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HomeMy WebLinkAboutAgenda - 03-02-2006-8bTASHLF draft of February 21, 2006 TRUST AGREEMENT by and between ORANGE COUNTY PUBLIC FACILITIES COMPANY and THE BANK OF NEW YORK, as Trustee Dated as of April 1, 2006 Relating to the execution and delivery of $24,000,000 Certificates of Participation (Orange County Public Improvement Projects), Series 2006A ~3ss~~3 THIS TRUST AGREEMENT is dated as of April 1, 200G, is between Orange COUNTY PUBLIC FACILITIES COMPANY, a North Carolina nonprofit corporation {the "Company"}, and THE BANK OF NEW YORK, as trustee (the "Trustee"), and relates to the execution and delivery of [$24,000,000] Certificates of Participation (Orange County Public Improvement Projects}, Series 200GA (the "200GA Certificates"). RECITALS: The Company and Orange County, North Carolina (the "County"), have entered into an Installment Financing Contract also dated as of April 1, 2000 (the "Financing Contract"). The Financing Contract provides for the Company's advance to the County of funds to be used, together with other available funds, to payT the costs of the acquisition, construction and impro~Tement of certain school facilities and to provide far certain other public improvements and to pay financing casts. The County will make "Installment Payments" under the Financing Contract in amounts sufficient to repay with interest the amount advanced under the Financing Contract. The Installment Payments in tLU71 will be sufficient to pay the components of principal and interest represented by the 200GA Certificates. The Company is providing for the execution and delivery of the 200GA Certificates to raise funds for the advance under the Financing Contract. The 200GA Certificates evidence proportionate and undivided interests in the Installment Payments. As security for the payment of the Certificates, the Company has agreed to assign to the Trustee, without recourse against the Company, the specific security described below. Unless the context clearly requires otherwise, capitalized terms used in this Trust Agreement and not otherwise defined will have the meanings set forth in ExlzibitA. NOW, THEREFORE, for and in consideration of the mutual promises and covenants contained in this Trust Agreement, the parties agree as follows: ARTICLE I THE CERTIFICATES 93362v2 2 Section 1.01. Provision for 2006A Certificates. The Company will prepare and execute, and the Trustee will authenticate and deliver, 2006A Certificates in an aggregate principal amount of $24,000,000 e~ridencing proportionate and undivided ownership interests in the Installment Payments. Section 1.02. Farm and Details; Payments. The 2006A Certificates ~~-i11 be designated "Certificates of Participation {Orange County Public Improvement Projects), Series 200GA," and uTill be in substantially the form of Exhibit B, with such changes as this Trust Agreement permits or requires. The 200GA Certificates will be dated the date of their initial delivery to the initial purchaser thereof, will be issuable only as fiilly registered certificates in denominations of $5,000 and multiples thereof, uTill be separatel~j numbered R-1 upward, twill be payable as to interest semiannually until payment on each Certificate Payment Date at the following rates {calculated on the basis of a 3G0- day year consisting of t~~•elve 30-day months}, and gill be payable as to principal on April 1 in the follov~Ting years and amounts: Date (April 1) Principal Amount ($) Rate °10 2007 1.00 2008 1.00 2009 1.00 2010 1.00 2011 1.00 2012 1.00 2013 1.00 2014 1.00 2015 1.00 2016 1.00 2017 1.00 2018 1.00 2021 1.00 2022 1.00 2.023 1.00 J3862v2 2024 1.00 2.025 1.00 2026 1.00 Each 2006A Certificate will be pa~jable as to interest (a) from its date, if such 2006A Certificate is authenticated prior to the Record Date preceding the first Certificate Payment Date, (b) from the succeeding Certificate Payment Date, if such 2000A Certificate is authenticated betv~Teen a Record Date and the succeeding Certificate Payment Date, or {c) otherwise from the Certificate Payment Date that is, or immediately precedes, the date on ~~Jluch such 2006A Certificate is authenticated; provided, however, that if at the time of authentication of any 2006A Certificate payment of interest is in default, such 2006A Certificate will be payable as to interest from the date to ~vluch interest has been paid. Principal, premium, if any, and interest on all Certificates will be payable in laujful money of the Uiuted States of America. Section 1.03. Prepayment Dates and Prices. The Certificates are subject to prepayment as described in Section 3.01. Section 1.04. Delivery of 2006A Certificates. The Trustee will authenticate and deli~Ter the 2006A Certificates when there ha~Te been filed with or delivered to it the following: (a) Original executed counterparts of this Trust Agreement, the Financing Contract and the Deed of Trust. (b) A certified copy of a resolution or resolutions of the County Board, approving substantially final forms of the Financing Contract and the Deed of Trust, authorizing their execution and delivery and approving the execution and deliverer of the 2006A Certificates. (c) Executed 2006A Certificates in the aggregate principal amounts, bearing interest at such rates and payable as to principal and interest at such times and in such amounts as are provided in this Trust Agreement. (d) A request and authorization, signed by any Company officer and by a County Representative, to the Trustee to authenticate and deliver the 2006A Certificates to such person or persons named therein upon payment to the Trustee with respect to the 2006A Certificates of a specified sum. J3862v2 4 (e) A certificate signed by a County Representative directing the Trustee as to the application of proceeds from the sale of 2006A Certificates to ~Tarious funds and accounts established under this Trust Agreement. Section 1.05. Additional Certificates. So long as the Financing Contract remains in effect, the Company may provide for Additional Certificates to be executed and delivered under this Trust Agreement to provide funds {a) to complete the Financed Facilities, {b) to expand or improve the Financed Facilities, (c) to refund any Outstanding Certificates, (d) to pay financing costs or establish reserves in connection with the issuance of Additional Certificates, (e) for an5~~ other purpose that may be allowed by law from time to time, including the acquisition and construction of additional public facilities, whether or not such facilities are related to the Financed Facilities, or (f) for any combination of such purposes. The Trustee will authenticate and deliver the Additional Certificates when there have been filed with or delivered to it the follov~Ting: (i) Certified copies of resolutions of the County Board and the Company's governing board approving the terms and conditions under which the Additional Certificates are to be issued and authorizing the execution of an amendment to the Financing Contract pro~jiding for payment of Contract Payments as required by the issuance of the Additional Certificates. {ll) An executed copy of the Financing Contract, as so amended, together with evidence satisfactory to the Trustee that the LGC has approved such amendment (if such approval is then required by la~v). (iii} An executed copy of an amendment or supplement to this Trust Agreement providing for the issuance of the Additional Certificates, which will set forth the payment and prepayment terms of such Additional Certificates, together with such other terms as may be appropriate. (iv} An Opinion of Special Cou11se1 to the effect that the issuance of such Additional Certificates is permitted under the terms of this Trust Agreement and has been duly authorized, and that the issuance of such Additional Certificates will not adversely affect the exclusion from federal gross income to which interest components of Installment Payments are otherwise entitled. (v) A certificate signed by a County Representative directing the Trustee as to the application of the proceeds from the sale of the Additional Certificates. (vi) The Ins~.~rer's consent to the issuance of the Additional Certificates. 93362v2 5 The Trustee will not authenticate and deliver any such Additional Certificates if any default under this Trust Agreement or under the Financing Contract is continuing. Simultaneously with the delivery of the Additional Certificates, the proceeds (including any accrued interest) of the Additional Certificates will be applied as pro~Tided in the certificate described in (v) above. Each of the Additional Certificates executed and delivered pursuant to this Section will evidence an assignment of a proportionate and undivided ownership interest in Installment Payments under the Financing Contract, as amended, proportionately and ratably secured with the 2006A Certificates and all other Additional Certificates, if any, executed and deli~Tered pursuant to this Section, without preference, priority or distinction of any Certificates over any other. No Additional Certificates will be so proportionately and ratably secured without. compliance with the provisions of thus Section. After the execution and delivery of any such Additional Certificates, such will be "Certificates" under this Trust Agreement and subject to all of its terms and conditions, except as may be provided in the supplement to this Trust Agreement provided for in (iii) above. ARTICLE II ADDITIONAL PROVISIONS FOR THE FORM, REGISTRATION AND EXCHANGE OF CERTIFICATES Section 2.01. Book-Entry-Only Form. {a) The Certificates will be issued by means of a book-entry system, with one certificate for each maturity immobilized at DTC, and not available for distribution to the public. Transfer of beneficial ownership interests in the Certificates in the principal amounts of $5,000 or any multiple thereof will be effected on the records of DTC and its participants pursuant to rules and procedures established by DTC and its participants. Principal, premium, if any, and interest with respect to the Certificates will be payable to DTC or its nominee as registered owner of the Certificates. Transfer of principal, premium, if any, and interest to DTC participants ~~Till be DTC's responsibilit~j, and transfer of principal, premium, if any, and interest with respect to the Certificates to beneficial owners of the Certificates by DTC participants will be the responsibility of such participants and other nominees of beneficial owners. Neither the Trustee, the Company nor the County will be responsible or liable for such transfer of payments or for maintaining, supervising or revieuJing the records maintained b~T DTC, its participants or persons acting through such participants. J3862v2 {b) If {i) DTC determines not to continue to act as securities depository far the Certificates or {ii) a County Representative so directs, the Company will arrange to discontinue the book-entry s~Tstem ~~jith DTC. If the County identifies an alternate qualified securities depository to replace DTC, that depositary ti~Till replace DTC and all references to DTC in this Trust Agreement will be deemed references to such alternate depository. If the County fails to identify another qualified SecurltleS depository to replace DTC, the Company will deliver fully- registered certificates as replacements for Certificates in book-entry form. Such certificates ~~Till be in such form as the Company, `~Tith the County's appro~Tal, may hereafter authorize. Section 2.02. Execution. The Certificates will be signed on the Company's behalf by the manual or facsimile signature of its President or any Vice President, and the Company's seal will be impressed or imprinted on the Certificates by facsimile or otherwise and attested by the manual or facsimile signature of the Company's Secretary or any Assistant Secretary. If any Company officer whose signature is on a Certificate no longer holds that office at the time the Tnistee authenticates such Certificate, such Certificate will nevertheless be valid. If a person signing a Certificate is the proper officer on the actual date of execution, the Certificate will be valid even if that person is not the proper officer on the noYniY~al date of action. Section 2.03. Authentication. The Certificates will bear a certificate of authentication, substantially in the form set forth in Exhibit B, and no Certificate will be valid until the Trustee has duly executed the certificate of authentication and inserted the authentication date thereon. The Trustee will authenticate each Certificate with the signature of an authorized officer or employee, but it will not be necessary for the same person to authenticate all of the Certificates. Only such authenticated Certificates will be entitled to any right or benefit under this Trust Agreement, and such certificate on any Certificate issued under this Trust Agreement will be conclusive evidence that the Certificate has been duly issued and is secured by the pro~risions hereof. Section 2.04. Registration and Exchange of Certificates; Persons Treated as O~~ners. Certificates may be exchanged and transferred only on a register which the Trustee will establish and maintain. Upon surrender for transfer of any Certificate to the Trustee, duly endorsed for transfer or accompanied by an assignment duly executed by the Owner or the Owner's duly authorized attorney, the Trustee will authenticate a new Certificate or Certificates in an equal total principal amount and registered in the name of the transferee; provided, however, that the Trustee is not required to exchange or register the transfer of any Certificate after the giving of