HomeMy WebLinkAboutagenda item 2015 0626 rda 03a450 East 96 th
Street, Suite 500, Indianapolis, Indiana 46240
Tel: 317-581-6305
Piper Jaffray & Co. Since 1895. Member SIPC and NYSE
June 9, 2015
John H. Murphy, Controller
City of South Bend, Indiana
227 W. Jefferson Boulevard
South Bend, Indiana 46601
Re: $35,300,000 (estimated) South Bend Redevelopment Authority Lease Rental Refunding
Revenue Bonds of 2015 to be issued in a single issue for refinancing all or a portion of the
Authority’s outstanding Series 2008 bonds (the “Bonds”).
Dear Mr. Murphy,
On behalf of Piper Jaffray & Co. (”us” or “Piper”), we are writing concerning a potential
municipal securities transaction as identified above. This letter confirms that you engage Piper
Jaffray as an underwriter or placement agent respecting the Bonds, subject to the conditions
and limitations described below.
This engagement is preliminary in nature, non-binding and may be terminated at any time by
you or us. Although you intend or reasonably expect to use Piper Jaffray as an underwriter
respecting the Bonds, this engagement is subject to any applicable procurement laws and the
formal approval of Piper Jaffray as underwriter by your board or governing body, and is also
subject to mutual agreement as to the final structure for the Bonds and the terms of a bond
purchase or similar agreement. This engagement does not restrict you from using other
underwriters respecting the Bonds or any other municipal securities transaction or prevent you
from delaying or cancelling the Bond issue or selecting an underwriting syndicate that does not
include Piper Jaffray.
As an underwriter or placement agent, Piper may provide advice concerning the structure,
timing, terms, and other similar matters concerning the Bonds. Attached to this letter are
regulatory disclosures required by the Securities and Exchange Commission and the Municipal
Securities Rulemaking Board to be made by us at this time because of this engagement. We
may be required to send you additional disclosures regarding the material financial
characteristics and risks of such transaction or describing those conflicts. At that time, we also
will seek your acknowledgement of receipt of any such additional disclosures. It is our
understanding that you have the authority to bind the issuer by contract with us, and that you
are not a party to any conflict of interest relating to the Bonds. If our understanding is
incorrect, please notify the undersigned immediately.
ITEM: 3.A.
We wish to receive your written acknowledgement that you have received the Appendix A
disclosures and that this engagement is approved. Accordingly, please send me an email to
that affect, or sign and return the enclosed copy of this letter to me at the address set forth
below. If you have any questions or concerns about anything in this letter, please make those
questions or concerns known immediately to us at the contact information below.
Thank you.
Sincerely,
________________________________
David Wimmer
Senior Vice President
Piper Jaffray & Co.
450 East 96th Street
Suite 500
Indianapolis, IN 46240
________________________________
Acknowledgement of Approval of Engagement
and Receipt of Appendix A and B Disclosures
South Bend Redevelopment Authority
Date: ___________________________
Appendix A – G-17 Disclosure
We are providing you with certain disclosures relating to the captioned bond issue (the Bonds),
as required by the Municipal Securities Rulemaking Board (MSRB) Rule G-17 in accordance
with MSRB Notice 2012-25 (May 7, 2012). Under new federal regulations, all underwriters
and placement agents are now required to send the following disclosures to you (as the Issuer
of the Bonds) in order to clarify with you the role of an underwriter or placement agent and
other matters relating to an underwriting of the Bonds.
