STAFF REPORT

Operations Committee, August 7, 2008

Installment Purchase Contract Resolution (FN09-01)
Consideration of a resolution to enter into a lease purchase contract with RBC Bank to finance the purchase of two fire trucks

Speaker:  Ms. Karen Mills
 

From:  Karen A. Mills, Finance Director
Prepared by:  Pat Liguori, Deputy Treasurer
Approved by:  William B. Coleman, Jr., Town Manager
Approved by:  Benjamin T. Shivar, Assistant Town Manager

 

REVIEW:  A service ladder truck replacement and an aerial service ladder truck in the existing capital budget were included for a total of $1,554,000.  These trucks have been received and final equipment for these trucks should be in place by September 1.  Both of these trucks were budgeted to be funded with installment financing through lease purchase agreements.  A request for proposal to provide financing for the fire trucks was issued to ten institutions.  Eight institutions responded.  The request specified the Town’s interest in a financing contract with a ten-year or fifteen-year term at a fixed rate of interest.  A summary of the proposal results is as follows:

 

 

Bidder

 

10 Year

Interest Rate

Fixed

 

10 Year

Estimated Total

Financing  Cost (a)

 

15 Year

Interest Rate Fixed

 

15 Year

Estimated Total

Financing Cost (a)

RBC Bank

3.560%

$247,492

3.890%

$418,608

BB&T

3.670%

255,406

3.810%

409,250

Bank of America

3.553%

268,938

n/a

n/a

Wachovia Bank

3.930%

274,265

4.420%

310,429

Sun Trust Leasing

4.000%

279,213

4.270%

462,512

First-Citizens Bank

3.990%

279,495

n/a

n/a

Koch Financial       

4.730%

333,314

5.000%

549,141

Fifth Third Bank (b)

n/a

n/a

n/a

n/a

 

(a)    estimated total cost includes total projected interest plus other fees, such as

attorney fees and documentation fees as provided in the response to the RFP

(b)    Fifth Third Bank provided a response based on a balloon repayment term that was

not requested in the RFP and was not beneficial to the Town

 

Both 10 and 15 year financings were requested in the bid to evaluate the necessity of a 15 year repayment in case the 10 year financing repayment exceeded budget.   RBC Bank proposed the lowest total estimated financing cost of $247,492 for a 10 year repayment term that is within budgeted debt service for this purpose.  RBC Bank requires Council approval of a resolution that authorizes the Town to enter into a lease with RBC Bank and that authorizes certain Town officials to execute the necessary documents.  The proposed resolution is attached.   The resolution refers to the contract (pdf) documents which are also attached.

 

Fiscal Impact:   Annual debt service is estimated to be $156,239 per year for ten years.  The forecasted debt service on the fire trucks was included in the committed debt service budget for $170,299 in the General Fund as discussed in FY 2009 budget worksessions and included in the FY 2009 proposed and adopted budget. 

 

Staff Recommendation:  Staff recommends that Council accept the RBC Bank proposal for a ten-year term installment purchase agreement at a fixed rate of 3.56% and approve the attached resolution.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

RESOLUTION AUTHORIZING THE EXECUTION AND DELIVERY OF AN INSTALLMENT FINANCING CONTRACT, AN ESCROW DEPOSIT AGREEMENT AND RELATED DOCUMENTS IN CONNECTION WITH THE FINANCING OF EQUIPMENT FOR THE TOWN

BE IT RESOLVED by the Town Council (the “Town Council”) of the Town of Cary, North Carolina (the “Town”) as follows:

Section 1.  The Town Council does hereby find and determine as follows:

(a) There exists in the Town a need for the acquisition of an aerial fire truck and fire rescue truck for use by the Town in carrying out its governmental functions (collectively, the “Equipment”).

(b) The Town has solicited proposals from banks and other financial institutions to provide the financing for such Equipment and, upon careful review and consideration of the proposals submitted by banks to provide such financing, the Town desires to accept the proposal of RBC Bank (USA) (the “Lender”).

(c) The Town Council has determined that the most efficient manner of financing the Equipment will be through the entering of an Installment Financing Contract (the “Contract”) with the Lender pursuant Section 160A-20 of the General Statutes of North Carolina, as amended.  Pursuant to the Contract, the Lender will advance moneys to the Town in an amount sufficient to pay the cost of the Equipment, and the Town will repay the advancement in installments, with interest (the “Installment Payments”).

(d) In order to secure the repayment pursuant to the terms of the Contract by the Town of the advance of moneys for acquisition of the Equipment, the Town will grant to the Lender a security interest in the Equipment pursuant to the Contract.

(e)  In order to provide for the operation of the Escrow Account (as defined in the Contract), into which the advancement will be deposited, the Town will enter into an Escrow Deposit Agreement (the “Escrow Deposit Agreement”) with the Lender.

(f) There has been presented to the Town Council at this meeting drafts of the Contract and the Escrow Deposit Agreement.

Section 2.  The proposal of the Lender to provide financing through the Contract for the purpose of providing funds to pay the cost of the Equipment is hereby accepted, subject to further approval of the particular documentation related thereto by the Town Council, and all actions of the Town Manager, Assistant Town Manager and the Finance Director of the Town accepting the proposal of the Lender are hereby ratified, authorized and approved.

Section 3.  In order to provide for the financing of the Equipment, the Town is hereby authorized to enter into the Contract and receive an advancement pursuant thereto in a principal amount not to exceed $1,315,000.  The Town shall repay the advancement in installments due in the amounts and at the times set forth in the Contract.  The payments of the installment payments shall be designated as principal and interest as provided in the Contract.