notice calling such Certificate for prepayment. J3862v2 7 Certificates may be exchanged for an equal total principal amount of Certificates of different but authorized denominations. The Trustee will authenticate and deli~Ter Certificates that the Owner making the exchange is entitled to receive, bearing numbers not then Outstanding. The Trustee will deliver to the transferee any applicable notice of prepayment when it effects a transfer or exchange of any Certificate after the mailing of notice calling the Certificate or any portion of the Certificate for prepayment. The Owner will be the absolute owner of the Certificate for all purposes, and payment of principal, premium, if any, and interest v~Jill be made only to or upon the written order of the Owner or the Owner's legal representative, except that interest payments will be made to the person shown as the owner of the Certificate as of the applicable Record Date. The Trustee must require the payment by an Owner requesting exchange or transfer of any tax or other governmental charge required to be paid in respect of the exchange or transfer, but must not impose any other charge. Section 2.05. Mutilated, Lost, Stolen or Destroyed Certificates. (a) If any Outstanding Certificate is damaged, mutilated, lost, stolen or destroyed, the Company will execute, and the Trustee Till authenticate and deli~Ter, a replacement Certificate, of the same tenor as the damaged, mutilated, lost, stolen or destroyed Certificate, in the manner provided below. (b) Application for exchange and substitution of damaged, mutilated, lost, stolen or destroyed Certificates must be made to the Trustee. In every case, the applicant for a replacement Certificate must furnish to the Company, the County and the Trustee such security or indermuty as each may require to save it harmless. In every case of loss, theft or destruction of a Certificate, the applicant must also furnish to the Company, the County and the Trustee evidence to their satisfaction of the loss, theft or destruction of such Certificate. In the case of damage or mutilation of a Certificate, the applicant will surrender the Certificate so damaged or mutilated. (c) Notu~•ithstanding the foregoing, if any such Certificate has matured, and no default is then continuing in the payment of the principal or interest with respect to such Certificate, the County may authorize the payment of the same (~~rithout surrender thereof except in the case of a damaged or mutilated Certificate} instead of issuing a substitute Certificate, provided security ar ~3 s6zti~z g indemnity is furnished as provided above in the case of a lost, stolen or destroyed Certificate. (d) The Trustee will charge the O«uer of such Certificate ti~rith all expenses in connection uTith the issuance of any substitute Certificate. Every substitute Certificate issued pursuant to the provisions of this Section because any Certificate is lost, stolen or destroyed, whether or not the lost, stolen or destroyed Certificate may be found at any time, ar may be enforceable by anyone, ~~Till be entitled to all the benefits of this Trust Agreement equally and proportionally with any and all other Certificates duly executed and delivered hereunder. Section 2.06. Cancellation. Whenever a. Certificate is delivered to the Trustee for cancellation (upon payment, prepayment or otherwise} or for transfer, exchange ar replacement, the Trustee urill promptly destroy the Certificate and deliver a written certificate of such destruction to the County. Section 2.07. Temporary Certificates. Prior to the preparation of Certificates in definitive farm the Company may execute, and the Trustee may authenticate and deliver, temporary Certificates in such denominations as the County may determine, but otherwise in substantially the form set forth in Exhibit. B, with appropriate variations, omissions and insertions. The Company will promptly prepare, execute and deliver to the Trustee before the first Certificate Payment Date for such Certificates in definitive form and thereupon, upon surrender of Certificates in temporary farm, the Trustee will authenticate and deliver in exchange therefor Certificates in defintive farm of the same maturity having an equal aggregate principal amount. Until exchanged for Certificates in definitive form, Certificates in temporary form will be entitled to the lien and benefit of this Trust Agreement. Section 2.08. Non-Presentment of Certificates. (a) If any Certificate is not presented for payment when the principal with respect to the same becomes due (whether at maturity, upon acceleration or call for prepayment or otherv~~•ise}, all liability to the Owner thereof for the payment of such Certificate will be completely discharged if funds sufficient to pa~J such Certificate and the premium, if any, and interest due with respect thereto are held by the Trustee for such Owner's benefit, and thereupon it will be the Trustee's duty to bald such funds subject to subsection (b) belo~T, without liability for interest thereon, for the benefit of such Owner, ti~rho will thereafter be restricted exclusively to such funds far any claim of ~~rhatever nature under this Trust Agreement with respect to such Certificate. J3862v2 g (b) Notwithstanding any provision of this Trust Agreement to the contrary, the Trustee will dispose of moneys held by it for the payment of principal, premium, if any, or interest with respect to Certificates left unclaimed for five years after the date the principal with respect to the same becomes due in accordance with N.C. Gen. Stat. Sec. 116B-51 or any successor provision. The Owners of such Certificates will thereafter be entitled to look only to their remedies under N.C. Gen. Stat. Chapter 116B or any successor provision, and all liability of the County and the Trustee ujith respect to such moneys urill cease. ARTICLE III PREPAYMENT Section 3.01. Prepayment Dates and Prices. The 2006A Certificates may not be prepaid except as provided in tlus Section. (a) 2006A Certificates maturing on or after April 1, 2017, are subject to prepayment at the County's option on or after April 1, 2016, in whole at any time or in part on any Certificate Payment Date, upon payment of the principal amount to be prepaid plus interest accrued to the prepayment dates, without premium. (b) 2006A Certificates maturing on April 1, 2026, are required to be prepaid in part prior to maturity pursuant to the terms of the sinking fund requirements of Section 3.05 at a prepayment price equal to the principal amount to be prepaid plus interest accrued to the prepayment date, urithout premium. (c) The 2006A Certificates are subject to prepayment u1 whole or in part. on any Certificate Payment Date from Net Proceeds transferred to the Prepayment Account pursuant to Section 4.OG at a prepayment price equal to the principal amount to be prepaid plus interest accrued to the prepayment date, without premium. (d} The amendment or supplement to this Agreement providing for the issuance of Additional Certificates, as provided iri Section 1.05{iii), v~Till provide for the prepayment terms and conditions of an~j Additional Certificates. Section 3.02. Selection of Certificates far Prepayment. (a) If less than all of the Certificates are to be prepaid pursuant to subsection 3.01(a) or 3.01(c}, they ujill be prepaid as among maturities in such manner as the County maSj elect. J3862v2 10 (b) If less than all of the Certificates of any maturity are to be prepaid, the Trustee will select the Certificates to be prepaid by lot; provided, however, that so long as a book-entry system ujith DTC is used for determiiung beneficial ownership of Certificates, if less than all of the Certificates within a maturity are to be prepaid, DTC will determine which of the Certificates within any such maturity are to be prepaid in accordance with DTC's own rules and procedures. (c) In any case, (1 }the portion of any Certificate to be prepaid will be in the principal amount of $5,000 or some multiple thereof,, and (2) in selecting Certificates for prepayment, each Certificate will be considered as representing that number of Certificates which is obtained by dividing the principal amount of such Certificate by $5,000. If a portion of a Certificate will be called far prepayment, a new Certificate in principal amount equal to the unpaid portion thereof will be issued to the registered owner upon the surrender thereof. Section 3.03. Prepayment Natives. (a) The Trustee, upon being satisfactorily indemnified with respect to expenses, will send notice of prepayment no less than 30 nor more than GO days prior to the prepayment date, by registered or certified mail, return receipt requested, as follouTs: (1) If DTC or its nominee is the registered owner of the Certificates, to DTC. (2) If no book-entry-only system of registration is in effect, to each of the registered owners of the Certificates at their addresses as shown on the Trustee's registration books. (3) In any case, to at least two national information services which disseminate redemption and prepayment information, such as the following: (A) Financial Information, Inv.'s Daily Called Bond Service 30 Montgomery Street, 10th Floor Jersey City, New Jersey 07302 Attention: Editor; (B) Keruzy Information Service's Called Bond Service 55 Broad Street, 28th Floor New York, New York 10004; (C) Moody's Municipal and Government Called Bond Record 99 Church Street, $th Floor 93 362v2 11 New York, New York 10007 Attention: Municipal News Report; and {D)Standard &. Poor's Called Bond Record 55 Water Street New York, New York 10041. (4) In any case, to the Insurer. Failure to give any notice specified in (1) or (2), as applicable, or any defect therein, will not affect the validity of any proceedings for the prepayment of any Certificates ti~Jith respect to v~rlnich no such failure has occurred. Failure to give any notice specified in {3} or {4), or any defect therein, will not affect the validity of anyT proceedings for the prepayment of any Certificates with respect to which the 1lotlce specified in (1) or (2) is correctly gizTen. Any notice mailed as provided herein will conclusively be presumed to have been given regardless of whether actually received by any Owner. (b) Any prepayment notice, except a prepayment notice in respect of a sinking fund payment date, may state that the prepa~Tment to be effected is conditioned upon the Trustee's receipt on or prior to the prepayment date of moneys sufficient to pay the principal of and premium, if any, and interest on the Certificates to be prepaid, and that if such moneys are not so received such notice shall be of no force or effect and such Certificates shall not be required to be prepaid. If such notice contains such a condition and the Trustee does not receive moneys sufficient to pay the principal of and premium, if any, and interest on such Certificates on or prior to the prepayment date, the prepayment u~•ill not be made and the Trustee will, within a reasonable time thereafter, give notice, in a mariner in ti~rhich the prepayment notice ~~jas given, that such moneys v~Tere not so received. {c) Each prepayment notice must specify (1) the complete designation, including Series, of the Certificates to be prepaid, {2} the certificate and CUSIP numbers of the Certificates to be prepaid, (3) the dated dates and maturity dates and the interest rates of the Certificates to be prepaid, (4) the date fixed for prepayment, (5) the principal amount of Certificates or portions thereof to be prepaid, (6) the applicable prepayment price, (7} the address of the place or places of payment, (8) tlne Trustee's name and telephone number, and the name of a contact person, (9) that payment of the principal amount and premium, if any, with respect to such Certificates will be made upon presentation and surrender of the Certificates to be prepaid to the Trustee, (10) that interest accrued to the date fixed far prepayment will be paid as specified in such notice, and (l 1 } that on and after the established prepayment date interest on Certificates which have been prepaid will cease to accrue. 