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HomeMy WebLinkAboutRes 2023-08-1529 Anna CDC- Loan Agreement- Government Capital CorporationCERTIFICATE OF CITY SECRETARY THE STATE OF TEXAS § COUNTY OF COLLIN § CITY OF ANNA § I, the undersigned, City Secretary of the City of Anna, Texas DO HEREBY CERTIFY as follows: 1. On August 22, 2023, a regular meeting of the City Council of the City of Anna, Texas, was held at a meeting place within the City; the duly constituted members of the Council being as follows: Nate Pike Mayor Lee Miller Mayor Pro Tem Randy Atchley Deputy Mayor Pro Tem Stan Carver II Councilmember Kevin Toten Councilmember Pete Cain Councilmember Elden Baker Councilmember and all of said persons were present at said meeting, except the following: A) i�A Among other business considered at said meeting, the attached resolution entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANNA, TEXAS ("CITY"), APPROVING (I) THE RESOLUTION OF THE BOARD OF DIRECTORS OF ANNA COMMUNITY DEVELOPMENT CORPORATION ("CORPORATION") REGARDING A LOAN IN THE AMOUNT NOT TO EXCEED $1,800,000; M A SALES TAX REMITTANCE AGREEMENT BETWEEN THE CITY AND THE CORPORATION (III) RESOLVING OTHER MATTERS INCIDENT AND RELATED TO THE LOAN; AND (IV) THE AUTHORITY OF THE MAYOR TO EXECUTE, ON BEHALF OF THE CITY, A GENERAL CERTIFICATE OF THE CITY AND THE SALES TAX REMITTANCE AGREEMENT. was introduced and submitted to the City Council for passage and adoption. After presentation and due consideration of the resolution, and upon a motion made and seconded, the resolution was duly passed and adopted by the Council to be effective immediately by the following vote: AYES: All members of the City Council shown present above voted "Aye ", except as noted below, NOES: ABSTAIN: all as shown in the official Minutes of the City Council for the meeting held on the aforesaid date. 2. The attached resolution is a true and correct copy of the original on file in the official records of the City; the duly qualified and acting members of the City Council on the date of the aforesaid meeting are those persons shown above and, according to the records of my office, advance notice of the time, place and purpose of said meeting was given to each member of the Council; and that said meeting, and deliberation of the aforesaid public business, was open to the public and written notice of said meeting, including the subject of the above -entitled resolution, was posted and given in advance thereof in compliance with the provisions of V.T.C.A., Chapter 551, Government Code, as amended. IN WITNESS WHEREOF, I have hereunto signed my name officially on the date fast written above. Carrie Land, City geeretafy RESOLUTION NO. 20 02 3 - (56 - 15 aq A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANNA, TEXAS ("CITY"), APPROVING (I) THE RESOLUTION OF THE BOARD OF DIRECTORS OF ANNA COMMUNITY DEVELOPMENT CORPORATION ("CORPORATION") REGARDING A LOAN IN THE AMOUNT NOT TO EXCEED $1,800,000; (11) A SALES TAX REMITTANCE AGREEMENT BETWEEN THE CITY AND THE CORPORATION (III) RESOLVING OTHER MATTERS INCIDENT AND RELATED TO THE LOAN; AND (IV) THE AUTHORITY OF THE MAYOR TO EXECUTE, ON BEHALF OF THE CITY, A GENERAL CERTIFICATE OF THE CITY AND THE SALES TAX REMITTANCE AGREEMENT. WHEREAS, the Anna Community Development Corporation (the "Corporation') has been duly created and organized pursuant to the provisions of Chapter 505, Local Government Code, as amended (formerly Section 4B of the Development Corporation Act of 1979, Article 5190.6, Texas Revised Civil Statutes Annotated, as amended) (the "Act') by the City of Anna, Texas (the "CV'); and WHEREAS, pursuant to the Act, the Corporation is empowered to borrow money for the purpose of financing the cost of any "project" defined as such by the Act; and WHEREAS, the Board of Directors of the Corporation has found and determined that financing the acquisition of real property in Downtown Anna, Texas to promote new or expanded - business development in the City is authorized under the Act and loan proceeds may be used for such financing pursuant to that certain Loan Agreement (as amended, restated, supplemented and/or otherwise modified, the "Loan Agreement") in the original principal amount not to exceed $1,800,000 (the "Loan') between the Corporation and Government Capital Corporation (the "Lender'); and WHEREAS, the Corporation proposes to enter into a Sales Tax Remittance Agreement, (as amended, restated, supplemented and/or otherwise modified, the "Sales Tax Remittance Agreement") with the City pursuant to which, among other things, the Corporation will pledge its sales tax revenues to the Lender to secure repayment of the Loan; and WHEREAS, the Act requires the City Council of the City approve the resolution of the Corporation providing for the execution and delivery of the Loan Agreement. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ANNA, TEXAS: Section 1. The Resolution approving the Loan Agreement and authorizing the issuance of the Note (as defined in the Loan Agreement) adopted by the Corporation (the "Corporation Resolution') on August 3, 2023, and submitted to the City Council this day, is hereby approved in all respects. The Note is being issued to finance the costs of the Project, which is located within the City. Section 2. The approvals herein given are in accordance with the Act, and the Note shall never be construed as an indebtedness or pledge of the City, or the State of Texas (the "State'), within the meaning of any constitutional or statutory provision, and the owner of the Note shall never be paid in whole or in part out of any funds raised or to be raised by taxation (other than sales tax proceeds as authorized pursuant to Chapter 505 of the Act) or any other revenues of the Corporation, the City, or the State, except those revenues assigned and pledged by the Loan Agreement and the Sales Tax Remittance Agreement. Section 3. The City hereby agrees to promptly collect and remit to the Corporation the Economic Development Sales and Use Tax (defined in the Loan Agreement) to provide for the prompt payment of the Note, and to assist and cooperate with the Corporation in the enforcement and collection of sales and use taxes imposed on behalf of the Corporation. Section 4. The Sales Tax Remittance Agreement with respect to the obligations of the City and Corporation during the time the Note is outstanding, is hereby approved as to form and substance finally determined by the Mayor or City Manager. Furthermore, the Mayor and the City Secretary and the other officers of the City are hereby authorized, jointly and severally, to execute and deliver such endorsements, instruments, certificates, documents, or papers necessary and advisable to carry out the intent and purposes of this Resolution. Section 5. It is officially found, determined, and declared that the meeting at which this Resolution is adopted was open to the public and public notice of the time, place, and subject matter of the public business to be considered at such meeting, including this Resolution, was given, all as required by V.T.C.A. Government Code, Chapter 551, as amended. Section 6. This Resolution shall be in force and effect from and after its passage on the date shown below. [REMArNDER OF THIS PAGE INTENTIONALL Y LEFT BLANK] 16 PASSED AND ADOPTED, this eL;t 2023. CITY OF ANNA, TE Nate Pike, Mayor ATTEST: 1p/I Carrie Land, City Secretary CERTIFICATE FOR RESOLUTION On August 3, 2023, we, the undersigned officers of the Anna Community Development Corporation, hereby certify as follows: 1. The Board of Directors of said Corporation convened in Regular Meeting on August 3, 2023 at the designated meeting place, and the roil was called of the duly constituted officers and members of said Board of Directors, to wit: Bruce Norwood President Jody Bills Vice President Rocio Gonzalez Secretary Kylee Kelley Director Michelle Hawkins Director Ronald Kerr Director Allison Inesta Director and all of said persons were present, except the following absentees:Mvq�0.1(q- H&KIA&thus constituting a quorum. Whereupon, among other business, the followini was transacted at said Meeting: a written RESOLUTION OF THE BOARD OF DIRECTORS OF THE ANNA COMMUNITY DEVELOPMENT CORPORATION REGARDING A LOAN IN AN AMOUNT NOT TO EXCEED $1,800,000 was duly introduced for the consideration of said Board of Directors and read in full. It was then duly moved and seconded that said Resolution be adopted; and, after due discussion, said motion carrying with it the adoption of said Resolution, prevailed and carried by the following vote: AYES: All members of the Board of Directors shown present above voted "Aye" except as shown below. NOES: ABSTAIN: 2. That a true, full and correct copy of the aforesaid Resolution adopted at the Meeting described in the above and foregoing paragraph is attached to and follows this Certificate; that said Resolution has been duly recorded in said Board of Directors' minutes of said Meeting; that the above and foregoing paragraph is a true, full and correct excerpt from said Board of Directors' minutes of said Meeting pertaining to the adoption of said Resolution; that the persons named in the above and foregoing paragraph are the duly chosen, qualified and acting officers and members of said Board of Directors as indicated therein; that each of the officers and members of said Board of Directors was duly and sufficiently notified officially and personally, in advance, of the time, place and purpose of the aforesaid Meeting, and that said Resolution would be introduced and RESOLUTION OF THE BOARD OF DIRECTORS OF THE ANNA COMMUNITY DEVELOPMENT CORPORATION REGARDING A LOAN IN AN AMOUNT NOT TO EXCEED $1,800,000 WHEREAS, ANNA COMMUNITY DEVELOPMENT CORPORATION ( "Borrower ") proposes to enter into a Loan Agreement (as amended, restated, supplemented and/or otherwise modified, the "Loan AX:eement "), with Government Capital Corporation, as lender ( "Lender ") to enable Borrower to acquire one or more tracts of real property (the "Protect") in downtown Anna, Texas (the "CW") to promote new or expanded business development in the City, in an amount not to exceed $1,800,000 and as for the payment of the principal of and interest thereon, the Borrower has agreed to pledge its Economic Development Sales and Use Tax. All capitalized terms used herein, but not otherwise defined herein, shall have the meaning ascribed to such term in the Loan Agreement. WHEREAS, the Board of Directors (the "Board") of the Borrower desires to authorize the President of the Board, and/or the President's designee, to negotiate the final form of the Loan