Loading...
Arbitrage report (07-2014) GILMOI,EBELL 816-221-1000 MAIN GILMORE&BELL PC ST.LOUIS 816-221-1018 FAX 2405 GRAND BOULEVARD,SUITE 1100 WICHITA GILMOREBELL.COM KANSAS CITY,MISSOURI 64108-2521 OMAHA I LINCOLN October 20, 2014 Rod Franz,C.P.F.O. Director of Finance City of Salina, Kansas 300 West Ash Street, Room 206 P.O. Box 736 Salina,Kansas 67402-0736 Re: $3,800,000 General Obligation Temporary Notes, Series 2013-1 (the "Notes") issued by the City of Salina,Kansas Dear Rod: Enclosed are the following documents related to our computation of arbitrage rebate in connection with the above-referenced note issue: • Legal Opinion of Gilmore& Bell Regarding the Arbitrage Rebate Analysis; • Exhibit A—Explanation of Arbitrage Rebate Analysis; and • Exhibit B—Arbitrage Rebate Analysis as of July 30, 2014(the"Computation Date"). As of the Computation Date, no rebate payment or yield reduction payment is required to be made for the Notes. The amount accrued as of the Computation Date as a rebate liability attributable to the investment of the gross proceeds of the Notes subject to arbitrage rebate was negative $13,587.68. We understand that the Notes have been redeemed in full as of July 30, 2014. No future computations will be required. Please contact Jennifer Moehlman at 816-221-1000 or jmoehlman @gilmorebell.com if you have any questions. Very truly yours, Lrid K. Mische JLM:vp Enclosures cc: Gina Riekhof /i GILMOUBELL 816-221-1000 MAIN GILMORE&BELL PC ST.LOUIS 816-221-1018 FAX • 2405 GRAND BOULEVARD.SUITE 1100 WICHITA GILMOREBELL.COM KANSAS CITY,MISSOURI 64108-2521 OMAHA I LINCOLN October 20, 2014 City of Salina, Kansas Re: $3,800,000 General Obligation Temporary Notes, Series 2013-1 (the "Notes") issued by the City of Salina, Kansas — Legal Opinion Regarding Arbitrage Rebate Analysis as of July 30, 2014 Ladies and Gentlemen: We have acted as counsel to the City of Salina, Kansas (the "Issuer") in connection with the; preparation of the Arbitrage Rebate Analysis dated July 30, 2014 (the "Arbitrage Analysis") for the above-referenced Notes. We have attached as Exhibit A our Explanation of Arbitrage Rebate Analysis and as Exhibit B our Arbitrage Rebate Analysis. Our opinion is based on the facts and assumptions stated in the Explanation of Arbitrage Rebate' Analysis. Capitalized terms used in this opinion have the same meaning as described in the Explanation of Arbitrage Rebate Analysis. We have assumed that the financial records provided to us are accurate and correct. Unless! otherwise noted in the Explanation of Arbitrage Rebate Analysis, we have also assumed that the proceeds of the Notes and other funds were used and invested in accordance with the documents contained in the Transcript, including but not limited to the Federal Tax Certificate. Based upon the foregoing,we are of the opinion that, under existing law: 1. The accounting method, identification of funds and accounts subject to rebate or yield, reduction payment restrictions and the overall methodology employed in the preparation of the Arbitrage Analysis are in accordance with Section 148 of the Internal Revenue Code of 1986, as amended (the "Code")and United States Treasury Regulations and decisions. 2. As of the Computation Date, no rebate payment is required to be made for the Notes. 