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(F) Adverse tax opinions, the issuance by the Internal Revenue Service of <br />proposed or final determinations of taxability, Notices of Proposed Issue <br />(IRS Form 5701-TEB) or other material notices or determinations with <br />respect to the tax status of the security, or other material events affecting <br />the tax status of the security; <br />(G) Modifications to rights of security holders, if material; <br />(H) Bond calls, if material, and tender offers; <br />(I) Defeasances; <br />(J) Release, substitution, or sale of property securing repayment of the <br />securities, if material; <br />(K) Rating changes; <br />(L) Bankruptcy, insolvency, receivership or similar event of the obligated <br />person; <br />(M) The consummation of a merger, consolidation, or acquisition involving an <br />obligated person or the sale of all or substantially all of the assets of the <br />obligated person, other than in the ordinary course of business, the entry <br />into a definitive agreement to undertake such an action or the termination <br />of a definitive agreement relating to any such actions, other than pursuant <br />to its terns, if material; <br />(N) Appointment of a successor or additional trustee or the change of name of <br />a trustee, if material; <br />(0) Incurrence of a financial obligation of the obligated person, if material, or <br />agreement to covenants, events of default, remedies, priority rights, or <br />other similar terms of a financial obligation of the obligated person, any of <br />which affect security holders, if material; and <br />(P) Default, event of acceleration, termination event, modification of terms, or <br />other similar events under the terms of a financial obligation of the <br />obligated person, any of which reflect financial difficulties. <br />For purposes of the events identified in paragraphs (0) and (P) above, the term "financial <br />obligation" means (i) a debt obligation; (ii) a derivative instrument entered into in connection <br />with, or pledged as security or a source of payment for, an existing or planned debt obligation; or <br />(iii) a guarantee of (i) or (ii). The term "financial obligation" shall not include municipal <br />securities as to which a final official statement has been provided to the MSRB consistent with <br />the Rule. <br />As used herein, for those events that must be reported if material, an event is "material" if it is an <br />event as to which a substantial likelihood exists that a reasonably prudent investor would attach <br />importance thereto in deciding to buy, hold or sell a Bond or, if not disclosed, would <br />significantly alter the total information otherwise available to an investor from the Official <br />Statement, information disclosed hereunder or information generally available to the public. <br />Notwithstanding the foregoing sentence, an event is also "material" if it is an event that would be <br />deemed material for purposes of the purchase, holding or sale of a Bond within the meaning of <br />applicable federal securities laws, as interpreted at the time of discovery of the occurrence of the <br />event. <br />14 <br />4813-3012-092941 <br />