HomeMy WebLinkAboutAhers Bond and Disclosure Counsel Engagement Agmt Approved 1 18 2022L
A T T D R N E Y S
December 30, 2021
VIA E-MAIL
City of Waterloo
c/o Michelle Weidner
City Clerk
715 Mulberry
Waterloo, Iowa 50703
Ahlers & Cooney, P.C.
Attorneys at Law
100 Court Avenue, Suite 600
Des Moines, Iowa 50309-2231
Phone: 515-243 7611
Fax: 515-243-2149
www.ahlerslaw.com
Kristin B Cooper
515 246.0330
kcooper@ahlerslaw.com
Re: Waterloo, Iowa - Bond and Disclosure Counsel Engagement Agreement
Dear Mayor and City Council:
The purpose of this Engagement Agreement (the "Agreement") is to disclose and
memorialize the terms and conditions under which services will be rendered by Ahlers &
Cooney, P.C. as bond and disclosure counsel to Waterloo, Iowa (the "Issuer") in connection with
the issuance from time to time of bonds, notes, or other obligations (the "Bonds"), as applicable.
We understand the Issuer works with Speer Financial for financial advisory services. While
additional members of our firm may be involved in representing the Issuer on other matters
unrelated to the Bonds, this Agreement relates to the agreed -upon scope of bond counsel and
disclosure services described herein
Bond Counsel
SCOPE OF ENGAGEMENT
In the role of Bond Counsel, we will provide the following services:
(1)
Subject to the completion of proceedings and execution of documents to our
satisfaction, render our legal opinion (the "Bond Opinion') regarding the validity
and enforceability of the Bonds, the source of payment and security for the
Bonds, and the tax status of the Bonds for federal and State of Iowa, as applicable
income tax purposes.
WISHARD & BAILY - 1888; GUERNSEY & BAILY - 1893; BAILY & STIPP - 1901; STIPP, PERRY, BANNISTER & STARZINGER - 1914; BANNISTER, CARPENTER,
AHLERS & COONEY - 1950; AHLERS, COONEY, DORWEILER, ALLBEE, HAYNIE & SMITH - 1974; AHLERS, COONEY, DORWEILER, HAYNIE, SMITH & ALLBEE, P.C. -1990
December 30, 2021
Page 2
(2) Prepare and review documents necessary or appropriate to the authorization,
issuance and delivery of the Bonds, and coordinate the authorization and
execution of such documents
(3) Review legal issues relating to the structure of the Bond issue.
(4) Review or prepare those sections of the official statement, private placement
memorandum or other form of offering or disclosure document (the "Offering
Documents") to be disseminated in connection with the sale of the Bonds that
describe the terms of the Bonds, Iowa and federal law pertinent to the validity of
the Bonds, the tax status of interest on the Bonds, and the Bond Opinion.
(5) Upon request, assist the Issuer in presenting information to bond rating
organizations and providers of credit enhancement relating to the issuance of
Bonds
(6) Prepare the notice of sale relating to the competitive sale of Bonds.
(7) Draft the Continuing Disclosure Certificate of the Issuer, if applicable.
(8) File an appropriate Form 8038 with the IRS after Closing.
As Bond Counsel, our examination will extend to the actions and approvals necessary to
authorize the issuance and initial delivery of the Bonds to the original purchaser. Our Bond
Opinion does not extend to any re -offering of the Bonds by the original purchaser or other
persons The Bond Opinion will be delivered by us on the date the Bonds are exchanged for
their purchase price (the "Closing") and will be based on facts and law existing as of its date. In
rendering our Bond Opinion, we will rely upon the certified proceedings and other certifications
of public officials and other persons furnished to us without undertaking to verify the same by
independent investigation, and we will assume continuing compliance by the Issuer with
applicable laws relating to the Bonds. During the course of this engagement, we will rely on the
Issuer, and authorized officials, to provide us with complete and timely information on all
developments pertaining to any aspect of the Bonds and their security.
