final offering circular dated december 18, 2012 … › ea491315-ea381579-ea778426.pdfdated december...

35
NEW ISSUE RATING: S&P: AA- BANK QUALIFIED BOOK ENTRY ONLY Dated: Date of Delivery Due: March 1, as shown below THE BONDS are being issued by the Sni Valley Fire Protection District of Jackson and Lafayette Counties, Missouri (the “District”) and will be issued as fully registered bonds without coupons, and, when issued, will be registered in the name of CEDE & Co. as Bondowner and nominee for the Depository Trust Company (“DTC”), New York, New York. DTC will act as securities depository for the Bonds. Purchases for the Bonds will be made in book-entry only form, in the denomination of $5,000 or any integral multiple thereof. Purchasers will not receive certificates representing their interests in Bonds purchased. Principal and semi-annual interest will be payable by UMB Bank, N.A., Kansas City, Missouri, as Paying Agent and Registrar, directly to DTC. Principal is payable annually on March 1, commencing March 1, 2014. Interest is payable semiannually on March 1, and September 1, commencing September 1, 2013. The net proceeds of the Bonds will be used to 1.) finance the acquisition of a new fire truck, a storm siren for Bates City, Missouri and other equipment, and upgrade or replace breathing apparatus inventory, 2.) refund a portion of the outstanding Series 2005 Bonds, and 3.) pay costs of issuance of the Bonds. IN THE OPINION of Gilmore & Bell, P.C., Bond Counsel, under existing law and assuming continued compliance with certain requirements of the Internal Revenue Code of 1986, as amended (the “Code”), (1) the interest on the Bonds is excludable from gross income for federal income tax purposes, and is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations, (2) the interest on the Bonds is exempt from income taxation by the State of Missouri and (3) the Bonds have been designated as “qualified tax-exempt obligations” within the meaning of Section 265(b)(3) of the Code. See “TAX MATTERS” below. OPTIONAL REDEMPTION: The Bonds are subject to redemption at the option of the District on March 1, 2019, and on any date thereafter, in whole or in part, at par plus accrued interest. SECURITY: The Bonds are general obligations of the District payable as to both principal and interest from ad valorem taxes, which may be levied without limitation as to rate and amount, upon all the taxable tangible property, real and personal, within the territorial limits of the District. The full faith, credit and resources of the District are pledged to the payment of principal of and interest on the Bonds. FINAL OFFERING CIRCULAR Dated December 18, 2012 $940,000 Sni Valley Fire Protection District of Jackson and Lafayette Counties, Missouri General Obligation Bonds Series 2012

Upload: others

Post on 31-Jan-2021

0 views

Category:

Documents


0 download

TRANSCRIPT

  • NEW ISSUE RATING: S&P: AA- BANK QUALIFIED BOOK ENTRY ONLY Dated: Date of Delivery Due: March 1, as shown below THE BONDS are being issued by the Sni Valley Fire Protection District of Jackson and Lafayette Counties, Missouri (the “District”) and will be issued as fully registered bonds without coupons, and, when issued, will be registered in the name of CEDE & Co. as Bondowner and nominee for the Depository Trust Company (“DTC”), New York, New York. DTC will act as securities depository for the Bonds. Purchases for the Bonds will be made in book-entry only form, in the denomination of $5,000 or any integral multiple thereof. Purchasers will not receive certificates representing their interests in Bonds purchased. Principal and semi-annual interest will be payable by UMB Bank, N.A., Kansas City, Missouri, as Paying Agent and Registrar, directly to DTC. Principal is payable annually on March 1, commencing March 1, 2014. Interest is payable semiannually on March 1, and September 1, commencing September 1, 2013. The net proceeds of the Bonds will be used to 1.) finance the acquisition of a new fire truck, a storm siren for Bates City, Missouri and other equipment, and upgrade or replace breathing apparatus inventory, 2.) refund a portion of the outstanding Series 2005 Bonds, and 3.) pay costs of issuance of the Bonds. IN THE OPINION of Gilmore & Bell, P.C., Bond Counsel, under existing law and assuming continued compliance with certain requirements of the Internal Revenue Code of 1986, as amended (the “Code”), (1) the interest on the Bonds is excludable from gross income for federal income tax purposes, and is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations, (2) the interest on the Bonds is exempt from income taxation by the State of Missouri and (3) the Bonds have been designated as “qualified tax-exempt obligations” within the meaning of Section 265(b)(3) of the Code. See “TAX MATTERS” below. OPTIONAL REDEMPTION: The Bonds are subject to redemption at the option of the District on March 1, 2019, and on any date thereafter, in whole or in part, at par plus accrued interest. SECURITY: The Bonds are general obligations of the District payable as to both principal and interest from ad valorem taxes, which may be levied without limitation as to rate and amount, upon all the taxable tangible property, real and personal, within the territorial limits of the District. The full faith, credit and resources of the District are pledged to the payment of principal of and interest on the Bonds.

