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Tax Compliance Risk The issuance of tax-exempt bonds is subject to a number of requirements under the <br />United States Internal Revenue Code, as enforced by the Internal Revenue Service (IRS). You must take <br />certain steps and make certain representations prior to the issuance of tax-exempt bonds. You also must <br />covenant to take certain additional actions after issuance of the tax-exempt bonds. A breach of your <br />representations or your failure to comply with certain tax -related covenants may cause the interest on the <br />bonds to become taxable retroactively to the date of issuance of the bonds, which may result in an increase <br />in the interest rate that you pay on the bonds or the mandatory redemption of the bonds. The IRS also may <br />audit you or your bonds, in some cases on a random basis and in other cases targeted to specific types of <br />bond issues or tax concerns. If the bonds are declared taxable, or if you are subject to audit, the market price <br />of your bonds may be adversely affected. Further, your ability to issue other tax-exempt bonds also may <br />be limited. <br />This description is only a brief summary of issues relating to tax compliance and is not intended as legal <br />advice. You should consult with your bond counsel for further information regarding the tax implications <br />of issuing the bonds. <br />Future Financing Risk and Covenant Compliance Your ability to issue additional bonds prior to maturity <br />may be limited, depending on the terms of any financial covenants included in your financing plan. In the <br />event you do not meet financial covenants in the future prior to maturity, such as debt service coverage <br />ratios, you may be prohibited from issuing additional bonds under terms, conditions, or security that you <br />might desire. In addition, you may be required to implement increases in fees charged to your customers <br />in order to comply with the terms of specific rate covenants included in your financing plan. <br />This description is only a brief summary of issues relating to future financing risk and covenant compliance <br />and is not intended as legal advice. You should consult with your bond counsel for further information <br />regarding the covenants and other conditions of issuing the bonds and additional bonds. <br />