Disclosure Counsel
In the role of Disclosure Counsel, we will work with the Issuer, including the officials,
officers, and employees, the City's Municipal Advisor, and other parties to the Bond transaction
to provide the following services:
(1) Consult with Issuer officials and staff, the Municipal Advisor, and Underwriter
(as applicable), concerning primary disclosure requirements, questions and issues
relating to the initial issuance of Bonds and concerning continuing disclosure
requirements
(2) Participate or attend, upon request, any meeting of the Issuer or Issuer's staff
relating to disclosure matters that pertain to Issuer's issuance of Bonds
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Page 3
Participate in the drafting of the Issuer's Purchase Agreement for the negotiated
sale of Bonds.
Participate in the drafting of the Issuer's public sale solicitation documents for the
competitive sale of Bonds
Participate in the drafting/review of the Issuer's preliminary and final official
statements in connection with the offering of Bonds, with assistance of Issuer
officials and staff, and the Municipal Advisor and Underwriter, as necessary.
Coordinate with the printing and delivery of the preliminary and final official
statements
Review all Bond documents prepared in connection with the issuance of Bonds to
the extent such documents involve or affect disclosure matters.
Provide written advice to the Issuer at the time the Bonds are issued as described
herein.
Consult with Issuer officials and staff regarding all matters relating to continuing
disclosure requirements that pertain to the Bonds, specifically to include those
imposed by Securities and Exchange Commission Rule 15c2-12.
Subject to the completion of the diligence process to our satisfaction, we will render our
written advice addressed to the Issuer stating substantially that, in the course of our participation
in the preparation of the Official Statement, no information has come to our attention which
leads us to believe that the Official Statement (excluding the financial and demographic
information or charts, engineering and statistical data, financial statements, statements of trends
and forecasts, information concerning any bond insurance and The Depository Trust Company,
included in the Official Statement, and in the Appendices, as to which we will not express any
opinion or view) contains any untrue statement of a material fact or omits to state a material fact
required to be stated therein or necessary in order to make the statements therein, in light of the
circumstances under which they were made, not misleading. In rendering our advice, we will
rely upon the certified proceedings and other certifications of public officials and other persons
furnished to us without undertaking to verify the same by independent investigation. During the
course of the engagement, we will rely on the Issuer's staff to provide us with complete and
timely information on all developments pertaining to any aspect of the Bonds and their security.
The written advice rendered hereunder will be dated and executed and delivered by us at
Closing and will be based on existing law as of its date. Upon delivery of our written advice and
the filing of all appropriate closing documents, our responsibilities as Disclosure Counsel will be
concluded with respect to the issuance of a series of Bonds
COOPERATION
To enable us to provide effective representation, the Issuer agrees to: (1) disclose to us,
fully and accurately and on a timely basis, all facts and documents that are or might be material
or that we may request; (2) keep us apprised on a timely basis of all developments relating to the
representation that are or might be material; (3) attend meetings, conferences, and other
proceedings when it is reasonable to do so; and (4) cooperate fully with us in all matters relating
to the engagement During the course of this engagement, we will rely on the Issuer's staff to
December 30, 2021
Page 4
provide us with complete and timely information on all developments pertaining to any aspect of
the Bonds and the security for the Bonds.
LIMITATIONS
The duties covered by this engagement are limited to those expressly set forth above.
Our fee does not include the following services, or any other matter not required to render our
Bond Opinion or written advice as Disclosure Counsel:
(a) Preparing requests for tax rulings from the Internal Revenue Service, or "no action"
letters from the Securities and Exchange Commission.
(b) Drafting state constitutional or legislative amendments
(c) Pursuing test cases or other litigation, such as contested validation proceedings.
(d) Representing the Issuer in Internal Revenue Service examinations or inquiries, or
Securities and Exchange Commission investigations.
(e) After Closing, providing continuing advice to the Issuer or any other party concerning
actions necessary to assure that interest paid on the Bonds will continue to be
excludable from gross income for federal income tax purposes (e.g. this Bond
Counsel engagement for the Bonds does not include rebate calculations, nor
continuing post -issuance compliance activities).
(f) Opining on a continuing disclosure undertaking pertaining to the Bonds and, after the
execution and delivery of the Bonds, providing advice concerning any actions
necessary to assure compliance with any continuing disclosure requirements;
(g) After Closing, providing continuing advice to the Issuer or any other party concerning
disclosure issues or questions that relate to the Bonds, e.g., questions regarding
actions necessary to assure fulfillment of continuing disclosure responsibilities.
