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HomeMy WebLinkAbout901240.tiff WELD COUNTY, COLORADO TAX ANTICIPATION NOTES SERIES 1991A DATED JANUARY 10, 1991 - $4, 350, 000 Closing Index 1. Note Purchase Agreement 2 . Note Resolution 3. Specimen Note 4. Closing Memorandum 5. County Certificate and Receipt 6. County Certificate Regarding Federal Tax Matters 7. Form 8038-G and Evidence of Mailing 8 . Underwriter's Receipt 9. Opinion of Bond Counsel 10. Preliminary Offering Circular 11. Offering Circular 12 . County Disclosure Certificate 13 . Letter re Responsibility for Disclosure 14. Letter of Representations Complete transcripts of the closing documents will be furnished to the following parties: Weld County, Colorado (2 copies) County Attorney Ballard, Spahr, Andrews & Ingersoll Piper, Jaffray & Hopwood, Incorporated $4,350, 000 WELD COUNTY, COLORADO TAX ANTICIPATION NOTES SERIES 1991A NOTE PURCHASE AGREEMENT January 3, 1991 Board of County Commissioners Weld County 915 10th Street Greeley, Colorado 80632 Ladies and Gentlemen: On the basis of the representations, warranties and covenants contained in this Note Purchase Agreement (this "Note Purchase Agreement") and on the terms and conditions contained herein, the undersigned, Piper, Jaffray & Hopwood, Incorporated (the "Underwriter") , hereby offers to purchase from Weld County, Colorado (the "County") $4, 350, 000 aggregate principal amount of Tax Anticipation Notes, Series 1991A, dated January 10, 1991 (the "Notes") , to be issued under and pursuant to a resolution adopted by the District on December 19, 1990 (the "Note Resolution") . Section 1. The Countv's Representations, Warranties and Agreements. By your acceptance hereof the County hereby represents, warrants, and agrees with the Underwriter that: (a) You are a political subdivision of the State of Colorado (the "State") and a body politic and corporate duly organized and validly existing under the Constitution and laws of the State and your Home Rule Charter. To the best of your knowledge, you are authorized by the provisions of the Constitution and laws of the State, including the Tax Anticipation Note Act, part 1 of article 15 of title 29, Colorado Revised Statutes, as amended (the "Act") , and your Home Rule Charter to adopt the Note Resolution and issue the Notes. (b) To the best of your knowledge, you have complied with all provisions of the Constitution and laws of the State, including the Act, and your Home Rule Charter in connection with the issuance of the Notes, and have full power and authority to consummate all transactions contemplated by this Note Purchase Agreement, the Notes, the Note Resolution, and any and all other agreements relating thereto. (c) in order to enable the Underwriter to comply with Rule 15c2-12 under the Securities Exchange Act of 1934 (the "Rule") , (i) you have reviewed the Preliminary Offering Circular, dated as of December 20, 1990 (the "Preliminary Offering Circular") and have deemed it final as of its date except for the omission of no more than the following information: the offering price, interest rate, selling compensation, aggregate principal amount, delivery date, ratings, and other terms of the securities depending on such matters; (ii) you shall provide to the Underwriter 150 copies of a Final Offering Circular which the County deems complete as of its date (the "Final Offering Circular") , in substantially the same form as the Preliminary Offering Circular subject to minor additions, deletions and revisions within seven business days after the date of this Note Purchase Agreement and in sufficient time to accompany any confirmation that requires payment from any customer; (iii) you shall deliver, at the Closing Time (hereinafter defined) , a certificate executed by appropriate officers of the County acting in their official capacities, to the effect that the facts contained in the Final Offering Circular are true and correct in all material respects, and that the Final Offering Circular does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading; and (iv) you agree to notify the Underwriter of any material developments impacting the County or the Notes of which the County becomes aware within 60 days after delivery of the Notes. (d) To the best of your knowledge, you have duly authorized all necessary action to be taken by you for (i) the issuance and sale of the Notes upon the terms set forth herein and in the Preliminary Offering Circular prepared for use in connection with the Notes, the Final Offering Circular, and any amendment or supplement that may be authorized by you and approved by us for use with respect to the Notes (herein collectively referred to as the "Offering Circular") ; (ii) the adoption of the Note Resolution providing for the issuance of and security for the Notes; (iii) the execution and delivery of, and the due performance of all obligations represented by, this Note Purchase Agreement, the Notes, and any and all such other agreements and documents as may be required to carry out, give effect to, and consummate the transactions contemplated hereby and by the Offering Circular; and (v) the carrying out, giving effect to, and consummation of the transactions contemplated hereby and by the Offering Circular. Executed counterparts of the Note Resolution will be delivered to the Underwriter by you at the Closing Time (hereinafter defined) . 2 (e) There is no action, suit, proceeding, inquiry or investigation at law or in equity or before or by any court, public board or body pending and for which you have been served or, to the best of your knowledge, threatened against or affecting you (or to the best of your knowledge any basis therefor) , wherein an unfavorable decision, ruling or finding would adversely affect the transactions contemplated hereby or by the Offering Circular or the validity of this Note Purchase Agreement, the Notes, the Note Resolution, or any agreement or instrument to which you are a party and which is used or contemplated for use in the consummation of the transactions contemplated hereby or by the Offering Circular. (f) To the best of your knowledge, the execution and delivery of this Note Purchase Agreement, the Notes, the Note Resolution, the Offering Circular, and the other agreements contemplated hereby and by the Offering Circular and compliance with the provisions thereof will not conflict with or constitute on your part a breach of or a default under any existing law, court or administrative regulation, decree or order or any agreement, indenture, mortgage, lease or other instrument to which you are subject or by which you are or may be bound. (g) You have not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that you are an issuer whose arbitrage certifications may not be relied upon. (h) Any financial statements of the County supplied by you to the Underwriter have been prepared in conformity with generally accepted accounting principles consistently applied to the periods concerned and fairly present the financial condition of the County. (i) Any certificate signed by any of your authorized officers and delivered to the Underwriter is to the extent provided therein a representation and warranty by you to the Underwriter as to the statements made therein. Section 2 . The Underwriter's Representations, Warranties, and Agreements. The Underwriter hereby represents, warrants, and agrees with the County that: (a) The Underwriter shall supply to the County all information, referenced under Section 1(c) (i) of this Note Purchase Agreement, to complete the Final Offering Circular. 3 (b) In order to comply with the Rule, (i) the Underwriter has obtained and reviewed the Preliminary Offering Circular prior to the time the Underwriter bid for, purchased, offered or sold the Notes; (ii) the Underwriter has sent and shall send, by first-class mail or other equally prompt means, a copy of the most recent version of the Preliminary Offering Circular to any potential customer, on request, no later than the next business day after the request, until the Final Offering Circular is available; and (iii) from the time the Final Offering Circular becomes available until the earlier of 90 days after the End of the Underwriting Period (hereinafter defined) or the time when the Final Offering Circular is available to any person from a nationally recognized municipal securities information repository, but in no case less than 25 days after the End of the Underwriting Period, the Underwriter shall send, by first-class mail or other equally prompt means, a copy of the Final Offering Circular to any potential customer, on request, no later than the next business day after the request. (c) Within 25 days after the End of the Underwriting Period, the Underwriter shall send, by first- class mail or equally prompt means, a copy of the Final Offering Circular to both the Municipal Securities Rulemaking Board and a nationally recognized municipal securities information repository. "End of the Underwriting Period" means the later of the time (i) the County delivers the Notes to the Underwriter, or (ii) the Underwriter does not retain any unsold balance of the Notes for sale to the public, either directly or as a member of a syndicate. Section 3 . Purchase, Sale and Delivery of the Notes. On the basis of the representations, warranties and covenants contained herein and subject to the terms and conditions herein set forth, at the Closing Time (hereinafter defined) the Underwriter agrees to purchase from you and you agree to sell to the Underwriter the Notes for a price equal to 99.8375% of the principal amount thereof. The Notes shall be issued under and secured as provided in the Note Resolution. The Notes shall mature on December 31, 1991, and shall bear interest at the rate of 5.70% per annum. Payment for the Notes shall be made by certified or official bank check or at the Underwriter's option by wire transfer in immediately available federal funds payable to your order or for your account, at the offices of Ballard, Spahr, Andrews & Ingersoll, in Denver, Colorado, at 9: 00 a.m. , prevailing local time, on January 10, 1991, or such other place, time or date as 4 shall be mutually agreed upon by you and the Underwriter. The date of such delivery and payment is herein called the "Closing Date, " and the hour and date of such delivery and payment is herein called the "Closing Time. " The Notes shall be delivered in printed or typewritten form payable to such registered owner or owners as the Underwriter may direct. The Notes shall be available for examination and packaging by the Underwriter in Denver, Colorado at least twenty-four (24) hours prior to the Closing Time. Section 4. Conditions to the Underwriter's Obligations. The Underwriter's obligations hereunder shall be subject to the due performance by you of your obligations and agreements to be performed hereunder at or prior to the Closing Time and to the accuracy of and compliance with your representations and warranties contained herein as of the date hereof and as of the Closing Time and shall also be subject to the following conditions: (a) The Notes, the Note Resolution and the Offering Circular shall have been duly authorized, executed and delivered by the parties thereto in the form heretofore approved by the Underwriter with only such changes therein as shall be mutually agreed upon by you and the Underwriter. (b) At the Closing Time the Underwriter shall receive: (i) The opinion in form and substance satisfactory to the Underwriter dated the Closing Date of Ballard, Spahr, Andrews & Ingersoll, Bond Counsel, relating to the valid issuance of the Notes and the tax treatment of interest on the Notes under federal and Colorado income tax laws; (ii) Such certificates, opinions and other documents as the Underwriter may reasonably request to evidence performance of or compliance with the provisions hereof and the transactions contemplated hereby and by the Offering Circular, all such certificates and other documents to be satisfactory in form and substance to the Underwriter. Section 5. The Underwriter's Right to Cancel. The Underwriter shall have the right to cancel its obligation hereunder to purchase the Notes by notifying you in writing or by telegram of its election so to do between the date hereof and the Closing Time if at any time hereafter and prior to the Closing Time: (a) Legislation shall be proposed by any member of the Congress of the United States of America, or a tentative decision with respect to legislation shall be reached by a committee of the House of Representatives or the Senate of the 5 Congress of the United States of America, or legislation shall be favorably reported by such a committee or be introduced by amendment or otherwise in, or be passed by, the House of Representatives or the Senate or recommended to the Congress of the United States of America for passage by the President of the United States of America or enacted by the Congress of the United States of America, or a decision by a court established under Article III of the Constitution of the United States of America or the Tax Court of the United States of America shall be rendered, or a ruling, regulation or order of the Treasury Department of the United States of America or the Internal Revenue Service shall be made or proposed, or any other event shall have occurred, which results in the imposition of federal income taxation upon revenues or other income of the general character to be derived by you or by any similar body or upon interest received on obligations of the general character