    FINAL OFFERING CIRCULAR Dated December 18, 2012

    $940,000

    Sni Valley Fire Protection District of Jackson and Lafayette Counties, Missouri

    General Obligation Bonds Series 2012

  • 2

    Maturity Schedule Serial Bonds

    Due March 1 Principal Amount Coupon Price/Yield CUSIP

    2014 $ 70,000.00 4.00% 0.60% 833063 CT5 2015 75,000.00 3.00 0.70 833063 CU6 2016 75,000.00 2.00 0.80 833063 CV0 2017 75,000.00 0.90 Par 833063 CW8 2018 75,000.00 1.10 Par 833063 CX6 2019 75,000.00 1.25 Par 833063 CY4 2020 80,000.00 1.45 Par 833063 CZ1 2021 80,000.00 1.60 Par 833063 DA5 2022 80,000.00 1.85 Par 833063 DB3 2023 80,000.00 2.00 Par 833063 DC1 2024 90,000.00 2.15 Par 833063 DD9 2025 85,000.00 2.30 Par 833063 DE7

    ESTIMATED SOURCES AND USES OF FUNDS

    Following is a summary of the sources and application of Bond proceeds:

    Sources of Funds:

    Par Amount of Bonds $940,000.00 Reoffering Premium 9,326.60 Total sources of funds $949,326.60 Uses of Funds:

    Deposit to Project Fund $679,809.85 Deposit to Escrow Fund 244,868.75 Cost of Issuance, including Underwriter’s Discount 24,648.00 Total uses of funds $949,326.60

    THE DISTRICT

    Size and Location The District encompasses approximately 78 square miles and is located in the eastern portion of Jackson County, Missouri, and parts of western Lafayette County, Missouri. Firefighters and officers of the District respond to approximately 1,400 calls each year. The present estimated population of the District is 15,000, which includes the cities of Oak Grove, Missouri and Bates City, Missouri. The City of Oak Grove is located approximately 22 miles to the east of the Kansas City metropolitan area, and approximately 15 miles east of the City of Independence, Missouri. Since the City of Oak Grove is close to the Kansas City metropolitan area, the residents have easy access to all the medical, educational, and cultural amenities of a large city. The population of Oak Grove is approximately 7,795. Additional information regarding the

