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CC - Item 5G - Confirming the Issuance of 2016 Tax Allocation Refunding Bonds and Approving Preliminary And Final Official Statements and A Purchasing Contract Relating Thereto, and Providing for Other Matters Properly RelatingROSEMEAD SUCCESSOR AGENCY STAFF REPORT TO: THE HONORABLE CHAIR AND BOARD MEMBERS FROM: BILL R. MANIS, EXECUTIVE DIRECTOR R DATE: NOVEMBER 8, 2016 SUBJECT: CONFIRMING THE ISSUANCE OF 2016 TAX ALLOCATION REFUNDING BONDS AND APPROVING PRELIMINARY AND FINAL OFFICIAL STATEMENTS AND A PURCHASE CONTRACT RELATING THERETO, AND PROVIDING FOR OTHER MATTERS PROPERLY RELATING THERETO SUMMARY In 2006, the Rosemead Community Development Commission (the "Former Agency ") issued the following tax allocation bonds for the purpose of financing and refinancing certain activities of the Former Agency: $14,005,000 initial principal amount of Commission Redevelopment Project Area No (the "Series 2006A Bonds "); and $24,230,000 initial principal amount of Commission Redevelopment Project Area No. 2006B (the "Series 2006B Bonds "). Rosemead Community Development 1 Tax Allocation Bonds, Series 2006A Rosemead Community Development Tax Allocation Refunding Bonds, Series As of October 2, 2016, there is $3,635,000 of principal amount outstanding of the Series 2006A Bonds and $23,205,000 of principal amount outstanding of the Series 2006B Bonds (in aggregate, $26,840,000 outstanding). The Successor Agency to the Rosemead Community Development Commission (the "Successor Agency ") assumed responsibility of all debt management with respect to the Former Agency in 2012 in accordance with and pursuant to the Dissolution Act. Under California Health and Safety Code Section 34177.5, the Successor Agency may refinance outstanding bonds with approval from the Oversight Board and the California Department of Finance ("DOE"), provided that the total interest cost, principal amount, and final maturity on the refunding bonds do not exceed that of the prior (outstanding) bonds. In other words, there must be debt service savings created by the refinancing. The Series 2006A Bonds and Series 2006B Bonds are currently eligible to be refinanced at any time at the option of the Successor Agency, at interest rates lower than those at the time of original issuance. ITEM NUMBER: Successor Agency Meeting November 8, 2016 Page 2 of 3 On July 12, 2016, the Successor Agency directed staff to move forward with refinancing the Series 2006A Bonds and Series 2006B Bonds and approved the financing team. Since then, the Successor Agency (August 23), Oversight Board (August 29), and DOF (October 14) have all approved the issuance of the Refunding Bonds. Now the Successor Agency is being asked to approve the Preliminary Official Statement and Bond Purchase Agreement in connection with the Refunding Bonds. If approval is given to proceed, the Refunding Bonds are expected to price as early as mid - November and close a few weeks later in December. STAFF RECOMMENDATION That the Successor Agency approve Resolution No. 2016 -19 SA (Confirming the Issuance of 2016 Tax Allocation Refunding Bonds, Approving Preliminary and Final Official Statements and a Purchase Contract relating thereto, and providing for other matters properly relating thereto). A description of each of the bond documents covered in the resolution is as follows • Preliminary Official Statement: This is the offering document that provides a description of the Successor Agency, the 2016 Bonds, and the sources of payment. It allows prospective investors to make an informed investment decision about the purchase of bonds. Federal securities laws require the Preliminary Official Statement to include all facts that would be material to an investor in the 2016 Bonds. "Material" information is information that there is a substantial likelihood would have actual significance in the deliberations of the reasonable investor when deciding whether to buy or sell the 2016 Bonds. The resolution authorizes the Underwriter to distribute the Preliminary Official Statement to prospective investors. • Bond Purchase Agreement: This agreement provides for the purchase of the 2016 Bonds by the Underwriter from the Successor Agency. STRATEGIC PLAN IMPACT - None DISCUSSION Despite recent market volatility, interest rates continue to remain at attractive levels. Based on current market conditions, the refinancing is estimated to generate around $3 million in debt service savings over the next 16 years (approximately $2.4 million of net present value savings, or 9% of par value being refunded). The debt service savings amount would be allocated to enforceable obligations, administrative cost and /or split among taxing entities, including Los Angeles County, Garvey and Rosemead School Districts, and the City of Rosemead's General Fund. Market conditions at the time the refunding bonds are priced will dictate the final debt service savings amount. If approval is given to proceed, the refunding bonds could be priced as early as mid - November. FISCAL IMPACT As mentioned above, based on current market conditions, the refunding bonds generate an Successor Agency Meeting November 8, 2016 Page 3 of 3 estimated total debt service savings of approximately $3 million or an average of over $170,000 per year. Please note that these savings estimates are net of all costs of issuance. Based on the City's allocation of the residual, around $400,000 would flow into the City's General Fund over the next 16 years. The final maturity date of the refunding bonds would match the final maturity of the outstanding bonds. The refunding bonds would not be an obligation of the City, but rather the Successor Agency. As such, the source of repayment of the refunding bonds would be limited to tax increment revenues generated in the Rosemead Merged Project Area as described in the Indenture of Trust. PUBLIC NOTICE PROCESS This item has been noticed through the regular agenda notification process. Submitted by: Carolyn A. Chu, Finance Director Attachment A: Resolution No. 2016 -19 SA Attachment B: Preliminary Official Statement Attachment C: Bond Purchase Agreement � I 1T Resolution No. 2016 -19 SA RESOLUTION NO. 2016-19 SA A RESOLUTION OF THE SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION CONFIRMING THE ISSUANCE OF 2016 TAX ALLOCATION REFUNDING BONDS AND APPROVING PRELIMINARY AND FINAL OFFICIAL STATEMENTS AND A PURCHASE CONTRACT RELATING THERETO, AND PROVIDING FOR OTHER MATTERS PROPERLY RELATING THERETO WHEREAS, the Rosemead Community Development Commission (the "Former Agency ") was a public body, corporate and politic, duly established and authorized to transact business and exercise powers under and pursuant to the provisions of the Community Redevelopment Law of the State of California, constituting Part 1 of Division 24 of the Health and Safety Code of the State (the "Redevelopment Law "); WHEREAS, redevelopment plans for the redevelopment project area designated "Redevelopment Project Area No. 1" in the City of Rosemead, California, were adopted in compliance with all requirements of the Redevelopment Law; WHEREAS, pursuant to Section 34172(a) of the California Health and Safety Code (unless otherwise noted, all Section references hereinafter being to such Code), the Former Agency has been dissolved and no longer exists as a public body, corporate and politic, and pursuant to Section 34173, the City of Rosemead has become the successor entity to the Former Agency (the "Successor Agency "); WHEREAS, prior to dissolution of the Former Agency, the Former Agency issued the following outstanding series of bonds (collectively, the "2006 Bonds ") pursuant to an Indenture, dated as of October 1, 1993, as supplemented, by and between the Former Agency and U.S. Bank National Association, as Trustee, for the purpose of financing redevelopment activities: (i) $14,005,000 initial principal amount of Rosemead Community Development Commission Redevelopment Project Area No. 1 Tax Allocation Bonds, Series 2006A, for the purpose of financing and refinancing certain redevelopment activities of the Former Agency; and (ii) $24,230,000 initial principal amount of Rosemead Community Development Commission Redevelopment Project Area No. 1 Tax Allocation Refunding Bonds, Series 2006B, for the purpose of financing and refinancing certain redevelopment activities of the Former Agency. WHEREAS, Section 34177.5(a)(1) authorizes the Successor Agency to undertake proceedings for the refunding of outstanding bonds and other obligations of the Former Agency in order to achieve debt service savings within the parameters set forth in Section 34177.5(a)(1) (the "Savings Parameters "), and to issue bonds for such purpose pursuant to Article 11 (commencing with Section 53580) of Chapter 3 of Part 1 of Division 2 of Title 5 of the Government Code (the "Refunding Law ") WHEREAS, the Successor Agency determined that it will achieve debt service savings on the 2006 Bonds in compliance with the Savings Parameters as evidenced by the analysis prepared by its Financial Advisor, Urban Futures, Inc., describing potential savings that will accrue to the Successor Agency and to applicable taxing entities as a result of the refunding of the 2006 Bonds (the "Debt Service Savings Analysis "); WHEREAS, the Successor Agency has determined that the potential debt service savings evidenced by the Debt Service Savings Analysis can be achieved by refunding the 2006 Bonds through the issuance, as authorized by Section 34177.5(f), by the Successor Agency of its "Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds" (the "Refunding Bonds ") pursuant to the Redevelopment Law, the Refunding Law and the form of a Indenture of Trust approved by the Successor Agency pursuant to the Resolution No. 2016 -12 SA, adopted August 23, 2016, (the "Resolution of Issuance "); WHEREAS, pursuant to Section 34179, an oversight board (the "Oversight Board ") has been established for the Successor Agency and pursuant to Section 34177.5(f), the Oversight Board by Resolution No. 2016 -009 OB, adopted August 29, 2016, directed the Successor Agency to undertake such refunding proceedings and approved the issuance, sale and delivery of refunding bonds by the Successor Agency for the purpose of refunding the 2006 Bonds; WHEREAS, Resolution No. 2016 -009 OB of the Oversight Board was submitted to the California Department of Finance for its approval of such approval by the Oversight Board and the Department of Finance in a letter dated October 14, 2016, approved Resolution No. 2016 -009 OB in accordance with Section 34177.5(f); WHEREAS, the Agency has determined to sell the Refunding Bonds to Stifel, Nicolaus & Company, Incorporated (the "Underwriter ") pursuant to a Purchase Contract between the Successor Agency and the Underwriter (the "Purchase Contract'), the form of which is on file with the Secretary; WHEREAS, the Successor Agency has caused to be prepared a form of Official Statement describing the Refunding Bonds and containing material information relating to the Refunding Bonds, the preliminary form of which is on file with the Secretary; WHEREAS, the Successor Agency, with the aid of its staff, has reviewed the Purchase Contract and the Official Statement and wishes at this time to approve the foregoing as in the public interests of the Successor Agency and applicable taxing entities; NOW THEREFORE, THE CITY COUNCIL ACTING AS SUCCESSOR AGENCY HEREBY RESOLVES AS FOLLOWS: Section 1. Confirmation of Approval of Issuance of the Bonds. The Successor Agency hereby confirms its actions in the Resolution of Issuance authorizing and approving the issuance of the Refunding Bonds pursuant to the Indenture and under the Redevelopment Law and the Refunding Law. Section 2. Approval of Official Statement. The Successor Agency hereby approves the preliminary Official Statement describing the Refunding Bonds, in substantially the form on file with the Secretary. Each of the Mayor of the City of Rosemead, as Chair of the Successor Agency, the City Manager of the City of Rosemead, as the Executive Director of the Successor Agency, the Finance Director, as the chief financial officer of the Successor Agency, or the written designee of any such officer (each, an "Authorized Officer "), is hereby authorized and directed to execute and deliver the final Official Statement for and on behalf of the Successor Agency, to deliver to the Underwriter a certificate with respect to the information set forth therein and to deliver to the Underwriter a Continuing Disclosure Certificate substantially in the form appended to the final Official Statement. Distribution of the preliminary Official Statement by the Underwriter is hereby approved, and, prior to the distribution of the preliminary Official Statement, either Authorized Officer is authorized and directed, on behalf of the Successor Agency, to deem the preliminary Official Statement "final" pursuant to Rule 15c2 -12 under the Securities Exchange Act of 1934 (the "Rule "). The executed final Official Statement, which shall include such changes and additions thereto deemed advisable by an Authorized Officer, including bond insurance and/or a reserve surety if deemed by an Authorized Officer to be appropriate for savings, and such information permitted to be excluded from the preliminary Official Statement pursuant to the Rule, is hereby approved for delivery to the purchasers of the Refunding Bonds. Section 3. Purchase Contract. The Successor Agency hereby approves the Purchase Contract prescribing the provisions for purchase and sale of the Refunding Bonds. Each Authorized Officer is hereby authorized and directed to execute and deliver, and the City Clerk, as the secretary of the Successor Agency, is hereby authorized and directed to attest to, the Purchase Contract for and in the name and on behalf of the Successor Agency, in substantially the form on file with the City Clerk, with such changes therein, deletions therefrom and additions thereto as the Authorized Officer shall approve, such approval to be conclusively evidenced by the execution and delivery of the Purchase Contract. The Successor Agency hereby authorizes the delivery and performance of the Purchase Contract. Section 4. Official Actions. All actions heretofore taken by the officers and agents of the Successor Agency with respect to the issuance of the Refunding Bonds are hereby approved, confirmed and ratified. The Authorized Officers, the City Attorney as general counsel of the Successor Agency, the Secretary and any and all other officers of the Successor Agency are hereby authorized and directed, for and in the name and on behalf of the Successor Agency, to do any and all things and take any and all actions, including but not limited to execution and delivery of any and all assignments, certificates, requisitions, including requisitions for the payment of costs of issuance of the Refunding Bonds, agreements, including an escrow agreement determined to be necessary by an Authorized Officer in order to provide for payment of the 2006 Bonds, all as determined by an Authorized Officer to be necessary and appropriate in connection with the issuance of the Refunding Bonds and in customary form, and notices, consents, and other documents, which an Authorized Officer may deem necessary or advisable, in order to consummate the sale, issuance and delivery of the Refunding Bonds to the Underwriter. Section 5. Effective Date. This Resolution shall take effect from and after the date of approval and adoption thereof. PASSED, APPROVED, AND ADOPTED this 8 th day of November, 2016. APPROVED AS TO FORM: Rachel Richman, Successor Agency Counsel Sandra Armenta, Successor Agency Chair ATTEST: Marc Donohue, Successor Agency Clerk STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES) § CITY OF ROSEMEAD ) I, Marc Donohue, Successor Agency Clerk to the Rosemead Community Development Commission of the City of Rosemead, California, do hereby certify that the foregoing Successor Agency Resolution, No. 2016 -19 SA, was duly adopted by the Board of the Successor Agency, at a regular meeting thereof held on the 8` day of November, 2016, by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Marc Donohue, Successor Agency Clerk Attachment B Preliminary Official Statement OH &S 10/30/16 Draft PRELUMINARY OFFICIAL STATEMENT DATED NOVEMBER , 2016 NEW ISSUE BOOK ENTRY ONLY RATINGS: S &P (Insured 2016 Bonds): S &P (Underlying): " See "OTHER INFORMATION - Ratings" In the opinion of Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel, subject, however, to certain qualifications described herein, under existing law, the interest on the 2016 Bonds is excluded from gross income for federal income tax purposes and such interest is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations, although for the proposes of computing the alternative minimum tax imposed on certain corporations such interest is taken into account in determining certain income and earnings. In the further opinion of Bond Counsel such interest is exempt from California personal income taxes. See "OTHER INFORMATION— Tcu Matters "herein. Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds Dated: Date of Delivery Due: December 1, as shown on inside cover page The Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds (the "2016 Bonds ") are being issued by the Successor Agency to the Rosemead Community Development Commission (the "Successor Agency ") to refinance certain outstanding bonds of the Successor Agency as further described herein. The 2016 Bonds will be secured and payable under an Indenture of Trust, dated as of December 1, 2016 (the "Indenture "), by and between the Successor Agency and U.S. Bank National Association, as trustee (the "Trustee "). The payments due under the Indenture will be secured by a pledge of, security interest in and lien on Subordinate Tax Revenues (as defined in the Indenture and described herein), including all of the Subordinate Tax Revenues in the Redevelopment Obligation Retirement Fund (as defined in the Indenture and described herein) and certain funds and accounts established pursuant to the Indenture. The payment of debt service on the 2016 Bonds is subordinate to the payment of amounts payable under the Pass - Through Agreement, Statutory Pass - Through Payments and debt service on the Senior Bonds (each as defined herein) outstanding in the aggregate principal amount of $ The Successor Agency has covenanted not to issue any obligations payable from Tax Revenues on a senior basis to the 2016 Bonds. See "SBCURiTY FOR THE BONDS" herein. The 2016 Bonds are being issued in folly registered form, and when issued, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company ( "DTC "), New York, New York. DTC will act as securities depository for the 2016 Bonds. Individual purchases of the 2016 Bonds may be made in book -entry form only, in denominations of $5,000 or any integral multiple thereof. Purchasers of interests in the 2016 Bonds will not receive certificates from the Successor Agency or the Trustee representing their interest in the 2016 Bonds purchased. Interest on the 2016 Bonds will be payable semiannually on June 1 and December 1 of each year, commencing June 1, 2017. Payments of principal, premium, if any, and interest on the 2016 Bonds will be payable by the Trustee, to DTC, which is obligated in turn to remit such principal, premium, if any, and interest to the DTC Participants for subsequent disbursement to the Beneficial Owners of the 2016 Bonds, as more fully described herein, The 2016 Bonds are subject to optional redemption and mandatory sinking fund redemption prior to maturity as described herein. See "THE 2016 BONDS — Redemption of the 2016 Bonds" herein. The Successor Agency has applied for a municipal bond insurance policy which may insure some or all maturities of the 2016 Bonds and a debt service reserve fund policy for the 2016 Bonds as described herein. If any such policies are purchased, the Official Statement will be revised to specify the insured maturities of the 2016 Bonds and to reflect the material terms of such municipal bond insurance and /or debt service reserve fund policies and the Indenture will be revised to reflect such terms and the rights and obligations of the provider. The 2016 Bonds are limited obligations payable solely from certain payments from the Successor Agency and certain other funds. Neither the City of Rosemead (the "City"), the County of Los Angeles (the "County"), the State of California (the "State ") nor any political subdivision thereof, except the Successor Agency, shall be obligated to pay the principal of the 2016 Bonds, or the interest thereon, except from the funds described above, and neither the faith and the credit nor the taxing power of the County, the State nor any political subdivision thereof is pledged to the payment of the principal of or the interest on the 2016 Bonds. The issuance of the 2016 Bonds shall not directly, indirectly or contingently obligate the City, the County, the State or any political subdivision thereof to levy or pledge any form of taxation whatever therefor or to make any appropriations for their payment. The Successor Agency has no taxing power. This cover page contains certain information for general reference only. It is not intended to be a summary of the security or terms of this issue. Investors are advised to read the entire Official Statement to obtain information essential to the making of an informed investment decision. Capitalized terms used and not defined on this cover page shall have the meanings set forth herein. For a discussion of some of the risks associated with a purchase of the 2016 Bonds, see "RISK FACTORS" herein. Preliminary, subject to change. OHSUSA:765600743.3 MATURITY SCHEDULE See inside front cover The 2016 Bonds are offered when, as and if issued, subject to the approval of their legality by Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel. Certain disclosure matters will be passed upon for the Successor Agency by Orrick Herrington & Sutcliffe LLP, Los Angeles, California, as Disclosure Counsel. Certain matters will be passed upon for the Successor Agency by the City Attorney, Burke, Williams & Sorensen, LLP, as general counsel to the Successor Agency, and for the Underwriter by Norton Rose Fulbright US LLP, Los Angeles, California. It is anticipated that the 2016 Bonds will be available for delivery in definitive form on or about December 2016 [Stifel] Dated: November _, 2016 OHSUSA:765600743.3 MATURITY SCHEDULE Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds (Base CUSIPt No.: $ 2016 Serial Bonds Maturity Date Principal Interest (December 1) Amount Rate 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 Yield Price CUSIP t $ % 2016 Term Bonds due December 1, 20_ - Yield: _% CUSIP No. * Preliminary, subject to change. t CUSIP® is a registered trademark of the American Bankers Association. CUSIP Global Services (CGS) is managed on behalf of the American Bankers Association by S &P Capital IQ. Copyright(c) 2016 CUSIP Global Services. All rights reserved. CUSH`@ data herein is provided by CUSIP Global Services, This data is not intended to create a database and does not serve in any way as a substitute for the CGS database. CUSIP® numbers are provided for convenience of reference only. Neither the Underwriter nor the Successor Agency or their agents or counsel assume responsibility for the accuracy of such numbers. OHSUSA:765600743.3 SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION CITY COUNCIL Sandra Armenta, Mayor /Chair Polly Low, Mayor Pro- Tem/Vice Chair Bill Alarcon, Council MemberBoard Member Margaret Clark, Council Member /Board Member Steven Ly, Council Member /Board Member SUCCESSOR AGENCYICITY STAFF Bill R. Maris, City Manager Carolyn A. Chu, Finance Director Brad McKinney, Assistant City Manager Burke, Williams & Sorenson, LLP, City Attorney and General Counsel to the Successor Agency SPECIAL SERVICES Bond Counsel Jones Hall, A Professional Law Corporation San Francisco, California Disclosure Counsel Orrick, Herrington & Sutcliffe LLP Los Angeles, California Municipal Advisor Urban Futures, Inc. Orange, California Fiscal Consultant Urban Futures, Inc. Orange, California Trustee U.S. Bank National Association Los Angeles, California Verification Agent OHSUSA:765600743.3 GENERAL INFORMATION ABOUT THIS OFFICIAL STATEMENT No dealer, broker, salesperson or other person has been authorized by the Successor Agency to give any information or to make any representations in connection with the offer or sale of the 2016 Bonds other than as contained in this Official Statement, and if given or made, such other information or representations must not be relied upon as having been authorized by any of the foregoing. This Official Statement does not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of the 2016 Bonds by any person, in any jurisdiction where such offer, solicitation or sale would be unlawful. The information set forth herein has been obtained from sources that are believed to be reliable, but is not guaranteed as to accuracy or completeness, and is not to be construed as a representation, by the Successor Agency. Neither the delivery of this Official Statement nor any sale made hereunder will, under any circumstances, create any implication that there has been no change in the affairs of the Successor Agency since the date hereof. The information and expressions of opinion stated herein are subject to change without notice. Certain statements contained in this Official Statement reflect not historical facts but forecasts and "forward - looking statements." All forward - looking statements are predictions and are subject to known and unknown risks and uncertainties. No assurance can be given that the future results discussed herein will be achieved, and actual results may differ materially from the forecasts described herein. In this respect, the words "estimate," "project," "anticipate," "expect," "intend," "believe" and similar expressions are intended to identify forward - looking statements. All projections, forecasts, assumptions, expressions of opinions, estimates and other forward - looking statements are expressly qualified in their entirety by the cautionary statements set forth in this Official Statement. The achievement of certain results or other expectations contained in such forward - looking statements involves known and unknown risks, uncertainties, and other factors that may cause the actual results, performance, or achievements described to be materially different from any future results, performance, or achievements expressed or implied by such forward - looking statements. No updates or revisions to these forward - looking statements are expected to be issued if or when the expectations, events, conditions, or circumstances on which such statements are based change. INVESTORS ARE CAUTIONED NOT TO PLACE UNDUE RELIANCE ON SUCH FORWARD - LOOKING STATEMENTS, WHICH SPEAK ONLY AS OF THE DATE HEREOF. All summaries of the Indenture (as defined herein) and of statutes and other documents referred to herein do not purport to be comprehensive or definitive and are qualified in their entireties by reference to each such statute and document. This Official Statement, including any amendment or supplement hereto, is intended to be deposited with one or more depositories. This Official Statement does not constitute a contract between any Owner of a 2016 Bond and the Successor Agency. The issuance and sale of the 2016 Bonds have not been registered under the Securities Act of 1933 or the Securities Exchange Act of 1934, both as amended, in reliance upon exemptions provided thereunder by Sections 3(a)(2) and 3(a)(12), respectively, for the issuance and sale of municipal securities. The Underwriter has provided the following sentence for inclusion in this Official Statement: The Underwriter has reviewed the information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction, but the Underwriter do not guarantee the accuracy or completeness of such information. IN CONNECTION WITH THIS OFFERING, THE UNDERWRITER MAY OVERALLOT OR AFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE MARKET PRICE OF THE 2016 BONDS AT A LEVEL ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. THE UNDERWRITER MAY OFFER AND SELL THE 2016 BONDS TO CERTAIN DEALERS AND OTHERS AT PRICES LOWER THE PUBLIC OFFERING PRICE STATED ON THE INSIDE COVER PAGE HEREOF. THE OFFERING PRICES MAY BE CHANGED FROM TIME TO TIME BY THE UNDERWRITER. The City maintains a website. However, the information presented at such website is not part of this Official Statement, is not incorporated by reference herein, and must not be relied upon in making an investment decision with respect to the 2016 Bonds. 011SUSA:765600743.3 TABLE OF CONTENTS Page INTRODUCTION......................................................................................................... ............................... 1 General................................................................................................................... ............................... 1 Purpose................................................................................................................... ............................... 1 TheCity .................................................................................................................. ............................... 2 TheSuccessor Agency ........................................................................................... ............................... 2 TheProject Area .................................................................................................... ............................... 3 Authority for Issuance of the 2016 Bonds ............................................................. ............................... 3 Securityfor the 2016 Bonds ................................................................................... ............................... 3 Termsof the 2016 Bonds ....................................................................................... ............................... 5 Municipal Bond Insurance Policy and Reserve Fund Surety ................................. ............................... 5 Professionals Involved in the Offering .................................................................. ............................... 5 ContinuingDisclosure ............................................................................................ ............................... 6 Reference to Underlying Documents ..................................................................... ............................... 6 PLANOF REFUNDING ............................................................................................... ............................... 6 ESTIMATED SOURCES AND USES OF FUNDS ..................................................... ............................... 7 ANNUAL DEBT SERVICE REQUIREMENTS OF THE BONDS ............................. ............................... 8 THE2016 BONDS ........................................................................................................ ............................... 8 General................................................................................................................... ............................... 8 Redemptionof the 2016 Bonds .............................................................................. ............................... 9 SECURITY FOR THE BONDS .................................................................................. ............................... 11 Subordinate Tax Revenues ................................................................................... ............................... 11 Limitation on Issuance of Senior Bonds .............................................................. ............................... 13 Pass - Through Arrangements ................................................................................ ............................... 13 ReserveAccount .................................................................................................. ............................... 15 2016 Bonds Not a Debt of the City, County or the State ..................................... ............................... 15 AdditionalParity Debt ......................................................................................... ............................... 16 BONDINSURANCE .................................................................................................. ............................... 16 THESUCCESSOR AGENCY .................................................................................... ............................... 16 General................................................................................................................. ............................... 16 SuccessorAgency Staff ........................................................................................ ............................... 17 OversightBoard ................................................................................................... ............................... 17 Department of Finance Finding of Completion ................................................... ............................... 18 State Controller Asset Transfer Review ............................................................... ............................... 18 THEPROJECT AREA ................................................................................................ ............................... 18 General................................................................................................................. ............................... 18 Merged Project Area Description ......................................................................... ............................... 19 PropertyValue by Land Use ................................................................................ ............................... 20 AssessedValues ..................................................................................................... .............................22 Ten Largest Assessees .......................................................................................... ............................... 22 Property Tax Collection Procedures and Delinquencies ...................................... ............................... 23 Low and Moderate Income Housing Set -Aside ................................................... ............................... 24 Redevelopment Property Tax Trust Fund ............................................................ ............................... 25 -i- OHSUSA:765600743.3 TABLE OF CONTENTS (continued) Page Allocation of Taxes Subsequent to the Dissolution Act ...................................... ............................... 25 Recognized Obligation Payment Schedule .......................................................... ............................... 25 AssessmentAppeals ............................................................................................. ............................... 28 Property Tax Administrative Costs ...................................................................... ............................... 31 PlanLimitations ................................................................................................... ............................... 31 Last and Final Recognized Obligation Payment Schedule .................................. ............................... 31 ESTIMATED REVENUES AND BOND RETIREMENT ......................................... ............................... 33 RISKFACTORS ......................................................................................................... ............................... 36 Limited Special Obligations ................................................................................. ............................... 36 SubordinateLien Risks ........................................................................................ ............................... 36 Recognized Obligation Payment Schedule .......................................................... ............................... 36 Real Estate and General Economic Risks ............................................................ ............................... 37 Reductionin Taxable Value ................................................................................. ............................... 37 AssessmentAppeals ............................................................................................. ............................... 37 Reduction in Inflationary Rate and Changes in Legislation ................................. ............................... 38 EstimatedRevenues ............................................................................................. ............................... 38 Levy and Collection of Taxes ............................................................. ..............................; ................. 39 NoTeeter Plan ..................................................................................................... ............................... 39 Concentrationof Land Ownership ....................................................................... ............................... 39 Acceleration of Senior Bonds .............................................................................. ............................... 39 Bond Insurance Risk Factors ............................................................................... ............................... 39 Changein Law ..................................................................................................... ............................... 40 Lossof Tax Exemption .......................................................................................... .............................40 IRSAudit of Bond Issues ..................................................................................... ............................... 41 CertainBankruptcy Risks .................................................................................... ............................... 41 Bankruptcy of Landowners .................................................................................... .............................41 Riskof Earthquake ............................................................................................... ............................... 41 HazardousSubstances ............................................................................................ .............................42 StateBudget ......................................................................................................... ............................... 42 Direct and Overlapping Indebtedness .................................................................. ............................... 43 Future Legislation and Initiatives ......................................................................... ............................... 43 InvestmentRisk .................................................................................................... ............................... 43 Challenges to Dissolution Act .............................................................................. ............................... 43 SecondaryMarket ................................................................................................ ............................... 44 LIMITATIONS ON TAX REVENUES ...................................................................... ............................... 44 Property Tax Limitations - Article XIIIA ............................................................ ............................... 44 ImplementingLegislation .................................................................................... ............................... 