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38 Not Bank-Qualified Obligations The Series 2020 Bonds have not been designated by the Issuer as “qualified tax-exempt obligations” within the meaning of Section 265(b)(3) of the Code. Legislative Proposals Bond Counsel’s opinion is given as of its date and Bond Counsel assumes no obligation to update, revise, or supplement such opinion to reflect any changes in facts or circumstances or any changes in law that may hereafter occur. Proposals are regularly introduced in both the United States House of Representatives and the United States Senate that, if enacted, could alter or affect the tax-exempt status on municipal bonds. For example, the recent federal tax reform legislation (formerly known as the Tax Cuts and Jobs Act) signed by President Trump as of December 22, 2017, significantly changed the income tax rates for individuals and corporations and modified the alternative minimum tax for tax years beginning after December 31, 2017, and altered other existing tax law in a manner that may affect the market price for, or marketability of, the Series 2020 Bonds. Prospective purchasers of the Series 2020 Bonds should consult their own tax advisors regarding the impact of any such change in law. The above is not a comprehensive list of all federal tax consequences which may arise from the receipt of interest on the Series 2020 Bonds. The receipt of interest on the Series 2020 Bonds may otherwise affect the federal or state income tax liability of the recipient based on the particular taxes to which the recipient is subject and the particular tax status of other items or deductions. Bond Counsel expresses no opinion regarding any such consequences. All prospective purchasers of the Series 2020 Bonds are encouraged to consult with their personal tax advisors as to the tax consequences of, or tax considerations for, purchasing or holding the Series 2020 Bonds. THE FINANCIAL FEASIBILITY STUDY The Financial Feasibility Study (the “Forecast”) attached hereto in “APPENDIX B - FINANCIAL FEASIBILITY STUDY” prepared by the Borrower and examined by CliftonLarsonAllen LLP, Minneapolis, Minnesota, for the _______ years ending September 30, 20___ is based upon assumptions made by the Borrower. No assurance can be given that the results described in the Forecast will be achieved. The Forecast is based on assumptions made by management of the Borrower as to, among other things, future utilization levels, future costs and future revenues. The Forecast should be read in its entirety. The Forecast is based on various assumptions that represent only the beliefs of the Borrower’s management as to the most probable future events and are subject to material uncertainties. No assurances can be given that the Borrower will, in fact, be able to generate sufficient revenue and attain the utilization levels as stated in the Forecast, and variations from the Forecast for each of such matters should be expected to occur. Accordingly, the operations and financial condition of the Borrower in the future will inevitably vary from those set forth in the Forecast, and such variance may be material and adverse. See “RISK FACTORS – Financial Feasibility Study” in this Official Statement. The Borrower has not assumed any responsibility to update the Forecast or to provide any financial forecast or projections in the future. The Underwriter has not made any independent inquiry as to the assumptions on which the Forecast is based and assume no responsibility therefor.