  • 3

    District and the Project can be obtained by contacting the Fire Chief – Station One, 1600 South Broadway St., Oak Grove, MO 64075 or by telephoning (816) 690-6990. Organization and Government of the District The District was organized in 1974 and later expanded in 1975. It operates pursuant to Chapter 321 of the Revised Statutes of Missouri, as amended, and is governed by a five-member Board of Directors. The directors of the Board are elected by the qualified voters of the District for six year terms. The Chairman, Secretary and Treasurer are selected by the Board. The Secretary and Treasurer may or may not be directors. The Board of Directors is responsible for the management, control and supervision of all the business and affairs of the District. The Board has appointed John VanGorkom as Fire Chief to manage the day to day affairs of the District. Chief VanGorkom has served in this capacity since April 20, 2004. The District currently employs 22 full time employees, 2 part-time employees, and 8 volunteer firefighters. Facilities The District’s two fire stations are located at 1600 South Broadway, Oak Grove, Missouri (“Station 1”) and at 207 E. Market Street, Bates City, Missouri (“Station 2”). Station 1 was constructed in 2011, and serves as the headquarters for both the administration and operations of the District. Station 1 is 12,250 square feet in size and contains 3 truck bays. Station 2 is 3,500 square feet in size and contains three truck bays. In addition to miscellaneous fire fighting equipment, the District owns and operates one aerial ladder truck, two pumper trucks, two tanker trucks, two grass fire fighting trucks, two ambulances and other miscellaneous vehicles. District Performance The annual fire loss in the District has been $40.40 per capita, which is approximately 24.6% below the national average of $53.60 per capita. The District currently has an ISO Class 4 rating for property within 5 miles of the fire stations, and a Class 10 rating for all other property in the District.

    COMMUNITY SERVICES Transportation The District is served by Interstate Highway 70 and U.S. Highway 40 which provide the residents of the District with easy access to all of the commercial transportation and freight facilities serving the Kansas City metropolitan area. Public Utilities Aquila and West Central Electric Cooperative provide electric service for the District. Natural gas is supplied by Missouri Gas Energy. The Cities of Oak Grove and Bates City, as well as four water districts provide the District with water and sewer service.

  • 4

    Medical and Health Facilities The District is served by several hospitals throughout the Kansas City metropolitan area which provide inpatient/outpatient facilities as well as a full range of diagnostic and therapeutic services. Recreational, Cultural and Religious Facilities Either in or nearby the District are numerous cultural and athletic activities, including several theater and ballet groups, museums, golf courses and other sport facilities, and several professional sports teams. The District also includes many parks, lakes and other outdoor recreational areas. All major religious denominations are represented in the area.

    ECONOMIC INFORMATION CONCERNING THE DISTRICT Employment Major employers in the District include the following:

    Employer Product or Service

    Estimated Number of Employees

    Oak Grove School District Education 260 Oak Grove Wal-Mart Retail/Grocery 240 Oak Grove Petro Truck Stop Fuel, Food and Retail 126 Oak Grove Nursing & Rehab Health Care 100 TA Truck Stop Fuel, Food and Retail 60 Patricia’s Foods Grocery 52 City of Oak Grove City Government 49 Source: Eastern Jackson County Development Alliance The following table shows the average annual unemployment figures for the last five years for Jackson County and Lafayette County and the State of Missouri.

    Year Jackson County

    Lafayette County

    State of Missouri

    2012 7.0% 6.6% 6.3% 2011 8.4 8.6 8.0 2010 10.2 9.4 9.2 2009 10.3 10.9 9.5 2008 7.6 6.7 7.1

    Source: Missouri Department of Economic Development

  • 5

    Population The following table provides the estimated current and historic population figures for the City of Oak Grove and for Jackson and Lafayette Counties:

    Year Oak Grove Population

    Jackson County Population

    Lafayette County Population

    2010 7,795 674,158 33,381 2000 5,535 654,880 32,960 1990 4,565 633,232 31,107 1980 4,067 629,266 29,925 1970 2,025 654,558 26,626

    Source: Missouri Department of Economic Development, Eastern Jackson County Development Alliance

    FINANCIAL INFORMATION CONCERNING THE DISTRICT Financial Overview The following table summarizes certain financial information concerning the District. This information should be reviewed in conjunction with the sections under the heading “FINANCIAL INFORMATION CONCERNING THE DISTRICT” entitled “Current Indebtedness of the District” and “Overlapping Indebtedness” and the financial statements of the District in Appendix A hereto. 2012 Assessed Valuation $168,267,344 2012 Estimated Actual Valuation $761,148,461 Outstanding General Obligation Bonds (including the Bonds) $4,915,000 Population 15,000 Per capita General Obligation Debt $327.66 Ratio of General Obligation Debt to Assessed Valuation 2.92% Ratio of General Obligation Debt to Estimated Actual Valuation 0.65% Overlapping General Obligation Debt $25,717,165 Direct and Overlapping General Obligation Debt $30,632,165 Per capita Direct and Overlapping General Obligation Debt $2,042.14 Ratio of Direct and Overlapping General Obligation Debt to Assessed Valuation