Agreement, Note and the Sales Tax Remittance Agreement consistent with the terms of this Resolution. NOW THEREFORE, BE IT RESOLVED BY THE BOARD OF DIRECTORS OF ANNA COMMUNITY DEVELOPMENT CORPORATION AS FOLLOWS: Section 1. The Board agrees to enter into the Loan Agreement, Note and the Sales Tax Remittance Agreement to finance the costs of the Project in an amount not to exceed $1,800,000 at an interest rate agreed upon by the Lender and the Borrower on the date of execution of the Note, the Loan Agreement and the Sales Tax Remittance Agreement and, in order to secure the principal of and interest on the Note, to pledge its Economic Development Sales and Use Tax. Section 2. That the Board hereby accepts the following financing option as set forth by the Lender in its July 17, 2023 Preliminary Term Sheet [Select One]: 60 quarterly payments w/ an adjustable interest rate 80 quarterly payments w/ an adjustable interest rate 100 quarterly payments w/ an adjustable interest rate and that any one or more Authorized Officers (as defined below) are authorized to negotiate, execute, acknowledge and deliver in the name and on behalf of Borrower to the Lender the final Loan Agreement, including all attachments and exhibits thereto and the Note consistent with the options elected herein. Further, the Authorized Officers are each authorized to execute, acknowledge and deliver in the name and on behalf of the Borrower any other agreement, instrument, certificate, representation and document, and to take any other action as may be advisable, convenient or necessary to enter into such Loan Agreement and the Note; the execution thereof by the Authorized Officers shall be conclusive as to such determination. considered for adoption at said Meeting, and each of said officers and members consented, in advance, to the holding of said Meeting for such propose, and that said Meeting was open to the public and public notice of the time, place and purpose of said Meeting was given, all as required by Chapter 551, Texas Government Code. 3. That the President of the Board of Directors of the Corporation has approved and hereby approves the aforesaid Resolution; that the President and the Secretary of said Corporation have duly signed said Resolution; and that the President and the Corporation Secretary of said Corporation hereby declare that their signing of this Certificate shall constitute the signing of the attached and following copy of said Resolution for all put -poses. Signed on the date first written above. Sec etary, B ar l of ' •ectors President oard oY Directors Section 3. That for the purposes of this resolution, the following persons, or the persons holding the following positions, are "Authorized Officers" duly authorized to enter into the transaction contemplated by this resolution in the name and on behalf of the Borrower: Title Name Board President Bruce Norwood Board Vice -President Jody Bills Board Secretary Rocio Gonzalez Section 4. That this Resolution shall take effect immediately. PASSED AND ADOPTED this ,-3 _ 2023. ANNA COMMUNITY DEVELOPMENT CORPORATION By: �C� Bruce Np ood, Pr ident ATTEST: By:_r/ V I/ "�%1 X Rocco Gonzal , Secret y CLOSING DOCUMENTS INDEX $1,756,350.93 Series 2023 Note GOVERNMENT CAPITAL CORPORATION ("Lender") and ANNA COMMUNITY DEVELOPMENT CORPORATION ("Corporation") Dated as of September 28, 2023 Document No. Document Description 1 Loan Agreement between Lender and Corporation Exhibit A — Form of Note 2 Note executed by Corporation and payable to Lender Schedule I — Payment Schedule 3 Sales Tax Remittance Agreement executed by the Corporation and the City of Anna, Texas (the "City") 4 General Certificate of Corporation 5 Resolution of Corporation 6 General Certificate of the City 7 Resolution of the City 8 Opinion of Counsel 9 Articles of Incorporation of Corporation LOAN AGREEMENT between GOVERNMENT CAPITAL CORPORATION and ANNA COMMUNITY DEVELOPMENT CORPORATION $1,756,350.93 Series 2023 NOTE Dated as of September 28, 2023 4891-2397-2133, v. 1 LOAN AGREEMENT This LOAN AGREEMENT (as amended, restated, supplemented and/or otherwise modified, this "Agreement"), dated as of September 28, 2023, is between GOVENRMENT CAPITAL CORPORATION (the "Lender"), and ANNA COMMUNITY DEVELOPMENT COPORATION (the "Corporation"), a nonprofit economic development corporation duly established and created pursuant to Chapter 505, Local Government Code, as amended (formerly Section 4B of the Development Corporation Act of 1979, Article 5190.6, Texas Revised Civil Statutes Annotated, as amended), (the "Act"), created by or on behalf of the City of Anna, Texas (the WITNESSETH: WHEREAS, the City has established, levied, is maintaining and collecting on behalf of the Corporation the Economic Development Sales and Use Tax pursuant to the Act; WHEREAS, the Corporation has determined that it is in the best interests of the Corporation and the City to acquire real property in Downtown Anna, Texas to promote new or expanded business enterprises in the City (the "Project"); and WHEREAS, Corporation has determined that the Project will promote or develop new or expanded business enterprises in the City that create or retain primary jobs; and WHEREAS, the Corporation has asked the Lender to make a loan to the Corporation (the "Loan") for the purpose of financing the costs of the Project and to pay the costs associated with the issuance of the Loan, as authorized by the Act, such Loan to be secured by and payable from the proceeds of the Economic Development Sales and Use Tax; and; WHEREAS, the Lender is willing to make such Loan to the Corporation, on the terms and conditions hereinafter set forth; NOW, THEREFORE, in consideration of the premises and other good and valuable consideration and the mutual benefits, covenants and agreements herein expressed, the Lender and the Corporation agree as follows: ARTICLE I DEFINITIONS AND RULES OF CONSTRUCTION Section 1.1 Definitions. The capitalized terms used in this Agreement shall have the following respective meanings unless the context otherwise requires: Act - has the meaning ascribed to such term in the first paragraph hereof. Additional Parily Debt - means: Additional debt or other obligations to be issued or incurred by the Corporation including, without limitation, the issuance or incurrence of any bonds, notes, or other obligations payable from and secured in whole or in part by liens on the Pledged Revenues that are in parity with the lien on the Pledged Revenues securing the payment of the Notes. Additional Subordinate Debt - means: Additional debt or other obligations to be issued or incurred by the Corporation including, without limitation, the issuance or incurrence of any bonds, notes, or other obligations payable from and secured in whole or in part by liens on the Pledged Revenues that are junior or subordinate to the lien on the Pledged Revenues securing the payment of the Notes. Additional Subordinate Debt Resolution — means any resolution of the Board of Directors of the Corporation authorizing and providing the terms and provisions of the Additional Parity Debt. Agreement - has the meaning ascribed to such term in the first paragraph hereof. Bond Counsel - Naman Howell Smith & Lee, PLLC. Business Day - Any day, other than a Saturday, Sunday, or legal holiday, on which the offices of the Lender are not required or authorized by law or executive order to be closed. City - has the meaning ascribed to such term in the first paragraph hereof. Closing Date - The date that the Notes are delivered to the Lender. Code - The Internal Revenue Code of 1986, as amended, and all applicable regulations and any official rulings and determinations under the above. Corporation - has the meaning ascribed to such term in the first paragraph hereof. Costs of Issuance - The costs and expenses incurred by the Corporation with respect to the authorization, execution and delivery of the Loan Documents and all documentation related thereto. Debt Service Fund - shall have the meaning ascribed to such term in Section 4.4 hereof. Debt Service Requirement - The amount necessary to pay the principal of and interest due and owing on the Notes during each respective fiscal year of the Corporation. Economic Development Sales and Use Tax - The %2% sales and use tax authorized to be levied by the City on behalf of the Corporation for the promotion of economic development pursuant to the Act and elections duly held. Event of Default - Unless waived in writing by the Lender, the occurrence of any of the following: (a) the failure of the Corporation to make any of the Note Payments when due; (b) the failure of the Corporation to comply with any other covenant, condition, or agreement under this Agreement, and the continuation of such failure for a period of thirty (30) days after the date that the Corporation acquired actual knowledge or written notice of such failure, which knowledge may take the form of notice specifying such failure given to the Corporation by the Lender; 2 (c) bankruptcy, insolvency, appointment of a receiver for, or the failure to discharge a judgment against, the Corporation; (d) the violation of any representation or warranty made by the Corporation under Section 5.2 hereof; or (e) the failure of the Corporation to perform any of its obligations under or comply with any provisions of this Agreement not described in (a) or (b) above or any other agreement with the Lender to which it may be a party or by which it is bound. Existing Parity Debt — Any debt of the Corporation secured by a first lien pledge of the Pledged Revenues. Interest Payment Date - The date interest payments are due on the Loan, as set forth in the Note. Lender — Government Capital Corporation, together with its successors and assigns. Loan - The loan from the Lender to the Corporation made pursuant to this Agreement. Loan Documents - Collectively, this Agreement, the Notes, the Sales Tax Remittance Agreement, and the Resolution. Maximum Interest Rate - The maximum rate of interest allowed under Chapter 1204, Government Code, as amended, but not to exceed the "applicable interest rate ceiling" as determined under Chapter 303 of the Texas Finance Code from time to time in effect. Note — The Series 2023 Note. Note Patents - The payments required by Section 2.3 to be made by the Corporation in payment of the principal of and interest on the Note. Parity Obligations - Means collectively, the Existing Parity Obligations, the Note and any Additional Parity Debt. Pledged Revenues - 100% of the funds collected by the City from the levy of the Economic Development Sales and Use Tax, without deduction, offset or credit for any administrative charges or expenses incurred by the City or the Corporation in connection with the levy and collection of the Economic Development Sales and Use Tax, other than any amounts due and owing to the Comptroller of Public Accounts of the State for collection costs and other charges. Resolution - The resolution of the Board of Directors of the Corporation authorizing the execution and delivery of this Agreement and the Note and the pledge of the Pledged Revenues to the payment of the principal of and interest on the Note, and any amendments or supplements thereto. Revenue Fund - Shall have the meaning ascribed to such term in Section 4.4 hereof. 