Scope of the Guidance & General Information -

1. Application of the Guidance is limited to allocations of HTC from Buildings that are placed in service on or after December 30, 2013.

2. This means the Guidance does not address allocations of other federal tax credits or state tax credits other than HTC, federal HTC matters not specifically addressed by the safe harbor, or state tax credit transactions.

3. The Guidance is only a safe harbor and is not intended to provide substantive rules. We expect that Investors will require satisfaction of all components of the safe harbor outlined below.

4. No private letter rulings will be issued by the IRS on the issue of allocation of HTC (i.e., the IRS intends the Guidance to be the final official word from the IRS on this issue