of the Notes, or the Notes, which in the Underwriter's opinion materially adversely affects the market price of the Notes; (b) Any legislation, ordinance, resolution, rule, or regulation shall be introduced in or be enacted by any governmental body, department or agency in the State, or a decision by any court of competent jurisdiction within the State shall be rendered, which in the Underwriter's opinion materially adversely affects the market price of the Notes; (c) A stop order, ruling, regulation or official statement by or on behalf of the Securities and Exchange Commission or any other governmental agency having jurisdiction of the subject matter shall be issued or made to the effect that the issuance, offering or sale of obligations of the general character of the Notes, or the issuance, offering or sale of the Notes, including all the underlying obligations, as contemplated hereby or by the Offering Circular is in violation or would be in violation of any provision of the federal securities laws, the Securities Act of 1933, as amended and as then in effect, or the registration provisions of the Securities Exchange Act of 1934, as amended and as then in effect, or the qualification provisions of the Trust Indenture Act of 1939, as amended and as then in effect; (d) Legislation shall be enacted by the Congress of the United States of America, or a decision by a court of the United States of America shall be rendered, to the effect that obligations of the general character of the Notes, or the Notes, including all the underlying obligations, are not exempt from registration under or from other requirements of the Securities Act of 1933 , as amended and as then in effect, or the Securities Exchange Act of 1934, as amended and as then in effect, or that the Note Resolution is not exempt from 6 qualification under or from other requirements of the Trust Indenture Act of 1939, as amended and as then in effect; (e) Any event shall have occurred or information shall have become known, which in the Underwriter's opinion makes untrue in any material respect any statement or information contained in the Offering Circular or has the effect that the Offering Circular as originally circulated contains any untrue statement of a material fact or omits to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; (f) Additional material restrictions not in force as of the date hereof shall have been imposed upon trading in securities generally by any governmental authority or by any national securities exchange; (g) Any national securities exchange or any governmental authority shall impose as to the Notes or obligations of the general character of the Notes any material restrictions not now in force or increase materially those now in force with respect to the extension of credit by, or the charge to the net capital requirements of, the Underwriter; (h) A general banking moratorium shall have been established by federal, New York or State authorities; (i) Trading in any securities of yours shall have been suspended on any national securities exchange or otherwise or any proceeding shall be pending or threatened by the Securities and Exchange Commission against you; or (j) A war involving the United States of America shall have been declared, or any conflict involving the armed forces of the United States of America shall have escalated, or any other national emergency relating to the effective operation of government or the financial community shall have occurred, which in the Underwriter's opinion materially adversely affects the market price of the Notes. Section 6. Conditions of Your Obligations. Your obligations hereunder are subject to the Underwriter's performance of its obligations hereunder. Section 7 . Representations. Warranties and Agreements to Survive Delivery. All of your representations, warranties and agreements shall remain operative and in full force and effect, regardless of any investigations made by the Underwriter on its behalf and shall survive delivery of the Notes to the Underwriter. 7 Section 8. Payment of Expenses. The expenses and costs to effect the authorization, preparation, issuance, delivery and sale of the Notes (including the fees of Bond Counsel) shall be paid by you out of the proceeds of the Notes. Section 9. Use of Offering Circular. You hereby acknowledge the Underwriter's use and distribution of the Preliminary Offering Circular, and you acknowledge the proposed use and distribution of the Offering Circular for the use by the Underwriter in connection with the sale of the Notes and you warrant the information contained therein relating to the County to be true and correct. Section 10. Notice. Any notice or other communication to be given to you under this Note Purchase Agreement may be given by mailing or delivering the same in writing at your address set forth above; and any notice or other communication to be given to the Underwriter under this Note Purchase Agreement may be given by delivering the same in writing to the Underwriter, Suite 1680, 1660 Lincoln Street, Denver, Colorado 80264 . Section 11. Applicable Law: Nonassignability. This Note Purchase Agreement shall be governed by the laws of the State. This Note Purchase Agreement shall not be assigned by you. Section 12. Execution of Counterparts. This Note Purchase Agreement may be executed in several counterparts, each of which shall be regarded as an original and all of which shall constitute one and the same document. Very truly yours, PIPER, JAFFRAY & HOPWOOD, INCORPORATED d1- By: T t le: (/A.;:— �^----<--- Accepted as of the date first above written: WELD COUNTY OLO r�DO By: , VV mano e Board of County C issioners 8 RESOLUTION RE: AUTHORIZING THE ISSUANCE OF THE COUNTY'S TAX ANTICIPATION NOTES, SERIES 1991A, IN AN AGGREGATE PRINCIPAL AMOUNT NOT TO EXCEED $4 ,400, 000; PROVIDING FOR THE DATE, INTEREST RATE, MATURITY DATE AND SOURCE AND MANNER OF PAYMENT OF THE NOTES; AUTHORIZING THE PROPER OFFICERS OF THE COUNTY TO EXECUTE AND DELIVER THE NOTES AND OTHER DOCUMENTS; PRESCRIBING THE FORM OF THE NOTES; AND REPEALING INCONSISTENT RESOLUTIONS. WHEREAS, the Board of County Commissioners (the Board) of Weld County, Colorado (the County) , pursuant to Colorado statute and the County Home Rule Charter, is vested with the authority of administering the affairs of the County; and WHEREAS, the County anticipates receiving ad valorem taxes on real or personal property (Taxes) and other revenues during the fiscal year ending December 31, 1991 (the Current Fiscal Year) , which will be credited to the general fund (the General Fund) of the County; and WHEREAS, the County has estimated the anticipated Taxes and other revenues to be credited to the General Fund and the budgeted expenditures to be made from the General Fund in the Current Fiscal Year and has concluded that the Taxes will not be received in time to pay the County's projected budgeted expenses in the Current Fiscal Year; and WHEREAS, the County is authorized by the provisions of the Tax Anticipation Note Act, part 1 of article 15 of title 29, Colorado Revised Statutes, as amended (the Act) , to issue tax anticipation notes by resolution (this Resolution) in an amount not to exceed fifty percent (50%) of all Taxes estimated by the County to be received in the Current Fiscal Year; and WHEREAS, Piper, Jaffray & Hopwood, Inc. , Denver, Colorado (the Purchaser) , has offered to purchase such notes on terms favorable to the County. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, as follows: Section 1. The Board hereby determines that the Taxes will not be received in time to pay the County's projected budgeted expenses of the General Fund in the Current Fiscal Year. For the purpose of paying such expenses the County hereby authorizes the issuance of its negotiable registered Tax Anticipation Notes, Series 1991A, in an aggregate principal Page 2 RE: TAX ANTICIPATION NOTES, SERIES 1991A amount not to exceed $4,400, 000 (the Notes) , payable from Taxes, investment proceeds on Taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses of the General Fund, received by the County in the Current Fiscal Year and credited to the General Fund after the issuance of the Notes. The Board hereby determines that the aggregate principal amount of the Notes and all other tax anticipation notes issued by the County during the Current Fiscal Year does not exceed fifty percent (50%) of the Taxes estimated to be received by the County in the Current Fiscal Year as shown by the County's budget for the Current Fiscal Year. Section 2 . The Notes shall be in such denominations as may be determined by the Finance Director or his designee, shall be registered as to principal and interest without coupons, shall be dated the date of their delivery but in no event earlier than January 1, 1991, shall bear interest payable at maturity at such rate as may be determined by the Finance Director or his designee not to exceed seven and fifty hundredths percent (7 . 50%) per annum, shall not be subject to redemption in whole or in part at any time prior to their maturity date, shall mature on such date as may be determined by the Finance Director or his designee but not later than December 31, 1991, shall be payable as to principal and interest upon presentation and surrender thereof at the office of the County Treasurer, as paying agent, from the source and in the manner specified and be otherwise in substantially the form prescribed in Section 4 hereof. Section 3 . The Notes shall be executed by the Chairman of the Board, shall bear the seal of the County, and shall be attested by the Clerk to the Board. Said signatures and seals may be affixed manually or by the use of facsimiles in accordance with the Uniform Facsimile Signature of Public Officials Act, part 1 of article 55 of title 11, Colorado Revised Statutes, as amended. The Chairman of the Board and the Clerk to the Board are hereby authorized and directed to date, execute and deliver the Notes, and the appropriate officers of the County are hereby authorized and directed to date, execute and deliver such other documents, including, without limitation, closing documents and certificates, and to take such other action as may be necessary or appropriate in order to effectuate the issuance and sale of the Notes, all in accordance with this Resolution and the Act. Section 4 . The Notes and the registration panels appearing thereon shall be in substantially the following forms: Page 3 RE: TAX ANTICIPATION NOTES, SERIES 1991A [Form of Note] UNITED STATES OF AMERICA STATE OF COLORADO COUNTY OF WELD TAX ANTICIPATION NOTE SERIES 1991A No. R-_ $ Weld County, Colorado (the County) , for value received, hereby promises to pay to the registered owner hereof as shown on the registration panel attached hereto from ad valorem taxes on real and personal property, investment proceeds on such taxes, and proceeds of the notes of this issue to the extent not required for the payment of duly budgeted current expenses, received by the County in the fiscal year ending December 31, 1991, and credited to the general fund after the issuance hereof, on December 31, 1991, the principal sum of Dollars ($ ) together with interest thereon from the date hereof to the maturity date hereof at the rate of and hundredths percent ( . %) per annum, based upon the actual number of days elapsed in a month of 30 days and a year of 360 days, said interest in the amount of Dollars and Cents ($ . ) being payable at maturity. This Note is issued by the Board of County Commissioners of the County, on behalf of the County, in accordance with part 1 of article 15 of title 29, Colorado Revised Statutes, as amended (the Act) , and pursuant to a Resolution (the Resolution) of the Board of County Commissioners of the County duly adopted prior to the issuance hereof in order to pay duly budgeted current expenses of the general fund of the County. Reference is hereby made to the Act and the Resolution for a complete statement of the rights and limitations of rights of the registered owner of this Note, to all of which the registered owner hereof by acceptance of this Note assents. This Note is not subject to redemption in whole or in part at any time prior to its maturity date. The principal of and interest on this Note are payable upon presentation and surrender hereof at the office of the County Treasurer, as paying agent, either by check or draft mailed to the registered owner hereof or by wire transfer to such bank or other depository as the registered owner hereof shall designate. This Note is transferable only upon the books of the County by the Clerk to the Board, as transfer agent. Page 4 RE: TAX ANTICIPATION NOTES, SERIES 1991A It is hereby certified, recited and warranted that all acts, conditions and things required to be done, occur or be performed precedent to and in the issuance of this Note have been done, have occurred and have been performed in regular and due form and manner as required by law and that the obligations represented by this Note do not contravene any constitutional or statutory limitation of the State of Colorado. IN TESTIMONY WHEREOF the County has caused this Note to be executed in its name with the manual signature of the Chairman of the Board of County Commissioners, to be sealed with the seal of the County, and to be attested with the manual signature of the Clerk to the Board, all as of the day of January, 1991. WELD COUNTY, COLORADO (COUNTY) ( SEAL ) By: (Manual Signature) Chairman of the Board of County Commissioners ATTEST: (Manual Signature) Clerk to the Board Page 5 RE: TAX