Subject:
Title
Tax Equity Fiscal Responsibility Act Resolution for the reissuance, for federal tax purposes, by the Pinellas County Educational Facilities Authority of the Pinellas County Educational Facilities Authority Revenue Refunding Bond, Series 2015, in a principal amount of not to exceed $3,528,367.30 on behalf of Saint Paul’s School, Inc., a Florida not for profit corporation for its existing school located in Clearwater, Florida.
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Recommended Action:
Recommended Action
Conduct a public hearing and consider the adoption of a TEFRA Resolution authorizing TEFRA approval for the reissuance of the Pinellas County Educational Facilities Authority Revenue Refunding Bond (Saint Paul's School Project), Series 2015 (Series 2015 Bond) as a tax-exempt qualified 501(c)(3) bond in the principal amount of not to exceed $3,528,367.30 on behalf of Saint Paul’s School, Inc., a Florida not for profit corporation (Corporation).
The Series 2015 Bond is not a new bond, rather a restructuring and consequentially a reissuance of the original Series 2015 Bond for federal tax purposes (Reissuance). The amendments to the Series 2015 Bond are being requested by the Corporation and Seacoast National Bank (Bank) for the primary purpose of:
• Modifying the interest rate of the Series 2015 Bond to reflect current market interest rates;
• Deleting the Demand Purchase Option and Optional Tender Date of the Series 2015 Bond;
• Modifying the maturity date of the Series 2015 Bond;
• Modifying the amortization schedule of the Series 2015 Bond; and
• Undertaking additional minor modifications pursuant to the direction and approval of the Bank.
• This item has no fiscal impact on Pinellas County. The Educational Facilities Authority (EFA) is a dependent special district of Pinellas County. This financing (refinancing) pledges neither the EFA’s nor the County’s credit, and neither are responsible for payment of the debt except from funds received from the borrower (in this case, the school).
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Strategic Priorities:
Prosperity and Opportunity
3.4 Enhance educational and cultural opportunities
Summary:
Summary
The Corporation has requested the reissuance, for federal tax purposes, of the Pinellas County Educational Facilities Authority Revenue Refunding Bond (Saint Paul's School Project), Series 2015 (the "Series 2015 Bond"), in a principal amount of not to exceed $3,528,367.30, the proceeds of which were applied to (i) refund the Pinellas County Educational Facilities Authority Revenue Bond (Saint Paul's School, Inc. Project), Series 2005, the proceeds of which were used to finance the construction and equipping of a classroom building, to finance improvements and renovations to an existing classroom building and to make certain related capital improvements, all at the Borrower's campus located at 1600 St. Paul's Drive, Clearwater, Pinellas County, Florida 33764, and (ii) pay all or a portion of the costs of issuance of the Series 2015 Bond.
The County published the TEFRA Notice regarding the reissuance of the Series 2015 Bond on its website in accordance with Section 1.147(f)-1(c)(4)(iii) of the Income Tax Regulations (the "Regulations"). The TEFRA Notice was posted in a section of the County's website that is regularly used to inform residents of public events and meetings, as contemplated by the Regulations. In addition, the Regulations do not require the County to use any supplemental method of publication in conjunction with the website posting.
The proceeds of the original Series 2015 Bond were applied to (i) refund the Pinellas County Educational Facilities Authority Revenue Bond (Saint Paul's School, Inc. Project), Series 2005, the proceeds of which were used to finance the construction and equipping of a classroom building, to finance improvements and renovations to an existing classroom building and to make certain related capital improvements, all at the Borrower's campus located at 1600 St. Paul's Drive, Clearwater, Pinellas County, Florida 33764, and (ii) pay all or a portion of the costs of issuance of the Series 2015 Bond.
The Corporation is responsible for payments of all fees and expenses. The Reissuance will have no fiscal impact on Pinellas County, Florida.
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Background Information:
Providing for this reissuance for federal tax purposes will allow the Pinellas County Educational Facilities Authority to reissue the Series 2015 Bond on behalf of the Corporation.
Fiscal Impact:
No fiscal impact on the County. The Corporation is responsible for payments of all fees and expenses.
Staff Member Responsible:
Chris Rose, Director, Office of Management & Budget
Jim Abernathy, Deputy Director, Office of Management & Budget
Partners:
Pinellas County Educational Facilities Authority
Saint Paul's School, Inc. (the "Corporation")
Attachments:
Resolution
Exhibit A - Form of TEFRA Notice