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have an effect on both the Federal tax consequences resulting from ownership of Series 1996 Bonds and their market value. No assurance can be given that legislative proposals will not be introduced or enacted that would or might apply to, or have an adverse effect upon, the Series 1996 Bonds. Tax Treutita nt of Original Issue Discount Under the Code, the difference between the maturity amounts of the Series 1996 Bonds maturing in the years _ through _ and and the initial offering price to the public, excluding bond houses, brokers or similar persons or organizations acting in the capacity of underwriters or wholesalers, at which price a substantial amount of Series 1996 Bonds of the same maturity was sold is "original issue discount." Original issue discount will accrue over the term of the such Series 1996 Bonds at a constant interest rate compounded periodically. A purchaser who acquires such Series 1996 Bonds in the initial offering at a price equal to the initial offering price thereof to the public will be treated as receiving an amount of interest excludable from gross income for federal income tax purposes equal to the original issue discount accruing during the period he holds such Series 1996 Bonds, and will increase his adjusted basis in such Series 1996 Bonds by the amount of such accruing discount for purposes of determining taxable gain or loss on the sale or other disposition of such Series 1996 Bonds. The federal income tax consequences of the purchase, ownership and redemption, sale or other disposi- tion of Series 1996 Bonds which are not purchased in the initial offering at the initial offering price may be determined according to rules which differ from those above. Owners of such Series 1996 Bonds should consult their own tax advisors with respect to the precise determination for federal income tax purposes of interest accrued upon We, redemption or other disposition of Series 1996 Bonds and with respect to the state and local tax consequences of owning and disposing of Series 1996 Bonds. RATINGS Moody's Investors Service and Standard & Poor's Ratings Group have assigned ratings of "Aaa" and "AAA", respectively, to the Series 1996 Bonds, with the understanding that, upon delivery of the Series 1996 Bonds, the municipal bond insurance policy will be issued by Financial Guaranty Insurance Company. Such ratings reflect only the views of such organizations and any desired explanation of the significance of such ratings should be obtained from the rating agency furnishing the same, at the following addresses; Moody's Investors Service, Inc., 99 Church Street, New York, New York 10007; Standard & Poor's Ratings Group, 25 Broadway, New York, New York 10004, Generally, a rating agency bases its rating on the information and materials furnished to it and on investigations, studies and assumptions of its own. There is no assurance such ratings will continue for any given period of time or that such ratings will not be revised downward or withdrawn entirely by the rating agencies, if in the judgment of such rating agencies, circumstances so warrant. Any such downward revision or withdrawal of such ratings may have an adverse effect on the market price of the Series 1996 Bonds. DISCLOSURE PURSUANT TO SECTION 517.051, FLORIDA STATUTES Pursuant to Section 517.051, Florida Statutes, as amended by Chapter 87-316, Laws of Florida, no person may directly or indirectly offer or sell securities of the County except by an offering circular containing full and fair disclosure of all defaults as to principal or interest on its obligations since December 31, 1975, as provided by rule of the Florida Department of Banking and Finance (the "Department"). Pursuant to Rule 3E 400.003, Florida Administrative Code, the Department has required the disclosure of any amounts and types of defaults, any legal proceedings resulting from such defaults, whether a trustee or receiver has been appointed over the assets of the County, and certain additional financial information, unless the County believes in good faith that such information would not be considered material by a reasonable investor. The Series 1996 Bonds do not constitute a general debt, liability or obligation of the County, but are instead secured by the Pledged Funds and by other security discussed herein. The Series 1996 Bonds are not being offered on the basis of the financial strength of the County. Accordingly, the County, in good faith, believes that disclosure of any such default on bonds with respect to which the County was merely a conduit 27