HomeMy WebLinkAboutIR 7382 INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7382 p.1
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s To the Mayor and Members of the City Council
U� .�f; May 23, 1989
a�T:E•X•"A�y. Subject: ARBITRRA{EIREBATE STATUS REPORT
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Under the Tax Reform Act of 1986 (TRA), arbitraged (excess) earnings on
bond proceeds must be rebated to the federal government . Arbitrage
is defined by Treasury regulations as the ability to obtain tax exempt
funds and invest those funds in higher yielding taxable securities
resulting in a profit to the issuer. Arbitrage can only be earned
during a 'temporary period" (three years) without jeopardizing the tax-
exempt status of the bonds. After the 'temporary period" all
Investments must be yield restricted.
For the City's two bond Issues since the effective date of TRA (1987),
first year arbitrage earnings total $ 595,966.13. (GO Bonds,
=318, 485.78 and Revenue Bonds $27T,480.35) This amount is now
Identified as a liability of the City. It is not likely (without a
major market move in taxables) to decrease this positive arbitrage
already earned, however, dependent on the options chosen, we can limit
any further arbitrage. Each of the two options has costs associated
with it .
The City initially took and has retained the philosophy that it should
secure ALL of its legitimate investment earnings. We have not
attempted to earn arbitrage on these funds, however, the market 's
increasing rates created this unavoidable situation In taxable
securities. We have attempted not to leave any money on the table.
This report Is to 1) explain the effects of arbitrage on the City's
earnings and operations, 2) gain an historical perspective of how
arbitrage is earned and why, 3) review the monitoring process used, and
4) identify options available under Tax Reform.
It is important to remember that the final regulations on arbitrage/
rebate have not yet been published by Treasury. We are still working
In unknown territory.
HISTORICAL BACKGROUND AND PERSPECTIVE
With the Introduction of Tax Reform (TRA), the US Congress attempted to
remedy abuses in the tax-exempt issuances which were created solely for
arbitrage purposes. Arbitrage bonds would, for example, be sold at 6%
and invested in taxable securities yielding 9%.
There Is a more popular school of thought which alleges that the TRA
was structured to earn federal dollars to balance the budget by
capturing legitimate and Illegitimate arbitrage and ultimately to
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS—�-
INFORMAL REPORT TO CITY COUNCIL. MEMBERS No. 72 R9 r
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eliminate tax-exempt issuance for the additional Income from individual
and institutional owners of the bonds.
Regardless of the motive, cities and other entities were presented with
three options: M earn normal., legitimate arbitrage and hope that the
legislation would be changed within the five years reporting period
(before it had to be rebated), or (2) attempt to avoid arbitrage by
earning less than the issue yield (negative arbitrage) and lose money,
or (3) utilize a vehicle which avoids arbitrage, such as SLUGS or tax
exempt paper.
Initial indications were that substantial action was being taken at all
levels of government to protest the onerous aspects of the TRA. The
state treasurers initiated a constitutional amendment process. The
Governors presented their arguments and GFOA along with other
professional organizations moved to change the law legislatively. Such
action actually produced a change in the law raising the minimum
Issuance under rebate from 85mmillion to 810 million. The Supreme Court
case of "Baker versus South Carolina" however closed the door on
Judicial appeal of the arbitrage rebate provisions. Currently, changes
to the regulations remain uncertain.
` The City of Fort North made the decision in 1887, with the first bond
proceeds falling under TRA, to Invest the proceeds, according to the
projected draw-down schedules, in taxable securities. These bond
Issues were set up as separate portfolios and monitored carefully as
the expenditures were made. The portfolios were neither traded
aggressively nor actively, as was the other consolidated portfolio.
However, even the buy and hold strategy resulted in significant
arbitrage earnings. For the City's two bond Issues of 1887, first year
arbitrage earnings total 8 585,866.13. (GO Bonds, 8318,485.78 and
Revenue Bonds 8277, 480.35)
= &UITRAGE ZANIME RESULTED
Utilizing the buy and hold method to assure allowable earnings even in
a normal yield curve will generally earn excess Interest because of the
low rate at which the bonds are issued and the higher rates out 2-3
years on the curve. In the last two years, we have experienced a
significant yield rally in the bond market which has even further
Increased our excess earnings. For example, a two-year treasury in
1887 was yielding a 7T►, and a two-year now yields close to 10%.
