R99-030 04-12-99RESOLUTION NO. R99-30
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
PEARLAND, TEXAS, AUTHORIZING THE CITY MANAGER OR HIS
DESIGNEE TO ENTER INTO A CONTRACT WITH ARBITRAGE
COMPLIANCE SPECIALISTS, INC. FOR ARBITRAGE REBATE
SERVICES OF ALL CURRENT OUTSTANDING BOND ISSUES FOR
THE CITY OF PEARLAND.
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PEARLAND, TEXAS:
Section 1. That certain contract by and between the City of Pearland and
Arbitrage Compliance Specialists, Inc., is hereby authorized and approved.
Section 2. That the City Manager or his designee is hereby authorized to
execute and the City Secretary to attest the contract with Arbitrage Compliance
Specialists, Inc., for and on behalf of the City of Pearland, for arbitrage rebate services
of all current outstanding bond issues for the City.
PASSED, APPROVED and ADOPTED this the Z,,2- ~''''//
, A.D., 1999.
TOM REID
MAYOR
day of
ATTEST:
~U~ E ~' ~.Z'~¢''J''
APPROVED AS TO FORM:
DARRIN M. COKER
CITY ATTORNEY
PEARLAND
Page 1 of 1
To:
Glen Erwin, City Manager
Through:
From:
Date:
David Castillo, Director of Finance ~
Gordon Island, Purchasing Offic~/~
April 5, 1999
Subject: Recommendation for Arbitrage Rebate Services, RFP 99-049
Introduction: A proposal has have been received from Arbitrage Compliance Specialists, Inc,
Englewood, Colorado for Arbitrage Rebate Compliance Services. Arbitrage rebate compliance services
are required by the Internal Revenue Service ORS) for all current outstanding bonds issued by the City.
The service is included in the FY98/99 approved budget (Other Requirement/Debt Services, Special
Services).
Background: This is an extension of a contract executed April 14, 1998 for 1990, 91 & 93 bond issues.
Request for Qualifications were evaluated from three major firms engaged in arbitrage services in Texas.
Arbitrage Compliance Specialists, Inc., with a regional office in Houston, was rated the best qualified
provider of these services. Further, the proposed service provider is highly recommended by the City's
auditing firm. The work performed to date has been very satisfactory. The service falls within the scope
of services under the State of Texas Government Code, Chapter 2254. Professional Services and
Consulting Act.
The Internal Revenue Service Code, section 148 (f), requkes arbitrage rebate reports every five years
for amounts over 5 million dollars. A "Small Issuer Exception" report is required for amounts under 5
million.
Recommendation: Staff recommends extending this contract to include all current outstanding bond
issues for the fee not to exceed $31,825.00. A schedule otissues is included for review and information.
3519 LIBERTY DRIVE · PEARLAND, TEXAS 77581-5416-19 · (281) 485-2411 ° www. ci.pearland.tx.us
Bond Issue
$2,000,000
Public Improvement Bonds,
Series 1988
$2,125,000
Tax and Revenue Certificates of
Obligation, Series 1991
$7,364,39 ! .80
Refunding Bonds, Series 1990
Delivery Date: 10/11/90
$2,000,000 Street Improvement
Bonds, Series 1992
$6,510,000
Refunding Bonds, Series 1993
Delivery Date: 5/11/93
$5,000,000
Combination Tax and Revenue
Certificates of Obligation
Series 1995
Delivery Date: 5/24195
$1.115M Water and Sewer System
Revenue Refunding Bonds, Series
1996A
Delivery Date: 6/I 9/96
$8.870M Water and Sewer System
Revenue Bonds, Series 1996B
Delivery Date: 6/19~96
$6,250,000
Certificates of Obligation, Series
1997
Delivery Date: 4/3/97
$5,000,000
Sales Tax Revenue Bonds, Series
1997
Delivery Date: 5/7/97
$5,500,000
Certificates of Obligation
Series 1997A
Delivery Date: 9/25/97
Legal Documents Required
13 ACS signed Engagement Letter
for Legal Set-up Review (ACS
will not proceed with any work
unless authorized).