    18.20%

    Ratio of Direct and Overlapping General Obligation Debt to Estimated Actual Valuation 4.02%

    Current Indebtedness of the District In addition to this issue in the amount of $940,000, the District has outstanding its General Obligation Bonds, Series 2005 in the remaining amount of $75,000, with a final maturity in 2013, its General Obligation Bonds, Series 2009 in the amount of $3,000,000, with a final

  • 6

    maturity in 2029, and its General Obligation Bonds, Series 2010 in the amount of $900,000, with a final maturity in 2021. History of Indebtedness The following table sets forth the total outstanding general obligation bonded indebtedness of the District effective December 31st of each of the last five years:

    Year

    Principal Amount Outstanding

    December 31 Assessed Valuation

    Debt as % of Assessed Valuation

    2012 $4,915,000 $168,267,344 2.92% 2011 4,285,000 165,498,994 2.59% 2010 4,345,000 170,532,196 2.55% 2009 3,500,000 171,913,634 2.04% 2008 820,000 179,000,600 0.46%

    The District has never defaulted in the payment of interest on or principal of its general obligation indebtedness. Debt Service Requirements The following schedule shows the yearly principal and interest requirements for the outstanding general obligation indebtedness of the District, not including the Bonds:

    Calendar Year Series 2005 Series 2009 Series 2010 TOTAL

    2013 86,425.00 128,590.00 22,115.00 237,130.002014 93,037.50 128,590.00 22,115.00 243,742.502015 99,413.75 128,590.00 22,115.00 250,118.752016 61,245.00 128,590.00 81,620.00 271,455.002017 128,590.00 164,711.25 293,301.252018 128,590.00 181,441.25 310,031.252019 128,590.00 202,162.50 330,752.502020 128,590.00 216,852.50 345,442.502021 236,445.00 131,982.50 368,427.502022 388,900.00 388,900.002023 407,350.00 407,350.002024 429,165.00 429,165.002025 449,267.50 449,267.502026 472,590.00 472,590.002027 493,875.00 493,875.002028 517,837.50 517,837.502029 265,850.00 265,850.00

    $340,121.25 $4,690,000.00 $1,045,115.00 $6,075,236.25

  • 7

    Overlapping Indebtedness The following table sets forth overlapping indebtedness of political subdivisions with boundaries overlapping the District and the portion of such indebtedness attributable (on the basis of assessed valuation) to the District, as of December 1, 2012. Such indebtedness is payable from ad valorem taxes.

