Untitled Texas Attorney General Opinion

@ffice of tip !Zlttornep Q&nerd &tate of PCexae DAN MORALES ATTORNEY GENERAL September IS,1993 Ms. Mary Webb opinion No. DM-255 Chair Texas Agricultural Fhtance Authority Re: Whether the Texas Agriculturai P.O. Box 12847 Fiice Authority may use bond proceeds Austin, Texas 78711 from the Texas AgticulturaI Fund to reimburse the Department of Agriculture for administrative expenses incurred on behalf of theauthority (RQ-393) DWMS. Webb: You have requested an opinion co naming the Texas Agricuhural Fiice Authoritfs (“the authority”) use of the Texas Agricuhural Fund (“the fund”) for rambursrment of administmtive costs. You advise us that the !knd consists of three separate accounts: a program account; an interest and sinking tImd account; and a reserve al%mnlt.~ Cdy the only business conducted by the authority is related to the provision of financial assktance through the fund? The tinance division of the Depmtment of Agriculture (“the department”), administers various programs on behalf of the authority, preparea the authority’s portion ofthe annual report and covers the authority in its internal audits. These eqenses are tinanced by appropriations to the department tiom the state’s general revenue fund. You ask whether the authority is prohibited from using the tbnd and the investment income contained therein to reimburse the department for various administmtive expenses which you state are necessary as “preparation to meet the need of providing linancial assistance to the agriathural community.” It is our opinion that the authority is not prohibited t?om makhtg expenditures from the fund to pay for expemes incurred in administexing the timd in krtherance of the speciftc purposes for which it was created. p. 1323 MsMaryWebb - Page 2 @M-255) The authority’s enabling legislation provides that: The commissione-r with the assistance of the board shall administer the Texas Agricultural Fiice Authority. The bomd shall reimburse the Department of Agriculture for expenses incurred m required by the business of the m&or@ with the approval of a majority of the board. Agric. Code 3 58.015(a) (emphasis added). You have suggested that the enabling legislation, speci6cally the above italicized language, clearly supports the proposition that the department shag be reimbursed for various administrative expenses incurred on behalf of the authority. We agree. However, the Texas Constitution places a restriction on the use of the fund by prohibiting its use for any purpose other thsn to provide tinancial assistance to agricultursJ businesses. Speciftcally, article III, section 49-i of the constimtion provides in part: (a) The Texas agricultural timd shall be used only to prow& financial assistance to ahlop, increase, improve, w expand the production, processing, marketing, w export of crq or praiucts grown orprohcedphtariity in this skzte Sy agrictdtura~ businesses domic&d in this state. . . . . . (c) Income from the invesbnent of money in the jim~!~that is not immediately committed to the payment of the principal of and interest on the bonds or the provision of tinancial assistance shall be used to create new emplqvment and business opporhnittes in the state through diversification and expansion of agricultural or rural small businesses, as provided by the legislature. Tex. Const. art. III 5 49-i(a), (c) (emphasis added). The specitk grant of power in article 49-i(a) carries with it by necessary implication the grant of such additional powers as may be necessaq to effectuate its purpose. See First Nat? Bank of Port Arthur v. City of Port Arthur, 35 S.W.2d. 258 (Tex. Civ. App.-Port Arthur 1931, no writ) (bond proceeds may be used in a manner necessarily implied to carry out purpose and intent of constitutional provision). Furthermore, we are cognizant of the fact that the fund and more speci6cally, the bond proceeds may be used for reimbursemem of administrative costs. Eligible agricultural businesses or lenders participating in the authority’s programs shall pay the costs of applying for, participating in, and administering and servicing the program, in amounts the board considers reasonable and necessary. Any costs not paid by the ehgible agrkultural businesses or lenders shall be paid from the p. 1324 MaMarywebb-Pagc3 (DM-255) fimak of the author@, in&ding those@nds establishedfrom bond proceeds. (Emphasis added.) . . Proceeds of the bonds issued under Subsection (c) of this section shall be deposited in the Texas agricuhural Smd and applied in accordance with the resolution authorizing the bonds: (1) to pruviak hncial assistance to cligiile agricultural bUSill=; (2) to pay costs of issuance of those bonds and the administration of any financial assistance program established with the money in the Texas agriadtural fund, and (3) together with any other available timds, to pay the principal of or inter& on or to discharge or raiean, in whole or in part, any outstanding bonds isaued by the authority. Agric. Code 8 58.03 l(c),(d) (emphasis added). It is clear that to the extent allowed by the resolution authorizing the bonds, the bond proceeds may be used to pay for the . . admuwtdve expemes of the authority in the administration of authorized purposes as enunciated in article III, section 49-i of the Texas Constitution. Hence we conclude that such proceeds may also be used to reimburse the department for like expenses on behalf of theauthority. We now turn to the repayments of financial assistance and the investment income which is also contained in the fund. Section 58.032(c) of the Agriadturc Code provides in part: Repayments of tinancial as&stance under any program funded in whole or in part with the proceeds of any series of general obligation bonds shah be deposited first in the interest and sinking account as prescrii by the board’s resolutions authorizing such series of general obligation bonds, and second in the reserve account in respect of such series resolutions authorizing such series of general obligation bonds until that account is tUy timded as prescribed by the board’s resohttions. . . . In addition To the extent the board determines that any money credited to the Texas agricuhural tknd from repayments of tinancial assistance is not required by Subsection (c) of this section . . that money may be wed by the authori@ to pny the principal of and interest on revenue bonds issued by the authority or for any other authorizedpu~ of p. 1325 Ms.MaryW&b - Page 4 (DM-255) theauthwity,in- with this chqter and the authri~‘s nrsolutians au~gensral ob&atim bomk Id. 5 58.032(d) (emphasis added). Furthermore., article III, section 49-i(c) mandates that the investment income contained in the iimd which is not obligated to the payment of the principalofandintaestonthebondsortheprovisionoffiwrcialassistanceshallbeused to provide for speci!ic agricukural purposes, as provided by the legislature. In section 58.023(c) of the Agriculture Code, the legislature provides that the fund, including mvestnainwn&nUlybcusedtopay~expeMesofthefinancialassistanw program. Hence, we wnclude that repayments of Glacial assistance and income on investmend money wntained in the fhd may be used to pay for the expemzs of . . . admmmmgthefund. SUMMARY The Texas Agricultmnl Furance Authority may use bond proceeds Tom the Texas Agriadtural Fund to reimburse the Department of Agriculture for administrative Qcpenses incurred on behalf of the authority. DAN MORALES Attorney Oeneral of Texas WILL PRYOR Ftik+sistantAttomeyoeneral MARYELLER Deputy Attorney Oeneral for Litigation RENEAHICKS State Solicitor MADELEINE B. JOHNSON Chair, Opiion Committee Prepared by Toya C. Cook AssistantAttO~General p. 1326