Our Role as Underwriter:
In serving as underwriter for the Bonds, these are some important disclosures that clarify our
role and responsibilities:
(i) MSRB Rule G-17 requires an underwriter to deal fairly at all times with both
municipal issuers and investors;
(ii) The underwriter’s primary role is to purchase securities with a view to distribution
in an arm’s-length commercial transaction with the Issuer and it has financial and
other interests that differ from those of the Issuer;
(iii) Unlike a municipal advisor, the underwriter does not have a fiduciary duty to the
Issuer under the federal securities laws and is, therefore, not required by federal law
to act in the best interests of the Issuer without regard to its own financial or other
interests;
(iv) The underwriter has a duty to purchase securities from the Issuer at a fair and
reasonable price, but must balance that duty with its duty to sell municipal
securities to investors at prices that are fair and reasonable; and
(v) The underwriter will review the official statement for the Issuer’s securities in
accordance with, and as part of, its responsibilities to investors under the federal
securities laws, as applied to the facts and circumstances of the transaction.1
Our Role as Placement Agent:
In serving as placement agent for the Bonds, these are some important disclosures that clarify
our role and responsibilities:
(i) MSRB Rule G-17 requires us to deal fairly at all times with both municipal issuers
and investors;
(ii) Our primary role in this transaction is to facilitate the sale and purchase of
municipal securities between you and one or more investors for which we will
receive compensation;
(iii) Unlike a municipal advisor, we do not have a fiduciary duty to you under the
federal securities laws and are, therefore, not required by federal law to act in your
best interests without regard to our own financial or other interests;
(iv) We have a duty to arrange the purchase securities from you at a fair and reasonable
price, but must balance that duty with our duty to arrange the sale to investors at
prices that are fair and reasonable; and
1 Under federal securities law, an issuer of securities has the primary responsibility for disclosure for investors.
The review of the official statement by the underwriter is solely for purposes of satisfying the underwriter’s
obligations under the federal securities laws and such review should not be construed by an issuer as a guarantee
of the accuracy or completeness of the information in the official statement.
(v) In the event an official statement is prepared, we will review the official statement
for your securities in accordance with, and as part of, our responsibilities to
investors under the federal securities laws, as applied to the facts and circumstances
of the transaction.
Our Compensation:
As underwriter, compensation will be by a fee and/or an underwriting discount that will be set
forth in the bond purchase agreement to be negotiated and entered into in connection with the
issuance of the Bonds. As placement agent, compensation will be by a fee that was negotiated
and entered into in connection with the issuance of the Bonds. Payment or receipt of the
underwriting fee, discount or placement agent fee will be contingent on the closing of the
transaction and the amount of the fee or discount may be based, in whole or in part, on a
percentage of the principal amount of the Bonds. While this form of compensation is
customary in the municipal securities market, it presents a conflict of interest since the
underwriter or placement agent may have an incentive to recommend to the Issuer a
transaction that is unnecessary or to recommend that the size of the transaction be larger than
is necessary.
Conflicts of Interest for Underwritings Only:
We have entered into an agreement with Pershing LLC which enables us to distribute certain
new issue municipal securities underwritten by or allocated to us which could include the
Bonds. Under the agreement, we could share with Pershing LLC a portion of the fee or
commission paid to us as underwriter.
We have entered into a separate agreement with Charles Schwab & Co., Inc. that enables
Charles Schwab & Co., Inc. to distribute certain new issue municipal securities underwritten
by or allocated to us which could include the Bonds. Under that agreement, we will share with
Charles Schwab & Co., a portion of the fee or commission paid to us.
Risk Disclosures:
In accordance with the requirements of MSRB Rule G-17, attached as Appendix B is a
description of the material aspects of a typical fixed rate offering, including the Bonds. This
letter may be later supplemented if the material terms of the Bonds change from what is
described here.
If you have any questions or concerns about these disclosures, please make those questions or
concerns known immediately to me. In addition, you should consult with your own financial,
legal, accounting, tax and other advisors, as applicable, to the extent you deem appropriate.
Appendix B – Risk Disclosures
The following is a general description of the financial characteristics and security structures of
fixed rate municipal bonds (“Fixed Rate Bonds”), as well as a general description of certain
financial risks that you should consider before deciding whether to issue Fixed Rate Bonds.
