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HomeMy WebLinkAbout2026-037RESOLUTION NO. 2026- 037 RESOLUTION OF THE BOARD OF COUNTY COMMISSIONERS OF INDIAN RIVER COUNTY, FLORIDA, SUPPLEMENTING RESOLUTION NO. 2023-004 OF THE COUNTY; AUTHORIZING THE ISSUANCE OF NOT EXCEEDING $27,205,000 IN AGGREGATE PRINCIPAL AMOUNT OF INDIAN RIVER COUNTY, FLORIDA GENERAL OBLIGATION BONDS, SERIES 2026, IN ORDER TO FINANCE THE COST OF ACQUIRING AND PRESERVING ENVIRONMENTALLY SENSITIVE LANDS AND CONSTRUCTING PUBLIC ACCESS IMPROVEMENTS RELATED THERETO WITHIN THE COUNTY; MAKING CERTAIN OTHER COVENANTS AND AGREEMENTS IN CONNECTION WITH THE ISSUANCE OF SUCH BONDS; PROVIDING CERTAIN TERMS AND DETAILS OF SUCH BONDS; AUTHORIZING THE COUNTY ADMINISTRATOR OR THE CLERK OF THE COUNTY TO PUBLISH A SUMMARY NOTICE OF SALE AND TO RECEIVE BIDS PURSUANT TO A COMPETITIVE SALE OF SAID BONDS AND AWARD THE SALE OF SAID BONDS TO THE RESPONSIVE BIDDER OR BIDDERS OFFERING THE LOWEST TRUE INTEREST COST TO THE COUNTY, WHICH SHALL NOT EXCEED 5.00 PERCENT (5.00%); AUTHORIZING THE EXECUTION AND DELIVERY OF SAID BONDS; APPOINTING THE PAYING AGENT AND REGISTRAR WITH RESPECT TO SAID BONDS; APPROVING THE PREPARATION AND USE OF A SUMMARY NOTICE OF SALE, AN OFFICIAL NOTICE OF SALE, A PRELIMINARY OFFICIAL STATEMENT AND FINAL OFFICIAL STATEMENT; AUTHORIZING THE ELECTRONIC DISSEMINATION OF THE PRELIMINARY OFFICIAL STATEMENT AND OFFICIAL STATEMENT; AUTHORIZING THE EXECUTION AND DELIVERY OF A CONTINUING DISCLOSURE CERTIFICATE; AND PROVIDING AN EFFECTIVE DATE. BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF INDIAN RIVER COUNTY, FLORIDA, as follows: SECTION 1. FINDINGS. It is hereby found and determined that: 1. On January 31, 2023, the Board of County Commissioners of Indian River County, Florida (the "County" or "Issuer") duly adopted Resolution No. 2023-004 (the "Original Resolution"). All capitalized terms not otherwise defined herein shall have the meanings set forth in the Original Resolution. 2. The Original Resolution, as previously supplemented by Resolution No. 2024-023 adopted by the Board on June 4, 2024, is referred to herein as the 'Bond Resolution." 3. The Original Resolution provides for the issuance of bonds thereunder, upon meeting the requirements set forth in the Original Resolution. 4. The County deems it to be in the best interests of its citizens and taxpayers to issue its General Obligation Bonds, Series 2026 (the 'Bonds") for the purpose of financing the acquisition and preservation of environmentally sensitive lands and the construction of public access improvements with respect thereto within the County, as identified by resolution of the County (the "Project," as described in the Original Resolution). 5. The principal of and interest on the Bonds and all required sinking fund, reserve and other payments shall be general obligations of the County, secured by the full faith and credit of the County and the Ad Valorem Taxes, as provided in the Bond Resolution. 6. The County deems it necessary: (i) to fix the date, denominations, amount and maturities of the Bonds, (ii) to authorize the publication of a Summary Notice of Sale in The Bond Buyer or such other publication as directed by the County Administrator, (iii) to approve the form and authorize the use of an Official Notice of Sale, Preliminary Official Statement and a final Official Statement, (iv) to authorize the County Administrator or the Clerk of the County to award the Bonds to the best bidder or bidders upon the terms and conditions and subject to the limitations set forth herein and in the Official Notice of Bond Sale, (v) to appoint a Bond Registrar and Paying Agent, and (vi) to approve the form of a continuing disclosure undertaking. 7. The Original Resolution provides that the Bonds shall mature on such dates and in such amounts, shall bear such rates of interest, shall be payable in such places and shall be subject to such redemption provisions as shall be determined by Supplemental Resolution adopted by the County; and it is now appropriate that the County determine parameters for such terms and details. SECTION 2. AUTHORITY FOR THIS SUPPLEMENTAL RESOLUTION. This Supplemental Resolution is adopted pursuant to Articles II and VII 2 of the Original Resolution, the provisions of the Act (as defined in the Original Resolution) and other applicable provisions of law. SECTION 3. AUTHORIZATION AND DESCRIPTION OF THE BONDS. The County hereby determines to issue a series of Bonds in an aggregate principal amount not exceeding $27,205,000, the exact principal amount to be as authorized by the Official Notice of Sale, to be known as its "General Obligation Bonds, Series 2026," for the principal purpose of financing the Cost of the Project. The Bonds shall be dated as of their date of delivery, shall be issued as fully registered Bonds, numbered consecutively from one upward in order of maturity with the prefix "R"; shall bear interest from their date of delivery, payable semi-annually, on (except as otherwise established by the County Administrator based on advice of the County's Financial Advisor) January 1 and July 1 of each year, commencing on January 1, 2027, at such rates and maturing in such amounts on July 1 of such years (except as otherwise established by the County Administrator based on advice of the County's Financial Advisor) as to be set forth in the Official Notice of Sale. The Bonds shall be issued in denominations of $5,000 and any integral multiple thereof. Each Bond shall bear interest from the Interest Date next preceding the date on which it is authenticated, unless authenticated on an Interest Date, in which case it shall bear interest from such Interest Date, or, unless authenticated prior to the first interest payment date, in which case it shall bear interest from its date; provided, however, that if at the time of authentication interest is in default, such Bond shall bear interest from the date to which interest shall have last been paid. Interest on the Bonds shall be calculated on the basis of a 360 -day year comprised of twelve 30 -day months. The principal of and the interest on the Bonds shall be payable in any coin or currency of the United States of America which on the respective dates of payment thereof is legal tender for the payment of public and private debts. The principal of the Bonds shall be payable only to the registered Holder or his legal representative at the principal corporate trust office of the Paying Agent, and payment of interest on the Bonds shall be made by the Paying Agent on each interest payment date to the person appearing on the registration books of the Issuer hereinafter provided for as the registered Holder thereof, by electronic means, draft or check mailed to such registered Holder at his address as it appears on such registration books. Payment of the principal on all Bonds shall be made upon the presentation and surrender of such Bonds as the same shall become due and payable. The Bonds shall be subject to redemption prior to maturity as set forth below: The Bonds maturing on or before July 1, 2036 shall not be subject to optional redemption prior to maturity. The Bonds maturing on July 1, 2037 and thereafter are redeemable at the option of the County from any legally available source, in whole or in part and if in part, in any order of maturity selected by the County, at its discretion, and by lot within a maturity if less than an entire maturity is to be redeemed, on July 1, 2036, or 3 at any time thereafter, at a redemption price equal to the principal amount of the Bonds to be redeemed, together with accrued interest to the date fixed for redemption. Notwithstanding the foregoing, if the County's Financial Advisor, upon consultation with the County, determines that market conditions require different or no optional redemption provisions for the Bonds or for certain maturities of the Bonds, such different optional redemption provisions or the exclusion of certain or all maturities of the Bonds from such optional redemption provisions will be deemed approved by the County so long as the maximum redemption premium does not exceed I % and the first optional redemption period, if any, is not more than eleven (11) years from the date of issuance of the Bonds if the Bonds are to be subject to optional redemption. Any bonds which are designated as Term Bonds in accordance with the Official Notice of Sale shall also be subject to mandatory redemption prior to maturity by lot, in such manner as the Registrar may deem appropriate, on July l (subject to adjustment as described above), in such years, at a price of par plus accrued interest to the date of redemption, in the annual amounts established by the winning bidder in consultation with the County Administrator and/or the Clerk, or his or her designee, and the Financial Advisor. A book -entry -only system of registration is hereby authorized for the Bonds. So long as the Issuer shall maintain a book -entry -only system with respect to the Bonds, the following provisions shall apply: A blanket issuer letter of representations (the "BLOR") was entered into by the County with The Depository Trust Company ("DTC"). It is intended that the Bonds be registered so as to participate in a global book -entry system with DTC as set forth herein and in such BLOR. The terms and conditions of such BLOR shall govern the registration of the Bonds. The Bonds shall be initially issued in the form -of a, single fully registered Bond for each maturity of such Series. Upon initial issuance, the ownership of such Bonds shall be registered by the Registrar in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. So long as any Bond is registered in the name of DTC (or its nominee), the Issuer, the Registrar and the Paying Agent may treat DTC (or its nominee) as the sole and exclusive holder of such Bonds registered in its name, and all payments with respect to the principal or redemption price of, if any, and interest on such Bond ("Payments") and all notices with respect to such Bond ("Notices") shall be made or given, as the case may be, to DTC. Transfers of Payments and delivery of Notices to DTC Participants shall be the responsibility of DTC and not of the Issuer, subject to any statutory and regulatory requirements as may be in effect from time to time. Transfers of Payments and delivery of Notices to beneficial owners of the Bonds by DTC Participants shall be the responsibility of such participants, indirect participants and other nominees of such beneficial owners and not of the Issuer, subject to any statutory and regulatory requirements as may be in effect from time to time. M Upon (a) receipt by the Issuer of written notice from DTC (i) to the effect that a continuation of the requirement that all of the Outstanding Bonds be registered in the registration books kept by the Registrar in the name of Cede & Co., as nominee of DTC, is not in the best interest of the beneficial owners of the Bonds or (ii) to the effect that DTC is unable or unwilling to discharge its responsibilities and no substitute depository willing to undertake the functions of DTC hereunder can be found which is able to undertake such functions upon reasonable and customary terms, (b) termination, for any reason, of the agreement among the County, the Registrar and Paying Agent and DTC evidenced by the BLOR, or (c) determination by the Issuer that such book -entry only system should be discontinued by the County, and compliance with the requirements of any agreement between the Issuer and DTC with respect thereto, the Bonds shall no longer be restricted to being registered in the registration books kept by the Registrar in the name of Cede & Co., as nominee of DTC, but may be registered in whatever name or names Holders shall designate, in accordance with the provisions hereof. In such event, the County shall issue and the Registrar shall authenticate, transfer and exchange Bonds consistent with the terms hereof, in denominations of $5,000 or any integral multiple thereof to the Holders thereof. The foregoing notwithstanding, until such time as participation in the book -entry only system is discontinued, the provisions set forth in the BLOR shall apply to the registration and transfer of the Bonds and to Payments and Notices with respect thereto. SECTION 4. AUTHORIZATION OF THE PROJECT. The acquisition and construction of the Project (including the reimbursement to the Issuer of certain costs incurred with respect thereto), is hereby authorized by the Issuer. SECTION 5. SALE OF THE BONDS. The County Administrator and/or the Clerk, or his or her designee, is hereby authorized and directed to sell the Bonds at public sale by competitive bid and to publish the Summary Notice of Sale in the form attached hereto as Exhibit A in The Bond Buyer or such other publication as directed by the County Administrator or his designee at least ten (10) days prior to the date of sale, which date of sale shall be determined by the County Administrator or his designee, in consultation with the County's Financial Advisor, in an effort to achieve the lowest true interest cost for the County. The Official Notice of Sale attached hereto as Exhibit B and the Preliminary Official Statement attached hereto as Exhibit C are each hereby approved and authorized to be used in connection with the sale of the Bonds. The Preliminary Official Statement, upon advice of the County Administrator, is hereby deemed final for purposes of Rule 15c2-12 of the Securities and Exchange Commission (the "Rule"). The Preliminary Official Statement and Official Statement (as defined below) are authorized to be made available by electronic means. The Preliminary Official Statement, as amended on the date of sale of the Bonds to delete the preliminary language and as further amended to reflect the actual interest rates and reoffering terms and any changes of maturities or amounts and with such additional correcting and conforming changes as shall be approved by the County Administrator, is 5 hereinafter referred to as the "Official Statement," and as promptly as possible following the sale and within seven (7) business days of the date of sale of the Bonds, the County agrees to make available to the Underwriters of the Bonds a sufficient number of copies of the Official Statement as necessary to enable such purchasers to comply with the Rule. The Chairman and County Administrator are authorized to execute the Official Statement on behalf of the County, with such changes, completions and amendments as they shall determine are necessary or desirable. Execution of the Official Statement by the Chairman and County Administrator shall constitute approval of any such changes, completions or amendments. The County Administrator or his designee is hereby delegated the authority to award the Bonds to the responsive bidder offering to purchase the Bonds at the lowest true interest cost to' the County, which in no event shall exceed 5.00 percent (5.00%), calculated as provided in the Official Notice of Bond Sale, and with a final maturity date of no later than twenty (20) years following the date of issuance of the Bonds. SECTION 6. APPLICATION OF BOND PROCEEDS. The proceeds, including accrued interest and premium, if any, received from the sale of the Bonds shall be applied by the Issuer simultaneously with the delivery of such Bonds to the purchaser, as follows: 1. Capitalized interest, if any, shall be deposited into the Sinking Fund and shall be used only for the purpose of paying interest becoming due on the Bonds. 2. A portion of the Bond proceeds shall be deposited in the Project Fund. The Issuer covenants and agrees to establish a separate account within the Project Fund to be known as the "Indian River County, Florida General Obligation Bonds, Series 2026 Project Account" (hereinafter referred to as the "2026 Project Account") which shall be used only for the payment of the Cost of the Project. Moneys in the 2026 Project Account until applied in payment of any item of the Cost of the Project, shall be held in trust by the Issuer and shall be subject to a lien and charge in favor of the Holders of the Bonds, and for the further security of such Holders. 3. To the extent not paid by the original purchaser of the Bonds, the Issuer shall pay all costs and expenses in connection with the issuance, sale and delivery of the Bonds. SECTION 7. CONTINUING DISCLOSURE CERTIFICATE. In order to enable the Underwriter to comply with the provisions of the Rule relating to secondary market disclosure, the County Administrator is hereby authorized and directed to execute and deliver the Continuing Disclosure Certificate in the name and on behalf of the County substantially in the form attached hereto as Exhibit D, with such changes, amendments, omissions and additions as shall be approved by the Chairman, his execution and delivery thereof being conclusive evidence of such approval. N SECTION 8. APPOINTMENT OF REGISTRAR AND PAYING AGENT. U.S. Bank Trust Company, National Association, Jacksonville, Florida, is hereby designated Registrar and Paying Agent for the Bonds. The Chairman and the Clerk are hereby authorized to enter into any agreement which may be necessary to effect the transactions contemplated by this Section 8. SECTION 9. GENERAL AUTHORITY. The members of the Board of the County Commission and the officers, attorneys and other agents or employees of the County are hereby authorized to do all acts and things required of them by this Supplemental Resolution, the Original Resolution or the Bond Resolution, or desirable or consistent with the requirements hereof or of the Original Resolution, including the execution of such documents necessary to establish a book -entry system of registration with respect to the Bonds, for the full punctual and complete performance hereof or thereof. Each member, employee, attorney and officer of the County is hereby authorized and directed to execute and deliver any and all papers and instruments and to be and cause to be done any and all acts and things necessary or proper for carrying out the transactions contemplated hereunder. The County Administrator and/or the Clerk or any designees thereof are hereby authorized to execute such tax forms or agreements as shall be necessary to effect the transactions contemplated hereby, including designating Bond Counsel to assist or act as agent with respect thereto. SECTION 10. ORIGINAL RESOLUTION TO CONTINUE IN FORCE. Except as herein expressly provided, the Original Resolution and all the terms and provisions thereof, including the covenants contained therein, are and shall remain in full force and effect. SECTION 11. SEVERABILITY AND INVALID PROVISIONS. If any one or more of the covenants, agreements or provisions herein contained shall be held contrary to any express provision of law or contrary to the policy of express law, even though not expressly prohibited, or against public policy, or shall for any reason whatsoever be held invalid, then such covenants, agreements or provisions shall be null and void and shall be deemed separable from the remaining covenants, agreements or provisions and shall in no way affect the validity of any of the other covenants, agreements or provisions hereof or the Bonds issued hereunder. [Remainder of page intentionally left blank] 7 SECTION 12. EFFECTIVE DATE. This Supplemental Resolution shall become effective immediately upon its adoption. The foregoing resolution was offered by Commissioner Susan Adams moved its adoption. The motion was seconded by Commissioner upon being put to a vote, the vote was as follows: who Joseph H. Earman and, Chairman Deryl Loar AYE Vice Chairman Laura Moss AYE Commissioner Susan Adams AYE Commissioner Joseph Earman AYE Commissioner Joseph E. Flescher AYE The Chairman thereupon declared the resolution passed and adopted this 19th day of May 2026. BOARD OF COUNTY COMMISSIONERS INDIAN RIVER COUNTY, FLORIDA ......... . .... G 0 ht MISS •., By: Deryl Loar, Chairman ATTEST: Ryan L. Butler, Clerk of Circuit Court and Comptroller By: DLJ C rk Approved as to form and legal sufficiency: Je fer W. Chuler, County Attorney �•• �� � .� Oma-, EXHIBIT A FORM OF SUMMARY NOTICE OF SALE SUMMARY NOTICE OF SALE $[PAR AMOUNT]* Indian River County, Florida General Obligation Bonds, Series 2026 Bids for the above captioned bonds will be received by Indian River County, Florida (the "County") via the BiDCOMP/Parity'. Competitive Bidding System ("Parity®") until [11: 00] A.M. (the "Submittal Deadline"), Eastern time, [June 11], 2026 or such other date as may be established by the County Administrator or Chief Deputy Comptroller of the County or their respective designee no less than ten (10) days after the date of publication of this notice and communicated through Refinitiv TM3 at the internet website address www.tm3.com not less than twenty (20) hours prior to the time bids are received (the "Bid Date"). Such bids are to be opened in public as soon as practical after the Submittal Deadline on said day for the purchase of the Indian River County, Florida General Obligation Bonds, Series 2026 (the "2026 Bonds"). The 2026 Bonds will mature as specified in the Official Notice of Sale. Proceeds of the 2026 Bonds shall be used for the purpose of (i) financing the acquisition and preservation of environmentally sensitive lands and the construction of public access improvements with respect thereto within the County and (ii) paying the costs of issuing the 2026 Bonds. The approving opinion of Nabors, Giblin & Nickerson, P.A., Tampa, Florida, Bond Counsel, will be furnished to the successful bidder at the expense of the County. Electronic copies of the Preliminary Official Statement and the Official Notice of Sale relating to the 2026 Bonds may be obtained at the website address www.munios.com. Printed, bound copies of the Preliminary Official Statement will be available on a limited basis from the County's Financial Advisor, Joel Tindal, Hilltop Securities Inc., 450 South Orange Avenue, Suite 225, Orlando, Florida 32801, telephone 407/426-9611, email joel.tindal(i4hilltopsecurities.com. For more information about Parit)®, potential bidders may call Parity® at 212/849-5021. Indian River County, Florida John A. Titkanich, Jr. County Administrator Dated: [June 1], 2026 `Preliminary, subject to change. EXHIBIT B FORM OF OFFICIAL NOTICE OF SALE OFFICIAL NOTICE OF SALE $[PAR AMOUNT]* INDIAN RIVER COUNTY, FLORIDA GENERAL OBLIGATION BONDS, SERIES 2026 The Indian River County, Florida General Obligation Bonds, Series 2026 (the "2026 Bonds") are being offered for sale in accordance with this Official Notice of Sale. Notice is hereby given that bids will be received by Indian River County, Florida (the "Issuer" or the "County") for the purchase of the 2026 Bonds via the BiDCOMP/Parity® Competitive Bidding System ("Parity®") in the manner described below until [ 11:00 A.M.], Eastern time, on [June 111, 2026, or on such other date and/or time as will be established by the County Administrator or Clerk of the Circuit Court and Comptroller of the County or their respective designee and communicated through Refinitiv TM3 at the internet website address www.tm3.com not less than 20 hours prior to the time the bids are to be received. To the extent any instructions or directions set forth on Parity® conflict with this Official Notice of Sale, the terms of this Official Notice of Sale shall control. For further information about Parity®, and to subscribe in advance of the bid, potential bidders may contact Parity® at (212) 849-5021. The use of Parity® shall be at the bidder's risk and expense, and the Issuer shall have no liability with respect thereto. BOND DETAILS The description of the 2026 Bonds, the purpose thereof and the security therefor, as set forth in this Official Notice of Sale, is subject in its entirety to the disclosures made in the Preliminary Official Statement relating to the 2026 Bonds (the "Preliminary Official Statement"). See "DISCLOSURE INFORMATION" herein. The 2026 Bonds will be issued as fully registered bonds, and when executed and delivered, will be registered in the name of Cede & Co., as registered owner and nominee for The Depository Trust Company ("DTC"), which will act as securities depository for the 2026 Bonds. Individual purchases of the 2026 Bonds may be made only in book -entry form in denominations of $5,000 or integral multiples thereof. Purchasers of the 2026 Bonds (the "Beneficial Owners") will not receive physical delivery of bond certificates. As long as Cede & Co. is the registered owner of the 2026 Bonds as nominee for DTC, payments of principal and interest with respect to the 2026 Bonds will be made directly to such registered owner who will in turn remit such principal and interest payments to DTC participants for subsequent disbursement to the Beneficial Owners. The Issuer will not be responsible for payments to Beneficial Owners. The 2026 Bonds will be dated their date of delivery (expected to be [July 11, 2026) or such other date as may be communicated through Refinitiv TM3 at the internet website * Preliminary, subject to change. address www.tm3.com not less than 20 hours prior to the time bids are to be received, and shall bear interest from such date and shall be payable semiannually commencing on January 1, 2027, and on each July 1 and January 1 thereafter until maturity at the rate or rates specified in such proposals as may be accepted. The proposed schedule of maturities and amounts are as follows: INITIAL MATURITY SCHEDULE FOR THE 2026 BONDS Maturity Principal (July 1) Amount* 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 Preliminary, subject to change. Term Bond Option as described herein. NOTE: The Issuer reserves the right to modify the maturity schedule shown above. Any such modification will be communicated through the Refinitiv TM3 (See, "ADJUSTMENT OF PRINCIPAL AMOUNTS" below.) PAYING AGENT AND REGISTRAR The Paying Agent and Registrar for the 2026 Bonds will be U.S. Bank Trust Company, National Association, Jacksonville, Florida. 