ANTICIPATION NOTES, SERIES 1991A [Form of Registration Panel] This Note is registered with the Clerk to the Board, as registrar, in the name of the owner listed below, and the principal of and interest on this Note are payable only to such owner. Date of Name, Address and Tax I.D. Signature of Registration Number of Registered Owner Registrar January _, 1991 [End of Form of Registration Panel] Page 6 RE: TAX ANTICIPATION NOTES, SERIES 1991A Section 5. Upon their execution and prior to their delivery the Notes shall be registered for the purpose of payment of principal and interest with the Clerk to the Board, as registrar. Thereafter, the Notes shall be transferable only upon the registration books of the County by the Clerk to the Board, as transfer agent. The fact of registration shall be noted on the registration panels appearing on the Notes. The County shall be entitled to treat the persons or entities listed on its registration books as the sole owners of the Notes for all purposes, including the right to receive payment of the principal of and interest on the Notes. Section 6. The Notes may be sold at private sale to the Purchaser at, above, or below the aggregate principal amount thereof as may be determined by the Finance Director or his designee, and the Board hereby determines such action to be in the public interest. Section 7. The proceeds of the Notes shall be deposited in a restricted account within the General Fund and shall be used solely for the payment of duly budgeted current expenses of the General Fund when and to the extent that other moneys on deposit in the General Fund are insufficient therefor. Any portion of said proceeds may be temporarily invested pending such use in securities or investments which are lawful investments for the County. All Taxes levied for General Fund purposes (except Taxes collected for retirement of existing debt) , investment proceeds on such Taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses of the General Fund, received by the County in the Current Fiscal Year after the issuance of the Notes, shall be deposited in a separate restricted account within the General Fund to be known as the "Tax Anticipation Notes, Series 1991A, Principal and Interest Redemption Account" (the Note Account) until such time as the moneys therein are sufficient in the aggregate to pay when due the principal of and interest on the Notes. All moneys in the Note Account not in excess of the amount required to pay when due the principal of and interest on the Notes and all securities in which the same may be invested from time to time are hereby pledged to secure the payment of the principal of and interest on the Notes and shall be used for no other purpose. This pledge shall be valid and binding from and after the first delivery of the Notes, and the moneys so pledged shall immediately be subject to the lien of said pledge without any physical delivery thereof, any filing, or further act. Section 8. The County shall make no investment or other use of the proceeds of the Notes which, if such investment or other use had been reasonably expected on the date of issue of the Notes, would have caused the Notes to be "arbitrage bonds" Page 7 RE: TAX ANTICIPATION NOTES, SERIES 1991A within the meaning of the Internal Revenue Code of 1986, as amended (the Code) , and the regulations thereunder and shall comply with the requirements of the Code and said regulations throughout the term of the Notes. The County hereby designates the Notes as "qualified tax-exempt obligations" under Section 265(b) of the Code. Section 9. All acts, orders, resolutions or parts thereof taken by the County and in conflict with this Resolution are hereby repealed, except that this repealer shall not be construed so as to revive any act, order, resolution or part thereof heretofore repealed. Section 10. This Resolution is, and shall constitute, a legislative measure of the County, and after the Notes are issued, sold and outstanding, this Resolution shall constitute a contract between the County and the registered owners of the Notes and shall be and remain irrepealable until the Notes and the interest thereon shall have been fully paid, satisfied and discharged. Section 11. If any paragraph, clause or provision of this Resolution is judicially adjudged invalid or unenforceable, such judgment shall not affect, impair or invalidate the remaining paragraphs, clauses or provisions hereof, the intention being that the various paragraphs, clauses or provisions hereof are severable. Section 12 . This Resolution shall take effect immediately upon its adoption. Page 8 RE: TAX ANTICIPATION NOTES, SERIES 1991A The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 19th day of December, A.D. , 199Y. tb BO D OF COUNTY COMMISSIONERS ATTEST: WE OUNTY, CO DO ene R. Brantner, Chairman George Ken edy,Pc-Tem ldr t the Board py APPROVED AS TO FORM: Constance L. Hart — C. W. K' County Attorney Go d cy UNITED STATES OF AMERICA STATE OF COLORADO COUNTY OF WELD TAX ANTICIPATION NOTE SERIES 1991A No. R-1 CUSIP: 949221 AB 1 $4 , 350, 000 Original Date Maturity Date Interest Rate Interest Amount January 10, 1991 December 31, 1991 4, 41,751. 25 REGISTERED OWNER: PRINCIPAL SUM: Four i n d Fifty Thousand Dollars Weld County, olorado (the County) , for value received, hereby promises to pay to the Registered Owner (specified above) from ad valorem taxes on real and personal property, investment proceeds on such taxes, and proceeds of the Notes of this issue to the extent not required for the payment of duly budgeted current expenses, received by the County in the fiscal year ending December 31, 1991, and credited to the general fund after the issuance hereof, on the Maturity Date (specified above) , the Principal Sum (specified above) together with interest thereon from the Original Date (specified above) to the Maturity Date at the per annum Interest Rate (specified above) , based upon the actual number of days elapsed in a month of 30 days and a year of 360 days, the amount of said interest being the Interest Amount (specified above) . This Note is issued by the Board of County Commissioners of the County, on behalf of the County, in accordance with part 1 of article 15 of title 29 , Colorado Revised Statutes, as amended (the Act) , and pursuant to a Resolution (the Resolution) of the Board of County Commissioners duly adopted prior to the issuance hereof in order to pay duly budgeted current expenses of the general fund of the County. Reference is hereby made to the Act and the Resolution for a complete statement of the rights and limitations of rights of the Registered Owner, to all of which the Registered Owner by acceptance of this Note assents. This Note is not subject to redemption in whole or in part at any time prior to the Maturity Date. The principal of and interest on this Note are payable upon presentation and surrender hereof at the office of the County Treasurer, as paying agent (the Paying Agent) , either by check or draft mailed to the Registered Owner or by wire transfer to such bank or other depository as the Registered Owner shall designate. So long as the Registered Owner is a securities depository or a nominee thereof, the Registered Owner is to disburse any payments received, through its participants or otherwise, to the beneficial owners of this Note. Neither the County nor the Paying Agent has any responsibility or obligation for the payment to any participant, beneficial owner or other person (except the Registered Owner) of the principal of or interest on this Note. ' " This t i e 2. k to the Board, as registrar (the , '.-egistered Owner, and the princi 1 • ere are payable only to the Register O -gistrar have no responsibility o ig io e • the accuracy of the records of the er r any participant with respect to any ownershi -rest in the Notes or the delivery to any participant, beneficial owner or other person (except the Registered Owner) of any notice with respect to the Notes. This Note is transferable only upon the registration books of the County by the Clerk to the Board, as transfer agent. Unless this Note is presented by an authorized representative of The Depository Trust Company to the County or its agent for registration of transfer, exchange or payment, and any Note is registered in the name of Cede & Co. or such other name as requested by an authorized representative of The Depository Trust Company and any payment is made to Cede & Co. , ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL since the Registered Owner hereof, Cede & Co. , has an interest herein. It is hereby certified, recited and warranted that all acts, conditions and things required to be done, occur or be performed precedent to and in the issuance of this Note have been done, have occurred and have been performed in regular and due form and manner as required by law and that the obligations represented by this Note do not contravene any constitutional or statutory limitation of the State of Colorado. IN TESTIMONY WHEREOF the County has caused this Note to be executed in its name with the manual signature of the Chairman of the Board of County Commissioners, to be sealed with the seal 2 of the County, and to be attested with the manual signature of the Clerk to the Board, all as of the 1Oth day of January, 1991 . WELD COUNTY, COLORADO (COUNTY) ( SEAL ) intik e Board of nt issioners ATT ST: ?• l/ Cler to t e oard 3 ASSIGNMENT FOR VALUE RECEIVED, the undersigned sells, assigns and transfers unto PLEASE INSERT SOCIAL SECURITY OR OTHER IDENTIFYING NUMBER OF ASSIGNEE (Name s e this Note and does SViva \ an appoint to transfer this Noe ooks kept for registration thereof. Dated: Signature guaranteed: (Bank, Trust Company or Firm) NOTICE: The signature to this assignment must correspond with the name of the registered owner as it appears upon the face of this Note in every particular without alteration or enlargement or any change whatever. 4 Oa, PIPER,JAFFR% &HOPWOOD SINCE INS MEMBERSTI CMEMBER NEW YORK INC Suite 1680 1660 Lincoln Street Denver, Colorado 80264 303-839-9300 CLOSING MEMORANDUM TO: Closing Participants FROM: Jim Manire /` /V (r � DATE: January 4, 4 1 RE: Closing Details $4,350,000 WELD COUNTY, COLORADO TAX ANTICIPATION NOTES SERIES 1991A 1. Time of Closing: 10:00 a.m., Thursday, January 10, 1991 2. Place of Closing: Ballard, Spahr, Andrews & Ingersoll 1225 Seventeenth Street Suite 2300 Denver, CO 80202 3. Piper, Jaffray & Hopwood Incorporated ("Piper Jaffray") will pay Weld County, Colorado (the "County") for its legally issued $4,350,000 Series 1991A Tax Anticipation Notes, the amount computed as follows: Par Amount of the Issue $4,350,000 Less: Underwriter's Discount (7,069) Attorney's Fee (4.000) Total Due at Closing $4,338,931 4. Piper Jaffray will wire transfer on the day of closing $4,338,931 to the account to be designated by the County prior to closing. 5. Participants whose signatures have been collected in advance need not be present at closing. 6. A final payment schedule is attached to this memo. $4,350,000 WELD COUNTY, COLORADO TAX ANTICIPATION NOTES SERIES 1991A Closing Participants Weld County 915 19th Street Greeley, CO 80632 Attn: Mr. Don Warden Ballard, Spahr, Andrews & Ingersoll 1225 Seventeenth Street Suite 2300 Denver, CO 80202 Attn: Loring Harkness, Esq. Matt Hogan, Esq. Piper, Jaffray & Hopwood Incorporated 1660 Lincoln Street Suite 1680 Denver, CO 80264 Attn: Mr. Steve Clark Ms. Linda Clark Mr. Paul Ferry Mr. Ken Arney Piper, Jaffray & Hopwood Incorporated 222 South 9th Street Minneapolis, MN 55402 Attn: Mr. Duke Steenson Mr. John Taft Mr. Tim Couture PIPER,k xng&H0P'AO0D WELD COUNTY, COLORADO TAX ANTICIPATION NOTES SERIES 1991A DEBT SERVICE SCHEDULE --` DATE PRINCIPAL COUPON INTEREST PERIOD TOTAL FISCAL TOTAL 12/31/91 4,350,000.00 5.700000 241,751.25 4,591,751.25 4,591,751.25 4,350,000.00 241,751.25 4,591,751.25 ACCRUED 4,350,000.00 241,751.25 4,591,751.25 -------------- -------------- Dated 1/10/91 with Delivery of 1/10/91 Bond Years 4,241.250 Average Coupon 5.700000 Average Life 0.975000 N I C X 5.866667 X Using 99.8375000 T I C X 5.624891 % From Delivery Date COUNTY CERTIFICATE AND RECEIPT The undersigned hereby certify that: They are the duly elected or appointed, qualified, sworn and acting Chairman of the Board of County Commissioners and Clerk to the Board, respectively, of the County. The County is a political subdivision of the State of Colorado and a body politic and corporate duly organized and validly existing under the Constitution and laws of the State of Colorado and its Home Rule Charter, and there is no litigation pending or, to the best of their knowledge, threatened, relating in any way to the existence or boundaries of the County or to the rights of the commissioners and officers thereof to hold their respective positions. The Resolution of the Board of County Commissioners authorizing the issuance of the County's Tax Anticipation Notes, Series 1991A, was duly adopted by the Board of County Commissioners upon motion duly made and seconded and carried by a majority vote of the commissioners present and constituting a quorum thereof at a regular or special meeting thereof duly called and held prior to the issuance of the Notes, and the Resolution has not been repealed, revoked or rescinded and remains in full force and effect on the date hereof. Pursuant to the Resolution the County has established a restricted account within its general fund into which will be deposited the net proceeds of the Notes and has further established within its general fund a separate restricted account known as the "Tax