Continuing Disclosure

Digital Assurance Certification, L.L.C. (DAC)

The Capital Trust Agency has selected Digital Assurance Certification, L.L.C. (DAC), formerly an Ernst and Young LLP affiliate company, to serve as its dissemination agent for purposes of post-issuance compliance with SEC Rule 15c2-12. In this role, DAC serves both as the party responsible for ensuring timely compliance by CTA and its conduit borrowers with the filing requirements of the Rule, as well as a resource for any party wishing to obtain material disclosure information related to financings issued by CTA. As the holder of an SEC No-Action Letter, DAC is the nation’s best known post-issuance disclosure service provider.

The DAC system uses full bond name and 9-digit CUSIP numbers to avoid misfiling or loss of issuer and obligated person reports. Investors and other interested persons who wish to research CTA issues without accessing EMMA may access the DAC web site free of charge to review disclosure on municipal bonds issued by CTA . (Please note that a password is required to access the DAC web site; one can be obtained through the registration protocol at the “Rule 15c2-12 Compliance Login” on the DAC web site. If information being sought is not available, please contact offices of Capital Trust Agency by calling 850-934-4046. The DAC web site is available at: www.dacbond.com

Electronic Municipal Market Access (EMMA) System

The Municipal Securities Rulemaking Board (MSRB) is a self-regulatory organization created to protect municipal entities and the public interest by promoting a fair and efficient municipal market, regulating firms that engage in municipal securities and promoting market transparency. As a part of its mission, the MSRB created the EMMA System as a free online repository of information on virtually all municipal bonds. The free public access to official disclosures, trade data and other information about the municipal securities market regarding financings done by CTA can be found on EMMA at: www.emma.msrb.org

Post issuance compliance policies and procedures

Along side the continuing disclosure information CTA ensures to be available for the public, ensuring that tax-exempt debt maintains its tax-advantaged status is also of large importance.  In order to accomplish this goal CTA implemented policies and procedures to ensure each borrower is compliant with the tax laws relevant to their project.  An appointed compliance officer of each borrower will remit an annual post-issuance tax compliance certification of the tax-exempt bonds used for the project, and should they have any questions throughout the year have a designated compliance officer at CTA to communicate with.  These policies and procedures plus all relevant exhibits and references are available here: CTA Post Issuance Compliance Policies and Procedures