Section 4.  The Town Council hereby approves the Contract and the Escrow Deposit Agreement in substantially the forms presented at this meeting.  The Mayor, the Town Manager, the Assistant Town Manager and the Finance Director of the Town are each hereby authorized to execute and deliver on behalf of the Town said documents in substantially the forms presented at this meeting, containing such insertions, deletions and filling in of blanks as the person executing such documents shall approve, such execution to be conclusive evidence of approval by the Town Council of any such changes.  The Town Clerk or any Deputy or Assistant Town Clerk of the Town is hereby authorized and directed to affix the official seal of the Town to said documents and to attest the same.

Section 5.  No deficiency judgment may be rendered against the Town in any action for breach of any contractual obligation authorized pursuant to this resolution and the taxing power of the Town is not and may not be pledged directly or indirectly to secure any moneys due under any contract herein authorized.

Section 6.  The Mayor, the Town Manager, the Assistant Town Manager, the Finance Director and the Town Clerk of the Town, and any other officers, agents and employees of the Town, are hereby authorized and directed to execute and deliver such closing certificates, opinions and other items of evidence as shall be deemed necessary to consummate the transactions described above.

Section 7.  The Town hereby represents that it reasonably expects that it, all subordinate entities thereof and all issuers issuing obligations on behalf of the Town will not issue in the aggregate more than $10,000,000 of tax-exempt obligations (not counting private-activity bonds except for qualified 501(c)(3) bonds as defined in the Code) during calendar year 2008.  In addition, the Town hereby designates each of the installment payments under the Agreement as a “qualified tax-exempt obligation” for the purposes of the Code.

Section 8.  This resolution shall take effect immediately upon its passage.


 

 

                                                                                                                                                                                  

INSTALLMENT FINANCING CONTRACT

$1,315,000.00

between

RBC BANK (USA)
as the Lender

and

Town of Cary
as the
 MERGEFIELD City_or_County Town

Dated:  August ____, 2008

                                                                                                                                                                                  

 

TABLE OF CONTENTS

 TOC \o "1-1" \t "Heading 1,1" SECTION 1.  DEFINITIONS................................................................................................................................... PAGEREF _Toc32041765 \h 6

SECTION 2.  ADVANCE OF LOAN AMOUNT....................................................................................................... PAGEREF _Toc32041766 \h 7

SECTION 3.  INSTALLMENT PAYMENTS AND OTHER PAYMENTS.................................................................. PAGEREF _Toc32041767 \h 7

SECTION 4.  NATURE OF CONTRACT............................................................................................................... PAGEREF _Toc32041768 \h 8

SECTION 5.  RESPONSIBILITIES AND COVENANTS OF THE  MERGEFIELD CITY_OR_COUNTY1 TOWN.............................................................. PAGEREF _Toc32041769 \h 8

SECTION 6.  SECURITY INTEREST; LIENS...................................................................................................... PAGEREF _Toc32041770 \h 11

SECTION 7.  INSURANCE AND UNFORESEEN LOSSES................................................................................ PAGEREF _Toc32041771 \h 11

SECTION 8.  WARRANTIES AND REPRESENTATIONS OF THE  MERGEFIELD CITY_OR_COUNTY1 TOWN....................................................... PAGEREF _Toc32041772 \h 12

SECTION 9.  INDEMNIFICATION......................................................................................................................... PAGEREF _Toc32041773 \h 13

SECTION 10.  DISCLAIMER OF WARRANTIES................................................................................................ PAGEREF _Toc32041774 \h 13

SECTION 11.  DEFAULT AND REMEDIES......................................................................................................... PAGEREF _Toc32041775 \h 13

SECTION 12.  ASSIGNMENT.............................................................................................................................. PAGEREF _Toc32041776 \h 14

SECTION 13.  LIMITED OBLIGATION OF THE  MERGEFIELD CITY_OR_COUNTY1 TOWN...................................................................................... PAGEREF _Toc32041777 \h 15

SECTION 14.  TAX‑EXEMPT INTEREST............................................................................................................ PAGEREF _Toc32041778 \h 16

SECTION 15.  MISCELLANEOUS....................................................................................................................... PAGEREF _Toc32041779 \h 17

 


 

INSTALLMENT FINANCING CONTRACT

EQUIPMENT

THIS INSTALLMENT FINANCING CONTRACT, dated as of August _____, 2008  (the "Contract"), by and between RBC BANK (USA), a North Carolina banking corporation (the "Bank"); and TOWN OF CARY, a body politic and corporate of the State of North Carolina (the "Town");

                                                                         W I T N E S S E T H:

WHEREAS, the Town is a duly and validly created, organized and existing public body politic, duly created and existing under and by virtue of the Constitution and laws of the State of North Carolina; and

WHEREAS, the Town has the power, pursuant to Section 160A‑20 of the General Statutes of North Carolina, to enter into installment contracts to finance the purchase of personal property, including property to be affixed or attached to real estate as fixtures; and

WHEREAS, the Bank desires to advance certain funds to enable the Town to finance the purchase and installation of the Equipment (as hereinafter defined); and

WHEREAS, the Town desires to obtain such advance from the Bank and to purchase and install the Equipment pursuant to the terms and conditions hereinafter set forth; and

WHEREAS, the obligation of the Town to make Installment Payments (as hereinafter defined) and other payments required under Section 3 hereof shall constitute a limited obligation payable solely from currently budgeted appropriations of the Town and shall not constitute a pledge of the faith and credit of the Town within the meaning of any constitutional debt limitation or as otherwise prohibited by the North Carolina Constitution; and

WHEREAS, no deficiency judgment may be rendered against the Town in any action for breach of a contractual obligation under this Contract, and the taxing power of the Town is not and may not be pledged in any way, directly or indirectly or contingently, to secure any moneys due under this Contract; and

WHEREAS, the Bank and the Town each have duly authorized the execution and delivery of this Contract.

