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issuance of the Notes. It is the understanding of the City that the covenants contained herein are intended to assure compliance • Code and any regulationsgpromulgated f U.S. Department of the Treasury pursuant thereto. In the event that`► u f or .` hereafterpromulgated #f or expandprovisions of I applicable i the Notes, the City will 1. requiredo comply with any covenantI , ! herein failure I comply,the opinion of nationally. bond counsel,1t adversely affect the exemption fl federal 4me taxation of interest on the Notes undersection In the event that regulations or rulings are hereafterpromulgated !I additional .' requirements .` applicable 1 . the City agrees comply with the additional requirements to the extent necessary, in the opinion of nationally recognized bond counsel, to preserve the exemption 1 taxation of interest on I ., under section# I the #f'. In furtherance of such intention,. City hereby authorizes . Mayor,the Mayor Pro Tem, the City Manager, the Directorof Financeand the City Clerk (collectively, the certificates or renorts rewired bi with the purpose fr the issuance of the Notes. I Allocation I and LimitatioqpgJExpenditures ! ► ects. The City covenants on its books and records/ f. . with the requirementsof 11 The City recognizes that in order for the proceeds to be considered used for the reimbursement of costs, the proceeds must be allocated o expenditures within 18 monthsof the ! expenditure is made, or (2) the Projects are completed; but in no event later than three years after the date on which the original expenditure is paid. The foregoing notwithstanding, the City recognizes that in order for proceeds to be expended under the Code, the sale proceeds or investment earnings must Iowa 101101 will not adversely . tax-exempt of # For purposes , ll not be obligated to comply with this covenant if it obtains an opinion that such failure to comply I ` t, i r �� 1Of the interest. (e) Disposition of the Proiects. The City covenants that the property constituting the Projects will not'�C_sold or otherwise disposed in a transaction resulting in the receipt by the City of or otherany action , . in connection with such disposition on an opinion or nationaily-recognizeaDona counsel " e ZiCL1011 LaKull 111 C*IXICC11011 such sale or other dispositionadversely .ffect the tax-exempt status1i the Notes. For purposes I #' I r the portionproperty 4 i g personal property an# disposed in the ordinary course shall not be treated as a transaction resulting in the receipt of cash or other compensation. For purposes hereof, the City shall not be obligated to comply with this covenant if it obtains an opinion that such failure to comply 1 adverselyexcludabilityf incomefederal .x purposes from "fl