2 ADJUSTMENT OF PRINCIPAL AMOUNTS The schedule of maturities set forth above (the "Initial Maturity Schedule") represents an estimate of the principal amount and maturities of the 2026 Bonds that will be sold. The Issuer reserves the right to change the Initial Maturity Schedule by announcing any such change not later than 3:00 P.M., Eastern time, on the business day immediately preceding the date set for receipt of bids, through Refinitiv TM3 at the internet website address www.tm3.com. If no such change is announced, the Initial Maturity Schedule will be deemed the schedule of maturities for submission of the bid. Furthermore, if after final computation of the bids, the Issuer determines in its sole discretion that the funds necessary to accomplish the purpose of the 2026 Bonds is more or less than the proceeds of the sale of all of the 2026 Bonds, the Issuer reserves the right to increase or decrease the principal amount, by no more than [ 15% of the principal amount of the 2026 Bonds, or 25%] within a given maturity of the 2026 Bonds (to be rounded to the nearest $5,000) or by such other amount as approved by the winning bidder; provided, that the aggregate principal amount of the 2026 Bonds may not exceed $[PAR AMOUNT]. In the event of any such adjustment, no rebidding or recalculation of the bids submitted will be required or permitted; and the 2026 Bonds of each maturity, as adjusted, will bear interest at the same rate and must have the same initial reoffering yield as specified immediately after award of the 2026 Bonds of that maturity, and the Underwriter's Discount on the 2026 Bonds as submitted by the successful bidder shall be held constant. The "Underwriter's Discount" shall be defined as the difference between the purchase price of the 2026 Bonds submitted by the bidder and the price at which the 2026 Bonds will be issued to the public, less any bond insurance premium to be paid by the successful bidder, calculated from information provided by the bidder, divided by the par amount of the 2026 Bonds bid. However, the award will be made to the bidder whose bid produces the lowest True Interest Cost ("TIC"), calculated as specified herein, solely on the basis of the 2026 Bonds offered, without taking into account any adjustment in the amount of 2026 Bonds pursuant to this paragraph. REDEMPTION PROVISIONS The 2026 Bonds maturing on or before July 1, 2036 will not be subject to optional redemption prior to maturity. The 2026 Bonds maturing on July 1, 2037 and thereafter are redeemable at the option of the County from any legally available source, in whole or in part and if in part, in any order of maturity selected by the County, at its discretion, and by lot within a maturity if less than an entire maturity is to be redeemed, on July 1, 2036, or at any time thereafter, at a redemption price equal to the principal amount of the 2026 Bonds to be redeemed, together with accrued interest to the date fixed for redemption. 9 TERM BONDS OPTIONS Any bidder may, at its option, specify that the maturities of the 2026 Bonds maturing after July 1, 20_ will consist of term bonds which are subject to mandatory sinking fund redemption in consecutive years immediately preceding the maturity thereof (each a "Term Bond") as designated in the bid of such bidder. In the event that the bid of the successful bidder specifies that a permitted maturity of the 2026 Bonds will be a Term Bond, such Term Bond will be subject to mandatory sinking fund redemption on July 1 in each applicable year, in the principal amount for such year as set forth hereinbefore under the heading "INITIAL MATURITY SCHEDULE FOR THE 2026 BONDS," at a redemption price equal to the principal amount thereof to be redeemed together with accrued interest thereon to the redemption date, without premium. AUTHORITY AND PURPOSE The 2026 Bonds are being issued under the authority of the Florida Constitution, Chapter 166.021, Florida Statutes, and other applicable provisions of law (collectively, the "Act"), and Resolution No. 2023-004, adopted by the Board of County Commissioners of the County on January 31, 2023, as supplemented, particularly as supplemented by Resolution No. 2026- , adopted by the Board of County Commissioners of the County on May 19, 2026 (the "Resolution"). The 2026 Bonds are being issued for the purpose of financing the acquisition and preservation of environmentally sensitive lands and the construction of public access improvements with respect thereto in and for the Issuer. SECURITY The 2026 Bonds are secured by the full faith and credit of the County, which has covenanted to levy an ad valorem tax without limitation as to rate or amount to pay principal and interest on the 2026 Bonds. MUNICIPAL BOND INSURANCE OPTION The purchase of municipal bond insurance, if available, will be at the option and expense of the bidder. The successful bidder will be responsible for the payment of all costs associated with any such insurance, including the premium charged by the insurer, and the County will not be obligated to enter into any covenants or agreements with the insurer. Each bidder should indicate whether municipal bond insurance has been purchased and provide the name of the insurer. The bidder understands, by submission of its bid, that the bidder is solely responsible for the selection of any insurer and for all negotiations with the insurer as to the premium to be paid. If all or a portion of the Series 2026 Bonds are awarded on an insured basis, reference to the insurance policy will appear on the Series 2026 Bonds and in the Official Statement; however, the provisions of the financing documents will not be altered nor will the County consent to make additional representations, undertakings or n warranties. The failure of an insurer to issue its policy shall not constitute cause for a failure or refusal by the successful bidder to accept delivery of or pay for the Series 2026 Bonds. In the event of such failure, the County shall supplement or amend the Official Statement and the responsibility for paying the cost of printing and mailing such supplement or amendment shall be borne solely by the successful bidder. In addition, if the successful bidder is arranging for bond insurance for all or a portion of the Series 2026 Bonds, it also shall provide the amount of the premium to be paid and certification that the present value of the premium is less than the present value of the interest reasonably expected to be saved as a result of the insurance and that the premium does not exceed a reasonable arms -length charge for the transfer of credit risk accomplished through the bond insurance. Insured ratings with the use of bond insurance, if required, are to be applied for by the successful bidder, and costs incurred for such ratings must be paid at the successful bidder's expense. RATING S&P Global Ratings, a division of Standard and Poor's Financial Services LLC has assigned a municipal bond rating of "_" ( outlook) to the 2026 Bonds. TERMS OF BID AND BASIS OF AWARD Proposals must be unconditional and for the purchase of all of the 2026 Bonds. The aggregate purchase price, inclusive of original issue discount ("OID"), original issue premium ("OIP") and underwriter's discount, may not be less than 100% of the principal amount of the 2026 Bonds. The reoffering price of the 2026 Bonds may not be less than 98% of the principal amount of the 2026 Bonds for any single maturity thereof. The 2026 Bonds shall bear interest expressed in multiples of one-eighth (1/8) or one -twentieth (1/20) of one (1) per centum. The use of split or supplemental interest coupons will not be considered and a zero rate or blank rate will not be permitted. All 2026 Bonds maturing on the same date shall bear the same rate of interest. The 2026 Bonds will be awarded to the bidder offering to purchase the 2026 Bonds at the lowest annual interest cost computed on a TIC basis. The annual TIC will be determined by doubling the semi-annual interest rate (compounded semi-annually) necessary to discount the debt service payments on the 2026 Bonds from the payment dates to the Closing Date (as defined below) and to the aggregate purchase price bid on the 2026 Bonds, calculated on a 360 day year consisting of twelve 30 -day months. The TIC must be calculated to six (6) decimal places. If more than one bid offers the same lowest TIC, the successful bid will be selected by lot from among all such bids. NO BID SHALL BE ACCEPTED WITH A TIC GREATER THAN 5.00%. THE ISSUER RESERVES THE RIGHT TO REJECT ALL BIDS OR ANY BID NOT CONFORMING TO THIS OFFICIAL NOTICE OF SALE. THE ISSUER ALSO W RESERVES THE RIGHT TO WAIVE, IF PERMITTED BY LAW, ANY IRREGULARITY OR INFORMALITY IN ANY PROPOSAL. THE ISSUER SHALL NOT REJECT ANY CONFORMING BID, UNLESS ALL CONFORMING BIDS ARE REJECTED. GOOD FAITH DEPOSIT If the County selects a winning bid, then the successful bidder must submit a "Good Faith Deposit" (the "Deposit") to the County in the form of a wire transfer in the amount of $ not later than 5:00 P.M., Eastern time, on the date of the award. The Deposit of the successful bidder will be collected and the proceeds thereof retained by the Issuer to be applied as partial payment for the 2026 Bonds and no interest will be allowed or paid upon the amount thereof, but in the event the successful bidder shall fail to comply with the terms of the bid, the proceeds thereof will be retained as and for full liquidated damages. ANTI-HUMAN TRAFFICKING AFFIDAVIT OF THE PURCHASER Section 787.06(13), Florida Statutes, requires the successful bidder to provide an affidavit to the County, under penalty of perjury, attesting that such successful bidder does not use coercion for labor or services as defined in Section 787.06, Florida Statutes. The successful bidder will be required to submit an Anti -Human Trafficking Affidavit (the form of which is attached hereto as Exhibit A-3) to the County, by email at [enagy@indianriverclerk.coml, with a copy to joel.tindal@hilltopsecurities.com, in connection with the official award. STANDARD FILINGS, CHARGES AND CLOSING DOCUMENTS The winning bidder will be required to make the standard filings and maintain the appropriate records routinely required pursuant to MSRB Rules G-8, G-11 and G-36. The winning bidder will be required to pay the standard MSRB charge for the 2026 Bonds purchased. In addition, those who are members of SIFMA will be required to pay SIFMA's standard charge per bond. The winning bidder will also be required to execute certain closing documents required by Florida law or required by Bond Counsel (as defined below) in connection with the delivery of its tax opinion. See "DISCLOSURE; AMENDMENTS TO NOTICE OF SALE; NOTIFICATION OBLIGATIONS OF PURCHASER" herein. CUSIP NUMBERS The Issuer will assume no obligation for the assignment of CUSIP numbers to the 2026 Bonds or for the correctness of any such numbers printed thereon, but the Issuer will permit such printing to be done at the expense of the purchaser, provided that such printing does not result in any delay of the date of delivery of the 2026 Bonds. Hilltop Securities Inc. (the "Financial Advisor") will request the assignment of CUSIP numbers prior to the sale of the 2026 Bonds. .1 DELIVERY OF THE 2026 BONDS The Issuer will pay the cost of preparing the 2026 Bonds. The successful bidder is responsible for DTC eligibility and related DTC costs. Delivery of and payment for the 2026 Bonds will be via DTC Fast on or about [July 11, 2026 (the "Closing Date") in New York, New York, or such other time and place mutually acceptable to the successful bidder and the Issuer. Payment of the full purchase price, less the Deposit, shall be made to the Issuer not later than 12:00 P.M., Eastern time on the Closing Date, in Federal Reserve Funds of the United States of America, without cost to the Issuer. The legal opinion of Nabors, Giblin & Nickerson, P.A. ('Bond Counsel") will be furnished without charge to the successful bidder at the time of delivery of the 2026 Bonds. For a further discussion of the content of that opinion and the proposed form of the approving opinion, see the Preliminary Official Statement for the 2026 Bonds. There will also be furnished at the time of delivery of the 2026 Bonds, a certificate or certificates of the Issuer (which may be included in a consolidated closing certificate) relating to the accuracy and completeness of the Official Statement; and stating, among other things, that there is no litigation or administrative action or proceeding pending or, to the knowledge of the Issuer, threatened, at the time of delivery of the 2026 Bonds, (a) to restrain or enjoin or seeking to restrain or enjoin the issuance and delivery of the 2026 Bonds or (b) affecting the validity of the 2026 Bonds, and that the Preliminary Official Statement has been deemed by the Issuer to be a "final official statement" for purposes of SEC Rule 15c2 -12(b)(3) and (4). The successful bidder will be responsible for the clearance or exemption with respect to the status of the 2026 Bonds for sale under the securities or 'Blue Sky" laws of the several states and the preparation of any surveys or memoranda in connection with such sale. ESTABLISHMENT OF ISSUE PRICED) The winning bidder shall assist the Issuer in establishing the issue price of the 2026 Bonds and shall execute and deliver to the Issuer on or prior to the closing date for the 2026 Bonds an "issue price" or similar certificate setting forth the reasonably expected initial offering prices to the public or the actual sales price or prices of the 2026 Bonds, together with the supporting pricing wires or equivalent communications, substantially in the applicable form attached hereto as Exhibit A-2, with such modifications as may be appropriate or necessary, in the reasonable judgment of the winning bidder, the Issuer and Bond Counsel. Note: 10% or Hold -the -Offering -Price Rule may apply if Competitive Sale Requirements are not satisfied. 7 The Issuer intends that the provisions of Treasury Regulation Section 1.148- 1(f)(3)(i) (defining "competitive sale" for purposes of establishing the issue price of the 2026 Bonds) will apply to the initial sale of the 2026 Bonds ("competitive sale requirements") because: 1. the Issuer has disseminated this Official Notice of Sale to potential underwriters in a manner that is reasonably designed to reach potential underwriters; 2. all bidders shall have an equal opportunity to bid; 3. the Issuer may receive bids from at least three underwriters of municipal bonds who have established industry reputations for underwriting new issuances of municipal bonds; and 4. the Issuer anticipates awarding the sale of the 2026 Bonds to the bidder who submits a firm offer to purchase the 2026 Bonds at the lowest true interest cost, as set forth in this Official Notice of Sale. Any bid submitted pursuant to this Official Notice of Sale shall be considered a firm offer for the purchase of the 2026 Bonds, as specified in the bid. BY SUBMITTING A BID FOR THE 2026 BONDS, A BIDDER REPRESENTS AND WARRANTS TO THE ISSUER THAT THE BIDDER HAS AN ESTABLISHED INDUSTRY REPUTATION FOR UNDERWRITING NEW ISSUANCES OF MUNICIPAL BONDS SUCH AS THE 2026 BONDS AND SUCH BIDDER'S BID IS SUBMITTED FOR AND ON BEHALF OF SUCH BIDDER BY AN OFFICER OR AGENT WHO IS DULY AUTHORIZED TO BIND THE BIDDER TO A LEGAL, VALID AND ENFORCEABLE CONTRACT FOR THE PURCHASE OF THE 2026 BONDS. Once the bids are communicated electronically via Parity® to the Issuer, each bid will constitute an irrevocable offer to purchase the 2026 Bonds on the terms herein and therein provided. In the event that the competitive sale requirements are not satisfied, the Issuer shall so advise the winning bidder. In such case, the Issuer shall treat (i) the first price at which 10% of a maturity of the 2026 Bonds is sold to the public (the "10% test") as the issue price of that maturity, and/or (ii) the initial offering price to the public as of the sale date of any maturity of the 2026 Bonds as the issue price of that maturity (the "hold -the -offering -price rule"), in each case applied on a maturity -by -maturity basis. The winning bidder shall advise the Issuer if any maturity of the 2026 Bonds satisfies the 10% test as of the date and time of the award of the 2026 Bonds. The Issuer will promptly advise the winning bidder, at or before the time of award of the 2026 Bonds, which maturities of the 2026 Bonds shall be subject to the 10% test or shall be subject to the hold -the -offering -price rule. Bids will not be subject to cancellation in the event that the Issuer determines to apply the hold -the - offering -price rule to any maturity of the 2026 Bonds. Bidders should prepare their bids on the assumption that some or all of the maturities of the 2026 Bonds will be subject to the hold -the -offering -price rule in order to establish the issue price of the 2026 Bonds. By submitting a bid, the winning bidder shall confirm (i) that it and all other underwriters that are participating in the winning bidder's bid have offered or will offer the 2026 Bonds to the public on or before the date of award at the offering price or prices (the "initial offering price"), or at the corresponding yield or yields, set forth in the bid submitted by the winning bidder and (ii) agree, on behalf of itself and all other underwriters participating in the winning bidder's bid for the purchase of the 2026 Bonds, that the underwriters will neither offer nor sell unsold 2026 Bonds of any maturity to which the hold -the -offering -price rule shall apply to any person at a price that is higher than the initial offering price to the public during the period starting on the sale date and ending on the earlier of the following: (a) the close of the fifth (5th) business day after the sale date; or (b) the date on which the underwriters have sold at least 10% of that maturity of the 2026 Bonds to the public at a price that is no higher than the initial offering price to the public. The winning bidder will advise the Issuer promptly after the close of the fifth (5th) business day after the sale date whether it has sold 10% of that maturity of the 2026 Bonds to the public at a price that is no higher than the initial offering price to the public. If the competitive sale requirements are not satisfied, then until the 10% test has been satisfied as to each maturity of the 2026 Bonds, the winning bidder agrees to promptly report to the Issuer the prices at which the unsold 2026 Bonds of that maturity have been sold to the public. That reporting obligation shall continue, whether or not the Closing Date has occurred, until either (i) all the 2026 Bonds of that maturity have been sold or (ii) the 10% test has been satisfied as to the 2026 Bonds of that maturity, provided that, the winning bidder's reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Issuer or Bond Counsel. The Issuer acknowledges that, in making the representations set forth above, the winning bidder will rely on (i) the agreement of each underwriter to comply with the requirements for establishing the issue price of the 2026 Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the 2026 Bonds, as set forth in an agreement among underwriters and the related pricing wires, (ii) in the event a selling group has been created in connection with the initial sale of the 2026 Bonds to the public, the agreement of each dealer who is a member of the selling group to comply with the requirements for establishing the issue price of the 2026 Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the 2026 Bonds, as set forth in a selling group agreement and the related pricing wires, and (iii) in the event that an underwriter or dealer who is a member of the selling group is a party to a third -party distribution agreement that was employed in connection with the initial sale of the 2026 Bonds to the public, the agreement of each broker-dealer that is a party to such agreement to comply with the requirements for establishing the issue price of the 2026 Bonds, including, but not limited to, its agreement L9 to comply with the hold -the -offering -price rule, if applicable to the 2026 Bonds, as set forth in the third -party distribution agreement and the related pricing wires. The Issuer further acknowledges that each underwriter shall be solely liable for its failure to comply with its agreement regarding the requirements for establishing the issue price of the 2026 Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the 2026 Bonds, and that no underwriter shall be liable for the failure of any other underwriter, or of any dealer who is a member of a selling group, or of any broker-dealer that is a party to a third -party distribution agreement to comply with its corresponding agreement to comply with the requirements for establishing the issue price of the 2026 Bonds, including, but not limited to, its agreement to comply with the hold - the -offering -price rule if applicable to the 2026 Bonds. By submitting a bid, each bidder confirms that: (i) any agreement among underwriters, any selling group agreement and each third -party distribution agreement (to which the bidder is a party) relating to the initial sale of the 2026 Bonds to the public, together with the related pricing wires, contains or will contain language obligating each underwriter, each dealer who is a member of the selling group, and each broker-dealer that is a party to such retail distribution agreement, as applicable: (A) (1) to report the prices at which it sells to the public the unsold 2026 Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all 2026 Bonds of that maturity allocated to it have been sold or until it is notified by the winning bidder that the 10% test has been satisfied as to the 2026 Bonds of that maturity, provided that the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the winning bidder and (2) to comply with the hold -the -offering -price rule, if applicable, if and for so long as directed by the winning bidder and as set forth in the related pricing wires; (B) to promptly notify the winning bidder of any sales of 2026 Bonds that, to its knowledge, are made to a purchaser who is a related party to an underwriter participating in the initial sale of the 2026 Bonds to the public (each such term being used as defined below); and (C) to acknowledge that, unless otherwise advised by the underwriter, dealer or broker-dealer, the winning bidder shall assume that each order submitted by the underwriter, dealer or broker-dealer is a sale to the public. (ii) any agreement among underwriters or selling group agreement relating to the initial sale of the 2026 Bonds to the public, together with the related pricing wires, contains or will contain language obligating each underwriter or dealer that is a party to a third -party distribution agreement to be employed in 10 connection with the initial sale of the 2026 Bonds to the public to require each broker-dealer that is a party to such third -party distribution agreement to (A) report the prices at which it sells to the public the unsold 2026 Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all 2026 Bonds of that maturity allocated to it have been sold or it is notified by the winning bidder or such underwriter that the 10% test has been satisfied as to the 2026 Bonds of that maturity, provided that the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the winning bidder or such underwriter and (B) comply with the hold -the -offering -price rule, if applicable, if and for so long as directed by the winning bidder or the underwriter and as set forth in the related pricing wires. Sales of any 2026 Bonds to any person that is a related party to an underwriter shall not constitute sales to the public for purposes of this Official Notice of Sale. Further, for purposes of this Official Notice of Sale: (i) "public" means any person other than an underwriter or a related party, (ii) "underwriter" means (A) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the 2026 Bonds to the public and (B) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (A) to participate in the initial sale of the 2026 Bonds to the public (including a member of a selling group or a party to a retail distribution agreement participating in the initial sale of the 2026 Bonds to the public), (iii) a purchaser of any of the 2026 Bonds is a "related party" to an underwriter if the underwriter and the purchaser are subject, directly or indirectly, to (i) more than 50% common ownership of the voting power or the total value of their stock, if both entities are corporations (including direct ownership by one corporation of another), (ii) more than 50% common ownership of their capital interests or profits interests, if both entities are partnerships (including direct ownership by one partnership of another), or (iii) more than 50% common ownership of the value of the outstanding stock of the corporation or the capital interests or profit interests of the partnership, as applicable, if one entity is a corporation and the other entity is a partnership (including direct ownership of the applicable stock or interests by one entity of the other), and (iv) "sale date" means the date that the 2026 Bonds are awarded by the Issuer to the winning bidder. 