We will follow the example of the two bond proceeds (from April 1887)
to see how such earnings are created. The two issues and their issue
yields base-line are:
ISSUE ISSUE TIELD
GO Bonds 1987 6.50277
Rater do Sewer Bonds 1987 6.4258896
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS --
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Therefore, any earnings over these yields are arbitrage.
Figure 1 shows that although the funds are to be spent over a three
year period and matched as closely as possible to the scheduled draw-
downs during that period, any security with a maturity over one year
already put the City into an arbitrage position. (The lines on Figure
i represent the issue yield and the bars the earnings for the treasury
securities across the yield curve.)
Figure 2 shows the breakdown on the original purchases, based on draw-
down schedules, by yield. If the issue yield in April 1987 was
6.458898%, arbitrage was earned beginning with the stay 1988 maturity
yielding 7.06%.
In addition, Figures 3 and 4 show the planned draw-down (construction)
schedules for each issue. These work plans were subsequently changed
to reflect the realities of the construction protects . The delays in
spending however simply magnified our arbitrage situation because the
rates were moving up continuously during this period.
None of the funds in question have been traded or swapped to create
non-market-generated arbitrage. If proceeds were not spent the funds
were simply re-invested to new schedules.
The yield curve now, which reflects the expected yields at various
maturities, for the remaining "temporary period" is basically:
05/89 8.82
06/89 8.89
07/89 8.96
08/89 8.98
09/89 9.26
10/89 9.20
11/89 9.20
12/89 9.25
01/90 9.30
02/90 9.28
03/90 9.33
04/90 9.30
That means that everything (at this point) that has had to be re-
invested and will have to be re-invested will be at a minims 200
points above the issue yield.
This then is the situation which created for the City substantial
arbitrage profits - without trying!
We now have four bond portfolios under TRA restrictions. The effect on
the overall earnings for all funds distributed to all funds is
estimated at 91.5 - 2 million this year. This is a result of limiting
the maturities and the trading possibilities in the TRA funds .
ISSUED BY THE CITY MANAGER FORT WORTH. TEXAS--
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 72A2 p-4
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WNI TORI NG
All funds are monitored on a ongoing basis. The Treasurer and the
departments Involved have worked together to address the expenditure
levels in these funds.
According to the regulations, 85% of the funds In each issue must be
expended in the three year "temporary period" or the City is required
to restrict earnings to the Issue yield. Failure to do so could result
in loss of the tax exempt status of the issue. This will be done
through tax exempts or SLUGS if necessary.
Efforts are being made to assure that the funds will be expended on the
planned projects and funds in these issues is being expended before
older issues (not under TRA) proceeds .
No options are available to the City after the three year "temporary
period". Control of arbitrage options exist only before the yield
restriction becomes mandatory.
TURE OPTIONS
All tax-exempt bond Issues will come under the TRA. At this point,
there is no viably proposed change being considered by Congress or the
Treasury to that rule. As a result, the City has options available to
It In only two areas : Issuance and investment . Each of these options
are being evaluated as to their advantages and their disadvantages .
All options must be evaluated In terms of our overall goals .
-provide funds for needed capital projects,
-provide capital funds at the lowest cost to taxpayers,
-secure all allowable earnings due the City, and
-be in a position to maximize and retain earnings should the
TRA regulations change.
OPTIONS Sf. ISSUANCE
The City of Fort Worth has traditionally sold general obligation or
revenue bonds in the tax-exempt arena. There are other options
available to the City which may avoid some or all arbitrage provisions .
2). Continue to issue tax-exempt debt .
Advantages: The advantages of this option are low Interest rates and a
set debt schedule.
Disadvantages: The primary disadvantage is the necessity to rebate all
earnings over Issue yield.
