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The representations set forth in this certificate are limited to factual matters only. Nothing in this
certificate represents Colliers’ interpretation of any laws, including specifically Sections 103 and 148 of
the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned
understands that the foregoing information will be relied upon by the Issuer and the Borrower with respect
to certain of the representations set forth in the Tax Certificate and with respect to compliance with the
federal income tax rules affecting the Bonds, and by Williams Mullen, in connection with rendering its
opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the
preparation of the Internal Revenue Service Form 8038, and other federal income tax advice that it may
give to the Issuer and the Borrower from time to time relating to the Bonds.
[Signature Page Follows]
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