Financial Characteristics
Maturity and Interest. Fixed Rate Bonds are interest-bearing debt securities issued by
state and local governments, political subdivisions and agencies and authorities.
Maturity dates for Fixed Rate Bonds are fixed at the time of issuance and may include
serial maturities (specified principal amounts are payable on the same date in each year
until final maturity) or one or more term maturities (specified principal amounts are
payable on each term maturity date) or a combination of serial and term maturities.
The final maturity date typically will range between 10 and 30 years from the date of
issuance. Interest on the Fixed Rate Bonds typically is paid semiannually at a stated
fixed rate or rates for each maturity date.
Redemption. Fixed Rate Bonds may be subject to optional redemption, which allows
you, at your option, to redeem some or all of the bonds on a date prior to scheduled
maturity, such as in connection with the issuance of refunding bonds to take advantage
of lower interest rates. Fixed Rate Bonds will be subject to optional redemption only
after the passage of a specified period of time, often approximately ten years from the
date of issuance, and upon payment of the redemption price set forth in the bonds,
which may include a redemption premium. You will be required to send out a notice
of optional redemption to the holders of the bonds, usually not less than 30 days prior
to the redemption date. Fixed Rate Bonds with term maturity dates also may be
subject to mandatory sinking fund redemption, which requires you to redeem specified
principal amounts of the bonds annually in advance of the term maturity date. The
mandatory sinking fund redemption price is 100% of the principal amount of the
bonds to be redeemed.
Security
Payment of principal of and interest on a municipal security, including Fixed Rate Bonds, may
be backed by various types of pledges and forms of security, some of which are described
below.
General Obligation Bonds
“General obligation bonds” are debt securities to which your full faith and credit is
pledged to pay principal and interest. If you have taxing power, generally you will
pledge to use your ad valorem (property) taxing power to pay principal and interest.
Ad valorem taxes necessary to pay debt service on general obligation bonds may not be
subject to state constitutional property tax millage limits (an unlimited tax general
obligation bond). The term “limited” tax is used when such limits exist.
General obligation bonds constitute a debt and, depending on applicable state law,
may require that you obtain approval by voters prior to issuance. In the event of
default in required payments of interest or principal, the holders of general obligation
bonds have certain rights under state law to compel you to impose a tax levy.
Revenue Bonds
“Revenue bonds” are debt securities that are payable only from a specific source or
sources of revenues. Revenue bonds are not a pledge of your full faith and credit and
you are obligated to pay principal and interest on your revenue bonds only from the
revenue source(s) specifically pledged to the bonds. Revenue bonds do not permit the
bondholders to compel you to impose a tax levy for payment of debt service. Pledged
revenues may be derived from operation of the financed project or system, grants or
excise or other specified taxes. Generally, subject to state law or local charter
requirements, you are not required to obtain voter approval prior to issuance of
revenue bonds. If the specified source(s) of revenue become inadequate, a default in
payment of principal or interest may occur. Various types of pledges of revenue may
be used to secure interest and principal payments on revenue bonds. The nature of
these pledges may differ widely based on state law, the type of issuer, the type of
revenue stream and other factors.
General Fund Obligations
“General Fund Obligations” are debt securities that are payable from an issuer’s
general fund and are not secured by a specific tax levy like a general obligation bond or
a specific revenue pledge like a revenue bond. General fund obligations come in many
varieties and may be a continuing obligation of the general fund or may be subject to
annual appropriation. Often general fund obligations are issued in the form of
certificates of participation in a lease obligation of the issuer.
Financial Risk Considerations
Certain risks may arise in connection with your issuance of Fixed Rate Bonds, including some
or all of the following:
Risk of Default and Fiscal Stress
You may be in default if the funds pledged to secure your bonds are not sufficient to
pay debt service on the bonds when due. The consequences of a default may be serious
for you and may include the exercise of available remedies against you on behalf of the
holders of the bonds. Depending on state law, if the bonds are secured by a general
obligation pledge, you may be ordered by a court to raise taxes or other budgetary
adjustments may be necessary to enable you to provide sufficient funds to pay debt
service on the bonds. If the bonds are revenue bonds, subject to applicable state law
and the terms of the authorizing documents, you may be required to take steps to
increase the available revenues that are pledged as security for the bonds.
