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(a) a verification by an independent certified public accounting firm which shall <br /> be satisfactory to bond counsel to the City that the moneys and Acquired Obligations on deposit <br /> after such transfer will be sufficient, without reinvestment, to effect the advance refunding of the <br /> Refunded Bonds as set forth herein and in Section 14 of the Bond Ordinance; and <br /> (b) an opinion from bond counsel that such transfer (i) is permitted under <br /> Ordinance Nos. 1504-88 and 902-82 of the City, and (ii)will not cause the interest on the <br /> Refunded Bonds or the Bonds to become subject to federal income taxes and will not cause any <br /> Refunded Bond or Bond to become an "arbitrage bond" as defined in Section 148 of the Internal <br /> Revenue Code of 1986 and the applicable regulations promulgated thereunder (as the same may <br /> be amended, to the extent such amendments apply to the Refunded Bonds or the Bonds). <br /> The City reserves the right to substitute other securities for the Acquired Obligations in <br /> the event it may.do so pursuant to Section 148 of the federal Internal Revenue Code of 1986, as <br /> amended, and applicable regulations thereunder, upon compliance with the following conditions: <br /> (a) The securities to be substituted are direct noncallable obligations of the <br /> United States of America. <br /> (b) The City obtains a verification by an independent certified public <br /> accounting firm which shall be satisfactory to bond counsel and the City that such securities bear <br /> such interest and mature at such times and in such amounts, without reinvestment, as to fully <br /> replace the Acquired Obligations for which they are substituted, and to provide, together with <br /> Acquired Obligations and cash remaining, for the payment of the amounts specified in Section 2, <br /> items (a)through(d) above. <br /> (c) The City obtains an opinion from bond counsel that such substitution (i) is <br /> permitted under Ordinance Nos. 1504-88 and 902-82 of the City, and (ii)will not cause the <br /> interest on the Refunded Bonds or the Bonds to become subject to federal income taxes and will <br /> not cause any Refunded Bond or Bond to become an "arbitrage bond" as defined in Section 148 <br /> of the Internal Revenue Code of 1986 and the applicable regulations promulgated thereunder (as <br /> A-5 ooTo6M.00c 94/01/19 <br />