We will provide one or more of the services listed in (a)—(g) upon your request, however, a
separate, written engagement or request for services in accordance with the "Other Advice"
section of this engagement will be required before we assume one or more of these duties. The
remaining services in this list, specifically those listed in subparts (h)—(1) below, are not included
in this Agreement, nor will they be provided by us at any time.
(h) Providing any advice, opinion or representation as to the financial feasibility or the
fiscal prudence of issuing the Bonds, the financial condition of the Issuer, or to any
other aspect of the financing, such as the proposed financing structure, use of a
financial advisor, or the investment of proceeds of the Bonds
(i) Acting as an underwriter, or otherwise marketing the Bonds
(j) Acting in a financial advisory role.
(k) Preparing blue sky or investment surveys with respect to the Bonds
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(1) Making an investigation or expressing any view as to the creditworthiness of the
Issuer or of the Bonds
ATTORNEY -CLIENT RELATIONSHIP
Upon execution of this Agreement and upon notification by the Issuer that our Bond
Counsel and/or Disclosure Counsel services are requested with regard to a specific issue of
Bonds (it being understood the Issuer has discretion hereunder, as to each service offered) the
Issuer will be our client and an attorney -client relationship will exist between us with respect to
the issuance of the Bonds We assume that all other parties will retain such counsel as they deem
necessary and appropriate to represent their interests in this transaction. We further assume that
all parties understand that in this transaction we represent only the Issuer, we are not counsel to
any other party, and we are not acting as an intermediary among the parties. Our services are
limited to those contracted for in this Agreement; the Issuer's execution of this Agreement will
constitute an acknowledgement of those limitations. Our representation of the Issuer will not
affect, however, our responsibility to render an objective Bond Opinion or written advice as
Disclosure Counsel.
Our representation of the Issuer and the attorney -client relationship created by this
Agreement with respect to a series of Bonds will be concluded upon issuance of such Bonds.
Nevertheless, subsequent to Closing, we will mail the appropriate completed Internal Revenue
Service Form 8038 and prepare and distribute to the participants in the transaction a transcript of
the proceedings pertaining to the Bonds.
OTHER REPRESENTATIONS
As you are aware, our firm represents many political subdivisions, companies and
individuals. It is possible that during the time that we are representing the Issuer, one or more of
our present or future clients will have transactions with the Issuer. We do not believe such
representation, if it occurs, will adversely affect our ability to represent you as provided in this
Agreement, either because such matters will be sufficiently different from the issuance of the
Bonds so as to make such representations not adverse to our representation of you, or because
the potential for such adversity is remote or minor and outweighed by the consideration that it is
unlikely that advice given to the other client will be relevant to any aspect of the issuance of the
Bonds We will decline to participate in any matter where the interests of our clients, including
the Issuer, may differ to the point where separate representation is advisable. The firm
historically has arranged its practice to hold such occasions to a minimum, and intends to
continue doing so. Execution of this Agreement will signify the Issuer's consent to our
representation of others consistent with the circumstances described in this paragraph.
December 30, 2021
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FEES
We charge a flat fee for each issue of Bonds for which Bond Counsel and Disclosure
Counsel services are rendered under this Agreement respectively, as applicable Our fees are
based upon: (i) our current understanding of the terms, structure, size and schedule of the
financing represented by the Bonds; (ii) the duties we will undertake pursuant to this Agreement;
(iii) the time we anticipate devoting to the financing; and (iv) the responsibilities we will assume
in connection therewith. We will communicate our estimated fee to the Issuer's finance team,
including the Municipal Advisor, as applicable, for purposes of sizing each new Bond issue. It is
anticipated that our fees will be capitalized into the Bond issue. It is understood the Chief
Financial Officer is delegated authority to approve our fees. If, at any time, we believe that
circumstances require an adjustment of our original fee estimate(s), we will advise the finance
team. Such adjustment might be necessary in the event* (a) the principal amount of Bonds
actually issued differs significantly from the amount anticipated at the time we initially estimated
our fee(s); (b) material changes in the structure or schedule of the financing occur; or (c) unusual
or unforeseen circumstances arise which require a significant increase or decrease in our time or
responsibility, such as personal attendance at meetings, significant travel, or unexpected revision
of the issuance documents at the request of the Issuer, any agent acting on your behalf (such as a
financial advisor), the purchaser, a bond insurer, other counsel providing services with respect to
issuance of a particular issuance of obligations.