3. As of the Computation Date, no yield reduction payment is required to be made for the Notes. Our opinion is based on statutes, regulations and decisions in effect as of this date, and is intended for and can be relied on only by the parties to whom it is addressed. We understand that the Issuer will use this opinion and the Arbitrage Analysis to determine whether any rebate liability or yield reduction payment is due and the amount and timing of that payment. In preparing the Arbitrage Analysis, we have exercised our best efforts to (1) correctly analyze the financial records provided to us and correctly incorporate those records into the Arbitrage Analysis, (2) correctly interpret applicable provisions of the of the Code, United States Treasury Regulations, rulings, and decisions,and(3)accurately compute the amount of rebate payment or yield reduction payment owed to the Internal Revenue Service(the"IRS"). This opinion represents our reasoned judgment based on the financial records provided to us and existing statutes, regulations, rulings and decisions and the stated assumptions in the Explanation of Arbitrage Rebate Analysis. The conclusions in this opinion are not binding on the IRS. We express no opinion as to the tax-exempt status of interest on the Notes or as to compliance with the terms of the covenants and documents under which the Notes were issued. Very truly yours, LKM:jIm /1 GILMOREBELL Exhibit A Explanation of Arbitrage Rebate Analysis This Explanation of Arbitrage Rebate Analysis summarizes the methodology and primary assumptions used in the Arbitrage Rebate Analysis dated July 30, 2014 (the"Arbitrage Analysis") for the $3,800,000 General Obligation Temporary Notes, Series 2013-1 (the "Notes") issued by the City of Salina,Kansas(the"Issuer"). This explanation accompanies our legal opinion dated October 20,2014. General Matters The time period covered by the Arbitrage Analysis (the "Computation Period") began July 25, 2013 and ended July 30, 2014, the date the Notes were redeemed in full.. (The latter date is referred to as the"Computation Date.") We determined that the funds included in the Arbitrage Analysis were"gross proceeds" subject to rebate and/or yield restriction payments under Section 148 of the Internal Revenue Code of 1986, as amended (the "Code") and applicable United States Treasury Regulations and decisions. This determination was based on our review of the various documents included in the Transcript of Proceedings at the time the Notes were issued(the"Transcript.") The Arbitrage Analysis was prepared using financial records provided by the Issuer (the; "Investment Records.") The relevant investment data contained in the Investment Records for each fund! and account was entered in the Arbitrage Analysis. Multiple procedures were used to analyze and test the accuracy of the Investment Records as well as the accuracy and the overall reasonableness of the investment results for each fund or account that was included in the Arbitrage Analysis. Based on the; procedures employed, the results reflected in the Arbitrage Analysis appear to accurately incorporate the information in the Investment Records. However, the Arbitrage Analysis is not intended