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(e) As an alternative to paragraph (d) above, the obligation of the Issuer to pay Rebatable Arbitrage to the United States, as described herein, shall be treated as satisfied with respect to the Note if the Gross Proceeds are expended for the governmental purposes of the issue within the periods set forth below: (i) at least fifteen percent (15%) of such Gross Proceeds are spent within the six-month period beginning on the Issue Date; (ii) at least sixty percent (60%) of such Gross Proceeds are spent within the 1 - year period beginning on the Issue Date; and (iii) at least one hundred percent (100%) of such Gross Proceeds are spent within the 18 -month period beginning on the Issue Date. As set forth in Section 1.148-7(d)(2) of the Regulations, for purposes of the expenditure requirements set forth in this paragraph (e), one hundred percent (100%) of the Gross Proceeds of the Note shall be treated as expended for the governmental purposes of the issue within the 18 -month period beginning on the Issue Date if such requirement is met within the 30 -month period beginning on the Issue Date and such requirement would have been met within such 18 - month period but for a reasonable retainage (not exceeding five percent (5%) of the Net Proceeds of the Note). If Gross Proceeds are in fact expended by such dates, then Rebatable Arbitrage need not be calculated and no payment thereof to the United States Department of Treasury need be made. Any failure to satisfy the final spending requirement shall be disregarded if the Issuer exercises due diligence to complete the project financed by the Note and the amount of the failure does not exceed the lesser of three percent (3%) of the issue price of the Note or $250,000. Use of Gross Proceeds to redeem the Note shall not be treated as an expenditure of such Gross Proceeds. For purposes of this paragraph (e), "Gross Proceeds" shall be modified as described in paragraph (d) above. [the following is not applicable to the Note] (f) As an alternative to paragraphs (d) and (e) above, the obligation to pay Rebatable Arbitrage to the United States, as described herein, shall be treated as satisfied with respect to the Note if the Available Construction Proceeds (as defined in Section 148(f)(4)(c)(vi) of the Code and described below) are expended for the governmental purposes of the issue within the periods set forth below: (i) at least ten percent (10%) of such Available Construction Proceeds are spent within the six-month period beginning on the Issue Date; (ii) at least forty-five percent (45%) of such Available Construction Proceeds are spent within the 1 -year period beginning on the Issue Date; A-7