Loading...
31. Forward Purchase Agreement FORWARD PURCHASE AGREEMENT THIS FORWARD PURCHASE AGREEMENT (this “Agreement”) is made and entered into as of December 1, 2023, by and among BANK OF AMERICA, N.A., a national banking association (“Seller”), CITIBANK, N.A., a national banking association (“Purchaser”), and VISTA BREEZE, LTD., a Florida limited partnership (the “Borrower”). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Closing Date (as hereinafter defined). RECITALS A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Forward Commitment Fee Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. The Borrower has applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (the “Governmental Lender”) for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Miami-Dade County, Florida, on the land described in Exhibit A attached hereto, known or to be known as Vista Breeze (the “Project” or the “Mortgaged Property”). C. The Borrower has requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Seller, as Funding Lender, pursuant to which Seller will make a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan” or the “Loan”), the proceeds of which Governmental Lender will use to make the Borrower Loan. D. The Governmental Lender has executed and delivered to the Seller its Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) dated as of the Closing Date (the “Governmental Lender Note”) evidencing its obligation to make the payments due to the Seller under the Funding Loan. E. The proceeds of the Borrower Loan are being loaned and disbursed to Borrower pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023 (the “Original Borrower Loan Agreement”). Borrower and Seller have also entered into that certain Construction Disbursement Agreement, dated as of December 15, 2023 (the “Disbursement Agreement”), which provides for the manner, procedures and conditions of disbursements under the Borrower Loan. F. The Borrower Loan is evidenced by that certain Construction Phase Project Loan Note (the “Original Borrower Note”) dated as of December 15, 2023 (the “Closing Date”) made - 2 - Forward Purchase Agreement Vista Breeze by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of Seller. G. The Borrower Loan is secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”; and together with the Original Borrower Note, the Original Borrower Loan Agreement, the Disbursement Agreement and all other documents executed in connection with the Borrower Loan, collectively, the “Borrower Loan Documents”), which Original Security Instrument will encumber the Mortgaged Property. H. Pursuant to the Original Funding Loan Agreement, the Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement, the Funding Loan Documents (as defined in the Original Funding Loan Agreement; and together with the Borrower Loan Documents, collectively, the “Loan Documents”) and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), are being assigned by the Governmental Lender to Fiscal Agent, for the benefit of the Seller to secure the Funding Loan. I. Pursuant to the terms and conditions of this Agreement, upon satisfaction of the Conditions to Closing set forth in Article III and any other conditions herein, Purchaser has agreed to purchase the Funding Loan in the maximum principal amount of up to $11,875,000 (the “Maximum Permanent Period Amount”), as the same may be increased pursuant to the Earn- Out Option set forth in Exhibit C to this Agreement, or such lesser amount as required by the terms hereof. The terms and conditions of Purchaser’s purchase of the Funding Loan are set forth in this Agreement. Upon such purchase of the Loan by Purchaser (subject to the terms hereof), the Funding Loan will, pursuant to its terms, convert into a term loan in an aggregate principal amount not to exceed the Permanent Period Amount (calculated in accordance with Exhibit C to this Agreement), bearing interest at an annual rate equal to the Underwriting Rate (as defined in Exhibit C to this Agreement), with a maturity date of July 1, 2057, a mandatory prepayment of the Borrower Loan and, accordingly, the Funding Loan, required to be made no later than January 1, 2042, and with a forty (40) year amortization schedule (the “Permanent Loan”). If Purchaser does not purchase the Loan from Seller for any reason whatsoever or if Borrower does not otherwise refinance the Project with Purchaser pursuant to an alternative loan facility, the Loan will, at the option of Seller, become immediately due and payable pursuant to the terms of the Loan Documents, and Borrower shall be liable to Purchaser for a fee equal to the Forward Commitment Fee (as defined in that certain Promissory Note (Forward Commitment Fee) dated as of the Closing Date, by Borrower in favor of Purchaser), payable upon the Termination Date (as defined herein) or any earlier date on which this Agreement terminates (the “Forward Commitment Fee”). J. From and after the Conversion Date (as hereinafter defined) and the Purchaser’s acquisition of the Funding Loan, the Borrower Loan shall be evidenced by that certain Amended and Restated Multifamily Note (the “Permanent Borrower Note”), which Permanent Borrower Note shall amend and restate and replace in its entirety the Original Borrower Note. Concurrently therewith, the Original Security Instrument shall be assigned by Fiscal Agent (at the direction of the Seller) to Governmental Lender, and shall subsequently be amended and restated and replaced in its entirety by that certain Amended and Restated Multifamily Leasehold Mortgage, Assignment - 3 - Forward Purchase Agreement Vista Breeze of Rents, Security Agreement and Fixture Filing (Florida) (“Amended and Restated Security Instrument”), to be recorded on or about the Conversion Date. The Permanent Loan shall be made to the Borrower pursuant to the terms of that certain Loan Covenant Agreement between Purchaser and Borrower (the “Loan Covenant Agreement”). K. The Amended and Restated Security Instrument will be assigned by Governmental Lender to Fiscal Agent for the benefit of Purchaser, and will be recorded on or about the Conversion Date. L. As a condition precedent to the closing of the Loan, Seller requires that Borrower and Purchaser execute this Agreement and enter into the agreements, and make the certifications, set forth below. NOW, THEREFORE, in consideration of the mutual covenants and promises of the parties herein contained, and for other good and valuable consideration, receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: ARTICLE 1 PURCHASE OF LOAN 1.1 Sale and Purchase. Subject to the terms and conditions of this Agreement, Seller agrees to sell to Purchaser, and Purchaser agrees to purchase from Seller, without recourse, representation or warranty, the Funding Loan (which at the time of purchase shall have principal outstanding equal to the Permanent Period Amount as defined in Section 2.1 hereof), together with an assignment (or in the case of the opinions herein, delivery thereof) of all of Seller’s right, title and interest, as “Lender,” “Funding Lender” or “Servicer” or otherwise (as applicable), in the following documents or instruments relating to the Loan (collectively the “Assigned Documents”): (a) The Original Funding Loan Agreement, the Original Borrower Loan Agreement, and the other Loan Documents, other than the Terminated Documents (as hereinafter defined); (b) (i) The original or a copy of the legal opinion letter addressed to Seller from Borrower’s legal counsel, dated as of the Closing Date, and (ii) a new opinion letter addressed to Purchaser from Borrower’s legal counsel, dated as of the Conversion Date; (c) Except for the Terminated Documents (the “Terminated Documents”), as listed in Schedule II to the form of Assignment and Assumption of Mortgage and Loan Documents attached as Exhibit E-1 to this Agreement (the “Assignment and Assumption”), original copies of all of the Loan Documents as listed in Schedule I to the form of Assignment and Assumption, together with appropriate Uniform Commercial Code financing statements and continuation statements (the “UCC Statements”) sufficient to perfect (and maintain the perfection of) the security interest held by Seller in and to the personalty and other collateral of Borrower described in the Original Security Instrument (in each case, with evidence of filing thereon), together with all amendments thereto; - 4 - Forward Purchase Agreement Vista Breeze (d) Any subordination agreements and/or tri-party agreements related to subordinate financing or restrictions relating to the Project, including, without limitation, the Approved Subordinate Debt (as defined in Exhibit B hereto), with evidence of recording thereon; (e) Each modification, amendment, assumption, release, or waiver letter, if any, executed by Seller (if legally required) and/or Borrower (if legally required), pertaining to any of the terms, covenants or conditions of the Loan, any obligor under the Loan and/or any collateral for the Loan, with evidence of recording where appropriate; and (f) Except for the Terminated Documents, all other instruments, agreements, documents or reports (other than documents, memos, notes or reports prepared by employees, agents, attorneys or representatives of Seller solely for the internal use of Seller) affecting or relating to the Loan which were prepared and delivered to Seller in connection with, or executed and delivered to Seller in connection with or as security for, the Loan, including but not limited to any and all security agreements, collateral assignments, pledge agreements, financial agreements, corporate authorizations, limited liability company certificates, partnership consents and other corporate limited liability company or partnership documents, legal opinion letters from Borrower’s counsel, estoppel letters addressed to Borrower in connection with the Assigned Documents, estoppel letters from Borrower, tenants on the Project or governmental authorities or agencies, operating reports, environmental reports, site plans, surveys, soil and substrata studies, architectural drawings, plans and specifications, engineering plans and studies, floor plans, landscape plans, external written correspondence, insurance certificates or policies, appraisals, financial statements of Borrower, any constituent parties of Borrower, and any other obligors under the Loan; provided that notwithstanding the foregoing, Seller shall not be responsible for delivering any reliance, read-and-rely or similar letters or consents from any party to or for the benefit of Purchaser. 1.2 Form of Loan Documents and Subordinate Loan Documents. As of the Conversion Date, Purchaser confirms that copies of the Assigned Documents and documents relating to the Approved Subordinate Debt made to Borrower as of the date hereof have been delivered to, and approved by, Purchaser. 1.3 Assignment and Assumption. As of the Conversion Date, the Assignment and Assumption shall have been executed by Seller and Purchaser. On the Conversion Date, and upon recordation of the Assignment and Assumption and delivery to Purchaser of the Assigned Documents, the ownership of the Loan, and the interest of Seller in the Governmental Lender Note, Original Security Instrument and the other Assigned Documents shall immediately vest in Purchaser. 1.4 Terminated Documents. The foregoing provisions of this Article 1 to the contrary notwithstanding, the Terminated Documents shall not be deemed Assigned Documents sold to Purchaser, shall not be delivered to Purchaser, and substantially all of the provisions of such Terminated Documents shall be released and terminated upon the Conversion Date, pursuant to the Release and Termination Agreement to be executed by Borrower, Seller and Purchaser substantially in the form attached hereto as Exhibit G to this Agreement (the “Release and - 5 - Forward Purchase Agreement Vista Breeze Termination”); except to the extent of any provisions that, by the express terms of the Terminated Documents or applicable law, survive any such termination. ARTICLE 2 PURCHASE PRICE 2.1 Purchase Price. Provided that all of the Conditions to Closing set forth in Article 3 of this Agreement are satisfied, Purchaser shall purchase the Loan at par; provided, however, that at Conversion, the Loan shall not exceed the principal amount of the Borrower Loan following the calculation provided for in Exhibit C to this Agreement (the “Permanent Period Amount”), which shall be calculated as follows: (a) Borrower shall deliver to Purchaser the Conversion Package on or before the Conversion Package Submission Date (as such terms are defined in Exhibit B hereto). Provided that Purchaser receives the Conversion Package on or before the Conversion Package Submission Date, Purchaser shall calculate the Permanent Period Amount in accordance with Exhibit C to this Agreement based upon the Underwritten NOI (as defined in Exhibit C hereto) from the Project during the Calculation Period (as defined in Exhibit B hereto). (b) Notwithstanding the provisions of Exhibit C to this Agreement or any other provision to the contrary in the Original Borrower Note, in this Agreement or in the Original Borrower Loan Agreement, the Permanent Period Amount (i) shall not exceed the Maximum Permanent Period Amount or an amount that results in a loan-to-value ratio of more than the Required Loan to Value Ratio (as defined in Exhibit C hereto) (as determined by Purchaser) and (ii) subject to such restrictions, shall be the principal amount necessary to cause the ratio of the Underwritten NOI to the amount of principal and interest due in a 12-month period on the Original Borrower Note following any reamortization of the principal amount thereof as a result of a principal reduction, to equal no less than the Required Debt Service Coverage Ratio (as defined in Exhibit C hereto). (c) Following satisfaction of all of the Conditions to Conversion (as defined in Exhibit B hereto), Purchaser shall deliver written notice to Seller, Fiscal Agent and Borrower of: (i) the proposed Conversion Date, (ii) the amount of the Permanent Period Amount, (iii) any required prepayment of the Original Borrower Note, and (iv) any amendments to the amortization schedule for the Original Borrower Note, as applicable. (d) Purchaser’s calculation of the Permanent Period Amount and any amendments to the amortization schedule for the Borrower Loan shall be made in accordance with Exhibit C to this Agreement and such determination shall be, in the absence of manifest error, conclusive and binding on all parties. 2.2 Payment of Permanent Period Amount. The Permanent Period Amount shall be payable at the Conversion Date by wire transfer of immediately available funds from Purchaser directly to Seller or Fidelity National Title Insurance Company (the “Title Company”), as escrow agent for further payment to Seller upon the satisfaction of the Conditions To Closing. - 6 - Forward Purchase Agreement Vista Breeze 2.3 Fees To Be Paid to Purchaser. Purchaser shall have received the following fees from Borrower at or prior to the closing and initial disbursement of the Loan (the “Loan Closing”) upon execution of this Agreement as provided below: (a) Purchaser Loan Fee. Purchaser shall have received a loan fee equal to one percent (1.0%) of the Maximum Permanent Period Amount and the Earn Out Amount (as hereinafter defined) (the “Purchaser Loan Fee”). The Purchaser Loan Fee shall be paid to Purchaser upon execution of this Agreement. The Purchaser Loan Fee shall not be refundable. (b) Other Fees. Borrower shall pay all reasonable out of pocket costs of Purchaser, such as appraisal fees, legal fees, environmental review and consulting fees, and all other costs related to this transaction (the “Expenses”). Purchaser hereby acknowledges receipt of payment of a non-refundable application fee equal to $25,000 (the “Application Deposit”), which shall be applied against payment of the Expenses, provided that Borrower shall be responsible for the payment of all such Expenses if the foregoing Application Deposit is insufficient for such purposes. (c) Forward Commitment Fee. Borrower acknowledges that Purchaser has entered into, and will continue to enter into, other contracts with other parties in reliance upon Borrower’s fulfillment of Borrower’s obligations under this Agreement and the Loan Documents. In the event Borrower fails to fulfill or otherwise breaches the terms, provisions or conditions of this Agreement or the Loan Documents or the conditions to Purchaser’s purchase of the Loan as set forth herein are never met, and, as a result, Purchaser does not fund the purchase price hereunder, Borrower shall pay to Purchaser the Forward Commitment Fee calculated as follows: (i) In the event that Borrower voluntarily prepays the Borrower Loan to any amount less than ninety percent (90%) of the Maximum Permanent Period Amount on or prior to the Termination Date (the “Minimum Permanent Period Amount”) and the Permanent Period Amount is funded, a fee shall be payable which is equal to the greater of (i) the amount calculated pursuant to Purchaser’s standard yield maintenance formula on the amount that is less than ninety percent (90%) of the Maximum Permanent Period Amount, as determined by Purchaser in accordance with this Agreement, and (ii) one percent (1%) of the amount that is less than ninety percent (90%) of the Maximum Permanent Period Amount, as determined by Purchaser in accordance with this Agreement. (ii) If the Conditions to Conversion are not satisfied, or if Purchaser terminates this Agreement in accordance with its terms, and in each case the Permanent Period Amount is not funded, a yield maintenance premium shall be payable which is equal to the greater of (i) the amount calculated pursuant to Purchaser’s standard yield maintenance formula on the Maximum Permanent Period Amount, as determined by Purchaser in accordance with this Agreement, or (ii) two percent (2%) of the Maximum Permanent Period Amount, as determined by Purchaser in accordance with this Agreement. - 7 - Forward Purchase Agreement Vista Breeze Borrower’s obligation to pay the Forward Commitment Fee shall be evidenced by a recourse Forward Commitment Note, which shall be secured by a subordinate deed to secure debt encumbering the Mortgaged Property (the “Forward Commitment Fee Security Instrument”) and shall be guaranteed for the benefit of Purchaser by the Guarantor (as defined in the Forward Commitment Fee Security Instrument). The Forward Commitment Fee shall be payable as liquidated damages to compensate Purchaser for losses sustained on its other contracts, time spent, labor and services performed, loss of interest and any other loss which might be incurred by Purchaser in connection with this transaction, it being understood that Purchaser’s damages are not fully capable of being ascertained at this time and that the Forward Commitment Fee represents Borrower’s and Purchaser’s best estimate at this time of such damages. In such event, Borrower shall have no further liability to Purchaser for any breach of this Agreement or the Loan Documents. ARTICLE 3 CONDITIONS TO PURCHASE 3.1 Conditions to Purchaser’s Purchase. Purchaser’s obligation to purchase the Loan at the Conversion Date shall be subject to only the following specific conditions precedent (the “Conditions to Closing”): (a) Compliance with Conditions to Conversion. It shall be a Condition to Closing that Borrower or any other relevant party shall have complied with the Conditions to Conversion set forth on Exhibit B to this Agreement to the extent applicable to each such party. Borrower and Seller acknowledge that Purchaser shall have the exclusive right to determine whether and to what extent the Conditions to Conversion set forth on Exhibit B are satisfied and to determine the actual Permanent Period Amount. Seller and Borrower acknowledge that, with regard to the Condition to Conversion relating to completion of the Improvements (as defined in the Disbursement Agreement), such Improvements shall be required to be completed in substantial accordance with the Plans and Specifications approved by Purchaser (unless otherwise approved by Purchaser). In order to facilitate Purchaser’s determination of the satisfaction of the Conditions to Conversion and calculation of the Permanent Period Amount, Borrower shall submit to Purchaser for its review, approval and reliance, the Conversion Package and each of the documents collected with respect to Borrower, any managing members, general partners or managers of Borrower, the Project and the Improvements (collectively, the “Underwriting Documents”) specified in this Agreement, the Disbursement Agreement or as otherwise requested by Purchaser, each in accordance with the submission deadlines applicable to each such document. In addition, once Purchaser has approved any Underwriting Document, any further additions or changes to such Underwriting Document must be resubmitted to Purchaser for approval. Purchaser’s determination of the satisfaction of Conditions to Conversion and calculation of the Permanent Period Amount and any amendments to the amortization of the Loan shall be, in the absence of manifest error, conclusive and binding on all parties. (b) Borrower Payment. Borrower shall have made all payments of any accrued and outstanding interest on the Original Borrower Note and to reduce the aggregate principal due and owing thereunder to the Permanent Period Amount. - 8 - Forward Purchase Agreement Vista Breeze (c) Loan Documents. Borrower, Guarantor, Governmental Lender and Fiscal Agent, as applicable, shall have executed and delivered to Purchaser each of the Loan Documents in the respective forms annexed to this Agreement as Exhibit D to this Agreement. (d) Assigned Documents; Additional Documents. Seller shall have delivered to Purchaser directly or through the Title Company the original, fully executed Assigned Documents. Borrower shall have executed (or caused to be executed) and Seller shall have delivered to Purchaser such amendments to the Assigned Documents and/or such additional documents as Purchaser may reasonably require (the “Additional Documents”) in order to satisfy the Conditions to Closing or other terms of this Agreement. (e) Payment of Purchaser Fees and All Other Costs. Borrower shall have paid Purchaser any and all fees in accordance with the terms and conditions of this Agreement, the Disbursement Agreement and Original Borrower Loan Agreement. All outstanding actual costs, expenses, taxes and actual attorneys’ fees incurred by Purchaser in connection with the Loan Closing and the sale of the Loan shall have been paid by Borrower to Purchaser, including (without limiting the generality of the foregoing) escrow fees and costs, recording costs, title insurance premiums, flood certification, tax service contract (if any), appraisal fees, mortgage tax (if any), fees paid to attorneys in connection with preparation of documents, or providing legal advice or opinions and all other fees, costs and expenses contemplated by this Agreement and the Loan Documents. (f) Loan Purchase Documents. Seller shall have duly executed (or authorized the Fiscal Agent to execute as applicable) and delivered (i) to Purchaser (A) an original certificate of Seller, in the form attached hereto as Exhibit F to this Agreement (the “Seller Certificate”), certifying that all information contained therein shall be true and correct, (B) an original, notarized Assignment and Assumption, in recordable form, (C) an original endorsement to the Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) in the form attached hereto as Exhibit E-2 to this Agreement, (D) an original endorsement to the Original Borrower Note in the form attached hereto as Exhibit E-3 executed as of the Conversion Date, and (ii) to Fiscal Agent, the Notice to Fiscal Agent in the form attached hereto as Exhibit I (“Notice to Fiscal Agent”). (g) Legal Opinion. Purchaser shall have received (i) an original opinion of Borrower’s legal counsel addressed to Seller, dated as of the Loan Closing and (ii) a reliance letter from Borrower’s legal counsel, authorizing Purchaser to rely on the opinion delivered to Seller by Borrower’s legal counsel at the Loan Closing, together with a new original opinion of Borrower’s legal counsel, addressed to Purchaser and dated as of the Conversion Date. Such opinion shall be in form and substance reasonably satisfactory to Purchaser, and shall address the legality, validity, authorization and enforceability of the Loan and the Assigned Documents. (h) Security Interest. Purchaser shall have a first priority perfected security interest in the Project, subject to the Permitted Encumbrances (as defined herein), and Borrower shall authorize and deliver any and all financing statements and fixture filings - 9 - Forward Purchase Agreement Vista Breeze required in connection therewith, which financing statements shall have been filed in the appropriate office therefor. (i) Recordation of Documents. The Amended and Restated Security Instrument and Assignment and Assumption and all Loan Documents which, by their express terms, are required to be recorded, must be delivered and released to the Title Company for recording. 3.2 Conditions to Seller’s Sale. Seller’s obligation to sell the Loan at the Conversion Date shall be subject to only the following specific conditions precedent: (a) Payment of Permanent Period Amount. Purchaser shall have paid Seller the Permanent Period Amount. (b) Payment by Borrower of Note Balance. Borrower shall have paid Seller the difference, if any, between the Permanent Period Amount and the amount of outstanding principal, accrued interest and costs and expenses on the Loan as of the Conversion Date. (c) Seller’s Costs. Seller’s costs, expenses, taxes and attorneys’ fees in connection with the Loan Closing and the sale of the Loan to Purchaser shall have been paid as otherwise mutually agreed by Borrower and Seller in the Disbursement Agreement and other Loan Documents. (d) Release and Termination. Borrower shall have executed and delivered to Seller and Purchaser the Release and Termination dated as of the Conversion Date. ARTICLE 4 CONVERSION 4.1 Time of Conversion. The closing of the sale of the Loan by Seller to Purchaser and the recordation of the Assignment and Assumption (the “Conversion”), shall occur on or before a date no later than ten (10) Business Days following satisfaction of all of the conditions set forth in Article 3 of this Agreement (such date, the “Conversion Date”). The precise date and time of the Conversion Date shall be mutually determined by Seller and Purchaser; provided, however, the Conversion Date shall not occur later than July 1, 2026 (the “Termination Date”). If the Conversion Date is extended by the Seller by six (6) months as contemplated in Section 2.1 of the Disbursement Agreement (the “First Extended Construction Loan Maturity Date”), then the Termination Date shall be extended to January 1, 2027 (the “First Extended Termination Date”). Further, if the First Extended Construction Loan Maturity Date is further extended, as Seller determines in its discretion, then the First Extended Termination Date may be further extended to a date that is no later than July 1, 2027 (the “Second Extended Termination Date”). In the event the Conversion Date has not occurred by the Termination Date, then Purchaser shall have the independent right, in its sole and absolute discretion, to either terminate this Agreement or extend the Termination Date to a date that is mutually acceptable to Purchaser and Seller. In the event the Termination Date is extended to the First Extended Termination Date, an additional 0.05% will be added to the interest rate set forth in the Permanent Borrower Note. In the event the Termination Date is further extended from the First Extended Termination Date to the Second Extended - 10 - Forward Purchase Agreement Vista Breeze Termination Date, an additional 0.05% will be added to the interest rate set forth in the Permanent Borrower Note. 4.2 Procedure for Conversion and Sale. The sale of the Loan to Purchaser shall close by the Title Company, as escrow agent: (a) delivering the Assigned Documents to Purchaser, if not previously delivered to Purchaser; (b) delivering the Additional Documents to Purchaser, if not previously delivered to Purchaser; (c) recording a fully executed original of the Assignment and Assumption in the Office of the County Recorder where the Mortgaged Property is located; (d) filing of UCC-3 forms of assignment in the appropriate filing office; (e) issuing a new or re- issued title policy in the form required under Exhibit B to this Agreement and in form and substance satisfactory to Purchaser; (f) paying Seller in immediately available funds: (i) the Permanent Period Amount, (ii) any payment of principal required from Borrower to reduce the principal amount outstanding under the Loan and the Original Borrower Note to the Permanent Period Amount and (iii) the payment from Borrower of accrued interest and other fees and charges owed to Seller, if any; (g) delivering the original Assignment and Assumption to Seller and Purchaser (each receiving the original signature of the other party thereto); (h) delivering the original Release and Termination to Seller, Purchaser and Borrower (each receiving the original signatures of the other parties thereto); (i) delivering an original opinion of legal counsel for the Borrower to Purchaser or reliance letter (together with the appropriate bring-down letter), as set forth in Section 3.1 above; (j) delivering to the Fiscal Agent the Notice to Fiscal Agent and an executed copy of the Wire Instructions Transfer executed by Purchaser, in the form attached hereto as Exhibit J; and (k) otherwise complying with the terms of the escrow instructions from Purchaser and/or Seller to the Title Company. ARTICLE 5 REPRESENTATIONS AND WARRANTIES 5.1 Representations of Seller. Seller represents and warrants to Purchaser as of the date hereof that: (a) Sole Owner. Seller is the sole legal and beneficial owner and holder of the Loan, free and clear of any and all liens and security interests in favor of any other party, other than Unassigned Rights retained by Governmental Lender. (b) Authority. Seller, and the officers acting on its behalf, have all requisite power and authority to execute and deliver, and to perform all of its obligations under this Agreement and all instruments and other documents required to be executed and delivered by Seller in connection herewith. (c) Binding Obligation. This Agreement constitutes the valid, legal and binding agreement of Seller, and is enforceable against Seller in accordance with its terms, except as such enforceability may be limited by bankruptcy, insolvency, reorganization, moratorium and other similar laws of general applicability relating to or affecting the enforcement of creditors’ rights and/or by general equitable principles which may limit the availability of equitable remedies, including without limitation, the remedy of specific performance. - 11 - Forward Purchase Agreement Vista Breeze (d) Brokers. Seller has not engaged any broker or finder or incurred or become obligated to pay any broker’s commission or finder’s fee in connection with the transactions contemplated by this Agreement. 5.2 Representations of Purchaser. Purchaser represents and warrants to Seller as of the date hereof that: (a) Authority. Purchaser and the officers acting on its behalf have all requisite power and authority to execute and deliver, and to perform all of its obligations under this Agreement and under all instruments and other documents to be executed and delivered by Purchaser in connection herewith. (b) Binding Obligation. This Agreement constitutes the legal, valid and binding obligation of Purchaser enforceable against Purchaser in accordance with its terms, except as such enforceability may be limited by bankruptcy, insolvency, reorganization, moratorium and other similar laws of general applicability relating to or affecting the enforcement of creditors’ rights and/or by general equitable principles which may limit the availability of equitable remedies, including without limitation, the remedy of specific performance. (c) Brokers. Purchaser has not engaged any broker or finder or incurred or become obligated to pay any broker’s commission or finder’s fee in connection with the transactions contemplated by this Agreement. (d) Independent Decision. Purchaser represents that it has made and will make independently and without reliance on Seller, or any other party, or upon the officers, directors, agents, attorneys or employees of Seller or any other party, and based on such documents and information as it has deemed appropriate, including, without limitation, the Underwriting Documents, its own credit and legal evaluation of the Loan and Borrower, and valuation of the Project, and the decision to enter into this Agreement. Neither Seller nor its officers, directors, agents, attorneys or employees shall be deemed an agent for Purchaser or be deemed to have assumed any fiduciary obligation toward or relationship of Governmental Lender with or for Purchaser in connection with the Permanent Loan or the Underwriting Documents. 5.3 Representations of Borrower. As of the date hereof, Borrower represents and warrants to Seller and Purchaser that: (a) Authority. Borrower has all requisite power and authority to execute and deliver, and to perform all of its obligations under this Agreement and under all instruments and other documents to be executed and delivered by Borrower in connection herewith. The transactions contemplated by this Agreement are and will be in all respects valid and legal. Borrower warrants that all information in the loan application and the financial statements and other documents submitted by, or on behalf of, Borrower in connection with the Loan, this Agreement and/or the Project, including, without limitation, the Underwriting Documents (hereinafter referred to collectively as the “Application Documents”) was correct in all material respects when made, that no material information - 12 - Forward Purchase Agreement Vista Breeze was omitted from the Application Documents, that there has been no materially adverse change in any condition or fact stated in the Application Documents between the date of the applicable document and the date hereof. (b) Organization. Borrower and each general partner of Borrower is duly formed and is validly existing pursuant to the laws of the State of Florida, is in full compliance with all requirements for its formation and existence and has continuously been in existence. (c) Binding Obligation. This Agreement constitutes a legal, valid and binding obligation of Borrower enforceable against Borrower in accordance with its terms, except as such enforceability may be limited by bankruptcy, insolvency, reorganization, moratorium and other similar laws of general applicability relating to or affecting the enforcement of creditors’ rights and/or by general equitable principles which may limit the availability of equitable remedies, including without limitation, the remedy of specific performance. (d) No Actions, Suits or Proceedings. There are no actions, suits or proceedings at law or in equity now pending or, to Borrower’s best knowledge, overtly threatened against or affecting the Project or Borrower, its sponsor, or any of Borrower’s general partners, which would have a material adverse effect on the Project or the financial condition of Borrower, and there are no facts now in existence that, with the giving of notice or the lapse of time, or both, would form the basis for any such action, suit or proceeding. To its knowledge, Borrower is not in default with respect to any order, writ, injunction, decree or demand of any court or any Governmental Lender. (e) No Voluntary Bankruptcy. Neither Borrower nor any of its general partners have: (i) filed a petition for relief under the United States Bankruptcy Reform Act of 1978, as amended from time to time, or any substitute or replacement legislation (the “Bankruptcy Code”), or under any other present or future state or federal law regarding bankruptcy, reorganization or other debtor relief law; (ii) filed a pleading or an answer in any involuntary proceeding under the Bankruptcy Code or other debtor relief law which admits the jurisdiction of the court or the petition’s material allegations regarding Borrower’s (or its general partners’) insolvency; (iii) made a general assignment for the benefit of creditors; or (iv) applied for, or suffered the appointment of, a receiver, trustee, custodian or liquidator of Borrower (or its general partners) or any of their respective property. (f) No Involuntary Bankruptcy. No involuntary petition under the Bankruptcy Code or under any other debtor relief law has been filed against Borrower or its general partners or in any way restrains or limits Borrower or its general partners or Seller or Purchaser, regarding the Loan or the Project. (g) FIRPTA Compliance. Borrower is a “United States Person” within the meaning of Section 7702(a)(30) of the Code. The “Code” shall mean the Internal Revenue Code of 1986, the Regulations (whether temporary or final) under that Code or the statutory predecessor of that Code, and any amendments of, or successor provisions to, the foregoing - 13 - Forward Purchase Agreement Vista Breeze and any official rulings, announcements, notices, procedures and judicial determinations regarding any of the foregoing, all as and to the extent applicable. Unless otherwise indicated, reference to a Section includes any applicable successor section or provision and such applicable Regulations, rulings, announcements, notices, procedures and determinations pertinent to that Section. (h) Affiliation of Parties. Borrower is not affiliated, directly or indirectly, with Seller or with any of the respective subsidiaries, affiliates or officers of Seller; provided, no representation is made with respect to persons that own, directly or indirectly, interests in Borrower’s investor limited partner. (i) Brokers. Borrower has not engaged any broker or finder or incurred or become obligated to pay any broker’s commission or finder’s fee in connection with the Loan or the transactions contemplated by this Agreement. 5.4 Disclaimer. (a) Obligations of Seller. Notwithstanding anything to the contrary in this Agreement, Seller shall have no obligation to sell the Loan if (a) Borrower fails to satisfy Seller’s requirements in this Agreement or in the Loan Documents or (b) Seller reasonably determines that any condition to Purchaser’s purchase of the Loan in accordance with this Agreement has not been timely satisfied by Borrower as required under this Agreement. (b) Obligations of Purchaser. Notwithstanding anything to the contrary in this Agreement, Purchaser shall have no obligation to purchase the Loan if Borrower or Seller fails to satisfy Purchaser’s requirements in this Agreement to purchase the Loan or Purchaser reasonably determines that any condition to Purchaser’s purchase of the Loan in accordance with this Agreement has not been timely satisfied by Borrower or Seller as required under this Agreement. 5.5 Payment and Performance Bonds. Seller and Purchaser acknowledge and agree that each of them have been named as dual obligees under the payment and performance bonds issued in connection with the Project, as their respective interests may appear. Notwithstanding the foregoing, prior to Conversion, Seller shall have the sole right to claim and collect on the proceeds of such payment and performance bonds. Purchaser shall have no right to claim and collect on the proceeds of such payment and performance bonds until after Conversion. Purchaser agrees that, prior to Conversion, Seller is hereby authorized and empowered to take any and all actions and exercise any and all rights relating to such payment and performance bonds. Purchaser shall not take any actions or exercise any rights relating to such payment and performance bonds until after Conversion. ARTICLE 6 COVENANTS OF SELLER 6.1 Modification of Loan; Release of Security. - 14 - Forward Purchase Agreement Vista Breeze (a) Without the prior written consent of Purchaser (which consent shall not be unreasonably withheld, conditioned or delayed), Seller will not modify, amend, cancel, extend, release, waive or otherwise change in any manner any of the terms, covenants, conditions or obligors under any of the Assigned Documents in any material respect to the extent that they apply to the Permanent Loan. Without the prior written consent of Purchaser or except as otherwise contemplated by the Assigned Documents, Seller shall not cause the subordination of the Original Security Instrument or the release of any security for the Loan which is intended to be assigned to Purchaser hereunder. (b) Without the prior written consent of Purchaser, which shall not be unreasonably withheld, Seller shall not consent to any replacement of Atlantic Pacific Community Management, LLC, a Delaware limited liability company, as property manager of the Project (“Property Manager”), or to any changes to the Management Agreement for the Project, executed as of the Closing Date, by and between Borrower and Property Manager. Notwithstanding the foregoing, at the request of Borrower, Seller may consent to the replacement of the Property Manager by the Landlord within thirty-six (36) months of stabilization, subject to the discretionary approval of Purchaser, Equity Investor and Governmental Lender. (c) Without the prior consent of Purchaser, which shall not be unreasonably withheld, Seller shall not consent to any material amendments to the Partnership Agreement (as defined in Exhibit B hereto). ANY BREACH OF COVENANTS CONTAINED IN THIS SECTION 6.1 WHICH ARE MATERIAL TO PURCHASER’S PERMANENT LOAN UNDERWRITING WILL, AT THE SOLE AND ABSOLUTE DISCRETION OF PURCHASER RESULT IN THE TERMINATION OF THIS AGREEMENT. PURCHASER’S SOLE AND EXCLUSIVE REMEDY FOR SUCH BREACH SHALL BE THE TERMINATION OF THIS AGREEMENT AND ENTITLEMENT TO RECEIVE FROM BORROWER ANY FEE UNDER THE TERMS OF THIS AGREEMENT, INCLUDING, WITHOUT LIMITATION, ANY FORWARD COMMITMENT FEE TO WHICH PURCHASER IS ENTITLED UNDER THE FORWARD COMMITMENT FEE NOTE OR HEREUNDER. 6.2 Pendency of Action. Upon actual knowledge thereof, Seller shall promptly notify Purchaser of the institution or pendency of any action, suit, or proceeding against or affecting the Loan, the Project or Improvements, Borrower, or any of Borrower’s general partners and shall deliver to Purchaser copies of all notices and other writings relating to said actions promptly upon receipt thereof. 6.3 Transfer of Loan. Prior to the Conversion Date or termination of this Agreement, Seller shall not transfer, assign, sell, convey, hypothecate, or otherwise alienate the Loan or negotiate or attempt to negotiate the transfer, assignment, sale, conveyance, hypothecation, or other alienation of the Loan without in each case Purchaser’s prior written consent, which consent shall not be unreasonably withheld, conditioned or delayed. Anything in this Agreement or the Loan Documents to the contrary notwithstanding, without notice to or consent of any party or the need to comply with any of the formal or procedural requirements of this Agreement or the Loan Documents, (a) the Seller and/or any eligible transferee, assignee, purchaser or participant may (to - 15 - Forward Purchase Agreement Vista Breeze the fullest extent permitted under applicable law) at any time and from time to time pledge and assign any or all of its right, title and interest in, to and under all or any of the Loan or the Loan Documents to a Federal Reserve Bank; provided, however, that prior to Conversion, any such pledge and/or assignment shall have been released by such Federal Reserve Bank, and (b) the Seller may transfer the Loan to any wholly owned affiliate or may sell, assign or grant participations in all or any portion of its interests and rights under the Loan and Loan Documents so long as the Seller remains as the holder of the Loan. ARTICLE 7 NOTICE OF DEFAULT 7.1 Notice of Default; Borrower’s and Seller’s Right to Cure. 7.1.1 Notice of Default. Concurrently with the delivery by Purchaser to Borrower of any notice of default under this Agreement, Purchaser shall deliver to Seller a copy of any such notice of default at the address of each set forth in Section 8.2 below. 7.1.2 Seller’s and Borrower’s Right to Cure Default. Notwithstanding anything to the contrary in the Loan Documents, Seller or Borrower shall not be in default under this Agreement, nor shall Purchaser be entitled to exercise any rights and remedies it may have arising out of Seller’s or Borrower’s failure to satisfy any of the terms, conditions and/or covenants set forth in this Agreement, until and unless Purchaser has notified Borrower and Seller in writing of the occurrence of any such default (that continues beyond any applicable notice and cure period) in accordance with the terms and conditions of Section 7.1.1 and Seller (with no obligation to do so) or Borrower has failed to cure such default or breach prior to the Termination Date. If any such default or breach is not cured within the period specified above in this Section 7.1.2, then Purchaser may, at its option, exercisable by written notice to Seller and Borrower: (a) terminate Purchaser’s obligations under this Agreement including but not limited to Purchaser’s obligation to purchase the Loan; or (b) waive the defaults that have not yet been cured or extend the time for cure of such defaults, in which event this Agreement will remain in full force and effect. 7.2 Notice to Purchaser of Default Under Loan. Concurrently with the delivery by Seller to Borrower of any notice of default under the Loan Documents, Seller shall send to Purchaser a copy of any such notice of default at the address set forth in Section 8.2 below. Notwithstanding anything stated to the contrary in the Loan Documents or this Agreement, in no event shall the occurrence of a default under the Loan constitute a default under this Agreement or entitle Purchaser to terminate this Agreement or exercise any other rights or remedies it may have hereunder, except to the extent that such default has not been cured within the cure period as set forth in Section 7.1.2 above. 7.3 Default by Seller. Seller shall be in default hereunder upon the occurrence of any one or more of the following events: - 16 - Forward Purchase Agreement Vista Breeze (a) any of Seller’s representations or warranties set forth in this Agreement prove to be materially untrue or inaccurate in any material respect on the date when made; or (b) Seller shall fail to meet, substantially comply with or perform any covenant, agreement, or obligation within the time limits and in the manner required in this Agreement. The parties acknowledge that, in the event of a default by Seller hereunder (except a breach by Seller of the covenants contained in Section 6.1 above), damages would be an inadequate remedy. Accordingly, with that exception, in the event of a default by Seller hereunder, Purchaser and/or Borrower shall have the right to obtain specific performance of this Agreement against Seller. In addition to the other remedies of Purchaser hereunder, if the Conversion Date does not occur by the Termination Date as a result of non-performance by Seller of its obligations under this Agreement, Purchaser may terminate this Agreement. 7.4 Default by Purchaser. Purchaser shall be in default hereunder upon the occurrence of any one or more of the following events: (a) any of Purchaser’s representations or warranties set forth in this Agreement are materially untrue or inaccurate in any material respect on the date when made; or (b) Purchaser shall fail to meet, substantially comply with or perform any covenant, agreement, or obligation within the time limits and in the manner required in this Agreement. The parties acknowledge that, in the event of a default by Purchaser hereunder, damages would be an inadequate remedy. Accordingly, in the event of a default by Purchaser hereunder, Seller and Borrower shall each, separate and independent of one another, have the right to obtain specific performance of this Agreement against Purchaser. In addition to the other remedies of Seller hereunder, if the Conversion Date does not occur by the Termination Date as a result of non- performance by Purchaser of its obligations under this Agreement, Seller may terminate this Agreement. 7.5 Default by Borrower. Borrower shall be in default hereunder upon the occurrence of any one or more of the following events: (a) any of Borrower’s representations or warranties set forth in this Agreement are materially untrue or inaccurate in any material respect on the date when made; or (b) Borrower shall fail to meet, comply with or materially perform any covenant, agreement, or obligation within the time limits and in the manner required in this Agreement. In the event of a default by Borrower hereunder, and if such default is not cured within the time periods set forth in Section 7.1.2 above, the sole and exclusive remedy of Purchaser shall be to terminate this Agreement and collect from Borrower any amounts set forth in Section 2.3 above. Furthermore, in the event of a default by Borrower hereunder, Seller shall have all the rights and - 17 - Forward Purchase Agreement Vista Breeze remedies available to Seller under the Loan Documents. Seller and Purchaser acknowledge and agree that Borrower’s investor limited partner, or its designees, shall have the right, but not the obligation, to cure any default on behalf of Borrower hereunder, and the same shall be accepted as if made by Borrower itself. ARTICLE 8 NOTICES 8.1 Method of Delivery. All notices and demands given pursuant to the terms hereof shall be given in writing delivered in person, by commercial courier, or by registered or certified mail, return receipt requested, with all postage and fees fully prepaid. Notices shall be considered delivered upon receipt by a person commonly accepting delivery of letters or parcels at the recipient’s address, such receipt to be as indicated by the return receipt if the notice was sent by mail; except that, upon an attempt to effectuate service of notice as provided herein, if the party being sent the notice either (a) refuses to accept delivery, or (b) has moved and no notice has been served upon the party sending the notice in question informing it of the recipient’s new address, then the party to whom the notice was intended to be served shall be deemed to have received the notice upon the attempt to deliver it at the last address for the intended recipient as to which the sender had notice. Notices shall be addressed as specified below, subject to the right of either party to change the address for service of notice on it by such party serving a notice upon the other of the new address, except that any change of address to a post office box shall not be effective unless a street address is also specified for use in effectuating personal service. 8.2 Address for Notices. (a) The address of Seller for all purposes under this Agreement and for all notices hereunder shall be: Bank of America, N.A. 401 E. Las Olas Blvd. Fort Lauderdale, Florida 33301 FL6-812-18-02 Attention: Binyamin Rosenbaum With a copy to: Bank of America, N.A. 101 East Kennedy Blvd., 6th Floor P.O. Box 31590 Tampa, FL 33602 Mail Stop: FL1-400-06-13 Attention: CREB Loan Administration With a copy to: Holland & Knight LLP 31 West 52nd Street, 11th Floor - 18 - Forward Purchase Agreement Vista Breeze New York, NY 10019 Attention: Kathleen M. Furey, Esq. (b) The address of Purchaser for all purposes under this Agreement and for all notices hereunder shall be: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 With a copy of any default notice to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291 5754 (c) The address of Borrower for all purposes under this Agreement and for all notices hereunder shall be: - 19 - Forward Purchase Agreement Vista Breeze Vista Breeze, LTD. c/o Atlantic Pacific Communities 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor With a copy to: Klein Hornig LLP 1325 G Street NW, Suite 770 Washington, D.C. 20005 Attention: Chris Hornig, Esq. With a copy to: Vista Breeze HACMB, Inc. c/o Housing Authority of the City of Miami Beach 200 Alton Road Miami Beach, FL 33139 Attention: Miguell Del Campillo, Executive Director Phone: (305) 532-6401, ext. 3020 Email: miguell@hacmb.org With a copy to: Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 Pittsburgh, PA 15219 Attention: Michael H. Syme, Esq. Email: msyme@foxrothschild.com Phone: (412) 391-2450 (d) The address of Equity Investor for all purposes under this Agreement and for all notices hereunder shall be: Bank of America, N.A. MA5-100-04-11 100 Federal Street Boston, MA 02110 Attention: Tax Credit Asset Management (Vista Breeze) Holland & Knight LLP 10 St. James Avenue Boston, MA 02116 Attention : Sara C. Heskett, Esq. - 20 - Forward Purchase Agreement Vista Breeze ARTICLE 9 MISCELLANEOUS 9.1 Entire Agreement. This Agreement (including the exhibits hereto) contains the entire agreement among the parties regarding the sale and purchase of the Loan, and no oral statements or prior written matter not specifically incorporated herein shall be of any force and effect. No variation, modification, or changes hereof shall be binding on any party hereto unless set forth in a document executed by all parties. 9.2 Successors and Assigns. This Agreement shall inure to the benefit of and be binding upon the parties hereto and upon their respective legal representatives, successors and assigns. Except as permitted under Section 6.3, any assignment of this Agreement by Seller or Purchaser (other than an assignment involving the sale of all or substantially all of the assets of either such institution) without the consent of the other institution shall be null and void and of no force and effect. 9.3 Time of Essence. Time is of the essence in the execution and performance of this Agreement and of each provision hereof. 9.4 Terminology. Wherever required by the context, any gender shall include any other gender, the singular shall include the plural, and the plural shall include the singular. 9.5 Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the State of Florida. 9.6 Severability. In case any one or more of the provisions contained in this Agreement shall for any reason be held to be invalid, illegal, or unenforceable in any respect, such invalidity, illegality, or unenforceability shall not affect any other provision hereof, and this Agreement shall be construed as if such invalid, illegal, or unenforceable provision had never been contained herein. 9.7 Attorneys’ Fees. In the event of any action at law or in equity in relation to this Agreement, the losing party shall pay the prevailing party’s reasonable attorneys’ fees and costs. 9.8 Rules of Construction. The parties acknowledge that each party and its counsel have reviewed and commented as to the terms and conditions of this Agreement, and the parties hereby agree that normal rules of construction to the effect that any ambiguities are to be resolved against the drafting party shall not be employed in the interpretation of this Agreement or amendments or exhibits hereto. 9.9 Counterparts. This Agreement and any exhibits attached hereto requiring signatures may be executed in any number of counterparts, each of which shall be an original, but all of which together shall constitute but one instrument. 9.10 Exhibits. Each of the Exhibits attached hereto is hereby incorporated by reference into this Agreement. 9.11 Determinations by Purchaser or Seller. In any instance where the consent or approval of Purchaser may be given or is required, or where any determination, judgment or - 21 - Forward Purchase Agreement Vista Breeze decision is to be rendered by Purchaser or Seller under this Agreement, including in connection with determination of the satisfaction of the Conditions to Conversion or the Conditions to Closing, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by Purchaser or Seller (or their respective designated representative), at its sole and exclusive option and in its sole and absolute discretion. 9.12 Venue; Jurisdiction. Borrower, Seller and Purchaser agree that any controversy arising under or in relation to this Agreement may be litigated in the State of Florida. The state and federal courts and authorities with jurisdiction in the State of Florida shall have jurisdiction over all controversies that shall arise under or in relation to this Agreement and the Loan Documents. Borrower, Seller and Purchaser irrevocably consent to service, jurisdiction and venue of such courts for any such litigation and waive any other venue to which they might be entitled by virtue of domicile, habitual residence or otherwise. 9.13 WAIVER OF JURY TRIAL. TO THE FULLEST EXTENT PERMITTED BY LAW, EACH PARTY HERETO (a) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR ANY RELATIONSHIP AS BORROWER AND LENDER THAT IS TRIABLE OF RIGHT BY A JURY AND (b) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. [REMAINDER OF PAGE LEFT INTENTIONALLY BLANK] A-1 Forward Purchase Agreement Vista Breeze EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. B-1 Forward Purchase Agreement Vista Breeze EXHIBIT B CONDITIONS TO CONVERSION The conditions set forth in this Exhibit B (collectively, the “Conditions to Conversion”) must be satisfied prior to the occurrence of the Conversion Date. (a) Completion of Construction and/or Rehabilitation. Borrower shall submit to Purchaser no later than the Conversion Package Submission Date (as hereinafter defined) evidence satisfactory to Purchaser that Borrower has completed the construction and/or rehabilitation required by this Agreement (the “Improvements”) (including all amenities, landscaping, signage, parking, and the like (i) in a good and workmanlike manner, (ii) in accordance with the approved Plans and Specifications, including approved change orders, if any, (iii) on a lien-free basis, (iv) in compliance with all legal requirements, including, without limitation, all Legal Requirements, including building codes, zoning requirements, subdivision requirements, fire and safety laws, the requirements of the Americans with Disabilities Act and, if applicable, the design and rehabilitation requirements established pursuant to the Fair Housing Act, as amended, (v) in compliance with the environmental requirements set forth in the Borrower Loan Documents, and (vi) otherwise in accordance with the terms and provisions of this Agreement and the other Borrower Loan Documents. Such evidence shall include the documentation that Borrower is required to provide pursuant to this Agreement and the Borrower Loan Documents, including, but not limited to, any and all certificates of occupancy (or equivalent documentation) from the local government authority, certificates of Borrower, Borrower’s architect, engineer, the inspecting architect/architectural consultant and other project consultants, if applicable, which shall, among other things, certify that the Improvements were completed in accordance with the requirements of this Paragraph (a) and have attached thereto supporting documentation from all applicable Governmental Authorities. All such evidence shall be in form and content satisfactory to Purchaser and shall also be subject to verification, review and inspection, as applicable, by Purchaser and/or its consultants. (b) Borrower; Guarantor; Borrower’s Ownership of the Project; No Material Adverse Change. The identity of Borrower and Guarantor shall not have changed (except for such changes as may have been approved by Purchaser or Transfers permitted by the Forward Commitment Fee Security Instrument). To the extent there is a Credit Enhancer (as hereinafter defined), Borrower shall remain eligible under such Credit Enhancer’s requirements for mortgage borrowers and shall continue to own the Project. There shall be no reduction in the Guarantor’s direct or indirect ownership interest in and control over Borrower except as expressly permitted by the Forward Commitment Fee Security Instrument. There shall be no Material Adverse Change in the condition, financial or otherwise, of Borrower or any Guarantor. There shall be no Material Adverse Change in the financial condition of the Project or any other feature of the transaction from that which existed on the Closing Date. Borrower shall submit to Purchaser no later than the Conversion Package Submission Date evidence satisfactory to Purchaser that the requirements of this Paragraph (b) have been satisfied as of such date, provided, however, that such requirements shall continue to be satisfied through the Conversion Date. Notwithstanding anything to the contrary in this Agreement or the Loan Documents, if Landlord exercises its option to acquire the ownership interest of Atlantic Pacific Companies (“APC”) in Borrower pursuant to that certain Master Development Agreement, then a to-be-formed affiliate entity of Landlord shall replace the B-2 Forward Purchase Agreement Vista Breeze Guarantor, provided such entity satisfies a minimum liquidity requirement of $1,000,000 and such other requirements as Purchaser determines in its discretion. (c) Sources and Uses of Funds. Borrower shall provide assurances and evidence, satisfactory in form and content to Purchaser, that Borrower (1) has received or will receive fully and timely, all Equity Contributions to be made to Borrower as of such date, proceeds of approved subordinate financing and other cash to be received by Borrower as of such date and the Conversion Date, and has properly applied such Equity Contributions, proceeds, and other cash to the Project to the extent received and (2) has funded or will fund, fully and timely, all cash required to be invested in the Project as of such date and the Conversion Date. Borrower shall have submitted to Purchaser no later than the Conversion Package Submission Date evidence satisfactory to Purchaser of the satisfaction of the requirements of this Paragraph (c) as of such date, provided, however, that such requirements shall continue to be satisfied through the Conversion Date. (d) Low-Income Housing Tax Credits. Borrower shall have provided on or before the Conversion Package Submission Date evidence satisfactory to Purchaser that (i) the Project is eligible for low-income housing tax credits, which evidence may be a draft or copy of the accountant’s cost certification and, to the extent available, the IRS Form 8609 for the Project, (ii) Borrower has taken all steps necessary to obtain such low-income housing tax credits for the Project in the amount required under the Partnership Agreement, and (iii) the Project (A) meets the requirements of a “qualified low-income housing project” within the meaning of Section 42(g) of the Internal Revenue Code and of a “qualified residential rental project” within the meaning of Section 142(d) of the Internal Revenue Code and (B) at all times has been in compliance with (1) all federal, state and local low-income housing and other requirements applicable to the Project and (2) any applicable requirements of the Internal Revenue Code, and the final and temporary regulations issued under the Internal Revenue Code. The requirements of this Paragraph (d) shall continue to be satisfied through the Conversion Date. (e) Minimum Occupancy Requirement. Borrower shall provide to Purchaser evidence satisfactory to Purchaser that occupancy at the Project has stabilized and not less than ninety percent (90%) of the residential rental units of the Project were physically occupied under acceptable leases (i.e., legally valid, binding and enforceable written lease agreements with bona fide tenants (excluding employees of the Borrower or any affiliate of the Borrower) providing for initial lease terms of not less than six months and complying with all Legal Requirements and with the Multifamily Underwriting Guidelines (as hereinafter defined)) with appropriate tenants, all for each of the three consecutive full calendar months comprising the Calculation Period. From and after the date construction and/or rehabilitation of the Project is completed, through and including the Conversion Date, Borrower shall promptly deliver to Purchaser each month a current certified rent roll and such other information as may be reasonably required for Purchaser to determine the physical occupancy of the Project. The rent rolls for the second and third months of the Calculation Period shall be dated one month and two months, respectively, from the date of the rent roll for the first month of the Calculation Period. Evidence of stabilized occupancy shall include, but is not limited to, such information and documents required by the Multifamily Underwriting Guidelines to establish the annualized stabilized effective gross income of the Project for each of the three months comprising the Calculation Period including: (i) the percentage of the residential rental units in the Project that have achieved occupancy categorized by bedroom configuration B-3 Forward Purchase Agreement Vista Breeze (e.g., one-bedroom, two-bedroom, etc.), square footage and rent type (i.e., low income or market rate); (ii) actual effective gross income produced by the Project in the Calculation Period; and (iii) rental income by unit type. (f) Permanent Period Amount; Mandatory Prepayment of the Borrower Loan. Purchaser shall have determined the Permanent Period Amount in accordance with the terms of Exhibit C to this Agreement, and Borrower shall have made any prepayment required pursuant to Section 3.3 of the Original Borrower Loan Agreement within the time required to reduce the Borrower Loan to the Permanent Period Amount. (g) Title and Survey. Borrower shall submit to Purchaser at Borrower’s sole cost and expense on or before the Conversion Package Submission Date, (i) a pro-forma commitment for a re-issuance of the title policy insuring the Borrower Loan that (A) reflects the Original Security Instrument, as amended and restated for the benefit of Purchaser, (B) contains no exceptions other than the Permitted Encumbrances (as hereinafter defined), or such other encumbrances and exceptions as shall be acceptable to Purchaser in its sole discretion, and (C) otherwise conforms to Purchaser’s then-current title requirements, and (ii) ALTA “as-built” survey complying with Purchaser’s then-current survey requirements. Borrower shall deliver to Purchaser on the Conversion Date a re-issued title policy that conforms in all respects to the pro- forma approved by Purchaser. (h) Other Real Estate Due Diligence. In addition to those items required by Paragraph (g) above, Purchaser must receive, if requested by Purchaser, at Borrower’s sole cost and expense, on or before the Conversion Package Submission Date satisfactory updates to any and all other third-party reports and other items delivered in connection with Borrower’s application for the Borrower Loan, including, without limitation, the appraisal, any of which may be ordered by Purchaser, in its sole discretion, directly from the third party. (i) Equity Investor. There shall be no change in the identity or interest of the Equity Investor or the parties to the Partnership Agreement (as each such term is hereinafter defined), as of the Closing Date except as otherwise permitted by Section 6.1(c) of this Agreement or Section 21 of the Forward Commitment Fee Security Instrument. The requirements of this Paragraph (i) shall continue to be satisfied through the Conversion Date. (j) No Event of Default. There shall be no Event of Default or event which would be an Event of Default under the Borrower Loan Documents but for the requirement that notice be given or time elapse or both. The requirements of this Paragraph (j) shall continue to be satisfied through the Conversion Date. (k) Conversion Fee and other Costs in Connection with Conversion. Borrower shall pay Purchaser the Conversion Fee for Purchaser’s services in processing information to determine whether the Conditions to Conversion have been satisfied, due and payable upon the earlier to occur of (i) the submission of the Conversion Package or (ii) ninety (90) days prior to the Termination Date. Additionally, Borrower shall pay any other costs or expenses in connection with the Conversion, including, without limitation, actual legal fees and all costs associated with the updates of all third-party reports actually incurred within five (5) Business Days after written request therefor from Purchaser. B-4 Forward Purchase Agreement Vista Breeze (l) Updated Physical Needs Assessment. Purchaser shall have received at Borrower’s cost an updated physical needs assessment, with a replacement reserve analysis, by Purchaser’s engineering consultant (and, if indicated by such analysis or assessment, the replacement reserves for the Project shall be increased accordingly). (m) Management Agent. To the extent not previously provided, Borrower shall provide Purchaser with a copy of the management agreement for the management of the Project, satisfying the requirements of Purchaser’s underwriting criteria. There shall have been no change in the management firm or the management agreement for the management of the Project approved by Purchaser as of the Closing Date without Purchaser’s prior written consent, which shall not be unreasonably withheld, delayed or conditioned. The requirements of this Paragraph (m) shall continue to be satisfied through the Conversion Date. (n) Inspections; Audits. Purchaser and/or its consultants may, in Purchaser’s sole discretion, inspect any portion of the units and audit any portion of the tenant lease files, the results of which inspections and/or audits must be acceptable to Purchaser. (o) Deposits. To the extent not previously paid, Borrower shall have paid to Purchaser, or Servicer, as applicable, any deposits required to be paid under the Borrower Loan Documents at any time prior to the Conversion Date, including, without limitation, any initial deposit for taxes, insurance, or other escrows. (p) Insurance. Purchaser shall have received from its insurance consultant a report satisfactory to Purchaser in its sole discretion that the insurance for the Project conforms in all respects to Purchaser’s requirements, including, without limitation, confirmation that the policy does not contain an exclusion for acts of terrorism. The insurance for the Project must be obtained by Borrower at a cost that will allow for an underwritten debt service coverage ratio no less than the Required Debt Service Coverage Ratio (as defined in Exhibit C hereto). (q) Gap or Bridge Financing Repaid. Any construction, gap or bridge financing provided to Borrower is paid in full or has become subordinate debt of the Borrower conforming to Purchaser’s requirements. (r) MMP/O&M Program. Borrower shall have adopted: (i) a Moisture Management Program/Microbial Operations and Maintenance Program in form and substance acceptable to Purchaser and (ii) any additional operations and maintenance plan that may be necessary or appropriate as determined by Purchaser based on any environmental condition at the Project. (s) Permanent Period Amount. The Permanent Period Amount, as determined by Purchaser in accordance with the provisions of Exhibit C to this Agreement, shall be no less than the Minimum Permanent Period Amount. (t) Flood Insurance Coverage. Purchaser shall have received from Borrower in a form acceptable to Purchaser in its sole discretion either (i) a Letter of Map Revision (LOMR) for the Project evidencing that the Mortgaged Property is not located in an area identified as a flood prone area or a Special Flood Hazard Area (as defined by the U.S. Department of Housing B-5 Forward Purchase Agreement Vista Breeze and Urban Development pursuant to the Flood Disaster Act of 1973), or (ii) an insurance policy that provides acceptable flood insurance coverage. (u) Defined Terms: As used herein, the following terms have the meanings set forth below: “Approved Subordinate Debt” shall mean each of the following: (a) City of Miami Beach, Florida (HOME Loan) Principal Amount: $1,003,969 Maturity: 30 years from issuance of a Final Certificate of Occupancy Interest Rate: 0.00% Amortization: N/A Recourse: Non-Recourse, subject to carveouts (b) Miami-Dade County (Surtax Loan) Principal Amount: $5,950,000 Maturity: December 1, 2053 Interest Rate: 1.00% Amortization: N/A Recourse: Non-Recourse, subject to carveouts (c) Florida Housing Finance Corporation (SAIL Loan) Principal Amount: $3,000,000 Maturity: June 1, 2044 Interest Rate: 1.00% Amortization: N/A Recourse: Non-Recourse, subject to carveouts (d) Florida Housing Finance Corporation (ELI Loan) Principal Amount: $600,000 Maturity: June 1, 2044 Interest Rate: 0.00% Amortization: N/A Recourse: Non-Recourse, subject to carveouts (e) Florida Housing Finance Corporation (NHTF Loan) Principal Amount: $1,301,500 Maturity: December 1, 2053 Interest Rate: 0.00% Amortization: N/A Recourse: Non-Recourse, subject to carveouts (f) Florida Housing Finance Corporation (Viability Loan) Principal Amount: $4,300,000 Maturity: June 1, 2044 Interest Rate: 1.00% B-6 Forward Purchase Agreement Vista Breeze Amortization: N/A Recourse: Non-Recourse, subject to carveouts (g) Housing Authority of the City Of Miami Beach (HACMB Loan) Principal Amount: $8,800,000 Maturity: December 1, 2098 Interest Rate: 5.54% Amortization: N/A Recourse: Non-Recourse, subject to carveouts “Calculation Period” shall mean three (3) consecutive full calendar months occurring prior to the Conversion Date, as the same may be extended pursuant to this Agreement. “Conversion Fee” means $10,000. “Conversion Package” shall mean all items that must be delivered to Purchaser pursuant to this Exhibit B on or before the Conversion Package Submission Date. “Conversion Package Submission Date” shall mean the date that is three (3) months prior to the Conversion Date, as the same may be extended pursuant to the provisions of this Agreement. “Credit Enhancer” means a government sponsored enterprise that at any time, directly or indirectly, purchases the Loan or provides credit enhancement with respect to the Loan. “Equity Contributions” shall mean the equity to be contributed by the Equity Investor to Borrower, in accordance with and subject to the terms and conditions of the Partnership Agreement. “Equity Investor” shall mean Bank of America, N.A., a national banking association, its successors or assigns, as investor limited partner in Borrower. “Governmental Authority” shall mean (i) any governmental municipality or political subdivision thereof, (ii) any governmental or quasi-governmental agency, authority, board, bureau, commission, department, instrumentality or public body, or (iii) any court, administrative tribunal or public utility, agency, commission, office or authority of any nature whatsoever for any governmental unit (federal, state, county, district, municipal, city or otherwise), now or hereafter in existence. “Legal Requirements” shall mean statutes, laws, rules, orders, regulations, ordinances, judgments, decrees and injunctions of Governmental Authorities affecting all or part of the Project or any of Borrower’s property (including the Project) or the construction, rehabilitation, use, alteration or operation thereof, whether now or hereafter enacted and in force, and all permits, licenses and authorizations and regulations relating thereto, and all covenants, agreements, restrictions and encumbrances contained in any instrument, either of record or known to the Borrower, at any time in force affecting all or B-7 Forward Purchase Agreement Vista Breeze part of the Project, including any that may (i) require repairs, modifications or alterations in or to all or part of the Project, or (ii) in any way limit the use and enjoyment thereof. “Managing General Partner” means APC Vista Breeze, LLC, a Florida limited liability company. “Material Adverse Change” means any set of circumstances or events which (a) has or would reasonably be expected to have any material adverse effect whatsoever upon the validity or enforceability of this Agreement or any other document executed in connection with the Permanent Loan; (b) is or would reasonably be expected to be material and adverse to the business, properties, assets, financial condition, results of operations of the Borrower, Managing General Partner, Guarantor or the Mortgaged Property; (c) would reasonably be expected to impair materially the ability of the Borrower, Managing General Partner or Guarantor to duly and punctually pay or perform any of their respective obligations under any of the documents executed in connection with the Permanent Loan to which they are a party; or (d) impairs materially or would reasonably be expected to impair materially any rights of or benefits available to the Governmental Lender under this Agreement or any other document executed in connection with the Permanent Loan, including, without limitation, the ability of Governmental Lender or, upon the assignment of the Borrower Loan to it, of the Purchaser, to the extent permitted, to enforce its legal remedies pursuant to this Agreement or any other document executed in connection with the Permanent Loan. “Multifamily Underwriting Guidelines” shall mean multifamily underwriting guidelines generated by the Credit Enhancer (or if there is no Credit Enhancer, the Purchaser’s internal multifamily underwriting guidelines), as in effect from time to time. “Partnership Agreement” means that certain Amended and Restated Agreement of Limited Partnership, dated as of the Closing Date, among Managing General Partner, Equity Investor, Vista Breeze HACMB, Inc., a Florida not-for-profit corporation, Banc of America CDC Special Holding Company, Inc., a North Carolina corporation, and the Howard D. Cohen Revocable Trust U/A/D 4/6/1993, as withdrawing limited partner. “Permitted Encumbrances” means any easements, encumbrances or restrictions listed on the schedule of exceptions in the title insurance policy issued to Seller as of the date of recordation of the Original Security Instrument insuring Seller’s interest in the Mortgaged Property, together with the liens securing the Approved Subordinate Debt, any extended low-income housing commitment (as such term is defined in Section 42(h)(6)(B) of the Internal Revenue Code) and the Tax Regulatory Agreement (as defined in the Original Funding Loan Agreement) and restrictive use agreements pursuant to any subordinate loan(s), customary easements entered into by Borrower in connection with the development and operation of the Mortgaged Property which Purchaser has determined would have no material adverse effect on the use of the Mortgaged Property, documents required to be recorded by applicable law which have no material adverse effect on the use or value of the Mortgaged Property and are otherwise acceptable to Purchaser, and apartment leases executed in connection with the terms of the Project. C-1 Forward Purchase Agreement Vista Breeze EXHIBIT C CALCULATION OF PERMANENT PERIOD AMOUNT 1. Underwritten NOI. Purchaser shall determine the net operating income of the Project (“Underwritten NOI”). Underwritten NOI is the difference between the annualized stabilized effective gross income of the Project and the annualized expenses for the Project as adjusted. (a) Annualized Stabilized Effective Gross Income. Purchaser shall base its determination of annualized stabilized effective gross income on the (i) rental income from the residential rental units of the Project, and (ii) such of the income from garage, parking, laundry, commercial space and “other income” as allowed by the Multifamily Underwriting Guidelines as Purchaser determines in its discretion. Purchaser shall base its determination on the certified rent roll for each of the three months comprising the Calculation Period. Purchaser shall adjust rental income from the residential rental units of the Project, garage, parking, laundry, commercial space and other income for: (i) evidence of rent deterioration; (ii) concessions, reductions, inducements or forbearances (such as any cash reduction in monthly rent during the term of a lease, any free rent before, during or after the term of a lease, any rent coupons, gift certificates and tangible goods or any other form of rent reduction or forbearance); (iii) re-tenanting costs if a substantial number of leases of units have a term of less than 12 months; (iv) vacancy at the highest of: (i) actual vacancy based on the annualized vacancy from the Calculation Period, and (ii) the applicable minimum physical vacancy factor required by the Multifamily Underwriting Guidelines for the Project based on the number of units and the market in which the Project exists adjusted for concessions and bad debt; (v) 30-day or more delinquencies; (vi) low-income restrictions required by any applicable federal, state or local subsidy program, any restrictive covenant or regulatory agreement or otherwise as required by the Multifamily Underwriting Guidelines; and (vii) all other applicable adjustments required by the Multifamily Underwriting Guidelines. (b) Annualized Expenses. Purchaser shall base its determination of annualized expenses on the higher of: (i) the actual year-to-date expenses of the Project (“Actual Operating Expenses”) on an annualized basis; and C-2 Forward Purchase Agreement Vista Breeze (ii) the annualized expenses for the Project estimated by Purchaser in underwriting and approving the Borrower Loan (“Pro Forma Expenses”). Purchaser shall adjust the Pro Forma Expenses for the following categories of expenses, taking into account all relevant facts and circumstances and making prudent allowances for inflation and other increases in costs: (A) real estate taxes: facts and circumstances include availability of full or partial exemptions or abatements and the length thereof, pending changes in relevant law, growth rate of tax rates of the relevant taxing districts, whether the current assessment of the Project is a full assessment reflecting completion of the Improvements in accordance with the approved Plans and Specifications and assessed values of other properties in the relevant tax district; (B) property liability and other insurance: insurance premiums must reflect insurance coverage for the Project complying in all respects with the Multifamily Underwriting Guidelines requirements; (C) utilities; and (D) management fees for the Project: Purchaser shall adjust the management fee if the property manager or managing agent is related to the Borrower or a Borrower Affiliate and the actual management fee is lower than market rates. In determining the annualized expenses of the Project, Purchaser shall: (i) except with respect to expenses for real estate taxes, property liability and other insurance and management fees, compare both total expenses and individual line items to determine whether Pro Forma Expenses or Actual Operating Expenses are higher and either (a) adjust the overall number if the sum of changes results in a higher amount, or (b) apply Actual Operating Expenses with supportive reasoning to justify analysis; (ii) make appropriate adjustments for any unusually low or high expenses which do not reflect stable operations of the Project; (iii) for non-residential management expenses (incurred, for example, for off-site management and leasing), use the greater of actual expenses or the percentage of effective gross income used in the original underwriting; and (iv) for replacement reserve deposit amounts, use the greater of the amount used by Purchaser in the original underwriting or the actual amount required to be set aside by the Replacement Reserve Agreement. (c) Adjustments for Special Risks. Purchaser shall further adjust Underwritten NOI and the component parts of Underwritten NOI on account of any special risks addressed by the Multifamily Underwriting Guidelines. C-3 Forward Purchase Agreement Vista Breeze 2. Permanent Period Amount. Purchaser shall determine the Permanent Period Amount by dividing (x) by (y), where (x) is the quotient obtained by dividing the Underwritten NOI of the Project by the applicable Required Debt Service Coverage Ratio and (y) is the Annual Debt Service Constant or, expressed as a formula: x = (Underwritten NOI ÷ Permanent Period Amount = Required Debt Service Coverage Ratio) y = Annual Debt Service Constant Defined Terms: As used herein, the following terms have the meanings set forth below: “Annual Debt Service Constant” shall mean the constant annual percentage determined by Purchaser necessary to fully amortize the Borrower Loan in level monthly annuity payments over a forty (40) year period at the Underwriting Rate (when expressed as a percentage, carried out to at least six (6) decimal places). “Multifamily Underwriting Guidelines” shall mean multifamily underwriting guidelines generated by the Credit Enhancer (or if there is no Credit Enhancer, the Purchaser’s internal multifamily underwriting guidelines), as in effect from time to time. “Required Debt Service Coverage Ratio” shall mean 1.15 to 1.00. “Required Loan to Value Ratio” shall mean 90%, based on the market value, if applicable, of permanent below market financing and assuming project rents on 80% or more of the units are discounted to a level at least ten percent below market rentals, otherwise 85%. “Underwriting Rate” shall mean the following: 6.27% In the event the Conversion Date occurs on or prior to July 1, 2026. 6.32% In the event the Conversion Date occurs after July 1, 2026. 6.37% In the event the Conversion Date occurs after January 1, 2027. “Underwritten NOI” shall have the meaning set forth in this Exhibit C. 3. Earn-Out Option. At the Conversion Date, Borrower will have the option to request an increase of up to $1,187,500 above the contemplated $11,875,000 Maximum Permanent Period Amount (such increase above $11,875,000 shall hereafter be referred to as the “Earn-Out Amount”) (bringing the Permanent Period Amount up to $13,062,500) (the “Earn-Out Option”), which amount shall be determined by Purchaser in its sole discretion based on Purchaser’s Conversion underwriting and application of Purchaser’s loan sizing parameters. To the extent that C-4 Forward Purchase Agreement Vista Breeze the Permanent Period Amount (including the Earn-Out Amount) exceeds the Required Loan to Value Ratio, Purchaser will require a new appraisal at Borrower’s expense to support the Earn- Out Amount. The Permanent Period Amount must support the Required Debt Service Coverage at Conversion and a minimum 1.15 debt service coverage in the fifteenth (15th) year of the exit analysis performed by Purchaser in connection with Conversion underwriting. To the extent that the Borrower exercises the Earn-Out Option, and the Purchaser confirms that the required conditions described above are satisfied, such Earn-Out Option shall be evidenced by the terms of the Permanent Borrower Note. The interest rate on the Earn-Out Amount will be set at a fixed rate five (5) Business Days prior to the Conversion Date, and which shall be the sum of the SOFR swap index (“SOFR Swap Index”) for the remaining term, plus a spread of 2.40% (the “Spread”), provided however, that if the Termination Date is extended to the First Extended Termination Date, an additional 0.05% will be added to the Spread, such that the spread will be 2.45%, and if the Termination Date is further extended to the Second Extended Termination Date, an additional 0.05% will be added to the Spread, such that the spread will be 2.50%; and provided further, that if the SOFR Swap Index becomes unavailable, then the Purchaser, in its sole and absolute discretion, will choose a successor index and provide notice of such choice to the Borrower (the “Earn-Out Interest Rate”). In no event shall the interest rate on the Earn-Out Amount be less than 0.25% less than the interest rate on the Maximum Permanent Period Amount. The rate of the Permanent Borrower Note will be a blended rate consisting of the Earn-Out Interest Rate and the fixed rate of the Maximum Permanent Period Amount (the “Permanent Period Interest Rate”) set as of the Closing Date and any increase to the Permanent Period Interest Rate as set forth in Section 4.1 of this Agreement. Such blended rate shall be the Underwriting Rate for all purposes hereunder. D-1 Forward Purchase Agreement Vista Breeze EXHIBIT D FORMS OF LOAN DOCUMENTS [See Attached] 1. Amended and Restated Funding Loan Agreement 2. Amended and Restated Borrower Loan Agreement 3. Amended and Restated Multifamily Note 4. Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents and Security Agreement (Florida) 5. Assignment of Mortgage and Loan Documents 6. Exceptions to Non-Recourse Guaranty 7. Replacement Reserve Agreement 8. Assignment of Management Agreement 9. Agreement of Environmental Indemnification 10. Loan Covenant Agreement 11. Assignment of HAP Contract 12. Subordination and Intercreditor Agreement (City) 13. Subordination and Intercreditor Agreement (County) 14. Subordination and Intercreditor Agreement (FHFC) 15. Subordination and Intercreditor Agreement (HACMB) 16. Insurance Anti-Coercion Statement 17. Business Purpose Affidavit 18. Continuing Disclosure Agreement 19. Borrower’s Conversion Certificate 20. UCC Financing Statements D Forward Purchase Agreement Vista Breeze EXHIBIT D-1 TO FORWARD PURCHASE AGREEMENT FORM OF AMENDED AND RESTATED FUNDING LOAN AGREEMENT [See attached] 4856-5616-9347.5 FOLEY DRAFT #4 December 13, 2023 AMENDED AND RESTATED FUNDING LOAN AGREEMENT (Permanent Phase) among CITIBANK, N.A., as Funding Lender HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, as Governmental Lender and THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., as Fiscal Agent Relating to Vista Breeze 175 S. Shore Drive and 280 S. Shore Drive, in the City of Miami Beach, Miami-Dade County, Florida Loan Principal Amount: $____________ Dated as of ______, 202_ (Conversion Date) 4856-5616-9347.5 TABLE OF CONTENTS Page ARTICLE I DEFINITIONS; PRINCIPLES OF CONSTRUCTION Section 1.1. Definitions. ......................................................................................................................... 2 Section 1.2. Effect of Headings and Table of Contents. ....................................................................... 11 Section 1.3. Date of Funding Loan Agreement. ................................................................................... 11 Section 1.4. Designation of Time for Performance. ............................................................................. 11 Section 1.5. Interpretation. .................................................................................................................... 11 ARTICLE II TERMS; GOVERNMENTAL LENDER NOTE Section 2.1. Terms. ............................................................................................................................... 11 Section 2.2. Form of Governmental Lender Note. ................................................................................ 13 Section 2.3. Execution and Delivery of Governmental Lender Note. .................................................. 13 Section 2.4. Authentication. .................................................................................................................. 13 Section 2.5. Registration and Transfer of Governmental Lender Note. ............................................... 13 Section 2.6. Restrictions on Transfer. ................................................................................................... 14 ARTICLE III PREPAYMENT Section 3.1. Prepayment of the Governmental Lender Note from Prepayments Under the Permanent Phase Borrower Note. ....................................................................................................... 15 Section 3.2. Notice of Prepayment. ...................................................................................................... 15 ARTICLE IV SECURITY Section 4.1. Security for the Funding Loan. ......................................................................................... 15 Section 4.2. Delivery of Security. ......................................................................................................... 16 ARTICLE V LIMITED LIABILITY Section 5.1. Source of Payment of Funding Loan, the Governmental Lender Note and Other Obligations. ....................................................................................................................... 17 Section 5.2. Exempt from Individual Liability. .................................................................................... 17 Section 5.3. Revenue Obligation. ......................................................................................................... 18 ARTICLE VI RESERVED ARTICLE VII FUNDS AND ACCOUNTS Section 7.1. Authorization to Create Funds and Accounts. .................................................................. 19 Section 7.2. Investment of Funds. ......................................................................................................... 19 Section 7.3. Establishment of Funds and Accounts. ............................................................................. 20 Section 7.4. Loan Payment Fund. ......................................................................................................... 20 ii 4856-5616-9347.5 Section 7.5. Administration Fund. ........................................................................................................ 21 Section 7.6. Project Fund. ..................................................................................................................... 21 Section 7.7. Rebate Fund. ..................................................................................................................... 21 Section 7.8. Amounts Remaining in Funds. ......................................................................................... 22 ARTICLE VIII REPRESENTATIONS AND COVENANTS Section 8.1. General Representations. .................................................................................................. 22 Section 8.2. No Encumbrance on Security. .......................................................................................... 23 Section 8.3. Repayment of Funding Loan. ........................................................................................... 23 Section 8.4. Servicer. ............................................................................................................................ 23 Section 8.5. Borrower Loan Agreement Performance. ......................................................................... 23 Section 8.6. Maintenance of Records; Inspection of Records. ............................................................. 23 Section 8.7. Tax Covenants. ................................................................................................................. 24 Section 8.8. Performance by the Borrower. .......................................................................................... 25 Section 8.9. Maintenance of Records. .................................................................................................. 25 ARTICLE IX DEFAULT; REMEDIES Section 9.1. Events of Default. ............................................................................................................. 25 Section 9.2. Acceleration of Maturity; Rescission and Annulment. ..................................................... 26 Section 9.3. Additional Remedies; Funding Lender Enforcement. ...................................................... 26 Section 9.4. Application of Money Collected. ...................................................................................... 28 Section 9.5. Remedies Vested in Funding Lender. ............................................................................... 28 Section 9.6. Restoration of Positions. ................................................................................................... 28 Section 9.7. Rights and Remedies Cumulative. .................................................................................... 29 Section 9.8. Delay or Omission Not Waiver. ........................................................................................ 29 Section 9.9. Waiver of Past Defaults. ................................................................................................... 29 Section 9.10. Remedies Under Borrower Loan Agreement or Permanent Phase Borrower Note. ......... 29 Section 9.11. Waiver of Appraisement and Other Laws. ....................................................................... 29 Section 9.12. Suits to Protect the Security. ............................................................................................. 29 Section 9.13. Remedies Subject to Applicable Law. .............................................................................. 30 Section 9.14. Assumption of Obligations. .............................................................................................. 30 ARTICLE X AMENDMENT; AMENDMENT OF FUNDING LOAN AGREEMENT AND OTHER DOCUMENTS Section 10.1. Amendment of Funding Loan Agreement. ....................................................................... 30 Section 10.2. Amendments Require Funding Lender Consent. .............................................................. 30 Section 10.3. Consents and Opinions. .................................................................................................... 30 ARTICLE XI THE FISCAL AGENT Section 11.1. Appointment of Fiscal Agent; Acceptance. ...................................................................... 31 Section 11.2. Certain Duties and Responsibilities of Fiscal Agent. ....................................................... 31 Section 11.3. Notice of Defaults. ............................................................................................................ 32 Section 11.4. Certain Rights of Fiscal Agent. ......................................................................................... 33 Section 11.5. Not Responsible for Recitals. ........................................................................................... 34 iii 4856-5616-9347.5 Section 11.6. May Hold Governmental Lender Note. ............................................................................ 34 Section 11.7. Moneys Held in Trust. ...................................................................................................... 34 Section 11.8. Compensation and Reimbursement. ................................................................................. 34 Section 11.9. Fiscal Agent Required; Eligibility. ................................................................................... 35 Section 11.10. Resignation and Removal; Appointment of Successor. .................................................... 35 Section 11.11. Acceptance of Appointment by Successor. ...................................................................... 36 Section 11.12. Merger, Conversion, Consolidation or Succession to Business. ....................................... 36 Section 11.13. Appointment of Co-Fiscal Agent. ..................................................................................... 36 Section 11.14. Loan Servicing. ................................................................................................................. 37 Section 11.15. No Recourse Against Officers or Employees of Fiscal Agent. ......................................... 37 Section 11.16. USA Patriot Act Requirements of the Fiscal Agent. ........................................................ 37 Section 11.17. Filing of Financial Statements. ......................................................................................... 38 ARTICLE XII MISCELLANEOUS Section 12.1. Notices. ............................................................................................................................. 38 Section 12.2. Term of Funding Loan Agreement. .................................................................................. 40 Section 12.3. Successors and Assigns. ................................................................................................... 41 Section 12.4. Legal Holidays. ................................................................................................................. 41 Section 12.5. Governing Law. ................................................................................................................ 41 Section 12.6. Invalidity, Illegality or Unenforceability of Provisions. ................................................... 41 Section 12.7. Execution in Several Counterparts. ................................................................................... 41 Section 12.8. Nonrecourse Obligation of the Borrower. ........................................................................ 41 Section 12.9. Waiver of Trial by Jury. .................................................................................................... 41 Section 12.10. Electronic Transactions. .................................................................................................... 41 Section 12.11. Reference Date. ................................................................................................................. 42 EXHIBIT A FORM OF TRANSFEREE REPRESENTATIONS LETTER 4856-5616-9347.5 AMENDED AND RESTATED FUNDING LOAN AGREEMENT This AMENDED AND RESTATED FUNDING LOAN AGREEMENT (this “Funding Loan Agreement”), is made and entered into as of ___________, 20__ (Conversion Date), by and among CITIBANK, N.A., in its capacity as Funding Lender (the “Funding Lender” or the “Funding Lender”), the HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA (the “Governmental Lender”), a public body corporate and politic organized and existing under the laws of the State of Florida (the “State”), and THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., a national banking association, organized and operating under the laws of the United States of America, having a corporate trust office in Jacksonville, Florida, as Fiscal Agent (the “Fiscal Agent”) and amends and restates the Funding Loan Agreement, dated as of December 1, 2023 (the “Construction Phase Funding Loan Agreement”) by and among BANK OF AMERICA, N.A., in its capacity as Initial Funding Lender (the “Initial Funding Lender”), the Governmental Lender and the Fiscal Agent. The Funding Loan Agreement, as amended and restated hereby is referred to herein as the Funding Loan Agreement. Capitalized terms are defined in Section 1.01 of this Funding Loan Agreement. RECITALS A. Pursuant to Chapter 159, Part IV, Florida Statutes, as amended, Resolution R-1194-78 adopted by the Board of County Commissioners of Miami-Dade County (the “Board”) on October 17, 1978, Ordinance No. 78-89 enacted by the Board on December 12, 1978 and Ordinance No. 11-99 enacted by the Board on December 6, 2011 (collectively, the “Act”) and the Construction Phase Borrower Loan Agreement dated as of December 1, 2023 (the “Construction Phase Borrower Loan Agreement”) by and among the Governmental Lender, the Fiscal Agent and Vista Breeze, Ltd., a Florida limited partnership, duly organized and existing under the laws of the State (the “Borrower”), the Governmental Lender made a construction period mortgage loan pursuant to the Construction Phase Borrower Loan Agreement (the “Borrower Loan”) to the Borrower in the aggregate principal amount of $32,500,000 to provide for the financing of the acquisition, construction and equipping of a multifamily rental housing development to be located at 175 S. Shore Drive and 280 S. Shore Drive, in the City of Miami Beach, Miami-Dade County, Florida known as Vista Breeze (the “Project”). B. The Governmental Lender made the Borrower Loan to the Borrower with the proceeds received from the separate loan made to the Governmental Lender by the Initial Funding Lender pursuant to the Funding Loan Agreement in the maximum aggregate principal amount of $32,500,000 (the “Funding Loan”). The Funding Loan was evidenced by the Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) dated December 15, 2023 (together with all riders and addenda thereto, the “Governmental Lender Note”) delivered by the Governmental Lender to the Initial Funding Lender. C. The Borrower’s repayment obligations in respect of the Borrower Loan were evidenced by a Multifamily Note dated December 15, 2023 (together with all riders and modifications thereto, the “Construction Phase Borrower Note”) delivered to the Governmental Lender, which Construction Phase Borrower Note was endorsed by the Governmental Lender to the Fiscal Agent as security for the Funding Loan. D. To secure the Borrower’s obligations under the Construction Phase Borrower Note, the Borrower executed and delivered to the Governmental Lender a Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing dated as of December 1, 2023 (the “Security Instrument”) with respect to the Project, which Security Instrument was assigned by the Governmental Lender to the Fiscal Agent as security for the Funding Loan. 2 4856-5616-9347.5 E. The Initial Funding Lender, the Funding Lender and the Borrower entered into a Forward Purchase Agreement, dated as of December 1, 2023 (the “Forward Purchase Agreement”) pursuant to which the Funding Lender agreed to purchase the Funding Loan from the Initial Funding Lender upon the satisfaction of certain conditions, including the Conditions to Conversion. The Conditions to Conversion have been satisfied and the Borrower Loan is converting from the Borrower Loan to the Permanent Phase Borrower Loan on the date hereof which is the Conversion Date. F. In connection with the Funding Lender’s purchase of the Funding Loan on the Conversion Date, (i) this Funding Loan Agreement and the Amended and Restated Borrower Loan Agreement, dated the date hereof, between the Governmental Lender, the Borrower and the Fiscal Agent (the “Borrower Loan Agreement”) are being executed and delivered and shall become effective, (ii) the Permanent Phase Borrower Note, dated the date hereof, from the Borrower to the Governmental Lender (the “Permanent Phase Borrower Note”), which amends and restates in its entirety the Construction Phase Borrower Note, is being executed and delivered by the Borrower and assigned to the Funding Lender by the Governmental Lender, (iii) the Security Instrument is being amended and restated and (iv) this Funding Loan Agreement, the Borrower Loan Agreement and the Permanent Phase Borrower Note will secure the Funding Loan in substitution for the Construction Phase Funding Loan Agreement, Construction Phase Borrower Loan Agreement and Construction Phase Borrower Note, respectively, which Construction Phase Funding Loan Agreement and Construction Phase Borrower Loan Agreement are simultaneously being terminated. G. All of the Conditions to Conversion (as defined in the Forward Purchase Agreement) and all of the other conditions of Funding Lender’s purchase of the Funding Loan set forth in the Forward Purchase Agreement have been, or as of the Conversion Date will be, satisfied. NOW, THEREFORE, in consideration of the premises and of the purchase of the Funding Loan by the Funding Lender, and for other good and valuable consideration, the receipt of which is hereby acknowledged, the parties hereto agree as follows: ARTICLE I DEFINITIONS; PRINCIPLES OF CONSTRUCTION Section 1.1. Definitions. For all purposes of this Funding Loan Agreement, except as otherwise expressly provided or unless the context otherwise clearly requires: (a) Unless specifically defined herein, all capitalized terms shall have the meanings ascribed thereto in the Borrower Loan Agreement. (b) The terms “herein,” “hereof” and “hereunder” and other words of similar import refer to this Funding Loan Agreement as a whole and not to any particular Article, Section or other subdivision. The terms “agree” and “agreements” contained herein are intended to include and mean “covenant” and “covenants.” (c) All references made (i) in the neuter, masculine or feminine gender shall be deemed to have been made in all such genders, and (ii) in the singular or plural number shall be deemed to have been made, respectively, in the plural or singular number as well. Singular terms shall include the plural as well as the singular, and vice versa. (d) All accounting terms not otherwise defined herein shall have the meanings assigned to them, and all computations herein provided for shall be made, in accordance with GAAP (Generally Accepted Accounting Principles). 3 4856-5616-9347.5 (e) All references in this instrument to designated “Articles,” “Sections” and other subdivisions are to the designated Articles, Sections and subdivisions of this instrument as originally executed. (f) All references in this instrument to a separate instrument are to such separate instrument as the same may be amended or supplemented from time to time pursuant to the applicable provisions thereof. (g) References to the Governmental Lender Note as “tax exempt” or to the “tax exempt status” of the Governmental Lender Note are to the exclusion of interest on the Governmental Lender Note (other than any portion of the Governmental Lender Note held by a “substantial user” of the Project or a “related person” within the meaning of Section 147 of the Code) from gross income for federal income tax purposes pursuant to Section 103(a) of the Code. (h) The following terms have the meanings set forth below: “Act” shall have the meaning assigned to such term in the recitals above. “Additional Borrower Payments” shall have the meaning given such term in the Borrower Loan Agreement. “Administration Fund” shall mean the fund by that name created and established under this Funding Loan Agreement. “Affiliate” shall mean, as to any Person, any other Person that, directly or indirectly, is in Control of, is Controlled by or is under common Control with such Person. “Approved Transferee” means (1) a “qualified institutional buyer” (“QIB”) as defined in Rule 144A promulgated under the Securities Act of 1933, as in effect on the date hereof (the “Securities Act”) that is a financial institution or commercial bank having capital and surplus of $5,000,000,000 or more, (2) an Affiliate of the Funding Lender that is a QIB, (3) a trust or custodial arrangement established by the Funding Lender or one of its Affiliates or any state or local government or any agency or entity which is a political subdivision of a federal, state or local government (a “Governmental Entity”), in each case (i) the beneficial interests in which will be owned only by QIBs, (ii) the beneficial interests in which will be rated in the “A” category or higher without regard to modifier (or the equivalent investment grade category) by at least one nationally recognized rating agency and (iii) evidence of compliance with (i) or (ii) acceptable to the Fiscal Agent, or (4) a Governmental Entity. For any transfers after the six (6) month anniversary of the Conversion Date, “A” will be replaced by “BBB” for purposes of clause 3(ii) above. “Authorized Attesting Officer” means the Vice Chair, Secretary/Treasurer or any Assistant Secretary of the Governmental Lender, or such other officer or official or member of the Governmental Lender, including but not limited to the Executive Director of the Governmental Lender who, in accordance with the County Authorization, the law of the State, the bylaws or other governing documents of the Governmental Lender, or practice or custom, regularly attests or certifies official acts and records of the Governmental Lender, and includes any assistant or deputy officer to the principal officer or officers exercising such responsibilities. “Authorized Governmental Lender Representative” shall mean the Chair, Vice-Chair, and any other, officer or employee of the Governmental Lender designated to perform a specified act, to sign a specified document or to act generally on behalf of the Governmental Lender as evidenced by a written certificate furnished to the Funding Lender, the Fiscal Agent, the Servicer (if any) and the Borrower containing the specimen signature of such person and signed on behalf of the Governmental Lender by the 4 4856-5616-9347.5 Chair, Vice-Chair or Executive Director of the Governmental Lender. Such certificate may designate an alternate or alternates, each of whom shall be entitled to perform all duties of the Authorized Governmental Lender Representative. “Borrower” shall mean Vista Breeze, Ltd., a Florida limited partnership, and its successors and assigns. “Borrower Loan” shall mean the mortgage loan made by the Governmental Lender to the Borrower pursuant to the Construction Phase Borrower Loan Agreement in the original maximum aggregate principal amount of $32,500,000, as originally evidenced by the Construction Phase Borrower Note, which on the Conversion Date is outstanding in the amount of $__________ and evidenced by the Permanent Phase Borrower Note. “Borrower Loan Agreement” shall mean the Amended and Restated Borrower Loan Agreement, dated as of _______, 20__, between the Governmental Lender, the Borrower and the Fiscal Agent, as supplemented, amended or replaced from time to time in accordance with its terms. “Borrower Loan Agreement Default” shall mean any event of default set forth in 8.1 of the Borrower Loan Agreement. A Borrower Loan Agreement Default shall “exist” if a Borrower Loan Agreement Default shall have occurred and be continuing beyond any applicable cure period. “Borrower Loan Documents” shall have the meaning given to such term in the Borrower Loan Agreement. “Business Day” shall mean any day other than (i) a Saturday or a Sunday, or (ii) a day on which the offices of the Fiscal Agent in Jacksonville, Florida or federally insured depository institutions in New York, New York are authorized or obligated by law, regulation, governmental decree or executive order to be closed. “Code” shall mean the Internal Revenue Code of 1986, as in effect on the Delivery Date or (except as otherwise referenced herein) as it may be amended to apply to obligations issued on the Delivery Date, together with applicable proposed, temporary and final regulations promulgated, and applicable official public guidance published, under the Code. “Compliance Monitoring Fee” means the compliance monitoring fee in an annual amount equal to $30.00 per rental unit in the Project (119 units; $3,570.00 annual fee) (subject to adjustment from time to time by the Governmental Lender) to be paid by the Borrower to the Governmental Lender pursuant to the Regulatory Agreement. “Conditions to Conversion” shall have the meaning given such term in the Forward Purchase Agreement. “Control” shall mean, with respect to any Person, either (i) ownership directly or through other entities of more than 50% of all beneficial equity interest in such Person, or (ii) the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of such Person, through the ownership of voting securities, by contract or otherwise. “Conversion Date” shall mean ___________, the date on which the Funding Lender purchases the Governmental Lender Note from the Initial Funding Lender and assumes the role of the Funding Lender under the Funding Loan Documents. 5 4856-5616-9347.5 “County” shall mean Miami-Dade County, Florida. “County Authorization” has the meaning set forth in the recitals above. “Delivery Date” shall mean the date of issuance and delivery of the Governmental Lender Note. “Equity Investor” shall have the meaning ascribed thereto in the Borrower Loan Agreement. “Event of Default” shall have the meaning ascribed thereto in Section 9.1 hereof. “Fee Guaranty & Environmental Indemnity” means the Fee Guaranty and Environmental Indemnity Agreement, dated as of December 1, 2023, by and among the Governmental Lender, the Fiscal Agent and the Governmental Lender Guarantors. “Fiscal Agent” shall mean The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent hereunder, and any successor fiscal agent or co-fiscal agent appointed under this Funding Loan Agreement. “Fiscal Agent’s Fees” shall mean the Fiscal Agent’s initial acceptance fee and expenses of $2,000 plus fees and expenses of its counsel in conjunction with the delivery of the Governmental Lender Note and the ongoing compensation and expenses payable to the Fiscal Agent as follows: (i) the annual administration fees of the Fiscal Agent, for the ordinary services of the Fiscal Agent rendered under this Funding Loan Agreement during each twelve-month period and shall be $4,250, payable in advance in semiannual installments of $2,125 on the Delivery Date and each December 1 and June 1 thereafter; (ii) the reasonable fees and charges of the Fiscal Agent for necessary extraordinary services rendered by it and/or reimbursement for extraordinary expenses incurred by it under this Funding Loan Agreement as and when the same become due, including reasonable fees and expenses of legal counsel and internal default administrators (including fees prior to litigation, at trial or for appellate proceedings); provided, however, that the Fiscal Agent shall not be required to undertake any such extraordinary services unless provision for payment of extraordinary expenses satisfactory to the Fiscal Agent shall have been made; and (iii) for purposes of the Borrower Loan Agreement, indemnification of the Fiscal Agent by the Borrower. “Funding Lender” shall mean Citibank, N.A., a national banking association, and any successor under this Funding Loan Agreement and the Borrower Loan Documents. “Funding Loan Agreement” shall mean this Amended and Restated Funding Loan Agreement, dated ________, 20__, by and among the Funding Lender, the Governmental Lender and the Fiscal Agent, as it may from time to time be supplemented, modified or amended by one or more instruments supplemental hereto entered into pursuant to the applicable provisions hereof. “Funding Loan Documents” shall mean (i) this Funding Loan Agreement, (ii) the Borrower Loan Agreement, (iii) the Regulatory Agreement, (iv) the Tax Certificate, (v) the Borrower Loan Documents, (vi) the Loan Covenant Agreement, (vii) the Governmental Lender Guaranties, (viii) all other documents evidencing, securing, governing or otherwise pertaining to the Funding Loan, and (ix) all amendments, modifications, renewals and substitutions of any of the foregoing. 6 4856-5616-9347.5 “Governmental Lender” shall mean the Housing Finance Authority of Miami-Dade County, Florida. “Governmental Lender Extraordinary Fees and Expenses” means the expenses and disbursements payable to the Governmental Lender under this Funding Loan Agreement for extraordinary services and extraordinary expenses, including extraordinary fees, costs and expenses incurred by the Governmental Lender, Bond Counsel and counsel to the Governmental Lender which are to be paid by the Borrower pursuant to the Borrower Loan Documents. “Governmental Lender Fee” means, collectively, the Governmental Lender Ordinary Fees and Expenses and the Governmental Lender Extraordinary Fees and Expenses. “Governmental Lender Guaranties” means, collectively, (i) the Guaranty of Recourse Obligations, (ii) the Operating Deficit Guaranty, and (iii) the Fee Guaranty and Environmental Indemnity, each dated as of December 1, 2023, by the Governmental Lender Guarantors for the benefit of the Governmental Lender and the Fiscal Agent. “Governmental Lender Guarantors” means, collectively, the Borrower, APC Vista Breeze, LLC, a Florida limited liability company, Vista Breeze HACMB, Inc., a Florida not for profit corporation, Atlantic Pacific Communities, LLC, a Delaware limited liability company, APC Vista Breeze Development, LLC, a Florida limited liability company, HACMB Development, LLC, a Florida limited liability company, Howard D. Cohen Revocable Trust Under Agreement Dated 4/6/1993, and Howard D. Cohen, individually. “Governmental Lender Ordinary Fees and Expenses” means collectively (i) the annual fee of the Governmental Lender, payable by the Borrower in the amount of 25 basis points (0.25%) of the outstanding principal amount of the Governmental Lender Note (calculated on the Business Day prior to any reduction on such payment date), payable in semiannual installments in arrears on each December 1 and June 1, commencing on June 1 or December 1 following Conversion, pro-rated as applicable to such date, (ii) the Compliance Monitoring Fee and (iii) the Governmental Lender Short-Term Prepayment Fee, if applicable. “Governmental Lender Short-Term Prepayment Fee” means the applicable fee in the following schedule determined based on the principal amount of the Governmental Lender Note to be prepaid and the length of time between the date of issuance of the Note and the prepayment or final maturity of the Governmental Lender Note; provided however, such fee shall not be less than $20,000, which fee is payable on the partial or full prepayment or final maturity date, as applicable: Prepayment Date Note Amount ≤ 18-Month 18+ to 24-Months 24+ to 60-Months $15 million or less 31 bps 24 bps 18 bps Above $15 million up to $20 million 30 bps 23 bps 17 bps $20 million up to $25 million 29 bps 22 bps 16 bps $25 million up to $30 million 28 bps 21 bps 15 bps $30 million or above 27 bps 20 bps 14 bps 7 4856-5616-9347.5 “Governmental Lender Note” shall mean the Governmental Lender Note described in the recitals of this Funding Loan Agreement. “Guaranty of Recourse Obligations” means the Absolute and Unconditional Guaranty of Recourse Obligations, dated as of December 1, 2023, from the Governmental Lender Guarantors, jointly and severally, in favor of the Governmental Lender and the Fiscal Agent. “Highest Rating Category” shall mean, with respect to a Permitted Investment, that the Permitted Investment is rated by S&P or Moody’s in the highest rating given by that Rating Agency for that general category of security. By way of example, the Highest Rating Category for tax exempt municipal debt established by S&P is “A 1+” for debt with a term of one year or less and “AAA” for a term greater than one year, with corresponding ratings by Moody’s of “MIG 1” (for fixed rate) or “VMIG 1” (for variable rate) for three (3) months or less and “Aaa” for greater than three months. If at any time (i) both S&P and Moody’s rate a Permitted Investment and (ii) one of those ratings is below the Highest Rating Category, then such Permitted Investment will, nevertheless, be deemed to be rated in the Highest Rating Category if the lower rating is no more than one rating category below the highest rating category of that Rating Agency. For example, a Permitted Investment rated “AAA” by S&P and “Aa3” by Moody’s is rated in the Highest Rating Category. If, however, the lower rating is more than one full rating category below the Highest Rating Category of that Rating Agency, then the Permitted Investment will be deemed to be rated below the Highest Rating Category. For example, a Permitted Investment rated “AAA” by S&P and “A1” by Moody’s is not rated in the Highest Rating Category. “Loan Covenant Agreement” shall mean the Loan Covenant Agreement between the Borrower and the Funding Lender, dated the date hereof. “Loan Payment Fund” shall mean the fund by that name created and established under this Funding Loan Agreement. “Maturity Date” shall mean with respect to the Governmental Lender Note, July 1, 2057. “Minimum Beneficial Ownership Amount” shall mean an amount not less than fifteen percent (15%) of the aggregate outstanding principal amount of the Funding Loan. “Moody’s” shall mean Moody’s Investors Service, Inc., or its successor. “Operating Deficit Guaranty” means the Absolute and Unconditional Guaranty of Operating Deficits, dated as of December 1, 2023, from the Governmental Lender Guarantors, jointly and severally, to the Governmental Lender and the Fiscal Agent. “Opinion of Counsel” shall mean a written opinion from an attorney or firm of attorneys, acceptable to the Funding Lender and the Governmental Lender with experience in the matters to be covered in the opinion; provided that whenever an Opinion of Counsel is required to address the exclusion of interest on the Governmental Lender Note from gross income for purposes of federal income taxation, such opinion shall be provided by Tax Counsel. “Permanent Phase Borrower Loan” shall mean the mortgage loan made by the Governmental Lender to the Borrower pursuant to the Borrower Loan Agreement in the aggregate principal amount of $___________, as evidenced by the Permanent Phase Borrower Note. “Permanent Phase Borrower Note” shall mean the “Permanent Phase Borrower Note” as defined in the Recitals hereto. 8 4856-5616-9347.5 “Permitted Investments” shall mean, to the extent authorized by law for investment of any moneys held under this Funding Loan Agreement: (a) Direct obligations of the United States of America including obligations issued or held in book-entry form on the books of the Department of the Treasury of the United States of America (“Government Obligations”). (b) Direct obligations of, and obligations on which the full and timely payment of principal and interest is unconditionally guaranteed by, any agency or instrumentality of the United States of America, or direct obligations of the World Bank, which obligations are rated in the Highest Rating Category. (c) Demand deposits or time deposits with, or certificates of deposit issued by, the Fiscal Agent or its Affiliates or any bank organized under the laws of the United States of America or any state or the District of Columbia which has combined capital, surplus and undivided profits of not less than $50,000,000 and maturing in less than 365 days; provided that the Fiscal Agent or such other institution has been rated at least “VMIG-1”/”A-1+” by Moody’s/S&P which deposits or certificates are fully insured by the Federal Deposit Insurance Corporation or collateralized pursuant to the requirements of the Office of the Comptroller of the Currency. (d) Bonds (including tax-exempt bonds), bills, notes or other obligations of or secured by Fannie Mae, Freddie Mac, the Federal Home Loan Bank or the Federal Farm Credit Bank. (e) Money market funds rated AAA by S&P which are registered with the Securities and Exchange Commission and which meet the requirements of Rule 2(a)(7) of the Investment Company Act of 1940, as amended, which may be administered by the Fiscal Agent or its Affiliates. (f) Collateralized Investment Agreements or Repurchase Agreements with financial institutions rated in the “A” category or higher without regard to qualifiers, by at least one Rating Agency. The agreement must be continually collateralized with obligations specified in paragraphs (a), (b) and/or (d) above, eligible for wire through the Federal Reserve Bank System or the DTC/PTC as applicable, and at a level of at least 103% of the amount on deposit and valued no less than daily. The collateral must be held by a third party custodian and be free and clear of all liens and claims of third parties. Securities must be valued daily, marked-to-market at current market price plus accrued interest. If the market value of the securities is found to be below the required level, the provider must restore the market value of the securities to the required level within one (1) business day. Permitted collateral must be delivered to and held in a segregated account by the Fiscal Agent or a custodian (the “Collateral Agent”), and the Collateral Agent cannot be the provider. The collateral must be delivered to the Collateral Agent before/simultaneous with payment (perfection by possession of certificated securities). Acceptable collateral must be free and clear of all liens and claims of third parties and shall be registered in the name of the Collateral Agent for the benefit of the Governmental Lender and Fiscal Agent. The agreement shall state that the Collateral Agent has a valid and perfected first priority security interest in the securities, any substituted securities and all proceeds thereof. (g) Any other investment authorized by the laws of the State, if such investment is approved in advance in writing by the Funding Lender in its sole discretion. Permitted Investments shall not include any of the following: (1) Except for any investment described in the next sentence, any investment or any agreement with a maturity profile greater than the date(s) on which funds representing the corpus of the investment may be needed under the Funding Loan Documents. This exception (1) shall not apply to Permitted Investments listed in paragraph (g). 9 4856-5616-9347.5 (2) Any obligation bearing interest at an inverse floating rate. (3) Any investment which may be prepaid or called at a price less than its purchase price prior to stated maturity. (4) Any investment the interest rate on which is variable and is established other than by reference to a single index plus a fixed spread, if any, and which interest rate moves proportionately with that index. Ratings of Permitted Investments shall be determined at the time of purchase of such Permitted Investments and without regard to ratings subcategories, and the Fiscal Agent shall have no responsibility to monitor the ratings of Permitted Investments after the initial purchase of such Permitted Investments. “Person” shall mean any individual, corporation, limited liability company, partnership, joint venture, estate, trust, unincorporated association, any federal, state, county or municipal government or any bureau, department or agency thereof and any fiduciary acting in such capacity on behalf of any of the foregoing. “Pledged Revenues” shall mean the amounts pledged under this Funding Loan Agreement to the payment of the principal of, prepayment premium, if any, and interest on the Funding Loan and the Governmental Lender Note, consisting of the following: (i) all income, revenues, proceeds and other amounts to which the Governmental Lender is entitled (other than amounts received by the Governmental Lender with respect to the Unassigned Rights) derived from or in connection with the Project and the Funding Loan Documents, including all Borrower Loan Payments due under the Borrower Loan Agreement and the Permanent Phase Borrower Note, payments with respect to the all Permanent Phase Borrower Loan Payments and all amounts obtained through the exercise of the remedies provided in the Funding Loan Documents and all receipts credited under the provisions of this Funding Loan Agreement against said amounts payable, and (ii) moneys held in the funds and accounts established under this Funding Loan Agreement, together with investment earnings thereon (except any amounts on deposit in the Administration Fund and Rebate Fund). “Prepayment Premium” shall mean (i) any premium payable by the Borrower pursuant to the Borrower Loan Documents in connection with a prepayment of the Permanent Phase Borrower Note (including any Prepayment Premium as set forth in the Permanent Phase Borrower Note) and (ii) any premium payable on the Governmental Lender Note pursuant to this Funding Loan Agreement. “Project” shall have the meaning given to that term in the Borrower Loan Agreement. “Rating Agency” shall mean any one and each of S&P and Moody’s then rating the Permitted Investments or any other nationally recognized statistical rating agency then rating the Permitted Investments, which has been approved by the Funding Lender. “Rebate Fund” shall mean the fund by that name created and established under this Funding Loan Agreement. “Record Date” shall mean the last day of each calendar month. “Regulations” shall mean with respect to the Code, the relevant U.S. Treasury regulations and proposed regulations thereunder or any relevant successor provision to such regulations and proposed regulations. 10 4856-5616-9347.5 “Regulatory Agreement” shall mean that certain Land Use Restriction Agreement, dated as of the date hereof, by and among the Governmental Lender, the Borrower and the Fiscal Agent, as hereafter amended or modified. “Required Transferee Representations” shall mean the representations in substantially the form attached to this Funding Loan Agreement as Exhibit A. “Resolution” shall mean the resolution of the Governmental Lender authorizing the Funding Loan, as evidenced by the Governmental Lender Note and the execution and delivery of the Funding Loan Documents to which the Governmental Lender is a party. “Responsible Officer” shall mean any officer within the Corporate Trust Department (or any successor group) of the Fiscal Agent, including any vice president, assistant vice president, assistant secretary or any other officer or assistant officer of the Fiscal Agent customarily performing functions similar to those performed by the persons who at the time shall be such officers, respectively, who is responsible for the administration of this Funding Loan Agreement. “Securities Act” shall mean the Securities Act of 1933, as amended. “Security” shall mean the security for the performance by the Governmental Lender of its obligations under the Governmental Lender Note and this Funding Loan Agreement as more fully set forth in Article IV hereof. “Security Instrument” shall mean the Amended and Restated Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of the date hereof (as amended, restated and/or supplemented from time to time), made by the Borrower in favor of the Governmental Lender and assigned to the Funding Lender to secure the performance by the Governmental Lender of its obligations with respect to the Funding Loan, as evidenced by the Governmental Lender Note. “Servicer” shall mean any Servicer appointed by the Funding Lender to perform certain servicing functions with respect to the Funding Loan and on the Permanent Phase Borrower Loan pursuant to a separate servicing agreement to be entered into between the Funding Lender and the Servicer. Initially the Servicer shall be the Funding Lender pursuant to this Funding Loan Agreement. “Servicing Agreement” shall mean any servicing agreement entered into between the Funding Lender and a Servicer with respect to the servicing of the Funding Loan and/or the Permanent Phase Borrower Loan. “S&P” shall mean S&P Global Ratings, a division of S&P Global Inc., and its successors. “State” shall mean the State of Florida. “Tax Certificate” shall mean the Tax Certificate and Agreement executed by the Governmental Lender and the Borrower including all exhibits and other attachments thereto as may be amended from time to time. “Tax Counsel” shall mean, collectively, Foley & Lardner, LLP, or any other attorney or firm of attorneys designated by the Governmental Lender and approved by the Funding Lender having a national reputation for skill in connection with the authorization and issuance of municipal obligations under Sections 103 and 141 through 150 (or any successor provisions) of the Code. 11 4856-5616-9347.5 “Tax Counsel No Adverse Effect Opinion” shall mean an opinion of Tax Counsel to the effect that the taking of the action specified therein will not, in and of itself, impair the exclusion of interest on the Governmental Lender Note from gross income for purposes of federal income taxation (subject to the inclusion of such customary exceptions as are acceptable to the recipient thereof). “Unassigned Rights” shall mean the Governmental Lender’s rights to reimbursement and payment of its fees, costs and expenses and the Rebate Amount under Section 2.5 of the Borrower Loan Agreement, its rights of access under Section 5.18 thereof, its rights to indemnification under Section 5.16 thereof and under any of the other Funding Loan Documents, if such right exists, its rights to attorneys’ fees under Sections 5.12 and 5.15 thereof, its rights to receive notices, reports and other statements and its rights to consent to certain matters, as provided in this Funding Loan Agreement, the Borrower Loan Agreement and under any of the other Funding Loan Documents, if such right exists. “Written Certificate,” “Written Certification,” “Written Consent,” “Written Direction,” “Written Notice,” “Written Order,” “Written Registration,” “Written Request,” and “Written Requisition” shall mean a written certificate, direction, notice, order or requisition signed by an Authorized Borrower Representative, an Authorized Governmental Lender Representative, a Responsible Officer of the Fiscal Agent or an authorized representative of the Funding Lender and delivered to the Funding Lender, the Servicer, the Governmental Lender Servicer, the Fiscal Agent or such other Person as required under the Funding Loan Documents. “Yield” shall mean yield as defined in Section 148(h) of the Code and any regulations promulgated thereunder. Section 1.2. Effect of Headings and Table of Contents. The Article and Section headings herein and in the Table of Contents are for convenience only and shall not affect the construction hereof. Section 1.3. Date of Funding Loan Agreement. The date of this Funding Loan Agreement is intended as and for a date for the convenient identification of this Funding Loan Agreement and is not intended to indicate that this Funding Loan Agreement was executed and delivered on said date. Section 1.4. Designation of Time for Performance. Except as otherwise expressly provided herein, any reference in this Funding Loan Agreement to the time of day shall mean the time of day in the city where the Funding Lender maintains its place of business for the performance of its obligations under this Funding Loan Agreement. Section 1.5. Interpretation. The parties hereto acknowledge that each of them and their respective counsel have participated in the drafting and revision of this Funding Loan Agreement. Accordingly, the parties agree that any rule of construction that disfavors the drafting party shall not apply in the interpretation of this Funding Loan Agreement or any amendment or supplement or exhibit hereto. ARTICLE II TERMS; GOVERNMENTAL LENDER NOTE Section 2.1. Terms. (a) Principal Amount. The maximum aggregate principal amount of the Funding Loan and the Governmental Lender Note evidencing such Funding Loan is $______________. 12 4856-5616-9347.5 (b) Maturity. The Funding Loan shall mature on the Maturity Date at which time the entire principal amount, to the extent not previously paid, and all accrued and unpaid interest, shall be due and payable. (c) Principal. The outstanding principal amount of the Governmental Lender Note and of the Funding Loan as of any given date shall be the principal amount outstanding on the Conversion Date, less any payments of principal of the Governmental Lender Note received from payments of corresponding principal amounts under the Borrower Note, including regularly scheduled principal payments and voluntary and mandatory prepayments. The principal amount of the Governmental Lender Note and interest thereon shall be payable on the basis specified in paragraphs (d), (e) and (f) of this Section 2.1. The Fiscal Agent shall keep a record of all principal repayments made under the Governmental Lender Note and shall upon written request provide the Governmental Lender and the Funding Lender with a statement of the outstanding principal balance of the Governmental Lender Note and the Funding Loan. (d) Interest. Interest shall be paid on the outstanding principal amount of the Governmental Lender Note at the rate or rates set forth in the Permanent Phase Borrower Note and otherwise as set forth in the Borrower Loan Agreement. (e) Corresponding Payments. The payment or prepayment of principal, interest and premium, if any, due on the Governmental Lender Note shall be identical with and shall be made on the same dates, terms and conditions, as the principal, interest, premiums, late payment fees and other amounts due on the Permanent Phase Borrower Note. Any payment or prepayment made by the Borrower of principal, interest, premium, if any, due on the Permanent Phase Borrower Note shall be deemed to be like payments or prepayments of principal, interest and premium, if any, due on the Funding Loan and the Governmental Lender Note. (f) Usury. The Governmental Lender intends to conform strictly to the usury laws applicable to this Funding Loan Agreement and the Governmental Lender Note and all agreements made in the Governmental Lender Note, this Funding Loan Agreement and the Funding Loan Documents are expressly limited so that in no event whatsoever shall the amount paid or agreed to be paid as interest or the amounts paid for the use of money advanced or to be advanced hereunder exceed the highest lawful rate prescribed under any law which a court of competent jurisdiction may deem applicable hereto. If, from any circumstances whatsoever, the fulfillment of any provision of the Governmental Lender Note, this Funding Loan Agreement or the other Funding Loan Documents shall involve the payment of interest in excess of the limit prescribed by any law which a court of competent jurisdiction may deem applicable hereto, then the obligation to pay interest hereunder shall be reduced to the maximum limit prescribed by law. If from any circumstances whatsoever, the Funding Lender shall ever receive anything of value deemed interest, the amount of which would exceed the highest lawful rate, such amount as would be excessive interest shall be deemed to have been applied, as of the date of receipt by the Funding Lender, to the reduction of the principal remaining unpaid hereunder and not to the payment of interest, or if such excessive interest exceeds the unpaid principal balance, such excess shall be refunded to the Borrower. This paragraph shall control every other provision of the Governmental Lender Note, this Funding Loan Agreement and all other Funding Loan Documents. In determining whether the amount of interest charged and paid might otherwise exceed the limit prescribed by law, the parties hereto intend and agree that (i) interest shall be computed upon the assumption that payments under the Borrower Loan Agreement and other Funding Loan Documents will be paid according to the agreed terms, and (ii) any sums of money that are taken into account in the calculation of interest, even though paid at one time, shall be spread over the actual term of the Funding Loan. 13 4856-5616-9347.5 Section 2.2. Form of Governmental Lender Note. As evidence of its obligation to repay the Funding Loan, the Governmental Lender has executed and delivered the Governmental Lender Note. Section 2.3. Execution and Delivery of Governmental Lender Note. The Governmental Lender Note shall each be executed on behalf of the Governmental Lender by the manual or facsimile signature of an Authorized Governmental Lender Representative and attested by the manual or facsimile signature of an Authorized Attesting Officer. Any facsimile signatures shall have the same force and effect as if said officers had manually signed the Governmental Lender Note. In case any officer of the Governmental Lender whose manual or facsimile signature shall appear on a Governmental Lender Note shall cease to be such officer before the delivery thereof, such signature or such facsimile shall nevertheless be valid and sufficient for all purposes, the same as if he had remained in office until delivery, and also a Governmental Lender Note may bear the facsimile signatures of, or may be signed by, such persons as at the actual time of the execution thereof shall be the proper officers to sign such Governmental Lender Note although at the date of the Governmental Lender Note such persons may not have been such officers. Section 2.4. Authentication. The Fiscal Agent has authenticated the Governmental Lender Note by execution of the certificate of authentication on or attached to the Governmental Lender Note, and the certificate of authentication so executed on or attached to the Governmental Lender Note shall be conclusive evidence that the Governmental Lender Note has been authenticated and delivered under this Funding Loan Agreement. Section 2.5. Registration and Transfer of Governmental Lender Note. (a) The Fiscal Agent acknowledges that the Funding Lender is the holder of the Governmental Lender Note as of the Conversion Date and shall remain the sole holder of the Governmental Lender Note except as otherwise provided herein. (b) The Fiscal Agent, on behalf of the Governmental Lender, shall provide for the registration of the Governmental Lender Note or interests therein and the registration of transfers thereof. In that regard, the Fiscal Agent shall maintain a register which shall contain a record of the Governmental Lender Note at any time authenticated hereunder, together with the name and address of the holder thereof, the date of authentication, the date of transfer or payment, and such other matters as may be deemed appropriate by the Fiscal Agent or the Governmental Lender. The Governmental Lender, the Fiscal Agent and any agent of the Governmental Lender or the Fiscal Agent shall treat the person in whose name the Governmental Lender Note is registered as of the Record Date as the owner of the Governmental Lender Note for the purpose of receiving payment of the Governmental Lender Note and for all other purposes whatsoever whether or not the Governmental Lender Note payments are overdue, and, to the extent permitted by law, neither the Governmental Lender, the Fiscal Agent nor any such agent shall be affected by notice to the contrary. (c) The transfer of the Governmental Lender Note is subject to registration by the holder thereof only upon compliance with the conditions for registration of transfer imposed on the holder under this Section 2.5 and under Section 2.6 hereof. Upon surrender of any Governmental Lender Note at the principal corporate trust office of the Fiscal Agent, the Governmental Lender shall execute (if necessary), and the Fiscal Agent shall authenticate and deliver, in the name of the designated transferee (but not registered in blank or to “bearer” or a similar designation), a new Governmental Lender Note of a like principal amount, and having the same stated maturity, tenor and interest rate, substantially in the form set forth in Exhibit A hereto. (d) Any Governmental Lender Note delivered in exchange for or upon transfer of a Governmental Lender Note shall be a valid limited obligation of the Governmental Lender evidencing the 14 4856-5616-9347.5 same debt and entitled to the same benefits under this Funding Loan Agreement, as the Governmental Lender Note surrendered for such exchange or transfer. (e) Registration of the transfer of the Governmental Lender Note may be made on the Fiscal Agent’s register by the holder thereof by such holder’s attorney duly authorized in writing; provided, that the Governmental Lender Note presented or surrendered for registration of transfer or exchange (i) is accompanied by evidence of compliance with the provisions of Section 2.6 hereof, (ii) is duly endorsed or be accompanied by a written instrument or instruments of transfer, in a form satisfactory to the Governmental Lender and the Fiscal Agent, duly executed by the holder thereof or his, her or its attorney duly authorized in writing and (iii) includes written instructions as to the details of the transfer of the Governmental Lender Note. (f) No service charge shall be made to the registered holder of the Governmental Lender Note for any registration, transfer or exchange, but the Fiscal Agent and the Governmental Lender may require payment of a sum sufficient to cover any tax, fee or other governmental charge that may be imposed in connection with any transfer or exchange of the Governmental Lender Note, and any legal or unusual costs of transfers. Such sums shall be paid in every instance by the purchaser or assignee of the Funding Loan or portion thereof. (g) The Governmental Lender Note shall not be transferred through the services of the Depository Trust Company or any other third-party registrar. (h) The transferor shall also provide or cause to be provided to the Fiscal Agent all information necessary to allow the Fiscal Agent to comply with any applicable tax reporting obligations, including without limitation any cost basis reporting obligations under Internal Revenue Code Section 6045. The Fiscal Agent may rely on the information provided to it and shall have no responsibility to verify or ensure the accuracy of such information. Section 2.6. Restrictions on Transfer. (a) The Funding Lender shall deliver to the Governmental Lender the Required Transferee Representations in substantially the form attached hereto as Exhibit A on the Delivery Date. (b) The Funding Lender shall have the right to sell (i) the Governmental Lender Note and the Funding Loan in whole or (ii) a participation interest or other beneficial ownership interest in the Governmental Lender Note and the Funding Loan to the extent permitted by Section 2.6(c) below, provided that such sale shall be only to Approved Transferees that execute and deliver the Required Transferee Representations to the Funding Lender, with a copy to the Governmental Lender and the Fiscal Agent; provided, however, that no Required Transferee Representations shall be required to be delivered by transferees or beneficial interest holders described in clauses (3) or (4) of the definition of “Approved Transferee.” (c) Notwithstanding the other provisions of this Section 2.6, no beneficial ownership interest in the Governmental Lender Note and Funding Loan shall be sold in an amount that is less than the Minimum Beneficial Ownership Amount; provided, however, that beneficial ownership interests in the Governmental Lender Note and Funding Loan described in clause (3) of the definition of “Approved Transferee” may be sold in any amount equal to or greater than $100,000. (d) The parties agree that no rating shall be sought from a rating agency with respect to the Funding Loan or the Governmental Lender Note. 15 4856-5616-9347.5 The Fiscal Agent shall be entitled to rely, without any further inquiry, on any Required Transferee Representations delivered to it and shall be fully protected in registering any transfer or exchange of the Governmental Lender Note in reliance on any such Required Transferee Representations which appear on their face to be correct and of which the Fiscal Agent has no actual knowledge otherwise. Any such holder desiring to effect such transfer shall agree to indemnify the Governmental Lender and the Fiscal Agent from and against any and all liability, cost or expense (including attorneys’ fees) that may result if the transfer is not exempt from registration under the Securities Act or is not made in accordance with such federal and state laws. Notwithstanding anything to the contrary herein, the holder shall not transfer or sell the Governmental Lender Note or any interest therein to a party related to or affiliated with the Borrower, any general partner, limited partner or member of the Borrower without the prior written consent of the Governmental Lender. ARTICLE III PREPAYMENT Section 3.1. Prepayment of the Governmental Lender Note from Prepayments Under the Permanent Phase Borrower Note. The Governmental Lender Note is subject to voluntary and mandatory prepayment as follows: (a) The Governmental Lender Note shall be subject to voluntary prepayment to the extent and in the manner and on any date that the Permanent Phase Borrower Note is subject to voluntary prepayment as set forth therein, at a prepayment price equal to the principal balance of the Permanent Phase Borrower Note to be prepaid, plus interest thereon to the date of prepayment and the amount of any Prepayment Premium payable under the Permanent Phase Borrower Note, plus any Additional Borrower Payments due and payable under the Borrower Loan Agreement through the date of prepayment. The Borrower shall not have the right to voluntarily prepay all or any portion of the Permanent Phase Borrower Note, thereby causing the Governmental Lender Note to be prepaid, except as specifically permitted in the Permanent Phase Borrower Note, without the prior written consent of Funding Lender, which may be withheld in Funding Lender’s sole and absolute discretion. (b) The Governmental Lender Note shall be subject to mandatory prepayment in whole or in part upon prepayment of the Permanent Phase Borrower Note at the direction of the Funding Lender in accordance with the terms of the Permanent Phase Borrower Note at a prepayment price equal to the outstanding principal balance of the Permanent Phase Borrower Note prepaid, plus accrued interest plus any other amounts payable under the Permanent Phase Borrower Note or the Borrower Loan Agreement. Section 3.2. Notice of Prepayment. Notice of prepayment of the Governmental Lender Note shall be deemed given to the extent that notice of prepayment of the Permanent Phase Borrower Note is timely and properly given to Funding Lender and Fiscal Agent in accordance with the terms of the Permanent Phase Borrower Note and the Borrower Loan Agreement, and no separate notice of prepayment of the Governmental Lender Note is required to be given. ARTICLE IV SECURITY Section 4.1. Security for the Funding Loan. To secure the payment of the Funding Loan and the Governmental Lender Note, to declare the terms and conditions on which the Funding Loan and the Governmental Lender Note is secured, and in consideration of the premises and of the funding of the Funding Loan by the Funding Lender, the Governmental Lender by these presents does grant, bargain, sell, remise, release, convey, assign, transfer, mortgage, hypothecate, pledge, set over and confirm to the 16 4856-5616-9347.5 Funding Lender for the benefit of the holder from time to time of the Governmental Lender Note or any interests therein, a lien on and security interest in the following described property (excepting, however, the Unassigned Rights) (said property, rights and privileges being herein collectively called, the “Security”): (a) All right, title and interest of the Governmental Lender in, to and under the Borrower Loan Agreement and the Permanent Phase Borrower Note, including, without limitation, all rents, revenues and receipts derived thereunder by the Governmental Lender from the Borrower relating to the Project and including, without limitation, all Pledged Revenues, Borrower Loan Payments and Additional Borrower Payments (except those related to the Unassigned Rights) derived by the Governmental Lender under and pursuant to, and subject to the provisions of, the Borrower Loan Agreement; provided that the pledge and assignment made under this Funding Loan Agreement shall not impair or diminish the obligations of the Governmental Lender under the provisions of the Borrower Loan Agreement; (b) All right, title and interest of the Governmental Lender in, to and under, together with all rights, remedies, privileges and options pertaining to, the Funding Loan Documents, and all other payments, revenues and receipts derived by the Governmental Lender under and pursuant to, and subject to the provisions of, the Funding Loan Documents; (c) Any and all moneys and investments from time to time on deposit in, or forming a part of, all funds and accounts created and held under this Funding Loan Agreement (other than the Administration Fund and the Rebate Fund), subject to the provisions of this Funding Loan Agreement permitting the application thereof for the purposes and on the terms and conditions set forth herein; and (d) Any and all other real or personal property of every kind and nature or description, which may from time to time hereafter, by delivery or by writing of any kind, be subjected to the lien of this Funding Loan Agreement as additional security by the Governmental Lender or anyone on its part or with its consent, or which pursuant to any of the provisions hereof or of the Borrower Loan Agreement may come into the possession or control of the Fiscal Agent or the Funding Lender or a receiver appointed pursuant to this Funding Loan Agreement; and the Fiscal Agent or the Funding Lender is hereby authorized to receive any and all such property as and for additional security for the Funding Loan and the Governmental Lender Note and to hold and apply all such property subject to the terms hereof. The pledge and assignment of and the security interest granted in the Security pursuant to this Section 4.1 for the payment of the principal of, premium, if any, and interest on the Governmental Lender Note, in accordance with its terms and provisions, and for the payment of all other amounts due hereunder, shall attach and be valid and binding from and after the time of the delivery of the Governmental Lender Note by the Governmental Lender. The Security so pledged and then or thereafter received by the Fiscal Agent or the Funding Lender shall immediately be subject to the lien of such pledge and security interest without any physical delivery or recording thereof or further act, and the lien of such pledge and security interest shall be valid and binding and prior to the claims of any and all parties having claims of any kind in tort, contract or otherwise against the Governmental Lender irrespective of whether such parties have notice thereof. Section 4.2. Delivery of Security. In order to secure payment of the Funding Loan and the Governmental Lender Note, the Governmental Lender has pledged and assigned its right, title and interest in the Security to the Funding Lender. In connection with such pledge, assignment, transfer and conveyance, the Governmental Lender shall deliver to the Funding Lender the following documents or instruments promptly following their execution and, to the extent applicable, their recording or filing: 17 4856-5616-9347.5 (a) The Permanent Phase Borrower Note endorsed without recourse to the Funding Lender by the Governmental Lender; (b) The originally executed Borrower Loan Agreement and Regulatory Agreement; (c) The originally executed Security Instrument and all other Borrower Loan Documents existing at the time of delivery of the Permanent Phase Borrower Note and an assignment for security of the Security Instrument from the Governmental Lender to the Funding Lender, in recordable form; (d) Uniform Commercial Code financing statements or other chattel security documents giving notice of the Funding Lender’s status as an assignee of the Governmental Lender’s security interest in any personal property forming part of the Project, in form suitable for filing; and (e) Uniform Commercial Code financing statements giving notice of the pledge by the Governmental Lender of the Security pledged under this Funding Loan Agreement. The Governmental Lender shall, at the expense of the Borrower, deliver and deposit with the Fiscal Agent or the Funding Lender such additional documents, financing statements, and instruments as the Funding Lender may reasonably require and direct from time to time for the better perfecting and assuring to the Funding Lender of its lien and security interest in and to the Security. ARTICLE V LIMITED LIABILITY Section 5.1. Source of Payment of Funding Loan, the Governmental Lender Note and Other Obligations. The Governmental Lender Note evidencing the Funding Loan is a revenue obligation of the Governmental Lender, payable solely from the Pledged Revenues and other funds and moneys and Security pledged and assigned hereunder. None of the Governmental Lender, the State, or any political subdivision thereof nor any public agency shall in any event be liable for the payment of the principal of, premium (if any) or interest on the Governmental Lender Note and the Funding Loan or for the performance of any pledge, obligation or agreement of any kind whatsoever with respect thereto except as set forth herein, and none of the Funding Loan or the Governmental Lender Note or any of the Governmental Lender’s agreements or obligations shall be construed to constitute an indebtedness of or a pledge of the faith and credit of or a loan of the credit of or a moral obligation of any of the foregoing within the meaning of any constitutional or statutory provision whatsoever. Neither the faith, revenues, credit nor taxing power of the Governmental Lender, the State or any other political corporation or subdivision or agency thereof shall be pledged to the payment of the principal of, premium (if any), or interest on the Governmental Lender Note or this Funding Loan Agreement. Section 5.2. Exempt from Individual Liability. No recourse under or upon any obligation, covenant, warranty or agreement contained in this Funding Loan Agreement or in the Governmental Lender Note, or under any judgment obtained against the Governmental Lender, or the enforcement of any assessment, or any legal or equitable proceedings by virtue of any constitution or statute or otherwise, or under any circumstances under or independent of this Funding Loan Agreement, shall be had against any of the members, officers, agents or employees of the Governmental Lender (past, present or future), either directly or through the Governmental Lender or otherwise, for the payment for or to the Governmental Lender or any receiver of the Governmental Lender, or for or to the owner of the Governmental Lender Note, or otherwise, of any sum that may be due and unpaid by the Governmental Lender upon the Governmental Lender Note. Any and all personal liability of every nature whether at common law or in equity or by statute or by constitution or otherwise of any such member, officer, agent or employee, as such, by reason of any act of omission on his or her part or otherwise, for the payment for or to the owner of a 18 4856-5616-9347.5 Governmental Lender Note or otherwise of any sum that may remain due and unpaid upon a Governmental Lender Note secured by this Funding Loan Agreement or any of them is, by the acceptance of the Governmental Lender Note, expressly waived and released as a condition of and in consideration for the execution of this Funding Loan Agreement and the delivery of the Governmental Lender Note. Anything in this Funding Loan Agreement to the contrary notwithstanding, it is expressly understood by the parties to this Funding Loan Agreement that (a) the Governmental Lender may rely exclusively on the truth and accuracy of any certificate, opinion, notice or other instrument furnished to the Governmental Lender by the Fiscal Agent, the Servicer, the Borrower or the owner of the Governmental Lender Note as to the existence of any fact or state of affairs, (b) the Governmental Lender shall not be under any obligation under this Funding Loan Agreement to perform any record keeping or to provide any legal services, it being understood that such services shall be performed or caused to be performed by the Fiscal Agent or by the Servicer and its respective counsel, as applicable, and (c) none of the provisions of this Funding Loan Agreement shall require the Governmental Lender to expend or risk its own funds or otherwise to incur financial liability in the performance of any of its duties or in the exercise of any of its rights or powers under this Funding Loan Agreement, unless it shall first have been adequately indemnified to its satisfaction against any costs, expenses and liability which it may incur as a result of taking such action. No recourse for the payment of any part of the principal of, premium, if any, or interest on the Governmental Lender Note or for the satisfaction of any liability arising from, founded upon or existing by reason of the initial delivery, purchase or ownership of a Governmental Lender Note shall be had against any officer, member, agent or employee of the Governmental Lender, as such, all such liability being expressly released and waived as a condition of and as a part of the consideration for the execution of this Funding Loan Agreement and the delivery of the Governmental Lender Note. No covenant, stipulation, obligation or agreement of the Governmental Lender contained in this Funding Loan Agreement shall be deemed to be a covenant, stipulation, obligation or agreement of any present or future member, officer, agent or employee of the Governmental Lender in other than that person’s official capacity. No member, officer, agent or employee of the Governmental Lender shall be individually or personally liable for the payment of the principal or redemption price of or interest on the Governmental Lender Note or be subject to any personal liability or accountability by reason of the delivery of the Governmental Lender Note. It is recognized that notwithstanding any other provision of this Funding Loan Agreement, neither the Borrower, the Fiscal Agent nor any owner of the Governmental Lender Note shall look to the Governmental Lender for damages suffered by the Borrower, the Fiscal Agent or such owner as a result of the failure of the Governmental Lender to perform any covenant, undertaking or obligation under this Funding Loan Agreement, the Borrower Loan Agreement, the Governmental Lender Note or any of the other documents referred to herein, or as a result of the incorrectness of any representation made by the Governmental Lender in any of such documents, or for any other reason. Although this Funding Loan Agreement recognizes that such documents shall not give rise to any pecuniary liability of the Governmental Lender, nothing contained in this Funding Loan Agreement shall be construed to preclude in any way any action or proceeding (other than that element of any action or proceeding involving a claim for monetary damages against the Governmental Lender) in any court or before any governmental body, agency or instrumentality or otherwise against the Governmental Lender or any of its officers or employees to enforce the provisions of any of such documents which the Governmental Lender is obligated to perform and the performance of which the Governmental Lender has not assigned to the Fiscal Agent or any other person. Section 5.3. Revenue Obligation. Notwithstanding any other provision of this Funding Loan Agreement to the contrary: THE GOVERNMENTAL LENDER NOTE IS ISSUED PURSUANT TO THE COUNTY AUTHORIZATION, THE RESOLUTION AND IN ACCORDANCE WITH THE ACT, AND ARE REVENUE OBLIGATIONS OF THE GOVERNMENTAL LENDER. NEITHER THE 19 4856-5616-9347.5 GOVERNMENTAL LENDER NOR ANY OFFICIAL OR EMPLOYEE OF THE GOVERNMENTAL LENDER NOR ANY PERSON EXECUTING A GOVERNMENTAL LENDER NOTE SHALL BE LIABLE PERSONALLY ON SUCH GOVERNMENTAL LENDER NOTE OR SUBJECT TO ANY PERSONAL LIABILITY OR ACCOUNTABILITY BY REASON OF ITS ISSUANCE. THE GOVERNMENTAL LENDER NOTE AND THE INTEREST THEREON ARE REVENUE OBLIGATIONS OF THE GOVERNMENTAL LENDER, PAYABLE ONLY FROM THE SOURCES DESCRIBED IN THIS FUNDING LOAN AGREEMENT. NEITHER THE GOVERNMENTAL LENDER, THE STATE NOR ANY OTHER POLITICAL CORPORATION OR SUBDIVISION OR AGENCY THEREOF SHALL BE OBLIGATED TO PAY THE PRINCIPAL OF THE GOVERNMENTAL LENDER NOTE OR THE INTEREST THEREON OR OTHER COSTS INCIDENT THERETO EXCEPT FROM THE MONEY PLEDGED THEREFOR. NEITHER THE FAITH AND CREDIT NOR THE TAXING POWER OF THE STATE NOR ANY POLITICAL CORPORATION OR SUBDIVISION OR AGENCY THEREOF NOR THE FAITH AND CREDIT OF THE GOVERNMENTAL LENDER IS PLEDGED TO THE PAYMENT OF THE PRINCIPAL OF, PREMIUM, IF ANY, OR INTEREST ON THE GOVERNMENTAL LENDER NOTE OR OTHER COSTS INCIDENT THERETO. THE GOVERNMENTAL LENDER NOTE IS NOT A DEBT OF THE UNITED STATES OF AMERICA. ARTICLE VI RESERVED ARTICLE VII FUNDS AND ACCOUNTS Section 7.1. Authorization to Create Funds and Accounts. Except as provided in Section 7.3 hereof, no funds or accounts shall be established in connection with the Funding Loan. The Fiscal Agent is authorized to establish and create from time to time such other funds and accounts or subaccounts as directed by the Funding Lender or, if there is a Servicer, by the Servicer, as may be necessary for the deposit of moneys (including, without limitation, insurance proceeds and/or condemnation awards), if any, received by the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer pursuant to the terms hereof or any of the other Funding Loan Documents and not immediately transferred or disbursed pursuant to the terms of the Funding Loan Documents and/or the Borrower Loan Documents. Section 7.2. Investment of Funds. Amounts held in any funds or accounts created by the Fiscal Agent under this Funding Loan Agreement shall be invested in Permitted Investments at the written direction of the Borrower, subject in all cases to the restrictions of Section 8.7 hereof and of the Tax Certificate. The Fiscal Agent may make any and all such investments through its own investment department or that of its affiliates or subsidiaries, and may charge its ordinary and customary fees for such trades, including account maintenance fees. The Fiscal Agent may conclusively rely upon the Borrower’s written instructions as to both the suitability and legality of any directed investments. In the absence of written direction from the Borrower, the Fiscal Agent shall hold such amounts on deposit in the funds and accounts established under this Funding Loan Agreement uninvested. The Fiscal Agent shall have no liability in respect of losses incurred as a result of the liquidation of any investment prior to its stated maturity or the failure of the Borrower to provide timely written investment direction. Although the Governmental Lender and the Borrower each recognizes that it may obtain a broker confirmation or written statement containing comparable information at no additional cost, the Governmental Lender and the Borrower hereby agree that confirmations of Permitted Investments are not required to be issued by the Fiscal Agent for each month in which a monthly statement is rendered. No 20 4856-5616-9347.5 statement need be rendered for any fund or account if no activity occurred in such fund or account during such month. Section 7.3. Establishment of Funds and Accounts. In connection with the Funding Loan, there were established with the Fiscal Agent the following funds and accounts: (a) Project Fund; (b) Revenue Fund; (c) Loan Payment Fund; (d) Administration Fund (and therein a Governmental Lender Conversion Fee Account); (e) Cost of Issuance Fund; and (f) Rebate Fund. Upon Conversion, the Project Fund, the accounts therein, the Governmental Lender Conversion Fee Account and the Cost of Issuance Fund are closed. All money required to be deposited with or paid to the Fiscal Agent for the account of any of the funds or accounts created by this Funding Loan Agreement shall be held by the Fiscal Agent for the benefit of the Funding Lender, and except for money held in the Administration Fund and Rebate Fund, shall, while held by the Fiscal Agent, constitute part of the Pledged Revenues and be subject to the lien hereof. The Fiscal Agent shall provide Written Notice of any change to its wiring instructions to the Funding Lender and the Borrower no less than five (5) Business Days prior to the next payment date for which such revised instructions will be applicable. Section 7.4. Loan Payment Fund. The Governmental Lender and the Borrower shall have no interest in the Loan Payment Fund or the moneys therein, which shall always be maintained by the Fiscal Agent completely separate and segregated from all other moneys held hereunder and from any other moneys of the Governmental Lender and the Borrower. The Fiscal Agent shall deposit into the Loan Payment Fund any amounts received from the Borrower as payments of principal of, premium, if any, or interest on the Permanent Phase Borrower Loan and any other amounts received by the Fiscal Agent that are subject to the lien and pledge of this Funding Loan Agreement, including any Pledged Revenues not required to be deposited to the Administration Fund or Rebate Fund or not otherwise specifically directed in writing to be deposited into other funds created by this Funding Loan Agreement. The Fiscal Agent shall apply all amounts on deposit in the Loan Payment Fund in the following order of priority: First, to pay or provide for the payment of the interest then due on the Governmental Lender Note; Second, to pay or provide for the payment and premium, if any, or the prepayment of principal on the Governmental Lender Note, provided moneys have been transferred or deposited into the Loan Payment Fund for such purpose; and Third, to pay or provide for the payment of the Governmental Lender Note on the Maturity Date. 21 4856-5616-9347.5 If the Fiscal Agent has not received, by 2:00 p.m. Eastern time on the date interest is due on the Governmental Lender Note, an amount sufficient to pay such interest, the Fiscal Agent shall provide immediate telephonic or electronic notice to the Funding Lender of such deficiency. The Fiscal Agent may rely on the payment terms of the Governmental Lender Note for purposes of payments described above. Section 7.5. Administration Fund. The Fiscal Agent shall deposit in the Administration Fund the amounts required by the Borrower Loan Agreement to be paid by the Borrower to the Governmental Lender or the Fiscal Agent, as provided in this Section 7.5. Amounts on deposit in the Administration Fund shall be used to pay the fees and expenses of the Governmental Lender and the Fiscal Agent, as and when the same become due. In that regard, moneys in the Administration Fund shall be withdrawn or maintained, as appropriate, by the Fiscal Agent to pay (a) the Governmental Lender Fee when due and payable, (b) on each December 1 and June 1 to the Fiscal Agent amounts due pursuant to subparts (i) and (ii) of the definition of “Fiscal Agent’s Fees” herein, (c) upon receipt, to the Fiscal Agent, any amounts due to the Fiscal Agent which have not been paid, other than amounts paid in accordance with clause (b) above, and (d) upon receipt, to, or at the direction of, the Governmental Lender, any amounts owing the Governmental Lender by the Borrower and then due and unpaid, other than amounts paid in accordance with clause (a) above. In the event that the amounts on deposit in the Administration Fund are not equal to the amounts payable from the Administration Fund as provided in the preceding paragraph on any date on which such amounts are due and payable, the Fiscal Agent shall give notice to the Borrower of such deficiency and of the amount of such deficiency and request payment within two Business Days to the Fiscal Agent of the amount of such deficiency. Written notice of any insufficiency, which results in the Governmental Lender not receiving the Governmental Lender Fee on the applicable due date, shall be provided by the Fiscal Agent to the Governmental Lender (with a copy to the Borrower and the Funding Lender) within 10 days of the respective due date. Upon payment by the Borrower to the Fiscal Agent of such deficiency, the amounts for which such deficiency was requested shall be paid by the Fiscal Agent. Notwithstanding anything herein to the contrary, the Fiscal Agent, on behalf of the Governmental Lender, shall prepare and submit a written invoice to the Borrower for payment of the Governmental Lender Fee not later than 10 days prior to the due date for payment of such Governmental Lender Fee, and shall remit moneys received from the Borrower to the Governmental Lender for payment of such fee. Failure of the Fiscal Agent to prepare or submit such notice shall not excuse the Borrower from making the required payments. Section 7.6. Project Fund. Proceeds of the Funding Loan provided by the Initial Funding Lender were deposited to the Note Proceeds Account of the Project Fund and disbursed in accordance with the Funding Loan Agreement to pay Qualified Project Costs and to pay other costs related to the Project as provided therein. Not less than 95% of the moneys deposited in and credited to the Note Proceeds Account of the Project Fund representing the proceeds of the Funding Loan, including Investment Income thereon, have been expended for Qualified Project Costs (the “95% Requirement”). The Project Fund is closed. Section 7.7. Rebate Fund. All amounts in the Rebate Fund shall be held, invested and disbursed by the Fiscal Agent in accordance with the provisions of the Tax Certificate, the terms of which are incorporated herein by reference and made a part hereof as if fully set forth herein. The Borrower shall have the absolute obligation to deposit funds into the Rebate Fund in accordance with the provisions of the Tax Certificate. The Fiscal Agent shall make rebate payments to the United States Treasury in accordance 22 4856-5616-9347.5 with the applicable provisions of the Tax Certificate. The Fiscal Agent shall conclusively be deemed to have complied with such provisions if it follows the written instructions of the Borrower or the Rebate Analyst and shall not be required to take any actions under the Tax Certificate on behalf of the Borrower in the absence of written instructions from the Borrower and the Rebate Analyst. Section 7.8. Amounts Remaining in Funds. After full payment of the Funding Loan and full payment of the fees, charges and expenses of the Fiscal Agent, the Governmental Lender, the Rebate Analyst, the Funding Lender and the Servicer and other amounts required to be paid hereunder or under any Borrower Loan Document (as certified in writing to the Fiscal Agent by the Governmental Lender with respect to amounts due to the Governmental Lender and by the Rebate Analyst with respect to amounts due to the Rebate Analyst), any amounts remaining in any fund or account hereunder other than the Rebate Fund shall be paid to the Borrower.. ARTICLE VIII REPRESENTATIONS AND COVENANTS Section 8.1. General Representations. The Governmental Lender makes the following representations as the basis for the undertakings on its part herein contained: (g) The Governmental Lender is a public body corporate and politic under the Act, has the power and authority to (i) enter into the Funding Loan Documents to which it is a party and the transactions contemplated thereby, (ii) incur the indebtedness represented by the Governmental Lender Note and the Funding Loan and apply the proceeds of such indebtedness to finance a portion of the costs of the Project and (iii) carry out its other obligations under this Funding Loan Agreement and the Governmental Lender Note, and by proper action has duly authorized the Governmental Lender’s execution and delivery of, and its performance under, such Funding Loan Documents and all other agreements and instruments relating thereto. (h) The Governmental Lender is not in default under or in violation of, and the execution and delivery of the Funding Loan Documents to which it is a party and its compliance with the terms and conditions thereof will not conflict with or constitute a default under or a violation of, (i) the Act or the County Authorization, (ii) to its knowledge, any other existing laws, rules, regulations, judgments, decrees and orders applicable to it, or (iii) to its knowledge, the provisions of any agreements and instruments to which the Governmental Lender is a party, a default under or violation of which would prevent it from entering into this Funding Loan Agreement, executing and delivering the Governmental Lender Note, financing the Project, executing and delivering the other Funding Loan Documents to which it is a party or consummating the transactions contemplated thereby, and, to its knowledge, no event has occurred and is continuing under the provisions of any such agreement or instrument or otherwise that with the lapse of time or the giving of notice, or both, would constitute such a default or violation (it being understood, however, that the Governmental Lender is making no representations as to the necessity of registering the Permanent Phase Borrower Note pursuant to any securities laws or complying with any other requirements of securities laws). (i) No litigation, inquiry or investigation of any kind in or by any judicial or administrative court or agency is pending or, to the knowledge of the Governmental Lender, threatened against the Governmental Lender with respect to (i) the organization and existence of the Governmental Lender, (ii) its authority to execute or deliver the Funding Loan Documents to which it is a party, (iii) the validity or enforceability of any such Funding Loan Documents or the transactions contemplated thereby, (iv) the title of any officer of the Governmental Lender who executed such Funding Loan Documents or (v) any 23 4856-5616-9347.5 authority or proceedings relating to the execution and delivery of such Funding Loan Documents on behalf of the Governmental Lender, and no such authority or proceedings have been repealed, revoked, rescinded or amended but are in full force and effect. (j) The revenues and receipts to be derived from the Borrower Loan Agreement, the Permanent Phase Borrower Note and this Funding Loan Agreement have not been pledged previously by the Governmental Lender to secure any of its notes or bonds other than the Funding Loan as evidenced by the Governmental Lender Note. THE GOVERNMENTAL LENDER MAKES NO REPRESENTATION, COVENANT OR AGREEMENT AS TO THE FINANCIAL POSITION OR BUSINESS CONDITION OF THE BORROWER OR THE PROJECT AND DOES NOT REPRESENT OR WARRANT AS TO ANY STATEMENTS, MATERIALS, REPRESENTATIONS OR CERTIFICATIONS FURNISHED BY THE BORROWER IN CONNECTION WITH THE FUNDING LOAN OR AS TO THE CORRECTNESS, COMPLETENESS OR ACCURACY THEREOF. Section 8.2. No Encumbrance on Security. The Governmental Lender will not knowingly create or knowingly permit the creation of any mortgage, pledge, lien, charge or encumbrance of any kind on the Security or any part thereof prior to or on a parity with the lien of this Funding Loan Agreement, except as expressly permitted or contemplated by the Funding Loan Documents. Section 8.3. Repayment of Funding Loan. Solely from amounts pledged therefor, and subject to the provisions of Article V hereof, the Governmental Lender will duly and punctually repay, or cause to be repaid, the Funding Loan, as evidenced by the Governmental Lender Note, as and when the same shall become due, all in accordance with the terms of the Governmental Lender Note and this Funding Loan Agreement. Section 8.4. Servicer. The Funding Lender may appoint a Servicer to service and administer the Governmental Loan and/or the Permanent Phase Borrower Loan on behalf of the Funding Lender and the Fiscal Agent, including without limitation the fulfillment of rights and responsibilities granted by Governmental Lender to Funding Lender pursuant to Section 2.1 of the Borrower Loan Agreement. Section 8.5. Borrower Loan Agreement Performance. The Funding Lender, the Fiscal Agent and the Servicer, if any, on behalf of the Governmental Lender, may (but shall not be required or obligated to) perform and observe any such agreement or covenant of the Governmental Lender under the Borrower Loan Agreement, all to the end that the Governmental Lender’s rights under the Borrower Loan Agreement may be unimpaired and free from default. (b) The Governmental Lender will promptly notify the Borrower, the Fiscal Agent, the Servicer, if any, and the Funding Lender in writing of the occurrence of any Borrower Loan Agreement Default, provided that the Governmental Lender has received written notice or otherwise has knowledge of such event. Section 8.6. Maintenance of Records; Inspection of Records. The Fiscal Agent shall keep and maintain adequate records pertaining to any funds and accounts established hereunder, including all deposits to and disbursements from said funds and accounts and shall keep and maintain the registration books for the Governmental Lender Note and interests therein. The Fiscal Agent shall retain in its possession all certifications and other documents presented to it, all such records and all records of principal, interest and premium paid on the Governmental Lender Note, subject to the inspection of the Funding Lender and the Governmental Lender and their representatives at all reasonable times and upon reasonable prior notice. 