47 RedevelopmentPlan Limits ................................................................................. ............................... 47 UnitaryProperty ................................................................................................... ............................... 47 Tax Increment Limitations; Senate Bill 107 ........................................................ ............................... 48 Property Taxes; Delinquencies ............................................................................ ............................... 49 TaxCollection Fees ............................................................................................. ............................... 49 FutureInitiatives .................................................................................................. ............................... 49 OTHERINFORMATION ........................................................................................... ............................... 49 -ii- OHSUSA:765600743.3 TABLE OF CONTENTS (continued) Page Certain Information Concerning the City ............................................................. ............................... 49 FinancialStatements ............................................................................................ ............................... 49 ContinuingDisclosure .......................................................................................... ............................... 50 Litigation.............................................................................................................. ............................... 50 TaxMatters .......................................................................................................... ............................... 50 MunicipalAdvisor ............................................................................................... ............................... 52 LegalOpinion ...................................................................................................... ............................... 52 Verification of Mathematical Accuracy ............................................................... ............................... 52 Ratings................................................................................................................. ............................... 52 Underwriting........................................................................................................ ............................... 53 Miscellaneous....................................................................................................... ............................... 53 APPENDIX A FISCAL CONSULTANT REPORT ................................................ ............................... A -1 APPENDIX B GENERAL INFORMATION CONCERNING THE CITY OF ROSEMEAD .............. B -1 APPENDIX C CITY OF ROSEMEAD COMPREHENSIVE ANNUAL FINANCIAL REPORT FOR THE YEAR ENDED JUNE 30, 2015 .................................................. ............................... C -1 APPENDIX D SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE ............................. D -1 APPENDIX E FORM OF OPINION OF BOND COUNSEL .................................. ............................... E -1 APPENDIX F FORM OF CONTINUING DISCLOSURE CERTIFICATE ............... ............................F -1 APPENDIX G DTC AND BOOK -ENTRY ONLY SYSTEM ................................. ............................... G -1 APPENDIX H FORM OF DEBT SERVICE RESERVE FUND SURETY BOND ............................... H -1 APPENDIX I SPECIMEN MUNICIPAL BOND INSURANCE POLICY .................. ............................I -1 -iii - OHSUSA:765600743.3 [THIS PAGE INTENTIONALLY LEFT BLANK] OHSUSA:765600743.3 Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds INTRODUCTION This Introduction is subject in all respects to the more complete information contained elsewhere in this Official Statement and the offering of the 2016 Bonds to potential investors is made only by means of the entire Official Statement. Capitalized terms used and not defined in this Introduction shall have the meanings assigned to them elsewhere in this Official Statement. General This Official Statement, including the cover page, inside cover page and appendices hereto, provides information in connection with the issuance by the Successor Agency to the Rosemead Community Development Commission (the "Successor Agency ") of its 2016 Subordinate Tax Allocation Refunding Bonds (the "2016 Bonds "). The 2016 Bonds are being issued to refinance certain outstanding bonds with respect to the Rosemead Merged Project Area of the Successor Agency (the "Project Area "), as further described herein. The 2016 Bonds will be secured and payable under an Indenture of Trust, dated as of December 1, 2016 (the "Indenture "), by and between the Successor Agency and U.S. Bank National Association, as trustee (the "Trustee "). The payments due under the Indenture will be secured by a pledge of, security interest in and lien on Subordinate Tax Revenues (as defined in the Indenture and described herein), including all of the Subordinate Tax Revenues in the Redevelopment Obligation Retirement Fund (as defined in the Indenture and described herein) and certain funds and accounts established pursuant to the Indenture. The payment of debt service on the 2016 Bonds is subordinate to the payment of amounts payable under the Pass - Through Agreement, Statutory Pass - Through Payments and debt service on the Senior Bonds (each as defined herein) outstanding in the aggregate principal amount of $ .* The Successor Agency has covenanted not to issue any obligations payable from Tax Revenues, described herein, on a senior basis to the 2016 Bonds. See "SECURITY FOR THE BONDS" herein. Purpose The 2016 Bonds are being issued to refund, on a current basis, all of the outstanding Rosemead Community Development Commission Redevelopment Project Area No. 1 Tax Allocation Bonds, Series 2006A, initially issued in the principal amount of $14,005,000, of which $3,635,000 principal amount is currently outstanding (the "Series 2006A Bonds ") and the Rosemead Community Development Commission Redevelopment Project Area No. 1 Tax Allocation Refunding Bonds, Series 2006B, initially issued in the principal amount of $24,230,000, of which $23,205,000 principal amount is currently outstanding (the "Series 2006B Bonds" and, together with the Series 2006A Bonds, the "Refunded Bonds "). Proceeds of the 2016 Bonds will additionally be applied to pay costs of issuance of the 2016 Bonds, including the premium for the Policy and the 2016 Reserve Surety (as such terms are defined below). See "PLAN OF REFUNDING" and "ESTIMATED SOURCES AND USES OF FUNDS" herein. * Preliminary, subject to change. OHSUSA:765600743.3 The City The City of Rosemead (the "City ") encompasses approximately 5 1 /2 square miles located in the central northwestern section of Los Angeles County, approximately 12 miles east of the central business district of Los Angeles. The City shares common boundaries with the municipalities of San Gabriel, Temple City, El Monte, Montebello, Monterey Park and Alhambra. The City's current population is approximately 55,23 1. Incorporated in August 4, 1959, the City operates as a general law city. It has a council- manager form of government, with five council members elected at large for four -year overlapping terms. The Rosemead City Council (the "City Council ") selects a mayor and mayor pro -tem each year from its membership. The City Council is responsible for enacting local legislation, establishing general policy for the City and adopting the annual budget. The City Council's duties also include the appointment of a City Manager, City Attorney, City Clerk and City Treasurer and the selection of citizens to serve of the City's various advisory commissions. The City contracts with the Los Angeles County Sheriff's Department for sheriff services. Fire protection is provided through the Los Angeles County Fire Protection District. Two fire stations are located in the City. For additional information regarding the City, see APPENDIX B — "GENERAL INFORMATION CONCERNING THE CITY OF ROSEMEAD." The Successor Agency As described below, the Successor Agency has succeeded to certain rights of the former Rosemead Community Development Commission. The Rosemead Redevelopment Agency, later known as the Rosemead Community Development Commission (the "Former Agency "), was activated in 1972 by City ordinance. The City Council adopted the Redevelopment Plan for Redevelopment Project Area No. 1 on June 27, 1972, by Ordinance No. 340. That Redevelopment Plan has been amended three times: on December 9, 1986, by Ordinance No. 592, to establish the tax increment collection limit and to establish an eminent domain sunset date; on December 20, 1994, by Ordinance No. 752, to comply with provisions of Assembly Bill 1290; and on January 22, 2002, by Ordinance No. 822, to eliminate the date restriction on establishing loans, advances and indebtedness. Pursuant to California legislation enacted in 2011 and 2012 and most recently in 2014 and 2015 (as more fully described herein, the "Dissolution Act "), redevelopment agencies in the State of California (the "State "), including the Former Agency, were dissolved, and with certain exceptions, could no longer conduct redevelopment activities. The Successor Agency, however, is authorized to continue to refinance existing bonds in order to achieve savings in debt service, and to finance and refinance other obligations of the Successor Agency. See " —The Project Area" below. Additional amendments constituting a portion of the Dissolution Act resulted from the enactment of Senate Bill No. 107 ( "SB 107 ") (Chapter 325, Statutes of 2015), which became effective on September 22, 2015. See "THE SUCCESSOR AGENCY" for a discussion of the Dissolution Act, the formation of the Successor Agency and the current powers, and limitations thereon, of the Successor Agency. 2 OHSUSA:765600743.3 The Project Area The Successor Agency has two component project areas, the Project Area No. 1 Component ( "Component Area No. 1 ") and the Project Area No. 2 Component ( "Component Area No. 2 "). By Ordinance No. 871 adopted by the City Council on March 10, 2009, the City Council adopted a merger amendment, merging the Redevelopment Plans for Component Area No. 1 and the Component Area No. 2, creating the Project Area, as defined herein. Component Area No. 1. Component Area No. 1 is a contiguous area of about 510 acres and is roughly triangular with Garvey Avenue, San Gabriel Boulevard and Walnut Grove Avenue being the major thoroughfares traversing the area. Component Area No. 1 is within a few miles of the City's Civic Center and is located between the San Bernardino and Pomona Freeways to the north and south, respectively. Component Area No. 2. The City Council adopted the Redevelopment Plan for Redevelopment Project Area No. 2 on June 27, 2000, by Ordinance No. 809. The territory within Component Area No. 2 includes about 205 acres. The Component Area No. 2 is a contiguous area of about 205 acres and encompasses Valley Boulevard from the eastern and western boundaries of the City and Rosemead Boulevard from the southern and northern boundaries of the City. Authority for Issuance of the 2016 Bonds The 2016 Bonds are being issued by the Successor Agency pursuant to the provisions of the Dissolution Act, the Redevelopment Law and Article 11 (commencing with Section 53588) of Chapter 3 of Part 1 of Division 2 of the Government Code of the State of California. The issuance of the 2016 Bonds was subject to approvals under the Dissolution Act, of the Successor Agency's Oversight Board, as described below, and the Department of Finance of the State of California (the "DOF "). All such approvals have been obtained. See "THE SUCCESSOR AGENCY." The Successor Agency approved the issuance of the 2016 Bonds by resolution adopted on August 23, 2016. The Oversight Board for the Successor Agency approved the issuance of the 2016 Bonds by the Successor Agency by resolution adopted on August 29, 2016. The DOF released its letter approving the Oversight Board Resolution approving the issuance of the 2016 Bonds on October 14, 2016. The 2016 Bonds are being issued by the Successor Agency pursuant to the provisions of the Dissolution Act, the Redevelopment Law and Article 11 (commencing with Section 53588) of Chapter 3 of Part 1 of Division 2 of the Government Code of the State of California. Security for the 2016 Bonds The 2016 Bonds shall be payable from Subordinate Tax Revenues. As defined in the Indenture, the term "Subordinate Tax Revenues" means, for each Fiscal Year, the Tax Revenues, as defined in the Senior Indenture and as defined herein, minus (i) the amount needed by the Successor Agency for payment of debt service on the Senior Bonds and any other payment obligations due under the Senior Indenture, (ii) amounts payable by the Successor Agency pursuant to Sections 33676, 33607.5, 33607.7 and 34183(a)(1) of the Law ( "Statutory Pass - Through Payments "), and (iii) amounts payable under the Pass - Through Agreement. Upon satisfaction of the Successor Agency's obligations under the Senior Bonds and Senior Indenture, Subordinate Tax Revenues shall mean Tax Revenues as defined herein, subject to amounts due under the Pass - Through Agreement and for Statutory Pass - Through Payments. Pursuant to the Indenture, the Bonds and any Parity Debt shall be equally secured by a pledge of, security interest in and lien on all of the Subordinate Tax Revenues in the Redevelopment Obligation OHSUSA:765600743.3 Retirement Fund and a first and exclusive pledge of, security interest in and lien upon all of the moneys in the Debt Service Fund, the Interest Account, Principal Account and the Redemption Account, established under the Indenture. See "SECURITY FOR THE BONDS." As used in this Official Statement and in the Fiscal Consultant's Report attached to this Official Statement as APPENDIX A, the term "Gross Tax Revenues" means all property tax revenues deposited in the designated property tax (formerly tax increment revenues) related to the Project Area, which will include, moneys deposited, from time to time, in the Redevelopment Property Tax Trust Fund held and administered by the Office of the Auditor Controller of the County of Los Angeles (the "County Auditor - Controller") with respect to the Successor Agency (the "Redevelopment Property Tax Trust Fund" or "RPTTF "). The Senior Bonds are generally secured by "Pledged Revenues" which are equal to Gross Tax Revenues less County Administrative Fees and amounts payable by the Successor Agency pursuant to the Pass - Through Agreement. As defined in the Indenture, the term "Tax Revenues" means, for each Fiscal Year, all moneys derived from that portion of taxes levied upon assessable property within the Project Area deposited from time to time in the Redevelopment Property Tax Trust Fund, as provided in paragraph (2) of subdivision (a) of Section 34183 of the Law, excluding amounts if any, payable by the Successor Agency pursuant to Sections 33676, 33607.5, 33607.7 and 34183(a)(1) of the Law, including amounts payable under the Pass - Through Agreement, except to the extent that such amounts are payable on a basis subordinate to the payment of Annual Debt Service on the 2016 Bonds or any Parity Debt pursuant to Sections 33607.5(e) and 34177.5(c) of the Law or pursuant to the terms of the Pass - Through Agreement, as applicable. The Bonds shall be also equally secured by the pledge and lien created with respect to the Bonds by Section 34177.5(g) of the Law on the Tax Revenues deposited from time to time in the RPTTF. As provided in the Indenture, the Successor Agency shall deposit all Tax Revenues into the Redevelopment Obligation Retirement Fund promptly upon receipt thereof. Except for the Tax Revenues and such moneys, no funds or properties of the Successor Agency shall be pledged to, or otherwise liable far, the payment of principal of or interest on the 2016 Bonds or any amounts due and owing to the Insurer with respect to the Policy or the 2016 Reserve Surety. Pursuant to the Indenture, the Bonds shall be additionally secured by a first and exclusive pledge of, security interest in and lien upon all of the moneys in the Reserve Account established under the Indenture. The Senior Bands as defined herein, consisting of $ currently outstanding principal amount of the $11,230,000 Rosemead Merged Project Area, Tax Allocation Bonds, Series 2010A (the "Senior Bonds ") were issued by the Former Agency on July 15, 2010. The proceeds from the sale of the Senior Bonds were used to: (i) finance the cost of certain redevelopment projects within the Project Area, (ii) fund a reserve account for the Senior Bonds, and (iii) pay costs associated with the issuance of the Senior Bonds. The Senior Bonds are secured from tax increment revenues generated from the Project Area. The Senior Bonds were issued pursuant to an Indenture, dated as of June 1, 2010 (the "Senior Indenture "), by and between the Former Agency and U.S. Bank National Association, as trustee. SB 107, which became effective September 22, 2015, amended the Dissolution Act to provide that the time limits for receiving property tax revenues and the limitation on the amount of property tax revenues that may be received by the Successor Agency set forth in the Redevelopment Plan are not effective for purposes of paying the Successor Agency's enforceable obligations such as the Senior Bonds, the 2016 Bonds and Parity Debt. Accordingly, the projections set forth in this Official Statement and in the Fiscal Consultant's Report attached to this Official Statement as APPENDIX A were prepared without regard to the time and financial limitations set forth in the Redevelopment Plan. 4 OHSUSA:765600743.3 Terms of the 2016 Bonds The 2016 Bonds will be issued in denominations of $5,000 and any integral multiple thereof (the "Authorized Denominations "). The 2016 Bonds will be dated their date of delivery and are payable with respect to interest semiannually each June 1 and December 1, commencing on June 1, 2017. The 2016 Bonds will be delivered in fully - registered form only, and when delivered, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York ( "DTC "). DTC will act as securities depository for the 2016 Bonds. Ownership interests in the 2016 Bonds may be purchased in book -entry form only. Principal of and interest on the 2016 Bonds will be paid by the Trustee to DTC or its nominee, which will in turn remit such payments to its Participants (defined herein) for subsequent disbursement to the Owners of the 2016 Bonds. See APPENDIX G — "DTC AND BOOK -ENTRY ONLY SYSTEM" attached hereto. The 2016 Bonds are subject to redemption prior to maturity, as described herein. See "THE 2016 BONDS — Redemption of the 2016 Bonds" herein. Municipal Bond Insurance Policy and Reserve Fund Surety The Successor Agency has applied for a municipal bond insurance policy which may insure some or all maturities of the 2016 Bonds and a debt service reserve fund policy for the 2016 Bonds as described herein. If any such policies are purchased, the Official Statement will be revised to specify the insured maturities of the 2016 Bonds and to reflect the material terms of such municipal bond insurance and /or debt service reserve fund policies and the Indenture will be revised to reflect such terms and the rights and obligations of the provider. Professionals Involved in the Offering U.S. Bank National Association, Los Angeles, California, will act as trustee with respect to the 2016 Bonds under the Indenture. Urban Futures, Inc., Orange, California, has acted as Municipal Advisor to the Successor Agency in the structuring and presentation of the financing. Urban Futures, Inc., Orange, California, has also acted as Fiscal Consultant to the Successor Agency and has prepared an analysis of taxable values and tax increment revenues in the Project Area. See APPENDIX A — "FISCAL CONSULTANT REPORT" herein. All proceedings in connection with the issuance of the 2016 Bonds are subject to the approval of Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel. Orrick, Herrington & Sutcliffe LLP is acting as Disclosure Counsel. Certain legal matters will be passed on for the Successor Agency by the City Attorney, Burke, Williams & Sorensen, LLP, as general counsel to the Successor Agency, and for the Underwriter by Norton Rose Fulbright US LLP, Los Angeles, California. Bond Counsel, Disclosure Counsel and Underwriter's Counsel undertake no responsibility for the accuracy, completeness or fairness of this Official Statement. The fees and expenses of the Municipal Advisor, Bond Counsel, Disclosure Counsel and Underwriter's Counsel are contingent upon the sale and delivery of the 2016 Bonds. OHSUSA:765600743.3 Continuing Disclosure With respect to continuing disclosure, the Successor Agency will prepare and provide annual updates of the information contained in the tables included in this Official Statement with respect to property tax revenues, collections, any material delinquencies, principal taxpayers, and notices of enumerated events as required under the Continuing Disclosure Certificate. Initially, the Successor Agency will act as Dissemination Agent and will ensure that the annual reports and notices are filed with the Municipal Securities Rulemaking Board (the "MSRB ") through its Electronic Municipal Market Access system ( "EMMA "). See the caption "OTHER INFORMATION — Continuing Disclosure" and APPENDIX F — "FORM OF CONTINUING DISCLOSURE CERTIFICATE." Reference to Underlying Documents Brief descriptions of the 2016 Bonds, the Indenture, the Successor Agency, the Project Area and other related information are included in this Official Statement. Such descriptions and information do not purport to be comprehensive or definitive. The summaries of and references to all documents, statutes, reports and other instruments referred to herein is qualified in its entirety by reference to such document, statute, report or instrument, copies of which are all available for inspection at the offices of the Successor Agency. Certain capitalized terms used and not defined herein shall have the meaning given to those terms in APPENDIX D — "SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE" attached hereto. PLAN OF REFUNDING Net proceeds of the 2016 Bonds, together with other available moneys, will be applied to refund and redeem all of the outstanding Refunded Bonds. The following table details the Refunded Bonds. Series 2006A Bonds Series 2006B Bonds Maturity Date Principal Interest Principal Interest (October 1) Amount Rate CUSIP No. Amount Rate CUSIP No. 2017 $1,200,000 4.000% 777510AMO $ 95,000 3.700% 777510BD9 2018 1,250,000 4.250 777510AN8 100,000 3.750 777510BE7 2019 280,000 4.000 777510AP3 725,000 4.000 777510BF4 2019 -- -- 400,000 4.500 777510BR8 2020 290,000 4.125 77751OAQI 1,175,000 4.000 777510BG2 2021 300,000 4.125 777510AR9 1,220,000 4.000 77751OBHO 2022 315,000 4.125 777510AS7 1,270,000 4.125 777510BJ6 2023 -- 1,320,000 4.200 777510BK3 2024 1,375,000 4.250 777510BL1 2025 1,430,000 4.250 777510BM9 2033 10,595,000 4.375 777510BP2 2033 3,500,00 5.000 777510BQO $3,635,000 $23,205,000 On the date of issuance of the 2016 Bonds, a portion of the proceeds thereof, together with other available moneys, will be deposited in a special fund for the outstanding Series 2006A Bonds (the "Series 2006A Bonds Refunding Fund") and a special fund for the outstanding Series 2006B Bonds (the "Series 2006B Bonds Refunding Fund "), to be held in trust by U.S. Bank National Association, as prior trustee, in accordance with those Irrevocable Refunding Instructions with respect to the Refunded Bonds dated December _, 2016 (the "Instructions "). The Successor Agency expects to apply remaining amounts in OHSUSA:765600743.3 the aggregate amount of $ currently on deposit under the indentures for the Refunded Bonds in accordance with the Instructions. Such funds on hand and proceeds deposited, respectively, into the 2006A Bonds Refunding Fund and the 2006B Bonds Refunding Fund (together referred to herein as the "Refunding Funds ") pursuant to the Instructions will be held uninvested, and applied to pay the redemption price of the respective series of Refunded Bonds on December _, 2016, at a redemption price equal to 100% of their principal amount as specified in the Instructions, plus accrued interest. See "ESTIMATED SOURCES AND USES OF FUNDS." Upon deposit of such proceeds and other moneys into the Refunding Funds, the Refunded Bonds will no longer be deemed outstanding. The moneys held in accordance with the Instructions are pledged solely to the payment of the Refunded Bonds and are not available to pay principal of or interest on the 2016 Bonds or other outstanding bonds of the Successor Agency. See "ESTIMATED SOURCES AND USES OF FUNDS" below. See also "OTHER INFORMATION — Verification of Mathematical Accuracy" below. ESTIMATED SOURCES AND USES OF FUNDS Set forth below are the estimated sources and uses of proceeds of the 2016 Bonds. Sources: Par Amount of 2016 Bonds Net Original Issue Premium (Discount) Amounts Released from accounts of Refunded Bonds TOTALSOURCES Uses: Deposit to Refunding Fund Costs of Issuance TOTAL USES: P) Includes $ for deposit in the 2006A Bonds Refunding Fund and $ for deposit in the 2006B Bonds Refunding Fund under the Instructions to be applied to the refunding of the Refunded Bonds. (a) Deposit to the Costs of Issuance Account includes premiums for the Policy and the 2016 Reserve Surety, Underwriter's discount, legal fees, printing, rating agency fees and expenses, fees of the Municipal Advisor, fees of the Fiscal Consultant, and other issuance costs of the 2016 Bonds. OHSUSA:765600743.3 ANNUAL DEBT SERVICE REQUIREMENTS OF THE BONDS The following table provides the annual debt service requirements of the Senior Bonds and the 2016 Bonds. Fiscal Year Ended (Dec. 1) 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 Total Senior Bonds 2016 Bonds Principal Interest Total Annual Total Nate: Totals may not 6e due to rounding. General THE 2016 BONDS The 2016 Bonds will be dated as of the date of original delivery (the "Closing Date "), will bear interest at the rates per annum and will mature on the dates and in the amounts set forth on the inside cover page hereof. The 2016 Bonds will be issued in fully registered form, without coupons, in the denomination of $5,000 each or any integral multiple thereof. Interest on the 2016 Bonds is payable semiannually on June 1 and December 1 of each year, commencing June 1, 2017 (each an "Interest Payment Date "). While the 2016 Bonds are held in the book -entry only system of DTC, all such payments of principal, interest and premium, if any, will be made to Cede & Co. as the registered owner of the 2016 Bonds, for subsequent disbursement to Participants and beneficial owners. See APPENDIX G — "DTC AND BOOK -ENTRY SYSTEM." Interest on the 2016 Bonds (including the final interest payment upon maturity or earlier redemption) shall be payable on each Interest Payment Date to the person whose name appears on the Registration Books as the Owner thereof as of the fifteenth day of the month preceding the Interest Payment Date (the "Record Date ") immediately preceding each such Interest Payment Date, such interest to be paid by check of the Trustee mailed by first class mail, postage prepaid, on the Interest Payment Date, to such Owner at the address of such Owner as it appears on the Registration Books as of such Record Date; provided however, that payment of interest may be by wire transfer to an account in the United States of America to any registered owner of 2016 Bonds in the aggregate principal amount of OHSUSA:765600743.3 $1,000,000 or more who shall furnish written wire instructions to the Trustee prior to the applicable Record Date. Principal of and redemption premium (if any) on any 2016 Bond shall be paid upon presentation and surrender thereof, at maturity or earlier redemption, at the Principal Corporate Trust Office of the Trustee. Both the principal of and interest and redemption premium (if any) on the 2016 Bonds shall be payable in lawful money of the United States of America. Each 2016 Bond shall bear interest from the Interest Payment Date next preceding the date of authentication thereof, unless (a) it is authenticated after a Record Date and on or before the following Interest Payment Date, in which event it shall bear interest from such Interest Payment Date; or (b) a 2016 Bond is authenticated on or before the first Record Date, in which event it shall bear interest from the Closing Date; provided, however, that if, as of the date of authentication of any 2016 Bond, interest thereon is in default, such 2016 Bond shall bear interest from the Interest Payment Date to which interest has previously been paid or made available for payment thereon. Redemption of the 2016 Bonds Optional Redemption. The 2016 Bonds maturing on or before December 1, 20_ are not subject to optional redemption prior to maturity. The 2016 Bonds maturing on and after December 1, 20, are subject to redemption, at the option of the Successor Agency on any date on or after December 1, 20_, as a whole or in part, by such maturities as shall be determined by the Successor Agency, and by lot within a maturity, from any available source of funds, at a redemption price equal to the principal amount of the 2016 Bonds to be redeemed, together with accrued interest thereon to the date fixed for redemption, without premium. The Successor Agency will give the Trustee written notice of its intention to redeem 2016 Bonds by optional redemption with a designation of the principal amount and maturities to be redeemed at least forty -five (45) days prior to the date fixed for such redemption (or such later date as is acceptable to the Trustee).. Mandatory Sinking Account Redemption. The 2016 Bonds that are Term Bonds maturing December 1, 20_ and maturing December 1, 20_ shall be subject to mandatory redemption in whole, or in part by lot, on December 1 in each year, commencing December 1, 20_, as set forth below, from sinking fund payments made by the Successor Agency to the Principal Account at a redemption price equal to the principal amount thereof to be redeemed, without premium, in the aggregate respective principal amounts and on December 1 in the respective years as set forth in the following table; provided however, that in lieu of redemption thereof such Term Bonds may be purchased by the Successor Agency pursuant to the Indenture: Sinking Payment Principal Amount Date (December 1) to be Redeemed 20 20 20—* Final Maturity. If some but not all of such Term Bonds have been optionally redeemed pursuant to the Indenture, the total amount of all future sinking fund payments shall be reduced by the aggregate principal amount of such Term Bonds so redeemed, to be allocated among such sinking fund payments in integral multiples of $5,000 as determined by the Successor Agency (notice of which determination shall be given by the Successor Agency to the Trustee) and shall include a revised sinking fund schedule. OHSUSA:765600743.3 Notice of Redemption. The Trustee on behalf and at the expense of the Successor Agency will mail (by first class mail, postage prepaid) notice of any redemption at least twenty (20) but not more than forty -five (45) days prior to the redemption date, to (i) to the Owners of any 2016 Bonds designated for redemption at their respective addresses appearing on the Registration Books, and (ii) the Securities Depositories and to the Information Services; but such mailing shall not be a condition precedent to such redemption and neither failure to receive any such notice nor any defect therein shall affect the validity of the proceedings for the redemption of such 2016 Bonds or the cessation of the accrual of interest thereon. Such notice will state the redemption date and the redemption price, will state that optional redemption is conditioned upon the timely delivery of the redemption price by the Successor Agency to the Trustee for deposit in the Redemption Account, will designate the CUSIP number of the 2016 Bonds to be redeemed, will state the individual number of each Bond to be redeemed or will state that all 2016 Bonds between two stated numbers (both inclusive) or all of the Bonds Outstanding are to be redeemed, and will require that such 2016 Bonds be then surrendered at the Principal Corporate Trust Office of the Trustee for redemption at the redemption price, giving notice also that further interest on such 2016 Bonds will not accrue from and after the redemption date. The Successor Agency has the right to rescind any notice of the optional redemption of 2016 Bonds by written notice to the Trustee on or prior to the date fixed for redemption, and the redemption notice may provide that the proposed redemption is subject to the availability of sufficient funds on the scheduled redemption date. Any notice of optional redemption will be cancelled and annulled if for any reason funds will not be or are not available on the date fixed for redemption for the payment in full of the 2016 Bonds then called for redemption, and such cancellation shall not constitute an Event of Default. The Successor Agency and the Trustee have no liability to the Owners or any other party related to or arising from such rescission of redemption. The Trustee will mail notice of such rescission of redemption in the same manner as the original notice of redemption was sent. Upon the payment of the redemption price of 2016 Bonds being redeemed, each check or other transfer of funds issued for such purpose will, to the extent practicable, bear the CUSM number identifying, by issue and maturity, the 2016 Bonds being redeemed with the proceeds of such check or other transfer. Partial Redemption of 2016 Bonds. In the event only a portion of any 2016 Bond is called for redemption, then upon surrender of such 2016 Bond the Successor Agency shall execute and the Trustee shall authenticate and deliver to the Owner thereof, at the expense of the Successor Agency, a new 2016 Bond or 2016 Bonds of the same interest rate and maturity, of authorized denominations, in aggregate principal amount equal to the unredeemed portion of the 2016 Bond to be redeemed. Effect of Redemption. From and after the date fixed for redemption, if funds available for the payment of the redemption price of and interest on the 2016 Bonds so called for redemption shall have been duly deposited with the Trustee, such 2016 Bonds so called shall cease to be entitled to any benefit under the Indenture other than the right to receive payment of the redemption price and accrued interest to the redemption date, and no interest shall accrue thereon from and after the redemption date specified in such notice. Manner of Redemption. Whenever any 2016 Bonds or portions thereof are to be selected for redemption by lot within a maturity, the Trustee shall make such selection, in such manner as the Trustee shall deem appropriate, and shall notify the Successor Agency thereof to the extent 2016 Bonds are no longer held in book -entry form. All 2016 Bonds redeemed or purchased under the Indenture shall be cancelled and destroyed. Purchase in Lieu of Redemption. In lieu of redemption of the Term Bonds, amounts on deposit in the Principal Account may also be used and withdrawn by the Successor Agency and the Trustee, respectively, at any time, upon the Written Request of the Successor Agency, for the purchase of the Term Bonds at public or private sale as and when and at such prices (including brokerage and other OHSUSA:765600743.3 10 charges, but excluding accrued interest, which is payable from the Interest Account) as the Successor Agency may in its discretion determine. The par amount of any Term Bonds so purchased by the Successor Agency in any twelve -month period ending on October 1 in any year shall be credited towards and shall reduce the par amount of the Term Bonds required to be redeemed on December 1 in each year; provided that evidence satisfactory to the Trustee of such purchase has been delivered to the Trustee by said October 1. In no event shall the Successor Agency purchase any Term Bonds in lieu of redemption without canceling such Term Bonds. SECURITY FOR THE BONDS Subordinate Tax Revenues Pursuant to the Indenture, the 2016 Bonds and any Parity Debt shall be equally secured by a pledge of, security interest in and lien on all of the Subordinate Tax Revenues, including all of the Subordinate Tax Revenues in the Redevelopment Obligation Retirement Fund and a first and exclusive pledge of, security interest in and lien upon all of the moneys in the Debt Service Fund, the Interest Account, Principal Account and the Redemption Account, established under the Indenture. The 2016 Bonds shall be additionally secured by a first and exclusive pledge of, security interest in and lien upon all of the moneys in the Reserve Account established under the Indenture. The 2016 Bonds shall be also equally secured by the pledge and lien created with respect to the Bonds by Section 34177.5(g) of the Law on the Subordinate Tax Revenues deposited from time to time in the Redevelopment Property Tax Trust Fund. The 2016 Bonds shall be payable from Subordinate Tax Revenues. As defined in the Indenture, the term "Subordinate Tax Revenues" means, for each Fiscal Year, the Tax Revenues, as defined in the Senior Indenture and as defined herein, minus (i) the amount needed by the Successor Agency for payment of debt service on the Senior Bonds and any other payment obligations due under the Senior Indenture, (ii) amounts payable by the Successor Agency pursuant to Sections 33676, 33607.5, 33607.7 and 34183(a)(1) of the Law ( "Statutory Pass - Through Payments "), and (iii) amounts payable under the Pass - Through Agreement. Upon satisfaction of the Successor Agency's obligations under the Senior Bonds and Senior Indenture, Subordinate Tax Revenues shall mean Tax Revenues as defined herein, subject to amounts due under the Pass - Through Agreement and for Statutory Pass - Through Payments. Pursuant to the Indenture, the Bonds and any Parity Debt shall be equally secured by a pledge of, security interest in and lien on all of the Subordinate Tax Revenues in the Redevelopment Obligation Retirement Fund and a first and exclusive pledge of, security interest in and lien upon all of the moneys in the Debt Service Fund, the Interest Account, Principal Account and the Redemption Account, established under the Indenture. See "SECURITY FOR THE BONDS." As used in this Official Statement and in the Fiscal Consultant's Report attached to this Official Statement as APPENDIX A, the term "Gross Tax Revenues" means all property tax revenues deposited in the designated property tax (formerly tax increment revenues) related to the Project Area, which will include, moneys deposited, from time to time, in the Redevelopment Property Tax Trust Fund held and administered by the Office of the Auditor Controller of the County of Los Angeles (the "County Auditor - Controller") with respect to the Successor Agency (the "Redevelopment Property Tax Trust Fund" or "RPTTF "). The Senior Bonds are generally secured by "Pledged Revenues" which are equal to Gross Tax Revenues less County Administrative Fees and amounts payable by the Successor Agency pursuant to the Pass - Through Agreement. As defined in the Indenture, the term "Tax Revenues" means, for each Fiscal Year, all moneys derived from that portion of taxes levied upon assessable property within the Project Area deposited from time to time in the Redevelopment Property Tax Trust Fund, as provided in paragraph (2) of subdivision 11 OHSUSA:765600743.3 (a) of Section 34183 of the Law, excluding amounts if