NOW, THEREFORE, for and in consideration of the premises and of the covenants hereinafter contained, and other valuable consideration, the parties hereto agree as follows:

SECTION 1.            DEFINITIONS

For purposes of this Contract, the following definitions will apply:

1.1.           "Equipment" means all of the property described in Exhibit A attached hereto, including any Equipment to be affixed to or attached to real estate as fixtures.

1.2.           "Escrow Deposit Agreement" means the Escrow Deposit Agreement dated as of August _____, 2008 by and between the Town and the Bank pursuant to which the Bank agrees to hold the Escrow Funds on behalf of Town and to advance such Escrow Funds in accordance with the terms thereof.

1.3.           "Escrow Fund" means the funds deposited by the Town with the Bank pursuant to the terms of the Escrow Deposit Agreement.

1.4.           "Installment Payments" means those payments made by the Town to the Bank as described in Section 3 of this Contract and in the Payment Schedule.

1.5.           "Loan Amount" means the amount described in Exhibit B hereto which will be advanced by the Bank to enable the Town to finance the purchase and construction, installation or repair of the Equipment, under the terms of this Contract.

1.6.           "Net Proceeds," when used with respect to any proceeds from policies of insurance required hereunder or proceeds of any condemnation award arising out of the condemnation of all or any portion of the Equipment, means the amount remaining after deducting from the gross proceeds thereof all expenses (including, without limitation, attorneys' fees and costs) incurred in the collection of such proceeds.

1.7.           "Payment Schedule" means the document labeled "Payment Schedule" attached hereto as Exhibit B and incorporated herein by reference, which describes the Town's Installment Payments.

1.8.           "Prime Rate" means the Bank's prime rate, which is one of the Bank's variable rate indices for credit extensions and is set by the Bank at its discretion based on the Bank's perception of market interest rate levels, trends and general economic conditions.  It is not tied to any specific index published by any third party and is not represented by the Bank to be the lowest rate at which the Bank extends credit.

SECTION 2.            ADVANCE OF LOAN AMOUNT

The Bank agrees to advance the Loan Amount to the Town and the Town agrees to borrow the Loan Amount from the Bank to be applied in accordance with the terms and conditions of this Contract.  The proceeds of the Loan Amount shall be used to purchase and to install, construct or repair the Equipment.  The advance by the Bank shall be made by the deposit by the Bank to the Escrow Fund of the Loan Amount.  The Loan Amount may be invested pending disbursement, and shall be disbursed to acquire and to install, construct or repair the Equipment in accordance with the Escrow Deposit Agreement.  The Town shall pay any additional sums necessary to purchase and install, construct or repair the Equipment and shall provide evidence of the payment of such additional sums to the Bank upon request.

SECTION 3.            INSTALLMENT PAYMENTS AND OTHER PAYMENTS

3.1.           Amounts and Times of Installment Payments and Other Payments.  Subject to the provisions of Section 13 hereof entitled "Limited Obligation of the Town," the Town shall repay the Loan Amount in installments as provided in Exhibit B to this Contract.  Each installment shall be deemed to be an Installment Payment and shall be paid in the amounts and at the times set forth in the Payment Schedule except as provided herein.  Installment Payments shall be sufficient in the aggregate to repay the Loan Amount together with interest thereon at a per annum rate equal to the rate per annum described in Exhibit B hereto.  A portion of each Installment Payment is interest.

Interest on the Loan Amount as set forth on Exhibit B is based upon a 360-day year, with twelve (12) thirty (30) day months.  The amortization schedule is based on all payments being received by the Bank on the scheduled due date.  The Bank reserves the right to increase the initial payment to reflect any additional interest accruing prior to the end of the initial interest period.

3.2.           Place of Payments.  All payments required to be made to the Bank hereunder shall be made at the Bank's principal office or as may be otherwise directed by the Bank or its assignee.

3.3.           Late Charges.  Should the Town fail to pay any Installment Payment or any other sum required to be paid to the Bank within fifteen (15) days after the due date thereof, the Town shall pay a late payment charge equal to four percent (4%) of the delinquent payment.

3.4.           Abatement of Installment Payments.  Subject to Section 13 hereof entitled "Limited Obligation of the Town," there shall be no abatement or reduction of the Installment Payments or other payments by the Town for any reason, including but not limited to, any defense, recoupment, setoff, counterclaim, or any claim (real or contingent) arising out of or related to the Equipment.  The Town assumes and shall bear the entire risk of loss and damage to the Equipment from any cause whatsoever, it being the intention of the parties that the Installment Payments and other payments shall be made in all events unless the obligation to make such Installment Payments and other payments is terminated as otherwise provided herein.

3.5.           Prepayment of Installment PaymentsThe loan may not be prepaid in years one (1) through five (5).  The loan may be prepaid at any time thereafter without penalty.

SECTION 4.            NATURE OF CONTRACT

This Contract is an installment contract and security agreement pursuant to Section 160A‑20 and Article 9 of Chapter 25 (the "Uniform Commercial Code ‑ Secured Transactions") of the General Statutes of North Carolina.

SECTION 5.            RESPONSIBILITIES AND COVENANTS OF THE TOWN

5.1.           Care and Use.  The Town shall use the Equipment in a careful and proper manner, in compliance with all applicable laws and requisitions, and, at its sole cost and expense or at the cost or expense of a third party other than the Bank, shall service, repair and maintain the Equipment so as to keep the Equipment in good condition, repair, appearance and working order for the purposes intended, ordinary wear and tear excepted, and shall replace any part of the Equipment as may from time to time become worn out, lost, stolen, destroyed or damaged or is unfit for use.  Any and all additions to or replacements of the Equipment and all parts thereof shall constitute accessions to the Equipment and shall be subject to all terms and conditions of this Contract and included in the term "Equipment" as used in this Contract.  If requested by the Bank, the Town shall enter into or cause to be entered into, and maintained in full force and effect during the term of this Contract, manufacturer's or supplier's standard maintenance contracts satisfactory to the Bank covering the Equipment and shall comply with all of its obligations thereunder.  The Town shall furnish evidence to the Bank upon Bank's request of such signed maintenance contracts at or prior to the date of this Contract and the payment of all charges and premiums therefore.