93 362v2 12 In preparing such notices, the Trustee will take into account, to the extent applicable, any regulatory statement of any Federal or state administrative body ha~Ting jurisdiction over the tax-exempt securities industry, including, without limitation, Release No. 34-23856 of the Securities and Exchange Commission or any subsequent amending or superseding release. Section 3.04. Certificates Payable on Prepayment Date; Interest Ceases To Accrue. If on or before the date fixed for prepayment funds are deposited ~~Tith the Trustee to pay the principal, premium, if any, and interest accrued to the prepayment date with respect to the Certificates called for prepayment, the Certificates or portions thereof thus called for prepayment will cease to accrue interest from and after the prepayment date, will no longer be entitled to the benefits pro~Tided by this Agreement and will not be deemed to be Outstanding under this Agreement. Section 3.05. Mandatory Sinking Fund Prepayment. The Trustee, from amounts received from or on behalf of the County, will prepay 2006A Certificates maturing on April 1, 2026, on April l in }Tears and amounts upon payment of 100% of the principal amount thereof plus interest accrued to the prepayment date as follows: Year Amount 2024 2025 2026 Notwithstanding the foregoing, on or before the 70th day next preceding any sinking field payment date, the County may do any or all of the follov~Ting: {1) pay to the Trustee for deposit in the PrepayTment Account such amount as the County may determine, accompanied by a certificate signed by a County Representative directing the Trustee to apply such amount to the purchase of Certificates required to the prepaid on such sinking fund payment date; the Trustee must thereupon use all reasonable efforts to expend the greatest portion of such funds as may be practicable iri the purchase of such Certificates at a price not exceeding the principal amount thereof plus accrued interest to the purchase date; or (2) deliver to the Trustee for cancellation Term Certificates required to be prepaid on such sinking fund payment date in any aggregate principal amount desired, or J3862v2 13 (3) instruct the Tnistee to apply a credit against the County's sinking fund payment obligation for any such Term Certificates that previously have been prepaid (other than through the operation of the sinking fund requirements) and canceled by the Trustee but not previously applied as a credit against any sinking fund payment obligation. The Trustee will credit against the County's sinking fiuzd payment obligation on such sinking fund payment date the amount of such Certificates so purchased, delivered or previously prepaid as described in paragraphs (1), (2) or (3} abo~Te. Within seven days of receipt of such amount, Term Certificates or instruction to apply a credit (as described in paragraphs (1), (2) and (~) above), any amounts remaining in the Principal Account in excess of the amount required to fulfill the remainng required sinking fund prepayment obligation on the next sinking filed payment date will, as directed by a County Representative, either be (A) transferred to the Interest Account or (B) used to prepay Certificates as soon as practicable. Any funds received by the Trustee pursuant to paragraph (1) above but not expended as provided therein for the purchase of Certificates ujithin twenty days after such 70th day ~.•ill be transferred to the Principal Account to the extent the amounts in the Principal Account are insufficient to fulfill the required payment on the next principal or sinking fund payment date. To the extent amounts in the Principal Account are not so insufficient, the Trustee will, as directed by a County Representative, either (A) transfer such fiends to the Interest Account or (B) use the funds to prepay Certificates as soon as practicable. ARTICLE IV PROJECT FUND; OTHER FUNDS AND ACCOUNTS Section 4.01. Creation and Use of Project Fund. The Trustee will establish a special fund designated as the "Orange County 2006 Public Improvement Projects Fund." The Trustee will keep such Fund separate and apart from all other funds and moneys held by it, and will hold and administer such Fund as pro~Tided in tlus Trust Agreement. Moneys in the Project Fund will be expended only for Project Costs, except as provided in Section 4.03. Section 4.02. Deposit of Moneys; Payment of Project Costs. (a) The Trustee will deposit into the Project Fund the amount specified in the certificate referenced in Section 1.04(e}, any amount to be deposited therein as specified in the certificate referenced in Section 1.0~(~T), an}r amounts received as 93 362v2 14 refunds of State sales tax with respect to expenditures for Project Costs previously paid far from Project Fund amounts and all other amounts paid to it far deposit in the Project Fund. (b) Subject to the limitations in paragraph (d) belouJ, the Trustee ujill disburse moneys in the Project Fund from time to time, either to pay Project Costs directly or to reimburse the County for previous expenditures for Project Costs, upon receipt by the Trustee of a requisition substantially in the form of Exhibit C. The Trustee may rely conclusively on such requisitions as authorization for such payments and will have no duty or responsibility to verif~r any matters therein. (c) Unless otherwise directed by the County, the Trustee will disburse moneys from the Project Fund that are due to the County by wire transfer to such bank account or accounts in the United States as the County may designate from time to time by notice to the Trustee. (d) The Trustee shall not, hov~Tever, be required to (but may in its discretion} disburse any moneys from the Project Fund during the continuation of anyT E~Tent of Default, except that the Trustee will make such disbursements if so directed by the Insurer. Section 4.03. Transfers of Unexpended Proceeds. Upon receipt of the Completion Certificate, the Tnistee will withdraw all remaining moneys in the Project Fund (other than any moneys to be retained therein pursuant to the Completion Certificate) and deposit such moneys in the Payment Fund to be applied to the payment of principal and interest ~~Tith respect to the 2006A Certificates as directed by a County Representati~-~e. Section 4.04. Other Funds and Accounts. The Trustee will establish the following special funds and accounts, will keep the same separate and apart from all other funds and moneys held by it, and will hold and administer the same as provided herein: (a) Orange County 2006 Public Improvement Projects Payment Fund, and therein an Interest Account, a Principal Account and a Prepayment Account; and (b} Orange County 2006 Public Improvement Projects Net Proceeds Fund. Section 4.0~. Pa~~ment Fund. {a} The Trustee will deposit in the Interest Account in the Payment Fund the amount specified in the certificate J3862v2 15 referenced in Section 1.04{e), and will deposit in the proper account all other amounts paid to it for deposit in the Payment Fund. (b) The Trustee ~~~ill pay the principal and interest with respect to Certificates from the Principal Account and the Interest Account, respectively, as the same become due. (c) The TrLtstee will determine whether any amounts are on deposit with the Trustee that are to be credited against the amount of the County's Installment Payments at the times and in the manner provided for in [Section 2.1(b)] of the Financing Contract. (d} On the second Business Day preceding each Certificate Payment Date, the Trustee will first set aside an amount sufficient to pay the interest with respect to the Certificates becoming due and pa}cable on such Certificate Payment Date, and then an amount sufficient to pay the principal ~~•ith respect to the Certificates becoming due and payable on such Payment Date, and v~Till transfer on the Certificate Payment Date the amounts due to DTC as registered owner of the Certificates. (e} If the amount on deposit in the Principal Account or the Interest Account is insufficient for the purposes thereof t~vo Business Days before any Certificate Payment Date, the Trustee ~~rill notify the County of the amount of such insufficiency and the Trustee will transfer to such Accounts such amounts as may be necessary therefor from the Prepayment Account. If the amount on deposit in the Interest Account on any Certificate Payment Date exceeds the amount payable on account of interest on the Certificates on such date, the Trustee will, as directed by a County Representative, retain such excess in the Interest Account or transfer such excess to the Principal Account to be credited against subsequent required deposits thereto. If the amount on deposit in the Principal Account on any [September 1] exceeds the amount required on such date to pay principal of Certificates coming due on such date (whether by reason of maturity or mandatory redemption}, then the Trustee will, as directed by a County Representati~Te, retain such excess in the Principal Account or transfer such excess to the Interest Account to be credited against subsequent required deposits thereto. (f} The Trustee will deposit in the Prepayment Account of the Payment Fund all amounts paid to it for deposit therein, and, except as provided in subsection {g) below, will use such amounts within 12 months of their deposit therein as directed by a County Representative (1) to pay Certificates called for 93 362v2 16 prepayment on their prepayment dates, or (2) to purchase, for cancellation;. Certificates at or below their prepayment price on the next date on which such Certificates maybe prepaid. The Trustee u~•ill transfer any amounts not so used u~•ithin 12 months of their deposit in the Prepayment Account to the Interest Account in the Payment Fund for use on the next Certificate Payment Date to pay interest with respect to the Certificates, and pending such use will invest such funds in Permitted Investments ha~Ting a yield not in excess of the Restricted Yield. Subject to retaining moneys necessary to pay Certificates that have been called for prepayment but not yet presented for payment, the Trustee will use amounts in the Prepayment Account as needed to make transfers to the Interest Account or the Principal Account to the extent the balances therein may be insufficient for the purposes thereof. {g) The Trustee will hold amounts transferred to the Prepayment Account from the Net Proceeds Fund pursuant to Section 4.OG(b} and apply such amounts to the prepayment of Certificates pursuant to Section 3.01(c} as directed by a County Representative. Section 4.06. Net Proceeds Fund. (a) The Trustee will deposit Net Proceeds in the Net Proceeds Fund as provided in [Section 6.2(c)] of the Financing Contract. The Trustee will invest and reinvest all amounts on deposit in the Net Proceeds Fund in Permitted Investments having a yield not in excess of the Restricted Yield, to the extent such amounts are on deposit therein on any date follouTing the later of (1 }the third anniversary of the Closing Date or (2} 30 days from the payment of such Net Proceeds to the County or the Trustee, as applicable. (b) The Trustee hill disburse Net Proceeds for replacement or repair as pro~Tided in [Section G.3(c)] of the Financing Contract, or transfer such proceeds to the Prepayment Account in the Payment Fund for application as provided in Section 4.05(g), in either case as directed by a County Representative as provided in [Section 6.3] of the Financing Contract. The Trustee shall not, however, be required to (but may in its discretion} disburse an~J moneys from the Net Proceeds Fund during the continuation of an Event or Default, except that the Trustee ~~Till make such disbursements if so directed by the Insurer. {c) If the County directs the Trustee to apply amounts on deposit in the Net Proceeds Fund to the prepayment of Certificates pursuant to [Section 6.3(a} or 6.3(b}] of the Financing Contract, the Trustee will provide for such prepayment pursuant to Section 3.01(c} at the earliest practicable date. Pending disbursement for prepayment, the Trustee will hold such amounts in the Net Proceeds Fund and 93 862v2 17 invest such amounts only in Federal Securities having a maturity date not later than the prepayment date. (d) After all principal and interest ti~Tith respect to the Certificates has been paid in full, and all the Trustee's fees and expenses hay-re been paid, or provision has been made for the payment thereof satisfactory to the Tnistee, the Trustee will pay any moneys remaining in the Net Proceeds Fund to the County. ARTICLE V SECURITY PROVISIONS Section 5.01. Security Provisions. (a) Assignment o, f Rights under Financing Contt°act. The Company transfers and absolutely assigns to the Trustee, far the benefit of the Owners and without recourse against the Company, all of the Company's rights under the Financing Contract, including, without limitation, (i) the right to receive and collect all of the Installment Payments, (ii} the right to take all actions and give all consents under the Financing Contract, and (iii) the right to exercise such rights and remedies conferred on the Company pursuant to the Financing Contract as may be necessary or convenient (A) to enforce payment of the Contract Payments and any other amounts required to be deposited in any Fund established under this Trust Agreement, or (B} otherujise to protect the Owners' interests if the County defaults under the Financing Contract. Any Installment Payments collected or received by the Company ~~Till be deemed to be held and to have been collected or received by the Company as the Trustee's agent, and if received by the Company at. any time will be deposited by the Company with the Trustee within one Business Day after the receipt thereof. (b) A.s.si~~nment o, f Rights under Deed o, f Trust. The Company transfers and absolutely assigns to the Trustee, for the benefit of the Owners and uJithout recourse against the Company, all of the Company's rights as beneficiary under the Deed of Trust. (c) As.sigrcment of1l~Ione~s and ~nvest~nents. The Company absolutely assigns to the Trustee, for the benefit of the Owners and without recourse against the Company, all moneys and investments thereof held by the Trustee in the Funds and Accounts under this Trust Agreement. The Trustee will hold all such moneys in trust and will apply the same to the purposes specified herein and in the Financing Contract. The foregoing assignments are absolute and not for the purpose of security. 