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' � 1 <br />will be transferred directly, or indirectly trans- <br />ferred or deemed transferred to a person other than <br />a governmental unit in a fashion that would in sub- <br />stance constitute a loan of said Series 1988 Bond <br />proceeds; <br />(c) The Redevelopment District will not take any <br />action or fail to take any action with respect to <br />the Series 1988 Bonds that would result in the loss <br />of the exclusion from gross income for federal tax <br />purposes of interest on the Series 1988 Bonds pur- <br />suant to Section 103(a) of the Internal Revenue Code <br />of 1986, as amended (the "Code ") , as in effect on <br />the date of delivery of the Series 1988 Bonds, nor <br />will the Commission act in any manner which would <br />adversely affect such exclusion. The Commission <br />further covenants that it will not make any invest- <br />ment or do any other act or thing during the period <br />that any Series 1988 Bond is outstanding hereunder <br />which would cause any Series 1988 Bond to be an <br />"arbitrage bond" within the meaning of Section 148 <br />of the Code and the regulations applicable thereto <br />as in effect on the date of delivery of the Series <br />1988 Bonds. The Commission shall comply with the <br />arbitrage rebate requirements under Section 148 of <br />the Code to the extent applicable; and <br />(d) All officers, members, employees and agents of <br />the Commission, the Department and the City are <br />authorized and directed to provide certifications of <br />facts and estimates that are material to the reason- <br />able expectations of the Commission as of the date <br />the Series 1988 Bonds are issued and to enter into <br />covenants on behalf of the Commission evidencing the <br />Commission's commitments made herein. In particu- <br />lar, all or any officers, members, employees and <br />agents of the Commission, the Department and the <br />City are authorized to certify and /or enter into <br />covenants for the Redevelopment District regarding <br />the facts and circumstances and reasonable expecta- <br />tions of the Commission on the date the Series 1988 <br />Bonds are issued and the commitments made by the <br />Commission herein regarding the amount and use of <br />the proceeds of the Series 1988 Bonds. <br />SECTION 16. Notwithstanding any other provisions of this Series <br />1988 Bond Resolution, the covenants and authorizations contained in <br />this Series 1988 Bond Resolution ( "Tax Sections ") which are designed <br />to preserve the exclusion of interest on the Series 1988 Bonds from <br />gross income under federal law ( "Tax Exemption ") need not be complied <br />with if the Redevelopment District receives an opinion of bond <br />-28- <br />