Interoffice Memorandum
DATE: April 1, 2026
TO: Mayor Jerry L. Demings and County Commissioners
THROUGH: N/A
FROM: Chris Traber, Attorney for Orange County Health Facilities Authority
CONTACT: : Chris Traber (Nabors Giblin & Nickerson)
PHONE: (813) 281-2222
DIVISION: N/A
ACTION REQUESTED:
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Approval and execution of Resolution approving the issuance of educational facilities revenue bonds by the Orange County Industrial Development Authority to loan funds to Orangewood Christian School, Inc. for the financing and refinancing (including reimbursement for prior related expenditures) of educational facilities; providing for the issuance of revenue bonds of the Authority, in one or more series, in an aggregate principal amount not to exceed $40,000,000 for the purpose of making a loan of funds for such purposes. (Orange County Industrial Development Authority)
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PROJECT:
The financing and refinancing (including reimbursement for prior related expenditures) of: ( 1) a portion of the original debt related to existing educational facilities located at 1221 Trinity Woods Lane, Maitland, Florida 32751 (collectively, the "Lower School"); (2) a portion of the original debt related to existing educational facilities and the construction, acquisition, renovation, installation and/or equipping of new educational and related parking facilities located at 1300 West Maitland Boulevard, Maitland, Florida 32751 (collectively, the "Upper School" and together with the "Lower School," the "Project''); (3) funding any necessary reserves for the Bonds; and ( 4) paying all or a portion of the costs related to issuance of the Bonds.
PURPOSE:
Adoption of the resolution would provide the Board's limited approval to the issuance by the Orange County Industrial Development Authority (the "Authority") of not to exceed $40,000,000 Educational Facilities Revenue Bonds (Orangewood Christian School Project), Series 2026 (the "Series 2026 Bonds"), to be issued in one or more series of tax-exempt and taxable bonds pursuant to a plan of finance for the financing and refinancing (including reimbursement for prior related expenditures) of educational facilities owned or leased by Orangewood Christian School, Inc. (the "Borrower"), a Florida nonprofit corporation and an organization described in Section 50l (c)(3) of the Internal Revenue Code of 1986, as amended (the "Code").
The Bonds will be issued as qualified 50l(c)(3) bonds, as defined in Section 145 of the Code. The Board's approval is extremely limited and is required by Section 147(f) of the Internal Revenue Code and Part II of Chapter 159, Florida Statutes. These provisions provide that an elected public body must give its approval to the issuance of private activity bonds prior to their issuance. The Board's approval is given in accordance with Section 125.0l(l)(z), Florida Statutes.
Section 3 of the Board's resolution makes it clear that the approval being given by the Board is limited and, importantly, that the Board is not incurring any liability as a result of its approval.
The Authority held a duly advertised public hearing and adopted their preliminary resolution on March 17, 2026, which is attached as Exhibit A to the proposed Board resolution.
BUDGET: N/A