93 362v2 18 Notwithstanding the foregoing assignments, the Company will retain its rights to notices, indemnification and payment of costs under the Financing Contract and the Deed of Trust. Section 5.02. Limited Obligation. Each Certificate will evidence a proportionate and undivided ownership interest in Installment Payments. The Certificates are payable solely from Installment Payments as, when and if the same are recei~Ted by the Trustee, except to the extent payTable from the proceeds of the Certificates, income from investments, and Net Proceeds as provided in this Trust. Agreement and the Financing Contract, which Installment Payments and other moneys have been pledged as provided herein to secure payment of the Certificates. ARTICLE VI INVESTMENT OF MONEYS IN FUNDS Section 6.01. In~~estments Authorized. (a) Subject to the further provisions of this Article VI, the Trustee will invest and reinvest moneys held by it hereunder, upon the written direction of a County Representative, in Permitted Investments. Such investments, if registrable, will be registered in the name of the Trustee or its assignee far the benefit of the Owners and held by the Trustee. If the County does not provide the Trustee with written direction as to any in~Testment or reinvestment provided for under this Trust Agreement, the Trustee will invest or reins-rest such moneys in the North Carolina Capital Management Trust (or its successor). (b) The Trustee will invest and reinvest amounts on deposit from time to time in the Project Fund only iri Permitted Investments having a yield not in excess of the Restricted Yield to the extent any such amounts remain on deposit therein (or remain on deposit in the Payment Fund after being transferred there pursuant to Section 4.03) on any date following the later of (a} the third aruuversary of the Closing Date or (b) 30 days from their deposit in the Project Fund. (c) The Trustee may purchase or sell, to itself or to any affiliate, as principal or agent, investments of funds held under this Trust Agreement. The Trustee may act as purchaser or agent in the making or disposing of any investment, and may make any investment through its bond or investment department. J3862v2 19 (d) The Trustee will not be responsible or liable for any loss suffered in connection with any investment of funds made by it in accordance lvith this Section. (e} Moneys u~•ill be invested in Permitted Investments having maturities not extending beyond the date on which the County estimates such moneys are to be needed for their intended purposes. Investments will be considered as maturing on the date on which they are redeemable without penalty at the holder's option or the date on which the Trustee may require their repurchase without penalty pursuant to a repurchase agreement. Section 6.02. Held in Trust. The moneys and investments held by the Trustee under this Trust Agreement are irrevocably held in trust for the benefit of the O~~Tners, and such mone~rs, and an~j income or interest earned thereon, will be expended only as provided in this Trust Agreement, and will not be subject to levy or attachment or lien by or for the benefit of any creditor of the Company, the Trustee or the County. Section 6.03. Investments Part of Fund. Any income, profit or loss on the investment of moneys held by the Trustee hereunder uTill be credited to the respective fund to which such moneys are credited, except as otherwise provided herein. Section 6.04. Accounting. The Trustee will furnish to the County, not less frequently than monthhT, an accounting of all investments made by the Tnistee in all funds and accounts held by the Tnistee. Such accounting may be supplied in the form of the Trustee's customary statements. The Trustee u~•ill keep accurate records of all funds admiiustered by it and of all Certificates paid and discharged. Section 6.05. Valuation. For the purpose of determining the amount on deposit in any Fund or Account held under this Trust Agreement, the Trustee ~~Till ~Talue all Permitted Investments credited to such Fund or Account at the market value thereof. Such valuations will be made at least every six months and at such additional times as the County may request, but in no event more frequently than monthly. Section 6.06. Disposition. The Trustee will sell, or present for redemption, and reduce to cash any Permitted Investment in a Fund or Account at. the best price obtainable whenever the cash balance in such Fund or Account is insufficient for the purposes thereof. Section 6.07. Commingling of Moneys in Funds. The Trustee, at its sole discretion and upon a County Representative's appro~Tal, may commingle any J3362v2 20 of the funds held by it pursuant to this Trust Agreement with any other separate fund or funds for investment purposes only; provided, however, that the Trustee will separately account for all Funds or Accounts held by it under this Trust Agreement. Section 6.08. Tax Covenants. The County, the Company and the Trustee covenant with the Owners that, notwithstanding any other provision of this Trust Agreement, they ~~jill make no use or investment of the proceeds of the Certificates v4-hich will cause the Certificates to be "arbitrage bonds" or "private activity bonds" within the meaning of the Code. Section 6.09. Information Concerning Investments. The Trustee ti~Jill establish and maintain written records regarding investments made under this Article VI, and ~~Till supply such information to the County at its request, including information as to: {a) purchase date; (b) purchase price; (c) information establishing that the purchase was at a fair market value as of the purchase date {e.g., the published quoted bid by a dealer in such an investment on the purchase date); (d) any accnied interest paid; (e) face amount; {f) coupon rate; {g) periodicity of interest payments; (h) disposition price; (i) any accrued interest received; and (j} disposition date. Section 6.10. Restricted Yield Investments. The Trustee may invest funds held hereunder without regard to yield despite any provision herein directing investment with regard to the Restricted Yield provided that prior to making such an investment, the Trustee receives an Opinion of Special Counsel that such an investment will not adversely affect the exclusion from gross income that would otherwise be applicable to interest components of Installment Payments. ARTICLE VII DISCHARGE OF TRUST AGREEMENT Section 7.01. Certificates Deemed Paid; Discharge of Trust Agreement. Any Certificate will be deemed paid for all purposes of this Trust Agreement when (a) payment of the principal and interest with respect to such Certificate to the due date of such principal and interest (whether at maturity, upon prepayment or otherwise) either (i) has been made in accordance ~~Tith the terms of the Certificates or {ii) has been provided for by irrevocably depositing with the Trustee or other fiduciary in escrow (A) cash sufficient to make such payment or {B) Federal Securities maturing as to principal and interest u1 such amounts and at such times as will insLlre, without rein~restment, the availability of sufficient moneys to make such payment (which will be evidenced or verified by a certificate or other writing, in form and substance satisfactory to the Trustee, of a firm of independent certified public accountants acceptable to the Trustee), and which are 93 362v2 21 not subject to redemption or purchase prior to maturity at the option of anyone other than the holder, and (b) all compensation and expenses of the Trustee pertaining to each Certificate in respect of which such deposit is made have been paid or pro~Tided far to the Trustee's satisfaction. When a Certificate is deemed paid, it will no longer be secured by or entitled to the benefits of this Trust Agreement, and all rights to payment of such Certificates will be limited to payment from moneys or Federal Securities under {a}(ii) above, and except that it may be transferred, exchanged, registered or replaced as provided in Article II. Notwithstanding the foregoing, no deposit Colder clause (a)(ii) above uJill be made until the County has fi~rnished the Trustee an Opinion of Special Counsel to the effect that the deposit of such cash or Federal Securities will not cause the Certificates to become "arbitrage bonds" within the meaning of the Code. Also, if the Certificate is to be prepaid prior to maturity, notice of prepayment of the Certificate must be given in accordance ujith Article II for such deposit to be deemed a payment of such Certificate. Alternatively, if the Certificate is not to be paid or prepaid within the next 60 days, the County must give the Trustee, in form satisfactory to the Trustee, irrevocable instnictions (A) to provide notice, as soon as practicable, in accordance with Article II, that the deposit required by (a)(ii) above has been made with the Trustee and that the Certificate is deemed to be paid under this Article and stating the maturity or prepayment date upon which moneys are to be available for the payment of the principal with respect to the Certificate, and (B) to give notice of prepayment not less than 30 nor more than 60 days prior to the prepayment date far such Certificate as provided in Section 3.03. When all Outstanding Certificates are deemed paid under the foregoing prop-risions of this SeGtlon, the Trustee Till upon request acknowledge the discharge of the lien of this Trust Agreement and the Deed of Tnist and repay any excess amounts remaining on deposit in the Funds established under this Trust Agreement to the County; provided, however, that the obligations under Article II in respect of the transfer, exchange, registration, discharge from registration and replacement of Certificates will sur~~ive the discharge of the lien of this Trust Agreement, and further provided that in the case of a deposit made under {a)(ii) above, the Certificates v~Till continue to constitute proportionate and undivided interests in Installment Payments arising under the Financing Contract. No deposit will be made or accepted and no use made of any such deposit that u~•ould cause any Certificates to be treated as "arbitrage bonds" within the meaning of the Code. Section 7.U2. Application of Trust Money. The Trustee gill hold in trust money or Federal Securities deposited with it pursuant to Section 7.01 and will apply the deposited money and the money paid with respect to the Federal 93862v2 22 SecL~rities in accordance with this Trust Agreement only to the payment of principal, premium, if any, and interest lvith respect to the Certificates. ARTICLE VIII DEFAULTS; REMEDIES Section 8.01. Events of Default. An "Event of Default" is any of the follo~~ring: (a) Default in the payment of the principal with respect to any Certificate when the same becomes due and payable, whether at the stated maturity thereof or upon proceedings for mandatory (but not optional) prepayment. (b) Default in the payment of any installment of interest with respect to any Certificate when the same becomes due and payable. (c) The occurrence of any Event of Default as defined in the Financing Contract. Section 8.02. Acceleration. If any Event of Default occurs and is continuing, then (a} the Trustee, with the Insurer's consent and by notice to the County, or (b) the Majority Owners, ujith the Insurer's consent and by notice to the County and the Trustee, may declare the principal of and accrued interest with respect to the Certificates to be due and payable immediately, and such principal and interest ~~Till thereupon become and be immediately due and payable. The Trustee uTill immediately give notice of acceleration to the Owners and the Insurer. The Trustee, with the Insurer's consent may, and upon the Insurer's direction will, rescind an acceleration and its consequences if all existing Events of Default have been cured or waived, if the rescission would not conflict with any judgment or decree. Section 8.03. Other Remedies. If an Event of Default occurs and is continuing, the Trustee may pursue any available remedy by proceeding at law or in equity to collect the principal or interest with respect to the Certificates or to enforce the performance of any provision of tlus Trust Agreement, the Certificates, the Financing Contract or the Deed of Trust. The Trustee may maintain a proceeding even if it does not possess any of the Certificates or does not produce any of them in the proceeding. A delay or omission by the Trustee or an}r O~~rner in exercising any right or remed}r accruing upon an Event of Default will not impair the right or remedy or constitute a waiver J3862v2 ~3 of or acquiescence in the Event of Default. No remedy is exclusive of any other remedy. All available remedies are cumulative. Section 8.04. Waiver of Past Defaults. The Majority Owners, with the Insurer's consent and by notice to the Trustee, may waive an existing Event of Default and its consequences. When an Event of Default is ti~raived, it is cured and stops continuing, but no such waiver will extend to any subsequent or other Event of Default or impair any right consequent to it. Section 8.05. Majority's Control. The Majority O~~ners may, upon satisfactory indemnification of the Trustee, direct the time, method and place of conducting any proceeding for any remedy available to the Trustee or of exercising any trust or pou~•er conferred on it. The Trustee, however, may refuse to follow any direction that conflicts with law or tlus Trust Agreement or, subject to Section 9.01, that the Trustee determines is unduly prejudicial to the rights of other Owners or would involve the Trustee in personal liability. Section 8.06. Limitation on Suits. An Owner may not pursue any remedy lvith respect to this Trust Agreement or the Certificates {except as provided in Section $.07) unless {a) the O~~jner gi~Tes the Trustee notice stating that an Event of Default is continuing, (b) the Majority Owners make a written request to the Trustee to pursue the remedy, (c} such Owner or Owners offer to the Trustee indemnity satisfactory to the Trustee against any loss, liability or expense, and (d) the Trustee does not comply u~•ith the request uTithin 60 days after receipt of the request and the offer of indemnity. An Owner may not use this Trust Agreement to prejudice the rights of another Owner or to obtain a preference or priority over the other Owners. Section 8.07. Rights Ta Receive Payment. The right of any Owner to receive