13 Official Statement
13 Arbitrage Tax Certificate
13 Form 8038-G
None
None
CJ ACS signed Engagement Letter
for required 10th Year Report
(ACS will not proceed with any
work unless authorized)
ACS completed Rebate Report
for 5th Year 10/11/90 - 10/11/95
13 ACS signed Engagement Letter
for Legal Set-up Review (ACS
will not proceed with any work
unless authorized).
13 Official Statement
13 Arbitrage Tax Certificate
13 Form 8038-G
None
Rebate Report Done for 5th Year
5/11/93 - 5/11/98
0 ACS signed Engagement Letter
for required 5th Year Report (ACS
will not proceed with any work
unless authorized)
13 Form 8038-G
None
13 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
None
13 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
None
13 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
13 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
O Arbitrage Tax Certificate
13 Form 8038-G
None
C21 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
Investment
Information Requirements
This issue may have met
Small Issuer Exception
None
ACS completed initial legal
review and this issue met
Small lssuer Exception.
13 Investment data:
Interest & Sinking Fund
9/!/96 through 10/31/00
This issue may have met
Small Issuer Exception.
None until Final Rebate
Report due for IRS after
3/1/03, then need:
13 Investment data:
Interest and Sinking Fund
(Reserve Portion)
5/31/98 through 3/I/03
13 Investment data:
5/24/95 through 5/24/00
(5th year Report due for
IRS)
Investment data:
6/19196 through Current
13 Investment data:
6/19196 through Current
13 Investment data:
4/3/97 through Current
13 Investment data
5f7/97 through Current
13 Investment data
9/25/97 through Current
DATE:
VENDOR:
Ap~l13,1999
PEARLAND
Arbitrage Compliance Specialists, Inc.
3800 South Albion St, Suite 200
Englewood, CO 801104239
Janet P. Sacks, Director
Page I of I
DEAR VENDOR:
SUBJECT:
NOTICE OF CONTRACT
ACCEPTANCE AND AWARD
The City of Pearland accepts your offer to supply the listed commodities and/or sentices in accordance with the terms
and conditions of the invitation to bid and your bid submission. Releases for the commodities and/or services will be
in the form of a purchase order or contract. All invoices are to be mailed to the Finance Department, 3519 Liberty,
Pearland, TX 77581. ffyou have any questions, contact the Purchasing Office. Please sign and return one copy of this
document as acknowledgment.
Authorized Agem Date
CLASS/ITEM & DESCRIFFION
BID NO: 98-017A
CONTRACT NO: 99-017A
CONTRACT PERIOD: 4-13-99 to 4-12-00 Or until services are completed
Commodity/Service: 946-030 Contract agreement for Rebate Services in accordance with IRS regulations Section
148(0.
1. Rebate Services for bonds issues noted on attached schedule and engagement letter for each issue.
2. The City will issue a bl3.1cet order for the services not to exceed $31,825.00.
3. Payment terms net 30 days. Blanket order number is to be noted on all invoices for payment.
4. Delivery of reports will be fob destination within 30 calendar days of receipt of client information.
5. Fee will be in accordance with fee schedule.
CC:
Null-Lairson CPA's
11 Greenway Plaza, Suite 1515
Houston, TX 77046
Attn: Charles G. Yaple, CPA
3519 LIBERTY DRIVE * PEARLAND, TEXAS 77581-5416-19 o (281) 485-2411 o www. ci.pearland.tx.us
Bond Issue
$2,000,000
Public Improvement Bonds.
Series 1988
$2.125,000
Tax and Revenue Certificates of
Obligation, Series 1991
$7.364,391.80
Refunding Bonds, Series 1990
Delivery Date: 10/11/90
S2,000,000 Street Improvement
Bonds, Series 1992
$6,510,000
Refunding Bonds, Series 1993
Delivery Date: 5/11/93
$S,000,000
Combination Tsx and Revenue
Certificates of Obligation
Series 1995
Delivery Date: 5/24/95
$1.115M Water and Sewer System
Kevenue Kefunding Bonds, Series
1996A
Deliver), Date: 6/19/96
$8.870M Water and Sewer System
Revenue Bonds, Series 1996B
Delivery Date: 6/19/96
$6,250,000
Certificates of Obligation, Series
1997
Delivery Date: 4/3/97
S5,000,000
Sales Tax Revenue Bonds, Series
1997
Delivery Date: 5/7/97
S5,500.000
Certificates of Obligation
Series 1997A
Delivery Date: 9/25/97
l.egal Documents Required
13 ACS signed Engagement Letter
for Legal Set-up Review (ACS
will not proceed with any work
unless authorized).