to be a mathematical verification of the information contained in the Investment Records or an audit of the investment results actually obtained. The Computation Date is a rebate computation installment payment date. The computation of yield on the Notes used in the Arbitrage Analysis is contained in the Transcript as an exhibit to the Federal Tax Certificate. All investments purchased or sold using gross proceeds of the Notes were treated as purchased and sold on the dates and at the prices reflected in the Investment Records, and these prices were assumed to be at fair market value of the investment on the purchase or sale date. Unless otherwise noted, investments that were required to be valued on dates other than a date, when they actually were purchased or sold, were valued either at par plus accrued interest or at present; value as of that date. These values are shown in the Arbitrage Analysis. Accounting for Expenditures and Investments Except as described below,Note proceeds were allocated to expenditures on the dates reflected in the Investment Records for the Improvement Fund. Note proceeds were assumed to have been spent in accordance with the various documents contained in the Transcript. In general these rules permit Note proceeds to be spent only for costs that can or must be capitalized for financial accounting or federal income tax purposes. All expenditures were assumed to have been paid only to third parties directly or as a valid reimbursement of the Issuer for costs previously spent for those purposes. The Issuer generally invests all funds (including proceeds of the Notes), in a variety of investments without regard to the sources from which the funds were derived (e.g., note proceeds, tax revenues, grants, etc.). Earnings from the investment of proceeds of the Notes were calculated based on the unspent balance of Note proceeds and the average monthly interest rate on Issuer's investments, as reported by the Issuer. The average monthly interest rates provided by the Issuer are included in Exhibit B. We understand that Investment earnings on proceeds of the Notes are initially deposited to the General Fund of the Issuer. Amounts in the General Fund were reasonably expected to be spent(using a "Note proceeds spent first" method of accounting) within six months of the date of deposit. Since the Notes are an issue of governmental purpose obligations, and because the General Fund contains tax or other revenues of the Issuer other than the proceeds of issues of tax exempt obligations, we have treated investment earnings on Note proceeds as spent on the date they were earned in accordance with Treasury Regulation §1.148-6(d)(6). Yield Reduction Payment–Restricted Investment No funds or accounts were identified as subject to investment yield restrictions. Exemption of Funds from Rebate–Bona Fide Debt Service Fund Amounts held in a "bona fide debt service fund" are not taken into account in computing arbitrage rebate if the gross earnings on such fund during a given Note Year are less than$100,000. If thel average annual debt service on the issue does not exceed $2,500,000, the $100,000 earnings test may be treated as satisfied. A"bona fide debt service fund" is a fund that— (1) is used primarily to