payment of principal, premium, if any, and interest ti~rith respect to a Certificate, on or after the due dates expressed in the Certificate, or to bring suit for the enforcement of any such payment on or after such dates, uTill not be impaired or affected without such Owner's consent. Section 8.08. Collection Suit by Trustee. If an Event of Default occurs and is continuing, the Trustee may recover judgment in its own name and as trustee of an express trust against the County for the whole amount remaining unpaid. Section 8.09. Trustee May File Proofs of Claim. (a) The Trustee may file such proofs of claim and other papers or documents as may be necessary or advisable in order to have the claims of the Trustee and the O~~Jners allo~ved in anv judicial proceedings relati~Je to the County, the Company, their creditors or their 93 362v2 ~4 property and, unless prohibited by law or applicable regulations, may vote on behalf of the Owners in any election of a trustee in bankruptcy or other person performing similar functions. (b) If the Trustee incurs expenses or renders services in any proceedings which result from an Event of Default, or from any event or occurrence which, with the passage of time, v~Tould become an Event of Default, the expenses so incurred and compensation far services so rendered are intended to constitute expenses of admiiustration under the United States Bankruptcy Cade or equi~Talent lau~•. Section 8.10. Insurer's Control. Notwithstanding any provision of this .Article VIII to the contrary, neither the Trustee nor the Owners may declare any acceleration pursuant to Section 8.02, pursue any remedy, waive an}r E~Tent of Default or otherujise control or direct any proceedings on default without the Insurer's consent, except that an Owner shall in all cases have the rights provided in Section 8.07. The Trustee must take any such action as the Insurer may direct. Section 8.11. Priorities. If the Trustee collects any money pursuant to this Article, it will deposit the same in a special account in the Payment Fund and pay out such money in the fo1lo~Ting order: (a) If the principal with respect to all Certificates has not become or will not have been declared due and payable, all such moneys in the Payment Fund will be applied: First, Costs and Expenses: to the payment of the costs and expenses of the Trustee and of the Owners in declaring such Event of Default, including reasonable compensation to its or their agents, attorneys and counsel; Second, Interest: to the payment to the persons entitled thereto of all installments of interest then due in the order of the matL~rity of such installments, and, if the amount available is not sufficient to pay u1 full any installment or installments maturing on the same date, then to the payment thereof ratably, according to the amounts due thereon, to the persons entitled thereto, without any discrimination or preference; and Third, Principal: to the payment to the persons entitled thereto of the unpaid principal with respect to any Certificates which have become due, whether at maturity or by call for prepayment, in the order of their due dates, with interest on the overdue principal at a rate equal to the rate paid uTith respect to the Certificates, and, if the amount available uJill not be sufficient to pay in full all of the amounts due with respect to the Certificates on any date, together with such interest, then to 93862v2 25 the payment thereof ratably, according to the amounts of principal due on such date to the persons entitled thereto, lvithout any discrimination or preference. (b) If the principal with respect to all Certificates has become or been declared due and payable, all such money will be applied (i} first to pay the Trustee's fees and expenses, and then (ii) to the payment of principal and interest then due with respect to the Certificates, without preference or priority of principal or interest, or of any installment of interest over any other installment of interest, or of any Certificate o~Ter any other Certificate, ratably according to the amounts due respectively for principal and interest, to the persons entitled thereto without any discrimination ar privilege. (c) If the principal with respect to all Certificates has been declared due and payable and if such declaration thereafter has been rescinded and aruzulled under the provisions of Section 8.02, then, subject to the provisions of subsection (b} above, if the principal with respect to all Certificates later becomes due and payable or is declared due and payable, the money then remaining in and thereafter accruing to the Payment Fund will be applied in accordance with the provisions of subsection (a) above. The Trustee may fix a payment date for any payment to the Owners under this Section. Section 8.12. Undertaking for Costs. In anSj suit for the enforcement of any right or remedy under this Trust Agreement or in any suit against the Trustee for anyT action taken or omitted by it as Trustee, a court in its discretion may require the filing by any party litigant in the suit of an undertaking to pay the costs of the suit, and the court in its discretion may assess reasonable costs, including reasonable attorneys' fees, against any party litigant in the suit, having due regard to the merits and good faith of the claims or defenses made by the party litigant. Tlus Section does not apply to a suit by the Trustee or any authorized suit byj any Owner or O~~jners. ARTICLE IX THE TRUSTEE Section 9.01. Rights and Duties. (a) If an Event of Default has occurred and is continuing, the Trustee must exercise its rights and powers and use the same degree of care and skill in their exercise as a prudent person would exercise or use under the circumstances in the conduct of such person's o~vn affairs. J3862v2 ~~ (b) Nat later than August 1 of each year, the Trustee will notify the LGC of the principal amount of Certificates outstanding as of the preceding Tune 30. (c} Except during the continuance of an E~rent of Default: (i) the Trustee need perform only those duties that are specifically set forth in this Trust Agreement and no other; and (ii) in the absence of bad faith on its part, the Trustee may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed, upon certificates or opinions furnislled to the Trustee and conforming to the requirements of this Tnist Agreement which the Trustee actually a11d in good faith believes to be genuine and to have been signed or presented by the proper person. The Trustee, however, 111L1st examine the certificates and opinions to determine whether they conform to the requirements of this Trust Agreement. (d) The Trustee may not be relieved from liability for its Dorn negligent action, its own negligent failure to act or its own u.•illful misconduct, except that: (i) this paragraph does not limit the effect of subsection (a} above; (ii) the Trustee will not be liable with respect to any action it takes or omits to take in good faith in accordance with a direction received by it pursuant to Section 8.05; and (iii} no provision of this Trust Agreement requires the Trustee to expend or risk its own funds or otherwise incur any financial liability in the performance of any of its duties hereunder or in the exercise of any of its rights or powers, if it has reasonable grounds for believing that repayment of such fiends or adequate indemnity against such risk or liability is 11at reasonably assured to it. (e) Every provision of this Trust Agreement that in any way relates to the Trustee is subject to all the provisions of this Sectian 9.01. (f} The Trustee may refuse to perform any duty or exercise any right or power unless it receives indemnity satisfactory to it against any loss, liability or expense, but the Trustee may not require indemnity as a condition to declaring the principal and interest with respect to the Certificates to be due immediately under Sectian 8.02. No permissive right of the Trustee shall be construed as a duty. J3862v2 ~'] (g) The Trustee will not be liable for interest on any cash held by it except as the Trustee may agree with the County. (h) The Trustee ti~rill not be liable for any action it takes or omits to take in good faith in reliance on advice from counsel as to legal matters. (i) The Trustee may act through agents or co-trustees and will not be responsible far the misconduct or negligence of any agent or co-trustee appointed with due care. (j) If an event occurs which with the giving of notice or lapse of time would be an Event of Default, and if the event is continuing and if it is known to the Trustee, the Trustee will so notify the Owners and the LGC uTithin 15 days after such becomes known to the Trustee. Except in the case of a default in payment on any Certificates, the Trustee may withhold such notice from Owners (but not from the LGC) if and so long as it in good faith determines that withholding the notice is in the interest of Owners. (k) At any and all reasonable times, the Trustee and its agents will have the right to inspect the Project Sites, the Financed Facilities and all books and records of the Company or of the County related thereto. Notwithstanding anything in this Tnist Agreement to the contrary, the Trustee and its agents will have the right to require such additional evidence, certificates or Opinions of Counsel as the Trustee may deem appropriate to establish the County's right to the withdrawal of any funds held hereunder or to require the Trustee's taking of any other action hereunder. (1) The Trustee shall not be liable for any debts contracted or for damages to persons or to property injured or damaged, or for salaries or nonfulfillment of contracts, relating to the Financed Facilities. (m) The Trustee shall have no duty to inspect or oversee the construction or completion of the Financed Facilities. (n) In any judicial proceeding to which the Company or the County is a party and ~~rhich in the Trustee's opinion has a substantial bearing on the interests of Owners, the Trustee may intervene on the Owners' behalf, and ~~Jill do so if requested in ~Triting by the Owners of a majority in aggregate principal amount of Certificates then Outstanding or the Insurer and the Trustee ti~rill have a lien therefor on any and all funds any time held by it under this Tnist Agreement. Section 9.02. Trustee's Individual Rights. The Trustee in its individual or any other capacity may become the O~~Jner or pledgee of Certificates and may J3362v2 28 otherwise deal with the Company or with the County or its affiliates with the same rights it would have if it were not Trustee. Section 9.03. Disclaimer. The Trustee makes na representation as to the validity or adequacy of this Trust Agreement or the Certificates, and the Trustee will not be accountable for the County's use of the proceeds from the Certificates. Section 9.04. Eligibility. The Company will maintain a Trustee far this Trust Agreement that is a corporation organized and doing business under the laws of the United States or any state or the District of Columbia, is authorized under such laws and the laws of the State to exercise corporate trust powers, is subject to supervision or examination by the United States, any state or the District of Columbia and has a combined capital and surplus of at least $100,000,000 as set forth in its most recent published annual report of condition. Section 9.05. Resignation; Removal; Replacement. The Trustee may resign by notifying the County and the Insurer. The Majority owners, with the Insurer's consent, may remove the Trustee by notifying the County and the removed Trustee and may appoint a successor Trustee. The County, ujith the Insurer's consent, may remove the Trustee by notifying the removed Trustee. The Insurer may remove the Trustee at any time, by notifying the County and the remo~Ted Trustee, for any breach of the trust established in tlus Agreement. If the Trustee resigns or is removed or if a vacancy exists in the office of Trustee for any reason, the County, will promptly appoint a successor Trustee (except ujhen that right is exercised by the Majority OuTners as described in the preceding paragraph). No corporation will be eligible for appointment as successor Trustee unless such corporation {a) meets the requirements of Section 9.04 and {b) either has previously been approved by the LGC for service as a corporate trustee or obtains such appro~-~a1 from the LGC. A successor Trustee ujill deliver a written acceptance of its appointment to the retiring Tnistee and to the Count}~~. Immediately thereafter, the retiring Trustee will transfer all property held by it as Trustee to the successor Trustee; the resignation or removal of the retiring Trustee will then {but only then) become effective, and the successor Trustee will have all the rights, powers and duties of the Trustee under this Trust Agreement. If the Trustee fails to comply with Section 9.04, the County or any Owner may petition any court of competent j urisdiction for the removal of the Trustee and the appointment of a successor Trustee. J3862v2 ~9 If a successor Trustee does not take office within GO days after the retiring Trustee resigns or is removed, the retiring Trustee, the County, the Insurer or the Majority Owners may petition any court of competent jurisdiction for the appointment of a successor Trustee. Section 9.06. Successor Trustee by Merger. If the Trustee consolidates ~vitll, merges or con~jerts into, or transfers all or substantially all its assets (or, in the case of a bank or trust company, its corporate trust assets) to another corporation, the resulting, sur~Ti~Ting or transferee corporation ~~Tithout any further act uTill be the successor