El Official Statement
13 Arbitrage Tax Certificate
13 Form 8038-G
None
None
13 ACS signed Engagement Loner
for required IOth Year Report
(ACS will not proceed with any
work unless authorized)
ACS completed Rebate Report
for 5th Year I0/! !/90 - 10/I 1/95
13 ACS signed Engagement Letter
for Legal Set-up Review (ACS
will not proceed with any work
unless authorized).
13 Official Statement
13 Arbitrage Tax Certificate
13 Form 8038-G
None
Rebate Report Done for $th Year
5/11/93 - 5/I !/98
13 ACS signed Engagement Letter
for required Sth Year Report (ACS
will not proceed with any work
unless authorized)
El Form 8038-G
None
C3 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
None
0 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
None
O ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
13 ACS signed Engagement Letter
(ACS will not proceed with any
work unless authorized)
C} Arbitrage Tax Certificate
O Form 8038-G
None
ID ACS signed Engagement Lcucr
(ACS will not proceed with any
work unless authorized)
Investment
Information Requirements
This issue ma~ have met
Small issucr Exccptlon
None
ACS completed initial legal
review and this issue met
Small Issucr Exception.
C] Investment data:
Interest & Sinking Fund
9/I/96 through 10/31/00
This issue ~ have met
Small Issuer Exception.
None until Final Rebate
Rcpod due for IlLS after
3/1103, then need:
13 Investment data:
Interest and Sinking Fund
(Reserve Portion)
5/'3 !/98 through 311103
13 Investment data:
S/24/95 through 5/24100
(5th year Report due for
IRS)
lfivcstmcnt daM:
6/19/96 through Current
13 Investment data:
6/19/96 through Current
[nvcst~nent data:
4/3/97 through Current
Investment data
5/'//97 through Currcnt
O Investment data
9/25/97 through Current
ARB ITRAG E
COMPLIANCE
SPECI.ALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-54 16
and
Mr. Charles G. Yaple, CPA
Nuli-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
March 5, 1999
3800 South Albion Street, Suite 200
Englewood, Colorado 80110-4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
Colurnbia. S4xr~h CaPolina
Houston. Texas
LaJofa, Calikynia
Porfand,,Oregon
Sa~ Lake Cily. Utah
W'dmingfon, Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$7,364,391.80 REFUNDING BONDS, SERIES 1990
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. C'ACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(f) of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
$7,364,391.80 REFUNDING BONDS, SERIES 1990
Computation Period I0/11/95 - 10/11/00 as part of the period
10/11/90 - 10/11/00 (10th Year Report as required by the IRS)
Rebate Report Fee for Fixed Rate Bond (1 year @ $1,500 per year) $1,500
Rebate Report Fee for computations in excess of I year ($575 for additional
year; 4 years) 2,300
Hourly Fees for Uncommingling/Allocation of Interest & Sinking Fund, Reserve
Portion (4 hours ~ $125/hour) 500
TOTAL $4.3000
Data Requirement: Interest and Sinking Fund 9/1/96 - 10/3 !/00 when available.
Foomote:
OOptional Charges for all issues. if applicable: $125 per hour - Uncornmingling of any funds. accounts or
investments. as required; Transferred Proceeds Allocations from the prior refunded bonds. as required;
preparation of Form 8038-T.
The Issuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the mount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the Issuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the Issuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the mount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, amend or interpret such regulations and pronouncements from time to
time, with the result that the amount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and .invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
March 5, 1999
A R B I T R A G E
COMPLIANCE
SPECIALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty DriVe
Pearland, Texas 77581-54 16
and
Mr. Charles G. Yaple, CPA
NulI-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
3800 South Albion Street. Suite 200
Englewood. Colorado 801 I0-4239
303. 756. 5100 Fax: 303. 756. 090t
Regional and Affiliated Offices:
Colurrf~a. South Carolina
Houston. Texas
La Joila. CaWtom e
Po, lland. Oregon
Sait Lake City. Ulah
Wik~on. Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$5;500,000
CERTIFICATES OF OBLIGATION
SERIES 1997A
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(t) of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
55,500,000 Certificates of Obligation, Series 1997A
Computation Period 9/25/97 - 9/25/99 (2 Year Report)-
One-Time Initial Set-Up Review Fee
Rebate Report Fee for Fixed Rate Bond (1 year ~ $1,500 per year)
Rebate Report Fee for computations in excess of I year ($575 for additional
year; I year)
TOTAL
$ 4500
1,500
575
$2,5250
Data Requirement: Investment data 9/25/97 - 9/25/99
Footnote:
~`4n initia~ set~up fee is required f~r each b~nd issue that d~es n~t have a pri~r rebate rep~rt. This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which rituals are subject
to arbitrage rebate.
{}Optional Charges for all issues. if applicable; $125 per hour - Uncommingling of any funds. accounts or
investments. as required: Transferred Proceeds Allocations from the prior refunded bonds. as required:
preparation of Form 8038-T.
The lssuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the amount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the lssuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired ~vith gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the lssuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the lssuer as to the amount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, amend or interpret such regulations and pronouncements from time to
time, with the result that the amount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
March 5, 1999
AR B IT RAG E
COMPLIANCE
SPECIALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-5416
and
Mr. Charles G. Yaple, CPA
Nuli-Lairson
Certified Public Accountants
I 1 Greenway Plaza, Suite 1515
Houston, Texas 77046
3800 South Albion Street, Suite 200
Englewood, Colorado 80 t 10.4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
Columbia, South Carolina
HO~ Texas
Salt Lake City. Utah
Winit~on, De/aware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$5,000,000
SALES TAX REVENUE BONDS
SERIES 1997
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. C'ACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(0 of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
$5,000,000 Sales Tax Revenue Bonds, Series 1997
Computation Period 5/7/97 - 5/7/99 (2 Year Report)
One-Time Initial Set-Up Review Fee
Rebate Report Fee for Fixed Rate Bond ( 1 year @ $ 1,500 per year)
Rebate Report Fee for computations in excess of I year ($575 for additional
year; I year)
TOTAL
$ 4500
1,500
575
$2.5250
Data Requirement: Non-Arbitrage Certificate, Form 8038-G and
investment data 5/7/97 - 5/7/99
Footnote:
~~4n initia~ set~up fee is required f~r each b~nd issue that d~es n~t have a pri~r rebate rep~rt~ This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which funds are subject
to arbitrage rebate.
{}Optional Charges for all issues, if applicable: $125 per hour - Uncommingling of any funds, accounts or
investments, as required: Transferred Proceeds ,41locations from the prior refunded bonds, as required;
preparation of Form 8038-T.
The Issuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the amount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the Issuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the lssuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the mount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other .
pronouncements and supplement, mend or interpret such regulations and pronouncements from time to
time, with the result that the mount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-5416
and
Mr. Charles G. Yaple, CPA
Nu!l-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
March 5, 1999
ARB IT RAG E
COMPLIANCE
SPECIALISTS
3800 South Albion Street. Suite 200
Engle wood. Colorado 80110.4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
Cobml~, South Caro~ina
Houston, Texas
LaJ~la, Califomia
Pod/and, Oregon
Salt Lake Cify, Utah
~, Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$6,250,000
CERTIFICATES OF OBLIGATION
SERIES 1997
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "lssuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(0 of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
One-Time Initial Set-Up Review Fee
Rebate Report Fee for Fixed Rate Bond (I year @ $1,500 per year)
Rebate Report Fee for computations in excess of I year ($575 for additional
year; 1 year)
TOTAL
$ 4500
1,500
575
$2.5250
Data Requirement: Investment data 4/3/97 - 4/3/99
Footnote:
OAn initial set-upfee is required for each bond issue that does not have a prior rebate report. This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which funds are subject
to arbitrage rebate.