5.2.           Inspection.  The Bank shall have the right upon reasonable prior notice to the Town to enter into and upon the premises where the Equipment is located to inspect the Equipment and observe its use during normal business hours.

5.3.           Alterations.  Without the prior written consent of the Bank, which consent shall not be unreasonably withheld, the Town shall not make any alterations, modifications or attachments to the Equipment which cannot be removed without materially damaging the functional capabilities or economic value of the Equipment.

5.4.           Utilities.  The Town shall pay, when due, all charges for utility services used in connection with the Equipment. There shall be no abatement of the Installment Payments on account of interruption of any such services.

5.5.           Taxes.  The Town shall pay, when due, any and all taxes levied by any governmental body as a result of the Town 's ownership, possession, or use of the Equipment or as a direct or indirect result of the purchase of the Equipment by the Town.

5.6.           Risk of Loss.  Subject to the provisions of Section 13 hereof entitled "Limited Obligation of the Town," the Town shall bear all risk of loss to and condemnation of the Equipment.  In the event of loss or damage to the Equipment, the Town shall either (a) continue to make the Installment Payments due hereunder and repair or replace the Equipment or (b) prepay in full the principal components of the outstanding Installment Payments in accordance with Section 3.5 hereof.  Said repair or replacement of the Equipment shall meet with the satisfaction of the Bank.

5.7.           Performance by the Bank of the Town's Responsibilities.  Any performance required of the Town or any payments required to be made by the Town may, if not timely performed or paid, be performed or paid by the Bank, and, in that event, the Bank shall be immediately reimbursed by the Town for such payments and for any costs and expenses, legal or otherwise, associated with the payments or other performance by the Bank, with interest thereon at a per annum rate equal to the Prime Rate in effect on the last business day of the calendar month preceding the payment (but not exceeding the maximum rate, if any, permitted by applicable law).

5.8.           Financial Statements.  The Town agrees that it will furnish the Bank current audited financial statements (as soon as practicable after the Town's acceptance thereof) and the Town's annual budget as submitted or approved, and permit the Bank or its agents and representatives to inspect the Town's books and records and make extracts therefrom at its own expense during regular business hours and in a manner which will not disrupt the normal business routine of the Town.  Town shall furnish to Bank current financial statements at such reasonable times as the Bank may request.  The Town represents and warrants to the Bank that all financial statements which have been delivered to the Bank in connection with this Contract fairly and accurately reflect the Town's financial condition and there has been no material adverse change in the Town’s financial condition as reflected in the financial statements since the date thereof.

5.9.           Other Responsibilities and Conditions.  Simultaneously with the execution of this Contract and prior to the advancement of any funds hereunder by the Bank, the Town shall cause to be provided to the Bank the following:

(a)             An Incumbency and Authorization Certificate in the form of Exhibit C attached hereto;

(b)             An Opinion Letter of counsel for the Town in the form of Exhibit D attached hereto;

(c)             A certificate in the form of Exhibit E attached hereto or other proof of insurance on the Equipment satisfactory to the Bank;

(d)             Certified copies of resolutions of the Town's governing body authorizing the Town to enter into this Contract and carry out its terms;

(e)             Properly completed UCC financing statements as required by Section 6.1 hereof sufficient in form and substance and filed in all necessary locations to perfect a first lien in the Equipment;

(f)              An Escrow Deposit Agreement in a form satisfactory to the Bank; and

(g)             If required by the Bank, an opinion letter from tax counsel, in form and substance and from an attorney satisfactory to the Bank, which states that the interest on the Town's obligations under the Contract will not be included in the gross income of the Bank for Federal and North Carolina income tax purposes, will not be an item of tax preference for purposes of the Federal alternative minimum income tax, if applicable and that such obligations are "qualified tax‑exempt obligations" within the meaning of Section 265(b)(3) of the Internal Revenue Code of 1986;

(h)             Executed originals of any other documents and instruments required by Bank in connection with this Contract.

5.10.        Special Tax Covenants.  The Town covenants that: (a) it will make no use of the monies advanced by the Bank (the "proceeds") which would cause this Contract to be an "arbitrage bond" within the meaning of Section 148 of the Internal Revenue Code of 1986, as amended (the "Code"), or the Treasury Regulations promulgated thereunder; (b) so long as the Contract remains in effect, the Town will comply with the requirements of the Code and the applicable Treasury Regulations promulgated thereunder and will not take or omit to take any action which will cause the interest paid or payable under this Contract to be includible in the gross income of the registered owner hereof; (c) the Equipment shall be used exclusively for essential governmental purposes of the Town and no use shall be made of the proceeds or of the Equipment, directly or indirectly, which would cause this Contract to be a "private activity bond" within the meaning of Section 141 of the Code; (d) no part of the payment of principal or interest under this Contract is or shall be guaranteed, in whole or in part, by the United States or any agency or instrumentality thereof; (e) no portion of the proceeds shall be used, directly or indirectly, in making loans the payment of principal or interest with respect to which are to be guaranteed, in whole or in part, by the United States or any agency or any instrumentality thereof; and (f) the Town shall not lease or otherwise make any of the Equipment available to any entity if such lease or other availability would cause the interest portion of the Installment Payments to be included in the gross income of the Bank under the Code for income tax purposes.

The Town shall furnish promptly all information necessary to permit the Bank to file on or before its due date IRS Form 8038‑G.  The Town shall not take or omit to take any action that may cause a loss of the federal, state or local tax‑exempt status of this Contract or the interest thereon.