11 DISCLOSURE; AMENDMENTS TO NOTICE OF SALE; NOTIFICATION OBLIGATIONS OF PURCHASER This Official Notice of Sale is not intended as a disclosure document and bidders are required to obtain and carefully review the Preliminary Official Statement before submitting a bid. This Official Notice of Sale may be amended from time to time after its initial publication by publication of amendments thereto not less than 20 hours prior to the bid date and time through Refinitiv TM3 at the internet website address www.tm3.com. Each bidder will be charged with the responsibility of obtaining any such amendments and complying with the terms thereof. Prior to delivery of the 2026 Bonds to the successful bidder, the successful bidder shall file with the Issuer a statement as described in Section 218.38(1)(c)2, Florida Statutes, containing the underwriting spread (including management fee, if any), and the amount of any fee, bonus or gratuity paid in connection with the 2026 Bonds to any person not regularly employed by the successful bidder. This statement shall be filed with the Issuer even if no such management fee or underwriting spread has been charged by the successful bidder or no such fee, bonus or gratuity has been paid by the successful bidder, and such filing shall be a condition precedent to the delivery of the 2026 Bonds by the Issuer to the successful bidder. The successful bidder, by submitting its bid, agrees to furnish to the Issuer and Bond Counsel a certificate verifying information as to the bona fide initial offering prices or yields of the 2026 Bonds to the public and sales of the 2026 Bonds appropriate for determination of the issue price of, and the yield on, the 2026 Bonds under the Internal Revenue Code of 1986, as amended, in the form attached hereto as Exhibit A-2, and such other documentation as and at the time requested by Bond Counsel. The successful bidder shall also verify its winning bid in writing to the Issuer by executing a printed copy of its winning bid as reported on Parity®. The winning bidder is required to provide a Truth in Bonding Statement pursuant to Section 218.385, Florida Statutes, and to disclose the payment of any "finder's fee" pursuant to Section 218.386, Florida Statutes, prior to the award of the 2026 Bonds, as set forth in Exhibit A-1 to this Official Notice of Sale. OFFICIAL STATEMENT The Issuer shall furnish at its expense within seven (7) business days after the 2026 Bonds have been awarded to the successful bidder, or at least five (5) business days before the Closing Date, whichever is earlier, a reasonable number of copies of the final Official Statement, which, in the judgment of the Financial Advisor to the County will permit the 12 successful bidder to comply with applicable SEC and MSRB rules. The successful bidder may arrange for additional copies of the final Official Statement at its expense. CONTINUING DISCLOSURE In order to assist bidders in complying with SEC Rule 15c2-12, the Issuer will undertake to provide, or cause to be provided, certain financial information and operating data and to provide notices of certain events, if material. Such information will be filed with the Municipal Securities Rulemaking Board through its Electronic Municipal Market Access System. A summary of such undertaking is contained in the Preliminary Official Statement. DISCLOSURE INFORMATION Copies of the Preliminary Official Statement "deemed final" (except for permitted omissions) by the Issuer in accordance with SEC Rule 15c2-12 must be obtained from the Financial Advisor, Hilltop Securities Inc., 450 South Orange Avenue, Suite 225, Orlando, Florida 32801, (407) 426-9611 before a bid is submitted. The Issuer's Preliminary Official Statement and Official Notice of Sale are also available for viewing in electronic format at www.munios.com. CHOICE OF LAW Any litigation or claim arising out of any bid submitted (regardless of the means of submission) pursuant to this Official Notice of Bond Sale shall be governed by and construed in accordance with the laws of the State of Florida. The venue situs for any such action shall be the state courts of the Nineteenth Judicial Circuit in and for Indian River County, Florida. [Remainder of page intentionally left blank] 13 NOTICE OF BIDDERS REGARDING PUBLIC ENTITY CRIMES A person or affiliate who has been placed on the convicted vendor list following a conviction for a public entity crime may not submit a bid on a contract to provide any goods or services to a public entity, may not submit a bid on a contract with a public entity for the construction or repair of a public building or public work, may not submit bids on leases of real property to a public entity, may not be awarded or perform work as a contractor, supplier, subcontractor, or consultant under a contract with any public entity, and may not transact business with any public entity in excess of the threshold amount provided in Section 287.017, for CATEGORY TWO for a period of 36 months from the date of being placed on the convicted vendor list. INDIAN RIVER COUNTY, FLORIDA By: /s/John A. Titkanich, Jr. John A. Titkanich, Jr., County Administrator 14 EXHIBIT A-1 TRUTH -IN -BONDING STATEMENT AND DISCLOSURE In compliance with Section 218.385, Florida Statutes, as amended, the undersigned bidder submits the following Truth -In -Bonding Statement with respect to the Indian River County, Florida General Obligation Bonds, Series 2026 (the "Bonds") (NOTE: For information purposes only and not a part of the bid): Indian River County, Florida (the "Issuer") is proposing to issue $ * of the Bonds for the purpose of financing the acquisition and preservation of environmentally sensitive lands and the construction of public access improvements with respect thereto within the County. The Bonds are expected to be repaid over a period of approximately years. At a forecasted interest rate of %, total interest paid over the life of the Bonds will be $ The source of repayment or security for the Bonds is a pledge of the full faith and credit of the Issuer, as more fully described in the Preliminary Official Statement and Official Notice of Sale. In compliance with Section 218.386, Florida Statutes, the undersigned, on behalf of itself and all other members of the underwriting group, if any, hereby certifies that neither it nor any member of the underwriting group have paid any "finder's fees" as defined in Section 218.386, Florida Statutes, or any bonus, fee or gratuity in connection with the sale of the Bonds, except as provided below: Bidder's Name: By: Title: Date: * Preliminary, subject to change. EXHIBIT A-2 CERTIFICATE WITH RESPECT TO "ISSUE PRICE" The undersigned, on behalf of [UNDERWRITER] ("[UNDERWRITER SHORT NAME] "), hereby represents and warrants that it has an established industry reputation for underwriting new issuances of municipal bonds and certifies as set forth below with respect to the sale of the above -captioned obligations (the 'Bonds"). [Alternate 1 - Competitive Safe Harbor Met] 1. Reasonably Expected Initial Offering Price. (a) As of the Sale Date, the reasonably expected initial offering prices of the Bonds to the Public by [UNDERWRITER SHORT NAME] are the prices listed in Schedule A (the "Expected Offering Prices"). The Expected Offering Prices are the prices for the Maturities of the Bonds used by [UNDERWRITER SHORT NAME] in formulating its bid to purchase the Bonds. Attached as Schedule B are true and correct copies of the bid provided by [UNDERWRITER SHORT NAME] to purchase the Bonds and the pricing wire or equivalent communication for the Bonds. (b) [UNDERWRITER SHORT NAME] was not given the opportunity to review other bids prior to submitting its bid. (c) The bid submitted by [UNDERWRITER SHORT NAME] constituted a firm offer to purchase the Bonds. [Alternate 2 — If all Maturities use General Rule] 1. Sale of Bonds under General Rule. (a) As of the date of this certificate, for each Maturity of the Bonds, the first price at which at least 10% of such Maturity of the Bonds was sold to the Public is the respective price listed in Schedule A. [Alternate 3 — If select Maturities use General Rule] Sale of Bonds under General Rule (Select Maturities). (a) As of the date of this certificate, for each Maturity of the General Rule Maturities, the first price at which at least 10% of such Maturity of the Bonds was sold to the Public is the respective price listed in Schedule A. (b) [UNDERWRITER SHORT NAME] offered the Hold -the -Offering -Price Maturities to the public for purchase at the respective initial offering prices listed in F.-VA51 Schedule A (the "Initial Offering Prices") on or before the Sale Date. A copy of the pricing wire or equivalent communication for the Bonds is attached to this certificate as Schedule B. (c) As set forth in the Official Notice of Sale and bid award, [UNDERWRITER SHORT NAME] has agreed in writing that, (i) for each Maturity of the Hold -the -Offering - Price Maturities, it would neither offer nor sell any of the Bonds of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the "hold -the -offering -price rule"), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any retail distribution agreement shall contain the agreement of each broker- dealer who is a party to the retail distribution agreement, to comply with the hold -the - offering -price rule. Pursuant to such agreement, no Underwriter (as defined below) has offered or sold any Maturity of the Hold -the -Offering -Price Maturities at a price that is higher than the respective Initial Offering Price for that Maturity of the Bonds during the Holding Period. [Alternate 4 — If all Maturities Hold -the -Offering -Price Rule] 1. Sale of Bonds under Hold -the -Offering -Price Rule. (a) [UNDERWRITER SHORT NAME] offered the Bonds to the Public for purchase at the respective initial offering prices listed in Schedule A (the "Initial Offering Prices") on or before the Sale Date. A copy of the pricing wire or equivalent communication for the Bonds is attached to this certificate as Schedule B. (b) As set forth in the Official Notice of Sale and bid award, [UNDERWRITER SHORT NAME] has agreed in writing that, (i) for each Maturity of the Bonds, it would neither offer nor sell any of the Bonds of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the "hold -the -offering -price rule"), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any retail distribution agreement, to comply with the hold -the -offering -price rule. Pursuant to such agreement, no Underwriter (as defined below) has offered or sold any Maturity of the Bonds at a price that is higher than the respective Initial Offering Price for that Maturity of the Bonds during the Holding Period. 2. Total Issue Price. The total of the issue prices of all Maturities is 3. Defined Terms. (a) General Rule Maturities means those Maturities of the Bonds listed in Schedule A hereto as the "General Rule Maturities." A-2-2 (b) Hold -the -Offering -Price Maturities means those Maturities of the Bonds listed in Schedule A hereto as the "Hold -the -Offering -Price Maturities." (c) Holding Period means, with respect to a Hold -the -Offering -Price Maturity, the period starting on the Sale Date and ending on the earlier of (i) the close of the fifth business day after the Sale Date ([June 111, 2026), or (ii) the date on which [UNDERWRITER SHORT NAME] sold at least 10% of such Hold -the -Offering -Price Maturity to the Public at prices that are no higher than the Initial Offering Price for such Hold -the -Offering -Price Maturity. (d) Issuer means Indian River County, Florida. (e) Maturity means Bonds with the same credit and payment terms. Bonds with different maturity dates, or Bonds with the same maturity date but different stated interest rates, are treated as separate Maturities. (f) Public means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter. The term "related party" for purposes of this certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. (g) Sale Date means the first day on which there is a binding contract in writing for the sale of a Maturity of the Bonds. The Sale Date of the Bonds is [June 11 ], 2026. (h) Underwriter means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Bonds to the Public (including a member of a selling group or a party to a retail distribution agreement participating in the initial sale of the Bonds to the Public). The representations set forth in this certificate are limited to factual matters only. Nothing in this certificate represents [UNDERWRITER SHORT NAME]'s interpretation of any laws, including specifically Sections 103 and 148 of the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the Certificate as to Arbitrage and Certain Other Tax Matters relating to the Bonds and with respect to compliance with the federal income tax rules affecting the Bonds, and by Nabors, Giblin & Nickerson, P.A. in connection with rendering its opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other A-2-3 federal income tax advice that it may give to the Issuer from time to time relating to the Bonds. Dated: 12026 [Name] A-2-4 SCHEDULEI EXPECTED OFFERING PRICES OR PRICES OF GENERAL RULE MATURITIES AND HOLD -THE -OFFERING PRICE MATURITIES SCH 1-1 SCHEDULE 2 COPY OF UNDERWRITER'S BID AND PRICING WIRE SCH 2-1 EXHIBIT A-3 NONGOVERNMENTAL ENTITY ANTI-HUMAN TRAFFICKING AFFIDAVIT Section 787.06(13), Florida Statutes $[PAR AMOUNT] INDIAN RIVER COUNTY, FLORIDA GENERAL OBLIGATION BONDS, SERIES 2026 I, the undersigned, am an officer or representative of [UNDERWRITER] and attest that said entity does not use coercion for labor or services as defined in Section 787.06, Florida Statutes. Under penalty of perjury, I hereby declare and affirm, to the best of my knowledge and belief, that the above stated facts are true and correct. [UNDERWRITER] [Name], [Title] STATE OF COUNTY OF SWORN TO AND SUBSCRIBED before me by means of ❑ physical presence or ❑ online notarization this —day of 2026, by [Name] as [Title] on behalf of [UNDERWRITER]. He/she is ❑ personally known to me or ❑ has produced (Type of Identification) as identification. (Notary Seal) A-3-1 Signature of Notary Public Print, Type or Stamp Name of Notary Serial Number, if any EXHIBIT C FORM OF PRELIMINARY OFFICIAL STATEMENT PRELIMINARY OFFICIAL STATEMENT DATED [JUNE] _, 2026 NEW ISSUE - BOOK -ENTRY ONLY See "RATING" herein In the opinion of Nabors, Giblin & Nickerson, P.A., Tampa, Florida, Bond Counsel, under existing statutes, regulations, rulings and court decisions and subject to the conditions described herein under "TAX MATTERS, " interest on the Series 2026 Bonds is (a) excludable from gross income of the owners thereof for federal income tax purposes except as otherwise described herein under the caption "TAX MATTERS, " and (b) not an item of tax preference for purposes of the federal alternative minimum tax; provided, however, with respect to certain corporations, interest on the Series 2026 Bonds is taken into account in determining the annual adjusted financial statement income for the purpose of computing the alternative minimum tax imposed on such corporations. Such interest, however, may be subject to other federal income tax consequences referred to herein under "TAX MATTERS." See "TAX MATTERS" herein for a general discussion of Bond Counsel's opinion and other tax considerations. $[PAR AMOUNT]* Y, INDIAN RIVER COUNTY, FLORIDA GENERAL OBLIGATION BONDS, SERIES 2026 �.ORI� Dated: Date of Delivery Due: July 1, as shown on inside cover The Indian River County, Florida General Obligation Bonds, Series 2026 (the "Series 2026 Bonds") will be issued by Indian River County, Florida (the "County") as fully registered bonds in denominations of $5,000 and integral multiples thereof. Interest on the Series 2026 Bonds will be payable semiannually on each January 1 and July 1, commencing on [January 1, 2027], by check or draft of U.S. Bank Trust Company, National Association, as Paying Agent, to the registered owner thereof or by electronic means. Principal of and redemption premium, if any, on the Series 2026 Bonds is payable upon presentation and surrender at the principal corporate trust office of the Paying Agent. The Series 2026 Bonds initially will be registered in the name of Cede & Co., as registered owner and nominee for The Depository Trust Company ("DTC"), which will act as securities depository for the Series 2026 Bonds. Series 2026 Bonds will be available to purchasers under the book -entry system maintained by DTC through brokers and dealers who are, or act through, Direct Participants (as defined herein). Purchasers of the Series 2026 Bonds (the "Beneficial Owners") will not receive physical delivery of bond certificates. Ownership by the Beneficial Owners of the Series 2026 Bonds will be evidenced by book -entry only. As long as Cede & Co. is the registered owner as nominee of DTC, payments of principal, interest and premium, if any, will be made directly to such registered owner which will in turn remit such payments to the Direct Participants for subsequent disbursement to the Beneficial Owners. See "DESCRIPTION OF THE SERIES 2026 BONDS — Book Entry Only System" herein. The Series 2026 Bonds are being issued for the purposes of (1) financing costs of the acquisition and preservation of certain environmentally sensitive lands, and the construction of public access improvements with respect thereto, as described in the plans and specifications on file with the County, and (2) paying certain costs and expenses relating to the issuance of the Series 2026 Bonds. The Series 2026 Bonds are being issued by the County under the authority of Article VII, Section 12 of the Constitution of the State of Florida, Chapter 125, Florida Statutes, and other applicable provisions of law, and pursuant to Resolution No. 2023-004 adopted by the Board of County Commissioners of the County on January 31, 2023, as supplemented, particularly as supplemented by Resolution No. 2026-[] adopted by the Board on [May 19], 2026 (collectively, the 'Bond Resolution"). The issuance of certain general obligation bonds such as the Series 2026 Bonds was approved by a majority of the qualified electors of the County voting in a bond referendum held on November 8, 2022 and validated by a judgment of the Circuit Court of the Nineteenth Judicial Circuit of the State of Florida, in and for the County, on April 27, 2023. The Series 2026 Bonds are subject to redemption prior to their stated maturities, as more particularly described herein. See "DESCRIPTION OF THE SERIES 2026 BONDS — Redemption Provisions" herein. The Series 2026 Bonds are general obligation bonds of the County to which the full faith, credit and taxing power of the County are irrevocably pledged in the manner and to the extent described in the Bond Resolution. The Series 2026 Bonds are payable from ad valorem taxes levied without limitation as to rate or amount on all taxable property within the County sufficient in amount to pay the principal of and interest on the Series 2026 Bonds. See "SECURITY FOR THE SERIES 2026 BONDS" herein. SEE INSIDE COVER PAGE FOR THE MATURITY SCHEDULE This cover page and the inside cover page contains certain information for quick reference only. They are not, and are not intended to be, a summary of this issue. Investors must read the entire Official Statement, including the Appendices, to obtain information essential to the making of an informed investment decision. Electronic bids only for the Series 2026 Bonds pursuant to the provisions of the Notice of Sale will be received by the County pursuant to BiDCOMP/Parity® electronic bid submission system in the manner and at the time and/or date described in the Official Notice of Sale. The County is not planning to purchase bond insurance at its expense to insure all or some of the Series 2026 Bonds. However, bidders, at their own expense, may elect to insure all or a portion of the Series 2026 Bonds and such insurance may be obtained from one or more bond insurance providers identified by the successful bidder. See "TERMS OF BIDS AND BASIS OF AWARD" in the Official Notice of Sale for further information. The Series 2026 Bonds are offered when, as and if issued and received by the underwriter, subject to the approving legal opinion of Nabors, Giblin & Nickerson, P.A., Tampa, Florida, Bond Counsel. Certain legal matters will be passed upon for the County by Jennifer W. Shuler, Esq., County Attorney, and certain disclosure matters will be passed upon by Nabors, Giblin & Nickerson, P.A., Tampa, Florida, as Disclosure Counsel to the County. Hilltop Securities Inc., Orlando, Florida, is acting as Municipal Advisor for the County. It is expected that the Series 2026 Bonds will be available for delivery through the facilities of DTC on or about [July] [_J, 2026 Dated: [June] [_], 2026 Preliminary, subject to change. $[PAR AMOUNT]' INDIAN RIVER COUNTY, FLORIDA General Obligation Bonds, Series 2026 $[ ] Serial Bonds Maturity Principal Interest Initial (July 1)'t Amount" Rate Yield Price CUSIP Nos." S % % $ Preliminary, subject to change. See "ADJUSTMENTS OF PRINCIPAL AMOUNTS" in the Official Notice of Sale for further information. Copyright, CUSIP Global Services. CUSIP is a registered trademark of the American Bankers Association. CUSIP data herein is provided by CUSIP Global Services, which is managed on behalf of the American Bankers Association by FactSet Research Systems, Inc. All rights reserved. This data is not intended to create a database and does not serve in any way as a substitute for CUSIP Global Services. The County is not responsible for the use of the CUSIP numbers referenced herein nor is any representation made by the County as to their correctness. The CUSIP numbers provided herein are included solely for the convenience of the readers of this Official Statement. The CUSIP number for a specific maturity is subject to being changed after the issuance of the Series 2026 Bonds as a result of various subsequent actions including, but not limited to, a refunding in whole or in part of as a result of the procurement of secondary markets portfolio insurance or other similar enhancement by investors that is applicable to all or a portion of certain maturities of the bonds. t May be combined into Term Bonds. The maturities of the Series 2026 Bonds may consist of Serial Bonds and/or Term Bonds. There is no limitation on the number of Term Bonds, provided only principal amounts maturing on and after July 1, 20_ may be combined into Term Bonds, See "TERM BONDS OPTIONS" in the Official Notice of Sale for the Series 2026 Bonds. INDIAN RIVER COUNTY, FLORIDA BOARD OF COUNTY COMMISSIONERS DerylLoar.............................................................................................................. Chairman LauraMoss.................................................................................................... Vice Chairman SusanAdams.................................................................................................. Commissioner JosephEarman ................................................................................................ Commissioner JosephE. Flescher.......................................................................................... Commissioner COUNTY ADMINISTRATOR John A. Titkanich, Jr., ICMA-CM CLERK OF THE CIRCUIT COURT AND COMPTROLLER AND EX -OFFICIO CLERK OF THE BOARD OF COUNTY COMMISSIONERS Ryan L. Butler COUNTY ATTORNEY Jennifer W. Shuler, Esq. CHIEF DEPUTY COMPTROLLER Elissa Nagy, CPA, CGFO DIRECTOR OF THE OFFICE OF MANAGEMENT AND BUDGET Kristin Daniels, CGFO BOND AND DISCLOSURE COUNSEL Nabors, Giblin & Nickerson, P.A. Tampa, Florida MUNICIPAL ADVISOR Hilltop Securities Inc. Orlando, Florida I No dealer, broker, salesman or other person has been authorized by the County to give any information or to make any representations other than those contained in this Official Statement, and if given or made, such other information or representations must not be relied upon as having been authorized by the County. This Official Statement neither constitutes an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of the Series 2026 Bonds by any person in any jurisdiction in which it is unlawful for such person to make such offer, solicitation or sale. The information