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS
INFORMAL REPORT TO CITY COUNCIL. MEMBERS No. 7382 p.5 —
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To the Mayor and Members of the City Council
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2). Issuance of taxable debt.
Advantages: Taxable debt does not come under the tax reform provisions .
It is not subject to arbitrage nor rebate. The strong credit rating of
Fort Worth and generally high visibility could make it a viable player
In the taxable market .
Disadvantages: Taxables do not enjoy the lower borrowing rate of the
tax-exempts and thus would raise our borrowing cost . This would have
to be balanced by higher Investment earnings.
If taxable rates decline significantly, the City would still be stuck
with the higher rates unless the bonds are refunded and refundings are
limited to one under TRA.
The City's rating and reputation, though strong, does not guarantee it
as strong position in the taxable market because of the significantly
stronger corporate Issues against which it would be competing.
(Parenthetically this assures some degree of success to one assumed
federal objective: that of reducing or eliminating tax-exempts for the
tax earnings available to the federal government . )
3). Issuance of short-term debt .
Advantages: Issuance of short term debt takes advantage of the TRA
provisions for bond proceeds spent within six months . Under these
regulations, sales of such short term vehicles as commercial paper
would be timed to provide funds as construction schedules required. No
arbitrage cost is involved.
Disadvantages: The administrative costs are somewhat higher for short
Issues and the borrowing rates can fluctuate widely dependent upon the
markets. Definite debt planning becomes such more difficult and some
larger construction projects can not be effectively timed to avoid
higher rates demanded by the markets.
4). Utilization of a state fund.
The State Revolving Loan Fund administered by the Water Development
Board Is being used currently to finance $33 million in projects.
Advantages: These draws are spent within the six months period. Under
the fund, moneys can be drawn therefore as needed and thus avoid
arbitrage.
Disadvantages: Competition for these funds is growing and there is a
limit to the funds available.
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS--
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7392 .p-A -
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too? the Mayor and Members of the City Council
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OPTIONS Q,K INVESTMENTS
There is only one safe haven for bond proceeds' investments and that Is
purchase of tax exempt securities . Any arbitrage earned on tax exempts
may be retained. Calculations of arbitrage treat purchase of tax
exempts as cash outlays. However, the substantially lower rates on
tax-exempt paper makes earning any arbitrage - even up to the allowable
Issue yield - difficult . Combinations of taxables and tax exempts are
therefore the options most normally investigated.
1). Purchase of tax exempt securities.
Tax exempts can be bought for the entire bond proceeds or for a portion
of the proceeds.
Advantages: Under this method, the arbitrage calculations treat the
purchases as if the cash has been spent and there are no earnings being
received. This would relieve arbitrage and enable all earnings to be
retained by the City.
Disadvantages: The earnings made under this option are considerably
less than that on taxable securities . (We would insist on AAA bonds
for the portfolios . ) The purchase of these securities is not as
flexible or operationally as efficient as taxables and the supply of
short term municipals Is somewhat limited. The liquidity of the
securities could be the largest problem.
2). Utilize WiF tax exempts
Advantages: Legislation is currently pending which would allow
municipalities to utilize tax-exempt funds. This would eliminate some
of the more difficult operational problems of dealing with tax-exempts
(liquidity and short durations) while increasing yields which would not
have to be rebated.
Disadvantages: The yields, although increased, would still be below
normal taxable securities.
3). Investments bought to a specific drawdown schedule to earn
allowable arbitrage. Allowing for rebate of excess funds.
Advantages: This option allows the City to earn its maximum earnings
under the law. Until the laws are finalized, it also provides for the
opportunity to keep those earnings should the laws be changed.
Disadvantages: All excess earnings are to be rebated to the Treasury.
