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this franchise shall terminate. The price to be paid by the City for the <br />property that may be acquired by the City from a Grantee, by purchase, <br />condemnation or otherwise, shall, to the extent permitted by law, exclude all <br />value of this franchise. <br /> <br /> Section 11. Trustee° The Huntington National Bank, Cleveland, Ohio, <br />is hereby approved as TrUstee for the Bonds. <br /> <br /> Section 12. Tax Compliance Covenants and Transcript of Proceeding,~. <br /> (a) The Issuer covenants that it will restrict, and that it will take such <br /> actions as are reasonably necessary to require the Trustee in its capacity as <br /> Trustee to restrict the use of the proceeds of the Series 1991 Bonds in such <br /> manner and to such extent, if any, as maybe necessary, after taking into account <br /> reasonable expectations at the time of the delivery of and payment for the Series <br /> 1991 Bonds, so that the Series 1991 Bonds will not constitute arbitrage bonds <br /> under Section 148 of the Internal Revenue Code of 1986, as amended (the "Code") <br /> and the apPlicable regulations prescribed under that Section. To that end, the <br /> Authorized Official, or any other officer having responsibility for issuing the <br /> Series 1991 Bonds, shall, alone or with any other officer, agent, or employee of <br /> or consultant to the Issuer, give an appropriate certificate of the Issuer for <br /> inclusion in the transcript of proceedings for the Series 1991 Bonds, setting <br /> forth the reasonable expectations of the Issuer regarding the amount and use of <br /> all the proceeds of the Series 1991 Bonds and the facts, estimates, and <br /> circumstances on which those exceptions are based, which certificate may be <br /> premised in part on the reasonable expectations and the facts, estimates, and <br /> circumstances as provided by the Independent Engineer, all as of the date of <br /> delivery of and payment for the Series 1991 Bonds. <br /> <br /> The Issuer covenants and represents that it will take all actions <br /> that may be required of the Issuer for the interest on the Series 1991 Bonds to <br /> be and remain excludable from gross income for federal income tax purposes, and <br /> that it has not taken and will not take or omit to take any actions which, if <br /> taken or omitted, would adversely affect such exclusion from gross income for <br /> federal income tax purposes, under the provisions of the Code and applicable <br /> amendments thereto, until and unless, and except to the extent the Issuer obtains <br /> a written Opinion of Bond Counsel that this covenant need not be complied with <br /> in order for the interest on the Series 1991 Bonds to continue to be excludable <br /> from gross income for federal income tax purposes. <br /> <br /> The Issuer will, among other acts of compliance, apply the proceeds <br />of the Series 1991 Bonds, restrict the yield on investments of, or on obligations <br />acquired with, such proceeds, make timely rebate payments to the federal <br />government, maintain books and records, and refrain from certain uses of <br />proceeds, all in such manner and to the extent necessary for the interest on the <br />Series 1991 Bonds to be and remain excluded from gross income fOr federal income <br />tax purposes; and the Authorized Official and other appropriate officers are <br />hereby authorized and directed to take any and all such actions, make such rebate <br />payments, and make or give such reports and certifications as may be appropriate <br />to assure such exclusion of that interest. <br /> <br /> (b) The Clerk shall furnish to the Original Purchaser a true <br />transcript of proceedings certified by the Clerk, of all proceedings had with <br />reference to the issuance of the Series 1991 Bonds along With such other <br />information for the records of the Issuer as is necessary to determine the <br />regularity and validity 'of th® issuance of the Series 1991 Bonds; <br /> <br /> Section 13. Bond Insurance. The Legislative Authority hereby <br />authorizes the Fiscal Officer to make application for, and to purchase, with <br />respect to the Series 1991 Bonds, a municipal bond insurance policy and hereby <br />ratifies any application made. Reasonably standard provisions pertaining to such <br />insurance policy and reasonable changes to the Indenture relating to such <br />insurance policy shall be approved by the officers executing the Indenture, which <br /> <br />-12- <br /> <br /> <br />