set forth herein has been furnished by the County, The Depository Trust Company (as to itself and its book - entry only system), and other sources which are believed to be reliable, but such information is not guaranteed as to accuracy or completeness by, and is not to be construed as a representation of, the County. The information and expressions of opinion herein are subject to change without notice, and neither the delivery of this Official Statement nor any sale made hereunder shall, under any circumstances, create the implication that there has been no change in the affairs of the County since the date hereof. THE SERIES 2026 BONDS HAVE NOT BEEN REGISTERED WITH THE SECURITIES AND EXCHANGE COMMISSION UNDER THE SECURITIES ACT OF 1933, AS AMENDED, NOR HAS THE BOND RESOLUTION BEEN QUALIFIED UNDER THE TRUST INDENTURE ACT OF 1939, AS AMENDED, IN RELIANCE UPON EXEMPTIONS CONTAINED IN SUCH ACTS. THE REGISTRATION OR QUALIFICATION OF THE SERIES 2026 BONDS IN ACCORDANCE WITH APPLICABLE PROVISIONS OF THE SECURITIES LAWS OF THE STATES, IF ANY, IN WHICH THE SERIES 2026 BONDS HAVE BEEN REGISTERED OR QUALIFIED AND THE EXEMPTION FROM REGISTRATION OR QUALIFICATION IN CERTAIN OTHER STATES CANNOT BE REGARDED AS A RECOMMENDATION THEREOF. NEITHER THESE STATES NOR ANY OF THEIR AGENCIES HAVE PASSED UPON THE MERITS OF THE SERIES 2026 BONDS OR THE ACCURACY OR COMPLETENESS OF THIS OFFICIAL STATEMENT. ANY REPRESENTATIONS TO THE CONTRARY MAY BE A CRIMINAL OFFENSE. References herein to laws, rules, regulations, resolutions, agreements, reports and other documents do not purport to be comprehensive or definitive. All references to such documents are qualified in their entirety by reference to the particular document, the full text of which may contain qualifications of and exceptions to statements made herein. Where full texts have not been included as appendices to this Official Statement they may be obtained from the County as provided in the final paragraph under "INTRODUCTION" herein. Any statements made in this Official Statement involving matters of opinion, forecasts or estimates, whether or not so expressly stated, are set forth as such and not as representations of fact, and no representation is made that any of the forecasts or estimates will be realized. The information and expressions of opinion herein are subject to change ii without notice, and neither the delivery of this Official Statement nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the County since the date hereof. Certain statements included or incorporated by reference in this Official Statement constitute "forward-looking statements." Such statements generally are identifiable by the terminology used, such as "plan," "expect," "estimate," "anticipate," "intend," "project," "forecast," "budget" or other similar words. The achievement of certain results or other expectations contained in such forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause actual results, performance or achievements described to be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. The County does not plan to issue any updates or revisions to those forward-looking statements if or when its expectations or events, conditions or circumstances on which such statements are based occur. THIS OFFICIAL STATEMENT IS BEING PROVIDED TO PROSPECTIVE PURCHASERS IN EITHER BOUND OR IN PRINTED FORMAT ("ORIGINAL BOUND FORMAT"), OR IN ELECTRONIC FORMAT ON THE FOLLOWING WEBSITE: WWW.MUNIOS.COM. THIS OFFICIAL STATEMENT MAY BE RELIED ON ONLY IF IT IS IN ITS ORIGINAL BOUND FORMAT, OR IF IT IS PRINTED OR SAVED IN FULL DIRECTLY FROM SUCH WEBSITE OR WWW.EMMA.MSRB.ORG. iii TABLE OF CONTENTS Page INTRODUCTION...............................................................................................................1 INDIANRIVER COUNTY................................................................................................ 2 ESTIMATED SOURCES AND USES OF FUNDS...........................................................4 COMBINED DEBT SERVICE SCHEDULE..................................................................... 5 DESCRIPTION OF THE SERIES 2026 BONDS.............................................................. 6 General............................................................................................................................. 6 Book -Entry Only System................................................................................................. 6 Transfer of Series 2026 Bonds........................................................................................ 9 RedemptionProvisions..................................................................................................10 Selection of Series 2026 Bonds to be Redeemed..........................................................11 Noticeof Redemption....................................................................................................12 Redemption of Portions of Series 2026 Bonds.............................................................. 13 Payment of Redeemed Series 2026 Bonds.................................................................... 13 Purchase in Lieu of Optional Redemption....................................................................13 SECURITY FOR THE SERIES 2026 BONDS................................................................14 General........................................................................................................................... 14 Establishment of Funds and Accounts...........................................................................15 No Debt Service Reserve...............................................................................................15 Investments in Funds and Accounts.............................................................................. 15 AD VALOREM TAXATION...........................................................................................16 General...........................................................................................................................16 Procedure for Property Assessment...............................................................................17 Settingthe Millage......................................................................................................... 18 Historical and Current Millages..................................................................................... 18 Procedures for Tax Collection and Distribution............................................................19 Assessed Value of Taxable Property............................................................................. 21 Ad Valorem Tax Levies and Collections...................................................................... 22 PrincipalTaxpayers....................................................................................................... 22 Constitutional Amendments and Legislative Initiatives Affecting Ad Valorem Taxes 23 LIABILITIES OF THE COUNTY.................................................................................... 32 PensionPlans................................................................................................................. 32 Other Post -Employment Benefits.................................................................................. 32 LITIGATION.................................................................................................................... 32 LEGALMATTERS.......................................................................................................... 33 ENFORCEABILITY OF REMEDIES..............................................................................34 MUNICIPALADVISOR.................................................................................................. 34 TAXMATTERS............................................................................................................... 34 Opinionof Bond Counsel.............................................................................................. 34 Internal Revenue Code of 1986..................................................................................... 35 Collateral Tax Consequences......................................................................................... 35 IV OtherTax Matters.......................................................................................................... 35 OriginalIssue Discount.................................................................................................. 36 Original Issue Premium................................................................................................. 37 DISCLOSURE REQUIRED BY FLORIDA BLUE SKY REGULATIONS ................... 37 RATING............................................................................................................................ 38 UNDERWRITING............................................................................................................ 38 CONTINUING DISCLOSURE........................................................................................ 38 FINANCIAL STATEMENTS...........................................................................................39 INVESTMENT POLICY OF THE COUNTY.................................................................. 39 CONTINGENTFEES....................................................................................................... 40 MISCELLANEOUS.......................................................................................................... 40 AUTHORIZATION OF OFFICIAL STATEMENT........................................................ 41 Appendix A - General Information Regarding Indian River County Appendix B - Annual Comprehensive Financial Report for the Fiscal Year ended September 30, 2025 Appendix C - Form of Bond Resolution Appendix D - Form of Approving Opinion of Bond Counsel Appendix E - Form of Continuing Disclosure Certificate v OFFICIAL STATEMENT Relating to $[PAR AMOUNT]* INDIAN RIVER COUNTY, FLORIDA GENERAL OBLIGATION BONDS, SERIES 2026 INTRODUCTION The purpose of this Official Statement, which includes the cover page, inside cover page and the appendices, is to furnish information with respect to the issuance by Indian River County, Florida (the "County") of $[PAR AMOUNT]* aggregate principal amount of its General Obligation Bonds, Series 2026 (the "Series 2026 Bonds"). The Series 2026 Bonds are being issued by the County under the authority of Article VII, Section 12 of the Constitution of the State of Florida, Chapter 125, Florida Statutes, and other applicable provisions of law, and pursuant to Resolution No. 2023-004 adopted by the Board of County Commissioners (the 'Board") of the County on January 31, 2023, as supplemented, particularly as supplemented by Resolution No. 2026-[ ] adopted by the Board on [May 19], 2026 (collectively, the 'Bond Resolution"). The issuance of certain general obligation bonds in one or more series in a combined aggregate principal amount of $50,000,000 was approved by the qualified electors of the County at a bond referendum held on November 8, 2022 (the "Referendum") and validated by a judgment of the Circuit Court of the Nineteenth Judicial Circuit of the State of Florida, in and for the County, on April 27, 2023, the period for appeal of which has expired. The Series 2026 Bonds are the second and final series of new money general obligation bonds to be issued by the County pursuant to the authority of the Referendum. The County has previously issued $22,795,000 of the indebtedness authorized in the Referendum (the "Series 2024 Bonds"). Upon issuance of the Series 2026 Bonds, the County will have issued the full $50,000,000 of new money general obligation bonds authorized by the voters in the County in the Referendum; provided, however, the County may issue future series of general obligation bonds for refunding purposes. The Series 2026 Bonds are general obligation bonds of the County to which the full faith, credit and taxing power of the County are irrevocably pledged in the manner and to the extent described in the Bond Resolution. The Series 2026 Bonds are payable from ad valorem taxes levied without limitation as to rate or amount on all taxable property within * Preliminary, subject to change. the County, sufficient in amount to pay the principal ,of and interest on the Series 2026 Bonds. See "SECURITY FOR THE SERIES 2026 BONDS" herein. The Series 2026 Bonds are being issued for the purposes of (1) financing costs of the acquisition and preservation of certain environmentally sensitive lands, and the construction of public access improvements with respect thereto, as described in the plans and specifications on file with the County, and (2) paying certain costs and expenses relating to the issuance of the Series 2026 Bonds. The Series 2026 Bonds are subject to redemption prior to their stated maturities, as more particularly described herein. See "DESCRIPTION OF THE SERIES 2026 BONDS — Redemption Provisions" herein. U.S. Bank Trust Company, National Association, Jacksonville, Florida, shall serve as the initial Paying Agent and Registrar for the Series 2026 Bonds. The County has covenanted to provide certain continuing disclosure information pursuant to Rule 15c2-12 of the Securities and Exchange Commission relating to the Series 2026 Bonds. See "CONTINUING DISCLOSURE" herein. Capitalized terms used but not defined herein have the same meanings as when used in the Bond Resolution unless the context would clearly indicate otherwise. Complete descriptions of the terms and conditions of the Series 2026 Bonds are set forth in the Bond Resolution, the form of which is contained in Appendix C of this Official Statement. The descriptions of the Series 2026 Bonds, the documents authorizing and securing the same, and the information from various reports and statements contained herein are not comprehensive or definitive. All references herein to such documents, reports and statements are qualified by the entire, actual content of such documents, reports and statements. Copies of such documents, reports and statements referred to herein that are not included in their entirety in this Official Statement may be obtained from the County. INDIAN RIVER COUNTY The Florida Legislature established Indian River County on June 29, 1925. The County is located on the central Atlantic coast of Florida, approximately 100 miles southeast of Orlando and 135 miles north of Miami. The County is bordered by Brevard County to the north, St. Lucie County to the south, and Osceola and Okeechobee Counties on the west. There are approximately 100 miles of waterfront land in the County, including 23 miles of Atlantic beaches. The City of Vero Beach is the seat of County government. The County is a noncharter county established under the Constitution and the Laws of the State of Florida. A five member Board of County Commissioners, elected at large from five districts, governs the County. The Board appoints a County Administrator who is responsible for 2 implementing the policies set forth by the Board. The County Administrator is charged with the proper fiscal management of the resources of the County. In addition to the Board, there are five elected Constitutional Officers serving specific governmental functions: Clerk of the Circuit Court and Comptroller, Property Appraiser, Sheriff, Supervisor of Elections, and Tax Collector. Although the majority of the funding for all Constitutional Officers is part of the County's General Fund, the Board does not have direct responsibility for their operations. Indian River County provides a full range of services including, but not limited to: construction and maintenance of roadways, sidewalks and other infrastructure, fire rescue/emergency services, law enforcement, library services, traffic operations and control, parks and recreational services, golf course, human services, building inspections, licenses and permits, water/sewer utility services, and refuse collection and disposal. The County is a political subdivision of the State, and is governed by the State Constitution and the general laws of the State. See "Appendix A - General Information Regarding Indian River County" attached hereto. [Remainder of page intentionally left blank] 3 ESTIMATED SOURCES AND USES OF FUNDS The proceeds to be received from the sale of the Series 2026 Bonds are expected to be applied as follows: SOURCES OF FUNDS Principal Amount $[PAR AMOUNT] [Plus/Less] [Net] Original Issue [Premium/Discount] Total Sources of Funds $ USES OF FUNDS Deposit to 2026 Project Account(') $ Costs of issuance (2) Total Uses of Funds $ 0) To be applied to finance and/or reimburse costs of the 2026 Project. See "PURPOSE OF THE BONDS" herein. (2) Includes underwriters' discount, legal, municipal advisory, professional, administrative and other customary costs of issuance. [Remainder of page intentionally left blank] F51 COMBINED DEBT SERVICE SCHEDULE The following table sets forth the annual debt service requirements with respect to the Series 2026 Bonds and the outstanding Series 2024 Bonds: Bond Year Ending (July 1) 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 Totals Annual Debt Service Annual Debt Service Combined Annual Principal Interest on Series 2026 Bonds on Series 2024 Bonds Debt Service $ $ $1,778,350 $ 1,780,350 1,780,350 1,778,350 1,779,350 1,778,100 1,779,600 1,778,600 1,780,100 1,778,850 1,779,850 1,777,850 1,777,850 1,779,600 1,777,850 1,782,600 1,779,200 1,778,400 'Totals may not add due to rounding. $32,025,200 [Remainder of page intentionally left blank] 5 DESCRIPTION OF THE SERIES 2026 BONDS General The Series 2026 Bonds will be dated their date of delivery and will be issued in fully registered form, without coupons, in denominations of $5,000 each or integral multiples thereof, maturing on July 1 in the years and in the principal amounts set forth on the inside cover page of this Official Statement. The Series 2026 Bonds will bear interest at the rates set forth on the inside cover page of this Official Statement, computed on the basis of a 360 -day year, consisting of twelve 30 -day months. Interest on the Series 2026 Bonds will be payable semi-annually on January 1 and July 1 of each year, commencing on [January 1, 2027]. U.S. Bank Trust Company, National Association, Jacksonville, Florida, is serving as the initial Paying Agent and Registrar. Interest on any Series 2026 Bond will be paid by check or draft of the Paying Agent or by electronic means to the registered Holder of such Series 2026 Bond. Except as otherwise set forth under "- Book -Entry Only System" below, principal of the Series 2026 Bonds shall be made upon presentation and surrender of the Series 2026 Bonds at the corporate trust office of the Paying Agent. The principal of and interest on the Series 2026 Bonds shall be payable in any coin or currency of the United States of America which on the respective dates of payment thereof is legal tender for the payment of public and private debts. Book -Entry Only System THE FOLLOWING INFORMATION IN THIS SECTION CONCERNING DTC AND DTC'S BOOK -ENTRY ONLY SYSTEM HAS BEEN OBTAINED FROM DTC AND OTHER SOURCES THAT THE COUNTY BELIEVES TO BE RELIABLE AND THE COUNTY DOES NOT TAKE ANY RESPONSIBILITY FOR THE ACCURACY THEREOF. DTC will act as securities depository for the Series 2026 Bonds. The Series 2026 Bonds will be issued as fully -registered bonds registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully -registered bond certificate will be issued for each maturity of the Series 2026 Bonds and will be deposited with DTC. SO LONG AS CEDE & CO. IS THE REGISTERED OWNER OF THE SERIES 2026 BONDS, AS NOMINEE OF DTC, CERTAIN REFERENCES IN THIS OFFICIAL STATEMENT TO THE SERIES 2026 BONDHOLDERS OR REGISTERED OWNERS OF THE SERIES 2026 BONDS SHALL MEAN CEDE & CO. AND SHALL NOT MEAN THE BENEFICIAL OWNERS OF THE SERIES 2026 BONDS. THE DESCRIPTION WHICH FOLLOWS OF THE PROCEDURES AND RECORD KEEPING WITH RESPECT TO BENEFICIAL OWNERSHIP INTERESTS IN THE SERIES 2026 BONDS, PAYMENT OF INTEREST AND PRINCIPAL ON THE SERIES 2026 BONDS TO DIRECT PARTICIPANTS (AS HEREINAFTER DEFINED) OR BENEFICIAL OWNERS OF THE SERIES 2026 BONDS, CONFIRMATION AND TRANSFER OF BENEFICIAL OWNERSHIP 1.1 INTERESTS IN THE SERIES 2026 BONDS, AND OTHER RELATED TRANSACTIONS BY AND BETWEEN DTC, THE DIRECT PARTICIPANTS AND BENEFICIAL OWNERS OF THE SERIES 2026 BONDS IS BASED SOLELY ON INFORMATION FURNISHED BY DTC. ACCORDINGLY, THE COUNTY NEITHER MAKES NOR CAN MAKE ANY REPRESENTATIONS CONCERNING THESE MATTERS. DTC, the world's largest securities depository, is a limited -purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non -U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC's participants (the "Direct Participants") deposit with DTC. DTC also facilitates the post -trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book -entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly (the "Indirect Participants"). , DTC has a Standard and Poor's rating of AA+. The DTC rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com and www.dtc.org. Purchases of the Series 2026 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for such Series 2026 Bonds on DTC's records. The ownership interest of each actual purchaser of each Series 2026 Bond (the "Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Series 2026 Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of the Beneficial Owners. Beneficial Owners will not receive certificates VA representing their ownership interests in the Series 2026 Bonds, except in the event that use of the book -entry system for the Series 2026 Bonds is discontinued. To facilitate subsequent transfers, all Series 2026 Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co. or such other name as may be requested by an authorized representative of DTC. The deposit of the Series 2026 Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Series 2026 Bonds; DTC's records reflect only the identity of the Direct Participants to whose accounts such Series 2026 Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping an account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements made among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Redemption notices shall be sent to DTC. If less than all of the Series 2026 Bonds are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such Series 2026 Bonds, as the case may be, to be redeemed. Beneficial Owners of the Series 2026 Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Series 2026 Bonds, such as redemptions, defaults, and proposed amendments to the Series 2026 documents. For example, Beneficial Owners of the Series 2026 Bonds may wish to ascertain that the nominee holding the Series 2026 Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the Registrar and request that copies of notices be provided directly to them. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to the Series 2026 Bonds unless authorized by a Direct Participant in accordance with DTC's MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the County as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts the Series 2026 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Principal and interest payments on the Series 2026 Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts, upon DTC's receipt of funds and corresponding detail information from the County or the Registrar on the payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary E? practices, as is the case with securities held for the accounts of customers in bearer form or with securities registered in "street name," and will be the responsibility of such Participant and not of DTC or the County, subject to any statutory and regulatory requirements as may be in effect from time to time. Payment of principal and interest to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the County. Disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of the Direct and Indirect Participants. DTC may discontinue providing its services as securities depository with respect to the Series 2026 Bonds at any time by giving reasonable notice to the County. Under such circumstances, in the event that a successor securities depository is not obtained, Series 2026 Bond certificates are required to be printed and delivered. The County may decide to discontinue use of the book -entry transfers through DTC (or a successor securities depository). In that event and upon compliance with applicable DTC procedures, Series 2026 Bond certificates will be printed and delivered. Transfer of Series 2026 Bonds So long as the Series 2026 Bonds are registered in the name of DTC or its nominee, the following paragraphs relating to transfer and exchange of beneficial ownership interests in the Series 2026 Bonds will not apply to the Series 2026 Bonds, and the transfer and registration of beneficial ownership interests in the Series 2026 Bonds will be governed by the rules and procedures of DTC as generally described under "DESCRIPTION OF THE SERIES 2026 BONDS - Book -Entry Only System, " above. Series 2026 Bonds, upon surrender thereof at the office of the Registrar with a written instrument of transfer satisfactory to the Registrar, duly executed by the Holder thereof or such Holder's attorney duly authorized in writing, may, at the option of the Holder thereof, be exchanged for an equal aggregate principal amount of registered Series 2026 Bonds of the same maturity of any other authorized denominations. The Series 2026 Bonds issued under the Bond Resolution shall be and have all the qualities and incidents of negotiable instruments under the law merchant and the Uniform Commercial Code of the State of Florida, subject to the provisions for registration and transfer contained in the Bond Resolution and in the Series 2026 Bonds. So long as any of the Series 2026 Bonds shall remain outstanding, the County shall maintain and keep at the office of the Registrar, books for the registration and transfer of the Series 2026 Bonds. Each Series 2026 Bond shall be transferable only upon the books of the County, at the office of the Registrar, under such reasonable regulations as the County may prescribe, by the Holder thereof in person or by such Holder's attorney duly authorized in writing upon surrender thereof together with a written instrument of transfer satisfactory to the 6 Registrar duly executed and guaranteed by the Holder or such Holder's duly authorized attorney. Upon the registration or transfer of any such Series 2026 Bond, the County shall issue, and cause to be authenticated, in the name of the transferee a new Series 2026 Bond or Series 2026 Bonds of the same aggregate principal amount and maturity as the surrendered Series 2026 Bond. The County, the Registrar and any Paying Agent or fiduciary of the County may deem and treat the Person in whose name any outstanding Series 2026 Bond shall be registered upon the books of the County as the absolute owner of such Series 2026 Bond, whether such Series 2026 Bond shall be overdue or not, for the purpose of receiving payment of, or on account of, the principal and interest on such Series 2026 Bond and for all other purposes, and all such payments so made to any such Holder or upon such Holder's order shall be valid and effectual to satisfy and discharge the liability upon such Series 2026 Bond to the extent of the sum or sums so paid and neither the County nor the Registrar nor any Paying Agent or other fiduciary of the County shall be affected by any notice to the contrary. In all cases in which the privilege of exchanging Series 2026 Bonds or transferring Series 2026 Bonds is registered, the County shall execute and the Registrar shall authenticate and deliver such Series 2026 Bonds in accordance with the provisions of the Bond Resolution. Execution of Series 2026 Bonds in the same manner as is provided in the Bond Resolution for purposes of exchanging, replacing or transferring Series 2026 Bonds may occur at the time of the original delivery of the Series 2026 Bonds. All Series 2026 Bonds surrendered in any such exchanges or transfers shall be held by the Registrar in safekeeping until directed by the County to be canceled by the Registrar. For every such exchange or transfer of Series 2026 Bonds, the County or the Registrar may make a charge sufficient to reimburse it for any tax, fee, expense or other governmental charge required to be paid with respect to such exchange or transfer. The County and the Registrar shall not be obligated to make any such exchange or transfer of Series 2026 Bonds during the fifteen (15) days next preceding an Interest Date on the Series 2026 Bonds, or, in the case of any proposed redemption of Series 2026 Bonds, then, for the Series 2026 Bonds subject to redemption, during the fifteen (15) days next preceding the date of the first mailing of notice of such redemption and continuing until such redemption date. Redemption Provisions Optional Redemption of Series 2026 Bonds. The Series 2026 Bonds maturing on or before July 1, 2036 are not subject to optional redemption prior to maturity. The Series 2026 Bonds maturing on July 1, 2037 and thereafter are redeemable at the option of the County from any legally available source, in whole or in part and if in part, in any order of maturity selected by the County, at its discretion, and by lot within a maturity if less than an entire maturity is to be redeemed, on July 1, 2036, or at any time thereafter, at a redemption price equal to the principal amount of the Series 2026 Bonds to be redeemed, together with accrued interest to the date fixed for redemption. 10 Mandatory Redemption of Series 2026 Bonds. The Series 2026 Bonds maturing on July 1, 20_ are subject to mandatory sinking fund redemption prior to maturity, by lot, in such manner as the Registrar deems appropriate, at a Redemption Price equal to principal amount of the Series 2026 Bonds to be redeemed, plus interest accrued thereon to the date of redemption, commencing on July 1, 20_, and on each July 1 in the following years and in the following Amortization Installments: Amortization Year Installment *Final Maturity Selection of Series 2026 Bonds to be Redeemed The Series 2026 Bonds shall be redeemed only in the principal amount of $5,000 each and integral multiples thereof. The County shall, at least thirty-five (35) days prior to the redemption date (unless a shorter time period shall be satisfactory to the Registrar, but in no event less than twenty-five (25) days) notify the Registrar of such redemption date and of the principal amount of Series 2026 Bonds to be redeemed. For purposes of any redemption of less than all of the outstanding Series 2026 Bonds of a single maturity, the particular Series 2026 Bonds or portions of Series 2026 Bonds to be redeemed shall be selected not more than thirty-five (35) days and not less than twenty-five (25) days prior to the redemption date by the Registrar from the Outstanding Series 2026 Bonds of the maturity or maturities designated by the County or by such method as the Registrar shall deem fair and appropriate and which may provide for the selection for redemption of Series 2026 Bonds or portions of Series 2026 Bonds in principal amounts of $5,000 and integral multiples thereof. If less than all of a Term Bond is to be redeemed, the aggregate principal amount to be redeemed shall be allocated to the Amortization Installments on a pro -rata basis unless the Issuer, in its discretion, designates a different allocation. Investors should note that while DTC is the registered owner of the Series 2026 Bonds, partial prepayments of the Series 2026 Bonds will be determined in accordance with DTC's procedures. The County intends that prepayment allocations made by DTC, the DTC Participants or such other intermediaries that may exist between the County and the Beneficial Owners of the Series 2026 Bonds be made in accordance with the method of selection of Series 2026 Bonds for a partial prepayment described above. However, the selection of the Series 2026 Bonds for prepayment in DTC's book -entry only system is subject to DTC's practices and procedures as in effect at the time of any such partial prepayment. The County can provide no assurance that DTC or the DTC Participants or 11 any other intermediaries will allocate prepayments among Beneficial Owners in accordance with the method of selection of Series 2026 Bonds for a partial prepayment described above. Notice of Redemption Notice of such redemption, which shall specify the Series 2026 Bond or Series 2026 Bonds (or portions thereof) to be redeemed and the date and place for redemption, shall be given by the Registrar on behalf of the County, and (A) shall be filed with the Paying Agent of such Series 2026 Bonds and (B) shall be mailed first class, postage prepaid, at least twenty (20) days prior to the redemption date to all Holders of Series 2026 Bonds to be redeemed at their addresses as they appear on the registration books kept by the Registrar as of the date of mailing of such notice. Failure to mail notice to the Holders of the Series 2026 Bonds to be redeemed, or any defect therein, shall not affect the proceedings for redemption of Series 2026 Bonds as to which no such failure or defect has occurred. Failure of any Holder to receive any notice mailed as provided in the Bond Resolution shall not affect the proceedings for redemption of such Holder's Series 2026 Bonds. Each notice of redemption shall state: (1) the CUSIP numbers of all Series 2026 Bonds being redeemed, (2) the original issue date of such Series 2026 Bonds, (3) the maturity date and rate of interest borne by each Series 2026 Bond being redeemed, (4) the redemption_ date, (5) the Redemption Price, (6) the date on which such notice is mailed, (7) if less than all Outstanding Bonds are to be redeemed, the certificate number (and in the case of a partial redemption of any Series 2026 Bond, the principal amount) of each Series 2026 Bond to be redeemed, (8) that on such redemption date there shall become due and payable upon each Series 2026 Bond to be redeemed the Redemption Price thereof, or the Redemption Price of the specified portions of the principal thereof in the case of Series 2026 Bonds to be redeemed in part only, together with interest accrued thereon to the redemption date, and that from and after such date interest thereon shall cease to accrue and be payable, (9) that the Series 2026 Bonds to be redeemed, whether as a whole or in part, are to be surrendered for payment of the Redemption Price at the designated office of the Paying Agent at an address specified, (10) unless sufficient funds have been set aside by the County for such purpose prior to the mailing of the notice of redemption, that such redemption is conditioned upon the deposit of sufficient funds for such purpose on or prior to the date set for redemption; and provided, further, that such notice and the redemption set forth therein may be subject to the satisfaction of one or more additional conditions set forth therein, and (12) any other conditions that must be satisfied prior to such redemption. The County may provide that a redemption may be contingent upon the occurrence of certain condition(s) and that if such condition(s) do not occur the notice of redemption will be rescinded, provided notice of rescission shall be mailed in the manner described above to all affected Series 2026 Bondholders as soon as practicable. 12 So long as the Series 2026 Bonds are registered in the name of Cede & Co., as nominee of DTC (or in the name of a successor securities depository), notices of redemption shall only be given on behalf of the County to Cede & Co., or any successor securities depository. See "DESCRIPTION OF THE SERIES 2026 BONDS - Book -Entry Only System " herein. Redemption of Portions of Series 2026 Bonds Any Series 2026 Bond which is to be redeemed only in part shall be surrendered at any place of payment specified in the notice of redemption (with due endorsement by, or written instrument of transfer in form satisfactory to, the Registrar duly executed by, the Holder thereof or such Holder's attorney duly authorized in writing) and the County shall execute and the Registrar shall authenticate and deliver to the Holder of such Series 2026 Bond, without service charge, a new Series 2026 Bond or Series 2026 Bonds, of the same interest rate, maturity and series, and of any authorized denomination as requested by such Holder, in an aggregate principal amount equal to and in exchange for the unredeemed portion of the principal of the Series 2026 Bonds so surrendered. Payment of Redeemed Series 2026 Bonds Notice of redemption having been given substantially as described above, the Series 2026 Bonds or portions of Series 2026 Bonds to be redeemed shall, on the redemption date, become due and payable at the Redemption Price therein specified, and from and after such date (unless the County shall default in the payment of the Redemption Price) such Series 2026 Bonds or portions of Series 2026 Bonds shall cease to bear interest. Upon surrender of such Series 2026 Bonds for redemption in accordance with said notice, such Series 2026 Bonds shall be paid by the Registrar and/or Paying Agent at the appropriate Redemption Price, plus accrued interest. All Series 2026 Bonds which have been redeemed shall be canceled by the Registrar and shall not be reissued. Purchase in Lieu of Optional Redemption Notwithstanding anything in this Resolution to the contrary, at any time the Series 2026 Bonds are subject to optional redemption pursuant to the Bond Resolution, all or a portion of the Series 2026 Bonds to be redeemed as specified in the notice of redemption, may be purchased by the Paying Agent, as trustee, at the direction of the County, on the date which would be the redemption date if such Series 2026 Bonds were redeemed rather than purchased in lieu thereof at a purchase price equal to the redemption price which would have been applicable to such Series 2026 Bonds on the redemption date for the account of and at the direction of the County who shall give the Paying Agent, as trustee, notice at least ten days prior to the scheduled redemption date accompanied by an opinion of Bond Counsel to the effect that such purchase will not adversely affect the exclusion from gross income for federal income tax purposes of interest on such Series 2026 Bonds or any other Outstanding Bonds. In the event the Paying Agent, as trustee, is so directed 13 to purchase Series 2026 Bonds in lieu of optional redemption, no notice to the holders of the Series 2026 Bonds to be so purchased (other than the notice of redemption otherwise required under this Resolution) shall be required, and the Paying Agent, as trustee, shall be authorized to apply to such purchase the funds which would have been used to pay the redemption price for such Bonds if such Series 2026 Bonds had been redeemed rather than purchased. Each Series 2026 Bond so purchased shall not be canceled or discharged and shall be registered in the name of the County. Series 2026 Bonds to be purchased under the Bond Resolution in the manner set forth above which are not delivered to the Paying Agent, as trustee, on the purchase date shall be deemed to have been so purchased and not optionally redeemed on the purchase date and shall cease to accrue interest as to the former holder thereof on the purchase date. SECURITY FOR THE SERIES 2026 BONDS General Pursuant to the Bond Resolution, the County has irrevocably pledged its full faith, credit and taxing power for the full and prompt payment of the principal of and interest on the Bonds. The Bond Resolution further provides that there shall be levied a direct annual tax on all taxable property within the County to make such payments. Provision shall be included and made in the County's annual budget and tax levy for the levy of the Ad Valorem Taxes provided in the Bond Resolution. Whenever the County shall, in any Bond Year, have irrevocably deposited in the Sinking Fund any monies derived from sources other than Ad Valorem Taxes, said Ad Valorem Taxes may be correspondingly diminished; but any such diminution must leave available an amount of such Ad Valorem Taxes, after allowance for anticipated delinquencies in collection, fully sufficient, with such monies so deposited from other sources, to assure the prompt payment of principal, interest, and other related charges falling due prior to the time that the proceeds of the next annual Ad Valorem Tax levy will be available. Such Ad Valorem Taxes shall be levied and collected at the same time, and in the same manner, as other ad valorem taxes of the County are assessed, levied and collected. The Ad Valorem Taxes shall be levied and collected in accordance with all applicable law, including, but not limited to, the Referendum Resolution. The payment of the principal of or Redemption Price, if applicable, and interest on the Bonds shall be secured forthwith equally and ratably by a pledge of and lien upon the Pledged Funds, and the County has, pursuant to the Bond Resolution irrevocably pledged such Pledged Funds to the payment of the Bonds. "Pledged Funds" is defined in the Bond Resolution as (1) the Ad Valorem Taxes, and (2) until applied in accordance with the provisions of the Bond Resolution, all moneys, including investments thereof, in the funds, accounts and subaccounts (other than the Rebate Fund) established under the Bond Resolution. 14 the County's internal investment policy (See "INVESTMENT POLICY OF THE COUNTY" herein) maturing not later than the date on which the moneys therein will be needed for the purposes of such fund or account. Any and all income received by the County from the investment of moneys in such funds and accounts shall be retained in such respective funds and accounts. AD VALOREM TAXATION General Under Florida law, ad valorem property taxes may be levied only by counties, school districts, municipalities and certain special districts. No ad valorem taxes may be levied by the State upon real estate or tangible personal property. The assessment of all properties and the collection of all county, municipal and other local government property taxes are consolidated in the office of each County Property Appraiser and County Tax Collector. The laws of the State of Florida regulating tax assessment are designed to assure a consistent property valuation method statewide. The Florida Constitution limits the aggregate rate of ad valorem taxes that may be levied on real and personal property. The limitation, except as noted below, is ten (10) mills each for all county and municipal purposes. A mill is equal to one-tenth (0.1) of one cent of one dollar or $1.00 for every $1,000 of assessed value. The Florida Constitution excludes from the general 10 mill cap ad valorem taxes which are necessary to pay debt service on voter approved general obligation bonds, such as the ad valorem taxes that secure the Series 2026 Bonds and other voter approved levies. Each respective millage rate, except as limited by law, is set on the basis of estimates of revenue needs and total taxable property valuations within the taxing authority's respective jurisdiction. Ad valorem taxes are not levied in excess of actual budget requirements. In setting millage rates, the county is required by Section 200.065, Florida Statutes, to assume no less than a 95% tax collection rate. The following uses of real property are generally exempt from ad valorem taxation: religious, educational, charitable, scientific, literary and governmental. In addition, there are a variety of special exemptions, including but not limited to, for widows, hospitals, homesteads, working waterfronts and homes for the aged and disabled veterans and first responders. The general "homestead exemption" exempts from taxation the first $25,000 of the assessed valuation of a residence occupied by the owner on a permanent basis, as of January 1 of the year of valuation. Agricultural land, noncommercial recreational land, inventory and livestock are assessed at less than 100 percent of fair market value. See also "AD VALOREM TAXATION - Constitutional Amendments and Legislative Initiatives Affecting Ad Valorem Taxes" herein. Procedure for Property Assessment Real and personal property valuation is determined as of January 1 by each County Property Appraiser. Except as noted below under "AD VALOREM TAXATION - Constitutional Amendments and Legislative Initiatives Affecting Ad Valorem Taxes," all taxable real and tangible personal property must be assessed at 100% of fair market value. The Property Appraiser of Indian River County (the "Property Appraiser") determines property valuation on real and tangible personal property as of January 1 of each year. The Property Appraiser determines the valuation of all real and personal property by July 1 of each year and notifies the County, each municipality within the County, the Indian River County School District (the "School District") and each other legally constituted special taxing district as to its just valuation, notes the legal adjustments and exemptions and the taxable valuation. The taxable valuation is then used by each taxing body to calculate its ad valorem millage for the budget year. Each taxing body must advertise its budget, stating the proposed millage and hold public hearings on such budgets. Final budgets are determined by each taxing body and the millage is certified to the Property Appraiser by October 1. Concurrently, the Property Appraiser notifies each property owner of the proposed valuation and the proposed millage on such property. If the individual property owner believes that his or her property has not been appraised at fair market value, the owner may file a petition with the Indian River County Value Adjustment Board (the "Adjustment Board"). Taxpayers appealing the assessed value or assigned classification of their property must make a required partial payment of taxes (generally equal to 75% of the ad valorem taxes due, less the applicable statutory discount, if any) with respect to properties that will have a petition pending on or after the delinquency date (normally, the following April 1). A taxpayer's failure to make the required partial payment before the delinquency date will result in the denial of the taxpayer's petition. The Adjustment Board appoints independent special magistrates (real estate appraisers and/or attorneys) who hold public hearings on such petitions and determine whether adjustments to the valuations made by the Property Appraiser should be made, if such valuations were found not to be fair and at market value. The Adjustment Board must complete all required hearings and certify its decision with regard to all petitions and certify to the Property Appraiser the valuation to be used by June 1 following the tax year in which the assessments were made. These changes are then made to the final tax roll. The June 1 requirement shall be extended until December 1 in each year in which the number of petitions filed with the Adjustment Board increased by more than 10% over the previous year. The decision of the Adjustment Board may be appealed to the Circuit Court. The Property Appraiser applies the final certified millage of each taxing body to the assessed valuation on each item of real and tangible personal property and prepares the final tax roll which is certified to the Indian River County Tax Collector (the "Tax Collector") by October 1. This permits the printing of tax bills for delivery on November 1 17 of each year. The tax bills contain all of the overlapping and underlying millages set by the various taxing bodies so that all ad valorem taxes are collected by the Tax Collector and distributed to the various taxing bodies. See "AD VALOREM TAXATION - Assessed Value of Taxable Property" below for a historical table of assessed valuations. Setting the Millage The Property Appraiser assesses and the Tax Collector collects all ad valorem taxes within the County. While one tax bill emanates from the Tax Collector, the bill represents ad valorem taxes levied by the County, the School District, municipalities and other taxing authorities. The Florida Constitution limits the non -voted millage rate that counties may levy on an annual basis for county purposes to 10 mills (S 10 per S 1,000 of taxable real and personal property value). The millage limitation does not apply to taxes approved at referendum by qualified electors in the county for general obligation bonds (such as the Series 2026 Bonds) and for certain other voter approved levies. Each respective millage rate, except as limited by law, is set on the basis of estimates of revenue needs and the total taxable property values within the taxing authority's respective jurisdiction. Revenues derived from ad valorem property taxes are budgeted, as required by Florida law, on the application of millage levies equal to 95% of the non- exempt assessed valuation of property in the county. Ad valorem taxes are not levied in excess of actual budget requirements. Historical and Current Millages The following table contains the tax millage rates of the County and other taxing authorities within the County for the Fiscal Years 2022-2026: Indian River County, Florida Property Tax Millage Rates for Direct and Overlapping Governments (Unaudited) Fiscal Years 2022-2026 County direct rates General fund Municipal service Total direct rate(') County -wide district school board rate Other County -wide rates Emergency Services District Land acquisition bond Total other County -wide rates Fiscal Year 2022 2023 2024 2025 2026 3.5475 3.5475 3.5475 3.5475 1.1506 1.1506 1.1506 1.1506 4.6981 4.6981 4.6981 4.6981 3.5475 1.1506 4.6981 6.2680 5.9850 5.9110 5.7530 5.7530 2.3531 2.3531 2.3531 2.3531 2.3531 - - - 0.0639 0.0610 2.3531 2.3531 2.3531 2.4170 2.4141 18 Total County -wide rate (2) 13.3192 13.0362 12.9622 12.8681 12.8652 City rates Fellsmere 5.3226 5.2210 5.5150 5.0000 5.3500 Indian River Shores 1.3349 1.3349 1.3349 1.3349 1.2810 Sebastian 3.0043 2.9050 3.1955 3.1955 3.4455 Orchid 1.4000 1.1000 1.0000 0.7000 0.7000 Vero Beach 2.5000 2.6964 2.7680 2.7680 2.9816 Average of cities rates 2.7124 2.6515 2.7627 2.5997 2.7516 Other special district rates 1.2933 1.0677 1.0657 1.3759 1.3393 Per Section 200.071, Florida Statutes, no ad valorem tax millage shall be levied