Trustee. Section 9.07. Acceptance of Financing Contract Terms. By its execution of this Trust Agreement, the Trustee hereby signifies its acceptance of its responsibilities under the Financing Contract, and agrees to be bound thereby. ARTICLE X AMENDMENTS OF AND SUPPLEMENTS TO TRUST AGREEMENT, CERTIFICATES, FINANCING CONTRACT OR DEED OF TRUST Section 10.01. Without Owners' Consent. (a) The Company and the Trustee may amend or supplement this Trust Agreement or the Certificates without notice to or consent of any Owner for the following purposes: (i) to cure any ambiguit<<r, inconsistency or formal defect or omission; (ii) to grant to the Trustee for the benefit of the Owners additional rights, remedies, powers or authority; {111} to subject to this Trust Agreement additional collateral or to add other agreements of the Company or the County; (iv) to modify this Trust Agreement or the Certificates to permit qualification under the Trust Indenture Act of 1939 or any similar federal statute at the time in effect, or to permit the qualification of the Certificates for sale under the securities laws of the United States or of any state of the United States; (v) to provide for Certificates in certificated, registered form pursuant to Section 2.01(b), or for the issuance of Additional Certificates; (vi} to e~jidence the succession of a new Trustee; or J3862v2 30 (Vll) to make any change that does not materially adversely affect the rights of any Owner. (b) The Company may enter into, and the Trustee may consent to, any amendment of or supplement to the Financing Contract or the Deed of Trust, without notice to or consent of any Owner, if the amendment or supplement is required or permitted {i) by the provisions of the Financing Contract or this Trust Agreement, (ii) to cure any ambiguity, inconsistency or formal defect or omission, {111) m COnneCtloll with any authorized amendment of or supplement to this Trust Agreement, or (iv} to make any change that does not materially adversely affect. the rights of anyJ Ot~ner. Section 10.02. With Owners' Consent. (a} If the preceding Section does not permit an amendment of or supplement to this Trust Agreement or the Certificates without any consent of Owners, the Company and the Trustee may enter into such amendment or supplement only uJith the consent of the Majority Owners and the Insurer. (b) If the preceding Section does not permit an amendment of or supplement to the Financing Contract or the Deed of Trust without any consent of Owners, the Company may enter into, and the Trustee may consent to, such amendment or supplement only v~Tit11 the consent of the Majority Owners and the Insurer. (c) Without the consent of each Owner affected, however, no amendment or supplement to this Trust Agreement, the Certificates, the Financing Contract or the Deed of Trust may (i} extend the maturity of the principal or interest ~Tith respect to any Certificate, (ii) reduce the principal amount of, or rate of interest on, any Certificate, (iii) effect a privilege or priority of any Certificate or Certificates over any other Certificate or Certificates, {iv) reduce the percentage of the principal amount of the Certificates required for consent to such amendment or supplement, (v) impair the exclusion of interest on the Certificates from the federal gross income of the Owner of any Certificate, (vi) eliminate ally mandatory prepayment of the Certificates, extend the due date for any call for mandatory prepayment, reduce the prepayment price or otheruTise change the prepayment terms of such Certificates, (vii) create a lien ranking prior to or on a parity with the lien of this Trust Agreement on the property pledged hereunder (except with respect to a parity pledge for the benefit of the Owners of Additional Certificates), or (viii) deprive any Owner of the lien created by this Trust Agreement on such property. In addition, if moneys or Federal Securities have been deposited or set aside with the Trustee pursuant to Article VII for the payment of Certificates and those 93 362v2 31 Certificates have not in fact been actually been paid in full, no amendment to the provisions of that Article may be made ujithout the consent of the Owner of each Certificate affected. Section 10.03. Procedure far Amendment with Owners' Written Consent. (a) If the consent of the 0~~,~ners is required pL~rsuant to Section 10.0? for an amendment or supplement to this Trust Agreement, the Certificates or the Financing Contract, the Trustee will establish a record date, and Owners as of such date will be the Owners with the right to consent to such amendment or supplement. Such record date v~Till be a date not later than five Business Days after the date the Trustee receives direction from the Company to solicit such consents. (b) The Trustee will send, by first class mail, a copy of such supplement or amendment, together with a request to the Owners for their consent thereto, to the Insurer and to each Owner at its address as set forth in the Certificate registration books maintained pursuant to Section 2.04, but failure to receive copies of such supplement or amendment and request so mailed ~jill not affect the ~Talidity of the supplement or amendment when assented to as provided in this Section. The request mailed by the Trustee ujill also designate a date not more than 60 nor less than 30 days following the mailing date by which consent must be returned to be effective. (c) Such supplement or amendment tivill not become effective unless there are filed with the Trustee the ~~~ritten consent of the Owners of not less than a majority in aggregate principal amount of the Certificates then Outstanding (exclusive of Certificates disqualified as provided in Section 10.04) and notices have been mailed as hereinafter in this Section provided. Each such consent will be effective o1~ly if accompaiued by proof of ownership of the Certificates for which such consent is given, wThich proof ~~jill be such as is permitted by Section 10.10. (d} If DTC is the registered owner of the Certificates, the Trustee will take such actions as may be appropriate to solicit the consents provided for in this Section from beneficial owners in accordance with DTC's rules and regulations, as the same may be in effect from time to time. Section 10.04. Disqualified Certificates. Certificates owned or held by or for the account of the County or the Company or by any person directly or indirectly controlling or controlled by, or under direct or indirect common control with the County or the Company (except any Certificates held in any pension or retirement fund) will not be deemed Outstanding for the purpose of any action or J3862v2 ~~ any calculation of Outstanding Certificates provided for in this Trust Agreement, and will not be entitled to take any action provided far in this Trust Agreement. The Trustee may provide far each Owner, before his or her consent provided for in this Article X will be deemed effective, to reveal if the Certificates as to which such consent is given are disqualified. Notwithstanding the foregoing provisions of this Section, it is the intent of the Company, the County and the Trustee that the ownership or holding of Certificates by the Company or the County will not, by itself, give rise to an extinguishment of the Certificates or any obligation arising under this Trust Agreement or the Financing Contract. Section 10.05. Effect of Consents. After an amendment or supplement becomes effective, it will bind every Owner. Any such consent will be binding upon and irrevocable by the Owner of the Certificate giving such consent and on any subsequent Owner {whether or not such subsequent Owner has notice thereof}, Lidless such consent is revoked in writing by the Owner giving such consent or a subsequent Owner by filing such revocation with the Trustee prior to the date when the notice provided for in Section 10.9 has been mailed. Section 10.06. Notation on or Exchange of Certificates. If an amendment or supplement changes the terms of a Certificate, the Trustee may require the O~~ner of such Certificate to deliver it to the Trustee. The Trustee maSj place an appropriate natation on the Certificate about the changed terms and return it to the Owner. Alternatively, if the Trustee, the Companyr and the CoLiltyj so determine, the Company, in exchange for the Certificate, will execute, and the Trustee uTill authenticate and deliver, a new Certificate that reflects the changed terms. Section 10.07. Trustee's Execution of Amendments and Supplements. The Trustee will execute and deli~Ter anyr amendment or supplement to the Trust Agreement or the Certificates authorized by this Article if the amendment or supplement does not adversely affect the rights, duties, liabilities or immunities of the Trustee. If the amendment or supplement has such an adverse effect, the Trustee may, but need not, execute and deliver the same. In executing and delivering an amendment or supplement, the Trustee will be entitled to recei~Te and (subject to Section 9.01) will be fully protected 111 relying on an Opinion of Counsel stating that such amendment or supplement is authorized by this Trust Agreement. Section 10.08. County's Consent Required. Na amendment or supplement to this Trust Agreement, the Certificates, the Financing Contract or the Deed of J3862v2 33 Trust will become effective unless the County delivers to the Trustee its prior lvritten consent to the amendment or supplement. Section 10.09. Insurer's Consent Required. No amendment or supplement to this Agreement, the Certificates, the Contract or the Deed of Trust (a) for which consent of the Owners is required, or (b) which affects an}J provision expressly recognizing or granting rights in or to the Policy, shall become effective unless the Insurer delivers to the Trustee its prior written consent to the amendment or supplement. Section 10.10. Notice to Owners and Insurer. The Trustee shall cause notice of the execution of each supplement or amendment to this Agreement, the Certificates or the Contract to be mailed to the Owners and to the Insurer. The notice will, at the Trustee's option, either (a) briefly state the nature of the amendment or supplement and that copies of it are on file urith the Trustee for inspection by OuJners, or (b) enclose a copy of such amendment or supplement. Section 10.11. Owners' Consents. Any consent or other instrument required by this Trust Agreement to be signed by Owners may be in any number of concurrent documents and may be signed by an Owner or by the Owner's agent appointed in writing. Proof of the execution of such instrument or of the instrument appointing an agent and of the ownership of Certificates, if made in the following manner, will be conclusive for any purposes of this Trust Agreement ujith regard to any action taken by the Trustee. (a) The fact and date of a person's signing an instrument may be proved by the certificate of any officer in any jurisdiction uTho by lour has power to take acknowledgments within that jurisdiction that the person signng the writing acknowledged before the officer the execution of the writing, or by an affidavit of any witness to the signing. (b} The fact of ownership of Certificates, the amount or amounts, numbers and other identification of such Certificates and the date of holding will be proved by the registration books kept pursuant to this Trust Agreement. ARTICLE XI INSURANCE ON CERTIFICATES [To come.] ARTICLE XII 93362v2 34 MISCELLANEOUS Section 12.01. Notices. (a) Any communication prop-Tided for in this Trust Agreement or the Certificates must be in writing. (b) Any communication under this Contract will be sufficiently given and deemed given when deli~Tered by hand or on the date shown as the date of delivery on a United States Postal Service return receipt, if addressed as follows: (i) if to the County, to Orange County Manager, Attention: Notice under 2006A COPS Financing Trust Agreement, Post Office Box 8181, Hillsborough, North Carolina 27278; (11) if to the Company, to Orange County Public Facilities Company, Attention: Notice under Trust Agreement for Orange County 2006A COPS Financing, ;and (iii} if to the Trustee, to The Bank of New York, Attention: Corporate Trust Department, Regarding: Notice under 2006A Trust Agreement for Orange County {North Carolina), 10161 Centurion Parkway, Jacksonville, FL 32256. (iv} if to the InsL~rer, to . ; (c) Any communication sent under this Agreement must also be sent to the County, the Trustee and the Insurer, along with any other parties to which the communication may be addressed. (d) Alzy addressee may designate additional or different addresses for communications by notice gi~~ren under this Section to each of the others. Section 12.02. Limitation of Rights. Nothing expressed or implied in this Trust Agreement or the Certificates gives any person other than the Trustee, the Company, the Coulzty and the O`~~ners any right, remedy or claim ulzder or with respect to this Trust Agreement. Section 12.03. Severability. If any provision of this Trust Agreement is determined to be unenforceable, that will not affect any other provision of this Trust Agreement. J3862v2 35 Section 12.04. Non-Business Days. If a Certificate Payment Date is not a Business Day, then payment will be made on the next Business Day, and no interest will accrue for the intervening period. When any other action is provided in this Trust Agreement to be done on a day or within a time period named, and the day or the last day of the period is not a Business Day, the action may be done on the next ensuing Business Day. Section 12.05. Governing La~v. The parties intend that North Carolina law will govern tlus Trust Agreement. To the extent permitted by law, the parties agree that any action brought with respect to this Tnist Agreement will be brought in the North Carolina General Court of Justice in Orange County, North Carolina. Section 12.06. Limitation on Liability of Officers and Agents. No officer, agent or employee of the Company, the County or the LGC will be subject to any personal liability or accountability by reason of lus execution of this Trust Agreement., the Certificates or any other documents related to the transactions contemplated hereby. Such officers or agents will be deemed to execute such documents in their official capacities only, and not in their individual capacities. This Section will not relieve an officer, agent or emplo~ree of the County or the Company from the performance of any official duty pro~jided by lauT or tlus Trust Agreement.. Section 12.07. Records. The Trustee will keep complete and accurate records of all moneys received and disbursed by it under this Trust Agreement, which will be available for inspection by the County, the Company and any Owner, or any of their agents at any time during regular business hours upon reasonable prior notice. Section 12.08. Binding Effect. This Trust Agreement will be binding upon and inure to the benefit of and be enforceable by the parties and their respective successors and assigns. Section 12.09. Waiver of Notice. Whenever in this Trust Agreement the giving of notice is required, the giving of such notice may be waived in writing by the person entitled to receive such notice and in any case the giving or receipt of such notice ti~jill not be a condition precedent to the validity of any action taken in reliance upon such uJaiver. Section 12.10. References to Insurer. All references to the Insurer herein shall be disregarded and deemed to have been deleted if the Insurer is then in default with respect to its obligations under the Policy, is insolvent or is in bankruptcy, or if the Policy has been declared in~jalid by any court of competent jurisdiction. 