24 4856-5616-9347.5 (d) The Governmental Lender and the Funding Lender will at any and all times, upon the reasonable request of the Servicer, if any, the Borrower, the Fiscal Agent, the Governmental Lender or the Funding Lender, afford and procure a reasonable opportunity by their respective representatives to inspect the books, records, reports and other papers of the Governmental Lender or the Funding Lender, as appropriate, relating to the Project and the Funding Loan, if any, and to make copies thereof. Section 8.7. Tax Covenants. The Governmental Lender covenants to and for the benefit of the Funding Lender that, notwithstanding any other provisions of this Funding Loan Agreement or of any other instrument, it will (subject to the limited liability provisions hereof): (a) Enforce or cause to be enforced all obligations of the Borrower under the Regulatory Agreement in accordance with its terms and seek to cause the Borrower to correct any violation of the Regulatory Agreement within a reasonable period after any such violation is first discovered; (b) Not take or cause to be taken any other action or actions, or fail to take any action or actions, which would cause the interest payable on the Governmental Lender Note to be includable in gross income for federal income tax purposes; (c) At all times do and perform all acts and things permitted by law and necessary or desirable in order to assure that interest paid by the Governmental Lender on the Governmental Lender Note will be excluded from the gross income of the holders of the Governmental Lender Note, for federal income tax purposes, pursuant to Section 103 of the Code, except in the event where any holder of the Governmental Lender Note or a portion thereof is a “substantial user” of the facilities financed with the Funding Loan or a “related person” within the meaning of Section 147(a) of the Code; (d) Not take any action or permit or suffer any action to be taken if the result of the same would be to cause the Governmental Lender Note to be “federally guaranteed” within the meaning of Section 149(b) of the Code and the Regulations; and (e) Require the Borrower to agree, pursuant to the terms and provisions of the Borrower Loan Agreement, not to commit any act and not to make any use of the proceeds of a Governmental Lender Note, or any other moneys which may be deemed to be proceeds of such Governmental Lender Note pursuant to the Code, which would cause such Governmental Lender Note to be an “arbitrage bond” within the meaning of Sections 103(b) and 148 the Code, and to comply with the requirements of the Code throughout the term of the Funding Loan; and (f) Require the Borrower to take all steps necessary to compute and pay or cause to be paid pursuant to the provisions of Section 7.7 hereof any rebatable arbitrage in accordance with Section 148(f) of the Code in accordance with the applicable provisions of the Tax Certificate. (g) In furtherance of the covenants in this Section 8.7, the Governmental Lender and the Borrower have executed, delivered and complied with the provisions of the Tax Certificate, which are by this reference incorporated into this Funding Loan Agreement and made a part of this Funding Loan Agreement as if set forth in this Funding Loan Agreement in full. For purposes of this Section 8.7 the Governmental Lender’s compliance shall be based solely on matters within the Governmental Lender’s control and no acts, omissions or directions of the Borrower, the Fiscal Agent, the Funding Lender or any other Persons shall be attributed to the Governmental Lender. In complying with the foregoing covenants, the Governmental Lender may rely from time to time on a Tax Counsel No Adverse Effect Opinion or other appropriate opinion of Tax Counsel. 25 4856-5616-9347.5 Section 8.8. Performance by the Borrower. Without relieving the Governmental Lender from the responsibility for performance and observance of the agreements and covenants required to be performed and observed by it hereunder, the Borrower, on behalf of the Governmental Lender, may perform any such agreement or covenant if no Borrower Loan Agreement Default or Potential Default under the Borrower Loan Agreement exists. Section 8.9. Maintenance of Records. The Funding Lender shall keep and maintain adequate records pertaining to funds and accounts relative to the Permanent Phase Borrower Loan not established with the Fiscal Agent, if any, including all deposits to and disbursements from said funds and accounts and will provide information and records relating thereto to the Fiscal Agent or the Governmental Lender upon request. ARTICLE IX DEFAULT; REMEDIES Section 9.1. Events of Default. Subject in all respects to Article V hereof, any one or more of the following shall constitute an event of default (an “Event of Default”) under this Funding Loan Agreement (whatever the reason for such event and whether it shall be voluntary or involuntary or be effected by operation of law or pursuant to any judgment, decree or order of any court or any order, rule or regulation of any administrative or governmental body): (a) A default in the payment of any interest upon the Governmental Lender Note when such interest becomes due and payable; or (b) A default in the payment of principal of, or premium on, the Governmental Lender Note when such principal or premium becomes due and payable, whether at its stated maturity, by declaration of acceleration or call for mandatory prepayment or otherwise; or (c) Subject to Section 8.8 hereof, default in the performance or breach of any material covenant or warranty of the Governmental Lender in this Funding Loan Agreement (other than a covenant or warranty or default in the performance or breach of which is elsewhere in this Section specifically dealt with), and continuance of such default or breach for a period of 30 days after there has been given written notice, as provided in Section 12.1 hereof, to the Governmental Lender, the Fiscal Agent and the Borrower by the Funding Lender or the Servicer, specifying such default or breach and requiring it to be remedied and stating that such notice is a “Notice of Default” under this Funding Loan Agreement; provided that, so long as the Governmental Lender, or the Borrower or Equity Investor on behalf of the Governmental Lender, has commenced to cure such failure to observe or perform within the thirty (30) day cure period and the subject matter of the default is not capable of cure within said thirty (30) day period and the Governmental Lender, or the Borrower or Equity Investor on behalf of the Governmental Lender, is diligently pursuing such cure to the Funding Lender’s satisfaction, with the Funding Lender’s Written Direction or Written Consent, then the Governmental Lender shall have an additional period of time as reasonably necessary (not to exceed 30 days unless extended in writing by the Funding Lender) within which to cure such default; or (d) A default in the payment of any Additional Borrower Payments; or (e) Any other “Default” or “Event of Default” under any of the other Funding Loan Documents to which the Governmental Lender is a party and is an obligor thereunder or, upon the Written Direction of the Funding Lender, under any other Funding Loan Document (taking into account any applicable grace periods therein). 26 4856-5616-9347.5 Any notice of default delivered by the Funding Lender to the Borrower shall be contemporaneously delivered to the Equity Investor. Section 9.2. Acceleration of Maturity; Rescission and Annulment. (a) Subject to the provisions of Article V and Section 9.9 hereof, upon the occurrence of an Event of Default under Section 9.1 hereof, then and in every such case, the Funding Lender may declare the principal of the Funding Loan and the Governmental Lender Note and the interest accrued to be immediately due and payable, by notice to the Fiscal Agent, the Governmental Lender and the Borrower and upon any such declaration, all principal of and Prepayment Premium, if any, and interest on the Governmental Lender Note shall become immediately due and payable. (b) At any time after a declaration of acceleration has been made pursuant to subsection (a) of this Section, the Funding Lender may by Written Notice to the Fiscal Agent, the Borrower and the Governmental Lender, rescind and annul such declaration and its consequences if: (i) The Borrower has deposited with the Fiscal Agent or the Funding Lender a sum sufficient to pay (1) all overdue installments of interest on the Governmental Lender Note, (2) the principal of and Prepayment Premium on the Governmental Lender Note that has become due otherwise than by such declaration of acceleration and interest thereon at the rate or rates prescribed therefor in the Governmental Lender Note, (3) to the extent that payment of such interest is lawful, interest upon overdue installments of interest at the rate or rates prescribed therefor in the Governmental Lender Note, and (4) all sums paid or advanced by the Funding Lender and the reasonable compensation, expenses, disbursements and advances of the Funding Lender, its agents and counsel (but only to the extent not duplicative with subclauses (1) and (3) above); and (ii) All Events of Default, other than the non-payment of the principal of the Governmental Lender Note which have become due solely by such declaration of acceleration, have been cured or have been waived in writing as provided in Section 9.9 hereof. No such rescission and annulment shall affect any subsequent default or impair any right consequent thereon. (c) Notwithstanding the occurrence and continuation of an Event of Default, it is understood that the Funding Lender shall pursue no remedies against the Borrower or the Project if no Borrower Loan Agreement Default has occurred and is continuing. An Event of Default hereunder shall not in and of itself constitute a Borrower Loan Agreement Default. Section 9.3. Additional Remedies; Funding Lender Enforcement. (a) Upon the occurrence of an Event of Default, the Funding Lender may, subject to the provisions of Article V, this Section 9.3 and Section 9.9 hereof, proceed to protect and enforce its rights by mandamus or other suit, action or proceeding at law or in equity. No remedy conferred by this Funding Loan Agreement upon, or remedy reserved to the Funding Lender is intended to be exclusive of any other remedy, but each such remedy shall be cumulative and shall be in addition to any other remedy given to the Funding Lender hereunder or now or hereafter existing at law or in equity or by statute. The Funding Lender acknowledges and agrees that the Governmental Lender shall not be responsible or liable for any fees and expenses incurred by the Funding Lender in connection with pursuing remedies under this Article IX. 27 4856-5616-9347.5 (b) Upon the occurrence and continuation of any Event of Default, the Funding Lender may proceed forthwith to protect and enforce its rights and this Funding Loan Agreement by such suits, actions or proceedings as the Funding Lender, in its sole discretion, shall deem expedient. Funding Lender shall have upon the occurrence and continuation of any Event of Default all rights, powers, and remedies with respect to the Security as are available under the Uniform Commercial Code applicable thereto or as are available under any other applicable law at the time in effect and, without limiting the generality of the foregoing, the Funding Lender may proceed at law or in equity or otherwise, to the extent permitted by applicable law: (i) to take possession of the Security or any part thereof, with or without legal process, and to hold, service, administer and enforce any rights thereunder or thereto, and otherwise exercise all rights of ownership thereof, including (but not limited to) the sale of all or part of the Security; (ii) to become mortgagee of record for the Permanent Phase Borrower Loan including, without limitation, completing the assignment of the Security Instrument by the Governmental Lender to the Funding Lender as anticipated by this Funding Loan Agreement, and recording the same in the real estate records of the jurisdiction in which the Project is located, without further act or consent of the Governmental Lender, and to service and administer the same for its own account; (iii) to service and administer the Funding Loan as agent and on behalf of the Governmental Lender or otherwise, and, if applicable, to take such actions necessary to enforce the Borrower Loan Documents and the Funding Loan Documents on its own behalf, and to take such alternative courses of action, as it may deem appropriate; or (iv) to take such steps to protect and enforce its rights whether by action, suit or proceeding in equity or at law for the specific performance of any covenant, condition or agreement in the Governmental Lender Note, this Funding Loan Agreement or the other Funding Loan Documents, or the Borrower Loan Documents, or in and of the execution of any power herein granted, or for foreclosure hereunder, or for enforcement of any other appropriate legal or equitable remedy or otherwise as the Funding Lender may elect. (c) Whether or not an Event of Default has occurred, the Funding Lender, in its sole discretion, shall have the sole right to waive or forbear any term, condition, covenant or agreement of the Security Instrument, the Borrower Loan Agreement, the Permanent Phase Borrower Note or any other Borrower Loan Documents or Funding Loan Documents applicable to the Borrower, or any breach thereof, other than a covenant that would adversely impact the tax exempt status of the interest on the Governmental Lender Note, and provided that the Governmental Lender may enforce specific performance with respect to the Unassigned Rights; provided, however, that any such forbearance by the Funding Lender in the exercise of its remedies under the Funding Loan Documents shall not be construed as a waiver by the Funding Lender of any Conditions to Conversion. (d) If the Borrower defaults in the performance or observance of any covenant, agreement or obligation of the Borrower set forth in the Regulatory Agreement, and if such default remains uncured for a period of 60 days after the Borrower, the Governmental Lender, the Fiscal Agent and the Funding Lender receive Written Notice stating that a default under the Regulatory Agreement has occurred and specifying the nature of the default, the Funding Lender shall have the right to seek specific performance of the provisions of the Regulatory Agreement or to exercise its other rights or remedies thereunder; provided, however, that any such forbearance by the Funding Lender in the exercise of its remedies under the Funding Loan Documents shall not be construed as a waiver by the Funding Lender of any Conditions to Conversion. 28 4856-5616-9347.5 (e) If the Borrower defaults in the performance of its obligations under the Borrower Loan Agreement to make rebate payments, to comply with any applicable continuing disclosure requirements, or to make payments owed pursuant to Sections 2.5, 5.15 or 5.16 of the Borrower Loan Agreement for fees, expenses or indemnification, the Funding Lender shall have the right to exercise all its rights and remedies thereunder (subject to the last paragraph of Section 9.14 hereof). Section 9.4. Application of Money Collected. Any money collected by the Funding Lender or the Fiscal Agent pursuant to this Article and any other sums then held by the Funding Lender as part of the Security, shall be applied in the following order, at the date or dates fixed by the Funding Lender: First: To the payment of any and all other amounts due under the Funding Loan Documents to the Fiscal Agent incurred in performance of its duties under this Funding Loan Agreement, including, without limitation, the payment of all reasonable fees and expenses of the Fiscal Agent incurred in exercising any remedies under this Funding Loan Agreement; Second: To the payment of any and all other amounts due under the Funding Loan Documents other than with respect to principal and interest accrued on the Funding Loan, including, without limitation, any amounts due to the Governmental Lender, the Funding Lender, the Servicer, and the Rebate Analyst; Third: To the payment of the whole amount of the Funding Loan, as evidenced by the Governmental Lender Note, then due and unpaid in respect of which or for the benefit of which such money has been collected, with interest (to the extent that such interest has been collected or a sum sufficient therefor has been so collected and payment thereof is legally enforceable at the respective rate or rates prescribed therefor in the Governmental Lender Note) on overdue principal of, and Prepayment Premium and overdue installments of interest on the Governmental Lender Note; provided, however, that partial interests in any portion of the Funding Loan, as evidenced by the Governmental Lender Note shall be paid in such order of priority as may be prescribed by Written Direction of the Funding Lender in its sole and absolute discretion; and Fourth: The payment of the remainder, if any, to the Borrower or to whosoever may be lawfully entitled to receive the same or as a court of competent jurisdiction may direct. If and to the extent this Section 9.4 conflicts with the provisions of the Servicing Agreement, the provisions of the Servicing Agreement shall control. Capitalized terms used in this Section 9.4 but not otherwise defined in this Funding Loan Agreement shall have the meanings given such terms in the Servicing Agreement. Section 9.5. Remedies Vested in Funding Lender. All rights of action and claims under this Funding Loan Agreement or the Governmental Lender Note may be prosecuted and enforced by the Funding Lender without the possession of the Governmental Lender Note or the production thereof in any proceeding relating thereto. Section 9.6. Restoration of Positions. If Funding Lender shall have instituted any proceeding to enforce any right or remedy under this Funding Loan Agreement and such proceeding shall have been discontinued or abandoned for any reason or shall have been determined adversely to the Funding Lender, then and in every such case the Governmental Lender and the Funding Lender shall, subject to any determination in such proceeding, be restored to their former positions hereunder, and thereafter all rights and remedies of the Governmental Lender and the Funding Lender shall continue as though no such proceeding had been instituted. 29 4856-5616-9347.5 Section 9.7. Rights and Remedies Cumulative. No right or remedy herein conferred upon or reserved to the Funding Lender is intended to be exclusive of any other right or remedy, and every right and remedy shall, to the extent permitted by law, be cumulative and in addition to every other right and remedy given hereunder or now or hereafter existing at law or in equity or otherwise. The assertion or employment of any right or remedy hereunder, or otherwise, shall not prevent the concurrent assertion or employment of any other appropriate right or remedy. Section 9.8. Delay or Omission Not Waiver. No delay or omission of the Funding Lender to exercise any right or remedy accruing upon an Event of Default shall impair any such right or remedy or constitute a waiver of any such Event of Default or an acquiescence therein. Every right and remedy given by this Article or by law to the Funding Lender may be exercised from time to time, and as often as may be deemed expedient, by Funding Lender. No waiver of any default or Event of Default pursuant to Section 9.9 hereof shall extend to or shall affect any subsequent default or Event of Default hereunder or shall impair any rights or remedies consequent thereon. Section 9.9. Waiver of Past Defaults. Before any judgment or decree for payment of money due has been obtained by the Funding Lender against the Borrower, the Funding Lender may, subject to Section 9.6 hereof, by Written Notice to the Fiscal Agent, the Governmental Lender and the Borrower, waive any past default hereunder or under the Borrower Loan Agreement and its consequences except for default in obligations due the Governmental Lender pursuant to or under the Unassigned Rights. Upon any such waiver, such default shall cease to exist, and any Event of Default arising therefrom shall be deemed to have been cured, for every purpose of this Funding Loan Agreement and the Borrower Loan Agreement; but no such waiver shall extend to any subsequent or other default or impair any right consequent thereon. Section 9.10. Remedies Under Borrower Loan Agreement or Permanent Phase Borrower Note. As set forth in this Section 9.10 but subject to Section 9.9 hereof, the Funding Lender shall have the right, in its own name or on behalf of the Governmental Lender, to declare any default and exercise any remedies under the Borrower Loan Agreement or the Permanent Phase Borrower Note, whether or not the Governmental Lender Note have been accelerated or declared due and payable by reason of an Event of Default. Section 9.11. Waiver of Appraisement and Other Laws. (a) To the extent permitted by law, the Governmental Lender will not at any time insist upon, plead, claim or take the benefit or advantage of, any appraisement, valuation, stay, extension or redemption law now or hereafter in force, in order to prevent or hinder the enforcement of this Funding Loan Agreement; and the Governmental Lender, for itself and all who may claim under it, so far as it or they now or hereafter may lawfully do so, hereby waives the benefit of all such laws. The Governmental Lender, for itself and all who may claim under it, waives, to the extent that it may lawfully do so, all right to have the property in the Security marshaled upon any enforcement hereof. (b) If any law now in effect prohibiting the waiver referred to in Section 9.11(a) shall hereafter be repealed or cease to be in force, such law shall not thereafter be deemed to constitute any part of the contract herein contained or to preclude the application of this Section 9.11. Section 9.12. Suits to Protect the Security. The Funding Lender shall have power to institute and to maintain such proceedings as it may deem expedient to prevent any impairment of the Security by any acts that may be unlawful or in violation of this Funding Loan Agreement and to protect its interests in the Security and in the rents, issues, profits, revenues and other income arising therefrom, including power to institute and maintain proceedings to restrain the enforcement of or compliance with any Governmental enactment, rule or order that may be unconstitutional or otherwise invalid, if the enforcement of or 30 4856-5616-9347.5 compliance with such enactment, rule or order would impair the security hereunder or be prejudicial to the interests of the Funding Lender. Section 9.13. Remedies Subject to Applicable Law. All rights, remedies and powers provided by this Article may be exercised only to the extent that the exercise thereof does not violate any applicable provision of law in the premises, and all the provisions of this Article are intended to be subject to all applicable mandatory provisions of law which may be controlling in the premises and to be limited to the extent necessary so that they will not render this Funding Loan Agreement invalid, unenforceable or not entitled to be recorded, registered or filed under the provisions of any applicable law. Section 9.14. Assumption of Obligations. In the event that the Funding Lender or its assignee or designee shall become the legal or beneficial owner of the Project by foreclosure or deed in lieu of foreclosure, such party shall succeed to the rights and the obligations of the Borrower under the Borrower Loan Agreement, the Permanent Phase Borrower Note, the Regulatory Agreement and any other Funding Loan Documents to which the Borrower is a party. Such assumption shall be effective from and after the effective date of such acquisition and shall be made with the benefit of the limitations of liability set forth therein and without any liability for the prior acts of the Borrower. It is the intention of the parties hereto that upon the occurrence and continuance of an Event of Default hereunder, rights and remedies may be pursued pursuant to the terms of the Funding Loan Documents. ARTICLE X AMENDMENT; AMENDMENT OF FUNDING LOAN AGREEMENT AND OTHER DOCUMENTS Section 10.1. Amendment of Funding Loan Agreement. Any of the terms of this Funding Loan Agreement and the Governmental Lender Note may be amended or waived only by an instrument signed by the Funding Lender, the Fiscal Agent and the Governmental Lender; provided, however, no such amendment which materially affects the rights, duties, obligations or other interests of the Borrower shall be made without the consent of the Borrower, and, provided further, that if the Borrower is in default under any Funding Loan Document, no Borrower consent shall be required unless such amendment has a material adverse effect on the rights, duties, obligations or other interests of the Borrower. All of the terms of this Funding Loan Agreement shall be binding upon the successors and assigns of and all persons claiming under or through the Governmental Lender, the Fiscal Agent or any such successor or assign, and shall inure to the benefit of and be enforceable by the successors and assigns of the Funding Lender and the Fiscal Agent. Section 10.2. Amendments Require Funding Lender Consent. Neither the Governmental Lender nor the Fiscal Agent shall consent to any amendment, change or modification of the Borrower Loan Agreement or any other Permanent Phase Borrower Loan Document or Funding Loan Document without the prior Written Consent of the Funding Lender. Section 10.3. Consents and Opinions. No amendment to this Funding Loan Agreement or any other Funding Loan Document entered into under this Article X or any amendment, change or modification otherwise permitted under this Article X shall become effective unless and until (i) the Funding Lender shall have approved the same in writing in its sole discretion and (ii) the Funding Lender, the Governmental Lender and the Fiscal Agent shall have received, at the expense of the Borrower, a Tax Counsel No Adverse Effect Opinion and an Opinion of Counsel to the effect that any such proposed amendment is authorized and complies with the provisions of this Funding Loan Agreement and is a legal, valid and binding 31 4856-5616-9347.5 obligation of the parties thereto, subject to normal exceptions relating to bankruptcy, insolvency and equitable principles limitations. ARTICLE XI THE FISCAL AGENT Section 11.1. Appointment of Fiscal Agent; Acceptance. The Governmental Lender hereby appoints The Bank of New York Mellon Trust Company, N.A. as Fiscal Agent hereunder. The Fiscal Agent shall signify its acceptance of the duties and obligations imposed upon it by this Funding Loan Agreement by executing this Funding Loan Agreement. Section 11.2. Certain Duties and Responsibilities of Fiscal Agent. (a) The Fiscal Agent undertakes to perform such duties and only such duties as are specifically set forth in this Funding Loan Agreement, and no implied covenants or obligations shall be read into this Funding Loan Agreement against the Fiscal Agent. (b) If an event of default exists hereunder or under any Permanent Phase Borrower Loan Document of which Fiscal Agent has been provided Written Notice, the Fiscal Agent shall exercise such of the rights and powers vested in it by this Funding Loan Agreement, and subject to Section 11.2(c)(iii) hereof, use the same degree of care and skill in its exercise, as a prudent corporate trust officer would exercise or use under the circumstances in the conduct of corporate trust business. The Fiscal Agent, prior to the occurrence of an event of default and after the curing of all events of default which may have occurred, undertakes to perform such duties and only such duties as are specifically set forth in this Funding Loan Agreement, and no implied covenants or obligations should be read into this Funding Loan Agreement against the Fiscal Agent. (i) The Fiscal Agent may consult with counsel, and the advice of such counsel or any Opinion of Counsel shall be full and complete authorization and protection in respect of any action taken, suffered or omitted by the Fiscal Agent hereunder in good faith and in reliance thereon. (ii) The Fiscal Agent shall not be accountable for the use or application by the obligor of the Governmental Lender Note or the proceeds thereof or for the use or application of any money paid over by the Fiscal Agent in accordance with the provisions of this Funding Loan Agreement or for the use and application of money received by any paying agent. (iii) The Fiscal Agent shall have no liability for any loss, expense or liability incurred as a result of such investment made in accordance with directions of the Borrower or the Governmental Lender, as applicable. (c) No provision of this Funding Loan Agreement shall be construed to relieve the Fiscal Agent from liability for its own negligent action, its own negligent failure to act, or its own willful misconduct, in each case, as finally adjudicated by a court of law, except that: (i) This subsection shall not be construed to limit the effect of subsection (a) of this Section; (i) The Fiscal Agent shall not be liable for any error of judgment made in good faith, unless it shall be proved that the Fiscal Agent was negligent in ascertaining the pertinent facts; 32 4856-5616-9347.5 (ii) The Fiscal Agent shall not be liable with respect to any action taken or omitted to be taken by it in accordance with the direction of the Funding Lender relating to the time, method and place of conducting any proceeding for any remedy available to the Fiscal Agent, or exercising any trust or power conferred upon the Fiscal Agent under this Funding Loan Agreement; and (iii) No provision of this Funding Loan Agreement shall require the Fiscal Agent to expend or risk its own funds or otherwise incur any financial liability in the performance of any of its duties hereunder, or in the exercise of any of its rights or powers, if it shall have reasonable grounds for believing that repayment of such funds or adequate indemnity against such risk or liability is not assured to it in its sole discretion. Subject to its rights to indemnification pursuant to Section 11.4 hereof, the Fiscal Agent is directed to enter into the Borrower Loan Documents to which it is a party and other related documents, solely in its capacity as Fiscal Agent. (d) Whether or not therein expressly so provided, every provision of this Funding Loan Agreement and the other Funding Loan Documents relating to the conduct or affecting the liability of or affording protection to the Fiscal Agent shall be subject to the provisions of this Section. (e) The Fiscal Agent may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed therein, upon certificates or opinions furnished to the Fiscal Agent and conforming to the requirements of this Funding Loan Agreement; but in the case of any such certificates or opinions which by any provision hereof are specifically required to be furnished to the Fiscal Agent, the Fiscal Agent shall be under a duty to examine the same to determine whether or not they conform to the requirements of this Funding Loan Agreement. (f) The permissive rights of the Fiscal Agent to do things enumerated in this Funding Loan Agreement shall not be construed as a duty. (g) The rights of the Fiscal Agent and limitations of liability enumerated herein and in Section 11.4 shall extend to actions taken or omitted in its role as assignee of the Governmental Lender under the Borrower Loan Agreement and the other Funding Loan Documents. (h) In connection with the issuance of the Governmental Lender Note, certain moneys may be deposited with the Fiscal Agent before the Delivery Date pursuant to one or more letters of instruction from the provider or providers of such moneys. Such moneys will be held uninvested by the Fiscal Agent subject to the terms and conditions of this Funding Loan Agreement in addition to terms provided in such letter(s) of instruction. For such purpose the standards of care, provisions regarding responsibilities and indemnification and other sections relating to the Fiscal Agent contained in this Funding Loan Agreement and the Borrower Loan Agreement (the “Effective Provisions”) shall be effective as of the first day of receipt by the Fiscal Agent of such moneys. The Effective Provisions shall be deemed incorporated into such letter(s) of instructions. Section 11.3. Notice of Defaults. Upon the occurrence of any default hereunder or under any Permanent Phase Borrower Loan Document and provided that a Responsible Officer of the Fiscal Agent is aware of or has received Written Notice of the existence of such default, promptly, and in any event within 15 days, the Fiscal Agent shall transmit to the Governmental Lender, the Borrower, the Equity Investor, the Servicer, if any, and the Funding Lender, in the manner and at the addresses for notices set forth in Section 12.1 hereof, notice of such default hereunder known to the Fiscal Agent pursuant to Section 11.4(g) hereof, unless such default shall have been cured or waived. 33 4856-5616-9347.5 Section 11.4. Certain Rights of Fiscal Agent. Except as otherwise provided in Section 11.1 hereof: (a) The Fiscal Agent may rely and shall be protected in acting or refraining from acting upon any resolution, certificate, statement, instrument, opinion, report, notice, request, direction, consent, order, bond, note, debenture, coupon or other paper or document believed by it to be genuine and to have been signed or presented by the purported proper party or parties; (b) Any request or direction of the Governmental Lender mentioned herein shall be sufficiently evidenced by a certificate or order executed by an Authorized Governmental Lender Representative; (c) Whenever in the administration of this Funding Loan Agreement or any Permanent Phase Borrower Loan Document the Fiscal Agent shall deem it desirable that a matter be proved or established prior to taking, suffering or omitting any action hereunder, the Fiscal Agent (unless other evidence be herein specifically prescribed) may, in the absence of bad faith on its part, rely upon a Written Certificate of the Governmental Lender, the Funding Lender, the Servicer or the Borrower, as appropriate; (d) The Fiscal Agent shall be under no obligation to exercise any of the rights or powers vested in it by this Funding Loan Agreement or any Permanent Phase Borrower Loan Document at the request or direction of the Funding Lender, pursuant to this Funding Loan Agreement, unless the Funding Lender shall have offered to the Fiscal Agent in writing security or indemnity reasonably satisfactory to the Fiscal Agent against the costs, expenses and liabilities which might be incurred by it in compliance with such request or direction, except costs, expenses and liabilities which are adjudicated to have resulted from its own negligence or willful misconduct, provided, that nothing contained in this subparagraph (d) shall be construed to require such security or indemnity for the performance by the Fiscal Agent of its obligations under Section 8.6 hereof; (e) The Fiscal Agent shall not be bound to make any investigation into the facts or matters stated in any resolution, certificate, statement, instrument, opinion, report, notice, request, direction, consent, order, bond, note, debenture, coupon or other paper or document but the Fiscal Agent, in its discretion, may make such further inquiry or investigation into such facts or matters as it may see fit, and, if the Fiscal Agent shall determine to make such further inquiry or investigation, it shall be entitled to examine the books and records of the Governmental Lender, if any, and of the Borrower, in either case personally or by agent or attorney after reasonable notice and during normal business hours; (f) The Fiscal Agent may execute any of the trusts or powers hereunder or perform any duties hereunder either directly or by or through agents or attorneys and pay reasonable compensation thereto and the Fiscal Agent shall not be responsible for any misconduct or negligence on the part of any agent or attorney appointed with due care by it hereunder. The Fiscal Agent may act upon the advice of counsel of its choice concerning all matters hereof and the Fiscal Agent shall not be responsible for any loss or damage resulting from any action or inaction taken in good faith reliance upon said advice; (g) Notwithstanding anything contained herein or in the Security Instrument to the contrary, upon the occurrence and continuance of an Event of Default, before taking any foreclosure action or any action which may subject the Fiscal Agent to liability under any environmental law, statute, regulation or similar requirement relating to the environment, the Fiscal Agent may require that a satisfactory indemnity bond, indemnity or environmental impairment insurance be furnished for the payment or reimbursement of all expenses to which it may be put and to protect it against all liability resulting from any claims, judgments, damages, losses, penalties, fines, liabilities (including strict liability) and expenses which may result from such foreclosure or other action. The Fiscal Agent shall not be required to take any action to foreclose or otherwise enforce the Security Instrument unless indemnified to its satisfaction and will not be 34 4856-5616-9347.5 required to foreclose if doing so will subject it to environmental liability or will require the approval of a governmental regulator that cannot be obtained; and (h) The Fiscal Agent shall not be required to take notice or be deemed to have notice of any default hereunder or under any Permanent Phase Borrower Loan Document except for failure by the Borrower to make payments of principal, interest, premium, if any, or the Governmental Lender Fee when due, unless a Responsible Officer of the Fiscal Agent shall be specifically notified by a Written Direction of such default by the Governmental Lender, the Servicer or the Funding Lender, and all notices or other instruments required by this Funding Loan Agreement or under any Permanent Phase Borrower Loan Document to be delivered to the Fiscal Agent, must, in order to be effective, be delivered in writing to a Responsible Officer of the Fiscal Agent at the Office of the Fiscal Agent, and in the absence of such Written Notice so delivered the Fiscal Agent may conclusively assume there is no default as aforesaid. Section 11.5. Not Responsible for Recitals. The recitals contained herein and in the Governmental Lender Note shall be taken as the statements of the Governmental Lender, and the Fiscal Agent assumes no responsibility for their correctness. The Fiscal Agent makes no representations as to the value or condition of the Pledged Revenues, the Security or any part thereof, or as to the title of the Governmental Lender thereto or as to the security afforded thereby or hereby, or as to the validity or sufficiency of this Funding Loan Agreement or of the Governmental Lender Note. The Fiscal Agent shall have no responsibility or liability with respect to any information, statement or recital in any offering memorandum or other disclosure material prepared or distributed with respect to the funding of the Funding Loan. The Fiscal Agent shall not be required to monitor the financial condition of the Borrower or the physical condition of the Project. Unless otherwise expressly provided, the Fiscal Agent shall be under no obligation to analyze, review or make any credit decisions with respect to any financial statements, reports, notices, certificates or documents received hereunder but shall hold such financial statements reports, notices, certificates and documents solely for the benefit of, and review by, the Funding Lender and such other parties to whom the Fiscal Agent may provide such information pursuant to this Funding Loan Agreement The Fiscal Agent shall not be deemed to have notice of any information contained therein or event of default which may be disclosed therein in any manner. The Fiscal Agent makes no representations as to and shall have no responsibility for the sufficiency of the insurance required under any of the Borrower Loan Documents. Section 11.6. May Hold Governmental Lender Note. The Fiscal Agent in its individual or any other capacity may become the owner or pledgee of the Governmental Lender Note and may otherwise deal with the Governmental Lender, the Funding Lender and the Borrower with the same rights it would have if it were not Fiscal Agent. Section 11.7. Moneys Held in Trust. Moneys held by the Fiscal Agent in trust hereunder need not be segregated from other funds except to the extent required by law. The Fiscal Agent shall be under no liability for interest on any moneys received by it hereunder except as otherwise provided herein. Section 11.8. Compensation and Reimbursement. Under the Borrower Loan Agreement, the Borrower has agreed to, except as otherwise expressly provided herein, reimburse the Fiscal Agent as provided in this Funding Loan Agreement or the Borrower Loan Agreement, upon its request for all reasonable expenses, disbursements and advances incurred or made by the Fiscal Agent in accordance with any provision of this Funding Loan Agreement (including the reasonable fees, expenses and disbursements 35 4856-5616-9347.5 of its agents and counsel), except any such expense, disbursement or advance as may be attributable to the Fiscal Agent’s negligence or willful misconduct, both as finally adjudicated by a court of law. When the Fiscal Agent incurs expenses or renders service in connection with any bankruptcy or insolvency proceeding, such expenses (including the fees and expenses of its counsel) and the compensation for such services are intended to constitute expenses of administration under any bankruptcy law or law relating to creditors rights generally. (a) The Governmental Lender has no obligation to pay the Fiscal Agent for services rendered. (b) As security for the performance of the obligations of the Borrower under this Section and for the payment of such compensation, expenses, reimbursements and indemnity, the Fiscal Agent shall have the right to use and apply any moneys held by it as Pledged Revenues. (c) The Fiscal Agent’s rights to compensation and reimbursement shall survive its resignation or removal, the payment of the Funding Loan or the Permanent Phase Borrower Loan or the release of this Funding Loan Agreement. Section 11.9. Fiscal Agent Required; Eligibility. Any successor Fiscal Agent shall at all times be a trust company, a state banking corporation or a national banking association with the authority to accept trusts in the State approved in writing by the Governmental Lender and either (a) have a combined capital and surplus of at least $50,000,000 as set forth in its most recent published annual report of condition, (b) be a wholly owned subsidiary of a bank holding company, or a wholly owned subsidiary of a company that is a wholly owned subsidiary of a bank holding company, having a combined capital surplus of at least $50,000,000 as set forth in its most recent published annual report of condition, have at least $500,000,000 of trust assets under management and have a combined capital surplus of at least $2,000,000 as set forth in its most recent published annual report of condition, or (c) be otherwise acceptable to the Funding Lender in its sole and absolute discretion. Section 11.10. Resignation and Removal; Appointment of Successor. (a) No resignation or removal of the Fiscal Agent hereunder and no appointment of a successor Fiscal Agent pursuant to this Article shall become effective until the written acceptance by the successor Fiscal Agent of such appointment. (b) The Fiscal Agent may resign at any time by giving 60 days’ Written Notice thereof to the Governmental Lender, the Borrower, the Servicer, if any, and the Funding Lender. If an instrument of acceptance by a successor Fiscal Agent shall not have been delivered to the Fiscal Agent within 30 days after the giving of such notice of resignation, the resigning Fiscal Agent may petition any court of competent jurisdiction for the appointment of a successor Fiscal Agent. (c) The Fiscal Agent may be removed at any time with 30 days’ notice by (i) the Governmental Lender, with the Written Consent of the Funding Lender, (ii) the Borrower (unless the Borrower is in default under any of the Borrower Loan Documents), with the Written Consent of the Funding Lender and the Governmental Lender, or (iii) the Funding Lender by Written Notice delivered to the Fiscal Agent, the Governmental Lender and the Borrower. (d) If the Fiscal Agent shall resign, be removed or become incapable of acting, or if a vacancy shall occur in the Office of the Fiscal Agent for any cause, the Governmental Lender shall promptly appoint a successor Fiscal Agent, with the consent of the Funding Lender. In case all or substantially all of the Pledged Revenues and Security shall be in the possession of a receiver or trustee lawfully appointed, such 36 4856-5616-9347.5 receiver or trustee may similarly appoint a successor to fill such vacancy until a new Fiscal Agent shall be so appointed by the Governmental Lender. If, within 60 days after such resignation, removal or incapability or the occurrence of such vacancy, the Governmental Lender has failed to so appoint a successor Fiscal Agent, then a successor Fiscal Agent shall be appointed by the Funding Lender (from any institution acceptable to the Governmental Lender to serve as a fiscal agent or trustee) with Written Notice thereof delivered to the Governmental Lender, the Borrower, the Servicer, if any, and the retiring Fiscal Agent, and the successor Fiscal Agent so appointed shall, forthwith upon its acceptance of such appointment, become the successor Fiscal Agent and supersede the successor Fiscal Agent appointed by such receiver or Fiscal Agent. If no successor Fiscal Agent shall have been appointed by the Governmental Lender or the Funding Lender and accepted appointment in the manner hereinafter provided, the Fiscal Agent may petition any court of competent jurisdiction for the appointment of a successor Fiscal Agent. (e) The retiring Fiscal Agent shall cause Written Notice of each resignation and each removal of the Fiscal Agent and each appointment of a successor Fiscal Agent to be provided to the Funding Lender. Each notice shall include the name of the successor Fiscal Agent and the address of the office of the successor Fiscal Agent. Section 11.11. Acceptance of Appointment by Successor. (a) Every successor Fiscal Agent appointed hereunder shall execute, acknowledge and deliver to the Governmental Lender and to the retiring Fiscal Agent an instrument accepting such appointment, and thereupon the resignation or removal of the retiring Fiscal Agent shall become effective and such successor Fiscal Agent, without any further act, deed or conveyance, shall become vested with all the estates, properties, rights, powers, trusts and duties of the retiring Fiscal Agent; notwithstanding the foregoing, on request of the Governmental Lender or the successor Fiscal Agent, such retiring Fiscal Agent shall, upon payment of its charges, execute and deliver an instrument conveying and transferring to such successor Fiscal Agent upon the trusts herein expressed all the estates, properties, rights, powers and trusts of the retiring Fiscal Agent, and shall duly assign, transfer and deliver to such successor Fiscal Agent all property and money held by such retiring Fiscal Agent hereunder. Upon request of any such successor Fiscal Agent, the Governmental Lender shall execute any and all instruments for more fully and certainly vesting in and confirming to such successor Fiscal Agent all such estates, properties, rights, powers and trusts. (b) No successor Fiscal Agent shall accept its appointment unless at the time of such acceptance such successor Fiscal Agent shall be qualified and eligible under this Article, to the extent operative. Section 11.12. Merger, Conversion, Consolidation or Succession to Business. Any corporation or association into which the Fiscal Agent may be merged or with which it may be consolidated, or any corporation resulting from any merger, conversion or consolidation to which the Fiscal Agent shall be a party, or any corporation or association succeeding to all or substantially all of the corporate trust business of the Fiscal Agent, shall be the successor of the Fiscal Agent hereunder, provided such corporation shall be otherwise qualified and eligible under this Article, to the extent operative, without the execution or filing of any paper or any further act on the part of any of the parties hereto. Notwithstanding the foregoing, any such successor Fiscal Agent shall cause Written Notice of such succession to be delivered to the Funding Lender within 30 days of such succession. Section 11.13. Appointment of Co-Fiscal Agent. It is the purpose of this Funding Loan Agreement that there shall be no violation of any laws of any jurisdiction (including particularly the laws of the State) denying or restricting the right of banking corporations or associations to transact business as Fiscal Agent in such jurisdiction. It is recognized that in case of litigation under this Funding Loan Agreement, the Borrower Loan Agreement, any other Permanent Phase Borrower Loan Document or the 37 4856-5616-9347.5 Regulatory Agreement, and in particular in case of the enforcement of any of them on default, or in case the Fiscal Agent deems that by reason of any present or future law of any jurisdiction it may not exercise any of the powers, rights or remedies herein granted to the Fiscal Agent or hold title to the properties, in trust, as herein provided, or take any other action which may be desirable or necessary in connection therewith, it may be necessary that the Fiscal Agent appoint an additional individual or institution as a separate or co-fiscal agent. The following provisions of this Section are adopted to these ends. The Fiscal Agent is hereby authorized to appoint an additional individual or institution as a separate or co-fiscal agent hereunder, upon Written Notice to the Governmental Lender, the Funding Lender and the Borrower, and with the consent of the Governmental Lender and the Funding Lender, but without the necessity of further authorization or consent, in which event each and every remedy, power, right, claim, demand, cause of action, immunity, estate, title, interest and lien expressed or intended by this Funding Loan Agreement, any Permanent Phase Borrower Loan Document, the Regulatory Agreement or the Borrower Loan Agreement to be exercised by or vested in or conveyed to the Fiscal Agent with respect thereto shall be exercisable by and vest in such separate or co-fiscal agent but only to the extent necessary to exercise such powers, rights and remedies, and every covenant and obligation necessary to the exercise thereof by such separate or co-fiscal agent shall run to and be enforceable by either of them. Should any instrument in writing from the Governmental Lender be required by the separate fiscal agent or co-fiscal agent appointed by the Fiscal Agent for more fully and certainly vesting in and confirming to him or it such properties, rights, powers, trusts, duties and obligations, any and all such instruments in writing shall, on request of the Fiscal Agent, be executed, acknowledged and delivered by the Governmental Lender. In case any separate fiscal agent or co Fiscal Agent, or a successor to either, shall die, become incapable of acting, resign or be removed, all the estates, properties, rights, powers, trusts, duties and obligations of such separate fiscal agent or co-fiscal agent, so far as permitted by law, shall vest in and be exercised by the Fiscal Agent until the appointment of a successor to such separate fiscal agent or co-fiscal agent. Section 11.14. Loan Servicing. The Governmental Lender and the Fiscal Agent acknowledge that the Funding Lender shall have the right to appoint a Servicer to service and administer the Funding Loan and Permanent Phase Borrower Loan, as set forth in a Servicing Agreement. The Funding Lender shall provide Written Notice to the Fiscal Agent of the appointment, termination or replacement of any Servicer. The Governmental Lender and the Fiscal Agent shall not be responsible for monitoring the performance of any Servicer or for any acts or omissions of such Servicer. The Funding Lender may, in its sole discretion, terminate or replace the Servicer. Section 11.15. No Recourse Against Officers or Employees of Fiscal Agent. No recourse with respect to any claim related to any obligation, duty or agreement contained in this Funding Loan Agreement or any other Funding Loan Document shall be had against any officer or employee, as such, of the Fiscal Agent, it being expressly understood that the obligations, duties and agreements of the Fiscal Agent contained in this Funding Loan Agreement and the other Funding Loan Documents are solely corporate in nature. Section 11.16. USA Patriot Act Requirements of the Fiscal Agent. To help the government of the United States of America fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. For a non-individual person such as a business entity, a charity, a trust, or other legal entity, the Fiscal Agent may request documentation to verify such person’s formation and existence as a legal entity and the identity of the owners or controlling persons thereof. The Fiscal Agent may also request financial statements, licenses, identification and authorization documents from individuals claiming authority to represent such person or other relevant documentation. 38 4856-5616-9347.5 Section 11.17. Filing of Financial Statements. The Fiscal Agent shall cause to be filed a continuation statement with respect to each Uniform Commercial Code financing statement relating to the Funding Loan on which it is listed as a secured party, and which was filed at the time of the issuance of the Funding Loan, in such manner and in such places as the initial filings (copies of which shall be provided to the Fiscal Agent by the Governmental Lender) were made. The Borrower shall be responsible for the reasonable costs incurred by the Fiscal Agent in the preparation and filing of all such continuation statements hereunder. Notwithstanding anything to the contrary contained herein, the Fiscal Agent shall not be responsible for any initial filings of any financing statements or the information contained therein (including the exhibits thereto), the perfection of any such security interests, or the accuracy or sufficiency of any description of collateral in such initial filings or for filing any modifications or amendments to the initial filings required by any amendments to Article 9 of the Uniform Commercial Code, and unless the Fiscal Agent shall have been notified by the Funding Lender that any such initial filing or description of collateral was or has become defective, the Fiscal Agent shall be fully protected in relying on such initial filing and descriptions in filing any continuation statements or modifications thereto pursuant to this Section 11.17 and in filing any continuation statements in the same filing offices as the initial filings were made. ARTICLE XII MISCELLANEOUS Section 12.1. Notices. All notices, demands, requests and other communications required or permitted to be given by any provision of this Funding Loan Agreement shall be in writing and sent by first class, regular, registered or certified mail, commercial delivery service, overnight courier, e-mail, telecopier or facsimile transmission, air or other courier, or hand delivery to the party to be notified addressed as follows: If to the Borrower: Vista Breeze, Ltd. c/o Atlantic Pacific Communities, LLC 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor Telephone: (305) 357-4700 Email: knaylor@apcompanies.com with a copy to: Klein Hornig LLP 1325 G. Street NW, Suite 770 Washington, DC 20005 Attention: Chris Hornig Email: chornig@kleinhornig.com Tel: (202) 926-3402 Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A. (which copy shall not constitute notice to Borrower) 150 W. Flagler Street Miami, Florida 33130 Attention: Brian McDonough, Esq. Email: bmcdonough@stearnsweaver.com Telephone: (305) 789-3350 Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 39 4856-5616-9347.5 Pittsburg, Pennsylvania 15219 Attention: Alec Stone Email: ajstone@foxrothschild.com Telephone: (412) 391-2523 with a copy to: Bank of America, N.A. MA5-100-04-11 100 Federal Street Boston, MA 02110 Attention: Tax Credit Asset Management (Vista Breeze) Email: LIHTCreporting@bofa.com with a copy to: Holland & Knight LLP 10 St. James Avenue Boston, MA 02116 Attention: Sara C. Heskett, Esq. Email: sara.heskett@hklaw.com Telephone: (503) 243-5860 If to the Governmental Lender: Housing Finance Authority of Miami-Dade County, Florida 7855 NW 12th Street, Suite 202 Doral, Florida 33126 Attention: Cheree Gulley, Executive Director Facsimile: (305) 392-2722 Email: cgulley@hfamiami.com and a copy to: Miami-Dade County Attorney’s Office. 111 N.W. 12th Street Suite 2810 Miami, Florida 33128 Attention: David S. Hope, Esq. Email: dhope@miamidade.gov If to Funding Lender: with a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction and Asset Management Group Re: Vista Breeze Deal ID# __________ Facsimile: (212) 723-8209 Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID# __________ Facsimile: (805) 557-0924 and 40 4856-5616-9347.5 with a copy to: Citibank, N.A c/o Berkadia Commercial Mortgage LLC 323 Norristown Road, Suite 300 Ambler, Pennsylvania 19002 Attention: Client Relations Manager Re: Vista Breeze Deal ID# __________ Facsimile: (215) 328-0305 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID# _________ Facsimile: (646) 291-5754 If to Fiscal Agent: The Bank of New York Mellon Trust Company, N.A. 4655 Salisbury Road, Suite 300 Jacksonville, Florida 33256 Attention: Corporate Trust Department Email: heidi.bowers@bnymellon.com Telephone: (904) 645-1983 Any such notice, demand, request or communication shall be deemed to have been given and received for all purposes under this Funding Loan Agreement: (i) three Business Days after the same is deposited in any official depository or receptacle of the United States Postal Service first class, or, if applicable, certified mail, return receipt requested, postage prepaid; (ii) on the date of transmission when delivered by telecopier or facsimile transmission, e-mail or other telecommunication device, provided any telecopy or other electronic transmission received by any party after 4:00 p.m., local time, as evidenced by the time shown on such transmission, shall be deemed to have been received the following Business Day; (iii) on the next Business Day after the same is deposited with a nationally recognized overnight delivery service that guarantees overnight delivery; and (iv) on the date of actual delivery to such party by any other means; provided, however, if the day such notice, demand, request or communication shall be deemed to have been given and received as aforesaid is not a Business Day, such notice, demand, request or communication shall be deemed to have been given and received on the next Business Day. Any facsimile signature by a Person on a document, notice, demand, request or communication required or permitted by this Funding Loan Agreement shall constitute a legal, valid and binding execution thereof by such Person. Any party to this Funding Loan Agreement may change such party’s address for the purpose of notice, demands, requests and communications required or permitted under this Funding Loan Agreement by providing written notice of such change of address to all of the parties by written notice as provided herein. Section 12.2. Term of Funding Loan Agreement. This Funding Loan Agreement shall be in full force and effect until all payment obligations of the Governmental Lender hereunder have been paid in full and the Funding Loan has been retired or the payment thereof has been provided for; except that on and after payment in full of the Governmental Lender Note, this Funding Loan Agreement shall be terminated, without further action by the parties hereto. 41 4856-5616-9347.5 Section 12.3. Successors and Assigns. All covenants and agreements in this Funding Loan Agreement by the Governmental Lender shall bind its successors and assigns, whether so expressed or not. Section 12.4. Legal Holidays. In any case in which the date of payment of any amount due hereunder or the date on which any other act is to be performed pursuant to this Funding Loan Agreement shall be a day that is not a Business Day, then payment of such amount or such act need not be made on such date but may be made on the next succeeding Business Day, and such later payment or such act shall have the same force and effect as if made on the date of payment or the date fixed for prepayment or the date fixed for such act, and no additional interest shall accrue for the period after such date and prior to the date of payment. Section 12.5. Governing Law. This Funding Loan Agreement shall be governed by and shall be enforceable in accordance with the laws of the State. Section 12.6. Invalidity, Illegality or Unenforceability of Provisions. If any provision of this Funding Loan Agreement shall be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining portions shall not in any way be affected or impaired. In case any covenant, stipulation, obligation or agreement contained in the Governmental Lender Note or in this Funding Loan Agreement shall for any reason be held to be usurious or in violation of law, then such covenant, stipulation, obligation or agreement shall be deemed to be the covenant, stipulation, obligation or agreement of the Governmental Lender or the Funding Lender only to the full extent permitted by law. Section 12.7. Execution in Several Counterparts. This Funding Loan Agreement may be contemporaneously executed in several counterparts, all of which shall constitute one and the same instrument and each of which shall be, and shall be deemed to be, an original. Section 12.8. Nonrecourse Obligation of the Borrower. Except as otherwise provided in the Borrower Loan Agreement, any obligations of the Borrower under this Funding Loan Agreement pursuant to the provisions of the Borrower Loan Agreement are without recourse to the Borrower or to the Borrower’s partners or members, as the case may be, and the provisions of Section 11.1 of the Borrower Loan Agreement are by this reference incorporated herein. Section 12.9. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF THE PARTIES HERETO (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS FUNDING LOAN AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. Section 12.10. Electronic Transactions. (a) The transactions described in this Funding Loan Agreement may be conducted and related documents and may be stored by electronic means. Copies, telecopies, facsimiles, electronic files and other reproductions of original executed documents shall be deemed to be authentic and valid counterparts of such original documents for all purposes, including the filing of any claim, action or suit in the appropriate court of law. Notwithstanding the foregoing, original executed versions of each of the Funding Loan Agreement and the Borrower Loan Agreement shall be delivered to the Funding Lender in connection with the closing of the transaction described herein. 42 4856-5616-9347.5 (b) The Fiscal Agent shall have the right to accept and act upon instructions including funds transfer instructions (“Instructions”) given pursuant to this Funding Loan Agreement and related financing documents and delivered using Electronic Means; provided, however, that Borrower and/or the Governmental Lender, as applicable, shall provide to the Fiscal Agent an incumbency certificate listing officers with the authority to provide such Instructions (“Authorized Officers”) and containing specimen signatures of such Authorized Officers, which incumbency certificate shall be amended by Governmental Lender and/or the Borrower, as applicable, whenever a person is to be added or deleted from the listing. For purposes of this subsection (b), “Electronic Means” shall mean the following communications methods: e-mail, facsimile transmission, secure electronic transmission containing applicable authorization codes, passwords and/or authentication keys issued by the Fiscal Agent, or another method or system specified by the Fiscal Agent as available for use in connection with its services hereunder. If the Governmental Lender and/or the Borrower, as applicable, elects to give the Fiscal Agent Instructions using Electronic Means and the Fiscal Agent in its discretion elects to act upon such Instructions, the Fiscal Agent’s understanding of such Instructions shall be deemed controlling. The Governmental Lender and the Borrower understand and agree that the Fiscal Agent cannot determine the identity of the actual sender of such Instructions and that the Fiscal Agent shall conclusively presume that directions that purport to have been sent by an Authorized Officer listed on the incumbency certificate provided to the Fiscal Agent have been sent by such Authorized Officer. The Governmental Lender and the Borrower shall be responsible for ensuring that only Authorized Officers transmit such Instructions to the Fiscal Agent and that the Governmental Lender, the Borrower and all Authorized Officers are solely responsible to safeguard the use and confidentiality of applicable user and authorization codes, passwords and/or authentication keys upon receipt by the Governmental Lender and/or the Borrower, as applicable. The Fiscal Agent shall not be liable for any losses, costs or expenses arising directly or indirectly from the Fiscal Agent’s reliance upon and compliance with such Instructions notwithstanding such directions conflict or are inconsistent with a subsequent written instruction. The Governmental Lender and the Borrower agree: (i) to assume all risks arising out of the use of Electronic Means to submit Instructions to the Fiscal Agent, including without limitation the risk of the Fiscal Agent acting on unauthorized Instructions, and the risk of interception and misuse by third parties; (ii) that it is fully informed of the protections and risks associated with the various methods of transmitting Instructions to the Fiscal Agent and that there may be more secure methods of transmitting Instructions than the method(s) selected by the Governmental Lender and/or the Borrower, as applicable; (iii) that the security procedures (if any) to be followed in connection with its transmission of Instructions provide to it a commercially reasonable degree of protection in light of its particular needs and circumstances; and (iv) to notify the Fiscal Agent immediately upon learning of any compromise or unauthorized use of the security procedures. Section 12.11. Reference Date. This Funding Loan Agreement is dated for reference purposes only as of the date first above written. Section 12.12. Restatement of Construction Phase Funding Loan Agreement. The Construction Phase Funding Loan Agreement is hereby amended and restated in its entirety pursuant to this Funding Loan Agreement. [The remainder of this page is intentionally left blank; signature pages follow.] S-1 4856-5616-9347.5 IN WITNESS WHEREOF, the Funding Lender, the Fiscal Agent and the Governmental Lender have caused this Funding Loan Agreement to be duly executed as of the date first written above. CITIBANK, N.A., as the Funding Lender By: Name: Title: Deal ID # _________ [SIGNATURE PAGE TO AMENDED AND RESTATED FUNDING LOAN AGREEMENT – VISTA BREEZE] S-2 4856-5616-9347.5 THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., as Fiscal Agent By: ______________________________________ Name: Title: [SIGNATURE PAGE TO AMENDED AND RESTATED FUNDING LOAN AGREEMENT – VISTA BREEZE] S-3 4856-5616-9347.5 HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, as Governmental Lender By: Name: Title: [SIGNATURE PAGE TO AMENDED AND RESTATED FUNDING LOAN AGREEMENT – VISTA BREEZE] A-1 4856-5616-9347.5 EXHIBIT A FORM OF REQUIRED TRANSFEREE REPRESENTATIONS _________________, 20__ The undersigned, as holder (the “Holder”) of a loan (the “Funding Loan”) in the principal amount of $____________ from CITIBANK, N.A. (the “Funding Lender”) to Housing Finance Authority of Miami-Dade County, Florida (the “Governmental Lender”) pursuant to an Amended and Restated Funding Loan Agreement dated as of _________, 20__ (the “Funding Loan Agreement”) among the Funding Lender, The Bank of New York Mellon Trust Company, N.A., as fiscal agent (the “Fiscal Agent”), and the Governmental Lender (the “Funding Loan”) evidenced by the Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) (the “Governmental Lender Note”), or an interest therein, hereby represents that: 1. The Holder has sufficient knowledge and experience in financial and business matters with respect to the evaluation of residential real estate developments such as the Project to be able to evaluate the risk and merits of the investment represented by the Governmental Lender Note. We are able to bear the economic risks of such investment. 2. The Holder acknowledges that it has either been supplied with or been given access to information, including financial statements and other financial information, to which a reasonable investor would attach significance in making investment decisions, and the Holder has had the opportunity to ask questions and receive answers from knowledgeable individuals concerning the Governmental Lender, the Project, the use of proceeds of the Governmental Lender Note and the security therefor so that, as a reasonable investor, the Holder has been able to make its decision to purchase the Governmental Lender Note or an interest therein. In entering into this transaction, the Holder acknowledges that it has not relied upon any representations or opinions of the Governmental Lender relating to the legal consequences to the Funding Lender or other aspects of its making the Funding Loan and acquiring the Governmental Lender Note, nor has it looked to, nor expected, the Governmental Lender to undertake or require any credit investigation or due diligence reviews relating to the Borrower, its financial condition or business operations, the Project (including the financing or management thereof), or any other matter pertaining to the merits or risks of the transactions contemplated by the Funding Loan Agreement and the Borrower Loan Agreement, or the adequacy of the funds pledged to the Funding Lender to secure repayment of the Governmental Lender Note. 3. The Holder is an Approved Transferee. 4. The Holder acknowledges that it is purchasing [an interest in] the Governmental Lender Note for investment for its own account and not with a present view toward resale or the distribution thereof, in that it does not now intend to resell or otherwise dispose of all or any part of its interests in the Governmental Lender Note; provided, however, that the Holder may sell or transfer the Governmental Lender Note[ or an interest therein] pursuant to the terms of Section 2.6 of the Funding Loan Agreement. 5. The Holder understands that the Governmental Lender Note is a limited obligation of the Governmental Lender; payable solely from funds and moneys pledged and assigned under the Funding Loan Agreement, and that the liabilities and obligations of the Governmental Lender with respect to the Governmental Lender Note is expressly limited as set forth in the Funding Loan Agreement and related documents. A-2 4856-5616-9347.5 6. The Holder acknowledges that the Funding Loan is being made as a direct loan evidenced by the Governmental Lender Note and not through the purchase of a municipal security and that the Governmental Lender will not make a filing with the municipal securities Rulemaking Board’s Electronic Municipal Market Access Repository. The Holder acknowledges that no CUSIP numbers or credit ratings have been obtained with respect to the Governmental Lender Note. 7. The Holder hereby indemnifies the Governmental Lender and the Fiscal Agent from and against any and all liability, cost or expense (including attorneys’ fees) that may result if the purchase/transfer is not exempt from registration under the Securities Act or is not made in accordance with federal and state laws. Further, the Holder hereby affirms it shall not transfer or sell the Governmental Lender Note or any interest therein to a party related to or affiliated with the Borrower, any general partner, limited partner or member of the Borrower without the prior written consent of the Governmental Lender. 8. Capitalized terms used herein and not otherwise defined have the meanings given such terms in the Funding Loan Agreement. [Remainder of page intentionally left blank.] A-3 4856-5616-9347.5 [Signature Page to Required Transferee Representations] [ ], as Holder By Name Its D Forward Purchase Agreement Vista Breeze EXHIBIT D-2 TO FORWARD PURCHASE AGREEMENT FORM OF AMENDED AND RESTATED BORROWER LOAN AGREEMENT [See attached] 4894-2953-3827.5 FOLEY DRAFT #4 December 13, 2023 AMENDED AND RESTATED BORROWER LOAN AGREEMENT (Permanent Phase) among HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, as Governmental Lender THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A, as Fiscal Agent and VISTA BREEZE, LTD, as Borrower Relating to Vista Breeze Approximate 1.22 Acre Site located at 175 S. Shore Drive and 280 S. Shore Drive, in the City of Miami Beach, Miami-Dade County, Florida Borrower Loan Principal Amount: $_____________ Dated as of ________, 20__ All of the right, title and interest of the Housing Finance Authority of Miami-Dade County, Florida (except for its Unassigned Rights) in and to this Borrower Loan Agreement are being assigned to The Bank of New York Mellon Trust Company, N.A., as Fiscal Agent, as security for the Funding Loan made pursuant to that certain Amended and Restated Funding Loan Agreement dated as of ________, 20__ by and among the Governmental Lender, the Funding Lender named therein and the Fiscal Agent. 4894-2953-3827.5 TABLE OF CONTENTS Page ARTICLE I DEFINITIONS Section 1.1 Definitions. .......................................................................................................................... 2 ARTICLE II GENERAL Section 2.1 Origination of the Permanent Phase Borrower Loan. ....................................................... 14 Section 2.2 Security for the Funding Loan. ......................................................................................... 15 Section 2.3 Loan; the Permanent Phase Borrower Note. ..................................................................... 16 Section 2.4 Borrower Loan Payments. ................................................................................................. 16 Section 2.5 Additional Borrower Payments. ........................................................................................ 17 Section 2.6 Overdue Payments; Payments in Default. ......................................................................... 18 Section 2.7 Calculation of Interest Payments and Deposits to Real Estate Related Reserve Funds. 18 Section 2.8 Grant of Security Interest; Application of Funds. ............................................................. 18 Section 2.9 Marshalling; Payments Set Aside. .................................................................................... 18 ARTICLE III RESERVED ARTICLE IV REPRESENTATIONS AND WARRANTIES Section 4.1 Borrower Representations. ................................................................................................ 19 Section 4.2 Survival of Representations and Covenants. ..................................................................... 29 ARTICLE V AFFIRMATIVE COVENANTS Section 5.1 Existence. .......................................................................................................................... 29 Section 5.2 Taxes and Other Charges. ................................................................................................. 29 Section 5.3 Repairs; Maintenance and Compliance; Physical Condition. ........................................... 29 Section 5.4 Litigation. .......................................................................................................................... 29 Section 5.5 Performance of Other Agreements. ................................................................................... 30 Section 5.6 Notices. 30 Section 5.7 Cooperate in Legal Proceedings. ....................................................................................... 30 Section 5.8 Further Assurances. ........................................................................................................... 30 Section 5.9 Delivery of Financial Information. ................................................................................... 31 Section 5.10 Environmental Matters. ..................................................................................................... 31 Section 5.11 Title to the Project. ............................................................................................................ 31 Section 5.12 Governmental Lender’s, Fiscal Agent’s and Funding Lender’s Fees. .............................. 31 ii 4894-2953-3827.5 Section 5.13 Estoppel Statement. ........................................................................................................... 31 Section 5.14 Defense of Actions. ........................................................................................................... 32 Section 5.15 Expenses. ........................................................................................................................... 32 Section 5.16 Indemnity. ......................................................................................................................... 33 Section 5.17 No Warranty of Condition or Suitability by the Governmental Lender or Funding Lender. ............................................................................................................................. 35 Section 5.18 Right of Access to the Project. .......................................................................................... 35 Section 5.19 Notice of Default. .............................................................................................................. 35 Section 5.20 Covenant with Governmental Lender, the Fiscal Agent and the Funding Lender. ........... 35 Section 5.21 Reserved. ........................................................................................................................... 36 Section 5.22 Maintenance of Insurance. ................................................................................................ 36 Section 5.23 Information; Statements and Reports. ............................................................................... 36 Section 5.24 Additional Notices. ........................................................................................................... 37 Section 5.25 Compliance with Other Agreements; Legal Requirements. .............................................. 37 Section 5.26 Maintenance of Project. .................................................................................................... 38 Section 5.27 Fixtures. ............................................................................................................................. 38 Section 5.28 Income from Project. ......................................................................................................... 38 Section 5.29 Leases and Occupancy Agreements. ................................................................................. 38 Section 5.30 Project Agreements and Licenses. .................................................................................... 39 Section 5.31 Payment of Debt Payments. .............................................................................................. 39 Section 5.32 ERISA. ............................................................................................................................. 39 Section 5.33 Patriot Act Compliance. .................................................................................................... 39 Section 5.34 Funds from Equity Investor. ............................................................................................. 40 Section 5.35 Tax Covenants. .................................................................................................................. 40 Section 5.36 Payment of Rebate. ........................................................................................................... 44 Section 5.37 Covenants under Funding Loan Agreement. ..................................................................... 46 Section 5.38 Continuing Disclosure Agreement. ................................................................................... 47 Section 5.39 Subordinate Loans. ............................................................................................................ 47 ARTICLE VI NEGATIVE COVENANTS Section 6.1 Management Agreement. .................................................................................................. 47 Section 6.2 Dissolution. ....................................................................................................................... 47 Section 6.3 Change in Business or Operation of Property. .................................................................. 47 Section 6.4 Debt Cancellation. ............................................................................................................. 48 Section 6.5 Assets. 48 Section 6.6 Transfers. ........................................................................................................................... 48 Section 6.7 Debt. 48 Section 6.8 Assignment of Rights. ....................................................................................................... 48 Section 6.9 Principal Place of Business. .............................................................................................. 48 Section 6.10 Partnership Agreement. ..................................................................................................... 48 Section 6.11 ERISA. 48 Section 6.12 No Hedging Arrangements. .............................................................................................. 49 iii 4894-2953-3827.5 Section 6.13 Loans and Investments; Distributions; Related Party Payments. ...................................... 49 Section 6.15 Personal Property. ............................................................................................................. 49 Section 6.16 Fiscal Year. ....................................................................................................................... 49 Section 6.17 Publicity. ........................................................................................................................... 49 Section 6.18 Subordinate Loan Documents. .......................................................................................... 50 Section 6.19 Ground Lease. ................................................................................................................... 50 ARTICLE VII RESERVED ARTICLE VIII DEFAULTS Section 8.1 Events of Default. ............................................................................................................. 50 Section 8.2 Remedies. .......................................................................................................................... 53 ARTICLE IX SPECIAL PROVISIONS Section 9.1 Sale of Note and Secondary Market Transaction. ............................................................. 56 ARTICLE X MISCELLANEOUS Section 10.1 Notices. 58 Section 10.2 Brokers and Financial Advisors. ....................................................................................... 62 Section 10.3 Survival. ............................................................................................................................ 62 Section 10.4 Preferences. ....................................................................................................................... 62 Section 10.5 Waiver of Notice. .............................................................................................................. 63 Section 10.6 Offsets, Counterclaims and Defenses................................................................................ 63 Section 10.7 Publicity. ........................................................................................................................... 63 Section 10.8 Construction of Documents. .............................................................................................. 63 Section 10.9 No Third Party Beneficiaries. ........................................................................................... 63 Section 10.10 Assignment. ....................................................................................................................... 64 Section 10.11 Governmental Lender, Funding Lender, Fiscal Agent and Servicer Not in Control; No Partnership. ................................................................................................................. 64 Section 10.12 Release. ............................................................................................................................. 65 Section 10.13 Term of the Amended and Restated Borrower Loan Agreement. ..................................... 65 Section 10.14 Reimbursement of Expenses. ............................................................................................ 65 Section 10.15 Permitted Contests. ........................................................................................................... 65 Section 10.16 Funding Lender Approval of Instruments and Parties. ..................................................... 66 Section 10.17 Funding Lender Determination of Facts. .......................................................................... 66 Section 10.18 Calendar Months. .............................................................................................................. 66 Section 10.19 Determinations by Lender. ................................................................................................ 66 Section 10.20 Governing Law. ................................................................................................................ 66 Section 10.21 Consent to Jurisdiction and Venue. ................................................................................... 66 iv 4894-2953-3827.5 Section 10.22 Successors and Assigns. .................................................................................................... 66 Section 10.23 Severability. ...................................................................................................................... 67 Section 10.24 Entire Agreement; Amendment and Waiver. .................................................................... 67 Section 10.25 Counterparts. ..................................................................................................................... 67 Section 10.26 Captions. ........................................................................................................................... 67 Section 10.27 Servicer. ............................................................................................................................ 67 Section 10.28 Beneficiary Parties as Third Party Beneficiary. ................................................................ 67 Section 10.29 Waiver of Trial by Jury. .................................................................................................... 67 Section 10.30 Time of the Essence. ......................................................................................................... 68 Section 10.31 Reference Date. ................................................................................................................. 68 Section 10.32 Americans with Disabilities Act. ...................................................................................... 68 ARTICLE XI LIMITATIONS ON LIABILITY Section 11.1 Limitation on Liability. ..................................................................................................... 68 Section 11.2 Limitation on Liability of Governmental Lender. ............................................................. 68 Section 11.3 Waiver of Personal Liability. ............................................................................................ 70 Section 11.4 Limitation on Liability of Funding Lender’s Officers, Employees, Etc. .......................... 70 Section 11.5 Delivery of Reports, Etc. ................................................................................................... 71 Section 11.6 Restatement of Construction Phase Borrower Loan Agreement. ...................................... 71 Section 11.7 Electronic Transactions. .................................................................................................... 71 4894-2953-3827.5 AMENDED AND RESTATED BORROWER LOAN AGREEMENT THIS BORROWER LOAN AGREEMENT (this “Borrower Loan Agreement”) is made and entered into as of ________, 20__, by and among the HOUSING FINANCE AUTHORITY OF MIAMI- DADE COUNTY, FLORIDA (the “Governmental Lender”), a public body corporate and politic organized and existing under the laws of the State of Florida (the “State”), THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., a national banking association, duly organized and existing under the laws of the United States of America (together with any successor Fiscal Agents appointed under the Funding Loan Agreement, the “Fiscal Agent”), and VISTA BREEZE, LTD., a Florida limited partnership, duly organized and existing under the laws of the State (together with its successors and assigns permitted hereunder, the “Borrower”). RECITALS A. Pursuant to Chapter 159, Part IV, Florida Statutes, as amended, Resolution R-1194-78 adopted by the Board of County Commissioners of Miami-Dade County (the “Board”) on October 17, 1978, Ordinance No. 78-89 enacted by the Board on December 12, 1978 and Ordinance No. 11-99 enacted by the Board on December 6, 2011 (collectively, the “Act”) and the Construction Phase Borrower Loan Agreement dated as of December 1, 2023 (the “Construction Phase Borrower Loan Agreement”) by and among the Governmental Lender, the Fiscal Agent and Vista Breeze, Ltd., a Florida limited partnership, duly organized and existing under the laws of the State (the “Borrower”), the Governmental Lender made a construction period mortgage loan pursuant to the Construction Phase Borrower Loan Agreement (the “Construction Phase Borrower Loan”) to the Borrower in the maximum aggregate principal amount of $32,500,000 to provide for the financing of the acquisition, construction and equipping of a multifamily rental housing development located 175 S. Shore Drive and 280 S. Shore Drive, in the City of Miami Beach, Miami-Dade County, Florida, known as Vista Breeze (the “Project”). B. The Governmental Lender made the Construction Phase Borrower Loan to the Borrower with the proceeds received from the separate loan made to the Governmental Lender by the Initial Funding Lender pursuant to the Funding Loan Agreement in the maximum aggregate principal amount of $32,500,000 (the “Construction Phase Funding Loan”). The Construction Phase Funding Loan is evidenced by the Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) dated December 15, 2023 (together with all riders and addenda thereto, the “Governmental Lender Note”) delivered by the Governmental Lender to the Initial Funding Lender. C. The Borrower’s repayment obligations in respect of the Construction Phase Borrower Loan were by a Construction Phase Borrower Loan Note dated December 15, 2023 (together with all riders and modifications thereto, the “Construction Phase Borrower Note”) delivered to the Governmental Lender, which Construction Phase Borrower Note was endorsed by the Governmental Lender to the Fiscal Agent as security for the Construction Phase Funding Loan. D. To secure the Borrower’s obligations under the Construction Phase Borrower Note, the Borrower executed and delivered to the Governmental Lender a Mortgage, Assignment of Rents, Security Agreement and Fixture Filing dated as of December 1, 2023 (the “Security Instrument”) with respect to the Project, which Security Instrument was assigned by the Governmental Lender to the Fiscal Agent as security for the Construction Phase Funding Loan. E. The Initial Funding Lender, the Funding Lender and the Borrower entered into a Forward Purchase Agreement, dated as of December 1, 2023 (the “Forward Purchase Agreement”) pursuant to which the Funding Lender agreed to purchase the Funding Loan from the Initial Funding Lender upon the satisfaction of certain conditions, including the Conditions to Conversion. The Conditions to Conversion 2 4894-2953-3827.5 have been satisfied and the Construction Phase Borrower Loan is converting from the Construction Phase Borrower Loan to the Permanent Phase Borrower Loan on the date hereof which is the Conversion Date (the “Permanent Phase Borrower Loan”). F. In connection with the Conversion (i) the Funding Loan Agreement and this Borrower Loan Agreement are being executed and delivered and shall become effective, (ii) the Permanent Phase Borrower Note, dated the date hereof, from the Borrower to the Governmental Lender (the “Permanent Phase Borrower Note”) is being executed and delivered by the Borrower and assigned to the Funding Lender by the Governmental Lender and the Construction Phase Borrower Note is being returned to the Borrower and marked as superseded by the Permanent Phase Borrower Note, (iii) the Security Instrument is being amended and restated and (iv) the Permanent Phase Funding Loan, the Amended and Restated Borrower Loan Agreement and the Permanent Phase Borrower Note will secure the Funding Loan in substitution for the Construction Phase Funding Loan Agreement, Construction Phase Borrower Loan Agreement and Construction Project Note, respectively, which Construction Phase Funding Loan Agreement and Construction Phase Borrower Loan Agreement are simultaneously being terminated. NOW, THEREFORE, for and in consideration of the mutual covenants and representations hereinafter contained, the parties hereto agree as follows: ARTICLE I DEFINITIONS Section 1.1 Definitions. Capitalized terms not otherwise defined herein shall have the meanings provided in the Funding Loan Agreement, the Security Instrument or the Loan Covenant Agreement. The following terms, when used in this Borrower Loan Agreement (including when used in the above recitals), shall have the following meanings: “Act of Bankruptcy” shall mean the filing of a petition in bankruptcy (or any other commencement of a bankruptcy or similar proceeding) under any applicable bankruptcy, insolvency, reorganization, or similar law, now or hereafter in effect; provided that, in the case of an involuntary proceeding, such proceeding is not dismissed within ninety (90) days after the commencement thereof. “ADA” shall have the meaning set forth in Section 4.1.38 hereof. “Additional Borrower Payments” shall mean the payments payable pursuant to Section 2.5 (Additional Borrower Payments), Section 2.6 (Overdue Payments; Payments in Default) and Section 5.15 (Expenses) of this Borrower Loan Agreement; and Section 10 (Prepayments) of the Permanent Phase Borrower Note. “Agreement of Environmental Indemnification” shall mean the Agreement of Environmental Indemnification, dated as of the date hereof, executed by the Borrower and the Guarantor for the benefit of the Beneficiary Parties (as defined therein) and any lawful holder, owner or pledgee of the Permanent Phase Borrower Note from time to time. “Appraisal” shall mean an appraisal of the Project and Improvements, which appraisal shall be (i) performed by a qualified appraiser licensed in the State selected by the Funding Lender, and (ii) satisfactory to the Funding Lender (including, without limitation, as adjusted pursuant to any internal review thereof by the Funding Lender) in all respects. “Authorized Borrower Representative” shall mean a person at the time designated and authorized to act on behalf of the Borrower by a written certificate furnished to the Governmental Lender, the Funding 3 4894-2953-3827.5 Lender, the Fiscal Agent and the Servicer and containing the specimen signature of such person and signed on behalf of the Borrower by its Borrower Controlling Entity which certificate may designate one or more alternates. “Bankruptcy Code” shall mean the United States Bankruptcy Reform Act of 1978, as amended from time to time, or any substitute or replacement legislation. “Bankruptcy Event” shall have the meaning given to that term in the Security Instrument. “Bankruptcy Proceeding” shall have the meaning set forth in Section 4.1.8 hereof. “Beneficiary Parties” shall mean, collectively, the Fiscal Agent, the Governmental Lender and the Funding Lender. “Borrower” shall have the meaning set forth in the recitals to this Borrower Loan Agreement. “Borrower Affiliate” shall mean, as to the Borrower, the General Partner or the Guarantor, (i) any entity that directly or indirectly owns, controls, or holds with power to vote, 20 percent or more of the outstanding voting securities of Borrower, the General Partner or the Guarantor, (ii) any corporation 20 percent or more of whose outstanding voting securities are directly or indirectly owned, controlled or held with power to vote by the Borrower, the General Partner or the Guarantor, (iii) any partner, shareholder or, if a limited liability company, member of Borrower, the General Partner or the Guarantor, or (iv) any other person that is related (to the third degree of consanguinity) by blood or marriage to the Borrower, the General Partner or the Guarantor (to the extent any of the Borrower, the General Partner or the Guarantor is a natural person). “Borrower Controlling Entity” shall mean, if the Borrower is a partnership, any general partner or managing general partner of the Borrower, or if the Borrower is a limited liability company, the manager or authorized member of the Borrower, or if the Borrower is a not-for-profit corporation, the members or directors thereof, as applicable. “Borrower Loan Documents” shall mean this Borrower Loan Agreement, the Loan Covenant Agreement, the Permanent Phase Borrower Note, the Security Instrument, the Agreement of Environmental Indemnification, the Guaranty, the Replacement Reserve Agreement, the Governmental Lender Guaranties and all other documents or agreements evidencing or relating to the Permanent Phase Borrower Loan. “Borrower Loan Payment Date” shall mean (i) the date upon which regularly scheduled Borrower Loan Payments are due pursuant to the Permanent Phase Borrower Note, or (ii) any other date on which the Permanent Phase Borrower Note is prepaid or paid, whether at the scheduled maturity or upon the acceleration of the maturity thereof. “Borrower Loan Payments” shall mean the monthly loan payments payable pursuant to the Permanent Phase Borrower Note. “Borrower Payment Obligations” shall mean all payment obligations of the Borrower under the Borrower Loan Documents, including, but not limited to, the Permanent Phase Borrower Loan Payments and the Additional Borrower Payments. “Business Day” shall mean any day other than (i) a Saturday or Sunday, or (ii) a day on which the offices of the Fiscal Agent in Jacksonville, Florida, or federally insured depository institutions in New York, 4 4894-2953-3827.5 New York are authorized or obligated by law, regulation, governmental decree or executive order to be closed. “Calendar Month” shall mean each of the twelve (12) calendar months of the year. “CC&R’s” shall mean any covenants, conditions, restrictions, maintenance agreements or reciprocal easement agreements affecting the Project or the Mortgaged Property. “City HOME Loan” means the subordinate loan in the aggregate principal amount of $1,003,969 made by City of Miami Beach, Florida to the Borrower, as evidenced by the City Home Loan Documents. “City HOME Loan Documents” means, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the City HOME Loan or executed and delivered by the Borrower in connection with the City HOME Loan. “Code” shall mean the Internal Revenue Code of 1986, as in effect on the Delivery Date or (except as otherwise referenced herein) as it may be amended to apply to obligations issued on the Delivery Date, together with applicable proposed, temporary and final regulations promulgated (the “Regulations”), and applicable official public guidance published, under the Code. “Collateral” shall mean all collateral described in (i) this Borrower Loan Agreement (including, without limitation, all property in which the Governmental Lender and/or the Funding Lender is granted a security interest pursuant to any provision of this Borrower Loan Agreement), (ii) the Security Instrument, or (iii) any other Security Document which collateral shall include the Project, all of which collateral (exclusive of the Unassigned Rights) is pledged and assigned to the Funding Lender under Funding Loan Agreement to secure the Funding Loan. “Compliance Monitoring Fee” means a compliance monitoring fee in an annual amount equal to $30.00 per rental unit in the Project (subject to adjustment from time to time by the Governmental Lender) to be paid by the Borrower to the Governmental Lender on an annual basis during the Qualified Project Period (as defined in the Regulatory Agreement) or for such longer period if the set-aside requirements required by the Code, the Act or other Governmental Lender requirements remain in force. “Computation Date” shall have the meaning ascribed thereto in Section 1.148-3(e) of the Regulations. “Condemnation” shall mean any action or proceeding or notice relating to any proposed or actual condemnation or other taking, or conveyance in lieu thereof, of all or any part of the Project, whether direct or indirect. “Conditions to Conversion” shall have the meaning given to such term in the Forward Purchase Agreement. “Continuing Disclosure Agreement” shall mean that certain Continuing Disclosure Agreement dated as of _________, 20__, by and between the Borrower and the Funding Lender, pursuant to which the Borrower agrees to provide certain information with respect to the Project, the Borrower and the Funding Loan subsequent to the Conversion Date, as amended, supplemented or restated from time to time. “Contractual Obligation” shall mean, for any Person, any debt or equity security issued by that Person, and any indenture, mortgage, deed of trust, contract, undertaking, instrument or agreement (written or oral) to which such Person is a party or by which it is bound, or to which it or any of its assets is subject. 5 4894-2953-3827.5 “Conversion Date” shall mean ______, 20__, the date on which the Funding Lender purchases the Governmental Lender Note from the Initial Funding Lender and assumes the role of the Funding Lender under the Funding Loan Documents. “County” shall mean Miami-Dade County, Florida. “County Authorization” shall have the meaning given to that term in the recitals to this Borrower Loan Agreement. “Day” or “Days” shall mean calendar days unless expressly stated to be Business Days. “Debt” shall mean, as to any Person, any of such Person’s liabilities, including all indebtedness (whether recourse and nonrecourse, short term and long term, direct and contingent), all committed and unfunded liabilities, and all unfunded liabilities, that would appear upon a balance sheet of such Person prepared in accordance with GAAP. “Default Rate” shall have the meaning given to that term in the Permanent Phase Borrower Note. “Delivery Date” shall mean the date of issuance and delivery of the Governmental Lender Note. “Determination of Taxability” shall mean (i) a determination by the Commissioner or any District Director of the Internal Revenue Service, (ii) a private ruling or Technical Advice Memorandum concerning the Governmental Lender Note issued by the National Office of the Internal Revenue Service in which the Governmental Lender and Borrower were afforded the opportunity to participate, (iii) a determination by any court of competent jurisdiction, (iv) the enactment of legislation or (v) receipt by the Funding Lender, at the request of the Governmental Lender, the Borrower or the Funding Lender, of an opinion of Tax Counsel, in each case to the effect that the interest on the Governmental Lender Note is includable in gross income for federal income tax purposes of any holder or any former holder of all or a portion of the Governmental Lender Note, other than a holder who is a “substantial user” of the Project or a “related person” (as such terms are defined in Section 147(a) of the Code); provided, however, that no such Determination of Taxability under clause (i) or (iii) shall be deemed to have occurred if the Governmental Lender (at the sole expense of the Borrower) or the Borrower is contesting such determination, has elected to contest such determination in good faith and is proceeding with all applicable dispatch to prosecute such contest until the earliest of (a) a final determination from which no appeal may be taken with respect to such determination, (b) abandonment of such appeal by the Governmental Lender or the Borrower, as the case may be, or (c) one year from the date of initial determination. “Developer” shall mean APC Vista Breeze Development, LLC and HACMB Development, LLC, each a Florida limited liability company, and its respective successors and assigns. “ELI Loan” means the subordinate loan in the aggregate principal amount of $___________ made by Florida Housing Finance Corporation to the Borrower, as evidenced by the ELI Loan Documents. “ELI Loan Documents” means, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the ELI Loan or executed and delivered by the Borrower in connection with the ELI Loan. “Equipment” shall have the meaning given to the term “Personalty” in the Security Instrument. “Equity Contributions” shall mean the equity to be contributed by the Equity Investor to Borrower, in accordance with and subject to the terms of the Partnership Agreement. 6 4894-2953-3827.5 “Equity Investor” shall mean Bank of America, N.A., a national association, as a limited partner of the Borrower, and its permitted successors and assigns. “ERISA” shall mean the Employment Retirement Income Security Act of 1974, as amended from time to time, and the rules and regulations promulgated thereunder. “ERISA Affiliate” shall mean all members of a controlled group of corporations and all trades and business (whether or not incorporated) under common control and all other entities which, together with the Borrower, are treated as a single employer under any or all of Section 414(b), (c), (m) or (o) of the Code. “Event of Default” shall mean any Event of Default set forth in Section 8.1 of this Borrower Loan Agreement. An Event of Default shall “exist” if a Potential Default shall have occurred and be continuing beyond any applicable cure period. “Excess Revenues” shall have the meaning ascribed thereto in Section 2.2(e) hereof. “Exchange Act” shall mean the Securities Exchange Act of 1934, as amended. “Expenses of the Project” shall mean, for any period, the current expenses, paid or accrued, for the operation, maintenance and current repair of the Project, as calculated in accordance with GAAP, and shall include, without limiting the generality of the foregoing, salaries, wages, employee benefits, cost of materials and supplies, costs of routine repairs, renewals, replacements and alterations occurring in the usual course of business, costs and expenses properly designated as capital expenditures (e.g. repairs which would not be payable from amounts on deposit in a repair and replacement fund held pursuant to the Borrower Loan Documents), a management fee (however characterized) not to exceed the Underwritten Management Fee, costs of billings and collections, costs of insurance, and costs of audits. Expenses of the Project shall not include any payments, however characterized, on account of any subordinate financing in respect of the Project or other indebtedness, allowance for depreciation, amortization or other non-cash items, gains and losses or prepaid expenses not customarily prepaid. “Fair Market Value” shall mean the price at which a willing buyer would purchase the investment from a willing seller in a bona fide, arm’s length transaction (determined as of the date the contract to purchase or sell the investment becomes binding) if the investment is traded on an established securities market (within the meaning of Section 1273 of the Code) and, otherwise, the term “Fair Market Value” means the acquisition price in a bona fide arm’s length transaction (as referenced above) if (i) the investment is a certificate of deposit that is acquired in accordance with applicable regulations under the Code, (ii) the investment is an agreement with specifically negotiated withdrawal or reinvestment provisions and a specifically negotiated interest rate (for example, a guaranteed investment contract, a forward supply contract or other investment agreement) that is acquired in accordance with applicable regulations under the Code, (iii) the investment is a United States Treasury Security State and Local Government Series that is acquired in accordance with applicable regulations of the United States Bureau of Public Debt, or (iv) the investment is an interest in any commingled investment fund in which the Governmental Lender and related parties do not own more than a ten percent (10%) beneficial interest therein if the return paid by the fund is without regard to the source of investment. “Fee Guaranty and Environmental Indemnity Agreement” means the Fee Guaranty and Environmental Indemnity Agreement, dated as of the date of this Borrower Loan Agreement, by Governmental Lender Guarantors for the benefit of the Governmental Lender and the Fiscal Agent. 7 4894-2953-3827.5 “Fiscal Agent” shall mean the fiscal agent from time to time under and pursuant to the Funding Loan Agreement. Initially, the Fiscal Agent is The Bank of New York Mellon Trust Company, N.A. “Funding Lender” shall mean Citibank, N.A., a national banking association, in its capacity as lender under the Funding Loan, and its successors and assigns. “Funding Loan” means the Funding Loan made by the Initial Funding Lender to the Governmental Lender under the Funding Loan Agreement, which Funding Loan has been purchased by the Funding Lender on the date hereof in a principal amount of $_______. “Funding Loan Agreement” means the Amended and Restated Funding Loan Agreement dated of even date herewith, by and among the Governmental Lender, the Fiscal Agent and the Funding Lender, as it may from time to time be supplemented, modified or amended by one or more amendments or other instruments supplemental thereto entered into pursuant to the applicable provisions thereof. “Funding Loan Documents” shall have the meaning given to that term in the Funding Loan Agreement. “GAAP” shall mean generally accepted accounting principles as in effect on the date of the application thereof and consistently applied throughout the periods covered by the applicable financial statements. “General Partner” shall mean (i) Vista Breeze HACMB, Inc., a Florida not for profit corporation, and/or (ii) any other Person as otherwise permitted with the Funding Lender’s approval pursuant to the Borrower Loan Documents. “Governmental Authority” shall mean (i) any governmental municipality or political subdivision thereof, (ii) any governmental or quasi-governmental agency, authority, board, bureau, commission, department, instrumentality or public body, or (iii) any court, administrative tribunal or public utility, agency, commission, office or authority of any nature whatsoever for any governmental unit (federal, state, county, district, municipal, city or otherwise), now or hereafter in existence. “Governmental Lender” shall have the meaning set forth in the recitals to this Borrower Loan Agreement. “Governmental Lender Guaranties” means, collectively, (i) the Continuing, Absolute and Unconditional Guaranty of Recourse Obligations, and (ii) the Fee Guaranty and Environmental Indemnity Agreement, each dated as of December1, 2023, by the Governmental Lender Guarantors for the benefit of the Governmental Lender and the Fiscal Agent. “Governmental Lender Guarantors” means, collectively, the Borrower, APC Vista Breeze, LLC, a Florida limited liability company, Vista Breeze HACMB, Inc., a Florida not for profit corporation, Atlantic Pacific Communities, LLC, a Delaware limited liability company, APC Vista Breeze Development, LLC, a Florida limited liability company, HACMB Development, LLC, a Florida limited liability company, Howard D. Cohen Revocable Trust Under Agreement Dated 4/6/1993, and Howard D. Cohen, individually. “Governmental Lender Note” shall mean that certain Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) dated December 15, 2023, in the principal maximum amount of $32,500,000, made by the Governmental Lender and payable to the Funding Lender, as it may be amended, supplemented or replaced from time to time, as purchased by the Funding Lender on the Conversion Date in the principal amount of $__________. 8 4894-2953-3827.5 “Gross Income” shall mean all receipts, revenues, income and other moneys received or collected by or on behalf of the Borrower and derived from the ownership or operation of the Project, if any, and all rights to receive the same, whether in the form of accounts, accounts receivable, contract rights or other rights, and the proceeds of such rights, and whether now owned or held or hereafter coming into existence and proceeds received upon the foreclosure sale of the Project. Gross Income shall not include loan proceeds, equity or capital contributions, or tenant security deposits being held by the Borrower in accordance with applicable law. “Gross Proceeds” shall mean, without duplication, the aggregate of: (a) the net amount (after payment of all expenses of originating the Funding Loan) of Funding Loan proceeds received by the Governmental Lender as a result of the origination of the Funding Loan; (b) all amounts received by the Governmental Lender as a result of the investment of the Funding Loan proceeds; (c) any amounts held in any fund or account to the extent that the Governmental Lender reasonably expects to use the amounts in such fund to pay any portion of the Funding Loan; and (d) any securities or obligations pledged by the Governmental Lender or by the Borrower as security for the payment of any portion of the Funding Loan. “Ground Lease” shall mean the Second Amended and Restated Ground Lease, dated December 15, 2023, between the Housing Authority of the City of Miami Beach, Florida, as landlord and the Borrower, as tenant. “Guarantor” shall mean, the Borrower, or any other person or entity which may hereafter become a guarantor of any of the Borrower’s obligations under the Permanent Phase Borrower Loan and the Governmental Lender Guarantors with respect to the Governmental Lender Guaranties. “Guaranty” shall mean the Exceptions to Non-Recourse Guaranty, dated as of the date of this Borrower Loan Agreement, by Guarantor for the benefit of the Beneficiary Parties. “HACMB Loan” means the loan made by the Housing Authority of the City of Miami Beach, Florida to the Borrower with respect to the Project in the principal amount of $________ pursuant to the HACMB Loan Documents. “HACMB Loan Documents” means collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the HACMB Loan or executed and delivered by the Borrower in connection with the HACMB Loan. “Indemnified Party” shall have the meaning set forth in Section 5.16 hereof. “Installment Computation Date” shall mean any Computation Date other than the first Computation Date or the final Computation Date. “Interest Rate” shall mean, with respect to the Permanent Phase Borrower Note, the rate of interest accruing on such Permanent Phase Borrower Note pursuant to the terms thereof. “Land” means the real property described on Exhibit A to the Security Instrument. 9 4894-2953-3827.5 “Late Charge” shall mean the amount due and payable as a late charge on overdue payments under the Permanent Phase Borrower Note, as provided in Section 7 of the Permanent Phase Borrower Note and Section 2.5(a)(v) hereof. “Legal Action” shall mean an action, suit, investigation, inquiry, proceeding or arbitration at law or in equity or before or by any foreign or domestic court, arbitrator or other Governmental Authority. “Legal Requirements” shall mean statutes, laws, rules, orders, regulations, ordinances, judgments, decrees and injunctions of Governmental Authorities affecting all or part of the Project or any property (including the Project) or the construction, rehabilitation, use, alteration or operation thereof, whether now or hereafter enacted and in force, and all permits, licenses and authorizations and regulations relating thereto, and all covenants, agreements, restrictions and encumbrances contained in any instrument, either of record or known to the Borrower, at any time in force affecting all or part of the Project, including any that may (i) require repairs, modifications or alterations in or to all or part of the Project, or (ii) in any way limit the use and enjoyment thereof. “Liabilities” shall have the meaning set forth in Section 5.16 hereof. “Licenses” shall mean all rights, licenses, permits, franchises, authorizations, approvals and agreements relating to use, occupancy, operation or leasing of the Project or the Mortgaged Property. “Lien” shall mean any interest, or claim thereof, in the Project securing an obligation owed to, or a claim by, any Person other than the owner of the Project, whether such interest is based on common law, statute or contract, including the lien or security interest arising from a deed of trust, mortgage, deed to secure debt, assignment, encumbrance, pledge, security agreement, conditional sale or trust receipt or a lease, consignment or bailment for security purposes. The term “Lien” shall include reservations, exceptions, encroachments, easements, rights of way, covenants, conditions, restrictions, leases and other title exceptions and encumbrances affecting the Project. “Management Agreement” shall mean the Management Agreement between the Borrower and the Property Manager, pursuant to which the Property Manager is to manage the Project, as same may be amended, restated, replaced, supplemented or otherwise modified from time to time. “Material Adverse Change” means any set of circumstances or events which (a) has or could reasonably be expected to have any material adverse effect whatsoever upon the validity or enforceability of this Borrower Loan Agreement or any other Borrower Loan Document; (b) is or could reasonably be expected to be material and adverse to the business, properties, assets, financial condition, or results of operations of the Borrower, General Partner, Guarantor or the Mortgaged Property; (c) could reasonably be expected to impair materially the ability of the Borrower, General Partner or Guarantor to duly and punctually pay or perform any of their respective obligations under any of the Borrower Loan Documents to which they are a party; or (d) impairs materially or could reasonably be expected to impair materially any rights of or benefits available to the Governmental Lender or the Fiscal Agent under this Borrower Loan Agreement or any other Borrower Loan Document, including, without limitation, the ability of Governmental Lender or the Fiscal Agent or, upon the assignment of the Permanent Phase Borrower Loan to it, of the Funding Lender, to the extent permitted, to enforce its legal remedies pursuant to this Borrower Loan Agreement or any other Borrower Loan Document. “Moody’s” shall mean Moody’s Investors Service, Inc., or its successor. “Mortgaged Property” shall have the meaning given to that term in the Security Instrument. 10 4894-2953-3827.5 “NHTF Loan” means the subordinate loan in the aggregate principal amount of $___________ made by Florida Housing Finance Corporation to the Borrower, as evidenced by the NHTF Loan Documents. “NHTF Loan Documents” means, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the NHTF Loan or executed and delivered by the Borrower in connection with the NHTF Loan. “Nonpurpose Investment” shall mean any investment property (as defined in Section 148(b) of the Code) that is acquired with the Gross Proceeds of the Funding Loan, and which is not acquired to carry out the governmental purpose of the Funding Loan. “Other Charges” shall mean all maintenance charges, impositions other than Taxes, and any other charges, including vault charges and license fees for the use of vaults, chutes and similar areas adjoining the Project, now or hereafter levied or assessed or imposed against the Project or any part thereof. “Partnership Agreement” shall mean that certain Amended and Restated Agreement of Limited Partnership of the Borrower dated the Delivery Date, as the same may be amended, restated or modified in accordance with its terms. “Patriot Act” shall mean the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT ACT) of 2001, as the same may be amended from time to time, and corresponding provisions of future laws. “Patriot Act Offense” shall have the meaning set forth in Section 4.1.48 hereof. “Permanent Phase Borrower Loan” shall mean the leasehold mortgage loan made by the Governmental Lender to the Borrower pursuant to this Borrower Loan Agreement, in the principal amount of $___________, as evidenced by the Permanent Phase Borrower Note as of the Conversion Date. “Permanent Phase Borrower Loan Amount” shall mean $______________, the aggregate original maximum principal amount of the Permanent Phase Borrower Note. “Permitted Encumbrances” shall have the meaning given to that term in the Security Instrument. “Permitted Lease” shall mean a lease and occupancy agreement pursuant to the form approved by Funding Lender, to a residential tenant in compliance with the Legal Requirements, providing for an initial term of not less than six (6) months nor more than two (2) years. “Person” shall mean a natural person, a partnership, a joint venture, an unincorporated association, a limited liability company, a corporation, a trust, any other legal entity, or any Governmental Authority. “Plan” shall mean (i) an employee benefit or other plan established or maintained by the Borrower or any ERISA Affiliate or to which the Borrower or any ERISA Affiliate makes or is obligated to make contributions and (ii) which is covered by Title IV of ERISA or Section 302 of ERISA or Section 412 of the Code. “Potential Default” shall mean the occurrence of an event which, under this Borrower Loan Agreement or any other Borrower Loan Document, would, but for the giving of notice or the passage of time, or both, be an Event of Default. 11 4894-2953-3827.5 “Prepayment Premium” shall mean any premium payable by the Borrower pursuant to the Borrower Loan Documents in connection with a prepayment of the Permanent Phase Borrower Note (including any prepayment premium as set forth in the Permanent Phase Borrower Note). “Project” shall mean the Mortgaged Property and Improvements thereon owned by the Borrower and encumbered by the Security Instrument, together with all rights pertaining to such real property and Improvements, as more particularly described in the Granting Clauses of the Security Instrument and referred to therein as the “Mortgaged Property.” “Project Agreements and Licenses” shall mean any and all Construction Contracts, Engineer’s Contracts and Management Agreements, and all other rights, licenses, permits, franchises, authorizations, approvals and agreements relating to use, occupancy, operation or leasing of the Project or the Mortgaged Property. “Property Manager” shall mean Atlantic Pacific Community Management, LLC, or any other management company to be employed by the Borrower and approved by the Funding Lender in accordance with the terms of the Security Instrument, this Borrower Loan Agreement or any of the other Borrower Loan Documents. “Provided Information” shall have the meaning set forth in Section 9.1.1(a) hereof. “Qualified Project Costs” shall mean costs paid with respect to the Project that meet each of the following requirements: (i) the costs are properly chargeable to capital account (or would be so chargeable with a proper election by the Borrower or but for a proper election by the Borrower to deduct such costs) in accordance with general federal income tax principles and in accordance with Section 1.103-8(a)(1) of the Regulations, provided, however, that only such portion of the interest accrued during rehabilitation or construction of the Project (in the case of rehabilitation, with respect to vacated units only) shall be eligible to be a Qualified Project Cost as bears the same ratio to all such interest as the Qualified Project Costs bear to all costs of the acquisition and construction or rehabilitation of the Project; and provided further that interest accruing after the date of completion of the Project shall not be a Qualified Project Cost; and provided still further that if any portion of the Project is being constructed or rehabilitated by an Affiliate (whether as general contractor or a subcontractor), Qualified Project Costs shall include only (A) the actual out of pocket costs incurred by such affiliate in constructing or rehabilitating the Project (or any portion thereof), (B) any reasonable fees for supervisory services actually rendered by such affiliate, and (C) any overhead expenses incurred by such affiliate which are directly attributable to the work performed on the Project, and shall not include, for example, intercompany profits resulting from members of an “affiliated group” (within the meaning of Section 1504 of the Code) participating in the rehabilitation or construction of the Project or payments received by such affiliate due to early completion of the Project (or any portion thereof); (ii) the costs are paid with respect to a qualified residential rental project or projects within the meaning of Section 142(d) of the Code, (iii) the costs are paid after the earlier of 60 days prior to March 28, 2022, being the date on which the Governmental Lender first declared its “official intent” to reimburse costs paid with respect to the Project (within the meaning of Section 1.150-2 of the Regulations) or the date or dates of issue of the Funding Loan, and (iv) if the costs of the acquisition and construction or rehabilitation of the Project were previously paid and are to be reimbursed with proceeds of the Funding Loan such costs were (A) “preliminary expenditures” (within the meaning of Section 1.150-2(f)(2) of the Regulations) with respect to the Project (such as architectural, engineering and soil testing services) incurred before commencement of acquisition and construction or rehabilitation of the Project that do not exceed twenty percent (20%) of the issue price of the Funding Loan (as defined in Section 1.148-1 of the Regulations), or (B) were capital expenditures with respect to the Project that are reimbursed no later than 18 months after the later of the date the expenditure was paid or the date the Project is placed in service (but no later than three years after the expenditures is paid); provided, however, that (w) costs of issuance 12 4894-2953-3827.5 shall not be deemed to be Qualified Project Costs; (x) fees, charges or profits (including, without limitation, developer fees) payable to the Borrower or a “related person” (within the meaning of Section 144(a)(3) of the Code) shall not be deemed to be Qualified Project Costs; (y) letter of credit fees and municipal bond insurance premiums which represent a transfer of credit risk shall be allocated between Qualified Project Costs and other costs and expenses to be paid from the proceeds of the Funding Loan; and (z) letter of credit fees and municipal bond insurance premiums which do not represent a transfer of credit risk (including, without limitation, letter of credit fees payable to a “related person” to the Borrower) shall not constitute Qualified Project Costs. “Rebate Amount” shall mean, for any given period, the amount determined by the Rebate Analyst as required to be rebated or paid as a yield reduction payment to the United States of America with respect to the Funding Loan. “Rebate Analyst” shall mean the rebate analyst, if any, selected by the Borrower pursuant to Section 5.35(d) and acceptable to the Governmental Lender and the Funding Lender. The initial Rebate Analyst shall be __________________. “Rebate Analyst’s Fee” shall mean the annual fee of the Rebate Analyst payable by the Borrower to the Rebate Analyst. “Rebate Fund” shall mean the Rebate Fund created pursuant to Section 5.36(b) hereof. “Regulations” shall have the meaning given to the term in the definition of the “Code” in this Section 1.2. “Regulatory Agreement” shall mean that certain Land Use Restriction Agreement, dated as of the date hereof, among the Governmental Lender, the Fiscal Agent and the Borrower. “Related Documents” shall mean, collectively, any agreement or other document (other than the Borrower Loan Documents) granting a security interest (including each agreement that is the subject of any Borrower Loan Document), the Partnership Agreement, and any other agreement, instrument or other document (not constituting a Borrower Loan Document) relating to or executed in connection with the transactions contemplated by this Borrower Loan Agreement. “Replacement Reserve Agreement” shall mean any Replacement Reserve Agreement between the Borrower and the Funding Lender, as the same may be amended, restated or supplemented from time to time. “Replacement Reserve Fund Requirement” means the Borrower’s funding obligations from time to time under the Replacement Reserve Agreement. “Resolution” shall mean the resolution of the Governmental Lender authorizing the Funding Loan, as evidenced by the Governmental Lender Note and the execution and delivery of the Funding Loan Documents to which the Governmental Lender is a party. “Review Fee” shall mean the three thousand dollar ($3,000) fee payable to Funding Lender in connection with the review of requests from the Borrower in connection with events requiring the consent and/or approval of the Funding Lender, including, but not limited to, subordinate financings and easements. “SAIL Loan” means the subordinate loan in the aggregate principal amount of $___________ made by Florida Housing Finance Corporation to the Borrower, as evidenced by the SAIL Loan Documents. 13 4894-2953-3827.5 “SAIL Loan Documents” means, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the SAIL Loan or executed and delivered by the Borrower in connection with the SAIL Loan. “Secondary Market Disclosure Document” shall have the meaning set forth in Section 9.1.2 hereof. “Secondary Market Transaction” shall have the meaning set forth in Section 9.1.1 hereof. “Securities” shall have the meaning set forth in Section 9.1.1 hereof. “Securities Act” shall mean the Securities Act of 1933, as amended. “Security Documents” shall mean the Security Instrument, the Replacement Reserve Agreement, the Collateral Agreements, the Collateral Assignments, this Borrower Loan Agreement, the Guaranty, the Governmental Lender Guarantees, the Agreement of Environmental Indemnification, and such other security instruments that Funding Lender may reasonably request. “Security Instrument” shall have the meaning set forth in the recitals to this Borrower Loan Agreement. “Servicer” shall mean the servicer contracting with or appointed by the Funding Lender to service the Permanent Phase Borrower Loan. The initial Servicer shall be Citibank, N.A. “Servicing Agreement” shall mean any servicing agreement or master servicing agreement, between the Servicer and the Funding Lender relating to the servicing of the Permanent Phase Borrower Loan and any amendments thereto or any replacement thereof. “Standard & Poor’s” or “S&P” shall mean S&P Global Ratings, its successors and assigns. “State” shall mean the State of Florida. “Submission Date” shall have the meaning assigned to such term in the Partnership Agreement. “Subordinate Lender” shall mean, as applicable with respect to the Subordinate Loans, Miami- Dade County, Florida, Florida Housing Finance Corporation and the City of Miami Beach, Florida. “Subordinate Loans” shall mean collectively, the City HOME Loan, the ELI Loan, the NHTF Loan, the Viability Loan, the SAIL Loan, the HACMB Loan and the Surtax Loan. “Subordinate Loan Documents” shall mean the Surtax Loan Documents, the City HOME Loan Documents, the SAIL Loan Documents, the HACMB Loan Documents and the Viability Loan Documents. “Surtax Loan” means the subordinate loan in the aggregate principal amount of $___________ made by Miami-Dade County to the Borrower, as evidenced by the Surtax Loan Documents. “Surtax Loan Documents” means, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the Surtax Loan or executed and delivered by the Borrower in connection with the Surtax Loan. “Tax Counsel” shall have the meaning set forth in the Funding Loan Agreement. 