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<br /> RATUiC',S <br /> A,oplications ~Ot' conVact ,'atinc:" on this issue 'la\e 'Jeen rwde to Moody's Investors Ser',ice, <br /> I",c. it'd Standa"d i, :')oor", Cor'['cl'atior:, A~ explanüticn of the si9nifica~ce of such ,'atirgs <br /> )~ obtained 'rom the company furnishing the rating, The ratings reflect only the respec- <br /> tive views cf such oroanizations and the City makes no representation as to the appropriate- <br /> ness of the ratings, There is no assurance that such ratings will continue for any given <br /> period of time or that they will not be revised downward or withdrawn entirely by either or <br /> both of SuCh rating companies, if in the judgment of either or both companies, circumstances <br /> so warrant. Any such downward revision or withdrawal of such ratings, or either of them, may <br /> have an adverse effect on the market price of the Certificates. <br /> TAX EXEMPTION <br /> The delivery of the Certificates is subject to an opinion of Mr, Rick p, Fisher, Bond Counsel <br /> to the City ("Bond Counsel"), to the effect that interest on the Certificates is exempt from <br /> all present Federal income taxes under the application statutes, published rulings, regula- <br /> tions and court decisions existing on the date of such opinion. The laws, regulations, court <br /> decisions and administrative regulations and rulings upon which the conclusion stated in Bond <br /> Counsel's opinion will be based are subject to change by the Congress, the Treasury Department <br /> and later judicial and administrative decisions. <br /> REGISTRATION AND QUALIFICATION OF CERTIFICATES FOR SALE <br /> The sale of the Certificates has not been registered under the Federal Securities Act of 1933, <br /> as amended, in reliance upon the exemption provided thereunder by Section 3(a) (2); and the <br /> Certificates have not been qualified under the Securities Act of Texas in reliance upon <br /> various exemptions contained therein; nor have the Certificates been qualified under the <br /> securities acts of any jurisdiction. The City assumes no responsibility for qualification of <br /> the Certificates under the securities laws of any jurisdiction in which the Certificates may <br /> be sold, assigned, pledged, hypothecated or otherwise transferred. This disclaimer of respon- <br /> sibility for qualification for sale or other disposition of the Certificates shall not be con- <br /> strued as an interpretation of any kind with regard to the availability of any exemption from <br /> securities registration provisions. <br /> LEGAL INVESTMENTS AND ELIGIBILITY TO SECURE PUBLIC FUNDS IN TEXAS <br /> Section 9 of the Bond Procedures Act of 1981 states: "All bonds issued by an issuer shall <br /> constitute negotiable instruments, and are investment securities governed by Chapter 8, Texas <br /> Uniform Commercial Code, notwithstanding any provisions of law or court decision to the con- <br /> trary, and are legal and authorized investments for banks, savings banks, trust companies, <br /> building and loan associations, savings and loan associations, insurance companies, fiduci- <br /> aries, and trustees, and for the sinking fund of cities, towns, villages, school districts, <br /> and other political subdivisions or public agencies of the State of Texas", The Act further <br /> provides that the bonds andlor certificates are eligible to secure deposits of public funds <br /> of the state, its agencies and political subdivisions, and are legal security for those <br /> deposits to the extent of their market value. No review by the City has been made of the <br /> laws in other states to determine whether the certificates are legal investments for various <br /> institutions in those states. <br /> LEGAL OPINIONS AND NO-LITIGATION CERTIFICATE <br /> The City will furnish a complete transcript of proceedings had incident to the authorization <br /> and issuance of the Certificates, including the unqualified approving legal opinion of the <br /> Attorney General of the State of Texas as to the Initial Certificate and any changes in denom- <br /> ations or form authorized in said proceedings, to the effect that the Certificates are valid <br /> and legally binding obligations of the City, and based upon examination of such transcript of <br /> proceedings, the unqualified approving legal opinion of Bond Counsel, to like effect and to <br /> the effect that the interest on the Certificates is exempt from Federal income taxation under <br /> applicable statutes, published rulings, regulations, and court decisions. The customary <br /> closing papers, including a certificate to the effect that no litigation of any nature has <br /> been filed or is then pending to restrain the issuance and delivery of the Certificates, or <br /> which would affect the provision made for their payment or security, or in any manner ques- <br /> tioning the validity of said Certificates will also be furnished. Bond Counsel was not <br /> requested to participate, and did not take part, in the preparation of the Notice of Sale and <br /> Bidding Instructions, the Official Bid Form and the Official Statement, and such firm has not <br /> assumed any responsibility with respect thereto or undertaken independently to verify any of <br /> -27- <br />