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Federal income tax laws generally restrict the ability to earn arbitrage in
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

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