TEFRA Inperium Project

NOTICE OF PUBLIC HEARING CONDUCTED BY THE PENNSYLVANIA ECONOMIC DEVELOPMENT FINANCING AUTHORITY WITH RESPECT TO NOT TO EXCEED $156,823,000 OF PUBLIC FINANCE AUTHORITY REVENUE BONDS (INPERIUM PROJECT) SERIES 2026 AND NOT TO EXCEED $18,000,000 PUBLIC FINANCE AUTHORITY REVENUE BONDS (INPERIUM PROJECT) SERIES 2024

Notice is hereby given that on May 18, 2026, a public hearing, as required by Section 147(f) of the Internal Revenue Code of 1986, as amended (the “Code”), will be held by the Pennsylvania Economic Development Financing Authority (“PEDFA”) with respect to (i) the proposed issuance by the Public Finance Authority (the “Authority”) of its Revenue Bonds (Inperium Project) Series 2026 in one or more series (the “2026 Bonds”), in an amount not to exceed $156,823,000 (as further detailed below) and (ii) the change in use of proceeds (the “Available 2024 Proceeds”) of previously issued Public Finance Authority Revenue Bonds (Inperium Project) Series 2024 in the maximum principal amount of $18,000,000 (as further detailed below) (the “2024 Bonds”, and together with the 2026 Bonds, the “Bonds”), a portion of which in an amount not to exceed $133,757,000 (not to exceed $115,757,000 of the 2026 Bonds and not to exceed $18,000,000 of the 2024 Bonds), will be allocated to and used in the Commonwealth of Pennsylvania.  The Bonds will constitute “qualified 501(c)(3) bonds” within the meaning of Section 145(a) of the Code.  The hearing will commence at 10:00 am, or as soon thereafter as the matter can be heard.  Pursuant to Internal Revenue Procedure 2022-20, the hearing will be held via conference call by dialing the toll-free number 888-535-7020 and then when prompted, passcode 355 645 410#.

The Bonds are expected to be issued pursuant to Section 66.0304 of the Wisconsin Statutes, as amended, by the Authority, a commission organized under and pursuant to the provisions of Section 66.0301, 66.0303 and 66.0304 of the Wisconsin Statutes, as amended.

PROJECT:

Inperium, Inc., a Pennsylvania nonprofit corporation that is exempt from federal income tax as an organization described in Section 501(c)(3) of the Code (together with its affiliates or assigns, including, but not limited to, the affiliate owners referenced on Exhibit A below, the “Borrower“), and is the parent corporation of a network of multiple affiliated corporations and limited liability companies that offer a diverse array of human services, has requested the Authority to issue the Bonds, the proceeds of which will be loaned to the Borrower and, together with other available funds (including, but not limited to, Available 2024 Proceeds) used to pay all or a portion of the costs of a project (the “Project”) consisting of:

1. the acqui­sition of, or the reimbursement of acquisition costs related to, three nonprofit, federally tax-exempt 501(c)(3) providers of human services, KidsPeace Corporation, Children & Family Services Corporation and Crystal Lake Supportive Environments Inc. d/b/a Attain, Inc., and their respective tax-exempt affiliates (the “Acquired Providers”) with facilities and integrated operations offering an array of human services, including, but not limited to, mental and behavioral health services, located in Pennsylvania, Florida, Indiana and Maine (the “Acquisition Jurisdictions”) through the purchase of sole membership interests in such Acquired Providers;
2. the construction, improve­ment, and/or equipping of the facilities of the Borrower, including, but not limited to, the facilities of the Acquired Providers located in the Acquisition Jurisdictions (the “Construction Jurisdiction”);
3. the refinancing of lines of credit used by Borrower to fund some or a portion of the purchase of the membership interests of some or all of the Acquired Providers;
4. the acquisition by Borrower of information technology software and equipment to be part of its headquarters network located in Reading, Pennsylvania, for the delivery of its exempt services (the “Technology Jurisdiction”); and
5. the funding of required reserves and certain costs of issuance.

The Acquisition Jurisdictions and Technology Jurisdiction are collectively referred to herein as the “Project Jurisdic­tions“.

Available 2024 Proceeds will be allocated to the cost of acquiring KidsPeace Corporation and to the refinancing of lines of credit used by Borrower to fund such acquisition.

2026 BONDS:

The maximum principal amount of the Bonds issued for the Project is further detailed as follows:

 * The Project Jurisdictions located in Pennsylvania for which the hearing is being held are more fully detailed in Exhibit A below.

2024 BONDS:

The maximum principal amount of the 2024 Bonds being allocated to the Project is as follows:

* The Project Jurisdiction located in Pennsylvania for which the hearing is being held is more fully detailed in Exhibit A below.

All of the facilities and equipment to be financed or refinanced with the proceeds of the Bonds are or will be initially owned and/or operated by the Borrower either directly, as a sole corporate member or otherwise.  The 2026 Bonds will be, and the 2024 Bonds are, special limited obligations of the Authority payable solely from the loan repayments to be made by the Borrower to the Authority, and certain funds and accounts established by the bond indenture for each of the 2026 Bonds and 2024 Bonds, respectively.  The Bonds will not be a debt or other obligation of the Authority or of any other governmental entity in the State of Wisconsin, nor the Pennsylvania Economic Development Financing Authority or of any other governmental entity in the Commonwealth of Pennsylvania.  This notice is given pursuant to the provisions of Section 147(f) of the Code, Section 66.0304(11)(a) of the Wisconsin Statutes and Section 4 of the Amended and Restated Joint Exercise of Powers Agreement Relating to the Public Finance Authority.

The hearing will provide a reasonable opportunity to be heard for persons wishing to express their views on the merits of the Project, its Pennsylvania locations, the issuance of the 2026 Bonds for the Project, the 2024 Bonds and the application of the Available 2024 Proceeds to the Project, and/or related matters.  Oral comments will be limited to 10 minutes per speaker.  A person wishing to speak at the hearing will be asked to provide his or her name, address and the person(s’) or entity(ies) he or she represents, if any, prior to speaking.  Written comments will be accepted by Pennsylvania Economic Development Financing Authority c/o Craig Petrasic, Executive Director at crpetrasic@pa.gov but must be received by the start of the hearing.

Dated:  May 8, 2026

Exhibit A – Project Jurisdiction in Pennsylvania

PENNSYLVANIA