5.11.        Appropriations of Payments.  (a) The Town reasonably believes that funds sufficient to make all Installment Payments during the Term of this Contract can be obtained.  While recognizing that it is not empowered to make any binding commitment to make Installment Payments or any other payments beyond its current fiscal year, the Governing Body of the Town in authorizing the execution of this Contract has stated its intent to make annual appropriations sufficient to make the Installment Payment and has recommended that future governing bodies continue to do so during the Term of this Contract.

(b)         The Manager shall include in the initial proposal for each of the Town's annual budgets the amount of all Installment Payments coming due during the fiscal year to which such budget is applicable.  Notwithstanding that the Manager includes an appropriation for Installment Payments in a proposed budget, the Town may terminate all its obligations hereunder by not appropriating sufficient funds to make the scheduled Installment Payments.  In the event the Governing Body determines not to appropriate in its budget an amount sufficient to pay all Installment Payments coming due in the applicable fiscal year, the Governing Body shall adopt a resolution specifically deleting such appropriation from the proposed budget for that fiscal year.  Such resolution shall state the reasons for such deletion, shall be adopted by a vote identifying those voting for and against and abstaining from the resolution, and shall be recorded in the minutes of the Governing Body.  A copy of such resolution shall be promptly sent to the Bank.  Such failure to appropriate shall constitute an Event of Default.

(c)         The Budget Officer shall deliver to the Bank, within (15) days after the beginning of each Fiscal Year, a certificate stating whether an amount equal to the Installment payments and estimated Additional Payments coming due during the next Fiscal Year has been appropriated by the Town in such budget for such purposes. If such amount has not been so appropriated, the Budget Officer shall send a copy of such certificate to the LGC, to the attention of its Secretary, at the Albermarle Building, 325 North Salisbury St., Raleigh, NC 27603-1385.

SECTION 6.            SECURITY INTEREST; LIENS

6.1.           Security Interest.  The Town hereby grants to the Bank a security interest in the Equipment and in any and all additions, accessions, repairs, replacements, substitutions, and modifications to the Equipment, and all proceeds of all the foregoing, including any insurance proceeds paid because of loss or damage to the Equipment to the extent necessary to secure the Town's payment obligations to the Bank under this Contract.  The Town shall cause to be filed, at the Town's expense, financing statements and other related documents that are necessary under Article 9 of Chapter 25 (the "Uniform Commercial Code ‑ Secured Transactions") of the General Statutes of North Carolina to perfect a first lien security interest by filing and to maintain that first lien security interest in perfected form.  If the Equipment is or includes one or more motor vehicles, the ownership of which is or are evidenced by a certificate of title(s), the Town shall cause the Bank's lien to be properly shown on such title(s) as a first lien security interest.

The Equipment is and shall throughout the term of this Contract be and remain personal property, regardless of whether the Equipment is now or may become in any manner affixed or attached to real estate or any building or fixtures on real estate.  No portion of the Equipment may be affixed or attached to real estate or any building or fixtures on real estate.  If the Equipment is permanently located on any real estate,  not owned in fee simple by the Town, or if such real estate, is subject to any liens, the Town shall obtain a waiver of any rights in and to the Equipment (including the rights of levy and distraint) from the person who gives the Town permission to use the real property on which the Equipment is located and from any holder of liens on the real estate on which the Equipment is located.

6.2.           Liens.  The Town shall not directly or indirectly create, incur, assume or suffer to exist any lien, charge, security interest, encumbrance or claim on or with respect to the Equipment (except the security interest granted to the Bank).  The Town shall promptly, at its own expense, take such action as may be necessary to duly discharge any such lien, security interest, charge, encumbrance or claim if the same shall arise at any time.  The Town shall reimburse the Bank for any expense incurred by it in order to discharge or remove any such lien, security interest, encumbrance or claim.

SECTION 7.            INSURANCE AND UNFORESEEN LOSSES

7.1.           Insurance.  The Town shall obtain and maintain, at its expense, at all times until termination of this Contract a primary policy of insurance covering the Equipment and providing the insurance protection described in this Section.  The Town shall maintain at its own expense fire, casualty, public liability, property damage and theft insurance, and such other insurance in such amounts and with such deductibles, if permitted, as required by the Bank from time to time.  The Equipment shall be insured in an amount at least equal to its replacement value.  All such insurance shall be maintained with such insurance company or companies as shall be satisfactory to the Bank and shall provide that losses shall be payable to the Bank and the Bank shall be named as an additional insured with respect to all such insurance.  The Town shall deliver to the Bank the policies of insurance or duplicates thereof or other evidence satisfactory to the Bank of such insurance coverage.  Each insurer shall agree by endorsement upon the policy or policies issued by it that (i) it will give thirty (30) days prior written notice to the Bank of the cancellation or material modification of such policy; and (ii) the coverage of the Bank shall not be terminated, reduced or affected in any manner regardless of any breach or violation by the Town of any warranties, declarations and conditions of such insurance.  The Town agrees to cooperate fully in all accident insurance investigations, claims and litigation proceedings.  The Town shall cooperate fully with the Bank in filing any proof of loss with respect to any insurance policy described above.  In no event shall the Town voluntarily settle, or consent to the settlement of, any proceeding arising out of any insurance claim with respect to the Equipment without the written consent of the Bank.

In lieu of policies of insurance written by commercial insurance companies meeting the requirements of this Section, the Town may maintain a program of self-insurance or participate in group risk financing programs, risk pools, risk retention groups, purchasing groups and captive insurance companies, and in state or federal insurance programs.

7.2.           Condemnation.  Any condemnation award paid as a result of the exercise of the power of eminent domain over the Equipment or any part thereof by any governmental body or any person or entity acting under governmental authority, which is not utilized by the Town to repair or replace the Equipment to the satisfaction of the Bank shall be paid to the Bank in accordance with Sections 3.5 and 5.6 hereof.