Anticipation Notes, Series 1991A, Principal and Interest Redemption Account" into which will be deposited the moneys pledged to the payment of the principal of and interest on the Notes. The aggregate principal amount of all obligations issued by the County in the current fiscal year in anticipation of the collection of ad valorem taxes on real or personal property is $4 , 350, 000, and the amount of ad valorem taxes on real or personal property estimated to be received by the County in the current fiscal year is $21, 350, 000. The undersigned are duly authorized to execute the Notes and this certificate on behalf of the County. The Notes have been executed with the manual signatures of the undersigned, whose specimen signatures appear below and sealed with the seal of the County. There is no litigation pending or, to the best of their knowledge, threatened, relating in any way to the authorization, issuance or delivery or the legality of the Notes. The facts contained in the Final Offering Circular of the County, dated January 4, 1991, relating to the sale of the Notes are true and correct in all material respects, and the Final Offering Circular does not contain any untrue statements of a material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. The County hereby acknowledges receipt of the full purchase price of the Notes. IN WITNESS WHEREOF, the undersigned have hereunto set their hands and the seal of the County this 10th day of January, 1991. WELD COUNTY, COLORADO By: C n f e oard of unt o s ers (COUNTY) By: ( SEAL ) C erk to the Board 2 COUNTY CERTIFICATE REGARDING FEDERAL TAX MATTERS The undersigned hereby certify and declare in the name and on behalf of the County the following facts, estimates, circumstances and expectations, as of the date of issue of the County's Tax Anticipation Notes, Series 1991A, dated January 10, 1991, in the aggregate principal amount of $4, 350, 000, as follows: 1. Capacity. As duly elected and authorized officers of the County, charged with others with the responsibility of issuing the Notes, our certification may be relied upon as the certification of the "issuer" pursuant to Treasury Regulation §1. 103-13 (a) (2) (ii) . 2. The Notes. 2. 1 Purpose. The Notes are being issued for the purpose of paying duly budgeted current expenses of the general fund of the County. 2 . 2 Note Resolution. The Notes are being issued pursuant to a Resolution duly adopted by the Board of County Commissioners prior to the issuance of the Notes. 2 . 3 Date of Notes; Date of Issue. The Notes are dated their date of issue. 3 . Original Proceeds; Cumulative Cash Flow Deficit; Other Amounts Available for Payment; Period for Which Notes Will Be Outstanding. 3 . 1 Original Proceeds. The amount to be received by the County from the sale of the Notes will be 99.8375% of the par amount thereof. 3. 2 Cumulative Cash Flow Deficit. Based upon the County's estimates of its revenues and expenditures during the period in which the Notes are to be outstanding, as set forth on Exhibit A hereto, the maximum cumulative cash flow deficit for such period is $4, 419, 000. Exhibit A hereto is a true and correct computation of the anticipated cumulative cash flow deficit of the County for the period from January 1, 1991, to December 31, 1991, computed in accordance with Section 1.103-14 (c) of the regulations under Section 103 of the Internal Revenue Code of 1986, as amended (the Code) . 3 . 3 Other Amounts Available for Payment. The County expects to earn no more than $291, 183 .89 on the investment of the original proceeds of the Notes and on the investment of amounts deposited in the "Tax Anticipation Notes, Series 1991A, Principal and Interest Redemption Account" which are to be used to pay the principal of and interest on the Notes. The County expects to spend the sum of $241,751.25 to pay interest on the Notes and the sum of $11, 068 .75 to pay the costs of issuance of the Notes. Thus, there will be no more than $38,363 .89 derived from investment proceeds available for payment of the expenditures set forth on Exhibit A hereto. There will not be any amounts in the general fund of the County or any other fund or account which are available for the payment of the expenditures set forth on Exhibit A hereto which may, without legislative or judicial action, be invaded to pay such expenditures without a legislative, judicial or contractual requirement that any such fund or account be reimbursed other than those set forth therein or herein. 3 .4 Period for Which Notes Will Be Outstanding. The principal of and interest on the Notes will be paid within one year of their date of issue. 4. Note Account. Moneys from ad valorem taxes on real and personal property, investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the current fiscal year and credited to the Note Account after the issuance of the Notes, will be used to pay the principal of and interest on the Notes. There are no other funds created by the Resolution or otherwise available that will be so used. The Note Account will be used primarily to achieve a proper matching of revenues and debt service requirements on the Notes during the period for which the Notes will be outstanding. The Note Account will be depleted at least once a year. It is expected that any moneys deposited in the Note Account will be spent within a thirteen-month period beginning on the date of deposit and that any amount received from the investment of such moneys will be spent within a one-year period beginning on the date of receipt. 5. Arbitrage Rebate. The County expects that the Notes will be exempt from the arbitrage rebate requirements of the Code and the regulations promulgated thereunder, as it is a governmental unit with general taxing powers, the Notes are not private activity bonds, 95% or more of the net proceeds of the Notes are to be used for local governmental activities of the County, and the aggregate face amount of all tax-exempt obligations issued by the County and all subordinate entities during the calendar year 1991 is not reasonably expected to exceed $5, 000, 000. If said expectation is not realized, the 2 County will comply with all arbitrage rebate requirements of the Code. 6. Covenants and Representations. 6. 1 County Covenants. In the Resolution the County covenants that it will make no investment or other use of the proceeds of the Notes at any time during the term thereof which, if such investment or other use had been reasonably expected on the date the Notes were issued, would have caused the Notes to be "arbitrage bonds" within the meaning of the Code and the regulations thereunder and that it will comply with the requirements of said Section and regulations throughout the term of the Notes. The County will also comply with all information reporting requirements of the Code. 6.2 Notification. The County has not been notified of any listing of it by the Internal Revenue Service as an issuer whose certification respecting arbitrage may not be relied upon. 7. Oualified Tax Exempt Obligations. In the Resolution the County designates the Notes as "qualified tax-exempt obligations" under Section 265 (b) of the Code as the Notes are governmental bonds and the aggregate face amount of all governmental bonds and the aggregate face amount of all governmental bonds and 501(c) (3) bonds issued by the County and all subordinate entities during the calendar year 1991 is not reasonably anticipated to exceed $10, 000, 000. 8. Certification. 8. 1 Purpose. This certification is being issued and delivered pursuant to §§ 1. 103-13 and 1. 103-14 of the Treasury Regulations promulgated under Section 103 of the Code. 8.2 Reasonable Expectations. To the best of our knowledge, information and belief, the above expectations are reasonable. 3 IN WITNESS WHEREOF, the undersigned have hereunto set their hands and the seal of the County this 10th day of January, 1991. WELD COUNTY, COLORADO By: -n o t` ' Boa • of C ty (COUNTY) ( SEAL ) By: lerk o e Board 4 EXHIBIT A (1) (2) (3) (4) (5) Cumulative Surplus(Deficit) Cumulative (2 virus 1 plus or Reasonably Cash Flow Estimated Estimated minus previous figure Required Cash Surplus(Deficit) Jxvendiures 1teceipts in this column) Balance (3 minus 4) Opening Balance $ 690,000 January $4,119,000 $ 760,000 (2,669,000) $1,750,000 $(4,419,000) February 1,750,000 1,520,000 (2,899,000) 1,046,000 (3,945,000) March 1,046,000 2,530,000 (1,415,000) 1,700,000 (3,115,000) April 1,700,000 3,780,000 665,000 1,320,000 (655,000) May 1,320,000 1,846,000 1,191,000 1,320,000 (129,000) June 1,320,000 1,020,000 891,000 1,585,000 (694,000) July 1,585,000 3,350,000 2,656,000 1,450,000 1,206,000 August 1,450,000 2,180,000 3,386,000 2,280,000 1,106,000 September 2,280,000 950,000 2,056,000 1,320,000 736,000 October 1,320,000 945,000 1,681,000 1,450,000 231,000 November 1,450,000 1,195,000 1,426,000 2,107,000 (681,000) December 2,107,000 1,274,000 593,000 0 593,000 5 Fars, 8038-G Information Return for Tax-Exempt Governmental Obligations (Rev.October 1989) a Under Seddon 149(e) OMB No.1545-0720 Department of the Treasury le on separate Instructions Expires•5-31-92 internal Revenue Service (Use Form 8038-GC if the issue price is under 6100,000) ® Reporting Authority Check box if Amended Return ► If I Issuer's name 2 Issuer's employer identification number Weld County, Colorado 84-6000813 3 Number and street 4 Report number 915 10th Street G1991 - 1 5 City or town,state.and ZIP code , 6 ()steel issue Greeley, Colorado 80632 January 10. 1991 7 Name of Issue I CUSIP Number Tax Anticipation Notes, Series 1991A 949221 AB 1 Part II Type of Issue(check box(es)that applies and enter the Issue Price) 9 Check box if obligations are tax or other revenue anticipation bonds to ® sue price 10 Check box if obligations are in the form of a lease or installment sale► ❑ 11 ® Education 1 4,350,000 12 0 Heatth and hospital . 13 0 Transportation 14 0 Public safety 15 0 Environment(including sewage bonds) 16 0 Housing 17 0 Utilities is 0 Other.Describe(see Instructions)* Part uI Description of Obligations to P) (c) Stated (redemption wateet)+ted (f) Net interest Maturity date Interest rate Issue price price at maturity matu- Yield cast 19 Final maturity . 5.70 . 4,_350,000 $4.350.000 %//////irli//////%/i W//////////�//////i 20 Entire issue . . ;%//////////////////////////////i//////////////////. $4,350,000 $4.350.000 .975 years N/C C % 5.70 % • rt IV Uses of Original Proceeds of Bond Issues(including underwriters'discount) 21 Proceeds used for accrued interest 21 —0- 22 Issue price of entire issue(enter line 20c) 22 4 350 000 23 Proceeds used for bond issuance costs(including underwriters'discount). 23 $ 11,069 %/%%/////%%� / 24 —0— %% �/// 24 Proceeds used for credit enhancement 25 Proceeds allocated fu reasonably regwredreserve or replacement fund 26 —0— "C���i7//��/ /// 26 Proceeds used to refund prior issues 27 Total(add lines 23,24,25,and 26) 27 $ 11 ,069 28 Nonrefunding proceeds of the issue(subtract line 27 from line 22 and enter amount here) 28 $4,338,931 Part V Description of Refunded Bonds(complete this part only for refunding bonds) 29 Enter the remaining weighted average maturity of the bonds to be refunded 0 years 30 Enter the last date on which the refunded bonds will be called 0 31 Enter the date(s)the refunded bonds were issued ► Part VI Miscellaneous 32 Enter the amount of the state volume cap allocated to the issue ► 33 Enter the amount of the bonds designated by the issuer under section 265(bX3X8XiXlll) (small ► $4,350,000 issuer exception) 34 Pooled financings: a Enter the amount of the proceeds of this issue that are to be used to make bans to other governmental units 0 b Check box if this issue is a loan made from the proceeds of another tax-exempt issue to 0 and enter the name of the issuer ► and the date of the issue ► Under peratties rryry,I declare that I have a amined Mm return end accompanying scJedur and Wtement.and a to bast of my snowedae and belef, trey are true. ,and complete. . i Siga6! G /Z� Donald D. Warden Sign i��� any 10, 1991 Finance Director Here Seratore of officer Date ,Type or print name ant title For Paperwork Reduction Act Notice,see page 1 of the Instructions. Form 8038G (Rev 10-89) e0.e. anaraint eesaia Min tea,-2e2-iet,asotf LAW OFFICES BALLARD, SPAHR, ANDREWS a INGERSOLL 30 SOUTH ITmF'0 STREET SUITE 2300 PHILADELPHIA,PA 19103 1225 17TH STREET ONE WESTLAKES 1235 WESTLAKES DRIVE DENVER, COLORADO 80202 BERWYN, PA 19312 303 292-2400 SIESMAYERSTRASSE 44 0 6000 FRANKFURT/MAIN I TELECOPIER:303 296-3956 FEDERAL REPUBLIC OF GERMANY CABLE BALLARD AMERICAN PLAZA S, SUITE 400 57 WEST 200 SOUTH SALT LAKE CITY, UT 84101 SUITE 90 EAST LORING E. HARKNESS III 555 13TH ST 0REET. N w. WASHINGTON, O. C. 20004 January 10, 1991 Internal Revenue Service Center Philadelphia, PA 19255 Attention: Director Re: Weld County, Colorado Tax Anticipation Notes Series 1991A Dated January 10, 1991 - $4 , 350, 000 Dear Director: Enclosed herewith are three (3) copies (one originally executed) of the Information Return for Tax-Exempt Governmental Bond Issues (Form 8038-G) with respect to the above-referenced issue. This return is being filed pursuant to Section 149 (e) of the Internal Revenue Code of 1986, as amended. Please file the original of the enclosed return and acknowledge receipt on the copies and return them separately to the issuer and the undersigned in the self-addressed envelopes provided for your convenience. Thank you for your assistance. Very truly yours, -14 Loring E. Harkness III LEH:dal Enclosures cc: Mr. Donald D. Warden Certified P 557 612 868 Return Receipt Requested P-557 612 868 LEH/WELD R.._ FOR CERTIFIED MAL , Internal Revenue Service ', Philadelphia, PA 19255 � 45 r 8� I 90 /;} • 1I if Z E 1 ,v� •C I KY' ai S UNDERWRITER'S RECEIPT The undersigned on behalf of the underwriter of the Weld County, Colorado, Tax Anticipation Notes, Series 1991A, dated January 10, 1991, in the aggregate principal amount of $4, 350, 000 hereby acknowledges receipt of the Notes. IN WITNESS WHEREOF, the undersigned has hereunto set his hand this 10th day of January, 1991. PIPER, JAFFRAY & HOPWOOD, INCORPORATED ' /J • By: L 4-t-t,,,c. Ti le: w'- ^+*.s...t..J LAW OFFICES 2OrK FLOOR BALLARD, SPAHR, ANDREWS & INGERSOLL 30 SOUTH I7FK STREET SUITE 2300 PHILADELPHIA,PA 19103 ONE WESTLAKES 1225 17TH STREET 1235 WESTLAKES DRIVE DENVER, COLORADO 80202 BERWVN, PA 19312 303 202-2400 SIESMAYERSTRASSE 44 D 6000 FRANKFURT/MAIN I TELECOPIER PIER:303 296-3956 FEDERAL REPUBLIC OF GERMANY CABLE: BALLARD AMERICAN PLAZA II, SUITE 400 57 WEST 200 SOUTH SALT LAKE CITY, UT 64101 SUITE 900 EAST 555 I3rr STREET, N.W. WASHINGTON, D.0. 