against real property and tangible personal property by counties in excess of 10 mills, except for voted levies. (2) Total County -wide rate is borne by all property owners within the County boundaries. Sources: Indian River County Property Appraiser, www.ircpa.org; Indian River County, Florida Annual Comprehensive Financial Report for the Fiscal Year ended September 30, 2025; Indian River County, Florida Adopted Budget for the Fiscal Year 2025-2026. Procedures for Tax Collection and Distribution All real and tangible personal property taxes are due and payable on November 1 of each year, or as soon thereafter as the tax roll is certified and delivered to the Tax Collector. The Tax Collector mails a notice to each property owner on the tax roll for the taxes levied by the County, the School District, municipalities within the County and other taxing authorities. Taxes may be paid upon receipt of such notice, with discounts at the rate of 4% if paid in the month of November; 3% if paid in the month of December; 2% if paid in the month of January and 1 % if paid in the month of February. Taxes paid in the month of March are without discount. All unpaid taxes on real and personal property become delinquent on April I of the year following the year in which taxes were levied. Delinquent real property taxes bear interest at the rate of 18% per year from April 1 until a tax certificate is sold at auction, from which time the interest rate shall be as bid by the buyer of the tax certificate. Delinquent tangible personal property taxes also bear interest at the rate of 18% per year from April 1 until paid. Delinquent personal property taxes must be advertised within 45 days after delinquency, and after May 1, the property is subject to warrant, levy, seizure and sale. On or before June 1 or the 60th day after the date of delinquency, whichever is later, the Tax Collector must advertise once each week for three weeks and must sell tax certificates on all real property with delinquent taxes. The tax certificates are sold to those bidding the lowest interest rate to be borne by the certificates. Such certificates include the amount of delinquent taxes, the penalty interest accrued thereon and the cost of advertising. Delinquent tax certificates not sold at auction become the property of the County. Florida 19 law provides that real property tax liens are superior to all other liens, except prior Internal Revenue Service liens. To redeem a tax certificate, the owner of the property must pay all delinquent taxes, the interest that accrued prior to the date of the sale of the tax certificate, charges incurred in connection with the sale of the tax certificate, omitted taxes,- if any, and interest at the rate shown on the tax certificate (or interest at the rate of 5%, whichever is higher) from the date of the sale of the tax certificate to the date of redemption. If such tax certificates or liens are not redeemed by the property owner within two years, the holder of the tax certificates can cause the property to be sold to pay off the outstanding certificates and the interest thereon. Provisions are also made for the collection of delinquent tangible personal property taxes, but in a different manner which includes the possible seizure of the tangible personal property. Florida law requires the Tax Collector to distribute the taxes collected to each governmental unit levying the tax. Such distribution is to be made four times during the first two months after the tax roll comes into its possession, and once per month thereafter. [Remainder of page intentionally left blank] 20 Assessed Value of Taxable Property The following table sets forth the assessed value of taxable property in the County for the Fiscal Years 2016-2026: Indian River County, Florida Assessed Value and Actual Value of Taxable Property (Unaudited) Fiscal Years 2016-2026 2026 Total Actual Value Less: Tax - Exempt Property Personal Fiscal Real Property Property Actual Year Actual Value Value 2016 $17,855,660,837 $696,658,855 2017 19,941,465,452 698,630,083 2018 23,725,954,463 675,815,085 2019 25,295,251,822 634,654,180 2020 26,921,744,684 737,895,129 2021 27,867,246,400 802,782,805 2022 29,331,050,832 850,748,919 2023 36,552,287,738 986,160,779 2024 44,508,153,413 1,292,191,481 2025 47,335,746,558 1,307,557,308 2026 Total Actual Value Less: Tax - Exempt Property Total Taxable Assessed Value Total Direct Tax Rate $18,552,319,692 $5,150,260,231 $13,402,059,461 4.4108 mills 20,640,095,535 6,338,690,254 14,301,405,281 4.4335 24,401,769,548 8,125,447,769 16,276,321,779 4.4335 25,929,906,002 8,125,447,769 17,804,458,233 4.5337 27,659,639,813 9,079,222,273 18,580,417,540 4.5337 28,670,029,205 9,092,020,308 19,578,008,897 4.6981 30,181,799,751 9,592,471,404 20,589,328,347 4.6981 37,538,448,517 14,173,050,634 23,365,397,883 4.6981 45,800,344,894 19,208,591,426 26,591,753,468 4.6981 48,643,303,866 19,357,835,173 29,285,468,693 4.6981 Sourcels]: Indian River County Property Appraiser; values are established as of January 1 of the previous calendar year, i.e., January 1, 2025 taxable values apply to the Fiscal Year ending September 30, 2026; Indian River County, Florida Annual Comprehensive Financial Report for the Fiscal Year ended September 30, 2025. 21 Ad Valorem Tax Levies and Collections The following table sets forth the amounts billed and the percent collected for ad valorem property taxes levied by the County for the last ten Fiscal Years: Indian River County, Florida Property Tax Levies and Collections (Unaudited) Last Ten Fiscal Years Source: Indian River County, Florida Annual Comprehensive Financial Report for the Fiscal Year ended September 30, 2025. Principal Taxpayers The following table sets forth the principal property taxpayers in Indian River County, Florida for Fiscal Year 2025 (relating to taxes levied in tax/calendar year 2024): [Remainder of page intentionally left blank] 22 % of Current % of Total Tax Total Tax Current Tax Tax Collections Delinquent Tax Total Tax Collections to Year Levy Collections to Tax Levy Collections Collections Tax Levy 2016 $87,611,062 $84,648,230 96.62% $60,147 $84,708,377 96.69% 2017 93,167,061 90,100,287 96.71 78,624 90,178,911 96.79 2018 102,322,230 98,568,670 96.33 40,811 98,609,481 96.37 2019 108,994,936 105,148,685 96.47 26,255 105,174,940 96.50 2020 118,478,616 114,292,023 96.47 108,270 114,400,293 96.56 2021 119,796,353 115,517,250 96.43 67,544 115,584,794 96.48 2022 126,027,404 121,551,348 96.45 82,076 121,633,424 96.51 2023 143,132,352 137,866,142 96.32 80,377 137,946,519 96.38 2024 162,600,962 157,033,602 96.58 71,836 157,105,438 96.62 2025 181,187,502 174,416,303 96.26 52,102 174,468,405 96.29 Source: Indian River County, Florida Annual Comprehensive Financial Report for the Fiscal Year ended September 30, 2025. Principal Taxpayers The following table sets forth the principal property taxpayers in Indian River County, Florida for Fiscal Year 2025 (relating to taxes levied in tax/calendar year 2024): [Remainder of page intentionally left blank] 22 Indian River County, Florida Principal Property Taxpayers (Unaudited) Fiscal Year 2025 Taxes Levied % of Total Taxpayer in thousands Rank Taxes Levied Florida Power & Light Disney Vacation Dev. Inc. Ocean Trail LLC John's Island Club, Inc. MPT of Sebastian -Steward, LLC Welltower TCG Ridea Landlord, LLC Adult Community Total Services, Inc. 1920 South Highway AIA LLC Florida East Coast Railway EPC Guardian, LLC Total Principal Property Taxpayers Real Property Assessed Valuation $ 670,758,606 1 2.29% 76,245,372 2 0.26 36,134,960 3 0.12 35,446,065 4 0.12 33,988,624 5 0.12 33,110,734 6 0.11 33,092,306 7 0.11 27,246,743 8 0.09 26,712,882 9 0.09 25,507,924 10 0.09 $ 998,244,216 3.40% Total County Taxable Valuation $29,285,468,693 Sources: Indian River County Property Appraiser, www.ircpa.org Indian River County, Florida Annual Comprehensive Financial Report for the Fiscal Year ended September 30, 2025. Constitutional Amendments and Legislative Initiatives Affecting Ad Valorem Taxes Several amendments to the Florida Constitution and Florida legislative initiatives affecting ad valorem taxes have been approved by voters in the past including, but not limited to, the following. Save Our Homes Amendment. By voter referendum held on November 2, 1992, Article VII, Section 4 of the Florida Constitution was amended by adding thereto a subsection which, in effect, limits the increases in assessed just value of homestead property to the lesser of (1) three percent of the assessment for the prior year or (2) the percentage change in the Consumer Price Index for all urban consumers, U.S. City Average, all items 1967=100, or successor reports for the preceding calendar year as initially reported by the United States Department of Labor, Bureau of Labor Statistics. Further, the amendment provides that (a) no assessment shall exceed just value, (b) after any change of ownership of homestead property or upon termination of homestead status such property shall be reassessed at just value as of January 1 of the year following the year of sale or change of status, (c) new homestead property shall be assessed at just value as of January 1 of the year following the establishment of the homestead, and (d) changes, additions, reductions or improvements to homestead shall initially be assessed as provided for by general law, and thereafter as provided in the amendment. The amendment is known as the "Save Our Homes" amendment. The effective date of the amendment was January 5, 1993 and, pursuant to a ruling by the Supreme Court of the State of Florida, it began to 23 affect homestead property valuations commencing January 1, 1995 with 1994 assessed values being the base year for determining compliance. Constitutional amendments related to ad valorem exemptions. On January 29, 2008, in a special election held in conjunction with Florida's presidential primary, the requisite number of voters approved amendments to the State Constitution exempting certain portions of a property's assessed value from taxation. The amendments were effective beginning with the 2008 tax year. The following is a brief summary of certain important provisions contained in such amendments: • Provides for an additional exemption for the assessed value of homestead property between $50,000 and $75,000, thus doubling the existing general homestead exemption for property with an assessed value equal to or greater than $75,000. See "AD VALOREM TAXATION - General" herein for a description of the general $25,000 homestead exemption. • Permits owners of homestead property to transfer their Save Our Homes benefit (up to $500,000) to a new homestead property purchased within two years of the sale of their previous homestead property to which such benefit applied if the just value of the new homestead is greater than or is equal to the just value of the prior homestead. If the just value of the new homestead is less than the just value of the prior homestead, then owners of homestead property may transfer a proportional amount of their Save Our Homes benefit, such proportional amount equaling the just value of the new homestead divided by the just value of the prior homestead multiplied by the assessed value of the prior homestead. As discussed above, the Save Our Homes amendment generally limits annual increases in ad valorem tax assessments for those properties with homestead exemptions to the lesser of 3% or the annual rate of inflation. 0 Exempts from ad valorem taxation $25,000 of the assessed value of property subject to tangible personal property tax. 0 Limits increases in the assessed value of non -homestead property to 10% per year, subject to certain adjustments. The cap on increases is in effect for a 10 -year period, subject to extension by an affirmative vote of electors. See "- Extending the Limitation on Assessed Values of Non -Homesteaded Real Property" below for information concerning another approved constitutional amendment to extend the 10% cap on increases of non - homesteaded properties. Homestead Exemption Increase for Low -Income Seniors and Disabled Veterans. In the November 7, 2006 general election, the voters of Florida approved amendments to the State Constitution, which provide for an increase in the homestead (ad valorem tax) exemption to $50,000 from $25,000 for certain low-income seniors effective January 1, 2007 and provide a discount from the amount of ad valorem taxes for certain permanently disabled veterans effective December 7, 2006, respectively. 24 Homestead Portability Amendment. During the 2020 State legislative session, a constitutional amendment was proposed by the State legislature which would extend the period for a homestead property owner to transfer a prior Save Our Homes benefit to a new homestead from two years to three years (the "Portability Amendment"). Specifically, the Portability Amendment allows a homeowner who establishes a new homestead as of January 1 to have the new homestead assessed at less than just value if the homeowner received a prior homestead exemption as of January 1 of any of the immediately preceding three years. The Portability Amendment was approved by voters on November 3, 2020 and such amendment took effect on January 1, 2021. Exemptions for Certain Property Uses. In the November 4, 2008 general election, the voters of the State approved amendments to the State Constitution providing the Florida Legislature with authority to enact exemptions or special assessment protections for certain types of property subject to ad valorem taxation, including exemptions for conservation lands and residential wind damage resistance and renewable energy source improvements, and restrictions on the assessment of working waterfront properties. Thereafter, legislation was enacted which creates an exemption for land used exclusively for conservation purposes. Such exemption applies to property tax assessments made on or after January 1, 2011. Exemption for Deployed Military Personnel. In the November 2010 general election, voters approved a constitutional amendment which provides an additional homestead exemption for deployed military personnel. The exemption equals the percentage of days during the prior calendar year that the military homeowner was deployed outside of the United States in support of military operations designated by the legislature. This constitutional amendment took effect on January 1, 2011. Exemption for Disabled Veterans. In the November 2012 General Election, voters approved a constitutional amendment which allows totally or partially disabled veterans who were not Florida residents at the time of entering military service to qualify for the combat -related disabled veteran's ad valorem tax discount on homestead property. The amendment became effective on January 1, 2013. Exemption for Surviving Spouse of Veterans and First Responders. In the November 2012 General Election, voters approved a constitutional amendment which allows the State Legislature to provide ad valorem tax relief to the surviving spouse of a veteran who died from service -connected causes while on active duty as a member of the United States Armed Forces and to the surviving spouse of a first responder who died in the line of duty. The amount of tax relief, to be defined by general law, can equal the total amount or a portion of the ad valorem tax otherwise owed on the homestead property. The amendment became effective on January 1, 2013. During the 2020 State legislative session, a constitution amendment was proposed by the State legislature which would extend the discount on ad valorem taxes provided to certain honorably discharged veterans to their surviving spouses (the "Surviving Spouse Exemption"). Specifically, the Surviving 25 Spouse Exemption allows the same ad valorem tax discount on a homestead property for combat disabled veterans age 65 or older to transfer to the surviving spouse of a veteran receiving the discount if the surviving spouse holds the legal or beneficial title to the homestead, permanently resides thereon, and does not remarry. The amendment was approved by voters on November 3, 2020 and such amendment took effect on January 1, 2021. Exemption for Low Income Seniors. In the November 2012 General Election, voters approved a constitutional amendment which allows the State Legislature by general law to permit counties and municipalities, by ordinance, to grant an additional homestead tax exemption equal to the assessed value of homestead property to certain low income seniors. To be eligible for the additional homestead exemption, the county or municipality must have granted the exemption by ordinance, the property must have a just value of less than $250,000, the owner must have title to the property and maintained his or her permanent residence thereon for at least 25 years, the owner must be age 65 years or older and the owner's annual household income must be less than $27,300. The County has granted this additional exemption. The additional homestead tax exemption authorized by HJR 169 does not apply to school property taxes. In the November 2016 General Election, voters approved a constitutional amendment changing the existing homestead tax exemption for low-income seniors so that the value of property owned by eligible senior citizens with a household income of $20,000 or less could be assessed when they first apply for the exemption. The measure was designed to ensure eligible seniors' ability to be able to keep their tax exemption even if their home value exceeded $250,000 in the future. The amendment took effect on January 1, 2017 but is retroactive to January 1, 2013, meaning a senior who qualified for the exemption in 2013, but lost it, would regain the exemption. Various Changes to Ad Valorem Assessment, Exemptions and Definitions. During its 2013 Regular Session, the Florida Legislature passed Senate Bill 1830 ("SB 1830"), which was signed into law by the Governor and creates a number of changes affecting ad valorem taxation which became effective as of July 1, 2013. First, SB 1830 provides long- term lessees the ability to retain their homestead exemption and related assessment limitations and exemptions in certain instances and extends the time for property owners to appeal value Adjustment Board decisions on transfers of assessment limitations to conform with general court filing time frames. Second, SB 1830 inserts the term "algaculture" in the definition of "agricultural purpose" and inserts the term "aquacultural crops" in the provision specifying the valuation of certain annual agricultural crops, nonbearing fruit trees and nursery stock. Third, SB 1830 allows for an automatic renewal for assessment reductions related to certain additions to homestead properties used as living quarters for a parent or grandparent and aligns related appeal and penalty provisions to those for other homestead exemptions. Fourth, SB 1830 deletes a statutory requirement that the owner of Florida real property permanently reside upon such property 26 in order to qualify for a homestead exemption. This change conforms the statute at issue with the Florida Constitution by allowing non-resident owners of property to claim a homestead exemption if a person legally or naturally dependent upon the owner permanently resides on such property. Fifth, SB 1830 clarifies a drafting error regarding the property tax exemptions counties and cities may provide for certain low-income persons age 65 and older. Sixth, SB 1830 removes a residency requirement that a senior disabled veteran must have been a Florida resident at the time they entered the service to qualify for certain property tax exemptions. Seventh, SB 1830 repeals the ability for limited liability partnerships with a general partner that is a charitable 501(c)(3) organization to qualify for the affordable housing property tax exemption. Finally, SB 1830 exempts from property taxes property used exclusively for educational purposes when the entities that own the property and the educational facility are the same natural persons. Assessment of Renewable Energy Devices Upon Residential Property. Also during the Florida Legislature's 2013 Regular Session, the Florida Legislature passed House Bill 277 ("HB 277"), which provides that certain renewable energy devices are exempt from being considered when calculating the assessed value of residential property. HB 277 only applies to devices installed on or after January 1, 2013. HB 277 took effect on July 1, 2013. Reclassification of Agricultural Lands. Also during the Florida Legislature's 2013 Regular Session, the Florida Legislature passed House Bill 1193 ("HB 1193"), which eliminated three ways in which the Property Appraiser had authority to reclassify agricultural land as non-agricultural land. Additionally, HB 1193 relieves the value Adjustment Board of the authority to review the Property Appraisers' classifications of land upon its own motion. HB 1193 applies retroactively as of January 1, 2013. Exemption and Assessment of Renewable Energy Devices Upon all Real Property. In the August 2016 primary election, the voters in the State approved a constitutional amendment exempting the assessed value of certain renewable energy devices from the ad valorem tax on tangible personal property and prohibiting certain renewable energy devices from being considered when calculating the assessed value of all real property, not just real property used for residential purposes as provided for in HB 277 described above. This constitutional amendment took effect on January 1, 2018 and expires on December 31, 2037. Exemption for Disabled First Responders. In the November 2016 General Election, voters approved a constitutional amendment authorizing first responders who are totally and permanently disabled as a result of injuries sustained in the line of duty to receive ad valorem tax relief on the homestead property. The amount of tax relief, to be defined by general law, can equal the total amount or a portion of the ad valorem tax otherwise owed on the homestead property. Florida defines first responders as law enforcement officers, 27 correctional officers, firefighters, emergency medical technicians and paramedics. This amendment took effect on January 1, 2017. Extending the Limitation on Assessed Values of Non -Homesteaded Real Property. In the November 2018 General Election, voters approved a constitutional amendment removing the scheduled January 1, 2022 repeal of the limitation prohibiting the increase in the assessed value of non -homestead property to 10% per year. The limitation does not apply to property taxes levied by school districts. This amendment took effect on January 1, 2019. Exempting Assessed Value of a Renewable Energy Device. During the Florida Legislature's 2017 Regular Session, the Florida Legislature passed SB 90 ("SB 90") implementing Amendment 4, which was approved by the voters in August 2016. SB 90 exempts the assessed value of a renewable energy device from tangible personal property tax and the installation of those devices from determining the assessed value of real property, both residential and non-residential, for the purpose of ad valorem taxation. SB 90 also revises the definition of "renewable energy source device" to include power conditioning and storage devices, wiring, structural support and other components used as integral parts of such systems. The changes made by SB 90 expire on December 31, 2037. Future Amendments Relating to Ad Valorem Taxation. Historically, various legislative proposals and constitutional amendments relating to ad valorem taxation have been introduced in each session of the State legislature. Many of these proposals have provided for new or increased exemptions to ad valorem taxation and limited increases in assessed valuation of certain types of property or otherwise restricted the ability of local governments in the State to levy ad valorem taxes at current levels. There can be no assurance that similar or additional legislative or other proposals will not be introduced or enacted in the future that would have a material adverse effect upon the collection of ad valorem taxes by the County, the County's finances in general or the County's ad valorem taxing power. [Property Tax Reform. On April 29, 2025, the Speaker of the Florida House of Representatives announced the creation of the Select Committee on Property Taxes (the "Select Committee") to consider various property tax reforms in the State. On May 2, 2025, the Select Committee convened for its first meeting to discuss several proposals regarding providing property tax relief. The Select Committee has held subsequent meetings since May 2025. Certain recommendations from the Select Committee were filed for consideration during the 2026 regular session and, if enacted, would be placed on the November 2026 general election ballot. The Florida Legislature convened its 2026 regular session on January 13, 2026. The regular session ended on March 13, 2026 without the passage of significant legislation to address property tax reform. As such, it is expected that the Governor of the State will call a special session of the legislature to address property tax reform. Several proposed bills M. relating to property tax reform were filed in both the House and the Senate for consideration during the 2026 regular session. These bills varied greatly in their approach in addressing property tax reform, but all aimed to reduce the property tax burden for Florida property owners, particularly residential homestead property owners. Some sought to exempt homestead property from all property tax levies other than school district levies. Some provided this relief to certain of the senior population. Others, increased homestead property tax exemptions or added additional homestead exemptions for certain properties and would have applied to all property tax levies, including school district levies. Some increased or otherwise modified the homestead exemption portability benefit. Certain proposals revised the property assessment process, limiting the allowable increases in property assessments and/or how frequently property can be assessed. Bills were also filed that would affect the ability of local governments to increase ad valorem tax millages. Additional bills may be filed in anticipation of a special session and some of the previously filed bills may be amended or refiled for the expected special session. If any property tax reform bill is passed by the State legislature and approved by the Governor, it would then be subject to a state-wide referendum requiring at least 60% of the voters approving such measure to become law. There can be no assurance that any of the bills filed or amended during the regular session and refiled for the special session, or bills that are subsequently filed, will be approved by the House and Senate, or will be approved by the Governor or will be approved by 60 percent of voters of the State. The County cannot predict what legislation may be introduced and possibly enacted into law during the expected special session or in any future legislative session that could have a materially adverse effect on the ad valorem tax revenues of the County. However, the County does not expect any such proposals to impair its ability to pay the Series 2026 Bonds or the other Outstanding Bonds, all of which have been approved by referendum and are secured by the Ad Valorem Taxes as provided in the Bond Resolution. See "SECURITY FOR THE SERIES 2026 BONDS" herein.] CERTAIN INVESTMENT CONSIDERATIONS The purchase of the Series 2026 Bonds involves a degree of risk, as is the case with all investments. Factors that could affect the market price of the Series 2026 Bonds or the County's ability to perform its obligations under the Bond Resolution, including the timely payment of principal of and interest on the Series 2026 Bonds, include, but are not limited to, the following: 1. There is no assurance that any rating assigned to the Series 2026 Bonds by the rating agencies will continue for any given period of time or that it will not be lowered or withdrawn entirely by such rating agency, if in its judgment, circumstances warrant. A downgrade change in or withdrawal of any rating may have an adverse effect on the market price of the Series 2026 Bonds. 