SECTION 8.            WARRANTIES AND REPRESENTATIONS OF THE TOWN

The Town warrants and represents to the Bank (all such representations and warranties being continuing) as follows:

(a)             The Town is a public body politic duly created and existing under the laws of the State of North Carolina as a political subdivision of the State of North Carolina, and has all powers necessary to enter into the transactions contemplated by this Contract and to carry out its obligations hereunder;

(b)             This Contract and all other documents relating hereto, have been duly and validly authorized, approved, executed and delivered by the Town, and the performance by the Town of its obligations under such documents has been approved and authorized under all laws, regulations and procedures applicable to the Town, including, but not limited to, compliance with all applicable public meeting and bidding requirements, and the transactions contemplated by this Contract and all other documents relating hereto constitute a public purpose for which public funds may be expended pursuant to the Constitution and laws of the State of North Carolina, and, assuming due authorization, execution and delivery hereof by the Bank, constitute valid, legal and binding obligations of the Town, enforceable in accordance with their respective terms, except as enforcement thereof may be limited by general principles of equity or by bankruptcy, insolvency and other laws affecting the enforcement of creditors' rights generally and as those other laws may be further limited by the provisions of Section 160A‑20 of the General Statutes of North Carolina, as amended;

(c)             No approval or consent is required from any governmental authority with respect to the entering into or performance by the Town of this Contract and the transactions contemplated hereby, or, if any such approval is required, it has been duly obtained;

(d)             There is no action, suit, proceeding or investigation at law or in equity before or by any court, public board or body pending or, to the best of the Town's knowledge, threatened, against or affecting the Town challenging the validity or enforceability of this Contract or any other documents relating hereto, or the performance of the Town's obligations hereunder, and compliance with the provisions hereof, under the circumstances contemplated hereby, does not and will not in any material respect conflict with, constitute on the part of the Town a breach of or default under, or result in the creation of a lien or other encumbrance on any property of the Town (except as contemplated herein) pursuant to any agreement or other instrument to which the Town is a party, or any existing law, regulation, court order or consent decree to which the Town is subject;

(e)             There are no liens or encumbrances on the Equipment other than the lien created by this Contract;

(f)              A resolution relating to the performance by the Town of this Contract and the transactions contemplated hereby has been duly adopted, is in full force and effect, and has not been in any respect amended, modified, revoked or rescinded;

(g)             The purchase of the Equipment is essential to the proper, efficient and economical operation of the Town and the delivery of its service and the Equipment will provide an essential use and permit the Town to carry out public functions that it is authorized by law to perform;

(h)             The security interest granted by the Town to the Bank in the Equipment shall have been duly perfected and shall constitute a first lien security interest in the Equipment; and

(i)              The Town has designated its obligation hereunder as a "qualified tax‑exempt obligation" within the meaning of Section 265(b)(3) of the Code.  The Town (i) has not, does not expect to and shall not issue, directly or indirectly through subordinate units, more than $10,000,000 of tax‑exempt obligations (other than private activity bonds) during this calendar year and (ii) has not and shall not designate during this calendar year more than $10,000,000 of its obligations (or of its subordinate units) as "qualified tax‑exempt obligations".

SECTION 9.            INDEMNIFICATION

To the extent permitted by applicable law, the Town hereby agrees to indemnify protect and save the Bank, the Escrow Agent and the members and employees of each of the foregoing harmless from all liability, obligations, losses, claims, damages, actions, suits, proceedings, costs and expenses, including attorneys fees, arising out of, connected with, or resulting directly or indirectly from the Equipment, including without limitation, the possession, condition or use thereof.  The indemnification arising under this section shall continue in full force and effect notwithstanding the payment in full of all obligations under this Contract.

SECTION 10.         DISCLAIMER OF WARRANTIES

10.1.        No Representations by the Bank.  The Town acknowledges that it has inspected the Equipment and found the Equipment to be satisfactory and acknowledges and agrees that it has selected the Equipment based upon its own judgment and disclaims any reliance upon any statements or representations made by the Bank with respect thereto.

10.2.        Disclaimer By the Bank.  THE BANK MAKES NO WARRANTIES OR REPRESENTATIONS, EXPRESS OR IMPLIED, AS TO THE CONDITION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF THE EQUIPMENT OR ANY OTHER REPRESENTATION OR WARRANTY WITH RESPECT TO THE EQUIPMENT.

SECTION 11.         DEFAULT AND REMEDIES

11.1.        Definition of Event of Default.  The Town shall be deemed to be in default hereunder upon the happening of any of the following events of default (each, an "Event of Default"):

(a)             The Town shall fail to make any Installment Payment or fail to pay any other sum hereunder when due, in either case within ten (10) days after receipt of written notice of such failure; or

(b)             The Town shall fail to perform or observe any term, condition or covenant of this Contract or shall breach any warranty by the Town herein or therein contained; or

(c)             Proceedings under any bankruptcy, insolvency, reorganization or similar litigation shall be instituted by or against the Town, or a receiver, custodian or similar officer shall be appointed for the Town or any of its property, and such proceedings or appointments shall not be vacated or fully stayed after the institution or occurrence thereof; or

(d)             Any warranty, representation or statement made by the Town herein or in any other document executed or delivered in connection herewith is found to be incorrect or misleading in any material respect on the date made; or

(e)             An attachment, levy or execution of a security interest or lien is levied upon or against the Equipment.

