may be supplemented or revised or replaced by a letter from the City delivered to and accepted by the Depository. Minimum Ratite Requirement. The tern "Minimum Rating Requirement" means the rating requirement described in Section 11.16(b). Moody's. The term "Moody's" means Moody's Investors Service, Inc. or any successor thereto Net Proceeds. The term "Net Proceeds" means, when used with respect to any casualty insurance or condemnation award, the proceeds from such insurance or condemnation award remaining after payment of all expenses (including attorneys' fees) incurred in the collection of such proceeds. Net Revenues. The term "Net Revenues" means, for any period, the Revenues for such period less the Operation and Maintenance Costs for such period. When held by the Trustee in any funds or accounts established hereunder, Net Revenues shall include all interest or realized gain derived from the investment of amounts in any of such funds or accounts. Nominee. The term "Nominee" means the nominee of the Depository, which may be the Depository, as determined from time to time pursuant to Section 2.08 hereof. Office. The term "Office" means with respect to the Trustee, the corporate trust office of the Trustee at 400 South Hope Street, Suite 500, Los Angeles, California 90071, Attention: Corporate Trust, Reference: City of Vemon 2020 Water Bonds, or such other or additional offices as may be specified in writing by the Trustee to the City, except that with respect to presentation of 2020 Bonds for payment or for registration of transfer and exchange, such term means the office or agency of the Trustee at which, at any particular time, its corporate trust agency business shall be conducted Operation and Maintenance Costs. The term "Operation and Maintenance Costs" means: (1) costs spent or incurred for maintenance and operation of the Water System calculated in accordance with Generally Accepted Accounting Principles applicable to governmental agencies, including, but not limited to, the reasonable expenses of management and repair and other expenses necessary to maintain and preserve the Water System in good repair and working order, and including administrative costs of the City that are charged directly or apportioned to the Water System, including but not limited to salaries and wages of employees, payments to the Public Employees Retirement System, overhead insurance, taxes (if any), fees of auditors, accountants, attorneys or engineers and insurance premiums, and including all other reasonable and necessary costs of the City or charges (other than debt service payments) required to be paid by it to comply with the terns of the 2020 Bonds or of this Indenture or any Contract or of any resolution or indenture authorizing the issuance of any Bonds or of such Bonds; and (2) all payments under any contract for the purchase of water; but excluding in all cases depreciation, replacement and obsolescence charges or reserves therefor and amortization of intangibles or other bookkeeping entries of a similar nature. Opinion of Counsel. The term "Opinion of Counsel" means a written opinion of counsel (including but not limited to counsel to the City) selected by the City. If and to the extent required by the provisions of Section 1.02, each Opinion of Counsel shall include the statements provided for in Section 1.02. Outstandine. The term "Outstanding," when used as of any particular time with reference to 2020 Bonds, means (subject to the provisions of Section 11.09) all 2020 Bonds theretofore or thereupon being authenticated and delivered by the Trustee under the Indenture except: (i) 2020 Bonds theretofore canceled by the Trustee or surrendered to the Trustee for cancellation; (ii) 2020 Bonds with respect to which all liability of the City shall have been discharged in accordance with Section 10.02, including 2020 Bonds (or portions thereof) described in Section 11.09; and (iii) 2020 Bonds for the transfer or exchange of or in lieu of or in substitution for which other 2020 Bonds shall have been authenticated and delivered by the Trustee pursuant to the Indenture. Owner; 2020 Bond Owner. The term "Owner' or "2020 Bond Owner," whenever used herein with respect to a 2020 Bond, means the person in whose name the ownership of such 2020 Bond is registered on the Registration Books. Paired Obligation Provider. The term "Paired Obligation Provider" means a party to a Paired Obligation other than the City. Paired Obligations. The term "Paired Obligations" means any Bond or Contract (or portion thereof) designated as Paired Obligations in the resolution, indenture or other document authorizing the issuance or execution and delivery thereof, which are simultaneously issued or executed and delivered: (i) the principal of which is of equal amount maturing and to be redeemed or prepaid (or cancelled after acquisition thereof) on the same dates and in the same amounts; and (ii) the interest rates which, taken together, are reasonably expected to result in a fixed interest rate obligation of the City for the term of such Bond or Contract, as certified by an Independent Financial Consultant in writing, and which comply with the provisions of Section 11.16 hereof. Participants. The term "Participants" means those broker -dealers, banks and other financial institutions from time to time for which the Depository holds book entry certificates as securities depository. Payment Fund. The term "Payment Fund" means the fund by that name established pursuant to Section 5.02. Permitted Investments. The term "Permitted Investments" means any of the following which at the time of investment are legal investments under the laws of the State for the moneys proposed to be invested therein. The Trustee is entitled to rely upon the written investment direction of the City as a representation that such investment constitutes a legal investment under the laws of the State. (a) for all purposes, including but not limited to defeasance investments in refunding escrow accounts: (1) cash (insured at all times by the Federal Deposit Insurance Corporation or otherwise collateralized with obligations described in paragraph (2) below); and (2) direct obligations of the United States of America (including obligations issued or held in book entry form on the books of the Department of the Treasury, including REFCORP Interest STRIPS) or obligations the principal of and interest on which are unconditionally guaranteed by the United States of America; and (b) for all purposes other than defeasance investments in refunding escrow accounts: (1) obligations of any of the following federal agencies which obligations represent full faith and credit of the United States of America, including the Export - Import Bank; Farmers Home Administration; General Services Administration; U.S. Maritime Administration; Government National Mortgage Association (GNMA); U.S. Department of Housing & Urban Development (PHA's); and Federal Housing Administration; (2) bonds, notes or other evidences of indebtedness rated at least "AA-" or "Aa3" by the applicable Rating Agency issued by Fannie Mae or the Federal Home Loan Mortgage Corporation with remaining maturities not exceeding three years; (3) U.S. dollar denominated deposit accounts, certificates of deposit (including those placed by a third party pursuant to a separate agreement between the City and the Trustee), other deposit products, time deposits, trust funds, trust accounts, interest -bearing deposits, overnight bank deposits, interest - bearing money market accounts, federal funds and banker's acceptances with domestic commercial banks (including the Trustee and its affiliates) which are either insured by the Federal Deposit Insurance Corporation or have a rating on their short term certificates of deposit on the date of purchase of "A -I" or "A -I+" by S&P and "P-I" by Moody's and maturing no more than 360 days after the date of purchase (ratings on holding companies are not considered as the rating of the bank); (4) commercial paper which is rated at the time of purchase in the single highest classification, "A-1+" by S&P and "P-I" by Moody's and which matures not more than 270 days after the date of purchase; (5) investments in a money market fund rated "AAm", "AAm-G", "AAAm" or "AAAm- G" or better by S&P, including such funds for which the Trustee or an affiliate receives and retains a fee for services provided to the fund, whether as a custodian, transfer agent, investment advisor or otherwise; (6) pre -refunded municipal obligations defined as follows: any bonds or other obligations of any state of the United States of America or of any agency, instrumentality or local governmental unit of any such state which are not callable at the option of the obligor prior to maturity or as to which irrevocable instructions have been given by the obligor to call on the date specified in the notice and which are rated, based on the escrow, in the highest rating category of S&P and Moody's; (7) any Investment Agreement; and (8) the Local Agency Investment Fund. Principal Account. The term "Principal Account" means the account by that name in the Payment Fund established pursuant to Section 5.02. Rate Stabilization Fund. The term "Rate Stabilization Fund" means the fund by that name established pursuant to Section 5.08. Rating. The term "Rating" means any currently effective rating on the 2020 Bonds issued by a Raring Agency. Rating Agencies. The term "Rating Agencies" means S&P, Moody's or Fitch, as the context dictates. Rebate Fund. The term "Rebate Fund" means the fund by that name established pursuant to Section 5.07. Record Date. The term "Record Date" means, with respect to any Interest Payment Date, the fifteenth (15th) day of the calendar month preceding such Interest Payment Date, whether or not such day is a Business Day. Redemption Date. The term "Redemption Date" means the date fixed for an optional redemption prior to maturity of the 2020 Bonds. Redemption Fund. The term `Redemption Fund" means the fund by that name established pursuant to Section 5.05. Redemption Price. The tern `Redemption Price" means, with respect to any 2020 Bond (or portion thereof), the principal amount of such 2020 Bond (or portion) plus the interest accrued to the applicable Redemption Date and the applicable premium, if any, payable upon redemption thereof pursuant to the provisions of such 2020 Bond and the Indenture. Registration Books. The term "Registration Books" means the records maintained by the Trustee for the registration of ownership and registration of transfer of the 2020 Bonds pursuant to Section 2.05. Reserve Fund. The term "Reserve Fund" means the fund by that name established in Section 5.09 hereof. Reserve Policv. The term `Reserve Policy" means Municipal Bond Debt Service Reserve Insurance Policy No. issued by the Insurer on the date of issuance of the 2020 Bonds. Reserve Requitement. The term "Reserve Requirement" means initially, $, and thereafter the lesser of. (i) $; or (ii) the least of. (a) the maximum principal of and interest on the 2020 Bonds due in the then current or any future Fiscal Year; (b) 125% of average annual Debt Service on the Outstanding 2020 Bonds; or (c) 10% of the then -Outstanding principal amount of the 2020 Bonds. Responsible Officer of the Trustee. The term "Responsible Officer of the Trustee" means any officer within the corporate trust services division (or any successor group or department of the Trustee) including any vice president, assistant vice president, assistant secretary or any other officer or assistant officer of the Trustee within the Office (or any successor corporate trust office) customarily performing functions similar to those performed by the persons who at the time shall be such officers, respectively, or to whom any corporate trust matter is referred at the Office because of such persot's knowledge of any familiarity with the particular subject and having direct responsibility for the administration of this Indenture. Revenue Fund. The term "Revenue Fund" means the Water Enterprise Fund of the City and/or such other fund or account of the City in which Revenues are deposited Revenues. The tern "Revenues" means all income, rents, rates, fees, charges and other moneys derived from the ownership of or operation of the Water System, including, without limiting the generality of the foregoing: (1) all in lieu charges and groundwater augmentation charges (including investment eammgs thereon) collected by or on behalf of the City; (2) all income, rents, rates, fees, charges, business interruption insurance proceeds or other moneys derived by the City from the sale, furnishing and supplying of the water, drainage or other services, facilities, and commodities sold, furnished or supplied through the facilities of or in the conduct or operation of the business of the Water System; and (3) the earnings on and income derived from the investment of such income, rents, rates, fees, charges, proceeds or other moneys, including City reserves, but excluding in all cases: (y) customers' deposits or any other deposits or advances subject to refund until such deposits or advances have become the property of the City; and (z) proceeds of taxes or benefit assessments restricted by law to be used by the City to pay amounts due on bonds or other obligations hereafter incurred. "Revenues" also include all amounts transferred from the Rate Stabilization Fund to the Revenue Fund during any Fiscal Year in accordance with Section 5.08. "Revenues" do not include any amounts transferred from the Revenue Fund to the Rate Stabilization Fund during any Fiscal Year in accordance with Section 5.01(b)(iii). 10 S&P. The term "S&P" means S&P Global Ratings, a Standard & Poor's Financial Services LLC business, or any successor thereto. Securities Depositories. The tens "Securities Depositories" means The Depository Trust Company; and, in accordance with then current guidelines of the Securities and Exchange Commission, such other addresses and/or such other securities depositories as the City may designate in a Written Request of the City delivered to the Trustee. State. The term "State" means the State of California. Supplemental Indenture. The term "Supplemental Indenture" means any indenture hereafter duly authorized and entered into between the City and the Trustee, supplementing, modifying or amending the Indenture; but only if and to the extent that such Supplemental Indenture is specifically authorized hereunder. Tax Certificate. The term `Tax Certificate" means the Tax Certificate dated the Closing Date, concerning certain matters pertaining to the use and investment of proceeds of the 2020 Bonds issued by the City on the date of issuance of the 2020 Bonds, including any and all exhibits attached thereto. Term Bond. The term "Term Bond" means the 2020 Bonds maturing on August 1, 20_. Trustee. The term `Trustee" means The Bank of New York Mellon Trust Company, N.A., a national banking association duly organized and existing under the laws of the United States of America, or its successor as Trustee hereunder as provided in Section 8.01. 2020 Bonds. The tens "2020 Bonds" means the City of Vernon Water System Revenue Bonds, 2020 Series A issued by the City and at any time Outstanding pursuant to the Indenture. 2020 Project. The tens "2020 Project" means those Water System capital improvements that are described in Exhibit B. Water Service. The term "Water Service" means the potable and recycled water distribution service that is made available or provided by the Water System. Water System. The term "Water System" means the whole and each and every part of the waterworks system serving the City, whether owned or operated by the City or another party, including the portion thereof existing on the date hereof, and including all additions, betterments, extensions and improvements to such water system or any part thereof hereafter acquired or constructed. The recycled water system of the City is part of the Water System. Written Consent of the City; Written Order of the Citv; Written Request of the City; Written Requisition of the Citv. The terms "Written Consent of the City," "Written Order of the City," "Written Request of the City" and "Written Requisition of the City" mean, respectively, a written consent, order, request or requisition signed by or on behalf of the City by an Authorized Representative of the City or by any two persons who are specifically authorized by resolution of the City to sign or execute such a document on its behalf. Section 1.02. Content of Certificates and Minions. Every certificate or opinion provided for in the Indenture except the certificate of destruction provided for in Section 11.05 hereof, with 11 respect to compliance with any provision hereof shall include: (a) a statement that the person making or giving such certificate or opinion has read such provision and the definitions herein relating thereto; (b) a brief statement as to the nature and scope of the examination or investigation upon which the certificate or opinion is based; (c) a statement 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 referred to in the instrument to which his or her signature is affixed; (d) a statement of the assumptions upon which such certificate or opinion is based and that such assumptions are reasonable; and (e) a statement as to whether, in the opinion of such person, such provision has been complied with. Any such certificate or opinion made or given by an officer of the City may be based, insofar as it relates to legal or accounting matters, upon a certificate or opinion of or representation by counsel or an Independent Certified Public Accountant or Independent Financial Consultant, unless such officer knows, or in the exercise of reasonable care should have known, that the certificate, opinion or representation with respect to the matters upon which such certificate or statement may be based, as aforesaid, is erroneous. Any such certificate or opinion made or given by counsel or an Independent Certified Public Accountant or Independent Financial Consultant may be based, insofar as it relates to factual matters (with respect to which information is in the possession of the City) upon a certificate or opinion of or representation by an officer of the City, unless such counsel or Independent Certified Public Accountant or Independent Financial Consultant knows, or in the exercise of reasonable care should have known, that the certificate or opinion or representation with respect to the matters upon which such person's certificate or opinion or representation may be based, as aforesaid, is erroneous. The same officer of the City, or the same counsel or Independent Certified Public Accountant or Independent Financial Consultant, as the case may be, need not certify to all of the matters required to be certified under any provision of the Indenture, but different officers, counsel or Independent Certified Public Accountants or Independent Financial Consultants may certify to different matters, respectively. Section 1.03. Interpretation. (a) Unless the context otherwise indicates, words expressed in the singular shall include the plural and vice versa and the use of the neuter, masculine, or feminine gender is for convenience only and shall be deemed to include the neuter, masculine or feminine gender, as appropriate. (b) Headings of articles and sections herein and the table of contents hereof are solely for convenience of reference, do not constitute a part hereof and shall not affect the meaning, construction or effect hereof. (c) All references herein to "Articles," "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of the Indenture; the words "herein," "hereof," "hereby," "hereunder" and other words of similar import refer to the Indenture as a whole and not to any particular Article, Section or subdivision hereof. 12 ARTICLE II THE 2020 BONDS Section 2.01. Authorization of 2020 Bonds. The City hereby authorizes the issuance hereunder from time to time of the 2020 Bonds, which shall constitute special obligations of the City, for the purposes of financing the 2020 Project. The 2020 Bonds are hereby designated the "City of Vernon Water System Revenue Bonds, 2020 Series A" in the aggregate principal amount of $_ The Indenture constitutes a continuing agreement with the Owners from time to time of the 2020 Bonds to secure the full payment of the principal of and interest and premium (if any) on all the 2020 Bonds, subject to the covenants, provisions and conditions herein contained. Section 2.02. Terms of the 2020 Bonds. The 2020 Bonds shall be issued in fully registered form without coupons in denominations of $5,000 or any integral multiple thereof. The 2020 Bonds shall mature on August 1 in each of the years and in the amounts set forth below and shall bear interest on each Interest Payment Date at the rates set forth below: Maturity Date (August 1) Principal Amount Interest Rate 20 $ % Interest on the 2020 Bonds shall be payable on each Interest Payment Date to the person whose name appears on the Registration Books as the Owner thereof as of the Record Date immediately preceding each such Interest Payment Date, such interest to be paid by check of the Trustee sent by first class mail on the applicable Interest Payment Date to the Owner at the address of such Owner as it appears on the Registration Books (except that in the case of an Owner of one million dollars ($1,000,000) or more in principal amount, such payment may, at such Owner's option, be made by wire transfer of immediately available funds to an account in the United States in accordance with written instructions provided to the Trustee by such Owner prior to the Record Date. Principal of and premium (if any) on any 2020 Bond shall be paid by check of the Trustee upon presentation and surrender thereof at maturity or upon the prior redemption thereof, at the Office of the Trustee. Both the principal of and interest and premium (if any) on the 2020 Bonds shall be payable in lawful money of the United States of America. 13 Each 2020 Bond shall be dated the date of initial delivery, and shall bear interest from the Interest Payment Date next preceding the date of authentication thereof unless: (a) it is authenticated after a Record Date and on or before the following Interest Payment Date, in which event it shall bear interest from such Interest Payment Date; or (b) unless it is authenticated on or before [July 15, 20201, in which event it shall bear interest from the date of initial delivery; provided, however, that if, as of the date of authentication of any 2020 Bond, interest thereon is in default, such 2020 Bond shall hear interest from the Interest Payment Date to which interest has previously been paid or made available for payment thereon. Interest on the 2020 Bonds shall be calculated on the basis of a 360 day year composed of twelve 30 day months. Section 2.03. Transfer of 2020 Bonds. Any 2020 Bond may, in accordance with its terms, be transferred on the Registration Books by the person in whose name it is registered, in person or by his or her duly authorized attorney, upon surrender of such 2020 Bond at the Office of the Trustee for cancellation, accompanied by delivery of a written instrument of transfer, duly executed in a form acceptable to the Trustee. The Trustee shall not be required to register the transfer of any 2020 Bond during the period in which the Trustee is selecting 2020 Bonds for redemption and any 2020 Bond that has been selected for redemption. Whenever any 2020 Bond or 2020 Bonds shall be surrendered for transfer, the City shall execute and the Trustee shall authenticate and shall deliver a new 2020 Bond or 2020 Bonds of authorized denomination or denominations for a like series and aggregate principal amount of the same maturity. The Trustee shall require the 2020 Bond Owner requesting such transfer to pay any tax or other governmental charge required to be paid with respect to such transfer. Following any transfer of 2020 Bonds, the Trustee will cancel and destroy the 2020 Bonds that it has received. Prior to any transfer of the 2020 Bonds outside the book -entry system (including, but not limited to, the initial transfer outside the book -entry system) the transferor shall provide or cause to be provided to the Trustee all information necessary to allow the Trustee to comply with any applicable tax reporting obligations, including without limitation any cost basis reporting obligations under Code Section 6045, as amended. The Trustee shall conclusively rely on the information provided to it and shall have no responsibility to verify or ensure the accuracy of such information. Section 2.04. Exchange of 2020 Bonds. 2020 Bonds may be exchanged at the Office of the Trustee for a like aggregate principal amount of other authorized denominations of the same series and maturity. The Trustee shall not be required to exchange any 2020 Bond during the period in which the Trustee is selecting 2020 Bonds for redemption and any 2020 Bond that has been selected for redemption. The Trustee shall require the 2020 Bond Owner requesting such exchange to pay any tax or other governmental charge required to be paid with respect to such exchange. Following any exchange of 2020 Bonds, the Trustee will cancel and destroy the 2020 Bonds that it has received. Section 2.05. Registration Books. The Trustee will keep or cause to be kept, at the Office of the Trustee, sufficient records for the registration and transfer of ownership of the 2020 Bonds, which shall upon reasonable notice and at reasonable times be open to inspection during regular business hours by the City and the Owners; and, upon presentation for such purpose, the Trustee shall, under such reasonable regulations as it may prescribe, register or transfer or cause to be registered or transferred, on such records, the ownership of the 2020 Bonds as hereinbefore provided. The person in whose name any 2020 Bond shall be registered shall be deemed the owner thereof for all purposes hereof, and payment of or on account of the interest on and principal and 14 Redemption Price of by such 2020 Bonds shall be made only to or upon the order in writing of such registered Owner, which payments shall be valid and effectual to satisfy and discharge liability upon such 2020 Bond to the extent of the sum or sums so paid. Section 2.06. Form and Execution of 2020 Bonds. The 2020 Bonds shall be in substantially the form set forth in Exhibit A hereto. The 2020 Bonds shall be executed in the name and on behalf of the City with the manual or facsimile signature of its Mayor. The 2020 Bonds may carry a seal, and such seal may be in the form of a facsimile of the City's seat and may be reproduced, imprinted or impressed on the 2020 Bonds. The 2020 Bonds shall then be delivered to the Trustee for authentication by it. In case any of the officers who shall have signed or attested any of the 2020 Bonds shall cease to be such officer or officers of the City before the 2020 Bonds so signed or attested shall have been authenticated or delivered by the Trustee, or issued by the City, such 2020 Bonds may nevertheless be authenticated, delivered and issued and, upon such authentication, delivery and issue, shall be as binding upon the City as though those who signed and attested the same had continued to be such officers of the City, and also any 2020 Bonds may be signed and attested on behalf of the City by such persons as at the actual date of execution of such 2020 Bonds shall be the proper officers of the City although at the nominal date of such 2020 Bonds any such person shall not have been such officer of the City. Only such of the 2020 Bonds as shall bear thereon a certificate of authentication substantially in the form set forth in Exhibit A hereto, manually executed by the Trustee, shall be valid or obligatory for any purpose or entitled to the benefits of the Indenture, and such certificate of or on behalf of the Trustee shall be conclusive evidence that the 2020 Bonds so authenticated have been duly executed, authenticated and delivered hereunder and are entitled to the benefits of the Indenture. Section 2.07. 2020 Bonds Mutilated, Lost. Destroyed or Stolen. If any 2020 Bond shall become mutilated, the City, at the expense of the Owner of said 2020 Bond, shalt execute, and the Trustee shall thereupon authenticate and deliver, a new 2020 Bond of like tenor, series and authorized denomination in exchange and substitution for the 2020 Bonds so mutilated, but only upon surrender to the Trustee of the 2020 Bond so mutilated. Every mutilated 2020 Bond so surrendered to the Trustee shall be canceled by it and upon the Written Request of the City delivered to, or upon the order of, the City. If any 2020 Bond shall be lost, destroyed or stolen, evidence of such loss, destruction or theft may be submitted to the Trustee and, if such evidence be satisfactory to the Trustee and indemnity satisfactory to the Trustee shall be given, the City, at the expense of the Owner, shall execute, and the Trustee shall thereupon authenticate and deliver, a new 2020 Bond of like tenor, series and authorized denomination in lieu of and in substitution for the 2020 Bond so lost, destroyed or stolen (or if any such 2020 Bond shall have matured or shall be about to mature, instead of issuing a substitute 2020 Bond, the Trustee may pay the same without surrender thereof). The City may require payment by the Owner of a sum not exceeding the actual cost of preparing each new 2020 Bond issued under this Section and of the expenses which may be incurred by the City and the Trustee in the premises. Any 2020 Bond issued under the provisions of this Section in lieu of any 2020 Bond alleged to be lost, destroyed or stolen shall constitute an original additional contractual obligation on the part of the City whether or not the 2020 Bond so alleged to be lost, destroyed, or stolen be at any time enforceable by anyone, and shall be entitled to the benefits of the Indenture with all other 2020 Bonds secured by the Indenture. Notwithstanding any other provision of this Section, in lieu of delivering a new 2020 Bond for a 2020 Bond which bas been mutilated, lost, destroyed or stolen and which has matured or has been selected for redemption, the Trustee may make payment of such 2020 Bond upon receipt of indemnity satisfactory to the Trustee. is Section 2.08. Book Entry System. (a) Election of Book Entry System. Prior to the issuance of the 2020 Bonds, the City may provide that such 2020 Bonds shall be initially issued as book entry 2020 Bonds. If the City shall elect to deliver any 2020 Bonds in book entry form, then the City shall cause the delivery of a separate single fully registered bond (which may be typewritten) for each maturity date of such 2020 Bonds in an authorized denomination corresponding to that total principal amount of the 2020 Bonds designated to mature on such date. Upon initial issuance, the ownership of each such 2020 Bond shall be registered in the 2020 Bond Registration Books in the name of the Nominee, as nominee of the Depository, and ownership of the 2020 Bonds, or any portion thereof may not thereafter be transferred except as provided in Section 2.08(e). With respect to book entry 2020 Bonds, the City and the Trustee shall have no responsibility or obligation to any Participant or to any person on behalf of which such a Participant holds an interest in such book entry 2020 Bonds. Without limiting the immediately preceding sentence, the City and the Trustee shall have no responsibility or obligation with respect to: (i) the accuracy of the records of the Depository, the Nominee, or any Participant with respect to any ownership interest in book entry 2020 Bonds; (ii) the delivery to any Participant many other person, other than an Owner as shown in the 2020 Bond Registration Books, of any notice with respect to book entry 2020 Bonds, including any notice of redemption; (iii) the selection by the Depository and its Participants of the beneficial interests in book entry 2020 Bonds to be redeemed in the event that the City redeems the 2020 Bonds in part; or (iv) the payment by the Depository many Participant or any other person, of any amount of principal of, premium, if any, or interest on book entry 2020 Bonds. The City and the Trustee may treat and consider the person in whose name each book entry 2020 Bond is registered in the 2020 Bond Registration Books as the absolute Owner of such book entry 2020 Bond for the purpose of payment of principal of, premium and interest on such 2020 Bond, for the purpose of giving notices of redemption and other matters with respect to such 2020 Bond, for the purpose of registering transfers with respect to such 2020 Bond, and for all other purposes whatsoever. The Trustee shall pay all principal of, premium, if any, and interest on the 2020 Bonds only to or upon the order of the respective Owner, as shown in the 2020 Bond Registration Books, or his respective attorney duly authorized in writing, and all such payments shall be valid and effective to f dly satisfy and discharge the City's obligations with respect to payment of principal of, premium, if any, and interest on the 2020 Bonds to the extent of the sum or sums so paid. No person other than an Owner, as shown in the 2020 Bond Registration Books, shall receive a 2020 Bond evidencing the obligation to make payments of principal of, premium, if any, and interest on the 2020 Bonds. Upon delivery by the Depository to the City and the Trustee, of written notice to the effect that the Depository has determined to substitute a new nominee in place of the Nominee, and subject to the provisions herein with respect to Record Dates, the word Nominee in the Indenture shall refer to such nominee of the Depository. (b) Delivery of Letter of Representations. In order to qualify the book entry 2020 Bonds for the Depository's book entry system, the City and the Trustee (if required by the Depository) shall execute and deliver to the Depository a Letter of Representations. The execution and delivery of a Letter of Representations shall not in any way impose upon the City or the Trustee any obligation whatsoever with respect to persons having interests in such book entry 2020 Bonds other than the Owners, as shown on the 2020 Bond Registration Books. By executing a Letter of Representations, the Trustee shall agree to take all action necessary at all times so that the Trustee will be in compliance with all representations of the Trustee in such Letter of Representations. In addition to the execution and delivery of a Letter of Representations, the City and the Trustee shall 16 take such other actions, not inconsistent with the Indenture, as are reasonably necessary to qualify book entry 2020 Bonds for the Depository's book entry program. (c) Selection of Depository. In the event that: (i) the Depository determines not to continue to act as securities depository for book entry 2020 Bonds; or (ii) the City determines that continuation of the book entry system is not in the best interest of the beneficial owners of the 2020 Bonds or the City, then the City will discontinue the book entry system with the Depository. If the City determines to replace the Depository with another qualified securities depository, the City shall prepare or direct the preparation of a new single, separate, fully registered 2020 Bond for each of the maturity dates of such book entry 2020 Bonds, registered in the name of such successor or substitute qualified securities depository or its Nominee as provided in subsection (e) hereof. If the City fails to identify another qualified securities depository to replace the Depository, then the 2020 Bonds shall no longer be restricted to being registered in such 2020 Bond Registration Books in the name of the Nominee, but shall be registered in whatever name or names the Owners transferring or exchanging such 2020 Bonds shall designate, in accordance with the provisions of Sections 2.03 and 2.04 hereof. (d) Payments To Depository. Notwithstanding any other provision of the Indenture to the contrary, so long as all Outstanding 2020 Bonds are held in book entry form and registered in the name of the Nominee, all payments of principal of, redemption premium, if any, and interest on such 2020 Bond and all notices with respect to such 2020 Bond shall be made and given, respectively to the Nominee, as provided in the Letter of Representations or as otherwise instructed by the Depository and agreed to by the Tmstee notwithstanding any inconsistent provisions herein. (e) Transfer of 2020 Bonds to Substitute Depository. (i) The 2020 Bonds shall be initially issued as provided in Section 2.01 hereof. Registered ownership of such 2020 Bonds, or any portions thereof, may not thereafter be transferred except: (A) to any successor of DTC or its nominee, or of any substitute depository designated pursuant to clause (B) of subsection (i) of this Section 2.08(e) (a "Substitute Depository"); provided that any successor of DTC or Substitute Depository shall be qualified under any applicable laws to provide the service proposed to be provided by it; (B) to any Substitute Depository, upon: (1) the resignation of DTC or its successor (or any Substitute Depository or its successor) from its functions as depository; or (2) a determination by the City that DTC (or its successor) is no longer able to carry out its functions as depository; provided that any such Substitute Depository shall be qualified under any applicable laws to provide the services proposed to be provided by it; or (C) to any person as provided below, upon: (1) the resignation of DTC or its successor (or any Substitute Depository or its successor) from its functions as depository; or (2) a determination by the City that DTC or its successor (or Substitute Depository or its successor) is no longer able to carry out its functions as depository. (ii) In the case of any transfer pursuant to clauses (A) or (B) of subsection (i) of this Section 2.08(e), upon receipt of all Outstanding 2020 Bonds by the Trustee, together with a Written Request of the City to the Trustee designating the Substitute Depository, a single new 2020 Bond, which the City shall prepare or cause to be prepared, shall be issued for each maturity of 2020 17 Bonds then Outstanding, registered in the name of such successor or such Substitute Depository or their Nominees, as the case may be, all as specified in such Written Request of the City. In the case of any transfer pursuant to clause (C) of subsection (i) of this Section 2.08(e), upon receipt of all Outstanding 2020 Bonds by the Trustee, together with a Written Request of the City to the Trustee, new 2020 Bonds, which the City shall prepare or cause to be prepared, shall be issued in such denominations and registered in the names of such persons as we requested in such Written Request of the City, subject to the limitations of Section 2.01 hereof, provided that the Trustee shall not be required to deliver such new 2020 Bonds within a period of less than sixty (60) days from the date of receipt of such Written Request from the City. (iii) In the case of a partial redemption or an advance refunding of any 2020 Bonds evidencing a portion of the principal maturing in a particular year, DTC or its successor (or any Substitute Depository or its successor) shall make an appropriate notation on such 2020 Bonds indicating the date and amounts of such reduction in principal, in form acceptable to the Trustee, all in accordance with the Letter of Representations. The Trustee shall not be liable for such Depository's failure to make such notations or errors in making such notations and the records of the Trustee as to the Outstanding principal amount of such 2020 Bonds shall be controlling. (iv) The City and the Trustee shall be entitled to treat the person in whose name any 2020 Bond is registered as the Owner thereof for all purposes of the Indenture and any applicable laws, notwithstanding any notice to the contrary received by the Trustee or the City; and the City and the Trustee shall not have responsibility for transmitting payments to, communicating with, notifying, or otherwise dealing with any beneficial owners of the 2020 Bonds. Neither the City nor the Trustee shall have any responsibility or obligation, legal or otherwise, to any such beneficial owners or to any other party, including DTC or its successor (or Substitute Depository or its successor), except to the Owner of any 2020 Bonds, and the Trustee may rely conclusively on its records as to the identity of the Owners of the 2020 Bonds. ARTICLE III ISSUANCE OF 2020 BONDS; APPLICATION OF PROCEEDS Section 3.01. Issuance of the 2020 Bonds. At any time after the execution of the Indenture, the City may execute and the Trustee shall authenticate and, upon Written Request of the City, deliver the 2020 Bonds in the aggregate principal amount of $_ Section 3.02. Application of Proceeds of the 2020 Bonds. The proceeds of the sale of the 2020 Bonds in the amount of $ shall be delivered to the Trustee, who shall: (a) transfer S to the Acquisition Fund; (b) deposit $_ to the Reserve Fund; and (c) deposit $_ into the Costs of Issuance Fund The Trustee may establish temporary fiords or accounts in its records to record and facilitate such deposits. 18 Section 3.03. Establishment and Application of Costs of Issuance Fund. The Trustee shall establish, maintain and hold in trust a separate fund designated as the "Costs of Issuance Fund." The moneys in the Costs of Issuance Fund shall be used and withdrawn by the Trustee to pay the Costs of Issuance upon submission of Written Requisitions of the City stating the person to whom payment is to be made, the amount to be paid, the purpose for which the obligation was incurred, that such payment is proper charge against said fund and that payment for such charge has not previously been made. Each such Written Requisition of the City shall be sufficient evidence to the Trustee of the facts stated therein and the Trustee shall have no duty to confirm the accuracy of such facts. On the six month anniversary of the issuance of the 2020 Bonds, or upon the earlier Written Request of the City, all amounts remaining in the Costs of Issuance Fund shall be transferred by the Trustee to the Interest Account and the Costs of Issuance Fund shall be closed. Investment earnings on amounts on deposit in the Costs of Issuance Fund shall be applied in accordance with Section 5.06 hereof. Section 3.04. Validity of 2020 Bonds. The validity of the authorization and issuance of the 2020 Bonds is not dependent on and shall not be affected in any way by any proceedings taken by the City or the Trustee with respect to any other agreement. The recital contained in the 2020 Bonds that the same are issued pursuant to the Constitution and laws of the State shall be conclusive evidence of the validity and of compliance with the provisions of law in their issuance. Section 3.05. Acquisition Fund. The Trustee shall establish, maintain and hold in trust a separate fund designated as the "Acquisition Fund." The moneys in the Acquisition Fund shall be held by the Trustee in trust and applied to the payment of the costs of acquisition and construction of the 2020 Project and of expenses incidental thereto. Before any payment is made from the Acquisition Fund by the Trustee, the General Manager of Public Utilities or the Finance Director of the City shall cause to be filed with the Trustee a certificate of the City in the form set forth in Exhibit C. Upon receipt of each such certificate, the Trustee will pay the amount that is set forth in such certificate as directed by the terms thereof or disburse funds to the City for such payment as directed by the City in such certificate. The Trustee need not make any such payment if it has received notice of any lien, right to lien, attachment upon or claim affecting the right to receive payment of any of the moneys to be so paid which has not been released or will not be released simultaneously with such payment. When the 2020 Project has been constructed and acquired in accordance with the Indenture, a statement of the City stating the fact and date of such acquisition, construction and acceptance and stating that all of such costs of acquisition and incidental expenses have been determined and paid (or that all of such costs and expenses have been paid less specified claims which are subject to dispute and for which a retention in the Acquisition Fund is to be maintained in the full amount of such claims until such dispute is resolved), shall be delivered to the Trustee by the General Manager of Public Utilities or the Finance Director of the City. Upon the receipt of such statement, the Trustee shall deposit any remaining balance in the Acquisition Fund which is not needed for Acquisition Fund purposes (but less the amount of any such retention, which amount shall be certified to the Trustee by the General Manager of Public Utilities or the Finance Director of the City) to the Trustee in the Payment Fund for payment of 2020 Bonds in accordance herewith. Section 3.06. Changes to the 2020 Project. The City may substitute other improvements for those listed as components of the 2020 Project in Exhibit B, but only if the City first files with the 19 Trustee a statement of the City in the form attached as Exhibit D: (a) identifying the improvements to be substituted and the improvements to City facilities they replace in the 2020 Project; and (b) stating that the estimated costs of construction, acquisition and installation of the substituted improvements are not less than such costs for the improvements previously planned. ARTICLE IV REDEMPTION OF 2020 BONDS Section 4.01. Terms of Redemption. (a) The 2020 Bonds with stated maturities on or after August 1, 20 , shall be subject to redemption prior to their respective stated maturities, as a whole or in part on 1, 20 , or any date thereafter, as directed by the City in a Written Request provided to the Trustee at least 35 days (or such lesser number of days acceptable to the Trustee in the sole discretion of the Trustee, such notice for the convenience of the Trustee) and by lot within each maturity in integral multiples of $5,000, at a Redemption Price equal to the principal amount thereof plus accrued interest thereon to the Redemption Date, without premium. (b) The Term Bonds with stated maturities on August 1, 20_ are subject to mandatory sinking fund redemption in part (by lot) on August 1, 20_ and each August I thereafter, in integral multiples of $5,000 at a Redemption Price of the principal amount thereof plus accrued interest to the date fixed for redemption, without premium, in accordance with the following schedule: Redemption Date Principal (August l) Amount 20 1 • Maturity. If some but not all of the Term Bonds are redeemed pursuant to subsections (a) or (b) above, the principal amount of the applicable Term Bonds to be redeemed pursuant to this subsection (c) on any subsequent August 1 will be reduced, by $5,000 or an integral multiple thereof, as designated by the City in a Written Order of the City filed with the Trustee; provided, however, that the aggregate amount of such reductions shall not exceed the aggregate amount of the applicable Term Bonds redeemed pursuant to subsections (a) or (b) above. Section 4.02. Selection of 2020 Bonds for Redemption. Whenever provision is made in the Indenture for the redemption of less than all of the 2020 Bonds, the Trustee shall select the 2020 Bonds for redemption as a whole or in part on any date as directed by the City and by lot within each maturity in integral multiples of $5,000 in accordance with Section 4.01 hereof. The Trustee will promptly notify the City in writing of the numbers of the 2020 Bonds or portions thereof so selected for redemption. 20 Section 4.03. Notice of Redemption. Notice of redemption shall be mailed by first class mail at least twenty (20) days but not more than sixty (60) days before any Redemption Date, to the respective Owners of any 2020 Bonds designated for redemption at their addresses appearing on the Registration Books, to the Securities Depositories and to the Information Services. Each notice of redemption shall state the date of the notice, the Redemption Date, the place or places of redemption, the Redemption Price, the maturities, CUSIP numbers, if any, and, in the case of 2020 Bonds to be redeemed in part only, the respective portions of the principal amount thereof to be redeemed. Each such notice shall also state that on the Redemption Date there will become due and payable on each of said 2020 Bonds or parts thereof designated for redemption the Redemption Price thereof or of said specified portion of the principal thereof in the case of a 2020 Bond to be redeemed in part only, together with interest accrued thereon to the Redemption Date, and that (provided that moneys for redemption have been deposited with the Trustee) from and after such Redemption Date interest thereon shall cease to accrue, and shall require that such 2020 Bonds be then surrendered to the Trustee. Neither the failure to receive such notice nor any defect in the notice or the mailing thereof will affect the validity of the redemption of any 2020 Bond. Notice of redemption of 2020 Bonds shall be given by the Trustee, at the expense of the City, for and on behalf of the City. With respect to any notice of optional redemption of 2020 Bonds, such notice may state that such redemption shall be conditional upon the receipt by the Trustee on or prior to the date fixed for such redemption of moneys sufficient to pay the principal of, premium, if any, and interest on such 2020 Bonds to be redeemed and that, if such moneys shall not have been so received, said notice shall be of no force and effect and the Trustee shall not be required to redeem such 2020 Bonds. In the event that such notice of redemption contains such a condition and such moneys are not so received, the redemption shall not be made, and the Trustee shall within a reasonable time thereafter give notice, in the manner in which the notice of redemption was given, that such moneys were not so received. Section 4.04. Partial Redemption of 2020 Bonds. Upon surrender of any 2020 Bond redeemed in part only, the City shall execute and the Trustee shall authenticate and deliver to the Owner thereof, at the expense of the City, a new 2020 Bond or 2020 Bonds of authorized denominations equal in aggregate principal amount to the unredeemed portion of the 2020 Bonds surrendered and of the same series, interest rate and maturity. Section 4.05. Effect of Redemption. Notice of redemption having been duly given as aforesaid, and moneys for payment of the Redemption Price of, together with interest accrued to the date fixed for redemption on, the 2020 Bonds (or portions thereof) so called for redemption being held by the Trustee, on the Redemption Date designated in such notice, the 2020 Bonds (or portions thereof) so called for redemption shall become due and payable, interest on the 2020 Bonds so called for redemption shall cease to accrue, said 2020 Bonds (or portions thereof) shall cease to be entitled to any benefit or security under the Indenture, and the Owners of said 2020 Bonds shall have no rights in respect thereof except to receive payment of the Redemption Price thereof. The Trustee shall, upon surrender for payment of any of the 2020 Bonds to be redeemed on their Redemption Dates, pay such 2020 Bonds at the Redemption Price. All 2020 Bonds redeemed pursuant to the provisions of this Article shall be canceled and destroyed upon surrender thereof to the Trustee. 21 ARTICLE V REVENUES, FUNDS AND ACCOUNTS; PAYMENT OF PRINCIPAL AND INTEREST Section 5.01. Pledge and Assignment; Revenue Fund. (a) All of the Revenues, all amounts held in the Revenue Fond described in subsection (b) below, all amounts that are transferred from the Rate Stabilization Fund to the Revenue Fond as described in Section 5.08, and any other amounts (including proceeds of the sale of the 2020 Bonds) held in any fund or account established pursuant to the Indenture (except the Rebate Fond and the Rate Stabilization Fond (other than those amounts which are transferred by the City from the Rate Stabilization Fund to the Revenue Fund)) are hereby irrevocably pledged to secure the payment of the principal of and interest, and the premium, if any, on the 2020 Bonds in accordance with their terms and the provisions of the Indenture, and the Revenues shall not be used for any other purpose while the 2020 Bonds remain Outstanding; provided that out of the Revenues there may be apportioned such sums for such purposes as are expressly permitted herein. Said pledge, together with the pledge created by all other Contracts and Bonds, shall constitute a first lien on and security interest on Revenues and, subject to application of Revenues and all amounts on deposit therein as permitted herein, the Revenue Fund and other funds and accounts created hereunder for the payment of the principal of and interest, and the premium, if any, on the 2020 Bonds and all Contracts and Debt Service on Bonds in accordance with the terms hereof, and shall attach, be perfected and be valid and binding from and after the Closing Date, without any physical delivery thereof or further act and shall be valid and binding against all parties having claims of any kind in tort, contract or otherwise against the City, irrespective of whether such parties have notice hereof. (b) In order to carry out and effectuate the pledge and lien contained herein, the City agrees and covenants that all Revenues shall be received by the City in trust hereunder and shall be deposited when and as received in the Revenue Fund, which fund the City agrees and covenants to maintain and to hold separate and apart from other funds so long as the 2020 Bonds and any Contracts or Debt Service on Bonds remain unpaid. Moneys in the Revenue Fond shall be used and applied by the City as provided herein. All moneys in the Revenue Fond shall be held in tout and shall be applied, used and withdrawn for the purposes set forth in this Section. The City shall, from the moneys in the Revenue Fond, pay all Operation and Maintenance Costs (including amounts reasonably required to be set aside in contingency reserves for Operation and Maintenance Costs, the payment of which is not then immediately required) as such Operation and Maintenance Costs become due and payable. All remaining moneys in the Revenue Fund shall he set aside by the City at the following times for the transfer to the following respective special funds in the following order of priority: (i) Interest and Principal Payments. Not later than the Business Day prior to each Interest Payment Date, the City shall, from the moneys in the Revenue Fond, transfer to the Trustee for deposit in the Payment Fond or the Redemption Fund the payments of interest and principal or mandatory sinking fund payments, as applicable, on the 2020 Bonds due and payable on such Interest Payment Date. The City shall also, from the moneys in the Revenue Fund, transfer to the applicable trustee for deposit in the respective payment fund, without preference or priority, and in the event of any insufficiency of such moneys ratably without any discrimination or preference, any other Debt Service in accordance with the provisions of any Bond or Contract. 22 (ii) Reserve Fonds. After making the payments, allocations or transfers provided for in subsection (i) above, the City shall, from the remaining moneys in the Revenue Fund, thereafter, without preference or priority and in the event of any insufficiency of such moneys ratably without any discrimination or preference, transfer to the Reserve Fond and to the applicable trustee for such other reserve funds and/or accounts, if any, as may have been established in connection with Bonds or Contracts, that sum, if any, necessary to restore such funds or accounts to an amount equal to the Reserve Requirement and the reserve requirement applicable to such Bonds or Contracts, as applicable; provided, however, that the City may provide for the Reserve Fond by means other than cash and Permitted Investments pursuant to Section 5.09. (iii) Surplus. Moneys on deposit in the Revenue Fund on any date when the City reasonably expects such moneys will not be needed for the payment of Operation and Maintenance Costs or any of the purposes described in clauses (b)(i) or (b)(ii) may be deposited in the Rate Stabilintion Fund or expended by the City at any time for any purpose permitted by law. (iv) Investments. All moneys held by the City in the Revenue Fund shall be invested in Permitted Investments and the investment earnings thereon shall remain on deposit in such fund, except as otherwise provided herein. Section 5.02. Allocation of Revenues. There is hereby established with the Trustee the Payment Fund, which the Trustee covenants to maintain and hold in trust separate and apart from other funds held by it so long as any principal of and interest on the 2020 Bonds remain unpaid. Except as directed herein, all payments of interest and principal on the 2020 Bonds received by the Trustee pursuant to Section 5.01(b) shall be promptly deposited by the Trustee upon receipt thereof into the Payment Fund; except that all moneys received by the Trustee and required hereunder to be deposited in the Redemption Fund shall be promptly deposited therein. All payments of interest and principal on the 2020 Bonds deposited with the Trustee shall be held, disbursed, allocated and applied by the Trustee only as provided in the Indenture. The Trustee shall also establish and hold an Interest Account and a Principal Account within the Payment Fond. The Trustee shall transfer from the Payment Fond and deposit into the following respective accounts, the following amounts in the following order of priority and at the following times, the requirements of each such account (including the making up of any deficiencies in any such account resulting from lack of Revenues sufficient to make any earlier required deposit) at the time of deposit to be satisfied before any transfer is made to any account subsequent in priority: (a) Not later than the Business Day preceding each Interest Payment Date, the Trustee shall deposit in the Interest Account that sum, if any, required to cause the aggregate amount on deposit in the Interest Account to be at least equal to the amount of interest becoming due and payable on such date on all 2020 Bonds then Outstanding. No deposit need be made into the Interest Account so long as there shall be in such fund moneys sufficient to pay the interest becoming due and payable on such date on all 2020 Bonds then Outstanding. (b) Not later than the Business Day preceding each date on which the principal of the 2020 Bonds shall become due and payable hereunder, the Trustee shall deposit in the Principal Account that sum, if any, required to cause the aggregate amount on deposit in the Principal Account to equal the principal amount of the 2020 Bonds coming due and payable on such date. No deposit need be made into the Principal Account so long as there shall be in such fund moneys sufficient to pay the principal becoming due and payable on such date on all 2020 Bonds then Outstanding. 