any, payable by the Successor Agency pursuant to Sections 33676, 33607.5, 33607.7 and 34183(a)(1) of the Law, including amounts payable under the Pass - Through Agreement, except to the extent that such amounts are payable on a basis subordinate to the payment of Annual Debt Service on the 2016 Bonds or any Parity Debt pursuant to Sections 33607.5(e) and 34177.5(c) of the Law or pursuant to the terms of the Pass - Through Agreement, as applicable. The Bonds shall be also equally secured by the pledge and lien created with respect to the Bonds by Section 34177.5(g) of the Law on the Tax Revenues deposited from time to time in the RPTTF. As provided in the Indenture, the Successor Agency shall deposit all Tax Revenues into the Redevelopment Obligation Retirement Fund promptly upon receipt thereof. Except for the Tax Revenues and such moneys, no funds or properties of the Successor Agency shall be pledged to, or otherwise liable for, the payment of principal of or interest on the 2016 Bonds or any amounts due and owing to the Insurer with respect to the Policy or the 2016 Reserve Surety. The term "Senior Bonds" is defined in the Indenture to mean the $ currently outstanding principal amount of the $11,230,000 Rosemead Merged Project Area, Tax Allocation Bonds, Series 2010A payable on each June 1 and December 1, with a final maturity of December 1, 2023. The Senior Bonds were issued pursuant to the Senior Indenture. The term "Pass- Through Agreement' is defined in the Indenture to mean the Agreement for Reimbursement of Tax Increment Funds (Rosemead Redevelopment Agency Project Area No. 1), made and entered into on July 1, 1988, by and among the Former Agency, the County, the County Public Library District (the "Library District') and the Consolidated Fire Protection District (the "Fire District'), entered into by the Former Agency pursuant to Section 33401 of the Law. Except for the Subordinate Tax Revenues and such moneys, no funds or properties of the Successor Agency shall be pledged to, or otherwise liable for, the payment of principal of or interest on the 2016 Bonds or any amounts due and owing to the Insurer with respect to the 2016 Insurance Policy or the 2016 Reserve Surety. The Successor Agency has heretofore established the Redevelopment Obligation Retirement Fund pursuant to Section 34170.5(a) of the Law which the Successor Agency shall continue to hold and maintain so long as any of the Bonds are Outstanding. As provided in the Indenture, the Successor Agency shall deposit all Tax Revenues into the Redevelopment Obligation Retirement Fund promptly upon receipt thereof. All Subordinate Tax Revenues received by the Successor Agency in excess of amounts required under the Indenture or as additionally required pursuant to a Supplemental Indenture or Parity Debt Instrument, and except as may be provided to the contrary in the Senior Indenture or Parity Debt Instrument, shall be released from the pledge and lien under the Indenture and shall be applied in accordance with the Law, including but not limited to the payment of debt service on any Subordinate Debt. Prior to the payment in full of the principal of and interest and redemption premium (if any) on the Bonds and the payment in full of all other amounts payable under the Indenture and under any Supplemental Indentures, the Successor Agency shall not have any beneficial right or interest in the moneys on deposit in the Redevelopment Obligation Retirement Fund, except as may be provided in the Indenture and in any Supplemental Indenture. As defined in the Indenture, the term "Subordinate Debt' means any loan, advances or indebtedness issued or incurred by the Successor Agency, which are either: (a) payable from, but not secured by a pledge of or lien upon, the Subordinate Tax Revenues, including revenue bonds and other debts and obligations scheduled for payment pursuant to Section 34183(a)(2) of the Law; or (b) secured by a pledge of or lien upon the Subordinate Tax Revenues which is subordinate to the pledge of and lien OHSUSA:765600743.3 12 upon the Subordinate Tax Revenues hereunder for the security of the Bonds and payable on the same dates as the Bonds. As provided in the Indenture, pursuant to Section 34177 of the Law, not later than each date a Recognized Obligation Payment Schedule is due, the Successor Agency shall submit to the Oversight Board and the State Department of Finance, a Recognized Obligation Payment Schedule. The Successor Agency shall take all actions required under the Law to include in the Recognized Obligation Payment Schedule for each Semiannual Period (i) amounts due with respect to the Senior Bonds under the Senior Indenture, (ii) debt service on the 2016 Bonds and (iii) all amounts due and owing to the Insurer under the Indenture, so as to enable the County Auditor - Controller to distribute from the Redevelopment Property Tax Trust Fund for deposit in the Redevelopment Obligation Retirement Fund on each January 2 and June 1, as applicable, amounts required to enable the Successor Agency to pay timely principal of, and interest on, the 2016 Bonds on a timely basis, as such amounts of debt service are set forth in the Recognized Obligation Payment Schedule attached to the Indenture, as well as all amounts due and owing to the Insurer thereunder. Without limiting the foregoing, in order to ensure that amounts are available for the Trustee to pay debt service on all Outstanding Bonds and all amounts due and owing to the Series Insurer under the Indenture on a timely basis, the Successor Agency has agreed under the Indenture that not later than February 1, 2017 and each February 1 thereafter (or at such earlier time as may be required by the Dissolution Act), for so long as any Bonds are outstanding, the Successor Agency will submit an Oversight Board- approved ROPS to the DOF and to the County Auditor - Controller that will include (a) for distribution on the immediately succeeding June 1, interest on all Outstanding Bonds due on the immediately succeeding December 1 plus 50% of principal due on the Outstanding Bonds on such December 1, which amounts will distributed to the Successor Agency, (b) for distribution on the immediately succeeding January 2, interest on all Outstanding Bonds due on the immediately succeeding June 1 plus 50% of principal due on all Outstanding Bonds on the immediately succeeding December 1, and (d) any amount required to cure any deficiency in the Reserve Account and subaccounts thereunder pursuant to the Indenture (including any amounts required due to a draw on any Qualified Reserve Instrument as well as all amounts due and owing to the Insurer under the Indenture). In the event the provisions set forth in the Dissolution Act as of the Closing Date of the 2016 Bonds that relate to the filing of ROPS are amended or modified in any manner, the Successor Agency agrees under the Indenture to take all such actions as are necessary to comply with such amended or modified provisions so as to ensure the timely payment of debt service on the Bonds and, if the timing of distributions of the RPTTF is changed, the receipt of (i) not less than one of half of debt service due during each Bond Year on all Outstanding Bonds prior to June 1 of such Bond Year, and (ii) the remainder of debt service due during such Bond Year on all Outstanding Bonds prior to the next succeeding December 1. Limitation on Issuance of Senior Bonds The Successor Agency covenants under the Indenture that it will not issue any bonds, notes, or other obligations that are payable from or secured by a lien on Tax Revenues that is superior to the lien under the Indenture. Pass - Through Arrangements Pass - Through Agreement. Under the Pass - Through Agreement: (i) the Successor Agency, as successor to the Former Agency, is to provide for a pass- through of a portion of its tax increment revenues with respect to Component Area No. 1 received after July 1, 1988 for the Fire District; and (ii) the Successor Agency, as successor to the Former Agency, is to allow an additional pass- through of tax increment revenues with respect to Component Area No. 1 for the Library District at such time that the OHSUSA:765600743.3 13 Former Agency or the City constructs a replacement facility. The Successor Agency currently does not make any payments pursuant to the Pass - Through Agreement to the Library District because no such facility has been constructed. The City and the Successor Agency have no current plans to proceed with the construction of any replacement library facility. The reimbursement of the Fire District is approximately 17% of gross tax revenues with respect to Component Area No. 1 and the reimbursement to the Library District, if any, is 4% of gross tax revenues with respect to Component Area No. 1. Such pass - through payments are payable from tax increment revenues from Component Area No. 1 senior to the pledge and lien established pursuant to the Indenture and will not be available to the Successor Agency to pay debt service on the 2016 Bonds. Statutory Pass- Through Payments. The Successor Agency is obligated to make statutory pass - through payments to all affected tax agencies that do not currently have a tax sharing agreements. [The general levy share of all agencies that do not currently possess tax - sharing agreements is 83% of every $1.00 of property tax generated.] Affected taxing entities that may receive a share of Statutory Pass - Through Payments include the City of Rosemead, County, Library District, Los Angeles County Flood Control District, Los Angeles County Sanitation District No. 15, Upper San Gabriel Valley Metropolitan Water District, Los Angeles County Office of Education (County School Services), Garvey School District, Rosemead School District, Alhambra Unified School District, El Monte School District, Los Angeles Community College District, Pasadena Community College District, and the Montebello School District. The Fire District is not eligible to receive statutory pass through payments from Component Area No. 1, as it currently receives pass through payments pursuant to the Pass - Through Agreement. The Fire District may receive statutory pass through payments in Component Area No. 2. Although the Library District is a party to the Pass - Through Agreement, pursuant to the terms of the Pass - Through Agreement the Library District is not currently receiving payments under the Pass - Through Agreement, and the County and the Former Agency agreed that the Library District is therefore eligible to receive statutory pass through payments from Component Area No. 1. These payments are a result of Senate Bill No. 211 (Statutes of 2001 Chapter 741) ( "SB 211 "), which provided a procedure by which any redevelopment plan or amendment adopted prior to January 1, 1994 could extend the then current time limit to incur indebtedness of its plan or amendment to the expiration date of the plan or amendment. As a result the Former Agency initiated statutory pass - throughs to all affected tax agencies that did have tax sharing agreements. The AB 1290 Pass Through Formula will apply to all taxing entities in Component Area No. 2 (and some of the Component Area No. 1 taxing entities, as noted above), and will be applied as follows: Pass Through Percentagel Tier A (Years 1 -45) 25% Tier B (Years 11 -45) 21% k Tier A Tier C (Years 31 -45) 14 %+ Tiers A & B (t) Applied to the taxing entity's share of tax increment, reduced by a pro - ram share of Agency's Former LW Housing Set - Aside. Statutory pass- through payments are payable on a senior basis to debt service on bonds under the Dissolution Act, unless the pass- through payments have been subordinated. The Redevelopment Law, as amended by the Dissolution Act, allows statutory pass - through payments to be subordinated to debt service on the Successor Agency's bonds. However, the Successor Agency did not seek or obtain the consent from any taxing entities to subordinate their right to receive statutory payments to the payment of 14 OHSUSA:765600743.3 debt service on the 2016 Bonds. Accordingly, statutory pass - through payments from the Project Area are payable on a senior basis to debt service on the 2016 Bonds. See "APPENDIX A — FISCAL CONSULTANT'S REPORT." See the projections of [Pledged Tax Revenues and Subordinate Tax Revenues] in Exhibit A to the Fiscal Consultant's Report attached hereto as APPENDIX A and Table _ herein. The Successor Agency does not pay a pass through payment to the Library District because no facility has been constructed. [The County includes the unitary assessed values in its calculation of SB 211 pass - throughs. However, there is no consistent methodology among various counties within the State as to the calculation of SB 211 pass - tbroughs. For the purpose of the projections set forth herein, the City has calculated the pass - throughs based on the County's current methodology.] Reserve Account The Indenture provides for the establishment of a separate account within the Debt Service Fund a separate account known as the "Reserve Account" which shall be held by the Trustee in trust for the benefit of the Owners of the 2016 Bonds. The Reserve Requirement for the 2016 Bonds will be satisfied by the delivery of the 2016 Reserve Surety by the Insurer on the Closing Date with respect to the 2016 Bonds, the policy premium for which will be paid from a portion of the proceeds derived from the issuance and sale of the 2016 Bonds. For additional information regarding the Insurer, see "BOND INSURANCE." All money in the Reserve Account shall be used and withdrawn by the Trustee solely for the purpose of making transfers to the Interest Account and the Principal Account, in the event of any deficiency at any time in any of such accounts or for the retirement of all the 2016 Bonds then Outstanding. The term "Reserve Requirement" means, with respect to the 2016 Bonds, the lesser of (i) 10% of the original aggregate principal amount of the 2016 Bonds (if there is more than a de minimis amount of original issue discount or premium (as defined in the Code), the issue price shall be used instead of principal amount) or (ii) 125% of the average Annual Debt Service with respect to the 2016 Bonds or (iii) Maximum Annual Debt Service with respect to the 2016 Bonds. The Successor Agency will have no obligation to replace the 2016 Policy or to fund the Reserve Account with cash if, at any time that the 2016 Bonds are Outstanding, amounts are not available under the 2016 Reserve Surety other than in connection with a draw on the 2016 Reserve Surety. [Terms of Reserve Policy] 2016 Bonds Not a Debt of the City, County or the State The 2016 Bonds are limited obligations of the Successor Agency and are payable, as to interest thereon and principal thereof, exclusively from Subordinate Tax Revenues, including all of the Subordinate Tax Revenues in the Redevelopment Obligation Retirement Fund and a first and exclusive pledge of, security interest in and lien upon all of the moneys in certain funds and accounts established under the Indenture as described in this Official Statement. The 2016 Bonds are also equally secured by the pledge and lien created with respect to the 2016 Bonds by Section 34177.5(g) of the Law on the Tax Revenues deposited from time to time in the Redevelopment Property Tax Trust Fund. The 2016 Bonds are not a debt of the City, the State of California or any of its political subdivisions, and neither the City, the State nor any of its political subdivisions is liable therefor, nor in any event will the 2016 Bonds be payable out of any funds or properties other than those of the Successor Agency. The 2016 Bonds do not constitute an indebtedness within the meaning of any constitutional or statutory limitation or restriction, and neither the members of the Successor Agency nor any persons executing the 2016 Bonds are liable personally on the 2016 Bonds by reason of their issuance. 15 OHSUSA:765600743.3 Additional Parity Debt The Successor Agency may issue Parity Debt to refund all or a portion of the Outstanding Bonds provided that with respect to any such refunding (i) debt service on such Parity Debt, as applicable, is lower than debt service on the obligations being refunded during the remaining period the obligations would otherwise be outstanding (ii) the final maturity of any such Parity Debt does not exceed the final maturity of the obligations being refunded, (iii) the interest rate on the Parity Debt shall be fixed on the date of issuance of the Parity Debt, and (iv) principal payments shall be on December 1 and interest payments on June 1 and December 1. The Successor Agency further covenants in the Indenture not to issue bonds on a parity with the Senior Bonds. Nothing in the Indenture shall prevent the Successor Agency from issuing Subordinate Debt. BOND INSURANCE [TO COME] THE SUCCESSOR AGENCY General As described below, the Successor Agency was established by the City Council following dissolution of the Former Agency pursuant to the Dissolution Act. Set forth below is a discussion the history of the Former Agency and the Successor Agency, the governance and operations of the Successor Agency and its powers under the Redevelopment Law and the Dissolution Act, and the limitations thereon. The City, acting pursuant to the Redevelopment Law, activated the Former Agency in 1972 by City ordinance. Under the terms of this Ordinance the City Council declared itself to be the governing body of the Former Agency. As a result of AB 1X 26 and the decision of the California Supreme Court in the California Redevelopment Association case, as of February 1, 2012, all redevelopment agencies in the State were dissolved, including the Former Agency, and successor agencies were designated as successor entities to the former redevelopment agencies to expeditiously wind down the affairs of the former redevelopment agencies and also to satisfy "enforceable obligations" of the former redevelopment agency all under the supervision of a new oversight board, the State Department of the Finance and the State Controller. The present members of the City Council acting as the board members of the Successor Agency are as follows: Sandra Armenta, Mayor Polly Low, Mayor Pro -Tem Bill Alarcon, Council Member Margaret Clark, Council Member Steven Ly, Council Member The Successor Agency is a component unit of the City for financial reporting purposes and does not have separate audited financial statements. The audited financial statements of the City for year ending June 30, 2015, are included herein as APPENDIX C. The Successor Agency has one project area, the Rosemead Merged Project Area, consisting of two component areas, which is referred to as the Project Area herein (see "THE PROJECT AREA "). 16 OHSUSA:765600743.3 Successor Agency Staff The City Manager also serves as the Executive Director of the Successor Agency. The City Finance Director maintains the Successor Agency's financial records and serves as the Successor Agency's Treasurer. The City Attorney also serves as the Successor Agency's counsel. Brief resumes of the key staff at the City and Successor Agency are set forth below: Bill R. Manis, City Manager. Bill R. Manis has worked in the public sector for 31 years and has held numerous positions in seven jurisdictions. During his career, Mr. Manis has overseen over 10 million square feet of development projects resulting in over 10,000 new jobs, implemented numerous programs to help the economically disadvantaged, and served a key member of the San Bernardino Bankruptcy Recovery Team. Mr. Manis received his Bachelors of Science Degree in City & Regional Planning from California State Polytechnic University Pomona. Carolyn A. Chu, Finance Director. Carolyn A. Chu has worked in the public sector for 29 years serving as Finance Manager, Assistant Finance Director and Finance Director in three different cities. Prior to that, Ms. Chu worked for a local CPA firm auditing municipal governments and obtained her CPA license during that time. Ms. Chu has been with the City of Rosemead for 9 years where she has prepared the annual budgets and annual financial reports. Ms. Chu obtained her Bachelor's degree in Business Administration from California State Polytechnic University, Pomona. Brad McKinney, Assistant City Manager. Brad McKinney has held several public sector positions, including Assistant City Manager, Assistant to the City Manager, Senior Management Analyst, and Administrative Analyst while in three jurisdictions. During his career, Mr. McKinney has managed various areas of multiple departments, which include, budgets, compliance issues, human resources, risk management, and economic development. Prior to his career in the public sector, Mr. McKinney worked for municipal consultant firms. Mr. McKinney received his Master and Bachelor of Arts Degrees in Business Administration from Azusa Pacific University. Pursuant to Resolution No. 2012 -04 (the "Establishing Resolution ") adopted by the City Council on January 10, 2012, and Sections 341710) and 34173 of the Dissolution Act, the City Council appointed itself as successor to the Former Agency. On June 27, 2012, the Redevelopment Law was amended by AB 1484, which clarified that successor agencies are separate political entities and that the successor agency succeeds to the organizational status of the former redevelopment agency but without any legal authority to participate in redevelopment activities except to complete the work related to an approved enforceable obligation. As discussed below, many actions of the Successor Agency are subject to approval by an "oversight board" and the review or approval by the DOF, including the issuance of bonds such as the 2016 Bonds. Oversight Board The Oversight Board was formed pursuant to Establishing Resolution adopted by the City Council on January _, 2012. The Oversight Board is governed by a seven - member governing board, with one member appointed by each of the City, the County, the County Fire Protection District, and the County of Los Angeles Superintendent of Schools, and one public appointee representative of the County and one City employee representative. 17 OHSUSA:765600743.3 Department of Finance Finding of Completion The Dissolution Act established a process for determining the liquid assets that redevelopment agencies should have shifted to their successor agencies when they were dissolved, and the amount that should be available for remittance by the successor agencies to their respective county auditor - controllers for distribution to affected taxing entities within the project areas of the former redevelopment agencies. This determination process was required to be completed through the final step (review by the DOF) by November 9, 2012 with respect to affordable housing funds and by April 1, 2013 with respect to non- housing funds. Within five business days of receiving notification from the DOE, a successor agency must remit to the county auditor - controller the amount of unobligated balances determined by the DOE, or it may request a meet and confer with the DOF to resolve any disputes. [In Fiscal Year 2012 -13, the City received its Finding of Completion from the DOE, which was the final step needed to utilize approximately $7 million in tax increment bond proceeds from the Former Agency. In Fiscal Year 2014 -15, the City has included capital improvement project funding from these bond proceeds in order to complete several projects that were either started in the prior year or have been on hold for more than two years. These projects included the Rosemead Community Recreation Center Expansion and Downtown Plaza as well as the Rosemead Park Improvements. These projects were completed by the end of Fiscal Year 2015 -16.1 The Successor Agency has paid to the County Auditor - Controller all unobligated balances relating to affording housing funds, as determined by the DOE. [Pursuant to Health and Safety Code Section 34176 (a)(2), the City submitted a Housing Assets Transfer Form to the DOE on July 23, 2012 for the period February 1, 2012 through July 23, 2012 which reported no housing assets.] The Successor Agency has remitted to the County Auditor - Controller all unobligated balances relating to all other funds determined by the DOE. The Successor Agency has made all payments required under AB 1484 and has received its finding of completion from the DOF on April 18, 2013. On September 18, 2015, the DOF approved the Successor Agency's Long -Range Property Management Plan which was submitted on September 29, 2014 and revised and submitted on September 16, 2015. State Controller Asset Transfer Review The Dissolution Act requires that any asset of a former redevelopment agency transferred to a city, county or other local agency after January 1, 2011, be sent back to the successor agency. The State Controller reviewed and approved all transfers. THE PROJECT AREA General The Merged Project Area evolved from an intent to achieve efficiencies and ease of administration in the operation of the Successor Agency's two redevelopment areas. In 2009, a study determined the basis for merger of the Former Agency's two redevelopment areas in accordance with the California Community Redevelopment Law. The Redevelopment Plan for the Rosemead Merged Project Area (the "Project Area ") was adopted by Ordinance No. 871 of the City Council adopted on March 10, 2009. Redevelopment Project Area No. 1 evolved from a City Council study commenced in 1967. The study determined areas in the City which were blighted within the meaning of the California Community Redevelopment Law, and were therefore qualified for redevelopment. The Redevelopment Plan for the 18 OHSUSA:765600743.3 Redevelopment Project Area No. 1 was adopted by Ordinance No. 340 of the City Council on June 27, 1972. Redevelopment Project Area No. 2 evolved from a City Council study commenced in 1999. The study determined areas in the City which were blighted within the meaning of the California Community Redevelopment Law, and were therefore qualified for redevelopment. The Redevelopment Plan for the Redevelopment Project Area No. 2 was adopted by Ordinance No. 809, adopted by the City Council of the City on June 27, 2000. Merged Project Area Description By Ordinance No. 871 adopted by the City Council on February 10, 2009, the City Council adopted a merger amendment, merging the Redevelopment Plans for Component Area No. 1 and Component Area No. 2, creating the Merged Project Area. The Merged Project Area encompasses an area of 716 acres. Component Area No. 1 encompasses an area of 511 acres. Component Area No. 1 is roughly triangular with Garvey Avenue, San Gabriel Boulevard and Walnut Grove Avenue being the major thoroughfares traversing the area. Component Area No. 1 is within a few miles of the City's Civic Center and is located between the San Bernardino and Pomona Freeways to the north and south, respectively. The area contains a complete cross section of the City's existing land uses. At the time of the adoption of the Redevelopment Plan, major sections were composed of deteriorating commercial strips along Garvey Avenue and San Gabriel Boulevard, industrial uses in the east Garvey area, large vacant areas surrounding the Southern California Edison headquarters, several schoolyards, segments of the Alhambra Wash, Southern California Edison rights -of -way, and residential areas with some deterioration present. The territory within Project Area No. 2 Component includes about 205 acres and encompasses Valley Boulevard from the eastern and western boundaries of the City and Rosemead Boulevard from the southern and northern boundaries of the City. OHSUSA:765600743.3 19 Property Value by Land Use Table 1 sets forth the distribution of property value located in the Project Area by principal purpose for which the land is used. Table 1 Successor Agency to the Rosemead Community Development Commission Rosemead Merged Project Area Land Use Summary Fiscal Year 2016 -17 Land Use Number of Secured Assessed Percent of Parcels Valuation Secured AV Commercial Single Family Residential Multi- Family Residential Vacant Industrial Vacant Commercial Recreational GovernmentaUInstitutional /Other Vacant Residential Vacant Governmental/Institutional/Other Total All Secured 331 $483,200,505 57.96% 616 168,673,916 20.23 191 67,545,804 8.10 22 8,793,569 1.05 26 6,783,471 0.81 3 5,357,479 0.64 84 5,203,650 0.62 16 1,164,221 0.14 4 318,667 0.04 1,373 $833,689,284 100.00% to Based on fiscal year 2016 -17 secured assessed valuation of $833,689.284. Source: Urban Futures, Inc. with information from the Los Angeles County 2016 -17 Secured Property Tax Roll. A map of the Project Area follows. 20 OHSUSA:765600743.3 Roeemeed C9rdly Development CommWaiao MER GER AMENDMENT TO THE REDEVELOPMENT PLANS FOR THE ROSEIAEAD REDEVELOPMENT PROJECT AREA NOS. 1. AND 2 PRWECT AREA MAP Cw'. ttillN& �ffi 0.1t 6� HYYaae. 21 OHSUSA:765600743.3 Assessed Values Taxable values are prepared and reported by the County Auditor - Controller each fiscal year and represent the aggregation of all locally assessed properties within the Project Area. The assessments are assigned Tax Rate Areas (TRA) that are coterminous to the boundaries of the project area in the first year that an agency is eligible to receive tax increment revenue. The Project Area consists of 17 individual TRAs. See the projections of [Pledged Tax Revenues and Subordinate Tax Revenues] in Exhibit A to the Fiscal Consultant's Report attached hereto as APPENDIX A in Table 4 "ROJECT TAX RATE AREA ID NUMBERS." The following table sets forth assessed values in the Project Area in Fiscal Years 2011 -12 through 2016 -17. Future assessed values and future Gross Tax Revenues will depend upon the rate of growth in tax increment resulting from new development, change of ownership and inflation, assessment appeals and adjustments of assessed values, and changes in tax rates, and may differ from the projections presented herein. Table 2 Successor Agency to the Rosemead Community Development Commission Rosemead Merged Project Area Historical Assessed Valuation (Fiscal Year Ended June 30) Roll 2011 -12 2012 -13 2013 -14 2014 -15 2015 -16 2016 -17 Secured Assessed Value $708,846,863 $715,250,929 $738,211,814 $765,049,559 $804,545,813 $833,689,284 Unsecured Assessed Value 51,765,576 50,312,398 50,921,372 52,778,664 44,071,591 44,749,176 Total Assessed Value $760,612,439 $765,563,327 $789,133,186 $817,828,223 $848,617,404 $878,438,460 Percentage Change -- 0.65% 3.08% 3.64 % 3.76% 3.51% Sources: Los Angeles County Auditor - Controller and Urban Futures, Inc. Ten Largest Assessees Table 3 sets forth the ten largest assessees in the Project Area whose property in the aggregate comprises approximately 23.70% of the total taxable value in the Project Area. The following is restricted to only locally assessed tax- payers, and does not include state assessed properties. Southern California Edison, which owns a significant amount of property within the Project Area, is a public utility and therefore its properties are state assessed and is, accordingly, not included in the following table of top ten property owners. See "Unitary Property" above for a description of unitary revenues. 22 OHSUSA:765600743.3 Table 3 Successor Agency to the Rosemead Community Development Commission Rosemead Merged Project Area Largest Local Secured Taxpayers/Property Owners Fiscal Year 2016 -17 (i) Based on Fiscal Year 2016 -17 secured assessed valuation of $833,689,284. (2) Assessment appeals are pending for this property owner. See "Assessment Appeals" below. Source: Urban Futures, Inc. with information from the Los Angeles County 2016 -17 Secured Property Tax Roll. Among these ten largest secured tax payers for Fiscal Year 2016 -17, Rosemead Place LLC ownership consist of the Target Superstore, Rosemead Place shopping center and two -story office complex, which includes 596,000 square feet of retail, restaurant and office space within the 25.7 acre property, located in the Component Area No. 2. The Wal -Mart Real Estate Business ownership consist of Wal -Mart Supercenter, which includes 227,700 square feet of retail within a 20.8 acre property and the Rosemead Hwang LLC ownership consists of the Diamond Square shopping center, which includes 325,800 square feet of retail, restaurant, and grocery store within a 7.3 acre property, each located in Component Area No. 1. There is some variety in use among the ten largest assesses. The top four are all commercial/retail stores or plazas. One of the ten largest assesses has an appeal pending. See "Assessment Appeals" below. Property Tax Collection Procedures and Delinquencies [The overall delinquency rate for the last full fiscal year (2015 -16) for all secured properties in the Project Area was % as of August _, 2016.] For assessment and collection purposes, property is classified either as "secured" or "unsecured" and is listed accordingly on separate parts of the assessment roll. The "secured roll" is that part of the assessment roll containing state - assessed public utilities property and property the taxes on which are a lien on real property sufficient, in the opinion of the County Assessor, to secure payment of the taxes. Other property is assessed on the "unsecured roll." A tax levied on unsecured property does not become a lien against the unsecured property but may become a lien on certain other property owned by the taxpayer. Every tax which becomes a lien on secured property has a priority over all other liens arising pursuant to California law on the secured property, regardless of the time of creation of the other liens. 23 OHSUSA:765600743.3 Taxable Secured Percent of Percent of Assessed Primary Secured Incremental Property Owner Valuation Land Use AV AV (2) 1. Rosemead Place LLC $ 48,976,049 Commercial 5.87% 6.89% 2. Wal Mart Real Estate Business 35,607,894 Commercial 4.27 5.01 3. Rosemead Hwang, LLC 35,030,575 Commercial 4.20 4.93 4. 420 Boyd Street LLC(2) 18,398,441 Commercial 2.21 2.59 5. Shurl & Kay Curci Foundation 14,596,008 Commercial 1.75 2.05 6. Taiking LLC 10,433,554 Commercial 1.25 1.47 7. Bokai Investment Group LP 9,874,760 Commercial 1.18 1.39 8. Citadel Panda Express Inc. 9,862,505 Commercial 1.18 1.39 9. Su Joseph & Eva W 7,572,151 Commercial 0.91 1.07 10. BMC Rosemead LLC 7,200,000 Industrial 0.86 1.01 Total $197,551,937 23.70% 27.80% (i) Based on Fiscal Year 2016 -17 secured assessed valuation of $833,689,284. (2) Assessment appeals are pending for this property owner. See "Assessment Appeals" below. Source: Urban Futures, Inc. with information from the Los Angeles County 2016 -17 Secured Property Tax Roll. Among these ten largest secured tax payers for Fiscal Year 2016 -17, Rosemead Place LLC ownership consist of the Target Superstore, Rosemead Place shopping center and two -story office complex, which includes 596,000 square feet of retail, restaurant and office space within the 25.7 acre property, located in the Component Area No. 2. The Wal -Mart Real Estate Business ownership consist of Wal -Mart Supercenter, which includes 227,700 square feet of retail within a 20.8 acre property and the Rosemead Hwang LLC ownership consists of the Diamond Square shopping center, which includes 325,800 square feet of retail, restaurant, and grocery store within a 7.3 acre property, each located in Component Area No. 1. There is some variety in use among the ten largest assesses. The top four are all commercial/retail stores or plazas. One of the ten largest assesses has an appeal pending. See "Assessment Appeals" below. Property Tax Collection Procedures and Delinquencies [The overall delinquency rate for the last full fiscal year (2015 -16) for all secured properties in the Project Area was % as of August _, 2016.] For assessment and collection purposes, property is classified either as "secured" or "unsecured" and is listed accordingly on separate parts of the assessment roll. The "secured roll" is that part of the assessment roll containing state - assessed public utilities property and property the taxes on which are a lien on real property sufficient, in the opinion of the County Assessor, to secure payment of the taxes. Other property is assessed on the "unsecured roll." A tax levied on unsecured property does not become a lien against the unsecured property but may become a lien on certain other property owned by the taxpayer. Every tax which becomes a lien on secured property has a priority over all other liens arising pursuant to California law on the secured property, regardless of the time of creation of the other liens. 