Bonds payable from the general fund, particularly bonds without a defined revenue
stream identified to pay debt service, reduce your flexibility to balance the general
fund. Because a fixed debt service payment is required to be paid regardless of how
your general fund is impacted by revenue losses or by increased expenses, you have less
flexibility in the options available to you in assuring a balanced budget for your general
fund.
General Fund Obligations that are Project Based. Some general fund obligations are
issued for projects which are expected to generate revenues that will pay for some or all
of the debt service on the bonds. In the event the project does not generate the
anticipated levels of revenues available for debt service, or, in the extreme case, does
not create any revenue available for debt service, you may need to make payments from
other available general fund revenues. This may force you to reduce other expenditures
or to make difficult decisions about how to pay your debt service obligation while
meeting other expenditure needs.
General Fund Obligations that are Subject to Annual Appropriation. Some general
fund obligations require that debt service is subject to annual appropriation by your
governing body. If your governing body decides not to appropriate payments for debt
service, your credit ratings may be negatively impacted and you may be forced to pay a
higher interest rate on future debt issuance or may be unable to access the market for
future debt issuance.
For all bonds, a default may negatively impact your credit ratings and may effectively
limit your ability to publicly offer bonds or other securities at market interest rate
levels. Further, if you are unable to provide sufficient funds to remedy the default,
subject to applicable state law and the terms of the authorizing documents, it may be
necessary for you to consider available alternatives under state law, including (for some
issuers) state-mandated receivership or bankruptcy. A default also may occur if you
are unable to comply with covenants or other provisions agreed to in connection with
the issuance of the bonds.
Redemption Risk
Your ability to redeem the bonds prior to maturity may be limited, depending on the
terms of any optional redemption provisions. In the event that interest rates decline,
you may be unable to take advantage of the lower interest rates to reduce debt service.
Refinancing Risk
If your financing plan contemplates refinancing some or all of the bonds at maturity
(for example, if you have term maturities or if you choose a shorter final maturity than
might otherwise be permitted under the applicable federal tax rules), market conditions
or changes in law may limit or prevent you from refinancing those bonds when
required. Further, limitations in the federal tax rules on advance refunding of bonds
(an advance refunding of bonds occurs when tax-exempt bonds are refunded more than
90 days prior to the date on which those bonds may be retired) may restrict your ability
to refund the bonds to take advantage of lower interest rates.
Reinvestment Risk
You may have proceeds of the bonds to invest prior to the time that you are able to
spend those proceeds for the authorized purpose. Depending on market conditions,
you may not be able to invest those proceeds at or near the rate of interest that you are
paying on the bonds, which is referred to as “negative arbitrage”.
Tax Compliance Risk
The issuance of tax-exempt bonds is subject to a number of requirements under the
United States Internal Revenue Code, as enforced by the Internal Revenue Service
(IRS). You must take certain steps and make certain representations prior to the
issuance of tax-exempt bonds. You also must covenant to take certain additional
actions after issuance of the tax-exempt bonds. A breach of your representations or
your failure to comply with certain tax-related covenants may cause the interest on the
bonds to become taxable retroactively to the date of issuance of the bonds, which may
result in an increase in the interest rate that you pay on the bonds or the mandatory
redemption of the bonds. The IRS also may audit you or your bonds, in some cases on
a random basis and in other cases targeted to specific types of bond issues or tax
concerns. If the bonds are declared taxable, or if you are subject to audit, the market
price of your bonds may be adversely affected. Further, your ability to issue other tax-
exempt bonds also may be limited.