23 Section 5.03. Application of Interest Account. All amounts in the Interest Account shall be used and withdrawn by the Trustee solely for the purpose of paying interest on the 2020 Bonds as it shall become due and payable (including accrued interest on any 2020 Bonds purchased or accelerated prior to maturity pursuant to the Indenture). Section 5.04. Application of Principal Account. All amounts in the Principal Account shall be used and withdrawn by the Trustee solely to pay the principal amount of the 2020 Bonds at maturity, purchase or acceleration; provided, however, that at any time prior to selection for redemption of any such 2020 Bonds, upon written direction of the City, the Trustee shall apply such amounts to the purchase of 2020 Bonds at public or private sale, as and when and at such prices (including brokerage and other charges, but excluding accrued interest, which is payable from the Interest Account) as stall be directed pursuant to a Written Request of the City, except that the purchase price (exclusive of accrued interest) may not exceed the Redemption Price then applicable to the 2020 Bonds. Section 5.05. Application of Redemption Fund. There is hereby established with the Trustee a special fund designated as the "Redemption Fund." All amounts in the Redemption Fund shall be used and withdrawn by the Trustee solely for the purpose of paying the Redemption Price of the 2020 Bonds to be redeemed on any Redemption Date pursuant to Section 4.01; provided however, that at any time prior to selection for redemption of any such 2020 Bonds, upon written direction of the City, the Trustee shall apply such amounts to the purchase of 2020 Bonds at public or private sale, as and when and at such prices (including brokerage and other charges, but excluding accrued interest, which is payable from the Interest Account) as shall be directed pursuant to a Written Request of the City, except that the purchase price (exclusive of accrued interest) may not exceed the Redemption Price then applicable to the 2020 Bonds. Section 5.06. Investments. All moneys in any of the funds or accounts established with the Trustee pursuant to the Indenture shall be invested by the Trustee solely in Permitted Investments. Such investments shall be directed by the City pursuant to a Written Request of the City filed with the Trustee at least two (2) Business Days in advance of the making of such investments. In the absence of any such directions from the City, the Trustee shall invest any such moneys in Permitted Investments described in clause (b)(5) of the definition thereof; provided, however, that any such investment shall be made by the Trustee only if, prior to the date on which such investment is to be made, the Trustee shall have received a written direction from the City specifying a specific money market fund and, if no such written direction from the City is so received the Trustee shall hold such moneys uninvested. Obligations purchased as an investment of moneys in any fund shall be deemed to be part of such fund or account. All interest or gain derived from the investment of amounts in any of the funds or accounts established hereunder shall be deposited in the Interest Account unless otherwise provided in the Indenture. For purposes of acquiring any investments hereunder, the Trustee may commingle funds (other than the Rebate Fund) held by it hereunder upon the Written Request of the City. The Trustee may act as principal or agent in the acquisition or disposition of any investment and may impose its customary charges therefor. The Trustee shall incur no liability for losses arising from any investments made pursuant to this Section 5.06. The City acknowledges that to the extent that regulations of the Comptroller of the Currency or other applicable regulatory entity grant the City the right to receive brokerage confirmations of security transactions as they occur, the City specifically waives receipt of such confirmations to the 24 extent permitted by law. The City further understands that trade confirmations for securities transactions effected by the Trustee will be available upon request at no additional cost and other trade confirmations may be obtained from the applicable broker. The Trustee will famish the City with periodic cash transaction statements which shall include detail for all investment transactions effected by the Trustee hereunder. Upon the City's election, such statements will be delivered via the Trustee's online service and upon electing such service, paper statements will be provided only upon request. The Trustee or any of its affiliates may act as sponsor, advisor or manager in connection with any investments made by the Trustee under the Indenture. The City shall invest, or cause to be invested, all moneys in any fund or accounts established with the Trustee as provided in the Tax Certificate. For investment purposes, the Trustee may commingle the funds and accounts established hereunder, but shall account for each separately. In making any valuations of investments hereunder, the Trustee may utilize and rely on generally recognized pricing information services (including brokers and dealers in securities) that may be available to the Trustee, including those available through the Trustee accounting system. Section 5.07. Rebate Fond. (a) Establishment. The Trustee shall establish a fund for the 2020 Bonds designated the "Rebate Fund" when required in accordance herewith. Absent an opinion of Bond Counsel that the exclusion from gross income for federal income tax purposes of interest on the 2020 Bonds will not be adversely affected, the City shall cause to be deposited in the Rebate Fond such amounts as are required to be deposited therein pursuant to this Section and the Tax Certificate. All money at any time deposited in the Rebate Fond shall be held by the Trustee in trust for payment to the United States Treasury. All amounts on deposit in the Rebate Fond for the 2020 Bonds shall be governed by this Section and the Tax Certificate, unless and to the extent that the City delivers to the Trustee an opinion of Bond Counsel that the exclusion from gross income for federal income tax purposes of interest on the 2020 Bonds will not be adversely affected if such requirements are not satisfied. Notwithstanding anything to the contrary contained herein or in the Tax Certificate, the Trustee: (i) shall be deemed conclusively to have complied with the provisions thereof if it follows all Requests of the City; (ii) shall have no liability or responsibility to enforce compliance by the City with the terms of the Tax Certificate; (iii) may rely conclusively on the City's calculations and determinations and certifications relating to rebate matters; and (iv) shall have no responsibility to independently make any calculations or determinations or to review the City's calculations or determinations thereunder. (i) Annual Computation. Within 55 days of the end of each Bond Year (as such term is defined in the Tax Certificate), the City shall calculate or cause to be calculated the amount of rebatable arbitrage, in accordance with Section 148(f)(2) of the Code and Section 1.148-3 of the Treasury Regulations (taking into account any applicable exceptions with respect to the computation of the rebatable arbitrage, described, if applicable, in the Tax Certificate (e.g., the temporary investments exceptions of Section 148(f)(4)(B) and the construction expenditures exception of Section 148(f)(4)(C) of the Code), and taking into account whether the election pursuant to Section 148(f)(4XCxvii) of the Code (the "1%% Penalty") has been made), for this purpose treating the last day of the applicable Bond Year as a computation date, within the meaning of 25 Section 1.148-1(b) of the Treasury Regulations (the "Rebatable Arbitrage'). The City shall obtain expert advice as to the amount of the Rebatable Arbitrage to comply with this Section. (ii) Annual Transfer. Within 55 days of the end of each Bond Yew, upon the Written Request of the City, an amount shall be deposited to the Rebate Fund by the Trustee from any Net Revenues legally available for such purpose (as specified by the City in the aforesaid Written Request), if and to the extent required so that the balance in the Rebate Fund shall equal the amount of Rebatable Arbitrage so calculated in accordance with clause (i) of this subsection (a). In the event that immediately following the transfer required by the previous sentence, the amount then on deposit to the credit of the Rebate Fund exceeds the amount required to be on deposit therein, upon Written Request of the City, the Trustee shall withdraw the excess from the Rebate Fund and then credit the excess to the Payment Fund. (iii) Payment to the Treasury. The Trustee shall pay, as directed by Written Request of the City, to the United States Treasury, out of amounts in the Rebate Fund: (A) Not later than 60 days after the end of: (X) the fifth Bond Year; and (Y) each applicable fifth Bond Year thereafter, an amount equal to at least 90% of the Rebatable Arbitrage calculated as of the end of such Bond Year; and (B) Not later than 60 days after the payment of all of the 2020 Bonds, an amount equal to 100% of the Rebatable Arbitrage calculated as of the end of such applicable Bond Year, and any income attributable to the Rebatable Arbitrage, computed in accordance with Section 148(f) of the Code and Section 1.148-3 of the Treasury Regulations. In the event that, prior to the time of any payment required to be made from the Rebate Food, the amount in the Rebate Fund is not sufficient to make such payment when such payment is due, the City shall calculate or cause to be calculated the amount of such deficiency and deposit an amount received from any legally available source equal to such deficiency prior to the time such payment is due. Each payment required to be made pursuant to this subsection (a) shall be made to the Internal Revenue Service Center, Ogden, Utah 84201 on or before the date on which such payment is due, and shall be accompanied by Internal Revenue Service Form 8038-T (prepared by the City), or shall be made in such other manner as provided under the Code. (b) Disposition of Unexpended Funds. Any funds remaining in the Rebate Fund after redemption and payment of the 2020 Bonds and the payments described in subsection (a) above being made may be withdrawn by the City and utilized in any manner by the City. (c) Survival of Defemance. Notwithstanding anything in this Section to the contrary, the obligation to comply with the requirements of this Section shall survive the defeasance or payment in full of the 2020 Bonds. Section 5.08. Establishment and Application of Rate Stabilization Fund The City shall establish, maintain and hold in trust a special fund designated as the "Rate Stabilization Fund." The City agrees and covenants to maintain and to hold such fund separate and apart from other funds so long as the 2020 Bonds or any other Contracts or Bonds remain unpaid. Money transferred by the City from the Revenue Fund to the Rate Stabilization Fund in accordance with Section 5.01(b)(ui) will be held in the Rate Stabilization Fond and applied in accordance herewith. 26 The City may withdraw all or any portion of the amounts on deposit in the Rate Stabilization Fund and transfer such amounts to the Revenue Fund for application in accordance with Section 5.01 or, in the event that all or a portion of the 2020 Bonds are discharged in accordance with Article X, transfer all or any portion of such amounts for application in accordance with Article X. Any such amounts transferred from the Rate Stabilization Fund to the Revenue Fund in accordance with the Indenture constitute pledged Revenues. Section 5.09. Reserve Fund. The Trustee shall establish a fund known as the "Reserve Fund" to be held and applied as set forth herein. The Trustee shall deposit in the Reserve Food the amounts required to be deposited therein pursuant to this Indenture and apply moneys in the Reserve Fund in accordance with this Section. The initial deposit to the Reserve Fund shall be in the amount of the Reserve Requirement. If one Business Day prior to any Interest Payment Date the moneys in the Payment Fund are insufficient to pay amounts due on the 2020 Bonds on such Interest Payment Date, the Trustee shall transfer from the Reserve Fund to the Payment Fund the amount of such insufficiency. In the event that the Trustee has transferred moneys from the Reserve Fund to the Payment Fund in accordance with this Section, upon receipt of the moneys from the City to increase the balance in the Reserve Fund to the Reserve Requirement, the Trustee shall deposit such moneys in the Reserve Fund. If the amount available and contained in the Reserve Fund exceeds an amount equal to the Reserve Requirement and if the City is not then in default under this Indenture, the Trustee shall semiannually on or before each Interest Payment Date withdraw the amount of such excess from the Reserve Fund and shall deposit such amount in the Payment Fund and for this determination the Trustee shall make a valuation of the Reserve Fund as often as it may deem appropriate, and in any event on or before each Interest Payment Date in each year. In addition, the Trustee shall, on the date all or any portion of the 2020 Bonds are discharged in accordance with Section 10.02 hereof, value the Reserve Fund in accordance with this Section and withdraw the excess, if any, on deposit in the Reserve Fund and transfer such amount to or in accordance with the written direction of the District. Except for such withdrawals, all moneys in the Reserve Fund shall be used and withdrawn by the Trustee solely for the purpose of paying principal, Redemption Price and interest on the 2020 Bonds in the event that no other moneys of the District are available therefor. For the purpose of determining the amount in the Reserve Fund, all Permitted Investments credited to the Reserve Fund shall be valued at the lower of cost (inclusive of all interest accrued but not paid), or book value. The District may satisfy the Reserve Requirement to deposit a specified amount in the Reserve Fund by the deposit of. (a) a surety bond; (b) a municipal bond insurance policy; (c) an unconditional irrevocable letter of credit; or (d) any other security device, in each case issued by providers whose long term debt, or, in the case of a monoline financial guaranty insurance company, claims paying ability, is rated, at the time such security device is issued, "AA" or better by S&P, if S&P is then rating the 2020 Bonds, "AA" or better by Moody's, if Moody's is then rating the 2020 Bonds, and "AA" or better by Fitch, if Fitch is then rating the 2020 Bonds. Section 5.10. Application of Funds and Accounts When No 2020 Bonds are Outstanding. On the date on which all 2020 Bonds shall be retired hereunder or provision made therefor pursuant to Article X and after payment of all amounts due the Trustee hereunder, all moneys then on deposit in any of the funds or accounts (other than the Rebate Fund) established with the Trustee pursuant to 27 the Indenture shall be withdrawn by the Trustee and paid to the City for use by the City at any time for any purpose permitted by law. ARTICLE VI PARTICULAR COVENANTS Section 6.01. Punctual Payment. The City shall punctually pay or cause to be paid the principal and interest to become due in respect of all of the 2020 Bonds, in strict conformity with the terns of the 2020 Bonds and of the Indenture, according to the true intent and meaning thereof, but only out of Net Revenues and other assets pledged for such payment as provided in the Indenture. Section 6.02. Extension of Payment of 2020 Bonds. The City shall not directly or indirectly extend or assent to the extension of the maturity of any of the 2020 Bonds or the time of payment of any claims for interest by the purchase of such 2020 Bonds or by any other arrangement, and in case the maturity of any of the 2020 Bonds or the time of payment of any such claims for interest shall be extended, such 2020 Bonds or claims for interest shall not be entitled, in case of any default hereunder, to the benefits of the Indenture, except subject to the prior payment in full of the principal of all of the 2020 Bonds then Outstanding and of all claims for interest thereon which shall not have been so extended Nothing in this Section shall be deemed to limit the right of the City to issue Bonds for the purpose of refunding any Outstanding 2020 Bonds, and such issuance shall not be deemed to constitute an extension of maturity of 2020 Bonds. Section 6.03. Against Encumbrunces. The City will not make any pledge of or place any lien on Revenues or the moneys in the Revenue Fund except as provided herein. The City may at any time, or from time to time, execute Contracts or issue Bonds as permitted herein. The City may also at any time, or from time to time, incur evidences of indebtedness or incur other obligations for any lawful purpose which are payable from and secured by a pledge of lien on Revenues on any moneys in the Revenue Food as may from time to time be deposited therein, provided that such pledge and lien shall be subordinate in all respects to the pledge of and lien thereon provided herein. Section 6.04. Power to Issue 2020 Bonds and Make Pledge and Assignment. The City is duly authorized pursuant to law to issue the 2020 Bonds, to enter into the Indenture and to pledge and assign the Revenues and other assets purported to be pledged and assigned under the Indenture in the manner and to the extent provided in the Indenture. The 2020 Bonds and the provisions of the Indenture are and will be the legal, valid and binding special obligations of the City in accordance with their terms, and the City shall and the Trustee may, at all times, subject to the provisions of Article VQI and to the extent permitted by law, defend, preserve and protect said pledge and assignment of Revenues and other assets and all the rights of the 2020 Bond Owners under the Indenture against all claims and demands of all persons whomsoever. Section 6.05. Accounting Records and Financial Statements. (a) The Trustee shall at all times keep, or cause to be kept, proper books of record and account, prepared in accordance with corporate trust industry standards, in which complete and accurate entries shall be made of all transactions made by it relating to the proceeds of 2020 Bonds and all funds and accounts established by it pursuant to the Indenture. Such books of record and account shall be available for inspection by the City upon reasonable prior notice during business hours and under reasonable circumstances. 28 (b) The City will keep appropriate accounting records in which complete and correct entries shall be made of all transactions relating to the Water System, which records shall be available for inspection by the Trustee (which shall have no duty to inspect such records) at reasonable hours and under reasonable conditions. (c) The City will prepare and file with the Trustee annually within two hundred seventy (270) days of each Fiscal Year (commencing with the Fiscal Year ended June 30, 2019) financial statements of the City for the preceding Fiscal Year prepared in accordance with Generally Accepted Accounting Principles, together with an Accountant's Report thereon. The Trustee shall have no duty to review, verify or analyze such financial statements, and shall hold such financial statements solely as a repository for the benefit of the 2020 Bond Owners. The Trustee shall not be deemed to have notice of any information contained therein, or default or Event of Default which may be disclosed therein in any manner. Section 6.06. Tax Covenants. Notwithstanding any other provision of the Indenture, absent an opinion of Bond Counsel that the exclusion from gross income of the portion of interest on the 2020 Bonds will not be adversely affected for federal income tax purposes, the City covenants to comply with all applicable requirements of the Code necessary to preserve such exclusion from gross income with respect to the 2020 Bonds and specifically covenants, without limiting the generality of the foregoing, as follows: (a) Private Activity. The City will take no action, refrain from taking any action and make no use of the proceeds of the 2020 Bonds or of any other moneys or property which would cause the 2020 Bonds to be "private activity bonds" within the meaning of Section 141 of the Code; (b) Arbitnuxe The City will make no use of the proceeds of the 2020 Bonds or of any other amounts or property, regardless of the source, and will take no action and refrain from taking any action which will cause the 2020 Bonds to be "arbitrage bonds" within the meaning of Section 148 of the Code; (c) Federal Guarantee. The City will make no use of the proceeds of the 2020 Bonds and will not take or omit to take any action that would cause the 2020 Bonds to be `federally guaranteed" within the meaning of Section 149(b) of the Code; (d) Information Reoortine. The City will take or cause to be taken all necessary action to comply with the informational reporting requirement of Section 149(e) of the Code necessary to preserve the exclusion of interest on the 2020 Bonds pursuant to Section 103(a) of the Code; (e) Hedge Bonds. The City will make no use of the proceeds of the 2020 Bonds or any other amounts or property, regardless of the source, and will not take any action or refrain from taking any action that would cause the 2020 Bonds to be considered "hedge bonds" within the meaning of Section 149(g) of the Code unless the City takes all necessary action to assure compliance with the requirements of Section 149(g) of the Code to maintain the exclusion from gross income of interest on the 2020 Bonds for federal income tax purposes; and (t) Miscellaneous. The City will take no action and refrain from taking any action inconsistent with its expectations stated in the Tax Certificate executed by the City in 29 connection with the issuance of the 2020 Bonds and will comply with the covenants and requirements stated therein and incorporated by reference herein. This Section and the covenants set forth herein shall not be applicable to, and nothing contained herein shall be deemed to prevent the City issuing revenue bonds or causing the Trustee to to execute and deliver contracts payable on a parity with the 2020 Bonds, the interest with respect to which has been determined by Bond Counsel to be subject to federal income taxation. Section 6.07. Waiver of Laws. The City shall not at any time insist upon or plead in any manner whatsoever, or claim or take the benefit or advantage of, any stay or extension law now or at any time hereafter in force that may affect the covenants and agreements contained in the Indenture or in the 2020 Bonds, and all benefit or advantage of any such law or laws is hereby expressly waived by the City to the extent permitted by law. Section 6.08. Further Assurances. The City will make, execute and deliver any and all such fiuther indentures, instruments and assurances as may be reasonably necessary or proper to carry out the intention or to facilitate the performance of the Indenture and for the better assuring and confirming unto the Owners of the 2020 Bonds of the rights and benefits provided in the Indenture. Section 6.09. Budgets. On or prior to the fifteenth day of each Fiscal Year, the City shall certify to the Trustee that the amounts budgeted for payment of the principal of and interest on the 2020 Bonds are fully adequate for the payment of all such payments for such Fiscal Year. If the amounts so budgeted are not adequate for the payment of the principal of and interest on the 2020 Bonds due under the Indenture, the City will take such action as may be necessary to cause such annual budget to be amended, corrected or augmented so as to include therein the amounts required to be raised by the City in the then ensuing Fiscal Year for the payment of the principal of and interest on the 2020 Bonds due under the Indenture and will notify the Trustee of the proceedings then taken or proposed to be taken by the City. Section 6.10. Observance of Laws and Regulations. To the extent necessary to assure its performance hereunder, the City will well and truly keep, observe and perform all valid and lawful obligations or regulations now or hereafter imposed on the City by contract, or prescribed by any law of the United States of America, or of the State, or by any officer, board or commission having jurisdiction or control, as a condition of the continued enjoyment of any and every right, privilege or franchise now owned or hereafter acquired by the City, respectively, including its right to exist and carry on its business, to the end that such contracts, rights and franchises shall be maintained and preserved, and shall not become abandoned, forfeited or in any manner impaired. Section 6.11. Compliance with Contracts. The City will neither take nor omit to take any action under any contract if the effect of such act or failure to act would in any manner impair or adversely affect the ability of the City to pay principal of or interest on the 2020 Bonds; and the City will comply with, keep, observe and perform all agreements, conditions, covenants and terms, express or implied, required to be performed by it contained in all other contracts affecting or involving the Water System, to the extent that the City is a party thereto. Section 6.12. Prosecution and Defense of Suits. The City shall promptly, upon request of the Trustee or any 2020 Bond Owner, from time to time take such action as may be necessary or proper to remedy or care any defect in or cloud upon the title to the Water System or any part thereof, whether now existing or hereafter developing, shall prosecute a0 such suits, actions and 30 other proceedings as may be appropriate for such purpose and shall indemnify and save the Trustee (including all of its employees, officers and directors), the Trustee and every 2020 Bond Owner harmless from all loss, cost, damage and expense, including attorneys' fees, which they or any of them may incur by reason of any such defect, cloud, suit, action or proceeding. The City shall defend against every suit, action or proceeding at any time brought against the Tmstee (including all of its employees, officers and directors) or any 2020 Bond Owner upon any claim arising out of the receipt, application or disbursement of any of the payments of principal of or interest on the 2020 Bonds or involving the rights of the Trustee or any 2020 Bond Owner under the Indenture; provided that the Trustee or any 2020 Bond Owner at such party's election may appear in and defend any such suit, action or proceeding. The City shall indemnify and hold harmless the Trustee and the 2020 Bond Owners against any and all liability claimed or asserted by any person, arising out of such receipt, application or disbursement, and shall indemnify and hold harmless the 2020 Bond Owners against any attorneys' fees or other expenses which any of them may incur in connection with any litigation (including pre -litigation activities) to which any of them may become a party by reason of ownership of 2020 Bonds. The City shall promptly reimburse any 2020 Bond Owner in the full amount of any attorneys' fees or other expenses which such Owner may incur in litigation or otherwise in order to enforce such party's rights under the Indenture or the 2020 Bonds, provided that such litigation shall be concluded favorably to such parry's contentions therein. Section 6.13. Continuing Disclosure. The City hereby covenants and agrees that it will comply with and carry out all of its obligations under the Continuing Disclosure Agreement to be executed and delivered by the City in connection with the issuance of the 2020 Bonds. Notwithstanding any other provision of the Indenture, failure of the City to comply with the Continuing Disclosure Agreement shall not be considered an Event of Default; however, any Owner or Beneficial Owner may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the City to comply with its obligations under this Section. For purposes of this Section, 'Beneficial Owner" means any person which has or shares the power, directly or indirectly, to make investment decisions concerning ownership of any 2020 Bonds (including persons holding 2020 Bonds through nominees, depositories or other intermediaries). Section 6.14. Additional Contracts and Bonds. The City may at any time execute any Contract or issue any Bonds, as the case may be, in accordance herewith; provided that: (a) The Net Revenues for the last audited Fiscal Year of the City, or for any consecutive twelve calendar month period during the eighteen calendar month period, preceding the date of adoption by the City Council of the City of the resolution authorizing the issuance of such Bonds or the date of the execution of such Contract, as the case may be, as evidenced by a special report prepared by an Independent Certified Public Accountant or Independent Financial Consultant on file with the City, shall have produced a sum equal to at least one hundred fifteen percent (1150%) of the Debt Service for such Fiscal Year or other twelve month period. [When calculated for purposes of this subsection, Net Revenues will not include amounts that have been transferred from the Rate Stabilization Fund to the Revenue Fund pursuant to Section 5.08 that are in excess of fifteen percent (15%) of Debt Service for such Fiscal Year]; and (b) The Net Revenues for the last audited Fiscal Year of the City, or for any consecutive twelve calendar month period during the eighteen calendar month period, preceding the date of adoption by the City Council of the City of the resolution authorizing the issuance of such 31 Bonds or the date of the execution of such Contract, as the case may be, including adjustments to give effect as of the first day of such twelve month period to increases or decreases in rates and charges for the Water Service approved and in effect as of the date of calculation, as evidenced by a special report prepared by an Independent Certified Public Accountant or Independent Financial Consultant on file with the City, shall have produced a sum equal to at least one hundred fifteen percent (115%) of the Debt Service for such Fiscal Year or other twelve month period, plus the Debt Service which would have accrued on any Contracts executed or Bonds issued since the end of such Fiscal Year or other twelve month period, assuming that such Contracts had been executed or Bonds had been issued at the beginning of such Fiscal Year or other twelve month period, plus the Debt Service which would have accrued had such proposed additional Contract been executed or proposed additional Bonds been issued at the beginning of such Fiscal Year or other twelve month period. [When calculated for purposes of this subsection, Net Revenues will not include amounts which have been transferred from the Rate Stabilization Fund to the Revenue Fond pursuant to Section 5.08 that are in excess of fifteen percent (150/6) of Debt Service for such Fiscal Year). Notwithstanding the foregoing, Bonds issued or Contracts executed to refund Bonds or prepay Contracts may be delivered without satisfying the conditions set forth above if total Debt Service after the issuance of such refunding Bonds or execution of such refunding Contracts executed is not greater than total Debt Service would have been prior to the issuance of such Bonds or execution of such Contracts. Section 6.15. Against Sale or Other Disposition of Procertv. The City will not enter into any agreement or lease which impairs the operation of the Water System or any part thereof necessary to secure adequate Revenues for the payment of the principal of and interest on the 2020 Bonds, or which would otherwise impair the operation of the Water System. Any real or personal property which has become nonoperative or which is not needed for the efficient and proper operation of the Water System, or any material or equipment which has become worn out, may be sold if such sale will not impair the ability of the City to pay the principal of and interest on the 2020 Bonds and if the proceeds of such sale are deposited in the Revenue Fund. Nothing herein shall restrict the ability of the City to sell any portion of the Water System if such portion is immediately repurchased by the City and if such arrangement cannot by its terms result in the purchaser of such portion of the Water System exercising any remedy which would deprive the City of or otherwise interfere with its right to own and operate such portion of the Water System. Section 6.16. Against Comuctitive Facilities. To the extent that it can so legally obligate itself, the City covenants that it will not acquire, construct, maintain or operate and will not, to the extent permitted by law and within the scope of its powers, permit any other public or private agency, corporation, district or political subdivision or any person whomsoever to acquire, construct, maintain or operate within the City any municipal water system competitive with the Water System. Section 6.17. Maintenance and Operation of the Water System. The City will maintain and preserve the Water System in good repair and working order at all times and will operate the Water System in an efficient and economical manner and will pay all Operation and Maintenance Costs as they become due and payable. Section 6.18. Payment of Claims. The City will pay and discharge any and all lawful claims for labor, materials or supplies which, if unpaid, might become a lien on the Revenues or the 32 funds or accounts created hereunder or on any funds in the hands of the City pledged to pay the principal of or interest on the 2020 Bonds or to the Owners prior or superior to the lien under the Indenture. Section 6.19. Insurance. (a) The City will procure and maintain or cause to be procured and maintained insurance on the Water System with responsible insurers in such amounts and against such risks (including damage to or destruction of the Water System) as are usually covered in connection with facilities similar to the Water System so long as such insurance is available from reputable insurance companies. In the event of any damage to or destruction of the Water System caused by the perils covered by such insurance, the Net Proceeds thereof shall be applied to the reconstruction, repair or replacement of the damaged or destroyed portion of the Water System. The City shall begin such reconstruction, repair or replacement promptly after such damage or destruction shall occur, and shall continue and properly complete such reconstruction, repair or replacement as expeditiously as possible, and shall pay out of such Net Proceeds all costs and expenses in connection with such reconstruction, repair or replacement so that the same shall be completed and the Water System shall be free and clear of all claims and liens. If such Net Proceeds exceed the costs of such reconstruction, repair or replacement portion of the Water System, and/or the cost of the construction of additions, betterments, extensions or improvements to the Water System, then the excess Net Proceeds may be applied in part to defeasance of 2020 Bonds and in part to such other fund or account as may be appropriate and used for the retirement of Bonds and Contracts in the same proportion which the aggregate unpaid principal balance of 2020 Bonds then hears to the aggregate unpaid principal amount of such Bonds and Contracts. If such Net Proceeds are sufficient to enable the City to retire the entire obligation evidenced hereby prior to the final due date of the 2020 Bonds as well as the entire obligations evidenced by Bonds and Contracts then remaining unpaid prior to their final respective due dates, the City may elect not to reconstruct, repair or replace the damaged or destroyed portion of the Water System, and/or not to construct other additions, betterments, extensions or improvements to the Water System; and thereupon such Net Proceeds shall be applied to the retirement of 2020 Bonds and to the retirement of such Bonds and Contracts- (b) The City will procure and maintain such other insurance as it shall deem advisable or necessary to protect its interests and the interests of the 2020 Bond Owners, which insurance shall afford protection in such amounts and against such risks as are usually covered in connection with municipal water systems similar to the Water System. (c) Any insurance required to be maintained by paragraph (a) above and, if the City determines to procure and maintain insurance pursuant to paragraph (b) above, such insurance, may be maintained under a self-insurance program so long as such self-insurance is maintained in the amounts and manner usually maintained in connection with municipal water systems similar to the Water System and is, in the opinion of an accredited actuary, actuarially sound. Section 6.20. Payment of Taxes and Compliance with Governmental Regulations. The City will pay and discharge all taxes, assessments and other governmental charges which may hereafter be lawfully imposed upon the Water System, many part thereof or upon the Revenues when the same 33 shall become due. The City will duly observe and conform with all valid regulations and requirements of any governmental authority relative to the operation of the Water System, or any part thereof, but the City shall not be required to comply with any regulations or requirements so long as the validity or application thereof shall be contested in good faith. Section 6.21. Amount of Rates and Charees. (a) In any Fiscal Year in which the amount on deposit in the Rate Stabilization Fund on the first day of such Fiscal Year is less than the payments of principal of and interest on the 2020 Bonds payable in such Fiscal Year, to the fullest extent permitted by law, the City will fix and prescribe, at or before the commencement of each such Fiscal Year, rates and charges for the Water Service which are reasonably expected, at the commencement of such Fiscal Year, to be at least sufficient to yield during such Fiscal Year Net Revenues equal to one hundred fifteen percent (115%) of Debt Service for such Fiscal Year. [When calculated for purposes of this subsection, Net Revenues will not include amounts which have been transferred from the Rate Stabilization Fund pursuant to Section 5.08 that are in excess of fifteen percent (15°/u) of Debt Service for such Fiscal Year]. (b) In any Fiscal Year in which the amount on deposit in the Rate Stabilization Fund on the first day of such Fiscal Year is at least equal to the payments of principal of and interest on the 2020 Bonds payable in such Fiscal Year, to the fullest extent permitted by law, the City will fix and prescribe, at or before the commencement of each such Fiscal Year, rates and charges for the Water Service which are reasonably expected, at the commencement of such Fiscal Year, to be at least sufficient to yield during such Fiscal Year Revenues equal to one hundred fifteen percent (115%) of the Operation and Maintenance Costs for such Fiscal Year. [When calculated for purposes of this subsection, Revenues will not include any amounts which have been transferred from the Rate Stabilization Fund pursuant to Section 5.08]. (c) The City may make or permit to be made adjustments from time to time in such rates, fees and charges and may make or permit to be made such classification thereof as it deems necessary, but shall not reduce or permit to be reduced such rates, fees and charges below those then in effect unless the Revenues from such reduced rates, fees and charges will at all times be sufficient to meet the requirements of this Section. Section 6.22. Collection of Rates and Changes. The City will have in effect at all times by-laws, rules and regulations requiring each customer to pay the rates and charges applicable to the Service and providing for the billing thereof and for a due date and a delinquency date for each bill. Section 6.23. Eminent Domain proceeds. If all or any part of the Water System shall be taken by eminent domain proceedings, the Net Proceeds thereof shall be applied as follows: (a) If. (1) the City files with the Trustee a certificate showing: (i) the estimated loss of annual Net Revenues, if any, suffered or to be suffered by the City by reason of such eminent domain proceedings; (ii) a general description of the additions, betterments, extensions or improvements to the Water System proposed to be acquired and constructed by the City fiom such Net Proceeds; and (iii) an estimate of the additional annual Net Revenues to be derived from such additions, betterments, extensions or improvements; and (2) the City, on the basis of such certificate filed with the Trustee, determines that the estimated additional annual Net Revenues will sufficiently offset the estimated loss of annual Net Revenues resulting from such eminent domain proceedings so 34 that the ability of the City to meet its obligations hereunder will not be substantially impaired (which determination shall be final and conclusive), then the City shall promptly proceed with the acquisition and construction of such additions, betterments, extensions or improvements substantially in accordance with such certificate and such Net Proceeds shall be applied for the payment of the costs of such acquisition and construction, and any balance of such Net Proceeds not required by the City for such purpose shall be deposited in the Revenue Fund. (b) If the foregoing conditions are not met, then such Net Proceeds shall be applied by the City in part to the defeasance or redemption of 2020 Bonds as provided herein, and in part to such other fund or account as may be appropriate and used for the retirement of Bonds and Contracts in the same proportion which the aggregate unpaid principal balance of 2020 Bonds then bears to the aggregate unpaid principal amount of such Bonds and Contracts. Section 6.24. Enforcement of Contracts. The City will not voluntarily consent to or permit any rescission of, not will it consent to any amendment to or otherwise take any action under or in connection with any contracts previously or hereafter entered into if such rescission or amendment would in any manner impair or adversely affect the ability of the City to pay principal of and interest on the 2020 Bonds. ARTICLE VII EVENTS OF DEFAULT AND REMEDIES OF 2020 BOND OWNERS Section 7.01. Events of Default. The following events shall be Events of Default hereunder: (a) Default by the City in the due and punctual payment of the principal of any 2020 Bonds, the principal of any Bonds or the principal with respect to any Contract, when and as the same shall become due and payable, whether at maturity as therein expressed, by proceedings for redemption, by acceleration, or otherwise. (b) Default by the City in the due and punctual payment of any installment of interest on any 2020 Bonds, any installment of interest on any Bond or any installment of interest with respect to any Contract, when and as the same shall become due and payable. (c) Default by the City in the observance of any of the other covenants, agreements or conditions on its part in the Indenture or in the 2020 Bonds, or required by any Bond or indenture relating thereto or by any Contract, if such default shall have continued for a period of sixty (60) days after written notice thereof, specifying such default and requiring the same to be remedied, shall have been given to the City by the Trustee or by the Owners of not less than a majority in aggregate principal amount of 2020 Bonds Outstanding, a majority in principal amount of such Bond outstanding, or a majority in principal amount outstanding with respect to such Contract, as applicable; provided, however, that if in the reasonable opinion of the City the default stated in the notice can he corrected, but not within such sixty (60) day period, and corrective action is instituted by the City within such sixty (60) day period and diligently pursued in good faith until the default is corrected, such default shall not be an Event of Default hereunder; provided however, that such extended care period shall not be longer than 180 days from the delivery date of such default notice. 35 (d) The City shall file a petition or answer seeking arrangement or reorganization under the federal bankruptcy laws or any other applicable law of the United States of America or any state therein, or a court of competent jurisdiction shall approve a petition filed with or without the consent of the City seeking arrangement or reorganization under the federal bankruptcy laws or any other applicable law of the United States of America or any state therein, or 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 or of the whole or any substantial part of its property. (e) Payment of the principal of any Bond or with respect to any Contract is accelerated in accordance with its terms. Section 7.02. Remedies Upon Event of Default. If any Event of Default specified in Section 7.01(d) or (e) shall occur and be continuing, the Trustee shall, and for any other Event of Default, the Trustee may, and, at the written direction of the Owners of not less than a majority in aggregate principal amount of the 2020 Bonds at the time Outstanding, shall, in each case, upon notice in writing to the City, declare the principal of all of the 2020 Bonds then Outstanding, and the interest accrued thereon, to be due and payable immediately, and upon any such declaration, the same shall become and shall be immediately due and payable, anything in the Indenture or in the 2020 Bonds contained to the contrary notwithstanding. Nothing contained herein shall permit or require the Trustee to accelerate payments due under the Indenture if the City is not in default of its obligation hereunder. Any such declaration is subject to the condition that if, at any time after such declaration and before any judgment or decree for the payment of the moneys due shall have been obtained or entered, the City shall deposit with the Trustee a sum sufficient to pay all the principal of and installments of interest on the 2020 Bonds payment of which is overdue, with interest on such overdue principal at the rate home by the respective 2020 Bonds to the extent permitted by law, and the reasonable fees, disbursements and expenses of the Trustee, or shall deposit with the applicable trustee with respect to any Contract a sum sufficient to pay all the principal and installments of interest with respect to such Contract payment of which is overdue, with interest on such overdue principal at the rate home by such Contract to the extent permitted by law, and the reasonable charges and expenses of the applicable trustee with respect to such Contract, or shall deposit with the applicable trustee with respect to any Bond a sum sufficient to pay all the principal of and installment of interest on such Bond payment of which is overdue, with interest on such overdue principal at the rate borne by such Bonds to the extent permitted by law, and the reasonable charges and expenses of the applicable trustee with respect to such Bonds, and any and all other Events of Default actually known to a Responsible Officer of the Trustee or the applicable trustee with respect to such Contract or Bonds (other than in the payment of principal of and interest on the 2020 Bonds, payment of principal and interest with respect to such Contract or payment of principal and interest on such Bond, as applicable, due and payable solely by reason of such declaration) shall have been made good or cured to the satisfaction of the Trustee or provision deemed by the Trustee to be adequate shall have been made therefor, then and in every such case the Trustee shall on behalf of the Owners of all of the 2020 Bonds, rescind and annul such declaration and its consequences and waive such Event of Default; but no such rescission and annulment shall extend to or shall affect any subsequent Event of Default, or shall impair or exhaust any right or power consequent thereon. Section 7.03. Annlication of Revenues and Other Funds After Default. If an Event of Default shall occur and be continuing, all Revenues held or thereafter received by the Trustee and 36 any other funds then held or thereafter received by the Trustee under any of the provisions of the Indenture (other than amounts held in the Rebate Fond) shall be applied in the following order: (a) To the payment of any expenses necessary in the opinion of the Trustee to protect the interests of the Owners of the 2020 Bonds, Contract or Bonds and payment of reasonable fees and expenses of the Trustee (including reasonable fees and disbursements of its counsel) incurred in and about the performance of its powers and duties under the Indenture; (b) To the payment of Operation and Maintenance Costs; and (c) To the payment of the principal of and interest then due on the 2020 Bonds (upon presentation of the 2020 Bonds to be paid, and stamping or otherwise noting thereon of the payment if only partially paid, or surrender thereof if fully paid), in accordance with the provisions of the Indenture, and to the payment of the principal and interest then due with respect to such Contract in accordance with the provisions thereof and the payment of the principal of and interest then due on such Bonds in accordance with the provisions thereof and of any indenture related thereto, in the following order of priority: First: To the payment to the persons entitled thereto of all installments of interest then due on the 2020 Bonds, with respect to such Contract or on such Bonds, as applicable, in the order of the maturity of such installments, and, if the amount available shall not be sufficient to pay in full any installment or installments maturing on the same date, then to the payment thereof ratably, according to the amounts due thereon, to the persons entitled thereto, without any discrimination or preference; and Second: To the payment to the persons entitled thereto of the unpaid principal of any 2020 Bonds, principal with respect to such Contract or principal of any Bonds, as applicable, which shall have become due, whether at maturity or by acceleration or redemption, with interest on the overdue principal at the rate of eight percent (8%) per annum, and, if the amount available shall not be sufficient to pay in full all the 2020 Bonds, all amounts due under such Contract or all the Bonds, as applicable, together with such interest, then to the payment thereof ratably, according to the amounts of principal 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 7.04. Trustee to Represent 2020 Bond Owners. The Trustee is hereby irrevocably appointed (and the successive respective Owners of the 2020 Bonds, by taking and holding the same, shall be conclusively deemed to have so appointed the Trustee) as trustee and true and lawful attorney in fact of the Owners of the 2020 Bonds for the purpose of exercising and prosecuting on their behalf such rights and remedies as may be available to such Owners under the provisions of the 2020 Bonds or the Indenture and applicable provisions of law. Upon the occurrence and continuance of an Event of Default or other occasion giving rise to a right in the Trustee to represent the 2020 Bond Owners, the Trustee in its discretion may, and upon the written request of the Owners of a majority in aggregate principal amount of the 2020 Bonds then Outstanding, and upon being indemnified to its satisfaction therefor, shall proceed to protect or enforce its rights or the rights of such Owners by such appropriate action, suit, mandamus or other proceedings as it shall deem most effectual to protect and enforce any such right, at law or in equity, either for the specific performance 37 of any covenant or agreement contained herein, or in aid of the execution of any power herein granted, or for the enforcement of any other appropriate legal or equitable right or remedy vested in the Trustee or in such Owners under the 2020 Bonds or the Indenture or any law; and upon instituting such proceeding, the Trustee shall be entitled, as a matter of right, to the appointment of a receiver of the Revenues and other assets pledged under the Indenture, pending such proceedings. All rights of action under the Indenture or the 2020 Bonds or otherwise may be prosecuted and enforced by the Trustee without the possession of any of the 2020 Bonds or the production thereof in any proceeding relating thereto, and any such suit, action or proceeding instituted by the Trustee shall be brought in the name of the Trustee for the benefit and protection of all the Owners of such 2020 Bonds, subject to the provisions of the Indenture. Nothing herein shall be deemed to authorize the Trustee to authorize or consent to or accept or adopt on behalf of any 2020 Bond Owner any plan of reorganization, arrangement, adjustment, or composition affecting the Bonds or the rights of any 2020 Bond Owner thereof, or to authorize the Trustee to vote in respect of the claim of any 2020 Bond Owner in any such proceeding without the approval of the 2020 Bond Owners so affected. Section 7.05. 2020 Bond Owners' Direction of Proceedings. Anything in the Indenture to the contrary notwithstanding, the Owners of a majority in aggregate principal amount of the 2020 Bonds then Outstanding shall have the right, by an instrument or concur ent instruments in writing executed and delivered to the Trustee, and upon indemnification of the Trustee to its reasonable satisfaction to direct the method of conduct in all remedial proceedings taken by the Trustee hereunder, provided that such direction shall not be otherwise than in accordance with law and the provisions of the Indenture, and that the Trustee shall have the right to decline to follow any such direction which in the opinion of the Trustee (which determination the Trustee has no duty to make) would be unjustly prejudicial to 2020 Bond Owners not parties to such direction. Section 7.06. Suit by Owners. No Owner of any 2020 Bonds shall have the right to institute any suit, action or proceeding at law or in equity, for the protection or enforcement of any right or remedy under the Indenture with respect to such 2020 Bonds, unless: (a) such Owners shall have given to the Trustee written notice of the occurrence of an Event of Default; (b) the Owners of not less than fifty percent (50%) in aggregate principal amount of the 2020 Bonds then Outstanding shall have made written request upon the Trustee to exercise the powers hereinbefore granted or to institute such suit, action or proceeding in its own time; (c) such Owner or Owners shall have tendered to the Trustee reasonable indemnity against the costs, expenses and liabilities to be incurred in compliance with such request; (d) the Trustee shall have failed to comply with such request for a period of sixty (60) days after such written request shall have been received by, and said tender of indemnity, shall have been made to, the Trustee; and (e) no direction inconsistent with such written request shall have been given to the Trustee during such sixty (60) day period by the Owners of a majority in aggregate principal amount of the 2020 Bonds then Outstanding. Such notification, request, tender of indemnity and refusal or omission are hereby declared, in every case, to be conditions precedent to the exercise by any Owner of 2020 Bonds of any remedy hereunder or under law; it being understood and intended that no one or more Owners of 2020 Bonds shall have any right in any manner whatever by their action to affect, disturb or prejudice the security of the Indenture or the rights of any other Owners of 2020 Bonds, or to enforce any right under the 2020 Bonds, the Indenture, or applicable law with respect to the 2020 Bonds, except in the manner herein provided, and that all proceedings at law or in equity to enforce any such right shall be 38 instituted, had and maintained in the manner herein provided and for the benefit and protection of all Owners of the Outstanding 2020 Bonds, subject to the provisions of the Indenture. Section 7.07. Absolute Obligation of the City. Nothing in this Section 7.07 or in any other provision of the Indenture or in the 2020 Bonds shall affect or impair the obligation of the City, which is absolute and =conditional, to pay the principal of and interest on the 2020 Bonds to the respective Owners of the 2020 Bonds at their respective dates of maturity, or upon call for redemption, as herein provided, but only out of the Revenues and other assets herein pledged therefor, or affect or impair the right of such Owners, which is also absolute and unconditional, to enforce such payment by virtue of the contract embodied in the 2020 Bonds. Section 7.08. Remedies Not Exclusive. No remedy herein conferred upon or reserved to the Trustee or to the Owners of the 2020 Bonds is intended to be exclusive of any other remedy or remedies, and each and every such remedy, to the extent permitted by law, shall be cumulative and in addition to any other remedy given hereunder or now or hereafter existing at law or in equity or otherwise. Section 7.09. No Waiver of Default. No delay or omission of the Trustee or of any Owner of the 2020 Bonds to exercise any right or power arising upon the occurrence of 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 an acquiescence therein. ARTICLE VIB THE TRUSTEE Section 8.01. Duties. Immunities and Liabilities of Trustee. (a) The Trustee shall, prior to an Event of Default, and after the curing or waiving of all Events of Default which may have occurred perform such duties and only such duties as are expressly and specifically set forth in the Indenture, and no implied covenants or duties shall be read into the Indenture against the Trustee. The Trustee shall, during the existence of any Event of Default (which has not been cured or waived), exercise such of the rights and powers vested in it by the Indenture, and use the same degree of care and skill in their exercise, as a prudent person would exercise or use under the circumstances in the conduct of such person's own affairs. (b) The City may remove the Trustee at any time upon thirty (30) days' prior notice, unless an Event of Default shall have occurred and then be continuing, and shall remove the Trustee if at any time requested to do so by an instrument or concurrent instruments in writing signed by the Owners of not less than a majority in aggregate principal amount of the 2020 Bonds then Outstanding (or their attorneys duly authorized in writing) or if at any time the Trustee shall cease to be eligible in accordance with subsection (e) of this Section, or shall become incapable of acting, or shall be adjudged a bankrupt or insolvent, or a receiver of the Trustee or its property shall be appointed, or any public officer shall take control or charge of the Trustee or of its property or affairs for the purpose of rehabilitation, conservation or liquidation, in each case by giving written notice of such removal to the Trustee and thereupon shall promptly appoint a successor Trustee by an instrument in writing. 