23 OHSUSA:765600743.3 Property taxes on the secured roll are due in two installments, on July 1 and February 1 of each Fiscal Year. If unpaid, such taxes become delinquent on December 10 and April 10, respectively, and a 10% penalty attaches to any delinquent payment. In addition, property on the secured roll with respect to which taxes are delinquent is sold to the State on or about June 30 of the Fiscal Year. Such property may thereafter be redeemed by payment of the delinquent taxes and delinquent penalty, plus a redemption penalty of 1 1/2% per month to the time of redemption. If taxes are unpaid for a period of five years or more, the property is deeded to the State and then is subject to sale by the County Tax Collector. Current law provides for the supplemental assessment and taxation of property as of the occurrence of a change of ownership or completion of new construction. Property taxes on the unsecured roll are due as of the January 1 lien date and become delinquent, if unpaid, on the following August 31. A 10% penalty attaches to delinquent taxes on property on the unsecured roll, and an additional penalty of 1 -1/2% per month begins to accrue on the first day of the third month following the delinquency date. The taxing authority has four ways of collecting unsecured personal property taxes: (1) a civil action against the taxpayer; (2) filing a certificate in the office of the County Clerk specifying certain facts in order to obtain a judgment lien on certain property of the taxpayer; (3) filing a certificate of delinquency for recording in the County Recorder's office, in order to obtain a lien on certain property of the taxpayer; and (4) seizure and sale of personal property, improvements or possessory interests belonging or assessed to the assessee. As described in more detail under the headings below, the Controller deposits property tax revenues attributable to the Project Area into the RPTTF twice each year, once on January 2 and again on June 1. The Successor Agency's annual debt service and contractual obligations are identified on a Recognized Obligation Payment Schedule that is approved by the Successor Agency's Oversight Board and by the DOE The Successor Agency prepares a single Recognized Obligation Payment Schedule each year, covering payments due in the January to June period (referred to as ROPS "B ") and in the July to December period (referred to as ROPS "A "). In order to have sufficient funds in a subsequent period, the Successor Agency may identify on its Recognized Obligation Payment Schedule an amount necessary to be retained in the RPTTF to be applied to obligations shown on a subsequent Recognized Obligation Payment Schedule. Any amount remaining in the RPTTF after payment of administrative costs, pass - through payments and Recognized Obligation Payment Schedule obligations is immediately distributed to other taxing entities. Low and Moderate Income Housing Set -Aside Prior to the Dissolution Act, the Redevelopment Law required generally that redevelopment agencies set aside in a low and moderate income housing fund not less than 20% of all tax revenues allocated to such agencies. This 20% set -aside requirement was eliminated by the Dissolution Act. There are currently no obligations outstanding which will have a prior lien on the low and moderate housing fund. Accordingly, the former set aside requirement is included in Tax Revenues and, subject to the prior claim, also in Subordinate Tax Revenues pledged to the payment of debt service on the Bonds, including the 2016 Bonds. The City's Rosemead Housing Development Corporation ( "RHDC "), and RHDC Fund receives its funding from tenant rents and subsidies from the Successor Agency from [Subordinate Tax Revenues], on a basis subordinate to the 2016 Bonds, as an enforceable obligation of the Successor Agency. Revenues and expenditures in this fund will typically balance out at the end of each fiscal year. OHSUSA:765600743.3 24 Redevelopment Property Tax Trust Pund The Dissolution Act authorizes bonds, including the 2016 Bonds, to be secured by a pledge of moneys deposited from time to time in a RPTTF held by a county auditor - controller with respect to a successor agency, which are equivalent to the tax increment revenues that were formerly allocated under the Redevelopment Law to the redevelopment agency and formerly authorized under the Redevelopment Law to be used for the financing of redevelopment projects, less amounts deducted pursuant to Section 34183(a) of the Dissolution Act for permitted administrative costs of the county auditor - controller. Successor agencies have no power to levy property taxes and must look specifically to the allocation of taxes as described below. Allocation of Taxes Subsequent to the Dissolution Act The Dissolution Act requires the County Auditor - Controller to determine the amount of property taxes that would have been allocated to the Former Agency (pursuant to subdivision (b) of Section 16 of Article XVI of the State Constitution) had the Former Agency not been dissolved pursuant to the operation of AB 26, using current assessed values on the last equalized roll on August 20, and to deposit that amount in the RPTTF for the Successor Agency established and held by the County Auditor - Controller pursuant to the Dissolution Act. The Dissolution Act provides that any bonds authorized thereunder to be issued by the Successor Agency will be considered indebtedness incurred by the dissolved Former Agency, with the same legal effect as if the bonds had been issued prior to the effective date of AB 26, in full conformity with the applicable provision of the Redevelopment Law that existed prior to that date so that property tax revenues (formerly tax increment revenues) are paid to the Successor Agency in such amounts and on such dates to ensure the timely payment of debt service on the Senior Bonds, the 2016 Bonds and any such Parity Debt. Pursuant to the Dissolution Act, the Successor Agency has covenanted to take all actions necessary to ensure that the 2016 Bonds will be included in the Successor Agency's Recognized Obligation Payment Schedules (as defined herein) as prepared from time to time under the Dissolution Act. See "Recognized Obligation Payment Schedule" below. Taxes levied on the property within the Project Area on that portion of the taxable valuation over and above the taxable valuation of the applicable base year property tax roll within the Project Area, to the extent they constitute Tax Revenues, less administrative costs, as described herein, will be deposited in the RPTTF for transfer by the County Auditor - Controller to the Successor Agency's Redevelopment Obligation Retirement Fund established pursuant to the Dissolution Act on January 2 and June 1 of each year to the extent required for payments listed in the Successor Agency's Recognized Obligation Payment Schedule in accordance with the requirements of the Dissolution Act. See "Recognized Obligation Payment Schedule" below. Recognized Obligation Payment Schedule The Dissolution Act provides for the completion, approval and submission of an annual Recognized Obligation Payment Schedule (the "Recognized Obligation Payment Schedule ") pursuant to which enforceable obligations (as defined in the Dissolution Act) of the successor agency are listed, together with the source of funds to be used to pay for each enforceable obligation. The timing for the preparation and approval of a Recognized Obligation Payment Schedule, among other procedures, was changed with the amendments to the Dissolution Act under SB 107. On or before each February 1, commencing February 1, 2016, with respect to each fiscal year, the Dissolution Act requires successor agencies to prepare and approve, and submit to the successor agency's oversight board and the DOF for approval, a Recognized Obligation Payment Schedule pursuant to which enforceable obligations (as such term is defined in the Dissolution Act) of the successor agency are listed, together with the source of funds to be used to pay for each enforceable obligation. As defined in the Dissolution Act, "enforceable 25 OHSUSA:765600743.3 obligation" includes bonds, including the required debt service, reserve set - asides and any other payments required under the indenture or similar documents governing the issuance of the outstanding bonds of the former redevelopment agency, as well as other obligations such as loans, judgments or settlements against the former redevelopment agency, any legally binding and enforceable agreement that is not otherwise void as violating the debt limit or public policy, contracts necessary for the administration or operation of the successor agency, and amounts borrowed from the low and moderate housing fund. The Dissolution Act permits a successor agency to request additional amounts on a Recognized Obligation Payment Schedule to fund a reserve when required by a bond indenture or when the next property tax allocation will be insufficient to pay all enforceable obligations due under the provisions of the bonds for the next payment due in the following half of the calendar year. Under the Dissolution Act, the categories of sources of payments for enforceable obligations listed on a Recognized Obligation Payment Schedule are the following: (i) the low and moderate housing fund; (ii) bond proceeds; (iii) reserve balances; (iv) administrative cost allowance; (v) the RPTTF (but only to the extent that no other funding source is available or when payment from property tax revenues is required by an enforceable obligation or otherwise required under the Dissolution Act); or (vi) other revenue sources (including rents, concessions, asset sale proceeds, interest earnings, and any other revenues derived from the former redevelopment agency, as approved by its oversight board). The Dissolution Act provides that, commencing on the date that the first Recognized Obligation Payment Schedule is valid, only those payments listed in the Recognized Obligation Payment Schedule may be made by the Successor Agency from the funds specified in the Recognized Obligation Payment Schedule. Each annual Recognized Obligation Payment Schedule may be amended once, provided that (i) the Successor Agency submits the amendment to the DOF no later than October 1, (ii) the Oversight Board makes a finding that the amendment is necessary for the payment of approved enforceable obligations during the second half of the Recognized Obligation Payment Schedule period (from January 1 to June 30, inclusive), and (iii) the Successor Agency may only amend the amount requested for payment of approved enforceable obligations. The DOF shall notify the Successor Agency and the County Auditor - Controller as to whether the Successor Agency's requested amendment is approved at least 15 days before the January 2 property tax distribution. The Recognized Obligation Payment Schedule must be submitted by the Successor Agency, after approval by the Oversight Board, to the County Administrative Officer, the County Auditor - Controller, the DOF and the State Controller by February 1 in each year, commencing February 1, 2016. If the Successor Agency does not submit an Oversight Board- approved Recognized Obligation Payment Schedule by such deadline, the City will be subject to a civil penalty equal to $10,000 per day for every day that the schedule is not submitted. Additionally, the Successor Agency's administrative cost allowance will be reduced by 25% for any fiscal year for which the Successor Agency does not submit an Oversight Board- approved Recognized Obligation Payment Schedule within 10 days of the February 1 deadline. If the Successor Agency fails to submit a Recognized Obligation Payment Schedule by the February 1 deadline, any creditor of the successor agency or the department or any affected taxing entity shall have standing to, and may request a writ of mandate to, require the Successor Agency to immediately perform this duty. For additional information regarding procedures under the Dissolution Act relating to late Recognized Obligation Payment Schedules and implications thereof on the 2016 Bonds, see the caption "RISK FACTORS — Recognized Obligation Payment Schedule." With respect to each Recognized Obligation Payment Schedule submitted by the Successor Agency, the Dissolution Act requires the DOF to make a determination of the enforceable obligations and the amounts and funding sources available to pay approved enforceable obligations no later than April 15. Within five business days of the determination by the DOF, the Successor Agency may request additional review by the DOF and an opportunity to meet and confer on disputed items, if any. The DOF will notify 26 OHSUSA:765600743.3 the Successor Agency and the County Auditor - Controller as to the outcome of its review at least 15 days before the February 1 property tax distribution date preceding the applicable Recognized Obligation Payment Schedule period. Additionally, the County Auditor - Controller may review a submitted Recognized Obligation Payment Schedule and object to the inclusion of any items that are not demonstrated to be enforceable obligations and may object to the funding source proposed for any items, provided that the County Auditor - Controller must provide notice of any such objections to the Successor Agency, the Oversight Board and the DOF at least 60 days prior to the next February 1 property tax distribution date. The Successor Agency has submitted each Recognized Obligation Payment Schedule to the DOF on or before the applicable statutory deadline. See the caption "— Last and Final Recognized Obligation Payment Schedule" below for a description of the Last and Final Recognized Obligation Payment Schedule authorized by the Dissolution Act pursuant to SB 107. In connection with the allocation and distribution by the County Auditor - Controller of property tax revenues deposited in the RPTTF, under the Dissolution Act the County Auditor - Controller must prepare estimates of the amounts of: (i) property tax to be allocated and distributed; and (ii) the amounts of pass - through payments to be made for the upcoming fiscal year, and provide those estimates to the entities receiving the distributions and DOF by no later than October 1 and April 1 of each year, as applicable. If, after receiving such estimate from the County Auditor - Controller, the Successor Agency determines and reports, no later than December 1 or May 1, as applicable, that the total amount available to the Successor Agency from the RPTTF allocation to the Successor Agency's Redevelopment Obligation Retirement Fund, from other funds transferred from the Former Agency and from funds that have or will become available through asset sales and all redevelopment operations, is insufficient to fund the payment of pass- through obligations, Successor Agency enforceable obligations listed on the Recognized Obligation Payment Schedule and the Successor Agency's administrative cost allowance, the County Auditor- Controller must notify the State Controller and the DOF by no later than 10 days from the date of the Successor Agency's notification. If the State Controller concurs that there are insufficient funds to pay required debt service, and if the Successor Agency's tax sharing obligations described in Section 38183(a)(1) of the Dissolution Act have been subordinated to the Successor Agency's enforceable obligations, then the Dissolution Act provides for certain adjustments to be made to the estimated distributions, as described in more detail under the caption "— Tax Increment Financing Generally" above. The Dissolution Act provides that any bonds authorized to be issued by the Successor Agency will be considered indebtedness incurred by the dissolved Former Agency, with the same legal effect as if such bonds had been issued prior to the effective date of AB Xl 26, in full conformity with the applicable provision of the Redevelopment Law that existed prior to such date, will be included in the Successor Agency's Recognized Obligation Payment Schedule and will be secured by a pledge of, and lien on, and will be repaid from moneys deposited from time to time in the RPTTF established pursuant to the Dissolution Act. Additionally, if an enforceable obligation provides for an irrevocable commitment of property tax revenue and where allocation of revenues is expected to occur over time, the Dissolution Act provides that a successor agency may petition the DOF to provide written confirmation that its determination of such enforceable obligation as approved in a Recognized Obligation Payment Schedule is final and conclusive, and reflects the DOF's approval of subsequent payments made pursuant to the enforceable obligation. If the confirmation is granted by the DOF, then the DOF's review of such payments in each future Recognized Obligation Payment Schedule will be limited to confirming that they are required by the prior enforceable obligation. OHSUSA:765600743.3 27 Pursuant to the Dissolution Act, the Successor Agency has covenanted to take all actions necessary to ensure that the 2016 Bonds will be included in the Successor Agency's Recognized Obligation Payment Schedules as prepared from time to time under the Dissolution Act. [The Successor Agency has no power to levy and collect property taxes, and any property tax limitation, legislative measure, voter initiative or provisions of additional sources of income to taxing agencies having the effect of reducing the property tax rate could reduce the amount of Tax Increment Revenues and, accordingly, Subordinate Tax Revenues that would otherwise be available to pay the principal of, and interest on, the 2016 Bonds. Likewise, broadened property tax exemptions could have a similar effect. See "RISK FACTORS" and "LIMITATIONS ON TAX REVENUES." The Successor Agency cannot guarantee that this process prescribed by the Dissolution Act of administering the Tax Increment Revenues and the statutory tax sharing amounts will effectively result in adequate Subordinate Tax Revenues for the payment of principal and interest on the 2016 Bonds when due. See "— Recognized Obligation Payment Schedule." See also "ESTIMATED REVENUES AND BOND RETIREMENT" for additional information regarding the Statutory Pass - Through Amounts applicable to the Successor Agency and the revenues derived from the Project Area. The Successor Agency has no power to levy and collect taxes, and various factors beyond its control could affect the amount of Subordinate Tax Revenues available in any six -month period to pay the principal of and interest on the 2016 Bonds. See "RISK FACTORS." The 2016 Bonds are not a debt of the City, the County, the State or any of its political subdivisions (except the Successor Agency), and none of the City, the County, the State or any of its political subdivisions (except the Successor Agency) is liable therefor. The 2016 Bonds do not constitute indebtedness within the meaning of any constitutional or statutory debt limitation or restriction.) Assessment Appeals Property owners can appeal the assessment of their property to the county assessment appeals board. See "RISK FACTORS — Assessment Appeals" and APPENDIX A — "FISCAL CONSULTANT REPORT." The Fiscal Consultant conducted a review of pending and recently resolved assessment appeals in order to determine potential impact on current and future Project Area value and tax increment revenue. The results of this review are described in the Fiscal Consultant's Report attached as APPENDIX A, portions of which are summarized below. There are two basic types of assessment appeals provided for under California law. The first type of appeal, commonly referred to as a base year assessment appeal, involves a dispute on the valuation assigned by the county assessor immediately subsequent to a change in ownership or completion of new construction. If the base year value assigned by the county assessor is reduced, the valuation of the property cannot increase in subsequent years more than two percent annually unless and until another change in ownership and/or additional new construction activity occurs. The most common type of appeal filed is known as a Proposition 8 appeal, in which the property owner seeks a reduction in a particular year's assessment based on the current economic value of the property. The county assessor may also adjust valuations based on Proposition 8 criteria. Reductions in valuation made under Proposition 8 are temporary, with valuations restored to their full assessments once the economic reason for the reduction no longer applies. Such reductions can affect the Successor Agency's tax increment while they are in effect. The Los Angeles County Assessor (the "Assessor ") annually reports on the number of assessments by city subject to Proposition 8 reductions, and the amount of Proposition 8 reductions. For 28 OHSUSA:765600743,3 Fiscal Year 2015 -16, the Assessor reports properties reduced through Proposition 8 in the City of Rosemead and $ in reduced valuation. This compares to properties and $ in Proposition 8 reductions in Fiscal Year 2015 -16, _ properties and $ in Proposition 8 reductions in Fiscal Year 2014 -15, and, properties and $ in Proposition 8 reductions in Fiscal Year 2013 -14. In Los Angeles County, a property owner desiring to reduce the assessed value of such owner's property in any one year must submit an application to the Los Angeles County Assessment Appeals Board (the "Appeals Board "). Applications for any tax year must be submitted by September 15 of such tax year. The Appeals Board, within two years of each applicant's filing date, will hold a hearing and then either reduce the assessment or confirm the assessment. As reported in the Fiscal Consultant's Report, total assessment appeals pending in the Project Area represent real property with a total assessed valuation of $116,132,448. Based on the applicants' opinion of value, the total requested reduction in assessed valuation is $46,710,723. Based on the actual valuation reductions allowed by the Appeals Board for property in the Project Area over the last five years, the amount of the allowed reductions by the Appeals Board represented approximately 10.79% of the total assessed valuation of the properties that were the subject of the appeals. If the historical reduction percentage of 10.79% is applied to the total assessed valuation of the currently outstanding appeals, it is estimated that the resolution of the current appeals pending could result in a reduction to [Tax Revenues] in Fiscal Year 2016 -17 of $36,152. This amount has not been deducted from the [Pledged Tax Revenues and Subordinate Tax Revenues] shown in Exhibit A, as the outcome of pending appeals cannot be predicted with certainty. [With respect to the Project Area, a review of the Project Area property tax rolls for Fiscal Year 2016 -7 indicates that a substantial number of residential parcels that appear to have previously been subject to Proposition 8 reductions have had their valuations increased, while some vacant properties have had their valuations reduced through what appear to be Proposition 8 reductions (the Assessor does not indicate on the rolls which parcels are subject to Proposition 8). These reductions and restorations are discussed further below and in the Fiscal Consultant's Report attached hereto as APPENDIX A.] With respect to direct property owner appeals, the County experienced a high level of assessment appeals in the late 1990's and again in 2007 and 2008. Within the Project Area, the primary cause of such appeals was declining market value of improved and unimproved residential property. Further significant appeals to assessed values in the Project Area may be filed from time to time in the future. The Successor Agency cannot predict the extent of any such appeals or their likelihood of success. The County has two years from the date of filing to rule on appeal requests. If the County reduces the assessed value of any parcel, there can be no assurance that the reduction will be by the amount estimated by the Fiscal Consultant. Also, additional appeals on property within the Project Area may be filed in the future. The Successor Agency cannot predict the extent of any such appeals or their likelihood of success. The following table illustrates the pending and resolved assessment appeals in the Project Area, and a projection of the estimated impact of pending appeals on assessed value. OHSUSA:765600743.3 29 Table 4 Successor Agency to the Rosemead Community Development Commission Rosemead Merged Project Area Historical Assessment Appeals Reviewed January 1, 2011 through June 13, 2016 Number of Appeals Filed 99 Roll Year Appealed 2011 2012 2013 2014 2015 Number Allowed of Assessed Owner's Reduction Reductions Successful Value of Opinion of Total Requested Allowed by as % of Appeals Property Value AV Reduction Board Requested 28 $231,511,488 $130,828,536 $100,682,952 $10,867,295 10.79% Outstanding Assessment Appeals as of June 13, 2016 Estimated Number Reduction of Assessed Owner's Potential Loss (based on Appeals Value of Opinion of of Assessed Historical historical Filed Property Value Value Success Rate success) 1 $ 1,469,091 $ 730,000 $ 739,091 10.79% 79,774 1 1,418,822 700,000 718,822 10.79 77,587 11 23,913,510 15,910,086 8,003,424 10.79 863,856 16 39,857,217 22,790,310 17,066,907 10.79 1,842,130 19 49,473,808 29,291,329 20,182,479 10.79 2,178,412 Source: Urban Futures, Inc. with data obtained from Los Angeles County. [A number of the appeals in the Project Area that were allowed resulted in a reduction in value were based on Section 51 of the Revenue and Taxation Code. This section requires that for each lien date the value of real property shall be the lesser of its base year value annually adjusted by the inflation factor pursuant to Article XIIIA of the State Constitution or its full cash value, taking into account reductions in value due to damage, destruction, depreciation, obsolescence, removal of property or other factors causing a decline in value. Significant reductions took place in some counties during the mid- 1990's due to declining real estate values. Reductions made under this code section may be initiated by the Assessor or requested by the property owner. After a roll reduction is granted under this section, the property is reviewed on an annual basis to determine its full cash value and the valuation is adjusted accordingly, which may result in either further reductions in or increases in assessed value. Such increases shall be in accordance with the actual full cash value of the property and may exceed the maximum annual inflationary growth rate allowed on other properties under Article XIIIA of the State Constitution. Once the property has regained its prior value, adjusted for inflation it once again is subject to the annual inflationary factor growth rate allowed under Article XIIIA. Under Section 51 of the Revenue and Taxation Code the annual increase in assessed valuation for real property is limited to the lesser of two percent or the October -to- October change in the California Consumer Price Index (CCPI) preceding the January 1 lien date. The State Board of Equalization reports the figure annually in late December. Since 197677 the CCPI has been above two percent in all but seven years, with the lowest CCPIs being a negative 0.237 percent for Fiscal Year 2010 -11 and a positive 0.753% for Fiscal Year 2011 -12. The factor applied to the Fiscal Year 2012 -13 and Fiscal Year 2013 -14 rolls was 2.00 %. The factor for the Fiscal Year 2014 -15 rolls was 0.454% and the factor for the Fiscal Year 2015 -16 roll was 1.998 %. The factor for Fiscal Year 2016 -17 is [1.525] %. This factor, referred to at times in this Analysis as the Proposition 13 inflation factor, is applied to land and improvements where 30 OHSUSA:765600743.3 the property has not been sold or, in the case of improvements, newly constructed. Properties whose valuations have been reduced under Proposition 8 continue to receive an inflationary adjustment under Proposition 13 on the reduced valuation.] The Successor Agency cannot predict whether any future appeals will be successful, or whether the number of appeals may increase in the Project Area. Future reductions in taxable values in the Project Area resulting from successful appeals by property owners will reduce the amount of Subordinate Tax Revenues available to pay the principal of and interest on the 2016 Bonds. Property Tax Administrative Costs In 1990, SB 2557, and in 1992, SB 1559, authorized county auditors to determine property tax administrative costs proportionately attributable to local jurisdictions and to charge agencies for such costs. The Los Angeles County Auditor - Controller deducts administration charges and collection fees from the tax increment distributed to the Successor Agency's RPTTF for the Project Area. In fiscal year 2015 -16, the County administration charges and collection fees totaled $137,352. The Fiscal Consultant has estimated such fees and charges to be 1.64% of Gross Tax Revenues, which is consistent with historical amounts. The Fiscal Consultant and the Successor Agency have assumed that the County fees and charges will continue to be collected by the Auditor Controller and will increase or decrease proportionally with the changes in revenues. County fees and charges have been deducted from the projected [Pledged Tax Revenues and Subordinate Tax Revenues]. See the Fiscal Consultant's Report attached hereto as APPENDIX A. Plan Limitations Under the provisions of Redevelopment Law prior to the Dissolution Act, certain time and revenue limitations were imposed upon the redevelopment plan for the Project Area. SB 107, which became effective September 22, 2015, amended the Dissolution Act to provide that the time limits for receiving property tax revenues and the limitation on the amount of property tax revenues that may be received by the Former Agency and the Successor Agency set forth in the Redevelopment Plan are not effective for purposes of paying the Successor Agency's enforceable obligations such as the Senior Bonds, the 2016 Bonds and Parity Debt. Accordingly, the projections set forth in this Official Statement and in the Fiscal Consultant's Report attached to this Official Statement as APPENDIX A were prepared without regard to the time and financial limitations set forth in the Redevelopment Plan. See the projections of [Pledged Tax Revenues and Subordinate Tax Revenues] in Exhibit A to the Fiscal Consultant's Report attached hereto as APPENDIX A in Table 3 "REDEVELOPMENT PLAN LIMITATION DATES AND AMOUNTS." Last and Final Recognized Obligation Payment Schedule SB 107 amended the Dissolution Act to permit a successor agency to submit a Last and Final Recognized Obligation Payment Schedule (a "Last and Final Recognized Obligation Payment Schedule ") for approval by the oversight board and DOF if: (i) The successor agency's only remaining debt is administrative costs and payments pursuant to enforceable obligations with defined payment schedules, (ii) All remaining obligations have been previously listed on a Recognized Obligation Payment Schedule and approved by DOF, and (iii) The successor agency is not a party to outstanding or unresolved litigation. The Last and Final Recognized Obligation Payment Schedule must list the remaining enforceable obligations of the successor agency in the following order: (A) enforceable obligations to be funded from the RPTTF, (B) enforceable obligations to be funded from bond proceeds or other legally or contractually dedicated or restricted funding sources, and (C) loans or deferrals authorized for repayment 31 OHSUSA:765600743.3 to the city that created the redevelopment agency or the successor to the former redevelopment agency's housing functions and assets. The Last and Final Recognized Obligation Payment Schedule must also include the total outstanding obligation and a schedule of remaining payments for each enforceable obligation described in (A) and (B) above, and the total outstanding obligation and an interest rate of 4 %, for any loans or deferrals listed pursuant to (C) above. The Last and Final Recognized Obligation Payment Schedule will also establish the maximum amount of RPTTFs to be distributed to the successor agency for each remaining fiscal year until all obligations have been fully paid. DOF approval is required for any Last and Final Recognized Obligation Payment Schedule to become effective. The county auditor - controller is also required to review the Last and Final Recognized Obligation Payment Schedule and provide any objection to the inclusion of any items or amounts to the DOE Successor agencies may only amend an approved Last and Final Recognized Obligation Payment Schedule twice. Commencing on the effective date of the approved Last and Final Recognized Obligation Payment Schedule, the successor agency will not prepare or transmit annual Recognized Obligation Payment Schedules. After the Last and Final Recognized Obligation Payment Schedule is approved by DOF, the county auditor - controller will continue to allocate moneys in the successor agency's RPTTF pursuant to Section 34183 of the Dissolution Act; however, the county auditor - controller will allocate such moneys in each fiscal period, after deducting the county auditor - controller's administrative costs, in the following order of priority: (A) pass through payments pursuant to Section 34183(a)(1) of the Dissolution Act, (B) scheduled debt service payments on tax allocation bonds listed and approved in the Last and Final Recognized Obligation Payment Schedule, (C) scheduled payments on revenue bonds listed and approved in the Last and Final Recognized Obligation Payment Schedule, but only to the extent the revenues pledged for them are insufficient to make the payments and only if the successor agency's tax increment revenues were also pledged for the repayment of bonds, (D) scheduled payments for debts and obligations listed and approved in the Last and Final Recognized Obligation Payment Schedule to be paid from the RPTTF, (E) payments listed and approved on the Last and Final Recognized Obligation Payment Schedule that were authorized but unfunded in prior periods, (F) repayment of loans and deferrals to the city that created the redevelopment agency or the successor to the former redevelopment agency's housing functions and assets that are listed and approved on the Last and Final Recognized Obligation Payment Schedule, and (G) any moneys remaining in the RPTTF after the payments and transfers described in (A) to (F), above, will be distributed to taxing entities in accordance with Section 34183(a)(4) of the Dissolution Act. If the successor agency reports to the county auditor - controller that the total available amounts in the RPTTF will be insufficient to fund the successor agency's current or future fiscal year obligations, and if the county auditor - controller concurs that there are insufficient funds to pay the required obligations, the county auditor - controller may distribute funds pursuant to Section 34183(b) of the Dissolution Act. See the caption "— Tax Increment Financing Generally" above. [The Successor Agency is not currently eligible to submit a Last and Final Recognized Obligation Payment Schedule and has no current plans to seek approval of a Last and Final Recognized Obligation Payment Schedule.] OHSUSA:765600743.3 32 ESTIMATED REVENUES AND BOND RETIREMENT The Successor Agency has retained Urban Futures, Inc., Orange, California (the "Fiscal Consultant "), to analyze the Project Area and to project future [Pledged Tax Revenues and Subordinate Tax Revenues] shown for the Project Area. The Fiscal Consultant's report is included as APPENDIX A and should be read in its entirety. The Project Area's base year assessed valuation is approximately $170.4 million. The total assessed valuation for Fiscal Year 2016 -17 is approximately $878.4 million, with approximately $833.7 million attributable to secured assessed value and approximately $44.7 million attributable to the unsecured assessed value. The total assessed valuation for Fiscal Year 2009 -10 is approximately $878.4 million which produces a total incremental value of approximately $ million. Gross Tax Revenues consist primarily of tax increment revenues generated from the application of appropriate tax rates to the incremental taxable value of the Project Area. An additional significant source of Gross Tax Revenues includes unitary property taxes. Unitary tax revenues make up a substantial portion of the tax increment revenues received by the Successor Agency. This is primarily because the headquarters of Southern California Edison are located within the Project Area. See "LIMITATIONS ON TAX REVENUES — Unitary Property" herein. Reductions in Tax Revenues received by the Successor Agency may result from declining tax rates, property tax administrative costs and refunds resulting from successful appeals of assessed values. [The Component Area No. 1 base year 1971 -72 assessed valuation is $ The assessed valuation in Component Area No. 1 for Fiscal Year 2016 -17 is $ , which produces a total incremental value of $ . The total Gross Tax Revenues for Fiscal Year 2016 -17 attributed to Component Area No. 1 are estimated to be approximately $ and Subordinate Tax Revenues are estimated to be approximately $ . ] [The Component Area No. 2 base year 1999 -2000 assessed valuation is $ The assessed valuation in Component Area No. 2 for Fiscal Year 2016 -17 is $ , which produces a total incremental value of $ . The total Gross Tax Revenues for Fiscal Year 2016 -17 attributed to Component Area No. 2 are estimated to be approximately $ and Subordinate Tax Revenues are estimated to be approximately $ . ] The Tax Rate calculated by the City is 1.000% for the secured roll and the unsecured roll for the Successor Agency. In accordance with Health and Safety Code Section 33670(e) the Successor Agency Tax Rate excludes taxes related to bonded indebtedness of the City approved by the voters of the City on or after January 1, 1989, and issued for the acquisition or improvement of real property. [Pledged Tax Revenues and Subordinate Tax Revenues] shown in Table 5 below and in Exhibit A of the Fiscal Consultant's Report. Exhibit A in the Fiscal Consultant's Report attached hereto as APPENDIX A sets forth estimated Fiscal Year 2016 -17 [Pledged Tax Revenues and Subordinate Tax Revenues] shown and forecasts growth in [Pledged Tax Revenues and Subordinate Tax Revenues] shown through Fiscal Year 2033 -34, incorporating the Proposition 13 adjustment of [1.525]% for real property on the Fiscal Year 2016 -17 roll and assuming a 2% rate of growth in real property from Fiscal Year 2017- 18 forward. [No inflationary trend is applied to personal property value and the personal property assessed valuation is assumed in each Fiscal Year presented below to remain at the 2016 -17 fiscal year level.] These projections do not reflect changes to assessed valuation due to new construction, property sales, Proposition 8 reductions, assessment appeals or other factors. The actual growth rate may be less than the projected in the Project Area. Debt service is based on the maturity schedule and interest rates, subject to prior redemption or acceleration, for the 2016 Bonds as set forth on the inside cover page 33 OHSUSA:765600743.3 hereof, and the debt service attributable to the Senior Bonds. Table 5 projects annual debt service coverage based on the forecasts of [Pledged Tax Revenues and Subordinate Tax Revenues] shown. Secured personal property, unsecured valuations and estimated unitary revenue in the amount of $1,276,382 for Fiscal Year 2016 -17 are assumed to remain constant throughout. [Consider General Projection Assumptions] 1. The revenue projections are based on the Fiscal Year 16 -17 assessed valuation of the Project Area, with projected 2% annual assessed valuation growth thereafter. 2. The Project Area tax rate is assumed to be 1% in Fiscal Year 2016 -17 and thereafter. 3. Unitary revenues are projected to be $1,276,382 annually, based on historical receipts and held constant at the 2016 -17 level. See "LIMITATIONS ON TAX REVENUES — Unitary Property." 4. Projected Gross Tax Revenues is based upon incremental taxable values factored against an assumed project tax rate. The assumed future tax rates remain at $1.00 per $100 of taxable value as reported by the County Auditor Controller. 5. With respect to pass - throughs, the Fire District receives approximately 17% of gross tax revenues from the Component Area No. 1 pursuant to the Pass - Through Agreement. Statutory pass - throughs to agencies that do not have a current tax sharing agreement receive a combined share of 82.9% of general levy property tax. Payments under the Pass - Through Agreement and Statutory Pass -- through payments are, pursuant to previous action of the Former Agency, subordinate to payments on the Senior Bonds. Such payments are not subordinate to debt service on the 2016 Bonds. 6. Growth in real property land and improvement values have been limited to an assumed rate of growth of real property taxable values of two percent annually as allowed under Article XIIIA of the state Constitution. Should the future growth of taxable value in the project areas be less than two percent, the resultant Gross Tax Revenues would be reduced proportionately. Future values will also be impacted by changes of ownership and new construction not reflected in our projections. In addition, the values of property previously reduced in value due to assessment appeals based on reduced market values could increase more than two percent when real estate values increase more than two percent. The Successor Agency, the City and the Underwriter are unable to make any representation that taxable values will actually grow at the rate projected. 7. Los Angeles County Administration Fee is estimated at 1.5% of Gross Revenue based on the actual 2016 -17 level. 34 OHSUSA:765600743.3 (mi& )§a° ]] \\ �)\ ) } / \ \ § \\ ) )\ � \) :) ±aa; ; ±!} \ \ \)t PQ {) /) fiaa« )j\ \\ 4 Ej b :as +/ ( a 35 ]7)] § \ ( - } \\ \ t�! %§ { {) )2 A&j) a � m t 2\ } ) ƒ/ )) j]() > /A ) } / \ \ § \\ ) )\ � \) :) ±aa; ; ±!