82-25 AUTHORIZING, APPROVING, RATIFYING AND CONFIRMING CERTAIN ADDITIONS AND CHANGES TO ECONOMIC DEVELOPMENT REVENUE BONDS (BRETTWOOD VILLAGE ASSOCIATES PROJECT)

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� i k Section 103(b) (6) of the Internal Revenue Code of 1954, as amended, issued after December 31, 1981. If H. R. 4420 becomes law in that form, all interest paid on the Bonds from the date of their issuance will become subject to federal income taxation. In such event, the Indenture provides that the Bonds must be redeemed as described in "THE BONDS -- Redemption Provisions -- Mandatory Redemption -- Taxability." In a statement that appeared in the Congressional Record on December 9, 1981, Representative Rangel announced his intention to offer an amendment to H. R. 4420 which would make the effective date of the bill prospective. As of the date of this Official Statement, Representative Rangel has not offered an amendment to H. R. 4420; Representative Rangel has stated that such an amend- ment would be offered in the event H. R. 4420 is considered by the House Ways and Means Committee after the House of Representatives reconvenes on January 25, 1982. If H. R. 4420 is amended in the form described by Representative Rangel, the tax-exempt status of the interest on the Series 1982 Bonds under the Code would be preserved. Issuance of the approving opinion of Bond Counsel is subject to the condition that H. R. 4420 (or a substitute bill therefor) , in the form in which such bill was introduced and is pending before the House Ways and Means Committee, shall not have become law in such form on the date of such opinion. No opinion will be expressed by Bond Counsel as to the effect of any changes in such legislation that may be proposed after the issuance and acceptance of the Bonds or of any other legislation. There can be no assurance as to what form any legislation with respect to the foregoing matters, if enacted by Congre ss, may take. Interest on the Bonds is not exemgt from present Illinois income taxes. LEGAL MATTERS Certain legal matters incident to the authorization and issuance of the Bonds are subject to the approving legal opinion of Chapman and Cutler, Chicago, Illinois, Bond Counsel (the proposed form of such opinion is included in this Official Statement as Appendix E). Certain legal matters will be passed upon for the Partnership by Winston & Strawn, Chicago, Illinois; for the Bank by internal legal counsel of the Bank; and for the Underwriter by Borge and Pitt, Chicago, Illinois. Chapman and Cutler will also deliver an opinion to the Underwriter with respect to the Letter of Credit. (The proposed form of such opinion is included as Appendix D). 38