29 2. In the event of a default in the payment of principal of and interest on the Series 2026 Bonds, the remedies of the owners of the Series 2026 Bonds are limited under the Bond Resolution and may be further limited under Florida law. 3. There can be no assurance that legislation or other proposals will not be introduced or enacted in the future that would, or might apply to, or have a material adverse effect upon, the levy or collection of Ad Valorem Taxes or the County's finances. 4. The State of Florida is naturally susceptible to the effects of extreme weather events and natural disasters including floods, droughts, and hurricanes, which could result in negative economic impacts on communities including the County. Such effects can be exacerbated by a longer-term shift in the climate over several decades (commonly referred to as climate change, generally discussed in paragraph 5 below), including increasing global temperatures and rising sea levels. The occurrence of such extreme weather events could damage local infrastructure that provides essential services to the County. The economic impacts resulting from such extreme weather events could include a loss of revenue, interruption of service, and escalated recovery costs. The County is located on the east central coast of Florida and has been affected by hurricanes in the past and is likely to be affected in the future. 5. Numerous scientific studies on climate change show that, among other effects on the global ecosystem, sea levels may rise, extreme temperatures may become more common, and extreme weather events may become more frequent as a result of increasing global temperatures attributable to atmospheric pollution. Sea levels may continue to rise in the future due to the increasing temperature of the oceans causing thermal expansion and growing ocean volume from glaciers and ice caps melting into the ocean. Coastal areas like the County are at risk of substantial flood damage over time, affecting private development and public infrastructure, including roads, utilities, emergency services, schools, and parks. If this were to happen, the County could lose considerable tax revenues and many residents, businesses, and governmental operations along the waterfront could be displaced, and the County could be required to mitigate these effects at a potentially material cost. The County is unable to predict whether sea level rise or other impacts of climate change will occur, when they may occur, and if any such events occur, whether they will have a material adverse effect on the business operations or financial condition of the County. Additionally, climate change concerns have led, and may continue to lead, to new laws and regulations at the federal and state levels (including but not limited to air, water, hazardous substances and solid waste regulations) that could have a material adverse effect on the operations and/or financial condition of the County. The County has established a Comprehensive Emergency Management Plan and Local Mitigation Strategy Plan which identifies the natural hazards that may affect the County. The County has commenced a Vulnerability Assessment which is intended to inform and guide policies and responses to natural hazards. ka 6. Computer networks and systems used for data transmission and collection are vital to the efficient operations of the County. County systems provide support to departmental operations and constituent services by collecting and storing sensitive data, including intellectual property, security information, proprietary business process information, information applying to suppliers and business partners, and personally identifiable information of customers, constituents and employees. The secure processing, maintenance and transmission of this information is critical to department operations and the provision of citizen services. Increasingly, governmental entities are being targeted by cyberattacks (including, but not limited to, hacking, viruses, malware and other attacks on computers and other sensitive digital networks and systems) seeking to obtain confidential data or disrupt critical services. A rapidly changing cyber risk landscape may introduce new vulnerabilities and avenues that attackers/hackers can exploit in attempts to cause breaches or service disruptions. Employee error and/or malfeasance may also contribute to data loss or other system disruptions. Additionally, the County's computer networks and systems routinely interface and rely on third party systems that are also subject to the risks previously described. Any such breach could compromise networks and the confidentiality, integrity and availability of systems and the information stored there. The potential disruptions, access, modification, disclosure or destruction of data could result in interruption of the efficiency of County commerce, initiation of legal claims or proceedings, liability under laws that protect the privacy of personal information, regulatory penalties, disruptions in operations and the services provided and the loss of confidence in County operations, ultimately adversely affecting County revenues. [The County's cyber security program is managed by cyber security professionals within the Information Technology Department. This group's primary concern is protecting electronic assets and sensitive data stored on and transmitted through the County's networks and servers. This chiefly includes all financial data, employee records and other sensitive personnel information and sensitive customer data. Preventative actions being taken by the County include diligent firewall monitoring, proactive security evaluation of new software prior to launching them on the County's networks and servers, institution and consistent application of PCI (Payment Card Industry) security standards, and annual cybersecurity training for County employees. Access to County systems ends upon termination of employment with the County, and County -owned electronic assets are obtained from the terminated employee at that time. All external emails are heavily screened to ensure the County's cyber defenses are not penetrated. HIPAA (Health Insurance Portability and Accountability Act) and PCI compliance are also areas of great concern with respect to the County's cybersecurity efforts. Despite the County's efforts in this area, no assurance can be given that any cyberattacks, if successful, will not have a material adverse effect on the operations or financial condition of the County.] 7. [The outbreak of the highly contagious COVID-19 pandemic in the United States in March 2020 generally had a disruptive financial impact on local, state and national economies around the country, including without limitation fueling inflation and creating 31 supply chain issues. COVID-19 was considered a Public Health Emergency of International Concern by the World Health Organization. This led to quarantine and other "social distancing" measures throughout the United States. These measures included recommendations and warnings to limit non-essential travel and promote telecommuting. There can be no guarantee that State and/or local shut downs or closures similar to those implemented in 2020 will not happen in the future. It is possible the United States, including the State and the County, may experience increased COVID-19 cases, hospitalizations, and deaths as a result of current or future variants, or may experience a new viral pandemic, which could, in turn, impact State and local government finances.] Prospective purchasers of the Series 2026 Bonds should review carefully all of the provisions of the Bond Resolution the form of which is included in Appendix C attached to this Official Statement. LIABILITIES OF THE COUNTY Pension Plans The County employees participate in the Florida Retirement System ("FRS"). FRS was created pursuant to Chapter 121, Florida Statutes, to provide a defined benefit pension plan for participating public employees. See "APPENDIX B - Annual Comprehensive Financial Report" attached hereto, Note 14, for additional information on the FRS. Other Post -Employment Benefits Pursuant to the provision of Section 112.080 1, Florida Statutes, former employees who retire from the County and eligible dependents may continue to participate in the County's respective medical/prescription and life insurance plans as long as they pay the premium applicable to coverage elected. See "APPENDIX B Annual Comprehensive Financial Report" attached hereto, Note 15, for additional information on the County's post - employment benefit plans. LITIGATION [TO BE REVIEWED BY THE COUNTY ATTORNEY] There is no litigation pending or, to the knowledge of the County, threatened, which restrains or enjoins the issuance or delivery of the Series 2026 Bonds or questions or affects the validity of the Series 2026 Bonds or the proceedings and authority under which they are to be issued, or the authority of the County to annually levy ad valorem taxes to pay debt service on the Series 2026 Bonds in accordance with the Bond Resolution. Neither the creation, organization or existence of the County, nor the title of the present members of the County or other officers of the County in their respective offices is being contested. k% There is no litigation pending or, to the knowledge of the County, threatened, which, if it were decided against the County, would have a materially adverse impact upon the financial position of the County or its ability to perform its obligations to the Series 2026 Bondholders. The County experiences routine litigation and claims incidental to the conduct of its affairs. In the opinion of the County Attorney, there are no other actions presently pending or threatened, the adverse outcome of which would have a material adverse effect on the County's ability to pay debt service on the Series 2026 Bonds. The County is party to other various legal proceedings which individually are not expected to have a material adverse effect on its operations or financial condition, but may, in the aggregate, have a material impact thereon. However, in the opinion of the County Attorney, the County will either successfully defend such actions or otherwise resolve such matters without any material adverse consequences. LEGAL MATTERS Certain legal matters in connection with the authorization, issuance and sale of the Series 2026 Bonds are subject to the approval of Nabors, Giblin & Nickerson, P.A., Tampa, Florida, Bond Counsel, whose approving opinion will be available at the time of delivery of the Series 2026 Bonds. Nabors, Giblin, & Nickerson, P.A., Tampa, Florida, is also serving as Disclosure Counsel to the County. Certain legal matters will be passed upon for the County by Jennifer W. Shuler, Esq., County Attorney. The proposed form of the Bond Counsel opinion is attached hereto as Appendix D, and reference is made to such form of opinion for the complete text thereof. The actual legal opinion to be delivered may vary from that text if necessary to reflect facts and law on the date of delivery. The opinion will speak only as of its date, and subsequent distribution of it by recirculation of the Official Statement or otherwise shall create no implication that Bond Counsel has reviewed or expresses any opinion concerning any of the matters referenced in the opinion subsequent to its date. Bond Counsel has not been engaged to, nor has it undertaken to, review (1) the accuracy, completeness or sufficiency of this Official Statement or any other offering material relating to the Series 2026 Bonds; provided, however, that Bond Counsel will render an opinion to the Underwriter and the County relating to the accuracy of certain statements contained herein under the heading "TAX MATTERS" and certain statements which summarize provisions of the Bond Resolution and the Series 2026 Bonds, and (2) the compliance with any federal or state law with regard to the sale or distribution of the Series 2026 Bonds. 33 ENFORCEABILITY OF REMEDIES The remedies available to the owners of the Series 2026 Bonds upon a monetary or covenant default under the Bond Resolution are in many respects based upon judicial actions which are often subject to discretion, delay and equitable considerations. Under existing constitutional and statutory law and judicial decisions, the remedies specified by the Federal bankruptcy code, the Bond Resolution and the Series 2026 Bonds may not be readily available or may be limited. The various legal opinions to be delivered concurrently with the delivery of the Series 2026 Bonds (including Bond Counsel's approving opinion) will be qualified as to the enforceability of the various legal instruments, by limitations imposed by general principles of equity, bankruptcy, reorganization, insolvency or other similar laws affecting the rights of creditors enacted before or after such delivery. MUNICIPAL ADVISOR Hilltop Securities Inc., Orlando, Florida served as Municipal Advisor (the "Municipal Advisor") to the County with respect to the issuance of the Series 2026 Bonds. The Municipal Advisor has assisted the County in the preparation of this Official Statement and has advised the County as to other matters relating to the planning, structuring and issuance of the Series 2026 Bonds. The Municipal Advisor is not obligated to undertake and has not undertaken to make an independent verification or to assume responsibility for the accuracy, completeness or fairness of the information contained in this Official Statement. The fee payable to the Municipal Advisor is contingent upon the issuance and delivery of the Series 2026 Bonds. TAX MATTERS Opinion of Bond Counsel In the opinion of Bond Counsel, the form of which is included as APPENDIX D hereto, the interest on the Series 2026 Bonds is excludable from gross income of the owners thereof for federal income tax purposes and is not an item of tax preference for purposes of the federal alternative minimum tax under existing statutes, regulations, rulings and court decisions; provided, however, with respect to certain corporations, interest on the Series 2026 Bonds is taken into account in determining the annual adjusted financial statement income for the purpose of computing the alternative minimum tax imposed on such corporations. Failure by the County to comply subsequent to the issuance of the Series .2026 Bonds with certain requirements of the Internal Revenue Code of 1986, as amended (the "Code"), including but not limited to requirements regarding the use, expenditure and investment of Series 2026 Bond proceeds and the timely payment of certain investment earnings to the Treasury of the United States, may cause interest on the Series 2026 Bonds to become includable in gross income for federal income tax purposes retroactive to their a] date of issuance. The County has covenanted in the Bond Resolution to comply with all provisions of the Code necessary to, among other things, maintain the exclusion from gross income of interest on the Series 2026 Bonds for purposes of federal income taxation. In rendering its opinion, Bond Counsel has assumed continuing compliance with such covenants. Internal Revenue Code of 1986 The Code contains a number of provisions that apply to the Series 2026 Bonds, including, among other things, restrictions relating to the use or investment of the proceeds of the Series 2026 Bonds and thepayment of certain arbitrage earnings in excess of the "yield" on the Series 2026 Bonds to the Treasury of the United States of America. Noncompliance with such provisions may result in interest on the Series 2026 Bonds being included in gross income for federal income tax purposes retroactive to their date of issuance. Collateral Tax Consequences Except as described above, Bond Counsel will express no opinion regarding the federal income tax consequences resulting from the ownership of, receipt or accrual of interest on, or disposition of, the Series 2026 Bonds. Prospective purchasers of Series 2026 Bonds should be aware that the ownership of Series 2026 Bonds may result in other collateral federal tax consequences. For example, ownership of the Series 2026 Bonds may result in collateral tax consequences to various types of corporations relating to (1) denial of interest deduction to purchase or carry such Series 2026 Bonds, (2) the branch profits tax, and (3) the inclusion of interest on the Series 2026 Bonds in passive income for certain Subchapter S corporations. In addition, the interest on the Series 2026 Bonds may be included in gross income by recipients of certain Social Security and Railroad Retirement benefits. PURCHASE, OWNERSHIP, SALE OR DISPOSITION OF THE SERIES 2026 BONDS AND THE RECEIPT OR ACCRUAL OF THE INTEREST THEREON MAY HAVE ADVERSE FEDERAL TAX CONSEQUENCES FOR CERTAIN INDIVIDUAL AND CORPORATE BONDHOLDERS, INCLUDING, BUT NOT LIMITED TO, THE CONSEQUENCES REFERRED TO ABOVE. PROSPECTIVE SERIES 2026 BONDHOLDERS SHOULD CONSULT WITH THEIR TAX ADVISORS FOR INFORMATION IN THAT REGARD Other Tax Matters Interest on the Series 2026 Bonds may be subject to state or local income taxation under applicablestate or local laws in other jurisdictions. Purchasers of the Series 2026 Bonds should consult their own tax advisors as to the income tax status of interest on the Series 2026 Bonds in their particular state or local jurisdictions. 35 The Inflation Reduction Act, H.R. 5376 (the "IRA"), was passed by both houses of the U.S. Congress and was signed by the President on August 16, 2022. As enacted, the IRA includes a 15 percent alternative minimum tax to be imposed on the "adjusted financial statement income," as defined in the IRA, of certain corporations for tax years beginning after December 31, 2022. Interest on the Series 2026 Bonds will be included in the "adjusted financial statement income" of such corporations for purposes ofcomputing the corporate alternative minimum tax. Prospective purchasers that could be subject to this minimum tax should consult with their own tax advisors regarding the potential tax consequences of owning the Series 2026 Bonds. During prior years, legislative proposals have been introduced in Congress, and in some cases enacted, that altered certain federal tax consequences resulting from the ownership of obligations that aresimilar to the Series 2026 Bonds. In some cases, these proposals have contained provisions that altered these federal tax consequences on a retroactive basis. Such alteration of federal tax consequences may have affectedthe market value of obligations similar to the Series 2026 Bonds. From time to time, legislative proposals are pending which could have an effect on both the federal tax consequences resulting from ownership ofthe Series 2026 Bonds and their market value. No assurance can be given that additional legislative proposals will not be introduced or enacted that would or might apply to, or have an adverse effect upon,the Series 2026 Bonds. Original Issue Discount Certain of the Series 2026 Bonds (the "Discount Bonds") may be offered and sold to the public at anoriginal issue discount, which is the excess of the principal amount of the Discount Bonds over the initial offering price to the public, excluding bond houses, brokers or similar persons or organizations acting in the capacity of underwriters or wholesalers, at which initial offering price a substantial amount of the Discount Bonds of the same maturity was sold. Original issue discount represents interest which is excluded from gross income for federal income tax purposes to the same extent as interest on the Discount Bonds. Original issuediscount will accrue over the term of a Discount Bond at a constant interest rate compounded semi-annually. An initial purchaser who acquires a Discount Bond at the initial offering price thereof to the public will be treated as receiving an amount of interest excludable from gross income for federal income tax purposes equal to the original issue discount accruing during the period such purchaser holds such Discount Bonds and will increase the adjusted basis in such Discount Bonds by the amount of such accruing discount for purposes of determining taxable gain or loss on the sale or other disposition of such Discount Bonds. The federal income tax consequences of the purchase, ownership and prepayment, sale or other disposition ofDiscount Bonds which are not purchased in the initial offering at the initial offering price may be determined according to rules which differ from those above. Owners of Discount Bonds should consult their own tax advisors with respect to the precise determination for federal income tax purposes of interest accrued 36 upon sale, prepayment or other disposition of such Discount Bonds and with respect to the stateand local tax consequences of owning and disposing of such Discount Bonds. Original Issue Premium Certain of the Series 2026 Bonds (the "Premium Bonds") may be offered and sold to the public at an initial offering price in excess of the principal amount of such Premium Bond, which excess constitutes to an initial purchaser amortizable bond premium which is not deductible from gross income for Federal income tax purposes. The amount of amortizable bond premium for a taxable year is determined actuarially on a constant interest rate basis over the term of the Premium Bonds which term ends on the earlier of the maturity or call date for each Premium Bond which minimizes the yield on said Premium Bonds to the purchaser. For purposes of determining gain or loss on the sale or other disposition of a Premium Bond, an initial purchaser who acquires such obligation in the initial offering to the public at the initial offering price is required to decrease such purchaser's adjusted basis in such Premium Bond annually by the amount of amortizable bond premium for the taxable year. The amortization of bond premium may be taken into account as a reduction in the amount of tax-exempt income for purposes of determining various other taxconsequences of owning such Premium Bonds. The federal income tax consequences