20004 January 10, 1991 Piper, Jaffray & Hopwood, Incorporated 1660 Lincoln Street Denver, Colorado 80264 Re: Weld County, Colorado Tax Anticipation Notes Series 1991A Dated January 10, 1991 - $4, 350, 000 Ladies and Gentlemen: We have acted as bond counsel in connection with the issuance by Weld County, Colorado (the County) , of its Tax Anticipation Notes, Series 1991A, dated January 10, 1991, in the aggregate principal amount of $4, 350, 000 (the Notes) , issued for the purpose of paying duly budgeted current expenses of the general fund of the County. The Notes are issued in fully registered form and are initially registered in the name of Cede & Co. , as nominee of The Depository Trust Company, as securities depository for the Notes. Purchases by beneficial owners of the Notes are to be made in book-entry form in the principal amount of $5, 000 or any integral multiple thereof. Beneficial owners are not to receive certificates evidencing their interests in the Notes. The principal of and interest on the Notes are payable on December 31, 1991, upon presentation and surrender thereof at the office of the County Treasurer, as paying agent, by check or draft mailed to the registered owner at the address appearing on the registration books of the County maintained by the Clerk to the Board of County Commissioners, as registrar and transfer agent, or by wire transfer to such bank or other depository as the registered owner shall designate. So long as the registered owner is a securities depository or a nominee thereof, the securities depository is to disburse any payments received, through its participants or otherwise, to the beneficial owners of the Notes. Neither the County nor the paying agent has any responsibility or obligation for the payment to any participant, any beneficial owner or any other person (except the registered owner of the Notes) of the principal of or interest on the Notes. The Notes bear interest at the rate of five and seventy hundredths percent (5.70%) per annum from their date to their maturity date. The Notes are not subject to redemption in whole or in part at any time prior to maturity. The Resolution of the Board of County Commissioners authorizing the issuance of the Notes (the Resolution) provides that the principal of and interest on the Notes shall be payable from ad valorem taxes on real and personal property, investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the current fiscal year and credited to its general fund after the issuance of the Notes. The Resolution also contains a covenant by the County that it will make no investment or other use of the proceeds of the Notes, which, if such investment or other use had been reasonably expected on the date of issue of the Notes, would have caused the Notes to be "arbitrage bonds" within the meaning of the Internal Revenue Code of 1986, as amended (the Code) , and the regulations thereunder and that it will comply with the requirements of the Code and said regulations throughout the term of the Notes. Officers of the County responsible for issuing the Notes have executed a certificate (the Certificate) stating the reasonable expectations of the County as of the date of issue of the Notes as to future events that are material for purposes of the Code and making certain covenants on behalf of the County relating to compliance therewith. In the Resolution the County has also designated the Notes as "qualified tax-exempt obligations" under Section 265 (b) of the Code. In our capacity as bond counsel we have examined the laws and the Constitution of the State of Colorado, the Resolution, the certificates delivered by the County as of the date of delivery of and payment for the Notes, and such other documents as we deemed necessary in order to render this opinion. We have also examined a representative executed Note and have assumed that all other Notes have been similarly executed. Based upon the foregoing examination, it is our opinion that: 2 1. The Resolution has been duly adopted and the Notes have been duly authorized, executed and delivered by the County under the laws of the State of Colorado now in force. 2. The Notes are valid and legally binding obligations of the general fund of the County payable solely from ad valorem taxes on real and personal property, investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the current fiscal year and credited to its general fund after the issuance of the Notes. 3 . The Notes are enforceable according to their terms, except to the extent such enforcement is limited by bankruptcy and other laws of general application relating to or affecting the enforcement of creditors' rights, by the reasonable exercise of the sovereign police power of the State of Colorado, and by the exercise of the powers delegated to the United States of America by the federal Constitution. Based upon the foregoing examination and our review of the Code and the regulations and rulings thereunder and of the Certificate and assuming compliance by the County with certain covenants contained in the Resolution and the Certificate, it is also our opinion that: 1. The Notes are not arbitrage bonds within the meaning of the Code. 2 . Interest on the Notes is excluded from gross income for federal income tax purposes under the laws and regulations of the United States of America as presently enacted and construed. 3 . Interest on the Notes is not an item of preference for purposes of computing the individual or corporate alternative minimum tax under the laws and regulations of the United States of America as presently enacted and construed. However, interest on Notes held by corporations (other than regulated investment companies, real estate investment trusts, real estate mortgage investment conduits and certain S corporations) may be indirectly subject to the alternative minimum tax or the environmental tax because of its inclusion in the earnings and profits of corporations, and interest on Notes held by foreign corporations may be subject to the branch profits tax imposed by the Code. 4 . The Notes are "qualified tax-exempt obligations" under Section 265 (b) of the Code for purposes of determining the deductibility of interest expenses of banks and other financial institutions holding the Notes. 3 5. Interest on the Notes is exempt from State of Colorado income taxes under the laws of the State of Colorado as presently enacted and construed. Ownership of tax-exempt obligations may result in collateral federal income tax consequences to certain taxpayers, including, without limitation, financial institutions, property and casualty insurance companies, S corporations with "excess passive income, " individual recipients of Social Security or Railroad Retirement benefits, foreign corporations engaged in a trade or business in the United States and taxpayers who may be deemed to have incurred or continued debt to purchase or carry such obligations. We express no opinion herein with respect to such consequences. We also express no opinion herein with respect to the accuracy or completeness of any documents prepared or used or statements made in connection with the offering or sale of the Notes. Very truly yours, / 4 PRELIMINARY OFFERING CIRCULAR Dated: December 20, 1990 New Issue Not Rated Bank Qualified In the opinion of Bond Counsel, interest on the Notes is excluded from gross income for federal income tax purposes, is exempt from Colorado income tax and is not an item of preference for purposes of computing the individual or corporate alternative minimum tax, to the extent, upon the conditions and subject to the limitations stated under "TAX EXEMPTION". $4,400,000* WELD COUNTY, COLORADO Tax Anticipation Notes, Series 1991A Dated: As of Delivery Due: December 31, 1991 The Notes are being issued as fully registered Notes without coupons. Interest, at the rate set forth below, is computed on a basis of a 360-day year and is payable on December 31, 1991. The Notes are not subject to redemption in whole or in part at any time. AMOUNT MATURITY RATE PRICE $4,400,000* 12-31-91 The Notes are payable solely from ad valorem taxes on real and personal property previously levied, investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the current fiscal year and credited to the General Fund after the issuance of the Notes. The Notes are offered when, as, and if issued by the County subject to the approving legal opinion of Bond Counsel, Ballard, Spahr, Andrews & Ingersoll, Denver, Colorado. The matters passed upon by Bond Counsel do not extend beyond the validity and enforceability of the Notes and the tax treatment of interest thereon under Federal and State of Colorado income tax laws, and Bond Counsel has no responsibility for the accuracy, completeness of fairness of statements made to any persons in connection with any offer or sale of the Notes in this document or otherwise. PIPER, JAFFRAY & HOPWOOD INCORPORATED * Preliminary; Subject to change. 1 Certain of the information contained herein has been obtained from the issuer of the Notes identified herein (the "County") and other sources which are believed to be reliable. Such information is neither guaranteed as to accuracy or completeness nor is to be construed as a representation by Piper, Jaffray &Hopwood Incorporated (the "Underwriter"). The information and expressions of opinion herein are subject to change without notice, and neither the delivery of this Offering Circular nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the County, since the date hereof. This Offering Circular doe not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of the Notes, in any jurisdiction in which it is unlawful for any person to make such an offer, solicitation or sale. No dealer, broker, salesman or other person has been authorized to give any information or to make any representations other than as contained in this Offering Circular. If given or made, such other information or representations must not be relied as having been authorized by the County or the Underwriter. The summaries of various statutes, resolutions, and other documents contained herein are intended as summaries only and are qualified in their entirety by reference to the originals thereof, copies of which are available from the Underwriter or the County during the period of the original offering of the Notes, upon reasonable request and payment of the reasonable costs of copying the same. IN CONNECTION WITH THIS OFFERING, THE UNDERWRITER MAY OVER ALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE MARKET PRICE OF THE NOTES AT A LEVEL ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. 