3 Sales Tax Remittance Agreement - The Sales Tax Remittance Agreement dated as of even date herewith by and between the Corporation and the City, as same may be amended, restated, supplemented and/or otherwise modified. Series 2023 Note - The tax-exempt promissory note of even date herewith (such promissory note, as the same may be renewed, extended, amended or otherwise modified from time to time) delivered pursuant to this Agreement in substantially the form attached hereto as Exhibit A, and any promissory note executed and delivered by the Corporation in replacement thereof or in substitution therefor. Note Principal - $1,756,350.93 State - The State of Texas. Surplus Fund - Shall have the meaning ascribed to such term in Section 4.4 hereof. Section 1.2 Interpretative Matters. Whenever the context requires: (i) References in this Agreement of the singular number shall include the plural and vice versa; and (ii) Words denoting gender shall be construed to include the masculine, feminine, and neuter. (b) The table of contents and the titles given to any article or section of this Agreement are for convenience of reference only and are not intended to modify the meaning of the article or section. ARTICLE II THE LOAN; REPAYMENT OF THE LOAN Section 2.1 Financing the Loan Subject to the terms and conditions set forth in this Agreement, including without limitation the conditions set forth in Section 2.2, and for and in consideration of the payment by the Corporation of its obligations under this Agreement and the Note and the covenants and agreements herein contained, the Lender will advance to and for the sole use and benefit of the Corporation for the exclusive purpose of providing funds to pay the costs of acquiring the Project and paying the costs related thereto including, without limitation, the Costs of Issuance. Section 2.2 Conditions to Closing. The obligation of the Lender to make the advances pursuant to Section 2.1 hereof shall be subject to the following conditions: (a) The representations of the Corporation herein shall be true, complete and correct in all material respects on the date hereof and on and as of the Closing Date as if made on the Closing Date; (b) On the Closing Date, the Loan Documents shall be in full force and effect, assuming due authorization and execution by the other parties thereto, and shall not have been amended or supplemented except as may have been agreed to in writing by the Lender; E (c) At or prior to the Closing Date, the Lender shall have received each of the following documents: (i) This Agreement executed by an authorized officer of the Corporation; (ii) The Note executed by an authorized officer of the Corporation; (iii) A certificate, dated the Closing Date, executed by an authorized officer of the Corporation, to the effect that (A) the representations and warranties of the Corporation contained in this Agreement are true and correct on the date hereof and on and as of the Closing Date as if made on the Closing Date; (B) the Resolution and this Agreement are in full force and effect and have not been amended or supplemented except as may have been approved in writing by the Lender; (C) the Corporation is not in default with respect to any of its outstanding obligations; and (D) no litigation is pending or, to the best of their knowledge, threatened in any court to restrain or enjoin the execution and delivery of this Agreement or the Note, or the levy and collection of the Economic Development Sales and Use Tax or the pledge thereof, or contesting or affecting the adoption and validity of the Resolution or the authorization, execution and delivery of the Loan Documents, or contesting the powers of the Board of Directors of the Corporation; (iv) Certified copies of resolutions of the City and the Corporation authorizing execution, delivery and performance of all of the Loan Documents and authorizing the borrowing hereunder, along with such certificates of existence, certificates of good standing and other certificates or documents as the Lender may reasonably require to evidence the Corporation's authority; (v) True copies of all organizational documents of the Corporation, including all amendments, restatements or supplements thereto; (vi) An opinion of counsel to the Corporation which shall specifically provide that (1) the Corporation is a validly existing non-profit corporation created by the City of Anna, Texas pursuant to Chapter 505 of the Act and (2) the Corporation is duly authorized and empowered to execute, deliver and perform the Loan Documents. Section 2.3 Repayment Terms. The Corporation agrees to execute and deliver the Note to the Lender on the Closing Date (b) The Note shall be dated the Closing Date, shall be in an aggregate principal amount equal to the Note Principal Amount and shall be payable in installments on the dates and in the amounts specified in the Note. (c) Interest shall accrue and be paid on the outstanding Note Principal Amount as specified in the Note. Section 2.4 Note Payments. All Note Payments shall be made on the applicable payment date in immediately available funds and shall be paid to the Lender at the address provided to the Corporation pursuant to Section 8.2. 5 Section 2.5 Note Payments Due on Business Days. If the regularly scheduled due date for a Note Payment is not a Business Day, the due date for such payment shall be the next succeeding Business Day, and payment made on such succeeding Business Day shall have the same force and effect as if made on the regularly scheduled due date. Section 2.6 Prepayment of Note. The Corporation may at its option prepay the principal amount of the Note outstanding hereunder, in whole but not in part, on October 28, 2028 or on any payment date on or after October 28, 2033. The prepayment price shall be an amount equal to the Early Redemption Value for the date determined for prepayment as set forth on Schedule I of the Note. Section 2.7 Limited Obligation. The obligations of the Corporation hereunder are special limited obligations thereof and neither the Notes nor any instrument related to this Agreement may give a holder a right to demand payment from any source other than the Economic Development Sales and Use Tax imposed by Chapter 505 of the Act and pledged hereunder. Section 2.8 Segregation of Economic Development Sales and Use Tax. The Corporation shall or shall cause the City to maintain a separate fund into which shall be deposited the Economic Development Sales and Use Tax and the Corporation shall or shall cause the City to segregate such taxes collected from the general fund of the City. ARTICLE III ADDITIONAL DEBT Section 3.1 Additional Parity Debt. The Corporation shall have the right and power at any time and from time to time and in one or more series or issues, to authorize, issue and deliver Additional Parity Debt, in accordance with law, in any amounts, for any lawful purpose including the refunding of any Parity Obligations, Subordinate Debt or other obligations of the Corporation. Such Additional Parity Debt, if and when authorized, issued and delivered in accordance with this Agreement, shall be secured by and made payable equally and ratably on a parity with the Note and all other Existing Parity Obligations, from the line on and pledge of the Pledged Revenues herein granted, provided: (a) The Treasurer of the Corporation (or other officer of the Corporation then having the primary responsibility for the financial affairs of the Corporation) shall have executed a certificate stating that, to the best of his or her knowledge and belief, the Corporation is not then in default as to any covenant, obligation or agreement contained in this Agreement, any resolution authorizing any Existing Parity Obligation or any Additional Parity Debt Resolution; (b) The Corporation has secured from a certified public accountant a certificate or opinion to the effect that, according to the books and records of the Corporation, the Pledged Revenues received by the Corporation for either (i) the last completed fiscal year next preceding the adoption of the Additional Parity Debt Resolution or (ii) any twelve (12) consecutive months out of the previous eighteen (18) months next preceding the adoption of the Additional Parity Debt Resolution equal to not less than 1.25 times the average annual debt service requirements for all Parity Obligations then outstanding after giving effect to the issuance of the Additional Parity Debt then being considered; M (c) For the purposes of the Certificate required in Section 3.1(a) above, the full amount of each payment must be included as debt service in the year payable (without giving effect to any assumed amortization). Section 3.2 Subordinate Debt. The Corporation hereby reserves the right to issue or create Additional Subordinate Debt payable from or secured by a lien on all or any part of the Pledged Revenues for any lawful purpose, provided the pledge and the lien securing such debt is subordinate to the pledge and lien established, made and created in Section 4.3 of this Agreement with respect to the Pledged Revenues to the payment and security of the Parity Obligations. ARTICLE IV SPECIAL AGREEMENTS Section 4.1 Obligations of Corporation Unconditional. The obligation of the Corporation to make the payments required by Section 2.3 shall be absolute and unconditional. The Corporation shall pay all such amounts without abatement, diminution or deduction (whether for taxes or otherwise) regardless of any cause or circumstances whatsoever including, without limitation, any defense, set-off, recoupment or counterclaim that the Corporation may have or assert against the Lender or any other person. (b) Until such time as the Note is fully paid the Corporation: (i) will not suspend or discontinue, or permit the suspension or discontinuance of, any Note Payment; (ii) will perform and observe all of its other agreements contained in this Agreement; and (iii) will not terminate this Agreement for any cause except by, full payment and retirement of the Note. Section 4.2 Agreement as Security Agreement. An executed copy of this Agreement shall constitute a security agreement pursuant to applicable law, with the Lender as the secured party. The lien, pledge, and security interest of the Lender created in this Agreement shall become effective immediately upon the Closing Date, and the same shall be continuously effective for so long as the Note is outstanding. (b) A fully executed copy of this Agreement and the proceedings authorizing it shall be filed as a security agreement among the permanent records of the Corporation. Such records shall be open for inspection to any member of the general public and to any person proposing to do or doing business with, or asserting claims against, the Corporation, at all times during regular business hours. (c) The provisions of this section are prescribed pursuant to the Bond Procedures Act of 1981 (Chapter 1204, Government Code), as amended, and other applicable laws of the State. If any other applicable law, in the opinion of counsel to the Corporation or in the opinion, reasonably exercised, of counsel to the Lender, requires any filing or other action additional to the filing pursuant to this section in order to preserve the priority of the lien, pledge, and security 7 interest of the Lender created by this Agreement, the Corporation shall diligently make such filing or take such other action to the extent required by law to accomplish such result. Section 4.3 Pledge and Source of Payment. The Corporation hereby covenants that all Pledged Revenues shall be deposited and paid into the Special Funds established in Section 4.4 hereof, and shall be applied in the manner set out herein, to provide for the payment of principal and interest on the Note, the Existing Parity Obligations and, to the extent permitted, any Additional Parity Debt and all expenses of paying the same. The obligations of the Corporation under the Notes, the Existing Parity Obligations and any Additional Parity Debt shall be special limited obligations of the Corporation payable solely from, and secured by a first lien on, the Pledged Revenues, and collected and received by the Corporation, which Pledged Revenues shall, in the manner herein provided, be set aside and pledged to the payment of the Notes and any Parity Obligations in the Debt Service Fund, and any excess Economic Development Sales and Use Tax revenues shall be set aside in the Surplus Fund; as hereinafter provided. The Lender shall never have the right to demand payment out of any funds raised or to be raised by ad valorem taxation. The Lender shall never have the right to demand payment from sales tax revenues in excess of those collected from the Economic Development Sales and Use Tax. Section 4.4 Special Funds. The following special funds are hereby created, and such funds shall be maintained and accounted for as hereinafter provided, so long as the Notes and any Additional Debt remain outstanding: (a) Economic Development Sales and Use Revenue Fund (the "Revenue Fund"); (b) Economic Development Sales and Use Note Debt Service Fund (the "Debt Service Fund"); and (c) Economic Development Sales and Use Fund (the "Surplus Fund"). The Revenue Fund, the Debt Service Fund and the Surplus Fund shall be maintained and accounted for as separate accounts on the books of the Corporation. All of the funds named above shall be used solely as provided herein so long as the Notes and any Parity Obligations remain outstanding. Notwithstanding the foregoing and the provisions of Sections 4.5, 4.6 and 4.7 hereof, the Corporation may utilize existing accounts and maintain appropriate internal records regarding the Revenue Fund, the Debt Service Fund and the Surplus Fund. Section 4.5 Flow of Funds. All Pledged Revenues shall be deposited as collected into the Revenue Fund. Money from time to time on deposit to the credit of the Revenue Fund shall be applied as follows in the following order and priority: (a) First, to make all deposits into the Debt Service Fund required by this Agreement to pay principal of and interest on the Notes and any Parity Obligations; (b) Second, to make the transfers required by any condition authorizing the issuance or incurrence of subordinate lien obligations (subject to the prior requirements of any resolution authorizing the issuance of any Additional Parity Debt); and (c) Third, to make all deposits into the Surplus Fund as required by this Agreement, said funds to be used by the Corporation for any lawful purpose. Whenever the total amounts on deposit to the credit of the Debt Service Fund shall be equal to the amount set forth in Section 4.6 hereof, no further payments need be made into the Debt Service Fund. Section 4.6 Debt Service Fund. While any Parity Obligations remain outstanding, there shall be deposited into the Debt Service Fund from the Revenue Fund an amount equal to one hundred per cent (100%) of the interest on and the principal of the Parity Obligations then falling due and payable prior to each principal and interest payment date. If in any month the Corporation shall fail to make the full transfer to the Debt Service Fund required by this Agreement, amount equivalent to such deficiency shall be transferred to the Debt Service Fund from the first available and unallocated money in the Revenue Fund in the following month or months, and such transfers shall be in addition to the other amounts required to be transferred to the Debt Service Fund. Money deposited to the credit of the Debt Service Fund required by this Agreement shall be used solely for the purpose of paying principal and interest on the Parity Obligations plus any costs related thereto. Section 4.7 Surplus Fund. After making any transfers required into the Debt Service Fund or any other funds created in any resolution authorizing the issuance of any Additional Debt or any subordinate lien obligations, any money remaining in the Revenue Fund shall be considered surplus, and may be deposited into the Surplus Fund and, notwithstanding the pledge of the Pledged Revenues hereunder, may be used by the Corporation for any lawful purpose so long as there is no Event of Default hereunder. Section 4.8 Investment of Funds; Transfer of Investment Income. Money in the Revenue Fund and the Debt Service Fund may, at the option of the Corporation, be invested in time deposits or certificates of deposit of commercial banks secured in the manner required by law for public funds and insured by the Federal Deposit Insurance Corporation to the maximum extent permitted by law, or be invested in direct obligations of, or obligations fully guaranteed by, the United States of America, or in any other investments authorized by the laws of the State; provided that all such deposits or investments shall be made in such manner that the money required to be expended from any fund will be available at the proper time or times. Any obligation in which money is so invested shall be kept and held in the official depository bank of the Corporation at which the fund is maintained from which the investment was made. All such investments shall be promptly sold when necessary to prevent any default in connection with the Note or any Additional Debt. All interest and income derived from such deposits and investments shall be transferred or credited as received to the Revenue Fund, and shall constitute Pledged Revenues. Section 4.9 Security for Uninvested Funds. All uninvested money on deposit in, or credited to, the Revenue Fund and the Debt Service Fund shall be secured by the pledge of security as provided by the laws of the State. Section 4.10 Financial Statements and Reports. For so long as any amounts remain outstanding under the Notes, the Corporation will promptly furnish to the Lender from time to time upon request such information regarding the business and affairs and financial condition of the Corporation as the Lender may reasonably request, and furnish to the Lender promptly after E available and in any event within one hundred eighty (180) days of each fiscal year end, current audited financial statements, on a consolidated basis, of the Corporation, or if not separately prepared, then of the City, including (i) a balance sheet, (ii) statement of revenues, expenses and changes in fund balances, (iii) statements of cash flow, (iv) operating fund budget analysis, and (iv) appropriate notes and attachments to the financial statements. Section 4.11 Inspection Rights. At any reasonable time and from time to time, the Corporation will permit representatives of the Lender to examine, copy, and make extracts from its books and records, to visit and inspect its properties, and to discuss its business, operations, and financial condition with its officers, employees, and independent certified public accountants. Section 4.12 Keeping Books and Records. The Corporation will maintain proper books of record and account in which full, true, and correct entries in conformity with generally accepted accounting principles shall be made of all dealings and transactions in relation to its business and activities. ARTICLE V REPRESENTATIONS AND WARRANTIES Section 5.1 Representations and Warranties of Lender. The Lender represents and warrants to the Corporation the following: (a) The Lender has all necessary power and authority to enter into and perform this Agreement. (b) The Lender has taken all actions required to authorize and execute this Agreement and to perform its obligations hereunder and the execution, delivery and performance by the Lender of and compliance with the provisions of this Agreement will not conflict with any existing law, regulation, rule, decree or order or any agreement or other instrument by which the Lender is bound. Section 5.2 Representations by the Corporation. The Corporation represents, warrants and covenants to the Lender as follows: (a) The Corporation is a nonprofit economic development corporation, within the meaning of Chapter 505 (formerly Section 4B) of the Act, has all of the rights, powers, privileges, authority and functions given by the general laws of the State to nonprofit corporations incorporated under the Texas Non -Profit Corporation Act, as amended, except as otherwise provided in Section 501.054(a) of the Act (formerly Section 23(a) of the Act), and is authorized by the Act to execute and to enter into this Agreement and to undertake the transactions contemplated herein and to carry out its obligations hereunder. (b) The Corporation is duly organized, validly existing, and