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9 A 55 included in federal gross income, possibly from the date of issuance of the Bonds. The opinion of Bond Counsel assume compliance with these covenants. Bond Counsel has not undertaken to determine (or to inform any person) whether any actions taken (or not taken) or events occurring (or not occurring) after the date of issuance of the Bonds may affect the valuo of, or the tax status of interest on tho Bonds. Further, no assurance can be given that pending or future legislation or amendments to the Code, will not adversely affect the value of, or the tax status of interest on, the Bonds. Prospective owners are urged to consult their own tax advisors with respect to proposals to restructure the federal income tax. Bond Counsel is further of the opinion that interest on the Bonds is not a specific preference item for purposes of the federal individual or corporate alternative minimum taxes, although Bond Counsel observes that it is included in adjusted current earnings in calculating corporate alternative minimum taxable income. Although Bond Counsel has rendered an opinion that interest on the Bonds is excluded from federal gross income, and is exempt from State of California personal income taxes, the ownership or disposition of the Bonds, and the accrual or receipt of interest on the Bonds may otherwise affect an Owner's state or federal tax liability. The nature and extent of these other tax consequences will depend upon each Owner's particular tax status and the Owner's other items of income or deduction. Bond Counsel expresses no opinion regarding any such other tax consequences. Legal Opinion Nossaman, Guthner, Knox & Elliott, LLP, Irvine, California, will render an opinion with respect to the validity of the Bonds in substantially the form set forth in Appendix C hereto. Copies of such approving opinion will be available at the time of delivery of the Bonds. Jones Hall, A Professional Law Corporation, San Francisco, is serving as Disclosure Counsel to the Agency. Ratings The Bonds have received the rating of " " and " by Standard & Poor's Ratings Services, a Division of The McGraw -Hill Companies ( "S &P ") and Moody's Investors Service ( "Moody's "), respectively, with the understanding that upon execution and delivery of the Bonds the Policy insuring the payment when due of the principal and interest on the Bonds will be issued by Insurer. Such ratings reflect only the views of such organizations and an explanation of the significance of such rating may be obtained from S&P and Moody's. The rating issued reflects only the view of such rating agency, and any explanation of the significance of such rating should be obtained from such rating agency. There is no assurance that such rating will be retained for any given period of time or that they will not be revised downward or withdrawn entirely by such rating agency if, in the judgment of such rating agency, circumstances so warrant. Any such downward revision or withdrawal of any rating obtained may have an adverse effect on the market price of the Bonds. The Authority The City of Redwood City Public Financing Authority is a joint powers authority, organized under a Joint Exercise of Powers Agreement, dated as of June 18, 1991. The Agreement was entered into under the provisions of Articles 1, 2 and 4, Chapter 5, Division 7, Title 1 of the California Government Code (the "JPA Lawl. The Authority was created for the primary purpose of assisting the financing or refinancing of public capital improvements of the -37-