51-91 $4,750,000 Water System Mortgage Revenue Bonds

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Net Revenues) and the Water Reserve Fund, all as defined and further described in the Preliminary Official Statement. The payment of the Bond Service Charges on the' Series 1991 Bonds is to be secured (i) by a pledge of and lien on the Special Funds, Net Revenues and the Revenue Fund (to the extent the moneys therein constitute Net Revenues) and the Water Reserve Fund, all as further described in the Preliminary Official Statement. If a fractional interest rate is bid, the fraction must be 1/Sth or 1/20th of 1% or a whole multiple thereof. Nc.interest rate shall exceed nine percent (9%). Different rates may be bid for different maturities, but only one rate may be specified for all Series 1991 Bonds maturing on the same date, and the maximum difference between the highest rate and the lowest rate stated in a bid may not exceed 300 basis points. It is contemplated that the Fiscal Officer of the Issuer will promptly consider the bids and award the Series 1991 Bonds on the basis hereinafter described. It is contemplated that the Series 1991 Bonds will be available for delivery to DTC in definitive form on or about August 15, 1991. Legal matters incident to the issuance of the Series 1991 Bonds and with regard to the tax-exempt status of the interest thereon are subject to the approving legal opinion of Calfee, Halter & Griswold, Bond Counsel, which will be furnished at the expense of the Issuer at the time the Series 1991 Bonds are ~delivered to the successful bidder, an original counterpart of which opinion will be delivered with the Series 1991 Bonds to DTC. That opinion will include an opinion, based upon and assuming compliance with covenants and the accuracy and representations and certifications of the Issuer, that under existing laW (a) the interest on the Series 1991 Bonds (i) is excluded from gross income for federal income tax purposes under the Internal Revenue Code of 1986, as amended (the "Code"), (ii) is not treated as an item of tax preference for purposes of the alternative minimum tax imposed on individuals and corporations by the Code, and (iii) is exempt from the Ohio personal income tax, the Ohio corporate franchise tax (to the extent computed on the net income basis) and income taxes imposed by municipalities and other political subdivisions in Ohio, and (b) the Series 1991 Bonds are not "private activity bonds" as defined in the Code. The Series 1991 Bonds are not "qualified tax-exempt obligations,, as defined in the Code. Under the Code, the interest on the Series 1991 Bonds may be subject to alternative minimum, environmental and branch profits taxes imposed on certain corporations, and to a tax imposed on excess net passive income of certain S corporations. For a more complete discussion of tax aspects, see the Preliminary Official Statement referred to below. The successful bidder agrees to provide to the Issuer and Bond Counsel information (i) as to bona fide initial offering -4-