achieve a proper matching of revenues with principal and interest payments within each note year; and 1 (2) is depleted at least once each note year, except for a reasonable carryover amount, not to exceed the greater of(A)the earnings on the fund for the preceding note year, or(B) one-, twelfth of the principal and interest payments on the bond issue for the preceding note year. We understand that the Debt Service Account qualified as a bona fide debt service fund for all Note years during the Computation Period. A-1 Exhibit B Arbitrage Rebate Analysis • Computed as of July 30, 2014 City of Salina, Kansas General Obligation Temporary Notes Series 2013-1 /1 GILMOI�E BELL Gil M O R E L G E L L, PC I City of Salina,Kansas General Obligation Temporary Notes Series 2013-1 ARBITRAGE REBATE ANALYSIS' Results as of July 30,2014 Summary of Issue Par $3,800,000 Allocation of Proceeds Downtown Issue Date July 25,2013 Street Lighting Note Year Date August I 81.8% Note Yield 0.44996% • Computation Date July 30,2014 um Discount 0.1% Ninth and Cloud Improvements 18.1% Summary of Rebate Computation Computation Results Rebate Liability by Source • Total Rebate Amount ($13,587.68) Downtown Street Lighting (7,293.72) Credits&Adjustments (3,217.14) • • No arbitrage rebate payment is due at this time. • Total Rebate Amount (13,587.68) The net rebate amount as of July 30,2014 is ($13,587.68). ($50,000) ($25,000) $0 825,000 $50,000 it 10/20/2014 -1- Gilmore&Bell,P.C. I I City of Salina,Kansas General Obligation Temporary Notes Series 2013-I ARBITRAGE REBATE ANALYSIS . Comments and Yield Comparison Comments Yield Comparison As of 7/30/2014 • The Debt Service Accounts qualified as a bona fide i.00% debt service fund for all note years ended during Bond Yield=0.45% this computation period. / • The Notes were redeemed in full on July 30,2014. 017%'' 0.1(8% No future computations will be required. 0.00% ® # Downtown Street Ninth and Ooud Lighting Improvements 10/20/2014 -2- Gilmore&Bell,P.C. iI 1 1 City of Salina,Kansas General Obligation Temporary Notes Series 20/3-1 - .. , - ACCOUNT NQ'I: UoNntod'n Street Lighting •. . . 1 Cash and Investment Activity I Imputed Interest Calculation Total Relevant Relevant Days 1 Cash Transactions I Investments I Cash and Investment Invested Invested , Imputed Date Cash In Cash Out Balance Purchase Receipt Earnings Balance Investments Rate Balance (Actual) �Earnings 7/25/2013 3,125,103.18 - 3,125,103.18 3,125,103.18 3,125,103.18 0.1350% 3,125,103.18 6' 69.35 7/31/2013 69.35 - 69.35 3,125,103.18 3,125,103.18 0.1350% 3,125,103.18 15, 173.38 8/15/2013 5,655.78 - 5,655.78 3,119,447.40 3,119,447.40 0.1470% 3,119,447.40 14 i 175.89 8/29/2013 147.39 - 147.39 3,1 19,300.01 3,1 19,300.01 0.1470% 3,119,300.01 I! 12.56 8/30/2013 1,053,357.00 - 1,053,357.00 2,065,943.01 2,065 943.01 0.1470°/. 2,065 943.01 I 8.32 8/31/2013 370.15 - 370.15 2,065,943.01 2,065,943.01 0.1470% 2,065,943.01 30' 249.61 9/30/2013 249.61 - 249.61 2,065,943.01 2,065,943.01 0.1830% 2,065,943.01 3, 31.07 10/3/2013 197,033.00 - 197,033.00 1,868,910.01 '1,868,910.01 0.1830% 1,868,910.01 28; 262.36 10/31/2013 293.43 - 293.43 1,868,910.01 1,868,910.01 0.1830°h 1,868 910.01 71 65.59 11/7/2013 85,999.00 - 85,999.00 1,782,911.01 1,782,911.01 0.1950% 1,782,911.01 23 r 219.08 11/30/2013 284.67 - 284.67 1,782,911.01 1,782,911.01 0.1950% 1,782,911.01 31 295.28 12/31/2013 295.28 - 295.28 1,782,911.01 1,782,911.01 0.1910% 1,782,911.01 31 289.22 1/31/2014 289.22 - 289.22 1,782,911.01 1,782,911.01 0.1910% 1,782,911.01 61 55.98 2/6/2014 364,153.00 - 364,153.00 1,418,758.01 1,418,758.01 0.1720% 1,418,758.01 22! 