14 4894-2953-3827.5 “Taxes” shall mean all real estate and personal property taxes, assessments, water rates or sewer rents, now or hereafter levied or assessed or imposed against all or part of the Project. “Term” shall mean the term of this Borrower Loan Agreement pursuant to Section 10.13. “Title Company” means Chicago Title Insurance Company. “Title Insurance Policy” shall mean the mortgagee title insurance policy, or marked title insurance commitment, in form acceptable to the Funding Lender, issued with respect to the Mortgaged Property and insuring the lien of the Security Instrument. “Transfer” shall have the meaning given to that term in the Security Instrument. “UCC” shall mean the Uniform Commercial Code as in effect in the State. “Underwritten Management Fee” shall have the meaning set forth in the Loan Covenant Agreement. “Unit” shall mean a residential apartment unit within the Improvements. “Viability Loan” means the subordinate loan in the aggregate principal amount of $___________ made by Florida Housing Finance Corporation to the Borrower. “Viability Loan Documents” means, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the Viability Loan or executed and delivered by the Borrower in connection with the Viability Loan. “Written Consent” and “Written Notice” shall mean a written consent or notice signed by an Authorized Borrower Representative or an authorized representative of the Governmental Lender or the Funding Lender, as appropriate. ARTICLE II GENERAL Section 2.1 Origination of the Permanent Phase Borrower Loan. In order to provide funds for the purposes provided in the Construction Phase Borrower Loan Agreement and herein, the Governmental Lender, pursuant to the County Authorization and in accordance with the Act, entered into the Construction Phase Funding Loan Agreement and accepted the Funding Loan from the Initial Funding Lender. The proceeds of the Funding Loan were advanced by the Initial Funding Lender to the Fiscal Agent for payment to or for the benefit of the Borrower in accordance with the terms of the Construction Phase Funding Loan Agreement and the Construction Phase Borrower Loan Agreement. Upon the purchase of the Governmental Lender Note by the funding Lender on the Conversion Date, the Permanent Phase Borrower Loan will be governed by this Borrower Loan Agreement, which amends and restates the Construction Phase Borrower Loan Agreement in its entirety. The Governmental Lender hereby appoints the Funding Lender as its agent with full authority and power to act on its behalf to take certain actions and exercise certain remedies with respect to the Permanent Phase Borrower Loan, and for the other purposes set forth in this Borrower Loan Agreement and to do all other acts necessary or incidental to the performance and execution thereof (in all cases other than actions relating to Unassigned Rights). This appointment is coupled with an interest and is irrevocable except as expressly set forth herein. Accordingly, references to the rights of the Funding Lender to take actions under 15 4894-2953-3827.5 this Borrower Loan Agreement shall refer to Funding Lender in its role as agent of the Governmental Lender. The Funding Lender may designate Servicer to fulfill the rights and responsibilities granted by Governmental Lender to Funding Lender pursuant to this Section 2.1. Section 2.2 Security for the Funding Loan. (a) As security for the Funding Loan, the Governmental Lender has pledged and assigned to the Funding Lender under and pursuant to the Funding Loan Agreement (a) the Permanent Phase Borrower Note and all of its right, title and interest in and to this Borrower Loan Agreement and the Borrower Loan Documents (except for the Unassigned Rights) and all revenues and receipts therefrom and the security therefor (including the Security Instrument) and (b) the amounts on deposit from time to time in any and all funds established under the Funding Loan Agreement other than the Rebate Fund and Expense Fund created and established thereunder. All revenues and assets pledged and assigned thereby shall immediately be subject to the lien of such pledge without any physical delivery thereof or any further act, except in the case of the Permanent Phase Borrower Note, which shall be delivered to the Funding Lender. The Borrower hereby acknowledges and consents to such assignment to the Funding Lender. (b) With respect to the Unassigned Rights, subject to the limitations set forth in this Section 2.2, the Governmental Lender may: (i) Tax Covenants. Seek specific performance of, and enforce, the tax covenants of the Funding Loan Agreement, the Regulatory Agreement, the Tax Certificate and this Borrower Loan Agreement, seek injunctive relief against acts which may be in violation of any of the tax covenants, and enforce the Borrower’s obligation to pay amounts for credit to the Rebate Fund; and (ii) Regulatory Agreement. Seek specific performance of the obligations of the Borrower or any other owner of the Project under the Regulatory Agreement and injunctive relief against acts which may be in violation of the Regulatory Agreement or otherwise in accordance with the provisions of the Regulatory Agreement; provided, however, that the Governmental Lender may enforce any right it may have under the Regulatory Agreement for monetary damages (which term shall not be deemed to include fees, expenses and indemnification obligations payable by the Borrower to the Governmental Lender or Fiscal Agent under the Regulatory Agreement, the Funding Loan Agreement or this Borrower Loan Agreement) only against Excess Revenues (defined below), if any, of the Borrower, unless the Funding Lender otherwise specifically consents in writing to the use of other funds; and (iii) Unassigned Rights. Take whatever action at law or in equity which appears necessary or desirable to enforce the other Unassigned Rights, provided, however, that the Governmental Lender or any person under its control may only enforce any right it may have for monetary damages (which term shall not be deemed to include fees, expenses and indemnification obligations payable by the Borrower to the Governmental Lender or Fiscal Agent under the Regulatory Agreement, the Governmental Lender Guaranties, the Governmental Lender Environmental Indemnity Agreement, the Funding Loan Agreement or this Borrower Loan Agreement) against Excess Revenues, if any, of the Borrower, unless the Funding Lender otherwise specifically consents in writing to the enforcement against other funds of the Borrower. (c) In no event shall the Governmental Lender, except at the express written direction of the Funding Lender: (i) prosecute its action to a lien on the Project; or (ii) take any action which has a substantial likelihood of or that has a result of, impairing the ability of the Borrower to timely pay the principal of, interest on, or other amounts due under, 16 4894-2953-3827.5 the Permanent Phase Borrower Loan or of causing the Borrower to file a petition seeking reorganization, arrangement, adjustment or composition of or in respect of the Borrower under any applicable liquidation, insolvency, bankruptcy, rehabilitation, composition, reorganization, conservation or other similar law in effect now or in the future; or (iii) interfere with the exercise by the Fiscal Agent, the Funding Lender or the Servicer of any of their rights under the Borrower Loan Documents upon the occurrence of an event of default by the Borrower under the Borrower Loan Documents or the Funding Loan Documents; or (iv) take any action to accelerate or otherwise enforce payment or seek other remedies with respect to the Permanent Phase Borrower Loan or the Funding Loan. (d) The Governmental Lender shall provide Written Notice to the Funding Lender and the Servicer immediately upon taking any action at law or in equity to exercise any remedy or direct any proceeding under the Borrower Loan Documents or the Funding Loan Documents. (e) As used in this Section 2.2, the term “Excess Revenues” means, for any period, the net cash flow of the Borrower available for distribution to shareholders, members or partners (as the case may be) for such period, after the payment of all interest expense, the amortization of all principal of all indebtedness coming due, including but not limited to, the Subordinate Loan, during such period (whether by maturity, mandatory sinking fund payment, acceleration or otherwise), the payment of all fees, costs and expenses on an occasional or recurring basis in connection with the Permanent Phase Borrower Loan or the Funding Loan, the payment of all operating, overhead, ownership and other expenditures of the Borrower directly or indirectly in connection with the Project (whether any such expenditures are current, capital or extraordinary expenditures), and the setting aside of all reserves for taxes, insurance, water and sewer charges or other similar impositions, capital expenditures, repairs and replacements and all other amounts which the Borrower is required to set aside pursuant to agreement, but excluding depreciation and amortization of intangibles. Section 2.3 Loan; the Permanent Phase Borrower Note. (a) As evidence of its obligation to repay the Permanent Phase Borrower Loan, simultaneously with the delivery of this Borrower Loan Agreement to the Governmental Lender, the Borrower hereby agrees to execute and deliver the Permanent Phase Borrower Note, which amends and restates the Construction Phase Borrower Note in its entirety. The Permanent Phase Borrower Loan shall mature and be payable at the times and in the amounts required under the terms hereof and of the Permanent Phase Borrower Note. The Governmental Lender shall assign the Permanent Phase Borrower Note to the Funding Lender on the Conversion Date as a condition to Conversion. Section 2.4 Borrower Loan Payments. (a) The Borrower shall make Borrower Loan Payments in accordance with the Permanent Phase Borrower Note. Each Borrower Loan Payment made by the Borrower shall be made in funds immediately available to the Servicer by 2:00 p.m., New York City time, on the date that is two (2) Business Days prior to the Borrower Loan Payment Date. Each such payment shall be made to the Fiscal Agent or Servicer, as applicable, by deposit to such account as the Fiscal Agent or Servicer, as applicable, may designate by Written Notice to the Borrower. Whenever any Borrower Loan Payment shall be stated to be due on a day that is not a Business Day, such payment shall be due on the first Business Day immediately thereafter. In addition, the Borrower shall make Borrower Loan Payments in accordance with the Permanent Phase Borrower Note in the amounts and at the times necessary to make all payments due and payable on the Funding Loan. All payments made by the Borrower hereunder or by the Borrower 17 4894-2953-3827.5 under the other Borrower Loan Documents, shall be made irrespective of, and without any deduction for, any set-offs or counterclaims, but such payment shall not constitute a waiver of any such set offs or counterclaims. (b) Unless there is no Servicer, payments of principal and interest on the Permanent Phase Borrower Note shall be paid to the Servicer and the Servicer shall then remit such funds to the Fiscal Agent for deposit into the Funding Loan Payment Fund created under the Funding Loan Agreement. If there is no Servicer, payments of principal and interest on the Permanent Phase Borrower Note shall be paid to the Fiscal Agent. Section 2.5 Additional Borrower Payments. (a) The Borrower shall pay the following amounts: (i) to the Fiscal Agent, the Rebate Amount then due, if any, to be deposited in the Rebate Fund as specified in Section 5.36 hereof and the Rebate Analyst’s Fee to be deposited in the Expense Fund and any other costs incurred to calculate such Rebate Amount (to the extent such costs are not included in the Borrower Loan Payment); (ii) to the Fiscal Agent for remittance to the Governmental Lender, the Governmental Lender Fee, the Compliance Monitoring Fee and, on demand, all fees, charges, costs, advances, indemnities and expenses, including agent and counsel fees, of the Governmental Lender incurred under the Borrower Loan Documents or the Funding Loan Documents, and any taxes and assessments with respect to the Project, as and when the same become due; (iii) all costs of issuance and fees, charges and expenses, including agent and counsel fees incurred in connection with the origination of the Permanent Phase Borrower Loan and the Funding Loan, as and when the same become due; (iv) to the Funding Lender, on demand, all charges, costs, advances, indemnities and expenses, including agent and counsel fees, of the Funding Lender incurred by the Funding Lender at any time in connection with the Permanent Phase Borrower Loan, the Funding Loan or the Project, including, without limitation, any Review Fee, reasonable counsel fees and expenses incurred in connection with the interpretation, performance, or amendment and all counsel fees and expenses relating to the enforcement of the Borrower Loan Documents or the Funding Loan Documents or any other documents relating to the Project or the Borrower Loan or in connection with questions or other matters arising under such documents or in connection with any federal or state tax audit; (v) all Late Charges due and payable under the terms of the Permanent Phase Borrower Note and Section 2.6 hereof; provided, however, that all payments made pursuant to this subsection (v) shall be made to the Servicer, and, if there is no Servicer, such payments shall be made to the Funding Lender; and (vi) to the Fiscal Agent, the Fiscal Agent’s Fees as and when the same become due. (b) The Borrower shall pay to the party entitled thereto as expressly set forth in this Borrower Loan Agreement or the other Borrower Loan Documents or Funding Loan Documents: (i) all expenses incurred in connection with the enforcement against the Borrower of any rights under this Borrower Loan Agreement or any other Borrower Loan Document, the Regulatory 18 4894-2953-3827.5 Agreement, or any Funding Loan Document by the Governmental Lender, Funding Lender, Fiscal Agent or the Servicer, as applicable; (ii) all other payments of whatever nature that the Borrower has agreed to pay or assume under the provisions of this Borrower Loan Agreement or any other Borrower Loan Document or Funding Loan Document; and (iii) all expenses, costs and fees relating to inspections of the Project required by the Governmental Lender, the Funding Lender, the Fiscal Agent, the Servicer, in accordance with the Borrower Loan Documents or the Funding Loan Documents or to reimburse such parties for such expenses, costs and fees. Section 2.6 Overdue Payments; Payments in Default. If any Borrower Payment Obligation is not paid by or on behalf of the Borrower when due, the Borrower shall pay to the Servicer, a Late Charge in the amount and to the extent set forth in the Permanent Phase Borrower Note, if any. Section 2.7 Calculation of Interest Payments and Deposits to Real Estate Related Reserve Funds. The Borrower acknowledges as follows: (a) calculation of all interest payments shall be made by the Funding Lender in accordance with the terms of the Permanent Phase Borrower Note; (b) deposits with respect to the Taxes and Other Charges shall be calculated by the Servicer or if there is no Servicer, the Funding Lender in accordance with the Security Instrument; and (c) deposits with respect to any replacement reserve funds required by the Funding Lender shall be calculated by the Servicer in accordance with the Replacement Reserve Agreement. In the event and to the extent that the Servicer or the Funding Lender, pursuant to the terms hereof, shall determine at any time that there exists a deficiency in amounts previously owed but not paid with respect to deposits to such replacement reserve fund, such deficiency shall be immediately due and payable hereunder following Written Notice to the Borrower. Section 2.8 Grant of Security Interest; Application of Funds. To the extent not inconsistent with the Security Instrument and as security for payment of the Borrower Payment Obligations and the performance by the Borrower of all other terms, conditions and provisions of the Borrower Loan Documents, the Borrower hereby pledges and assigns to the Funding Lender, and grants to the Funding Lender, a security interest in, all the Borrower’s right, title and interest in and to all payments to or moneys held in the funds and accounts (other than the Rebate Fund and the Expense Fund) created and held by the Fiscal Agent, the Funding Lender or the Servicer for the Project. This Borrower Loan Agreement is, among other things, intended by the parties to be a security agreement for purposes of the UCC. Upon the occurrence and during the continuance of an Event of Default hereunder, the Fiscal Agent, the Funding Lender and the Servicer shall apply or cause to be applied any sums held by the Fiscal Agent (other than sums held in the Rebate Fund and the Expense Fund), the Funding Lender and the Servicer with respect to the Project in any manner and in any order determined by Funding Lender, in Funding Lender’s sole and absolute discretion. Section 2.9 Marshalling; Payments Set Aside. The Governmental Lender, the Fiscal Agent and the Funding Lender shall be under no obligation to marshal any assets in favor of the Borrower or any other Person or against or in payment of any or all of the proceeds. To the extent that the Borrower makes a payment or payments or transfers any assets to the Governmental Lender or Funding Lender, or the Governmental Lender, the Fiscal Agent or the Funding Lender enforces its liens, and such payment or payments or transfers, or the proceeds of such enforcement or any part thereof are subsequently invalidated, declared to be fraudulent or preferential, set aside or required to be repaid to a trustee, receiver or any other party in connection with any insolvency proceeding, or otherwise, then: (i) any and all obligations owed to the Governmental Lender, the Fiscal Agent or the Funding Lender and any and all remedies available to the Governmental Lender, the Fiscal Agent or the Funding Lender under the terms 19 4894-2953-3827.5 of the Borrower Loan Documents and the Funding Loan Documents or in law or equity against the Borrower, Guarantor or General Partner and/or any of their properties shall be automatically revived and reinstated to the extent (and only to the extent) of any recovery permitted under clause (ii) below; and (ii) the Governmental Lender, the Fiscal Agent and the Funding Lender shall be entitled to recover (and shall be entitled to file a proof of claim to obtain such recovery in any applicable bankruptcy, insolvency, receivership or fraudulent conveyance or fraudulent transfer proceeding) either: (x) the amount of payments or the value of the transfer or (y) if the transfer has been undone and the assets returned in whole or in part, the value of the consideration paid to or received by the Borrower for the initial asset transfer, plus in each case any deferred interest from the date of the disgorgement to the date of distribution to the Governmental Lender, the Fiscal Agent or the Funding Lender in any bankruptcy, insolvency, receivership or fraudulent conveyance or fraudulent transfer proceeding, and any costs and expenses due and owing, including, without limitation, any reasonable attorneys’ fees incurred by the Governmental Lender, the Fiscal Agent or the Funding Lender in connection with the exercise by the Governmental Lender, the Fiscal Agent or the Funding Lender of its rights under this Section 2.9. ARTICLE III RESERVED ARTICLE IV REPRESENTATIONS AND WARRANTIES Section 4.1 Borrower Representations. To induce the Governmental Lender, the Fiscal Agent and the Funding Lender to execute this Borrower Loan Agreement, the Borrower represents and warrants for the benefit of the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer, that the representations and warranties set forth in this Section 4.1 are complete and accurate as of the Conversion Date. Section 4.1.1 Organization; Special Purpose. The Borrower is a Florida limited partnership in good standing under the laws of the State, has full legal right, power and authority to enter into the Borrower Loan Documents to which it is a party, and to carry out and consummate all transactions contemplated by the Borrower Loan Documents to which it is a party, and by proper company action, has duly authorized the execution, delivery and performance of the Borrower Loan Documents to which it is a party. The Person(s) executing the Borrower Loan Documents and the Funding Loan Documents to which the Borrower is a party, in the name of and on behalf of the General Partner, is(are) fully authorized to execute the same. The Borrower Loan Documents and the Funding Loan Documents to which the Borrower is a party have been duly authorized, executed and delivered by the Borrower. The sole business of the Borrower is the ownership, management and operation of the Project. Section 4.1.2 Proceedings; Enforceability. Assuming due execution and delivery by the other parties thereto, the Borrower Loan Documents and the Funding Loan Documents to which the Borrower is a party will constitute the legal, valid and binding agreements of the Borrower enforceable against the Borrower in accordance with their terms; except in each case as enforcement may be limited by bankruptcy, insolvency or other laws affecting the enforcement of creditors’ rights generally, by the application of equitable principles regardless of whether enforcement is sought in a proceeding at law or in equity and by public policy. Section 4.1.3 No Conflicts. The execution and delivery of the Borrower Loan Documents and the Funding Loan Documents to which the Borrower is a party, the consummation of the transactions herein and therein contemplated and the fulfillment of or compliance with the terms and conditions hereof and thereof, will not conflict with or constitute a violation or breach of or default (with due notice or the passage of time or both) under the Partnership Agreement of the Borrower, or to the best 20 4894-2953-3827.5 knowledge of the Borrower and with respect to the Borrower, any applicable law or administrative rule or regulation, or any applicable court or administrative decree or order, or any mortgage, deed of trust, loan agreement, lease, contract or other agreement or instrument to which the Borrower is a party or by which it or its properties are otherwise subject or bound, or result in the creation or imposition of any lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the Borrower, which conflict, violation, breach, default, lien, charge or encumbrance might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Borrower Loan Documents and the Funding Loan Documents, or the financial condition, assets, properties or operations of the Borrower. Section 4.1.4 Litigation; Adverse Facts. There is no Legal Action, nor is there a basis known to the Borrower for any Legal Action, before or by any court or federal, state, municipal or other governmental authority, pending, or to the knowledge of the Borrower, after reasonable investigation, threatened in writing, against or affecting the Borrower, any General Partner or the Guarantor, or their respective assets, properties or operations which, if determined adversely to the Borrower or its interests, would have a material adverse effect upon the consummation of the transactions contemplated by, or the validity of, the Borrower Loan Documents or the Funding Loan Documents, upon the ability of each of the Borrower, each General Partner and Guarantor to perform their respective obligations under the Borrower Loan Documents, the Funding Loan Documents and the Related Documents to which it is a party, or upon the financial condition, assets (including the Project), properties or operations of the Borrower, the General Partner or the Guarantor. None of the Borrower, any General Partner or Guarantor is in default (and to the Borrower’s knowledge no event has occurred and is continuing which with the giving of notice or the passage of time or both could constitute a default) with respect to any order or decree of any court or any order, regulation or demand of any federal, state, municipal or other governmental authority, which default might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Borrower Loan Documents and the Funding Loan Documents, the ability of each of the Borrower, any General Partner and Guarantor to perform their respective obligations under the Borrower Loan Documents, the Funding Loan Documents and the Related Documents to which it is a party, or the financial condition, assets, properties or operations of the Borrower, any General Partner or Guarantor. None of the Borrower, any General Partner or Guarantor are (a) in violation of any applicable law, which violation materially and adversely affects or may materially and adversely affect the business, operations, assets (including the Project), or condition (financial or otherwise) of the Borrower, any General Partner or Guarantor, as applicable; (b) subject to, or in default with respect to, any other Legal Requirement that would have a material adverse effect on the business, operations, assets (including the Project), or condition (financial or otherwise) of the Borrower, any General Partner or Guarantor, as applicable; or (c) in default with respect to any agreement to which the Borrower, any General Partner or Guarantor, as applicable, are a party or by which they are bound, which default would have a material adverse effect on the business, operations, assets (including the Project), or condition (financial or otherwise) of the Borrower, any General Partner or Guarantor, as applicable; and (d) there is no Legal Action pending or, to the knowledge of the Borrower, threatened against or affecting the Borrower, any General Partner or Guarantor questioning the validity or the enforceability of this Borrower Loan Agreement or any of the other Borrower Loan Documents or the Funding Loan Documents or of any of the Related Documents. All tax returns (federal, state and local) required to be filed by or on behalf of the Borrower have been filed, and all taxes shown thereon to be due, including interest and penalties, except such, if any, as are being actively contested by the Borrower in good faith, have been paid or adequate reserves have been made for the payment thereof which reserves, if any, are reflected in the audited financial statements described therein. The Borrower enjoys the peaceful and undisturbed possession of all of the premises upon which it is operating its facilities. Section 4.1.5 Agreements; Consents; Approvals. Except as contemplated by the Borrower Loan Documents and the Funding Loan Documents, the Borrower is not a party to any agreement 21 4894-2953-3827.5 or instrument or subject to any restriction that would materially adversely affect the Borrower, the Project, or the Borrower’s business, properties, operations or financial condition, except the Permitted Encumbrances. The Borrower is not in default in any material respect in the performance, observance or fulfillment of any of the obligations, covenants or conditions contained in any Permitted Encumbrance or any other agreement or instrument to which it is a party or by which it or the Project is bound. No consent or approval of any trustee or holder of any indebtedness of the Borrower, and to the best knowledge of the Borrower and only with respect to the Borrower, no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority (except no representation is made with respect to any state securities or “blue sky” laws) is necessary in connection with the execution and delivery of the Borrower Loan Documents or the Funding Loan Documents, or the consummation of any transaction herein or therein contemplated, or the fulfillment of or compliance with the terms and conditions hereof or thereof, except as have been obtained or made and as are in full force and effect. Section 4.1.6 Title. The Borrower shall have a leasehold interest in the land and fee simple title to the Project, free and clear of all Liens except the Permitted Encumbrances. The Security Instrument, when properly recorded in the appropriate records, together with any UCC financing statements required to be filed in connection therewith, will create (i) a valid, perfected first priority lien on the Project and (ii) perfected security interests in and to, and perfected collateral assignments of, all personalty included in the Project (including the Leases), all in accordance with the terms thereof, in each case subject only to any applicable Permitted Encumbrances. To the Borrower’s knowledge, there are no delinquent real property taxes or assessments, including water and sewer charges, with respect to the Project, nor are there any claims for payment for work, labor or materials affecting the Project which are or may become a Lien prior to, or of equal priority with, the Liens created by the Borrower Loan Documents and the Funding Loan Documents. Section 4.1.7 Survey. To the best knowledge of the Borrower, the survey for the Project delivered to the Governmental Lender and the Funding Lender does not fail to reflect any material matter affecting the Project or the title thereto. Section 4.1.8 No Bankruptcy Filing. The Borrower is not contemplating either the filing of a petition by it under any state or federal bankruptcy or insolvency law or the liquidation of all or a major portion of its property (a “Bankruptcy Proceeding”), and the Borrower has no knowledge of any Person contemplating the filing of any such petition against it. As of the Delivery Date, the Borrower has the ability to pay its debts as they become due. Section 4.1.9 Full and Accurate Disclosure. No statement of fact made by the Borrower in any Borrower Loan Document or any Funding Loan Document contains any untrue statement of a material fact or omits to state any material fact necessary to make statements contained therein in light of the circumstances in which they were made, not misleading. There is no material fact or circumstance presently known to the Borrower that has not been disclosed to the Governmental Lender and the Funding Lender which materially and adversely affects the Project or the business, operations or financial condition of the Borrower or the Borrower’s ability to meet its obligations under this Borrower Loan Agreement and the other Borrower Loan Documents and Funding Loan Documents to which it is a party in a timely manner. Section 4.1.10 No Plan Assets. The Borrower is not an “employee benefit plan,” as defined in Section 3(3) of ERISA, subject to Title I of ERISA, and none of the assets of the Borrower constitutes or will constitute “plan assets” of one or more such plans within the meaning of 29 C.F.R. Section 2510.3-101. 22 4894-2953-3827.5 Section 4.1.11 Compliance. The Borrower, the Project and the use thereof will comply, to the extent required, in all material respects with all applicable Legal Requirements. The Borrower is not in default or violation of any order, writ, injunction, decree or demand of any Governmental Authority, the violation of which would materially adversely affect the financial condition or the business of the Borrower. There has not been committed by the Borrower or any Borrower Affiliate involved with the operation or use of the Project any act or omission affording any Governmental Authority the right of forfeiture as against the Project or any part thereof or any moneys paid in performance of the Borrower’s obligations under any Borrower Loan Document or any Funding Loan Documents. Section 4.1.12 Contracts. All service, maintenance or repair contracts affecting the Project have been entered into at arm’s length (except for such contracts between the Borrower its affiliates or the affiliates of the Borrower Controlling Entity of the Borrower) in the ordinary course of the Borrower’s business and provide for the payment of fees in amounts and upon terms comparable to existing market rates. Section 4.1.13 Financial Information. All financial data, including any statements of cash flow and income and operating expense, that have been delivered to the Governmental Lender or the Funding Lender in respect of the Project by or on behalf of the Borrower, to the best knowledge of the Borrower, (i) are accurate and complete in all material respects, (ii) accurately represent the financial condition of the Project as of the date of such reports, and (iii) to the extent prepared by an independent certified public accounting firm, have been prepared in accordance with GAAP consistently applied throughout the periods covered, except as disclosed therein. Other than pursuant to or permitted by the Borrower Loan Documents or the Funding Loan Documents or the Borrower organizational documents, the Borrower has no contingent liabilities, unusual forward or long-term commitments or unrealized or anticipated losses from any unfavorable commitments. Since the date of such financial statements, there has been no materially adverse change in the financial condition, operations or business of the Borrower from that set forth in said financial statements. Section 4.1.14 Condemnation. No Condemnation or other proceeding has been commenced or, to the Borrower’s knowledge, is contemplated, threatened or pending with respect to all or part of the Project or for the relocation of roadways providing access to the Project. Section 4.1.15 Federal Reserve Regulations. No part of the proceeds of the Permanent Phase Borrower Loan will be used for the purpose of purchasing or acquiring any “margin stock” within the meaning of Regulation U of the Board of Governors of the Federal Reserve System or for any other purpose that would be inconsistent with such Regulation U or any other regulation of such Board of Governors, or for any purpose prohibited by Legal Requirements or any Borrower Loan Document or Funding Loan Document. Section 4.1.16 Utilities and Public Access. To the best of the Borrower’s knowledge, the Project is or will be served by water, sewer, sanitary sewer and storm drain facilities adequate to service it for its intended uses. All public utilities necessary or convenient to the full use and enjoyment of the Project are or will be located in the public right-of-way abutting the Project, and all such utilities are or will be connected so as to serve the Project without passing over other property absent a valid easement. All roads necessary for the use of the Project for its current purpose have been or will be completed and dedicated to public use and accepted by all Governmental Authorities. Except for Permitted Encumbrances, the Project does not share ingress and egress through an easement or private road or share on-site or off- site recreational facilities and amenities that are not located on the Project and under the exclusive control of the Borrower, or where there is shared ingress and egress or amenities, there exists an easement or joint use and maintenance agreement under which (i) access to and use and enjoyment of the easement or private road and/or recreational facilities and amenities is perpetual, (ii) the number of parties sharing such 23 4894-2953-3827.5 easement and/or recreational facilities and amenities must be specified, (iii) the Borrower’s responsibilities and share of expenses are specified, and (iv) the failure to pay any maintenance fee with respect to an easement will not result in a loss of usage of the easement. Section 4.1.17 Not a Foreign Person. The Borrower is not a “foreign person” within the meaning of Section 1445(f)(3) of the Code. Section 4.1.18 Separate Lots. As of the Conversion Date each parcel comprising the Land will be a separate tax lot and is not a portion of any other tax lot that is not a part of the Land. Section 4.1.19 Assessments. There are no pending or, to the Borrower’s best knowledge, proposed special or other assessments for public improvements or otherwise affecting the Project, or any contemplated improvements to the Project that may result in such special or other assessments, other than the Borrower’s pending application for a special taxing district for lighting. Section 4.1.20 Enforceability. The Borrower Loan Documents and the Funding Loan Documents are not subject to, and the Borrower has not asserted, any right of rescission, set-off, counterclaim or defense, including the defense of usury. Section 4.1.21 Insurance. The Borrower has obtained the insurance required by this Borrower Loan Agreement, if applicable, and the Security Instrument and has delivered to the Servicer copies of insurance policies or certificates of insurance reflecting the insurance coverages, amounts and other requirements set forth in this Borrower Loan Agreement, if applicable, and the Security Instrument. Section 4.1.22 Use of Property; Licenses. The Project will be used exclusively as a multifamily residential rental project and other appurtenant and related uses, which use is consistent with the zoning classification for the Project. To the Borrower’s knowledge, all Licenses obtained by the Borrower have been validly issued and are in full force and effect. No Licenses will terminate, or become void or voidable or terminable, upon any sale, transfer or other disposition of the Project, including any transfer pursuant to foreclosure sale under the Security Instrument or deed in lieu of foreclosure thereunder. The Project does not violate any density or building setback requirements of the applicable zoning law except to the extent, if any, shown on the survey. No proceedings are, to the best of the Borrower’s knowledge, pending or threatened that would result in a change of the zoning of the Project. Section 4.1.23 Flood Zone. No structure within the Mortgaged Property lies or is located in an identifiable or designated Special Flood Hazard Area, or if the Mortgaged Property is determined to be in a Special Flood Hazard Area, Borrower will obtain appropriate flood insurance as required under the National Flood Insurance Act of 1968, Flood Disaster Protection Act of 1973, or the National Flood Insurance Reform Act of 1994, as amended, or as required by the Servicer pursuant to its underwriting guidelines. Section 4.1.24 Physical Condition. The Project, including all Improvements, parking facilities, systems, fixtures, Equipment and landscaping, are in good and habitable condition in all material respects and in good order and repair in all material respects (reasonable wear and tear excepted). The Borrower has not received notice from any insurance company or bonding company of any defect or inadequacy in the Project, or any part thereof, which would adversely affect its insurability or cause the imposition of extraordinary premiums or charges thereon or any termination of any policy of insurance or bond. The physical configuration of the Project is not in material violation of the ADA, if required under applicable law. 24 4894-2953-3827.5 Section 4.1.25 Encroachments. All of the Improvements included in determining the appraised value of the Project lie wholly within the boundaries and building restriction lines of the Project, and no improvement on an adjoining property encroaches upon the Project, and no easement or other encumbrance upon the Project encroaches upon any of the Improvements, so as to affect the value or marketability of the Project, except those insured against by the Title Insurance Policy or disclosed in the survey of the Project as approved by the Servicer. Section 4.1.26 State Law Requirements. The Borrower hereby represents, covenants and agrees to comply with the provisions of all applicable state laws relating to the Permanent Phase Borrower Loan, the Funding Loan and the Project. Section 4.1.27 Filing and Recording Taxes. All transfer taxes, deed stamps, intangible taxes or other amounts in the nature of transfer taxes required to be paid by any Person under applicable Legal Requirements in connection with the transfer of the Project to the Borrower have been paid. All mortgage, mortgage recording, stamp, intangible or other similar taxes required to be paid by any Person under applicable Legal Requirements in connection with the execution, delivery, recordation, filing, registration, perfection or enforcement of any of the Borrower Loan Documents and the Funding Loan Documents have been or will be paid. Section 4.1.28 Investment Company Act. The Borrower is not (i) an “investment company” or a company “controlled” by an “investment company,” within the meaning of the Investment Company Act of 1940, as amended; or (ii) a “holding company” or a “subsidiary company” of a “holding company” or an “affiliate” of either a “holding company” or a “subsidiary company” within the meaning of the Public Utility Holding Company Act of 1935, as amended. Section 4.1.29 Fraudulent Transfer. The Borrower has not accepted the Permanent Phase Borrower Loan or entered into any Borrower Loan Document or Funding Loan Document with the actual intent to hinder, delay or defraud any creditor, and the Borrower has received reasonably equivalent value in exchange for its obligations under the Borrower Loan Documents and the Funding Loan Documents. Giving effect to the transactions contemplated by the Borrower Loan Documents and the Funding Loan Documents, the fair saleable value of the Borrower’s assets exceeds and will, immediately following the execution and delivery of the Borrower Loan Documents and the Funding Loan Documents, exceed the Borrower’s total liabilities, including subordinated, unliquidated, disputed or contingent liabilities. The fair saleable value of the Borrower’s assets is and will, immediately following the execution and delivery of the Borrower Loan Documents and the Funding Loan Documents, be greater than the Borrower’s probable liabilities, including the maximum amount of its contingent liabilities or its debts as such debts become absolute and matured. The Borrower’s assets do not and, immediately following the execution and delivery of the Borrower Loan Documents and the Funding Loan Documents will not, constitute unreasonably small capital to carry out its business as conducted or as proposed to be conducted. The Borrower does not intend to, and does not believe that it will, incur debts and liabilities (including contingent liabilities and other commitments) beyond its ability to pay such debts as they mature (taking into account the timing and amounts to be payable on or in respect of obligations of the Borrower). Section 4.1.30 Ownership of the Borrower. Except as set forth in the Partnership Agreement of the Borrower, the Borrower has no obligation to any Person to purchase, repurchase or issue any ownership interest in the Borrower. Section 4.1.31 Environmental Matters. To the best of the Borrower’s knowledge, the Project is not in violation of any Legal Requirement pertaining to or imposing liability or standards of conduct concerning environmental regulation, contamination or clean-up, and will comply with covenants and requirements relating to environmental hazards as set forth in the Security Instrument. The Borrower 25 4894-2953-3827.5 will execute and deliver the Fee Guaranty and Environmental Indemnity Agreement and the Agreement of Environmental Indemnification on the Delivery Date. Section 4.1.32 Name; Principal Place of Business. Unless prior Written Notice is given to the Funding Lender, the Borrower does not use and will not use any trade name, and has not done and will not do business under any name other than its actual name set forth herein. The principal place of business of the Borrower is its primary address for notices as set forth in Section 10.1 hereof, and the Borrower has no other place of business, other than the Project and such principal place of business. Section 4.1.33 Subordinated Debt. There is no secured or unsecured indebtedness with respect to the Project or any residual interest therein, other than Permitted Encumbrances and the permitted indebtedness described in Section 6.7 hereof. Section 4.1.34 Filing of Taxes. The Borrower has filed (or has obtained effective extensions for filing) all federal, state and local tax returns required to be filed and has paid or made adequate provision for the payment of all federal, state and local taxes, charges and assessments, if any, payable by the Borrower. Section 4.1.35 General Tax. All representations, warranties and certifications of the Borrower set forth in the Regulatory Agreement and the Tax Certificate are incorporated by reference herein and the Borrower will comply with such as if set forth herein. Section 4.1.36 Approval of Borrower Loan Documents and Funding Loan Documents. By its execution and delivery of this Borrower Loan Agreement, the Borrower approves the form and substance of the Borrower Loan Documents and the Funding Loan Documents, and agrees to carry out the responsibilities and duties specified in the Borrower Loan Documents and the Funding Loan Documents to be carried out by the Borrower. The Borrower acknowledges that (a) it understands the nature and structure of the transactions relating to the financing of the Project, (b) it is familiar with the provisions of all of the Borrower Loan Documents and the Funding Loan Documents and other documents and instruments relating to the financing, (c) it understands the risks inherent in such transactions, including without limitation the risk of loss of the Project, and (d) it has not relied on the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer for any guidance or expertise in analyzing the financial or other consequences of the transactions contemplated by the Borrower Loan Documents and the Funding Loan Documents or otherwise relied on the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer in any manner. Section 4.1.37 Funding Loan Agreement. The Borrower has read and accepts and agrees that it is bound by the Funding Loan Agreement and the Funding Loan Documents. Section 4.1.38 American with Disabilities Act. The Project, as designed, will conform in all material respects, with all applicable zoning, planning, building and environmental laws, ordinances and regulations of governmental authorities having jurisdiction over the Project, including, but not limited to, the Americans with Disabilities Act of 1990, 42 U.S.C. 12101 et seq., and its implementing regulations and the American Disabilities Act Amendments Act (ADAAA) Pub. L. 10-325 and all subsequent amendments (the “ADA”), to the extent required (as evidenced by an architect’s certificate to such effect). Section 4.1.39 Requirements of Act, County Authorization, Code and Regulations. The Project satisfies all requirements of the Act, the County Authorization, the Code and the Regulations applicable to the Project. 26 4894-2953-3827.5 Section 4.1.40 Regulatory Agreement. The Project is, as of the date of origination of the Funding Loan, in compliance with all requirements of the Regulatory Agreement to the extent such requirements are applicable; and the Borrower intends to cause the residential units in the Project to be rented or available for rental on a basis which satisfies the requirements of the Regulatory Agreement, including all applicable requirements of the Act, the County Authorization, the Code and the Regulations, and pursuant to leases which comply with all applicable laws. Section 4.1.41 Intention to Hold Project. The Borrower intends to hold the Project for its own account and has no current plans, and has not entered into any agreement, to sell the Project or any part of it other than a purchase option/right of first refusal in favor of the Housing Authority of the City of Miami Beach and/or its affiliates; and the Borrower intends to occupy the Project or cause the Project to be occupied and to operate it or cause it to be operated at all times during the term of this Borrower Loan Agreement in compliance with the terms of this Borrower Loan Agreement and the Regulatory Agreement and does not know of any reason why the Project will not be so used by it in the absence of circumstances not now anticipated by it or totally beyond its control. Section 4.1.42 Concerning General Partner. (a) The General Partner of the Borrower is a Florida not for profit corporation, duly organized and validly existing under the laws of the State of Florida. The General Partner has all requisite power and authority, rights and franchises to enter into and perform its obligations under the Borrower Loan Documents and the Funding Loan Documents to be executed by the General Partner for its own account and on behalf of the Borrower, as authorized member of the Borrower, under this Borrower Loan Agreement and the other Borrower Loan Documents and the Funding Loan Documents. (b) The General Partner has made all filings (including, without limitation, all required filings related to the use of fictitious business names) and is in good standing in the State and in each other jurisdiction in which the character of the property it owns or the nature of the business it transacts makes such filings necessary or where the failure to make such filings could have a material adverse effect on the business, operations, assets, condition (financial or otherwise) or prospects of General Partner. (c) The Borrower General Partner is duly authorized to do business in the State. (d) The execution, delivery and performance by the Borrower of the Borrower Loan Documents and the Funding Loan Documents have been duly authorized by all necessary action of the General Partner on behalf of the Borrower, and by all necessary action on behalf of the General Partner. (e) The execution, delivery and performance by the General Partner, on behalf of the Borrower, of the Borrower Loan Documents and the Funding Loan Documents will not violate (i) the General Partner’s organizational documents; (ii) any other Legal Requirement affecting the Borrower General Partner or any of its properties; or (iii) any agreement to which the General Partner is bound or to which it is a party; and will not result in or require the creation (except as provided in or contemplated by this Borrower Loan Agreement) of any Lien upon any of such properties, any of the Collateral or any of the property or funds pledged or delivered to Funding Lender pursuant to the Security Documents. Section 4.1.43 Government and Private Approvals. All governmental or regulatory orders, consents, permits, authorizations and approvals required for the construction, rehabilitation, use, occupancy and operation of the Improvements, that may be granted or denied in the discretion of any Governmental Authority, have been obtained and are in full force and effect (or, in the case of any of the foregoing that the Borrower is not required to have as of the Delivery Date, will be obtained), and will be maintained in full force and effect at all times during the construction or rehabilitation of the Improvements. 27 4894-2953-3827.5 All such orders, consents, permits, authorizations and approvals that may not be denied in the discretion of any Governmental Authority shall be obtained prior to the commencement of any work for which such orders, consents, permits, authorizations or approvals are required, and, once obtained, such orders, consents, permits, authorizations and approvals will be maintained in full force and effect at all times during the construction or rehabilitation of the Improvements. Except as set forth in the preceding two sentences, no additional governmental or regulatory actions, filings or registrations with respect to the Improvements, and no approvals, authorizations or consents of any trustee or holder of any indebtedness or obligation of the Borrower, are required for the due execution, delivery and performance by the Borrower or General Partner of any of the Borrower Loan Documents or the Funding Loan Documents or the Related Documents executed by the Borrower or General Partner, as applicable. All required zoning approvals have been obtained, and the zoning of the Land for the Project is not conditional upon the happening of any further event. Section 4.1.44 Concerning Guarantor. The Borrower Loan Documents and the Funding Loan Documents to which the Guarantor is a party or a signatory executed simultaneously with this Borrower Loan Agreement have been duly executed and delivered by the Guarantor and are legally valid and binding obligations of the Guarantor, enforceable against the Guarantor in accordance with their terms, except as enforceability may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws affecting creditors’ rights generally and by general principles of equity. Section 4.1.45 No Material Defaults. Except as previously disclosed to Funding Lender in writing, there exists no material violation of or material default by the Borrower under, and, to the best knowledge of the Borrower, no event has occurred which, upon the giving of notice or the passage of time, or both, would constitute a material default with respect to: (i) the terms of any instrument evidencing, securing or guaranteeing any indebtedness secured by the Project or any portion or interest thereof or therein; (ii) any lease or other agreement affecting the Project or to which the Borrower is a party; (iii) any license, permit, statute, ordinance, law, judgment, order, writ, injunction, decree, rule or regulation of any Governmental Authority, or any determination or award of any arbitrator to which the Borrower or the Project may be bound; or (iv) any mortgage, instrument, agreement or document by which the Borrower or any of its respective properties is bound; in the case of any of the foregoing: (1) which involves any Borrower Loan Document or Funding Loan Document; (2) which involves the Project and is not adequately covered by insurance; (3) that might materially and adversely affect the ability of the Borrower, General Partner or Guarantor or to perform any of its respective obligations under any of the Borrower Loan Documents or the Funding Loan Documents or any other material instrument, agreement or document to which it is a party; or (4) which might adversely affect the priority of the Liens created by this Borrower Loan Agreement or any of the Borrower Loan Documents or the Funding Loan Documents. Section 4.1.46 Payment of Taxes. Except as previously disclosed to Funding Lender in writing: (i) all tax returns and reports of the Borrower, General Partner and Guarantor required to be filed have been timely filed, and all taxes, assessments, fees and other governmental charges upon the Borrower, General Partner and Guarantor, and upon their respective properties, assets, income and franchises, which are due and payable have been paid when due and payable; and (ii) the Borrower knows of no proposed tax assessment against it or against General Partner or Guarantor, that would be material to the condition (financial or otherwise) of the Borrower, General Partner or Guarantor, and neither the Borrower nor General Partner have contracted with any Government Authority in connection with such taxes. Section 4.1.47 Rights to Project Agreements and Licenses. The Borrower is the legal and beneficial owner of all rights in and to the plans and specifications of the Project and all existing Project Agreements and Licenses and will be the legal and beneficial owner of all rights in and to all future Project Agreements and Licenses. The Borrower’s interest in the plans and specifications of the Project and all 28 4894-2953-3827.5 Project Agreements and Licenses is not subject to any present claim (other than under the Borrower Loan Documents and the Funding Loan Documents or as otherwise approved by Funding Lender in its sole discretion), set-off or deduction other than in the ordinary course of business. Section 4.1.48 Patriot Act Compliance. The Borrower is not now, nor has ever been (i) listed on any Government Lists (as defined below), (ii) a person who has been determined by a Governmental Authority to be subject to the prohibitions contained in Presidential Executive Order No. 13224 (Sept. 23, 2001) or any other similar prohibitions contained in the rules and regulations of OFAC (as defined below) or in any enabling legislation or other Presidential Executive Orders in respect thereof, (iii) indicted for or convicted of any felony involving a crime or crimes of moral turpitude or for any Patriot Act Offense, or (iv) under investigation by any Governmental Authority for alleged criminal activity. For purposes hereof, the term “Patriot Act Offense” shall mean any violation of the criminal laws of the United States of America or of any of the several states, or that would be a criminal violation if committed within the jurisdiction of the United States of America or any of the several states, relating to terrorism or the laundering of monetary instruments, including any offense under (A) the criminal laws against terrorism; (B) the criminal laws against money laundering, (C) Bank Representative Secrecy Act, as amended, (D) the Money Laundering Control Act of 1986, as amended, or (E) the Patriot Act. “Patriot Act Offense” also includes the crimes of conspiracy to commit, or aiding and abetting another to commit, a Patriot Act Offense. For purposes hereof, the term “Government Lists” shall mean (1) the Specially Designated Nationals and Blocked Persons Lists maintained by the Office of Foreign Assets Control (“OFAC”), (2) any other list of terrorists, terrorist organizations or narcotics traffickers maintained pursuant to any of the Rules and Regulations of OFAC that Funding Lender notified the Borrower in writing is now included in “Government Lists,” or (3) any similar lists maintained by the United States Department of State, the United States Department of Commerce or any other Governmental Authority or pursuant to any Executive Order of the President of the United States of America that the Funding Lender notified the Borrower in writing is now included in “Government Lists.” Section 4.1.49 Reserved. Section 4.1.50 Subordinate Loan Documents. The Subordinate Loan Documents are in full force and effect and the Borrower has paid all commitment fees and other amounts due and payable to the Subordinate Lender(s) thereunder. There exists no material violation of or material default by the Borrower under, and no event has occurred which, upon the giving of notice of the passage of time, or both, would constitute a material default under the Subordinate Loan Documents. Section 4.1.51 Other Documents. Each of the representations and warranties of the Borrower or the General Partner contained in any of the other Borrower Loan Documents or the Funding Loan Documents or Related Documents is true and correct in all material respects (or, in the case of representations or warranties contained in any of the other Borrower Loan Documents or Funding Loan Documents or Related Documents that speak as of a particular date, were true and correct in all material respects as of such date). All of such representations and warranties are incorporated herein for the benefit of the Funding Lender. Section 4.1.52 Subordinate Loan Documents. There exists no material violation of or material default by the Borrower under, and no event has occurred which, upon the giving of notice or the passage of time, or both, would constitute a material default under the Subordinate Loan Documents. Section 4.1.53 Ground Lease. The Ground Lease is in full force and effect and the Borrower has paid all rent and other amounts due and payable to the ground lessor thereunder. There exists no material violation of or material default by the Borrower under the Ground Lease, and no event has 29 4894-2953-3827.5 occurred which, upon the giving of notice or the passage of time, or both, would constitute a material default by any other party under the Ground Lease Section 4.2 Survival of Representations and Covenants. All of the representations and warranties in Section 4.1 hereof and elsewhere in the Borrower Loan Documents (i) shall survive for so long as any portion of the Borrower Payment Obligations remains due and owing and (ii) shall be deemed to have been relied upon by the Governmental Lender and the Servicer notwithstanding any investigation heretofore or hereafter made by the Governmental Lender or the Servicer or on its or their behalf, provided, however, that the representations, warranties and covenants set forth in Section 4.1.31 hereof shall survive in perpetuity and shall not be subject to the exculpation provisions of Section 11.1 hereof. ARTICLE V AFFIRMATIVE COVENANTS During the term of this Borrower Loan Agreement, the Borrower hereby covenants and agrees with the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer that: Section 5.1 Existence. The Borrower shall (i) do or cause to be done all things necessary to preserve, renew and keep in full force and effect its existence and its material rights, and franchises, (ii) continue to engage in the business presently conducted by it, (iii) obtain and maintain all material Licenses, and (iv) qualify to do business and remain in good standing under the laws of the State. Section 5.2 Taxes and Other Charges. The Borrower shall pay all Taxes and Other Charges as the same become due and payable and prior to their becoming delinquent in accordance with the Security Instrument, except to the extent that the amount, validity or application thereof is being contested in good faith as permitted by the Security Instrument. The Borrower covenants to pay all Taxes and Other Charges of any type or character charged to the Funding Lender affecting the amount available to the Funding Lender from payments to be received hereunder or in any way arising due to the transactions contemplated hereby (including Taxes and Other Charges assessed or levied by any public agency or governmental authority of whatsoever character having power to levy taxes or assessments) but excluding franchise taxes based upon the capital and/or income of the Funding Lender and taxes based upon or measured by the net income or gross receipts (to the extent such Taxes are assessed outside the Property Jurisdiction) of the Funding Lender; provided, however, that the Borrower shall have the right to protest any such Taxes or Other Charges and to require the Funding Lender, at the Borrower’s expense, to protest and contest any such Taxes or Other Charges levied upon them and that the Borrower shall have the right to withhold payment of any such Taxes or Other Charges pending disposition of any such protest or contest unless such withholding, protest or contest would adversely affect the rights or interests of the Funding Lender. This obligation shall remain valid and in effect notwithstanding repayment of the Permanent Phase Borrower Loan hereunder or termination of this Borrower Loan Agreement. Section 5.3 Repairs; Maintenance and Compliance; Physical Condition. The Borrower shall cause the Project to be maintained in a good, habitable and safe (so as to not threaten the health or safety of the Project’s tenants or their invited guests) condition and repair (reasonable wear and tear excepted) as set forth in the Security Instrument and shall not remove, demolish or materially alter the Improvements or Equipment (except for removal of aging or obsolete equipment or furnishings in the normal course of business), except as provided in the Security Instrument. Section 5.4 Litigation. The Borrower shall give prompt Written Notice to the Governmental Lender, the Funding Lender and the Servicer of any litigation, governmental proceedings or claims or 30 4894-2953-3827.5 investigations regarding an alleged actual violation of a Legal Requirement pending or, to the Borrower’s knowledge, threatened against the Borrower which might materially adversely affect the Borrower’s condition (financial or otherwise) or business or the Project. Section 5.5 Performance of Other Agreements. The Borrower shall observe and perform in all material respects each and every term to be observed or performed by it pursuant to the terms of any agreement or instrument affecting or pertaining to the Project. Section 5.6 Notices. The Borrower shall promptly advise the Governmental Lender, the Funding Lender and the Servicer of (i) any Material Adverse Change in the Borrower’s financial condition, assets, properties or operations other than general changes in the real estate market, (ii) any fact or circumstance affecting the Borrower or the Project that materially and adversely affects the Borrower’s ability to meet its obligations hereunder or under any of the other Borrower Loan Document to which it is a party in a timely manner, or (iii) the occurrence of any Potential Default or Event of Default of which the Borrower has actual knowledge. If the Borrower becomes subject to federal or state securities law filing requirements, the Borrower shall cause to be delivered to the Governmental Lender, the Funding Lender and the Servicer any Securities and Exchange Commission or other public filings, if any, of the Borrower within two (2) Business Days of such filing. Section 5.7 Cooperate in Legal Proceedings. The Borrower shall cooperate fully with the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer with respect to, and permit the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer at their option, to participate in, any proceedings before any Governmental Authority that may in any way affect the rights of the Governmental Lender, the Funding Lender, the Fiscal Agent and/or the Servicer under any Borrower Loan Document or Funding Loan Document. Section 5.8 Further Assurances. The Borrower shall, at the Borrower’s sole cost and expense (except as provided in Section 9.1 hereof), (i) furnish to the Servicer and the Funding Lender all instruments, documents, boundary surveys, footing or foundation surveys (to the extent that the Borrower’s construction or renovation of the Project alters any existing building foundations or footprints), certificates, plans and specifications, appraisals, title and other insurance reports and agreements relating to the Project, reasonably requested by the Servicer or the Funding Lender for the better and more efficient carrying out of the intents and purposes of the Borrower Loan Documents and the Funding Loan Documents; (ii) execute and deliver to the Servicer, the Fiscal Agent and the Funding Lender such documents, instruments, certificates, assignments and other writings, and do such other acts necessary or desirable, to evidence, preserve and/or protect the collateral at any time securing or intended to secure the Permanent Phase Borrower Loan, as the Servicer, the Fiscal Agent and the Funding Lender may reasonably require from time to time; (iii) do and execute all and such further lawful and reasonable acts, conveyances and assurances for the better and more effective carrying out of the intents and purposes of the Borrower Loan Documents and the Funding Loan Documents, as the Servicer, the Fiscal Agent or the Funding Lender shall reasonably require from time to time; provided, however, with respect to clauses (i)-(iii) above, the Borrower shall not be required to do anything that has the effect of (A) changing the essential economic terms of the Permanent Phase Borrower Loan or (B) imposing upon the Borrower greater liability under the Borrower Loan Documents and the Funding Loan Documents or decreasing Borrower’s rights under the Borrower Loan Documents and the Funding Loan Documents; and (iv) upon the Servicer’s, the Fiscal Agent’s or the Funding Lender’s request therefor given from time to time after the occurrence of any Potential Default or Event of Default for so long as such Potential Default or Event of Default, as applicable, is continuing pay for (a) reports of UCC, federal tax lien, state tax lien, judgment and pending litigation searches with respect to the Borrower and (b) searches of title to the Project, each 31 4894-2953-3827.5 such search to be conducted by search firms reasonably designated by the Servicer or the Funding Lender in each of the locations reasonably designated by the Servicer or the Funding Lender. Section 5.9 Delivery of Financial Information. After notice to the Borrower of a Secondary Market Disclosure Document, the Borrower shall, concurrently with any delivery to the Funding Lender or the Servicer, deliver copies of all financial information required under Article IX. Section 5.10 Environmental Matters. So long as the Borrower owns or is in possession of the Project, the Borrower shall (a) keep the Project in compliance with all Hazardous Materials Laws (as defined in the Security Instrument), (b) promptly notify the Funding Lender, the Fiscal Agent, the Governmental Lender and the Servicer if the Borrower shall become aware that any Hazardous Materials (as defined in the Security Instrument) are on or near the Project in violation of Hazardous Materials Laws, and (c) commence and thereafter diligently prosecute to completion all remedial work necessary with respect to the Project required under any Hazardous Material Laws, in each case as set forth in the Security Instrument, the Fee Guaranty and Environmental Indemnity Agreement or the Agreement of Environmental Indemnification. Section 5.11 Title to the Project. The Borrower will warrant and defend the title to the Project, subject only to Permitted Encumbrances against the claims of all Persons. Section 5.12 Governmental Lender’s, Fiscal Agent’s and Funding Lender’s Fees. The Borrower covenants to pay the Governmental Lender Fee and fees and expenses of the Fiscal Agent and the Funding Lender or any agents, attorneys, accountants, consultants selected by the Governmental Lender, the Fiscal Agent or the Funding Lender to act on its behalf in connection with this Borrower Loan Agreement and the other Borrower Loan Documents, the Regulatory Agreement and the Funding Loan Documents, including, without limitation, any and all reasonable expenses incurred in connection with the making of the Permanent Phase Borrower Loan or in connection with any litigation which may at any time be instituted involving the Permanent Phase Borrower Loan, this Borrower Loan Agreement, the other Borrower Loan Documents, the Regulatory Agreement and the Funding Loan Documents or any of the other documents contemplated thereby, or in connection with the reasonable supervision or inspection of the Borrower, its properties, assets or operations or otherwise in connection with the administration of the foregoing. This obligation shall remain valid and in effect notwithstanding repayment of the Permanent Phase Borrower Loan hereunder or termination of this Borrower Loan Agreement. Section 5.13 Estoppel Statement. The Borrower shall furnish to the Funding Lender or the Servicer for the benefit of the Funding Lender or the Servicer within ten (10) days after written request by the Funding Lender and the Servicer, with a statement, duly acknowledged and certified, setting forth (i) the unpaid principal of the Permanent Phase Borrower Note, (ii) the applicable Interest Rate, (iii) the date installments of interest and/or principal were last paid, (iv) any offsets or defenses to the payment of the Borrower Payment Obligations, and (v) that the Borrower Loan Documents and the Funding Loan Documents to which the Borrower is a party are valid, legal and binding obligations of the Borrower and have not been modified or, if modified, giving particulars of such modification, and no Event of Default exists thereunder or specify any Event of Default that does exist thereunder. The Borrower shall use commercially reasonable efforts to furnish to the Funding Lender or the Servicer, within 30 days of a request by the Funding Lender or Servicer, tenant estoppel certificates from each commercial tenant at the Project in form and substance reasonably satisfactory to the Funding Lender and the Servicer; 32 4894-2953-3827.5 provided that the Funding Lender and the Servicer shall not make such requests more frequently than twice in any year. Section 5.14 Defense of Actions. The Borrower shall appear in and defend any action or proceeding purporting to affect the security for this Borrower Loan Agreement hereunder or under the Borrower Loan Documents and the Funding Loan Documents, and shall pay, in the manner required by Section 2.4 hereof, all reasonable costs and expenses, including the cost of evidence of title and attorneys’ fees, in any such action or proceeding in which Funding Lender may appear. If the Borrower fails to perform any of the covenants or agreements contained in this Borrower Loan Agreement or any other Borrower Loan Document, or if any action or proceeding is commenced that is not diligently defended by the Borrower which affects the Funding Lender’s interest in the Project or any part thereof, including eminent domain, code enforcement or proceedings of any nature whatsoever under any Federal or state law, whether now existing or hereafter enacted or amended, then the Funding Lender may make such appearances, disburse such sums and take such action as the Funding Lender deems necessary or appropriate to protect its interests. Such actions include disbursement of attorneys’ fees, entry upon the Project to make repairs or take other action to protect the security of the Project, and payment, purchase, contest or compromise of any encumbrance, charge or lien which in the judgment of Funding Lender appears to be prior or superior to the Borrower Loan Documents or the Funding Loan Documents. The Funding Lender shall have no obligation to do any of the above. The Funding Lender may take any such action without notice to or demand upon the Borrower, but the Funding Lender shall endeavor to notify the Borrower upon taking any of such action (but the Funding Lender shall have no liability for any failure to do so). No such action shall release the Borrower from any obligation under this Borrower Loan Agreement or any of the other Borrower Loan Documents or Funding Loan Documents. In the event (i) that the Security Instrument is foreclosed in whole or in part or that any Borrower Loan Document is put into the hands of an attorney for collection, suit, action or foreclosure, or (ii) of the foreclosure of any mortgage, deed of trust or deed to secure debt prior to or subsequent to the Security Instrument or any Borrower Loan Document in which proceeding the Funding Lender is made a party or (iii) of the bankruptcy of the Borrower or an assignment by the Borrower for the benefit of its creditors, the Borrower shall be chargeable with and agrees to pay all costs of collection and defense, including actual attorneys’ fees in connection therewith and in connection with any appellate proceeding or post- judgment action involved therein, which shall be due and payable together with all required service or use taxes. Section 5.15 Expenses. The Borrower shall pay all reasonable expenses incurred by the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer (except as provided in Section 9.1 hereof) in connection with the Permanent Phase Borrower Loan and the Funding Loan, including reasonable fees and expenses of the Governmental Lender’s, the Fiscal Agent’s, the Funding Lender’s and the Servicer’s attorneys, environmental, engineering and other consultants, and fees, charges or taxes for the recording or filing of the Borrower Loan Documents and the Funding Loan Documents. The Borrower shall pay or cause to be paid all reasonable expenses of the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer (except as provided in Section 9.1 hereof) in connection with the issuance or administration of the Permanent Phase Borrower Loan and the Funding Loan, including audit costs, inspection fees, settlement of condemnation and casualty awards, and premiums for title insurance and endorsements thereto. The Borrower shall, upon request, promptly reimburse the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer for all reasonable amounts expended, advanced or incurred by the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer to collect the Permanent Phase Borrower Note, or to enforce the rights of the Governmental Lender, the Fiscal Agent, the Funding Lender, the Fiscal Agent and the Servicer under this Borrower Loan Agreement or any other Borrower Loan Document, or to defend or assert the rights and claims of the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer under the Borrower Loan Documents and the Funding Loan Documents arising out of an Event of Default 33 4894-2953-3827.5 or with respect to the Project (by litigation or other proceedings) arising out of an Event of Default, which amounts will include all court costs, attorneys’ fees and expenses, fees of auditors and accountants, and investigation expenses as may be reasonably incurred by the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer in connection with any such matters (whether or not litigation is instituted), together with interest at the Default Rate on each such amount from the date of disbursement until the date of reimbursement to the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer, all of which shall constitute part of the Permanent Phase Borrower Loan and the Funding Loan and shall be secured by the Borrower Loan Documents and the Funding Loan Documents. The obligations and liabilities of the Borrower under this Section 5.15 shall survive the Term of this Borrower Loan Agreement and the exercise by the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer, as the case may be, of any of its rights or remedies under the Borrower Loan Documents and the Funding Loan Documents, including the acquisition of the Project by foreclosure or a conveyance in lieu of foreclosure. Notwithstanding the foregoing, the Borrower shall not be obligated to pay amounts incurred as a result of the gross negligence or willful misconduct of any other party, and any obligations of the Borrower to pay for environmental inspections or audits will be governed by the Security Instrument. Notwithstanding anything to the contrary in this Agreement, the Borrower shall not be responsible for any costs associated with any securitization of the Permanent Phase Borrower Loan. Section 5.16 Indemnity. In addition to its other obligations hereunder, and in addition to any and all rights of reimbursement, indemnification, subrogation and other rights of the Governmental Lender, the Fiscal Agent or the Funding Lender pursuant hereto and under law or equity, to the fullest extent permitted by law, the Borrower agrees to indemnify, hold harmless and defend the Servicer, the Beneficiary Parties, Citigroup, Inc., and each of their respective officers, directors, employees, attorneys and agents (each an “Indemnified Party”), against any and all losses, damages, claims, actions, liabilities, reasonable costs and expenses of any nature, kind or character (including, without limitation, reasonable attorneys’ fees, litigation and court costs, amounts paid in settlement (to the extent that the Borrower has consented to such settlement) and amounts paid to discharge judgments) (hereinafter, the “Liabilities”) to which the Indemnified Parties, or any of them, may become subject under federal or state securities laws or any other statutory law or at common law or otherwise, to the extent arising out of or based upon or in any way relating to: (a) The Borrower Loan Documents and the Funding Loan Documents or the execution or amendment thereof or in connection with transactions contemplated thereby, including the sale, transfer or resale of the Permanent Phase Borrower Loan or the Funding Loan, except with respect to any Secondary Market Disclosure Document (other than any of the Borrower’s obligations under Article IX); (b) Any act or omission of the Borrower or any of its agents, contractors, servants, employees or licensees in connection with the Permanent Phase Borrower Loan, the Funding Loan or the Project, the operation of the Project, or the condition, environmental or otherwise, occupancy, use, possession, conduct or management of work done in or about, or from the planning, design, acquisition, construction, installation or rehabilitation of, the Project or any part thereof; (c) Any lien (other than a Permitted Lien) or charge upon payments by the Borrower to the Governmental Lender, the Fiscal Agent or the Funding Lender hereunder, or any taxes (including, without limitation, all ad valorem taxes and sales taxes, but excluding income taxes other than those covered by (g)), assessments, impositions and Other Charges imposed on the Governmental Lender, the Fiscal Agent or the Funding Lender in respect of any portion of the Project; (d) Any violation of any environmental law, rule or regulation with respect to, or the release of any toxic substance or hazardous material from, the Project or any part thereof; provided, however, Borrower’s liability under this provision shall not extend to cover the period of any violation that first 34 4894-2953-3827.5 arose, commenced or occurred as a result of actions of the Indemnified Party, after the satisfaction, discharge, release, assignment, termination or cancellation of the Security Instrument following the payment in full of the Permanent Phase Borrower Note and all other sums payable under the Borrower Loan Documents or after the actual dispossession from the entire Mortgaged Property of Borrower and all entities which control, are controlled by, or are under common control with Borrower following foreclosure of the Security Instrument or acquisition of the Mortgaged Property by a deed in lieu of foreclosure; (e) The enforcement of, or any action taken by the Governmental Lender, the Fiscal Agent or the Funding Lender related to remedies under, this Borrower Loan Agreement and the other Borrower Loan Documents and the Funding Loan Documents; (f) Any untrue statement or misleading statement or alleged untrue statement or alleged misleading statement of a material fact by the Borrower made in the course of the Borrower applying for the Permanent Phase Borrower Loan or the Funding Loan or contained in any of the Borrower Loan Documents or Funding Loan Documents to which the Borrower is a party; (g) Any Determination of Taxability; (h) Any breach (or alleged breach) by the Borrower of any representation, warranty or covenant made in or pursuant to this Borrower Loan Agreement or in connection with any written representation, presentation, report, appraisal or other information given or delivered by the Borrower, General Partner, Guarantor or their Affiliates to the Governmental Lender, the Funding Lender, the Fiscal Agent, the Servicer or any other Person in connection with the Borrower’s application for the Permanent Phase Borrower Loan and the Funding Loan (including, without limitation, any breach or alleged breach by the Borrower of any agreement with respect to the provision of any substitute credit enhancement); (i) any failure (or alleged failure) by the Borrower, the Funding Lender or Governmental Lender to comply with applicable federal and state laws and regulations pertaining to the making of the Permanent Phase Borrower Loan and the Funding Loan; (j) the Project, or the condition, occupancy, use, possession, conduct or management of, or work done in or about, or from the planning, design, acquisition, installation, construction or rehabilitation of, the Project or any part thereof; or (k) the use of the proceeds of the Permanent Phase Borrower Loan and the Funding Loan, except (A) in the case of the foregoing indemnification of the Fiscal Agent, or any of its respective officers, commissioners, members, directors, officials, employees, attorneys and agents, to the extent such Liabilities are caused by the negligence, unlawful acts or willful misconduct of such Indemnified Party; or (B) in the case of the foregoing indemnification of the Servicer, the Funding Lender, the Governmental Lender Servicer, or the Governmental Lender or any of their respective officers, commissioners, members, directors, officials, employees, attorneys and agents, to the extent such Liabilities are caused by the gross negligence or willful misconduct of such Indemnified Party Notwithstanding anything herein to the contrary, the Borrower’s indemnification obligations to the parties specified in Section 9.1.4 hereof with respect to any securitization or Secondary Market Transaction described in Article IX hereof shall be limited to the indemnity set forth in Section 9.1.4 hereof. In the event that any action or proceeding is brought against any Indemnified Party with respect to which indemnity may be sought hereunder, the Borrower, upon written notice from the Indemnified Party (which notice shall be timely given so as not to materially impair the Borrower’s right to defend), shall assume the 35 4894-2953-3827.5 investigation and defense thereof, including the employment of counsel reasonably approved by the Indemnified Party, and shall assume the payment of all expenses related thereto, with full power to litigate, compromise or settle the same in its sole discretion; provided that the Indemnified Party shall have the right to review and approve or disapprove any such compromise or settlement, which approval shall not be unreasonably withheld. Each Indemnified Party shall have the right to employ separate counsel in any such action or proceeding and to participate in the investigation and defense thereof. The Borrower shall pay the reasonable fees and expenses of such separate counsel; provided, however, that such Indemnified Party may only employ separate counsel at the expense of the Borrower if and only if in such Indemnified Party’s good faith judgment (based on the advice of counsel) a conflict of interest exists or could arise by reason of common representation. Notwithstanding any transfer of the Project to another owner in accordance with the provisions of this Borrower Loan Agreement or the Regulatory Agreement, the Borrower shall remain obligated to indemnify each Indemnified Party pursuant to this Section 5.16 if such subsequent owner fails to indemnify any party entitled to be indemnified hereunder, unless the Governmental Lender and the Funding Lender have consented to such transfer and to the assignment of the rights and obligations of the Borrower hereunder. The rights of any persons to indemnity hereunder shall survive the final payment or defeasance of the Permanent Phase Borrower Loan and the Funding Loan and in the case of the Servicer, any resignation or removal. The provisions of this Section 5.16 shall survive the termination of this Borrower Loan Agreement. Section 5.17 No Warranty of Condition or Suitability by the Governmental Lender or Funding Lender. Neither the Governmental Lender nor the Funding Lender make any warranty, either express or implied, as to the condition of the Project or that it will be suitable for the Borrower’s purposes or needs. Section 5.18 Right of Access to the Project. The Borrower agrees that the Governmental Lender, the Funding Lender, the Fiscal Agent, and the Servicer and their duly authorized agents, attorneys, experts, engineers, accountants and representatives shall have the right, but no obligation at all reasonable times during business hours and upon not less than five (5) days prior written notice and subject to the rights of residential tenants, to enter onto the Land (a) to examine, test and inspect the Project without material interference or prejudice to the Borrower’s operations and (b) to perform such work in and about the Project made necessary by reason of the Borrower’s default under any of the provisions of this Borrower Loan Agreement. The Governmental Lender, the Funding Lender, the Fiscal Agent, the Servicer, and their duly authorized agents, attorneys, accountants and representatives shall also be permitted, without any obligation to do so, at all reasonable times and upon reasonable notice during business hours, to examine the books and records of the Borrower with respect to the Project. Section 5.19 Notice of Default. The Borrower will provide the Governmental Lender, the Funding Lender and the Servicer as soon as possible, and in any event not later than five (5) Business Days after the occurrence of any Potential Default or Event of Default, with a statement of an Authorized Representative of Borrower describing the details of such Potential Default or Event of Default and any curative action Borrower proposes to take. Section 5.20 Covenant with Governmental Lender, the Fiscal Agent and the Funding Lender. The Borrower agrees that this Borrower Loan Agreement is executed and delivered in part to induce the purchase by others of the Governmental Lender Note and, accordingly, all covenants and agreements of the Borrower contained in this Borrower Loan Agreement are hereby declared to be for 36 4894-2953-3827.5 the benefit of the Governmental Lender, the Funding Lender, the Fiscal Agent and any lawful owner, holder or pledgee of the Borrower Note or the Governmental Lender Note from time to time. Section 5.21 Reserved. Section 5.22 Maintenance of Insurance. Borrower will maintain the insurance required by the Security Instrument. Section 5.23 Information; Statements and Reports. The Borrower shall furnish or cause to be furnished to the Funding Lender and, upon the written request, the Governmental Lender: (a) Financial Statements; Rent Rolls. In the manner and to the extent required under the Security Instrument, such financial statements, expenses statements, rent rolls, reports and other financial documents and information as required by the Security Instrument and the other Borrower Loan Documents and Funding Loan Documents, in the form and within the time periods required therein; (b) Reserved. (c) Audit Reports. Promptly upon receipt thereof, copies of all reports, if any, submitted to Borrower by independent public accountants in connection with each annual, interim or special audit of the financial statements of Borrower made by such accountants, including the comment letter submitted by such accountants to management in connection with their annual audit; (d) Notices; Certificates or Communications. Immediately upon giving or receipt thereof, copies of any notices, certificates or other communications delivered at the Project or to the Borrower or General Partner naming the Governmental Lender or the Funding Lender as addressee or which could reasonably be deemed to affect the structural integrity of the Project or the ability of the Borrower to perform its obligations under the Borrower Loan Documents and the Funding Loan Documents; (e) Certification of Non-Foreign Status. Promptly upon request of the Funding Lender from time to time, a Certification of Non-Foreign Status, executed on or after the date of such request by the Funding Lender; (f) Compliance Certificates. Together with each of the documents required pursuant to Section 5.23(a) hereof submitted by or on behalf of the Borrower, a statement, in form and substance satisfactory to the Funding Lender and certified by an Authorized Borrower Representative, to the effect that the Borrower is in compliance with all covenants, terms and conditions applicable to the Borrower, under or pursuant to the Borrower Loan Documents and the Funding Loan Documents and under or pursuant to any other Debt owing by the Borrower to any Person, and disclosing any noncompliance therewith, and any Event of Default or Potential Default, and describing the status of the Borrower’s actions to correct such noncompliance, Event of Default or Potential Default, as applicable; and (g) Other Items and Information. Such other information concerning the assets, business, financial condition, operations, property, prospects and results of operations of the Borrower, General Partner, Guarantor or the Project, as the Funding Lender or the Governmental Lender reasonably requests from time to time. In addition, and notwithstanding the foregoing, the Governmental Lender shall receive from the Borrower all reports required under the Regulatory Agreement. 37 4894-2953-3827.5 Section 5.24 Additional Notices. The Borrower will, promptly after becoming aware thereof, give notice to the Funding Lender and the Governmental Lender of: (a) any Lien affecting the Project, or any part thereof, other than Liens expressly permitted under this Borrower Loan Agreement; (b) any Legal Action which is instituted by or against the Borrower, General Partner or Guarantor, or any Legal Action which is threatened against the Borrower, General Partner or Guarantor which, in any case, if adversely determined, could have a material adverse effect upon the business, operations, properties, assets, management, ownership or condition (financial or otherwise) of the Borrower, General Partner, Guarantor or the Project; (c) any Legal Action which constitutes an Event of Default or a Potential Default or a default under any other Contractual Obligation to which the Borrower, General Partner or Guarantor is a party or by or to which the Borrower, General Partner or Guarantor, or any of their respective properties or assets, may be bound or subject, which default would have a material adverse effect on the business, operations, assets (including the Project), condition (financial or otherwise) or prospects of the Borrower, General Partner or Guarantor, as applicable; (d) any default, alleged default or potential default on the part of the Borrower under the Subordinate Loan Documents or any of the CC&R’s (together with a copy of each notice of default, alleged default or potential default received from any other party thereto); (e) any notice of material default, alleged material default or potential material default on the part of the Borrower received from any tenant or occupant of the Project under or relating to its lease or occupancy agreement (together with a copy of any such notice), if, in the aggregate, notices from at least fifteen percent (15%) of the tenants at the Project have been received by the Borrower with respect to, or alleging, the same default, alleged default or potential default; (f) any change or contemplated change in (i) the location of the Borrower’s or General Partner’s executive headquarters or principal place of business; (ii) the legal, trade, or fictitious business names used by the Borrower or General Partner; or (iii) the nature of the trade or business of the Borrower; and (g) any default, alleged default or potential default on the part of any partner (including, without limitation, General Partner and the Equity Investor) under the Partnership Agreement. Section 5.25 Compliance with Other Agreements; Legal Requirements. (a) The Borrower shall timely perform and comply with and shall cause General Partner to timely perform and comply with the covenants, agreements, obligations and restrictions imposed on them under the Partnership Agreement, and the Borrower shall not do or permit to be done anything to impair any such party’s rights or interests under any of the foregoing. (b) The Borrower will comply and, to the extent it is able, will require others to comply with, all Legal Requirements of all Governmental Authorities having jurisdiction over the Project, and will furnish the Funding Lender with reports of any official searches for or notices of violation of any requirements established by such Governmental Authorities. The Borrower will comply and, to the extent it is able, will use commercially reasonable efforts to cause others to comply, with applicable CC&R’s and all restrictive covenants and all obligations created by private contracts and leases which affect ownership, construction, rehabilitation, equipping, fixturing, use or operation of the Project, and all other 38 4894-2953-3827.5 agreements requiring a certain percentage of the Units to be rented to persons of low or moderate income. The Improvements comply with all applicable building, zoning and other Legal Requirements, and do not violate any restrictions of record against the Project or the terms of any other lease of all or any portion of the Project. The Funding Lender shall at all times have the right to audit, at the Borrower’s expense, the Borrower’s compliance with any agreement requiring a certain percentage of the Units to be rented to persons of low or moderate income, and the Borrower shall supply all such information with respect thereto as Funding Lender may request and otherwise cooperate with the Funding Lender in any such audit; provided, however, that so long as no Event of Default has occurred and is continuing, the Borrower shall have no obligation to bear the expense of more than one (1) audit ever three years. Without limiting the generality of the foregoing, the Borrower shall properly obtain, comply with and keep in effect (and promptly deliver copies to the Funding Lender of) all permits, licenses and approvals which are required to be obtained from Governmental Authorities in order to construct, occupy, operate, market and lease the Project. Section 5.26 Maintenance of Project. The Borrower shall maintain the Project as a residential apartment complex in good order and condition, ordinary wear and tear excepted. A maintenance program shall be in place at all times to assure the continuation of first class maintenance. Section 5.27 Fixtures. The Borrower shall deliver to the Funding Lender, on demand, any contracts, bills of sale, statements, receipted vouchers or agreements under which the Borrower or any other Person claims title to any materials, fixtures or articles incorporated into the Improvements. Section 5.28 Income from Project. The Borrower shall first apply all Gross Income to Expenses of the Project, including all amounts then required to be paid under the Borrower Loan Documents and the Funding Loan Documents and the funding of all sums necessary to meet the Replacement Reserve Fund Requirement, before using or applying such Gross Income for any other purpose Section 5.29 Leases and Occupancy Agreements. (a) Lease Approval. (i) Borrower may enter into leases of space within the Improvements (and amendments to such leases) in the ordinary course of business with bona fide third-party tenants without the Funding Lender’s prior Written Consent if: (A) The lease is a Permitted Lease; (B) The Borrower, acting in good faith following the exercise of due diligence, has determined that the tenant meets requirements imposed under any applicable CC&R and is financially capable of performing all of its obligations under the lease; and (ii) If any Event of Default has occurred and is continuing, the Funding Lender may make written demand on the Borrower to submit all future leases for the Funding Lender’s approval prior to execution. The Borrower shall comply with any such demand by the Funding Lender. (iii) No approval of any lease by the Funding Lender shall be for any purpose other than to protect the Funding Lender’s security for the Permanent Phase Borrower Loan and to preserve the Funding Lender’s rights under the Borrower Loan Documents and the Funding Loan Documents. No approval by the Funding Lender shall result in a waiver of any default of the Borrower. In no event shall 39 4894-2953-3827.5 any approval by Funding Lender of a lease be a representation of any kind with regard to the lease or its enforceability, or the financial capacity of any tenant or guarantor. (b) Landlord’s Obligations. The Borrower shall perform all obligations required to be performed by it as landlord under any lease affecting any part of the Project or any space within the Improvements. (c) Leasing and Marketing Agreements. Except as may be contemplated in the Management Agreement with the Property Manager, the Borrower shall not without the approval of the Funding Lender enter into any leasing or marketing agreement and the Funding Lender reserves the right to approve the qualifications of any marketing or leasing agent. Section 5.30 Project Agreements and Licenses. To the extent not heretofore delivered to the Funding Lender, the Borrower will furnish to the Funding Lender, as soon as available, true and correct copies of all Project Agreements and Licenses and the Plans and Specifications, together with assignments thereof to the Funding Lender and consents to such assignments where required by the Funding Lender, all in form and substance acceptable to the Funding Lender. Neither the Borrower nor General Partner has assigned or granted, or will assign or grant, a security interest in any of the Project Agreements and Licenses, other than to Funding Lender. Section 5.31 Payment of Debt Payments. In addition to its obligations under the Permanent Phase Borrower Note, the Borrower will (i) duly and punctually pay or cause to be paid all principal of and interest on any Debt of the Borrower as and when the same become due on or before the due date; (ii) comply with and perform all conditions, terms and obligations of other instruments or agreements evidencing or securing such Debt; (iii) promptly inform the Funding Lender of any default, or anticipated default, under any such note, agreement, instrument; and (iv) forward to the Funding Lender a copy of any notice of default or notice of any event that might result in default under any such note, agreement, instrument, including Liens encumbering the Project, or any portion thereof, which have been subordinated to the Security Instrument (regardless of whether or not permitted under this Borrower Loan Agreement). Section 5.32 ERISA. To the extent applicable, the Borrower will comply, and will cause each of its ERISA Affiliates to comply, in all respects with the provisions of ERISA. Section 5.33 Patriot Act Compliance. The Borrower shall use its good faith and commercially reasonable efforts to comply with the Patriot Act and all applicable requirements of Governmental Authorities having jurisdiction over the Borrower and/or the Project, including those relating to money laundering and terrorism. The Funding Lender shall have the right to audit the Borrower’s compliance with the Patriot Act and all applicable requirements of Governmental Authorities having jurisdiction over the Borrower and/or the Project, including those relating to money laundering and terrorism. In the event that the Borrower fails to comply with the Patriot Act or any such requirements of Governmental Authorities, then the Funding Lender may, at its option, cause Borrower to comply therewith and any and all costs and expenses incurred by Funding Lender in connection therewith shall be secured by the Security Instrument and shall be immediately due and payable. Borrower covenants that it shall comply with all Legal Requirements and internal requirements of Funding Lender relating to money laundering, anti-terrorism, trade embargos and economic sanctions, now or hereafter in effect. Without limiting the foregoing, Borrower shall not take any action, or permit any action to be taken, that would cause Borrower’s representations and warranties in Section 4.1.48 and this Section 5.32 to become untrue or inaccurate at any time during the term of the Funding Loan. Upon any Beneficiary Party’s request from time to time during the term of the Funding Loan, Borrower shall certify 40 4894-2953-3827.5 in writing to such Beneficiary Party that Borrower’s representations, warranties and obligations under Section 4.1.48 and this Section 5.32 remain true and correct and have not been breached, and in addition, upon request of any Beneficiary Party, Borrower covenants to provide all information required to satisfy obligations under all Legal Requirements and internal requirements of Funding Lender relating to money laundering, anti-terrorism, trade embargos and economic sanctions, now or hereafter in effect, during the term of the Funding Loan. Borrower shall immediately notify the Funding Lender in writing of (a) Borrower’s actual knowledge that any of such representations, warranties or covenants are no longer true and have been breached, (b) Borrower has a reasonable basis to believe that they may no longer be true and have been breached or (c) Borrower becomes the subject of an investigation by Governmental Authorities related to money laundering, anti-terrorism, trade embargos and economic sanctions. Borrower shall also reimburse Funding Lender for any reasonable expense incurred by Funding Lender in evaluating the effect of an investigation by Governmental Authorities on the Funding Loan and Funding Lender’s interest in the collateral for the Funding Loan, in obtaining necessary license from Governmental Authorities as may be necessary for Funding Lender to enforce its rights under the Funding Loan Documents, and in complying with all Legal Requirements and internal requirements of Funding Lender relating to money laundering, anti-terrorism, trade embargos and economic sanctions, now or hereafter in effect applicable to Funding Lender as a result of the existence of such an event and for any penalties or fines imposed upon Funding Lender as a result thereof. Section 5.34 Funds from Equity Investor. The Borrower shall cause the Equity Investor to fund all installments of the Equity Contributions in the amounts and at the times subject and according to the terms of the Partnership Agreement. Section 5.35 Tax Covenants. The Borrower further represents, warrants and covenants as follows: (a) General. The Borrower shall not take any action or omit to take any action which, if taken or omitted, respectively, would adversely affect the exclusion of interest on the Governmental Lender Note from gross income (as defined in Section 61 of the Code), for federal income tax purposes and, if it should take or permit any such action, the Borrower will take all lawful actions that it can take to rescind such action promptly upon having knowledge thereof and that the Borrower will take such action or actions, including amendment of this Borrower Loan Agreement, the Security Instrument and the Regulatory Agreement, as may be necessary, in the opinion of Tax Counsel, to comply fully with all applicable rules, rulings, policies, procedures, regulations or other official statements promulgated or proposed by the Department of the Treasury or the Internal Revenue Service applicable to the Governmental Lender Note, the Funding Loan or affecting the Project. Capitalized terms used in this Section 5.35 shall have the respective meanings assigned to them in the Regulatory Agreement or, if not defined therein, in the Funding Loan Agreement. With the intent not to limit the generality of the foregoing, the Borrower covenants and agrees that, prior to the final maturity of the Governmental Lender Note, unless it has received and filed with the Governmental Lender and the Funding Lender a Tax Counsel No Adverse Effect Opinion (other than with respect to interest on any portion of the Governmental Lender Note for a period during which such portion of the Governmental Lender Note is held by a “substantial user” of any facility financed with the proceeds of the Governmental Lender Note or a “related person,” as such terms are used in Section 147(a) of the Code), the Borrower will comply with this Section 5.35. (b) Use of Proceeds. The use of the net proceeds of the Funding Loan at all times will satisfy the following requirements: (i) Limitation on Net Proceeds. At least ninety-five percent (95%) of the net proceeds of the Funding Loan (within the meaning of the Code) actually expended shall be used to pay Qualified 41 4894-2953-3827.5 Project Costs that are costs of a “qualified residential rental project” (within the meaning of Sections 142(a)(7) and 142(d) of the Code) and property that is “functionally related and subordinate” thereto (within the meaning of Sections 1.103-8(a)(3) and 1.103-8(b)(4)(iii) of the Regulations). (ii) Limit on Costs of Issuance. The proceeds of the Funding Loan will be expended for the purposes set forth in this Borrower Loan Agreement and in the Funding Loan Agreement and no portion thereof in excess of two percent (2%) of the proceeds of the Funding Loan, within the meaning of Section 147(g) of the Code, will be expended to pay costs of issuance of the Funding Loan. (iii) Prohibited Facilities. The Borrower shall not use or permit the use of any proceeds of the Funding Loan or any income from the investment thereof to provide any airplane, skybox, or other private luxury box, health club facility, any facility primarily used for gambling, or any store the principal business of which is the sale of alcoholic beverages for consumption off premises. (iv) Limitation on Land. Less than twenty-five percent (25%) of the net proceeds of the Funding Loan actually expended will be used, directly or indirectly, for the acquisition of land or an interest therein, nor will any portion of the net proceeds of the Funding Loan be used, directly or indirectly, for the acquisition of land or an interest therein to be used for farming purposes. (v) Limitation on Existing Facilities. No portion of the net proceeds of the Funding Loan will be used for the acquisition of any existing property or an interest therein unless (A) the first use of such property is pursuant to such acquisition or (B) the construction expenditures with respect to any building and the equipment therefor equal or exceed fifteen percent (15%) of the cost of acquiring such building financed with the proceeds of the Funding Loan (with respect to structures other than buildings, this clause shall be applied by substituting one hundred percent (100%) for fifteen percent (15%)). For purposes of the preceding sentence, the term “construction expenditures” shall have the meaning set forth in Section 147(d)(3) of the Code. (vi) Accuracy of Information. The information furnished by the Borrower and used by the Governmental Lender in preparing its certifications with respect to Section 148 of the Code and the Borrower’s information statement pursuant to Section 149(e) of the Code is accurate and complete as of the date of origination of the Funding Loan. (vii) Limitation of Project Expenditures. The acquisition, construction and equipping of the Project were not commenced (each within the meaning of Section 144(a) of the Code) prior to the 60th day preceding the adoption of the resolution of the Governmental Lender with respect to the Project on March 28, 2022, and no obligation for which reimbursement will be sought from proceeds of the Funding Loan relating to the acquisition, construction or equipping of the Project was paid or incurred prior to 60 days prior to such date, except for permissible “preliminary expenditures” not in excess of 20% of the aggregate issue price of the Funding Loan which include architectural, engineering surveying, soil testing, reimbursement bond issuance and similar costs (other than land acquisition, site preparation and similar costs incident to commencement of construction) incurred prior to the commencement of the construction or acquisition of the Project. (viii) Qualified Costs. The Borrower hereby represents, covenants and warrants that the proceeds of the Funding Loan shall be used or deemed used exclusively to pay costs which (i) are (A) capital expenditures (as defined in Section 1.150-1(a) of the Code’s regulations) and (B) not made for the acquisition of existing property, to the extent prohibited in Section 147(d) of the Code, and that for the greatest number of buildings the proceeds of the Funding Loan shall be deemed allocated on a pro rata basis to each building in the Project and the land on which it is located so that the buildings (including eligible furniture and fixtures and functionally related subordinate facilities) and the land on which they are located 42 4894-2953-3827.5 will have been financed fifty percent (50%) or more by the proceeds of the Funding Loan for the purpose of complying with Section 42(h)(4)(B) of the Code; provided however, the foregoing representation, covenant and warranty is made for the benefit of the Borrower and its partners and neither the Funding Lender nor the Governmental Lender shall have any obligation to enforce this statement nor shall they incur any liability to any person, including without limitation, the Borrower, the partners of the Borrower, any other affiliate of the Borrower or the holders or payees of the Funding Loan and the Permanent Phase Borrower Note for any failure to meet the intent expressed in the foregoing representation, covenant and warranty; and provided further, failure to comply with this representation, covenant and warranty shall not constitute a default or event of default under this Borrower Loan Agreement or the Funding Loan Agreement. (c) Limitation on Maturity. The average maturity of the Governmental Lender Note does not exceed 120 percent of the average reasonably expected economic life of the Project to be financed by the Funding Loan, weighted in proportion to the respective cost of each item comprising the property the cost of which has been or will be financed, directly or indirectly, with the Net Proceeds of the Funding Loan. For purposes of the preceding sentence, the reasonably expected economic life of property shall be determined as of the later of (A) the Delivery Date for the Funding Loan or (B) the date on which such property is placed in service (or expected to be placed in service). In addition, land shall not be taken into account in determining the reasonably expected economic life of property. (d) No Arbitrage. The Borrower shall not take any action or omit to take any action with respect to the Gross Proceeds of the Governmental Lender Note or of any amounts expected to be used to pay the principal thereof or the interest thereon which, if taken or omitted, respectively, would cause a Governmental Lender Note to be classified as an “arbitrage bond” within the meaning of Section 148 of the Code. Except as provided in the Funding Loan Agreement and this Borrower Loan Agreement, the Borrower shall not pledge or otherwise encumber, or permit the pledge or encumbrance of, any money, investment, or investment property as security for payment of any amounts due under this Borrower Loan Agreement or the Permanent Phase Borrower Note relating to the Funding Loan, shall not establish any segregated reserve or similar fund for such purpose and shall not prepay any such amounts in advance of the redemption date of an equal principal amount of the Funding Loan, unless the Borrower has obtained in each case a Tax Counsel No Adverse Effect Opinion with respect to such action, a copy of which shall be provided to the Governmental Lender and the Funding Lender. The Borrower shall not, at any time prior to the final maturity of the Funding Loan, invest or cause any Gross Proceeds to be invested in any investment (or to use Gross Proceeds to replace money so invested), if, as a result of such investment the Yield of all investments acquired with Gross Proceeds (or with money replaced thereby) on or prior to the date of such investment exceeds the Yield of the Funding Loan to the Maturity Date, except as permitted by Section 148 of the Code and Regulations thereunder or as provided in the Regulatory Agreement. The Borrower further covenants and agrees that it will comply with all applicable requirements of said Section 148 and the rules and Regulations thereunder relating to the Funding Loan and the interest thereon, including, subject to the second paragraph of this Section 5.35(d), the employment of a Rebate Analyst acceptable to the Governmental Lender and Funding Lender at all times from and after the Delivery Date for the calculation of rebatable amounts to the United States Treasury Department. Subject to the second paragraph of this Section 5.35(d), The Borrower agrees that it will cause the Rebate Analyst to calculate the rebatable amounts not later than forty-five days after the fifth anniversary of the Delivery Date and each five years thereafter and not later than forty-five days after the final Computation Date and agrees that the Borrower will pay all costs associated therewith. Subject to the second paragraph of this Section 5.35(d), The Borrower agrees to provide evidence of the employment of the Rebate Analyst satisfactory to the Governmental Lender and Funding Lender. Notwithstanding the foregoing provisions of this subparagraph (d) with respect to the engagement of a Rebate Analyst, the Borrower shall not be required to engage a Rebate Analyst so long as on each 43 4894-2953-3827.5 Computation Date, the Borrower provides to the Funding Lender and the Fiscal Agent a written certification that, as of such Computation Date, no moneys have been received with respect to the Permanent Phase Borrower Loan or, to the Borrower’s knowledge, after diligent inquiry, the Funding Loan which, under the Funding Loan Documents, are pledged directly or indirectly to pay principal and/or interest on the Permanent Phase Borrower Loan or the Funding Loan, other than regularly scheduled payments of principal and interest on the Permanent Phase Borrower Loan. If such certification is not given when due, the Borrower agrees to immediately (and no later than 15 days after such Computation Date) engage a Rebate Analyst and to have the Rebate Analyst remain engaged to calculate any Rebate Amount which might be owed with respect to the Governmental Lender Note with respect to such Computation Date. (e) No Federal Guarantee. Except to the extent permitted by Section 149(b) of the Code and the Regulations and rulings thereunder, the Borrower shall not take or omit to take any action which would cause the Governmental Lender Note to be “federally guaranteed” within the meaning of Section 149(b) of the Code and the Regulations and rulings thereunder. (f) Representations. The Borrower has supplied or caused to be supplied to Tax Counsel all documents, instruments and written information requested by Tax Counsel, and all such documents, instruments and written information supplied by or on behalf of the Borrower at the request of Tax Counsel, which have been reasonably relied upon by Tax Counsel in rendering its opinion with respect to the exclusion from gross income of the interest on the Governmental Lender Note for federal income tax purposes, are true and correct in all material respects, do not contain any untrue statement of a material fact and do not omit to state any material fact necessary to be stated therein in order to make the information provided therein, in light of the circumstances under which such information was provided, not misleading, and the Borrower is not aware of any other pertinent information which Tax Counsel has not requested. (g) Qualified Residential Rental Project. The Borrower hereby covenants and agrees that the Project will be operated as a “qualified residential rental project” within the meaning of Section 142(d) of the Code, on a continuous basis during the longer of the Qualified Project Period (as defined in the Regulatory Agreement) or any period during which any portion of the Governmental Lender Note remains outstanding, to the end that the interest on the Governmental Lender Note shall be excluded from gross income for federal income tax purposes. The Borrower hereby covenants and agrees, continuously during the Qualified Project Period, to comply with all the provisions of the Regulatory Agreement. (h) Information Reporting Requirements. The Borrower will comply with the information reporting requirements of Section 149(e)(2) of the Code requiring certain information regarding the Governmental Lender Note to be filed with the Internal Revenue Service within prescribed time limits. (i) Funding Loan Not a Hedge Bond. The Borrower covenants and agrees that not more than 50% of the proceeds of the Funding Loan will be invested in Nonpurpose Investments having a substantially guaranteed Yield for four years or more within the meaning of Section 149(f)(3)(A)(ii) of the Code, and the Borrower reasonably expects that at least 85% of the spendable proceeds of the Funding Loan will be used to carry out the governmental purposes of the Funding Loan within the three-year period beginning on the Delivery Date. (j) Termination of Restrictions. Although the parties hereto recognize that, subject to the provisions of the Regulatory Agreement, the provisions of this Borrower Loan Agreement shall terminate in accordance with Section 10.13 hereof, the parties hereto recognize that pursuant to the Regulatory Agreement, certain requirements, including the requirements incorporated by reference in this Section, may continue in effect beyond the term hereof. 44 4894-2953-3827.5 (k) Public Approval. The Borrower covenants and agrees that the proceeds of the Funding Loan will not be used in a manner that deviates in any substantial degree from the Project described in the written notice of a public hearing regarding the Funding Loan. (l) 40/60 Test Election. The Borrower and the Governmental Lender hereby elect to apply the requirements of Section 142(d)(1)(B) to the Project. The Borrower hereby represents, covenants and agrees, continuously during the Qualified Project Period, to comply with all the provisions of the Regulatory Agreement. (m) Modification of Tax Covenants. Subsequent to the origination of the Funding Loan and prior to its payment in full (or provision for the payment thereof having been made in accordance with the provisions of the Funding Loan Agreement), this Section 5.35 hereof may not be amended, changed, modified, altered or terminated except as permitted herein and by the Funding Loan Agreement and with the Written Consent of the Governmental Lender and the Funding Lender. Anything contained in this Borrower Loan Agreement or the Funding Loan Agreement to the contrary notwithstanding, the Governmental Lender, the Funding Lender and the Borrower hereby agree to amend this Borrower Loan Agreement and, if appropriate, the Funding Loan Agreement and the Regulatory Agreement, to the extent required, in the opinion of Tax Counsel, in order for interest on the Governmental Lender Note to remain excludable from gross income for federal income tax purposes. The party requesting such amendment, which may include the Funding Lender, shall notify the other parties to this Borrower Loan Agreement of the proposed amendment and send a copy of such requested amendment to Tax Counsel. After review of such proposed amendment, Tax Counsel shall render to the Funding Lender and the Governmental Lender an opinion to the effect that such proposed amendment will not adversely impact the excludability of interest on the Governmental Lender Note in the gross income of the recipient thereof for federal income tax purposes. The Borrower shall pay all necessary fees and expenses incurred with respect to such amendment. The Borrower, the Governmental Lender and, where applicable, the Funding Lender per written instructions from the Governmental Lender shall execute, deliver and, if applicable, the Borrower shall file of record, any and all documents and instruments, including without limitation, an amendment to the Regulatory Agreement, with a file-stamped copy to the Funding Lender, necessary to effectuate the intent of this Section 5.35, and the Borrower and the Governmental Lender hereby appoint the Funding Lender as their true and lawful attorney-in-fact to execute, deliver and, if applicable, file of record on behalf of the Borrower or the Governmental Lender, as is applicable, any such document or instrument (in such form as may be approved by and upon instruction of Tax Counsel) if either the Borrower or the Governmental Lender defaults in the performance of its obligation under this Section 5.35; provided, however, that the Funding Lender shall take no action under this Section 5.35 without first notifying the Borrower or the Governmental Lender, as is applicable, of its intention to take such action and providing the Borrower or the Governmental Lender, as is applicable, a reasonable opportunity to comply with the requirements of this Section 5.35. The Borrower irrevocably authorizes and directs the Funding Lender and any other agent designated by the Governmental Lender to make payment of such amounts from funds of the Borrower, if any, held by the Funding Lender, or any agent of the Governmental Lender or the Funding Lender. The Borrower further covenants and agrees that, pursuant to the requirements of Treasury Regulation Section 1.148-1(b), it (or any related person contemplated by such regulations) will not purchase interests in the Funding Loan in an amount related to the amount of the Permanent Phase Borrower Loan. Section 5.36 Payment of Rebate. (a) Arbitrage Rebate. The Borrower agrees to take all steps necessary to compute and pay any rebatable arbitrage relating to the Governmental Lender Note in accordance with Section 148(f) of the Code including: 45 4894-2953-3827.5 (i) Delivery of Documents and Money on Computation Dates. The Borrower will deliver to the Fiscal Agent, the Governmental Lender, the Servicer, or, if there is no Servicer, to the Funding Lender, within 55 days after each Computation Date: (A) a statement, signed by the Borrower, stating the Rebate Amount as of such Computation Date; (B) (1) if such Computation Date is an Installment Computation Date, an amount that, together with any amount then held for the credit of the Rebate Fund, is equal to at least 90% of the Rebate Amount as of such Installment Computation Date, less the future value of any “previous rebate payments” made to the United States (as that term is used in Section 1.148-3(f)(1) of the Regulations), or (2) if such Computation Date is the final Computation Date, an amount that, together with any amount then held for the credit of the Rebate Fund, is equal to the Rebate Amount as of such final Computation Date, less the future value of any “previous rebate payments” made to the United States (as that term is used in Section 1.148-3(f)(1) of the Regulations); and (C) an Internal Revenue Service Form 8038-T properly signed and completed as of such Computation Date. (ii) Correction of Underpayments. If the Borrower shall discover or be notified as of any date that any payment paid to the United States Treasury pursuant to this Section 5.36 of an amount described in Section 5.36(a)(i)(A) or (B) above shall have failed to satisfy any requirement of Section 1.148- 3 of the Regulations (whether or not such failure shall be due to any default by the Borrower, the Governmental Lender or the Funding Lender), the Borrower shall (1) pay to the Servicer (for deposit to the Rebate Fund) and cause the Fiscal Agent to pay to the United States Treasury from the Rebate Fund the underpayment of the Rebate Amount, together with any penalty and/or interest due, as specified in Section 1.148-3(h) of the Regulations, within 175 days after any discovery or notice and (2) deliver to the Servicer an Internal Revenue Service Form 8038-T completed as of such date. If such underpayment of the Rebate Amount, together with any penalty and/or interest due, is not paid to the United States Treasury in the amount and manner and by the time specified in the Regulations, the Borrower shall take such steps as are necessary to prevent the Governmental Lender Note from becoming an arbitrage bond within the meaning of Section 148 of the Code. (iii) Records. The Borrower shall retain all of its accounting records relating to the funds established under this Borrower Loan Agreement and all calculations made in preparing the statements described in this Section 5.36 for at least six years after the later of the final maturity of the Governmental Lender Note or the date the Funding Loan is retired in full. (iv) Costs. The Borrower agrees to pay all of the fees and expenses of a nationally recognized Tax Counsel, the Rebate Analyst, a certified public accountant and any other necessary consultant employed by the Borrower or the Funding Lender in connection with computing the Rebate Amount. (v) No Diversion of Rebatable Arbitrage. The Borrower will not indirectly pay any amount otherwise payable to the federal government pursuant to the foregoing requirements to any person other than the federal government by entering into any investment arrangement with respect to the Gross Proceeds of the Funding Loan which is not purchased at Fair Market Value or includes terms that the Borrower would not have included if the Funding Loan were not subject to Section 148(f) of the Code. (vi) Modification of Requirements. If at any time during the term of this Borrower Loan Agreement, the Governmental Lender, the Funding Lender or the Borrower desires to take any action 46 4894-2953-3827.5 which would otherwise be prohibited by the terms of this Section 5.36, such Person shall be permitted to take such action if it shall first obtain and provide to the other Persons named herein a Tax Counsel No Adverse Effect Opinion with respect to such action. (b) Rebate Fund. The Fiscal Agent shall establish under the Funding Loan Agreement and hold a separate fund designated as the “Rebate Fund.” The Servicer shall deposit or transfer to the credit of the Rebate Fund each amount delivered to the Servicer by the Borrower for deposit thereto and each amount directed by the Borrower to be transferred thereto. (c) Within fifteen (15) days after each receipt or transfer of funds to the Rebate Fund, the Fiscal Agent shall withdraw from the Rebate Fund and pay to the United States of America the entire balance of the Rebate Fund. (d) All payments to the United States of America pursuant to this Section 5.36 shall be made by the Fiscal Agent for the account and in the name of the Governmental Lender and shall be paid through the United States Mail (return receipt requested or overnight delivery), addressed to the appropriate Internal Revenue Service Center and accompanied by the appropriate Internal Revenue Service forms (such forms to be provided to the Servicer by the Borrower or the Rebate Analyst as set forth in this Section 5.36). (e) The Borrower shall preserve all statements, forms and explanations received or delivered pursuant this Section 5.36 and all records of transactions in the Rebate Fund until six years after the retirement of the Funding Loan. (f) Moneys and securities held in the Rebate Fund shall not be deemed funds of the Funding Lender, the Fiscal Agent or of the Governmental Lender and are not pledged or otherwise subject to any security interest in favor of the Funding Lender to secure the Funding Loan or any other obligations. (g) Notwithstanding anything to the contrary in this Borrower Loan Agreement, no payment shall be made to the United States if the Borrower shall furnish to the Governmental Lender, the Fiscal Agent and the Funding Lender an opinion of Tax Counsel to the effect that such payment is not required under Section 148(d) and (f) of the Code in order to maintain the exclusion from gross income for federal income tax purposes of interest on the Governmental Lender Note. In such event, the Borrower shall be entitled to withdraw funds from the Rebate Fund to the extent the Borrower shall provide a Tax Counsel No Adverse Effect Opinion to the Governmental Lender, the Fiscal Agent and the Funding Lender with respect to such withdrawal. (h) Notwithstanding the foregoing, the computations and payments of rebate amounts referred to in this Section 5.36 need not be made to the extent that neither the Governmental Lender nor the Borrower will thereby fail to comply with any requirements of Section 148(f) of the Code based on a Tax Counsel No Adverse Effect Opinion, a copy of which shall be provided to the Funding Lender and the Fiscal Agent. Section 5.37 Covenants under Funding Loan Agreement. The Borrower will fully and faithfully perform all the duties and obligations which the Governmental Lender has covenanted and agreed in the Funding Loan Agreement to cause the Borrower to perform and any duties and obligations which the Borrower is required in the Funding Loan Agreement to perform. The foregoing will not apply 47 4894-2953-3827.5 to any duty or undertaking of the Governmental Lender which by its nature cannot be delegated or assigned. Section 5.38 Continuing Disclosure Agreement. The Borrower and the Funding Lender shall enter into the Continuing Disclosure Agreement to provide for the continuing disclosure of information about the Funding Loan, the Borrower and other matters as specifically provided for in such agreement. The duties and obligations of the Borrower under the Continuing Disclosure Agreement shall be as set forth in the Continuing Disclosure Agreement. The Governmental Lender shall be a third-party beneficiary under the Continuing Disclosure Agreement and as such shall be entitled to copies of all filings and reports required thereunder. Section 5.39 Subordinate Loans. Borrower shall comply in all respects with all of the covenants contained in the Subordinate Loan Documents. Borrower shall deliver to Funding Lender for its prior written approval all requests for proceeds of the Subordinate Loans, together with copies of any other forms for construction-related or non-construction-related disbursements submitted by Borrower in connection with the Subordinate Loans. ARTICLE VI NEGATIVE COVENANTS The Borrower hereby covenants and agrees as follows, which covenants shall remain in effect so long as any Borrower Payment Obligation or other obligation of the Borrower under any of the other Borrower Loan Documents or the Funding Loan Documents remains outstanding or unperformed. The Borrower covenants and agrees that it will not, directly or indirectly: Section 6.1 Management Agreement. Without first obtaining the Funding Lender’s prior Written Consent, enter into the Management Agreement, and thereafter the Borrower shall not, without the Funding Lender’s prior Written Consent (which consent shall not be unreasonably withheld) and subject to the Regulatory Agreement: (i) surrender, terminate or cancel the Management Agreement or otherwise replace the Property Manager or enter into any other management agreement; (ii) reduce or consent to the reduction of the term of the Management Agreement; (iii) increase or consent to the increase of the amount of any charges under the Management Agreement; (iv) otherwise modify, change, supplement, alter or amend in any material respect, or waive or release in any material respect any of its rights and remedies under, the Management Agreement; or (v) suffer or permit the occurrence and continuance of a default beyond any applicable cure period under the Management Agreement (or any successor management agreement) if such default permits the Property Manager to terminate the Management Agreement (or such successor management agreement); provided, however, that Funding Lender’s prior Written Consent shall not be required for any extension or renewal of the Management Agreement on the same terms and conditions. Section 6.2 Dissolution. Dissolve or liquidate, in whole or in part, merge with or consolidate into another Person. Section 6.3 Change in Business or Operation of Property. Enter into any line of business other than the ownership and operation of the Project, or make any material change in the scope or nature of its business objectives, purposes or operations, or undertake or participate in activities other than the 48 4894-2953-3827.5 continuance of its present business and activities incidental or related thereto or otherwise cease to operate the Project as a multi-family property or terminate such business for any reason whatsoever. Section 6.4 Debt Cancellation. Cancel or otherwise forgive or release any claim or debt owed to the Borrower by a Person, except for adequate consideration or in the ordinary course of the Borrower’s business in its reasonable judgment. Section 6.5 Assets. Purchase or own any real property or personal property incidental thereto other than the Project. Section 6.6 Transfers. Make, suffer or permit the occurrence of any Transfer other than a transfer permitted under the Security Instrument, nor transfer any material License required for the operation of the Project. Section 6.7 Debt. Other than as expressly approved in writing by the Funding Lender, create, incur or assume any indebtedness for borrowed money (including subordinate debt) whether unsecured or secured by all or any portion of the Project or interest therein or in the Borrower or any partner thereof (including subordinate debt) other than (i) the Borrower Payment Obligations, (ii) secured indebtedness incurred pursuant to or permitted by the Borrower Loan Documents and the Funding Loan Documents, (iii) trade payables incurred in the ordinary course of business, (iv) the Subordinate Loans, and (v) unsecured deferred developer fees as permitted pursuant to the terms of the Development Services Agreement. Partners of the Borrower may make unsecured loans to the Borrower in accordance with the Partnership Agreement. Section 6.8 Assignment of Rights. Without the Funding Lender’s prior Written Consent, attempt to assign the Borrower’s rights or interest under any Borrower Loan Document or Funding Loan Document in contravention of any Borrower Loan Document or Funding Loan Document. Section 6.9 Principal Place of Business. Change its principal place of business without providing 30 days’ prior Written Notice of the change to the Funding Lender, the Governmental Lender, the Fiscal Agent and the Servicer. Section 6.10 Partnership Agreement. Without the Funding Lender’s prior Written Consent (which consent shall not be unreasonably withheld, conditioned or delayed) surrender, terminate, cancel, modify, change, supplement, alter or amend in any material respect, or waive or release in any material respect, any of its rights or remedies under the Partnership Agreement; provided, however, the consent of the Funding Lender is not required for (i) modifications necessary to reflect the occurrence of a “Permitted Transfer” as defined in and permitted by the Security Instrument or (ii) modifications that do not: (A) impose any additional or greater obligations on the Borrower or any of the partners, managers or members of Borrower, (B) reduce or relieve the Borrower or any of the partners of the Borrower of any of their obligations, (C) modify the timing, amounts, number, conditions or other terms of the installments or other payment obligations of the partners or members of the Borrower or (D) impair the collateral for the loan from the Funding Lender; provided, however, that the Borrower shall promptly provide to the Funding Lender a copy of any modifications to the Borrower’s organizational documents that do not require the Funding Lender’s consent. Section 6.11 ERISA. To the extent applicable, maintain, sponsor, contribute to or become obligated to contribute to, or suffer or permit any ERISA Affiliate of the Borrower to, maintain, sponsor, 49 4894-2953-3827.5 contribute to or become obligated to contribute to, any Plan, or permit the assets of the Borrower to become “plan assets,” whether by operation of law or under regulations promulgated under ERISA. Section 6.12 No Hedging Arrangements. Without the prior Written Consent of the Funding Lender or unless otherwise required by this Borrower Loan Agreement, the Borrower will not enter into or guarantee, provide security for or otherwise undertake any form of contractual obligation with respect to any interest rate swap, interest rate cap or other arrangement that has the effect of an interest rate swap or interest rate cap or that otherwise (directly or indirectly, derivatively or synthetically) hedges interest rate risk associated with being a debtor of variable rate debt or any agreement or other arrangement to enter into any of the above on a future date or after the occurrence of one or more events in the future. Section 6.13 Loans and Investments; Distributions; Related Party Payments. Without the prior Written Consent of the Funding Lender in each instance, the Borrower shall not (i) lend money, make investments, or extend credit, other than in the ordinary course of its business as presently conducted; or (ii) repurchase, redeem or otherwise acquire any interest in the Borrower, any Borrower Affiliate or any other Person owning an interest, directly or indirectly, in the Borrower, or make any distribution, in cash or in kind, in respect of interests in the Borrower, any Borrower Affiliate or any other Person owning an interest, directly or indirectly, in the Borrower (except to the extent permitted by the Security Instrument and subject to the limitations set forth in Section 5.28 hereof). Section 6.14 Amendment of Related Documents or CC&R’s. Without the prior Written Consent of Funding Lender in each instance, except as provided herein or in the Loan Covenant Agreement, Borrower shall not enter into or consent to any amendment, termination, modification, or other alteration of any of the Related Documents or any of the CC&R’s (including, without limitation, those contained in this Borrower Loan Agreement, any Architect’s Agreement or Engineer’s Contract, any Construction Contract, and any Management Agreement, but excluding the Partnership Agreement, which is covered by Section 6.10 hereof), or any assignment, transfer, pledge or hypothecation of any of its rights thereunder, if any. Section 6.15 Personal Property. The Borrower shall not install materials, personal property, equipment or fixtures subject to any security agreement or other agreement or contract wherein the right is reserved to any Person other than the Borrower to remove or repossess any such materials, equipment or fixtures, or whereby title to any of the same is not completely vested in the Borrower at the time of installation, without the Funding Lender’s prior Written Consent; provided, however, that this Section 6.15 shall not apply to laundry equipment or other equipment that is owned by a third-party vendor and commercial tenants. Section 6.16 Fiscal Year. Without the Funding Lender’s Written Consent, which shall not be unreasonably withheld, neither the Borrower nor the General Partner shall change the times of commencement or termination of its fiscal year or other accounting periods, or change its methods of accounting, other than to conform to GAAP. Section 6.17 Publicity. Neither the Borrower nor the General Partner shall issue any publicity release or other communication to any print, broadcast or on-line media, post any sign or in any other way identify the Funding Lender or any of its Affiliates as the source of the financing provided for herein, without the prior written approval of the Funding Lender in each instance (provided that nothing herein shall prevent the Borrower or the General Partner from identifying the Funding Lender or its Affiliates 50 4894-2953-3827.5 as the source of such financing to the extent that the Borrower or the General Partner are required to do so by disclosure requirements applicable to publicly held companies). Section 6.18 Subordinate Loan Documents. Without the Funding Lender’s prior Written Consent, Borrower will not surrender, terminate, cancel, modify, change, supplement, alter, amend, waive, release, assign, transfer, pledge or hypothecate any of its rights or remedies under the Subordinate Loan Documents. Section 6.19 Ground Lease. Without the Funding Lender’s prior written consent, the Borrower will not surrender, terminate, cancel, modify, change, supplement, alter, amend, waive, release, assign, transfer, pledge or hypothecate any of its rights or remedies under the Ground Lease. ARTICLE VII RESERVED ARTICLE VIII DEFAULTS Section 8.1 Events of Default. Each of the following events shall constitute an “Event of Default” under this Borrower Loan Agreement: (a) failure by the Borrower to pay any Borrower Loan Payment in the manner and on the date such payment is due in accordance with the terms and provisions of the Permanent Phase Borrower Note, or the failure by the Borrower to pay any Additional Borrower Payment on the date such payment is due in accordance with the terms and provisions of the Permanent Phase Borrower Note, the Security Instrument, this Borrower Loan Agreement or any other Borrower Loan Document; (b) failure by or on behalf of the Borrower to pay when due any amount (other than as provided in subsections (a) above or elsewhere in this Section 8.1) required to be paid by the Borrower under this Borrower Loan Agreement, the Permanent Phase Borrower Note, the Security Instrument or any of the other Borrower Loan Documents or Funding Loan Documents, including a failure to repay any amounts that have been previously paid but are recovered, attached or enjoined pursuant to any insolvency, receivership, liquidation or similar proceedings, which default remains uncured for a period of five (5) days after Written Notice thereof shall have been given to the Borrower; (c) an Event of Default, as defined or described in the Permanent Phase Borrower Note, the Security Instrument or any other Borrower Loan Document, occurs (or to the extent an “Event of Default” is not defined in any other Borrower Loan Document, any default or breach by the Borrower or any Guarantor of its obligations, covenants, representations or warranties under such Borrower Loan Document occurs and any applicable notice and/or cure period has expired); (d) any representation or warranty made by any of the Borrower, the Guarantor or the General Partner in any Borrower Loan Document or Funding Loan Document to which it is a party, or in any report, certificate, financial statement or other instrument, agreement or document furnished by the Borrower, the Guarantor or the General Partner in connection with any Borrower Loan Document or Funding Loan Document, shall be false or misleading in any material respect as of the Delivery Date; (e) the Borrower shall make a general assignment for the benefit of creditors, or shall generally not be paying its debts as they become due; 51 4894-2953-3827.5 (f) a Borrower Controlling Entity shall make a general assignment for the benefit of creditors, shall generally not be paying its debts as they become due, or an Act of Bankruptcy with respect to the Borrower Controlling Entity shall occur, unless in all cases the Borrower Controlling Entity is replaced with a substitute Borrower Controlling Entity that satisfies the requirements of the Security Instrument; which, in the case of a non-profit controlled by the Borrower Controlling Entity, may be replaced within sixty (60) days of such event with another non-profit not controlled by the Borrower Controlling Entity acceptable to the Funding Lender, in which case no Event of Default shall be deemed to have occurred; (g) the failure by the Borrower or any ERISA Affiliate of the Borrower to comply in all respects with ERISA, if applicable, or the occurrence of any other event (with respect to the failure of the Borrower or any ERISA Affiliate to pay any amount required to be paid under ERISA or with respect to the termination of, or withdrawal of the Borrower or any ERISA Affiliate from, any employee benefit or welfare plan subject to ERISA) the effect of which is to impose upon the Borrower (after giving effect to the tax consequences thereof) for the payment of any amount in excess of Fifty Thousand Dollars ($50,000); (h) a Bankruptcy Event shall occur with respect to the Borrower, any General Partner or Guarantor, or there shall be a change in the assets, liabilities or financial position of any such Person which has a material adverse effect upon the ability of such Person to perform such Person’s obligations under this Borrower Loan Agreement, any other Borrower Loan Document or any Related Document, provided that any such Bankruptcy Event with respect to a Guarantor shall not constitute an Event of Default: (i) if such Bankruptcy Event occurs on or after the date upon which the Guaranty terminates in accordance with its terms (or the date upon which all of the Guaranties have terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor), or (ii) if such Bankruptcy Event occurs prior to the date upon which the Guaranty terminates in accordance with its terms (or the date upon which the Guaranties have terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor) and the Borrower replaces such Guarantor with a person or entity satisfying the Funding Lender’s mortgage credit standards for principals and acceptable to the Funding Lender in its sole and absolute discretion within thirty (30) days after notice thereof from the Funding Lender; (i) all or any part of the property of the Borrower is attached, levied upon or otherwise seized by legal process, and such attachment, levy or seizure is not quashed, stayed or released within thirty (30) days of the date thereof; (j) subject to Section 10.15 hereof, the Borrower fails to pay when due any monetary obligation (other than pursuant to this Borrower Loan Agreement) to any Person in excess of One Hundred Thousand Dollars ($100,000), and such failure continues beyond the expiration of any applicable cure or grace periods; (k) any material litigation or proceeding is commenced before any Governmental Authority against or affecting Borrower, any General Partner or Guarantor, or property of Borrower, any General Partner or Guarantor, or any part thereof, and such litigation or proceeding is not defended diligently and in good faith by Borrower, any General Partner or Guarantor, as applicable, provided that any such material litigation or proceeding against a Guarantor shall not constitute an Event of Default: (i) if such material litigation is commenced on or after the date upon which the Guaranty terminates in accordance with its terms (or the date upon which all of the Guaranties have terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor), or (ii) if such material litigation or proceeding is commenced prior to the date upon which the Guaranty terminates in accordance with its terms (or the date upon which all of the Guaranties have terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor) and the Borrower replaces such Guarantor with a person or entity satisfying the Funding Lender’s mortgage credit standards for principals and acceptable to the 52 4894-2953-3827.5 Funding Lender in its sole and absolute discretion within thirty (30) days after notice thereof from the Funding Lender; (l) a final judgment or decree for monetary damages in excess of Fifty Thousand Dollars ($50,000) or a monetary fine or penalty (not subject to appeal or as to which the time for appeal has expired) is entered against Borrower, any General Partner or Guarantor by any Governmental Authority, and such judgment, decree, fine or penalty is not paid and discharged or stayed within thirty (30) days after entry thereof (or such longer period as may be permitted for payment by the terms of such judgment, fine or penalty) , provided that any such judgment, decree, fine or penalty against a Guarantor shall not constitute an Event of Default: (i) if such judgment, decree, fine or penalty is entered on or after the date upon which the Guaranty terminates in accordance with its terms (or the date upon which each Guaranty has terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor), or (ii) if such judgment, decree, fine or penalty is entered prior to the date upon which the Guaranty terminates in accordance with its terms (or the date upon which each Guaranty has terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor) and the Borrower replaces such Guarantor with a person or entity satisfying the Funding Lender’s mortgage credit standards for principals and acceptable to the Funding Lender in its sole and absolute discretion within thirty (30) days after notice thereof from the Funding Lender; (m) a final, un-appealable and uninsured money judgment or judgments, in favor of any Person other than a Governmental Authority, in the aggregate sum of Fifty Thousand Dollars ($50,000) or more shall be rendered against the Borrower, any General Partner or Guarantor, or against any of their respective assets, that is not paid, superseded or stayed within thirty (30) days after entry thereof (or such longer period as may be permitted for payment by the terms of such judgment); or any levy of execution, writ or warrant of attachment, or similar process, is entered or filed against the Borrower, any General Partner or Guarantor, or against any of their respective assets (that is likely to have a material adverse effect upon the ability of the Borrower, any General Partner or Guarantor to perform their respective obligations under this Borrower Loan Agreement, any other Borrower Loan Document or any Related Document), and such judgment, writ, warrant or process shall remain unsatisfied, unsettled, unvacated, unhanded and unstayed for a period of thirty (30) days, or in any event later than five (5) Business Days prior to the date of any proposed sale thereunder, provided that any such judgment, levy, writ, warrant, attachment or similar process against a Guarantor shall not constitute an Event of Default: (i) if such judgment, levy, writ, warrant, attachment or similar process is entered on or after the date upon which the Guaranty terminates in accordance with its terms (or the date upon which all of the Guaranties have terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor), or (ii) if such judgment, levy, writ, warrant, attachment or similar process is entered prior to the date upon which the Guaranty terminates in accordance with its terms (or the date upon which all of the Guaranties have terminated in accordance with their terms, if more than one Guaranty was executed by such Guarantor) and the Borrower replaces such Guarantor with a person or entity satisfying the Funding Lender’s mortgage credit standards for principals and acceptable to the Funding Lender in its sole and absolute discretion within thirty (30) days after notice thereof from the Funding Lender; (n) the Borrower shall fail to keep in force and effect any material permit, license, consent or approval required under this Borrower Loan Agreement, or any required approval, license, or permit shall be withdrawn or suspended, and the order, requirement, withdrawal or suspension remains in effect for a period of thirty (30) days; (o) a default shall occur under any of the Subordinate Loan Documents, which shall continue beyond the expiration of all applicable notice and cure periods and which shall not be waived by the Subordinate Lender; or 53 4894-2953-3827.5 (p) any failure by the Borrower to perform or comply with any of its obligations under this Borrower Loan Agreement (other than those specified in this Section 8.1), as and when required, which continues for a period of thirty (30) days after written notice of such failure by Funding Lender or the Servicer on its behalf to the Borrower; provided, however, if such failure is susceptible of cure but cannot reasonably be cured within such thirty (30) day period, and the Borrower shall have commenced to cure such failure within such thirty (30) day period and thereafter diligently and expeditiously proceeds to cure the same, such thirty (30) day period shall be extended for an additional period of time as is reasonably necessary for the Borrower in the exercise of due diligence to cure such failure, such additional period not to exceed sixty (60) days. However, no such notice or grace period shall apply to the extent such failure could, in the Funding Lender’s judgment, absent immediate exercise by the Funding Lender of a right or remedy under this Borrower Loan Agreement, result in harm to the Funding Lender, impairment of the Permanent Phase Borrower Note or this Borrower Loan Agreement or any security given under any other Borrower Loan Document. Notwithstanding anything to the contrary contained herein, the Equity Investor shall have the right in its sole discretion to cure an Event of Default and the Funding Lender agrees to accept such performance as if provided by the Borrower itself. Section 8.2 Remedies. Section 8.2.1 Acceleration. Upon the occurrence of an Event of Default (other than an Event of Default described in paragraph (e), (f) or (i) of Section 8.1) and at any time and from time to time thereafter, as long as such Event of Default continues to exist, in addition to any other rights or remedies available to the Governmental Lender pursuant to the Borrower Loan Documents or at law or in equity, the Funding Lender may, take such action (whether directly or by directing the actions of the Fiscal Agent), without notice or demand, as the Funding Lender deems advisable to protect and enforce its rights against the Borrower and in and to the Project, including declaring the Borrower Payment Obligations to be immediately due and payable (including, without limitation, the principal of, Prepayment Premium, if any, and interest on and all other amounts due on the Permanent Phase Borrower Note to be immediately due and payable), without notice or demand, and apply such payment of the Borrower Payment Obligations in any manner and in any order determined by Funding Lender, in Funding Lender’s sole and absolute discretion; and upon any Event of Default described in paragraph (e), (f) or (i) of Section 8.1, the Borrower Payment Obligations shall become immediately due and payable, without notice or demand, and the Borrower hereby expressly waives any such notice or demand, anything contained in any Borrower Loan Document to the contrary notwithstanding. Notwithstanding anything herein to the contrary, enforcement of remedies hereunder and under the Funding Loan Agreement shall be controlled by the Funding Lender. Section 8.2.2 Remedies Cumulative. Upon the occurrence of an Event of Default, all or any one or more of the rights, powers, privileges and other remedies available to the Funding Lender or the Fiscal Agent against the Borrower under the Borrower Loan Documents or at law or in equity may be exercised by the Funding Lender, at any time and from time to time, whether or not all or any of the Borrower Payment Obligations shall be declared due and payable, and whether or not the Funding Lender shall have commenced any foreclosure proceeding or other action for the enforcement of its rights and remedies under any of the Borrower Loan Documents. Any such actions taken by the Funding Lender shall be cumulative and concurrent and may be pursued independently, singly, successively, together or otherwise, at such time and in such order as the Funding Lender may determine in its sole discretion, to the fullest extent permitted by law, without impairing or otherwise affecting the other rights and remedies of the Funding Lender permitted by law, equity or contract or as set forth in the Borrower Loan Documents. Without limiting the generality of the foregoing, the Borrower agrees that if an Event of Default is continuing, all Liens and other rights, remedies or privileges provided to the Funding Lender shall remain in full force and effect until it has exhausted all of its remedies, the Security Instrument has been foreclosed, the Project has been sold and/or otherwise realized upon satisfaction of the Borrower Payment Obligations or the Borrower Payment Obligations have been paid in full. To the extent permitted by applicable law, 54 4894-2953-3827.5 nothing contained in any Borrower Loan Document shall be construed as requiring the Funding Lender to resort to any portion of the Project for the satisfaction of any of the Borrower Payment Obligations in preference or priority to any other portion, and the Funding Lender may seek satisfaction out of the entire Project or any part thereof, in its absolute discretion. Notwithstanding any provision herein to the contrary, the Governmental Lender, the Fiscal Agent and the Funding Lender agree that any cure of any default made or tendered by the Equity Investor shall be deemed to be a cure by the Borrower and shall be accepted or rejected on the same basis as if made or tendered by the Borrower. Section 8.2.3 Delay. No delay or omission to exercise any remedy, right, power accruing upon an Event of Default, or the granting of any indulgence or compromise by the Funding Lender or the Fiscal Agent shall impair any such remedy, right or power hereunder or be construed as a waiver thereof, but any such remedy, right or power may be exercised from time to time and as often as may be deemed expedient. A waiver of one Potential Default or Event of Default shall not be construed to be a waiver of any subsequent Potential Default or Event of Default or to impair any remedy, right or power consequent thereon. Notwithstanding any other provision of this Borrower Loan Agreement, the Funding Lender and the Fiscal Agent reserve the right to seek a deficiency judgment or preserve a deficiency claim, in connection with the foreclosure of the Security Instrument to the extent necessary to foreclose on the Project, the Rents, the funds or any other collateral. Section 8.2.4 Setoff; Waiver of Setoff. Upon the occurrence of an Event of Default, the Funding Lender may, at any time and from time to time, without notice to the Borrower or any other Person (any such notice being expressly waived), set off and appropriate and apply (against and on account of any obligations and liabilities of the Borrower to the Funding Lender or the Fiscal Agent arising under or connected with this Borrower Loan Agreement and the other Borrower Loan Documents and the Funding Loan Documents, irrespective of whether or not the Funding Lender shall have made any demand therefor, and although such obligations and liabilities may be contingent or unmatured), and the Borrower hereby grants to the Funding Lender, as security for the Borrower Payment Obligations, a security interest in, any and all deposits (general or special, including but not limited to Debt evidenced by certificates of deposit, whether matured or unmatured, but not including trust accounts) and any other Debt at any time held or owing by the Funding Lender to or for the credit or the account of the Borrower. Section 8.2.5 Assumption of Obligations. In the event that the Funding Lender, the Fiscal Agent or the assignee or designee of either shall become the legal or beneficial owner of the Project by foreclosure or deed in lieu of foreclosure, such party shall succeed to the rights and the obligations of the Borrower under this Borrower Loan Agreement, the Permanent Phase Borrower Note, the Regulatory Agreement, and any other Borrower Loan Documents and Funding Loan Documents to which the Borrower is a party. Such assumption shall be effective from and after the effective date of such acquisition and shall be made with the benefit of the limitations of liability set forth therein and without any liability for the prior acts of the Borrower. Section 8.2.6 Accounts Receivable. Upon the occurrence of an Event of Default, the Funding Lender shall have the right, to the extent permitted by law, to impound and take possession of books, records, notes and other documents evidencing the Borrower’s accounts, accounts receivable and other claims for payment of money, arising in connection with the Project, and to make direct collections on such accounts, accounts receivable and claims for the benefit of Funding Lender. Section 8.2.7 Defaults under Other Documents. The Funding Lender shall have the right to cure any default under any of the Related Documents and Subordinate Loan Documents, but shall have no obligation to do so. 55 4894-2953-3827.5 Section 8.2.8 Reserved. Section 8.2.9 Reserved. Section 8.2.10 Right to Directly Enforce. Notwithstanding any other provision hereof to the contrary, the Funding Lender shall have the right to directly enforce all rights and remedies hereunder with or without involvement of the Governmental Lender or the Fiscal Agent, provided that only the Governmental Lender may enforce the Unassigned Rights. In the event that any of the provisions set forth in this Section 8.2.10 are inconsistent with the covenants, terms and conditions of the Security Instrument, the covenants, terms and conditions of the Security Instrument shall prevail. Section 8.2.11 Power of Attorney. Effective upon the occurrence of an Event of Default, and continuing until and unless such Event of Default is cured or waived, the Borrower hereby constitutes and appoints Funding Lender, or an independent contractor selected by the Funding Lender, as its true and lawful attorney-in-fact with full power of substitution, for the purposes of completion of the Project and performance of the Borrower’s obligations under this Borrower Loan Agreement in the name of the Borrower, and hereby empowers said attorney-in-fact to do any or all of the following upon the occurrence and continuation of an Event of Default (it being understood and agreed that said power of attorney shall be deemed to be a power coupled with an interest which cannot be revoked until full payment and performance of all obligations under this Borrower Loan Agreement and the other Borrower Loan Documents and the Funding Loan Documents): (a) to employ attorneys to defend against attempts to interfere with the exercise of power granted hereby; (b) to pay, settle or compromise all existing bills and claims which are or may be liens against the Project or the Improvements, or may be necessary or desirable for the completion of the construction or rehabilitation, as the case may be, of the Improvements, or clearance of objections to or encumbrances on title; (c) to execute all applications and certificates in the name of the Borrower, which may be required by any other construction contract; (d) to prosecute and defend all actions or proceedings in connection with the Project and to take such action, require such performance and do any and every other act as is deemed necessary with respect to the completion of the construction or rehabilitation, as the case may be, of the Improvements, which the Borrower might do on its own behalf; (e) to let new or additional contracts to the extent not prohibited by their existing contracts; (f) to employ watchmen and erect security fences to protect the Project from injury; and (g) to take such action and require such performance as it deems necessary under any of the bonds or insurance policies to be furnished hereunder, to make settlements and compromises with the sureties or insurers thereunder, and in connection therewith to execute instruments of release and satisfaction. It is the intention of the parties hereto that upon the occurrence and continuance of an Event of Default, rights and remedies may be pursued pursuant to the terms of the Borrower Loan Documents and the Funding Loan Documents. The parties hereto acknowledge that, among the possible outcomes to the pursuit of such remedies, is the situation where the Funding Lender assignees or designees become the 56 4894-2953-3827.5 owner of the Project and assume the obligations identified above, and the Permanent Phase Borrower Note, the Permanent Phase Borrower Loan and the other Borrower Loan Documents and Funding Loan Documents remain outstanding. ARTICLE IX SPECIAL PROVISIONS Section 9.1 Sale of Note and Secondary Market Transaction. Section 9.1.1 Cooperation. Subject to the restrictions of Section 2.5 and Section 2.6 of the Funding Loan Agreement, at the Funding Lender’s or the Servicer’s request (to the extent not already required to be provided by the Borrower under this Borrower Loan Agreement), the Borrower shall use reasonable efforts to satisfy the market standards to which the Funding Lender or the Servicer customarily adheres or which may be reasonably required in the marketplace or by the Funding Lender or the Servicer in connection with one or more permitted sales or assignments of all or a portion of the Governmental Lender Note or participations therein or securitizations of single or multi-class securities (the “Securities”) secured by or evidencing ownership interests in all or a portion of the Permanent Phase Borrower Loan (each such sale, assignment and/or securitization, a “Secondary Market Transaction”); provided that the Borrower shall not incur any third party or other out-of-pocket costs and expenses in connection with a Secondary Market Transaction, including the costs associated with the delivery of any Provided Information or any opinion required in connection therewith, and all such costs shall be paid by the Funding Lender or the Servicer, and shall not materially modify the Borrower’s rights or obligations. Without limiting the generality of the foregoing, the Borrower shall, so long as the Permanent Phase Borrower Loan is still outstanding: (a) (i) provide such financial and other information with respect to the Permanent Phase Borrower Loan, and with respect to the Project, the Borrower, the Property Manager, the contractor of the Project or the Borrower Controlling Entity, (ii) provide financial statements, audited, if available, relating to the Project with customary disclaimers for any forward looking statements or lack of audit, and (iii), at the expense of the Funding Lender or the Servicer, perform or permit or cause to be performed or permitted such site inspection, appraisals, surveys, market studies, environmental reviews and reports (Phase I’s and, if appropriate, Phase II’s), engineering reports and other due diligence investigations of the Project, as may be reasonably requested from time to time by the Funding Lender or the Servicer or the Rating Agencies or as may be necessary or appropriate in connection with a Secondary Market Transaction or Exchange Act requirements (the items provided to the Funding Lender or the Servicer pursuant to this paragraph (a) being called the “Provided Information”), together, if customary, with appropriate verification of and/or consents (including, without limitation, auditor consents) to include or incorporate by reference the Provided Information in an offering document or otherwise provided the Provided Information to investors and potential investors or opinions of counsel of independent attorneys acceptable to the Funding Lender or the Servicer and the Rating Agencies; (b) make such representations and warranties as of the closing date of any Secondary Market Transaction with respect to the Project, the Borrower, the Borrower Loan Documents and the Funding Loan Documents reasonably acceptable to the Funding Lender or the Servicer, consistent with the facts covered by such representations and warranties as they exist on the date thereof; and (c) execute such amendments to the Borrower Loan Documents and the Funding Loan Documents to accommodate such Secondary Market Transaction so long as such amendment does not affect the economic terms of the Borrower Loan Documents and the Funding Loan Documents, does not impose any additional administrative burden on the Borrower, and is not otherwise adverse to the Borrower in its reasonable discretion. 