11.2.        Remedies on Default.  Subject to Section 13 hereof entitled "Limited Obligation of the Town," upon the occurrence of any Event of Default, the Bank may exercise any one or more of the following remedies as the Bank in its sole discretion shall elect:

(a)             Declare the entire principal amount of the Installment Payments and all accrued interest and other charges immediately due and payable without notice or demand to the Town;

(b)             Proceed by appropriate court action to enforce performance by the Town of the applicable covenants of this Contract or to recover for the breach thereof;

(c)             Exercise all the rights and remedies of a secured party or creditor under the Uniform Commercial Code of the State of North Carolina and the general laws of the State of North Carolina with respect to the enforcement of the security interest granted or reserved hereunder, including, without limitation, to the extent permitted by law, take possession of any collateral without any court order or other process of law and without liability for entering the premises and sell, lease, sublease or make other disposition of the same in a commercially reasonable manner for the account of the Town, and apply the proceeds of any such sale, lease, sublease or other disposition, after deducting all costs and expenses, including court costs and attorneys' fees, incurred with the recovery, repair, storage and other sale, lease, sublease or other disposition costs, toward the balance due under this Contract and, thereafter, shall pay any remaining proceeds to the Town;

(d)             Take possession of any proceeds of the Equipment, including Net Proceeds; or

(e)             Pursue any other remedy available at law or equity to the Bank.

11.3.        Further Remedies.  In connection with the exercise by the Bank of its remedies under Section 11.2(d), Town agrees to deliver the Equipment, at its own expense, to any location within North Carolina designated by the Bank.  All remedies of the Bank are cumulative and may be exercised concurrently or separately.  The exercise of any one remedy shall not be deemed an election of such remedy or preclude the exercise of any other remedy.  The Town agrees to pay to the Bank all court costs and reasonable attorney fees incurred by the Bank in enforcing the Bank's rights and remedies under this Contract.

SECTION 12.         ASSIGNMENT

12.1.        Assignment by the Town.  The Town agrees not to sell, assign, lease, sublease, pledge or otherwise encumber or suffer a lien or encumbrance upon or against any interest in this Contract or the Equipment (except for the lien and security interest of the Bank therein) without the Bank's prior written consent.

12.2.        Assignment by the Bank.  The Bank may, at any time and from time to time, assign all or any part of its interest in the Equipment and/or this Contract, including without limitation, the Bank's rights to receive the Installment Payments due and to become due hereunder.  Any assignment made by the Bank or any subsequent assignee may be made only to a bank, insurance company, or similar financial institution or other entity approved by the LGC.  No such assignment shall grant or purport to grant any greater interest or rights than those held by the Bank pursuant to this Contract.  The Town agrees that this Agreement may become part of a pool of obligations and the Bank or its assignees may assign or reassign all or any part of this Contract, including the assignment or reassignment of any partial interest through the use of certificate evidencing participation interests in this Contract, but only if such certificates are sold to a bank, insurance company or similar financial institution or other entity assigned by the LGC.  The Bank or its designees may assign or reassign either this entire Contract or a partial interest herein, subject to the foregoing restrictions.  All assignments by the Bank shall be subject to the following rules and conditions:

(a)             The Bank shall send written notice of the assignment and its effective date to the Town before it makes the assignment.  Such notification shall be forwarded to the Town at least 30 days before the effective date of the assignment.  The notification shall include an executed copy of the assignment document and shall specify the assignee's name and address, and shall provide the Town with instructions for making payments after the effective date of the assignment. The requirement of 30 days notice may be waived in writing by the Town.

(b)             The Town shall not be obligated to make payments to anyone other than the Bank until the notification specified in part (a) of this Section is received by the Town or until the effective date of the assignment, whichever is later. Should the Town incorrectly make payments to the Bank after the conditions specified in the preceding sentence are met, the Bank shall return those payments to the Town.

(c)             When it receives the notification specified in part (a) of this section, the Town shall send a written acknowledgement of the same to the Bank and shall record the assignment in the Town's "book entry system".

(d)             The Bank shall require each of its assignees (1) to conform to the notification requirements of this section in the event of further assignments, and (2) to require such conformity from that assign's assignees.

(e)             The Town shall execute, at the Bank's request, a notice of assignment and other related documents that are reasonably necessary to protect the security interest in the Equipment or in this Contract and to maintain those security interests in perfected form.

After the giving of notice described above to the Town, the Town shall thereafter make all payments in accordance with the notice to the assignee named therein and shall, if so requested, acknowledge such assignment in writing, but such acknowledgement shall in no way be deemed necessary to make the assignment effective.

SECTION 13.         LIMITED OBLIGATION OF THE TOWN

NO PROVISION OF THIS CONTRACT SHALL BE CONSTRUED OR INTERPRETED AS CREATING A PLEDGE OF THE FAITH AND CREDIT OF THE TOWN WITHIN THE MEANING OF ANY CONSTITUTIONAL DEBT LIMITATION.  NO PROVISION OF THIS CONTRACT SHALL BE CONSTRUED OR INTERPRETED AS CREATING A DELEGATION OF GOVERNMENTAL POWERS NOR AS A DONATION BY OR A LENDING OF THE CREDIT OF THE TOWN WITHIN THE MEANING OF THE CONSTITUTION OF THE STATE OF NORTH CAROLINA.  THIS CONTRACT SHALL NOT DIRECTLY OR INDIRECTLY OR CONTINGENTLY OBLIGATE THE TOWN TO MAKE ANY PAYMENTS BEYOND THOSE APPROPRIATED IN THE SOLE DISCRETION OF THE TOWN FOR ANY FISCAL YEAR IN WHICH THIS AGREEMENT IS IN EFFECT; PROVIDED, HOWEVER, ANY FAILURE OR REFUSAL BY THE TOWN TO APPROPRIATE FUNDS, WHICH RESULTS IN THE FAILURE BY THE TOWN TO MAKE ANY PAYMENT COMING DUE HEREUNDER WILL IN NO WAY OBVIATE THE OCCURRENCE OF THE EVENT OF DEFAULT RESULTING FROM SUCH NONPAYMENT.  NO DEFICIENCY JUDGMENT MAY BE RENDERED AGAINST THE TOWN IN ANY ACTION FOR BREACH OF A CONTRACTUAL OBLIGATION UNDER THIS CONTRACT, AND THE TAXING POWER OF THE TOWN IS NOT AND MAY NOT BE PLEDGED DIRECTLY OR INDIRECTLY OR CONTINGENTLY TO SECURE ANY MONEYS DUE UNDER THIS CONTRACT.

