Orange County NC Website
147 <br /> The 2021 Bonds will be delivered in book-entry form only without physical delivery of certificates <br /> to beneficial owners of the 2021 Bonds. Payments to beneficial owners of the 2021 Bonds will be made <br /> by The Depository Trust Company("DTC"),New York,New York,and its participants. See Appendix E, <br /> "BOOK-ENTRY ONLY SYSTEM"hereto. So long as Cede & Co. is the registered owner of the 2021 <br /> Bonds,references herein to registered owner or Owners of the 2021 Bonds means Cede& Co. and not the <br /> beneficial owners of the 2021 Bonds. <br /> TAx STATUS <br /> [In the opinion of Bond Counsel, under existing law and subject to conditions described under <br /> "TAX TREATMENT" herein, (1) interest on the 2021A Bonds paid by the County (a) is not includable <br /> in the recipient's gross income for federal income tax purposes and(b) is not an item of tax preference for <br /> purposes of the federal alternative minimum income tax,(2)interest on the 2021 B Bonds paid by the County <br /> will not be excluded from gross income for federal income tax purposes,and(3)interest on the 2021 Bonds <br /> is exempt from current State of North Carolina income taxes.] See"TAX TREATMENT." <br /> PROFESSIONALS <br /> FHN Financial Capital Markets and Robert W.Baird&Co. Incorporated(the"Underwriters")are <br /> underwriting the 2021 Bonds. The Bank of New York Mellon Trust Company,N.A. is serving as Trustee <br /> with respect to the 2021 Bonds. Davenport & Company LLC is serving as financial advisor. Sanford <br /> Holshouser LLP is serving as Bond Counsel. John L. Roberts, Esq. is the County Attorney. <br /> McGuireWoods LLP is serving as counsel to the Underwriters. <br /> POTENTIAL IMPACT OF COVID-19 <br /> The continued spread of COVID-19 has impacted and will continue to impact global financial <br /> markets, national, State, and local economies, and areas of transportation. Management of the County is <br /> closely monitoring the situation. The County cannot predict the ultimate effects of COVID-19 on (i) the <br /> financial and operating condition of the County or(ii)the investment in the 2021 Bonds. See Appendix A, <br /> "THE COUNTY—RECENT DEVELOPMENTS RELATED TO COVID-19." <br /> ADDITIONAL INFORMATION <br /> Summaries of the Trust Agreement and the Deed of Trust, including a list of definitions of certain <br /> terms, are included as Appendix C. All quotations from and summaries and explanations of the Trust <br /> Agreement and the Deed of Trust contained in this Official Statement, including in Appendix C, do not <br /> purport to be complete. Reference is made to such documents for full and complete statements of their <br /> respective provisions. <br /> Additional information and copies in reasonable quantity of the principal financing documents may <br /> be obtained from the County at 200 South Cameron Street,Hillsborough,North Carolina 27278,Attention: <br /> Chief Financial Officer. Copies of such documents can also be obtained during the offering period from <br /> FHN Financial Capital Markets at 845 Crossover Lane,Memphis,Tennessee 38117 or Robert W. Baird& <br /> Co. Incorporated at 380 Knollwood Street, Suite 440, Winston-Salem, North Carolina 27103. After the <br /> offering period, copies of such documents may be obtained from the Trustee at 10161 Centurion Parkway, <br /> Jacksonville,Florida 32256. <br /> 3 <br />