} \ \ \)t PQ {) /) fiaa« )j\ \\ 4 Ej b :as +/ ( a 35 RISK FACTORS The following factors, along with all other information in this Official Statement, should be considered by potential investors in evaluating the 2016 Bonds and the credit quality of the 2016 Bonds. The following does not purport to be an exhaustive listing of risks and other considerations which may be relevant to investing in the 2016 Bonds. In addition, the order in which the following information is presented is not intended to reflect the relative importance of any such risks. For a discussion of certain matters that will or could cause reductions in the Tax Revenues available in future years, see "LIMITATIONS ON TAX REVENUES" of this Official Statement. Limited Special Obligations The 2016 Bonds are special obligations payable solely from certain payments from the Successor Agency and certain other funds. Neither the City, the County, the State nor any political subdivision thereof, except the Successor Agency, shall be obligated to pay the principal of the 2016 Bonds, or the interest thereon, except from the funds described above, and neither the faith and the credit nor the taxing power of the County, the State nor any political subdivision thereof is pledged to the payment of the principal of or the interest on the 2016 Bonds. The issuance of the 2016 Bonds shall not directly, indirectly or contingently obligate the City, the County, the State or any political subdivision thereof to levy or pledge any form of taxation whatever therefor or to make any appropriations for their payment. The Successor Agency has no taxing power. Subordinate Lien Risks The 2016 Bonds are payable from tax increment revenues from the Project Area on a basis junior and subordinate to the payment of debt service on the Senior Bonds and the amounts payable under the Pass - Through Agreement as described under the captions "INTRODUCTION - Security for the Bonds — Outstanding Senior Bonds" and "SECURITY FOR THE BONDS — Subordinate Tax Revenues." In the event of default or insufficiency of tax increment revenues from the Project Area that affects payment under the Senior Bonds, the owners of such Senior Bonds will have the right to direct rights and remedies including acceleration of the principal amount of such Senior Bonds, which would adversely affect the availability of Subordinate Tax Revenues to the 2016 Bonds. Recognized Obligation Payment Schedule The Dissolution Act provides that only those payments listed in a Recognized Obligation Payment Schedule may be made by the Successor Agency from the funds specified in the Recognized Obligation Payment Schedule. The Successor Agency prepares a single Recognized Obligation Payment Schedule each year, covering payments due in the January to June period (referred to as ROPS `B ") and in the July to December period (referred to as ROPS "A "). In order to have sufficient funds in a subsequent period, the Successor Agency may identify on its Recognized Obligation Payment Schedule an amount necessary to be retained in the RPTTF to be applied to obligations shown on a subsequent Recognized Obligation Payment Schedule. The Controller deposits funds into the RPTTF twice each year, once on January 2 and again on June 1. Any amount remaining in the RPTTF after payment of administrative costs, pass - through payments and Recognized Obligation Payment Schedule obligations is immediately distributed to other taxing entities. Tax revenues will not be withdrawn from the RPTTF by the County Auditor- Controller and remitted to the Successor Agency without a Recognized Obligation Payment Schedule approved by the DOE See "THE PROJECT AREA - Recognized Obligation Payment Schedule." If the Successor Agency were to fail to complete an approved Recognized Obligation Payment Schedule, the availability of Subordinate Tax Revenues to the Successor Agency could be adversely affected for such period. 36 OHSUSA:765600743.3 Real Estate and General Economic Risks The Successor Agency's ability to make payments on the 2016 Bonds will depend upon the economic strength of the Project Area. The general economy of the Project Area will be subject to all the risks generally associated with real estate and real estate development. Property values and further development in the Project Area, may be adversely affected by changes in general economic conditions, fluctuations in the real estate market and interest rates, unexpected increases in development costs and by other similar factors. Further, real estate development within the Project Area could be adversely affected by future governmental policies, including governmental policies to restrict or control certain kinds of development. If development activities in the Project Area encounter significant obstacles of the kind described herein or other impediments, the economy of the Project Area could be adversely affected, causing reduction of the Subordinate Tax Revenues available to repay the 2016 Bonds. In addition, if there is a decline in the general economy of the region, the City or the Project Area, the owners of property within the Project Area may be less able or less willing to make timely payments of property taxes, causing a delay or stoppage of Tax Revenues received by the Successor Agency from the Project Area. Reduction in Taxable Value Tax Increment Revenues allocated to the Successor Agency are determined by the amount of incremental taxable value in the Project Area allocable to the Project Area and the current rate or rates at which property in the Project Area is taxed. The reduction of taxable values of property caused by economic factors beyond the Successor Agency's control, such as a relocation out of the Project Area by one or more major property owners, or the transfer, pursuant to California Revenue and Taxation Code Section 68, of a lower assessed valuation to property within the Project Area by a person displaced by eminent domain or similar proceedings, appeals to value under Proposition 8 or other assessment appeals, or the discovery of hazardous substances on a property within the Project Area (see "Hazardous Substances," below) or the complete or partial destruction of such property caused by, among other eventualities, an earthquake (see "Risk of Earthquake" below), flood or other natural disaster, could cause a reduction in the Subordinate Tax Revenues securing the 2016 Bonds. Property owners may also appeal to the Assessor for a reduction of their assessed valuations or the Assessor could order a blanket reduction in assessed valuations based on then current economic conditions. See APPENDIX A — "FISCAL CONSULTANT REPORT — Assessment Appeals." To estimate the total tax increment revenues available to pay debt service on the Senior Bonds and the 2016 Bonds, the Successor Agency has made certain assumptions with regard to the availability of tax increment revenues. The Successor Agency believes these assumptions to be reasonable, but to the extent tax increment revenues are less than anticipated, the total tax increment revenues available to pay debt service on the 2016 Bonds may be less than those projected herein. Unless mentioned herein, no independent third party has reviewed the estimates or assumptions made by the Successor Agency. See "ESTIMATED REVENUES AND BOND RETIREMENT" herein. Assessment Appeals Property taxable values may be reduced as a result of Proposition 8, which reduces the assessed value of property, or of a successful appeal of the taxable value determined by the Assessor. An appeal may result in a reduction to the Assessor's original taxable value and a tax refund to the applicant property owner. A reduction in taxable values within the Project Area and the refund of taxes which may arise out of successful appeals by property owners will affect the amount of Subordinate Tax Revenues under the Indenture. The Successor Agency has in the past experienced reductions in its Tax Increment Revenues as a result of assessment appeals. The actual impact to tax increment is dependent upon the 37 OHSUSA:765600743.3 actual revised value of assessments resulting from values determined by the County Assessment Appeals Board or through litigation and the ultimate timing of successful appeals. As discussed in this Official Statement, based on the historical success rate of 10.79% for approved valuation reductions as a percentage of the requested reduction amounts over the past five years, the estimated potential reduction to [Tax Revenues] in Fiscal Year 2016 -17 is $36,152. This amount has not been deducted from the [Pledged Tax Revenues and Subordinate Tax Revenues] shown in Exhibit A to the Fiscal Consultant's Report attached hereto as APPENDIX A or in the projected Subordinate Tax Revenues and estimated debt service coverage in this Official Statement. For a discussion of historical assessment appeals in the Project Area and summary information regarding pending and resolved assessment appeals for the Successor Agency, see "THE PROJECT AREA — Assessment Appeals" and APPENDIX A — FISCAL CONSULTANT REPORT — Assessment Appeals." The Successor Agency cannot predict whether any future appeals will be successful, or whether the number of appeals may increase in the Project Area. Future reductions in taxable values in the Project Area resulting from successful appeals by property owners will reduce the amount of Subordinate Tax Revenues available to pay the principal of and interest on the 2016 Bonds. See "THE PROJECT AREA — Assessed Values" herein. Reduction in Inflationary Rate and Changes in Legislation As described in greater detail below (see "LIMITATIONS ON TAX REVENUES "), Article XIIIA of the California Constitution provides that the full cash value base of real property used in determining taxable value may be adjusted from year to year to reflect the inflationary rate, not to exceed a 2% increase for any given year, or may be reduced to reflect a reduction in the consumer price index or comparable local data. Such measure is computed on a calendar year basis. Article XIIIA limits inflationary assessed value adjustments to the lesser of the actual inflationary rate or 2% and there have been several years in which taxable values were adjusted by an actual inflationary rate that was less than 2 %. The adjusted inflationary rate for Fiscal Year 2015 -16 roll was 1.998 %; the factor for Fiscal Year 2016 -17 is [1.525] %. This factor, referred to at times in this Official Statement [and in the Fiscal Consultant's Report] as the Proposition 13 inflation factor, is applied to land and improvements where the property has not been sold or, in the case of improvements, newly constructed. Properties whose valuations have been reduced under Proposition 8 continue to receive an inflationary adjustment under Proposition 13 on the reduced valuation. The Successor Agency is unable to predict whether future annual inflationary adjustments to the taxable value base of real property within the Project Area will be in the amount of the full 2% permitted under Article XIIIA or will be in an amount less than 2 %. Estimated Revenues In estimating that tax increment revenues from the Project Area will be sufficient to pay debt service on the Senior Bonds and the 2016 Bonds, the Successor Agency has made certain assumptions with regard to present and future assessed valuation in the Project Area, future tax rates and percentage of taxes collected. The Successor Agency believes these assumptions to be reasonable, but there is no assurance these assumptions will be realized and to the extent that the assessed valuation and the tax rates are less than expected, the tax increment revenues from the Project Area available to pay debt service on the 2016 Bonds will be less than those projected and such reduced tax increment revenues from the Project Area may be insufficient to provide for the payment of principal of, premium (if any) and interest on the Senior Bonds, the 2016 Bonds and any Parity Debt. OHSUSA:765600743.3 38 Levy and Collection of Taxes The Successor Agency has no independent power to levy and collect property taxes. Any reduction in the tax rate or the implementation of any constitutional or legislative property tax decrease could reduce the Tax Revenues and, accordingly, could have an adverse impact on the availability of Subordinate Tax Revenues the ability of the Successor Agency to make debt service payments on the 2016 Bonds. Likewise, delinquencies in the payment of property taxes could have an adverse effect on the Successor Agency's ability to make timely debt service payments on the 2016 Bonds. No Teeter Plan Certain counties in the State of California operate under a statutory program entitled Alternative Method of Distribution of Tax Levies and Collections and of Tax Sales Proceeds (the "Teeter Plan "). Under the Teeter Plan, local taxing entities receive 100% of their tax levies, net of delinquencies, but do not receive interest or penalties on delinquent taxes collected by the county. The County of Los Angeles has not adopted the Teeter Plan, and consequently the Teeter Plan is not available to local taxing entities within the County, such as the Successor Agency. The Successor Agency's receipt of property taxes is therefore subject to delinquencies in the Project Area. Concentration of Land Ownership Based upon Fiscal Year 2016 -17 assessed value data, approximately 24% of the total net secured assessed property value in the Project Area is owned by the ten largest taxpayers. In addition, a substantial portion, approximately 10% of Gross Tax Revenues are derived from unitary property taxes. This is primarily because the headquarters of Southern California Edison are located within the Project Area. See "LIMITATIONS ON TAX REVENUES — Unitary Property" herein. Reductions in Tax Revenues received by the Successor Agency may result from declining tax rates, property tax administrative costs and refunds resulting from successful appeals of assessed values. The inability or unwillingness of such taxpayers to pay property taxes on their property in the Project Area might have an adverse effect on the Successor Agency's ability to repay the 2016 Bonds. In addition, as a result of the high concentration of land ownership in the Project Area, decreases in the assessed value of one or more parcels of land may have a significant impact on the Tax Revenues. See "THE PROJECT AREA — Ten Largest Assessees" herein. Acceleration of Senior Bonds The Senior Bonds are subject to acceleration upon an event of default under the Senior Indenture pursuant to which such bonds were issued. See "SECURITY FOR THE BONDS" herein. Bond Insurance Risk Factors The scheduled payment of principal of and interest on the 2016 Bonds when due will be guaranteed under the Policy. The following are risk factors relating to the Policy. In the event of default of the scheduled payment of principal of or interest on the 2016 Bonds when all or some becomes due, the Trustee on behalf of the Owners of the 2016 Bonds shall have a claim under the Policy for such payments. However, in the event of any acceleration of the due date of such principal by reason of mandatory or optional redemption or acceleration resulting from default or otherwise, other than any advancement of maturity pursuant to a mandatory sinking fund payment, the payments are to be made in such amounts and at such times as such payments would have been due had there not been any such acceleration. The Policy does not insure against redemption premium, if any. The 39 OHSUSA:765600743.3 payment of principal and interest in connection with mandatory or optional prepayment of the 2016 Bonds by the Successor Agency from the bond owner as a voidable preference under applicable bankruptcy law is covered by the insurance policy, however, such payments will be made by the Insurer at such time and in such amounts as would have been due absence such prepayment by the Successor Agency unless the Insurer chooses to pay such amounts at an earlier date. A default of payment of principal and interest does not result in an acceleration of the Bonds or the obligations of the Insurer unless consented to by the Insurer. The Insurer may direct and must consent to any remedies and the Insurer's consent may be required in connection with amendments to any applicable bond documents. In the event the Insurer is unable to make payment of principal and interest as such payments become due under the Policy, the 2016 Bonds are payable solely from the moneys received pursuant to the applicable bond documents. In the event the Insurer becomes obligated to make payments with respect to the 2016 Bonds, no assurance is given that such event will not adversely affect the market price of the 2016 Bonds or the marketability (liquidity) for the 2016 Bonds. The insured ratings on the 2016 Bonds are dependent in part on the financial strength of the Insurer and its claim paying ability. The Insurer's financial strength and claims paying ability are predicated upon a number of factors which could change over time. No assurance is given that the ratings of the Insurer and of the ratings on the 2016 Bonds insured by the Insurer will not be subject to downgrade and such event could adversely affect the market price of the 2016 Bonds or the marketability (liquidity) for the 2016 Bonds. See description of "OTHER INFORMATION — Ratings" herein. The obligations of the Insurer are unsecured obligations and in an event of default by the Insurer, the remedies available may be limited by applicable bankruptcy law or state law related to insolvency of insurance companies. Neither the Successor Agency nor the Underwriter have made independent investigation into the claims paying ability of the Insurer and no assurance or representation regarding the financial strength or projected financial strength of the Insurer is given. Thus, when making an investment decision, potential investors should carefully consider the ability of the Successor Agency to pay principal and interest on the 2016 Bonds and the claims paying ability of the Insurer, particularly over the life of the investment. See "BOND INSURANCE" herein for further information provided by the Insurer and the Policy, which includes further instructions for obtaining current financial information concerning the Insurer. Change in Law In addition to the other limitations on Tax Revenues, the California electorate or Legislature could adopt a constitutional or legislative property tax decrease with the effect of reducing Tax Revenues payable to the Successor Agency. There is no assurance that the California electorate or Legislature will not at some future time approve additional limitations that could reduce the Subordinate Tax Revenues and adversely affect the security of the 2016 Bonds. Loss of Tax Exemption As discussed under the caption "TAX MATTERS" herein, interest on the 2016 Bonds could become includable in gross income for purposes of federal income taxation retroactive to the date such 2016 Bonds were issued as a result of future acts or omissions of the Successor Agency in violation of its covenants contained in the Indenture. Should such an event of taxability occur, the 2016 Bonds are not subject to special redemption or any increase in interest rate and will remain outstanding until maturity. 1HSby11MaLSYSIIryF.ic ,! 40 IRS Audit of Bond Issues The Internal Revenue Service has initiated an expanded program for the auditing of tax - exempt bond issues, including both random and targeted audits. It is possible that the 2016 Bonds will be selected for audit by the Internal Revenue Service. It is also possible that the market value of the 2016 Bonds might be affected as a result of such an audit of the 2016 Bonds (or by an audit of similar bonds). Certain Bankruptcy Risks The enforceability of the rights and remedies of the owners of the 2016 Bonds and the obligations of the Successor Agency may become subject to the following: the federal bankruptcy code and applicable bankruptcy, insolvency, reorganization, moratorium, or similar laws relating to or affecting the enforcement of creditors' rights generally, now or hereafter in effect; usual equitable principles which may limit the specific enforcement under state law of certain remedies; the exercise by the United States of America of the powers delegated to it by the federal Constitution; and the reasonable and necessary exercise, in certain exceptional situations of the police power inherent in the sovereignty of the State of California and its governmental bodies in the interest of servicing a significant and legitimate public purpose. Bankruptcy proceedings, or the exercise of powers by the federal or state government, if initiated, could subject the owners of the 2016 Bonds to judicial discretion and interpretation of their rights in bankruptcy or otherwise and consequently may entail risks of delay, limitation, or modification of their rights. The opinion of Bond Counsel as to the enforceability of the obligation to make payments on the 2016 Bonds will be qualified as to bankruptcy and such other legal events. See APPENDIX E — "FORM OF OPINION OF BOND COUNSEL." Bankruptcy of Landowners The bankruptcy of a major assessee in the Project Area could delay and/or impair the collection of property taxes by the County with respect to properties in the bankruptcy estate. Although the Successor Agency is not aware of any major property owners in the Project Area that are in bankruptcy or threatening to declare bankruptcy, the Successor Agency cannot predict the effects on the collections of Tax Revenues if such an event were to occur. Risk of Earthquake The City, like most regions in California, is an area of significant seismic activity and, therefor, is subject to potentially destructive earthquakes. The Los Angeles basin has experienced significant earthquakes in the past. Most recently in the vicinity of the Project Area, on October 1, 1987, a 5.9 magnitude earthquake occurred on a previously unknown, concealed thrust fault approximately 11 miles east of downtown Los Angeles, California, approximately 6 miles southeast of Pasadena and approximately 1 mile southeast of the City. The earthquake resulted in eight fatalities and approximately $358 million in property damage. Severe damage was confined mainly to communities east of Los Angeles and near the epicenter in the City of Whittier. Significant structural damage to property within the Project Area was reported and repairs were completed within one year of the earthquake. If an earthquake were to substantially damage or destroy taxable property within the Project Area, the assessed valuation of such property could be reduced. Such a reduction of assessed valuations could result in a reduction of the Subordinate Tax Revenues that secure the 2016 Bonds, which in turn could impair the ability of the Successor Agency to make payments of principal of and/or interest on the 2016 Bonds when due. 41 OHSUSA:765600743.3 Hazardous Substances An additional environmental condition that may result in the reduction in the assessed value of property would be the discovery of a hazardous substance that would limit the beneficial use of taxable property within the Project Area. In general, the owners and operators of a property may be required by law to remedy conditions of the property relating to releases or threatened releases of hazardous substances. The owner or operator may be required to remedy a hazardous substance condition of property whether or not the owner or operator has anything to do with creating or handling the hazardous substance. The effect, therefore, should any of the property within the Project Area be affected by a hazardous substance, could be to reduce the marketability and value of the property by the costs of remedying the condition. State Budget AB 26 and AB 1484 were enacted by the State Legislature and Governor as trailer bills necessary to implement provisions of the State's budget acts for its Fiscal Years 2011 -12 and 2012 -13, respectively, as efforts to address structural deficits in the State general fund budget. In general terms, these bills implemented a framework to transfer cash assets previously held by redevelopment agencies to cities, counties, and special districts to fund core public services, with assets transferred to schools offsetting State general fund costs (then projected savings of $1.5 billion). SB 107, which makes extensive amendments to the Dissolution Act, was enacted following the adoption of the Fiscal Year 2015 -16 Budget, after having initially been presented as AB 113, a trailer bill to the Fiscal Year 2015 -16 Budget. SB 107 changes the process for submitting Recognized Obligation Payment Schedules from a six -month to an annual process, authorizes successor agencies to submit and obtain DOF approval of a Last and Final Recognized Obligation Payment Schedule to govern all remaining payment obligations of the successor agency, alters the provisions governing the distribution of RPTTF moneys attributable to pension and State Water Project tax rate overrides, and eliminates the impact of financial and time limitations in redevelopment plans for purposes of paying enforceable obligations, among other changes to the Dissolution Act. These statutory amendments impact the manner in which successor agencies claim RPTTF moneys for enforceable obligations and, for some successor agencies, impact the amount of RPTTF moneys that will be available for payment of the successor agency's enforceable obligations. Certain litigation is challenging some of the terms of the Dissolution Act, and there can be no assurance that additional legislation will not be enacted in the future to additionally implement provisions relating to the State budget or otherwise that may affect successor agencies or tax increment revenues, including Subordinate Tax Revenues. The Successor Agency cannot predict what measures may be proposed or implemented for the current fiscal year or in the future. Information about the State budget and State spending is available at various State maintained websites. Text of the Fiscal Year 2016 -17 Budget and other documents related to the State budget may be found at the website of the DOF, www.dof.ca.gov. A nonpartisan analysis of the budget is posted by the Legislative Analyst's Office at www.lao.ca.gov. In addition, various State official statements, many of which contain a summary of the current and past State budgets may be found at the website of the State Treasurer, www.treasurer.ca.gov. None of the websites or webpages referenced above is incorporated into this Official Statement. They are cited for informational purposes only. The Successor Agency makes no representation as to the accuracy or completeness of any of the information on such websites. 42 OHSUSA:765600743.3 Direct and Overlapping Indebtedness The ability of land owners within the Project Area to pay property tax installments as they come due could be affected by the existence of other taxes and assessments, imposed upon the land. In addition, other public agencies whose boundaries overlap those of the Project Area could, without consent of the Successor Agency, and in certain cases without the consent of the owners of the land within the Project Area, impose additional taxes or assessment liens on the property to finance public improvements. Future Legislation and Initiatives Article XIIIA, Article XM and Proposition 218 were each adopted as measures that qualified for the ballot pursuant to California's initiative process. From time to time other initiative measures could be adopted, further affecting revenues of the Successor Agency or the Successor Agency's ability to expend revenues. In addition, there are currently a number of proposed legislative changes to the Dissolution Act which, if adopted, would also affect revenues of the Successor Agency or the Successor Agency ability to expend revenues. The nature and impact of these measures cannot currently be anticipated. Investment Risk Funds held under the Indenture are required to be invested in Permitted Investments as provided under the Indenture. See APPENDIX D attached hereto for a summary of the definition of Permitted Investments. All investments, including the Permitted Investments and those authorized by law from time to time for investments by municipalities, contain a certain degree of risk. Such risks include, but are not limited to, a lower rate of return than expected and loss or delayed receipt of principal. [Further, the Successor Agency cannot predict the effects on the receipt of Tax Revenues if the County were to suffer significant losses in its portfolio of investments or if the County or the City were to become insolvent or declare bankruptcy. See "RISK FACTORS — Certain Bankruptcy Risks. "] Challenges to Dissolution Act Several successor agencies, cities and other entities have filed judicial actions challenging the legality of various provisions of the Dissolution Act. One such challenge is an action filed on August 1, 2012, by Syncora Guarantee Inc. and Syncora Capital Assurance Inc. (collectively, "Syncora") against the State, the State Controller, the State Director of Finance, and the Auditor - Controller of San Bernardino County on his own behalf and as the representative of all other County Auditors in the State (Superior Court of the State of California, County of Sacramento, Case No. 34- 2012- 80001215). Syncora are monoline financial guaranty insurers domiciled in the State of New York, and as such, provide credit enhancement on bonds issued by state and local governments and do not sell other kinds of insurance such as life, health, or property insurance. Syncora provided bond insurance and other related insurance policies for bonds issued by former California redevelopment agencies. The complaint alleged that the Dissolution Act, and specifically the "Redistribution Provisions" thereof (i.e., California Health and Safety Code Sections 34172(d), 34174, 34177(d), 34183(a)(4), and 34188) violate the "contract clauses" of the United States and California Constitutions (U.S. Const. art. 1, § 10, cl.l; Cal. Const. art. 1, § 9) because they unconstitutionally impair the contracts among the former redevelopment agencies, bondholders and Syncora. The complaint also alleged that the Redistribution Provisions violate the "Takings Clauses" of the United States and California Constitutions (U.S. Const. amend. V; Cal Const. art. 1 § 19) because they unconstitutionally take and appropriate bondholders' and Syncora's contractual right to critical security mechanisms without just compensation. 43 OHSUSA:765600743.3 After hearing by the Sacramento County Superior Court on May 3, 2013, the Superior Court ruled that Syncora's constitutional claims based on contractual impairment were premature. The Superior Court also held that Syncora's takings claims, to the extent based on the same arguments, were also premature. Pursuant to a Judgment stipulated to by the parties, the Superior Court on October 3, 2013, entered its order dismissing the action. The Judgment, however, provides that Syncora preserves its rights to reassert its challenges to the Dissolution Act in the future. The Successor Agency can offer no assurance that any reassertion of challenges by Syncora or that the final results of any of the judicial actions brought by others challenging the Dissolution Act will not result in an outcome that may have a material adverse effect on the Successor Agency's ability to timely pay debt service on the 2016 Bonds. Secondary Market There can be no guarantee that there will be a secondary market for the 2016 Bonds, or, if a secondary market exists, that the 2016 Bonds can be sold for any particular price. Occasionally, because of general market conditions or because of adverse history or economic prospects connected with a particular issue, secondary marketing practices in connection with a particular issue are suspended or terminated. Additionally, prices of issues for which a market is being made will depend upon the then prevailing circumstances. LIMITATIONS ON TAX REVENUES Property Tax Limitations - Article XIIIA Article XIIIA of the California Constitution. Section 1(a) of Article XIIIA of the California Constitution limits the maximum ad valorem tax on real property to one percent of full cash value, to be collected by the counties and apportioned according to law. Section 2 of Article XIIIA defines "full cash value" to mean "the county assessor's valuation of real property as shown on the 1975/76 tax bill under full cash value or, thereafter, the appraised value of real property when purchased, newly constructed, or a change in ownership has occurred after the 1975 assessment." The full cash value may be adjusted annually to reflect inflation at a rate not to exceed 2% per year, or reduction in the consumer price index or comparable data for the area under taxing jurisdiction or reduced in the event of declining property value caused by substantial damage, destruction or other factors. Legislation enacted by the California Legislature to implement Article XHIA provides that notwithstanding any other law, local agencies may not levy any ad valorem property tax except to pay debt service on indebtedness approved by the voters as described above. In the general elections of 1986, 1988, and 1990, the voters of the State approved various measures which further amended Article XIIIA. One such amendment generally provides that the purchase or transfer of (i) real property between spouses or (ii) the principal residence and the first $1,000,000 of the full cash value of other real property between parents and children, do not constitute a "purchase" or "change of ownership" triggering reassessment under Article XIIIA. This amendment will reduce the tax increment of the Successor Agency. Other amendments permitted the Legislature to allow persons over 55 who sell their residence and on or after November 5, 1986, to buy or build another of equal or lesser value within two years in the same county, to transfer the old residence's assessed value to the new residence, and permitted the Legislature to authorize each county under certain circumstances to adopt an ordinance making such transfers or assessed value applicable to situations in which the replacement dwelling purchased or constructed after November 8, 1988, is located within that county and the original property is located in another county within California. In the June 1990 election, the voters of the State approved additional amendments to Article XIIIA permitting the State Legislature to extend the replacement dwelling provisions applicable to 44 OHSUSA:765600743.3 persons over 55 to severely disabled homeowners for replacement dwellings purchased or newly constructed on or after June 5, 1990, and to exclude from the definition of "new construction" triggering reassessment improvements to certain dwellings for the purpose of making the dwelling more accessible to severely disabled persons. In the November 1990 election, the voters approved the amendment of Article XIIIA to permit the State Legislature to exclude from the definition of "new construction" seismic retrofitting improvements or improvements utilizing earthquake hazard mitigation technologies constructed or installed in existing buildings after November 6, 1990. Both the California Supreme Court and the United States Supreme Court have upheld the constitutionality of Article XBIA. Legislation Implementing Article XIIIA. Legislation has been enacted and amended a number of times since 1978 to implement Article XIIIA. Under current law, local agencies are no longer permitted to levy directly any property tax (except to pay voter - approved indebtedness). The 1% property tax is automatically levied by the county and distributed according to a formula among taxing agencies. The formula apportions the tax roughly in proportion to the relative shares of taxes levied prior to 1978. Increases of assessed valuation resulting from reappraisals of property due to new construction, change in ownership or from the 2% annual adjustment are allocated among the various jurisdictions in the "taxing area" based upon their respective "situs." Any such allocation made to a local agency continues as part of its allocation in future years. Article XIIIB of the California Constitution. On November 6, 1979, California voters approved Proposition 4, the Gann Initiative, which added Article XM13 to the California Constitution. Under Article XIIIB, as amended, state and local governmental entities have an annual "appropriations limit" and are not permitted to spend certain moneys which are called "appropriations subject to limitation" (consisting of tax revenues, state subventions and certain other funds) in an amount higher than the "appropriations limit." The principal effect of Article XIH I3 is to limit the annual appropriations of the State and any city, county, school district, authority or other political subdivision of the State to the level of appropriations for the prior fiscal year, as adjusted for changes in the cost of living, population and services rendered by the government entity. Appropriations subject to Article XIHB include generally the proceeds of taxes levied by the State or other entity of local government, exclusive of certain State subventions, refunds of taxes, benefit payments from retirement, unemployment insurance and disability insurance funds. Effective September 30, 1980, the California Legislature added Section 33678 to the Law which provides that the allocation of taxes to a redevelopment agency for the purpose of paying principal of, or interest on, loans, advances, or indebtedness will not be deemed the receipt by the Successor Agency of proceeds of taxes levied by or on behalf of the Successor Agency within the meaning of Article XI11B or any statutory provision enacted in implementation thereof, including Section 33678 of the Law. The constitutionality of Section 33678 has been upheld by the Second and Fourth District Courts of Appeal in two decisions: Bell Community Redevelopment Agency v. Woosely and Brown v. Community Redevelopment Agency of the City of Santa Ana. On the basis of these decisions, the Successor Agency has not adopted an appropriations limit. Proposition 218. On November 5, 1996, the voters of the State approved Proposition 218, the "Right to Vote on Taxes Act." Proposition 218 added Articles XIIIC and XII D to the State Constitution, which contain a number of provisions affecting the ability of the public agencies to levy and collect both existing and future taxes, assessments, fees and charges. OHSUSA:765600743.3 45 Article XEIC removes limitations on the initiative power in matters of local taxes, special taxes, assessments, fees and charges. While the matter is not free from doubt, it is likely that a court would hold that the initiative power cannot be used to reduce or repeal the levy of property taxes or to materially affect the collection and pledge of Subordinate Tax Revenues. The interpretation and application of the initiative provisions of Proposition 218 will ultimately be determined by the courts with respect to a number of the matters discussed above, and while it is not possible at this time to predict with certainly the outcome of such determination, the Successor Agency does not believe that Proposition 218 will materially affect its ability to pay principal of and interest on the 2016 Bonds. Unitary Property. AB 454 (Chapter 921, Statutes of 1986) provides that revenues derived from most utility property assessed by the State Board of Equalization ( "Unitary Property "), commencing with the 1988 89 fiscal year, will be allocated as follows: (1) each jurisdiction, including the Project Area, will receive up to 102% of its prior year State- assessed revenue; and (2) if county -wide revenues generated from Unitary Property are less than the previous year's revenues or greater than 102% of the previous year's revenues, each jurisdiction will share the burden of the shortfall or excess revenues by a specified formula. This provision applies to all Unitary Property except railroads, whose valuation will continue to be allocated to individual tax rate areas. To administer the allocation of unitary tax revenues to redevelopment agencies, the County no longer includes the taxable value of utilities as part of the reported taxable values of the project area, therefore, the base year of project areas have been reduced by the amount of utility value that existed originally in the base year. The provisions of AB 454 do not constitute an elimination of the assessment of any State - assessed properties nor a revision of the method of assessing utilities by the State Board of Equalization. Generally, AB 454 allows valuation growth or decline of Unitary Property to be shared by all jurisdictions in a county. In addition, a substantial portion, approximately 10% of Gross Tax Revenues are derived from unitary property taxes. Unitary revenue of $1,237,273 is assumed to remain constant at that level for projection purposes