    Jurisdiction

    Outstanding General

    Obligation Indebtedness

    Percent of Indebtedness Applicable to

    the District

    Amount of Indebtedness Applicable to

    the District City of Oak Grove $ 7,720,000 100.00% $ 7,720,000 Oak Grove R-VI School District 12,800,000 89.82 11,496,960 Odessa R-VII School District 18,954,995 12.68 2,403,493 Grain Valley R-V School District 38,520,000 10.50 4,044,600 Lone Jack C-VI School District 5,900,000 0.40 23,600 Wellington-Napoleon R-IX School District 2,822,959 1.01 28,512 Total $86,717,954 $25,717,165 Sources: City of Oak Grove, Oak Grove R-VI School District, Odessa R-VII School District, Lafayette and Jackson counties; Missouri State Auditor Authority to Incur Debt Under Article VI, Section 26(b) of the Constitution of Missouri, the District may incur indebtedness not to exceed 5% of the valuation of taxable tangible property in the District according to the last completed assessment (including state assessed railroad and utility valuations) upon the approval of two-thirds (four-sevenths at certain elections) of the qualified voters in the District voting on the proposition. The current legal debt limit of the District (based upon an assessed valuation of $168,267,344) is $8,413,367. The current total outstanding net indebtedness of the District, including the Bonds, is $4,915,000, which leaves a legal debt margin of $3,498,367. Chapter 321 of the Revised Statues of Missouri, as amended, authorizes the Board of Directors to enter into bonded indebtedness when approved by the constitutionally required majority (either 4/7 or 2/3) of the voters within the District. Accounting, Budgeting and Auditing Procedures The District currently produces financial statements that are in conformity with the cash basis of accounting. The accounts of the District are organized on the basis of funds and account groups, each of which is considered a separate accounting entity. The operations of each fund are accounted for with a separate set of self-balancing accounts that comprise its assets, liabilities, fund equity, revenues and expenditures or expenses as appropriate. An annual budget is prepared under the direction of the Fire Chief and submitted to the Board of Directors for consideration prior to the fiscal year commencing on October 1. The operating

  • 8

    budget includes proposed expenditures and revenue sources. Public hearings are conducted to obtain taxpayer comments. The budget is legally enacted through the adoption of a resolution. The financial records of the District are audited annually by a firm of independent certified public accountants in accordance with generally accepted auditing standards. The audit for the fiscal year ending September 30, 2012 was performed by Novak Birks, P.C., Certified Public Accountants, Kansas City, Missouri (“Novak Birks, P.C.”). Summary Statement of Cash Receipts, Disbursements and Changes in Fund Balances: Financial Statements. Included in this official statement at Appendix A is a statement of cash receipts, disbursements and cash balances for the twelve months ended September 30, 2012, together with the Report and Notes appertaining thereto, that has been obtained from the District’s annual audit reports prepared by Novak Birks, P.C. Financial statements for earlier years with reports by said Certified Public Accountants are available for examination in the District’s office. The financial information relating to the District set forth in this Offering Circular should be read in conjunction with the financial statements and notes set forth in Appendix A. Sources of Revenue The District finances its operations primarily through the local property tax levy. In the 2012 fiscal year, the District’s General Operating Fund received revenues from various sources as follows:

    Revenue Source

    Amount

    Percentage Of Total

    Property Taxes $1,393,605 57.71% Sales Tax 552,156 22.86% Charges for Services 304,385 12.60% Fees & Permits 4,880 0.20% Investment Income 4,945 0.20% Miscellaneous 154,935 6.42% Total $2,414,906 100.00%

    The local property taxes also provide the source of funds payable into the Debt Service Fund. Such taxes are levied and collected by the County as hereinafter described. See “FINANCIAL INFORMATION CONCERNING THE DISTRICT – Property Tax Levies and Collections.”

  • 9

    Property Valuations The total assessed valuation by category of all taxable tangible property situated in the District on December 1, 2012 is as follows: Assessed Valuation Assessment

    Rate Estimated Actual

    Valuation Real Estate Residential $105,491,148 19.0% $555,216,568 Commercial 20,496,315 32.0% 64,050,984 Agricultural 2,638,678 12.0% 21,988,983 Total Real Estate $128,626,141 $641,256,535 Total Personal Property $32,679,762 33.3% $98,137,423 Total Utilities $6,961,441 32.0% $21,754,503 Total Assessed Valuation $168,267,344 $761,148,461 Source: Jackson & Lafayette counties History of Property Valuation: The total assessed valuation of all taxable tangible property situated in the District according to the assessments of December 31 in each of the following years has been as follows:

    Year Assessed Valuation Percentage Change 2012 $168,267,344 1.67% 2011 165,498,994 (2.95) 2010 170,532,196 (0.80) 2009 171,913,634 (3.96) 2008 179,000,600 0.91 2007 177,382,896 12.56

    Assessment Procedure All taxable real and personal property within the District is assessed annually by the County Assessor. Missouri law requires that real property be assessed at the following percentages of true value:

    Residential real property ………………………. 19% Agricultural and horticultural real property……………………………. 12% Utility, industrial, commercial, railroad and all other real property…….. 32%

  • 10

    A general reassessment of real property occurred statewide in 1985. In order to maintain equalized assessed valuations following this reassessment, the Missouri General Assembly adopted a maintenance law in 1986. Beginning January 1, 1987, and every odd numbered year thereafter, each County Assessor must adjust the assessed valuation of all real property located within his or her county in accordance with a two year assessment and equalization maintenance plan approved by the State Tax Commission. The assessment ratio for personal property is generally 33 1/3% of true value. However, subclasses of tangible personal property are assessed at the following assessment percentages: grain and other agricultural crops in an unmanufactured condition, 1/2%; livestock, 12%; farm machinery, 12%; historic motor vehicles, 5%; and poultry, 12%. The County Assessor is responsible for preparing the tax roll each year and for submitting the tax roll to the Board of Equalization. The County Board of Equalization has the authority to adjust and equalize the values of individual properties appearing on the tax rolls. Property Tax Levies and Collections Property Assessment and Tax Collection Procedure The District is required by law to prepare an annual budget, which includes an estimate of the amount of revenues to be received from all sources for the budget year, including an estimate of the amount of money required to be raised from property taxes and the tax levy rates required to produce such amounts. The budget must also include proposed expenditures and must state the amount required for the payment of interest, amortization and redemption charges on the District’s debt for the ensuing budget year. Such estimates are based on the assessed valuation figures provided by the County Clerk. The District must fix its ad valorem property tax rates and certify them to the County Clerk not later than September first for entry in the tax books. The County Clerk receives the county tax books from the County Assessor, which set forth the assessments of real and personal property. The County Clerk enters the tax rates certified to him by the local taxing bodies in the tax books and assesses such rates against all taxable property in the District as shown in such books. The County Clerk forwards the tax books by October 31 to the County Collector, who is charged with levying and collecting taxes as shown therein. The County Collector extends the taxes on the tax rolls and issues the tax statements in early December. Taxes are due by December 31 and become delinquent if not paid to the County Collector by that time. All tracts of land and District lots on which delinquent taxes are due are charged with a penalty of eighteen percent of each year’s delinquency. All lands and lots on which taxes are delinquent and unpaid are subject to sale at public auction in August of each year. The County Collector is required to make disbursements of collected taxes to the District each month, less a 1.5% collection fee retained by the County. Because of the tax collection procedure described above, the District receives the bulk of its moneys from local property taxes in the months of December, January and February.

  • 11

    Debt Service Levy The District’s current debt service levy is $0.1454 per $100 of assessed valuation. Once indebtedness has been approved by the constitutionally required percentage of the voters voting therefor and bonds are issued, the District is required under Article VI, Section 26(f) of the Missouri Constitution to levy an annual tax on all taxable tangible property therein sufficient to pay the interest and principal of the indebtedness as they fall due and to retire the same within 20 years from the date of issue. The Board of Directors may set the tax rate for debt service, without limitation as to rate or amount, at the level required to make such payments. Operating Levy The current operating levy of the District is $0.6823 per $100 of assessed valuation. The operating levy (consisting of all ad valorem taxes levied except the debt service levy) cannot exceed the “tax rate ceiling” for the current year without voter approval. The tax rate ceiling, determined annually, is the rate of levy which, when charged against the newly assessed valuation of the District for the current year, excluding new construction and improvements, will produce an amount of tax revenues equal to tax revenues for the previous year increased by 5% or the Consumer Price Index, whichever is lower. Without the required percentage of voter approval, the tax rate ceiling cannot at any time exceed the greater of the tax rate in effect in 1984 or the most recent voter-approved tax rate. The tax levy for debt service on the District’s general obligation bonds is exempt from the calculations of and limitations upon the tax rate ceiling. In 2008, through the enactment of Senate Bill 711 (“SB 711”), the Missouri General Assembly approved further limitations on the amount of property taxes that can be imposed by a local governmental unit. Prior to the enactment of SB 711, a Hancock rollback would not necessarily result in a reduction of a district’s actual operating tax levy if its current tax levy was less than its current tax levy ceiling, due to the district’s voluntary rollback from the maximum authorized tax levy. Under SB 711, in reassessment years (odd-numbered years), the Hancock rollback is applied to a district’s actual operating tax levy, regardless of whether that levy is at the district’s tax levy ceiling. This further reduction is sometimes referred to as an “SB 711 rollback.” In non-reassessment years (even-numbered years), the operating levy may be increased to the district’s tax levy ceiling (as adjusted by the Hancock rollback), only after a public hearing and adoption of a resolution or policy statement justifying the action. The following table shows the District’s adjusted tax levies (per $100 of assessed valuation) for each of the following calendar years:

    Calendar Year

    General Fund Dispatch

    Fire and Ambulance

    Debt Service Fund

    Total

    2012 $0.5023 $0.0300 $0.1500 $0.1454 $0.8277 2011 0.5023 0.0300 0.1500 0.1424 0.8247 2010 0.4846 0.0300 0.1500 0.1327 0.7973 2009 0.4836 0.0300 0.1500 0.1177 0.7813 2008 0.4537 0.0282 0.1414 0.1055 0.7288 2007 0.4700 0.0296 0.1481 0.1175 0.7652

  • 12

    Retirement Plan The District participates in the Missouri Local Government Employees Retirement System. The plan is non-contributory with the contribution by the District, actuarially determined annually, totaling $197,913 in 2012.

    INDEPENDENT PUBLIC ACCOUNTANTS The District maintains it financial records on the basis of a fiscal year ending September 30. Excerpts of the audited general purpose financial statements of the District for the fiscal year ended September 30, 2012, prepared by Novak Birks, P.C., Certified Public Accounts, are included in this Offering Circular as Appendix A. Such financial statements have been included in reliance upon the reports of such firm given upon their expertise in accounting and auditing.

    LEGALITY

    All legal matters incident to the authorization and issuance of the Bonds are subject to the approval of Gilmore & Bell, P.C., Kansas City, Missouri, Bond Counsel.

    TAX MATTERS Tax Opinion of Bond Counsel Federal and Missouri Tax Exemption. In the opinion of Gilmore & Bell, P.C., Bond Counsel, under existing law, the interest on the Bonds is excludable from gross income for federal and Missouri income tax purposes. Interest on the Bonds is not an item of tax preference for purposes of computing the federal alternative minimum tax imposed on individuals and corporations, but is taken into account in determining adjusted current earnings for the purpose of computing the alternative minimum tax imposed on certain corporations. The opinions set forth in this paragraph are subject to the condition that the District comply with all requirements of the Internal Revenue Code of 1986, as amended (the “Code”), that must be satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or continue to be, excludable from gross income for federal and Missouri income tax purposes. The District has covenanted to comply with each such requirement. Failure to comply with certain of such requirements may cause the inclusion of interest on the Bonds in gross income for federal and Missouri income tax purposes retroactive to the date of issuance of the Bonds. The Bonds are “qualified tax-exempt obligations” within the meaning of Section 265(b) of the Code. No Other Opinions. Bond Counsel expresses no opinion regarding other federal, state or local tax consequences arising with respect to the Bonds. Original Issue Premium. If a Bond is issued at a price that exceeds the stated redemption price at maturity of the Bond, the excess of the purchase price over the stated redemption price at maturity constitutes “premium” on that Bond. Under Section 171 of the Code, the purchaser of that Bond must amortize the premium over the term of the Bond using constant yield principles, based on the purchaser’s yield to maturity. As premium is amortized, the owner’s basis in the Bond and the amount of tax-exempt interest received will be reduced by the amount of amortizable premium

