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interest on the Note from becoming taxable for federal income tax purposes for the owners thereof (other than any owner who is a "substantial user" or "related person thereto" within the meaning of Section l03(b) of the Code} including but not limited to taking all actions required of it under Section 103(c)(6) of the Code. To this end, the City shall: (A) cause the Borrower to maintain records identifying all "gross proceeds" attributable to the Note, the yield at which such gross proceeds are invested, any arbitrage profit derived therefrom, and any earnings derived from the investment of such arbitrage profit; (B) make and maintain on file all annual determinations of the amount, if any, of excess arbitrage required to be rebated to the United States; (c) rebate to the United States at least once every five years the amount, if any, which is required to be rebated to the United States, including the last installment which shall be made no later than 30 days after the day on which the Note is paid in full; (D) not invest "gross proceeds" in any acquired nonpurpose obligations so as to deflect arbitrage otherwise payable to the United States as a "prohibited payment" to a third party; (E) refrain from investing any "gross proceeds" allocable to the Note in acquired nonpurpose obligations at'a yield in excess of the yield on the Note to the extent such gross proceeds exceed in any calendar year more than 150% of the debt service requirements for the Note in that calendar year; and (F) retain on file all records of the annual determination of the rebate amount until six (6) years after the retirement of the Note; (2) The City hereby represents and covenants that any fees received by it in connection with the issuance of the Note shall be spent as quickly as practicable and until spent shall not be invested in acquired nonpurpose obligations the yield on which exceeds the yield on the Note. 21