This responds to the letter from your authorized representative requesting a ruling that, following transfer of partial title by deed in lieu of foreclosure, sale of a portion of the Projects financed with tax-exempt bond proceeds, and redemption of a proportionate amount of the Bonds, substantially all of the net proceeds of the Bonds will be used for residential rental projects that comply with the requirements of former section 103(b)(4) of the Internal Revenue Code.

The following facts and representations have been made. The Agency is an authority of the State created to provide, among other things, residential rental projects for low and moderate income individuals and families by making loans to the owners of housing developments who supply a portion of residential units to such individuals and families at rentals they can afford.

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