in good standing under the laws of the State. The Corporation has all requisite power, authority and legal right to execute and deliver the Loan Documents and all other instruments and documents to be executed and delivered by the Corporation pursuant thereto, to perform and observe the provisions thereof and to carry out the transactions contemplated by the Loan Documents. All corporate action on the part of the Corporation which is required for the execution, delivery, performance and 10 observance by the Corporation of the Loan Documents has been duly authorized and effectively taken, and such execution, delivery, performance and observation by the Corporation do not contravene applicable law or any contractual restriction binding on or affecting the Corporation. (c) The Corporation has duly approved the borrowing of funds from the Lender and has received the approval of the City therefor; no other authorization or approval or other action by, and no notice to or filing with any governmental authority or regulatory body is required as a condition to the performance by the Corporation of its obligations under any of the Loan Documents. (d) This Agreement and the Note are legally valid and binding obligations of the Corporation enforceable against the Corporation in accordance with their respective terms. (e) There is no default of the Corporation in the payment of the principal of or interest on any of its indebtedness for borrowed money or under any instrument or instruments or agreements under and subject to which any indebtedness for borrowed money has been incurred which does or could affect the validity and enforceability of the Loan Documents or the ability of the Corporation to perform its obligations thereunder, and no event has occurred and is continuing under the provisions of any such instrument or agreement which constitutes or, with the lapse of time or the giving of notice, or both, would constitute such a default. (f) There is no pending or, to the knowledge of the undersigned officers of the Corporation, threatened action or proceeding before any court, governmental agency or department or arbitrator (i) to restrain or enjoin the execution or delivery of this Agreement and the Note or the collection of any Pledged Revenues to pay the Notes, (ii) in any way contesting or affecting the authority for the execution and delivery or the validity of the Loan Documents, or (iii) in any way contesting the levy of the Economic Development Sales and Use Tax or the existence of the Corporation or the title or powers of the officers of the Corporation. (g) In connection with the authorization, execution and delivery of this Agreement and the Notes, the Corporation has complied with all provisions of the laws of the State, including the Act. (h) The execution and delivery of the documents contemplated hereunder do not violate any provision of any instrument or agreement to which the Corporation is a party or by which it is bound. (i) The Corporation has, by proper corporate action, duly authorized the execution and delivery of this Agreement. 0) The Corporation is not in default under or in violation of the Constitution or any of the laws of the State relevant to the issuance of the Note or the consummation of the transactions contemplated hereby or in connection with such issuance, and has duly authorized the issuance of the Note and the execution and delivery of this Agreement. The Corporation agrees that it will do or cause to be done in a timely manner all things necessary to preserve and keep in full force and effect its existence, and to carry out the terms of this Agreement and the Indenture. 11 (k) The Corporation's books and records properly reflect the financial condition of the Corporation and, to the best of the Corporation's knowledge, there has been no material adverse change in the business, condition (financial or otherwise), operations, prospects or properties of the Corporation since the effective date of the Corporation's most recent financial statements. Section 5.3 Permits or Licenses. In the event that it may be necessary for the proper performance of this Agreement on the part of the Corporation that any application or applications for any permit or license to do or to perform certain things be made to any governmental or other agency by the District, the Corporation shall execute such application or applications and shall otherwise comply with regulatory requirements, as applicable. ARTICLE VI REMEDIES SECTION Section 6.1 Remedies Available. So long as any Event of Default has occurred and is continuing, the Lender may take any action at law or in equity to collect all amounts then due under this Agreement and the enforcing of compliance with any other obligation of the Corporation under this Agreement. (b) In addition to the remedies provided in subsection (a) of this Section, the Lender shall, to the extent permitted by law, be entitled to recover the costs and expenses, including attorney's fees and court costs, incurred by the Lender in the proceedings authorized under subsection (a) of this Section. (c) Notwithstanding any other provision of this Agreement, the acceleration of the Note Payments is not available as a remedy under this Agreement. Section 6.2 Non -Exclusive Remedies. No remedy conferred upon or reserved to the Lender by this Agreement is intended to be exclusive of any other available remedy, and each such remedy shall be in addition to any other remedy given under this Agreement or the other Loan Documents or now or hereafter existing at law or in equity. Section 6.3 Delays. No delay or omission to exercise any right or power accruing upon any Event of Default shall impair any such right or power or be construed to be a waiver thereof, and all such rights and powers may be exercised as often as may be deemed expedient. Section 6.4 Limitation on Waivers. If an Event of Default is waived, such waiver shall be limited to the particular Event of Default so waived and shall not be deemed a waiver of any other Event of Default; provided, that no waiver of an Event of Default shall be effective unless such waiver is made in writing. 12 ARTICLE VII DISCHARGE BY PAYMENT When the Note has been paid in full or when the Corporation has made payment to the Lender of the whole amount due or to become due under the Notes (including all interest that has accrued thereon or that may accrue to the date of maturity or prepayment, as applicable), and all other amounts payable by the Corporation under this Agreement have been paid, the liens of this Agreement shall be discharged and released, and the Lender, upon receipt of a written request by the Corporation and the payment by the Corporation of the reasonable expenses with respect thereto, shall discharge and release the lien of this Agreement and execute and deliver to the Corporation such releases or other instruments as shall be requisite to release the lien hereof. ARTICLE VIII MISCELLANEOUS Section 8.1 Term of Agreement. This Agreement shall become effective upon the Closing Date and shall continue in full force and effect until all obligations of the Corporation under this Agreement and the Note have been fully paid. Section 8.2 Notices. (a) All notices, certificates, or other communications required by or made pursuant to this Note Agreement shall be in writing and given by certified or registered United States Mail, return receipt requested, addressed as follows: (i) if to the Lender: Government Capital Corporation 345 Miron Drive Southlake, Texas 76092 Attn: Document Department if to the Corporation: Anna Community Development Corporation 120 W. 71h Street Anna, Texas 75409 Attention: Economic Development Director (b) The Corporation and the Lender may designate any further or different addresses to which subsequent notices shall be sent; provided, that, any of such parties shall designate only one address for such party to receive such notices. (c) Except as otherwise provided by this Agreement, any communication delivered by mail in compliance with this section is deemed to have been given as of the date of deposit in the mail. (d) A provision of this Agreement that provides for a specific method of giving notice or otherwise conflicts with this section supersedes this section to the extent of the conflict. 13 Section 8.3 Binding Effect, Assignment. (a) This Agreement shall (i) be binding upon the Corporation, its successors and assigns, and (ii) inure to the benefit of and be enforceable by the Lender and its successors, transferees and assigns; provided that the Corporation may not assign all or any part of this Agreement without the prior written consent of the Lender. The Lender may assign, transfer or grant participations in all or any portion of this Agreement, the Notes, or any of its rights or security hereunder, including without limitation, the instruments securing the Corporation's obligations under this Agreement; provided that any such assignment, transfer or grant shall be made only to a financial institution whose primary business is the lending of money. Section 8.4 Expenses, Fees, Etc. The Corporation hereby agrees to pay on demand all reasonable costs and expenses of the Lender in connection with the preparation, negotiation, execution, and delivery of the Loan Documents and any and all amendments, modifications, renewals, extensions, and supplements thereof and thereto, including, without limitation, the fees and expenses of legal counsel for the Lender and other professionals. Section 8.5 Severability. If any part of this Agreement is ruled invalid or unenforceable by a court of competent jurisdiction, the invalidity or unenforceability thereof shall not affect the remainder of this Agreement. Section 8.6 Counterparts. This Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same document. Section 8.7 Applicable Law. This Agreement shall be governed in, all respects, whether as to validity, construction, performance, or otherwise, by the laws of the State and, if applicable, federal law. Section 8.8 Jurisdiction. All actions or proceedings with respect to, and the performance of, the Notes and this Agreement shall be, or shall be instituted in the courts of the State of Texas, in Collin County, Texas, and by execution and delivery of this Agreement, the Corporation and the Lender irrevocably and unconditionally submit to the jurisdiction of such courts and unconditionally waive (i) any objection each may now or hereafter have to the laying of venue in any such courts, and (ii) any claim that any action or proceeding brought in any such courts has been brought in an inconvenient forum. Section 8.9 Notice of Final Agreement. THIS WRITTEN AGREEMENT AND ANY OTHER DOCUMENTS EXECUTED IN CONNECTION HEREWITH REPRESENT THE FINAL AGREEMENT BETWEEN THE PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN AGREEMENTS BETWEEN THE PARTIES. 