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January 21, 2025 The Industrial Development Authority of the County of Maricopa Maricopa County Board of Supervisors Re: Host Community Public Approval Request Pursuant to Section 147(f) of the Internal Revenue Code of 1986 for Issuance of Tax-Exempt Bonds by the Public Finance Authority to Finance Certain Education Facilities Located in Maricopa County, Arizona Dear Sir or Madam: Our firm serves as bond counsel for an upcoming transaction involving the sale of 100% of the goodwill of STVT-AAI Education Inc. (the “Company”), to Lindenwood Education System, a Missouri nonprofit corporation (the “Borrower”). The Borrower is undertaking a tax-exempt revenue bond financing in the maximum principal amount of $175,000,000 (the “Bonds”) through the Public Finance Authority (the “Issuer”) to finance certain costs associated with the acquisition and to pay certain other costs related to the issuance of the Bonds (collectively, the “Project”). Although much of the Company’s presence is online, the Project relates to, benefits, or is otherwise used in the integrated operation for educational services, including educational assets and associated operations for training and education programs for Arizona Automotive Institute and Ancora High School at several locations (the “Arizona Acquired Assets”) in Maricopa County, Arizona (the “County”). The maximum stated principal amount of the Bonds expected to be issued for the Arizona Assets is $8,500,000. The Issuer has statutory authority to issue its revenue bonds for projects located outside of the State of Wisconsin. In order for the Bonds to be issued as tax-exempt obligations under the Internal Revenue Code of 1986 (the “Code”), the approval of the highest elected official(s) of each jurisdiction in which Bond-financed assets are located must be obtained, following public hearing, as required by Section 147(f) of the Code (referred to below as the “TEFRA Approval”). Solely in order to satisfy the requirements of the Code, the Borrower is seeking TEFRA Approval of the Maricopa County Board of Supervisors as to the issuance of the portion of the Bonds that are to be issued to finance the Arizona Assets located in the County. At the request of the Borrower, The Industrial Development Authority of the County of Maricopa (the “Maricopa IDA”) has given Notice of Public Hearing at the time and in the manner required by the Code and will hold the public hearing required by the Code with respect to the Bonds and the Arizona Assets located in the County to be financed thereby on January 22, 2025. The Bonds will not constitute a debt or obligation of the Maricopa IDA, the County, the State of Arizona, or any other agency or political subdivision thereof. None of the Maricopa IDA, the County, or 2 January 21, 2025 the State of Arizona will have any obligations whatsoever with respect to the Bonds. The Bonds will constitute special, limited obligations of the Issuer, payable solely from funds pledged and assigned for the payment of the Bonds in accordance with their terms and the terms of the related bond documents. Please let me know if you have any questions or if you need anything further from our firm, the Company, or the Borrower. The Company and the Borrower greatly appreciate the assistance from the Maricopa IDA and from the Maricopa County Board of Supervisors in this matter, all of which will help the Borrower to continue its mission of service to the community through education. Sincerely, Tracy E. Shafton Bond Counsel cc: Meghan K. McKernan, Esq. Tyler M. Cobb, Esq.