57 4894-2953-3827.5 Section 9.1.2 Use of Information. The Borrower understands that certain of the Provided Information and the required records may be included in disclosure documents in connection with a Secondary Market Transaction, including a prospectus or private placement memorandum (each, a “Secondary Market Disclosure Document”), or provided or made available to investors or prospective investors in the Securities, the Rating Agencies and service providers or other parties relating to the Secondary Market Transaction. In the event that the Secondary Market Disclosure Document is required to be revised, the Borrower shall cooperate, subject to Section 9.1.1(c) hereof, with the Funding Lender and the Servicer in updating the Provided Information or required records for inclusion or summary in the Secondary Market Disclosure Document or for other use reasonably required in connection with a Secondary Market Transaction by providing all current information pertaining to the Borrower and the Project necessary to keep the Secondary Market Disclosure Document accurate and complete in all material respects with respect to such matters. The Borrower hereby consents to any and all such disclosures of such information. Section 9.1.3 Borrower Obligations Regarding Secondary Market Disclosure Documents. In connection with a Secondary Market Disclosure Document, the Borrower shall provide, or in the case of a Borrower-engaged third party such as the Property Manager, cause it to provide, information reasonably requested by the Funding Lender pertaining to the Borrower, the Project or such third party (and portions of any other sections reasonably requested by the Funding Lender pertaining to the Borrower, the Project or the third party); provided that the Borrower shall not be required to incur any third party or other out of pocket costs or expenses in connection therewith. The Borrower shall, if requested by the Funding Lender and the Servicer, certify in writing that the Borrower has carefully examined those portions of such Secondary Market Disclosure Document, pertaining to the Borrower, the Project or the Property Manager, and such portions (and portions of any other sections reasonably requested and pertaining to the Borrower, the Project or the Property Manager) do not contain any untrue statement of a material fact or omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading; provided that the Borrower shall not be required to make any representations or warranties regarding any Provided Information obtained from a third party except with respect to information it provided to such parties. Furthermore, the Borrower hereby indemnifies the Funding Lender and the Servicer for any Liabilities to which any such parties may become subject to the extent such Liabilities arise out of or are based upon a misrepresentation by the Borrower in the Provided Information in a Secondary Market Disclosure Document; provided that the Borrower shall not provide any indemnification regarding any Provided Information obtained from unrelated third parties (except with respect to the information it provided to such parties). Section 9.1.4 Borrower Indemnity Regarding Filings. In connection with filings under the Exchange Act or the Securities Act, the Borrower shall (i) indemnify the Funding Lender, the Governmental Lender, the Fiscal Agent, the underwriter group for any securities (the “Underwriter Group”) for any Liabilities to which Funding Lender, the Governmental Lender, the Fiscal Agent, the Servicer or the Underwriter Group may become subject insofar as the Liabilities arise out of or are based upon the omission or alleged omission to state in the Provided Information of a material fact required to be stated in the Provided Information in order to make the statements in the Provided Information, in the light of the circumstances under which they were made not misleading and (ii) reimburse the Funding Lender, the Servicer, the Governmental Lender, the Fiscal Agent, the Underwriter Group and other indemnified parties listed above for any legal or other expenses reasonably incurred by the Funding Lender, the Governmental Lender, the Fiscal Agent, the Servicer or the Underwriter Group in connection with defending or investigating the Liabilities; provided that the Borrower shall not provide any indemnification regarding any Provided Information obtained from unrelated third parties except with respect to information it provided to such parties. 58 4894-2953-3827.5 Section 9.1.5 Indemnification Procedure. Promptly after receipt by an indemnified party under Sections 9.1.3 and 9.1.4 hereof of notice of the commencement of any action for which a claim for indemnification is to be made against the Borrower, such indemnified party shall notify the Borrower in writing of such commencement, but the omission to so notify the Borrower will not relieve the Borrower from any liability that it may have to any indemnified party hereunder except to the extent that failure to notify causes prejudice to the Borrower. In the event that any action is brought against any indemnified party, and it notifies the Borrower of the commencement thereof, the Borrower will be entitled, jointly with any other indemnifying party, to participate therein and, to the extent that it (or they) may elect by Written Notice delivered to the indemnified party promptly after receiving the aforesaid notice of commencement, to assume the defense thereof with counsel selected by the Borrower and reasonably satisfactory to such indemnified party in its sole discretion. After notice from the Borrower to such indemnified party under this Section 9.1.5, the Borrower shall not be responsible for any legal or other expenses subsequently incurred by such indemnified party in connection with the defense thereof other than reasonable costs of investigation. No indemnified party shall settle or compromise any claim for which the Borrower may be liable hereunder without the prior Written Consent of the Borrower. Section 9.1.6 Contribution. In order to provide for just and equitable contribution in circumstances in which the indemnity agreement provided for in Section 9.1.4 hereof is for any reason held to be unenforceable by an indemnified party in respect of any Liabilities (or action in respect thereof) referred to therein which would otherwise be indemnifiable under Section 9.1.4 hereof, the Borrower shall contribute to the amount paid or payable by the indemnified party as a result of such Liabilities (or action in respect thereof); provided, however, that no Person guilty of fraudulent misrepresentation (within the meaning of Section 10(f) of the Securities Act) shall be entitled to contribution from any Person not guilty of such fraudulent misrepresentation. In determining the amount of contribution to which the respective parties are entitled, the following factors shall be considered: (i) the indemnified parties and the Borrower’s relative knowledge and access to information concerning the matter with respect to which the claim was asserted; (ii) the opportunity to correct and prevent any statement or omission; and (iii) any other equitable considerations appropriate in the circumstances. The parties hereto hereby agree that it may not be equitable if the amount of such contribution were determined by pro rata or per capita allocation. ARTICLE X MISCELLANEOUS Section 10.1 Notices. All notices, consents, approvals and requests required or permitted hereunder or under any other Borrower Loan Document or Funding Loan Document (a “notice”) shall be deemed to be given and made when delivered by hand, by recognized overnight delivery service, confirmed facsimile transmission (provided any telecopy or other electronic transmission received by any party after 4:00 p.m., local time, as evidenced by the time shown on such transmission, shall be deemed to have been received the following Business Day), or five (5) calendar days after deposited in the United States mail, registered or certified, postage prepaid, with return receipt requested, addressed as follows: If to the Borrower: Vista Breeze HACMB, Inc. c/o Atlantic Pacific Communities, LLC 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor Telephone: (305) 357-4700 Email: knaylor@apcompanies.com 59 4894-2953-3827.5 with a copy to: Klein Hornig LLP 1325 G. Street NW, Suite 770 Washington, DC 20005 Attention: Chris Hornig Email: chornig@kleinhornig.com Tel: (202) 926-3402 Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A. (which copy shall not constitute notice to Borrower) 150 W. Flagler Street Miami, Florida 33130 Attention: Brian McDonough, Esq. Email: bmcdonough@stearnsweaver.com Telephone: (305) 789-3350 with a copy to: Vista Breeze, Ltd. c/o Atlantic Pacific Communities, LLC 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor Telephone: (305) 357-4700 Email: knaylor@apcompanies.com with a copy to: Klein Hornig LLP 1325 G. Street NW, Suite 770 Washington, DC 20005 Attention: Chris Hornig Email: chornig@kleinhornig.com Tel: (202) 926-3402 Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A. (which copy shall not constitute notice to Borrower) 150 W. Flagler Street Miami, Florida 33130 Attention: Brian McDonough, Esq. Email: bmcdonough@stearnsweaver.com Telephone: (305) 789-3350 Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 Pittsburg, Pennsylvania 15219 Attention: Alec Stone Email: ajstone@foxrothschild.com Telephone: (412) 391-2523 60 4894-2953-3827.5 with copy to: Bank of America, N.A. MA5-100-04-11 100 Federal Street Boston, MA 02110 Attention: Tax Credit Asset Management (Vista Breeze) Email: LIHTCreporting@bofa.com with copy to: Holland & Knight LLP 10 St. James Avenue Boston, MA 02116 Attention: Sara C. Heskett, Esq. Email: sara.heskett@hklaw.com If to the Governmental Lender: Housing Finance Authority of Miami-Dade County, Florida 7855 NW 12th Street, Suite 202 Doral, Florida 33126 Attention: Cheree Gulley, Executive Director Facsimile: (305) 392-2722 Email: cgulley@hfamiami.com and a copy to: Miami-Dade County Attorney’s Office 111 N.W. First Street Suite 2810 Orlando, Florida 32801 Attention: David S. Hope, Esq. Email: dhope@miamidade.gov If to Funding Lender: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction and Asset Management Group Re: Vista Breeze Deal ID# _____________ Facsimile: (212) 723-8209 61 4894-2953-3827.5 with a copy to: : Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID# ___________ Facsimile: (805) 557-0924 and Citibank, N.A c/o Berkadia Commercial Mortgage LLC 323 Norristown Road, Suite 300 Ambler, Pennsylvania 19002 Attention: Client Relations Manager Re: Vista Breeze Deal ID# _____________ Facsimile: (215) 328-0305 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID# _____________ Facsimile: (646) 291-5754 If to Fiscal Agent: The Bank of New York Mellon Trust Company, N.A. 4655 Salisbury Road, Suite 300 Jacksonville, Florida 33256 Attention: Corporate Trust Department Email: heidi.bowers@bnymellon.com Telephone: (904) 645-1983 Any party may change such party’s address for the notice or demands required under this Borrower Loan Agreement by providing written notice of such change of address to the other parties by written notice as provided herein. The Fiscal Agent shall have the right to accept and act upon instructions, including funds transfer instructions (“Instructions”) given pursuant to this Borrower Loan Agreement and related financing documents and delivered using Electronic Means; provided, however, that Borrower, and/or the Governmental Lender, as applicable, or and such other party giving such instruction (the “Sender”) shall provide to the Fiscal Agent an incumbency certificate listing officers with the authority to provide such Instructions (“Authorized Officers”) and containing specimen signatures of such Authorized Officers, which incumbency certificate shall be amended by Governmental Lender and/or the Borrower, as applicable, the Sender whenever a person is to be added or deleted from the listing. ”Electronic Means” shall mean the following communications methods: S.W.I.F.T., e-mail, facsimile transmission, secure electronic transmission containing applicable authorization codes, passwords and/or authentication keys issued by the Fiscal Agent, or another method or system specified by the Fiscal Agent as available for use in connection with its services hereunder. If the Governmental Lender and/or the Borrower, as applicable, 62 4894-2953-3827.5 elects to give the Fiscal Agent Instructions using Electronic Means and the Fiscal Agent in its discretion elects to act upon such Instructions, the Fiscal Agent’s understanding of such Instructions shall be deemed controlling. The Governmental Lender and the Borrower understand and agree that the Fiscal Agent cannot determine the identity of the actual sender of such Instructions and that the Fiscal Agent shall conclusively presume that directions that purport to have been sent by an Authorized Officer listed on the incumbency certificate provided to the Fiscal Agent have been sent by such Authorized Officer. The Governmental Lender and the Borrower shall be responsible for ensuring that only Authorized Officers transmit such Instructions to the Fiscal Agent and that the Governmental Lender, the Borrower and all Authorized Officers are solely responsible to safeguard the use and confidentiality of applicable user and authorization codes, passwords and/or authentication keys upon receipt by the Governmental Lender and/or the Borrower, as applicable. The Fiscal Agent shall not be liable for any losses, costs or expenses arising directly or indirectly from the Fiscal Agent’s reliance upon and compliance with such Instructions notwithstanding such directions conflict or are inconsistent with a subsequent written instruction. The Governmental Lender and the Borrower agree: (i) to assume all risks arising out of the use of Electronic Means to submit Instructions to the Fiscal Agent, including without limitation the risk of the Fiscal Agent acting on unauthorized Instructions, and the risk of interception and misuse by third parties; (ii) that it is fully informed of the protections and risks associated with the various methods of transmitting Instructions to the Fiscal Agent and that there may be more secure methods of transmitting Instructions than the method(s) selected by the Governmental Lender and/or the Borrower, as applicable; (iii) that the security procedures (if any) to be followed in connection with its transmission of Instructions provide to it a commercially reasonable degree of protection in light of its particular needs and circumstances; and (iv) to notify the Fiscal Agent immediately upon learning of any compromise or unauthorized use of the security procedures. Section 10.2 Brokers and Financial Advisors. The Borrower hereby represents that it has dealt with no financial advisors, brokers, underwriters, placement agents, agents or finders in connection with the Permanent Phase Borrower Loan, other than those disclosed to the Funding Lender and whose fees shall be paid by the Borrower pursuant to separate agreements. The Borrower and the Funding Lender shall indemnify and hold the other harmless from and against any and all claims, liabilities, costs and expenses of any kind in any way relating to or arising from a claim by any Person that such Person acted on behalf of the indemnifying party in connection with the transactions contemplated herein. The provisions of this Section 10.2 shall survive the expiration and termination of this Borrower Loan Agreement and the repayment of the Borrower Payment Obligations. Section 10.3 Survival. This Borrower Loan Agreement and all covenants, agreements, representations and warranties made herein and in the certificates delivered pursuant hereto shall survive the making by the Governmental Lender of the Permanent Phase Borrower Loan and the execution and delivery to the Governmental Lender of the Permanent Phase Borrower Note and the assignment of the Permanent Phase Borrower Note to the Funding Lender, and shall continue in full force and effect so long as all or any of the Borrower Payment Obligations is unpaid. All the Borrower’s covenants and agreements in this Borrower Loan Agreement shall inure to the benefit of the respective legal representatives, successors and assigns of the Governmental Lender, the Fiscal Agent the Funding Lender and the Servicer. Section 10.4 Preferences. To the extent the Borrower makes a payment to the Governmental Lender, the Fiscal Agent or the Servicer, or the Governmental Lender, the Fiscal Agent or the Servicer receives proceeds of any collateral, which is in whole or part subsequently invalidated, declared to be fraudulent or preferential, set aside or required to be repaid to a trustee, receiver or any other party under any bankruptcy law, state or federal law, common law or equitable cause, then, to the extent of such payment or proceeds received, the Borrower Payment Obligations or part thereof intended to be satisfied shall be revived and continue in full force and effect, as if such payment or proceeds had not been received by the Governmental Lender or the Servicer. In furtherance of the preceding sentence, the Governmental 63 4894-2953-3827.5 Lender shall have the continuing and exclusive right to apply or reverse and reapply any and all payments by the Borrower to any portion of the Borrower Payment Obligations. Section 10.5 Waiver of Notice. The Borrower shall not be entitled to any notices of any nature whatsoever from the Funding Lender, the Fiscal Agent or the Servicer except with respect to matters for which this Borrower Loan Agreement or any other Borrower Loan Document specifically and expressly provides for the giving of notice by the Funding Lender, the Fiscal Agent or the Servicer, as the case may be, to the Borrower and except with respect to matters for which the Borrower is not, pursuant to applicable Legal Requirements, permitted to waive the giving of notice. The Borrower hereby expressly waives the right to receive any notice from the Funding Lender, the Fiscal Agent or the Servicer, as the case may be, with respect to any matter for which no Borrower Loan Document specifically and expressly provides for the giving of notice by the Funding Lender, the Fiscal Agent or the Servicer to the Borrower. Section 10.6 Offsets, Counterclaims and Defenses. The Borrower hereby waives the right to assert a counterclaim, other than a compulsory counterclaim, in any action or proceeding brought against it by the Funding Lender, the Fiscal Agent, the Governmental Lender or the Servicer with respect to a Borrower Loan Payment. Any assignee of the Funding Lender’s, the Governmental Lender’s or the Fiscal Agent’s interest in and to the Borrower Loan Documents or the Funding Loan Documents shall take the same free and clear of all offsets, counterclaims or defenses that are unrelated to the Borrower Loan Documents or the Funding Loan Documents which the Borrower may otherwise have against any assignor of such documents, and no such unrelated offset, counterclaim or defense shall be interposed or asserted by the Borrower in any action or proceeding brought by any such assignee upon such documents, and any such right to interpose or assert any such unrelated offset, counterclaim or defense in any such action or proceeding is hereby expressly waived by the Borrower. Section 10.7 Publicity. The Funding Lender and the Servicer (and any Affiliates of either party) shall have the right to issue press releases, advertisements and other promotional materials describing the Funding Lender’s or the Servicer’s participation in the making of the Permanent Phase Borrower Loan or the Permanent Phase Borrower Loan’s inclusion in any Secondary Market Transaction effectuated by the Funding Lender or the Servicer or one of its or their Affiliates. All news releases, publicity or advertising by the Borrower or its Borrower Affiliates through any media intended to reach the general public, which refers to the Borrower Loan Documents or the Funding Loan Documents, the Permanent Phase Borrower Loan, the Funding Lender or the Servicer in a Secondary Market Transaction, shall be subject to the prior Written Consent of the Funding Lender or the Servicer, as applicable. Section 10.8 Construction of Documents. The parties hereto acknowledge that they were represented by counsel in connection with the negotiation and drafting of the Borrower Loan Documents and the Funding Loan Documents and that the Borrower Loan Documents and the Funding Loan Documents shall not be subject to the principle of construing their meaning against the party that drafted them. Section 10.9 No Third Party Beneficiaries. The Borrower Loan Documents and the Funding Loan Documents are solely for the benefit of the Governmental Lender, the Funding Lender, the Fiscal Agent, the Servicer and the Borrower and, with respect to Sections 9.1.3 and 9.1.4 hereof, the Underwriter Group, and nothing contained in any Borrower Loan Document shall be deemed to confer upon anyone other than the Governmental Lender, the Funding Lender, the Fiscal Agent, the Servicer, and the 64 4894-2953-3827.5 Borrower any right to insist upon or to enforce the performance or observance of any of the obligations contained therein. Section 10.10 Assignment. The Permanent Phase Borrower Loan, the Security Instrument, the Borrower Loan Documents and the Funding Loan Documents and all Funding Lender’s or Fiscal Agent’s rights, title, obligations and interests therein may be assigned by the Funding Lender or the Fiscal Agent, as appropriate, at any time in its sole discretion, whether by operation of law (pursuant to a merger or other successor in interest) or otherwise, subject to the requirements of Article II of the Funding Loan Agreement. Upon such assignment, all references to Funding Lender or the Fiscal Agent, as appropriate, in this Borrower Loan Agreement and in any Borrower Loan Document shall be deemed to refer to such assignee or successor in interest and such assignee or successor in interest shall thereafter stand in the place of the Funding Lender or the Fiscal Agent, as appropriate. The Borrower shall accord full recognition to any such assignment, and all rights and remedies of Funding Lender in connection with the interest so assigned shall be as fully enforceable by such assignee as they were by Funding Lender before such assignment. In connection with any proposed assignment, Funding Lender may disclose to the proposed assignee any information that Borrower has delivered, or caused to be delivered, to Funding Lender with reference to the Borrower, General Partner, Guarantor or any Borrower Affiliate, or the Project, including information that the Borrower is required to deliver to Funding Lender pursuant to this Borrower Loan Agreement, provided that such proposed assignee agrees to treat such information as confidential. The Borrower may not assign its rights, interests or obligations under this Borrower Loan Agreement or under any of the Borrower Loan Documents or Funding Loan Documents, or the Borrower’s interest in any moneys to be disbursed or advanced hereunder, except only as may be expressly permitted hereby. Section 10.11 Governmental Lender, Funding Lender, Fiscal Agent and Servicer Not in Control; No Partnership. None of the covenants or other provisions contained in this Borrower Loan Agreement shall, or shall be deemed to, give the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer the right or power to exercise control over the affairs or management of the Borrower, the power of the Governmental Lender, the Funding Lender and the Servicer being limited to the rights to exercise the remedies referred to in the Borrower Loan Documents and the Funding Loan Documents. The relationship between the Borrower and the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer is, and at all times shall remain, solely that of debtor and creditor. No covenant or provision of the Borrower Loan Documents or the Funding Loan Documents is intended, nor shall it be deemed or construed, to create a partnership, joint venture, agency or common interest in profits or income between the Borrower and the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer or to create an equity interest in the Project in the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer. Neither the Governmental Lender, the Funding Lender, the Fiscal Agent nor the Servicer undertakes or assumes any responsibility or duty to the Borrower or to any other person with respect to the Project or the Permanent Phase Borrower Loan, except as expressly provided in the Borrower Loan Documents or the Funding Loan Documents; and notwithstanding any other provision of the Borrower Loan Documents and the Funding Loan Documents: (1) the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer are not, and shall not be construed as, a partner, joint venturer, alter ego, manager, controlling person or other business associate or participant of any kind of the Borrower or its stockholders, members, or partners and the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer do not intend to ever assume such status; (2) the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer shall in no event be liable for any the Borrower Payment Obligations, expenses or losses incurred or sustained by the Borrower; and (3) the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer shall not be deemed responsible for or a participant in any acts, omissions or decisions of the Borrower, the Borrower Controlling Entities or its stockholders, members, or partners. The Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer and the Borrower disclaim any intention to create any 65 4894-2953-3827.5 partnership, joint venture, agency or common interest in profits or income between the Governmental Lender, the Funding Lender, the Fiscal Agent, the Servicer and the Borrower, or to create an equity interest in the Project in the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer, or any sharing of liabilities, losses, costs or expenses. Section 10.12 Release. The Borrower hereby acknowledges that it is executing this Borrower Loan Agreement and each of the Borrower Loan Documents and the Funding Loan Documents to which it is a party as its own voluntary act free from duress and undue influence. Section 10.13 Term of the Amended and Restated Borrower Loan Agreement. This Borrower Loan Agreement shall be in full force and effect until all payment obligations of the Borrower hereunder have been paid in full and the Permanent Phase Borrower Loan and the Funding Loan have been retired or the payment thereof has been provided for; except that on and after payment in full of the Permanent Phase Borrower Note, this Borrower Loan Agreement shall be terminated, without further action by the parties hereto; provided, however, that the obligations of the Borrower under Sections 5.12, 5.15, 5.16, 9.1.4, 9.1.5, 9.1.6 and 10.14 hereof shall survive the termination of this Borrower Loan Agreement. Section 10.14 Reimbursement of Expenses. If, upon or after the occurrence of any Event of Default or Potential Default, the Governmental Lender, the Funding Lender, the Fiscal Agent or the Servicer shall employ attorneys or incur other expenses for the enforcement of performance or observance of any obligation or agreement on the part of the Borrower contained herein, the Borrower will on demand therefor reimburse the Governmental Lender, the Funding Lender, the Fiscal Agent and the Servicer for fees of such attorneys and such other expenses so incurred. Section 10.15 Permitted Contests. Notwithstanding anything to the contrary contained in this Borrower Loan Agreement, Borrower shall have the right to contest or object in good faith to any claim, demand, levy or assessment (other than in respect of Debt or Contractual Obligations of Borrower under any Borrower Loan Document or Related Document) by appropriate legal proceedings that are not prejudicial to Funding Lender’s rights, but this shall not be deemed or construed as in any way relieving, modifying or providing any extension of time with respect to the Borrower’s covenant to pay and comply with any such claim, demand, levy or assessment, unless the Borrower shall have given prior Written Notice to the Governmental Lender and the Funding Lender of the Borrower’s intent to so contest or object thereto, and unless (i) the Borrower has, in the Funding Lender’s judgment, a reasonable basis for such contest, (ii) the Borrower pays when due any portion of the claim, demand, levy or assessment to which the Borrower does not object, (iii) the Borrower demonstrates to Funding Lender’s reasonable satisfaction that such legal proceedings shall conclusively operate to prevent enforcement prior to final determination of such proceedings, (iv) if required by the Funding Lender, the Borrower furnishes such bond, surety, undertaking or other security in connection therewith as required by law, or as reasonably requested by and satisfactory to Funding Lender, to stay such proceeding, which bond, surety, undertaking or other security shall be issued by a bonding company, insurer or surety company reasonably satisfactory to Funding Lender and shall be sufficient to cause the claim, demand, levy or assessment to be insured against by the Title Company or removed as a lien against the Project, (v) the Borrower at all times prosecutes the contest with due diligence, and (vi) the Borrower pays, promptly following a determination of the amount of such claim, demand, levy or assessment due and owing by the Borrower, the amount so determined to be due and owing by the Borrower. In the event that the Borrower does not make, promptly following a determination of the amount of such claim, demand, levy or assessment due and owing by the Borrower, any payment required to be made pursuant to clause (vi) of the preceding sentence, an Event of Default shall have occurred, and Funding Lender may draw or realize upon any 66 4894-2953-3827.5 bond or other security delivered to Funding Lender in connection with the contest by the Borrower, in order to make such payment. Section 10.16 Funding Lender Approval of Instruments and Parties. All proceedings taken in accordance with transactions provided for herein, and all surveys, appraisals and documents required or contemplated by this Borrower Loan Agreement and the persons responsible for the execution and preparation thereof, shall be satisfactory to and subject to approval by the Funding Lender. The Funding Lender’s approval of any matter in connection with the Project shall be for the sole purpose of protecting the security and rights of the Funding Lender. No such approval shall result in a waiver of any default of the Borrower. In no event shall the Funding Lender’s approval be a representation of any kind with regard to the matter being approved. Section 10.17 Funding Lender Determination of Facts. The Funding Lender shall at all times be free to establish independently, to its reasonable satisfaction, the existence or nonexistence of any fact or facts, the existence or nonexistence of which is a condition of this Borrower Loan Agreement. Section 10.18 Calendar Months. With respect to any payment or obligation that is due or required to be performed within a specified number of Calendar Months after a specified date, such payment or obligation shall become due on the day in the last of such specified number of Calendar Months that corresponds numerically to the date so specified; provided, however, that with respect to any obligation as to which such specified date is the 29th, 30th or 31st day of any Calendar Month: if the Calendar Month in which such payment or obligation would otherwise become due does not have a numerically corresponding date, such obligation shall become due on the first day of the next succeeding Calendar Month. Section 10.19 Determinations by Lender. Except to the extent expressly set forth in this Borrower Loan Agreement to the contrary, in any instance where the consent or approval of the Governmental Lender and the Funding Lender may be given or is required, or where any determination, judgment or decision is to be rendered by the Governmental Lender and the Funding Lender under this Borrower Loan Agreement, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by the Governmental Lender and the Funding Lender, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. Section 10.20 Governing Law. This Borrower Loan Agreement shall be governed by and enforced in accordance with the laws of the State, without giving effect to the choice of law principles of the State that would require the application of the laws of a jurisdiction other than the State. Section 10.21 Consent to Jurisdiction and Venue. The Borrower agrees that any controversy arising under or in relation to this Borrower Loan Agreement shall be litigated exclusively in the county in which the Project is located. The state and federal courts and authorities with jurisdiction in the State shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Borrower Loan Agreement. The Borrower irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Borrower Loan Agreement against the Borrower or any of the Borrower’s assets in any court of any other jurisdiction. Section 10.22 Successors and Assigns. This Borrower Loan Agreement shall be binding upon and shall inure to the benefit of the parties hereto and their respective heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate. The terms used to designate any of the 67 4894-2953-3827.5 parties herein shall be deemed to include the heirs, legal representatives, successors, successors-in- interest and assigns, as appropriate, of such parties. References to a “person” or “persons” shall be deemed to include individuals and entities. Section 10.23 Severability. The invalidity, illegality or unenforceability of any provision of this Borrower Loan Agreement shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. Section 10.24 Entire Agreement; Amendment and Waiver. This Borrower Loan Agreement contains the complete and entire understanding of the parties with respect to the matters covered. This Borrower Loan Agreement may not be amended, modified or changed without the written consent of the parties hereto, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Borrower Loan Agreement shall be considered as a general waiver. Section 10.25 Counterparts. This Borrower Loan Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. Section 10.26 Captions. The captions of the sections of this Borrower Loan Agreement are for convenience only and shall be disregarded in construing this Borrower Loan Agreement. Section 10.27 Servicer. The Borrower hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, the Governmental Lender or the Funding Lender may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under the Permanent Phase Borrower Note, this Borrower Loan Agreement or the other Borrower Loan Documents, and to otherwise service the Permanent Phase Borrower Loan and (b) unless the Borrower receives Written Notice from the Governmental Lender or the Funding Lender to the contrary, any action or right which shall or may be taken or exercised by the Governmental Lender or the Funding Lender may be taken or exercised by such servicer with the same force and effect. Section 10.28 Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Borrower Loan Agreement for all purposes. Section 10.29 Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF BORROWER AND THE BENEFICIARY PARTIES OTHER THAN THE GOVERNMENTAL LENDER (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS BORROWER LOAN AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY OTHER 68 4894-2953-3827.5 THAN THE GOVERNMENTAL LENDER, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. Section 10.30 Time of the Essence. Time is of the essence with respect to this Borrower Loan Agreement. Section 10.31 Reference Date. This Borrower Loan Agreement is dated for reference purposes only as of the ____ day of __________, 202___, and will not be effective and binding on the parties hereto unless and until the Conversion Date (as defined herein) occurs. Section 10.32 Americans with Disabilities Act. The Borrower hereby certifies that it will comply with the ADA. The Borrower will provide reasonable accommodations to allow qualified individuals with disabilities to have access to and to participate in its programs, services and activities in accordance with the provisions of the ADA. The Borrower will not discriminate against persons with disabilities nor against persons due to their relationship to or association with a person with a disability. Any subcontract entered into by the Borrower, relating to this Borrower Loan Agreement, to the extent allowed hereunder, shall be subject to the provisions of this Section. ARTICLE XI LIMITATIONS ON LIABILITY Section 11.1 Limitation on Liability. Notwithstanding anything to the contrary herein, the liability of the Borrower hereunder and under the other Borrower Loan Documents and the Funding Loan Documents shall be limited to the extent set forth in the Permanent Phase Borrower Note. Section 11.2 Limitation on Liability of Governmental Lender. The Governmental Lender shall not be obligated to pay the principal (or Prepayment Amount) of or interest on the Funding Loan, except from moneys and assets received by the Fiscal Agent or the Funding Lender on behalf of the Governmental Lender pursuant to this Borrower Loan Agreement. Any obligation or liability of the Governmental Lender created by or arising out of this Borrower Loan Agreement (including, without limitation, any liability created by or arising out of the representations, warranties or covenants set forth herein or otherwise) shall not impose a debt or pecuniary liability upon the Governmental Lender or a charge upon its general credit, but shall be payable solely out of the moneys due and to become due under the Funding Loan Documents (and not from any moneys due or to become due to the Governmental Lender pursuant to the Unassigned Rights). Neither the issuance of the Funding Loan nor the delivery of this Borrower Loan Agreement shall, directly or indirectly or contingently, obligate the Governmental Lender to make any appropriation for payment of the Funding Loan. No agreements or provisions contained in this Borrower Loan Agreement, the Funding Loan Agreement, any other Funding Loan Document, nor any agreement, covenant or undertaking by the Governmental lender contained in any document executed by the Governmental Lender in connection with the Project or the issuance, sale and delivery of the Governmental Lender Note shall give rise to any pecuniary liability of the Governmental Lender or a charge against its general credit or taxing powers, or shall obligate the Governmental Lender financially in any way. Nothing in the Funding Loan or this Borrower Loan Agreement or the proceedings of the Governmental Lender authorizing the Funding Loan or in the Act or the Law or in any other related document shall be construed to authorize the Governmental Lender to create a debt of the Governmental Lender within the meaning of constitutional or statutory provision of the State. No covenant, agreement or obligation contained herein shall be deemed to be a covenant, agreement or obligation of any present or future director, officer, employee or agent of the Governmental Lender in his or her individual capacity, and neither any employee or officer of the Governmental Lender nor any officer thereof executing the Governmental Lender Note shall be liable personally on the Governmental Lender Note or be subject to any personal liability or accountability by reason of the issuance thereof. No director, officer, employee 69 4894-2953-3827.5 or agent of the Governmental Lender shall incur any personal liability with respect to any other action taken by him or her pursuant to this Borrower Loan Agreement, the Funding Loan Agreement, the Act or the Law. No breach of any pledge, obligation or agreement of the Governmental Lender hereunder may impose any pecuniary liability upon the Governmental Lender or any charge upon its general credit. The Governmental Lender shall not be liable for any costs, expenses, losses, damages, claims or actions, of any conceivable kind on any conceivable theory, under or by reason of or in connection with this Borrower Loan Agreement, Funding Loan or the Funding Loan Agreement, except only to the extent amounts are received for the payment thereof from the Borrower under this Borrower Loan Agreement. The Borrower hereby acknowledges that the Governmental Lender’s sole source of moneys to repay the Funding Loan will be provided by the payments made by the Borrower pursuant to this Borrower Loan Agreement and the Permanent Phase Borrower Note, together with investment income on certain funds and accounts held by the Fiscal Agent under the Funding Loan Agreement, and hereby agrees that if the payments to be made hereunder shall ever prove insufficient to pay all principal (or Prepayment Amount) of and interest on the Funding Loan as the same shall become due (whether by maturity, prepayment, acceleration or otherwise), then upon notice from the Fiscal Agent, the Borrower shall pay such amounts as are required from time to time to prevent any deficiency or default in the payment of such principal (or Prepayment Amount) of or interest on the Funding Loan, including, but not limited to, any deficiency caused by acts, omissions, nonfeasance or malfeasance on the part of the Fiscal Agent, the Borrower, the Governmental Lender or any third party, subject to any right of reimbursement from the Fiscal Agent, the Governmental Lender or any such third party, as the case may be, therefor. THE FUNDING LOAN IS ORIGINATED PURSUANT TO THE ACT AND IN ACCORDANCE WITH THE COUNTY AUTHORIZATION, THE RESOLUTION AND THE ACT AND IS A REVENUE OBLIGATION OF THE GOVERNMENTAL LENDER. NEITHER THE GOVERNMENTAL LENDER, THE COUNTY NOR ANY OFFICIAL OR EMPLOYEE OF THE GOVERNMENTAL LENDER, NOR ANY PERSON EXECUTING THE FUNDING LOAN, SHALL BE LIABLE PERSONALLY ON THE FUNDING LOAN OR SUBJECT TO ANY PERSONAL LIABILITY OR ACCOUNTABILITY BY REASON OF ITS ISSUANCE. THE FUNDING LOAN, THE GOVERNMENTAL LENDER NOTE AND THE INTEREST THEREON ARE LIMITED OBLIGATIONS OF THE GOVERNMENTAL LENDER, PAYABLE ONLY FROM THE SOURCES DESCRIBED IN THE FUNDING LOAN AGREEMENT. NEITHER THE GOVERNMENTAL LENDER, THE COUNTY, THE STATE NOR ANY OTHER POLITICAL CORPORATION OR SUBDIVISION OR AGENCY THEREOF SHALL BE OBLIGATED TO PAY THE PRINCIPAL OF SUCH FUNDING LOAN, THE GOVERNMENTAL LENDER NOTE OR THE INTEREST THEREON OR OTHER COSTS INCIDENT THERETO EXCEPT FROM THE MONEY PLEDGED THEREFOR. THE FUNDING LOAN, THE GOVERNMENTAL LENDER NOTE AND THE INTEREST THEREON DO NOT AND SHALL NEVER CONSTITUTE A DEBT OF INDEBTEDNESS OR A GENERAL OBLIGATION OF THE GOVERNMENTAL LENDER, THE COUNTY, THE STATE OR ANY MUNICIPAL OR POLITICAL CORPORATION OR SUBDIVISION OF THE STATE. NEITHER THE FAITH AND CREDIT NOR THE TAXING POWER OF THE GOVERNMENTAL LENDER, THE COUNTY, THE STATE NOR ANY POLITICAL CORPORATION OR SUBDIVISION OR AGENCY THEREOF OR THE FAITH AND CREDIT OF THE ISSUER IS PLEDGED TO THE PAYMENT THE PRINCIPAL OF PREMIUM, IF ANY, OR INTEREST ON THE FUNDING LOAN, THE GOVERNMENTAL LENDER NOTE OR OTHER COSTS INCIDENT THERETO. THE FUNDING LOAN AND GOVERNMENTAL LENDER NOTE ARE NOT DEBTS OF THE UNITED STATES OF AMERICA. THE GOVERNMENTAL LENDER HAS NO TAXING POWER. No recourse shall be had for the payment of the principal of, premium, if any, or interest on the Funding Loan or for any claim based thereon or upon any obligation, covenant or agreement in this Borrower Loan Agreement contained, against any past, present or future member of the Governmental 70 4894-2953-3827.5 Lender, the County, its respective governing body, officers, attorneys, accountants, financial advisors, agents or staff or the officers, attorneys, accountants, financial advisors, agents or staff of any successor public entity, as such, either directly or through the Governmental Lender, the County or any successor public entity, under any rule of law or penalty of otherwise, and all such liability of any member of the Governmental Lender, its governing body and its officers, attorneys, accountants, financial advisors, agents and staff is hereby, and by the acceptance of the Funding Loan, expressly waived and released as a condition of, and in consideration for, the execution of this Borrower Loan Agreement and the issuance of the Funding Loan. It is recognized that notwithstanding any other provision of this Borrower Loan Agreement, neither the Borrower, the Funding Lender nor the Fiscal Agent shall look to the members of the Governmental Lender or the County or its officers, program participants, attorneys, accountants, financial advisors, agents or staff, past, present or future, for damages suffered by the Borrower, the holders or such Fiscal Agent as a result of the failure of the Governmental Lender to perform any covenant, undertaking or obligation under this Borrower Loan Agreement, the Funding Loan, the Regulatory Agreement, any of the other Funding Loan Documents or any of the other documents referred to herein, or as a result of the incorrectness of any representation made by the Governmental Lender in any of such documents, nor for any other reason except for representations made by the Governmental Lender in any certificate of the Governmental Lender and the opinion of counsel to the Governmental Lender delivered on the date of origination of the Funding Loan. Although this Borrower Loan Agreement recognizes that such documents shall not give rise to any pecuniary liability of the Governmental Lender, nothing contained in this Borrower Loan Agreement shall be construed to preclude in any way any action or proceeding (other than that element of any action or proceeding involving a claim for monetary damages against the Governmental Lender) in any court or before any governmental body, agency or instrumentality or otherwise against the Governmental Lender or any of its officers or employees to enforce the provisions of any of such documents which the Governmental Lender is obligated to perform and the performance of which the Governmental Lender has not assigned to the Fiscal Agent or any other person. Section 11.3 Waiver of Personal Liability. No member, director, officer, agent, elected official or employee of the Governmental Lender shall be individually or personally liable for the payment of any principal (or prepayment price) of or interest on the Funding Loan or any other sum hereunder or be subject to any personal liability or accountability by reason of the execution and delivery of this Borrower Loan Agreement; but nothing herein contained shall relieve any such member, director, officer, agent or employee from the performance of any official duty provided by law or by this Borrower Loan Agreement. Section 11.4 Limitation on Liability of Funding Lender’s Officers, Employees, Etc. (a) The Borrower assumes all risks of the acts or omissions of the Governmental Lender and the Funding Lender, provided, however, this assumption is not intended to, and shall not, preclude Borrower from pursuing such rights and remedies as it may have against the Governmental Lender and the Funding Lender at law or under any other agreement. None of Governmental Lender and the Funding Lender, nor the other Beneficiary Parties or their respective officers, directors, employees or agents shall be liable or responsible for (i) for any acts or omissions of the Governmental Lender and the Funding Lender; or (ii) the validity, sufficiency or genuineness of any documents, or endorsements, even if such documents should in fact prove to be in any or all respects invalid, insufficient, fraudulent or forged. In furtherance and not in limitation of the foregoing, the Governmental Lender and the Funding Lender may accept documents that appear on their face to be in order, without responsibility for further investigation, regardless of any notice or information to the contrary, unless acceptance in light of such notice or information constitutes gross negligence or willful misconduct on the part of the Governmental Lender or the Funding Lender. 71 4894-2953-3827.5 (b) None of the Governmental Lender the Funding Lender, the other Beneficiary Parties or any of their respective officers, directors, employees or agents shall be liable to any contractor, subcontractor, supplier, laborer, architect, engineer or any other party for services performed or materials supplied in connection with the Project. The Governmental Lender and the Funding Lender shall not be liable for any debts or claims accruing in favor of any such parties against Borrower or others or against the Project. Borrower is not and shall not be an agent of the Governmental Lender and the Funding Lender for any purpose. Neither the Governmental Lender nor the Funding Lender is a joint venture partner or member with Borrower in any manner whatsoever. Prior to default by Borrower under this Borrower Loan Agreement and the exercise of remedies granted herein, the Governmental Lender and the Funding Lender shall not be deemed to be in privity of contract with any contractor or provider of services to the Project, nor shall any payment of funds directly to a contractor, subcontractor or provider of services be deemed to create any third party beneficiary status or recognition of same by the Governmental Lender and the Funding Lender. Approvals granted by the Governmental Lender and the Funding Lender for any matters covered under this Borrower Loan Agreement shall be narrowly construed to cover only the parties and facts identified in any written approval or, if not in writing, such approvals shall be solely for the benefit of Borrower. (c) Any obligation or liability whatsoever of the Governmental Lender and the Funding Lender that may arise at any time under this Borrower Loan Agreement, or any other Borrower Loan Document shall be satisfied, if at all, out of the Funding Lender’s assets only. No such obligation or liability shall be personally binding upon, nor shall resort for the enforcement thereof be had to, the Project or any of the Governmental Lender’s or the Funding Lender’s shareholders (if any), directors, officers, employees or agents, regardless of whether such obligation or liability is in the nature of contract, tort or otherwise. Section 11.5 Delivery of Reports, Etc. The delivery of reports, information and documents to the Governmental Lender and the Funding Lender as provided herein is for informational purposes only and the Governmental Lender’s and the Funding Lender’s receipt of such shall not constitute constructive knowledge of any information contained therein or determinable from information contained therein. The Governmental Lender and the Funding Lender shall have no duties or responsibilities except those that are specifically set forth herein, and no other duties or obligations shall be implied in this Borrower Loan Agreement against the Governmental Lender and the Funding Lender. Section 11.6 Restatement of Construction Phase Borrower Loan Agreement. The parties hereto do hereby amend and restate the Construction Phase Borrower Loan Agreement by substituting this Borrower Loan Agreement in its entirety for the Construction Phase Borrower Loan Agreement. Section 11.7 Electronic Transactions. The transactions described in this Borrower Loan Agreement may be conducted and the related documents may be stored by electronic means. Copies, telecopies, facsimiles, electronic files and other reproductions of original executed documents shall be deemed to be authentic and valid counterparts of such original documents for all purposes, including the filing of any claim, action or suit in the appropriate court of law. Notwithstanding the foregoing, original executed versions of each of the Funding Loan Agreement and the Borrower Loan Agreement shall be delivered to the Funding Lender in connection with the closing of the transactions described herein. [The remainder of this page is intentionally left blank; signature pages follow.] S-1 4894-2953-3827.5 IN WITNESS WHEREOF, the undersigned has duly executed and delivered this Borrower Loan Agreement or caused this Borrower Loan Agreement to be duly executed and delivered by its authorized representative as of the date first set forth above. The undersigned intends that this instrument shall be deemed to be signed and delivered as a sealed instrument. BORROWER: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, it’s authorized partner By: Kenneth Naylor, Vice President [Signature Page to Amended and Restated Borrower Loan Agreement – Vista Breeze] S-2 4894-2953-3827.5 GOVERNMENTAL LENDER: HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, as the Governmental Lender By: Name: Title: [Signature Page to Amended and Restated Borrower Loan Agreement – Vista Breeze] S-3 4894-2953-3827.5 Agreed to and Acknowledged by: FUNDING LENDER: CITIBANK, N.A. By: Name: Title: [Signature Page to Amended and Restated Borrower Loan Agreement – Vista Breeze] S-4 4894-2953-3827.5 Agreed to and Acknowledged by: FISCAL AGENT: THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A. By: Name: Title: [Signature Page to Amended and Restated Borrower Loan Agreement –Vista Breeze] D Forward Purchase Agreement Vista Breeze EXHIBIT D-3 TO FORWARD PURCHASE AGREEMENT FORM OF AMENDED AND RESTATED MULTIFAMILY NOTE [See attached] EXHIBIT D-3 TO FORWARD PURCHASE AGREEMENT FORM OF AMENDED AND RESTATED MULTIFAMILY NOTE $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN-OUT] [Month] [Day], 202[_] FOR VALUE RECEIVED, the undersigned (“Borrower”) promises to pay to the order of the HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, a public body corporate and politic organized and existing under the laws of the State of Florida, in the principal sum of [ELEVEN MILLION EIGHT HUNDRED SEVENTY FIVE THOUSAND AND NO/100 DOLLARS ($11,875,000)], with interest on the unpaid principal balance from time to time outstanding at the annual rate as set forth on Schedule A. The terms of this Note incorporate the Modifications, if any, set forth on Schedule C to this Note. 1. Defined Terms. As used in this Note, the following terms shall have the following definitions: (a) “Beneficiary Parties” shall have the meaning set forth in the Security Instrument. (b) “Borrower Loan” means the loan evidenced by this Note, the proceeds of which shall be disbursed in accordance with the Borrower Loan Agreement. (c) “Borrower Loan Agreement” means that certain Amended and Restated Borrower Loan Agreement, dated as of [Month] [Day], 20[_], by and between Borrower and Governmental Lender. (d) “Business Day” means any day other than (i) a Saturday or a Sunday, or (ii) a day on which federally insured depository institutions in New York, New York are authorized or obligated by law, regulation, governmental decree or executive order to be closed. (e) “Closing Date” shall mean the date of this Note. (f) “Default Rate” shall have the meaning set forth in Section 8 of this Note. (g) “First Payment Date” means the first Business Day of the first month following the Closing Date. (h) “Fiscal Agent” means The Bank of New York Mellon Trust Company, N.A., a national banking association, and its successors. (i) “Funding Lender” means Citibank, N.A., a national banking association, and its successors and assigns. 2 Vista Breeze (j) “Governmental Lender” means the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida. (k) “Indebtedness” means the principal of, interest on, and any other amounts due at any time under, this Note, the Security Instrument or any other Borrower Loan Document, including prepayment premiums, late charges, default interest, and advances to protect the security of the Security Instrument as described in Section 12 of the Security Instrument. (l) “Interest-Only Period End Date” means the date that is twenty-four (24) months after the First Payment Date. (m) “Interest Rate” shall have the meaning set forth in Schedule A to this Note. (n) “Lender” means the Funding Lender, as assignee of this Note, and any subsequent holder of this Note. (o) “Loan Month” means the period commencing on a Loan Payment Date and ending on the day preceding the next succeeding Loan Payment Date (without adjustment in either case for Business Day conventions). (p) “Loan Payment Date” means the first Business Day of each month, commencing on the First Payment Date. (q) “Lock-Out Period” means the tenth (10th) anniversary of the Closing Date. (r) “Mandatory Prepayment Date” means January 1, 2042, or if such day is not a Business Day, the first Business Day following means January 2, 2042. (s) “Maturity Date” means the earlier to occur of (i) July 1, 2057, or (ii) any earlier date on which the unpaid principal balance of this Note becomes due and payable, by acceleration or otherwise. (t) “Maximum Rate” means the lesser of (i) twelve percent (12%) per annum or (ii) the maximum interest rate that may be paid on the Borrower Loan under the laws of the Property Jurisdiction. (u) “Note” means this Amended and Restated Multifamily Note. (v) “Note Interest” shall have the meaning set forth in Paragraph 1 of Schedule A to this Note. 3 Vista Breeze (w) “Original Funding Lender” means Bank of America, N.A., a national banking association, in its capacity as initial funding lender. (x) “Prepayment Premium Period” means the period commencing on the Closing Date and ending on the date that is six (6) months prior to the Mandatory Prepayment Date. (y) “Property Jurisdiction” shall have the meaning set forth in the Security Instrument. (z) “Security Instrument” means the Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents Security Agreement and Fixture Filing (Florida), dated as of [_] 1, 202[_], made by Borrower and Landlord for the benefit of Governmental Lender, as assigned to the Fiscal Agent. (aa) “Servicer Remittance Date” means two (2) Business Days prior to each Loan Payment Date. All other capitalized terms used but not defined in this Note shall have the meanings given to such terms in the Borrower Loan Agreement. 2. Method of Payment. All payments due under this Note shall be payable to Servicer, or, if there is no Servicer, to the Lender, or its successor. Each such payment shall be made by wire transfer of immediately available funds in accordance with wire transfer instructions that the Lender or Servicer shall supply by Written Notice to the Borrower from time to time. 3. Payment of Principal and Interest. Principal and interest shall be paid as follows: (a) Borrower shall pay all amounts due under this Note at the times and in the amounts set forth herein and in the Borrower Loan Agreement. Borrower shall make its payments under this Note in immediately available funds. (b) Commencing on the First Payment Date and continuing on each Loan Payment Date thereafter until and including the Interest-Only Period End Date, Borrower shall pay monthly payments of interest only, as interest only, at the Interest Rate set forth on Schedule A attached hereto, in successive monthly installments. Such payments shall be made to the Lender or the Servicer by 2:00 p.m., New York City time, on each Servicer Remittance Date. (c) Commencing on the first Loan Payment Date following the Interest-Only Period End Date, and continuing on each Loan Payment Date thereafter until and including the Maturity Date, Borrower shall pay monthly payments of principal and interest as set forth on Schedule A attached hereto, in successive monthly installments. Such payments shall be made to the Lender or the Servicer by 2:00 p.m., New York City time, on each Servicer Remittance Date. 4 Vista Breeze (d) Any accrued interest remaining past due may, at Lender’s discretion, be added to and become part of the unpaid principal balance and shall bear interest at the rate or rates specified in this Note, and any reference below to “accrued interest” shall refer to accrued interest that has not become part of the unpaid principal balance. (e) Borrower shall pay all unpaid principal of and interest on this Note on the Maturity Date and any other amounts due under subsection 3(a) hereof. (f) Any regularly scheduled monthly installment of principal and interest that is received by Lender before the date it is due shall be deemed to have been received on the due date solely for the purpose of calculating interest due. (g) Borrower shall make all payments of principal and interest under this Note without relief from valuation and appraisement laws. (h) Borrower acknowledges that the calculation of all interest payments shall be made by the Lender and shall be final and conclusive, absent manifest error. 4. Application of Payments. If at any time Lender receives, from Borrower or otherwise, any amount applicable to the Indebtedness which is less than all amounts due and payable at such time, Lender may apply that payment to amounts then due and payable under this Note in any manner and in any order determined by Lender, in Lender’s discretion. Borrower agrees that neither Lender’s acceptance of a payment from Borrower in an amount that is less than all amounts then due and payable nor Lender’s application of such payment shall constitute or be deemed to constitute either a waiver of the unpaid amounts or an accord and satisfaction. 5. Security. The Indebtedness is secured by, among other things, the Security Instrument, and reference is made to the Security Instrument for other rights of Lender as to collateral for the Indebtedness. 6. Acceleration. If an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Lender have any obligation to accept a cure of an Event of Default), the entire unpaid principal balance, any accrued interest, the prepayment premium payable under Section 10, if any, and all other amounts payable under this Note and any other Borrower Loan Document shall at once become due and payable, at the option of Lender, without any prior notice to Borrower (except if notice is required by applicable law, then after such notice). Lender may exercise this option to accelerate regardless of any prior forbearance. 7. Late Charge. If any amount payable under this Note or under the Security Instrument or any other Borrower Loan Document is not received by Lender when such amount is due (unless applicable law requires a longer period of time before a late charge may be imposed, in which event, such longer period shall be substituted), Borrower shall pay to Lender, immediately and without demand by Lender, a late charge equal to five percent (5.0%) of such amount (unless applicable law requires a lesser amount be charged, in which event such lesser amount shall be substituted). Notwithstanding the foregoing, with regard to each regularly scheduled monthly installment of principal and/or interest payable pursuant to this Note, such 5 Vista Breeze late charge shall not become due and payable to Lender so long as the Borrower makes such payment on or prior to the tenth (10th) calendar day following the date upon which such payment is due (or the Business Day immediately following such tenth (10th) calendar day if such tenth (10th) calendar day is not a Business Day). Any accrued but unpaid late charges shall be added to and become part of the unpaid principal balance of this Note, shall bear interest at the rate or rates specified in this Note, and shall be secured by the Security Instrument and the other applicable Borrower Loan Documents. Borrower acknowledges that its failure to make timely payments will cause Lender to incur additional expenses in servicing and processing the Borrower Loan, and that it is extremely difficult and impractical to determine those additional expenses. Borrower agrees that the late charge payable pursuant to this Section represents a fair and reasonable estimate, taking into account all circumstances existing on the Closing Date, of the additional expenses Lender will incur by reason of such late payment, and such late charge shall be deemed liquidated damages and not additional interest or a penalty. The late charge is payable in addition to, and not in lieu of, any interest payable at the Default Rate pursuant to Section 8. Notwithstanding anything to the contrary in any other Borrower Loan Document, if a Servicer has been appointed by Lender, any late charges payable hereunder shall not be remitted to Lender and shall instead be paid directly to Servicer, who shall apply such late charges in accordance with the terms of the applicable servicing agreement. Any action regarding the collection of a Late Charge will be without prejudice to any other rights, and shall not act as a waiver of any other rights that the Servicer or the Lender may have as provided herein, in the other Borrower Loan Documents, or at law or in equity. 8. Default Rate. So long as (a) any monthly installment under this Note remains past due, or (b) any other Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Lender have any obligation to accept a cure of an Event of Default), interest under this Note shall accrue on the unpaid principal balance from the earlier of the due date of the first unpaid monthly installment or the occurrence of such other Event of Default, as applicable, at a rate per annum (the “Default Rate”) equal to the lesser of the Maximum Rate or a rate equal to the Interest Rate plus four percent (4%), in each case compounded monthly (computed in accordance with Schedule A in the same manner in which Note Interest is computed). In accordance with Section 55.03(1), Florida Statutes, Borrower hereby expressly agrees that the Default Rate shall be applicable to interest accruing on any judgment entered with respect to the indebtedness evidenced hereby or by any of the other Borrower Loan Documents. If the unpaid principal balance and all accrued interest are not paid in full on the Maturity Date, the unpaid principal balance and all accrued interest shall bear interest from the Maturity Date at the Default Rate until the unpaid principal balance and all accrued interest is paid in full. Borrower also acknowledges that its failure to make timely payments will cause Lender to incur additional expenses in servicing and processing the Borrower Loan, that, during the time that any monthly installment under this Note is delinquent, Lender will incur additional costs and expenses arising from its loss of the use of the money due and from the adverse impact on Lender’s ability to meet its other obligations and to take advantage of other investment opportunities, and that it is extremely difficult and impractical to determine those additional costs and expenses. Borrower also acknowledges that, during the time that any monthly installment under this Note is delinquent or any other Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Lender have any obligation to accept a cure of an Event of Default), Lender’s risk of nonpayment of this Note will be materially increased and Lender is entitled to be compensated for such increased risk. 6 Vista Breeze Borrower agrees that the increase in the rate of interest payable under this Note to the Default Rate as provided above represents a fair and reasonable estimate, taking into account all circumstances existing on the Closing Date, of the additional costs and expenses Lender will incur by reason of Borrower’s delinquent payment and the additional compensation Lender is entitled to receive for the increased risks of nonpayment associated with a delinquent loan. 9. Personal Liability of Borrower. (a) Intentionally Omitted. (b) Except as otherwise provided in this Section 9, neither Borrower nor any of its partners, members and/or managers shall have any personal liability under this Note, the Security Instrument or any other Borrower Loan Document for the repayment of the Indebtedness or for the performance of any other obligations of Borrower under the Borrower Loan Documents, and Lender’s only recourse for the satisfaction of the Indebtedness and the performance of such obligations shall be Lender’s exercise of its rights and remedies with respect to the Mortgaged Property and any other collateral held by Lender as security for the Indebtedness. This limitation on Borrower’s liability shall not limit or impair Lender’s enforcement of its rights against any guarantor of the Indebtedness or any guarantor of any obligations of Borrower. (c) Borrower shall at all times be personally liable to Lender for the repayment of a portion of the Indebtedness equal to any loss or damage suffered by Lender (the “Losses”) as a result of (1) failure of Borrower to pay to Lender upon demand after an Event of Default all Rents to which Lender is entitled under Section 3(a) of the Security Instrument and the amount of all security deposits collected by Borrower from tenants then in residence; (2) failure of Borrower to apply all insurance proceeds and condemnation proceeds as required by the Security Instrument; (3) failure of Borrower to comply with Section 14(d) or (e) of the Security Instrument relating to the delivery of books and records, statements, schedules, and reports; (4) fraud or material misrepresentation by Borrower or Guarantor or any general partner, managing member, manager, officer, director, partner, member, agent or employee of Borrower or Guarantor in connection with the application for or creation of the Indebtedness or any request for any action or consent by or on behalf of Lender; (5) failure to apply Rents (as defined in the Security Instrument), first, to the payment of reasonable operating expenses (other than property management fees that are not currently payable pursuant to the terms of an Assignment of Management Agreement or any other Borrower Loan Document) and then to amounts (“Debt Service Amounts”) payable under this Note, the Security Instrument or any other Borrower Loan Document (except that Borrower will not be personally liable (i) to the extent that Borrower lacks the legal right to direct the disbursement of such sums because of a bankruptcy, receivership or similar judicial proceeding, or (ii) with respect to Rents that are distributed on account of any calendar year if Borrower has paid all operating expenses and Debt Service Amounts for that calendar year); (6) failure of Borrower to comply with the provisions of Section 17(a) of the Security Instrument prohibiting the commission of waste or allowing the impairment or deterioration of the Mortgaged Property; or (7) failure of Borrower to obtain and maintain any local real estate tax abatement or exemption required under the Security Instrument, or the 7 Vista Breeze reduction, revocation, cancellation or other termination of such abatement or exemption, as a result of any act or omission by or on behalf of Borrower, Guarantor or any of their respective partners, members, managers, directors, officers, agents, employees or representatives. (d) For purposes of determining Borrower’s personal liability under this Section 9, all payments made by Borrower with respect to the Indebtedness and all amounts received by Lender from the enforcement of its rights under the Security Instrument shall be applied first to the portion of the Indebtedness for which Borrower has no personal liability. (e) Borrower shall at all times be personally liable to Lender for the repayment of all of the Indebtedness upon the occurrence of any of the following Events of Default: (1) Borrower’s acquisition of any property or operation of any business not permitted by Section 32 of the Security Instrument; or (2) a Transfer (including, but not limited to, a lien or encumbrance) that is an Event of Default under Section 21 of the Security Instrument, other than a Transfer consisting solely of the involuntary removal or involuntary withdrawal of a general partner in a limited partnership or a manager in a limited liability company; or (3) a Bankruptcy Event, as defined in the Security Instrument (but only if the Bankruptcy Event occurs with the consent or active participation of Borrower, its General Partner, Guarantor or any Borrower Affiliate. (f) In addition to the Borrower’s personal liability pursuant to the other provisions of this Note, Borrower shall at all times be personally liable to Lender for (1) the performance of all of Borrower’s obligations under Section 18 of the Security Instrument (relating to environmental matters) and the Agreement of Environmental Indemnification; (2) the costs of any audit under Section 14(d) of the Security Instrument; and (3) any costs and expenses incurred by Lender in connection with the collection of all amounts for which Borrower is personally liable under this Section 9, including out of pocket expenses and reasonable fees of attorneys and expert witnesses and the costs of conducting any independent audit of Borrower’s books and records to determine the amount for which Borrower has personal liability. (g) To the extent that Borrower has personal liability under this Section 9, Lender may exercise its rights against Borrower personally without regard to whether Lender has exercised any rights against the Mortgaged Property or any other security, or pursued any rights against any guarantor, or pursued any other rights available to Lender under this Note, the Security Instrument, any other Borrower Loan Document or applicable law. For purposes of this Section 9, the term “Mortgaged Property” shall not include any funds that (1) have been applied by Borrower as required or permitted by the Security Instrument prior to the occurrence of an Event of Default or (2) Borrower was unable to apply as required or permitted by the Security Instrument because of a bankruptcy, receivership, or similar judicial proceeding. To the fullest extent permitted by applicable law, in any action to enforce Borrower’s personal liability under this Section 9, Borrower waives any right to set off the value of the Mortgaged Property against such personal liability. 8 Vista Breeze (h) Nothing herein or in the other Borrower Loan Documents shall be deemed to be a waiver of any right which the Lender or the Servicer may have under Sections 506(a), 506(b), 1111(b) or any other provision of the United States Bankruptcy Code, as such sections may be amended, or corresponding or superseding sections of the Bankruptcy Amendments and Federal Judgeship Act of 1984, to file a claim for the full amount due to the Lender and the Servicer hereunder and under the other Borrower Loan Documents or to require that all collateral shall continue to secure the amounts due hereunder and under the other Borrower Loan Documents. 10. Prepayments. (a) In connection with any prepayment (i.e., any receipt by Lender of principal, other than principal required to be paid in monthly installments pursuant to Section 3, prior to the Maturity Date) made under this Note, whether voluntary or involuntary, a prepayment premium shall be payable to the extent provided below. EXCEPT AS OTHERWISE PERMITTED HEREIN, NO VOLUNTARY PREPAYMENTS OF THIS NOTE, IN WHOLE OR IN PART, SHALL BE PERMITTED. (b) Intentionally Omitted. (c) Intentionally Omitted. (d) No voluntary prepayments of this Note, in whole or in part, shall be permitted during the Lock-Out Period. After the Lock-Out Period, Borrower may voluntarily prepay all (but not less than all) of the unpaid principal balance of this Note if: (i) Borrower has given Lender prior Written Notice of its intention to make such prepayment at least thirty (30) days prior to the proposed prepayment date (or such shorter time as agreed to by Lender in its sole discretion) and (ii) Borrower pays (A) the entire unpaid principal balance of this Note, (B) all accrued interest, (C) if applicable, the prepayment premium calculated pursuant to Schedule B, and (D) all other sums due Lender at the time of such prepayment. If Lender, in Lender’s sole and absolute discretion, agrees in writing to waive the foregoing provisions and allow any prepayment that is not permitted hereunder, a prepayment premium calculated pursuant to Schedule B shall be due and payable by Borrower on the amount of principal being prepaid. In connection with any prepayment pursuant to this Section 10(d), the Borrower shall wire transfer the amount required hereunder in immediately available funds by no later than 12:00 p.m., New York City time, on the date of prepayment. For all purposes including the accrual of interest, any prepayment received by Lender on any day other than the last calendar day of a Loan Month shall be deemed to have been received on the last calendar day of such Loan Month. (e) Upon Lender’s exercise of any right of acceleration under this Note, Borrower shall pay to Lender, in addition to the entire unpaid principal balance of this Note outstanding at the time of the acceleration, (i) all accrued interest and all other sums due Lender, and (ii) if applicable, the prepayment premium calculated pursuant to Schedule B. 9 Vista Breeze (f) Any application by Lender of any collateral or other security to the repayment of any portion of the unpaid principal balance of this Note in the absence of acceleration shall be deemed to be a partial prepayment by Borrower, requiring the payment to Lender by Borrower of a prepayment premium, calculated pursuant to Schedule B. (g) Intentionally Omitted. (h) The Borrower shall prepay the entire outstanding principal balance of this Note, at the direction of the Lender, at a price equal to the outstanding principal balance of this Note, plus (i) accrued interest and any other amounts payable under this Note or the Borrower Loan Agreement through the date of prepayment, and (ii) if applicable, the prepayment premium calculated pursuant to Schedule B, upon the occurrence of any event or condition described below: (1) no later than the day before (a) any sale of the Project, restructuring of the Borrower or any other event that would cause or be deemed to cause an assumption of obligations of an unrelated party for purposes of Section 1.150-1(d)(2) of the Regulations (any such event referred to herein as a “Transfer”) which Transfer would occur within six months of a “refinancing” (as contemplated by such Regulation), or (b) any “refinancing” that would occur within six months of a Transfer; or (2) in whole, upon a Determination of Taxability. In connection with any such prepayment, the Borrower shall wire transfer immediately available funds by no later than 12:00 p.m., New York City time, on the date fixed by the Lender, which date shall be communicated by the Lender in writing to the Borrower. (i) The Borrower shall prepay the outstanding principal balance of this Note at the direction of the Lender, in whole or in part, at a price equal to the amount of principal being prepaid plus accrued interest and any other amounts payable under this Note or the other Borrower Loan Documents, upon the occurrence of any event or condition described below: (1) in whole or in part, if the Mortgaged Property shall have been damaged or destroyed to the extent that it is not practicable or feasible to rebuild, repair or restore the damaged or destroyed property within the period and under the conditions described in the Security Instrument following such event of damage or destruction; or (2) in whole or in part, if title to, or the use of, all or a portion of the Mortgaged Property shall have been taken under the exercise of the power of eminent domain by any Governmental Authority which results in a prepayment of this Note under the conditions described in the Security Instrument; or 10 Vista Breeze (3) in whole or in part, to the extent that insurance proceeds or proceeds of any condemnation award with respect to the Mortgaged Property are not applied to restoration of the Mortgaged Property in accordance with the provisions of the Security Instrument. In connection with any such prepayment, the Borrower shall wire transfer immediately available funds by no later than 12:00 p.m., New York City time, on the date fixed by the Lender, which date shall be communicated by the Lender in writing to the Borrower. To the extent that the Borrower receives any insurance proceeds or condemnation awards that are to be applied to the prepayment of this Note, such amounts shall be applied to the prepayment of this Note. No prepayment premium shall be payable with respect to any prepayment required by this Section 10(i). (j) Any permitted or required prepayment of less than the unpaid principal balance of this Note shall not extend or postpone the due date of any subsequent monthly installments or change the amount of such installments, unless Lender agrees otherwise in writing. (k) Borrower recognizes that any prepayment of the unpaid principal balance of this Note, whether voluntary, involuntary or resulting from a default by Borrower, will result in Lender incurring a loss, including reinvestment loss, additional expense and frustration or impairment of Lender’s ability to meet its commitments to third parties. Borrower agrees to pay to Lender upon demand damages for the detriment caused by any prepayment, and agrees that it is extremely difficult and impractical to ascertain the extent of such damages. Borrower therefore acknowledges and agrees that the formula for calculating prepayment premiums set forth on Schedule B represents a reasonable estimate of the damages Lender will incur because of a prepayment. (l) Borrower further acknowledges that the prohibition of voluntary prepayment and the prepayment premium provisions of this Note are a material part of the consideration for the Borrower Loan, and acknowledges that the terms of this Note are in other respects more favorable to Borrower as a result of Borrower’s voluntary agreement to such provisions. (m) Notwithstanding anything herein to the contrary, Borrower shall prepay this Note, together with all amounts due under the Borrower Loan Documents, in full on the Mandatory Prepayment Date. (n) Any prepayment premium payable hereunder shall be remitted to Servicer, or if a Servicer has not been appointed by Lender, to Lender. 11. Costs and Expenses. To the fullest extent allowed by applicable law, Borrower shall pay all expenses and costs, including, without limitation, out-of-pocket expenses and reasonable fees of attorneys (including, without limitation, in-house attorneys) and expert witnesses and costs of investigation, incurred by Lender as a result of any default under this Note or in connection with efforts to collect any amount due under this Note, or to enforce the provisions of any of the other Borrower Loan Documents, including those incurred in post- 11 Vista Breeze judgment collection efforts and in any bankruptcy proceeding (including any action for relief from the automatic stay of any bankruptcy proceeding) or judicial or non-judicial foreclosure proceeding. For purposes of Section 9(f) and this Section 11, attorneys’ out-of-pocket expenses shall include, but are not limited to, support staff costs, costs of preparing for litigation, computerized research, telephone and facsimile transmission expenses, mileage, deposition costs, postage, duplicating, process service, videotaping and similar costs and expenses. 12. Forbearance. Any forbearance by Lender in exercising any right or remedy under this Note, the Security Instrument, or any other Borrower Loan Document or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of that or any other right or remedy. The acceptance by Lender of any payment after the due date of such payment, or in an amount which is less than the required payment, shall not be a waiver of Lender’s right to require prompt payment when due of all other payments or to exercise any right or remedy with respect to any failure to make prompt payment. Enforcement by Lender of any security for Borrower’s obligations under this Note shall not constitute an election by Lender of remedies so as to preclude the exercise of any other right or remedy available to Lender. 13. Waivers. Presentment, demand, notice of dishonor, protest, notice of acceleration, notice of intent to demand or accelerate payment or maturity, presentment for payment, notice of nonpayment, grace, and diligence in collecting the Indebtedness are waived by Borrower and all endorsers and guarantors of this Note and all other third party obligors. 14. Borrower Loan Charges. Neither this Note nor any of the other Borrower Loan Documents shall be construed to create a contract for the use, forbearance or detention of money requiring payment of interest at a rate greater than the maximum interest permitted to be charged under applicable law. If any applicable law limiting the amount of interest or other charges permitted to be collected from Borrower in connection with the Borrower Loan is interpreted so that any interest or other charge provided for in any Borrower Loan Document, whether considered separately or together with other charges provided for in any other Borrower Loan Document, violates that law, and Borrower is entitled to the benefit of that law, that interest or charge is hereby reduced to the extent necessary to eliminate that violation. The amounts, if any, previously paid to Lender in excess of the permitted amounts shall be applied by Lender to reduce the unpaid principal balance of this Note. For the purpose of determining whether any applicable law limiting the amount of interest or other charges permitted to be collected from Borrower has been violated, all Indebtedness that constitutes interest, as well as all other charges made in connection with the Indebtedness that constitute interest, shall be deemed to be allocated and spread ratably over the stated term of this Note. Unless otherwise required by applicable law, such allocation and spreading shall be effected in such a manner that the rate of interest so computed is uniform throughout the stated term of this Note. 15. Obligations of the Borrower Absolute and Unconditional. Subject to Section 9, the obligations of the Borrower to make all payments required under this Note and the other Borrower Loan Documents on or before the date the same become due, and to perform all of its other obligations, covenants and agreements hereunder and under the other Borrower Loan Documents shall be primary, absolute, unconditional and irrevocable, and shall be paid or performed strictly in accordance with the terms of this Note and the other Borrower Loan Documents under any and all circumstances, without notice or demand, and without abatement, 12 Vista Breeze deduction, set-off, counterclaim, recoupment or defense or any right of termination or cancellation arising from any circumstance whatsoever, whether now existing or hereafter arising, and irrespective of whether the Borrower’s title to the Mortgaged Property or to any part thereof is defective or nonexistent, and notwithstanding any damage due to loss, theft or destruction of the Mortgaged Property or any part thereof, any failure of consideration or frustration of commercial purpose, the taking by eminent domain of title to or of the right of temporary use of all or any part of the Mortgaged Property, legal curtailment of the Borrower’s use thereof, the eviction or constructive eviction of the Borrower, any change in the tax or other laws of the United States of America, the State or any political subdivision thereof, any change in the Lender’s legal organization or status, or any default of the Lender hereunder or under any other Borrower Loan Document, and regardless of the invalidity of any action of the Lender or the invalidity of any portion of this Note or the other Borrower Loan Documents. Provided further, the obligations of Borrower under this Note and the other Borrower Loan Documents shall not be affected by: (a) any lack of validity or enforceability of any Borrower Loan Document or any of the Related Documents; (b) any amendment of, or any waiver or consent with respect to, any of the Borrower Loan Documents or Related Documents; (c) the existence of any claim, set-off, defense or other rights which Borrower, General Partner or Guarantor may have at any time against Lender (other than the defense of payment in accordance with the terms of this Note or the other Borrower Loan Documents) or any other Person, whether in connection with this Note or any other Borrower Loan Document, the Related Documents or any transaction contemplated thereby or any unrelated transaction; (d) any breach of contract or other dispute between Borrower, General Partner or Guarantor, and Lender; (e) any Funding Requisition or any document presented in connection therewith, proving to be forged, fraudulent, untrue, inaccurate, invalid or insufficient in any respect (except in the event of willful misconduct by Lender with respect to same); or (f) any exchange, release or nonperfection of any lien or security interest in any collateral pledged or otherwise provided to secure any of the obligations contemplated herein, in any other Borrower Loan Document or in any Related Document. The Borrower hereby waives the application to it of the provisions of any statute or other law now or hereafter in effect contrary to any of its obligations, covenants or agreements under this Note or the other Borrower Loan Documents or which releases or purports to release the Borrower therefrom. Nothing contained herein shall be construed as prohibiting the Borrower from pursuing any rights or remedies it may have against any Person in a separate legal proceeding. 13 Vista Breeze 16. Commercial Purpose. Borrower represents that the Indebtedness is being incurred by Borrower solely for the purpose of carrying on a business or commercial enterprise, and not for personal, family, household or agricultural purposes. 17. Counting of Days. Except where otherwise specifically provided, any reference in this Note to a period of “days” means calendar days, not Business Days. 18. Notices. All notices, demands and other communications required or permitted to be given pursuant to this Note shall be in writing and addressed as set forth below. Each notice shall be deemed given on the earliest to occur of (a) the date when the notice is received by the addressee; (b) the first Business Day after the notice is delivered to a recognized overnight courier service, with arrangements made for payment of charges for next Business Day delivery; or (c) the third Business Day after the notice is deposited in the United States mail with postage prepaid, certified mail, return receipt requested. If to Borrower: Vista Breeze, LTD. c/o Atlantic Pacific Communities 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor With a copy to: With a copy to: With a copy to: Klein Hornig LLP 1325 G Street NW, Suite 770 Washington, D.C. 20005 Attention: Chris Hornig, Esq. Vista Breeze HACMB, Inc. c/o Housing Authority of the City of Miami Beach 200 Alton Road Miami Beach, FL 33139 Attention: Miguell Del Campillo, Executive Director Phone: (305) 532-6401, ext. 3020 Email: miguell@hacmb.org Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 Pittsburgh, PA 15219 Attention: Michael H. Syme, Esq. Email: msyme@foxrothschild.com Phone: (412) 391-2450 If to Lender: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze ID No. 60001596 14 Vista Breeze Facsimile: (212) 723-8209 And to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze ID No. 60001596 Facsimile: (805) 557-0924 With a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291-5754 The Borrower or the Lender may change the address to which notices intended for it are to be directed by means of notice given to the other party in accordance with this Section 18. Each party agrees that it will not refuse or reject delivery of any notice given in accordance with this Section 18, that it will acknowledge, in writing, the receipt of any notice upon request by the other party and that any notice rejected or refused by it shall be deemed for purposes of this Section 18 to have been received by the rejecting party on the date so refused or rejected, as conclusively established by the records of the U.S. Postal Service or the courier service. 19. Payments on Non-Business Day. If the date for the making of any payment under this Note is not a Business Day, such payment shall be due and payable on the next succeeding Business Day. 20. Terms of Note Governing Payment Matters Control in the Event of any Conflict. In the event the provisions of the Borrower Loan Agreement or the other Borrower Loan Documents (other than this Note) conflict with the provisions of this Note which govern the terms of repayment of the Borrower Loan or the payment of other amounts due in connection with the Borrower Loan (including, without limitation, the provisions of this Note which govern the required payments of principal, interest and other amounts due in connection with the Borrower Loan, the manner of payment, the calculation of interest, the payment of the Lender’s costs and expenses, the application of payments received by the Lender, the acceleration of amounts owed by the Borrower, late charges, default rates of interest, prepayments, prepayment premiums or maximum rates of interest or similar charges), the provisions of this Note shall govern and control. 15 Vista Breeze 21. Local Law Provisions (Florida). THIS NOTE IS GIVEN TO SECURE THE FINANCING OF HOUSING UNDER PART IV OF CHAPTER 159, FLORIDA STATUTES, AND IS EXEMPT FROM TAXATION PURSUANT TO SECTION 159.621, FLORIDA STATUTES. ACCORDINGLY, NO DOCUMENTARY STAMP TAX OR INTANGIBLE TAX IS DUE IN CONNECTION WITH THIS NOTE. 22. Determinations by Lender. Except to the extent expressly set forth in this Note to the contrary, in any instance where the consent or approval of Lender may be given or is required, or where any determination, judgment or decision is to be rendered by Lender under this Note, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by Lender, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. 23. Release; Indemnity. (a) Release. Borrower covenants and agrees that, in performing any of its rights or duties under this Note, neither the Beneficiary Parties, nor their respective agents or employees, shall be liable for any losses, claims, damages, liabilities and expenses that may be incurred by any of them as a result of such performance, except to the extent such liability for any losses, claims, damages, liabilities or expenses arises out of the willful misconduct or gross negligence of such party. (b) Indemnity. Borrower hereby agrees to indemnify and hold harmless the Beneficiary Parties and their respective agents and employees from and against any and all losses, claims, damages, liabilities and expenses including, without limitation, reasonable attorneys’ fees and costs and disbursements, which may be imposed or incurred by any of them in connection with this Note, except that no such party will be indemnified for any losses, claims, damages, liabilities or expenses arising out of the willful misconduct or gross negligence of such party. 24. Governing Law. This Note shall be governed by and enforced in accordance with the laws of the Property Jurisdiction, without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 25. Consent to Jurisdiction and Venue. Borrower agrees that any controversy arising under or in relation to this Note shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Note. Borrower irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Lender’s right to bring any suit, action or proceeding relating to matters arising under this Note against Borrower or any of Borrower’s assets in any court of any other jurisdiction. 16 Vista Breeze 26. Severability. The invalidity, illegality or unenforceability of any provision of this Note shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 27. Remedies Cumulative. In the event of Borrower’s default under this Note, the Lender may exercise all or any one or more of its rights and remedies available under this Note, at law or in equity. Such rights and remedies shall be cumulative and concurrent, and may be enforced separately, successively or together, and the exercise of any particular right or remedy shall not in any way prevent the Lender from exercising any other right or remedy available to the Lender. The Lender may exercise any such remedies from time to time as often as may be deemed necessary by the Lender. 28. No Agency or Partnership. Nothing contained in this Note shall constitute Lender as a joint venturer, partner or agent of Borrower, or render Lender liable for any debts, obligations, acts, omissions, representations or contracts of Borrower. 29. Entire Agreement; Amendment and Waiver. This Note contains the complete and entire understanding of the parties with respect to the matters covered. This Note may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Note shall be considered as a general waiver. 30. Further Assurances. Borrower shall at any time and from time to time, promptly execute and deliver all further instruments and documents, and take all further action that may be reasonably necessary or desirable, or that Lender may reasonably request, in order to protect any right or interest granted by this Note or to enable Lender to exercise and enforce its rights and remedies under this Note. 31. Captions. The captions of the sections of this Note are for convenience only and shall be disregarded in construing this Note. 32. Servicer. Borrower hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Lender may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under this Note or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Borrower receives written notice from Lender to the contrary, any action or right which shall or may be taken or exercised by Lender may be taken or exercised by such servicer with the same force and effect. 33. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF BORROWER AND LENDER (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS NOTE OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS 17 Vista Breeze NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 34. Time of the Essence. Time is of the essence with respect to this Note. 35. Modifications. All modifications (if any) to the terms of this Note (“Modifications”) are set forth on Schedule C attached to this Note. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer that does not require the consent of the Funding Lender), some or all of the Modifications to this Note may be modified or rendered void by Lender at its option by notice to Borrower or such transferee. 36. Amended and Restated Note. This Note amends and restates that certain Construction Phase Project Loan Note, dated as of December 15, 2023 in the original maximum principal amount of $32,500,000 the (“Original Note”) made by Borrower in favor of Governmental Lender and endorsed to Fiscal Agent for the benefit of Original Funding Lender. Pursuant to that certain Funding Loan Agreement dated as of December 1, 2023, among Original Funding Lender, Governmental Lender and Fiscal Agent, the Original Funding Lender made a loan to the Governmental Lender, the proceeds of which Governmental Lender used to make a loan to the Borrower pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, by and between Borrower and Governmental Lender. Contemporaneously with the execution and delivery of this Note, Original Funding Lender has assigned all of its right, title and interest in and to the Original Note to Fiscal Agent for the benefit of Funding Lender pursuant to the provisions of a certain Assignment of Mortgage and Collateral Loan Documents, dated as of the December 15, 2023, and intended to be recorded in the Official Records of Miami-Dade County, Florida. This Note does not create any new or additional indebtedness but evidences the reduced outstanding indebtedness established by the Original Note so that this Note evidences a single consolidated debt in the principal amount of $[11,875,000]. This Note amends and restates in its entirety the terms, obligations, agreements, covenants and conditions set forth in the Original Note so that the terms of this Note supersede the terms, obligations, agreements, covenants and conditions of the Original Note. This Note does not extinguish the outstanding indebtedness evidenced by the Original Note or discharge or release any security therefor, and the parties do not intend this Note to be a substitution or novation of the original indebtedness or instruments securing the same. 37. Attached Schedules. The following Schedules are attached to this Note and are incorporated by reference herein as if more fully set forth in the text hereof: Schedule A – Principal and Interest Payments Schedule B – Prepayment Premium Schedule C – Modifications to Amended and Restated Multifamily Note The terms of this Note are modified and supplemented as set forth in said Schedules. To the extent of any conflict or inconsistency between the terms of said Schedules and the text of this Note, the terms of said Schedules shall be controlling in all respects. 18 Vista Breeze [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] S-1 Vista Breeze IN WITNESS WHEREOF, the undersigned has duly executed and delivered this Amended and Restated Multifamily Note or caused this Amended and Restated Multifamily Note to be duly executed and delivered by its authorized representative as of the date first set forth above. BORROWER: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: S-2 Vista Breeze PAY TO THE ORDER OF: THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS FISCAL AGENT AND ASSIGNEE, FOR THE BENEFIT OF CITIBANK, N.A. UNDER THAT CERTAIN AMENDED AND RESTATED FUNDING LOAN AGREEMENT DATED AS OF ________ 1, 202[_] WITHOUT RECOURSE HOUSING FINANCE AUTHORITY OF MIAMI- DADE COUNTY, FLORIDA By: Name: Title: A-1 Vista Breeze SCHEDULE A PRINCIPAL AND INTEREST PAYMENTS Except as provided in Sections 8 and 14 of this Note, interest (“Note Interest”) shall accrue on the unpaid principal of this Note from, and including, the Closing Date until paid in full at an annual rate (the “Interest Rate”) as follows: A. Interest Rate and Principal Payments on and after the Closing Date. From, and including, the Closing Date, until the Maturity Date, the following provisions shall apply: 1. Interest Rate. Note Interest shall accrue on the unpaid principal of this Note from, and including, the Closing Date, until the Maturity Date, at an annual rate, as follows: (a) Fixed Rate. Interest shall accrue at annual rate of six and 27/100 percent (6.27%1). [NOTE: IF THE TERMINATION DATE IS EXTENDED TO THE FIRST EXTENDED TERMINATION DATE IN ACCORDANCE WITH SECTION 4.1 OF THE FORWARD PURCHASE AGREEMENT, AN ADDITIONAL 0.05% WILL BE ADDED TO THE INTEREST RATE SET FORTH HEREUNDER, SUCH THAT INTEREST WILL ACCRUE AT AN ANNUAL INTEREST RATE OF SIX AND 32/100 PERCENT (6.32%). IF THE TERMINATION DATE IS FURTHER EXTENDED FROM THE FIRST EXTENDED TERMINATION DATE TO THE SECOND EXTENDED TERMINATION DATE IN ACCORDANCE WITH SECTION 4.1 OF THE FORWARD PURCHASE AGREEMENT, AN ADDITIONAL 0.05% WILL BE ADDED TO THE INTEREST RATE SET FORTH HEREUNDER, SUCH THAT INTEREST WILL ACCRUE AT A N ANNUAL INTEREST RATE OF SIX AND 37/100 PERCENT (6.37%). IN ADDITION, IF THE EARN-OUT RIGHT IS EXERCISED, THE PRINCIPAL AMOUNT OF THIS LOAN WILL BE INCREASED BY THE EARN-OUT AMOUNT AND THE RATE WILL BE A BLENDED RATE BETWEEN THE RATE LISTED AND THE RATE OF THE EARN-OUT AS DESCRIBED IN THE FORWARD PURCHASE AGREEMENT]. (b) Maximum Rate. Notwithstanding any other provision of this Note to the contrary, Note Interest shall not exceed the Maximum Rate, as the Maximum Rate may change in accordance with this Note. (c) Interest Accrual. Note Interest shall be computed on the basis of the actual number of days in the period in respect of which payment is being made, divided by 360. B. Monthly Interest Only Payments Until and Including the Interest-Only Period End Date. Commencing on the First Payment Date following the Closing Date and on each Loan Payment Date thereafter until and including the Interest-Only Period End Date, consecutive monthly 1 NOTE: The interest rate shall be a fixed rate equal to the sum of 18 year SOFR Swap Index (which shall have a floor of 0.75%) plus a spread of 2.40%. The rate does not include Issuer, Trustee, or miscellaneous third-party fees. A-2 Vista Breeze installments of interest only that has accrued on the outstanding principal balance of the Borrower Loan during the applicable accrual period shall be payable. C. Monthly Payments Following the Interest-Only Period End Date. Commencing on the first Loan Payment Date following the Interest-Only Period End Date and on each Loan Payment Date thereafter until and including the Maturity Date, consecutive monthly installments of principal and interest in the amount of $67,586.57 [NOTE: THIS AMOUNT CONSTITUTES THE ORIGINAL AMOUNT WITH NO EXTENSIONS. IF THE TERMINATION DATE IS EXTENDED TO THE FIRST EXTENDED TERMINATION DATE IN ACCORDANCE WITH SECTION 4.1 OF THE FORWARD PURCHASE AGREEMENT, MONTHLY INSTALLMENTS OF PRINCIPAL AND INTEREST WILL BE PAID IN THE AMOUNT OF $68,005.93. IF THE TERMINATION DATE IS FURTHER EXTENDED TO THE SECOND EXTENDED TERMINATION DATE IN ACCORDANCE WITH SECTION 4.1 OF THE FORWARD PURCHASE AGREEMENT, MONTHLY INSTALLMENTS OF PRINCIPAL AND INTEREST WILL BE PAID IN THE AMOUNT OF $68,426.18.] shall be payable on each Loan Payment Date until the entire unpaid principal balance evidenced by this Note is fully paid. Any remaining principal and interest, if not sooner paid, shall be due and payable on the Maturity Date. In the event that the Borrower Loan is reamortized at any time as a result of the application of any insurance proceeds or condemnation award in accordance with Section 10(i) of this Note, equal monthly payments of principal and interest in installments in the amount necessary to fully amortize the remaining principal balance of this Note over the remainder of the original forty (40) year amortization period, assuming, for these purposes only, a 360-day year comprised of twelve 30-day months, and a final installment on the Maturity Date in the amount of the remaining principal balance of this Note, which amortization schedule shall be determined by Lender and which determination shall be final and conclusive absent manifest error. D. Loss of Tax Exclusion. Borrower understands that the interest rates provided under this Note are based on the assumption that interest income paid on the Funding Loan and received by the Funding Lender will be excludable from Funding Lender’s gross income under Section 103 of the Internal Revenue Code and applicable state law. In the event that Borrower receives notice from Funding Lender that a Determination of Taxability (as defined in the Borrower Loan Agreement) has occurred, then, notwithstanding any provision to the contrary contained herein, the interest rate on this Note and on all obligations of Borrower under the Borrower Loan Documents (other than those to which the Default Rate applies) shall be equal to the Fixed Rate plus a number of basis points equal to the value of the exclusion of interest on the Funding Loan from Funding Lender’s gross taxable income. Borrower shall, in addition, pay to Lender, promptly upon demand, an amount equal to the difference between the amount of interest payable on this Note from the date on which such loss of tax exemption on the Funding Loan shall be applicable to the date on which the interest rate on this Note was increased and the amount of interest that would have been payable on this Note during such period had this Note borne interest during such period at such higher rate. The Borrower shall also indemnify, defend and hold Lender harmless from any penalties, interest expense or other costs, including attorneys’ fees (including all allocated time and charges of “in- house” and “outside” counsel) and accountants’ costs, resulting from any dispute with the A-3 Vista Breeze Internal Revenue Service concerning the proper tax treatment of the Funding Loan and the interest payable to Funding Lender on the Funding Loan. The obligations of the Borrower under this paragraph shall survive any termination of the Borrower Loan Documents, release of the Security Instrument and repayment of the Borrower Loan and/or Funding Loan. B-1 Vista Breeze SCHEDULE B PREPAYMENT PREMIUM Any prepayment premium payable under Section 10 of this Note shall be computed as follows: (a) If the prepayment is made at any time after the date of this Note and before the end of the Prepayment Premium Period (the “Yield Maintenance Period End Date”) the prepayment premium shall be the greater of: (i) 1% of the amount of principal being prepaid; or (ii) The product obtained by multiplying: (A) the amount of principal being prepaid, by (B) the difference obtained by subtracting the Yield Rate (as defined below) from the Interest Rate on this Note on the twenty-fifth Business Day preceding (x) the date upon which any voluntary prepayment will be made, determined in accordance with Section 10 of this Note, or (y) the date Lender accelerates the Borrower Loan or otherwise accepts a prepayment pursuant to Section 10 of this Note, by (C) the present value factor calculated using the following formula: 1 - (1 + r)-n/12 r r = Yield Rate n = the number of months remaining between (1) either of the following: (x) in the case of a voluntary prepayment, the last calendar day of the month during which the prepayment is made, or (y) in any other case, the date on which Lender accelerates the unpaid principal balance of this Note and (2) the Yield Maintenance Period End Date. For purposes of this clause (ii), the “Yield Rate” means the yield calculated by interpolating the yields for the immediately shorter and longer term U.S. “Treasury constant maturities” (as reported in the Federal Reserve Statistical Release H.15 Selected Interest Rates (the “Fed Release”) under the heading “U.S. government B-2 Vista Breeze securities”) closest to the remaining term of the Prepayment Premium Period, as follows (rounded to three decimal places): { ( (a – b) ÷ (x – y) ) × (z – y) } + b a = the yield for the longer U.S. Treasury constant maturity b = the yield for the shorter U.S. Treasury constant maturity x = the term of the longer U.S. Treasury constant maturity y = the term of the shorter U.S. Treasury constant maturity z = “n” (as defined in the present value factor calculation above) divided by 12. Notwithstanding any provision to the contrary, if “z” equals a term reported under the U.S. “Treasury constant maturities” subheading in the Fed Release, the yield for such term shall be used, and interpolation shall not be necessary. If publication of the Fed Release is discontinued by the Federal Reserve Board, Lender shall determine the Yield Rate from another source selected by Lender. Any determination of the Yield Rate by Lender will be binding absent manifest error. (b) Notwithstanding the provisions of Section 10 of this Note, no prepayment premium shall be payable with respect to any prepayment made on or after the Yield Maintenance Period End Date. C-1 Vista Breeze SCHEDULE C MODIFICATIONS TO AMENDED AND RESTATED MULTIFAMILY NOTE The following modifications are made to the text of the Note that precedes this Schedule: 1. The following new clause (8) is hereby added to Section 9(c) of this Note “or (8) any adverse material effect on Lender resulting from terms contained in the HAP Contract that (i) may have a material adverse effect on Lender’s projections of income from the HAP Contract and (ii) were not previously known due to Borrower’s failure to provide Lender with full, complete, and accurate copies of the HAP Contract, including all amendments, renewals, and assignments thereof.” 2. Section 9 is amended by adding the following sentence to the end of subsection (e) thereof: Borrower shall be personally liable to Lender for the payment of any payments made to Borrower under the HAP Contract to the extent such payments are not made to the Lender as provided for under that certain Housing Assistance Payments Contract (pertaining to the HAP Contract, as defined therein), dated as of [_], 20[_], by Borrower (as Owner) for the benefit of Funding Lender. 3. The following new clause (4) is hereby added to Section 9(e) of this Note “or (4) any failure by Borrower to comply with the provisions of Sections 61{Covenants to Protect Leasehold Estate}, 62(b) {Ground Lessee’s Bankruptcy section}, 63(a) {Ground Lessor’s Bankruptcy section} or 64 {Option to Renew or Extend Ground Lease section} of the Security Instrument.” Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Note. 4884-4417-5242v.4 D Forward Purchase Agreement Vista Breeze EXHIBIT D-4 TO FORWARD PURCHASE AGREEMENT FORM OF AMENDED AND RESTATED MULTIFAMILY LEASEHOLD MORTGAGE, ASSIGNMENT OF RENTS AND SECURITY AGREEMENT (FLORIDA) [See attached] i EXHIBIT D-4 TO FORWARD PURCHASE AGREEMENT FORM OF AMENDED AND RESTATED MULTIFAMILY LEASEHOLD MORTGAGE, ASSIGNMENT OF RENTS, SECURITY AGREEMENT AND FIXTURE FILING (FLORIDA) THIS INSTRUMENT PREPARED BY: Aviva Yakren, Esq. Sidley Austin LLP 787 Seventh Avenue New York, New York 10019 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: Citibank, N.A. Transaction and Asset Management Group/Post Closing Citi Community Capital 3800 Citibank Center Tampa, Florida 33610 Re: Vista Breeze Deal ID No. 60001596 ABOVE SPACE RESERVED FOR RECORDING PURPOSES ONLY AMENDED AND RESTATED MULTIFAMILY LEASEHOLD MORTGAGE, ASSIGNMENT OF RENTS, SECURITY AGREEMENT AND FIXTURE FILING (FLORIDA) THIS MORTGAGE IS EXECUTED AND DELIVERED IN CONNECTION WITH AND PURSUANT TO THE ISSUANCE OF A CERTAIN NOTE BY THE HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA AND IS EXEMPT FROM DOCUMENTARY STAMP TAXES AND INTANGIBLE TAX PURSUANT TO SECTION 159.621 FLORIDA STATUTES. ii Table of Contents 1. DEFINITIONS ................................................................................................................... 3 2. UNIFORM COMMERCIAL CODE SECURITY AGREEMENT ................................. 12 3. ASSIGNMENT OF RENTS; APPOINTMENT OF RECEIVER; LENDER IN POSSESSION .................................................................................................................. 13 4. ASSIGNMENT OF LEASES; LEASES AFFECTING THE MORTGAGED PROPERTY ..................................................................................................................... 15 5. PAYMENT OF INDEBTEDNESS; PERFORMANCE UNDER LOAN DOCUMENTS; PREPAYMENT PREMIUM ................................................................ 17 6. EXCULPATION.............................................................................................................. 18 7. DEPOSITS FOR TAXES, INSURANCE AND OTHER CHARGES ............................ 18 8. COLLATERAL AGREEMENTS ................................................................................... 19 9. APPLICATION OF PAYMENTS ................................................................................... 19 10. COMPLIANCE WITH LAWS ........................................................................................ 19 11. USE OF PROPERTY ...................................................................................................... 20 12. PROTECTION OF LENDER’S SECURITY; INSTRUMENT SECURES FUTURE ADVANCES ................................................................................................... 20 13. INSPECTION .................................................................................................................. 21 14. BOOKS AND RECORDS; FINANCIAL REPORTING ................................................ 22 15. TAXES; OPERATING EXPENSES ............................................................................... 24 16. LIENS; ENCUMBRANCES ........................................................................................... 25 17. PRESERVATION, MANAGEMENT AND MAINTENANCE OF MORTGAGED PROPERTY........................................................................................... 25 18. ENVIRONMENTAL HAZARDS ................................................................................... 26 19. PROPERTY AND LIABILITY INSURANCE ............................................................... 35 20. CONDEMNATION ......................................................................................................... 38 21. TRANSFERS OF THE MORTGAGED PROPERTY OR INTERESTS IN BORROWER ................................................................................................................... 40 22. EVENTS OF DEFAULT ................................................................................................. 45 23. REMEDIES CUMULATIVE .......................................................................................... 48 24. FORBEARANCE ............................................................................................................ 48 25. WAIVER OF STATUTE OF LIMITATIONS ................................................................ 48 26. WAIVER OF MARSHALLING ..................................................................................... 48 27. FURTHER ASSURANCES ............................................................................................ 49 iii 28. ESTOPPEL CERTIFICATE ............................................................................................ 49 29. GOVERNING LAW; CONSENT TO JURISDICTION AND VENUE ........................ 49 30. NOTICE ........................................................................................................................... 50 31. CHANGE IN SERVICER ............................................................................................... 51 32. SINGLE ASSET BORROWER ...................................................................................... 51 33. SUCCESSORS AND ASSIGNS BOUND ...................................................................... 52 34. JOINT AND SEVERAL LIABILITY ............................................................................. 52 35. RELATIONSHIP OF PARTIES; NO THIRD PARTY BENEFICIARY ....................... 52 36. SEVERABILITY; AMENDMENTS............................................................................... 52 37. CONSTRUCTION ........................................................................................................... 52 38. SERVICER ...................................................................................................................... 53 39. DISCLOSURE OF INFORMATION .............................................................................. 53 40. NO CHANGE IN FACTS OR CIRCUMSTANCES ...................................................... 54 41. SUBROGATION ............................................................................................................. 54 42. FINANCING STATEMENT ........................................................................................... 54 43. STATE SPECIFIC PROVISIONS (FLORIDA) ............................................................. 54 44. WAIVER OF TRIAL BY JURY ..................................................................................... 55 45. ATTACHED EXHIBITS ................................................................................................. 55 EXHIBITS EXHIBIT A Description of the Land EXHIBIT B Modifications to Instrument EXHIBIT C Financing Statement Information EXHIBIT D Modifications to Instrument (Ground Lease) EXHIBIT E Description of Ground Lease Amended and Restated Mortgage 1 Vista Breeze AMENDED AND RESTATED MULTIFAMILY LEASEHOLD MORTGAGE, ASSIGNMENT OF RENTS, SECURITY AGREEMENT AND FIXTURE FILING (FLORIDA) This AMENDED AND RESTATED MULTIFAMILY LEASEHOLD MORTGAGE, ASSIGNMENT OF RENTS, SECURITY AGREEMENT AND FIXTURE FILING (FLORIDA) (this “Instrument”) is dated for reference purposes only as of the [__] day of [Month], 202[__], by VISTA BREEZE, LTD., a Florida limited partnership, whose address is c/o Atlantic Pacific Communities, 161 NW 6th Street, Suite 1020, Miami, Florida 33136, as grantor (“Borrower”), to HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, a public body corporate and politic organized and existing under the laws of the State of Florida, whose address is 7855 NW 12th Street, Suite 202, Doral, Florida 33126, as beneficiary, and its successors and assigns (“Lender” or “Governmental Lender”). Borrower’s organizational identification number is A20000000470. The Borrower previously applied to the Governmental Lender for a loan (the “Borrower Loan”) for the acquisition, construction, rehabilitation, development and/or equipping of the Mortgaged Property (as hereinafter defined). The Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023 (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note dated as of December 15, 2023 (the “Original Borrower Note”) made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Borrower for the benefit of Governmental Lender, and recorded in the Official Records of Miami-Dade County on [_], 2023, as Instrument No. [_] (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property and was assigned to the Fiscal Agent for the benefit of the Original Funding Lender pursuant to that certain Assignment of Mortgage and Collateral Loan Documents, dated as of December 15, 2023 and recorded in the Official Records of Miami-Dade County on December [_], 2023 as Instrument No. [_]. At the request of Borrower, the Borrower, Original Funding Lender and Citibank, N.A., a national banking association (“Funding Lender”) entered into that certain Forward Purchase Amended and Restated Mortgage 2 Vista Breeze Agreement, dated as of December 1, 2023, pursuant to which the Funding Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). Insofar as the Loan Purchase Conditions have been satisfied or waived, Funding Lender has acquired the Funding Loan from the Original Funding Lender, and in connection therewith, (i) Funding Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement, dated as of the date hereof (the “Funding Loan Agreement”), by and among Governmental Lender, Fiscal Agent and the Funding Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement, dated as of the date hereof (the “Borrower Loan Agreement”), which amends and restates the Original Borrower Loan Agreement; and (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [Month] [Day], 20[_], in the principal amount of [ELEVEN MILLION EIGHT HUNDRED SEVENTY FIVE THOUSAND AND 00/100 DOLLARS ($11,875,000)][NOTE: AS MAY BE INCREASED PER THE EARN-OUT], which amends and restates the Borrower Note (the “Note”), and which matures on the earlier to occur of July 1, 2057, or any earlier date on which the unpaid principal balance of the Note becomes due and payable, by acceleration or otherwise (the “Maturity Date”). The terms, covenants, agreements, rights, obligations and conditions contained in this Instrument supersede and control the terms, covenants, agreements, rights, obligations and conditions contained in the Original Security Instrument, it being agreed that the amendment and restatement of the Original Security Instrument hereby shall neither impair the Indebtedness secured by the Original Security Instrument nor constitute a novation of the Indebtedness. NOW THEREFORE: Granting Clause. Borrower, in consideration of the Indebtedness and the trust created by this Instrument, irrevocably grants, conveys and assigns to Lender, in trust, with power of sale, the Mortgaged Property, including the Land located in the City of Miami Beach, Miami- Dade County, Florida, and described in Exhibit A attached to this Instrument, to have and to hold the Mortgaged Property unto Lender, Lender’s successor in trust and Lender’s assigns forever. TO SECURE TO LENDER and its successors and assigns the repayment of the Indebtedness evidenced by the Note executed by Borrower and maturing on the Maturity Date, and all renewals, extensions and modifications of the Indebtedness, including, without limitation, the payment of all sums advanced by or on behalf of Lender to protect the security of this Instrument under Section 12 and the performance of the covenants and agreements of Borrower contained in the Loan Documents. Borrower represents and warrants that Borrower is lawfully seized of the Mortgaged Property and has the right, power and authority to grant, convey and assign the Mortgaged Property, and that the Mortgaged Property is unencumbered except for the Permitted Encumbrances. Borrower covenants that Borrower will warrant and defend generally the title to the Mortgaged Property against all claims and demands, subject to any Permitted Encumbrances. Amended and Restated Mortgage 3 Vista Breeze This Instrument is also a financing statement and a fixture filing under the Uniform Commercial Code of the Property Jurisdiction and the information set forth on Exhibit C is included for that purpose. Covenants. Borrower and Lender covenant and agree as follows: 1. DEFINITIONS. The following terms, when used in this Instrument (including when used in the above recitals), shall have the following meanings: (a) “Affiliate” means, as to any Person, any other Person that, directly or indirectly, is in Control of, is Controlled by or is under common Control with such Person. (b) “Agreement of Environmental Indemnification” means that certain Agreement of Environmental Indemnification, dated as of the date hereof, by Borrower and Guarantor for the benefit of Beneficiary Parties. (c) “Bankruptcy Event” means any one or more of the following: (i) (A) the commencement of a voluntary case under one or more of the Insolvency Laws by the Borrower; (B) the acknowledgment in writing by the Borrower that it is unable to pay its debts generally as they mature; (C) the making of a general assignment for the benefit of creditors by the Borrower; (D) the commencement of an involuntary case under one or more Insolvency Laws against the Borrower; or (E) the appointment of a receiver, liquidator, custodian, sequestrator, trustee or other similar officer who exercises control over the Borrower or any substantial part of the assets of the Borrower provided that any proceeding or case under (D) or (E) above is not dismissed within 90 days after filing; (ii) Any Guarantor or any Affiliate of a Guarantor files an involuntary petition against Borrower under one or more of the Insolvency Laws; or (iii) Both (A) an involuntary petition under any one or more of the Insolvency Laws is filed against Borrower or Borrower directly or indirectly becomes the subject of any bankruptcy, insolvency, reorganization, arrangement, readjustment of debt, dissolution, liquidation or similar proceeding relating to it under the laws of any jurisdiction, or in equity, and (B) Borrower or any Affiliate of Borrower has acted in concert or conspired with such creditors of Borrower (other than Lender) to cause the filing thereof with the intent to interfere with enforcement rights of Lender after the occurrence of an Event of Default. Amended and Restated Mortgage 4 Vista Breeze (d) “Beneficiary Parties” means Lender, Governmental Lender, Funding Lender, Fiscal Agent, any Servicer and their respective successors and assigns, together with any lawful owner, holder or pledgee of the Note. (e) “Borrower” means all persons or entities identified as “Borrower” in the first paragraph of this Instrument, together with their successors and assigns. (f) “Borrower’s Agreement of Limited Partnership” means that certain Amended and Restated Agreement of Limited Partnership, dated as of December 15, 2023, as the same may be amended and/or restated from time to time. (g) “Borrower’s Organizational Documents” means, collectively: (i) the certificate of limited partnership of Borrower filed with the Office of the Secretary of State of Florida on October 21, 2020; and (ii) Borrower’s Agreement of Limited Partnership. (h) “Business Day” means any day other than (i) a Saturday or a Sunday, or (ii) a day on which federally insured depository institutions in New York, New York are authorized or obligated by law, regulation, governmental decree or executive order to be closed. (i) “Closing Date” means [_____], 202[_]. (j) “Collateral Agreement” means any separate agreement between Borrower and Funding Lender and/or Lender or Servicer for the purpose of establishing tax, repair or replacement reserve or escrow accounts for the Mortgaged Property or granting Lender a security interest in any such accounts (including, without limitation, the Replacement Reserve Agreement), or any other agreement or agreements between Borrower, Funding Lender and/or Lender or Servicer which provide for the establishment of any other fund, reserve or account. (k) “Collateral Assignment” means the (i) Assignment of Management Agreement, dated as of the date hereof, by Borrower and the Manager (as defined therein) to Funding Lender, and (ii) Assignment of HAP Contract, dated as of the date hereof. (l) “Control” means, with respect to any Person, either (i) ownership directly or through other entities of more than 50% of all beneficial equity interest in such Person, or (ii) the possession, directly or indirectly, of the power to direct or cause the direction of the management or policies of such Person, through the ownership of voting securities, by contract or otherwise, including the power to elect a majority of the directors of a corporation, to select the managing partner of a partnership, or otherwise to have the power independently to remove and then select a majority of those individuals exercising managerial authority over an entity. (m) “Credit Enhancer” means a government sponsored enterprise that at any time, directly or indirectly, purchases the Loan or provides credit enhancement with respect to the Loan. Amended and Restated Mortgage 5 Vista Breeze (n) “Credit Enhancer Insurance Standards” means the insurance standards and requirements set forth in the multifamily underwriting guidelines generated by the Credit Enhancer, as in effect from time to time. (o) “Environmental Permit” means any permit, license, or other authorization issued under any Hazardous Materials Law with respect to any activities or businesses conducted on or in relation to the Mortgaged Property. (p) “Event of Default” means the occurrence of any event listed in Section 22. (q) “Fiscal Agent” has the meaning ascribed in the Recitals hereof. (r) “Fixtures” means all property which is so attached to the Land or the Improvements as to constitute a fixture under applicable law, including: machinery, equipment, engines, boilers, incinerators, installed building materials; systems and equipment for the purpose of supplying or distributing heating, cooling, electricity, gas, water, air, or light; antennas, cable, wiring and conduits used in connection with radio, television, security, fire prevention, or fire detection or otherwise used to carry electronic signals; telephone systems and equipment; elevators and related machinery and equipment; fire detection, prevention and extinguishing systems and apparatus; security and access control systems and apparatus; plumbing systems; water heaters, ranges, stoves, microwave ovens, refrigerators, dishwashers, garbage disposers, washers, dryers and other appliances; light fixtures, awnings, storm windows and storm doors; pictures, screens, blinds, shades, curtains and curtain rods; mirrors; cabinets, paneling, rugs and floor and wall coverings; fences, trees and plants; swimming pools; and exercise equipment. (s) “Funding Lender” has the meaning ascribed in the Recitals hereof. (t) “Governmental Authority” means any board, commission, department or body of any municipal, county, state or federal governmental unit, or any subdivision of any of them, that has or acquires jurisdiction over the Mortgaged Property or the use, operation or improvement of the Mortgaged Property. (u) “Guarantor” means (i) Howard D. Cohen Revocable Trust U/A/D/ 4/6/1993, and/or (ii) any other person or entity which may hereafter become a guarantor, and the successors and assigns of Guarantor. (v) “Hazardous Materials” means petroleum and petroleum products and compounds containing them, including gasoline, diesel fuel and oil; explosives; flammable materials; radioactive materials; polychlorinated biphenyls (“PCBs”) and compounds containing them; lead and lead-based paint; asbestos or asbestos-containing materials in any form that is or could become friable; underground or above-ground storage tanks, whether empty or containing any substance; radon; Mold; toxic or mycotoxin spores; any substance the presence of which on the Mortgaged Property is prohibited by any federal, state or local authority; any substance that requires special handling; and any other material or substance (whether or not naturally occurring) now or Amended and Restated Mortgage 6 Vista Breeze in the future that (i) is defined as a “hazardous substance,” “hazardous material,” “hazardous waste,” “toxic substance,” “toxic pollutant,” “solid waste”, “pesticide”, “contaminant,” or “pollutant”, or otherwise classified as hazardous or toxic by or within the meaning of any Hazardous Materials Law, or (ii) is regulated in any way by or within the meaning of any Hazardous Materials Law. (w) “Hazardous Materials Laws” means all federal, state, and local laws, ordinances and regulations and standards, rules, policies and other governmental requirements, rule of common law (including, without limitation, nuisance and trespass), consent order, administrative rulings and court judgments and decrees or other government directive in effect now or in the future and including all amendments, that relate to Hazardous Materials or to the protection or conservation of the environment or human health and apply to Borrower or to the Mortgaged Property, including, without limitation, those relating to industrial hygiene, or the use, analysis, generation, manufacture, storage, discharge, release, disposal, transportation, treatment, investigation, or remediation of Hazardous Materials. Hazardous Materials Laws include, but are not limited to, the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. Section 9601, et seq., the Resource Conservation and Recovery Act, 42 U.S.C. Section 6901, et seq., the Toxic Substances Control Act, 15 U.S.C. Section 2601, et seq., the Clean Water Act, 33 U.S.C. Section 1251, et seq., the Hazardous Materials Transportation Act, 49 U.S.C. Section 5101, et seq., the Superfund Amendments and Reauthorization Act, the Solid Waste Disposal Act, the Clean Air Act, the Occupational Safety and Health Act, and their state analogs. (x) “Impositions” and “Imposition Deposits” shall have the meanings ascribed thereto in Section 7(a). (y) “Improvements” means the buildings, structures, improvements, and alterations now constructed or at any time in the future constructed or placed upon the Land, including any future replacements and additions. (z) “Indebtedness” means collectively, the principal of, interest on, and all other amounts due at any time under, the Note, this Instrument or any other Loan Document, including prepayment premiums, late charges, default interest, and advances as provided in Section 12 to protect the security of this Instrument, and any fees or expenses paid by Lender on behalf of Borrower to Lender, or any other party for the Loan or other amounts relating to the Loan Documents which are paid by Lender; (aa) “Initial Owners” means, with respect to Borrower or any other entity, the persons or entities who on the date of the Note, directly or indirectly, own in the aggregate 100% of the ownership interests in Borrower or that entity. (bb) “Insolvency Laws” means the United States Bankruptcy Code, 11 U.S.C. § 101, et seq., together with any other federal or state law affecting debtor and creditor rights or relating to the bankruptcy, insolvency, reorganization, arrangement, Amended and Restated Mortgage 7 Vista Breeze readjustment of debt, dissolution, liquidation or similar proceeding, as amended from time to time, to the extent applicable to the Borrower. (cc) “Land” means the land described in Exhibit A. (dd) “Leases” means all present and future leases, subleases, licenses, concessions or grants or other possessory interests now or hereafter in force, whether oral or written, covering or affecting the Mortgaged Property, or any portion of the Mortgaged Property (including proprietary leases or occupancy agreements if Borrower is a cooperative housing corporation), and all modifications, extensions or renewals. (ee) “Lender” means the entity identified as “Lender” in the first paragraph of this Instrument, or any subsequent holder of the Note. (ff) “Loan” means the loan made by Lender to Borrower in an amount not to exceed the original principal amount of the Note, which loan is evidenced by the Note and secured by, among other things, this Instrument. (gg) “Loan Agreement” means that certain Amended and Restated Borrower Loan Agreement, dated as of the date hereof, by and between Governmental Lender and Borrower, relating, to the Loan, as the same may be amended, modified or supplemented from time to time. (hh) “Loan Covenant Agreement” means that certain Loan Covenant Agreement, dated as of the date hereof, between the Funding Lender and Borrower, as such agreement may be amended, modified, supplemented and replaced from time to time. (ii) “Loan Documents” means collectively, the Loan Agreement, the Note, this Instrument, the Loan Covenant Agreement, the Agreement of Environmental Indemnification, all guaranties, all indemnity agreements, all Collateral Agreements, the Collateral Assignment, the Replacement Reserve Agreement, all O&M Programs, the MMP, and any other documents now or in the future executed by Borrower, any guarantor or any other person in connection with the Loan, as such documents may be amended from time to time. (jj) “Material Property Agreements” means any agreement which, in Lender’s sole discretion, acting in good faith, materially affects the Mortgaged Property, the use thereof or otherwise materially affects the rights of Borrower or Beneficiary Parties in, to, and with respect to the Mortgaged Property or the proceeds therefrom, including, without limitation, each of the following: (i) any agreement regarding the payment in lieu of taxes (“PILOT”), (ii) all covenants, conditions and restrictions, including, without limitation, any declaration subjecting the Mortgaged Property to an association of owners or other community governance, (iii) any agreement regarding the abatement or exemption of real estate taxes, (iv) any easement pursuant to which the Mortgaged Property is granted access to a public right of way, (v) any material lease of all or any portion of the Mortgaged Property, (vi) any operating agreements relating to the Land or the Improvements and (vii) any regulatory agreements, declarations, land use Amended and Restated Mortgage 8 Vista Breeze restriction agreements or similar instruments affecting the Mortgaged Property including the operation or use thereof. (kk) “Maturity Date” has the meaning ascribed thereto in the recitals to this Instrument. (ll) “MMP” means an operations and maintenance plan, moisture management program and/or microbial operations and maintenance program approved by Lender to control water intrusion and prevent the development of Mold or moisture at the Mortgaged Property throughout the term of this Instrument. If required by Lender, the MMP shall contain a provision for (i) staff training, (ii) information to be provided to tenants, (iii) documentation of the plan, (iv) the appropriate protocol for incident response and remediation and (v) routine, scheduled inspections of common space and unit interiors. (mm) “Mold” means mold, fungus, microbial contamination or pathogenic organisms. (nn) “Mortgaged Property” means all of Borrower’s present and future right, title and interest in and to all of the following: (i) the Land; (ii) the Improvements; (iii) the Fixtures; (iv) the Personalty; (v) all current and future rights, including air rights, development rights, zoning rights and other similar rights or interests, easements, tenements, rights-of-way, strips and gores of land, streets, alleys, roads, sewer rights, waters, watercourses, and appurtenances related to or benefiting the Land or the Improvements, or both, and all rights-of-way, streets, alleys and roads which may have been or may in the future be vacated; (vi) all proceeds paid or to be paid by any insurer of the Land, the Improvements, the Fixtures, the Personalty or any other part of the Mortgaged Property, whether or not Borrower obtained the insurance pursuant to Lender’s requirements; (vii) all awards, payments and other compensation made or to be made by any municipal, state or federal authority with respect to the Land, the Improvements, the Fixtures, the Personalty or any other part of the Mortgaged Property, including any awards or settlements resulting from condemnation proceedings or the total or partial taking of the Land, the Improvements, the Fixtures, the Amended and Restated Mortgage 9 Vista Breeze Personalty or any other part of the Mortgaged Property under the power of eminent domain or otherwise and including any conveyance in lieu thereof; (viii) all contracts, options and other agreements for the sale of the Land, the Improvements, the Fixtures, the Personalty or any other part of the Mortgaged Property entered into by Borrower now or in the future, including cash or securities deposited to secure performance by parties of their obligations; (ix) all Rents and Leases; (x) all earnings, royalties, accounts receivable, issues and profits from the Land, the Improvements or any other part of the Mortgaged Property, whether the foregoing are now due, past due, or to become due, all undisbursed proceeds of the loan secured by this Instrument, deposits forfeited by tenants, and, if Borrower is a cooperative housing corporation, maintenance charges or assessments payable by shareholders or residents; (xi) all refunds or rebates of Impositions by any municipal, state or federal authority or insurance company (other than refunds applicable to periods before the real property tax year in which this Instrument is dated); (xii) all tenant security deposits which have not been forfeited by any tenant under any Lease and any bond or other security in lieu of such deposits; (xiii) all names under or by which any of the above Mortgaged Property may be operated or known, and all trademarks, trade names, and goodwill relating to any of the Mortgaged Property; (xiv) all documents, writings, books, files, records and other documents arising from or relating to any of the foregoing, whether now existing or hereafter created; and (xv) all proceeds from the conversion, voluntary or involuntary, of any of the above into cash or liquidated claims, and the right to collect such proceeds, and all other cash and non-cash proceeds and products of any of the foregoing. (oo) “Note” means that certain Amended and Restated Multifamily Note, dated as of the Closing Date, executed and delivered by the Borrower, payable to Lender in an amount not to exceed the maximum principal amount of the Loan set forth in the recitals to this Instrument, including all schedules, riders, allonges and addenda, as the same may be amended, modified, or supplemented from time to time. Amended and Restated Mortgage 10 Vista Breeze (pp) “O&M Program” has the meaning ascribed thereto in Section 18(d). (qq) “Permitted Encumbrances” means any easements, encumbrances or restrictions listed on the schedule of exceptions in the title insurance policy issued to Lender as of the date of recordation of this Instrument insuring Lender’s interest in the Mortgaged Property, any extended low-income housing commitment (as such term is defined in Section 42(h)(6)(B) of the Internal Revenue Code), the Regulatory Agreement (defined herein) and the liens securing the Subordinate Loans (defined herein), and such other title and survey exceptions as Lender has approved or may approve in writing in Lender’s sole and absolute discretion. (rr) “Permitted Transfer” has the meaning ascribed thereto in Section 21(b). (ss) “Person” means any individual, corporation, limited liability company, partnership, joint venture, estate, trust, unincorporated association, any federal, state, county or municipal government or any bureau, department or agency thereof and any fiduciary acting in such capacity on behalf of any of the foregoing. (tt) “Personalty” means all of Borrower’s right, title, and interest in and to all: (i) accounts (including deposit accounts) of Borrower related to the Mortgaged Property; (ii) Imposition Deposits; (iii) equipment, goods, supplies and inventory owned by Borrower that are used now or in the future in connection with the ownership, management or operation of the Land or the Improvements or are located on the Land or in the Improvements (other than Fixtures), including furniture, furnishings, machinery, building materials, tools, books, records (whether in written or electronic form), computer equipment (hardware and software); (iv) other tangible personal property owned by Borrower which are used now or in the future in connection with the ownership, management or operation of the Land or Improvements or are located on the Land or in the Improvements (other than Fixtures), including ranges, stoves, microwave ovens, refrigerators, dishwashers, garbage disposers, washers, dryers and other appliances; (v) any operating agreements relating to the Land or the Improvements; (vi) any surveys, plans and specifications and contracts for architectural, engineering and construction services relating to the Land or the Improvements; Amended and Restated Mortgage 11 Vista Breeze (vii) documents, instruments, chattel paper, claims, deposits, deposit accounts, payment intangibles, other intangible property, general intangibles, and rights relating to the operation of, or used in connection with, the Land or the Improvements, including all governmental permits relating to any activities on the Land and including subsidy or similar payments received from any sources, including a Governmental Authority; and (viii) any rights of Borrower in or under letters of credit. (uu) “Project” means the 119-unit multifamily residential project known or to be known as Vista Breeze, and located in the City of Miami Beach, Miami-Dade County, State of Florida. (vv) “Property Jurisdiction” means the State of Florida. (ww) “Regulatory Agreement” means the Land Use Restriction Agreement, dated as of December 1, 2023, by and among Governmental Lender, Fiscal Agent and the Borrower, regulating or restricting the use or manner of operation of the Mortgaged Property and containing requirements that specified percentages of the dwelling units in the Mortgaged Property be occupied by tenants whose incomes are below specified levels. (xx) “Rents” means all rents (whether from residential or non-residential space), revenues and other income of the Land or the Improvements, including subsidy payments received from any sources (including, but not limited to payments under any Housing Assistance Payments Contract or similar agreements), parking fees, laundry and vending machine income and fees and charges for food, health care and other services provided at the Mortgaged Property, whether now due, past due, or to become due, and deposits forfeited by tenants. (yy) “Replacement Reserve Agreement” means that certain Replacement Reserve Agreement, dated as of the date hereof, by and between Borrower and Funding Lender. (zz) “Replacement Reserve Fund” has the meaning ascribed thereto by the Replacement Reserve Agreement. (aaa) “Servicer” means the servicing party that is designated by Lender to service the Loan, together with its successors in such capacity. (bbb) “Subordinate Loans” has the meaning ascribed to that term in the Borrower Loan Agreement. (ccc) “Taxes” means, collectively, all taxes, assessments, vault rentals and other charges, if any, general, special or otherwise, including all assessments for schools, public betterments and general or local improvements, which are levied, assessed or Amended and Restated Mortgage 12 Vista Breeze imposed by any public authority or quasi-public authority, and which, if not paid, will become a lien, on the Land or the Improvements. (ddd) “Transfer” means (i) a sale, assignment, transfer, or other disposition (whether voluntary, involuntary or by operation of law); (ii) the grant, creation, or attachment of a lien, encumbrance, or security interest (whether voluntary, involuntary or by operation of law); (iii) the issuance or other creation of a direct or indirect ownership interest; or (iv) the withdrawal, retirement, removal or involuntary resignation of any owner or manager of a legal entity. (eee) “Uniform Commercial Code” means the Florida Uniform Commercial Code. (fff) “United States Bankruptcy Code” means the United States Bankruptcy Code, 11 U.S.C. Section 101 et seq., as amended from time to time. 2. UNIFORM COMMERCIAL CODE SECURITY AGREEMENT. (a) This Instrument is also a security agreement under the Uniform Commercial Code for any of the Mortgaged Property which, under applicable law, may be subjected to a security interest under the Uniform Commercial Code, whether such Mortgaged Property is owned now or acquired in the future, and all products and cash and non-cash proceeds thereof (collectively, “UCC Collateral”), and Borrower hereby grants to Lender a security interest in the UCC Collateral. Borrower hereby authorizes Lender to prepare and file any and all financing statements, continuation statements and financing statement amendments, in such form as Lender may require to perfect or continue the perfection of this security interest without execution by Borrower. Borrower shall pay all filing costs and all costs and expenses of any record searches for financing statements and/or amendments that Lender may require. Without the prior written consent of Lender, Borrower shall not create or permit to exist any other lien or security interest in any of the UCC Collateral except for the Permitted Encumbrances. If an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Lender shall have the remedies of a secured party under the Uniform Commercial Code, in addition to all remedies provided by this Instrument or existing under applicable law. In exercising any remedies, Lender may exercise its remedies against the UCC Collateral separately or together, and in any order, without in any way affecting the availability of Lender’s other remedies. This Instrument constitutes a financing statement with respect to any part of the Mortgaged Property which is or may become a Fixture. (b) Unless Borrower gives at least thirty (30) days’ prior written notice to Lender and subject to Section 21 hereof, Borrower shall not: (i) change its name, identity, or structure of organization; (ii) change its state of organization through dissolution, merger, transfer of assets or otherwise; (iii) change its principal place of business (or chief executive office if more than one place of business); or (iv) add to or change any location at which any of the Mortgaged Property is stored, held or located. Such notice shall be accompanied by new financing statements and/or financing Amended and Restated Mortgage 13 Vista Breeze statement amendments in the same form as the financing statements delivered to Lender on the date hereof. Without limiting the foregoing, upon the occurrence and during the continuance of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Borrower hereby authorizes and irrevocably appoints Lender and each of its officers attorneys-in-fact for Borrower to execute, deliver, and file, as applicable, such financing statements, continuation statements or amendments deemed necessary by Lender in its sole discretion for and on behalf of Borrower, without execution by Borrower. Borrower shall also execute and deliver to Lender modifications or supplements of this Instrument as Lender may require in connection with any change described in this Section. 3. ASSIGNMENT OF RENTS; APPOINTMENT OF RECEIVER; LENDER IN POSSESSION. (a) As part of the consideration for the Indebtedness, Borrower absolutely and unconditionally assigns and transfers to Lender all Rents. It is the intention of Borrower to establish a present, absolute and irrevocable transfer and assignment to Lender of all Rents and to authorize and empower Lender to collect and receive all Rents without the necessity of further action on the part of Borrower. Promptly upon request by Lender, Borrower agrees to execute and deliver such further assignments of Rents as Lender may from time to time require. Borrower and Lender intend this assignment of Rents to be immediately effective and to constitute an absolute present assignment and not an assignment for additional security only. For purposes of giving effect to this absolute assignment of Rents, and for no other purpose, Rents shall not be deemed to be a part of the Mortgaged Property. However, if this present, absolute and unconditional assignment of Rents is not enforceable by its terms under the laws of the Property Jurisdiction, then the Rents shall be included as a part of the Mortgaged Property and it is the intention of Borrower that in this circumstance this Instrument create and perfect a lien on Rents in favor of Lender, which lien shall be effective as of the date of this Instrument. (b) Borrower authorizes Lender to collect, sue for and compromise Rents and directs each tenant of the Mortgaged Property to pay all Rents to, or as directed by, Lender. However, until the occurrence of an Event of Default, Lender hereby grants to Borrower a revocable license to collect and receive all Rents, to hold all Rents in trust for the benefit of Lender and to apply all Rents to pay the installments of interest and principal then due and payable under the Note and the other amounts then due and payable under the other Loan Documents, including Imposition Deposits, and to pay the current costs and expenses of managing, operating and maintaining the Mortgaged Property, including utilities, Taxes and insurance premiums (to the extent not included in Imposition Deposits), tenant improvements and other capital expenditures. So long as no Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), the Rents remaining after application pursuant to the preceding sentence may be retained by Borrower free and clear of, and released from, Lender’s rights with respect to Rents under this Instrument. During the continuation of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), and without the necessity of Lender entering upon Amended and Restated Mortgage 14 Vista Breeze and taking and maintaining control of the Mortgaged Property directly, or by a receiver, Borrower’s license to collect Rents shall automatically terminate and Lender shall without notice be entitled to all Rents as they become due and payable, including Rents then due and unpaid (such license shall be reinstated upon Borrower’s cure of the Event of Default to the satisfaction of Lender). Borrower shall pay to Lender upon demand all Rents to which Lender is entitled. At any time during the continuation of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Lender may give, and Borrower hereby irrevocably authorizes Lender to give, notice to all tenants of the Mortgaged Property instructing them to pay all Rents to Lender, no tenant shall be obligated to inquire further as to the right of Lender to collect Rents, and no tenant shall be obligated to pay to Borrower any amounts which are actually paid to Lender in response to such a notice. Any such notice by Lender shall be delivered to each tenant personally, by mail or by delivering such demand to each rental unit. Borrower shall not interfere with and shall cooperate with Lender’s collection of such Rents. (c) Borrower represents and warrants to Lender that Borrower has not executed any prior assignment of Rents (other than an assignment of Rents securing indebtedness that will be paid off and discharged with the proceeds of the Loan or in connection with the Subordinate Loans), that Borrower has not performed, and Borrower covenants and agrees that it will not perform, any acts and has not executed, and shall not execute, any instrument which would prevent Lender from exercising its rights under this Section 3, and that at the time of execution of this Instrument there has been no anticipation or prepayment of any Rents for more than two months prior to the due dates of such Rents (other than a security deposit not in excess of one month’s rent). Borrower shall not collect or accept payment of any Rents more than two months prior to the due dates of such Rents (other than a security deposit not in excess of one month’s rent). (d) If an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Lender may, but shall in no event be required to, regardless of the adequacy of Lender’s security or the solvency of Borrower and even in the absence of waste, enter upon and take and maintain full control of the Mortgaged Property in order to perform all acts that Lender in its discretion determines to be necessary or desirable for the operation and maintenance of the Mortgaged Property, including the execution, cancellation or modification of Leases, the collection of all Rents, the making of repairs to the Mortgaged Property and the execution or termination of contracts providing for the management, operation or maintenance of the Mortgaged Property, for the purposes of enforcing the assignment of Rents pursuant to Section 3(a), protecting the Mortgaged Property or the security of this Instrument, or for such other purposes as Lender in its discretion may deem necessary or desirable. Alternatively, if an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), regardless of the adequacy of Lender’s security, without regard to Borrower’s solvency and without the necessity of giving prior notice (oral or written) to Borrower, Lender may apply to any court having jurisdiction for the appointment of a receiver for the Mortgaged Property to take any or all of the actions set forth in the preceding Amended and Restated Mortgage 15 Vista Breeze sentence. If Lender elects to seek the appointment of a receiver for the Mortgaged Property at any time after an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Borrower, by its execution of this Instrument, expressly consents to the appointment of such receiver, including the appointment of a receiver ex parte if permitted by applicable law. Lender or the receiver, as the case may be, shall be entitled to receive a reasonable fee for managing the Mortgaged Property. Immediately upon appointment of a receiver or immediately upon Lender’s entering upon and taking possession and control of the Mortgaged Property, Borrower shall surrender possession of the Mortgaged Property to Lender or the receiver, as the case may be, and shall deliver to Lender or the receiver, as the case may be, all documents, records (including records on electronic or magnetic media), accounts, surveys, plans, and specifications relating to the Mortgaged Property and all security deposits and prepaid Rents. In the event Lender takes possession and control of the Mortgaged Property, Lender may exclude Borrower and its representatives from the Mortgaged Property. Borrower acknowledges and agrees that the exercise by Lender of any of the rights conferred under this Section 3 shall not be construed to make Lender a mortgagee-in- possession of the Mortgaged Property so long as Lender has not itself entered into actual possession of the Land and Improvements. (e) If Lender enters the Mortgaged Property, Lender shall be liable to account only to Borrower and only for those Rents actually received. Lender shall not be liable to Borrower, anyone claiming under or through Borrower or anyone having an interest in the Mortgaged Property, by reason of any act or omission of Lender under this Section 3, and Borrower hereby releases and discharges Lender from any such liability to the fullest extent permitted by law, except for the gross negligence or willful misconduct of Lender or its agents. (f) If the Rents are not sufficient to meet the costs of taking control of and managing the Mortgaged Property and collecting the Rents, any funds expended by Lender for such purposes shall become an additional part of the Indebtedness as provided in Section 12. (g) Any entering upon and taking of control of the Mortgaged Property by Lender or the receiver, as the case may be, and any application of Rents as provided in this Instrument shall not cure or waive any Event of Default or invalidate any other right or remedy of Lender under applicable law or provided for in this Instrument. 