39 (c) The Trustee may at any time resign by giving written notice of such resignation to the City and by giving the 2020 Bond Owners notice of such resignation by mail at the addresses shown on the Registration Books. Upon receiving such notice of resignation, the City shall promptly appoint a successor Trustee by an instrument in writing. (d) Any removal or resignation of the Trustee and appointment of a successor Trustee shall become effective upon acceptance of appointment by the successor Trustee. If no successor Trustee shall have been appointed and have accepted appointment within forty-five (45) days of giving notice of removal or notice of resignation as aforesaid, the retiring Trustee or any 2020 Bond Owner (on behalf of such 2020 Bond Owner and all other 2020 Bond Owners) may petition any court of competent jurisdiction for the appointment of a successor Trustee, and such court may thereupon, after such notice (if any) as it may deem proper, appoint such successor Trustee. Any successor Trustee appointed under the Indenture shall signify its acceptance of such appointment by executing and delivering to the City and to its predecessor Trustee a written acceptance thereof, and thereupon such successor Trustee, without any further act, deed or conveyance, shall become vested with all of the moneys, estates, properties, rights, powers, trusts, duties and obligations of such predecessor Trustee, with like effect as if originally named Trustee herein; but, nevertheless at the Written Request of the City or the request of the successor Trustee, such predecessor Trustee shall execute and deliver any and all instruments of conveyance or further assurance and do such other things as may reasonably be required for more fully and certainly vesting in and confirming to such successor Trustee all of the right, title and interest of such predecessor Trustee in and to any property held by it under the Indenture and shall pay over, transfer, assign and deliver to the successor Trustee any money or other property subject to the trusts and conditions herein set forth. Upon request of the successor Trustee, the City shall execute and deliver any and all instruments as may be reasonably required for more fully and certainly vesting in and confirming to such successor Trustee all such moneys, estates, properties, rights, powers, trusts, duties and obligations. Upon acceptance of appointment by a successor Trustee as provided in this subsection, the City shall mail or cause the successor trustee to mail a notice of the succession of such Trustee to the trusts hereunder to each rating agency which is then rating the 2020 Bonds and to the 2020 Bond Owners at the addresses shown on the Registration Books. If the City fails to mail such notice within fifteen (15) days after acceptance of appointment by the successor Trustee, the successor Trustee shall cause such notice to be mailed at the expense of the City. (e) Any Tout" appointed under the provisions of this Section in succession to the Trustee shall be a trout company, banking association or bank having the powers of a trust company, having a combined capital and surplus of at least Seventy Five Million Dollars ($75,000,000), and subject to supervision or examination for federal or state authority. If such bank, banking association or trust company publishes a report of condition at least annually, pursuant to law or to the requirements of any supervising or examining authority above referred to, then for the purpose of this subsection the combined capital and surplus of such trust company, banking association or bank 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 subsection (a), the Trustee shall resign immediately in the manner and with the effect specified in this Section. Section 8.02. Merger or Consolidation. Any tout company, banking association or bank into which the Trustee may be merged or converted or with which it may be consolidated or any trust company, banking association or bank resulting from any merger, conversion or consolidation to which it shall be a party or any trust company, banking association or bank to which the Trustee may 40 sell or transfer all or substantially all of its corporate trust business, provided that such trust company, banking association or bank shall be eligible under subsection (e) of Section 8.01, shall be the successor to such Trustee, without the execution or filing of any paper or any further act, anything herein to the contrary notwithstanding. Section 8.03. Liability of Trustee. (a) The recitals of facts herein and in the 2020 Bonds shall be taken as statements of the City, and the Trustee shall not assume responsibility for the correctness of the same, or make any representations as to the validity or sufficiency of the Indenture or the 2020 Bonds, nor shall the Trustee incur any responsibility in respect thereof, other than as expressly stated herein in connection with the respective duties or obligations herein or in the 2020 Bonds assigned to or imposed upon it. The Trustee shall, however, be responsible for its representations contained in its certificate of authentication on the 2020 Bonds. The Trustee shall not be liable in connection with the performance of its duties hereunder, except for its own negligence or willful misconduct. The Trustee may become the Owner of 2020 Bonds with the same rights it would have if it were not Trustee, and, to the extent permitted by law, may act as depository for and permit any of its officers or directors to act as a member of, or in any other capacity with respect to, any committee formed to protect the rights of 2020 Bond Owners, whether or not such committee shall represent the Owners of a majority in principal amount of the 2020 Bonds then Outstanding. (b) The Trustee shall not be liable for any error of judgment made in good faith by a responsible officer, unless it shall be proved that the Trustee was negligent in ascertaining the pertinent facts. (c) 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 not less than a majority (or such other percentage provided for herein) in aggregate principal amount of the 2020 Bonds at the time Outstanding 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 the Indenture. (d) The Trustee shall not be liable for any action taken by it in good faith and believed by it to be authorized or within the discretion or rights or powers conferred upon it by the Indenture. (e) The Trustee shall not be deemed to have knowledge of any default or Event of Default hereunder or any other event which, with the passage of time, the giving of notice, or both, would constitute an Event of Default hereunder unless and until a Responsible Officer of the Trustee shall have actual knowledge of such event or the Trustee shall have been notified in writing, in accordance with Section 11.07, of such event by the City or the Owners of not less than fifty percent (50%) of the 2020 Bonds then Outstanding. Except as otherwise expressly provided herein, the Trustee shall not be bound to ascertain or inquire as to the performance or observance by the City of any of the terms, conditions, covenants or agreements herein of any of the documents executed in connection with the 2020 Bonds, or as to the existence of an Event of Default thereunder or an event which would, with the giving of notice, the passage of time, or both, constitute an Event of Default thereunder. The Trustee shall not be responsible for the validity, effectiveness or priority of any collateral given to or held by it. 41 (f) No provision of the Indenture shall require the Trustee to expend or risk its own funds or otherwise incur any financial liability in the performance of its duties hereunder, or in the exercise of any of its rights or powers. (g) The Trustee shall be under no obligation to exercise any of the rights or powers vested in it by the Indenture, including at the request, order or direction of any of the Owners pursuant to the Indenture, unless such Owners shall have offered to the Trustee security or indemnity satisfactory to the Trustee against the costs, expenses and liabilities which might be incurred by it in compliance with such request or direction. No permissive power, right or remedy conferred upon the Trustee hereunder shall be construed to impose a duty to exercise such power, right or remedy. (h) Whether or not herein expressly so provided every provision of the Indenture relating to the conduct or affecting the liability of or affording protection to the Trustee shall be subject to the provisions of this Article VIII. (i) The Trustee shall have no responsibility or liability with respect to any information, statement, or recital in any official statement, offering memorandum or any other disclosure material prepared or distributed with respect to the 2020 Bonds. 0) The immunities extended to the Trustee also extend to its directors, officers, employees and agents. (k) The Trustee may execute any of the trusts or powers of the Indenture and perform any of its duties through attorneys, agents and receivers and shall not be answerable for the conduct of the same if appointed by it with reasonable care. (1) The Trustee shall not be considered in breach of or in default in its obligations hereunder or progress in respect thereto in the event of delay in the performance of such obligations due to unforeseeable causes beyond its control and without its fault or negligence, including, but not limited to, acts of God or of the public enemy or terrorists, acts of a government, acts of the other party, fires, floods, epidemics, quarantine restrictions, strikes, freight embargoes, earthquakes, explosion, mob violence, riot, inability to procure or general sabotage or rationing of labor, equipment, facilities, sources of energy, material or supplies in the open market, litigation or arbitration involving a party or others relating to zoning or other governmental action or inaction pertaining to the Water System, malicious mischief, condemnation, and unusually severe weather or delays of suppliers or subcontractors due to such causes or any similar event and/or occurrences beyond the control of the Trustee. (m) The Trustee shall have the right to accept and act upon instructions, including fords transfer instructions ("Instructions") given pursuant to this Indenture and delivered using Electronic Means ("Electronic Means" shall mean the following communications methods: e- mail, facsimile transmission, secure electronic transmission containing applicable authorization codes, passwords and/or authentication keys issued by the Trustee, or another method or system specified by the Trustee as available for use in connection with its services hereunder); provided, however, that the City shall provide to the Trustee an incumbency certificate listing officers with the authority to provide such Instructions ("Authorized Officers") and containing specimen signatures of such Authorized Officers, which incumbency certificate shall be amended by the City whenever a person is to be added or deleted from the listing. If the City elects to give the Trustee Instructions using Electronic Means and the Trustee in its discretion elects to act upon such 42 Instructions, the Trustee's understanding of such Instructions shall be deemed controlling. The City understands and agrees that the Trustee cannot determine the identity of the actual sender of such Instructions and that the Trustee shall conclusively presume that directions that purport to have been seat by an Authorized Officer listed on the incumbency certificate provided to the Trustee have been sent by such Authorized Officer. The City shall be responsible for ensuring that only Authorized Officers transmit such Instructions to the Trustee and that the City and all Authorized Officers are solely responsible to safeguard the use and confidentiality of applicable user and authorization codes, passwords and/or authentication keys upon receipt by the City. The Trustee shall not be liable for any losses, costs or expenses arising directly or indirectly from the Trustee's reliance upon and compliance with such Instructions notwithstanding the fact that such directions conflict or are inconsistent with a subsequent written instruction. The City agrees: (i) to assume all risks arising out of the use of Electronic Means to submit Instructions to the Trustee, including without limitation the risk of the Trustee acting on unauthorized Instructions, and the risk of interception and misuse by third parties; (ii) that it is fully informed of the protections and risks associated with the various methods of transmitting Instructions to the Trustee and that there may be more secure methods of transmitting Instructions than the method(s) selected by the City; (iii) that the security procedures (if any) to be followed in connection with its transmission of Instructions provide to it a commercially reasonable degree of protection in light of its particular needs and circumstances; and (iv) to notify the Trustee immediately upon learning of any compromise or unauthorized use of the security procedures. (n) The Trustee shall not be concerned with or accountable to anyone for the subsequent use or application of any moneys which shall be released or withdrawn in accordance with the provisions hereof. (a) The permissive right of the Trustee to do things enumerated herein shall not be construed as a duty and it shall not be answerable for other than its negligence or willful misconduct. Section 8.04. Rielit to Rely on Documents. The Trustee shall be protected in acting upon any notice, resolution, requisition, request, consent, order, certificate, report, opinion, notes, direction, facsimile transmission, electronic mail in other paper or document believed by it to be genuine and to have been signed or presented by the proper party or parties. The Trustee may consult with counsel, who may be counsel of or to the City, with regard to legal questions, 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 therewith. The Trustee may treat the Owners of the 2020 Bonds appearing in the Trustee's Registration Books as the absolute owners of the 2020 Bonds for all purposes and the Trustee shall not be affected by any notice to the contrary. Whenever in the administration of the trusts imposed upon it by the Indenture 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, Request or Requisition of the City, and such Certificate, Request or Requisition shall be full warrant to the Trustee for any action taken or suffered in good faith under the provisions of the Indenture in reliance upon such Certificate, Request or Requisition, but in its discretion the Trustee may, in lieu thereof, 43 accept other evidence of such matter or may require such additional evidence as it may deem reasonable. Section 8.05. Preservation and Inspection of Documents. All documents that are received by the Trustee under the provisions of the Indenture shall be retained in its possession during the term hereof in accordance with applicable document retention policies and shall be subject at all reasonable times to the inspection of the City and any 2020 Bond Owner, and their agents and representatives duly authorized in writing, at reasonable hours and under reasonable conditions. Section 8.06. Compensation and Indemnification. The City shall pay to the Trustee from time to time all reasonable compensation for all services tendered under the Indenture, and also all reasonable expenses, charges, legal and consulting fees and other disbursements and those of their attorneys, agents and employees, incurred in and about the performance of their powers and duties under the Indenture. The City shall indemnify, defend and hold harmless the Trustee, its officers, employees, directors and agents from and against any loss, costs, claim, liability or expense (including fees and expenses of its attorneys and advisors) incurred without negligence or willful misconduct on its part, arising out of or in connection with the execution of the Indenture, acceptance or administration of this trust or any other document or transaction executed in connection herewith, including costs and expenses of defending itself against any claim or liability in connection with the exercise or performance of any of its powers hereunder. The rights of the Trustee and the obligations of the City under this Section 8.06 shall survive removal or resignation of the Trustee hereunder or the discharge of the 2020 Bonds and the Indenture. When the Trustee incurs expenses or renders services after the occurrence of an Event of Default, such expenses and the compensation for such services are intended to constitute expenses of administration under any federal or state bankruptcy, insolvency, arrangement, moratorium, reorganization or other debtor relief law. Upon an Event of Default, and only upon an Event of Default, the Trustee shall have a first lien with right of payment prior to payment on account of principal of and premium, if any, and interest on any 2020 Bond, upon the trust estate for the foregoing fees, charges and expenses incurred by it. ARTICLE IX MODIFICATION OR AMENDMENT OF THE INDENTURE Section 9.01. Amendments Permitted. (a) The Indenture and the rights and obligations of the City and of the Owners of the 2020 Bonds and of the Trustee may be modified or amended from time to time and at any time by an indenture or indentures supplemental thereto, which the City and the Trustee may enter into when the written consent of the Owners of a majority in aggregate principal amount of all 2020 Bonds then Outstanding, exclusive of 2020 Bonds disqualified as provided in Section 11.09 hereof, shall have been filed with the Trustee. No such modification or amendment shall: (1) extend the fixed maturity of any 2020 Bonds, or reduce the amount of principal thereof or premium (if any) thereon, or extend the time of payment, or change the rate of interest or the method of computing the rate of interest thereon, or extend the time of payment of interest thereon, without the consent of the Owner of each 2020 Bond so affected; or (2) reduce the aforesaid percentage of 2020 Bonds the consent of the m Owners of which is required to affect any such modification or amendment, or permit the creation of any lien on the Revenues and other assets pledged under the Indenture prior to or on a parity with the lien created by the Indenture except as permitted herein, or deprive the Owners of the 2020 Bonds of the lien created by the Indenture on such Revenues and other assets except as permitted herein, without the consent of the Owners of all of the 2020 Bonds then Outstanding. It shall not be necessary for the consent of the 2020 Bond Owners to approve the particular form of any Supplemental Indenture, but it shall be sufficient if such consent shall approve the substance thereof. Promptly after the execution by the City and the Trustee of any Supplemental Indenture pursuant to this subsection (a), the Trustee shall mail a notice, setting forth in general temps the substance of such Supplemental Indenture, to each Rating Agency and the Owners of the 2020 Bonds at the respective addresses shown on the Registration Books. Any failure to give such notice, or any defect therein, shall not, however, in any way impair or affect the validity of any such Supplemental Indenture. (b) The Indenture and the rights and obligations of the City, the Trustee and the Owners of the 2020 Bonds may also be modified or amended from time to time and at any time by a Supplemental Indenture, which the City and the Trustee may enter into without the consent of any 2020 Bond Owners, if the Trustee shall receive an opinion of Bond Counsel to the effect that the provisions of such Supplemental Indenture shall not materially adversely affect the interests of the Owners of the Outstanding 2020 Bonds, including, without limitation, for any one or more of the following purposes: (1) to add to the covenants and agreements of the City contained in the Indenture other covenants and agreements thereafter to be observed to pledge or assign additional security for the 2020 Bonds (or any portion thereof), or to surrender any right or power herein reserved to or conferred upon the City; (2) to make such provisions for the purpose of curing any ambiguity, inconsistency or omission, or of curing or correcting any defective provision, contained in the Indenture, or in regard to matters or questions arising under the Indenture, as the City may deem necessary or desirable; (3) to modify, amend or supplement the Indenture in such manner as to permit the qualification hereof under the Trust Indenture Act of 1939, as amended, or any similar federal statute hereunder in effect, and to add such other terms conditions and provisions as may be permitted by said act or similar federal statute; and (4) to modify, amend or supplement the Indenture in such manner as to cause interest on the 2020 Bonds to remain excludable from gross income =der the Code- (c) The Trustee may in its discretion, but shall not be obligated to, enter into any such Supplemental Indenture authorized by subsections (a) or (b) of this Section which materially adversely affects the Trustee's own rights, duties or immunities =der the Indenture or otherwise. (d) Prior to the Trustee entering into any Supplemental Indenture hereunder, there shall be delivered to the Trustee an opinion of Bond Counsel stating, in substance, that such Supplemental Indenture has been adopted in compliance with the requirements of the Indenture and that the adoption of such Supplemental Indenture will not, in and of itself, adversely affect the exclusion of interest on the 2020 Bonds from federal income taxation and from state income taxation. U1 Section 9.02. Effect of Supplemental Indenture. Upon the execution of any Supplemental Indenture pursuant to this Article, the Indenture shall be deemed to be modified and amended in accordance therewith, and the respective rights, duties and obligations under the Indenture of the City, the Trustee and all Owners of 2020 Bonds Outstanding shall thereafter be determined, exercised and enforced thereunder subject in all respects to such modification and amendment, and all the terms and conditions of any such Supplemental Indenture shall be deemed to be part of the terms and conditions of the Indenture for any and all purposes. Section 9.03. Endorsement of 2020 Bonds; Preparation of New 2020 Bonds. 2020 Bonds delivered after the execution of any Supplemental Indenture pursuant to this Article 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 any modification or amendment provided for in such Supplemental Indenture, and, in that case, upon demand on the Owner of any 2020 Bonds Outstanding at the time of such execution and presentation of his or her 2020 Bonds for the purpose at the Office of the Trustee or at such additional offices as the Trustee may select and designate for that purpose, a suitable notation shall be made on such 2020 Bonds. If the Supplemental Indenture shall so provide, new 2020 Bonds so modified as to conform, in the opinion of the City and the Trustee, to any modification or amendment contained in such Supplemental Indenture, shall be prepared and executed by the City and authenticated by the Trustee, and upon demand on the Owners of any 2020 Bonds then Outstanding shall be exchanged at the Office of the Trustee, without cost to any 2020 Bond Owner, for 2020 Bonds then Outstanding, upon surrender fm cancellation of such 2020 Bonds, in equal aggregate principal amount of the same maturity. Section 9.04. Amendment of particular 2020 Bonds. The provisions of this Article shall not prevent any 2020 Bond Owner from accepting any amendment as to the particular 2020 Bonds held by such Owner. ARTICLE X DEFEASANCE Section 10.01. Discharge of Indenture. The 2020 Bonds may be paid by the City in any of the following ways, provided that the City also pays or causes to be paid any other sums payable hereunder by the City: (a) by paying or causing to be paid the principal of and interest and redemption premiums (if any) on the 2020 Bonds, as and when the same become due and payable; (b) by depositing with the Trustee, in tout, at or before maturity, money or securities in the necessary amount (as provided in Section 10.03) to pay or redeem all 2020 Bonds then Outstanding; or (c) by delivering to the Trustee, for cancellation by it, all of the 2020 Bonds then Outstanding. If the City shall also pay or cause to be paid all other sums payable hereunder by the City, then and in that case, at the election of the City (as evidenced by a Certificate of the City, filed with the Trustee, signifying the intention of the City to discharge all such indebtedness and the Indenture), and notwithstanding the fact that any 2020 Bonds shall not have been surrendered for payment, the 46 Indenture and the pledge of Revenues and other assets made under the Indenture and all covenants, agreements and other obligations of the City under the Indenture shall cease, terminate, become void and be completely discharged and satisfied, except for the City's obligations under Section 8.06. In such event, upon the Written Request of the City, the Trustee shall execute and deliver to the City all such instruments as may be necessary or desirable to evidence such discharge and satisfaction, and the Trustee shall pay over, transfer, assign or deliver all moneys or securities or other property held by it pursuant to the Indenture which are not required for the payment or redemption of 2020 Bonds not theretofore surrendered for such payment or redemption to the City. Section 10.02. Discharge of Liability on 2020 Bonds. Upon the deposit with the Trustee, in tout, at or before maturity, of money or securities in the necessary amount (as provided in Section 10.03) to pay or redeem any Outstanding 2020 Bonds (whether upon or prior to the maturity or the Redemption Date of such 2020 Bonds), provided that, if such Outstanding 2020 Bonds are to be redeemed prior to maturity, notice of such redemption shall have been given as provided in Article IV or provisions satisfactory to the Trustee shall have been made for the giving of such notice, then all liability of the City in respect of such 2020 Bonds shall cease, terminate and be completely discharged, and the Owners thereof shall thereafter be entitled only to payment out of such money or securities deposited with the Trustee as aforesaid for their payment, subject however, to the provisions of Section 10.04. The City may at any time surrender to the Trustee for cancellation by it any 2020 Bonds previously issued and delivered, which the City may have acquired in any mamaer whatsoever, and such 2020 Bonds, upon such surrender and cancellation, shall be deemed to be paid and retired. Section 10.03. Deoosit of Money or Securities with Trustee. Whenever in the Indenture it is provided or permitted that there be deposited with or held in trust by the Trustee money or securities in the necessary amount to pay or redeem any 2020 Bonds, the money or securities so to be deposited or held may include money or securities held by the Trustee in the Ponds and accounts established pursuant to the Indenture and shall be: (a) lawful money of the United States of America in an amount equal to the principal amount of such 2020 Bonds and all unpaid interest thereon to maturity, except that, in the case of 2020 Bonds which are to be redeemed prior to maturity and in respect of which notice of such redemption shall have been given as provided in Article IV or provisions satisfactory to the Trustee shall have been made for the giving of such notice, the amount to be deposited or held shall be the principal amount of such 2020 Bonds and all unpaid interest and premium, if any, thereon to the Redemption Date; or (b) Federal Securities the principal of and interest on which when due will, in the written opinion of an Independent Certified Public Accountant or Independent Financial Consultant filed with the City and the Trustee, provide money sufficient to pay the principal of and all unpaid interest to maturity, or to the Redemption Date (with premium, if any), as the case may be, on the 2020 Bonds to be paid or redeemed, as such principal, interest and premium, if any, become due, provided that in the case of 2020 Bonds which are to be redeemed prior to the maturity thereof, notice of such redemption shall have been given as provided in Article IV or provision satisfactory to the Trustee shall have been made for the giving of such notice; provided, in each case, that: (i) the Trustee shall have been irrevocably instructed (by the terms of the Indenture or by Written Request of the City) to apply such money to the payment of such principal, 47 interest and premium, if any, with respect to such 2020 Bonds; and (ii) the City shall have delivered to the Trustee an opinion of Bond Counsel addressed to the City and the Trustee to the effect that such 2020 Bonds have been discharged in accordance with the Indenture (which opinion may rely upon and assume the accuracy of the Independent Certified Public Accountant's or Independent Financial Consultant's opinion referred to above). Section 10.04. Payment of 2020 Bonds After Discharge of Indenture. Notwithstanding any provisions of the Indenture, any moneys held by the Trustee in trust for the payment of the principal of, or interest on, any 2020 Bonds and remaining unclaimed for two (2) years after the principal of all of the 2020 Bonds has become due and payable (whether at maturity or upon call for redemption or by acceleration as provided in the Indenture), if such moneys were so held at such date, or two (2) years after the date of deposit of such moneys if deposited after said date when all of the 2020 Bonds became due and payable, shall be repaid to the City (without liability for interest) free from the trusts created by the Indenture upon receipt of an indemnification agreement acceptable to the City and the Trustee indemnifying the Trustee with respect to claims of Owners of 2020 Bonds which have not yet been paid, and all liability of the Trustee with respect to such moneys shall thereupon cease; provided, however, that before the repayment of such moneys to the City as aforesaid, the Trustee shall at the written direction of the City (at the cost of the City) first mail to the Owners of 2020 Bonds which have not yet been paid, at the addresses shown on the Registration Books, a notice, in such form as may be deemed appropriate by the Trustee with respect to the 2020 Bonds so payable and not presented and with respect to the provisions relating to the repayment to the City of the moneys held for the payment thereof. ARTICLE XI MISCELLANEOUS Section 11.01. Liability of City Limited to Revenues. Notwithstanding anything in the Indenture or the 2020 Bonds, but subject to the priority of payment with respect to Operation and Maintenance Costs, the City shall not be required to advance any moneys derived from any source other than the Revenues, the Revenue Fund and other moneys pledged under the Indenture for any of the purposes mentioned in the Indenture, whether for the payment of the principal of or interest on the 2020 Bonds or for any other purpose of the Indenture. Nevertheless, the City may, but shall not be required to, advance for any of the purposes hereof any funds of the City which may be made available to it for such purposes. The obligation of the City to pay interest and principal on the 2020 Bonds is a special obligation of the City payable solely from the Net Revenues, and does not constitute a debt of the City or of the State of California or of any political subdivision thereof (other than the City) in contravention of any constitutional or statutory debt limitation or restriction. Section 11.02. Successor Is Deemed Included in All References to Predecessor. Whenever in the Indenture either the City or the Trustee is named or referred to, such reference shall be deemed to include the successors or assigns thereof, and all the covenants and agreements in the Indenture contained by or on behalf of the City or the Trustee shall bind and inure to the benefit of the respective successors and assigns thereof whether so expressed or not. Section 11.03. Limitation of Rights to Parties and 2020 Bond Owners. Nothing in the Indenture or in the 2020 Bonds expressed or implied is intended or shall be constmed to give to any 48 person other than the City, the Trustee and the Owners of the 2020 Bonds, any legal or equitable right, remedy or claim under or in respect of the Indenture or any covenant, condition or provision therein or herein contained; and all such covenants, conditions and provisions are and shall be held to be for the sole and exclusive benefit of the City, the Trustee and the Owners of the 2020 Bonds. Section 11.04. Waiver of Notice; RRte uirement of Mailed Notice. Whenever in the Indenture the giving of notice by mail or otherwise is required, the giving of such notice may be waived in writing by the person entitled to receive such notice and in any such case the giving or receipt of such notice shall not be a condition precedent to the validity of any action taken in reliance upon such waiver. Whenever in the Indenture any notice shall be required to be given by mail, such requirement shall be satisfied by the deposit of such notice in the United States mail, postage prepaid by first class mail. Section 11.05. Destruction of 2020 Bonds. Whenever in the Indenture provision is made for the cancellation by the Trustee and the delivery to the City of any 2020 Bonds, the Trustee shall destroy such 2020 Bonds as may be allowed by law, and, upon the City's request, deliver a certificate of such destruction to the City. Section 11.06. Severability of Invalid Provisions. If any one or more of the provisions contained in the Indenture or in the 2020 Bonds 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 the Indenture and such invalidity, illegality or munforceability shall not affect any other provision of the Indenture, and the Indenture shall be construed as if such invalid or illegal or unenforceable provision had never been contained herein. The City hereby declares that it would have entered into the Indenture and each and every other Section, paragraph, sentence, clause or phrase hereof and authorized the issuance of the 2020 Bonds pursuant thereto irrespective of the fact that any one or more Sections, paragraphs, sentences, clauses or phrases of the Indenture may be held illegal, invalid or unenforceable. Section 11.07. Notices. Any notice to or demand upon the City or the Trustee shall be deemed to have been sufficiently given or served for all purposes by being sent by facsimile, electronic mail, overnight mail or courier, or by being deposited, first class mail, postage prepaid, in a post office letter box, addressed, as the case may be, to the City at City of Vemon, 4305 South Santa Fe Avenue, Vernon, California 90058, Attention: City Administrator (or such other address as may have been filed in writing by the City with the Trustee), or to the Trustee at its Office. Notwithstanding the foregoing provisions of this Section 11.07, the Trustee shall not be deemed to have received, and shall not be liable for failing to act upon the contents of, any notice unless and until the Trustee actually receives such notice. Section 11.08. Evidence of Rights of 2020 Bond Owners. Any request, consent or other instrument required or permitted by the Indenture to be signed and executed by 2020 Bond Owners may be in any number of concurrent instruments of substantially similar tenor and shall be signed or executed by such 2020 Bond Owners in person or by an agent or agents duly appointed in writing. Proof of the execution of any such request, consent or other instrument or of a writing appointing any such agent, or of the holding by any person of 2020 Bonds transferable by delivery, shall be sufficient for any purpose of the Indenture and shall be conclusive in favor of the Trustee and the Cityif made in the manner provided in this Section. 49 The fact and date of the execution by any person of any such request, consent or other instrument or writing may be proved by the certificate of any notary public or other officer of any jurisdiction, authorized by the laws thereof to take acknowledgments of deeds, certifying that the person signing such request, consent or other instrument acknowledged to him the execution thereof, or by an affidavit of a witness of such execution duly swom to before such notary public or other officer. The Ownership of 2020 Bonds shall be proved by the Registration Books. Any request, consent, or other instrument or writing of the Owner of any 2020 Bond shall bind every future Owner of the same 2020 Bond and the Owner of every 2020 Bond issued in exchange therefor or in lieu thereof, in respect of anything done or suffered to be done by the Trustee or the City in accordance therewith or reliance thereon. Section 11.09. Disqualified 2020 Bonds. In determining whether the Owners of the requisite aggregate principal amount of 2020 Bonds have concurred in any demand, request, direction, consent or waiver under the Indenture, 2020 Bonds which are actually known by a Responsible Officer of the Trustee to be owned or held by or for the account of the City, or by any other obligor on the 2020 Bonds, or by any person directly or indirectly controlling or controlled by, or under direct or indirect common control with, the City or any other obligor on the 2020 Bonds, shall be disregarded and deemed not to be Outstanding for the purpose of any such determination, unless all 2020 Bonds are so owned or held, in which case such 2020 Bonds shall not be disregarded and shall be deemed to be Outstanding. 2020 Bonds so owned which have been pledged in good faith may be regarded as Outstanding for the purposes of this Section if the pledgee shall establish to the satisfaction of the Trustee the pledgm's right to vote such 2020 Bonds and that the pledgee is not a person directly or indirectly controlling or controlled by, or under direct or indirect common control with, the City or any other obligor on the 2020 Bonds. In case of a dispute as to such right, any decision by the Trustee taken upon the advice of counsel shall be fall protection to the Tntstee. Upon request, the City shall certify to the Trrstee those 2020 Bonds that are disqualified pursuant to this Section 11.09 and the Trustee may conclusively rely on such certificate. Section 11.10. Money Held for Particular 2020 Bonds. The money held by the Trustee for the payment of the interest, principal or premium due on any date with respect to particular 2020 Bonds (or portions of 2020 Bonds in the case of registered 2020 Bonds redeemed in par only) shall, on and after such date and pending such payment, be set aside on its books and held in trust by it for the Owners of the 2020 Bonds entitled thereto, subject, however, to the provisions of Section 10.04 hereof but without any liability for interest thereon. Section It. 11. Funds and Accounts. Any fund or account required by the Indenture to be established and maintained by the Trustee may be established and maintained in the accounting records of the Trustee, either as a fund or an account, and may, for the purposes of such records, any audits thereof and any reports or statements with respect thereto, be treated either as a fund or as an account; but all such records with respect to all such funds and accounts shall at all times be maintained in accordance with corporate trust industry standards to the extent practicable, and with due regard for the requirements of Section 6.05(a) and for the protection of the security of the 2020 Bonds and the rights of every Owner thereof. Section 11.12. Waiver of Personal Liabiliri. No member, officer, agent, employee, consultant or attorney of the City shall be individually or personally liable for the payment of the 50 principal of or premium or interest on the 2020 Bonds or be subject to any personal liability or accountability by reason of the issuance thereof; but nothing herein contained shall relieve any such member, officer, agent, employee, consultant or attorney from the performance of any official duty provided by law or by the Indenture. Section 11.13. Execution in Several Counterparts. The Indenture may be executed in any number of counterparts and each of such counterparts shall for all purposes be deemed to be an original; and all such counterparts, or as many of them as the City and the Trustee shall preserve undestroyed, shall together constitute but one and the same instrument. Section 11.14. CUSIP Numbers. Neither the Trustee nor the City shall be liable for any defect or inaccuracy in the CUSIP number that appears on any 2020 Bond or in any redemption notice. The Trustee may, in its discretion, include in any redemption notice a statement to the effect that the CUSIP numbers on the 2020 Bonds have been assigned by an independent service and are included in such notice solely for the convenience of the 2020 Bondholders and that neither the City nor the Trustee shall be liable for my inaccuracies in such numbers. Section 11.15. Choice of Law. THE INDENTURE SHALL BE GOVERNED BY THE LAWS OF THE STATE OF CALIFORNIA. Section 11.16. Paired Obligation Provider Guidelines. For purposes of Sections 6.14 and 6.21, Paired Obligations shall comply with the following conditions: (a) A Paired Obligation Provider shall initially have a long-term rating of A- or better by S&P and A3 or better by Moody's. (b) So long as the long-term rating of the Paired Obligation Provider is not reduced below Baa2 by S&P or BBB by Moody's, the interest rate of such Paired Obligation shall be deemed to be equal to the irrevocable fixed interest rate attributable thereto for purposes of Sections 6.14 and 6.21. In the event that a Paired Obligation Provider does not maintain the Minimum Rating Requirement and the City does not replace such Paired Obligation Provider with another Paired Obligation Provider which maintains the Initial Rating Requirement within ten (10) Business Days of notice that the Paired Obligation Provider has not maintained the Minimum Rating Requirement, interest with respect to such Paired Obligations shall be computed for purposes of Sections 6.14 and 6.21 without regard to payments to be received from the Paired Obligation Provider. The Trustee has no obligation to monitor the ratings of any Paired Obligation Providers. 51 IN WITNESS WHEREOF, the City has caused the Indenture to be signed in its name by its Authorized Representative, and the Trustee, in token of its acceptance of the duties and obligations of the Trustee created hereunder, has caused the Indenture to be signed in its corporate name by its officer thereunto duly authorized, all as of the day and year first above written. CITY OF VERNON By: Its: THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., as Trustee By: Its: Authorized Officer S-1 EXHIBIT A FORM OF 2020 BOND UNLESS THIS BOND IS PRESENTED BY AN AUTHORIZED REPRESENTATIVE OF THE DEPOSITORY (AS DEFINED IN THE INDENTURE) TO THE TRUSTEE FOR REGISTRATIONOF TRANSFER, EXCHANGE, OR PAYMENT, AND ANYBOND ISSUED IS REGISTERED RV THE NAME OF CEDE A CO. OR RV SUCH OTHER NAME AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF THE DEPOSITORY (AND ANY PAYMENT IS MADE TO CEDE A CO. OR TO SUCH OTHER ENTITY AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF THE DEPOSITOR}), ANY TRANSFER, PLEDGE, OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANYPERSONIS WRONGFUL RVASMUCH AS THE REGISTERED OWNER HEREOF, CEDE A CO., HAS AN INTEREST HEREIN. No. $ UNITED STATES OF AMERICA STATE OF CALIFORNIA CITY OF VERNON WATER SYSTEM REVENUE BONDS, 2020 SERIES A INTEREST RATE MATURITY DATE ORIGINAL ISSUE DATE CUSB' % August 1, 20_ March _, 2020 _ REGISTERED OWNER CEDE & CO. PRINCIPAL AMOUNT: DOLLARS The CITY OF VERNON, a municipal corporation that is duly organized and existing under its charter and the Constitution of the State of California (the "City"'), for value received, hereby promises to pay to the Registered Owner specified above or registered assigns (the "Registered Owner"), on the Maturity Date specified above (subject to any right of prior redemption hereinafter provided for), the Principal Amount specified above, in lawful money of the United States of America, and to pay interest thereon in like lawful money from the interest payment date next preceding the date of authentication of this Bond (unless: (i) this Bond is authenticated after the fifteenth day of the calendar month preceding an interest payment date, whether or not such day is a business day, and on or before the following interest payment date, in which event it shall bear interest from such interest payment date; or (ii) this Bond is authenticated on or before [July 15, 2020], in which event it shall bear interest from the Original Issue Date identified above; provided, however, that if as of the date of authentication of this Bond, interest is in default on this Bond, this Bond shall bear interest from the interest payment date to which interest has previously been paid or made available for payment on this Bond), at the Interest Rate per annum specified above, payable on August 1, 2020 and each February 1 and August 1 thereafter, calculated on the basis of a 360 day year composed of twelve 30 day months. Principal hereof and premium, if any, upon early redemption hereof are payable by check of the Trustee upon presentation and surrender hereof at the Office (as defined in the hereinafter described Indenture) of The Bank of New York Mellon Trust Company, N.A., as trustee (the "Trustee"). Interest hereon is payable by check of the Trustee sent by A-1 first class mail on the applicable interest payment date to the Registered Owner hereof at the Registered Owner's address as it appears on the registration books of the Trustee as of the close of business on the fifteenth day of the month preceding each interest payment date (except that in the case of a Registered Owner of one million dollars ($1,000,000) or more in principal amount, such payment may, at such Registered Owner's option, be made by wire transfer of immediately available funds to an account in the United States in accordance with written instructions provided to the Trustee by such Registered Owner prior to the fifteenth (15th) day of the month preceding such interest payment date). This Bond is not a debt of the State of California, or any of its political subdivisions (other than the City), and neither the State, nor any of its political subdivisions (other than the City), is liable hereon, nor in any event shall this Bond be payable out of any funds or properties of the City other than the Net Revenues (as such term is defined in the Indenture of Trust, dated as of March 1, 2020 (the "Indenture"), by and between the City and the Trustee) and other moneys pledged therefor under the Indenture. The obligation of the City to make payments in accordance with the Indenture is a limited obligation of the City as set forth in the Indenture and the City shall have no liability or obligation in connection herewith except with respect to such payments to be made pursuant to the Indenture. This Bond does not constitute an indebtedness of the City in contravention of any constitutional or statutory debt limitation or restriction. This Bond is one of a duly authorized issue of bonds of the City designated as the "City of Vernon Water System Revenue Bonds, 2020 Series A" (the "2020 Bonds"), of an aggregate principal amount of Million _ Thousand Dollars ($�, all of like tenor and date (except for such variation, if any, as may be required to designate varying series, numbers or interest rates) and all issued pursuant to the provisions of Section 4.3 of the City's charter and Articles 10 and 11 of Chapter 3 of Part 1 of Division 2 of Title 5 (commencing with Section 53570) of the Government Code of the State of California, and pursuant to the Indenture and the resolution authorizing the issuance of the 2020 Bonds. Reference is hereby made to the Indenture (copies of which are on file at the office of the City) and all supplements thereto for a description of the terms on which the 2020 Bonds are issued, the provisions with regard to the nature and extent of the Net Revenues, and the rights thereunder of the Owners of the 2020 Bonds and the rights, duties and immunities of the Trustee and the rights and obligations of the City hereunder, to all of the provisions of which the Registered Owner of this Bond, by acceptance hereof, assents and agrees. The 2020 Bonds have been issued in fully registered form without coupons in denominations of $5,000 or any integral multiple thereof. The 2020 Bonds have been issued by the City for the purpose of financing certain capital improvements to the Water System of the City. This Bond and the interest, premium, if any, hereon and all other 2020 Bonds and the interest and premium, if any, thereon (to the extent set forth in the Indenture) are special obligations of the City, secured by a pledge and lien on the Revenues and any other amounts on deposit in certain funds and accounts created under the Indenture, and payable from the Net Revenues. As and to the extent set forth in the Indenture, all of the Revenues are exclusively and irrevocably pledged in accordance with the terms hereof and the provisions of the Indenture, to the payment of the principal of and interest and premium (if any) on this Bond. The Indenture and the rights and obligations of the City and the Owners of the 2020 Bonds and the Trustee may be modified or amended from time to time and at any time with the written A-2 consent of the Owners of a majority in aggregate principal amount of all 2020 Bonds then Outstanding, exclusive of Bonds disqualified as set forth in the Indenture, in the manner, to the extent and upon the terms provided in the Indenture, but no such modification or amendment shall: (i) extend the fixed maturity of any 2020 Bonds, or reduce the amount of principal thereof or premium (if any) thereon, or extend the time of payment, or change the method of computing the rate of interest thereon, or extend the time of payment of interest thereon, without the consent of the owner of each 2020 Bond so affected; or (ii) reduce the aforesaid percentage of 2020 Bonds the consent of the Owners of which is required to affect any such modification or amendment, or permit the creation of any lien on the Revenues and other assets pledged under the Indenture prior to or on a parity with the lien created by the Indenture except as permitted in the Indenture, or deprive the Owners of the 2020 Bonds of the lien created by the Indenture on such Revenues and other assets, except as expressly provided in the Indenture, without the consent of the Owners of all of the 2020 Bonds then Outstanding. The Indenture and the rights and obligations of the City, of the Trustee and the Owners of the 2020 Bonds may also be modified or amended for certain purposes described more fully in the Indenture at any time in the manner, to the extent and upon the terms provided in the Indenture by a supplemental indenture, which the City and the Trustee may enter into without the consent of any 2020 Bond Owners, if the Trustee shall receive an opinion of Bond Counsel to the effect that the provisions of such supplemental indenture will not materially adversely affect the interests of the Owners of the Outstanding 2020 Bonds. The 2020 Bonds with stated maturities on or after August 1, 20_, are subject to redemption prior to their respective stated maturities, as a whole or in part on _ 1, 20_, or any date thereafter, as directed by the City in a Written Request provided to the Trustee at least 35 days (or such lesser number of days acceptable to the Trustee in the sole discretion of the Trustee, such notice for the convenience of the Trustee) and by lot within each maturity in integral multiples of $5,000, at a Redemption Price equal to the principal amount thereof plus accrued interest thereon to the Redemption Date, without premium. The Term Bonds with stated maturities on August 1, 20_ are subject to mandatory sinking fund redemption in part (by lot) on August 1, 20_ and each v 1 thereafter, in integral multiples of $5,000 at a Redemption Price of the principal amount thereof plus accrued interest to the date fixed for redemption, without premium, in accordance with the following schedule: Redemption Date Principal (August 1) Amount zo 1 • Maturity. If some but not all of the Term Bonds are redeemed pursuant to the optional or extraordinary redemption provisions of the Indenture, as described above, the principal amount of the applicable Term Bonds to be redeemed on any subsequent August 1 will be reduced, by $5,000 or an integral multiple thereof, as designated by the City in a Written Order of the City filed with the Trustee; A-3 provided, however, that the aggregate amount of such reductions shall not exceed the aggregate amount of the applicable Term Bonds redeemed pursuant to the optional or extraordinary redemption provisions of the Indenture. As provided in the Indenture, notice of redemption shall be mailed by the Trustee by first class mail at least 20 days but not more than 60 days prior to the date fixed for redemption to the respective Owners of any 2020 Bonds designated for redemption at their addresses appearing on the registration books of the Trustee, but neither the failure to receive such notice nor any defect in the notice or the mailing thereof shall affect the validity of the redemption. If this Bond is called for redemption and payment is duly provided therefor as specified in the Indenture, interest shall cease to accrue hereon from and after the date fixed for redemption. If an Event of Default, as defined in the Indenture, shall occur, the principal of all of the 2020 Bonds and the interest accrued thereon may be declared due and payable upon the conditions, in the manner and with the effect provided in the Indenture, but such declaration and its consequences may be rescinded and annulled as fartber provided in the Indenture. This Bond is transferable by the Registered Owner hereof, in person or by his or her duly authorized attorney in writing, at the office of the Trustee but only in the manner, subject to the limitations and upon payment of the taxes and charges provided in the Indenture and upon surrender and cancellation of this Bond. Upon registration of such transfer, a new 2020 Bond or 2020 Bonds of the same series, of authorized denomination or denominations, for the same aggregate principal amount of the same maturity will be issued to the transferee in exchange therefor. This Bond may be exchanged at said office of the Trustee for a like aggregate principal amount of Bonds of other authorized denominations of the same series and same maturity, but only in the manner, subject to the limitations and upon payment of the taxes and charges provided in the Indenture. The Trustee shall not be required to register the transfer or exchange of this Bond during the period in which the Trustee is selecting 2020 Bonds for redemption or if this Bond has been selected for redemption. The City and the Trustee may treat the Registered Owner hereof as the absolute owner hereof for all purposes, and the City and the Trustee shall not be affected by any notice to the contrary. It is hereby certified that all of the things, conditions and acts required to exist, to have happened or to have been performed precedent to and in the issuance of this Bond do exist, have happened or have been performed to due and regular time, form and manner as required by the Indenture and the laws of the State of California and that the amount of this Bond together with all other indebtedness of the City, does not exceed any limit under any laws of the State of California, and is not in excess of the amount of 2020 Bonds permitted to be issued under the Indenture. This Bond shall not be entitled to any benefit under the Indenture or become valid or obligatory for any purpose until the certificate of authentication hereon endorsed shall have been manually signed by the Trustee. A-4 IN WITNESS WHEREOF, the City has caused this Bond to be executed in its name and on its behalf with the manual or facsimile signature of its Mayor as of this _ day of March, 2020. CITY OF VERNON By: Its: A-5 [FORM OF TRUSTEE'S CERTIFICATE OF AUTHENTICATION TO APPEAR ON BONDS] This is one of the Bonds described in the within -mentioned indenture. Dated: March , 2020 THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., as Trustee By: Its: Authorized Signatory M [FORM OF ASSIGNMENT] For value received the undersigned hereby sells, assigns and transfers onto (Name, Address and Tax Identification or Social Security Number of Assignee) the within registered Bond and hereby irrevocably constitute(s) and appoint(s) attorney, to transfer the same on the registration books of the Trustee with full power of substitution in the premises. Dated: Note: The signature(s) on this Assignment must correspond with the name(s) as written on the face of the within Bond in every particular without alteration or enlargement or any change whatsoever. Signature Guaranteed: Note: Signature guarantee shall be made by a guarantor institution participating in the Securities Transfer Agents Medallion program or in such other guarantee program acceptable to the Trustee. A-7 EXHIBIT B DESCRIPTION OF 2020 PROJECT Yevl Y.2 Ym3 Y.4 Capital Outln FY 19-20 FY M21 FY 21-22 FY 22-23 WeR5 Bea w S 125,OOO WeR 11 Nw and Ma S ISO" Gmunmm We1111 $ 3W,000 W6120 Rnub $ 550,W0 Gmeralmm WA S 3W,W0 WeR I] Rehabiliuvm S 6m,W0 WCR22Bnllin and CuMg S 2050m0 WeR 22 Wel& mem S 1 ,800,000 New WCWW.I &CM S 215AM S 215AW NewWeMMdhn&C3uftCmmsntim f 155.M S 155 m0 - ad Ma4r Phn S ON eto rcatliRmawnempW bl f t El lereud Turku mtavenm $ 2m m0 11 r eubmenm f 250000 cy GmM c GrnuummuteWeR 33 S 3m,W0 WeR IS Hebb S 5mm F�cy Grnmmrm Well is f 30%= lm,m0 Raavelr Demo at Wcll zo s 1 m0 BPI, BP2.BP3E - - Benp 3mm0 BPI Pumpand Mohr Rev wcle&ng RighHwm SW Om Bmer enc GmaarmB S R m ll t-s Pu BP3 m and Mal includino Riinn S ,=mo 500O SW BP2RcservoirS I f 1 m0 -nRdMBP3Dui &Cmumcnhl S 1 m0 P2 =andM B i&C Ri Rine S Raga R &Cauhu tim f ImO mO OEBP2Bev f 256 m0 WeR 3e UiAg mdCw WeR 23 and Cum f 2 Om Wel WeR 33WelWead m S 19669m Geomtmm Well S Imm0E35HAN S 1mm0 S 1 EM ca Ekclvml 11 S 5 m0 f 2Mmo $ 2 m0 PiW M Pill Main wm Peke eM Rd Soe Exlmaim H.,2 Have 2 fte[mbishmml Fmce hcemml PP2&Well 19 AusW TOhI S 7APMO S 3,10e,KR S CumuhRve Tnhl f 7AVJ M 1 S ll ISl,W S 14,261,M 1 $ 1 3l mm EXHIBIT C FORM OF REQUISITION FROM ACQUISFFION FUND CITY OF VERNON WATER SYSTEM REVENUE BONDS, 2020 SERIES A REQUISITION NO. FOR DISBURSEMENT FROM ACQUISITION FUND The undersigned hereby states and certifies: (i) that the undersigned is the duly appointed, qualified and acting Finance Director of the City of Vernon, a municipal corporation that is organized and existing under its charter and the Constitution of the State of California (the "City"), and as such, is familiar with the facts herein certified and is authorized to certify the same; (ii) that, pursuant to Section 3.05 of that certain Indenture of Trust, dated as of March 1, 2020 (the "Installment Purchase Agreement'), by and between the City and The Bank of New York Mellon Trust Company, N.A., as trustee (the "Trustee"), the undersigned hereby requests the Trustee to disburse this date the following amounts from the Acquisition Fund established under the Indenture relating to the above -captioned obligations, to the payees designated on the attached Exhibit A; (iii) that each obligation mentioned herein has been incurred by the City and is a proper charge against the Acquisition Fund; (iv) that any approval required under the California Environmental Quality Act, as amended (Division 13 of the California Public Resources Code), prior to the expenditure of such amount for the purpose set forth on the attached Exhibit A has been received and is final; and (v) that there has not been filed with or served upon the City notice of any lien, right to lien or attachment upon, or claim affecting the right to receive payment of, any of the moneys payable to any of the payees named on the attached Exhibit A. which has not been released or will not be released simultaneously with the payment of such obligation, other than materiahnen's or mechanics' liens accruing by mere operation of law. Dated: . 