2 INFORMATION This Offering Circular is provided to furnish certain information in connection with the issuance by Weld County, Colorado (the "County") of its Tax Anticipation Notes, Series 1991A, in the aggregate principal amount of $4,400,000* (est.) (the "Notes") to be issued pursuant to a Resolution (the "Resolution") adopted by the Board of County Commissioners of the County on December 19, 1990. The Notes are being issued to pay duly budgeted current General Fund expenses. Brief descriptions of the County and the Notes are included in this Offering Circular. Such descriptions do not purport to be comprehensive or definitive. All reference herein to the Resolution, the Notes, and other documents are qualified in their entirety by reference to such documents or to the form of the Notes, copies of which are available for inspection in the office of the County. THE NOTES Description The Notes are to be issued by the County in an aggregate principal amount of no more than $4,400,000, to be dated as of their delivery, to be registered as to principal and interest, to bear interest from issue date to maturity at the rate per annum set forth on the Cover Page hereof, computed on the basis of a 360-day year. The Notes will pay interest and mature on December 31, 1991. The principal of and interest on the Notes are payable at maturity, upon surrender of the Notes, to the office of the County Clerk, either by check or draft mailed to the registered owner or by wire transfer to such bank or depository as the registered owner shall designate. Redemption Provisions Notes of this issue are not subject to redemption prior to maturity. Authorization The Notes are issued pursuant to the Resolution and the Constitution and laws of the State of Colorado, including, in particular, the provisions of the Tax Anticipation Note Act (the "Act"), Section 29-15-101 et seq., Colorado Revised Statutes, as amended. The Act permits the County to issue tax anticipation notes by resolution in an amount not to exceed fifty percent (50%) of all ad valorem taxes estimated by the County to be received in the current fiscal year. Security The proceeds of the Notes are to be deposited in the General Fund of the County and are to be used solely for the payment of duly budgeted current expenses when and to the extent that other moneys on deposit in the General Fund are insufficient therefor; provided however, that any 3 portion of the proceeds may be temporarily invested in securities or investments which are lawful investments for the County. All ad valorem personal and real property taxes ("Taxes") levied for General Fund purposes (except Taxes collected for retirement of existing debt,) investment proceeds on such Taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the Current Fiscal Year after the issuance of the Notes are to be deposited in a restricted account within the General Fund to be known as the "Tax Anticipation Notes, Series 1991A, Principal and Interest Redemption Account" (the "Note Account") until such time as the moneys are sufficient to pay when due the principal required to pay when due the principal of and interest on the Notes, and all securities in which the same may be invested from time to time, are pledged to secure the payments of the principal of and interest on the Notes. Investment of Proceeds Proceeds of the Notes and moneys held in the Note Account will, pending their use, be invested in securities which are legal investments for Colorado counties or deposited in eligible public depositories, with such deposits being insured or collateralized as required by law. THE COUNTY Weld County, established in 1861, is located at the north central part of the State and is the third largest county in Colorado, covering an area of approximately 4,033 square miles. The surface is level to rolling prairies with low hills near the western border. Elevation ranges from 4,400 to 5,000 feet. The South Platte River and its tributaries, the Cache La Poudre, Big Thompson, Little Thompson, Boulder, and St. Vrain enter from the south and west and leave the county on the east. The county seat is located in the City of Greeley (est. pop. 62,000) which is 60 miles north of Denver on State Highway 85. Weld County ranked as the fourth most productive agricultural county in the nation and the third most productive oil and gas county in the Rocky Mountain Region during 1989. More than 85 percent of its area is devoted to irrigated and dryland farming and livestock raising. Weld County incorporates one of the nation's largest irrigated areas: 647,000 acres of the 2,500,000 acres in Weld County are irrigated by a combination of mountain run-off, which is controlled by eight major irrigation companies and 4,000 wells. The reservoir storage and stream run-off supply an annual average of 900,000 acre feet while the wells supply approximately 250,000 acre feet of water. The Colorado Big Thompson Water Diversion Project supplies approximately 300,000 acre feet of water annually. Water is diverted to farms and ranches via an extensive system of irrigation canals. Oil and gas play an important role in the economic picture of Weld County. Wattenberg Gas field, part of which is located in the southern part of Weld County, was discovered by Amoco Oil Company, the prime developer of the field. Amoco Oil has estimated that this field contains approximately 400 billion feet of gas reserves. The gas that is being produced by the Wattenberg Field is delivered to the Public Service Company of Colorado. This potentially 4 great gas accumulation covers nearly 1,000 square miles. Wattenberg Field is also producing some oil. Development of oil and gas wells has had an increasingly more significant impact on the economy of Weld County in the past ten years. FINANCIAL INFORMATION CONCERNING THE COUNTY The financial operations of the County are, pursuant to State law, conducted primarily through its General Fund. General Fund The General Fund is the major operating fund of the County, providing most of the resources for the County's general operations. General fund revenues amounted to $20,491,136 in 1989, an increase of 10.7% from 1988. Property Tax Collection Taxes levied in one year are collected in the next; thus 1990 taxes will be collected in 1991. Taxes are said to be due January 1 in the year of collection; however, they may be paid in two installments, without interest penalty, if the payments are made by February 28 and by July 31 of the collection year. The property owner may elect to make only one payment, and if made by April 30, it is also free of interest penalty. All taxes levied on property, together with interest thereon and penalties for default, as well as all other costs of collection, constitute a perpetual lien on and against the property taxes, and such lien is on a parity with the tax liens of other general taxes. In the event collection of property taxes becomes impossible, the County Treasurer may distrain, seize, and sell property to enforce the collection of delinquent taxes on property. There can be no assurance that the value of specific property, in the event of foreclosure and sale by the Weld County Treasurer, would be sufficient to produce the amount required with respect to taxes levied by the County and by overlapping taxing entities. 5 Property Tax Levies and Collections in the County Collection Total Tax Total % of Year Levy Collected Collections 1981 $12,622,216 $12,596,620 99.68 1982 13,252,865 13,169,249 99.37 1983 14,399,734 14,307,719 99.36 1984 15,119,720 14,985,503 99.11 1985 15,875,706 15,469,833 97.44 1986 17,147,925 17,013,025 99.20 1987 18,005,273 17,756,037 98.60 1988 18,931,528 18,506,143 97.75 1989 20,534,080 20,153,920 98.13 1990 21,449,358 21,127,077 * 98.50 * *Through November 30, 1990. Source: Weld County 1989 Annual Financial Report, Weld County Treasurer's Office Historical Property Tax Data Set forth below is certain historical information concerning mill levies, assessed valuation and property tax collection for the County. Mill Levy Histori 1982 - 1990 Collection Year 1983 17.172 1984 17.369 1985 19.342 1986 19.342 1987 19.968 1988 17.208 1989 19.268 1990 20.892 1991 22.210 Source: Weld County 1989 Annual Financial Report, and Weld County Assessor's Office 6 Total Assessed Valuation of the County 1980 - 1990 Budget Assessed Percent Year Valuation Increase 1980 $ 677,285,480 9.8% 1981 731,849,970 9.3% 1982 771,771,770 9.5% 1983 870,453,500 8.9% 1984 820,747,830 (1.1%) 1985 886,564,250 9.3% 1986 813,134,000 (8.3%) *1987 1,118,963,490 37.6% 1988 1,062,703,770 (5.0%) 1989 1,021,455,100 (3.9%) 1990 1,008,659,220 (1.3%) *Reassessment mandated by Colorado statute changed the base year of market value for valuation from 1977 in 1986 to 1985 in 1987. Source: Weld County 1989 Annual Financial Report, Weld County Assessor's Office Direct Indebtedness The county currently has no outstanding debt. TAX-EXEMPTION In the opinion of Bond Counsel, assuming the accuracy of certain certifications of the County regarding federal income tax matters and continuing compliance with the requirements of the Internal Revenue Code of 1986, as amended, interest on the Notes is excluded from gross income tax purposes and is not an item of preference for purposes of either the individual or corporate alternative minimum tax under the laws and regulations of the United States of America as presently enacted and construed. However, interest on Notes held by corporations (other than regulated investment companies, real estate investment trusts, real estate mortgage investment conduits and certain S corporations) may be directly subject to the alternative minimum tax and the environmental tax because of its inclusion in the reported income or current earning of corporations, and interest on Notes held by foreign corporations may be subject to the branch profits tax. In the opinion of Bond Counsel, the Notes are "qualified tax-exempt obligations" under Section 265(b) of the Code for purposes of determining the deductibility of interest expense of banks and other financial institutions holding the Notes. Ownership of tax-exempt obligations may result in collateral federal income tax consequences to certain taxpayers, including, without limitation, financial institutions, property and casualty insurance companies, S corporations, individual recipients of Social Security or Railroad 7 Retirement benefits, foreign corporations engaged in a trade or business in the United States and taxpayers who may be deemed to have incurred or continue debt to purchase or carry such obligations. Bond Counsel will express no opinion with respect to such consequences. Prospective purchasers of the Notes should consult their own tax advisors as to such consequences. In the opinion of Bond Counsel, interest on the Notes is also exempt from Colorado income taxation under the laws of the State of Colorado as presently enacted and construed. LEGAL MATTERS Legal matter incident to the authorization and issuance of the Notes are subject to approval by Ballard, Spahr, Andrews & Ingersoll, Denver, Colorado, Bond Counsel, whose approving opinion on such matters is expected to state in substance that the Notes are valid and binding obligations of the general fund the County payable solely from ad valorem taxes on real and personal property previously levied, incorporated and investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County and credited to its general fund in the current fiscal year after the issuance of the Notes and that the Notes are enforceable according to the terms, except to the extent such enforcement is limited by the bankruptcy and other laws affecting the enforcement of creditors' rights, by the reasonable exercise of the police power of the State of Colorado and by the exercise of the powers delegated to the United States of America by the Federal Constitution. Bond Counsel has assumed no responsibility to make independent verifications or confirmations of the statements make in this Offering Circular or otherwise in connection with the sale of the Notes. RATING These Notes have not been rated by any municipal rating service. UNDERWRITER The Notes are being purchased pursuant to negotiation by Piper, )affray & Hopwood Incorporated, Denver, Colorado, at a discount of 8 WELD COUNTY 1990 CASH FLOW SUMMARY GENERAL FUND ($000's) Cumulative Estimated Estimated Surplus Expenditures Receipts (Deficit) Opening Balance - - $690 January $4,119 $ 760 ($2,669) February 1,750 1,520 (2,899) March 1,046 2,530 (1,415) April 1,700 3,780 665 May 1,320 1,846 1,191 June 1,320 1,020 891 July 1,585 3,350 2,656 August 1,450 2,180 3,386 September 2,280 950 2,056 October 1,320 945 1,681 November 1,450 1,195 1,426 December 2.107 1.274 593 Total Budget $21.447 $21350 9 FINAL OFFERING CIRCULAR Dated: January 9, 1991 New Issue Not Rated Book-Entry Only Bank Qualified In the opinion of Bond Counsel, interest on the Notes is excluded from gross income for federal income tax purposes, is exempt from Colorado income taxes and is not an item of preference for purposes of computing the individual or corporate alternative minimum tax, to the extent, upon the conditions and subject to the limitations stated under "TAX EXEMPTION". $4,350,000 WELD COUNTY, COLORADO Tax Anticipation Notes, Series 1991A Dated: January 10, 1991 Due: December 31, 1991 AMOUNT MATURITY RATE PRICE $4,350,000 12-31-91 5.70% 100% Principal of and interest on the Notes are payable at maturity upon presentation and surrender of the Notes to the Treasurer of the County by check or draft or by wire transfer to the registered owner of the Notes. The Notes are issuable in fully registered form and are initially to be registered in the name of Cede & Co., as nominee of The Depository Trust Company, as securities depository for the Notes. Purchases by beneficial owners are to be made in book- entry form in the principal amount of $50,000 or any integral multiple thereof. Beneficial owners are not to receive certificates evidencing their interests in the Notes. The Notes are not subject to redemption prior to maturity. The Notes are payable solely from ad valorem taxes on real and personal property previously levied, investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the current fiscal year and credited to the General Fund after the issuance of the Notes. The Notes are offered when, as, and if issued by the County subject to the approving legal opinion of Bond Counsel, Ballard, Spahr, Andrews & Ingersoll, Denver, Colorado. PIPER, JAFFRAY & HOPWOOD INCORPORATED 1 The matters passed upon by Bond Counsel do not extend beyond the validity and enforceability of the Notes and the tax treatment of interest thereon under Federal and State of Colorado income tax laws, and Bond Counsel has no responsibility for the accuracy, completeness or fairness of statements made to any persons in connection with any offer or sale of the Notes in this document or otherwise. Certain of the information contained herein has been obtained from the issuer of the Notes identified herein (the "County") and other sources which are believed to be reliable. Such information is neither guaranteed as to accuracy or completeness nor is to be construed as a representation by Piper, Jaffray &Hopwood Incorporated (the "Underwriter"). The information and expressions of opinion herein are subject to change without notice, and neither the delivery of this Offering Circular nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the County, since the date hereof. This Offering Circular does not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of the Notes, in any jurisdiction in which it is unlawful for any person to make such an offer, solicitation or sale. No dealer, broker, salesman or other person has been authorized to give any information or to make any representations other than as contained in this Offering Circular. If given or made, such other information or representations must not be relied upon as having been authorized by the County or the Underwriter. The summaries of various statutes, resolutions, and other documents contained herein are intended as summaries only and are qualified in their entirety by reference to the originals thereof, copies of which are available from the Underwriter or the County during the period of the original offering of the Notes, upon reasonable request and payment of the reasonable costs of copying the same. IN CONNECTION WITH THIS OFFERING, THE UNDERWRITER MAY OVERALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE MARKET PRICE OF THE NOTES AT A LEVEL ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. 