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25 Taxability, see “THE SERIES 2020 BONDS – Redemption or Prepayment – Mandatory Redemption Upon Determination of Taxability.” Possible Limitations on the Mortgage The lien on the Borrower’s interest in the Project and security interest in the equipment, fixtures and personal property, may be limited by the following: (i) statutory liens; (ii) rights arising in favor of the United States of America or any agency thereof; (iii) present or future prohibitions against assignment contained in any federal statutes or regulations; (iv) constructive trusts, equitable liens or other rights impressed or conferred by any state or federal court in the exercise of its equitable jurisdiction; (v) federal bankruptcy or state insolvency laws affecting assignments of revenues earned after any effective institution of bankruptcy or insolvency proceedings by or against the Borrower; (vi) rights of third parties in any revenues, including revenues converted to cash, not in possession of the Trustee; and (vii) the requirement that appropriate continuation statements be filed in accordance with the Minnesota Uniform Commercial Code. Property Taxes It is anticipated that the Borrower will pay property taxes on the 2020 Project, which includes the town center. The Borrower will not pay property taxes on the 2018 Project as the 2018 Project is exempt from property taxes under current Minnesota law. The system of real property taxation in Minnesota is complex and involves the City of Roseville, Minnesota, Ramsey County, the school district, and other local taxing jurisdictions. There have been many revisions to the property tax system over the years by the Minnesota legislature and no assurance can be made that property taxes payable by the Borrower on the 2020 Project will not increase in the future or that the 2018 Project will not become subject to property taxes in the future. Increases in the rate of property taxes on the 2020 Project (or if the 2018 Project were to become subject to property taxes) could have an adverse impact on the operating costs of the Borrower. The Borrower’s assumptions for the anticipated initial amount of property taxes to be paid with respect to the 2020 Project are set forth in “APPENDIX B - FINANCIAL FEASIBILITY STUDY” in this Official Statement. Risk of Early Redemption There are a number of circumstances under which all or a portion of the Series 2020 Bonds may be redeemed prior to their stated maturity. See “THE SERIES 2020 BONDS – Redemption or Prepayment” and “SECURITY FOR THE SERIES 2020 BONDS” in this Official Statement. Effect of Affiliates; Conflicts with Affiliates; Related Party Transactions; No Restrictions Manager currently provides administrative and oversight services, such as accounting services, employee benefits and human resources, marketing support, management information systems, and the services of the Manager’s key administrative staff to affiliates of the Borrower and plans to continue to do so in the future for such affiliate’s facilities and future facilities to be developed by the Limited Guarantor and future affiliates. The Borrower expects that the Manager will provide such administrative and oversight services to the Project and the Borrower on a long-term basis. Conflicts in the allocation of time and resources may arise with respect to the Borrower as between the Project and the other facilities of the affiliates, to the detriment of operations of the Project and the Borrower. Neither the Indenture nor the Loan Agreement directly restricts the business activities of the Borrower, or any affiliate. Accordingly, the Borrower and any affiliate may become engaged in other full-time business activities and only devote such time and attention to the operation of the Project as they, in their discretion, determine necessary in the circumstances. The Borrower, together with any of its affiliates, may develop,