98-34 PROVIDING FOR THE ISSUANCE OF GENERAL OBLIGATION BONDS

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with such advice as may be given; (d) to file such forms, statements and supporting documents as may be required and in a timely manner; and (e) if deemed necessary or advis- able by its officers, to employ and pay fiscal agents, �nancial advisors, attorneys and other persons to assist the City in such compliance. Section 16. Reimbursement. None of the proceeds of the Bonds will be used to pay, directly or indirectly, in whole or in part, for an expenditure that has been paid by the City prior to the date hereof except (i) architectural or engineering costs incurred prior to commencement of any of the Project (ii) or expenditures for which an intent to reimburse it as properly declared under Treasury Regulations Section 1.103-18. This Ordinance is in itself a declaration of official intent under Treasury Regulations Section 1.103-18 as to all costs of the Project paid after the date hereof and prior to issuance of the Bonds. Section 17. Qualified Tax-exempt Obligations. The City recognizes the provisions of Section 265(b)(3) of the Code which provide that a "qualified tax-exempt obligation" as therein defined may be treated by certain financial institutions as if it were acquired on August 7, 1986, for certain purposes. The City hereby designates the Bonds for purposes of Section 265(b)(3) of the Code as a "qualified tax-exempt obligation" as provided therein. Section 18. Opinion of Counsel Exception. The City reserves the right to use or invest moneys in connection with the Bonds in any manner, or to make changes in the Project, or to use the Project in any manner, provided it shall first have received an opinion from an attorney or a firm of attorneys of nationally recognized standing in matters pertaining to Tax-exempt bonds to the effect that use or investment of such moneys or the changes in or use of such infrastructure as contemplated will not result in loss or impairment of Tax-exempt status for the Bonds. ' -24- '