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knowledge and belief the Official Statement is a eomplete and accurate representation of the facts and representations made therein as of the date of the Official Statement. Section To Tax Covenant 7. of F The City covenants and agrees with the holders from time to time of the • of its officers employees or Bonds that it will not take or permit to be taken by any . agents an action which would cause the interest on the Bonds to become subject to age � 1986, as aYnended (the Oode ) , and the taxation under the Internal Revenue Code of u Regulations promulgated thereunder, in effect at the tie of such actions, T� � five and that it will take or cause its officers, employees or agents to take , all affirms its power that may be necessary to ensure that such interest will not action thin � � become subject to taxation under the Code and applicable Treasury Regulations, latione as presently . subject or as hereafter amended and made applicable to the Bonds. ting The Cif will comply with requirements necessary under the '� � � (a) Code to establish and main, the exclusion from gross incom e of the intere�t r on the Bonds under Section 103 of the Code, including without hm tation re- quiremen is relatin g � to temporary periods for investments, Hmitations on amounts invested at a yield greater than the Meld on the Bonds and the vestment earnings to the United Mates if the Bonds rebate of excess �n g issued in calendar with other obligations reasonably expected to be (together � • amount of � �� 000, year 1993) exceed the small issuer exception amo � � purposes of qualifying for the small issuer exception to the €b � for purp � �g determines and arbitrage rebate requirements , the City finds , federal g t bonds (other the�x� t the a e to face amount of all tax - e x� emp , . declares the aggregate dinate entities of the private activity bonds) issued by the City (and all subor p y City) during the calendar year in which the Bonds are issued is not reasonably expected to exceed $5, 000, 000, within the meaning of Section 148 (f) (4 ) ( ) of the Code, 7.03. The y fit further covenants not to use the proceeds of the Bonds or to an of them to be used, in such a manner as to cause the cause or permit them or y . + Bon to Sections 1 and 11 Bonds be "private activity bonds within the mean3 ng of e through 150 of the Code* qualify the Bonds as Piqua fled tax- exempt obligations' '� # .. In order to � y within 'thin the meanie of Section 265 (b) (3) of the Code , the City mak es the following factual statements and representations (a) the Bonds are not "p rivate activity bonds" as defined In Section 141 of the Code; the Cif hereby designatea the Bonds as "qua ad tax - exempt (b) y y - de obligations" for purposes of Section 265 (b) (3) of the Code; reasonably anticipated amount of tax - exempt obligations (c) the p F bonds � an rivate activity bonds other than qualified 501 (c) i (other than � entities �� the City) which will be issued by the City (and all subordinate e d g urin calendar year 1993 win not exceed $10, 000 , 000; and 474167 1� "200 -1a