of the purchase, ownership and sale or other disposition of Premium Bonds which are not purchased in the initial offeringat the initial offering price may be determined according to rules which differ from those described above. Owners of the Premium Bonds are advised that they should consult with their own tax advisors with respect to the state and local tax consequences of owning such Premium Bonds. DISCLOSURE REQUIRED BY FLORIDA BLUE SKY REGULATIONS Pursuant to Section 517.051, Florida Statutes, as amended, no person may directly or indirectly offer or sell securities of the County except by an offering circular containing full and fair disclosure of all defaults as to principal or interest on its obligations since December 31, 1975, as provided by rule of the Financial Services Commission (the "Commission"). Pursuant to the Florida Administrative Code, the Commission has required the disclosure of the amounts and types of defaults, any legal proceedings resulting from such defaults, whether a trustee or receiver has been appointed over the assets of the County, and certain additional financial information, unless the County believes in good faith that such information would not be considered material by a reasonable investor. The County is not and has not been in default on any bond issued since December 31, 1975 which it believes would be considered material by a reasonable investor of the Series 2026 Bonds. Although the County is not aware of any other defaults with respect to bonds or other debt obligations as to which it has served only as a conduit issuer, it has not undertaken an independent review or investigation of such bonds or other debt obligations 37 for which it served only as a conduit issuer. To the extent any of such bonds or other debt obligations are in default as to principal and/or interest or otherwise, the obligation of the County thereunder is limited solely to payment from funds received by the party on whose behalf such bonds or other debt obligations were issued, and the County is not obligated to pay the principal of or interest on such bonds or other debt obligations from any funds of the County. The County in good faith believes the disclosure of such defaults or investigations would not be considered material by a reasonable investor in the Series 2026 Bonds. RATING [S&P Global Ratings ("S&P")] has assigned a municipal bond rating of "[__]" Q ) to the Series 2026 Bonds. Such rating reflects the view of [] and an explanation of the significance of such rating may be obtained only from at the following address: S&P Global Ratings, 55 Water Street, New York, New York 10041. Generally, a rating agency bases its rating on the information and materials furnished to it and on investigations, studies and assumptions of its own. There is no assurance that such rating will continue for any given period of time or that such rating will not be revised downward or withdrawn entirely by S&P, if, in the judgment of S&P, circumstances so warrant. Any such downward revision or withdrawal of such rating may have an adverse effect upon the market price of the Series 2026 Bonds. UNDERWRITING The Series 2026 Bonds are being purchased by [UNDERWRITER] (the "Underwriter"), at a purchase price of $[ 1 (par amount of the Series 2026 Bonds, less an underwriter's discount of $[ and plus net original issue premium of $[ ]). See "ESTIMATED SOURCES AND USES OF FUNDS" herein. The offer of the Underwriter to purchase the Series 2026 Bonds, as accepted by the County, provides for the Underwriter to purchase all of the Series 2026 Bonds. The Series 2026 Bonds may be offered and sold to certain dealers and others at prices lower than such offering prices and such public offering prices may be changed, from time to time, by the Underwriter. CONTINUING DISCLOSURE The County has covenanted for the benefit of the Series 2026 Bondholders to provide certain financial information and operating data relating to the County and the Series 2026 Bonds in each year and to provide notices of the occurrence of certain enumerated material events. Such covenant shall only apply so long as the Series 2026 Bonds remain outstanding under the Bond Resolution. The covenant shall also cease upon the termination of the continuing disclosure requirements of S.E.C. Rule 15c2 -12(b)(5) (the "Rule") by legislative, judicial or administrative action. The County has agreed to file annual financial information and operating data and its audited financial statements (collectively, the "Annual Report") with the Municipal Services Rulemaking Board (the "MSRB") through its Electronic Municipal Market Access system ("EMMA"), as described in "Appendix E - Form of Continuing Disclosure Certificate." The County has agreed to file notices of certain enumerated material events, when and if they occur, with the MSRB through EMMA. The County has engaged HTS Continuing Disclosure Services, a Division of Hilltop Securities Inc., as its dissemination agent. The specific nature of the financial information, operating data, and of the type of events which trigger a disclosure obligation, and other. details of the undertaking are described in "Appendix E - Form of Continuing Disclosure Certificate" attached hereto. The Continuing Disclosure Certificate shall be executed by the County prior to the issuance of the Series 2026 Bonds. These covenants have been made in order to assist the underwriters for the Series 2026 Bonds in complying with the continuing disclosure requirements of the Rule. With respect to the Series 2026 Bonds, no party other than the County is obligated to provide, nor is expected to provide, any continuing disclosure information with respect to the aforementioned Rule. FINANCIAL STATEMENTS The financial statements of the County as of and for the Fiscal Year ended September 30, 2025, included in the County's Annual Comprehensive Financial Report (Fiscal Year Ended September 30, 2025) attached to this Official Statement as Appendix B, have been audited by James Moore & Co. P.L., independent auditors (the "Auditors"), as stated in their report dated March 9, 2026, included in Appendix B. The Annual Comprehensive Financial Report, including such financial statements and the Auditors' report, has been included in this Official Statement as a public document, and the consent of the Auditors was not requested. The Auditors have not been engaged to perform and have not performed, since the date of the Auditors' report any procedures on the financial statements addressed in that report. The Auditors also have not performed any procedures relating to this Official Statement. INVESTMENT POLICY OF THE COUNTY Pursuant to the requirements of Section 218.415, Florida Statutes, as amended, the County adopted a written investment policy applicable to all cash and surplus funds of the County except debt proceeds and monetary assets held by other entities on behalf of the County. The objectives of the investment policy, listed in order of importance, are: (1) to preserve capital in the overall portfolio and to maintain the safety of principal; (2) to remain sufficiently liquid to meet disbursement requirements that might be reasonably anticipated; and (3) to manage the investment portfolio to provide a competitive return consistent with 39 the objectives in items 1 and 2 and other risk limitations described in the investment policy. The investment policy notes that the highest priority of all investment activities shall be the safety of principal and liquidity of funds. The optimization of investment returns shall be secondary to the requirements for safety and liquidity. The investment policy limits the securities eligible for inclusion in the County's investment portfolio. Derivatives, reverse repurchase agreements or similar forms of leverage are prohibited. Cryptocurrency purchases are also specifically prohibited. The investment policy provides that County investments shall be managed to maintain liquidity for meeting the County's need for cash and to limit potential market risks. All investments must have stated maturities of 10 years or less and no more than 25% of the portfolio shall be invested in instruments with stated final maturities greater than five years. The portfolio shall have securities with varying maturities and at least 10% of the portfolio shall be invested in readily available funds. The Clerk is responsible for conducting investment transactions for the County. The investment policy also requires the establishment of an Investment Advisory Committee which is tasked with evaluating the investment performance and the current and future liquidity needs and investment strategies. It is also responsible for preparing periodic reports for the Board. The Clerk is required to establish a system of investment internal controls and operational procedures. Subject to the requirements of Section 218.415, Florida Statutes, as amended, the investment policy may be modified by the Board. The most recent investment policy of the County became effective as of [January 9, 2024]. CONTINGENT FEES The County has retained Bond Counsel, Disclosure Counsel and the Municipal Advisor with respect to the authorization, sale, execution and delivery of the Series 2026 Bonds. Payment of the fees of Bond Counsel, Disclosure Counsel and the Municipal Advisor and an underwriting discount to the Underwriter are each contingent upon the issuance of the Series 2026 Bonds. MISCELLANEOUS All information included herein has been provided by the County, except where attributed to other sources. The summaries of and references to all documents, statutes, reports and other instruments referred to herein do not purport to be complete, comprehensive or definitive, and each such reference or summary is qualified in its entirety by reference to each such document, statute, report or other instrument. The information herein has been compiled from official and other sources and, while not guaranteed by the County, is believed to be correct. So far as any statements made in this Official Statement 40 and the appendices attached hereto involve matters of opinion or of estimates whether or not expressly stated, they are set forth as such and not as representation of fact, and no representation is made that any of the estimates will be realized. AUTHORIZATION OF OFFICIAL STATEMENT The delivery of this Official Statement has been duly authorized by the County. At the time of delivery of the Series 2026 Bonds, the Chairman of the Board and the County Administrator will furnish a certificate to the effect that neither the Chairman nor said County Administrator has any knowledge or reason to believe that this Official Statement, as of its date and as of the date of delivery of the Series 2026 Bonds, contains any untrue statement of a material fact or omits to state a material fact necessary in order to make the statements made herein, in light of the circumstances under which they were made, not misleading. INDIAN RIVER COUNTY, FLORIDA By: Chairman, Board of County Commissioners County Administrator 41 APPENDIX A GENERAL INFORMATION REGARDING INDIAN RIVER COUNTY APPENDIX B ANNUAL COMPREHENSIVE FINANCIAL REPORT FOR THE FISCAL YEAR ENDED SEPTEMBER 30, 2025 APPENDIX C FORM OF BOND RESOLUTION APPENDIX D FORM OF APPROVING OPINION OF BOND COUNSEL APPENDIX E FORM OF CONTINUING DISCLOSURE CERTIFICATE EXHIBIT D FORM OF CONTINUING DISCLOSURE CERTIFICATE CONTINUING DISCLOSURE CERTIFICATE This Continuing Disclosure Certificate (the "Disclosure Certificate") is executed and delivered by Indian River County, Florida (the "County") in connection with the issuance of $[PAR AMOUNT] aggregate principal amount of its Indian River County, Florida General Obligation Bonds, Series 2026 (the "Series 2026 Bonds"). The Series 2026 Bonds are being issued pursuant to Resolution No. 2023-004 adopted by the Board of County Commissioners (the "Board") of the County on January 31, 2023, as supplemented, as particularly supplemented by Resolution No. 2026- adopted by the Board on [May 19], 2026 (collectively, the "Bond Resolution"). Capitalized terms used but not otherwise defined herein shall have the same meaning as when used in the Bond Resolution unless the context would clearly indicate otherwise. The County covenants and agrees as follows: SECTION 1. PURPOSE OF DISCLOSURE CERTIFICATE. This Disclosure Certificate is being executed and delivered by the County for the benefit of the Series 2026 Bondholders and to assist the Underwriter of the Series 2026 Bonds in complying with the continuing disclosure requirements of Rule 15c2-12 promulgated by the Securities and Exchange Commission ("SEC") pursuant to the Securities Exchange Act of 1934 (the "Rule"). SECTION 2. NATURE OF UNDERTAKING. The County, in accordance with the Rule, hereby covenants to provide or cause to be provided to the Electronic Municipal Market Access system ("EMMA") and maintained by the Municipal Securities Rulemaking Board (the "MSRB") for purposes of the Rule and any other entity authorized and approved by the SEC from time to time to act as a repository for purposes of complying with the Rule: (a) (i) annual financial information and operating data of the type described as "Annual Information" in Section 3(a) hereof for each Fiscal Year ending on or after September 30, 2026, not later than the following April 30, and (ii) audited financial statements of the County for each such Fiscal Year, not later than the following April 30, if then available as described in the final paragraph of this Section 2; and (b) in a timely manner not in excess of ten business days after the occurrence of any Specified Event described in Section 3(b) hereof (a "Specified Event"), notice of (i) any Specified Event described in Section 3(b) hereof, (ii) the County's failure to provide the Annual Information on or prior to the date specified above, and (iii) any change in the accounting principles applied in the preparation of its annual financial statements, any change in its Fiscal Year, and the termination of the County's continuing disclosure obligations. The County expects that audited annual financial statements will be prepared and will be filed together with the Annual Information identified below. The accounting principles to be applied in the preparation of those financial statements will be generally accepted accounting principles, as modified by applicable State of Florida requirements and the governmental accounting standards promulgated by the Governmental Accounting Standards Board. In the event that the audited annual financial statements are not available by the date on which the Annual Information will be provided, the County will provide unaudited financial statements by the date specified and audited financial statements when available. SECTION 3. ANNUAL INFORMATION AND SPECIFIED EVENTS. (a) "Annual Information" to be provided by the County for the immediately completed Fiscal Year shall consist of information contained in the tables entitled: (1) "Indian River County, Florida Property Tax Millage Rates for Direct and Overlapping Governments (Unaudited);" (2) "Indian River County, Florida Assessed Value and Actual Value of Taxable Property (Unaudited);" (3) "Indian River County, Florida Property Tax Levies and Collections (Unaudited);" and (4) "Indian River County, Florida Principal Property Taxpayers (Unaudited)" in the Official Statement prepared for the Series 2026 Bonds and presented in a manner consistent with the presentation in the Official Statement; provided, however, any of such information may be provided in the audited financial statements filed in accordance with this Disclosure Certificate. (b) Specified Events shall include the occurrence of the following events, within the meaning of the Rule, with respect to the Series 2026 Bonds: (1) principal and interest payment delinquencies; (2) non-payment related defaults, if material; (3) unscheduled draws on debt service reserves reflecting financial difficulties; (4) unscheduled draws on credit enhancements reflecting financial difficulties; 2 (5) substitution of credit or liquidity providers, or their failure to perform; (6) adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax status of the Series 2026 Bonds, or other material events affecting the tax status of the Series 2026 Bonds; (7) modifications to rights of the holders of the Series 2026 Bonds, if material; (8) any Series 2026 Bond calls, if material, and tender offers; (9) defeasances in whole or in part of the Series 2026 Bonds; (10) release, substitution, or sale of property securing repayment of the Series 2026 Bonds, if material; (11) any changes in the ratings assigned to the Series 2026 Bonds; (12) bankruptcy, insolvency, receivership or similar event of the County (this event is considered to occur when any of the following occur: the appointment of a receiver, fiscal agent or similar officer for the County in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the County, or if such jurisdiction has been assumed by leaving the existing governing body and officials or officers in possession but subject to the supervision and orders of a court or governmental authority, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the County); (13) the consummation of a merger, consolidation, or acquisition involving the County or the sale of all or substantially all of the assets of the County, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms; (14) appointment of a successor or additional trustee or the change of name of a trustee; (15) Incurrence of a financial obligation of the County, if material, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a financial obligation of the County, any of which affect holders of the Series 2026 Bonds; and 3 (16) Default, event of acceleration, termination event, modification of terms, or other similar events under the terms of the financial obligation of the County, any of which reflect financial difficulties. The County may, from time to time, in its sole discretion, choose to provide notice of the occurrence of certain other events if, in the judgment of the County, such other events are material with respect to the Series 2026 Bonds, but the County does not specifically undertake to commit to provide any such additional notice of the occurrence of any material event except those events listed above. Any voluntary inclusion by the County of supplemental information that is not required hereunder shall not expand the obligations of the County hereunder and the County shall have no obligation to update such supplemental information or include it in any subsequent report. SECTION 4. SUBMISSION OF INFORMATION TO THE MSRB. The information required to be disclosed pursuant to Sections 2 and 3 of this Disclosure Certificate shall be submitted to EMMA and/or any successor repository required by federal or state law or regulation. Subject to future changes in submission rules and regulations, such submissions shall be provided to the MSRB, through EMMA, in portable document format ("PDF") files configured to permit documents to be saved, viewed, printed and retransmitted by electronic means. Such PDF files are required to be word - searchable (allowing the user to search for specific terms used within the document through a search or find function available in a software package). Subject to future changes in submission rules and regulations, at the time that such information is submitted through EMMA, the County, or any dissemination agent engaged by the County pursuant to Section 7 hereof, shall also provide to the MSRB information necessary to accurately identify: (A) the category of information being provided; (B) the period covered by the County's Annual Comprehensive Financial Report and any additional financial information and operating data being provided; (C) the issues or specific securities to which such submission is related or otherwise material (including CUSIP number, County name, state, issue description/securities name, dated date, maturity date, and/or coupon rate); (D) the name of any Obligated Person other than the County; (E) the name and date of the document being submitted; and (F) contact information for the submitter. SECTION 5. REMEDIES; NO EVENT OF DEFAULT. The County agrees that its undertaking pursuant to the Rule set forth above is intended to be for the III benefit of the holders and beneficial owners of the Series 2026 Bonds and shall be enforceable by any such holder or beneficial owner; provided that the right to enforce the provisions of this undertaking shall be limited to a right to obtain specific performance of the County's obligations hereunder and any failure by the County to comply with the provisions of this undertaking shall not be an event of default with respect to the Series 2026 Bonds under the Bond Resolution. SECTION 6. SEPARATE BOND REPORT NOT REQUIRED; INCORPORATION BY REFERENCE. The requirements of this Disclosure Certificate do not necessitate the preparation of any separate annual report addressing only the Series 2026 Bonds. These requirements may be met by the filing of a combined bond report or the County's Annual Comprehensive Financial Report; provided, such report includes all of the required information and is available by April 30. Additionally, the County may incorporate any information provided in any prior filing with EMMA or one of the Nationally Recognized Municipal Securities Information Repositories recognized by the SEC for purposes of the Rule or other information filed with the SEC or included in any final official statement of the County; provided, such final official statement is filed with the MSRB. SECTION 7. DISSEMINATION AGENTS. The County may, from time to time, appoint or engage a dissemination agent to assist it in carrying out its obligations under this Disclosure Certificate, and may discharge any such agent, with or without appointing a successor dissemination agent. The County has appointed HTS Continuing Disclosure Services, a Division of Hilltop Securities Inc., as its initial dissemination agent. SECTION 8. TERMINATION. The County's obligations under this Disclosure Certificate shall cease (a) upon the legal defeasance, prior redemption, payment in full of all of the Series 2026 Bonds, or (b) when the County no longer remains an Obligated Person with respect to the Series 2026 Bonds within the meaning of the Rule, or (c) upon the termination of the continuing disclosure requirements of the Rule by legislative, judicial or administrative action. SECTION 9. AMENDMENTS. The County reserves the right to amend the provisions of this Disclosure Certificate as may be necessary or appropriate to achieve its compliance with any applicable federal securities law or rule, to cure any ambiguity, inconsistency or formal defect or omission, and to address any change in circumstances arising from a change in legal requirements, change in law, or change in the identity, nature, or status of the County, or type of business conducted by the County. Any such amendment shall be made only in a manner consistent with the Rule and any amendments and interpretations thereof by the SEC. Additionally, compliance with any provision of this Disclosure Certificate may be waived. Any such amendment or waiver will not be effective unless this Disclosure Certificate (as amended or taking into account such waiver) would have complied with the requirements of the Rule at the time of the primary offering of the Series 2026 Bonds, after taking into account any applicable amendments to or official 5 interpretations of the Rule, as well as any change in circumstances, and until the County shall have received either (a) a written opinion of bond or other qualified independent special counsel selected by the County that the amendment or waiver would not materially impair the interests of holders or beneficial owners of the Series 2026 Bonds, or (b) the written consent to the amendment or waiver of the holders of at least a majority of the principal amount of the Series 2026 Bonds then outstanding. Annual Information containing any amended operating data or financial information shall explain, in narrative form, the reasons for any such amendment and the impact of the change on the type of operating data or financial information being provided. Additionally, in the year in which any change in accounting principles is made, the County shall present a comparison (in narrative form and also, if feasible, in quantitative form) between the financial statements as prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles in accordance with the requirements of the Governmental Accounting Standards Board. SECTION 10. OBLIGATED PERSONS. If any person other than the County becomes an Obligated Person (as defined in the Rule) relating to the Series 2026 Bonds, the County shall use its best efforts to require such Obligated Person to comply with all provisions of the Rule applicable to such Obligated Person. Dated: July [1], 2026 IM ATTESTED AND COUNTERSIGNED: By: Clerk of the Circuit Court and Ex -Officio Clerk of the Board of County Commissioners of Indian River County, Florida 51 Chairman, Board of County Commissioners