14 IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed and attested by their respective duly authorized officers as of the date first above written. GOI By: Nam Title 15 ANNA COMMUNITY DEVELOPMENT CORPORATION 1 16 EXHIBIT A $197569350.93 September 28, 2023 This Note may not be negotiated in the name of bearer and is not a registered obligation ANNA COMMUNITY DEVELOPMENT CORPORATION NOTE, SERIES 2023 ANNA COMMUNITY DEVELOPMENT CORPORATION (the "Corporation") for value received, hereby promises to pay to the order of GOVERNMENT CAPITAL CORPORATION, its successor or assigns, at its offices located at 345 Miron Drive, Southlake, Texas 76092 the principal sum of ONE MILLION SEVEN HUNDRED FIFTY-SIX THOUSAND THREE HUNDRED FIFTY AND 93/100 DOLLARS ($1,756,350.93). All capitalized terms which are used but not defined in this Note shall have the same meanings as in the Loan Agreement dated as of even date herewith, between the Corporation and the Lender (such Loan Agreement, together with all amendments, restatements, supplements and/or other modifications thereto, being the "Loan Agreement"). Subject to Section 2.3 of the Loan Agreement, beginning on January 28, 2024 and on each April 28, July 28, October 28 and January 28 thereafter until the Maturity Date, the Corporation agrees to pay principal and accrued interest on all amounts hereof so advanced and remaining from time to time unpaid hereon in such amounts as reflected on Schedule I attached hereto. All unpaid principal and accrued interest shall be finally due and payable on or before October 28, 2038 (the "Maturity Date"). Interest shall accrue at a per annum rate of 6.526%; provided, however, the interest rate under this Note may be adjusted by Lender, or its assigns, on the date of the twentieth (20th) and fortieth (401h) payments, being October 28, 2028 and October 28, 2033, respectively, (each an "Adjustment Date"). Notice of any rate adjustment shall be given in writing to the Borrower on or before the 30th day prior to such rate adjustment (the "Determination Date"). The interest rate shall be adjusted to the five (5) year treasury rate on the Determination Date, plus 215 basis points. "Treasury Rate" shall mean, as of the Determination Date, the ask yield of the United States Treasury obligations (as compiled by and published in the most recently published issue of the Wall Street Journal). Upon any rate adjustment, the future installments of principal and interest payable under this Note shall be adjusted. Any such adjustment shall be set forth in a new amortization schedule which the Lender, or its assignee, shall prepare using the same format as used to produce the original amortization schedule. Once the amortization schedule is prepared, the Lender, or its assignee, shall attach it to this Note and shall deliver a copy of same to the Borrower. All payments of interest shall be computed quarterly based upon al 360 day year. Past due principal and interest shall bear interest at a rate per annum which is fifteen percent (15.0%), but in no event to exceed the Maximum Interest Rate. Principal of and interest on this Note shall be payable from and secured by a pledge of the Corporation's Economic Development Sales and Use Tax. 4891-2397-2133, v. 1 This Note is authorized under that certain Loan Agreement and is subject to, and is executed in accordance with, all of the terms, conditions and provisions thereof. A fully executed copy of the Loan Agreement is on file in the permanent records of the Corporation and is open for inspection to any member of the general public and to any person proposing to do business with, or asserting claims against, the Corporation, at all times during regular business hours. The principal of and interest on this Note are payable from the Economic Development Sales and Use Tax imposed by Chapter 505 of the Local Government Code (formerly Section 4B of the Development Corporation Act of 1979, Article 5190.6, Texas Revised Civil Statutes Annotated, as amended), as described in and subject to the limitations contained in the Loan Agreement. Except as otherwise provided in the Loan Agreement, the Corporation waives all demands for payment, presentations for payment, protests, notices of protests, and all other demands and notices, to the extent permitted by law. All agreements between the Corporation and holder hereof, whether now existing or hereafter arising and whether written or oral, are hereby limited so that in no contingency, whether by reason of demand, prepayment, or otherwise, shall the interest contracted for, charged, received, paid or agreed to be paid to the holder hereof, exceed the maximum permissible by applicable law. If, from any circumstances whatsoever, interest would otherwise be payable to the holder hereof in excess of the Maximum Interest Rate, then the interest payable to the holder hereof shall be reduced to the maximum amount permitted under applicable law; and if from any circumstances the holder hereof shall ever receive anything of value deemed interest by applicable law in excess of the Maximum Interest Rate, an amount equal to any excessive interest shall be applied to the reduction of the principal hereof and not to the payment of interest, or if such excessive interest exceeds the unpaid balance of principal hereof, such excess shall be refunded to the Corporation. All interest paid or agreed to be paid to the holder hereof shall, to the extent permitted by applicable law, be amortized, prorated, allocated and spread throughout the full period of the subject loan until payment in full of the principal so that the interest hereon for such full period shall not exceed the maximum amount permitted by applicable law. This paragraph shall control all agreements between the Corporation and the holder hereof. THIS NOTE AND THE LOAN AGREEMENT REPRESENT THE FINAL AGREEMENT BETWEEN THE PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES. NEITHER THE STATE OF TEXAS, THE CITY OF ANNA, TEXAS (THE "CITY % NOR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF SHALL BE OBLIGATED TO PAY THE PRINCIPAL OF OR INTEREST ON THIS NOTE, EXCEPT TO THE EXTENT THAT THE CORPORATION IS OBLIGATED TO MAKE THE PAYMENT OF THE PRINCIPAL OF AND INTEREST ON THIS NOTE. NEITHER THE FULL FAITH AND CREDIT NOR THE TAXING POWER OF THE STATE OF TEXAS, THE CITY, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF IS PLEDGED TO THE PAYMENT OF 4891-2397-2133, v. 1 THE PRINCIPAL OF OR INTEREST ON THIS NOTE, EXCEPT TO THE EXTENT THE CORPORATION HAS PLEDGED THE ECONOMIC DEVELOPMENT SALES AND USE TAX DESCRIBED ABOVE TO MAKE THE NOTE PAYMENTS. The Corporation may at its option prepay the principal amount of the Note outstanding hereunder, in whole but not in part, on October 28, 2028 or on any payment date on or after October 28, 2033. The prepayment price shall be an amount equal to the Early Redemption Value for the date determined for prepayment as set forth on Schedule I. If a date for the payment of the principal of or interest on the Note is a Saturday, Sunday, legal holiday, or a day on which the Lender is authorized by law or executive order to close, then the date for such payment shall be the next succeeding day which is not a Saturday, Sunday, legal holiday, or day on which such banking institution is authorized to close; and payment on such date shall have the same force and effect as if made on the original date payment was due. This Note shall be governed in all respects by the laws of the State of Texas and of the United States of America. IN WITNESS WHEREOF, this Note has been duly executed effective as of the date first written above. ANNA COMMUNITY DEVELOPMENT CORPORATION By: 2 Nam�,gar/c� ,t/ofZuio� Title: C.t� .t�JA.w'D PQGSidC✓1%T 4891-2397-2133, v. 1 Schedule I — Payment Schedule EARLY REDEMPTION PMT PMT DATE TOTAL INTEREST PRINCIPAL VALUE NO. MO. DAY YR PAYMENT PAID PAID after pmt on this line 1 1/28/2024 $46,371.94 $38,362.32 $8,009.62 N/A 2 4/28/2024 $46,371.94 $28,524.19 $17,847.75 N/A 3 7/28/2024 $46,371.94 $28,233.00 $18,138.94 N/A 4 10/28/2024 $46,371.94 $27,937.07 $18,434.87 N/A 5 1/28/2025 $46,371.94 $27,636.30 $18,735.64 N/A 6 4/28/2025 $46,371.94 $27,330.63 $19,041.31 N/A 7 7/28/2025 $46,371.94 $27,019.97 $19,351.97 N/A 8 10/28/2025 $46,371.94 $26,704.24 $19,667.70 N/A 9 1 /28/2026 $46,371.94 $26, 383. 36 $19, 988. 58 N/A 10 4/28/2026 $46,371.94 $26, 057.25 $20, 314.69 N/A 11 7/28/2026 $46,371.94 $25,725.82 $20,646.12 N/A 12 10/28/2026 $46,371.94 $25,388.97 $20,982.97 N/A 13 1 /28/2027 $46,371.94 $25, 046.64 $21, 325.30 N/A 14 4/28/2027 $46,371.94 $24,698.72 $21,673.22 N/A 15 7/28/2027 $46,371.94 $24, 345.12 $22,026.82 N/A 16 10/28/2027 $46,371.94 $23, 985.75 $22, 386.19 N/A 17 1/28/2028 $46,371.94 $23,620.52 $22,751.42 N/A 18 4/28/2028 $46,371.94 $23, 249.33 $23,122.61 N/A 19 7/28/2028 $46,371.94 $22,872.08 $23,499.86 N/A 20 10/28/2028 $46,371.94 $22,488.68 $23,883.26 $1,377,179.49 21 1 /28/2029 $46,371.94 $22, 099.03 $24,272.91 N/A 22 4/28/2029 $46,371.94 $21,703.02 $24,668.92 N/A 23 7/28/2029 $46,371.94 $21,300.54 $25,071.40 N/A 24 10/28/2029 $46,371.94 $20,891.50 $25,480.44 N/A 25 1/28/2030 $46,371.94 $20,475.79 $25,896.15 N/A 26 4/28/2030 $46,371.94 $20, 053.29 $26, 318.65 N/A 27 7/28/2030 $46,371.94 $19,623.90 $26,748.04 N/A 28 10/28/2030 $46,371.94 $19,187.51 $27,184.43 N/A 29 1 /28/2031 $46,371.94 $18, 744.00 $27, 627.94 N/A 30 4/28/2031 $46,371.94 $18,293.25 $28,078.69 N/A 31 7/28/2031 $46,371.94 $17, 835.14 $28, 536.80 N/A 32 10/28/2031 $46,371.94 $17,369.56 $29,002.38 N/A 33 1 /28/2032 $46,371.94 $16, 896.39 $29,475.55 N/A 34 4/28/2032 $46,371.94 $16,415.50 $29,956.44 N/A 35 7/28/2032 $46,371.94 $15, 926.76 $30,445.18 N/A 36 10/28/2032 $46,371.94 $15,430.04 $30,941.90 N/A 37 1 /28/2033 $46,371.94 $14, 925.23 $31,446.71 N/A 38 4/28/2033 $46,371.94 $14,412.17 $31,959.77 N/A 39 7/28/2033 $46,371.94 $13,890.75 $32,481.19 N/A 40 10/28/2033 $46,371.94 $13,360.82 $33,011.12 $793,012.59 41 1/28/2034 $46,371.94 $12,822.24 $33,549.70 $758,853.04 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 4/28/2034 $46,371.94 $12,274.88 $34,097.06 $724,167.44 7/28/2034 $46,371.94 $11,718.59 $34,653.35 $688,947.68 10/28/2034 $46,371.94 $11,153.22 $35,218.72 $653,185.53 1/28/2035 $46,371.94 $10,578.62 $35,793.32 $616,872.65 4/28/2035 $46,371.94 $9,994.66 $36,377.28 $580,000.55 7/28/2035 $46,371.94 $9,401.16 $36,970.78 $542,560.62 