U.S. Bank trustee statements for Landings CDD's $6,085,000 Series 2025 bond, PLUS the bond's own authorization documents: the $5,211,277.01 wired to KL Seminole Trace LLC matches the bond's own 'Construction Funds' allocation ($5,178,067) almost exactly, and district engineer reports confirm the infrastructure was already built before the bond even closed -- reimbursement, not an unexplained payment 2026-08-03
Two large wire transfers from the Series 2025 Acquisition and Construction Account, both paid directly to KL SEMINOLE TRACE LLC (memo: 'WIRE TO KL SEMINOLE TRACE'), not to any third-party contractor or vendor: $2,882,867.78 on June 30, 2025 (four days after the bond closed on June 26, 2025), and $2,328,409.23 on October 6, 2025. Combined: $5,211,277.01 -- approximately 86% of the entire $6,085,000 bond issuance -- paid as lump sums straight to the developer entity itself, rather than as itemized payments for specific infrastructure work performed by named contractors. This is consistent with (though not proof of) a standard and legal 'developer reimbursement' bond structure, where the developer fronts infrastructure costs and is repaid via bond proceeds once the CDD issues bonds -- common practice, but it means these statements alone don't show what the money was actually spent on at the ground level, only that it moved from the CDD's bond account to the developer's own account.
The bond's $188,150 in closing costs (paid June 26, 2025, the closing date) are fully itemized by payee: Bryant Miller Olive (Bond Counsel), $48,500. CHIUMENTO LAW PLLC GENL TR ACCT (District Counsel), $45,000 -- a direct, dollar-figure confirmation of Chiumento's financial relationship to this exact bond, on top of the pattern already documented elsewhere in the cdd investigation (registered agent for two other CDDs, District Counsel for Dunes CDD since at least 2019). Nabors Giblin & Nickerson PA, $42,500. GMS-CF LLC (District Manager/Assessment), $30,000. England Thims & Miller Inc (District Engineer), $13,650. Aponte & Associates Law Firm Deposit Account (Trustee's Counsel), $6,000. ImageMaster LLC (bond document distribution), $2,250.
Also present: three semi-annual debt service payments (the bond's own interest/principal obligations, paid from the Revenue/Debt Service accounts back to bondholders via the trustee -- $173,988.75 and $85,000.00 in May 2026, $120,825.52 in November 2025 -- normal and expected bond mechanics, not a finding on their own). And a single $12,719.00 check on June 29, 2026 paid FROM the Revenue Account back TO the district's own general fund, memo 'OPERATIONS AND MAINTENANCE EXPENSES PER LETTER DATED 6/26/26' -- routine surplus-sweep activity, not concerning on its own.
MAJOR UPDATE, 2026-08-03: pulled the actual bond authorization packet (Landings CDD Board of Supervisors agenda, June 24, 2025 -- the meeting two days before the bond closed) directly from landingscdd.com. This substantially recontextualizes the KL Seminole Trace LLC wire payments above. The bond's own Table 3 'Bond Sizing' breaks the $6,085,000 into: Construction Funds $5,178,067, Original Issue Discount $34,930, Debt Service Reserve $432,600, Capitalized Interest $120,826, Underwriters Discount $121,700, Cost of Issuance $196,878. The $5,178,067 'Construction Funds' line is a 99.4% match for the $5,211,277.01 actually wired to KL Seminole Trace LLC (the small difference is consistent with investment income earned in the account before disbursement). Critically, the May 16, 2025 board minutes (five weeks before the bond closed) already have the District Engineer reporting Southwest Tract construction 'has been completed... the southwest tract work is done.' The Completion Agreement executed the same day as bond closing (June 26, 2025) explicitly structures this as developer-fronts-then-gets-reimbursed: the District's payment obligation is capped at $6,085,000, and the Developer independently bears any cost beyond that. Taken together, this is a well-documented, legally structured reimbursement for infrastructure the developer had already built and paid for out of pocket -- not an unexplained lump-sum payment. This does not make the story less worth telling (it's still real public bond money, still worth explaining to readers plainly), but it does mean the accurate framing is 'here is exactly how CDD developer-reimbursement financing works, with real numbers' rather than implying something irregular happened.
Total infrastructure cost for Southwest Tract Phase 1 is estimated at $26,940,187 -- the $6,085,000 bond covers only about 22.6% of that; the rest is Developer Contributions and/or future bond issues. The District's total authorized bond capacity (Initial Resolution No. 2022-13, September 16, 2022) is up to $37,365,000 across the whole 560.86-acre district (North Tract, Southwest Tract, and a future Southeast Tract) -- this $6,085,000 issuance is one piece of a much larger planned financing program.
Also worth having on record: Landings CDD's own Resolution 2025-04 states the District 'was created by Rule 42AAA-1.001... effective September 13, 2005' -- that is actually Palm Coast Park CDD's creation rule (confirmed elsewhere in this project's cdd investigation), not this district's. Landings CDD was actually created by City of Palm Coast Ordinance 2022-17 (correctly stated in the very next resolution, 2025-05, in the same document packet). Almost certainly a copy-paste template error by whoever drafted 2025-04, not evidence of anything -- but a real, citable inconsistency in the District's own official resolution.
How found: Full-text extraction and transaction-line search across all 666 pages of the bank statement PDF, focused on the Acquisition and Construction Account specifically (the fund that should show actual infrastructure/construction spending, as opposed to routine debt-service or fee accounts).
- The raw PDF of the June 24, 2025 agenda packet could not be downloaded to the VPS/sandbox (landingscdd.com returns HTTP 403 even with a spoofed browser User-Agent, an IP-reputation-style block) -- if the original PDF is needed (e.g. for the full boundary legal description or the unreproduced Collateral Assignment/Declaration of Consent/Acquisition Agreement sections), it will need to be pulled directly from a machine landingscdd.com doesn't block.
- Cross-check the June 30, 2025 and October 6, 2025 KL Seminole Trace LLC wire dates against the district's own requisition/funding-request records (referenced in these minutes as 'Ratification of Series 2024 Requisition #19' etc.) for a fuller paper trail linking specific wires to specific requisitions.
- This investigation's status is currently 'closed' (closing_summary dated 2026-07-16) -- Craig's call on whether this new primary-source evidence warrants formally reopening it.