through the projections in the Fiscal Consultant's Report. This amount is reasonably consistent with the unitary revenue allocations made to the Successor Agency in recent years. The relatively high amount of unitary revenues is attributable to Southern California Edison properties contained in the Component Area No. 1. In March 2010, Southern California Edison purchased 270,000 square feet of additional office space for their operations in the City, an investment of $33,750,000. The Successor Agency and City believe this significant investment represents a desire for Southern California Edison to remain in the City for the foreseeable future. However, it should be noted that unitary revenues allocated to the Successor Agency come from several sources and are allocated based on the statutory method described above and do not reflect the current unitary assessed value within the Component Area No. 1 particularly or the Project Area. For purposes of projection, it is assumed herein that unitary tax revenue will continue to be allocated in similar amounts over the life of the Project Area, and that unitary tax will remain constant through the life of the project. Changes in law with respect to the allocation of unitary values could impact Tax Revenues. [The Successor Agency's unitary revenues have fallen by approximately 19.2% since 1992 -93. According to the California State Board of Equalization, there have been two primary causes of the decrease unitary assessed valuation in the County of Los Angeles. The first was the privatization of power generation facilities in the late 1990's. When a power generation facility was sold to a private entity it became locally assessed and was attributed to the Tax Rate Area (TRA) in which it is located. Assessment of these facilities moved back to the State in 2003, but the value is associated with specific TRAs according to California Revenue and Taxation Code Section 100.9. The second primary cause of a OHSUSA:765(00743.3 46 decrease in unitary valuations within the County was due to a decrease in the assessed valuation of telecommunication companies during the period 2002 through 2005.1 Implementing Legislation Legislation enacted by the California Legislature to implement Article XIIIA provides that all taxable property is shown at full assessed value as described above. In conformity with this procedure, all taxable property value is shown at 100% of assessed value and all general tax rates reflect the $1.00 per $100 of taxable value. Tax rates for bond debt service and pension liability are also applied to 100% of assessed value. Future assessed valuation growth allowed under Article XIIIA (new construction, change of ownership, 2% annual value growth) will be allocated on the basis of "situs" among the jurisdictions that serve the tax rate area within which the growth occurs. Local agencies and school districts will share the growth of "base" revenue from the tax rate area. Each year's growth allocation becomes part of each agency's allocation in the following year. The Successor Agency is not able to predict the nature or magnitude of future revenue sources which may be provided by the State to replace lost property tax revenues. Article XIIIA effectively prohibits the levying of any other ad valorem property tax above the I% limit except for taxes to support indebtedness approved by the voters as described above. Redevelopment Plan Limits The redevelopment plans for each component project area comprising the Project Area originally included separate time and financial limitations applicable to each project area comprising the Project Area. SB 107, which became effective September 22, 2015, amended the Dissolution Act to provide that the time limits for receiving property tax revenues and the limitation on the amount of property tax revenues that may be received by the Former Agency and the Successor Agency set forth in the Redevelopment Plan are not effective for purposes of paying the Successor Agency's enforceable obligations such as the Senior Bonds, the 2016 Bonds and Parity Debt. Accordingly, the projections set forth in this Official Statement and in the Fiscal Consultant's Report attached to this Official Statement as APPENDIX A were prepared without regard to the time and financial limitations set forth in the Redevelopment Plan. Previous descriptions of the source of payment and security for the Senior Bonds included summary descriptions of time and financial limitations applicable to each project area comprising the Project Area, which limits are no longer applicable to the repayment of principal of and interest on the Senior Bonds or the 2016 Bonds. Unitary Property Assembly Bill 2890 (Statutes of 1986, Chapter 1457), which added Section 98.9 to the California Revenue and Taxation Code, provided that, commencing with the Fiscal Year 1988 -89, assessed value derived from State - assessed unitary property (consisting mostly of operational property owned by utility companies) was to be allocated county -wide as follows: (i) each tax rate area will receive the same amount from each assessed utility received in the previous fiscal year unless the applicable county -wide values are insufficient to do so, in which case values will be allocated to each tax rate area on a pro rata basis; and (ii) if values to be allocated are greater than in the previous fiscal year, each tax rate area will receive a pro rata share of the increase from each assessed utility according to a specified formula. Additionally, the lien date on State - assessed property was changed from March 1 to January 1. Assembly Bill 454 (Statutes of 1987, Chapter 921) further modified the distribution of tax revenues derived from property assessed by the State Board of Equalization. Chapter 921 provided for the consolidation of all State- assessed property, except for regulated railroad property, into a single tax rate 47 OHSUSA:765600743.3 area in each county. Chapter 921 further provided for a new method of establishing tax rates on State - assessed property and distribution of property tax revenues derived from State - assessed property to taxing jurisdictions within each county as follows: for revenues generated from the 1% tax rate, each jurisdiction, including redevelopment project areas, will receive a percentage up to 102% of its prior year State - assessed unitary revenue; and if county -wide revenues generated for unitary property are greater than 102% of the previous year's unitary revenues, each jurisdiction will receive a percentage share of the excess unitary revenue generated from the application of the debt service tax rate to county -wide unitary taxable value, further, each jurisdiction will receive a percentage share of revenue based on the jurisdiction's annual debt service requirements and the percentage of property taxes received by each jurisdiction from unitary property taxes in accordance with a new formula. Railroads will continue to be assessed and revenues allocated to all tax rate areas where railroad property is sited. The intent of Chapters 1457 and 921 was to provide redevelopment agencies with their appropriate share of revenue generated from the property assessed by the State Board of Equalization. As noted in the Fiscal Consultant's Report, Gross Tax Revenue includes estimated unitary revenue in the amount of $1,276,382 annually, based on recent historical receipts. The secured roll accounted for approximately 89% of the Gross Tax Revenues in Fiscal Year 2015 -16, with the unsecured roll comprising approximately I M. There was no non - unitary utility roll valuation (the unitary utility roll is based on countywide assessments and is not reported by project area). The Successor Agency cannot predict the effect of any future litigation or settlement agreements on the amount of unitary tax revenues received or to be received nor the impact on unitary property tax revenues of any transfer of electrical transmission lines to tax - exempt agencies. Tax Increment Limitations; Senate Bill 107 AB 1290, signed into law in December 1993, provided for the placement of time limits on the effectiveness of every redevelopment plan, and provided that after 10 years from the termination date of a plan's effectiveness, no redevelopment agency, subject to certain exceptions, will pay indebtedness or receive property taxes in connection therewith. Subsequent bills, Senate Bill 1045 ( "SB 1045 ") and Senate Bill 1096 (SB "1096 ") allowed the Former Agency to extend the effective date of the related redevelopment plan, and the date to receive Tax Revenues in the Project Area, by one year, and two years, subject to certain conditions and subject to compliance with major housing requirements. The Former Agency has taken such action with respect to SB 1045. Pursuant to the related redevelopment plan, the expiration date of the related redevelopment plan is as described in "THE PROJECT AREA," herein. The redevelopment plans for each project area comprising the Project Area originally included separate time and financial limitations applicable to the Project Area. SB 107, which became effective September 22, 2015, amended the Dissolution Act to provide that the time limits for receiving property tax revenues and the limitation on the amount of property tax revenues that may be received by the Former Agency and the Successor Agency set forth in the Redevelopment Plan are not effective for purposes of paying the Successor Agency's enforceable obligations. Accordingly, the projections set forth in this Official Statement and in the Fiscal Consultant's Report attached to this Official Statement as APPENDIX A were prepared without regard to the time and financial limitations set forth in the Redevelopment Plan. With the passage of SB 107, the Successor Agency is no longer subject to either the last date to repay indebtedness or the tax increment limit for purposes of payment of enforceable obligations. 48 OHSUSA:765600743.3 Property Taxes; Delinquencies [Under the mechanism used by the County to distribute tax increment revenue to the former redevelopment agencies, the County pays one -half of the taxes from the net taxable assessed valuation appearing on the equalized roll to each agency's RPTTF on January 2 and the other one -half on June 1; delinquencies are not deducted from the RPTTF revenue, and delinquent tax payments and defaulted tax redemptions, penalties and interest are not added to RPTTF revenue. Consequently, the Successor Agency is not affected by delinquent tax payments. The overall delinquency rate for the last full fiscal year (2015- 16) for all secured properties in the Project Area was _% as of August _, 2016.] Tax Collection Fees Legislation enacted by the State Legislature authorizes county auditors to determine property tax administration costs proportionately attributable to local jurisdictions and to submit invoices to the jurisdictions for such costs. Subsequent legislation specifically includes redevelopment agencies among the entities which are subject to a property tax administration charge. The County administration fee amounts to approximately 2% of the tax increment revenues from a project area. The calculations of Tax Revenues take such administrative costs into account. Future Initiatives Article XIHA, Article XIIIB and Proposition 218 were each adopted as measures that qualified for the ballot under California's initiative process. From time to time other initiative measures could be adopted, further affecting property tax revenues or the Successor Agency's ability to expend such revenues. OTHER INFORMATION Certain Information Concerning the City Certain general information concerning the City is included herein as APPENDIX B hereto. Such information is provided for informational purposes only. The General Fund of the City is not liable for the payment of the 2016 Bonds or the interest thereon, nor is the taxing power of the City pledged for the payment of the 2016 Bonds or the interest thereon. Financial Statements Selected portions of the Audited Financial Statements of the Successor Agency for the Fiscal Year ended June 30, 2015, which have been audited by Rogers, Anderson, Malody & Scott, LLP, certified public accountants, are included in APPENDIX C hereto. The Successor Agency anticipates that its Audited Financial Statements for the Fiscal Year ended June 30, 2015 will be filed pursuant to the Continuing Disclosure Certificate with the Municipal Securities Rulemaking Board's Electronic Municipal Market Access (EMMA) system, or such other electronic system designated by the MSRB, on or before April 1, 2017. The Successor Agency has not requested, nor has Rogers, Anderson, Malody & Scott, LLP given, consent to the inclusion in APPENDIX C of its report on such financial statements, nor have such accountants reviewed or performed any audit procedures in connection with the preparation of this Official Statement. At the time of the authorization and issuance of the 2016 Bonds, the Successor Agency will certify that there has been no material adverse change in the Successor Agency's financial position since June 30, 2015. 49 OHSUSA:765600743.3 Continuing Disclosure The Successor Agency will covenant pursuant to a Continuing Disclosure Certificate, dated December _, 2016 (the "Continuing Disclosure Certificate "), to provide with respect to the 2016 Bonds, or to cause to be provided, to the Municipal Securities Rulemaking Board's Electronic Municipal Market Access system (the "EMMA System "), for purposes of Rule 15c2- 12(b)(5) (the "Rule ") adopted by the U.S. Securities and Exchange Commission ( "SEC "), certain annual financial information and operating data relating to the Successor Agency not later than the first Business Day of the month following the ninth month after the end of the Successor Agency's fiscal year, which date is on or about April 1 (the "Annual Report"), commencing with the Annual Report for the fiscal year ending June 30, 2016 and notice of the occurrence of certain enumerated events ( "Notice Events ") in a timely manner not in excess of ten (10) business days after the occurrence of such Notice Event. See APPENDIX F — "FORM OF CONTINUING DISCLOSURE CERTIFICATE." These covenants have been made in order to assist the Underwriter in complying with S.E.C. Rule 15c2- 12(b)(5). [Discuss Compliance] In addition, the Successor Agency has engaged Urban Futures, Inc. to act as Dissemination Agent under the Continuing Disclosure Certificate. As part of its services as Dissemination Agent, Urban Futures has agreed to develop and maintain a database to monitor, track and review reporting and filing requirements as outlined in the Continuing Disclosure Certificate. Litigation At the time of delivery of and payment for the 2016 Bonds, the Successor Agency will certify that, except as disclosed herein, to their respective best knowledge there is no litigation, action, suit, proceeding or investigation, at law or in equity, before or by any court, governmental agency or body, pending against or threatened against the Successor Agency in any way affecting the existence of the Successor Agency or the titles of its officers to their respective offices or seeking to restrain or enjoin the issuance, sale or delivery of the 2016 Bonds, the application of the proceeds thereof in accordance with the Indenture, or the collection or application of Tax Revenues to be pledged to pay the principal of and interest on the 2016 Bonds, or the pledge thereof, or in any way contesting or affecting the validity or enforceability of the 2016 Bonds, the Indenture, or any action of the Successor Agency contemplated by any of said documents, or in any way contesting the completeness or accuracy of this Official Statement or the powers of the Successor Agency or its authority with respect to the Indenture or any action of the Successor Agency contemplated by said documents, or in any way contesting the completeness or accuracy of this Official Statement or the powers of the Successor Agency or its authority with respect to the Indenture or any action of the Successor Agency contemplated by said documents, or which would adversely affect the exclusion of interest paid on the 2016 Bonds from gross income for Federal income tax purposes or the exemption of interest paid on the 2016 Bonds from California personal income taxation, nor, to the knowledge of the Successor Agency, is there any basis therefor. Tax Matters In the opinion of Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel, subject, however to the qualifications set forth below, under existing law, the interest on the 2016 Bonds is excluded from gross income for federal income tax purposes and such interest is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations, provided, however, that, for the purpose of computing the alternative minimum tax imposed on corporations (as defined for federal income tax purposes), such interest is taken into account in determining certain income and earnings. 50 OHSUSA:765600743.3 The opinions set forth in the preceding paragraph are subject to the condition that the Successor Agency comply with all requirements of the Internal Revenue Code of 1986, as amended (the "Tax Code ") that must be satisfied subsequent to the issuance of the 2016 Bonds. The Successor Agency has covenanted to comply with each such requirement. Failure to comply with certain of such requirements may cause the inclusion of such interest in gross income for federal income tax purposes to be retroactive to the date of issuance of the 2016 Bonds. If the initial offering price to the public (excluding bond houses and brokers) at which a Bond is sold is less than the amount payable at maturity thereof, then such difference constitutes `original issue discount" for purposes of federal income taxes and State of California personal income taxes. If the initial offering price to the public (excluding bond houses and brokers) at which a Bond is sold is greater than the amount payable at maturity thereof, then such difference constitutes "original issue premium" for purposes of federal income taxes and State of California personal income taxes. De minimis original issue discount and original issue premium is disregarded. Under the Tax Code, original issue discount is treated as interest excluded from federal gross income and exempt from State of California personal income taxes to the extent properly allocable to each owner thereof subject to the limitations described in the first paragraph of this section. The original issue discount accrues over the term to maturity of the 2016 Bond on the basis of a constant interest rate compounded on each interest or principal payment date (with straight -line interpolations between compounding dates). The amount of original issue discount accruing during each period is added to the adjusted basis of such 2016 Bonds to determine taxable gain upon disposition (including sale, redemption, or payment on maturity) of such 2016 Bond. The Tax Code contains certain provisions relating to the accrual of original issue discount in the case of purchasers of the 2016 Bonds who purchase the 2016 Bonds after the initial offering of a substantial amount of such maturity. Owners of such 2016 Bonds should consult their own tax advisors with respect to the tax consequences of ownership of Bonds with original issue discount, including the treatment of purchasers who do not purchase in the original offering, the allowance of a deduction for any loss on a sale or other disposition, and the treatment of accrued original issue discount on such 2016 Bonds under federal individual and corporate alternative minimum taxes. Under the Tax Code, original issue premium is amortized on an annual basis over the term of the 2016 Bond (said term being the shorter of the 2016 Bond's maturity date or its call date). The amount of original issue premium amortized each year reduces the adjusted basis of the owner of the 2016 Bond for purposes of determining taxable gain or loss upon disposition. The amount of original issue premium on a Bond is amortized each year over the term to maturity of the 2016 Bond on the basis of a constant interest rate compounded on each interest or principal payment date (with straight -line interpolations between compounding dates). Amortized Bond premium is not deductible for federal income tax purposes. Owners of premium Bonds, including purchasers who do not purchase in the original offering, should consult their own tax advisors with respect to State of California personal income tax and federal income tax consequences of owning such 2016 Bonds. Current and future legislative proposals, if enacted into law, clarification of the Tax Code or court decisions may cause interest on the 2016 Bonds to be subject, directly or indirectly, to federal income taxation or to be subject to or exempted from state income taxation, or otherwise prevent beneficial owners from realizing the full current benefit of the tax status of such interest. The introduction or enactment of any such legislative proposals, clarification of the Tax Code or court decisions may also affect the market price for, or marketability of, the 2016 Bonds. Prospective purchasers of the 2016 Bonds should consult their own tax advisors regarding any pending or proposed federal or state tax legislation, regulations or litigation, as to which Bond Counsel expresses no opinion. OHSUSA:765600743.3 51 In the further opinion of Bond Counsel, interest on the 2016 Bonds is exempt from California personal income taxes. Current and future legislative proposals, if enacted into law, clarification of the Tax Code or court decisions may cause interest on the 2016 Bonds to be subject, directly or indirectly, to federal income taxation or to be subject to or exempted from state income taxation, or otherwise prevent beneficial owners from realizing the full current benefit of the tax status of such interest. The introduction or enactment of any such legislative proposals, clarification of the Tax Code or court decisions may also affect the market price for, or marketability of, the 2016 Bonds. Prospective purchasers of the 2016 Bonds should consult their own tax advisors regarding any pending or proposed federal or state tax legislation, regulations or litigation, as to which Bond Counsel expresses no opinion. Owners of the 2016 Bonds should also be aware that the ownership or disposition of, or the accrual or receipt of interest on, the 2016 Bonds may have federal or state tax consequences other than as described above. Bond Counsel expresses no opinion regarding any federal or state tax consequences arising with respect to the Bonds other than as expressly described above. Municipal Advisor Urban Futures, Inc., Orange, California (the "Municipal Advisor ") has assisted the Successor Agency in matters relating to the planning, structuring, and sale of the 2016 Bonds and the preparation of this Official Statement, and has provided general financial advisory services to the Successor Agency with respect to the sale of the 2016 Bonds. The Municipal Advisor provides financial advisory services only and does not engage in the underwriting, marketing, or trading of municipal securities or other negotiable instruments. The payment of fees of the Municipal Advisor is contingent upon the closing of the 2016 Bonds. Legal Opinion Jones Hall, A Professional Law Corporation, San Francisco, California, will render is opinion with respect to the validity of the 2016 Bonds in substantially the form set forth in APPENDIX E hereto. Copies of such approving opinion will be available at the time of delivery of the 2016 Bonds. In addition, Orrick, Herrington & Sutcliffe LLP, as Disclosure Counsel, will deliver to the Underwriter a letter in customary form concerning the information set forth in this Official Statement. Verification of Mathematical Accuracy , certified public accountants, will verify, from the information provided to them, the mathematical accuracy of the computations contained in schedules to determine that the amounts to be held in the Refunding Fund pursuant to the Instructions will be sufficient to pay principal, interest and redemption price due on the Refunded Bonds through and including the redemption date. will express no opinion on the assumptions provided to them, nor as to the exemption from taxation of interest on the 2016 Bonds. Ratings S &P Global Ratings ( "S &P ") is expected to assign to the Insured 2016 Bonds its municipal bond rating of "_" with the understanding that the Policy insuring the payment when due of the principal of and interest on the Insured 2016 Bonds will be issued by the Insurer concurrently with the delivery of the Insured 2016 Bonds. S &P has assigned to the 2016 Bonds an underlying rating of "_... Such ratings 52 OHSUSA:765600743.3 reflect only the views of S &P, and do not constitute a recommendation to buy, sell or hold any of the 2016 Bonds. Explanation of the significance of such ratings may be obtained only from Standard and Poor's, 55 Water Street, New York, New York 10041. The ratings issued reflect only the view of such rating agency, and any explanation of the significance of such ratings should be obtained from such rating agency. There is no assurance that such ratings will be retained for any given period of time or that they will not be revised downward or withdrawn entirely by such rating agency if, in the judgment of such rating agency, circumstances so warrant. Any such downward revision or withdrawal of any rating obtained may have an adverse effect on the market price of the 2016 Bonds. Underwriting Stifel, Nicolaus & Company, Incorporated (the "Underwriter ") has agreed to purchase the 2016 Bonds at a price of $ (being the principal amount of the 2016 Bonds, plus an original issue premium of $ , less an Underwriter's discount of $ ) under a Bond Purchase Contract between the Successor Agency and the Underwriter. The Underwriter is committed to purchase all of the 2016 Bonds if any are purchased. The Underwriter may offer and sell the 2016 Bonds to certain dealers and others at prices lower the public offering price stated on the inside cover page hereof. The offering prices may be changed from time to time by the Underwriter. Miscellaneous All quotations from and summaries and explanations of the Indenture and other statutes and documents contained herein do not purport to be complete, and reference is made to such documents, Indenture and statutes for full and complete statements of their provisions. OHSUSA:765600743.3 53 This Official Statement is submitted only in connection with the sale of the 2016 Bonds by the Successor Agency. All estimates, assumptions, statistical information and other statements contained herein, while taken from sources considered reliable, are not guaranteed by the Successor Agency. The information contained herein should not be construed as representing all conditions affecting the Successor Agency or the 2016 Bonds. SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION LE Finance Director on behalf of the Successor Agency 54 OHSUSA:765600743.3 [THIS PAGE INTENTIONALLY LEFT BLANK] OHSUSA:765600743.3 APPENDIX A FISCAL CONSULTANT REPORT A -1 OHSUSA:765600743.3 [THIS PAGE INTENTIONALLY LEFT BLANK] 1IS: 1 1 II,Y W1w..9DMA /:\771IN 13►'o.l GENERAL INFORMATION CONCERNING THE CITY OF ROSEMEAD The following information is presented as general background data. The 2016 Bonds are payable solely from Tax Revenues and other sources as described herein. The taxing power of the City, the County, the State of California or any political subdivision thereof is not pledged to the payment of the 2016 Bonds. INTRODUCTION Location The City of Rosemead (the "City "), encompassing approximately 5'/2 square miles, is located in the central northwestern section of Los Angeles County approximately 12 miles east of the central business district of Los Angeles. The City shares common boundaries with the municipalities of San Gabriel, Temple City, El Monte, Montebello, Monterey Park and Alhambra. Municipal Government Incorporated in August 4, 1959, the City operates as a general law city. It has a council- manager form of government, with five council members elected at large for four -year overlapping terms. The Rosemead City Council (the "City Council ") selects a mayor and mayor pro -tem each year from its membership. The Council is responsible for enacting local legislation, establishing general policy for the City and adopting the annual budget. The Council's duties also include the appointment of a City Manager, City Attorney, City Clerk and City Treasurer and the selection of citizens to serve of the City's various advisory commissions. The City contracts with the Los Angeles County Sheriff's Department for sheriff services. Fire protection is provided through the Los Angeles County Fire Protection District. Two fire stations are located in the City. ECONOMIC AND DEMOGRAPHIC INFORMATION Data contained under this caption is intended to portray economic, demographic, and business trends within the City and the County of Los Angeles (the "County "). While not constituting direct revenue sources as such, these trends help explain changes in revenue sources such as property taxes, sales taxes, and transient occupancy taxes, which could be affected by changes in economic conditions. All the information presented in the following tables and other specific data references is the latest information available from the respective data sources. IM OHSUSA:765600743.3 Population Between 2007 and 2016, the population of the City increased by more than _ %. The table below displays population changes and other demographic data for the City and the County for the past five years. POPULATION DATA FOR THE CITY OF ROSEMEAD AND THE COUNTY OF LOS ANGELES City of Rosemead County of Los Angeles Year Population % Change Population % C hange 2007 54,045 -0.67 9,780,808 - 0.18% 2008 53,849 -0.36 9,785,474 0.05 2009 53,877 0.05 9,801,096 0.16 2010 53,764 -0.21 9,818,605 0.18 2011 54,119 0.66 9,874,887 0.57 2012 54,505 0.71 9,956,722 0.82 2013 54,669 0.30 10,023,753 0.67 2014 54,865 0.36 10,093,053 0.69 2015 54,987 0.22 10,155,069 0.61 2016 55,231 0.44 10,241,335 0.84 Source: State Department of Finance B -2 OHSUSA:765600743.3 Personal Income The table below summarizes the total effective buying income and median household effective buying income for the City, the County, the State of California and the United States for the period 2011 through 2015. City of Rosemead, County of Los Angeles, State of California, and United States Total Effective Buying Income Calendar Years 2011 through 2015 Year and Area 2011 Total Effective Buying Median Household Effective Income(in thousands) Buying Income City of Rosemead $ 653,983 $37,119 County of Los Angeles 197,831,465 43,083 State of California 814,578,458 47,062 United States 6,438,704,663 41,253 2012 City of Rosemead $ 694,890 $39,578 County of Los Angeles 210,048,048 44,384 State of California 864,088,828 47,307 United States 6,737,867,730 41,358 2013 City of Rosemead $ 715,898 $41,090 County of Los Angeles 205,133,995 45,013 State of California 858,676,636 48,340 United States 6,982,757,379 43,715 2014 City of Rosemead $ 730,285 $40,331 County of Los Angeles 214,247,274 46,449 State of California 901,189,699 50,072 United States 7,357,153,421 45,448 2015 City of Rosemead $ 754,180 $40,323 Los Angeles MSA 231,719,110 48,950 State of California 981,231,666 53,589 United States 7,757,960,399 46,738 Source: The Nielsen Company (US), Inc Labor Force The following chart provides information concerning the annual average total labor force, employment, and unemployment for the City, the County, the State of California and the United States for the years 2005 through 2016. B -3 OHSUSA:765600743.3 City of Rosemead, Los Angeles County, State of California and United States Labor Force, Employment, and Unemployment Annual Averages from 2005 through 2015 Year and Area Labor Force Employment Unemployment Unemployment Rated 2005 City of Rosemead t2> _la - -(2) -_ (2) Los Angeles County 4,781,600 4,525,200 256,400 5.4% State of California 17,530,100 16,582,700 947,400 5.4 United States 149,320,000 141,730,000 7,591,000 5.1 2006 City of Rosemead 24,900 (2) — (2) — 121 Los Angeles County 4,807,900 4,577,600 230,300 4.8% State of California 17,654,100 16,789,400 864,700 4.9 United States 151,428,000 144,427,000 7,001,000 4.6 2007 City of Rosemead -« — ( 2) —« -« Los Angeles County 4,864,200 4,614,800 249,400 5.1% State of California 17,893,100 16,931,600 961,500 5.4 United States 153,124,000 146,047,000 7,078,000 4.6 ►AIIN City of Rosemead 25,100 23,500 1,600 6.5% Los Angeles County 4,929,000 4,555,100 373,900 7.6 State of California 18,178,100 16,854,500 1,323,600 7.3 United States 154,287,000 145,362,000 8,924,000 5.8 2009 City of Rosemead 24,900 22,300 2,500 10.2% Los Angeles County 4,914,700 4,345,200 569,500 11.6 State of California 18,215,100 16,182,600 2,032,600 11.2 United States 154,142,000 139,877,000 14,265,000 9.3 2010 City of Rosemead 25,400 21,700 3,600 14.3% Los Angeles County 4,917,400 4,302,300 615,100 12.5 State of California 18,336,300 16,091,900 2,244,300 12.2 United States 153,889,000 139,064,000 14,825,000 9.6 (1) Unemployment rate is based on unrounded data. <a) Data not available. Source: California State Employment Development Department, Labor Market Information Division; U.S. Department of Labor, Bureau of Labor Statistics. B -4 OHSUSA:765600743.3 Unemployment Year and Area Labor Force Employment Unemployment Rate 2011 City of Rosemead 25,400 21,900 3,500 13.9% Los Angeles County 4,928,500 4,327,900 600,500 12.2 State of California 18,415,100 16,258,100 2,157,000 11.7 United States 153,617,000 139,869,000 13,747,000 8.9 2012 City of Rosemead 25,200 22,100 3,200 12.5% Los Angeles County 4,921,800 4,385,300 536,500 10.9 State of California 18,551,400 16,627,800 1,923,600 10.4 United States 154,975,000 142,469,000 12,506,000 8.1 2013 City of Rosemead 25,400 22,600 2,800 11.2% Los Angeles County 4,979,000 4,494,400 484,600 9.7 State of California 18,670,100 17,001,000 1,669,000 8.9 United States 155,389,000 143,929,000 11,460,000 7.4 2014 City of Rosemead 25,500 23,100 2,400 9.5% 7.7% Los Angeles County 5,025,900 4,611,500 414,300 8.2 6.7 State of California 18,827,900 17,418,000 1,409,900 7.5 6.2 United States 155,922,000 146,305,000 9,617,000 6.2 5.3 2015 City of Rosemead 25,400 23,400 2,000 7.7% Los Angeles County 5,011,700 4,674,800 336,900 6.7 State of California 18,981,800 17,798,600 1,183,200 6.2 United States 157,130,000 148,834,000 8,296,000 5.3 2016 City of Rosemead Los Angeles Countyl State of California (3) United States (3) 2) 5,109,700 19,357,900 18,281,600 1,076,300 159,800,000 151,804,000 7,996,000 2) 4,839,800 ( 269,900 2) 5.3% 5.6 5.0 (0 Unemployment rate is based on unrounded data. (2) Data not available. (3) Data not seasonally adjusted, as of August 2016. Source: California State Employment Development Department, Labor Market Information Division; U.S. Department of Labor, Bureau of Labor Statistics. B -5 OHSUSA:765600743.3 Business and Industry A sample of the major employers in the City are shown below, together with the approximate number of persons employed by each. CITY OF ROSEMEAD Major Employers Employer Edison International Garvey School District Wal -Mart Panda Restaurant Group Rosemead School District Target Hermetic Seal Corp. Olive Garden Double Tree Don Bosco Technical Institute of Business Utility — Regional headquarters Education Retail and Grocery Restaurant management Education Retail and Grocery Hermetic seal manufacturing Restaurant Hotel Education Number of Employees 4,100 804 400 400 337 225 187 112 110 90 Source: City of Rosemead. Commercial Activity Taxable transactions in the City totaled $397,902,000 in 2014, a 17% increase over 2010. The following table details taxable permits and transactions in the City of Rosemead for the years 2010 through 2014. CITY OF ROSEMEAD Taxable Transactions Calendar Years 2004 through 2008 (Taxable Transactions in $000's) 2010 2011 2012 2013 2014 Retail Stores Permits 650 651 689 695 723 Taxable Transactions $307,565 $324,335 $334,394 $350,493 $358,786 Total Outlets Permits 948 954 1,006 1,009 1,049 Taxable Transactions $340,797 $356,686 $368,379 $389,088 $397,902 Source: California State Board of Equalization, Construction Activity In the past five years for which complete information is available, the City issued building permits totaling approximately $145,951,361. Approximately 43% of this total consisted of permits for non - residential construction. Permits for new housing included 278 units, of which 46 were for multi OHSUSA:765600743.3 family occupancy. The following table details building permit activity in the City for the years 2005 through 2009: New Housing Units Single Units 50 72 58 22 30 Multiple Units 0 15 16 8 7 Total 50 87 74 330 37 Source: Construction Industry Research Board. Utilities Electricity is provided by Southern California Edison Company and gas is supplied by the Southern California Gas Company. Telephone services are provided by AT &T (successor to SBC and Pacific Bell). Water is supplied by six water companies: Adams Ranch Mutual Water, Amarillo Mutual Water, California- American Water, Golden State Water, San Gabriel Valley Water and San Gabriel County Water District. The majority of these organizations obtain water from the Metropolitan Water District of Southern California, while the San Gabriel County Water District and locally drilled wells provide the balance. Sewage treatment services are provided by the County of Los Angeles Sanitation District. Transportation The City's location near several interstate freeways affords residents immediate access to the extensive Southern California freeway network. This network links Rosemead to a number of diverse commercial and recreation activities located throughout Orange, Los Angeles and San Bernardino Counties. Two main east -west thoroughfares pass through the City. The San Bernardino Freeway (Interstate 10) traverse the central portion of the City and the Pomona Freeway (State Route 60) crosses the southern extremity of the City. Rosemead Boulevard (State Route 19) intersects these major routes and continues north to Pasadena, and south to Orange County. Major airports in the Los Angeles Basin are easily accessible by means of the highly developed freeway network in the West San Gabriel Valley. Air cargo and passenger facilities include those at the Los Angeles International Airport, Burbank- Glendale - Pasadena Airport, Long Beach International B -7 OHSUSA:765600743.3 CITY OF ROSEMEAD Building Permit Valuations Calendar Years 2005 through 2009 2005 2006 2007 2008 2009 Valuation ($000's) Residential $18,162,780 24,590,153 $23,195,904 $10,207,454 $12,530,293 Non - Residential 8,813,761 20,506,250 9,817,849 10,557,492 7,569,425 Total $26,976,541 $45,096,403 $33,013,753 $20,764,946 $20,099,718 New Housing Units Single Units 50 72 58 22 30 Multiple Units 0 15 16 8 7 Total 50 87 74 330 37 Source: Construction Industry Research Board. Utilities Electricity is provided by Southern California Edison Company and gas is supplied by the Southern California Gas Company. Telephone services are provided by AT &T (successor to SBC and Pacific Bell). Water is supplied by six water companies: Adams Ranch Mutual Water, Amarillo Mutual Water, California- American Water, Golden State Water, San Gabriel Valley Water and San Gabriel County Water District. The majority of these organizations obtain water from the Metropolitan Water District of Southern California, while the San Gabriel County Water District and locally drilled wells provide the balance. Sewage treatment services are provided by the County of Los Angeles Sanitation District. Transportation The City's location near several interstate freeways affords residents immediate access to the extensive Southern California freeway network. This network links Rosemead to