  • 13

    properly allocable to the owner. This will result in an increase in the gain (or decrease in the loss) to be recognized for federal income tax purposes on the sale or disposition of the Bond prior to its maturity. Even though the owner’s basis is reduced, no federal income tax deduction is allowed. Prospective investors should consult their own tax advisors concerning the calculation and accrual of bond premium. Sale, Exchange or Retirement of Bonds. Upon the sale, exchange or retirement (including redemption) of a Bond, an owner of the Bond generally will recognize gain or loss in an amount equal to the difference between the amount of cash and the fair market value of any property received on the sale, exchange or retirement of the Bond (other than in respect of accrued and unpaid interest) and such owner’s adjusted tax basis in the Bond. To the extent a Bond is held as a capital asset, such gain or loss will be capital gain or loss and will be long-term capital gain or loss if the Bond has been held for more than 12 months at the time of sale, exchange or retirement. Reporting Requirements. In general, information reporting requirements will apply to certain payments of principal, interest and premium paid on the Bonds, and to the proceeds paid on the sale of the Bonds, other than certain exempt recipients (such as corporations and foreign entities). A backup withholding tax will apply to such payments if the owner fails to provide a taxpayer identification number or certification of foreign or other exempt status or fails to report in full dividend and interest income. The amount of any backup withholding from a payment to an owner will be allowed as a credit against the owner’s federal income tax liability. Other Tax Consequences

    Prospective purchasers of the Bonds should be aware that ownership of the Bonds may result in collateral federal income tax consequences to certain taxpayers, including, without limitation, financial institutions, property and casualty insurance companies, individual recipients of Social Security or Railroad Retirement benefits, certain S corporations with “excess net passive income,” foreign corporations subject to the branch profits tax, life insurance companies, and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry or have paid or incurred certain expenses allocable to the Bonds. Bond Counsel expresses no opinion regarding these tax consequences. Purchasers of Bonds should consult their tax advisors as to the applicability of these tax consequences and other federal income tax consequences of the purchase, ownership and disposition of the Bonds, including the possible application of state, local, foreign and other tax laws.

    RATING

    Standard & Poor’s Rating Service has given the Bonds a rating of “AA-” which reflects its evaluation of the investment quality of the Bonds. Such rating reflects only the view of such rating agency, and an explanation of the significance of such ratings may be obtained therefrom. There is no assurance that the ratings will remain in effect for any given period of time or that they will not be revised, either downward or upward, or withdrawn entirely, by said rating agency if, in its judgment, circumstances warrant. Any such downward revisions or withdrawal of the ratings may have an adverse effect on the market price of the Bonds.

  • 14

    UNDERWRITER UMB Bank, N.A., (the “Underwriter”) is acting as underwriter for the Bonds. The Underwriter is purchasing the Bonds at a purchase price of $940,866.60 (which represents the par amount of the Bonds, plus a premium of $9,326.60, less an underwriter’s discount of $8,460.00).

    DELIVERY Delivery on or about December 27, 2012.

  • FINAL OFFERING CIRCULARDated December 18, 2012Maturity ScheduleSerial BondsTHE DISTRICTSize and LocationOrganization and Government of the DistrictFacilitiesDistrict PerformanceCOMMUNITY SERVICESPublic UtilitiesMedical and Health FacilitiesRecreational, Cultural and Religious Facilities

    ECONOMIC INFORMATION CONCERNING THE DISTRICTEmploymentPopulation

    FINANCIAL INFORMATION CONCERNING THE DISTRICTFinancial OverviewCurrent Indebtedness of the DistrictHistory of IndebtednessDebt Service RequirementsOverlapping IndebtednessAuthority to Incur DebtAccounting, Budgeting and Auditing ProceduresSources of RevenueProperty ValuationsAssessment ProcedureProperty Tax Levies and CollectionsRetirement Plan

    INDEPENDENT PUBLIC ACCOUNTANTS

    State of MissouriLafayette CountyJackson CountyYearAssessed ValuationJurisdictionIndebtednessPercentageYearYearFundFundTotal

    Assessed ValuationOutstandingYear