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connection with the Obligations. “Arbitrage,” in this context, refers to any profit
earned from investing the proceeds from the issuance of any Obligations at a yield
that is higher than that on such Obligations.

Federal income tax laws restrict Arbitrage via two separate mechanisms: “yield
restriction” and the “rebate requirement.” Yield restriction prohibits the investment
of bond proceeds at a rate higher than the yield on the related Obligations. The
rebate requirement requires an issuer to rebate to the federal government any
Arbitrage earned from the investment of Obligations.

Federal income tax laws provide exceptions to the yield restriction and rebate
requirement rules, the most common of which are applicable to bond proceeds
allocated to construction expenditures. Certain procedures related to these
exceptions are set forth in Section VII below (see procedures A and B, related to
exceptions from yield restriction, and procedure C, related to exceptions from the
rebate requirement). The exceptions must be evaluated independently, as the
applicability of an exception from yield restriction does not guarantee an
exception from the rebate requirement. Bond Counsel should be consulted in
determining the available exceptions and procedures with respect to Obligations
issued for construction projects involving timelines in excess of those described
below.

The Responsible Person will review the Closing Documents and Section VII below
periodically (at least once a fiscal year) to ascertain compliance with Arbitrage
restrictions and applicable exceptions.

VI. Review of Federal Tax Certificate for Each Issuance

The Issuer's Director of Finance/Chief Financial Officer (such officer, together
with other employees of the Issuer who report to such officer, are, collectively,
the "Responsible Person") will review and track the federal tax certificate prepared
in connection with each issuance of Obligations.

VII. Compliance Procedures Applicable to Obligations Issued for Construction and
Acquisition Purposes

With respect to the investment and expenditure of the proceeds of the Obligations
that are issued to finance public improvements or to acquire land or personal
property, the Responsible Person will:

A. Instruct the appropriate person who is primarily responsible for the
construction, renovation or acquisition of the facilities financed or refinanced
with the Obligations (the “Project”) that (i) binding contracts for the
expenditure of at least 5% of the proceeds of the Obligations must be entered
into within six months of the date of closing of the Obligations (the "Issue

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