2 INFORMATION This Offering Circular is provided to furnish certain information in connection with the issuance by Weld County, Colorado (the "County") of its Tax Anticipation Notes, Series 1991A, in the aggregate principal amount of $4,350,000 (the "Notes") to be issued pursuant to a Resolution (the "Resolution") adopted by the Board of County Commissioners of the County on December 19, 1990. The Notes are being issued to pay duly budgeted current General Fund expenses. Brief descriptions of the County and the Notes are included in this Offering Circular. Such descriptions do not purport to be comprehensive or definitive. All reference herein to the Resolution, the Notes, and other documents are qualified in their entirety by reference to such documents or to the form of the Notes, copies of which are available for inspection in the office of the County. THE NOTES Description The Notes are to be issued by the County in an aggregate principal amount of no more than $4,350,000, to be dated as of their delivery, to be registered as to principal and interest, to bear interest from issue date to maturity at the rate per annum set forth on the Cover Page hereof, computed on the basis of a 360-day year. The Notes will pay interest and mature on December 31, 1991. The principal of and interest on the Notes are payable at maturity, upon surrender of the Notes, to the office of the County Treasurer, either by check or draft mailed to the registered owner or by wire transfer to such bank or depository as the registered owner shall designate. Redemption Provisions Notes of this issue are not subject to redemption prior to maturity. Authorization The Notes are issued pursuant to the Resolution and the Constitution and laws of the State of Colorado, including, in particular, the provisions of the Tax Anticipation Note Act (the "Act"), Section 29-15-101 et seq., Colorado Revised Statutes, as amended. The Act permits the County to issue tax anticipation notes by resolution in an amount not to exceed fifty percent (50%) of all ad valorem taxes estimated by the County to be received in the current fiscal year. Security The proceeds of the Notes are to be deposited in the General Fund of the County and are to be used solely for the payment of duly budgeted current expenses when and to the extent that other 3 moneys on deposit in the General Fund are insufficient therefor; provided however, that any portion of the proceeds may be temporarily invested in securities or investments which are lawful investments for the County. All ad valorem personal and real property taxes ("Taxes") levied for General Fund purposes (except Taxes collected for retirement of existing debt,) investment proceeds on such Taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County in the Current Fiscal Year after the issuance of the Notes are to be deposited in a restricted account within the General Fund to be known as the "Tax Anticipation Notes, Series 1991A, Principal and Interest Redemption Account" (the "Note Account") until such time as the moneys are sufficient to pay when due the principal of and interest on the Notes, and all securities in which the same may be invested from time to time, are pledged to secure the payments of the principal of and interest on the Notes. Investment of Proceeds Proceeds of the Notes and moneys held in the Note Account will, pending their use, be invested in securities which are legal investments for Colorado counties or deposited in eligible public depositories, with such deposits being insured or collateralized as required by law. Payment and Registration The Notes are issuable in fully registered form and are initially to be registered in the name of Cede & Co., a nominee of The Depository Trust Company, as securities depository for the Notes. Purchases by beneficial owners of the Notes ("Beneficial Owners") are to be made in book-entry form in the principal amount of $50,000 or any integral multiple thereof. The principal of and interest on the Notes are payable at maturity upon presentation and surrender thereof to the Treasurer of the County, as paying agent (the "Paying Agent"), by check or draft or by wire transfer to the registered owner at the address appearing on the registration books of the County maintained by the Treasurer of the County, as registrar (the "Registrar"). Payments to Beneficial Owners are to be made as described below under "THE NOTES - BOOK-ENTRY FORM." Transfer and Exchange The Notes are transferable only upon the registration books of the County by the Treasurer of the County, as transfer agent, at the request of the registered owner. Transfers by Beneficial Owners are to be made as described below under "THE NOTES - BOOK-ENTRY FORM." Book-Entry Form The Depository Trust Company, New York, New York ("DTC"), will act as securities depository for the Notes. One fully registered Note, in the aggregate principal amount of the issue, will be registered in the name of Cede & Co., as nominee of DTC. DTC is a limited- purpose trust company organized under the laws of the State of New York, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform 4 Commercial Code and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934, as amended. DTC was created to hold securities of its participants (the "Participants") and to facilitate the clearance and settlement of securities transactions among Participants in such securities through electronic book-entry changes in accounts of the Participants, thereby eliminating the need of physical movement of securities certificates. Participants include securities brokers and dealers, banks trust companies, clearing corporations and certain other organizations, some of whom (and/or their representatives) own DTC. Access to the DTC system is also available to others such as banks, brokers, dealers and trust companies that clear through or maintain a custodial relationship with a Participant, either directly or indirectly. Ownership interests in the Notes may be purchased by or through Participants. Such Participants and the persons for whom they acquire interests in the Notes as nominees will not receive certificated Notes, but each such Participant will receive a credit balance in the records of DTC in the amount of such Participant's interest in the Notes, which will be confirmed in accordance with DTC's standard procedures. Each such person for which a Participant has an interest in the Notes, as nominee, may desire to make arrangements with such Participant to receive a credit balance in the records of such Participant to have all notices or other communications of the County to DTC, which may affect such persons, forwarded in writing by such Participant and to have notification made of all interest payments. Neither the County, the Paying Agent nor the Registrar has any responsibility or obligation to any Participant or to any person on behalf of whom a Participant holds an interest in the Notes with respect to payments and notices. The obligations of the Participants to the Beneficial Owners and of DTC to the Participants with respect to interests in the Notes are established by the rules and procedures used by such Participants and DTC. DTC will receive payment from the Paying Agent to be remitted to the Participants for subsequent disbursement to the Beneficial Owners. The ownership interest for each Beneficial Owner in the Notes will be recorded on the records of the Participants, whose ownership interest will be recorded on a computerized book-entry system operated by DTC. When reference is made to any action which is required or permitted to be taken by the Beneficial owners, such reference relates only to those permitted to act by stature, regulation or otherwise on behalf of such Beneficial Owners for such purposes. When notices are given, they are to be sent to DTC with a request that DTC forward (or cause to be forwarded) the notices to the Participants so that such Participants may forward (or cause to be forwarded) the notice to the Beneficial Owners. Beneficial Owners will receive a written confirmation of their purchase detailing the terms of the Notes acquired. Transfers of ownership interest in the Notes will be accomplished by book- entries made by DTC and the Participants who act on behalf of the Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in the Notes. Principal and interest will be paid by the Paying Agent to DTC, then paid by DTC to the Participants and thereafter paid by the Participants to the Beneficial Owners when due. 5 For every transfer and exchange of the Notes or an interest therein, the Beneficial Owner may be charged a sum sufficient to cover any tax, fee or other governmental charge that may be imposed in relation thereto. DTC's services with respect to the Notes may be discontinued or terminated at any time under the following circumstances: (i) DTC may determine to discontinue providing its services with respect to the Notes at any time by giving notice to the County and discharging its responsibilities with respect thereto under applicable law. (ii) The County may remove DTC. In the event that DTC's services are so discontinued or terminated because it is unwilling or is determined to be unable to discharge its responsibilities or DTC is removed or resigns, and no substitute securities depository willing to undertake the functions of DTC can be found which, in the opinion of the County, is willing and able to undertake such functions upon reasonable and customary terms, or in the event it is so determined that continuation of the system of book- entry transfers is not in the best interests of the Beneficial Owners, the County will be obligated to deliver certificated notes to the Beneficial Owners. THE COUNTY Weld County, established in 1861, is located at the north central part of the State and is the third largest county in Colorado, covering an area of approximately 4,033 square miles. The surface is level to rolling prairies with low hills near the western border. Elevation ranges from 4,400 to 5,000 feet. The South Platte River and its tributaries, the Cache La Poudre, Big Thompson, Little Thompson, Boulder, and St. Vrain enter from the south and west and leave the county on the east. The county seat is located in the City of Greeley (est. pop. 62,000) which is 60 miles north of Denver on State Highway 85. Weld County ranked as the fourth most productive agricultural county in the nation and the third most productive oil and gas county in the Rocky Mountain Region during 1989. More than 85 percent of its area is devoted to irrigated and dryland farming and livestock raising. Weld County incorporates one of the nation's largest irrigated areas: 647,000 acres of the 2,500,000 acres in Weld County are irrigated by a combination of mountain run-off, which is controlled by eight major irrigation companies and 4,000 wells. The reservoir storage and stream run-off supply an annual average of 900,000 acre feet while the wells supply approximately 250,000 acre feet of water. The Colorado Big Thompson Water Diversion Project supplies approximately 300,000 acre feet of water annually. Water is diverted to farms and ranches via an extensive system of irrigation canals. Oil and gas play an important role in the economic picture of Weld County. Wattenberg Gas field, part of which is located in the southern part of Weld County, was discovered by Amoco 6 Oil Company, the prime developer of the field. Amoco Oil has estimated that this field contains approximately 400 billion feet of gas reserves. The gas that is being produced by the Wattenberg Field is delivered to the Public Service Company of Colorado. This potentially great gas accumulation covers nearly 1,000 square miles. Wattenberg Field is also producing some oil. Development of oil and gas wells has had an increasingly more significant impact on the economy of Weld County in the past ten years. FINANCIAL INFORMATION CONCERNING THE COUNTY The financial operations of the County are, pursuant to State law, conducted primarily through its General Fund. General Fund The General Fund is the major operating fund of the County, providing most of the resources for the County's general operations. General fund revenues amounted to $20,491,136 in 1989, an increase of 10.7% from 1988. Property Tax Collection Taxes levied in one year are collected in the next; thus 1990 taxes will be collected in 1991. Taxes are said to be due January 1 in the year of collection; however, they may be paid in two installments, without interest penalty, if the payments are made by February 28 and by July 31 of the collection year. The property owner may elect to make only one payment, and if made by April 30, it is also free of interest penalty. All taxes levied on property, together with interest thereon and penalties for default, as well as all other costs of collection, constitute a perpetual lien on and against the property taxes, and such lien is on a parity with the tax liens of other general taxes. In the event collection of property taxes becomes impossible, the County Treasurer may distrain, seize, and sell property to enforce the collection of delinquent taxes on property. There can be no assurance that the value of specific property, in the event of foreclosure and sale by the Weld County Treasurer, would be sufficient to produce the amount required with respect to taxes levied by the County and by overlapping taxing entities. 