a number of diverse commercial and recreation activities located throughout Orange, Los Angeles and San Bernardino Counties. Two main east -west thoroughfares pass through the City. The San Bernardino Freeway (Interstate 10) traverse the central portion of the City and the Pomona Freeway (State Route 60) crosses the southern extremity of the City. Rosemead Boulevard (State Route 19) intersects these major routes and continues north to Pasadena, and south to Orange County. Major airports in the Los Angeles Basin are easily accessible by means of the highly developed freeway network in the West San Gabriel Valley. Air cargo and passenger facilities include those at the Los Angeles International Airport, Burbank- Glendale - Pasadena Airport, Long Beach International B -7 OHSUSA:765600743.3 Airport and Ontario International Airport. All are less than 35 miles from the City. El Monte Airport, located two miles to the east, has facilities to service private aircraft. Education Most of the City is located in the Garvey School District and the Rosemead School District. Rosemead has 9 elementary schools, 3 junior high schools and 1 high school. Continuing education is available through the Los Angeles City Community College District. Los Angeles County is the location of many colleges and universities, both public and private, including such well known institutions as the University of California at Los Angeles, the University of Southern California, Occidental College, Claremont College and the California Institute of Technology. State University campuses are located in Los Angeles, Long Beach, Northridge, Pomona and Dominguez Hills. The City is also home to the Don Bosco Technical Institute (a private high school) and University of the West (formerly known as Hsi Lai University, a private, nonprofit, university). Community Facilities Health care services are provided by medical centers in Alhambra, San Gabriel and other neighboring communities. Located within the City are 2 fully - equipped mental health centers and a convalescent center. Religious and cultural facilities include 22 churches of various denominations and one library. Financial institutions include 10 banks and two savings and loan institutions. Recreational facilities for area residents include the City's own community parks and outdoor recreation offered in the surrounding areas. City facilities include 4 major public parks, 10 playgrounds, two municipal swimming pools, tennis courts, several baseball diamonds and 2 community centers. Southeast of the City is the Whittier Narrows Regional Park which includes the Whittier Narrows Golf Course. The San Gabriel Mountains and the Angeles National Forest, both located north of the City, provide additional outdoor recreation opportunities. Rosemead's proximity to the San Bernardino and Pomona Freeways bring the cultural and recreational advantages of Los Angeles and Orange Counties within convenient driving distance. OHSUSA:765600743.3 MC APPENDIX C CITY OF ROSEMEAD COMPREHENSIVE ANNUAL FINANCIAL REPORT FOR THE YEAR ENDED JUNE 30, 2015 C -1 OHSUSA:7656007433 APPENDIX D SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE D -1 OHSUSA:765600743.3 APPENDIX E FORM OF OPINION OF BOND COUNSEL Upon issuance of the 2016 Bonds, Jones Hall, A Professional Law Corporation, Bond Counsel, proposes to render its final approving opinion with respect to the 2016 Bonds in substantially the following form: [Closing Date] E -1 OHSUSA:765600743.3 APPENDIX F FORM OF CONTINUING DISCLOSURE CERTIFICATE THIS CONTINUING DISCLOSURE CERTIFICATE, dated December 2016, (this "Disclosure Certificate "), is executed and delivered by the SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION, a public body, corporate and politic, duly organized and existing pursuant to the Community Redevelopment Law of the State of California (as successor agency to the Rosemead Community Development Commission, the "Successor Agency "), in connection with the issuance of the Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds (the "Bonds ") pursuant to an Indenture of Trust, dated as of December 1, 2016 (the "Indenture "), by and between the Successor Agency and U.S. Bank National Association, as trustee (the "Trustee "). WITNESSETH: WHEREAS, successor agencies to former community redevelopment agencies are permitted to refund tax increment obligations pursuant to California Assembly Bill 1484 ( Stats 2012 c. 26) ( "AB 1484 ") in order to provide debt service savings to successor agencies and to increase property tax revenues available for distribution to affected taxing entities; and WHEREAS, the Successor Agency is empowered under the provisions of Section 34177.5(b) of the California Health and Safety Code authorizes a successor agency to issue refunding bonds pursuant to Article 11 (commencing with Section 53580) of Chapter 3 of Part 1 of Division 2 of Title 5 of the California Government Code, including tax allocation refunding bonds issued by said successor agencies, as described in Section 34177.5(a)(1) of the California Health and Safety Code; and WHEREAS, the Successor Agency has determined to issue the Bonds in order to provide funds to acquire bonds issued by the Successor Agency, in order to assist the Successor Agency in refunding certain of its outstanding bonds pursuant to AB 1484; and WHEREAS, such Refunding Bonds will be secured by a pledge of, and lien on, and shall be repaid from Tax Revenues (as defined in the Indenture) deposited from time to time in the Redevelopment Property Tax Trust Fund established pursuant to subdivision (c) of Section 34172 of the California Health and Safety Code; and WHEREAS, this Disclosure Certificate is being executed and delivered by the Successor Agency for the benefit of the holders and beneficial owners of the Bonds and in order to assist the underwriters of the Bonds in complying with Securities and Exchange Commission Rule 15c2- 12(b)(5); NOW, THEREFORE, for and in consideration of the mutual promises and covenants herein contained, the parties hereto agree as follows: Section 1. Definitions Unless the context otherwise requires, the terms defined in this Section shall for all purposes of this Disclosure Certificate have the meanings herein specified. Capitalized undefined terms used herein shall have the meanings ascribed thereto in the Indenture. "Annual Report" means any Annual Report provided by the Successor Agency pursuant to, and as described in, Sections 2 and 3 hereof. F -1 OHSUSA:765600743.3 "Annual Report Date" means not later than the first Business Day of the month following the ninth month after the end of the Successor Agency's fiscal year, which date, as of the date of this Disclosure Certificate, is April 1. "Successor Agency" means the Successor Agency to the Rosemead Community Development Commission, a public body, corporate and politic, duly organized and existing under and pursuant to the Law. "City" means the City of Rosemead, California. "County Auditor - Controller" means the Auditor - Controller of the County of Los Angeles. "Disclosure Representative" means or other agent as the Successor Agency and the Dissemination Agent (if other than the Successor Agency) may designate in writing from time to time. "Dissemination Agent" means the Successor Agency, acting in its capacity as Dissemination Agent hereunder, or any successor dissemination agent designated in writing by the Successor Agency and which has filed with the Successor Agency a written acceptance of such designation. hereof. "Listed Events" means any of the events listed in subsection (a) or subsection (b) of Section 4 "MSRB" means the Municipal Securities Rulemaking Board or any other entity designated or authorized by the Securities and Exchange Commission to receive reports pursuant to the Rule. Until otherwise designated by the MSRB or the Securities and Exchange Commission, filings with the MSRB are to be made through the Electronic Municipal Market Access (EMMA) website of the MSRB, currently located at http: / /emma.msrb.org. Bonds. "Official Statement" means the Official Statement, dated November , 2016, relating to the "Participating Underwriter" means any of the original underwriters of the Bonds required to comply with the Rule in connection with the offering of the Bonds. "Project Area" shall have the meaning specified in the Official Statement. "Rule" means Rule 15c2- 12(b)(5) adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as the same may be amended from time to time. "Trustee" means U.S. Bank National Association, as trustee under the Indenture, or any successor thereto as trustee thereunder, substituted in its place as provided therein. Section 2. Provision of Annual Reports (a) The Successor Agency shall, or shall cause the Dissemination Agent to, provide to the MSRB an Annual Report which is consistent with the requirements of Section 3 hereof, not later than the Annual Report Date, commencing with the report for the 2015 -16 Fiscal Year. The Annual Report may include by reference other information as provided in Section 3 hereof, provided, however, that the audited financial statements of the Successor Agency, if any, may be submitted separately from the balance of the Annual Report, and later than the date required above for the filing of the Annual Report if they are not available by that date. If the Successor Agency's fiscal year changes, it shall, or it shall instruct the Dissemination Agent to, give notice of such change in a F -2 OHSUSA:765600743.3 filing with the MSRB. The Annual Report shall be submitted on a standard form in use by industry participants or other appropriate form and shall identify the Bonds by name and CUSIP number. (b) Not later than 15 business days prior to the date specified in subsection (a) of this Section for the providing of the Annual Report to the MSRB, the Successor Agency shall provide the Annual Report to the Dissemination Agent. If by such date, the Dissemination Agent has not received a copy of the Annual Report, the Dissemination Agent shall contact the Successor Agency and the Dissemination Agent to determine if the Successor Agency is in compliance with the first sentence of this subsection (b). (c) If the Dissemination Agent is unable to verify that an Annual Report has been provided to the MSRB by the date required in subsection (a) of this Section, the Dissemination Agent shall, in a timely manner, send a notice to the MSRB in substantially the form attached as Exhibit A. (d) The Dissemination Agent shall: (i) provide any Annual Report received by it to the MSRB, as provided herein; and (ii) file a report with the Successor Agency certifying that the Annual Report has been provided pursuant to this Disclosure Certificate, stating the date it was provided to the MSRB. Section 3. Content of Annual Reports The Annual Report shall be prepared by the Successor Agency and shall contain or include by reference the following: (a) The Successor Agency's separate audited financial statements, or the City's audited financial statements including Successor Agency operations as a trust fund, prepared in accordance with generally accepted accounting principles as promulgated to apply to governmental entities from time to time by the Governmental Accounting Standards Board. If such audited financial statements are not available by the time the Annual Report is required to be filed pursuant to subsection (a) of Section 2 hereof, the Annual Report shall contain unaudited financial statements in a format similar to that used for the audited financial statements, and the audited financial statements, if any, shall be filed in the same manner as the Annual Report when they become available. (b) Unless otherwise provided in the audited financial statements filed on or before the Annual Report Date, financial information and operating data with respect to the Successor Agency, substantially similar to that provided in the corresponding tables relating to the Successor Agency and the Project Area in the Official Statement (and where not specified by date or period for the preceding fiscal year): (i) A summary description of the tax levy, percentage of current year levy collected, percentage of current levy delinquent, total collections and total collections as a percentage of the most recent year's tax levy; (ii) An update of the information contained in Table 1 of the Official Statement for the most recently completed fiscal year; (iii) An update of the information contained in Table 2 of the Official Statement for the most recently completed fiscal year; (iv) An update of the information contained in Table 3 of the Official Statement for the most recently completed fiscal year; and F -3 OHSUSA:765600743.3 (v) An update of the information contained in Table 4 of the Official Statement for the most recently completed fiscal year. (c) In addition to any of the information expressly required to be provided under subsections (a) and (b) of this Section, the Successor Agency shall provide such further information, if any, as may be necessary to make the specifically required statements, in light of the circumstances under which they are made, not misleading. Any or all of the items described above may be included by specific reference to other documents, including official statements of debt issues of the Successor Agency or related public entities, which have been submitted to the Securities and Exchange Commission. If the document included by reference is a final official statement, it must be available from the MSRB. The Successor Agency shall clearly identify each such other document so included by reference. Section 4. Reporting of Significant Events (a) Pursuant to the provisions of this Section, the Successor Agency shall give, or cause to be given with respect to the Refunding Bonds, and hereby authorizes the Successor Agency to give, or cause to be given, with respect to the Bonds, notice of the occurrence of any of the following events with respect to the Bonds in a timely manner not later than ten business days after the occurrence of the event: (i) Principal and interest payment delinquencies. (ii) Unscheduled draws on debt service reserves reflecting financial difficulties. (iii) Unscheduled draws on credit enhancements reflecting financial difficulties. (iv) Substitution of credit or liquidity providers, or their failure to perform. (v) Adverse tax opinions or issuance by the Internal Revenue Service of proposed or final determination of taxability or of a Notice of Proposed Issue (IRS Form 5701 TEB). (vi) Tender offers. (vii) Redemptions and Defeasances. (viii) Rating changes. (ix) Bankruptcy, insolvency, receivership or similar event of the obligated person. For purposes of the event identified in paragraph (ix), the event is considered to occur when any of the following occur: the appointment of a receiver, fiscal agent or similar officer for an obligated person in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the obligated person, or if such jurisdiction has been assumed by leaving the existing governmental body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the obligated person. (b) Pursuant to the provisions of this Section, the Successor Agency shall give, or cause to be given with respect to the Refunding Bonds, and hereby authorizes the Successor Agency to give, or cause F -4 OHSUSA:7 65 6 00743 3 to be given, with respect to the Bonds, notice of the occurrence of any of the following events with respect to the Bonds, if material, in a timely manner not later than ten business days after the occurrence of the event: (i) Unless described in paragraph (v) of subsection (a) of this Section, other material notices or determinations by the Internal Revenue Service with respect to the tax status of the Bonds or other material events affecting the tax status of the Bonds. (ii) Modifications to rights of holders of the Bonds. (iii) Optional, unscheduled or contingent Bond calls. (iv) Release, substitution, or sale of property securing repayment of the Bonds. (v) Non - payment related defaults. (vi) The consummation of a merger, consolidation, or acquisition involving an obligated person or the sale of all or substantially all of the assets of the obligated person, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms. (vii) Appointment of a successor or additional trustee or the change of name of a trustee. (c) The Successor Agency shall, within one business day of obtaining actual knowledge of the occurrence of any of the Listed Events, contact the Disclosure Representative and the Dissemination Agent and inform such persons of the event. (d) Whenever the Successor Agency obtains knowledge of the occurrence of a Listed Event described in subsection (b) of this Section, the Successor Agency, as applicable shall determine if such event would be material under applicable Federal securities law. (e) Whenever the Successor Agency obtains knowledge of the occurrence of a Listed Event described in subsection (a) of this Section, or determines that the occurrence of a Listed Event described in subsection (b) of this Section is material under subsection (d) of this Section, the Successor Agency shall, or shall cause the Dissemination Agent (if the Successor Agency is not the Dissemination Agent) to, file a notice of the occurrence of such Listed Event with the MSRB within ten business days of such occurrence. (f) Notwithstanding the foregoing, notice of Listed Events described in paragraph (iii) of subsection (a) of this Section and in paragraph (vii) of subsection (a) of this Section need not be given under this subsection any earlier than the notice (if any) of the underlying event is given to holders of affected Bonds pursuant to the Indenture. Section 5. Format for Filings with MSRB Any report or filing with the MSRB pursuant to this Disclosure Certificate must be submitted in electronic format, accompanied by such identifying information as is prescribed by the MSRB. Section 6. Termination of Reporting Obligation The obligations of the Successor Agency and the Dissemination Agent under this Disclosure Certificate shall terminate upon the legal defeasance, prior prepayment or payment in full of all of the Bonds or the legal defeasance, prior prepayment or payment in full of all of the Refunding Bonds, if earlier. If such termination occurs prior to the final principal F -5 OHSUSA:765600743.3 payment date of the Bonds, the Successor Agency shall give notice of such termination in a filing with the MSRB. Section 7. Dissemination Agent The Successor Agency may, from time to time, appoint or engage a Dissemination Agent (if the Successor Agency is not the Dissemination Agent) to assist it in carrying out its obligations under this Disclosure Certificate, and may discharge any such Dissemination Agent (if other than the Successor Agency or the Trustee), with or without appointing a successor Dissemination Agent. The Dissemination Agent may resign by providing thirty days written notice to the Successor Agency. Section 8. Amendment; Waiver Notwithstanding any other provision of this Disclosure Certificate, the Successor Agency may amend this Disclosure Certificate and any provision of this Disclosure Certificate may be waived, provided that the following conditions are satisfied: (a) if the amendment or waiver relates to the provisions of subsection (a) of Section 2 hereof, Section 3 hereof or subsections (a) or (b) of Section 4 hereof, it may only be made in connection with a change in circumstances that arises from a change in legal requirements, change in law, or change in the identity, nature or status of an obligated person with respect to the Bonds, or the type of business conducted; (b) the undertakings herein, as proposed to be amended or waived, would, in the opinion of nationally recognized bond counsel, have complied with the requirements of the Rule at the time of the primary offering of the Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances; and (c) the proposed amendment or waiver (i) is approved by holders of the Bonds in the manner provided in the Indenture for amendments to the Indenture with the consent of holders, or (ii) does not, in the opinion of nationally recognized bond counsel, materially impair the interests of holders or beneficial owners of the Bonds. hi the event of any amendment or waiver of a provision of this Disclosure Certificate, the Successor Agency shall describe such amendment or waiver in the next Annual Report, and shall include, as applicable, a narrative explanation of the reason for the amendment or waiver and its impact on the type (or in the case of a change of accounting principles, on the presentation) of financial information or operating data being presented by the Successor Agency. In addition, if the amendment relates to the accounting principles to be followed in preparing financial statements (i) notice of such change shall be given in a filing with the MSRB, and (ii) the Annual Report for the year in which the change is made shall present a comparison (in narrative form and also, if feasible, in quantitative form) between the financial statements as prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles. Section 9. Additional Information Nothing in this Disclosure Certificate shall be deemed to prevent the Successor Agency from disseminating any other information, using the means of dissemination set forth in this Disclosure Certificate or any other reasonable means of communication, or including any other information in any Annual Report or notice required to be filed pursuant to this Disclosure Certificate, in addition to that which is required by this Disclosure Certificate. If the Successor Agency chooses to include any information in any Annual Report or notice in addition to that which is specifically required by this Disclosure Certificate, the Successor Agency shall have no obligation under this Disclosure Certificate to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event or any other event required to be reported. F -6 OHSUSA:765600743.3 Section 10. Default The parties hereto acknowledge that in the event of a failure of the Successor Agency or the Dissemination Agent to comply with any provision of this Disclosure Certificate, the Trustee may (and, at the written direction of any Participating Underwriter or the holders of at least 25% of the aggregate amount of principal evidenced by Outstanding Bonds, shall, upon receipt of indemnification reasonably satisfactory to the Trustee), or any holder or beneficial owner of the Bonds may, take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the Successor Agency or the Dissemination Agent, as the case may be, to comply with its obligations under this Disclosure Certificate. A default under this Disclosure Certificate shall not be deemed an Event of Default under the Indenture, and the sole remedy under this Disclosure Certificate in the event of any failure of the Successor Agency or the Dissemination Agent to comply with this Disclosure Certificate shall be an action to compel performance. Section 11. Duties Immunities and Liabilities of Dissemination Agent. The Dissemination Agent shall (so long as the Successor Agency is the Dissemination Agent) be entitled to the protections and limitations from liability afforded to the Successor Agency under the Indenture. The Dissemination Agent shall be not responsible for the form or content of financial statements made part of any Annual Report or notice of Listed Event or for information sourced to the Successor Agency. The Dissemination Agent shall receive reasonable compensation for its services provided under this Disclosure Certificate. The Dissemination Agent (if other than the Successor Agency or the Successor Agency acting in its capacity as Dissemination Agent) shall have only such duties as are specifically set forth in this Disclosure Certificate. To the extent permitted by law, the Successor Agency shall indemnify and save the Dissemination Agent (if other than the Successor Agency) and the Successor Agency harmless against any liabilities which it may incur in the exercise and performance of its powers and duties hereunder, and which are not due to its negligence or its willful misconduct. The obligations of the Successor Agency under this Section shall survive resignation or removal of the Dissemination Agent and payment of the Bonds. Section 12. Beneficiaries This Disclosure Certificate shall inure solely to the benefit of the Successor Agency, the Dissemination Agent, the Participating Underwriter and the holder and beneficial owners from time to time of the Bonds, and shall create no rights in any other person or entity. Section 13. Counterparts This Disclosure Certificate may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. OHSUSA:765600743.3 F -7 IN WITNESS WHEREOF, the parties hereto have executed this Disclosure Certificate as of the date first above written. SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION Lm Finance Director ACCEPTED AND AGREED TO: URBAN FUTURES, INC., as Dissemination Agent m Authorized Signatory F -8 OHSUSA:765600743.3 SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION W [] on behalf of the Successor Agency F -9 OHSUSA:765600743.3 EXHIBIT A NOTICE OF FAILURE TO FILE ANNUAL REPORT Name of Issuer: Successor Agency to the Rosemead Community Development Commission Name of Issue: Successor Agency to the Rosemead Community Development Commission 2016 Subordinate Tax Allocation Refunding Bonds Date of Issuance: , 2016 NOTICE IS HEREBY GIVEN that the Successor Agency to the Rosemead Community Development Commission (the "Successor Agency ") has not provided an Annual Report with respect to the above -named bonds as required by the Continuing Disclosure Certificate, dated December _, 2016, by the Successor Agency. The Successor Agency anticipates that the Annual Report will be filed by Dated: SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION go [] on behalf of the Successor Agency cc: [Successor Agency to the Rosemead Community Development Commission] F -10 OHSUSA:765600743.3 APPENDIX G DTC AND BOOK -ENTRY ONLY SYSTEM The information in this APPENDIX G concerning the procedures and recordlceeping with respect to beneficial ownership interests in the 2016 Bowls, payment of principal of and interest on the 2016 Bonds to Participants or Beneficial Owners, confirmation and transfer of beneficial ownership interests in the 2016 Bonds, and other 2016 Bonds- related transactions by and between DTC, Participants and Beneficial Owners, is based on information furnished by DTC which the Successor Agency believes to be reliable, but the Successor Agency does not take responsibility for the completeness or accuracy thereof. The Depository Trust Company ( "DTC "), New York, NY, will act as securities depository for the 2016 Bonds, The 2016 Bonds will be issued as fully- registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully- registered bond certificate for each maturity of the 2016 Bonds will be issued for the 2016 Bonds in the aggregate principal amount of such maturity, and will be deposited with DTC. DTC, the world's largest securities depository, is a limited - purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non -U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC's participants ( "Direct Participants ") deposit with DTC. DTC also facilitates the post -trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book -entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly -owned subsidiary of The Depository Trust & Clearing Corporation ( "DTCC "). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ( "Indirect Participants "). DTC has a Standard & Poor's rating of AA +. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtec.com. The information on such website is not incorporated herein by such reference or otherwise. Purchases of 2016 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the 2016 Bonds on DTC's records. The ownership interest of each actual purchaser of each 2016 Bond ( "Beneficial Owner ") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the 2016 Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in 2016 Bonds, except in the event that use of the book -entry system for the 2016 Bonds is discontinued. G -1 OHSUSA:765600743.3 To facilitate subsequent transfers, all 2016 Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of 2016 Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the 2016 Bonds; DTC's records reflect only the identity of the Direct Participants to whose accounts such 2016 Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of 2016 Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the 2016 Bonds, such as redemptions, tenders, defaults, and proposed amendments to the Indenture. For example, Beneficial Owners of 2016 Bonds may wish to ascertain that the nominee holding the 2016 Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of notices be provided directly to them. Redemption notices shall be sent to DTC. If less than all of the 2016 Bonds within an issue are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to 2016 Bonds unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the Successor Agency as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts 2016 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Redemption proceeds, distributions, and dividend payments on the 2016 Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detail information from the Successor Agency or the Trustee, on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name" and will be the responsibility of such Participant and not of DTC, the Trustee, or the Successor Agency, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of redemption proceeds, distributions, and dividend payments to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the Successor Agency or the Trustee, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants. DTC may discontinue providing its services as depository with respect to the 2016 Bonds at any time by giving reasonable notice to the Successor Agency or the Trustee. Under such circumstances, in the event that a successor depository is not obtained, 2016 Bond certificates are required to be printed and delivered. OHSUSA:765600743.3 G -2 APPENDIX H FORM OF DEBT SERVICE RESERVE FUND SURETY BOND H -1 OHSUSA:7656007433 APPENDIX SPECIMEN MUNICIPAL BOND INSURANCE POLICY I -I OHSUSA:765600743.3 Attachment C Bond Purchase Agreement SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION ROSEMEAD MERGED PROJECT AREA 2016 SUBORDINATE TAX ALLOCATION REFUNDING BONDS PURCHASE CONTRACT , 2016 Successor Agency to the Rosemead Community Development Commission 8838 East Valley Boulevard Rosemead, California 91770 Ladies and Gentlemen: Stifel, Nicolaus & Company, Incorporated (the "Underwriter ") offers to enter into this Purchase Contract with the Successor Agency to the Rosemead Community Development Commission (the "Successor Agency ") with regard to the purchase and sale of the Bonds described herein which will be binding upon the Successor Agency the Underwriter upon the Successor Agency's acceptance hereof. All capitalized terms not otherwise defined herein shall have the meanings given them in the Indenture (defined below). 1. Purchase and Sale. Upon the terms and conditions and upon the basis of the representations herein set forth, the Underwriter agrees to purchase from the Successor Agency, and the Successor Agency agrees to sell to the Underwriter, all (but not less than all) of the Successor Agency's $ aggregate principal amount of Rosemead Merged project Area 2016 Subordinate Tax Allocation Refunding Bonds (the "Bonds "). The purchase price of the Bonds shall be $ (being the principal amount of the Bonds, less an Underwriter's discount in the amount of $ and plus /less original issue premium/discount of $ J . The Bonds will have the maturities and bear interest at the rates set forth on Exhibit A hereto. The Bonds will be subject to redemption as set forth in the Official Statement herein described. The Bonds will be dated as described in the Official Statement. The Bonds will be issued in book -entry form only. The net proceeds of the Bonds will be applied to refund outstanding indebtedness of the Rosemead Community Development Commission (the "Former Agency ") including the Former Agency's Redevelopment Project No. 1 Tax Allocation Bonds, Series 2006A, and the Former Agency's Project Area No. 1 Tax Allocation Refunding Bonds, Series 200613, and to purchase a municipal bond debt service reserve insurance policy (the "Reserve Policy "), and pay costs of issuance of the Bonds. 2. Authorizing Instruments and Law. The Bonds shall be issued pursuant to the Constitution and the laws of the State of California (the "State "), including Article 11 (commencing with Section 53580 of Chapter 3 of Part 1 of Division 2 of Title 5 of the Government Code and Parts 1.8 and 1.85 of Division 24 of the Health and Safety Code of the State of California (the "Law "), a resolution of the Successor Agency approving the issuance of the Bonds (the "Approving Resolution ") and a resolution of the Oversight Board (the "Oversight Board ") approving the action of the Successor Agency set forth in the Agency Resolution (the "Oversight Board Resolution "), and an Indenture of Trust, dated as of 1, 2016 (the "Indenture "), between the Successor Agency and U.S. Bank National Association, as trustee (the "Trustee "). The Bonds shall be as described in the hrdenture and the Official 22304696.1 Statement (defined below). The Successor Agency approved the execution and delivery of the Official Statement pursuant to a resolution of the Successor Agency (the "Disclosure Resolution" and, together with the Approving Resolution, the "Agency Resolution "). The Bonds are payable exclusively from Tax Revenues and from amounts on deposit in the Reserve Account for the Bonds and other accounts pledged under the Indenture. 3. Offering the Bonds. The Underwriter agrees to offer all the Bonds to the public initially at the prices (or yields) set forth on the inside cover page of the Official Statement of the Successor Agency pertaining to the Bonds, dated , 2016 (such Official Statement, together with all appendices thereto, and with such changes therein and supplements thereto as are consented to in writing by the Underwriter, are collectively called the "Official Statement "). Subsequent to the initial public offering of the Bonds, the Underwriter reserves the right to change the public offering prices (or yields) as it deems necessary in connection with the marketing of the Bonds. The Bonds may be offered and sold to certain dealers at prices lower than such initial public offering prices. "Public Offering" shall include an offering to a representative number of institutional investors or registered investment companies, regardless of the number of such investors to which the Bonds are sold. The Successor Agency acknowledges and agrees that (i) the purchase and sale of the Bonds pursuant to this Purchase Contract is an arm's - length commercial transaction between the Successor Agency and the Underwriter, (ii) in connection with such transaction the Underwriter has not assumed a fiduciary responsibility in favor of the Successor Agency with respect to (x) the offering of the Bonds or the process leading thereto (whether or not the Underwriter has advised or is currently advising the Successor Agency on other matters) or (y) any other obligation to the Successor Agency except the obligations expressly set forth in this Purchase Contract, and (iii) the Successor Agency has consulted with its own legal and other professional advisors to the extent it deemed appropriate in connection with the offering of the Bonds, including but not limited to matters relating to the timing of the sale of the Bonds, the size of the Bonds, and the potential impacts of the sale of the Bonds on the Successor Agency's financial condition. 4. Delivery of Official Statement on the Date Hereof. The Successor Agency shall deliver to the Underwriter two (2) copies of the Official Statement manually executed on behalf of the Successor Agency by the Executive Director of the Successor Agency. The Successor Agency shall also deliver a sufficient number of copies of the Official Statement to enable the Underwriter to distribute a single copy of the Official Statement to any potential customer of the Underwriter requesting an Official Statement during the time period beginning when the Official Statement become available and ending on the End Date (defined below). The Successor Agency shall deliver these copies to the Underwriter within seven (7) business days after the execution of this Purchase Contract and in sufficient time to accompany or precede any sales confirmation that requests payment from any customer of the Underwriter. The Underwriter shall inform the Successor Agency in writing of the End Date, and covenants to file the Official Statement with the Municipal Securities Rulemaking Board (the "MSRB ") on a timely basis. "End Date" as used herein is that date which is the earlier of: (a) ninety (90) days after the end of the underwriting period, as defined in SEC Rule 15c2 -12 adopted by the Securities and Exchange Commission on June 28, 1989 ( "Rule 15c2 -12 "); or (b) the time when the Official Statement become available from the MSRB, but in no event less than twenty -five (25) days after the underwriting period (as defined in Rule 15c2 -12) ends. Pursuant to the Agency Resolution, the Successor Agency has authorized the use of the Official Statement in connection with the public offering of the Bonds. The Successor Agency also has consented 22304696.1 to the use by the Underwriter prior to the date hereof of the Preliminary Official Statement of the Successor Agency, dated , 2016, in connection with the public offering of the Bonds (which, together with all appendices thereto, are herein called the "Preliminary Official Statement'). An authorized officer of the Successor Agency has certified to the Underwriter on behalf of the Successor Agency that such Preliminary Official Statement were deemed to be final as of their date for purposes of Rule 150-12, with the exception of certain final pricing and related information referred to in Rule 15c2- 12. The Underwriter has distributed a copy of the Preliminary Official Statement to potential customers on request. 5. The Closing. At 8:00 A.M., California time, on , 2016, or at such other time or on such earlier or later business day as shall have been mutually agreed upon by the Successor Agency and the Underwriter, the Successor Agency will deliver (i) the Bonds in book -entry form through or otherwise in care of the facilities of The Depository Trust Company ( "DTC "), and (ii) the closing documents hereinafter mentioned at the offices of Orrick, Herrington & Sutcliffe LLP, Los Angeles, California, or another place to be mutually agreed upon by the Successor Agency and the Underwriter. The Underwriter will pay the purchase price of the Bonds as set forth in Section 1 hereof by wire transfer of immediately available funds to the Trustee. This payment and delivery, together with the delivery of the aforementioned documents, is herein called the "Closing." 