93362v2 36 Section 12.11. Counterparts. This Trust Agreement may be signed in several counterparts, including separate counterparts. Each ~~jill be an original, but all of them together constitute the same instrument. Section 12.12. Definitions; Rules of Construction. Unless the context clearly requires otherwise, capitalized terms used in this Trust Agreement and not othenuise defined ha~Te the meanings set forth in Exhibit A, and this Trust Agreement will be interpreted in accordance with the rules of construction set forth in Exhibit A. jThe refnaindet~ of this page has been left binnk intentionully.J J3862v2 37 IN WITNESS WHEREUF, the parties hereto have caused this Trust Agreement to be executed in their corporate names by their duly authorized officers, all as of the date first above u~itten. ATTEST: (SEAL) ORANGE COUNTY PUBLIC FACILITIES COMPANY [Name] Secretanr [Name] President [TRUSTEE], as Tnistee By: Printed name: Authorized Officer [Trust Agreement dated as of April 1, ?0~6] J3862v2 3g Exhibit A -- Definitions; Rules of Canstructian Definitions. All capitalized terms used in this Trust Agreement and not otherwise defined will have the meanings ascribed thereto in the Financing Contract. In addition, for all purposes of this Trust Agreement, unless the context. requires otherwise, the following terms will have the following meanings. "2006A Certificates" means the [$24,000,000] Certificates of Participation (Orange County Public Improvement Projects), Series 2006A, issued pursuant to this Trust Agreement. "Additional Certificates" means any Certificates delivered pursuant to Section 1.05. "Appropriate Consultant" has the meaning assigned in the Financing Contract. "Business Day" means any day (a) other than a day on which banks in New York, Ne~v York, or the city of the Trustee's principal corporate trust office are required or authorized to close and {b} on wluch the New Yark Stock Exchange is not closed. "Certificate Payment Date" means, with respect to the 2006A Certificates, each April 1 and October 1 beginning October 1, 2006, and uTith respect to any Additional Certificates means the dates specified for principal and interest payments ~~Tith respect to such Additional Certificates. "Certificates" means, together, the 2006A Certificates and all Additional Certificates. "Cade" means the Internal Revenue Code of 1986, as amended, including regulations, rulings and revenue procedures promulgated thereunder or under the Internal Revenue Code of 1954, as amended, as applicable to the Certificates. Reference to any specific Code provision will be deemed to include any successor provisions. "Company Representative" means the Company's President or any other person at the time designated to act on the Company's behalf in matters related to this Trust Agreement (or for any specific matters) by a written instrument furnished to the Trustee containing the specimen signature of such person and signed on the Company's behalf by any of its officers (other than the person being designated as a Company Representative). J3862v2 39 "County" means Orange County, North Carolina, or its successors. "Deed of Trust" means the Deed of Trust and Security Agreement dated as of April 1, 2000, from the County to a deed of trust trustee for the Company's benefit, as it may be duly amended or supplemented. "DTC" means The Depository Trust Company, New York, New York, or its successors as the securities depository maintaining abook-entry system for recording beneficial otivnership interests in the Certificates "Event of Default" has the meaning set forth in Section 8.01. "Federal Securities" means, to the extent such are legal investments for the County's funds at the time of purchase, (a} direct obligations of the Uiuted States of America far which its full faith and credit are pledged, or (b) Securltles or obligations evidencing direct o~~~ership interests in specified portions (principal or interest) of obligations described in {a). "Financing Contract" means the Installment Financing Contract dated as of April 1, 2006, between the County and the Company, as it may be duly amended or supplemented. "Independent Counsel" has the meaning assigned in the Financing Contract. "Insurer" means , or any successor. "Interest Account" means the account of that name in the Payment Fund established in Section 4.04. "LGC" means the North Carolina Local Government Commission, or any successor to its functions. "Majority Owners" means, as of any date, the Owners of at least a majority in principal amount of the Certificates then Outstanding. "Net Proceeds" has the meaning assigned in the Financing Contract. "Net Proceeds Fund" means the fund by that name established in Section 3.04 "Opinion of Counsel" or "Opinion of Special Counsel" means a u~~ritten opinion of Independent Counsel or Special Counsel, as appropriate. J3862v2 40 "Outstanding," when used with reference to Certificates, or "Certificates Outstanding," means all Certificates which have been authenticated and delivered by the Trustee under this Trust Agreement and not yet paid, except the following: (a} CertlflcateS canceled or purchased by or delivered to the Trustee for cancellation; (b) Certificates that have become due {at maturity or on prepayment, acceleration or otherwise} and for the payment, including interest accnied to the due date, of which the Trustee holds sufficient moneys; (c) Certificates deemed paid in accordance with Section 7.01; and (d) Certificates in lieu of which others have been authenticated under Section 2.04 {relating to registration and exchange of Certificates} or Section 2.05 (relating to mutilated, lost, stolen, destroyed or undelivered Certificates); provided, however, that no Certificate will be deemed to be not Outstanding by any reason of any payment uTith respect thereto by the Insurer. "Owner," uThen used with reference to Certificates, means the person in whose name such Certificate is registered on the registration books maintained by the Tnistee. "Payment Fund" means the fund by that name established in Section 4.04. "Permitted Investments" means such investments as from time to time are legal investments for the County's funds, as determined at the time of investment. "Policy" means the financial guarant~J insurance policy issued by Insurer insuring the payment when due of the principal of and interest ti~jith respect to the 2006A Certificates as provided therein. "Prepayment Account" means the account of that name in the Payment Fund established in Section 4.04. "Principal Account" means the account of that name in the Payment Fund established in Section 4.04. "Project Fund" means the fund by that name established in Section 4.01. "Record Date" means the close of business on the 15th day of the month (ti~Jhether or not a Business Day} preceding a Certificate Payment Date. 93 362v2 41 "Restricted Yield" means a "yield," ujithin the meaning of Treas. Regs. Secs. 1.103-13(c}, -13(d), 1.148-9T(a), or any successor or other provision that may be applicable, not in excess of a "yield" equal to %. "Special Counsel" means such attorney or firm of attorneys nationally recognized on the subject of mu~ucipal obligations as may be selected by the County and approved by the Trustee {which approval will not be unreasonably withheld). "State" means the State of North Carolina. "Term Certificates" means any Certificates (including the 2006A Certificates maturing April 1, 2026) that are subject to mandatory redemption pursuant to sinking field requirements. "Trust Agreement" means this Trust Agreement, as it may be duly amended or supplemented. "Trustee" means the bank or trust company from time to time serving as trustee under this Trust Agreement, uThether the original or a successor Trustee. Rules of Construction. Unless the context otherwise requires, (a) an accounting term not otherwise defined leas the meaning assigned to it in accordance with generally accepted accounting principles; (b) unless otherwise indicated, references to Articles, Sections and Exhibits are to the Articles, Sections and Exhibits of this Trust Agreement; (c) words importing the singular uJill include the plural and vice versa and words importing the masculine gender will include the feminine and neuter genders as urell. (d) the headings and Table of Contents are solely for convenience of reference and will not constitute a part of this Trust Agreement nor will they affect its meanings, constn~ction or effect; (e) words importing the prepayment or calling for prepayment of Certificates will not be deemed to refer to or connote the payment of Certificates at their stated maturity; and J3862v2 42 {f) all references to the payment of Certificates are references to payment of principal of and premium, if any, and interest uTith respect to the Certificates. J3862v2 43 Exhibit B -Form of Certificate REGISTERED [Insurance Legend, if applicable] Number R-X REGISTERED CERTIFICATE OF PARTICIPATION (Orange County Fublic Improvement Frojects), Series 2006A in certain payments to be made under an installment financing contract «~ith ORANGE COUNTY, NORTH CAROLINA INTEREST RATE MATURITY DATE DATED DATE CUSIP April 1, [closing date] REGISTERED OWNER: '~ ~"~'~'~ CEDE ~ CO. ~'~ ~"~'~ PRINCIPAL AMOUNT: ~ ~` ~` ~ THOUSAND DOLLARS ~ ~ ~` ~~~~~~ ,000)~~~ THIS CERTIFIES that the registered owner hereof, or registered assigns or legal representative, is the owner of a proportionate and undivided interest in certain payments to be made by Orange County, North Carolina (the "County"}, arising under an Installment Financing Contract dated as of April 1, 2006 (the "Financing Contract"}, between the County and Orange County Public Facilities Company (the "Company"). Principal is payable to such o~~•ner in the amount stated above on the matL~rity date stated above, subject to prepayment as described belov~T, and interest is payable on each April 1 and October 1, beginning October 1, 2006 (the "Certificate Payment Dates"), at the ar~lual rate stated above (calculated on the basis of a 360-day year consisting of twelve 30-day months). Interest is payable {a} from the Dated Date shown above, if this Certificate is authenticated prior to the Record Date, as defined below, preceding October 1, 2006, {b) from the succeeding Certificate Payment Date, if this Certificate is J3862v2 44 authenticated between a Record Date and the succeeding Certificate Payment Date, or (c} otherwise from the Certificate Payment Date that is, or immediately precedes, the date on uThich this Certificate is authenticated (unless payment of interest hereon is in default, in which case this Certificate will bear interest from the date to which interest has been paid}. Principal and interest are payable in lawful money of the United States of America. This Certificate is one of an issue of the [$24,000,000] Certificates of Participation (Orange County Public Improvement Projects), Series 2006A (the "Certificates"}, of like date and tenor, except as to number, denomination, rate of interest, privilege of prepayment and maturity. The Certificates are executed and delivered under, and are equally and ratably secured by, a Trust Agreement dated as of April 1, 2006 (the "Trust Agreement"), betu~•een the Company and The Bank of Ne~~T York, as trustee (the "Trustee"). The Company is advancing funds under the Financing Contract to provide funds to the County, together with other available funds, to pay the cost of acquiring, constructing and improving certain school facilities, to provide for certain other public improvements and to pay certain financing costs, as more fully described in the Trust Agreement and the Financing