7 Property Tax Levies and Collections in the County Collection Total Tax Total % of Year Levy Collected Collections 1981 $12,622,216 $12,596,620 99.68 1982 13,252,865 13,169,249 99.37 1983 14,399,734 14,307,719 99.36 1984 15,119,720 14,985,503 99.11 1985 15,875,706 15,469,833 97.44 1986 17,147,925 17,013,025 99.20 1987 18,005,273 17,756,037 98.60 1988 18,931,528 18,506,143 97.75 1989 20,534,080 20,153,920 98.13 1990 21,449,358 21,127,077 * 98.50 * * Through November 30, 1990. Source: Weld County 1989 Annual Financial Report, Weld County Treasurer's Office Historical Property Tax Data Set forth below is certain historical information concerning mill levies, assessed valuation and property tax collection for the County. Mill Levy History 1982 - 1990 Collection Year 1983 17.172 1984 17.369 1985 19.342 1986 19.342 1987 19.968 1988 17.208 1989 19.268 1990 20.892 1991 22.210 Source: Weld County 1989 Annual Financial Report, and Weld County Assessor's Office 8 Total Assessed Valuation of the County 1980 - 1990 Budget Assessed Percent Year Valuation Increase 1980 $ 677,285,480 9.8% 1981 731,849,970 9.3% 1982 771,771,770 9.5% 1983 870,453,500 8.9% 1984 820,747,830 (1.1%) 1985 886,564,250 9.3% 1986 813,134,000 (8.3%) *1987 1,118,963,490 37.6% 1988 1,062,703,770 (5.0%) 1989 1,021,455,100 (3.9%) 1990 1,008,659,220 (1.3%) *Reassessment mandated by Colorado statute changed the base year of market value for valuation from 1977 in 1986 to 1985 in 1987. Source: Weld County 1989 Annual Financial Report, Weld County Assessor's Office Direct Indebtedness The County currently has no outstanding debt. TAX-EXEMPTION In the opinion of Bond Counsel, assuming the accuracy of certain certifications of the County regarding federal income tax matters and continuing compliance with the requirements of the Internal Revenue Code of 1986 (the "Code"), as amended, interest on the Notes is excluded from gross income for federal income tax purposes and is not an item of preference for purposes of computing the individual or corporate alternative minimum tax under the laws and regulations of the United States of America as presently enacted and construed. However, interest on Notes held by corporations (other than regulated investment companies, real estate investment trusts, real estate mortgage investment conduits and certain S corporations) may be indirectly subject to the alternative minimum tax and the environmental tax because of its inclusion in the current earning of corporations, and interest on Notes held by foreign corporations may be subject to the branch profits tax. In the opinion of Bond Counsel, the Notes are "qualified tax-exempt obligations" under Section 265(b) of the Code for purposes of determining the deductibility of interest expenses of banks and other financial institutions holding the Notes. Ownership of tax-exempt obligations may result in collateral federal income tax consequences to certain taxpayers, including, without limitation, financial institutions, property and casualty insurance companies, S corporations, individual recipients of Social Security or Railroad 9 Retirement benefits, foreign corporations engaged in a trade or business in the United States and taxpayers who may be deemed to have incurred or continue debt to purchase or carry such obligations. Bond Counsel will express no opinion with respect to such consequences. Prospective purchasers of the Notes should consult their own tax advisors as to such consequences. In the opinion of Bond Counsel, interest on the Notes is also exempt from Colorado income taxes under the laws of the State of Colorado as presently enacted and construed. LEGAL MATTERS Legal matter incident to the authorization and issuance of the Notes are subject to approval by Ballard, Spahr, Andrews & Ingersoll, Denver, Colorado, Bond Counsel, whose approving opinion on such matters is expected to state in substance that the Notes are valid and binding obligations of the general fund the County payable solely from ad valorem taxes on real and personal property previously levied, income and investment proceeds on such taxes, and proceeds of the Notes to the extent not required for the payment of duly budgeted current expenses, received by the County and credited to its general fund in the current fiscal year after the issuance of the Notes and that the Notes are enforceable according to the terms, except to the extent such enforcement is limited by the bankruptcy and other laws affecting the enforcement of creditors' rights, by the reasonable exercise of the police power of the State of Colorado and by the exercise of the powers delegated to the United States of America by the Federal Constitution. Bond Counsel has assumed no responsibility to make independent verifications or confirmations of the statements make in this Offering Circular or otherwise in connection with the sale of the Notes. RATING These Notes have not been rated by any municipal rating service. UNDERWRITING The Notes are being purchased pursuant to negotiation by Piper, Jaffray & Hopwood Incorporated, Denver, Colorado, at a discount of 0.1625%. DELIVERY The Notes are offered when, as and if issued and accepted by the Underwriter, subject to prior sale, modification or withdrawal of the offer without sale, and subject to the approval of validity and certain other matters by Ballard, Spahr, Andrews & Ingersoll. It is expected that the Notes will be available for delivery in Denver, Colorado, on or about January 10, 1991, against payment therefor. 10 WELD COUNTY 1991 CASH FLOW SUMMARY GENERAL FUND ($000's) Cumulative Estimated Estimated Surplus Expenditures Receipts (Deficit) Opening Balance - - $690 January $4,119 $ 760 ($2,669) February 1,750 1,520 (2,899) March 1,046 2,530 (1,415) April 1,700 3,780 665 May 1,320 1,846 1,191 June 1,320 1,020 891 July 1,585 3,350 2,656 August 1,450 2,180 3,386 September 2,280 950 2,056 October 1,320 945 1,681 November 1,450 1,195 1,426 December 2.107 1.274 593 Total Budget $21.447 $21,350 11 COUNTY DISCLOSURE CERTIFICATE The undersigned hereby certify that: They are the duly elected or appointed, qualified, sworn and acting Chairman and Clerk to the Board, respectively, of the Board of County Commissioners of Weld County, Colorado. The County provided to the underwriter of the Notes sufficient copies of the final Offering Circular, dated January 4, 1991, relating to its Tax Anticipation Notes, in sufficient time within seven (7) days after the sale of the Notes to enable the underwriter to send a copy of the final Offering Circular with all confirmations requiring payment from customers. The facts contained in the final Offering Circular are true and correct in all material respects, and the final Offering Circular does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. The County will notify the underwriter of any material developments impacting the County of which the County becomes aware within sixty (60) days after delivery of the Notes. IN WITNESS WHEREOF, the undersigned have hereunto set their hands and the seal of the County this 10th day of January, 1991. WELD COUNTY, COLORADO By: Board of (COUNTY) County Cole s ' •n r ( SEAL ) By: I�J/Lw ' / - W-L erk to the Board LAW OFFICES 20TH FLOOR BALLARD, SPAHR, ANDREWS & INGERSOLL 30 SOUTH 17TH STREET PHILADELPHIA,PA 19103 SUITE 2300 ONE WESTLAKES 1225 17TH STREET 1235 WESTLAKES DRIVE BERWYN, PA 19312 DENVER, COLORADO 80202 303 292-2400SIESMAYERSTRA55E 44 0 6000 FRANKFURT/MAIN I . FEDERAL REPUBLIC OF GERMANY TELECO PIER 303 296-3956 CABLE. BALLARD AMERICAN PLAZA U.SUITE 400 57 WEST 200 SOUTH SALT LAKE CITY, UT 84101 SUITE 900 EAST 555 13TH STREET, N.W. LORING E. HARKNESS III WASHINGTON, 0.C 20004 January 10, 1991 Piper, Jaffray & Hopwood, Incorporated 1660 Lincoln Street Denver, Colorado 80264 Board of County Commissioners of Weld County 915 10th Street Greeley, Colorado 80632 Re: Weld County, Colorado Tax Anticipation Notes Series 1991A Dated January 10, 1991 - $4, 350, 000 Ladies and Gentlemen: By this letter we wish to confirm our understanding with you that this firm has been engaged in connection with the above-referenced issue (the Notes) to render an opinion as to the validity of the Notes and the tax treatment of the interest thereon under federal and State of Colorado income tax laws and not to prepare or pass upon any official statement, prospectus, offering circular, or other documents used in the offer or sale of the Notes or to make any investigation incident to the preparation of such documents or to the offer or sale of the Notes. Very truly yours, 7 L � - k Loring E. Harkness III BOOK-ENTRY-ONLY MUNICIPAL NOTES Letter of Representations Weld County, Colorado, as Issuer Name of Agent, If Any January 10, 1991 The Depository Trust Company 55 Water Street New York, New York 10041 Attention: General Counsel ' s Office Re: Weld County, Colorado Tax Anticipation Notes Series 1991A Dated January 10, 1991 - $4 , 350, 000 Gentlemen: The purpose of this letter is to set out certain matters relating to the above-referenced Notes (the "Notes") . (the "Agent") is acting as Trustee, Paying Agent, Faecal Agent, or other Agent of the Issuer with respect to the No es. The Notes will be issued pursuant to a Trust Indenture, Not Resolution, or other such document authorizing the issuance of he Notes dated as of December 19, 1990 (the "Document(s) ") . Piper, Jaffray & Hopwood, Incorporated (the "Underwriter") is distributing the Notes through The Depository Trust Company ("DTC") . To induce DTC to accept the Notes as eligible for deposit at DTC and act in accordance with its Rules with respect Page 2 to the Notes, the Issuer and the Agent, if any, make the following representations to DTC: 1. Subsequent to Closing on the Notes on January 10, 1991, there shall be deposited with DTC one Note certificate in registered form registered in the name of DTC's nominee, Cede & Co. , for each stated maturity of the Notes in the face amounts set forth on Schedule A hereto, the total of which represents 100% of the principal amount of such Notes. If, however, the aggregate principal amount of the issue exceeds $150, 000, 000, one certificate will be issued with respect to each $150, 000, 000 of principal amount and an additional certificate will be issued with respect to any remaining principal amount. Each Note Certificate shall bear the following legend: "Unless this certificate is presented by an authorized representative of The Depository Trust Company to the issuer or its agent for registration of transfer, exchange or payment, and certificate issued is registered in the name of Cede & Co. or s r other name as requested by an authorized representative of T Depository Trust Company and any payment is made to Cede & C , ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR O i:ERWISE BY OR TO ANY PERSON IS WRONGFUL since the registered owner hereof, Cede & Co. , has an interest herein. " 2 . All notices and payment advices sent to DTC shall contain the CUSIP number of the Notes. Page 3 3 . Interest and principal payments shall be made in same-day funds by the Agent in the manner set forth in the SDFS Paying Agent Operating Procedures (a copy of which previously has been furnished to the Agent) . 4 . In the event the Issuer determines pursuant to the Document(s) that beneficial owners of the Notes shall be able to obtain certificated Notes, the Issuer or Agent shall notify DTC of the availability of Note certificates and shall issue, transfer and exchange Note certificates in appropriate amounts as required by DTC and others. 5. DTC may determine to discontinue providing its service as securities depository with respect to the Notes at any time by giving reasonable notice to the Issuer or Agent (at which time DTC will confirm with the Issuer or Agent the aggregate principal amount of the Notes outstanding) and discharging its responsibilities with respect thereto under applicable law. Under such circumstances, whenever DTC requests the Issuer and the Agent to do so, the Agent and the Issuer will cooperate with DTC in taking appropriate action to make available one or more separate certificates evidencing the Notes to any DTC Participant having Notes credited to its DTC account. Page 4 6. Nothing herein shall be deemed to require the Agent to advance funds on behalf of the Issuer. Very truly yours, - (as Agent) By: (Authorized Officer's Signature) Weld Coun y, lorado, as Issuer By: 1 cer's Signature) Received and Accepted: THE DEP0SI 111 TRUST MPAN Y By: �/LY Signature cc: (Authorized Officer's Sig Sig cc: Underwriter Underwriter' s Counsel Page 5 SCHEDULE A (Describe Issue) Principal Amount Maturity Date Interest Rate $241, 751.25 12-31-91 5.70% Hello