4. ASSIGNMENT OF LEASES; LEASES AFFECTING THE MORTGAGED PROPERTY. (a) As part of the consideration for the Indebtedness, Borrower absolutely and unconditionally assigns and transfers to Lender all of Borrower’s right, title and interest in, to and under the Leases, including Borrower’s right, power and authority to modify the terms of any such Lease, or extend or terminate any such Lease. It is the intention of Borrower to establish a present, absolute and irrevocable transfer and assignment to Lender of all of Borrower’s right, title and interest in, to and under the Leases. Borrower Amended and Restated Mortgage 16 Vista Breeze and Lender intend this assignment of the Leases to be immediately effective and to constitute an absolute present assignment and not an assignment for additional security only. For purposes of giving effect to this absolute assignment of the Leases, and for no other purpose, the Leases shall not be deemed to be a part of the “Mortgaged Property” as that term is defined in Section 1. However, if this present, absolute and unconditional assignment of the Leases is not enforceable by its terms under the laws of the Property Jurisdiction, then the Leases shall be included as a part of the Mortgaged Property and it is the intention of Borrower that in this circumstance this Instrument create and perfect a lien on the Leases in favor of Lender, which lien shall be effective as of the date of this Instrument. (b) Unless an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Borrower shall have all rights, power and authority granted to Borrower under any Lease (except as otherwise limited by this Section or any other provision of this Instrument), including the right, power and authority to modify the terms of any Lease or extend or terminate any Lease. During the continuance of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), the permission given to Borrower pursuant to the preceding sentence to exercise all rights, power and authority under Leases shall automatically terminate. Borrower shall comply with and observe Borrower’s obligations under all Leases, including Borrower’s obligations pertaining to the maintenance and disposition of tenant security deposits. (c) Borrower acknowledges and agrees that the exercise by Lender, either directly or by a receiver, of any of the rights conferred under this Section 4 shall not be construed to make Lender a mortgagee-in-possession of the Mortgaged Property so long as Lender has not itself entered into actual possession of the Land and the Improvements. The acceptance by Lender of the assignment of the Leases pursuant to Section 4(a) shall not at any time or in any event obligate Lender to take any action under this Instrument or to expend any money or to incur any expenses. Lender shall not be liable in any way for any injury or damage to person or property sustained by any person or persons, firm or corporation in or about the Mortgaged Property, except to the extent arising from the gross negligence or willful misconduct of Lender. Prior to Lender’s actual entry into and taking possession of the Mortgaged Property, Lender shall not (i) be obligated to perform any of the terms, covenants and conditions contained in any Lease (or otherwise have any obligation with respect to any Lease); (ii) be obligated to appear in or defend any action or proceeding relating to the Lease or the Mortgaged Property; or (iii) be responsible for the operation, control, care, management or repair of the Mortgaged Property or any portion of the Mortgaged Property. The execution of this Instrument by Borrower shall constitute conclusive evidence that all responsibility for the operation, control, care, management and repair of the Mortgaged Property is and shall be that of Borrower, prior to such actual entry and taking of possession. (d) Upon delivery of notice by Lender to Borrower of Lender’s exercise of Lender’s rights under this Section 4, at any time during the continuance of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have Amended and Restated Mortgage 17 Vista Breeze any obligation to accept a cure of an Event of Default), and without the necessity of Lender entering upon and taking and maintaining control of the Mortgaged Property directly, by a receiver, or by any other manner or proceeding permitted by the laws of the Property Jurisdiction, Lender immediately shall have all rights, powers and authority granted to Borrower under any Lease, including the right, power and authority to modify the terms of any such Lease, or extend or terminate any such Lease. (e) Borrower shall, promptly upon Lender’s request, deliver to Lender an executed copy of each residential Lease then in effect. All Leases for residential dwelling units shall (i) be on forms approved by Lender, (ii) be for initial terms of at least six (6) months and not more than two (2) years, (iii) not include options to purchase, (iv) be legally valid, binding, and enforceable obligations of the tenants, (v) contain language expressly stating that such Lease is subordinate to the lien of this Instrument, and (vi) comply with all applicable laws. (f) Except for laundry facilities and cable television services for tenants on market terms and conditions, Borrower shall not lease any portion of the Mortgaged Property for non-residential use except with the prior written consent of Lender and Lender’s prior written approval of the Lease agreement. Borrower shall not modify the terms of, or extend or terminate, any Lease for non-residential use (including any Lease in existence on the date of this Instrument) without the prior written consent of Lender. Borrower shall, without request by Lender, deliver an executed copy of each non- residential Lease to Lender promptly after such Lease is signed. All non-residential Leases, including renewals or extensions of existing Leases, shall specifically provide that (i) such Leases are subordinate to the lien of this Instrument; (ii) the tenant shall attorn to Lender and any purchaser at a foreclosure sale, such attornment to be self- executing and effective upon acquisition of title to the Mortgaged Property by any purchaser at a foreclosure sale or by Lender in any manner; (iii) the tenant agrees to execute such further evidences of attornment as Lender or any purchaser at a foreclosure sale may from time to time request; (iv) the Lease shall not be terminated by foreclosure or any other transfer of the Mortgaged Property; (v) after a foreclosure sale of the Mortgaged Property, Lender or any other purchaser at such foreclosure sale may, at Lender’s or such purchaser’s option, accept or terminate such Lease; and (vi) the tenant shall, upon receipt after the occurrence of an Event of Default of a written request from Lender, pay all Rents payable under the Lease to Lender. (g) Borrower shall not receive or accept Rent under any Lease (whether residential or non-residential) for more than two months in advance (other than a security deposit not in excess of one month’s rent). 5. PAYMENT OF INDEBTEDNESS; PERFORMANCE UNDER LOAN DOCUMENTS; PREPAYMENT PREMIUM. Borrower shall pay the Indebtedness when due in accordance with the terms of the Note and the other Loan Documents and shall perform, observe and comply with all other provisions of the Note and the other Loan Documents. To the extent required pursuant to the Note, Borrower shall pay a prepayment premium in connection with certain prepayments of the Indebtedness, including a payment made after Lender’s exercise of any right of acceleration of the Indebtedness, as provided in the Note. Amended and Restated Mortgage 18 Vista Breeze 6. EXCULPATION. The personal liability of Borrower for payment of the Note and for performance of the other obligations to be performed by Borrower under this Instrument is limited in the manner, and to the extent, provided in the Note. 7. DEPOSITS FOR TAXES, INSURANCE AND OTHER CHARGES. (a) Borrower shall deposit with Lender on the day monthly installments of principal or interest, or both, are due under the Note (or on another day designated in writing by Lender), until the Indebtedness is paid in full, an additional amount sufficient to accumulate with Lender the entire sum required to pay, when due (i) any water and sewer charges which, if not paid, may result in a lien on all or any part of the Mortgaged Property, (ii) the premiums for fire and other hazard insurance, rental loss insurance and such other insurance as Lender may require under Section 19, (iii) Taxes, and (iv) amounts for other charges and expenses which Lender at any time reasonably deems necessary to protect the Mortgaged Property, to prevent the imposition of liens on the Mortgaged Property, or otherwise to protect Lender’s interests, all as reasonably estimated from time to time by Lender, plus one-twelfth of such estimate, if required by Lender. The amounts deposited under the preceding sentence are collectively referred to in this Instrument as the “Imposition Deposits”. The obligations of Borrower for which the Imposition Deposits are required are collectively referred to in this Instrument as “Impositions”. The amount of the Imposition Deposits shall be sufficient to enable Lender to pay each Imposition before the last date upon which such payment may be made without any penalty or interest charge being added. Lender shall maintain records indicating how much of the monthly Imposition Deposits and how much of the aggregate Imposition Deposits held by Lender are held for the purpose of paying Taxes, insurance premiums and each other Imposition. (b) Imposition Deposits shall be held in an institution (which may be Lender, if Lender is such an institution) whose deposits or accounts are insured or guaranteed by a federal agency. Lender shall not be obligated to open additional accounts or deposit Imposition Deposits in additional institutions when the amount of the Imposition Deposits exceeds the maximum amount of the federal deposit insurance or guaranty. Lender shall apply the Imposition Deposits to pay Impositions so long as no Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default). Unless applicable law requires, Lender shall not be required to pay Borrower any interest, earnings or profits on the Imposition Deposits. As additional security for all of Borrower’s obligations under this Instrument and the other Loan Documents, Borrower hereby pledges and grants to Lender a security interest in the Imposition Deposits and all proceeds of and all interest and dividends on the Imposition Deposits. Any amounts deposited with Lender under this Section 7 shall not be trust funds, nor shall they operate to reduce the Indebtedness, unless applied by Lender for that purpose under Section 7(e). (c) If Lender receives a bill or invoice for an Imposition, Lender shall pay the Imposition from the Imposition Deposits held by Lender. Lender shall have no obligation to pay any Imposition to the extent it exceeds Imposition Deposits then held by Lender. Lender may pay an Imposition according to any bill, statement or estimate from Amended and Restated Mortgage 19 Vista Breeze the appropriate public office or insurance company without inquiring into the accuracy of the bill, statement or estimate or into the validity of the Imposition. (d) If at any time the amount of the Imposition Deposits held by Lender for payment of a specific Imposition exceeds the amount deemed necessary by Lender, plus one twelfth of such estimate if required by Lender, the excess shall be credited against future installments of Imposition Deposits. If at any time the amount of the Imposition Deposits held by Lender for payment of a specific Imposition is less than the amount estimated by Lender to be necessary, plus one twelfth of such estimate if required by Lender, Borrower shall pay to Lender the amount of the deficiency within 15 days after notice from Lender. (e) If an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Lender may apply any Imposition Deposits, in any amounts and in any order as Lender determines, in Lender’s discretion, to pay any Impositions or as a credit against the Indebtedness. Upon payment in full of the Indebtedness, Lender shall refund to Borrower any Imposition Deposits held by Lender. (f) If Lender does not collect an Imposition Deposit pursuant to a separate written waiver by Lender, then on or before the date each such Imposition is due, or on the date this Instrument requires each such Imposition to be paid, Borrower shall, if required by Lender, provide Lender with proof of payment of each such Imposition for which Lender does not require collection of Imposition Deposits. Lender may, at any time and in Lender’s discretion, revoke its deferral or waiver and require Borrower to deposit with Lender any or all of the Imposition Deposits listed in this Section 7. 8. COLLATERAL AGREEMENTS. Borrower shall deposit with Lender such amounts as may be required by the Loan Agreement and any Collateral Agreement and shall perform all other obligations of Borrower under the Loan Agreement and each Collateral Agreement. 9. APPLICATION OF PAYMENTS. If at any time Lender receives, from Borrower or otherwise, any amount applicable to the Indebtedness which is less than all amounts due and payable at such time, then Lender may apply that payment to amounts then due and payable in any manner and in any order determined by Lender, in Lender’s discretion. Neither Lender’s acceptance of an amount that is less than all amounts then due and payable nor Lender’s application of such payment in the manner authorized shall constitute or be deemed to constitute either a waiver of the unpaid amounts or an accord and satisfaction. Notwithstanding the application of any such amount to the Indebtedness, Borrower’s obligations under this Instrument and the Note shall remain unchanged. 10. COMPLIANCE WITH LAWS. Borrower shall comply with all laws, ordinances, regulations and requirements of any Governmental Authority and all recorded lawful covenants and agreements relating to or affecting the Mortgaged Property, including all laws, ordinances, regulations, requirements and covenants pertaining to health and safety, construction of improvements on the Mortgaged Property, fair housing, disability accommodation, zoning and Amended and Restated Mortgage 20 Vista Breeze land use, and Leases. Borrower also shall comply with all applicable laws that pertain to the maintenance and disposition of tenant security deposits. Borrower shall at all times maintain records sufficient to demonstrate compliance with the provisions of this Section 10. Borrower shall take appropriate measures to prevent, and shall not engage in or knowingly permit, any illegal activities at the Mortgaged Property that could endanger tenants or visitors, result in damage to the Mortgaged Property, result in forfeiture of the Mortgaged Property, or otherwise materially impair the lien created by this Instrument or Lender’s interest in the Mortgaged Property. Borrower represents and warrants to Lender that no portion of the Mortgaged Property has been or will be purchased with the proceeds of any illegal activity. 11. USE OF PROPERTY. Unless required by applicable law, Borrower shall not (a) allow changes in the use for which all or any part of the Mortgaged Property is being used at the time this Instrument was executed, except for any change in use approved by Lender, (b) convert any individual dwelling units or common areas to commercial use, (c) initiate a change in the zoning classification of the Mortgaged Property or acquiesce in a change in the zoning classification of the Mortgaged Property, (d) establish any condominium or cooperative regime with respect to the Mortgaged Property; (e) combine all or any part of the Mortgaged Property with all or any part of a tax parcel which is not part of the Mortgaged Property, or (f) subdivide or otherwise split any tax parcel constituting all or any part of the Mortgaged Property without the prior consent of Lender. 12. PROTECTION OF LENDER’S SECURITY; INSTRUMENT SECURES FUTURE ADVANCES. (a) If Borrower fails to perform any of its obligations under this Instrument or any other Loan Document after the expiration of any applicable notice and cure period, or if any action or proceeding (including a Bankruptcy Event) is commenced which purports to affect the Mortgaged Property, Lender’s security or Lender’s rights under this Instrument, including eminent domain, insolvency, code enforcement, civil or criminal forfeiture, enforcement of Hazardous Materials Laws, fraudulent conveyance or reorganizations or proceedings involving a bankrupt or decedent, then Lender at Lender’s option may make such appearances, file such documents, disburse such sums and take such actions as Lender deems necessary to perform such obligations of Borrower and to protect Lender’s interest, including (i) payment of fees, expenses and reasonable fees of attorneys, accountants, inspectors and consultants, (ii) entry upon the Mortgaged Property to make repairs or secure the Mortgaged Property, (iii) procurement of the insurance required by Section 19 (specifically including, without limitation, flood insurance if required by Section 19), and (iv) payment of amounts which Borrower has failed to pay under Sections 15 and 17. (b) Any amounts disbursed by Lender under this Section 12, or under any other provision of this Instrument that treats such disbursement as being made under this Section 12, shall be secured by this Instrument, shall be added to, and become part of, the principal component of the Indebtedness, shall be immediately due and payable and shall bear interest from the date of disbursement until paid at the “Default Rate”, as defined in the Note. Amended and Restated Mortgage 21 Vista Breeze (c) If the Lender shall elect to pay any sum due with reference to the Project or the Mortgaged Property, the Lender may do so in reliance on any bill, statement or assessment procured from the appropriate Governmental Authority or other issuer thereof without inquiring into the accuracy or validity thereof. Similarly, in making any payments to protect the security intended to be created by this Instrument and/or the other Loan Documents, the Lender shall not be bound to inquire into the validity of any apparent or threatened adverse title, lien, encumbrance, claim or charge before making an advance for the purpose of preventing or removing the same. (d) Nothing in this Section 12 shall require Lender to incur any expense or take any action. 13. INSPECTION. (a) Lender and its agents, representatives, and designees may make or cause to be made entries upon and inspections of the Mortgaged Property (including environmental inspections and tests to the extent permitted under Section 18) during normal business hours, or at any other reasonable time, upon reasonable notice to Borrower and subject to the rights of tenants under their respective leases if the inspection is to include occupied residential units (which notice need not be in writing). Notice to Borrower shall not be required in the case of an emergency, as determined in Lender’s discretion, or when an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default). (b) If Lender determines that Mold has developed as a result of a water intrusion event or leak, Lender, at Lender’s discretion, may require that a professional inspector inspect the Mortgaged Property as frequently as Lender determines is necessary until any issue with Mold and its cause(s) are resolved to Lender’s satisfaction. Such inspection shall be limited to a visual and olfactory inspection of the area that has experienced the Mold, water intrusion event or leak. Borrower shall be responsible for the cost of such professional inspection and any remediation deemed to be necessary as a result of the professional inspection. After any issue with Mold, water intrusion or leaks is remedied to Lender’s satisfaction, Lender shall not require a professional inspection any more frequently than once every three years unless Lender is otherwise aware of Mold as a result of a subsequent water intrusion event or leak. (c) If Lender determines not to conduct an annual inspection of the Mortgaged Property, and in lieu thereof Lender requests a certification, Borrower shall be prepared to provide and must actually provide to Lender a factually correct certification each year that the annual inspection is waived to the following effect: that Borrower represents and warrants that Borrower has not received any written complaint, notice, letter or other written communication from tenants, management agent or any Governmental Authority regarding odors, indoor air quality, Mold or any activity, condition, event or omission that causes or facilitates the growth of Mold on or in any part of the Mortgaged Property, or if Borrower has received any such written complaint, notice, letter or other written communication, that Borrower has investigated and Amended and Restated Mortgage 22 Vista Breeze determined that no Mold activity, condition or event exists or alternatively has fully and properly remediated such activity, condition, event or omission in compliance with the MMP for the Mortgaged Property. If Borrower is unwilling or unable to provide such certification, Lender may require a professional inspection of the Mortgaged Property at Borrower’s expense. 14. BOOKS AND RECORDS; FINANCIAL REPORTING. (a) Borrower shall keep and maintain at all times at the Mortgaged Property or the management agent’s offices, and upon Lender’s request shall make available at the Mortgaged Property, complete and accurate books of account and records (including copies of supporting bills and invoices) adequate to reflect correctly the operation of the Mortgaged Property, and copies of all written contracts, Leases, and other instruments which affect the Mortgaged Property. The books, records, contracts, Leases and other instruments shall be subject to examination and inspection at any reasonable time by Lender upon reasonable advance written notice (which may be via email). (b) Borrower shall furnish to Lender all of the following: (i) (1) except as provided in clause (2) below, within 45 days after the end of each fiscal quarter of Borrower, a statement of income and expenses for Borrower’s operation of the Mortgaged Property on a year-to-date basis as of the end of each fiscal quarter, (2) within 120 days after the end of each fiscal year of Borrower, (A) a statement of income and expenses for Borrower’s operation of the Mortgaged Property for such fiscal year, (B) a statement of changes in financial position of Borrower relating to the Mortgaged Property for such fiscal year, and (C) a balance sheet showing all assets and liabilities of Borrower relating to the Mortgaged Property as of the end of such fiscal year; and (3) any of the foregoing at any other time upon Lender’s request; (ii) within 45 days after the end of each fiscal quarter of Borrower, and at any other time upon Lender’s request, a rent schedule for the Mortgaged Property showing the name of each tenant, and for each tenant, the space occupied, the lease expiration date, the rent payable for the current month, the date through which rent has been paid, and any related information requested by Lender; (iii) within 120 days after the end of each fiscal year of Borrower, and at any other time upon Lender’s request, an accounting of all security deposits held pursuant to all Leases, including the name of the institution (if any) and the names and identification numbers of the accounts (if any) in which such security deposits are held and the name of the person to contact at such financial institution, along with any authority or release necessary for Lender to access information regarding such accounts; Amended and Restated Mortgage 23 Vista Breeze (iv) within 120 days after the end of each fiscal year of Borrower, and at any other time upon Lender’s request, a statement that identifies all owners of any interest in Borrower and the interest held by each, if Borrower is a corporation, all officers and directors of Borrower, and if Borrower is a limited liability company, all managers who are not members; (v) upon Lender’s request, a monthly property management report for the Mortgaged Property, showing the number of inquiries made and rental applications received from tenants or prospective tenants and deposits received from tenants and any other information requested by Lender; (vi) upon Lender’s request, a balance sheet, a statement of income and expenses for Borrower and a statement of changes in financial position of Borrower for Borrower’s most recent fiscal year; (vii) annually, if applicable, within 60 days of the date required for submission by the agency in the Property Jurisdiction responsible for monitoring the low income housing tax credit program, a low income housing tax credit compliance report in form and substance acceptable to Lender; and (viii) if required by Lender, within 30 days of the end of each calendar month, a monthly statement of income and expenses for such calendar month on a year-to-date basis for Borrower’s operation of the Mortgaged Property. (c) Each of the statements, schedules and reports required by Section 14(b) shall be certified to be complete and accurate by an individual having authority to bind Borrower and shall be in such form and contain such detail as Lender may require. Lender also may require that any statements, schedules or reports be audited at Borrower’s expense by independent certified public accountants acceptable to Lender. (d) If Borrower fails to provide in a timely manner the statements, schedules and reports required by Section 14(b), Lender shall have the right to have Borrower’s books and records audited, at Borrower’s expense, by independent certified public accountants selected by Lender in order to obtain such statements, schedules and reports, and all related reasonable costs and expenses of Lender shall become immediately due and payable and shall become an additional part of the Indebtedness as provided in Section 12. (e) If an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Borrower shall deliver to Lender upon written demand all books and records relating to the Mortgaged Property or its operation. Amended and Restated Mortgage 24 Vista Breeze (f) Borrower authorizes Lender to obtain a credit report on Borrower at any time. 15. TAXES; OPERATING EXPENSES. (a) Subject to the provisions of Section 15(c) and Section 15(d), Borrower shall pay, or cause to be paid, all Taxes when due and before the imposition of any interest, fine, penalty or cost for nonpayment. (b) Subject to the provisions of Section 15(c), Borrower shall pay (i) the expenses of operating, managing, maintaining and repairing the Mortgaged Property (including insurance premiums, utilities, repairs and replacements) before the last date upon which each such payment may be made without any penalty or interest charge being added, and (ii) insurance premiums at least 30 days prior to the expiration date of each policy of insurance, unless applicable law specifies some lesser period. (c) If Lender is collecting Imposition Deposits, and to the extent that Lender holds sufficient Imposition Deposits for the purpose of paying a specific Imposition, then Borrower shall not be obligated to pay such Imposition, so long as no Event of Default exists and Borrower has timely delivered to Lender any bills or premium notices that it has received. If an Event of Default exists, Lender may exercise any rights Lender may have with respect to Imposition Deposits as expressly provided in this Instrument without regard to whether Impositions are then due and payable. Lender shall have no liability to Borrower for failing to pay any Impositions to the extent that any Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), insufficient Imposition Deposits are held by Lender at the time an Imposition becomes due and payable or Borrower has failed to provide Lender with bills and premium notices as provided above. (d) Borrower, at its own expense, may contest by appropriate legal proceedings, conducted diligently and in good faith, the amount or validity of any Imposition other than insurance premiums, if (i) Borrower notifies Lender of the commencement or expected commencement of such proceedings, (ii) the Mortgaged Property is not in danger of being sold or forfeited, (iii) Borrower deposits with Lender reserves sufficient to pay the contested Imposition, if requested by Lender, and (iv) Borrower furnishes whatever additional security is required in the proceedings or is requested by Lender, which may include the delivery to Lender of the reserves established by Borrower to pay the contested Imposition. (e) Borrower shall promptly deliver to Lender copies of all notices of, and invoices for, Impositions, and if Borrower pays any Imposition directly, Borrower shall promptly furnish to Lender on or before the date this Instrument requires such Impositions to be paid, copies of receipts evidencing that such payments were made. (f) All payments made by Borrower to Lender pursuant to this Instrument or any of the Loan Documents shall be free and clear of any and all tax liabilities Amended and Restated Mortgage 25 Vista Breeze whatsoever (other than United States federal income taxation payable by Lender) and, to the extent Lender is required to pay any such tax liabilities, Borrower shall reimburse Lender in respect of any such payment of taxes and, immediately upon request from Lender, shall deliver to Lender copies of receipts evidencing the payment of such taxes. 16. LIENS; ENCUMBRANCES. Borrower acknowledges that, to the extent provided in Section 21, the grant, creation or existence of any mortgage, deed of trust, deed to secure debt, security interest or other lien or encumbrance (a “Lien”) on the Mortgaged Property (other than the lien of this Instrument and the Permitted Encumbrances) or on certain ownership interests in Borrower, whether voluntary, involuntary or by operation of law, and whether or not such Lien has priority over the lien of this Instrument, is a “Transfer” which constitutes an Event of Default and subjects Borrower to personal liability under the Note. Borrower shall maintain the lien created by this Instrument as a first mortgage lien upon the Mortgaged Property, subject to no other Liens or encumbrances other than Permitted Encumbrances. 17. PRESERVATION, MANAGEMENT AND MAINTENANCE OF MORTGAGED PROPERTY. (a) Borrower shall not commit waste or permit impairment or deterioration of the Mortgaged Property. (b) Borrower shall not abandon the Mortgaged Property. (c) Borrower shall restore or repair promptly, in a good and workmanlike manner, any damaged part of the Mortgaged Property to the equivalent of its original condition, or such other condition as Lender may approve in writing, whether or not insurance proceeds or condemnation awards are available to cover any costs of such restoration or repair. (d) Borrower shall keep the Mortgaged Property in good repair (normal wear and tear excepted), including the replacement of Personalty and Fixtures with items of equal or better function and quality. (e) Borrower shall provide for professional management of the Mortgaged Property by a residential rental property manager satisfactory to Lender at all times, under a contract approved by Lender, in writing, which contract must be terminable upon not more than thirty (30) days’ notice without the necessity of establishing cause and without payment of a penalty or termination fee by Borrower or its successors. There shall be no change in the property manager or any contract for the management of the Mortgaged Property without Lender’s prior written approval. Lender shall have the right to require that Borrower and any new property manager enter into an Assignment of Management Agreement on a form approved by Lender. If required by Lender (whether before or after an Event of Default), Borrower will cause any Affiliate of Borrower to whom fees are payable for the management of the Mortgaged Property to enter into an agreement with Lender, in a form approved by Lender, providing for subordination of those fees and such other provisions as Lender may require. Amended and Restated Mortgage 26 Vista Breeze (f) Borrower shall give notice to Lender of and, unless otherwise directed in writing by Lender, shall appear in and defend any action or proceeding purporting to affect the Mortgaged Property, Lender’s security or Lender’s rights under this Instrument. Borrower shall not (and shall not permit any tenant or other person to) remove, demolish or alter the Mortgaged Property or any part of the Mortgaged Property, including any removal, demolition or alteration occurring in connection with the construction or rehabilitation of all or part of the Mortgaged Property, except (i) in connection with the replacement of tangible Personalty and (ii) repairs and replacements in connection with making an individual unit ready for a new occupant. (g) Unless otherwise waived by Lender in writing, Borrower must have or must establish and must adhere to the MMP. If Borrower is required to have an MMP, Borrower must keep all MMP documentation at the Mortgaged Property or at the management agent’s office and available for Lender or its agents to review during any annual assessment or inspection of the Mortgaged Property that is required by Lender. 18. ENVIRONMENTAL HAZARDS. (a) Except for matters described in Section 18(b), Borrower shall not cause or permit any of the following: (i) the presence, use, generation, release, treatment, processing, storage (including storage in above ground and underground storage tanks), handling, or disposal of any Hazardous Materials on or under the Mortgaged Property (whether as a result of activities on the Mortgaged Property or on surrounding properties) or any other property of Borrower that is adjacent to the Mortgaged Property; (ii) the transportation of any Hazardous Materials to, from, or across the Mortgaged Property (whether as a result of activities on the Mortgaged Property or on surrounding properties); (iii) any occurrence or condition on the Mortgaged Property (whether as a result of activities on the Mortgaged Property or on surrounding properties) or any other property of Borrower that is adjacent to the Mortgaged Property, which occurrence or condition is or may be in violation of Hazardous Materials Laws; (iv) any violation of or noncompliance with the terms of any Environmental Permit with respect to the Mortgaged Property or any property of Borrower that is adjacent to the Mortgaged Property; (v) the imposition of any environmental lien against the Mortgaged Property; or Amended and Restated Mortgage 27 Vista Breeze (vi) any violation or noncompliance with the terms of any O&M Program. The matters described in clauses (i) through (vi) above, except as otherwise provided in Section 18(b), are referred to collectively in this Section 18 as “Prohibited Activities or Conditions”. (b) Prohibited Activities or Conditions shall not include lawful conditions permitted by an O&M Program or the safe and lawful use and storage of quantities of (i) pre-packaged supplies, cleaning materials, petroleum products, household products, paints, solvents, lubricants and other materials customarily used in the construction, renovation, operation, maintenance or use of comparable multifamily properties, (ii) cleaning materials, household products, personal grooming items and other items sold in pre-packaged containers for consumer use and used by tenants and occupants of residential dwelling units in the Mortgaged Property; and (iii) petroleum products used in the operation and maintenance of motor vehicles from time to time located on the Mortgaged Property’s parking areas, so long as all of the foregoing are used, stored, handled, transported and disposed of in compliance with Hazardous Materials Laws. (c) Borrower shall take all commercially reasonable actions (including the inclusion of appropriate provisions in any Leases executed after the date of this Instrument) to prevent its employees, agents, and contractors, and all tenants and other occupants from causing or permitting any Prohibited Activities or Conditions. Borrower shall not lease or allow the sublease or use of all or any portion of the Mortgaged Property to any tenant or subtenant for nonresidential use by any user that, in the ordinary course of its business, would cause or permit any Prohibited Activity or Condition. (d) If and as required by Lender, Borrower shall also establish a written operations and maintenance program with respect to certain Hazardous Materials. Each such operations and maintenance program and any additional or revised operations and maintenance programs established for the Mortgaged Property pursuant to this Instrument must be approved by Lender and shall be referred to herein as an “O&M Program.” Borrower shall comply in a timely manner with, and cause all employees, agents, and contractors of Borrower and any other persons present on the Mortgaged Property to comply with each O&M Program. Borrower shall pay all costs of performance of Borrower’s obligations under any O&M Program, and any Beneficiary Party’s out-of- pocket costs incurred by such Beneficiary Party in connection with the monitoring and review of each O&M Program and Borrower’s performance shall be paid by Borrower upon demand by such Beneficiary Party. Any such out-of-pocket costs of such Beneficiary Party which Borrower fails to pay promptly shall become an additional part of the Indebtedness as provided in Section 12. (e) Without limitation of the foregoing, (i) Borrower hereby agrees to implement and maintain during the entire term of the Loan the O&M Program(s), and (ii) if asbestos-containing materials are found to exist at the Mortgaged Property, the O&M Program with respect thereto shall be undertaken consistent with the Guidelines for Amended and Restated Mortgage 28 Vista Breeze Controlling Asbestos-Containing Materials in Buildings (USEPA, 1985) and other relevant guidelines and applicable Hazardous Materials Laws. (f) With respect to any O&M Program, Lender may require (i) periodic notices or reports to Lender in form, substance and at such intervals as Lender may specify; (ii) amendments to such O&M Program to address changing circumstances, laws or other matters, including, without limitation, variations in response to reports provided by environmental consultants; and (iii) execution of an Operations and Maintenance Agreement relating to such O&M Program satisfactory to Lender. (g) Borrower represents and warrants to Beneficiary Parties that, except as otherwise disclosed in the Environmental Reports (as defined in the Agreement of Environmental Indemnification): (i) Borrower has not at any time engaged in, caused or permitted any Prohibited Activities or Conditions; (ii) to the best of Borrower’s knowledge after reasonable and diligent inquiry, no Prohibited Activities or Conditions exist or have existed, and Borrower has provided Lender with copies of all reports and information acquired in such inquiries; (iii) the Mortgaged Property does not now contain any underground storage tanks and, to the best of Borrower’s knowledge, the Mortgaged Property has not contained any underground storage tanks in the past. If there is an underground storage tank located on the Mortgaged Property that has been disclosed in Exhibit A to the Agreement of Environmental Indemnification, that tank complies with all requirements of Hazardous Materials Laws; (iv) Borrower has complied with and will continue to comply with all Hazardous Materials Laws, including all requirements for notification regarding releases of Hazardous Materials. Without limiting the generality of the foregoing, Borrower has obtained all Environmental Permits required for the operation of the Mortgaged Property in accordance with Hazardous Materials Laws now in effect and all such Environmental Permits are in full force and effect; (v) no event has occurred with respect to the Mortgaged Property that constitutes, or with the passing of time or the giving of notice would constitute, noncompliance with the terms of any Environmental Permit or Hazardous Materials Law; (vi) there are no actions, suits, claims or proceedings pending or, to the best of Borrower’s knowledge after reasonable and diligent inquiry, threatened that involve the Mortgaged Property and allege, arise out of, or relate to any Prohibited Activity or Condition; Amended and Restated Mortgage 29 Vista Breeze (vii) Borrower has not received any complaint, order, notice of violation or other communication from any Governmental Authority with regard to air emissions, water discharges, noise emissions or Hazardous Materials, or any other environmental, health or safety matters affecting the Mortgaged Property or any other property of Borrower that is adjacent to the Mortgaged Property; (viii) no prior Remedial Work (as defined below) has been undertaken, and no Remedial Work is ongoing, with respect to the Mortgaged Property during Borrower’s ownership thereof or, to the best of Borrower’s knowledge, at any time prior to Borrower’s ownership thereof; and (ix) Borrower has disclosed in the Agreement of Environmental Indemnification all material facts known to Borrower or contained in Borrower’s records the nondisclosure of which could cause any representation or warranty made herein or any statement made in the Agreement of Environmental Indemnification to be false or materially misleading. The representations and warranties in this Section 18 shall be continuing representations and warranties that shall be deemed to be made by Borrower throughout the term of the Loan, until the Indebtedness has been paid in full or otherwise discharged. (h) Borrower shall promptly notify Lender in writing upon the occurrence of any of the following events: (i) Borrower’s discovery of any Prohibited Activity or Condition that is not described in the Environmental Reports; (ii) Borrower’s receipt of or knowledge of any complaint, order, notice of violation or other communication from any tenant, management agent, Governmental Authority or other person with regard to present or future alleged Prohibited Activities or Conditions or any other environmental, health or safety matters affecting the Mortgaged Property or any other property of Borrower that is adjacent to the Mortgaged Property; (iii) Borrower’s receipt of or knowledge of any personal injury claim, proceeding or cause of action directly or indirectly arising as a result of the presence of asbestos or other Hazardous Materials on or from the Mortgaged Property; (iv) Borrower’s discovery that any representation or warranty in this Section 18 has become untrue after the date of this Instrument; and (v) Borrower’s breach of any of its obligations under this Section 18. Amended and Restated Mortgage 30 Vista Breeze Any such notice given by Borrower shall not relieve Borrower of, or result in a waiver of, any obligation under this Instrument, the Note, or any other Loan Document. (i) Borrower shall pay promptly the actual costs of any environmental inspections, tests or audits (“Environmental Inspections”) required by Lender or any Beneficiary Party in connection with any foreclosure or deed in lieu of foreclosure, or as a condition of Lender’s consent to any Transfer under Section 21, or required by Lender following a determination by Lender that Prohibited Activities or Conditions may exist. Any such costs incurred by Lender (including, without limitation, actual fees and expenses of attorneys, expert witnesses, engineers, technical consultants and investigatory fees, whether incurred in connection with any judicial or administrative process or otherwise) that Borrower fails to pay promptly shall become an additional part of the Indebtedness as provided in Section 12. The results of all Environmental Inspections made by Lender shall at all times remain the property of Lender and Lender shall have no obligation to disclose or otherwise make available to Borrower or any other party such results or any other information obtained by Lender in connection with such Environmental Inspections. Lender hereby reserves the right, and Borrower hereby expressly authorizes Lender, to make available to any party, including any prospective bidder at a foreclosure sale of the Mortgaged Property, the results of any Environmental Inspections made by Lender with respect to the Mortgaged Property. Borrower consents to Lender notifying any party (either as part of a notice of sale or otherwise) of the results of any of Lender’s Environmental Inspections. Borrower acknowledges that Lender cannot control or otherwise assure the truthfulness or accuracy of the results of any of its Environmental Inspections and that the release of such results to prospective bidders at a foreclosure sale of the Mortgaged Property may have a material and adverse effect upon the amount which a party may bid at such sale. Borrower agrees that Lender shall have no liability whatsoever as a result of delivering the results of any of its Environmental Inspections to any third party, and Borrower hereby releases and forever discharges Lender from any and all claims, damages, or causes of action, arising out of, connected with or incidental to the results of, the delivery of any of Lender’s Environmental Inspections. (j) If any investigation, site monitoring, containment, clean-up, restoration or other remedial work (“Remedial Work”) is necessary to comply with or cure a violation of any Hazardous Materials Law or order of any Governmental Authority that has or acquires jurisdiction over the Mortgaged Property or the use, operation or improvement of the Mortgaged Property under any Hazardous Materials Law, or is otherwise required by Lender as a consequence of any Prohibited Activity or Condition or to prevent the occurrence of a Prohibited Activity or Condition, Borrower shall, by the earlier of (i) the applicable deadline required by such Hazardous Materials Law or (ii) thirty (30) days after notice from Lender demanding such action, begin performing the Remedial Work, and thereafter diligently prosecute it to completion, and shall in any event complete the work by the time required by such Hazardous Materials Law. Borrower shall promptly provide Lender with a cost estimate from an environmental consultant acceptable to Lender to complete any required Remedial Work. If required by Lender, Borrower shall promptly establish with Lender a reserve fund in the amount of such estimate. If in Lender’s opinion the amount reserved at any time during the Remedial Work is Amended and Restated Mortgage 31 Vista Breeze insufficient to cover the work remaining to complete the Remedial Work or achieve compliance, Borrower shall increase the amount reserved in compliance with Lender’s written request. All amounts so held in reserve, until disbursed, are hereby pledged to Lender as security for payment of Borrower’s obligations under this Instrument. If Borrower fails to begin on a timely basis or diligently prosecute any required Remedial Work, Lender may, at its option, cause the Remedial Work to be completed, in which case Borrower shall reimburse Lender on demand for the cost of doing so. Any reimbursement due from Borrower to Lender shall become part of the Indebtedness as provided in Section 12. (k) Borrower shall comply with all Hazardous Materials Laws applicable to the Mortgaged Property. Without limiting the generality of the previous sentence, Borrower shall (i) obtain and maintain all Environmental Permits required by Hazardous Materials Laws and comply with all conditions of such Environmental Permits; (ii) cooperate with any inquiry by any Governmental Authority; and (iii) comply with any governmental or judicial order that arises from any alleged Prohibited Activity or Condition. (l) BORROWER SHALL INDEMNIFY, HOLD HARMLESS AND DEFEND BENEFICIARY PARTIES AND THEIR RESPECTIVE OFFICERS, DIRECTORS, SHAREHOLDERS, PARTNERS, EMPLOYEES, AGENTS, ATTORNEYS, TRUSTEES, HEIRS AND LEGAL REPRESENTATIVES (COLLECTIVELY, THE “INDEMNITEES”) FROM AND AGAINST ALL LOSSES, PROCEEDINGS, CLAIMS, DAMAGES, PENALTIES AND COSTS (WHETHER INITIATED OR SOUGHT BY GOVERNMENTAL AUTHORITIES OR PRIVATE PARTIES), INCLUDING, WITHOUT LIMITATION, ACTUAL FEES AND OUT-OF- POCKET EXPENSES OF ATTORNEYS AND EXPERT WITNESSES, ENGINEERING FEES, ENVIRONMENTAL CONSULTANT FEES, INVESTIGATORY FEES, AND REMEDIATION COSTS (INCLUDING, WITHOUT LIMITATION, ANY FINANCIAL ASSURANCES REQUIRED TO BE POSTED FOR COMPLETION OF REMEDIAL WORK AND COSTS ASSOCIATED WITH ADMINISTRATIVE OVERSIGHT), AND ANY OTHER LIABILITIES OF WHATEVER KIND AND WHATEVER NATURE, WHETHER INCURRED IN CONNECTION WITH ANY JUDICIAL OR ADMINISTRATIVE PROCESS OR OTHERWISE, ARISING DIRECTLY OR INDIRECTLY FROM ANY OF THE FOLLOWING: (i) ANY BREACH OF ANY REPRESENTATION OR WARRANTY OF BORROWER IN THIS SECTION 18; (ii) ANY FAILURE BY BORROWER TO PERFORM ANY OF ITS OBLIGATIONS UNDER THIS SECTION 18; (iii) THE EXISTENCE OR ALLEGED EXISTENCE OF ANY PROHIBITED ACTIVITY OR CONDITION; Amended and Restated Mortgage 32 Vista Breeze (iv) THE PRESENCE OR ALLEGED PRESENCE OF HAZARDOUS MATERIALS ON OR UNDER THE MORTGAGED PROPERTY (WHETHER AS A RESULT OF ACTIVITIES ON THE MORTGAGED PROPERTY OR ON SURROUNDING PROPERTIES) OR IN ANY OF THE IMPROVEMENTS OR ON OR UNDER ANY PROPERTY OF BORROWER THAT IS ADJACENT TO THE MORTGAGED PROPERTY; (v) THE ACTUAL OR ALLEGED VIOLATION OF ANY HAZARDOUS MATERIALS LAW; (vi) ANY LOSS OR DAMAGE RESULTING FROM A LOSS OF PRIORITY OF THIS INSTRUMENT OR ANY OTHER LOAN DOCUMENT DUE TO AN IMPOSITION OF AN ENVIRONMENTAL LIEN AGAINST THE MORTGAGED PROPERTY; AND (vii) ANY PERSONAL INJURY CLAIM, PROCEEDING OR CAUSE OF ACTION DIRECTLY OR INDIRECTLY ARISING AS A RESULT OF THE PRESENCE OF ASBESTOS OR OTHER HAZARDOUS MATERIALS ON OR FROM THE MORTGAGED PROPERTY. (m) COUNSEL SELECTED BY BORROWER TO DEFEND INDEMNITEES SHALL BE SUBJECT TO THE APPROVAL OF THOSE INDEMNITEES. IN ANY CIRCUMSTANCES IN WHICH THE INDEMNITY UNDER THIS SECTION 18 APPLIES, ANY BENEFICIARY PARTY MAY EMPLOY ITS OWN LEGAL COUNSEL AND CONSULTANTS TO PROSECUTE, DEFEND OR NEGOTIATE ANY CLAIM OR LEGAL OR ADMINISTRATIVE PROCEEDING AT BORROWER’S EXPENSE, AND SUCH BENEFICIARY PARTY, WITH THE PRIOR WRITTEN CONSENT OF BORROWER (WHICH SHALL NOT BE UNREASONABLY WITHHELD, DELAYED OR CONDITIONED) MAY SETTLE OR COMPROMISE ANY ACTION OR LEGAL OR ADMINISTRATIVE PROCEEDING. BORROWER SHALL REIMBURSE SUCH BENEFICIARY PARTY UPON DEMAND FOR ALL COSTS AND EXPENSES INCURRED BY SUCH BENEFICIARY PARTY, INCLUDING, WITHOUT LIMITATION, ALL COSTS OF SETTLEMENTS ENTERED INTO IN GOOD FAITH, AND THE FEES AND OUT OF POCKET EXPENSES OF SUCH ATTORNEYS AND CONSULTANTS. (n) BORROWER SHALL NOT, WITHOUT THE PRIOR WRITTEN CONSENT OF THOSE INDEMNITEES WHO ARE NAMED AS PARTIES TO A CLAIM OR LEGAL OR ADMINISTRATIVE PROCEEDING (A “CLAIM”), SETTLE OR COMPROMISE THE CLAIM IF THE SETTLEMENT (1) RESULTS IN THE ENTRY OF ANY JUDGMENT THAT DOES NOT INCLUDE AS AN UNCONDITIONAL TERM THE DELIVERY BY THE CLAIMANT OR PLAINTIFF TO BENEFICIARY PARTIES OF A WRITTEN RELEASE OF THOSE INDEMNITEES, SATISFACTORY IN FORM AND SUBSTANCE TO LENDER; OR Amended and Restated Mortgage 33 Vista Breeze (2) MAY MATERIALLY AND ADVERSELY AFFECT BENEFICIARY PARTIES, AS DETERMINED BY LENDER IN ITS DISCRETION. (o) BORROWER’S OBLIGATION TO INDEMNIFY THE INDEMNITEES SHALL NOT BE LIMITED OR IMPAIRED BY ANY OF THE FOLLOWING, OR BY ANY FAILURE OF BORROWER OR ANY GUARANTOR TO RECEIVE NOTICE OF OR CONSIDERATION FOR ANY OF THE FOLLOWING: (i) ANY AMENDMENT OR MODIFICATION OF ANY LOAN DOCUMENT; (ii) ANY EXTENSIONS OF TIME FOR PERFORMANCE REQUIRED BY ANY LOAN DOCUMENT; (iii) ANY PROVISION IN ANY LOAN DOCUMENT LIMITING BENEFICIARY PARTIES’ RECOURSE TO PROPERTY SECURING THE INDEBTEDNESS, OR LIMITING THE PERSONAL LIABILITY OF BORROWER OR ANY OTHER PARTY FOR PAYMENT OF ALL OR ANY PART OF THE INDEBTEDNESS; (iv) THE ACCURACY OR INACCURACY OF ANY REPRESENTATIONS AND WARRANTIES MADE BY BORROWER UNDER THIS INSTRUMENT OR ANY OTHER LOAN DOCUMENT; (v) THE RELEASE OF BORROWER OR ANY OTHER PERSON, BY BENEFICIARY PARTIES OR BY OPERATION OF LAW, FROM PERFORMANCE OF ANY OBLIGATION UNDER ANY LOAN DOCUMENT; (vi) THE RELEASE OR SUBSTITUTION IN WHOLE OR IN PART OF ANY SECURITY FOR THE INDEBTEDNESS; AND (vii) FAILURE BY BENEFICIARY PARTIES TO PROPERLY PERFECT ANY LIEN OR SECURITY INTEREST GIVEN AS SECURITY FOR THE INDEBTEDNESS. (p) BORROWER SHALL, AT ITS OWN COST AND EXPENSE, DO ALL OF THE FOLLOWING: (i) PAY OR SATISFY ANY JUDGMENT OR DECREE THAT MAY BE ENTERED AGAINST ANY INDEMNITEE OR INDEMNITEES IN ANY LEGAL OR ADMINISTRATIVE PROCEEDING INCIDENT TO ANY MATTERS AGAINST WHICH INDEMNITEES ARE ENTITLED TO BE INDEMNIFIED UNDER THIS SECTION 18; Amended and Restated Mortgage 34 Vista Breeze (ii) REIMBURSE INDEMNITEES FOR ANY AND ALL EXPENSES PAID OR INCURRED IN CONNECTION WITH ANY MATTERS AGAINST WHICH INDEMNITEES ARE ENTITLED TO BE INDEMNIFIED UNDER THIS SECTION 18; AND (iii) REIMBURSE INDEMNITEES FOR ANY AND ALL EXPENSES, INCLUDING, WITHOUT LIMITATION, FEES AND OUT OF POCKET EXPENSES OF ATTORNEYS AND EXPERT WITNESSES, PAID OR INCURRED IN CONNECTION WITH THE ENFORCEMENT BY INDEMNITEES OF THEIR RIGHTS UNDER THIS SECTION 18, OR IN MONITORING AND PARTICIPATING IN ANY LEGAL OR ADMINISTRATIVE PROCEEDING. (q) THE PROVISIONS OF THIS SECTION 18 SHALL BE IN ADDITION TO ANY AND ALL OTHER OBLIGATIONS AND LIABILITIES THAT BORROWER MAY HAVE UNDER APPLICABLE LAW OR UNDER ANY OTHER LOAN DOCUMENT, AND EACH INDEMNITEE SHALL BE ENTITLED TO INDEMNIFICATION UNDER THIS SECTION 18 WITHOUT REGARD TO WHETHER ANY OTHER BENEFICIARY PARTY OR THAT INDEMNITEE HAS EXERCISED ANY RIGHTS AGAINST THE MORTGAGED PROPERTY OR ANY OTHER SECURITY, PURSUED ANY RIGHTS AGAINST ANY GUARANTOR, OR PURSUED ANY OTHER RIGHTS AVAILABLE UNDER THE LOAN DOCUMENTS OR APPLICABLE LAW. IF BORROWER CONSISTS OF MORE THAN ONE PERSON OR ENTITY, THE OBLIGATION OF THOSE PERSONS OR ENTITIES TO INDEMNIFY THE INDEMNITEES UNDER THIS SECTION 18 SHALL BE JOINT AND SEVERAL. THE OBLIGATION OF BORROWER TO INDEMNIFY THE INDEMNITEES UNDER THIS SECTION 18 SHALL SURVIVE ANY REPAYMENT OR DISCHARGE OF THE INDEBTEDNESS, ANY FORECLOSURE PROCEEDING, ANY FORECLOSURE SALE, ANY DELIVERY OF ANY DEED IN LIEU OF FORECLOSURE, AND ANY RELEASE OF RECORD OF THE LIEN OF THIS INSTRUMENT. (r) Notwithstanding anything herein to the contrary, (i) Borrower shall have no obligation hereunder to indemnify any Indemnitee for any liability under this Section 18 to the extent that the Prohibited Activity or Condition giving rise to such liability resulted solely from the gross negligence or willful misconduct of such Indemnitee, and (ii) Borrower’s liability under this Section 18 shall not extend to cover the violation of any Hazardous Materials Laws or Prohibited Activities or Conditions that first arise, commence or occur as a result of actions of Lender, its successors, assigns or designees, after the satisfaction, discharge, release, assignment, termination or cancellation of this Instrument following the payment in full of the Note and all other sums payable under the Loan Documents or after the actual dispossession from the entire Mortgaged Property of Borrower and all Affiliates of Borrower following foreclosure of this Instrument or acquisition of the Mortgaged Property by a deed in lieu of foreclosure. Amended and Restated Mortgage 35 Vista Breeze 19. PROPERTY AND LIABILITY INSURANCE. (a) Borrower shall keep the Improvements insured at all times against such hazards as Lender may from time to time require, which insurance shall include but not be limited to coverage against loss by fire and allied perils, general boiler and machinery coverage, business income coverage and extra expense insurance, coverage against acts of terrorism, mold and earthquake coverage. Borrower acknowledges and agrees that Lender’s insurance requirements may change from time to time throughout the term of the Indebtedness. If Lender so requires, such insurance shall also include sinkhole insurance, mine subsidence insurance, earthquake insurance, and, if the Mortgaged Property does not conform to applicable zoning or land use laws, building ordinance or law coverage. If any portion of the Improvements is at any time located in an area identified by the Federal Emergency Management Agency (or any successor to that agency) as an area now or hereafter having special flood hazards, and if flood insurance is available in that area, Borrower shall insure such Improvements against loss by flood in an amount equal to the maximum amount available under the National Flood Insurance Program or any successor thereto. (b) All premiums on insurance policies required under Section 19(a) shall be paid in the manner provided in Section 7, unless Lender has designated in writing another method of payment. All such policies shall also be in a form approved by Lender. All policies of property damage insurance shall include a non-contributing, non-reporting mortgage clause in favor of, and in a form approved by, Lender. Lender shall have the right to hold the original policies or duplicate original policies of all insurance required by Section 19(a). Borrower shall promptly deliver to Lender a copy of all renewal and other notices received by Borrower with respect to the policies and all receipts for paid premiums. At least 30 days prior to the expiration date of a policy, Borrower shall deliver to Lender the original (or a duplicate original) of a renewal policy in form satisfactory to Lender. (c) All insurance policies and renewals of insurance policies required by this Section 19 shall be in such amounts and for such periods as Lender may from time to time require consistent with Lender’s then current practices and standards, and shall be issued by insurance companies satisfactory to Lender. (d) All insurance policies and renewals of insurance policies required by this Section 19 shall also comply with any applicable Credit Enhancer Insurance Standards. The following provisions shall apply, in addition to the other provisions of this Section 19 and without limiting the generality of the other provisions of this Section 19: (i) Borrower shall provide (or cause to be provided), maintain and keep in force, the following insurance coverage: (A) Builder’s “all risk” insurance or the equivalent coverage, including theft, to insure all buildings, machinery, equipment, materials, supplies, temporary structures and all other property of any nature on-site, off-site and while in Amended and Restated Mortgage 36 Vista Breeze transit which is to be used in fabrication, erection, installation and construction and/or rehabilitation of the Project, and to remain in effect until the entire Project has been completed and accepted by Borrower and is first occupied by any tenants (provided that in any event, such coverage shall remain in effect until such time as Borrower has provided Lender with evidence of property insurance covering the Improvements and meeting the requirements of this Section 19). Such insurance shall be provided on a replacement cost value basis and shall include foundations, other underground property, tenant improvements and personal property. If tenant improvements and personal property are not included in the above coverage, they may be insured separately by Borrower provided coverage is acceptable to Lender. Builders “all risk” insurance shall (i) be on a nonreporting, completed value form, (ii) cover soft costs, debris removal expense (including removal of pollutants), resulting loss and damage to property due to faulty or defective workmanship or materials and error in design or specification, loss while the property is in the care, custody and control of others to whom the property may be entrusted, (iii) provide that Borrower can complete and occupy the Mortgaged Property without further written consent from the insurer, and (iv) cover loss of income resulting from delay in occupancy and use of the Mortgaged Property due to loss. During the initial construction and/or rehabilitation of the Project and until such time as the Project is first occupied by any tenants, the Borrower shall not be required to maintain property insurance as required by this Section 19 for so long as Builder’s “all risk” insurance or equivalent coverage is maintained in accordance with this paragraph. (B) If any portion of the Mortgaged Property is or becomes located in an area identified by the United States Secretary of Housing and Urban Development as an area having special flood hazards and in which flood insurance has been made available under the National Flood Insurance Act of 1968 and Flood Disaster Protection Act of 1973, as amended, Borrower shall also keep the improvements and the equipment located thereon insured against loss by flood in an amount at least equal to the principal amount of the Loan or the maximum limits of coverage available with respect to the Mortgaged Property, whichever is less. All such insurance shall also cover continuing expenses not directly involved in the direct cost of construction, rehabilitation or renovation, including interest on money Amended and Restated Mortgage 37 Vista Breeze borrowed to finance construction, rehabilitation or renovation, continuing interest on the Loan, advertising, promotion, real estate taxes and other assessments, the cost of renegotiating leases, and other expenses incurred as the result of property loss or destruction by the insured peril. Such coverage shall not contain any monthly limitation. (ii) If Lender fails to receive proof and evidence of the insurance required hereunder, Lender shall have the right, but not the obligation, to obtain or cause to be obtained current coverage (and, in its sole discretion, advance funds) to pay the premiums for it. If Lender makes an advance for such purpose, Borrower shall repay such advance immediately on demand and such advance shall be considered to be a demand loan to Borrower bearing interest at the Default Rate (as defined in the Note) and secured by the Mortgaged Property. (e) Borrower shall maintain at all times commercial general liability insurance, workers’ compensation insurance (to the extent Borrower has employees) and such other liability, errors and omissions and fidelity insurance coverages as Lender may from time to time require, consistent with Lender’s then current practices and standards (and any applicable Credit Enhancer Insurance Standards). (f) Borrower shall comply with all insurance requirements and shall not permit any condition to exist on the Mortgaged Property that would invalidate any part of any insurance coverage that this Instrument requires Borrower to maintain. (g) In the event of loss, Borrower shall give immediate written notice to the insurance carrier and to Lender. Borrower hereby authorizes and appoints Lender as attorney-in-fact for Borrower to make proof of loss, to adjust and compromise any claims under policies of property damage insurance, to appear in and prosecute any action arising from such property damage insurance policies, to collect and receive the proceeds of property damage insurance, and to deduct from such proceeds Lender’s expenses incurred in the collection of such proceeds. This power of attorney is coupled with an interest and therefore is irrevocable. However, nothing contained in this Section 19 shall require Lender to incur any expense or take any action. Lender may, at Lender’s option, (i) cause the Fiscal Agent to hold the balance of such proceeds to be used to reimburse Borrower for the cost of restoring and repairing the Mortgaged Property to the equivalent of its original condition or to a condition approved by Lender (the “Restoration”), or (ii) apply the balance of such proceeds to the payment of the Indebtedness, whether or not then due. To the extent Lender determines to apply insurance proceeds to Restoration, Lender shall authorize the Fiscal Agent to disburse the proceeds in accordance with Lender’s then-current policies relating to the restoration of casualty damage on similar multifamily properties. (h) Lender shall not exercise its option to apply insurance proceeds to the payment of the Indebtedness if all of the following conditions are met: (i) no Event of Amended and Restated Mortgage 38 Vista Breeze Default (or any event which, with the giving of notice or the passage of time, or both, would constitute an Event of Default) has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default); (ii) Lender determines, in its discretion, that there will be sufficient funds to complete the Restoration; (iii) Lender determines, in its discretion, that the net operating income generated by the Mortgaged Property after completion of the Restoration will be sufficient to meet all operating costs and other expenses, Imposition Deposits, deposits to reserves and loan repayment obligations relating to the Mortgaged Property; (iv) Lender determines, in its discretion, that the Restoration will be completed before the earlier of (A) one year before the Mandatory Prepayment Date set forth in the Note, or (B) one year after the date of the loss or casualty; and (v) upon Lender’s request, Borrower provides Lender evidence of the availability during and after the Restoration of the insurance required to be maintained pursuant to this Instrument. (i) If the Mortgaged Property is sold at a foreclosure sale or Lender acquires title to the Mortgaged Property, Lender shall automatically succeed to all rights of Borrower in and to any insurance policies and unearned insurance premiums and in and to the proceeds resulting from any damage to the Mortgaged Property prior to such sale or acquisition. (j) Unless Lender otherwise agrees in writing, any application of any insurance proceeds to the Indebtedness shall not extend or postpone the due date of any monthly installments referred to in the Note, Section 7 of this Instrument or any Collateral Agreement, or change the amount of such installments, except as provided in the Note. (k) Borrower agrees to execute such further evidence of assignment of any insurance proceeds as Lender may require. (l) Borrower further agrees that to the extent that Borrower obtains any form of property damage insurance for the Mortgaged Property or any portion thereof that insures perils not required to be insured against by Lender, such policy of property damage insurance shall include a standard mortgagee clause and shall name Lender as loss payee and, within ten (10) days following Borrower’s purchase of such additional insurance, Borrower shall cause to be delivered to Lender a duplicate original policy of insurance with respect to such policy. Any insurance proceeds payable to Borrower under such policy shall be additional security for the Indebtedness and Lender shall have the same rights to such policy and proceeds as it has with respect to insurance policies required by Lender pursuant to this Section 19 (except that Lender shall not require that the premium for such additional insurance be included among the Imposition Deposits). 20. CONDEMNATION. (a) Borrower shall promptly notify Lender in writing of any action or proceeding or notice relating to any proposed or actual condemnation or other taking, or conveyance in lieu thereof, of all or any part of the Mortgaged Property, whether direct or Amended and Restated Mortgage 39 Vista Breeze indirect (a “Condemnation”), and shall deliver to the Lender copies of any and all papers served in connection with such Condemnation. Borrower shall appear in and prosecute or defend any action or proceeding relating to any Condemnation unless otherwise directed by Lender in writing. Borrower authorizes and appoints Lender as attorney-in- fact for Borrower to commence, appear in and prosecute, in Lender’s or Borrower’s name, any action or proceeding relating to any Condemnation and to settle or compromise any claim in connection with any Condemnation. This power of attorney is coupled with an interest and therefore is irrevocable. However, nothing contained in this Section 20 shall require Lender to incur any expense or take any action. Borrower hereby transfers and assigns to Lender all right, title and interest of Borrower in and to any award or payment with respect to (i) any Condemnation, or any conveyance in lieu of Condemnation, and (ii) any damage to the Mortgaged Property caused by governmental action that does not result in a Condemnation. (b) Subject to the provisions of Section 20(c), Lender may apply such awards or proceeds, after the deduction of Lender’s expenses incurred in the collection of such amounts (including, without limitation, fees and out-of-pocket expenses of attorneys and expert witnesses, investigatory fees, whether incurred in connection with any judicial or administrative process or otherwise), at Lender’s option, to the restoration or repair of the Mortgaged Property or to the payment of the Indebtedness in accordance with the provisions of the Note as to application of payments to the Indebtedness, with the balance, if any, to Borrower. Unless Lender otherwise agrees in writing, any application of any awards or proceeds to the Indebtedness shall not extend or postpone the due date of payments due under the Note, Section 7 of this Instrument or any Collateral Agreement or any other Loan Document, or change the amount of such payments, except as otherwise provided in the Note. Borrower agrees to execute such further evidence of assignment of any awards or proceeds as Lender may require. (c) Lender shall not exercise its option to apply condemnation awards to payment of the Indebtedness if all of the following conditions are met (i) no Event of Default (or any event which, with the giving of notice or passage of time, or both, would constitute an Event of Default) has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), (ii) Lender determined, in its discretion, that there will be sufficient funds to complete the Restoration, (iii) Lender determines, in its discretion, that the net operating income generated by the Mortgaged Property after completion of the Restoration will be sufficient to meet all operating costs and other expenses, Imposition Deposits, deposits to reserves and loan repayment obligations relating to the Mortgaged Property, and (iv) Lender determines, in its discretion, that the Restoration will be completed before the earlier of (A) one year before the Mandatory Prepayment Date set forth in the Note, or (B) one year after the date of the loss or casualty. Amended and Restated Mortgage 40 Vista Breeze 21. TRANSFERS OF THE MORTGAGED PROPERTY OR INTERESTS IN BORROWER. (a) The occurrence of any of the following events shall constitute an Event of Default under this Instrument: (i) other than the lien of this Instrument and the Permitted Encumbrances, a Transfer of all or any part of the Mortgaged Property or any interest in the Mortgaged Property; (ii) a Transfer of a Controlling Interest in Borrower; (iii) a Transfer of a Controlling Interest in any entity which owns, directly or indirectly through one or more intermediate entities, a Controlling Interest in Borrower; (iv) a Transfer of all or any part of a Guarantor’s ownership interests in Borrower, or in any other entity which owns, directly or indirectly through one or more intermediate entities, an ownership interest in Borrower (other than a Transfer of an aggregate beneficial ownership interest in Borrower of 49% or less of such Guarantor’s original ownership interest in Borrower and which does not otherwise result in a Transfer of the Guarantor’s Controlling Interest in such intermediate entities or in Borrower); (v) if Guarantor is an entity, (A) a Transfer of a Controlling Interest in Guarantor, or (B) a Transfer of a Controlling Interest in any entity which owns, directly or indirectly through one or more intermediate entities, a Controlling Interest in Guarantor; (vi) if Borrower or Guarantor is a trust, the termination or revocation of such trust; unless the trust is terminated as a result of the death of an individual trustor, in which event Lender must be notified and such Borrower or Guarantor must be replaced with an individual or entity acceptable to Lender, in accordance with the provisions of Section 21(c) hereof, within 90 days of such death (provided however that no property inspection shall be required and a 1% transfer fee will not be charged); (vii) if Guarantor is a natural person, the death of such individual; unless the Lender is notified and such individual is replaced with an individual or entity acceptable to Lender, in accordance with the provisions of Section 21(c) hereof, within 90 days of such death (provided however that no property inspection shall be required and a 1% transfer fee will not be charged); (viii) the merger, dissolution, liquidation, or consolidation of (i) Borrower, (ii) any Guarantor that is a legal entity, or (iii) any Amended and Restated Mortgage 41 Vista Breeze legal entity holding, directly or indirectly, a Controlling Interest in Borrower or in any Guarantor that is an entity; (ix) a conversion of Borrower from one type of legal entity into another type of legal entity (including the conversion of a general partnership into a limited partnership and the conversion of a limited partnership into a limited liability company), whether or not there is a Transfer; if such conversion results in a change in any assets, liabilities, legal rights or obligations of Borrower (or of any Guarantor, or any general partner of Borrower, as applicable), by operation of law or otherwise; (x) a Transfer of the economic benefits or right to cash flows attributable to the ownership interests in Borrower and/or, if Guarantor is an entity, Guarantor, separate from the Transfer of the underlying ownership interests, unless the Transfer of the underlying ownership interests would otherwise not be prohibited by this Instrument; and (xi) the filing, recording, or consent to filing or recording of any plat or map subdividing, replatting or otherwise affecting the Mortgaged Property or any other replat or subdivision of the Mortgaged Property, whether or not any such action affects the priority of the lien of this Instrument. Lender shall not be required to demonstrate any actual impairment of its security or any increased risk of default in order to exercise any of its remedies with respect to an Event of Default under this Section 21. (b) The occurrence of any of the following events shall not constitute an Event of Default under this Instrument, notwithstanding any provision of Section 21(a) to the contrary (each a “Permitted Transfer”): (i) a Transfer to which Lender has consented; (ii) except as provided in Section 21(a)(vi) and (vii), a Transfer that occurs by devise, descent, pursuant to the provisions of a trust, or by operation of law upon the death of a natural person; (iii) the grant of a leasehold interest in an individual dwelling unit for a term of two years or less not containing an option to purchase; (iv) a Transfer of obsolete or worn out Personalty or Fixtures that are contemporaneously replaced by items of equal or better function and quality, which are free of liens, encumbrances and security interests other than those created by or permitted pursuant to the Loan Documents or consented to by Lender; Amended and Restated Mortgage 42 Vista Breeze (v) the grant of an easement, servitude, or restrictive covenant if, before the grant, Lender determines that the easement, servitude, or restrictive covenant will not materially affect the operation or value of the Mortgaged Property or Lender’s interest in the Mortgaged Property, and Borrower pays to Lender, upon demand, all actual costs and expenses incurred by Lender in connection with reviewing Borrower’s request; provided, however, utility easements of a type usually permitted or required to operate a multifamily project in the Property Jurisdiction (such as, by way of example, gas, sewer and electricity supplier easements and easements to provide cable service) shall be deemed to be Permitted Transfers without the need for Lender’s prior review or determination so long as (A) such easement does not obligate Borrower to incur any additional costs, (B) such easement does not grant the grantee of the easement the option to acquire any other estate in the Mortgaged Property, and (C) Lender is not obligated to subordinate the lien of this Instrument to the proposed easement; (vi) the creation of a mechanic’s, materialman’s, or judgment lien against the Mortgaged Property which is released of record, bonded to the full satisfaction of Lender, or otherwise remedied to Lender’s satisfaction within 45 days after Borrower has actual or constructive notice of the existence of such lien; (vii) the conveyance of the Mortgaged Property at a judicial or non- judicial foreclosure sale under this Instrument; and (viii) the assignment of Managing General Partner’s Class B limited partner interest in the Borrower to Administrative General Partner pursuant to Section 7.1 of Borrower’s Agreement of Limited Partnership. (c) Lender shall consent to a Transfer that would otherwise violate this Section 21 if, prior to the Transfer, Borrower has satisfied each of the following requirements: (i) the submission to Lender of all information required by Lender to make the determination required by this Section 21(c); (ii) the absence of any Event of Default; (iii) the transferee meets all of the eligibility, credit, management and other standards (including any standards with respect to previous relationships between Lender and the transferee and the organization of the transferee) customarily applied by Lender at the time of the proposed Transfer to the approval of borrowers in connection with the origination or purchase of similar mortgage Amended and Restated Mortgage 43 Vista Breeze finance structures on similar multifamily properties, unless partially waived by Lender in exchange for such additional conditions as Lender may require; (iv) the Mortgaged Property, at the time of the proposed Transfer, meets all standards as to its physical condition that are customarily applied by Lender at the time of the proposed Transfer to the approval of properties in connection with the origination or purchase of similar mortgage finance structures on similar multifamily properties, unless partially waived by Lender in exchange for such additional conditions as Lender may require; (v) if the transferor or any other person has obligations under any Loan Document, the execution by the transferee or one or more individuals or entities acceptable to Lender of an assumption agreement that is acceptable to Lender and that, among other things, requires the transferee to perform all obligations of transferor or such person set forth in the Loan Documents, and may require that the transferee comply with any provisions of this Instrument or any other Loan Document which previously may have been waived by Lender; (vi) if a guaranty has been executed and delivered by the transferor in connection with the Note, this Instrument or any of the other Loan Documents, Borrower causes one or more individuals or entities acceptable to Lender to execute and deliver to Lender a substitute guaranty in a form acceptable to Lender; (vii) Lender’s receipt of all of the following: (A) a non-refundable review fee in the amount of $3,000, and a transfer fee equal to one percent (1%) of the outstanding Indebtedness immediately prior to the Transfer; and (B) Borrower’s reimbursement of all of Lender’s out-of-pocket costs (including, reasonable attorneys’ fees) incurred in reviewing the Transfer request, to the extent such expenses exceed $3,000; (viii) Borrower has agreed to Lender’s conditions to approve such Transfer, which may include, but are not limited to (A) providing additional collateral, guaranties, or other credit support to mitigate any risks concerning the proposed transferee or the performance or condition of the Mortgaged Property, and (B) amending the Loan Documents to (1) delete any specially negotiated terms or provisions previously granted for the exclusive benefit of transferor and (2) restore to original provisions of the standard Amended and Restated Mortgage 44 Vista Breeze Lender forms of multifamily loan documents, to the extent such provisions were previously modified; and (ix) Lender’s receipt of evidence of consent to the Transfer, to the extent required pursuant to the terms of the Regulatory Agreement. (d) For purposes of this Section, the following terms shall have the meanings set forth below: (i) A Transfer of a “Controlling Interest” shall mean: (A) with respect to any entity, the following: (1) if such entity is a general partnership or a joint venture, a Transfer of any general partnership interest or joint venture interest which would cause the Initial Owners to own less than a Controlling Percentage of all general partnership or joint venture interests in such entity; (2) if such entity is a limited partnership, (A) a Transfer of any general partnership interest, or (B) a Transfer of any partnership interests which would cause the Initial Owners to own less than a Controlling Percentage of all limited partnership interests in such entity; (3) if such entity is a limited liability company or a limited liability partnership, (A) a Transfer of any membership or other ownership interest which would cause the Initial Owners to own less than a Controlling Percentage of all membership or other ownership interests in such entity, (B) a Transfer of any membership, or other interest of a manager, in such entity that results in a change of manager, or (C) a change of the non-member manager; (4) if such entity is a corporation (other than a Publicly- Held Corporation) with only one class of voting stock, a Transfer of any voting stock which would cause the Initial Owners to own less than a Controlling Percentage of voting stock in such corporation; (5) if such entity is a corporation (other than a Publicly- Held Corporation) with more than one class of voting stock, a Transfer of any voting stock which would cause the Initial Owners to own less than a sufficient number of shares of voting stock having the power to elect the majority of directors of such corporation; and Amended and Restated Mortgage 45 Vista Breeze (6) if such entity is a trust (other than a Publicly-Held Trust), the removal, appointment or substitution of a trustee of such trust other than (A) in the case of a land trust, or (B) if the trustee of such trust after such removal, appointment, or substitution is a trustee identified in the trust agreement approved by Lender; and/or (B) any agreement (including provisions contained in the organizational and/or governing documents of Borrower or Guarantor) or Transfer not specified in clause (A), the effect of which, either immediately or after the passage of time or occurrence of a specified event or condition, including the failure of a specified event or condition to occur or be satisfied, would (i) cause a change in or replacement of the Person that controls the management and operations of the Borrower or Guarantor or (ii) limit or otherwise modify the extent of such Person’s control over the management and operations of Borrower or Guarantor. (ii) “Controlling Percentage” shall mean (i) greater than 50% of the ownership interests in an entity, or (ii) a percentage ownership interest in an entity of 50% or less if the owner(s) of that interest actually direct(s) the business and affairs of the entity without requirement of consent of any other party. (iii) “Publicly-Held Corporation” shall mean a corporation the outstanding voting stock of which is registered under Section 12(b) or 12(g) of the Securities and Exchange Act of 1934, as amended. (iv) “Publicly-Held Trust” shall mean a real estate investment trust the outstanding voting shares or beneficial interests of which are registered under Section 12(b) or 12(g) of the Securities Exchange Act of 1934, as amended. (e) Lender shall be provided with written notice of all Transfers under this Section 21, whether or not such Transfers are permitted under Section 21(b) or approved by Lender under Section 21(c), no later than 10 days prior to the date of the Transfer. 22. EVENTS OF DEFAULT. The occurrence of any one or more of the following shall constitute an Event of Default under this Instrument: (a) (i) any failure by Borrower to pay or deposit any payment of principal, interest, principal reserve fund deposit, any payment with a specified due date, or any other scheduled payment or deposit required by the Note, this Instrument or any other Loan Document when such payment or deposit is due or (ii) any failure by Borrower to pay or deposit any unscheduled payment or deposit, or other payment or deposit without Amended and Restated Mortgage 46 Vista Breeze a specified due date, required by the Note, this Instrument or any other Loan Document, within five (5) days after written notice from Lender; (b) any failure by Borrower to maintain the insurance coverage required by Section 19; (c) any failure by Borrower to comply with the provisions of Section 32; (d) fraud or material misrepresentation or material omission by Borrower or Guarantor, any of their respective officers, directors, trustees, general partners, managing members, managers, agents or representatives in connection with (i) the application for the Loan, (ii) any financial statement, rent roll, or other report or information provided to Lender during the term of the Indebtedness, or (iii) any request for Lender’s consent to any proposed action, including a request for disbursement of funds under any Collateral Agreement; (e) any of Borrower’s representations and warranties in this Instrument is false or misleading in any material respect; (f) any Event of Default under Section 21; (g) the commencement of a forfeiture action or proceeding, whether civil or criminal, which, in Lender’s judgment, could result in a forfeiture of the Mortgaged Property or otherwise materially impair the lien created by this Instrument or Lender’s interest in the Mortgaged Property; (h) any failure by Borrower to perform or comply with any of its obligations under this Instrument (other than those specified in this Section 22), as and when required, which continues for a period of thirty (30) days after written notice of such failure by Lender to Borrower; provided, however, if such failure is susceptible of cure but cannot reasonably be cured within such thirty (30) day period, and the Borrower shall have commenced to cure such failure within such thirty (30) day period and thereafter diligently and expeditiously proceeds to cure the same, such thirty (30) day period shall be extended for an additional period of time as is reasonably necessary for the Borrower in the exercise of due diligence to cure such failure, such additional period, not to exceed sixty (60) days. However, no such notice or grace period shall apply to the extent such failure could, in Lender’s judgment, absent immediate exercise by Lender of a right or remedy under this Instrument, result in harm to Lender, impairment of the Note or this Instrument or any other security given under any other Loan Document; (i) any failure by Borrower or any Guarantor to perform any of its obligations as and when required under any Loan Document other than this Instrument which continues beyond any applicable notice and cure periods, if any, specified in that Loan Document; (j) any exercise by the holder of any debt instrument secured by a mortgage, deed of trust or deed to secure debt on the Mortgaged Property of a right to declare all amounts due under that debt instrument immediately due and payable; Amended and Restated Mortgage 47 Vista Breeze (k) the occurrence of a Bankruptcy Event; (l) any Event of Default (as defined in any of the Loan Documents), which continues beyond the expiration of all applicable cure periods; (m) any breach of, or event of default by Borrower under, any other document or agreement relating to the Loan or the provision of low income housing tax credits to the Mortgaged Property to which Borrower is a party, which continues beyond the expiration of any applicable notice and cure period thereunder; (n) any failure by Borrower or the Project to qualify for low income housing tax credits pursuant to the provisions of Section 42 of the Internal Revenue Code; (o) Intentionally Omitted; (p) any amendment, modification, waiver or termination of any of the provisions of Borrower’s Organizational Documents without the prior written consent of Lender, other than (i) modifications necessary to reflect the occurrence of a Permitted Transfer or (ii) modifications that do not: (A) impose any additional or greater obligations on Borrower or any of the partners, managers or members of Borrower, (B) reduce or relieve Borrower or any of the partners, managers or members of Borrower of any of their obligations, (C) modify the timing, amounts, number, conditions or other terms of the installments or other payment obligations of the partners or members of Borrower or (D) impair the collateral for the Loan; provided, however, that Borrower shall promptly provide to Lender a copy of any modifications to Borrower’s Organizational Documents that do not require Lender’s consent; (q) (i) breach of any Material Property Agreement by Borrower or its officers, directors, employees, agents or tenants that continues beyond all applicable notice, grace, and cure periods; (ii) any failure by Borrower or its officers, directors, employees or agents to deliver concurrently (in case of notices given) or promptly (in case of notices received) copies of any and all notices received or given thereby to Lender with respect to any Material Property Agreement; or (iii) any breach of the representations, warranties, or covenants set forth in Section 6.1.15 of the Loan Covenant Agreement; (r) if Borrower or any Guarantor is a trust, the termination or revocation of any such trust; unless the trust is terminated as a result of the death of an individual trustor, in which event Lender must be notified and such Borrower or Guarantor must be replaced with an individual or entity acceptable to Lender, in accordance with the provisions of Section 21(c) hereof, within 90 days of such death (provided however that no property inspection shall be required and a 1% transfer fee will not be charged); or (s) if any Guarantor is a natural person, the death of such individual; unless the Lender is notified and such individual is replaced with an individual or entity acceptable to Lender, in accordance with the provisions of Section 21(c) hereof, within 90 days of such death (provided however that no property inspection shall be required and a 1% transfer fee will not be charged). Amended and Restated Mortgage 48 Vista Breeze 23. REMEDIES CUMULATIVE. Each right and remedy provided in this Instrument is distinct from all other rights or remedies under this Instrument or any other Loan Document or afforded by applicable law, and each shall be cumulative and may be exercised concurrently, independently, or successively, in any order. 24. FORBEARANCE. (a) Lender may (but shall not be obligated to) agree with Borrower, from time to time, and without giving notice to, or obtaining the consent of, or having any effect upon the obligations of, any guarantor or other third party obligor, to take any of the following actions: extend the time for payment of all or any part of the Indebtedness; reduce the payments due under this Instrument, the Note, or any other Loan Document; release anyone liable for the payment of any amounts under this Instrument, the Note, or any other Loan Document; accept a renewal of the Note; modify the terms and time of payment of the Indebtedness; join in any extension or subordination agreement; release any Mortgaged Property; take or release other or additional security; modify the rate of interest or period of amortization of the Note or change the amount of the monthly installments payable under the Note; and otherwise modify this Instrument, the Note, or any other Loan Document. (b) Any forbearance by Lender in exercising any right or remedy under the Note, this Instrument, or any other Loan Document or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any other right or remedy, or the subsequent exercise of any right or remedy. The acceptance by Lender of payment of all or any part of the Indebtedness after the due date of such payment, or in an amount which is less than the required payment, shall not be a waiver of Lender’s right to require prompt payment when due of all other payments on account of the Indebtedness or to exercise any remedies for any failure to make prompt payment. Enforcement by Lender of any security for the Indebtedness shall not constitute an election by Lender of remedies so as to preclude the exercise of any other right available to Lender. Lender’s receipt of any awards or proceeds under Sections 19 and 20 shall not operate to cure or waive any Event of Default. 25. WAIVER OF STATUTE OF LIMITATIONS. BORROWER HEREBY WAIVES THE RIGHT TO ASSERT ANY STATUTE OF LIMITATIONS AS A BAR TO THE ENFORCEMENT OF THE LIEN OF THIS INSTRUMENT OR TO ANY ACTION BROUGHT TO ENFORCE ANY LOAN DOCUMENT. 26. WAIVER OF MARSHALLING. Notwithstanding the existence of any other security interests in the Mortgaged Property held by Lender or by any other party, Lender shall have the right to determine the order in which any or all of the Mortgaged Property shall be subjected to the remedies provided in this Instrument, the Note, any other Loan Document or applicable law. Lender shall have the right to determine the order in which any or all portions of the Indebtedness are satisfied from the proceeds realized upon the exercise of such remedies. Borrower and any party who now or in the future acquires a security interest in the Mortgaged Property and who has actual or constructive notice of this Instrument waives any and all right to require the marshalling of assets or to require that any of the Mortgaged Property be sold in the Amended and Restated Mortgage 49 Vista Breeze inverse order of alienation or that any of the Mortgaged Property be sold in parcels or as an entirety in connection with the exercise of any of the remedies permitted by applicable law or provided in this Instrument. 27. FURTHER ASSURANCES. Borrower shall execute, acknowledge, and deliver, at its sole cost and expense, all further acts, deeds, conveyances, assignments, estoppel certificates, financing statements or amendments, transfers and assurances as Lender may require from time to time in order to better assure, grant, and convey to Lender the rights intended to be granted, now or in the future, to Lender under this Instrument and the Loan Documents. In furtherance thereof, on the request of Lender, Borrower shall re-execute or ratify any of the Loan Documents or execute any other documents or take such other actions as may be necessary to effect the assignment, pledge or other transfer of the Loan to any party that may purchase, insure, credit enhance or otherwise finance all or any part of the Loan, including, without limitation, any Credit Enhancer (including Freddie Mac or Fannie Mae), the U.S. Department of Housing and Urban Development, or any insurance company, conduit lender or any other lender or investor. Notwithstanding the foregoing sentence, in no event shall Borrower be required to execute and deliver any document or perform any act otherwise required pursuant to the foregoing sentence to the extent such document or act imposes a material additional obligation or liability on Borrower or materially adversely affects the rights of Borrower under any Loan Document. 28. ESTOPPEL CERTIFICATE. Within 10 days after a request from Lender, Borrower shall deliver to Lender a written statement, signed and acknowledged by Borrower, certifying to Lender or any person designated by Lender, as of the date of such statement, (i) that the Loan Documents are unmodified and in full force and effect (or, if there have been modifications, that the Loan Documents are in full force and effect as modified and setting forth such modifications); (ii) the unpaid principal balance of the Note; (iii) the date to which interest under the Note has been paid; (iv) that Borrower is not in default in paying the Indebtedness or in performing or observing any of the covenants or agreements contained in this Instrument or any of the other Loan Documents (or, if Borrower is in default, describing such default in reasonable detail); (v) whether or not there are then existing any setoffs or defenses known to Borrower against the enforcement of any right or remedy of Lender under the Loan Documents; and (vi) any additional facts requested by Lender. 29. GOVERNING LAW; CONSENT TO JURISDICTION AND VENUE. (a) This Instrument, and any Loan Document which does not itself expressly identify the law that is to apply to it, shall be governed by the laws of the Property Jurisdiction. (b) Borrower agrees that any controversy arising under or in relation to the Note, this Instrument, or any other Loan Document may be litigated in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have jurisdiction over all controversies that shall arise under or in relation to the Note, any security for the Indebtedness, or any other Loan Document. Borrower irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of Amended and Restated Mortgage 50 Vista Breeze domicile, habitual residence or otherwise. However, nothing in this Section 29 is intended to limit Lender’s right to bring any suit, action or proceeding relating to matters arising under this Instrument in any court of any other jurisdiction. 30. NOTICE. (a) All notices, demands and other communications (“notice”) under or concerning this Instrument shall be in writing and addressed as set forth below. Each notice shall be deemed given on the earliest to occur of (i) the date when the notice is received by the addressee; (ii) the first Business Day after the notice is delivered to a recognized overnight courier service, with arrangements made for payment of charges for next Business Day delivery; or (iii) the third Business Day after the notice is deposited in the United States mail with postage prepaid, certified mail, return receipt requested. If to Borrower: Vista Breeze, LTD. c/o Atlantic Pacific Communities 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor With a copy to: Klein Hornig LLP 1325 G Street NW, Suite 770 Washington, D.C. 20005 Attention: Chris Hornig, Esq. With a copy to: With a copy to: Vista Breeze HACMB, Inc. c/o Housing Authority of the City of Miami Beach 200 Alton Road Miami Beach, FL 33139 Attention: Miguell Del Campillo, Executive Director Phone: (305) 532-6401, ext. 3020 Email: miguell@hacmb.org Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 Pittsburgh, PA 15219 Attention: Michael H. Syme, Esq. Email: msyme@foxrothschild.com Phone: (412) 391-2450 Amended and Restated Mortgage 51 Vista Breeze If to Lender: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 With a copy to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 With a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291-5754 (b) Any party to this Instrument may change the address to which notices intended for it are to be directed by means of notice given to the other party in accordance with this Section 30. Each party agrees that it will not refuse or reject delivery of any notice given in accordance with this Section 30, that it will acknowledge, in writing, the receipt of any notice upon request by the other party and that any notice rejected or refused by it shall be deemed for purposes of this Section 30 to have been received by the rejecting party on the date so refused or rejected, as conclusively established by the records of the U.S. Postal Service or the courier service. (c) Any notice under the Note and any other Loan Document that does not specify how notices are to be given shall be given in accordance with this Section 30. 31. CHANGE IN SERVICER. If there is a change of the Servicer, Borrower will be given notice of the change. 32. SINGLE ASSET BORROWER. Until the Indebtedness is paid in full, Borrower (a) shall not acquire any real or personal property other than the Mortgaged Property and personal property related to the operation and maintenance of the Mortgaged Property; Amended and Restated Mortgage 52 Vista Breeze (b) shall not operate any business other than the management and operation of the Mortgaged Property; and (c) shall not maintain its assets in a way difficult to segregate and identify. 33. SUCCESSORS AND ASSIGNS BOUND. This Instrument shall bind, and the rights granted by this Instrument shall inure to, the successors and assigns of Lender and the permitted successors and assigns of Borrower. 34. JOINT AND SEVERAL LIABILITY. If more than one person or entity signs this Instrument as Borrower, the obligations of such persons and entities shall be joint and several. 35. RELATIONSHIP OF PARTIES; NO THIRD PARTY BENEFICIARY. (a) The relationship between Lender and Borrower shall be solely that of creditor and debtor, respectively, and nothing contained in this Instrument shall create any other relationship between Lender and Borrower. (b) No creditor of any party to this Instrument and no other person (other than a holder of the Note and Servicer) shall be a third party beneficiary of this Instrument or any other Loan Document. Without limiting the generality of the preceding sentence, (i) any arrangement (a “Servicing Arrangement”) between Lender and any Servicer for loss sharing or interim advancement of funds shall constitute a contractual obligation of such Servicer that is independent of the obligation of Borrower for the payment of the Indebtedness, (ii) Borrower shall not be a third party beneficiary of any Servicing Arrangement, and (iii) no payment by Servicer under any Servicing Arrangement will reduce the amount of the Indebtedness. 36. SEVERABILITY; AMENDMENTS. The invalidity or unenforceability of any provision of this Instrument shall not affect the validity or enforceability of any other provision, and all other provisions shall remain in full force and effect. This Instrument contains the entire agreement among the parties as to the rights granted and the obligations assumed in this Instrument. This Instrument may not be amended or modified except by a writing signed by the party against whom enforcement is sought; provided, however, that in the event of a Transfer (other than a Permitted Transfer), any or some or all of the Modifications to Instrument set forth in Exhibit B (if any) may be modified or rendered void by Lender at Lender’s option by notice to Borrower or such transferee. 37. CONSTRUCTION. The captions and headings of the sections of this Instrument are for convenience only and shall be disregarded in construing this Instrument. Any reference in this Instrument to an “Exhibit” or a “Section” shall, unless otherwise explicitly provided, be construed as referring, respectively, to an Exhibit attached to this Instrument or to a Section of this Instrument. All Exhibits attached to or referred to in this Instrument are incorporated by reference into this Instrument. Any reference in this Instrument to a statute or regulation shall be construed as referring to that statute or regulation as amended from time to time. Use of the singular in this Instrument includes the plural and use of the plural includes the singular. As used in this Instrument, the term “including” means “including, but not limited to.” Amended and Restated Mortgage 53 Vista Breeze 38. SERVICER. (a) Borrower further acknowledges that Lender may from time to time and in accordance with the terms of the Loan Agreement, appoint a Servicer or a replacement servicer to collect payments, escrows and deposits, to give and receive notices under the Note, this Instrument, or the other Loan Documents, and to otherwise service the Loan. Borrower hereby acknowledges and agrees that, unless Borrower receives written notice from Lender to the contrary, any action or right which shall or may be taken or exercised by Lender may be taken or exercised by Servicer with the same force and effect, including, without limitation, the collection of payments, the giving of notice, the holding of escrows, inspection of the Mortgaged Property, inspections of books and records, the request for documents or information, and the granting of consents and approvals. Borrower further agrees that, unless Lender instructs Borrower to the contrary in writing, (i) any notices, books or records, or other documents or information to be delivered under this Instrument, the Note, or any other Loan Document shall also be simultaneously delivered to the Servicer at the address provided for notices to Servicer pursuant to Section 30 hereof, and (ii) any payments to be made under the Note or for escrows under Section 7 of this Instrument or under any of the other Loan Documents shall be made to Servicer. In the event Borrower receives conflicting notices regarding the identity of the Servicer or any other subject, any such notice from Lender shall govern. (b) Borrower further acknowledges and agrees that, for the purpose of determining whether a security interest is created or perfected under the Uniform Commercial Code of the Property Jurisdiction, any escrows or other funds held by Servicer pursuant to the Loan Documents shall be deemed to be held by Lender. 39. DISCLOSURE OF INFORMATION. Lender may furnish information regarding Borrower or the Mortgaged Property to third parties with an existing or prospective interest in the servicing, enforcement, evaluation, performance, purchase or securitization of the Indebtedness, including but not limited to trustees, master servicers, special servicers, rating agencies, and organizations maintaining databases on the underwriting and performance of multifamily mortgage loans. Without limiting the generality of the foregoing, without notice to or the consent of Borrower, Lender may disclose to any title insurance company which insures any interest of Lender under this Instrument (whether as primary insurer, coinsurer or reinsurer) any information, data or material in its possession relating to Borrower, the Loan, the Improvements or the Mortgaged Property. Borrower irrevocably waives any and all rights it may have under applicable law to prohibit such disclosure, including but not limited to any right of privacy. Amended and Restated Mortgage 54 Vista Breeze 40. NO CHANGE IN FACTS OR CIRCUMSTANCES. Borrower warrants that all information in Borrower’s application for the Loan and in all financial statements, rent rolls, reports, certificates and other documents submitted in connection with Borrower’s application for the Loan are complete and accurate in all material respects. There has been no material adverse change in any fact or circumstance that would make any such information incomplete or inaccurate. 41. SUBROGATION. If, and to the extent that, the proceeds of the Loan are used to pay, satisfy or discharge any obligation of Borrower for the payment of money that is secured by a pre-existing mortgage, deed of trust or other lien encumbering the Mortgaged Property (a “Prior Lien”), such loan proceeds shall be deemed to have been advanced by Lender at Borrower’s request, and Lender shall automatically, and without further action on its part, be subrogated to the rights, including lien priority, of the owner or holder of the obligation secured by the Prior Lien, whether or not the Prior Lien is released. 42. FINANCING STATEMENT. As provided in Section 2, this Instrument constitutes a financing statement with respect to any part of the Mortgaged Property which is or may become a Fixture and for the purposes of such financing statement: (a) the Debtor shall be Borrower and the Secured Party shall be Lender; (b) the addresses of Borrower as Debtor and of Lender as Secured Party are as specified above in the first paragraph of this Instrument; (c) the name of the record owner is Borrower; (d) the types or items of collateral consist of any part of the Mortgaged Property which is or may become a Fixture; and (e) the organizational identification number of Borrower (if any) as Debtor is set forth on Exhibit C. 43. STATE SPECIFIC PROVISIONS (FLORIDA). (a) Principles of Construction. In the event of any inconsistencies between the terms and conditions of this Section 43 and the terms and conditions of this Security Document, the terms and conditions of this Section 43 shall control and be binding. (b) Copy of Instrument. Borrower acknowledges that Borrower has received a copy of this Instrument without charge. (c) Future Advances. This Instrument is intended to be and is a mortgage to secure the payment of such future or additional advances as may be made by Lender at its option to Borrower, or its successors in title, for any purpose, provided that all those advances are to be made within twenty (20) years from the date of this Instrument or within such lesser period of time as may be provided hereafter by law as a prerequisite for the sufficiency of actual notice or record notice of the optional future or additional advances as against the rights of creditors or subsequent purchasers for valuable consideration. The total amount of indebtedness secured by this Instrument may decrease or increase from time to time, but the total unpaid balance so secured at any one time shall not exceed twice the principal amount of the Note, plus interest that may have accrued thereon, together with any disbursements made for the payment of taxes, levies or insurance on the Mortgaged Property covered by the lien of this Instrument, including interest on all such disbursements. Nothing herein contained shall be deemed an obligation on the part of the Lender to make any future advances. Amended and Restated Mortgage 55 Vista Breeze (d) Assignment of Leases and Rents. The assignments of leases and rents contained in this Instrument are intended to provide Lender with all of the rights and remedies of mortgagees pursuant to Section 697.07 of the Florida Statutes (hereinafter “Section 697.07”), as may be amended from time to time. However, in no event shall this reference diminish, alter, impair, or affect any other rights and remedies of Lender, including but not limited to, the appointment of a receiver, nor shall any provision in this section diminish, alter, impair or affect any rights or powers of the receiver in law or equity or as set forth herein. In addition, this assignment shall be fully operative without regard to value of the Property or without regard to the adequacy of the Property to serve as security for the obligations owed by Borrower to Lender, and shall be in addition to any rights arising under Section 697.07. Further, except for the notices required hereunder, if any, Borrower hereby waives any notice of default or demand for turnover of rents by Lender, together with any rights under Section 697.07 to apply to a court to deposit the rents into the registry of the court or such other depository as the court may designate. 44. WAIVER OF TRIAL BY JURY. TO THE FULLEST EXTENT PERMITTED BY LAW, BORROWER AND LENDER EACH (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS INSTRUMENT OR THE RELATIONSHIP BETWEEN THE PARTIES AS BORROWER AND LENDER THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 45. ATTACHED EXHIBITS. The following Exhibits are attached to this Instrument and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A Description of the Land. Exhibit B Modifications to Instrument. Exhibit C Financing Statement Information. Exhibit D Modifications to Instrument (Ground Lease). Exhibit E Description of Ground Lease. The terms of this Instrument are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Instrument, the terms of said Exhibits shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Amended and Restated Mortgage Vista Breeze IN WITNESS WHEREOF, the undersigned has duly executed and delivered this Instrument or caused this Instrument to be duly executed and delivered by its authorized representative as of the date first set forth above. GRANTOR: VISTA BREEZE, LTD., a Florida limited partnership Witness: By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By:______________________________ Signature ________________________________ Printed Name By: By:______________________________ Name: Signature Title: _________________________________ Printed Name ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ______________, as _____________ of APC Vista Breeze, LLC, a Florida limited liability company, duly authorized signatory of Vista Breeze, Ltd., a Florida limited partnership. Said person is personally known to me or has produced a valid driver's license as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): Amended and Restated Mortgage A-1 Vista Breeze EXHIBIT A DESCRIPTION OF THE LAND That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. Amended and Restated Mortgage B-1 Vista Breeze EXHIBIT B MODIFICATIONS TO INSTRUMENT The following modifications are made to the text of the Instrument that precedes this Exhibit: 1. Section 21(a) of the Instrument is amended by adding the following at the end of such Section: “(xii) notwithstanding anything to the contrary herein or in Borrower’s Organizational Documents, a Transfer or pledge of a general partnership interest in Borrower or an interest in any general partner of Borrower to a 501(c)(3) nonprofit corporation, or a limited liability company whose sole member is a 501(c)(3) nonprofit corporation, without the prior written consent of Lender following full review and underwriting by Lender of the proposed transferee.” 2. Section 21(b) of the Instrument is amended by adding the following at the end of such Section: “(viii) Provided that (i) Borrower owns the Mortgaged Property and remains the borrower under the Note, (ii) APC Vista Breeze, LLC, a Florida limited liability company (“Managing General Partner”) is the managing general partner of Borrower or the Class B limited partner with irrevocable rights of control, (iii) Vista Breeze HACMB, Inc., a Florida not for profit corporation and tax-exempt entity pursuant to Section 501(c)(3) of the Internal Revenue Code (the “Administrative General Partner”) is the administrative general partner of Borrower and (iv) Bank of America, N.A., a national banking association, or its permitted transferee (the “Equity Investor”), has not less than a 99.99% limited partnership interest in Borrower: (A) the removal by Equity Investor of Managing General Partner as managing general partner of Borrower or removal by Equity Investor of Administrative General Partner as administrative general partner and replacement as managing general partner or administrative general partner, as applicable, by Banc of America CDC Special Holding Company, Inc., a North Carolina corporation (“Special Limited Partner”), or by a wholly-owned affiliate of Special Limited Partner, which removal shall be in accordance with the terms of the limited partnership agreement of Borrower, provided that (i) the entity replacing the removed Managing General Partner or Administrative General Partner must be the Special Limited Partner or a single purpose entity, (ii) after such replacement, Special Limited Partner or the Initial Owners of Special Limited Partner must own directly or indirectly not less than a Controlling Percentage of the general partnership interests, as applicable, in the entity which replaced the removed Managing General Partner or Administrative General Partner and (iii) each Amended and Restated Mortgage B-2 Vista Breeze Guarantor (if affiliated with the removed general partner) shall be replaced as Guarantor by an individual or entity that is approved by Lender and satisfies Lender’s mortgage credit standards for guarantors; or (B) For the sole purpose of effecting the initial sale of limited partnership interests to a purchaser of low income housing tax credits allocated to the Mortgaged Property in either a one or two- step transaction: (i) a Transfer of limited partnership interests of Equity Investor in Borrower to (A) a wholly-owned affiliate of Equity Investor or a wholly-owned affiliate of Special Limited Partner, or (B) an entity whose management is controlled by Equity Investor, by a wholly-owned affiliate of Equity Investor or by Special Limited Partner, or (ii) so long as Special Limited Partner remains the sole managing member, sole manager or sole general partner, as applicable, of Equity Investor, the transfer of non-managing membership interests or limited partnership interests, as applicable, in Equity Investor; (C) provided that Equity Investor has previously made all requisite capital contributions applicable to LIHTCs pursuant to the terms of the operating agreement of Borrower, a Transfer of membership interests of Equity Investor in Borrower to (1) any financial institution, corporation, financial service firm or insurance company that is investment grade (defined as BBB- or better rating by S&P or similar rating agency) or has net assets of $250,000,000 or more or is a wholly-owned subsidiary of such an entity, or (2) a syndicated tax credit fund whose manager has at least five (5) years of prior experience in tax credit funds which have totaled in the aggregate at least $50,000,000 in equity; provided, however, the transferee is not (and does not have a principal who is) (w) a person identified on the U.S Treasury Department Office of Foreign Assets Control (OFAC) List, (x) any other person or foreign country or agency thereof with whom a U.S. person may not conduct business or transactions by prohibition of Federal law or Executive Order of the President of the United States of America, and (y) is not a person that the Lender and/or Servicer is prohibited from doing business with in accordance with its customary business practices; provided, further, Lender shall be provided with advance written notice of any proposed Transfer permitted under this Section 21(b)(viii)(C) no later than 30 days before the date of the proposed Transfer. (ix) a Transfer of the interests of Equity Investor in Borrower to the Housing Authority of the City of Miami Beach (“HACMB”), Managing General Partner or the Administrative General Partner or to an Affiliate of HACMB, the Managing General Partner or the Administrative General Amended and Restated Mortgage B-3 Vista Breeze Partner at any time following the expiration of, for each building in the Project, the applicable credit period of ten (10) taxable years described in Code Section 42(f)(1), provided that at the time of such Transfer (A) Lender shall be provided with advance written notice of any proposed Transfer permitted under this Section 21(b)(ix) no later than 30 days before the date of the proposed Transfer, (B) the transferee, if other than the Managing General Partner or any Guarantor, shall be subject to the satisfactory completion by Lender of due diligence with respect to such transferee, including without limitation, financial, credit, U.S Treasury Department Office of Foreign Assets Control (OFAC), know-your- customer (KYC) and similar reviews, (C) no Event of Default shall have occurred and be continuing, and (D) Borrower shall pay to Lender a $10,000 transfer fee and the reasonable costs and expenses of Lender in connection with such Transfer, including reasonable legal fees. Borrower must provide Lender with: (i) advance written notice of the identity of any entity replacing the Managing General Partner or a Guarantor pursuant to this Section 21(b), and (ii) upon request by Lender from time to time, the names of all owners of interests in Borrower, whether such interests are owned directly or indirectly.” 3. Section 30(a) of the Instrument is amended to add the following at the end of such Paragraph: “Lender agrees that, so long as Equity Investor has a continuing ownership interest in Borrower, effective notice to Borrower under the Loan Documents shall require delivery of a copy of such notice to Equity Investor. Such notice shall be given in the manner provided in this Section 30(a), at Equity Investor’s address set forth below: Bank of America, N.A. MA5-100-04-11 100 Federal Street Boston, MA 02110 Attention: Tax Credit Asset Management – Vista Breeze With a copy to: Holland & Knight LLP 10 St. James Avenue, 11th Floor Boston, MA 02116 Attention: Sara C. Heskett, Esq. Lender agrees that, notwithstanding its rights to invoke the remedies permitted by Section 43 of this Instrument, upon the breach of any covenant or agreement by Borrower in this Instrument (including, but not limited to, the covenants to pay when due sums secured by this Instrument) or any other Loan Document, Lender shall not, so long as Equity Investor has a continuing ownership interest in Borrower, conduct a foreclosure sale of the Mortgaged Property or receive Amended and Restated Mortgage B-4 Vista Breeze a deed-in-lieu of foreclosure, until such time as Equity Investor has first been given 30 days written notice of such default and has failed, within such 30-day period to cure such default; provided, however, that Lender shall be entitled, during such 30-day period, to continue to accelerate the Note and to pursue its remedies. Any cure tendered by Equity Investor will be accepted or rejected on the same basis as cures tendered by Borrower.” 4. The following new Sections are added to the Instrument after the last numbered Section: “46. RECOURSE LIABILITY. So long as Equity Investor has a continuing ownership interest in Borrower, the provisions of Section 9 of the Note, as they relate to Events of Default described in Section 9(e) of the Note, shall be operative only after Equity Investor has been given thirty (30) days’ notice of the applicable Event(s) of Default described in Section 9(e) of the Note, together with an opportunity within such thirty (30) day period to remedy the applicable Event(s) of Default. In all events, Lender shall be entitled during such thirty (30) day period to exercise all of its rights and remedies under this Instrument upon the occurrence of such Event of Default other than foreclosure of the Mortgaged Property. 47. EXTENDED LOW-INCOME HOUSING COMMITMENT. Lender agrees that the lien of this Instrument shall be subordinate to any extended low-income housing commitment (as such term is defined in Section 42(h)(6)(B) of the Internal Revenue Code) (the “Extended Use Agreement”) recorded against the Mortgaged Property; provided that such Extended Use Agreement, by its terms, must terminate upon foreclosure under this Instrument or upon a transfer of the Mortgaged Property by instrument in lieu of foreclosure, in accordance with Section 42(h)(6)(E) of the Internal Revenue Code. 48. ANNUAL LIHTC REPORTING REQUIREMENTS. Borrower must submit to Lender each year at the time of annual submission of Borrower’s financial analysis of operations, a copy of the following sections of Borrower’s federal tax return: Internal Revenue Forms 1065, 8586, 8609 and Form 8609, Schedule A, which must reflect the total low-income housing tax credits (“LIHTCs”) allocated to the Mortgaged Property and the LIHTCs claimed for the Mortgaged Property in the preceding year. 49. CROSS-DEFAULT. Borrower acknowledges and agrees that (a) any failure by Borrower or the Project to qualify for low income housing tax credits pursuant to the provisions of Section 42 of the Internal Revenue Code and (b) any default, event of default, or breach (however such terms may be defined) after the expiration of any applicable notice and/or cure periods under the Extended Use Agreement shall be an Event of Default under this Instrument and that any costs, damages or other amounts, including reasonable attorney’s fees incurred by Lender as a result of such an Event of Default by Borrower, including amounts paid to cure any default or event of default, under the Extended Use Agreement shall be an obligation of Borrower and become a part of the Indebtedness secured by this Instrument. 50. ANNUAL COMPLIANCE. Borrower shall submit to Lender on an annual basis, evidence that the Mortgaged Property is in ongoing compliance with all income, occupancy and rent restrictions under the Extended Use Agreement relating to the Mortgaged Amended and Restated Mortgage B-5 Vista Breeze Property. Such submissions shall be made contemporaneously with Borrower’s reports required to be made to the regulator under the Extended Use Agreement. 51. TAX EXEMPTION OR ABATEMENT. (a) Borrower represents, warrants and covenants to Lender that the Mortgaged Property is eligible for and will receive a tax exemption or abatement (the “Tax Abatement”) for the exemption for property used by nonprofit homes for the aged under Section 196.1975 Florida Statutes (the “Program”). (b) Borrower must file or cause to be filed on a timely basis all documentation necessary to maintain the Tax Abatement. (c) Borrower must comply or cause compliance fully with all of the Program requirements in order to obtain and maintain the Tax Abatement. (d) Borrower shall promptly provide Lender with a copy of any notice Borrower may receive alleging that Borrower is in breach of the requirements of the Program or that the Mortgaged Property is not being maintained as required by the Program. (e) In any application for a Transfer of the Mortgaged Property, any interest in the Mortgaged Property or any interest in Borrower, Borrower shall notify Lender if the completion of such Transfer without the consent of the agency administering the Tax Abatement would result in the termination of the Tax Abatement. (f) Borrower shall avail itself of all rights and opportunities to renew or extend the Tax Abatement. (g) Borrower shall not voluntarily take or cause to be taken any action that would threaten the Tax Abatement or cause the Tax Abatement to terminate without the prior written consent of Lender. (h) Borrower represents and warrants that: (1) Borrower has not received any notice indicating that the Tax Abatement will be terminated or will not be obtained. (2) Borrower has adhered to any income, rent or other restrictions imposed by the Tax Abatement. (i) Each of the following shall constitute an Event of Default: (1) Any breach of any of the representations and warranties in Subsection (h). Amended and Restated Mortgage B-6 Vista Breeze (2) Any transfer of the Mortgaged Property, any interest in the Mortgaged Property, or any interest in Borrower that would cause the Tax Abatement to terminate. (j) In addition to the foregoing: (1) The Borrower shall notify Lender if it receives any notice indicating that the Tax Abatement will be terminated before its scheduled expiration date. (2) The Borrower shall notify Lender if a Transfer of the Mortgaged Property or any interest in Borrower would result in the termination of the Tax Abatement. 52. REGULATORY AGREEMENT. Notwithstanding anything in this Instrument to the contrary, the Lender hereby acknowledges and consents to the lien of the Regulatory Agreement and agrees that, irrespective of the order of recordation or date of effectiveness, the lien of this Instrument shall be subordinate to the Regulatory Agreement. Borrower acknowledges and agrees that any default, event of default, or breach (however such terms may be defined) after the expiration of any applicable notice and/or cure periods under the Regulatory Agreement shall be an Event of Default under this Instrument and that any costs, damages or other amounts, including reasonable attorney’s fees incurred by the Lender as a result of such an Event of Default by Borrower, including amounts paid to cure any default or event of default, under the Regulatory Agreement shall be an obligation of Borrower and become a part of the Indebtedness secured by this Instrument. 53. SECTION 8 HAP CONTRACT. (a) Borrower is a party to that certain Housing Assistance Payments Contract between Borrower and HACMB, dated as of [_] (as may be assigned, amended, and renewed to date, the “HAP Contract”), for the Mortgaged Property, which HAP Contract has been collaterally assigned by Borrower to Funding Lender pursuant to that certain Assignment of Housing Assistance Payments Agreement (the “Assignment of HAP Contract”), dated as of [_]. (b) Borrower represents that Borrower has at all times been and presently is in full compliance with the HAP Contract and that Borrower has not in the past defaulted and is presently not in default under the HAP Contract. (c) Borrower acknowledges and agrees that any default, event of default, or breach (however such terms may be defined) under the HAP Contract or the Assignment of HAP Contract shall be an Event of Default under this Instrument and that any costs, damages or other amounts, including reasonable attorneys’ fees incurred by Lender as a result of such an Event of Default by Borrower, including amounts paid to cure any default, event of default or breach under the HAP Contract or under the Assignment of HAP Contract, shall be an obligation of Borrower and become a part of the Indebtedness secured by this Instrument. Amended and Restated Mortgage B-7 Vista Breeze 54. AFFORDABILITY RESTRICTIONS. (a) Borrower shall not use the Mortgaged Property for any purpose other than Affordable Housing until the later of (i) the expiration of the term of the Affordability Restriction (as defined below) or (ii) 15 years from the date of this Instrument. (b) Borrower’s tenant selection procedure shall be conducted in accordance with all applicable state and federal laws including but not limited to fair housing laws, rules and regulations. If any Affordable Unit in the Mortgaged Property is occupied by a Qualifying Tenant(s) at the time of initial occupancy, and such Qualifying Tenant’s income should subsequently exceed 140 percent of the applicable income limit, Borrower shall, after such determination of income, rent the next available residential unit of comparable or smaller size in the Mortgaged Property to another Qualified Tenant. (c) A family, who, at the commencement of occupancy of a unit in the Mortgaged Property, was of low or moderate income, shall be treated as continuing to meet the low and moderate income requirement. (d) For purposes of this Section: “Affordable Housing” means a multifamily housing project in which 20 percent or more of the residential units are both rent-restricted and occupied by families whose incomes are 50 percent or less of the area median income as determined by the U.S. Department of Housing and Urban Development (“HUD”), with adjustments for household size, or in which 40 percent or more of the residential units are both rent- restricted and occupied by families whose incomes are 60 percent or less of the area median income as determined by the HUD Commissioner with adjustments for household size. A residential unit is rent-restricted if the Gross Rent with respect to such unit does not exceed 30 percent of the Imputed Income Limitation (as defined herein) applicable to such unit. “Affordability Restriction” means a contractual agreement or covenant prohibiting the use of the Mortgaged Property for any purpose other than Affordable Housing. “Affordable Units” means those units which are designated by Borrower for occupancy by Qualifying Tenants. “Gross Rent” means the rental charge for an Affordable Unit in the Mortgaged Property including any utility allowance determined by HUD in accordance with Section 8 of the United States Housing Act of 1937 (42 U.S.C. 1437f) (“Section 8”). Gross Rent does not include any subsidy payment under Section 8 or any comparable rental assistance program (with respect to such unit or the tenant(s) thereof), nor does it include any fee for a basis of the low income status of the tenant(s) of the unit by any governmental program of assistance (or by an organization described in Section 501(c)(3) and exempt from tax under Section 501(a) of the Code (26 U.S.C. 501(a)) if such Amended and Restated Mortgage B-8 Vista Breeze program (or organization) provides assistance for rent and the amount of assistance provided for rent is not separable from the amount of assistance provided for supportive services. Gross Rent does not include any rental payment to the owner of a unit if the owner pays an equivalent amount to the Farmers Home Administration under Section 515 of the Housing Act of 1949 (42 U.S.C. 1485). “Imputed Income Limitation” has the meaning as defined in Section 42(g)(2)(C) of the Code (26 U.S.C. 42(g)(2)(C). “Qualifying Tenant” means persons or family whose income at time of initial occupancy does not exceed 50 percent or 60 percent as applicable, of the area median income, as determined by HUD with adjustments for family size. 55. FAIR HOUSING; EQUAL OPPORTUNITY. Borrower shall: (a) comply with the provisions of Title VIII of the Civil Rights Act of 1968, as amended, and any regulations or administrative procedures issued pursuant thereto. These laws and regulations prohibit discrimination in the rental or financing of housing on the basis of race, color, national origin, religion (creed), or sex. Borrower agrees to administer the Property and related activities in a manner to affirmatively further fair housing. Borrower also agrees to comply with similar state and local fair housing laws and ordinances; and (b) comply with the provisions of Executive Order 11063 on Equal Opportunity in Housing and all regulations issued pursuant thereto. This order and related regulations prohibit discrimination on the basis of race, color, religion (creed), national origin, or sex in housing and related facilities provided through Federal financial assistance. 56. AFFORDABILITY RESTRICTION. The Affordability Restriction is incorporated into and made a part of this Instrument and a default under such Agreement shall constitute an Event of Default under this Instrument and Lender may exercise all of its rights under this Instrument. All capitalized terms used in this Exhibit not specifically defined herein shall have the meanings set forth in the text of the Instrument that precedes this Exhibit. Amended and Restated Mortgage Vista Breeze EXHIBIT C FINANCING STATEMENT INFORMATION 1. Name and Address of Debtor: Vista Breeze, Ltd. c/o Atlantic Pacific Communities 161 NW 6th Street Suite 1020 Miami, Florida 33136 2. Debtor’s State of Organization and Organizational I.D.#: State of Formation: Florida Type of Entity: limited partnership Organizational I.D.#: A20000000470 3. Name and Address of Secured Party: The Bank of New York Mellon Trust Company, N.A. 4655 Salisbury Road, Suite 300 Jacksonville, Florida 33256 4. The Collateral is: Fixtures (as that term is described in the Uniform Commercial Code of Florida) attached to the Land described in Exhibit A attached to this Instrument. 1 Vista Breeze EXHIBIT D MODIFICATIONS TO INSTRUMENT (Ground Lease) The following modifications are made to the text of the Instrument that precedes this Exhibit: 1. The granting clause on page 2 is deleted in its entirety and the following new granting clause is inserted in its place: “Granting Clause. Borrower, in consideration of the Indebtedness and the trust created by this Instrument, irrevocably grants, conveys and assigns to Lender, with power of sale, the Mortgaged Property, including the Leasehold Estate in the Land located in Miami-Dade County, Florida and described in Exhibit A attached to this Instrument, to have and to hold the Mortgaged Property unto Lender, Lender’s successor in trust and Lender’s assigns forever.” 2. The definition of Mortgaged Property in Section 1 is amended by deleting paragraph (i) and inserting the following new paragraph in its place: “(i) the Ground Lease and the Leasehold Estate;” 3. The definition of Mortgaged Property in Section 1 is amended by deleting the word “Land” from paragraph (viii) and inserting the words “Leasehold Estate” in its place. 4. Section 1 is amended by adding the following new definitions: “Event of Ground Lessor Bankruptcy” means either of the following actions taken by or with respect to Ground Lessor: (i) Ground Lessor pursuant to or within the meaning of the United States Bankruptcy Code (x) commences a voluntary case, or (y) consents to the entry of an order for relief against it in an involuntary case; or (ii) a court of competent jurisdiction enters an order or decree under the United States Bankruptcy Code that is for relief against Ground Lessor in an involuntary case. “Ground Lease” means the lease described in Exhibit E pursuant to which Borrower leases the Land, as such lease may from time to time be amended, modified, supplemented, renewed and extended. “Ground Lessee Default” means (i) a default by Borrower in making any payment of rent, additional rent or other sum of money payable by Borrower to Ground Lessor under the Ground Lease on the date such payment is due and payable, or (ii) a default by Borrower in performing or observing any of the terms, covenants or conditions of the Ground Lease (other than the payments referred to in clause (i)) required to be performed or observed by Ground Lessee. “Ground Lessor” means the lessor from time to time under the Ground Lease. “Ground Lessor Default” means a default by Ground Lessor in performing or observing any of the terms, covenants or conditions of the Ground Lease required to be performed or observed by Ground Lessor. 2 Vista Breeze “Ground Rent” means the base or minimum rent payable in fixed monthly or other periodic installments under the Ground Lease. “Leased Premises” means the Land and any other real property leased by Borrower pursuant to the Ground Lease. “Leasehold Estate” means Borrower’s interest in the Land and any other real property leased by Borrower pursuant to the Ground Lease, including (i) all rights of Borrower to renew or extend the term of the Ground Lease, (ii) all amounts deposited by Borrower with Ground Lessor under the Ground Lease, (iii) Borrower’s right or privilege to terminate, cancel, surrender, modify or amend the Ground Lease, and (iv) all other options, privileges and rights granted and demised to Borrower under the Ground Lease and all appurtenances with respect to the Ground Lease. 5. Section 22(d) is amended in its entirety to read as follows: “(d) fraud or material misrepresentation or material omission by Borrower or Guarantor, any of their respective officers, directors, trustees, general partners, managing members, managers, agents or representatives in connection with (i) the application for the Loan, (ii) any financial statement, rent roll, or other report or information provided to Lender during the term of the Indebtedness, (iii) any request for Lender’s consent to any proposed action, including a request for disbursement of funds under any Collateral Agreement or (iv) any of the representations and warranties contained in Section 53;” 6. Section 22 is amended by inserting the following new provision as additional subsection (t): “any failure by Borrower to comply with the provisions of Sections 57, 58, 59, 61, 62(b), 63(a) or 64;” 7. The following new Sections are added at the end of the Instrument after the last numbered Section: “57. REPRESENTATIONS AND WARRANTIES REGARDING GROUND LEASE. Borrower warrants and represents to Lender that, as of the date of this Instrument: (i) the Ground Lease is in full force and effect in accordance with its terms; (ii) Borrower has not waived, canceled or surrendered any of its rights under the Ground Lease; (iii) Borrower is the sole owner of the Leasehold Estate, without defect; (iv) the Leasehold Estate, the Leased Premises and the Mortgaged Property are free and clear of all liens, encumbrances and other matters affecting title, other than the lien of this Instrument and the Permitted Encumbrances; (v) there is no existing Ground Lessee Default and no event has occurred which, with the passage of time or the giving of notice, or both, would constitute a Ground Lessee Default; and (vi) to the best of Borrower’s knowledge, there is no existing Ground Lessor Default and no event has occurred which, with the passage of time or the giving of notice, or both, would constitute a Ground Lessor Default. 3 Vista Breeze 58. NOTICES UNDER GROUND LEASE. Borrower shall deliver to Lender, within ten (10) days after Borrower’s receipt, a true and correct copy of each notice, demand, complaint or request from Ground Lessor under, or with respect to, the Ground Lease. 59. BORROWER’S OBLIGATIONS TO COMPLY WITH GROUND LEASE. Borrower shall (i) pay the Ground Rent and all other sums of money due and payable at any time and from time to time under the Ground Lease as and when such sums become due and payable, but in any event before the expiration of any grace period provided in the Ground Lease for the payment of any such sum, and (ii) at all times fully perform, observe and comply with all other terms, covenants and conditions of the Ground Lease to be performed, observed or complied with by Borrower as lessee under the Ground Lease. If the Ground Lease does not provide for a grace period for the payment of a sum of money, Borrower shall make the payment on or before the date on which the payment becomes due and payable. Borrower shall deliver evidence of the payment to Lender within ten (10) days after receipt of a written request from Lender for evidence of the payment. 60. LENDER’S RIGHT TO CURE GROUND LESSEE DEFAULTS. At any time after Lender receives notice of a Ground Lessee Default, (i) Lender may (but shall not be obligated to do so), make any payment, perform any obligation and take any other action Borrower would have the right to pay, perform or take under the Ground Lease which Lender deems necessary or desirable to cure the Ground Lessee Default, and (ii) Lender and its authorized agents shall have the right at any time or from time to time to enter the Land and Improvements, or any part thereof, to such extent and as often as Lender, in its discretion, deems necessary or desirable in order to cure the Ground Lessee Default, subject to the rights of the tenants and occupants of the Mortgaged Property. Lender may exercise its rights under this Section immediately after receipt of notice of a Ground Lessee Default and after the expiration of any grace period provided to Borrower in the Ground Lease to cure the Ground Lessee Default. For purposes of exercising its rights under this Section, Lender shall be fully protected for any action taken or omitted to be taken by Lender, in good faith, in reliance on any written notice from Ground Lessor stating that a Ground Lessee Default has occurred and is continuing even though Borrower may question or deny the existence or nature of the Ground Lessee Default. All actual expenditures made by Lender pursuant to this Section to cure a Ground Lessee Default shall become an additional part of the Indebtedness as provided in Section 12. 61. COVENANTS TO PROTECT LEASEHOLD ESTATE. Borrower shall not, without the written consent of Lender (which may be given or withheld by Lender in its discretion), (i) surrender the Leasehold Estate to Ground Lessor or terminate or cancel the Ground Lease, (ii) amend, modify or change the Ground Lease, either orally or in writing, or waive any of Borrower’s rights under the Ground Lease, (iii) subordinate the Ground Lease or the Leasehold Estate to any mortgage, deed of trust or other lien on Ground Lessor’s fee title to the Leased Premises, or (iv) except as otherwise provided in Section 58(b), reject or assume the Ground Lease or assign the Leasehold Estate pursuant to Section 365(h) of the United States Bankruptcy Code. Borrower absolutely and unconditionally transfers and assigns to Lender all of Borrower’s rights to surrender, terminate, cancel, modify and change the Ground Lease, and any such surrender, termination, cancellation, modification or change made without the prior written consent of Lender shall be void and have no legal effect. 4 Vista Breeze 62. GROUND LESSEE’S BANKRUPTCY. (a) Borrower assigns to Lender, as additional security for the Indebtedness, Borrower’s right to reject the Ground Lease under Section 365 of the United States Bankruptcy Code after the occurrence of a Bankruptcy Event, subject to Section 58(b). (b) If, after the occurrence of a Bankruptcy Event, Borrower decides to reject the Ground Lease, Borrower shall give Lender written notice, at least ten (10) days in advance, of the date on which Borrower intends to apply to the Bankruptcy Court for authority and permission to reject the Ground Lease. Lender shall have the right, but not the obligation, within ten (10) days after receipt of Borrower’s notice, to deliver to Borrower a notice (“Lender’s Assumption Notice”) in which (i) Lender demands that Borrower assume the Ground Lease and assign the Ground Lease to Lender, or its designee, in accordance with the United States Bankruptcy Code, and (ii) Lender agrees to cure or provide adequate assurance of prompt cure of all Ground Lessee Defaults reasonably susceptible of being cured by Lender and of future performance under the Ground Lease. If Lender timely delivers Lender’s Assumption Notice to Borrower, Borrower shall not reject the Ground Lease and shall, within fifteen (15) days after receipt of Lender’s notice, comply with the demand contained in clause (i) of Lender’s notice. If Lender does not timely deliver Lender’s Assumption Notice to Borrower, Borrower shall have the right to reject the Ground Lease. 63. GROUND LESSOR’S BANKRUPTCY. (a) If, after the occurrence of an Event of Ground Lessor Bankruptcy, Ground Lessor rejects the Ground Lease pursuant to Section 365(h) of the United States Bankruptcy Code (i) Borrower, immediately after obtaining notice of the rejection, shall deliver a copy of the notice to Lender, (ii) Borrower shall not, without Lender’s prior written consent (which may be given or withheld in Lender’s discretion), elect to treat the Ground Lease as terminated pursuant to Section 365(h) or any other applicable provision of the United States Bankruptcy Code, and (iii) this Instrument and the lien created by this Instrument shall extend to and encumber Borrower’s retained rights under the Ground Lease that are appurtenant to the Leased Premises for the balance of the term of the Ground Lease and for any renewal or extension of those rights under the Ground Lease. Borrower transfers and assigns to Lender, as additional security for the Indebtedness, Borrower’s rights, after Ground Lessor’s rejection of the Ground Lease, to treat the Ground Lease as terminated, and any termination of the Ground Lease made by Borrower without Lender’s prior written consent shall be void and have no legal effect. (b) Borrower transfers and assigns to Lender, as additional security for the Indebtedness, all of Borrower’s rights to damages caused by Ground Lessor’s rejection of the Ground Lease after the occurrence of an Event of Ground Lessor Bankruptcy and all of Borrower’s rights to offset such damages against rent payable under the Ground Lease. As long as no Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Lender agrees that it will not enforce its rights under the preceding sentence, but will permit Borrower to exercise such rights with Lender’s prior written consent. Any amounts received by Lender as damages arising out of Ground Lessor’s rejection of the Ground Lease shall be applied in the manner set forth in Section 9. 5 Vista Breeze 64. OPTION TO RENEW OR EXTEND GROUND LEASE. Borrower shall give Lender written notice of Borrower’s intention to exercise each option to renew or extend the term of the Ground Lease at least ninety (90) days, but not more than one hundred fifty (150) days, before the last day on which the option may be timely exercised. If Borrower intends to renew or extend the term of the Ground Lease, it shall deliver to Lender, together with the notice of such decision, a copy of the notice of renewal or extension it delivers to Ground Lessor. If Borrower does not intend to renew or extend the term of the Ground Lease or, if Borrower fails to deliver its written notice of exercise of its option to renew or extend the term of the Ground Lease at least ninety (90) days before the last day on which the option may be timely exercised, Lender shall have the right, but shall not be obligated, to renew or extend the term of the Ground Lease for and on behalf of Borrower. 65. NO MERGER OF ESTATES. If Borrower acquires the fee estate of Ground Lessor under the Ground Lease (the “Fee Estate”) (i) there shall be no merger between the Fee Estate and the Leasehold Estate unless all persons, including Lender, having an interest in the Ground Lease consent in writing to the merger, and (ii) simultaneously with Borrower’s acquisition of the Fee Estate, the lien of this Instrument shall automatically, without the necessity of any further conveyance, be spread to cover the Fee Estate and as so spread shall be prior to the lien of any mortgage, deed of trust or other lien placed on the Fee Estate after the date of this Instrument. Promptly after Borrower’s acquisition of the Fee Estate, Borrower, at its sole cost and expense, including payment of Lender’s actual attorneys’ fees and out-of-pocket disbursements, shall execute and deliver all documents and instruments necessary to subject the Fee Estate to the lien of this Instrument, and shall provide to Lender a title insurance policy insuring the lien of this Instrument as a first lien on the Fee Estate and the Leasehold Estate. If Lender acquires the Fee Estate and the Leasehold Estate (whether pursuant to the provisions of the Ground Lease, by foreclosure of this Instrument, or otherwise), the Fee Estate and the Leasehold Estate shall not merge as a result of such acquisition and shall remain separate and distinct for all purposes after such acquisition unless and until Lender shall elect to merge the Fee Estate and the Leasehold Estate. 66. NEW LEASE. If (i) the Ground Lease is canceled or terminated for any reason before the natural expiration of its term, and (ii) Lender (or its designee) obtains from Ground Lessor a new lease in accordance with the term of the Ground Lease, Borrower shall have no right, title or interest in and to the new lease or the leasehold estate created by the new lease. 67. APPOINTMENT OF LENDER AS BORROWER’S ATTORNEY-IN-FACT. Borrower makes, constitutes and appoints Lender as Borrower’s attorney-in-fact, in Borrower’s name, place and stead, with full power of substitution, to take all actions and to sign all documents and instruments which Lender, in its discretion, considers to be necessary or desirable to (i) prevent or cure a Ground Lessee Default pursuant to Section 56, (ii) perform or carry out any of Borrower’s covenants under Section 55, (iii) renew or extend the term of the Ground Lease pursuant to Section 60, (iv) appoint arbitrators and conduct arbitration proceedings pursuant to the Ground Lease, and (v) request and obtain estoppel certificates from Ground Lessor pursuant to the Ground Lease. Borrower gives and grants to Lender, as Borrower’s attorney-in-fact, full power and authority to do and perform every act and sign every document and instrument necessary and proper to be done in the exercise of the foregoing power as fully as Borrower might or could do, and Borrower hereby ratifies and confirms all acts that Lender, as 6 Vista Breeze Borrower’s attorney-in-fact, shall lawfully do or cause to be done by virtue of this power of attorney. This power of attorney, being coupled with an interest, shall be irrevocable as long as any of the Indebtedness remains unpaid.” All capitalized terms used in this Exhibit not specifically defined herein shall have the meanings set forth in the text of the Instrument that precedes this Exhibit. 1 Vista Breeze EXHIBIT E DESCRIPTION OF GROUND LEASE Second Amended and Restated Ground Lease, between Housing Authority of the City of Miami Beach, as Landlord, and Vista Breeze, Ltd., as Tenant, dated as of December 15, 2023. 4860-1147-8922v.4 D Forward Purchase Agreement Vista Breeze EXHIBIT D-5 TO FORWARD PURCHASE AGREEMENT FORM OF ASSIGNMENT OF MORTGAGE AND LOAN DOCUMENTS [See attached] EXHIBIT D-5 TO FORWARD PURCHASE AGREEMENT FORM OF ASSIGNMENT OF MORTGAGE AND LOAN DOCUMENTS WHEN RECORDED MAIL TO: Citibank, N.A. Transaction and Asset Management Group/Post Closing Citi Community Capital 3800 Citibank Center Tampa, Florida 33610 Re: Vista Breeze Deal ID No. 60001596 ASSIGNMENT OF MORTGAGE AND LOAN DOCUMENTS KNOW ALL PERSONS BY THESE PRESENTS: HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, a public body corporate and politic organized and existing under the laws of the State of Florida (“Assignor”), pursuant to that certain Amended and Restated Funding Loan Agreement, dated as of [Month] [Day], 20[_] (“Funding Loan Agreement”), by and among Assignor, THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., a national banking association, as Fiscal Agent (“Assignee”), and CITIBANK, N.A., a national banking association (“Funding Lender”), for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, does by these presents assign to Assignee, for the benefit of Funding Lender, without recourse, all of Assignor’s right, title and interest in and to, subject to the Unassigned Rights (as defined in the Funding Loan Agreement), the instruments (“Assigned Instruments”) described on Schedule 1 attached hereto. TOGETHER with the Note described in the Assigned Instruments, and the money due and to become due thereon, with the interest thereon, TO HAVE AND TO HOLD the same unto the said Assignee forever, subject only to all the provisions contained therein, AND the said Assignor hereby constitutes and appoints the Assignee as the Assignor’s true and lawful attorney, irrevocable in law or in equity, in the Assignor’s name, place and stead, but at Assignee’s cost and expense, to have, use and take all lawful ways and means for the recovery of all of the said money and interest; and in case of payment, to discharge the same as fully as the Assignor might or could if these presents were not made. Overriding Limitations. In no event shall Assignor: (i) prosecute its action to a lien on the Project, as defined in that certain Amended and Restated Borrower Loan Agreement, by and between Vista Breeze, Ltd., a Florida limited partnership (“Borrower”), and Assignor (the “Borrower Loan Agreement”); or Assignment of Mortgage 2 Vista Breeze (ii) take any action which may have the effect, directly or indirectly, of impairing the ability of Borrower to timely pay the principal of, interest on, or other amounts due under, the Borrower Loan or of causing Borrower to file a petition seeking reorganization, arrangement, adjustment or composition of or in respect of Borrower under any applicable liquidation, insolvency, bankruptcy, rehabilitation, composition, reorganization, conservation or other similar law in effect now or in the future; or (iii) interfere with the exercise by Assignee or Servicer of any of their rights under the Borrower Loan Documents upon the occurrence of an event of default by Borrower under and as defined in the Borrower Loan Documents; or (iv) take any action to accelerate or otherwise enforce payment or seek other remedies with respect to the Borrower Loan. Definitions. All capitalized terms that are used and are not defined herein shall have the respective meanings ascribed to them in the Borrower Loan Agreement. In all references herein to any parties, persons, entities or corporations the use of any particular gender on the plural or singular number is intended to include the appropriate gender or number as the text of the within instrument may require. Dated as of the 1st day of [Month], 202[_] (the foregoing date is for reference purposes only and this Assignment shall not be effective until the Closing Date, as defined in the Borrower Loan Agreement). [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Assignment of Mortgage N-1 Vista Breeze IN WITNESS WHEREOF, the undersigned has duly executed and delivered this Assignment of Mortgage and Loan Documents or caused this Assignment of Mortgage and Loan Documents to be duly executed and delivered by its authorized representative as of the date first set forth above. ASSIGNOR: HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, a public body corporate and politic organized and existing under the laws of the State of Florida Witness: By: ______________________________ By: __________________________ Print Name: ________________________ Name: Title: By: _______________________________ Print Name: ________________________ ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ________________, as ____________ of Housing Finance Authority of Miami-Dade County, Florida. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): Assignment of Mortgage Sch. 1-1 Vista Breeze SCHEDULE 1 TO ASSIGNMENT OF MORTGAGE AND LOAN DOCUMENTS ASSIGNEE: The Bank of New York Mellon Trust Company, N.A. 4655 Salisbury Road, Suite 300 Jacksonville, Florida 33256 ASSIGNED INSTRUMENTS: 1. Amended and Restated Multifamily Note by Vista Breeze, Ltd., a Florida limited partnership (“Borrower”), to Assignor, dated as of [_] [_], 20[_], in the original principal amount of up to [$11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT]. 2. Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof, executed by Borrower for the benefit of Assignor securing the principal amount of up to [$11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN-OUT], which is being recorded immediately prior hereto in the Recorder’s Office of Miami-Dade County, Florida, and encumbers the real property (and improvements thereon) that is more particularly described on Exhibit A. Assignment of Mortgage A-1 Vista Breeze EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. 