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EXHIBIT A ARBITRAGE REBATE STATEMENT This Arbitrage Rebate Statement is intended to set forth certain duties and requirements necessary for compliance with Section 148(0 of the Code to the extent necessary to preserve the tax exempt treatment of interest on the Note. This Statement is based upon Section 148(0 of the Code and, by analogy, to the Regulations. However, it is not intended to be exhaustive. Since the requirements of such Section 148(0 are subject to amplification and clarification, it may be necessary to supplement or modify this Statement from time to time to reflect any additional or different requirements of such Section and the Regulations or to specify that action required hereunder is no longer required or that some further or different action is required to maintain or assure the exemption from federal income tax of interest with respect to the Note. For purposes hereof, any covenant relating to a fund, account or subaccount established under the Resolution shall be deemed to apply only to that portion of such fund, account or subaccount allocable to the Note. SECTION 1. TAX COVENANTS. Pursuant to the Resolution, the Issuer has made certain covenants designed to assure that the interest with respect to the Note is and shall remain excludable from gross income for purposes of federal income taxation. The Issuer shall not, directly or indirectly, use or permit the use of any proceeds of the Note or any other funds or take or omit to take any action that would cause the Note to be an "arbitrage bond" within the meaning of Section 148 of the Code or that would cause interest on the Note to be included in gross income for federal income tax purposes under the provisions of the Code. The Issuer shall comply with all other requirements as shall be determined by Bond Counsel to be necessary or appropriate to assure that interest on the Note will be excludable from gross income for purposes of federal income taxation. To that end, the Issuer shall comply with all requirements of Section 148 of the Code to the extent applicable to the Note. SECTION 2. DEFINITIONS. Capitalized terms used herein, not otherwise defined herein, shall have the same meanings set forth in the Resolution and in the Issuer's Certificate as to Arbitrage and Certain Other Tax Matters relating to the Note, as appropriate. "Bond Counsel" means Nabors, Giblin & Nickerson, P.A., or such other firm of nationally recognized Bond Counsel as may be selected by the Issuer. "Bond Year" means any one-year period (or shorter period from the Issue Date) ending on the close of business on the day preceding the anniversary of the Issue Date; provided, however, that the Issuer may select any other day as the end of a Bond Year if such selection is made prior to the earlier of the final maturity date of the Note or the fifth anniversary of the Issue Date. A-1