Tax Increment Financing Revenue Loan Note - USVI Public Finance Authority

Virgin Islands Public Finance Authority

VIPFA

Tax Increment Financing Revenue Loan Note

Bonds issued by the PFA.

The Revised Organic Act of 1954, as amended, authorizes the Government of the United States Virgin Islands (the “Government”) to issue several types of municipal securities and distinguishes general obligation bonds from revenue bonds.

Pursuant to 2008 V.I. Act No. 7054 enacted October 11, 200, the Virgin Islands Public Finance Authority is authorized to issue Tax Increment Financing (“TIF”) bonds. Pursuant to the Act (the “Island Crossings TIF Act”), the Legislature of the Virgin Islands (the “Legislature”) approved the development plan, titled “Development Plan for the Islands Crossings Development Area”, dated September 12, 2008 (the “Development Plan”), and authorized, among other things, the Development Agreement, by and between the Government and CDP LLC, a United States Virgin Islands limited liability company (the “TIF Project Developer”), as developer of the Islands Crossings Project, dated as of September 30, 2008 (the “Development Agreement”); and the TIF Act Authorizes the Virgin Islands Public Finance Authority to issue tax increment financing bonds, notes or other obligations by the Authority for the purpose of financing a portion of the Islands Crossings Project constituting TIF Qualified Improvement.

The Tax Increment Revenue Bonds were issued to finance the Island Crossing Shopping Center project on St. Croix and are paid from the Incremental Property Taxes and 90% of the Gross Receipts Taxes collected from the project.

The TIF Loan Note of $12,000,000 Series 2019A Tax Increment Revenue and Refunding Bond (Virgin Islands Tax Increment Revenue Loan Note – Island Crossing Shopping Center), was issued on November 1, 2019.

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