20 CITY OF VERNON L-M Finance Director C-1 EXHIBIT A ACQUISMON FUND Item Number Payee Name and Address Purpose of Obligation Amount C-2 EXHIBIT C FORM OF SUBSTITUTION STATEMENT The Bank of New York Mellon Trust Company, N.A. 400 South Hope Street, Suite 500 Los Angeles, California 90071 Attention: Corporate Trust Reference: City of Vernon 2020 The undersigned Finance Director of the City of Vernon (the "City") hereby states pursuant to Section 3.06 of the Indenture of Trust, dated as of March 1, 2020 (the "Indenture"), by and between the City and The Bank of New York Mellon Trust Company, N.A., as trustee that each component of the 2020 Project (as such term is defined in the Installment Purchase Agreement) described in the fast column of Exhibit A attached hereto, with an estimated cost set forth in the second column of Exhibit A, will be replaced by the corresponding improvement described in the third column of Exhibit A with an estimated cost set forth in the fourth column of Exhibit A. Dated: , 20_ D-1 Finance Director Components of 2020 Project to be Replaced EXHIBIT A Cost of Each Component of 1020 Project to be Replaced D-2 Improvements to be Substituted Cost of Each Improvement to be Substituted EXHIBIT C Norton Rase Fulbright USLLP—Draft of 01130120 S CITY OF VERNON Water System Revenue Bonds, 2020 Series A CONTRACT OF PURCHASE City of Vernon 4305 South Santa Fe Avenue Vernon, California 90058 Ladies and Gentlemen: 2020 The undersigned, J.P. Morgan Securities LLC, as underwriter (the "Underwriter'l, hereby offers to enter into this Contract of Purchase (this "Purchase Contract") with you, the City of Vernon ("the City"). This offer is made subject to acceptance by the City prior to 11:59 P.M., California time, on the date hereof, and if not so accepted, this offer will be subject to withdrawal by the Underwriter upon notice delivered to the City at any time prior to acceptance by the City. Upon acceptance by the execution hereof, this Purchase Contract shall be in full force and effect in accordance with its terms and shall be binding upon the City and the Underwriter. All capitalized terms used herein and not otherwise defined herein shall have the respective meanings ascribed thereto in the Official Statement (as defined herein). Purchase. Sale and Delivery of the Bonds. (a) Subject to the terms and conditions, and in reliance upon the representations, warranties and agreements set forth herein, the Underwriter agrees to purchase, and the City agrees to sell and deliver to the Underwriter, all (but not less than all) of the $ City of Vernon Water System Revenue Bonds, 2020 Series A (the `Bonds"). The Bonds shall be dated the date of delivery thereof, shall mature on such dates and shall bear interest at such rates, and shall be subject to redemption, all set forth in Schedule 1 attached hereto. Interest on the Bonds shall be payable semiannually on February 1 and August I of each year, commencing [August 1, 2020]. The purchase price for the Bonds shall be $ (consisting of the $ aggregate principal amount of the Bonds [plus/less] $ of original issue [premium/discount], less $ of Underwriter's discount). (b) The Bonds are to be issued pursuant to the City of Vernon Municipal Facilities Revenue Bond Law, constituting Article XI of Chapter 2 of the Vernon City Code, and an Indenture of Trust, dated as of March 1, 2020 (the `Indenture"), by and between the City and [The Bank of New York Mellon Trust Company, N.A.], as trustee (the `"Trustee"), substantially in the form previously submitted to the Underwriter, with only such changes therein as shall be mutually agreed upon by the City and the Underwriter. Proceeds of the Bonds will be used to (i) finance the costs of certain capital improvements to the City's Water System (including by reimbursing the Water System for the prior Error! Uumo m dmvm t prepetty n payment of such costs from the Water Fund), [(ii) fund a deposit to a Debt Service Reserve Fund,] and (iii) pay costs of issuance of the Bonds. The City will undertake, pursuant to a Continuing Disclosure Agreement, dated March , 2020 (the "Continuing Disclosure Agreement"), by and between the City and the Trustee, to provide certain annual financial information and notices of the occurrence of certain events. A form of the Continuing Disclosure Agreement is set forth in the Preliminary Official Statement (defined below) and will also be set forth in the Official Statement (defined below). The Indenture, the Continuing Disclosure Agreement and this Purchase Contract are hereinafter referred to collectively as the "Legal Documents." (c) At 8:00 o'clock A.M., California time, on [March 1, 2020, or at such other time or on such other date as mutually agreed upon by the City and the Underwriter (the "Closing Date"), the City will, subject to the temms and conditions hereof, sell and deliver, or cause to be delivered, the Bonds to the Underwriter, in definitive form, duly executed and authenticated, together with the other documents mentioned herein, and subject to the terns and conditions hereof, the Underwriter will accept such delivery and pay the purchase price of the Bonds as set forth in subparagraph (a) above in immediately available funds (such delivery and payment being herein referred to as the "Closing") to the order of the Trustee. Sale, delivery and payment as aforesaid shall be made at the offices of Stradling Yocca Carlson & Rauth, a Professional Corporation, Newport Beach, California ("Bond Counsel"), or such other place as shall have been mutually agreed upon by the City and the Underwriter, except that the Bonds shall be delivered through the Trustee via the F.A.S.T. delivery book -entry system of The Depository Trost Company ("DTC") in New York, New York, or at such other place as shall have been mutually agreed upon by the City and the Underwriter, in fully registered book -entry eligible form (which may be typewritten) and registered in the name of Cede & Co. as nominee of OTC. 2. Establishment of Issue Price. (a) The Underwriter agrees to make a bona fide public offering of all of the Bonds at prices not in excess of the initial, respective public offering prices or at yields not lower than the initial, respective yields shown or derived from information shown on the inside cover of the Official Statement. [Except as set forth in subsection (d) below,] the Underwriter reserves the right to change such initial offering prices after such offering as it shall deem necessary in connection with the marketing of the Bonds. (b) The Underwriter agrees to assist the City in establishing the issue price of the Bonds and shall execute and deliver to the City at Closing an "issue price" or similar certificate, together with the supporting pricing wires or equivalent communications, substantially in the form attached hereto as Exhibit A, with such modifications as may be appropriate or necessary, in the reasonable judgment of the Underwriter, the City and Bond Counsel, to accurately reflect, as applicable, the sales price or prices or the initial offering price or prices to the public of the Bonds. (c) [Except for the Hold -the -Price Maturities described in subsection (d) below and Schedule 1 attached hereto,] the City will treat the first price at which l0°/p of each maturity of the Bonds (the "10% test') is sold to the public as the issue price of that maturity. Schedule 1 attached hereto sets forth, as of the date of this Purchase Contract, the maturities of the Bonds for which the 10% test has been satisfied (the "10% Test Maturities") and the price m prices at which the Underwriter has sold such 10% Test Maturities to the public. For purposes of this section, if Bonds Error! Unknown document properly vine. mature on the same date but have different interest rates, each separate CUSIP number within that maturity will be treated as a separate maturity of the Bonds. (d) (With respect to the maturities of the Bonds that are not 10% Test Maturities, as described in Schedule 1 attached hereto (the "Hold -the -Price Maturities"), the Underwriter confirms that it has offered such maturities of the Bonds to the public on or before the date of this Purchase Contract at the offering price or prices (the "initial offering price"), or at the corresponding yield or yields, set forth in Schedule I attached hereto. The City and the Underwriter agree that the restrictions set forth in the next sentence shall apply to the Hold -the -Price Maturities, which will allow the City to treat the initial offering price to the public of each such maturity as of the sale date as the issue price of that maturity (the "hold -the -offering -price rule'). So long as the hold -the - offering -price rule remains applicable to any maturity of the Bonds, the Underwriter will neither offer nor sell any portion of such maturity of the Hold -the -Price Maturities to any person at a price that is higher than the initial offering price to the public during the period starting on the sale date and ending on the earlier of the following: (1) the close of the fifth (5th) business day after the sale date; or (2) the date on which the Underwriter has sold at least 10% of that maturity of the Hold -the -Price Maturities to the public at a price that is no higher than the initial offering price to the public. The Underwriter will advise the City promptly after the close of the fifth (5'h) business day after the sale date whether it has sold 10% of that maturity of the Hold -the -Price Maturities to the public at a price that is no higher than the initial offering price to the public.] (e) The Underwriter confirms that: (i) any selling group agreement and each third -party distribution agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer who is a member of the selling group, and each broker -dealer that is a party to such third -party distribution agreement, as applicable, to (A)(i) report the prices at which it sells to the public the unsold Bonds of each maturity allocated to it until it is notified by the Underwriter that either the 101/u test has been satisfied as to the Bonds of that maturity or all Bonds of that maturity have been sold to the public and (ii) comply with the hold-theoffering-price rule, if applicable, in each case if and for so long as directed by the Underwriter and w set forth in the related pricing wires; (B) promptly notify the Underwriter of any sales of the Bonds that, to its knowledge, are made to a purchaser who is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below); and (C) acknowledge that, unless otherwise advised by the dealer or broker -dealer, the Underwriter shall assume that each order submitted by the dealer or broker -dealer is a sale to the public; and (ii) any selling group agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer that is a party to a third -party distribution agreement to be employed in connection with the initial sale of the Bonds to the public to require each broker -dealer that is a party to such third -party distribution agreement to (A) report the prices at which it sells to the public the unsold Bonds of each maturity allotted to it until it is notified by the Underwriter or the dealer that either the 10% test has been satisfied as to the Bonds of that E.! U.b . a.r.tee.t pnprrq ooe. maturity or all Bonds of that maturity have been sold to the public and (B) comply with the hold -the -offering -price mle, if applicable, in each case if and for so long as directed by the Underwriter or the dealer and as set forth in the related pricing wires. (f) The City acknowledges that, in making the representations set forth in this section, the Underwriter will rely on (i) in the event a selling group has been created in connection with the initial sale of the Bonds to the public, the agreement of each dealer who is a member of the selling group to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Bonds, as set forth in the selling group agreement and the related pricing wires, and (ii) in the event that a third -party distribution agreement was employed in connection with the initial sale of the Bonds to the public, the agreement of each broker -dealer that is a party to such agreement to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with hold -the -offering -price rile, if applicable to the Bonds, as set forth in the third -party distribution agreement and the related pricing wires. The City further acknowledges that the Underwriter shall not be liable for the failure of any dealer who is a member of a selling group, or of any broker -dealer that is a party to a third -party distribution agreement, to comply with its corresponding agreement to comply with the requirements for establishing the issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the -offering - price rile, if applicable to the Bonds. (g) The Underwriter acknowledges that sales of any Bonds to any person that is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below) shall not constitute sales to the public for purposes of this section. Further, for purposes of this section: (i) "public" means any person other than an underwriter or a related party; (ii) "underwriter" (when used with a lower case "u") means (A) any person that agrees pursuant to a written contract with the City (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the public and (B) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (A) to participate in the initial sale of the Bonds to the public (including a member of a selling group or a party to a third -party distribution agreement participating in the initial sale of the Bonds to the public); (iii) a purchaser of any of the Bonds is a 'related party" to an underwriter if the underwriter and the purchaser are subject, directly or indirectly, to (A) more than 50% common ownership of the voting power or the total value of their stock, if both entities are corporations (including direct ownership by one corporation of another), (B) more than 50% common ownership of their capital interests or profits interests, if both entities are partnerships (including direct ownership by one partnership of another), or (C) more than 50% common ownership of the value of the outstanding stock of the corporation or the capital interests or profit interests of the partnership, as applicable, if one entity is a corporation and the other entity is a partnership (including direct ownership of the applicable stock or interests by one entity of the other); and (iv) "sale date" means the date of execution of this Purchase Contract by all parties. Urrar! Unknown document property name. 3. Use and Preparation of Official Statement. The City hereby ratifies, confirms and approves of the distribution and use by the Underwriter prior to the date hereof of the preliminary official statement dated , 2020, relating to the Bonds (including all appendices thereto, the "Preliminary Official Statement") and the making available of the Preliminary Official Statement to investors prim to the date hereof. The City has deemed the Preliminary Official Statement final as of the date thereof for purposes of Rule 15c2-12 promulgated under the Securities Exchange Act of 1934 ("Rule 15c2-12"), except for information permitted to be omitted therefrom in accordance with paragraph (b)(1) of Rule 15c2-12. The City hereby acknowledges that the Preliminary Official Statement has been made available to investors in electronic form. The City hereby agrees to deliver or cause to be delivered to the Underwriters, within seven (7) business days of the date hereof and at least in sufficient time to accompany any orders or confirmations that request payment from any customer, copies of the final official statement, dated the date hereof (which, together with all information previously permitted to have been omitted by Rule 15c2-12 and any amendments or supplements to such official statement as have been approved by the City and the Underwriter is referred to herein as the "Official Statement") in sufficient quantity to enable the Underwriter to comply with the riles of the Securities and Exchange Commission and the Municipal Securities Rulemaking Board The City hereby approves of the distribution and use by the Underwriter of the Official Statement in connection with the offer and sale of the Bonds. At the time of or prior to the Closing Date, the Underwriter shall file a copy of the Official Statement in printed or electronic form with, and as permitted by, the Municipal Securities Rulemaking Board through its Electronic Municipal Market Access System. The Underwriter shall advise the City of the date of such filing. 4. Representations Warranties and Ammements of the City. The City represents, warrants and agrees with the Underwriter as follows: (a) The City is, and will be on the Closing Date, duly existing as a chartered city organized under the laws of the State of California (the `State"), and has full legal right, power and authority to cause the Bonds to be authenticated and delivered to execute and deliver the Official Statement and to enter into the Legal Documents and to perform its obligations contained herein and therein, and, when executed and delivered by the other parties thereto, the Legal Documents will constitute the legal, valid and binding obligations of the City enforceable in accordance with their respective terns; (b) By all necessary official action of the City prior to or concurrently with the acceptance hereof, the City has duly approved the distribution of the Preliminary Official Statement and the execution, delivery and distribution of the Official Statement, and has duly authorized and approved the execution and delivery of, and the performance by the City of the obligations on its part contained in, the Legal Documents and the consummation by it of all other transactions contemplated by the Preliminary Official Statement and the Legal Documents; (c) The City is not in breach of or default under any applicable constitutional provision, law or administrative regulation to which it is subject or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or to which the City or any of its property or assets is otherwise subject, and no event has occurred and is continuing which with the passage of time or the giving of notice, or both, would constitute such a default or event of default in any material respect =der any such instrument; and the issuance of the Bonds and the execution and delivery of the Official Statement and the Legal Documents and compliance with the provisions on the City's part contained in the Legal Documents, will not in any material respect conflict with or constitute a breach of or default Error! Uurmowa doeunmat property mme. under any law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject, nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the properties or assets of the City under the temts of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument, except as provided in the Indenture; (it) There is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, governmental agency, public board or body, pending or, to the best knowledge of the City after reasonable investigation, threatened, against the City in any material respect affecting the existence of the City or the titles of its officers to their respective offices or affecting or seeking to prohibit, restrain or enjoin the issuance, sale or delivery of the Bonds or contesting or affecting, as to the City, the validity or enforceability of the Bonds or the Legal Documents or the collection of Net Revenues of the Water System or other amounts pledged or to be pledged to pay the principal of, premium, if any, and interest on the Bonds or contesting the powers of the City or its authority to enter into, adopt or perform its obligations under any of the foregoing, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement, or any amendment or supplement thereto, wherein an unfavorable decision, oiling or finding would likely to result in a material adverse change in the business, properties, assets or financial condition of the Water System or materially adversely affect the validity or enforceability of the Legal Documents; (e) All authorizations, approvals, licenses, permits, consents and orders of any governmental authority, legislative body, board, agency or commission having jurisdiction of the matter which are required for the due authorization by, or which would constitute a condition precedent to or the absence of which would materially adversely affect the due performance by, the City of its obligations in connection with the issuance of the Bonds under the Indenture have been duly obtained, except for such approvals, consents and orders as may be required under the Blue Sky or securities laws of any state in connection with the offering and sale of the Bonds; and, except as described in or contemplated by the Preliminary Official Statement and the Official Statement, all authorizations, approvals, licenses, permits, consents and orders of any governmental authority, board, agency or commission having jurisdiction of the matter which are required for the due authorization by, or which would constitute a condition precedent to or the absence of which would materially adversely affect the due performance by, the City of its obligations under the Legal Documents have been duly obtained; (f) The Bonds, the Legal Documents and the other documents described in the Preliminary Official Statement and the Official Statement conform in all material respects to the descriptions thereof contained in the Preliminary Official Statement and the Official Statement, and the Bonds, when delivered as provided herein, will be validly issued and outstanding obligations of the City entitled to the benefits of the Indenture; (g) The City will famish such information, execute such instruments and take such other action in cooperation with the Underwriter as the Underwriter may reasonably request in order (i) to qualify the Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions of the United States as the Underwriter may designate and (ii) to determine the eligibility of the Bonds for investment under the laws of such states and other jurisdictions, and will use its best efforts to continue such qualification in effect so Error! Uelmoxn document propern onme. long as required for distribution of the Bonds; provided, however, that in no event shall the City be required to take any action which would subject it to service of process in any jurisdiction in which it is not now so subject; (h) As of its date and the date hereof, the Preliminary Official Statement (excluding information concerning DTC and the book -entry system as to which no representation is made) did not, except as to the information permitted to be omitted by Rule 15c2-12, contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; (i) As of the date thereof and at all times subsequent thereto to and including the date which is 25 days following the End of the Underwriting Period (as such tern is hereinafter defined) for the Bonds, the Official Statement (excluding information concerning DTC and the book - entry system as to which no representation is made) did not and will not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; 6) If between the date hereof and the date which is 25 days after the End of the Underwriting Period for the Bonds, an event occurs which might or would cause the information contained in the Official Statement, as then supplemented or amended, to contain an untrue statement of a material fact or to omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, the City will notify the Underwriter, and if in the opinion of the City, the Underwriter or their respective counsel, such event requires the preparation and publication of a supplement or amendment to the Official Statement, the City will forthwith prepare and furnish to the Underwriter (at the expense of the City) a reasonable number of copies of an amendment of or supplement to the Official Statement (in form and substance satisfactory to the Underwriter) which will amend or supplement the Official Statement so that it will not contain an untrue statement of a material fact or omit to state a material fact necessary in order to make the statements therein, in the light of the circumstances existing at the time the Official Statement is delivered to prospective purchasers, not misleading. For the purposes of this subsection, between the date hereof and the date which is 25 days after the End of the Underwriting Period for the Bonds, the City will furnish such information with respect to itself as the Underwriter may from time to time reasonably request; (k) If the information contained in the Official Statement is amended or supplemented pursuant to paragraph 0) of this Section 4, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such paragraph) at all times subsequent thereto up to and including the date which is 25 days after the End of the Underwriting Period for the Bonds, the Official Statement so supplemented or amended (excluding information concerning DTC and the book -entry system as to which no representation is made) will not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; (1) As used herein and for the purposes of the foregoing, the term "End of the Underwriting Period' for the Bonds shall mean the later of (i) the Closing Date, or (ii) the date on which the End of the Underwriting Period for the Bonds has occurred under Rule 15c2-12; provided, however, that the City may treat as the End of the Underwriting Period for the Bonds the date specified as such in a notice from the Underwriter stating the date which is the End of the Underwriting Period; Err . u.dm.. a..+ t proper .se. (m) After the Closing Date, the City will not participate in the issuance of any amendment of or supplement to the Official Statement to which, after being famished with a copy, the Underwriter shall reasonably object in writing; (n) The City will apply, or cause the application of, the proceeds of the Bonds in accordance with the Indenture; (o) As of the time of acceptance hereof and as of the Closing Date, the City does not and will not have outstanding any indebtedness which is secured by a lien on Water System Revenues superior to or on a parity with the lien of the Bonds thereon; (p) Between the date hereof and the Closing Date, except as contemplated by the Preliminary Official Statement and the Official Statement, the City will not have incurred any material liabilities, direct or contingent, payable from Water System Revenues or entered into any material transaction in connection with the Water System in either case other than in the ordinary course of business, and there shall not have been any material adverse change in the financial condition or operations of the Water System; (q) The financial statements of the [Water Fund][and the City] contained as Appendix A to the Preliminary Official Statement and the Official Statement do and will fairly present the financial position and results of operations of the Water System as of the dates and for the periods therein set forth in accordance with the accounting principles described in Appendix A to the Preliminary Official Statement and the Official Statement applied consistently, and there has not been a material adverse change in the business, properties or financial condition of the City or the Water System from that set forth in or contemplated by the Preliminary Official Statement and the Official Statement; (r) The City (i) has all necessary licenses and permits required to carry on and operate all of the facilities, equipment and other property comprising the Water System the lack of which would materially adversely affect the operations or financial condition of the Water System, and (ii) has not received any notice of an alleged violation and, to the best knowledge of the City, the City is not in violation of any zoning, land use or other similar law or regulation applicable to any of its property comprising the Water System that would materially adversely affect its operations or financial condition; (s) Any certificate signed by an authorized officer of the City and delivered to the Underwriter shall be deemed a representation and warranty by the City to the Underwriter as to the statements made therein; and (t) Except as disclosed in the Preliminary Official Statement and the Official Statement, the City has not failed to comply in all material respects with the terms of any continuing disclosure obligation under Rule 15c2-12 within the past five years. 5. Conditions to the Obli¢ations of the Underwriter. The Underwriter hereby enters into this Purchase Contract in reliance upon the representations and warranties of the City contained herein and the representations and warranties of the City to be contained in the documents and instruments to be delivered on or prior to the Closing Date and upon the performance by the City of its obligations both on and as of the date hereof and as of the Closing Date. Accordingly, the Underwriter's obligations under this Purchase Contract to purchase, to accept delivery of and to pay for the Bonds shall be subject, at the option of the Underwriter, to the accuracy in all material Ermr! Uurmoxn document property name. 8 respects of the representations and warranties of the City contained herein as of the date hereof and as of the Closing Date, to the accuracy in all material respects of the statements of the officers and other officials of the City made in any certificate or other document furnished pursuant to the provisions hereof, to the performance by the City of its obligations to be performed hereunder and under such documents and instruments at or prior to the Closing Date, and also shall be subject to the following additional conditions: (a) The City shall have delivered to the Underwriter a letter from [Vasquez & Company LLP ](the "Independent Auditors"), dated the date of the Preliminary Official Statement, in form acceptable to the Underwriter, consenting to the references to such firm and the inclusion of the financial statements of the [Water Fund][and the City] as of and for the year ended June 30, 2019 in the Preliminary Official Statement and the Official Statement, or confirmation from the City in a form satisfactory to the Underwriter that no such consent shall be required under the terms of the City's contract for services of the Independent Auditors; (b) The Underwriter shall receive, within seven (7) business days of the date hereof and at least in sufficient time to accompany any orders or confirmations that request payment from any customer, copies of the Official Statement (including all information previously permitted to have been omitted by Rule 15c2-12 and any amendments or supplements as have been approved by the Underwriter), in such quantity as the Underwriter shall have requested pursuant to Section 3 hereof; (c) The representations and warranties of the City contained herein shall be true and correct on the date hereof and on the Closing Date, as if made on and at the Closing Date; (d) As of the Closing Date, the Legal Documents shall have been duly authorized, executed and delivered by the respective parties thereto, and the Official Statement shall have been duly authorized, executed and delivered by the City, all in substantially the forms heretofore submitted to the Underwriter, with only such changes as shall have been agreed to in writing by the Underwriter, and such Legal Documents shall be in full force and effect and shall not have been amended, modified or supplemented and the Official Statement shall not have been supplemented or amended, except in any such case as may have been agreed to by the Underwriter; and there shall be in full force and effect such resolution or resolutions of the City Council of the City as, in the opinion of Bond Counsel, shall be necessary or appropriate in connection with the transactions contemplated hereby; (e) Between the date hereof and the Closing Date, the Underwriter may terminate this Purchase Contract (evidenced by a written notice to the City terminating the obligation of the Underwriter to accept delivery of and make any payment for the Bonds) if, in the reasonable judgment of the Underwriter, any of the following shall occur. (1) an amendment to the Constitution of the United States or the State of California shall have been passed or legislation shall have been introduced in or enacted by the Congress of the United States or the legislature of any state having jurisdiction of the subject matter or legislation pending in the Congress of the United States shall have been amended or legislation shall have been recommended to the Congress of the United States or to any state having jurisdiction of the subject matter or otherwise endorsed for passage (by press release, other form of notice or otherwise) by the President of the United States, the Treasury Department of the United States, the Internal Revenue Service or the Chairman or ranking minority member of the Committee on Finance of the United States Senate or the Ermr!Unknew aoenmmt properly rime. Committee on Ways and Means of the United States House of Representatives, or legislation shall have been proposed for consideration by either such Committee by any member thereof or presented as an option for consideration by either such Committee by the staff of such Committee or by the staff of the Joint Committee on Taxation of the Congress of the United States, or legislation shall have been favorably reported for passage to either House of the Congress of the United States by a Committee of such House to which such legislation has been referred for consideration, or a decision shall have been rendered by a court of the United States or of the State of California or the Tax Court of the United States, or a ruling shall have been made or a regulation or temporary regulation shall have been proposed or made or any other release or announcement shall have been made by the Treasury Department of the United States, the Internal Revenue Service or other federal or State of California authority, with respect to federal or State of California taxation upon revenues or other income of the general character to be derived by the City or upon interest received on obligations of the general character of the Bonds which may have the purpose or effect, directly or indirectly, of affecting the tax status of the City, its property or income, its securities (including the Bonds) or the interest thereon, or (with respect to the Bonds) any tax exemption granted or authorized by State of California legislation which materially adversely affects the market price or marketability of the Bonds or the ability of the Underwriter to enforce contracts for the sale, at the contemplated offering prices (or yields) of the Bonds; (2) legislation enacted, introduced in the Congress or recommended for passage by the President of the United States, or a decision rendered by a court of the United States, or an order, ruling, regulation (final, temporary or proposed) or official statement issued or made by or on behalf of the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter shall have been made or issued to the effect that obligations of the general character of the Bonds, or the Bonds, including any or all underlying arrangements, are not exempt from registration under the Securities Act of 1933, as amended, or that the Indenture is not exempt from qualification under the Trust Indenture Act of 1939, as amended; (3) any of the following shall have occurred (i) the outbreak or escalation in military hostilities or declaration by the United States of a national or international emergency or war, (ii) the sovereign debt rating of the United States is downgraded by any major credit rating agency or a payment default occurs on United States Treasury Obligation, (iii) a default with respect to the debt obligations of, or the institution of proceedings under any federal bankruptcy laws by or against, any state of the United States or any city, county or political subdivision located in the United States having a population of over 500,000, or (iv) a major financial crisis or any other calamity or crisis the effect of any of which on the financial markets is such as to make it impracticable or inadvisable to proceed with the offering or delivery of the Bonds as contemplated hereby or by the Official Statement; (4) the general suspension of trading on the New York Stock Exchange or other major securities exchange shall be in force, or minimum or maximum prices for trading shall have been fixed and be in force, or maximum ranges for prices for securities shall have been required and be in force on any such exchange, whether by virtue of determination by that exchange or by order of the Securities Exchange Commission or any other governmental authority having jurisdiction, which materially adversely affects the market price or marketability of the Bonds or the ability of the Underwriter to enforce contracts for the sale, at the contemplated offering prices (or yields) of the Bonds; Error! Unhvown dacumem prnpern name. 10 (5) the declaration of a general banking moratorium by federal, New York or California authorities, or the imposition by the New York Stock Exchange or other national securities exchange, or any governmental authority having jurisdiction of the subject matter, of any material restrictions not now in force with respect to the Bonds or obligations of the general character of the Bonds or securities generally, or the material increase of any such restrictions now in force, including those relating to the extension of credit by, or the charge to the net capital requirements of, the Underwriter, or a material disruption in commercial banking or securities settlement or clearances services shall have occurred; (6) an order, decree or injunction of any court of competent jurisdiction, or order, ruling, regulation or official statement by the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter, issued or made to the effect that the issuance, offering or sale of obligations of the general character of the Bonds, or the issuance, offering or sale of the Bonds, including any or all underlying obligations, as contemplated hereby or by the Official Statement, is or would be in violation of the federal securities laws as amended and then in effect; (7) except as disclosed in or contemplated by the Official Statement, any material adverse change in the business, properties, assets or financial condition of the Water System of the City; (8) the suspension, withdrawal or downgrading of any rating of the Bonds or any other outstanding debt of the City's Water System by any rating agency then rating such Bonds or other outstanding debt of the City's Water System, or any official action by any rating agency then rating the Bonds to place the Bonds on "Credit Watch" for possible downgrade or on "Negative Outlook" after the date hereof (and provided that the Bonds were not on "Credit Watch" or "Negative Outlook" prior to the date hereof); or (9) an event shall occur or circumstance shall exist or any information shall become known which makes untrue or incorrect in any material respect at the time of such event or circumstance or information becoming known any statement or information contained in the Official Statement, or has the effect that the Official Statement contains any untrue statement of material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading and, in any such case, (a) the City refuses to permit the Official Statement to be supplemented to supply such statement or information or (b) the effect of the Official Statement as so supplemented is, in the reasonable judgment of the Underwriter, to materially adversely affect the market price or marketability of the Bonds or the ability of the Underwriter to enforce contracts for the sale, at the contemplated offering prices (or yields) of the Bonds; (f) At or prior to the Closing, the Underwriter shall receive the following documents, in each case satisfactory in form and substance to the Underwriter and Underwriter's Counsel: (1) the unqualified approving opinion of Bond Counsel, dated the Closing Date and addressed to the City, substantially in the form attached as Appendix C to the Official Statement; Error! Uoimoein document property name. I l (2) a supplemental opinion of Bond Counsel, dated the Closing Date and addressed to the Underwriter, substantially in the form attached hereto as Exhibit B; (3) a letter, dated the Closing Date and addressed to the Underwriter, of Stradling Yocca Carlson & Rauth, a Professional Corporation, Disclosure Counsel to the City, in substantially the form attached hereto as Exhibit C; (4) an opinion of the City Attorney or other counsel to the City acceptable to the Underwriter, dated the Closing Date and addressed to the Underwriter, substantially in the form attached hereto as Exhibit D: (5) an opinion of counsel to the Trustee, dated the Closing Date and addressed to the City and the Underwriter, to the effect that: (i) the Trustee is a national banking association duly organized and validly existing under the laws of the United States of America; (ii) the Trustee is duly eligible and qualified to act as Trustee under the Indenture and as Dissemination Agent under the Continuing Disclosure Agreement; (ui) the Trustee has all requisite power, authority and legal right to execute and deliver the Indenture and the Continuing Disclosure Agreement and to perform its obligations under such documents; (iv) the Trustee has duly authenticated the Bonds; and (v) the Trustee has duly executed and delivered the Indenture and the Continuing Disclosure Agreement and assuming that such documents constitute the legal, valid and binding agreements of the other respective parties thereto, such documents are the legal, valid and binding agreements of the Trustee, enforceable in accordance with their terms, except to the extent enforceability thereof may be subject to (a) bankmptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws affecting creditors' rights and remedies heretofore or hereafter enacted, and (b) the application of equitable principles and the exercise of judicial discretion in appropriate cases; (6) an opinion of Norton Rose Fulbright US LLP, Underwriter's Counsel, dated the Closing Date and addressed to the Underwriter, to the effect that (i) the Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Indenture is exempt from qualification under the Trust Indenture Act of 1939, as amended; (ii) assuming the due authorization, execution and delivery of the Continuing Disclosure Agreement by the City and the Trustee and the enforceability thereof, the Continuing Disclosure Agreement is in a form which satisfies the requirements of section (b)(5)(i) of Rule 15c2-12 of the Securities Exchange Act of 1934, as amended; and (iii) on the basis of the information made available to such firm in the course of acting as counsel to the Underwriter (but without having undertaken to determine or verify independently, or assuming any responsibility for, the accuracy, completeness or fairness of any of the statements contained in the Preliminary Official Statement or the Official Statement), no facts have come to the attention of the personnel in such firm directly involved in rendering legal advice and assistance to the Underwriter in connection with the preparation of the Preliminary Official Statement and the Official Statement that cause them to believe that (a) the Preliminary Official Statement as of its date or as of the date of this Purchase Contract (excluding therefrom financial, demographic and statistical data; forecasts, projections, estimates, assumptions and expressions of opinions; statements relating to DTC, Cede & Co. and the operation of the book -entry system; statements relating to the treatment of the Bonds or the interest, discount or premium, if any, thereon or therefrom for tax purposes under the law of any jurisdiction; and the statements contained in the Preliminary Official Statement Error! Un" an document proper, name. 12 under the captions "TAX MATTERS,' and in the Appendices to the Preliminary Official Statement; as to all of which they express no view) contained any untrue statement of a material fact or omitted to state a material fact necessary in order to make the statements made therein, in the light of the circumstances under which they were made, not misleading, except for such information as is permitted to be excluded from the Preliminary Official Statement pursuant to Rule 15c2-12 of the Securities Exchange Act of 1934, as amended, including but not limited to information as to pricing, yields, interest rates, maturities, amortization, redemption provisions, debt service requirements, Underwriter's discount and CUSIP numbers or (b) the Official Statement as of its date or as of the Closing Date (excluding therefrom financial, demographic and statistical data; forecasts, projections, estimates, assumptions and expressions of opinions; statements relating to DTC, Cede & Co. and the operation of the book -entry system; statements relating to the treatment of the Bonds or the interest, discount or premium, if any, thereon or therefrom for tax purposes under the law of any jurisdiction; and the statements contained in the Official Statement under the captions "TAX MATTERS," and in the Appendices to the Official Statement; as to all of which they express no view) contained any untrue statement of a material fact or omitted to state a material fact necessary in order to make the statements made therein, in the light of the circumstances under which they were made, not misleading; (7) a certificate or certificates, dated the Closing Date, of the City executed by its City Administrator or other appropriate official, to the effect that (i) the representations and warranties of the City in this Purchase Contract are true and correct on and as of the Closing Date as if made on and as of the Closing Date, and the City has complied with and performed all of its covenants and agreements in this Purchase Contract on its part to be complied with and performed at or prior to the Closing; (ii) since June 30, 2019, except as referred to in or as contemplated by the Preliminary Official Statement and the Official Statement, with respect to its Water System, the City has not incurred any financial liabilities, direct or contingent, or entered into any transactions and there has not been any adverse change in the condition, financial or physical, of the Water System, in any case that would materially and adversely affect the ability of the City to meet its obligations under the Indenture; (iii) other than as described in the Preliminary Official Statement and the Official Statement, there is no action, suit, proceeding, inquiry or investigation pending or, to the best knowledge of such official, threatened (a) in any way questioning the corporate existence of the City or the titles of the officers of the City to their respective offices; (b) seeking to restrain or enjoin the delivery of the Bonds, or the collection of Net Revenues of the Water System or other amounts pledged to pay the principal of, premium, if any, and interest on such Bonds or the pledge thereof; (c) in any way contesting or affecting the validity of the Bonds or the Legal Documents; (d) in any way contesting the powers of the City or any authority for the issuance and delivery of the Bonds and the performance of its obligations contained therein or the execution and delivery of the Legal Documents and the performance of its obligations contained therein, nor to the best knowledge of such official after reasonable investigation, is there any basis for any such action, suit, proceeding, inquiry or investigation, wherein an unfavorable decision, ruling or finding would make invalid or materially adversely affect the authorization, execution, delivery or performance by the City of the foregoing; (e) which would be likely to result in a material adverse change in the business, properties, assets or the financial condition of the Water System or which would be likely to have a material adverse effect on the ability of the City to meet its obligations under the Indenture; or (f) asserting that the Preliminary Official Statement or the Official Statement contained any untrue statement of a material fact or omitted to state any material error!Uuw a«. tprpenr..mr. 13 fact necessary to make the statements made therein, in the light of the circumstances under which they were made, not misleading, which certificate shall be in form and substance acceptable to the Underwriter (but in lieu of such certificate, the Underwriter may in its sole discretion accept an opinion of Bond Counsel or other counsel to the City, acceptable to the Underwriter in form and substance, that in their opinion the issues raised in any such pending or threatened litigation are without substance or that the contentions of any plaintiffs therein are without merit); (8) a certificate, dated the Closing Date, signed by a duly authorized official of the Trustee, satisfactory in form and substance to the Underwriter, to the effect that: (i) the Trustee is a national banking association organized and existing under and by virtue of the laws of the United States of America, having the full power and being qualified to enter into and perform its duties under the Indenture and the Continuing Disclosure Agreement; (ii) the Trustee is duly authorized to enter into the Indenture and the Continuing Disclosure Agreement and to authenticate and deliver the Bonds to the Underwriter pursuant to the terms of the Indenture; (iii) the execution and delivery of the Indenture and the Continuing Disclosure Agreement and compliance with the provisions on the Trustee's part contained therein, and the authentication and delivery of the Bonds will not conflict with or constitute a breach of or default under any law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Trustee is a party or is otherwise subject (except that no representation, warranty or agreement is made with respect to any federal or state securities or Blue Sky laws or regulations), nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the properties or assets held by the Trustee pursuant to the lien created by the Indenture under the terms of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument, except as provided by the Indenture; and (iv) there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, governmental agency, public board or body, served on, or, to the best knowledge of such officer, threatened against, the Trustee, affecting the existence of the Trustee or the titles of its officers to their respective offices, or in any way contesting or affecting the validity or enforceability of the Indenture against the Trustee, or contesting the power of the Trustee or its authority to enter into, adopt or perform its obligations under the Indenture, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Indenture against the Trustee or the authentication and delivery of the Bonds; (9) a certified copy of the general resolution of the Trustee authorizing the execution and delivery of the Indenture and the Continuing Disclosure Agreement; (10) the Official Statement and each supplement or amendment, if any, thereto, executed by the City; (11) copies of each of the Legal Documents, each duly executed and delivered by the respective parties thereto; (12) certified copies of all proceedings relating to the authorization and issuance of the Bonds certified by the City Clerk or other appropriate official of the City; Error! l nimman document property nvme. 14 (13) tax certifications by the City in form and substance acceptable to Bond Counsel; (14) evidence that a federal tax information form 8038-G has been prepared for filing with respect to the Bonds. (15) evidence that the rating on the Bonds of "_" from [S&P Global Ratings) is in full force and effect as of the Closing Date; (16) the DTC Blanket Issuer Letter of Representations of the City; (17) a copy of any Blue Sky Memorandum with respect to the Bonds, prepared by Counsel to the Underwriter; (I8) a copy of the Notice of Final Sale required to be delivered to the California Debt and Investment Advisory Commission pursuant to Section 8855 of the California Government Code; (19) evidence of the City's compliance with the requirements of Section 8855(i) of the California Government Code; and (20) such additional certificates, instruments and other documents as the Underwriter, Underwriter's Counsel or Bond Counsel may reasonably deem necessary to evidence the truth and accuracy as of the Closing Date of the City's representations and warranties contained in this Purchase Contract and the due performance or satisfaction by the City at or prior to such time of all agreements then to be performed and all conditions then to be satisfied by the City pursuant to this Purchase Contract. If the City shall be unable to satisfy the conditions to the obligations of the Underwriter to purchase, accept delivery of and pay for the Bonds contained in this Purchase Contract or if the obligations of the Underwriter to purchase, accept delivery of and pay for the Bonds shall be subject to termination by the Underwriter for any reason permitted by this Purchase Contract, this Purchase Contract and all obligations of the Underwriter hereunder may, at the option of the Underwriter, be terminated by the Underwriter at, or at any time prior to, the Closing Date by written notice to the City, and upon any such termination, neither the Underwriter nor the City shall have any further obligations hereunder. Expenses. (a) The Underwriter shall be under no obligation to pay, and the City shall pay, any expenses incident to the performance of the City's obligations hereunder including, but not limited to: (i) the cost of preparation, printing and distribution of the Legal Documents, the Preliminary Official Statement, the Official Statement and any supplements or amendments thereto, including a reasonable number of certified or conformed copies thereof, (ii) the cost of preparation and printing of the Bonds; (iii) the fees and disbursements of Bond Counsel and Disclosure Counsel; (iv) the fees and disbursements of the City's financial advisor and any engineers, accountants and other experts, consultants or other advisors retained by the City; (v) fees for bond ratings (which include fees of rating agencies and travel expenses of the City); and (vi) all expenses incurred on behalf of City personnel with respect to the financing, including (a) air travel and hotel costs in connection with the pricing of the Bonds, any investor meetings, any rating agency trips and the Error! UaRoowa doeameat property came. 15 Closing, (b) meals and transportation for City personnel during such trips, (c) expenses of City personnel related to attending working group meetings, such as parking, meals and transportation, and (d) any other miscellaneous costs related to the Closing. (b) The Underwriter shall pay: (i) the cost of preparation and printing of this Purchase Contract and the Preliminary Blue Sky Memorandum; (ii) all advertising expenses and Blue Sky filing fees in connection with the public offering of the Bonds; (iii) fees, if any, payable to the California Debt and Investment Advisory Commission, the Municipal Securities Rulemaking Board and DTC; and (iv) all other expenses (including travel and other out-of-pocket expenses) incurred by them in connection with the public offering of the Bonds and the transactions contemplated by this Purchase Contract not outlined in (a) above, including the fees and disbursements of Underwriter's Counsel. The City acknowledges and agrees that some or all of the expenses (including all normally occurring out-of-pocket expenses) to be paid by the Underwriter may be included as part of the expense component of the Underwriter's discount or may be reimbursed to the Underwriter as out- of-pocket expenses. 7. Notices. Any notice or other communication to be given to the City under this Purchase Contract may be given by delivering the same in writing to: City of Vernon, 4305 South Santa Fe Avenue, Vernon, California 90058, Attention: City Administrator; and any notice or other communication to be given to the Underwriter under this Purchase Contract may be given by delivering the same in writing to the Underwriter: J.P. Morgan Securities LLC, 560 Mission Street, Floor Three, San Francisco, CA 94105, Attention: Will Frymann. 8. Survival of Representations and Warranties The City's representations, warranties and agreements contained in this Purchase Contract or made in any certificate delivered hereunder shall remain operative and in full force and effect, regardless of. (i) any investigations or statements made by or on behalf of the Underwriter; and (ii) delivery of and payment for the Bonds pursuant to this Purchase Contract. 9. No Fiduciary. The City acknowledges and agrees that (i) the purchase and sale of the Bonds pursuant to this Purchase Contract is an arm's-length commercial transaction between the City and the Underwriter in which the Underwriter is acting solely as a principal and is not acting as the agent, fiduciary, financial advisor or municipal advisor of the City, (ii) the Underwriter has not assumed an advisory or fiduciary responsibility in favor of the City with respect to the offering contemplated hereby or the discussions, undertakings and procedures leading thereto (irrespective of whether the Underwriter has provided other services or is currently providing other services to the City on other matters); (iii) the Underwriter has no obligation to the City with respect to the offering contemplated hereby except the obligations expressly set forth in this Purchase Contract; (iv) the Underwriter has financial and other interests that differ from those of the City; and (iv) the City has consulted with its own legal, accounting, tax, financial and other advisors to the extent it deemed appropriate. 10. Governing Law. This Purchase Contract shall be construed in accordance with and governed by the Constitution and laws of the State of California applicable to contracts made and performed in the State. 11. Counterpart Signatures. This Purchase Contract may be executed in several counterparts, each of which shall be an original, and all of which shall constitute but one and the same instrument. Errror! V.kmwv d.a..w vr.pul, n.m 16 12. Parties in Interest. This Purchase Contract, when accepted by the City in writing as heretofore specified, shall constitute the entire agreement between the City and the Underwriter in connection with the subject matter hereof and is made solely for the benefit of the City and the Underwriter (including any successor in business of the Underwriter). No other person shall acquire or have any right hereunder or by virtue hereof. Very truly yours, J.P. MORGAN SECURITIES LLC By: Authorized Representative Accepted on , 2020 CITY OF VERNON By: City Administrator ATTEST: 1Iy: City Clerk SCHEDULE I CITY OF VERNON Water System Revenue Bonds, 2020 Series A MATURITY SCHEDULE Maturity Date Principal Interest 10%Test (August 1) Amount Rate Yield Price Used REDEMPTION PROVISIONS Hold -the - Offering Price Rule Used [Optional Redemption. The Bonds with stated maturities on or after August 1, 20_, are subject to redemption prior to their respective stated maturities, as a whole or in part on _ 1, 20 , or any date thereafter, as directed by the City in a Written Request provided to the Trustee at least 35 days (m such lesser number of days acceptable to the Trustee in the sole discretion of the Trustee, such notice for the convenience of the Trustee) and by lot within each maturity in integral multiples of $5,000, at a Redemption Price equal to the principal amount thereof plus accrued interest thereon to the Redemption Date, without premium Mandatory Sinking Fund Redemption. The Bonds maturing on August 1, 20 (the "Term Bond) with stated maturities on August I, 20_ are subject to mandatory sinking find redemption in part (by lot) on August 1, 20_ and each August I thereafter, in integral multiples of $5,000 at a Redemption Price of the principal amount thereof plus accrued interest to the date fixed for redemption, without premium, in accordance with the following schedule: rrrod rnino.n document proper. name. Sch. 1, Page I Redemption Date Principal (August I) Amount Mamnly] error! uomowa aosawm prap.rry oaaK. Sch. I, Page 2 EXHIBIT A FORM OF ISSUE PRICE CERTIFICATE S CITY OF VERNON Water System Revenue Bonds, 2020 Series A The undersigned, J.P. Morgan Securities LLC, as underwriter ("J.P. Morgan"), hereby certifies as set forth below with respect to the sale and issuance of the above -captioned obligations (the "Bonds") of the City of Vernon, California (the "Issuer"). 1. Sale of the General Rule Maturities. As of the date of this certificate, for each Maturity of the General Rule Maturities, the first price at which at least 10% of such Maturity was sold to the Public is the respective price listed in Schedule 1. 2. Initial Offering Price of the Hold -the -Offering -Price Maturities. (a) J.P. Morgan has offered the Hold -the -Offering -Price Maturities to the Public for purchase at the respective initial offering prices listed in Schedule I (the "Initial Offering Prices") on or before the Sale Date. A copy of the pricing wire or equivalent communication for the Bonds is attached to this certificate as Schedule 2. (b) As set forth in the Contract of Purchase dated , 2020 (the "Purchase Contract"), between J.P. Morgan and the Issuer, J.P. Morgan agreed in writing on or prior to the Sale Date that, (i) for each Maturity of the Hold -the -Offering -Price Maturities, it would neither offer nor sell any of the Bonds of such Maturity to any person at a price that is higher than the britial Offering Price for such Maturity during the Holding Period for such Maturity (the "hold-theoffering-price rule"), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any third -party distribution agreement shall contain the agreement of each broker -dealer who is a party to the third -party distribution agreement, to comply with the hold -the -offering -price rule. Pursuant to such agreement, J.P. Morgan has not offered or sold any of its Allotted Portion of unsold Bonds of any Maturity of the Hold -the -Offering -Price Maturities at a price that is higher than the respective Initial Offering Price for that Maturity of the Bonds during the Holding Period. 3. Defined Terms. (a) Allotted Portion means that portion of a Maturity of the Hold -the -Offering Price Maturities that was retained by or allotted to J.P. Morgan, as identified in Schedule 1. (b) General Rule Maturities means those Maturities of the Bonds listed in Schedule I hereto as the "General Rule Maturities." (c) Hold -the -Offering -Price Maturities means those Maturities of the Bonds listed in Schedule 1 hereto as the "Hold -the -Offering -Price Maturities" Fx... 7 t k..