OOptional Charges for all issues. if applicable: $125 per hour - Uncommingling of any funds. accounts or
investments. as required; Transferred Proceeds .41locations from the prior refunded bonds. as required;
preparation of Form 8038-T.
The lssucr undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the mount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the Issuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entided to rely entirely on information provided by the Issuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the mount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, amend or interpret such regulations and pronouncements from time to
time, with the result that the mount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
March 5, 1999
ARB IT RAG E
COM.PLIANCE
SPECIALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-5416
and
Mr. Charles G. Yaple, CPA
Nuli-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 15 15
Houston, Texas 77046
3800 South Albion Street, Suite 200
Englewood, Colorado 80110.4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
Column. South Carotina
Houston. Texas
La Jotia. Califorraa
Pofltand. Oregon
Salt Lake City. Utah
Wdmington, Deiaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$1,115,000
WATER AND SEWER SYSTEM REVENUE REFUNDING BONDS
SERIES 1996A
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(0 of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
$1,115,000 Water and Sewer System Revenue Refunding Bonds,
Series 1996A
Computation Period 6/19/96 - 6/19/99 (3 Year Report)
One-Time Initial Set-Up Review Fee
Rebate Report Fee for Fixed Rate Bond (I year ~ $1,500 per year)
Rebate Report Fee for computations in excess of I year ($575 for additional
year; 2 years)
TOTAL
$ 4500
1,500
1.150
$3,1000
Data Requirement: Investment data 6/19~96 - 6/19~99
Footnote:
~.4n initia~ set~up fee is required f~r each b~nd issue that d~es n~t have a pri~r reba~e rep~rt~ This fee covers our
initial research on the bond issue and legal fees frora our bond counsel who determines which funds are subject
to arbitrage rebate.
OOptional Charges for all issues. if applicable: $125 per hour - Uncornmingling of any funds. accounts or
investments, as required: Transferred Proceeds Allocations from the prior refunded bonds. as required.'
preparation of Form 8038-7~
The Issuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the mount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the Issuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations oi' to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the Issuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the lssuer as to the mount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, mend or interpret such regulations and pronouncements from time to
time, with the result that the mount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
Mr. David Casti!lo, Director of Finance
and
Ms. Janet Eastbum, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-5416
and
Mr. Charles G. Yaple, CPA
Null-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
March 5, 1999
ARB ITRAG E
COMPLIANCE
SPECIALISTS
INCORPORATED
3800 South Albion Street, Suite 200
Englewood, Colorado 80t t0-4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
Cdunfoia. Soo~ Carotina
HOUStOn. Texas
Poa!an~Oreg, on
Salt Lake City, Utah
W~. Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$8,870,000
WATER AND SEWER SYSTEM REVENUE BONDS
SERIES 1996B
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. C'ACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(0 of the Internal Revenue Code (the "Code") and
those regulations promulgated therounder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
$8,870,000 Water and Sewer System Revenue Bonds, Series 1996B
Computation Period 6/19/96 - 6/19/99 (3 Year Report)
One-Time Initial Set-Up Review Fee
Rebate Report Fee for Fixed Rate Bond (1 year @ $1,500 per year)
Rebate Report Fee for computations in excess of I year ($575 for additional
year; 2 years)
TOTAL
$ 4500
1,500
1.150
$3.1000
Data Requirement: Investment data 6/! 9/96 - 6/19/99
Footnote:
~`4n initial ~et~upfee is required f~r each b~nd issue tha~ d~es n~t have a pri~r rebate rep~rt~ This fee covers our
initial research on the bond issue and legal fees frora our bond counsel who determines which funds are subject
to arbitrage rebate.
O Optional Charges for all issues. if applicable: $125 per hour - Uncommingling of any funds. accounts or
investments. as required; Transferred Proceeds Allocations from the prior refunded bonds. as required;
preparation of Form 8038-T.
The lssuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the mount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liabilit~ of the Issuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the Issuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the amount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, mend or interpret such regulations and pronouncements from time to
time, with the result that the mount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
March 5, 1999
ARB IT RAGE
COMPLIANCE
SPECIALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-5416
and
Mr. Charles G. Yaple, CPA
Nuil-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
3800 South Albion Street, Suite 200
Englewood, Colorado 80110.4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
Columbia. South Carolina
Houston. Texas
La Jo#a. Callfomia
Pt~tXand. Oregon
Salt Lake C~. Utah
P. qtmit~on. Detaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$5,000,000 COMBINATION TAX AND REVENUE
CERTIFICATES OF OBLIGATION, SERIES 1995
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(f) of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
$5,000,000 COMBINATION TAX AND REVENUE CERTIFICATES
OF OBLIGATION, SERIES 1995
Computation Period 5/24/95 - 5/24/00
(5th Year Report as required by the IRS)
One-Time Initial Set-Up Review Fee
Rebate Report Fee for Fixed Rate Bond (1 year ~ $1,500 per year)
Rebate Report Fee for computations in excess of I year ($575 for additional
year; 4 years)
TOTAL
$ 450O
1,500
2.300
$4,2500
Data Requirement: Form 8038-G, investment data 5/24/95 - 5/24/00
Footnote:
O Jn initial set-up fee is required for each bond issue that does not have a prior rebate report. This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which funds are subject
to arbitrage rebate.
{}Optional Charges for all issues. if applicable: $125 per hour ~ Uncommingling of any funds. accounts or
investments. as require& Transferred Proceeds Allocations from the prior refunded bonds. as required.'
preparation of Form 8038-E
The lssuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the amount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the Issuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the Issuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the lssuer as to the amount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, amend or interpret such regulations and pronouncements from time to
time, with the result that the amount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
ARB ITRAG E
COMPLIANCE
SPECIALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastbum, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-54 ! 6
and
Mr. Charles G. Yaple, CPA
NulI-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
March 5, 1999
3800 South Albion Street, Suite 200
Englewoocl, Colorado 80110-4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
ColumbO. S~lh Carolina
Houston. Texas
La Jolla. Cagomia
Pordan~. Oregon
Salt Lake City, Utah
W'dmingto~ Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$2M 1988 PUBLIC IMPROVEMENT BONDS
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(1) of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
152M 1988 PUBLIC IMPROVEMENT BONDS
One-Time Initial Set-Up Legal Review Fee
TOTAL
$450.000
$450.0O
Data Requirement: Official Statement, Non-Arbitrage Tax Certificate,
Form 8038-G.
Footnote:
~`4n initia~ se~~upfee is required f~r each b~nd issue that d~es n~t have a pri~r rebate rep~rt~ This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which funds are subject
to arbitrage rebate.
The lssuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the amount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the lssuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by ~e lssuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the amount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, mend or interpret such regulations and pronouncements from time to
time, with the result that the mount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
remm to Mr. Charles Yaple of Nul!-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
ARBITRAGE
COMPLIANCE
SPECIALISTS
INCORPORATED
Mr. David Castillo, Director of Finance
and
Ms. Janet Eastburn, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-5416
and
Mr. Charles G. Yaple, CPA
NulI-Lairson
Certified Public Accountants
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
March 5, 1999
3800 South Albion Street. Suite 200
Englewood, Colorado 80 t 10-4239
303. 756. 5100 Fax: 303. 756. 0901
Regional and Affiliated Offices:
C~umbia. South Carolina
I'~uston. Texas
La Joaa. CalifonVa
PorrlaM. G, egon
Sail Lake Cily, Utah
W'drnington. Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$2M 1992 STREET IMPROVEMENT BONDS
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(0 of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
[$2M 1992 STREET IMPROVEMENT BONDS
One-Time Initial Set-Up Legal Review Fee
TOTAL
$450.000
$450.00
Data Requirement: Official Statement, Non-Arbitrage Tax Certificate,
Form 8038-G.
