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Matching Fund Loan Note

Bonds issued by the PFA.

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

The Government’s revenue bonds are secured by the pledge of Matching Fund Revenues. Matching Fund Revenues are those revenues received by the Government from the United States Department of the Treasury, through the Secretary of the Interior, as a transfer of federal excise taxes imposed and collected under the Internal Revenue code of 1986, as amended (the “Code”) in any Fiscal Year on any product produced in the Virgin Islands and exported to the United States and that is subject to federal excise tax that qualifies for transfer to the Government (the “Matching Fund Revenues”). Rum is the principal article presently produced in the Virgin Islands and exported to the United States that is subject to federal excise tax that qualifies for transfer to the Government under the applicable provisions of the Revised Organic Act and the Code. Matching Fund Revenues have been transferred to the Government since 1954 in accordance with certain Acts of the United Sates Congress.

The matching fund bonds were issued for working capital and for various capital projects and are secured by the Government’s Matching Fund Revenue.

Act 8540, which was signed into law on February 8, 2022, created the Matching Fund Special Purpose Securitization Corporation (“MFSPSC”), a special purpose independent and autonomous corporation and government instrumentality of the Virgin Islands for the limited purpose of:

a) acquiring during the Transfer Period (as defined in the Act) (x) all of the right, title and interest in the Matching Fund Receipts (as defined in the Act) that would have been paid to the Government and (y) the Related Rights (as contained in the Act); and

(b) issuing Matching Fund Securitization Bonds and the Residual Certificate (both as defined in the Act) in order to pay a portion of the purchase price for the Matching Fund Receipts and the Related Rights.

On April 6, 2022, the MFSPSC issued $952,825,000 Matching Fund Securitization Bonds consisting of $930,315,000 Series 2022A triple-tax-exempt bonds and $22,510,000 Series 2022B federally taxable bonds (together, the “Bonds”). Proceeds of the Series 2022A Bonds were used to (i) fund the purchase of all the PFA Bonds to be Refunded that are validly tendered pursuant to the Tender Offer and to pay a portion of the cost of redeeming and/or defeasing certain of the PFA Bonds to be Refunded that are not purchased pursuant to the Invitation, and (ii) pay the costs of issuance of the Series 2022A Bonds. Proceeds of the Series 2022B Bonds were used to pay (i) the cost of redeeming and/or defeasing certain of the Untendered PFA Bonds to be Refunded and (ii) the costs of issuance of the Series 2022 Bonds. In addition, proceeds of the Series 2022 Bonds were used to pay Capitalized Interest on a portion of the Series 2022 Bonds.

Please view for historical reference the offering statement(s) and bond report(s) for more information on individual bond series issued under this bond type.

Offering Statements
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