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STATEMENT OF BOND COUNSEL <br />Re: City of Little Canada, Minnesota—$9,319,750 Multifamily Housing Revenue Bonds <br />(Twin Lake Apartments Project) <br />The above-referenced bonds to be issued by the City of Little Canada, Minnesota, to finance the <br />acquisition and construction of an approximately 87,723 square-foot rentable apartment <br />community that will consist of an approximately 60-unit multifamily housing development for <br />households of low and moderate income, and functionally related facilities, including an <br />underground parking garage, expected to be known as Twin Lake Apartments, located at the <br />northwest comer of Twin Lake Boulevard and Bankers Drive, Little Canada, Minnesota (the <br />"Project"), require an allocation of tax exempt bonding authority since they are to be issued as <br />tax exempt "residential rental project" bonds under Section 142(d) of the Internal Revenue Code <br />of 1986. The Project does not preserve existing federally-subsidized housing. <br />January 3, 2022 TAFT STETTINIUS & HOLLISTER LLP <br />7208531Ivt