No provision of this Contract shall be construed to pledge or to create a lien on any class or source of the Town's moneys other than the Escrow Fund created pursuant to the Escrow Deposit Agreement referenced in Section 5.9(f).  To the extent of any conflict between this Section and any other provision of this Contract, this Section shall take priority.

SECTION 14.         TAX‑EXEMPT INTEREST

14.1.        Intent of Parties.  It is the intention of the parties hereto that the interest portion of the Installment Payments paid by the Town to the Bank under this Contract shall be tax‑exempt under Section 103 of the United States Internal Revenue Code.

14.2.        Determination or Event of Taxability.  If at any time there is a Determination of Taxability or Event of Taxability, as such terms are hereinafter defined, the principal portion of the indebtedness of the Town to the Bank which is represented by the Installment Payments shall, from and after the Date of Taxability, as hereinafter defined, bear interest at the Prime Rate, as the Prime Rate fluctuates from time to time, plus one percent (1%) per annum (the "Alternative Rate of Interest") payable from the Date of Taxability to such time.  In such event, the Town also shall be required to pay to the Bank all amounts, if any, which may be necessary to reimburse the Bank for any interest, penalties or other charges assessed by the Internal Revenue Service and the Department of Revenue of the State of North Carolina against the Bank by reason of the Bank's failure to include the interest portion of the Installment Payments in its gross income for income tax purposes.  Installment Payment amounts under this Contract shall be increased as a result of the increased interest rate and additional interest as a result of said rate increase on all previous payments shall be paid to the Bank upon demand thereof.  The Town shall pay to the Bank the above‑mentioned Alternative Rate of Interest notwithstanding any transfer by the Bank or payment or prepayment by the Town prior to the date such Determination of Taxability was made.

An Event of Taxability shall mean any event, occurrence or situation, resulting from an action, or failure to act, by the Town, the effect of which is to cause the interest portion of the Installment Payments to be includible in the gross income of the Bank for federal income tax purposes.  A Determination of Taxability shall mean a determination that the interest portion of the Installment Payments is included in gross income of the Bank for federal income tax purposes, which determination shall be deemed to have been made upon the occurrence of the first to occur of the following: (a) the date on which the Bank is advised in writing by the Commissioner or any District Director of the Internal Revenue Service that, as a consequence of an action, or failure to act, by the Town, the interest portion of the Installment Payments (hereinafter called "Interest") is included in the gross income of the Bank for federal income tax purposes; (b) the date on which the Town receives notice from the Bank that the Bank has been advised (i) in writing that the Internal Revenue Service has issued a statutory notice of deficiency or similar notice to the Bank which asserts, in effect, that Interest received by the Bank is included in the gross income of the Bank for federal income tax purposes, as a result of an action, or failure to act, by the Town, or (ii) by an opinion of counsel received by the Bank which concludes, in effect, that Interest is included in the gross income of the Bank for federal income tax purposes as a result of an action, or failure to act, by the Town; (c) the day on which the Town is advised in writing by the Commissioner or any District Director of the Internal Revenue Service that there has been issued a public or private ruling of the Internal Revenue Service that the Interest is included in the gross income of the Bank for federal income tax purposes as a result of an action, or failure to act, by the Town; or (d) the day on which the Town is advised in writing by counsel to the Bank that a final determination, from which no further right of appeal exists, has been made by a court of competent jurisdiction in the United States of America in a proceeding with respect to which the Town has been given written notice and an opportunity to participate and defend that the Interest is included in the gross income of the Bank for federal income tax purposes, as a result of an action, or failure to act, by the Town.

The Date of Taxability shall mean the first date upon which Interest is included in the gross income of the Bank for federal income tax purposes as a result of an Event of Taxability or a Determination of Taxability.

If at any time there is a Change in Deductibility (hereinafter defined), the interest rate payable hereunder shall increase to the rate which will provide to the Bank the effective yield which it would have received had there not been a Change in Deductibility.  A "Change in Deductibility" means any determination by the Internal Revenue service or any court of competent jurisdiction that the obligation of the Town hereunder is not a "qualified tax‑exempt obligation" within the meaning of Section 265(b) (3) of the Internal Revenue Code as a result or as a consequence of (i) an action, or failure to act, by the Town or (ii) a breach of any representation or warranty made by the Town to the Bank relating to the status of this Contract as a qualified tax‑exempt obligation as defined above, including but not limited to the representations and warranties contained in Section 8(i) of this Contract.

14.3.        Duty to Notify the Bank.  The Town agrees to give prompt written notice to the Bank upon the Town's receipt of any oral or written notice or information from any source whatsoever to the effect that an Event of Taxability or a Determination of Taxability has occurred.

SECTION 15.         MISCELLANEOUS

15.1.        Waiver.  No covenant or condition of this Contract can be waived except by the written consent of the Bank. Any failure of the Bank to require strict performance by the Town or any waiver by the Bank of any terms, covenants or conditions herein shall not be construed as a waiver of any other breach of the same or any other term, covenant or condition herein.

15.2.        Severability.  In the event any portion of this Contract shall be determined to be invalid under any applicable law, such provision shall be deemed void and the remainder of this Contract shall continue in full force and effect.

15.3.        Governing Law.  This Contract shall be construed, interpreted and enforced in accordance with the laws of the State of North Carolina.

15.4.