4891-6500-5706 D Forward Purchase Agreement Vista Breeze EXHIBIT D-6 TO FORWARD PURCHASE AGREEMENT FORM OF EXCEPTIONS TO NON-RECOURSE GUARANTY [See attached] EXHIBIT D-6 TO FORWARD PURCHASE AGREEMENT FORM OF EXCEPTIONS TO NON-RECOURSE GUARANTY This EXCEPTIONS TO NON-RECOURSE GUARANTY (this “Guaranty”) is entered into as of the [___] day of [Month], 202[_], by HOWARD D. COHEN REVOCABLE TRUST U/A/D/ 4/6/1993 (the “Guarantor”), for the benefit of Beneficiary Parties (as defined below). The date of this Guaranty as set forth above is for reference purposes only, and this Guaranty will not be effective and binding until the Closing Date (as defined in the Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Vista Breeze, Ltd., a Florida limited partnership (“Borrower”), Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December Exceptions to Non-Recourse Guaranty 2 Vista Breeze 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Citibank, N.A., a national banking association (“Funding Lender”) entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Funding Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, Funding Lender has acquired the Funding Loan from the Original Funding Lender, and in connection therewith, (i) Funding Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement dated as of the date hereof (the “Funding Loan Agreement”) by and among Governmental Lender, Fiscal Agent, and Funding Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement dated as of the date hereof (the “Borrower Loan Agreement”) which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [Month] [Day], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN-OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Funding Lender and Borrower have entered into a certain Loan Covenant Agreement and dated as of the date hereof (the “Loan Covenant Agreement”; together with the Borrower Note, the Security Instrument, the Borrower Loan Agreement and all other documents executed in connection with the Borrower Loan, including this Agreement, the “Borrower Loan Documents”). I. The term “Beneficiary Parties” as used herein shall mean Governmental Lender, Funding Lender, any Servicer and their respective successors and assigns. The term “Beneficiary Parties” shall also include any lawful owner, holder or pledgee of the Borrower Note. J. As a condition to the purchase of the Funding Loan by Funding Lender, Beneficiary Parties require that Guarantor execute this Guaranty. K. Guarantor will directly or indirectly derive a material financial benefit from the Funding Loan, the Borrower Loan and the purchase of the Funding Loan by Funding Lender. Exceptions to Non-Recourse Guaranty 3 Vista Breeze NOW, THEREFORE, in consideration of the Funding Loan, the Borrower Loan and the purchase of the Funding Loan by Funding Lender, and in order to induce Beneficiary Parties to consummate said transactions, Guarantor agrees as follows: 1. Defined Terms. Capitalized terms used but not defined in this Guaranty shall have the meanings assigned to them in the Security Instrument. 2. Scope of Guaranty. Guarantor represents to Beneficiary Parties that Guarantor has a direct or indirect ownership interest in Borrower and/or will otherwise derive a material financial benefit from the continuation of the Borrower Loan and the acquisition by the Funding Lender of the Funding Loan. Guarantor hereby does jointly, severally and unconditionally guaranty to Beneficiary Parties the full and prompt payment when due, whether at maturity or earlier, by reason of acceleration or otherwise, and at all times thereafter, and the full and prompt performance when due, of all of the following (collectively, the “Guaranteed Obligations”): (a) All amounts for which Borrower is personally liable under the Borrower Note, including, without limitation, all amounts under Section 9 of the Borrower Note. (b) All costs and expenses, including out of pocket expenses and reasonable fees of attorneys and expert witnesses, incurred by Beneficiary Parties in enforcing their rights under this Guaranty. (c) All school and/or road impact fees incurred by Borrower and assessed pursuant to Chapter 33 of the Code of Miami-Dade County, Florida, as a result of any act or omission by or on behalf of Borrower. For purposes of determining Guarantor’s liability under this Guaranty, all payments made by Borrower with respect to the Indebtedness and all amounts received by Beneficiary Parties from the enforcement of their rights under the Security Instrument or the other Borrower Loan Documents (other than this Guaranty) shall be applied first to the portion of the Indebtedness for which neither Borrower nor Guarantor has personal liability. 3. Guarantor’s Obligations Survive Foreclosure. The obligations of Guarantor under this Guaranty shall survive any foreclosure proceeding, any foreclosure sale, any delivery of any deed in lieu of foreclosure, and any release of record of the Security Instrument or the other Borrower Loan Documents. 4. Guaranty of Payment and Performance. Guarantor’s obligations under this Guaranty constitute an unconditional and continuing guaranty of payment and performance and not merely a guaranty of collection. Guarantor hereby irrevocably and unconditionally covenants and agrees that Guarantor is liable for the Guaranteed Obligations as a primary obligor. The Guaranteed Obligations and this Guaranty are separate, distinct and in addition to any liability and/or obligations that Borrower or Guarantor may have under any other guaranty or indemnity executed by Borrower or Guarantor in connection with the Borrower Loan, and no other agreement, guaranty or indemnity executed in connection with the Borrower Loan shall act to reduce or set off any of Guarantor’s liability hereunder. Exceptions to Non-Recourse Guaranty 4 Vista Breeze 5. Unconditional Guaranty. The obligations of Guarantor under this Guaranty shall be performed without demand by Beneficiary Parties and shall be unconditional irrespective of the genuineness, validity, regularity or enforceability, in whole or in part, of the Guaranteed Obligations, the Borrower Note, the Security Instrument or any other Borrower Loan Document, and without regard to any other circumstance which might otherwise constitute a legal or equitable discharge of a surety, a guarantor, a borrower or a mortgagor. Guarantor hereby waives the benefit of all principles or provisions of law, statutory or otherwise, which are or might be in conflict with the terms of this Guaranty and agrees that Guarantor’s obligations shall not be affected by any circumstances, whether or not referred to in this Guaranty, which might otherwise constitute a legal or equitable discharge of a surety, a guarantor, a borrower or a mortgagor. Guarantor hereby waives the benefits of any right of discharge under any and all statutes or other laws relating to a guarantor, a surety, a borrower or a mortgagor, and any other rights of a guarantor, a surety, a borrower or a mortgagor, thereunder. Without limiting the generality of the foregoing, Guarantor hereby waives, to the fullest extent permitted by law, diligence in collecting the Indebtedness, presentment, demand for payment, protest, all notices with respect to the Borrower Note and this Guaranty which may be required by statute, rule of law or otherwise to preserve Beneficiary Parties’ rights against Guarantor under this Guaranty, including, but not limited to, notice of acceptance, notice of any amendment of the Borrower Loan Documents, notice of the occurrence of any default or Event of Default, notice of intent to accelerate, notice of acceleration, notice of dishonor, notice of foreclosure, notice of protest, and notice of the incurring by Borrower of any obligation or indebtedness. Guarantor also waives, to the fullest extent permitted by law, all rights to require Beneficiary Parties to (a) proceed against Borrower or any other guarantor of Borrower’s payment or performance with respect to the Indebtedness (an “Other Guarantor”), (b) if Borrower or any Other Guarantor is a partnership, proceed against any general partner of Borrower or the Other Guarantor, (c) proceed against or exhaust any collateral held by Beneficiary Parties to secure the repayment of the Indebtedness, (d) pursue any other remedy it may now or hereafter have against Borrower, or, if Borrower is a partnership, any general partner of Borrower or (e) record the Security Instrument or to file any financing statement or to otherwise enforce, perfect, protect, secure or insure any lien or security interest given as security in connection with the Security Documents. Guarantor further waives, to the fullest extent permitted by applicable law, (a) any right to revoke this Guaranty as to any future advances under the Security Instrument or the other Borrower Loan Documents, (b) any defenses that could arise with respect to an amendment or modification of the Guaranteed Obligations by operation of law, action of any court or the amendment of any of the Borrower Loan Documents, (c) any defense that Beneficiary Parties have waived any Guaranteed Obligation by failing to enforce any right or remedy hereunder, or to promptly enforce any such right or remedy and (d) any other event or circumstance that may constitute a defense of Borrower or Guarantor to payment of the Guaranteed Obligations. 6. Modification of Borrower Loan Documents. At any time or from time to time and any number of times, without notice to Guarantor and without affecting the liability of Guarantor, (a) the time for payment of the principal of or interest on the Indebtedness may be extended or the Indebtedness may be renewed in whole or in part; (b) the time for Borrower’s performance of or compliance with any covenant or agreement contained in the Borrower Note, the Security Instrument or any other Borrower Loan Document, whether presently existing or hereinafter entered into, may be extended or such performance or compliance may be waived; (c) the maturity of the Indebtedness may be accelerated as provided in the Borrower Note, the Exceptions to Non-Recourse Guaranty 5 Vista Breeze Security Instrument, or any other Borrower Loan Document; (d) the Borrower Note, the Security Instrument, or any other Borrower Loan Document may be modified or amended by Beneficiary Parties and Borrower in any respect, including, but not limited to, an increase in the principal amount; and (e) any security for the Indebtedness may be modified, exchanged, surrendered or otherwise dealt with or additional security may be pledged or mortgaged for the Indebtedness and the Guaranteed Obligations. 7. Joint and Several Liability. If more than one person executes this Guaranty, the obligations of those persons under this Guaranty and any Other Guarantor shall be joint and several. Beneficiary Parties, in their sole and absolute discretion, may (a) bring suit against Guarantor, or any one or more of the persons constituting Guarantor, and any Other Guarantor, jointly and severally, or against any one or more of them; (b) compromise or settle with any one or more of the persons constituting Guarantor or any Other Guarantor for such consideration as Beneficiary Parties may deem proper; (c) release one or more of the persons constituting Guarantor, or any Other Guarantor, from liability; and/or (d) otherwise deal with Guarantor and any Other Guarantor, or any one or more of them, in any manner, and no such action shall impair the rights of Beneficiary Parties to collect from Guarantor any amount guaranteed by Guarantor under this Guaranty. Nothing contained in this paragraph shall in any way affect or impair the rights or obligations of Guarantor with respect to any Other Guarantor. 8. Subordination of Borrower’s Indebtedness to Guarantor. Any indebtedness of Borrower held by Guarantor now or in the future is and shall be subordinated to the Indebtedness of Borrower to Beneficiary Parties under the Borrower Loan Documents. After the occurrence and during the continuance of an Event of Default or the occurrence and during the continuance of an event which would, with the giving of notice or the passage of time, or both, constitute an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Guarantor shall not receive or collect, directly or indirectly, from Borrower or any other party any amount of such indebtedness until the Guaranteed Obligations are paid in full. To the extent that Guarantor receives payment of any of the indebtedness of Borrower in violation of the preceding sentence, the same shall be collected, enforced and received by Guarantor, as trustee for Beneficiary Parties, but without reducing or affecting in any manner the liability of Guarantor under the other provisions of this Guaranty. 9. Waiver of Subrogation. Guarantor agrees to withhold the exercise of any and all subrogation and reimbursement rights against Borrower, against any other person, and against any collateral or security for the Indebtedness and Guarantor shall have no right of, and hereby waives any claim for, subrogation or reimbursement against Borrower or any managing member or general partner of Borrower by reason of any payment by Guarantor under this Guaranty, whether such right or claim arises at law or in equity or under any contract or statute, until (i) the Indebtedness has been indefeasibly paid and satisfied in full, (ii) all obligations owed to Beneficiary Parties under the Borrower Loan Documents have been fully performed, (iii) there has expired the maximum possible period thereafter during which any payment made by Borrower to Beneficiary Parties with respect to the Indebtedness, could be deemed a preference under the United States Bankruptcy Code and (iv) each of Beneficiary Parties has released, transferred or disposed of all its right, title and interest in such collateral or security. Exceptions to Non-Recourse Guaranty 6 Vista Breeze 10. Preference. If any payment by Borrower is held to constitute a preference under any applicable bankruptcy, insolvency, or similar laws, or if for any other reason any of Beneficiary Parties is required to refund any sums to Borrower, such refund shall not constitute a release of any liability of Guarantor under this Guaranty. It is the intention of Beneficiary Parties and Guarantor that Guarantor’s obligations under this Guaranty shall not be discharged except by Guarantor’s performance of such obligations and then only to the extent of such performance. 11. Reinstatement. If at any time any payment of any amounts due under the Borrower Loan Documents by Borrower, Guarantor or any other Person is rescinded or must be otherwise restored or returned upon the insolvency, bankruptcy or reorganization of Borrower or Guarantor or otherwise, Guarantor’s obligations hereunder with respect to such payment shall be reinstated as though such payment has been due but not made at such time. 12. Guarantor’s Financial Condition. (a) Guarantor hereby represents and warrants to Beneficiary Parties that as of the date hereof and throughout the term of the Borrower Loan, and after giving effect to this Guaranty and the contingent obligation evidenced hereby, Guarantor is and will be solvent and has and will have (i) assets which, fairly valued, exceed its obligations, liabilities (including contingent liabilities) and debts, and (ii) property and assets sufficient to satisfy and repay its obligations and liabilities. Guarantor hereby covenants and agrees that during the term of the Borrower Loan, except for the payment of employee salaries and benefits and dividends in the ordinary course of business, it shall not sell, pledge, mortgage or otherwise transfer any of its assets, or any interest therein, on terms materially less favorable than would be obtained in an arms-length transaction for fair consideration. (b) Guarantor hereby represents and warrants to Beneficiary Parties that all financial statements and other financial data previously delivered to Funding Lender in connection with the application for the Borrower Loan and/or this Guaranty relating to the Guarantor are true, correct and complete in all material respects. Such financial statements fairly present the financial positions of all Persons who are the subjects thereof as of the respective dates thereof. Guarantor further represents and warrants to Beneficiary Parties that, except as previously disclosed to Funding Lender in writing, no material adverse change has occurred as of the date hereof and no material change shall have occurred as of the date of each advance of the Borrower Loan, in such financial position, or in the business, operations, assets, management, ownership or condition (financial or otherwise) of Guarantor, since the respective dates of such financial statements and financial data. Except as otherwise previously disclosed to Funding Lender in writing, Guarantor has no knowledge of any material contractual obligations of Guarantor which might have a material adverse effect upon the ability of Guarantor to perform Guarantor’s obligations under this Guaranty. (c) Guarantor shall furnish or cause to be furnished to Funding Lender: (i) within ten (10) days of Funding Lender’s request, a copy of the most recent year’s federal tax return for such Guarantor, and (ii) as soon as available and in any event within one Exceptions to Non-Recourse Guaranty 7 Vista Breeze hundred twenty (120) days after the end of each fiscal year of Guarantor, copies of the following financial statements of Guarantor for such fiscal year, prepared and audited by an independent certified public accountant acceptable to Funding Lender, in accordance with generally accepted accounting principles: (A) a balance sheet as of the end of such fiscal year (including supporting schedules), and (B) a statement of income and capital accounts for such fiscal year. Notwithstanding the foregoing, the financial statements of any individual Guarantor are not required to be audited by an independent certified public accountant. (d) Guarantor shall from time to time, upon request by Funding Lender, deliver to Funding Lender such other financial statements as Funding Lender may reasonably require. 13. Intentionally Omitted. 14. Intentionally Omitted. 15. Determinations by Funding Lender. Except to the extent expressly set forth in this Guaranty to the contrary, in any instance where the consent or approval of Funding Lender may be given or is required, or where any determination, judgment or decision is to be rendered by Funding Lender under this Guaranty, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by Funding Lender, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. 16. Governing Law. This Guaranty shall be governed by and enforced in accordance with the laws of the Property Jurisdiction, without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 17. Consent to Jurisdiction and Venue. Guarantor agrees that any controversy arising under or in relation to this Guaranty shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Guaranty. Guarantor irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Guaranty against Guarantor or any of Guarantor’s assets in any court of any other jurisdiction. 18. Successors and Assigns. This Guaranty shall be binding upon Guarantor and its heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, and shall inure to the benefit of the Beneficiary Parties and their respective successors, successors-in- interest and assigns. The terms used to designate any of the parties herein shall be deemed to include the heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, of such parties. References to a “person” or “persons” shall be deemed to include Exceptions to Non-Recourse Guaranty 8 Vista Breeze individuals and entities. Guarantor acknowledges and agrees that any Beneficiary Party, at its option, may assign its respective rights and interests under this Guaranty and the other Borrower Loan Documents in whole or in part and upon such assignment all the terms and provisions of this Guaranty or the other Borrower Loan Documents shall inure to the benefit of such assignee to the extent so assigned. Guarantor may not assign or delegate its rights, interests or obligations under this Guaranty without first obtaining Funding Lender’s prior written consent. 19. Severability. The invalidity, illegality or unenforceability of any provision of this Guaranty shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 20. Expenses. Guarantor shall pay to the Beneficiary Parties, upon demand, the amount of any and all expenses, including, without limitation, reasonable attorneys’ fees (including reasonable time charges of attorneys who may be employees of Beneficiary Parties), which the Beneficiary Parties may incur in connection with (a) the exercise or enforcement of any of their rights hereunder, (b) the failure by Guarantor to perform or observe any of the provisions hereof, or (c) the breach by Guarantor of any representation or warranty of Guarantor set forth herein. Guarantor shall also pay to the Beneficiary Party who incurs any such expenses, interest on such expenses computed at the Default Rate set forth in the Borrower Note from the date on which such expenses are incurred to the date of payment thereof. 21. Remedies Cumulative. In the event of Guarantor’s default under this Guaranty, the Beneficiary Parties may exercise all or any one or more of their rights and remedies available under this Guaranty, at law or in equity. Such rights and remedies shall be cumulative and concurrent, and may be enforced separately, successively or together, and the exercise of any particular right or remedy shall not in any way prevent the Beneficiary Parties from exercising any other right or remedy available to the Beneficiary Parties. The Beneficiary Parties may exercise any such remedies from time to time as often as may be deemed necessary by the Beneficiary Parties. 22. No Agency or Partnership. Nothing contained in this Guaranty shall constitute any Beneficiary Party as a joint venturer, partner or agent of Guarantor, or render any Beneficiary Party liable for any debts, obligations, acts, omissions, representations or contracts of Guarantor. 23. Entire Agreement; Amendment and Waiver. This Guaranty contains the complete and entire understanding of the parties with respect to the matters covered herein. Guarantor acknowledges that Guarantor has received copies of the Borrower Note and all other Borrower Loan Documents. This Guaranty may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Guaranty shall be considered as a general waiver. 24. Further Assurances. Guarantor shall at any time and from time to time, promptly execute and deliver all further instruments and documents, and take all further action that may be reasonably necessary or desirable, or that any Beneficiary Party may reasonably Exceptions to Non-Recourse Guaranty 9 Vista Breeze request, in order to protect any right or interest granted by this Guaranty or to enable the Beneficiary Party to exercise and enforce its rights and remedies under this Guaranty. 25. Notices; Change of Guarantor’s Address. All notices given under this Guaranty shall be in writing and shall be sent to the respective addresses of the parties, in the manner set forth in the Security Instrument. Notices to Guarantor shall be sent to the address of Guarantor, at the address set forth below Guarantor’s signature block to this Guaranty. Guarantor agrees to notify Funding Lender (in the manner for giving notices provided in the Security Instrument) of any change in Guarantor’s address within ten (10) Business Days after such change of address occurs. 26. Counterparts. To the extent Guarantor consists of more than one party, this Guaranty may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. 27. Captions. The captions of the sections of this Guaranty are for convenience only and shall be disregarded in construing this Guaranty. 28. Servicer. Guarantor hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Funding Lender may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under the Borrower Note, this Guaranty or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Borrower receives written notice from Funding Lender to the contrary, any action or right which shall or may be taken or exercised by Funding Lender may be taken or exercised by such servicer with the same force and effect. 29. Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Guaranty for all purposes. 30. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF GUARANTOR AND THE BENEFICIARY PARTIES (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS GUARANTY OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 31. Time of the Essence. Time is of the essence with respect to this Guaranty. 32. Modifications. All modifications (if any) to the terms of this Guaranty (“Modifications”) are set forth on Exhibit A attached to this Guaranty. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer that does not require the consent of the Funding Lender), some or all of the Modifications to this Guaranty may be modified or rendered void by Funding Lender at its option by notice to Guarantor. Exceptions to Non-Recourse Guaranty 10 Vista Breeze 33. Attached Exhibit. The following Exhibit is attached to this Guaranty and is incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Modifications to Exceptions to Non-Recourse Guaranty The terms of this Guaranty are modified and supplemented as set forth in said Exhibit. To the extent of any conflict or inconsistency between the terms of said Exhibit and the text of this Guaranty, the terms of said Exhibit shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Exceptions to Non-Recourse Guaranty Vista Breeze IN WITNESS WHEREOF, the undersigned has duly executed and delivered this Exceptions to Non-Recourse Guaranty or caused this Exceptions to Non-Recourse Guaranty to be duly executed and delivered by its authorized representative as of the date first set forth above. GUARANTOR: HOWARD D. COHEN REVOCABLE TRUST U/A/D 4/6/1993 By: _________________________________ Name: Howard D. Cohen Title: Trustee Witness: By:______________________________ ________________________________ Printed Name By:______________________________ _________________________________ Printed Name Guarantor’s Address for Notices: Howard D. Cohen Revocable Trust c/o Atlantic Pacific Communities, LLC 161 NW 6th Street Suite 1020 Miami, Florida 33136 Attention: Howard D. Cohen Exceptions to Non-Recourse Guaranty Vista Breeze ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by Howard D. Cohen, as Trustee for Howard D. Cohen Revocable Trust U/A/D 4/6/1993. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): ___________ Title or Rank: Serial number (if any): Exceptions to Non-Recourse Guaranty B-1 Vista Breeze EXHIBIT A MODIFICATIONS TO EXCEPTIONS TO NON-RECOURSE GUARANTY The following modifications are made to the text of the Guaranty that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Guaranty. 4858-7686-7978v.5 D Forward Purchase Agreement Vista Breeze EXHIBIT D-7 TO FORWARD PURCHASE AGREEMENT FORM OF REPLACEMENT RESERVE AGREEMENT [See attached] EXHIBIT D-7 TO FORWARD PURCHASE AGREEMENT FORM OF REPLACEMENT RESERVE AGREEMENT This REPLACEMENT RESERVE AGREEMENT (this “Agreement”) is made and entered into as of the 1st day of [Month], 202[_], by and between VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”), and CITIBANK, N.A., a national banking association (together with its successors and assigns, the “Funding Lender”). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Closing Date (as defined in the Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December Replacement Reserve Agreement 2 Vista Breeze 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Funding Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Funding Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, Funding Lender has acquired the Funding Loan from the Original Funding Lender, and in connection therewith, (i) Funding Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement dated as of the date hereof (the “Funding Loan Agreement”) by and among Governmental Lender, Fiscal Agent, and Funding Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement dated as of the date hereof (the “Borrower Loan Agreement”) which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [Month] [Day], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN-OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Funding Lender and Borrower have entered into a certain Loan Covenant Agreement and dated as of the date hereof (the “Loan Covenant Agreement”; together with the Borrower Note, the Security Instrument, the Borrower Loan Agreement and all other documents executed in connection with the Borrower Loan, including this Agreement, the “Borrower Loan Documents”). I. The term “Beneficiary Parties” as used herein shall mean Funding Lender, Governmental Lender, Fiscal Agent and any Servicer, and their respective successors and assigns. The term “Beneficiary Parties” shall also include any lawful owner, holder or pledgee of the Borrower Note. J. As a condition to the purchase of the Funding Loan by Funding Lender, Borrower is required to establish the Replacement Reserve Fund for the funding of Capital Replacements (as defined herein) throughout the term of the Borrower Loan. NOW, THEREFORE, for and in consideration of the purchase of the Funding Loan by Funding Lender, the mutual promises and covenants herein contained, and other good and Replacement Reserve Agreement 3 Vista Breeze valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Funding Lender and Borrower agree as follows: 1. Definitions. The following terms used in this Agreement shall have the meanings set forth below in this Section 1. Any term used in this Agreement and not defined herein shall have the meaning given to that term in the Security Instrument. (a) “Capital Replacement” means the replacement of those items which are capital in nature, as determined by Funding Lender in its sole but good-faith judgment in accordance with generally accepted accounting principles and such other replacements of equipment, major components, or capital systems related to the Improvements as may be approved in writing or required by Funding Lender pursuant to the terms of the Borrower Loan Documents. (b) “Disbursement Period” means the interval between disbursements from the Replacement Reserve Fund, which interval shall be no shorter than once a month. (c) “First Deposit Date” means the date on which the first scheduled monthly payment of interest is due under the Borrower Note. (d) “Minimum Disbursement Request Amount” means Five Thousand and No/100 Dollars ($5,000.00). (e) “Replacement Reserve Deposit” means for each month from the First Deposit Date until the fifth (5th) anniversary of the First Deposit Date, the sum of one- twelfth of Three Hundred and No/100 Dollars ($300.00) per apartment unit located in the Mortgaged Property (or such higher amount per apartment unit located in the Mortgaged Property as may be required by Funding Lender based on the updated physical needs assessment delivered by Borrower as one of the Loan Purchase Conditions), and thereafter during the remainder of the term of the Borrower Loan, such higher amounts as may be required by Funding Lender based on any updated physical needs assessment delivered pursuant to Section 2(a) below or otherwise in its sole discretion. (f) “Replacement Reserve Fund” means the account established pursuant to this Agreement to defray the costs of Capital Replacements. 2. Replacement Reserve Fund. (a) Establishment; Funding. On the Closing Date, the Borrower shall establish the Replacement Reserve Fund with Funding Lender. Commencing on the First Deposit Date and continuing on the first day of each successive month during the Borrower Loan term, Borrower shall pay to Funding Lender for deposit into the Replacement Reserve Fund the monthly Replacement Reserve Deposit, together with its regular monthly payments of principal and interest as required by the Borrower Note and Security Instrument. The Replacement Reserve Fund shall be maintained and governed in accordance with this Agreement. No earlier than the sixth (6th) month and no later than the ninth (9th) month of the year which precedes the fifth (5th) anniversary of the First Deposit Date (and each fifth (5th) anniversary thereafter), a physical needs Replacement Reserve Agreement 4 Vista Breeze assessment shall be performed on the Mortgaged Property by Funding Lender at the expense of Borrower, which expense may be paid out of the Replacement Reserve Fund. If determined necessary or appropriate by Funding Lender, after review of the most recently obtained physical needs assessment, Borrower’s required Replacement Reserve Deposits to the Replacement Reserve Fund set forth herein shall be adjusted for the remaining Borrower Loan term (or until adjusted in accordance with the terms of this Section 2(a)), so that the Replacement Reserve Deposits will create a Replacement Reserve herein that will in Funding Lender’s determination, be sufficient to meet required Capital Replacements. (b) Investment of Deposits. Borrower agrees that all moneys deposited into the Replacement Reserve Fund shall be held in an interest-bearing account, and, except as otherwise provided in this Section 2(b), the interest earned on such moneys shall be added to the principal balance of the Replacement Reserve Fund and disbursed in accordance with the provisions of this Agreement. Borrower acknowledges and agrees that it shall not have the right to direct Funding Lender as to any specific investment of moneys in the Replacement Reserve Fund. Funding Lender shall not be responsible for any losses resulting from investment of moneys in the Replacement Reserve Fund or for obtaining any specific level or percentage of earnings on such investment. (c) Use. Subject to the pledge to and security interest of the Funding Lender and other rights of Funding Lender set forth in this Agreement, the Replacement Reserve Fund shall be maintained for the payment of the costs of the Capital Replacements; provided, however that if rebatable arbitrage occurs on account of the interest earned on the Replacement Reserve Fund, the amounts held in the Replacement Reserve Fund shall be used to pay any such amounts. Funding Lender shall not be obligated to make disbursements from the Replacement Reserve Fund to reimburse Borrower for the costs of routine maintenance to the Mortgaged Property or for costs which are to be reimbursed from funds deposited with Funding Lender pursuant to any Completion/Repair and Security Agreement between the Borrower and the Funding Lender or any similar agreement. (d) Early Deposits. Funding Lender reserves the right to require at any time upon written notice to Borrower that Borrower begin making the monthly Replacement Reserve Deposit if Funding Lender determines that, prior to the First Deposit Date, any of the following events have occurred: (i) the occurrence of an Event of Default under the Borrower Note, Security Instrument, or any other document delivered in connection with the Borrower Loan, (ii) the occurrence of a Transfer which is prohibited under the terms of the Security Instrument or requires consent, or (iii) Borrower’s failure to maintain the Mortgaged Property in a satisfactory manner and/or in accordance with the requirements of the Security Instrument. Replacement Reserve Agreement 5 Vista Breeze 3. Disbursements. (a) Requests for Disbursement. Funding Lender shall disburse funds from the Replacement Reserve Fund, as follows: (i) Borrower’s Request. If Borrower determines, at any time or from time to time, that a Capital Replacement is necessary or desirable, Borrower shall perform such Capital Replacement and request from Funding Lender, in writing, payment or reimbursement for such Capital Replacement. Borrower’s request for payment or reimbursement shall include (A) a detailed description of the Capital Replacement performed, together with either (1) evidence, satisfactory to Funding Lender, that the cost of such Capital Replacement has been paid or (2) an invoice for such payment from the party entitled thereto, and (B) conditional (subject only to payment of the amounts shown on the invoice provided to Funding Lender as required in clause (A) hereof, if applicable) lien waivers from each contractor and material supplier supplying labor or materials for such Capital Replacement, if required by Funding Lender. (ii) Funding Lender’s Request. If Funding Lender shall determine, at any time or from time to time, that Capital Replacements are necessary or desirable, it shall so notify Borrower, in writing, requesting that Borrower obtain and submit to Funding Lender bids for all labor and materials required in connection with such Capital Replacement. Borrower shall submit such bids and a time schedule for completing each Capital Replacement to Funding Lender within thirty (30) days after Borrower’s receipt of Funding Lender’s notice. Borrower shall perform such Capital Replacement and request from Funding Lender, in writing, payment or reimbursement for such Capital Replacement. Borrower’s request for reimbursement shall conform to the requirements of Section 3(a)(i) above. (b) Conditions Precedent. Disbursement from the Replacement Reserve Fund shall be made no more frequently than once every Disbursement Period and, except for the final disbursement, no disbursement shall be made in an amount less than the Minimum Disbursement Request Amount. Disbursements shall be approved only if the following conditions precedent have been satisfied, as determined by Funding Lender: (i) Payment for Capital Replacement. The Capital Replacement has been performed and/or installed on the Mortgaged Property in a good and workmanlike manner with suitable materials (or in the case of a partial disbursement, performed and/or installed on the Mortgaged Property to an acceptable stage) and paid for by Borrower as evidenced by copies of all applicable paid invoices (or subject to payment by Borrower as evidenced by invoices for such payment from the party entitled thereto) submitted to Funding Lender by Borrower at the time Borrower requests disbursement from the Replacement Reserve Fund. Replacement Reserve Agreement 6 Vista Breeze (ii) No Default. There shall exist no condition, event or act that would constitute a default (with or without notice and/or lapse of time) under this Agreement or any other Borrower Loan Document. (iii) Representations and Warranties. All representations and warranties of Borrower set forth in this Agreement and in the Borrower Loan Documents are true and correct in all material respects. (iv) Continuing Compliance. Borrower shall be in full compliance with the provisions of this Agreement, the other Borrower Loan Documents and any request or demand by Funding Lender permitted hereby. (v) No Lien Claim. No lien or claim based on furnishing labor or materials has been filed or asserted against the Mortgaged Property or the Improvements, unless Borrower has properly provided bond or other security against loss to the satisfaction of Funding Lender and in accordance with applicable law. Funding Lender shall have the right to require Borrower to provide a search of title to the Mortgaged Property effective to the date of the disbursement, which search shows that no mechanic’s or materialmen’s liens or other liens of any nature have been placed against the Mortgaged Property since the date of this Agreement (other than liens which Borrower is diligently contesting in good faith and which have been bonded off to the satisfaction of Funding Lender and in accordance with applicable law) and that title to the Mortgaged Property is free and clear of all liens (other than the lien of the Security Instrument and any other liens previously approved in writing by Funding Lender, if any). (vi) Approvals. All licenses, permits, and approvals of governmental authorities required for the Capital Replacement as completed to the applicable stage have been obtained. (vii) Contracts. Funding Lender shall have the right to approve all contracts or work orders with materialmen, mechanics, suppliers, subcontractors, contractors or other parties providing labor or materials in connection with the Capital Replacements. Upon Funding Lender’s request, Borrower shall collaterally assign any contract or subcontract to Funding Lender. (viii) Legal Compliance. The Capital Replacement as completed to the applicable stage does not violate any laws, ordinance, rules or regulations, or building lines or restrictions applicable to the Mortgaged Property. 4. Right to Complete Capital Replacements. If Borrower abandons or fails to proceed diligently to undertake or complete any Capital Replacement in a timely fashion or is otherwise in default under this Agreement or any other Borrower Loan Document, (a) Funding Lender shall have the right (but not the obligation) to enter upon the Mortgaged Property upon no less than two (2) days’ prior written notice and take over and cause the completion of such Capital Replacement (provided no such notice or grace period shall apply in the case of such Replacement Reserve Agreement 7 Vista Breeze failure which could, in Funding Lender’s judgment, absent immediate exercise by Funding Lender of a right or remedy under this Agreement, result in harm to Funding Lender or impairment of the security given under the Security Instrument) and (b) any contracts entered into or indebtedness incurred upon the exercise of such right may be in the name of Borrower, and Funding Lender is hereby irrevocably appointed the attorney in fact of Borrower, such appointment being coupled with an interest, to enter into such contracts, incur such obligations, enforce any contracts or agreements made by or on behalf of Borrower (including the prosecution and defense of all actions and proceedings in connection with the Capital Replacement and the payment, settlement or compromise of all bills and claims for materials and work performed in connection with the Capital Replacement) and do any and all things necessary or proper to complete any Capital Replacement including signing Borrower’s name to any contracts and documents as may be deemed necessary by Funding Lender. In no event shall Funding Lender be required to expend its own funds to complete any Capital Replacement, but Funding Lender may, in its sole discretion, (i) expend funds then held in the Replacement Reserve Fund, or (ii) expend funds advanced by or on behalf of Funding Lender in accordance with the terms of the Security Instrument (and any funds so advanced shall be added to the outstanding balance of the Borrower Note, secured by the Security Instrument and payable in accordance with the provisions of the Security Instrument pertaining to protective advances). Borrower waives any and all claims it may have against Funding Lender for materials used, work performed or resultant damage to the Mortgaged Property, except to the extent arising out of the gross negligence or willful misconduct of Funding Lender or its agents, as applicable. 5. Inspection. Funding Lender or any of its agents may periodically inspect any Capital Replacement in progress and upon completion during normal business hours or at any other reasonable time upon reasonable prior written notice to Borrower (except in an emergency, as determined by Funding Lender in its sole discretion, or after an Event of Default, in which event no such prior notice shall be required) and subject to the rights of residential tenants under leases; provided, however that not more than one inspection shall be required for each draw request. If Funding Lender, in its sole discretion, retains a professional inspection engineer or other qualified third party to inspect any Capital Replacement, Funding Lender also shall be entitled to deduct from the Replacement Reserve Fund an amount sufficient to pay all reasonable fees and expenses charged by such third party inspector. 6. Insufficient Account. The insufficiency of any balance in the Replacement Reserve Fund shall not abrogate the Borrower’s agreement to fulfill all preservation and maintenance covenants in the Borrower Loan Documents. In the event that the balance of the Replacement Reserve Fund is less than the current estimated cost to make the Capital Replacements required under this Agreement, Borrower shall deposit the shortage within ten (10) days of request by Funding Lender. In the event Funding Lender determines from time to time, based on Funding Lender’s inspections, that the amount of the monthly Replacement Reserve Deposit is insufficient to fund the cost of likely Capital Replacements and related contingencies that may arise during the remaining term of the Borrower Loan, Funding Lender may require an increase in the amount of the monthly Replacement Reserve Deposits upon thirty (30) days’ prior written notice to Borrower. 7. Security Agreement. Borrower hereby conveys, pledges, transfers and grants to Funding Lender a security interest pursuant to the Uniform Commercial Code of the Property Replacement Reserve Agreement 8 Vista Breeze Jurisdiction or any other applicable law in and to all money in the Replacement Reserve Fund, as the same may increase or decrease from time to time, for the purpose of securing Borrower’s obligations under this Agreement and to further secure Borrower’s obligations under the Borrower Note, the Security Instrument, and the other Borrower Loan Documents. 8. Post Default. If Borrower defaults in the performance of its obligations under this Agreement or under the Borrower Note, Security Instrument or any other Borrower Loan Document (beyond any applicable notice and cure period), Funding Lender and its successors and assigns shall have all remedies available to them under Article 9 of the Uniform Commercial Code of the Property Jurisdiction and under any other applicable law and, in addition, may retain all money in the Replacement Reserve Fund, including interest, and in Funding Lender’s discretion, may apply such amounts, without restriction and without any specific order of priority, to the payment of any and all indebtedness or obligations of Borrower set forth in the Borrower Note, Security Instrument or any other Borrower Loan Document, including, but not limited to, principal, interest, taxes, insurance, reasonable attorneys’ fees and costs (including those of in-house counsel) and disbursements actually incurred and/or repairs to the Mortgaged Property. 9. Compliance with Laws; Insurance Requirements. (a) Compliance with Laws. All Capital Replacements shall comply with all applicable laws, ordinances, rules and regulations of all governmental authorities having jurisdiction over the Mortgaged Property and applicable insurance requirements including, without limitation, applicable building codes, special use permits, environmental regulations, and requirements of insurance underwriters. (b) Insurance Requirements. In addition to any insurance required under the Borrower Loan Documents, Borrower shall provide or cause to be provided workers’ compensation, builder’s risk (if required by Funding Lender), and public liability insurance and other insurance required under applicable law in connection with any of the Capital Replacements, all of which shall be in form and substance, and from carriers, acceptable to Funding Lender. All such policies that can be endorsed with standard mortgagee clauses making losses payable to Funding Lender or its assigns shall be so endorsed. The originals or certified copies of such policies shall be deposited with Funding Lender. 10. Completion of Capital Replacements. Funding Lender’s disbursement of moneys from the Replacement Reserve Fund or other acknowledgment of completion of any Capital Replacement in a manner satisfactory to Funding Lender shall not be deemed a certification by Funding Lender that the Capital Replacement has been completed in accordance with applicable building, zoning or other codes, ordinances, statutes, laws, regulations or requirements of any governmental authority or agency. Borrower shall at all times have the sole responsibility for ensuring that all Capital Replacements are completed in accordance with all such governmental requirements. 11. Assignment of Rights and Claims. Borrower assigns to Funding Lender all rights and claims Borrower may have against all persons or entities supplying labor or materials Replacement Reserve Agreement 9 Vista Breeze in connection with the Capital Replacements; provided, however, that Funding Lender may not pursue any such right or claim unless a default exists under this Agreement or an Event of Default shall have occurred under the Security Instrument. 12. Termination. If not sooner terminated by the written concurrence of the parties, this Agreement shall terminate upon the payment in full of the Borrower Loan and all indebtedness incurred in connection therewith, and upon such termination, Funding Lender shall pay to Borrower all funds remaining in the Replacement Reserve Fund. Notwithstanding the foregoing, any and all provisions herein relating to the indemnification of the Beneficiary Parties shall survive such termination. 13. Determinations by Funding Lender. Except to the extent expressly set forth in this Agreement to the contrary, in any instance where the consent or approval of Funding Lender may be given or is required, or where any determination, judgment or decision is to be rendered by Funding Lender under this Agreement, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by Funding Lender, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. 14. Release; Indemnity. (a) Release. Borrower covenants and agrees that, in performing any of their rights or duties under this Agreement, neither the Beneficiary Parties, nor their agents or employees, shall be liable for any losses, claims, damages, liabilities and expenses that may be incurred by any of them as a result of such performance, except to the extent such liability for any losses, claims, damages, liabilities or expenses arises out of the willful misconduct or gross negligence of such party. (b) Indemnity. Borrower hereby agrees to indemnify and hold harmless the Beneficiary Parties and their respective agents and employees from and against any and all losses, claims, damages, liabilities and expenses including, without limitation, reasonable attorneys’ fees and costs and disbursements, which may be imposed or incurred by any of them in connection with this Agreement, except that no such party will be indemnified for any losses, claims, damages, liabilities or expenses arising out of the willful misconduct or gross negligence of such party. 15. Governing Law. This Agreement shall be governed by and enforced in accordance with the laws of the Property Jurisdiction, without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 16. Consent to Jurisdiction and Venue. Borrower agrees that any controversy arising under or in relation to this Agreement shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Agreement. Borrower irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by Replacement Reserve Agreement 10 Vista Breeze virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Agreement against Borrower or any of Borrower’s assets in any court of any other jurisdiction. 17. Successors and Assigns. This Agreement shall be binding upon and shall inure to the benefit of the parties hereto and their respective heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate. The terms used to designate any of the parties herein shall be deemed to include the heirs, legal representatives, successors, successors-in- interest and assigns, as appropriate, of such parties. References to a “person” or “persons” shall be deemed to include individuals and entities. Borrower acknowledges and agrees that any Beneficiary Party, at its option, may assign its respective rights and interests under this Agreement and the other Borrower Loan Documents in whole or in part and upon such assignment all the terms and provisions of this Agreement or the other Borrower Loan Documents shall inure to the benefit of such assignee to the extent so assigned. Borrower may not assign or delegate its rights, interests or obligations under this Agreement without first obtaining Funding Lender’s prior written consent. 18. Severability. The invalidity, illegality or unenforceability of any provision of this Agreement shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 19. Expenses. Borrower shall pay to the Beneficiary Parties, upon demand, the amount of any and all expenses, including, without limitation, reasonable attorneys’ fees (including reasonable time charges of attorneys who may be employees of Beneficiary Parties), which the Beneficiary Parties may incur in connection with (a) the custody, preservation or sale of, collection from, or other realization upon any of the collateral pledged or encumbered by this Agreement, (b) the exercise or enforcement of any of their rights hereunder, (c) the failure by Borrower to perform or observe any of the provisions hereof, or (d) the breach by Borrower of any representation or warranty of Borrower set forth herein. Such expenses, together with interest thereon computed at the Default Rate set forth in the Borrower Note from the date on which such expenses are incurred to the date of payment thereof, shall constitute indebtedness secured by the Security Instrument. 20. Remedies Cumulative. In the event of Borrower’s default under this Agreement, the Beneficiary Parties may exercise all or any one or more of their rights and remedies available under this Agreement, at law or in equity. Such rights and remedies shall be cumulative and concurrent, and may be enforced separately, successively or together, and the exercise of any particular right or remedy shall not in any way prevent the Beneficiary Parties from exercising any other right or remedy available to the Beneficiary Parties. The Beneficiary Parties may exercise any such remedies from time to time as often as may be deemed necessary by the Beneficiary Parties. 21. No Agency or Partnership. Nothing contained in this Agreement shall constitute any Beneficiary Party as a joint venturer, partner or agent of Borrower, or render any Beneficiary Party liable for any debts, obligations, acts, omissions, representations or contracts of Borrower. Replacement Reserve Agreement 11 Vista Breeze 22. Transfer of Mortgaged Property or Ownership Interests in Borrower. If a Transfer (as defined in the Security Instrument) of all or part of the Mortgaged Property or of an ownership interest in Borrower shall occur, which Transfer requires the prior written consent of Funding Lender, the transferee(s) shall be required to assume the transferor’s duties and obligations under this Agreement and the other Borrower Loan Documents and shall be required to execute and deliver to Funding Lender such documents as Funding Lender requires to effectuate such assumption of duties and obligations. No transfer and assumption shall relieve the transferor of any of its duties or obligations under this Agreement or any of the other Borrower Loan Documents, unless the Borrower has obtained the prior written consent of Funding Lender to the release of such duties and obligations. 23. Entire Agreement; Amendment and Waiver. This Agreement contains the complete and entire understanding of the parties with respect to the matters covered herein. This Agreement may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Agreement shall be considered as a general waiver. 24. Further Assurances. Borrower shall at any time and from time to time, promptly execute and deliver all further instruments and documents, and take all further action that may be reasonably necessary or desirable, or that any Beneficiary Party may reasonably request, in order to protect any right or interest granted by this Agreement or to enable the Beneficiary Party to exercise and enforce its rights and remedies under this Agreement. 25. No Amendment; Conflicts. Nothing contained in this Agreement shall be construed to amend, modify, alter, change or supersede the terms and provisions of the Borrower Note, the Security Instrument or the Borrower Loan Agreement; and, if there is a conflict between the terms and provisions of this Agreement and those of the Borrower Note, the Security Instrument or the Borrower Loan Agreement, then the terms and provisions of the Borrower Note, the Security Instrument or the Borrower Loan Agreement shall control. 26. Limitation of Liability. The personal liability of Borrower for the payment and performance of the obligations hereunder is limited in the manner and to the extent provided in the Borrower Note. 27. Notices. All notices given under this Agreement shall be in writing and shall be sent to the respective addresses of the parties, in the manner set forth in the Security Instrument. 28. Counterparts. This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. 29. Captions. The captions of the sections of this Agreement are for convenience only and shall be disregarded in construing this Agreement. 30. Servicer. Borrower hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Funding Lender may appoint a servicer to Replacement Reserve Agreement 12 Vista Breeze collect payments, escrows and deposits, to give and to receive notices under the Borrower Note, this Agreement or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Borrower receives written notice from Funding Lender to the contrary, any action or right which shall or may be taken or exercised by Funding Lender may be taken or exercised by such servicer with the same force and effect. 31. Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Agreement for all purposes. 32. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF BORROWER AND THE BENEFICIARY PARTIES (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 33. Time of the Essence. Time is of the essence with respect to this Agreement. 34. Modifications. All modifications (if any) to the terms of this Agreement (“Modifications”) are set forth on Exhibit A attached to this Agreement. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer that does not require the consent of the Funding Lender), some or all of the Modifications to this Agreement may be modified or rendered void by Funding Lender at its option by notice to Borrower or such transferee. 35. Attached Exhibit. The following Exhibit is attached to this Agreement and is incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Modifications to Replacement Reserve Agreement The terms of this Agreement are modified and supplemented as set forth in said Exhibit. To the extent of any conflict or inconsistency between the terms of said Exhibit and the text of this Agreement, the terms of said Exhibit shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Vista Breeze IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Replacement Reserve Agreement or caused this Replacement Reserve Agreement to be duly executed and delivered by their respective authorized representatives as of the date first set forth above. BORROWER: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: Replacement Reserve Agreement S-2 Vista Breeze FUNDING LENDER: CITIBANK, N.A. By: Name: Title: Deal ID No. 60001596 Vista Breeze EXHIBIT A MODIFICATIONS TO REPLACEMENT RESERVE AGREEMENT The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. 4859-6108-1738v.3 D Forward Purchase Agreement Vista Breeze EXHIBIT D-8 TO FORWARD PURCHASE AGREEMENT FORM OF ASSIGNMENT OF MANAGEMENT AGREEMENT [See attached] EXHIBIT D-8 TO FORWARD PURCHASE AGREEMENT FORM OF ASSIGNMENT OF MANAGEMENT AGREEMENT This ASSIGNMENT OF MANAGEMENT AGREEMENT (this “Assignment”) is made as of the 1st day of [Month], 202[_], by and between VISTA BREEZE, LTD., a Florida limited partnership (“Assignor”), and ATLANTIC PACIFIC COMMUNITY MANAGEMENT, LLC, a Delaware limited liability company (“Manager”), for the benefit of CITIBANK, N.A., a national banking association (together with its successors and assigns, the “Assignee”). The date of this Assignment as set forth above is for reference purposes only, and this Assignment will not be effective and binding until the Closing Date (as defined in the Borrower Loan Agreement (as hereinafter defined)). This Assignment is a collateral assignment and not a present assignment of rights and interests, and is effective only upon the occurrence of an Event of Default (as defined in the Borrower Loan Agreement). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and Assignor, Assignor is the holder of a leasehold interest in the Land. B. Assignor previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Assignor previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023 (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and Assignor. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Assignor payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. Assignment of Management Agreement 2 Vista Breeze E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Assignor for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Assignor, Assignor, Original Funding Lender and Assignee entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Assignee agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, Assignee has acquired the Funding Loan from the Original Funding Lender, and in connection therewith, (i) Assignee has agreed to enter into a certain Amended and Restated Funding Loan Agreement dated as of the date hereof (the “Funding Loan Agreement”) by and among Governmental Lender, Fiscal Agent, and Assignee, which amends and restates the Original Funding Loan Agreement; (ii) Assignor and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement dated as of the date hereof (the “Borrower Loan Agreement”) which amends and restates the Original Borrower Loan Agreement; (iii) Assignor has executed and delivered an Amended and Restated Multifamily Note, dated as of [Month] [Day], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Assignor has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Assignee and Assignor have entered into a certain Loan Covenant Agreement and dated as of the date hereof (the “Loan Covenant Agreement”; together with the Borrower Note, the Security Instrument, the Borrower Loan Agreement and all other documents executed in connection with the Borrower Loan, including this Agreement, the “Borrower Loan Documents”). I. The term “Beneficiary Parties” as used herein shall mean Assignee, Governmental Lender, Fiscal Agent and any Servicer, and their respective successors and assigns. The term “Beneficiary Parties” shall also include any lawful owner, holder or pledgee of the Borrower Note. I. Assignor has engaged Manager to rent, lease, operate and manage the Mortgaged Property pursuant to the terms of that certain Property Management Agreement (Vista Breeze), dated as of December 15, 2023, by and between Assignor and Manager (the “Management Agreement”). Manager is entitled to earn management fees, commissions, compensation and/or Assignment of Management Agreement 3 Vista Breeze all other amounts payable to Manager under the Management Agreement (collectively, “Management Fees”). J. As a condition to the purchase of the Funding Loan by Assignee, Assignor is required to enter into this Assignment and assign to Assignee all of Assignor’s rights, title and interests in, to and under the Management Agreement for the purpose of providing additional security for the full payment and performance by Assignor of all of its obligations under the Borrower Loan Documents. K. Manager is willing to consent to the assignment and to attorn to Assignee upon an Event of Default by Assignor under and as defined in the Borrower Loan Documents, and perform its obligations under the Management Agreement for Assignee or to permit Assignee to terminate the Management Agreement, without liability on the terms and conditions set forth herein. NOW, THEREFORE, for and in consideration of the purchase of the Funding Loan, the mutual promises and covenants herein contained, and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Assignor and Manager agree as follows: 1. Definitions. Capitalized terms which appear and are not otherwise defined herein shall have the meanings ascribed to such terms in the Security Instrument or the Loan Covenant Agreement. 2. Assignment. Assignor hereby transfers, assigns and sets over to Assignee all right, title and interest of Assignor in and to the Management Agreement. Manager hereby consents to the foregoing assignment. The foregoing assignment is being made by Assignor to Assignee as collateral security for the full payment and performance by Assignor of all of its obligations under the Borrower Loan Documents. However, until the occurrence of an Event of Default (as such term is defined in the Borrower Loan Documents), Assignor may exercise all rights as owner of the Mortgaged Property under the Management Agreement, except as otherwise provided in this Assignment. The foregoing assignment shall remain in effect as long as the Borrower Loan, or any part thereof, remains unpaid, but shall automatically terminate upon the release of the Security Instrument as a lien on the Mortgaged Property. 3. Representations and Warranties. Assignor and Manager represent and warrant to Assignee that (a) the Management Agreement is unmodified and is in full force and effect, (b) the Management Agreement is a valid and binding agreement enforceable against the parties in accordance with its terms, and (c) neither party is in default in performing any of its obligations under the Management Agreement. 4. Certain Covenants. Assignor hereby covenants with Assignee that during the term of this Assignment: (a) Assignor shall not transfer the responsibility for management of the Mortgaged Property from Manager to any other person or entity without the prior written consent of Assignee; (b) Assignor shall not terminate or amend any of the material terms or provisions of the Management Agreement without the prior written consent of Assignee; and (c) Assignor shall give Assignee written notice of any notice or information that Assignor receives which Assignment of Management Agreement 4 Vista Breeze indicates that Manager is terminating the Management Agreement or that Manager is otherwise discontinuing its management of the Mortgaged Property. 5. Assignee Rights. Upon receipt by Manager of written notice from Assignee that an Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Assignee have any obligation to accept a cure of an Event of Default), Assignee shall have the right to exercise all rights as owner of the Mortgaged Property under the Management Agreement. 6. Termination or Amendment of Management Agreement. Manager agrees that notwithstanding anything to the contrary in the Management Agreement, at any time that the Security Instrument encumbers the Mortgaged Property (or at any time after a foreclosure or deed in lieu of foreclosure of the Mortgaged Property): (i) the Management Agreement may not be amended or modified in any material respect without the prior written consent of Assignee, and (ii) the Management Agreement may be terminated by Assignor or its successors and assigns, with or without cause and for any reason whatsoever, upon 30 days written notice to Manager. Manager further agrees that after the occurrence of an Event of Default, Assignee (or its nominee) shall have the right at any time thereafter to terminate the Management Agreement, without cause and without liability, by giving written notice to Manager of its election to do so. Assignee’s notice shall specify the date of termination, which shall not be less than 30 days after the date of such notice. 7. Post-Termination. On the effective date of termination of the Management Agreement, Manager shall turn over to Assignee all books and records relating to the Mortgaged Property (copies of which may be retained by Manager, at Manager’s expense), together with such authorizations and letters of direction addressed to tenants, suppliers, employees, banks and other parties as Assignee may reasonably require. Manager shall cooperate with Assignee in the transfer of management responsibilities to Assignee or its designee. A final accounting of unpaid fees (if any) due to Manager under the Management Agreement shall be made within 60 days after the effective date of termination, but Assignee shall not have any liability or obligation to Manager for unpaid fees or other amounts payable under the Management Agreement which accrue before Assignee (or its nominee) acquires title to the Mortgaged Property, or Assignee becomes a mortgagee in possession. 8. Termination. If not sooner terminated by the written concurrence of the parties, this Assignment shall terminate upon the payment in full of the Borrower Loan and all indebtedness incurred in connection therewith. Notwithstanding the foregoing, any and all provisions herein relating to the indemnification of the Beneficiary Parties shall survive such termination. 9. Determinations by Assignee. Except to the extent expressly set forth in this Assignment to the contrary, in any instance where the consent or approval of Assignee may be given or is required, or where any determination, judgment or decision is to be rendered by Assignee under this Assignment, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by Assignee, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. Assignment of Management Agreement 5 Vista Breeze 10. Release; Indemnity; Assignment of Rights and Claims. (a) Release. Each of Assignor and Manager covenants and agrees that, in performing any of their rights or duties under this Assignment, neither the Beneficiary Parties, nor their agents or employees, shall be liable for any losses, claims, damages, liabilities and expenses that may be incurred by any of them as a result of such performance, except to the extent such liability for any losses, claims, damages, liabilities or expenses arises out of the willful misconduct or gross negligence of such party. (b) Indemnity. Assignor hereby agrees to indemnify and hold harmless the Beneficiary Parties and their respective agents and employees from and against any and all losses, claims, damages, liabilities and expenses including, without limitation, reasonable attorneys’ fees and costs and disbursements, which may be imposed or incurred by any of them in connection with this Assignment, except that no such party will be indemnified for any losses, claims, damages, liabilities or expenses arising out of the willful misconduct or gross negligence of such party. (c) Assignment of Rights and Claims against Manager. Assignor assigns to Assignee all rights and claims Assignor may have against Manager in connection with the Management Agreement; provided, however, that Assignee may not pursue any such right or claim unless a default exists under this Assignment or an Event of Default shall have occurred under the Security Instrument. 11. Governing Law. This Assignment shall be governed by and enforced in accordance with the laws of the Property Jurisdiction, without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 12. Consent to Jurisdiction and Venue. Each of Assignor and Manager agrees that any controversy arising under or in relation to this Assignment shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Assignment. Each of Assignor and Manager irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Assignment against Assignor, Manager or any of Assignor’s or Manager’s assets in any court of any other jurisdiction. 13. Successors and Assigns. This Assignment shall be binding upon Assignor, Manager and their respective heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, and shall inure to the benefit of the Beneficiary Parties and their respective successors, successors-in-interest and assigns. The terms used to designate any of the parties herein shall be deemed to include the heirs, legal representatives, successors, successors- in-interest and assigns, as appropriate, of such parties. References to a “person” or “persons” shall be deemed to include individuals and entities. Each of Assignor and Manager acknowledges and agrees that any Beneficiary Party, at its option, may assign its respective Assignment of Management Agreement 6 Vista Breeze rights and interests under this Assignment and the other Borrower Loan Documents in whole or in part and upon such assignment all the terms and provisions of this Assignment or the other Borrower Loan Documents shall inure to the benefit of such assignee to the extent so assigned. Neither of Assignor nor Manager may assign or delegate its rights, interests or obligations under this Assignment without first obtaining Assignee’s prior written consent. 14. Severability. The invalidity, illegality or unenforceability of any provision of this Assignment shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 15. Expenses. Assignor shall pay to the Beneficiary Parties, upon demand, the amount of any and all expenses, including, without limitation, reasonable attorneys’ fees (including reasonable time charges of attorneys who may be employees of Beneficiary Parties), which the Beneficiary Parties may incur in connection with (a) the custody, preservation or sale of, collection from, or other realization upon any of the interests assigned or encumbered by this Assignment, (b) the exercise or enforcement of any of their rights hereunder, (c) the failure by Assignor to perform or observe any of the provisions hereof, or (d) the breach by Assignor of any representation or warranty of such party set forth herein. Such expenses, together with interest thereon computed at the Default Rate set forth in the Borrower Note from the date on which such expenses are incurred to the date of payment thereof, shall constitute indebtedness secured by the Security Instrument. 16. Remedies Cumulative. In the event of Assignor’s default under this Assignment, the Beneficiary Parties may exercise all or any one or more of their rights and remedies available under this Assignment, at law or in equity. Such rights and remedies shall be cumulative and concurrent, and may be enforced separately, successively or together, and the exercise of any particular right or remedy shall not in any way prevent the Beneficiary Parties from exercising any other right or remedy available to the Beneficiary Parties. The Beneficiary Parties may exercise any such remedies from time to time as often as may be deemed necessary by the Beneficiary Parties. 17. No Agency or Partnership. Nothing contained in this Assignment shall constitute any Beneficiary Party as a joint venturer, partner or agent of Assignor or Manager, or render any Beneficiary Party liable for any debts, obligations, acts, omissions, representations or contracts of Assignor or Manager. 18. Transfer of Mortgaged Property or Ownership Interests in Assignor. If a Transfer (as defined in the Security Instrument) of all or part of the Mortgaged Property or of an ownership interest in Assignor shall occur, which Transfer requires the prior written consent of Assignee, the transferee(s) shall be required to assume the transferor’s duties and obligations under this Assignment and the other Borrower Loan Documents and shall be required to execute and deliver to Assignee such documents as Assignee requires to effectuate such assumption of duties and obligations. No transfer and assumption shall relieve the transferor of any of its duties or obligations under this Assignment or any of the other Borrower Loan Documents, unless the Assignor has obtained the prior written consent of Assignee to the release of such duties and obligations. Assignment of Management Agreement 7 Vista Breeze 19. Entire Agreement; Amendment and Waiver. This Assignment contains the complete and entire understanding of the parties with respect to the matters covered herein. This Assignment may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Assignment shall be considered as a general waiver. 20. Further Assurances. Each of Assignor and Manager shall at any time and from time to time, promptly execute and deliver all further instruments and documents, and take all further action that may be reasonably necessary or desirable, or that any Beneficiary Party may reasonably request, in order to protect any right or interest granted by this Assignment or to enable the Beneficiary Party to exercise and enforce its rights and remedies under this Assignment. 21. No Amendment; Conflicts. Nothing contained in this Assignment shall be construed to amend, modify, alter, change or supersede the terms and provisions of the Borrower Note, the Security Instrument or the Borrower Loan Agreement; and, if there is a conflict between the terms and provisions of this Assignment and those of the Borrower Note, the Security Instrument or the Borrower Loan Agreement, then the terms and provisions of the Borrower Note, the Security Instrument or the Borrower Loan Agreement shall control. 22. Limitation of Liability. The personal liability of Assignor for the payment and performance of the obligations hereunder is limited in the manner and to the extent provided in the Borrower Note. 23. Notices. All notices to be given by Assignee to Manager shall be given to Manager, at the address set forth below Manager’s signature block to this Assignment, in the same manner as notices to Assignor pursuant to the notice provisions contained in the Security Instrument. All other notices given under this Assignment shall be in writing and shall be sent to the respective addresses of the parties, in the manner set forth in the Security Instrument. 24. Counterparts. This Assignment may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. 25. Captions. The captions of the sections of this Assignment are for convenience only and shall be disregarded in construing this Assignment. 26. Servicer. Each of Assignor and Manager hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Assignee may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under the Borrower Note, this Assignment or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Assignor receives written notice from Assignee to the contrary, any action or right which shall or may be taken or exercised by Assignee may be taken or exercised by such servicer with the same force and effect. Assignment of Management Agreement 8 Vista Breeze 27. Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Assignment for all purposes. 28. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF ASSIGNOR, MANAGER AND THE BENEFICIARY PARTIES (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS ASSIGNMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 29. Time of the Essence. Time is of the essence with respect to this Assignment. 30. Modifications. All modifications (if any) to the terms of this Assignment (“Modifications”) are set forth on Exhibit A attached to this Assignment. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer that does not require the consent of the Funding Lender), some or all of the Modifications to this Assignment may be modified or rendered void by Assignee at its option by notice to Assignor, Manager or such transferee. 31. Attached Exhibit. The following Exhibit is attached to this Assignment and is incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Modifications to Assignment of Management Agreement The terms of this Assignment are modified and supplemented as set forth in said Exhibit. To the extent of any conflict or inconsistency between the terms of said Exhibit and the text of this Assignment, the terms of said Exhibit shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Assignment of Management Agreement S-1 Vista Breeze IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Assignment of Management Agreement or caused this Assignment of Management Agreement to be duly executed and delivered by their respective duly authorized representatives as of the date first set forth above. ASSIGNOR: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: Assignment of Management Agreement S-2 Vista Breeze MANAGER: ATLANTIC PACIFIC COMMUNITY MANAGEMENT, LLC, a Delaware limited liability company By: __________________________ Name: Title: Manager’s Address for Notices: Atlantic Pacific Community Management, LLC 161 NW 6th Street, Suite 1020 Miami, FL 33136 Attn: Kenneth Naylor Assignment of Management Agreement A-1 Vista Breeze EXHIBIT A MODIFICATIONS TO ASSIGNMENT OF MANAGEMENT AGREEMENT The following modifications are made to the text of the Assignment that precedes this Exhibit: 1. The Assignment is modified by adding a new Section 32 and a new Section 33 as follows: 32. Further Agreements. Manager agrees that: (a) (i) any fees payable to Manager pursuant to the Management Agreement in excess of the Underwritten Management Fee (as such term is defined in the Loan Covenant Agreement) (any such fees in excess of the Underwritten Management Fee being sometimes collectively referred to in this Assignment as the “Subordinated Fees”) are and shall be subordinated in right of payment, to the extent and in the manner provided in this Assignment, to the prior payment in full of the Indebtedness (as defined in the Security Instrument), and (ii) the Management Agreement is and shall be subject and subordinate in all respects to the liens, terms, covenants and conditions of the Security Instrument and the other loan documents evidencing and securing the Borrower Loan and to all advances heretofore made or which may hereafter be made pursuant to the Security Instrument (including all sums advanced for the purposes of (x) protecting or further securing the lien of the Security Instrument, curing defaults by Assignor under the Security Instrument or for any other purposes expressly permitted by the Security Instrument, or (y) constructing, renovating, repairing, furnishing, fixturing or equipping the Mortgaged Property); (b) if, by reason of its exercise of any other right or remedy under the Management Agreement, Manager acquires by right of subrogation or otherwise a lien on the Mortgaged Property which (but for this subsection) would be senior to the lien of the Security Instrument, then, in that event, such lien shall be subject and subordinate to the lien of the Security Instrument; (c) until Manager receives notice (or otherwise acquires actual knowledge) of an Event of Default, Manager shall be entitled to retain for its own account all payments made under or pursuant to the Management Agreement; (d) after Manager receives notice (or otherwise acquires actual knowledge) of an Event of Default, it will not accept any payment of any Subordinated Fees under or pursuant to the Management Agreement without Assignee’s prior written consent; (e) if, after Manager receives notice (or otherwise acquires actual knowledge) of an Event of Default, Manager receives any payment of any Subordinated Fees under the Management Agreement, or if Manager receives any other payment or distribution of any kind from Assignor or from any other person or entity in connection with the Management Agreement which Manager is not permitted by this Assignment to retain for its own account, such payment or other distribution will be received and held in trust for Assignee and unless Assignee otherwise notifies Manager, will be promptly remitted, in Assignment of Management Agreement A-2 Vista Breeze cash or readily available funds, to Assignee, properly endorsed to Assignee, to be applied to the principal of, interest on and other amounts due under the Borrower Loan Documents in such order and in such manner as Assignee shall determine in its sole and absolute discretion. Manager hereby irrevocably designates, makes, constitutes and appoints Assignee (and all persons or entities designated by Assignee) as Manager’s true and lawful attorney in fact with power to endorse the name of Manager upon any checks representing payments referred to in this subsection; (f) Manager shall notify (telephonically, followed by written notice) Assignee of Manager’s receipt from any person or entity other than Assignor of a payment with respect to Assignor’s obligations under the Borrower Loan Documents, promptly after Manager obtains knowledge of such payment; and (g) during the term of this Assignment, Manager will not commence, or join with any other creditor in commencing any bankruptcy, reorganization, arrangement, insolvency or liquidation proceedings with respect to Assignor, without Assignee’s prior written consent. 33. Payment of Management Fees Upon Event of Default. Assignor agrees that after Assignor receives notice (or otherwise has actual knowledge) of an Event of Default, it will not make any payment of any Subordinated Fees under or pursuant to the Management Agreement without Assignee’s prior written consent. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Assignment. 4870-3429-9274v.4 D Forward Purchase Agreement Vista Breeze EXHIBIT D-9 TO FORWARD PURCHASE AGREEMENT FORM OF AGREEMENT OF ENVIRONMENTAL INDEMNIFICATION [See attached] EXHIBIT D-9 TO FORWARD PURCHASE AGREEMENT FORM OF AGREEMENT OF ENVIRONMENTAL INDEMNIFICATION This AGREEMENT OF ENVIRONMENTAL INDEMNIFICATION (this “Agreement”) is entered into as of the [____] day of [Month], 202[_] by HOWARD D. COHEN REVOCABLE TRUST U/A/D/ 4/6/1993 (the “Guarantor”) and VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”; and together with the Guarantor, collectively, jointly and severally, the “Indemnitor”), for the benefit of Beneficiary Parties (as defined herein). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Closing Date (as defined in the Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title in the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. A. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. 2 Vista Breeze B. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. C. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. D. At the request of Borrower, the Borrower, Original Funding Lender and Funding Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Funding Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). E. Insofar as the Loan Purchase Conditions have been satisfied or waived, Funding Lender has acquired the Funding Loan from the Original Funding Lender, and in connection therewith, (i) Funding Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement dated as of the date hereof (the “Funding Loan Agreement”) by and among Governmental Lender, Fiscal Agent, and Funding Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement dated as of the date hereof (the “Borrower Loan Agreement”) which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [Month] [Day], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN-OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Funding Lender and Borrower have entered into a certain Loan Covenant Agreement and dated as of the date hereof (the “Loan Covenant Agreement”; together with the Borrower Note, the Security Instrument, the Borrower Loan Agreement and all other documents executed in connection with the Borrower Loan, including this Agreement, the “Borrower Loan Documents”). F. The term “Beneficiary Parties” as used herein shall mean Governmental Lender, Funding Lender, Fiscal Agent, any Servicer and their respective successors and assigns. The term “Beneficiary Parties” shall also include any lawful owner, holder or pledgee of the Borrower Note. G. Guarantor acknowledges that it will receive substantial economic and other benefits from the Funding Loan, Borrower Loan and the purchase of the Funding Loan by Funding Lender. 3 Vista Breeze H. As a condition to the purchase of the Funding Loan by Funding Lender, each Indemnitor is required to enter into this Agreement. NOW THEREFORE, in consideration of the Funding Loan, the Borrower Loan and the purchase of the Funding Loan by Funding Lender, and in order to induce Beneficiary Parties to consummate said transactions, each Indemnitor agrees for the benefit of Beneficiary Parties as follows: 1. Recitals. The parties agree the recitals are true and correct, and are incorporated herein by reference. 2. Certain Definitions. Capitalized terms used but not defined in this Agreement shall have the meanings assigned to them in the Security Instrument. The following terms, when used herein, shall have the following meanings: (a) “Hazardous Materials” means petroleum and petroleum products and compounds containing them, including gasoline, diesel fuel and oil; explosives; flammable materials; radioactive materials; polychlorinated biphenyls (“PCBs”) and compounds containing them; lead and lead-based paint; asbestos or asbestos-containing materials in any form that is or could become friable; underground or above-ground storage tanks, whether empty or containing any substance; radon; Mold; toxic or mycotoxin spores; any substance the presence of which on the Mortgaged Property is prohibited by any federal, state or local authority; any substance that requires special handling under any Hazardous Materials Law; and any other material or substance (whether or not naturally occurring) now or in the future that (i) is defined as a “hazardous substance,” “hazardous material,” “hazardous waste,” “toxic substance,” “toxic pollutant,” “solid waste,” “pesticide,” “contaminant,” or “pollutant” or otherwise classified as hazardous or toxic by or within the meaning of any Hazardous Materials Law, or (ii) is regulated in any way by or within the meaning of any Hazardous Materials Law. (b) “Hazardous Materials Law” means all federal, state, and local laws, ordinances and regulations and standards, rules, policies and other governmental requirements, rules of common law (including without limitation nuisance and trespass), consent order, administrative rulings and court judgments and decrees or other government directive in effect now or in the future and including all amendments, that relate to Hazardous Materials or to the protection or conservation of the environment or human health and apply to any Indemnitor or to the Mortgaged Property, including without limitation those relating to industrial hygiene, or the use, analysis, generation, manufacture, storage, discharge, release, disposal, transportation, treatment, investigation or remediation of Hazardous Materials. Hazardous Materials Laws include, but are not limited to, the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. Section 9601, et seq., the Resource Conservation and Recovery Act, 42 U.S.C. Section 6901, et seq., the Toxic Substances Control Act, 15 U.S.C. Section 2601, et seq., the Clean Water Act, 33 U.S.C. Section 1251, et seq., the Hazardous Materials Transportation Act, 49 U.S.C. Section 5101, et seq., the Superfund Amendments and 4 Vista Breeze Reauthorization Act, the Solid Waste Disposal Act, the Clean Air Act, the Occupational Safety and Health Act, and their state analogs. (c) “Indemnitees” for purposes of this Agreement, means collectively Beneficiary Parties and their successors, assigns, and transferees and the officers, directors, shareholders, partners, members, trustees, heirs, legal representatives, employees and agents of Beneficiary Parties and their successors, assigns and transferees. (d) “Mold” means mold, fungus, microbial contamination or pathogenic organisms. (e) “O&M Program” shall have the meaning set forth in Section 3(d) hereof. 3. Prohibited Activities or Conditions. (a) Except for matters described in Section 3(b), no Indemnitor shall cause or permit any of the following: (i) the presence, use, generation, release, treatment, processing, storage (including storage in above ground and underground storage tanks), handling, or disposal of any Hazardous Materials on or under the Mortgaged Property (whether as a result of activities on the Mortgaged Property or on surrounding properties) or any other property of any Indemnitor that is adjacent to the Mortgaged Property; (ii) the transportation of any Hazardous Materials to, from, or across the Mortgaged Property (whether as a result of activities on the Mortgaged Property or on surrounding properties); (iii) any occurrence or condition on the Mortgaged Property (whether as a result of activities on the Mortgaged Property or on surrounding properties) or any other property of any Indemnitor that is adjacent to the Mortgaged Property, which occurrence or condition is or may be in violation of Hazardous Materials Laws; (iv) any violation of or noncompliance with the terms of any Environmental Permit with respect to the Mortgaged Property or any property of any Indemnitor that is adjacent to the Mortgaged Property; (v) the imposition of any environmental lien against the Mortgaged Property; or (vi) any violation or noncompliance with the terms of any O&M Program. The matters described in clauses (i) through (vi) above, except as otherwise provided in Section 3(b), are referred to collectively in this Agreement as “Prohibited Activities or Conditions”. 5 Vista Breeze (b) Prohibited Activities or Conditions shall not include lawful conditions permitted by an O&M Program or the safe and lawful use, transportation and storage of quantities of (1) pre-packaged supplies, cleaning materials, petroleum products, household products, paints, solvents, lubricants and other materials customarily used in the construction, operation, maintenance or use of comparable multifamily properties, (2) cleaning materials, household products, personal grooming items and other items sold in pre-packaged containers for consumer use and used by tenants and occupants of residential dwelling units in the Mortgaged Property, and (3) petroleum products used in the operation and maintenance of motor vehicles from time to time located on the Mortgaged Property’s parking areas, so long as all of the foregoing are used, stored, handled, transported and disposed of in compliance with Hazardous Materials Laws. (c) Each Indemnitor shall take all commercially reasonable actions (including the inclusion of appropriate provisions in any Leases executed after the date hereof) to prevent its employees, agents, and contractors, and all tenants and other occupants from causing or permitting any Prohibited Activities or Conditions. Indemnitor shall not lease or allow the sublease or use of all or any portion of the Mortgaged Property to any tenant or subtenant for nonresidential use by any user that, in the ordinary course of its business, would cause or permit any Prohibited Activity or Condition. (d) If and as required by Funding Lender, Borrower shall also establish a written operations and maintenance program with respect to certain Hazardous Materials. Each such operations and maintenance program and any additional or revised operations and maintenance programs established for the Mortgaged Property pursuant to this Agreement must be approved by Funding Lender and shall be referred to herein as an “O&M Program.” Borrower shall comply in a timely manner with, and cause all of its employees, agents, and contractors and any other persons present on the Mortgaged Property to comply with each O&M Program. Borrower shall pay all costs of performance of its obligations under any O&M Program, and any Beneficiary Party’s out-of-pocket costs incurred by such Beneficiary Party in connection with the monitoring and review of each O&M Program and Borrower’s performance shall be paid by Borrower upon demand by such Beneficiary Party. (e) Without limitation of the foregoing, (1) Borrower hereby agrees to implement and maintain during the entire term of the Borrower Loan the moisture management program/microbial operations and maintenance program as described in the Loan Covenant Agreement, and (2) if asbestos-containing materials are found to exist at the Mortgaged Property, the O&M Program with respect thereto shall be undertaken consistent with the Guidelines for Controlling Asbestos-Containing Materials in Buildings (USEPA, 1985) and other relevant guidelines and applicable Hazardous Materials Laws. (f) With respect to any O&M Program, Funding Lender may require (1) periodic notices or reports to Funding Lender in form, substance and at such intervals as Funding Lender may specify; (2) amendments to such O&M Program to address changing circumstances, laws or other matters, including without limitation variations in response to reports provided by environmental consultants; and (3) execution of an 6 Vista Breeze Operations and Maintenance Agreement relating to such O&M Program reasonably satisfactory to Funding Lender. 4. Representations and Warranties. Each Indemnitor represents and warrants to Beneficiary Parties that, except as otherwise disclosed in the environmental reports described on Exhibit A (the “Environmental Reports”): (a) Indemnitor has not at any time engaged in, caused or permitted any Prohibited Activities or Conditions; (b) to the best of Indemnitor’s knowledge after reasonable and diligent inquiry, no Prohibited Activities or Conditions exist or have existed; and Indemnitor has provided Funding Lender with copies of all reports and information acquired in such inquiries; (c) the Mortgaged Property (1) does not now contain any underground storage tanks, and (2) to the best of Indemnitor’s knowledge, has not contained any underground storage tanks in the past. If there is an underground storage tank located on the Mortgaged Property which has been disclosed in the Environmental Reports, that tank complies with all requirements of Hazardous Materials Laws; (d) Indemnitor has complied with and will continue to comply with all Hazardous Materials Laws, including all requirements for notification regarding releases of Hazardous Materials. Without limiting the generality of the foregoing, Indemnitor has obtained all Environmental Permits required for the operation of the Mortgaged Property in accordance with Hazardous Materials Laws now in effect and all such Environmental Permits are in full force and effect; (e) to the best of Indemnitor’s knowledge, after reasonable and diligent inquiry, no event has occurred with respect to the Mortgaged Property that constitutes, or with the passing of time or the giving of notice would constitute, noncompliance with the terms of any Environmental Permit or Hazardous Materials Law; (f) there are no actions, suits, claims or proceedings pending or, to the best of Indemnitor’s knowledge after reasonable and diligent inquiry, threatened that involve the Mortgaged Property and allege, arise out of, or relate to any Prohibited Activity or Condition; (g) Indemnitor has not received any complaint, order, notice of violation or other communication from any Governmental Authority with regard to air emissions, water discharges, noise emissions or Hazardous Materials, or any other environmental, health or safety matters affecting the Mortgaged Property or any other property of Indemnitor that is adjacent to the Mortgaged Property; (h) no prior Remedial Work (as defined below) has been undertaken, and no Remedial Work is ongoing, with respect to the Mortgaged Property during Borrower’s ownership thereof or, to the best of Indemnitor’s knowledge after reasonable and diligent 7 Vista Breeze inquiry, at any time prior to Borrower’s ownership thereof, except as set forth in the Environmental Reports; and (i) Indemnitor has disclosed herein all material facts known to Indemnitor or contained in Indemnitor’s records, the nondisclosure of which could cause any representation and warranty made herein or any statement made in the Environmental Report to be false or materially misleading. The representations and warranties in this Agreement shall be continuing representations and warranties that shall be deemed to be made by each Indemnitor throughout the term of the Borrower Loan until the Indebtedness has been paid in full or otherwise discharged. 5. Covenants of Indemnitor. Each Indemnitor does hereby covenant and agree with Indemnitees that: (a) Indemnitor shall promptly notify Funding Lender in writing upon the occurrence of any of the following events: (i) Indemnitor’s discovery of any Prohibited Activity or Condition; (ii) Indemnitor’s receipt of or knowledge of any complaint, order, notice of violation or other communication from any tenant, management agent, Governmental Authority or other person with regard to present or future alleged Prohibited Activities or Conditions or any other environmental, health or safety matters affecting the Mortgaged Property or any other property of any Indemnitor that is adjacent to the Mortgaged Property; (iii) Indemnitor’s receipt of or knowledge of any personal injury claim, proceeding or cause of action directly or indirectly arising as a result of the presence of asbestos or other Hazardous Materials on or from the Mortgaged Property; (iv) Indemnitor’s discovery that any representation or warranty in this Agreement has become untrue after the date of this Agreement; and (v) any Indemnitor’s breach of any of its obligations under this Agreement. Any such notice given by Indemnitor shall not relieve Indemnitor of, or result in a waiver of, any obligation under this Agreement, or any Borrower Loan Document. (b) Indemnitor shall pay promptly the costs of any environmental inspections, tests or audits (“Environmental Inspections”) required by Funding Lender or any Beneficiary Party in connection with any foreclosure or deed in lieu of foreclosure, or as a condition of Funding Lender’s consent to any Transfer, or required by Funding Lender following a reasonable determination by Funding Lender that Prohibited Activities or Conditions may exist. The results of all Environmental Inspections shall at all times remain the property of Funding Lender and Funding Lender shall have no obligation to 8 Vista Breeze disclose or otherwise make available to Indemnitor or any other party such results or any other information obtained by Funding Lender in connection with its Environmental Inspections. Funding Lender hereby reserves the right, and Indemnitor hereby expressly authorizes Funding Lender, to make available to any party, including any prospective bidder at a foreclosure sale of the Mortgaged Property, the results of any Environmental Inspections with respect to the Mortgaged Property. Indemnitor consents to Funding Lender notifying any party (either as part of a notice of sale or otherwise) of the results of any Environmental Inspections. Indemnitor acknowledges that Beneficiary Parties cannot control or otherwise assure the truthfulness or accuracy of the results of any of the Environmental Inspections and that the release of such results to prospective bidders at a foreclosure sale of the Mortgaged Property may have a material and adverse effect upon the amount which a party may bid at such sale. Indemnitor agrees that no Beneficiary Party shall have any liability whatsoever as a result of delivering the results of any of the Environmental Inspections to any third party, and Indemnitor hereby releases and forever discharges Beneficiary Parties from any and all claims, damages, or causes of action, arising out of, connected with or incidental to the results of, the delivery of any Environmental Inspections. (c) If any investigation, site monitoring, containment, clean-up, restoration or other remedial work (“Remedial Work”) is necessary to comply with or cure a violation of any Hazardous Materials Law or order of any Governmental Authority that has or acquires jurisdiction over the Mortgaged Property or the use, operation or improvement of the Mortgaged Property under any Hazardous Materials Law, or is otherwise required by Funding Lender as a consequence of any Prohibited Activity or Condition or to prevent the occurrence of a Prohibited Activity or Condition, Indemnitor shall, by the earlier of (1) the applicable deadline required by such Hazardous Materials Law or (2) thirty (30) days after notice from Funding Lender, demanding such action, begin performing the Remedial Work, and thereafter diligently prosecute it to completion, and shall in any event complete the work by the time required by such Hazardous Materials Law. Indemnitor shall promptly provide Funding Lender with a cost estimate from an environmental consultant reasonably acceptable to Funding Lender to complete any required Remedial Work. If required by Funding Lender, Indemnitor shall promptly establish with Funding Lender a reserve fund in the amount of such estimate. If, in Funding Lender’s reasonable opinion, the amount reserved at any time during the Remedial Work is insufficient to cover the work remaining to complete the Remedial Work or achieve compliance, Indemnitor shall increase the amount reserved in compliance with Funding Lender’s written request. All amounts so held in reserve, until disbursed, are pledged to Beneficiary Parties as security for payment of Indemnitor’s obligations under this Agreement. If Indemnitor fails to begin on a timely basis or diligently prosecute any required Remedial Work, Funding Lender may, at its option, cause the Remedial Work to be completed, in which case Indemnitor shall reimburse Beneficiary Parties on demand for the cost of doing so. (d) Indemnitor shall comply with all Hazardous Materials Laws applicable to the Mortgaged Property. Without limiting the generality of the previous sentence, Indemnitor shall (1) obtain and maintain all Environmental Permits required by Hazardous Materials Laws and comply with all conditions of such Environmental 9 Vista Breeze Permits; (2) cooperate with any inquiry by any Governmental Authority; and (3) comply with any governmental or judicial order that arises from any alleged Prohibited Activity or Condition. 6. Indemnification. (a) INDEMNITOR SHALL INDEMNIFY, HOLD HARMLESS AND DEFEND INDEMNITEES FROM AND AGAINST ALL LOSSES, PROCEEDINGS, CLAIMS, DAMAGES, PENALTIES AND COSTS (WHETHER INITIATED OR SOUGHT BY GOVERNMENTAL AUTHORITIES OR PRIVATE PARTIES), INCLUDING, WITHOUT LIMITATION, FEES AND OUT-OF-POCKET EXPENSES OF ATTORNEYS AND EXPERT WITNESSES, ENGINEERING FEES, ENVIRONMENTAL CONSULTANT FEES, INVESTIGATORY FEES AND REMEDIATION COSTS (INCLUDING, WITHOUT LIMITATION, ANY FINANCIAL ASSURANCES REQUIRED TO BE POSTED FOR COMPLETION OF REMEDIAL WORK AND COSTS ASSOCIATED WITH ADMINISTRATIVE OVERSIGHT), AND OF ANY LIABILITIES OF WHATEVER KIND AND NATURE, WHETHER INCURRED IN CONNECTION WITH ANY JUDICIAL OR ADMINISTRATIVE PROCESS OR OTHERWISE, ARISING DIRECTLY OR INDIRECTLY FROM ANY OF THE FOLLOWING: (i) ANY BREACH OF ANY REPRESENTATION OR WARRANTY OF ANY INDEMNITOR IN THIS AGREEMENT; (ii) ANY FAILURE BY ANY INDEMNITOR TO PERFORM ANY OF ITS OBLIGATIONS UNDER THIS AGREEMENT; (iii) THE EXISTENCE OR ALLEGED EXISTENCE OF ANY PROHIBITED ACTIVITY OR CONDITION; (iv) THE PRESENCE OR ALLEGED PRESENCE OF HAZARDOUS MATERIALS ON OR UNDER THE MORTGAGED PROPERTY OR IN ANY OF THE IMPROVEMENTS OR ON OR UNDER ANY PROPERTY OF ANY INDEMNITOR THAT IS ADJACENT TO THE MORTGAGED PROPERTY; (v) THE ACTUAL OR ALLEGED VIOLATION OF ANY HAZARDOUS MATERIALS LAW; (vi) ANY LOSS OR DAMAGE RESULTING FROM A LOSS OF PRIORITY OF THE SECURITY INSTRUMENT OR ANY OTHER BORROWER LOAN DOCUMENT DUE TO AN IMPOSITION OF A LIEN AGAINST THE MORTGAGED PROPERTY; AND (vii) ANY PERSONAL INJURY CLAIM, PROCEEDING OR CAUSE OF ACTION DIRECTLY OR INDIRECTLY ARISING AS A RESULT OF THE PRESENCE OF ASBESTOS OR OTHER HAZARDOUS MATERIALS ON OR FROM THE MORTGAGED PROPERTY. 10 Vista Breeze (b) COUNSEL SELECTED BY ANY INDEMNITOR TO DEFEND INDEMNITEES SHALL BE SUBJECT TO THE APPROVAL OF THOSE INDEMNITEES. IN ANY CIRCUMSTANCES IN WHICH THE INDEMNITY UNDER THIS AGREEMENT APPLIES, ANY BENEFICIARY PARTY MAY EMPLOY ITS OWN LEGAL COUNSEL AND CONSULTANTS TO PROSECUTE, DEFEND OR NEGOTIATE ANY CLAIM OR LEGAL OR ADMINISTRATIVE PROCEEDING AT INDEMNITOR’S EXPENSE, AND SUCH BENEFICIARY PARTY, WITH THE PRIOR WRITTEN CONSENT OF INDEMNITOR (WHICH SHALL NOT BE UNREASONABLY WITHHELD, DELAYED OR CONDITIONED) MAY SETTLE OR COMPROMISE ANY ACTION OR LEGAL OR ADMINISTRATIVE PROCEEDING. INDEMNITOR SHALL REIMBURSE SUCH BENEFICIARY PARTY UPON DEMAND FOR ALL COSTS AND EXPENSES INCURRED BY SUCH BENEFICIARY PARTY, INCLUDING, WITHOUT LIMITATION, ALL COSTS OF SETTLEMENTS ENTERED INTO IN GOOD FAITH AND THE FEES AND OUT-OF-POCKET EXPENSES OF SUCH ATTORNEYS AND CONSULTANTS. (c) INDEMNITOR SHALL NOT, WITHOUT THE PRIOR WRITTEN CONSENT OF THOSE INDEMNITEES WHO ARE NAMED AS PARTIES TO A CLAIM OR LEGAL OR ADMINISTRATIVE PROCEEDING (A “CLAIM”), SETTLE OR COMPROMISE THE CLAIM IF THE SETTLEMENT (1) RESULTS IN THE ENTRY OF ANY JUDGMENT THAT DOES NOT INCLUDE AS AN UNCONDITIONAL TERM THE DELIVERY BY THE CLAIMANT OR PLAINTIFF TO BENEFICIARY PARTIES OF A WRITTEN RELEASE OF THOSE INDEMNITEES, SATISFACTORY IN FORM AND SUBSTANCE TO FUNDING LENDER; OR (2) MAY MATERIALLY AND ADVERSELY AFFECT BENEFICIARY PARTIES, AS DETERMINED BY FUNDING LENDER IN ITS DISCRETION. (d) INDEMNITOR’S OBLIGATION TO INDEMNIFY THE INDEMNITEES SHALL NOT BE LIMITED OR IMPAIRED BY ANY OF THE FOLLOWING, OR BY ANY FAILURE OF ANY INDEMNITOR OR ANY GUARANTOR TO RECEIVE NOTICE OF OR CONSIDERATION FOR ANY OF THE FOLLOWING: (i) ANY AMENDMENT OR MODIFICATION OF ANY BORROWER LOAN DOCUMENT; (ii) ANY EXTENSIONS OF TIME FOR PERFORMANCE REQUIRED BY ANY BORROWER LOAN DOCUMENT; (iii) ANY PROVISION IN ANY BORROWER LOAN DOCUMENT LIMITING BENEFICIARY PARTIES’ RECOURSE TO ANY PROPERTY SECURING THE INDEBTEDNESS, OR LIMITING THE PERSONAL LIABILITY OF ANY INDEMNITOR OR ANY OTHER PARTY FOR PAYMENT OF ALL OR ANY PART OF THE INDEBTEDNESS; 11 Vista Breeze (iv) THE ACCURACY OR INACCURACY OF ANY REPRESENTATIONS AND WARRANTIES MADE BY ANY INDEMNITOR UNDER THIS AGREEMENT OR ANY BORROWER LOAN DOCUMENT; (v) THE RELEASE OF ANY INDEMNITOR OR ANY OTHER PERSON, BY BENEFICIARY PARTIES OR BY OPERATION OF LAW, FROM PERFORMANCE OF ANY OBLIGATION UNDER ANY BORROWER LOAN DOCUMENT; (vi) THE RELEASE OR SUBSTITUTION IN WHOLE OR IN PART OF ANY SECURITY FOR THE INDEBTEDNESS; AND (vii) FAILURE BY BENEFICIARY PARTIES TO PROPERLY PERFECT ANY LIEN OR SECURITY INTEREST GIVEN AS SECURITY FOR THE INDEBTEDNESS. (e) INDEMNITOR SHALL, AT ITS OWN COST AND EXPENSE, DO ALL OF THE FOLLOWING: (i) PAY OR SATISFY ANY JUDGMENT OR DECREE THAT MAY BE ENTERED AGAINST ANY INDEMNITEE OR INDEMNITEES IN ANY LEGAL OR ADMINISTRATIVE PROCEEDING INCIDENT TO ANY MATTERS AGAINST WHICH INDEMNITEES ARE ENTITLED TO BE INDEMNIFIED UNDER THIS AGREEMENT; (ii) REIMBURSE INDEMNITEES FOR ANY AND ALL EXPENSES PAID OR INCURRED IN CONNECTION WITH ANY MATTERS AGAINST WHICH INDEMNITEES ARE ENTITLED TO BE INDEMNIFIED UNDER THIS AGREEMENT; AND (iii) REIMBURSE INDEMNITEES FOR ANY AND ALL EXPENSES, INCLUDING, WITHOUT LIMITATION, FEES AND OUT-OF- POCKET EXPENSES OF ATTORNEYS AND EXPERT WITNESSES, PAID OR INCURRED IN CONNECTION WITH THE ENFORCEMENT BY INDEMNITEES OF THEIR RIGHTS UNDER THIS AGREEMENT, OR IN MONITORING AND PARTICIPATING IN ANY LEGAL OR ADMINISTRATIVE PROCEEDING. 7. Obligation Not Secured by Security Instrument. Notwithstanding any provision of the Security Instrument or any of the other Borrower Loan Documents to the contrary: (i) the rights of the Beneficiary Parties under this Agreement shall not be secured by the Security Instrument, and (ii) the rights of the Beneficiary Parties under this Agreement shall not be affected by any provision of the Borrower Loan Documents limiting Funding Lender’s or any other party’s recourse or Indemnitor’s or any other party’s liability for the Borrower Loan or any other Indebtedness. 8. Survival. This Agreement shall survive the satisfaction or release of the Security Instrument and the other Borrower Loan Documents by full and final payment of all obligations 12 Vista Breeze of Indemnitor to Beneficiary Parties, by foreclosure of Borrower’s equity of redemption in the Mortgaged Property (whether by power of sale or judicial proceedings), by deed in lieu of foreclosure or by any other comparable means and the conveyance or disposition of any Indemnitor’s interest in the Mortgaged Property, and shall continue in full force and effect forever, irrespective of any such foreclosure and/or satisfaction of the obligations of any Indemnitor in connection with the Borrower Loan. 9. Conflicting Provisions. Borrower acknowledges and agrees that its covenants and obligations hereunder are in addition to, and separate and distinct from, the obligations under the Security Instrument. 10. Joint and Several Liability. If more than one person executes this Agreement, the obligations of those persons under this Agreement and any other Indemnitor (an “Other Indemnitor”) shall be joint and several. Beneficiary Parties, in their sole and absolute discretion, may (a) bring suit against Indemnitor, or any one or more of the persons constituting Indemnitor, and any Other Indemnitor, jointly and severally, or against any one or more of them; (b) compromise or settle with any one or more of the persons constituting Indemnitor or any Other Indemnitor for such consideration as Beneficiary Parties may deem proper; (c) release one or more of the persons constituting Indemnitor, or any Other Indemnitor, from liability; and/or (d) otherwise deal with Indemnitor and any Other Indemnitor, or any one or more of them, in any manner, and no such action shall impair the rights of Beneficiary Parties to collect from Indemnitor any amount owed by Indemnitor under this Agreement. Nothing contained in this paragraph shall in any way affect or impair the rights or obligations of Indemnitor with respect to any Other Indemnitor. 11. Intentionally Omitted. 12. Determinations by Funding Lender. Except to the extent expressly set forth in this Agreement to the contrary, in any instance where the consent or approval of Funding Lender may be given or is required, or where any determination, judgment or decision is to be rendered by Funding Lender under this Agreement, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised by Funding Lender, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. 13. Release; Indemnity. (a) Release. Without limiting the provisions of Section 6, Indemnitor covenants and agrees that, in performing any of their rights or duties under this Agreement, neither the Beneficiary Parties, nor their agents or employees, shall be liable for any losses, claims, damages, liabilities and expenses that may be incurred by any of them as a result of such performance, except to the extent such liability for any losses, claims, damages, liabilities or expenses arises out of the willful misconduct or gross negligence of such party. (b) Indemnity. Without limiting the provisions of Section 6, Indemnitor hereby agrees to indemnify and hold harmless the Beneficiary Parties and their respective 13 Vista Breeze agents and employees from and against any and all losses, claims, damages, liabilities and expenses including, without limitation, reasonable attorneys’ fees and costs and disbursements, which may be imposed or incurred by any of them in connection with this Agreement, except that no such party will be indemnified for any losses, claims, damages, liabilities or expenses arising out of the willful misconduct or gross negligence of such party. 14. Governing Law. This Agreement shall be governed by and enforced in accordance with the laws of the Property Jurisdiction, without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 15. Consent to Jurisdiction and Venue. Indemnitor agrees that any controversy arising under or in relation to this Agreement shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Agreement. Indemnitor irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Agreement against Indemnitor or any of Indemnitor’s assets in any court of any other jurisdiction. 16. Successors and Assigns. This Agreement shall be binding upon Indemnitor and its heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, and shall inure to the benefit of the Beneficiary Parties and their respective successors, successors-in- interest and assigns. The terms used to designate any of the parties herein shall be deemed to include the heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, of such parties. References to a “person” or “persons” shall be deemed to include individuals and entities. Indemnitor acknowledges and agrees that any Beneficiary Party, at its option, may assign its respective rights and interests under this Agreement and the other Borrower Loan Documents in whole or in part and upon such assignment all the terms and provisions of this Agreement or the other Borrower Loan Documents shall inure to the benefit of such assignee to the extent so assigned. Indemnitor may not assign or delegate its rights, interests or obligations under this Agreement without first obtaining Funding Lender’s prior written consent. 17. Severability. The invalidity, illegality or unenforceability of any provision of this Agreement shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 18. Expenses. Indemnitor shall pay to the Beneficiary Parties, upon demand, the amount of any and all expenses, including, without limitation, reasonable attorneys’ fees (including reasonable time charges of attorneys who may be employees of Beneficiary Parties), which the Beneficiary Parties may incur in connection with (a) the exercise or enforcement of any of their rights hereunder, (b) the failure by Indemnitor to perform or observe any of the provisions hereof, or (c) the breach by Indemnitor of any representation or warranty of 14 Vista Breeze Indemnitor set forth herein. Such expenses, together with interest thereon computed at the Default Rate set forth in the Borrower Note from the date on which such expenses are incurred to the date of payment thereof, shall constitute indebtedness secured by the Security Instrument. 19. Remedies Cumulative. In the event of Indemnitor’s default under this Agreement, the Beneficiary Parties may exercise all or any one or more of their rights and remedies available under this Agreement, at law or in equity. Such rights and remedies shall be cumulative and concurrent, and may be enforced separately, successively or together, and the exercise of any particular right or remedy shall not in any way prevent the Beneficiary Parties from exercising any other right or remedy available to the Beneficiary Parties. The Beneficiary Parties may exercise any such remedies from time to time as often as may be deemed necessary by the Beneficiary Parties. 20. No Agency or Partnership. Nothing contained in this Agreement shall constitute any Beneficiary Party as a joint venturer, partner or agent of Indemnitor, or render any Beneficiary Party liable for any debts, obligations, acts, omissions, representations or contracts of Indemnitor. 21. Transfer of Mortgaged Property or Ownership Interests in Borrower. If a Transfer (as defined in the Security Instrument) of all or part of the Mortgaged Property or of an ownership interest in Borrower shall occur, which Transfer requires the prior written consent of Funding Lender, the transferee(s) shall be required to assume the transferor’s duties and obligations under this Agreement and the other Borrower Loan Documents and shall be required to execute and deliver to Funding Lender such documents as Funding Lender requires to effectuate such assumption of duties and obligations. No transfer and assumption shall relieve the transferor of any of its duties or obligations under this Agreement or any of the other Borrower Loan Documents, unless the Borrower has obtained the prior written consent of Funding Lender to the release of such duties and obligations. 22. Entire Agreement; Amendment and Waiver. This Agreement contains the complete and entire understanding of the parties with respect to the matters covered herein. This Agreement may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Agreement shall be considered as a general waiver. 23. Further Assurances. Indemnitor shall at any time and from time to time, promptly execute and deliver all further instruments and documents, and take all further action that may be reasonably necessary or desirable, or that any Beneficiary Party may reasonably request, in order to protect any right or interest granted by this Agreement or to enable the Beneficiary Party to exercise and enforce its rights and remedies under this Agreement. 24. No Amendment; Conflicts. Nothing contained in this Agreement shall be construed to amend, modify, alter, change or supersede the terms and provisions of the Borrower Note, the Security Instrument or the Borrower Loan Agreement; and, if there is a conflict between the terms and provisions of this Agreement and those of the Borrower Note, the 15 Vista Breeze Security Instrument or the Borrower Loan Agreement, then the terms and provisions of the Borrower Note, the Security Instrument or the Borrower Loan Agreement shall control. 25. Notices. All notices to be given by any Beneficiary Party to Guarantor shall be given to Borrower, at the address and in the same manner as notices to Borrower pursuant to the notice provisions contained in the Security Instrument. All other notices given under this Agreement shall be in writing and shall be sent to the respective addresses of the parties, in the manner set forth in the Security Instrument. 26. Counterparts. This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. 27. Captions. The captions of the sections of this Agreement are for convenience only and shall be disregarded in construing this Agreement. 28. Servicer. Indemnitor hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Funding Lender may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under the Borrower Note, this Agreement or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Indemnitor receives written notice from Funding Lender to the contrary, any action or right which shall or may be taken or exercised by Funding Lender may be taken or exercised by such servicer with the same force and effect. 29. Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Agreement for all purposes. 30. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF INDEMNITOR AND THE BENEFICIARY PARTIES (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 31. Time of the Essence. Time is of the essence with respect to this Agreement. 32. Modifications. All modifications (if any) to the terms of this Agreement (“Modifications”) are set forth on Exhibit B attached to this Agreement. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer that does not require the consent of the Funding Lender), some or all of the Modifications to this Agreement may be modified or rendered void by Funding Lender at its option by notice to Indemnitor or such transferee. 16 Vista Breeze 33. Attached Exhibits. The following Exhibits are attached to this Agreement and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Environmental Reports Exhibit B – Modifications to Agreement of Environmental Indemnification The terms of this Agreement are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Agreement, the terms of said Exhibits shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] S-1 Vista Breeze IN WITNESS WHEREOF, each of the undersigned has duly executed and delivered this Agreement of Environmental Indemnification or caused this Agreement of Environmental Indemnification to be duly executed and delivered by its authorized representative as of the date first set forth above. BORROWER: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: S-3 Vista Breeze GUARANTOR: HOWARD D. COHEN REVOCABLE TRUST U/A/D 4/6/1993 By: _________________________________ Name: Howard D. Cohen Title: Trustee A-1 Vista Breeze EXHIBIT A ENVIRONMENTAL REPORTS 1. Phase I Environmental Site Assessment (ESA) report (280-300 South Shore Drive) prepared for Vista Breeze Ltd. by Hydrologic Associates U.S.A., Inc. and dated October 6, 2023 2. Phase I ESA report (165-185 South Shore Drive) prepared for Vista Breeze Ltd. by Hydrologic Associates U.S.A., Inc. and dated October 6, 2023 B-1 Vista Breeze EXHIBIT B MODIFICATIONS TO AGREEMENT OF ENVIRONMENTAL INDEMNIFICATION The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. 4872-6931-1370v.3 D Forward Purchase Agreement Vista Breeze EXHIBIT D-10 TO FORWARD PURCHASE AGREEMENT FORM OF LOAN COVENANT AGREEMENT [See attached] EXHIBIT D-10 TO FORWARD PURCHASE AGREEMENT FORM OF LOAN COVENANT AGREEMENT by and between VISTA BREEZE, LTD. as Borrower and CITIBANK, N.A. as Funding Lender Dated as of [Month] 1, 202[_] Relating to: $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN-OUT] Borrower Loan by the Housing Finance Authority of Miami-Dade County, Florida as Governmental Lender TABLE OF CONTENTS Page Loan Covenant Agreement -i- Vista Breeze ARTICLE 1 DEFINITIONS. ........................................................................................................2 1.1 Definitions. ..............................................................................................................2 1.2 Accounting Terms.. ................................................................................................5 1.3 Other Interpretive Provisions. ..............................................................................5 ARTICLE 2 CONDITIONS PRECEDENT. ................................................................................5 2.1 Documents. .............................................................................................................5 2.2 Other Requirements ..............................................................................................7 2.3 Representations Correct; No Default ...................................................................8 ARTICLE 3 INTENTIONALLY OMITTED. .............................................................................8 ARTICLE 4 TITLE INSURANCE...............................................................................................8 ARTICLE 5 INTENTIONALLY OMITTED. .............................................................................9 ARTICLE 6 REPRESENTATIONS AND COVENANTS..........................................................9 6.1 Borrower Representations ....................................................................................9 ARTICLE 7 INTENTIONALLY OMITTED. ...........................................................................13 ARTICLE 8 EVENTS OF DEFAULT AND REMEDIES. .......................................................13 8.1 Events of Default. .................................................................................................13 8.2 Remedies. ..............................................................................................................13 ARTICLE 9 MISCELLANEOUS. .............................................................................................16 9.1 Notices. ..................................................................................................................16 9.2 Brokers and Financial Advisors. ......................................................................16 9.3 Survival. . .............................................................................................................16 9.4 Preferences............................................................................................................16 9.5 Waiver of Notice ...................................................................................................16 9.6 Offsets, Counterclaims and Defenses.. ...............................................................17 9.7 Publicity. ...............................................................................................................17 9.8 Construction of Documents .................................................................................17 9.9 No Third Party Beneficiaries.. ............................................................................17 9.10 Funding Lender and Servicer Not in Control; No Partnership. .....................17 9.11 Release ...................................................................................................................18 9.12 Reimbursement of Expenses. ..............................................................................18 TABLE OF CONTENTS (Continued) Page Loan Covenant Agreement -ii- Vista Breeze 9.13 Relationships with Other Customers.. ...............................................................18 9.14 Permitted Contests.. .............................................................................................18 9.15 Funding Lender Approval of Instruments and Parties ....................................19 9.16 Funding Lender Determination of Facts.. .........................................................19 9.17 Calendar Months. ................................................................................................19 9.18 Determinations by Funding Lender. ..................................................................19 9.19 Governing Law.. ...................................................................................................20 9.20 Consent to Jurisdiction and Venue. ...................................................................20 9.21 Successors and Assigns.. ......................................................................................20 9.22 Severability.. .........................................................................................................20 9.23 Transfer of Mortgaged Property or Ownership Interest in Borrower............20 9.24 Entire Agreement; Amendment and Waiver.. ...................................................20 9.25 Counterparts.. ......................................................................................................21 9.26 Captions. ...............................................................................................................21 9.27 Servicer. . ..............................................................................................................21 9.28 Beneficiary Parties as Third Party Beneficiary ................................................21 9.29 Waiver of Trial by Jury. ......................................................................................21 9.30 Time of the Essence.. ............................................................................................21 9.31 Limitation on Liability. .......................................................................................21 9.32 Modifications.. ......................................................................................................22 ARTICLE 10 INCORPORATION OF EXHIBITS. ....................................................................22 Exhibit A — Legal Description of the Land Exhibit B — Modifications to Loan Covenant Agreement Exhibit C — Form of Estoppel Certificate Loan Covenant Agreement Vista Breeze LOAN COVENANT AGREEMENT This LOAN COVENANT AGREEMENT (this “Agreement”), is entered into as of [Date] 1, 202[_], by and between VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”), and CITIBANK, N.A., a national banking association (together with its successors and assigns, “Funding Lender”). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (“Ground Lessor”), is the legal owner of fee simple title to that certain property located in the City of Miami Beach, Miami-Dade County, Florida, as more particularly described on Exhibit A attached hereto (the “Land”), and pursuant to that certain Second Amended and Restated Ground Lease (the “Ground Lease”), dated as of December 15, 2023, between the Ground Lessor, as ground lessor, and the Borrower, as ground lessee, the Borrower is the holder of a leasehold interest in the Land. B. The Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”) for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Miami-Dade County, Florida, known as Vista Breeze (the “Project”). C. The Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property (as hereinafter defined). F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement, the Funding Loan Documents (as defined in the Original Funding Loan Agreement) and all other Borrower Loan Documents except for the Unassigned Rights (as Loan Covenant Agreement -2- Vista Breeze defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Funding Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023 (the “Forward Purchase Agreement”), pursuant to which the Funding Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, Funding Lender has acquired the Funding Loan from the Original Funding Lender and, in connection therewith, (i) Funding Lender has agreed to, and, concurrently herewith, has entered into that certain Amended and Restated Funding Loan Agreement, dated as of the date hereof (the “Funding Loan Agreement”), by and among Governmental Lender, Fiscal Agent, and Funding Lender; (ii) Borrower and Governmental Lender have entered into that certain Amended and Restated Borrower Loan Agreement, dated as of the date hereof (the “Borrower Loan Agreement”), which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered that certain Amended and Restated Multifamily Note, dated as of [_] [_], 20[_], in the principal amount of $[11,875,000] [NOTE: AS MAY BE INCREASED PER THE EARN-OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; and (iv) Borrower has executed and delivered that certain Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof (the “Security Instrument”), which Security Instrument encumbers the leasehold interest in the real property and improvements of the Project and amends and restates the Original Security Instrument. I. In connection with the foregoing, Funding Lender and Borrower have agreed to enter into this Agreement (together with the Borrower Note, the Security Instrument, the Borrower Loan Agreement and all other documents executed in connection with the Borrower Loan, including this Agreement, the “Borrower Loan Documents”), for the purpose of stipulating certain additional covenants and agreements with respect to the Borrower Loan. NOW, THEREFORE, for and in consideration of the mutual promises and covenants herein contained, and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Funding Lender and Borrower agree as follows: ARTICLE 1 DEFINITIONS. 1.1 Definitions. As used herein, the following terms have the meanings set forth below; provided, however, that any capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Borrower Loan Agreement: “Agreement” shall mean this Loan Covenant Agreement, as amended, modified, supplemented or restated from time to time including all the exhibits, appendices and schedules attached hereto, all of which are incorporated herein by this reference and made a part hereof. Loan Covenant Agreement -3- Vista Breeze “Beneficiary Parties” as used herein shall mean Funding Lender, Governmental Lender, Fiscal Agent, any Servicer and their respective successors and assigns. The term “Beneficiary Parties” shall also include any lawful owner, holder or pledgee of the Original Borrower Note. “Borrower” has the meaning given to that term in the introductory paragraph of this Agreement, together with its successors or assigns by merger, acquisition or otherwise, subject to Section 9.21. “Borrower Loan” has the meaning set forth in the Recitals. “Borrower Loan Agreement” has the meaning set forth in the Recitals. “City” shall mean the City of Miami Beach, Florida. “City HOME Loan” means the subordinate loan in the aggregate principal amount of $1,003,969 made by the City to Borrower. “County” shall mean the County of Miami-Dade, Florida. “ELI Loan” shall mean the subordinate loan in the aggregate principal amount of $600,000 made by FHFC to Borrower. “Event of Default” has the meaning given to that term in Section 8.1. “FHFC” shall mean the Florida Housing Finance Corporation. “Financing Statements” shall mean those certain UCC-1 financing statements designating Borrower as debtor, Governmental Lender as secured party and Funding Lender as assignee secured party, intended to perfect Governmental Lender’s security interest in the Collateral now owned or hereafter acquired by Borrower, in form and substance satisfactory to Funding Lender, to be filed in the Office of the Secretary of State of the State, and in such other offices for recording or filing such statements in such jurisdictions as Funding Lender shall desire to perfect Governmental Lender’s security interest or to reflect such interest in appropriate public records. “Forward Purchase Agreement” has the meaning set forth in the Recitals. “Guarantor” shall mean Howard D. Cohen Revocable Trust U/A/D/ 4/6/1993. “Governmental Lender Note” shall mean that certain Multifamily Housing Revenue Note, Series 2023 (Vista Breeze), dated December 15, 2023 in the original maximum principal amount of $32,500,000, made by the Governmental Lender and payable to Funding Lender, as may be amended, supplemented or replaced from time to time. “Ground Lease” has the meaning set forth in the Recitals. “Ground Lessor” has the meaning set forth in the Recitals. “HACMB” shall mean the Housing Authority of the City of Miami Beach. Loan Covenant Agreement -4- Vista Breeze “HACMB Loan” means the subordinate loan in the aggregate principal amount of $8,800,000 made by HACMB to Borrower. “HAP Contract” shall mean that certain Housing Assistance Payments Contract, dated as of [_], 20[_], between HACMB and Borrower, which shall cover 119 units. “Improvements” shall mean the 119 -unit multifamily residential project located on the Land, and known or to be known as Vista Breeze, and all other buildings, structures, fixtures, equipment and other improvements and personal property constructed, rehabilitated and/or installed at or on the Land. “Material Property Agreement” has the meaning given to that term in the Security Instrument. “Mortgaged Property” has the meaning set forth in the Security Instrument. “Multifamily Underwriting Guidelines” shall mean multifamily underwriting guidelines generated by the Credit Enhancer (or if there is no Credit Enhancer, the Funding Lender’s internal multifamily underwriting guidelines), as in effect from time to time. “NHTF Loan” shall mean the subordinate loan in the aggregate principal amount of $1,301,500 made by FHFC to Borrower. “Origination Fee” shall mean an origination fee in an amount of $[NOTE: 1% OF PERMANENT LOAN AMOUNT AND 1% OF EARN-OUT AMOUNT], which sum was fully paid to Funding Lender concurrently with the closing of the Funding Loan, which Origination Fee is non-refundable and was deemed fully earned by Funding Lender upon the execution of the Forward Purchase Agreement by Funding Lender, Original Funding Lender and Borrower. “Potential Default” shall mean any condition or event which, but for the lapse of time or the giving of notice, or both, would constitute an Event of Default. “SAIL Loan” shall mean the subordinate loan in the aggregate principal amount of $3,000,000 made by FHFC to Borrower. “Subordinate Debt” shall mean, individually and collectively, (i) the City HOME Loan pursuant to the Subordinate Loan Documents, (ii) the Surtax Loan pursuant to the Subordinate Loan Documents, (iii) the SAIL Loan pursuant to the Subordinate Loan Documents, (iv) the ELI Loan pursuant to the Subordinate Loan Documents, (v) the NHTF Loan pursuant to the Subordinate Loan Documents, (vi) the Viability Loan pursuant to the Subordinate Loan Documents, and (vii) the HACMB Loan pursuant to the Subordinate Loan Documents. “Subordinate Lender” shall mean, individually and collectively, (i) the City, (ii) the County, (iii) FHFC, and (iv) HACMB. “Subordinate Loan Documents” shall mean, collectively, all instruments, agreements and other documents evidencing, securing or otherwise relating to the Subordinate Debt or executed and delivered by Borrower and/or Subordinate Lender in connection with the Subordinate Debt. Loan Covenant Agreement -5- Vista Breeze “Surtax Loan” shall mean the subordinate loan in the aggregate principal amount of $5,950,000 made by the County to Borrower. “Underwritten Management Fee” shall mean a fee per annum not to exceed six percent (6%) of effective gross income from the Project. “Viability Loan” shall mean the subordinate loan in the aggregate principal amount of $4,300,000 made by FHFC to Borrower. 1.2 Accounting Terms. For purposes of this Agreement, all accounting terms not otherwise defined herein or in the Recitals have the meanings assigned to them in conformity with GAAP consistently applied. 1.3 Other Interpretive Provisions. References to “Articles”, “Sections”, “subsections”, “paragraphs”, “subparagraphs”, “Appendices”, “Recitals” and “Exhibits” shall be to Articles, Sections, subsections, paragraphs, subparagraphs, Appendices, Recitals, and Exhibits of this Agreement unless otherwise specifically provided. Any of the terms defined in this Article 1 may be used in singular or plural form. As used herein, the singular includes the plural, and the masculine gender includes the feminine and neuter genders, and vice versa, unless the context otherwise requires. In interpreting the meaning of this Agreement or of any other Borrower Loan Document: (i) “includes” and “including” shall not be limiting; (ii) “or” shall not be exclusive; and (iii) “all” shall include “any”, and “any” shall include “all”. Except as otherwise provided herein, references to any document or instrument defined in this Article 1 are to such document or instrument as amended or supplemented from time to time with Funding Lender’s consent or as otherwise permitted by this Agreement. The titles and headings of articles, sections or subsections of this Agreement are intended for convenience only and shall not in any way affect the meaning or construction of any provision of this Agreement. No listing of specific instances, items or matters as examples shall in any way limit the scope or generality of any language of this Agreement. The language of this Agreement shall be construed as a whole according to its fair meaning, and not strictly for or against any party. For purposes of this Agreement, the term “Managing General Partner” shall refer to APC Vista Breeze, LLC, the Class B limited partner of the Borrower. ARTICLE 2 CONDITIONS PRECEDENT. 2.1 Documents. The purchase of the Borrower Loan by Funding Lender is expressly conditioned upon (i) the satisfaction of all of the conditions set forth in Sections 2.1, 2.2 and 2.3; (ii) the Title Company’s unconditional commitment to issue the Title Insurance Policy; and (iii) Borrower’s delivery to Funding Lender of the following documents, together with such other documents that Governmental Lender or Funding Lender may reasonably require, in form and content satisfactory to Funding Lender, duly executed (and acknowledged where necessary) by the appropriate parties thereto: 2.1.1 This Agreement, duly executed by Funding Lender and Borrower; Loan Covenant Agreement -6- Vista Breeze 2.1.2 The Security Instrument, duly executed and acknowledged by Borrower, which shall be duly delivered to the Title Company to be recorded in the official records of the County; 2.1.3 The Financing Statement, which shall be duly filed with the Secretary of State of the State and in such other offices for recording or filing such statements in such jurisdictions as Funding Lender shall desire to perfect Governmental Lender’s security interest or to reflect such interest in appropriate public records; 2.1.4 The other Security Documents; 2.1.5 An executed copy of the Partnership Agreement; 2.1.6 A true copy of all of the organizational documents of the Managing General Partner, including, without limitation, the operating agreement and certificate of limited partnership of the Managing General Partner; 2.1.7 A borrowing authorization of the Managing General Partner duly executed by the Managing General Partner on behalf of Borrower; 2.1.8 An authorization of any Guarantor which is not an individual to guaranty completion of the Project and payment of the Borrower Payment Obligations of Borrower hereunder; 2.1.9 A signature authorization form and disbursement instructions, duly executed by Borrower and by the authorized signatories specified therein; 2.1.10 Executed copies of the Management Agreement and Manager’s consent to assignment of the Management Agreement, each in a form acceptable to Funding Lender; 2.1.11 An environmental site assessment report with respect to the Project, in form and substance acceptable to Funding Lender and prepared by an environmental engineering firm acceptable to Funding Lender; 2.1.12 Originals or, if permitted by Funding Lender, certified copies, of insurance policies evidencing the maintenance of insurance by Borrower required by the Security Instrument; 2.1.13 The Title Insurance Policy; 2.1.14 An ALTA/NSPS survey and surveyor’s certificate, certified to Borrower, Governmental Lender, Funding Lender, the Title Company and any other party designated by Funding Lender, in form and substance acceptable to Funding Lender and meeting the requirements of Funding Lender, including a legal description of the Project, the square footage of the Project and currently existing Improvements (as well as whether or not any portion of the Project is in a flood risk zone) showing the locations of the currently existing Improvements, easements, building or setback lines, rights-of-way and Loan Covenant Agreement -7- Vista Breeze dedications affecting the Project, and showing no state of facts objectionable to Funding Lender or the Title Company in their reasonable discretion; 2.1.15 Uniform Commercial Code lien searches and judgment, litigation and bankruptcy searches, with respect to Borrower, Guarantor and each of Borrower’s partners or members, from appropriate state and/or county offices; 2.1.16 Certificates issued by the Secretary of State of the State and the relevant state of formation showing Borrower, the Managing General Partner and any Guarantor which is not an individual, to be in existence and, if applicable, in good standing under the laws of such state, together with certified organizational documents and resolutions of the managing partners or members of Borrower authorizing and approving the closing and consummation of the Borrower Loan and all instruments, documents and agreements executed in connection therewith and of any Guarantor which is not an individual authorizing and approving the Guaranties; 2.1.17 A written opinion from counsel for Borrower and Guarantor in all respects satisfactory to Governmental Lender and Funding Lender; 2.1.18 Any other documents that Governmental Lender or Funding Lender may reasonably request. 2.2 Other Requirements. The Funding Lender’s acquisition of the Borrower Loan and of the Governmental Lender Note are subject to the further conditions that on or before the date hereof: 2.2.1 All of the Conditions to Conversion (as such term is defined in the Forward Purchase Agreement) shall have been satisfied unless expressly waived in writing by the Funding Lender in its sole and absolute discretion; 2.2.2 The Borrower shall deliver an Estoppel Certificate, in the form attached hereto as Exhibit C, from HACMB confirming that the Ground Lease is in effect and that there are no defaults thereunder by the Borrower.; 2.2.3 Intentionally Omitted; 2.2.4 Funding Lender shall have received payment of all amounts required by this Agreement to be paid to Funding Lender pursuant to the Forward Purchase Agreement; 2.2.5 Funding Lender shall have received satisfactory evidence of the availability to the Project of all public utility services and facilities needed for the use, occupancy and/or operation of the Improvements; 2.2.6 Funding Lender shall have received satisfactory evidence that all roads, streets, traffic turn lanes and accessways necessary for the full utilization of the Improvements for their intended purposes have either been completed or the necessary rights of way or authorizations therefor have either been acquired by the appropriate Loan Covenant Agreement -8- Vista Breeze Governmental Authority or have been dedicated to public use and accepted by said Governmental Authority, and all necessary steps have been taken by Borrower and said Governmental Authority to assure the complete construction and installation thereof by the time needed for construction, rehabilitation and/or occupancy and operation of the Improvements; 2.2.7 Funding Lender shall have received satisfactory evidence that all taxes, fees and other charges, if any, in connection with the execution, delivery and recording of the Borrower Loan Documents and the Funding Loan Documents have been paid, and all delinquent taxes, assessments or other governmental charges or liens affecting the Project, if any, have been paid; 2.2.8 Funding Lender shall have received satisfactory evidence that Borrower has complied with all covenants, conditions, restrictions and reservations affecting the Project, that the Project is duly and validly zoned for the intended use, and that Borrower has obtained all zoning, subdivision and environmental approvals, permits and maps required to be obtained in order to construct the Improvements. 2.3 Representations Correct; No Default. The Funding Lender's acquisition of the Borrower Loan and of the Governmental Lender Note is subject to the further conditions that on the date hereof: 2.3.1 The representations and warranties contained herein and in each written document delivered by Borrower, the Managing General Partner or Guarantor to Governmental Lender or Funding Lender in connection with this Agreement shall be true and correct in all material respects on and as of the date hereof; 2.3.2 Since the date(s) of the most recent financial statements provided to Funding Lender with respect to Borrower, the Managing General Partner or Guarantor and the Project, no material adverse change shall have occurred in the financial condition or business of Borrower, the Managing General Partner, Guarantor or the Project; 2.3.3 No Event of Default or Potential Default shall have occurred and be continuing; and 2.3.4 Funding Lender shall have received a certificate, signed by an Authorized Borrower Representative and dated the date hereof, confirming the satisfaction of the foregoing conditions set forth in this Article 2 as of the date hereof. ARTICLE 3 INTENTIONALLY OMITTED. ARTICLE 4 TITLE INSURANCE. The Title Insurance Policy issued with respect to the Security Instrument shall provide coverage satisfactory to Funding Lender, insuring Funding Lender’s interest under the Security Instrument as a valid first mortgage lien on the Project, together with such reinsurance or coinsurance agreements and such endorsements to the Title Insurance Policy as Funding Lender may require, which policy shall contain only such exceptions from its coverage as shall have been Loan Covenant Agreement -9- Vista Breeze approved in writing by Funding Lender, and thereafter Borrower shall, at its own cost and expense, do all things necessary to maintain the Security Instrument as a valid first lien on Borrower’s leasehold interest in the Project. ARTICLE 5 INTENTIONALLY OMITTED. ARTICLE 6 REPRESENTATIONS AND COVENANTS. 6.1 Borrower Representations. To induce the Funding Lender to execute this Agreement and to induce Funding Lender, Governmental Lender and Fiscal Agent to enter into the Funding Loan Agreement and the Borrower Loan Agreement, Borrower represents and warrants for the benefit of the Governmental Lender, Fiscal Agent, Funding Lender and the Servicer, that the representations and warranties set forth in this Section 6 are complete and accurate as of the date hereof in accordance with the terms and conditions hereof. The representations, warranties and agreements set forth in this Section 6.1 shall survive the acquisition by Funding Lender of the Original Funding Lender’s right, title and interest in the Funding Loan, Governmental Lender Note and the Borrower Loan, and shall remain in effect and true and correct in all material respects until the Borrower Loan and all other Borrower Payment Obligations have been repaid in full: 6.1.1 Address. The Mortgaged Property is located at 175 S. Shore Drive and 280 S. Shore Drive, Miami Beach, Florida 33141. 6.1.2 Condition of Project. No portion of the Mortgaged Property is presently damaged by fire, water, wind or other casualty and any previous damage has been fully restored. There has been no taking or notice of intended taking in condemnation or eminent domain proceedings with respect to the Mortgaged Property or any portion thereof, nor, to the best of Borrower’s knowledge, is any proceeding pending or threatened for the partial or total taking of the Mortgaged Property. 6.1.3 Outstanding Claims and Litigation. (A) Neither Borrower, any general partner, manager, or managing member of Borrower, nor any guarantor of any of Borrower’s obligations in connection with the Borrower Loan, is involved in any bankruptcy, reorganization or insolvency proceeding (either as creditor or debtor), nor is any such proceeding contemplated or threatened, and neither Borrower, any general partner, manager and/or managing member of Borrower, nor any guarantor of any of Borrower’s obligations in connection with the Borrower Loan, has made a general assignment for the benefit of its creditors, nor is such contemplated or threatened. (B) There are no judgments or creditors’ liens affecting the Mortgaged Property, Borrower or any general partner, manager and/or managing member of Borrower, and there is no litigation or other claim pending before any court or administrative or other governmental body or overtly threatened by a written communication against Borrower, any general partner, manager and/or managing member of Borrower or the Mortgaged Property or any other properties of Borrower. Loan Covenant Agreement -10- Vista Breeze (C) Borrower represents and warrants that no delinquencies, defaults, foreclosures or deeds in lieu of foreclosure have occurred (i) relating to any property in which Borrower had an interest at the time of delinquency, default, foreclosure, or deed in lieu of foreclosure or (ii) during the past ten (10) years on any loan obligating Borrower or any general partner, manager and/or managing member of Borrower in any manner, irrespective of the loan purpose or collateral (i.e., not just multifamily loans). (D) All of the following items regarding the Mortgaged Property which have become due and payable have been paid or, with the approval of Funding Lender, an escrow fund sufficient to pay them has been established: (i) taxes, (ii) government assessments, (iii) insurance premiums, (iv) water, sewer and municipal charges, (v) leasehold payments, if applicable (other than annual payments due under the Ground Lease), (vi) ground rents, if applicable (other than annual payments due under the Ground Lease), and (vii) any other charges affecting the Mortgaged Property. 6.1.4 Compliance with Laws. The Mortgaged Property conforms to all applicable subdivision and use laws, ordinances or codes and local building and housing codes, and will be a legally conforming use with respect to all applicable zoning requirements without reliance on “grandfathering” or a variance. Without limitation of the foregoing, with respect to existing improvements at the Mortgaged Property, if any, the Mortgaged Property is zoned to permit existing improvements to be rebuilt to their presently existing size, shape and density if partially or totally destroyed. 6.1.5 Compliance With Health, Safety And Other Laws. There are no governmental citations issued against Borrower or the Mortgaged Property which remain uncured. To the best of Borrower’s knowledge: (a) no fire, health or safety hazards exist on the Mortgaged Property, and (b) there is no evidence of illegal activities, including without limitation any illegal activity relating to controlled substances, on the Mortgaged Property. 6.1.6 Financial Condition. There are no financial demands on Borrower from any source which would materially adversely affect its financial condition or stability or its ability to satisfy its obligations under the Borrower Loan Documents. Borrower is not presently insolvent, and the proposed Borrower Loan will not render Borrower insolvent. As used in this section, the term “insolvent” means that the sum total of all of an entity’s liabilities (whether secured or unsecured, contingent or fixed, or liquidated or unliquidated) is in excess of the value of all such entity’s non-exempt assets, i.e., all of the assets of the entity that are available to satisfy claims of creditors. 6.1.7 No Labor or Materialmen’s Claims. All parties furnishing labor and materials with respect to the Mortgaged Property have been paid in full and no claims are outstanding that have not been bonded over or insured to the satisfaction of Funding Lender. In the event that any work of any kind has been commenced or performed upon the Mortgaged Property or in the event that any materials or equipment have been ordered or delivered to or upon the Mortgaged Property, then (i) prior to the date hereof Borrower has fully disclosed in writing to Funding Lender and the title insurance company issuing the Title Insurance Policy insuring the lien of the Security Instrument that work has been Loan Covenant Agreement -11- Vista Breeze commenced or performed on the Mortgaged Property or materials or equipment have been ordered or delivered to or upon the Mortgaged Property, (ii) prior to the date hereof Borrower has obtained and delivered to Funding Lender and the title company issuing the Title Insurance Policy insuring the lien of the Security Instrument lien waivers from all contractors, subcontractors, suppliers, or any other applicable party, pertaining to all work commenced or performed on the Mortgaged Property or materials or equipment ordered or delivered to or upon the Mortgaged Property, and (iii) the Title Insurance Policy insuring the lien of the Security Instrument shall take no exception from coverage for any mechanics or materialmens liens. 6.1.8 No Outstanding Trade Payables. Borrower has no trade payables, utility bills, contract payments, deferred payment plans, or similar type arrangement in connection with the Mortgaged Property that are past due. 6.1.9 Rent Roll. The certified rent roll of the Project, dated [___________________], and delivered to Funding Lender is true and correct (the “Rent Roll”). The apartment units the Rent Roll reflects as leased are occupied by tenants under leases that continue in effect on the date hereof. No tenant is more than 30 days past due in making a rental payment except as disclosed on the Rent Roll. There were no rental concessions made in connection with the apartments and/or apartment leases except as described in the Rent Roll. There are no policies or practices presently in effect or pending with regard to any leased or unleased apartment in the Project that would allow any tenant a rental concession. Except as disclosed in the Rent Roll, no party has any possessory interest in the Mortgaged Property or right to occupy the same. No party has any option to purchase the Mortgaged Property or an interest therein except as previously disclosed to, and approved by, Funding Lender. 6.1.10 Leases. Except (i) as set forth on the Rent Roll referenced in Section 6.1.9 above and (ii) the Ground Lease, there are no commercial or residential leases affecting the Mortgaged Property as of this date. 6.1.11 Collateral. All of the physical collateral for the Borrower Loan is located at the Mortgaged Property. 6.1.12 MMP/O&M Program. Borrower hereby adopts the Mold and Moisture O&M Plan prepared by [_______________] dated [________________], and shall maintain the same during the term of the Borrower Loan. Borrower further agrees to implement any additional operations and maintenance plan that may be necessary or appropriate based on any environmental condition at the Mortgaged Property and maintain the same for the remaining term of the Borrower Loan. 6.1.13 The Mortgaged Property; Single Asset Status. The Mortgaged Property contains not less than [53,172] square feet of land (approximately [1.22] acres). There are not less than [55] parking spaces located on the Mortgaged Property, including [3] handicap parking spaces. No part of the Mortgaged Property is included or assessed under or as part of another tax lot or parcel, and no part of any other property is included or assessed under or as part of the tax lot or parcels for the Mortgaged Property. Except as Loan Covenant Agreement -12- Vista Breeze otherwise expressly approved by Funding Lender in writing, Borrower does not own any real property or assets other than the Mortgaged Property and does not operate any business other than the management and operation of the Mortgaged Property. 6.1.14 Assessments. To the best of Borrower’s knowledge, there are not presently pending any special assessments against the Mortgaged Property or any part thereof. 6.1.15 Material Property Agreements. As of the date hereof, Borrower has provided to Funding Lender all Material Property Agreements, including all renewals, amendments, modifications, and extensions thereof, together with all exhibits and addenda thereto. Neither Borrower nor any of its officers, directors, employees or agents shall, without the prior written consent of Funding Lender (a) enter into any Material Property Agreement, or (b) amend, waive, supplement, or terminate any provision of any Material Property Agreement previously approved by Funding Lender. 6.1.16 Subordinate Loan Documents. The Subordinate Loan Documents are in full force and effect and Borrower has paid all commitment fees and other amounts due and payable to the Subordinate Lender(s) thereunder. There exists no material violation of or material default by Borrower under, and no event has occurred which, upon the giving of notice or the passage of time, or both, would constitute a material default under the Subordinate Loan Documents. Borrower shall comply in all respects with all of the covenants contained in the Subordinate Loan Documents. Borrower represents that, as of the date hereof, the entire proceeds of the Subordinate Debt have been fully disbursed to Borrower. Without Lender’s prior written consent, Borrower will not surrender, terminate, cancel, modify, change, supplement, alter, amend, waive, release, assign, transfer, pledge or hypothecate any of its rights or remedies under the Subordinate Loan Documents. 