— d--.1 p ,-t, n me. A-1 (d) Holding Period means, with respect to a Hold -the -Offering -Price Maturity, the period starting on the Sale Date and ending on the earlier of (i) the close of the fifth business day after the Sale Date, or (ii) the date on which the Underwriter sold at least 10% of such Hold -the -Offering - Price Maturity to the Public at prices that are no higher than the Initial Offering Price for such Hold - the -Offering -Price Maturity. (e) Maturity means Bonds with the same credit and payment terms. Bonds with different maturity dates, or Bonds with the same maturity date but different stated interest rates, are treated as separate maturities. (t) Public means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter. The term `related party" for purposes of this certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. (g) Sale Date means the first day on which there is a binding contract in writing for the sale of a Maturity of the Bonds. The Sale Date of the Bonds is _, 2020. (h) Underwriter means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Bonds to the Public (including a member of a selling group or a party to a third -party distribution agreement participating in the initial sale of the Bonds to the Public). The representations set forth in this certificate are limited to factual matters only. Nothing in this certificate represents the undersigned's interpretation of any laws, including specifically Sections I03 and 148 of the Internal Revenue Code of 1986, as amended and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the Tax Certificate with respect to the Bonds and with respect to compliance with the federal income tax rules affecting the Bonds, and by Stradling Yocca Carlson & Rauth, a Professional Corporation, in connection with rendering its opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other federal income tax advice that it may give to the Issuer from time to time relating to the Bonds. IN WITNESS WHEREOF, the undersigned has executed this certificate on this _'t day of , 2020. J.P. MORGAN SECURITIES LLC By: _ Name: Title: [Note: if any selling group members, add separate certification form for members of selling group] Error! Untie decant pnperty se A-2 SCHEDULEI SALE PRICES OF THE GENERAL RULE MATURITIES AND INITIAL OFFERING PRICES OF THE HOLD -THE OFFERING -PRICE MATURITIES (Attached) Frrnr! Cnknown document prupern name. A-1 SCHEDULE2 PRICING WIRE OR EQUIVALENT (Auwhed) EmN U.0 �pmperq. A4 FORM OF SUPPLEMENTAL OPINION OF BOND COUNSEL [Closing Date] J.P. MORGAN SECURITIES LLC, as Underwriter San Francisco, California Re: $ City of Vernon Water System Revenue Bonds, 2020 Series A Ladies and Gentlemen We have acted as bond counsel in connection with the issuance of the above -referenced bonds (the "Bonds"). The Bonds have been issued pursuant to the City of Vernon Municipal Facilities Revenue Bond Law, constituting Article XI of the Vernon City Code, and an Indenture of Trust, dated as of _ 1, 2020 (the "Indenture"), by and between the City and The Bank of New York Mellon Trust Company, N.A. (the "Trustee'). Capitalized terms used herein and not defined shall have the meanings given to such terns in the Contract of Purchase, dated _ _, 2020 (the "Purchase Contmct" ), by and between the City and J.P. Morgan Securities LLC, as underwriter (the "Underwriter"). On the date hereof, we delivered to the City our opinion relating to, among other things, the validity of the Bonds (the "Approving Opinion"). You are authorized to rely upon the Approving Opinion as if addressed to you. Based upon the foregoing and our review of such other information, documents and matters of law as we considered necessary and in reliance on the foregoing, as appropriate, we are of the opinion that: (i) The Purchase Contract and the Continuing Disclosure Agreement have each been duly executed and delivered by the City and each of the Purchase Contract and the Continuing Disclosure Agreement is a valid and binding agreement of the City. No opinion regarding the adequacy of the Continuing Disclosure Agreement for purposes of S.E.C. Rule 15c2-12 may be inferred from this opinion. (ii) The statements contained in the Official Statement under the captions "INTRODUCTION," `THE 2020 BONDS," "SECURITY FOR THE 2020 BONDS" and "TAX MATTERS," and in Appendices B and C, insofar as such statements purport to summarize certain provisions of the Bonds and the Indenture and our opinion with respect to certain federal and state income tax matters related to the Bonds, are accurate in all material respects; and (iii) The Bonds are exempt from registration pursuant to the Securities Act of 1933, as amended, and the Indenture is exempt from qualification pursuant to the Tmst Indenture Act of 1939, as amended. arm! U."mn . earum.m B-1 The opinions that are expressed herein are based upon our analysis and interpretation of existing laws, regulations, rulings and judicial decisions and cover certain matters not directly addressed by such authorities. This opinion is limited to matters governed by the laws of California and federal securities laws, and we assume no responsibility with respect to the applicability or the effect of the laws of any other jurisdiction. We call attention to the fact that the rights and obligations under the Purchase Contract, the Indenture, the Continuing Disclosure Agreement and the Bonds are subject to banlwptcy, insolvency, reorganization, moratorium, fraudulent conveyance or transfer and other similar laws affecting creditors' rights, to the application of equitable principles if equitable remedies are sought, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against public agencies in the State of California. This letter is limited to matters governed by the laws of the State of California and federal securities laws, and we assume no responsibility with respect to the applicability or the effect of the laws of any otherjurisdiction. Except as expressly set forth in the Approving Opinion, we express no opinion regarding any tax consequences with respect to the Bonds. No opinion is expressed herein with respect to the compliance with, or applicability of, any "blue sky" laws of any state as they relate to the offer or sale of the Bonds. The Underwriter has been represented in connection with the purchase of the Bonds by its counsel. No attomeyclient relationship has existed or exists between the Underwriter and our firm in connection therewith or by virtue of this letter. This letter is delivered to you as the Underwriter of the Bonds, is solely for your benefit as such, and is not to be used, circulated, quoted or otherwise referred to or relied to or relied upon for any other purpose or by any other person without our prior written consent. Respectfully submitted, Error' ea"o.a document propem name. B-2 Ail�r 1'�Yl�al FORM OF LETTER OF DISCLOSURE COUNSEL [Closing Date] J.P. MORGAN SECURITIES LLC, as Underwriter San Francisco, California Re: $_ City of Vernon Water System Revenue Bonds, 2020 Series A Ladies and Gentlemen We have acted as disclosure counsel for the City of Vernon (the "City") in connection with the issuance of the above -referenced bonds (the "Bonds"). The Bonds are being purchased by you, as underwriter of the Bonds pursuant to the terms of a Contract of Purchase (the "Purchase Contract"), dated _ _, 2020, by and between the City and you. All capitalized terms that are used herein and not defined have the meanings that are ascribed thereto in the Purchase Contract. In rendering the advice contained herein, we have examined originals or copies certified or otherwise identified to our satisfaction of (i) the Preliminary Official Statement, dated _, 2020 (the "POS") and the Official Statement, dated _ _, 2020 (the "Official Statement'), each relating to the Bonds; and (ii) the letters, certificates, and opinions that were delivered to you in connection with the sale of the Bonds. We have not reviewed, and we do not assume any responsibility for any electronic version of the Official Statement and for all purposes of this letter, we have assumed that any electronic version of the Official Statement conforms in all respects to the printed version of the Official Statement. The conclusions that are expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such conclusions may he affected by actions taken or omitted or events occurring after the date hereof. We have not undertaken to determine, or to inform you or any other person, whether any such actions are taken or omitted or whether such events do occur or any other matters come to our attention after the date hereof. We have assumed, but not independently verified, that the signatures on all documents, letters, opinions and certificates which we have examined are genuine, that all documents submitted to us are authentic and were duly and properly executed by the parries thereto and that all representations that have been made in the documents that we have reviewed are true and accurate. We have assumed, without independent verification, the accuracy of the factual matters that are represented, warranted or certified in the documents, and of the legal conclusions contained in any opinions referenced in the Official Statement. By delivering this letter, we are not expressing any opinion with respect to any indemnification, contribution, liquidated damages, penalty (including any remedy deemed to constitute a penalty), right of set-off, arbitration, judicial reference, choice of law, choice of forum, choice of venue, non -exclusivity of remedies, waiver or severability provisions contained in any Error!Uvk eo ducumem'-partyn me. C-1 document referenced in the Official Statement, nor are we expressing any opinion with respect to the state or quality of title to or interest in any assets described in or as subject to the lien of the Indenture or the accuracy or sufficiency of the description contained therein of, or the remedies available to enforce liens on any assets thereunder. Our services as disclosure counsel to the City did not involve the rendering of financial or other non -legal advice to you, the City or any other party to the transaction. Although we have not undertaken to determine independently or verify and are not passing upon and do not assume responsibility for, the accuracy, completeness or fairness of the statements contained in the POS or the Official Statement, and are therefore unable to make any representation to you in that regard, we have participated in conferences prior to the respective dates of the POS and the Official Statement with representatives of the City, including the City Attorney, the City's municipal advisor, BLX Group, JP Morgan Securities LLC and its counsel Norton Rose Fulbright US LLP, and others, during which conferences the contents of the POS and the Official Statement and related matters were discussed. Based upon the information made available to us in the course of our participation in such conferences as disclosure counsel to the City, our review of the documents referred to above, our reliance on the oral and written statements of the representatives of the City and others, the documents, certificates, instructions and records and the opinions of counsel described above and our understanding of applicable law, and subject to the limitations on our role as disclosure counsel to the City, we advise you as a matter of fact but not opinion that no information has come to the attention of the attorneys in the firm performing services for the City as disclosure counsel on this matter which caused us to believe that the POS or the Official Statement as of their respective dates contained, or as of the date hereof contain, any untrue statement of a material fact, or as of their respective dates omitted, or as of the date hereof omit, to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading in any material respect (except that we express no view with respect to: (i) the expressions of opinion, the assumptions, the projections, estimates and forecasts, the charts, the financial statements or other financial, numerical, economic, demographic or statistical data, or assessed valuations contained in the POS and the Official Statement; (ii) any CUSIP numbers or information relating thereto; (iii) any information with respect to The Depository Trust Company and its book -entry system; (iv) any information contained in the appendices to the Official Statement; (v) any information incorporated by reference into the POS and the Official Statement; (vi) the City's compliance with its obligations to provide notice of the events described in part (b)(5)(i)(C) of Rule 15c2-12 promulgated under the Securities Act of 1934 ("Rule 15c2-12") or to file annual reports described in part (b)(5)(i)(A) of Rule 15c2-12, review of which matters we understand has been undertaken you; (vii) any information with respect to the underwriter or underwriting matters with respect to the Bonds, including but not limited to information under the caption "UNDERWRITING"; and (viii) any information with respect to the ratings on the Bonds and the rating agency referenced therein, including but not limited to information under the caption "RATING"). Finally, we advise you that, other than reviewing the various certificates and opinions which are referenced above, we have not taken any steps since the date of the Official Statement to verify the accuracy of the statements that are contained in the POS or the Official Statement as of the date hereof. No responsibility is undertaken or opinion rendered with respect to any other disclosure document, materials or activity, or as to any information from another document or source that is referred to by, or incorporated by reference in, the POS or the Official Statement. By acceptance of this letter you recognize and acknowledge that: (i) the negative assurance above is not an opinion and is based on certain limited activities performed by specific attorneys in our firm in our role as disclosure counsel to the City; (ii) the scope of the activities performed by Emr. Umlea an document prop" name. C-2 such attorneys in our role as disclosure counsel to the City and for purposes of delivering such negative assurances were inherently limited and do not purport to encompass all activities necessary for compliance by you or others in accordance with applicable state and federal securities laws; and (iii) the activities performed by such attorneys in our role as disclosure counsel to the City rely in part by representations, warranties, certifications and opinions of other parties to the transaction, including representations, warranties and certifications made by the City. This letter is being famished to you solely for you benefit in connection with your purchase of the Bonds and is not to be used, circulated, quoted or otherwise referred to for any other purpose without our prior written consent. We note that you were represented by separate counsel that was retained by you in connection with the transaction described in the Official Statement. No attorney - client relationship has existed or exists between our firm and you in connection with the execution and delivery of the Bonds or by virtue of this letter. This letter is not intended to, and may not, be relied upon by owners of the Bonds, the owners of any beneficial ownership interest in the Bonds or by any other party to whom it is not addressed. This letter is limited to matters governed by federal securities laws, and we assume no responsibility with respect to the applicability or the effect of the laws of any other jurisdiction. Our engagement as disclosure contact to the City with respect to this transaction terminates as of the date hereof, and we have not undertaken any duty, and expressly disclaim any responsibility, to advise you as to events occurring after the date hereof with respect to the Bonds or other matters discussed in the Official Statement. r..oe L.�.— d—.,M p.... m -.1. C-3 EXHIBIT D FORM OF OPINION OF CITY ATTORNEY [Closing Date] J.P. MORGAN SECURITIES LLC, m Underwriter San Francisco, California Re: $ City ofVemon Water System Revenue Bonds, 2020 Series A Ladies and Gentlemen: I am the City Attorney of the City of Vernon (the "City") and as such I have served as counsel to the City in connection with the issuance of the City's $ Water System Revenue Bonds, 2020 Series A (the "Bonds"). As such counsel, I have examined and am familiar with (i) those documents relating to the existence, organization and operation of the City; (ii) all necessary documentation of the City relating to the authorization, execution and delivery of (a) the Indenture of Trust, dated as of March 1, 2020 (the "Indenture"), by and between the City and [The Bank of New York Mellon Trust Company, N.A.], as trustee (the "Trustee"), providing for the issuance of the Bonds, (b) the Continuing Disclosure Agreement, dated [as off March _, 2020 (the "Continuing Disclosure Agreement"), between the City and the Trustee, as dissemination agent; and (c) the Contract of Purchase, dated , 2020 with respect to the Bonds (the "Purchase Contract"), between the City and J.P. Morgan Securities LLC, as Underwriter (the "Underwriter'); and (iii) a Preliminary Official Statement of the City, dated , 2020 (the "Preliminary Official Statement") and an Official Statement of the City, dated , 2020 (the "Official Statement"), relating to the Bonds. The Indenture, the Continuing Disclosure Agreement and the Purchase Contract are collectively referred to herein as the "Legal Documents." I am of the opinion that: 1. The City is a chartered city, duly created, organized and existing under the Constitution and laws of the State of California and duly qualified to fiunish water service within said City. 2. The resolution of the City (the `Resolution") approving and authorizing the execution and delivery of Legal Documents and approving and authorizing the distribution of the Preliminary Official Statement and the Official Statement and the execution of the Official Statement by the City was duly adopted at a meeting of the City Council of the City, which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout. Error! Uninoan document property name. D-1 3. The City has the authority and right to execute, deliver and perform its obligations under the Legal Documents, and the City has complied in all material respects with the provisions of applicable law in all matters relating to the transaction contemplated by the Legal Documents. 4. The distribution of the Preliminary Official Statement and the Official Statement has been duly authorized by the City, the Official Statement and the Legal Documents have been duly authorized, executed and delivered by the City and, assuming the due authorization, execution and delivery by the other respective parties thereto, the Legal Documents constitute the legal, valid and binding agreements of the City enforceable in accordance with their terms, subject to laws relating to bankmptcy, insolvency or other laws affecting the enforcement of creditors' rights generally and to the application of equitable principles if equitable remedies me sought and to limitations on legal remedies against municipal corporations in the State. 5. No approval, consent or authorization of any governmental or public agency, authority or person is required for the execution and delivery by the City of the Legal Documents or the performance by the City of its obligations thereunder or the execution and delivery, on the part of the City, of the Bonds. Under the laws of the State of California, the City has the authority to determine, fix, impose and collect rates and charges for water service and is not presently subject to the regulatoryjurisdiction of any state, regional or local governmental regulatory authority other than to the extent described in the Preliminary Official Statement and the Official Statement. 6. The execution and delivery of the Legal Documents by the City and compliance with the provisions thereof will not conflict with or constitute a breach of or default under any instrument relating to the organization, existence or operation of the City, or commitment, agreement or other instrument to which the City is a party or by which it or its property is bound or affected, or any ruling, regulation, ordinance, judgment, order or decree to which the City or any of its officers in their respective capacities as such me subject or any provision of the laws of the State of California relating to the City and its affairs. 7. There is no action, suit, proceeding, inquiry or investigation at law or in equity, or before any court, public board or body, pending or, to the best of my knowledge, threatened against or affecting the City or any entity affiliated with the City or any of its officers in their respective capacities as such (nor to the best of my knowledge, is there any basis therefor) that questions the powers of the City referred to in paragraph 3 above or in connection with the transactions contemplated by the Legal Documents, or the validity of the proceedings taken by the City in connection with the authorization, execution or delivery of the Legal Documents, or wherein any unfavorable decision, ruling or finding would adversely affect the transactions contemplated by the Legal Documents, or that, in any way, would adversely affect the validity or enforceability of the Legal Documents or, in any material respect, the ability of the City to perform its obligations under the Legal Documents. 8. Based upon my participation in the preparation of the Preliminary Official Statement and the Official Statement and without having undertaken to determine independently the accuracy, completeness or fairness of the statements contained in the Preliminary Official Statement or the Official Statement, nothing has come to my attention which would lead me to believe that (i) the Preliminary Official Statement (excluding therefrom the financial statements and the statistical data and the information concerning DTC and the book -entry system included therein, the information under the caption "UNDERWRMNG" and the Appendices thereto, as to which no view is expressed) m of its date and as of , 2020, contained or contains an unfree statement of a Error! Unmo%n document property name. D-2 material fact or omitted or omits to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. or (ii) the Official Statement (excluding therefrom the financial statements and the statistical data and the information conceming DTC and the book -entry system included therein, the information under the caption "UNDERWRITING" and the Appendices thereto, as to which no view is expressed) as of its the date and as of the date hereof, contained or contains an untrue statement of a material fact or omitted or omits to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. Capitalized terns used herein not otherwise defined shall have the meanings ascribed thereto in the Purchase Contract. Respectfully submitted, Error! unknown aor t property uam D-3 EXHIBIT D Strolling force Carbon & Roush Or,t ofl/30/20 PRELIMINARY OFFICIAL STATEMENT DATED MARCH , 2020 NEW ISSUE — BOOK -ENTRY ONLY RATING: See the caption "RATING^ In the opinion ofSandling yocen Carlson & Routh, a Profersiodm( Corporation, Bond Counsel, under existing statutes, regulations, rulings andjudicial decisions, and assuming the accuracy ofcertain representations and compliance with certain covenants and requirements described in this O,Qiclal Statement interest (and original issue discoun) on the 2020 Bonds is excluded from gross inrome jor jederol income tax purposes and is not an item of tax preference for purposes of calculating the federal alternative minimum tax imposed on individuals. In the further opinion of Bond Counsel, interest (and original issue discount) on the 2020 Bonds u exempt from State of California personal income lax. See the caption "TAXMATTERS" a• CITY OF VERNON WATER SYSTEM REVENUE BONDS, 2020 SERIES A Dated: Date of Issuance Due: August 1, as set forth on the inside front cover page The 2020 Bonds are being issued in fully registered form and, when issued, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York. Parehaseri of the 2020 Bonds will not receive securities representing Weir beneficial ownership in the 2020 Bonds purchased. Interest on the 2020 Bonds is payable on [August 1, 20201 and each February 1 and August 1 thereafter, until Weir maturity or earlier redemption. The principal of and interest on the 2020 Bonds are payable by the Trustee to Cede & Co. and such interest and principal paym®ts are to be diammacd to the Beneficial Owners of the 2020 Bonds through their nominees. The 2020 Bonds are subject to optional and mandatory sinking fund redemption as more fully described in this Official Statement. The 2020 Bonds are being issued to provide moneys: (i) to finance the acquisition and construction of certain capital improvements to the Water System of the City; (ii) to fond a deposit in the Reserve Food in satisfaction of the Reserve Requirement; and (iii) to pay casts of issuance of the 2020 Bonds, all as more fully described in this Official Statement. The 2020 Bonds are being issued Focused to the Indenture of Trust, dated as of March 1, 2020, by and between the City and The Bank of New York Mellon Tnsst Company, N.A, as trustee. The 2020 Bonds son limited obligations of the City payable solely from Net Renames, which consist of Revenues of the City's Water System remaining after the payment of Operation and Maintenance Costs, and from amounts on deposit in certain funds and accounts created under the Indenture. The City may incur additional obligations payable from Net Revenues on a parity with the obligation to pay principal of and interest on the 2020 Bonds, subject to the terms and conditions of the Indenture, as more fully described in this Official Statement. THE OBLIGATION OF THE CITY TO PAY PRINCIPAL OF AND INTEREST ON THE 2020 BONDS PURSUANT TO THE INDENTURE DOES NOT CONSTITUTE AN OBLIGATION FOR WHICH THE GENERAL CREDIT OR TAXING POWER OF THE CITY IS PLEDGED. THE OBLIGATION OF THE CITY TO PAY PRINCIPAL OF AND INTEREST ON THE 2020 BONDS IS A SPECIAL OBLIGATION OF THE CITY PAYABLE SOLELY FROM NET REVENUES, AND DOES NOT CONSTITUTE A DEBT OF THE CITY OR OF THE STATE OF CALIFORNIA OR OF ANY POLITICAL SUBDIVISION THEREOF IN CONTRAVENTION OF ANY CONSTITUTIONAL OR STATUTORY DEBT LIMITATION OR RESTRICTION. THIS COVER PAGE CONTAINS CERTAIN INFORMAITON FOR REFERENCE ONLY. IT IS NOT A SUMMARY OF TIES ISSUE. INVESTORS ARE ADVISED TO READ THE ENTIRE OFFICIAL STATEMENT TO OBTAIN INFORMATION ESSENTIAL TO THE MAKING OF AN INFORMED INVESTMENT DECISION. MATURITY SCHEDULE— See Inside Forest Cover Page The 2020 Bonds are offered when, as and ifissued and received by the Underwriter, subject to the approval of the valid, legal and binding velure of the 2020 Bonds by Stradling focro Carlson & Routh, a Professional Corporation, Bond Counsel, and certain other conditions. Certain legal matters will be passed upon for the City by Stradling facto Carlson & Routh, a Professiow( Corporation, ar Disclosure Counsel, add by the City Attorney, for the Underwriter by its coumel, Norton Rose Fulbright US LLP, and for the Trader by its counsel. It is anticipated that the 2020 Bonds will be available for delivery through the facilities of The Depository Trust Company on or about March . 2020. J.P. Morgan Dated: March J 2020 ' Preliminary; subject to change. Prehowu ry, subject to change. S ' CITY OF VERNON WATER SYSTEM REVENUE BONDS, 2020 SERIES A MATURITY SCHEDULE BASE CUSWt Sfaturirr Date CUSIpmt (August t) PrintipalAmount InterestRahe YirM Price Srjfm S %Term 2020 Bonds Due August I, 20_ Yield: / Price: CUSIPst Suffix Peelimawry; eubjeona change. ' CUSIP' v a regvrered rmdemark of the Anemm� 9ankers A.rrociuian. CUSIP Global Sm es (CGS) a mawged on behalfof+he A.M. HaMere Auiauem; by 5" Cap+al IQ CopynghP 2020 CUSIP Global S uee All nthu mserved CURPe data harem is Pmvaded by CUSIP G&W &mry .. ]hu data u nm iwe to create a databue and dam mm. M m w u a ovb dwre for Me CGS dmabaee. CUSleew n arepmvhaedfor ronvenimce ofmferea'e only. Neither the Cary nar the UMerwriter take any rempouibililyfor Me aaurvty ofeaeh numbers. CITY OF VERNON COUNTY OF LOS ANGELES STATE OF CALIFORNIA CITY COUNCIL Melissa Ybarra, Mayor Leticia Lopez, Mayor Pro Tern William'Bill" Davis, Council Member Carol Menke, Council Member Diana Gonzales, Council Member STAFF Carlos R. Fandino, Jr., City Administrator Scott Williams, Finance Directodfressrrer Abraham Alemu, General Manager of Public Utilities Tema Patel, Esq., City Attorney Bond Counsel and Disclosure Counsel Stradling Yocc , Carlson & Rauth, a Professional Corporation Newport Beach, California Municipal Advisor BLX Group LLC Los Angeles, California Trustee The Bank of New York Mellon Trust Company, N.A. Los Angeles, California No dealer, broker, salesperson or other person has been authorized by the City or the Underwriter to give any information or to make my representations other than those contained in this Official Statement in connection with the offering made hereby and, if given or made, such other information or representations must not be relied upon as having been authorized by the City or the Underwriter. This Official Statement does not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be my sale of the 2020 Bonds by a person in my jurisdiction in which it is unlawful for such person to make such an offer, solicitation or sale. This Official Statement is not to be construed as a contract with the purchasers of the 2020 Bonds. Statements contained in this Official Statement which involve estimates, forecasts or matters of opinion, whether or not expressly so described herein, are intended solely as such and are not to be construed as a representation of facts. The Underwriter has provided the following sentence for inclusion in this Official Statement: The Underwriter has reviewed the information in this Official Statement in accordance with, and as a pan of, its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction, but the Underwriter does not guarantee the accuracy or completeness of such information. The information set forth herein has been obtained from official sources which are believed to be reliable, but it is not guaranteed as to accuracy or completeness and is not to be construed as a representation by the Underwriter. The information and expression of opinions herein are subject to change without notice and neither delivery of this Official Statement nor any sale made hereunder shall, under my circumstances, create any implication that there has been no change in the affairs of the City since the date hereof. IN CONNECTION WITH THIS OFFERING, THE UNDERWRITER MAY OVERALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE MARKET PRICE OF THE 2020 BONDS AT A LEVEL ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. THE UNDERWRITER MAY OFFER AND SELL THE 2020 BONDS TO CERTAIN DEALERS AND DEALER BANKS AND BANKS ACTING AS AGENT AND OTHERS AT PRICES LOWER THAN THE PUBLIC OFFERING PRICES STATED ON THE COVER PAGE HEREOF AND SAID PUBLIC OFFERING PRICES MAY BE CHANGED FROM TIME TO TIME BY THE UNDERWRITER CERTAIN STATEMENTS CONTAINED IN THIS OFFICIAL STATEMENT REFLECT NOT HISTORICAL FACTS BUT FORECASTS AND "FORWARD -LOOKING STATEMENTS." NO ASSURANCE CAN BE GIVEN THAT THE FUTURE RESULTS DISCUSSED HEREIN WILL BE ACHIEVED, AND ACTUAL RESULTS MAY DIFFER MATERIALLY FROM THE FORECASTS DESCRIBED HEREIN. IN THIS RESPECT, THE WORDS "ESTIMATE," "PROJECT," "ANTICIPATE," "EXPECT" "INTEND" "BELIEVE" AND SIMILAR EXPRESSIONS ARE INTENDED TO IDENTIFY FORWARD -LOOKING STATEMENTS WITHIN THE MEANING OF TILE PRIVATE SECURITIES LITIGATION REFORM ACT OF 1995, SECTION 21E OF THE UNITED STATES SECURITIES EXCHANGE ACT OF 1934, AS AMENDED, AND SECTION 27A OF THE UNITED STATES SECURITIES ACT OF 1933, AS AMENDED. ALL PROJECTIONS, FORECASTS, ASSUMPTIONS, EXPRESSIONS OF OPINIONS, ESTIMATES AND OTHER FORWARD -LOOKING STATEMENTS ARE EXPRESSLY QUALIFIED IN THEIR ENTIRETY BY THE CAUTIONARY STATEMENTS SET FORTH IN THIS OFFICIAL STATEMENT. The 2020 Bonds have not been registered under the Securities Act of 1933, as amended, in reliance upon an exemption contained in such act. The 2020 Bonds have not been registered or qualified under the securities laws of any state. The Indenture has not been qualified under the Trust Indenture Act of 1939. as amended, in reliance upon an exemption contained in such act. The City maintains a website. However, the information presented there is not part of this Official Statement and should not be relied upon in making an investment decision with respect to the 2020 Bonds. TABLE OF CONTENTS SUMMARY STATEMENT...................................i INTRODUCTION.................................................I PLAN OF FINANCE.............................................2 The 2020 Project................................................2 Estimated Sources And Uses Of Funds..............2 THE 2020 BONDS................................................2 General Provisions.............................................2 Transfers and Exchanges Upon Termination of Book -Entry Only System ............................3 Redemption of the 2020 Bonds ..........................4 Notice of Redemption........................................4 Book -Entry Only System...................................5 DEBT SERVICE PAYMENT SCHEDULE ......... 6 SECURITY FOR THE 2020 BONDS...................6 Limited Obligations Payable From Net Revenues.........................................................6 Rate Stabilisation Fund......................................9 Rate Covenant....................................................9 Additional Indebtedness ................................... 10 ReserveFond .................................................... 10 THECITY........................................................... I I ... General.......................................................... 11 Land Use and Service Area .....................4........ 12 Governanceand Management .......................... 12 Prior Attempt to Disinimporate City; City Reform.......................................................... 14 Employees................................6.6..................... 15 Employee Benefits........................4...6.6.6........4.15 Budget Process.................................................20 City Insurance.............................4.....................21 No Outstanding Senior or Parity Obligations...21 THE WATER SYSTEM.... .................................. 21 General.............................................................21 Water Quality ...................................................22 WaterSupply...........................6.6.......6.6.4..........22 Seismic Considerations....................................25 Drought Response ....................... 4....................25 Historical Water System Connections and Production.....................................................28 Historical Water Supply Sources and Usage .... 29 Largest Water System Customers ....................30 Water System Rates and Clines.....................30 Future Water System Capital Improvements .... 33 Projected Water System Connections and Production.....................................................35 Projected Water Supply Sources and Usage ..... 36 FINANCIAL INFORMATION ... 4... 4...................36 Financial Statements.........................................36 Available Cub.................................................37 Page Historical Water System Operating Results and Debt Service Coverage .......................... 37 Projected Water System Operating Results and Debt Service Coverage .......................... 38 CONSTITUTIONAL LIMITATIONS ON APPROPRIATIONS AND CHARGES .............. 39 Article XB®.................................................... 39 Proposition 218................................................ 39 Proposition 26.................................................. 41 Form Initiatives .............................................. 41 CERTAIN RISKS TO BONDHOLDERS .......... 41 Limited Obligations ......................................... 42 Accuracy of Assumptions ................................ 42 System Demand...............................................42 System Expenses..............................................42 Limited Recourse on Default ...........................42 Rate -Setting Process under Proposition 218....43 Statutory and Regulatory Compliance ............. 43 Natural Disasters .............................................. 43 Cybersecurity ................................................... 43 Limitations on Remedies ................................. 44 Loss of Tax Exemption .................................... 44 Secondary Market ............................................ 45 Parity Obligations ............................................ 45 Climate Change ......................... ...45 Rare Covenant Not a Guarantee ....................... 45 APPROVAL OF LEGAL PROCEEDINGS....... 45 LITIGATION...................................................... 45 TAX MATTERS ................................................. 46 RATING.............................................................. 47 MUNICIPAL ADVISOR .................................... 48 UNDERWRITING .............................................. 48 CONTINUING DISCLOSURE .......................... 49 FINANCIAL INTERESTS ................................. 49 MISCELLANEOUS ............................................ 49 APPENDIX A - FINANCIAL STATEMENTSA-1 APPENDIX B - SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE...... B-1 APPENDIX C - FORM OF OPINION OF BOND COUNSEL ..................................... C-1 APPENDIX D - INFORMATION CONCERNING DTC.................................D-1 APPENDIX E - FORM OF CONTINUING DISCLOSURE AGREEMENT .................. E-I SUMMARY STATEMENT This Summary Statement is subject in all respects to the more complete information contained in this Official Statement, and the offering of the 2020 Bonds to potential investors is made only by means of the entire Official Statement. Capitalized terms that are used and not otherwise defined in this Summary Statement have the meanings ascribed to them in this Official Statement. Purpose. The 2020 Bonds are being issued to provide moneys: (i) to finance the acquisition and construction of certain capital improvements to the Water System of the City; (ii) to fund a deposit in the Reserve Fund in satisfaction of the Reserve Requirement; and (iii) to pay costs of issuance of the 2020 Bonds, all as more fully described herein. See the caption "PLAN OF FINANCE." Security for the 2020 Bonds. The 2020 Bonds are limited obligations of the City payable solely from Net Revenues, which consist of Revenues of the City's Water System remaining after the payment of Operation and Maintenance Costs, and from amounts on deposit in certain funds and accounts created under the Indenture. THE OBLIGATION OF THE CITY TO PAY PRINCIPAL OF AND INTEREST ON THE 2020 BONDS PURSUANT TO THE INDENTURE DOES NOT CONSTITUTE AN OBLIGATION FOR WHICH THE GENERAL CREDIT OR TAXING POWER OF THE CITY IS PLEDGED. THE OBLIGATION OF THE CITY TO PAY PRINCIPAL OF AND INTEREST ON THE 2020 BONDS IS A SPECIAL OBLIGATION OF THE CITY PAYABLE SOLELY FROM NET REVENUES, AND DOES NOT CONSTITUTE A DEBT OF THE CITY OR OF THE STATE OF CALIFORNIA OR ANY POLITICAL SUBDIVISION THEREOF IN CONTRAVENTION OF ANY CONSTITUTIONAL OR STATUTORY DEBT LIMITATION OR RESTRICTION. See the caption "SECURITY FOR THE 2020 BONDS." Rate Stabilization Fund. The City will establish, maintain and hold in trust under the Indenture a special fund designated as the "Rate Stabilization Fund." The City will maintain and hold such fund separate and apart from other funds so long as the 2020 Bonds in any other Contracts or Bonds remain unpaid. Money transferred by the City from the Revenue Fund to the Rate Stabilization Fund in accordance with the hidenture will be held in the Rate Stabilization Fund and applied in accordance with the Indenture. The City may withdraw all or any portion of the amounts on deposit in the Rate Stabilization Fund and transfer such amounts to the Revenue Fund for application in accordance with the Indenture or, in the event that all or a portion of the 2020 Bonds are discharged in accordance with the Indenture, transfer all or any portion of such amounts for application in accordance with the Indenture. Any such amounts transferred from the Rate Stabilization Fund to the Revenue Fond in accordance with the Indenture constitute pledged Revenues. Rote Covenant In any Fiscal Year in which the amount on deposit in the Rate Stabilization Fund on the fast day of such Fiscal Year is less than the payments of principal of and interest on the 2020 Bonds payable in such Fiscal Year, to the fullest extent permitted by law, the City will fix and prescribe, at or before the commencement of each such Fiscal Year, rates and charges for the Water Service which are reasonably expected, at the commencement of such Fiscal Year, to be at least sufficient to yield during such Fiscal Year Net Revenues equal to 115% of Debt Service for such Fiscal Year. When calculated for the foregoing purposes, Net Revenues will not include amounts which have been transferred from the Rate Stabilization Fund pursuant to the Indenture that are in excess of 15% of Debt Service for such Fiscal Year. In any Fiscal Year in which the amount on deposit in the Rate Stabilization Fund on the first day of such Fiscal Year is at least equal to the payments of principal of and interest on the 2020 Bonds payable in such Fiscal Year, to the fullest extent permitted by law, the City will fix and prescribe, at or before the commencement of each such Fiscal Year, rates and charges for the Water Service which are reasonably expected, at the commencement of such Fiscal Year, to be at least sufficient to yield during such Fiscal Year Revenues equal to 115% of the Operation and Maintenance Costs for such Fiscal Year. When calculated for purposes of this subsection, Revenues will not include any amounts which have been transferred from the Rate Stabilization Fond pursuant to the Indenture. The City may make or permit to be made adjustments from time to time in such rates, fees and charges and may make or permit to be made such classification thereof as it deems necessary, but shall not reduce or permit to be reduced such rates, fees and charges below those then in effect unless the Revenues from such reduced rates, fees and charges will at all times be sufficient to meet the foregoing requirements. See the caption "SECURITY FOR THE 2020 BONDS —Rate Covenant." Additional Contracts and Bonds. The Indenture permits the City to execute additional Contracts or to issue additional Bonds on a parity with the obligation to pay principal of and interest on the 2020 Bonds, provided that certain conditions are satisfied as described herein. See the caption "SECURITY FOR THE 2020 BONDS —Additional Indebtedness." The Indenture also permits the City to execute or issue obligations payable on a subordinate basis to the 2020 Bonds. Reserve Fund. A Reserve Fund for the 2020 Bonds is established pursuant to the Indenture in an amount equal to the Reserve Requirement. If one Business Day prior to any Interest Payment Date the moneys in the Payment Fund are insufficient to pay amounts due on the 2020 Bonds on such Interest Payment Date, the Trustee will transfer from the Reserve Fond to the Payment Fund the amount of such insufficiency. See the caption "SECURITY FOR THE 2020 BONDS —Reserve Fund." Redemption. The 2020 Bonds are subject to optional and mandatory sinking fund redemption prior to maturity as described herein. See the caption "THE 2020 BONDS —Redemption of the 2020 Bonds." The City and the Water System. The City was incorporated in 1905 under the general laws of the State of California. City voters approved a charter in 1988 and the City thereafter became a charter city. The City has a land area of approximately 5.2 square miles and an estimated population of 240 people as of December I, 2019. Land use in the City primarily consists of industrial development, with small areas devoted to commercial and residential uses. The City is located in the County of Los Angeles, approximately 5 miles south of downtown Los Angeles. See the caption `TIM CITY." The City provides water service to approximately 238 industrial, 829 commercial and 38 residential and other customers as of June 30, 2019. The City's Water System includes approximately 244,000 linear fat of water mains, 3 booster stations and 8 reservoirs (one of which is elevated and one of which is below ground) which provide total operational storage of approximately 16.375 million gallons. The City pumps groundwater from 8 wells which are located within the Central Groundwater Basin, an adjudicated groundwater basin. The City also purchases imported water at wholesale and recycled water from Central Basin Municipal Water District, a member agency of The Metropolitan Water District of Southern California, See the caption "TILE WATER SYSTEM." S' CITY OF VERNON WATER SYSTEM REVENUE BONDS, 2020 SERIES A INTRODUCTION This Official Statement, including the front cover page, the inside front cover page and all appendices, provides certain information concerning the sale and delivery of the City of Vernon Water System Revenue Bonds, 2020 Series A (the "2020 Bonds'). The 2020 Bonds are being issued pursuant to Article 11 of the Charter of the City of Vernon (the "City"), the City of Vernon Municipal Facilities Revenue Bond Law, constituting Article XI of the Vernon City Code, an Indenture of Tout, dated as of March 1, 2020 (the 'Indenture"), by and between the City and The Bank of New York Mellon Trust Company, N.A., Los Angeles, California, as trustee (the "Trustee"). The 2020 Bonds are being issued to provide moneys: (i) to finance the acquisition and construction of certain capital improvements to the Water System of the City (the "2020 Prejecfl; (ii) to fund a deposit in the Reserve Fond in satisfaction of the Reserve Requirement; and (ui) to pay costs of issuance of the 2020 Bonds. See the caption "PLAN OF FINANCE." The 2020 Bonds are limited obligations of the City payable solely from Net Revenues, which consist of Revenues of the City's Water System (the "Water System') remaining after the payment of Operation and Maintenance Costs of the Water System, as such terms are defined in Appendix B, and from amounts on deposit in certain funds and accounts created under the Indenture. A Reserve Fond for the 2020 Bonds is established pursuant to the Indenture in an amount equal to the Reserve Requirement. If one Business Day prior to any Interest Payment Date the moneys in the Payment Fond are insufficient to pay amounts due on the 2020 Bonds on such Interest Payment Date, the Trustee will transfer from the Reserve Fond to the Payment Fond the amount of such insufficiency. See the caption "SECURITY FOR THE 2020 BONDS —Reserve Fund." The City may incur additional obligations payable on a parity with the obligation to pay principal of and interest on the 2020 Bonds in the future as described under the caption "SECURITY FOR THE 2020 BONDS —Additional Indebtedness." The 2020 Bonds are subject to optional and mandatory sinking fund redemption prior to maturity as described herein. See the caption "THE 2020 BONDS —Redemption of the 2020 Bonds." The summaries and references to the Indenture and all documents, statutes, reports and other instruments that are referred to herein do not purport to be complete, comprehensive or definitive, and each such summary or reference is qualified in its entirety by reference to the full Indenture or the respective document, statute, report or instrument, copies of which are available for inspection at the offices of the City in Vernon, California or from the Trustee upon request and payment of duplication cost. The capitalization of any word that is not conventionally capitalized or otherwise defined herein indicates that such word is defined in the Indenture and, as used herein, has the meaning that is given to it in the Indenture. See Appendix B for a summary of the Indenture. Unless otherwise indicated, all financial and statistical information herein has been provided by the City. The City regularly prepares a variety of reports, including audits, budgets and related documents. Any registered owner of the 2020 Bonds may obtain a copy of such reports, as available, from the Trustee or the City. Additional information regarding the Official Statement may be obtained by contacting the Trustee or the City of Vernon, 4305 South Santa Fe Avenue, Vemon, California 90058, Attention: Finance Department. PWI.b m6jmrochange. The City has also undertaken to provide annual reports and notice of certain enumerated events to the Municipal Securities Rulemaking Board's Electronic Municipal Market Access System ("EMMA') pursuant to a continuing disclosure agreement. See the caption "CONTINUING DISCLOSURE" and Appendix E. PLAN OF FINANCE The 2020 Project The 2020 Project consists of the following capital improvements: (i) construction of two new groundwater wells, as discussed under the caption "THE WATER SYSTEM —Water Supply —Groundwater," and (ii) upgrades and rehabilitations of existing water wells, reservoirs, tanks, pumps, generators, pipelines, fencing and other equipment. See the caption "THE WATER SYSTEM —Future Water System Capital Improvements" for a full listing of anticipated capital projects, including the 2020 Project, in the current and next four fiscal years of the City ending June 30 (each, a "Fiscal Year"). The City expects to comply with all governmental approval, environmental review, public bidding and other pemutting requirements for each component of the 2020 Project as required by law and to complete the 2020 Project by early 2023. Pursuant to the Indenture, the City may substitute or add additional projects to the 2020 Project. See Appendix B under the caption "ISSUANCE OF 2020 BONDS; APPLICATION OF PROCEEDS --Changes to the 2020 Project." Estimated Sources And Uses Of Funds The following table sets forth the estimated sources and uses of funds: Sources('): Principal Amount $ Plus/Less Net Original Issue Premiura/Discount Total Sources $ Uses(1) Deposit to Acquisition Fund(2) $ Deposit to Reserve Fund Costs of Issuance([) Total Uses 0) All amounts rounded to the aeanal dollar. Totals may not add due to rounding. on Includes amounts being applied to reimburse the City for previous expenditures on the 2020 Project. 01 Includes Underwriter's discount and certain legal, municipal advisory, rating agency, printing, and other financing -related costs. THE 2020 BONDS General Provisions The 2020 Bonds will be issued in the aggregate principal amount of $ The 2020 Bonds will be dated as of their date of initial issuance, will bear interest from such date at the rates per annum set forth on the inside front cover page hereof, payable on (August 1, 20201 and each February 1 and August 1 thereafier (each, an "Interest Payment Date"), and will mature on the dates set forth on the inside front cover Preliminary; .rubjecr ro change. MI page hereof. Interest on the 2020 Bonds will be computed on the basis of a 360 day year composed of twelve 30 day months. The 2020 Bonds will be issued only in fully registered form and, when issued, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York ("DTC"). DTC will act as securities depository for the 2020 Bonds. Ownership interests in the 2020 Bonds may be purchased in book -entry form, in any integral multiple of $5,000. See the caption "—Book-Entry Only System' below and Appendix D. In the event that the book -entry only system that is described below is discontinued, the principal of and redemption premium (if any) on the 2020 Bonds are payable by check of the Trustee upon presentation and surrender thereof at maturity or upon prior redemption at the office of the Trustee in Los Angeles, California (the "Office of the Trustee'). Interest on the 2020 Bonds is payable on each Interest Payment Date to the person whose name appears on the registration books maintained by the Trustee (the `Registration Books") as the Owner thereof as of the close of business on the fifteenth day of the calendar month preceding the Interest Payment Date (the "Record Date"), such interest to be paid by check of the Trustee sent by first class mail on the applicable Interest Payment Date to the Owner at such Owner's address as it appears on the Registration Books. An Owner of $1.000,000 or more in principal amount of 2020 Bonds may, at such Owner's option, be paid by wire transfer of immediately available funds to an account in the United States in accordance with written instructions provided to the Trustee by such Owner prior to the applicable Record Date. The principal of and interest and premium, if any, on the 2020 Bonds will be payable in lawful money of the United States. Each 2020 Bond will bear interest from the Interest Payment Date next preceding the date of authentication thereof unless: (a) it is authenticated after a Record Date and on or before the following Interest Payment Date, in which event it will bear interest from such Interest Payment Date; or (b) unless it is authenticated on or before [July 15], 2020, in which event it will bear interest from its date of issuance; provided, however, that if, as of the date of authentication of any 2020 Bond, interest thereon is in default, such 2020 Bond will bear interest from the Interest Payment Date to which interest has previously been paid or made available for payment thereon. Transfers and Exchanges Upon Termination of Book -Entry Only System In the event that the book -entry system that is described herein is discontinued, the 2020 Bonds will be printed and delivered as provided in the Indenture. Thereafter, any 2020 Bond may, in accordance with its terms, be transferred on the Registration Books by the person in whose name it is registered, in person or by his or her duly authorized attorney, upon surrender of such 2020 Bond at the Office of the Trustee for cancellation, accompanied by delivery of a written instrument of transfer, duly executed in a form acceptable to the Trustee. The Trustee is not required to register the transfer of any 2020 Bond during the period in which the Trustee is selecting 2020 Bonds for redemption and any 2020 Bond that has been selected for redemption. Whenever any 2020 Bond or 2020 Bonds are surrendered for transfer, the City will execute and the Trustee will authenticate and deliver a new 2020 Bond or 2020 Bonds of authorized denomination or denominations for a like aggregate principal amount of the same maturity. The Trustee will require the 2020 Bond Owner requesting such transfer to pay any tax or other governmental charge required to be paid with respect to such transfer. Following any transfer of 2020 Bonds, the Trustee will cancel and destroy the 2020 Bonds that it has received. The 2020 Bonds may be exchanged at the Office of the Trustee for a like aggregate principal amount of other authorized denominations of the same maturity. The Trustee is not required to exchange my 2020 Bond during the period in which the Trustee is selecting 2020 Bonds for redemption and any 2020 Bond that has been selected for redemption. The Trustee will require the 2020 Bond Owner requesting such exchange to -3- pay any tax or other governmental charge required to be paid with respect to such exchange. Following any exchange of 2020 Bonds, the Trustee will cancel and destroy the 2020 Bonds that it has received. Prior to any transfer of the 2020 Bonds outside the book -entry system (including, but not limited to, the initial transfer outside the book -entry system) the transferor will provide or cause to be provided to the Trustee all information necessary to allow the Trustee to comply with any applicable tax reporting obligations, including without limitation any cost basis reporting obligations under Internal Revenue Code Section 6045, as amended. The Trustee will conclusively rely on the information provided to it and has no responsibility to verify or ensure the accuracy of such information. Redemption of the 2020 Bonds Optional Redemption.' The 2020 Bonds with stated maturities on or after August 1, 20, are subject to redemption prior to their respective stated maturities, as a whole or in part on _ 1, 20_, or any date thereafter, as directed by the City in a Written Request provided to the Trustee at least 35 days (or such lesser number of days acceptable to the Trustee in the sole discretion of the Trustee, such notice for the convenience of the Trustee) and by lot within each maturity in integral multiples of $5,000, at a Redemption Price equal to the principal amount thereof plus accrued interest thereon to the Redemption Date, without premium. Mandatory Sinking Fund Redemption.' The 2020 Bonds maturing on August 1, 20_ (the "Term Bonds') with stated maturities on August 1, 20_ are subject to mandatory sinking fund redemption in par (by lot) on August 1, 20_ and each August I thereafter, in integral multiples of $5,000 at a Redemption Price of the principal amount thereof plus accrued interest to the date fixed for redemption, without premium, in accordance with the following schedule: Redemption Date Principal (4ugust 1) Amount 20 1 r Maturity If some but not all of the Term Bonds are redeemed pursuant to the optional redemption provisions of the Indenture (as described under the subcaption "--Optional Redemption"), the principal amount of the applicable Tern Bonds to be redeemed pursuant to the Indenture on any subsequent August 1 will be reduced, by $5,000 or an integral multiple thereof, as designated by the City in a Written Order of the City filed with the Trustee; provided, however, that the aggregate amount of such reductions may not exceed the aggregate amount of the applicable Term Bonds redeemed pursuant to optional redemption provisions of the Indenture. Notice of Redemption Notice of redemption will be mailed by first class mail at least 20 days but not more than 60 days before any Redemption Date, to the respective Owners of my 2020 Bonds designated for redemption at their addresses appearing on the Registration Books, to the Securities Depositories and to the Information Services. Each notice of redemption will state the date of notice, the Redemption Date, the place or places of redemption, the Redemption Price, will designate the maturities, CUSIP numbers, if any, and, in the case of 2020 Bonds to be redeemed in par only, the respective portions of the principal amount thereof to be redeemed. Each such notice will also state that on the Redemption Date there will become due and payable on P.ddnl oov ..yen ro change. A- each of said 2020 Bonds or parts thereof designated for redemption the Redemption Price thereof or of said specified portion of the principal thereof in the case of a 2020 Bond to be redeemed in part only, together with interest accrued thereon to the Redemption Date, and that (provided that moneys for redemption have been deposited with the Trustee) from and after such Redemption Date interest thereon will cease to accrue, and will require that such 2020 Bonds be then surrendered to the Trustee. Neither the failure to receive such notice nor any defect in the notice or the mailing thereof will affect the validity of the redemption of any 2020 Bond. Notice of redemption of 2020 Bonds will be given by the Trustee, at the expense of the City, for and on behalf of the City. With respect to any notice of optional redemption of 2020 Bonds, such notice may state that such redemption will be conditional upon the receipt by the Trustee on or prior to the date fixed for such redemption of moneys sufficient to pay the principal of, premium, if any, and interest on such 2020 Bonds to be redeemed and that, if such moneys have not been so received, said notice will be of no force and effect and the Trustee will not be required to redeem such 2020 Bonds. In the event that such notice of redemption contains such a condition and such moneys are not so received, the redemption will not be made, and the Trustee will within a reasonable time thereafter give notice, in the manner in which the notice of redemption was given, that such moneys were not so received. Book -Entry Only System One fully -registered 2020 Bond of each maturity will be issued in the principal amount of the 2020 Bonds of such maturity. Such 2020 Bond will be registered in the name of Cede & Co. and will be deposited with DTC. As long as the ownership of the 2020 Bonds is registered in the name of Cede & Co., the term "Owner" as used in this Official Statement will refer to Cede & Co. and not to the actual purchasers of the 2020 Bonds (the "Beneficial Owners"). The City may decide to discontinue use of the system of book -entry transfers through DTC (or a successor securities depositary). In that event, the 2020 Bonds will be printed and delivered and will be governed by the provisions of the Indenture with respect to payment of principal and interest and rights of exchange and transfer. See the caption "—Transfers and Exchanges Upon Termination of Book -Entry Only System." The City cannot and does not give any assurances that DTC Participants or others will distribute payments of principal of and interest on the 2020 Bonds received by DTC or its Nominee as the registered Owner, or any redemption or other notices, to the Beneficial Owners (as such term is defined in Appendix D), or that they will do so on a timely basis, or that DTC will service and act in the manner described in this Official Statement. See Appendix D for additional information concerning DTC. 5E DEBT SERVICE PAYMENT SCHEDULE Set forth below is an annualized schedule of principal of and interest on the 2020 Bonds for the period ending June 30 in each of the years indicated, assuming no optional redemptions of the 2020 Bonds. Period Ending 2020 Bonds 2020 Bonds 2020 Bonds June 30 Principal Interest Totat Debt Service 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 TOTAL Source: Underwriter. SECURITY FOR TILE 2020 BONDS Limited Obligations Payable From