10/28/2035 $46,371.94 $8,797.98 $37,573.96 $504,544.11 1 /28/2036 $46,371.94 $8,184.96 $38,186.98 $465, 942.15 4/28/2036 $46,371.94 $7,561.94 $38,810.00 $426,745.72 7/28/2036 $46,371.94 $6,928.76 $39,443.18 $386,945.66 10/28/2036 $46,371.94 $6,285.24 $40,086.70 $346,532.68 1/28/2037 $46,371.94 $5,631.23 $40,740.71 $305,497.34 4/28/2037 $46,371.94 $4,966.54 $41,405.40 $2631830.06 7/28/2037 $46,371.94 $4,291.01 $42,080.93 $221,521.10 10/28/2037 $46,371.94 $3,604.46 $42,767.48 $178,560.58 1/28/2038 $46,371.94 $2,906.71 $43,465.23 $134,938.47 4/28/2038 $46,371.94 $2,197.58 $44,174.36 $90,644.58 7/28/2038 $46,371.94 $1,476.87 $44,895.07 $45,668.57 10/28/2038 $46,371.94 $744.67 $45,627.27 $0.00 $197569350.93 September 28, 2023 This Note may not be negotiated in the name of bearer and is not a registered obligation ANNA COMMUNITY DEVELOPMENT CORPORATION NOTE, SERIES 2023 ANNA COMMUNITY DEVELOPMENT CORPORATION (the "Corporation") for value received, hereby promises to pay to the order of GOVERNMENT CAPITAL CORPORATION, its successor or assigns, at its offices located at 345 Miron Drive, Southlake, Texas 76092 the principal sum of ONE MILLION SEVEN HUNDRED FIFTY-SIX THOUSAND THREE HUNDRED FIFTY AND 93/100 DOLLARS ($1,756,350.93). All capitalized terms which are used but not defined in this Note shall have the same meanings as in the Loan Agreement dated as of even date herewith, between the Corporation and the Lender (such Loan Agreement, together with all amendments, restatements, supplements and/or other modifications thereto, being the "Loan Agreement"). Subject to Section 2.3 of the Loan Agreement, beginning on January 28, 2024 and on each April 28, July 28, October 28 and January 28 thereafter until the Maturity Date, the Corporation agrees to pay principal and accrued interest on all amounts hereof so advanced and remaining from time to time unpaid hereon in such amounts as reflected on Schedule I attached hereto. All unpaid principal and accrued interest shall be finally due and payable on or before October 28, 2038 (the "Maturity Date"). Interest shall accrue at a per annum rate of 6.526%; provided, however, the interest rate under this Note may be adjusted by Lender, or its assigns, on the date of the twentieth (20th) and fortieth (40th) payments, being October 28, 2028 and October 28, 2033, respectively, (each an "Adjustment Date"). Notice of any rate adjustment shall be given in writing to the Borrower on or before the 30th day prior to such rate adjustment (the "Determination Date"). The interest rate shall be adjusted to the five (5) year treasury rate on the Determination Date, plus 215 basis points. "Treasury Rate" shall mean, as of the Determination Date, the ask yield of the United States Treasury obligations (as compiled by and published in the most recently published issue of the Wall Street Journal). Upon any rate adjustment, the future installments of principal and interest payable under this Note shall be adjusted. Any such adjustment shall be set forth in a new amortization schedule which the Lender, or its assignee, shall prepare using the same format as used to produce the original amortization schedule. Once the amortization schedule is prepared, the Lender, or its assignee, shall attach it to this Note and shall deliver a copy of same to the Borrower. All payments of interest shall be computed quarterly based upon a 360 day year. Past due principal and interest shall bear interest at a rate per annum which is fifteen percent (15.0%), but in no event to exceed the Maximum Interest Rate. Principal of and interest on this Note shall be payable from and secured by a pledge of the Corporation's Economic Development Sales and Use Tax. This Note is authorized under that certain Loan Agreement and is subject to, and is executed in accordance with, all of the terms, conditions and provisions thereof. A fully executed copy of the Loan Agreement is on file in the permanent records of the Corporation and is open for inspection to any member of the general public and to any person proposing to do business with, or asserting claims against, the Corporation, at all times during regular business hours. The principal of and interest on this Note are payable from the Economic Development Sales and Use Tax imposed by Chapter 505 of the Local Government Code (formerly Section 4B of the Development Corporation Act of 1979, Article 5190.6, Texas Revised Civil Statutes Annotated, as amended), as described in and subject to the limitations contained in the Loan Agreement. Except as otherwise provided in the Loan Agreement, the Corporation waives all demands for payment, presentations for payment, protests, notices of protests, and all other demands and notices, to the extent permitted by law. All agreements between the Corporation and holder hereof, whether now existing or hereafter arising and whether written or oral, are hereby limited so that in no contingency, whether by reason of demand, prepayment, or otherwise, shall the interest contracted for, charged, received, paid or agreed to be paid to the holder hereof, exceed the maximum permissible by applicable law. If, from any circumstances whatsoever, interest would otherwise be payable to the holder hereof in excess of the Maximum Interest Rate, then the interest payable to the holder hereof shall be reduced to the maximum amount permitted under applicable law; and if from any circumstances the holder hereof shall ever receive anything of value deemed interest by applicable law in excess of the Maximum Interest Rate, an amount equal to any excessive interest shall be applied to the reduction of the principal hereof and not to the payment of interest, or if such excessive interest exceeds the unpaid balance of principal hereof, such excess shall be refunded to the Corporation. All interest paid or agreed to be paid to the holder hereof shall, to the extent permitted by applicable law, be amortized, prorated, allocated and spread throughout the full period of the subject loan until payment in full of the principal so that the interest hereon for such full period shall not exceed the maximum amount permitted by applicable law. This paragraph shall control all agreements between the Corporation and the holder hereof. THIS NOTE AND THE LOAN AGREEMENT REPRESENT THE FINAL AGREEMENT BETWEEN THE PARTIES AND MAY NOT BE CONTR.A.DICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES. NEITHER THE STATE OF TEXAS, THE CITY OF ANNA, TEXAS (THE "CITY"), NOR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF SHALL BE OBLIGATED TO PAY THE PRINCIPAL OF OR INTEREST ON THIS NOTE, EXCEPT TO THE EXTENT THAT THE CORPORATION IS OBLIGATED TO MAKE THE PAYMENT OF THE PRINCIPAL OF AND INTEREST ON THIS NOTE. NEITHER THE FULL FAITH AND CREDIT NOR THE TAXING POWER OF THE STATE OF TEXAS, THE CITY, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF IS PLEDGED TO THE PAYMENT OF THE PRINCIPAL OF OR INTEREST ON THIS NOTE, EXCEPT TO THE EXTENT THE CORPORATION HAS PLEDGED THE ECONOMIC DEVELOPMENT SALES AND USE TAX DESCRIBED ABOVE TO MAKE THE NOTE PAYMENTS. The Corporation may at its option prepay the principal amount of the Note outstanding hereunder, in whole but not in part, on October 28, 2028 or on any payment date on or after October 28, 2033. The prepayment price shall be an amount equal to the Early Redemption Value for the date determined for prepayment as set forth on Schedule I. If a date for the payment of the principal of or interest on the Note is a Saturday, Sunday, legal holiday, or a day on which the Lender is authorized by law or executive order to close, then the date for such payment shall be the next succeeding day which is not a Saturday, Sunday, legal holiday, or day on which such banking institution is authorized to close; and payment on such date shall have the same force and effect as if made on the original date payment was due. This Note shall be governed in all respects by the laws of the State of Texas and of the United States of America. IN WITNESS WHEREOF, this Note has been duly executed effective as of the date first written above. ANNA COMMUNITY DEVELOPMENT CORPORATION A% L �.r _OAeI �� Schedule I — Payment Schedule EARLY REDEMPTION PMT PMT DATE TOTAL INTEREST PRINCIPAL VALUE NO. MO. DAY YR PAYMENT PAID PAID after pmt on this line 1 1/28/2024 $46,371.94 $38,362.32 $8,009.62 NIA 2 4/28/2024 $46,371.94 $28,524.19 $17,847.75 N/A 3 7/28/2024 $46,371.94 $28,233.00 $18,138.94 N/A 4 10/28/2024 $46,371.94 $27,937.07 $18,434.87 N/A 5 1/28/2025 $46,371.94 $27,636.30 $18,735.64 N/A 6 4/28/2025 $46,371.94 $27, 330.63 $19, 041.31 N/A 7 7/28/2025 $46,371.94 $27,019.97 $19,351.97 NIA 8 10/28/2025 $46,371.94 $26,704.24 $19,667.70 NIA 9 1 /28/2026 $46,371.94 $26, 383.36 $19, 988.58 N/A 10 4/28/2026 $46,371.94 $26, 057.25 $20, 314.69 N/A 11 7/28/2026 $46,371.94 $25, 725.82 $20, 646.12 N/A 12 10/28/2026 $46,371.94 $25, 388.97 $20, 982.97 NIA 13 1 /28/2027 $46,371.94 $25, 046.64 $21, 325.30 NIA 14 4/28/2027 $46,371.94 $24,698.72 $21,673.22 NIA 15 7/28/2027 $46,371.94 $24, 345.12 $22, 026.82 NIA 16 10/28/2027 $46,371.94 $23,985.75 $22,386.19 NIA 17 1/28/2028 $46,371.94 $23,620.52 $22,751.42 N/A 18 4/28/2028 $46,371.94 $23,249.33 $23,122.61 N/A 19 7/28/2028 $46,371.94 $22, 872.08 $23,499.86 N/A 20 10/28/2028 $46,371.94 $22,488.68 $23,883.26 $1,377,179.49 21 1/28/2029 $46,371.94 $22,099.03 $24,272.91 N/A 22 4/28/2029 $46,371.94 $21,703.02 $24,668.92 N/A 23 7/28/2029 $46,371.94 $21,300.54 $25,071.40 N/A 24 10/28/2029 $46,371.94 $20,891.50 $25,480.44 N/A 25 1 /28/2030 $46,371.94 $20,475.79 $25, 896.15 N/A 26 4/28/2030 $46,371.94 $20, 053.29 $26, 318.65 N/A 27 7/28/2030 $46,371.94 $19,623.90 $26,748.04 N/A 28 10/28/2030 $46,371.94 $19,187.51 $27,184.43 N/A 29 1/28/2031 $46,371.94 $18,744.00 $27,627.94 N/A 30 4/28/2031 $46,371.94 $18,293.25 $28,078.69 N/A 31 7/28/2031 $46,371.94 $17,835.14 $28,536.80 N/A 32 10/28/2031 $46,371.94 $17,369.56 $29,002.38 N/A 33 1 /28/2032 $46,371.94 $16, 896.39 $29,475.55 N/A 34 4/28/2032 $46,371.94 $16,415.50 $29,956.44 N/A 35 7/28/2032 $46,371.94 $15,926.76 $30,445.18 N/A 36 10/28/2032 $46,371.94 $15,430.04 $30,941.90 N/A 37 1/28/2033 $46,371.94 $14,925.23 $31,446.71 N/A 38 4/28/2033 $46,371.94 $14,412.17 $31,959.77 N/A 39 7/28/2033 $46,371.94 $13,890.75 $32,481.19 N/A 40 10/28/2033 $46,371.94 $13,360.82 $33,011.12 $793,012.59 41 1 /28/2034 $46,371.94 $12, 822.24 $33, 549.70 $758, 853.04 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 4/28/2034 $46,371.94 $12,274.88 $34,097.06 $724,167.44 7/28/2034 $46,371.94 $11,718.59 $34,653.35 $688,947.68 10/28/2034 $46,371.94 $11,153.22 $35,218.72 $653,185.53 1/28/2035 $46,371.94 $10,578.62 $35,793.32 $616,872.65 4/28/2035 $46,371.94 $9,994.66 $36,377.28 $580,000.55 7/28/2035 $46,371.94 $9,401.16 $36,970.78 $542,560.62 10/28/2035 $46,371.94 $8,797.98 $37,573.96 $504,544.11 1/28/2036 $46,371.94 $8,184.96 $38,186.98 $465,942.15 4/28/2036 $46,371.94 $7,561.94 $38,810.00 $426,745.72 7/28/2036 $46,371.94 $6,928.76 $39,443.18 $386,945.66 10/28/2036 $46,371.94 $6,285.24 $40,086.70 $346,532.68 1/28/2037 $46,371.94 $5,631.23 $40,740.71 $305,497.34 4/28/2037 $46,371.94 $4,966.54 $41,405.40 $263,830.06 7/28/2037 $46,371.94 $4,291.01 $42,080.93 $221,521.10 10/28/2037 $46,371.94 $3,604.46 $42,767.48 $178,560.58 1/28/2038 $46,371.94 $2,906.71 $43,465.23 $134,938.47 4/28/2038 $46,371.94 $2,197.58 $44,174.36 $90, 644.58 7/28/2038 $46,371.94 $1,476.87 $44,895.07 $45668.57 10/28/2038 $46,371.94 $744.67 $45,627.27 $0.00 SALES TAX REMITTANCE AGREEMENT NOTE This SALES TAX REMITTANCE AGREEMENT (as amended, restated, supplemented and/or otherwise modified, this "Agreement") is made to be effective as of August 28, 2023, by and between the CITY OF ANNA, TEXAS, a duly incorporated and existing home rule city operating and existing under the laws of the State of Texas (the "CZ") and the ANNA COMMUNITY DEVELOPMENT CORPORATION, a nonprofit development corporation organized and existing under the laws of the State of Texas, including Chapters 501, 502 and 505, Local Government Code, as amended (formally Section 4B of the Development Corporation Act of 1979, Article 5190.6, Texas Revised Civil Statutes Annotated, as amended) (the "Corporation"). RECITALS WHEREAS, the Corporation on behalf of the City is to finance the costs to acquire certain real property which the Corporation has found will promote new or expanded business enterprise in the City (the "Project"); and WHEREAS, such financing contemplates the issuance of the Corporation's promissory note in the principal amount of $1,756,350.93 (the "Note"), and the proceeds are to be used by the Corporation to acquire the Project. AGREEMENT 1. Financing: For and in consideration of the City's covenants and agreements herein contained and subject to the terms contained herein, the Corporation hereby agrees to enter into a Loan Agreement dated of even date herewith (as same may be amended, restated, supplemented and/or otherwise modified, the "Loan Agreement"), with Government Capital Corporation (the "Lender"), and to execute the Note, and the Corporation hereby agrees and covenants that all proceeds of the loan evidenced by the Note shall be used solely to accomplish the Project and to pay all costs related thereto. 2. Receipt and Transfer of Proceeds of Sales Tax. The City agrees, in cooperation with the Corporation, to take such actions as are required to cause the "Sales Tax" received from the Comptroller of Public Accounts of the State of Texas for and on behalf of the Corporation to be deposited immediately upon receipt by the City to the credit of the Corporation. 3. Modifications. This Agreement shall not be changed orally, and no executory agreement shall be effective to waive, change, modify or discharge this Agreement in whole or in part unless such executory agreement is in writing and is signed by the parties against whom enforcement of any waiver, change, modification or discharge is sought and approved in writing by the Lender. 4. Entire Agreement. This Agreement contains the entire agreement between the parties pertaining to the subject matter hereof and fully supersedes all prior agreements and understandings between the parties pertaining to such subject matter. SALES TAx REMITTANCE (2023 NOTE) 5. Counterparts. This Agreement may be executed in several counterparts, and all such executed counterparts shall constitute the same agreement. It shall be necessary to account for only one such counterpart in proving this Agreement. 6. Severability. If any provision of this Agreement is determined by a court of competent jurisdiction to be invalid or unenforceable, the remainder of this Agreement shall nonetheless remain in full force and effect. 7. Applicable Law. This Agreement shall in all respects be governed by, and construed in accordance with, the substantive federal laws of the United States and the laws of the State of Texas. 8. Captions. The section headings appearing in this Agreement are for convenience of reference only and are not intended, to any extent and for any purpose, to limit or define the text of any section or any subsection hereof. 9. Capitalized Terms. All capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Loan Agreement. [THE REMAINDER OF THIS PAGE 17VTENTIONALL Y LEFT BLANK] 2 SALES TAX REMITTANCE (2023 NOTE IN WITNESS WHEREOF, the parties hereto have executed this Agreement to be effective as of the date and year first above written. ATTEST: By: Rocio Go les Board gecretary ANNA COMMUNITY DEVELOPMENT CORPORATION By: XL12 Bruce N6rwood, Boaz President SALES TAx RFmTTANCE (2023 NOTE) ATTEST: Carrie Land, City Secr tary CITY OF ANN ERAS /' aZz & Nate Pike, Mayor SALES TAX REMITTANCE (2023 NOTE) GENERAL CERTIFICATE OF CORPORATION NOTE We, the undersigned duly authorized officers of the Board of Directors of THE ANNA COMMUNITY DEVELOPMENT CORPORATION (the "Corporation") acting in our official capacities as such, hereby certify with respect to the Loan Agreement dated as of September 28, 2023, (as amended, restated, supplemented and/or otherwise modified, the "Loan Agreement") by and between the Corporation and Government Capital Corporation authorizing the Corporation's Note (as defined in the Loan Agreement) (the "Note"), as follows: 1. That the Corporation is a nonprofit economic development corporation, validly created by the City of Anna, Texas (the "2W') under Chapters 501, 502 and 505, Local Government Code, as amended (formally Section 4A of the Development Corporation Act of 1979, Article 5190.6, Texas Revised Civil Statutes Annotated, as amended) (the "Act") and existing under the Act, and the laws and the Constitution of the State of Texas and is a governmental agency thereof. All capitalized terms used herein shall have the meanings set forth for such terms in the Loan Agreement unless the context clearly indicates otherwise. 2. That as of the date of approval of the Loan Agreement by the Corporation, the following named persons constitute the members of the Board of Directors of Corporation: Bruce Norwood President Jody Bills Vice President Rocio Gonzalez Secretary Kylee Kelley Director Michelle Hawkins Director Ronald Kerr Director Alison Inesta Director 4. The Board of Directors of the Corporation duly adopted by a majority vote a resolution (the "Resolution") authorizing and approving the entering into the Loan Agreement, at a duly called public meeting, at which a quorum was present and acting throughout; the Resolution is in full force and effect and has not been altered, amended or repealed as of the date hereof; that said meeting was duly called and open to the public in accordance with the laws of the State of Texas. The Resolution was considered and approved by the City Council of the City by resolution on August 22, 2023. 5. The following described instruments (collectively, the "Instruments"), as executed and delivered or authorized by the Corporation, are in substantially the same form and text as copies of such Instruments which were before and were approved or ratified by the Board of Directors of the Corporation, and which the officers of the Corporation were authorized to execute and deliver for and on behalf of the Corporation: EDC GENERAL CERTIFICATE (SERIES 2023) (a) the Loan Agreement; (b) the Note in the principal amount of $1,756,350.93; and (c) the Sales Tax Remittance Agreement. 5. To the best knowledge of the undersigned, on the date hereof, the Corporation is not in default in the performance or observance of any of the covenants, conditions, agreements or provisions of the Instruments. 6. The representations and warranties of the Corporation contained in the Instruments are correct on and as of the date hereof as though made on and as of such date. 7. No litigation is pending or, to the best of Corporation's knowledge; threatened in any court to restrain or enjoin the execution and delivery of the Loan Agreement or the Note, or the levy and collection of the Economic Development Sales and Use Tax or the pledge thereof, or contesting or affecting the adoption and validity of the Resolution or the authorization, execution and delivery of the Instruments, or contesting the powers of the Board of Directors of the Corporation. EDC GENERAL CERTIFICATE (SERIES 2023) IN WITNESS WHEREOF, we have duly executed this certificate on the date first written above. ATTEST: By: 2?p�� Rocio Gonzal oard Set4etary THE ANNA COMMUNITY DEVELOPMENT CORPORATION By: ALP Bruce 2 orwood, k0ard President EDC GENERAL CERTIFICATE (SERIES 2023) GENERAL CERTIFICATE OF CITY SERIES 2023 NOTE We, the undersigned duly authorized officers of the CITY OF ANNA, TEXAS (" ty ") acting in our official capacities as such, hereby certify with respect to the Loan Agreement dated as of September 28, 2023, (as same may be amended, restated, supplemented and/or otherwise modified, the "Loan Agreement ") by and between the ANNA COMMUNITY DEVELOPMENT CORPORATION ("Corporation ") and GOVERNMENT CAPITAL CORPORATION ( "Lender ") authorizing a loan in the principal amount of $1,756,350.93, as follows: 1. All capitalized terms used herein shall have the meaning set forth for such term in the Loan Agreement unless the context clearly indicates otherwise. 2. The City is a duly incorporated home rule city, operating and existing under the Constitution and the laws of the State of Texas. 3. The City has duly authorized the creation of the Corporation under the Act. 4. Attached hereto as Exhibit "A" are true, correct, and full copies of the proceedings pertaining to the levy of the Economic Development Sales and Use Tax and the election at which the Economic Development Sales and Use Tax was approved by the voters of the City. 5. No Litigation is pending or, to the best of their knowledge, threatened against the City with respect to the issuance by the Corporation of the Note, the Loan Agreement or the Sales Tax Remittance Agreement, the creation of the Corporation or the title or authority of the governing body or director of the Corporation. [Remainder of Page Intentionally Left Blank] CITY GENERAL CERTIFICATE (SERIES 2023) IN WITNESS WHEREOF, we have duly executed this certificate on the date first written above. ATTEST: eLand, City oretary ���� CITY OF ANNA, TEXASI{, Nate Pike, Mayor CITY GENERAL CERTIFICATE (SERIES 2023)