6.1.17 HAP Contract. The HAP Contract is in full force and effect and there exists no material violation of or material default by the Borrower under the HAP Contract, and no event has occurred which, upon the giving of notice or the passage of time, or both, would constitute a material default by any other party under the HAP Contract. 6.1.18 No Illegal Activity as Source of Funds. No portion of the Mortgaged Property has been or will be purchased, improved, equipped or furnished with proceeds of any illegal activity. 6.1.19 Ground Lease. The Ground Lease is in full force and effect and Borrower has paid all rent and other amounts due and payable to the ground lessor thereunder in accordance with the terms of the Ground Lease. There exists no material violation of or material default by Borrower under the Ground Lease, and no event has occurred which, upon the giving of notice or the passage of time, or both, would constitute a material default by any other party under the Ground Lease. Without Funding Lender’s prior written consent, Borrower will not surrender, terminate, cancel, modify, change, supplement, alter, amend, waive, release, assign, transfer, pledge or hypothecate any of its rights or remedies under the Ground Lease. Loan Covenant Agreement -13- Vista Breeze ARTICLE 7 INTENTIONALLY OMITTED. ARTICLE 8 EVENTS OF DEFAULT AND REMEDIES. 8.1 Events of Default. The occurrence of any one or more of the following shall constitute an “Event of Default” under this Agreement: 8.1.1 An “Event of Default” shall occur under any of the Security Documents, any of the Borrower Loan Documents, the Borrower Loan Agreement or the Related Documents. 8.1.2 Any failure by Borrower to perform or comply with any of its obligations under this Agreement (other than those specified in Sections 8.1.1 through 8.1.2), as and when required, which continues for a period of thirty (30) days after written notice of such failure by Funding Lender to Borrower; provided, however, if such failure is susceptible of cure but cannot reasonably be cured within such thirty (30) day period, and the Borrower shall have commenced to cure such failure within such thirty (30) day period and thereafter diligently and expeditiously proceeds to cure the same, such thirty (30) day period shall be extended for an additional period of time as is reasonably necessary for the Borrower in the exercise of due diligence to cure such failure, such additional period not to exceed sixty (60) days. However, no such notice or grace period shall apply to the extent such failure could, in Funding Lender’s judgment, absent immediate exercise by Funding Lender of a right or remedy under this Agreement or the other Borrower Loan Documents, result in harm to Funding Lender, impairment of the Original Borrower Note or Borrower Loan Agreement or any security given under any other Borrower Loan Document. 8.1.3 An “Event of Default” or “Default” shall occur by Borrower under the Ground Lease, after the expiration of all applicable notice, grace, and cure periods. 8.1.4 An “Event of Default” or “Default” (as defined in the applicable agreement) shall occur by Borrower under any of the Subordinate Loan Documents, after the expiration of all applicable notice, grace, and cure periods. (A) An “Event of Default” or “Default” (as defined in the HAP Contract) shall occur by Borrower under the HAP Contract, after the expiration of all applicable notice, grace, and cure periods. 8.1.5 Notwithstanding any provision herein to the contrary, the Funding Lender agrees that any cure of any default made or tendered by the Equity Investor or its designee(s) shall be deemed to be a cure by the Borrower and shall be accepted or rejected on the same basis as if made or tendered by the Borrower. 8.2 Remedies. 8.2.1 Notice to Governmental Lender. Upon the occurrence and continuation of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Funding Loan Covenant Agreement -14- Vista Breeze Lender shall, at its option, have the right (but not the obligation) to notify Governmental Lender, Fiscal Agent, Borrower and Equity Investor of the occurrence of such Event of Default and Governmental Lender and Funding Lender (i) shall have all the rights and remedies provided herein and in the other Borrower Loan Documents, including, without limitation, the right to enforce any Liens granted under this Agreement and the Security Documents; and (ii) shall have the option to declare or to cause Governmental Lender to declare all sums then owing hereunder or under any of the other Borrower Loan Documents immediately due and payable by Borrower, without presentment, demand, protest, or notice of any kind; provided that upon the occurrence of any Event of Default resulting from bankruptcy or insolvency of Borrower, the above-described sums, and all amounts reimbursable on demand under this Agreement, shall automatically become immediately due and payable without the necessity of any such declaration by Governmental Lender or Funding Lender, and without presentment, demand, protest or any notice of any kind, all of which are hereby expressly waived by Borrower. 8.2.2 Power of Attorney. Effective upon the occurrence of an Event of Default, and continuing until and unless such Event of Default is cured or waived, Borrower hereby constitutes and appoints Funding Lender, or an independent contractor selected by Funding Lender, as its true and lawful attorney-in-fact with full power of substitution, for the purposes of completion of the construction, rehabilitation, equipping, installation and operation of the Project and performance of Borrower’s obligations under this Agreement in the name of Borrower, and hereby empowers said attorney-in-fact to do any or all of the following upon the occurrence and continuation of an Event of Default (it being understood and agreed that said power of attorney shall be deemed to be a power coupled with an interest which cannot be revoked until full payment and performance of all obligations under this Agreement and the other Borrower Loan Documents): (A) to pay, settle or compromise all existing bills and claims which are or may be liens against the Mortgaged Property, the Improvements or the Project, or may be necessary or desirable for the completion of the construction or rehabilitation, as the case may be, of the Improvements, or clearance of objections to or encumbrances on title; (B) to prosecute and defend all actions or proceedings in connection with the Mortgaged Property and/or the Project and to take such action, require such performance and do any and every other act as is deemed necessary with respect to the completion of the construction or rehabilitation, as the case may be, of the Improvements which Borrower might do on its own behalf; (C) to employ watchmen and erect security fences to protect the Project from damage or injury; and (D) to take such action and require such performance as it deems necessary under any of the bonds or insurance policies to be furnished hereunder, to make settlements and compromises with the sureties or insurers thereunder, and in connection therewith to execute instruments of release and satisfaction. Loan Covenant Agreement -15- Vista Breeze 8.2.3 Set Off; Waiver of Set Off. Upon the occurrence and continuation of an Event of Default (it being acknowledged and agreed that in no event shall Funding Lender have any obligation to accept a cure of an Event of Default), Funding Lender may, at any time and from time to time, without notice to Borrower or any other Person (any such notice being expressly waived), set off and appropriate and apply (against and on account of any obligations and liabilities of Borrower to Funding Lender arising under or connected with this Agreement, the Borrower Loan Agreement and the other Borrower Loan Documents and the Funding Loan Documents, irrespective of whether or not Funding Lender shall have made any demand therefor, and although such obligations and liabilities may be contingent or unmatured), and Borrower hereby grants to Funding Lender, as security for the Borrower Payment Obligations, a security interest in, any and all deposits (general or special, including but not limited to Debt evidenced by certificates of deposit, whether matured or unmatured, but not including trust accounts) and any other Debt at any time held or owing by Funding Lender to or for the credit or the account of Borrower. 8.2.4 Assumption of Obligations. In the event that the Funding Lender or its assignee or designee shall become the legal or beneficial owner of the Project by foreclosure or deed in lieu of foreclosure, such party shall succeed to the rights and the obligations of the Borrower under this Agreement, the Borrower Loan Agreement, the Original Borrower Note, the Regulatory Agreement, and any other Borrower Loan Documents and Funding Loan Documents to which the Borrower is a party. Such assumption shall be effective from and after the effective date of such acquisition and shall be made with the benefit of the limitations of liability set forth therein and without any liability for the prior acts of the Borrower. 8.2.5 Accounts Receivable. Upon the occurrence of an Event of Default, Funding Lender shall have the right, to the extent permitted by law, to impound and take possession of books, records, notes and other documents evidencing Borrower’s accounts, accounts receivable and other claims for payment of money, arising in connection with the Project, and to make direct collections on such accounts, accounts receivable and claims for the benefit of Funding Lender. 8.2.6 Defaults under Other Documents. Funding Lender shall have the right to cure any default under any of the Related Documents and the Subordinate Loan Documents, but shall have no obligation to do so. 8.2.7 Remedies Cumulative; No Waiver. All remedies of Governmental Lender, Fiscal Agent and Funding Lender provided for in this Agreement are cumulative and shall be in addition to any and all other rights and remedies available under the other Borrower Loan Documents or any other document or by law or equity. No exercise by Governmental Lender or Funding Lender of any right or remedy shall in any way constitute a cure or waiver of any Event of Default hereunder, or invalidate any act done pursuant to any notice of default, or prejudice Governmental Lender, Fiscal Agent or Funding Lender in the exercise of any other right or remedy available to Governmental Lender, Fiscal Agent or Funding Lender. No failure on the part of Governmental Lender, Fiscal Agent and Funding Lender to exercise, and no delay in exercising, any right or remedy shall operate as a waiver or otherwise preclude enforcement of any of their respective rights and Loan Covenant Agreement -16- Vista Breeze remedies, nor shall any single or partial exercise of any right or remedy preclude any further exercise thereof or of any other right or remedy. Governmental Lender, Fiscal Agent and Funding Lender need not resort to any particular right or remedy before exercising or enforcing any other. ARTICLE 9 MISCELLANEOUS. 9.1 Notices. All notices and other communications to Governmental Lender, Funding Lender and Borrower hereunder shall be in writing and shall be delivered in the manner and to the addresses required by the Borrower Loan Agreement. 9.2 Brokers and Financial Advisors. The Borrower hereby represents that it has dealt with no financial advisors, brokers, underwriters, placement agents, agents or finders in connection with the Borrower Loan or the Funding Loan, other than those disclosed to the Funding Lender and whose fees shall be paid by the Borrower pursuant to separate agreements. The Borrower and the Funding Lender shall indemnify and hold the other harmless from and against any and all claims, liabilities, costs and expenses of any kind in any way relating to or arising from a claim by any Person that such Person acted on behalf of the indemnifying party in connection with the transactions contemplated herein. The provisions of this Section 9.2 shall survive the expiration and termination of this Agreement and the repayment of the Borrower Payment Obligations. 9.3 Survival. This Agreement and all covenants, agreements, representations and warranties made herein and in the certificates delivered pursuant hereto shall survive the making by the Funding Lender of the Borrower Loan and the execution and delivery to the Funding Lender of the Original Borrower Note, and shall continue in full force and effect so long as all or any of the Borrower Payment Obligations is unpaid. All the Borrower’s covenants and agreements in this Agreement shall inure to the benefit of the respective legal representatives, successors and assigns of the Funding Lender and the Servicer. 9.4 Preferences. The Funding Lender shall have the continuing and exclusive right to apply or reverse and reapply any and all payment by the Borrower to any portion of the Borrower Payment Obligations. To the extent the Borrower makes a payment under the Borrower Loan, or the Funding Lender or the Servicer receives proceeds of any collateral, which is in whole or part subsequently invalidated, declared to be fraudulent or preferential, set aside or required to be repaid to a trustee, receiver or any other party under any bankruptcy law, state or federal law, common law or equitable cause, then, to the extent of such payment or proceeds received, the Borrower Payment Obligations or part thereof intended to be satisfied shall be revived and continue in full force and effect, as if such payment or proceeds had not been received by the Funding Lender or Servicer. 9.5 Waiver of Notice. The Borrower shall not be entitled to any notices of any nature whatsoever from the Funding Lender or the Servicer except with respect to matters for which this Agreement or any other Borrower Loan Document specifically and expressly provides for the giving of notice by the Funding Lender or the Servicer, as the case may be, to the Borrower and except with respect to matters for which the Borrower is not, pursuant to applicable Legal Requirements, permitted to waive the giving of notice. The Borrower hereby expressly waives the right to receive any notice from the Funding Lender or the Servicer, as the case may be, with Loan Covenant Agreement -17- Vista Breeze respect to any matter for which no Borrower Loan Document specifically and expressly provides for the giving of notice by the Funding Lender or the Servicer to the Borrower. 9.6 Offsets, Counterclaims and Defenses. The Borrower hereby waives the right to assert a counterclaim, other than a compulsory counterclaim, in any action or proceeding brought against it by the Funding Lender or the Servicer with respect to a Borrower Loan Payment. Any assignee of Governmental Lender’s or Funding Lender’s interest in and to the Borrower Loan Documents shall take the same free and clear of all offsets, counterclaims or defenses that are unrelated to the Borrower Loan Documents which the Borrower may otherwise have against any assignor of such documents, and no such unrelated offset, counterclaim or defense shall be interposed or asserted by the Borrower in any action or proceeding brought by any such assignee upon such documents, and any such right to interpose or assert any such unrelated offset, counterclaim or defense in any such action or proceeding is hereby expressly waived by the Borrower. 9.7 Publicity. The Funding Lender and the Servicer (and any Affiliates of either party) shall have the right to issue press releases, advertisements and other promotional materials describing the Funding Lender’s or the Servicer’s participation in the making of the Borrower Loan or the Borrower Loan’s inclusion in any Secondary Market Transaction effectuated by the Funding Lender or the Servicer or one of its or their Affiliates. All news releases, publicity or advertising by the Borrower or its Affiliates through any media intended to reach the general public, which refers to the Borrower Loan Documents, the Borrower Loan, the Funding Lender or the Servicer in a Secondary Market Transaction, shall be subject to the prior Written Consent of the Funding Lender or the Servicer, as applicable. 9.8 Construction of Documents. The parties hereto acknowledge that they were represented by counsel in connection with the negotiation and drafting of the Borrower Loan Documents and that the Borrower Loan Documents shall not be subject to the principle of construing their meaning against the party that drafted them. 9.9 No Third Party Beneficiaries. The Borrower Loan Documents are solely for the benefit of the Governmental Lender, Fiscal Agent, the Funding Lender, the Servicer and the Borrower and, with respect to Sections 9.1.3 and 9.1.4 of the Borrower Loan Agreement, the Underwriter Group, and nothing contained in any Borrower Loan Document shall be deemed to confer upon anyone other than the Funding Lender, the Servicer, and the Borrower any right to insist upon or to enforce the performance or observance of any of the obligations contained therein. 9.10 Funding Lender and Servicer Not in Control; No Partnership. None of the covenants or other provisions contained in this Agreement shall, or shall be deemed to, give the Funding Lender or the Servicer the right or power to exercise control over the affairs or management of the Borrower, the power of the Funding Lender and the Servicer being limited to the rights to exercise the remedies referred to in the Borrower Loan Documents. The relationship between the Borrower and the Funding Lender and the Servicer is, and at all times shall remain, solely that of debtor and creditor. No covenant or provision of the Borrower Loan Documents is intended, nor shall it be deemed or construed, to create a partnership, joint venture, agency or common interest in profits or income between the Borrower and the Funding Lender or the Servicer or to create an equity interest in the Mortgaged Property in the Funding Lender or the Loan Covenant Agreement -18- Vista Breeze Servicer. Neither the Funding Lender nor the Servicer undertakes or assumes any responsibility or duty to the Borrower or to any other person with respect to the Mortgaged Property, the Project or the Borrower Loan, except as expressly provided in the Borrower Loan Documents; and notwithstanding any other provision of the Borrower Loan Documents: (1) the Funding Lender and the Servicer are not, and shall not be construed as, a partner, joint venturer, alter ego, manager, controlling person or other business associate or participant of any kind of the Borrower or its stockholders, members, or partners and the Funding Lender and the Servicer do not intend to ever assume such status; (2) the Funding Lender and the Servicer shall in no event be liable for any of the Borrower Payment Obligations, expenses or losses incurred or sustained by the Borrower; and (3) the Funding Lender and the Servicer shall not be deemed responsible for or a participant in any acts, omissions or decisions of the Borrower, the Borrower Controlling Entities or its stockholders, members, or partners. The Funding Lender and the Servicer and the Borrower disclaim any intention to create any partnership, joint venture, agency or common interest in profits or income between the Funding Lender, the Servicer and the Borrower, or to create an equity interest in the Mortgaged Property in the Funding Lender or the Servicer, or any sharing of liabilities, losses, costs or expenses. 9.11 Release. The Borrower hereby acknowledges that it is executing this Agreement and each of the Borrower Loan Documents to which it is a party as its own voluntary act free from duress and undue influence. 9.12 Reimbursement of Expenses. If, upon or after the occurrence of any Event of Default or Potential Default, the Funding Lender, Fiscal Agent or the Servicer shall employ attorneys or incur other expenses for the enforcement of performance or observance of any obligation or agreement on the part of the Borrower contained herein, the Borrower will on demand therefor reimburse the Funding Lender, Fiscal Agent and the Servicer for fees of such attorneys and such other expenses so incurred. 9.13 Relationships with Other Customers. From time to time, Funding Lender and Fiscal Agent may have business relationships with Borrower’s customers, suppliers, contractors, tenants, members, partners, shareholders, officers or directors, or with businesses offering products or services similar to those of Borrower, or with Persons seeking to invest in, borrow from or lend to Borrower. Borrower agrees that Funding Lender and Fiscal Agent may extend credit to such parties and may take any action it may deem necessary to collect the credit, regardless of the effect that such extension or collection of credit may have on Borrower’s financial condition or operations. Borrower further agrees that in no event shall Funding Lender or Fiscal Agent be obligated to disclose to Borrower any information concerning any other customer. 9.14 Permitted Contests. Notwithstanding anything to the contrary contained in this Agreement, Borrower shall have the right to contest or object in good faith to any claim, demand, levy or assessment (other than in respect of Debt or Contractual Obligations of Borrower under any Borrower Loan Document or Related Document) by appropriate legal proceedings that are not prejudicial to Funding Lender’s rights, but this shall not be deemed or construed as in any way relieving, modifying or providing any extension of time with respect to Borrower’s covenant to pay and comply with any such claim, demand, levy or assessment, unless Borrower shall have given prior written notice to Funding Lender of Borrower’s intent to so contest or object thereto, and unless (i) Borrower has, in Funding Lender’s judgment, a reasonable basis for such contest, Loan Covenant Agreement -19- Vista Breeze (ii) Borrower pays when due any portion of the claim, demand, levy or assessment to which Borrower does not object, (iii) Borrower demonstrates to Funding Lender’s satisfaction that such legal proceedings shall conclusively operate to prevent enforcement prior to final determination of such proceedings, (iv) Borrower furnishes such bond, surety, undertaking or other security in connection therewith as required by law, or as requested by and satisfactory to Funding Lender, to stay such proceeding, which bond, surety, undertaking or other security shall be issued by a bonding company, insurer or surety company reasonably satisfactory to Funding Lender and shall be sufficient to cause the claim, demand, levy or assessment to be insured against by the Title Company or removed as a lien against the Mortgaged Property, (v) Borrower at all times prosecutes the contest with due diligence, and (vi) Borrower pays, promptly following a determination of the amount of such claim, demand, levy or assessment due and owing by Borrower, the amount so determined to be due and owing by Borrower. In the event that Borrower does not make, promptly following a determination of the amount of such claim, demand, levy or assessment due and owing by Borrower, any payment required to be made pursuant to clause (vi) of the preceding sentence, an Event of Default shall have occurred, and Funding Lender may draw or realize upon any bond or other security delivered to Funding Lender in connection with the contest by Borrower, in order to make such payment. 9.15 Funding Lender Approval of Instruments and Parties. All proceedings taken in accordance with transactions provided for herein, and all surveys, appraisals and documents required or contemplated by this Agreement and the persons responsible for the execution and preparation thereof, shall be satisfactory to and subject to approval by Funding Lender. Funding Lender’s approval of any matter in connection with the Project or the Mortgaged Property shall be for the sole purpose of protecting the security and rights of Governmental Lender and Funding Lender. No such approval shall result in a waiver of any default of Borrower. In no event shall Funding Lender’s, Fiscal Agent’s and/or Governmental Lender’s approval be a representation of any kind with regard to the matter being approved. 9.16 Funding Lender Determination of Facts. Funding Lender shall at all times be free to establish independently, to its reasonable satisfaction, the existence or nonexistence of any fact or facts, the existence or nonexistence of which is a condition of this Agreement. 9.17 Calendar Months. With respect to any payment or obligation that is due or required to be performed within a specified number of Calendar Months after a specified date, such payment or obligation shall become due on the day in the last of such specified number of Calendar Months that corresponds numerically to the date so specified; provided, however, that with respect to any obligation as to which such specified date is the 29th, 30th or 31st day of any Calendar Month: if the Calendar Month in which such payment or obligation would otherwise become due does not have a numerically corresponding date, such obligation shall become due on the first day of the next succeeding Calendar Month. 9.18 Determinations by Funding Lender. Except to the extent expressly set forth in this Agreement to the contrary, in any instance where the consent or approval of Funding Lender may be given or is required, or where any determination, judgment or decision is to be rendered by Funding Lender under this Agreement, the granting, withholding or denial of such consent or approval and the rendering of such determination, judgment or decision shall be made or exercised Loan Covenant Agreement -20- Vista Breeze by Funding Lender, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. 9.19 Governing Law. This Agreement shall be governed by and enforced in accordance with the laws of the Property Jurisdiction, without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 9.20 Consent to Jurisdiction and Venue. Borrower agrees that any controversy arising under or in relation to this Agreement shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Agreement. Borrower irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Agreement or to enforce any judgment against Borrower or any of Borrower’s assets in any court of any other jurisdiction in which such assets are located. 9.21 Successors and Assigns. This Agreement shall be binding upon and shall inure to the benefit of the parties hereto and their respective heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate. The terms used to designate any of the parties herein shall be deemed to include the heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, of such parties. References to a “person” or “persons” shall be deemed to include individuals and entities. 9.22 Severability. The invalidity, illegality or unenforceability of any provision of this Agreement shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 9.23 Transfer of Mortgaged Property or Ownership Interest in Borrower. If a Transfer (as defined and permitted in the Security Instrument) of all or part of the Mortgaged Property or of an ownership interest in Borrower shall occur, which Transfer requires the prior written consent of Funding Lender, the transferee(s) shall be required to assume the transferor’s duties and obligations under this Agreement and the other Borrower Loan Documents and shall be required to execute and deliver to Funding Lender such documents as Funding Lender requires to effectuate such assumption of duties and obligations. No transfer and assumption shall relieve the transferor of any of its duties or obligations under this Agreement or any of the other Borrower Loan Documents, unless the Borrower has obtained the prior written consent of Funding Lender to the release of such duties and obligations. 9.24 Entire Agreement; Amendment and Waiver. This Agreement contains the complete and entire understanding of the parties with respect to the matters covered. This Agreement may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth Loan Covenant Agreement -21- Vista Breeze in that instrument. No specific waiver of any of the terms of this Agreement shall be considered as a general waiver. 9.25 Counterparts. This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. 9.26 Captions. The captions of the sections of this Agreement are for convenience only and shall be disregarded in construing this Agreement. 9.27 Servicer. Borrower hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Funding Lender may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under the Original Borrower Note, this Agreement or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Borrower receives written notice from Funding Lender to the contrary, any action or right which shall or may be taken or exercised by Funding Lender may be taken or exercised by such servicer with the same force and effect. 9.28 Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Agreement for all purposes. 9.29 Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF BORROWER AND THE BENEFICIARY PARTIES (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 9.30 Time of the Essence. Time is of the essence with respect to this Agreement. 9.31 Limitation on Liability. Borrower assumes all risks of the acts or omissions of Funding Lender, Fiscal Agent and Governmental Lender, provided, however, this assumption is not intended to, and shall not, preclude Borrower from pursuing such rights and remedies as it may have against Governmental Lender, Fiscal Agent and Funding Lender at law or under any other agreement. None of the Beneficiary Parties or any of their respective officers, directors, employees or agents shall be liable or responsible for (i) any acts or omissions of Governmental Lender or Funding Lender; or (ii) the validity, sufficiency or genuineness of any documents, or endorsements, even if such documents should in fact prove to be in any or all respects invalid, insufficient, fraudulent or forged. In furtherance and not in limitation of the foregoing, Funding Lender and Fiscal Agent may accept documents that appear on their face to be in order, without responsibility for further investigation, regardless of any notice or information to the contrary, unless acceptance in light of such notice or information constitutes gross negligence or willful misconduct on the part of Funding Lender or Fiscal Agent. Loan Covenant Agreement -22- Vista Breeze 9.32 Modifications. All modifications (if any) to the terms of this Agreement (“Modifications”) are set forth on Exhibit B attached to this Agreement. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer not requiring Funding Lender’s consent or a Transfer made with Funding Lender’s consent), some or all of the Modifications to this Agreement may be modified or rendered void by Funding Lender at its option by notice to Borrower or such transferee. ARTICLE 10 INCORPORATION OF EXHIBITS. The following exhibits to this Agreement are fully incorporated herein: Exhibit A — Legal Description of the Land Exhibit B — Modifications to Loan Covenant Agreement Exhibit C — Form of Estoppel Certificate The terms of this Agreement are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Agreement, the terms of said Exhibits shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] S-3 Forward Purchase Agreement Vista Breeze IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Loan Covenant Agreement or caused this Loan Covenant Agreement to be duly executed and delivered by their respective authorized representatives as of the date first set forth above. BORROWER: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: Loan Covenant Agreement S-1 Vista Breeze FUNDING LENDER: CITIBANK, N.A. By: __________________________ Name: Title: Deal ID No. 60001596 Loan Covenant Agreement A-1 Vista Breeze EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. Loan Covenant Agreement B-1 Vista Breeze EXHIBIT B MODIFICATIONS TO LOAN COVENANT AGREEMENT The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. C-1 EXHIBIT C FORM OF ESTOPPEL CERTIFICATE [Month] [Date], 202[_] Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Re: Vista Breeze; Deal ID No. 60001596 Re: Ground leased property located at 175 S. Shore Drive and 280 S. Shore Drive, Miami Beach, Florida 33141, and commonly known as Vista Breeze (“Property”) Ladies and Gentlemen: The undersigned, the Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (“Lessor”), as lessor under that certain Second Amended and Restated Ground Lease (“Lease”), dated as of December 15, 2023, between Lessor and Vista Breeze, Ltd., a Florida limited partnership (“Lessee”), as lessee, covering the Property, warrants, represents and certifies to CITIBANK, N.A. and each subsequent owner of the mortgage loan secured by Lessee’s leasehold interest in the Property (collectively or individually, “Lender”) as follows, as of the date of this Ground Lessor’s Estoppel Certificate (“Certificate”): 1. The term of the Lease commenced on December 15, 2023, and expires at 12:01 A.M. 75 years thereafter. 2. The fixed rent under the Lease is comprised of an $129,260 annual base rent, the receipt of which is hereby acknowledged by Lessor. No additional rent or charge (including taxes, maintenance, operating expenses or otherwise) that has been billed to Lessee by Lessor is overdue. There are no provisions for, and Lessor has no rights with respect to, increasing the rent, except as expressly set forth in the Lease. 3. All conditions precedent to the effectiveness of the Lease have been fully satisfied and the Lease is in full force and effect. A list of all the documents constituting the Lease is attached as Schedule A. The Lease has not been assigned, modified, supplemented or amended in any way, except as described on Schedule A. There are no other agreements concerning the Property, whether oral or written, between Lessee and Lessor. 4. Lessor has not delivered or received any notices of default under the Lease; to the best of the Lessor’s knowledge, there is no default by Lessee or Lessor under the Lease, nor has any event or omission occurred which, with the giving of notice or the lapse of time, or both, would constitute a default. C-2 5. Lessor is the record and beneficial owner of the Property. Lessor has not subordinated its interest in the Lease to any mortgage, lien or other encumbrance on the fee. Lessor has not assigned, conveyed, transferred, sold encumbered or mortgaged its interest in the Lease or the Property. 6. No third party has any option or preferential right to purchase all or any part of the Property, except pursuant to that certain Purchase Option Agreement, dated December 15, 2023, in favor of Vista Breeze HACMB, Inc., a Florida not-for-profit corporation, or its affiliate (the “Purchase Option Agreement”), and pursuant to that certain Right of First Refusal Agreement, dated December 15, 2023, in favor of Lessor or its affiliate (the “Right of First Refusal Agreement”), which such Purchase Option Agreement and such Right of First Refusal Agreement shall be subject and subordinate to any and all liens securing the repayment of indebtedness owed to Lender by Lessee in each and every respect. 7. Lessor has not received written notice of any pending eminent domain proceedings or other governmental actions or any judicial actions of any kind against Lessor’s interest in the Property. 8. Lessor has not received written notice that it is in violation of any governmental law or regulation applicable to its interest in the Property and has no reason to believe that there are grounds for any claim of any such violation. 9. No union of the interests of Lessor and Lessee will result in a merger of the Lease into any superior leasehold interest or the fee interest in the Property. 10. Lessor acknowledges that Lender’s address for notice and other purposes under the Lease is as follows: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 AND Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 AND Citibank, N.A. C-3 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291 5754 11. Lessor and the person or persons executing this Certificate on behalf of Lessor have the power and authority to execute this Certificate. 12. Lessor consents to the execution and delivery by Lessee to Lender of an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) covering Lessee’s leasehold interest in and to the Property and the recording of same in the applicable real property records. Lessor also consents to the execution and delivery by Lessee, and the filing and/or recording in the appropriate public records, of such additional documents and instruments as Lender may deem necessary or desirable to establish, perfect and maintain a lien upon and against Lessee’s leasehold interests in the Property, including, but not limited to, Uniform Commercial Code financing statements and such other documents, instruments and agreements as Lender may deem necessary or desirable in connection with the creation, grant, maintenance, renewal, extension, modification or enforcement of the lien. 13. Lessor acknowledges that Lender is a Leasehold Mortgagee under the Lease and is entitled to the benefit of all protections granted to a Leasehold Mortgagee under the Lease without the need for providing any separate notice under the Lease. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] C-4 Lender and its successors and assigns may rely upon the truth and accuracy of the certifications contained in this Certificate, and this Certificate will be binding upon Lessor and its successors and assigns, and inure to the benefit of Lender and its successors and assigns. This Certificate may not be deemed to alter or modify any of the terms and conditions of the Lease. GROUND LESSOR: HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes By: _________________________________ Name: Title: Witness: By: ______________________________ Print Name: ________________________ By: _______________________________ Print Name: ________________________ ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ________________, as _____________ of the Housing Authority of the City of Miami Beach. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): C-5 SCHEDULE A Second Amended and Restated Ground Lease, dated as of December 15, 2023, by and between Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes, as Landlord, and Vista Breeze, Ltd., as Tenant. 4875-5485-1722v.5 D Forward Purchase Agreement Vista Breeze EXHIBIT D-11 TO FORWARD PURCHASE AGREEMENT FORM OF ASSIGNMENT OF HAP CONTRACT [See attached] EXHIBIT D-11 TO FORWARD PURCHASE AGREEMENT FORM OF ASSIGNMENT OF HOUSING ASSISTANCE PAYMENTS AGREEMENT THIS ASSIGNMENT OF HAP CONTRACT (this “Assignment”) is made as of the 1st day of [_], 20[_], by VISTA BREEZE, LTD., a Florida limited partnership (“Assignor”), for the benefit of CITIBANK, N.A., a national banking association (together with its successors and assigns, collectively, “Assignee”). The date of this Assignment as set forth above is for reference purposes only, and this Assignment will not be effective and binding until the Closing Date (as defined in the Borrower Loan Agreement (as hereinafter defined)). This Assignment is a collateral assignment and not a present assignment of rights and interests, and is effective only upon the occurrence of an Event of Default (as defined in the Borrower Loan Agreement). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and Assignor, Assignor is the holder of a leasehold interest in the Land. B. Assignor previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Assignor previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023 (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and Assignor. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Assignor payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. Assignment of HAP Contract 2 Vista Breeze E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Assignor for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Assignor, Assignor, Original Funding Lender and Assignee entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Assignee agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, Assignee has acquired the Funding Loan from the Original Funding Lender, and in connection therewith, (i) Assignee has agreed to enter into a certain Amended and Restated Funding Loan Agreement dated as of the date hereof (the “Funding Loan Agreement”) by and among Governmental Lender, Fiscal Agent, and Assignee, which amends and restates the Original Funding Loan Agreement; (ii) Assignor and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement dated as of the date hereof (the “Borrower Loan Agreement”) which amends and restates the Original Borrower Loan Agreement; (iii) Assignor has executed and delivered an Amended and Restated Multifamily Note, dated as of [Month] [Day], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Assignor has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida), dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Assignee and Assignor have entered into a certain Loan Covenant Agreement and dated as of the date hereof (the “Loan Covenant Agreement”; together with the Borrower Note, the Security Instrument, the Borrower Loan Agreement and all other documents executed in connection with the Borrower Loan, including this Agreement, the “Borrower Loan Documents”). I. The term “Beneficiary Parties” as used herein shall mean Assignee, Governmental Lender and any Servicer, and their respective successors and assigns. The term “Beneficiary Parties” shall also include any lawful owner, holder or pledgee of the Note. J. Assignor has entered into that certain Housing Assistance Payments Contract pursuant to Section 8 with the Housing Authority of the City of Miami Beach, a public body corporate and politic (“Contract Administrator”) identified as Section 8 HAP Contract Number _______________ with an effective date of _____________, covering units within the Mortgaged Property (as the same may be extended, renewed, amended, modified, supplemented Assignment of HAP Contract 3 Vista Breeze or restated from time to time, the “HAP Contract”), a copy of which is attached hereto as Exhibit A. K. As a condition to the purchase of the Funding Loan by Assignee, Assignor is required to enter into this Assignment and assign and pledge to Assignee all of Assignor’s rights, title and interests in, to and under the HAP Contract, for the purpose of providing additional security for the full payment and performance by Assignor of all of its obligations under the Borrower Loan Documents. NOW, THEREFORE, for and in consideration of the making of the Funding Loan and the Borrower Loan, the mutual promises and covenants herein contained, and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, Assignor agrees as follows: 1. Definitions. Capitalized terms which appear and are not otherwise defined herein shall have the meanings ascribed to such terms in the Security Instrument. The definitions and recitals set forth hereinabove are incorporated herein by reference to the same extent and with the same force and effect as if fully hereinafter set forth. 2. Assignment. Assignor hereby absolutely, unconditionally and irrevocably transfers, conveys, sets over and assigns to Assignee, all of its right, title, and interest (including, but not limited to, the right to receive payments due thereunder) in and to the HAP Contract, together with full power and authority, in the name of the Assignor, to enforce, collect, receive, and provide receipt for any and all of the foregoing. The foregoing assignment is being made by Assignor to Assignee as collateral security for the full payment and performance by Assignor of all of its obligations under the Borrower Loan Documents. It is the intention of the Assignor to establish a present, absolute and irrevocable transfer and assignment to Assignee of all rights under the HAP Contract and to authorize and empower Assignee to exercise all rights and remedies available under the HAP Contract without the necessity of further action on the part of Assignor. This Assignment shall be effective immediately upon the execution of this Assignment and is not conditioned upon the occurrence of any default under any of the Borrower Loan Documents. 3. License. Until the occurrence of an Event of Default, Assignee hereby grants to Assignor a revocable license to collect the payments due under the HAP Contract, to hold the payments in trust for the benefit of Assignee, and to apply the payments under the HAP Contract to pay the installments of interest and principal then due and payable under the Note, and the other amounts then due and payable under the Borrower Loan Documents, and to pay the current costs and expenses of managing, operating and maintaining the Mortgaged Property, including utilities, taxes and insurance premiums, tenant improvements and other capital expenditures required to maintain the housing as decent, safe and sanitary. So long as no Event of Default has occurred and is continuing (it being acknowledged and agreed that in no event shall Assignee have any obligation to accept a cure of an Event of Default), the funds from the payments under the HAP Contract remaining after application pursuant to the preceding sentence may be retained by the Assignor free and clear of, and released from, Assignee’s rights with respect to the payments under the HAP Contract. Assignment of HAP Contract 4 Vista Breeze 4. Termination of License. Upon the occurrence of an Event of Default, and without the necessity of Assignee entering upon and taking and maintaining control of the Mortgaged Property directly, or by a receiver, Assignor’s license to collect payments under the HAP Contract shall automatically terminate, without notice to Assignor, and Assignee shall be entitled to all payments under the HAP Contract, as applicable, as they become due and payable, including payments then due and unpaid. 5. Payments to Assignee. (a) Assignor shall direct and pay to Assignee upon demand all payments under the HAP Contract to which Assignee is entitled. Assignor also agrees that in the event it does not transfer any payments received by Assignor under the HAP Contract to Assignee within three business days of its receipt of such payments from HUD or Contract Administrator it shall constitute an Event of Default under the Borrower Loan Documents for which Assignor shall be personally liable to the extent of the HAP payments received. (b) Assignor also agrees that upon receipt by HUD or Contract Administrator of written notice by Assignee of termination of the license with respect to the HAP Contract, HUD and Contract Administrator shall be entitled to make payments to Assignee or its assign. Assignor agrees that it shall not take any action or engage in any communication with HUD or Contract Administrator which is intended to delay or prohibit HUD’s or Contract Administrator’s payments to Assignee. Assignor agrees and instructs that HUD and Contract Administrator shall not be required to consider or to make any inquiry as to the existence of a default under the Borrower Loan Documents, but may rely solely on the notice by Assignee. (c) Assignee agrees that it shall apply any HAP payments it receives to the installments of interest and principal then due and payable under the Note and the other amounts then due and payable under the Borrower Loan Documents, and shall apply or cause such payments to be applied to the current costs and expenses of managing, operating and maintaining the Mortgaged Property, including utilities, taxes and insurance premiums, tenant improvements and other capital expenditures immediately required to maintain the housing as decent, safe and sanitary. (d) Assignor hereby warrants, represents, covenants and agrees to strictly comply with the terms of the HAP Contract and all other requirements of HUD and Contract Administrator with respect thereto, and Assignor covenants and agrees to continue to perform all of its obligations under the HAP Contract. Assignor agrees to provide Assignee with copies of all notices from HUD and/or Contract Administrator of any default of Assignor’s obligations under the HAP Contract and all certificates, reports, records, reviews, notices, correspondence, records, and other written communications received from, or sent to HUD and/or Contract Administrator which copies shall be received by Assignee no later than five (5) days following the receipt or sending thereof by Assignor, as the case may be. Assignment of HAP Contract 5 Vista Breeze 6. Financing Statements. Assignor authorizes Assignee to file financing statements in the appropriate jurisdictions in order to publish notice of and fully perfect this Assignment. 7. Representations of Assignor. Assignor warrants, represents, covenants and agrees that there have been no other assignments of the HAP Contract; that Assignor will not further assign, transfer, exchange, pledge, or otherwise dispose of its interest in and to the HAP Contract; and that any such existing or further assignment, transfer, exchange, pledge or other disposition is and would be void. 8. Unconditional Assignment. (a) The obligations of the Assignor hereunder shall be performed without demand by Assignee and shall be unconditional irrespective of the genuineness, validity, or enforceability of the Note, or any other Borrower Loan Document, and without regard to any other circumstance which might otherwise constitute a legal or equitable discharge of the Assignor. Assignor hereby waives the benefits of any right of discharge and all other rights under any and all statutes to the fullest extent permitted by law, diligence in collecting the payments due under the HAP Contract, presentment, demand for payment, protest, all notices with respect to the Note and Borrower Loan Documents, which may be required by statute, rule of law or otherwise to preserve Assignee’s rights against the Assignor under this Assignment, including notice of acceptance, notice of any amendment of the Borrower Loan Documents, notice of the occurrence of any default or Event of Default, notice of intent to accelerate, notice of acceleration, notice of dishonor, notice of foreclosure, notice of protest, notice of the incurring by Assignor of any obligation or indebtedness and all rights to require Assignee to (a) proceed against Assignor, (b) proceed against any general partner of Assignor, (c) proceed against or exhaust any collateral held by Assignee to secure the repayment of the Indebtedness or the HAP payments, or (d) if Assignor is a partnership, pursue any other remedy it may have against Assignor, or any general partner of Assignor. (b) Assignor agrees that its intent in executing this Assignment is to create an absolute, unconditional and irrevocable assignment of all of its right, title and interest in and to the HAP Contract to Assignee and its intent is not to create a security interest in said HAP Contract. To the extent that this Assignment may conflict or otherwise be inconsistent with any other agreement signed by the Assignor in connection with the assignment of the HAP Contract, the provisions of this Assignment shall govern. 9. Termination. If not sooner terminated by the written concurrence of the parties, this Assignment shall terminate upon the payment in full of the Borrower Loan and all indebtedness incurred in connection therewith. Notwithstanding the foregoing, any and all provisions herein relating to the indemnification of the Beneficiary Parties shall survive such termination. 10. Determinations by Assignee. Except to the extent expressly set forth in this Assignment to the contrary, in any instance where the consent or approval of Assignee may be given or is required, or where any determination, judgment or decision is to be rendered by Assignee under this Assignment, the granting, withholding or denial of such consent or approval Assignment of HAP Contract 6 Vista Breeze and the rendering of such determination, judgment or decision shall be made or exercised by Assignee, as applicable (or its designated representative) at its sole and exclusive option and in its sole and absolute discretion. 11. Release; Indemnity. (a) Release. Assignor covenants and agrees that, in performing any of their rights or duties under this Assignment, neither the Beneficiary Parties, nor their agents or employees, shall be liable for any losses, claims, damages, liabilities and expenses that may be incurred by any of them as a result of such performance, except to the extent such liability for any losses, claims, damages, liabilities or expenses arises out of the willful misconduct or gross negligence of such party. (b) Indemnity. Assignor hereby agrees to indemnify and hold harmless the Beneficiary Parties and their respective agents and employees from and against any and all losses, claims, damages, liabilities and expenses including, without limitation, reasonable attorneys’ fees and costs and disbursements, which may be imposed or incurred by any of them in connection with this Assignment, except that no such party will be indemnified for any losses, claims, damages, liabilities or expenses arising out of the willful misconduct or gross negligence of such party. Assignor assigns to Assignee all rights and claims Assignor may have against any other party in connection with the HAP Contract; provided, however, that Assignee may not pursue any such right or claim unless a default exists under this Assignment or an Event of Default shall have occurred under the Security Instrument. 12. Governing Law. This Assignment shall be governed by and enforced in accordance with the laws of the Property Jurisdiction (or to the extent inconsistent with the laws of the Property Jurisdiction, the laws of the United States of America), without giving effect to the choice of law principles of the Property Jurisdiction that would require the application of the laws of a jurisdiction other than the Property Jurisdiction. 13. Consent to Jurisdiction and Venue. Assignor agrees that any controversy arising under or in relation to this Assignment shall be litigated exclusively in the Property Jurisdiction. The state and federal courts and authorities with jurisdiction in the Property Jurisdiction shall have exclusive jurisdiction over all controversies which shall arise under or in relation to this Assignment. Assignor irrevocably consents to service, jurisdiction, and venue of such courts for any such litigation and waives any other venue to which it might be entitled by virtue of domicile, habitual residence or otherwise. However, nothing herein is intended to limit Beneficiary Parties’ right to bring any suit, action or proceeding relating to matters arising under this Assignment against Assignor or any of Assignor’s assets in any court of any other jurisdiction. 14. Successors and Assigns. This Assignment shall be binding upon Assignor and its heirs, legal representatives, successors, successors-in-interest and assigns, as appropriate, and shall inure to the benefit of the Beneficiary Parties and their respective successors, successors-in- interest and assigns. The terms used to designate any of the parties herein shall be deemed to include the heirs, legal representatives, successors, successors-in-interest and assigns, as Assignment of HAP Contract 7 Vista Breeze appropriate, of such parties. References to a “person” or “persons” shall be deemed to include individuals and entities. Assignor acknowledges and agrees that any Beneficiary Party, at its option, may assign its respective rights and interests under this Assignment and the other Borrower Loan Documents in whole or in part and upon such assignment all the terms and provisions of this Assignment or the other Borrower Loan Documents shall inure to the benefit of such assignee to the extent so assigned. Assignor may not assign or delegate its rights, interests or obligations under this Assignment without first obtaining Assignee’s prior written consent. 15. Severability. The invalidity, illegality or unenforceability of any provision of this Assignment shall not affect the validity, legality or enforceability of any other provision, and all other provisions shall remain in full force and effect. 16. Expenses. Assignor shall pay to the Beneficiary Parties, upon demand, the amount of any and all expenses, including, without limitation, reasonable attorneys’ fees (including reasonable time charges of attorneys who may be employees of Beneficiary Parties), which the Beneficiary Parties may incur in connection with (a) the custody, preservation or sale of, collection from, or other realization upon any of the collateral assigned or encumbered by this Assignment, (b) the exercise or enforcement of any of their rights hereunder, (c) the failure by Assignor to perform or observe any of the provisions hereof, or (d) the breach by Assignor of any representation or warranty of Assignor set forth herein. Such expenses, together with interest thereon computed at the Default Rate set forth in the Note from the date on which such expenses are incurred to the date of payment thereof, shall constitute indebtedness secured by the Security Instrument. 17. Remedies Cumulative. In the event of Assignor’s default under this Assignment, the Beneficiary Parties may exercise all or any one or more of their rights and remedies available under this Assignment, at law or in equity. Such rights and remedies shall be cumulative and concurrent, and may be enforced separately, successively or together, and the exercise of any particular right or remedy shall not in any way prevent the Beneficiary Parties from exercising any other right or remedy available to the Beneficiary Parties. The Beneficiary Parties may exercise any such remedies from time to time as often as may be deemed necessary by the Beneficiary Parties. 18. No Agency or Partnership. Nothing contained in this Assignment shall constitute any Beneficiary Party as a joint venturer, partner or agent of Assignor, or render any Beneficiary Party liable for any debts, obligations, acts, omissions, representations or contracts of Assignor. 19. Transfer of Mortgaged Property or Ownership Interests in Assignor. If a Transfer (as defined in the Security Instrument) of all or part of the Mortgaged Property or of an ownership interest in Assignor, shall occur, which Transfer requires the prior written consent of Assignee, the transferee(s) shall be required to assume the transferor’s duties and obligations under this Assignment and the other Borrower Loan Documents and shall be required to execute and deliver to Assignee such documents as Assignee requires to effectuate such assumption of duties and obligations. No transfer and assumption shall relieve the transferor of any of its duties or obligations under this Assignment or any of the other Borrower Loan Documents, unless the Assignment of HAP Contract 8 Vista Breeze Assignor has obtained the prior written consent of Assignee to the release of such duties and obligations. 20. Entire Agreement; Amendment and Waiver. This Assignment contains the complete and entire understanding of the parties with respect to the matters covered herein. This Assignment may not be amended, modified or changed, nor shall any waiver of any provision hereof be effective, except by a written instrument signed by the party against whom enforcement of the waiver, amendment, change, or modification is sought, and then only to the extent set forth in that instrument. No specific waiver of any of the terms of this Assignment shall be considered as a general waiver. 21. Further Assurances. Assignor shall at any time and from time to time, promptly execute and deliver all further instruments and documents, and take all further action that may be reasonably necessary or desirable, or that any Beneficiary Party may reasonably request, in order to protect any right or interest granted by this Assignment or to enable the Beneficiary Party to exercise and enforce its rights and remedies under this Assignment. 22. No Amendment; Conflicts. Nothing contained in this Assignment shall be construed to amend, modify, alter, change or supersede the terms and provisions of the Note, the Security Instrument or the Borrower Loan Agreement; and, if there is a conflict between the terms and provisions of this Assignment and those of the Note, the Security Instrument or the Borrower Loan Agreement, then the terms and provisions of the Note, the Security Instrument or the Borrower Loan Agreement shall control. 23. Limitation of Liability. The personal liability of Assignor for the payment and performance of the obligations hereunder is limited in the manner and to the extent provided in the Note. 24. Notices. All notices given under this Assignment shall be in writing and shall be sent to the respective addresses of the parties, in the manner set forth in the Security Instrument. 25. Counterparts. This Assignment may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. 26. Captions. The captions of the sections of this Assignment are for convenience only and shall be disregarded in construing this Assignment. 27. Servicer. Assignor hereby acknowledges and agrees that, pursuant to the terms of the Security Instrument: (a) from time to time, Assignee may appoint a servicer to collect payments, escrows and deposits, to give and to receive notices under the Note, this Assignment or the other Borrower Loan Documents, and to otherwise service the Borrower Loan and (b) unless Assignor receives written notice from Assignee to the contrary, any action or right which shall or may be taken or exercised by Assignee may be taken or exercised by such servicer with the same force and effect. 28. Beneficiary Parties as Third Party Beneficiary. Each of the Beneficiary Parties shall be a third party beneficiary of this Assignment for all purposes. Assignment of HAP Contract 9 Vista Breeze 29. Waiver of Trial by Jury. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF ASSIGNOR AND THE BENEFICIARY PARTIES (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS ASSIGNMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 30. Time of the Essence. Time is of the essence with respect to this Assignment. 31. Modifications. All modifications (if any) to the terms of this Assignment (“Modifications”) are set forth on Exhibit B attached to this Assignment. In the event of a Transfer under the terms of the Security Instrument (other than a Permitted Transfer that does not require the consent of the Funding Lender), some or all of the Modifications to this Assignment may be modified or rendered void by Assignee at its option by notice to Assignor or such transferee. 32. Attached Exhibits. The following Exhibits are attached to this Assignment and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Housing Assistance Payments Contract with Amendments, if any Exhibit B - Modifications to Assignment of Housing Assistance Payments Agreement The terms of this Assignment are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Assignment, the terms of said Exhibits shall be controlling in all respects. Assignment of HAP Contract A-1 Vista Breeze IN WITNESS WHEREOF, the undersigned has caused this Assignment of Housing Assistance Payments Agreement to be signed and delivered by its duly authorized representative as of the date first set forth above. ASSIGNOR: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: Assignment of HAP Contract A-2 Vista Breeze EXHIBIT A HOUSING ASSISTANCE PAYMENTS CONTRACT WITH AMENDMENTS, IF ANY [See Attached.] Assignment of HAP Contract C-1 Vista Breeze EXHIBIT B MODIFICATIONS TO ASSIGNMENT OF HOUSING ASSISTANCE PAYMENTS AGREEMENT The following modifications are made to the text of the Assignment that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Assignment. 4888-6295-0282 D Forward Purchase Agreement Vista Breeze EXHIBIT D-12 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT (CITY) [See attached] THIS INSTRUMENT PREPARED BY: Aviva Yakren, Esq. Sidley Austin LLP 787 Seventh Avenue New York, New York 10019 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: Citibank, N.A. Transaction and Asset Management Group/Post Closing Citi Community Capital 3800 Citibank Center Tampa, Florida 33610 Re: Vista Breeze Deal ID No. 60001596 ABOVE SPACE RESERVED FOR RECORDING PURPOSES ONLY EXHIBIT D-12 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT Subordination and Intercreditor Agreement (City) Vista Breeze EXHIBIT D-12 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT THIS SUBORDINATION AND INTERCREDITOR AGREEMENT (this “Agreement”) dated as of the [_] day of [Month], 202[_], is made by and between CITY OF MIAMI BEACH, FLORIDA, a political subdivision of the State of Florida (“Junior Lender”) and CITIBANK, N.A., a national banking association (“Senior Lender”) and acknowledged by VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Conversion Date (as defined in the Original Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, Subordination and Intercreditor Agreement (City) 2 Vista Breeze 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Senior Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Senior Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, the Borrower Loan has converted into a permanent loan (the “Senior Loan”), and in connection therewith, (i) Senior Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement, dated as of the date hereof (the “Funding Loan Agreement”), by and among Governmental Lender, Fiscal Agent, and Senior Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement, dated as of the date hereof (the “Borrower Loan Agreement”), which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [_], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) executed and delivered by Borrower and dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Senior Lender and Borrower have entered into a certain the Loan Covenant Agreement executed and delivered by Borrower and dated as of the date hereof (the “Loan Covenant Agreement”). I. Junior Lender has made a loan in the principal amount of $500,000 to Borrower, as evidenced by that certain Promissory Note dated as of September 21, 2023, made by Borrower, as maker, to Junior Lender, as payee, and has agreed to make an additional future advance loan in the amount of $503,969 for a total indebtedness from Borrower to Junior Lender in the amount of $1,003,969 (the “Junior Loan”), which Junior Loan is evidenced by a certain Amended, Restated, Renewal and Consolidated Promissory Note dated as of December 15, 2023 made by Borrower to Junior Lender (the “Junior Note”) and secured by, the Junior Security Instrument (as hereinafter defined) encumbering the Property, and will be advanced to Borrower pursuant to that certain Amended and Restated HOME Program Development Agreement (the “Junior Loan Agreement”), dated as of December 15, 2023, between Borrower and Junior Lender. J. As a condition to the making of the Senior Loan, Senior Lender requires that Junior Lender execute and deliver this Agreement prior to conversion of the Borrower Loan to the Senior Loan. Subordination and Intercreditor Agreement (City) 3 Vista Breeze NOW, THEREFORE, for Ten Dollars ($10.00) and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, and to induce the making of the Senior Loan and to induce Senior Lender to consent to the Junior Loan and the Junior Security Instrument, Junior Lender hereby agrees as follows: 1. Definitions. Capitalized terms used but not defined in this Agreement shall have the meanings ascribed thereto in the Senior Security Instrument. As used in this Agreement, the terms set forth below shall have the respective meanings indicated: “Bankruptcy Proceeding” means any bankruptcy, reorganization, insolvency, composition, restructuring, dissolution, liquidation, receivership, assignment for the benefit of creditors, or custodianship action or proceeding under any federal or state law with respect to Borrower, any guarantor of any of the Senior Indebtedness, any of their respective properties, or any of their respective partners, members, officers, directors, or shareholders. “Casualty” means the occurrence of damage to or loss of any of the Property by fire or other casualty. “Condemnation” means any proposed or actual condemnation or other taking, or conveyance in lieu thereof, of all or any part of the Property, whether direct or indirect. “Enforcement Action” means any exercise of any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Loan Documents, including, without limitation, any of the following: (i) the acceleration of all or any part of the Junior Indebtedness, (ii) the commencement of any judicial or non-judicial action or proceeding to enforce any obligation of Borrower under any of the Junior Loan Documents, collect any monies payable to Borrower or have a receiver appointed to collect any monies payable to Borrower, or foreclose the lien(s) created by the Junior Security Instrument, (iii) the filing or joining in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower, (iv) the advertising of or commencement of any foreclosure or trustee’s sale proceedings, (v) the exercise of any power of sale, (vi) the acceptance of a deed or assignment in lieu of foreclosure or sale, (vii) the collecting of Rents, (viii) the obtaining of or seeking of the appointment of a receiver, (ix) the seeking of default interest, (x) the taking of possession or control of any of the Property, (xi) the commencement of any suit or other legal, administrative, or arbitration proceeding based upon the Junior Note or any other of the Junior Loan Documents, (xii) the exercising of any banker’s lien or rights of set-off or recoupment, or (xiii) the taking of any other enforcement action against Borrower, any other party liable for any of the Junior Indebtedness or obligated under any of the Junior Loan Documents, or the Property. “Enforcement Action Notice” means a written notice from Junior Lender to Senior Lender, given following a Junior Loan Default and the expiration of any notice or cure periods provided for such Junior Loan Default in the Junior Loan Documents, setting forth in reasonable detail the Enforcement Action proposed to be taken by Junior Lender. “Junior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Junior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. Subordination and Intercreditor Agreement (City) 4 Vista Breeze “Junior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Junior Security Instrument. “Junior Loan Documents” means, collectively, the Junior Note, the Junior Security Instrument, the Junior Loan Agreement, that certain Amended and Restated Declaration of Restrictive Covenants, dated as of December 15, 2023, made by Borrower and Landlord in favor of Junior Lender (the “Junior Declaration”), and all other documents evidencing, securing or delivered in connection with the Junior Loan, all of which are listed on Exhibit B attached hereto, together with such modifications, amendments and supplements thereto as are approved in writing by Senior Lender prior to their execution, to the extent required by this Agreement. “Junior Security Instrument” means that certain Amended and Restated Leasehold Mortgage, Security Agreement and Fixture Filing dated as of December 15, 2023, by Borrower in favor of Junior Lender, made by Borrower for the benefit of Junior Lender, as the same may from time to time be extended, consolidated, substituted for, modified, amended or supplemented upon receipt of the consent of Senior Lender to the extent required by this Agreement. “Loan Agreement” means the Loan Covenant Agreement. “Loss Proceeds” means all monies received or to be received under any insurance policy, from any condemning authority, or from any other source, as a result of any Condemnation or Casualty. “Property” means (i) the land and improvements known or to be known as Vista Breeze, located in the City of Miami Beach, Miami-Dade County, State of Florida, which Property is more particularly described on Exhibit A attached hereto, and (ii) all furniture, fixtures and equipment located at such apartments and other property, accounts, deposits and rights and interests of Borrower encumbered by the Senior Security Instrument and/or the other Senior Loan Documents. “Senior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Senior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. “Senior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Senior Security Instrument. “Senior Loan Documents” means, collectively, the Senior Security Instrument, the Senior Note, the Borrower Loan Agreement and all of the other documents, instruments and agreements now or hereafter evidencing, securing or otherwise executed in connection with the Senior Loan, as the same may from time to time be extended, consolidated, substituted for, modified, increased, amended and supplemented in accordance with the provisions of this Agreement. Subordination and Intercreditor Agreement (City) 5 Vista Breeze 2. Junior Loan and Junior Loan Documents are Subordinate; Acts by Senior Lender do not Affect Subordination. (a) Junior Lender hereby covenants and agrees on behalf of itself and its successors and permitted assigns that the Junior Indebtedness is and shall at all times continue to be, subordinate, subject and inferior in priority and in payment, to the extent and in the manner provided in this Agreement to the prior payment in full of the Senior Indebtedness, and that the liens, rights, payment interests, priority interests and security interests granted to Junior Lender in connection with the Junior Loan and under the Junior Loan Documents are, and are hereby expressly acknowledged to be in all respects and at all times, subject, subordinate and inferior in all respects to the liens, rights, payment, priority and security interests granted to Senior Lender under the Senior Loan and the Senior Loan Documents. (b) Except as expressly set forth herein, repayment of the Junior Indebtedness, is and shall be postponed and subordinated to repayment in full of the Senior Loan. Prior to a Senior Loan Default (regardless of whether such Senior Loan Default occurs prior to or during the pendency of a Bankruptcy Proceeding), Junior Lender shall be entitled to receive and retain payments made pursuant to and in accordance with the terms of the Junior Loan Documents; provided, however, that no such payment is made more than thirty (30) days in advance of the due date thereof. Junior Lender agrees that from and after such time as it has received from either Senior Lender or Borrower written notice that a Senior Loan Default then exists (which has not been expressly waived in writing by Senior Lender) or otherwise has actual knowledge of such a Senior Loan Default, Junior Lender shall not receive or accept any payments under the Junior Loan. If (i) Junior Lender receives any payment, property, or asset of any kind or in any form on account of the Junior Indebtedness (including, without limitation, any proceeds from any Enforcement Action) after a Senior Loan Default of which Junior Lender has (i) received written notice from Senior Lender or Borrower in accordance with this Agreement, or (ii) such payment, property, or asset will be received and held in trust for Senior Lender. Prior to the filing of a Bankruptcy Proceeding, Junior Lender will promptly remit, in kind and properly endorsed as necessary, all such payments, properties, and assets to Senior Lender. Senior Lender shall apply any payment, asset, or property so received from Junior Lender to the Senior Indebtedness in such order, amount (with respect to any asset or property other than immediately available funds), and manner as Senior Lender shall determine in its sole and absolute discretion. Upon Borrower curing the Senior Loan Default or waiver of the Senior Loan Default by Senior Lender, Junior Lender may resume collecting and retaining payments made pursuant to and in accordance with the terms of the Junior Loan Documents. (c) Without limiting the complete subordination of the Junior Indebtedness to the payment in full of the Senior Indebtedness, in any Bankruptcy Proceeding, upon any payment or distribution (whether in cash, property, securities, or otherwise) to creditors (i) the Senior Indebtedness shall first be paid in full in cash before Junior Lender shall be entitled to receive any payment or other distribution on account of or in respect of the Junior Indebtedness, and (ii) until all of the Senior Indebtedness is paid in full in cash, any Subordination and Intercreditor Agreement (City) 6 Vista Breeze payment or distribution to which Junior Lender would be entitled but for this Agreement (whether in cash, property, or other assets) shall be made to Senior Lender. (d) The subordination of the Junior Indebtedness shall continue in the event that any payment under the Senior Loan Documents (whether by or on behalf of Borrower, as proceeds of security or enforcement of any right of set-off or otherwise) is for any reason repaid or returned to Borrower or its insolvent estate, or avoided, set aside or required to be paid to Borrower, a trustee, receiver or other similar party under any bankruptcy, insolvency, receivership or similar law. In such event, the Senior Indebtedness or part thereof originally intended to be satisfied shall be deemed to be reinstated and outstanding to the extent of any repayment, return, or other action, as if such payment on account of the Senior Indebtedness had not been made. (e) The subordination of the Junior Loan Documents and of the Junior Indebtedness shall apply and continue notwithstanding (i) the actual date and time of execution, delivery, recording, filing or perfection of the Senior Security Instrument and other Senior Loan Documents and of the Junior Security Instrument and other Junior Loan Documents, and (ii) the availability of any collateral to Senior Lender, including the availability of any collateral other than the Property. (f) By reason of, and without in any way limiting, the full subordination of the Junior Indebtedness and the Junior Loan Documents provided for in this Agreement, all rights and claims of Junior Lender under the Junior Security Instrument or under the Junior Loan Documents in or to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto, are, to the extent and in the manner provided in this Agreement, expressly subject and subordinate in all respects to the rights and claims of Senior Lender under the Senior Loan Documents in and to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto. (g) If Junior Lender, by indemnification, subrogation or otherwise, shall acquire any lien, estate, right or other interest in any of the Property, that lien, estate, right or other interest shall be fully subject and subordinate to the receipt by Senior Lender of payment in full of the Senior Indebtedness, to the extent and in the manner provided in this Agreement, and to the Senior Loan Documents, to the same extent as the Junior Indebtedness and the Junior Loan Documents are subordinate pursuant to this Agreement. (h) In confirmation, and not as a condition, of the subordination of the Junior Indebtedness and the Junior Loan Documents provided for in this Agreement, and for so long as the Senior Loan is outstanding, the Junior Note shall be deemed to include the following provision: “The indebtedness evidenced by this Note is and shall be subordinate in right of payment, to the extent and in the manner provided in the Subordination Agreement (as defined herein), to the prior payment in full of all amounts then due and payable (including, but not limited to, all Subordination and Intercreditor Agreement (City) 7 Vista Breeze amounts due and payable by virtue of any default or acceleration or upon maturity) with respect to the indebtedness evidenced by the Note (as defined by that certain Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) by the Borrower in favor of Governmental Lender and assigned to The Bank of New York Mellon Trust Company, N.A., a national banking association, in the original maximum principal amount of $[11,875,000] [NOTE: AS MAY BE INCREASED PER THE EARN-OUT]) to the extent and in the manner provided in that certain Subordination and Intercreditor Agreement, dated as of [_______], 20 [___], between Citibank, N.A. (“Senior Lender”) and the holder of this Note (the “Subordination Agreement”). The rights and remedies of the payee and each subsequent holder of this Note shall be deemed, by virtue of such holder’s acquisition of this Note, to have agreed to perform and observe all of the terms, covenants and conditions to be performed or observed by the “Junior Lender” under the Subordination Agreement.” (i) Junior Lender hereby acknowledges and agrees that Senior Lender may, without the consent or approval of Junior Lender, agree with Borrower to extend, consolidate, modify, or amend any or all the Senior Loan Documents and otherwise act or fail to act with respect to any matter set forth in any Senior Loan Document (including, without limitation, the exercise of any rights or remedies, waiver, forbearance or delay in enforcing any rights or remedies, the declaration of acceleration, the declaration of defaults or events of default, the release, in whole or in part, of any collateral or other property, and any consent, approval or waiver), and all such extensions, consolidations, modifications, amendments acts and omissions shall not release, impair or otherwise affect Junior Lender’s obligations and agreements hereunder; provided, however, notwithstanding the foregoing or anything else to the contrary in this Agreement, Senior Lender shall not modify any provision of the Senior Loan Documents that increases the interest rate, extends the term (other than extensions expressly provided for in accordance with the Senior Loan Documents) or increases the Senior Indebtedness, except for increases in the Senior Indebtedness that result from advances made by Senior Lender to protect the security or lien priority of Senior Lender under the Senior Loan Documents or to cure defaults under the Junior Loan Documents. 3. Junior Lender Agreements. (a) Without the prior written consent of Senior Lender in each instance, which consent shall not be unreasonably withheld, conditioned or delayed, Junior Lender shall not (i) amend, modify, waive, extend, renew or replace any provision of any of the Junior Loan Documents, or (ii) pledge, assign, transfer, convey, or sell any interest in the Junior Indebtedness or any of the Junior Loan Documents unless the transferee is a governmental entity, quasi-governmental entity, or a nonprofit entity created and controlled by the City of Miami Beach, and Senior Lender is given thirty (30) days’ prior written notice of any such transfer and acknowledgment by transferee that the loan remains subject to this Agreement, and provided that in no event may any such pledge, assignment, transfer, conveyance or sale be to Borrower or its affiliates; or (iii) accept any payment on account Subordination and Intercreditor Agreement (City) 8 Vista Breeze of the Junior Indebtedness other than a regularly scheduled payment of interest or principal and interest made not earlier than thirty (30) days prior to the due date thereof; or (iv) take any action which has the effect of increasing the Junior Indebtedness; or (v) appear in, defend or bring any action in connection with the Property until such time as the Junior Lender Standstill Period has expired; or (vi) take any action concerning environmental matters affecting the Property. Regardless of any contrary provision in the Junior Loan Documents, Junior Lender shall not collect payments for the purpose of escrowing for any cost or expense related to the Property or for any portion of the Junior Indebtedness. Notwithstanding anything to the contrary herein, Junior Lender agrees that, until the principal of, interest on and all other amounts payable under the Senior Loan Documents have been paid in full, it will not, without the prior written consent of Senior Lender, increase the amount of the Junior Loan, increase the required payments due under the Junior Loan, decrease the term of the Junior Loan, increase the interest rate on the Junior Loan, or otherwise amend the Junior Loan terms in a manner that creates an adverse effect upon Senior Lender under the Junior Loan Documents. If Junior Lender either (i) amends the Junior Loan Documents in the manner set forth above or (ii) assigns the Junior Loan without Senior Lender’s consent except as provided in this Section 3(a), then such amendment or assignment will be void ab initio and of no effect whatsoever. (b) Junior Lender shall give Senior Lender a concurrent copy of each notice of a Junior Loan Default , Enforcement Action Notice or other material notice given by Junior Lender under the Junior Loan Documents. Notwithstanding any contrary provision in the Junior Loan Documents, Senior Lender shall have the right, but shall not have any obligation, to cure any Junior Loan Default until ninety (90) days following Senior Lender’s receipt of an Enforcement Action Notice given by Junior Lender as a consequence of the Junior Loan Default. Senior Lender shall not be subrogated to the rights of Junior Lender under the Junior Loan Documents by reason of Senior Lender having cured any Junior Loan Default. However, Junior Lender acknowledges that all amounts advanced or expended by Senior Lender to cure a Junior Loan Default shall be added to and become a part of the Senior Indebtedness pursuant to the terms of the Senior Security Instrument. (c) Senior Lender shall have all approval, consent and oversight rights in connection with any insurance claims relating to the Property, any decisions regarding the use of insurance proceeds after a casualty loss or condemnation awards, and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby. Notwithstanding the foregoing, in the event of an insurance claim, Junior Lender shall be entitled to make its own claim to any insurance proceeds which exceed the total amount owed to, and received by, Senior Lender under the Senior Loan Documents. (d) Junior Lender agrees that in any action commenced to enforce the obligation of Borrower to pay any portion of the Junior Indebtedness, the judgment shall not be enforceable personally against Borrower or Borrower’s assets except in the case of fraud or misrepresentation as set forth in the Junior Note, and the recourse of Junior Lender for the collection of the Junior Indebtedness shall be limited to actions against the Property and the rents, profits, issues, products, and income from the Property. Subordination and Intercreditor Agreement (City) 9 Vista Breeze (e) Without the prior written consent of Senior Lender, Junior Lender will not commence, or join with any other creditor in commencing, any Bankruptcy Proceeding. In the event of a Bankruptcy Proceeding, Junior Lender will not vote affirmatively in favor of any plan of reorganization or liquidation unless Senior Lender has also voted affirmatively in favor of such plan. (f) Junior Lender covenants and agrees that the effectiveness of this Agreement and the rights of Senior Lender hereunder shall be in no way impaired, affected, diminished or released by any renewal or extension of the time of payment of the Senior Loan, by any delay, forbearance, failure, neglect or refusal of Senior Lender in enforcing payment thereof or in enforcing the lien of or attempting to realize upon the Senior Loan Documents or any other security which may have been given or may hereafter be given for the Senior Loan, by any waiver or failure to exercise any right or remedy under the Senior Loan Documents, or by any other act or failure to act by Senior Lender. Junior Lender acknowledges that Senior Lender, at its sole option, may release all or any portion of the Property from the lien of the Senior Security Instrument, and may release or waive any guaranty, surety or indemnity providing additional collateral to Senior Lender, and Junior Lender hereby waives any legal or equitable right in respect of marshaling it might have, in connection with any release of all or any portion of the Property by Senior Lender, to require the separate sales of any portion of the Property or to require Senior Lender to exhaust its remedies against any portion of the Property or any other collateral before proceeding against any other portion of the Property or other collateral (including guarantees) for the Senior Loan. Senior Lender may pursue all rights and remedies available to it under the Senior Loan Documents, at law, or in equity, regardless of any Enforcement Action Notice or Enforcement Action by Junior Lender. At any time or from time to time and any number of times, without notice to Junior Lender and without affecting the liability of Junior Lender, (a) the time for payment of the Senior Indebtedness may be extended or the Senior Indebtedness may be renewed in whole or in part; (b) the time for Borrower’s performance of or compliance with any covenant or agreement contained in the Senior Loan Documents, whether presently existing or hereinafter entered into, may be extended or such performance or compliance may be waived; (c) the maturity of the Senior Indebtedness may be accelerated as provided in the Senior Loan Documents; and (d) any security for the Senior Indebtedness may be modified, exchanged, surrendered or otherwise dealt with or additional security may be pledged or mortgaged for the Senior Indebtedness. If, after the occurrence of a Senior Loan Default, Senior Lender acquires title to any of the Property pursuant to a completed mortgage foreclosure proceeding conducted in accordance with applicable law, the lien, operation, and effect of the Junior Security Instrument and other Junior Loan Documents automatically shall terminate with respect to such Property upon Senior Lender’s acquisition of title. (g) Junior Lender acknowledges that it entered into the transactions contemplated by the Junior Loan Documents and made the Junior Loan to Borrower without reliance upon any information or advice from Senior Lender. Junior Lender made its own underwriting analysis in connection with the Junior Loan and the Borrower, and investigated all matters pertinent, in Junior Lender’s judgment, to its determination to make the Junior Loan to Borrower. Junior Lender acknowledges that it is a sophisticated and Subordination and Intercreditor Agreement (City) 10 Vista Breeze experienced governmental lender and was represented by competent counsel in connection with this Agreement. (h) Junior Lender hereby represents and warrants that, as of the date hereof, the entire proceeds of the Junior Loan have been disbursed to Borrower, except as otherwise notified in writing by Junior Lender to Senior Lender. Junior Lender hereby further represents and warrants that: (i) Junior Lender is now the owner and holder of the Junior Loan Documents; (ii) the Junior Loan Documents are now in full force and effect; (iii) the Junior Loan Documents have not been modified or amended; (iv) to its actual knowledge, no default or event which, with the passing of time or giving of notice would constitute a default, under the Junior Loan Documents has occurred; (v) the current outstanding principal balance of the Junior Indebtedness is $1,003,969; (vi) no scheduled monthly payments under the Junior Loan Documents have been or will be prepaid more than thirty (30) days in advance except with the prior written consent of Senior Lender; (vii) none of the rights of Junior Lender under any of the Junior Loan Documents are subject to the rights of any third parties, by way of subrogation, indemnification or otherwise; and (viii) there are no other Junior Loan Documents other than those listed on Exhibit B hereto. Borrower further represents and warrants that it has provided to Senior Lender a true, complete, and correct copy of all the Junior Loan Documents. 4. Standstill Agreement; Right to Cure Senior Loan Default. (a) Until such time as the Senior Indebtedness has been repaid in full and the Senior Security Instrument has been released and discharged and provided that Senior Lender (x) is diligently, continuously and in good faith pursuing its remedies under the Senior Loan Documents and/or a workout of the Senior Loan with Borrower and (y) keeps Junior Lender reasonably apprised of the status of such pursuit and in any event provides status updates to Junior Lender within ten (10) business days after Junior Lender’s written request for same to Senior Lender (the “Standstill Conditions”), Junior Lender shall not without the prior written consent of Senior Lender, which may be withheld in Senior Lender’s sole and absolute discretion, take any Enforcement Action, including, without limitation, (i) accelerate the Junior Loan, (ii) exercise any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Loan Documents (including, without limitation, the commencement of any judicial or non-judicial action or proceeding (a) to enforce any obligation of Borrower under any of the Junior Loan Documents, (b) to collect any monies payable to Borrower, (c) to have a receiver appointed to collect any monies payable to Borrower; or (d) to foreclose the lien(s) created by the Junior Security Instrument) or (iii) file or join in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower; provided, however, that such limitation on the remedies of Junior Lender shall not derogate or otherwise limit Junior Lender’s rights, following an event of default under the Junior Loan Documents to (a) compute interest on all amounts due and payable under the Junior Loan at the Default Interest Rate described in the Junior Loan Documents, (b) compute prepayment premiums and late charges, (c) enforce against any person, other than Borrower and any guarantors or indemnitors under the Senior Loan Documents, any guaranty of the obligations of Borrower under the Junior Loan, and/or (d) exercise and enforce applicable laws, restrictive covenants and agreements relating to income, rent or Subordination and Intercreditor Agreement (City) 11 Vista Breeze affordability restrictions contained in the Junior Loan Documents. Junior Lender agrees not to commence an Enforcement Action for so long as the Senior Lender is complying with the Standstill Conditions; provided, however, if the Senior Lender is not satisfying the Standstill Conditions, the Junior Lender agrees not to commence an Enforcement Action until after ninety (90) days have elapsed since the date of Junior Lender’s written notice to Senior Lender of such failure (such 90-day day period, the “Junior Lender Standstill Period”). The commencement of an Enforcement Action following the expiration of the Junior Lender Standstill Period does not and shall not require Senior Lender’s consent. Notwithstanding anything to the contrary set forth in this Section 4(a) or otherwise in this Agreement, solely in the event an Enforcement Action is brought by Junior Lender as a result of Borrower’s failure to pay the Junior Loan in full on the Maturity Date (as defined in the Junior Note) and not earlier (a “Maturity Date Enforcement Action”) and the terms of this Agreement are then in effect, then Junior Lender shall not commence a Maturity Date Enforcement Action until after ninety (90) days have elapsed since the date of delivery of an Enforcement Action Notice to Senior Lender with respect to such Maturity Date Enforcement Action (such 90-day period, the “Junior Lender Maturity Date Standstill Period”) and Senior Lender elects not to cure such Maturity Date payment default by Borrower within such Junior Lender Maturity Date Standstill Period. The commencement of a Maturity Date Enforcement Action following the expiration of the Junior Lender Maturity Date Standstill Period does not and shall not require Senior Lender’s consent. (b) Senior Lender shall, simultaneously with the sending of any notice of a Senior Loan Default to Borrower, send to Junior Lender a copy of said notice under the Senior Loan Documents; provided, however, failure to do so shall not affect the validity of such notice or any obligation of Borrower to Senior Lender and shall not affect the relative priorities between the Senior Loan and the Junior Loan as set forth herein. Borrower covenants and agrees to forward to Junior Lender, within three (3) business days of Borrower’s receipt thereof, a copy of any notice of a Senior Loan Default Borrower receives from Senior Lender. (c) Junior Lender shall have the right, but shall have no obligation, to cure any Senior Loan Default; provided, if Junior Lender shall elect to cure any such Default, it shall so notify Senior Lender and shall commence and complete such curing within any applicable notice or grace period, if any, as Borrower is permitted by the terms of the Senior Loan Documents to cure such Senior Loan Default. Junior Lender shall not be subrogated to the rights of Senior Lender under the Senior Loan Documents by reason of Junior Lender having cured any Senior Loan Default. However, Senior Lender acknowledges that, to the extent so provided in the Junior Loan Documents, amounts advanced or expended by Junior Lender to cure a Senior Loan Default may be added to and become a part of the Junior Indebtedness. (d) Junior Lender agrees that, notwithstanding any contrary provision contained in the Junior Loan Documents, a Senior Loan Default shall not constitute a default under the Junior Loan Documents if no other default occurred under the Junior Loan Documents. Subordination and Intercreditor Agreement (City) 12 Vista Breeze (e) Junior Lender acknowledges that it will not enter into any deed or assignment in lieu of foreclosure or similar arrangement without the prior written consent of Senior Lender. 5. Insurance. Junior Lender agrees that all original policies of insurance required pursuant to the Senior Security Instrument shall be held by Senior Lender. The preceding sentence shall not preclude Junior Lender from requiring that it be named as a loss payee, as its interest may appear, under all policies of property damage insurance maintained by Borrower with respect to the Property, provided such action does not affect the priority of payment of the proceeds of property damage insurance under the Senior Security Instrument, or that it be named as an additional insured under all policies of liability insurance maintained by Borrower with respect to the Property. 6. Default. Junior Lender and Borrower acknowledge and agree that a default by either such party under this Agreement shall, at the sole option of Senior Lender, constitute a default under the Senior Loan Documents. Each party hereto acknowledges that in the event any party fails to comply with its obligations hereunder, the other parties shall have all rights available at law and in equity, including the right to obtain specific performance of the obligations of such defaulting party and injunctive relief. No failure or delay on the part of any party hereto in exercising any right, power or remedy hereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any such right, power or remedy preclude any other or further exercise thereof or the exercise of any other right, power or remedy hereunder. 7. Enforcement Costs. Borrower agrees to reimburse Senior Lender for any and all costs and expenses (including reasonable attorneys’ fees) incurred by Senior Lender in connection with enforcing its rights against Junior Lender under this Agreement. 8. Notices. Any notice which any party hereto may be required or may desire to give hereunder shall be deemed to have been given and shall be effective only if it is in writing and (i) delivered personally, (ii) mailed, postage prepaid, by United State registered or certified mail, return receipts requested, (iii) delivered by overnight express courier or (iv) sent by telecopier, in each instance addressed as follows: To Junior Lender: With a copy to: City of Miami Beach 1700 Convention Center Drive Miami Beach, Florida 33139 Attention: City Manager City of Miami Beach Office of Housing & Community Services 1700 Convention Center Drive Miami Beach, Florida 33139 Attention: Director Subordination and Intercreditor Agreement (City) 13 Vista Breeze With a copy to: If to Senior Lender: City of Miami Beach 1700 Convention Center Drive Miami Beach, Florida 33139 Attention: Rafael A. Paz, City Attorney Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 With a copy to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 With a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291-5754 or at such other addresses or to the attention of such other persons as may from time to time be designated by the party to be addressed by written notice to the other in the manner herein provided. Notices, demands and requests given in the manner aforesaid shall be deemed sufficiently served or given for all purposes hereunder when received or when delivery is refused or when the same are returned to sender for failure to be called for. 9. WAIVER OF TRIAL BY JURY. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF THE PARTIES HERETO (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS Subordination and Intercreditor Agreement (City) 14 Vista Breeze SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 10. Term. The term of this Agreement shall commence on the date hereof and shall continue until the earliest to occur of the following events: (i) the payment of all of the principal of, interest on and other amounts payable under the Senior Loan Documents; (ii) the payment of all of the principal of, interest on and other amounts payable under the Junior Loan Documents, other than by reason of payments which Junior Lender is obligated to remit to Senior Lender pursuant to the terms hereof; (iii) the acquisition by Senior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Senior Security Instrument; or (iv) the acquisition by Junior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Junior Security Instrument, but only if such acquisition of title does not violate any of the terms of this Agreement. 11. Miscellaneous. (a) Junior Lender shall, within thirty (30) business days following a written request from Senior Lender, provide Senior Lender with a written statement setting forth the then current outstanding principal balance of the Junior Loan, the aggregate accrued and unpaid interest under the Junior Loan, and stating whether, to the actual knowledge of Junior Lender, any default or event of default exists under the Junior Loan, and containing such other factual information with respect to the Junior Indebtedness as Senior Lender may reasonably require. Upon notice from Senior Lender from time to time, Junior Lender shall execute and deliver such additional instruments and documents, and shall take such actions, as are required by Senior Lender in order to further evidence or effectuate the provisions and intent of this Agreement, provided that any such instruments, documents and actions shall be subject to approval by the Senior Lender and Junior Lender, which approval shall not be unreasonably withheld. (b) This Agreement shall bind and inure to the benefit of all successors and assigns of Junior Lender and Senior Lender. Senior Lender may assign its interest in the Senior Loan Documents without notice to or consent of Junior Lender. Except as set forth in Section 3(a) above, Junior Lender may only assign its rights and interests hereunder following the prior written consent of Senior Lender, which consent shall not be unreasonably withheld, conditioned or delayed. (c) Senior Lender hereby consents to the Junior Loan and the Junior Loan Documents; provided, however, that this Agreement does not constitute an approval by Senior Lender of the terms of the Junior Loan Documents. Junior Lender hereby consents to the Senior Loan and the Senior Loan Documents; provided, however, that this Agreement does not constitute an approval by Junior Lender of the terms of the Senior Loan Documents. (d) This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. Subordination and Intercreditor Agreement (City) 15 Vista Breeze (e) IN ALL RESPECTS, INCLUDING, WITHOUT LIMITATION, MATTERS OF CONSTRUCTION AND PERFORMANCE OF THIS AGREEMENT AND THE OBLIGATIONS ARISING HEREUNDER, THIS AGREEMENT HAS BEEN ENTERED INTO AND DELIVERED IN, AND SHALL BE CONSTRUED IN ACCORDANCE WITH AND GOVERNED BY, THE LAWS OF THE STATE WHERE THE PROPERTY IS LOCATED, WITHOUT GIVING EFFECT TO ANY PRINCIPLES OF CONFLICTS OF LAW. (f) Time is of the essence in the performance of every covenant and agreement contained in this Agreement. (g) If any provision or remedy set forth in this Agreement for any reason shall be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provision or remedy of this Agreement and this Agreement shall be construed as if such invalid, illegal or unenforceable provision or remedy had never been set forth herein, but only to the extent of such invalidity, illegality or unenforceability. (h) Each party hereto hereby represents and warrants that this Agreement has been duly authorized, executed and delivered by it and constitutes a legal, valid and binding agreement enforceable in all material respects in accordance with its terms. (i) Borrower hereby acknowledges and consents to the execution of this Agreement and agrees to be bound by the provisions hereof that are applicable to Borrower. Solely as between Senior Lender and Junior Lender, all of the signatories below hereby agree that to the extent of any conflict between the terms and provisions of this Agreement and the terms and provisions of the Senior Loan Documents and/or the Junior Loan Documents respectively, the terms and provisions of this Agreement shall govern and control. By executing this Agreement in the place provided below, Borrower hereby (i) acknowledges the provisions hereof, (ii) agrees not to take any action inconsistent with Senior Lender’s rights or Junior Lender’s rights under this Agreement, (iii) waives and relinquishes to the maximum extent permitted by law any and all rights, defenses and claims now existing or hereinafter accruing relating to Junior Lender’s forbearance from exercising any rights and remedies pursuant to Section 4 of this Agreement, including, without limitation, any defenses based on the statute of limitations or any equitable defenses, such as laches, and (iv) acknowledges and agrees that (A) this Agreement is entered into for the sole protection and benefit of Senior Lender and Junior Lender (and their respective successors, assigns and participants), and no other person (including Borrower) shall have any benefits, rights or remedies under or by reason of this Agreement, (B) nothing in this Agreement is intended, or shall be construed to, relieve or discharge the obligations or liabilities of any third party (including Borrower under the Senior Loan Documents and the Junior Loan Documents), (C) neither of them nor any of their affiliates shall be, or be deemed to be, beneficiaries of any of the provisions hereof or have any rights hereunder whatsoever, and (D) no provision of this Agreement is intended to, or shall be construed to, give any such third party (including Borrower) any right subrogating to the rights of, or action against, Senior Lender or Junior Lender. Subordination and Intercreditor Agreement (City) 16 Vista Breeze (j) No amendment, supplement, modification, waiver or termination of this Agreement shall be effective against any party unless such amendment, supplement, modification, waiver or termination is contained in a writing signed by such party. (k) No party other than Senior Lender and Junior Lender shall have any rights under, or be deemed a beneficiary of any of the provisions of, this Agreement. (l) Nothing herein or in any of the Senior Loan Documents or Junior Loan Documents shall be deemed to constitute Senior Lender as a joint venturer or partner of Junior Lender. 12. Intentionally Omitted. 13. Attached Exhibits. The following Exhibits are attached to this Agreement and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Legal Description Exhibit B – Junior Loan Documents Exhibit C – Modifications to Subordination and Intercreditor Agreement The terms of this Agreement are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Agreement, the terms of said Exhibits shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Subordination and Intercreditor Agreement (City) A-1 Vista Breeze IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Subordination and Intercreditor Agreement or caused this Subordination and Intercreditor Agreement to be duly executed and delivered by their respective authorized representatives as of the date first set forth above. JUNIOR LENDER: WITNESS OR ATTEST: CITY OF MIAMI BEACH, FLORIDA, a political subdivision of the State of Florida ________________________________ Name: __________________________ By:_______________________________ Name: Title: ________________________________ Name: __________________________ STATE OF ________ COUNTY OF _______ The foregoing instrument was acknowledged before me by means of [ ] physical presence or [ ] online notarization this __ day of _______, 20__, by _____________________, as ____________________________ of the City of Miami Beach, Florida, a political subdivision of the State of Florida. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (City) 2 Vista Breeze SENIOR LENDER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ CITIBANK, N.A., By: ___________ Name: Title: Deal ID No. 60001596 ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ________________, as ________________ of Citibank., N.A. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (City) 3 Vista Breeze ACKNOWLEDGED AND AGREED AS OF THE DATE FIRST SET FORTH ABOVE: BORROWER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: Name: Title: ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ___________________, as ___________ of APC Vista Breeze, LLC, a Florida limited liability company, a duly authorized signatory of Vista Breeze, Ltd., a Florida limited partnership. Said person is personally known to me or has produced a valid driver's license as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (City) A-1 Vista Breeze EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. Subordination and Intercreditor Agreement (City) C-1 Vista Breeze EXHIBIT B JUNIOR LOAN DOCUMENTS 1. Junior Note; 2. Junior Security Instrument; 3. Junior Loan Agreement; 4. Junior Declaration; and 5. UCC-1 Financing Statement made by Borrower, as debtor, and Junior Lender, as secured party and filed with the Secretary of State of the State of Florida. Subordination and Intercreditor Agreement (City) 2 Vista Breeze EXHIBIT C MODIFICATIONS TO SUBORDINATION AND INTERCREDITOR AGREEMENT The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. 4892-6776-9486, v. 9 D Forward Purchase Agreement Vista Breeze EXHIBIT D-13 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT (COUNTY) [See attached] 4891-9288-4364v.4 THIS INSTRUMENT PREPARED BY: Aviva Yakren, Esq. Sidley Austin LLP 787 Seventh Avenue New York, New York 10019 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: Citibank, N.A. Transaction and Asset Management Group/Post Closing Citi Community Capital 3800 Citibank Center Tampa, Florida 33610 Re: Vista Breeze Deal ID No. 60001596 ABOVE SPACE RESERVED FOR RECORDING PURPOSES ONLY EXHIBIT D-13 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT Subordination and Intercreditor Agreement (County) Vista Breeze 4891-9288-4364v.4 EXHIBIT D-13 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT THIS SUBORDINATION AND INTERCREDITOR AGREEMENT (this “Agreement”) dated as of the [_] day of [Month], 202[_], is made by and between MIAMI-DADE COUNTY, FLORIDA, a political subdivision of the State of Florida (“Junior Lender”) and CITIBANK, N.A., a national banking association (“Senior Lender”) and acknowledged by VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Conversion Date (as defined in the Original Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, Subordination and Intercreditor Agreement (County) 2 Vista Breeze 4891-9288-4364v.4 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Senior Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Senior Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, the Borrower Loan has converted into a permanent loan (the “Senior Loan”), and in connection therewith, (i) Senior Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement, dated as of the date hereof (the “Funding Loan Agreement”), by and among Governmental Lender, Fiscal Agent, and Senior Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement, dated as of the date hereof (the “Borrower Loan Agreement”), which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [_], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) executed and delivered by Borrower and dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Senior Lender and Borrower have entered into a certain the Loan Covenant Agreement executed and delivered by Borrower and dated as of the date hereof (the “Loan Covenant Agreement”). I. Junior Lender is making a loan (the “Junior Loan”) to Borrower in the original principal amount of $5,950,000, which Junior Loan is evidenced by a certain note dated as of the date hereof made by Borrower to Junior Lender (the “Junior Note”) and secured by, the Junior Security Instrument (as hereinafter defined) encumbering the Property, and will be advanced to Borrower pursuant to that certain Loan Agreement (Surtax Loan) (the “Junior Loan Agreement”), dated as of December 15, 2023, between Borrower and Junior Lender. J. As a condition to the making of the Senior Loan, Senior Lender requires that Junior Lender execute and deliver this Agreement prior to the making of the Junior Loan and the granting of the Junior Security Instrument by Borrower. NOW, THEREFORE, for Ten Dollars ($10.00) and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, and to induce the making of the Senior Loan and to induce Senior Lender to consent to the Junior Loan and the Junior Security Instrument, Junior Lender hereby agrees as follows: Subordination and Intercreditor Agreement (County) 3 Vista Breeze 4891-9288-4364v.4 1. Definitions. Capitalized terms used but not defined in this Agreement shall have the meanings ascribed thereto in the Senior Security Instrument. As used in this Agreement, the terms set forth below shall have the respective meanings indicated: “Bankruptcy Proceeding” means any bankruptcy, reorganization, insolvency, composition, restructuring, dissolution, liquidation, receivership, assignment for the benefit of creditors, or custodianship action or proceeding under any federal or state law with respect to Borrower, any guarantor of any of the Senior Indebtedness, any of their respective properties, or any of their respective partners, members, officers, directors, or shareholders. “Casualty” means the occurrence of damage to or loss of any of the Property by fire or other casualty. “Condemnation” means any proposed or actual condemnation or other taking, or conveyance in lieu thereof, of all or any part of the Property, whether direct or indirect. “Enforcement Action” means any exercise of any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Loan Documents, including, without limitation, any of the following: (i) the acceleration of all or any part of the Junior Indebtedness, (ii) the commencement of any judicial or non-judicial action or proceeding to enforce any obligation of Borrower under any of the Junior Loan Documents, collect any monies payable to Borrower or have a receiver appointed to collect any monies payable to Borrower, or foreclose the lien(s) created by the Junior Security Instrument, (iii) the filing or joining in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower, (iv) the advertising of or commencement of any foreclosure or trustee’s sale proceedings, (v) the exercise of any power of sale, (vi) the acceptance of a deed or assignment in lieu of foreclosure or sale, (vii) the collecting of Rents, (viii) the obtaining of or seeking of the appointment of a receiver, (ix) the seeking of default interest, (x) the taking of possession or control of any of the Property, (xi) the commencement of any suit or other legal, administrative, or arbitration proceeding based upon the Junior Note or any other of the Junior Loan Documents, (xii) the exercising of any banker’s lien or rights of set-off or recoupment, or (xiii) the taking of any other enforcement action against Borrower, any other party liable for any of the Junior Indebtedness or obligated under any of the Junior Loan Documents, or the Property. “Enforcement Action Notice” means a written notice from Junior Lender to Senior Lender, given following a Junior Loan Default and the expiration of any notice or cure periods provided for such Junior Loan Default in the Junior Loan Documents, setting forth in reasonable detail the Enforcement Action proposed to be taken by Junior Lender. “Junior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Junior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. “Junior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Junior Security Instrument. Subordination and Intercreditor Agreement (County) 4 Vista Breeze 4891-9288-4364v.4 “Junior Loan Documents” means, collectively, the Junior Note, the Junior Security Instrument, the Junior Loan Agreement, that certain Miami-Dade County Rental Regulatory Agreement, dated as of December 15, 2023, by Borrower in favor of Junior Lender, and all other documents evidencing, securing or delivered in connection with the Junior Loan, all of which are listed on Exhibit B attached hereto, together with such modifications, amendments and supplements thereto as are approved in writing by Senior Lender prior to their execution. “Junior Security Instrument” means, collectively, that certain (i) Leasehold Mortgage and Security Agreement and Assignment of Leases, Rents and Profits, dated as of December 15, 2023, made by Borrower for the benefit of Junior Lender, and (ii) that certain Collateral Assignment of Leases, Rents and Contract Rights, dated as of December 15, 2023, made by Borrower for the benefit of Junior Lender, as the same may from time to time be extended, consolidated, substituted for, modified, amended or supplemented upon receipt of the consent of Senior Lender. “Loan Agreement” means the Loan Covenant Agreement. “Loss Proceeds” means all monies received or to be received under any insurance policy, from any condemning authority, or from any other source, as a result of any Condemnation or Casualty. “Property” means (i) the land and improvements known or to be known as Vista Breeze, located in the City of Miami Beach, Miami-Dade County, State of Florida, which Property is more particularly described on Exhibit A attached hereto, and (ii) all furniture, fixtures and equipment located at such apartments and other property, accounts, deposits and rights and interests of Borrower encumbered by the Senior Security Instrument and/or the other Senior Loan Documents. “Senior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Senior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. “Senior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Senior Security Instrument. “Senior Loan Documents” means, collectively, the Senior Security Instrument, the Senior Note, the Borrower Loan Agreement and all of the other documents, instruments and agreements now or hereafter evidencing, securing or otherwise executed in connection with the Senior Loan, as the same may from time to time be extended, consolidated, substituted for, modified, increased, amended and supplemented in accordance with the provisions of this Agreement. 2. Junior Loan and Junior Loan Documents are Subordinate; Acts by Senior Lender do not Affect Subordination. (a) Junior Lender hereby covenants and agrees on behalf of itself and its successors and permitted assigns that the Junior Indebtedness is and shall at all times continue to be, subordinate, subject and inferior (in payment and priority) to the prior payment in full of the Senior Indebtedness, and that the liens, rights, payment interests, priority interests and security interests granted to Junior Lender in connection with the Subordination and Intercreditor Agreement (County) 5 Vista Breeze 4891-9288-4364v.4 Junior Loan and under the Junior Loan Documents are, and are hereby expressly acknowledged to be in all respects and at all times, subject, subordinate and inferior in all respects to the liens, rights, payment, priority and security interests granted to Senior Lender under the Senior Loan and the Senior Loan Documents and the terms, covenants, conditions, operations and effects thereof. (b) Except as expressly set forth herein, repayment of the Junior Indebtedness, is and shall be postponed and subordinated to repayment in full of the Senior Loan. Prior to a Senior Loan Default (regardless of whether such Senior Loan Default occurs prior to or during the pendency of a Bankruptcy Proceeding), Junior Lender shall be entitled to receive and retain payments made pursuant to and in accordance with the terms of the Junior Loan Documents; provided, however, that no such payment is made more than ten (10) days in advance of the due date thereof. Junior Lender agrees that from and after such time as it has received from either Senior Lender or Borrower written notice that a Senior Loan Default then exists (which has not been expressly waived in writing by Senior Lender) of such a Senior Loan Default, Junior Lender shall not receive or accept any payments under the Junior Loan. If (i) Junior Lender receives any payment, property, or asset of any kind or in any form on account of the Junior Indebtedness (including, without limitation, any proceeds from any Enforcement Action) after a Senior Loan Default of which Junior Lender has been given notice of, or (ii) Junior Lender receives, voluntarily or involuntarily, by operation of law or otherwise, any payment, property, or asset in or in connection with any Bankruptcy Proceeding, such payment, property, or asset will be received and held in trust for Senior Lender. Junior Lender will promptly remit, in kind and properly endorsed as necessary, all such payments, properties, and assets to Senior Lender. Senior Lender shall apply any payment, asset, or property so received from Junior Lender to the Senior Indebtedness in such order, amount (with respect to any asset or property other than immediately available funds), and manner as Senior Lender shall determine in its sole and absolute discretion. (c) Without limiting the complete subordination of the Junior Indebtedness to the payment in full of the Senior Indebtedness, in any Bankruptcy Proceeding, upon any payment or distribution (whether in cash, property, securities, or otherwise) to creditors (i) the Senior Indebtedness shall first be paid in full in cash before Junior Lender shall be entitled to receive any payment or other distribution on account of or in respect of the Junior Indebtedness, and (ii) until all of the Senior Indebtedness is paid in full in cash, any payment or distribution to which Junior Lender would be entitled but for this Agreement (whether in cash, property, or other assets) shall be made to Senior Lender. (d) The subordination of the Junior Indebtedness shall continue in the event that any payment under the Senior Loan Documents (whether by or on behalf of Borrower, as proceeds of security or enforcement of any right of set-off or otherwise) is for any reason repaid or returned to Borrower or its insolvent estate, or avoided, set aside or required to be paid to Borrower, a trustee, receiver or other similar party under any bankruptcy, insolvency, receivership or similar law. In such event, the Senior Indebtedness or part thereof originally intended to be satisfied shall be deemed to be reinstated and outstanding to the extent of any repayment, return, or other action, as if such payment on account of the Senior Indebtedness had not been made. Subordination and Intercreditor Agreement (County) 6 Vista Breeze 4891-9288-4364v.4 (e) The subordination of the Junior Loan Documents and of the Junior Indebtedness shall apply and continue notwithstanding (i) the actual date and time of execution, delivery, recording, filing or perfection of the Senior Security Instrument and other Senior Loan Documents and of the Junior Security Instrument and other Junior Loan Documents, and (ii) the availability of any collateral to Senior Lender, including the availability of any collateral other than the Property. (f) By reason of, and without in any way limiting, the full subordination of the Junior Indebtedness and the Junior Loan Documents provided for in this Agreement, all rights and claims of Junior Lender under the Junior Security Instrument or under the Junior Loan Documents in or to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto, are expressly subject and subordinate in all respects to the rights and claims of Senior Lender under the Senior Loan Documents in and to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto. (g) If Junior Lender, in its capacity as lender, by indemnification, subrogation or otherwise, shall acquire any lien, estate, right or other interest in any of the Property, that lien, estate, right or other interest shall be fully subject and subordinate to the receipt by Senior Lender of payment in full of the Senior Indebtedness, and to the Senior Loan Documents, to the same extent as the Junior Indebtedness and the Junior Loan Documents are subordinate pursuant to this Agreement. (h) In confirmation, and not as a condition, of the subordination of the Junior Indebtedness and the Junior Loan Documents provided for in this Agreement, Junior Lender shall place on or attach to the Junior Note a notice to the following effect, and shall provide Senior Lender with a copy of the Junior Note showing such notice: “The indebtedness evidenced by this Note is and shall be subordinate in right of payment to the prior payment in full of all amounts then due and payable (including, but not limited to, all amounts due and payable by virtue of any default or acceleration or upon maturity) with respect to the indebtedness evidenced by the Note (as defined by that certain Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) by the Borrower in favor of Governmental Lender and assigned to The Bank of New York Mellon Trust Company, N.A., a national banking association, in the original maximum principal amount of $[11,875,000] [NOTE: AS MAY BE INCREASED PER THE EARN-OUT]) to the extent and in the manner provided in that certain Subordination and Intercreditor Agreement, dated as of [_____], 20[_], between Citibank, N.A. (“Senior Lender”) and the holder of this Note (the “Subordination Agreement”). The rights and remedies of the payee and each subsequent holder of this Note shall be deemed, by virtue of such holder’s acquisition of this Note, to have agreed to perform and observe all of the terms, covenants and conditions to be Subordination and Intercreditor Agreement (County) 7 Vista Breeze 4891-9288-4364v.4 performed or observed by the “Junior Lender” under the Subordination Agreement.” (i) Junior Lender hereby acknowledges and agrees that Senior Lender may, without the consent or approval of Junior Lender, agree with Borrower to extend, consolidate, modify, or amend any or all the Senior Loan Documents and otherwise act or fail to act with respect to any matter set forth in any Senior Loan Document (including, without limitation, the exercise of any rights or remedies, waiver, forbearance or delay in enforcing any rights or remedies, the declaration of acceleration, the declaration of defaults or events of default, the release, in whole or in part, of any collateral or other property, and any consent, approval or waiver), and all such extensions, consolidations, modifications, amendments acts and omissions shall not release, impair or otherwise affect Junior Lender’s obligations and agreements hereunder. Notwithstanding the prior sentence, the Senior Lender shall not modify or amend any or all of the Senior Loan Documents to increase the Senior Indebtedness without the prior written consent of the Junior Lender. 3. Junior Lender Agreements. (a) Without the prior written consent of Senior Lender in each instance, Junior Lender shall not (i) amend, modify, waive, extend, renew or replace any provision of any of the Junior Loan Documents, or (ii) pledge, assign, transfer, convey, or sell any interest in the Junior Indebtedness or any of the Junior Loan Documents unless the transferee is a governmental entity, quasi-governmental entity, or a nonprofit entity created and controlled by Miami-Dade County, and Senior Lender is given 30 days’ prior written notice of any such transfer and acknowledgment by transferee that the loan remains subject to this Agreement, and provided that in no event may any such pledge, assignment, transfer, conveyance or sale be to Borrower or its affiliates; or (iii) accept any payment on account of the Junior Indebtedness other than a regularly scheduled payment of interest or principal and interest made not earlier than ten (10) days prior to the due date thereof; or (iv) take any action which has the effect of increasing the Junior Indebtedness. Without giving prior notice to Senior Lender in each instance, Junior Lender, in its capacity as lender, shall not appear in, defend or bring any action in connection with the Property or take any action concerning environmental matters affecting the Property. Regardless of any contrary provision in the Junior Loan Documents, Junior Lender shall not collect payments for the purpose of escrowing for any cost or expense related to the Property or for any portion of the Junior Indebtedness. (b) Junior Lender hereby agrees that Senior Lender may, at its option (but without any obligation to do so), at any time (including during the pendency of a Bankruptcy Proceeding), purchase the Junior Loan at par (and without liability for any prepayment premiums or liquidated damages set forth in the Junior Loan Documents). Such transfer and assignment of the Junior Loan shall be without representation or recourse, except that Junior Lender shall represent that it is the sole holder of the Junior Loan, that it has authority to assign and convey the Junior Loan Documents, that, to the best of its knowledge, there are no defaults or breaches under the Junior Loan Documents, and as to the total amount then outstanding under the Junior Loan. Junior Lender shall give Senior Lender a concurrent copy of each notice of a Junior Loan Default, Enforcement Subordination and Intercreditor Agreement (County) 8 Vista Breeze 4891-9288-4364v.4 Action Notice or other material notice given by Junior Lender under the Junior Loan Documents. Notwithstanding any contrary provision in the Junior Loan Documents, Senior Lender shall have the right, but shall not have any obligation, to cure any Junior Loan Default until ninety (90) days following Senior Lender’s receipt of an Enforcement Action Notice given by Junior Lender as a consequence of the Junior Loan Default. Senior Lender shall not be subrogated to the rights of Junior Lender under the Junior Loan Documents by reason of Senior Lender having cured any Junior Loan Default. However, Junior Lender acknowledges that all amounts advanced or expended by Senior Lender to cure a Junior Loan Default shall be added to and become a part of the Senior Indebtedness pursuant to the terms of the Senior Security Instrument. (c) In the event and to the extent that each of Senior Lender and Junior Lender have under their respective loan documents certain approval or consent rights over the same subject matters (regardless of whether the obligations or rights are identical or substantially identical), Junior Lender agrees that Senior Lender shall exercise such approval rights on behalf of both Senior Lender and Junior Lender, and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby. Without limiting the generality of the foregoing, Senior Lender shall have all approval, consent and oversight rights in connection with any insurance claims relating to the Property, any decisions regarding the use of insurance proceeds after a casualty loss or condemnation awards, the hiring or firing of property managers, or otherwise related in any way to the Property, and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby. (d) Junior Lender agrees that in any action commenced to enforce the obligation of Borrower to pay any portion of the Junior Indebtedness, the judgment shall not be enforceable personally against Borrower or Borrower’s assets, and the recourse of Junior Lender for the collection of the Junior Indebtedness shall be limited to actions against the Property and the rents, profits, issues, products, and income from the Property. (e) Junior Lender shall not commence or join with any other creditor in commencing any Bankruptcy Proceeding involving Borrower, and Junior Lender shall not initiate and shall not be a party to any action, motion or request, in a Bankruptcy Proceeding involving any other person or entity, which seeks the consolidation of some or all of the assets of Borrower into such Bankruptcy Proceeding. In the event of any Bankruptcy Proceeding relating to Borrower or the Property or, in the event of any Bankruptcy Proceeding relating to any other person or entity into which (notwithstanding the covenant in the first sentence of this clause) the assets or interests of Borrower are consolidated, then in either event, the Senior Loan shall first be paid in full before Junior Lender shall be entitled to receive and retain any payment or distribution in respect to the Junior Loan. Junior Lender agrees that (i) Senior Lender shall receive all payments and distributions of every kind or character in respect of the Junior Loan to which Junior Lender would otherwise be entitled, but for the subordination provisions of this Agreement (including without limitation, any payments or distributions during the pendency of a Bankruptcy Proceeding involving Borrower or the Property), and (ii) the subordination of the Junior Loan and the Junior Loan Documents shall not be affected in any way by Senior Lender Subordination and Intercreditor Agreement (County) 9 Vista Breeze 4891-9288-4364v.4 electing, under Section 1111(b) of the federal bankruptcy code, to have its claim treated as being a fully secured claim. In addition, Junior Lender hereby covenants and agrees that, in connection with a Bankruptcy Proceeding involving Borrower, neither Junior Lender nor any of its affiliates shall (i) make or participate in a loan facility to or for the benefit of Borrower on a basis that is senior to or pari passu with the liens and interests held by Senior Lender pursuant to the Senior Loan Documents, (ii) not vote affirmatively in favor of any plan of reorganization or liquidation unless Senior Lender has also voted affirmatively in favor of such plan, and (iii) not contest the continued accrual of interest on the Senior Indebtedness, in accordance with and at the rates specified in the Senior Loan Documents, both for periods before and for periods after the commencement of such Bankruptcy Proceedings. Junior Lender shall execute and deliver to Senior Lender powers of attorney, assignments or other instruments, as may be requested by Senior Lender in order to enable it to exercise the above-described authority or powers with respect to any or all of the Junior Loan Documents, and to collect and receive any and all payments or distributions which may be payable or deliverable at any time upon or with respect to any of the Junior Loan Documents to Junior Lender. (f) Junior Lender covenants and agrees that the effectiveness of this Agreement and the rights of Senior Lender hereunder shall be in no way impaired, affected, diminished or released by any renewal or extension of the time of payment of the Senior Loan, by any delay, forbearance, failure, neglect or refusal of Senior Lender in enforcing payment thereof or in enforcing the lien of or attempting to realize upon the Senior Loan Documents or any other security which may have been given or may hereafter be given for the Senior Loan, by any waiver or failure to exercise any right or remedy under the Senior Loan Documents, or by any other act or failure to act by Senior Lender. Junior Lender acknowledges that Senior Lender, at its sole option, may release all or any portion of the Property from the lien of the Senior Security Instrument, and may release or waive any guaranty, surety or indemnity providing additional collateral to Senior Lender, and Junior Lender hereby waives any legal or equitable right in respect of marshaling it might have, in connection with any release of all or any portion of the Property by Senior Lender, to require the separate sales of any portion of the Property or to require Senior Lender to exhaust its remedies against any portion of the Property or any other collateral before proceeding against any other portion of the Property or other collateral (including guarantees) for the Senior Loan. Senior Lender may pursue all rights and remedies available to it under the Senior Loan Documents, at law, or in equity, regardless of any Enforcement Action Notice or Enforcement Action by Junior Lender. At any time or from time to time and any number of times, without notice to Junior Lender and without affecting the liability of Junior Lender, (a) the time for payment of the Senior Indebtedness may be extended or the Senior Indebtedness may be renewed in whole or in part; (b) the time for Borrower’s performance of or compliance with any covenant or agreement contained in the Senior Loan Documents, whether presently existing or hereinafter entered into, may be extended or such performance or compliance may be waived; (c) the maturity of the Senior Indebtedness may be accelerated as provided in the Senior Loan Documents; (d) any Senior Loan Document may be extended, consolidated, modified or amended by Senior Lender and Borrower in any respect, including, but not limited to, an increase in the principal amount; and (e) any security for the Senior Indebtedness may be modified, exchanged, surrendered or otherwise dealt with or additional security may be pledged or mortgaged Subordination and Intercreditor Agreement (County) 10 Vista Breeze 4891-9288-4364v.4 for the Senior Indebtedness. If, after the occurrence of a Senior Loan Default, Senior Lender acquires title to any of the Property pursuant to a mortgage foreclosure conducted in accordance with applicable law, the lien, operation, and effect of the Junior Security Instrument and other Junior Loan Documents automatically shall terminate with respect to such Property upon Senior Lender’s acquisition of title. (g) Junior Lender acknowledges that it entered into the transactions contemplated by the Junior Loan Documents and made the Junior Loan to Borrower without reliance upon any information or advice from Senior Lender. Junior Lender made its own underwriting analysis in connection with the Junior Loan, its own credit review of Borrower, and investigated all matters pertinent, in Junior Lender’s judgment, to its determination to make the Junior Loan to Borrower. Junior Lender acknowledges that it is a sophisticated, experienced commercial lender, and was represented by competent counsel in connection with this Agreement. (h) Junior Lender hereby represents and warrants that, as of the date hereof, the entire proceeds of the Junior Loan have been disbursed to Borrower. Junior Lender hereby further represents and warrants that: (i) Junior Lender is now the owner and holder of the Junior Loan Documents; (ii) the Junior Loan Documents are now in full force and effect; (iii) the Junior Loan Documents have not been modified or amended; (iv) no default or event which, with the passing of time or giving of notice would constitute a default, under the Junior Loan Documents has occurred; (v) the current outstanding principal balance of the Junior Indebtedness is $[_]; (vi) no scheduled monthly payments under the Junior Loan Documents have been or will be prepaid except with the prior written consent of Senior Lender; (vii) none of the rights of Junior Lender under any of the Junior Loan Documents are subject to the rights of any third parties, by way of subrogation, indemnification or otherwise; and (viii) there are no other Junior Loan Documents other than those listed on Exhibit B hereto. Borrower further represents and warrants that it has provided to Senior Lender a true, complete, and correct copy of all the Junior Loan Documents. 4. Standstill Agreement; Right to Cure Senior Loan Default. (a) Until such time as any of the Senior Indebtedness has been repaid in full and the Senior Security Instrument has been released and discharged, Junior Lender shall not without sixty (60) days’ prior written notice to Senior Lender, take any Enforcement Action, including, without limitation, (i) accelerate the Junior Loan, (ii) exercise any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Loan Documents (including, without limitation, the commencement of any judicial or non- judicial action or proceeding (a) to enforce any obligation of Borrower under any of the Junior Loan Documents, (b) to collect any monies payable to Borrower, (c) to have a receiver appointed to collect any monies payable to Borrower; or (d) to foreclose the lien(s) created by the Junior Security Instrument) or (iii) file or join in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower; provided, however, that such limitation on the remedies of Junior Lender shall not derogate or otherwise limit Junior Lender’s rights, following an event of default under the Junior Loan Documents to (a) compute interest on all amounts due and payable under the Junior Loan at the default rate described in the Junior Loan Subordination and Intercreditor Agreement (County) 11 Vista Breeze 4891-9288-4364v.4 Documents, (b) compute prepayment premiums and late charges, and (c) enforce against any person, other than Borrower and any guarantors or indemnitors under the Senior Loan Documents, any guaranty of the obligations of Borrower under the Junior Loan. (b) Senior Lender shall, simultaneously with the sending of any notice of a Senior Loan Default to Borrower, send to Junior Lender a copy of said notice under the Senior Loan Documents; provided, however, failure to do so shall not affect the validity of such notice or any obligation of Borrower to Senior Lender and shall not affect the relative priorities between the Senior Loan and the Junior Loan as set forth herein. Borrower covenants and agrees to forward to Junior Lender, within three (3) business days of Borrower’s receipt thereof, a copy of any notice of a Senior Loan Default Borrower receives from Senior Lender. (c) Junior Lender shall have the right, but shall have no obligation, to cure any Senior Loan Default; provided, if Junior Lender shall elect to cure any such Default, it shall so notify Senior Lender and shall commence and complete such curing within any applicable notice or grace period, if any, as Borrower is permitted by the terms of the Senior Loan Documents to cure such Senior Loan Default. Junior Lender shall not be subrogated to the rights of Senior Lender under the Senior Loan Documents by reason of Junior Lender having cured any Senior Loan Default. However, Senior Lender acknowledges that, to the extent so provided in the Junior Loan Documents, amounts advanced or expended by Junior Lender to cure a Senior Loan Default may be added to and become a part of the Junior Indebtedness. (d) Junior Lender agrees that, notwithstanding any contrary provision contained in the Junior Loan Documents, a Senior Loan Default shall not constitute a default under the Junior Loan Documents if no other default occurred under the Junior Loan Documents. (e) Junior Lender acknowledges that any conveyance or other transfer of title to the Property pursuant to a foreclosure of the Junior Security Instrument (including a conveyance or other transfer of title pursuant to the exercise of a power of sale contained in the Junior Security Instrument), or any deed or assignment in lieu of foreclosure or similar arrangement, shall be subject to the transfer provisions of the Senior Loan Documents; and the person (including Junior Lender) who acquires title to the Property pursuant to the foreclosure proceeding (or pursuant to the exercise of a power of sale contained in the Junior Security Instrument) shall not be deemed to be automatically approved by Senior Lender. 5. Insurance. Junior Lender agrees that all original policies of insurance required pursuant to the Senior Security Instrument shall be held by Senior Lender. The preceding sentence shall not preclude Junior Lender from requiring that it be named as a loss payee, as its interest may appear, under all policies of property damage insurance maintained by Borrower with respect to the Property, provided such action does not affect the priority of payment of the proceeds of property damage insurance under the Senior Security Instrument, or that it be named as an additional insured under all policies of liability insurance maintained by Borrower with respect to the Property. Subordination and Intercreditor Agreement (County) 12 Vista Breeze 4891-9288-4364v.4 6. Default. Junior Lender and Borrower acknowledge and agree that a default by either such party under this Agreement shall, at the sole option of Senior Lender, constitute a default under the Senior Loan Documents. Each party hereto acknowledges that in the event any party fails to comply with its obligations hereunder, the other parties shall have all rights available at law and in equity, including the right to obtain specific performance of the obligations of such defaulting party and injunctive relief. No failure or delay on the part of any party hereto in exercising any right, power or remedy hereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any such right, power or remedy preclude any other or further exercise thereof or the exercise of any other right, power or remedy hereunder. 7. Enforcement Costs. Borrower and Junior Lender agree to reimburse Senior Lender for any and all costs and expenses (including reasonable attorneys’ fees) incurred by Senior Lender in connection with enforcing its rights against Junior Lender under this Agreement. 8. Notices. Any notice which any party hereto may be required or may desire to give hereunder shall be deemed to have been given and shall be effective only if it is in writing and (i) delivered personally, (ii) mailed, postage prepaid, by United State registered or certified mail, return receipts requested, (iii) delivered by overnight express courier or (iv) sent by telecopier, in each instance addressed as follows: To Junior Lender: With copies to: Miami-Dade County 111 N. W. 1st Street, 29th Floor Miami, Florida 33128 Attention: County Mayor Miami-Dade County Public Housing and Community Development 701 N.W. 1st Court, 16th Floor Miami, Florida 33136 Attention: Director Assistant County Attorney County Attorney's Office 111 N. W. 1st Street, Suite 2810 Miami, Florida 33128 Attn: Shannon D. Summerset-Williams, Esq. If to Senior Lender: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 Subordination and Intercreditor Agreement (County) 13 Vista Breeze 4891-9288-4364v.4 With a copy to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 With a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291-5754 or at such other addresses or to the attention of such other persons as may from time to time be designated by the party to be addressed by written notice to the other in the manner herein provided. Notices, demands and requests given in the manner aforesaid shall be deemed sufficiently served or given for all purposes hereunder when received or when delivery is refused or when the same are returned to sender for failure to be called for. 9. WAIVER OF TRIAL BY JURY. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF THE PARTIES HERETO (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 10. Term. The term of this Agreement shall commence on the date hereof and shall continue until the earliest to occur of the following events: (i) the payment of all of the principal of, interest on and other amounts payable under the Senior Loan Documents; (ii) the payment of all of the principal of, interest on and other amounts payable under the Junior Loan Documents, other than by reason of payments which Junior Lender is obligated to remit to Senior Lender pursuant to the terms hereof; (iii) the acquisition by Senior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Senior Security Instrument; or (iv) the acquisition by Junior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale Subordination and Intercreditor Agreement (County) 14 Vista Breeze 4891-9288-4364v.4 contained in) the Junior Security Instrument, but only if such acquisition of title does not violate any of the terms of this Agreement. 11. Miscellaneous. (a) Junior Lender shall, within ten (10) business days following a request from Senior Lender, provide Senior Lender with a written statement setting forth the then current outstanding principal balance of the Junior Loan, the aggregate accrued and unpaid interest under the Junior Loan, and stating whether, to the knowledge of Junior Lender, any default or event of default exists under the Junior Loan, and containing such other information with respect to the Junior Indebtedness as Senior Lender may require. Upon notice from Senior Lender from time to time, Junior Lender shall execute and deliver such additional instruments and documents, and shall take such actions, as are required by Senior Lender in order to further evidence or effectuate the provisions and intent of this Agreement. (b) This Agreement shall bind and inure to the benefit of all successors and assigns of Junior Lender and Senior Lender. Senior Lender may assign its interest in the Senior Loan Documents without notice to or consent of Junior Lender. Junior Lender may only assign its rights and interests hereunder following the prior written consent of Senior Lender, which consent, to the extent that any such assignment is in favor of a governmental or quasi-governmental entity, agency or authority, shall not be unreasonably withheld, but which may otherwise be withheld or conditioned in the sole and absolute discretion of Senior Lender. (c) Senior Lender hereby consents to the Junior Loan and the Junior Loan Documents; provided, however, that this Agreement does not constitute an approval by Senior Lender of the terms of the Junior Loan Documents. Junior Lender hereby consents to the Senior Loan and the Senior Loan Documents; provided, however, that this Agreement does not constitute an approval by Junior Lender of the terms of the Senior Loan Documents. (d) This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. (e) IN ALL RESPECTS, INCLUDING, WITHOUT LIMITATION, MATTERS OF CONSTRUCTION AND PERFORMANCE OF THIS AGREEMENT AND THE OBLIGATIONS ARISING HEREUNDER, THIS AGREEMENT HAS BEEN ENTERED INTO AND DELIVERED IN, AND SHALL BE CONSTRUED IN ACCORDANCE WITH AND GOVERNED BY, THE LAWS OF THE STATE WHERE THE PROPERTY IS LOCATED, WITHOUT GIVING EFFECT TO ANY PRINCIPLES OF CONFLICTS OF LAW. (f) Time is of the essence in the performance of every covenant and agreement contained in this Agreement. (g) If any provision or remedy set forth in this Agreement for any reason shall be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or Subordination and Intercreditor Agreement (County) 15 Vista Breeze 4891-9288-4364v.4 unenforceability shall not affect any other provision or remedy of this Agreement and this Agreement shall be construed as if such invalid, illegal or unenforceable provision or remedy had never been set forth herein, but only to the extent of such invalidity, illegality or unenforceability. (h) Each party hereto hereby represents and warrants that this Agreement has been duly authorized, executed and delivered by it and constitutes a legal, valid and binding agreement enforceable in all material respects in accordance with its terms. (i) Borrower hereby acknowledges and consents to the execution of this Agreement, and agrees to be bound by the provisions hereof that are applicable to Borrower. Solely as between Senior Lender and Junior Lender, all of the signatories below hereby agree that to the extent of any conflict between the terms and provisions of this Agreement and the terms and provisions of the Senior Loan Documents and/or the Junior Loan Documents respectively, the terms and provisions of this Agreement shall govern and control. By executing this Agreement in the place provided below, Borrower hereby (i) acknowledges the provisions hereof, (ii) agrees not to take any action inconsistent with Senior Lender’s rights or Junior Lender’s rights under this Agreement, (iii) waives and relinquishes to the maximum extent permitted by law any and all rights, defenses and claims now existing or hereinafter accruing relating to Junior Lender’s forbearance from exercising any rights and remedies pursuant to Section 4 of this Agreement, including, without limitation, any defenses based on the statute of limitations or any equitable defenses, such as laches, and (iv) acknowledges and agrees that (A) this Agreement is entered into for the sole protection and benefit of Senior Lender and Junior Lender (and their respective successors, assigns and participants), and no other person (including Borrower) shall have any benefits, rights or remedies under or by reason of this Agreement, (B) nothing in this Agreement is intended, or shall be construed to, relieve or discharge the obligations or liabilities of any third party (including Borrower under the Senior Loan Documents and the Junior Loan Documents), (C) neither of them nor any of their affiliates shall be, or be deemed to be, beneficiaries of any of the provisions hereof or have any rights hereunder whatsoever, and (D) no provision of this Agreement is intended to, or shall be construed to, give any such third party (including Borrower) any right subrogating to the rights of, or action against, Senior Lender or Junior Lender. (j) No amendment, supplement, modification, waiver or termination of this Agreement shall be effective against any party unless such amendment, supplement, modification, waiver or termination is contained in a writing signed by such party. (k) No party other than Senior Lender and Junior Lender shall have any rights under, or be deemed a beneficiary of any of the provisions of, this Agreement. (l) Nothing herein or in any of the Senior Loan Documents or Junior Loan Documents shall be deemed to constitute Senior Lender as a joint venturer or partner of Junior Lender. 12. Intentionally Omitted. Subordination and Intercreditor Agreement (County) 16 Vista Breeze 4891-9288-4364v.4 13. Attached Exhibits. The following Exhibits are attached to this Agreement and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Legal Description Exhibit B – Junior Loan Documents Exhibit C – Modifications to Subordination and Intercreditor Agreement The terms of this Agreement are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Agreement, the terms of said Exhibits shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Subordination and Intercreditor Agreement (County) A-1 Vista Breeze 4891-9288-4364v.4 IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Subordination and Intercreditor Agreement or caused this Subordination and Intercreditor Agreement to be duly executed and delivered by their respective authorized representatives as of the date first set forth above. JUNIOR LENDER: WITNESS OR ATTEST: MIAMI-DADE COUNTY, FLORIDA, a political subdivision of the State of Florida ________________________________ Name: __________________________ By:_______________________________ Name: Title: ________________________________ Name: __________________________ STATE OF ________ COUNTY OF _______ The foregoing instrument was acknowledged before me by means of [ ] physical presence or [ ] online notarization this __ day of _______, 20__, by _____________________, as ____________________________ of Miami-Dade County, Florida, a political subdivision of the State of Florida. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (County) 2 Vista Breeze 4891-9288-4364v.4 SENIOR LENDER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ CITIBANK, N.A., By: ___________ Name: Title: Deal ID No. 60001596 ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ________________, as ________________ of Citibank., N.A.. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (County) 3 Vista Breeze 4891-9288-4364v.4 ACKNOWLEDGED AND AGREED AS OF THE DATE FIRST SET FORTH ABOVE: BORROWER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: Name: Title: ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ___________________, as ___________ of APC Vista Breeze, LLC, a Florida limited liability company, a duly authorized signatory of Vista Breeze, Ltd., a Florida limited partnership. Said person is personally known to me or has produced a valid driver's license as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (County) A-1 Vista Breeze 4891-9288-4364v.4 EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. Subordination and Intercreditor Agreement (County) B-1 Vista Breeze 4891-9288-4364v.4 EXHIBIT B JUNIOR LOAN DOCUMENTS 1. Junior Note; 2. Junior Security Instrument; 3. Junior Loan Agreement; 4. Junior Security Instrument; and 5. Miami-Dade County Rental Regulatory Agreement, dated as of December 15, 2023, by Borrower in favor of Junior Lender. Subordination and Intercreditor Agreement (County) C-1 Vista Breeze 4891-9288-4364v.4 EXHIBIT C MODIFICATIONS TO SUBORDINATION AND INTERCREDITOR AGREEMENT The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. D Forward Purchase Agreement Vista Breeze EXHIBIT D-14 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT (FHFC) [See attached] 4889-5265-7294v.3 THIS INSTRUMENT PREPARED BY: Aviva Yakren, Esq. Sidley Austin LLP 787 Seventh Avenue New York, New York 10019 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: Citibank, N.A. Transaction and Asset Management Group/Post Closing Citi Community Capital 3800 Citibank Center Tampa, Florida 33610 Re: Vista Breeze Deal ID No. 60001596 ABOVE SPACE RESERVED FOR RECORDING PURPOSES ONLY EXHIBIT D-14 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT Subordination and Intercreditor Agreement (FHFC) Vista Breeze 4889-5265-7294v.3 EXHIBIT D-14 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT VISTA BREEZE / CONSTRUCTION INFLATION RESPONSE VIABILITY FUNDING / RFA 2023-211 / 2023-260V VISTA BREEZE / SAIL / ELI / NHTF / RFA 2021-205 / 2022-159SN THIS SUBORDINATION AND INTERCREDITOR AGREEMENT (this “Agreement”) dated as of the [_] day of [Month], 202[_], is made by and between FLORIDA HOUSING FINANCE CORPORATION, a public corporation and a public body corporate and politic duly created and existing under the laws of the State of Florida (“Junior Lender”) and CITIBANK, N.A., a national banking association (“Senior Lender”) and acknowledged by VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Conversion Date (as defined in the Original Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable Subordination and Intercreditor Agreement (FHFC) 2 Vista Breeze 4889-5265-7294v.3 to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Senior Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Senior Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, the Borrower Loan has converted into a permanent loan (the “Senior Loan”), and in connection therewith, (i) Senior Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement, dated as of the date hereof (the “Funding Loan Agreement”), by and among Governmental Lender, Fiscal Agent, and Senior Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement, dated as of the date hereof (the “Borrower Loan Agreement”), which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [_], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) executed and delivered by Borrower and dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Senior Lender and Borrower have entered into a certain the Loan Covenant Agreement executed and delivered by Borrower and dated as of the date hereof (the “Loan Covenant Agreement”). I. Junior Lender is making (i) a loan to Borrower in the original principal amount of $4,300,000 (the “Viability Loan”), which Viability Loan is evidenced by that certain Promissory Note, dated as of December 15, 2023, made by Borrower to Junior Lender (the “Viability Loan Note”) and secured by, that certain Leasehold Mortgage and Security Agreement, dated as of December 15, 2023, made by Borrower to Junior Lender and that certain Assignment of Leases, Rents and Contract Rights, dated as of December 15, 2023, encumbering the Property (collectively, the “Viability Loan Security Instrument”), and will be advanced to Borrower pursuant to that certain Construction Loan Agreement (the “Viability Loan Agreement”), dated as of December 15, 2023, between Borrower and Junior Lender, (ii) a loan to Borrower in the original principal amount of $3,000,000 (the “SAIL Loan”), which SAIL Loan is evidenced by Subordination and Intercreditor Agreement (FHFC) 3 Vista Breeze 4889-5265-7294v.3 that certain Promissory Note, dated as of December 15, 2023, made by Borrower to Junior Lender (the “SAIL Loan Note”) and secured by, that certain Leasehold Mortgage and Security Agreement, dated as of December 15, 2023, made by Borrower to Junior Lender and that certain Assignment of Leases, Rents and Contract Rights, dated as of December 15, 2023, encumbering the Property (collectively, the “SAIL Loan Security Instrument”), and will be advanced to Borrower pursuant to that certain Construction Loan Agreement (the “SAIL Loan Agreement”), dated as of December 15, 2023, between Borrower and Junior Lender, (iii) a loan to Borrower in the original principal amount of $600,000 (the “ELI Loan”), which ELI Loan is evidenced by that certain Promissory Note, dated as of December 15, 2023, made by Borrower to Junior Lender (the “ELI Loan Note”) and secured by, that certain Leasehold Mortgage and Security Agreement, dated as of December 15, 2023, made by Borrower to Junior Lender, and that certain Assignment of Leases, Rents and Contract Rights, dated as of December 15, 2023, encumbering the Property (collectively, the “ELI Loan Security Instrument”), and will be advanced to Borrower pursuant to that certain Construction Loan Agreement (the “ELI Loan Agreement”), dated as of December 15, 2023, between Borrower and Junior Lender, and (iv) a loan to Borrower in the original principal amount of $1,301,500 (the “NHTF Loan”; and together with the Viability Loan, SAIL Loan, ELI Loan and NHTF Loan, collectively, the “Junior Loan”), which NHTF Loan is evidenced by that certain Promissory Note, dated as of December 15, 2023, made by Borrower to Junior Lender (the “NHTF Loan Note”; and together with the Viability Loan Note, SAIL Loan Note, ELI Loan Note and NHTF Loan Note, collectively, the “Junior Loan Note”) and secured by, that certain Leasehold Mortgage and Security Agreement, dated as of December 15, 2023, made by Borrower to Junior Lender, and that certain Assignment of Leases, Rents and Contract Rights, dated as of December 15, 2023, encumbering the Property (collectively, the “NHTF Loan Security Instrument”), and will be advanced to Borrower pursuant to that certain Construction Loan Agreement (the “NHTF Loan Agreement”; and together with the Viability Loan Agreement, SAIL Loan Agreement, ELI Loan Agreement and NHTF Loan Agreement, collectively, the “Junior Loan Agreement”), dated as of December 15, 2023, between Borrower and Junior Lender. J. As a condition to the making of the Senior Loan, Senior Lender requires that Junior Lender execute and deliver this Agreement prior to the making of the Junior Loan and the granting of the Junior Security Instrument by Borrower. NOW, THEREFORE, for Ten Dollars ($10.00) and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, and to induce the making of the Senior Loan and to induce Senior Lender to consent to the Junior Loan and the Junior Security Instrument, Junior Lender hereby agrees as follows: 1. Definitions. Capitalized terms used but not defined in this Agreement shall have the meanings ascribed thereto in the Senior Security Instrument. As used in this Agreement, the terms set forth below shall have the respective meanings indicated: “Bankruptcy Proceeding” means any bankruptcy, reorganization, insolvency, composition, restructuring, dissolution, liquidation, receivership, assignment for the benefit of creditors, or custodianship action or proceeding under any federal or state law with respect to Borrower, any guarantor of any of the Senior Indebtedness, any of their respective properties, or any of their respective partners, members, officers, directors, or shareholders. Subordination and Intercreditor Agreement (FHFC) 4 Vista Breeze 4889-5265-7294v.3 “Casualty” means the occurrence of damage to or loss of any of the Property by fire or other casualty. “Condemnation” means any proposed or actual condemnation or other taking, or conveyance in lieu thereof, of all or any part of the Property, whether direct or indirect. “Enforcement Action” means any exercise of any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Loan Documents, including, without limitation, any of the following: (i) the acceleration of all or any part of the Junior Indebtedness, (ii) the commencement of any judicial or non-judicial action or proceeding to enforce any obligation of Borrower under any of the Junior Loan Documents, collect any monies payable to Borrower or have a receiver appointed to collect any monies payable to Borrower, or foreclose the lien(s) created by the Junior Security Instrument, (iii) the filing or joining in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower, (iv) the advertising of or commencement of any foreclosure or trustee’s sale proceedings, (v) the exercise of any power of sale, (vi) the acceptance of a deed or assignment in lieu of foreclosure or sale, (vii) the collecting of Rents, (viii) the obtaining of or seeking of the appointment of a receiver, (ix) the seeking of default interest, (x) the taking of possession or control of any of the Property, (xi) the commencement of any suit or other legal, administrative, or arbitration proceeding based upon the Junior Note or any other of the Junior Loan Documents, (xii) the exercising of any banker’s lien or rights of set-off or recoupment, or (xiii) the taking of any other enforcement action against Borrower, any other party liable for any of the Junior Indebtedness or obligated under any of the Junior Loan Documents, or the Property. “Enforcement Action Notice” means a written notice from Junior Lender to Senior Lender, given following a Junior Loan Default and the expiration of any notice or cure periods provided for such Junior Loan Default in the Junior Loan Documents, setting forth in reasonable detail the Enforcement Action proposed to be taken by Junior Lender. “Junior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Junior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. “Junior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Junior Security Instrument. “Junior Loan Documents” means, collectively, the Junior Note, the Junior Security Instrument, the Junior Loan Agreement, the Junior LURA, and all other documents evidencing, securing or delivered in connection with the Junior Loan, all of which are listed on Exhibit B attached hereto, together with such modifications, amendments and supplements thereto as are approved in writing by Senior Lender prior to their execution. “Junior LURA” means, collectively, (i) that certain Land Use Restriction Agreement, dated as of December 15, 2023, by and between Borrower and Junior Lender, in connection with the Viability Loan, (ii) that certain Land Use Restriction Agreement, dated as of December 15, 2023, by and between Borrower and Junior Lender, in connection with the SAIL Loan, (iii) that certain Subordination and Intercreditor Agreement (FHFC) 5 Vista Breeze 4889-5265-7294v.3 Land Use Restriction Agreement, dated as of December 15, 2023, by and between Borrower and Junior Lender, in connection with the ELI Loan, and (iv) that certain Land Use Restriction Agreement, dated as of December 15, 2023, by and between Borrower and Junior Lender, in connection with the NHTF Loan. “Junior Security Instrument” means, collectively, the Viability Loan Security Instrument, the SAIL Loan Security Instrument, the ELI Loan Security Instrument, the NHTF Loan Security Instrument, as the same may from time to time be extended, consolidated, substituted for, modified, amended or supplemented upon receipt of the consent of Senior Lender. “Loan Agreement” means the Loan Covenant Agreement. “Loss Proceeds” means all monies received or to be received under any insurance policy, from any condemning authority, or from any other source, as a result of any Condemnation or Casualty. “Property” means (i) the land and improvements known or to be known as Vista Breeze, located in the City of Miami Beach, Miami-Dade County, State of Florida, which Property is more particularly described on Exhibit A attached hereto, and (ii) all furniture, fixtures and equipment located at such apartments and other property, accounts, deposits and rights and interests of Borrower encumbered by the Senior Security Instrument and/or the other Senior Loan Documents. “Senior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Senior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. “Senior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Senior Security Instrument. “Senior Loan Documents” means, collectively, the Senior Security Instrument, the Senior Note, the Borrower Loan Agreement and all of the other documents, instruments and agreements now or hereafter evidencing, securing or otherwise executed in connection with the Senior Loan, as the same may from time to time be extended, consolidated, substituted for, modified, increased, amended and supplemented in accordance with the provisions of this Agreement. 2. Junior Loan and Junior Loan Documents are Subordinate; Acts by Senior Lender do not Affect Subordination. (a) Junior Lender hereby covenants and agrees on behalf of itself and its successors and permitted assigns that the Junior Indebtedness is and shall at all times continue to be, subordinate, subject and inferior (in payment and priority) to the prior payment in full of the Senior Indebtedness, and that the liens, rights, payment interests, priority interests and security interests granted to Junior Lender in connection with the Junior Loan and under the Junior Loan Documents are, and are hereby expressly acknowledged to be in all respects and at all times, subject, subordinate and inferior in all respects to the liens, rights, payment, priority and security interests granted to Senior Subordination and Intercreditor Agreement (FHFC) 6 Vista Breeze 4889-5265-7294v.3 Lender under the Senior Loan and the Senior Loan Documents and the terms, covenants, conditions, operations and effects thereof. (b) Except as expressly set forth herein, repayment of the Junior Indebtedness, is and shall be postponed and subordinated to repayment in full of the Senior Loan. Prior to a Senior Loan Default (regardless of whether such Senior Loan Default occurs prior to or during the pendency of a Bankruptcy Proceeding), Junior Lender shall be entitled to receive and retain payments made pursuant to and in accordance with the terms of the Junior Loan Documents; provided, however, that no such payment is made more than ten (10) days in advance of the due date thereof. Junior Lender agrees that from and after such time as it has received from either Senior Lender or Borrower written notice that a Senior Loan Default then exists (which has not been expressly waived in writing by Senior Lender) or otherwise has actual knowledge of such a Senior Loan Default, Junior Lender shall not receive or accept any payments under the Junior Loan. If (i) Junior Lender receives any payment, property, or asset of any kind or in any form on account of the Junior Indebtedness (including, without limitation, any proceeds from any Enforcement Action) after a Senior Loan Default of which Junior Lender has actual knowledge or has been given notice of, or (ii) Junior Lender receives, voluntarily or involuntarily, by operation of law or otherwise, any payment, property, or asset in or in connection with any Bankruptcy Proceeding, such payment, property, or asset will be received and held in trust for Senior Lender. Junior Lender will promptly remit, in kind and properly endorsed as necessary, all such payments, properties, and assets to Senior Lender. Senior Lender shall apply any payment, asset, or property so received from Junior Lender to the Senior Indebtedness in such order, amount (with respect to any asset or property other than immediately available funds), and manner as Senior Lender shall determine in its sole and absolute discretion. (c) Without limiting the complete subordination of the Junior Indebtedness to the payment in full of the Senior Indebtedness, in any Bankruptcy Proceeding, upon any payment or distribution (whether in cash, property, securities, or otherwise) to creditors (i) the Senior Indebtedness shall first be paid in full in cash before Junior Lender shall be entitled to receive any payment or other distribution on account of or in respect of the Junior Indebtedness, and (ii) until all of the Senior Indebtedness is paid in full in cash, any payment or distribution to which Junior Lender would be entitled but for this Agreement (whether in cash, property, or other assets) shall be made to Senior Lender. (d) The subordination of the Junior Indebtedness shall continue in the event that any payment under the Senior Loan Documents (whether by or on behalf of Borrower, as proceeds of security or enforcement of any right of set-off or otherwise) is for any reason repaid or returned to Borrower or its insolvent estate, or avoided, set aside or required to be paid to Borrower, a trustee, receiver or other similar party under any bankruptcy, insolvency, receivership or similar law. In such event, the Senior Indebtedness or part thereof originally intended to be satisfied shall be deemed to be reinstated and outstanding to the extent of any repayment, return, or other action, as if such payment on account of the Senior Indebtedness had not been made. (e) The subordination of the Junior Loan Documents and of the Junior Indebtedness shall apply and continue notwithstanding (i) the actual date and time of Subordination and Intercreditor Agreement (FHFC) 7 Vista Breeze 4889-5265-7294v.3 execution, delivery, recording, filing or perfection of the Senior Security Instrument and other Senior Loan Documents and of the Junior Security Instrument and other Junior Loan Documents, and (ii) the availability of any collateral to Senior Lender, including the availability of any collateral other than the Property. (f) By reason of, and without in any way limiting, the full subordination of the Junior Indebtedness and the Junior Loan Documents provided for in this Agreement, all rights and claims of Junior Lender under the Junior Security Instrument or under the Junior Loan Documents in or to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto, are expressly subject and subordinate in all respects to the rights and claims of Senior Lender under the Senior Loan Documents in and to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto. (g) If Junior Lender, by indemnification, subrogation or otherwise, shall acquire any lien, estate, right or other interest in any of the Property, that lien, estate, right or other interest shall be fully subject and subordinate to the receipt by Senior Lender of payment in full of the Senior Indebtedness, and to the Senior Loan Documents, to the same extent as the Junior Indebtedness and the Junior Loan Documents are subordinate pursuant to this Agreement. (h) In confirmation, and not as a condition, of the subordination of the Junior Indebtedness and the Junior Loan Documents provided for in this Agreement, Junior Lender shall place on or attach to the Junior Note a notice to the following effect, and shall provide Senior Lender with a copy of the Junior Note showing such notice: “The indebtedness evidenced by this Note is and shall be subordinate in right of payment to the prior payment in full of all amounts then due and payable (including, but not limited to, all amounts due and payable by virtue of any default or acceleration or upon maturity) with respect to the indebtedness evidenced by the Note (as defined by that certain Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) by the Borrower in favor of Governmental Lender and assigned to The Bank of New York Mellon Trust Company, N.A., a national banking association, in the original maximum principal amount of $[11,950,000] [NOTE: AS MAY BE INCREASED PER THE EARN-OUT]) to the extent and in the manner provided in that certain Subordination and Intercreditor Agreement, dated as of [_____], 20[_], between Citibank, N.A. (“Senior Lender”) and the holder of this Note (the “Subordination Agreement”). The rights and remedies of the payee and each subsequent holder of this Note shall be deemed, by virtue of such holder’s acquisition of this Note, to have agreed to perform and observe all of the terms, covenants and conditions to be performed or observed by the “Junior Lender” under the Subordination Agreement.” Subordination and Intercreditor Agreement (FHFC) 8 Vista Breeze 4889-5265-7294v.3 (i) Junior Lender consents to any agreement or arrangement in which Senior Lender waives, postpones, extends, reduces or modifies any provisions of the Senior Loan Documents, including any provision requiring the payment of money. Notwithstanding the foregoing, Senior Lender may not modify any provisions of the Senior Loan Documents that increases the interest rate, extends the term (other than extensions expressly provided for in accordance with the Senior Loan Documents) or increases the Senior Loan, except for increases in the interest rate, extensions of the term or increases in the Senior Loan that results from advances made by Senior Lender to protect the security or lien priority of Senior Lender under the Senior Loan Documents or to cure defaults under the Junior Loan Documents. Junior Lender hereby acknowledges and agrees that, upon the occurrence and continuation of a Senior Loan Default, Senior Lender may, without the consent or approval of Junior Lender, agree with Borrower to extend, consolidate, modify, increase or amend any or all the Senior Loan Documents and otherwise act or fail to act with respect to any matter set forth in any Senior Loan Document (including, without limitation, the exercise of any rights or remedies, waiver, forbearance or delay in enforcing any rights or remedies, the declaration of acceleration, the declaration of defaults or events of default, the release, in whole or in part, of any collateral or other property, and any consent, approval or waiver), and all such extensions, consolidations, modifications, amendments acts and omissions shall not release, impair or otherwise affect Junior Lender’s obligations and agreements hereunder. In the event of a Potential Default under the Senior Loan documents, Senior Lender may exercise its remedies and take such actions as it believes necessary to preserve is security and lien position as long as such actions shall not release, impair or otherwise affect Junior Lender’s obligations and agreements hereunder. The Senior Lender shall endeavor to provide Junior Lender with notice of any such modifications in a reasonable amount of time after such modifications are made, however, failure to provide such notice shall not cause a breach of any obligations of Senior Lender under this Agreement. All notices shall be sent in accordance with Section 8 hereof. 3. Junior Lender Agreements. (a) Without the prior written consent of Senior Lender in each instance, Junior Lender shall not (i) amend, modify, waive, extend, renew or replace any provision of any of the Junior Loan Documents, or (ii) pledge, assign, transfer, convey, or sell any interest in the Junior Indebtedness or any of the Junior Loan Documents; or (iii) accept any payment on account of the Junior Indebtedness other than a regularly scheduled payment of interest or principal and interest made not earlier than ten (10) days prior to the due date thereof; or (iv) take any action which has the effect of increasing the Junior Indebtedness; or (v) appear in, defend or bring any action in connection with the Property; or (vi) take any action concerning environmental matters affecting the Property. Regardless of any contrary provision in the Junior Loan Documents, Junior Lender shall not collect payments for the purpose of escrowing for any cost or expense related to the Property or for any portion of the Junior Indebtedness. (b) Senior Lender shall have the right, but shall not have any obligation, to cure any Junior Loan Default until ninety (90) days following Senior Lender’s receipt of an Enforcement Action Notice given by Junior Lender as a consequence of the Junior Loan Default. Senior Lender shall not be subrogated to the rights of Junior Lender under the Subordination and Intercreditor Agreement (FHFC) 9 Vista Breeze 4889-5265-7294v.3 Junior Loan Documents by reason of Senior Lender having cured any Junior Loan Default. However, Junior Lender acknowledges that all amounts advanced or expended by Senior Lender to cure a Junior Loan Default shall be added to and become a part of the Senior Indebtedness pursuant to the terms of the Senior Security Instrument. (c) Other than as provided below in this subsection (c), in the event and to the extent that each of Senior Lender and Junior Lender have under their respective loan documents certain approval or consent rights over the same subject matters (regardless of whether the obligations or rights are identical or substantially identical), Junior Lender agrees that Senior Lender shall exercise such approval rights on behalf of both Senior Lender and Junior Lender, and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby; but only in the event that Senior Lender shall have provided Junior Lender with written notice regarding such approval and consent and the Junior Lender has not notified Senior Lender that it objects to Senior Lender taking such action or giving such approval within ten Business Days of such notice. Notwithstanding the prior sentence, the Senior Lender shall have all approval, consent and oversight rights in connection with any insurance claims relating to the Property, and any decisions regarding the use of insurance proceeds after a casualty loss or condemnation awards and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby. (d) Junior Lender agrees that, except as may otherwise be provided in the Junior LURA, in any action commenced to enforce the obligation of Borrower to pay any portion of the Junior Indebtedness, the judgment shall not be enforceable personally against Borrower or Borrower’s assets, and the recourse of Junior Lender for the collection of the Junior Indebtedness shall be limited to actions against the Property and the rents, profits, issues, products, and income from the Property. (e) Junior Lender shall not commence or join with any other creditor in commencing any Bankruptcy Proceeding involving Borrower, and Junior Lender shall not initiate and shall not be a party to any action, motion or request, in a Bankruptcy Proceeding involving any other person or entity, which seeks the consolidation of some or all of the assets of Borrower into such Bankruptcy Proceeding. In the event of any Bankruptcy Proceeding relating to Borrower or the Property or, in the event of any Bankruptcy Proceeding relating to any other person or entity into which (notwithstanding the covenant in the first sentence of this clause) the assets or interests of Borrower are consolidated, then in either event, the Senior Loan shall first be paid in full before Junior Lender shall be entitled to receive and retain any payment or distribution in respect to the Junior Loan. Junior Lender agrees that (i) Senior Lender shall receive all payments and distributions of every kind or character in respect of the Junior Loan to which Junior Lender would otherwise be entitled from the Borrower, but for the subordination provisions of this Agreement (including without limitation, any payments or distributions during the pendency of a Bankruptcy Proceeding involving Borrower or the Property), and (ii) the subordination of the Junior Loan and the Junior Loan Documents shall not be affected in any way by Senior Lender electing, under Section 1111(b) of the federal bankruptcy code, to have its claim treated as being a fully secured claim. In addition, Junior Lender hereby Subordination and Intercreditor Agreement (FHFC) 10 Vista Breeze 4889-5265-7294v.3 covenants and agrees that, in connection with a Bankruptcy Proceeding involving Borrower, neither Junior Lender nor any of its affiliates shall (i) make or participate in a loan facility to or for the benefit of Borrower on a basis that is senior to or pari passu with the liens and interests held by Senior Lender pursuant to the Senior Loan Documents, (ii) not vote affirmatively in favor of any plan of reorganization or liquidation unless Senior Lender has also voted affirmatively in favor of such plan, and (iii) not contest the continued accrual of interest on the Senior Indebtedness, in accordance with and at the rates specified in the Senior Loan Documents, both for periods before and for periods after the commencement of such Bankruptcy Proceedings. In the event of any such Bankruptcy Proceeding, Junior Lender shall execute and deliver to Senior Lender powers of attorney, assignments or other instruments, as may be requested by Senior Lender in order to enable it to exercise the above-described authority or powers with respect to any or all of the Junior Loan Documents, and to collect and receive any and all payments or distributions which may be payable or deliverable at any time upon or with respect to any of the Junior Loan Documents to Junior Lender. (f) Junior Lender covenants and agrees that the effectiveness of this Agreement and the rights of Senior Lender hereunder shall be in no way impaired, affected, diminished or released by any renewal or extension of the time of payment of the Senior Loan, provided for in this Agreement, by any delay, forbearance, failure, neglect or refusal of Senior Lender in enforcing payment thereof or in enforcing the lien of or attempting to realize upon the Senior Loan Documents or any other security which may have been given or may hereafter be given for the Senior Loan, by any waiver or failure to exercise any right or remedy under the Senior Loan Documents, or by any other act or failure to act by Senior Lender. Junior Lender acknowledges that Senior Lender, at its sole option, may release all or any portion of the Property from the lien of the Senior Security Instrument, and may release or waive any guaranty, surety or indemnity providing additional collateral to Senior Lender, and Junior Lender hereby waives any legal or equitable right in respect of marshaling it might have in connection with any such release of all or any portion of the Property by Senior Lender. Senior Lender may pursue all rights and remedies available to it under the Senior Loan Documents, at law, or in equity, regardless of any Enforcement Action by Junior Lender. At any time or from time to time and any number of times, without notice to Junior Lender and without affecting the liability of Junior Lender, (a) the time for Borrower’s performance of or compliance with any covenant or agreement contained in the Senior Loan Documents, whether presently existing or hereinafter entered into, may be extended or such performance or compliance may be waived; (b) the maturity of the Senior Indebtedness may be accelerated as provided in the Senior Loan Documents; and (c) any security for the Senior Indebtedness may be modified, exchanged, surrendered or otherwise dealt with or additional security may be pledged or mortgaged for the Senior Indebtedness. If, after the occurrence of a Senior Loan Default, Senior Lender acquires title to any of the Property pursuant to a mortgage foreclosure conducted in accordance with applicable law, the lien, operation, and effect of the Junior Security Instrument and other Junior Loan Documents automatically shall terminate with respect to such Property upon Senior Lender’s acquisition of title. (g) Junior Lender acknowledges that it entered into the transactions contemplated by the Junior Loan Documents and made the Junior Loan to Borrower Subordination and Intercreditor Agreement (FHFC) 11 Vista Breeze 4889-5265-7294v.3 without reliance upon any information or advice from Senior Lender. Junior Lender made its own underwriting analysis in connection with the Junior Loan, its own credit review of Borrower, and investigated all matters pertinent, in Junior Lender’s judgment, to its determination to make the Junior Loan to Borrower. Junior Lender acknowledges that it is a sophisticated, experienced governmental lender, and was represented by competent counsel in connection with this Agreement. (h) Junior Lender hereby further represents and warrants that as of the date hereof: (i) Junior Lender is now the owner and holder of the Junior Loan Documents; (ii) the Junior Loan Documents are now in full force and effect; (iii) the Junior Loan Documents have not been modified or amended; (iv) no default or event which, with the passing of time or giving of notice would constitute a default, under the Junior Loan Documents has occurred; (v) the current principal balance of the Junior Indebtedness is $[_]; (vi) no scheduled monthly payments under the Junior Loan Documents have been or will be prepaid except with the prior written consent of Senior Lender; (vii) none of the rights of Junior Lender under any of the Junior Loan Documents are subject to the rights of any third parties, by way of subrogation, indemnification or otherwise; and (viii) there are no other Junior Loan Documents other than those listed on Exhibit B hereto. Borrower further represents and warrants that it has provided to Senior Lender a true, complete, and correct copy of all the Junior Loan Documents. (i) Junior Lender further agrees that its agreement to subordinate hereunder shall, subject to favorable credit underwriting and the approval of its Board of Directors, extend to any new mortgage debt which is for the purpose of refinancing all or any part of the Senior Indebtedness (including reasonable and necessary costs associated with the closing and/or the refinancing), as long as the principal amount of such new mortgage debt is not greater than the original principal amount of the Senior Indebtedness unless such excess amount is used to improve the Property or to compensate Senior Lender for costs, fees and/or expenses incurred in protecting the security of the Senior Security Instrument; and that all the terms and covenants of this Agreement shall inure to the benefit of any holder of any such refinanced debt; and that all references to the Senior Indebtedness, the Senior Note, the Senior Security Instrument, the Senior Loan Documents and Senior Lender shall mean, respectively, the refinance loan, the refinance note, the mortgage securing the refinance note, all documents evidencing securing or otherwise pertaining to the refinance note and the holder of the refinance note. In the event the principal amount of any new mortgage debt is greater than the original principal amount of the Senior Indebtedness and such excess is not used to either improve the Property or to compensate Senior Lender for costs, fees and/or expenses incurred in protecting the security of the Senior Security Instrument, Senior Lender and Borrower agree to seek the written consent of Junior Lender which consent shall not be unreasonably withheld, conditioned or delayed. 4. Standstill Agreement; Right to Cure Senior Loan Default. (a) Until such time as any of the Senior Indebtedness has been repaid in full and the Senior Security Instrument has been released and discharged, Junior Lender shall not without the prior written consent of Senior Lender, which may be withheld in Senior Subordination and Intercreditor Agreement (FHFC) 12 Vista Breeze 4889-5265-7294v.3 Lender’s sole and absolute discretion, (i) accelerate the Junior Loan, (ii) exercise any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Loan Documents (including, without limitation, the commencement of any judicial or non- judicial action or proceeding (a) to enforce any obligation of Borrower under any of the Junior Loan Documents, (b) to collect any monies payable to Borrower, (c) to have a receiver appointed to collect any monies payable to Borrower; or (d) to foreclose the lien(s) created by the Junior Security Instrument) or (iii) file or join in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower; provided, however, that such limitation on the remedies of Junior Lender shall not derogate or otherwise limit Junior Lender’s rights under the Junior Loan Documents to (a) compute interest on all amounts due and payable under the Junior Loan at the default rate described in the Junior Loan Documents, (b) compute prepayment premiums and late charges, (c) enforce against any person, other than Borrower and any guarantors or indemnitors under the Senior Loan Documents, any guaranty of the obligations of Borrower under the Junior Loan, and (d) enforce the Junior LURA through equitable remedies, including specific performance as provided therein. (b) Senior Lender shall, simultaneously with the sending of any notice of a Senior Loan Default to Borrower, send to Junior Lender a copy of said notice under the Senior Loan Documents; provided, however, failure to do so shall not affect the validity of such notice or any obligation of Borrower to Senior Lender and shall not affect the relative priorities between the Senior Loan and the Junior Loan as set forth herein. Borrower covenants and agrees to forward to Junior Lender, within three (3) business days of Borrower’s receipt thereof, a copy of any notice of a Senior Loan Default Borrower receives from Senior Lender. (c) Junior Lender shall have the right, but shall have no obligation, to cure any Senior Loan Default; provided, if Junior Lender shall elect to cure any such Default, it shall so notify Senior Lender and shall commence and complete such curing within any applicable notice or grace period, if any, as Borrower is permitted by the terms of the Senior Loan Documents to cure such Senior Loan Default. Junior Lender shall not be subrogated to the rights of Senior Lender under the Senior Loan Documents by reason of Junior Lender having cured any Senior Loan Default. However, Senior Lender acknowledges that, to the extent so provided in the Junior Loan Documents, amounts advanced or expended by Junior Lender to cure a Senior Loan Default may be added to and become a part of the Junior Indebtedness. (d) Junior Lender agrees that, notwithstanding any contrary provision contained in the Junior Loan Documents, a Senior Loan Default shall not constitute a default under the Junior Loan Documents if no other default occurred under the Junior Loan Documents. (e) Junior Lender acknowledges that any conveyance or other transfer of title to the Property pursuant to a foreclosure of the Junior Security Instrument (including a conveyance or other transfer of title pursuant to the exercise of a power of sale contained in the Junior Security Instrument), or any deed or assignment in lieu of foreclosure or similar arrangement, shall be subject to the transfer provisions of the Senior Loan Subordination and Intercreditor Agreement (FHFC) 13 Vista Breeze 4889-5265-7294v.3 Documents; and the person (including Junior Lender) who acquires title to the Property pursuant to the foreclosure proceeding (or pursuant to the exercise of a power of sale contained in the Junior Security Instrument) shall not be deemed to be automatically approved by Senior Lender. 5. Insurance. Junior Lender agrees that all original policies of insurance required pursuant to the Senior Security Instrument shall be held by Senior Lender. The preceding sentence shall not preclude Junior Lender from requiring that it be named as a loss payee, as its interest may appear, under all policies of property damage insurance maintained by Borrower with respect to the Property, provided such action does not affect the priority of payment of the proceeds of property damage insurance under the Senior Security Instrument, or that it be named as an additional insured under all policies of liability insurance maintained by Borrower with respect to the Property. 6. Default. Junior Lender and Borrower acknowledge and agree that a default by either such party under this Agreement shall, at the sole option of Senior Lender, constitute a default under the Senior Loan Documents. Each party hereto acknowledges that in the event any party fails to comply with its obligations hereunder, the other parties shall have all rights available at law and in equity, including the right to obtain specific performance of the obligations of such defaulting party and injunctive relief. No failure or delay on the part of any party hereto in exercising any right, power or remedy hereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any such right, power or remedy preclude any other or further exercise thereof or the exercise of any other right, power or remedy hereunder. 7. Enforcement Costs. Borrower agrees to reimburse Senior Lender for any and all costs and expenses (including reasonable attorneys’ fees) incurred by Senior Lender in connection with enforcing its rights against Junior Lender under this Agreement. 8. Notices. Any notice which any party hereto may be required or may desire to give hereunder shall be deemed to have been given and shall be effective only if it is in writing and (i) delivered personally, (ii) mailed, postage prepaid, by United State registered or certified mail, return receipts requested, (iii) delivered by overnight express courier or (iv) sent by telecopier, in each instance addressed as follows: To Junior Lender: With a copy to: Florida Housing Finance Corporation 227 N. Bronough Street, Suite 5000 Tallahassee, Florida 32301-1329 Attention: Executive Director Weiss Serota Helfman Cole + Bierman 2800 Ponce de Leon Blvd., Suite 1200 Coral Gables, FL 33134 Attention: Maria Victoria Currais, Esq. Subordination and Intercreditor Agreement (FHFC) 14 Vista Breeze 4889-5265-7294v.3 If to Senior Lender: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 With a copy to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 With a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291-5754 or at such other addresses or to the attention of such other persons as may from time to time be designated by the party to be addressed by written notice to the other in the manner herein provided. Notices, demands and requests given in the manner aforesaid shall be deemed sufficiently served or given for all purposes hereunder when received or when delivery is refused or when the same are returned to sender for failure to be called for. 9. WAIVER OF TRIAL BY JURY. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF THE PARTIES HERETO (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 10. Term. The term of this Agreement shall commence on the date hereof and shall continue until the earliest to occur of the following events: (i) the payment of all of the principal of, interest on and other amounts payable under the Senior Loan Documents; (ii) the payment of Subordination and Intercreditor Agreement (FHFC) 15 Vista Breeze 4889-5265-7294v.3 all of the principal of, interest on and other amounts payable under the Junior Loan Documents, other than by reason of payments which Junior Lender is obligated to remit to Senior Lender pursuant to the terms hereof; (iii) the acquisition by Senior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Senior Security Instrument; or (iv) the acquisition by Junior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Junior Security Instrument, but only if such acquisition of title does not violate any of the terms of this Agreement. 11. Miscellaneous. (a) Junior Lender shall, within ten (10) business days following a request from Senior Lender, provide Senior Lender with a written statement setting forth the then current outstanding principal balance of the Junior Loan, the aggregate accrued and unpaid interest under the Junior Loan, and stating whether, to the knowledge of Junior Lender, any default or event of default exists under the Junior Loan, and containing such other information with respect to the Junior Indebtedness as Senior Lender may require. Upon notice from Senior Lender from time to time, Junior Lender shall execute and deliver such additional instruments and documents, and shall take such actions, as are required by Senior Lender in order to further evidence or effectuate the provisions and intent of this Agreement. (b) Senior Lender shall, within ten (10) business days following a request from Junior Lender, provide Junior Lender with a written statement setting forth the then current outstanding principal balance of the Senior Loan, the aggregate accrued and unpaid interest under the Senior Loan, and stating whether, to the knowledge of Senior Lender, any default or event of default exists under the Senior Loan, and containing such other information with respect to the Senior Indebtedness as Junior Lender may require. (c) Junior Lender shall give Senior Lender a concurrent copy of each notice of a Junior Loan Default or other material notice given by Junior Lender under the Junior Loan Documents. (d) Senior Lender shall endeavor to give Junior Lender a concurrent copy of each notice of a Senior Loan Default or other material notice given by Senior Lender under the Senior Loan Documents; provided however, failure to provide such notice shall not in any manner impair the rights of the Senior Lender under this Agreement or the subordination of the Junior Loan to the Senior Loan in accordance with this Agreement. (e) This Agreement shall bind and inure to the benefit of all successors and assigns of Junior Lender and Senior Lender. Senior Lender may assign its interest in the Senior Loan Documents without notice to or consent of Junior Lender. Junior Lender may assign its rights and interests hereunder upon notice to the Senior Lender. (f) Senior Lender hereby consents to the Junior Loan and the Junior Loan Documents; provided, however, that this Agreement does not constitute an approval by Senior Lender of the terms of the Junior Loan Documents. Junior Lender hereby consents to the Senior Loan and the Senior Loan Documents; provided, however, that this Subordination and Intercreditor Agreement (FHFC) 16 Vista Breeze 4889-5265-7294v.3 Agreement does not constitute an approval by Junior Lender of the terms of the Senior Loan Documents. (g) This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. (h) IN ALL RESPECTS, INCLUDING, WITHOUT LIMITATION, MATTERS OF CONSTRUCTION AND PERFORMANCE OF THIS AGREEMENT AND THE OBLIGATIONS ARISING HEREUNDER, THIS AGREEMENT HAS BEEN ENTERED INTO AND DELIVERED IN, AND SHALL BE CONSTRUED IN ACCORDANCE WITH AND GOVERNED BY, THE LAWS OF THE STATE WHERE THE PROPERTY IS LOCATED, WITHOUT GIVING EFFECT TO ANY PRINCIPLES OF CONFLICTS OF LAW. (i) Time is of the essence in the performance of every covenant and agreement contained in this Agreement. (j) If any provision or remedy set forth in this Agreement for any reason shall be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provision or remedy of this Agreement and this Agreement shall be construed as if such invalid, illegal or unenforceable provision or remedy had never been set forth herein, but only to the extent of such invalidity, illegality or unenforceability. (k) Each party hereto hereby represents and warrants that this Agreement has been duly authorized, executed and delivered by it and constitutes a legal, valid and binding agreement enforceable in all material respects in accordance with its terms. (l) Borrower hereby acknowledges and consents to the execution of this Agreement, and agrees to be bound by the provisions hereof that are applicable to Borrower. Solely as between Senior Lender and Junior Lender, all of the signatories below hereby agree that to the extent of any conflict between the terms and provisions of this Agreement and the terms and provisions of the Senior Loan Documents and/or the Junior Loan Documents respectively, the terms and provisions of this Agreement shall govern and control. By executing this Agreement in the place provided below, Borrower hereby (i) acknowledges the provisions hereof, (ii) agrees not to take any action inconsistent with Senior Lender’s rights or Junior Lender’s rights under this Agreement or the Junior Loan Documents, (iii) waives and relinquishes to the maximum extent permitted by law any and all rights, defenses and claims now existing or hereinafter accruing relating to Junior Lender’s forbearance from exercising any rights and remedies pursuant to Section 4 of this Agreement, including, without limitation, any defenses based on the statute of limitations or any equitable defenses, such as laches, and (iv) acknowledges and agrees that (A) this Agreement is entered into for the sole protection and benefit of Senior Lender and Junior Lender (and their respective successors, assigns and participants), and no other person (including Borrower) shall have any benefits, rights or remedies under or by reason of this Agreement, (B) nothing in this Agreement is intended, or shall be construed to, relieve or Subordination and Intercreditor Agreement (FHFC) 17 Vista Breeze 4889-5265-7294v.3 discharge the obligations or liabilities of any third party (including Borrower under the Senior Loan Documents and the Junior Loan Documents), (C) it is required to comply with its obligations and duties set forth in the Senior Loan Documents and the Junior Loan Documents, (D) neither it nor any of its affiliates shall be, or be deemed to be, beneficiaries of any of the provisions hereof or have any rights hereunder whatsoever, and (D) no provision of this Agreement is intended to, or shall be construed to, give any such third party (including Borrower) any right subrogating to the rights of, or action against, Senior Lender or Junior Lender. (m) No amendment, supplement, modification, waiver or termination of this Agreement shall be effective against any party unless such amendment, supplement, modification, waiver or termination is contained in a writing signed by such party. (n) No party other than Senior Lender and Junior Lender shall have any rights under, or be deemed a beneficiary of any of the provisions of, this Agreement. (o) Nothing herein or in any of the Senior Loan Documents or Junior Loan Documents shall be deemed to constitute Senior Lender or Junior Lender as a joint venturer or partner of Junior Lender. (p) Notwithstanding any provision in this Agreement, the obligations of Junior Lender hereunder are subject to compliance with all applicable Florida laws and regulations, including but not limited to Chapter 420, Part V, Florida Statutes and Rule Chapter 67-48, Florida Administrative Code. (q) Except as specifically provided herein, this Agreement does not amend, modify, waive or limit any provision, term or condition of the Junior Loan Documents or the Senior Loan Documents. 12. Intentionally Omitted. 13. Attached Exhibits. The following Exhibits are attached to this Agreement and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Legal Description Exhibit B – Junior Loan Documents Exhibit C – Modifications to Subordination and Intercreditor Agreement The terms of this Agreement are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Agreement, the terms of said Exhibits shall be controlling in all respects. Subordination and Intercreditor Agreement (FHFC) 18 Vista Breeze 4889-5265-7294v.3 [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Subordination and Intercreditor Agreement (FHFC) A-1 Vista Breeze 4889-5265-7294v.3 IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Subordination and Intercreditor Agreement or caused this Subordination and Intercreditor Agreement to be duly executed and delivered by their respective authorized representatives as of the date first set forth above. JUNIOR LENDER: WITNESS OR ATTEST: FLORIDA HOUSING FINANCE CORPORATION, a public corporation and a public body corporate and politic duly created and existing under the laws of the State of Florida ________________________________ Name: __________________________ By:_______________________________ Name: Title: ________________________________ Name: __________________________ STATE OF ________ COUNTY OF _______ The foregoing instrument was acknowledged before me by means of [ ] physical presence or [ ] online notarization this __ day of _______, 20__, by _____________________, as ____________________________ of the FLORIDA HOUSING FINANCE CORPORATION, a public corporation and a public body corporate and politic duly created and existing under the laws of the State of Florida, on behalf of Florida Housing. Said person is personally known to me or has produced a valid driver’s license as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (FHFC) 2 Vista Breeze 4889-5265-7294v.3 SENIOR LENDER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ CITIBANK, N.A., By: ___________ Name: Title: Deal ID No. 60001596 ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ________________, as ________________ of Citibank., N.A.. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (FHFC) 3 Vista Breeze 4889-5265-7294v.3 ACKNOWLEDGED AND AGREED AS OF THE DATE FIRST SET FORTH ABOVE: BORROWER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: Name: Title: ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ___________________, as ___________ of APC Vista Breeze, LLC, a Florida limited liability company, a duly authorized signatory of Vista Breeze, Ltd., a Florida limited partnership. Said person is personally known to me or has produced a valid driver's license as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (FHFC) A-1 Vista Breeze 4889-5265-7294v.3 EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. Subordination and Intercreditor Agreement (FHFC) B-1 Vista Breeze 4889-5265-7294v.3 EXHIBIT B JUNIOR LOAN DOCUMENTS Viability Loan 1. Land Use Restriction Agreement. 2. Promissory Note. 3. Leasehold Mortgage and Security Agreement. 4. Assignment of Leases, Rents and Contract Rights. 5. Construction Loan Agreement. 6. Environmental Indemnity Agreement. 7. Compliance Monitoring and Servicing Agreement. 8. Continuing, Absolute and Unconditional Guaranty of Recourse Obligations. 9. Completion and Operating Deficit Guaranty. 10. Further Assurance Agreement. 11. Assignment of Management and Service Contracts. 12. Adverse Change Certificate of Borrower. 13. Affidavit of No Liens and Possession. 14. Anti-Coercion Statement. 15. Assignment of Permits, Agreements, Approvals, Fees and Deposits. 16. Business Purposes Affidavit. 17. Collateral Assignment of Construction Contract and Permits. 18. Flood Insurance Information and Insurance Acknowledgment. 19. Architect’s Agreement with Florida Housing Finance Corporation. 20. Assignment of Architect Agreement and Architect Plans and Specifications. 21. Consent to Assignment of Construction Contract. 22. Contractor’s Agreement with Florida Housing Finance Corporation. 23. Consent of Owner of Fee Title to Leasehold Mortgage and Security Agreement. 24. UCC-1 (State) 25. UCC-1 (County) SAIL Loan 1. Land Use Restriction Agreement. 2. Promissory Note. 3. Leasehold Mortgage and Security Agreement. 4. Assignment of Leases, Rents and Contract Rights. 5. Construction Loan Agreement. 6. Environmental Indemnity Agreement. 7. Compliance Monitoring and Servicing Agreement. 8. Continuing, Absolute and Unconditional Guaranty of Recourse Obligations. 9. Completion and Operating Deficit Guaranty. 10. Further Assurance Agreement. 11. Assignment of Management and Service Contracts. 12. Adverse Change Certificate of Borrower. 13. Affidavit of No Liens and Possession. Subordination and Intercreditor Agreement (FHFC) 2 Vista Breeze 4889-5265-7294v.3 14. Anti-Coercion Statement. 15. Assignment of Permits, Agreements, Approvals, Fees and Deposits. 16. Business Purposes Affidavit. 17. Collateral Assignment of Construction Contract and Permits. 18. Flood Insurance Information and Insurance Acknowledgment. 19. Architect’s Agreement with Florida Housing Finance Corporation. 20. Assignment of Architect Agreement and Architect Plans and Specifications. 21. Consent to Assignment of Construction Contract. 22. Contractor’s Agreement with Florida Housing Finance Corporation. 23. Consent of Owner of Fee Title to Leasehold Mortgage and Security Agreement. 24. UCC-1 (State) 25. UCC-1 (County) ELI Loan 1. Land Use Restriction Agreement. 2. Promissory Note. 3. Leasehold Mortgage and Security Agreement. 4. Assignment of Leases, Rents and Contract Rights. 5. Construction Loan Agreement. 6. Environmental Indemnity Agreement. 7. Compliance Monitoring and Servicing Agreement. 8. Continuing, Absolute and Unconditional Guaranty of Recourse Obligations. 9. Completion and Operating Deficit Guaranty. 10. Further Assurance Agreement. 11. Assignment of Management and Service Contracts. 12. Adverse Change Certificate of Borrower. 13. Affidavit of No Liens and Possession. 14. Anti-Coercion Statement. 15. Assignment of Permits, Agreements, Approvals, Fees and Deposits. 16. Business Purposes Affidavit. 17. Collateral Assignment of Construction Contract and Permits. 18. Flood Insurance Information and Insurance Acknowledgment. 19. Architect’s Agreement with Florida Housing Finance Corporation. 20. Assignment of Architect Agreement and Architect Plans and Specifications. 21. Consent to Assignment of Construction Contract. 22. Contractor’s Agreement with Florida Housing Finance Corporation. 23. Consent of Owner of Fee Title to Leasehold Mortgage and Security Agreement. 24. UCC-1 (State) 25. UCC-1 (County) NHTF Loan 1. Land Use Restriction Agreement. 2. Promissory Note. 3. Leasehold Mortgage and Security Agreement. 4. Assignment of Leases, Rents and Contract Rights. Subordination and Intercreditor Agreement (FHFC) 3 Vista Breeze 4889-5265-7294v.3 5. Construction Loan Agreement. 6. Environmental Indemnity Agreement. 7. Compliance Monitoring and Servicing Agreement. 8. Continuing, Absolute and Unconditional Guaranty of Recourse Obligations. 9. Completion and Operating Deficit Guaranty. 10. Further Assurance Agreement. 11. Assignment of Management and Service Contracts. 12. Adverse Change Certificate of Borrower. 13. Affidavit of No Liens and Possession. 14. Anti-Coercion Statement. 15. Assignment of Permits, Agreements, Approvals, Fees and Deposits. 16. Business Purposes Affidavit. 17. Collateral Assignment of Construction Contract and Permits. 18. Flood Insurance Information and Insurance Acknowledgment. 19. Architect’s Agreement with Florida Housing Finance Corporation. 20. Assignment of Architect Agreement and Architect Plans and Specifications. 21. Consent to Assignment of Construction Contract. 22. Contractor’s Agreement with Florida Housing Finance Corporation. 23. Consent of Owner of Fee Title to Leasehold Mortgage and Security Agreement. 24. UCC-1 (State) 25. UCC-1 (County) Subordination and Intercreditor Agreement (FHFC) C-1 Vista Breeze 4889-5265-7294v.3 EXHIBIT C MODIFICATIONS TO SUBORDINATION AND INTERCREDITOR AGREEMENT The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. D Forward Purchase Agreement Vista Breeze EXHIBIT D-15 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT (HACMB) [See attached] 4860-0474-2293v.3 THIS INSTRUMENT PREPARED BY: Aviva Yakren, Esq. Sidley Austin LLP 787 Seventh Avenue New York, New York 10019 RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: Citibank, N.A. Transaction and Asset Management Group/Post Closing Citi Community Capital 3800 Citibank Center Tampa, Florida 33610 Re: Vista Breeze Deal ID No. 60001596 ABOVE SPACE RESERVED FOR RECORDING PURPOSES ONLY EXHIBIT D-15 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT Subordination and Intercreditor Agreement (HACMB) Vista Breeze 4860-0474-2293v.3 EXHIBIT D-15 TO FORWARD PURCHASE AGREEMENT FORM OF SUBORDINATION AND INTERCREDITOR AGREEMENT THIS SUBORDINATION AND INTERCREDITOR AGREEMENT (this “Agreement”) dated as of the [_] day of [Month], 202[_], is made by and between HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH, a public body corporate and politic (“Junior Lender”) and CITIBANK, N.A., a national banking association (“Senior Lender”) and acknowledged by VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”). The date of this Agreement as set forth above is for reference purposes only, and this Agreement will not be effective and binding until the Conversion Date (as defined in the Original Borrower Loan Agreement (as hereinafter defined)). RECITALS: A. The Housing Authority of the City of Miami Beach, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Landlord”), is the legal owner of fee simple title to the Land (as defined in the Security Instrument (as hereinafter defined)) and pursuant to that certain Second Amended and Restated Ground Lease, dated as of December 15, 2023, between the Landlord and the Borrower, the Borrower is the holder of a leasehold interest in the Land. B. Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida (“Governmental Lender”), for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Florida, known as Vista Breeze (the “Mortgaged Property”). C. Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Bank of America, N.A., a national banking association (the “Original Funding Lender”), pursuant to which the Original Funding Lender made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan pursuant to that certain Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, (the “Original Borrower Loan Agreement”), by and between the Governmental Lender and the Borrower. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note, dated as of December 15, 2023 (the “Original Borrower Note”), made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of the Original Funding Lender. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, Subordination and Intercreditor Agreement (HACMB) 2 Vista Breeze 4860-0474-2293v.3 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”), which Original Security Instrument encumbers the Mortgaged Property. F. The Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were each assigned by Governmental Lender to Fiscal Agent for the benefit of Original Funding Lender to secure the Funding Loan. G. At the request of Borrower, the Borrower, Original Funding Lender and Senior Lender entered into that certain Forward Purchase Agreement, dated as of December 1, 2023, pursuant to which Senior Lender agreed to acquire Original Funding Lender’s interests in the Funding Loan and Funding Loan Documents (as defined in the Original Funding Loan Agreement) upon satisfaction of the terms and conditions set forth therein (the “Loan Purchase Conditions”). H. Insofar as the Loan Purchase Conditions have been satisfied or waived, the Borrower Loan has converted into a permanent loan (the “Senior Loan”), and in connection therewith, (i) Senior Lender has agreed to enter into a certain Amended and Restated Funding Loan Agreement, dated as of the date hereof (the “Funding Loan Agreement”), by and among Governmental Lender, Fiscal Agent, and Senior Lender, which amends and restates the Original Funding Loan Agreement; (ii) Borrower and Governmental Lender have entered into an Amended and Restated Borrower Loan Agreement, dated as of the date hereof (the “Borrower Loan Agreement”), which amends and restates the Original Borrower Loan Agreement; (iii) Borrower has executed and delivered an Amended and Restated Multifamily Note, dated as of [_], 202[_], in the principal amount of $[11,875,000][NOTE: AS MAY BE INCREASED PER THE EARN- OUT] (the “Borrower Note”), which amends and restates the Original Borrower Note; (iv) Borrower has executed and delivered an Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) executed and delivered by Borrower and dated as of the date hereof (the “Security Instrument”), which amends and restates the Original Security Instrument; and (v) Senior Lender and Borrower have entered into a certain the Loan Covenant Agreement executed and delivered by Borrower and dated as of the date hereof (the “Loan Covenant Agreement”). I. Borrower has executed and delivered to Junior Lender a Promissory Note (the “Junior Note”) dated as of December 15, 2023, evidencing a total debt owed to Subordinate Lender in the original principal amount of $8,800,000 (the “Junior Obligation”), which Junior Obligation is subject to the terms and conditions of that certain Note Covenant Agreement, dated as of December 15, 2023, by and between Borrower and Junior Lender (the “HACMB Agreement”), and secured by the Junior Security Instrument (as hereinafter defined) encumbering the Property. J. As a condition to the making of the Senior Loan, Senior Lender requires that Junior Lender execute and deliver this Agreement prior to the making of the Junior Obligation and the granting of the Junior Security Instrument by Borrower. NOW, THEREFORE, for Ten Dollars ($10.00) and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, and to induce the making of the Subordination and Intercreditor Agreement (HACMB) 3 Vista Breeze 4860-0474-2293v.3 Senior Loan and to induce Senior Lender to consent to the Junior Obligation and the Junior Security Instrument, Junior Lender hereby agrees as follows: 1. Definitions. Capitalized terms used but not defined in this Agreement shall have the meanings ascribed thereto in the Senior Security Instrument. As used in this Agreement, the terms set forth below shall have the respective meanings indicated: “Bankruptcy Proceeding” means any bankruptcy, reorganization, insolvency, composition, restructuring, dissolution, liquidation, receivership, assignment for the benefit of creditors, or custodianship action or proceeding under any federal or state law with respect to Borrower, any guarantor of any of the Senior Indebtedness, any of their respective properties, or any of their respective partners, members, officers, directors, or shareholders. “Casualty” means the occurrence of damage to or loss of any of the Property by fire or other casualty. “Condemnation” means any proposed or actual condemnation or other taking, or conveyance in lieu thereof, of all or any part of the Property, whether direct or indirect. “Enforcement Action” means any exercise of any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Documents, including, without limitation, any of the following: (i) the acceleration of all or any part of the Junior Indebtedness, (ii) the commencement of any judicial or non-judicial action or proceeding to enforce any obligation of Borrower under any of the Junior Documents, collect any monies payable to Borrower or have a receiver appointed to collect any monies payable to Borrower, or foreclose the lien(s) created by the Junior Security Instrument, (iii) the filing or joining in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower, (iv) the advertising of or commencement of any foreclosure or trustee’s sale proceedings, (v) the exercise of any power of sale, (vi) the acceptance of a deed or assignment in lieu of foreclosure or sale, (vii) the collecting of Rents, (viii) the obtaining of or seeking of the appointment of a receiver, (ix) the seeking of default interest, (x) the taking of possession or control of any of the Property, (xi) the commencement of any suit or other legal, administrative, or arbitration proceeding based upon the Junior Note or any other of the Junior Documents, (xii) the exercising of any banker’s lien or rights of set-off or recoupment, or (xiii) the taking of any other enforcement action against Borrower, any other party liable for any of the Junior Indebtedness or obligated under any of the Junior Documents, or the Property. “Enforcement Action Notice” means a written notice from Junior Lender to Senior Lender, given following a Junior Default and the expiration of any notice or cure periods provided for such Junior Default in the Junior Documents, setting forth in reasonable detail the Enforcement Action proposed to be taken by Junior Lender. “Junior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Junior Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. Subordination and Intercreditor Agreement (HACMB) 4 Vista Breeze 4860-0474-2293v.3 “Junior Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Junior Security Instrument. “Junior Documents” means, collectively, the Junior Note, the Junior Security Instrument, and all other documents evidencing, securing or delivered in connection with the Junior Obligation, all of which are listed on Exhibit B attached hereto, together with such modifications, amendments and supplements thereto as are approved in writing by Senior Lender prior to their execution. “Junior Security Instrument” means, collectively, that certain Open-End Leasehold Mortgage and Security Agreement, dated as of December 15, 2023, made by Borrower for the benefit of Junior Lender, as the same may from time to time be extended, consolidated, substituted for, modified, amended or supplemented upon receipt of the consent of Senior Lender. “Loss Proceeds” means all monies received or to be received under any insurance policy, from any condemning authority, or from any other source, as a result of any Condemnation or Casualty. “Property” means (i) the land and improvements known or to be known as Vista Breeze, located in the City of Miami Beach, Miami-Dade County, State of Florida, which Property is more particularly described on Exhibit A attached hereto, and (ii) all furniture, fixtures and equipment located at such apartments and other property, accounts, deposits and rights and interests of Borrower encumbered by the Senior Security Instrument and/or the other Senior Loan Documents. “Senior Indebtedness” means all indebtedness of any kind at any time evidenced or secured by, or arising under, the Senior Loan Documents, whether incurred, arising or accruing before or after the filing of any Bankruptcy Proceeding. “Senior Loan Default” means any act, failure to act, event, condition, or occurrence which constitutes, or which with the giving of notice or the passage of time, or both, would constitute, an “Event of Default” as defined in the Senior Security Instrument. “Senior Loan Documents” means, collectively, the Senior Security Instrument, the Senior Note, the Borrower Loan Agreement and all of the other documents, instruments and agreements now or hereafter evidencing, securing or otherwise executed in connection with the Senior Loan, as the same may from time to time be extended, consolidated, substituted for, modified, increased, amended and supplemented in accordance with the provisions of this Agreement. 2. Junior Obligation and Junior Documents are Subordinate; Acts by Senior Lender do not Affect Subordination. (a) Junior Lender hereby covenants and agrees on behalf of itself and its successors and permitted assigns that the Junior Indebtedness is and shall at all times continue to be, subordinate, subject and inferior (in payment and priority) to the prior payment in full of the Senior Indebtedness, except as set forth in the Junior Note and that the liens, rights, payment interests, priority interests and security interests granted to Junior Lender in connection with the Junior Obligation and under the Junior Documents are, and Subordination and Intercreditor Agreement (HACMB) 5 Vista Breeze 4860-0474-2293v.3 are hereby expressly acknowledged to be in all respects and at all times, subject, subordinate and inferior in all respects to the liens, rights, payment, priority and security interests granted to Senior Lender under the Senior Loan and the Senior Loan Documents and the terms, covenants, conditions, operations and effects thereof, except as set forth in the Junior Note. (b) Except as expressly set forth herein, repayment of the Junior Indebtedness, is and shall be postponed and subordinated to repayment in full of the Senior Loan. Prior to a Senior Loan Default (regardless of whether such Senior Loan Default occurs prior to or during the pendency of a Bankruptcy Proceeding), Junior Lender shall be entitled to receive and retain payments made pursuant to and in accordance with the terms of the Junior Documents; provided, however, that no such payment is made more than ten (10) days in advance of the due date thereof. Junior Lender agrees that from and after such time as it has received from either Senior Lender or Borrower written notice that a Senior Loan Default then exists (which has not been expressly waived in writing by Senior Lender) or otherwise has actual knowledge of such a Senior Loan Default, Junior Lender shall not receive or accept any payments under the Junior Obligation. If (i) Junior Lender receives any payment, property, or asset of any kind or in any form on account of the Junior Indebtedness (including, without limitation, any proceeds from any Enforcement Action) after a Senior Loan Default of which Junior Lender has actual knowledge or has been given notice of, or (ii) Junior Lender receives, voluntarily or involuntarily, by operation of law or otherwise, any payment, property, or asset in or in connection with any Bankruptcy Proceeding, such payment, property, or asset will be received and held in trust for Senior Lender. Junior Lender will promptly remit, in kind and properly endorsed as necessary, all such payments, properties, and assets to Senior Lender. Senior Lender shall apply any payment, asset, or property so received from Junior Lender to the Senior Indebtedness in such order, amount (with respect to any asset or property other than immediately available funds), and manner as Senior Lender shall determine in its sole and absolute discretion. (c) Without limiting the complete subordination of the Junior Indebtedness to the payment in full of the Senior Indebtedness, in any Bankruptcy Proceeding, upon any payment or distribution (whether in cash, property, securities, or otherwise) to creditors (i) the Senior Indebtedness shall first be paid in full in cash before Junior Lender shall be entitled to receive any payment or other distribution on account of or in respect of the Junior Indebtedness, and (ii) until all of the Senior Indebtedness is paid in full in cash, any payment or distribution to which Junior Lender would be entitled but for this Agreement (whether in cash, property, or other assets) shall be made to Senior Lender. (d) The subordination of the Junior Indebtedness shall continue in the event that any payment under the Senior Loan Documents (whether by or on behalf of Borrower, as proceeds of security or enforcement of any right of set-off or otherwise) is for any reason repaid or returned to Borrower or its insolvent estate, or avoided, set aside or required to be paid to Borrower, a trustee, receiver or other similar party under any bankruptcy, insolvency, receivership or similar law. In such event, the Senior Indebtedness or part thereof originally intended to be satisfied shall be deemed to be reinstated and outstanding to the extent of any repayment, return, or other action, as if such payment on account of the Senior Indebtedness had not been made. Subordination and Intercreditor Agreement (HACMB) 6 Vista Breeze 4860-0474-2293v.3 (e) The subordination of the Junior Documents and of the Junior Indebtedness shall apply and continue notwithstanding (i) the actual date and time of execution, delivery, recording, filing or perfection of the Senior Security Instrument and other Senior Loan Documents and of the Junior Security Instrument and other Junior Documents, and (ii) the availability of any collateral to Senior Lender, including the availability of any collateral other than the Property. (f) By reason of, and without in any way limiting, the full subordination of the Junior Indebtedness and the Junior Documents provided for in this Agreement, all rights and claims of Junior Lender under the Junior Security Instrument or under the Junior Documents in or to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto, are expressly subject and subordinate in all respects to the rights and claims of Senior Lender under the Senior Loan Documents in and to the Property or any portion thereof, the proceeds thereof, the Leases thereof, the Rents, issues and profits therefrom, and the Loss Proceeds payable with respect thereto. (g) If Junior Lender, in its capacity as lender, by indemnification, subrogation or otherwise, shall acquire any lien, estate, right or other interest in any of the Property, that lien, estate, right or other interest shall be fully subject and subordinate to the receipt by Senior Lender of payment in full of the Senior Indebtedness, and to the Senior Loan Documents, to the same extent as the Junior Indebtedness and the Junior Documents are subordinate pursuant to this Agreement. (h) In confirmation, and not as a condition, of the subordination of the Junior Indebtedness and the Junior Documents provided for in this Agreement, Junior Lender shall place on or attach to the Junior Note a notice to the following effect, and shall provide Senior Lender with a copy of the Junior Note showing such notice: “The indebtedness evidenced by this Note is and shall be subordinate in right of payment, to the extent and in the manner provided in the Subordination Agreement (as defined herein), to the prior payment in full of all amounts then due and payable (including, but not limited to, all amounts due and payable by virtue of any default or acceleration or upon maturity) with respect to the indebtedness evidenced by the Note (as defined by that certain Amended and Restated Multifamily Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (Florida) by the Borrower in favor of Governmental Lender and assigned to The Bank of New York Mellon Trust Company, N.A., a national banking association, in the original maximum principal amount of $[11,875,000] [NOTE: AS MAY BE INCREASED PER THE EARN-OUT]) to the extent and in the manner provided in that certain Subordination and Intercreditor Agreement, dated as of [_____], 20[_], between Citibank, N.A. (“Senior Lender”) and the holder of this Note (the “Subordination Agreement”). The rights and remedies of the payee and each subsequent holder of this Note shall be deemed, by virtue of such holder’s acquisition of this Note, to have agreed to perform and observe all of the terms, covenants and conditions to be Subordination and Intercreditor Agreement (HACMB) 7 Vista Breeze 4860-0474-2293v.3 performed or observed by the “Junior Lender” under the Subordination Agreement.” (i) Junior Lender hereby acknowledges and agrees that Senior Lender may, without the consent or approval of Junior Lender, agree with Borrower to extend, consolidate, modify, increase or amend any or all the Senior Loan Documents and otherwise act or fail to act with respect to any matter set forth in any Senior Loan Document (including, without limitation, the exercise of any rights or remedies, waiver, forbearance or delay in enforcing any rights or remedies, the declaration of acceleration, the declaration of defaults or events of default, the release, in whole or in part, of any collateral or other property, and any consent, approval or waiver), and all such extensions, consolidations, modifications, amendments acts and omissions shall not release, impair or otherwise affect Junior Lender’s obligations and agreements hereunder. 3. Junior Lender Agreements. (a) Without the prior written consent of Senior Lender in each instance, Junior Lender shall not (i) amend, modify, waive, extend, renew or replace any provision of any of the Junior Documents, or (ii) pledge, assign, transfer, convey, or sell any interest in the Junior Indebtedness or any of the Junior Documents; or (iii) accept any payment on account of the Junior Indebtedness other than a regularly scheduled payment of interest or principal and interest made not earlier than ten (10) days prior to the due date thereof; or (iv) take any action which has the effect of increasing the Junior Indebtedness; or (v) appear in, defend or bring any action in connection with the Property; or (vi) take any action concerning environmental matters affecting the Property. Regardless of any contrary provision in the Junior Documents, Junior Lender shall not collect payments for the purpose of escrowing for any cost or expense related to the Property or for any portion of the Junior Indebtedness. (b) Junior Lender hereby agrees that Senior Lender may, at its option (but without any obligation to do so), at any time (including during the pendency of a Bankruptcy Proceeding), purchase the Junior Obligation at par (and without liability for any prepayment premiums or liquidated damages set forth in the Junior Documents). Such transfer and assignment of the Junior Obligation shall be without representation or recourse, except that Junior Lender shall represent that it is the sole holder of the Junior Obligation, that it has authority to assign and convey the Junior Documents, that, to the best of its knowledge, there are no defaults or breaches under the Junior Documents, and as to the total amount then outstanding under the Junior Obligation. Junior Lender shall give Senior Lender a concurrent copy of each notice of a Junior Default, Enforcement Action Notice or other material notice given by Junior Lender under the Junior Documents. Notwithstanding any contrary provision in the Junior Documents, Senior Lender shall have the right, but shall not have any obligation, to cure any Junior Default until ninety (90) days following Senior Lender’s receipt of an Enforcement Action Notice given by Junior Lender as a consequence of the Junior Default. Senior Lender shall not be subrogated to the rights of Junior Lender under the Junior Documents by reason of Senior Lender having cured any Junior Default. However, Junior Lender acknowledges that all amounts advanced or Subordination and Intercreditor Agreement (HACMB) 8 Vista Breeze 4860-0474-2293v.3 expended by Senior Lender to cure a Junior Default shall be added to and become a part of the Senior Indebtedness pursuant to the terms of the Senior Security Instrument. (c) In the event and to the extent that each of Senior Lender and Junior Lender have under their respective loan documents certain approval or consent rights over the same subject matters (regardless of whether the obligations or rights are identical or substantially identical), Junior Lender agrees that Senior Lender shall exercise such approval rights on behalf of both Senior Lender and Junior Lender, and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby. Without limiting the generality of the foregoing, Senior Lender shall have all approval, consent and oversight rights in connection with any insurance claims relating to the Property, any decisions regarding the use of insurance proceeds after a casualty loss or condemnation awards, the hiring or firing of property managers, or otherwise related in any way to the Property, and Junior Lender shall have no right to object to any such action or approval taken by Senior Lender and shall consent thereto and be bound thereby. (d) Junior Lender agrees that in any action commenced to enforce the obligation of Borrower to pay any portion of the Junior Indebtedness, the judgment shall not be enforceable personally against Borrower or Borrower’s assets, and the recourse of Junior Lender for the collection of the Junior Indebtedness shall be limited to actions against the Property and the rents, profits, issues, products, and income from the Property. (e) Junior Lender shall not commence or join with any other creditor in commencing any Bankruptcy Proceeding involving Borrower, and Junior Lender shall not initiate and shall not be a party to any action, motion or request, in a Bankruptcy Proceeding involving any other person or entity, which seeks the consolidation of some or all of the assets of Borrower into such Bankruptcy Proceeding. In the event of any Bankruptcy Proceeding relating to Borrower or the Property or, in the event of any Bankruptcy Proceeding relating to any other person or entity into which (notwithstanding the covenant in the first sentence of this clause) the assets or interests of Borrower are consolidated, then in either event, the Senior Loan shall first be paid in full before Junior Lender shall be entitled to receive and retain any payment or distribution in respect to the Junior Obligation. Junior Lender agrees that (i) Senior Lender shall receive all payments and distributions of every kind or character in respect of the Junior Obligation to which Junior Lender would otherwise be entitled, but for the subordination provisions of this Agreement (including without limitation, any payments or distributions during the pendency of a Bankruptcy Proceeding involving Borrower or the Property), and (ii) the subordination of the Junior Obligation and the Junior Documents shall not be affected in any way by Senior Lender electing, under Section 1111(b) of the federal bankruptcy code, to have its claim treated as being a fully secured claim. In addition, Junior Lender hereby covenants and agrees that, in connection with a Bankruptcy Proceeding involving Borrower, neither Junior Lender nor any of its affiliates shall (i) make or participate in a loan facility to or for the benefit of Borrower on a basis that is senior to or pari passu with the liens and interests held by Senior Lender pursuant to the Senior Loan Documents, (ii) not vote affirmatively in favor of any plan of reorganization or liquidation unless Senior Lender has also voted affirmatively in favor of such plan, and (iii) not contest the continued accrual of interest on the Senior Subordination and Intercreditor Agreement (HACMB) 9 Vista Breeze 4860-0474-2293v.3 Indebtedness, in accordance with and at the rates specified in the Senior Loan Documents, both for periods before and for periods after the commencement of such Bankruptcy Proceedings. Junior Lender shall execute and deliver to Senior Lender powers of attorney, assignments or other instruments, as may be requested by Senior Lender in order to enable it to exercise the above-described authority or powers with respect to any or all of the Junior Documents, and to collect and receive any and all payments or distributions which may be payable or deliverable at any time upon or with respect to any of the Junior Documents to Junior Lender. (f) Junior Lender covenants and agrees that the effectiveness of this Agreement and the rights of Senior Lender hereunder shall be in no way impaired, affected, diminished or released by any renewal or extension of the time of payment of the Senior Loan, provided for in this Agreement, by any delay, forbearance, failure, neglect or refusal of Senior Lender in enforcing payment thereof or in enforcing the lien of or attempting to realize upon the Senior Loan Documents or any other security which may have been given or may hereafter be given for the Senior Loan, by any waiver or failure to exercise any right or remedy under the Senior Loan Documents, or by any other act or failure to act by Senior Lender. Junior Lender acknowledges that Senior Lender, at its sole option, may release all or any portion of the Property from the lien of the Senior Security Instrument, and may release or waive any guaranty, surety or indemnity providing additional collateral to Senior Lender, and Junior Lender hereby waives any legal or equitable right in respect of marshaling it might have in connection with any such release of all or any portion of the Property by Senior Lender. Senior Lender may pursue all rights and remedies available to it under the Senior Loan Documents, at law, or in equity, regardless of any Enforcement Action by Junior Lender. At any time or from time to time and any number of times, without notice to Junior Lender and without affecting the liability of Junior Lender, (a) the time for Borrower’s performance of or compliance with any covenant or agreement contained in the Senior Loan Documents, whether presently existing or hereinafter entered into, may be extended or such performance or compliance may be waived; (b) the maturity of the Senior Indebtedness may be accelerated as provided in the Senior Loan Documents; and (c) any security for the Senior Indebtedness may be modified, exchanged, surrendered or otherwise dealt with or additional security may be pledged or mortgaged for the Senior Indebtedness. If, after the occurrence of a Senior Loan Default, Senior Lender acquires title to any of the Property pursuant to a mortgage foreclosure conducted in accordance with applicable law, the lien, operation, and effect of the Junior Security Instrument and other Junior Loan Documents automatically shall terminate with respect to such Property upon Senior Lender’s acquisition of title. (g) Junior Lender acknowledges that it entered into the transactions contemplated by the Junior Documents and made the Junior Obligation to Borrower without reliance upon any information or advice from Senior Lender. Junior Lender made its own underwriting analysis in connection with the Junior Obligation, its own credit review of Borrower, and investigated all matters pertinent, in Junior Lender’s judgment, to its determination to make the Junior Obligation to Borrower. Junior Lender acknowledges that it is a sophisticated, experienced commercial lender, and was represented by competent counsel in connection with this Agreement. Subordination and Intercreditor Agreement (HACMB) 10 Vista Breeze 4860-0474-2293v.3 (h) Junior Lender hereby further represents and warrants that: (i) Junior Lender is now the owner and holder of the Junior Documents; (ii) the Junior Documents are now in full force and effect; (iii) the Junior Documents have not been modified or amended; (iv) no default or event which, with the passing of time or giving of notice would constitute a default, under the Junior Documents has occurred; (v) the current outstanding principal balance of the Junior Indebtedness is $[_]; (vi) no scheduled monthly payments under the Junior Documents have been or will be prepaid except with the prior written consent of Senior Lender; (vii) none of the rights of Junior Lender under any of the Junior Documents are subject to the rights of any third parties, by way of subrogation, indemnification or otherwise; and (viii) there are no other Junior Documents other than those listed on Exhibit B hereto. Borrower further represents and warrants that it has provided to Senior Lender a true, complete, and correct copy of all the Junior Documents. 4. Standstill Agreement; Right to Cure Senior Loan Default. (a) Until such time as any of the Senior Indebtedness has been repaid in full and the Senior Security Instrument has been released and discharged, Junior Lender shall not without the prior written consent of Senior Lender, take any Enforcement Action, including, without limitation, (i) accelerate the Junior Obligation, (ii) exercise any of Junior Lender’s remedies under the Junior Security Instrument or any of the other Junior Documents (including, without limitation, the commencement of any judicial or non- judicial action or proceeding (a) to enforce any obligation of Borrower under any of the Junior Documents, (b) to collect any monies payable to Borrower, (c) to have a receiver appointed to collect any monies payable to Borrower; or (d) to foreclose the lien(s) created by the Junior Security Instrument) or (iii) file or join in the filing of any involuntary Bankruptcy Proceeding against Borrower or any person or entity which owns a direct or indirect interest in Borrower; provided, however, that such limitation on the remedies of Junior Lender shall not derogate or otherwise limit Junior Lender’s rights, following an event of default under the Junior Documents to (a) compute interest on all amounts due and payable under the Junior Obligation at the default rate described in the Junior Documents, (b) compute prepayment premiums and late charges, and (c) enforce against any person, other than Borrower and any guarantors or indemnitors under the Senior Loan Documents, any guaranty of the obligations of Borrower under the Junior Obligation. (b) Senior Lender shall, simultaneously with the sending of any notice of a Senior Loan Default to Borrower, send to Junior Lender a copy of said notice under the Senior Loan Documents; provided, however, failure to do so shall not affect the validity of such notice or any obligation of Borrower to Senior Lender and shall not affect the relative priorities between the Senior Loan and the Junior Obligation as set forth herein. Borrower covenants and agrees to forward to Junior Lender, within three (3) business days of Borrower’s receipt thereof, a copy of any notice of a Senior Loan Default Borrower receives from Senior Lender. (c) Junior Lender shall have the right, but shall have no obligation, to cure any Senior Loan Default; provided, if Junior Lender shall elect to cure any such Default, it shall so notify Senior Lender and shall commence and complete such curing within any applicable notice or grace period, if any, as Borrower is permitted by the terms of the Senior Subordination and Intercreditor Agreement (HACMB) 11 Vista Breeze 4860-0474-2293v.3 Loan Documents to cure such Senior Loan Default. Junior Lender shall not be subrogated to the rights of Senior Lender under the Senior Loan Documents by reason of Junior Lender having cured any Senior Loan Default. However, Senior Lender acknowledges that, to the extent so provided in the Junior Documents, amounts advanced or expended by Junior Lender to cure a Senior Loan Default may be added to and become a part of the Junior Indebtedness. (d) Junior Lender agrees that, notwithstanding any contrary provision contained in the Junior Documents, a Senior Loan Default shall not constitute a default under the Junior Documents if no other default occurred under the Junior Documents. (e) Junior Lender acknowledges that any conveyance or other transfer of title to the Property pursuant to a foreclosure of the Junior Security Instrument (including a conveyance or other transfer of title pursuant to the exercise of a power of sale contained in the Junior Security Instrument), or any deed or assignment in lieu of foreclosure or similar arrangement, shall be subject to the transfer provisions of the Senior Loan Documents; and the person (including Junior Lender) who acquires title to the Property pursuant to the foreclosure proceeding (or pursuant to the exercise of a power of sale contained in the Junior Security Instrument) shall not be deemed to be automatically approved by Senior Lender. 5. Insurance. Junior Lender agrees that all original policies of insurance required pursuant to the Senior Security Instrument shall be held by Senior Lender. The preceding sentence shall not preclude Junior Lender from requiring that it be named as a loss payee, as its interest may appear, under all policies of property damage insurance maintained by Borrower with respect to the Property, provided such action does not affect the priority of payment of the proceeds of property damage insurance under the Senior Security Instrument, or that it be named as an additional insured under all policies of liability insurance maintained by Borrower with respect to the Property. 6. Default. Junior Lender and Borrower acknowledge and agree that a default by either such party under this Agreement shall, at the sole option of Senior Lender, constitute a default under the Senior Loan Documents. Each party hereto acknowledges that in the event any party fails to comply with its obligations hereunder, the other parties shall have all rights available at law and in equity, including the right to obtain specific performance of the obligations of such defaulting party and injunctive relief. No failure or delay on the part of any party hereto in exercising any right, power or remedy hereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any such right, power or remedy preclude any other or further exercise thereof or the exercise of any other right, power or remedy hereunder. 7. Enforcement Costs. Borrower and Junior Lender agree to reimburse Senior Lender for any and all costs and expenses (including reasonable attorneys’ fees) incurred by Senior Lender in connection with enforcing its rights against Junior Lender under this Agreement. 8. Notices. Any notice which any party hereto may be required or may desire to give hereunder shall be deemed to have been given and shall be effective only if it is in writing and (i) delivered personally, (ii) mailed, postage prepaid, by United State registered or certified mail, Subordination and Intercreditor Agreement (HACMB) 12 Vista Breeze 4860-0474-2293v.3 return receipts requested, (iii) delivered by overnight express courier or (iv) sent by telecopier, in each instance addressed as follows: To Junior Lender: With a copy to: Vista Breeze HACMB, Inc. c/o Housing Authority of the City of Miami Beach 200 Alton Road Miami Beach, FL 33139 Attention: Miguell Del Campillo, Executive Director Phone: (305) 532-6401, ext. 3020 Email: miguell@hacmb.org Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 Pittsburgh, PA 15219 Attention: Michael H. Syme, Esq. Email: msyme@foxrothschild.com Phone: (412) 391-2450 If to Senior Lender: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction Management Group Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 With a copy to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Re: Vista Breeze Deal ID No. 60001596 Facsimile: (805) 557-0924 With a copy to: Citibank, N.A. 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Account Specialist Re: Vista Breeze Deal ID No. 60001596 Facsimile: (212) 723-8209 And a copy of any notices of default sent to: Citibank, N.A. 388 Greenwich Street, 17th Floor New York, New York 10013 Attention: General Counsel’s Office Re: Vista Breeze Deal ID No. 60001596 Facsimile: (646) 291-5754 Subordination and Intercreditor Agreement (HACMB) 13 Vista Breeze 4860-0474-2293v.3 or at such other addresses or to the attention of such other persons as may from time to time be designated by the party to be addressed by written notice to the other in the manner herein provided. Notices, demands and requests given in the manner aforesaid shall be deemed sufficiently served or given for all purposes hereunder when received or when delivery is refused or when the same are returned to sender for failure to be called for. 9. WAIVER OF TRIAL BY JURY. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, EACH OF THE PARTIES HERETO (A) COVENANTS AND AGREES NOT TO ELECT A TRIAL BY JURY WITH RESPECT TO ANY ISSUE ARISING OUT OF THIS AGREEMENT OR THE RELATIONSHIP BETWEEN THE PARTIES THAT IS TRIABLE OF RIGHT BY A JURY AND (B) WAIVES ANY RIGHT TO TRIAL BY JURY WITH RESPECT TO SUCH ISSUE TO THE EXTENT THAT ANY SUCH RIGHT EXISTS NOW OR IN THE FUTURE. THIS WAIVER OF RIGHT TO TRIAL BY JURY IS SEPARATELY GIVEN BY EACH PARTY, KNOWINGLY AND VOLUNTARILY WITH THE BENEFIT OF COMPETENT LEGAL COUNSEL. 10. Term. The term of this Agreement shall commence on the date hereof and shall continue until the earliest to occur of the following events: (i) the payment of all of the principal of, interest on and other amounts payable under the Senior Loan Documents; (ii) the payment of all of the principal of, interest on and other amounts payable under the Junior Documents, other than by reason of payments which Junior Lender is obligated to remit to Senior Lender pursuant to the terms hereof; (iii) the acquisition by Senior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Senior Security Instrument; or (iv) the acquisition by Junior Lender of title to the Property pursuant to a foreclosure, or a deed in lieu of foreclosure, of (or the exercise of a power of sale contained in) the Junior Security Instrument, but only if such acquisition of title does not violate any of the terms of this Agreement. 11. Miscellaneous. (a) Junior Lender shall, within fifteen (15) business days following a request from Senior Lender, provide Senior Lender with a written statement setting forth the then current outstanding principal balance of the Junior Obligation, the aggregate accrued and unpaid interest under the Junior Obligation, and stating whether, to the knowledge of Junior Lender, any default or event of default exists under the Junior Obligation, and containing such other information with respect to the Junior Indebtedness as Senior Lender may require. Upon notice from Senior Lender from time to time, Junior Lender shall execute and deliver such additional instruments and documents, and shall take such actions, as are required by Senior Lender in order to further evidence or effectuate the provisions and intent of this Agreement. (b) This Agreement shall bind and inure to the benefit of all successors and assigns of Junior Lender and Senior Lender. Senior Lender may assign its interest in the Senior Loan Documents without notice to or consent of Junior Lender. Junior Lender may only assign its rights and interests hereunder following the prior written consent of Senior Lender, which consent may be withheld or conditioned in its sole and absolute discretion. Subordination and Intercreditor Agreement (HACMB) 14 Vista Breeze 4860-0474-2293v.3 (c) Senior Lender hereby consents to the Junior Obligation and the Junior Documents; provided, however, that this Agreement does not constitute an approval by Senior Lender of the terms of the Junior Documents. Junior Lender hereby consents to the Senior Loan and the Senior Loan Documents; provided, however, that this Agreement does not constitute an approval by Junior Lender of the terms of the Senior Loan Documents. (d) This Agreement may be executed in multiple counterparts, each of which shall constitute an original document and all of which together shall constitute one agreement. (e) IN ALL RESPECTS, INCLUDING, WITHOUT LIMITATION, MATTERS OF CONSTRUCTION AND PERFORMANCE OF THIS AGREEMENT AND THE OBLIGATIONS ARISING HEREUNDER, THIS AGREEMENT HAS BEEN ENTERED INTO AND DELIVERED IN, AND SHALL BE CONSTRUED IN ACCORDANCE WITH AND GOVERNED BY, THE LAWS OF THE STATE WHERE THE PROPERTY IS LOCATED, WITHOUT GIVING EFFECT TO ANY PRINCIPLES OF CONFLICTS OF LAW. (f) Time is of the essence in the performance of every covenant and agreement contained in this Agreement. (g) If any provision or remedy set forth in this Agreement for any reason shall be held to be invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provision or remedy of this Agreement and this Agreement shall be construed as if such invalid, illegal or unenforceable provision or remedy had never been set forth herein, but only to the extent of such invalidity, illegality or unenforceability. (h) Each party hereto hereby represents and warrants that this Agreement has been duly authorized, executed and delivered by it and constitutes a legal, valid and binding agreement enforceable in all material respects in accordance with its terms. (i) Borrower hereby acknowledges and consents to the execution of this Agreement, and agrees to be bound by the provisions hereof that are applicable to Borrower. Solely as between Senior Lender and Junior Lender, all of the signatories below hereby agree that to the extent of any conflict between the terms and provisions of this Agreement and the terms and provisions of the Senior Loan Documents and/or the Junior Documents respectively, the terms and provisions of this Agreement shall govern and control. By executing this Agreement in the place provided below, Borrower hereby (i) acknowledges the provisions hereof, (ii) agrees not to take any action inconsistent with Senior Lender’s rights or Junior Lender’s rights under this Agreement, (iii) waives and relinquishes to the maximum extent permitted by law any and all rights, defenses and claims now existing or hereinafter accruing relating to Junior Lender’s forbearance from exercising any rights and remedies pursuant to Section 4 of this Agreement, including, without limitation, any defenses based on the statute of limitations or any equitable defenses, such as laches, and (iv) acknowledges and agrees that (A) this Agreement is entered into for the sole protection and benefit of Senior Lender and Junior Lender (and Subordination and Intercreditor Agreement (HACMB) 15 Vista Breeze 4860-0474-2293v.3 their respective successors, assigns and participants), and no other person (including Borrower) shall have any benefits, rights or remedies under or by reason of this Agreement, (B) nothing in this Agreement is intended, or shall be construed to, relieve or discharge the obligations or liabilities of any third party (including Borrower under the Senior Loan Documents and the Junior Documents), (C) neither of them nor any of their affiliates shall be, or be deemed to be, beneficiaries of any of the provisions hereof or have any rights hereunder whatsoever, and (D) no provision of this Agreement is intended to, or shall be construed to, give any such third party (including Borrower) any right subrogating to the rights of, or action against, Senior Lender or Junior Lender. (j) No amendment, supplement, modification, waiver or termination of this Agreement shall be effective against any party unless such amendment, supplement, modification, waiver or termination is contained in a writing signed by such party. (k) No party other than Senior Lender and Junior Lender shall have any rights under, or be deemed a beneficiary of any of the provisions of, this Agreement. (l) Nothing herein or in any of the Senior Loan Documents or Junior Documents shall be deemed to constitute Senior Lender as a joint venturer or partner of Junior Lender. 12. Intentionally Omitted. 13. Attached Exhibits. The following Exhibits are attached to this Agreement and are incorporated by reference herein as if more fully set forth in the text hereof: Exhibit A – Legal Description Exhibit B – Junior Documents Exhibit C – Modifications to Subordination and Intercreditor Agreement The terms of this Agreement are modified and supplemented as set forth in said Exhibits. To the extent of any conflict or inconsistency between the terms of said Exhibits and the text of this Agreement, the terms of said Exhibits shall be controlling in all respects. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Subordination and Intercreditor Agreement (HACMB) A-1 Vista Breeze 4860-0474-2293v.3 IN WITNESS WHEREOF, the undersigned have duly executed and delivered this Subordination and Intercreditor Agreement or caused this Subordination and Intercreditor Agreement to be duly executed and delivered by their respective authorized representatives as of the date first set forth above. JUNIOR LENDER: WITNESS OR ATTEST: HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH, a public body corporate and politic ________________________________ Name: __________________________ By:_______________________________ Name: Title: ________________________________ Name: __________________________ STATE OF ________ COUNTY OF _______ The foregoing instrument was acknowledged before me by means of [ ] physical presence or [ ] online notarization this __ day of _______, 2023, by _____________________, as ____________________________ of Housing Authority of the City of Miami Beach, a public body corporate and politic. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (HACMB) 2 Vista Breeze 4860-0474-2293v.3 SENIOR LENDER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ CITIBANK, N.A., By: ___________ Name: Title: Deal ID No. 60001596 ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ________________, as ________________ of Citibank., N.A. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (HACMB) 3 Vista Breeze 4860-0474-2293v.3 ACKNOWLEDGED AND AGREED AS OF THE DATE FIRST SET FORTH ABOVE: BORROWER: WITNESS OR ATTEST: ______________________________ Name:_________________________ ______________________________ Name:_________________________ VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: Name: Title: ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ___________________, as ___________ of APC Vista Breeze, LLC, a Florida limited liability company, duly authorized signatory of Vista Breeze, Ltd., a Florida limited partnership. Said person is personally known to me or has produced a valid driver's license as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped): __________________ Title or Rank: Serial number (if any): Subordination and Intercreditor Agreement (HACMB) A-1 Vista Breeze 4860-0474-2293v.3 EXHIBIT A LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. Subordination and Intercreditor Agreement (HACMB) B-1 Vista Breeze 4860-0474-2293v.3 EXHIBIT B JUNIOR DOCUMENTS 1. Junior Note. 2. Junior Security Agreement. 2. The HACMB Agreement. Subordination and Intercreditor Agreement (HACMB) C-1 Vista Breeze 4860-0474-2293v.3 EXHIBIT C MODIFICATIONS TO SUBORDINATION AND INTERCREDITOR AGREEMENT The following modifications are made to the text of the Agreement that precedes this Exhibit: None. Capitalized terms used and not defined herein shall have the respective meanings ascribed to them in the Agreement. D Forward Purchase Agreement Vista Breeze EXHIBIT D-16 TO FORWARD PURCHASE AGREEMENT FORM OF INSURANCE ANTI-COERCION STATEMENT [See attached] EXHIBIT D-16 TO FORWARD PURCHASE AGREEMENT FORM OF INSURANCE ANTI-COERCION STATEMENT The following statement is required under Rule 69B-124.002 of the Florida Administrative Code, regarding rules promulgated by the Chief Financial Officer of the State of Florida relative to anti-coercion: The Insurance Laws of this state provide that a lender may not require its borrower to take insurance through any particular insurance agent or company to protect the mortgaged property. The borrower, subject to the rules adopted by the Chief Financial Officer, has the right to have the insurance placed with an insurance agent or company of its choice, provided the company meets the requirements of the lender. The lender has the right to designate reasonable financial requirements as to the company and the adequacy of the coverage. I have read the foregoing statement or the rules of the Chief Financial Officer relative thereto, and understand my rights and privileges and those of the lender relative to the placing of such insurance. I have selected [_] to write the hazard, general public liability, workmen’s compensation, and flood insurance covering the property described on Exhibit “A” attached hereto and made a part hereof. (Signature Page to Follow) Borrower: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: ________________________ Name: Title: Exhibit A Legal Description That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. 4867-3296-4746 D Forward Purchase Agreement Vista Breeze EXHIBIT D-17 TO FORWARD PURCHASE AGREEMENT FORM OF BUSINESS PURPOSES AFFIDAVIT [See attached] Business Purpose Affidavit Vista Breeze 4883-6194-4971v.4 EXHIBIT D(17) TO FORWARD PURCHASE AGREEMENT FORM OF BUSINESS PURPOSES AFFIDAVIT STATE OF FLORIDA COUNTY OF MIAMI-DADE BEFORE ME, the undersigned, a Notary Public in and for the County and State aforesaid, personally appeared [_] (“Affiant”) who, being first duly sworn, on oath, says: 1. That this Affidavit is given on the personal knowledge of Affiant. 2. Affiant is the [_] of APC Vista Breeze, LLC, a Florida limited liability company, the Class B limited partner of Vista Breeze, Ltd., a Florida limited partnership (the “Borrower”), and is authorized to make this Affidavit on behalf of the Borrower. 3. That Borrower is the owner of a leasehold estate in certain real property located in Miami-Dade County, Florida, which is more particularly described on Exhibit “A” attached hereto and made a part hereof. 4. That Citibank, N.A., a national banking association (“Lender”), has agreed to make a loan to Borrower in the principal amount of [ELEVEN MILLION EIGHT HUNDRED SEVENTY FIVE THOUSAND] and No/100 Dollars ($[11,875,000.00]) [NOTE: AS MAY BE INCREASED PER THE EARN-OUT] (the “Loan”). 5. That the Loan is to be made for business or commercial purposes only, not for personal, family or household purposes, and, specifically will be used for the development and rental of the real property to third parties. 6. That this Affidavit is made for the purpose of inducing Lender to make the Loan. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] Business Purpose Affidavit Vista Breeze S-1 4883-6194-4971v.4 [_], individually Affiant ACKNOWLEDGEMENT STATE OF ____________ COUNTY OF ____________ The foregoing instrument was acknowledged before me by means of ☐ physical presence or ☐ online notarization, this _____ day of _______________, 20___, by ___________, as _______________ of APC Vista Breeze, LLC, a Florida limited liability company, duly authorized signatory of Vista Breeze, Ltd., a Florida limited partnership. Said person is personally known to me or has produced _________________ as identification. [Notary Seal] Signature of person taking acknowledgment Name (typed, printed or stamped):_____________ Title or Rank: Serial number (if any): Business Purpose Affidavit Vista Breeze A-1 4883-6194-4971v.4 EXHIBIT “A” LEGAL DESCRIPTION That leasehold estate created by that Second Amended and Restated Ground Lease, by and between Vista Breeze, Ltd., a Florida limited partnership, and the Housing Authority of The City of Miami Beach, a public body corporate and politic, as evidenced by that Amended and Restated Memorandum of Lease to be recorded over the following described lands: PARCEL 1: LOT 3, 4 and 5, Block 55, OF NORMANDY GOLF COURSE, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 44, AT PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. PARCEL 2: LOTS 6, 7 and 8, BLOCK 56, NORMANDY GOLF COURSE SUBDIVISION, ACCORDING TO THE PLAT THEREOF RECORDED IN PLAT BOOK 44, PAGE 62, OF THE PUBLIC RECORDS OF MIAMI-DADE COUNTY, FLORIDA. D Forward Purchase Agreement Vista Breeze EXHIBIT D-18 TO FORWARD PURCHASE AGREEMENT FORM OF CONTINUING DISCLOSURE AGREEMENT [See attached] CONTINUING DISCLOSURE AGREEMENT by and between VISTA BREEZE, LTD, and CITIBANK, N.A. Dated as of ________ 1, 20__ Relating to: Loan in the amount of $____________ to Vista Breeze, LTD pursuant to an Amended and Restated Borrower Loan Agreement dated as of ________ 1, 20__ between Housing Finance Authority of Miami- Dade County, Florida and Vista Breeze, LTD, and a loan to the Housing Finance Authority of Miami-Dade County, Florida in the amount of $____________ pursuant to an Amended and Restated Funding Loan Agreement dated as of ________ 1, 20__ among Housing Finance Authority of Miami-Dade County, Florida and Citibank, N.A., as Funding Lender. CONTINUING DISCLOSURE AGREEMENT This CONTINUING DISCLOSURE AGREEMENT dated as of ________ 1, 20__ (this “Continuing Disclosure Agreement”) is executed and delivered by Vista Breeze, LTD, a Florida limited partnership (the “Borrower”), and Citibank, N.A., as Funding Lender (the “Funding Lender”). RECITALS 1. This Continuing Disclosure Agreement is being executed and delivered in connection with a loan (the “Borrower Loan”) made by the Housing Finance Authority of Miami-Dade County, Florida (the “Governmental Lender”) to the Borrower pursuant to a Construction Phase Borrower Loan Agreement, dated as of December 1, 2023, between the Governmental Lender, the Fiscal Agent and the Borrower (the “Construction Borrower Loan Agreement”) with the proceeds of a loan (the “Funding Loan”) from Bank of America, N.A. (“BOA”) to the Governmental Lender pursuant to a Funding Loan Agreement (Construction Phase), dated as of December 1, 2023, among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A. (“Fiscal Agent”) and BOA (the “Construction Funding Loan Agreement”). The proceeds of the Borrower Loan were used to finance the acquisition, construction and equipping of a multifamily rental housing development located at 175 S. Shore Drive and 280 S. Shore Drive, in the City of Miami Beach, Miami-Dade County, Florida known as Vista Breeze (the “Project”), and pay certain related costs. 2. The Funding Lender has purchased the Funding Loan from BOA in the outstanding amount of $[Perm Amount] pursuant to a Forward Purchase Agreement dated as of December 1, 2023 among the Funding Lender, the Borrower and BOA, and in connection with such purchase the Construction Funding Loan Agreement is being amended and restated in its entirety by the Amended and Restated Funding Loan Agreement dated as of _______ 1, 20__, among the Governmental Lender, the Fiscal Agent and the Funding Lender (the “Funding Loan Agreement”) and the Construction Borrower Loan Agreement is being amended and restated in its entirety by the Amended and Restated Borrower Loan Agreement dated as of _______ 1, 20__, between the Governmental Lender, the Fiscal Agent and the Borrower (the “Borrower Loan Agreement”). The Funding Lender is requiring the Borrower to enter into this Continuing Disclosure Agreement in connection with the Funding Lender’s purchase of the Funding Loan. 3. The parties acknowledge that the transaction is presently exempt from the continuing disclosure requirements of Rule 15c2-12 adopted by the Securities and Exchange Commission under the Securities and Exchange Act of 1934, as the same may be amended from time to time (the “Rule”) and that this Continuing Disclosure Agreement is not an undertaking pursuant to the Rule. Borrower and the Funding Lender are entering into this Continuing Disclosure Agreement as an agreement between the parties for the benefit of the Funding Lender and its successors and assigns, to provide disclosure in a manner consistent with the requirements of the Rule. The parties recognize and acknowledge that the Rule does not require such disclosure with respect to the Borrower Loan and the Funding Loan. In consideration of the mutual covenants and agreements in this Continuing Disclosure Agreement, the Borrower and the Funding Lender covenant and agree as follows: Section 1. Definitions. In addition to the definitions set forth in the Funding Loan Agreement, which apply to any capitalized term used in this Continuing Disclosure Agreement unless otherwise defined in this section and in the Recitals above, the following capitalized terms shall have the following meanings: 2 “Annual Financial Information” means, in the case of the Borrower, the financial information and operating data with respect to the Project, provided at least annually, of the type included in Exhibit A hereto, which Annual Financial Information may, but is not required to, include Audited Financial Statements. “Annual Report” means any annual report provided by the Borrower pursuant to, and as described in, Section 2 of this Continuing Disclosure Agreement. “Audited Financial Statements” means, in the case of the Borrower, the annual audited financial statements, if any. “Beneficial Owner” means the Funding Lender and any permitted transferees of an interest or interests in the Funding Loan pursuant to the Funding Loan Agreement and any person which (a) has the power, directly or indirectly, to vote or consent with respect to, or to dispose of ownership of, the Funding Loan or any interests in the Funding Loan (including persons holding the Funding Loan or any interests in the Funding Loan through nominees, depositories or other intermediaries), or (b) is treated as the owner of the Funding Loan or any interests in the Funding Loan for federal income tax purposes. “Financial Obligation” means (a) a debt obligation, (b) a derivative instrument entered into in connection with, or pledged as security or a source of payment for, an existing or planned debt obligation, or (c) a guarantee of (a) or (b). The term Financial Obligation shall not include municipal securities as to which a final official statement has been provided to the MSRB consistent with the Rule. “Listed Events” means any of the events listed in Section 3(a) of this Continuing Disclosure Agreement. “MSRB” means the Municipal Securities Rulemaking Board established pursuant to Section 15B(b)(1) of the Securities Exchange Act of 1934. All documents provided to the MSRB shall be in an electronic format and accompanied by identifying information, as prescribed by the MSRB. Initially, any documents submitted to the MSRB to effect compliance with this Continuing Disclosure Agreement shall use the MSRB’s Electronic Municipal Market Access (EMMA) system at www.emma.msrb.org. Section 2. Provision of Annual Reports. (a) The Borrower shall provide to the Funding Lender, not later than 150 days after the end of the Borrower’s fiscal year, commencing within 150 days following the end of the Borrower’s current fiscal year, the Annual Report of the Borrower containing the Annual Financial Information for the prior fiscal year. The Funding Lender may, but is not obligated to, provide a copy of such Annual Report to the MSRB. (b) Any or all of the items listed above may be included by specific reference to other documents, including official statements of debt issues with respect to which the Borrower or any affiliate is an “obligated person” (as defined by the Rule), which have been filed with the MSRB or the Securities and Exchange Commission. The Borrower shall clearly identify each such other document so included by reference. (c) In each case, the Annual Report may be submitted as a single document or as separate documents comprising a package, and may cross-reference other information as provided in this section; provided, that the financial statements of the Borrower may be submitted separately from the balance of the Annual Report and later than the date required above for the filing of the Annual Report if they are not available by that date. If the Borrower’s fiscal year changes, it shall give notice of such change in the same manner as for a Listed Event under Section 3(c). 3 Section 3. Reporting of Listed Events. (a) Pursuant to the provisions of this section, the Borrower shall give, or cause to be given, notice to the Funding Lender of the occurrence of any of the following events with respect to the Funding Loan (“Listed Events”): (i) principal and interest payment delinquencies; (ii) non-payment related defaults, if material; (iii) unscheduled draws on debt service reserves reflecting financial difficulty; (iv) unscheduled draws on credit enhancements reflecting financial difficulty; (v) substitution of credit or liquidity providers, or their failure to perform; (vi) adverse tax opinions, the issuance by the Internal Revenue Service of proposed or final determinations of taxability, Notices of Proposed Issue (IRS Form 5701-TEB) or other material notices or determinations with respect to the tax-exempt status of interest paid on the Governmental Lender Note, or other Listed Events affecting the tax-exempt status of interest paid on the Governmental Lender Note; (vii) modifications to rights of owners of any interest in the Funding Loan, if material; (viii) optional, contingent or unscheduled prepayments of the Borrower Loan or Funding Loan; (ix) defeasances of the Borrower Loan or Funding Loan; (x) release, substitution or sale of property securing repayment of the Borrower Loan or the Funding Loan, if material; (xi) rating changes with respect to the Borrower; (xii) bankruptcy, insolvency, receivership or similar event of the Borrower. For purposes of this clause (xii), any such event shall be considered to have occurred when any of the following occur: the appointment of a receiver, fiscal agent or similar officer for the Borrower in a proceeding under the U.S. Bankruptcy Code or in any other proceeding under state or federal law in which a court or governmental authority has assumed jurisdiction over substantially all of the assets or business of the Borrower, or the entry of an order confirming a plan of reorganization, arrangement or liquidation by a court or governmental authority having supervision or jurisdiction over substantially all of the assets or business of the Borrower; (xiii) the consummation of a merger, consolidation, or acquisition involving the Borrower or the sale of all or substantially all of the assets of the Borrower, other than in the ordinary course of business, the entry into a definitive agreement to undertake such an action or the termination of a definitive agreement relating to any such actions, other than pursuant to its terms, if material; and (xiv) appointment of a successor or additional trustee or paying agent or the change of the name of a trustee or paying agent, if material. 4 (xv) incurrence of a Financial Obligation of the Borrower, if material, or agreement to covenants, events of default, remedies, priority rights, or other similar terms of a Financial Obligation of the Borrower, any of which affect the holders of the Governmental Lender Note, if material; and (xvi) default, event of acceleration, termination event, modification of terms, or other similar events under the terms of a Financial Obligation of the Borrower, any of which reflect financial difficulties. (b) The Funding Lender may, but shall not be expected to, promptly after obtaining knowledge of the occurrence of any event that it believes may constitute a Listed Event, provide notice to the Borrower of the occurrence of such event, and request that the Borrower promptly notify the Funding Lender in writing pursuant to subsection (a). If in response to a request under this subsection (b), the Borrower determines that such event is not a Listed Event, the Borrower shall so notify the Funding Lender in writing and provide in writing the basis for such conclusion to the Funding Lender. (c) Whenever the Borrower obtains knowledge of the occurrence of a Listed Event, because of a notice from the Funding Lender pursuant to subsection (b) or otherwise, the Borrower shall promptly (and in any event within ten (10) Business Days of the occurrence of the Listed Event) notify the Funding Lender in writing pursuant to subsection (a) and include in such notice a description of the basis for its conclusion that a Listed Event has occurred. Section 4. Termination of Reporting Obligation. The Borrower’s obligations under this Continuing Disclosure Agreement shall terminate upon any legal defeasance of the Borrower Loan and the Funding Loan, prior prepayment or payment in full of all of the obligations of the Borrower under the Borrower Loan and all of the obligations of the Governmental Lender under the Funding Loan. If the Borrower’s obligations with respect to the Borrower Loan are assumed in full by some other entity, such person shall be responsible for compliance with this Continuing Disclosure Agreement in the same manner as if it were the Borrower and the Borrower shall have no further responsibility hereunder. The Borrower, in connection with such assumption, shall require the other entity to specifically assume in writing the obligations of the Borrower hereunder, which written instrument shall be filed with the Funding Lender. If such termination or substitution occurs prior to the final maturity of the Borrower Loan and the Funding Loan, the Borrower shall give notice of such termination or substitution in the same manner as for a Listed Event under Section 3(c). Section 5. Amendment; Waiver. (a) Notwithstanding any other provision of this Continuing Disclosure Agreement, the Borrower and the Funding Lender may amend this Continuing Disclosure Agreement and any provision of this Continuing Disclosure Agreement may be waived, provided that no waiver by the Funding Lender of any disclosure obligation of the Borrower hereunder with respect to a particular matter shall constitute a waiver or release of the Borrower from its disclosure obligations hereunder with respect to any other matters. (b) In the event of any amendment or waiver of a provision of this Continuing Disclosure Agreement, the Borrower shall describe such amendment in the next Annual Report and shall include, as applicable, a narrative explanation of the reason for the amendment or waiver and its impact on the type (or, in the case of a change of accounting principles, on the presentation) of financial information or operating data being presented by the Borrower. In addition, if the amendment relates to the accounting principles to be followed in preparing financial statements, (1) notice of such change shall be given in the same manner as for a Listed Event under Section 3(c), and (2) the Annual Report for the year in which the 5 change is made should present a comparison (in narrative form and also, if feasible, in quantitative form) between the financial statements as prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles. Section 6. Additional Information. Nothing in this Continuing Disclosure Agreement shall be deemed to prevent the Borrower from disseminating any other information, using the means of dissemination set forth in this Continuing Disclosure Agreement or any other means of communication, or including any other information in any Annual Report or notice of occurrence of a Listed Event, in addition to that which is required by this Continuing Disclosure Agreement. If the Borrower chooses to include any information in any Annual Report or notice of occurrence of a Listed Event, in addition to that which is specifically required by this Continuing Disclosure Agreement, the Borrower shall have no obligation under this Continuing Disclosure Agreement to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event. Section 7. Default. In the event of a failure of the Borrower to comply with any provision of this Continuing Disclosure Agreement, the Funding Lender may, or any Beneficial Owner of an interest or interests in the Funding Loan may as its sole and exclusive remedy seek specific performance by court order, to cause the Borrower, to comply with its obligations under this Continuing Disclosure Agreement. A default under this Continuing Disclosure Agreement shall not be deemed an event of default under the Funding Loan Agreement or the Borrower Loan Agreement, and the sole remedy under this Continuing Disclosure Agreement in the event of any failure of the Borrower to comply with this Continuing Disclosure Agreement shall be an action to compel performance. Section 8. Notices. All notices or other communications shall be sufficiently given and shall be deemed given on the date on which the same have been personally delivered or the second day following the date on which the same have been mailed by certified mail, return receipt requested, postage prepaid, addressed as follows: If to Borrower: Vista Breeze, Ltd. c/o Atlantic Pacific Communities, LLC 161 NW 6th Street, Suite 1020 Miami, Florida 33136 Attention: Kenneth Naylor and with a copy to: Klein Hornig LLP 1325 G. Street NW, Suite 770 Washington, DC 20005 Attention: Chris Hornig Email: chornig@kleinhornig.com Tel: (202) 926-3402 And with a copy to: Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A. (which copy shall not constitute notice to Borrower) 150 W. Flagler Street Miami, Florida 33130 Attention: Brian McDonough, Esq. Email: bmcdonough@stearnsweaver.com With a copy to: Housing Authority of the City of Miami Beach 200 Alton Road Miami Beach, FL 33139 Attention: Miguell Del Campillo, Executive Director 6 Phone: (305) 532-6401, ext. 3020 Email: miguell@hacmb.org With a copy to: Fox Rothschild LLP BNY Mellon Center 500 Grant Street, Suite 2500 Pittsburgh, PA 15219 Attention: Michael H. Syme Telephone: (412) 391-2450 Email: msyme@foxrothschild.com To the Funding Citibank, N.A. Lender: 388 Greenwich Street, Trading 4th Floor New York, New York 10013 Attention: Transaction and Asset Management Group Deal ID # 60001596 Facsimile: (212) 723-8209 And to: Citibank, N.A. 325 East Hillcrest Drive, Suite 160 Thousand Oaks, California 91360 Attention: Operations Manager/Asset Manager Deal ID # 60001596 Facsimile: (805) 557 0924 With a copy to: Citibank, N.A. c/o Berkadia Commercial Servicing Department 322 Norristown Road, Suite 300 Ambler, Pennsylvania 19002 Attention: Client Relations Manager Deal ID# 60001596 Facsimile: (215) 328-0305 And a copy of any Citibank, N.A., 17th Floor notices of default 388 Greenwich Street sent to: New York, New York 10013 Attention: General Counsel’s Office Deal ID # 60001596 Facsimile: (646) 291-5754 Any person may, by written notice to the other persons listed above, designate a different address or telephone number to which subsequent notices or communications should be sent. Section 9. Borrower’s Obligations Non-recourse. In any action or proceeding brought hereon and except as otherwise provided in the Security Instrument (as defined in the Borrower Loan Agreement) or the Borrower Loan Agreement, the liability of the Borrower under this Continuing Disclosure Agreement shall be limited to the Project and any other collateral securing the Borrower Loan or the Funding Loan. 7 Section 10. Beneficiaries. This Continuing Disclosure Agreement shall inure solely to the benefit of the Borrower, the Funding Lender and the Beneficial Owners from time to time of any interest or interests in the Funding Loan, and shall create no rights in any other person or entity. Section 11. Severability. If any provision in this Continuing Disclosure Agreement shall be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby. Section 12. Counterparts. This Continuing Disclosure Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. Section 13. Electronic Transactions. The transactions described in this Continuing Disclosure Agreement may be conducted and the related documents may be stored by electronic means. Copies, telecopies, facsimiles, electronic files and other reproductions of original executed documents shall be deemed to be authentic and valid counterparts of such original documents for all purposes, including the filing of any claim, action or suit in the appropriate court of law. Section 14. Governing Law. This Continuing Disclosure Agreement shall be governed by and construed in accordance with the laws of the State of Florida. [Remainder of this page intentionally left blank] IN WITNESS WHEREOF, the parties hereto have caused this Continuing Disclosure Agreement to be executed by their duly authorized representatives as of the date set forth above. VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, Duly Authorized By: _____________________________ Kenneth Naylor, Vice President [Signatures to the Vista Breeze Continuing Disclosure Agreement continued on following page] [Counterpart signature page to the Vista Breeze Continuing Disclosure Agreement] CITIBANK, N.A., as Funding Lender By: Name: Title: Deal ID #60001596 EXHIBIT A ANNUAL FINANCIAL INFORMATION $[Perm Amount] Housing Finance Authority of Miami-Dade County, Florida Multifamily Housing Revenue Note Series 2023 (Vista Breeze) Report for Period Ending Name: _________________________ Address: _________________________ Occupancy _________________________ Number of Units _________________________ Number of Units Occupied as of Report Date ________________________ Operating History of the Project[s] The following table sets forth a summary of the operating results of the Project for fiscal year ended ___________, as derived from the Borrower’s [un]audited financial statements. Revenues Operating Expenses1 Net Operating Income Debt Service on the Loan Net Operating Income/(Loss) After Debt Service The average occupancy of the Project[s] for the fiscal year ended [___] was [___]%. __________________________ 1Excludes depreciation and other non-cash expenses, includes management fee. E-1-1 Forward Purchase Agreement Vista Breeze EXHIBIT E-1 ASSIGNMENT AND ASSUMPTION RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: Citi Community Capital CCC Post-Closing Department 3800 Citibank Center Tampa, FL 33610 Re: Vista Breeze Deal ID No. 60001596 ASSIGNMENT AND ASSUMPTION OF MORTGAGE AND LOAN DOCUMENTS THIS ASSIGNMENT AND ASSUMPTION OF MORTGAGE AND LOAN DOCUMENTS (this “Assignment”) is executed by BANK OF AMERICA, N.A., a national banking association (“Initial Funding Lender”), THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., a national banking association (“Fiscal Agent”; and together with Initial Funding Lender, sometimes referred to herein as, collectively, the “Assignor”), in favor of the HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, a public body corporate and politic organized and existing under the laws of the State of Florida (“Assignee”). Capitalized terms used but not otherwise defined herein shall have the meanings given them in the Forward Purchase Agreement dated as of December 1, 2023 (the “Forward Purchase Agreement”) among Assignor, CITIBANK, N.A. (“Citi”) and VISTA BREEZE, LTD., a Florida limited partnership (the “Borrower”). FOR VALUABLE CONSIDERATION, the receipt of which is hereby acknowledged, Assignor and Assignee agree as follows: 1. Assignor hereby grants, assigns, conveys and transfers, without recourse, representation or warranty, to Assignee, and its successors and assigns, all right, title and interest of Assignor in and to the following: a. All of its right, title and interest in and to the Loan, as evidenced by that certain Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) (the “Governmental Lender Note”) in the maximum original principal amount of $32,500,000, the outstanding principal balance of which, as of the date hereof, is $_______________ (the “Note”); b. All of its right, title and interest in and to that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing (the “Original Security Instrument”) dated as of December 15, 2023 and executed by Borrower for the benefit of Assignee, as assigned to Assignor pursuant to that certain Assignment of Mortgage and Collateral Loan Documents, dated as of December 15, 2023 (collectively, the “Assignment”); E-1-2 Forward Purchase Agreement Vista Breeze c. The other documents described on Schedule I attached hereto, which sets forth all of the documents to be assigned to Assignee by Assignor (the “Assigned Documents”), including the foregoing instruments; d. Except for (i) that certain Environmental Indemnification and Release Agreement dated December 15, 2023 by and among Borrower, Howard D. Cohen, Howard D. Cohen Revocable Trust U/A/D 4/6/1993 and Initial Funding Lender, and (ii) the documents listed on Schedule II attached hereto (the “Terminated Documents”), all other instruments, and agreements, (other than documents, memos, notes or reports prepared by Assignor employees solely for the internal use of Assignor) affecting or relating to the Loan which were prepared and delivered to Assignor in connection with, or executed and delivered to Assignor in connection with or as security for, the Loan, including but not limited to any and all security agreements, collateral assignments, pledge agreements, financial agreements, corporate authorizations, limited liability company consents and other corporate or limited liability company documents (including any limited liability company consents or approvals by any member of Borrower), legal opinion letters from Borrower’s counsel, estoppel letters from Borrower or tenants of the Project, operating reports, environmental reports, site plans, surveys, soil and substrata studies, architectural drawings, plans and specifications, engineering plans and studies, floor plans, landscape plans, external written correspondence, insurance certificates or policies, appraisals, financial statements of Borrower; provided that, notwithstanding the foregoing provisions of this Section 1(e), Assignor and Assignee agree that Assignor shall not be required on the Conversion Date to deliver to Assignee any of the referenced documents (not constituting a Loan Document) it may have in its files but instead Assignor will retain copies of the documents in its files for not less than five years after the Conversion Date and upon the reasonable request of Assignee or Borrower will provide copies thereof to Assignee, at the expense of Borrower; and e. Each modification, amendment, assumption, and release, if any, executed by Assignor (if legally required) and/or Borrower (if legally required) of any of the items listed above, except for the Terminated Documents. 2. Assignee is purchasing the Loan for a purchase price of $[_]. Assignee hereby assumes and agrees to perform, from and after the date of recordation of this Assignment in the Official Records, all liabilities, obligations and duties of Assignor arising from and after the date hereof with respect to the Loan, including, without limitation, the obligations of Assignor under the Assigned Documents. 3. This Assignment may be executed in multiple counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. 4. This Assignment is made without any recourse or representation whatsoever, except to the extent set forth in the Forward Purchase Agreement. [REMAINDER OF PAGE LEFT INTENTIONALLY BLANK] E-1-3 Forward Purchase Agreement Vista Breeze EXECUTED as of the _______ day of _______, 20___. ASSIGNOR: THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A. By: Name: Title: GENERAL ACKNOWLEDGMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. STATE OF __________________________ ) ) COUNTY OF ) On ____________, 20__, before me, _________________________________, Notary Public, personally appeared _____________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of _____________ that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Signature of Notary Public (Seal) E-1-4 Forward Purchase Agreement Vista Breeze ASSIGNOR: BANK OF AMERICA, N.A., a national banking association By: Name: Title: GENERAL ACKNOWLEDGMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. STATE OF __________________________ ) ) COUNTY OF ) On ____________, 20__, before me, _________________________________, Notary Public, personally appeared _____________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of _____________ that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Signature of Notary Public (Seal) E-1-1 Forward Purchase Agreement Vista Breeze ASSIGNEE: HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA By:__________________________________ Name: Title: GENERAL ACKNOWLEDGMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. STATE OF __________________________ ) ) COUNTY OF ) On ____________, 20__, before me, _________________________________, Notary Public, personally appeared _____________________________, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of _____________ that the foregoing paragraph is true and correct. WITNESS my hand and official seal. Signature of Notary Public (Seal) E-8 Forward Purchase Agreement Vista Breeze SCHEDULE I ASSIGNED DOCUMENTS 1. Original Borrower Note 2. Original Funding Loan Agreement 3. Original Borrower Loan Agreement 4. UCC-1 Financing Statements 5. Any non-disturbance agreements delivered in connection with any leases, sub-leases, and/or sub-sub-leases 6. Any purchase options and rights of first refusal for the Project (if any) 7. All authority documents executed in connection with the above 8. Opinion(s) of counsel E-2-1 Forward Purchase Agreement Vista Breeze SCHEDULE II TERMINATED DOCUMENTS 1. Construction Disbursement Agreement by and between Borrower and Initial Funding Lender 2. Guaranty Agreement by Howard D. Cohen and Howard D. Cohen Revocable Trust U/A/D 4/6/1993 in favor of Initial Funding Lender 3. Collateral Assignment and Pledge of Developer Fees and Security Agreement (APC Vista Breeze Development, LLC) by APC Vista Breeze Development, LLC in favor of Initial Funding Lender 4. Collateral Assignment and Pledge of Developer Fees and Security Agreement (HACMB Development, LLC) by HACMB Development, LLC in favor of Initial Funding Lender 5. Collateral Assignment and Pledge of Partnership Interests and Security Agreement (APC Vista Breeze, LLC) by APC Vista Breeze, LLC in favor of Initial Funding Lender 6. Collateral Assignment and Pledge of Partnership Interests and Security Agreement (Vista Breeze HACMB, Inc.) by Vista Breeze HACMB, Inc. in favor of Initial Funding Lender 7. Investor Equity Assignment and Security Agreement by Borrower in favor of Initial Funding Lender 8. Assignment of Contracts by Borrower in favor of Initial Funding Lender 9. Assignment of Management Agreement and Subordination of Management Agreement and Fees by Borrower in favor of Initial Funding Lender, and consented and agreed to by Atlantic Pacific Community Management, LLC E-2-2 Forward Purchase Agreement Vista Breeze EXHIBIT E-2 FORM OF ALLONGE TO GOVERNMENTAL NOTE This Allonge is affixed to, and forms a part of, that certain Multifamily Housing Revenue Note, Series 2023 (Vista Breeze), dated December 15, 2023, in the original principal amount of THIRTY TWO MILLION FIVE HUNDRED THOUSAND AND 00/100 Dollars ($32,500,000), made by the Housing Finance Authority of Miami-Dade County, Florida, as Governmental Lender, and payable to Bank of America, N.A., as Funding Lender, the current holder of thereof. PAY TO THE ORDER OF CITIBANK, N.A., WITHOUT RECOURSE OR REPRESENTATION, AS OF _________, 20___ BANK OF AMERICA, N.A. By: Name: Title: E-3-1 Forward Purchase Agreement Vista Breeze EXHIBIT E-3 FORM OF ALLONGE TO ORIGINAL BORROWER NOTE This Allonge is affixed to, and forms a part of, that certain Construction Phase Project Loan Note, dated as of December 15, 2023, in the original principal amount of THIRTY TWO MILLION FIVE HUNDRED THOUSAND AND 00/100 Dollars ($32,500,000), made by Vista Breeze, Ltd., a Florida limited partnership, and payable to the Housing Finance Authority of Miami-Dade County, Florida, as Governmental Lender, and endorsed to The Bank of New York Mellon Trust Company, N.A., as fiscal agent, for the benefit of Bank of America, N.A., as Funding Lender, the current holder thereof. PAY TO THE ORDER OF HOUSING FINANCE AUTHORITY OF MIAMI-DADE COUNTY, FLORIDA, WITHOUT RECOURSE OR REPRESENTATION, AS OF _________, 20___ THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A. By: Name: Title: F-1 Forward Purchase Agreement Vista Breeze EXHIBIT F FORM OF CERTIFICATE OF SELLER The undersigned, BANK OF AMERICA, N.A., a national banking association (“Seller”) hereby represents and warrants as set forth below to CITIBANK, N.A. (“Purchaser”), as of [Month] [Day], 202[_], as an inducement to Purchaser to purchase the Loan, as defined in that certain Forward Purchase Agreement by and among Purchaser, Seller and VISTA BREEZE, LTD., a Florida limited partnership (“Borrower”), dated as of December 1, 2023 (the “Forward Purchase Agreement”). All capitalized terms not otherwise defined herein shall have the same definition as set forth in the Forward Purchase Agreement. 1. Entire Agreement. The Forward Purchase Agreement and the Assigned Documents, full and complete copies of each of which have been furnished to Purchaser, constitute the entire agreement among the parties thereto with respect to the matters set forth therein, and there are no agreements, understandings, warranties or representations with respect to the matters set forth therein except as specifically delineated in the foregoing documents. There has not been any written, oral or other modification, waiver, release, cancellation, extension or other change in any of the terms, covenants, or condition in the Assigned Documents in any material respect to the extent that they apply to the Permanent Loan or the obligors thereunder without the prior written consent of Purchaser. 2. No Release or Subordination. There has been no release or subordination of Seller’s interest in the Original Security Instrument or in any of the collateral for the Loan under the Assigned Documents. 3. Sole Owner and Holder. Seller is the sole legal and beneficial owner and holder of the interests of the “Funding Lender” under the Original Borrower Note and each of the documents executed by Borrower which relate thereto, with the sole and absolute power and authority to sell and transfer such interest in the Assigned Documents to Purchaser. 4. Amount Outstanding. The principal indebtedness outstanding under the Loan is $____________ and interest is paid through __________________, 202__. 5. No Obligation to Make Further Disbursement. The Loan is fully disbursed and there is no remaining obligation on the part of Seller to disburse any further sum in connection with the Loan. 6. No Known Default. To the actual knowledge of Seller, without investigation or inquiry, there is no uncured default with respect to the Loan. BANK OF AMERICA, N.A., a national banking association By: Name: Title: Forward Purchase Agreement G-1 Vista Breeze EXHIBIT G FORM OF RELEASE AND TERMINATION AGREEMENT THIS RELEASE AND TERMINATION AGREEMENT (this “Agreement”) is dated as of [Month] [Day], 202[_], by and among VISTA BREEZE, LTD., a Florida limited partnership (the “Borrower”), BANK OF AMERICA, N.A., a national banking association (“Seller”), and CITIBANK, N.A., a national banking association (“Purchaser”). (Seller and Purchaser are sometimes referred to herein collectively as “Lenders”). RECITALS: A. The Borrower previously applied to the Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic established pursuant to Chapter 421, Florida Statutes (the “Governmental Lender”) for a loan (the “Borrower Loan”) for the acquisition, construction, development and/or equipping of a 119-unit multifamily residential project, located in the City of Miami Beach, Miami-Dade County, Florida, known as Vista Breeze (the “Project”). B. The Borrower previously requested that the Governmental Lender enter into that certain Funding Loan Agreement, dated as of December 1, 2023 (the “Original Funding Loan Agreement”), among the Governmental Lender, The Bank of New York Mellon Trust Company, N.A., a national banking association, as fiscal agent (the “Fiscal Agent”), and Seller, pursuant to which Seller made a loan to the Governmental Lender in the original principal amount of $32,500,000 (the “Funding Loan” or the “Loan”), the proceeds of which Governmental Lender used to make the Borrower Loan. C. The proceeds of the Borrower Loan were loaned and disbursed to Borrower pursuant to that certain Borrower Loan Agreement, dated as of December 1, 2023 (the “Original Borrower Loan Agreement”). Borrower and Seller also entered into that certain Construction Disbursement Agreement, dated as of December 15, 2023 (the “Disbursement Agreement”), which provided for the manner, procedures and conditions of disbursements under the Borrower Loan. D. The Borrower Loan was evidenced by that certain Construction Phase Project Loan Note (the “Original Borrower Note”) dated as of December 15, 2023 (the “Closing Date”) made by Borrower payable to the order of Governmental Lender, as endorsed and assigned to Fiscal Agent for the benefit of Seller. E. The Borrower Loan was secured by, among other things, that certain Leasehold Mortgage, Assignment of Rents, Security Agreement and Fixture Filing, dated as of December 15, 2023, executed by Borrower for the benefit of Governmental Lender (the “Original Security Instrument”; and together with the Original Borrower Note, the Original Borrower Loan Agreement, the Disbursement Agreement and all other documents executed in connection with the Borrower Loan, collectively, the “Borrower Loan Documents”), which Original Security Instrument will encumber the Mortgaged Property. F. Pursuant to the Original Funding Loan Agreement, the Original Borrower Note, the Original Security Instrument, the Original Borrower Loan Agreement; the Funding Loan Forward Purchase Agreement G-2 Vista Breeze Documents (as defined in the Original Funding Loan Agreement; and together with the Borrower Loan Documents, collectively, the “Loan Documents”) and all other Borrower Loan Documents except for the Unassigned Rights (as defined in the Original Funding Loan Agreement), were assigned by the Governmental Lender to Fiscal Agent, for the benefit of the Seller to secure the Funding Loan. G. Subject only to completion of the Improvements and the other terms and conditions set forth in that certain Forward Purchase Agreement dated as of December 1, 2023 by and among Borrower, Seller and Purchaser (the “Forward Purchase Agreement”) to which a form of this Agreement is an exhibit, Purchaser has agreed to purchase the Loan, the Original Borrower Loan Agreement and Original Funding Loan Agreement, and certain of the Loan Documents, from Seller. Upon such purchase, an Assignment of Mortgage and Collateral Loan Documents (the “Assignment”) will be recorded in the recorder’s office of the county in which the Land is situated (the date upon which such recordation occurs being the “Conversion Date”), which Assignment will, among other things, assign and transfer the Original Borrower Note, the Original Security Instrument and certain of the Loan Documents to Governmental Lender, which will subsequently be assigned to the Fiscal Agent, for the benefit of the Purchaser. H. Pursuant to the terms of the Forward Purchase Agreement, the Terminated Documents (as defined in the Assignment) are to be released and terminated on the Conversion Date and shall not be deemed Loan Documents assigned to Purchaser. The documents other than the Terminated Documents being assigned to Purchaser pursuant to the Forward Purchase Agreement are herein referred to as the “Assigned Documents.” NOW, THEREFORE in consideration of the mutual promises contained herein and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties hereto do hereby agree as follows: SECTION 1 LOAN PURCHASE AND SALE Concurrently with the execution and delivery of this Agreement by Lenders and Borrower, the Lenders have caused the recordation of the Assignment and Purchaser has assumed all of Seller’s obligations under the Assigned Documents arising from and after the Conversion Date. In the event the Assignment is not or has not been recorded, this Agreement shall be of no force and effect. The Borrower acknowledges and agrees that from and after the Conversion Date, Seller shall have no obligations or liabilities under any of the Assigned Documents. SECTION 2 RELEASE AND ACKNOWLEDGMENT BY BORROWER 2.1.1 Release of Seller. Effective as of the Conversion Date, Borrower, for itself and each of its agents, employees, representatives, affiliates, assigns, and all persons acting by, through, under, or under control of any of the foregoing, and anyone claiming by, through or under them (all of the above hereinafter collectively referred to as “Releasor”), for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, hereby releases, waives and discharges any right to trial by jury (to the extent permitted by law), and hereby Forward Purchase Agreement G-3 Vista Breeze releases, waives, discharges, and covenants not to sue, Seller, its predecessors, successors, assigns and/or representatives, and each of their respective officers, directors, shareholders, affiliates, agents, employees, servicers (past and present, and their respective officers, directors, shareholders, affiliates, agents, and employees), (hereinafter collectively referred to as “Seller Releasee”), with respect to any and all past and present claims, causes of action, damages, demands, costs, and other liabilities of any kind, direct or indirect, known or unknown, foreseen or unforeseen, which any Releasor now has or which may arise in the future and which relate to or arise from any of the following: (i) any and all of the Seller’s (or beneficiaries’) obligations and liabilities in connection with the Loan or under any of the Assigned Documents whether accruing prior to or after the Conversion Date; (ii) any of Purchaser’s administration of the Loan after the Conversion Date; (iii) the conduct of any Seller Releasee relating to the negotiation, documentation, execution, and delivery of any of the Assigned Documents or the Forward Purchase Agreement and the documents executed in connection therewith; (iv) the review, approval or disapproval of any and all documents, instruments, projections, estimates, plans, specifications, drawings and other items submitted after the Conversion Date; (v) the disbursement of funds under the Loan after the Conversion Date; and (vi) any other actions, statements or omissions by the Seller Releasee in connection with the Loan occurring after the Conversion Date. 2.1.2 Release of Purchaser. Effective as of the Conversion Date, Releasor, for good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, hereby releases, waives and discharges any right to trial by jury (to the extent permitted by law), and hereby releases, waives, discharges, and covenants not to sue, Purchaser, its predecessors, successors, assigns and/or representatives, and each of their respective officers, directors, shareholders, affiliates, agents, employees, servicers (past and present, and their respective officers, directors, shareholders, affiliates, agents, and employees), (hereinafter collectively referred to as “Purchaser Releasee”), with respect to any and all past and present claims, causes of action, damages, demands, costs, and other liabilities of any kind, direct or indirect, known or unknown, foreseen or unforeseen, which any Releasor now has or which may arise in the future and which relate to or arise from any of the following: (i) any and all of the Purchaser Releasee’s (or beneficiaries’) obligations and liabilities in connection with the Loan or under any of the Assigned Documents accruing prior to the Conversion Date; (ii) any Seller Releasee’s administration of the Loan on or before the Conversion Date; (iii) the conduct of any Purchaser Releasee relating to the negotiation, documentation, execution, and delivery of any of the Assigned Documents or the Forward Purchase Agreement; (iv) the review, approval or disapproval of any and all documents, instruments, projections, estimates, plans, specifications, drawings and other items submitted to Purchaser Releasee prior to the Conversion Date; (v) the disbursement of funds under the Loan prior to the Conversion Date; and (vi) any other actions, statements or omissions by the Purchaser Releasee in connection with the Loan, the Land or the Improvements occurring before the Conversion Date. 2.1.3 Advice of Counsel. Borrower, for itself and each of the Releasors, hereby acknowledges that they have been advised by their legal counsel in connection with the granting of this waiver and release. Borrower agrees that if Borrower or any other Releasor asserts against any Seller Releasee or Purchaser Releasee (any of whom is a “Releasee”) any of the claims released herein, Borrower shall pay, in addition to any other damages caused to the Releasee thereby, all actual attorneys’ fees incurred by the Releasee in defending or otherwise responding to the released claims. Forward Purchase Agreement G-4 Vista Breeze 2.1.4 No Admission. It is expressly understood and agreed that the terms hereof are contractual and that the releases given hereby shall not be construed as an admission of liability, any liability being expressly denied. 2.1.5 Assignment of Claims. Borrower represents and warrants that it has not assigned, in whole or in part, any of the claims released herein. 2.1.6 Voluntary Waiver and Release. Borrower acknowledges that this waiver and release is voluntary and without any duress or undue influence, and is given as part of the consideration for Lenders entering into and consummating the transactions contemplated by the Forward Purchase Agreement. 2.2 Disbursement of Loan. Borrower acknowledges and agrees that the Loan has been fully disbursed and no further disbursement is required under the Original Borrower Note or any other Loan Documents, including the Terminated Documents. Borrower hereby waives any right to seek disbursement of any further Loan proceeds. 2.3 Subsequent Discovered Claims. Borrower expressly acknowledges that it may hereafter discover facts different from or in addition to those which it now believes to be true with respect to the release of claims. Borrower agrees that the foregoing release shall be and remain effective in all respect notwithstanding such different or additional facts. SECTION 3 TERMINATED DOCUMENTS As of the Conversion Date, the Terminated Documents shall not be deemed Loan Documents assigned to Purchaser and shall be deemed terminated and shall be of no further force or effect. SECTION 4 MISCELLANEOUS 4.1 Counterparts. This Agreement may be executed in counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument. 4.2 Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the State of Florida. 4.3 Invalid Provisions. If any one or more of the provisions of this Agreement shall for any reason be held to be invalid, unenforceable or illegal in any respect, such invalidity, illegality or unenforceability shall not affect any other provisions of this Agreement, and this Agreement shall be construed as if such invalid, illegal or unenforceable provisions had never been set forth. 4.4 Valid and Enforceable. Borrower represents and warrants to the Lenders that this Agreement constitutes a valid and binding obligation of Borrower and is enforceable against Borrower in accordance with its terms. 4.5 Attorneys’ Fees. In the event of any action at law or in equity in relation to this Agreement, the losing party shall pay the prevailing party’s actual attorneys’ fees and costs. Forward Purchase Agreement G-5 Vista Breeze 4.6 ADVICE OF INDEPENDENT COUNSEL. BORROWER HEREBY AGREES, REPRESENTS AND WARRANTS THAT IT HAS HAD THE ADVICE OF INDEPENDENT LEGAL COUNSEL OF ITS OWN CHOOSING, DULY ADMITTED TO PRACTICE IN THE STATE OF FLORIDA, IN NEGOTIATIONS FOR AND DURING THE PREPARATION OF THIS AGREEMENT, THAT IT HAS READ THE PROVISIONS OF THIS AGREEMENT, THAT ALL PROVISIONS OF THIS AGREEMENT HAVE BEEN FULLY EXPLAINED TO IT BY ITS ATTORNEYS, AND THAT IT IS FULLY AWARE AND UNDERSTANDS THE PROVISIONS OF THIS AGREEMENT AND THEIR LEGAL EFFECT AND CONSEQUENCES. BORROWER HEREBY AGREES, REPRESENTS AND WARRANTS THAT IT HAS EXECUTED THIS AGREEMENT ON THE ADVICE OF ITS ATTORNEYS, AFTER CAREFUL AND INDEPENDENT INVESTIGATION, AND IS NOT EXECUTING THIS AGREEMENT UNDER FRAUD, DURESS OR UNDUE INFLUENCE. [REMAINDER OF PAGE LEFT INTENTIONALLY BLANK] Forward Purchase Agreement G-6 Vista Breeze IN WITNESS WHEREOF, this Release and Termination Agreement is hereby made as of the date first written above. SELLER: BANK OF AMERICA, N.A., a national banking association By: Name: Title: PURCHASER: CITIBANK, N.A., a national banking association By: Name: Title: Deal ID No. 60001596 Forward Purchase Agreement G-7 Vista Breeze BORROWER: VISTA BREEZE, LTD., a Florida limited partnership By: APC Vista Breeze, LLC, a Florida limited liability company, its managing general partner By: ________________________ Name: Title: Forward Purchase Agreement H-1 Vista Breeze EXHIBIT H [RESERVED] Forward Purchase Agreement I-1 Vista Breeze EXHIBIT I NOTICE TO FISCAL AGENT VIA E-MAIL AND OVERNIGHT DELIVERY [DATE] The Bank of New York Mellon Trust Company, N.A. 4655 Salisbury Road, Suite 300 Jacksonville, Florida 33256 Attention: Miami-Dade HFA Relationship Manager Email: [_] Fax: (904) 645-1926 RE: Vista Breeze Funding Loan Principal Amount: $32,500,000 Re: Notice of Conversion Date/Funding Loan Agreement dated as of December 1, 2023 (the “Funding Loan Agreement”) among Bank of America, N.A., a national banking association (“Initial Funding Lender”), Housing Finance Authority of Miami-Dade County, Florida, a public body corporate and politic organized and existing under the laws of the State of Florida, as Governmental Lender, and The Bank of New York Mellon Trust Company, N.A., as Fiscal Agent. Dear [_]: The undersigned, as Initial Funding Lender with respect to the above-referenced Funding Loan Agreement, hereby notifies you of the occurrence of the purchase of the Funding Loan by Citibank, N.A., in its capacity as Permanent Lender (the “Permanent Lender”), on the Conversion Date (which occurred _______________, 20____) as contemplated by the terms of the Funding Loan Agreement. The Transferee Representations Letter required to be delivered pursuant to Section 2.6 of the Funding Loan Agreement was delivered by the Funding Lender on the Conversion Date (a copy of which is attached hereto as Exhibit A). Henceforth, pursuant to the Funding Loan Agreement, the Permanent Lender (and not the undersigned) shall be the Funding Lender for all purposes of the Funding Loan Agreement and the other Funding Loan Documents commencing on and after the Conversion Date. As provided in Section 8.6(a) of the Funding Loan Agreement, please update your books or other records maintained for the registration of the Funding Loan accordingly to reflect the Funding Lender as the registered owner thereof. All capitalized terms used herein and not otherwise defined have the meanings assigned in the Funding Loan Agreement. [SIGNATURE PAGE FOLLOWS] Forward Purchase Agreement I-2 Vista Breeze BANK OF AMERICA, N.A., a national banking association By: Name: Title: Forward Purchase Agreement I-3 Vista Breeze EXHIBIT A TO NOTICE TO FISCAL AGENT TRANSFEREE REPRESENTATIONS LETTER [See Attached] Forward Purchase Agreement J-1 Vista Breeze EXHIBIT J WIRE INSTRUCTIONS TRANSFER [DATE] The Bank of New York Mellon Trust Company, N.A. 4655 Salisbury Road, Suite 300 Jacksonville, Florida 33256 Attention: Miami-Dade HFA Relationship Manager Email: [_] Fax: (904) 645-1926 RE: Multifamily Housing Revenue Note, Series 2023 (Vista Breeze) To Whom It May Concern: Please accept this letter as direction to change the current wire instructions for payments to Citibank, N.A., the Funding Lender on the above-referenced note issue. Wire instructions are detailed on the attached Exhibit A. Below are two notarized signatures of Citibank, N.A. as the holder of the above-referenced note. Very truly yours, FUNDING LENDER: CITIBANK, N.A. By: ______________________________________ Name: ____________________________________ Title: _____________________________________ Phone Number _____________________________ CITIBANK, N.A. By: ______________________________________ Name: ____________________________________ Title: _____________________________________ Phone Number _____________________________ [INSERT APPROPRIATE NOTARY BLOCK FOR EACH SIGNATORY] Forward Purchase Agreement J-2 Vista Breeze EXHIBIT A TO WIRE INSTRUCTIONS TRANSFER WIRE INSTRUCTIONS Bank Name: Bank Address: Bank Account Name: ABA: Bank Account #: OBI Line 1: OBI Line 2: OBI Line 3: 4861-9583-1690v.5