Footnote:
~~4n initia~ se~~upfee is required f~r each b~nd issue ~hat d~es n~t have a pri~r rebate rep~rt~ This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which funds are subject
to arbitrage rebate.
The lssuer undertakes to provide or cause to be provided to ACS all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the amount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the lssuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the Issuer without
independent verification.
With re.spect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the mount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, mend or interpret such regulations and pronouncements from time to
time, with the result that the mount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
If this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Nu!l-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-
ARB ITRAG E
COMPLIANCE
SPECIALISTS
March 25, 1999
3800 South Albion Street, Suite 200
Englewood, Colorado 80 t 10-4239
303. 756. 5100 Fax.' 303. 756. 0901
Mr. David Castiilo, Director of Finance
and
Ms. Janet Eastbum, Staff Accountant II
City of Pearland
3519 Liberty Drive
Pearland, Texas 77581-54 i 6
and
Mr. Charles G. Yaple, CPA
NulI-Lairson
Certified Public Accountants
1 I Greenway Plaza, Suite 1515
Houston, Texas 77046
Regional at~d Affiliated Oftfur:
Caum~. S<~h Caro~na
Houston. Texas
La ~ Califoo~a
Pordana. Orego~
Salt Lake Chy. Utah
Wdm~jto~. Delaware
CITY OF PEARLAND, TEXAS
ARBITRAGE REBATE COMPLIANCE SERVICES
$17,100,000
CERTIFICATES OF OBLIGATION
SERIES 1998
This letter is to propose the engagement of Arbitrage Compliance Specialists, Inc. CACS") to the
City of Pearland (the "Issuer") for the purpose of performing calculations and/or services relating to the
arbitrage rebate requirements contained in Section 148(f) of the Internal Revenue Code (the "Code") and
those regulations promulgated thereunder for the following issue. Listed below is the issue requiring
computations and ACS's fees to complete these calculations.
One-Time Initial Set-Up Review Fee
TOTAL
Footnote:
4Y~5_..QO
~`4n initia~ set~up fee is required f~r each b~nd issue that d~es n~t have a pri~r rebate rep~rt. This fee covers our
initial research on the bond issue and legal fees from our bond counsel who determines which funds are subject
to arbitrage rebate.
The issuer undertakes to provide or cause to be provided to AC5; all such relevant data as specified by
ACS from time to time, with respect to each Calculation Date within 30 days after such date and shall
cooperate with all reasonable requests of ACS in connection therewith. This information will be necessary
to identify the amount of "gross proceeds" (as that term is used in the Code) of the issue subject to the
rebate/penalty requirement, investment income thereon and applicable yields on the issue and on such
investments in order to calculate the rebate and/or penalty liability of the lssuer with respect to the issue as
of each Calculation Date. ACS is not being engaged hereunder to independently determine whether there
were "prohibited payments" or "imputed receipts" within the meaning of the Treasury Regulations or to
perform an audit or review of the investments acquired with gross proceeds or the payment of debt service
on the issue. ACS will be entitled to rely entirely on information provided by the Issuer without
independent verification.
With respect to each Calculation Date, ACS will prepare schedules reflecting the relevant calculations
and assumptions involved and will deliver a rebate report and instructions to the Issuer as to the amount of
rebate liability as of such Calculation Date.
Although the Treasury has published certain regulations and other pronouncements relating to the
calculation of arbitrage rebate and penalty, the Treasury may publish additional regulations and other
pronouncements and supplement, amend or interpret such regulations and pronouncements from time to
time, with the result that the amount of rebate and/or penalty liability determined by ACS may be subject to
adjustment in the future.
if this engagement letter is satisfactory, please have an authorized official execute one copy and
return to Mr. Charles Yaple of Null-Lairson or to me at ACS. We welcome any questions you may have,
and invite you to call me at ACS at anytime at (800) 672-9993.
Sincerely,
Arbitrage Compliance Specialists, Inc.
Janet P. Sacks, Director
Please acknowledge acceptance of this engagement by signing and returning one copy of this letter to
Arbitrage Compliance Specialists, Inc.
Accepted
Title
Date
-2-