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Bonds. Prospective purchasers of the Series 1989 Bonds should consult their own tax advisors concerning these matters. NON -ARBITRAGE BONDS The County has covenanted in the Resolution with the purchasers of the Series 1989 Bonds that it will make no use of the proceeds of the Series 1989 Bonds which will cause the Series 1989 Bonds to be or become "arbitrage bonds," and has further covenanted in the Resolution to comply with the requirements of Section 103 and 148 of the Internal Revenue Code of 1986, as amended, and regulations promulgated thereunder from time to time, during the term of the Series 1989 Bonds, if and to the extent applicable to maintain continuously the Federal income tax exemption of interest on the Series 1989 Bonds. Officials of the County have executed a certificate concerning the use of the proceeds of the Series 1989 Bonds in conformity with regulations issued under Sections 103 and 148 of the Code. LITIGATION In the opinion of the County Attorney, no legal proceedings are pending or threatened that materially affect the County's ability to perform its obligations to the holders of the Series 1989 Bonds or that materially affect the financial condition of the System. In the opinion of the County Attorney, there is no litigation or controversy of any nature now pending or, to the County's knowledge, threatened to restrain or enjoin the issuance, sale, execution or delivery of the Series 1989 Bonds or in any way contesting the validity of the Series 1989 Bonds or any proceedings of the County taken with respect to the authorization, sale or issuance of the Series 1989 Bonds or the pledge or application of any moneys provided for the payment of the Series 1989 Bonds. RATINGS It is expected that Moody's Investors Service and Standard & Poor's Corporation will assign a rating of "Aaa" and "AAA," respectively, to the Series 1989 Bonds on the understanding that the standard insurance policy, insuring the timely payment of the principal of and interest on the Series 1989 Bonds, will be issued by Financial Guaranty upon delivery of the Series 1989 Bonds. No application has been made to any other agency for a rating on the Series 1989 Bonds. A rating reflects only the views of the rating agency at the time such rating is given, and neither the.County nor the Underwriter make any representation as to the appropriateness of any rating. An explanation of the significance of the rating may be obtained from the rating agency providing such rating. There is no assurance that the ratings on the Series 1989 Bonds will continue 34