In addition to our flat fees, we will charge for any incidental costs (copies, overnight
charges, bond printing, travel reimbursement, deliveries, etc. at actual costs incurred. We
estimate that such charges will not exceed $750 per issue of Bonds. We will contact you prior to
incurring expenses that exceed this amount.
The delivery of written advice, or opinions beyond the Bond Opinion, to third parties at
the request of the Issuer with respect to a series of Bonds shall be subject to a separate charge in
an amount established at the time of the request.
Billing Matters:
We will submit an electronic summary invoice for the professional services described
herein after Closing. In the event of a substantial delay in completing the financing, we reserve
the right to present an interim statement for payment Unless other arrangements have been
agreed upon in advance, we anticipate our statements to be paid in full within thirty (30) days of
receipt.
If, for any reason, the financing represented by an issue of Bonds is not consummated or
is completed without the delivery of our Bond Opinion or written advice as Disclosure Counsel,
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or our services are otherwise terminated, we will expect to be compensated at our noirrial hourly
rates, plus client charges, as described above (not to exceed the fee we would have received if we
had rendered our Bond Opinion and written advice as Disclosure Counsel) The current hourly
rate of the undersigned (as of 1/1/2021) is $275 per hour. Work performed by other attorneys
will be billed at their current hourly rate (currently ranging from $200-$400 per hour). Work by
legal assistants is currently billed at $120. The hourly rates reflected herein are subject to our
periodic review and adjustment — typically annually.
Other Advice:
If requested, we will maintain one or more separate accounts for periodic services
rendered to the Issuer in connection with other matters unrelated to any particular Bond
financing. Such services may involve the rendering of advice, opinions or other assistance in
connection with such issues including, but not limited to (i) financing alternatives in connection
with a particular project, (ii) compliance with lending programs, (iii) the impact of specified
actions on tax-exempt status of outstanding Bonds, (iv) interpretation and/or required actions
with regard to other "financial obligations" under a continuing disclosure certificate, or (v) other
matters the Issuer may seek advice or guidance upon. Billings for such separate services will be
based on our standard hourly rate of the individual attorney performing the services.
RECORDS
At your request, papers and property furnished by you will be returned promptly upon
receipt of payment for outstanding fees and client charges. Our own files, including lawyer work
product, pertaining to the transaction will be retained by us. We may store some or all client file
materials in a digital format. After any or all paper documents are digitized, we may destroy all
paper documents in the client file. We typically retain financing files for the life of the Bonds, at
which point we will destroy all client file materials unless you notify us in writing that you wish
to take possession of them This clause applies to any client file materials being held or stored
by a third -party vendor.
In the interest of facilitating our services to you, we may send documents, information or
data electronically or via the Internet or store electronic documents or data via computer software
applications hosted remotely or utilize cloud -based storage. Your confidential electronic
documents or data may be transmitted or stored using these methods. We may use third party
service providers to store or transmit these documents or data. In using these electronic
communication and storage methods, we employ reasonable efforts to keep such
communications, documents and data secure in accordance with our obligations under applicable
laws, regulations, and professional standards; however, you recognize and accept that we have
December 30, 2021
Page 8
no control over the unauthorized interception or breach of any communications, documents or
data once it has been transmitted or if it has been subject to unauthorized access while stored,
notwithstanding all reasonable security measures employed by us or by our third party vendors.
By your acceptance of this letter, you consent to our use of these electronic devices and
applications and submission of confidential client information to or through third party service
providers during this engagement.
Please carefully review the terms and conditions of this Agreement. If the above
correctly reflects our mutual understanding please indicate by returning a signed and dated
copy of this letter, retaining an original for your file as well.
If you have questions regarding any aspect of the above or our representation as Bond
Counsel or Disclosure Counsel, please do not hesitate to contact me. It has been a pleasure to
serve you in the past, and we look forward to our continued relationship.
KBC:seb
Accepted:
City of Waterloo, Iowa*
By'flu-'o1-4< eLfra/L)
Very truly yours,
Ahlers & Cooney, P.C.
Lf7,z,Ie,
!J if
-C z
Kristin Billingsley Cooper
FOR THE FIRM
Date: /-1tf02?
*Approved by action of the governing body on January 18, 2022
01966485-1 \ 11310-144