Kutak Rock served as special tax counsel in connection with the issuance and sale by The Health, Educational and Housing Facility Board of the County of Knox of (i) $217,835,000 aggregate principal amount of its Student Housing Revenue Bonds (Provident Group - UTK Properties LLC - University of Tennessee Project), Series 2024A-1 (Tax-Exempt) and (ii) $2,510,000 aggregate principal amount of its Student Housing Revenue Bonds (Provident Group - UTK Properties LLC - University of Tennessee Project), Series 2024A-2 (Taxable).

The Series 2024A Bonds were issued for the purpose of providing funds to finance the costs of (i) construction of new student housing at the University of Tennessee, Knoxville campus, consisting of approximately 1,166 beds expected to be in 324 primarily semi‐suite style units in two buildings between Terrace Avenue and Caledonia Avenue and approximately 788 beds expected to be in 228 primarily semi‐suite style units at the intersection of Andy Holt Avenue and 20th Street and equipment, machinery, furnishings, and other personal property all replacements, substitutions, and additions thereto; (ii) associated site development, demolition of existing improvements, common area space, and off-site infrastructure improvements; (iii) acquisition of a ground lease and leasehold interest in the Campus Core Project, and the related real estate, fixtures, equipment and facilities; (iv) the acquisition, construction, furnishing, and equipping of other capital projects at the University of Tennessee, Knoxville campus; and (v) amounts required for reserves, working capital, capitalized interest, costs of issuance and other financing expenses related to the issuance of the Series 2024A Bonds, including amounts required to pay premiums for the Series 2024A Bond Insurance Policies and the Series 2024A Reserve Policy.