Net Revenues General. The City is obligated to make payments of principal of and interest on the 2020 Bonds solely from Net Revenues. The term "Net Revenues' means, for any period, the Revenues of the Water System for such period less the Operation and Maintenance Costs of the Water System for such period. See Appendix B for detailed definitions of `Revenues" and "Operation and Maintenance Costs." When held by the Trustee in any funds or accounts established under the Indenture, Net Revenues will include all interest or realized gain derived from the investment of amounts in any of such funds or accounts. -6- THE OBLIGATION OF THE CITY TO PAY PRINCIPAL OF AND INTEREST ON THE 2020 BONDS PURSUANT TO THE INDENTURE DOES NOT CONSTITUTE AN OBLIGATION FOR WHICH THE GENERAL CREDIT OR TAXING POWER OF THE CITY IS PLEDGED. THE OBLIGATION OF THE CITY TO PAY PRINCIPAL OF AND INTEREST ON THE 2020 BONDS IS A SPECIAL OBLIGATION OF THE CITY PAYABLE SOLELY FROM NET REVENUES, AND DOES NOT CONSTITUTE A DEBT OF THE CITY OR OF THE STATE OF CALIFORNIA OR OF ANY POLITICAL SUBDIVISION THEREOF IN CONTRAVENTION OF ANY CONSTITUTIONAL OR STATUTORY DEBT LIMITATION OR RESTRICTION. Pledge and Assignment, Revenue Fund. All of the Revenues, all amounts held in the Revenue Fund, all amounts that are transferred from the Rate Stabilization Fund to the Revenue Fund as described in the Indenture, and any other amounts (including proceeds of the sale of the 2020 Bonds) held in any fund or account established pursuant to the Indenture (except the Rebate Fund and the Rate Stabilization Fund (other than those amounts which are transferred by the City from the Rate Stabilization Fund to the Revenue Fund)) have been irrevocably pledged to secure the payment of the principal of and interest, and the premium, if my, on the 2020 Bonds in accordance with their terms and the provisions of the Indenture, and the Revenues may not be used for my other purpose while the 2020 Bonds remain Outstanding; provided that out of the Revenues there may be apportioned such sums for such purposes as are expressly permitted in the Indenture. Said pledge, together with the pledge created by all other Contracts and Bonds, constitutes a first lien on and security interest on Revenues and, subject to application of Revenues and all amounts on deposit therein as permitted herein, the Revenue Fund and other fords and accounts created under the Indenture for the payment of the principal of and interest, and the premium, if my, on the 2020 Bonds and all Contracts and Debt Service on Bonds in accordance with the terms of the Indenture, and will attach, be perfected and be valid and binding from and after the Closing Date, without my physical delivery thereof or further act and will be valid and binding against all parties having claims of my kind in tort, contract or otherwise against the City, irrespective of whether such parties have notice of the Indenture. In order to carry out and effectuate the pledge and lien contained in the Indenture, the City has agreed and covenanted that all Revenues will be received by the City in trust under the Indenture and will be deposited when and as received in the Revenue Fund, which fund the City has agreed and covenanted to maintain and to hold separate and apart from other funds so long as the 2020 Bonds and my Contracts or Debt Service on Bonds remain unpaid. Moneys in the Revenue Fund will be used and applied by the City as provided in the Indenture. All moneys in the Revenue Fond will be held in trust and will be applied, used and withdrawn for the purposes set forth below. The City will, from the moneys in the Revenue Food, pay all Operation and Maintenance Costs (including amounts reasonably required to be set aside in contingency reserves for Operation and Maintenance Costs, the payment of which is not then immediately required) as such Operation and Maintenance Costs become due and payable. All remaining moneys in the Revenue Fund will be set aside by the City at the following times for the transfer to the following respective special funds in the following order of priority: (i) interest and Principal Payments. Not later than the third Business Day prior to each Interest Payment Date, the City will, from the moneys in the Revenue Food, transfer to the Trustee for deposit in the Payment Food or the Redemption Food the payments of interest and principal or mandatory sinking fund payments, as applicable, on the 2020 Bonds due and payable on such Interest Payment Date. The City will also, from the moneys in the Revenue Food, transfer to the applicable trustee for deposit in the respective payment fund, without preference or priority, and in the event of my insufficiency of such moneys ratably without any discrimination or preference, any other Debt Service in accordance with the provisions of my Bond or Contract. (ii) Reserve Funds. After making the payments, allocations or transfers provided for in clause (i) above, the City will, from the remaining moneys in the Revenue Fund, thereafter, without preference or priority and in the event of my insufficiency of such moneys ratably without my discrimination or preference, IFA transfer to the Reserve Fund and to the applicable trustee for such other reserve funds and/or accounts, if any, as may have been established in connection with Bonds or Contracts, that sum, if any, necessary to restore such funds or accounts to an amount equal to the Reserve Requirement and the reserve requirement applicable to such Bonds or Contracts, as applicable; provided, however, that the City may provide for the Reserve Fund by means other than cash and Permitted Investments pursuant to the Indenture. See the caption "—Reserve Fund." (iii) Sumlus. Moneys on deposit in the Revenue Fund on any date when the City reasonably expects such moneys will not be needed for the payment of Operation and Maintenance Costs or any of the purposes described in clauses (i) or (ii) above may be deposited in the Rate Stabilization Fond or expended by the City at any time for any purpose permitted bylaw. See the caption' —Rate Stabilization Fond." (iv) Investments. All moneys held by the City in the Revenue Fond will be invested in Pemtitted Investments and the investment earnings thereon will remain on deposit in such fund, except as otherwise provided herein. Allocation ofRevenues. There has been established with the Trustee the Payment Food, which the Trustee has covenanted to maintain and hold in trust separate and apart from other funds held by it so long as any principal of and interest on the 2020 Bonds remain unpaid. Except as directed in the Indenture, all payments of interest and principal on the 2020 Bonds received by the Trustee as described above under the subcaption "—Pledge and Assignment; Revenue Fund" will be promptly deposited by the Trustee upon receipt thereof into the Payment Fond; except that all moneys received by the Trustee and required under the Indenture to be deposited in the Redemption Fond will be promptly deposited therein. All payments of interest and principal on the 2020 Bonds deposited with the Trustee will be held, disbursed, allocated and applied by the Trustee only as provided in the Indenture. The Trustee will also establish and hold an Interest Account and a Principal Account within the Payment Fond. The Trustee will transfer from the Payment Fund and deposit into the following respective accounts, the following amounts in the following order of priority and at the following tines, the requirements of each such account (including the making up of any deficiencies in any such account resulting from lack of Revenues sufficient to make any earlier required deposit) at the time of deposit to be satisfied before any transfer is made to any account subsequent in priority: (a) Not later than the Business Day preceding each Interest Payment Date, the Trustee will deposit in the Interest Account that sum, if any, required to cause the aggregate amount on deposit in the Interest Account to be at least equal to the amount of interest becoming due and payable on such date on all 2020 Bonds then Outstanding. No deposit need be made into the Interest Account so long as there is in such fund moneys sufficient to pay the interest becoming due and payable on such date on all 2020 Bonds then Outstanding. All amounts in the Interest Account will be used and withdrawn by the Tmstee solely for the purpose of paying interest on the 2020 Bonds as it becomes due and payable (including seemed interest on any 2020 Bonds purchased or accelerated prior to maturity pursuant to the Indenture). (b) Not later than the Business Day preceding each date on which the principal of the 2020 Bonds becomes due and payable under the Indenture, the Trustee will deposit in the Principal Account that sum, if any, required to cause the aggregate amount on deposit in the Principal Account to equal the principal amount of the 2020 Bonds coming due and payable on such date. No deposit need be made into the Principal Account so long as there is in in such fond moneys sufficient to pay the principal becoming due and payable on such date on all 2020 Bonds then Outstanding. All amounts in the Principal Account will be used and withdrawn by the Trustee solely to pay the principal amount of the 2020 Bonds at maturity, purchase or acceleration; provided, however, that at any time -8- prior to selection for redemption of any such 2020 Bonds, upon written direction of the City, the Trustee will apply such amounts to the purchase of 2020 Bonds at public or private sale, as and when and at such prices (including brokerage and other charges, but excluding accrued interest, which is payable from the Interest Account) as directed pursuant to a Written Request of the City, except that the purchase price (exclusive of accrued interest) may not exceed the Redemption Price then applicable to the 2020 Bonds. Rate Stabilization Fund The City will establish, maintain and hold in trust under the Indenture a special fund designated as the "Rate Stabilization Fund." The City will maintain and hold such fund separate and apart from other funds so long as the 2020 Bonds or any other Contracts or Bonds remain unpaid. Money transferred by the City from the Revenue Fund to the Rate Stabilization Fond as described in clause (iii) under the caption "—Limited Obligations Payable From Net Revenues —Pledge and Assignment; Revenue Fm8' will be held in the Rate Stabilization Ford and applied in accordance with the Indenture. The City may withdraw all or any portion of the amounts on deposit in the Rate Stabilization Ford and transfer such amounts to the Revenue Ford for application in accordance with the Indenture or, in the event that all or a portion of the 2020 Bonds are discharged in accordance with the Indenture, transfer all or any portion of such amounts for application in accordance with the defeasance provisions of the Indenture. Any such amounts transferred from the Rate Stabilization Fund to the Revenue Fund in accordance with the Indenture constitute pledged Revenues. The City does not intend to deposit any moneys in the Rate Stabilization Ford at the time the 2020 Bonds are issued; however, as noted above, the City retains the right to deposit and withdraw moneys from the Rate Stabilization Fund from time to time and apply such moneys in accordance with the Indenture. No assurance can be made that moneys will, in fact, be deposited into the Rate Stabilization Ford or that moneys will be on deposit in the Rate Stabilization Ford to pay debt service on the 2020 Bonds in the event that Net Revenues are insufficient for this purpose. Rate Covenant In any Fiscal Year in which the amount on deposit in the Rate Stabilization Ford on the first day of such Fiscal Year is less than the payments of principal of and interest on the 2020 Bonds payable in such Fiscal Year, to the fullest extent permitted by law, the City will fix and prescribe, at or before the commencement of each such Fiscal Year, rates and charges for the Water Service which are reasonably expected, at the commencement of such Fiscal Year, to be at least sufficient to yield during such Fiscal Year Net Revenues equal to 115% of Debt Service for such Fiscal Year. When calculated for the foregoing purposes, Net Revenues will not include amounts which have been transferred from the Rate Stabilization Fond pursuant to the Indenture that are in excess of 15% of Debt Service for such Fiscal Year. In any Fiscal Year in which the amount on deposit in the Rate Stabilization Fund on the frost day of such Fiscal Year is at least emral to the payments of principal of and interest on the 2020 Bonds payable in such Fiscal Year, to the fullest extent permitted by law, the City will fix and prescribe, at or before the commencement of each such Fiscal Year, rates and charges for the Water Service which are reasonably expected, at the commencement of such Fiscal Yew, to be at least sufficient to yield during such Fiscal Year Revenues equal to 115% of the Operation and Maintenance Costs for such Fiscal Year. When calculated for purposes of this subsection, Revenues will not include any amounts which have been transferred from the Rate Stabilization Fond pursuant to the Indenture. The City may make or permit to be made adjustments from time to time in such rates, fees and charges and may make or permit to be made such classification thereof as it deems necessary, but may not reduce or permit to be reduced such rates, fees and charges below those then in effect unless the Revenues from such reduced rates, fees and charges will at all times be sufficient to meet the foregoing requirements. S2 Additional Indebtedness Pursuant to the Indenture, the City may at any time execute any Contracts or issue any Bonds payable from Net Revenues on a parity with the obligation to pay principal of and interest on the 2020 Bonds provided that the following conditions are satisfied: (a) The Net Revenues for the last audited Fiscal Year of the City, or for any consecutive twelve calendar month period during the eighteen calendar month period, preceding the date of adoption by the City Council of the City of the resolution authorizing the issuance of such Bonds or the date of the execution of such Contract, as the case may be, as evidenced by a special report prepared by an Independent Certified Public Accountant or Independent Financial Consultant on file with the City, produce a sum equal to at least 115% of the Debt Service for such Fiscal Year or other twelve month period. When calculated for purposes of the foregoing test, Net Revenues will not include amounts that have been transferred from the Rate Stabilization Fund to the Revenue Fund pursuant to the Indenture that are in excess of 15% of Debt Service for such Fiscal Year; and (b) The Net Revenues for the last audited Fiscal Year of the City, or for any consecutive twelve calendar month period during the eighteen calendar month period, preceding the date of adoption by the City Council of the City of the resolution authorizing the issuance of such Bonds or the date of the execution of such Contract, as the case may be, including adjustments to give effect as of the fast day of such twelve month period to increases or decreases in rates and charges for the Water Service approved and in effect as of the date of calculation, as evidenced by a special report prepared by an Independent Certified Public Accountant or Independent Financial Consultant on file with the City, produce a sum equal to at least 115% of the Debt Service for such Fiscal Year or other twelve month period, plus the Debt Service which would have accrued on any Contracts executed or Bonds issued since the end of such Fiscal Year or other twelve month period, assuming that such Contracts had been executed or Bonds had been issued at the beginning of such Fiscal Year or other twelve month period, plus the Debt Service which would have accrued had such proposed additional Contract been executed or proposed additional Bonds been issued at the beginning of such Fiscal Year or other twelve month period. When calculated for purposes of the foregoing test, Net Revenues will not include amounts that have been transferred from the Rate Stabilization Fund to the Revenue Fund pursuant to the Indenture that are in excess of 15%of Debt Service for such Fiscal Year. Notwithstanding the foregoing, Bonds issued or Contracts executed to refund Bonds or prepay Contracts may be delivered without satisfying the conditions set forth above if total Debt Service after the issuance of such refunding Bonds or execution of such refunding Contracts executed is not greater than total Debt Service would have been prior to the issuance of such Bonds or execution of such Contracts. Reserve Fund There has been established with the Trustee a separate account known as the "Reserve Fund" solely as security for payments by the City on the 2020 Bonds. The initial deposit to the Reserve Fund shall be in the amount of S_, which is equal to the initial Reserve Requirement. The term "Reserve Requirement" means initially, S. and thereafter the lesser of. (i) S_; m (ii) the least of (a) the maximum principal of and interest on the 2020 Bonds due in the then current or any future Fiscal Yew; (b) 125% of average annual Debt Service on the Outstanding 2020 Bonds; or (c) 10% of the then -Outstanding principal amount of the 2020 Bonds. If one Business Day prior to any Interest Payment Date the moneys in the Payment Fond are insufficient to pay amounts due on the 2020 Bonds on such Interest Payment Date, the Trustee will transfer from the Reserve Ford to the Payment Fund the amount of such insufficiency. In the event that the Trustee has transferred moneys from the Reserve Fund to the Payment Ford in accordance with the Indenture, upon 5113 receipt of the moneys from the City to increase the balance in the Reserve Fund to the Reserve Requirement, the Trustee will deposit such moneys in the Reserve Fund. If the amount available and contained in the Reserve Fond exceeds an amount equal to the Reserve Requirement and if the City is not then in default under the Indenture, the Trustee will semiannually on or before each Interest Payment Date withdraw the amount of such excess from the Reserve Fund and deposit such amount in the Payment Fund, and for such determination the Trustee will make a valuation of the Reserve Fund as often as it may deem appropriate, and in any event on or before each Interest Payment Date in each year. In addition, the Tntstee will, on the date all or any portion of the 2020 Bonds are discharged in accordance with the Indenture, value the Reserve Fund in accordance with the Indenture and withdraw the excess, if any, on deposit in the Reserve Fund and transfer such amount to or in accordance with the written direction of the District. Except for such withdrawals, all moneys in the Reserve Fund will be used and withdmwn by the Trustee solely for the purpose of paying principal, Redemption Price and interest on the 2020 Bonds in the event that no other moneys of the District are available therefor. For the purpose of determining the amount in the Reserve Fund, all Permitted Investments credited to the Reserve Fund will be valued at the lower of cost (inclusive of all interest accrued but not paid), or book value. The District may satisfy the Reserve Requirement to deposit a specified amount in the Reserve Fund by the deposit of (a) a surety bond; (b) a municipal bond insurance policy; (c) an unconditional irrevocable letter of credit; or (d) any other security device, in each case issued by providers whose long term debt, or, in the case of a monoline financial guaranty insurance company, claims paying ability, is rated, at the time such security device is issued, "AA" or better by S&P, if S&P is then rating the 2020 Bonds, "AA" or better by Moody's, if Moody's is then rating the 2020 Bonds, and "AA" or better by Fitch, if Fitch is then rating the 2020 Bonds. THE CITY General The City was incorporated in 1905 under the general laws of the State of California (the `State"). City voters approved a charter in 1988 and the City thereafter became a charter city. The City has a land area of approximately 5.2 square miles and an estimated population of 240 people as of December 1, 2019. Land use in the City primarily consists of industrial development, with small areas devoted to commercial and residential uses. See the caption' —Land Use and Service Area." The City provides a wide range of services, such as public utilities (including water, gas, fiber and electric services), police protection and public works. The City is currently in the process of transitioning fire services from the City's Fire Department to the County of Los Angeles Fire Department. The transition is expected to be finalized by late 2020. The City is located in the County of Los Angeles (the "County"), approximately 5 miles south of downtown Los Angeles. The City has extensive rail lines rumring through it, as well as two large intermodal freight yards at the City northem boundaries, to serve its industrial customer base. It is also located along Interstate 710 and is in close proximity to Intendates 5, 10, 105 and 110. With its location along or near these freeways, its close proximity to the Ports of Los Angeles and Long Beach and Los Angeles International Airport, together with the rail lines within the City, the City has access to a significant transportation network. The City has diversified from its origins as a hub for livestock businesses and there are currently over 1,700 industrial firms employing approximately 37,000 people within the City. The City provides water service to approximately 238 industrial, 829 commercial and 38 residential and other customers as of June 30, 2019. The City's Water System includes approximately 244,000 linear feet of water mains, 3 booster stations and 8 reservoirs (one of which is elevated and one of which is below ground) which provide total operational storage of approximately 16.375 million gallons. The City pumps groundwater from 8 wells which are located within the Central Groundwater Basin, an adjudicated groundwater basin. The City also purchases imported water at wholesale and recycled water from Central Basin Municipal Water District ("CBMWD"), a member agency of The Metropolitan Water District of Southern California ("MWD"). Land Use and Service Area The Water System provides water to a service area of approximately 3.7 square miles (the majority of the geographic area of the City), with small areas within the northeast and southeast boundaries of the City served by private water companies. The service area is largely built out and primarily encompasses industrial and commercial businesses, with small areas of residential use. In Fiscal Year 2019, industrial and commercial customers consumed approximately 99.7% of the water served by the City. Because the Water System's customer base is primarily industrial and commercial, water demand is not dependent on population growth or precipitation but is closely tied to regional, national and international economic trends. Many of the City's industrial and commercial customers have operated in the City for decades. In addition, the City has a low vacancy rate of less than 2.5% (as of the fourth quarter of 2018, the latest period for which such information is available), and the City believes that other businesses would quickly fill any vacant spaces upon the departure of a large customer of the Water System. Governance and Management General. The City is governed by a five -member City Council, the members of which are elected at large for staggered four year terms. Council members select a Mayor and Mayor Pro 'rem from among the City Council. The current Mayor and City Council members and the expiration dates of their terms are set forth below. CITY OF VERNON Mayor and City Council Members Name and Title Erpiratlon ojTerm Melissa Ybarra, Mayor April 2022 Leticia Lopez, Mayor Pro Tem April 2021 William "Bill" Davis, Council Member April 2023 Carol Menke, Council Member April 2024 Diana Gonzales, Council Member April 2020 The City Administrator, who is appointed by the City Council, serves as the City's chief executive officer and is responsible for overseeing the daily operations of City departments. The City Administrator serves as an advisor to the City Council on policy matters, supports the informational and policymaking needs of the City Council, implements City Council decisions and prepares, manages and implements the City's annual budgets and Capital Improvement Program. Carlos R. Fandino, Jr. has served as the City Administrator since 2016. Mr. Fandino previously worked for the City's Gas and Electric Department (now known as Vernon Public Utilities), serving in a variety of capacities, including as General Manager. Mr. Fandino previously served in the United States Marine Corps and is a Desert Storm/Desert Shield combat veteran. He obtained a Bachelor's degree in Business & Management from the University of Woodbury in Burbank, graduating Magna Cum Laude. Other key personnel responsible for management of the Water System include the Director of Financefrreaswer and the General Manager of Public Utilities. Scott Williams is the Director of Finance/Treasurer of the City. Mr. Williams has been with the City since 2019 and has over 20 years of financial management experience. Prior to coming to the City, Mr. -12- Williams served as the Finance Director and Administrative Services Officer for the City of Signal Hill, California, and in various financial management positions in both the public and private sector. Mr. Williams obtained a Bachelor's degree in Business Administration from The Master's University, an MBA from California State University, Monterey Bay, and a Doctorate in Public Administration from California Baptist University in Riverside, California. Mr. Williams is a member of the California Society of Municipal Finance Officers, the California Municipal Treasurers Association, the Association of Certified Fraud Examiners and the Institute of Management Accountants. Abraham Alemu is the General Manager of Public Utilities of the City. Mr. Alemu has been with the City since 1992. Mr. Alemu obtained a Bachelor's degree in Electrical Engineering from California State University, Los Angeles, and a Masters in Business Administration from Woodbury University. Mr. Alamo is a Registered Professional Engineer in California and a member of the Institute of Electrical and Electronics Engineers. Management Policies. The City has adopted several policies which are designed to ensure the prudent and effective management of City operations, including an investment policy and a debt management policy. Further information about each such policy is set forth below. Investment Policy. The City invests its funds in accordance with the City's investment policy (the `Investment Policy'), which was most recently amended on July 2, 2019. The Investment Policy sets forth the policies and procedures that are applicable to the investment of City funds and designates eligible investments. The Investment Policy also sets forth stated objectives, including the assurance of the safety of invested fonds by limiting credit and market risks, the maintenance of sufficient liquidity, compliance with law and the attainment of the best yield or returns on investments. Fonds are invested in the following order of priority: • Safety of Principal; • Liquidity; and • Yield. The City Council has delegated the authority to invest funds of the City to the City Treasurer, who most invest City funds in accordance with the prudent person standard under California Civil Code § 2261 et seq. The Investment Policy provides a number of permitted investment categories, including: (i) United States Treasury securities and other federal government securities with a maximum maturity of 5 years; (u) asset -backed securities with a maximum maturity of 5 years; (iii) certificates of deposit with a maximum maturity of 5 years (limited to 30"/• of the portfolio); (iv) bankers' acceptances with a maximum maturity of 180 days (limited 40% of the portfolio); (v) repurchase agreement with a maximum maturity of one year; (vi) money market mutual funds (limited to 20•/ of the portfolio); and (vii) the Local Agency Investment Fond of the State (limited to $50 million). As of June 30, 2019, the City had total moneys invested in the amount of $99,924,928 in permitted investments under the Investment Policy ([excluding] cash and capital reserves of the Water System). The City has not specifically allocated my portion of such amounts to the Water Enterprise Fond. See the caption "FINANCIAL INFORMATION —Available Cash" for information about available cash and capital reserves of the Water Enterprise Fund. The City Treasurer is required to provide a quarterly report to the City Administrator and the City Council detailing the City's investments, dates of raturity, amounts invested, current market value, rate of interest and other such information as may be required by the City Council. For additional information relating to the Investment Policy, see Note 12] to the City's audited financial statements set forth in Appendix A. aIT Debt Management Policy. The City's debt management policy addresses the matters that are required by California Government Code § 8855(i), including: (i) the purposes for which debt proceeds may be used; (ii) the types of debt that may be issued; (ui) the relationship of the debt to, and integration with, the City's capital improvement program or budget; (iv) policy goals related to the City's planning goals and objectives; and (v) the internal control procedures which ensure that the proceeds of each debt issuance are directed to their intended use. Business and Industry Commission. In July 2014, the City established the Vernon Business and Industry Commission to advise, assist and make recommendations to the City regarding ways to make the City more attractive to employees, businesses and investors while appropriately considering the needs and concerns of the residential communities within and in close proximity to the City. The Business and Industry Commission represents the consolidation of two previously existing Ad Hoc Advisory Committees created and appointed by the City Council, one on Electric Rates and the other on Business Development. The Commission is comprised of seven members from the following categories who am, appointed by the City Council: three City business representatives, two City real estate representatives, one employee of a business located in the City or who is a member of a labor union that represents workers at a business located in the City and one current City Council Member. The Business and Industry Commission meets quarterly to provide input and make recommendations to the City on a number of matters relating to or impacting business and industrial development with the City, including water rate adjustments. The input and recommendations provided by the Business and Industry Commission are not binding on the City. Prior Attempt to Disincorporate City; City Reform In December 2010, Assembly Bill 46 ("AB 46" ), an act to disincorporate the City and make it part of the unincorporated territory of the County, was introduced into the State Assembly. AB 46 stated that it was motivated by, among other things, a desire to eliminate alleged corrupt practices by City officials, including misuse of public funds and excessive salaries and concern with the close relationship between the City management and its relatively small number of residents. A companion bill, Assembly Bill 781 ("AB 781"), was also introduced which, among other things, would have transferred the Water System to a special district governed by the Board of Supervisors of the County. The enactment of AB 781 was dependent upon the enactment of AB 46. The City took the position that AB 46 violated the provisions of the State Constitution providing that a vote of the City electorate was necessary to repeal a city charter. Both bills were opposed by assay of the residents and businesses within the City as well as labor unions representing workers within the City. Although both bills were passed by the State Assembly, the bills were not approved by the State Senate and neither bill became law. In connection with the State Senate's consideration of AB 46 and AB 781, the City Council agreed to a reform program proposed by the State Senator for the senatorial district in which the City is located (the "De Leon Plan"). A key recommendation of the De Leon Plan was implemented in December 2011 when forma State Attorney General and County District Attorney John Van de Kamp was retained by the City to serve as the City's Independent Reform Monitor for a four-year term, commencing February 15, 2012. As part of this engagement, the Independent Reform Monitor evaluated and assessed the City's reform progress on a periodic basis and issued recommendations in semi-annual reports to the City. Since 2011, the City has implemented a variety of good governance reform measures. In November 2011, the City Council placed before the electorate a series of amendments to the City's charter to implement significant elements of the reform program. The amendments were overwhelmingly passed by the voters and are now in effect. in October 2013, the City Council adopted a personnel merit system to replace the City's former at -will employment system. The City's personnel policy and procedures manual provides for City staff salaries to be set based on comparable labor market data as pan of a periodic Citywide classification and compensation study, and the City believes that City salaries have been adjusted to a level that more closely reflects salaries for comparable positions in other cities in the State. Additionally, the selection process for -14- hiring the City's senior administration officials was revised and now utilizes professional search firms and interview panels. In September 2011, a week after the State Senate vote on AB 46, the Joint Legislative Audit Committee of the State Legislature requested that the Bureau of State Audits undertake an audit of the City and its Gas and Electric Department. The City fully cooperated with the Bureau of State Audits and, in September 2014, the Bureau of State Audits concluded that although a few of the recommendations were still in progress, no further follow-up responses from the City were requited at that time. In early 2016, the four-year term of the Independent Reform Monitor ended and was not renewed. Although the City is not aware of any further attempt to disincorporate the City or any audits or investigations, the City can provide no assurances that there will not be a future attempt to disincorporate the City or calls for additional reform of City governance. Should any future disincorporation attempts be successful, or should any future audits or investigations result in the identification or allegation of any impropriety, or should the City be required to implement additional reforms of its practices and procedures, the City cannot predict what effects, if any, such events would have on the City, its Water System or the 2020 Bonds. Employees As of June 30, 2019, the City had approximately 256 full-time equivalent employees, of whom approximately 14 worked solely on behalf of the Water System. Certain employees of the Public Utilities Department are represented by the International Brotherhood of Electrical Workers Local 47 (the "IBEWI and the Teamsters Local 911 (the "Teamsters"). Relations between the City and the IBEW are govemed by a memorandum of understanding which expires on June 30, 2022 and relations between the City and the Teamsters are governed by a memomndum of understanding which expires on June 30, 2022. Certain management, supervisory and professional employees are unrepresented. The City has never experienced a strike, slowdown or work stoppage. Employee Benefits Pension Obligations. Accounting and financial reporting by state and local government employers for defined benefit pension plans is governed by Governmental Accounting Standards Board ("GASB") Statement No. 68 ("GASB 69'). GASB 68 governs the accounting treatment of defined benefit pension plans, including how expenses and liabilities are calculated and reported by state and local government employers in their financial statements. GASB 68 includes the following components: (i) unfunded pension liabilities are included on the employer's balance sheet; (it) pension expense incorporates rapid recognition of actuarial experience and investment returns and is not based on the employer's actual contribution amounts; (iii) lower actuarial discount rates are required to be used for underfunded plans in certain cases for purposes of the financial statements; (iv) closed amortization periods for unfunded liabilities are required to be used for certain purposes of the financial statements; and (v) the difference between expected and actual investment returns will be recognized over a closed five-year smoothing period. GASB 68 affects the City's accounting and reporting requirements, but it does not change the City's pension plan funding obligations. The City participates in a Miscellaneous plan to fund pension benefits for employees who operate the Water System. The City's Miscellaneous plan is administered by the California Public Employees Retirement System ("CaIPERS'). CatPERS administers an agent multiple -employer public employee defined benefit pension plan for all of the City's full-time and certain part-time employees. Ca1PERS provides retirement, disability and death benefits to plan members and beneficiaries and acts w a common investment and administrative agent for participating public entities within the State, including the City. CalPERS plan benefit provisions and all other requirements am established by State statute and the City Council. City employees are subject to different benefit levels based on their hire date. Current benefit provisions for City employees are set forth below. CM OF VERNON CaIPERS Miscellaneous Pension Plan — Summary of Benefit Provisions Employees Hired On or Employees Hired Before After January 1, 2013 (Not January 1, 2013 Prior CalPEBS Members) Benefit Formula 2.7% @ age 55 2.0% @ age 62 Benefit Vesting 5 years of service 5 years of service Benefit Payments Monthly for life Monthly for life Minimum Retirement Age 50 52 Monthly Benefits as % of 2.0%- 2.7 % 1.0%, 2.5% Eligible Compensation Employee Normal Cost 8.0%I1I 5.75°/al2t Employer Normal Cost Rate 9.433% 9.433% M [Employees who were hired before January 1, 2013 are required to rake the full employee contribution.) [The City makes %ofthe required employee contribution fm employees who were hired before January I, 2013]. n� Employees who were hived on or after January I, 2013 who were not previomly CatPERS members are required to make the full employee contribution. Source: City. City employees who were hired on and after January 1, 2013 and who were not previously CalPERS members receive benefits based on a 2.0% at age 62 formula; such employees are required to make the full amount of required employee contributions themselves under the California Public Employees' Pension Reform Act of 2013 ("AB 340"), which was signed by the State Governor on September 12, 2012. AB 340 established a new pension fier: the 2.0% at age 62 formula, with a maximum benefit formula of 2.5% at age 67. Benefits for such participants are calculated on the highest average annual compensation over a consecutive 36-month period. Employees are required to pay at least 50% of the total normal cost rate. AB 340 also capped pensionable income for 2019 as noted below. Amounts are set annually, subject to Consumer Price Index increases, and retroactive benefits increases are prohibited, as are contribution holidays and purchases of additional non -qualified service credit. CITY OF VERNON Pensionable Income Caps for Calendar Year 2019 (AB 340 and Noo-AB 340 Employees) Employees Hired Before Employees Hired After January 1, 2013 January 1, 2013 fNon-AB 340 Employees) (AB 340 Employees) Maximum Pensionable Income $280,000 $149,016 Maximum Pensionable Income if also Participating in Social Security N/A $124,180 Source: City. Additional employee contributions, limits on pensionable compensation and higher retirement ages for new members as a result of the passage of AB 340 are expected to reduce the City's unfunded pension lability and potentially reduce City contribution levels in the long tens. The City is also required to contribute the actuarially determined remaining amounts necessary to fund benefits for its members. Employer contribution rates for all public employers are determined on an annual -16- basis by the CalPERS actuary and are effective on the July I following notice of a change in the rate. Total plan contributions are determined through the CalPERS annual actuarial valuation process. The total minimum required employer contribution is the sum of the plu's employer normal cost rate (expressed as a percentage of payroll) plus the employer unfunded accrued liability contribution amount (billed monthly). The normal cost rate is the annual cost of service accrual for the upcoming Fiscal Year of active employees. Required employer normal cost rates for Fiscal Year 2019 were 9.433 % for all benefit levels, and the required employer payment of the unfunded accrued liability was $2,397,908. Required employer normal cost rates for Fiscal Year 2020 are 10.862% for all benefit levels, and the required employer payment of the unfunded accrued liability is $2,852,713. The Miscellaneous plan contributions for Fiscal Years 2018 and 2019 were $8,713,902 and $8,8%,669, respectively. The City currently expects its annual required contribution for the Miscellaneous plan in Fiscal Year 2020 to be approximately 57,566,993. The share of such contributions which is attnbutable to the Water System is determined based an the proportion of Water Enterprise Fund payroll expenditures to payroll expenditures for all City employees who participate in the Miscellaneous plan. Such share was 8.0% in Fiscal Year 2019, and is expected to be approximately 8.4% in Fiscal Year 2020. The City's required contributions to CalPERS fluctuate each year and, as noted, include a normal cost component and a component equal to an amortized amount of the unfunded liability. Many assumptions are used to estimate the ultimate liability of pensions and the contributions that will be required to meet those obligations. The CalPERS Board of Administration has adjusted and may in the future further adjust certain assumptions used in the CalPERS actuarial valuations, which adjustments may increase the City's required contributions to CalPERS in future years. Accordingly, the City cannot provide any assurances that the City's required contributions to CaIPERS in furore years will not significantly increase (or otherwise vary) from any past or current projected levels of contributions. CalPERS earnings reports for Fiscal Years 2010 through 2019 report investment gains of approximately 13.3%, 21.7%, 0.1%, 13.2%, 18.41%, 2.40%, 0.60%, 11.2%, 8.6% and 6.7%, respectively. Future earnings performance may increase or decrease future contribution rates for plan participants, including the City. On December 21, 2016, the CalPERS Board of Administration voted to lower its discount rate from the current rate of 7.50% to 7.00%. Effmfive with its June 2017 Comprehensive Annual Financial Report, CalPERS reduced its discount rate to 7.15% and its investment rate of return to 7.15%. The discount rate for Fiscal Year 2020 is 7.00%. For public agencies such as the City, the new discount rate took effect July 1, 2017. Lowering the discount rate means that employers that contract with CalPERS to administer their pension plans will see increases in their normal costs and unfunded actuarial liabilities. Active members hired after January 1, 2013 will also see then contribution rates rise under AB 340. The reduction of the discount rate will result in average employer rate increases of approximately 1 % to 3% of normal cost as a percentage of payroll for most Miscellaneous retirement plans such as the City's plan. Additionally, many employers will see a 30 % to 40% increase in their current unfunded accrued liability payments (relative to the unfunded accrued liability payments projected in the June 30, 2015 valuation report) for miscellaneous pension plans. These payments are made to amortize unfunded liabilities over 20 years to bring pension funds to a fully funded status over the long-term. Portions of the above information are primarily derived from information that has been produced by CaIPERS, its independent accountants and its actuaries. The City has not independently verified such information and neither makes any representations nor expresses any opinion as to the accuracy of the information that has been provided by CaIPERS. The comprehensive annual financial reports of CaIPERS are available on CaIPERS' Internet website at www.calpers.ca.gov. The CaIPERS website also contains CaIPERS' most recent actuarial valuation reports -17- and other information that concerns benefits and other matters. The tertual reference to such Internet website is provided for convenience only. None of the information on such Internet "briar is incorporated by reference herein. The City cannot guarantee the accuracy of such information. Actuarial assessments are 'forward -looking - statements that reflect the judgment of the fiduciaries of the pension plans, and are based upon a variety of assumptions, one or more of which may not materialize or be changed in the future. The City's Miscellaneous plan had a total net pension liability of approximately 534,060,942 for the Fiscal Year ended June 30, 2018 and approximately $36,594,112 for the Fiscal Year ended June 30, 2019. The net pension liability is the difference between the total pension liability and the fair market value of pension assets. The City's total pension assets include funds that are held by Ce1PERS, and its net pension asset or liability is based on such amounts. [CONFIRM] [For Fiscal Years 2018 and 2019, the City incurred Miscellaneous plan pension expenses of $3,173,495 and $8,476,844, respectively.] A summary, of principal assumptions and methods used to determine the total pension liability for Fiscal Year 2019 is shown below. CITY OF VERNON Actuarial Assumptions for CAPERS Miscellaneous Pension Plan Actuarial Cost Method Entry Age Normal in accordance with the requirements of GASB 68 Asset Valuation Method Market Value of Assets Actuarial Assumptions: Discount Rate 7.15% inflation 2.75% Salary Increases Varies by entry age and service investment Rate of Return 7.50% net of pension plan investment and administrative expenses; includes projected inflation rate of 2.75% Mortality Rate Table(') Derived using Ce1PERS' membership data for all funds 0' The mortality table used was developed baud on CaIPERS-specific data. The table includes 20 years of mortality impmvemeats using Society of Actuaries Scale BB. Source: City. Changes in the net pension liability for the City's Miscellaneous plan in the most recent Fiscal Year for which information is available were as follows: CITY OF VERNON Changes in C21PERS Miscellaneous Pension Plan Net Pension Liability Increase/(Decrease) Told Phrn Fiduciary Net Pension Pension Lfabf6ty Net Position Liability/(Asset) Balance at June 30, 2017 $ 153,756,378 $ 119,695,436 $ 34,060,942 Balance at June 30, 2018 163,980,758 127,386.646 36,594,112 Net Changes for period from July 1, 2017 S 10,224,380 $ 7,691,210 $ 2,533,170 through June 30, 2018 Source: City. The table below presents the net pension liability of the City's Miscellaneous plan, calculated using the discount rate applicable to Fiscal Year 2019 (7.159/6), as well as what the net pension liability would be if it 1s- were calculated using a discount rate that is 1 percentage point lower (6.15%) or 1 percentage point higher (8.15%) than the Fiscal Yew 2019 rate: CITY OF VERNON Sensitivity of the CalPERS Miscellaneous Pension Plan Net Pension Liability to Changes in the Discount Rate Discount Rate - I % Applicable Discount Discount Rate +I % (6.15%) Rate (7.15%) (8.15%) Plan's Net Pension Liability/(Asset) $60,377,852 $36,594,112 $17,177,143 Source: City. The City's projections of Operation and Maintenance Costs under the caption "FINANCIAL INFORMATIONProjectedWater System Operating Results and Debt Service Coverage" do not assume unusual increases in CaIPERS contributions or other labor costs in the future. However, no assurance can be provided that such expenses will not increase significantly in the future. The City does not expect that any increased funding of pension benefits will have a material adverse effect on the ability of the City to pay the 2020 Bonds. For additional information relating to the City's CalPERS Miscellaneous pension plan, see Note [81 to the City's audited financial statements set forth in Appendix A. Post -Employment BeneJUs. In addition to the pension benefits that are described under the caption '—Pension Obligations," the City provides certain health cue benefits for retired employees and eligible dependents. Substantially all of the City's full-time employees who are eligible for pension benefits may become eligible for such other post -employment benefits. As of June 30, 2019, 256 employees meet these eligibility requirements and 116 retirees or their beneficiaries participate in the plan, with another 3 eligible to participate but not yet doing so. [Annual required contributions] of approximately $2,951,698 and $1,073,477, respectively, were recognized for post -employment health cue benefits in Fiscal Years 2018 and 2019. GASH Statement No. 75 ("GASH 75") requires governmental agencies to account for and report outstanding obligations and commitments related to post -employment benefits in essentially the same manner as for pensions. For the City, the reporting obligation began in Fiscal Year 2018. The City retained Van Iwaarden Associates (the "Actuarial Consultant") to calculate the City's post - employment benefits funding status. In a report dated November 15, 2019 (the "Report'), the Actuarial Consultant concluded that, as of Jane 30, 2019, the City's net liability for post -employment benefits was $23,100,129. The Actuarial Consultant also concluded that the City's actuarially determined contribution for Fiscal Year 2020 (the actuarial value of benefits earned during Fiscal Year 2020 plus costs to amortize the unfunded actuarial accrued liability, or "ADC") is $1,931,700. The share of such contribution which is attributable to the Water System is expected to be approximately 8.4% in Fiscal Yew 2020. Changes in the net liability for the City's post -employment benefit plan were as follows. -19- CITY OF VERNON Changes in Post -Employment Benefit Plan Liability Increase / (Decrease) Total Post -Employment Benefit Plan Liability Balance at June 30, 2018 $37,355,851 Balance at June 30, 2019 25,279,784 Net Changes for period (f12,076,067) from July 1, 2018 through Jose 30, 2019 source: City. Net Post -Employment Plan Fiducimy Benefit Plan Net Position Liability/(Asset) $1,057,267 $36,298,594 2,179,655 23,100,129 $1,122,388 ($13,198,455) The following table presents the net liability of the City's post -employment benefits plan, calculated using the discount rate applicable to Fiscal Year 2019 (6.50%), as well as what the net post -employment benefit liability would be if it were calculated using a discount rate that is I percentage point lower (5.50%) or 1 percentage point higher (7.5(r) than the Fiscal Year 2019 rate: CM OF VERNON Sensitivity of the Post -Employment Benefit Plan Net Liability to Changes in the Miscount Rate Discount Rate - l % Applicable Discount Discount Rate + J% (5.50%) Rate (6.50-1.) (7.50%) Plan's Net Liability/(Asset) $26,234,945 $23,100,129 $20,472,569 source: City. The City's projections of Operation and Maintenance Costs under the caption "FINANCIAL INFORMATION —Projected Water System Operating Results and Debt Service Coverage" do not assume unusual increases in post -employment benefit funding expenses in the future. However, future changes in funding policies and assumptions, including those related to assumed rates of investment retain and healthcare cost inflation, could trigger increases in the City's annual required contributions, and such increases could be material to the finances of the City. No assurance can be provided that such expenses will not increase significantly in the future. The City does not expect that any increased funding of post -employment benefits will have a material adverse effect on the ability of the City to pay the 2020 Bonds. For additional information relating to the post-eWloyment benefit plan, see Note (9] to the City's audited financial statements set forth in Appendix A. Budget Process The City prepares and adopts a budget on a modified accrual basis for each Fiscal Year which includes proposed expenditures and the means of financing such expenditures. Under the City's budget procedure, the City Administrator submits a proposed budget to the City Council for the Fiscal Year commencing the following July 1. Prim to June 30 of each year, a public hearing is held and public notice is disseminated to obtain public comments and the budget is legally enacted by the City Council through the passage of a resolution. As discussed under the caption "— General;' the City reached an agreement in mid-2019 to transition fire services, which are currently provided by the City's Fire Department, to the County of Los Angeles Fire -20- Department. As a result of the negotiations with the County of Los Angeles Fire Department and the significant adjustments to the City's budget arising from the outsourcing of fire services and the planned phaseout of the City's Fire Department, the City Council adopted the Fiscal Year 2020 budget on August 20, 2019, after the commencement of Fiscal Year 2020. City Insurance The City maintains liability insurance coverage for amounts up to $20,000,000, with a $2,000,000 self -insured retention. The City is self -insured for workers' compensation liabilities for amounts up to $1,000,000 per occurrence and maintains excess coverage of $50,000,000. The City maintains property insurance coverage for amounts up to $100,000,000, with a deductible of $25,000. Certain Water System components, including pipelines are not covered by property insurance. The City does not tarty earthquake coverage. See the captions "TIE WATER SYSTEM —Seismic Considerations" and "CERTAIN RISKS TO BONDHOLDERS —Natural Disasters." The City maintains directors and officers and employee dishonesty insurance coverage for amounts up to $2,000,000, with a $150,000 deductible. The City maintains pollution insurance coverage for amounts up to $5,000,000, with a $5,000,000 aggregate and a $50,000 self -insured retention. The City has not settled any claims that exceeded its insurance coverages in the past three years. The City can provide no assurance that it will maintain the above insurance coverage amounts while the 2020 Bonds are outstanding. See Appendix B under the caption "PARTICULAR COVENANTS — Insurance" for a description of insurance coverages that are required to be maintained while the 2020 Bonds are Outstanding. No Outstanding Senior or Parity Obligations Other than obligations which constitute Operation and Maintenance Costs, there are no debt or contractual obligations which are payable from Water System Revenues on a senior basis to, or on a parity with, the 2020 Bonds. The City bas entered into a Loan Agreement, dated as of May 16, 2019 (the "WRD Loan"), with The Water Replenishment District of Southern California ("WRD') to finance the cost of a new groundwater well. See the caption "THE WATER SYSTEM —Water Supply —Groundwater." Under the WILD Loan, which bears no interest, the City borrowed $1,500,000, to be repaid in quarterly installments through April 1, 2031. Although it is the City's practice to make payments on the WILD Loan from surplus Revenues of the Water System, the WRD Loan is payable from any City revenues and no Water System revenues are pledged to repayment. THE WATER SYSTEM General The City provides water service to approximately 238 industrial, 829 commercial and 38 residential and other customers as of June 30, 2019. The City's Water System includes approximately 244,000 linear feet of water mains, 3 booster stations and 8 reservoirs (one of which is elevated and one of which is below -21- ground) which provide total operational storage of approximately 16.375 million gallons (or approximately 50 acre feet). The City pumps groundwater from 8 wells which are located within the Central Groundwater Basin, an adjudicated groundwater basin. See the caption "—Water Supply —Groundwater." The City also purchases water imported from the State Water Project (the'SWP") at wholesale, and recycled water, from CBMWD, a member agency of MWD. See the captions "—Water Supply —Imported Water Supply" and "— Water Supply —Recycled Water," respectively. As discussed under the caption "—Water Supply--Croundwater," the City is currently constructing two new groundwater wells. Water Quality General. Groundwater that is pumped from City wells is generally of high quality and does not require extensive treatment prior to delivery to customers. The Public Utilities Department routinely submits groundwater samples to a third party laboratory for analysis in compliance with State law. The City also purchases treated potable water and recycled water from CBMWD. Such water does not require treatment prim to delivery to customers. PFAS. The State Water Resources Control Board (the "SWRCB") Division of Drinking Water (the "Division") has lowered the Notification Levels for Perfluorooctanoic acid ("PFOA') and Pertluorooctanesulfanic acid ("PFOS'J to 5.1 and 6.5 parts per trillion ("PPT'), respectively. Notification Levels are non -regulatory, precautionary health -based measures for concentrations of chemicals in drinking water that warrant notification and further monitoring and assessment. The City understands that the Division may also lower the Response Level for PFOA and PFOS from 70 PPT, combined, to about 10 to 12 PPT, each in early 2020. Response Levels are non -regulatory, precautionary health -based measures that are set at higher levels than Notification Levels and represent thresholds at which the Division recommends that water systems remove a water source from use or treat it. PFOA and PFOS are fluorinated organic chemicals which are part of a family of synthetic compounds referred to as per- and polyfluoroalkyl substances ("PFAS"). PFAS are water and lipid resistant and are useful for a variety of manufacturing processes and industrial applications. The City understands that recent technological advances have enabled water agencies to detect PFAS compounds at very low concentrations. No discernible traces of PFAS have been found in the City's groundwater sources to date. The City tested its wells for HAS under the UCMR3 (Unregulated Contaminant Monitoring Rule), resulting in a "non -detect" determination. The City does not anticipate that implementation of the proposed lower Response Level for PFAS would have a material adverse effect on the operation of the Water System or the costs thereof. The projected operating results which are set forth under the caption "FINANCIAL INFORMATION —Projected Water System Operating Results and Debt Service Coverage" reflect the City's current expectation that there will not be significant increases in water treatment or purchase costs to meet State regulations relating to PFAS. Water Supply The City's primary source of water is groundwater from City -owned wells. The City also purchases SWP water from CBMWD, a member agency of MWD. The Water System's goal is to minimize purchases of imported water from CBMWD, which is more expensive than groundwater produced from the City's wells. In addition, the City purchases recycled water from CBMWD. Each of these sources is described below. See Table 4 under the caption "—Historical Water Supply Sources and Usage" for historical information with respect to the amount of the City's water supply derived from each of such sources. 