Contract. The County ~vill repay the amounts advanced by making Installment Payments, as defined in and pursuant to the Financing Contract, ~vluch are designed to be sufficient in times and amounts to provide for timely payment of the Certificates. To further secure its obligations under the Financing Contract, the County has granted, for the Company's benefit, a security interest in certain of the financed facilities, the underlying real property and certain other property (the "Trust Property") pursuant to the Financing Contract and a Deed of Trust and Security Agreement dated as of April 1, 2006 (the "Deed of Trust"). The Company has assigned substantially all of its rights under the Financing Contract and as beneficiary under the Deed of Trust, including its right to receive Installment Payments, to the Trustee, without recourse against the Compan}r, far the benefit of the o~~jners of the Certificates. The Certificates are payable solely from amounts paid by the County pursuant to the Financing Contract, except to the extent payable from the proceeds of the Certificates, income from investments and certain net insurance and condemnation ati~rards, which revenues and other moneyrs have been pledged as described in the Trust Agreement and the Financing Contract to secure payment of the Certificates. Neither the Certificates nor the County's obligation to make payments under the Financing Contract constitutes a pledge of the County's faith and credit within the meaning of any constitutional provision. J3862v2 4~ Additional Certificates secured by a parity lien on the Trust Property, and payable from the same sources of funds as the initial Certificates, may be issued from time to time under the terms and conditions set forth in the Trust Agreement. Reference is made to the Trust Agreement and all amendments and supplements thereto for a description of the provisions, among others, with respect to the nature and extent of the security, the rights, duties and obligations of the Company and the Trustee, the rights of the Owners of the Certificates and the terms upon which the Certificates are executed, delivered and secured, to all of which provisions the owner of this Certificate, by the acceptance hereof, agrees. Additional Certificates secL~red by an interest in the Trust Property on a parity with the interest securing the Certificates may be issued under the terms and conditions set forth in the Trust Agreement. The Certificates are issued by means of a book-entry system, ujith one certificate for each maturity immobilized at The Depository Trust Company, New fork, New fork ("DTC "), and not available for distribution to the public. Transfer of beneficial ownership interests in the Certificates in the principal amount of $5,000 or any integral multiple thereof will be effected on the records of DTC and its participants pursuant to rules and procedures established by DTC and its participants. Principal and interest on the Certificates are payable to DTC or its nominee as registered owner of the Certificates. Neither the Trustee, the Company nor the County is responsible or liable for such transfer of ownership or payments or for maintaining, supervising or revieuling the records maintained by DTC, its participants or persons acting through such participants. If (a} DTC determines not to continue to act as securities depository for the Certificates or (b) a County Representative so elects, the Company and the Trustee will discontinue the book-entry system ti~rith DTC. If the County fails to identify another qualified securities depository to replace DTC, the Company) will prepare and execute, and the Trustee will authenticate and deliver 111 exchange, replacement Certificates in the form of fully-registered certificates. The Certificates may not be prepaid prior to maturity except as provided in this Certificate and in the Trust Agreement. Certificates maturing on or after April 1, 2017, are subject to prepayment at the County's option on or after April 1, 2016, in Thole at any time or in part on any Certificate Payment Date, upon payment of the principal amount to be prepaid plus interest accrued to the prepayment dates, without premium. The Certificates are subject to prepayment in whole or in part on any Certificate Payment Date from Net Proceeds, as defined in the Contract, credited 93 362v2 46 towards the prepayment of Installment Payments under the Contract as a result of certain casualty and other losses to the Financed Facilities, as described in the Contract, at a prepayment price equal to the principal amount to be prepaid plus interest accrued to the prepayment date, without premium. The Trustee will prepay Certificates maturing on April 1, 2026, on April 1 in years and amounts upon payment of 100% of the principal amount thereof plus interest accrued to the prepayment date as follows: Year Amount 2024 2025 2026 The amount of Certificates to be prepaid on any sinking fund payment date may be reduced in accordance ~~ith the provisions of the Trust Agreement. If less than all of the Certificates are to be prepaid, they will be prepaid in such manner as the County may elect. If less than all the Certificates of any maturity are called for prepayment, the Trustee will select the Certificates to be prepaid by lot; provided, hou~•ever, that so long as a book-entry system ~.•ith DTC is used for recording beneficial ownerslup of Certificates, if less than all of the Certificates within a maturity are to be prepaid, DTC and its participants will determine which of the Certificates within any such maturity are to be prepaid. In any case, (1) the portion of any Certificate to be prepaid will be in the principal amount of $5,000 or some multiple thereof, and (2) u1 selecting Certificates for prepayment, each Certificate will be considered as representing that number of Certificates which is obtained by dividing the principal amount of such Certificate by $5,000. If a portion of a Certificate u~•ill be called far prepayment, a new Certificate in principal amount equal to the unpaid portion thereof will be issued to the Owner upon the surrender thereof. The Trustee will send notice of prepayment by registered or certified mail to DTC or its nominee as the Owner of the Certificates. The Trustee will mail such notice not more than 60 days nor less than 30 days prior to the date fixed far prepayment. Neither the Trustee, the Company nar the County is responsible for sending notices of prepayment to anyone other than DTC or its nominee. If on or before the date fixed for prepayment funds will be deposited with the Trustee to pay the principal, premium, if any, and interest accrued to the prepayment date with respect to the Certificates called for prepayment, the Certificates or portions thereof thus called for prepayment ~~-ill cease to accrue 93 362v2 47 interest from and after the prepayment date, will no longer be entitled to the benefits provided by the Trust Agreement and uTill not be deemed to be Outstanding under the Trust Agreement. The Owner of this Certificate has no right to enforce the provisions of the Trust Agreement or to institute action to enforce the covenants therein.; or to take any action with respect to any event of default thereunder, or to institute, appear in or defend any suit or other proceeding with respect thereto, except as provided in the Trust Agreement. Changes to ar supplements of the Trust Agreement may be made to the extent and in the circumstances permitted by the Trust Agreement. The Certificates are issuable only as fully-registered Certificates without coupons in denominations of $S,Q~O principal amount and any integral multiple thereof. Ownerslup of tlus Certificate will be registered on the Certificate Register (as defined in the Trust Agreement) to be kept far that purpose by the Trustee, which u~•ill act as certificate registrar for the Certificates. This Certificate may be exchanged, and its transfer may be effected, only by the Owner hereof in person or by attorney duly authorized in writing at the aforesaid office of the Trustee, but only in the manner, subject to the limitations and upon pa}jment of the charges pro~Tided in the Trust Agreement, and upon surrender and cancellation of this Certificate. Upon exchange or registration of such transfer a new registered Certificate or Certificates of the same maturity and interest rate and of authorized r denomination or denominations for the same aggregate principal amount urill be issued in exchange therefor. The Company and the Trustee may deem and treat the person ui whose name this Certificate u~•ill be registered on the Certificate Register as the absolute owner hereof for the purpose of receivving payment of or on account of principal hereof and interest due hereon and for all other pLUposes and neither the Company nor the Trustee uTill be affected by any notice to the contrary, except that interest pad-~ments will be made to the persons sho~'n as Ourners on the Trustee's registration books on the 15th day (whether ar not a business day} {the "Record Date") preceding each Certificate Payment Date. All acts, conditions and things required by the Constitution and laws of the State of North Carolina to happen, exist or be performed precedent to and in the execution and delivery of this Certificate have happened, exist and ha~Je been performed. This Certificate will not be entitled to any benefit under the Trust Agreement or be valid or obligatory for any purpose until the Trustee uTill have executed the Certificate of Authentication appearing hereon. J3862v2 4g IN WITNESS WHEREOF, the Company has caused this Certificate to signed by the facsimile signature of its President, to be countersigned by the facsimile signature of its Secretary, a facsimile of its seal to be printed hereon and this Certificate to be dated April 1, 2006. COUNTERSIGNED : (SEAL) Sample only - do not sign] Sample only - do not sigrrJ Secretary President Orange County Orange County Public Facilities Company Public Facilities Company CERTIFICATE OF AUTHENTICATION This Certificate is one of the Certificates referred to in the within-mentioned Trust Agreement. Date of Authentication: THE BANK OF NEW YORK, as Trustee By: Authorized Officer J3862v2 49 ASSIGNMENT FOR VALUE RECEIVED the undersigned hereby sell(s), assign(s) and transfer(s) unto (Please print or type transferee's name and address, including zip code) PLEASE INSERT SOCIAL SECURITY OR OTHER IDENTIFYING hIZ_JIv~3ER OF TRANSFEREE: the u~•ithin certificate and all rights thereunder, hereby irrevocably constituting and appointing ,Attorney, to transfer said certificate on the books kept for the registration thereof, ujith full power of substitution in the premises. Dated: Signature Guaranteed: (Signature of Owner} NOTICE: Signatures} must be guaranteed by a participant in the Securities Transfer Agent Medallion Program ("STAMP"} or similar program NOTICE: The signature above must correspond with the name the Owner as it appears on the front of this certificate in every particular ~~Tithout alteration or enlargement or any change whatsoever. J3862v2 $Q Exhibit C -Form of Requisition (To Be Prep~rred on County's Letterhead for SubfsaissionJ [Date] The Bank of New York, as Trustee Attention: Corporate Trust Department Regarding: Requisition under 2006 Trust Agreement for Orange County (North Carolina} 10161 Centurion Park~~jav Jacksonirille, FL 32256 RE: Request by Orange County, North Carolina (the "County"), for disbursement of funds from a Project Fund created under a Trust Agreement dated as of April 1, 2006, between Orange County Public Facilities Company and The Sank of New York, as trustee. To the Trustee: Pursuant to the terms and conditions of the above-referenced Trust Agreement, the County authorizes and requests the disbursement of funds from the Project Fund established under such Trust Agreement for the Project Costs described below. Capitalized terms used in this requisition and not otherwise defined have the meanings ascribed in the Trust Agreement. This is requisition number from the Project Fund. Amount Payee Payee's address Amount requested Orange County makes this requisition pursuant to the following representations: J3862v2 51 1. The County has appropriated in its current fiscal year funds sufficient to pay the Installment Payments and estimated Additional Payments due in the current fiscal year. 2. The purpose of this disbursement is for partial payment on the project. contemplated under the Trust Agreement. 3. The requested disbursement has not been subject to any previous requisition. 4. No notice of any lien, right to lien or attachment upon, or claim affecting the right to receive payment of, any of the moneys payable herein to any of the persons, firms or corporations named herein has been received, or if any notice of any such lien, attachment or claim has been received, such lien, attachment or claim has been released or discharged or will be released or discharged upon payment of this requisition. 5. This requisition contains no items representing payment on account of any percentage entitled to be retained on the date of this requisition. 6. No Event of Default is continuing, and no event or condition is existing which, with notice or lapse of time or both, ~~•ould become an Event of Default. 7. The County has insurance in place that complies with the insurance requirements of the Financing Contract. Attached is evidence that the amounts shown in this requisition are properly payable at this time, such as bills, receipts, invoices, architects' payment certifications or other appropriate documents. ORANGE COUNTY, NORTH CAROLINA By: (E_xhibit Fo~r~x Onh~ - Do Not Si~nJ Title: J3862v2 52