147.08 2/28/2014 203.06 - 203.06 1,418,758.01 1,418,758.01 0.1720°/a 1,418,758.01 13; 86.91 3/13/2014 526,354.81 - 526,354.81 892,403.20 892,403.20 0.1840% 892,403.20 18 80.98 3/31/2014 167.89 - 167.89 892,403.20 892,403.20 0.1840% 892,403.20 17: 76.48 4/17/2014 467,322.00 - 467,322.00 425,081.20 425,081.20 0.1890% 425,081.20 13:. 28.61 4/30/2014 105.09 - 105.09 425,081.20 425,081.20 0.1890°/ 425,081.20 151 33.02 5/15/2014 351,712.00 - 351,712.00 73,369.20 73,369.20 0.1970% 73,369.20 16! 6.34 5/31/2014 40,769.00 - 40,769.00 32,600.20 32,600.20 0.1970% - - - 5/31/2014 39.36 - 39.36 32,600.20 32,600.20 0.1970% 32,600.20 19 3.34 6/19/2014 32,600.20 - 32,600.20 0.00 0.00 0.1750% 0.00 I I' - 6/30/2014 3.34 - 3.34 0.00 0.00 0.1750% 0.00 - - Totals 3,125,103.18 3,127,473.63 3,125,103.18 3,125,103.18 2,370.45 2,370.45 Cash Out Less Cash In: 2,370.45 Investment Receipts minus Purchases: - 1 10/20/2014 -3- Gilmore&Bell P.C. ■ 1 I I i I I• l � City of Salina,Kansas General Obligation Temporary Notes Series 2013-1 .. . ACCOUNT'NO.I: Downtown Street'Lighting. . Arbitrage Rebate Computation I Investment Yield I Future Present Net Value Future Value Present Investment Factor® Value to Number Factor Q Value to Date Activity 0.699794% 7/30/2014 of Days 0.172039% 7/25/2013 7/25/2013 (3,125,103.18) 1.0071079 (3,147,316.06) 365 1.0000000 (3,125,103.18) 7/31/2013 69.35 1.0070102 69.84 360 0.9999713 69.35 8/15/2013 5,655.78 1.0067171 5,693.77 345 0.9999045 5,655.24 8/29/2013 147.39 1.0064437 148.34 331 0.9998376 147.37 8/30/2013 1,053,357.00 1.0064241 1,060,123.90 330 0.9998328 1,053,180.91 8/31/2013 370.15 1.0064241 372.53 330 0.9998280 370.09 9/30/2013 249.61 1.0058384 251.07 300 0.9996896 249.53 10/3/2013 197,033.00 1.0057799 198,171.82 297 0.9996752 196,969.01 10/31/2013 293.43 1.0052530 294.97 270 0.9995415 293.30 11/7/2013 85,999.00 1.0051165 86,439.01 263 0.9995129 85,957.11 11/30/2013 284.67 1.0046680 286.00 240 0.9994031 284.50 12/31/2013 295.28 1.0040833 296.49 210 0.9992551 295.06 1/31/2014 289.22 1.0034990 290.23 180 0.9991119 288.96 2/6/2014 364,153.00 1.0033821 365,384.62 174 0.9990880 363,820.91 2/28/2014 203.06 1.0029150 203.65 150 0.9989831 202.85 3/13/2014 526,354.81 1.0026620 527,755.96 137 0.9989115 525,781.86 3/31/2014 167.89 1.0023313 168.28 120 0.9988256 167.69 4/17/2014 467,322.00 1.0020007 468,256.97 103 0.9987493 466,737.50 4/30/2014 105.09 1.0017480 105.27 90 0.9986872 104.95 5/15/2014 351,712.00 1.0014564 352,224.24 75 0.9986157 351,225.12 5/31/2014 40,769.00 1.0011650 40,816.49 60 0.9985394 40,709.45 5/31/2014 39.36 1.0011650 39.41 60 0.9985394 39.30 6/19/2014 32,600.20 1.0007959 32,626.15 41 0.9984535 32,549.78 6/30/2014 3.34 1.0005823 3.34 30 0.9984010 3.33 2,370.45 (7,293.72) (0.00) Summary of: Downtown Street Lighting Arbitrage Rebate Amount: S (7,293.72) Total Investment Earnings: 2,370.45 Investment Yield: 0.1720% Average Amount Invested: S 1,480,682 