9ME Groundwater. The City's 8 groundwater wells have a combined production capacity of approximately 10.2 million gallons per day ("mgd"), which is sufficient to supply all of the current average daily demand within the Water System service area. The City's wells have depths between approximately 1,020 and 2,500 feet. The City's wells are located in the Central Groundwater Basin, which encompasses an area of approximately 250 square miles. The amount of groundwater that is held in the Central Groundwater Basin fluctuates depending upon precipitation, pumping demand and the availability of replenishment water. The City is currently in the process of constructing a new well (Well 22), which is expected to produce 2,000-3,000 gallons of water per minute (equivalent to 2.88-4.32 mgd). The City also plans to construct an additional well (Well 23) in Fiscal Year 2023, which is expected to produce 2,000-3,000 gallons of water per minute. The total cost to drill the two wells, which are expected to come online in 2021 and 2023, respectively, is estimated at $3,800,000. The City has entered into the WRD Loan in the amount of $1,500,000 to fund a portion of such costs. See the caption "TFIE CITY —No Outstanding Senior or Parity Obligations." 2020 Bond proceeds will also fund a portion of such costs. See the caption "PLAN OF FINANCEThe2020 Project." The construction of the new wells is expected to reduce the City's reliance on imported water to supply Water System customers, resulting in reduced Operation and Maintenance Costs given the fact that imported water is significantly more expensive than groundwater produced from City wells. See the subcaption "—Imported Water Supply." The Central Groundwater Basin is an adjudicated groundwater basin, the adjudication of which is overseen and administered pursuant to the terms of a judgment (the "Judgment") entered in the Superior Court of California, County of Los Angeles. The Judgment, which became effective in 1966 and which was amended in 2013, adjudicated groundwater rights for entities which represent over 75% of the groundwater pumping rights in the Central Groundwater Basin. The Judgment contains a physical solution to meet the requirements of water users having rights in or dependent upon the Central Groundwater Basin. Under the Judgment, as amended in 2013, the Central Groundwater Basin is administered by a Watermaster, which is composed of three bodies: (i) the Water Rights Panel; (ii) the Administrative Body; and (iii) the Storage Panel. The Water Rights Panel is made up of seven Central Groundwater Basin water rights holders. Six are elected by their representative group (with parties grouped based upon the amount of their pumping rights, votes being weighted by such rights) and one member is elected at large by all water rights holders (with one vote each). WRD, a special water replenishment district that was established in 1959 under the Water Code, serves as the Administrative Body. Its role as a component of the Waterrrrsster is to accept pumping reports and summarize records for review by the Water Rights Panel. WRD also collects Replenishment Assessments from groundwater pumpers and undertakes certain activities with the proceeds thereof, as detailed below. The Storage Panel consists of the Water Rights Panel and the WRD Board of Directors. The Judgment limits the amount of groundwater that each party to the Judgment can extract annually from the Central Groundwater Basin to such parry's "Allowed Pumping Allocation." The total pumping rights of all parties to the Judgment in the Central Groundwater Basin is 217,367 acre feet per year. In order to provide flexibility with respect to groundwater pumping, the Judgment allows a party to tarty over a portion (limited to the greater of (i) 60% of the parry's Allowed Pumping Allocation less amounts in storage in the Central Groundwater Basin; or (ii) 200/ of the party's Allowed Pumping Allocation) of such parry's unused pumping rights into succeeding years. The Judgment also allows a party to extract amounts in excess of its Allowed Pumping Allocation with approval from the Water Rights Panel, provided that over -extraction is made up over a period not to exceed five years. In addition, the Judgment permits parties to transfer pumping rights from year to year. -23- Pursuant to the Judgment, the City bas been allocated an Allowed Pumping Allocation of 7,539 acre feet per year. Over the last three Fiscal Years, the City has underproduced its available pumping rights, resulting in carryover for production in subsequent years. As of Jane 30, 2019, the City had a total of 4,136.86 of carryover. The District pays WRD a Replenishment Assessment in order to extract groundwater from the Central Groundwater Basin. The Replenishment Assessment, which is equal to $365 per acre foot of groundwater extracted for Fiscal Year 2020, is applied by WRD to the following purposes: (i) purchasing water for replenishment into the Central Groundwater Basin; (ii) financing capital projects and supporting debt service on WRD obligations; and (iii) removing contaminants from groundwater. As an adjudicated groundwater basin, the Central Groundwater Basin is not subject to the provisions of State Assembly Bill No. 1739 and Senate Bill Nos. 1168 and 1319 (collectively, the Sustainable Groundwater Management Act), a Statewide effort regulate groundwater which was enacted on September 16, 2014. Imported Water Supply. The imported water source for the City is CBMWD. CBMWD is a member agency of MWD and receives water through MWD. The imported water delivered to the City from CBMWD consists of SWP water from northern California and the Colorado River which is treated prior to delivery to the City. The City is entitled but not obligated to purchase water from CBMWD when available at rates that are determined by CBMWD's governing board CBMWD's rates are designed primarily to recover CBMWD's costs to purchase water from MWD. CBMWD also levies a surcharge above the rates that it pays MWD. The City's practice is to recover the costs of water purchased from CBMWD through the rates that the City charges Water System customers. See the caption "—Water System Rates and Chargu—General." The City currently pays CBMWD the following rates for imported water purchases: (i) a Tier I MWD rate of $1,078 per acre foot or a Tier 2 MWD rate of $1,165 per acre foot; (ii) a surcharge of $190 per acre foot; (iii) a charge of $11,582 per year, representing the City's share of a readiness -to -serve charge levied by MWD on CBMWD, together with a surcharge thereon imposed by CMBWD; (iv) a capacity charge of 54,150 per cubic feet per second per year; (v) a water meter service charge of $117 per cubic feet per second per month; and (vi) an annual fired meter charge of $2 per retail connection. The City, along with several other public agency customers of CBMWD, is currently engaged in litigation with CBMWD with respect to the above -described "retail meter charge" which the City and the other agencies allege has been improperly billed by CBMWD. The case, which is entitled City ojSignal Hill et at. v. Central Basin Municipal Water District et al, Case No. 19STCP03882 (Superior Court of California, County of Los Angeles), is a petition for Writ of Mandate and Complaint for Determination of Invalidity and Declaratory Relief and was filed on September 6, 2019. The City has paid certain amounts billed by CMBWD under protest and does not expect that an unfavorable outcome with respect to the dispute will result in the City becoming obligated to make additional payments to CBMWD, while a favorable outcome with respect to the dispute could make additional credits available to the City. CBMWD and MWD face various challenges in the continued supply of imported water to the City. A description of these challenges as well as a variety of other operating information with respect to CBMWD and MWD is included in certain disclosure documents prepared by CBMWD and MWD, respectively. CBMWD and MWD each have certain publicly available documents and have entered into certain continuing disclosure agreements pursuant to which they are contractually obligated for the benefit of owners of certain of thew respective outstanding obligations to file annual reports, notices of enumerated events as defined under Rule 15c2-12 adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as the same may be amended from time to time ("Rule 15c2-12'), and annual audited financial statements with the Municipal Securities Rulemaking Board. None of such information is incorporated into this Official -24- Statement by reference thereto, and the City makes no representation as to the accuracy or completeness of such information. NEITHER CBMWD NOR MWD HAVE ENTERED INTO ANY CONTRACTUAL COMMITMENT WITH THE CITY, THE TRUSTEE OR THE OWNERS OF THE 2020 BONDS TO PROVIDE ANY INFORMATION ABOUT CBMWD OR MWD TO THE CITY OR THE OWNERS OF THE 2020 BONDS. NEITHER CBMWD NOR MWD HAVE REVIEWED THIS OFFICIAL STATEMENT AND NEITHER CBMWD NOR MWD HAVE MADE REPRESENTATIONS OR WARRANTIES WITH RESPECT TO THE ACCURACY OR COMPLETENESS OF THE INFORMATION CONTAINED OR INCORPORATED HEREIN, INCLUDING INFORMATION WITH REGARD TO CBMWD AND MWD, RESPECTIVELY. NEITHER CBMWD NOR MWD IS CONTRACTUALLY OBLIGATED, AND NEITHER CBMWD NOR MWD HAVE UNDERTAKEN, TO UPDATE SUCH INFORMATION FOR THE BENEFIT OF THE CITY OR THE OWNERS OF THE 2020 BONDS TINDER RULE 15c2-12. Recycled Water. CBMWD purchases recycled water meeting the requirements of Title 22 of the California Code of Regulations which is produced by the County Sanitation Districts of Los Angeles County (the "Sanitation Districts') for resale to retail agencies such as the City. The source of the recycled water is tertiary treated wastewater from the Sanitation Districts' San lose Creek and Los Coyotes Water Reclamation Plants, which are located in Whittier and Cerritos, California, respectively. The City pays CBMWD a Cued rate in the current amount of 5759 per acre foot of recycled water. However, pursuant to an agreement with CBMWD, the City receives up to a $353 credit for each acre foot of recycled water purchased by the City. Currently, the City's sole recycled water customer is the Malburg Generating Station, a combined cycle natural gas -fired electrical generating plant located in the City. Seismic Considerations The City is located in a seismically active region. Significant faults are located near the City, including the Newport -Inglewood Fault. There is potential for destructive ground shaking during the occurrence of a major seismic event. In addition, land along fault lines may be subject to liquefaction during the occurrence of such an event. In the event of a severe earthquake, there may be significant damage to both property and infrastructure within the City, including the Water System, which may affect the City's ability to supply water to its customers. The City has an emergency response plan that would be implemented under such circumstances. Newer Water System facilities are designed to withstand earthquakes with minimal damage, as earthquake loads are taken into consideration in the design of project structures. The impact of lesser magnitude events is expected by the City to be temporary, localized and reparable. The Water System has never sustained major damage to its facilities or experienced extended incidences of service interruptions as a result of seismic disturbances. All facilities have been designed and constructed in compliance with the City's construction standards. The City does not maintain earthquake insurance on Water System facilities. See the captions `THE CITY —City Insurance" and "CERTAIN RISKS TO BONDHOLDERS —Natural Disasters." Drought Response State Orders. On January 17, 2014, after several years of below -average precipitation in the State, the State Governor declared a drought state of emergency (the "Declaration') with immediate effect. The Declaration encouraged local urban water suppliers, including the City, to implement their local water shortage contingency plans, and the City implemented Phase One of its plan in the wake of the Declaration. See the subcaption "—Water Shortage Contingency Plan" for a description of the City's plan. The Declaration also -25- required DWR and the SWRCB to craft and enforce numerous emergency regulations that were designed to reduce water usage and increase water supplies. For instance, a May 2015 SWRCB regulation required the City to effect a 12% reduction from its 2013 potable water usage. On May 18, 2016, the SWRCB adopted a revised regulation that gave water agencies the ability to establish their own conservation standards based on a "stress test" of supply reliability. By June 22, 2016, water agencies were required to submit self -certifications to the SWRCB demonstrating that they had sufficient supplies to withstand three additional years of severe drought. Any identified percentage gap between supplies and demands became the water agency's updated mandatory conservation target. The City's self -certification demonstrated that it had sufficient supplies to meet its projected demands, even if the State were to have endured three more years of drought Consequently, the City's mandatory conservation target was eliminated retroactive to June 1, 2016. On April 7, 2017, after significant improvement in water supply conditions across California, the Govemor issued Executive Order B-40-17, which rescinded mandatory conservation measures for most counties in the State (including the County). The City is currently operating under normal supply conditions, as described below under the caption —Water Shortage Contingency Plan." In 2018, the California Governor signed Senate Bill 606 and Assembly Bill 1668 into law. These bills relate to water conservation and drought planning and empower DWR and the SWRCB to adopt long-term standards on water use. The City is unable to predict the substance, timing or effect on the Water System of regulations implementing Senate Bill 606 and Assembly Bill 1668 or any future legislation with respect to water conservation. Wafer Shortage Contingency Plan. The City's water shortage contingency plan is set forth in Article VI of Chapter 25 of the City's Municipal Code. Under the City's plan, the City responds to a water shortage in stages (referred to as "Phase One; "'Phase Two" and "Phase Three") as follows, in each case subject to publication by the City of its determination of the applicable stage in a local newspaper and the mailing of notice thereof to Water System customers: • Under normal supply conditions, wasteful use of water (including washing down paved areas, allowing sprinkler irrigation to run off, operating decorative water features that do not recirculate water and irrigating landscapes between 10:00 a.m. and 5:00 p.m.) is prohibited, and water leaks most be repaired as soon as reasonably practicable. The City is currently operating under normal supply conditions. • Phase One is intended to be implemented when water supplies are expected to be curtailed by more than 20%. The restrictions applicable to normal supply conditions are in effect and irrigation with potable water is limited to three days per week between the hours of 6:00 p.m. and 6:00 a.m. only. In addition, water leaks most be repaired within 72 hours of notification by the City. • Phase Two is intended to be implemented when water supplies are expected to be curtailed by more than 30%. Irrigation with potable water is limited to two days per week (except between the months of November and March, when it is limited to one day per week) on a schedule established and posted by the City. In addition, water leaks most be repaired within 48 hours of notification by the City and customers are required to limit water use to 85% of the amount used during the corresponding billing period two years prior to the declaration of the Phase One stage. • Phase Three is intended to he implemented when water supplies are expected to be curtailed by more than 50%. Irrigation with potable water is prohibited, water leaks must be repaired within 24 hours of notification by the City and customers are required to limit water use to 75% of the amount used during the -26- corresponding billing period two years prior to the declaration of the Phase One stage. In addition, the City may require commercial and industrial businesses which use more than 100 acre feet of potable water per year to prepare a water conservation plan and submit quarterly progress reports with respect to compliance with such plan. The City's water shortage contingency plan authorizes the City to levy increasing fines for successive violations of the water restrictions and water rate penalties for excess water usage when restrictions are in place. The projected Water System operating results that are set forth under the caption "FINANCIAL INFORMATION—Pmjected Water System Operating Results and Debt Service Coverage" reflect the assumed continuation of normal supply conditions. The City does not currently expect that the implementation of its water shortage contingency plan in the future will have a material adverse effect on its ability to pay the 2020 Bonds from Net Revenues. As discussed under the caption "—Water System Rates and Charges," the City's rate structure consists of variable and fixed rate components. Decreased water consumption is partially onset by a decrease in related variable costs, while fixed water charges largely cover the Water System's fixed Operation and Maintenance Costs. In addition, the City has covenanted to set Water System rates and charges in amounts that it expects to be sufficient to pay the 2020 Bonds from Net Revenues. See the caption "SECURITY FOR THE 2020 BONDS —Rate Covenant." If a water shortage should arise again in the future, legal issues exist as to whether different California Water Code provisions or State regulations will be invoked to manage the allocation of water. Any curtailment pursuant to State orders could necessitate an increase in the City's Water System rates and charges. See the caption "CONSTITUTIONAL LIMITATIONS ON APPROPRIATIONS AND CHARGES — Proposition 218" for a discussion of certain restrictions on the City's ability to raise water rates. -27- k/k Basle §�} ¥4(4# fƒ| 2!&([ � ! - ) §k !!! }|82!]§ k RS62m �§� In �!§! The table below shows water sales Revenues by class of user for the last Fiscal Year. TABLES CITY OF VERNON WATER SYSTEM Water Sales Revenues]') by Class of User Fiscal Year 2019t�1 Water sales User Class Revenues Industrial $1,929,001 Commercial 6,378,969 Residential/Other 43,336 Recycled 446.812 Total $8,798,118 2'1 Excludes other Revenues such as meter installation charges, penalties, connection fees and miscellaneous income. See the caption "FINANCIAL INFORMATION —Historical Water System Operating Results and Debt Service Coverage." ar Reflects [unaudited] actual cash. Totals may not add due to mondmg. Source: City. Historical Water Supply Sources and Usage The table below summarizes the sources of water supply and deliveries to users in the City for the five most recent Fiscal Years. TABLE 4 CITY OF VERNON WATER SYSTEM Historical Water Supply Sources and Usage in Acre Feet(l) Local Imported Recycled Total Water Percentage Fiscal Year Water Waterlt' Waterlrl Liawpl Change 2015 5,640 879 825 7,344 N/A% 2016 5,647 862 787 7,296 (0.65) 2017 6,008 570 750 7,328 0.44 2018 5,839 454 616 6,909 (5.72) 2019 5,499 582 626 6,707 (2.92) 01 The numbers shown above diner from the historical water production numbers shown under the caption "—Historical Water System Connections and Production" because the numbers shown above reflect water losses. '2' Reflects purchases from CBMWD. See the caption" —Water Supply." '�1 Decreases in water usage reflect conservation and increased water use efficiency measures undertaken by the City's primarily industrial and commercial customer base. Source: City. Historic water sales Reveaues for the last five Fiscal Years based on the historic water usage set forth in the table above are set forth under the caption "FINANCIAL INFORMATION —Historic Water System Operating Results and Debt Service Coverage." IP2 Largest Water System Customers The table below shows the largest customers of the Water System for Fiscal Year 2019, as determined by Revenues generated. TABLE 5 CITY OF VERNON WATER SYSTEM Ten Largest Water System Customers Fiscal Year 2019 Percentage ojAnnual User Type of Business Revenues(l) Revenues Clougherty Packing Food Processing $1,046,035 11.89% Wimatex Fabric Dyeing 442,751 5.03 7-Up Bottling Co. Food Processing 381,373 4.33 Overbill Farm Inc. Food Processing 225,495 2.56 Pabco Paper Products Co. Building Materials 224,012 2.55 Fantasy Dyeing and Finishing Inc. Fabric Dyeing 186,359 2.12 A's Match Dyeing Co. Inc. Fabric Dyeing 185,596 2.11 Owens Illinois Inc. Container Packaging I68,508 1.92 The Union Ice Company Ice Manufacturing 168,146 1.91 Golden West Trading Food Processing 156,639 1.78 Total $3,184,914 36.20% Iu Rounded to the nearest dollar. ReOects unaudited actual results. Source: City. These customers accounted for approximately 36.20% of total water sales revenues of $8,798,118 (reflecting unaudited actual results) in Fiscal Year 2019. Water System Rates and Charges General. The Water System's rates and charges are set by the City Council and are not subject to the jurisdiction of, or regulation by, the California Public Utilities Commission or any other regulatory body. The City, however, is required to comply with the notice, hearing and majority protest provisions of Article MILD of the State Constitution, which is popularly known as Proposition 218. See the caption "CONSTITUTIONAL LIMITATIONS ON APPROPRIATIONS AND CHARGES —Proposition 218" for further information with respect to Proposition 218. The City's Public Utilities Department determines the adequacy of the charge structure for water service in the service area after full consideration of expected operations, maintenance, capital costs and capital repayment obligations of the Water System. The City Council currently sets water rates and charges at a level that it determines is sufficient to pay all Operation and Maintenance Costs of water production and water purchases (including the cost of imported water purchased from CBMWD as discussed under the caption "— Water Supply —Imported Water Soppy'), to recover operating expenses for the Water System, to pay debt service and to maintain appropriate reserves for the Water System. Current charges include a fixed service charge based on meter size and a commodity charge based on usage. The City is subject to certain covenants with respect to the 2020 Bonds which require the City to set Water System rates and charges in amounts that it expects to be sufficient to pay the 2020 Bonds from Net Revenues. See the caption `SECURITY FOR THE 2020 BONDS —Rate Covenant" -30- In 2019, the City retained a consultant to evaluate the Water System's rates and charges, resulting in the preparation of a detailed rate study in September 2019. On November 19, 2019, after a public hearing as required under Proposition 218, the City Council adopted a comprehensive rate plan for the Water System (the "Rate Plan") based upon the findings in the rate study, including Water System rate increases for calendar years 2020 through 2024. Among the goals of the Rate Plan was to increase the percentage of Operation and Maintenance Costs that are paid for from fixed monthly service charges (which are not dependent on water consumption) from approximately 30% to approximately 38 % in order to provide greater revenue stability to the Water System and more fully the Water System's fixed costs. In order to accomplish this goal, fixed water fates were doubled, as shown in Table 7 below under the subcaption "—User Charges" below. The Rate Plan remains in place as of the date hereof There is no assurance that the City Council will not repeal or modify such rate increases in the future or that the City's ratepayers will not approve an initiative to repeal or modify any increase in water rates and charges approved by the City Council. User Charges. The City adopts water rates and water service charges for the Water System by City Council action. The current water rate structure consists of a fixed monthly service charge that varies by meter size, a commodity rate, as well as certain other charges as described below. The table below summarizes the commodity rate and certain other water fates charged by the Water System for all customer types. TABLE 6 CITY OF VERNON WATER SYSTEM Water Rates 2019 Current Rare as of Rate as of Rate as of Rate as of Rare Type Rate Rate 722021 1/72022 1112023 11112024 Potable Water Consumption Ratef) $2.20600 $2.20600 $2.27000 $2.34000 $2.41000 $2.48000 Monthly Square Footage Chargdt) 0.00319 0.00364 0.00375 0.00386 0.00398 0.00410 Recycled Water Consumption Ratc(r) 1.74200 1.74200 N/A N/A N/A N/A r'r Per 100 cubic feet. The rate will be increased by approximately 3 % per aanum beginning in 2021 in accordance with the Rate Plan. trr Charged monthly per square foot ofbuildings or outside storage space. The charge was increased by approximately 14% in the current calendar year and will be increased by approximately 3% per aonum thereafter, all in accordance with the Rate Plan. o� Per 100 cubic feet. Recycled water notes ptimarily consist of a pass -through of the ones charged to the City by CBMWD. See the caption "—Water Supply —Recycled Water." See Footnote I to Table 13 ander the caption "FINANCIAL INFORMATION —Projected Water System Operating Results and Debt Service Coverage" for a description of the District's assumptions with respect to recycled water rates in Fiscal Years 2021 through 2024. Source: City. 5110 The table below summarizes the City's current monthly water availability charges by meter size. TABLE 7 CITY OF VERNON WATER SYSTEM Monthly Water Availability Chargeslt> Current Rate as of Rate as of Rate ar of Rate as of Meter Size 2019 Rate Rate 11112021 12/1022 11712023 1172024 5/8" S 8.23 S 16.46 S 16.95 $ 17.46 $ 17.98 S 18.52 3/4" 12.34 24.68 25.42 26.18 26.97 27.78 1" 20.57 41.14 42.37 43.64 44.95 46.30 1h" 41.15 82.30 84.77 87.31 89.93 92.63 2" 65.94 131.68 135.63 139.70 143.89 148.21 3" 123.45 246.90 254.31 261.94 269.80 277.89 4" 205.75 411.50 423.85 436.57 449.67 463.16 6" 411.50 823.00 847.69 873.12 899.31 926.29 8" 658.41 1,316.82 1,356.32 1,397.01 1,439.92 1,482.09 t'u Rates were doubled in the current calmdar year and will be increased by appmxim wly 3%per am an beginning in 2021 in sccordance with the Rate Plan. Source: City. Connection Charges. A water connection right most be purchased from the City by anyone who wishes to connect to the Water System. The connection fee is equal to the cost of water service installation. The fee varies per location based on various factors including size of service and complexity. Comparison to Nearby Service Providers The table below sets forth a comparison of the City's typical monthly water bill for an industrial and commercial user (reflecting usage of approximately 5,500 hundred cubic feet) to those of certain nearby water purveyors as of June 30, 2019. As shown in Table 2 under the caption '-Historical Water System Connections and Production," industrial and commercial users comprise over 96% of the Water System's customer base. TABLE 9 CITY OF VERNON WATER SYSTEM Comparative Rates Source: City. Average Monthly Water Service Provider Water Charge City of Vernon $12,623 City of Whittier 12,691 City of Downey 13,291 City of Cerritos 13,867 City of long Beach 17,269 City of Pico Rivera 18,288 City of Paramount 18,968 City of Lakewood 19,588 City of Glendale 21,343 City of Santa Fe Springs 24,191 City of South Gate 34,813 -32- Water System Billing and Collection Procedures Charges for water service are billed monthly on a consolidated bill together with electric services. If payment is not received 20 days after billing, a second notice will be delivered and a $10 fee will be assessed. Second notice billing statements are due IS days after delivery. After such time, a door hanger will be hand delivered to the service address and a $10 final notice fee will be assessed If payment is not received within 45 days, the City will deliver a disconnection notice and shut off water service; a $25 disconnection fee will also be assessed. Service will not be restored until all charges have been paid in full. The City is currently developing slight modifications to the foregoing procedure to reflect Senate Bill 998, recently adopted State legislation which applies to shutoffs of delinquent residential customers. As shown in Table 2 under the caption "—Historical Water System Connections and Production," the Water System has fewer than 40 residential connections. The City's rate of delinquency has historically been very low given the City's primarily industrial and commercial customer base. As of June 30, 2019, none of the City's customer accounts were delinquent. Future Water System Capital Improvements The City projects total capital improvements to the Water System of approximately $20.5 million over the current and next four Fiscal Years, including the 2020 Project. See the caption "PLAN OF FINANCE — The 2020 Project" The capital improvements which are scheduled to be undertaken in Fiscal Years 2020 through 2023 and described to the following table are expected to be financed by a combination of proceeds of the 2020 Bonds deposited in the Acquisition Fond (as specified under the caption "PLAN OF FINANCE —Estimated Sources and Uses") and Revenues remaining after payment of Water System obligations. The remaining capital improvements which are scheduled to be undertaken in Fiscal Year 2023 and the capital improvements which are scheduled to be undertaken in Fiscal Year 2024 and described in the following table are expected to be financed by Revenues remaining after payment of Water System obligations. The City does not expect to issue additional Bonds or enter into additional Contracts to finance such capital improvements. -33- CITY OF VERNON WATER SYSTEM Capital Improvement Plan C-Pad Pro%M Well 5 Dumm0on Well I I Ping, a Motm Eme 'Gmmlarm Well 11 WeR2011h ilitalim Emergn,Genemloron Well 20 Well 17 Rehabihtetim Well 22 Dulling a Cuing Wen 22 WelNod equipment New Welh Wellhud Enginmivg&CM New Wells Dulling & Cuing Carmumim Mevsgement Op... Melyais and Maen Plm Rev eo bm useemenla(&I MG) Elevated Tam Upgrdes (autmna6m) Upgrades for IOMG Rues (wtmmatim) Emergency Genemm m Well 22 Well 15 Rehab Emergency Genentmm Well IS Reservoir Derno eI Well 20 BPI, BP2, BP3 Enginecdng Duigo"' BPI Pump Motor Revel mcludiog lbht-wang"' Finagenry Genemm m BPI"' BP3 Pump and Motm Revamp including Rigbl-sizing^' BP2 Resmoir supply Redmdancy Rrydn Reemoin BP3 Design & Consmsdim"' BP2 Pump and Motm Revamp mchming Right-sian¢n Repairs Reservoir BP2 Duigo & Conshuelim''' Dock Dcmo n OE Clark Well 23 Dtllling end Cuing Well 23 Wellhud equipment Emmgeney Genenlmm Well 23 M Po Elemieal Upgrades SCADA Pilot Man Replaeemml Pmgnm Packe.l .hmge and Downey Rd Pipeline Extmeim Pump Have 2 Re"iit t Fence Replacement PP2 & Well 19 Aaaad Tohl Cum Wes Talal "' BP sands for Booner Plane sesame: City. F6esl Y. Fised Fn Fiscd Year Fk at Year £iecd Year 2029 2021 2022 2023 2021 S 125,000 150,000 300,000 550,000 300,000 600,000 2,050,000 I,W,M 215,000 S 115,000 155,000 155,000 3m,1100 lz000 250,000 S 250,000 300,000 500,000 300,000 lanco0 300,000 500,000 300,000 5m,m0 Im,000 O SOo'looO,W0 000,000 251,000 s 2zlo,ogo 966,909 S lo0,000 100'" 100,000 100,000 Im,000 om SOO." 250,OW 250,000 2m,w 2 0,000 OO 00,1100 ,w 0,000 30'M S ],65],000 S 3,500,000 1,101,000 $ 4,676,M $ 1570,m0 S 7,657,O00 $ II,I57,010 S 10.2611000 $ $ 19,911,999 S 20,501,999 -34- k Projected Water Supply Sources and Usage Projected water supply sources and deliveries for the current and next four Fiscal Years we set forth in the table below. TABLE II CITY OF VERNON WATER SYSTEM Projected Water Supply Sources and Usage in Acre Feet Local Imported Recycled Percentage Finn( Year Water Wahr01 WWcrr" Total Water Usages" Change 2020 5,846 715 586 7,147 6.56% 2021 6,058 360 548 6,966 (2.53) 2022 6,279 0 512 6,791 (2.51) 2023 6,142 0 479 6,621 (2.50) 2024 6,009 0 448 6,457 (2.48) Reflects purchases from CBh1WD. See the caption "—Water Supply." Decreases in pmjWcd water usage reflect the City's expectation of continued conservation and increased water use efficiency measures underWcrn by the City's primarily industrial and commercial customer base. Source: City. Projected water sales Revenues for the current and next four Fiscal Years based on the projected water usage set forth in the table above are set forth under the caption "FINANCIAL INFORMATION —Projected Water System Operating Results and Debt Service Coverage." FINANCIAL INFORMATION Financial Statements A copy of the most recent audited financial statements (the "Financial Statements') of the City and Vernon Public Utilities prepared by the City's accountant, [Vasquez & Company LLP, Glendale, California] (the "Audkor") are set forth in Appendix A. The Auditor's letters dated [_ 2020] are set forth therein. The Financial Statements should be read in their entirety. The Auditor has not reviewed or audited this Official Statement. The audited financial statements of the City are included for reference only. No moneys of the City (including but not limited to General Fund moneys) except Water System Revenues are pledged to the repayment of the 2020 Bonds. The summary operating results that are contained under the caption "—Historical Water System Operating Results and Debt Service Coverage" are derived from the Financial Statements and audited financial statements for prior Fiscal Years (excluding certain non -cash items and after certain other adjustments), and are qualified in then entirety by reference to such statements, including the notes thereto. The City accounts for moneys received and expenses paid in accordance with generally accepted accounting principles applicable to public entities ("GAAP'). In certain cases, GAAP requires or permits moneys that are collected in one Fiscal Year to be recognized as revenue in a subsequent Fiscal Yea and requires or permits expenses that are paid or incurred in one Fiscal Yew to be recognized as expenses in a subsequent Fiscal Year. See Note I to the Financial Statements that are set forth in Appendix A. Except as otherwise expressly noted herein, all financial information that has been derived from the City's audited financial statements reflects the application of GAAP. -36- The Water System of the City is accounted for as within the Vernon Public Utilities Fund, a proprietary fund type (enterprise fund). In governmental accounting, enterprise funds are used to account for operations that are financed and operated in a manner similar to private business enterprises, where the intent is that the costs (expenses, including depreciation) of providing goods or services to the general public on a continuing basis are to be financed or recovered primarily through user charges, or where periodic determination of revenues earned, expenses incurred and/or net income is deemed appropriate for capital maintenance, public policy, management control, accountability or other purposes. Proprietary funds are accounted for using the "economic resources" measurement focus and the accrual basis of accounting. Under the accrual basis of accounting, revenues are recognized in the period in which they are earned while expenses are recognized in the period in which the liability is incurred. Proprietary funds distinguish operating revenues and expenses from nonopemting items. Operating revenues, such as charges for services, result from exchange transactions associated with the principal activity of the fund. Exchange transactions are those in which each party receives and gives up essentially equal values. Nonopemting revenues, such as subsidies and investment earnings, result from noncxchunge transactions or ancillary activities. Operating expenses include the cost of sales and services and administra ive expenses. All expenses which do not meet this definition (other than depreciation, a nonoash item which is not reflected in this Official Statement) are reported m non -operating expenses. Available Cash As of December 31, 2019, the Water System had approximately $6,023,430 in available cash reserves. This amount is equivalent to approximately 270 days of Operation and Maintenance Costs. The Water System also had approximately $7,992,695 in reserves that are currently allocated to future capital projects but can be reallocated to other purposes in the City's discretion. Historical Water System Operating Results and Debt Service Coverage The table below is a summary of operating results of the Water System for the last five Fiscal Years. The results have been derived from unaudited actual results for Fiscal Year 2019, the Financial Statements and prior audited financial statements of the City but exclude certain non -cash items which are not included as Revenues or Operation and Maintenance Costs and include certain other adjustments. The table has not been reviewed or audited by the City's Auditor. TABLE 12 CITY OF VERNON WATER SYSTEM Historical Operating Results (Fiscal Year Ended June 30) 2015 2016M 2017 2018 2019A31 Rcyenues Charges for Services $9,079,272 $8,042,095 $9,905,108 $9,392.914 S9,345,044 Investment Income - - - 1,796 - Other Revenues") 13.468 Total Revenues $9,078,272 $8,042.095 $8,805,109 $9.394,610 $9,358,512 Operation and Maintenance Cos&n Cost of Sales $6.550.220 S6.501.438 $6,723,125 S7.861.I03 S8.125.108 Total Operation and Maintenance Costs $ 6,550,220 $ 6,501,439 $ 6,723,125 $ 7,861.103 $ 8,125,108 Net Revenues $1,528,052 $1,540,657 $2,081,983 S 1,533,507 $1,233,404 m Includes legal settlement proceeds and oNer miscellaneous revenu . m Operation and Maintenance Costs [do not include] GASB 68 accounting entries, which are non -cash ite ns. There is not a linear correlative relatiooahip between GASB 68 accounting entries and the City's amoral pension contribution,; because GASB 68 -37- accounting entries are based on assumptions by CalPERS which vary annually. See the caption "]HE CITY —Employee Benefits —Pension Obligations" for a description of GASH 68. Reflects unaudited actual Fiscal Year 2019 results. Somme: City. Projected Water System Operating Results and Debt Service Coverage The projected operating results for the Water System for the current and next four Fiscal Years are set forth in the table below, reflecting certain significant assumptions concerning future events and circumstances. The financial forecast represents the City's estimate of projected financial results based upon its judgment of the probable occurrence of future events, including that the City's water shortage contingency plan (as described under the caption "THE WATER SYSTEM —Drought Response Water Shortage Contingency Plan') will not be in effect and assumptions set forth in the footnotes to the table set forth below. All of such assumptions are material to the development of the City's financial projections, and variations in the assumptions may produce substantially different financial results. Actual operating results achieved during the projection period may vary from those presented in the forecast and such variations may be material. See the caption "CERTAIN RISKS TO BONDHOLDERS —Accuracy of Assumptions." TABLE 13 CITY OF VERNON WATER SYSTEM Projected Operating Results (Fiscal Year Ending June 30) Revenues Charges for Servicesol Investment Income(2) Other Revenues Total Revenues Operation and Mature nance Costs Cast of Sales") Total Operation and Maintenance Costs Net Revenues Debt Service 2020 Bonds' Total Debt Service' Debt Service Coverage' Revenues Remaining After 1020 2021 2022 2023 2024 $9,476,500 $9,906,000 $10,202,000 $10,507,000 $10,921,000 53,100 54,000 55,000 56,000 57,000 $9,529,600 S9,960,000 $10,257,600 $10,563,000 $101878,IX10 118,350,975 $8,010.626 $8,327.000 $8,659,000 $9,003.000 $8,350,975 $9,010,626 $8,327,000 $8,658,000 $9,003,000 S 1,178,625 $ 1,949,374 $ 1,930,000 $ 1,905,000 S 1,975,000 SL $ S S S $ S $ It $ Payment of Debt Service' S $ $ $ $ (') Reflects adopted rate increases sat forth in she Rate Plan, See the caption "THE WATER SYSTEM —Water System Rates and Charges —User Charges." Also reflects the following projected recycled water rates: $1.81359, $1.88706, S1.96281 and $2.04316 per hundred cubic fear in Fiscal Mean 2021 through Fiscal Year 2024, respectively. 0) Reflects pr jetted investment earnings of 2% per arm on Water System res. Ol Reflects projected Operation Operation and Maintenance Costs as erves ec tomb in the water rate study that supported the Rate Plan. Somme: City. Preltedsary, aubjeer 1. change. ptjg CONSTITUTIONAL LEWTATIONS ON APPROPRIATIONS AND CHARGES Article MIR Article XIIIB of the State Constitution limits the annual appropriations of the State and of any city, county, school district, authority, special district or other political subdivision of the State to the level of appropriations of the particular governmental entity for the prior fiscal year, as adjusted for changes in the cost of living and population. The "base year' for establishing such appropriation limit is the 1978-79 State fiscal year and the limit is to be adjusted annually to reflect cbanges in population and consumer prices. Adjustments in the appropriations limit of an entity may also be made if: (a) the financial responsibility for a service is transferred to another public entity or to a private entity; (b) the financial source for the provision of services is transferred from taxes to other revenues; or (c) the voters of the entity approve a change in the limit for a period of time not to exceed four years. Appropriations that are subject to Article XI1[B; generally include the proceeds of taxes levied by or for the State or other entity of local govemment, exclusive of certain State subventions, refunds of taxes and benefit payments from retirement, unemployment, insurance and disability insurance funds. "Proceeds of taxes" include, but are not limited to, all tax revenues and the proceeds to an entity of government from: (i) regulatory licenses, user charges, and user fees (but only to the extent that such proceeds exceed the cost reasonably borne by the entity in providing the service or regulation); and (ii) the investment of tax revenues. Article XQIB includes a requirement that if an entity's revenues in any year exceed the amounts that are permitted to be spent, the excess would have to be returned by revising tax rates or fee schedules over the subsequent two years. Certain expenditures are excluded from the appropriations limit, including payments of indebtedness that were existing or legally authorized as of January 1, 1979, or of bonded indebtedness thereafter approved by the voters, and payments that are required to comply with court or federal mandates which without discretion require an expenditure for additional services or which unavoidably make the provision of existing services more costly. The City is of the opinion that its charges for Water Service do not exceed the costs that it reasonably bears in providing such service and therefore are not subject to the limits of Article XIIB. See the caption "SECURITY FOR THE 2020 BONDS —Rate Covenant" for a description of the City's covenant to set rates and charges for the Water Service. Proposition 218 General. An initiative measure entitled the "Right to Vote on Taxes Act" (the 'Initiative") was approved by the voters of the State at the November 5, 1996 general election. The Initiative added Articles XUIC and XUID to the State Constitution. According to the'"ritle and Summary' of the Initiative prepared by the State Attorney General, the Initiative limits "the authority of local governments to impose taxes and property -related assessments, fees and charges." Ardek MUD. Article XfI1D defines the terms "fee" and "charge" to mean "any levy other than an ad valorem tax, a special tax or an assessment, imposed by an agency upon a parcel or upon a person as an incident of property ownership, including user fees or charges for a property -related service." A "property -related service" is defined as "a public service having a direct relationship to property ownership." Article XUm further provides that reliance by an agency on any parcel map (including an assessor's parcel map) may be considered a significant factor in determining whether a fee or charge is imposed as an incident of property ownership. Article XflID requires that any agency which imposes or increases any property -related fee or charge must provide written notice thereof to the record owner of each identified parcel upon which such fee or -39- charge is to be imposed and most conduct a public hearing with respect thereto. The proposed fee or charge may not be imposed or increased if a majority of owners of the identified parcels file written protests against it. As a result, because fees for water service are a "fee" or "charge" as defined in Article XIIID, the local govemmem's ability to increase such fees or charges may be limited by a majority protest. In addition, Article XIIID includes a number of limitations that are applicable to existing fees and charges, including provisions to the effect that: (a) revenues that are derived from the fee or charge may not exceed the funds which are required to provide the property -related service; (b) such revenues may not be used for any purpose other than that for which the fee or charge was imposed; (c) the amount of a fee or charge that is imposed upon any parcel or person as an incident of property ownership may not exceed the proportional cost of the service attributable to the parcel; and (d) no such fee or charge may be imposed for a service unless that service is actually used by, or immediately available to, the owner of the property in question. Properly -related fees or charges based on potential or future use of a service are not permitted. Based upon the California Court of Appeal decision in Howard Jarvis Taxpayers Association v. City of Los Angeles, 85 Cal. App. 4th 79 (2000), which was denied review by the State Supreme Court, it was generally believed that Article XIIID did not apply to charges for water and wastewater services that are "primarily based on the amount consumed" (i.e., metered water or wastewater rates), which had been held to be commodity charges related to consumption of the service, not property ownership. The State Supreme Court ruled in Bighorn -Desert I iew Water Agency v. Verjil, 39 Cal. 4th 205 (2006) (the 'Bighorn Case'), however, that fees for ongoing water service through an existing connection were properly -related fees and charges. The Court specifically disapproved the holding in Howard Jarvis Taxpayers Association v. City of Los Angeles that metered water rates are not subject to Proposition 218. The City complied with the notice, hearing and protest procedures in Article XIED, as further explained by the State Supreme Court in the Bighorn Case, with respect to the water rate increases that were approved on December 10, 2019. See the caption "THE WATER SYSTEMWaterSystem Rates and Charges." On April 20, 2015, the California Court of Appeal, Fourth District, issued an opinion in Capistrano Taxpayers Association, Inc. v. City of San Juan Capistrano, 235 Cal. App. 4th 1493 (2015) (the "SAC Case") upholding tiered water rates under Proposition 218 provided that the tiers correspond to the actual cast of famishing service at a given level of usage. The opinion included a finding that the City of San Juan Capistrano did not attempt to calculate the actual costs of providing water at various tier levels. The City does not expect the decision in the SIC Case to affect its rate structure. The City's current rate structure does not include fiers. The City believes that its current water rates comply with the requirements of Proposition 218 because they arc cost -based and expects that any future water rate increases will comply with Proposition 218's procedural and substantive requirements to the extent applicable thereto. Article XHIC. Article XIIIC provides that the initiative power may not be prohibited or otherwise limited m matters of reducing or repealing any local tax, assessment, fee or charge and that the power of initiative to affect local taxes, assessments, fees and charges is applicable to all local governments. Article X TIC does not define the terms "local tax," "assessment," "fee" or "charge," so it was unclear whether the definitions set forth in Article XMD referred to above are applicable to Article XIIIC. Moreover, the provisions of Article XIBC are not expressly limited to local taxes, assessments, fees and charges imposed after November 6, 1996. On July 24, 2006, the State Supreme Court held in the Bighorn Case that the provisions of Article XIBC applied to rates and fees charged for domestic water use. In the decision, the Court noted that the decision did not address whether an initiative to reduce fees and charges could override statutory rate setting obligations. On November 15, 2018, the California Court of Appeal, Third District (the "Third District"), issued an opinion in Wilde v. City ofDunsmuir (2018) 29 Cal.App.Sth 158 (the "Wilde Case') holding that taxpayers have the right under the Initiative to place a referendum on the ballot and vote on whether to repeal a city's water rates. The Wilde Case concerned increases in water rates to fond new water storage and delivery projects of the city (rather than to fond general operations of a water system) which the court concluded were AO- legislative in nature and therefore subject to referendum. The City has reviewed the Wilde Case decision and determined that the decision does not directly impact the City and its water rate structure. The City notes that the Third District also in 2019 issued an opinion in Howard Jarvis Taxpayer Association v. Amador Water Agency (2019) 36 Cal.App.Sth 279 holding that ratepayers cannot place a referendum on the ballot to vote on repeal of the agency's water rams. This split in opinion has been appealed to the State Supreme Court, where it is awaiting review. In any event, the City does not believe that Article XMC! grants to the voters within the City the power (whether by initiative under Article XHIC or otherwise, or by referendum, which is not authorized under Article XIHC) to repeal or reduce rates and charges for the Water Service in a manner that would interfere with the contractual obligations of the City or the obligation of the City to maintain and operate the Water System. However, there can be no assurance as to the availability of particular remedies adequate to protect the Beneficial Owners of the 2020 Bonds. Remedies that are available to Beneficial Owners of the 2020 Bonds in the event of a default by the City are dependent upon judicial actions which are often subject to discretion and delay and could prove both expensive and time-consuming to obtain. So long as the 2020 Bonds are held in book -entry form, DTC (or its nominee) will be the sole registered owner of the 2020 Bonds and the rights and remedies of the 2020 Bond Owners will be exercised through the procedures of DTC. Proposition 26 On November 2, 2010, voters in the State approved Proposition 26. Proposition 26 amends Article XHIC of the State Constitution to expand the definition of "lax" to include "any levy, charge, or exaction of any kind imposed by a local government" except the following: (a) a charge imposed for a specific benefit confered or privilege granted directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of conferring the benefit or granting the privilege; (b) a charge imposed for a specific government service or product provided directly to the payor that is not provided to those not charged, and which does not exceed the reasonable costs to the local government of providing the service or product; (c) a charge imposed for the reasonable regulatory costs to a local government for issuing licenses and permits, performing investigations, inspections, and audits, enforcing agricultural marketing orders, and the administrative enforcement and adjudication thereof; (d) a charge imposed for entrance to or use of local government property, or the purchase, rental or lease of local government property; (e) a fine, penalty or other monetary charge imposed by the judicial branch of government or a local government as a result of a violation of law; (t) a charge imposed as a condition of property development; and (g) assessments and property -related fees imposed in accordance with the provisions of Article XIm. Proposition 26 applies to charges imposed or increased after November 2, 2010 and provides that the local government bears the burden of proving by a preponderance of the evidence that a levy, charge, or other exaction is not a tax, that the amount is no more than necessary to cover the reasonable costs of the governmental activity, and that the manner in which those costs are allocated to a payor bear a fair or reasonable relationship to the payor's burdens on, or benefits received from, the governmental activity. The City believes that its water rates and charges meet the exception that is described in clause (g) above and are not taxes under Proposition 26. Future Initiatives Articles XM, XHIC and XIm and Proposition 26 were adopted as measures that qualified for the ballot pursuant to the State's initiative process. From time to time other initiatives could be proposed and adopted affecting the City's revenues or ability to increase revenues. CERTAIN RISKS TO BONDHOLDERS The following information, in addition to the other matters that are described in this Official Statement, should be considered by prospective investors in evaluating the 2020 Bonds. However, the following does not purport to be comprehensive, definitive or an exhaustive listing of risks and other 41- considerations that may be relevant to making an investment decision with respect to the 1020 Bonds. In addition, the order in which the following information is presented is not intended to reflect the relative importance of any such risks. ff any risk factor materializes to a sufficient degree, it alone could delay or preclude payment of principal of or interest on the 2020 Bonds. Limited Obligations The obligation of the City to pay the 2020 Bonds is a limited obligation of the City and is not secured by a legal or equitable pledge or charge or lien upon any property of the City or any of its income or receipts, except the Revenues. The obligation of the City to pay the 2020 Bonds does not constitute an obligation for which the general credit or taxing power of the City is pledged. Accuracy of Assumptions To estimate the revenues that will be available to pay debt service on the 2020 Bonds, the City has made certain assumptions with regard to the rates and charges to be imposed in future years, the expenses associated with operating the Water System and the interest rate at which funds will be invested. The City believes these assumptions to be reasonable, but to the extent that any of these assumptions fail to materialize, the Net Revenues available to pay debt service on the 2020 Bonds will, in all likelihood, be less than those projected herein. See the caption "FINANCIAL INFORMATION —Projected Water System Operating Results and Debt Service Coverage." The City may choose, however, to maintain compliance with the rate covenant that is set forth in the Indenture in part by means of contributions from the Rate Stabilization Fund or other available reserves or resources. In such event, Net Revenues may generate amounts which are less than 115% of Debt Service in any given Fiscal Year. See the captions "SECURITY FOR THE 2020 BONDS — Rate Stabilization Fund" and "SECURITY FOR THE 2020 BONDS —Rate Covenant" System Demand There can be no assurance that the demand for water service will occur as described in this Official Statement. Reductions in demand could require an increase in rates or charges in order to comply with the rate covenant. Demand for water services could be reduced as a result of hydrological conditions, conservation efforts (including in response to drought), an economic downturn or other facmrs. See the caption "THE WATER SYSTEM —Water System Rates and Charges" and "—Accuracy of Assumptions." System Expenses There can be no assurance that the City's expenses will be consistent with the descriptions in this Official Statement. Operation and Maintenance Costs may vary with labor costs (including costs related to pension liabilities), treatment costs, regulatory compliance costs, increased costs to access groundwater due to land subsidence or falling water tables, increased imported water purchase costs and other factors. Increases in expenses could require an increase in rates or charges in order to comply with the rate covenant. See the caption "SECURITY FOR THE 2020 BONDS —Rate Covenant" Limited Recourse on Default If the City defaults on its obligation to pay the principal of and interest on the 2020 Bonds, the Trustee has the right to declare the total unpaid principal of the 2020 Bonds, together with the accrued interest thereon to be immediately due and payable. However, in the event of a default and such acceleration, there can be no assurance that the City will have sufficient funds to pay the accelerated amounts due on the 2020 Bonds from Net Revenues. -42- Rate -Setting Process under Proposition 218 Proposition 218, which added Articles XBIC and XIIB7 to the State Constitution, affects the City's ability to maintain existing rates and impose rate increases, and no assurance can be given that future rate increases will not encounter majority protest opposition or be challenged by initiative action authorized under Proposition 218. In the event that future proposed rate increases cannot be imposed as a result of majority protest or initiative, the City might thereafter be unable to generate Net Revenues in the amounts required by the Indenture to pay the 2020 Bonds. The City believes that its current water rates approved by the City Council were effected in compliance with the public hearing and majority protest provisions of Proposition 218. See the caption "CONSTITUTIONAL LIMITATIONS ON APPROPRIATIONS AND CHARGES — Proposition 218." Statutory and Regulatory Compliance Laws and regulations governing the treatment and delivery of water are enacted and promulgated by federal, State and local government agencies. Compliance with these laws and regulations is and will continue to be costly, and, as more stringent standards are developed, such costs will likely increase. Claims against the Water System for failure to comply with applicable laws and regulations could be significant. Such claims may be payable from assets of the Water System or from other legally available sources. In addition to claims by private parties, changes in the standards for public agency water systems such as that operated by the City may also lead to administrative orders issued by federal or State regulators. Form compliance with such orders could also impose substantial additional costs on the City. No assurance can be given that the cost of compliance with such laws, regulations and orders would not adversely affect the ability of the City to generate Net Revenues sufficient to pay the 2020 Bonds. Natural Disasters The occurrence of any natural disaster in the City, including, without limitation, fire, earthquake, landslide, land subsidence, high winds, drought or flood, could have an adverse material impact on the economy within the City, the Water System and the revenues available for the payment of the 2020 Bonds. Portions of the Water System may be at risk of damage or destruction from unpredictable seismic activity. The City is not required to maintain earthquake insurance under the Indenture, and does not currently maintain such insurance. See the caption "THE CITY —City Insurance." The occurrence of natural disasters in the City's service area could result in substantial damage to the Water System which, in turn, could substantially reduce revenue generated by the Water System and affect the ability of the City to pay the 2020 Bonds. The City maintains liability insurance for the Water System and property casualty insurance for certain portions of the Water System However, there can be no assurance that specific losses will be covered by insurance or, if covered, that claims will be paid in full by the applicable insurers. Furthermore, as described under the caption' f1IE CITY —City Insurance," significant portions of the Water System, including subsurface pipelines, are not covered by property casualty insurance. Damage to such portions of the Water System as a result of natural disasters would result in uninsured losses to the City. Cybersecurity The City relies on computers and technology to conduct its operations. The City and its departments face cyber threats from time to time including, but not limited to, hacking, viruses, malwme and other forms of technology attacks. Recently, there have been significant cyber security incidents affecting municipal agencies, including a freeze affecting computer systems of the City of Atlanta, an attack on the City of Baltimore's 911 system, an attack on the