OPL SUISAR
The options afforded issuers of tax-exempt debt are few and may be
limited further in the future as the federal government searches for
means to reduce its own debt . No one option will solve the problem. A
combination of short term debt (especially for revenue) and some
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS --
INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7382 p.7
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taxable options may prove feasible on the issuance side. On the
investment side, we will work within the TRA restraints, assure that no
legitimate earnings are lost, and assure that the tax-exempt status of
the bonds is in no way jeopardized. We are currently moving into tax
exempt bonds (where feasible) in preparation for the end of the first
two temporary periods for the 198T issues in 1990.
ugrlas Harman
City Manager
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ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS--
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YIELD CUR VE
Date PAR Yield at
Cast
10187 11230,000 5.85
11187 605,000 6.12
12187 11400,000 6.18
1188 193759000 6.14
2188 595,000 6.23
3188. 545,000 6.28
4188 6809000 6.25
110- 5188 940,000 7.06
6188 1 ,875,000 7.07
8188 935,040 7.09
9188 11900,000 6.93
11188 975,000 7.10
12188 1 ,940,000 7.09
2189 980,000 7.21
3189 985,000 7.27
WATER AND SEWER
Fig. 2
FIGURE 3
PLANNED PROCEEDS M VERSUS ACTUAL liSB.
HATER AND SEVER ISSUE 1987
(Shorting yield at scheduled maturities)
ORIGINAL SCHEDULE ACTUAL
PROCEEDS USE PLAN Yield SPENDING PATTERN
08/87 6 0 90, 000
09/87 0 0
10/87 0 0
11/87 1, 700, 000 6.20 0
12/87 680, 000 6.23 0
01/88 680, 000 6.34 0
02/88 680P000 6.40 0
03/88 680, 000 6.48 0
04/88 680, 000 6. 54 <<< arb. pt . 0
05/88 680, 000 6.54 0
06/88 1, 020, 000 6.59 0
0718E 1, 020, 000 6.61 0
08/88 1, 020, 000 6.66 571
09/88 1, 020, 000 6.70 0
10/88 1, 020, 000 6. 77 2, 009
11/88 1, 020, 000 6.80 0
12/88 1, 020, 000 6.82 3, 491, 494
01/89 1, 020, 000 6.87 0
02/89 1, 020, 000 6.92 2, 016, 735
03/89 1, 020, 000 6.97 701, 313
04/89 1, 020, 000 7.03 n/a
9 17, 000, 000 $ 6, 302, 122 37%
FIGURE 4
PLAN P20CEEDS M VERB ACTUAL M
G.O. BOND ISSUE 1887
(Showing yield at scheduled maturities )
ORIGINAL SCHEDULE ACTUAL
PROCEEDS USE PLAN * Yield SPENDING PATTERN
04/87 5 571,000 6 175, 590
05/87 506,000 84, 893
06/87 577, 000 20, 798
07/8" 549, 000 27, 086
08/87 338, 000 109, 475
09/87 640, 000 71, 503
10/8" 368, 000 51, 03-2
11/87 376, 000 6.20 445, 903
12/87 633, 000 6.23 172, 191
01/88 513, 000 6.34 18, 600
02/88 862, 000 6.40 20, 090
03/88 998, 000 6.48 626, 832
04/88 937, 000 6.54 M arb. pt . 630, 001
05/88 818,000 6.54 968, 215
06/88 1, 019, 000 6.59 7981742
07/88 868, 000 6.61 434, 097
08/88 958, 000 6.66 341, 455
09/88 703,000 6.70 1, 001, 000
10/88 661, 000 6.77 1, 987, 434
11/88 889, 000 6.80 1, 745, 450
12/88 987, 000 6.82 3, 159, 247
01/89 587, 000 6.87 750, 400
02/89 799, 000 6.92 809, 040
03/89 575, 000 6.97 n/a
04/89 652, 000 7.03 n/a 83% of plan
05/89 779, 000 7.13
06/89 685, 000 7.16
07/89 601, 000 7.20
08/89 283, 000 7.22
09/89 422, 000 7.23
10/89 382, 000 7.25
11/89 $55, 000 7.27
12/89 355, 000 7.30
01/90 148, 000 7.30
02/90 341, 000 7.37
03/90 493, 000 7.44
04/90 556, 000 7 .49
* Schedule was calculated using last four frond issues spending
patterns .