Total Time Invested: 0.93 years 10/20/2014 -4- Gilmore&Bel(P.C. 1 i City of Salina,Kansas General Obligation Temporary Notes i Series 20/3-1 . ' , . ..1 ACCOUNT NO.2:Ninth arid Cloud Imlirovement`s . , . , . . . - Cash and Investment Activity I Imputed Interest Calculation 1 I i Total Relevant Relevant Days 1 I - Cash Transactions I • Investments I Cash and Investment Invested Invested I Imputed Date Cash In Cash Out Balance Purchase Receipt Earnings Balance Investments Rate Balance (Actual) I I Earnings 7/25/2013 691,388.82 - 691,388.82 691,388.82 691,388.82 0.1350% 691,388.82 61 15.34 7/31/2013 15.34 - 15.34 691,388.82 691,388.82 0.1350% 691,388.82 15 38.36 8/15/2013 1,263.27 - 1,263.27 690,125.55 690,125.55 0.1470% 690,125.55 14, I 38.91 8/29/2013 32.61 - 32.61 690,092.94 690,092.94 0.1470% 690,092.94 2 5.56 8/31/2013 82.83 - 82.83 690,092.94 690,092.94 0.1470% 690,092.94 51 13.90 9/5/2013 7,000.00 - 7,000.00 683,092.94 683,092.94 0.1830% 683,092.94 251 85.62 9/30/2013 99.52 - 99.52 683,092.94 683,092.94 0.1830% 683 092.94 101 34.25 10/10/2013 200.00 • - 200.00 682,892.94 682,892.94 0.1830% 682,892.94 14, 47.93 10/24/2013 5,500.00 - 5,500.00 677,392.94 677,392.94 0.1830% 677,392.94 7: 23.77 10/31/2013 105.95 - 105.95 677,392.94 677,392.94 0.1830% 677,392.94 71 i 23.77 11/7/2013 3,500.00 - 3,500.00 673,892.94 673,892.94 0.1950% 673,892.94 231 82.81 11/30/2013 106.58 - 106.58 673,892.94 673,892.94 0.1950% 673,892.94 5 18.00 12/5/2013 20,060.00 - 20,060.00 653,832.94 653,832.94 0.1910% 653,832.94 261 88.96 12/31/2013 106.96 - 106.96 653,832.94 653,832.94 0.1910% 653,832.94 31 106.06 1/31/2014 106.06 - 106.06 653,832.94 653,832.94 0.1910% 653,832.94 28 95.80 2/28/2014 95.80 - 95.80 653,832.94 653,832.94 0.1720% 653,832.94 31 95.51 3/31/2014 95.51 - 95.51 653,832.94 653,832.94 0.1840% 653,832.94 30 98.88 4/30/2014 98.88 - 98.88 653,832.94 653,832.94 0.1890% 653,832.94 201 67.71 5/20/2014 421,513.17 - 421,513.17 232,319.77 232,319.77 0.1970% 232,319.77 II' 13.79 5/31/2014 81.50 - 81.50 232,319.77 232,319.77 0.1970% 232,319.77 30. ' 37.62 6/30/2014 37.62 - 37.62 232,319.77 232,319.77 0.1750% 232,319.77 17 18.94 7/17/2014 120.00 - 120.00 232,199.77 232,199.77 0.1590% 232,199.77 71 7.08 7/24/2014 30,648.00 - 30,648.00 201,551.77 201,551.77 0.1590% 201,551.77 61 5.27 7/30/2014 201,583.06 - 201,551.77 31.29 - - 0.1590% - - - Totals 691,388.82 692,452.66 691,388.82 691,388.82 1,063.84 I 1,063.84 Cash Out Less Cash In: 1,063.84 Investment Receipts minus Purchases: - 1 1 I 1 10/20/1014 -S- Gilmore&Bel{P.C. • i • 1 City of Salina,Kansas General Obligation Temporary Notes Series 20/3-1 ' - ACCODNT NO.2: Ninth and Cloud Improvements. Arbitrage Rebate Computation I Investment Yield Future Present Net Value Future Value Present Investment Factor(u) Value to Number Factor @ Value to Date Activity 0.699794% 7/30/2014 of Days 0.180094% 7/25/2013 7/25/2013 (691,388.82) 1.0071079 (696,303.13) 365 1.0000000 (691,388.82) 7/31/2013 15.34 1.0070102 15.45 360 0.9999700 15.34 8/15/2013 1,263.27 1.0067171 1,271.76 345 0.9999000 1,263.14 8/29/2013 32.61 1.0064437 32.82 331 0.9998300 32.60 8/31/2013 82.83 1.0064241 83.36 330 0.9998200 82.82 9/5/2013 7,000.00 1.0063265 7,044.29 325 0.9998000 6,998.60 9/30/2013 99.52 1.0058384 100.10 300 0.9996750 