6. Successor Agency Representations, Warranties and Covenants. The Successor Agency represents, warrants and covenants to the Underwriter that: (a) Due Organization Existence and Authority. The Successor Agency is a public body corporate and politic, organized and existing under the Constitution and laws of the State, including the Law, with full right, power and authority to adopt the Agency Resolution, to issue the Bonds, and to execute, deliver and perform its obligations under the Bonds, this Purchase Contract, the Indenture, the Continuing Disclosure Certificates, the Official Statement and the Agency Resolution (the Bonds, the Purchase Contract, the Indenture, the Official Statement, the Continuing Disclosure Certificates and the Agency Resolution are collectively referred to herein as the "Successor Agency Documents "). (b) Due Authorization and Approval. By all necessary official action of the Successor Agency, the Successor Agency has duly authorized and approved the adoption or execution and delivery of, and the performance by the Successor Agency of the obligations on its part contained in, the Successor Agency Documents, and has approved the use by the Underwriter of the Preliminary Official Statement and the Official Statement and, as of the date hereof, such authorizations and approvals are in full force and effect and have not been amended, modified or rescinded. When executed and delivered by the parties thereto the Successor Agency Documents will constitute the legally valid and binding obligations of the Successor Agency enforceable upon the Successor Agency in accordance with their respective terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws or equitable principles relating to or affecting creditors rights generally. The Successor Agency has complied, and will at the Closing be in compliance in all respects, with the terms of the Successor Agency Documents. (c) Official Statement Accurate. The Official Statement are, and at all times subsequent to the date of each Official Statement up to and including the Closing will be, true and correct in all material respects, and the Official Statement contain, and up to and including the Closing will contain, no misstatement of any material fact and do not, and up to and including the Closing will not, omit any statement necessary to make the statements contained therein, in the light of the circumstances in which such statements were made, not misleading. 22304696.1 (d) Underwriter's Consent to Amendments and Supplements to Official Statement. The Successor Agency will advise the Underwriter promptly of any proposal to amend or supplement an Official Statement from the date of delivery of such Official Statement to the End Date, and will not effect or consent to any such amendment or supplement without the consent of the Underwriter, which consent will not be unreasonably withheld. The Successor Agency will advise the Underwriter promptly of the institution of any proceedings known to it by any governmental agency prohibiting or otherwise affecting the use of the Official Statement in connection with the offering, sale or distribution of the Bonds. (e) Successor Agency Agreement to Amend or Supplement Official Statement. For a period beginning on the date hereof and continuing until the End Date, (a) the Successor Agency will not adopt any amendment of, or supplement to, the Official Statement to which the Underwriter shall object in writing and (b) if any event relating to or affecting the Merged Project Area or the Successor Agency shall occur as a result of which it is necessary, in the opinion of Disclosure Counsel or the Underwriter, to amend or supplement the Official Statement in order to make the Official Statement not misleading in the light of the circumstances existing at the time they are delivered to a purchaser of the Bonds, the Successor Agency will forthwith prepare and furnish to the Underwriter a reasonable number of copies of an amendment of, or supplement to, the Official Statement (in form and substance satisfactory to Disclosure Counsel and the Underwriter) which will amend or supplement the Official Statement so that they will not contain an untrue statement of a material fact or omit to state a material fact necessary in order to make the statements therein, in the light of the circumstances existing at the time the Official Statement are delivered to a purchaser of the Bonds, not misleading. (f) No Material Change in Finances; Tax Sharing Agreements. At the time of the Closing, there shall not have been any material adverse change in the financial condition of the Successor Agency or any material adverse change in the valuation of taxable property in the Merged Project Area (as described in the Official Statement) since June 30, 2015. Except as disclosed in the Official Statement, the Successor Agency has not entered into any tax sharing agreements with regards to tax increment generated within the Merged Project Area, and the Successor Agency is not subject to any resolution of taxing entities adopted pursuant to former Section 33676 of the Law pursuant to which Tax Revenues attributable to growth in assessed value as a result of lawful inflationary adjustments are captured by such taxing entity. (g) No Breach or Default. As of the time of acceptance hereof and as of the Closing, except as otherwise disclosed in the Official Statement, the Successor Agency is not and will not be in breach of or in default under any applicable constitutional provision, law or administrative rule or regulation of the State or the United States, or any applicable judgment or decree or any trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the Successor Agency is a party or is otherwise subject, and no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute a default or event of default under any such instrument which breach, default or event could have an adverse effect on the Successor Agency's ability to perform its obligations under the Successor Agency Documents; and, as of such times, except as disclosed in the Official Statement, the authorization, execution and delivery of the Successor Agency Documents and compliance by the Successor Agency with the provisions of each of such agreements or instruments do not and will not conflict with or constitute a breach of or default under any applicable constitutional provision, law or administrative rule or regulation of the State or the United States, or any applicable judgment, decree, license, permit, trust agreement, loan agreement, bond, note, resolution, ordinance, agreement or other instrument to which the Successor Agency (or any of its officers in their respective capacities as such) is subject, or by which it or any of its properties is bound, nor will any such authorization, execution, delivery or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of its assets or properties or 22304696.1 under the terms of any such law, regulation or instrument, except as may be provided by the Successor Agency Documents. (h) No Litigation. As of the time of acceptance hereof and as of the Closing, except as disclosed in the Official Statement, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending or to the best knowledge of the Successor Agency threatened against the Successor Agency: (i) in any way questioning the corporate existence of the Successor Agency or the titles of the officers of the Successor Agency to their respective offices; (ii) affecting, contesting or seeking to prohibit, restrain or enjoin the issuance or delivery of any of the Bonds, or the payment or collection of any amounts pledged or to be pledged to pay the principal of and interest on the Bonds, or in any way contesting or affecting the validity of the Successor Agency Documents or the consummation of the transactions on the part of the Successor Agency contemplated thereby, or contesting the exclusion of the interest on the Bonds from taxation or contesting the powers of the Successor Agency; (iii) which may result in any material adverse change relating to the financial condition of the Successor Agency; or (iv) contesting the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto or asserting that the Preliminary Official Statement or the Official Statement contained any untrue statement of a material fact or omitted to state any material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. (i) Prior Liens on Tax Revenues. As of the time of acceptance hereof and as of the Closing the Successor Agency does not and will not have outstanding any indebtedness which is secured by a lien on the Tax Revenues superior to or on a parity with the lien of the Bonds on such Tax Revenues, subject to the (a) amounts, if any, payable pursuant to the Senior Bonds and (b) amounts, if any, payable pursuant to Section 33607.5 of the Law, but only to the extent such amounts described in clauses (b) are not subordinated to the payment of debt service on the Bonds, and (c) [the Pass - Through Agreements], except as disclosed in the Official Statement. 0) Further Cooperation; Blue Sky. The Successor Agency will furnish such information, execute such instruments and take such other action in cooperation with the Underwriter as the Underwriter may reasonably request in order (i) to qualify the Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions of the United States as the Underwriter may designate and (ii) to determine the eligibility of the Bonds for investment under the laws of such states and other jurisdictions, and will use its best efforts to continue such qualifications in effect so long as required for the distribution of the Bonds; provided, however, that the Successor Agency will not be required to execute a special or general consent to service of process or qualify as a foreign corporation in connection with any such qualification in any jurisdiction. (k) Bonds Issued Per Indenture; Pledge. The Bonds, when issued, executed and delivered in accordance with the Indenture and sold to the Underwriter as provided herein, will be legally valid and binding limited obligations of the Successor Agency, entitled to the benefits of the Indenture and enforceable in accordance with their terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws or equitable principles relating to or limiting creditors rights generally, and upon execution and delivery of the Bonds, the Indenture will provide, for 22304696.1 5 the benefit of the owners from time to time of the Bonds, a legally valid and binding pledge of and lien on Tax Revenues and on the funds and accounts pledged to such Bonds under the Indenture as provided in and contemplated by the hndenture. (1) Consents and Approvals. All authorizations, approvals, licenses, permits, consents and orders of or filings with any governmental authority, legislative body, board, agency or commission having jurisdiction in the matters which are required for the due authorization of, which would constitute a condition precedent to or the absence of which would adversely affect the due performance by the Successor Agency of, its obligations in connection with the Successor Agency Documents have been duly obtained or made. (m) No Other Bonds: Compliance with Redevelopment Plan Limits. Between the date of this Purchase Contract and the date of Closing, the Successor Agency will not, without the prior written consent of the Underwriter, and except as disclosed in the Official Statement, offer or issue any bonds, notes or other obligations for borrowed money, or incur any material liabilities, direct or contingent, secured by tax increment generated in the Merged Project Area. The total obligations of the Successor Agency heretofore incurred and all payments thereon over the life of the Redevelopment Plan have been computed by the Successor Agency and will not exceed any applicable limit on tax increment revenues received by the Successor Agency over the life of the Redevelopment Plan or any constituent component as set forth therein, (b) the total bonded indebtedness of the Successor Agency outstanding and secured by the Tax Revenues as of the date hereof does not exceed any applicable limit thereon set forth in the Redevelopment Plan, and (c) except as disclosed in the Official Statement, the Successor Agency is entitled to receive Tax Revenues under the Redevelopment Plan for a term longer than the final maturity of the Bonds. (n) Certificates. Any certificate signed by any authorized officer of the Successor Agency and delivered to the Underwriter in connection with the issuance of the Bonds shall be deemed to be a representation and warranty by the Successor Agency to the Underwriter as to the statements made therein. (o) Compliance With the Redevelopment Law As of the time of acceptance hereof and as of the date of the Closing, except as otherwise disclosed in the Official Statement, the Successor Agency has complied with all material provisions of the Law. (p) Compliance With Continuing Disclosure Except as described in the Official Statement, the Successor Agency has not defaulted under any prior continuing disclosure undertaking pursuant to Rule 15c2 -12 over the past five years. (q) Oversight Board Approval The Oversight Board has duly adopted the Oversight Board Resolution approving the issuance of the Bonds and no further Oversight Board approval or consent is required for the issuing of the Bonds or the consummation of the transactions described in the Preliminary Official Statement. (r) Department of Finance of the State Final and Conclusive Determination Letter The Department of Finance of the State (the "Department of Finance ") has issued a Final and Conclusive Determination Letter (the "Final and Conclusive Determination Letter ") approving the issuance of the Bonds and the payment of debt service on the Bonds and no further Department of Finance approval or consent is required for the issuance of the Bonds or the consummation of the transactions described in the Preliminary Official Statement, and except as disclosed in the Preliminary Official Statement, the Successor Agency is not aware of the Department of Finance directing or having any basis to direct the County Auditor - Controller to deduct unpaid unencumbered funds from future allocations of property tax 22304696.1 to the Successor Agency pursuant to Section 34183 of the Health and Safety Code of the State of California. 7. Closing Conditions. The Underwriter has entered into this Purchase Contract in reliance upon the representations, warranties and covenants herein and the performance by the Successor Agency of its obligations hereunder, both as of the date hereof and as of the date of the Closing. The Underwriter's obligations under this Purchase Contract are and shall be subject to the following additional conditions: (a) Bring-Down Representation. The representations, warranties and covenants of the Successor Agency contained herein shall be true and correct at the date hereof and at the time of the Closing, as if made on the date of the Closing. (b) Executed Agreements and Performance Thereunder At the time of the Closing: (i) the Successor Agency Documents shall be in full force and effect, and shall not have been amended, modified or supplemented except with the consent of the Underwriter; (ii) there shall be in full force and effect such resolutions as, in the opinion of Jones Hall, A Professional Law Corporation (`Bond Counsel "), shall be necessary in connection with the transactions on the part of the Successor Agency contemplated by this Purchase Contract, the Official Statement, and the other Successor Agency Documents; (iii) the Successor Agency shall perform or have performed its obligations required or specified in the Successor Agency Documents to be performed at or prior to Closing; and (iv) the Official Statement shall not have been supplemented or amended, except pursuant to Paragraph 7(e) or as otherwise may have been agreed to in writing by the Underwriter. (c) No Default. At the time of the Closing, no default shall have occurred or be existing under this Purchase Contract, the Agency Resolution, or the other Successor Agency Documents and the Successor Agency shall not be in default in the payment of principal or interest on any of its bonded indebtedness which default shall adversely impact the ability of the Successor Agency to make payments on the Bonds. (d) Termination Events. The Underwriter shall have the right to terminate this Purchase Contract, without liability therefor, by written notification to the Successor Agency if at any time at or prior to the Closing: (i) any event shall occur which causes any statement contained in the Official Statement to be materially misleading or results in a failure of the Official Statement to state a material fact necessary to make the statements in the Official Statement, in the light of the circumstances under which they were made, not misleading; or (ii) the marketability of the Bonds or the market price thereof, in the opinion of the Underwriter, has been materially adversely affected by an amendment to the Constitution of the United States or by any legislation in or by the Congress of the United States or by the State, or the amendment of legislation pending as of the date of this Purchase Contract in the Congress of the United States, or the recommendation to Congress or endorsement for passage (by press release, other form of notice or otherwise) of legislation by the President of the United States, the Treasury Department of the United States, the Internal Revenue Service or the Chairman or ranking minority member of the 22304696.1 7 Committee on Finance of the United States Senate or the Committee on Ways and Means of the United States House of Representatives, or the proposal for consideration of legislation by either such Committee, or the presentment of legislation for consideration as an option by either such Committee, or by the staff of the Joint Committee on Taxation of the Congress of the United States, or the favorable reporting for passage of legislation to either House of the Congress of the United States by a Committee of such House to which such legislation has been referred for consideration, or any decision of any Federal or state court or any ruling or regulation (final, temporary or proposed) or official statement on behalf of the United States Treasury Department, the Internal Revenue Service or other Federal or State authority materially adversely affecting the Federal or State tax status of the Successor Agency, or the interest on bonds or notes or obligations of the general character of the Bonds; or (iii) any legislation, ordinance, rule or regulation shall be introduced in, or be enacted by any governmental body, department or agency of the State or a decision by any court of competent jurisdiction within the State or any court of the United States shall be rendered which, in the reasonable opinion of the Underwriter, materially adversely affects the market price of the Bonds; or (iv) legislation shall be enacted by the Congress of the United States, or a decision by a court of the United States shall be rendered, or 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 Bonds, or the issuance, offering or sale of the Bonds, including all underlying obligations, as contemplated hereby or by the Official Statement, is in violation or would be in violation of, or that obligations of the general character of the Bonds, or the Bonds, are not exempt from registration under, any provision of the federal securities laws, including the Securities Act of 1933, as amended and as then in effect, or that the Indenture need to be qualified under the Trust Indenture Act of 1939, as amended and as then in effect; or (v) 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 which restrictions materially adversely affect the Underwriter's ability to market the Bonds; or (vi) a general banking moratorium shall have been established by federal or State authorities; or (vii) the United States has become engaged in hostilities which have resulted in a declaration of war or a national emergency or there has occurred any other outbreak of hostilities or a national or international calamity or crisis, financial or otherwise, the effect of such outbreak, calamity or crisis on the financial markets of the United States, being such as, in the reasonable opinion of the Underwriter, would affect materially and adversely the ability of the Underwriter to market the Bonds; or (viii) the commencement of any action, suit or proceeding described in Paragraph 7(h) hereof which, in the judgment of the Underwriter, materially adversely affects the market price of the Bonds; or (ix) there shall be in force a general suspension of trading on the New York Stock Exchange; or (x) as a result of actions by the Successor Agency or the State of California the market for the Bonds or the market prices of the Bonds or the ability of the Underwriter to enforce 22304696.1 contracts for the sale of the Bonds shall have been materially and adversely affected, in the reasonable professional judgment of the Underwriter; or (xi) an event described in paragraph (e) of Section 7 hereof shall have occurred which, in the reasonable professional judgment of the Underwriter, requires the preparation and publication of a supplement or amendment to either of the Official Statement; or (xii) any rating or credit outlook of the Bonds or other obligations of the Successor Agency by a national rating agency shall have been withdrawn or downgraded. (e) Closing_ Documents. At or prior to the Closing, the Underwriter shall receive with respect to the Bonds (unless the context otherwise indicates) the following documents: (1) Bond Opinion. The approving opinions of Bond Counsel dated the date of the Closing and substantially in the forms included as APPENDIX F to the Official Statement, together with a letter from such counsel, dated the date of the Closing and addressed to the Underwriter, to the effect that the foregoing opinions may be relied upon by the Underwriter to the same extent as if such opinions were addressed to them. (2) Supplemental Opinion. A supplemental opinion or opinions of Bond Counsel addressed to the Underwriter, substantially to the following effect: (a) the statements and information contained in the Official Statement on the cover page and under the captions "THE BONDS" (except for the information under the captions "Book Entry System "), "SECURITY FOR THE BONDS" and "OTHER INFORMATION — Tax Matters," excluding any material that may be treated as included under such captions by cross - reference, insofar as such statements expressly summarize certain provisions of the Indenture, and the form and content of the Bond Opinion, are accurate in all material respects; (b) the Bonds are exempt from registration under the Securities Act of 1933, as amended (the "1933 Act "), and the Indenture is exempt from qualification as an indenture pursuant to the Trust Indenture Act of 1939, as amended; and (c) the Purchase Contract has been duly authorized, executed and delivered by the Successor Agency and constitutes a valid and binding agreement of the Successor Agency (subject to customary exceptions). (3) Successor Agency Counsel Opinion. An opinion of Burke, Williams & Sorenson, LLP, counsel to the Successor Agency, dated as of the Closing and addressed to the Underwriter, in form and substance acceptable to Bond Counsel and the Underwriter, to the following effect: (a) The Successor Agency is a public body, corporate and politic, duly organized and validly existing under the laws of the State; (b) The Successor Agency Documents have been duly authorized, executed and delivered by the Successor Agency and, assuming due authorization, execution and delivery by the other parties thereto, constitute the valid, legal and binding obligations of the Successor Agency enforceable in accordance with their respective terms; 22304696.1 (c) The Agency Resolution has been duly adopted at meetings of the governing body of the Successor Agency, each of which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout, and the Agency Resolution is in full force and effect and has not been modified, amended or rescinded; (d) To the best of such counsel's current actual knowledge, the execution and delivery of the Successor Agency Documents and the Official Statement and compliance with the provisions of the Successor Agency Documents, under the circumstances contemplated thereby, does not and will not in any material respect conflict with or constitute on the part of the Successor Agency a breach of or default (with due notice or the passage of time or both) under (a) any material agreement or other instrument to which the Successor Agency is a party or by which it is bound, (b) any applicable California or federal statutory law or administrative rule or regulation known to such counsel, or (c) any applicable court order or consent decree to which the Successor Agency is subject; (e) The Official Statement have been duly approved by the governing body of the Successor Agency and executed on its behalf by an authorized officer of the Successor Agency; (f) To the best of such counsel's actual knowledge, no additional authorization, approval, consent, waiver or any other action by any person, board or body, public or private, not previously obtained is required as of the date of the Closing for the Successor Agency to enter into the Successor Agency Documents or to perform its obligations under the Successor Agency Documents except as have been obtained or made and as are in full force and effect; (g) Except as otherwise disclosed in the Official Statement, to the best of such counsel's knowledge, there is no litigation, proceeding, action, suit, or investigation at law or in equity before or by any court, governmental agency or body, pending against the Successor Agency, challenging the creation, organization or existence of the Successor Agency, or the validity of the Bonds or the Successor Agency Documents or seeking to restrain or enjoin the repayment of the Bonds or in any way contesting or affecting the validity of the Bonds or the Successor Agency Documents or any of the transactions referred to therein or contemplated thereby or contesting the authority of the Successor Agency to enter into or perform its obligations under any of the Bonds or the Successor Agency Documents, or which, in any manner, questions the right of the Successor Agency to issue the Bonds or to use the Tax Revenues for repayment of the Bonds or affects in any manner the right or ability of the Successor Agency to enter into the Bonds or to collect or pledge the Tax Revenues for repayment of the Bonds, which, if determined adversely to the Successor Agency, would have a material and adverse effect upon the consummation of the transactions contemplated by or the validity of the Bonds, the Official Statement or the Successor Agency Documents (in rendering such opinion counsel may rely solely upon the representations made to us in Officer's Certificates and on information provided by the Successor Agency as to the existence or non- existence of any pending or threatened litigation, proceeding, action, suit, or investigation, which it has no reason to believe are incorrect).; and (h) Based upon the information made available to such counsel in the course of its participation in the preparation of the Official Statement, and without 22304696.1 10 having undertaken to determine independently or assuming any responsibility for the accuracy, completeness or fairness of the statements contained in the Official Statement, nothing has come to the attention of the lawyers in such firm rendering professional services in connection with the issuance of the Bonds that would lead them to believe that the statements and information contained in the Official Statement relating to the Successor Agency and the Merged Project Area contained under the following headings: "INTRODUCTION," "THE SUCCESSOR AGENCY" and "THE PROJECT AREA" (excluding therefrom: (a) the financial statements or information (including pro forma information), or any financial, statistical, economic, engineering or demographic data or forecasts, numbers, charts, tables, graphs, estimates, projections, assumptions or expressions of opinion contained in the Official Statement; and (b) any statements and information relating to The Depository Trust Company and Appendices, as to which we express no opinion) as of the date of the Official Statement or as of the date hereof, contained or contains any untrue statement of a material fact or omitted or omits to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading. (4) Trustee Counsel Opinion. The opinion of counsel to the Trustee, dated the date of the Closing, addressed to the Successor Agency and the Underwriter, in form and substance acceptable to the Underwriter substantially to the following effect: (a) The Trustee is a national banking association duly organized and validly existing under the laws of the United States. (b) The Trustee has duly authorized the execution and delivery of the Indenture and the Continuing Disclosure Certificate. (c) The Indenture and the Continuing Disclosure Certificate have been duly entered into and delivered by the Trustee and assuming due, valid and binding authorization, execution and delivery by the other parties thereto, constitute the legal, valid and binding obligations of the Trustee enforceable against the Trustee in accordance with their respective terms, except as the enforceability thereof may be limited by applicable bankruptcy, insolvency or other similar laws affecting the enforcement of creditors' rights generally, or by general principles of equity. (5) Disclosure Counsel Opinion. An opinion, dated the date of the Closing addressed to the Successor Agency and the Underwriter, of Orrick, Herrington & Sutcliff LLP, disclosure counsel, to the effect that based upon their participation in the preparation of the Official Statement as Disclosure Counsel to the Successor Agency and without having undertaken to determine independently the accuracy or completeness of the contents in the Official Statement, such counsel has no reason to believe that the Official Statement, as of their date and as of the Closing Date (except for the financial statements and the other financial and statistical data included therein and the information included therein relating to The Depository Trust Company and the book -entry system (as such terms are defined in the Official Statement), and in the Appendices thereto as to all of which no opinion or belief need be expressed) contained or contains any untrue statement of a material fact or omitted or omits to state any material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. 22304696.1 11 (6) Successor Agency Certificate. A certificate of the Successor Agency, dated the date of the Closing, signed on behalf of the Successor Agency by the Executive Director or Chairman or other duly authorized officer of the Successor Agency to the effect that: (a) The representations, warranties and covenants of the Successor Agency contained herein and in the Successor Agency Documents are true and correct in all material respects on and as of the date of the Closing as if made on the date of the Closing and the Successor Agency has complied with all of the terms and conditions of this Purchase Contract required to be complied with by the Successor Agency at or prior to the date of the Closing; (b) No event affecting the Successor Agency has occurred since the date of the Official Statement which has not been disclosed therein or in any supplement or amendment thereto which event should be disclosed in the Official Statement in order to make the statements therein, in the light of the circumstances under which they were made, not misleading; and (c) No further consent is required to be obtained for the inclusion of the Successor Agency's audited financial statements, including the accompanying accountant's letter, for Fiscal Year 2014 -15 in the Official Statement. (7) Trustee's Certificate. A Certificate of the Trustee, dated the date of Closing, addressed to the Successor Agency and the Underwriter, in form and substance acceptable to Bond Counsel and the Underwriter to the following effect: (a) The Trustee is duly organized and existing as a national banking association in good standing under the laws of the United States, having the full power and authority to accept and perform its duties under the Indenture and the Continuing Disclosure Certificate; (b) Subject to the provisions of the Indenture, the Trustee will apply the proceeds from the Bonds to the purposes specified in the Indenture; and (c) The Trustee has duly authorized and executed the Indenture and the Continuing Disclosure Certificate. (8) Transcripts. Two transcripts of all proceedings relating to the authorization and issuance of the Bonds. (9) Official Statement. The Official Statement and each supplement or amendment, if any, thereto, executed on behalf of the Successor Agency by a duly authorized officer of the Successor Agency. (10) Documents. An original executed copy of each of the Successor Agency Documents. (11) Successor Agency Resolution A copy, certified by the Clerk of the Commission of the Successor Agency, of the Agency Resolution, approving the issuance of the Bonds by the Successor Agency. 22304696.1 12 (12) Oversight Board Resolution A copy, certified by the Clerk to the Oversight Board, of Oversight Board Resolution approving the issuance of the Bonds by the Successor Agency; (13) IRS Form 8038 -G. Evidence that the federal tax information form 8038- ( for the Bonds has been prepared for filing. (14) Nonarbitrage Certificate. An arbitrage certificate in form satisfactory to Bond Counsel. (15) Ratings. Evidence of ratings on the Bonds. (16) Bond Insurance/Reserve Policy. The municipal bond insurance policy insuring the payment of principal and interest with respect to certain of the Bonds (the "Insurance Policy "), issued by (the "Insurer "); the Reserve Policy issued by the Insurer; an opinion of counsel to the Insurer, dated the date of Closing, addressed to the Successor Agency, the Trustee and the Underwriter, regarding the Insurer's valid existence, power and authority, the Insurer's due authorization and issuance of the Insurance Policy and the Reserve Policy and the enforceability of the Insurance Policy and the Reserve Policy against the Insurer; and a certificate of the Insurer or an opinion of counsel to the Bond Insurer, dated the date of Closing, regarding the accuracy of the information in the Official Statement describing the Insurer, the Insurance Policy, and the Reserve Policy. (17) CDIAC Statement. A copy of the Notices of Sale required to be delivered to the California Debt and Investment Advisory Commission pursuant to Section 53583 of the Government Code and Section 8855(g) of the Government Code. (18) Closing Certificate of Fiscal Consultant A certificate of Urban Futures, Inc., dated the Closing, certifying that as of the date of the Official Statement and as of the Closing Date, the statements contained in the Official Statement insofar as such statements purport to summarize their report included in the Official Statement are true and correct in all material respects, and did not and do not contain any untrue statement of a material fact or omit to state any material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading, and consenting to the use of their report as APPENDIX A to the Preliminary Official Statement and the Official Statement and all references to their report in the Preliminary Official Statement and the Official Statement. (19) Additional Documents. Such additional certificates, instruments and other documents as the Underwriter may reasonably deem necessary. If the Successor Agency shall be unable to satisfy the conditions contained in this Purchase Contract, or if the obligations of the Underwriter shall be terminated for any reason permitted by this Purchase Contract, this Purchase Contract may be terminated by the Underwriter by written notice to the Successor Agency, and neither the Underwriter or the Successor Agency shall be under further obligation hereunder. 8. Expenses. The Underwriter shall be under no obligation to pay, and the Successor Agency shall pay or cause to be paid, the expenses incident to the performance of the obligations of the Successor Agency hereunder including but not limited to: 22304696.1 13 (a) the costs of the preparation and printing, or other reproduction (for distribution on or prior to the date hereof) of the Successor Agency Documents and the cost of preparing, printing, issuing and delivering the Bonds; (b) the fees and disbursements of any counsel, financial advisors, accountants or other experts or consultants retained by the Successor Agency; (c) the fees and disbursements of Bond Counsel and Disclosure Counsel; (d) the cost of preparation and printing the Preliminary Official Statement and any supplements and amendments thereto and the cost of preparation and printing of the Official Statement, including a reasonable number of copies thereof for distribution by the Underwriter; (e) charges of rating agencies for the rating of the Bonds; (f) the cost of preparation of this Purchase Contract; and (g) any out -of- pocket disbursements of the Successor Agency incurred in connection with the public offering and distribution of the Bonds. Whether or not the Bonds are delivered to the Underwriter as set forth herein, the Successor Agency shall be under no obligation to pay, and the Underwriter shall pay, all expenses incurred by the Underwriter in connection with its public offering and distribution of the Bonds (except those specifically enumerated in paragraphs (a) through (g) above), including the fees and disbursements of its counsel and any advertising expenses. 9. Notice. Any notice or other communication to be given to the Underwriter may be given by delivering the same to Stifel, Nicolaus & Company, Incorporated, 515 S. Figueroa Street, Suite 1800, Los Angeles, California 90071, Attention: John Kim. Any notice or other communication to be given to the Successor Agency pursuant to this Purchase Contract may be given by delivering the same in writing to such entity, at the addresses set forth on the cover page hereof; provided, however, that all such notices, requests or other communications may be made by telephone and promptly confirmed by writing. The Successor Agency and Underwriter may, by notice given as aforesaid, specify a different address for any such notices, requests or other communications. 10. Entire Agreement. This Purchase Contract, when accepted by the Successor Agency, shall constitute the entire agreement among the Successor Agency and the Underwriter and is made solely for the benefit of the Successor Agency and the Underwriter (including the successors or assigns of any Underwriter, subject to Section 14 below). No other person shall acquire or have any right hereunder by virtue hereof, except as provided herein. All the Successor Agency's representations, warranties and agreements in this Purchase Contract shall remain operative and in full force and effect, regardless of any investigation made by or on behalf of the Underwriter, until the earlier of (a) delivery of and payment for the Bonds hereunder, and (b) any termination of this Purchase Contract. 11. Counterparts. This Purchase Contract may be executed by the parties hereto in separate counterparts, each of which when so executed and delivered shall be an original, but all such counterparts shall together constitute but one and the same instrument. 12. Severability. In case any one or more of the provisions contained herein shall for any reason be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provision hereof. 22304696.1 14 13. State of California Law Governs. The validity, interpretation and performance of this Purchase Contract shall be governed by the laws of the State applicable to contracts made and performed in the State. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] 22304696.1 15 14. No Assignment. The rights and obligations created by this Purchase Contract shall not be subject to assignment by the Underwriter or the Successor Agency without the prior written consent of the other parties hereto. STIFEL, NICOLAUS & COMPANY, INCORPORATED, as Underwriter Title: Authorized Signatory Accepted as of the date first stated above: SUCCESSOR AGENCY TO THE ROSEMEAD COMMUNITY DEVELOPMENT COMMISSION Executive Director Time of Execution: 22304696.1 EXHIBIT A Maturity Date Principal Interest (December 1) Amount Rate Yield 22304696.1 A -1