Colorado Department of Transportation's computers and an attack -43- that resulted in the temporary closure of the Port of Los Angeles' largest terminal. To date, there have been no significant cybemtfacks on the City's computer systems. The City employs a multi -level cyber protection scheme that includes firewalls, anti -virus software, anti-spam/malware software, intrusion protection and domain name system filtering software. The City also contracts with third party vendors to monitor and augment internal monitoring of the City's computer systems. To date, the City has not experienced an attack on its computer operating systems. However, there can be no assurance can be given that the City's security and operational control measures will be successful in guarding against all cyber threats and attacks. The results of any attack on the City's computer and technology could negatively impact the City's operations, and the costs related to such attacks could be substantial. Limitations on Remedies The ability of the City to comply with its covenants under the Indenture and to generate Net Revenues in amounts that are sufficient to pay principal of and interest on the 2020 Bonds may be adversely affected by actions and events outside of the control of the City or actions taken (or not taken) by voters, property owners, taxpayers or persons obligated to pay assessments, fees and charges. See the caption "CONSTITUTIONAL LIMITATIONS ON APPROPRIATIONS AND CHARGES —Proposition 218." Furthermore, the remedies available to the owners of the 2020 Bonds upon the occurrence of an event of default under the Indenture are in many respects dependent upon judicial actions which are often subject to discretion and delay and could prove both expensive and time consuming to obtain. In addition to the limitations on remedies contained in the Indenture, the rights and obligations under the Indenture may be subject to bankruptcy, insolvency, reorganization, arrangement, fraudulent conveyance, moratorium and other laws relating to or affecting creditors' rights, to the application of equitable principles, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against cities in the State. The opinion to be delivered by Bond Counsel concurrently with the issuance of the 2020 Bonds will be subject to such limitations, and the various other legal opinions to be delivered concurrently with the issuance of the 2020 Bonds will be similarly qualified. See Appendix C. In the event that the City fails to comply with its covenants under the Indenture or fails to pay principal of and interest on the 2020 Bonds, there can be no assurance as to the availability of remedies adequate to protect the interest of the holders of the 2020 Bonds. In addition, usual equity principles my limit the specific enforcement under State law of certain remedies, as my the exercise by the United States of America of the powers delegated to it by the federal Constitution, and the reasonable and necessary exercise, in certain exceptional situations, of the police power inherent in the sovereignty of the State and its governmental bodies in the interest of serving a significant and legitimate public purpose. Bankruptcy proceedings, or the exercise of powers by the federal or state government, if initiated, could subject the owners of the 2020 Bonds to judicial discretion and interpretation of their rights in bankruptcy or otherwise, and consequently my entail risks of delay, limitations or modification of then rights. Remedies may be limited because the Water System serves an essential public purpose. Loss of Tax Exemption In order to maintain the exclusion from gross income for federal income tax purposes of interest on the 2020 Bonds, the City has covenanted in the Indenture to comply with the applicable requirements of the Internal Revenue Code of 1986, as amended (the "Code'), and not to take any action or fail to take any action if such action or failure to take such action would adversely affect the exclusion from gross income of interest on the 2020 Bonds under Section 103 of the Code. Interest on the 2020 Bonds could become includable in gross income for purposes of federal income taxation retroactive to the date of issuance of such 2020 Bonds as a result of acts or omissions of the City in violation of this or other covenants in the Indenture applicable to the 2020 Bonds. The 2020 Bonds are not subject to redemption or any increase in interest rates should an event of taxability occur and will remain outstanding until maturity or prior redemption in accordance with the provisions of the Indenture. See the caption "TAX MATTERS." C_! Secondary Market There can be no guarantee that there will be a secondary market for the 2020 Bonds or, if a secondary market exists, that the 2020 Bonds can be sold for any particular price. Occasionally, because of general market conditions or because of adverse history or economic prospects connected with a particular issue, secondary marketing practices are suspended or terminated. Additionally, prices of issues for which a market is being made will depend upon then prevailing circumstances. Such prices could be substantially different from the original purchase price. Parity Obligations The Indenture permits the City to enter into additional Contracts and issue additional Bonds which are payable from Net Revenues on a parity with the 2020 Bonds, subject to the terms and conditions set forth therein. The entry into of additional Contracts or the issuance of Bonds could result in reduced Net Revenues available to pay the 2020 Bonds. The City has covenanted to maintain Debt Service coverage of 115%, as further described under the caption "SECURITY FOR THE 2020 BONDS —Additional Indebtedness." Climate Change The State has historically been susceptible to wildfires and hydrologic variability. As greenhouse gas emissions continue to accumulate in the atmosphere as a result of ecommuc activity, climate change is expected to intensify, increasing the frequency, severity and timing of extreme weather events such as coastal storm surges, drought, wildfires, floods and heat waves, and raising sea levels. The form fiscal impact of climate change on the City is difficult to predict, but it could be significant and it could have a material adverse effect on the Water System's finances by requiring greater expenditures to counteract the effects of climate change or by changing the business and activities of Water System customers. Rate Covenant Not a Guarantee The 2020 Bonds are payable from Net Revenues of the Water System See the caption "SECURITY FOR TBE 2020 BONDS." The City's ability to pay debt service on the 2020 Bonds depends on its ability to generate Net Revenues at the levels required by the Indenture. Although the City has covenanted in the Indenture to impose rates and charges as more particularly described under the caption "SECURrFY FOR THE 2020 BONDS —Rate Covenant," and although the City expects that sufficient Revenues will be generated through the imposition and collection of such rates and charges, there is no assurance that the imposition and collection of such rates and charges will result in the generation of Net Revenues in amounts that are sufficient to pay the 2020 Bonds. Among other matters, the availability of and demand for water and changes in law and government regulations could adversely affect the amount of Revenues realized by the City. APPROVAL OF LEGAL PROCEEDINGS The valid, legal and binding nature of the 2020 Bonds is subject to the approval of Stradling Yocca Carlson & Rauth, a Professional Corporation, acting as Bond Counsel. The form of such legal opinion is attached hereto as Appendix C, and such legal opinion will be attached to each 2020 Bond. Certain legal matters will be passed upon for the City by Shadling Yocea Carlson & Routh, a Professional Corporation, as Disclosure Counsel, and by the City Attorney, for the Underwriter by its counsel, Norton Rose Fulbright US LLP, and for the Trustee by its counsel. YI11 YIHVYDTI At the time of delivery of and payment for the 2020 Bonds, the City will certify substantially to the effect that there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any -45- court, regulatory agency, public board or body, pending or, to the knowledge of the City, threatened against the City affecting the existence of the City or the titles of its directors or officers to their respective offices or seeking to restrain or to enjoin the sale or delivery of the 2020 Bonds, the application of the proceeds thereof in accordance with the Indeatme, or in any way contesting or affecting the validity or enforceability of the 2020 Bonds, the Indenture, or any action of the City contemplated by any of said documents, or in any way contesting the completeness or accuracy of this Official Statement or any amendment or supplement thereto, or contesting the powers of the City or its authority with respect to the 2020 Bonds or any action of the City contemplated by any of said documents, nor to the knowledge of the City, is there any basis therefor. Y 1n:46 ry■Isl tRl In the opinion of Stiadling Yocca Carlson & Rauth, a Professional Corporation, Newport Beach, California, Bond Counsel, under existing statutes, regulations, rulings and judicial decisions, and assuming the accuracy of certain representations and compliance with certain covenants and requirements described herein, interest (and original issue discount) on the 2020 Bonds is excluded from gross income for federal income tax purposes and is not an item of tax preference for purposes of calculating the federal alternative minimum tax imposed on individuals. In the further opinion of Bond Counsel, interest (and original issue discount) on the 2020 Bonds is exempt from State of California personal income tax. Bond Counsel's opinion as to the exclusion from gross income for federal income tax purposes of interest (and original issue discount) on the 2020 Bonds is based upon certain representations of fact and certifications made by the City and others and is subject to the condition that the City comply with all requirements of the Code that most be satisfied subsequent to the issuance of the 2020 Bonds to assure that interest (and original issue discount) on the 2020 Bonds will not become includable in gross income for federal income tax purposes. Failure to comply with such requirements of the Code might cause interest (and original issue discount) on the 2020 Bonds to be included in gross income for federal income tax purposes retroactive to the date of issuance of the 2020 Bonds. The City has covenanted to comply with all such requirements. In the opinion of Bond Counsel, the difference between the issue price of a 2020 Bond (the first price at which a substantial amount of the 2020 Bonds of a maturity is to be sold to the public) and the stated redemption price at maturity of such 2020 Bond constitutes original issue discount. Original issue discount accrues under a constant yield method, and original issue discount will accrue to a Beneficial Owner before receipt of cash attributable to such excludable income. The amount of original issue discount deemed received by a Beneficial Owner will increase the Beneficial Owner's basis in the applicable 2020 Bond. The amount of original issue discount that ammes to the Beneficial Owner of a 2020 Bond is excluded from the gross income of such Beneficial Owner for federal income tax purposes, is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals, and is exempt from State of California personal income tax. The amount by which a 2020 Bond Owner's original basis for determining loss un sale or exchange in the applicable 2020 Bond (generally, the purchase price) exceeds the amount payable on maturity (or on an earlier call date) constitutes amortizable bond premium, which most be amortized under Section 171 of the Code; such amortizable bond premium reduces the 2020 Bond Owner's basis in the applicable 2020 Bond (and the amount of tax-exempt interest received with respect to the 2020 Bonds), and is not deductible for federal income tax purposes. The basis reduction as a result of the amortization of bond premium may result in a 2020 Bond Owner realizing a taxable gain when a 2020 Bond is sold by the Owner for an amount equal to or less (under certain circumstances) than the original cost of the 2020 Bond to the (honer. Purchasers of the 2020 Bonds should consult their own tax advisors m to the treatment, computation and collateral consequences of amortizable bond premium. The IRS has initiated an expanded program for the auditing of tax-exempt bond issues, including both random and targeted audits. It is possible that the 2020 Bonds will be selected for audit by the IRS. It is also possible that the market value of the 2020 Bonds might be affected as a result of such an audit of the 2020 A6- Bonds (or by an audit of similar municipal obligations). No assurance can be given that in the course of an audit, as a result of an audit, or otherwise, Congress or the IRS might not change the Code (or interpretation thereof) subsequent to the issuance of the 2020 Bonds to the extent that it adversely affects the exclusion from gross income of interest (and original issue discount) on the 2020 Bonds or then market value. SUBSEQUENT TO THE ISSUANCE OF THE 2020 BONDS THERE MIGHT BE FEDERAL, STATE OR LOCAL STATUTORY CHANGES (OR JUDICIAL OR REGULATORY CHANGES TO OR INTERPRETATIONS OF FEDERAL, STATE OR LOCAL LAW) THAT AFFECT THE FEDERAL, STATE OR LOCAL TAX TREATMENT OF THE 2020 BONDS INCLUDING THE IMPOSITION OF ADDITIONAL FEDERAL INCOME OR STATE TAXES BEING IMPOSED ON OWNERS OF TAX- EXEMPT STATE OR LOCAL OBLIGATIONS, SUCH AS THE 2020 BONDS. THESE CHANGES COULD ADVERSELY AFFECT THE MARKET VALUE OR LIQUIDITY OF THE 2020 BONDS. NO ASSURANCE CAN BE GIVEN THAT SUBSEQUENT TO THE ISSUANCE OF THE 2020 BONDS STATUTORY CHANGES WILL NOT BE INTRODUCED OR ENACTED OR JUDICIAL OR REGULATORY INTERPRETATIONS WILL NOT OCCUR HAVING THE EFFECTS DESCRIBED ABOVE. BEFORE PURCHASING ANY OF THE 2020 BONDS, ALL POTENTIAL PURCHASERS SHOULD CONSULT THEIR TAX ADVISORS REGARDING POSSIBLE STATUTORY CHANGES OR JUDICIAL OR REGULATORY CHANGES OR INTERPRETATIONS, AND THEIR COLLATERAL TAX CONSEQUENCES RELATING TO THE 2020 BONDS. Bond Counsel's opinions may be affected by actions taken (or not taken) or events occurring (or not occurring) after the date hereof. Bond Counsel has not undertaken to determine, or to inform any person, whether any such actions or events are taken or do occur. The Indenture and the Tax Certificate relating to the 2020 Bonds permit certain actions to be taken or to be omitted if a favorable opinion of Bond Counsel is provided with respect thereto. Bond Counsel expresses no opinion as to the effect on the exclusion from gross income of interest (and original issue discount) for federal income tax purposes with respect to any 2020 Bond if any such action is taken or omitted based upon the advice of counsel other than Stradling Yocca Carlson & Rauth, a Professional Corporation, Although Bond Counsel has rendered an opinion that interest (and original issue discount) on the 2020 Bonds is excluded from gross income for federal income tax purposes provided that the City continue to comply with certain requirements of the Code, the ownership of the 2020 Bonds and the accrual or receipt of interest (and original issue discount) on the 2020 Bonds may otherwise affect the tax liability of certain persons. Bond Counsel expresses no opinion regarding any such tax consequences. Accordingly, before purchasing any of the 2020 Bonds, all potential purchasers should consult their tax advisors with respect to collateral tax consequences relating to the 2020 Bonds. Should interest (and original issue discount) on the 2020 Bonds become includable in gross income for federal income tax purposes, the 2020 Bonds are not subject to early redemption and will remain outstanding until maturity or until redeemed in accordance with the Indenture. A copy of the proposed form of opinion of Bond Counsel is attached hereto as Appendix C. RATING The City expects that S&P Global Ratings, a Standard & Poor's Financial Services LLC business ("S&P"), will assign the 2020 Bonds the rating of "U". There is no assurance that any credit rating that is given to the 2020 Bonds will be maintained for any period of time or that a rating may not be lowered or withdrawn entirely by S&P if, in the judgment of S&P, circumstances so warrant. Any downward revision or withdrawal of a rating may have an adverse effect on the market price of the 2020 Bonds. The rating reflects only the views of S&P, and an explanation of the significance of such rating may be obtained from S&P. Generally, a rating agency bases its ratings on the information and materials famished to it (which may include -47- information and material from the City that is not included in this Official Statement) and on investigations, studies and assumptions of its own. The City has covenanted in a Continuing Disclosure Agreement to file notices of any rating changes on the 2020 Bonds with EMMA. See the caption "CONTINUING DISCLOSURE" and Appendix E. Notwithstanding such covenant, information relating to rating changes on the 2020 Bonds may be publicly available from the rating agencies prior to such information being provided to the City and prior to the date by which the City is obligated to file a notice ofrating change. Purchasers of the 2020 Bonds are directed to the rating agencies and their respective websites and official media outlets for the most current ratings with respect to the 2020 Bonds after the initial issuance of the 2020 Bonds. In providing a rating on the 2020 Bonds, S&P may have performed independent calculations of coverage ratios using its own internal formulas and methodology, which may not reflect the provisions of the Indenture. The City makes no representations as to any such calculations, and such calculations should not be construed as a representation by the City as to past or future compliance with any financial covenants, the availability of particular revenues for the payment of debt service or for any other purpose. MUNICIPAL ADVISOR The City has retained BLX Group LLC as municipal advisor (the "Municipal Advisor") in connection with the issuance of the 2020 Bonds. The Municipal Advisor bas not undertaken to make an independent verification or to assume responsibility for the accuracy, completeness, or fairness of the information contained in this Official Statement. The Municipal Advisor is an independent advisory fom and is not engaged in the business of underwriting, trading or distributing municipal or other public securities. I1101LdNPIliYIV0el The 2020 Bonds will be purchased by J.P. Morgan Securities LLC (the "Underwriter"), pursuant to a purchase contract, dated the date hereof (the "Purchase Contract"), by and between the City and the Underwriter. Under the Purchase Contract, the Underwriter has agreed to purchase all, but not less than all, of the 2020 Bonds for an aggregate purchase price of $ (representing the principal amount of the 2020 Bonds, less an Underwriter's discount of $ , plusAess a net original issue premium/discount of $__—). The Purchase Contract provides that the Underwriter will purchase all of the 2020 Bonds if any are purchased, the obligation to make such a purchase being subject to certain terms and conditions set forth in the Purchase Contract, the approval of certain legal matters by counsel and certain other conditions. The initial public offering prices stated on the inside cover page of this Official Statement may be changed from time to time by the Underwriter. The Underwriter may offer and sell the 2020 Bonds to certain dealers (including dealers depositing 2020 Bonds into investment trusts), dealer banks, banks acting as agents and others at prices lower than said public offering prices. The Underwriter has entered into negotiated dealer agreements (each, a "Dealer Agreement') with each of Charles Schwab & Co., Inc. ("CS&Co:) and LPL Financial LLC ("LPL") for the retail distribution of certain securities offerings at the original issue prices. Pursuant to each Dealer Agreement, each of CS&Co. and LPL may purchase 2020 Bonds from the Underwriter at the original issue price less a negotiated portion of the selling concession applicable to any 2020 Bonds that such firm sells. The Underwriter and its affiliates me full service financial institutions engaged in various activities, which may include securities trading, commercial and investment banking, financial advisory, investment management, principal investment, hedging, financing and brokerage activities. The Underwriter and certain of its affiliates have, from time to time, performed, and may in the future perform, various investment banking services for the City, for which they received or will receive customary fees and expenses. -48- In the ordinary course of their various business activities, the Underwriter and its affiliates may make or hold a broad array of investments and actively trade debt and equity securities (or related derivative securities) and financial instruments (which may include bank loans and/or credit default swaps) for their own account and for the accounts of their customers and may at any time hold long and short positions in such securities and instruments. Such investment and securities activities may involve securities and instruments of the City. CONTINUING DISCLOSURE The City has covenanted in a Continuing Disclosure Agreement, dated as of March 1, 2020, by and between the City and The Bank of New York Mellon Trust Company, N.A., as dissemination agent (the "Dissemination Agent") for the benefit of the holders and Beneficial Owners of the 2020 Bonds to provide certain financial information and operating data relating to the City by not later than April 1 following the end of the City's Fiscal Year (currently its Fiscal Year ends on June 30) (the "Annual Report"), commencing on April 1, 2020 with the report for the Fiscal Year ended June 30, 2019 (provided that the first Annual Report will consist solely of this Official Statement), and to provide notices of the occurrence of certain enumerated events. The Annual Report and the notices of enumerated events will be filed by the City with EMMA, which is maintained on the Internet at http://emma.msrb.org/. The specific nature of the information to be contained in the Annual Report and the notices of enumerated events is set forth in Appendix E. These covenants have been made in order to assist the Underwriter in complying with subsection (b)(5) of Rule 15c2-12 adopted by the Securities and Exchange Commission (the "Rule"). [DISCLOSURE RE PRIOR COMPLIANCE TO COME]. In order ensure compliance with its continuing disclosure undertakings under the Rule in the future, the City has appointed the Dissemination Agent to coordinate, on behalf of the City, the preparation and filing of Annual Reports by the City. FINANCIAL INTERESTS The fees being paid to the Underwriter, Bond Counsel, Disclosure Counsel and counsel to the Underwriter are contingent upon the issuance and delivery of the 2020 Bonds. MISCELLANEOUS Insofar as any statements made in this Official Statement involve matters of opinion or of estimates, whether or not expressly stated, they are set forth as such and not as representations of fact. No representation is made that any of such statements made will be realized. Neither this Official Statement nor any statement which may have been made verbally or in writing is to be construed as a contract with the Owners of the 2020 Bonds. The execution and delivery of this Official Statement have been duly authorized by the City. CITY OF VERNON By City Administrator -49- APPENDIX A FINANCIAL. STATEMENTS The following pages include audited financial statements of the City and Vernon Public Utilities for the most recent Fiscal Year. The audited financial statements of the City are included for reference only. No moneys of the City (including but not limited to General Fund moneys) except Water System Revenues are pledged to the repayment of the 2020 Bonds. A-1 "T7 821 11 ka 7 SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE The following is a summary of certain provisions of the Indenture which are not described elsewhere. This summary does not purport to be comprehensive and reference should be made to the Indenture for a full and complete statement of the provisions thereof. [TO COME FROM BOND COUNSEL] B-1 APPENDIX C FORM OF OPINION OF BOND COUNSEL Upon issuance of the 2020 Bonds, Stradling Yocca Carlson & Routh, a Professional Corporation, Bond Counsel, proposes to render its final approving opinion in substantially the followingfir m: March_, 2020 City of Vemon Vemon, California Re: City of Vernon Water System Revenue Bonds, 2020Series A Members of the City Council We have examined a certified copy of the record of the proceedings of the City of Vernon (the 'City) relative to the issuance of the $ City of Vemon Water System Revenue Bonds, 2020 Series A (the "2020 Bonds"), dated the date hereof, and such other information and documents as we consider necessary to render this opinion. In rendering this opinion, we have relied upon certain representations of fact and certifications made by the City, the initial purcbaser of the 2020 Bonds and others. We have not undertaken to verify through independent investigation the accuracy of the representations and certifications relied upon by us. The 2020 Bonds use being issued pursuant to an Indenture of Trust, dated as of March 1, 2020 (the "Indenture'), by and between the City and The Bank of New York Mellon Trust Company, N.A., as trustee (the —rnastec"). The 2020 Bonds mature on the dates and in the amounts referenced in the Indenture. The 2020 Bonds are dated thew date of delivery and bear interest at the rates per antrum referenced in the Indenture. The 2020 Bonds are registered in the form set forth in the Indenture. Based on our examination as Bond Counsel of existing law, certified copies of such legal proceedings and such other proofs as we deem necessary to render this opinion, we are of the opinion, as of the date hereof and under existing law, that: 1. The proceedings of the City show lawful authority for the issuance and sale of the 2020 Bonds under the laws of the State of California now in force, and the Indenture has been duly authorized, executed and delivered by the City. Assuming due authorization, execution and delivery by the Trustee, as appropriate, the 2020 Bonds and the Indenture are valid and binding obligations of the City enforceable against the City in accordance with their terms. 2. The Indenture creates a valid pledge of and lien and charge upon the Revenues and certain amounts held under the Indenture to secure the payment of the principal of and interest on the 2020 Bands. The obligation of the City to make the payments of principal of and interest on the 2020 Bonds from Net Revenues (as such term is defined in the Indenture) is an enforceable obligation of the City and does not constitute an indebtedness of the City in contravention of any constitutional or statutory debt limit or restriction. 3. Under existing statutes, regulations, mlings and judicial decisions, and assuming the accuracy of certain representations and compliance with certain covenants and requirements described herein, interest (and original issue discount) on the 2020 Bonds is excluded from gross income for federal income tax purposes and is not an item of tax preference for purposes of calculating the federal alternative minimum tax imposed on individuals. 4. Interest (and original issue discount) on the 2020 Bonds is exempt from State of California personal income tax. C-1 5. The difference between the issue price of a 2020 Bond (the first price at which a substantial amount of the 2020 Bonds of a maturity is to be sold to the public) and the stated redemption price at maturity with respect to such 2020 Bond constitutes original issue discount. Original issue discount accrues under a constant yield method, and original issue discount will accrue to a 2020 Bond Owner before receipt of cash attributable to such excludable income. The amount of original issue discount deemed received by a 2020 Bond owner will increase the 2020 Bond Owner's basis in the applicable 2020 Bond. The amount of original issue discount that accrues to the 2020 Bond Owner is excluded from the gross income of such Owner for federal income in purposes, is not an item of tax preference for purposes of calculating the federal alternative minimum tax imposed on individuals or corporations and is exempt from State personal income tax. 6. The amount by which a 2020 Bond Owner's original basis for determining loss on sale or exchange in the applicable 2020 Bond (generally, the purchase price) exceeds the amount payable on maturity (or on an earlier call date) constitutes amortizable bond premium, which must be amortized under Section 171 of the Internal Revenue Code of 1986, as amended (the "Code"); such amortizable bond premium reduces the 2020 Bond Owner's basis in the applicable 2020 Bond (and the amount of tax-exempt interest received), and is not deductible for federal income tax purposes. The basis reduction as a result of the amortization of 2020 Bond premium may result in a 2020 Bond Owner realizing a taxable gain when a 2020 Bond is sold by the Owner for an amount equal to or less (under certain circumstances) than the original cost of the 2020 Bond to the Owner. Purchasers of the 2020 Bonds should consult their own tax advisors as to the treatment, computation and collateral consequences of amortizable bond premium. The opinions expressed herein as to the exclusion from gross income of interest (and original issue discount) on the 2020 Bonds are based upon certain representations of fact and certifications made by the City and are subject to the condition that the City comply with all requirements of the Code that must be satisfied subsequent to the issuance of the 2020 Bonds to assure that such interest (and original issue discount) on the 2020 Bonds will not become includable in gross income for federal income tax purposes. Failure to comply with such requirements of the Code might cause interest (and original issue discount) on the 2020 Bonds to be included in gross income for federal income tax purposes retroactive to the date of issuance of the 2020 Bonds. The City has covenanted to comply with all such requirements. The opinions expressed herein may be affected by actions taken (or not taken) or events occurring (or not occurring) after the date hereof We have not undertaken to determine, or to inform any person, whether any such actions or events are taken or do occur. Our engagement ends as of the date of issuance of the 2020 Bonds. The Indenture and the Tax Certificate relating to the 2020 Bonds permit certain actions to be taken or to be omitted if a favorable opinion of Bond Counsel is provided with respect thereto. No opinion is expressed herein as to the effect on the exclusion from gross income of interest (and original issue discount) on the 2020 Bonds for federal income tax purposes with respect to any 2020 Bond if any such action is taken or omitted based upon the opinion or advice of counsel other than ourselves. Other than expressly stated herein, we express no other opinion regarding tax consequences with respect to the 2020 Bonds. The opinions expressed herein are based upon our analysis and interpretation of existing laws, regulations, rulings and judicial decisions and cover certain matters not directly addressed by such authorities. We call attention to the fact that the rights and obligations under the Indenture and the 2020 Bonds are subject to bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws affecting creditors' rights, to the application of equitable principles if equitable remedies are sought, to the exercise of judicial discretion in appropriate cases and to limitations on legal remedies against public agencies in the State of California. Our opinion is limited to matters governed by the laws of the State of California and federal law. We assume no responsibility with respect to the applicability or the effect of the laws of any other jurisdiction. We express no opinion herein as to the accuracy, completeness or sufficiency of the Official Statement relating in the 2020 Bonds or other offering material relating to the 2020 Bonds and expressly disclaim any duty to advise the owners of the 2020 Bonds with respect to matters contained in the Official Statement. Respectfully submitted, C-2 V 0 9 31,111 0Ar INFORMATION CONCERNING OTC The information in this section concerning OTC and DTC's book -entry only system has been obtained from sources that the City believes to be reliable, but the City takes no responsibilityfor the completeness or accuracy thereof The following description of the procedures and record keeping with respect to beneficial ownership interests in the 2010 Bonds, payment of principal, premium, if any, accreted value, if any, and interest on the 2020 Bonds to DTC Participants or Beneficial Owners, confirmation and transfers of beneficial ownership interests in the 2020 Bonds and other related transactions by and between DTC, the DTC Participants and the Beneficial Owners is based solely on information provided by DTC. The Depository Trust Company ("DTC"), New York, NY, will act as securities depository for the 2020 Bonds. The 2020 Bonds will be issued as fully -registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully -registered 2020 Bond will be issued for each amual maturity of the 2020 Bonds, each in the aggregate principal amount of such annual maturity, and will be deposited with DTC. DTC, the world's largest securities depository, is a limited -purpose trust company organized under the New York Banking Law, a `banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant in the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC's participants ("Direct Patticipants") deposit with DTC. DTC also facilitates the post -trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book -entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly -owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). DTC is rated AA+ by Standard & Poor's. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at wwwAtec.com. Purchases of 2020 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the 2020 Bonds on DTC's records. The ownership interest of each actual purchaser of each 2020 Bonds (`Beneficial Owner") is in tam to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the 2020 Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive bonds representing their ownership interests in 2020 Bonds, except in the event that use of the book -entry system for the 2020 Bonds is discontinued. To facilitate subsequent transfers, all 2020 Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of 2020 Bonds with DTC and thew registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the 2020 Bonds; DTC's records reflect only the identity of the Direct Participants to whose D-1 accounts such 2020 Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject many statutory or regulatory requirements as may be in effect from time in time. Beneficial Owners of 2020 Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the 2020 Bonds, such w redemptions, tenders, defaults, and proposed amendments to the 2020 Bonds documents. For example, Beneficial Owners of 2020 Bonds may wish to ascertain that the nommm holding the 2020 Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of notices be provided directly in them. Redemption notices shall be sent to DTC. If less than all of the 2020 Bonds within a maturity are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such maturity to be redeemed. Neither DTC nor Cede & Co. (nor my other DTC nominee) will consent or vote with respect in 2020 Bonds unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the City as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts 2020 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Redemption proceeds, distributions, and dividend payments on the 2020 Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detail information from the City or the Tmstee, on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name;' and will be the responsibility of such Participant and not of DTC, the Trustee or the City, subject to my statutory or regulatory requirements as may be in effect from time to time. Payment of redemption proceeds, distributions, and dividend payments in Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the City or the Trustee, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants. A 2020 Bond Owner shall give notice in elect to have its 2020 Bonds purchased or tendered, through its Participant, to the Trustee, and shall effect delivery of such 2020 Bond by causing the Direct Participant to transfer the Participant's interest in the 2020 Bonds, on DTC's records, to the Trustee. The requirement for physical delivery of 2020 Bond in connection with an options] tender or a mandatory purchase will be deemed satisfied when the ownership rights in the 2020 Bond are transferred by Direct Participants on DTC's records and followed by a book -entry credit of tendered 2020 Bond to the Trustee's DTC account. DTC may discontinue providing its services as depositary with respect to the 2020 Bonds at my time by giving reasonable notice in the City or the Trustee. Under such circumstances, in the event that a successor depository is not obtained, physical certificates are required to be printed and delivered. The City my decide to discontinue use of the system of book -entry only transfers through DTC for a successor securities depository). In that event, 2020 Bonds will be printed and delivered to DTC. THE TRUSTEE, AS LONG AS A BOOK -ENTRY ONLY SYSTEM IS USED FOR THE 2020 BONDS, WILL SEND ANY NOTICE OF REDEMPTION OR OTHER NOTICES TO OWNERS ONLY TO DTC. ANY FAILURE OF DTC TO ADVISE ANY DTC PARTICIPANT, OR OF ANY DTC PARTICIPANT TO NOTIFY ANY BENEFICIAL OWNER, OF ANY NOTICE AND ITS CONTENT OR EFFECT WILL NOT AFFECT THE VALIDITY OF SUFFICIENCY OF THE PROCEEDINGS RELATING TO THE REDEMPTION OF THE 2020 BONDS CALLED FOR REDEMPTION OR OF ANY OTHER ACTION PREMISED ON SUCH NOTICE. D-2 F.V 7TxJ 01.7V FORM OF CONTINUING DISCLOSURE AGREEMENT Upon issuance of the 2020 Bonds, the City proposes to enter into a Continuing Disclosure Agreement in substantially the following form: This Continuing Disclosure Agreement (the "Disclosure Agreement') is executed and delivered by and between the City of Vemon (the "City") and The Bank of New York Mellon Trust Company, N.A., in its capacity as dissemination agent (the "Dissemination Agent"), in connection with the issuance of the City of Vernon Water System Revenue Bonds, 2020 Series A in an aggregate principal amount of $_ (the "Bonds"). The Bonds are being issued by the City pursuant to the provisions of that certain Indenture of Trust, dated as of March 1, 2020 (the "Indenture"), by and between the City and The Bank of New York Mellon Trust Company, N.A., as trustee (the "Trustee"). The City and the Dissemination Agent hereby certify, covenant and agree as follows: Section 1. Pumose of the Disclosure Agreement. This Disclosure Agreement is being executed and delivered by the parties hereto for the benefit of the holders and Beneficial Owners of the Bonds and in order in assist the Participating Underwriter in complying with the Rule. Section 2. Definitions. In addition to the definitions set forth in the Indenture, which apply to any capitalized terms used in this Disclosure Agreement, unless otherwise defined in this Section, the following capitalized terms shall have the following meanings: "Annual Report" shall mean any Annual Report provided by the City pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. "Annual Report Date" shall mean each April 1 after the end of the City's fiscal year, the end of which, as of the date of this Disclosure Agreement, is June 30. "Beneficial Owwrl' shall mean any person which: (a) has the power, directly or indirectly, to vote or consent with respect ro, or to dispose of ownership of, any Bands (including persons holding Bonds through nominees, depositories or other intermediaries); or (b) is treated as the owner of any Bonds for federal income tax plus "Dissemination Agent" shall mean, initially, The Bank of New York Mellon Trust Company, N.A., acting in its capacity as Dissemination Agent hereunder, or any successor Dissemination Agent that is so designated in writing by the City and has filed with the then-cument Dissemination Agent a written acceptance of such designation. "Financial Obligation" shall mean a: (A) debt obligation; (B) derivative instrument entered into in comeetion with, or pledged as security or a source of payment for, an existing or planned debt obligation; or (C) guarantee of (A) or (B). The term "Financial Obligation" shall not include municipal securities as to which a final official statement has been provided to the Municipal Securities Rulemaking Board consistent with the Rule. "Listed Events" shall mean any of the events listed in Sections 5(a) and (b) of this Disclosure Agreement. "MSRB" shall mean the Municipal Securities Rulemaking Board. "Ofctal Statement "shall mean the Official Statement dated March _, 2020, relating to the Bonds. "Participating Underwriter" shall mean J.P. Morgan Securities LLC, the original underwriter of the Bonds required in comply with the Rule in connection with offering of the Bonds. E-1 "Rule" shall mean Rule 15c2-12 adopted by the SEC under the Securities Exchange Act of 1934, as the same may be amended from time to time. "SEC" shall mean the Securities and Exchange Commission. Section 3. Provision of Annual Retorts. (a) The City shall, or shall cause the Dissemination Agent in, not later than the Annual Report Date, commencing April 1, 2020 with the Annual Report for fiscal year 2015-19, provide m the MSRB an Annual Report that is consistent with the requirements of Section 4 of this Disclosure Agreement; provided that the filing of the Official Statement with the MSRB shall constitute compliance with this obligation for the first Annual Report Date. Not later than 15 calendar days prior to such date, the City shall provide its Annual Report to the Dissemination Agent, if such Dissemination Agent is a different entity than the City. The Annual Report most be submitted in an electronic format as prescribed by the MSRB, accompanied by such identifying information as is prescribed by the MSRB, and may include by reference other information as provided in Section 4 of this Disclosure Agreement; provided that any audited financial statements of the City may be submitted separately from the balance of the Annual Report, and not later than the date required above for the filings of the Annual Report. If the City's fiscal year changes, it shall give notice of such change in the same manner as for a Listed Event under Section 5(a). The City shall provide a written certification with each Annual Report furnished to the Dissemination Agent to the effect that such Annual Report constitutes the Annual Report required to be furnished hereunder. The Dissemination Agent may conclusively rely upon such certification of the City and shall have no duty or obligation to review such Annual Report. (b) If the City is unable to provide to the MSRB an Annual Report by the date required in subsection (a), the City in a timely manner shall send in the MSRB a notice in an electronic format as prescribed by the MSRB, accompanied by stub identifying information as prescribed by the MSRB. (c) The Dissemination Agent shall: provide any Amu] Report received by it in the MSRB by the date required in subsection (a); file a report with the City and the Trustee (if the Dissemination Agent is other than the Trustee) certifying that the Annual Report has been provided to the MSRB pursuant to this Disclosure Agreement and stating the date it was provided; and take my other actions as are mutually agreed upon between the Dissemination Agent and the City. Section 4. Content of Annual Returns. The Annual Report shall contain or incorporate by reference the following: (a) Audited financial statements of the Public Utilities Department of the City (Vernon Public Utilities) for the prior fiscal year, which include information regarding the funds and accounts of the Water System, if my, prepared in accordance with generally accepted accounting principles as promulgated m apply to govemmental entities from time to time by the Governmental Accounting Standards Board. If such audited financial statements are not available at the time that the Annual Report is required to be filed pursuant to Section 3(a), the Annual Report shall contain unaudited financial statements, and the audited financial statements shall be filed in the same manner as the Annual Report when they become available. (b) Principal amount of the Bonds outstanding. (c) An update of the information for the prior fiscal year in substantially the form set forth in the following tables in the Official Statement under the caption ` rHE WATER SYSTEM OF THE CITY": E-2 I. Historical Water System Connections and Production; 2. Historical Water Supply Sources and Usage in Acre Feet; and 3. Ten largest Water System Customers; (d) An update of the information for the prior fiscal year in substantially the form set forth in the following table in the Official Statement order the caption "FINANCIAL INFORMATION": Historical Water System Operating Results and Debt Service Coverage. Any or all of the items listed above may be included by specific reference to other documents, including official statements of debt issues of the City or related public entities, that are available to the public on the MSRB's Internet website or filed with the SEC. If the document included by reference is a final official statement, it must be available from the MSRB. The City shall clearly identify each such other document so included by reference. Section 5. Remitting of Significant Events. (a) Pursuant to the provisions of this Section $, the City shall give, or shall cause the Dissemination Agent to give, notice of the occurrence of any of the following events with respect to the Bonds in a timely counter not more than ten (10) Business Days after the event: 1. Principal and interest payment delinquencies. 2. Unscheduled draws on debt service reserves reflecting financial diffcultim. 3. Unscheduled draws on credit enhancements reflecting financial difficulties. 4. Substitution of credit or liquidity providers, or their failure to perform 5. Adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability or Notices of Proposed Issue (IRS Form 5701 TEB). 6. Tender offers. 7. Defeasances. 8. Rating changes. 9. Bankruptcy, insolvency, receivership or similar proceedings. Note: For the purposes of the event identified in subparagraph (9), the event is considered to occur when any of the following occur: the appointment of a receiver, fiscal agent or similar officer for an obligated person in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority bas assumed jurisdiction over substantially all of the assets or business of the obligated person, or if such jurisdiction has been assumed by leaving the existing governmental body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision orjurisdiction over substantially all of the assets or business of the obligated person. 10. Default, event of acceleration, termination event, modification of terns or other similar events under the terms of a Financial Obligation of the City, any of which reflect financial difficulties. E-3 (b) Pursuant to the provisions of this Section 5, the City shall give, or shall cause the Dissemination Agent to give, notice of the occurrence of any of the following events with respect to the Bonds, if material, in a timely maneer not more than ten (10) Business Days after occurrence: 1. Unless described in Section 5(a)(5), other notices or determinations by the Internal Revenue Service with respect to the not status of the Bonds or other events affecting the out status of the Bonds. 2. Modifications to the rights of Bondholders. 3. Bond calls. 4. Release, substitution or sale of property securing repayment of the Bonds. 5. Non-payment related defaults. 6. The consummation of a merger, consolidation or acquisition involving the City or the sale of all or substantially all of the assets of the City, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the [emanation of a definitive agreement relating to any such actions, other than pursuant to its terms. 7. Appointment of a successor or additional trustee or the change of the name of trustee. S. Incurrence of a Financial Obligation of the City, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of the City, any of which affect security holders. (c) If the City determines that knowledge of the occurrence of a Listed Event under subsection (b) would be material under applicable federal securities laws, and if the Dissemination Agent is other than the City, the City shall promptly notify the Dissemination Agent in writing. Such notice shall instruct the Dissemination Agent to file a notice of such occurrence with the MSRB in an electronic format as prescribed by the MSRB in a timely manner not more than ten (10) Business Days after the event. (d) If the City determines that a Listed Event under subsection (b) would not be material under applicable federal securities laws and if the Dissemination Agent is other than the City, the City shall so notify the Dissemination Agent in writing and instruct the Dissemination Agent not to report the occurrence. (e) The City hereby agrees that the undertaking set forth in this Disclosure Agreement is the responsibility of the City and, if the Dissemination Agent is other than the City, the Dissemination Agent shall not be responsible for determining whether the City's instructions to the Dissemination Agent under this Section comply with the requirements of the Rule. Section 6. Termination of Reoortina Obligation. The obligations of the City and the Dissemination Agent specified in this Disclosure Agreement shall terminate upon the legal defeasance, prior redemption or payment in full of all of the Bonds. If such termination occurs prior to the final maturity of the Bonds, the City shall give notice of such termination in the same manner as for a Listed Event under Section 5(a). Section 7. Dissemination Agent The City may from time to time appoint or engage a Dissemination Agent to assist it in carrying out its obligations under this Disclosure Agreement, and may discharge any such Dissemination Agent, with or without appointing a successor Dissemination Agent. If at any time there is not any other designated Dissemination Agent, the City shall act as Dissemination Agent. The initial Dissemination Agent shall be The Bank of New York Mellon Trust Company, N.A. EA Section 8. Amendment; Waiver. Notwithstanding any other provision of this Disclosure Agreement, the City may amend this Disclosure Agreement, and any provision of this Disclosure Agreement may be waived, provided that the following conditions are satisfied: (a) if the amendment or waiver relates to annual or event information to be provided hereunder, it may only be made in connection with a change in circumstances that arises from a change in legal requirements, change in law, or change in the identity, nature, or status of the City or type of business conducted; (b) the undertakings berein, as proposed to be amended or waived, would, in the opinion of nationally recognized bond counsel have complied with the requirements of the Rule at the time of the primary offering of the Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; and (c) the proposed amendment or waiver: (i) is approved by holders of the Bonds in the manner provided in the Indenture for amendments to the Indenture with the consent of holders; or (ii) does not, in the opinion of nationally recognized bond counsel, materially impair the interest of Bond owners. The City shall describe any amendment in this Disclosure Agreement in the next Annual Report filed after such amendment takes effect. If the annual financial information or operating data to be provided in the Annual Report is amended pursuant to the provisions hereof, the annual financial information containing the amended operating data or financial information shall explain, in narrative form, the reasons for the amendment and the impact of the change in the type of operating data or financial information being provided. If an amendment is made to the undertaking specifying the accounting principles to be followed in preparing financial statements, the annual financial information for the year in which the change is made shall present a comparison between the financial statements or information prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles. The comparison shall include a qualitative discussion of the differences in the accounting principles and the impact of the change in the accounting principles on the presentation of the financial information, in order to provide information to investors to enable them to evaluate the ability of the City to meet its obligations. To the extent reasonably feasible, the comparison shall be quantitative. A notice of the change in the accounting principles shall be sent to the MSRB. Section 9. Additional Infomation. Nothing in this Disclosure Agreement shall be deemed to prevent the City from disseminating any other information, using the means of dissemination set forth in this Disclosure Agreement or any other means of communication, or including any other information in any Annual Report or notice of occurrence of a Listed Event, in addition to that which is required by this Disclosure Agreement. If the City chooses to include any information in any Annual Report or notice of occurrence of a Listed Event in addition to that which is specifically required by this Disclosure Agreement, the City shall have no obligation under this Disclosure Agreement to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event. Section 10. Default In the event of a failure of the City to comply with any provisions of this Disclosure Agreement, any Participating Underwriter or any holder or Beneficial Owner of the Bonds, or the Trustee on behalf of the holders of the Bonds, may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by comet order, to cause the City to comply with its obligations under this Disclosure Agreement. A default under this Disclosure Agreement shall not be deemed to be a default under the Indenture, and the sole remedy under this Disclosure Agreement in the event of any failure of the City to comply with this Disclosure Agreement shall be an action to compel performance. Section 11. Duties. Immunities and Liabilities of Dissemination Agent. The Dissemination Agent shall have only such duties as are specifically set forth in this Disclosure Agreement, and the City agrees to indemnify and save the Dissemination Agent, its officers, directors, employees and agents, harmless against any loss, expense and liabilities that it may incur arising out of or in the exercise or performance of its duties as MI described hereunder, if any, including the costs and expenses (including attorneys' fees) of defending against any claim of liability, but excluding liabilities due to the Dissemination Agent's negligence or willful misconduct. The obligations of the City under this Section shall survive resignation or removal of the Dissemination Agent and payment of the Bonds. The Dissemination Agent shall not be responsible in any manner for the format or content of any notice or Annual Report prepared by the City pursuant to this Disclosure Agreement. The City shall pay the reasonable fees and expenses of the Dissemination Agent for its duties as described hereunder. Section 12. Notices. Any notices or communications to or among any of the parties to this Disclosure Agreement may be given to the Dissemination Agent (if other than the City) and to the City as follows: City: City of Vernon 4305 South Santa Fe Avenue Vernon, California 90058 Attention: City Administrator Dissemination Agent: The Bank of New York Mellon Trust Company, N.A. 400 South Hope Street, Suite 500 Los Angeles, California 90071 Attention: Corporate Trust Reference: City of Vernon 2020 Water Bonds Section 13. Beneficiaries. This Disclosure Agreement shall inure solely to the benefit of the City, the Dissemination Agent, the Trustee, the Participating Underwriter and holders and Beneficial Owners from time to time of the Bonds, and shall create no rights in any other person or entity. Section 14. Counterparts. This Disclosure Agreement may be executed in multiple counterparts, all of which shall constitute one and the same instrument, and each of which shall be deemed to be an original. Date: March � 2020 CITY OF VERNON By City Administrator THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A. as Dissemination Agent By: Authorized Signatory Efi STAFF REPORT City Council Agenda Item Report Agenda Rem No. COV-54-2020 Submitted by Scott Williams Submitting Department: Finance/Treasury Meeting Date: February 18, 2020 SUBJECT 2020 Water System Revenue Bonds Recommendation: A. Find that approval of the resolution to issue 2020 Water System Revenue Bonds is exempt under the California Environmental Quality Act (CEQA) in accordance with Sections 15060(c)(3), 15378(b)(4), and 15378(b)(5) because the activity approved by the Resolution relating to the refinancing or funding of previously -approved projects will not result indirect or indirect physical changes in the environment and, therefore, is rat a "project," as defined in Section 15378 of the CEQA Guidelines; and B. Adopt a resolution for the issuance of 2020 Water System Revenue Tax Exempt Series A Bonds in the par amount of $15 million to provide funds to (a) finance costs of certain capital improvements for the water system (b) fund a deposit to the Debt Service Reserve Fund, and (c) pay cost of issuance of the 2020 Series Bonds. The resolution provides for flexibility to accommodate interest rate fluctuations that would impact market conditions. Background: In November of 2019, the City Council held a public hearing regarding proposed changes in water rates and adopted a resolution approving a revised water rate schedule. The updated water rate schedule and corresponding rate increases are essential elements designed to provide, in part, the debt service capacity needed for securing tax-exempt bond financing as the increased revenue will enable the water utility to secure a proper credit rating, meet the required debt service coverages, and ensure repayment of time bond. The proceeds bond will provide available resources to address the current state of the Water Division facilities, urgent Capital Improvement Projects and critical activities that are already under way. Based on the Citys water system debt profile, a new issuance of revenue bond will be in the amount of $15 million. The result of this financing effort will provide immediate available resources for scheduled capital expenditures, as well as funding reserves in the water utility. This bond restructuring was performed following best business practices including the competitive selection process, and an Attorney Services Agreement (Transactional) was entered into with Stradling Yocca Carlson & Rauth for bond and disclosure counsel service, and J.P. Morgan was selected for Investment Banking and Underwriting Services. Upon finalizing the Series 2020 bond financial requirements and disclosure documents, City Council will be briefed on the specifics of the bonding transaction before proceeding with the final sale. At that time, staff will request that Council approve a resolution to move forward with the bond transaction, including approval of the Bond Purchase and Sale Agreement with Goldman Sachs, and authorization for the Director of Finance to accept or reject bids and set the interest rates on the bonds sold. A calculation will be done by the Citys Financial Advisor to determine the lowest cost investor bids to be accepted. This information will be brought forward to City Council and will be incorporated into the authorizing resolution. Council Policy Consideration This requested action supports the City Counci I's strategic goal of maintaining fiscal responsibility and stability while listening carefully to the needs of the Citys business community. Fiscal Impact: The result of this bond refunding and new issuance is projected to be $15 million in new 2020 Series A bonds with debt service to be funded by the adjusted rates adopted in November 2019. Attachments: 1. Resolution - 2020 Water System Revenue Bonds