99.49 10/10/2013 200.00 1.0056432 201.13 290 0.9996250 199.93 10/24/2013 5,500.00 1.0053701 5,529.54 276 0.9995551 5,497.55 10/31/2013 105.95 1.0052530 106.51 270 0.9995201 105.90 11/7/2013 3,500.00 1.0051165 3,517.91 263 0.9994901 3,498.22 11/30/2013 106.58 1.0046680 107.08 240 0.9993752 106.51 12/5/2013 20,060.00 1.0045705 20,151.68 235 0.9993502 20,046.96 12/31/2013 106.96 1.0040833 107.40 210 0.9992202 106.88 1/31/2014 106.06 1.0034990 106.43 180 0.9990704 105.96 2/28/2014 95.80 1.0029150 96.08 150 0.9989355 95.70 3/31/2014 95.51 1.0023313 95.73 120 0.9987707 95.39 4/30/2014 98.88 1.0017480 99.05 90 0.9986258 98.74 5/20/2014 421,513.17 1.0013593 422,086.11 70 0.9985260 420,891.85 5/31/2014 81.50 1.0011650 81.59 60 0.9984711 81.38 6/30/2014 37.62 1.0005823 37.64 30 0.9983263 37.56 7/17/2014 120.00 1.0002523 120.03 13 0.9982414 119.79 7/24/2014 30,648.00 1.0001164 30,651.57 6 0.9982065 30,593.03 7/30/2014 201,583.06 1.0000000 201,583.06 - 0.9981765 201,215.48 1,063.84 (3,076.82) (0.00) Summary of: Ninth and Cloud Improvements Arbitrage Rebate Amount: S (3,076.82) Total Investment Earnings: 1,063.84 Investment Yield: 0.1801% Average Amount Invested: S 582,623 Total Time Invested: 1.01 years 10/20/2014 -6- Gilmore&Bell P.C. I I City of Salina,Kansas General Obligation Temporary Notes Series 2013-1 - COMPUTATION CREDITS AND ADJUSTMENTS Arbitrage Rebate Computation Future Value Future Factor @ Value to Number Date Description Amount 0.449962% 7/30/2014 of Days 8/1/2013 Computation Credit (1,590.00) 1.0044921 (1,597.14) 359 7/30/2014 Computation Credit (1,620.00) 1.0000000 (1,620.00) - (3,210.00) Total Adjustments: S (3,217.14) 10/20/2014 -7- Gilmore&Bell,P.C. II City of Salina, Kansas General Obligation Temporary Notes Series 2013-1 Weighted Average Yields as Provided by Issuer'. Month Month Beg. Month End. Overall Yld Jul-11 7/1/2011 7/31/2011 0.308% Aug-11 8/1/2011 8/31/2011 0.289% Sep-11 9/1/2011 9/30/2011 0.295% Oct-II 10/1/2011 10/31/2011 0.275% Nov-11 11/1/2011 11/30/2011 0.385% Dec-11 12/1/2011 12/31/2011 0.385% Jan-12 1/1/2012 1/31/2012 0.312% Feb-12 2/1/2012 2/29/2012 0.322% Mar-12 3/1/2012 3/31/2012 0.321% Apr-12 4/1/2012 4/30/2012 0.348% May-12 5/1/2012 5/31/2012 0.348% Jun-12 6/1/2012 6/30/2012 0.330% Jul-12 7/1/2012 7/31/2012 0.329% Aug-12 8/1/2012 8/31/2012 0.307% Sep-12 9/1/2012 9/30/2012 0.327% Oct-12 10/1/2012 10/31/2012 0.350% Nov-12 11/1/2012 11/30/2012 0.372% Dec-12 12/1/2012 12/31/2012 0.358% Jan-13 1/1/2013 1/31/2013 0.313% Feb-13 2/1/2013 2/28/2013 0.283% Mar-13 3/1/2013 3/31/2013 0.312% Apr-13 4/1/2013 4/30/2013 0.219% May-13 5/1/2013 5/31/2013 0.181% 10/20/2014 -8- Gilmore&Bell,P.C. I I I i II Weighted'A"verage Yields as Prow ided' iy Issuer` °. Month Month Beg. Month End. Overall Yld Jun-13 6/1/2013 6/30/2013 0.148% Jul-13 7/1/2013 7/31/2013 0.135% Aug-13 8/1/2013 8/31/2013 0.147% Sep-13 9/1/2013 9/30/2013 0.183% Oct-13 10/1/2013 10/31/2013 0.183% Nov-13 11/1/2013 11/30/2013 0.195% Dec-13 12/1/2013 12/31/2013 0.191% Jan-14 1/1/2014 1/31/2014 0.191% Feb-14 2/1/2014 2/28/2014 0.172% Mar-14 3/1/2014 3/31/2014 0.184% Apr-14 4/1/2014 4/30/2014 0.189% May-14 5/1/2014 5/31/2014 0.197% Jun-14 6/1/2014 6/30/2014 0.175% Jul-14 7/1/2014 7/31/2014 0.159% • � I 10/20/2014 -9- Gilmore&Bell P.C. • I I